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More about FUSRAP

Protect human health and the environment.

Execute the approved alternative for cleaning up the radioactive contamination above health-based cleanup guidelines.

Minimize adverse impacts on residents and area business operations.

Return sites for appropriate beneficial use.

U.S. Army Corps of Engineers
St. Louis District 
FUSRAP Project Office
8945 Latty Ave.
Berkeley, MO 63134-1024

314-260-3905

STLFUSRAP@usace.army.mil 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

FUSRAP

The Formerly Utilized Sites Remedial Action Program has the mission of protecting public health and the environment by removing low-level radioactive contamination generated by activities of the Manhattan Engineer District and the Atomic Energy Commission (MED/AEC) during the development of atomic weapons in the 1940s and 1950s.


Helpful background information for understanding the low-level radiological cleanup process is available through the "Background" section.

For information about the progress of cleanup at these sites, click the "Newsletters" link.

 


Background

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 the development of atomic weapons in the 1940s and 1950s.

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 Lambert-St. Louis Airport (known since February 2017 as St. Louis Lambert International 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, Latty Avenue Properties 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 1950s. (See Chronology for more information.)

The 1998 Energy and Water Appropriations Bill, through 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 Oct. 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 aren’t exposed to them for long periods of time.

Although these materials don’t 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 remedy. 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).

1930s 1939

World War II begins when Hitler invades Poland Sept. 1, 1939.

1940s

1941

The United States declares war on Japan and Germany Dec. 8.

1942

The Manhattan Engineering District (MED) achieves the first self-sustained nuclear chain reaction at Stagg Field at the University of Chicago using uranium oxide produced by the Destrehan Street Refinery and Metal Plant (later Mallinckrodt Chemical Works).

Following the success of the Stagg Field experiment, the MED contracts with Mallinckrodt to process uranium. Under this contract, uranium and radium are extracted from ore and used to make the first atomic bombs. Years later, this facility will become known as the St. Louis Downtown Site (SLDS).

1945

The first atomic bomb is tested at White Sands Test Range in Alamogordo, New Mexico. On Aug. 6 and 9, atomic bombs are detonated at Hiroshima and Nagasaki, leading to Japanese surrender in September. World War II officially ends.

1946

MED acquires land from the City of St. Louis and obtains consent to store process byproducts containing radioactive residuals from the Mallinckrodt plant. Most of the wastes and residues are stored on open ground. Some contaminated materials and scrap are buried at the western end and other parts of the site. Later, this land becomes known as the St. Louis Airport Site (SLAPS).

Congress passes the Atomic Energy Act in September, which creates the five-member Atomic Energy Commission (AEC) to manage the atomic energy program. On Dec. 31, the Manhattan Engineering District is inactivated. The newly created AEC assumes the Manhattan Engineering District's responsibilities.

1948

With AEC financing, Mallinckrodt begins to decontaminate Plants 1 and 2.

1950s

1951

The AEC releases the Mallinckrodt Plants 1 and 2 for use without radiological restrictions.

1957

AEC operations downtown close. From 1942 to 1957, the plant had processed more than 50,000 tons of uranium product. Contaminated scrap metal and miscellaneous radioactive wastes are transported to SLAPS and buried on the western edge of the property.

1960s 1960

AEC offers uranium processing residues and wastes at SLAPS for sale.

1965

In a waste inventory and radiological survey conducted at SLAPS, the AEC finds approximately 121,000 tons of uranium refinery residues and contaminated material.

1966

In February, Continental Mining and Milling Co. purchases wastes stored at SLAPS and begins moving them to 9200 Latty Ave. in Berkeley, Missouri. Improper storage, handling and transportation of materials causes the spread of these materials along haul routes to Vicinity Properties (SLAPS VPs). The Latty Avenue property, where the wastes from SLAPS were stored, will later became known as the Hazelwood Interim Storage Site (HISS).

After removal of most residuals to HISS, structures on SLAPS are demolished and buried on the property. Sixty truckloads of scrap metal and a contaminated vehicle are buried on the property. One to three feet of clean fill material are spread over SLAPS to achieve acceptable levels of surface radioactivity.

1967

Commercial Discount Corporation purchases the residues stored on HISS and after drying, ships much of the material to Canon City, Colorado.

1969

Cotter Corporation purchases the remaining residues at HISS, dries it and ships additional material to Canon City during 1970.

1970s 1970

The Environmental Protection Agency is formed.

1973

The AEC conveys the SLAPS property by quitclaim deed to the St. Louis Airport Authority.

Cotter concludes its shipping operation at HISS. The remaining contaminated material (barium sulfate) is mixed with approximately five times as much topsoil "to disperse and dilute the uranium bearing residues" and disposed of in a St. Louis County landfill.

1974

AEC established the Formerly Utilized Sites Remedial Action Program (FUSRAP) for the cleanup of sites not owned by the Department of Energy but contaminated from past activities involving radioactive materials. The SLDS, SLAPS, SLAPS VPs and HISS sites are eventually placed in FUSRAP.

In a reorganization of the state government, the Missouri Department of Natural Resources (MDNR) is formed.

1975

The Atomic Energy Commission is replaced by two new federal agencies. One is the Nuclear Regulatory Commission (NRC), which is charged with regulating the civilian uses of atomic energy (mainly nuclear power plants). The other is the Energy Research and Development Administration (ERDA), whose duties include the control of the nuclear weapons complex.

1976

The Nuclear Regulatory Commission (NRC) conducts a radiological survey of HISS and determined the residual uranium concentrations, thorium concentrations and gamma exposure levels exceeded guidelines for release of the property without radiological restrictions.

From 1976 until 1978, radiological investigations of SLAPS and Latty Avenue are performed. Contamination is found at both sites, along with elevated radionuclide concentrations on site and north of the site in ditches along McDonnell Boulevard. The ditches are designated for remedial action under the FUSRAP program.

1977

ERDA is transferred to the newly created Department of Energy (DOE).

The buildings and grounds at 9200 Latty Ave. are purchased by the current owner and leased to a manufacturing facility. A follow-up radiological characterization of HISS is conducted prior to occupancy. This survey disclosed uranium, thorium and radium in and around the building and subsurface.

