1995-04-18 – Operable Unit 2 RI-FS Work Plan – Reference to 1993 underground fire

• OU-2 RI/FS WORK PLAN Rev. 0 1995 2-39 943-2848 earth and chemical covers, respectively; the odors... View Document


2014-09-29 – EPA – West Lake Landfill – Karl Brooks West Lake Landfill Earth City Meeting Talking Points

Monday, September 29, 2014
11:00 a.m. -12:00 p.m.
John Basilica, Senior Consultant, Earth City Board of Trustees (EPA contact)
Steve Schulte, Trustee/Chairman, Earth City Board of Trustees
Michael Reynoso, Trustee, Earth City Board of Trustees
Terry McCaffrey, Trustee, Earth City Board of Trustees
Brad Weston, Trustee, Earth City Board of Trustees
Toby Martin, Senior Vice President, Duke Realty Corporation*
Jon Hinds, Vice President, Duke Realty Corporation
Christy Lucido, Senior Property Manager, Duke Realty Corporation
Ryan Hodges, President, Earth City Levee District
Jerry Leigh, President, AMCI, Inc.*
*Duke Realty is the largest property owner within Earth City.
* AMCI Inc. is another property owner/developer within Earth City.
The attendees of this meeting represent senior leadership of Earth City; Duke Realty, and AMCI,
Inc. Staff level employees are not anticipated to attend.
LOCATION: Frontenac Bank
The meeting will take place in a conference room within Frontenac Bank. There will be a
conference phone available. We will open a conference line here in the Regional Office and
Shawn Grindstaff will dial in from the meeting room’s conference phone.
STAFF: Shawn Grindstaff will attend in person: 636-358-9154. Ben Washburn,
Mary Peterson, Dan Gravatt, Jeff Field, and Lynn Slugantz will attend by phone.
• Isolation Barrier
• Subsurface Smoldering Event
• EPA Progress
• Next Steps
FORMAT: 1 hour meeting with Q&A
This will be an opportunity for you to share with the Earth City Board of Trustees and major
businesses/property owners the status of work being done at the West Lake Landfill site, discuss
concerns and answer questions
Talking points – (p. 2)
Questions submitted by Earth City Board of Trustees – (p. 5)
Additional questions and answers- (p. 7)
WLLFOIA4312- 001 – 0057220
Talking Points
West Lake Landfill Earth City Meeting Talking Points
Karl Brooks, Regional Administrator
September 29, 2014
1. Site Background
The West Lake Landfill Superfund Site is located on a 200-acre parcel about one
mile north of the I-70 interchange within the city limits of Bridgeton, Mo., in
northwestern St. Louis County. The Earth City Industrial Park is adjacent to the
Site on the west. The Spanish Village residential subdivision is located less than
one mile to the south and a trailer park is located Y2 mile to the southeast.
Two areas of the Site were radiologically-contaminated in 1973 when soils mixed
with leached barium sulfate residues were used as daily and intermediate cover in
the landfill operations. The barium sulfate residues, containing traces of uranium,
thorium, and their long-lived daughter products, were some of the uranium ore
processing residues generated by Mallinckrodt at its downtown St. Louis plant
and were initially stored by the Atomic Energy Commission (AEC) on a 21.7-acre
tract ofland in a then undeveloped area of north St. Louis County, now known as
the St. Louis Airport Site (SLAPS). This area is part of the St. Louis Formerly
Utilized Sites Remedial Action Program managed by the U.S. Army Corps of
Engineers (COE). The radium and lead-bearing residues- known as K-65
residues- were stored in drums prior to being relocated to federal facilities in
New York and Ohio.
In 1966 and 1967, the remaining residues from SLAPS were purchased by a
private company for mineral recovery and placed in storage at a nearby facility on
Latty A venue under an AEC license. Most of the residues were shipped to Canon
City, Colorado for reprocessing except for the leached barium sulfate residues,
which were least valuable in terms of mineral content, i.e., most of the uranium
and radium was removed in previous precipitation steps. Reportedly, 8,700 tons
of leached barium sulfate residues were mixed with approximately 39,000 tons of
soil and then transported to the Site. According to the landfill operator, the soil
was used as cover for municipal refuse in routine landfill operations. The data
collected during the Remedial Investigation (RI) are consistent with this account.
The quarry pits were used for permitted solid waste landfill operations beginning
in 1979. In August 2005, the Bridgeton Sanitary Landfill (Former Active
Sanitary Landfill) stopped receiving waste, pursuant to an agreement with the city
of St. Louis to reduce the potential for birds to interfere with airport operations.
The Site is divided into two operable units (OUs), each with identifying areas.
OU -1 consists of radiological areas 1 and 2 and the Buffer Zone/Crossroad
Property; OU-2 consists of the other landfilled areas which did not receive any of
the radiologically-contaminated soil:
WLLFOIA4312- 001 – 0057221
• Radiological Area 1 -Approximately 10 acres are impacted by radionuclides.
The radionuclides are in soil material that is intermixed with the overall landfill
matrix consisting of municipal refuse. The total volume of radiologicallyimpacted
materials is estimated at 33,500 cubic yards.
• Radiological Area 2 – This area was also part of the unregulated landfill
operations conducted prior to 1974. Approximately 30 acres are impacted by
radionuclides. The radionuclides are in soil material that is intermixed with the
overall landfill matrix consisting mostly of construction and demolition debris.
The total volume of radiologically-impacted materials is estimated at 302,000
cubic yards.
• Buffer Zone/Crossroad Property – This property, also known as the Ford
Property, lies west of Radiological Area 2 and became surficially-contaminated
when erosion of soil from the landfill berm resulted in the transport of
radiologically-contaminated soils from Area 2 onto the adjacent property.
• Closed Demolition Landfill -This area is located on the southeast side of
Radiological Area 2. This landfill received demolition debris. It received none of
the radiologically-contaminated soil. It operated under a permit with the State
and was closed in 1995.
• Inactive Sanitary Landfill -This landfill is located south of Radiological Area 2
and was part of the unregulated landfill operations conducted prior to 197 4. The
landfill contains sanitary wastes and a variety of other solid wastes and
demolition debris. It received none of the radiologically-contaminated soil.
• Former Active Sanitary Landfill – This municipal solid waste landfill, known as
the Bridgeton Landfill, is located on the south and east portions of the Site. The
landfill is subject to a State permit, which was issued in 1974. This landfill
received none of the radiologically-contaminated soil. Landfill operations ceased
in 2005 and closure and post-closure activities are currently in progress by
MDNR in accordance with Missouri Solid Waste rules and regulations.
2. Ongoing Activities
a. Subsurface Smoldering Event
i. There is a SSE occurring on the Bridgeton LF side of the site. This piece
of the site is managed under state authority and the work is being
conducted by Republic Services. Republic has an extensive network of
gas extraction wells and temperature monitoring probes to monitor the
event, and currently has plans to expand its monitoring network. EPA
WLLFOIA4312- 001 – 0057222
maintains routine communication with MDNR to stay informed about the
SSE. All current data suggest the SSE remains distant from the areas
containing known RIM.
b. Isolation Barrier
i. EPA has been working with the PRPs to develop plans for a barrier that
would serve to prevent the SSE from contacting areas known to contain
ii. This is an enormously complex project from an engineering
111. To assist in evaluating the complexities, advantages, and
disadvantages of the various IB alternatives, EPA has enlisted the
expertise of the US ACE.
iv. The USACE has prepared an initial assessment report of the IB
alternatives, and the PRPs have recently been tasked to produce more
detailed plans by mid-October.
v. The more detailed plans will include bird mitigation plans to
address the threat of potential bird strikes, given the proximity to the
vi. The SLAA and FAA must approve these plans before additional
work can proceed.
c. Off-Site Air Monitoring
i. EPA has established an air monitoring system in the offsite areas
surrounding the WLL Site. This system includes 5 air monitoring stations
that collect data for a variety of constituents. A local field office has been
set up as the control center for the air monitoring network, which is staffed
each week by EPA On-Scene Coordinators and contractors. The field
office has recently been relocated due to planned construction activities at
the Fire Station.
3. What’s Next?
a. EPA will review the detailed plans for the IB alignment alternatives due midOctober.
b. EPA will review the Bird Mitigation plans also due mid-October, and will
coordinate that review with the SLAA and FAA.
c. EPA will review the USGS report regarding groundwater data, and will
communicate with the public regarding the conclusions.
d. EPA continues to progress toward selection of a final remedy. We expect to
approve work plans very soon for the next stages of Feasibility Study work that
must be completed to support a new Proposed Plan and Record of Decision.
4. Engagement Opportunities/Information Needs
a. EPA wants to keep stakeholders informed. There are a variety of ways to do that.
How can we best accomplish that for the Earth City Business Park? How would
you like to be kept informed?
i. Periodic meetings?
11. Receive periodic Fact sheets?
WLLFOIA4312- 001 – 0057223
111. Receive WL Update via email?
b. Are there specific topics or subjects that would be especially helpful or beneficial
for your constituents?
1. Briefly explain EPA’s role at West Lake Landfill as set forth in Superfund law.
EPA’s role at the West Lake Site is to act as the regulatory agency in charge of the
remediation at the landfill. As such, EPA has the final and ultimate decision making
authority and can direct the PRPs to take actions at the site as appropriate to protect
human health and the environment.
2. Briefly explain the role of Republic Services and others in determining the final
resolution of the landfill matter.
The Potentially Responsible Parties, of which Republic Services is one, conduct site
investigations and evaluations at the direction of EPA. The results of these, such as the
currently on-going Supplemental Supplemental Feasibility Study (SSFS) are sent to EPA
for careful review and approval. While these technical documents form the basis for
decisions, the final decision of the site remedy remains with EPA.
3. Is cost the primary reason EPA favors keeping the radioactive material in place with the
addition of safety improvements?
Cost is only one of nine criteria the NCP requires EPA to consider.
In the case of West Lake Landfill, other considerations include time to complete an
excavation, safety of flight operations and the flying public at the airport, and the
complexity of an excavation project due to the depth of the landfill.
4. Why after 40 years is there still an issue with the location of the radioactive material? Is
EPA investigating all other landfill areas not previously investigated for radioactive
The recent investigations into the location of the radiologically impacted material (RIM)
have been focused on finding the best location to install the proposed isolation barrier.
5. Is there an area-wide health risk in removing and relocating the radioactive material?
There is increased risk of human exposures associated with excavation and removal of
the material. Also important is the attraction of birds to the newly excavated waste,
which could pose a threat to flight operations and the safety of the flying public at the
airport and the communities near the airport.
WLLFOIA4312- 001 – 0057224
6. Briefly discuss the underground fire and construction of the barrier.
The Missouri Attorney General ordered Republic Services to construct the isolation
barrier in 2013. Work has been progressing with Republic Services on potential designs
of the isolation barrier since the order. Additionally, EPA has entered into an InterAgency
Agreement with the United States Army Corps of Engineers to assist with preconstruction
and construction activities at the site. Some preconstruction activities have
already begun; EPA has installed a robust air monitoring system around the landfill to
establish baseline air quality levels and a wind-blown debris barrier has been installed to
capture any debris generated during the excavation of the landfill to construct the barrier.
The PRPs are currently preparing detailed barrier alignment alternatives which will be
submitted to EPA and USACE for review. The St. Louis Airport Authority also has a
keen interest in these plans and bird mitigation plans that must be approved. Once an
alignment has been selected, planning for construction will begin in earnest. USACE
estimates construction of the isolation barrier could start in approximately 18 months.
The long planning period required reflects the scientific and engineering challenges of
this project, for which there is no parallel in the United States.
WLLFOIA4312- 001 – 0057225
1. I spend more than 40 hours a week working here. Am I at risk?
The site is protective of public health. EPA has no data to indicate there is any off-site
exposure to contaminants at the West Lake site.
2. Is it possible that these buildings might be condemned as part of the final remediation?
What about temporary closures during any digging for the isolation barrier?
There is no reason to believe the radioactive materials buried deep underground at the
landfill would requiring moving facilities or people. We will do everything we can to
ensure the potentially responsible parties conduct any type of remediation efforts in a
way to minimize impact on the businesses here. Typically, tenants are removed and
buildings demolished only if the selected remedy cannot be completed with those
buildings in place where they are. For example, if excavation is needed underneath a
building, then that building would have to be removed. EPA does not anticipate this at
the West Lake site.
The PRP may offer voluntary relocation to nearby residents during constmction of the
isolation barrier due to nuisance odors resulting from excavated waste. However, EPA
cannot compel the PRPs to offer this service.
3. The MDHSS study that just came said there are increased chance of getting cancer.
What can you tell me about that?
EPA Region 7 is reviewing the Coldwater Creek area cancer study conducted by the
Missouri Department of Health and Senior Services. As EPA continues to exercise its
authorities under the Superfund law, we will consider the MDHSS study as part of the
body of scientific data. We know the data will be of concern to many. While MDHSS is
seeking the involvement of the Agency for Toxic Substances and Disease Registry
(ATSDR) and the Centers for Disease Control (CDC) for further studies, we want people
to know that we are aggressively pursuing a final remedy at the West Lake Landfill site
to ensure the protection of public health there.
EPA appreciates the work ofMDHSS in producing this report, and looks forward to
continued cooperative efforts with MDHSS and other partners as we work to protect
human health and the environment in and around St. Louis.
4. You’ve kind of told us that we’re okay here and not at greater risk of cancer. If so, why
are you telling the PRPs to spend all that money to do all this work. Isn’t the site already
WLLFOIA4312- 001 – 0057226
The site is protective of public health to the neighborhoods in this area. However, it is
not a sustainable proposition for the long term to leave the landfill as is. That leads to a
science and engineering discussion on the best and most viable way to ensure protection
of public health for decades to come. Additionally, after the selection and
implementation of a final remedy at the site, EPA will continue to study and monitor the
site to ensure that the remedy remains protective.
5. In 2008 you announced a decision to cap the landfill (ROD). Why did you decide to
review that decision? Seems like the work would be done already if you had directed the
PRPs to cap it.
EPA decided to conduct additional site investigations after issuing the 2008 Record of
Decision due to continued community concerns about the selected remedy, which was to
install an engineered cap over the landfill with the implementation of institutional
controls to prevent risk of exposures.
WLLFOIA4312- 001 – 0057227
WLLFOIA4312- 001 – 0057228


