Meeting Held 08/15/2016 Note: These are general notes and not meant to represent a verbatim transcript of all questions and comments at the meeting. There were approximately 80 people in attendance. MEETING AGENDA: 6:00
Welcome, Introductions, Ground Rules, and Agenda Review Introductions – Cindy Cook, Facilitator
6:05
Overview of the Dialogue Process – Cindy Cook, Facilitator
6:10
Partial and Full Excavation Alternatives – Terrie Boguski, Technical Assistance Services for Communities Program For additional details please see the slide presentation online: https://semspub.epa.gov/work/07/30302961.pdf
7:00
Discussion
7:30
Site Update – Mary Peterson, Superfund Director and Brad Vann, WLL Remedial Project Manager For additional details please see the slide presentation online: https://semspub.epa.gov/work/07/30302960.pdf
7:45
Discussion
COMMUNITY QUESTIONS Provided below is a list of questions and answers from the meeting. To ensure EPA could take as many questions as possible from the community, we answered some questions during the meeting and took notes on others so that we could answer them today. Question (State Senator Jill Schupp): When does the feasibility study occur? Answer – Terrie Boguski: EPA issued a ROD (Record of Decision) in 2008. There was a Feasibility Study in 2006 that led to a decision in 2008. Now they are circling back to review that and do a new Feasibility Study. Once EPA gets to the proposed final remedy they make any adjustments needed based on community concerns. Mary Peterson, EPA Region 7 Superfund Director, noted that feasibility of the various remedial alternatives is evaluated in the Feasibility Study; cost is one of the criteria in the National Contingency Plan (NCP) that is a factor in the feasibility analysis. Question: We keep doing these studies. At what point does someone say it’s time to do something because this isn’t a safe environment to live in?
Answer: EPA and the Potentially Responsible Parties or PRPs have completed all field work at the site necessary to evaluate and propose remedial alternatives. EPA is currently awaiting the submission of the Final Feasibility Study (FFS) from the PRPs. After receipt of the FFS, EPA will evaluate the alternatives and select a preferred alternative. EPA will then begin a public comment period during which the public will have the opportunity to review and comment on the preferred alternative. Question (Bridgeton City Councilwoman Linda Eaker): We need to know when the work is going to get done. Answer: EPA and the Potentially Responsible Parties have completed all field work EPA needs. We are currently awaiting the submission of the Final Feasibility Study from the PRPs. We will then evaluate the alternatives and select a preferred alternative. EPA then will begin a public comment period during which the public will have the opportunity to review and comment on the preferred alternative. Question (Missouri State Rep. Bill Otto): You talk about getting it right. And then you set a deadline. Why? Seems like you already know what the answer is. I’m concerned that EPA is being driven by a selfimposed deadline and not by the science. What makes you think you’re going to know in December what you don’t know now? Answer -- Mary Peterson: Thank you for the question. It’s a valid point. I loved what you said. You want to get it right. We want to get it right, too. We are all together on that. We will review the feasibility of all of the alternatives in the FFS. We want to get it right. It’s critical that we do a quality technical analysis. We want to do that with the community involvement, which is why were are here. Answer -- Terrie Boguski: I’ve worked at a lot of sites and sometimes the dates slip. I see a lot of flexibility in those dates. Question (Bill Otto): So the date could slip? Answer -- Mary Peterson: The quality of the decision is the most important thing, so we’ll take the time to get it right. Question (Dawn Chapman): The PRPs get to make a recommendation [in the Final Feasibility Study], what about the community? Can we propose a partial excavation as well? Answer -- Mary Peterson: The Remedial Investigation/Feasibility Study work plan defines partial excavation alternatives, and allows the PRPs the opportunity to propose new alternatives in the feasibility study, with EPA approval. During the public comment period the community will have the opportunity to review the proposed remedy. Of course, we’re also having these dialogues, working with the Community Advisory Group and others to create an ongoing conversation about the options. We want you to be aware of the options we’re evaluating. Question (Dawn Chapman): For example, what if we offered a level of thorium that we would prefer to have it remediated to that level? Answer: EPA is always listening to public concerns. If the public feels that there are remediation alternatives that EPA should consider, please submit those during the upcoming public comment period after EPA proposes a final remedy for the site.
