Kiefer, Robyn V CIV USARMY CENWK (US) Jump, Christine · From: Kiefer, Robyn V CIV USARMY CENWK (US) To: Jump, Christine Cc: Barker, Justin; Juett, Lynn; Young, Scott E CIV USARMY
Post on 23-Aug-2020
7 Views
Preview:
Transcript
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
6Executive 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
Backcheck Conductd 12-15-17
West Lake Landfill Superfund Site
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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 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)
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 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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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 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
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 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
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 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
Addressed Comment Closed
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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 addressedAddressed 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
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
54 Section 41222 2nd paragraph
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
Will be addressed Addressed Comment Closed
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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 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)
Will be addressed Addressed Comment Closed
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
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
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
Will be addressed Addressed Comment Closed
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 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
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
Defer to EPA Comment Closed
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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
Will be addressed Clarified Comment Closed
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
Addressed Comment Closed
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)
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 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
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
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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)
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 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
West Lake Landfill Superfund Site
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
18Sectioin 1042 p 268
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
23Section 1052 p271 1st para 1st sentence
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
25Section 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
27Section 1061 1st para
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
30Section 1072 p 275
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
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
6Executive 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
Backcheck Conductd 12-15-17
West Lake Landfill Superfund Site
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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 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)
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 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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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 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
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 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
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 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
Addressed Comment Closed
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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 addressedAddressed 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
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
54 Section 41222 2nd paragraph
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
Will be addressed Addressed Comment Closed
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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 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)
Will be addressed Addressed Comment Closed
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
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
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
Will be addressed Addressed Comment Closed
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 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
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
Defer to EPA Comment Closed
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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
Will be addressed Clarified Comment Closed
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
Addressed Comment Closed
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)
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 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
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
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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)
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 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
West Lake Landfill Superfund Site
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
18Sectioin 1042 p 268
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
23Section 1052 p271 1st para 1st sentence
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
25Section 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
27Section 1061 1st para
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
30Section 1072 p 275
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
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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 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)
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 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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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 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
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 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
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 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
Addressed Comment Closed
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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 addressedAddressed 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
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
54 Section 41222 2nd paragraph
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
Will be addressed Addressed Comment Closed
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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 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)
Will be addressed Addressed Comment Closed
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
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
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
Will be addressed Addressed Comment Closed
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 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
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
Defer to EPA Comment Closed
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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
Will be addressed Clarified Comment Closed
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
Addressed Comment Closed
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)
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 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
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
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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)
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 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
West Lake Landfill Superfund Site
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
18Sectioin 1042 p 268
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
23Section 1052 p271 1st para 1st sentence
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
25Section 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
27Section 1061 1st para
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
30Section 1072 p 275
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
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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 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
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 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
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 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
Addressed Comment Closed
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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 addressedAddressed 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
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
54 Section 41222 2nd paragraph
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
Will be addressed Addressed Comment Closed
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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 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)
Will be addressed Addressed Comment Closed
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
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
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
Will be addressed Addressed Comment Closed
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 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
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
Defer to EPA Comment Closed
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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
Will be addressed Clarified Comment Closed
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
Addressed Comment Closed
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)
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 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
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
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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)
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 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
West Lake Landfill Superfund Site
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
18Sectioin 1042 p 268
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
23Section 1052 p271 1st para 1st sentence
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
25Section 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
27Section 1061 1st para
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
30Section 1072 p 275
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
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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 addressedAddressed 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
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
54 Section 41222 2nd paragraph
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
Will be addressed Addressed Comment Closed
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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 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)
Will be addressed Addressed Comment Closed
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
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
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
Will be addressed Addressed Comment Closed
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 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
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
Defer to EPA Comment Closed
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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
Will be addressed Clarified Comment Closed
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
Addressed Comment Closed
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)
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 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
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
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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)
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 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
West Lake Landfill Superfund Site
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
18Sectioin 1042 p 268
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
23Section 1052 p271 1st para 1st sentence
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
25Section 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
27Section 1061 1st para
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
30Section 1072 p 275
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
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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 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)
Will be addressed Addressed Comment Closed
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
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
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
Will be addressed Addressed Comment Closed
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 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
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
Defer to EPA Comment Closed
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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
Will be addressed Clarified Comment Closed
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
Addressed Comment Closed
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)
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 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
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
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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)
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 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
West Lake Landfill Superfund Site
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
18Sectioin 1042 p 268
