West Lake CAG NRRB Submission REVISED ADDENDUM January 4 2018

StLouisManhattanProjectHistory

To: National Remedy Review Board

Fr: West Lake Community Advisory Group

Re: Addendum to our November 20, 2017 Submission

Regarding the West Lake & Bridgeton Landfill Superfund Site

Dt: January 4, 2018

On behalf of the West Lake Landfill / Bridgeton Landfill Community Advisory Group (CAG) and

community members both locally and regionally, please accept this addendum to our original

submission dated November 20, 2017. We have modified that document (see attached) in the

following ways:

1. Added this cover page

2. Added the following to the section titled Opening Statement:

Please be informed that in February, an HBO documentary on the West Lake / Bridgeton Landfill

Superfund Site and the Coldwater Creek area, titled Atomic Homefront

www.AtomicHomefront.film will air for the entire nation to see. Our community’s struggle with

the EPA, DNR, Republic Services and the other PRPs will now echo from sea to shining sea. Our

nation will also learn about the massive underground fire that's been burning in the landfill since

2010 and the nuclear bomb production waste that is in its path. They will also learn about Republic

Services' lack of compassion and attempts to thwart our community's efforts in achieving a healthy,

safe environment to raise our families.

The Producers of Atomic Homefront along with HBO have agreed to the CAG distributing the

following clip from Atomic Homefront to the members of the NRRB and other select EPA

personal. It focuses on training our National Guard provided to our First Responders on how to

react to a release of RIM at this site. Please accept this as part of our submission.

It is our understanding that Full Removal with On-Site Storage has been added to the range of

Remedies being considered. To be clear, we favor Full Removal. That said, we are reluctant to

commit to supporting either On-Site or Off-Site Storage at this time. We recommend that the EPA

first make the decision that this material must be removed from its current illegal and unsafe

unlicensed de facto storage facility and then involve our community in frank discussions on On-Site

vs Off-Site storage. Should EPA choose this route, we commit to working with EPA to establish

and complete these community discussions.

3. Added the following to the section titled Broad Community Support for Full Removal

Please see the numerous local governments, cities, and State and Federal legislators who have

called for Full Removal at the following link:

http://www.stlradwastelegacy.com/supporters/government/ Note that the City of Bridgeton’s City

Council, where this Superfund Site is located, has passed a lawful resolution calling for Full

Removal. Some of the officials and government bodies sited at this link are calling for moving

jurisdiction from EPA to the Army Corps of Engineers vs Full Removal; these statements and

resolutions were made in the spirit of expanding the current cleanup of FUSRAP sites in the St.

Louis area to include the West Lake Landfill with the understanding that transfer to FUSRAP would

most likely result in Full Removal.

Page 1


4. Added the following new section:

Is WLL and/or Bridgeton Landfill A FUSRAP Vicinity Property?

The West Lake Landfill qualifies as a Vicinity Property to HISS/FUTURA (Latty Avenue site) and

should not have been excluded from the current FUSRAP cleanup 1 . Also, based on the Federal

Facilities Agreement, it appears that any RIM found within the Bridgeton Landfill property line

(and it has been documented by EPA/PRPs to be there) would become the responsibility of

FUSRAP.

5. Added the following (and Appendix) to the section on Underestimated Flood Risk

Below is a table from a document prepared by Maggie Weng, a student at Washington University,

under guidance of her professor showing the percentage of the landfill that will be flooded under

various scenarios (see full study including data sources and analysis techniques in Appendix F).

Recurrence Interval

(years)

Stage of flood, including

height above NAVD88 (m)

Area in map below

flood elevation (km2)

17.4 136.966 21.96 44.02

100 139.02 231.769 51.63

300 140.459 234.84 61.95

500 141.1267 236.17 63.58

6. Updated Table of Contents to reflect these additions.

% landfill below

flood elevation

Please don’t hesitate to call on us to answer any questions or to provide further information.

Sincerely,

Harvey Ferdman

Harvey Ferdman, Chair

West Lake Landfill / Bridgeton Landfill CAG.

314-469-0595 (land line) or 314-761-5100 (cell)

To: National Remedy Review Board

1

From pdf page 7 of the Federal Facilities Agreement for St. Louis and Hazelwood FUSRAP sites, docket

VII-90-F-0005 moenvironment.org/files/1990_FedFacilitiesAgreement.pdf

Page 2


Fr: West Lake Community Advisory Group

Re: West Lake & Bridgeton Landfill Superfund Site

Dt: November 20, 2017

On behalf of the West Lake Landfill / Bridgeton Landfill Community Advisory Group (CAG) and

community members both locally and regionally, we thank you for the opportunity to share our

thoughts and concerns about the unlicensed nuclear storage facility and EPA Superfund site that

we refer to as the Bridgeton Landfill / West Lake Landfill Complex.

Please do not hesitate to call on us to answer any questions or to provide further information.

Sincerely,

Harvey

Harvey Ferdman, Chair

West Lake Landfill / Bridgeton Landfill CAG.

314-469-0595 (land line) or 314-761-5100 (cell)

Page 3


Table of Contents

Is WLL and/or Bridgeton Landfill A FUSRAP Vicinity Property? ................................................................... 2

1) Opening Statement ..................................................................................................................................... 5

a) Inadequate Testing – Range of “Known” RIM is in Question ............................................................... 6

b) Full Removal at Similar Site Proved to be Right Decision .................................................................... 7

2) Community Member Letter ........................................................................................................................ 8

3) Letter to Mr. Albert Kelly, Superfund Task Force ................................................................................... 10

4) Effect on Our Community ........................................................................................................................ 10

5) Broad Community Support for Full Removal .......................................................................................... 11

5a) Is WLL and/or Bridgeton Landfill A FUSRAP Vicinity Property? ..................................................... 12

6) Timely Removal is Possible ..................................................................................................................... 12

7) Safe Removal – Is Relocation Necessary? ............................................................................................... 12

8) Baseline Risk Assessment (BRA) Concerns ............................................................................................ 12

9) Key Inconsistency Between NRRB 2013 and Current RIA ..................................................................... 13

10) Underestimated Flood Risk .................................................................................................................. 13

11) Short and Long-Term Seismic Risk ..................................................................................................... 15

12) Air Contaminates .................................................................................................................................. 15

13) Air Traffic Safety.................................................................................................................................. 16

14) Conceptual Site Model (CSM) Concern ............................................................................................... 17

15) Nightmare Scenario .............................................................................................................................. 17

Appendix A – Technical Concerns Letter to Mr. Kelly ................................................................................... 18

Appendix B – Economic Impact – Councilman Randy Hein ........................................................................... 22

Appendix C – Full Removal Safety References ............................................................................................... 22

Appendix D – School Emergency Preparedness Letters .................................................................................. 28

Appendix E - Flood Risk and a History of Flooding ........................................................................................ 33

Appendix F – Flood Stage Elevations at West Lake Landfill .......................................................................... 38

Page 4


1) Opening Statement

On behalf of the West Lake Landfill / Bridgeton Landfill Community Advisory Group (CAG) and

community members both locally and regionally, we thank you for the opportunity to share our

thoughts and concerns about the unlicensed nuclear storage facility and EPA Superfund site that

we refer to as the Bridgeton Landfill / West Lake Landfill Complex.

With so much focus on the Radioactively Impacted Materials (RIM) there, sometimes it’s hard to

remember that the entire Complex is a Superfund site, and would be such without the presence of

the illegally dumped WWII nuclear bomb production waste due to it being an unlined limestone

quarry that was allowed to accept a wide range of industrial, residential, and demolition wastes.

This site is further complicated by the existence of multiple “cells” that were filled over many

decades and it being located in a flood and earthquake zone virtually in the center of a major US

metropolitan area of 2.8 Million people.

Please be informed that in February, an HBO documentary on the West Lake / Bridgeton Landfill

Superfund Site and the Coldwater Creek area, titled Atomic Homefront

www.AtomicHomefront.film will air for the entire nation to see. Our community’s struggle with the

EPA, DNR, Republic Services and the other PRPs will now echo from sea to shining sea. Our

nation will also learn about the massive underground fire that's been burning in the landfill since

2010 and the nuclear bomb production waste that is in its path. They will also learn about Republic

Services' lack of compassion and attempts to thwart our community's efforts in achieving a healthy,

safe environment to raise our families.

