2015-05-06 – EPA – Talking Points for Meeting with Senator McCaskill’s Office Regarding West Lake Landfill


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Talking Points for Meeting with Senator McCaskill’s Office Regarding West Lake Landfill
May 6, 2015 Meeting, Washington DC- DRAFT Vl 4/30/15
Recent and On-Going Activities at the West Lake Landfill
• PRPs have agreed to define extent of RIM at the northern boundary of the North Quarry
under an EPA workplan and EPA oversight in the field. This will aid in both the decision
on an isolation barrier as well as the decision on the final remedy at the site.
• PRPs have agreed to conduct additional investigation in Areas 1 and 2 to refine the
boundaries of the location and extent of RIM.
• EPA has also recently directed the PRPs to submit revised work plans related to the
partial excavation alternative analysis. This is a key step in moving forward towards the
final remedy evaluation.
• EPA is planning pyrolysis testing of soil samples containing RIM. This analysis will expose
soil samples to temperatures similar to temperatures associated with those of the SSE in
the South Quarry.
• We are continuing to work closely with MDNR to monitor the SSE at the Bridgeton
Landfill and evaluate any potential impacts should the SSE come into contact with RIM.
• PRPs have been directed to submit to MDNR all H2S and S021andfill gas related data;
calculate potential estimated S02 emissions from the on-site flares and submit a permit
application for the flares that includes sulfur control technologies.
• EPA and MDNR are working together on the S02 matter. EPA supports MDNR/AGO in
enforcing their deadlines set for the PRPs. If needed, EPA has option of issuing Clean Air
Act 114 request for information and/or order for testing.
• EPA and MDNR are exploring options for mobile H2S and S02 monitoring within the
community, which could also help inform any additional monitoring in the community.
Potential timeframes- June/July for mobile monitoring and fall for siting stationary air
EPA Response to Just Moms STL Request for Relocation:
• The Bridgeton Landfill (former active sanitary landfill) is included in the 2008 Operable
Unit 2 Record of Decision (OU-2 ROD). EPA deferred implementation of an EPA
remedial action for the Bridgeton Landfill to the State of Missouri pursuant to the
requirements of the state’s existing closure and post-closure permit.
• EPA continues to have CERCLA response authority to ensure protectiveness of human
health and the environment for releases of hazardous substances from the Bridgeton
• EPA’s relocation authority under the National Contingency Plan includes: “[t]emporary
WLLFOIA4312- 001 – 0058370
Talking Points for Meeting with Senator McCaskill’s Office Regarding West Lake Landfill
May 6, 2015 Meeting, Washington DC- DRAFT Vl 4/30/15
or permanent relocation of residents, businesses, and community facilities may be
provided where it is determined necessary to protect human health and the
environment” (Title 40 of the Code of Federal Regulations (40 C.F.R.) section 300, App.
• Based on the scientific data we have at this time, EPA has determined that
circumstances at the West Lake Landfill Superfund Site do not currently warrant the use
of permanent relocation pursuant to CERCLA authority.
• Example of Herculaneum-Doe Run.
o Lead emissions and lead contaminated soils were suspected to be the cause of
elevated blood lead levels in the surrounding community.
o EPA performed a fund-lead removal action at Herculaneum, as a part of that
action EPA provided a temporary, voluntary relocation during the interior cleanup
of homes for a limited number of residents with health concerns and/or young
o In addition, Doe Run agreed to implement limited voluntary buyout for residents
who lived closest to the smelter under an April 2002 agreement between
Missouri AGO, MDNR and Doe Run (about 145 out of 173 homeowners
accepted a buyout offer).
o Doe Run was a NAAQS non-attainment area for lead at the time of the buyouts and later
for S02. Decisions to offer relocation were not based solely on NAAQS issues with
neither lead nor S02, but on the cumulative health effects on the population and unique
characteristics of lead (soil/air re-entrainment, blood levels, etc.).
o Note that S02 is much more transient and very unlikely that relocation decision would
be based solely on exceedances of S02 (or any other) NAAQS in the Bridgeton area. We
have several areas in R7 (including St. Louis- Ozone, PM) that are exceeding the NAAQS
for one pollutant or another.
WLLFOIA4312- 001 – 0058371