Comment Period for West Lake Landfill Ends April 9

The EPA has taken the unusual step to re-open the Public Comment period for its West Lake Landfill Superfund Site & "Proposed Plan." Comments will be accepted from March 27th through April 9th.

This Public Comment period is our last opportunity to affect a change in EPA's Proposed Plan to leave the waste at West Lake.

In 1973, thousands of cubic yards of highly radioactive waste were illegally dumped in the 200-acre landfill. Located in the Missouri River floodplain, West Lake sits 8.5 miles upstream from public drinking water intake pipes.

Missouri American Water Company's North County water plant (in Florissant) provides drinking water from the Missouri River for people who live or work north of I-70. Additional intake pipes farther downstream supply water to the City of St. Louis. Removing the radioactive waste from the landfill will prevent contaminated water from the West Lake Landfill from getting access to your kitchen sink.

The radioactive waste was illegally dumped. No liner exists beneath the site to protect the radioactive material from leaching into the groundwater. Through years of exposure to threats of high river water and heavy rains, resulting in highly-saturated soils, radioactive wastes have been already migrating into the groundwater which flows to the Missouri River.

In 2006, the EPA released its proposed plan to place a cap made of rocks, clay and construction rubble on top of the radioactive waste. The plan was met with public outrage; more than 100 comments were submitted to the EPA. Many comments voiced alarm concerning the potential of flooding.

Professor Robert E. Criss, a geochemist at Washington University, commented that, "Levees fail. Several levees in St. Louis County have failed in the last fifteen years. These risks are chronically underestimated." He explained that the flow rate of the Missouri River near West Lake Landfill is about 70,000 cubic feet per second. When asked how long it might take for the landfill's radioactive contaminants to reach the North County water plant, in the event of a levee failure, Dr. Criss estimated, "About a day. The wastes would be everywhere."

The predominant isotope of concern is thorium-230. It has a half-life of 75,000 years. Other isotopes include uranium-238, with a half-life of four-and-a-half billion years. Polonium-210 is also present at West Lake.

Though safe cleanup may be costly, it can be done. Modern methods for removing dangerous wastes include "dust suppression tents" that employ negative pressure and filters. Placed above a hazardous site during excavation and cleanup, they prevent the release of radioactive waste particles into the air. (Nothing has been containing West Lake's airborne radioactive particles for the past three decades.) The cleanup of all the other sites in St. Louis that contain similar wastes (from nuclear weapons production in the 1940's and '50's) has either been completed or the sites are currently being excavated by the US Army Corps of Engineers. The wastes are being transported to federally licensed radioactive waste disposal facilities --- away from water and away from people.

It is essential that Congress mandate that the Corps take charge of removing the radioactive waste from West Lake Landfill before the Corps' trained and experienced contractors leave St. Louis. That means NOW.

PLEASE send written comments to the EPA. Please urge your neighbors and elected officials to send in comments. Comments may be submitted in writing or electronically through April 9th. Send written or electronic comments to:

Debbie Kring
Community Involvement Coordinator
U.S. EPA - Region 7
901 North 5th Street
Kansas City, KS 66101
kring.debbie@epa.gov
Toll-free: 800-223-0425

Please ask our senators to take a stand:

Senator "Kit" Bond
St. Louis Office
7700 Bonhomme, #615
St. Louis, MO 63105
(314) 725-4484

Senator Claire McCaskill
St. Louis
5850 A Delmar Blvd
St. Louis, MO 63112
(314) 367-1364

For further information contact: visit our website at www.moenviron.org or call Missouri Coalition for the Environment, 314-727-0600.

Radioactive Waste in Earth City Floodplain

Please join with us in asking the EPA to remove the radioactive wastes that were dumped at the West Lake Landfill (Bridgeton Landfill) in 1973. These long-lived, dangerous materials (including Uranium, Thorium and daughter products such as radioactive lead and radium) should be transported to a federally licensed site away from water. West Lake is upstream from city and county drinking water intakes along the Missouri and Mississippi rivers.

