fM) West Lake Update

pr oi^	March 31,2014	1

EPA Researchers Assess PRP Report on
Potential of SSE and RIM Contact

EPA's top researchers in the Office of Research and Devel-
opment have completed a critical assessment of the PRP's
report on what could happen if the subsurface smoldering
event in the Bridgeton Landfill came in contact with the
radiologically-impacted material (RIM) at the West Lake
site. Based upon current data submitted to the State by the
PRPs EPA does not expect the SSE to come into contact
with the RIM. EPA's experts agree the RIM is not expected
to be more or less radioactive in the presence of heat and
that there's no evidence that RIM will become explosive in
the presence of heat.

Regardless, the EPA's work continues apace to finalize an
assessment on the location of RIM and to get the order to
the PRPs in place to construct an isolation barrier that will
ensure the Bridgeton event and the RIM remain sepa-
rate while a final remedy for the site is determined. As we
reported recently the EPA is also in discussions with the
Army Corps of Engineers in St. Louis and Kansas City to
seek their assistance in providing construction oversight
and technical support. The St. Louis District of the Corps
of Engineers has a team that is uniquely qualified on RIM
projects and the Kansas City District has exceptional con-
struction management experience under Superfund.

The ORD review is posted online and available at: http://

EPA Partnership with USGS

EPA Region 7 has partnered with the LJnited States Geo-
logical Survey (USGS) at the West Lake Landfill Site since
2013. The USGS is a governmental science organization
that provides impartial information on the health of our
ecosystems and environment. As the national govern-
mental experts on groundwater, geology and hydrogeol-
ogy, USGS's partnership with EPA brings the best and the
brightest scientists to the West Lake site team.

The EPA partnership with USGS is administered under an
Interagency Agreement, outlining the scope of cooperation
between the two agencies. Some of the work that USGS is
doing for EPA includes off-site groundwater sampling and
evaluating groundwater data related to the site.

Community Inquiries

Ben Washburn

Find Us On

www.faceb o aregion7

Meet David Hoefer

In addition to the complex
scientific and engineering models
required to bring a Superfund site
back to public use, a great deal of
legal forces are involved. In fact,
without EPA's enforcement au-
thority a site like West Lake would
never be listed as a Superfund site
and no potentially responsible
party would ever be named. The
result...we would not be in a
position to enforce a cleanup or
mitigation of a site like West Lake.

One of the driving legal profes-
sionals behind the West Lake Su-
perfund site at EPA's Region 7 is David Hoefer. An attorney
with EPA since 1990, David is currently the Chief of the
Superfund Branch in Region 7's Office of Regional Counsel.
David manages the legal aspects of the West Lake site for
Region 7, which includes two parts enforcement and one
part negotiation with the potentially responsible parties.

Prior to serving as Chief of the Superfund Branch, David
served as an attorney working with the Superfund program
on National Priorities List sites throughout Region 7. His
work ensured correct response and enforcement for many
significant sites. David earned his bachelor's from Regis
University in Denver, and his law degree from the Univer-
sity of Missouri - Kansas City.

Superfund Enforcement

Critical to the success of David Lloefer and the EPA is the
Comprehensive Environmental Response, Compensation
and Liability Act (commonly known as the Superfund law).
The law provides EPA broad enforcement authorities to
compel responsible parties to perform investigations and
clean-up actions at contaminated sites. This law keeps the
cost to the taxpayer at a minimum while keeping it on the
shoulders of those potentially responsible for the environ-
mental problem.

EPA identifies those responsible for contamination at a
site and pursues a "polluter pays" approach to obtaining
site clean-up. If a responsible party does not agree to do
the required investigation and cleanup, EPA has the legal
authority to issue an order compelling it to conduct work,
or EPA may work with the U.S. Department of Justice to
pursue the party through litigation. EPA may also assess
penalties against parties who do not cooperate, and may
conduct the work itself through use of the Superfund and
then sue the parties for recovery of its costs. We have a lot
more information about Superfund enforcement authori-
ties on our web site