West Lake Documents & Reports
The volume of documents and information related to the West Lake Landfill is large. MCE breaks it down for you below.
Read the latest
September 2018: Missouri Department of Health and Senior Services (DHSS) released a Health Consultation regarding risk to public health from the odor emissions generated by the ongoing smoldering landfill fire that started in 2010. DHSS is accepting comments on the report through November 20, 2018.
February 2018: EPA announces its proposed remedy of partial removal of up to 67% of the known areas of radioactive contamination.
August 2017: MCE submitted comment letters responding to a Department of Natural Resources public comment period for a draft stormwater pollution permit at Bridgeton Landfill. The National Pollution Elimination Discharge System (NPDES) permit is enforced under the Clean Water Act by regulating what’s known as point source pollution, mostly from industry or municipal waste systems that discharge directly to surface water. You can find MCE’s letters to the DNR here and here.
June 20, 2016: EPA Region 7 released the powerpoint that they presented to the National Remedy Review Board (NRRB) on February 29, 2012. MCE submitted a Freedom of Information Act (FOIA) request on June 17, 2016, requesting the powerpoint and other documents related to the NRRB document released on June 15, 2016. The other documents have not yet been released. MCE appreciates EPA Region 7’s prompt response in releasing the powerpoint.
June 15, 2016: EPA Region 7 released a document to them on February 28, 2013 by the National Remedy Review Board (NRRB), an internal group of experts at the EPA that reviews Superfund cleanup decisions. The NRRB document reviewed the decision in 2008 by Region 7 to cap-and-leave the radioactive wastes. The NRRB review suggests that at least some of the radioactive waste in the landfill could be removed safely with existing methods that are in use at other federal sites around the country. The document also suggests that the EPA underestimated maintenance costs for the cap remedy that they proposed in their 2008 ROD. In 2014, MCE submitted a Freedom of Information Act (FOIA) request to the EPA for this specific document, but was denied the request. The EPA Region 7 rationale for releasing the document ignores MCE’s previous requests through FOIA and in person over the few years.
June 6, 2016: On June 2, the U.S. Army Corps of Engineers responded to the letter sent by the U.S. House Committee on Energy and Commerce. The letter was made available to MCE on June 6. The letter addresses the Committee’s question regarding whether transfer of the West Lake Landfill to the Formerly Utilized Sites Remedial Action Program (FUSRAP) will expedite the cleanup of the landfill as well as questions regarding the Corps of Engineers remediation process. The U.S. Army Corps of Engineers believes that transfer of the West Lake Landfill “would not accelerate remediation.” However, the Corps of Engineers has much more experience with radioactive waste the the EPA. HR4100, which transfers jurisdiction of the West Lake Landfill from the EPA to the Corps of Engineers, needs to pass.
May 17, 2016: The U.S. House Committee on Energy and Commerce sent a letter with questions to the U.S. Army Corps of Engineers regarding pending legislation that would transfer jurisdiction at the West Lake Landfill to the Formerly Utilized Sites Remedial Action Program (FUSRAP). The letter recognizes the Congressional Budget Office determined there would be no financial impact on the Corps of Engineers if the legislation became law. The letter doesn’t recognize that West Lake should have always been a FUSRAP site and the legislation is an attempt to fix the federal government’s failure to list the site properly in 1990. Even more, the Corps of Engineers has a successful track record for remediation of radioactive sites in metro St. Louis whereas the EPA has had trouble managing its only radioactive site, West Lake Landfill, since 1990 when it was put in charge.
October 24, 2015: A grass fire ignited at the West Lake Landfill that was quickly extinguished by fire fighters. The EPA says the fire did not come in contact with the known areas of radioactive material at the surface of the landfill and that fire mitigation efforts will be further reviewed and implemented.
October 23, 2015: The West Lake Landfill Community Advisory Group technical committee submitted questions and concerns to the Environmental Protection Agency and Agency for Toxic Substances and Disease Registry regarding the release of the health consultation on October 16th.
October 16, 2015: The Agency for Toxic Substances and Disease Registry published a health consultation regarding the radioactive materials at the West Lake Landfill. The State of Missouri is working on a health assessment regarding the remaining contaminants at the landfill.
October 5, 2015: KMOX broke a story that includes the St. Louis County emergency shelter in place and evacuation plan for the West Lake Landfill. St. Louis County also released an emergency shelter in place and evacuation pamphlet for the West Lake Landfill a few days earlier.