In June 2006, the EPA unveiled its Proposed Plan for addressing the West Lake Landfill Superfund site. The EPA is proposing to leave the wastes where they are in the floodplain, described as Alternative 4 in the Proposed Plan. The agency is accepting public comment on its Plan and may modify its Preferred Alternative based on new information and public comment.

The Background

A 1988 U.S. Nuclear Regulatory Commission (NRC) Report describes the site's history. The contaminated material is processing waste left over from St. Louis' role in developing the atomic bomb. From 1942 to 1957, Mallinckrodt Chemical Works in St. Louis processed uranium for the U.S. Atomic Energy Commission (AEC). In addition to North American ores, in 1944 the plant began processing rich uranium ores from the Belgian Congo, which brought to this continent uranium of a purity unmatched by North American ores. The process resulted in some of the uranium and its radioactive daughter products remaining behind in the process tailings, called "raffinate".

Beginning in 1946, the AEC "stored" processing wastes from the project at a site they had acquired in north St. Louis County that is now known as the St. Louis Airport Site (SLAPS). In 1966, the AEC sold the process tailings for its high uranium content to the Continental Mining and Milling Company of Chicago. In 1966, Continental moved the material to a site on 9200 Latty Ave. in Hazelwood. Around 1967, the Commercial Discount Corporation of Chicago took possession of the material. The Cotter Corporation later began a process to remove moisture from it in order to reduce shipping costs, and then in 1969 began shipping some of the residues to the Cotter Corporation in Canon City, Colorado. The AEC's bid invitation listed 74,000 tons of Belgian Congo raffinate containing about 113 tons of uranium; 32,500 tons of Colorado raffinate containing about 48 tons of uranium; and 8,700 tons of leached barium sulfate containing about 7 tons of uranium. Much of the waste was left at Latty Avenue and the Airport Site. The 8,700 tons of radioactive leached barium sulfate was left at Latty Ave. In 1973, it was mixed with soil and other radioactive wastes, and transported to what is called the West Lake Landfill. An NRC investigation in 1976 revealed that 43,000 tons of material was moved from Latty Avenue and dumped at the West Lake Landfill. West Lake Landfill is adjacent to Earth City and St. Charles Rock Road, in the alluvial floodplain of the Missouri River.

Part of the landfill was a quarry until it became a municipal waste landfill. Records show that West Lake Landfill Inc. was incorporated in 1962. The property has since changed hands numerous times. The Missouri DNR closed the landfill in 1974 and permitted a new landfill to open next to the site.

Subsequent investigations at the site have identified two areas where radioactive materials were dumped. One of these areas, known as Area 2, is the closest to Earth City and has already experienced erosion that has resulted in contamination washing off-site to adjacent properties. For those familiar with Earth City, you already know that it is in a flood plain. Even in drought, water fills the ditches. The 1988 report notes that "the water table is generally within 10 feet of the ground surface but at some points is even shallower."

Flood Risk

One obvious concern is whether the Earth City levee will hold in the course of the millennia that the waste will remain radioactive. A 2008 letter from the Missouri Department of Natural Resources (MDNR) states that the floodwaters would have been at the toe of the landfill in Area 2 if the Earth City levee had failed in the 1993 floods. The risk of levee failure and flooding is increased by the newer, higher levees at St. Peters and Chesterfield. A flood similar to 1993 would put increased pressure on the Earth City levee -- and a breach would spread the radioactive waste. The EPA and the MDNR have chosen to ignore these increased risks.

Groundwater Risks

Another concern is whether the radioactive materials will be continue to be transported in the groundwater that moves under and through the site to the Missouri River. The West Lake landfill was in no way prepared to be a container for radioactive waste. The 1988 investigation found that the radioactive materials in Area 2 are in a layer 2-15 feet thick. They are spread over landfill debris, floodplain top soil, and sand and gravel alluvium in the Missouri River's historic floodplain. The investigation noted "The Missouri River alluvium acts as a single aquifer of very high permeability." Some radioactive materials are at the surface; some have already been found at least as deep as 20 feet; some have washed off-site. Area 1 wastes are in the site's former quarry pits, atop porous limestone. Groundwater samples have indicated the presence of the radioactive materials.

