West Lake CAG NRRB Submission REVISED ADDENDUM January 4 2018

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
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