1979

During a cleanup performed by the new owner under NRC guidance,13,000 cubic yards of material are excavated from the western half of the 9200 Latty Ave. and stockpiled on the eastern to form the main storage pile at HISS.

1980s

1981

SLAPS is designated for remedial action under FUSRAP.

A radiological characterization of the pile and portions of the northern and eastern vicinity properties for HISS is performed. Levels of contamination similar to those on the pile are found in both areas.

1982

DOE performs a radiological characterization of the ditches to the north and south of SLAPS and of portions of Coldwater Creek. The characterization sampling effort indicates radioactive levels exceed DOE guidelines then in effect.

1984

As a follow-up to the 1981 HISS/Latty Avenue survey, a detailed radiological survey of the northern and southern shoulders of Latty Avenue is conducted. Results indicate that contamination in excess of federal guidelines is present along the road beyond Hazelwood Avenue. Properties adjacent to HISS are also found to be contaminated in excess of guidelines.

The Energy and Water Development Appropriations Act directs DOE to conduct a decontamination research and development project at four sites throughout the nation, one of which is HISS. Results of the survey demonstrate that the property exceeds guidelines for residual radioactive material given in DOE Order 5400.5. Subsequently, Congress adds HISS to FUSRAP in order to expedite decontamination.

DOE is directed by Congress to reacquire SLAPS (Public Law 98-360) and use it as a permanent disposal site for waste already on the property, contaminated soil in the surrounding ditches and the waste from HISS. The City of St. Louis refuses to transfer the property to the DOE.

The DOE begins clearing the property at 9200 Latty Ave. and selected adjacent properties; constructing a vehicle-decontamination facility, installing a perimeter fence at HISS, excavating and backfilling the edges and shoulders of Latty Avenue, and consolidating and covering the contaminated soil storage pile. These activities resulted in adding 14,000 cubic yards of contaminated soils to the 13,000 cubic yards of material already in the storage pile.

1985

Erosion on the western side of SLAPS along Coldwater Creek necessitates emergency maintenance. Sloughing and seepage are causing erosion of contaminated fill and loess (soil) materials into the creek. The problem is temporarily corrected by installing a gabion wall (constructed of rock-filled wire baskets) along the western edge of the property.

DOE performs a radiological survey of the roads thought to have been used to transport contaminated materials to and from SLAPS and HISS. Gamma scans of roadsides detect exposure rates in excess of background due to elevated concentrations of radium-226 and uranium-238 in the soil. Thorium-230, an alpha emitter, is determined to be a primary radioactive contaminant in soil on the basis of its activity. Parts of Hazelwood Avenue, Pershall Road and McDonnell Boulevard are designated by the DOE for remedial action.

1986

DOE provides radiological support to the cities of Berkeley and Hazelwood for drainage/road improvement project along Latty Avenue. An additional 4,600 cubic yards of material is placed in a supplementary storage pile at HISS.

Boreholes are drilled at SLAPS and the SLAPS VPs to define the nature and extent of the subsurface contamination and geological conditions. A radiological and limited chemical characterization of SLAPS determines that radioactive impacts extend as deep as 5.5 meters (18 feet) below grade. Further surveys identify additional areas of contamination along the shoulders of McDonnell Boulevard, Hazelwood Avenue, and Pershall Road.

1987

Further investigation of the original transportation routes is conducted. A complete radiological characterization, which consists of sampling and analysis to determine the nature and extent of contamination, is conducted at HISS, along Coldwater Creek, and on about 70 haul-road properties. Contamination on the haul-road properties is found on road shoulders and adjacent properties. Contamination is shallow (less than 1 foot deep), and concentrations are low. Although characterization is essentially complete, some additional investigation in the creek and along haul roads is still required. Chemical characterization of SLAPS and HISS is completed.

The U.S. Army Corps of Engineers requests that DOE survey an additional portion of Coldwater Creek as part of the Coldwater Creek Local Flood Protection Project.

1988

Radiological characterization, which consists of sampling and analyses to determine the nature and extent of contamination, is performed at SLDS.

1989

SLAPS and HISS are added to the Environmental Protection Agency's National Priorities List (NPL). This list requires 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).

Characterization studies of the section of Coldwater Creek from Banshee Road to Old Halls Ferry Road indicate low-level radioactive contamination is present in the Coldwater Creek channel.

A survey of the Dow Chemical Company Buildings in Madison, Illinois, indicates low-level radioactive contamination is present in dust located on overhead surfaces in Building 6. About  cubic yards of contaminated uranium/thorium dust from MED/AEC operations is identified on roof beams at the facility.

1990s 1990

The Environmental Protection Agency (EPA) and DOE sign a Federal Facilities Agreement, which establishes an environmental review process and establishes a schedule for the remediation of SLAPS, SLDS and HISS. The process requires DOE to evaluate alternatives for waste management, one of which is storage at SLAPS.

The City of St. Louis offers to transfer the SLAPS property back to DOE under the condition that a permanent disposal cell for radioactive wastes won't be constructed on the site. DOE declines acceptance of the SLAPS property from the city until the environmental review process is conducted.

Radiological characterization activities are conducted on the six properties adjacent to Mallinckrodt to determine whether contamination extends beyond the Mallinckrodt property boundaries.

1991

An Engineering Evaluation/Cost Analysis (EE/CA), which outlines the scope of interim removal actions at SLDS, is prepared and released for review and comment to the public. Once DOE prepares a Responsiveness Summary to address the comments received on the SLDS EE/CA, limited removal action activities are undertaken at SLDS.

1992

The Madison Site is added to the FUSRAP list of sites slated for cleanup. The FUSRAP site is located within a limited area of an active facility.

1994

The St. Louis Site Remediation Task Force is established. Two citizens committees are established for the purpose of working closely with FUSRAP representatives and serving as a "voice of the people." These organizations are the St. Louis Radioactive and Hazardous Waste Oversight Committee and the City of St. Louis Mayor's Advisory Task Force on Radioactive Waste. Later this same year, the members of these two groups join together with other community stakeholders to form the St. Louis Sites Remediation Task Force.

1995

Contaminated soils are removed from seven residential vicinity properties, beginning the North County sites cleanup.

15,043 cubic yards of contaminated soil is excavated from the Mallinckrodt Plant 10 area (SLDS) and shipped to a licensed, out-of-state disposal facility.

