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
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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