2015-02-13 – EPA – West Lake Landfill – EPA Region 7 Indicates West Lake is Most Hot Button Issue in State of Missouri

To: Juett, Lynn[Juett.Lynn@epa.gov]; Jackson, Robert W.[Jackson.Robertw@epa.gov] From: Vann, Bradley Sent:... View Document

Post

2015-10-19 – EPA – West Lake Landfill – Mark Hague notes for call with Mathy Stanislaus

To:
From:
Stoy, Alyse[Stoy.Aiyse@epa.gov]; Peterson, Mary[Peterson.Mary@epa.gov]
Juett, Lynn
Sent:
Subject:
Mon 10/19/2015 3:50:03 PM
Notes for Mark’s Call with Mathy
Upcoming Activities
• October 23, 2016 – Bridgeton Landfill’s Expert Reports Due Date
• October 26, 2015 – CAG Meeting in St Louis
• October 26, 2015 Week- Congressional and Community Outreach by Acting RA
• November 13, 2015- Goal for completing negotiations on Addition Work and AOC
Modifications -which will provide an enforceable schedule for Final Feasibility
Study
• December 3, 2015- Goal for Announcement of Isolation Barrier Decision
Recent Community Concerns
Relocation: Over the past year, Lois Gibbs, Center for Health and Environmental
Justice, and Just Moms StLouis have asked EPA in writing to relocate residents within
a two-mile radius of the Site, payment of “property assurance” presumably to
compensate for loss of property value within a five-mile radius and establishment of a
health clinic. Initially these concerns were directed at potential exposure to RIM and
movement of the SSE. Then in early 2015, Bridgeton Landfill discovered potential
excessive S02 emissions from one of its landfill gas flares, which added to the
community’s concerns regarding their health. EPA has performed environmental
sampling at the West Lake Landfill site over the years, including air monitoring within the
community this past year, all of which have not shown evidence of releases from the
site that could pose an unacceptable risk to the community. EPA has informed the
community that we have determined that the conditions at the Site do not warrant
consideration of temporary or permanent relocation as a CERCLA response action at
this time.
‘–“–”–”–”–”–‘RIM- All data collected and reviewed by EPA supports the conclusion that
WLLFOIA4312- 001 – 0056383
RIM has not migrated off-site in soils or via air. (Further groundwater investigation is
being planned, but the nearby communities are all hooked up to public drinking water
supplies)
c__jc__jl_jc__jc__jc__j SSE – Based on the available scientific data evaluated to date by our experts,
the data do not conclusively support a scenario where the SSE will encounter the
RIM. To date, reviews of the data have not indicated advancement of the SSE beyond
the neck area of the Bridgeton Landfill. The radiological waste at West Lake Landfill is not
capable under any circumstance of producing a sustained chain reaction (fission or fusion) that is capable
of producing a nuclear reaction or “meltdown” as seen at the Chemobyl and more recently Fukushima
power plants. In the unlikely event the SSE should come into contact with the RIM, EPA
does not believe that the RIM will become explosive in the presence of heat. We do
anticipate an localized increases of radon gas escaping into the atmosphere.
State of Emergency: On September 4, the Attorney General released reports from its
experts who will testify in the upcoming hearing (currently scheduled for March 2016) in
the AG’s lawsuit against Bridgeton Landfill. These reports and the accompanying press
release made the following statements. Based upon the information and conclusions
contained in these reports, the community has repeated its requests for relocation as
well as circulated a petition for the governor to declare a state of emergency.
o RIM has migrated off-site through groundwater and airborne particulate matter
(based on their phytoforensics testing),
o The SSE is moving towards the RIM and could make contact in a matter of 3 – 5
months, and
o Groundwater is contaminated.
EPA has publically stated that we strongly disagree with these conclusions. Also, on
October 16, 2015, Republic Services released an excerpt from their deposition of one of
the AG’s landfill experts. Based on what was posted, the landfill expert stated he does
not believe the SSE has moved past the neck nor is currently moving towards the RIM.
St. Louis County Emergency Plan: Following the release of the AG expert reports,
postings in social media showed an increased public interest in emergency planning.
About two weeks ago, an October 2014 West Lake Landfill Shelter in Place/Evacuation
Plan was obtained and released by the press. In response to that release, four local
school districts sent letters to parents of school children regarding their implementation
plans. While the news of an emergency evacuation plan may be new information for
many people, the plan has existed and been publicly known for more than a year. The
plan was developed in 2014 in consultation with multiple emergency response
organizations including the EPA. In July 2014, Director of St. Louis County Office of
Emergency Management, Michael Smiley discussed the plan with the West Lake
Landfill Community Advisory Group. In April 2015, Local Emergency Planning
Committee Chairman and Director of the St. Louis County Police Department
Emergency Manager Mark Diedrich made a public presentation about the updated plan
WLLFOIA4312- 001 – 0056384
to the West Lake Landfill Community Advisory Group.
Local Elected Officials: Following the release of the AG expert reports, several local
officials are becoming increasingly involved and one has recently called for a
congressional oversight hearing into West Lake Landfill and a declaration of a state of
emergency. She will also be holding a series of nine town hall meetings in early
November claiming that radioactive waste will become airborne in 2-5 months.
FUSRAP: There are continued community and even congressional written requests for
DOE to reconsider its prior evaluation of the Site for the FUSRAP program. Many in the
community believe that if the site were turned over to FUSRAP, the USAGE would
excavate the RIM and dispose of it off-site, as they have done for much but not all of the
radioactively contaminated soils at FUSRAP sites in St. Louis. On September 10, 2015,
DOE responded to the congressional delegation’s recent request for reconsideration by
saying that they have no new information that would justify transfer of the site into the
FUSRAP program.
WLLFOIA4312- 001 – 0056385