1996

The owner of 9150 Latty Ave., located to the east of HISS, expands the facility and stockpiles about 8,000 cubic yards of contaminated soil on the southwestern corner of the property. This stockpile becomes known as the Eastern Pile.

At SLDS, 750 cubic yards of contaminated soil is excavated from the City Property, Riverfront Trail area, and shipped to a licensed, out-of-state disposal facility.

The 50-series buildings on the Mallinckrodt property are decontaminated and demolished. Contaminated materials are transported by covered gondola cars for disposal in a licensed, out-of-state facility. Brick and cinder blocks are crushed and piled onsite to await disposition.

The St. Louis Site Remediation Task Force releases its report containing local stakeholders' conclusions and recommendations for remediating the St. Louis FUSRAP sites.

1997

The St. Louis Oversight Committee is formed from a subset of the St. Louis Remediation Task Force to act as a citizens advisory group in the decision-making process for the St. Louis FUSRAP Sites.

Plant 6 and 7 Buildings are decontaminated and demolished. Contaminated materials are transported by covered gondola cars for disposal in a licensed out-of-state disposal facility. Brick and cinder blocks are crushed and piled onsite to await disposition.

On Oct. 13, the Fiscal Year 1998 Energy and Water Appropriations Act transfers the FUSRAP project to the U.S. Army Corps of Engineers. The St. Louis District of the Corps of Engineers is chosen to carry out remediation on the St. Louis sites. Cleanup activities continue to follow CERCLA guidelines and incorporate NCP values.

After public review and comment on an EE/CA released earlier in the year under the DOE, the Corps of Engineers completes the removal of approximately 5,100 cubic yards of contaminated material from the west end of SLAPS adjacent to the gabion wall. The area is backfilled with clean soils in December 1997.

Radiological surveys in the vicinity of two bridges over Coldwater Creek in Florissant are performed to support upcoming bridge replacements.

1998

In March, the U.S. Army Corps of Engineers issues two Engineering Evaluation/Cost Analysis (EE/CA) documents (one for SLAPS and one for HISS), which identify potential cleanup measures to be used until a comprehensive cleanup can be achieved. The SLAPS EE/CA includes the Ballfields property as part of the SLAPS/SLAPS VP cleanup and evaluates several possible interim cleanup measures. The HISS EE/CA includes VP No. 2 and soils on three Latty Avenue properties as part of the HISS cleanup and evaluates several possible interim cleanup measures. Both of these documents are presented for public comment and regulatory review at a public meeting in March.

In April, the U.S. Army Corps of Engineers issues a Proposed Plan to the public for review and comment detailing the preferred alternative for final cleanup of SLDS. In August, the EPA approves the final cleanup remedy outlined in the SLDS Record of Decision (ROD).

Building K is decontaminated by the government and demolished by Mallinckrodt. Contaminated materials are transported by covered gondola cars for disposal in a licensed out-of-state disposal facility.

A detailed characterization, including sampling and analysis, is performed at the Madison Site. The survey included scanning for gamma radiation on accessible floor and wall surfaces throughout the building and on overhead beams, collection and analysis of indoor dust and debris, and determination of radioactivity levels on overhead beam surfaces.

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 and 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 shouldn't 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 don't 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.


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 groundwater. Of the portion that does fall, not all will fall on the field, and of what does fall on 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.


Assessing the St. Louis Sites

The St. Louis Sites were used to process and/or store uranium for the nation's nuclear defense program. Byproduct 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 were done to clean up 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 streambed. 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.

Groundwater 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 groundwater. By sampling groundwater 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.

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 of the laws is different, their goals are the same: to protect human health and the environment.


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 and 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 of Engineers 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 of Engineers sign a legally binding Record of Decision.

You can find the actual law at the U.S. House of Representatives site: Read about CERCLA in Title 42's Chapter 103.


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. However, 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 isn't 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.


The CERCLA/NEPA Process

Because many requirements of CERCLA and NEPA are similar or overlapping, 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.

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.


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 may 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 as well as 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.

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. This 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 provide input into technical decisions
• informing the public of planned or ongoing actions
• identifying and resolving conflicts
• facilitating community relations planning

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



Information Repositories

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 sources -- such as the documents used to select a cleanup method, documents regarding site activities and general Superfund information -- are placed in 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.



Community Relations Plan

The U.S. Army Corps of Engineers developed a Community Relations Plan (CRP) based on information gathered from discussions with members of the community on 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. (Note that this document contains 358 pages of text and photos and may require extra time to download.) 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.



Newsletters

USACE publishes a newsletter twice a year 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 a FUSRAP mailing list and placed in local repositories and with the Administrative Record or Administrative Record File. Copies of the newsletters are also available online along with instructions for adding your name to the mailing list.

 





Informational Products

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



Educational Outreach

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



Public Meetings

Normally held twice a year, public meetings (open to interested citizens) provide members of the community the opportunity to discuss environmental issues with USACE staff and/or technical experts. Meeting dates and times are published in advance on the website and in the newsletter put out by the FUSRAP Project Office on Latty Avenue in Berkeley, Missouri.

Corps of Engineers to host FUSRAP public meeting

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

 

 

Meeting presentations

 

St. Louis Sites

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 Lambert-St. Louis International Airport, which changed its name to St. Louis Lambert International Airport in February 2017, 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 that 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. On-site 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 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 the Department of Energy. 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 the EPA to determine how the site would be cleaned up and where the contaminated soil would be stored. In July 1990, DOE and the 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, through the Energy and Water Development Appropriations Act, Congress transferred execution of FUSRAP from the Department of Energy 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 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. FUSRAP's 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, USACE invited the public to participate in setting the interim cleanup standards for the site.

In 1997, an Engineering Evaluation/Cost Analysis (EE/CA) developed by 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, 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 groundwater characterization studies for the SLAPS. These studies involved the installation of groundwater monitoring wells; measurement of groundwater levels; and radiological and chemical analysis of groundwater 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 USACE the authority to address the contaminated materials in these properties and prevent off-site 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 run-off was under control, 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 on-site 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 that had been occurring concurrent with the EE/CA removal action at SLAPS. 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 Sept. 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 m2: 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 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 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 – documents 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.