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

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
WLLFOIA4312- 001 – 0057177
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
WLLFOIA4312- 001 – 0057178
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
WLLFOIA4312- 001 – 0057179
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.
WLLFOIA4312- 001 – 0057180


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

Stoy, Alyse[[email protected]]; Peterson, Mary[[email protected]]
Juett, Lynn
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
• 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
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


2015-12-12 – EPA – West Lake Landfill – Analysis of requests to transfer authority to USACE

Hague, Mark[[email protected]]
Woolford, James
Sat 12/12/2015 8:24:55 PM
I sent this and then, catching up on email, saw your note.
We argue similar points.
Let me know if I can help further.
Jim Woolford, Director
Office of Superfund Remediation & Technology Innovation
Sent from my Windows Phone
Please excuse typos
Here are arguments from the Missouri coalition for the environment:
1) The St. Louis Army Corps of Engineers Formerly Utilized Sites Remedial Action Program
must be put in charge of the site now! The Corps is right for the job because:
West Lake Landfill deserves a much needed second opinion after mistakes made by the EPA,
it removes a significant amount of influence that Republic Services and Exelon Energy currently
enjoy as a Superfund site,
the Corps has the technical expertise and track record for the safe cleanup of radioactively
contaminated sites in the St. Louis metro area,
workers are better protected and compensated at FUSRAP sites than EPA Superfund sites,
the Corps is already familiar with the site through current interagency agreements with EPA
Region 7 so the transfer will be smooth,
the Corps office is local and therefore more accessible to the community
2) MCE supports the safe removal of the radioactive wastes from the West Lake Landfill
because the EPA’s 2008 decision to “cap-and-leave” the wastes will remain a constant threat to
our drinking water, public health, and our environment. The safe removal of the illegally dumped
radioactive wastes is necessary because the West Lake Landfill:
was never designed to permanently store radioactive material,
has no liner separating the radioactive material from the groundwater,
is in the floodplain of the Missouri River,
is upstream from St. Louis regional drinking water intakes,
is in an urban area,
is vulnerable to earthquakes,
is threatened by a smoldering landfill fire or future fires,
is susceptible to tornadoes, and
WLLFOIA4312- 001 – 0055676
is at a site never designed to temporarily or permanently store radioactive material.
I have little exposure to the USACE-FUSRAP program since I went over to OSRTI.
Background. Around 1997 Congress transferred responsibility for remediating some of the
former DOE sites to the USACE. DOE and the USACE then signed a MOU defining their
respective responsibilities. The Legacy Management office at DOE has responsibility for
monitoring the sites and operating any technologies and ICs.
The USACE did get the St Louis property sites which were in reality not nearly as technically
challenging as WLL. Generally these properties had some radioactively contaminated soils as
fill. Most of the cleanup has been a relatively simple dig and haul although special precautions
were required due to the radioactivity. Most if not all if these properties/sites were on the NPL
and thus had EPA oversight from Region 7.
Interestingly, remediation work at the sites in and around St. Louis has been going on for almost
20 years. The most recent ROD was 10 yrs ago and remediation work is still going on. Not
exactly expeditious.
The challenge the USACE will have is there is an actively engaged PRP doing work. The
FUSRAP sites where the USACE has responsibility don’t typically have this element as far as I
can recall. That is, they are doing the work and not overseeing PRPs doing work. I don’t think
they are particularly well suited to perform such a task. The MCE seems to believe the USACE
can somehow ignore the PRPs. I can’t see that happening unless there is a cash out
settlement. The PRPs to date have not signaled any such interest.
I cld find 3 LFs in the USACE’s FUSRAP portfolio. At each, (the Tonawanda LF in NY,
Middlesex Muni LF in NJ and Shpack LF in Mass ) the USACE is doing the work. I could not
find any evidence of PRP involvement with the USACE .
Shpack is on the NPL abd has a separate EPA I PRP element. The USACE did excavate rad
waste there – about 50 k cubic yards. The entire site achieved CC about a year ago. Not all rad
contamination was excavated.
At Tonawanda LF, the most recent info I cld find is the USACE has issued a PP in Sept 2015
with the following preferred alternative : “targeted shallow removal and off site disposal of fusraprelated
material to address the contaminated soils in the LF OU”. The removal depth is approx 5
ft. 1000 yr post closure monitoring is also included. They propose to leave more deeply buried
waste in place. Public comment pd closes Dec 14. Remedy is estimated to cost about $12M.
They proposed a “deep excavation” alternative costing about $55M. It was not their preferred
alt. Each alternative has off site disposal.
I mention the above becz if the rationale or belief behind the legislative push for a change to the
USACE is that the LF will be excavated and all the rad/FUSRAP waste will be removed, that is a
huge leap of faith. Tonawanda is in many respects most similar to WLL.
PROS and CONS for transfer
WLLFOIA4312- 001 – 0055677
1) Significant public discontent with EPA. (but the allegations of mismanagement stem from
disagreement with the first ROD and that the subsequent work has not resulted in a new ROD
requiring full excavation of all the rad waste.)
2) USACE generally has good reputation in StLouis area
3). The radioactive waste is similar to FUSRAP-related materials. Some argue it is. USACE has
experience here.
4). USACE had some knowledge of site due to support on the subsurface smoldering eventbut
not the WLL site – so an easy transition is not a given
5) site has been a significant investment for R 7 – they cld redirect to other sites
1) USACE does not have experience working with or overseeing PRPs
2). Uncertain PRP reaction- PRP has generally been cooperative with EPA. Republic owns the
LF. When the legislation was announced, their statements were in opposition citing potential for
significant delays.
3). Despite community negativity, work on both the SSI and the characterization of the WLL has
been progressing. Sorting thru the USACE role and bringing the USACE up to speed will likely
stop progress towards a new PP.
4) related to #3- there are a number of EPA enforcement instruments- AOCs and UAOs- in
place that cover WLL. Not clear how the legislation would/ could affect. What happens with
special account? Can USACE access?
5). The US (DOE) is a PRP. Negotiations have been ongoing with them and DOJ I ED.
6). Outcome/remedy could be not much different than an EPA-lead process. The work has to
go thru the same CERCLA process. Full excavation faces two significant challenges that I see :
1 – FAA concerns about bird strikes from SL airport and 2- not likely to be a cost effective
remedy under CERCLA.
There is no evidence of off site contaminated GW migration and the GW likely will be monitored
at the fenceline. If CoCs are identified, then the remedy will be to pump and treat- that will be
less costly and safer -see FAA- than full excavation. Same level of protectiveness.
Tornadoes are surface events. Assuming there is a cap of substance, it a tornado very unlikely
to have an effect. Not far away from here is the above ground (75 feet) DOE Weldon Springs
waste storage facility/disposal cell- part of a state park if memory serves. It is much more
vulnerable to tornadoes. It has, according a website., 1.5 M cubic yards of hazardous wastes.
7). I have heard DOE does not support
8). Not sure about the USACE- but I think they are not in support
WLLFOIA4312- 001 – 0055678
9). Putting site under the USACE is one thing, will they have resources to address? Likely would
adversely affect delay other FUSRAP sites if no more funding.
Jim Woolford, Director
Office of Superfund Remediation & Technology Innovation
Sent from my Windows Phone
Please excuse typos
Can you give me your thoughts on this question? I frankly can make an argument both ways
Mathy Stanislaus
USEP A Assistant Administrator
Begin forwarded message:
From: “Distefano, Nichole”
Date: December 11,2015 at 7:51:42 PM EST
To: “Stanislaus, Mathy” “Hague, Mark”
Subject: WLL
Mathy and Mark
I am going to raise the WLL issue with Gina via email.
I need to know from you both how strongly you feel about her weighing in on this. There
may be a couple of things she can try to do if we want to suggest she try to stop it – though
it may not work. She also may come to that conclusion on her own. That said, I need to
know from you all what you would suggest.
She gets back on Sunday so she may want to discuss with us when she lands.
Sent from my iPhone
WLLFOIA4312- 001 – 0055679


2016-07-20 – West Lake Landfill – Evaluation of the Selected Remedy for Operable Unit-1 at the West Lake Landfill