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
23Section 1052 p271 1st para 1st sentence
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
25Section 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
27Section 1061 1st para
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
30Section 1072 p 275
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
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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 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)
Will be addressed Addressed Comment Closed
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
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
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
Will be addressed Addressed Comment Closed
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 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
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
Defer to EPA Comment Closed
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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
Will be addressed Clarified Comment Closed
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
Addressed Comment Closed
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)
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 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
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
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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)
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 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
West Lake Landfill Superfund Site
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
18Sectioin 1042 p 268
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
23Section 1052 p271 1st para 1st sentence
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
25Section 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
27Section 1061 1st para
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
30Section 1072 p 275
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
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
Will be addressed Addressed Comment Closed
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 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
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
Defer to EPA Comment Closed
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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
Will be addressed Clarified Comment Closed
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
Addressed Comment Closed
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)
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 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
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
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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)
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 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
West Lake Landfill Superfund Site
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
18Sectioin 1042 p 268
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
23Section 1052 p271 1st para 1st sentence
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
25Section 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
27Section 1061 1st para
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
30Section 1072 p 275
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
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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
Will be addressed Clarified Comment Closed
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
Addressed Comment Closed
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)
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 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
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
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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)
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 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
West Lake Landfill Superfund Site
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
18Sectioin 1042 p 268
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
23Section 1052 p271 1st para 1st sentence
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
25Section 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
27Section 1061 1st para
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
30Section 1072 p 275
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
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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)
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 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
West Lake Landfill Superfund Site
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
18Sectioin 1042 p 268
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
23Section 1052 p271 1st para 1st sentence
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
25Section 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
27Section 1061 1st para
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
30Section 1072 p 275
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
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
West Lake Landfill Superfund Site
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
18Sectioin 1042 p 268
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
23Section 1052 p271 1st para 1st sentence
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
25Section 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
27Section 1061 1st para
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
30Section 1072 p 275
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
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
18Sectioin 1042 p 268
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
23Section 1052 p271 1st para 1st sentence
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
25Section 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
27Section 1061 1st para
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
30Section 1072 p 275
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
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
23Section 1052 p271 1st para 1st sentence
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
25Section 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
27Section 1061 1st para
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
30Section 1072 p 275
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
Security settings or invalid file format do not permit using USACE Comment Transmittal - Draft Final 2 RIApdf (343494 Bytes)
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
6Executive 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
Backcheck Conductd 12-15-17
West Lake Landfill Superfund Site
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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 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)
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 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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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 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
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 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
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 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
Addressed Comment Closed
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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 addressedAddressed 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
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
54 Section 41222 2nd paragraph
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
Will be addressed Addressed Comment Closed
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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 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)
Will be addressed Addressed Comment Closed
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
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
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
Will be addressed Addressed Comment Closed
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 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
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
Defer to EPA Comment Closed
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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
Will be addressed Clarified Comment Closed
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
Addressed Comment Closed
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)
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 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
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
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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)
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 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
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
West Lake Landfill Superfund Site
USACE Comments -
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
18Sectioin 1042 p 268
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
23Section 1052 p271 1st para 1st sentence
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
25Section 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
27Section 1061 1st para
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
30Section 1072 p 275
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
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
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
6Executive 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
Backcheck Conductd 12-15-17
West Lake Landfill Superfund Site
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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 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)
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 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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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 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
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 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
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 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
Addressed Comment Closed
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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 addressedAddressed 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
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
54 Section 41222 2nd paragraph
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
Will be addressed Addressed Comment Closed
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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 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)
Will be addressed Addressed Comment Closed
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
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
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
Will be addressed Addressed Comment Closed
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 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
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
Defer to EPA Comment Closed
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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
Will be addressed Clarified Comment Closed
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
Addressed Comment Closed
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)
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 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
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
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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)
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 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
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
West Lake Landfill Superfund Site
USACE Comments -
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
18Sectioin 1042 p 268
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
23Section 1052 p271 1st para 1st sentence
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
25Section 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
27Section 1061 1st para
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
30Section 1072 p 275
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
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
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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 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)
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 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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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 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
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 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
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 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
Addressed Comment Closed
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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 addressedAddressed 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
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
54 Section 41222 2nd paragraph
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
Will be addressed Addressed Comment Closed
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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 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)
Will be addressed Addressed Comment Closed
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
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
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
Will be addressed Addressed Comment Closed
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 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
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
Defer to EPA Comment Closed
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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
Will be addressed Clarified Comment Closed
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
Addressed Comment Closed
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)