Documents

North St. Louis County Sites Annual Environmental Monitoring Data and Analysis Report for Calendar Year 2016

North St. Louis County Sites Annual Environmental Monitoring Data and Analysis Report for Calendar Year 2015

North St. Louis County Sites Annual Environmental Monitoring Data and Analysis Report for Calendar Year 2014

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, which changed its name to St. Louis Lambert International Airport in February 2017.  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 (the essential ore of uranium) began at a newly constructed plant. The pitchblende 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 on-site 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 SLDS as part of its responsibility for the cleanup of FUSRAP sites. In October 1997, through the Energy and Water Development Appropriations Act, Congress transferred FUSRAP from DOE to the U.S. Army Corps of Engineers (USACE). Since that transition was effected, SLDS has fallen under the responsibility of USACE, St. Louis District.

Site Progress 1988 to 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 to 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 Environmental Protection Agency (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 groundwater 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 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 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:

 · Designating 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 SLDS to include additional areas to the north, south and west of the site.

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

An 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, 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 doesn't 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:

 · Destrehan Street-East/Plant 7 West-North - Remedial activities (RA) of this area began in June 2016. Approximately 70 percent of the projected contaminated-soil volume of 16,000 bank cubic yards has been removed. The RA of this area is currently scheduled for completion in 2018.

 · Mallinckrodt Inc. Plant 1 Former Building 17 Area - Preparation of this area, including Pre-Design Investigation sampling, began in August 2016. Approximately 40 percent of the projected 3,100 bank cubic yards have been excavated. RA of the building footprint area is scheduled for completion in 2018.

Inaccessible Soils at SLDS

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

USACE conducted a public hearing Jan. 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 Sept. 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 

  • St. Louis Downtown Site Annual Environmental Monitoring Data and Analysis Report for Calendar Year 2016
  • St. Louis Downtown Site Annual Environmental Monitoring Data and Analysis Report for Calendar Year 2015
  • St. Louis Downtown Site Annual Environmental Monitoring Data and Analysis Report for Calendar Year 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. Hazelwood Interim Storage Site (HISS) is located at 9170 Latty Ave., approximately 3.2 miles northeast of the control tower of the St. Louis Lambert International Airport, once known as Lambert-St. Louis International Airport, and approximately half a mile northeast of SLAPS. Latty is comprised of eight 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 the Manhattan Engineer District and the Atomic Energy Commission (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 on 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 Development Appropriations Act (Public Law 98-360), at various sites throughout the nation, including 9200 Latty Ave. 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 Ave., 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, through the Energy and Water Development Appropriation Act, Congress transferred FUSRAP from DOE to the U.S. Army Corps of Engineers (USACE). 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 to 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. Also in 1999, 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. To protect human health and the environment, 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. USACE chose to expedite the removal of the HISS piles to protect human health and the environment.

    A historical view of the piles removed by USACE

     

    USACE started removal of the HISS piles in spring 2000. Removal started with East Piles 1 and 2 located at VP-2L, adjacent to HISS. Work continued on the removal of the piles located on the HISS property. Contaminated materials from Spoil Piles A and B, Supplemental Pile and then the Main Pile were removed. Removal of the HISS piles was completed in 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 that had been occurring concurrent with the EE/CA removal action at SLAPS. 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 Sept. 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 m2: 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 to 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. USACE then prepares a PDIR/FSSE for that property.

    The data in a PDIR can also demonstrate that the property doesn't 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 portion 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, 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, USACE released 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 Drive, Berkeley, MO).

    2013

    In 2013, USACE completed remedial activities in the interior of the main building:

    ·         VP 1L (9151 Latty Ave., Berkeley, MO).

    Documents

    North St. Louis County Sites Annual Environmental Monitoring Data and Analysis Report for Calendar Year 2016

    North St. Louis County Sites Annual Environmental Monitoring Data and Analysis Report for Calendar Year 2015

    North St. Louis County Sites Annual Environmental Monitoring Data and Analysis Report for Calendar Year 2014

     

     

    Site Location

    The St. Louis Airport Site Vicinity Properties (SLAPS VPs) are located in the cities of Hazelwood and Berkeley, Missouri. These properties include Coldwater Creek and its vicinity properties to the west; adjacent ballfields 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 148 SLAPS VPs (named and unnamed within the industrial boundaries of the North County ROD), 96 Vicinity Properties have been released to date.

    Site Progress

    An Engineering Evaluation/Cost Analysis-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 Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) guidelines and incorporate the values of the National Contingency Plan (NCP), which is short for National Oil and Hazardous Substances Pollution Contingency Plan. 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 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 weren't released. Areas of the walls that weren't 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 Ave. to 8945 Latty Ave. to provide more operating room for heavy construction equipment removing the nearby HISS piles.

    USACE's primary goals for the SLAPS VPs 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 didn't 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 the EPA and the Missouri Department of Natural Resources (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 Feasibility Study (FS) and Proposed Plan (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).

    ·         In September 2005, the North County Record of Decision (ROD) was signed. Previous to the ROD, all work that 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.  USACE developed cleanup alternatives and presented them to the public for review in the FS and 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 Sept. 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 m2: 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 to 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. USACE prepares a PDIR/FSSE for that property.  

    Several Vicinity Properties, or VPs, have been released under the PDIR/FSSE process.

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

    ·         2009 – VPs 17, 18, 19, 20, 20A and 25 (southwest Frost Avenue)

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

    ·         2010 – VPs 33, 34 and 37 (Hazelwood Avenue)

    ·         2011 – VPs 3 and 4 (McDonnell Boulevard)

    The data in the PDIR can also demonstrate that the property doesn't 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 Avenue and Romiss Court) This VP was previously remediated in 2002 under a utility support. (See previous description.)

     

    2010

    The City of Hazelwood notified USACE regarding road improvements and widening Hazelwood Avenue from Frost Avenue to Pershall Road. 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. Contamination along Hazelwood Avenue and the adjacent rights-of-way (ROWs) and VPs occurred as a result of soil spillage from transport vehicles. As a result of characterization sampling and investigations along Hazelwood Avenue, 12 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 Avenue, and shipped to a licensed out-of-state disposal facility.

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

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

     

    2011

    In 2011, 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 and 6 (McDonnell Boulevard) – 42 cubic yards excavated

    ·         VPs 8 and 9 (McDonnell Boulevard) – 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 Boulevard, the old Ford Plant) – 70 cubic yards removed.

