ST. LOUIS DISTRICT

The Formerly Utilized Sites Remedial Action Program (FUSRAP) is an environmental remediation program. It addresses radiological contamination generated by activities of the Manhattan Engineer District and the Atomic Energy Commission (MED/AEC) during development of the atomic weapons in the 1940s and 50s.

Background

From 1942 to 1957, the Mallinckrodt Chemical Plant extracted uranium and radium from ore at the St. Louis Downtown Site (SLDS) in St. Louis, Missouri. During this time and until 1967, radioactive process byproducts were stored at an area adjacent to the Lambert-St. Louis Airport, which is now referred to as the St. Louis Airport Site (SLAPS). 

In 1966, certain SLAPS wastes were purchased, moved, and stored at Latty Avenue. Part of this property later became known as the Hazelwood Interim Storage Site (HISS). During this move, improper handling, and transportation of the contamination caused the spread of materials along haul routes and to adjacent vicinity properties forming the St. Louis Airport Site Vicinity Properties (SLAPS VPs).

During the late 1950s and early 1960s, Dow Chemical Company in Madison, Illinois operated as a uranium extrusion and rod-straightening facility leaving contamination in dust located on roof beams at the Madison Site.

The United States Army Corps of Engineers (USACE), St. Louis District is conducting a radiological cleanup program for these five St. Louis Sites (SLDS, SLAPS, SLAPS VPs, HISS and Madison). The sites contain soils contaminated with radium, thorium, and uranium as a result of federal defense activities performed under contracts with the Manhattan Engineer District and the Atomic Energy Commission (MED/AEC) in the 1940s and 50s (see Chronology for more information).

The 1998 Energy and Water Appropriations Bill, in which Congress transferred management of the Formerly Utilized Sites Remedial Action Program (FUSRAP) to the U. S. Army Corps of Engineers (USACE), was signed into law on October 13, 1997. Prior to the signing of this bill, FUSRAP was managed by the U. S. Department of Energy.

How Hazardous Are FUSRAP Sites?

Even though FUSRAP sites contain levels of radioactivity above current guidelines, none pose an immediate health risk to the public or environment given their current land uses. The contaminated materials have very low concentrations and people are not exposed to them for long periods of time.

Although these materials do not pose an immediate hazard, they will remain radioactive for thousands of years, and health risks could increase if the use of the land were to change. Under FUSRAP, each site is cleaned to levels acceptable for the projected future use for the land such as residential development, industrial operations, or recreational use.

What Are FUSRAP's Objectives?

The objectives of FUSRAP are to:
    • Protect human health and the environment.
• Execute the approved alternative for cleaning up the radioactive
        contamination above health-based cleanup guidelines.
• Minimize adverse effects on area business operations.

How Does FUSRAP Work?

FUSRAP sites undergo several steps that lead to cleanup. Information about the site is collected and reviewed. A Remedial Investigation/Feasibility Study (RI/FS) is conducted to develop cleanup alternatives.

The Remedial Investigation identifies the type and location of the contamination. The Feasibility Study develops and evaluates cleanup alternatives. The public is informed about the development of the RI/FS cleanup alternatives through public meetings and the media. Public participation is especially encouraged during the selection of the final remediation, or cleanup, method.

When a cleanup alternative is chosen, a Proposed Plan (PP) is written to explain why it was chosen. Members of the public are asked to comment on the cleanup options, including the selected alternative. After public comments have been considered, a final decision is made and documented in a Record of Decision (ROD). The Remedial Design follows the ROD and includes technical drawings and specifications that show how the cleanup will be conducted.

Cleanup, or Remedial Action, begins after the Remedial Design is complete. This phase involves site preparation and construction activities. When these remediation activities are completed, verification surveys are conducted to ensure that cleanup objectives for the site have been met and are documented in a Post Remedial Action Report (PRAR).

Risk Assessment

A Risk Assessment is a decision-making tool used to evaluate the likelihood of an unwanted event. An unwanted event could be someone getting cancer because of exposure to contaminants or it could be great numbers of fish dying because of pollution being dumped into a stream. Specially trained individuals called Risk Assessors evaluate how threatening a hazardous waste is to human health and the environment. In order to evaluate the potential for exposure to hazards and determine the likelihood for adverse effects on humans or the environment, risk assessors consider four questions:

1. Hazard Identification - What contaminants exist at the site?
2. Exposure - How are people exposed to them?
3. Toxicity Assessment - How dangerous could the contaminants be to human health?
4. Exposure & Toxicity Assessment - What contaminant concentrations are safe?

Reliable risk assessment methods provide the information necessary to discriminate between important and trivial threats. They also help people set priorities and allocate resources responsibly. The selection of site remediation alternatives involves the interaction of regulators with the community. A key challenge at the end of a risk assessment is to present the risk in a way that is meaningful and clear to the public.

Cancer Risks

The risks of getting cancer from exposure to site waste are expressed in probabilities. According to U. S. Environmental Protection Agency (EPA) guidelines, a person should not be exposed to radiation or a cancer-causing chemical if exposure increases that person's lifetime cancer risk by more than one chance in 1,000,000 ( or by .000001). Therefore, cleanup actions are selected primarily on how well they protect human health and the environment and on how well they meet safety requirements. In comparison, almost one in three people will get cancer from other causes.

Toxic Risks

A Hazard Index (HI) is used to estimate potential toxic risk from chemicals that do not cause cancer. The HI takes into account likely exposure and the toxicity of different chemicals and elements. If the HI at a site is 1.0 or more, this means that a person's health could be affected.

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Exposure Pathways

Scientists evaluate the effects of pollutants on an environment and its inhabitants by examining the exposure pathways. A pathway is a route by which hazardous materials may come into contact with people.

Although external contact with radiation can cause damage by irradiating the body from the outside, the primary hazard FUSRAP material poses is from material taken internally. Pollutants may reach people directly if they inhale or ingest contaminated air, water, or soil. Exposure is also possible via secondary pathways like a food chain. As a simplified example, dust released from a production stack settles onto a field and is mixed into the soil. Plants growing there absorb the pollutant through their roots and into the edible portions of the plant. People who eat the plants (or who eat the animals that ate the plants) might then be exposed to the pollutant.

The actual route that pollutants take can be very complex, and the quantity of material that may eventually reach people can be very small. To develop an understanding of the complexity, imagine the variables present in the figure shown. Not all materials released settle immediately; some will be washed out by rain and enter surface water or ground-water. Of the portion that does fall, not all will fall on the field. And of what does fall in the field, not all will be absorbed into plants. This process of dilution and separation alters what reaches the plant and the fruit of the plant until it is a small fraction of the initial release.

Certain plants, animals, and soils are more likely to concentrate specific pollutants and are, therefore, important points in pathways to be sampled. However, pathways frequently overlap, and it is difficult to trace pollutants precisely. Environmental sampling and analysis are performed to detect the presence and concentration of pollutants.

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Assessing the St. Louis Sites

The St. Louis Sites were used to process and/or store uranium for the nation's nuclear defense program. By-product materials contained radioactive radium, thorium, and uranium, as well as processing chemicals. A Baseline Risk Assessment, which evaluated the Missouri sites in 1993, describes the potential risks to human health and the environment. The study found that if nothing was done to cleanup the site and the future land use became residential, the public could be exposed to unacceptable cancer and toxic risks.

Cancer Risks

This chart compares the carcinogenic risk at St. Louis sites to the leading mortality risks in the United States.

Chemical Risks

Carcinogenic risks from chemicals at the St. Louis sites were within the acceptable EPA range. However, the sites could pose carcinogenic risks from chemicals to people who live directly on the properties for long periods of time. Without cleanup, carcinogenic chemicals and elements could potentially affect human health and the environment.

Exposure Pathways

Although both radioactive and nonradioactive materials can reach people through the same pathways, the pathway scenarios studied at the St. Louis Sites focus on radioactive materials as the primary hazard to human health. Uranium and its daughter products, thorium and radium are the primary contaminants of concern. The two major pathways under study at the St. Louis Sites are air and liquid pathways.

Air Pathways

The air pathway at the St. Louis Sites includes airborne contamination from storage sites and buildings. Dust from construction and remediation activities, waste handling, and wind erosion are also important potential sources. The form and chemical makeup of the contaminants influence how they are dispersed into the environment. For example, fine particles and gases may be breathed in, while larger, heavier particles tend to settle rapidly. Chemical properties determine whether the pollutant will dissolve in water, be absorbed by plants and animals, or settle in sediments and soils. Airborne pollutants are subject to weather conditions. Wind speed and direction, rainfall, and temperature are important factors in predicting how pollutants are distributed in the environment.

Protective coverings are in place at SLAPS and HISS to limit the air exposure pathways and reduce health risks.