The Producers of Atomic Homefront along with HBO have agreed to the CAG distributing the

following clip from Atomic Homefront to the members of the NRRB and other select EPA

personal. It focuses on the training our National Guard provided our First Responders should a

release of the RIM occur. Please accept this as part of our submission. NOTE: HBO has asked

that this clip and link not be distributed. This link expires on January 17 th , 2018. You are able

to download and store this clip.

https://ny.aframe.com/links/cfa3e7b312e15e8b351b8e247ccf8b20

Department of Energy (DOE) Responsibility and Rules: The radioactivity dumped at the West

Lake Landfill was referenced by the Nuclear Regulatory Commission (NRC) as being licensed

material in its 1995 letter to the EPA. The EPA identified the DOE as a responsible party at the

West Lake Landfill due to the Atomic Energy Commission (AEC) having licensed this material to

be processed at the Latty Avenue, St. Louis County, site. Therefore, the Radioactive Waste

Management Manual (RWMM) should be applicable at the West Lake Landfill. The RWMM

states, “The requirements of this Manual apply to all new and existing DOE radioactive waste

management facilities, operations, and activities.” The DOE manual clearly states that low-level

radioactive waste should not be located in a floodplain, tectonically active area, or in the zone of

water table fluctuation. West Lake Landfill’s location fails to meet this standard on all accounts and

no remedy other than Full Removal can comply.

It is our understanding that Full Removal with On-Site Storage has been added to the range of

Remedies being considered. To be clear, we favor Full Removal. That said, we are reluctant to

commit to supporting either On-Site or Off-Site Storage at this time. We recommend that the EPA

first make the decision that this material must be removed from its current illegal and unsafe

Page 5


unlicensed de facto storage facility and then involve our community in frank discussions on On-Site

vs Off-Site storage. Should EPA choose this route, we commit to working with EPA to establish

and complete said community discussions.

In 2013, the National Remedy Review Board (NRRB), after reviewing the 2008 Record of

Decision’s capping-in-place Remedy, found the analysis of this site severely deficient in the testing,

characterization, and protectiveness of our community 2 . Note: despite additional testing, the issues

with leaving RIM at this site are substantially the same as in the past in regard to capping-in-place

not providing short or long term protectiveness of our community. Since your last review, the

USGS has confirmed that RIM is leaching into our groundwater, and even more RIM in the soils

have been discovered in a select area that was tested for suitability for building a physical firewall,

once again highlighting the lack of full characterization of this site. In addition, according to a

report by Dr. Robert E. Criss of Washington University 3 , “Diagrams in McLaren-Hart (1996b;

Fig. 3-29) clearly show groundwater in contact with landfill radwaste. Data in EMSI (2012)

document that large-scale radionuclide migration in groundwater has occurred.”

We are also concerned that the separation of this site into more Operable Units, specifically

removing groundwater concerns from OU-1 and moving them into the newly formed OU-3 creates

a scenario where any Remedy for OU-1 other than Full Removal may have to be reworked as part

of OU-3. This also raises the question of which entity pays for this rework should it be required. To

us laypeople, it does not seem fair to have the PRPs do all that work and then them having to pay to

undo it. Does this mean we taxpayers will bear the burden? When asked if a rework of OU-1’s

Remedy implementation may have to be reworked based on the OU-3 Remedy, Region 7 staff has

clearly said “yes” on multiple occasions. For example, an EPA ROD at the Shattuck Superfund site

in Denver called for a viable responsible party to entomb Radium at cost of $26 million. A five year

review determined Radium migrated offsite leading to a ROD Amendment for the removal and

offsite disposal. Once the rework was ordered, the viable responsible party only paid

$5,450,000 of the nearly $60,000,000. It’s our understanding that tax dollars paid for the rest.

a) Inadequate Testing – Range of “Known” RIM is in Question

This site has had 2 previous documented fires in the North Quarry which were much closer to the

“known” RIM than the current Sub-surface Smoldering Event (SSE) in the South Quarry.

Therefore, we are very concerned that the issues raised by the Office of Research and Development

(ORD) 4 regarding the inadequacies of capping to protect us from the release of Radon and

Radioactive Particles have not been properly addressed in the FFS. Now that RIM has been

confirmed to be in the North Quarry, we hasten to point out that the North Quarry has NEVER

been tested for RIM other than along the upper northern boundary using the “Step-Out” method.

This was done in search of a clean path to install an isolation barrier that was agreed upon as part of

the State of Missouri case against Republic Services for various violations related to the Bridgeton

Landfill. At this time, a path for a physical isolation barrier remains elusive and potentially not

feasible.

2

National Remedy Review Board Discussions Regarding the Remedy at the West Lake Landfill Superfund Site, February 28, 2013

3

Risk and Character of Radioactive Waste at the West Lake Landfill, Bridgeton, Missouri, March 14, 2013

4

EPA Office of Research and Development, National Risk Management Research Laboratory, Engineering and Technical Support

Center - March 28, 2017

Page 6


) Full Removal at Similar Site Proved to be Right Decision

The Shattuck Superfund site under EPA Region 8 jurisdiction 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 5 . 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 6 .” EPA Region 8 eventually

determined that a decision reducing the Operation & Maintenance and reliance on institutional

controls would result in the greatest overall protectiveness.

5

Shattuck Record of Decision Amendment (2000) https://semspub.epa.gov/work/08/301191.pdf

6

Responsiveness Summary for the Proposed Plan for an Amendment to the Record of Decision, Denver Radium Operable Unit #8,

Shattuck Site, Executive Summary (2000)

Page 7


2) Community Member Letter

We want to open our comments to you by sharing a bit about the authors of the following letter that

we feel sums up our position and the overall community concerns about the range of Remedies

proposed for this site. Kay and Leo Drey, once Missouri’s largest private land owners, donated

their Pioneer Forest to a foundation that continues to preserve the forest by harvesting the timber

sustainably. Kay went on to lead our community effort to re-open the 2008 ROD.

Carolyn Bower, Kay’s co-author, a retired journalist of 30 years, has reported on the Nuclear

Weapons Waste left in St. Louis throughout her career, and in her retirement volunteers to help our

community.

To: Harvey Ferdman, Dawn Chapman, Karen Nickel

West Lake Community Advisory Group

Re: West Lake & Bridgeton Landfill Superfund Site

Fr: Kay Drey and Carolyn Bower

Dt: November 8, 2017

This letter is a request that the U.S. Environmental Protection Agency require the removal of

the radioactive material from the West Lake Landfill Site in St. Louis County, Missouri, as

the EPA’s Proposed Remedy for Operable Unit 1 (OU-1) at West Lake. We urge the EPA to

recommend that the U.S. Army Corps of Engineers lead the excavation and removal of these

nuclear weapons wastes as it has done elsewhere in St. Louis and nationwide (through its

Formerly Utilized Sites Remedial Action Program, or FUSRAP). Removal of the radioactive

wastes from the West Lake site is the only safe and permanent solution.

Here are some reasons that these long-lived wastes must be removed:

1. The West Lake wastes include thorium, uranium, and radium — some of the most toxic

materials on our planet — a legacy of the atomic weapons program that began near

downtown St. Louis during World War II, and continued in metropolitan St. Louis for

decades.

2. The downtown radioactive wastes were trucked after World War II to the St. Louis

Airport Site. Most of those wastes were moved in the late 1960s to a site on Latty

Avenue and piled up there. About 47,000 tons of radioactive materials from Latty were

then hauled in 1973 to the West Lake Landfill, which is only about a mile from the

Missouri River.

3. The radioactive materials are contaminating the groundwater at the landfill.

4. That contaminated groundwater flows into the Missouri River — upstream from

the drinking water intakes for north St. Louis County and for the city of St. Louis.

5. The radioactive gases and particles at West Lake also are contaminating the air we

breathe. The radioactive wastes will remain dangerous for hundreds of thousands of

years and beyond.

6. Swallowing, inhaling, or other exposure to radioactive materials can cause birth defects,

cancer, and many other life-threatening diseases.