Post

2015-11-19 – EPA – West Lake Landfill is more difficult to clean up than other St Louis FUSRAP sites

To:
From:
Sent:
Subject:
Fritz, Matthew[Fritz.Matthew@epa.gov]
Hague, Mark
Thur 11/19/2015 6:15:17 PM
FW: New Bill in Senate: R7 OPA –West Lake Landfill Updates
From: Carey, Curtis
Sent: Thursday, November 19, 2015 11:41 AM
To: Hague, Mark ; Brincks, Mike ; Peterson,
Mary ; Stoy, Alyse ; Juett, Lynn
; Vann, Bradley ; Field, Jeff

Cc: Washburn, Ben ; Sanders, LaTonya
Subject: RE: New Bill in Senate: R7 OPA –West Lake Landfill Updates
WLLFOIA4312- 001 – 0055787
For Immediate Release
November 19, 2015
Contacts:
Missouri Members Demand Action on
West Lake Landfill
WASHINGTON, DC- Today, members of the Missouri congressional delegation,
including Senators Roy Blunt and Claire McCaskill, and Representatives Ann Wagner
and Wm. Lacy Clay, introduced legislation to transfer remediation authority over the
West Lake landfill from the Environmental Protection Agency to the Army Corps of
Engineers, putting the site in the Corps’ Formerly Utilized Sites Remedial Action
Program (FUSRAP).
“The EPA’s unacceptable delay in implementing a solution for the West Lake landfill has
destroyed its credibility and it is time to change course,” said Blunt. “The Corps has the
knowledge, experience, and confidence of the families living near the site. Transferring
clean up efforts to its control will help move the process forward and finally give these
families the peace of mind they deserve. No parent should have to raise their child in an
environment where they fear for their health and safety.”
McCaskill added, “The needs of this community are our top concern. We’ve heard loud
and clear that they want the West Lake site transferred to the Army Corps of Engineers’
program that oversees all other sites in St. Louis containing this World War II era
nuclear waste. This legislation is not a silver bullet, and will take far longer than we’d like
WLLFOIA4312- 001 – 0055788
to resolve the many issues surrounding this site, but this is a concrete, positive step
forward in a process that’s been stagnant for far too long.”
The bill introduced today would not alter the current liability of potentially responsible
parties at the site nor its designation as a Superfund site.
The measure represents the latest step in the delegation’s effort to utilize the Corps’
expertise to expedite remediation at the West Lake site. In July, Blunt, McCaskill,
Wagner, and Clay sent to Energy Secretary Ernest Moniz asking the
Department of Energy to re-evaluate whether West Lake qualified for inclusion in the
Corps’ FUSRAP in light of new information regarding the source of radioactive waste at
the site.
“My constituents in the St. Louis region deserve a government where officials work
proactively on their behalf, rather than kicking the can down the road with recurring
delays and deflections,” said Wagner. “The Formerly Utilized Site Remedial Action
Program (FUSRAP) and the U.S. Army Corps of Engineers have an excellent track
record, broad support in the community and the expertise to handle a site as
complicated as the Westlake Landfill. I believe that this legislation is a crucial step in our
efforts to reach a permanent solution for the people of Missouri.”
Clay added, “Over a year ago, I called for the transfer of West Lake to the U.S. Army
Corps of Engineers FUSRAP program. This new bipartisan legislation will bring us
closer to achieving that goal.
This is a 70-year old problem and the federal government has a duty to finally do the
right thing.
I am totally committed to removing all the nuclear waste from West Lake landfill. It just
makes no sense to allow radioactive waste to remain buried in an unlined landfill, near
residential neighborhoods, schools, a hospital, the airport and the Missouri River. It’s
time to clean up West Lake landfill.”
On February 28, 2014, the members also sent to the EPA asking the agency to
contract directly with the Corps to handle remediation efforts through FUSRAP, citing
the Corps’ “expertise in this area, and the local community’s faith in the Corps’ FUSRAP
WLLFOIA4312- 001 – 0055789
mission.” In March of 2014, the agencies~~== an agreement to work together to
build a fire break at the West Lake landfill.
Peterson,
Cc: Washburn, Ben Sanders, LaTonya
Subject: New Bill in Senate: R7 OPA –West Lake Landfill Updates
To require the Secretary of the Army, acting through the Chief of Engineers,
to undertake remediation oversight of the West Lake Landfill located
in Bridgeton, Missouri.
WLLFOIA4312- 001 – 0055790
WLLFOIA4312- 001 – 0055791

Post

2015-12-17 – EPA – West Lake Landfill – EPA receiving complaints about Coalition to Keep Us Safe