Liquid Pathways

The liquid pathway examined at the St. Louis Sites includes all releases that could carry waterborne pollutants, including radioactive materials. The first step in monitoring this pathway is to sample the effluent streams as they leave all contaminated sites. Types and concentrations of pollutants in these streams provide the first estimate of the potential dose that could be delivered via the liquid pathway. Some pollutants in the liquid effluent may be carried along as suspended solids, which eventually settle out as sediment in the stream bed. Other pollutants dissolve in water and may be absorbed by plants and ingested by animals. Fish sampling can show how pollutants are absorbed by aquatic animals and can predict how much radioactive material could reach people if they ate the affected fish. Fish are often used as biological indicators, as their bodies concentrate certain pollutants, resulting in biological effects. Fish sampling helps to develop an evaluation of long-term contamination.

Ground-water is also an important component of the liquid pathway because it is the source of water for many homes and farms in the St. Louis area. Extensive well sampling on the St. Louis Sites and in the surrounding area provides information about the status of area ground-water. By sampling ground-water in many locations and at many different depths, scientists can determine the extent of contamination.

To help limit the potential for radioactive materials to move off-site by the liquid pathway, run-off water at the St. Louis Airport Site has been diverted to a Sedimentation Basin. Protective coverings at the Hazelwood Interim Storage Site minimize erosion by wind and water.

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Public Health Implications

The effects of exposure are unpredictable. If a person comes in direct contact with a contaminant by touching, eating, breathing or drinking a pollutant-bearing substance, he is exposed. Variable factors, however. affect the severity of the adverse health effect. Primarily, these variable factors include the concentration of the contaminant, the frequency and duration of exposure, the number of contaminants, and the pathways of exposure. An individual's own characteristics (age, gender, nutritional / health status, lifestyle, etc.) also influence the results of exposure to a contaminant.

Exposure pathways at the St. Louis Sites have specific standards and guidelines set by federal and state regulators that define the allowable dose limits. Health guidelines provide a way for public health administrators to compare estimated exposures with concentrations of contaminants in the soil, air, water, and food that people contact. The relative risk for cancer and other illnesses is determined, and guidelines and limits are set according to established legislation.

A number of federal laws and regulations guide every step of the FUSRAP cleanup process--from initial site identification to final certification.

It is typical for many FUSRAP sites to fall under several of these laws at the same time, depending on the type of contamination and the actions required to clean it up. Because so many different federal laws apply to environmental cleanup, compliance with these laws becomes very complex. Under certain circumstances, for example, the act of excavating contaminated soil could be affected by all of the laws discussed here. A general description of the main federal laws that apply to FUSRAP follows. While the focus of each law is different, their goals are the same: to protect human health and the environment.

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CERCLA

The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980 is the main law governing cleanup of FUSRAP sites. In 1986 major changes to this federal law were enacted with the passing of the Superfund Amendments and Reauthorization Act (SARA), which authorized the study and clean up uncontrolled hazardous waste sites. The CERCLA (or Superfund) process consists of three phases:

• Preliminary Assessment
• Evaluating cleanup alternatives
• Selecting a cleanup plan

The Preliminary Assessment is used to decide which sites should be added to the National Priorities List (NPL), which identifies the most serious uncontrolled hazardous waste sites. Sites are scored based on their impact on public health and the environment, and those sites that exceed a certain score are added to the NPL.

The Environmental Protection Agency (EPA) oversees CERCLA activities at most NPL sites. The cleanup of FUSRAP NPL sites is guided by a Federal Facilities Agreement (FFA) with EPA and with input from state agencies where the sites are located. The FFA also sets cleanup priorities, defines agency responsibilities, document reviews, interaction among agency officials, and establishes a schedule for work at a site.

CERCLA requirements for site cleanups vary based on the site's size and the extent of contamination. At the major sites, after an initial planning period workers begin a remedial investigation to identify the types and locations of contamination present. At the same time, a feasibility study is conducted that uses the results of the remedial investigation to formulate a range of cleanup options.

CERCLA allows and encourages public involvement at all stages in the process that leads to a decision for cleaning up a site. The public has an opportunity to
comment on the results of the remedial investigation and the analysis of alternatives. To keep the public informed, the Corps uses various community outreach programs, including public information centers, public meetings, and periodic fact sheets. Key documents used in making a cleanup decision at a site make up an administrative record, which is available to the public at a location near the site.

After the public comment period on the proposed plan is closed, the Corps prepares a draft Record of Decision and submits it to EPA. For NPL sites, EPA concurs or makes the final decision on site cleanup after considering input from state agencies and from the public, and the decision is final when the regulators and the Corps sign a legally binding Record of Decision.

You can find the actual law at the U.S. House of Representatives site: click on paragraph 103.

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NEPA

The National Environmental Policy Act (NEPA) sets basic national policy on environmental protection. This 1969 federal law established a process for determining if a proposed federal action will have significant environmental effects. NEPA requires federal agencies to consider environmental effects before proceeding with proposed actions.

Proposed federal actions are evaluated in light of NEPA guidelines to determine potential environmental effects and the level of NEPA documentation required. Depending on the results of initial findings, NEPA specifies several options: if an action will clearly have no significant impact, no further studies are required. If an action may have an impact on the environment, an Environmental Assessment or an Environmental Impact Statement (EIS) may be required.

In preparing an Environmental Assessment, information is gathered and studied to decide whether impacts are great enough to mean a more complete EIS study is needed. If an EIS is not required, a "finding of no significant impact" is issued.

When an EIS is required for an action at a site, NEPA requires public input early in the process of studying site conditions and cleanup options. Public involvement at all stages of the process helps ensure that problems are identified, focuses energies and efforts on those areas that must be resolved, and makes for a balanced and complete EIS.

For more information about NEPA visit the Council on Environmental Quality website.

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The CERCLA / NEPA Process

Because many requirements of CERCLA and NEPA are similar or over-lapping, most FUSRAP sites are cleaned up under an integrated CERCLA / NEPA process. Actual cleanup and decision-making activities are achieved under the requirements of CERCLA. Community relations activities are combined under the more comprehensive provisions of CERCLA and may borrow from the special requirements of NEPA where necessary. Coordination of CERCLA and NEPA requirements results in a means for open decision-making that involves the public, as well as local, state, and federal agencies. Site investigations, analyses, and documentation requirements of these laws are integrated to simplify regulatory review, reduce paperwork, and increase cost-effectiveness.

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RCRA

In addition to CERCLA and NEPA, a number of other federal regulations may also apply to FUSRAP sites, such as the Resource Conservation and Recovery Act (RCRA). Passed in 1976 as an amendment to the Solid Waste Disposal Act, RCRA establishes a "cradle to grave" system for controlling hazardous waste from the time it is generated until its ultimate disposal.

Contaminated materials at FUSRAP sites may contain both hazardous and radioactive waste. This mixed waste presents special challenges to the FUSRAP program. RCRA provides very specific requirements stating how mixed waste can be managed, treated, and disposed. RCRA also requires appropriate systems for permits and waste management at all FUSRAP sites that involve mixed waste.

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Other Regulations

Each FUSRAP site is unique and may need to meet the requirements of other specific laws designed to apply to certain types of contaminants or to particular types of cleanup circumstances. For example, if performing an excavation that may release contaminated dust particles into the air, FUSRAP many need to comply with the requirements of the Clean Air Act. In other situations FUSRAP may need to comply with different laws such as the Toxic Substances Control Act, the Clean Water Act, and/or the Safe Drinking Water Act. Many other federal, state, and local standards that may also apply to the FUSRAP cleanup.

Effective communication between the U. S. Army Corps of Engineers (USACE) and the public (government officials, interest groups, area residents) encourages understanding and knowledge of FUSRAP activities, minimizing or avoiding rumors and misinformation.

The USACE has developed a community relations program designed to involve the public in activities and decisions related to the cleanup of St. Louis FUSRAP Sites. Our public involvement program attempts to include community residents living near these sites in the decision-making process by:

• providing opportunities for citizens to express comments and concerns
and to providing input into technical decisions
• informing the public of planned or ongoing actions
• identifying and resolving conflicts
• facilitating community relations planning

To accomplish these objectives, the USACE developed several activities to encourage community involvement.

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Information Repositories

The USACE established Information Repositories for FUSRAP. These Information Repositories consist of either an Administrative Record or an Administrative Record File and have been established to offer the community access to site-related information. Information such as the documents used to select a cleanup method, documents regarding site activities, and general Superfund information are placed in the the Administrative Record or Administrative Record File. The information is available to the public so that they may make informed comments on the selection of a final site remedy. More information about the Administrative Record and/or Administrative Record Files is available online.

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Community Relations Plan

The USACE developed a Community Relations Plan (CRP) based on information gathered from discussions with members of the community of how they would like to be involved in the remediation of these sites. The Community Relations Plan provides a communication framework created to enhance public participation. Among other benefits, it enables public participation in the decision-making process to be conducted in as well informed a manner as possible. An electronic version of the Community Relations Plan is available online. (Please note that this document contains 358 pages of text and photos and may require extra time to download.) The USACE will review the Community Relations Plan each year and update it as needed to ensure it continues to address the concerns of the community.

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Newsletters

The USACE publishes a quarterly newsletter to inform the community of the status and progress of work at the St. Louis Sites. Upcoming events, public meetings, and recently released documents that are available for public review are also announced in the newsletter. Copies are forwarded to individuals on our mailing list, placed in local repositories and with the Administrative Record or Administrative Record File. Copies of our quarterly newsletters are also available online along with instructions for adding your name to our mailing list.

