CAG Board Comments on Proposed Remedy for West Lake Landfill April 18 2018
The Community Advisory Group (CAG) 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).
The Community Advisory Group (CAG) 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).
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BOARD COMMENTS ON PROPOSED REMEDY FOR WEST LAKE LANDFILL<br />
<strong>April</strong> <strong>18</strong>, 20<strong>18</strong><br />
identify the extent of cap damage. In additi<strong>on</strong>, cracks <strong>for</strong>ming below the rock<br />
barrier might not be expressed or be visible at the surface. The rock layer would<br />
likely allow infiltrati<strong>on</strong> from the surface to more easily spread laterally to any<br />
cracks that <strong>for</strong>m below this layer which may not be detected by surface cap<br />
m<strong>on</strong>itoring.<br />
c. Currently, pumps that keep groundwater from reaching the level of the radioactive waste<br />
are in place. We need to be assured that those pumps are maintained and running well<br />
bey<strong>on</strong>d site remediati<strong>on</strong>. This requires an <strong>on</strong>going funding source with financial surety and<br />
dedicated EPA resp<strong>on</strong>sibility, with, if needed, a successi<strong>on</strong> plan. C<strong>on</strong>sidering the 9000+ years<br />
that this radioactive waste will c<strong>on</strong>tinue to increase in radioactivity.<br />
d. We ask that the EPA use the maximum amount of time under CERCLA to guarantee the<br />
effectiveness of the water pumps and any other safety measures put in place at the <strong>West</strong><br />
<strong>Lake</strong> landfill. The l<strong>on</strong>g term effectiveness of safety and remediati<strong>on</strong> methods will impact<br />
generati<strong>on</strong>s to come.<br />
e. Since the North Quarry has not been fully characterized and tested <strong>for</strong> the presence of RIM,<br />
and that there have been multiple documented landfill fires even closer to the areas of<br />
known RIM than the current SSE in the South Quarry, we request and think it prudent <strong>for</strong><br />
the following to be included in the Final <strong>Remedy</strong>:<br />
i. Install 2 additi<strong>on</strong>al lines of TMPs into the North Quarry to the north of the <strong>on</strong>e line<br />
required in https://semspub.epa.gov/work/07/30351150.pdf (see map below from<br />
page 25)<br />
ii. Install TMPs into any deposits of RIM than must be left behind. Prophylactic<br />
installati<strong>on</strong> of Cooling Loops should also be evaluated.<br />
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