2009-12-28 – EPA – West Lake Landfill – EPA facing fresh pressure at key St. Louis-area radioactive landfill site

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2009-11-16 – EPA – West Lake Landfill – Cleanup of nuclear waste in landfill site on hold amid fears of precedent


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2010-02-08 – EPA – West Lake Landfill – Missouri radiation cleanup plan 18 times weaker than EPA precedent

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2010-06-28 – EPA – West Lake Landfill – EPA orders rare review of radioactive cleanup plan at precedential site


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2014-05-14 – EPA – West Lake Landfill – Why is EPA not testing drainage ditches at BMAC

Aboussie, Lou[[email protected]]
Sanders, LaTonya
Wed 5/14/2014 2:47:12 PM
RE: Westlake
Good Morning Lou,
EPA has no validated information indicating the need to screen for radiation outside of the West Lake
Landfill site. We are undertaking a screening of BMAC to allay public concerns at that heavily used
recreation complex. The screening methods EPA will use there have been employed at many sites
across the country and are supported by research and documented procedures. Soil sampling will also
be performed at BMAC to confirm the screening results. In their 2005 Record of Decision the U.S. Army
Corps of Engineers cited extensive Department of Energy sampling of the haul roads. None of the
samples collected exhibited radionuclide concentrations exceeding the proposed surface and subsurface
soil remediation goals identified in the ROD. Soil sampling conducted by MDNR in 2005 in the ditches
and shoulders along Boenker Lane and Taussig Road for radium, thorium and uranium did not identify
any high concentrations of these radionuclides. With regard to screening haul roads, they remain under
the purview of the USAGE FUSRAP program.
—–Original Message—–
From: Aboussie, Lou [mailto:[email protected]]
Sent: Tuesday, May 13, 2014 6:01 PM
To: Sanders, LaTonya
Subject: Re: Westlake
Just curious, does not have to be formal. Thx
—– Original Message —–
From: Sanders, LaTonya [mailto:[email protected]]
Sent: Tuesday, May 13, 2014 06:46PM
To: Aboussie, Lou
Subject: RE: Westlake
Hi Lou,
Working on a response.
—–Original Message—–
From: Aboussie, Lou [mailto:[email protected]]
Sent: Saturday, May 10, 2014 8:35AM
To: Sanders, LaTonya
Subject: Westlake
Why are the drainage ditches at BMAC not going to be tested? LA
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2013-03-27 – EPA – WEST LAKE LANDFILL BRIDGETON, MISSOURI – Questions and Answers

QUESTION: Why hasn’t EPA proposed to excavate the radiological waste at West Lake
Landfill, to be consistent with the ongoing excavation of similar radiological waste at the nearby
St. Louis Airport sites (SLAPS)?
While the wastes are similar at both sites, the pathways for people to be exposed to the material
at West Lake and SLAPS are very different
West Lake is fenced to prevent access, and the groundwater beneath the site is not being used for
drinking water. There are no current exposures to people.
The radiological waste at SLAPS is mainly at the surface along roads where the public could be
Existing risk assessments indicate that the West Lake waste can be safely managed by capping in
place as selected in the 2008 Record of Decision. However, due to extensive public interest, EPA
is currently re-evaluating the ROD remedy and several excavation remedies in more detail.
• EPA completed a Supplemental Feasibility Study in 2011 that re-evaluated the Record of
Decision remedy of cap-in-place as well as full excavation of the radiological waste with offsite
or on-site disposal.
• Region 7 presented the results of the SFS to the National Remedy Review Board as an “early
consultation” in February 2012, and the NRRB comments from this consultation resulted in
additional evaluations. The additional evaluations, including an evaluation of a partial
excavation alternative, are in work now by the potentially responsible parties and will result
in an addendum to the SFS report.
• The Lambert-St. Louis Airport Authority has expressed considerable interest in the remedy
to be selected, and has stated in writing that it views excavation of landfill waste so close to
the airport to constitute a bird strike hazard to aircraft.
• Questions received on this and related issues from Sens. Claire McCaskill and Roy Blunt,
Reps. William Lacy Clay
Dan Gravatt, 913-551-7324
Karl Brooks, 913-551-7006 3/27/2013
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QUESTION: What is EPA doing about the landfill fire or “subsurface smoldering event” at
West Lake?
• The landfill fire at West Lake is occurring underground in a non-radiological waste disposal
cell at the site which is permitted by the Missouri Department of Natural Resources
(MDNR). As the sole regulatory authority for this waste disposal cell, MDNR is responsible
for responding to the landfill fire.
• EPA and MDNR communicate regularly on the status of the fire and the PRP’s to contain
and put the fire out.
• The landfill fire was first discovered in December 2010 and reported to MDNR and the EPA.
• The landfill fire began to receive extensive press coverage in late 2012 when odors from the
fire increased and began to generate complaints from local residents and businesses.
• The landfill fire area is more than 1,000 feet from the nearest area of radiological waste.
• Questions received on this and related issues from Sens. Claire McCaskill and Roy Blunt,
Reps. William Lacy Clay and Ann Wagner.
The site is PRP-lead, meaning that the PRPs (including the U.S. Department of Energy) are
paying for the additional studies and site work, and are reimbursing EPA staff for its time in
overseeing the work.
Dan Gravatt, 913-551-7324
Karl Brooks, 913-551-7006 3/27/2013
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2015-04-02 – EPA – West Lake Landfill – Bridgeton Missouri CERCLA History

