kiefer, robyn v civ usarmy cenwk (us) jump, christine · from: kiefer, robyn v civ usarmy cenwk...

From Kiefer Robyn V CIV USARMY CENWK (US)To Jump ChristineCc Barker Justin Juett Lynn Young Scott E CIV USARMY CENWK (US) Leibbert Jason M CIV USARMY CENWK

(US)Subject West Lake Draft Final Remedial Investigation Addendum - USACE CommentsDate Friday December 15 2017 31137 PMAttachments USACE Comment Transmittal - Draft Final 2 RIA 12-15-17pdf

WLLF Final 2 RIA -USACE Comments+backcheck 12-15-17 MASTERxlsx

Chris

Attached are USACEs comments on the 2nd Draft Final Remedial Investigation Addendum Report Ive alsoincluded the excel file to aid you in preparing the full set of government comments

Let me know if you want to have a meeting to coordinatediscuss the comments

ThanksRobyn

Robyn KieferProject ManagerUS Army Corps of EngineersKansas City District

Phone 816-389-3615

DEPARTMENT OF THE ARMY CORPS OF ENGINEERS KANSAS CITY DISTRICT

635 FEDERAL BUILDING 601 E 12TH STREET

KANSAS CITY MO 64106-2824

Printed on Recycled Paper

December 15 2017 Ms Chris Jump Remedial Project Manager US Environmental Protection Agency Region 7 11201 Renner Boulevard Lenexa KS 66219 Dear Ms Jump The US Army Corps of Engineers (USACE) has completed a review of the Revised Draft of the ldquoRemedial Investigation Addendum West Lake Landfill Operable Unit-1rdquo report dated November 28 2017 and prepared on behalf of the West Lake Landfill OU-1 Respondents Group by Engineering Management Support Inc of Golden Colorado USACE comments are included in the attached Tables The first Table includes a back-check of the comments made on the draft version of the report Yellow highlighted cells indicate the comment has not been addressed Blue highlighted cells indicate that the comment requires information from EPA on disposition of the comment The second Table includes new comments on the Revised Draft report USACE is available to participate in comment clarification andor comment resolution meetings upon request Respectfully Robyn V Kiefer Project Manager CC Scott Young-CENWK-PM-E Jason Leibbert-CENWK-ED-E PDT

Final - Backcheck of Remedial Investigation Addendum Report dated June 16 2017 New comments on Final RIA Report dated Nov 28 2017

Comment

Reference Section Paragraph Appendix

Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017

1 Executive Summary and throughout report -General

Donakowski Avoid qualifiers such as generally and discuss data as qualatatively as possible (ie 97 of samples are below limits mean and median results are consistent with average background values etc)

EPA will incorporate this exactly Comment Closed

2 Executive Summary General

Lyons

On page 1 OU should be defined when it it is first used Recommend Paragraph 3 be presented first in order to introduce the Site It should be clearly stated which OU is the subject of the RI addendum and which media are addressed For example suggest stating that OU-1 at the site addresses SOIL AND SEDIMENT in two main areas Also the executive summary only addresses radionuclides however paragraph 2 on page 1 states this report will update dissusions of chemical extent etc Please clarify what (media and chemicals) is being addressed in this report and the BLRA vs what is being address under seperate OUs or RIs

EPA generaly agrees and will determine the best way to implement this There are a number of editorial comments regarding flow Balance against the timing of how long it will take to implement

Comment Closed Defer to EPA on direction they provided to PRPs

3 Executive Summary page 1 1st paragraph

Lyons The dates in the last sentence suggest this report addresses comments from EPA that were drafted prior to the submittal date of the report Please check the submittal date of the draft RI addendum (listed as July 29 2017)

EPA has incorporated Comment Closed

4 Executive Summary page 1 last paragraph

Lyons

This part of the ES should list the section headings of the report rather then these CSM subsections The purpose is to explain the flow of the RI report The CSM is a result of combining all of the topics listed but should not restate earlier parts of the report such as site description geology etc Rather the CSM should be briefly summarize all the main points of previous sections in section 9 The main purpose of the CSM is to provide a visual representation of the overall interpretration of the site which the report has provided in figures 7-1 and 9-1 The figures should be renumbered and referenced in section 9

EPA has asked that more narrative be included EPA agrees that Exec summary and CSM needs some work Issues wont include that CSM will be scaled back Will ask them to make other changes to reduce repetetiveness Ex explain better why no rim in Bridgeton landfill and how does info convey this EPA to let us know which comment this will be addressed in

Per EPA CSM is intended to be stand alone Comment Closed

5Executive Summary Page

ES-1 4th Paragraph and ES-2 1st paragraph

RankinsES-1 states The Site has been the subject of extensive investigation monitoring and sampling activities over the course of forty (40) yearshellip while ES-2 states Site has been greatly enhanced over the 30-plus years since the first investigations were performed There is an apparent discrepancy in the timelines presented

EPA had same issue when first reading and then determined 40 years is from discovey to now and 30 years is from investigation from now Will ask for some clarification

Comment Closed


ES-2 1st paragraph second sentence

Rankins

RIM at the site is defined using radium or thorium concentrations above backgoround but there is no mention of uranium as an indicator of radiological contamination although Section 626 list comined uranium of 545 pCig as an indication of RIM Also RIM should be determined by the combination of both radium and thorium isotopes compared to the 5 pCig limit (sum-of-ratios approach)

Will ask RPs to add Uranium U is glossed over bc there is no issue with U RPs willl be asked to do a better job of explaining Ur Ratios This comment was provided in the BLRA At site we use ARARs and other regs to set levels for PRGs to be evaluated If use sum of ratios approach how implement without saying current PRGs are meaningless PRGs are conservative in a variety of ways This was emailed to Jon If further discussion needed Jon to call Tom

Comment Closed


Kiefer Editorial-Spell out MSW the first time it is used Will address Addressed Comment Closed

8 Executive Summary page 2 3rd paragraph

Kiefer Editorial-Spell out RIA the first time it is used Will address Addressed Comment Closed

9 Executive Summary page 2 Lyons

The last two paragraphs are insufficient for summarizing the findings of the RI (ie nature and extent fate and transport and HHRA findings) Furthermore the potential migration pathways listed paragraph 2 does not include groundwater - it needs to be stated again here that groundwater is being deferred to OU-3 Also the text should not state that results are generally below regulatory standards because that only implies there are samples that are above the standards Instead the ES needs to summarize the data by media location and chemical Finally the last sentence says stormwater [results] indicated levels of radium and uranium were below drinking water standards however drinking water standards to not apply to storm water

EPA agrees in general The two paragraphs need to be expanded Will ask to remove generally below RE comparing Stormwater to drinking water standards - EPA is working on an official response

First full para on ES-3 compares stormwater runoff to 4 pCiL but doesnt say where the 4 pCiL comes from State which reg this is Otherwise ok as written

10 ESpage ES-2 first paragraph

Rankins

RIM is defined as any material containing combined radium (Ra-226 amp Ra-228) and combined thorium (Th-230 amp Th-232) at levels greater than 5 pCig above background Because the RIM at OU-1 is the result of the deposition of radiological wastes derived from former Manhattan Engineeing DistrictAtomic Energy Commission uranium ore processing activities that historically occurred at the St Louis Downtown Sites why is uranium not used to identify RIM in conjunction with the combined radium and combined thorium A similar comment was likely made on the Final Feasibility Study Report

Will provide a coment that includes the role that Ur has in definition of RIM

Comment addressed in ES and in document Comment closed

Backcheck Conductd 12-15-17

West Lake Landfill Superfund Site

Comment



11

Executive Summary page 2 2nd paragraph and

Section 98 Summary of Potential Risks

Kiefer States that an updated BLRA is being completed and will be submitted contemporaneously with this revised draft RI Addendum The BLRA should be referenced in Section 98 otherwise there is nothing to back up the summary provided in this discussion

Will direct to remove and reference actual report Addressed Comment Closed

12 Figure 6-12 and Figure 6-13 Kiefer Recommend showing Figure that outlines the extent of RIM based other than geostatistical analysis Implies a precision that is not there

Extent of RIM for geostatistical approach may not be the right thing to include in the RI EPA understands the perception concerns and will work a response

Not addressed in Final RIA Defer to EPA on decision

13 Figures 6-12 a and b Kiefer

Recommend showing the geostatistical estimate of RIM extent at all 5 increments Or at least indicate that these are the highest contaminated areas to be clear that these figures do not tell the whole story of where the contamianation is present There are many areas that are within the whole extent of RIM that are not shown for a particular elevation For example WL118 has contamination yet in this series of figures it is never highlighted yellow Because the topographical surface elevation isnt shown its hard to tell if the contaminated interval in WL118 just wasnt shown in these series of figures or if it was omitted The topographical elevation would also help to identify how deep the RIM is

Intent is to show vertical distribution and difficulty of excavation Not show complete vertical distribution Show surface distribution of RIM Topographic elevation is shown on diagrams 3d model being developed not sure if it will be available for final Some comments will be provided to show surface extent Show extent for that entire 5 interval (composite) and not just a small slice

Figures removed Comment Closed

14 Executive Summary page 3 2nd paragraph

Kiefer Should mention in this paragraph that groundwater migration path will be investigated under OU3 because it is a potential migration path

Will be addressed Addressed in first paragraph Comment Closed


Kiefer Reference to ambient air standard of 05 pCiL - recommend stating specific standard since specific number was cited Will be addressed Addressed Comment Closed


Kiefer First sentence is not worded correctly States there are no current exposures by on-site or off-site workers Recommend the word by be replaced with to

Will be addressed Addressed Comment Closed


Lyons The statement made need backed up by results from the BLRA For example need to state what the calculated risks are and what the risk range is

Will be addressedNo longer applicable as Executive Summary has been re-written Comment Closed

18 Table of Contents Lyons The report should include additional sections summarizing the HHRA and providing conclusions Conclusions should be definative statements about the media impact radionuclideschemicals of concern calculated risks data gaps and recommendations

Will be addressed Addressed Section 9 Comment Closed

19 Section 11last paragraph Rankins

Please explain the rationale and strategy behind the investigation of groundwater as part of a separate operable unit (OU-3) particularly if there are connections between the landfill media and groundwater Please indicate if OU-3 is to include groundater beneath OU-1 and OU-2 as well as off-site areas as well as all alluvial and bedrock units groundwater isolated perched zones seeps etc This explanation should be included as boiler plate text in the scope discussions for all CERCLA characterization and decision documents prepared for the WLL

EPA agrees in general EPA will provide language to RPs specifically for this This was EPA decision Jon to call Chris to clarify intent of last sentence

Addressed Comment Closed

20 Introduction Section 12 last paragraph

Kiefer States that modeling of potential leaching of radionuclides is being prepared separately after this RIA Please reference the report in this section of the RI

EPA said FampT model would not be incorporated into the RIA Yet RPs have incorporated this into certain sections Transport will be dealt with in OU3 EPA to make decision on whether or not to include this since it deals with OU3 USACE cant verify the info since we havent reviewed the FampT EPA to include comment but will be more expansive

Clarified in last sentence of Para 11 Comment Closed

21 Section 2 footnotes J Donakowski Given that the activities conducted in these work plans has been completed is there a need to state that the workplans were not approved or commented on

EPA specifically requested this RPs are including info from docs that EPA is not approving EPA didnt necessarily agree with how RPs were moving forward Will not be passing comment on USACE good with this

Defer to EPA Comment Closed

22 Section 22 paragraph 2 Kiefer The need for additional investigations after a ROD was issued is unclear It should be clearly stated here why additional investigations were required (public concern)


23 Section 22 paragraph 2 Kiefer Recommend include information regarding why the NCC was placed over portions of Area 1 and 2 or refer to section where this is discussed further


24 Section 2 section 3 KieferEditorial - There is a lot of information provided in this section (Summary of previous investigations) that doesnt make sense unless you have the site background information It might make more sense to put Summary of previous investigations after Site Background Information just does not flow appropriately

EPA agrees but will evaluate this and level of effort to RPs

Editiorial comment withdrawn

25 Section 31 last paragraph Kiefer

First sentence states [the West Lake site] hellipconsists of the various parcels that comprise the landfill property (on-property) and adjacent properties (off-property) where radionuclides have been or could be identified in the soil Consider clarifying this language so that the reader understands that the boundary of the superfund site was originally set up based upon this definition The way it reads now it reads in the current tense and the reference to could be identified implies that the nature and extent may not be determined

Will be addressed Clarified Comment Closed

Comment



26 Section 3321 2nd para 2nd to last line p 26

Speckin The diesel tank referred to in this paragraph could eventually corrode and result in a sinkhole at the surface It is recommended that this tank either be removed or closed in place by filling with flowable fill

USACE position the tank will corrode it will fall apart and there will be a sinkhole and cap can be impacted EPA will talk internally and get back to USACE on how to incorporate May have to be addressed as part of RD

EPA Cmt 28 Provide some additional information that they can gleen from aerial photography The revisions are probably ok but this will need to remain on the radar to potentially close the tank in place during RA


Speckin This indicates the North Quarry landfill overlaps the southeastern portion of Area 1 Shouldnt this be the southwestern portion This correction should be made to footnote 24 as well

Will be addressedEPA Cmt 265 RTC says change will be made but it was not 2nd to last line on the bottom of p 27

28 Section 3321 2nd paragraph

RankinsInclusion of or reference to a figure showing the areal extent of the NCC in radiological Area 1 relative to the RIM would provided a helpful visualization in understanding site charactistics as well as the conceptual model of the site How many acres of the 176-acre Area 1 are impacted by by RIM How many acres is the NCC

Will have RPs include acerage of Area 1 Will add surface rim info on same figure as NCC Confirm with Jon that this is his intent of this comment

Comment Closed

29 Section 3322 3rd paragraph

RankinsInclusion of or reference to a figure showing the areal extent of the NCC in radiological Area 2 relative to the RIM would provided a helpful visualization in understanding site charactistics as well as the conceptual model of the site How many acres of Area 2 are impacted by by RIM How many acres is the NCC


Comment Closed

30 Section 334 4th paragraph

Rankins

Since this section is giving a site history and description of the characteristics of Bridgeton Landfill North and South Quarry landfill areas and because of the publics expressed interests and concerns perhaps a summary discussion of the subsurface exothermic reaction (SSR) that is occurring in the Bridgeton Landfill South Quarry would be appropriate for this section along with a reference to Section 57 for more details regarding the SSR and actions being implemented to monitor and control the SSR

Will be addressed EPA to determine how this will be addressed

Comment Closed

31 Section 41 pdf page 56 2nd bullet

Kiefer States McLarenHart inventoried all existing monitoring wells which could be located at the landfill The language could be is confusing Either there are existing wells at the landfill or not Please clarify text

Misunderstood statement Withdraw comment Comment Withdrawn

32 Section 42 Kiefer This section titled Threatened and Endangered Species presents information about wetlands as well as threatened or endangered species assessment Recommend adding separate section on wetlands

Will be addressed by adding to heading Addressed Comment Closed

33 Section 433 KieferThis section mentions an ongoing SSR in South quarry and the ASPECT survey This is the first time the SSR is mentioned and there is no background provided in the report to give the reader an understanding of the SSR and concerns Recommend including this in the site background

Will be addressed Added discussion in Section 222 Comment closed

34 Section 434 paragraph 3 and Appendix A-4

Kiefer

All of the gamma surveys report in different units The McLaren Hart overland gamma survey reports in uRhr and uses a 20 uRhr background The ASPECT flyover uses a 6 sigma basis The Auxier uses 7001-14000 (no units listed in text or on Figure A-41) The background and relationship to sigma is explained in the McLaren Hart and ASPECT surveys but there is nothing to provide for interpretation of the Auxier gamma survey results on Fig A-41 with respect to a background or level Figures A-42 and A-43 have units of cpm It is not clear if the 7001-14000 reading or the cpm readings are of issue based on information provided Recommend this discussion be added to inform what can be interpreted from this data

Difficult to bring all of these into context There is no way to equate count data Investigations did not intend to use that Only the overland gamma survey is useful Explain how this data is used Very difficult to understand the data Does or does not coincide with CSM or extent of RIM determination Will add comment to try to get some clarity

Some additional clarification on how counts were interpreted was provided Comment Closed

35 Section 43last bullet RankinsClarification requestedWere the overland gamma surveys that were conducted in conjunction with the installation of the NCC over the RIM in Areas 1 and 2 done before or after installation of the NCC or both (ie so as to determine the effectiveness of the cover as a barrier to exposures) Who performed these surveys

Will ask RPs to address these questions by providing text to address this Chris to confirm with Jon if this is the intent of his comment or to provide examples

Clarified but not fully addressed

36 Section 434last paragraph

Rankins

Clarification requestedIts stated that the overland gamma surveys that were conducted in conjunction with the installation of the NCC over the RIM in Areas 1 and and that the surveys were condicted along the margins of the areas covered or to be covered by the road base material Were surveys done before or after installation of the NCC or both (ie so as to determine the effectiveness of the cover as a barrier to exposures) Who performed these surveys


Clarified but not confirmed in updated RIA

37 Section 435Rankins

Donakowski

Given that the activities conducted in these work plans has been completed is there a need to state that the workplans were not approved or commented on If BMAC is to be discussed please state the factorsconcerns that prompted EPA to target the BMAC for conducting gamma surveys

EPA will provide the language for PRs to inlcude in RIA


38 Section 435 Kiefer Laboratory verification samples were collected to confirm results Recommend that be mentioned here Will be addressed Not incorporated

39 Sections 44 and 45 Speckin Recommend combining the text of the 44 Soil Boring and Logging and 45 Sample Collection and Analysis for each investigationEditorial - Will ask RPs to try to commbine to provide ease of review

EPA Cmt 267 Was considered editorial RPs response was that change will be made but it was not made Because this is editorial comment is closed

