CAG Board Comments on Proposed Remedy for West Lake Landfill April 18 2018

BOARD COMMENTS ON PROPOSED REMEDY FOR WEST LAKE LANDFILL 

April 18, 2018 

Introduction: The Community Advisory Group (<strong>CAG</strong>) submits the following comments and we are 

including a copy of our submission to the NRRB as part of our public comment in response to the 

Environmental Protection Agency’s (EPA) public comment period for its Proposed Remedy at the West 

Lake Landfill Operable Unit 1 (OU-1). 

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

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

thoughts and concerns about the Proposed Remedy for 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. 

We strongly believe that any Remedy should include the following modifications and considerations. 

Modifications: 

1. Relocation: 

It is important the EPA to include the Effects of Error on any Remedy for this site. Therefore, 

any Remedy MUST include relocation of residents living within approximately one (1) mile of the 

site who request relocation. 

Justification: Although we try our best to engineer safety into our human endeavors, time and 

time again we are reminded of the stark reality that we are fallible: the pedestrian bridge in 

Florida that fell in March 2018 and crushed cars and killed people, the I-75 bridge in Ohio that 

fell in 2015 without warning, the I-35 Bridge collapse in 2007 that killed 13 and injured 145, our 

Space Shuttle that blew up with the unfortunate loss of lives. Need we remind you that the 

uranium ore that resulted in this RIM was ground to the consistency of confectionary sugar and 

has a history of becoming airborne? One shovel-full of this material, accidently carried by the 

wind, can inflict unnecessary harm on many living nearby. 

We also know that West Lake area families and residents have had to live with stress as odors 

from the subsurface smoldering event (SSE) drew attention to the hazards affecting the 

community residents, business owners and employees due to unlawful and reckless dumping of 

radioactive waste at this site. Some nearby residents are currently involved in a lawsuit with the 

PRPs due to finding radioactive material, presumably from West Lake Landfill, within their 

homes. The issue of possible past, current and future exposure to airborne radiation from West 

Lake Landfill is not settled and continues to stress the entire nearby community. The EPA must 

take some responsibility for the stress and the potentially contaminated homes, as it took the 

EPA nearly 30 years to decide that radioactive material at the surface of the landfill should be 

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covered! Covering of surface contamination only occurred last year, yet the wind has been 

blowing since before the surface contamination was acknowledged. 

We stand with the residents living within approximately one mile of the site who request 

voluntary relocation. We also believe that for those within two miles of the site who will remain 

in their homes, property value assurance must be part of the agreement. 

A commitment is essential to area residents who live within these defined perimeters and have 

suffered from health and safety issues, odor effluence and the devaluation of property. As much 

as possible, we believe that these residents deserve these options which, for the first time since 

the harmful nature of the site was uncovered, will give them some modicum of control over the 

circumstances of their lives, which have been put in harm's way through no fault of their own. 

We know from the health survey that people living closest to the landfill are statistically more 

likely to suffer from shortness of breath and are considerably more likely to be concerned about 

odors impacting their lives daily. These are real people with respiratory problems living near the 

landfill that are being advised by the DHSS that “during periods of objectionable odor, sensitive 

individuals should stay indoors as much as possible, avoid outdoor exercise, and seek medical 

advice for any acute symptoms.” 

Not knowing when the next odor attack will occur or how the chronic exposure to low-level 

contaminants being released by the landfill has and is impacting their health results in chronic 

stress for many fence-line families. Chronic stress, itself, has a proven impact on human health, 

leading to increased risk for cardiovascular disease, depression, and autoimmune disease, 

among other health problems. The combination of physical and mental impacts from the odor at 

the landfill has led to a reduced quality of life and increased risk of illness for the people who 

live closest to the landfill. 

2. St. Louis County Department of Emergency Management, Pattonville Fire District, and a 

representative from our community should be included in meetings and deliberations during the 

design and engineering phase. 

3. During construction and any field tests, St. Louis County Department of Emergency Management 

and Pattonville Fire District should each, independently, be granted the right to inspect the site at 

any time and be given the authority to stop work at any time they deem a risk to the public or 

workers has or is about to occur. 

