West Lake CAG NRRB Submission REVISED ADDENDUM January 4 2018

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
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