Question: Will EPA consider Operable Unit 3 groundwater in the proposed final remedy that you’re going to release for OU1? Answer -- Mary Peterson: The groundwater Operable Unit (OU3) is on a separate track to ensure we can dedicate the time needed for the complexity of the issue. The remedy selection that we are working on now is limited to soils in Operable Unit 1. Question (Drew Kuhn): Couldn’t there be some intersectionality between those? I would think that groundwater should be considered more thoroughly now? Answer -- Brad Vann: With regards to remedy decision in Operable Unit 1, the remedies have to be compatible. You don’t want one making the other worse or one make another one incompatible. In OU1 options include full and partial removal. Question (Bill Otto): How do we determine the remedy if we don’t know where the [radiological] material is located? Answer -- Brad Vann: We have been investigating the extent of RIM and we’re evaluating all data now. We believe that will make the picture much clearer to so that we can make a remedy decision. Question (Doug Clemens): This problem has plagued St Charles North County for a lot of years. We’re seeing effects in second and third generations. It’s part of a US government weapons program. The radiological material will become more radioactive in the next 9,000 years. We’ve had this stuff air blown in 1984 toward the high school I was attending at the time. The NRC did thorough studies. I am very happy to see that with the new faces in EPA we now have much more data about the site. I’ll tell you that the people I represent do not want anything short of a full excavation. We also would like a voluntary buyout during remedy implementation. It’s very important to note that once a site is cleaned up the property values tend to bounce back up. We also want property value assurance. We ask for these simply because as a community we need these measures. This is not a place to keep this material; it has to move. Answer: The community has had to cope with a lot over the years. EPA is working hard to develop a final proposed remedy to keep radiological material away from people who live and work here. Generally speaking EPA offers permanent relocation when it’s needed to address an immediate risk to human health (where an engineering solution is not readily available) or where the structures (e.g., homes or businesses) are an impediment to implementing a protective cleanup. EPA’s preference is to address risks by using well-designed cleanup methods to allow people to remain safely in their homes. EPA relocates people temporarily as part of a response action for three primary reasons:
Health threats—The contamination may pose an unacceptable threat to human health, or implementation of the response action may pose an unacceptable health risk to residents (e.g., there could be an increased chance of exposure during sampling, bulking, and excavation). Physical safety of residents—The response action itself may pose an unacceptable risk to residents (e.g., use of heavy construction equipment too near a house could threaten the integrity of the structure or pose an attractive nuisance to children). Efficiency of the response action—The response action can be implemented more quickly and at a lower cost if residents are not in the area (e.g., work hours can be extended to include early morning and late evening hours when residents would normally be at home).
Question (Matt LaVanchy): Its 2016 today and at what point does the NRRB look at this decision that EPA will make. Will we be sitting in another room in 8 years? Answer: The National Remedy Review Board will review any proposed remedy prior to the finalization of a remedy at the site. Question (Dawn Chapman): You are asking for a bottom spanking if you come back with a partial option that doesn’t include the groundwater. Unless you’re going to fully excavate you better be ready to address all of these other issues. Answer: EPA is currently considering groundwater at the site as a part of Operable Unit 3. EPA will conduct a full Remedial Investigation and Feasibility Study to identify the nature and extent of any groundwater contamination related to the site. Question (State Senator Jill Schupp): Can EPA verify that the SSE won’t reach the radioactive waste before the remedy is in place? Answer (Brad Vann): We put an action in place in December to prevent that from happening. Heat Extraction System, Temperature Monitoring Probes, and the EVOH cover on the North Quarry. There’s a balance there. These are preventative measures, we are working to evaluate a physical barrier. Question (Bill Otto): I can’t believe you have the do nothing option up there. Why is the cap in place option up there? Answer: The 2008 ROD is part of the record until it is amended. The no action alternative is included because it is required by CERCLA. It does not mean