To: Stanislaus, Mathy[Stanislaus.Mathy@epa.gov]; Distefano,
N ichole[DiStefano. N ichole@e pa .gov]
From: Hague, Mark
Sent: Thur 12/17/2015 12:23:35 AM
Subject: Fwd: Post-Dispatch Editorial WLL
Mathy and Nichole
FYI. We heard from several stakeholders similar concerns as expressed below when we were in
StLouis Tuesday.
Mark
Sent from my iPhone
Begin forwarded message:
From: “Carey, Curtis”
Date: December 16,2015 at 6:16:12 PM CST
To: “Hague, Mark”
“Peterson, Mary”
Alyse”
Christopher”
Subject: Post-Dispatch Editorial WLL
Editorial: Politics and money drive advocates of keeping radioactive waste in Bridgeton
By the Editorial Board
The let’s-keep-radioactive-waste-buried-in-Bridgeton crowd is not what it’s pretending to
be.
More than a group of concerned citizens who say they don’t want contaminated waste
WLLFOIA4312- 001 – 0055757
transported through their communities, the righteously named “Coalition to Keep Us Safe”
is a political campaign in action.
It has little to do with keeping anyone safe, considering that there already have been more
than 1 million cubic yards of contaminated material shipped by rail through Missouri since
the 1990s. Where was the coalition then?
This group was largely assembled and paid for recently by a subsidiary of Phoenix-based
Republic Services, owner of the Bridgeton and West Lake landfills. Its purpose is to lead
opposition to a clean-up effort that would involve excavating an estimated 150,000 cubic
yards of radioactive waste and transporting it by rail to a nuclear storage facility. That
would cost Republic most of an estimated $400 million.
What the coalition members have in common are ties to Republic Services. Spokeswoman
for the group, Molly Teichman, is a conservative political commentator based in Lafayette
County, Mo., near Kansas City. She has political ties to state Rep. Glen Kolkmeyer, ROdessa,
a coalition supporter. They are both longtime friends of Kay Hoflander, chair of the
Lafayette County Republicans, who has worked on behalf of the coalition.
The common thread stitching them together is Russ Knocke, Ms. Hoflander’s son. He is the
director of field communications and public affairs for Republic. Mr. Knocke told the PostDispatch’s
Blythe Bernhard and Jacob Barker that the company spent between $10,000 and
$100,000 on a recent advertising blitz against unearthing and transporting the waste. Ms.
Teichman is paid $1,500 a month from Republic.
Pretty easy to see where the opposition gets its marching orders, isn’t it?
It gets even better. Republic Services has taken a page straight out of the playbook of David
Plouffe, architect of the long-shot bid to get Barack Obama into the White House in 2008,
and currently the “strategic adviser” for Uber. When Mr. Plouffe was hired by Uber, the
ride-hailing company that is disrupting taxi services everywhere, the company discussed
“Uber the Candidate.” Mr. Plouffe was known as the “campaign manager.”
WLLFOIA4312- 001 – 0055758
The basics in Mr. Plouffe’s playbook are:
• Tum your campaign into a cause.
• Find a theme.
• Build an inspiring narrative around the theme.
• Speak to your core audience through social media, email, advertising or face to face.
• Tum your audience into advocates, partly by equipping them with selective facts.
• Ignore anything that doesn’t fit your strategy.
And, perhaps most importantly, keep doing the same thing day after day until people start to
buy your argument.
With this strategy, there is nothing that can’t be fought as a political campaign. But there is
also no meaning in it. Telling people you want to keep them safe when what you really
want to do is save a waste management company a lot of money is cynical. So what if
thousands of other people who live in the vicinity of West Lake and Bridgeton landfills
actually may not be safe? The coalition isn’t working to keep them safe, is it? But then,
those aren’t the people signing the checks.
Don’t fall for this strategy. This group is tying to scare the rest of us into thinking that
putting a cap over the landfill, a plan put forth by the Environmental Protection Agency in
2008, is the right way to handle radioactive waste in a landfill that is adjacent to another
WLLFOIA4312- 001 – 0055759
landfill in which an underground fire has been burning for years. They’re trying to convince
people that it is better to let the people around Bridgeton live with the waste in their
neighborhoods than it is to transport the contaminated material along rail lines through their
communities.
The evidence suggests otherwise. The waste products where they lie are a threat of
unknown proportions. A million cubic yards of contaminated waste already have moved
through Missouri- with more being transported daily- and there have been no known
disasters as a result.
The right thing to do is excavate the radioactive material and move it to a safe nuclear
storage site. Stop the political campaign. Tum off the money spigot. Let the phony concern
wither.
Ms. Teichman showed her complete lack of sensitivity and tin ear to the concerns of others
when she thumbed her nose on social media at members of the group, JustMomsSTL, which
wants the waste hauled away.
She tweeted: “Dear mombots of #westlakelandfill, your reality tv show is over. Go home
and hangout with your kids -they miss you.”
Nice. Easy shot to take when you live more than 200 miles from St. Louis with little chance
that you, your kids or loved ones are going to become ill or contaminated from radioactive
waste. Way to run a political campaign, Ms. Teichman.
WLLFOIA4312- 001 – 0055760

Post

2015-12-13 – EPA – West Lake Landfill – Agency review of SB 2306 – Transfer of authority to USACE