Page 8


There could be no worse place for radioactive materials than near the Missouri River, which

provides drinking water for so many people in our populated area and downstream. The

Missouri River is North America’s longest river and one of the most important sources of

drinking water and farm irrigation water in the Midwest.

• The U.S. Geological Survey in a 1960 report to the U.S. Atomic Energy Commission said

St. Louis’ legacy radioactive “sludges” should not be put into a quarry near the Missouri

River because of the “high probability of contaminating the Missouri River shortly

above the intakes for the St. Louis city and St. Louis County water supplies.’’ (From

Walter Haubach 1967 historical review of the legacy wastes attached as part of a May

1972 proposal to the AEC for the decontamination of the Latty Site by Cotter, the owner

at that time. With emphasis added.)

• Thirty years ago the U.S. Geological Survey (USGS) said: “West Lake Landfill

potentially is a serious, long-term health risk for persons residing and working in the

vicinity,” according to a USGS 1985 report called “Effects of Chemical and Radioactive

Wastes from West Lake Landfill on the Missouri River Alluvial Aquifer, St. Louis

County, Missouri’’.

• In 1988 the U.S. Nuclear Regulatory Commission said that the West Lake radioactive

wastes represent a significant long-term hazard and “will likely require moving the

material to a carefully designed and constructed ‘disposal cell.’”

It is our federal government, of course, that creates our nuclear weapons. As with other

nuclear weapons waste sites nationwide, it is our federal government that has the moral and

fiscal responsibility to remove the nuclear weapons wastes from West Lake Landfill.

The EPA has the opportunity and responsibility to mandate the removal of these hazardous,

radioactive wastes from threatening the Missouri River. We all need clean air to breathe and

clean water to drink.

Sincerely,

Kay Drey and Carolyn Bower

Page 9


3) Letter to Mr. Albert Kelly, Superfund Task Force

Please take a moment to read our recent letter to Mr. Albert Kelly, Superfund Task Force that

outlines many more of our concerns and perceived deficiencies in the current Final Feasibility

Study. Please see Appendix A.

4) Effect on Our Community

Our community’s concern over this site extends deep and broad. We have lost businesses,

residences, and property values; we have lost the use of our hard earned homes and ability to share

them with friends and family … and as long as this toxic material is allowed to remain here, we see

no relief to the undue burden this unlicensed nuclear storage facility brings to our community and

its economy as we lose businesses and developers put plans on hold while awaiting remediation. A

565 acre development proposal was recently put on hold due to the uncertainty surrounding the

landfill. For details, please see remarks from Councilman Randy Hein in Appendix B made at the

10/19/2017 EPA/CAG/JustMomsSTL meeting in Bridgeton, MO attended by Mr. Kelly and Ms.

Stepp.

We are concerned about the long term effects of leaving this material here. Institutional controls

have already failed to monitor radioactivity in the storm water runoff: Historic testing for

radioactivity in storm water is significantly lacking based on the Remedial Investigation (RI)

written by EMSI on behalf of Republic Services and the other Potentially Responsible Parties

(PRPs) for Operable Unit 1 (OU-1). The only range of dates provided for radioactive storm water

testing in the RI include 1995-1997 and 2016-2017 as detailed in section 4.12 – 4.12.2.27.

Institutional controls also failed when radioactive dirt was moved around with earth moving

equipment in what is now known as the Buffer Zone. EMSI detailed its concern about

radioactivity mobilizing due to unauthorized earth moving activity in a letter to Mr. Dan Wall

of the EPA on December 31, 1999. “Recent grading activities by others have resulted in removal of

stabilizing vegetative cover and disturbance of soil containing radionuclides on the Ford and

Crossroad properties. Removal of the vegetation and disturbance of the soil has resulted in a

potential for wind or water erosion of the soil and potential transport to unimpacted areas.” Note

that the RIM exposed by this activity in the mid-1990’s has not been remediated in the 22

years that have passed and remains in an unknown and unmonitored state! It was noted by

Herst & Associates, Inc. (Herst, 1999) that the disturbing of this soil "increased the potential for

windblown particles to exit the property" and the mounded material is "subject to erosion

potential due to runoff from precipitation.” This warning was given to the EPA in 1999, yet

radioactive stormwater testing was not conducted at the landfill again until 2016 according to

the RI.

7

Draft Remedial Investigation Addendum (June 16, 2017) https://semspub.epa.gov/work/07/30323745.pdf

Page 10


Furthermore, this material will become much more radioactive and bio-toxic in the near and distant

future 8 .

While we understand that no Remedy is going to be perfect, similar sites have been successfully and

safely cleaned to levels similar to the “Full Removal” Remedy (see Appendix C). While any

removal action carries risks, anything short of Full Removal of this hazard from the center of our

metropolitan area has the potential of a catastrophic event that could affect a large portion of the 2.8

Million people living here.

Our students and schools are affected too. Five (5) surrounding school districts have sent letters to

parents outlining their Emergency Preparedness Plans should there be an “event” at the landfill.

These plans include the possibility of extended Shelter-in-Place, during which parents will not be

allowed to pick up their children. One district suggests sending a supply of student’s medications to

be kept on hand in anticipation of such an event. See Appendix D.

5) Broad Community Support for Full Removal

Please see the numerous local governments, cities, and State and Federal legislators who have

called for Full Removal at the following link:

http://www.stlradwastelegacy.com/supporters/government/ Note that the City of Bridgeton’s City

Council, where this Superfund Site is located, has passed a lawful resolution calling for Full

Removal. Some of the officials and government bodies sited at this link are calling for moving

jurisdiction from EPA to the Army Corps of Engineers vs Full Removal; these statements and

resolutions were made in the spirit of expanding the current cleanup of FUSRAP sites in the St.

8

http://moenvironment.org/images/2013_11_21_RobertAlvarezWestLakeReport.pdf

Page 11


Louis area to include the West Lake Landfill with the understanding that transfer to FUSRAP would

most likely result in Full Removal.

5a) Is WLL and/or Bridgeton Landfill A FUSRAP Vicinity Property?

The West Lake Landfill qualifies as a Vicinity Property to HISS/FUTURA (Latty Avenue site) and

should not have been excluded from the current FUSRAP cleanup 9 . Also, based on the Federal

Facilities Agreement, it appears that any RIM found within the Bridgeton Landfill property line

(and it has been documented by EPA/PRPs to be there) would become the responsibility of

FUSRAP.

6) Timely Removal is Possible

The PRPs can afford to implement the Full Removal Remedy in less time than the artificial timeline

calculation in the FFS. This calculation erroneously holds the PRPs annual spending at the same

level independent of Remedy chosen. Obviously, this should not be tolerated by the EPA.

7) Safe Removal – Is Relocation Necessary?

We have noticed that the FFS does not include any costs for temporary or permanent relocation of

nearby residences or businesses. Are we to assume that the PRPs consider ALL evaluated

Remedies to be safe for our community? If not, shouldn’t these costs be included in the cost

estimates in the FFS? Also, our State and Federal legislators are being heavily lobbied by some of

the PRPs who are stating that Full Removal is not safe for those living or working nearby. Please

clarify this as it seems like it is not fair for them to have it both ways depending on what suits the

conversation at the moment.

8) Baseline Risk Assessment (BRA) Concerns

The baseline risk assessment doesn’t take into consideration various scenarios such as fires,

flooding, earthquakes, tornadoes or other ways for radioactivity to leave the landfill and impact

human health. On the other hand, the risks for remedial alternatives are significantly magnified to

account for uncertainty. Even though this may be “standard procedure,” it skews the risk

assessments so that various risk scenarios are considered in the remedial options whereas those risks

are not considered in the BRA.

9

From pdf page 7 of the Federal Facilities Agreement for St. Louis and Hazelwood FUSRAP sites, docket

VII-90-F-0005 moenvironment.org/files/1990_FedFacilitiesAgreement.pdf

Page 12


9) Key Inconsistency Between NRRB 2013 and Current RIA

Comparing the NRRB’s 2013 review10 with the data submitted for this review shows a 20 fold

difference in the peak Radium levels expected at this site if no action is taken, with the current RIA

being the lower of the two amounts … this raises serious concerns about the modeling, etc. that was

performed and we respectfully hope you will give this data close scrutiny.

