Frequently Asked Questions – West Lake Landfill
Category 1: Location of Radiologically Impacted Materials (RIM)
Category 2: Superfund Remedial Process
Category 3: Risk Assessment
Category 4: Isolation Barrier
Category 5: Subsurface Smoldering Event (SSE)
Category 6: First Responders and Worker Safety
Category 7: Miscellaneous
Category 1: Location of Radiologically Impacted Materials (RIM)
Q: Does the EPA have any plan to re-sample historical haul routes related to the transportation of Formerly Utilized Sites Remedial Action Program (FUSRAP) waste or to test haul routes to the landfill not tested under the FUSRAP program? Does EPA have plans to test for the presence of thorium 230 and other West Lake Landfill contaminants in all areas around the perimeters of Operable Unit 1 (OU1)?
A: EPA has no plans to retest any of the haul roads. All of the results from the Missouri Department of Natural Resource’s (MDNR’s) 2005 sampling were below the cleanup standards established for the St. Louis Airport Sites (SLAPS).
Q: Do any maps exist showing areas where RIM has been identified to date?
A: A map defining the previously designated areas of radiologically impacted material (RIM) in OU1 Area 1 and Area 2 can be found in the 2008 Record of Decision (ROD), Figure 5-5. The December 2014 Phase I report identifying additional locations of RIM at the southern and western edge of OU1 Area 1 is available on EPA Region 7’s West Lake Landfill website (1,361 pp., 74.94MB, About PDF). Site maps will be updated following completion of the additional RIM investigations in OU1 Areas 1 and 2.
Q: What is EPA doing to determine the southernmost boundary of RIM in Area 1?
A: EPA is overseeing the ongoing “Phase 1D” sampling work in this area at the site. A goal of this effort is to further characterize the extent of RIM along the southern and western boundaries of Area 1.
Category 2: Superfund Remedial Process
Q: Will EPA Region 7 consider climate change in the remedy reevaluation?
A: Relevant and predictable climatic or geologic events that are anticipated in this area (i.e., tornadoes, flooding, etc.) are typically addressed during evaluation of remedial alternatives in terms of implementability, and during remedial design. Remedies to address contaminated sites may also be vulnerable due to the impacts of climate change. Therefore, EPA's Superfund Program has developed an approach that raises awareness of the vulnerabilities and applies climate change science as a standard business practice in site cleanup projects. In accordance with Executive Order 13653 (2013) and EPA’s Draft Climate Change Adaptation Plan (February 2013), the remedies also will be evaluated for vulnerabilities following the Office of Solid Waste and Emergency Response (OSWER) Climate Change Adaptation Implementation Plan (June 2014).
Q: Did the EPA consider contaminants other than the RIM when evaluating remedial options for the site?
A: The Remedial Investigation/Feasibility Study (RIFS) and the 2008 Record of Decision for OU1 fully considered non-radiological contaminants in OU1 and selected a remedy that would protect the public from all contaminants in OU1, not just radiological contaminants. Any future final remedy decisions would likewise consider and be protective for other contaminants of concern in OU1.
Q: Will the EPA conduct remedial action at the site to clean-up the West Lake Landfill Superfund site to a minimum excess lifetime cancer risk of 1 in a million (1x10-6) for future onsite workers, future trespassers and future offsite residents?
A: Any remediation of the West Lake Landfill site will be conducted within the regulatory risk range of 10-4 to 10-6.
Q: Are there any laws regarding “Sellers Disclosures” when selling your home within a mile of a Superfund Site?
A: State law may require such disclosure. Sellers should contact a real estate professional or real estate lawyer for advice on this matter.
Q: Will the potential risks of a smoldering or surface fire be considered in the EPA Region 7 ROD Amendment?
A: The potential effect of a smoldering or surface fire on the final remedy will be considered during evaluation of remedial alternatives in terms of implementability and during remedial design.
Q: What steps remain in order for EPA to make a final decision on the soils remedy?