To:
From:
Hague, Mark[Hague.Mark@epa.gov]
Distefano, Nichole
Sent:
Subject:
Mon 12/14/2015 4:14:13 AM
Re: SB 2306
Thanks!!! What’s FFA stand for?
Sent from my iPhone
On Dec 13,2015, at 11:11 PM, Hague, Mark
From: Peterson, Mary
Sent: Sunday, December 13, 2015 1: 14 PM
To: Hague, Mark
Cc: Stoy, Alyse
Mike
Subject: RE: SB 2306
Juett, Lynn
Cozad, David
wrote:
Brincks,
WLLFOIA4312- 001 – 0055671
Attorney Work Product
Attorney Client Privilege
Deliberative
Do Not Release Under FOIA or in Discovery
Mark,
Alyse and I consulted on this today. Find below our responses in red to the points in your
email.
-‘–J,_j~’-J’—‘~’–”–‘ Reads like a transfer of oversight on WL to the COE under FSURP. And is
unclear what if any role EPA would have moving forward.
-~J_jl_j’–J’—‘l_j~jc_j Funding section talks about “funds made available to the Secretary”. That
seems to imply an appropriation that would go to FUSRP. I don’t see anything that would
imply the funding would come from EPA/SF approps. Given the site work is being paid by
the PRPs and if memory is correct we have some special account funds, there really is little
to no funding we have from our approps for this work.
WLLFOIA4312- 001 – 0055672
-~,~~~~,~~,~ It would seem that if signed into law that there is a transfer to
ACOE. .. although there is something in the language that like as soon as possible. Not sure
how that would implicate our work underway …. would we stop, continue or wait for
direction from the ACOE? You all may not have a different reading but want to check.
-‘–“–‘~~~’~’–”-‘-Does the transfer only include WL (language on radiation contamination) or
does it mean the entire site including areas where the State currently has the lead? This
seems unclear in reading the limited text and to my knowledge there is really no legislative
history beyond the bill language. If this moves quickly, which it could, we may not have
much more legislative history to guide next steps. If enacted figuring that out in and off
itself could add delays.
WLLFOIA4312- 001 – 0055673
From: Hague, Mark
Sent: Saturday, December 12, 2015 5:52PM
To: Peterson, Mary
Cc: Stoy, Alyse
Mike
Subject: Re: SB 2306
Juett, Lynn
Cozad, David
Yes anytime tomorrow. A quick few points are fine.
Sent from my iPhone
On Dec 12, 2015, at 5:50PM, Peterson, Mary
Brincks,
wrote:
How soon do you need this Mark? I’m not in a good place to review the attachment
until later tonight. I plan to work much of the day tomorrow- will that be soon enough?
Sent from my iPhone
On Dec 12,2015, at 11:37 AM, Hague, Mark wrote:
Mary, Alyse and Lynn
Attached is a copy of SB 2306. The bill to transfer WL to the ACOE.
I believe this is the same version we saw a week or two ago. If possible could I
get your general sense on a few key points.
-‘–“–‘~’–‘~”–‘~”–‘Reads like a transfer of oversight on WL to the COE under FSURP.
And is unclear what if any role EPA would have moving forward.
-‘-J’_j’-Jc_]L_” _ _cl_jc_j Funding section talks about “funds made available to the
Secretary”. That seems to imply an appropriation that would go to FUSRP. I
WLLFOIA4312- 001 – 0055674
don’t see anything that would imply the funding would come from EPA/SF
approps. Given the site work is being paid by the PRPs and if memory is correct
we have some special account funds, there really is little to no funding we have
from our approps for this work.
-~,~~~~,~~,~ It would seem that if signed into law that there is a transfer to
ACOE … although there is something in the language that like as soon as
possible. Not sure how that would implicate our work underway …. would we
stop, continue or wait for direction from the ACOE? You all may not have a
different reading but want to check.
-~,~~~~·~~,~ Does the transfer only include WL (language on radiation
contamination) or does it mean the entire site including areas where the State
currently has the lead? This seems unclear in reading the limited text and to my
knowledge there is really no legislative history beyond the bill language. If this
moves quickly, which it could, we may not have much more legislative history to
guide next steps. If enacted figuring that out in and off itself could add delays.
If at all possible send me a few bullet points if you have any insights.
Thanks
Mark
Mark Hague
Regional Administrator
Office of the Regional Administrator
EPA Region 7
11201 Renner Boulevard
Lenexa, KS 66219
913-551-7546

WLLFOIA4312- 001 – 0055675

Post

2015-08-10 – EPA – West Lake Landfill – Update on status of West Lake and ATSDR Health Consultation