DATED: 20 July 2016
Robert Alvarez
Senior Scholar
Institute for Policy Studies
Lucas W. Hixson
Director, Field Operations
Environmental Services
1 | P a g e 07/20/2016
In 1973, uranium ore processing residues from the production of nuclear weapons, mixed with contaminated soil from the Latty Avenue Site in Hazelwood, Missouri were transported and illegally dumped in the West Lake Landfill in Bridgeton, Missouri. Currently there are known concentrations of radiologically impacted material (RIM) in areas of the landfill designated by the US Environmental Protection Agency (EPA) as Operable Unit 1 Area 1 and Area 2. The full extent of the contamination relative to the potential impact of an adjacent underground fire* has not yet been determined. However, EPA experts indicate that sufficient data exists to support removal of these materials.
In 2008, the Environmental Protection Agency (EPA) proposed a Record of Decision (ROD) related to the Operable Unit-1 (OU-1) at the West Lake Landfill (EPA 2008)3. The EPA remedy proposes “in-place” disposal with the installation of a cap/cover over portions of the landfill and long-term monitoring of groundwater at the site.
Internal communications from EPA’s expert reviewers reveal that the proposed remedy is unlikely to protect thousands of urban residents from concentrated radioactive wastes in the floodplain of the Missouri River.
EPA internal analyses find that:
1. The EPA cannot ensure the protectiveness of the cap/cover for toxic uranium processing wastes, in an unlined landfill, that become increasingly radioactive for thousands of years.
2. Radioactive materials attributable to the waste materials at the West Lake Landfill have already been detected in the air, groundwater, surface soils, sediments, and vegetation around the site — at or above regulated standards.
3. An underground fire burning in the wastes in the adjacent Bridgeton Sanitary Landfill compromises the cap/cover remedy by increasing radiological emissions and offsite exposures.
4. The radioactive materials in the landfill can be removed and transported to a licensed radioactive waste landfill without unacceptable risk to the public. However, delays in removal will increase costs and long-term exposures to the public.
*U.S. Fire Administration, Topical Fire Research Series, Landfill Fires, Volume 1, Issue 18 March 2001 (Rev. December 2001)”Spontaneous heating is attributed to 5% of landfill fires. This occurs when underground, decomposing waste rising in temperature combusts as it comes in contact with a methane gas pocket. This is known as a “hotspot…” http://nfa.usfa.dhs.gov/downloads/pdf/statistics/v1i18-508.pdf.
Evaluation of the EPA Selected Remedy for Operable Unit-1 (OU-1) at the West Lake Landfill
This report provides a summary of observations based on internal communications and recommendations provided by Environmental Protection Agency (EPA) experts in documents published by Agency, including technical experts from the EPA Office of Research and Development, Engineering Technical Support Center (ETSC)1 in 2014 and from the EPA National Remedy Review Board (NRRB)2 in 2013- which was withheld from the public until mid-2016.
Evaluation of the EPA Selected Remedy for Operable Unit-1 at the West Lake Landfill 2 | P a g e
1. The EPA cannot ensure the protectiveness of the cap/cover of toxic uranium processing wastes, in an unlined landfill, that become increasingly radioactive for thousands of years.
a. The EPA’s own experts pointed out the known shortcomings with the proposed remedy design and recommended that Region 7 look into alternative remedies;4
In March 2013, EPA experts from the National Remedy Review Board (NRRB) stated that: “[the proposed remedy] lacked sufficient information on the long-term protectiveness of this alternative.” Furthermore, the NRRB stated: “both of the landfill designs (RCRA Subtitle D and UMTRCA) proposed in the 2008 ROD and 2011 SFS have known shortcomings for handling radioactive waste by itself, let alone handling radioactive waste in a humid region as it would be at the West Lake Landfill.”
The proposed remedy set an unprecedented limit for radiological contamination that was 18 times greater than previously allowed for such wastes located in an urban area.5
The NRRB recommended that instead of enclosing the wastes that Region 7 should excavate the radiological waste and transport it to facilities designed to provide long-term management for such materials.6
The NRRB also determined that the proposed long-term monitoring of the groundwater by itself is not a CERCLA remedy and so could not be a component of the ROD selected remedy.
b. The radiologically-impacted material in the West Lake Landfill is highly toxic and will increase in radioactivity and toxicity over time leading to increased risk to the public;7
The known radiologically-impacted material (RIM) disposed of in the West Lake Landfill is out of secular equilibrium and as daughter products grow back into normal concentrations, the waste materials will increase in radioactivity, toxicity, and risk to the public over time for the at least 10,000 years.
The EPA National Remedy Review Board (NRRB) detailed the dangerous nature of the materials noting, “Based on the package provided to the Board, it appears that there are potentially significant amounts of RIM that are highly toxic (e.g., based on NRC estimates in the 1982 and 1988 reports, radium of up to 22,000 pCi/g, bismuth-214 up to 19,000 pCi/g, and average thorium-230 concentrations of 9,000 pCi/g.” and; “Given the presence of highly radioactive material at this site, and the fact that its hazardous nature will continue to increase over time, the Board believes excavating and/or treatment of any amount of the RIM should lead to important risk reduction.”
The EPA’s cap/cover remedy proposed in the 2008 ROD and 2011 Supplemental Feasibility Study (SFS) does not address the in-growth of radioactivity over time that will occur in the landfill.
3 | P a g e 07/20/2016
c) The EPA’s proposed cap/cover would not protect the groundwater within and beyond around the landfill from becoming contaminated;
The EPA has not demonstrated that the groundwater can be protected from contamination if the cap/cover remedy as proposed in the 2008 ROD and 2011 SFS is approved. Samples of groundwater at the landfill have found levels of contamination that greatly exceed federal permissible maximum contaminant levels (MCLs) and indicate both the off-site migration of groundwater as well as the potential impact on offsite vegetation.8 9 Exceeding an MCL in groundwater would require a response action according to CERCLA protocol.10,11
The West Lake Landfill is an unlined landfill with no engineering barriers12 in the alluvial floodplain waters that flow into the Missouri River, upstream of the confluence with the Mississippi River. Groundwater levels can highly fluctuate according to rainfall event, and river levels can interact directly with surface water and groundwater runoff near the landfill. Because of the lack of engineered protection at the landfill, groundwater at the site can come into contact with RIM material and spread contamination in the highly permeable alluvial aquifer, and into the deeper bedrock aquifer.
It is extremely difficult to clean up contaminated groundwater. Every available corrective action to prevent groundwater contamination by RIM material in the West Lake Landfill should be considered. As long as the radioactive material remains in the landfill, the groundwater will continue to be contaminated.
d) EPA experts have raised serious concerns with the analysis and characterization of the RIM at West Lake;
In 2013, the NRRB raised a number of serious concerns with “…the way the nature and extent of the RIM at the site was characterized….” The Board pointed out that most of the RIM is located at or near the surface of the landfill (within 10 feet of the surface) as opposed to characterizations made in the ROD and SFS that the materials would be difficult to excavate. The lack of cover materials increases risk to members of the public, because there few if any barriers preventing the migration of radioactive materials and gases from the landfill into the air, groundwater and local environment around the facility.13
The EPA Office of Research and Development (ORD) pointed out that the lack of accurate accounting of the radioactive wastes at West Lake increases the uncertainties related to the potential impacts of the underground fire, at the adjacent Bridgeton Landfill.14
e) Alternative remedies could provide a more permanent remedy protective of the public;
The EPA National Remedy Review Board (NRRB) pointed out that the latest technologies could be employed to sort RIM from Non-RIM materials. The radioactive wastes could be then be sent to a dedicated and regulated radioactive disposal facility,
“Given the presence of highly radioactive material at this site, and the fact that its hazardous nature will continue to increase over time, the Board believes excavating and/or treating any amount of the RIM should lead to important risk reduction. Where it appears that much if not all of the RIM is located near the surface, cleanup at this site appears less complicated than other sites….Radiological material is also easily sorted out in the field with portable instruments that provide instantaneous measurements to ensure that only contaminated material is retrieved which, in turn, minimizes disposal costs.”
Evaluation of the EPA Selected Remedy for Operable Unit-1 at the West Lake Landfill 4 | P a g e
2. Radioactive wastes from the West Lake Landfill have already been detected in the air, groundwater, surface soils trees and other vegetation around the site, at levels above federal permissible Maximum Contamination Levels (MCLs).
Uranium, thorium and their related decay products have been detected in off-site vegetation on private properties around the landfill.15
RIM material has migrated beyond the landfill by surface water transport during strong rainfall events.16
Samples of groundwater at and around the landfill have found levels of contamination that exceed standards.17
Measurements of radon in air conducted for the 2011 SFS found concentrations of radon that nearly exceeded UMTRCA standards.
Levels of unsupported lead have been detected in the local environment around the landfill out of equilibrium with background levels of radon and radium.18
3. An underground fire, burning in the adjacent Bridgeton Sanitary Landfill, could seriously compromise the cap/cover remedy by increasing radiological emissions and offsite exposures.
In December 2010, operators of the Bridgeton Sanitary Landfill detected elevated temperatures and carbon monoxide levels indicating an underground fire was burning in an area adjacent to and connected with known contaminated areas of the West Lake Landfill. The movement of the underground fire in the South Quarry has been unpredictable and there are no estimates of the length of time it would take for the underground fire to reach the RIM in Area 1.
The threat of an underground fire reaching the nuclear waste was of such concern that the Potential Responsible Parties (PRPs) contracted a company called Engineering Management Support, Inc. (EMSI) to prepare a report the potential risks that would be generated if the fire were to interact with the RIM materials. The EMSI report was released to the public in January 2014.
On March 28, 2014, at the request of the EPA, a technical review of the EMSI report on the potential impacts of fire was conducted by the Office of Research and Development – who predicted that an underground fire in OU-1 would:
• Create long-term risks to people and the environment;19
• Limit the effectiveness of the proposed remedy in the 2008 ROD and 2011 SFS, even with a proper cap/cover design, inspection and maintenance;2021
• Increase the temperature and pressure conditions within the landfill, generating large amounts of steam and forcing out a larger volume of gases (including radon) and fine particulates into the local environment;22
• Increase production of contaminated leachate and dissolved gases that can migrate into the groundwater;23
5 | P a g e 07/20/2016
• Increase potential for releases of radon at levels of concern;
i. Measurements of radon around the landfill for the 2011 SFS recorded concentrations close to Uranium Mill Tailings Radiation Control Act (UMTRCA) standards.24
ii. An underground fire in OU-1 would be expected to further reduce the ability of the waste materials to retain radon gas. By reducing the amount of moisture in the buried wastes, thereby increasing the space between soil particles, more radon will escape;25
• A cap/cover installed over impacted areas at the West Lake Landfill could also hinder efforts to monitor and respond to future underground fire events.26
4. The radioactive materials in the landfill can be removed and transported safely to licensed radioactive waste landfill. However, delays in removal will increase costs and long-term exposures to the public.
Downhole gamma logging and laboratory analyses conducted at the West Lake Landfill reveal that the radiologically impacted materials are generally found at depths ranging between the surface and top 6 feet of topsoil. There are also hot spots of contamination could be targeted for excavation and removal.
In February 2012 the EPA’s National Remedy Review Board (NRRB) conducted its review of the EPA’s Region 7 proposal for remedial action of Operable Unit 1 at the West Lake Landfill. In March 2013, the Board finalized its draft discussions, which concluded
“…based on the fact that the Agency has safely cleaned up numerous hazardous waste sites with radiological contamination across the country, including many in residential areas, the cleanup work can be done safely without unacceptable risk…”
The NRRB recommended that EPA Region 7 should:
“…develop an alternative that reflects an approach which surgically removes the RIM, which appears to be a discrete, reachable source term that will continue to increase in toxicity over hundreds and thousands of years…”
Evaluation of the EPA Selected Remedy for Operable Unit-1 at the West Lake Landfill 6 | P a g e
The EPA has yet to propose a plan for the excavation of highly radioactive materials from the West Lake Landfill, despite their own scientific evidence and recommendations from their own staff experts.
The Federal Government has been removing radiological contaminants from residential and commercial properties for the past seventy years in order to reduce hazards stemming from exposure to members of the public. The removal of radiologically-impacted source material is protective and should be an important objective of any proposed cleanup. These cleanup activities can be safely and efficiently completed with appropriate engineering controls and in accordance with approved health and safety plans.
In the near term, efforts should be made to:
1. Evaluate and implement immediate responses to prevent an underground fire from coming into contact with RIM material;
2. Identify current technologies which could be employed to sort RIM materials;
3. Determine the vertical and linear characterization of groundwater contamination and potential groundwater plume as opposed to isolated groundwater hot-spots;
4. Detect and characterize additional hot spots in the landfill outside of the known contaminated areas;
5. Facilitate the excavation of RIM material from the West Lake Landfill and its shipment and ultimate disposal at a dedicated and licensed disposal facility;
Finally, in accordance with expert evaluations, the proposed remedy in the 2008 ROD should be replaced with a more permanent and protective removal remedy that will reduce hazards to the public. Such a remedy should be developed with feedback from the community.
7 | P a g e 07/20/2016
Comprehensive Environmental Response, Compensation, and Liability Act of 1980
Engineering Management Support, Inc.
Environmental Protection Agency
EPA ORD Engineering Technical Support Center
Maximum Contaminant Level
National Remedy Review Board
EPA Office of Research and Development
Operable Unit-1
Potentially Responsible Party
Recycled Concrete Aggregate
Radiologically-Impacted Material
Record of Decision
Supplemental Feasibility Study
Uranium Mill Tailings Radiation Control Act
Evaluation of the EPA Selected Remedy for Operable Unit-1 at the West Lake Landfill 8 | P a g e
1 U.S. Environmental Protection Agency, Memorandum, From: John McKernan, ScD, CIH Director, ORD Engineering Technical Support Center (ETSC), To: Dan Gravatt, RPM U.S. EPA Region 7, Subject: Observations on the EMSI report: Evaluation of Possible Impacts of a Potential Subsurface Smoldering Event on the Record of Decision – Selected Remedy for Operable Unit-1 at the West Lake Landfill, Dated January 14, 2014, March 28, 2014. https://semspub.epa.gov/work/07/30284983.pdf
2 U.S. Environmental Protection Agency, National Remedy Review Board Discussions Regarding the Remedy at the West Lake Landfill Superfund Site, February 28, 2013. http://moenvironment.org/files/WestLakeNRRB_MCEnotes.pdf (The National Remedy Review Board (NRRB) is a peer review group created to ensure that proposed Superfund cleanup decisions are consistent with Superfund law, regulations and guidance. NRRB members are EPA managers and senior technical and policy experts with significant experience in Superfund remedy selection issues.)
3 U.S. Environmental Protection Agency, Record of Decision, West Lake Landfill Site, Bridgeton, Missouri, Operable Unit 1, May 2008. http://westlakelandfill.com/Portals/0/Documents/West%20Lake%20ROD%20OU1%20signed%2005-29-08.pdf
4 Comments from NRRB Reviewer John Frisco on PRP Scope of Work: Alternative Cover Designs and Fate and Transport Modelling, “Not sure why an ET [evapotranspiration] Cover is even being considered at this site since its deficiencies have already been identified (Albright and Benson).”
5 Inside EPA, EPA Orders Rare Review of Radioactive Cleanup Plan at Precedential Site, June 28, 2010
6 Internal E-Mail from NRRB Reviewer John Frisco dated February 15th, 2012 stated “Radiological contamination remains active for a very long time and would require long-term management wherever it ends up. For this reason, where possible, we try to send such material to facilities designed specifically for this purpose (e.g., Idaho, Utah). If one could safely and efficiently extract the radiological waste that might be an option worth consideration.”
7 Comments from NRRB Reviewer Charles Openchowski on PRP Scope of Work for groundwater, “The NRC reports also discuss how the toxicity of this RIM will continue to increase over time…this increase in Ra-226 must be considered in evaluating the long-term hazard posed by this radioactive material.” The SFS also acknowledges this fact.”
8 State of Missouri Attorney General’s Office, “Westlake Landfill Tree Core Analysis Report,” Dr. Joel G. Burken, Dr. Shoaib Usman, September 2, 2015 – Scientific data published by the State of Missouri Attorney General’s Office, demonstrated the potential for RIM to transfer offsite. Tree coring analysis conducted around the West Lake Landfill observed elevated radiologic counts of U-238 and U-235 in many of the analyzed samples. These elevated levels indicate offsite migration of RIM into the local environment.
9 Missouri Department of Natural Resources,” Bridgeton Sanitary Landfill Groundwater Investigation Report,” St. Louis County, Missouri, prepared for the Attorney General of Missouri – Analysis of potentiometric contours published by the State of Missouri Attorney General’s Office indicate that groundwater flows in a westerly direction, angling away from the landfill toward the Missouri River.
10 OSWER Directive 9355.0-30, Role of the Baseline Risk Assessment in Superfund Remedy Selection Decisions, April 22nd, 1991
11 OSWER Directive 9283.1-33, Summary of Key Existing EPA CERCLA Policies for Groundwater Restoration
12 Robert E Criss, Risk and Character of Radioactive Waste at the West Lake Landfill, Bridgeton, Missouri, March 14, 2013 – “Specifically, it has no basal clay liner, no plastic sheeting, no internal cells, no leachate collection system, nor any type of protective cap, all of which are standard requirements for modern landfills. Instead the West Lake Landfill is a chaotic pile of debris covered by unmanaged “natural” vegetation, surrounded by a fence with radioactive hazard signs. This landfill is an unsuitable host for any type of radwaste, industrial waste, chemical waste, or even ordinary domestic waste.” http://moenvironment.org/images/West_Lake_Rept03142013.pdf
13 Environmental Protection Agency, West Lake Update – EPA to Conduct Additional Sediment Sampling at the West Lake Landfill, May 26th, 2016 – EPA analysis has determined that RIM materials are being transported off-site with surface water after significant rain events and collecting in sediment around the landfill.
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14 Internal Comments from EPA ORD ETSC experts on EMSI Executive Summary Bullet Point #2, “Since we do not have a full accounting of the material in OU-1, we cannot make a definitive assessment regarding the potential for chemical reactions between the RIM and non-RIM materials if an SSE (Sub-Surface Smoldering Event) were to occur. If these reactions were to occur, they could cause a rapid buildup of heat or gas, and subsequent reactions or reactive conditions in the landfill.”
15 State of Missouri Attorney General’s Office, Westlake Landfill Tree Core Analysis Report, Dr. Joel G. Burken, Dr. Shoaib Usman, September 2nd, 2015
16 Environmental Protection Agency, West Lake Update — EPA to Conduct Additional Sediment Sampling at the West Lake Landfill, May 26th, 2016.
17 Internal Comments by Charles O. on PRP Groundwater Scope of Work, “Based on information presented to the [National Remedy Review] Board, it appears that there have been some samples of groundwater at this site that exceed standards considered as ARARs…Generally, under existing Agency guidance, exceeding a maximum contaminant level in groundwater normally would warrant a response action.”
18 M. Kaltofen, R. Alvarez, L. Hixson, Tracking legacy radionuclides in St. Louis, Missouri, via unsupported 210Pb, Journal of Environmental Radioactivity, December 2015. http://www.coldwatercreekfacts.com/media/reports/Alvarez-Journal-2015.pdf
19 Internal Comments from EPA ORD ETSC experts on EMSI Executive Summary, Bullet Point #4, “We do not support the conclusion that no additional long term risks would be created in the event of a SSE at OU-1. There are at least two risk pathways that could exist from an SSE [subsurface smoldering event]. The first is through increased air exposures to contaminants such as radon. As airborne concentrations of radon increase, so would the risk to people. The second pathway is increased leachate production that could move contaminants and dissolved radon gas from OU-1 into the groundwater.”
20 Internal Comments from EPA ORD ETSC experts on EMSI Executive Summary, Bullet Point #2, “…using the higher temperatures observed in the Bridgeton Landfill as a worse-case scenario, these temperatures may cause the structural integrity of the cap called for in the 2008 ROD to be adversely affected. This could potentially include surface cracks and fissures in the cap extending down into the waste material, and potentially cause permeation of the cover used.”
21 Internal Comments from EPA ORD ETSC experts on EMSI Executive Summary, Bullet Point #2, “…if a SSE occurs, short-term risks may be present even with proper cap design, inspection and maintenance.”
22 Internal Comments from EPA ORD ETSC experts on EMSI Executive Summary Bullet Point #3, “A SSE in OU-1 would be expected to create increased pressure conditions within the landfill and force out entrained gases, including radon.”
23 Internal Comments from EPA ORD ETSC experts on EMSI Executive Summary, Bullet Point #5, “Short-term effects of an SSE could also include greater amounts of leachate production, which has been observed at the Bridgeton Landfill from condensation of large amounts of steam. An SSE may result in increased emissions of radon and other contaminants in the air and groundwater, even with annual inspections and proper maintenance of designs discussed in the 2008 ROD and 2011 SFS.”
24 Internal Comments from EPA ORD ETSC experts on EMSI Executive Summary, Bullet Point #3, “Given that measurements of radon in air during the SFS were close to a Uranium Mill Tailings Radiation Control Act (UMTRCA) standard, there is potential for radon releases at levels of concern if a SSE occurs in OU-1. This observation does not consider other environmental conditions that could cause radon and other landfill gas concentrations to increase at ground level, such as atmospheric inversions.”
25 Internal Comments from EPA ORD ETSC experts on EMSI Executive Summary, Bullet Point #4, “We do not support the conclusion that no additional long term risks would be created in the event of a SSE at OU-1. There are at least two risk pathways that could exist from a SSE. The first is through increased air exposures to contaminants such as radon. As airborne concentrations of radon increase, so would the risk to people.”
26 Internal Comments from EPA ORD ETSC experts on EMSI Executive Summary, Bullet Point #3, “…a SSE may be present in OU-1 for a long period of time before it is detected, because the only apparent means to detect a SSE after closure is through annual visual inspections.”