the agency will not take action. Question (Harvey Ferdman): I think you’re hearing from the community that people don’t know what will be removed. To what level of radiation would the removal occur? How can you address that? I agree with everyone that it seems to defy logic that you would come up with a solution for the soil without taking the groundwater into effect. Maybe Dawn is right and we’re going to get a Christmas present. I think you should connect groundwater and not rush the science on the soils. If there’s a partial removal remedy for OU1 and you do the groundwater investigation you may have to go back and rework the remedy. And who would pay for that? Answer: EPA is currently considering groundwater at the site as a part of Operable Unit 3. EPA will conduct a full Remedial Investigation and Feasibility Study to identify to nature and extent of any groundwater contamination related to the site. Question (Dawn Chapman): Can you address that question about whether the alternative would have to be reworked? Answer -- Brad Vann: The simple answer is yes we may need to. This is the point from the National Remedy Review Board report. I spoke with the individual who made that statement. We want the aquifer characterized but fate and transport is only part of that characterization. That’s why I pushed for OU3, so EPA could fully characterize the groundwater out there. The remedies have to be complementary. We won’t surrender any of our tools to make sure the site remains protective and people are not exposed. The box I live in is the law that requires the protection of public health. Question (Dawn Chapman): What I heard you say is the deadline is not your idea?
Answer (Brad Vann): We have a ROD that we may need to modify. We’ve done the investigations now and we’re culling mountains of data. We want every piece of this report out, including the National Remedy Review Board comments that we’ve taken to heart. If you look at the work we did and lay it next to various reports you’ll see parallels. We want to get the timing right. I don’t want to be here 8 years later. We want a remedy that addresses human health exposure to all media at the site, and that Is science-based, and that the community and state can accept. I can’t promise full excavation. Some people can’t accept anything less than that. It has to be what I can do within the law and the box I live in. The first alternative looks at a concentration to get the worst things out without consequence to where it may be. It requires moving the most material since you have to move other material to get to the higher concentration areas. Another is to get to a maximum depth at a lower concentration. Remember we were charged with partial excavation. You have to look at activity level, exposure, building in risk over time. We had to look at volume, depth, etc. The last piece we had to look at whether there is a risk level based on current and future land use scenarios. FUSRAP has looked at some as have we. We need to consider all these criteria. Question (Dawn Chapman): If the timetable sticks and it’s in December, you won’t know that it’s a permanent solution with regards to the groundwater? Answer: The Remedial Investigation and Feasibility Study that EPA conducts for groundwater under Operable Unit 3 will inform the agency as to the nature and extent of any potential groundwater contamination related to the West Lake Landfill. Question: I think we owe it to future generations to take care of this now. Answer: EPA issued a Record of Decision for the site in 2008 that called for a “cap in place” remedy. EPA is currently reevaluating that remedy and plans to issue a new proposed remedy for public comment soon. EPA’s primary mission is to protect the public and environment from any potential harmful exposure now or in the future. Question (Bill Otto): Will you know what’s left in the ground? And if you do, will you tell us. Answer -- Brad Vann: That’s a good question, and it’s why we had the PRPs put so many holes in the ground. It isn’t a straight line. How much is left behind and with regard to if it’s touching groundwater. Question: Tell us what’s okay to leave in the ground that won’t hurt our children. Question (Asker Unknown): Follow up on Rep. Otto’s question. With partial excavation what stuff is left behind? Do you say go down a certain level and then put a cap in place. Answer -- Brad Vann: Yes, there would be some type of engineered cover or cap. Question (Matt LaVanchy): How does EPA determine that the level is 16 feet when we’ve seen studies that some of these hotspots are further in the ground than that? How did you determine 16 feet? Answer -- Brad Vann: The first one is the 1,000 or the hot spot option (excavating RIM over 1000 picocuries per gram regardless of depth). You will have to go down 80 feet in some places to accomplish that effort. The 16 feet and certain activity which goes back to the feasibility study you have to look at what’s feasible with most impacted volumes in mind. You have to look digging to a certain depth. Also the bulk of the RIM as we look at the data, was determined to be at 16 feet and above. Another piece is