40Section 442 1st para

after bullets 1st sentence p 41

Speckin This sentence should be broken into several sentences As written it suggests soil boring advancement down-hole radiological logging and soil-boring abandonment are ways to complete soil borings

Will be addressed in editorial sectionEPA Cmt 268 Change made satisfactory Comment Closed

41 Section 445 Kiefer First paragraph discusses isolation barrier but doesnt discuss what the barrier was to be used for That should be discussed to provide context for reader

Will be addressed EPA to discuss with their team on how to do that Addressed Comment Closed

Comment



42 Section 45 General Rankins

Regarding the soil boring investigations two background investigations were discussed in Sections 452 and 457 It is unclear if these represent the current soil BTVs for characterizing the OU1 Areas 1 and 2 Please add text somewhere in this section that indicates the sampling investigation(s) that has provided the basis for the RIA BTVs being used to characterize the site or instead refers the reader to Section 625 for an explanation of current BTVs

Will be addressed Comment Closed

43Section 4451 p 49 1st para 2nd and 3rd to last

linesSpeckin Indicates the GCPT encoutered refusal due to the presence of inert fill Was this concrete debris If so recommend concrete

debris or whatever it happended to be be used instead of inert fill The inertness of the fill had nothing to do with refusalWill be addressed (editorial)

EPA Cmt 48 Change made satisfactory Comment Closed

44 Section 452 para Starting All of the surfacehellip p58

Speckin On the first line it appears helliptwo sampleshellip should be helliptwo subsurface sampleshellip Will be addressed (editorial)EPA mt 52 Change made satisfactory Comment Closed

45 Section 452 Rankins

Very little information is provided in this section regarding the background soil samples collected during the OU1 RI (1995 - 1997) Apparently only 4 surface samples were collected from within the 6 - 12 inch depth interval Were any subsurface soil samples (ie gt 12 inches) collected from the same locations More information should be presented regarding the locations (reference areas) from where the 4 background samples were collected relative to the site Seems like the reader must wait until Section 6 and Figure 6-1 to find such information on the 4 background soil locations Either add this information to Section 452 or refer the reader to Section 6 and Figure 6-1 which also gives more details regarding the calculation of background threshold values (BTVs) for use in the RI Report Addendum (RIA) Report

More info regarding locations - a map is included EPA Will have RPs cite figure earlier in Section 4 There are no subsurface samples for background in same location Will not pass along questions Background data is fine for how its being used May refine in RD and definatley for buffer zone during RD Clarify with Jon that this is the meaning of his comment

Comment Closed

46 Section 455 Kiefer

States that lab reports were provided to EPA in the monthly status reports for March April and May 2016 If this information is post ROD recommend it be included as attachment to this RI report Recommend that all data relied upon in determining nature and extent since 2008 be included as attachment to this RI Report If not attached then at least refer to where it is summarized Data is summarized in Appendix D Recommend cover pages identify the sampling event dates not just NRC or OU-1 because there are no dates on these reports

This is data for FampT evaluations FampT report was taken out because it was very flawed Will be addressed as part of FampT comment

Comment Withdrawn based upon EPA explanation during comment coordination meeting

47 Section 456 1st paragraph Kiefer Spell out LBSR first time used Will be addressed (editorial) Addressed Comment Closed


Kiefer Recommend more detail be given as to why EPA questioned the subset of Cotter samples Will be addressed Addressed as part of what was added in last paragraph of this section Comment Closed

49 Section 456 last paragraph

Kiefer Recommend this paragraph summarize the findings of the data usability evaluation at a very high level Will be addressedAddressed as part of what was added in last paragraph of this section Comment Closed


It is unclear what prompted the EPA to investigate the BMAC Please state What depth intervals were investigated at the BMAC What depth intervals were sampled in the reference areas (Koch and Blanchette Parks) Are the data from the samples collected from the two reference areas and the resulting BTVs included in the current soil background data sets for the RIA and Updated Baseline Risk Assessment characterizations of the site

Will be addressed Include info to make the complete case on 2 sampling

Comment Closed


Recommend stating the exact number of samples that had results less than the BTVs in lieu of stating the majority of the sample results were less than the BTVs Recommend stating that all of the samples were below EPA PRGs Not sure why Tetra Tech compared this to FUSRAP RGs recommend this be deleted because BMAC is not a FUSRAP project and therefore FUSRAP RGs are not applicable Should only compare to PRGs

This is language from BMAC report Why TT compare to FUSRAP RGs There was a perception that EPA was adjusting the background so RGs would be used to compare to help the public understand comparison to FUSRAP Will include direction to remove the ref to FUSRAP this is not necessary for RI since no issues

Reference to FUSRAP not removed Understand that this is merely a citation of the report but it can be misleading since FUSRAP RGs are not applicable to West Lake

52 Section 41212 Kiefer Recommend reference to Fig 4-13 in this section as it identifies where the SED-1 through SED-4 samples referenced in the text are located


53 Section 4 and all subsections

KieferSome subsections report general results of analyses (Ex 457 41221 4123) and nearly all of the other subsections do not they just refer to the appendix where lab results are included Recommend consistency be applied and that each sub section indicates that the results are discussed in Section 7 of the report

USACE recommendation Talk about sampling and results in same place EPA concurs with comment Will ask them to be more consistent

Does not impact results just clarityconsistency of report therefore comment is withdrawn


KieferThere is reference to NCC-003 and NCC-004 Recommend you indicate that these are now called OU1-003 and OU1-002 for consistency between text lab reports and figure 4-15 Note that text states OU-1-001 but Figure 4-15 shows as OU1-001 Please correct text to ensure consistency


Comment



55 Section 41222 Appendix G

KieferAppendix G-4 has a chain of custody and sample results for a sample labeled as Buffer Zone and another as SCRRA1 I cannot correlate these samples to the text in Section 41222 or to any of the figures (4-15 or 4-16) Where were these samples taken Recommend they be located on one of the figures

Will ask because these are not the only two samples like this Not sure if they are decon samples

Did EPA resolve

56 Section 4 Kiefer

There is limited discussion on data validation for most of the data sets Validation is mentioned for GCPT soundings (4451) Phase 1 Investigation (453 and 454) testing performed by Cotter (456) and non-Radiological constituents in stormwater samples collected in 2016-17 (86) There isnt mention of data validation on any of the other sampling events conducted Table 7-13 7-24 8-3 8-4 8-5 and 8-6 footnotes states radionuclied EPA and MDNR data for groundwater samples is not validated Data relied upon for this report should be validated

Will ask RPs to clarify the foot notes and be consistent on which data has been validated or not validated OR explain level of validation

Table footnotes have been fixed Comment closed

57 Section 41312 Kiefer 2nd paragraph states all samples were well below the regulatory limit for workers of 5000 mremy Recommend remove the word well It is sufficient to state below the regulatory limit


58 Section 41312 J Donakowski It is stated that the regulatory limit for workers is 5000 mremyear This is the limit for radiation workers (ie workers expected to be exposed to gt 100 mremyear) Are workers at the WLLF trained as radiation workers per 10 CFR 19

Will be addressed NRC has specifc definition of radiation workers Just because they are working in an area of radiation does not classify them as radiation workers

Discussion deleted Comment Closed

59 Section 41315 J Donakowski

While the statement MDHSS consistently concluded that gamma radiation rates continued to be indistinguishablefrom natural background levels is true there are occaisional anomalous readings in the data which is not addressed by MDNR For example during the period from 8292013 to 922013 sustained exposure rate measurements above 40 uRhr were reported in multiple intervals Maximum gamma levels were reported at levels above 100 uRhr

USACE concern MDNR puts out reports and says gamma levels are not distiguishable from background levels The levels are distinguishable EPA Data peaks at 2pm When temp exceed 90 degrees the readings go up The offsite data confirms this USACE withdraws comments but recommends MDNR explain this

Comment Withdrawn

60 Section 41316 J Donakowski It may be more appropriate to compare air concentrations to 20 of the NRC effluent limits per 40 CFR 61 Subpart H

Tom wants to pass along but needs folow up bc EPA did not tell RPs to compare air data to a limit It was for a baseline for IB EPA established background air monitor without basline to compare upwind to down wind RP was supposed to compare to EPA data and RPs took it on themselves to compare to NRC data EPA will discuss internally prior to making decision to pass along

Comment not addressed USACE still feels the requirements of the clean air act per original comment are apppropriate to discuss here and change should be made

61 Section 41321 J Donakowski The half life of Rn-219 is four seconds not four days as stated Will be addresed Addressed Comment Closed

62 Section 4133 KieferWhat was purpose of NCC vegetation sampling To sample the vegetation that would be cut down during installation of the NCC Since NCC is installed would this sampling even be possible at this point If not this section should clarify the purpose and events and state that the sampling will not be completed because the NCC is already installed

Will ask RPs to provide explanation EPA will have to provide language Tested remaining vegetation to ensure no additional radionuclides in vegetation

Now in 4143 Addressed Comment Closed

63 Section 415 Kiefer Paragraph reads like the entire effort of historical aerial photograph evaluation was done by EPAs Environmental Monitoring Systems Laboratory Was all of this done by EPAs lab or was some done by the Respondents Recommend this be clarified

Will be addresed Addressed Comment Closed

64 Section 5 Speckin Recommend moving Section 5 to earlier in the document prior to description of investigationsWill be addressed (editorial) if not a huge level of effort Likely will be recommendations instead of requirement to make this change

EPA Cmt 251 RPs disagreed with comment Their response that information presented in Section 5 waas based on resutls of investigation is Section 4 so it would not make sense for 5 to come before 4 This response is reasonable Comment Closed

65Section 75114 and Figures 5-8 and 5-13

through 5-16Mathews-Flynn Text appropriately references the St Louis Formation However 75114 and the figures incorrectly reference St Louis Limestone

Recommend using formationWill be addressed Addressed Comment Closed

66 Section 61 par 3 Kiefer Editorial Recommend spell out LBSR in 61 It is spelled out with abbreviation in para 611 Withdraw - first spelled out in section 4 Addressed Comment Closed

67 Section 611 RankinsBarium sulfate mixed with top-soil is described as the primary RIM disposed of at the site What radiological isotopes are expected to be present in the material that was disposed of in WLL Is it expected to be solely radium and thorium or was urainum present

Ur is expected to be present bc material license and responses to NRC inquiries specifically list Ur content A comment will be made to clarify what is coming over from Latty Ave Clarify with Jon that is his intent of this comment

Comment Closed

68 611 1st para p 154 Speckin Recommend deleting this paragraph as it doesnt appear appropriate to include in an RI Will ask RPs to revise and EPA will provide specific direction on how to address

EPA Cmt 104 RPs did not delete the 1st 2 paragraphs as requested by EPA

69 Section 611 para 4 Kiefer Editorial Spell out FOB first time used Will be addressed Addressed Comment Closed

Comment



70 Section 611 1st bullet Kiefer

States excavated at trench see May 4 1971 aerial photo) to establish the depth of AM-7 pile subsidence While the aerial does show a trench or cut into the surface of the pile the reason for this is not verified The interpretation from Randall Grip with Sero-Data Corporatoin LLC states this is likely test trenching operations to determine the remaining material to be rmoved from the pile 1 area There is no mention in Mr Grips report of pile subsidence Recommend that this bullet match the language used by Mr Grip and that his report is specifically referenced Similiarly for the second bullet the aerials cannot determine the reason why things were done they just document the current conditions Recommed the text in the report be adjusted to reflect this


71 Section 611 footnote 62 Kiefer Recommend footnote or text indicate what the 06 mRhr allowable level is based upon Will be addressedNot addressed Recommend citing what regetc established the 06 mRhr allowable level

72 Section 611 pg 156 J Donakowski 06 MRhr should be mRhr Will be addressed Corrected Comment Closed

73 Section 612 para 1 Kiefer Recommend adding additional text regarding how radionuclides might be present in MSW Ex disposal of xxx (list xxxx household wastes)


74 Section 612 2nd para p 157

SpeckinThis paragraph indicates there was 43000 tons of [soil mixed with LBSR However the bullet at the top of p 156 says there was 39850 tons of soil mixed with 8700 tons of LBSR fir a total of 48550 tons Recommend changing one of these for consistency purposes

Will be addressedEPA Cmt 109 RPs added a footnote explaining the inconsistencies in information provided from various historical reports Change is satisfactory Comment Closed


It is stated that the background data obtained during the OU1 RI conducted by McLaren Hart around 1996 were used to determine BTVs for determining the occurrences and extent of RIM at Areas 1 and 2 However as is the case with the information provided earlier in Section 452 very little information is provided about the samples specifically the areas from which they were collected Additionally although the OU1 RIA background values were conservatively derived using decay chain considerations and are comparable (per Table 6-1) to those values derived during the 1996 RI (BV = mean + 2 SD) the NRC Ra-226 values and the values determined for other St Louis area sites (eg FUSRAP) there are some uncertainty issues relative to the RIA BTVs being used to identify and characterize RIM that warrant some discussion in the text First please discuss uncertainties associated with the application of BTVs derived from analytical data obtained for only 4 background surface soil samples to the characterization of both Areas 1 and 2 which comprise a combined area of 649 acres with a combined approximated RIM area and volume of 331 acres and 284600 cy (per Section 65) Also because the area from which the 4 background samples were collected is unknown it is unclear as to how well the soil conditionscharacteristics (radiological chemical physical) of the background samples are representative of conditions of the material at Areas 1 and 2 containing the RIM (ie if no radiological contamination were present) Since the RIM is comprised of soil and waste materials it is questionable as to how well the background soil sample conditions approximate conditions of the RIM It would seem that the background soil conditions would be more comparable to soil conditions at the Buffer Zone andor Crossroads Lot 2A2 areas where the combined area and volume of radiological extent of contamination comprise 45 acres and 3600 bcy (per Section 67) However combined size and soil volume for these areas also bring into the question the statistical representativeness only 4 background surface soil samples Please add a discussions to address all of these uncertainties and the potential impacts on identifying and characterizing RIM at Areas 1 and 2 as well as radiologically impacted soil at the Buffer Zone and Lot 2A2 areas

EPA recognizes background sampling is not done the way it currently is done Clarify with Jon what his recommendation is for estimating uncertainty Area where background samples is shown on a figure Verify comments about soil Background is important for residential Ask RPs to be transparent about the limits of the background set

Comment Closed


Paragraph on page 165 states Based on the Site background values presented above the criteria to be used toidentify RIM are as followsbull Radium-226+228 = 79 pCig70bull Thorium-230+232 = 79 pCigbull Combined uranium = 545 pCigThe combined uranium criteria should be discussed in the Executive Summary


77 Section 626fifth paragraph

Rankins

First please cite the source of the 71 mgkg mass equivalent for the 50 pCig uranium standard Also please note that EPAs current (June 2017) non-carcinogenic residential screening levels (RSLs) for uranium (soluble salts) are now 16 mgkg for residential exposures and 230 for industrial worker exposures (httpswwwepagovriskregional-screening-levels-rsls-generic-tables-june-2017) The change in uranium non-carcinogenic RSLs between the May 2016 and June 2017 RSL tables is that EPA has adopted the ATSDR-based intermediate minimum risk level (MRL) of 00002 mgkg-day resulting in the lower RSLs EPA is now recommending the use of the MRL when evaluating non-carcinogenic risks posed by uranium in the December 21 2016 memo entitled Considering a Noncancer Oral Reference Dose for Uranium for Superfund Human Health Risk Assessments The May 2016 RSL was derived based on the chronic oral reference dose (RfDo) 0003 mgkg-day which is still presented for use in the Integrated Risk Information System (IRIS) Based on the updated June 2017 residential and industrial RSLs for uranium that were derived using the ATSDR MRL of 00002 mgkg-day a cleanup of uranium to 50 pCig (71 mgkg) plus background would not meet unrestricted land use based on non-carcinogenic effects Further discussion of this change is needed with EPA because implementation of the MRL as the basis for developing cleanup standards to protect from noncarcinogenic effects from uranium exposures could have impacts not only for WLL Areas 1 and 2 but also on investigations and cleanups that have been performed regionally using the 50 pCig standard for uranium for the past two decades

First line will be incorporated EPA agrees that most current RSLs wll be used EPA has no choice but to use this Acknowledge that USACE is waiting on higher level authority for their lead projects This is not something that the RPs will need to addrsess Discuss with Jon

Comment Addressed Note that Army and DoD use the IRIS Oral Reference Dose This is an EPA site therefore defer to EPAs decision

78 Section 626 page 164 and 165

J Donakowski The cleanup goals for the SLDS and SLAPS Sites are 50 pCig U-238 not 50 pCig total U Will pass along Corrected Comment Closed

Comment



79 Section 65 page 171 J Donakowski Please more clearly define best-estimate ie 80 certainty 95 Will be addressedBest estimate was replaced with another equally uncertain word significantly If there is significant uncertainty then why use it

80 Figures 6-2 through 6-7 Kiefer Cannot find where these figures are referenced in text These are some of the most important figures for explaining nature and extent Please include references in appropriate locations within text

Will be addressed should be in Section 6 CSM etc

Addressed in section 63 Comment Closed

81 Section 67 p 175 3rd and 5th line

Speckin 3rd line - it appears are unknot knownhellip should be hellipare not knownhellip and 5th line it appears I 2016 should be In 2016hellip Will be addressed (editorial) EPA Cmt 275 Corrections made Comment Closed

82 Section 71111 Donakowski Is the statement The average flux for all of the other portions of Area 2 exclusive of these two locationshellip warranted given that this amounts to demonstrating that by eliminating elevated data only non-elevated data exists which is self evident

Will be addressedComment addressed by deleting sentence of concern Comment Closed