2015-01-06 – EPA – West Lake Landfill – Preparation language for Wednesday’s meeting with MDNR

Vann, Bradley[Vann. [email protected] .gov]
McKernan, John[McKernan [email protected]]
Kiefer, Robyn V NWK
Tue 1/6/2015 3:34:30 PM
Subject: RE: Preparation language for Wednesday’s meeting with MDNR (UNCLASSIFIED)
Classification: UNCLASSIFIED
Caveats: NONE
We essentially would like to see all their operational information on the pilot, including the date they
started operating the cooling equipment along with all data collected.
We see that they have provided readings for the TMPs adjacent to a couple of the GIWs; however, we
don’t know which readings are prior to or after the cooling equipment was started up. There isn’t an
apparent impact, so we don’t even know if the cooling equipment has been started.
The data provided is in word format. It would be helpful to have the data either in excel format so we can
sort by depth and date or more preferred would be to have Republic provide graphs for each TMP that
show the temp trends by depth and date with start of cooling equipment annotated.
Also, to clarify 7) below, for the pilot, it would be best to have coolant temperature in and out at each pilot
well in addition to the in/out temps of the cooling equipment. After looking at Republic’s proposed system
(Aug 15 letter), there are no provisions for measuring coolant temperature at each well, but they do have
means to measure in/out temps at the cooling equipment.
The attached table attempts to summarize the data needed to evaluate the pilot study and incorporates
the ROI info. It might help clarify some of the info we’d like to see.
—–Original Message—–
From: Vann, Bradley [mailto:[email protected]]
Sent: Monday, January 05, 2015 3:52PM
To: Kiefer, Robyn V NWK; McKernan, John
Subject: [EXTERNAL] Preparation language for Wednesday’s meeting with MDNR
Trying to confirm what information EPA needs before our meeting with MDNR on pending IB items. I’ve
listed a number of items below from our call today (and others), but are there any specifics missing
please let me know so we can have a clear EPA position and be sure MDNR fully understands our
I heard the following needs:
1) Monitoring gas analytical data to better evaluate SSE
WLLFOIA4312- 001 – 0059051
2) Anticipated radiant heat to remove from system (delta temp)
3) Energy use required related to cooling capacity
4) Radius of Influence per cooling point
5) As-Builts
6) How quickly they can expand it/remove heat from an area (ramp up time) to respond to SSE
7) Water temps in/out
8) Best options for design needs/expanded pilot
9) Quality of data to EPA with regards to where the SSE is in Neck vs North Quarry (if we can get
10) Include prior technical USAGE “wish list” items sent to MDNR for draft order in December 2014
(bullet list)
Feel free to amend any errors or add items.
Bradley Vann – Remedial Project Manager
U.S. Environmental Protection Agency
Superfund Division
Missouri/Kansas Remedial Branch
11201 Renner Blvd.
Lenexa, KS 66219
Phone: 913-551-7611
Fax: 913-551-9611
Classification: UNCLASSIFIED
Caveats: NONE
WLLFOIA4312- 001 – 0059052


2015-01-22 – EPA – West Lake Landfill – Risk is the Driver for Decision-Making

To: Field, Jeff[[email protected]]; Jefferson, [email protected]]; Stoy,
Alyse[[email protected]]; Slugantz, Lynn[[email protected]]; Kiefer, Robyn V
NWK[Robyn .V. [email protected] mil]; McKernan, John[McKernan [email protected] .gov]; Kappelman,
David[Kappelman. [email protected] .gov]
From: Vann, Bradley
Sent: Thur 1/22/2015 5:07:38 PM
Subject: West Lake Landfill – Tomorrows Meeting with RPs (revised agenda)
Here is the revised agenda for tomorrow’s discussion with the RP technical team. Please review
this morning (or what is left of it) and let me know if additional changes are needed. Note items
in red font are internal considerations/discussion points and will not be sent out with final
version this afternoon.
Bradley Vann- Remedial Project Manager
U.S. Environmental Protection Agency
Superfund Division
Missouri/Kansas Remedial Branch
11201 Renner Blvd.
Lenexa, KS 66219
Phone: 913-551-7611
Fax: 913-551-9611
e Meeting purpose to be responsive to EPA letter dated 1/15/15 and discuss technical path
forward on RIM characterization
WLLFOIA4312- 001 – 0058779
e Overview on how characterization work fits with existing work
-Completion of the Soils Remedy
-Address Technical Concerns
-Risk is the Driver for Decision-Making
e Investigation of interface between OU -1 Area 1 and North Quarry
-Area of Interest
-Overview of Statistical Approach
e Cores and Composition of Area 1
-Review of existing cores
WLLFOIA4312- 001 – 0058780
e Projected Timeline
– Work Plan revision/review and approval
-Field Work
e Jan 30 meeting Primer/Meeting Wrap Up
WLLFOIA4312- 001 – 0058781


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
WLLFOIA4312- 001 – 0058493
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
WLLFOIA4312- 001 – 0058494


2015-08-10 – EPA – USACE – West Lake Landfill – Radon Flux – Emanation measurements related to EPA Pyrolysis study of RIM

To: Donakowski, Joseph NWK[[email protected]]
From: Mahler, Tom
Sent: Mon 8/10/2015 9:34:18 PM
Subject: Re: Radon flux/emanation measurements related to potential EPA Pyrolysis study of
RIM from the West Lake Landfill (UNCLASSIFIED)
I’ll set up a conference line tomorrow morning and send you the information. I had to leave the office a
little earlier than I expected today.
Sent from my iPhone
>On Aug 10,2015, at 4:14PM, Donakowski, Joseph NWK
> Classification: UNCLASSIFIED
> Caveats: NONE
> 10 sounds good to me. Would you like me to call you, or you I, or is there a conference number we can
call in if anyone else wants/needs to participate?
> Jough Donakowski
>Health Physicist- USACE Kansas City
> (816) 389-3993
> —–Original Message—–
> From: Mahler, Tom [mailto:[email protected]]
>Sent: Monday, August 10,2015 3:00PM
>To: Donakowski, Joseph NWK
> Subject: [EXTERNAL] RE: Radon flux/emanation measurements related to potential EPA Pyrolysis
study of RIM from the West Lake Landfill (UNCLASSIFIED)
> 10:00am tomorrow work?
> —–Original Message—–
> From: Donakowski, Joseph NWK [mailto:[email protected]]
>Sent: Monday, August 10,2015 12:16 PM
>To: Mahler, Tom
> Subject: RE: Radon flux/emanation measurements related to potential EPA Pyrolysis study of RIM from
the West Lake Landfill (UNCLASSIFIED)
> Classification: UNCLASSIFIED
> Caveats: NONE
>Yes, I’ll be free tomorrow, I get in around 7:45 so anytime between 8:00 and 4:00 would work for me.
> Jough Donakowski
> Health Physicist- USACE Kansas City
> (816) 389-3993
WLLFOIA4312- 001 – 0058859
> —–Original Message—–
> From: Mahler, Tom [mailto:[email protected]]
>Sent: Monday, August 10,2015 10:43 AM
>To: Donakowski, Joseph NWK
> Subject: [EXTERNAL] RE: Radon flux/emanation measurements related to potential EPA Pyrolysis
study of RIM from the West Lake Landfill (UNCLASSIFIED)
>Hey Jough,
> Just thought I would check in with you now that you are back in the office. I am free all day tomorrow
and plan to be in the office from about 7:30am central time to about 4:00pm. Any chance you would be
available for a short chat about Radon? I don’t think this would take longer than about 30 minutes.
>Let me know if you are available.
>Tom Mahler
> On-Scene Coordinator
> EPA Region 7
> 816-604-0546
> —–Original Message—–
> From: Donakowski, Joseph NWK [mailto:[email protected]]
>Sent: Tuesday, August 04,2015 4:01PM
>To: Mahler, Tom
> Cc: Vann, Bradley
> Subject: RE: Radon flux/emanation measurements related to potential EPA Pyrolysis study of RIM from
the West Lake Landfill (UNCLASSIFIED)
> Classification: UNCLASSIFIED
> Caveats: NONE
>Hi Tom,
>I’m currently TDY at our Maywood site in New Jersey doing field work and won’t be available until next
week, but I’d be available just about any time that week, so if there’s any time that works good for you I can
be available, just let me know. Thanks!
> Jough Donakowski
>Health Physicist- USACE Kansas City
> (816) 389-3993
> —–Original Message—–
> From: Mahler, Tom [mailto:[email protected]]
> Sent: Tuesday, August 04, 2015 1 :54 PM
>To: Donakowski, Joseph NWK
> Cc: Vann, Bradley
> Subject: [EXTERNAL] Radon flux/emanation measurements related to potential EPA Pyrolysis study of
RIM from the West Lake Landfill
> Sorry about the very long subject of this email…
>I was given your email address from Brad Vann, Remedial Project Manager for West Lake Landfill Site,
WLLFOIA4312- 001 – 0058860
because I was hoping to talk to you more about the Radon flux/emanation measurements related to a
pyrolysis study. I was given the impression that you at least initially suggested that the study include radon
and that the result might help improve the associated radon modeling of the site.
> My main goal is to make sure I understand as best as I can the intent or potential intent of such
measurements to help me evaluate whether the proposed sampling and measurement techniques are capable
of providing this information.
> I am an On-Scene Coordinator here at EPA Region 7 with a degree in Nuclear Engineering and aspiring
to become a certified health physicist (I took the first exam last month and still have a ways to go … ). I have
been asked me to help out with the pyrolysis study.
> Are you available to talk about radon flux/emanation at some point this week?
> I am available pretty much any time. Let me know what is convenient for you and thanks in advance.
>Tom Mahler
> On-Scene Coordinator
>US EPA Region 7
> 816-604-0546
> Classification: UNCLASSIFIED
> Caveats: NONE
> Classification: UNCLASSIFIED
> Caveats: NONE
> Classification: UNCLASSIFIED
> Caveats: NONE
WLLFOIA4312- 001 – 0058861


2014-10-14 – EPA – West Lake Landfill – Fiscal Year 2014 Accomplishments

Sumpter, Richard[[email protected]]
Weber, Rebecca
Tue 10/14/2014 6:35:10 PM
RE: West Lake FY14 accomplishments
From: Sumpter, Richard
Sent: Tuesday, October 14,2014 1:31PM
To: Weber, Rebecca
Cc: Lubbe, Wendy
Subject: RE: West Lake FY14 accomplishments
From: Weber, Rebecca
Sent: Tuesday, October 14, 2014 11:21 AM
To: Sumpter, Richard
Subject: RE: West Lake FY14 accomplishments
From: Sumpter, Richard
Sent: Tuesday, October 14,2014 11:19 AM
WLLFOIA4312- 001 – 0058210
To: Weber, Rebecca
Subject: RE: West Lake FY14 accomplishments
From: Weber, Rebecca
Sent: Tuesday, October 14,2014 11:15 AM
To: Sumpter, Richard
Subject: RE: West Lake FY14 accomplishments
From: Sumpter, Richard
Sent: Tuesday, October 14, 2014 11:07 AM
To: Jackson, Robert W.
Cc: Weber, Rebecca
Subject: RE: West Lake FY14 accomplishments
From: Jackson, Robert W.
Sent: Tuesday, October 14, 2014 10:55 AM
To: Sumpter, Richard
Subject: FW: West Lake FY14 accomplishments
WLLFOIA4312- 001 – 0058211
From: Gravatt, Dan
Sent: Tuesday, October I4, 20I4 I0:42 AM
To: Jackson, Robert W.; Field, Jeff; Ferguson, Jaci
Subject: West Lake FYI4 accomplishments
Provided at Bob’s request this morning:
FY20 I4 Milestones for West Lake Landfill
EPA entered into two separate Interagency Agreements with the US Army Corps of Engineers:
one to obtain their assistance with design and construction oversight for the subsurface barrier
intended to separate the subsurface oxidation event in OU2 from the radiologically impacted
material in OU I; and the other to provide independent technical reviews of the deliverables the
PRPs will generate under the Supplemental SFS. USACE provided EPA its evaluation of the
engineering considerations with the three potential barrier alignments that have been considered
to date. EPA continued to coordinate with the US Geological Survey under another IA as they
prepared a comprehensive evaluation of groundwater hydrology and background concentrations
and sources of radionuclides at the site. EPA issued a Pre-Construction Order to the PRPs that
directed them to begin preparing the site for the eventual construction of the subsurface barrier
and provide other technical documents on bird mitigation and air monitoring that will support
this construction. EPA installed a network of five off-site air monitor stations in the surrounding
community to begin collecting a background baseline data set to help evaluate air sampling data
to be collected during the eventual construction of the subsurface barrier. EPA’s Office of
Research and Development evaluated the PRP’s report on the possible effects the OU2
subsurface oxidation event might have on the RIM in OUI should the SSE migrate into OUI in
the future. ORD has also been tracking the monthly reports on the SSE extent and gas and
temperature data provided by the PRPs to the Missouri DNR to provide an independent
assessment of SSE behavior. EPA responded to community concerns about possible radiological
contamination at the Bridgeton Municipal Athletic Complex and conducted a thorough
investigation of the area which determined that there was no radiological contamination there.
EPA has coordinated extensively with the community through attendance of the monthly
Community Advisory Group meetings and issuance of weekly “West Lake Update” newsletters.
WLLFOIA4312- 001 – 0058212
Daniel R. Gravatt, PG
11201 Renner Boulevard, Lenexa, KS 66219
Phone (913) 551-7324
Principles and integrity are expensive, but they are among the very few things worth having.
WLLFOIA4312- 001 – 0058213