A: Additional soils investigatory work in OU1 Area 1 and Area 2 is ongoing to aid in the evaluation of a partial excavation remedy. The potentially responsible parties (PRPs) are also completing other studies which will result in better scoping and comparison of various remedial options. This evaluation of remedial options, including partial and full excavation of soils contaminated with RIM, will be contained in a final feasibility study. Using the information in that final feasibility study, Region 7 will consult with our Office of Solid Waste and Emergency Response and the National Remedy Review board on our proposed final decision. After that consultation, EPA will announce its proposed decision and solicit public comment on it.
Q: How does the EPA designate a “background” number at sites with radiological contamination?
A: Background samples are collected from areas with no evidence of previous radiological contamination. Samples can be collected from off-site if necessary. Background samples may contain naturally occurring radioactive isotopes.
Q: Does EPA Region 7 consider the possibility for future property damage/loss to nearby residents and businesses in its decision-making process for the ROD Amendment?
A: No. EPA lacks the legal authority to consider such damages. Pursuant to the Superfund law, Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), EPA has the legal authority to respond to releases, or substantial threats of releases, of hazardous substances into the environment. The factors that EPA must consider for remedy selection purposes is dictated by the statute, and the National Oil and Hazardous Substances Pollution Contingency Plan, specifically the nine criteria set forth in Title 40 of the Code of Federal Regulations 40 C.F.R. Section 300.430. CERCLA does not provide a means for EPA or private parties to compel the payment of, or recover damages associated with, personal injury, diminution in property value, “stigma damages,” lost profits, or lost rents.
Q: Will the potential for levee failure be considered during the remedial process or selection of a final remedy?
A: The integrity of any final remedy will not be dependent on the levee’s competency. If contaminated soils remain in place at the landfill as a part of the final remedy, the cover/cap over those contaminated soils will be designed to be protective in the event of flooding.
Q: Is the installation of a cap as specified in the 2008 ROD and 2011 Supplemental Feasibility Study (SFS) still under consideration?
A: Yes. EPA is still in the process of re-evaluating remedial alternatives for OU1, which include fully excavating, partially excavating, or capping the landfill wastes.
Category 3: Risk Assessment
Q: Does EPA plan to review the Baseline Health Risk Assessment used to inform its 2008 Record of Decision?
A: As EPA reviews new data at the site, we will evaluate the potential for further exposure pathways at the site and the need for a revised Baseline Health Risk Assessment.
Q: Does EPA plan to review and conduct a risk analysis of the air monitoring data that is being collected by Missouri DNR?
A: No. The Missouri Department of Health and Senior Services (MDHSS) performs an analysis of the MDNR air monitoring data and publishes the results of their analysis on the MDNR Bridgeton Landfill website. EPA works in partnership with the state of Missouri.
Category 4: Isolation Barrier
Q: What is the status of the proposed isolation barrier?
A: EPA will make a decision about the proposed isolation barrier after ongoing RIM data collection efforts in OU1 Area 1 are completed and analyzed. EPA is also evaluating whether there is testing that could be performed on the RIM which would be helpful in making this decision.
Category 5: Subsurface Smoldering Event (SSE)
Q: Is EPA evaluating what may happen if the SSE encounters the RIM?
A: EPA is researching the possibility of designing a study to evaluate the effect of high temperatures on RIM. The intent of the study would be to increase our understanding of what could occur if the SSE encounters RIM. Results of the study could also better inform the radon flux calculations. It is not yet clear whether there are tests protocols available which would be informative to decisions at the site.
Q: What potential risk does a SSE pose to RIM located in the West Lake Landfill?
A: EPA’s Office of Research and Development has evaluated the conditions at the landfill, along with data collected on the SSE’s temperature and gas concentrations to date. Based on their evaluation, the Agency believes that should the SSE come into contact with the RIM, the RIM would not become reactive or explosive at the temperatures typically observed in an SSE. An SSE would be expected to change the conditions within the landfill, and likely increase the rate at which landfill gases are released. We would anticipate an increase in release of gases from the landfill through surface cracks or fissures that may form. These gases could be released as steam, radon, and potentially other gases (as determined by the composition of the non-RIM materials present). From what we know of the constituents of OU1, particularly the RIM, we don’t expect any of the gases released to contain RIM material. We do expect radon to be released, as this is a breakdown product of the RIM in OU1 and it is a naturally occurring gas from geological formations in our area. Based upon the EPA’s understanding of the SSE, the release of any gases would be localized and not occur over the entire site, and is dependent on the composition and behavior of site soils that would influence rates of subsurface gas mobility. EPA is evaluating whether there is any testing on RIM which could be performed that would further inform these predictions. EPA is also having the potentially responsible parties (PRPs) collect additional soil samples this fall for geotechnical analyses to better understand the soils’ physical properties which will aid in radon flux calculations.