83 Section 7112 page 179 paragaraph 4

Kiefer

States comparison of Radon measurements were compared to relative probable risk Then states the measurements are nearly 10 times below the recommended EPA regulatory limit of 003 working level for indoor exposure The working levels are not a measuremnt of relative risk If the intent is to claim radon levels are below the CERCLA risk range then comparing levels to an UMTRCA working level does not seem appropriate

Will be addressed Clarification provided Comment Closed

84 Section 7112 page 180 top paragraph

Kiefer

The analysis in this paragraph is confusing States EPA health-based standard for radon is 05 pCiL but then states that Flare 2 stack results range from 83 +- 08 pCiL to 644 +- 65 pCiL This stack level is above the 05 pCiL However this paragraph doesnt state that It states that it compares well to a theoretical stack gas radon release for area 1 that might produce 19 pCiL Recommend this paragraph be restructured to compare first to the EPA health-based standard for radon and then separately discuss what occurs at the fenceline

EPA agrees that this is appropriate comment but needs to address potential language with air program

This is still confusing Seems like this could be simply addressed by comparing the radon sample results with something that translates to health-based risk for exposure

85 Section 7113 page 180 Kiefer Editorial - 3rd sentence - remove the second that from sentence processing or depository site that will not pose a substantialhellip


86 Section 7113 page 181 Kiefer Editorial 3rd paragraph - first sentence is not a complete sentence Withdraw Comment Withdrawn

87 Section 7121 page 183 J Donakowski It may be preferable to state that radiological results between upwind and downwind locations are not statistically significant as very minor is subjective

Will be addressed Use of very minor has been removed Comment Closed

88 Section 7122 84 J Donakowski It may be more appropriate to compare air concentrations to 20 of the NRC effluent limits per 40 CFR 61 Subpart H Same as comment 60 Comment Closed Defer to Comment 88 resolution

89 Section 7122 1st para p 184

Speckin Indicates concentration of gross Alpha from the 13 on-site monitoring stations were 3 to 4 times higher than the concentrations from EPAs off-site monitoring program Please indicate if the levels are above a health-based standard

Will be addressedEPA Cmt 143 Comment did not ask if it was above health based standard however the revised text appeared to address EPAs comment as submitted Comment Closed

90 Section 7122 para 2 2nd line

Speckin Recommend changing isotopic thorium uranium and by gamma spectroscopy to isotopic thorium and uranium by gamma spectroscopy

Will be addressed EPA Cmt 278 Correction made Comment Closed

91 Section 7122 para 2 3rd sentence

Speckin Recommend deleting As expected Also recommend explaining how it was determined that the results demonstrated only naturally occuring radioactive materials It is assumed this means the results are not reflective of the RIM on-site

will pass along as expected comment Will pass along second part too

EPA Cmt 144 Changes made as per EPA comment Comment Closed

92 Section 721 para 1 Speckin

Need to explain why stormwater runoff is being compared to MCLs This isnt drinking water therefore this isnt appropriate criteria to compare to Consider developing risk-based level for dermal contactThe last sentence indicates the primary criteria considered were drinking water standards for Ra-226 and Ra-228 However in a July 8th article the RPs were quoted as saying comparing storm water results to drinking water standards is not appropriate Therefore this will likely be viewed as contradictory to that statement

MCL vs drinking water for stormwater Due to state requirements EPA will determine language

EPA did not appear to submit this comment

93 Section 721 page 188 Kiefer Recommend that it be indicated if the lab results cited in these 2 paragraphs were filtered or unfiltered samples Will be addressed Addressed Comment Closed94 Section 722 and 723 Kiefer Recommend it be noted if these samples were filtered or unfiltered Will be addressed Addressed Comment Closed

95 Section 73111 73112 7312

Kiefer

The discussion on results only discusses results in terms of above RIM definition level but doesnt actually tell the results Recommend the concentrations be stated in a way to determine how much higher than the 79 pCiL level is present (high-low-avg concentration) This is important for natureextent determination however this section is labeled Radionuclide occurences in environmental media Im struggling with why this section (7) is necessary Seems like some of this should be included in Nature and Extent (section 6) discussion and some of it should be included in a Fate and Transport section (which does not appear to be a separate section of this RI report - there is one subsection 76 that addresses fate and persistence of radionuclides) There is a lot of redundant text that has already been covered in Section 4 (ex 75112 has same info as 4115 regarding attempts to get access to sample private wells)

Comparison to only meeting RIM definition level Will pass this along as it would be helpful to include (may be related to IK) Sec 6 is Nature and extent of RIM and Sec 7 is how RIM impacts env media EPA will make a comment on repetetiveness Editorial USACE defers to EPA on this


96 Figures 7-13 7-14 Kiefer Figures are labeled as Total Thorium but figure above title block says Uranium Explanation Should state Thorium Explanation Will be addressed Addressed Comment Closed

97 Section 7312 Kiefer Last paragraph - Compairs Pb210 to PRG by using the word near Suggest it state above the PRG Also states K-40 is not a known contaminant at the site however if its above the PRG it should be clearly stated

Will be addressedDiscusson of Pb 210 and K-40 appears to have been removed Comment Closed

98 Section 7312 page 195 J Donakowski Please clarify which exposure scenario (ie residential occupational etc) the PRG is relevent to and indicate the date the PRG was taken from the online calculator if the online tool was used

Will be addressed Sentence deleted Comment Closed

Comment




Speckin

This provides detailed explanation that a potential slope failure caused contamination on the adjacent Ford property and then goes on to explain this didnt actually occur and that the contamination was due to erosion Recommend reducing the slope failure description and simply mention that the it was initially thought the contamination on the Ford property was caused by a slope failure but it has been determined it was due to erosion

Appear to be referencing how it was characterized in original RI EPA will ask that they clarify that determination was updated

EPA Cmt 158 Satisfied with changes Comment Closed

100 751 752 and 874 J Donakowski

It may also be helpful to also discuss isotopic ratios (ie Th-230Th-232 Ra-228Ra-226) for groundwater (and sediment and leachate) results given that RIM has concentrations thorium and radium at levels appreciably different than natural levels and which vary by isotope (ie significantly more Th-230 or Ra-226 would likely be present in RIM impacted sediments and waters than Th-232 and Ra-228)

This goes away due to withdrawl of comment 101 Comment from USGS EPA will provide a comment but it will be different than how this is worded

Comment not addressed except in previous section 874 Comment does not significantly impact RI so comment is withdrawn

101 Section 75 p 199 Speckin Recommend considering removing Section 75 Radionuclides in Groundwater and just indicating it will be addressed in the OU3 RI Withdraw Comment Withdrawn

102 Section 75113 KieferRecommend showing results on a Figure and referencing it The Figures provide a much easier means for understanding the site conditions than the text

Will be addressed USGS has similar comment with suggestion

Not addressed Defer to EPA on whether or not they will require this from PRPs Must include this in OU3

103 Section 75123 Kiefer 4th bullet - suggest providing explanation why only 14 of 15 wells were sampled Will be addressed Addressed in footnote Comment Closed

104 Section 75123 KieferBullet 3 - recommend more clarity be provided with respect to resulting in greater analytical detections Do you mean that the improvements result in an ability to detect radium at a lower level (ie lower MDA) Use of the words greater analytical detections can be misinterpreted


105 Section 82 83 84 85 8687

KieferRecommend the non rad constituents listed in the bullets be compared with the regulatory limits so the natureextent of the contamination can be understood

Will be addressedAcceptable with statement in 2nd paragraph after bullets Comment Closed

106 Section 8 Kiefer Providing figures summarizing where non rad contamination has been identified would be helpful in understanding natureextentLimited hits may be why they didnt include figures Clarify if hits above MCLs and if so it is appropriate to have figure


107 Figures 8-6 8-7 8-8 8-12 and 8-13

LyonsThese figures show results for metals (iron manganese sulfate and chloride) compared against screening levels listed as MCLs However there are no MCLs for these metals The values listed are Secondary MCLs (SMCLS) and should be listed as such

Willl be addressedAddressed by using reference to Secondary MCL Comment closed

108 Section 9 KieferEditorial - this section contains repeated information from previous sections (site descriptionsetting history geology hydrology sourcesdistribution of RIM etc) Seems like the CSM should be introduced earlier in the report possibly as part of the Nature and Extent section Also see comment 3

EPA will ask to reduce competetiveness Wants CSM to be stand alone Editorial so USACE defers to EPA

Now CSM is Section 10 Comment Addressed in conjunction with EPA feedback on CSM to be stand-alone

109 Section 94 J Donakowski The cleanup goals for the SLDS and SLAPS Sites are 50 pCig U-238 not 50 pCig total U Will be addressed Addressed in section 626 4th paragraph Comment Closed

110 Section 96 J Donakowski Given that there has been recent discussion of natural events (surface fire flooding etc) it may be helpful to discussreference how these transport routes are mitigated (ie reference levee system in 932 installation of NCC cited in 9612 etc)


111 Section 961 Rankins Please note if volatile emissions (ie from organic compounds) was considered and the justification for elimination of this pathway

Will be addresed This was passed along in the BLRA comments too Will compare and ensure consistency

Addressed in 10512 Comment Closed

112 Section 9611 J DonakowskiIt may be helpful to discuss radon time-of-flight considerations that is due to the relatively long half life of radon compared to typical residence times of ambient outdoor air radon would not be anticipated to be localized in a single area long enough to appreciably in grow daughter products (which are the primary risk driver of radon)

Will be addressed This is discussed in BLRA Just need to make sure this is communicated with the BLRA for consistency

Comment not addressed in RIA however it if is addressed in BLRA then agree to close this comment

113 Section 971 RankinsGenerally Section 971 needs to be revised to better reflect the receptors as presented and discussed in the Updated Baseline Risk Assessment It might be better and more clear to discuss potential current receptors in the first paragraph and future receptors in the second paragraph

Will be addressed Addressed in 1061 Comment Closed

114 Section 971first paragraph

Rankins

In the third sentence of the first paragraph please add the word on-site before receptors Also please indicate that although there are currently no receptors in Areas 1 and 2 and the Buffer Zone there are potential on-property commercial building users and grounds keepers that work in areas adjacent to the aforementioned OU-1 areas These receptors were evaluated in the Updated Baseline Risk Assessment (see Table 13 of the risk assessment) Additionally current off-property receptors were considered andor evaluated such as the resident commercial building user recreationalintermittant user and groundskeeper The primary current off-property receptors of concern though are the resident and commercial building user


115 Section 971second paragraph

Rankins

Please describe the future receptors as follows on-property construction workers and storge yard workers on-property trespassers on- and off-property commerical building users grounds keepers and recreationalintermittant users and off-property farmers and residents Of the future on-property receptors the grounds keepers and strorage yard workers are the primary receptors of concern Of these two future receptors only the grounds keeper is assumed to spend time in OU-1

EPA will review BLRA and make determination on whether this applies anymore Will follow up with Jon


116 Section 98 Kiefer Recommend that the BLRA report be appropriately referenced (title date) Will be addressed Addressed Comment Closed

117 Section 98 KieferRecommend that actual risk numbers be presented here as opposed to just stating above or within CERCLA acceptable risk range Recommend BLRA be broken out as separate section not as part of CSM section Need to state that BLRA report will be under separate cover

Will be addressed

Risk broken out Risks still presented abovebelow risk range Generally acceptable Would rather see summary table of actual risks and comparison to CERCLA acceptable risk range Defer to EPA on presentation

Comment



118 Section 982 Kiefer Last paragraph last sentence should state helliprisks to off-property receptors are within the EPAs acceptable risk rangehellip Will be addressed Addressed Comment Closed

119 Section 982 Kieferparagraph 2 refers to an uncertainty section Need to be clear that section is not in the RIA but in the BLRA report (which is not attached to this RIA)


120 Section 982 J Donakowski Please clarify what direct contact with radium-226 entails Is this the gamma pathway or inhalationingestion or a combination of all pathways

Will be addressed Statement removed Comment Closed

121 App M Figure M 14 Speckin In some cases the Geostatisical Estimate of RIM Occurrence (purple dashed line) does not encompass clear instances of RIM For example on Figure M 14 PVC-38 shows a gamma count of 20000 cps yet is not included in the estimate of RIM

Will be addressedPer EPA cross section are being changed to reflect adjustments made in the geostat report Has not been verified as changes not provided

122 Table 4-3b Speckin The footnote indicates that the NRC boring locations are only approximate estimates yet the state plane coordinates are shown with an accuracy of 1100th of the foot

False sense of accuracy by showing 1100th of foot Recommend it go to nearest foot Will address

Could not find where comment was submitted Table still shows 1100 ft level of accuracy

Final - Backcheck of Remedial Investigation Addendum Report dated June 16 2017 New comments on Final RIA Report dated New Comments RIA - Nov 28 2017

Comment Reference Section

Paragraph AppendixCommentor Comment

1ES-2 last para 2nd

sentenceSpeckin

For consistency shouldnt the 79 pCig be introduced here The 50 pCig above background was included in the introduced in the 545 pCig concentration Or maybe just indicate uranium is 50 pCig above background and remove the 545

2 p27 last sentence Speckin Should say southwestern portion of Area 1 not southeastern This is also addressed in the backcheck comments

3445 p48 1st para

2nd sentenceSpeckin

Recommend changing to read hellipto prevent a subsurface heating event from coming in contact with the radioactive materials contained in the West Lake Landfill

4Section 626 Definition of RIM page 169 2nd

paragraphWhitfill

This is a confusing paragraph that may read better if the mini discussion of the buildup of Ra-226 from Th-230 is consolidated to a separate paragraph or re-written for better flow The future ingrowth has nothing to do with the derived response levels

5Section 75132 1st

para 4th to last sentence

Whitfill

NOTE This comment most likely is better applied to OU3 RI

Radium occurrences in Leachate page 225 first paragraph 4th to last sentences ldquoPrior to 2013 this involved testing of non-treated leachaterdquo

Is non-treated leachate still being tested If not this appears to be a lost opportunity and important to monitor at least periodically if leachate from Areas 1 and 2 are migrating through the different elevations to the lowest point where the leachate collection system is located I would think testing for Th-230 would also be prudent It is noted in Section 5622 that there is no liner or leachate collection system in Areas 1 and 2 If the leachate from these areas does not migrate towards the lower elevated leachate collection system then where does it go

6 Section 61 HaysThe process describing waste production is confusin at best and should be made into a figure or diagram Check use of K-65 for appropriatness stating K-65 may not be needed here

7 Section 62 Hays

Recommend the language from the SOR discussion of U data be moved more upfront in the definition discussions and used as a means to eliminate having to set a value The 50 pCig value is protective onsites without significant GW concerns The depth of the material and ground water concerns at WLLF causes concern for the appropriateness of the U value and as pointed out in the SOR comparison excess U is only found with excess Ra and Th thus not needed


USACE Comments -

Section 625 Hayspg 186 Use of term DCGL should be deleted as not appropriate here While conservative the approach of reducing the Ra-228 background to the Th-232 value is flawed as alpha spec for Th-232 often produces results less than Ra-228 analysis due to small aliquot size As such most projects use Ra-228 data as it better represents the actual conditions Again done conservatively as is

8 Section 626 Hayspg 188 new text discusses process of defining RIM as establishment of cleanup levels for the West Lake Landfill This should be deleted as not appropriate for an RI

9 Section 626 Hays pg 190 Delete statement that def of RIM is more stringent than criteria at North County FUSRAP

10 Section 626 Hays

In general the comparison of RIM def to FUSRAP clean up level discussions should be deleted and a simple table of values should be presented Language attempting to explain why FUSRAP criteria was selected is limited in usefulness and does not tell the complete story Using a simple table of stated values will allow the reader to determine the appropriateness of the definition without causing confusion and potential concerns for the FUSRAP sites

11 Section 7321 Hayspg 232 USACE previously commented on defining the source of PRGs (Donakowski cmt 98) and that comment was addressed in that section The use of PRG in this section should also be deleted or defined per comment 98

12 Section 75132 HaysThis section could be considered as misleading to public The stated permit levels are very high compared to typical environmental levels of concern but by stating all less than the permit levels it paints a diferent picture I realize this is an OU 3 issue and maybe as such should be deleted altogether

13 Section 9 1 Speckin The acrynom for lifetime cancer risks (LCR) is not in the list of acrynoms

14Section 93 p261 top

para last sentenceSpeckin

This sentence states that modeled radon activity in air from OU-1 is similar to background activity However the previous sentence indicates Future off-property risks are primarily attributable to radon and its daughter products in air If similar to background how can there be a risk exceedance because arnt we looking at increased risk from background conditions

15Section 1042 p 266

last lineSpeckin When refering to the 1977 EGampG flyover recommend referencing Appendix A-1

16Sectioin 1042 p 267

3rd paraSpeckin

Indicates that the above ground surface portion of the North Quarry started in 1979 However Figure 3-9 shows in started in 2002 Also recommend referencing 2002 It also may be helpful to include aerials up to the present in Appendix O

17Sectioin 1042 p 267 3rd para 2nd to last

sentenceSpeckin

Indicates fill above grade in the north quarry occurred long after placement of the LBSR-impacted soils Why not just give the year it began (2002) instead of being vague


top paraSpeckin When referring to the 1977 EGampG survey recommend referencing Appendix A-1

19Section 10511 p 269

1st full para 1st sentence

SpeckinRecommend providing a timeframe of this sampling and whether or not there were any noticeable changes from before and after the NCC cover Also reference Figure 4-20

20Section 10511 p 269

1st full para 2nd sentence

Speckin Recommend identifying the levels instead of just lt05 pCiL

21Section 10512 p270 1st para 1st sentence

Speckin Recommend referencing Figure 4-20 when discussing the 13 monitoring stations

22Section 10512 p270 2nd para 1st sentence

SpeckinDiscusses EPAs 5 monitoring stations Recommend indicating a date range when these monitoring stations were present and also providing a Figure showing the locations If a Figure already shows the locations recommend referencing it here