On page 247, the RIA says:

“The expected increases in the Ra-226 levels in Areas 1 and 2 owing to decay of Th-230 over time

are graphically presented on Figure 7-16 and 7-17. Peak radium levels are expected to occur in

approximately 9,000 years at which time average Ra-226 activities are estimated to be 1344 pCi/g

in Area 1 and 1844 pCi/g in Area 2.”

The NRRB report from 2013 states:

“Based on the documents provided to the Board, it appears that there are potentially significant

amounts of RIM that are highly toxic (e.g., based on NRC estimates in the 1982 and 1988 reports,

radium up to 22,000 picoCuries per gram (pCi/g), bismuth-214 up to 19,000 pCi/g, and average

thorium-230 concentrations of 9,000 pCi/gr; the package at page 44 notes that the RI report

discussed thorium-230 at levels as high as 57,300 pCi/gr and that the highest gamma peak intensity

readings are at shallow depths). The FS states (page 84) that most of Area 2 contains RIM at levels

above 100 pCi/gr. The NRC reports also discuss how the toxicity of this RIM will continue to

increase over time: “Ra-226 activity will increase in time (for example, over the next 200 years, Ra-

226 activity will increase nine-fold over the present level). This increase in Ra-226 must be

considered in evaluating the long-term hazard posed by this radioactive material.” (1988 NRC

report, page 14).”

10) Underestimated Flood Risk

According to the latest Army Corps of Engineers inspection report dated February 3, 2015, the

primary Levee protecting the landfill from the waters of the Missouri River was found to have an

Inspection Rating of Minimally Acceptable. A recent FEMA flood map 11 assumes OU-1 is

protected from flooding on the north side by a railroad track that has not been inspected nor was

designed as a levee.

10

National Remedy Review Board Discussions Regarding the Remedy at the West Lake Landfill Superfund Site, February 28, 2013

11

http://fema.maps.arcgis.com/home/webmap/viewer.html?webmap=cbe088e7c8704464aa0fc34eb99e7f30&extent=-

90.46496139697318,38.76747818611529,-90.42582260302683,38.7785194006372

Page 13


Below is a table from a document prepared by Maggie Weng, a student at Washington University,

under guidance of her professor showing the percentage of the landfill that will be flooded under

various scenarios (see full study including data sources and analysis techniques in Appendix F).

Recurrence Interval

(years)

Stage of flood, including

height above NAVD88 (m)

Area in map below

flood elevation (km2)

17.4 136.966 21.96 44.02

100 139.02 231.769 51.63

300 140.459 234.84 61.95

500 141.1267 236.17 63.58

% landfill below

flood elevation

The 2008 ROD says, “Flood control measures at the Site should meet or exceed design standards

for a 500-year storm event under the assumption that the existing levee system is breached.” The

EPA accepted the PRPs’ claim that a 500 year flooding event would be easy and gradual. The PRPs

do not consider various flooding scenarios, including a breach in the levee that leads to torrent and

violent water movement due to a levee failure. The PRPs only assume what would happen if a levee

is overtopped. The FEMA flood maps are not applicable to a scenario that involved a breach in the

levee that sends torrent waters toward the West Lake Landfill, therefore this risk scenario is

incomplete. Unlike the below picture that was just water impacting farmland, a breach and massive

torrent of water moving toward the West Lake Landfill would likely include large debris objects

considering the surrounding area has been commercially developed.

Eroded farmland following the breach of the Birds Point-New Madrid Floodway

Photo credit: Laura Simon from the Southeast Missourian

Note: there is also a concern that the installation of a non-permeable cap over a significant acreage

at the site may contribute to flooding of Cowmire Creek and therefore, will add to the already

frequently occurring flooding of local roads and businesses in this area. Specifically, Cowmire

Creek is already handling additional runoff being directed from the Superfund Site’s Outfall #4,

which due to the removal of Outfall #6, now drains approximately 72.5 acres into the creek. Any

Remedy that includes a non- or semi-permeable cap on this Superfund Site needs to include a

detailed analysis of the impact the additional drainage will have on Cowmire Creek and the Railway

Embankment and surrounding areas, which are not built to handle this type of drainage. See

Appendix E for a detailed discussion of the flooding history and future risk of flooding.

Page 14


11) Short and Long-Term Seismic Risk

Evaluation of earthquake risks at the West Lake Landfill appears deficient. The CAG is greatly

concerned about the unlined landfill being in the alluvial floodplain of the Missouri River. The

landfill is susceptible to liquefaction in the event of a large earthquake. Using the Modified Mercalli

Intensity Scale applied to a 7.6 magnitude earthquake along the New Madrid Fault, St. Louis

County would experience, “Panel walls thrown out of frames; fall of walls, monuments, chimneys;

sand and mud ejected; drivers of autos disturbed. 12 ” It’s not clear to the CAG how any cap-andleave

design will prevent the ejection of sand, mud, radioactive and non-radioactive contaminants of

concern at the landfill. Further, the liquefaction of the alluvium will cause slumping and

mobilization of the radioactive contamination into the groundwater, which will make it significantly

more difficult and expensive to remove in the future.

The DNR estimates the probability of a repeat of the 1811-1812 (magnitude 7.5-8.0) earthquakes is

7-10%. More from the DNR:

“The NMSZ [New Madrid Seismic Zone] appears to be about 30 years overdue for a

magnitude 6.3 quake because the last quake of this size occurred 100 hundred years ago at

Charleston, Missouri; on Oct. 31, 1895 (it was a magnitude 6.7). A magnitude 6.3 quake

near Lepanto, Arkansas, on Jan. 5, 1843, was the next prior earthquake of this magnitude.

About 75 percent of the estimated recurrence time for a magnitude 7.6 earthquake has

elapsed since the last quake of this size occurred in 1812. 13 ”

Further, in 2014 the United States Geological Survey (USGS) and various universities discovered a

new seismically active zone closer to the West Lake Landfill, called the St. Genevieve Seismic

Zone. The severity of impacts in the St. Louis region from a 7.6 magnitude earthquake that

originates in St. Genevieve would likely be greater than a 7.6 magnitude earthquake that originates

near the New Madrid fault.

From the Indiana University report’s author Michael Hamburger “It’s an underappreciated zone of

seismic activity that has potential implications for St. Louis and other populated areas in eastern

Missouri and Southwestern Illinois,” he said. “It’s comparable to the Wabash Valley Seismic Zone

in western Indiana, which is capable of producing moderate-sized earthquakes every few decades

and perhaps has the potential for larger earthquakes. 14 ”

12) Air Contaminates

Exposure pathways focus on the inhalation of air or ingestion of soils from the landfill. The risk of

inhalation from air should include smoke that can carry radionuclides as well as toxic particles and

gases considering that several surface fires have occurred at the landfill since the radioactive wastes

were dumped. Reported fires that the CAG is aware of include the following:

− 2015: Surface fire in grass area near OU-1 Area 1

− 2013: South quarry surface fire along Old Boenker Rd.

12

Facts About the New Madrid Seismic Zone, Missouri Department of Natural Resources. Accessed Nov. 2017.

https://dnr.mo.gov/geology/geosrv/geores/techbulletin1.htm

13

Facts About the New Madrid Seismic Zone, Missouri Department of Natural Resources. Accessed Nov. 2017.

https://dnr.mo.gov/geology/geosrv/geores/techbulletin1.htm

14

IU Geologists Identify New Seismic Zone Near Illinois-Missouri Border, Indiana University. Accessed Oct. 2017:

http://archive.news.indiana.edu/releases/iu/2014/11/ste-geneview-seismic-zone.shtml

Page 15





2010: South quarry SSE

1992: North quarry surface fire

1988: Methane fire along St. Charles Rock Rd. as reported in the Post-Dispatch

13) Air Traffic Safety

Aviation safety risks from bird activity at the landfill is a serious concern that is sensationalized by

the PRPs. Republic Services commissioned a vector control report for the Forward Landfill that it

operates within 10,000 feet of an airport in California. In 2013, the Forward Landfill, which is

owned by Republic Services, submitted a report to the State of California demonstrating “complete

effectiveness” of its gull control program at the landfill. The Forward Landfill is an active landfill in

San Joaquin County, California, that is located about 2,000 feet closer to the Stockton Metropolitan

Airport than West Lake Landfill is from the St. Louis Lambert International Airport. According to

the study, “the control program [at the Forward Landfill] continued to be virtually completely

effective at preventing gulls from feeding at, or otherwise using, the Forward Landfill.” If Republic

Services can continue to operate an active landfill near an airport with a “virtually completely

effective” gull control program for the duration of the life of the landfill, then surely it can

implement an effective bird control program at the West Lake Landfill during the time that it would

take to remove the radioactive wastes.