2014-04-07 – EPA – Report on West Lake-Bridgeton Landfill Fire – Cover Transmittal Letter and Report

To: Brecht Mulvihill[[email protected]]; Brendan
Fahey[[email protected]]; Downey Palmer[[email protected]];
Edwilla Massey[[email protected]]; Erik Rust[[email protected]]; Joeana
[email protected]]; John [email protected]]; Kerry
DeGregorio[[email protected]]; Lou Aboussie[[email protected]]; Mark
Fowler[[email protected]]; Mary Beth Wolf[[email protected]]; Mattie
Moore[[email protected]]; Miriam Stonebraker[[email protected]];
Nichole Distefano[[email protected]]; Patrick Bond[[email protected]];
Pauline Jamry[pau line .ja [email protected] I. house .gov]; Steven Engelhardt[ steven. engel [email protected] house .gov];
Tod Martin[[email protected]]
From: Sanders, LaTonya
Sent: Mon 4/7/2014 2:41:47 PM
Subject: FW: Report on West Lake-Bridgeton Landfill Fire – Cover Transmittal Letter and Report
From: Tapia, Cecilia
Sent: Friday, April 04, 2014 8:36AM
To: [email protected]
Subject: FW: Report on West Lake-Bridgeton Landfill Fire – Cover Transmittal Letter and Report
Importance: High
WLLFOIA4312- 001 – 0058480
From: Peter Anderson
Sent: Monday, March 24,2014 5:02:50 PM
To: Stanislaus, Mathy
Subject: FW: Report on West Lake-Bridgeton Landfill Fire- Cover Transmittal Letter and
WLLFOIA4312- 001 – 0058481
WLLFOIA4312- 001 – 0058482
From: Peter Anderson L’-‘-“==~~~===’-‘~=~”-=J
Sent: Friday, March 21, 2014 6:52 PM
To: ‘[email protected]
Cc: ‘[email protected]’; ‘[email protected]’; ‘[email protected]
Subject: Report on West Lake-Bridgeton Landfill Fire – Cover Transmittal Letter and Report
WLLFOIA4312- 001 – 0058483
WLLFOIA4312- 001 – 0058484


2015-05-22 – Republic – West Lake Landfill – Expanded Heat Removal Pilot Study – Bridgeton Landfill, Bridgeton, Missouri