Speckin 32 pCIL should be 32 pCiL

24Section 1052 p271

2nd para last sentenceSpeckin

It seems more information should be provided to make this conclusion Only provided results of a single location and it does not justify the conclusion Recommend reference location of an expanded discussion andor data


4th para middle of para Speckin Recommend giving a concentration or range of concentrations of the vinyl chloride detections

26 Section 106 p273 Speckin Figure 9-3 should be referenced instead of Figure 9-1


3rd sentenceSpeckin This sentence appears to contradict the last sentence of this paragraph

28Section 1061 2nd

para pages 273 amp 274 Speckin The (for 1000 years in the future) does not need to come after each time the word future is used

29Section 107 p 274

2nd paraSpeckin

This paragraph states that unacceptable risks to future on-site workers could occur before 1000 years Couldnt this also be true for off-property receptors


2nd paraSpeckin

Indicates Zirconium anad cobalt are the primary contributors to His greater than 1 Are these an issue for the current scenario If so shouldnt this discussion be included in 1071 If not there should be a brief explanation why it is included in here and not under the current receptor discussion

31Section 1072 p 275 last para 2nd to last

sentenceSpeckin

How can radon be a risk if modeled levels are similar to naturally-occurring activity Isnt risk based on an increased level above background

WLLF Final 2 RIA -USACE Comments+backcheck 12-15-17 MASTERpdf

Backcheck of Jun 2016 RIA

New Comments Nov 2017 RIA

2017-12-15T145419-0600

KIEFERROBYNV1271182852



Sheet3

Security settings or invalid file format do not permit using USACE Comment Transmittal - Draft Final 2 RIApdf (343494 Bytes)


Comment







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Did EPA resolve

56 Section 4 Kiefer












Comment Withdrawn


















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Kiefer




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88 Section 7122 Page 184 J Donakowski It may be more appropriate to compare air concentrations to 20 of the NRC effluent limits per 40 CFR 61 Subpart H Same as comment 60 Comment Closed Defer to Comment 88 resolution
















95 Section 73111 73112 7312

Kiefer









Comment




Speckin















105 Section 82 83 84 85 8687





107 Figures 8-6 8-7 8-8 8-12 and 8-13


















Rankins




Rankins






Will be addressed


Comment
















1ES-2 last para 2nd

sentenceSpeckin



3445 p48 1st para

2nd sentenceSpeckin



paragraphWhitfill


5Section 75132 1st


Whitfill





7 Section 62 Hays






USACE Comments -

10 Section 626 Hays











3rd paraSpeckin



sentenceSpeckin




19Section 10511 p 269



20Section 10511 p 269









24Section 1052 p271








28Section 1061 2nd


29Section 107 p 274

2nd paraSpeckin



2nd paraSpeckin



sentenceSpeckin


Backcheck

DOC28Kiefer Robyn V CIV USARMY CENWK (US) 12152017 West Lake Draft Final Remedial Investigation Adpdf

DOC29Attachment1USACE Comment Transmittal - Draft Final 2 RIApdf

DOC29Attachment2WLLF Final 2 RIA -USACE Comments+backcheck 1xlsx

barcode 30325719

barcodetext 30325719



USACE Comments -

Comment Reference Section Paragraph Appendix Commentor Comment Backcheck

1 ES-2 last para 2nd sentence Speckin For consistency shouldnt the 79 pCig be introduced here The 50 pCig above background was included in the introduced in the 545 pCig concentration Or maybe just indicate uranium is 50 pCig above background and remove the 545


3 445 p48 1st para 2nd sentence Speckin Recommend changing to read hellipto prevent a subsurface heating event from coming in contact with the radioactive materials contained in the West Lake Landfill

4 Section 626 Definition of RIM page 169 2nd paragraph Whitfill This is a confusing paragraph that may read better if the mini discussion of the buildup of Ra-226 from Th-230 is consolidated to a separate paragraph or re-written for better flow The future ingrowth has nothing to do with the derived response levels

5 Section 75132 1st para 4th to last sentence Whitfill NOTE This comment most likely is better applied to OU3 RI Radium occurrences in Leachate page 225 first paragraph 4th to last sentences ldquoPrior to 2013 this involved testing of non-treated leachaterdquoIs non-treated leachate still being tested If not this appears to be a lost opportunity and important to monitor at least periodically if leachate from Areas 1 and 2 are migrating through the different elevations to the lowest point where the leachate collection system is located I would think testing for Th-230 would also be prudent It is noted in Section 5622 that there is no liner or leachate collection system in Areas 1 and 2 If the leachate from these areas does not migrate towards the lower elevated leachate collection system then where does it go

6 Section 61 Hays The process describing waste production is confusin at best and should be made into a figure or diagram Check use of K-65 for appropriatness stating K-65 may not be needed here

7 Section 62 Hays Recommend the language from the SOR discussion of U data be moved more upfront in the definition discussions and used as a means to eliminate having to set a value The 50 pCig value is protective onsites without significant GW concerns The depth of the material and ground water concerns at WLLF causes concern for the appropriateness of the U value and as pointed out in the SOR comparison excess U is only found with excess Ra and Th thus not needed

Section 625 Hays pg 186 Use of term DCGL should be deleted as not appropriate here While conservative the approach of reducing the Ra-228 background to the Th-232 value is flawed as alpha spec for Th-232 often produces results less than Ra-228 analysis due to small aliquot size As such most projects use Ra-228 data as it better represents the actual conditions Again done conservatively as is

8 Section 626 Hays pg 188 new text discusses process of defining RIM as establishment of cleanup levels for the West Lake Landfill This should be deleted as not appropriate for an RI


10 Section 626 Hays In general the comparison of RIM def to FUSRAP clean up level discussions should be deleted and a simple table of values should be presented Language attempting to explain why FUSRAP criteria was selected is limited in usefulness and does not tell the complete story Using a simple table of stated values will allow the reader to determine the appropriateness of the definition without causing confusion and potential concerns for the FUSRAP sites

11 Section 7321 Hays pg 232 USACE previously commented on defining the source of PRGs (Donakowski cmt 98) and that comment was addressed in that section The use of PRG in this section should also be deleted or defined per comment 98

12 Section 75132 Hays This section could be considered as misleading to public The stated permit levels are very high compared to typical environmental levels of concern but by stating all less than the permit levels it paints a diferent picture I realize this is an OU 3 issue and maybe as such should be deleted altogether


14 Section 93 p261 top para last sentence Speckin This sentence states that modeled radon activity in air from OU-1 is similar to background activity However the previous sentence indicates Future off-property risks are primarily attributable to radon and its daughter products in air If similar to background how can there be a risk exceedance because arnt we looking at increased risk from background conditions

15 Section 1042 p 266 last line Speckin When refering to the 1977 EGampG flyover recommend referencing Appendix A-1

16 Sectioin 1042 p 267 3rd para Speckin Indicates that the above ground surface portion of the North Quarry started in 1979 However Figure 3-9 shows in started in 2002 Also recommend referencing 2002 It also may be helpful to include aerials up to the present in Appendix O

17 Sectioin 1042 p 267 3rd para 2nd to last sentence Speckin Indicates fill above grade in the north quarry occurred long after placement of the LBSR-impacted soils Why not just give the year it began (2002) instead of being vague

18 Sectioin 1042 p 268 top para Speckin When referring to the 1977 EGampG survey recommend referencing Appendix A-1

19 Section 10511 p 269 1st full para 1st sentence Speckin Recommend providing a timeframe of this sampling and whether or not there were any noticeable changes from before and after the NCC cover Also reference Figure 4-20

20 Section 10511 p 269 1st full para 2nd sentence Speckin Recommend identifying the levels instead of just lt05 pCiL

21 Section 10512 p270 1st para 1st sentence Speckin Recommend referencing Figure 4-20 when discussing the 13 monitoring stations

22 Section 10512 p270 2nd para 1st sentence Speckin Discusses EPAs 5 monitoring stations Recommend indicating a date range when these monitoring stations were present and also providing a Figure showing the locations If a Figure already shows the locations recommend referencing it here

23 Section 1052 p271 1st para 1st sentence Speckin 32 pCIL should be 32 pCiL

24 Section 1052 p271 2nd para last sentence Speckin It seems more information should be provided to make this conclusion Only provided results of a single location and it does not justify the conclusion Recommend reference location of an expanded discussion andor data

25 Section 1054 p 272 4th para middle of para Speckin Recommend giving a concentration or range of concentrations of the vinyl chloride detections


27 Section 1061 1st para 3rd sentence Speckin This sentence appears to contradict the last sentence of this paragraph

28 Section 1061 2nd para pages 273 amp 274 Speckin The (for 1000 years in the future) does not need to come after each time the word future is used

29 Section 107 p 274 2nd para Speckin This paragraph states that unacceptable risks to future on-site workers could occur before 1000 years Couldnt this also be true for off-property receptors

30 Section 1072 p 275 2nd para Speckin Indicates Zirconium anad cobalt are the primary contributors to His greater than 1 Are these an issue for the current scenario If so shouldnt this discussion be included in 1071 If not there should be a brief explanation why it is included in here and not under the current receptor discussion

31 Section 1072 p 275 last para 2nd to last sentence Speckin How can radon be a risk if modeled levels are similar to naturally-occurring activity Isnt risk based on an increased level above background




Comment Reference Section Paragraph Appendix Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017

1 Executive Summary and throughout report -General Donakowski Avoid qualifiers such as generally and discuss data as qualatatively as possible (ie 97 of samples are below limits mean and median results are consistent with average background values etc) EPA will incorporate this exactly Comment Closed

2 Executive Summary General Lyons On page 1 OU should be defined when it it is first used Recommend Paragraph 3 be presented first in order to introduce the Site It should be clearly stated which OU is the subject of the RI addendum and which media are addressed For example suggest stating that OU-1 at the site addresses SOIL AND SEDIMENT in two main areas Also the executive summary only addresses radionuclides however paragraph 2 on page 1 states this report will update dissusions of chemical extent etc Please clarify what (media and chemicals) is being addressed in this report and the BLRA vs what is being address under seperate OUs or RIs EPA generaly agrees and will determine the best way to implement this There are a number of editorial comments regarding flow Balance against the timing of how long it will take to implement Comment Closed Defer to EPA on direction they provided to PRPs

3 Executive Summary page 1 1st paragraph Lyons The dates in the last sentence suggest this report addresses comments from EPA that were drafted prior to the submittal date of the report Please check the submittal date of the draft RI addendum (listed as July 29 2017) EPA has incorporated Comment Closed

4 Executive Summary page 1 last paragraph Lyons This part of the ES should list the section headings of the report rather then these CSM subsections The purpose is to explain the flow of the RI report The CSM is a result of combining all of the topics listed but should not restate earlier parts of the report such as site description geology etc Rather the CSM should be briefly summarize all the main points of previous sections in section 9 The main purpose of the CSM is to provide a visual representation of the overall interpretration of the site which the report has provided in figures 7-1 and 9-1 The figures should be renumbered and referenced in section 9 EPA has asked that more narrative be included EPA agrees that Exec summary and CSM needs some work Issues wont include that CSM will be scaled back Will ask them to make other changes to reduce repetetiveness Ex explain better why no rim in Bridgeton landfill and how does info convey this EPA to let us know which comment this will be addressed in Per EPA CSM is intended to be stand alone Comment Closed

5 Executive Summary Page ES-1 4th Paragraph and ES-2 1st paragraph Rankins ES-1 states The Site has been the subject of extensive investigation monitoring and sampling activities over the course of forty (40) yearshellip while ES-2 states Site has been greatly enhanced over the 30-plus years since the first investigations were performed There is an apparent discrepancy in the timelines presented EPA had same issue when first reading and then determined 40 years is from discovey to now and 30 years is from investigation from now Will ask for some clarification Comment Closed

6 Executive Summary Page ES-2 1st paragraph second sentence Rankins RIM at the site is defined using radium or thorium concentrations above backgoround but there is no mention of uranium as an indicator of radiological contamination although Section 626 list comined uranium of 545 pCig as an indication of RIM Also RIM should be determined by the combination of both radium and thorium isotopes compared to the 5 pCig limit (sum-of-ratios approach) Will ask RPs to add Uranium U is glossed over bc there is no issue with U RPs willl be asked to do a better job of explaining Ur Ratios This comment was provided in the BLRA At site we use ARARs and other regs to set levels for PRGs to be evaluated If use sum of ratios approach how implement without saying current PRGs are meaningless PRGs are conservative in a variety of ways This was emailed to Jon If further discussion needed Jon to call Tom Comment Closed

7 Executive Summary page 2 1st paragraph Kiefer Editorial-Spell out MSW the first time it is used Will address Addressed Comment Closed

8 Executive Summary page 2 3rd paragraph Kiefer Editorial-Spell out RIA the first time it is used Will address Addressed Comment Closed

9 Executive Summary page 2 Lyons The last two paragraphs are insufficient for summarizing the findings of the RI (ie nature and extent fate and transport and HHRA findings) Furthermore the potential migration pathways listed paragraph 2 does not include groundwater - it needs to be stated again here that groundwater is being deferred to OU-3 Also the text should not state that results are generally below regulatory standards because that only implies there are samples that are above the standards Instead the ES needs to summarize the data by media location and chemical Finally the last sentence says stormwater [results] indicated levels of radium and uranium were below drinking water standards however drinking water standards to not apply to storm water EPA agrees in general The two paragraphs need to be expanded Will ask to remove generally below RE comparing Stormwater to drinking water standards - EPA is working on an official response First full para on ES-3 compares stormwater runoff to 4 pCiL but doesnt say where the 4 pCiL comes from State which reg this is Otherwise ok as written

10 ESpage ES-2 first paragraph Rankins RIM is defined as any material containing combined radium (Ra-226 amp Ra-228) and combined thorium (Th-230 amp Th-232) at levels greater than 5 pCig above background Because the RIM at OU-1 is the result of the deposition of radiological wastes derived from former Manhattan Engineeing DistrictAtomic Energy Commission uranium ore processing activities that historically occurred at the St Louis Downtown Sites why is uranium not used to identify RIM in conjunction with the combined radium and combined thorium A similar comment was likely made on the Final Feasibility Study Report Will provide a coment that includes the role that Ur has in definition of RIM Comment addressed in ES and in document Comment closed

11 Executive Summary page 2 2nd paragraph and Section 98 Summary of Potential Risks Kiefer States that an updated BLRA is being completed and will be submitted contemporaneously with this revised draft RI Addendum The BLRA should be referenced in Section 98 otherwise there is nothing to back up the summary provided in this discussion Will direct to remove and reference actual report Addressed Comment Closed

12 Figure 6-12 and Figure 6-13 Kiefer Recommend showing Figure that outlines the extent of RIM based other than geostatistical analysis Implies a precision that is not there Extent of RIM for geostatistical approach may not be the right thing to include in the RI EPA understands the perception concerns and will work a response Not addressed in Final RIA Defer to EPA on decision

13 Figures 6-12 a and b Kiefer Recommend showing the geostatistical estimate of RIM extent at all 5 increments Or at least indicate that these are the highest contaminated areas to be clear that these figures do not tell the whole story of where the contamianation is present There are many areas that are within the whole extent of RIM that are not shown for a particular elevation For example WL118 has contamination yet in this series of figures it is never highlighted yellow Because the topographical surface elevation isnt shown its hard to tell if the contaminated interval in WL118 just wasnt shown in these series of figures or if it was omitted The topographical elevation would also help to identify how deep the RIM is Intent is to show vertical distribution and difficulty of excavation Not show complete vertical distribution Show surface distribution of RIM Topographic elevation is shown on diagrams 3d model being developed not sure if it will be available for final Some comments will be provided to show surface extent Show extent for that entire 5 interval (composite) and not just a small slice Figures removed Comment Closed

14 Executive Summary page 3 2nd paragraph Kiefer Should mention in this paragraph that groundwater migration path will be investigated under OU3 because it is a potential migration path Will be addressed Addressed in first paragraph Comment Closed

15 Executive Summary page 3 2nd paragraph Kiefer Reference to ambient air standard of 05 pCiL - recommend stating specific standard since specific number was cited Will be addressed Addressed Comment Closed

16 Executive Summary page 3 3rd paragraph Kiefer First sentence is not worded correctly States there are no current exposures by on-site or off-site workers Recommend the word by be replaced with to Will be addressed Addressed Comment Closed

17 Executive Summary page 3 3rd paragraph Lyons The statement made need backed up by results from the BLRA For example need to state what the calculated risks are and what the risk range is Will be addressed No longer applicable as Executive Summary has been re-written Comment Closed

18 Table of Contents Lyons The report should include additional sections summarizing the HHRA and providing conclusions Conclusions should be definative statements about the media impact radionuclideschemicals of concern calculated risks data gaps and recommendations Will be addressed Addressed Section 9 Comment Closed

19 Section 11last paragraph Rankins Please explain the rationale and strategy behind the investigation of groundwater as part of a separate operable unit (OU-3) particularly if there are connections between the landfill media and groundwater Please indicate if OU-3 is to include groundater beneath OU-1 and OU-2 as well as off-site areas as well as all alluvial and bedrock units groundwater isolated perched zones seeps etc This explanation should be included as boiler plate text in the scope discussions for all CERCLA characterization and decision documents prepared for the WLL EPA agrees in general EPA will provide language to RPs specifically for this This was EPA decision Jon to call Chris to clarify intent of last sentence Addressed Comment Closed

20 Introduction Section 12 last paragraph Kiefer States that modeling of potential leaching of radionuclides is being prepared separately after this RIA Please reference the report in this section of the RI EPA said FampT model would not be incorporated into the RIA Yet RPs have incorporated this into certain sections Transport will be dealt with in OU3 EPA to make decision on whether or not to include this since it deals with OU3 USACE cant verify the info since we havent reviewed the FampT EPA to include comment but will be more expansive Clarified in last sentence of Para 11 Comment Closed