     

    2012 to 2013 Remedial Activities

    Presently, remedial activities are ongoing at:

    ·       IA-9 (Ballfields) - The Ballfields area consists of approximately 60 acres in Berkeley, Missouri. The property is located north of St. Louis Lambert International Airport, once known as 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 it was also a part of what was once Brown Road. Contamination of the Ballfields occurred when residues migrated from SLAPS via run-off 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 isn't in use.

    The remediation of the Ballfields is being completed in three phases. Phase 1 included 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. 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. 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 – USACE 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 Boulevard and CWC was remediated in 2011; a total of 2,939 cubic yards were removed.

     

    COLDWATER CREEK

     

    Coldwater Creek (CWC) is a SLAPS VP.  CWC flows adjacent to SLAPS, 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 1950s. The potential movement of contamination into the creek would have occurred by wind and water. The wastes consist of low-level radioactive contamination commingled with metals from uranium-processing activities.

     

    Project Description

    The approach to CWC is to first eliminate the sources of contamination. USACE completed the remediation of SLAPs (2007) and HISS/Futura (2012). 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 cleanup at SLAPS. USACE removed contamination from a tributary to CWC during remediation activities at HISS/Futura. 

     

    Monitoring

    In 1998, 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 isn't contaminated during remedial actions at adjacent properties.

     

    Recent and Future Sampling Events

    Several sampling events have taken place in CWC by DOE and 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 to 2013, USACE initiated characterizing/sampling of CWC from McDonnell Boulevard to Frost Avenue. Sampling was completed in March 2013, but additional sampling is needed to bound areas that may need remediation.

    ·          USACE completed the initial sampling of Coldwater Creek and adjacent properties from Frost Avenue to the St. Denis Bridge in 2016. Currently, USACE is sampling the next 1-mile stretch of CWC and adjacent properties from St. Denis Bridge to St. Ferdinand Park. USACE is also performing additional delineation sampling at areas where contamination was found above ROD remedial goals (RGs) at CWC and adjacent properties from Pershall Road to St. Denis Bridge. USACE completed sampling of St. Ferdinand Park in 2016 and found no contamination above ROD RGs.

    ·         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 Avenue to St. Denis Bridge Rev 0

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

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

  • North St. Louis County Sites Annual Environmental Monitoring Data and Analysis Report for Calendar Year 2016
  • North St. Louis County Sites Annual Environmental Monitoring Data and Analysis Report for Calendar Year 2015
  • North St. Louis County Sites Annual Environmental Monitoring Data and Analysis Report for Calendar Year 2014
  •  

    Site Location

    The Madison Site is located in Illinois within an active industrial site across the Mississippi River from St. Louis Downtown Site (SLDS). 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 (AEC) 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 2 cubic yards of contaminated uranium/thorium dust exceeding guidelines was identified from the Manhattan Engineer District and the Atomic Energy Commission (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 the U.S. Army Corps of Engineers (USACE) to identify an available time frame for cleanup. It is the intent of the facility owner and USACE that production operations won't 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 1999 (FY99), 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 (PP). Based on the comments received from the general public and regulatory agencies, 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 USACE's responses to those comments were incorporated into a section of the Madison Site ROD title the Responsiveness Summary. Upon approval of the Madison Site ROD, USACE began decontamination activities in June 2000.

    Uranium-contaminated dust was vacuumed from overhead structures 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 (PRAR), 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 isn't 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.

    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 USACE and Department of Energy (DOE), site stewardship consisting of records management was transferred to DOE. Information regarding this site may now be obtained from DOE's Office of Legacy Management, which provides long-term surveillance and maintenance of the site.

    Site Location

    The Iowa Army Ammunition Plant (IAAAP) is a secured, operational, Army-owned facility located on approximately 19,100 acres near Burlington in Des Moines County in southeastern Iowa. During its use as an Army facility, portions of IAAAP were occupied by tenant organizations, including the Atomic Energy Commission (AEC). 

    From 1947 to 1975, the AEC operated areas of the plant as the Burlington Atomic Energy Commission Plant (BAECP). In 2002 a Preliminary Assessment was completed for BAECP, and IAAAP was included in the Formerly Utilized Sites Remedial Action Program (FUSRAP). Evidence of a release was found in several areas. Two areas (Line 1 and the West Burn Pads South Area) were already investigated under other Army programs, but remedial action remained. In March 2013, FUSRAP completed remediation work at Operable Unit (OU) 1 (Soils OU) in Line 1 and West Burn Pads (WBP) Area South of the Road (ASOTR) under the Army Record of Decision (ROD) Soils (August 1998), except for explosive-contaminated soils above Remedial Goals (RGs) underneath Building 1-70. At that time, it was determined to suspend further remedial action at this site pending the planned demolition of this structure.

    Other areas at the plant required additional investigation, which was accomplished by the U.S. Army Corps of Engineers as part of a Remedial Investigation. The RI, which was completed in August 2008, identified three areas (the Firing Site area and Yards C and G) for further evaluation in the Feasibility Study. Contamination consisted of depleted uranium. Alternatives to address the DU contamination were presented in the Feasibility Report and a Record of Decision was completed in September 2011. The selected remedy consists of (1) the excavation and sorting of DU-contaminated soil with off-site shipment to a properly permitted disposal facility and (2) decontamination of structural surfaces in two buildings at Line 1. The primary regulators/stakeholders include the U.S. Environmental Protection Agency, Iowa Departments of Public Health and Natural Resources, Iowa Army Ammunition Plant (Army) and local residents. The site was placed on the National Priority List in 1990.

    The selected remedy implements a soil-sorting process system. During excavation of soils contaminated with DU, this sorting process is used to separate soils that are contaminated with DU from soils that aren't. This process reduces the amount of material that must be shipped off-site to an approved disposal facility. On-site soil that isn't DU-contaminated is used as backfill material, which reduces overall project cost. The construction season at IAAAP is approximately eight months from April to November.