September 10, 2015: The Department of Energy sent a short response to the Congressional Delegation denying their request for the DOE to consider designating the West Lake Landfill under the Formerly Utilized Sites Remedial Action Program. The DOE also failed to respond to many of the inquiries made by the Congressional Delegation.
August 26, 2017: St. Louis County Executive Steve Stenger signed a letter to the Environmental Protection Agency Region 7 concerning the smoldering fire and radioactive materials at the West Lake Landfill. Executive Stenger asks the EPA if it has a contingency plan should the proposed isolation barrier not be implemented if the smoldering fire continues to advance toward the radioactive materials and more. Read the full letter HERE.
July 17, 2015: Missouri Senators Claire McCaskill and Roy Blunt as well as Representatives Lacy Clay and Ann Wagner signed a letter to the Department of Energy raising new concerns about radioactive material at the West Lake Landfill. The delegation also asked the DOE to consider placing the landfill as a Formerly Utilized Sites Remedial Action Program cleanup site.
May 11, 2015: The financially responsible parties begin another round of radioactive testing to better identify the extent of contamination in order to build a proposed isolation barrier meant to separate the ongoing smoldering fire from the illegally dumped radioactive wastes. The EPA approved testing plan can be found here.
January 7, 2015: Attorney General Koster filed a temporary restraining order against Republic Services in order to acquire data due to concern the smoldering landfill fire in the south quarry is moving into the north quarry, closer to the illegally dumped radioactive wastes. Read a great summary of the details from St. Louis Pulbic Radio. Testimony from DNR landfill experts Todd Thalhamer and Dr. Timothy Stark.
August 29, 2014: Memo to the MO DNR from its landfill fire consultant, Todd Thalhamer. The memo details concerns about the smoldering fire turning into a surface fire.
Sign-On Letters from Missouri Congressional Delegation
July 17, 2014: Congressional delegation letter from Senator Blunt, Senator McCaskill, Congressman Clay, and Congresswoman Wagner to EPA Region 7.
January 28, 2014: Senator Blunt, Senator McCaskill, Congresswoman Wagner, and Congressman Clay send a letter to EPA Region 7 calling for the utilization of the St. Louis Army Corps of Engineers Formerly Utlized Sites Remedial Action Program (FUSRAP).
Correspondence between MCE and EPA Region 7
July 18, 2014: EPA Region 7 response to MCE’s clarifying questions from the EPA Region 7 June 16 response.
June 16, 2014: EPA Region 7 response to MCE questions.
June 10, 2014: MCE submits comments on the Preconstruction Work Plan for the proposed isolation barrier to EPA Region 7.
April 29, 2014: EPA response to MCE and community concerns regarding a contractor hired by the financially responsible parties at West Lake Landfill.
March 13, 2014: MCE letter to EPA Region 7 regarding a contractor hired by the financially responsible parties at West Lake.
March 5, 2014: EPA Region 7 response to MCE questions.
October 29, 2013: EPA Region 7 response to MCE questions.
August 23, 2013: EPA Region 7 response to MCE questions submitted in July and August. MCE questions are included in the EPA Region 7 responses.
July 26, 2013: EPA Region 7 response to MCE questions submitted in May and June.
Correspondence between the Center for Health, Environment and Justice and EPA Region 7
October 29, 2015: Lois Gibbs of the Center for Health, Environment and Justice sent a letter to the EPA with the help of Just Moms STL requesting a voluntary buyout for the people immediately around the smoldering and radioactive West Lake Landfill.
November 14, 2015: EPA Region 7 Administrator Brooks responded and denied the request to relocate people near the landfill. The EPA has relocated people at 33 of its more than 1,600 Superfund sites.
Independent Reviews of the West Lake Landfill Radioactive Wastes
March 14, 2013: Risk and Character of Radioactive Waste at the West Lake Landfill, Bridgeton, Missouri by Dr. Robert Criss, professor in the Department of Earth and Planetary Sciences at Washington University in St. Louis.
November 21, 2013: The West Lake Landfill: A Radioactive Legacy of the Nuclear Arms Race by Robert Alvarez, senior scholar at the Institute for Policy Studies.
Nuclear Regulatory Commission (NRC) West Lake Landfill Documents
1982: NRC Radiological Survey of the West Lake Landfill.
1988: NRC Summary Report of the radioactive material at the West Lake Landfill.
1995: NRC press release deferring regulatory authority to EPA Region 7 Superfund.
Technical Assistance Services for Communities (TASC) Fact Sheets
February 2014: Fact Sheet #1 contains site information and basic information about the Superfund process and radioactivity.