there a different depth? That’s what we’ve told the parties they can do. If there is another depth that should be considered. Question (Byron DeLear): The 43,000 tons represents three huge caches. West Lake is the only remaining huge cache. New study shows elevated levels of lead 210 in the region. Has EPA made any official finding with regard to the lead 210 in the region? There have been representations by EPA that the material is contained. This represents a threat that could be miles offsite. Radon could travel miles away. I have a document here I was handed earlier on BMAC that says lead 210 is very high. It is increasingly dangerous to the children playing there. It is an ongoing present threat. Have you made an official finding on that? Answer: EPA performed a pre-CERCLIS screening of the Bridgeton Municipal Athletic Complex in 2014, with included more than 100 soil samples. The results of that screening demonstrate that the BMAC remains suitable for use by the public. Question (Ed Smith): USGS did a groundwater report that they thought was related to the Radiologically Impacted Material (RIM). How can you separate that into a separate operable unit? Please address that in the Record of Decision. One thing we’ve been doing is evaluating rad sites around the country. In Colorado site it cost the taxpayers to pay for the site remediation after a cap in place option did not work five years later. A second site: the government tests landfills as a grid for radioactivity. I’ll present you with a flash drive with documents about these sites. I hope that in the Feasibility Study it’s the EPA that is looking at case studies like Shattuck landfill. They chose to look at groundwater as a complete pathway. To assume there is no groundwater pathway is simply unreasonable, given the long human civilization expected along these two major rivers. I hope you look at these sites and work plans. What they used for structures of dust mitigation, etc. Answer: EPA acknowledges the request made by Mr. Smith. EPA is currently considering groundwater at the site as a part of Operable Unit 3. As a part of that, EPA will conduct a full Remedial Investigation and Feasibility Study to identify the nature and extent of any groundwater contamination related to the site. These studies will include evaluating potential exposure pathways. Question (Gale Thackrey, Franciscan Sisters of Mary): We support full excavation. Superfund sites take priority over airport legal agreements. There are proven technologies used in Stockton, Calif. Worth reviewing it. Studies reported here whether the landfill control measures are working. Huge reduction from 3,000 gulls in March 2010 when it began. [Did not say what the reduction amounted to, would be good to know the results.] The study reported that continued complete effectiveness of the control techniques that are well established. This would ensure no bird hazard issues. We believe bird control should be removed from consideration. Answer: EPA acknowledges the comment made by Ms. Thackrey. During any excavation at the site, EPA will ensure that appropriate technologies are in place to mitigate the risk of bird strikes to airplanes taking off and landing at St. Louis Lambert International Airport. Question (Jerry Grimmer): I’m deeply troubled you wouldn’t consider groundwater. Weldon Springs has a large leachate control system.
Answer: EPA is currently considering groundwater at the site as a part of Operable Unit 3. EPA will conduct a full Remedial Investigation and Feasibility Study to identify the nature and extent of any groundwater contamination related to the site. Question (Karen Nickel): All we want is a safe and permanent solution. What I’m hearing is that there is no permanent solution to protect our children except for full excavation. How can we live this way? Our kids are dying, have bloody noses. When will there be action? If there won’t be action we want this moved to USACE. Answer: EPA’s focus is protecting human health and the environment. EPA issued a Record of Decision for the site in 2008 that called for a “cap in place” remedy. EPA is currently reevaluating that remedy and plans to issue a new proposed remedy for public comment in the near future. Question (Syd Hajicek): Studies: Dr. Criss and ATSDR. ‘West Lake Landfill has no engineering barriers, leachate protection system, etc. It is a chaotic pile of debris surrounded by rad signed fences.” 