WLLFOIA4312 – 001 – 0059522
WLLFOIA4312 – 001 – 0059523
WLLFOIA4312 – 001 – 0059524


2013-05-23 – MCE – Letter to EPA – Underground Fire at West Lake

May 23,2013
Karl Brooks
Regional Administrator, Region 7
Environmental Protection Agency
11201 Renner Blvd.
Lenexa, KS 66219
RE: West Lake/Bridgeton Landfill Superfund Site
Dear Mr. Brooks:
A subsurface landfill fire is burning in the proximity of nuclear weapons wastes in Bridgeton, Missouri.
The odor from the landfill fire has impacted tens of thousands of people and concern about it contacting
the nuclear weapons wastes is growing. The EPA announced in January the landfill fire was 1,200 feet
from the nuclear weapons wastes. In May, the Missouri Attorney General announced the landfill fire is
1,000 feet away from the nuclear weapons wastes. EPA employees have stated several times this year
that it is not possible for the landfill fire to reach the nuclear weapons wastes.
The Missouri Coalition for the Environment and the undersigned members of the adjacent communities
would love to be as confident as your staff that the fire will not reach the nuclear weapons wastes.
Please help us understand your position so that we may know our communities are safe. Please answer
our questions:
1. Can the EPA say with 100% confidence that the landfill fire will not reach the nuclear weapons
wastes? If yes, will the EPA explain to the community, in detail, the information it is using to
make this determination. If no, what is the EPA plan to ensure the fire does not reach the
nuclear weapons wastes?
2. How does EPA explain that the temperatures in the landfill past the interceptor wells are rising
above levels of concern- 170 degrees at several of the monitoring wells including at TMPS,
TMP13 and TMP14?
3. The EPA Remedial Investigation for the West Lake Landfill OU-1 (pg. 80) indicates that the
normal groundwater flow is toward the Missouri River. However, its normal flow was being
influenced by the leachate collection system in the adjacent landfill. It’s our understanding that
the leachate collection pumps have stopped working at the Bridgeton landfill. How will this
affect groundwater flow in the West Lake Landfill OU-1 Area 1 and 2?
WLLFOIA4312- 001 – 0058259
4. Is the EPA sampling groundwater between West Lake OU-1 and the Missouri River or anywhere
5. Will EPA provide the data on groundwater sampling locations, results, and plans?
6. How often is EPA sampling groundwater monitoring wells? What days did the EPA sample
groundwater at the site in 2012 and 2013? What is the schedule for groundwater sampling in
7. Groundwater plumes are often seen at superfund sites where soil has been contaminated with
chemicals. Soil is not the same as landfill waste. Would EPA expect to find a groundwater plume
in a heterogeneous mixture of materials such as can be found in the West Lake landfill?
8. How would groundwater behave in landfill material that might be different from how
groundwater would behave in a homogeneous material like soil?
9. What information would EPA need in order to predict groundwater movement in landfill
material with some degree of accuracy? Does the agency have this information?
10. Has the EPA conducted community interviews of “impacted communities” in the last 10 years? If
yes, does EPA have evidence to support that community interviews were conducted? If yes, how
have community interviews guided EPA response to community concerns? If no, what is the EPA
plan for conducting community interviews and when will people be notified?
11. In March, EPA told the public that it flew the Aspect plane over the area to measure airborne
radiological hazards. Where is the data from the Aspect plane?
12. Will EPA provide the raw data to the public?
13. What are the abilities and limitations of the ASPECT plane monitors?
14. Did the ASPECT plane conduct a thermal analysis ofthe landfill?
15. Who requested the ASPECT plane flyover?
16. Why was the ASPECT plane flown over?
17. Where did it take measurements?
18. Does the EPA have any air data on radon/radon daughters from north St. Louis?
Thank you for your consideration of our concerns.
Yours truly,
~~~t( ~F- fl_ 411-~
Kathleen Logan Smith, MCE Ed Smith, MCE Dawn Chapman, Maryland Heights
Bob Nowlin, Bridgeton
WLLFOIA4312- 001 – 0058260
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2016-02-09 – West Lake Landfill – AG Koster letter to Congressman Clay and Congresswoman Wagner supporting request to transfer WLL to FUSRAP

Washington, DC 20515
Congresswoman Ann Wagner
435 Cannon
Washington, DC 20515
Dear Congressman Congresswoman Wagner,
from the Environmental ,_,.,.,.,.,,””,.. .. -,
Action Program” (or “FUSRAP”) …, …… uuuu~…,,
Because the EPA has proven itself an
West Lake I I encourage
outlined 4100 and S. 2306 and prioritize
House of Representatives.
past three years, my
aggressively to a solution to
Landfill-a problem vAll~vv.1.
Bridgeton Landfill. For example, office
West Lake site to
contamination, anticipation of construction of an
call for testing and expedited construction
March, and August 14, and 2015.
In response our repeated calls to
promises failed to deliver results. For
stated it was with
construction was expected to
passed with no discernable movement toward a
letters, sent
(573) 751-3321
WLLFOIA4312 – 001 – 0001696
Similarly, in February 2015, the EPA reported taking steps
characterizing radiological at also
testing, which would provide valuable information regarding the potential consequences
of letting fire at the Bridgeton reach the radiological at West Lake.
A year passed, yet EPA still has not announced the results its site
characterization, nor does it appear that the pyrolysis testing has been completed.
All the while, the continues to Experts by my office have raised
questions regarding whether and how long the safeguards installed
Bridgeton landfill can continue to progress toward West Lake.
Additionally, a troubling report released by Missouri Department of Natural
Resources last month corroborated concerns originally identified by my experts
radiological contamination may be present outside the perimeter of fenced-in landfill.
burning radioactive waste dump requires government act with urgency, but
seems unable to move forward with a meaningful solution. The Corps of Engineers,
through FUSRAP, has experience dealing with contaminated sites. I hope that experience
will enable the Corps, if given primary jurisdiction over this site and the necessary
funding, to quickly design and implement a remedial solution to improve the health and
quality of life of the Missourians who live, work, and go to school near West
Lake and Bridgeton Landfills.
cc: Senator Roy
Senator Claire McCaskill
Congressman Blaine Luetkemeyer
Congresswoman Vicky Hartzler
Congressman Emanuel Cleaver
Congressman Graves
Congressman Billy Long
Congressman Jason Smith
Attorney General
WLLFOIA4312 – 001 – 0001697
Karl Brooks
Environmental Protection Agency
Regional Administrator, Region 7
11201 Renner Blvd.
Lenexa, Kansas 66219
Dear Regional Administrator Brooks,
November 27, 2013
P.O. Box see
(573) 751-3321
The State of Missouri has received a Phase I Status Report detailing the preliminary
results of the Gamma Cone Penetrometer Testing that EPA has required in preparation for the
installation of an isolation barrier at the Westlake site in Bridgeton, Missouri. After reviewing
the report, the State is concerned about some of the raw data summaries, which suggest the
presence of higher-than-background-level radioactivity at depth outside the area where previous
maps represented the radioactive material was located.
In light of this new preliminary data, it is critically imp01tant that EPA direct the
completion of a comprehensive survey of the Westlake site to determi11e with certainty the
boundary lines encompassing the radioactive material. The implementation of.engineering
controls, including the isolation barrier intended to separate the radioactive material in Westlake
from the smoldering event in the Bridgeton landfill, depends on an accurate picture of the
radiological profile of the site. The State calls upon EPA to commence this comprehensive
smvey without delay.
In addition, due to the importance of this data and the high level of public interest in the
site, the State strongly encomages EPA to make the information publicly available as soon as
EPA validates the data for accuracy.
We look forward to hearing from you and continuing to work with you in addressing the
difficult challenges ahead.
Attorney General.
WLLFOIA4312 – 001 – 0001698
· .
. .
. ·._·.• …
Karl Brooks
Environmental Protection Agency
Regional Administrator, Region 7
11201 Renner Blvd.
Lenexa, Kansas 66219
January 8, 2014
Dear Regional Administrator Brooks,
(573) 751-3321
For more than nine months now, our office has worked with the Missouri
Department of Natural Resources (DNR) and EPA in addressing a matter of great
public concern-the underground fire at the Bridgeton landfill and its proximity to
the radioactive material at the adjacent West Lake site. While the landfill is
supervised by the State and West Lake is within federal jurisdiction, it is important
that regulators at all levels continue to communicate openly and effectively with
each other and with the public. We have demanded that Republic Services take
substantial steps toward mitigating the landfill fire, and significant work has
already been done. I write today to encourage a similarly aggressive approach to the
West Lake side of the problem and to better understand EPA’s timetable and its
contingency plan should the situation worsen.
Since our office became involved in this matter last spring, we have moved
rapidly to compel Republic Services to get control over the fire in the Bridgeton
landfill. We filed suit against Republic less than a week after receiving a referral on
this matter from DNR, seeking injunctive relief and monetary penalties. By
Memorial Day, we had negotiated a preliminary injunctive agreement that required
the company to install protective measures, including an ethylene vinyl alcohol
(EVOH) cap and gas interceptor wells, in an effort to slow the spread of the fire.
Before the summer ended, the wells were in place and the southern portion of the
landfill had been covered. Republic subsequently agreed to cap the remainder of the
landfill (the north quarry), and work on that project is expected to be completed by
May 30, 2014.
While much has been accomplished to better manage the fire at the
Bridgeton landfill, progress toward securing the radioactive material at the
federally supervised West Lake site has, to this point, been less visible. Republic
www.ago.mo .gov
WLLFOIA4312 – 001 – 0001699
Karl Brooks
January 8, 2014
Page 2
agreed in September to construct an isolation barrier between the West Lake and
Bridgeton landfill sites, yet it appears that the company is still conducting a survey
of the area in advance of any construction. We appreciate that EPA has urged
Republic to expedite this process, but the seriousness of the West Lake issue
requires that regulators set an aggressive timetable for Republic to complete the
barrier installation and demand that its deadlines be met. With that in mind, we
ask that EPA identify when it expects the comprehensive radiological survey will be
completed and, further, when it expects Republic to complete the construction of the
isolation barrier.
No matter how ambitious the construction schedule is, of course, we must
recognize that circumstances may change. We cannot be certain that the spread of
the fire in the Bridgeton landfill will not accelerate or that a new fire will not
spontaneously develop in the north quarry near the West Lake boundary line. As
the regulatory agency with supervisory authority over the West Lake site, EPA
must be prepared to react quickly should it become apparent that the isolation
barrier cannot be constructed in time to prevent the fire from reaching the
radioactive waste. We ask that the EPA make public its contingency plan in the
event that the construction of the isolation barrier becomes infeasible.
The people who live, work, and travel in the Bridgeton area deserve swift
action from the State and from EPA as we address the complex challenges posed by
the landfill and West Lake site. We are grateful for your team’s efforts thus far, and
we look forward to further cooperation between our respective agencies as our work
Attorney General
WLLFOIA4312 – 001 – 0001700
Karl Brooks
Regional Administrator
Environmental Protection Agency
11201 Renner Blvd.
Lenexa, KS 66219
Dear Administrator Brooks,
March 18, 2014
(573) 751·3321
One year ago, my Office filed a lawsuit against Republic Services alleging a series of
environmental-law violations relating to events at the West Lake landfill complex. The suit
seeks to accomplish two primary objectives. First, the suit aims to hold Republic responsible for
the alleged violations of applicable environmental laws. Second, and more importantly, the suit
aims to compel Republic to move swiftly in preventing the subsurface fire in the south quarry of
the Bridgeton landfill from migrating northward and reaching the radioactive material deposited
in Operable Unit 1 (OU-1). Over the past year, Republic has taken steps to slow the spread of
the fire, but recent developments suggest that these measures do not address the entire problem.
It now appears that radioactive material from OU-1 may be spread more widely than originally
thought and may be present in the north quarry of the Bridgeton landfill. Republic and EPA
must act aggressively to address this apparent relocation.
Last fall, after initial reports indicated that radioactive material was found in sections of
OU-1 that were previously thought to be unaffected by radiological deposits, EPA agreed to
order a comprehensive survey of the area to determine the true boundary of radioactive
contamination. We understand preliminary tests have found radioactive material not only
outside the originally identified “radioactive perimeter,” but beyond the southern edge of OU-1
itself, into the north quarry of the Bridgetonland:fill.
Expedited radiological testing: The possible relocation of radioactive material from
OU-1 into the Bridgeton landfill highlights the need for EPA and Republic to accelerate their
surveying and engineering efforts to ensure the fire in the south and radioactive material in the
north never meet. In particular, the need for a comprehensive remapping of the West Lake site
to definitively identify the extent of OU-1 ‘s radioactive contamination has never been clearer.
We ask that EPA and Republic expedite their work to complete this project as quickly as
WLLFOIA4312 – 001 – 0001701
Karl Brooks
March 18, 2014
Page 2
Federal authority over OU-l’s radiological deposits: The entire West Lake I
Bridgeton landfill complex was long-ago designated a Superfund site under federal control. To
date, EPA has limited its exercise of regulatory jurisdiction to the defined Operable Units at
West Lake, and it deferred its oversight of the remainder of the Bridgeton landfill to the
Missouri Department of Natural Resources. But the developing information indicating the
spread of OU-1 ‘s radioactive material suggests this division of legal authority may require a
change. EPA expressly deferred its legal authority regarding solid-waste facility closure and
post-closure of the Bridgeton landfill to the State only because that portion was thought to be
untainted by OU-1 ‘s radioactive waste. It is the federal government-whether EPA exclusively
or EPA working in conjunction with the Army Corps of Engineers-that is vested with the legal
authority and the resources to direct remediation of sites containing 0 U-1 ‘s radioactive waste. If
radioactive material from OU-1 is confirmed to be located in the Bridgeton landfill, legal
authority oyer the contaminated site must shift back from the State to the federal government.
Rapid construction of isolation barrier: Last September, Republic announced its
intention to build an isolation barrier to separate the radiological material in OU-1 from the
smoldering :fire in the southern part of the Bridgeton landfill. Over six months have passed, yet
construction of the barrier still has not begun. Although we acknowledge that essential
surveying is still underway, the ongoing site testing need not prevent construction from
commencing, at least in part. As EPA completes its radiological profile of the site, we ask that it
also finish its review of Republic’s proposed plan to construct the isolation barrier and, upon
identifying a sound design, direct that construction begin without delay.
The State’s highest priority is to protect the health and safety of its residents. Even if
circumstances require that EPA reassert its legal authority over the entire West Lake site, the
State will continue its work in validating data, offering comments to remedial plans, and
providing whatever other support may be needed. We look forward to working with EPA and
Republic in taking the steps necessary to isolate the radioactive waste from the landfill fire and .
thereby give the people in Bridgeton and its surrounding communities the security and peace of
mind they deserve.
Attorney General
cc: Bill Beck, General Counsel, Republic Services
WLLFOIA4312 – 001 – 0001702
Karl Brooks
Regional Administrator
US EPA Region 7
11201 Reimer Blvd_
Lenexa, KS 66219
August 11, 2014
Dear Administrator Brooks:
P.O. Box: 899
(573) 751-3321
In the First Agreed Order that my Office reached with Republic Services (“Republic”)
over a year ago, the St Louis County Circuit Court ordered Republic to implement a number of
protective measures to control the spread of the subsurface smoldering event (“SSE”), reduce
odors caused by the smoldering refuse, and separate the burning trash from the radiologically
impacted material deposited at the north end of the West Lake site. While significant work has
been done and is ongoing in an effort to control the fire and mitigate odors, little visible
progress has been made toward constructing.the isolation barrier aimed to keep the SSE from
reaching radiological waste. As the construction of the isolation barrier depends on the detection
and handling of radioactive material, any work on the project necessarily requires EPA
oversight and approval.
We recognize that the design and construction of the isolation barrier is an enormously
complicated task, and we appreciate the involvement of the Army Corps of Engineers, who
bring special expertise to engineering projects of this complexity. We also understand that the
implementation of any isolation-barrier design depends on the review and approval of LarnbertSt
Louis International Airport (“Airport”), which is responsible for ensuring that any planned
excavation or construction will not draw large numbers of birds and put air traffic at risk.
We understand that the Corps has analyzed a number of alternatives for placement of the
isolation barrier. In the interest of moving this project forward in a timely fashion, we ask that
EPA adopt the following schedule:
• Within 30 days, EPA, in conjunction with the Corps, presents its formal analysis
of the isolation-barrier alignment alternatives to Republic and to the Airport.
• Within 45 days following Republic’s receipt of the analysis, Republic submits its
alignment selection to EPA and to the Airport, which must include sufficient
design specifications to allow EPA, the Corps, and the Airport to evaluate the
• Within 45 days following the Airport’s receipt of Republic’s proposal, the
Airport announces whether it will consent to the proposal in light of its concerns
WLLFOIA4312 – 001 – 0001703
regarding the risks excavation and construction at the landfill may pose to flights
due to increased bird activity.
• If the Airport approves the proposal, EPA announces within 30 days of approval
whether it approves the proposal.
• If the proposal is not approved, Republic submits a modified proposal to EPA,
the Corps, and the Airport within 30 days, taking into account the comments and
concerns raised.
As always, the health and safety of the public, including those who live and work around
the landfill and those who rely on the Airport to provide safe flights, is our highest priority. We
remain frustrated with the slow pace of progress thus far. It is critically important that all