21 Section 2 footnotes J Donakowski Given that the activities conducted in these work plans has been completed is there a need to state that the workplans were not approved or commented on EPA specifically requested this RPs are including info from docs that EPA is not approving EPA didnt necessarily agree with how RPs were moving forward Will not be passing comment on USACE good with this Defer to EPA Comment Closed

22 Section 22 paragraph 2 Kiefer The need for additional investigations after a ROD was issued is unclear It should be clearly stated here why additional investigations were required (public concern) Will be addressed Addressed Comment Closed

23 Section 22 paragraph 2 Kiefer Recommend include information regarding why the NCC was placed over portions of Area 1 and 2 or refer to section where this is discussed further Will be addressed Addressed Comment Closed

24 Section 2 section 3 Kiefer Editorial - There is a lot of information provided in this section (Summary of previous investigations) that doesnt make sense unless you have the site background information It might make more sense to put Summary of previous investigations after Site Background Information just does not flow appropriately EPA agrees but will evaluate this and level of effort to RPs Editiorial comment withdrawn

25 Section 31 last paragraph Kiefer First sentence states [the West Lake site] hellipconsists of the various parcels that comprise the landfill property (on-property) and adjacent properties (off-property) where radionuclides have been or could be identified in the soil Consider clarifying this language so that the reader understands that the boundary of the superfund site was originally set up based upon this definition The way it reads now it reads in the current tense and the reference to could be identified implies that the nature and extent may not be determined Will be addressed Clarified Comment Closed

26 Section 3321 2nd para 2nd to last line p 26 Speckin The diesel tank referred to in this paragraph could eventually corrode and result in a sinkhole at the surface It is recommended that this tank either be removed or closed in place by filling with flowable fill USACE position the tank will corrode it will fall apart and there will be a sinkhole and cap can be impacted EPA will talk internally and get back to USACE on how to incorporate May have to be addressed as part of RD EPA Cmt 28 Provide some additional information that they can gleen from aerial photography The revisions are probably ok but this will need to remain on the radar to potentially close the tank in place during RA

27 Section 3321 2nd para 2nd to last line p 26 Speckin This indicates the North Quarry landfill overlaps the southeastern portion of Area 1 Shouldnt this be the southwestern portion This correction should be made to footnote 24 as well Will be addressed EPA Cmt 265 RTC says change will be made but it was not 2nd to last line on the bottom of p 27

28 Section 3321 2nd paragraph Rankins Inclusion of or reference to a figure showing the areal extent of the NCC in radiological Area 1 relative to the RIM would provided a helpful visualization in understanding site charactistics as well as the conceptual model of the site How many acres of the 176-acre Area 1 are impacted by by RIM How many acres is the NCC Will have RPs include acerage of Area 1 Will add surface rim info on same figure as NCC Confirm with Jon that this is his intent of this comment Comment Closed

29 Section 3322 3rd paragraph Rankins Inclusion of or reference to a figure showing the areal extent of the NCC in radiological Area 2 relative to the RIM would provided a helpful visualization in understanding site charactistics as well as the conceptual model of the site How many acres of Area 2 are impacted by by RIM How many acres is the NCC Will have RPs include acerage of Area 2 Will add surface rim info on same figure as NCC Confirm with Jon that this is his intent of this comment Comment Closed

30 Section 334 4th paragraph Rankins Since this section is giving a site history and description of the characteristics of Bridgeton Landfill North and South Quarry landfill areas and because of the publics expressed interests and concerns perhaps a summary discussion of the subsurface exothermic reaction (SSR) that is occurring in the Bridgeton Landfill South Quarry would be appropriate for this section along with a reference to Section 57 for more details regarding the SSR and actions being implemented to monitor and control the SSR Will be addressed EPA to determine how this will be addressed Comment Closed

31 Section 41 pdf page 56 2nd bullet Kiefer States McLarenHart inventoried all existing monitoring wells which could be located at the landfill The language could be is confusing Either there are existing wells at the landfill or not Please clarify text Misunderstood statement Withdraw comment Comment Withdrawn

32 Section 42 Kiefer This section titled Threatened and Endangered Species presents information about wetlands as well as threatened or endangered species assessment Recommend adding separate section on wetlands Will be addressed by adding to heading Addressed Comment Closed

33 Section 433 Kiefer This section mentions an ongoing SSR in South quarry and the ASPECT survey This is the first time the SSR is mentioned and there is no background provided in the report to give the reader an understanding of the SSR and concerns Recommend including this in the site background Will be addressed Added discussion in Section 222 Comment closed

34 Section 434 paragraph 3 and Appendix A-4 Kiefer All of the gamma surveys report in different units The McLaren Hart overland gamma survey reports in uRhr and uses a 20 uRhr background The ASPECT flyover uses a 6 sigma basis The Auxier uses 7001-14000 (no units listed in text or on Figure A-41) The background and relationship to sigma is explained in the McLaren Hart and ASPECT surveys but there is nothing to provide for interpretation of the Auxier gamma survey results on Fig A-41 with respect to a background or level Figures A-42 and A-43 have units of cpm It is not clear if the 7001-14000 reading or the cpm readings are of issue based on information provided Recommend this discussion be added to inform what can be interpreted from this data Difficult to bring all of these into context There is no way to equate count data Investigations did not intend to use that Only the overland gamma survey is useful Explain how this data is used Very difficult to understand the data Does or does not coincide with CSM or extent of RIM determination Will add comment to try to get some clarity Some additional clarification on how counts were interpreted was provided Comment Closed

35 Section 43last bullet Rankins Clarification requestedWere the overland gamma surveys that were conducted in conjunction with the installation of the NCC over the RIM in Areas 1 and 2 done before or after installation of the NCC or both (ie so as to determine the effectiveness of the cover as a barrier to exposures) Who performed these surveys Will ask RPs to address these questions by providing text to address this Chris to confirm with Jon if this is the intent of his comment or to provide examples Clarified but not fully addressed

36 Section 434last paragraph Rankins Clarification requestedIts stated that the overland gamma surveys that were conducted in conjunction with the installation of the NCC over the RIM in Areas 1 and and that the surveys were condicted along the margins of the areas covered or to be covered by the road base material Were surveys done before or after installation of the NCC or both (ie so as to determine the effectiveness of the cover as a barrier to exposures) Who performed these surveys Will ask RPs to address these questions by providing text to address this Chris to confirm with Jon if this is the intent of his comment or to provide examples Clarified but not confirmed in updated RIA

37 Section 435 Rankins Donakowski Given that the activities conducted in these work plans has been completed is there a need to state that the workplans were not approved or commented on If BMAC is to be discussed please state the factorsconcerns that prompted EPA to target the BMAC for conducting gamma surveys EPA will provide the language for PRs to inlcude in RIA Addressed Comment Closed


39 Sections 44 and 45 Speckin Recommend combining the text of the 44 Soil Boring and Logging and 45 Sample Collection and Analysis for each investigation Editorial - Will ask RPs to try to commbine to provide ease of review EPA Cmt 267 Was considered editorial RPs response was that change will be made but it was not made Because this is editorial comment is closed

40 Section 442 1st para after bullets 1st sentence p 41 Speckin This sentence should be broken into several sentences As written it suggests soil boring advancement down-hole radiological logging and soil-boring abandonment are ways to complete soil borings Will be addressed in editorial section EPA Cmt 268 Change made satisfactory Comment Closed

41 Section 445 Kiefer First paragraph discusses isolation barrier but doesnt discuss what the barrier was to be used for That should be discussed to provide context for reader Will be addressed EPA to discuss with their team on how to do that Addressed Comment Closed

42 Section 45 General Rankins Regarding the soil boring investigations two background investigations were discussed in Sections 452 and 457 It is unclear if these represent the current soil BTVs for characterizing the OU1 Areas 1 and 2 Please add text somewhere in this section that indicates the sampling investigation(s) that has provided the basis for the RIA BTVs being used to characterize the site or instead refers the reader to Section 625 for an explanation of current BTVs Will be addressed Comment Closed

43 Section 4451 p 49 1st para 2nd and 3rd to last lines Speckin Indicates the GCPT encoutered refusal due to the presence of inert fill Was this concrete debris If so recommend concrete debris or whatever it happended to be be used instead of inert fill The inertness of the fill had nothing to do with refusal Will be addressed (editorial) EPA Cmt 48 Change made satisfactory Comment Closed

44 Section 452 para Starting All of the surfacehellip p58 Speckin On the first line it appears helliptwo sampleshellip should be helliptwo subsurface sampleshellip Will be addressed (editorial) EPA mt 52 Change made satisfactory Comment Closed

45 Section 452 Rankins Very little information is provided in this section regarding the background soil samples collected during the OU1 RI (1995 - 1997) Apparently only 4 surface samples were collected from within the 6 - 12 inch depth interval Were any subsurface soil samples (ie gt 12 inches) collected from the same locations More information should be presented regarding the locations (reference areas) from where the 4 background samples were collected relative to the site Seems like the reader must wait until Section 6 and Figure 6-1 to find such information on the 4 background soil locations Either add this information to Section 452 or refer the reader to Section 6 and Figure 6-1 which also gives more details regarding the calculation of background threshold values (BTVs) for use in the RI Report Addendum (RIA) Report More info regarding locations - a map is included EPA Will have RPs cite figure earlier in Section 4 There are no subsurface samples for background in same location Will not pass along questions Background data is fine for how its being used May refine in RD and definatley for buffer zone during RD Clarify with Jon that this is the meaning of his comment Comment Closed

46 Section 455 Kiefer States that lab reports were provided to EPA in the monthly status reports for March April and May 2016 If this information is post ROD recommend it be included as attachment to this RI report Recommend that all data relied upon in determining nature and extent since 2008 be included as attachment to this RI Report If not attached then at least refer to where it is summarized Data is summarized in Appendix D Recommend cover pages identify the sampling event dates not just NRC or OU-1 because there are no dates on these reports This is data for FampT evaluations FampT report was taken out because it was very flawed Will be addressed as part of FampT comment Comment Withdrawn based upon EPA explanation during comment coordination meeting


48 Section 456 7th paragraph Kiefer Recommend more detail be given as to why EPA questioned the subset of Cotter samples Will be addressed Addressed as part of what was added in last paragraph of this section Comment Closed

49 Section 456 last paragraph Kiefer Recommend this paragraph summarize the findings of the data usability evaluation at a very high level Will be addressed Addressed as part of what was added in last paragraph of this section Comment Closed

50 Section 457 Rankins It is unclear what prompted the EPA to investigate the BMAC Please state What depth intervals were investigated at the BMAC What depth intervals were sampled in the reference areas (Koch and Blanchette Parks) Are the data from the samples collected from the two reference areas and the resulting BTVs included in the current soil background data sets for the RIA and Updated Baseline Risk Assessment characterizations of the site Will be addressed Include info to make the complete case on 2 sampling Comment Closed

51 Section 457 Kiefer Recommend stating the exact number of samples that had results less than the BTVs in lieu of stating the majority of the sample results were less than the BTVs Recommend stating that all of the samples were below EPA PRGs Not sure why Tetra Tech compared this to FUSRAP RGs recommend this be deleted because BMAC is not a FUSRAP project and therefore FUSRAP RGs are not applicable Should only compare to PRGs This is language from BMAC report Why TT compare to FUSRAP RGs There was a perception that EPA was adjusting the background so RGs would be used to compare to help the public understand comparison to FUSRAP Will include direction to remove the ref to FUSRAP this is not necessary for RI since no issues Reference to FUSRAP not removed Understand that this is merely a citation of the report but it can be misleading since FUSRAP RGs are not applicable to West Lake

52 Section 41212 Kiefer Recommend reference to Fig 4-13 in this section as it identifies where the SED-1 through SED-4 samples referenced in the text are located Will be addressed Addressed Comment Closed

53 Section 4 and all subsections Kiefer Some subsections report general results of analyses (Ex 457 41221 4123) and nearly all of the other subsections do not they just refer to the appendix where lab results are included Recommend consistency be applied and that each sub section indicates that the results are discussed in Section 7 of the report USACE recommendation Talk about sampling and results in same place EPA concurs with comment Will ask them to be more consistent Does not impact results just clarityconsistency of report therefore comment is withdrawn

54 Section 41222 2nd paragraph Kiefer There is reference to NCC-003 and NCC-004 Recommend you indicate that these are now called OU1-003 and OU1-002 for consistency between text lab reports and figure 4-15 Note that text states OU-1-001 but Figure 4-15 shows as OU1-001 Please correct text to ensure consistency Will be addressed Addressed Comment Closed

55 Section 41222 Appendix G Kiefer Appendix G-4 has a chain of custody and sample results for a sample labeled as Buffer Zone and another as SCRRA1 I cannot correlate these samples to the text in Section 41222 or to any of the figures (4-15 or 4-16) Where were these samples taken Recommend they be located on one of the figures Will ask because these are not the only two samples like this Not sure if they are decon samples Did EPA resolve

56 Section 4 Kiefer There is limited discussion on data validation for most of the data sets Validation is mentioned for GCPT soundings (4451) Phase 1 Investigation (453 and 454) testing performed by Cotter (456) and non-Radiological constituents in stormwater samples collected in 2016-17 (86) There isnt mention of data validation on any of the other sampling events conducted Table 7-13 7-24 8-3 8-4 8-5 and 8-6 footnotes states radionuclied EPA and MDNR data for groundwater samples is not validated Data relied upon for this report should be validated Will ask RPs to clarify the foot notes and be consistent on which data has been validated or not validated OR explain level of validation Table footnotes have been fixed Comment closed

57 Section 41312 Kiefer 2nd paragraph states all samples were well below the regulatory limit for workers of 5000 mremy Recommend remove the word well It is sufficient to state below the regulatory limit Will be addressed Addressed Comment Closed

58 Section 41312 J Donakowski It is stated that the regulatory limit for workers is 5000 mremyear This is the limit for radiation workers (ie workers expected to be exposed to gt 100 mremyear) Are workers at the WLLF trained as radiation workers per 10 CFR 19 Will be addressed NRC has specifc definition of radiation workers Just because they are working in an area of radiation does not classify them as radiation workers Discussion deleted Comment Closed

59 Section 41315 J Donakowski While the statement MDHSS consistently concluded that gamma radiation rates continued to be indistinguishablefrom natural background levels is true there are occaisional anomalous readings in the data which is not addressed by MDNR For example during the period from 8292013 to 922013 sustained exposure rate measurements above 40 uRhr were reported in multiple intervals Maximum gamma levels were reported at levels above 100 uRhr USACE concern MDNR puts out reports and says gamma levels are not distiguishable from background levels The levels are distinguishable EPA Data peaks at 2pm When temp exceed 90 degrees the readings go up The offsite data confirms this USACE withdraws comments but recommends MDNR explain this Comment Withdrawn

60 Section 41316 J Donakowski It may be more appropriate to compare air concentrations to 20 of the NRC effluent limits per 40 CFR 61 Subpart H Tom wants to pass along but needs folow up bc EPA did not tell RPs to compare air data to a limit It was for a baseline for IB EPA established background air monitor without basline to compare upwind to down wind RP was supposed to compare to EPA data and RPs took it on themselves to compare to NRC data EPA will discuss internally prior to making decision to pass along Comment not addressed USACE still feels the requirements of the clean air act per original comment are apppropriate to discuss here and change should be made


62 Section 4133 Kiefer What was purpose of NCC vegetation sampling To sample the vegetation that would be cut down during installation of the NCC Since NCC is installed would this sampling even be possible at this point If not this section should clarify the purpose and events and state that the sampling will not be completed because the NCC is already installed Will ask RPs to provide explanation EPA will have to provide language Tested remaining vegetation to ensure no additional radionuclides in vegetation Now in 4143 Addressed Comment Closed

63 Section 415 Kiefer Paragraph reads like the entire effort of historical aerial photograph evaluation was done by EPAs Environmental Monitoring Systems Laboratory Was all of this done by EPAs lab or was some done by the Respondents Recommend this be clarified Will be addresed Addressed Comment Closed

64 Section 5 Speckin Recommend moving Section 5 to earlier in the document prior to description of investigations Will be addressed (editorial) if not a huge level of effort Likely will be recommendations instead of requirement to make this change EPA Cmt 251 RPs disagreed with comment Their response that information presented in Section 5 waas based on resutls of investigation is Section 4 so it would not make sense for 5 to come before 4 This response is reasonable Comment Closed

65 Section 75114 and Figures 5-8 and 5-13 through 5-16 Mathews-Flynn Text appropriately references the St Louis Formation However 75114 and the figures incorrectly reference St Louis Limestone Recommend using formation Will be addressed Addressed Comment Closed


67 Section 611 Rankins Barium sulfate mixed with top-soil is described as the primary RIM disposed of at the site What radiological isotopes are expected to be present in the material that was disposed of in WLL Is it expected to be solely radium and thorium or was urainum present Ur is expected to be present bc material license and responses to NRC inquiries specifically list Ur content A comment will be made to clarify what is coming over from Latty Ave Clarify with Jon that is his intent of this comment Comment Closed

68 611 1st para p 154 Speckin Recommend deleting this paragraph as it doesnt appear appropriate to include in an RI Will ask RPs to revise and EPA will provide specific direction on how to address EPA Cmt 104 RPs did not delete the 1st 2 paragraphs as requested by EPA