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Informational Products

The USACE develops informational products designed to summarize specific cleanup topics and activities, which may include fact sheets, brochures, or presentations. Posters, exhibits and photos are also utilized to provide easy-to-understand illustrations of cleanup activities. Many but not all of the fact sheets we have developed can be found on this website.

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Educational Outreach

Educational outreach activities have been designed for students of all ages. The USACE continues to offer to give presentations to groups, schools and associations. If you would like to hear from one of our experts in the field of management, engineering, geology, chemistry, physics, or industrial hygiene, please feel free to contact the St. Louis District, FUSRAP Project Office at (314) 260-3905.

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Public Meetings

Monthly meetings (open to interested citizens) provide the community opportunities to discuss environmental issues with USACE staff and/or technical experts. These meetings are held by the St. Louis Oversight Committee (developed from members of the St. Louis Site Task Force) at the FUSRAP Project Office on Latty Avenue in Berkeley, Missouri. Meeting dates and times are published in advance in the newsletter.

If you would like more information about how to become involved in the St. Louis FUSRAP sites' cleanup, please contact the FUSRAP Project Office during regular business hours at (314) 260-3905.

Site Location 

The St. Louis Airport Project Site (SLAPS) is a 21.7-acre property in St. Louis County, approximately 15 miles from downtown St. Louis. SLAPS is immediately north of the Lambert-St. Louis International Airport and is bounded by the Norfolk and Western Railroad and Banshee Road on the south, Coldwater Creek on the west, and McDonnell Boulevard and adjacent recreational fields on the north and east.

Land use adjacent to the property is varied. More than two-thirds of the land within a half mile of the property is used for transportation-related purposes (primarily the airport). Land adjacent to the property is generally used for transportation and commercial functions.  Because of its proximity to the airport, use of the property is limited due to height restrictions.

 

Site History

In 1946, the Manhattan Engineer District (MED) acquired the 21.7-acre tract of land now known as SLAPS to store residues from uranium processing at the Mallinckrodt facility in St. Louis.

The uranium processing, conducted under a contract with MED/AEC (Atomic Energy Commission), continued through 1957; the resulting radioactive residues accumulated at SLAPS. These materials included pitchblende raffinate residues, radium-bearing residues, barium sulfate cake, Colorado raffinate residues, and contaminated scrap. Some of the residues were stored in bulk on open ground. Others were stored in drums which were stacked across the site. Some contaminated materials and scrap iron were buried at the western end and in other parts of the property. To limit direct radiation exposure of the public, the property was fenced to prevent casual entry.

In 1966 and 1967, most of the stored residues were sold to a private entity for recycling and were removed from SLAPS. Onsite structures were razed, buried on the property, and covered with 1 to 3 feet of clean fill material. Although these activities reduced the surface dose rate to levels acceptable at the time, buried deposits of uranium-238, radium-226, and thorium-230 remained on the property.

In 1973, the tract was transferred from the AEC to the City of St. Louis by quitclaim deed. The 1984 Energy and Water Development Appropriations Act (Public Law 98-3060) authorized the DOE to reacquire the property from the city for use as a permanent disposal site for the wastes already on the property, contaminated soil in the surrounding ditches, and the waste from the nearby Hazelwood Interim Storage Site (HISS).

From 1976 through 1978, Oak Ridge National Lab (ORNL) conducted a radiological investigation of SLAPS. This survey indicated elevated concentrations of uranium-238 and radium-226 in drainage ditches north and south of McDonnell Boulevard. In 1981, the drainage ditches were designated for remedial action under FUSRAP. In October 1989, the EPA placed SLAPS on the National Priorities List (NPL), thus requiring the cleanup to proceed under the guidelines of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA).

In 1990, the St. Louis Board of Aldermen adopted a plan to transfer the SLAPS property to DOE. DOE had previously stated that the property would be used as a storage site for contaminated soil from the cleanup of the St. Louis Sites. After the site was placed on the NPL, DOE worked closely with EPA to determine how the site would be cleaned up and where the contaminated soil would be stored. In July 1990, DOE and EPA signed an agreement that established an environmental review process and schedule for the remediation of SLAPS and the other related St. Louis FUSRAP sites (i.e. SLDS), and the Latty Avenue properties). The process required DOE to evaluate alternatives for waste management, one of which was storage at SLAPS. DOE declined acceptance of the SLAPS property from the city until the environmental review process was conducted.

Until 1997, DOE was the lead agency responsible for the cleanup of SLAPS. In October 1997, Congress through the Energy and Water Development Appropriations Act transferred execution of FUSRAP from the DOE to the U.S. Army Corps of Engineers (USACE). Since that transition was effected, SLAPS has fallen under the responsibility of the St. Louis District USACE.  Upon completion of the execution (i.e. remediation) of FUSRAP at SLAPS, the responsibility for the long term management of the site will revert back to the DOE.

Site Progress

The U.S. Army Corps of Engineers (USACE) has accomplished a great deal at the St. Louis Airport Site (SLAPS) since the October 1997 transition of the program. Our primary goal for SLAPS is to restrict the release of contaminated materials and minimize their potential impact on human health, wildlife, and the environment. To accomplish this goal, the USACE invited the public to participate in setting the interim cleanup standards for the site.

In 1997, an EE/CA developed by the DOE proposed the removal of radioactive contaminated materials immediately adjacent to Coldwater Creek (CWC) at the West End of SLAPS next to the gabion wall and shipped to a licensed out-of-state disposal facility.  This action would minimize the potential for migration of contaminated material to CWC under current and anticipated site conditions as excavation of the site proceeded. Contaminated materials would be removed in accordance with DOE Order 5400.5 which specifies that the guideline for radionuclide concentrations for radium and thorium in soil is 5 picocuries per gram (pCi/g) above background in the top 15 cm (6 inches) of soil and 15 pCi/g above background in any subsequent 15 cm layer (below top 6 inches). The guideline concentration for uranium-238 (U-238) would be 50 pCi/g (surface and subsurface soils).  In October 1997 the execution of FUSRAP was transferred from DOE to USACE under the Energy and Water Appropriations Act. Initially, the USACE continued the removal of material under the authority of the DOE EE/CA document.  Completion of this removal action resulted in the disposal of 5,100 cubic yards of contaminated material, which were subsequently shipped by rail in covered gondola cars to an out-of-state licensed disposal facility.

Additionally, in 1997, the USACE conducted baseline ground-water characterization studies for the SLAPS. These studies involved the installation of ground-water monitoring wells; measurement of ground-water levels; and radiological and chemical analysis of ground-water samples.

In March 1998 USACE prepared an EE/CA proposing measures to stabilize SLAPS and the adjacent Ballfields until a comprehensive cleanup could be achieved.  Essentially the EE/CA called for the excavation of material exceeding radium-226(Ra-226) and thorium-230 (Th-230) at 5 pCi/g above background in the top 6 inches of soil (surface) averaged over 100 m² area; Ra-226 and Th-230at 15 pCi/g above background below the top 6 inches of soil (subsurface) averaged over 100 m² area; and U-238 at 50 pCi/g above background in the surface and subsurface of the soil with off-site disposal in a licensed facility.  The goal of the 1998 EE/CA was to give the USACE the authority to address the contaminated materials in these properties and prevent offsite migration. The second objective of the EE/CA was to restore these properties to beneficial use.

Under the authority of the 1998 EE/CA, USACE installed infrastructure to facilitate the future remediation of the site and took action to control surface water and off-site migration of contamination.  A 1,200-foot rail spur was constructed to allow for rapid shipment of contaminated material via rail.  A sedimentation basin was also constructed on the west end of the site (near Coldwater Creek). 

Once the infrastructure was in place and surface water runoff was under control, the USACE began excavating and shipping material from the site.  Initial efforts began at the upstream end of the site (i.e. often referred to as the “ East End”) and in the upstream segments of the drainage ditches along McDonnell Boulevard. The next priority was removal of an area referred to as the “Radium Pits”, which was believed to be the onsite location of the highest levels of contamination based on historical use.  Excavation/remediation under the authority of the EE/CA continued until 2005, when a Record of Decision was completed.

The Record of Decision (ROD) presented the Final Remedy for the site (as opposed to the EE/CA which presented an interim action.)  The ROD, which addressed not only the St. Louis Airport Site, but the Latty Avenue Site and the SLAPS Vicinity Properties Site as well, was the result of USACE investigations and CERCLA planning activities which had been occurring concurrent with the EE/CA removal action at SLAPS.  The USACE developed cleanup alternatives and presented them to the public for review in the Feasibility Study (FS) and Proposed Plan (PP) in May 2003. Comments on the documents were accepted through July 14, 2003. The public’s input was considered and a final ROD (Record of Decision for the North St. Louis County Sites, dated September 2, 2005) was issued in September 2005.  The final remedy consisted of excavation to achieve remediation goals:

-          top 6 inch layer averaged over any area 100 m²: 5 pCi/g Ra-226/14 pCi/g Th-230/50 pCi/g U-238 above background;

-          subsurface soil (below the top 6 inches) averaged over any area 100 m² and averaged over a 6-inch thick layer of soil: 15 pCi/g Ra-226/15 pCi/g Th-230/50 pCi/g U-238 above background;

-          Sediment below the mean water gradient will be removed if radionuclide concentrations averaged over any area of 100 m^2: 15 pCi/g Ra-226/43 pCi/g Th-230/150 pCi/g of U-238 above background.