     

    Site History


    When construction of the Iowa Army Ammunition Plant was completed in 1942, it was known as the Iowa Ordnance Plant (IOP). In 1947, the IOP was selected as the first production facility for the manufacture of high-explosives components for weapons under the AEC. From 1947 to 1975, portions of the IAAAP facility were under AEC control for research, development and production of materials and components as part of the U.S. early atomic program. The AEC-operated portions of the plant were commonly called the Burlington Atomic Energy Commission Plant (BAECP).

     

    In the late 1960s, it was determined that AEC operations at BAECP would be phased out and consolidated at the Pantex Plant near Amarillo, Texas. BAECP closed in July 1975 and control of the areas reverted to the IOP under direction of the Army. Later, the plant name was changed from IOP to IAAAP, as it is referred to today.

     

    In 1974, the Department of Energy (DOE) created FUSRAP to address sites used during the United States’ early atomic energy program that had residual contamination exceeding current regulatory limits.

      

    In 1989, IAAAP was proposed for inclusion on the National Priority List (NPL) pursuant to Section 105 of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) and the Superfund amendments and Reauthorization Act of 1986; it was added in 1990. In September 1990, the Army and EPA Region VII entered into a Federal Facilities Agreement (FFA, also called “Army FFA”) to define the roles and responsibilities for the Army’s CERCLA activities at IAAAP and the process for interagency coordination.

      

    IAAAP was placed under the U.S. Department of Defense (DOD) Installation Restoration Program (IRP), which manages CERCLA activities to identify, investigate and mitigate past hazardous-waste disposal practices that may have contributed to the release of pollutants into the environment at the U.S. Army installations/facilities. Past munitions production has resulted in contamination of soil and groundwater as well as discharges of waste water containing explosives to surface water. Response actions conducted by the Army at IAAAP under IRP are ongoing and separate from response actions conducted by USACE under FUSRAP.

      

    In 1997, a congressional action transferred FUSRAP responsibility from the Department of Energy (DOE) to the U.S. Army Corps of Engineers under the Energy and Water Development Appropriations Act.

      

    In March 2000, after performing historical research regarding AEC activities at IAAAP, DOE provided USACE with a determination that the portions of IAAAP utilized by the BAECP area may contain contamination resulting from activities that supported the nation’s early atomic energy program.

     

    Numerous environmental investigations have been conducted at IAAAP, both under the Defense Environmental Restoration Program (DERP) and Installation Restoration Program (IRP). A September 2000 report to the Congressional Defense Committee concluded that evidence of radiological contamination at Line 1 was uncovered and evidence of radiological contamination at FS-6 and FS-12 was uncovered.

     

    Another report written in November 2000 by the Department of Energy’s Oak Ridge National Laboratory was titled “Results of the Indoor Radiological Survey of Iowa Army Ammunition Plant; Middletown, Iowa” and concluded that contamination in Building 1-11 and at Firing Site 12 was likely attributable to AEC activities. This report also stated that contamination in Building 1-12 could have been the result of either AEC or Army activities.

     

    In April 2001, a gamma walkover survey and soil-sampling survey were performed at Firing Sites 6 and 12, finding non-uniform dispersion primarily located on or near chunks identified as depleted uranium (DU) throughout Firing Site 12, with two spots located at Firing Site 6.

     

    The Preliminary Assessment Report of IAAAP was completed in December of 2001 and found that further investigation was warranted to determine the nature and extent of AEC-associated contamination.

     

    In August 2006, a Federal Facility Agreement to address the FUSRAP project at IAAAP was executed among USACE, DOE, the EPA and the state of Iowa.

     

    St. Louis District, USACE, completed a Remedial Investigation report of IAAAP in October 2008, sampling the following areas for possible AEC contamination: firing sites area (five subareas); Yards G, C, L, E and F; an area west of Line 5B; and Warehouse 3-01. The conclusion reached during the Remedial Investigation was that of the eight areas only the Firing Sites exhibited potential human health risks.

     

    Site Progress


    Currently, the Army and USACE are performing cleanup simultaneously on IAAAP, with the Army remediating contaminants resulting from munitions production under the Defense Environmental Restoration Program (DERP) and USACE remediating contaminates resulting from the atomic energy program under FUSRAP.

     

    The Feasibility Study (FS) for IAAAP was completed April 22, 2011. This study identified, developed and evaluated the remedial-action alternatives for remediating AEC contaminates.

     

    The Proposed Plan (PP) for remediation was available for a 30-day public review at the Burlington Library and online starting April 22, 2011. A public meeting was held May 17, 2011, at the Comfort Suites Hotel and Conference Center in Burlington, Iowa, to present the FS/PP to members of the community. In the PP, USACE recommended Alternative 4, Excavation of DU-Contaminated Soil with Physical Treatment and Off-Site Disposal, along with Alternative S3, Decontamination/Replacement of Structures.

     

    The FUSRAP Record of Decision (OU8 ROD) was completed in September 2011. This ROD outlines the remedial activities that will be undertaken at IAAAP to address contamination resulting from AEC activities. The OU8 ROD selected remedy included Alternative 4, Excavation of DU-Contaminated Soil with Physical Treatment and Off-Site Disposal, along with Alternative S3, Decontamination/Replacement of Structures. The main components of the remedy include:

    ·          Excavation of DU-contaminated soil at Firing Sites 1 and 2; Firing Sites 3, 4 and 5; the Firing Site 6 Area; and the Firing Site 12 Area;

    ·          Physical treatment of DU-contaminated soil excavated via soil sorting;

    ·          Decontamination of structural surfaces and/or replacement of structural components (e.g., Building 1-11 floor grate and Building 1-63-6 air filters);

    ·          Disposal of DU-contaminated materials at a properly permitted off-site facility.

    The Remedial Design/Remedial Action Work Plan (RD/RAWP) was completed in February 2013. The RD/RAWP outlines a comprehensive process that follows the governing CERCLA and FFA requirements for implementing the selected remedy in the OU8 ROD. Work began under this RD/RAWP in summer 2013. The Pilot Study for soil-sorting method has been completed, and the excavation of the Firing Sites Areas has begun. Decontamination of the buildings at Line 1 was completed in July 2015.

    In 2008, it was determined that the soil in two of the FUSRAP areas (Line 1 and West Burn Pads South of the Road) was specifically covered in the existing Army Records of Decision (OU1 Soils RODs). As a result, these areas required remediation by FUSRAP under the authority of the Army RODs as directed by the EPA.