70 Section 611 1st bullet Kiefer States excavated at trench see May 4 1971 aerial photo) to establish the depth of AM-7 pile subsidence While the aerial does show a trench or cut into the surface of the pile the reason for this is not verified The interpretation from Randall Grip with Sero-Data Corporatoin LLC states this is likely test trenching operations to determine the remaining material to be rmoved from the pile 1 area There is no mention in Mr Grips report of pile subsidence Recommend that this bullet match the language used by Mr Grip and that his report is specifically referenced Similiarly for the second bullet the aerials cannot determine the reason why things were done they just document the current conditions Recommed the text in the report be adjusted to reflect this Will be addressed Addressed Comment Closed

71 Section 611 footnote 62 Kiefer Recommend footnote or text indicate what the 06 mRhr allowable level is based upon Will be addressed Not addressed Recommend citing what regetc established the 06 mRhr allowable level


73 Section 612 para 1 Kiefer Recommend adding additional text regarding how radionuclides might be present in MSW Ex disposal of xxx (list xxxx household wastes) Will be addressed Addressed Comment Closed

74 Section 612 2nd para p 157 Speckin This paragraph indicates there was 43000 tons of [soil mixed with LBSR However the bullet at the top of p 156 says there was 39850 tons of soil mixed with 8700 tons of LBSR fir a total of 48550 tons Recommend changing one of these for consistency purposes Will be addressed EPA Cmt 109 RPs added a footnote explaining the inconsistencies in information provided from various historical reports Change is satisfactory Comment Closed

75 Section 625 Rankins It is stated that the background data obtained during the OU1 RI conducted by McLaren Hart around 1996 were used to determine BTVs for determining the occurrences and extent of RIM at Areas 1 and 2 However as is the case with the information provided earlier in Section 452 very little information is provided about the samples specifically the areas from which they were collected Additionally although the OU1 RIA background values were conservatively derived using decay chain considerations and are comparable (per Table 6-1) to those values derived during the 1996 RI (BV = mean + 2 SD) the NRC Ra-226 values and the values determined for other St Louis area sites (eg FUSRAP) there are some uncertainty issues relative to the RIA BTVs being used to identify and characterize RIM that warrant some discussion in the text First please discuss uncertainties associated with the application of BTVs derived from analytical data obtained for only 4 background surface soil samples to the characterization of both Areas 1 and 2 which comprise a combined area of 649 acres with a combined approximated RIM area and volume of 331 acres and 284600 cy (per Section 65) Also because the area from which the 4 background samples were collected is unknown it is unclear as to how well the soil conditionscharacteristics (radiological chemical physical) of the background samples are representative of conditions of the material at Areas 1 and 2 containing the RIM (ie if no radiological contamination were present) Since the RIM is comprised of soil and waste materials it is questionable as to how well the background soil sample conditions approximate conditions of the RIM It would seem that the background soil conditions would be more comparable to soil conditions at the Buffer Zone andor Crossroads Lot 2A2 areas where the combined area and volume of radiological extent of contamination comprise 45 acres and 3600 bcy (per Section 67) However combined size and soil volume for these areas also bring into the question the statistical representativeness only 4 background surface soil samples Please add a discussions to address all of these uncertainties and the potential impacts on identifying and characterizing RIM at Areas 1 and 2 as well as radiologically impacted soil at the Buffer Zone and Lot 2A2 areas EPA recognizes background sampling is not done the way it currently is done Clarify with Jon what his recommendation is for estimating uncertainty Area where background samples is shown on a figure Verify comments about soil Background is important for residential Ask RPs to be transparent about the limits of the background set Comment Closed

76 Section 626 Rankins Paragraph on page 165 states Based on the Site background values presented above the criteria to be used toidentify RIM are as followsbull Radium-226+228 = 79 pCig70bull Thorium-230+232 = 79 pCigbull Combined uranium = 545 pCigThe combined uranium criteria should be discussed in the Executive Summary Will be addressed Addressed Comment Closed

77 Section 626fifth paragraph Rankins First please cite the source of the 71 mgkg mass equivalent for the 50 pCig uranium standard Also please note that EPAs current (June 2017) non-carcinogenic residential screening levels (RSLs) for uranium (soluble salts) are now 16 mgkg for residential exposures and 230 for industrial worker exposures (httpswwwepagovriskregional-screening-levels-rsls-generic-tables-june-2017) The change in uranium non-carcinogenic RSLs between the May 2016 and June 2017 RSL tables is that EPA has adopted the ATSDR-based intermediate minimum risk level (MRL) of 00002 mgkg-day resulting in the lower RSLs EPA is now recommending the use of the MRL when evaluating non-carcinogenic risks posed by uranium in the December 21 2016 memo entitled Considering a Noncancer Oral Reference Dose for Uranium for Superfund Human Health Risk Assessments The May 2016 RSL was derived based on the chronic oral reference dose (RfDo) 0003 mgkg-day which is still presented for use in the Integrated Risk Information System (IRIS) Based on the updated June 2017 residential and industrial RSLs for uranium that were derived using the ATSDR MRL of 00002 mgkg-day a cleanup of uranium to 50 pCig (71 mgkg) plus background would not meet unrestricted land use based on non-carcinogenic effects Further discussion of this change is needed with EPA because implementation of the MRL as the basis for developing cleanup standards to protect from noncarcinogenic effects from uranium exposures could have impacts not only for WLL Areas 1 and 2 but also on investigations and cleanups that have been performed regionally using the 50 pCig standard for uranium for the past two decades First line will be incorporated EPA agrees that most current RSLs wll be used EPA has no choice but to use this Acknowledge that USACE is waiting on higher level authority for their lead projects This is not something that the RPs will need to addrsess Discuss with Jon Comment Addressed Note that Army and DoD use the IRIS Oral Reference Dose This is an EPA site therefore defer to EPAs decision

78 Section 626 page 164 and 165 J Donakowski The cleanup goals for the SLDS and SLAPS Sites are 50 pCig U-238 not 50 pCig total U Will pass along Corrected Comment Closed

79 Section 65 page 171 J Donakowski Please more clearly define best-estimate ie 80 certainty 95 Will be addressed Best estimate was replaced with another equally uncertain word significantly If there is significant uncertainty then why use it

80 Figures 6-2 through 6-7 Kiefer Cannot find where these figures are referenced in text These are some of the most important figures for explaining nature and extent Please include references in appropriate locations within text Will be addressed should be in Section 6 CSM etc Addressed in section 63 Comment Closed

81 Section 67 p 175 3rd and 5th line Speckin 3rd line - it appears are unknot knownhellip should be hellipare not knownhellip and 5th line it appears I 2016 should be In 2016hellip Will be addressed (editorial) EPA Cmt 275 Corrections made Comment Closed

82 Section 71111 Donakowski Is the statement The average flux for all of the other portions of Area 2 exclusive of these two locationshellip warranted given that this amounts to demonstrating that by eliminating elevated data only non-elevated data exists which is self evident Will be addressed Comment addressed by deleting sentence of concern Comment Closed

83 Section 7112 page 179 paragaraph 4 Kiefer States comparison of Radon measurements were compared to relative probable risk Then states the measurements are nearly 10 times below the recommended EPA regulatory limit of 003 working level for indoor exposure The working levels are not a measuremnt of relative risk If the intent is to claim radon levels are below the CERCLA risk range then comparing levels to an UMTRCA working level does not seem appropriate Will be addressed Clarification provided Comment Closed

84 Section 7112 page 180 top paragraph Kiefer The analysis in this paragraph is confusing States EPA health-based standard for radon is 05 pCiL but then states that Flare 2 stack results range from 83 +- 08 pCiL to 644 +- 65 pCiL This stack level is above the 05 pCiL However this paragraph doesnt state that It states that it compares well to a theoretical stack gas radon release for area 1 that might produce 19 pCiL Recommend this paragraph be restructured to compare first to the EPA health-based standard for radon and then separately discuss what occurs at the fenceline EPA agrees that this is appropriate comment but needs to address potential language with air program This is still confusing Seems like this could be simply addressed by comparing the radon sample results with something that translates to health-based risk for exposure

85 Section 7113 page 180 Kiefer Editorial - 3rd sentence - remove the second that from sentence processing or depository site that will not pose a substantialhellip Will be addressed Addressed Comment Closed


87 Section 7121 page 183 J Donakowski It may be preferable to state that radiological results between upwind and downwind locations are not statistically significant as very minor is subjective Will be addressed Use of very minor has been removed Comment Closed


89 Section 7122 1st para p 184 Speckin Indicates concentration of gross Alpha from the 13 on-site monitoring stations were 3 to 4 times higher than the concentrations from EPAs off-site monitoring program Please indicate if the levels are above a health-based standard Will be addressed EPA Cmt 143 Comment did not ask if it was above health based standard however the revised text appeared to address EPAs comment as submitted Comment Closed

90 Section 7122 para 2 2nd line Speckin Recommend changing isotopic thorium uranium and by gamma spectroscopy to isotopic thorium and uranium by gamma spectroscopy Will be addressed EPA Cmt 278 Correction made Comment Closed

91 Section 7122 para 2 3rd sentence Speckin Recommend deleting As expected Also recommend explaining how it was determined that the results demonstrated only naturally occuring radioactive materials It is assumed this means the results are not reflective of the RIM on-site will pass along as expected comment Will pass along second part too EPA Cmt 144 Changes made as per EPA comment Comment Closed

92 Section 721 para 1 Speckin Need to explain why stormwater runoff is being compared to MCLs This isnt drinking water therefore this isnt appropriate criteria to compare to Consider developing risk-based level for dermal contactThe last sentence indicates the primary criteria considered were drinking water standards for Ra-226 and Ra-228 However in a July 8th article the RPs were quoted as saying comparing storm water results to drinking water standards is not appropriate Therefore this will likely be viewed as contradictory to that statement MCL vs drinking water for stormwater Due to state requirements EPA will determine language EPA did not appear to submit this comment

93 Section 721 page 188 Kiefer Recommend that it be indicated if the lab results cited in these 2 paragraphs were filtered or unfiltered samples Will be addressed Addressed Comment Closed

94 Section 722 and 723 Kiefer Recommend it be noted if these samples were filtered or unfiltered Will be addressed Addressed Comment Closed

95 Section 73111 73112 7312 Kiefer The discussion on results only discusses results in terms of above RIM definition level but doesnt actually tell the results Recommend the concentrations be stated in a way to determine how much higher than the 79 pCiL level is present (high-low-avg concentration) This is important for natureextent determination however this section is labeled Radionuclide occurences in environmental media Im struggling with why this section (7) is necessary Seems like some of this should be included in Nature and Extent (section 6) discussion and some of it should be included in a Fate and Transport section (which does not appear to be a separate section of this RI report - there is one subsection 76 that addresses fate and persistence of radionuclides) There is a lot of redundant text that has already been covered in Section 4 (ex 75112 has same info as 4115 regarding attempts to get access to sample private wells) Comparison to only meeting RIM definition level Will pass this along as it would be helpful to include (may be related to IK) Sec 6 is Nature and extent of RIM and Sec 7 is how RIM impacts env media EPA will make a comment on repetetiveness Editorial USACE defers to EPA on this Defer to EPA Comment Closed


97 Section 7312 Kiefer Last paragraph - Compairs Pb210 to PRG by using the word near Suggest it state above the PRG Also states K-40 is not a known contaminant at the site however if its above the PRG it should be clearly stated Will be addressed Discusson of Pb 210 and K-40 appears to have been removed Comment Closed

98 Section 7312 page 195 J Donakowski Please clarify which exposure scenario (ie residential occupational etc) the PRG is relevent to and indicate the date the PRG was taken from the online calculator if the online tool was used Will be addressed Sentence deleted Comment Closed

99 Section 7321 1st para p 195 Speckin This provides detailed explanation that a potential slope failure caused contamination on the adjacent Ford property and then goes on to explain this didnt actually occur and that the contamination was due to erosion Recommend reducing the slope failure description and simply mention that the it was initially thought the contamination on the Ford property was caused by a slope failure but it has been determined it was due to erosion Appear to be referencing how it was characterized in original RI EPA will ask that they clarify that determination was updated EPA Cmt 158 Satisfied with changes Comment Closed

100 751 752 and 874 J Donakowski It may also be helpful to also discuss isotopic ratios (ie Th-230Th-232 Ra-228Ra-226) for groundwater (and sediment and leachate) results given that RIM has concentrations thorium and radium at levels appreciably different than natural levels and which vary by isotope (ie significantly more Th-230 or Ra-226 would likely be present in RIM impacted sediments and waters than Th-232 and Ra-228) This goes away due to withdrawl of comment 101 Comment from USGS EPA will provide a comment but it will be different than how this is worded Comment not addressed except in previous section 874 Comment does not significantly impact RI so comment is withdrawn


102 Section 75113 Kiefer Recommend showing results on a Figure and referencing it The Figures provide a much easier means for understanding the site conditions than the text Will be addressed USGS has similar comment with suggestion Not addressed Defer to EPA on whether or not they will require this from PRPs Must include this in OU3


104 Section 75123 Kiefer Bullet 3 - recommend more clarity be provided with respect to resulting in greater analytical detections Do you mean that the improvements result in an ability to detect radium at a lower level (ie lower MDA) Use of the words greater analytical detections can be misinterpreted Will be addressed Clarified Comment Closed

105 Section 82 83 84 85 8687 Kiefer Recommend the non rad constituents listed in the bullets be compared with the regulatory limits so the natureextent of the contamination can be understood Will be addressed Acceptable with statement in 2nd paragraph after bullets Comment Closed

106 Section 8 Kiefer Providing figures summarizing where non rad contamination has been identified would be helpful in understanding natureextent Limited hits may be why they didnt include figures Clarify if hits above MCLs and if so it is appropriate to have figure Addressed Comment Closed

107 Figures 8-6 8-7 8-8 8-12 and 8-13 Lyons These figures show results for metals (iron manganese sulfate and chloride) compared against screening levels listed as MCLs However there are no MCLs for these metals The values listed are Secondary MCLs (SMCLS) and should be listed as such Willl be addressed Addressed by using reference to Secondary MCL Comment closed

108 Section 9 Kiefer Editorial - this section contains repeated information from previous sections (site descriptionsetting history geology hydrology sourcesdistribution of RIM etc) Seems like the CSM should be introduced earlier in the report possibly as part of the Nature and Extent section Also see comment 3 EPA will ask to reduce competetiveness Wants CSM to be stand alone Editorial so USACE defers to EPA Now CSM is Section 10 Comment Addressed in conjunction with EPA feedback on CSM to be stand-alone


110 Section 96 J Donakowski Given that there has been recent discussion of natural events (surface fire flooding etc) it may be helpful to discussreference how these transport routes are mitigated (ie reference levee system in 932 installation of NCC cited in 9612 etc) Will be addressed Addressed Comment Closed

111 Section 961 Rankins Please note if volatile emissions (ie from organic compounds) was considered and the justification for elimination of this pathway Will be addresed This was passed along in the BLRA comments too Will compare and ensure consistency Addressed in 10512 Comment Closed

112 Section 9611 J Donakowski It may be helpful to discuss radon time-of-flight considerations that is due to the relatively long half life of radon compared to typical residence times of ambient outdoor air radon would not be anticipated to be localized in a single area long enough to appreciably in grow daughter products (which are the primary risk driver of radon) Will be addressed This is discussed in BLRA Just need to make sure this is communicated with the BLRA for consistency Comment not addressed in RIA however it if is addressed in BLRA then agree to close this comment

113 Section 971 Rankins Generally Section 971 needs to be revised to better reflect the receptors as presented and discussed in the Updated Baseline Risk Assessment It might be better and more clear to discuss potential current receptors in the first paragraph and future receptors in the second paragraph Will be addressed Addressed in 1061 Comment Closed

114 Section 971first paragraph Rankins In the third sentence of the first paragraph please add the word on-site before receptors Also please indicate that although there are currently no receptors in Areas 1 and 2 and the Buffer Zone there are potential on-property commercial building users and grounds keepers that work in areas adjacent to the aforementioned OU-1 areas These receptors were evaluated in the Updated Baseline Risk Assessment (see Table 13 of the risk assessment) Additionally current off-property receptors were considered andor evaluated such as the resident commercial building user recreationalintermittant user and groundskeeper The primary current off-property receptors of concern though are the resident and commercial building user Will be addressed Addressed Comment Closed

115 Section 971second paragraph Rankins Please describe the future receptors as follows on-property construction workers and storge yard workers on-property trespassers on- and off-property commerical building users grounds keepers and recreationalintermittant users and off-property farmers and residents Of the future on-property receptors the grounds keepers and strorage yard workers are the primary receptors of concern Of these two future receptors only the grounds keeper is assumed to spend time in OU-1 EPA will review BLRA and make determination on whether this applies anymore Will follow up with Jon Addressed Comment Closed


117 Section 98 Kiefer Recommend that actual risk numbers be presented here as opposed to just stating above or within CERCLA acceptable risk range Recommend BLRA be broken out as separate section not as part of CSM section Need to state that BLRA report will be under separate cover Will be addressed Risk broken out Risks still presented abovebelow risk range Generally acceptable Would rather see summary table of actual risks and comparison to CERCLA acceptable risk range Defer to EPA on presentation


119 Section 982 Kiefer paragraph 2 refers to an uncertainty section Need to be clear that section is not in the RIA but in the BLRA report (which is not attached to this RIA) Will be addressed Addressed Comment Closed

120 Section 982 J Donakowski Please clarify what direct contact with radium-226 entails Is this the gamma pathway or inhalationingestion or a combination of all pathways Will be addressed Statement removed Comment Closed

121 App M Figure M 14 Speckin In some cases the Geostatisical Estimate of RIM Occurrence (purple dashed line) does not encompass clear instances of RIM For example on Figure M 14 PVC-38 shows a gamma count of 20000 cps yet is not included in the estimate of RIM Will be addressed Per EPA cross section are being changed to reflect adjustments made in the geostat report Has not been verified as changes not provided