The EPA seems to rely on a debatable conclusion that the radioactive materials have low solubility in water, thereby minimizing the chances of groundwater transport. Furthermore, the wastes are not mixed with water alone but with a chemical soup of landfill leachate that includes non-radioactive hazardous chemicals, such as the hydrocarbon solvents benzene and chlorobenzene. The Feasibility Study admits that "the RI [Remedial Investigation] was not designed to develop conclusions about the potential of contaminants to leach to groundwater over time." The 1988 study concluded that, "based on monitoring-well sample analyses, some low-level contamination of the groundwater is occurring, indicating that the groundwater in the vicinity is not adequately protected by the present disposition of the wastes."

Failure to Monitor

One of many disturbing features of this site is the seeming lack of controls at the site over its 33-year history. The 1988 report discusses an alarming occurrence. The radiological investigations in which technicians were taking gamma radiation readings, had begun in November 1980. When they returned to complete their work in May and July of 1981, they found that in Area 1 "approximately 4 feet of sanitary fill [garbage] had been added to the entire area and an equal amount of construction fill was added to most of Area 2." These activities occurred in a landfill the MDNR had "closed" in 1974. Why was additional waste added to a "closed" landfill? The technicians noted in the report that surface radiation readings were significantly lower in the May and July sampling events after the addition of more wastes. Whatever protections the addition of wastes provided, it did not prevent the contamination from spreading.

In what was an unheeded warning, the 1988 report also noted that the radioactive wastes were at the surface of the berm in Area 2 with "no protective cover of soil to prevent the spread of contamination and attenuate radiation." In the subsequent decade, the lack of protective cover resulted in erosion and contaminants washing off-site. The Feasibility Study mentions an instance of "large scale erosion" at Area 2 that deposited contamination onto adjacent properties (the Crossroads property and Buffer Zone.) "In November 1999, the vegetation and surface soil were scraped from the Buffer Zone property and a portion of the adjacent Crossroad property ... by AAA Trailer, a neighboring property owner..." and "piled in a berm along the southern boundary of the buffer property." The consultant relied on the grass and weeds growing on the site to prevent additional erosion and transport of contamination. As the consulting firm was conducting the soil sampling activities in 2000, it concluded that vegetation had been re-established on the off-site piles and was "determined to be sufficient to prevent windblown or rainwater runoff of these materials. Consequently, no additional interim measures were implemented." Unfortunately, the lack of any interim measures lead to another failure. Before publication of the Feasibility Study in 2006, its authors discovered that AAA Trailer had again moved the piles in 2003. I have not yet seen information on the current status of these off-site piles.

Hot and Getting Hotter

Another disturbing feature of the site relates to the unique nature of the radioactive materials. Because thorium-230 decays into radium-226, radiological hazards will actually increase over time. The 1988 report observes that "the Ra-226 [radium] activity will increase by a factor of five over the next 100 years, by a factor of nine 200 years from now, and by a factor of thirty-five 1000 years from now."

West Lake Landfill raises many questions about our ability to responsibly handle materials that will remain hazardous into the future longer than our records of human existence reach into the past. In 1988, the Nuclear Regulatory Commission staff concluded that measures must be taken to establish adequate permanent control of the radioactive wastes and to mitigate the potential long-term adverse impacts from its existing temporary storage conditions.

I applaud the EPA for taking responsibility for a long-neglected problem. However, I do not believe that the EPA's Preferred Alternative 4 in the Proposed Plan will contain the hazard and protect those of us downstream, now and into the future.

The West Lake Landfill was evaluated for potential remedial actions pursuant to EPA's "Presumptive Remedy for CERCLA Municipal Landfill Sites Guidance" (1993), which, at the very least, seem problematic since West Lake is no ordinary household garbage landfill. Nevertheless, leaving the wastes in the floodplain above the water-soaked alluvial soils, as the EPA has proposed, is unacceptable. We must do better than that for the children of the future.

Kathleen Logan Smith, Executive Director
Missouri Coalition for the Environment

West Lake Landfill Information and Resources