What's next for the West Lake Landfill
Updated March 5 with new public comments deadline — The Environmental Protection Agency has released the full details of its proposal to remove radioactive waste from the West Lake Landfill. The agency will make a final decision after a public comment period.
The EPA will take feedback from individuals, environmental groups and companies responsible for the Superfund site until April 23. A public meeting will be held March 6 at the District 9 Machinists Hall in Bridgeton.
Read more: How to submit feedback on EPA cleanup plan
Earlier this month, the agency announced plans to remove 70 percent of the radioactivity at the landfill, in northwest St. Louis County. The site sits about 600 feet from an underground smoking fire at the Bridgeton Landfill.
Residents have tried to convince the EPA to clean up the site for years, and to many, the agency’s decision is a victory. But activists and some people who live near the site worry that removing only some of the waste may not be enough.
The chosen remedy balances several factors the EPA must consider when making final decisions, according to Mary Peterson, the Superfund division director for the EPA region that includes the landfill.
“It provides a very high degree of protectiveness for human health, and it's balanced out in terms of worker safety, safety to the community during the implementation phase, and cost effectiveness,” she said.
What the EPA’s done so far
Government officials added West Lake Landfill to the National Priorities List in 1990, designating it as a Superfund site. The EPA then began investigating the site more closely. Afterward, the agency published a study in 1991 that found the site “presents no apparent public health hazard” and recommended “continued monitoring.”
The site wavered in legal limbo for the next few years while the government attempted to determine whether or not the site needed to be cleaned up, and if so, which companies were at fault and should pay for any remediation. During that time, the EPA continued investigating the site.
With the investigation complete, the EPA began its first feasibility study. In 2006, the agency proposed capping the waste. The EPA accepted public comments and held public meetings, then signed two Records of Decision for the site in 2008. Many Bridgeton residents maintained throughout this process that they didn’t think the cap was a sufficient solution.
With pressure from the community, in January 2010 the EPA began conducting a Supplemental Feasibility Study — an unusual step. In December 2011, the EPA released the new feasibility study, which found that removing the waste, while expensive, would not be impossible.
The agency then began evaluating other options for the site. Discovery of an underground smoldering fire at the nearby Bridgeton Landfill renewed residents’ push for decisions and answers.
After years of deliberation, the EPA announced that it would remove 27 percent of the total waste at the site, targeting 70 percent of the radioactivity. This solution combines several of the remedies that the agency has considered in the past few years. The “proposed plan” explains which “cleanup alternatives” will be used and the remedy ultimately selected.
The cleanup process
Records of decision
The EPA has extended the public comment period until April 23. Residents can offer input during this time.
The EPA has solicited input on several facets of the plan: Does the proposed excavation plan address public concerns regarding the thoroughness of the removal? How should excavation differ between waste areas? And, where should the radioactive material go after it is removed?
“We're really interested to hear what the public has to say if they have different ideas about how how excavation could occur, because maybe it should be different in Area 1 versus Area 2,” Peterson said of the two sections of landfill the EPA’s plan targets. Area 1 is closer to residential areas and contains about 25 percent of the site’s radioactivity; Area 2 contains 75 percent of the contamination, generally located closer to the surface. “We're very open to considering public comment on those issues.”
Peterson said the EPA also is interested in feedback on the depth because the 16-foot excavation limit was decided “prior to the completion of all of the investigative work that was done at the site.”
Community activists have called for deeper excavation.
“I think that’s a possibility,” Peterson said. She said the decision would depend on how accessible the area is and whether the EPA could remove high-concentration material by digging deeper.
Some question the rationale for removing just up to 16 feet.
“How much deeper is [some waste] than 16 feet?” asked Dawn Chapman, who lives in nearby Maryland Heights and co-founded the Just Moms STL activist group. “Are we talking 17, 18 feet? At some point, when you start getting that low, you’re up to your waist in leachate and liquid. Is it a risk factor? Is it a money thing?”
