West Lake CAG NRRB Submission REVISED ADDENDUM January 4 2018

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
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