The U.S. Environmental Protection Agency required significant revisions to four documents submitted for remediation of the radioactively contaminated portion of the West Lake Landfill Superfund Site in Missouri.
Contractor Parsons Corp. in July filed draft versions of the emergency response and site management plans for Operable Unit 1 (OU-1) at West Lake, then in August submitted the draft remedial design work plan and design criteria report. The documents were prepared on behalf of the entities responsible for the cleanup program – the U.S. Department of Energy, Cotter Corp., and Bridgeton Landfill – as required under their May 2019 agreement with the EPA for remedial design of OU-1.
The EPA formally disapproved the first two documents on Aug. 27, then did the same with the more recent filings on Sept. 13.
“The EPA has completed its review of these two documents and is disapproving both of them as submitted. Please revise the documents in accordance with the enclosed comments and re-submit them within 30 days of receipt of this letter,” Christine Jump, remedial project manager with the agency’s Superfund and Emergency Management Division, wrote in two letters of disapproval covering the four documents.
Thursday was the deadline for resubmission of the site management and emergency response plans. Parsons has until Oct. 15 to other updated documents. Environmental Protection Agency spokesman Ben Washburn confirmed Friday that the site management and emergency response plans had been delivered, but that they cannot be considered final pending further review.
“EPA will work with the parties to assure our comments are addressed and the documents are finalized,” Washburn said Wednesday by email.
Jump’s letters were both sent to Paul Rosasco, project coordinator for Engineering Management Support Inc., of Golden, Colo. Engineering Management Support is an environmental consultant that has provided services since 1994 at West Lake. Rosasco is managing communication between the various parties involved in the remediation program, according to the EPA.
Operable Unit 1 encompasses two radiologically contaminated areas, a buffer zone, and one nearby privately owned lot within the 200-acre Superfund site near St. Louis. The two areas were contaminated in 1973 by 39,000 tons of surface soil that had been mixed with 8,700 tons of radioactive leached barium sulfite residues prior to use as trash covering. Erosion migration is believed to have spread radiological material to the buffer zone and lot.
The Environmental Protection Agency has spent decades trying to finalize its cleanup approach for OU-1, to the point that some locals and lawmakers urged the program be transferred to the U.S. Army Corps of Engineers. Last September, the EPA updated its 2008 record of decision to establish its final method of remediation.
The new plan calls for removal of radiologically impacted material down as far as 20 feet in the contaminated zones. For the most part, soil contaminated at levels above 52.9 picocuries per gram would be removed to a depth of 12 feet. In certain sections material with concentrations above 52.9 picocuries per gram will not be removed at depths of 8 to 12 feet. An engineered cover would be placed over the landfill once excavation is complete. The project is estimated to cost $205 million over three years, to be paid by the potentially responsible parties.
In May, the potentially responsible parties agreed to fund and prepare the design necessary for the latest West Lake remediation plan. That process itself is expected to last up to three years from the date of the May order, according to Washburn.
Cotter Corp. and Bridgeton Landfill would provide the actual design work, with the federal government paying its share of Energy Department’s one-third of the cost to the companies. That payment approach would remain through the actual remediation response.
Bridgeton Landfill LLC, a subsidiary of Republic Services, owns the landfill. Cotter Corp. and the Energy Department are also designated as potentially responsible parties for having arranged for disposal or transport to disposal of the hazardous material at OU-1.
The 71-page draft remedial design work plan lays out the operations and documentation that will be used to carry out the cleanup approach formalized in the amended record of decision. Along with new investigations of the impacted area, the process will include submission of the design criteria report and several versions of the remedial design until it is complete.
The 51-page draft design criteria, meanwhile, covers topics including site preparation, environmental and community protection during cleanup, stormwater and erosion protection, and waste protection.
The EPA this month responded to the Parsons’ filings with 88 separate comments on the remedial design work plan and design criteria – six general comments and 82 addressing specific sections of the report. They range from the general finding that “several processes and elements” of the work plan do not appear to line up with descriptions in the record of decision, to requesting that a specific sentence be deleted.
The site management plan covers security and pollution prevention measures to be established for OU-1 during the remedial design and response. The emergency response plan addresses steps for dealing with an accident or other event during that period.
Among the long list of EPA requests in nine pages of comments on the documents: A schedule for submission of the emergency response plan to local authorities; addressing how the emergency response manager for OU-1 would be alerted to a possible emergency; clarifying whether emergency responders would have access to personal protective equipment before arrival of the OU-1 radiation safety officer; listing basic requirements for a radiation work permit for entry into the unit; and details of video surveillance of OU-1.
Washburn said the EPA reviewed all the documents in conjunction with the Missouri Department of Natural Resources and the St. Louis Lambert International Airport.