4. We continue to be concerned that EPA has issued a Remedy without knowing where all the RIM is 

located, i.e., the North Quarry has not been fully tested: indeed, the only testing for soil based RIM 

in the North Quarry was performed in order to find a suitable location for an isolation barrier that 

was ordered by both the Missouri Attorneys General and the EPA. Once it was determined that the 

Northern end of the North Quarry was too deep for an isolation barrier to be installed, testing was 

stopped, leaving a large percentage of the landfill untested and NOT included in the Proposed 

Remedy or any of the Alternatives evaluated. This is of particular concern since this is the area 

between the “known RIM” and the current SSE AND an area that has experienced landfill fires 

even closer to the “known RIM” than the current SSE. 

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5. Storage of removed materials: Permanent storage of the waste material should be moved offsite to 

a licensed facility. Continuation of this facility as an on-site storage facility would unnecessarily 

increase the on-going stress of our community. 

6. While the contaminated areas under the “muffin top” have complexities and safety concerns that 

may limit the depth of removal that is possible, it appears that there is no such limit on the 

“original” Area 1 and Area 2. Rather than limiting the depth of removal, it is our contention that all 

radioactive material be removed from the “original” Area 1, Area 2, and as much as is safely possible 

from under the “Muffin Top” and other areas in the North Quarry. 

7. Expedite Removal 

a. The removal is based on two, four-hour shifts. 

i. Expand the number of work shifts, i.e., some times of year may allow for more shifts 

per day, etc. 

b. Simultaneously remove RIM from Area 1 & Area 2. 

c. Resolve discrepancy between EPA and PRPs regarding expansion of volume of materials 

when removed from ground (PRPs use 200%, EPA 150%). If 150% is accurate, this will 

reduce time and cost. 

d. Remove and dispose of suspected contaminated materials w/o sorting if Alpha radiation 

detection in field is too complex or unreliable. 

8. Ongoing Monitoring and Protection From Any RIM that Must be Left Behind: 

Regardless of the Remedy selected, the <strong>CAG</strong> is concerned with the lack of a plan for the long-term 

monitoring and observation of the North Quarry “muffin top” as it relates to the development of a 

subsurface smoldering fire. Confirming a smoldering fire by observance of surface cracks and/or 

subsidence will, according to the Final FFS, be hampered by the presence a rock covered cap. 

Therefore, relying on the usual indicators may result in it being too late for meaningful intervention 

if the smoldering begins above, within, or close to areas of radioactive material. 

a. One of the key indicators of an SSE is the development of surface cracks. Another is 

subsidence of the surface level. It is unclear how either can be properly monitored: 

i. The Final FFS (page 74) states that the “extent of subsidence” in the area of the neck 

between the North and South Quarries is an indicator that the SSE “has not 

progressed into the North Quarry”. 

b. We believe that the following would also apply to earthquakes and floods. The Final FFS 

(page 80) states the following: 

5.1.2 Cap Degradation 

As discussed previously, subsidence combined with desiccation and damage to the 

landfill cap materials caused by an SSE could allow cracks to form in the cap allowing 

increased infiltration into the landfill. Increased infiltration would likely increase the 

amount of leachate generated and could increase potential groundwater impacts below 

the landfill site due to increased leachate generation. The magnitude of this impact would 

depend on the area of the subsidence and the extent of cap damage. If a cap remedy 

such as those included in some of the remedial alternatives in the FFS (Ref 2) was 

implemented, the rock barrier proposed at the surface might make it difficult to 

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identify the extent of cap damage. In addition, cracks forming below the rock 

barrier might not be expressed or be visible at the surface. The rock layer would 

likely allow infiltration from the surface to more easily spread laterally to any 

cracks that form below this layer which may not be detected by surface cap 

monitoring. 

c. Currently, pumps that keep groundwater from reaching the level of the radioactive waste 

are in place. We need to be assured that those pumps are maintained and running well 

beyond site remediation. This requires an ongoing funding source with financial surety and 

dedicated EPA responsibility, with, if needed, a succession plan. Considering the 9000+ years 

that this radioactive waste will continue to increase in radioactivity. 

