2015-09-21 – EPA – West Lake Landfill – Acting RA Talking Points for Calls with Federal, State and Local Elected Officials


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Acting RA Talking Points
for Calls with Federal, State and Local Elected Officials the week of September 21, 2015
Reports Released by the Missouri Attorney General:
I know you’re interested in our view of the Missouri Attorney General’s Office’s reports that were
prepared in support of the State’s lawsuit against Republic Services.
We have shared these documents and held follow up consultations with EPA’s Office of Research and
Development (ORD) and Office of Solid Waste and Emergency Response {OSWER), as well as with the
U.S. Geological Survey (USGS) and the U.S. Army Corps of Engineers (USACE).
Based upon our initial review and consultations, we have not seen anything in the reports to change our
overall assessment of conditions at the site.
My office has one goal at the site and that is to protect the health of the people who work at and live
around the West Lake Landfill. To accomplish this goal, it is this Agency’s duty to complete the
investigations necessary to support a remedy decision, to select a final remedy, and to implement that
remedy as quickly as possible.
Area 1 and 2 Additional Characterization:
As I indicated to you last week, we are moving forward with the additional RIM characterization work
planned for Areas 1 and 2 at the site.
Late last week, EPA gave the Potentially Responsible Parties’ (PRPs) approval to proceed with the work
in accordance with the approved work plans.
This is critical work needed to support a remedy decision.
The EPA has determined that the approved work plans and site Health and Safety plans provide
sufficient protocols to ensure protection of site workers and the public during field activities in Areas 1
and 2.
These plans contain specific protective measures related to clearing of site vegetation, dust suppression
and monitoring of personnel and equipment for radioactive contamination, as well as decontamination
if needed prior to exiting the work areas.
As a reminder, both the Missouri Department of Natural Resources and Republic Services have on-site
air monitors designed and operated to detect releases of radioactivity, among other things.
In addition, in order to ensure that the protective measures are implemented appropriately, all field
activities will be overseen by a certified Health Physicist and by trained EPA personnel.
The major tasks associated with the additional investigation:
• 25 boring locations will be surveyed and staked in the field, and on-site personnel familiar with
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the locations will of any underground utilities, or infrastructure will inspect the locations to
verify the absence of utilities or infrastructure.
• Gravel paths will be constructed to each boring location and drilling pads at each location will be
constructed in the same manner as those that were constructed in Phase I work. The extent of
the anticipated vegetation clearing is very small, approximately a quarter acre in Area 1 and
approximately one acre in Area 2.
• Vegetation removal and construction of access roads and drill pads will be performed using the
same procedures previously employed for those activities during the prior Phase 1 and Phase 1D
investigations in Area 1.
• A drill rig will be brought on site to drill soil borings and collect soil core samples at each
SSE Update
EPA’s Office of Research and Development reviews data and reports available on the MDNR website
related to the SSE. ORD provides quarterly reports and a comprehensive annual report to EPA Region 7
to assist in monitoring the status and advancement of the SSE. To date, none of the ORD reports
indicate rapid advancement of the SSE toward areas containing known RIM. EPA Region 7 will continue
to enlist the expertise of ORD in monitoring the SSE.
Pyrolysis Update
EPA is evaluating testing methodologies which may be available to support decisions related to an
isolation barrier and to selection of a final remedy. EPA is working closely with a contract lab to examine
analytical methods which could be employed to increase our understanding of potential impacts of an
SSE contacting RIM.
Off-Site Data Summary
As you may remember there have been a number of significant assessments over the years in the
community around the landfill:
• The EPA’s ASPECT overflight of the Site and nearby residential and commercial/industrial
properties in 2013 detected no off-Site excess gamma emissions in surface soil anywhere offSite,
and only on-Site in one small area of OU-1 Area 2 as previously identified in the Remedial
• Off-Site groundwater sampling by the USGS and the EPA of privately-owned wells to the
northwest and southwest of the site in 2013 revealed no radionuclide exceedances of drinking
water standards, and to our knowledge there is no use of private wells in the area for drinking
• The MDNR conducted soil sampling in 2005 along St. Charles Rock Road, Boenker Road and
Taussig Road just outside Site boundaries and did not detect uranium, thorium, or radium above
the cleanup standards.
• In addition, the EPA’s 2014 Bridgeton Municipal Athletic Complex sampling found no
exceedances for uranium, thorium, or radium.
• Lastly, the Missouri Department of Health and Senior Services analyzes ambient air monitoring
data for the Bridgeton Landfill collected by the MDNR, and to date the state reports
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summarizing this analysis do not indicate that there is a potentially unacceptable risk to human
health. The data from volatile organic compounds (VOCs), hydrogen sulfide (H2S), carbon
monoxide (CO), benzene and gamma radiation monitoring are published daily by the MDNR.
Moreover, EPA has completed an offsite air monitoring effort with similar results.
We are continuing to work closely with the MDNR to monitor site conditions. It is the EPA’s priority to
ensure that the right steps are taken to adequately monitor and address any release or threat of release
of hazardous substances, pollutants, or contaminants from the Site. We will continue to closely
evaluate the information provided by the Missouri Attorney General’s Office.
Qand A
1. What about the AG reports indicating offsite migration? Is EPA going to conduct offsite
Answer: EPA is relying on the body of validated scientific data which does not support the
conclusion that RIM has migrated offsite. Our efforts remain focused on completing the onsite
investigations necessary to support a final remedy decision.
2. What is the status of the isolation barrier?
Answer: Pending receipt of the validated data from the Phase 10 investigation and subsequent
consultation with USACE, EPA expects to make a decision regarding an isolation barrier. We expect
that decision to be made this calendar year.
3. What is EPA doing to protect residents from the SSE that is approaching the RIM?
Answer: EPA does not believe there is imminent danger of the SSE reaching RIM. EPA supports
MDNR efforts and direction to Republic Services regarding the monitoring and development of
corrective measures. EPA is focused on getting a final remedy in place which will provide long term
protection of the public.
4. Please provide more details about your review of the AG’s reports.
Answer: EPA has completed our initial evaluation of a collection of documents from the Missouri
Attorney General’s Office which were prepared in support of the State’s lawsuit against Republic
Services. The documents total more than 1, 700 pages which provides analyses of conditions on and
around the West Lake Landfill Superfund Site.
EPA Region 7 has shared these documents and held follow up consultations with EPA’s Office of
Research and Development (ORO) and Office of Solid Waste and Emergency Response (OSWER), as
well as with the U.S. Geological Survey (USGS) and the U.S. Army Corps of Engineers (USACE).
Our experts have reviewed the testing methodologies and results described in the reports, along
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with the previously collected environmental air, water and soils sampling data we have available to
us. Based upon that body of information, we do not believe that there is scientifically valid
evidence that people living near and working outside the boundaries of the West Lake Landfill
Superfund Site are currently being exposed to contaminants released from the Site that are above
levels of concern.
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