2 nd study “landfill is overlying water with no protection. The groundwater flow rate was estimated to be 1.2 feet per year during low flow and much higher during high flow periods. Estimated to reach the river in 57 years at highest flow rate.” Answer: EPA acknowledges the comment made by Mr. Hajicek. EPA is currently studying groundwater at the site as a part of Operable Unit 3. We will conduct a full Remedial Investigation and Feasibility Study to identify the nature and extent of any groundwater contamination related to the site. Question (Kay Drey): I have the National Remedy Review Board report that I’ve been asking for it for years. The NRRB said these materials should not be left in the landfill. The reason I believe you withheld it is that NRRB recommend EPA Region 7 should develop an alternative that surgically removes the RIM that appears to be discrete that will continue to become increasingly radioactive over the years. It clearly says these materials must be removed from the landfill. Answer: EPA acknowledges the comment made by Ms. Drey. EPA released the NRRB report after negotiating legal agreements with the PRPs to address items that required further study or actions. Question (Sen. Schupp): You said you wanted to know what we think what needs to be done. Everyone who supports full excavation, please raise your hands. Majority raised hands. How many of you support partial excavation? No hands were raised. Answer: EPA acknowledges Sen. Schupp’s comment regarding full excavation and the response given by those in the room. The public will also have a formal opportunity to comment on the proposed remedy for the site during the public comment period. Question (Asker unknown): I don’t want to sound rude. I don’t live here. You have to look where the money is. You are plainly guaranteeing yourself a paycheck, retirement, etc. This is the only thing you are doing. It’s obviously never going to be safe unless you completely remove it. There will always be new studies. The only thing it has proved to me is that you’re looking for a paycheck. Look inside of yourself and think about what you did. You may need a mental institution. You are the only ones who can handle this.
Answer: EPA’s sole focus at the site is protecting human health and the environment. We are working diligently towards proposing a final remedy at the site that we will present to the community for public review and comment. Question (Debbie Disser): The reason I’m against partial excavation is that you cannot guarantee there will never be a landfill fire. Answer: Subsurface Smoldering Events (SSE’s) are not uncommon in landfills. While we cannot guarantee that an SSE would never occur in the West Lake Landfill after the remediation, we believe that the likelihood of a new SSE starting is low due to the age of the waste and other factors. Question: When you guys talk about a feasible investigation we only get one planet. No amount of money. We spend who knows how much money is spent on wars every year. Feasibilities is a bunch of paper. F*** paper. Seriously. We only get one planet to live on. Answer: EPA acknowledges the comment. Question (Ed Smith): We’ve seen institutional controls fail. We’ve seen others move RIM with bulldozers like the Ford property. It behooves the EPA to consider groundwater as a complete pathway. If there is a decision to leave RIM at the landfill, EPA needs to consider surface fire, etc. And how they plan to respond to fire itself or support the local fire department for 9,000 or more years. Answer: EPA is currently considering groundwater at the site as a part of Operable Unit 3. EPA will conduct a full Remedial Investigation and Feasibility Study to identify to nature and extent of any groundwater contamination related to the site. In 2015, EPA ordered the Potentially Responsible Parties at the site to conduct a Removal Action to reduce the threat of surface fires at the West Lake Landfill. Vegetation was cut and matted in place and at least eight inches of crushed rock placed in areas where RIM has been identified to be at or near the surface. Question: I want to know about evacuations. Answer: St. Louis County has an emergency operations plan for the West Lake Landfill which can be found online: https://www.stlouisco.com/Portals/8/docs/document %20library/police/oem/lepc/WestLake%20Plan%20-%20FULL.pdf Question: How close is the Subsurface Smoldering Event to the Radiologically Impacted Material? Answer: The southernmost Radiologically Impacted Material (RIM) in the West Lake Landfill is approximately 700 feet from the nearest Temperature Monitoring Probe in the “neck area” of the Bridgeton Landfill. This TMP has never exhibited temperatures consistent with those found in a Subsurface Smoldering Event (SSE). Question (Ed Smith): As these documents become final will they be published immediately? Answer -- Brad Vann: We will publish final documents when available. Question (Harvey Ferdman): Thank you for removing the brush, extending the cover over the north quarry. Thank you for all of these actions. Too bad it took the federal government to step in to make this happen. I want to reinforce something that Ed said earlier I’m not sure everyone caught. Regarding EMSI, and Paul Rosasco. Ed said we would like to see you not accept them as contractor anymore. They
