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140730 - WLU

140730 - WLU

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This update is provided by EPA Region 7 in an effort to inform the community about the progress of environmental activities taking place at the West Lake Landfill Superfund Site in Bridgeton, Mo. EPA plans to provide routine updates which can be found at the links below.
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This update is provided by EPA Region 7 in an effort to inform the community about the progress of environmental activities taking place at the West Lake Landfill Superfund Site in Bridgeton, Mo. EPA plans to provide routine updates which can be found at the links below.
This document may not display correctly in older web browsers. For optimal viewing, use the latest version of Internet Explorer or other web browsers. If the document does not display correctly in a browser, please download the .PDF

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Categories:Types, Brochures
Published by: EPA Region 7 (Midwest) on Jul 30, 2014
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West Lake Update
July 30, 2014
To the CAG Executive Committee
,
Te U.S. Environmental Protection Agency (EPA) Region 7 thanks the West Lake Landfill Superund Site Community Advisory Group (CAG) Executive Committee or its July 20, 2014, e-mail regarding this agency’s work at the Bridgeton Municipal Athletic Complex (BMAC) during the week o May 19, 2014. Te EPA continues its vital efforts to protect the entire Bridgeton community through its work at the West Lake Landfill Superund Site. Although our primary ocus continues to be on the West Lake Landfill Superund Site, we would like to pause or a moment to provide details or the record on the work we perormed at BMAC.As you know, EPA Region 7 has consistently stated that based on all available scientifically valid data BMAC remains suitable or use. EPA Region 7 agrees with the Executive Committee that all data must be made available at the earliest possible time and be held to the highest industry standards beore accep-tance. Each step o the way through our assessment o BMAC, we’ve cited and provided rigorous scientific evidence supporting the decisions and recommendations we’ve made. EPA’s statements about the usability o BMAC were based on a valid, scientific oundation which EPA shared with the community. All statements regarding BMAC by EPA Region 7 were based on the body o evidence, which was made public at the time, and in so doing this agency has ulfilled its obligation to ensure that accurate inormation was available to the public.Specifically, the agency would like to note the ollowing acts that are useul or the record:
EPA Region 7 released the gamma screening report
only afer expert analysis and review. We perormed extensive quality assurance/quality control processes as well as a scientific peer review o the results. Te gam-ma screen is a tool used to identiy areas where levels o radiation may be present that could require reme-diation. Te gamma screen did not indicate any levels o radiation that would require any need to change the use o the BMAC acility. Te scientific and technical rigor was o a standard this agency is equipped to per-orm. EPA Region 7 is now perorming that same level o analysis and review o the soil sample tests and will be releasing the final report in the near uture.
Regarding our citation of other scientically valid
sources o data, EPA Region 7 used a series o tests—two by the Missouri Department o Natural Resources and one by the Department o Energy—to develop an early overall assessment o both BMAC and the area surrounding the complex.
Soil tests conducted by a community group headed
by one o your members in March that showed there was no reason or concern, but which was not pro- vided to the EPA until afer EPA completed the BMAC screening in May. Because o the limited nature o
Gamma Screening 
 
As referenced in your
e-mail, the EPA ollows the Multi-Agency Radiation Survey and Site Inspec-tion Manual (MARSSIM). Te CAG Executive Committee stated in its e-mail that “[t]he first observation regarding testing is that sodium iodide scintillation detectors or low count rate testing like BMAC can have a,“…reading error o 50%.” (U.S. Environmental Protection Agency; Multi-Agency Radiation Survey and Site Inspection Manual (MARSSIM), Revision 1. EPA 402-R-97-016, Rev. 1. August, 2000).Te quoted text above is part o a sen-tence which in whole reads “[t]he reading error o 50% can occur at low count rates because o a large needle swing, but this decreases with increased count rate.”
Tis sentence is referring to a detector with an ana
-log “needle type” display gauge. Te 50% error results rom the equipment operator’s inability to accurately read the display due to the wide swing o the needle during relatively low count rates.
Te potential reading error of 50% cited by the
Executive Committee does not apply to the equip-ment used by EPA to conduct the gamma survey at BMAC because the equipment EPA used was digital and not analog and does not require a person to read the needle as it swings rom one level to the next since a computer captures the readings automatically. Te more technical reasons are as ollows:that effort and the act we are not certain o their QA/QC procedures we have not included this inormation in our decision making and public comments. Te same group later conducted a “Gamma PAL” screen-ing that indicated the presence o Lead-210 at a level that would not require any remediation by the EPA but caused concern in the public afer media reports. Again, because o the QA/QC questions we could not use this inormation as a basis or any agency deci-sion. Instead, what we chose to do was test in the exact same locations. Te EPA Region 7 consulted with the leader o that group on the specific locations where soil samples were taken. Although she wasn’t able to point out those locations during a site visit she was able to later produce the locations by email, which we have tested.
EPA Region 7 reviewed existing data from credible
scientific and technical experts as part o a holistic effort to understand the conditions o the complex and surrounding area. Te MDNR dust samples pro- vided an important recent assessment but were in-complete on their own. Te 2005 MDNR haul road data provided important acts. Te third set o tests came rom the Department o Energy sampling cited in the Record o Decision or the North St. Louis County Sites issued by the U.S. Army Corps o Engineers, St. Louis District Office FUSRAP Program on September 2, 2005. EPAs citation o that sampling came rom a scientifically valid official decision document created by the USACE, another credible technical agency. Tis report indicated the roads were suitable or use and also provided important acts about the surrounding area that were valuable in ascertaining the suitability o BMAC. As EPA indicated at the time, there was no scientific basis rom a credible source to indicate BMAC was anything but suitable or use.
Regarding the USACE report, the EPA believes this
official FUSRAP decision document is a scientifically  valid source. By citing these three sampling efforts, EPA demonstrated that areas around BMAC did not contain levels o radiation requiring remediation and that there was no indication that conditions within the park would be any different.
EPAs statements about the usability of the complex
were based on valid, scientific sources which EPA shared with the community. All statements regarding BMAC by EPA Region 7 were based on the body o evidence, which was made public at the time, and in so doing ulfilled its obligation to ensure that accurate inormation was available to the public.
Testing Methods
 
