West Lake CAG NRRB Submission REVISED ADDENDUM January 4 2018

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