To:
Cc:
From:
Hague, Mark[Hague.Mark@epa.gov]; Breen, Barry[Breen.Barry@epa.gov]
Stalcup, Dana[Stalcup.Dana@epa.gov]; Peterson, Mary[Peterson.Mary@epa.gov]
Juett, Lynn
Sent: Mon 8/10/2015 12:59:33 PM
Subject: FW: Update on status of West Lake and ATSDR Health Consultation
From: Woolford, James
Sent: Tuesday, August 04, 2015 9:24AM
To: Juett, Lynn
Subject: Fw: Update on status of West Lake and A TSDR Health Consultation
WLLFOIA4312- 001 – 0055622
here is latest I have.
Jim Woolford, Director
Office of Superfund Remediation and Technology Innovation
Office of Solid Waste and Emergency Response
US EPA
Phone: 703-603-8960 (office)
Mailing address:
1200 PA Ave. NW
Washington, DC 20460
Mail Code – 5201 P
Address
2777 S. Crystal Drive
Arlington, VA 22202
Room 5622
Note – EPA email cannot receive or send emails greater than 25 mbs.
WLLFOIA4312- 001 – 0055623
From: Stalcup, Dana
Sent: Sunday, July 19, 2015 9:12PM
To: Breen, Barry
Cc: Woolford, James; Gardner, Monica; Hilosky, Nick; Bergman, Shawna; Stanislaus, Mathy
Subject: RE: Update on status of West Lake and ATSDR Health Consultation
WLLFOIA4312- 001 – 0055624
From: Breen, Barry
Sent: Monday, July 13, 2015 7:23 PM
To: Stalcup, Dana
Cc: Woolford, James; Gardner, Monica; Hilosky, Nick; Bergman, Shawna; Stanislaus, Mathy
Subject: RE: Update on status of West Lake and ATSDR Health Consultation
From: Stalcup, Dana
Sent: Monday, July 13, 2015 7:08 PM
To: Breen, Barry
Cc: Woolford, James; Gardner, Monica; Hilosky, Nick; Bergman, Shawna; Stanislaus, Mathy
Subject: RE: Update on status of West Lake and ATSDR Health Consultation
WLLFOIA4312- 001 – 0055625
Non-site related radon recommendation
ATSDR believes that radon migration through the soils on the West Lake
landfill will not extend past the landfill property. However, the average
indoor radon levels from naturally occurring radon in St. Louis County is
known to be higher than national levels ,~~~~~
As a general practice, the Surgeon
General and EPA recommend that all homes be tested for radon
WLLFOIA4312- 001 – 0055626
From: Breen, Barry
Sent: Monday, July 13, 2015 6:16PM
To: Stalcup, Dana
Cc: Woolford, James; Gardner, Monica; Hilosky, Nick; Bergman, Shawna; Stanislaus, Mathy
Subject: RE: Update on status of West Lake and ATSDR Health Consultation
From: Stalcup, Dana
Sent: Friday, July 10, 2015 2:59PM
To: Stanislaus, Mathy; Breen, Barry
Cc: Woolford, James; Gardner, Monica; Hilosky, Nick; Bergman, Shawna; Fitz-James, Schatzi;
Ammon, Doug; Scozzafava, MichaeiE
Subject: Update on status of West Lake and A TSDR Health Consultation
Mathy I Barry,
I wanted to provide you with a quick update on the status of our discussions with ATSDR
regarding their pending health consultation for the West Lake landfill.
Based on our discussions with ATSDR, they have modified how they are including the radon
recommendation, but they have not deleted the recommendation. They separated this
recommendation from the other site-specific recommendations, they state it is not related to the
landfill, and they cite the fact that St. Louis County has elevated levels of radon, and thus
recommend that people test for indoor radon.
In response to this latest change/draft, we provided a counterproposal to A TSDR. I have
provided our proposal below. You will see three requests in order of preference, from
completely deleting the recommendation, to putting it only in outreach materials, to making the
WLLFOIA4312- 001 – 0055627
language clearer that radon testing is generally good and not related to West Lake.
I also wanted to share a couple of points they have made during our discussion that might be
worth considering:
• They considered this recommendation somewhat analogous to health consultations for sites
with lead in soil, wherein they often weigh in on the importance of looking for other sources of
lead in households, such as lead paint, lead in toys, water/pipes, etc.
• They also thought it might be good to be clear about the elevated background radon levels
in St. Louis to help citizens’ understanding if they do find elevated levels in their homes.
So, we have provided these recommendations, and I have told them I would update you on our
discussions. Please let me know if you have any questions or need further information. Also, it
would be helpful to know whether you would be able to live with the Health Consultation going
out with our recommended new language, or whether you plan to elevate if I hear at my level
that they plan to proceed with the recommendation.
Thanks for your help and guidance – Dana
WLLFOIA4312- 001 – 0055628
Non-site related radon recommendation
Although unrelated to the landfill, inform residents to have their house
interiors tested for radon as the average indoor radon levels in St. Louis
County is known to higher than national levels ,~=~~~
Non-site related radon recommendation
ATSDR believes that radon migration through the soils on the West Lake landfill will not extend
past the landfill property. The average indoor radon levels from naturally occurring radon in St.
Louis County is known to be higher than national levels ,~=-==–==”-
As a general practice, the Surgeon General and EPA
recommend that all homes be tested for radon .~~~======~==~~~======
Dana Stalcup
Director, Assessment and Remediation Division
OSWER/Office of Superfund Remediation and Technology Innovation (OSRTI)
WLLFOIA4312- 001 – 0055629
Desk – 703-603-8702
Cell – 202-309-54 73
WLLFOIA4312- 001 – 0055630

Post

2016-01-22 – EPA – USACE – West Lake Landfill – Back-check of Comments to draft Comprehensive Phase 1 Report