    Under the Army RODs, USACE has disposed of more than 30,000 cubic yards of contaminated material from Line 1 and the West Burn Pads South of the Road. USACE continues this remediation effort at Line 1. Remediation has been completed at West Burn Pads South of the Road. The Remedial Action Closeout Report will be issued once all FUSRAP activities within the Army RODS have been completed.

    The Administrative Record, which contains the documentation used to select the response action, is available at the following locations:

    Burlington Public Library
    210 Court St.
    Burlington, IA 52601

    U.S. Army Corps of Engineers St. Louis District
    FUSRAP Project Office
    8945 Latty Ave.
    Berkeley, MO 63134

    Documents
    Proposed Plan for the IAAAP
    Feasibility Study for the IAAAP
    Iowa Administrative Record
    Final Record of Decision
    FFA with Appendices - text only (79 pages)

    Signature pages (four pages)

    Map of Areas covered by FFA (one page)

    Iowa Army Ammunition Plant Annual Environmental Monitoring Data and Analysis Report for Calendar Year 2016 

    Iowa Army Ammunition Plant Annual Environmental Monitoring Data and Analysis Report for Calendar Year 2015 

    Five-Year Review Report: Five-Year Review Report for Formerly Utilized Sites Remedial Action Program (FUSRAP) Iowa Army Ammunition Plant

     


     

    Comments

    Daniel O'Connor, Remedial Project Manager

    U.S. EPA-Region 7
    901 North Fifth St.
    Kansas City, KS66101

    oconnor.daniel@epa.gov

    Pamela Houston, Community Involvement Coordinator

    U.S. EPA-Region 7
    901 North Fifth St.
    Kansas City, KS66101

    houston.pamela@epa.gov


     

    FFA Locations

    Burlington Public Library
    501 North Fourth St.
    Burlington, IA 52601

    (319) 753-1647

    Danville City Hall
    105 West Shepherd St.
    Danville, IA 52623

    Lee County Health Department
    2218 Ave. H
    Fort Madison, IA 52627

    EPA Record Center
    901 North Fifth St.
    Kansas City, KS 66101

    The St. Louis District, U.S. Army Corps of Engineers (USACE), announced the signature and release of the Final Record of Decision (ROD) for the North St. Louis County Sites Sept. 2, 2005. These sites consist of the St. Louis Airport Site (SLAPS), the Latty Avenue Properties including the Hazelwood Interim Storage Site (HISS) and the Futura Coatings Property, the SLAPS Vicinity Properties, which include Coldwater Creek.

    The ROD outlines the final remedy selected to cleanup contamination at the North St. Louis County sites. Contamination at the sites is the result of Manhattan Engineer District/Atomic Energy Commission activities that supported our nation's early atomic program in the 1940s and 1950s.

    USACE worked with the U.S. Environmental Protection Agency and Missouri Department of Natural Resources to develop the document. The final remedy was selected based on comments received from the public and regulatory agencies on the North County Feasibility Study and Proposed Plan (FS/PP).

    The public was encouraged to review and comment on both documents during a 75-day review period beginning May 1, 2003, and continuing through July 14, 2003. The final remedy was selected and identified in a Record of Decision after all comments received and any new information presented were considered. Responses to comments submitted on the FS/PP are included in the Responsiveness Summary. The Responsiveness Summary is an appendix to the ROD.

    In response to the potential risk of radioactive exposure, USACE has implemented Alternative 5, Excavation with Institutional Controls for Soils under Roads, Rail lines and Other Permanent Structures to protect human health and the environment. Congress directed USACE to oversee the cleanup of the St. Louis North County Site under the Formerly Utilized Sites Remedial Action Program (FUSRAP). The cleanup must follow the requirements set by the Comprehensive Environmental Response, Compensation and Liability Act (also known as CERCLA or Superfund).


    Documents 

     

    To help you navigate through the Record of Decision, Feasibility Study and Proposed Plan, the Table of Contents for each document has electronic links to all the contents listed. Click a content, and the program will route you to it automatically.


    The ROD is available to the public and may be accessed at the Administrative Record locations listed below:

    U.S. Army Corps of Engineers, St Louis District
    FUSRAP Project Office
    8945 Latty Ave.
    Berkeley, MO 63134

    Can be viewed Monday through Friday by appointment from 8 a.m. to 3 p.m.

    Schedule an appointment by calling 314-260-3905


    St. Louis Public Library
    Government Information Room
    1302 Olive St.
    St. Louis, MO 63103

    The Administrative Record Index and the Administrative Record on CD can be viewed by appointment at the library. If you would like to view the contents of the hard-copy binder, you must give at least one day's notice so it can be moved into the Government Information Room from an off-site location.

    Schedule an appointment with Jason Sutterfield at 314-539-0375.


    Public Notices


    Other Documents

    Under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), an evaluation of response actions at hazardous-waste sites where contaminants are present above levels that allow for unlimited use/unrestricted exposure is required at least every five years following the start of the cleanup at the site.

    Purpose of the Five-Year Review

    The purpose of the FYR is to determine whether the cleanup response continues to be protective of human health and the environment. These reviews begin five years after the initiation of the first response and continue in five-year cycles in perpetuity or at least until the site is documented in an FYR to meet unlimited use/unrestricted exposure requirements (UUUE).

    St. Louis FUSRAP Sites

    The FYR assesses the cleanups underway at FUSRAP St. Louis sites (SLS). SLS consist of two locations designated as the St. Louis Downtown Site (SLDS) in northern St. Louis City and the North St. Louis County sites that contain radiological and chemical contamination resulting from Manhattan Engineer District/Atomic Energy Commission (MED/AEC) operations. SLDS is comprised of the Mallinckrodt Inc. property and 38 surrounding vicinity properties (VPs). The North St. Louis County sites are located near the St. Louis Lambert International Airport, once known as Lambert-St. Louis International Airport, and include:

    · the St. Louis Airport Site (SLAPS);
    · Latty Avenue Properties, including the Hazelwood Interim Storage Site (HISS) and Futura Coatings (Futura), and six VPs; and
    · the SLAPS VPs, which encompass numerous properties between SLAPS, HISS/Futura, Coldwater Creek and the properties along Coldwater Creek. Of the 148 SLAPS VPs (named and unnamed within the industrial boundaries of the North County Record of Decision), 106 industrial properties have been released to date. Of the 200 Coldwater Creek properties that FUSRAP has sampled so far, 33 CWC properties have been released.