122 Table 4-3b Speckin The footnote indicates that the NRC boring locations are only approximate estimates yet the state plane coordinates are shown with an accuracy of 1100th of the foot False sense of accuracy by showing 1100th of foot Recommend it go to nearest foot Will address Could not find where comment was submitted Table still shows 1100 ft level of accuracy

123 Appendix D-12 pg 2827 paragraph 3 Evans Text states that certain types of data were exlcluded from the BLRA including samples that were reanalyzed due to data quality issues Why would these samples be eliminated and not included in the BLRA Reanlyzed samples that have passed QC are considered valid and usable Please provide the rationale for their exclusion Will be addressed Addressed Comment Closed

124 Appendix D-12 section D6 Evans Cotter samples did not have any Matrix Spike samples as is common practice Please include these or explain that they are missing Will be addressed Addressed Comment Closed

125 Appendix D-12 pg 2832 section 4 Evans Excluded from the BLRA was Th-230 data from the Cotter samples analyzed by Test America as EPA could not reproduce the iso-thorium data from prep batch 234716 This prep batch corresponds to Test America job numbers 15607 and 15609 Although the text explains the lab issues that drive the exclusion of Th-230 from the BLRA namely blank contamination and poor tracer recovery there is no laboratory case narrative or QC section to verify this Please submit the missing case narrative and QC pages from all the Test America data packages Note that EPAs split sample data packages analyzed by Test Americal (collected 122115) included all pages Will be addressed Addressed Comment Closed

126 Appendix D-12 pg 2842 section 82 last paragraph Evans Text states that using aggressive digestion methods (EPA method SW846-3050B) for analyzing metals may yield higher results especially for certain analytes such as barium and that the Cotter samples analyzed by this method should not be considered in the BLRA as they might not be comparable to other metals results presented in the RI Addendum Text further states that the SwRI lab utilized a more suitable multiple step digestion method The 3050B method is the most widely used method in HTRW work and the reviewer would like to know what this other method employed by SwRI was Was this a widely used environmental method recognized by EPA and other environmental agencies The reviewer cannot verify which digestion methods were used by Test America because the case narrative and QC sections are missing Will be addressed but may not be passesd along exactly as is EPA has some additional info that will be conveyed Addressed Comment Closed

DID NOT RECEIVE D13 appendix and did not review

DEPARTMENT OF THE ARMY CORPS OF ENGINEERS KANSAS CITY DISTRICT

635 FEDERAL BUILDING 601 E 12TH STREET

KANSAS CITY MO 64106-2824

Printed on Recycled Paper

December 15 2017 Ms Chris Jump Remedial Project Manager US Environmental Protection Agency Region 7 11201 Renner Boulevard Lenexa KS 66219 Dear Ms Jump The US Army Corps of Engineers (USACE) has completed a review of the Revised Draft of the ldquoRemedial Investigation Addendum West Lake Landfill Operable Unit-1rdquo report dated November 28 2017 and prepared on behalf of the West Lake Landfill OU-1 Respondents Group by Engineering Management Support Inc of Golden Colorado USACE comments are included in the attached Tables The first Table includes a back-check of the comments made on the draft version of the report Yellow highlighted cells indicate the comment has not been addressed Blue highlighted cells indicate that the comment requires information from EPA on disposition of the comment The second Table includes new comments on the Revised Draft report USACE is available to participate in comment clarification andor comment resolution meetings upon request Respectfully Robyn V Kiefer Project Manager CC Scott Young-CENWK-PM-E Jason Leibbert-CENWK-ED-E PDT