To:
Cc:
From:
Sent:
Subject:
Robyn,
Kiefer, Robyn V NWK[Robyn.V.Kiefer@usace.army.mil]
Juett, Lynn[Juett.Lynn@epa.gov]; Vann, Bradley[Vann.Bradley@epa.gov]
Barker, Justin
Mon 1/25/2016 5:39:07 PM
RE: Back-check of Comments to draft Comp Phase 1 Report
Thanks for the quick turn-around. EPA will plan to finalize and send out the comment letter by COB
tomorrow. We will send USAGE a copy of the official comment letter, once submitted.
Thanks again,
Justin
—–Original Message—–
From: Kiefer, Robyn V NWK [mailto:Robyn.V.Kiefer@usace.army.mil]
Sent: Monday, January 25, 2016 10:51 AM
To: Barker, Justin
Cc: Juett, Lynn ; Vann, Bradley
Subject: RE: Back-check of Comments to draft Comp Phase 1 Report
Justin -we have backchecked these changes and have no issues with how our comments have been
incorporated.
Thanks,
Robyn
Robyn Kiefer
Project Manager
US Army Corps of Engineers
Kansas City District
Phone: 816-389-3615
—–Original Message—–
From: Barker, Justin [mailto:barker.justin@epa.gov]
Sent: Friday, January 22, 201611:18AM
To: Kiefer, Robyn V NWK
Cc: Juett, Lynn ; Vann, Bradley
Subject: [EXTERNAL] Back-check of Comments to draft Comp Phase 1 Report
Hi Robyn,
As discussed, for a back-check by USAGE, please find attached the comment letter for the draft
Comprehensive Phase 1 Report for OU-1 of the West Lake Landfill. The attached version of the
comments includes comments and input from EPA, USAGE and MDNR into a single comment letter.
USAGE provided review comments to EPA for this report on January 14, 2016, and EPA and USAGE
discussed the combined comments via teleconference on January 22, 2016. As discussed on the
teleconference some of the USAGE comments were modified or not included in the combined comment
letter. Specifically, comments #20, #22, #23, #24 and #27 were not included in the attached combined
WLLFOIA4312- 001 – 0058729
comment letter, mainly due to EPA already including a similar comment.
Please back-check the attached combined comment letter with your team and provide me or Brad
questions or additional input as warranted. To support the project schedule, EPA plans to distribute these
comments to EMSI next week, so timely feedback from USAGE on this information is greatly appreciated.
Please note that the attached comment letter document has not received final formatting or other checks
by our tech editor or senior staff, thus additional edits may occur by EPA during/following tech editing and
final reviews. Although it is not currently anticipated, EPA will plan to communicate with USAGE
regarding any significant changes made to the comment letter, if any should occur.
Thanks for the help and support,
Justin L. Barker
Missouri/Kansas Remedial Branch
Superfund Division
U.S. Environmental Protection Agency
11201 Renner Blvd
Lenexa, Kansas 66219
Phone: 913-551-7789
Cell 913-486-1661
Fax 913-551-9548
WLLFOIA4312- 001 – 0058730

Post

2016-01-04 – EPA – West Lake Landfill – Coordination for Release of information to the media

To:
From:
Sent:
Subject:
Weber, Rebecca[Weber.Rebecca@epa.gov]
Cozad, David
Mon 1/4/2016 3:09:11 PM
FW: RELEASE IS READY
From: Brees, Angela
Sent: Thursday, December 31,2015 5:00PM
To: Juett, Lynn
Cc: Hague, Mark ; Stoy, Alyse ; Cozad, David
; Peterson, Mary
Subject: Re: RELEASE IS READY
Last one I’ll link for today.
Angela M. Brees, Deputy Director
Office of Public Affairs
U.S. Environmental Protection Agency, Region 7
11201 Renner Blvd.
Lenexa, KS 66219
0: 913-551-7940
C: 816-663-2707
On Dec 31, 2015, at 3:46 PM, Brees, Angela wrote:
WLLFOIA4312- 001 – 0057913
1
19
81
From: Juett, Lynn
Sent: Thursday, December 31, 2015 2:45PM
To: Brees, Angela
Cc: Hague, Mark
7
David Peterson, Mary
Subject: Re: RELEASE IS READY
Release shared with MDNR and USACE.
I also shared the final version with Joe Benco with Republic.
Lynn Juett
913-551-7883
(Cell) 913-948-1129
Cozad,
WLLFOIA4312- 001 – 0057914
Sent from my iPhone
On Dec 31, 2015, at 2:01 PM, Brees, Angela wrote:
7
1
19
81
From: Hague, Mark
Sent: Thursday, December 31, 2015 1:57PM
To: Brees, Angela Juett, Lynn
Stoy, Alyse Cozad, David
Peterson, Mary
Subject: RE: RELEASE IS READY
From: Brees, Angela
Sent: Thursday, December 31,2015 1:55PM
To: Hague, Mark Juett, Lynn Stoy,
WLLFOIA4312- 001 – 0057915
Alyse Cozad, David ~~~~~~~~~· Peterson,
Mary
Subject: RE: RELEASE IS READY
7
1
19
81
From: Brees, Angela
Sent: Thursday, December 31, 2015 1:47PM
To: Hague, Mark Juett, Lynn
Alyse Cozad, David ~~~~~~~~~·
Mary
Subject: RELEASE IS READY
Once I have a final concur, we’ll start work on getting it out.
WLLFOIA4312- 001 – 0057916
1 1
19
81
WLLFOIA4312- 001 – 0057917