Bird strikes should be a serious concern during the removal remedy at the West Lake Landfill for

the safety of the community and those who fly in and out of St. Louis, but it does not have to deter

the removal of the radioactive waste at the West Lake Landfill. The EPA and Republic Services

have shown that there are ways to manage bird populations around landfills during removal; they

cannot continue to use it as an excuse for keeping the waste in an unlined landfill in the Missouri

River floodplain in the middle if a major American metropolitan area.

Page 16


Republic Services issued a report that concludes that the landfill in California should continue

to operate because it has “demonstrated the continued complete effectiveness of the gull

control program,” at the Forward Landfill 15 .

14) Conceptual Site Model (CSM) Concern

The CSM in the RI is a minimal snapshot in time from a few tests meant to extrapolate offsite

pathways for exposure to the surrounding community. This CSM would have more credibility had it

included historic context and extreme events, including fires and flooding. The CSM continues the

EPA’s stance that West Lake is not an “imminent threat,” which is what the agency said following

the surface fire near OU-1 Area 1 in 2015. The EPA insists the West Lake Landfill is not an

imminent threat to the people around the landfill, but as long as the radioactivity stays at the

landfill, it will be an imminent threat.

It was wrong for the EPA to disregard groundwater concerns as it relates to RIM in OU-1 and it’s

wrong for the EPA to disregard groundwater concerns again. The conceptual site model in the draft

RI details the inadequacy of groundwater characterization.

15) Nightmare Scenario

The CAG is not suggesting this is the only scenario that could result in the release of radioactive

materials into our community, nor are we suggesting that there would be an explosion that would

lead to the mobilization of any RIM left behind; we submit the following scenario for your

consideration. Should an earthquake bring radioactivity to the surface of this landfill followed by a

surface fire, radioactivity could be mobilized. It’s not a stretch to imagine that a surface fire could

break out following an earthquake. A strong earthquake could lead to liquefaction under the landfill.

That would destabilize the site as the alluvium liquefies, which will lead to slumping and

deterioration of the landfill gas management infrastructure. It’s worth noting in a worst case

scenario that first responders will be focused on rescue and preservation of human life and not

on containment at the landfill.

15

Demonstration of the Continued Effectiveness of the Bird Control Program at the Forward Landfill, Manteca, California – 2012-

2013. Prepared by LGL Limited Environmental Research Associates for Republic Services, Inc. (2013)

Page 17


Appendix A – Technical Concerns Letter to Mr. Kelly

Mr. Albert Kelly

EPA Superfund Task Force

November 6, 2017

Mr. Kelly

It is our understanding that you are meeting with Administrator Pruitt this week. On behalf of our

community, the CAG and Just Moms StL would like to highlight some inconsistencies and concerns

regarding the current FFS for West Lake Landfill that may inform your actions and

recommendations moving forward.

A. Despite the PRPs claim that “All of the following remedial alternatives … meet EPA’s

criteria for overall protection of human health and the environment.” 1 , we believe that this

conclusion cannot be reached based on a number of key omissions in the FFS analysis as

pointed out by Region 7 in their Comment Letter dated October 26, 2017:

1. Not included: “is an evaluation of the potential risk that an SSE could cause a release

of particulates from OU1or an estimate of the resulting risk should a release occur.” 2

2. Not included: Presence of “petroleum soaked soils” mixed with RIM in Area 1 3 and

the risk of meeting with a SSE

3. Not included: Reasonable Maximum Exposure (RME) to evaluate exposures to

residents or workers. These are missing. Averages were used instead of RME. 4

4. Questionable Parameters Used in Modeling: Reductions in the volume of gases in

the soils used in the modeling are suspected of generating an underestimate of

potential radon releases. 5

5. The risks identified by the ORD report 6 have not been fully addressed or nullified:

The ORD report states that even a properly maintained Cap would not be protective

of our community.

6. Multi-agencies errors/omissions: Recent FEMA flood map 7 assumes this area is

protected from flooding by Cowmire Creek on the north side by a railroad track that

has not been inspected nor was designed as a levee. Note: there is also a concern

that the installation of a non-permeable cap over a significant acreage at the site may

contribute to flooding of this creek and therefore, adding to the already occurring

flooding of local roads and businesses in this area.

B. Evaluation of earthquake risks at the West Lake Landfill appears deficient:

1

FFS August 25, 2017, Executive Summary, Page 4, #1

2

US EPA Region 7 October 26, 2017 Comment Letter, Page 1, #3

3

EMSI February 25, 1997 Superfund Document 40056510

4

US EPA Region 7 October 26, 2017 Comment Letter Page8, #50, #56

5

US EPA Region 7 October 26, 2017 Comment Letter, Page 5-6, #33-#37

6 EPA Office of Research and Development, National Risk Management Research Laboratory, Engineering and Technical Support

Center - March 28, 2017

7

http://fema.maps.arcgis.com/home/webmap/viewer.html?webmap=cbe088e7c8704464aa0fc34eb99e7f30&extent=-

90.46496139697318,38.76747818611529,-90.42582260302683,38.7785194006372

Page 18


The MDNR estimates the probability of a repeat of the 1811-1812 (magnitude 7.5-8.0)

earthquake is 7-10%. According to MDNR: About 75 percent of the estimated

reoccurrence time for a magnitude 7.6 earthquake has elapsed since the last quake of this

size occurred in 1812.” 8 We must assume that should an earthquake hit this area, our First

Responders would be focused on rescue and recovery, and not on tracking and cleaning

Radon and Radioactive particulates ejected from West Lake Landfill as the soils and cap

undergo liquefaction. Therefore, it is not clear to the CAG how the cap-and-leave design

will prevent the ejection of sand, mud, radioactive and non-radioactive contaminants of

concern at the landfill, as well as preventing slumping that may occur, deteriorating the gas

management system that could lead to a surface fire that could spread radioactive

particulates for miles. Further, the liquefaction will allow mobilization of the radioactive

contamination into the groundwater, which will make it significantly more difficult and

expensive to remove in the future. We therefore respectfully recommend the Full Removal

Remedy be selected.

C. Full Removal, though more expensive on the front end, has been shown at other sites to

be the most cost effective and protective of human health.

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 9 . 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 10 .” EPA Region 8 eventually determined that a decision

reducing the Operation & Maintenance and reliance on institutional controls would result in

the greatest overall protectiveness.

D. DOE Responsibility and Rules:

The radioactivity dumped at the West Lake Landfill was referenced by the NRC (now DOE)

as being licensed material in its 1995 letter to the EPA. Therefore, the Radioactive Waste

Management Manual (RWMM) should be applicable at the West Lake Landfill. The

RWMM states, “The requirements of this Manual apply to all new and existing DOE

radioactive waste management facilities, operations, and activities.” The DOE manual

clearly states that low-level radioactive waste should not be located in a floodplain,

tectonically active area, or in the zone of water table fluctuation. West Lake Landfill’s

location fails to meet this standard on all accounts and no remedy other than Full Removal

can comply.

8

Facts About the New Madrid Seismic Zone, Missouri Department of Natural Resources. Accessed Nov. 2017.

https://dnr.mo.gov/geology/geosrv/geores/techbulletin1.htm

9

Shattuck Record of Decision Amendment (2000) https://semspub.epa.gov/work/08/301191.pdf

10

Responsiveness Summary for the Proposed Plan for an Amendment to the Record of Decision, Denver Radium Operable Unit #8,

Shattuck Site, Executive Summary (2000)

Page 19


E. Cost Comparison:

Past FS documents have shown a range of costs for the alternatives. We respectfully submit

the chart below which shows the Full Excavation having a range of cost between $443M and

$710M. This particular Remedy has a 60% Contingency adder vs. the Cap Only Remedy

which has a 30% Contingency adder. If the Cap only Remedy had the same adder as Full

Excavation, its cost would have been $92M, thus closing the cost gap.