West Lake Landfill site, Bridgeton Missouri
CERCLA History
April2, 2015
• National Priority Listing (NPL) for West Lake
o West Lake Landfill was listed on the NPL in 1990 (See 55 FR 35502-25512, Aug.
30, 1990).
o The NPL listing package was primarily based on radioactive contamination;
however, the narrative summary mentions that there are other chemical
contaminants in the landfill.
o NPL listings are based on data of a sufficient nature to list the site but are not
inclusive of all contaminants that may present an unacceptable risk and do not
define the areal of extent of contamination.
• As noted in a 2012 HRS listing: The HRS does not require scoring all
pathways if scoring those pathways does not change the listing decision. The
HRS is a screening model that uses limited resources to determine whether a site
should be placed on the NPLfor evaluation and possible Superfund response. A
subsequent stage of the Superfund process, the remedial investigation (RI),
characterizes conditions and hazards at the site more comprehensively.
• For the West Lake site, Operable Unit (OU) 1 deals with landfills that contain RIM (and
other chemicals) and OU2 deals with the other non-RIM landfills at the NPL site.
• OUI had a Record of Decision (ROD) signed in 2008. Subsequent to the signature of the
ROD, concerns were raised by the Missouri Coalition for the Environment and others
regarding EPA’s decision to cap the Site and leave RIM in place. As a result, the Agency
chose to more thoroughly explore other potential alternate remedies, including full and
partial excavation. That has been the primary focus of work over the last few years,
including the NRRB consultation and ongoing work supported by OSRTI, ORD, and
• OU2 (non-RIM landfills) had a separate ROD signed in 2008 for the non-radiation
portion of the site.
o The ROD for OU2 (non-RIM landfills) states: “For areas operated under state
permit, i.e., the Former Active Sanitary Landfill and the Closed Demolition
Landfill, the terms of their respective permits dictate the appropriate closure and
post-closure care requirements. Successful completion of these requirements
would eliminate the need for further CERCLA action at these units. Consistent
with EPA’s policy on coordination between the Resource Conservation and
Recovery Act and CERCLA actions, these regulated units are deferred to the state
regulatory program.”
o The OU2 ROD indicates that the Former Active Sanitary Landfill, also known as
the Bridgeton Landfill, is part of the OU2 area The OU2 ROD requirements
• Installation of landfill cover meeting state sanitary landfill requirements
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• Groundwater monitoring consistent with requirements for sanitary
• Surface water runoff control
• Gas monitoring and control consistent with sanitary landfill requirements
• Institutional Controls
• Surveillance and maintenance of the remedy
o Because of the deferral, all of the activities and issues related to the Bridgeton
Landfill have been lead and managed by the State. This includes management of
the off-gassing, which has been an issue of significant community interest.
• The following maps are attached (please note the “North” arrows as the orientation can
vary from one map to the next):
o West Lake Landfill OU-2 map
• Shows the the overall boundaries and state permit coverages
o West Lake Site Layout for OU-1, which shows Radiological Areas 1 and 2
o West Lake Site vicinity map
• There also has been some recent discussion regarding a recent flyover.
o Based on discussions with the Region, in February 2015, a local fire department
official conducted a flyover using an infrared camera that supposedly indicated
that the North Quarry of the Bridgeton Landfill may have elevated temperatures.
Immediately north of the North Quarry is where RIM was found during 2014
sampling associated with locating an isolation barrier between the RIM and the
SSE. This could have led to the conclusion that the subsurface smoldering event
may have migrated to the radiation contamination areas.
o However, it appears that the State and the Region have determined that the data
from that flyover are not credible, due to concerns with the overall process,
equipment, etc.
o Thus, the Region and the State are no longer addressing the flyover. The Region
continues coordination with the state on review of the data from the temperature
probes and gas extraction wells to evaluate the possible movement of the SSE.
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2016-04-18 – EPA – 2008 Record of Decision – West Lake Landfill Community Dialogue Framework

2008 Record of
West Lake Landfill
Community Dialogue
April 18, 2016
Terrie Boguski, Skeo Solutions

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