-          All accessible contaminated soils/material will be disposed of off-site at a properly-  permitted facility.

The remainder of the SLAPS was remediated in accordance with the ROD.  More than 600,000 cubic yards of radiologically contaminated material was removed from the SLAPS over a 9-year period.  A formal closing ceremony took place on May 30, 2007.

A final Post Remedial Action Report/Final Status Survey Evaluation for the site was completed in May 2009.   

Current activities include site monitoring and maintenance of the rail spur which is still used to ship material excavated from the various SLAPS vicinity properties.  Upon completion of remediation of the SLAPS Vicinity Properties the rail spur will also be removed and the site (and associated files) will be turned over to the DOE for long term management.

Because of the extended time period for remediation, Five-Year Reviews have occurred in accordance with CERCLA and the NCP. Five-year reviews are conducted to ensure that human health and the environment are being protected by the response action being implemented. A team led by USACE and including representatives from EPA and Missouri Department of Natural Resources documented conditions at each site and the surrounding area. In addition, members of the community are contacted for their views about the cleanup process to date. Five-Year Review Reports have been issued in 2004 and 2010.

Site Location

The St. Louis Downtown Site (SLDS) is located in an industrial area on the eastern border of St. Louis, approximately 300 feet west of the Mississippi River.  The property is about 11 miles southeast of the St. Louis Airport Site and the Lambert-St. Louis International Airport.  The SLDS is comprised of approximately 210 acres of land, which includes Mallinckrodt Inc, (formerly Mallinckrodt Chemical Works) and 38 surrounding vicinity properties (VPs).  The former Mallinckrodt property comprises approximately 44.5 acres of land while the surrounding VPs comprise more than 165 acres of land.

Site History

From 1942 to 1957, under contracts with the Manhattan Engineer District (MED) and the Atomic Energy Commission (AEC), the site was used for processing various forms of uranium compounds, for machining and for recovery of uranium metal.  In 1946 the manufacture of uranium dioxide from pitchblende ore began at a newly constructed plant. The pitchblende ore was acquired from the African Metals Company.  Because this company retained ownership of the radium content of the ore, it was required that radium-226 and its daughter products be extracted along with the lead content.  The radium and lead were precipitated, and the precipitate was sent to the Lake Ontario Ordnance Works in Lewiston, New York and to the Feed Material Production Center in Fernald, Ohio for storage.

Decontamination was performed at two plants from 1948 through 1950.  In 1951, the plants were released to Mallinckrodt for use with no radiological restrictions.  From 1950 to 1951, an onsite plant was modified and subsequently used as a metallurgical pilot plant for uranium metal operation until it was closed in 1956.  This plant was released to Mallinckrodt in 1962 after decontamination work was conducted.

Mallinckrodt currently owns the buildings formerly used under the AEC contract. At the time of the MED/AEC operations, the plants were owned by Mallinckrodt and/or leased by AEC. Certain buildings in those plants were also constructed for and owned by AEC. From 1942 through 1945, uranium processing was conducted at Plants 1, 2, and 4. In 1945 operations at Plant 2 were terminated. Some uranium metallurgical research continued at Plant 4 through 1956. From 1945 to 1957, uranium concentrate or ore was processed in buildings at Destrehan Street (Plants 6, 6E, and 7). All uranium extraction operations at the Destrehan Street location ceased in 1957.

When the St. Louis MED/AEC operations were terminated, buildings owned by the government were either demolished or transferred to Mallinckrodt as part of the decommission. Several plants within the Mallinckrodt facility, containing about 60 buildings, were involved; fewer than 20 of these buildings remain. A number of new buildings have been constructed on the property; since 1962, they have been used for the commercial production of chemicals.

Until 1997, the U.S. Department of Energy (DOE) led the cleanup of the SLDS as part of its responsibility for the cleanup of FUSRAP sites. In October 1997, Congress through the Energy and Water Development Appropriations Act transferred FUSRAP from the DOE to the U. S. Army Corps of Engineers (USACE). Since that transition was effected, SLDS has fallen under the responsibility of the St. Louis District USACE.

Site Progress 1988 - 1998

Radiological characterization, which consisted of sampling and analyses to determine the nature and extent of contamination, was performed at SLDS in 1988 and 1989. Radiological characterization activities were conducted during 1990 on six properties adjacent to Mallinckrodt to determine whether contamination extended beyond the Mallinckrodt property boundaries.

The scope of interim removal actions at SLDS was outlined in an Engineering Evaluation/ Cost Analysis (EE/CA) prepared in 1991 by DOE. The EE/CA was reviewed by the public, and DOE prepared a responsiveness summary to address the comments received. Subsequently, limited removal action activities were undertaken at SLDS.

The purpose of these removal actions was to minimize human exposure to contaminated material and allow for consolidation of the impacted materials at temporary on-site storage areas.

Five interim actions were performed between 1995 and 1998:

1. In 1995, 15,043 cubic yards of contaminated soil were excavated from the Mallinckrodt Plant 10 (formerly Plant 4) area and shipped off-site for disposal at the Envirocare facility in Utah.

2. In 1996, 750 cubic yards of contaminated soil were excavated from the City Property, Riverfront Trail area, and shipped off-site for disposal at the Envirocare facility in Utah.

3. In 1996 the 50-series buildings from Plant 2 on the Mallinckrodt property were decontaminated and demolished. Contaminated materials were transported by covered gondola cars for disposal at the Envirocare facility in Utah. Brick and cinder blocks were crushed and piled on-site to await disposition.

4. In 1997 select buildings in Plants 6 and 7 were decontaminated and demolished. Again, contaminated materials were transported by covered gondola cars for disposal at the Envirocare facility in Utah. Brick and cinder blocks were crushed and piled on-site to await disposition.

5. In 1998 Building K was decontaminated by the government and demolished by Mallinckrodt. Contaminated materials were transported by covered gondola cars for disposal at the Envirocare facility in Utah.

Site Progress 1998 - Present

Since assuming responsibility for FUSRAP in 1997, USACE, St. Louis District has based its approach to cleaning up SLDS on data and findings contained within four key documents: the Baseline Risk Assessment, Initial Screening of Alternatives, the Remedial Investigation, and the Feasibility Study.  A Proposed Plan detailing USACE's preferred alternative was issued in April 1998.  The final cleanup remedy for accessible soils was outlined in the 1998 Record of Decision (ROD).

The 1998 SLDS ROD was published by USACE in consultation with the EPA and with concurrence from the Missouri Department of Natural Resources.  It defined remedial actions for accessible soil at the Mallinckrodt property and VPs.  The selected remedy for accessible soil was Alternative 6, Selective Excavation and Disposal.  Accessible soil is defined as soil that is not beneath buildings or other permanent structures.  Long term monitoring was required for ground water beneath the site as well as soils that are inaccessible as outlined in the 1998 SLDS ROD.

In March 2005, the Memorandum for Record: Non-Significant Change to the Record of Decision for the SLDS was published, which provided specific clarifications regarding the delineation of the SLDS boundary.  Additional VPs were determined to be impacted by MED/AEC wastes from the SLDS.  In addition, certain property boundaries and, in some cases, the associated property owners differed from those originally identified in the 1998 SLDS ROD.  The following specific areas were addressed:

 · Designated VPs by assigning property specific alphanumeric identification numbers

 · Modifying some VP boundaries due to changes in property boundaries after issuance of the 1998 SLDS ROD

 · Clarifying that contaminated soil under active rail lines on the three railroad properties is inaccessible.

 · Amending the SLDS boundaries to increase the geographical area/scope of the SLDS site to include additional areas to the north, south, and west of the site.

 · Adding the Terminal Railroad Soil Spoils Area, located south of the SLDS, to amended geographical area of the SLDS.

Before any actions are performed on a VP, a pre-design investigation (PDI) is performed. The PDI summarizes the existing/historical data, defines additional analytical data needs and determines if residual radiological contamination above the 1998 SLDS ROD remediation goals (RGs) are present on the property. Once the property has been sampled and completely characterized, a pre-design investigation report (PDIR) is prepared that documents the results of the PDI activities that were performed at the property.

If the data presented in the PDIR meets the 1998 SLDS ROD RGs, a final status survey evaluation (FSSE) is then performed.

A FSSE provides detailed information regarding:

 1. The survey process for soil and structures (including the design, methodology, and approach for area-weighted averaging);

 2. The assessment of survey results for soil and structures (including statistical tests and data quality);

 3. An assessment of residual risk and dose; and

 4. Conclusions

An FSSE is conducted (at the St. Louis FUSRAP Sites) to ensure that any residual radioactivity complies with the criteria specified in the 1998 SLDS ROD for protecting human health and the environment.