Per FFS Appendix K

Preliminary Estimated

Capital Costs

FFS ROD

Remedy

Alternative

FFS UMTRCA Cap

Remedy

Alternative

Partial Excavation

(52.9 pCi/g)

Remedy

Alternative

1,000 pCi/g

Remedy

Alternative

Full Excavation

(7.9 pCi/g)

Remedy

Alternative

Cost Range

Cost without Contingency $57,750,000 $68,500,000 $173,030,000 $221,850,000 $443,180,000

Cost with Contingency $75,000,000 $96,000,000 $280,000,000 $374,000,000 $710,000,000

Contigency Uplift Percent 30% 40% 62% 69% 60%

F. Time to Implement Remedy:

We find it curious that the annual expenditure by the PRPs is the same for each Remedy.

We find this to be inconsistent with EPA Region 7 prior statements that there is not a limit

to the amount of expense the PRPs are expected to bear per year. We have found that the

PRPs have not been behaving as good neighbors, causing many delays in the resolution of

this site. Their stall tactics with EPA, the State of Missouri, and their attacks on our efforts

by creating and funding a “grass roots” movement against remediation should not be

rewarded with low annual cash outlays.

G. Air Traffic Safety:

Republic Services has successfully controlled birds at similarly situated sites, including an

operational landfill within 10,000 feet of an airport in CA 11

After 27 years of waiting for the NRC/AEC/DOE to address this site, and another 27 years waiting

for Superfund to address this site, this community deserves the safest and most permanent solution

for this site; a solution that takes into consideration our future health and economic success. Any

solution which exposes us to risk from off-site migration of waste be it natural or man-made

disaster, any solution which is based in any part on incomplete skewed data, or any solution which

requires 1000 years of monitoring and maintenance is unacceptable to this community.

We hope you found this memo helpful and we look forward to working with you in the future to

bring a safe and permanent Remedy to the West Lake Landfill / Bridgeton Landfill Complex.

11

Demonstration of the Continued Effectiveness of the Bird Control Program at the Forward Landfill, Manteca, California – 2012-

2013. Prepared by LGL Limited Environmental Research Associates for Republic Services, Inc. (2013)

http://moenvironment.org/files/FLE_DSEIR_APPX_C.pdf

Page 20


Sincerely,

Harvey

Dawn

Harvey Ferdman

Dawn Chapman

Chair, West Lake Landfill / Bridgeton Landfill CAG Just Moms StL

314-469-0595 / 314-761-5100 (cell) 314-566-9762 (cell)

Page 21


Appendix B – Economic Impact – Councilman Randy Hein

Appendix C – Full Removal Safety References

Page 22


Removal is the safest long-term option under consideration. While Superfund considers remedies

based on a 1,000 year scenario, the remedy at West Lake needs to take into consideration a 75,000

year scenario due to the half-life of Thorium 230 [75,690±230 years (2σ) 27 ] and radioactive

ingrowth of the Radium becoming more radioactive and bio-toxic over the next 9000 years along

with other radiological materials at the landfill 28

The CAG has identified various federal authorizations for radioactive remediation at sites in

Missouri and throughout the country. EPA decision makers should recognize that radioactive

removal has been done safely in various different environments throughout Missouri. The CAG is

not aware of a site where the primary remedial decision was to leave the radioactivity in an unlined

area susceptible to groundwater contamination.

Weldon Spring, Missouri

The Weldon Spring remedial action plan included the removal of bulk waste from a quarry;

dismantle buildings, four Raffinate pits, two ponds, and two former dump areas. The Weldon

Spring Site Remedial Action Work Plan (WSSRAWP) for the Chemical Plant Area of the

Weldon Spring Site detailed the safety procedures used during the removal and movement of

radioactive material before it was placed in the final disposal cell, which included a liner to keep

the radioactivity from impacting the groundwater. 29 The Weldon Spring demolition and

disposal cell construction was completed safely by the Department of Energy (DOE) one

27

Chemical Geology Volume 169, Issues 1–2, 15 August 2000, Pages 17-33

http://www.sciencedirect.com/science/article/pii/S0009254199001576

28

http://moenvironment.org/images/2013_11_21_RobertAlvarezWestLakeReport.pdf Page 8.

29

Remedial Action Work Plan for the Chemical Plant Area of the Weldon Spring Site (November 2005)

https://www.lm.doe.gov/Weldon/DOE_OR_21548_529_R_0.pdf

Page 23


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

Page 24


Hematite, MissouriThe Nuclear Regulatory Commission (NRC) authorized the removal and offsite

transportation of low-level radioactive material at the nuclear fuel assembly plant in Hematite. The

CAG references the Westinghouse Waste Management & Transportation Plan i as an example of

how the government has approved radioactive removal in Missouri 37 .

Fernald, Ohio

This site transported more waste offsite than any other DOE site in its history. The DOE was

able to do this without a single accident in conjunction with the Building Trades. It’s worth

noting the Building Trades were vital in the cleanup of the Weldon Spring site in Missouri,

which means the St. Louis area has the skilled workforce needed to remove the radioactive

wastes at the West Lake Landfill. A few highlights from the DOE at Fernald 38 :



On June 15, [2005] the last train carrying Waste Pit material left Fernald marking an end to

the largest waste shipping campaign in DOE history. On April 26, 1999 the first unit train of

waste departed for Envirocare. In all, 154 shipments were needed to remove nearly 1 million

tons of radioactive waste. If strung end-to-end, the train cars used for this campaign would

stretch 87 miles. Building Trades personnel worked without a single OSHA recordable

accident while the project worked nearly 1 million hours without a lost-time accident.

October 29, 2006 Fluor Fernald declares Completion ahead of the Dec. 31, 2006 target date

and approximately $70 million under the established $1.911 billion target cost. The

workforce had fewer injuries than ever including an OSHA recordable rate of .76!

Worker Risk in EPA Feasibility Studies

The CAG supports the safe removal of the radioactive wastes, which includes safety to our

community and safety for the workers. We identified federal authorizations for various radioactive

remediation activities at several sites in this section. We did not find detailed risk scenarios for

workers based on the proposed remedies in our review of the feasibility studies and work plans for

these sites. We are, however, aware of other sites that have safely removed radioactive and toxic

materials without incident as shown below:

37

Westinghouse Waste Management & Transportation Guidance for the Hematite Decommissioning Project.

https://www.nrc.gov/docs/ML1103/ML110330370.pdf

38

DOE Fernald Closure Project Cleanup Highlights:

https://www.lm.doe.gov/land/sites/oh/fernald_orig/cleanup/highlights/high2.htm

Page 25


Final Feasibility Study Report

BoRit Asbestos Superfund Site, Operable Unit 1, Ambler, PA

November 18, 2016

Does not contain any numeric indicator of risk for remedial worker and includes qualitative

statements like:

This disturbance of contaminated waste, soil, and Reservoir sediment could also pose short-term

risks to workers from inhalation of asbestos fibers during implementation of the remedy. Safety

measures such as dust suppression, personal protective equipment (PPE), and establishment of

work zones would protect workers during implementation. Other potential impacts to workers

would be mitigated through adherence to safety plans and standard operating procedures.

Feasibility Study Report (Revison 01)

Donna Reservoir and Canal System

Donna , Hidalgo County, Texas

July 2016

Does not contain any numeric indicator of risk for remedial workers and includes qualitative

statements like:

Short term risks are elevated in Alternative 3. The community is affected by an increase in

traffic caused by the transportation of equipment and material. Additionally, dust may be

produced during construction and transportation activities, but can be mitigated through

standard construction practices.

Revised Draft Feasibility Study

Peterson/Puritan, Inc. Superfund Site – Operable

Unit 2

Cumberland and Lincoln, Rhode Island

July 2014

Does not contain any numeric indicator of risk for remedial workers and includes qualitative

statements like:

Implementation of this alternative would potentially result in short-term exposure risks to the

community, workers, or the environment during soil removal and installation of the RCRA

Subtitle C cap; these potential risks would be managed with engineering controls, access

restrictions, and worker training.

