2012-01-04 – Considering environmental justice issues EPA should establish a CAG for West Lake Community


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Debbie Kring, X7725 114/2012
Ad-Announcement of Release ofthe West Lake Landfill Superfund Site Final Supplemental Feasibility Study (SFS)
Announcement for the community at large, the Superfund repositories and the Record Center.
4. CONCURRENCE: SlgiHff …. Dille
OPA SUPR CNSL OPA ~ ~ Ji Thomas/Hood 01 ~~12011.l {?/’ SUPR CNSL -Singletary Gonzales
Signature in this block indicates the appropriate assistant administrator, regional administrator, head of staff office, or their delegate has reviewed and approved the material submitted to OEP or RGAD for signature.

G Drive: Product Masters File/Public Information Form 11 /1/05
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40436738 ~
Region 7
West Lake Landfill (Superfund Site)
Atter listing the site on the NPL the EPA completed a preliminary study and determined that no immediate actions were necessary at the Westlake Landfill site while site studies are underway. Subsequently, EPA entered into a consent agreement with the responsible parties in which the parties agreed to perform field studies and engineering evaluations designed to identify the best strategies for cleanup. Remedial investigation and feasibilty study work was completed in 2006 and a proposed plan for both operable units was published in June 2006. The Record of Decision for Operable Unit 1 was signed in May 2008. The selected remedy calls for the installation of an engineered landfill cover and implementation of a long-term monitoring program. The Record of Decision for Operable Unit 2 was signed in July 2008. Under this decision, the other landfill units \\·ill be closed and monitored in accordance with Missouri solid waste regulations.
Critics of the selected remedy for OU 1. including the Missouri Coalition for the Environment. want the waste material to be excavated and shipped to an off-site location. In an April 2009 letter to the Administrator, the Great Rivers Environmental Law Center (on behalf ofthe Coalition) again raised its concerns and requested the remedy be reevaluated. After extensive consultation between the Region and Headquarters. EPA made a decision to conduct a supplemental feasibility study (SfS) for QUI that further evaluated full-scale excavation of the radiologically-contaminated landfill material and disposal either off-site or in a new, on-site engineered disposal cell. The Remedial Design/Remedial Action (RD/RA) negotiations (which sequentially follow the signing ofthe Record of Decision) \Vere put on hold in June 2009, pending the outcome of this study.
In January 20 I 0. EPA agreed to allow the Potentially-Responsible Parties ( PRPs) to perform the SFS, pursuant to the existing Administrative Order on Consent under which the PRPs had performed the Remedial investigation/Feasibility Study (RI/FS) and RD. EPA-Headquarters (Jim Woolf(Jrd) sent a letter to the Great Rivers Environmental Law Center on March 3, 2010 stating that EPA would conduct a SFS. The SFS Work Plan was approved under a cover letter dated May 21, 2010, and was released to the public in June 2010. EPA received the draft SFS report on July 23.2010. On September 22,2010. EPA met with MDNR and the PRPs to discuss comments about the report. On November 10, 2010, EPA formally submitted comments to the PRPs and requested changes to the report by January 16, 2011. The PRPS asked for an additional 60 days, which EPA granted. PRPs responses to comments are currently under rCVlC\V.
Support Needed:
Contractor support is needed to potentially provide facilitation, technical assistance to public groups (i.e., the CAG), and review of technical documents that support the site:
Coordinating with Public Groups (i.e .. CAG):

Preparing tor, Facilitating, and providing summaries at EPA & Group (CAG) Meetings (up to 6 meetings):

Technical Document Review and Summary of Content (estimate= 3 technical documents):

Developing Presentation Materials (technical document content breakdown and summary):

Developing Responses to Community Inquiries (technical issues);

* Currently there is not a CAG at this Superfund Site, however, due to the site complexity, the extension of the original public comment period on the Proposed Plan (6 extensions). the political inquiries. EJ considerations, and environmental group involvement. it would be a wise move on EPA’s part to have additional options in the review, response, and facilitation arenas.