If a property meets the1998 SLDS ROD RGs during the PDI process, the property can be released.  As a result, the USACE prepares a PDIR/FSSE for that property.  

Several properties have been released under the PDIR/FSSE process:

 · 2002:  DT-1 formerly Archer Daniels and Midland and PVO Foods

 · 2006:  Mallinckrodt, Inc. Plants 3, 8, 9, and 11,  DT-20 Richey,  DT-21 Favre,  DT-22 Tobin Electric,  DT-23 InterChem,  DT-24 Bremen Bank,  DT-25 Eirten’s Parlors (OT Hodges),  DT-26 UAA Local 1887,  DT-27 Dillon,  DT-28 Challenge Enterprise,  DT-30 ZamZow Manufacturing,  DT- 32 Westerheide Tobacco Store

 · 2009:  DT-35 Factory Tire Outlet,  DT-36 OJM, Inc.

 · 2010:  DT-5 Ameren UE,  DT-13 Cash’s Scrap Metal,  DT-14 Cotto-Waxo Company,  DT-16 Star Bedding Company,  DT- 18 Curly Collins Recycling

 · 2012:  DT-15 City Properties (MSD Lift Station),  DT-34 Hjersted

 · 2013:  DT-37 Lange Stegmann

 When the PDI process determines that a property does not meet the 1998 SLDS ROD RGs, it must be remediated.  A remedial design/remedial action work plan (RD/RAWP) is prepared, and the property is then remediated.  The remediation is completed when the property meets the FSSE.

A post-remedial action Report (PRAR) document is prepared when remedial activities are completed on a property.  The PRAR documents the history, the site conditions and the response actions that occurred on a property.  The PRARs will be used collectively to provide supporting documentation for development of the Final Close-Out Report.

After Remedial Activities (RA) are completed and the property meets the 1998 SLDS ROD RGs, properties are released under a PRAR/FSSE.

USACE has conducted RA in accordance with the 1998 SLDS ROD to address MED/AEC contamination.  FSSEs for the accessible areas (in accordance with the 1998 ROD) have also been completed following RA for the following properties:

 · Mallinckrodt Plant 1

 · Mallinckrodt Plant 2

 · Mallinckrodt Plant 9

 · TRRA Soils Spoils Area

 · DT-3 Norfolk Southern Railroad

 · DT-4 Gunther Salt

 · DT-6 Heintz Steel and Manufacturing

 · DT-7 Midwest Waste

 · DT-8 PSC Metals

 · DT-10 Thomas and Proetz Lumber Company

 · DT-11 City of Venice Property (formerly McKinley Bridge)

 · DT-17 Christiana Court, LLC

 · DT-29 Midtown Garage

 Current RA at SLDS includes the following remediation:

 · DT-2 - City Property East of the Levee- Approximately 50% of the projected contaminated soil volume of 7500 bank cubic yards has been removed.  The RA of this area is currently scheduled for completion in 2016.

 · Mallinckrodt, Inc. Plant 6 West Half Building 101 Area – Mallinckrodt released Building 101 to USACE in March of 2011 for demolition and management of subsurface materials in accordance with the 1998 SLDS ROD.  Demolition of Building 101 was completed in October 2012 and excavation is currently underway.  Approximately 35% of the projected 46,000 bank cubic yards have been excavated.  Remedial Activities of the building footprint area is scheduled for completion in 2015

 · Kiesel Hall Street Property – RA at Kiesel Hall Street Property began in May of 2013. Approximately 3000 bank cubic yards of contaminated materials will be excavated.  RA in the area is scheduled for completion in January of 2014.

 Inaccessible Soils at SLDS

In September of 2012, the Remedial Investigation and Baseline Risk Assessment Report (RI/BRA) for the Inaccessible Soil Operable Unit (ISOU) at the St. Louis Downtown Site was published.  This document defines the nature and extent of MED/AEC soil contamination present in the ISOU at SLDS.  The document also assesses the associated risk to human health and the environment under the current and anticipated future land use for the SLDS.

On January 3, 2014 the USACE issued a Proposed Plan for the Inaccessible Soil Operable Unit Group 1 Properties at the SLDS.

USACE conducted a public hearing on January 30, 2014 to present and accept comments on this Proposed Plan. Public comments were accepted and incorporated into the Record of Decision (ROD) in the Responsiveness Summary. The ROD was published on September 29, 2014. A copy can be found in the Document section below.

Documents

Record of Decision for the Inaccessible Soil Operable Unit Associated with Group 1 Properties at the SLDS - Rev 0 9-29-2014

SLDS EMDAR CY13 Rev 0 7-23-2014

SLDS EMDAR rev 07-19-2013

SLDS EMDAR rev 07-13-2012

SLDS EMDAR rev 07-08-2011 - main text (172 pages)

SLDS Record of Decision - main text (90 pages)

SLDS Record of Decision - Appendix A, Detailed Responses to Comments (115 pages)

SLDS Proposed Plan (16 pages)

SLDS Feasibility Study (258 pages)

SLDS ISOU Proposed Plan for Group 1 Properties

SLDS ISOU-RI Final 09-20-2012 Part 1

SLDS ISOU-RI Final 09-20-2012 Part 2

SLDS ISOU-RI Final 09-20-2012 Part 3

SLDS ISOU-RI Final 09-20-2012 Part 4

SLDS ISOU-RI Final 09-20-2012 Part 5

SLDS ISOU-RI Final 09-20-2012 Part 6

Site Location 

The Latty Avenue Site (Latty) is located in northern St. Louis County within the city limits of Hazelwood and Berkeley, Missouri. HISS is located at 9170 Latty Avenue, approximately 3.2 miles northeast of the control tower of the Lambert-St. Louis International Airport and approximately a half mile northeast of SLAPS. Latty is comprised of 8 Vicinity Properties (VPs) as well as the Hazelwood Interim Storage Site (HISS) and Futura. Land use near the properties is primarily industrial; other uses are transportation-related, commercial, and residential. The residential areas nearest the property are approximately 0.3 mile to the east in Hazelwood. The residences in Berkeley are southeast of the site.

Site History

In early 1966, ore residues and uranium- and radium-bearing process wastes that had been stored at SLAPS were purchased by the Continental Mining and Milling Company and moved to a storage site on Latty Avenue. These wastes were generated at the Mallinckrodt plant in St. Louis from 1942 through the late 1950s under contracts with MED/AEC. Residues on the property at that time included 74,000 tons of Belgian Congo pitchblende raffinate containing approximately 13 tons of uranium; 32,500 tons of Colorado raffinate containing roughly 48 tons of uranium; and 8,700 tons of leached barium sulfate containing about 7 tons of uranium. The Commercial Discount Corporation of Chicago, Illinois, purchased the residues in January 1967. Much of the material was then dried and shipped to Canon City, Colorado. The material remaining at the Latty Avenue storage site was sold to Cotter Corporation in December 1969. From August through November 1970, Cotter Corporation dried some of the remaining residues and shipped them to its mill in Canon City. In December 1970, an estimated 10,000 tons of Colorado raffinate and 8,700 tons of leached barium sulfate remained at the Latty Avenue properties.

In April 1974, the Nuclear Regulatory Commission (NRC) was informed by Cotter Corporation that the remaining Colorado raffinate had been shipped in mid-1973 to Canon City without drying and that the leached barium sulfate had been diluted with 12 to18 inches of soil and transported to a landfill in St. Louis County.

Before the present owner occupied the property, Oak Ridge National Labs (ORNL) performed a radiological characterization. Thorium and radium contamination in excess of federal guidelines was found in and around the buildings and in the soil to depths of 18 inches. Subsequently, in preparing the property for use, the owner demolished one building, excavated portions of the western half of the property, paved certain areas, and erected several new buildings. Material excavated during these activities (approximately 13,000 cubic yards) was piled on the eastern portion of the property.

An additional 14,000 cubic yards of contaminated soil, from cleanup along Latty Avenue in 1984 and 1985 and from an area used for office trailers and a decontamination pad, was added to the pile. Approximately 4,600 cubic yards of contaminated soil was stored adjacent to the existing pile; the soil had been excavated during road and drainage improvements along Latty Avenue in support of a municipal storm sewer project. A total of approximately 32,000 cubic yards of contaminated soil is stored at the property.

In 1981, Oak Ridge Associated Universities conducted a radiological characterization of the pile and surveyed portions of the northern and eastern vicinity properties for radioactivity. Levels of contamination (principally thorium-230) similar to those on the pile were found in both areas. As a follow-up to this survey, ORNL conducted a detailed radiological survey of the northern and southern shoulders of Latty Avenue in January and February 1984; results indicated that contamination in excess of federal guidelines was present along the road beyond Hazelwood Avenue. Properties adjacent to HISS were also found to be contaminated in excess of guidelines.

A decontamination research and development project was conducted, under the authority of the 1984 Energy and Water Appropriations Act (Public Law 98-360), at various sites throughout the nation, including 9200 Latty Avenue and properties in its vicinity. Subsequently, Congress added the Latty Avenue properties to FUSRAP in order to expedite decontamination.