March 2014: Fact Sheet #2 contains information about the geology of the site and a summary of groundwater monitoring data.
May 2014: Fact Sheet #3 contains a summary of the information provided in the 2011 Supplemental Feasibilty Study Report.
June 2014: Fact Sheet #4 contains a summary of air monitoring data.
September 2014: Fact Sheet #5 contains information on regulatory limits for human exposure to low level radionuclides.
June 20, 2014: Summary of the Work Plan for Removal Action Preconstruction Work
April 2015: TASC Summary – December 2014 Groundwater Report Conclusions
June 2015: TASC Summary – Landfill Leachate at Bridgeton Landfill
May 2016: Baseline Human Health Risk Assessment (BHHRA)
Understanding Units of Measurement
EPA Region 7 post-2008 Record of Decision Documents
Fire was never considered a risk (see Oct. 2013 EPA response to MCE Question #1) to the radioactive wastes in the EPA’s 2008 Record of Decision. Therefore, EPA Region 7 required the financially responsible parties to prepare a report on what would happen if a smoldering fire were to contact the radioactive wastes if the 2008 Record of Decision were implemented. The financially responsible parties found no environmental or health impact to surrounding areas if a smoldering fire reached the radioactive wastes. The EPA Office of Research and Development, Missouri Department of Health and Senior Services, and Missouri Department of Natural Resources independent landfill fire expert, Todd Thalhamer, all disagree with the financially responsible parties’ conclusion.
January 2014: Fire and radioactive risk report submitted by the financially responsible parties to EPA Region 7.
February 2014: Missouri Department of Natural Resources independent landfill fire expert’s review of the financially responsible parties’ report.
March 2014: EPA Office of Research and Development’s review of the financially responsible parties’ report.
April 2014: Missouri Department of Health and Human Services’ review of the financially responsible parties’ report.
Groundwater Monitoring: Groundwater monitoring reports show more total wells above the Maximum Contaminant Level (MCL) for Radium and higher radioactivity of Radium in the groundwater than before the 2008 Record of Decision.
- October 2013 groundwater sampling report submitted to EPA Region 7 by the financially responsible parties.
- July 2013 groundwater sampling report submitted to EPA Region 7 by the financially responsible parties.
- April 2013 groundwater sampling report submitted to EPA Region 7 by the financially responsible parties.
- Draft summary of Radium results.
- August 2012 groundwater sampling report submitted to EPA Region 7 by the financially responsible parties.
Sept. 2013: Answers to questions submitted on EPA Region 7’s online portal.
May 2013: Radiological and Infrared Survey of the West Lake Landfill conducted by EPA Region 7.
2011: Supplemental Feasibility Study submitted to EPA Region 7 by the financially responsible parties.
2011: EPA Region 7 updated the Community Involvement Plan.
2010: Supplemental Feasibility Study Work Plan submitted to EPA Region 7 by the financially responsible parties.
EPA Region 7 Documents related to the 2008 Record of Decision
2008: EPA Region 7 Record of Decision calls for the radioactive wastes to be permanently buried at the West Lake Landfill. The 2008 Record of Deicision also includes a Responsiveness Summary, where EPA Region 7 responds to concerns raised by MCE and other concerned citizens.
2006: Feasibility Study submitted by the financially responsible parties to EPA Region 7.
2000: Remedial Investigation Report submitted by the financially responsible parties to EPA Region 7.
- Remedial Investigation Tables
- Appendix A: Baseline Risk Assessment
- Appendix B: Radiological and Non-Radiological Analytical Results for Soil Samples
- Appendix C: Radiological and Non-Radiological Analytical Results for Groundwater Samples
- Appendix D: Radiological and Non-Radiological Analytical Results for Surface Water Samples
- Appendix E: Radiological and Non-Radiological Analytical Results for Sediment Samples
1990: The Department of Energy excluded West Lake Landfill from FUSRAP designation, which allowed the landfill to be listed on the Federal Register as an EPA Superfund site. West Lake Landfill was listed near the bottom of the National Priorities List, ranked #1003. Even though the West Lake Landfill contains the exact same radioactive wastes as the Hazelwood Interim Storage Site (HISS), the location where the West Lake radioactive wastes came from, the DOE unfortunately decided in its Federal Facilities Agreement that West Lake Landfill does not qualify as a FUSRAP site.