Post

2015-07-21 – EPA – West Lake Landfill – Conference call with USACE

To: Stoy, Alyse[Stoy.Aiyse@epa.gov]; Juett, Lynn[Juett.Lynn@epa.gov]
Cc: Field, Jeff[Field.Jeff@epa.gov]; Jackson, Robert W.[Jackson.Robertw@epa.gov]; Peterson,
Mary[Peterson.Mary@epa.gov]; Sanders, LaTonya[Sanders.Latonya@epa.gov]; Washburn,
Ben[washburn.ben@epa.gov]; Carey, Curtis[Carey.Curtis@epa.gov]; Whitley,
Christopher[Wh itley. Christopher@epa .gov]
From: Vann, Bradley
Sent: Tue 7/21/2015 2:59:50 PM
Subject: RE: West Lake Landfill
From: Vann, Bradley
Sent: Tuesday, July 21, 2015 9:47AM
To: Stoy, Alyse; Juett, Lynn
Cc: Field, Jeff; Jackson, Robert W.; Peterson, Mary; Sanders, LaTonya; Washburn, Ben; Carey,
Curtis; Whitley, Christopher
Subject: RE: West Lake Landfill
WLLFOIA4312- 001 – 0058775
From: Stoy, Alyse
Sent: Tuesday, July 21, 2015 9:40AM
To: Vann, Bradley; Juett, Lynn
Subject: Fwd: West Lake Landfill
Brad/Lynn- I just sent an email to Steven that a call tomorrow would be best. I’ve asked him to
send me some times that work for them. Can you two figure out who should be on this call from
our end?
Sent from my iPhone
WLLFOIA4312- 001 – 0058776
Begin forwarded message:
From: “Miller, Steven (GC)”
Date: July 21,2015 at 9:19:02 AM CDT
Cc: “‘Vann, Bradley”‘
Subject: RE: West Lake Landfill
From: Stoy, Alyse I.!Il§W1Q:J;ili;~~~~!MQ’YJ
Sent: Monday, July 20, 2015 11:18 AM
To: Miller, Steven (GC); ·'”-==’-‘=~-====~· ”–‘-‘=========:.;;_,
Cc: Vann, Bradley
Subject: RE: West Lake Landfill
Hi Steven/Phil-
Our RPM is still getting questions about a DOE point of contact for the West Lake
CAG. Do you have a public affairs POC that we can forward along? Thanks!
Alyse Stoy
Assoc. Deputy Regional Counsel for Enforcement
Office of Regional Counsel
U.S. EPA Region 7
(913) 551-7826 phone
(816) 807-3271 cell
WLLFOIA4312- 001 – 0058777
From: Stoy, Alyse
Sent: Friday, May 22, 2015 10:03 AM
To:~~~~~~~~*·~~~,~~~~~~~~~~-
Subject: West Lake Landfill
Hi Steven/Phil-
Quick question for you. The West Lake CAG (community advisory group) has
asked EPA the name of a DOE contact person. I don’t know the specifics of what
the community is wanting to contact DOE about, but will defer to you who the
appropriate contact would be. Let me know and we are happy to pass this
information along to the CAG.
Thanks, Alyse
Alyse Stay
Assoc. Deputy Regional Counsel for Enforcement
Office of Regional Counsel
U.S. EPA Region 7
(913) 551-7826 phone
(816) 807-3271 cell
WLLFOIA4312- 001 – 0058778

Post

2014-04-03 – EPA – West Lake Landfill – Draft response to Lois Gibbs Letter

To:
From:
Weber, Rebecca[Weber.Rebecca@epa.gov]; Tapp, Joshua[Tapp.Joshua@epa.gov]
Smith, Mark A.
Sent:
Subject:
Fri 4/3/2015 1 :54:08 PM
For discussion
From: Juett, Lynn
Sent: Thursday, April 02, 2015 4:35PM
To: Smith, Mark A.
Subject: Fwd: Revised briefing paper and draft response letter
Lynn Juett
913-551-7883
(Cell) 913-948-1129
Sent from my iPhone
Begin forwarded message:
From: “Juett, Lynn”
Date: April2, 2015 at 1:45:03 PM CDT
To: “Stalcup, Dana”
Subject: Revised briefing paper and draft response letter
Below is the revised version of the draft response letter that you can send up
through your management. Also, attached is a revised version of your
briefing paper.
WLLFOIA4312- 001 – 0057926
WLLFOIA4312- 001 – 0057927
WLLFOIA4312- 001 – 0057928

Post

2016-02-09 – EPA – West Lake Landfill – Notes on February 9, 2016 CAG meeting

To: Peterson, Mary[Peterson.Mary@epa.gov]; Hague, Mark[Hague.Mark@epa.gov]; Carey,
Curtis[Carey. Curtis@epa.gov]; Stoy, Alyse[Stoy.Alyse@epa.gov]
Cc: Washburn, Ben[washburn.ben@epa.gov]; Mahler, Tom[mahler.tom@epa.gov]; Vann,
Bradley[Vann.Bradley@epa.gov]
From: Juett, Lynn
Sent: Tue 2/9/2016 5:57:32 AM
Subject: CAG
WLLFOIA4312 – 001 – 0014038
WLLFOIA4312 – 001 – 0014039
WLLFOIA4312 – 001 – 0014040

Post

2016-02-18 – EPA – West Lake Landfill – EMSI – Regarding work plan for cover installation

To:
From:
Sent:
Subject:
Washburn, Ben[washburn.ben@epa.gov]
Barker, Justin
Thur 2/18/2016 5:18:14 PM
FW: Revised Work Plan for Non-Combustible Cover
From: Mahler, Tom
Sent: Wednesday, February 17, 2016 11: 11 PM
To: Barker, Justin ; Gieseke, Andrew
Subject: FW: Revised Work Plan for Non-Combustible Cover
Greene’
Subject: Revised Work Plan for Non-Combustible Cover
Juett,
Dan
‘Cecilia
WLLFOIA4312 – 001 – 0016276
Tom,
Attached is a revised Work Plan for the Removal Action- Non-Combustible Cover project. The
work plan has been revised to address EPA’ s comments provided on January 29, 2016 on the
prior (January 4, 2016) submittal. Also attached is a revised Health and Safety Plan that has
been modified to address EPA’ s comments. Because EPA did not have any comments on the
Sampling and Analysis Plan, Radiation Safety Plan, or the Quality Management Plan, I have not
included those documents with this submittal as the versions that were previously provided to
EPA on January 4, 2016 remain unchanged.
We received your e-mail this morning providing conditional approval of the work plan based on
the responses to the four comments identified in EPA’ s January 29, 2016 that we submitted to
you on February 9, 2016. EPA’s conditional approval included additional comments, in
particular a comment related to ARARs, that your e-mail indicated should be addressed in the
next submittal of the work plan. Unfortunately, we had already obtained client approval and
were in the process of preparing the final version of the work plan that is attached to this e-mail
before we received your e-mail. Due to the short time available today and the fact that it is
Friday at the start of a long holiday weekend, we could not address the additional comment
related to ARARs in this submittal. I will contact you next week to discuss how to proceed
relative to the ARARs comment.
Thank-you and have a great weekend.
WLLFOIA4312 – 001 – 0016277
WLLFOIA4312 – 001 – 0016278