were integral to the cap in place design. Paul Rosasco insisted that when they studied the RIM they discovered all of it. The pink blob in the middle is now literally twice the size of what he said was the study of all studies. I think it’s a mistake to continue to use him. In case you don’t understand, DOE is a PRP. That’s our tax money going to pay that contractor. Answer: EPA acknowledges Mr. Ferdman’s comment regarding EMSI. EMSI remains the contractor at the site and EPA does not anticipate that a new contractor will be used. Question (Byron DeLear): How do we know there isn’t any radioactive material that has migrated to the neck? Answer--Brad Vann: The sampling we’ve done in Phase 1 shows where it is. Question (Byron DeLear): We need a comprehensive site characterization. Answer: The Phase I investigation has characterized the extent of the Radiologically Impacted Material (RIM) contained in the West Lake Landfill. Question (Bill Otto): Prove to me it isn’t there. Answer: The Phase I investigation has characterized the extent of the Radiologically Impacted Material (RIM) contained in the West Lake Landfill. Question: Can you swear on a bible that we aren’t being exposed? Answer -- Brad Vann: I can tell you that all data I’ve seen indicates that you are not being exposed. The investigations we’ve had the parties do show that it isn’t there. Question: You haven’t tested in the other areas of the landfill. Answer -- Brad Vann: The historical aerial photos show there wasn’t dumping occurring there at that time. Our offsite air monitoring have continued to show no detection of radionuclides. Question: Why haven’t you tested the entire site? Answer -- Brad Vann: We’ve done a full area 1 testing and are confident the extent of RIM has been fully delineated. Question (Byron DeLear): There were representations made that the RIM was contained at the site. That’s why we’ve said repeatedly we need you to do a full grid of north quarry, etc. Answer -- Brad Vann: We are doing additional studies as we do work at the north quarry. We’ll keep looking for ways to continue gathering information to address community concerns. The other evaluations haven’t stopped; however, at some point we have to make a decision at the site. Question (Dawn Chapman): We’ve discussed the aerial photos. I still encourage you to do the grid. If nothing else for the peace of mind. Have you considered if there were additional dumping of RIM? Have you noticed that surface RIM is high in uranium? There’re very unusual high rad levels at the surface. Why? If you look at the boring samples there’s some at the surface and then 20-30 feet down there’s thorium.
Answer -- Brad Vann: We’re looking at that data. The Cotter Corp has taken samples and we’ll evaluate them once they’ve sent them to us. It’s a good comment and we’re certainly evaluating this issue. Question (Dawn Chapman): Cotter is insistent there are other PRPs at the site. If so, that really opens up the door to the possibility that there’s material in other areas of the landfill. Answer: The data collected to date at the site, including the recently completed Phase I investigation, has characterized the nature of the Radiologically Impacted Material (RIM) at the site. EPA has not seen any indication of any previously-unknown radiological contaminants at the site. Question (Debbie Disser): Are you getting split samples from the HES system installed? Answer -- Brad Vann: The recently completed Phase I investigation in Area 1, OU1 has not demonstrated a need for further RIM characterization, which is why EPA did not continue that sampling effort or require it as part of the Bridgeton North Quarry order. Based on community concerns, EPA has requested that the responsible parties screen IDW and drilling equipment for gamma as a part of the TMP installation process. The approved drilling method, sonic drilling, selected to install the Temperature Monitoring Probes (TMPs) also may not yield sufficient material, as the procedure for TMP installation is designed specifically for ensuring the timely installation of the various engineering controls. Question (Kay Drey): The USACE has been cleaning up rad sites since 1997. We all know the RIM must be removed from the Missouri river flood plain. We’ve done enough discussion and debating. I hope we can turn this cleanup over to the USACE. Answer: EPA acknowledges Ms. Drey’s opinion that the United States Army Corps of Engineers should be the lead agency at the site. Under Federal law, EPA remains the lead agency for the remediation of the West Lake Landfill and remains committed to proposing a final remedy for public comment.