FINAL RADIOLOGICAL ADDENDUM TO THE REVISED FEASIBILITY STUDY

REPORT FOR PARCEL C

PARCEL C, HUNTERS POINT SHIPYARD

SAN FRANCISCO, CALIFORNIA

June 20, 2008

Does not contain any numeric indicator of risk for remedial workers and includes tables with

indicators of short-term risk as “good” or “very good.” It also has tables with circles partially

blacked out to indicate levels of short-term risk. The FS also includes qualitative statements like:

Workers would be protected during ROC remediation from Parcel C radiologically-impacted

sites by implementing containment controls such as dust suppression and following health and

safety protocols, including personal protective equipment and decontamination procedures.

Page 26


Page 27


Appendix D – School Emergency Preparedness Letters

Page 28


Page 29


Page 30


Page 31


Page 32


Appendix E - Flood Risk and a History of Flooding

A look into the past of this site shows a long history of flooding of this low-lying river basin. In

this look back, three years stand out because of the extent of flooding and the impact it has had on

our community and environment.

This Superfund site sits within the City of Bridgeton, Missouri and is bordered on the east by

Highway 270, the south by Highway 70, the north by a railway embankment, and the west by the

Earth City Levee and the Missouri River. Directly linked to this site is Cowmire Creek and its

tributaries which form a major stream system.

The Earth City Levee was built in 1972 to withstand a 500 year flood. In the flood of 1993, the

waters of the Missouri River came within 1 foot of topping it. Note that many levees have been

added upstream since then which will likely increase the water levels reaching this levee.

According to the latest Army Corps of Engineers inspection report dated February 3, 2015,

this Levee was found to have an Inspection Rating of Minimally Acceptable.

Page 33


This is concerning when one looks at the aerial images of just how close the communities next to

and around this Superfund site came to catastrophe!

We will never know the impact this flood would have had on the Earth City Levee had the

Monarch Levee upstream not collapsed or if the abandoned railway embankment on the St.

Charles side of the river had not also collapsed.

The Norfolk and Western Railway Embankment was built circa 1932 as that is when the bridge

across the Missouri River to St. Charles was completed. The image below shows the levee system

around the Superfund site.

Page 34


On the other side of the railway embankment is an area that is part of the Missouri Bottoms Levee

District (Agricultural Levee build for smaller than 100-year flood events) which has consistently

flooded with heavy rain events. When looking at the Railway Embankment and the MO

Bottom Levee area, no flood gates exist to keep flood waters out of the Earth City Levee

District if water over tops the roads in the area.

No inspection reports could be found for the Railway Embankment. Also note that Cowmire Creek

lies just East of this Embankment on both the North and South side of the Embankment. Per a flood

insurance report, “The excess amount of waterflow leaves Cowmire Creek by flowing southwest

across Route 115 (St. Charles Rock Rd) and the High Stages which produce this overflow are

created by the undersized culvert through the Norfolk and Western Railroad Embankment”.

http://environmentalarchives.com/doc/STL/1982-08%20-

%20City%20of%20Bridgeton,%20Missouri%20-%20Flood%20Insurance%20Study.pdf

We call your attention to studies done by the Army Corp of Engineers focused on downstream

flooding that neglected to take into consideration localized flood impact due to heavy rains, such as

the 9.18 inches which fell on the St. Louis Region Dec 26-28, 2015: 4.87 in. (Dec 26), 1.72 in (Dec

Page 35


27), 2.59 in. (Dec 28). The images below show the strong water flow from the landfill site to a

drainage ditch during this time.

A GLIMPSE OF THE FUTURE?

What impact will there be to the environment and the community in the future due to possible

building of a warehouse district in this area changing the landscape of the flood plan to the north of

the landfill, climate change and/or a CAP at the Superfund Site?

In two articles recently published in the St. Louis Post Dispatch, there are two proposals in two

cities that might have an impact on either side of the Earth City Levee District.

Article 1: The City of Hazelwood is considering a proposal to build a new industrial park, one mile

north of the Norfolk & Western Railway Embankment and along Cowmire Creek. It is proposed to

raise this park out of the flood prone plain. What effects will that have on the land between the

Embankment, Cowmire Creek and this proposed development? Will it cause Cowmire Creek to

back up into the landfill area? (http://www.stltoday.com/business/local/northpoint-considers-new-

hazelwood-industrial-park-northeast-of-outlet-mall/article_4e7d2bb7-db27-536c-aa63-

81707fb1715d.html#tracking-source=home-latest-1)

Article 2: The City of Maryland Heights is backing a deal to build the new St. Louis Blues

(Hockey) practice Facility in land along the road into the Hollywood Casino Drive, this land sits

between the Howards Bend Levee system (property considered part of Howards Bend) and the

Riverport Levee District. It is unknown what impact this facility will have as they will have to raise

the practice facility and parking out of the current low-lying flood plain?

(http://www.stltoday.com/business/local/maryland-heights-backs-new-blues-practice-facility-near-

casino/article_40d895b1-465a-5eb2-b94d-

93f6cef72e61.html?utm_medium=social&utm_source=facebook&utm_campaign=user-share)

An additional article discusses flaws to the FEMA Flood Maps

(http://www.slate.com/articles/health_and_science/science/2017/09/here_s_why_fema_s_flood_ma

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ps_are_so_terrible.html) as they do not take into account climate change, what impact would an

updated FEMA flood map show to the 1% Flood Hazard that is currently listed for Cowmire Creek

which is already handling additional runoff being directed from the Superfund Site’s Outfall #4

(which drains into Cowmire Creek), which due to the removal of Outfall #6 now drains

approximately 72.5 acres into the creek. If the Remedy selected is to CAP in Place on this

Superfund Site, what impact will the additional drainage have on Cowmire Creek, the Railway

Embankment and surrounding areas, which are not built to handle this type of drainage.

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Appendix F – Flood Stage Elevations at West Lake Landfill

Maggie Weng

margaret.weng@wustl.edu

Prof. Nandini Kar

12/8/17

An Investigation of Flood Stage Elevations at West Lake Landfill

Abstract

For this project, I used ArcGIS and water data for the Missouri River at St. Charles from the

National Weather Service and the U.S. Geological Survey to calculate the stage of a 100, 300, and

500 year flood. I then applied these measurements to a DEM of the Bridgeton area to analyze the

flood risk of the West Lake Landfill in each of these scenarios—i.e., whether or not the landfill’s

elevation was below the stage of the flood. I then compared these measurements to the known stage

of recent flooding from May 5, 2017, which I calculated to be a 17.4-year flood. I also calculated

the approximate area below flood stage in each scenario, and the percentage of the landfill area

below flood stage (if any). From this analysis, I concluded that the West Lake Landfill’s elevation is

at risk for flooding at all measured stages, and that further steps must be taken to secure the site in

order to prevent movement of radioactive particles during a flood event.

Introduction

The West Lake Landfill is a Superfund site located in Bridgeton, Missouri about 20 minutes

north of Washington University. Waste from uranium ore processing for the Manhattan Project was

illegally dumped there by the Cotter Corporation in 1973, disguised as “clean fill dirt”. Since that

time, the radioactive material has been unconfined within the landfill, which is an unlined limestone

quarry with groundwater movement common in karst terrain. The EPA gained jurisdiction of the

site in 1990, declaring it a Superfund site, but has not yet remediated it—a record of decision for the

site is due this coming January. Furthermore, the Bridgeton Landfill, which was dug after

deposition of radioactive material but lies in the same topographic area, currently harbors an

underground fire (termed a subsurface smoldering event) that is moving toward the area of known

radioactive material. If the radioactive material were to combust, it would cause a public health

crisis for the entire St. Louis county if not beyond. The closest residential areas to West Lake are

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about 0.5 miles from the landfill site, and residents in the area suffer from unusually high rates of

cancer and autoimmune disease.

The extent of radioactive material at West Lake is not well characterized. The EPA has

determined two known contaminated areas, OU1 and OU2, but has not tested offsite nor at the

adjoining Bridgeton Landfill. An investigation of groundwater, termed OU3, is pending, as

pizeometers monitored by the USGS at the site have detected radioactive contamination in the

landfill area. Another concern is radioactive runoff into storm water, as waste is not well contained

and could potentially be captured as runoff. The EPA has instituted a Stormwater Monitoring

Program but as of yet has not come up with a solution to this issue. Therefore, water is of great

importance to the issue of the landfill as a method of transport for radioactive material.