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 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
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
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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)
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 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
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
West Lake Landfill Superfund Site
USACE Comments -
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
18Sectioin 1042 p 268
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
23Section 1052 p271 1st para 1st sentence
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
25Section 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
27Section 1061 1st para
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
30Section 1072 p 275
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
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
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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 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
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 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
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 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
Addressed Comment Closed
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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 addressedAddressed 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
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
54 Section 41222 2nd paragraph
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
Will be addressed Addressed Comment Closed
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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 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)
Will be addressed Addressed Comment Closed
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
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
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
Will be addressed Addressed Comment Closed
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 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
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
Defer to EPA Comment Closed
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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
Will be addressed Clarified Comment Closed
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
Addressed Comment Closed
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)
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 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
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
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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)
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 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
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
West Lake Landfill Superfund Site
USACE Comments -
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
18Sectioin 1042 p 268
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
23Section 1052 p271 1st para 1st sentence
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
25Section 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
27Section 1061 1st para
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
30Section 1072 p 275
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
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
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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 addressedAddressed 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
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
54 Section 41222 2nd paragraph
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
Will be addressed Addressed Comment Closed
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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 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)
Will be addressed Addressed Comment Closed
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
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
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
Will be addressed Addressed Comment Closed
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 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
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
Defer to EPA Comment Closed
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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
Will be addressed Clarified Comment Closed
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
Addressed Comment Closed
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)
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 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
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
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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)
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 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
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
West Lake Landfill Superfund Site
USACE Comments -
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
18Sectioin 1042 p 268
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
23Section 1052 p271 1st para 1st sentence
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
25Section 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
27Section 1061 1st para
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
30Section 1072 p 275
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
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
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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 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)
Will be addressed Addressed Comment Closed
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
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
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
Will be addressed Addressed Comment Closed
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 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
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
Defer to EPA Comment Closed
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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
Will be addressed Clarified Comment Closed
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
Addressed Comment Closed
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)
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 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
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
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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)
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 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
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
West Lake Landfill Superfund Site
USACE Comments -
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
18Sectioin 1042 p 268
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
23Section 1052 p271 1st para 1st sentence
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
25Section 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
27Section 1061 1st para
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
30Section 1072 p 275
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
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
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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 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)
Will be addressed Addressed Comment Closed
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
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
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
Will be addressed Addressed Comment Closed
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 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
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
Defer to EPA Comment Closed
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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
Will be addressed Clarified Comment Closed
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
Addressed Comment Closed
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)
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 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
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
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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)
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 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
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
West Lake Landfill Superfund Site
USACE Comments -
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
18Sectioin 1042 p 268
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
23Section 1052 p271 1st para 1st sentence
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
25Section 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
27Section 1061 1st para
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
30Section 1072 p 275
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
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
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
Will be addressed Addressed Comment Closed
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 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
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
Defer to EPA Comment Closed
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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
Will be addressed Clarified Comment Closed
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
Addressed Comment Closed
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)
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 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
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
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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)
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 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
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
West Lake Landfill Superfund Site
USACE Comments -
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
18Sectioin 1042 p 268
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
23Section 1052 p271 1st para 1st sentence
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
25Section 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
27Section 1061 1st para
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
30Section 1072 p 275
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
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
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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
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
Will be addressed Clarified Comment Closed
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
Addressed Comment Closed
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)
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 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
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
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
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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)
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 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
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
West Lake Landfill Superfund Site
USACE Comments -
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
18Sectioin 1042 p 268
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
23Section 1052 p271 1st para 1st sentence
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
25Section 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
27Section 1061 1st para
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
30Section 1072 p 275
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
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
Comment
Reference Section Paragraph Appendix
Commentor Comment EPA Comment Coordination Results 81017 Backcheck against RIA dated Nov 28 2017
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)
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 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
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
West Lake Landfill Superfund Site
USACE Comments -
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
18Sectioin 1042 p 268
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
23Section 1052 p271 1st para 1st sentence
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
25Section 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
27Section 1061 1st para
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
30Section 1072 p 275
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
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
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
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
West Lake Landfill Superfund Site
USACE Comments -
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
18Sectioin 1042 p 268
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
23Section 1052 p271 1st para 1st sentence
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
25Section 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
27Section 1061 1st para
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
30Section 1072 p 275
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
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
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
18Sectioin 1042 p 268
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
23Section 1052 p271 1st para 1st sentence
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
25Section 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
27Section 1061 1st para
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
30Section 1072 p 275
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
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
25Section 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
27Section 1061 1st para
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
30Section 1072 p 275
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
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
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
- 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
top related