EPA Isolation Barrier Documents
Attorney General Koster filed a lawsuit against Republic Services in 2013 for breaking Missouri’s environmental laws due to the smoldering landfill fire. The summer of 2013 was filled with negotiations between Republic Services and the State of Missouri regarding contingencies if the smoldering fire were to start moving towards the radioactive wastes. In the fall of 2013, Attorney General Koster, EPA Region 7, and Republic Services decided to stop negotiating and implement the contingency plans that were being discussed, including the placement of an impermeable cap in the North Quarry and the creation of an “isolation barrier” between the smoldering fire and identified areas of radioactive wastes.
Sept. 2013: EPA Region 7 agrees to oversee the creation of an isolation barrier. EPA Region 7 has stated several times at public meetings that radioactive material will not be impacted during the creation of the isolation barrier. In order to meet this goal, Republic Services must identify a “clean line” where radioactive wastes are not present. The Gamma Cone Penetration Test (GCPT) was conducted as a qualitative first step in identifying a line free of nuclear weapons radioactive wastes. The GCPT Health and Safety Plan and Work Plan are located on EPA Region 7’s website.
Dec. 2013: Republic Services’ next step in identifying a “clean line” for the isolation barrier was to conduct core sampling. Results from the GCPT can be found on Drawing Number 2 in the West Lake Core Sampling Health and Safety Plan, submitted by Republic Services to EPA Region 7. The GCPT found areas of previously unidentified radioactive materials at the West Lake Landfill.
Jan. 2013: Republic Services submits Core Sampling Work Plan Revision 1 to EPA Region 7.
AEC, DOE, and EPA Shenanigans
- June 10, 1960: AEC to Cotter Corporation. Request for proposals for the purchase and removal of uranium contaminated residues.
- December 6, 1972: Cotter Corporation to AEC. Proposal for decontamination of Latty Avenue Storage Site, Hazelwood, Missouri.
- October 5, 1981: Radiation Management Corporation. Report on West Lake Landfill site visit.
- May 12, 1992: DOE to EPA Region 7. Letter regarding Department of Energy’s assertion of no liability at West Lake Landfill.
- May 15, 1992: DOE. Informal note regarding Apollo and West Lake Landfill Issues.
- May 15, 1995: DOE to Kay Drey. Letter regarding West Lake Landfill FUSRAP decision.
- June 13, 2000: MDNR to EPA Region 7. Letter regarding lack of removal options in draft of Feasibility Study.
- June 25, 2000: EPA Region 7 to MNDR. Response to letter regarding lack of removal options in draft of Feasibility Study.
- September 8, 2000: EMSI. Technical Memorandum: Evaluation of Potential “Hot Spot”: Occurrences and Removal for Radiologically Impacted Soil West Lake Landfill Operable Unit 1, Bridgeton, Missouri.
- May 17, 2002. EPA Region 7 to MDNR/MDNR to EPA Region 7. Email regarding hot spots at West Lake Landfill.
An Open Letter to Administrator McCarthy of the EPA
- March 24, 2016. EPA Region 7. West Lake Update.
- June 15, 2016. EPA Region 7. West Lake Update.
MCE Keeps Government Accountable at the West Lake Landfill
- May 2008. EPA Region 7. Record of Decision.
- June 15, 2016. EPA Region 7. West Lake Update.
- May 14, 2014. EPA Region 7. Response to FOIA Request.
- EPA Region 7. Presentation to NRRB.
Republic Services Reports “Complete Effectiveness” of Bird Control at California Landfill
- December 30, 2013. LGL Limited. Demonstration of the Continued Effectiveness of the Bird Control Program at the Forward Landfill.
- June 15, 2016. EPA Region 7. West Lake Update.
Extensive Testing for RIM is Needed at the West Lake Landfill
- March 24, 2016. EMSI. Map of Extent of Radiologically Impacted Material in Area 1.
- May 26, 2016. EPA Region 7. West Lake Update.
- August 25, 2014. US Army Corps of Engineers. Isolation Barrier Alignment Alternatives Assessment.
Analyzing Clean-Up at the Shpack Landfill
- August 2005. Conti Environment and Infrastructure, Inc. Remedial Action Work Plan.
- July 2005. Conti Environment and Infrastructure, Inc. Site Safety and Health Plan.
STL County Health Survey Releases Troubling Findings
- June 2016. STL County Dept of Public Health. Community Respiratory Health Survey.
- September 1995. Agency for Toxic Substances and Disease Registry. Report of the Expert Panel Workshop on the Psychological Responses to Hazardous Substances.