Furthermore, the West Lake Landfill is located in the floodplain for the Missouri River.

Contention has been expressed over where, exactly, the landfill lies in the floodplain; investigation

by EPA and the landfill’s owner (Republic Services) have determined that the landfill does not lie

in the 500-year floodplain, but adjoining properties do. However, nearby residents are concerned

that the landfill could become inundated by a flood due to its low elevation, and the combination of

groundwater and surface water movement associated with flood conditions could prove disastrous

for radioactive material movement. Therefore, I decided to investigate the potential for flooding at

West Lake Landfill by characterizing the flood stages of a 100, 300, and 500-year flood and

determining if the landfill lay above or below the height of the flood. I also compared this data to a

known flood from May 5 th , 2017, which I calculated to be a 17.4 year flood, for context.

Methods

First, I calculated the stage of a 100, 300, and 500-year flood. To do this, I used historical

crest data of the Missouri River at St. Charles using the National Weather Services’ database. These

historical crests contained flood stages ranked by magnitude back to 1844. I translated the data from

feet to meters and used this to calculate recurrence interval. I then created a plot of recurrence

interval vs. flood magnitude, which I graphed on logarithmic axes, and fitted a best fit curve. I used

this best fit curve equation to determine the stage of a 500, 300, and 100 year flood by plugging this

recurrence interval in. I found that the stage of a 100-year flood was 12.99m, a 300-year flood was

14.433 m, and a 500-year flood was 15.1007 m. I then added the gauge height above NAVD88

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(126.026m), which was used by both the NWS and the DEM I downloaded, in order to apply these

calculations to the topography.

I then used my DEM of the Bridgeton area, which I had identified from a larger DEM of

eastern Missouri. On this I found the location of the West Lake landfill using coordinates and

double-checking with a basemap, which I outlined in purple. I created a conditional raster in

ArcGIS for each of the flood stages to determine what would be inundated, in which values of the

DEM below the cutoff elevation were termed ‘0’ and values above the cutoff elevation were termed

‘1’. I calculated the inundated area within each of these conditional rasters using the knowledge that

each cell of the DEM is 30x30m, and finding the number of cells given a ‘0’ in the raster properties.

I also found the approximate percentage of the landfill inundated. First, I converted the

outline of the West Lake Landfill area I’d drawn into a feature class. I then used Zonal Statistics, to

count the total number of cells in the landfill area (given as ‘Count’). The “SUM” output gave the

number of cells above the flood elevation (these cells were given a value of 1) since it added

together the values of all the cells within the polygon, which were either 0 or 1. By subtracting the

SUM from the total number of cells in the West Lake area, I was able to find the number of cells

inundated, and then the percent of the landfill inundated by the equation below:

% landfill inundated =

# pixels below elevation

total # pixels in area × 100

However, I am unsure of the accuracy of my results in this section as they do not seem to

visually reflect the findings on my maps.

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River stage (m)

Results:

100

Flood Stage and Recurrence Interval in the

Missouri River at St. Charles

10

y = 1.3063ln(x) + 6.9826

R² = 0.8906

1

1 10 100

Recurrence Interval (years)

Figure 1: Above is my graph of flood interval vs. river stage, including the equation that I used to

find the stage of a 100, 300, and 500 year flood.

I determined that the West Lake Landfill is at risk for inundation in all four flood scenarios.

The landfill is partially below elevation for a 100, 300, and 500 year flood, with surprisingly not

much variance in coverage between the three. Even during the 17.4-year flood, West Lake stood

right on the boundary of the inundation zone. This surprised me because I don’t believe that the

West Lake Landfill was inundated or majorly threatened during the 17.4 year flood. This lead me to

conclude that the topography of Bridgeton does have a significant affect on countering the

progression of floodwaters, despite the potential for inundation due to landfill elevation.

Figure 2: Below is a table of area on the map below flood elevation in each of the flood

scenarios, and the percentage of the landfill inundated in each situation:

Recurrence Interval

(years)

Stage of flood, including

height above NAVD88 (m)

Area in map below

flood elevation (km 2 )

17.4 136.966 21.96 44.02

100 139.02 231.769 51.63

300 140.459 234.84 61.95

500 141.1267 236.17 63.58

% landfill below

flood elevation

Figures 3-6: Below are maps created on ArcGIS showing area below flood elevation for each of the

four scenarios:

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Figure 3

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Figure 4

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Figure 5

Discussion and Conclusion

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I was surprised by the proportion of the landfill below flood elevation in each of the

scenarios. I am a bit confused by the landfill percentage calculations as I believe the way I used

Zonal Statistics was right, however the percentages seem to be larger than what is visually apparent

on the map. I included the results anyway instead of scrapping the data because I wanted to display

my process, however I am unsure of the soundness of these results.

I was also surprised by how little the area under flood elevation changed between the 100,

300, and 500 year floods. This suggests that the elevation of the Bridgeton area is relatively low,

and at risk for inundation for a large range of floods: the only reason why it is not continuously

inundated is due to human engineering, topography not visible on the 30x30m DEM, or other

controls not factored in to my analysis. What we do know is that the West Lake Landfill lies on low

ground, below the elevation of high flooding stages, in the floodplain of the Missouri River. This is

a cause for awareness and concern when it comes to building flood prevention infrastructure, and

should be a call to secure radiological material so that it is less likely to be captured by floodwaters

or runoff.

My project did have some limitations. First, as mentioned above, the resolution of the DEM

was not high enough to accurately factor in the topography of Bridegton, which likely affects flood

paths. Second, to calculate flood stage I used only one gauging station: the Missouri River at St.

Charles. While this is accurate for areas close to St. Charles, such as the West Lake Landfill, other

portions of the map further from the landfill may be less accurate. If I were to study the flood reach

along more of the Missouri River, I would use more gauging stations since the river’s stage would

likely change downstream and upstream.

Finally, more analysis would be useful in order to understand the effects and risks of

flooding of the Missouri River at the West Lake Landfill. Understanding the sediment capacity of

such a flood, for example, could help one understand the risk of radioactive mass transport

downstream. Understanding the behavior of groundwater during large flood events is also crucial:

even if the landfill itself is not inundated by floodwaters, the groundwater may be behaving in ways

that must be safeguarded against to prevent further radioactive groundwater contamination.

Unfortunately, groundwater movement even during non-flood circumstances is poorly understood at

West Lake. The EPA has recommended a study of groundwater at the site, termed OU3, but as of

this writing the project has not yet been completed.

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The West Lake Landfill is a complicated, dynamic, and multifaceted environmental issue.

Despite 27 years of study, many aspects of its contamination are poorly understood, including basic

questions such as: what is the extent of radioactive material and, what is the rate of offsite

contamination? Despite the assertion that the West Lake Landfill does not lie in the 500-year

floodplain, my map demonstrates that parts of the landfill lie under flood stage elevation for 100,

300, and 500 year flood events. I am unsure how floodplain extent was officially determined, but I

recommend that precautions be taken to secure the landfill against flooding events since it does lie

at a low enough elevation to be inundated. I hope that my project helps further the understanding of

one aspect of this site, and raises awareness of the potential flood risk at the West Lake Landfill.

Works Cited

Just Moms STL: St. Louis Rad Waste Legacy. (2017). Just Moms STL, 2012,

stlradwastelegacy.com. Accessed 7 December 2017.

National Weather Service (2017). Missouri River at St. Charles [Advanced Hydrologic Prediction

Service]. Retrieved from http://water.weather.gov/ahps2/hydrograph.php?wfo=lsx&gage=sclm7.

U.S. Geological Survey. (2016). USGS NED 1 arc-second n39w091 1 x 1 degree IMG 2016

[National Elevation Dataset]. Retrieved from https://nationalmap.gov/elevation.html.

West Lake Landfill—Additional Details About Site Status, June 2017”. (2017). Environmental

Protection Agency, www.epa.gov/mo/west-lake-landfill-additional-details-about-site-status-june-

2017. Accessed 7 December 2017.

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