In October 1989, the Environmental Protection Agency (EPA) placed the HISS/FUTURA properties on the National Priorities List (NPL). This list required the cleanup to proceed under the guidelines of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) as amended by the Superfund Amendments and Reauthorization Act (SARA).

In July 1990, the Department of Energy (DOE) and EPA Region VII signed a Federal Facilities Agreement that established a procedure and schedule for remediation of the Latty Avenue properties.

 

In 1992, an Engineering Evaluation/Cost Analysis (EE/CA) – Environmental Assessment for the proposed decontamination of HISS and impacted soil from three adjacent Latty properties was released to the public.

 

In 1995, the EE/CA was approved with the modification that any soil excavated under the document be shipped to an out-of-state disposal facility.

In 1996, the owner of 9150 Latty Avenue, located to the east of HISS, expanded the facility and stockpiled about 8,000 cubic yards of contaminated soil. This stockpile, known as the Eastern Pile, is located on the southwestern corner of the property.

Until 1997, DOE was the lead agency responsible for the cleanup of the Latty Site. In October 1997, FUSRAP was transferred from the DOE to the U. S. Army Corps of Engineers (USACE) by Congress through the Energy and Water Development Appropriation Act. Since that transition was effected, Latty has fallen under the responsibility of the St. Louis District USACE. Cleanup activities continue to follow CERCLA guidelines and incorporate NCP values.

Site Progress 1998-2005

Since the transition of the program in Fiscal Year 1998 (FY98), the U.S. Army Corps of Engineers (USACE) has made significant progress at the Latty Site. The primary goal for Latty is to restrict the release of contaminated materials and minimize their potential impact on human health, wildlife, and the environment.

In 1999, USACE completed construction of the HISS/Latty Avenue rail spur, which is capable of holding 11 rail cars or 770 cubic yards of material. USACE also completed negotiations with an 8(a) woman-owned small business for a firm fixed-price contract to remove the two Eastern Piles. The USACE also renegotiated the St. Louis Utility Response Plan for all underground utilities affected by contamination from the MED/AEC in 1999.  The USACE trained and supported all affected utility companies. To protect human health and the environment, the USACE supports utility companies and other property improvements on properties potentially impacted by MED/AEC contamination.

In March 1998 USACE prepared an Engineer Evaluation/Cost Analysis (EE/CA) proposing to remove the HISS piles and impacted soil from three adjacent Latty Avenue properties until a comprehensive cleanup could be achieved. The proposal received public approval, and plans were developed to allow work to proceed. The USACE chose to expedite the removal of the HISS piles to protect human health and the environment.

 

The USACE started removal of the HISS piles in the spring 2000. Removal started with the East Piles 1 & 2 located at VP-2L adjacent to HISS. Work continued on the removal of the piles located on the HISS property. Contaminated materials from the Spoil Piles A & B; Supplemental Pile and then the Main Pile were removed. Removal of the HISS piles was completed in the fall 2001. Over 52,000 cubic yards of contaminated material was removed and transported by covered gondola cars for disposal at an out-of-state licensed or properly permitted facility.

The Record of Decision (ROD) presented the Final Remedy for the site (as opposed to the EE/CA which presented an interim action.)  The ROD, which addressed not only the St. Louis Airport Site, but the Latty Avenue Site and the SLAPS Vicinity Properties Site as well, was the result of USACE investigations and CERCLA planning activities which had been occurring concurrent with the EE/CA removal action at SLAPS.  The USACE developed cleanup alternatives and presented them to the public for review in the Feasibility Study (FS) and Proposed Plan (PP) in May 2003. Comments on the documents were accepted through July 14, 2003. The public’s input was considered and a final ROD (Record of Decision for the North St. Louis County Sites, dated September 2, 2005) was issued in September 2005.  The final remedy consisted of excavation to achieve remediation goals:

-          top 6 inch layer averaged over any area 100 m²: 5 pCi/g Ra-226/14 pCi/g Th-230/50 pCi/g U-238 above background;

-          subsurface soil (below the top 6 inches) averaged over any area 100 m² and averaged over a 6-inch thick layer of soil: 15 pCi/g Ra-226/15 pCi/g Th-230/50 pCi/g U-238 above background;

-          Sediment below the mean water gradient will be removed if radionuclide concentrations averaged over any area of 100 m^2: 15 pCi/g Ra-226/43 pCi/g Th-230/150 pCi/g of U-238 above background.

-          All accessible contaminated soils/material will be disposed of off-site at a properly-  permitted facility.

 

Site Progress 2005 – Present

Before any actions are performed on a FUSRAP property, a pre-design investigation (PDI) is performed. The PDI summarizes the existing/historical data, defines additional analytical data needs and determines if residual radiological contamination above the ROD remediation goals (RGs) are present on the property. Once the property has been sampled and completely characterized, a pre-design investigation report (PDIR) is prepared that documents the results of the PDI activities that were performed at the property.

 

If the data presented in the PDIR meets ROD RGs, a final status survey evaluation (FSSE) is then performed. 

 

A final status survey evaluation (FSSE) provides detailed information regarding:

(1) the survey process for soil and structures (including the design, methodology, and approach for area-weighted averaging);

(2) the assessment of survey results for soil and structures (including statistical tests and data quality);

(3) an assessment of residual risk and dose; and

(4) conclusions

 

An FSSE is conducted (at the St. Louis FUSRAP Sites) to ensure that any residual radioactivity complies with the criteria specified in the ROD (USACE 2005) for protecting human health and the environment.

 

If a property meets the ROD RGs during the PDIR/FSSE process the property can be released. The USACE then prepares a PDIR/FSSE for that property.

The data in a PDIR can also demonstrate that the property does not meet ROD RGs and must be remediated. A remedial design/remedial action work plan (RD/RAWP) is prepared to remediate the property. The remediation is completed when the property meets the FSSE.

 

A post-remedial action report (PRAR) document is prepared when remedial activities are completed on a property.  The PRAR documents the history, the site conditions and the response actions that occurred on a property. The collection of individual PRARs for each portions of the site will be used as the supporting documentation for development of the Final Close-Out Report.

 

After remedial activities are completed and the property meets the ROD RGs, properties are released under a PRAR/FSSE.

2010

In 2010, the USACE released the PRAR/FSSE for the following properties:

·         Parcel 10K530087 (9205 Latty Ave. Hazelwood, MO)

·         VP 1L (9151 Latty Ave. Berkeley, MO) (Excluding building interior. Interior remedial activities completed in 2013).

 

2012

In 2012, the USACE release the PRAR/FSSE for the following properties:

·         VP-2L (9150 Latty Ave. Berkeley, MO)

·         VP 3L (9060 Latty Ave. Berkeley, MO)

·         VP 4L (8966 Latty Ave. Berkeley, MO)

·         VP 5L (8942 Latty Ave. Berkeley, MO)

·         VP 6L (8999 Seeger Industrial Dr. Berkeley, MO)

 

Ongoing Activities

·         VP 1L – Currently performing remedial activities in the interior of the main building. Anticipated completion is in 2013.

Site Location

The SLAPS VPs are located in the cities of Hazelwood and Berkeley, Missouri. These properties (totaling approximately 80 vicinity properties) include Coldwater Creek and its vicinity properties to the west; adjacent ball fields to the north and east; Norfolk and Western Railroad properties adjacent to Coldwater Creek; Banshee Road to the south; ditches to the north and south; and St. Louis Airport Authority property to the south. Also included are the transportation routes (haul roads) at the following locations: Latty Avenue, McDonnell Boulevard, Pershall Road, Hazelwood Avenue, Eva Avenue, Frost Avenue, and other miscellaneous vicinity properties.

Site History 

Low-level radioactive contamination at the SLAPS VPs is linked to both the St. Louis Airport Site and the Latty Avenue Properties. In 1966, Continental Mining and Milling Company of Chicago purchased uranium-bearing residues from the Manhattan Engineer District (MED) and removed them from SLAPS. The company placed the residues in storage at Latty Avenue under an Atomic Energy Commission (AEC) license. Over time, residues migrated from other sites or were deposited as the residues were hauled along transportation routes, contaminating the soils and sediments of the vicinity properties. In 1996 the volume of impacted soils, which are owned by commercial enterprises, private residences, or local governments, was estimated at 195,000 cubic yards. Of the over 80 properties comprising the St. Louis Airport Site Vicinity Properties (SLAPS VPs), cleanup activities have been completed or substantially completed on nearly half of the properties.

Site Progress

An EE/CA-Environmental Assessment for the proposed decontamination of properties in the vicinity of HISS was released to the public in spring 1992. In 1995 the EE/CA was approved with the modification that any soil excavated under the document be shipped to an out-of-state disposal facility. Between 1995 and 1997 the Department of Energy (DOE) worked to remove contaminated soil from the road frontages of 30 VPs along Frost, Hazelwood, and Latty Avenues. In October 1997 FUSRAP was transferred from DOE to USACE under the Energy and Water Appropriations Act. Cleanup activities continue to follow CERCLA guidelines and incorporate NCP values. Other removal actions and environmental documentation undertaken since the approval of the EE/CA include:

1. In 1998 USACE removed and backfilled 450 cubic yards of contaminated soil and concrete in support of the city of Florissant's upgrade of the St. Denis Bridge over Coldwater Creek.

