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Five Year Review
The Second Five Year Review (FYR) has been completed for
the St. Louis FUSRAP sites. 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. This review covers the
09/01/2003 to 12/31/2008 time period.
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 to perpetuity or at least until the
site is documented in a FYR to meet unlimited use / unrestricted exposure
requirements (UUUE).
The St. Louis FUSRAP Sites
The second FYR for the St. Louis FUSRAP sites (SLS) has
been completed. The FYR assessed the cleanups underway at the SLS. The 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 the Manhattan Engineer
District/Atomic Energy Commission (MED/AEC) operations. The SLDS is comprised
of the Mallinckrodt, Inc. property and 34 surrounding vicinity properties
(VPs). The North St. Louis County sites are located near the Lambert-St. Louis
International Airport and are composed of: St. Louis Airport Site (SLAPS);
Latty Avenue Properties, including the Hazelwood Interim Storage Site (HISS) and
Futura Coatings (Futura), and eight VPs; and, the SLAPS VPs, consisting of
approximately 78 properties between the SLAPS, the HISS/Futura, and Coldwater
Creek, and the properties along Coldwater Creek.
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
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.
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 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 is not consistent with
UUUE;
·
Dredging contaminated sediments from Coldwater Creek to
remediation goals that support UUUE;
·
Monitoring ground water long-term in selected areas where soils
contaminated above remediation goals are left in place or where contaminated
ground water has the potential to degrade adjacent ground-water or surface-water
systems.
How is a Five Year Review Performed?
The Second FYR for the SLS was 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 consisted 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 it is 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 verified that key records (i.e. health and safety plans) were
onsite and available, access controls (i.e. fences) were in place, and noted the
general condition of site features (i.e. cover material).
The team also sought 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 were asked to identify any problems
that needed 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 the SLDS
and North St. Louis County sites, information (gathered during the document
review, site inspections, and site interviews) was used to answer three
essential questions:
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 the SLDS, the protectiveness of the remedy has not
been affected at this time. Ground water is not currently used as a drinking
water source and existing access controls limit potential exposures to
contaminated ground water. USACE will conduct the Phase 2 of the Ground-Water
Remedial Action Alternative Assessment (GRAAA) to evaluate the fate and
transport of the site FUSRAP contaminants-of-concern (COCs) in the ground
water. 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 ground water, surface water, and sediment to ensure that the elevated
total Uranium (U) concentrations in shallow ground water at the western edge of
SLAPS do not 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.
The Protectiveness Statement for the SLS:
As required by CERCLA, the USACE and the EPA have
completed the second FYR for the St. Louis FUSRAP sites. The FYR is required
because hazardous substances, pollutants or contaminants remain at the site
above levels that allow for UUUE. This review evaluates the protectiveness of
the SLDS Operable Unit (OU) remedy and the North St. Louis County OU remedy.
Since the remedial actions of the SLDS OU and the North
St. Louis County OU are under construction and not completed, the remedies for
the 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 review indicates that while conditions at the SLS
may be protective, conditions could be improved with relatively minor effort,
consistent with the recommendations in this review, to ensure the safety and
health of the SLS workers and other potential exposure groups.
Finding the Results of the Five Year Review
The results of the FYR 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.
Next Five Year Review
The dates of the next FYR will from January 2014 to
December 2019.
Finding the Results
Copies of this report have been placed with the
Administrative Record located at the FUSRAP Project Office at 8945 Latty Avenue
Berkeley, MO. Since the main branch of the St. Louis Public Library is closed
for re-modeling, a copy of this FYR can be found at the St. Louis Public Library
– Prairie Commons Branch 915 Utz Lane St. Louis, MO 64042. The FYR can also be
viewed on the USACE website:
http://www.mvs.usace.army.mil/eng-con/expertise/fusrap.html
For questions or comments on the Five Year Review or
FUSRAP, contact the FUSRAP Project Office at 314-260-3905.
SECOND FIVE-YEAR REVIEW REPORT FOR
FORMERLY UTILIZED SITES REMEDIAL ACTION PROGRAM (FUSRAP) ST. LOUIS SITES |
