ACT NOW: Big River Lead Cleanup Proposal Comment Period Ends Sept. 27th!
Dear EPA Region 7:
We are concerned citizens urging the EPA to put forward an aggressive cleanup plan for the Big River Superfund site that:
- Protects public health, wildlife, and the Meramec River watershed from future contamination;
- Minimizes future costs to taxpayers; and
- Provides ample opportunities for public engagement throughout the process.
Protecting Public Health, Wildlife, and the Meramec River Watershed
We urge the EPA to adopt a clean-up target that is protective of Missourians and visitors who currently recreate and will continue to recreate on the Big River. The EPA’s own standard for lead in bare soil in play areas for children is 400 ppm (parts per million). On any given weekend in St. Francois State Park, there are children playing on the gravel bars and beach areas. There are numerous ways that children and other sensitive populations unknowingly increase their risk of lead poisoning by ingesting (directly or indirectly) or tracking lead into their homes.
Like the beach and gravel bar areas in St. Francois State Park, we are also concerned about recreational activities that occur in the numerous gravel bars up and down the Big River and how those areas (and the adults and children who recreate on them) will be protected moving forward.
The Big River is already one of a handful of water bodies in Missouri that have “Do Not Eat” fish advisories from the Missouri Department of Health and Senior Services due to their high levels of lead accumulation. We believe that the EPA should take an aggressive, long-term view of the lead contamination in this area and strive to stop further contamination downstream, and remove fish from the “Do Not Eat” advisory in the future. The 1200 ppm target is nowhere near aggressive enough to accomplish this goal.
Finally, we are very concerned about a weak remediation plan’s long-term impacts on other water bodies. The Lower Meramec River currently enjoys good water quality, provides outstanding recreational uses, and supplies drinking water to nearly 70,000 households. We are concerned that the proposed cleanup plan for Big River does not adequately address or acknowledge how the Meramec River and its watershed will be protected from future lead contamination.
Minimizing Future Costs to Taxpayers
We recognize that the EPA, under the Trump Administration, has made reducing the number of Superfund sites a major priority. The efforts to remediate lead contamination in the Big River have been painfully slow, and we urge the EPA to act quickly and efficiently. The Big River site presents an opportunity for the EPA to put forward a robust remediation plan, not just a series of “interim” solutions that further postpone cleanup.
We think it is important that the responsible, viable party is held accountable for remediation activities at this site, and we urge the EPA to minimize cleanup costs being passed on to American taxpayers.
We are concerned that adopting least-cost measures today may not only negatively impact public health, but also ultimately cost taxpayers in the future. We think it is important to have an aggressive cleanup plan for Big River at the outset, even if it means that the cost to the corporation responsible for the pollution is higher.
Providing Opportunities for Public Engagement
We understand that this is an “Early Interim Action” that will employ adaptive and iterative management techniques. Because there is no Community Advisory Group (CAG) for this site, we are concerned about how the EPA plans to consult and receive input from the public as these adaptive and iterative changes are made to the remediation plan. We encourage the EPA to implement a robust communication operation with the public, similar to its activities at the West Lake Landfill. At West Lake, this included the creation of a regularly-released update prepared by an EPA community engagement specialist. We are also interested to know more about how any changes in cost during this “Early Interim Action” will be addressed.
Thank you for the opportunity to present these comments.