esting Equipment
 
1. Te survey data were generated using a Ludlum Model 2221 ratemeter with an attached Ludlum Model 44-20 probe (3 inch by 3 inch sodium Iodide crystal) scintillation detector which has an automatic digital display gauge, coupled with a GPS unit and notebook computer running Field Analysis and Sampling ool (FAS) sofware.2. Te sensitivity o the Ludlum 2221 with the attached 44-20 probe is such that even low or background measurements result in count rates in the tens o thousands o counts per minute.3. All the Ludlum 2221 measurements at BMAC and the reerence areas were nearly instanta-neously captured by a digitally linked computer. Tis completely eliminates the possibility o equipment operator reading errors since a person is not actually doing any physical reading o the detector.
Te Executive Committee continues by stating “Te
Multi-Agency Radiation Survey and Site Inspection Manual (MARSSIM) cited by the EPA in their report goes on to tell us that, a sodium iodide detector’s… ‘energy response is not linear, so it should be calibrated or the energy field it will measure or have calibra-tion actors developed by comparison with a PIC or a specific site. Tis check should be perormed ofen, possibly several times each day.Nowhere in the EPA report or attached log books was the mention o ever calibrating the machine to a site specific survey by a PIC (Pressurized Ion Chamber)."
Te Ludlum 2221 with attached 44-20 probes used
during the investigation were calibrated according to manuacturer’s specifications using a Cs-137 source. Tey were also response checked twice daily with a similar Cs-137 source as specified in the BMAC Qual-ity Assurance Project Plan and the BMAC Preliminary Pre-CERCLIS Screening Report. Tis is an appropriate calibration and check source or a gross gamma sur- vey to be used in an investigation into the presence omultiple isotopes that emit gamma radiation at differ-ent energies. Furthermore, the comparison with a PIC is necessary i the intended purpose o the data is to report in exposure units such as micro roentgens. Te reason or this is urther explained in Appendix H o MARSSIM in the same subsection that the authors o the e-mail quoted earlier. Te intended purpose o the data or the BMAC investigation was to complete “a survey o gross gamma activity over the exterior areas o BMAC.” (BMAC Preliminary Pre-CERCLIS Screen-ing Report, Section 3.1 Surace Soil Gamma Survey). Te purpose o the survey was to identiy any unusual patterns o concentrated discrete areas o elevated gross gamma activity. Tese areas would then be selected or soil sampling. Because the gamma screen-ing did not produce any areas o unusual patterns o concentrated discrete areas o elevated gross gamma activity at BMAC, the EPA experts ollowed statisti-cal protocols by dividing the readings into two sets— measurements above the median and measurements below the median in order to select an equal number o locations rom each set or soil sampling.
Regarding response checks, the twice daily response
checks reerred to in both EPAs BMAC Quality Assur-ance Project Plan and the BMAC Preliminary Pre-CERCLIS Screening Report ensure that the device is maintaining its calibration. In addition, the reerence areas were surveyed multiple times to ensure that other environmental actors would not significantly contrib-ute to a change in the response o the detectors.
Regarding “calibrating the machine to a site spe
-cific survey by a PIC (Pressurized Ion Chamber),” as explained above, this is only necessary i the intended purpose o the measurements taken with the Sodium Iodide detector are to be converted to exposure units such as micro roentgens.
Te CAG Executive Committee also states “[i]f
proper use o the sodium iodide detector was not done it reduces the 58,716 data points in the EPA report to the accuracy o a coin toss.Tis is not true given the act the EPA used digital equipment connected to a laptop.

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