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2nd sentenceSpeckin



paragraphWhitfill


5Section 75132 1st


Whitfill





7 Section 62 Hays






USACE Comments -

10 Section 626 Hays











3rd paraSpeckin



sentenceSpeckin




19Section 10511 p 269



20Section 10511 p 269









24Section 1052 p271








28Section 1061 2nd


29Section 107 p 274

2nd paraSpeckin



2nd paraSpeckin



sentenceSpeckin


Backcheck




barcode 30325719




USACE Comments -





































































































































































Comment















Comment Closed













Comment Closed














Comment






Did EPA resolve

56 Section 4 Kiefer












Comment Withdrawn


















Comment Closed




Comment
















Comment Closed





Rankins






Comment












Kiefer




Kiefer

























95 Section 73111 73112 7312

Kiefer









Comment




Speckin















105 Section 82 83 84 85 8687





107 Figures 8-6 8-7 8-8 8-12 and 8-13


















Rankins




Rankins






Will be addressed


Comment
















1ES-2 last para 2nd

sentenceSpeckin



3445 p48 1st para

2nd sentenceSpeckin



paragraphWhitfill


5Section 75132 1st


Whitfill





7 Section 62 Hays



USACE Comments -




10 Section 626 Hays











3rd paraSpeckin



sentenceSpeckin




19Section 10511 p 269



20Section 10511 p 269









24Section 1052 p271








28Section 1061 2nd


29Section 107 p 274

2nd paraSpeckin



2nd paraSpeckin



sentenceSpeckin





2017-12-15T145419-0600




Sheet3



Comment







Lyons








Lyons








Comment Closed



Rankins



Comment Closed










Rankins






Comment



11














































Comment













Comment Closed




Comment Closed


Rankins



Comment Closed









Kiefer








Rankins





Donakowski













Comment















Comment Closed













Comment Closed














Comment






Did EPA resolve

56 Section 4 Kiefer












Comment Withdrawn


















Comment Closed




Comment
















Comment Closed





Rankins






Comment












Kiefer




Kiefer

























95 Section 73111 73112 7312

Kiefer









Comment




Speckin















105 Section 82 83 84 85 8687





107 Figures 8-6 8-7 8-8 8-12 and 8-13


















Rankins




Rankins






Will be addressed


Comment
















1ES-2 last para 2nd

sentenceSpeckin



3445 p48 1st para

2nd sentenceSpeckin



paragraphWhitfill


5Section 75132 1st


Whitfill





7 Section 62 Hays






USACE Comments -

10 Section 626 Hays











3rd paraSpeckin



sentenceSpeckin




19Section 10511 p 269



20Section 10511 p 269









24Section 1052 p271








28Section 1061 2nd


29Section 107 p 274

2nd paraSpeckin



2nd paraSpeckin



sentenceSpeckin


Backcheck




barcode 30325719




USACE Comments -





































































































































































Comment






Did EPA resolve

56 Section 4 Kiefer












Comment Withdrawn


















Comment Closed




Comment
















Comment Closed





Rankins






Comment












Kiefer




Kiefer

























95 Section 73111 73112 7312

Kiefer









Comment




Speckin















105 Section 82 83 84 85 8687





107 Figures 8-6 8-7 8-8 8-12 and 8-13


















Rankins




Rankins






Will be addressed


Comment
















1ES-2 last para 2nd

sentenceSpeckin



3445 p48 1st para

2nd sentenceSpeckin



paragraphWhitfill


5Section 75132 1st


Whitfill





7 Section 62 Hays



USACE Comments -




10 Section 626 Hays











3rd paraSpeckin



sentenceSpeckin




19Section 10511 p 269



20Section 10511 p 269









24Section 1052 p271








28Section 1061 2nd


29Section 107 p 274

2nd paraSpeckin



2nd paraSpeckin



sentenceSpeckin





2017-12-15T145419-0600




Sheet3



Comment







Lyons








Lyons








Comment Closed



Rankins



Comment Closed










Rankins






Comment



11














































Comment













Comment Closed




Comment Closed


Rankins



Comment Closed









Kiefer








Rankins





Donakowski













Comment















Comment Closed













Comment Closed














Comment






Did EPA resolve

56 Section 4 Kiefer












Comment Withdrawn


















Comment Closed




Comment
















Comment Closed





Rankins






Comment












Kiefer




Kiefer

























95 Section 73111 73112 7312

Kiefer









Comment




Speckin















105 Section 82 83 84 85 8687





107 Figures 8-6 8-7 8-8 8-12 and 8-13


















Rankins




Rankins






Will be addressed


Comment
















1ES-2 last para 2nd

sentenceSpeckin



3445 p48 1st para

2nd sentenceSpeckin



paragraphWhitfill


5Section 75132 1st


Whitfill





7 Section 62 Hays






USACE Comments -

10 Section 626 Hays











3rd paraSpeckin



sentenceSpeckin




19Section 10511 p 269



20Section 10511 p 269









24Section 1052 p271








28Section 1061 2nd


29Section 107 p 274

2nd paraSpeckin



2nd paraSpeckin



sentenceSpeckin


Backcheck




barcode 30325719




USACE Comments -





































































































































































Comment
















Comment Closed





Rankins






Comment












Kiefer




Kiefer

























95 Section 73111 73112 7312

Kiefer









Comment




Speckin















105 Section 82 83 84 85 8687





107 Figures 8-6 8-7 8-8 8-12 and 8-13


















Rankins




Rankins






Will be addressed


Comment
















1ES-2 last para 2nd

sentenceSpeckin



3445 p48 1st para

2nd sentenceSpeckin



paragraphWhitfill


5Section 75132 1st


Whitfill





7 Section 62 Hays



USACE Comments -




10 Section 626 Hays











3rd paraSpeckin



sentenceSpeckin




19Section 10511 p 269



20Section 10511 p 269









24Section 1052 p271








28Section 1061 2nd


29Section 107 p 274

2nd paraSpeckin



2nd paraSpeckin



sentenceSpeckin





2017-12-15T145419-0600




Sheet3



Comment







Lyons








Lyons








Comment Closed



Rankins



Comment Closed










Rankins






Comment



11














































Comment













Comment Closed




Comment Closed


Rankins



Comment Closed









Kiefer








Rankins





Donakowski













Comment















Comment Closed













Comment Closed














Comment






Did EPA resolve

56 Section 4 Kiefer












Comment Withdrawn


















Comment Closed




Comment
















Comment Closed





Rankins






Comment












Kiefer




Kiefer

























95 Section 73111 73112 7312

Kiefer









Comment




Speckin















105 Section 82 83 84 85 8687





107 Figures 8-6 8-7 8-8 8-12 and 8-13


















Rankins




Rankins






Will be addressed


Comment
















1ES-2 last para 2nd

sentenceSpeckin



3445 p48 1st para

2nd sentenceSpeckin



paragraphWhitfill


5Section 75132 1st


Whitfill





7 Section 62 Hays






USACE Comments -

10 Section 626 Hays











3rd paraSpeckin



sentenceSpeckin




19Section 10511 p 269



20Section 10511 p 269









24Section 1052 p271








28Section 1061 2nd


29Section 107 p 274

2nd paraSpeckin



2nd paraSpeckin



sentenceSpeckin


Backcheck




barcode 30325719




USACE Comments -





































































































































































Comment












Kiefer




Kiefer

























95 Section 73111 73112 7312

Kiefer









Comment




Speckin















105 Section 82 83 84 85 8687





107 Figures 8-6 8-7 8-8 8-12 and 8-13


















Rankins




Rankins






Will be addressed


Comment
















1ES-2 last para 2nd

sentenceSpeckin



3445 p48 1st para

2nd sentenceSpeckin



paragraphWhitfill


5Section 75132 1st


Whitfill





7 Section 62 Hays



USACE Comments -




10 Section 626 Hays











3rd paraSpeckin



sentenceSpeckin




19Section 10511 p 269



20Section 10511 p 269









24Section 1052 p271








28Section 1061 2nd


29Section 107 p 274

2nd paraSpeckin



2nd paraSpeckin



sentenceSpeckin





2017-12-15T145419-0600




Sheet3



Comment







Lyons








Lyons








Comment Closed



Rankins



Comment Closed










Rankins






Comment



11














































Comment













Comment Closed




Comment Closed


Rankins



Comment Closed









Kiefer








Rankins





Donakowski













Comment















Comment Closed













Comment Closed














Comment






Did EPA resolve

56 Section 4 Kiefer












Comment Withdrawn


















Comment Closed




Comment
















Comment Closed





Rankins






Comment












Kiefer




Kiefer

























95 Section 73111 73112 7312

Kiefer









Comment




Speckin















105 Section 82 83 84 85 8687





107 Figures 8-6 8-7 8-8 8-12 and 8-13


















Rankins




Rankins






Will be addressed


Comment
















1ES-2 last para 2nd

sentenceSpeckin



3445 p48 1st para

2nd sentenceSpeckin



paragraphWhitfill


5Section 75132 1st


Whitfill





7 Section 62 Hays






USACE Comments -

10 Section 626 Hays











3rd paraSpeckin



sentenceSpeckin




19Section 10511 p 269



20Section 10511 p 269









24Section 1052 p271








28Section 1061 2nd


29Section 107 p 274

2nd paraSpeckin



2nd paraSpeckin



sentenceSpeckin


Backcheck




barcode 30325719




USACE Comments -





































































































































































Comment




Speckin















105 Section 82 83 84 85 8687





107 Figures 8-6 8-7 8-8 8-12 and 8-13


















Rankins




Rankins






Will be addressed


Comment
















1ES-2 last para 2nd

sentenceSpeckin



3445 p48 1st para

2nd sentenceSpeckin



paragraphWhitfill


5Section 75132 1st


Whitfill





7 Section 62 Hays



USACE Comments -




10 Section 626 Hays











3rd paraSpeckin



sentenceSpeckin




19Section 10511 p 269



20Section 10511 p 269









24Section 1052 p271








28Section 1061 2nd


29Section 107 p 274

2nd paraSpeckin



2nd paraSpeckin



sentenceSpeckin





2017-12-15T145419-0600




Sheet3



Comment







Lyons








Lyons








Comment Closed



Rankins



Comment Closed










Rankins






Comment



11














































Comment













Comment Closed




Comment Closed


Rankins



Comment Closed









Kiefer








Rankins





Donakowski













Comment















Comment Closed













Comment Closed














Comment






Did EPA resolve

56 Section 4 Kiefer












Comment Withdrawn


















Comment Closed




Comment
















Comment Closed





Rankins






Comment












Kiefer




Kiefer

























95 Section 73111 73112 7312

Kiefer









Comment




Speckin















105 Section 82 83 84 85 8687





107 Figures 8-6 8-7 8-8 8-12 and 8-13


















Rankins




Rankins






Will be addressed


Comment
















1ES-2 last para 2nd

sentenceSpeckin



3445 p48 1st para

2nd sentenceSpeckin



paragraphWhitfill


5Section 75132 1st


Whitfill





7 Section 62 Hays






USACE Comments -

10 Section 626 Hays











3rd paraSpeckin



sentenceSpeckin




19Section 10511 p 269



20Section 10511 p 269









24Section 1052 p271








28Section 1061 2nd


29Section 107 p 274

2nd paraSpeckin



2nd paraSpeckin



sentenceSpeckin


Backcheck




barcode 30325719




USACE Comments -





































































































































































Comment
















1ES-2 last para 2nd

sentenceSpeckin



3445 p48 1st para

2nd sentenceSpeckin



paragraphWhitfill


5Section 75132 1st


Whitfill





7 Section 62 Hays



USACE Comments -




10 Section 626 Hays











3rd paraSpeckin



sentenceSpeckin




19Section 10511 p 269



20Section 10511 p 269









24Section 1052 p271








28Section 1061 2nd


29Section 107 p 274

2nd paraSpeckin



2nd paraSpeckin



sentenceSpeckin





2017-12-15T145419-0600




Sheet3



Comment







Lyons








Lyons








Comment Closed



Rankins



Comment Closed










Rankins






Comment



11














































Comment













Comment Closed




Comment Closed


Rankins



Comment Closed









Kiefer








Rankins





Donakowski













Comment















Comment Closed













Comment Closed














Comment






Did EPA resolve

56 Section 4 Kiefer












Comment Withdrawn


















Comment Closed




Comment
















Comment Closed





Rankins






Comment












Kiefer




Kiefer

























95 Section 73111 73112 7312

Kiefer









Comment




Speckin















105 Section 82 83 84 85 8687





107 Figures 8-6 8-7 8-8 8-12 and 8-13


















Rankins




Rankins






Will be addressed


Comment
















1ES-2 last para 2nd

sentenceSpeckin



3445 p48 1st para

2nd sentenceSpeckin



paragraphWhitfill


5Section 75132 1st


Whitfill





7 Section 62 Hays






USACE Comments -

10 Section 626 Hays











3rd paraSpeckin



sentenceSpeckin




19Section 10511 p 269



20Section 10511 p 269









24Section 1052 p271








28Section 1061 2nd


29Section 107 p 274

2nd paraSpeckin



2nd paraSpeckin



sentenceSpeckin


Backcheck




barcode 30325719




USACE Comments -








































































































































































1ES-2 last para 2nd

sentenceSpeckin



3445 p48 1st para

2nd sentenceSpeckin



paragraphWhitfill


5Section 75132 1st


Whitfill





7 Section 62 Hays



USACE Comments -




10 Section 626 Hays











3rd paraSpeckin



sentenceSpeckin




19Section 10511 p 269



20Section 10511 p 269









24Section 1052 p271








28Section 1061 2nd


29Section 107 p 274

2nd paraSpeckin



2nd paraSpeckin



sentenceSpeckin





2017-12-15T145419-0600




Sheet3



Comment







Lyons








Lyons








Comment Closed



Rankins



Comment Closed










Rankins






Comment



11














































Comment













Comment Closed




Comment Closed


Rankins



Comment Closed









Kiefer








Rankins





Donakowski













Comment















Comment Closed













Comment Closed














Comment






Did EPA resolve

56 Section 4 Kiefer












Comment Withdrawn


















Comment Closed




Comment
















Comment Closed





Rankins






Comment












Kiefer




Kiefer

























95 Section 73111 73112 7312

Kiefer









Comment




Speckin















105 Section 82 83 84 85 8687





107 Figures 8-6 8-7 8-8 8-12 and 8-13


















Rankins




Rankins






Will be addressed


Comment
















1ES-2 last para 2nd

sentenceSpeckin



3445 p48 1st para

2nd sentenceSpeckin



paragraphWhitfill


5Section 75132 1st


Whitfill





7 Section 62 Hays






USACE Comments -

10 Section 626 Hays











3rd paraSpeckin



sentenceSpeckin




19Section 10511 p 269



20Section 10511 p 269









24Section 1052 p271








28Section 1061 2nd


29Section 107 p 274

2nd paraSpeckin



2nd paraSpeckin



sentenceSpeckin


Backcheck




barcode 30325719




USACE Comments -








































































































































































10 Section 626 Hays











3rd paraSpeckin



sentenceSpeckin




19Section 10511 p 269



20Section 10511 p 269









24Section 1052 p271








28Section 1061 2nd


29Section 107 p 274

2nd paraSpeckin



2nd paraSpeckin



sentenceSpeckin





2017-12-15T145419-0600




Sheet3



Comment







Lyons








Lyons








Comment Closed



Rankins



Comment Closed










Rankins






Comment



11














































Comment













Comment Closed




Comment Closed


Rankins



Comment Closed









Kiefer








Rankins





Donakowski













Comment















Comment Closed













Comment Closed














Comment






Did EPA resolve

56 Section 4 Kiefer












Comment Withdrawn


















Comment Closed




Comment
















Comment Closed





Rankins






Comment












Kiefer




Kiefer

























95 Section 73111 73112 7312

Kiefer









Comment




Speckin















105 Section 82 83 84 85 8687





107 Figures 8-6 8-7 8-8 8-12 and 8-13


















Rankins




Rankins






Will be addressed


Comment
















1ES-2 last para 2nd

sentenceSpeckin



3445 p48 1st para

2nd sentenceSpeckin



paragraphWhitfill


5Section 75132 1st


Whitfill





7 Section 62 Hays






USACE Comments -

10 Section 626 Hays











3rd paraSpeckin



sentenceSpeckin




19Section 10511 p 269



20Section 10511 p 269









24Section 1052 p271








28Section 1061 2nd


29Section 107 p 274

2nd paraSpeckin



2nd paraSpeckin



sentenceSpeckin


Backcheck




barcode 30325719




USACE Comments -





































































































































































20Section 10511 p 269









24Section 1052 p271








28Section 1061 2nd


29Section 107 p 274

2nd paraSpeckin



2nd paraSpeckin



sentenceSpeckin





2017-12-15T145419-0600




Sheet3



Comment







Lyons








Lyons








Comment Closed



Rankins



Comment Closed










Rankins






Comment



11














































Comment













Comment Closed




Comment Closed


Rankins



Comment Closed









Kiefer








Rankins





Donakowski













Comment















Comment Closed













Comment Closed














Comment






Did EPA resolve

56 Section 4 Kiefer












Comment Withdrawn


















Comment Closed




Comment
















Comment Closed





Rankins






Comment












Kiefer




Kiefer

























95 Section 73111 73112 7312

Kiefer









Comment




Speckin















105 Section 82 83 84 85 8687





107 Figures 8-6 8-7 8-8 8-12 and 8-13


















Rankins




Rankins






Will be addressed


Comment
















1ES-2 last para 2nd

sentenceSpeckin



3445 p48 1st para

2nd sentenceSpeckin



paragraphWhitfill


5Section 75132 1st


Whitfill





7 Section 62 Hays






USACE Comments -

10 Section 626 Hays











3rd paraSpeckin



sentenceSpeckin




19Section 10511 p 269



20Section 10511 p 269









24Section 1052 p271








28Section 1061 2nd


29Section 107 p 274

2nd paraSpeckin



2nd paraSpeckin



sentenceSpeckin


Backcheck




barcode 30325719




USACE Comments -







































































































































































Comment







Lyons








Lyons








Comment Closed



Rankins



Comment Closed










Rankins






Comment



11














































Comment













Comment Closed




Comment Closed


Rankins



Comment Closed









Kiefer








Rankins





Donakowski













Comment















Comment Closed













Comment Closed














Comment






Did EPA resolve

56 Section 4 Kiefer












Comment Withdrawn


















Comment Closed




Comment
















Comment Closed





Rankins






Comment












Kiefer




Kiefer

























95 Section 73111 73112 7312

Kiefer









Comment




Speckin















105 Section 82 83 84 85 8687





107 Figures 8-6 8-7 8-8 8-12 and 8-13


















Rankins




Rankins






Will be addressed


Comment
















1ES-2 last para 2nd

sentenceSpeckin



3445 p48 1st para

2nd sentenceSpeckin



paragraphWhitfill


5Section 75132 1st


Whitfill





7 Section 62 Hays






USACE Comments -

10 Section 626 Hays











3rd paraSpeckin



sentenceSpeckin




19Section 10511 p 269



20Section 10511 p 269









24Section 1052 p271








28Section 1061 2nd


29Section 107 p 274

2nd paraSpeckin



2nd paraSpeckin



sentenceSpeckin


Backcheck




barcode 30325719


Comment



11














































Comment













Comment Closed




Comment Closed


Rankins



Comment Closed









Kiefer








Rankins





Donakowski













Comment















Comment Closed













Comment Closed














Comment






Did EPA resolve

56 Section 4 Kiefer












Comment Withdrawn


















Comment Closed




Comment
















Comment Closed





Rankins






Comment












Kiefer




Kiefer

























95 Section 73111 73112 7312

Kiefer









Comment




Speckin















105 Section 82 83 84 85 8687





107 Figures 8-6 8-7 8-8 8-12 and 8-13


















Rankins




Rankins






Will be addressed


Comment
















1ES-2 last para 2nd

sentenceSpeckin



3445 p48 1st para

2nd sentenceSpeckin



paragraphWhitfill


5Section 75132 1st


Whitfill





7 Section 62 Hays






USACE Comments -

10 Section 626 Hays











3rd paraSpeckin



sentenceSpeckin




19Section 10511 p 269



20Section 10511 p 269









24Section 1052 p271








28Section 1061 2nd


29Section 107 p 274

2nd paraSpeckin



2nd paraSpeckin



sentenceSpeckin


Backcheck




barcode 30325719


Comment













Comment Closed




Comment Closed


Rankins



Comment Closed









Kiefer








Rankins





Donakowski













Comment















Comment Closed













Comment Closed














Comment






Did EPA resolve

56 Section 4 Kiefer












Comment Withdrawn


















Comment Closed




Comment
















Comment Closed





Rankins






Comment












Kiefer




Kiefer









88 Section 7122 4 J Donakowski It may be more appropriate to compare air concentrations to 20 of the NRC effluent limits per 40 CFR 61 Subpart H Same as comment 60 Comment Closed Defer to Comment 88 resolution
















95 Section 73111 73112 7312

Kiefer









Comment




Speckin















105 Section 82 83 84 85 8687





107 Figures 8-6 8-7 8-8 8-12 and 8-13


















Rankins




Rankins






Will be addressed


Comment
















1ES-2 last para 2nd

sentenceSpeckin



3445 p48 1st para

2nd sentenceSpeckin



paragraphWhitfill


5Section 75132 1st


Whitfill





7 Section 62 Hays






USACE Comments -

10 Section 626 Hays











3rd paraSpeckin



sentenceSpeckin




19Section 10511 p 269



20Section 10511 p 269









24Section 1052 p271








28Section 1061 2nd


29Section 107 p 274

2nd paraSpeckin



2nd paraSpeckin



sentenceSpeckin


Backcheck




barcode 30325719


Comment















Comment Closed













Comment Closed














Comment






Did EPA resolve

56 Section 4 Kiefer












Comment Withdrawn


















Comment Closed




Comment
















Comment Closed





Rankins






Comment












Kiefer




Kiefer

























95 Section 73111 73112 7312

Kiefer









Comment




Speckin















105 Section 82 83 84 85 8687





107 Figures 8-6 8-7 8-8 8-12 and 8-13


















Rankins




Rankins






Will be addressed


Comment
















1ES-2 last para 2nd

sentenceSpeckin



3445 p48 1st para

2nd sentenceSpeckin



paragraphWhitfill


5Section 75132 1st


Whitfill





7 Section 62 Hays






USACE Comments -

10 Section 626 Hays











3rd paraSpeckin



sentenceSpeckin




19Section 10511 p 269



20Section 10511 p 269









24Section 1052 p271








28Section 1061 2nd


29Section 107 p 274

2nd paraSpeckin



2nd paraSpeckin



sentenceSpeckin


Backcheck




barcode 30325719


Comment






Did EPA resolve

56 Section 4 Kiefer












Comment Withdrawn


















Comment Closed




Comment
















Comment Closed





Rankins






Comment












Kiefer




Kiefer

























95 Section 73111 73112 7312

Kiefer









Comment




Speckin















105 Section 82 83 84 85 8687





107 Figures 8-6 8-7 8-8 8-12 and 8-13


















Rankins




Rankins






Will be addressed


Comment
















1ES-2 last para 2nd

sentenceSpeckin



3445 p48 1st para

2nd sentenceSpeckin



paragraphWhitfill


5Section 75132 1st


Whitfill





7 Section 62 Hays






USACE Comments -

10 Section 626 Hays











3rd paraSpeckin



sentenceSpeckin




19Section 10511 p 269



20Section 10511 p 269









24Section 1052 p271








28Section 1061 2nd


29Section 107 p 274

2nd paraSpeckin



2nd paraSpeckin



sentenceSpeckin


Backcheck




barcode 30325719


Comment
















Comment Closed





Rankins






Comment












Kiefer




Kiefer

























95 Section 73111 73112 7312

Kiefer









Comment




Speckin















105 Section 82 83 84 85 8687





107 Figures 8-6 8-7 8-8 8-12 and 8-13


















Rankins




Rankins






Will be addressed


Comment
















1ES-2 last para 2nd

sentenceSpeckin



3445 p48 1st para

2nd sentenceSpeckin



paragraphWhitfill


5Section 75132 1st


Whitfill





7 Section 62 Hays






USACE Comments -

10 Section 626 Hays











3rd paraSpeckin



sentenceSpeckin




19Section 10511 p 269



20Section 10511 p 269









24Section 1052 p271








28Section 1061 2nd


29Section 107 p 274

2nd paraSpeckin



2nd paraSpeckin



sentenceSpeckin


Backcheck




barcode 30325719


Comment












Kiefer




Kiefer

























95 Section 73111 73112 7312

Kiefer









Comment




Speckin















105 Section 82 83 84 85 8687





107 Figures 8-6 8-7 8-8 8-12 and 8-13


















Rankins




Rankins






Will be addressed


Comment
















1ES-2 last para 2nd

sentenceSpeckin



3445 p48 1st para

2nd sentenceSpeckin



paragraphWhitfill


5Section 75132 1st


Whitfill





7 Section 62 Hays






USACE Comments -

10 Section 626 Hays











3rd paraSpeckin



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West Lake Landfill Superfund Site

Final - Backcheck of Remedial Investigation Addendum Report dated June 16 2017 New comments on Final RIA Report dated New Comments RIA - Nov 28 2017

USACE Comments -


Comment		Reference Section Paragraph Appendix		Commentor		Comment	Backcheck

1		ES-2 last para 2nd sentence		Speckin		For consistency shouldnt the 79 pCig be introduced here The 50 pCig above background was included in the introduced in the 545 pCig concentration Or maybe just indicate uranium is 50 pCig above background and remove the 545

2		p27 last sentence		Speckin		Should say southwestern portion of Area 1 not southeastern This is also addressed in the backcheck comments

3		445 p48 1st para 2nd sentence		Speckin		Recommend changing to read hellipto prevent a subsurface heating event from coming in contact with the radioactive materials contained in the West Lake Landfill

4		Section 626 Definition of RIM page 169 2nd paragraph		Whitfill		This is a confusing paragraph that may read better if the mini discussion of the buildup of Ra-226 from Th-230 is consolidated to a separate paragraph or re-written for better flow The future ingrowth has nothing to do with the derived response levels

5		Section 75132 1st para 4th to last sentence		Whitfill		NOTE This comment most likely is better applied to OU3 RI Radium occurrences in Leachate page 225 first paragraph 4th to last sentences ldquoPrior to 2013 this involved testing of non-treated leachaterdquoIs non-treated leachate still being tested If not this appears to be a lost opportunity and important to monitor at least periodically if leachate from Areas 1 and 2 are migrating through the different elevations to the lowest point where the leachate collection system is located I would think testing for Th-230 would also be prudent It is noted in Section 5622 that there is no liner or leachate collection system in Areas 1 and 2 If the leachate from these areas does not migrate towards the lower elevated leachate collection system then where does it go

6		Section 61		Hays		The process describing waste production is confusin at best and should be made into a figure or diagram Check use of K-65 for appropriatness stating K-65 may not be needed here

7		Section 62		Hays		Recommend the language from the SOR discussion of U data be moved more upfront in the definition discussions and used as a means to eliminate having to set a value The 50 pCig value is protective onsites without significant GW concerns The depth of the material and ground water concerns at WLLF causes concern for the appropriateness of the U value and as pointed out in the SOR comparison excess U is only found with excess Ra and Th thus not needed

	Section 625		Hays		pg 186 Use of term DCGL should be deleted as not appropriate here While conservative the approach of reducing the Ra-228 background to the Th-232 value is flawed as alpha spec for Th-232 often produces results less than Ra-228 analysis due to small aliquot size As such most projects use Ra-228 data as it better represents the actual conditions Again done conservatively as is

8		Section 626		Hays		pg 188 new text discusses process of defining RIM as establishment of cleanup levels for the West Lake Landfill This should be deleted as not appropriate for an RI

9		Section 626		Hays		pg 190 Delete statement that def of RIM is more stringent than criteria at North County FUSRAP

10		Section 626		Hays		In general the comparison of RIM def to FUSRAP clean up level discussions should be deleted and a simple table of values should be presented Language attempting to explain why FUSRAP criteria was selected is limited in usefulness and does not tell the complete story Using a simple table of stated values will allow the reader to determine the appropriateness of the definition without causing confusion and potential concerns for the FUSRAP sites

11		Section 7321		Hays		pg 232 USACE previously commented on defining the source of PRGs (Donakowski cmt 98) and that comment was addressed in that section The use of PRG in this section should also be deleted or defined per comment 98

12		Section 75132		Hays		This section could be considered as misleading to public The stated permit levels are very high compared to typical environmental levels of concern but by stating all less than the permit levels it paints a diferent picture I realize this is an OU 3 issue and maybe as such should be deleted altogether

13		Section 9 1		Speckin		The acrynom for lifetime cancer risks (LCR) is not in the list of acrynoms

14		Section 93 p261 top para last sentence		Speckin		This sentence states that modeled radon activity in air from OU-1 is similar to background activity However the previous sentence indicates Future off-property risks are primarily attributable to radon and its daughter products in air If similar to background how can there be a risk exceedance because arnt we looking at increased risk from background conditions

15		Section 1042 p 266 last line		Speckin		When refering to the 1977 EGampG flyover recommend referencing Appendix A-1

16		Sectioin 1042 p 267 3rd para		Speckin		Indicates that the above ground surface portion of the North Quarry started in 1979 However Figure 3-9 shows in started in 2002 Also recommend referencing 2002 It also may be helpful to include aerials up to the present in Appendix O

17		Sectioin 1042 p 267 3rd para 2nd to last sentence		Speckin		Indicates fill above grade in the north quarry occurred long after placement of the LBSR-impacted soils Why not just give the year it began (2002) instead of being vague

18		Sectioin 1042 p 268 top para		Speckin		When referring to the 1977 EGampG survey recommend referencing Appendix A-1

19		Section 10511 p 269 1st full para 1st sentence		Speckin		Recommend providing a timeframe of this sampling and whether or not there were any noticeable changes from before and after the NCC cover Also reference Figure 4-20

20		Section 10511 p 269 1st full para 2nd sentence		Speckin		Recommend identifying the levels instead of just lt05 pCiL

21		Section 10512 p270 1st para 1st sentence		Speckin		Recommend referencing Figure 4-20 when discussing the 13 monitoring stations

22		Section 10512 p270 2nd para 1st sentence		Speckin		Discusses EPAs 5 monitoring stations Recommend indicating a date range when these monitoring stations were present and also providing a Figure showing the locations If a Figure already shows the locations recommend referencing it here

23		Section 1052 p271 1st para 1st sentence		Speckin		32 pCIL should be 32 pCiL

24		Section 1052 p271 2nd para last sentence		Speckin		It seems more information should be provided to make this conclusion Only provided results of a single location and it does not justify the conclusion Recommend reference location of an expanded discussion andor data

25		Section 1054 p 272 4th para middle of para		Speckin		Recommend giving a concentration or range of concentrations of the vinyl chloride detections

26		Section 106 p273		Speckin		Figure 9-3 should be referenced instead of Figure 9-1

27		Section 1061 1st para 3rd sentence		Speckin		This sentence appears to contradict the last sentence of this paragraph

28		Section 1061 2nd para pages 273 amp 274		Speckin		The (for 1000 years in the future) does not need to come after each time the word future is used

29		Section 107 p 274 2nd para		Speckin		This paragraph states that unacceptable risks to future on-site workers could occur before 1000 years Couldnt this also be true for off-property receptors

30		Section 1072 p 275 2nd para		Speckin		Indicates Zirconium anad cobalt are the primary contributors to His greater than 1 Are these an issue for the current scenario If so shouldnt this discussion be included in 1071 If not there should be a brief explanation why it is included in here and not under the current receptor discussion

31		Section 1072 p 275 last para 2nd to last sentence		Speckin		How can radon be a risk if modeled levels are similar to naturally-occurring activity Isnt risk based on an increased level above background

kiefer, robyn v civ usarmy cenwk (us) jump, christine · from: kiefer, robyn v civ usarmy cenwk...

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