d. We ask that the EPA use the maximum amount of time under CERCLA to guarantee the 

effectiveness of the water pumps and any other safety measures put in place at the West 

Lake landfill. The long term effectiveness of safety and remediation methods will impact 

generations to come. 

e. Since the North Quarry has not been fully characterized and tested for the presence of RIM, 

and that there have been multiple documented landfill fires even closer to the areas of 

known RIM than the current SSE in the South Quarry, we request and think it prudent for 

the following to be included in the Final Remedy: 

i. Install 2 additional lines of TMPs into the North Quarry to the north of the one line 

required in https://semspub.epa.gov/work/07/30351150.pdf (see map below from 

page 25) 

ii. Install TMPs into any deposits of RIM than must be left behind. Prophylactic 

installation of Cooling Loops should also be evaluated. 

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This document is assumed to be current as it was referenced in response to the 

T<strong>CAG</strong> question #3 answered by Tom Mahler on April 3, 2018 as stated below: 

3. What is the plan should the existing SSE or a future SSE or landfill fire 

threaten the RIM left behind? 

EPA Response: Please refer to the January 26, 2017 Incident 

Management Plan 

(https://semspub.epa.gov/src/document/07/30337762), the August 4, 

2017 Temperature Monitoring Probe (TMP) Work Plan 

(https://semspub.epa.gov/src/document/07/30351150) and the 

December 16, 2017 draft Inert Gas Injection Work Plan for Hot Spot 

Remediation (https://semspub.epa.gov/src/document/07/30351149). 

9. Regarding remediation to 52.9 pCi/g vs 7.9 pCi/g: 

We would like to see the site cleaned to 7.9 pCi/g AND a UMTRCA cap installed for the following 

reasons: 

a. The EPA has made a case for defining radiation over 52.9 pCi/g as Principle Threat Waste, 

thus justifying to itself removal of radioactively contaminated materials above 52.9 pCi/g. 

However, the community has repeatedly expressed that it does not want any RIM left at 

the site. Even a cleanup to 7.9 pCi/g leaves unacceptable amounts of RIM at the site. 

b. Since there is a clear and present danger of earthquake and possible danger of flooding, the 

7.9 alternative would give this community more protection if and when either would strike 

this area. 

c. In addition to cleaning to 7.9 pCi/g, since the RIM was randomly dispersed within the 

landfill, making discovery of every deposit daunting if not impossible, installing an UMTRCA 

cap over the 7.9 remediation will also minimize the amount of radon and potential for 

radioactive dust, etc. that would leave the site should an earthquake occur during a windy 

time of year. 

10. Regarding cleaning to a depth of 16 feet: 

If a depth limit is part of the Final Remedy, please clean the soils within that depth limit to 7.9pCi/g 

AND install an UMTRCA cap over the 7.9 remediation. This will minimize the amount of radon and 

potential for radioactive dust, etc. that would leave the site should an earthquake occur during a 

windy time of year. 

Considerations: 

1. The City of Bridgeton deserves to be made whole and has asked for as much of the RIM to be 

removed as can be done, as has the St. Louis County Executive. Permanently abandoning accessible 

RIM at the landfill will leave a long-term stigma on the community. 

2. Making this community whole and safe should not be limited by the willingness of the PRPs to pay 

for a comprehensive Remedy. Federal regulators erred in selling the Leached Barium Sulfate that 

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created this problem. Our Federal Government is prohibited from selling nuclear waste as a means 

of disposal. While other materials in the sale were not pure waste, the Leached Barium Sulfate was. 

3. Safe Removal of RIM: If any of the RIM cannot be safely removed at this time due to proximity to 

the current SSE, come back after the SSE in the South Quarry is extinguished, fully characterize the 

North Quarry for RIM, and then remove any RIM left in the North Quarry to the best cleanup levels 

available. 

4. It is essential for all living in the area and beyond that the remediation of the site be contained 

within an enclosed structure during removal. 

5. It is essential that a skilled and experienced work force be deployed. 

6. Utilization of local workers will help the recovery of this community’s economy from the damage 

done by extended presence of this un-remediated site. 

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CAG Board Comments on Proposed Remedy for West Lake Landfill April 18 2018

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