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FUSRAP

Background

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St. Louis Sites

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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, now called a Community Involvement Plan (CIP), 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. USACE will review its CIPs every five years in conjunction with the Five-Year Review and update them as needed to ensure they continue to address the concerns of the community.

CIPs administered by the St. Louis District:

Iowa Army Ammunition Plant FUSRAP Site

St. Louis FUSRAP Sites main document 

St. Louis FUSRAP Sites appendices

(Note that these documents contain many pages of text and photos, and they may require extra time to download.)


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.

Edit Click here to expand contentClick here to collapse content  1998 to present


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 once 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.


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