2. In 1999, 550 cubic yards of contaminated soil were removed from VP-56. USACE also renegotiated the St. Louis Utility Response Plan for all underground utilities affected by contamination from the MED/AEC. USACE trained and supported all affected utility companies.

3. In March 2000, excavation of contaminated materials from a portion of SLAPS VP-38 on SuperValu, Inc. property commenced pursuant to the 1992 EE/CA developed by DOE. Approximately 5,000 cubic yards of radioactively contaminated materials were excavated and transported out-of-state for disposal at a permitted and licensed facility in Idaho. Analysis indicated that the entire floor of the excavated area met the cleanup and release criteria. However, only the west and northwest walls of the excavated area met these criteria. Residual soil concentrations in the other walls were determined to be in excess of the removal action goals and, as a result, these walls were not released. Areas of the walls that were not released were covered with geotextile material. Placement of clean backfill in the excavated area and against the geotextile material was completed in June 2000. Currently, the USACE field project office complex and on-site laboratory facility are located on the remediated portion of VP-38.

4. In July 2000 the FUSRAP Project Offices were relocated from 9170 Latty Avenue to 8945 Latty Avenue to provide more operating room for heavy construction equipment removing the nearby HISS piles.

USACE's primary goals for the SLAPS VP's are to restrict the release of contaminated materials and minimize potential impacts to human health, wildlife, and the environment. Its secondary goal is to restore the SLAPS VPs for potential reuse.

In August 2002 USACE offered a two-day training session to members of the public to familiarize people with technical processes and terms used to accomplish FUSRAP work. The training, targeted at SLAPS VP owners, was limited to general information and did not identify or discuss final cleanup alternatives that were still under development at the time. About 50 people from widely varied backgrounds attended the training session.

In 2002 USACE supported a property owner's plans to construct a warehouse on the western portion of VP-27. Surveys detected a small area of contamination consisting of 124 cubic yards of contaminated soil, which were subsequently removed from the property. Contaminated materials were transported by covered gondola cars for disposal at an out-of-state licensed or properly permitted facility.

In accordance with CERCLA requirements, a five-year review was initiated in January 2003 to ensure that human health and the environment are being protected by the response action being implemented. A team led by USACE and including representatives from EPA and MDNR documented conditions at each site and the surrounding area. In addition, members of the community were contacted for their views about the cleanup process to date. USACE released the draft report documenting the findings of the review in September 2003.

In early 2003 USACE collected samples from SLAPS, SLAPS VPs, HISS/Latty Avenue VPs, Futura, and Coldwater Creek. USACE chose to develop cleanup alternatives to address all of these sites. Accordingly, USACE conducted a Baseline Ecological Risk Assessment on Coldwater Creek. Cleanup alternatives for the North St. Louis County sites, identified in the FS and PP, were released for public review in May 2003. Comments on the documents were accepted through July 14, 2003. The final cleanup remedy is outlined in the Record of Decision for the North St. Louis County, Missouri Sites (SLAPS, HISS/Latty Avenue, and SLAPS VPs).

·         September 2005, the North County Record of Decision (ROD) was signed. Previous to ROD all work was conducted under the EE/CA and Action Memorandum (USACE 1999) was removal actions. Work conducted under the NC ROD (USACE 2005) is a remedial action.

The Record of Decision (ROD) presented the Final Remedy for the site (as opposed to the EE/CA which presented an interim action.)  The ROD, which addressed not only the St. Louis Airport Site, but the Latty Avenue Site and the SLAPS Vicinity Properties Site as well, was the result of USACE investigations and CERCLA planning activities which had been occurring concurrent with the EE/CA removal action at SLAPS.  The USACE developed cleanup alternatives and presented them to the public for review in the Feasibility Study (FS) and Proposed Plan (PP) in May 2003. Comments on the documents were accepted through July 14, 2003. The public’s input was considered and a final ROD (Record of Decision for the North St. Louis County Sites, dated September 2, 2005) was issued in September 2005.  The final remedy consisted of excavation to achieve remediation goals:

-          top 6 inch layer averaged over any area 100 m²: 5 pCi/g Ra-226/14 pCi/g Th-230/50 pCi/g U-238 above background;

-          subsurface soil (below the top 6 inches) averaged over any area 100 m² and averaged over a 6-inch thick layer of soil: 15 pCi/g Ra-226/15 pCi/g Th-230/50 pCi/g U-238 above background;

-          Sediment below the mean water gradient will be removed if radionuclide concentrations averaged over any area of 100 m^2: 15 pCi/g Ra-226/43 pCi/g Th-230/150 pCi/g of U-238 above background.

-          All accessible contaminated soils/material will be disposed of off-site at a properly-  permitted facility.

 

Site Progress 2005 – Present

Before any actions are performed on a FUSRAP property, a pre-design investigation (PDI) is performed. The PDI summarizes the existing/historical data, defines additional analytical data needs and determines if residual radiological contamination above the ROD remediation goals (RGs) are present on the property. Once the property has been sampled and completely characterized, a pre-design investigation report (PDIR) is prepared that documents the results of the PDI activities that were performed at the property.

 

If the data presented in the PDIR meets ROD RGs, a final status survey evaluation (FSSE) is then performed.  

A final status survey evaluation (FSSE) provides detailed information regarding:

(1) the survey process for soil and structures (including the design, methodology, and approach for area-weighted averaging);

(2) the assessment of survey results for soil and structures (including statistical tests and data quality);

(3) an assessment of residual risk and dose; and

(4) conclusions

 

An FSSE is conducted (at the St. Louis FUSRAP Sites) to ensure that any residual radioactivity complies with the criteria specified in the ROD (USACE 2005) for protecting human health and the environment.

If a property meets the ROD RGs during the PDIR/FSSE process the property can be released. The USACE prepares a PDIR/FSSE for that property.  

 

Several Vicinity Properties or VP's have been released under the PDIR/FSSE process.

·         2008 -  VPs 21, 22, 23, 24, 26, 28, 29, 30 and 31 (Frost Ave)

·         2009 -  VPs 17, 18, 19, 20, 20A and 25 (southwest Frost Ave)

·         2009 – VPs 41, 43, 44, 45, 46, 48, 49, 50, 51 and 52 (northeast Hazelwood Ave)

·         2010 -   VPs 33, 34 and 37 (Hazelwood Ave)

·         2011 -  VPs 3 and 4 (McDonnell Blvd)

The data in PDIR can also demonstrate that the property does not meet ROD RGs and must be remediated. A remedial design/remedial action work plan (RD/RAWP) is prepared to remediate the property. The remediation is completed when the property meets the FSSE.

 

A post-remedial action plan (PRAR) document is prepared when remedial activities are completed on a property.  The PRAR documents the history, the site conditions and the response actions that occurred on a property. The collection of individual PRARs for each portions of the site will be used as the supporting documentation for development of the Final Close-Out Report.

After remedial activities are completed and the property meets the ROD RGs, properties are released under a PRAR/FSSE.

 

2006 

VP 27 – (Frost Ave & Romiss Court) This VP was previously remediated in 2002 under a utility support. (See previous description.)

 

2010

The City of Hazelwood notified the USACE regarding road improvements and widening Hazelwood Avenue from Frost Avenue to Pershall Road. The USACE decided to start remediation activities along Hazelwood Avenue and the adjacent vicinity properties before the City of Hazelwood began the road improvement project.

 

Hazelwood Avenue was used as a haul route transporting uranium-bearing residuals from the St. Louis Airport Site on McDonnell Boulevard Avenue. Contamination along Hazelwood Avenue and the adjacent right-of-ways (ROWs) and VPs occurred as a result of soil spillage from transport vehicles. As a result of characterization sampling and investigations along Hazelwood Avenue, twelve areas required remediation to estimated depths ranging from 1 to 3 feet below ground surface. A total of 1,000 cubic yards was excavated from the VPS, the ROWs and Hazelwood Ave and shipped to a licensed out-of-state disposal facility.

In 2010, the USAEC issued the PRAR/FSSE to release Hazelwood Avenue, the ROWs and

VPs 32, 35, 35A, 36, 39, 40, 42 and 47.

 

2011

In 2011, the USACE released the PRAR/FSSE for the following properties:

(Disposal of contaminated material is shipped to a licensed out-of-state disposal facility.)