Post

2016-05-23 – EPA – West Lake – SED Further sediment sampling and storm water flow information

From: Mahler, Tom
To: paulrosasco@emsidenver.com
Cc: Vann, Bradley; Barker, Justin; Gieseke, Andrew; Juett, Lynn; Stoy, Alyse
Subject: Further sediment sampling and storm water flow information
Date: Monday, May 23, 2016 1:55:00 PM
Attachments: QAPP for West Lake Landfill – Sediment Sampling_Revision 02.pdf
160-15647_DVR_Rad_6Jan16_RM.pdf
160-16583_DVR_Rad_13Mar16_RM.pdf
Paul,
As you are aware, three sediment samples were collected on January 6th, 2016 as part of
the Additional Characterization work for Area 1 and Area 2. For each of these three
samples, EPA collected splits. After reviewing the validated data from you and your clients
in addition to the EPA split samples data (see attached), EPA has determined that SED4
and EPA’s split for this sample (SED 4-EPA DUP) contain radionuclides which meet the
definition of RIM for OU-1 of the West Lake Landfill site. Specifically the Combined
Thorium concentrations for SED4 and SED 4-EPA DUP are 16.16 pCi/g and 20.63 pCi/g
respectively which exceeds the established limit of 7.9 pCi/g.
Additionally, EPA provided a QAPP for the collection of additional sediment samples which
has since been updated. I have attached an updated version of this QAPP which includes
an updated figure that depicts the previously collected sediment samples as well as new
proposed sample locations. Specifically the QAPP requires the collection of additional
sediment samples located between SED4 and the north corner of the West Lake Landfill
property along the drainage pathway for storm water situated between the OU-1, Area 2
fence line and St. Charles Rock Road.
EPA Region 7 requires further characterization of this portion of the landfill property as
soon as access is attainable and recent storm water recedes. We are requesting that the
PRPs perform a gamma walkover survey to determine if there are any elevated areas of
gamma radiation for which biased sediment samples could be collected. In addition, EPA
Region 7 will require 5 additional sediment samples be collected approximately every 100
feet between SED 4 and the north corner of the landfill property (see attached updated
figure from the QAAP). One of these sample locations will require the collection of a
duplicate sample for data quality purposes. Finally, because of the recent storm events
which have inundated this area with storm water, the collection of an additional sample
from the SED4 location will also be required. EPA will collect these samples or will collect
100% split samples. This work is to be performed during the week of May 23, 2016. If a
gamma survey cannot be performed the week of May 23, 2016, because of residual storm
water or excessive vegetation, it may be delayed until conditions change. Please move
forward with collection of the sediment samples regardless.
Finally, EPA is also requiring the PRPs to provide definitive information on the locations of
storm water drainage that runs along the east side of the West Lake complex located
between the norther portion of the Bridgeton landfill, OU-1 Area 1, and St. Charles Rock
Road. Please ensure to include information associated with the four drop boxes and/or
inlets located immediately North and South of the landfill entrance road, as well as whether
there is a connection between the stormwater collection pond(s) in the northeast portion of
the West Lake complex, and immediately north of the complex and the sediment pond to
the north of the complex and east of St Charles Rock Road. Please provide this
information by Wednesday, May 25, 2016
Please let me know if you have any questions about these proposed sampling plan. Also,
please coordinate with me on the timing for collection of the sediment samples.
Tom Mahler
On-Scene Coordinator
US EPA Region 7
913-551-7416

Post

2016-02-18 – EPA – AAA Trailer Services Investigation

To: pau lrosasco@emsidenver.com[pau I rosasco@emsidenver.com]
Cc: Vann, Bradley[Vann.Bradley@epa.gov]; Juett, Lynn[Juett.Lynn@epa.gov]; Barker,
Justin[barker.justin@epa.gov]; Gieseke, Andrew[Gieseke.Andrew@epa.gov]
From: Mahler, Tom
Sent: Thur 2/18/2016 9:25:17 PM
Subject: AAA Trailer Investigation
Hey Paul,
I just wanted to send you a summary of what we just discussed. MDNR and I met with John
O’Brien from AAA Trailer Services today. While there, MDNR provided John a summary table
of the analytical data from their November 2015 vicinity sampling event. I then explained that
EPA had an interest in further investigation occurring on the uncovered soil areas of AAA
Trailer services between their gravel parking lot and the West Lake Landfill Fence. I told him
that this investigation would involve conducting telemeterized gamma scanning and
confirmation surface soil sampling. I told him that the West Lake Responsible Parties’
Representative would be contacting him soon to obtain permission to have access to the property
to perform this investigation. I also mentioned you would likely send a form that would need to
be signed for this access. I told John he would be contacted at a minimum by the end of next
work week (February 26th)but likely sooner. He is ready and waiting to be contacted.
John also mentioned that he would prefer if possible for the investigation to occur on the
weekend when there would be less impacts to their day to day business. John said that he could
provide access to whatever parts of the property need investigation over the weekend.
Let me know if there are any questions,
Tom Mahler
On-Scene Coordinator
US EPA Region 7
816-604-0546
WLLFOIA4312 – 001 – 0015853

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