West Lake CAG NRRB Submission REVISED ADDENDUM January 4 2018

half mile from Francis Howell High School 30 . A Weldon Spring timeline fact sheet says the
site “became the first DOE environmental remediation site to achieve the Department’s highest
award for excellence in safety.” 31 The EPA should be confident in a radioactive removal
decision given the DOE is a PRP at West Lake and has demonstrated excellence in safety for
radioactive remediation at the Weldon Spring site.
Shpack Landfill in Norton, Massachusetts
Since the FFS references Worker Safety (although we are under the impression this is NOT
standard for a FS), we suspect the risk is overstated and refer you to the Record of Decision 32 at
the FUSRAP-led Shpack Landfill in Massachusetts. The ROD called for excavation and
transportation of radioactive wastes to a federally designated repository. Section 6.0 of the
Remedial Action Work Plan 33 (2005) details the execution of radioactive removal while the Site
Safety and Health Plan 34 (2005) provide guidance for worker safety (2005). The Site Safety and
Health Plan for the Shpack Landfill demonstrate how worker safety has been accounted for at a
radioactive landfill site where removal was selected as the remedy.
Shattuck Superfund Site in Denver, Colorado
The Shattuck Superfund site contained several Operable Units, including OU-8 that was
contaminated with Radium. The EPA implemented a ROD in 1992 that called for containment
of the radioactive material in an onsite monolith. A five year review found Radium leaving the
site. A ROD Amendment was initiated in 2000 that called for the excavation and offsite disposal
of the radioactive material 35 . The EPA goes on to acknowledge that “Although all of the
alternatives would protect human health and the environment in the short-term, only
Alternative 3 which calls for the removal of the waste from the site to an approved
disposal facility can ensure long-term protectiveness 36 .” EPA Region 8 eventually
determined that a decision reducing the Operation & Maintenance and reliance on institutional
controls would result in the greatest overall protectiveness.
30
Weldon Spring Site Remedial Action Project Update
https://www.lm.doe.gov/cercla/documents/WeldonSpring_docs/Chemical_Plant/C-800-806-1.06.pdf
31
DOE Weldon Spring Timeline Fact Sheet: https://www.lm.doe.gov/Weldon_Fact_Sheets.pdf
32
EPA Record of Decision Summary for the Shpack Landfill in Norton, Massachusetts (2014)
https://www3.epa.gov/region1/superfund/sites/shpack/214530.pdf
33
Shpack Landfill Remedial Action Work Plan (2005) http://moenvironment.org/files/Remedial-Action-Work-Plan-2005.pdf
34
Shpack Landfill Site Safety and Health Plan (2005) http://moenvironment.org/files/Site-Safety-and-Health-Plan-2005.pdf
35
Shattuck Record of Decision Amendment (2000) https://semspub.epa.gov/work/08/301191.pdf
36
Shattuck Record of Decision Amendment (2000) https://semspub.epa.gov/work/08/301191.pdf Shattuck Record of Decision
Amendment (2000) https://semspub.epa.gov/work/08/301191.pdf
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