Q: When did EPA Region 7 first learn of the smoldering landfill fire in the South Quarry of OU2?
A: EPA was initially notified by MDNR in December 2010 of the smoldering when the landfill’s gas composition had started to change and temperatures became elevated.
Category 6: First Responders and Worker Safety
Q: What is being done to ensure worker safety at the West Lake Site?
A: When EPA requires the PRPs to perform work at the site, we require the PRPs to submit a work plan, subject to EPA review and approval, describing the work to be performed. In addition, EPA requires the PRPs to develop and submit health and safety plans along with work plans for field work.
Q: Who can the community contact with concerns regarding on-site worker safety?
A: We encourage any concerned community members or workers to contact the Occupational Safety and Health Administration (OSHA) directly with concerns about worker safety. The local OSHA office can be reached by calling 314-425-4249 or 800-392-7743. Request to speak with the “Duty Officer.” According to OSHA, once a complaint is received, their office will assign an inspector to perform the health and safety inspection. All public complaint information provided to OSHA is confidential and not released to outside parties. They also have a complaint process available under whistleblower protection if needed.
Q: How does EPA work with first responders who may need to respond to a surface fire at OU1?
A: EPA has assisted St. Louis County and other local first responder entities in developing their current emergency response plan in the event there is a need for an action by local first responders. The action plan includes elements to address firefighting, emergency response, relocation, and technical assistance that can be provided by state and federal entities. EPA participated in numerous conference calls, reviewed and commented on draft plans, and continues to serve in an advisory capacity with regard to that emergency response plan. Specifically, EPA Superfund Program personnel are part of the West Lake Landfill Emergency Planning Team. The team is comprised of MDNR and other state agencies, St. Charles and Bridgeton Fire Departments, St. Louis County Health Department and County Emergency Management, and various other state and local agencies (i.e., Red Cross, Combat Support Staff, etc.). EPA will continue to offer our support to local emergency responders.
Category 7: Miscellaneous
Q: Is the leachate treated on-site before being transported to the Bissell Point Wastewater Treatment Plant?
A: Before being directed to the Metropolitan Sewer District (MSD) Bissell Point Wastewater Treatment Plant (WWTP) for final treatment, the leachate receives preliminary treatment at the newly operational Bridgeton Pretreatment WWTP. This preliminary treatment is designed to adjust the pH, reduce metals, settle solids, and reduce organic material that reduces oxygen in the water column. MSD has issued Bridgton Landfill an Industrial Wastewater Discharge Permit that limits the amount of flow and the pollutant load that can be discharged to MSD collection system.
Q: What circumstances or criteria does EPA Region 7 use to determine if a contractor hired by a PRP should be removed or disapproved?
A: Any contractor hired by the PRPs must be approved by EPA to perform the work directed in the order. Pursuant to EPA’s Remedial Investigation/Feasibility Study (RIFS) Administrative Order on Consent with the PRPs, EPA has the ability to ensure contractors properly and promptly perform work at the site. EPA may disapprove of the technical qualifications of the PRP’s contractor and require a replacement to perform the work. EPA holds the PRP responsible for all work products or activities performed by their contractor.
Q: What types of information and technical documents does EPA post on its website?
A: EPA typically posts major submittals from the PRPs such as final technical documents, final work plans, final sampling results, and certain correspondence within a reasonable amount of time to allow for Section 508 compliance, which mandates that all electronic and information technology used by the federal government be accessible to people with disabilities. EPA will continue to post major submittals to our website in order to keep the public informed about the status of the work at the site.