    The Selected Remedy

    The Selected Remedy for accessible areas at the SLDS is presented in the 1998 SLDS Record of Decision (ROD) and requires excavation and off-site disposal of radiological and chemical contamination in surface and subsurface accessible soil resulting from MED/AEC processing activities. The selected remedy also includes monitoring of the Mississippi Alluvial Aquifer. 

    The U.S. Army Corps of Engineers released the Remedial Investigation (RI) and Baseline Risk Assessment (BRA) Report for the Inaccessible Soil Operable Unit at SLDS in 2012. Inaccessible soils are located under buildings, permanent structures, railroads, soils on buildings and permanent structures, sewers and soils adjacent to sewers. The RI/BRA identified and characterized properties/areas at SLDS that contained inaccessible soils.

    The results from the RI/BRA revealed that 17 properties/areas out of 23 at SLDS with inaccessible soils met the EPA risk-and-dose criteria for release with no institutional controls.

    USACE is currently preparing two RODs to address the inaccessible soils at SLDS. USACE will soon release a No-Action ROD that will release 17 properties/areas at SLDS that met EPA risk-and-dose criteria for release under UUUE. USACE will then prepare a ROD that addresses six properties/areas at SLDS that require institutional controls.

    A separate remedy for the North County sites is presented in the 2005 ROD for North St. Louis County. The selected remedy consists of excavation and off-site disposal of radiological and chemical contamination in accessible soil resulting from MED/AEC processing activities. Other components of the North County ROD include:

    · Using restrictions at areas under roads, active rail lines and other permanent structures where the residual condition isn't consistent with UUUE;

    · Dredging contaminated sediments from Coldwater Creek to remediation goals that support UUUE;

    · Monitoring groundwater long-term in selected areas where soils contaminated above remediation goals are left in place or where contaminated groundwater has the potential to degrade adjacent groundwater or surface-water systems.

    How is a Five-Year Review conducted?

    The FYR is conducted by a team led by the U.S. Army Corps of Engineers (USACE) with representatives from the U.S. Environmental Protection Agency (EPA) and the Missouri Department of Natural Resources (MDNR). The FYR consists of four components: document review, site inspection, site interviews and assessment of response-action protectiveness.

    The “document review” is a review of the key documents identifying the approved response actions, how they are being carried out, legal requirements influencing the response actions, impacts of the response action on human health and the environment, and community concerns. These documents include the RODs, as-built drawings, site-monitoring information, the Federal Facilities Agreement (FFA) and the Community Involvement Plan (CIP).

    The site-inspection process involves the team inspection of each site and identifies the condition of the site and surrounding area. The team verifies that key records (i.e. health and safety plans) are on-site and available, verifies that access controls (i.e. fences) are in place and notes the general condition of site features (i.e. cover material).

    The team also seeks community input regarding the implementation of the response actions through site interviews. Members of the community, site personnel, state/local authorities, community groups, property owners and neighboring residents/businesses are asked to identify any problems that need to be addressed at the sites and to identify concerns regarding the impacts of the cleanup as it progresses.

    Assessing the protectiveness of the remedy

    To assess the protectiveness of the remedy for SLDS and the North St. Louis County sites (using information gathered during the document review, site inspections and site interviews), three essential questions are asked:

    1. Is the response action functioning as intended?

    2. Are the exposure assumptions, toxicity data, cleanup levels and Remedial Action Objectives of the remedy valid?

    3. Is any new information available which would call into question the protectiveness of the remedy?

    At SLDS, the protectiveness of the remedy continues to be effective. Groundwater isn't currently used as a drinking water source and existing access controls limit potential exposures to contaminated groundwater. USACE will conduct Phase 2 of the Groundwater Remedial Action Alternative Assessment (GRAAA) to evaluate the fate and transport of the site FUSRAP contaminants-of-concern (COCs) in the groundwater. In addition, USACE will continue monitoring the Mississippi Alluvial Aquifer (HU-B) to monitor the effectiveness of the source removal action.

    At the North St. Louis County site, USACE will continue to monitor groundwater, surface water and sediment to ensure that the elevated total uranium (U) concentrations in shallow groundwater at the western edge of SLAPS doesn't impact Coldwater Creek. If the total U concentrations significantly increase and impacts to Coldwater Creek are anticipated, an evaluation of potential response actions will be conducted and an appropriate response will be implemented.

    Protectiveness Statement for SLS:

    As required by CERCLA, USACE and the EPA have completed the first, second and third FYRs for the St. Louis FUSRAP sites. (The third FYR was completed July 31, 2015.) The FYR is required because hazardous substances, pollutants or contaminants remain at SLS above levels that allow for UUUE. These reviews evaluated the protectiveness of the SLDS Operable Unit (OU) remedy and the North St. Louis County OU remedy.

    Since the remedial actions of SLDS Operable Unit (OU) and the North St. Louis County OU are under construction and not completed, the remedies for SLS OUs are expected to be protective of human health and the environment upon completion. In the interim, exposure pathways that could result in unacceptable risks are being controlled.

    The reviews indicate that while conditions at SLS may be protective, conditions could be improved with relatively minor effort, consistent with the recommendations in the reviews, to ensure the safety and health of SLS workers and other potential exposure groups.

    Next Five-Year Review

    USACE plans to initiate activities for the next (fourth) FYR in 2018. USACE will be contacting businesses, property owners, representatives from government agencies, utility companies and private citizens to interview. USACE anticipates the completion of the fourth FYR in late 2019.

    Finding the results of the Five-Year Review

    The results of the FYRs are available to the public in the “Five-Year Review Report for the St. Louis FUSRAP Sites.” The final report documents the methods, findings and conclusions of the review. Any problems found and recommendations to address them are documented in the report.

    Five-Year Review Report: Third Five-Year Review Report for Formerly Utilized Sites Remedial Action Program (FUSRAP) St. Louis Sites

    Five-Year Review Report: Five-Year Review Report for Formerly Utilized Sites Remedial Action Program (FUSRAP) Iowa Army Ammunition Plant