·         VPs 5 & 6 (McDonnell Blvd) – 42 cubic yards excavated

·         VPs 8 & 9 (McDonnell Blvd) – 252 cubic yards excavated

·         VP 53 – (Pershall Road) - 104 cubic yards removed

·         VP 54 – (Pershall Road) – 65 cubic yards removed

·         VP 55 –  (Pershall Road) – 228 cubic yards removed

·         VP 63 - (Lindbergh Blvd, the old Ford Plant) – 70 cubic yards removed

 

2012 – 2013 Remedial Activities

Presently remedial activities are ongoing at:

·       IA-9 (Ballfields) - The Ballfields area consists of approximately 60 acres in Berkely, MO. The property is located north of Lambert-St. Louis International Airport and bounded to the north by McDonnell Boulevard, to the east by Eva Avenue, to the north by Frost Avenue and to the west by Coldwater Creek. Historically, the property was used for agricultural land and a baseball field complex and was also a part of the former Brown Road. Contamination of the Ballfields occurred when residues migrated from SLAPS via runoff onto adjacent properties through Coldwater Creek or was windblown, released, or otherwise deposited when material was transported along haul routes. The northern portion of the Ballfields is currently used by the City of Berkeley as a shooting range; the remainder of the property is not in use. The remediation of the Ballfields will be completed in three phases. Phase 1 includes the east portion of the Ballfields area along Eva Avenue; IA-08 North Ditch (east portion); IA-09 North Ditch (east portion) and Eva Road. This area is situated on the east side of the area drainage divide and comprises approximately 25 acres. The USACE completed Phase 1 in 2012 and removed 11,085 cubic yards of contaminated material from Phase 1. Remediation in Phase 2 (17 acres) is ongoing. Phase 2 includes the ballfields central portion; IA-08 North Ditch central portion; IA-09 North Ditch central portion; and ballfields: north of IA-09 western portion. The USACE is preparing the Phase 2B remedial design plan to remediate 11 acres directly adjacent to the west side of the initial Phase 2. Phase 2B consists of Investigation Area (IA)-09: Ballfields (western portion); IA-08: North Ditch (western portion) and IA-09: North Ditch (western portion).

·         VP-16/Eva Loadout (McDonnell and Eva Road) – remedial activities are ongoing and almost completed.

·         IA-10 –The USAC is completing the characterization of IA-10, the area north of the ballfields adjacent to CWC. Additional samples are needed to identify areas that need additional remediation.  A part of IA-10 adjacent to McDonnell Blvd and CWC was remediated in 2011, a total of 2,939 cubic yards were removed.

 

COLDWATER CREEK

 

Coldwater Creek (CWC) is a SLAPS VPS.  CWC flows adjacent to the SLAPS and the Hazelwood Interim Storage Site (HISS) and Futura sites through the communities of Berkeley, Hazelwood, Florissant, Black Jack and Spanish Lake to where it empties into the Missouri River. 

 

Coldwater Creek has been divided into four reaches. Reach A extends from SLAPS to Pershall Road; Reach B from Pershall Road to Bruce Drive; Reach C from Bruce Drive to Old Halls Ferry Road; and Reach D from Old Halls Ferry Road to the Missouri River. The Creek also consists of several tributaries.

 

History

Potential radiological contamination in CWC can be attributed to the prior storage of uranium processing residues and wastes at SLAPS and subsequently at HISS. These wastes resulted from the uranium ore processing activities at Mallinckrodt in the 1940s and 50s. The potential movement of contamination into the creek would have occurred by wind and water. The wastes consist of low-level radioactive contamination co-mingled with metals from the uranium processing activities.

 

Project Description

The approach to CWC is to first eliminate the sources of contamination. The USACE completed the remediation of SLAPs (2007) and HISS/Futura (2012). The USACE is currently remediating properties adjacent to CWC from upstream to downstream.

 

Past Action

In 1998, the U.S. Army Corps of Engineers (USACE) removed contamination from the creek to support the City of Florissant’s upgrade of the St. Denis Bridge over CWC. In 2005, contamination in CWC was removed as part of the clean up at the SLAPS. The USACE removed contamination from a tributary to CWC during remediation activities at HISS/Futura. 

 

Monitoring

In 1998, the USACE developed a plan to monitor the water and sediments of CWC in Reach A. Six locations along CWC are sampled twice a year to ensure the creek is not contaminated during remedial actions at adjacent properties.

 

Recent and Future Sampling Events

Several sampling events have taken place in CWC by DOE and the USACE. However several data gaps still exist. As part of the plan to work from upstream to downstream, USACE is developing sampling plans for the creek. The purpose of the sampling is to confirm that the Creek meets ROD cleanup requirements or to identify/quantify any material requiring removal in order to meet these requirements. If remediation is required, the sediment/soil will be removed and shipped to an offsite permitted disposal facility in accordance with the North County ROD.

·         In 2012-2013, the USACE initiated characterizing/sampling of CWC from Mc Donnell Blvd. to Frost Avenue. Sampling was completed in March 2013 but additional sampling is needed to bound areas of that may need remediation.

 

·         The USACE is currently developing a sampling plan to sample CWC from Frost Ave. to the St. Denis Bridge. The USACE anticipates sampling of this section of CWC to begin in late summer or fall 2013. It is anticipated that sampling this stretch of CWC may take at least 12 months.

·         A future sampling plan will characterize CWC from the St. Denis Bridge to the Missouri River.

 

Documents

Pre-Design Investigation Work Plan for Coldwater Creek from Frost Ave to St. Denis Bridge Rev 0

Pre-Design Investigation Report for Coldwater Creek McDonnell Blvd to Frost Ave Rev 0

Pre-Design Investigation Summary Report for Coldwater Creek from McDonnell Boulevard to Frost Avenue Rev 0

 

Site Location

The Madison Site is located within an active industrial site across the Mississippi River from SLDS in Illinois. The site is located at College and Weaver Streets in Madison. It consists of two buildings owned by a component manufacturer in Madison, Illinois.

Site History

The Madison Site was part of an operating facility formerly known as Dow Chemical Company, a division of Dow Metal Products. The firm worked with Mallinckrodt Chemical to support Atomic Energy Commission needs during the late 1950s and early 1960s. A uranium extrusion and rod-straightening facility was operated at the site. A 1989 survey indicated Building 6 contained low-level radioactive contamination in dust located on overhead surfaces. About two cubic yards of contaminated uranium/thorium dust exceeding guidelines was identified from MED/ AEC operations on roof beams at the facility. In 1992, the Madison Site was added to the FUSRAP list of sites slated for cleanup. The FUSRAP site is located within a limited area of an active facility. The plant is in heavy production use, extruding aluminum and magnesium metal. As cleanup is ultimately necessary, the operator is working with USACE to identify an available time frame for cleanup. It is the intent of the facility owner and USACE that production operations will not be disrupted during cleanup, and that the safety of maintenance and production personnel continues to be protected.

Site Progress

With a $500,000 budget for Fiscal Year (FY) 1999, the U. S. Army Corps of Engineers (USACE) developed a Characterization Report for the Madison Site. Samples were taken to validate existing site data, define site contamination and update the risk associated with it. The Characterization Report confirmed the presence of contamination associated with MED/AEC activities in dust on overhead surfaces in two buildings, while the floors and equipment were below criteria.

In February 2000, four remedial alternatives were identified to address the contamination on overhead surfaces at the Madison Site. These alternatives were presented to the public for review and comment in a Remedial Investigation / Feasibility Study (RI / FS) and Proposed Plan. Based on the comments received from the general public and regulatory agencies, the USACE selected "Decontamination of Accessible Surfaces" (Alternative 4) as the final remedy for the site.

The Madison Site Record of Decision (ROD) outlined the final cleanup method selected to address contamination at the site. Comments received from the public on the Feasibility Study and the USACE's responses to those comments were incorporated into a section of the the Madison Site ROD title the Responsiveness Summary. Upon approval of the Madison Site ROD, the USACE began decontamination activities in June 2000.

Uranium-contaminated dust was vacuumed from overhead structrues over a 12-day period. By mid-July, independent surveys confirmed that the USACE had successfully decontaminated the Madison Site. Forty cubic yards of contaminated dust and materials were sent to a licensed, out-of-state facility for disposal.

The current condition of the site is documented in the approved Final Madison Site Post Remedial Action Report dated September 2000. This report provides an overall summary of remedial actions conducted at the site, assesses their effectiveness in meeting the criteria established in the Madison Site Record of Decision (ROD) dated April 2000, and serves as the closure report for the site. The FUSRAP remediation of AEC materials at the Madison Site achieved unrestricted release. However, it is important to note that the site is currently operating under a separate Illinois Department of Nuclear Safety (IDNS) licensed process that is not related to the AEC. While the remediation of AEC contamination achieved radiological criteria for unrestricted use, non-AEC portions of the facility will need to meet the criteria for license termination in the future.The approved Declaration of Remedial Action Completion Statement, the Final Madison Site Post Remedial Action Report and other supporting information have been placed with the site Administrative Record, which may be viewed during regular business hours at the U. S. Army Corps of Engineers, FUSRAP Project Office in Berkeley, Missouri and/or at the Madison Public Library in Madison, Illinois. it will be removed from the list of active FUSRAP sites.

Fiscal Year 2002 (FY02) Goals

In FY02, Madison was removed from the list of active FUSRAP sites. In accordance with the terms of the Memorandum of Understanding (MOU) between the USACE and Department of Energy (DOE), site stewardship consisting of records management was transferred to the DOE. Information regarding this site may now be obtained from the DOE's Office of Long-term Stewardship.