participants in this project move with greater dispatch to ensure that all members of the public
are protected.
Attorney General

WLLFOIA4312 – 001 – 0001704
Karl Brooks
Environmental Protection Agency
Regional Administrator, Region 7
11201 Renner Blvd.
Lenexa, Kansas 66219
February 18, 2015
Dear Regional Administrator Brooks,
(573) 751-3321
Thank you for your letter of February 9, 2015, updating our office on the EPA’s
recent directive regarding the Bridgeton Landfill / Westlake site. As you ’11 recall,
completing a comprehensive radiological characterization of the site was one of the three
action items discussed at our last meeting, and we appreciate the progress update and
your assurance that the work will proceed on an enforceable schedule.
We note also that, consistent with the second action item, EPA has secured
Bridgeton Landfill’s agreement to maintain soil corings and make them available for
EPA’s intended pyrolysis testing. Our recollection was that EPA expected that testing to
require five to six months to complete. Please keep us up to date on the progress of that
Finally, our colleagues from the Army Corps of Engineers suggested at our
meeting that an EVOH cover and gas extraction system could be explored as a potential
method to capture radon emissions that might occur as a consequence of the subsurface
fire at the landfill. As a third action item, we asked that EPA, in conjunction with the
ACOE, analyze the feasibility and probable effectiveness of installing such a system at
the Bridgeton Landfill/ Westlake site. Please let us know where things stand on that
We understand that scientific testing takes time to properly conduct. Yet, as we
have indicated before, the people of Missouri, particularly those who live, work, and go
to school near the landfill, are troubled by uncertainty surrounding the site and are eager
WLLFOIA4312 – 001 – 0001705
Karl Brooks
February 18, 2015
Page 2
for answers. We look forward to receiving the results of the above-mentioned tests and
analyses as soon as they are available.
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WLLFOIA4312 – 001 – 0001706
2/812016 Army Corps of Engineers to work on burning Bridgeton Landfill : News
– –
Army Corps of Engineers to work on burning Bridgeton
The Anny Corps of Engineers will help build an isolation barrier between an underground
fire at the Bridgeton landfill and radioactive materials in the adjacent West Lake Landfill,
according to the Environmental Protection Agency.
“The EPA intends soon to conclude an agreement with the United States Anny Corps of
Engineers to enlist Corps construction expertise for the isolation barrier to separate West
Lake from the (subsurface smoldering event),” EPA region seven administrator Karl Brooks
wrote in a letter Friday to Missouri Attorney General Chris Koster.
Construction on the barrier is expected to start within 90 days, Brooks said.
Koster urged the EPA this week to move quickly on the barrier. That move came one year
after Koster sued the landfills’ owner Republic Services, alleging violations of environmental
laws. Republic’s efforts to keep the fire from spreading “do not address the entire problem”
because additional radioactive material has been discovered closer to the fire, Koster said.
The Cold War-era nuclear waste was dumped illegally about 40 years ago and was
previously thought to be contained in West Lake. Early results from an EPA study show the
materials were found beyond the original perimeter and in the north section of the
Bridgeton landfill. The underground fire is in the south section.
Environmental groups and nearby residents have long called for the Army Corps of
Engineers to take over the cleanup of the Superfund site. The Corps has worked on other
nuclear waste cleanup projects around Lambert-St. Louis International Airport and
Coldwater Creek. Recently, several organizations, including St. Louis County, the cities of
Bridgeton and Maryland Heights and the Pattonville School District have supported such a
move. Missouri’s congressional delegation also called on the EPA to work with the Corps on
West Lake.
“I understand there’s a strong desire for action and that action is moving forward very
quickly,” Brooks said, adding that the EPA will retain authority over the site through its
Superfund program. “This is not a transfer to the Corps. This is an assist to EPA”
A spokesman for Republic Services said the company is committed to the construction of the
barrier when the regulatory authorities approve such a plan.
“The safety of both sites has always been our highest priority,” said Richard Callow.
http://www.stltoday.com/nev.1si1ocal/m etralarmy-corps-of-engi neers-to-work-on-burni ng-bri dgeton-landfi 11/articl e _ c914db0e-Oee4-50ca-a7 a2-53c565df2286.ht. . . 1 /1
WLLFOIA4312 – 001 – 0001707
FEB 13 20t5
The Honorable Chris Koster
Attorney General of Missouri
P.O. Box 899
Jefferson City, MO 65102
Dear Mr. Koster:
LENEXA, KS 66219
FEB 0 9 2015 OFFICE OF
I am pleased to report that the U. S. Environmental Protection Agency Region 7 has obtained agreement
from the West Lake Landfill Superfund site potentially responsible parties to gather additional data to
support identifying the nature and extent of Radiologically Impacted Materials contamination south and
west of the previously-defined boundaries of Operable Unit 1, Area 1. This Agency expects to receive
the work plan from the parties detailing this effort by the end of February, and the EPA will ensure this
work proceeds on an enforceable schedule. Bridgeton Landfill also provided written confirmation that
soil corings from the previous Phase 1 investigatory work have been maintained and can be made
available for the EPA’s proposed pyrolysis testing.
The EPA will continue to coordinate our efforts with the state of Missouri to ensure our respective data
collection activities at the Bridgeton Landfill and West Lake Landfill Superfund site support the mutual
goal of RIM identification and monitoring of the subsurface smoldering event.
Thank you for your and your staff’s excellent efforts to inform this agency about developments
connected with your office’s work on the Bridgeton Landfill. I have appreciated your timeliness and
Karl Brooks
WLLFOIA4312 – 001 – 0001708


2016-02-09 – EPA – Desk Statement and Update on West Lake Landfill Superfund Site Actions

Darryl Fears, Staff Writer Washington Post
1. Follow-ups with reporter
2. Desk Statement and Update provided to reporter
1. Follow-ups with reporter:
2. 02-09-2016 Desk Statement & Update on West Lake Landfill Superfund Site Actions
EPA is committed to working with the State of Missouri, as well as our federal partners with the U.S.
Army Corps of Engineers and the U.S. Geological Survey to implement a final remedy and other actions
to protect public health at the West Lake Landfill Superfund Site in Bridgeton, Mo.
Staff from EPA headquarters and Region 7 have met with the Just Moms STL members in person and
by phone, most recently this past Friday. We are in frequent contact to both listen to concerns and share
updates on progress at the site. We remain focused on numerous immediate and long-term actions
required to protect the community from the radioactive wastes contained at the West Lake Landfill in
Bridgeton, MO.
Our current priorities include:
Final Proposed Remedy
• EPA negotiated and finalized a modified Administrative Order on Consent Scope of Work
modification with the Potentially Responsible Parties (PRPs) in December 2015.
• PRPs will deliver a Remedial Investigation Addendum and subsequent Final Feasibility Study
for EPA’s review and approval this fall.
• Once the FFS is approved, EPA will finalize our evaluation of the 2008 remedy decision and
WLLFOIA4312 – 001 – 0001739
issue a draft final remedy for public review and comment.
Isolation Barrier Determination
• At the end of 2015, EPA announced its decision to require the installation of an isolation barrier,
along with other engineering measures, to ensure radiologically impacted material remains
separated from the subsurface smoldering event currently occurring in the adjacent Bridgeton
• EPA Region 7 made this decision with technical support from our Office of Research and
Development, the U.S. Army Corps of Engineers and in consultation with the Missouri
Department of Natural Resources and the Missouri Department of Health and Senior Services
throughout the fall and winter of 2015.
• Next Actions: EPA is negotiating the technical and legal details with the PRPs to perform this
work pursuant to an enforceable schedule. The state of Missouri continues its actions with the
owner of the Bridgeton Landfill to control the subsurface smoldering event and emissions.
Groundwater Investigations (new Operable Unit)
• EPA intends to investigate and address groundwater under a new Operable Unit (OU3). In late
2015 and January 2016, EPA had multiple discussions with the State of Missouri about future
groundwater work. Next Actions: EPA, with technical support from the U.S. Geological Survey,
is developing the scope of additional groundwater investigations to fully characterize the nature
and extent of contamination related to the site.
Surface Fire Unilateral Administrative Order for Removal Acton
• EPA issued a Unilateral Administrative Order (UAO) on December 9, 2015, for a time-critical
removal action to mitigate surface fire risks.
• The UAO requires the PRPs to:
o implement engineering measures to mitigate the risk of a surface fire within the boundary
of the West Lake Landfill site coming in contact with radiologically impacted material
(RIM) at or near the surface, and
o develop an incident management plan that will be used to coordinate with local
emergency responders.
• Next Actions: Work at the site begins the week of Feb. 8-12 and is expected to be completed
later in the spring of 2016. The PRPs provided EPA with a draft work plan and supporting
documents for constrnction of a non-combustible cover and an incident management plan. EPA
is currently reviewing these documents. A final report will be made available to the public.
Dialogue Framework
• EPA desires a more inclusive, transparent and fact-based dialogue with the community so we
have contracted with neutral facilitators Cindy Cook and Dain Maddox of Adamant Accord.
They have spoken with community members during this past week and continue to meet with
them in-person in St. Louis this week. These facilitators have substantial experience in
facilitating respectful and substantive dialogue regarding complex environmental issues. After
meeting with community members, they will report their findings at a meeting in St. Louis at the
end of Febrnary and then develop a framework for continued dialogue with this diverse group of
community members and leaders and EPA Region 7 staff.
WLLFOIA4312 – 001 – 0001740
WLLFOIA4312 – 001 – 0001741


2015-03-09 – USACE – Transmittal Letter Comments IB Alternatives Analysis Report Oct 10 2014

KANSAS CITY MO 64106-2824
Printed on Recycled Paper
March 9, 2015
Mr. Brad Vann, Remedial Project Manager
U.S. Environmental Protection Agency Region 7
11201 Renner Boulevard
Lenexa, KS 66219
Dear Mr. Vann:
The U.S. Army Corps of Engineers (USACE) has completed a review of the “Isolation Barrier Alternatives Analysis – West Lake Landfill Superfund Site” Report dated October 10, 2014 and prepared by Feezor Engineering of Bridgeton, Missouri, P.J. Carey & Associates of Sugar Hill, Georgia, Auxier & Associates, Inc. of Knoxville, Tennessee, and Engineering Management Support, Inc. of Lakewood, Colorado on behalf of Bridgeton Landfill, LLC. Note that this review was a qualitative analysis as plans and specifications for each alternative was not provided. These comments were originally transmitted to you on November 6, 2014.
USACE comments are as follows:
1) Section 3.4. If no action option is implemented and the SSE moved through the north quarry into Area 1, it is likely that the surface of the north quarry would drop and any leachate collection lines could potentially be severed due to the drop in landfill surface. If that occurred, would leachate spills from severed lines cause a potential increase in odors?
2) Section 3.6. At what depth to surface is there a risk of an SSE igniting a surface fire? If the SSE is able to migrate vertically it seems that there may be a potential for an SSE to ignite surface material.
3) Section 3.6. Last sentence – recommend including a reference to the section of the report where the quantitative evaluation for the No Action Alternative is included.
4) Section 3.6.1. Descriptions of locations of heat generating material are provided in Paragraph 3; however, it is difficult to follow the description. Recommend including a figure to help show/clarify the information trying to be conveyed.
5) Section 3.6.1. Para 5, 4th sentence. Inclusion of boring log cross sections with nearby temperature probe data on a figure would help clarify this information and prevent the reader from having to dig through past reports submitted to EPA and reports submitted to MDNR to confirm the information presented. Additionally, current boring logs from the most recent sampling event where additional RIM was found would be beneficial as well.
USACE Comments – Bridgeton Landfill Thermal Isolation Barrier 2
Alternatives Analysis Report
March 9, 2015
6) Section 3.6.1. Last paragraph – overall claim that it is highly unlikely that the SSE could migrate laterally – recommend that all the data cited to support this claim be provided with this report and clearly identified.
7) Section 3.6.1. Para 4, last sentence – Approximately how many other sites indicate no pyrolysis occurs in waste depths of less than 60 feet? Refer to section 4.7, advantages bullet 4, which states alignment 1 offers the lowest potential for a SSE to original on the north side of the barrier because the alignment is located along the northern boundary of the North Quarry area. Recommend consideration that the bullet language be changed to state that it offers the lowest potential for a SSE due to the alignment and the thickness of waste being less than 60 feet.
8) Section 3.6.1, 3rd Paragraph. The 10th line states that materials below the 360 to 380 elevation are undergoing heat loss. Para states that 360 to 380 may be the depth of reactive wastes or may reflect “thermal restraints”. Has the elevation of the groundwater level in this part of the quarry been considered? Is it such that the groundwater level is serving as a “thermal restraint”?
9) Section 3.6.1, 3rd Paragraph. The final sentence in this paragraph states that a similar pattern of heat dissipation is seen as the elevation in the landfill approaches the ground surface. The on-going studies/data that support this assertion and others made within this report should be included in this report as an attachment so the assertions can be easily verified without having to search through multiple reports to find supporting data.
10) Section 3.6.1, 4th Paragraph. This paragraph builds on the assertions of the previous paragraph stating that significant reduction of waste thickness in the north section of the north quarry will increase heat dissipation and expressed doubt that any significant pyrolysis would occur in wastes of such a shallow thickness. The paragraph asserts that this is consistent with observed behaviors of other sites with waste thickness less than 60-feet. Please provide references of the cited landfill SSEs to facilitate review of the referenced performance.
11) Section 3.6.1, Pg 7, 3rd Paragraph. How is the 25 times greater heat dissipation in Area 1 over that of the South Quarry determined?
12) Section 3.6.1, Pg 7, 3rd Paragraph. The statement that “no pyrolysis in waste depths of less than 60-feet should be supported by literature and/or example sites.
13) Section 3.6.1, Pg 8, 1st Paragraph. It would be helpful to provide a figure (cross section) illustrating what is being described in this paragraph.
14) Section 3.6.1, Page 7. Typo in second paragraph “… indicating they these materials…”
15) Section 3.6.2. It would assist in evaluation to provide updated figures defining the perimeter of Area 1. Figure 4-14 from the RI shows the locations where flux sampling was conducted. Locations 105, 107, 110, 120, 121, 122, 123 and 124 appear to be outside of the defined Area 1 boundary and their use in determining average flux activity may bias the actual flux from Area 1 low, though Location 105 does appear to have elevated Ra-226.
16) Section 3.6.2. Is Subpart T (Disposal of Uranium Mill Tailings) the cited NESHAP requirement? St. Louis FUSRAP has evaluated radon releases against the 40 CFR 192.02 (b) alternate criteria of 0.5
USACE Comments – Bridgeton Landfill Thermal Isolation Barrier 3
Alternatives Analysis Report
March 9, 2015
pCi/L, which may be also be an appropriate criteria to evaluate if UMTRCA is an ARAR. This would be better criteria to evaluate what exposure there may be to members of the public, if any. Models such as CAP88, AERMOD, or RESRAD-Offsite may be helpful to demonstrate a lack of current exposure, or monitoring data taken downwind from the facility could be discussed.
17) Section 3.6.2. It may be helpful to note here that additional radon generation may also be present in effluent releases from the gas collection system and not solely through radon emanation from the surface as discussed in Section 4.4 of Appendix A.
18) Section 3.6.2. Bullets – there were a total of 7 conclusions in EMSI’s report. 5 of those conclusions appear to relate to potential impacts if an SSE were to occur of the SSE that, at a minimum, should be addressed as part of a no action consideration. This report addresses only 3 of the 5 bullets. Recommend including and addressing bullet 4 from EMSI’s report: “An SSE in West Lake Area 1 or 2 would create no long-term additional risks to people or the environment.” and bullet 5 from EMSI’s report: “Any short-term risks would be associated with the temporary increase in radon gas coming from the surface of the landfill if no cap is installed on the landfill, or if the cap called for by the 2008 ROD was not properly maintained.”
19) Section 3.6.2. Para 4. the Flux calculations in Attachment A are compared with surface radiation measurements from the EMSI RI report in 2000. Recommend including that surface measurements will be taken to confirm calculated concentrations prior to selection of any no-action approach.
20) Section 2.6.2. Para 6. states that “even if these conditions were to occur, the radon emission rate from Area 1 could still be less than the standard….” then in the last sentence of the paragraph states the magnitude of radon emissions would still be less than the establishes standard….” The use of these two words seems contradictory.
21) Section 3.6.2, p 9, 3rd Paragraph. The discussion regarding leachate generation rates is appears inconsistent with the June 2013 Contingency Plan which states, “Heating of waste which results in steam/water vapor front moving out, up, and away from the SSE, which then condenses in the cooler surrounding waste mass and gas extraction well resulting in higher localized leachate generation.” Please clarify.
22) Section 3.7, Pg 12, 4th bullet. This bullet appears redundant. Recommend removing.
23) Section 3.7. A no action alternative would still require additional monitoring to observe whether modeled radon flux corresponds to actual radon flux in the event an SSE migrates to/occurs in Area 1.
24) Attachment 1, section 2.2. The RI states that the 95% UCL of the mean for surface radium is 581 pCi/g. Because shallow/surface material will contribute more to radon flux than subsurface material, it seems like an additional surface layer should be added to the RAECOM model.
25) Attachment 1, section 2.2. Though the reviewer agrees that the average flux calculated over Area 1 is 13 pCi/m^2/s and below the 20 pCi/m^2/s standard, Area 1 seems very heterogeneous, with only 1 measurement the same order of magnitude as 13 (location WL-106 at 22.3) Most flux measurements are well below this, but measurements exist ranging from 0 to as high as 246 pCi/m^2/s. Given that sample data and flux data is available for most locations it may be helpful to run the model for each
USACE Comments – Bridgeton Landfill Thermal Isolation Barrier 4
Alternatives Analysis Report
March 9, 2015
location where surface flux and surface/subsurface sample data is available to determine how well the RAECOM model compares to actual site data.