Activists also are concerned about a potential fire starting at a portion of the site near the transfer station where waste was moved in 2005. The radioactive contamination under that waste is below 16 feet and therefore would not be removed.
“Leaving fresh municipal solid waste with the potential to smolder on top of radioactive material is currently the gamble the EPA wants to make,” said Ed Smith, policy director for the Missouri Coalition for the Environment.
The EPA is still deciding whether to transport the waste out of state or store it at the site.
Smith said he believes the public needs more time — at least 60 days — to understand and respond to the proposal. The EPA has the option to extend the comment period.
The EPA may update its proposal, develop a formal response to public comments, and issue a final record of decision. This whole process took slightly more than two years last time.
During this phase, the EPA develops a process for cleaning up, then prepares and removes toxic materials on the site. The EPA will continue to keep community members informed about its progress.
Some residents are also concerned about exposure to radioactive chemicals while the work is being conducted. Community members will not be relocated during the remediation, but Peterson promised “a very robust health and safety plan that site workers will be following,” as well as “extensive air monitoring” that should protect the community from radiation.
From remedial design through construction completion, EPA officials say the entire process will take five years, $236 million, and the cooperation of parties responsible for the waste.
According to Peterson, the potentially responsible parties — Bridgeton Landfill LLC, Rock Road Industries, the Cotter Corporation and the U.S. Department of Energy — will decide what portion of the costs each entity will cover. Bridgeton Landfill and Rock Road Industries are subsidiaries of Republic Services. The power company Exelon Corporation owned Cotter from 1974 to 2000. When it sold Cotter, Exelon agreed to retain "certain financial obligations" relating to environmental claims arising from past Cotter actions.
The agency would complete any necessary physical construction by this point, regardless of whether or not cleanup is over. That would involve completing the cap.
The EPA will review the technology that keeps the site clean in the long-term, monitor the site to make sure it remains safe, and add any necessary restrictions to protect nearby residents.
Peterson said that the site would be evaluated at least every five years — “forever.”
Smith, of the Missouri Coalition for the Environment, said he thinks an evaluation every five years is too infrequent, because of the amount of waste that will remain under the EPA’s current plan.
Deletion from the National Priorities List
Once the cleanup process is complete, the EPA plans to remove the site from the Superfund list. The public will have time to comment on the agency’s announcement, and then the EPA will respond to the comments. If the site still qualifies for deletion after comments, the EPA publishes a formal deletion notice.
Reuse and redevelopment
The EPA will work with the community to make the site useful. In the case of the landfill, its owner, Republic Services, will likely continue to use the land for industrial purposes.
Can public comments make a difference?
Making major changes to a cleanup plan can be difficult, according to California-based environmentalist Lenny Siegel, who’s studied Superfund sites for three decades.
"Public comments frequently make small changes in a remedy — occasionally large changes,” said Siegel, executive director of the Center for Public Environmental Oversight.
If the community doesn’t like a remedy, the EPA will negotiate. Political support can push revisions in residents’ favor, but cost will always limit the final decision. "If the solution increases the price by a hundred, then you can expect the federal government to resist that,” he said.
Siegel noted that some communities rely on a “technical assistance consultant” who explains reports and researches issues; the people in and around Bridgeton are not working with such a consultant, but they have received help from local environmental groups. If moving the waste could have a negative impact another community, the EPA likely would not adopt that solution, Siegel also said.
“The challenge is for those who don’t like the initial proposal to come up with something that’s not a huge amount more money and won’t create other risks,” Siegel said.
He also said that under the current administration, getting resources and funding to perform the cleanup could still be difficult, due to major cuts to the EPA's budget and staff.
"If someone is footing the bill, even if there’s money, the Trump administration has proposed to cut EPA’s staff particularly at a time when experienced engineers are retiring throughout the economy,” he said. “It’s possible that in a few years EPA will become a shell of itself. It won’t have the experts and experience to address these sites."
This story has been updated to clarify the potentially responsible parties involved for the cleanup plan.