26) Attachment 1, section 2.2. It would be helpful to justify the use of 0.2 as the radon emanation fraction, as the RAECOM online instructions recommend a value between 0.2 – 0.3 and 0.2 is the low end of this value. The RESRAD default value is 0.25, which may be more appropriate.
27) Attachment 1, section 2.2. This analysis seems to imply an SSE is impacting the top 1.7 m of soil. At what point would risk transition from increased radon release from subsurface soil to release from a surface fire? If an SSE encounters material in the top 6′ of soil it seems like ignition of surface material may pose a larger risk than increased radon production. A surface fire could potentially pose greater risk than a SSE (ie. dust kicked up with Th or U).
28) Attachment 1, section 2.2. Is the cited gas temperature increase to 80º C consistent with current observations of the SSE and assumptions used for the design and evaluation of alternatives? Discussion above (Section 6.1) seems to suggest 200ºF (~90º C) is a design consideration?
29) Attachment 1, section 2.2. Area 1 should be better defined on a drawing (similar to Figure 4-14 of the RI) to ensure that “clean” flux measurements are not inadvertently included, see comment #16
30) Attachment 1, section 4.5. Though a comparison to 10 CFR 20 may be helpful in the absence of other regulatory criteria, it should be noted that 10 CFR 20 effluent releases generally apply only to releases from an NRC licensee and may not be applicable at a CERCLA site. The effluent concentrations listed in Table 2 correspond to a public total dose of 50 millirem/year, which is above those generally allowed by EPA at CERCLA Sites. Recommend you don’t compare to 10 CFR 20 since EHA has a more stringent standard.
31) Attachment 1, section 4.5. Suggest removal of the last paragraph of Section 4.5 as the release of radon into the air from stack release is not directly comparable to radon present in soil gas.
32) Attachment 1, section 4.5. 10 CFR 20 Appendix B Table 2 contains two values for radon, one for radon in 100% equilibrium and one for radon without daughters. Suggest a clarification that radon effluent releases are being compared to the 0.1 pCi/L criteria that assumes all daughters are present in equilibrium, or provide a discussion of measured/assumed equilibrium factor.
33) Section 4.0. The analyses of Options 1 and 3 generally agree with the analyses completed by USACE and provided to the EPA in the “Isolation Barrier Alignment Alternatives Assessment” dated 25 August 2014.
34) Sections 4.0 and 6.0. The eastern limits of the Option 1 & 3 alignments shown on Drawing 002 appear to violate the location of the North Quarry wall shown on Figure 2 of Part I of the Bridgeton Landfill Contingency Plan. Please verify that the proposed alignment does not violate the quarry wall and indeed meets the assumed 45-degree offset.
35) Sections 4.2 and 6.2. The excavation volumes are based on a 60-foot wide working platform which will be wide enough to accommodate the slurry trench excavating machinery and tooling. But the typical section of the slurry trench cutoff wall shown in Dwg 16 locates the wall at the center of the 60-foot wide platform. The plan view of Alignment 1 with the Waste Cut areas shown on Dwg 003
USACE Comments – Bridgeton Landfill Thermal Isolation Barrier 5
Alternatives Analysis Report
March 9, 2015
clearly shows the alignment assumed to be at the centerline of the work platform. But to accommodate the excavating machinery, the excavated trench will need to be much nearer one of the edges of the work platform. Given that the alignment is fixed based on occurrence and non-occurrence of RIM in the foundations, and the alignment must be near the edge of the working platform, the excavation plan must be shifted laterally up to 20-feet. Similar issue with Alignment 3.
36) Section 4.2, Pg 13, 1st Paragraph. A construction platform of 45-ft was originally discussed. A comment was made on the Pre-construction work plan, section 2.1 that asked you to ensure that the proposed 45-ft wide excavation is enough to allow access for support vehicles. Is the additional 15 feet required for support vehicles? If so, please clarify what this width accommodates and how the equipment will be configured such that 60′ is required.
37) Section 4.2, Pg 13, 1st Paragraph. Based on a review of the cross sections and a comparison to Option 3 (where there is substantial change of elevation along the length of the wall), it appears that a working platform could be constructed for Option 1 with much lower pre-excavation volumes. This would result in a slightly deeper wall but may be a good tradeoff due to odor and bird mitigation issues.
38) Section 4.2, Page 14, top Paragraph. This indicates the barrier volume is 5,000 bcy, however sheet 003 indicates the barrier volume is 7,500 bcy.
39) Sections 4.3 and 6.3. The 10th line states that trench construction “using slurry would require slurry decanting/liquid”. Slurry trench construction requires large volumes of slurry (typically soil-bentonite slurry) to provide trench wall support during trench excavation. When completed this slurry is typically processed to remove as much of the soil solids that are suspended in order to reduce the volume of slurry liquids that must be properly disposed of. A 10-foot wide, 3-foot thick, and 40-foot deep panel will need 1,200 cu-ft (8,970 gallons) of slurry. In this case, if a particular trench panel encounters RIM during its excavation, how will the slurry be disposed of? How you intend to address the slurry should be included in Section 4.1 or 4.2 (and 6.1 or 6.2) as it is waste that will be required to be disposed.
40) Sections 4.3 and 6.3. USACE has studied the 3-dimensional global stability of earthen levees assuming discrete panels excavated near the levee toe. This analysis is completed using FLAC-3D. Depending on the geotechnical parameters of the various fills/wastes encountered in the trench and remaining in the adjacent excavated slopes, longer panels may be safely used thereby shortening the construction times. To complete this analysis, detailed geotechnical exploration incorporating in-situ measurements of shear modulus with pressure meter must be completed. Recognize that this is a design issue to be addressed later; however, it can impact the quoted schedule.
41) Section 4.3, Pg 14, 1st Paragraph. Recommend changing “reaction” to “SSE”.
42) Section 4.3, Pg 14, 1st Paragraph. Recommend expanding on the limitation associated with storm water management.
43) Section 4.3, Pg 14, 1st Paragraph. The design timeframe (103 wks) has increased substantially over what had been previously discussed. Based on a review of the schedule there appears that there are places where durations could be reduced. For example, investigations could begin prior to completion of the heat extraction study.
USACE Comments – Bridgeton Landfill Thermal Isolation Barrier 6
Alternatives Analysis Report
March 9, 2015
44) Section 4.3. Last Paragraph. EPA will have to make determination on requirement regarding the need to test waste above the 1975 topographic surface. This is a landfill and although there may not be RIM above the 1975 topographic surface, there may be other constituents of concern and testing may be warranted.
45) Section 4.6. Recommend that laboratory data and boring logs from last sampling event be provided along with an updated dwg of currently know extent of contamination and information regarding vertical distribution of contamination if the information is to be relied upon for this report to back up a no action response. Recommend including a dwg showing estimated 1975 topographic surface and 1975 aerial photographs upon which this estimated surface is based. Would need to include that information that is being relied upon in this report to support the no action option.
46) Section 4.6. Para 2 – recommend the specific section in Attachment A that contains the info being referenced in this text be added within the parentheses so it is easy for reader to locate the information.
47) Section 4.7, Pg 17, 6th bullet. Although there is a caveat later in the document regarding acceptability of leaving excavated RIM waste on-site, that is far from certain so recommend not listing it as an advantage.
48) Section 4.7. It would be helpful in evaluating alternatives if an estimate of the potential amount of RIM to be excavated was discussed.
49) Section 4.7. The extent of RIM has not yet been determined. Recommend author considers qualifying the language in the first paragraph by indicating that the statements are based upon data collected to date and that the extent of RIM has not yet been determined.
50) Section 4.7. Report states, “Radon emissions from the RIM material located outside of the barrier would not result in an exceedance of the Radon NESHAP.” Because the extent of RIM has not yet been identified and because of the heterogeneity of the waste placement, recommend that this text be revised to allow for this consideration.
51) Section 4.7. Disadvantages – can non-rad waste removed as a result of barrier installation be placed back in the landfill? If this has not yet been determined, then it is recommended that it be captured as a disadvantage because there is a possibility that it would not be approved. If not approved, it would significantly impact the construction duration.
52) Attachment B, para 1.1.2. Another opportunity to provide clarity to the design would be to assume that the “maintenance” of the wall would include re-adjustment of the top of fill elevation on the “hot-side” of the wall. As the pyrolysis induced settlement (accelerated settlement due to consumption of waste materials due to SSE) occurs, the ground surface on the “hot side” of the wall could be raised to limit the difference in ground surface between the “hot side” and “cold side” of the wall. Use of careful compaction techniques (from just spreading fill to fully compacting the fill) could keep the in-place unit weight of the fill to within acceptable levels to equalize the geostatic horizontal stress placed on both sides of the wall.
USACE Comments – Bridgeton Landfill Thermal Isolation Barrier 7
Alternatives Analysis Report
March 9, 2015
53) Attachment B, para 1.1.2. The first paragraph states that it has been determined that anchoring the NCE into the alluvium/bedrock is not feasible. Dwg 004 shows the Option 1 NCE proposed to extend down to elevations 420 to 430. Cross section AA in Figure 2 of Part I of the Bridgeton Landfill Contingency Plan shows bottom of wastes or top of bedrock at/around elevation 425 under OU-1 Area 1. It seems that the top of rock may be quite close and if so, anchoring the NCE into the bedrock may not be as infeasible as first thought. Use of hydro mill technology to key into the bedrock is a common technique. Keying into bedrock will provide clarity on the fixity of the bottom of the NCE.
54) Attachment B, para 1.1.2. Perhaps the responsible party should consider a limited application of the heat extraction technology installed on the “hot-side” of the wall. If successful, it could limit the temperature applied to the concrete surface and thereby limit the heat induced stresses/strains.
55) Attachment B, para 1.1.3. See comment #42 concerning 3 dimensional slope stability using FLAC-3D.
56) Attachment B, para 1.1.3. A monitoring system will also include surveys of the ground surface adjacent to both sides of the wall. Also, replaceable temperature gages should be installed in the wall interior. Given the proposed life span of the wall, the temperature gages would have to be accessible for maintenance and replacement as necessary. Also some kind of telltale extending to the base of the wall to determine its elevation (if not embedded into bedrock) should be considered. It is recognize this is a design consideration and would be addressed during design.
57) Section 6.2, Pg 22, 1st Paragraph. Recommend explaining why a barrier width of 5.0-ft was assumed versus the 3.0-ft width of Option 1. It is assumed this is for structural considerations due to the greater depth of the wall.
58) Section 6.2, Pg 22, 1st Paragraph. Sheet 010 indicates a barrier volume of 7,500 bcy for Option 3 as opposed to the 11,000 bcy sited here in the text.
59) Section 6.7, Pg 25, 2nd bullet. Recommend not listing the potential to leave excavated RIM waste on-site as an advantage.
60) Section 6.7. The extent of RIM has not yet been determined. Recommend author considers qualifying the language in the first paragraph by indicating that the statements are based upon data collected to date and that the extent of RIM has not yet been determined.
61) Section 7. It is stated that for Option 4, the heat extraction points would be installed such that depths of the extraction points would be relatively shallow. Does this shallow installation still include installation down to the bedrock as indicated in drawing sheet 16?
62) Section 7.1. It is stated for Option 4, that the cooler would consist of an adiabatic air cooler installed with a closed loop liquid circulation system. While Attachment C., Heat Extraction Barrier Design Memorandum, describes a close circuit cooling tower. Please verify that a close circuit cooling tower is the current design concept.
USACE Comments – Bridgeton Landfill Thermal Isolation Barrier 8
Alternatives Analysis Report
March 9, 2015
63) Section 7.1. The limiting criteria for any barrier system would be to maintain the waste on the north side of the barrier at an average temperature of 175 degrees Fahrenheit. What is the best guess for the entering and leaving temperatures of the cooling liquid at this time?
64) Section 7.1. The heat extraction points would be driven in place vs. drilling a well. What is the typical depth that the pipe can be driven into place? What is the depth of the bedrock at the proposed locations? What is the possibility of success with this method of installation?
65) Section 7.6. Para 2. Potential RIM outside the barrier is not expected to pose a significant risk (see attachment A) and RIM outside barrier would not result in exceedance of Radon NESHAP. Recommend the specific section in Attachment A in which the information that supports this can be found is cited in the parentheses.
66) Section 7.7. It is stated for Option 4, that “The RIM material that would remain outside of the barrier wall is currently covered by 25 to 50 of solid waste and a landfill cover that prevents direct contact with the RIM and provides shielding from gamma radiation.” Recommend units of measurement be inserted (ie. “…25 to 50 ‘feet’ of solid waste…”).
67) Section 7.7. It is stated for Option 4, that “Installation of heat extraction points is a common technology used for geothermal energy development and therefore this alternative is technically feasible.” However, it comes down to the numbers. How do the proposed conceptual design conditions compare to the design conditions for a typical system that comprises this common technology? Do geothermal systems exist that have design conditions that are in the same neighborhood of the conditions that will exist within the SSE?
68) Attachment C, Section 1.1. It is stated that “The primary data parameters recorded…” from the single well, GIW-4, “…were the inflow and outflow water temperatures, flow rate and the temperature within the casing as measured by thermocouples at multiple depths. Where is that data, specifically the water flow rates and the entering and leaving water temperatures? Recommend that data be included in the report to as an attachment to support the claim of feasibility.
69) Attachment C, Section 1.3. It is stated that “Estimates of the maximum heat flux in the south quarry have been in the range of 14 Watts/sqm, as of July 2013.” This rate is very low. This rate is slightly less than 5 Btuh/sqft, which, as a comparison, would not fully heat a typical building to typical occupied conditions in the warmest areas of this country. Over what area is this rate determined? What is the total heat to be rejected by the system?
70) Attachment C, Section 2.2. It is stated that the vertical heat extraction elements be comprised of corrosion resistant metal (low carbon stainless steel) or nonmetallic materials. Metallic materials underground may required cathodic protection while temperature limitations maybe an issue for nonmetallic materials. It is recognized that this is a design issue that will need to be considered during design.
71) Attachment C, Section 2.3. Please confirm that the proposed design delta temperatures for a cooling tower powered system are 175 degrees F minus 85 degrees F or 90 degrees F.
72) Attachment C, Section 2.3. Please confirm that the proposed design delta temperatures for a chiller powered system are 175 degrees F minus 40 degrees F or 135 degrees F.
USACE Comments – Bridgeton Landfill Thermal Isolation Barrier 9
Alternatives Analysis Report
March 9, 2015
73) Attachment C, Section 2.3. It is stated that “These systems will be above ground HDPE pipe with flex connections to the extraction points.” Typically, we only see HDPE pipe installed below grade due to issues with UV. How will this be addressed? It is recognized that this is a design issue that will need to be considered during design.
74) Attachment C – General. The issue with utilizing typical HVAC machines in this situation is that the equipment pretty much does what it was designed to do, which is not a delta temperature of 90 to 135 degrees F. Specifically, vapor compression chillers typically will not produce a delta temperature above 20 degrees F and will shut down on a safety if entering water temperatures become too extreme. With a flowing fluid, do you intend to use equipment in series to achieve the necessary temperature differential? Do you know of a specific chiller that is capable of these high temperature drops?
75) Attachment C, Pg 3, 2nd Bullet. Why was a point of compliance of 15-ft north of the cooling elements selected for Option 4?
76) Drawing 16. The Option 1 and 3 Typical Inert Barrier shows the barrier centerline located in the center of the flat work area. To accommodate the heavy excavation machinery and tooling, the Inert Barrier must be located approximately 45 to 50 feet away from either edge. USACE studies of slope stability show that better global stability factors of safety are obtained when the heavy excavation machinery and tooling is located on the side of the trench opposite the taller excavated slope.
77) All Drawings. All drawings show historical boundaries. Recommend these drawings be updated to reflect current contaminant boundaries with a dashed line where the extent of contamination has not been determined.
78) Drawings 002 and 009. The eastern limits of the Option 1 and Option 2 alignments shown on Drawings 002 and 009 appears to violate the location of the North Quarry wall shown on Figure 2 of Part I of the Bridgeton Landfill Contingency Plan. Please verify that the proposed alignments do not violate the quarry wall and indeed meets the assumed 45-degree offset.
79) Drawings 003 and 010. Each of these drawings include values of pre-excavation and barrier excavation volume. Recommend also showing the overall volume needing to be relocated.
80) Sections 3.5, 3.6, 3.7, 4.5, 4.6, 4.7, 5.0, 6.5, 6.6, 6.7, 7.4, 7.5, 7.6, 7.7, and Attachment D. There is still no Bird Monitoring and Control Plan to review. The sections reviewed considered the concerns of the St Louis Airport Authority and consistently assessed the concerns of quantity of waste and duration of exposure and the impacts those two things have on Bird Airstrike concerns. A new Alternative, Heat Extraction Barrier, was introduced that has less bird airstrike implications than the other options. There was not much emphasis placed either on covering excavated waste or in handling and transport of waste for installation of the isolation barrier. This should be covered in the forthcoming Bird Monitoring and Control Plan.
USACE Comments – Bridgeton Landfill Thermal Isolation Barrier 10
Alternatives Analysis Report
March 9, 2015
USACE is available to participate in a comment resolution meeting upon request.
Robyn V. Kiefer
Project Manager
CC: Scott Young-CENWK-PM-E
Jason Leibbert-CENWK-ED-E

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