United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R07-84/002
January 1984
Superfund
Record of
Times Beach, MO (Quail
Run, Sontag Road, Minker,
Stout, Cashel, Sullins)
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TECHNICAL REPORT DATA
(PltfUt rtGd InstIVctions on tht rtvtnt INIon compltting)
1. REPORT NO. 12. 3. RECIPIENT'S ACCESSION NO.
EPA/ROD/R07-A.1 /()()2
.. TITLE AND SUBTITLE 5. REPORT DATE
SUPERFUND RECORD OF DECISION 1/13/84
Times Beach, MO (Quail Run, Sontag Road, 8. PERFORMING ORGANIZATION CODE
Minker Stout, Cashel, Sullins)
7. AUTHOR IS) 8. PERFORMING ORGANIZATION REPORT NO.
".
"PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT ~-o-:
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVERED
U.S. Environmental Protection Agency Final ROD Reoort
401 M Street, S.W. 1.. SPONSORING AGENCY CODE
Washington, D.t. 20460
.
16. SUPPLEMENTARY NOTES
18. ABSTRACT
The Minker.Stout, Cashel, Sullins, Quail Run, and Sontag Road sites
are contaminated with 2, 3, 7, 8 - tetrachlorodibenzo-p-dioxin (dioxin
or TCDD) greater than Ippb (CDC health advisory is lppb TCDD soils
level in residential areas). The cost-effective remedial alternative
selected for these sites entails construction of a 50,000 cubic yard
interim storage facility at Times Beach. The facility will be a
concrete tank with a flexible cover protected from flooding. The work
at each site includes excavation of the TCDD-contaminated soil, storage
in the interim storage facility, temporary relocation of affected
residents, and all necessary restoration leading to reinhabitation.
The remedial action also includes construction of spur levels at Times
Beach to minimize and control erosion and transport of contaminated
soil particles in the event that flooding occurs before response
actions can be completed. Total cost of this remedial action is ,
estimated to be $15,734,000.
17. KEY WORDS AND DOCUMENT ANALYSIS
~. OESCRIPTORS b.IDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Record of Decision .
Times Beach, MO
Contaminated media: soil
Key contaminants: dioxin (2, 3,7,8
TCDD)
18. DISTRIBUTION STATEMENT 19. SECURITY CLASS (This Rrpo'r) 21. NO. OF PAGES
None ' ?
20. SECURITY CLASS (TI,is pagr) 22. PRICE
None
EPA ''''111 2220-1 (Rn. ~-77)
PREVIOUI EDITION II 0810L.ETE
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INSTRUCTIONS
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LEAVE BLANK
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3.
RECIPIENTS ACCESSION NUMBER
RelllYed for use by nch report recipient.
TITLE ANO SUBTITLE
Title should in~icate de~ly an~ brien~ th~ subjtl:tcover;a~e u.f the report,' and b!: di~l'lay~'d "rumin~'ntly. S\'t ~ul>lill,'. if u",,'d. in ~mali~'r
type or otherwtse subordmate II 10 main IItle. When a report IS rrepared In moR' t""n un\' vulunl\'. reJ'l~atth~' rrimilry titl~'. iI,ld vulum,'
number and include subtitle for the specific title. .
4.
5.
REPORT DATE
Each report shaD carry I date indic:atinl at least month and year. Indkat\' Ih\' hil~i~ un whidl il was ",'Ie,'t,'d (I'./l.. .1111" ;lliuIIC', Jll/c'lIl
IIpproNI. diI" 01 p"ptlrtl'ion, "e,).
5.
PERFORMING ORGANIZATION CODE
Lean blank.
7.
AUTHORISI .
Gin name(sl in ~',mventional order (John R. Doe, J, Rolx'TI Doc', ('/('.). Li~t iluthur's aniliallun if il ,lilT\'r~ frum Ih\' I,,'rfurminj: "'j::llli-
zation.
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I.
PERFORMING ORGANIZATION NAME ANO AODRESS
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10. PROGRAM ELEMENT NUMBER
Use the prosram element number under which the report W;t~ prepared, Subordin;tte nUlllber, ilia)' bt: induJ,'.J in I';m'nlh~'"""
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Include ZIP code.
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15. SUPPLEMENTARY NOTES
Enter information not included elsewhere but useful, such IS:
To be published in, Supersedes, Supplements, etc.
Prepared ill cuopcr;tliun wllh, I r.III,I;tIlIlIlIlI, "r"""III,'" OIl ,.""",,,',,,,' IlL
1.. ABSTRACT
Inc:lude a brief (200 words or less) factual summary of the mosl sil{nilkanl infurm;tlilln ,.ulI!a,",," ,n I II,' "'I'ml. It Ih,' "'1'"11 "",1.1111' a
significant bibliosraphy or literature survey, mention it here,
17. KEY WORDS AND DOCUMENT ANALYSIS
(a) DESCRIPTORS - Select from the The~urus of Engineerir.~ ;tnd Sci"ntilk Terms Ihe pruper ;tulh"ri,,,J I,'rlll' Ihal,J,,"lIly Ih~' lIIaJm
concept of the research and are sufficiently specific and prel:ise to be used a~ index entries lur ~ata'u~lnj:,
(b) IDENTIrIERS AND OPEN-ENDED TERMS - Use identifiers for projecl nam", eude lIamcs. ~'4u1pmcnl J"SI~nalurs. "Ie. Usc "pen-
ended terms written in descriptor form for those subjects for which no dCSl:riplur e,-isls,
(c) COSA TI nI:lD GROUP. Field and grO\lP assignments are to be ...ken from Ihe 1965 (,OSI\ 11 SUh;l'~'1 ('''Il'~''ry Ust. SinCl' Ihe ma-
jority of documents are multidisciplinary in nature. the Primary "ield/Group ;tssignmenUs, will be '11I:dlk Ji".II,lin", an';t .,1' hUIII..n
endeavor, or type of physical object. The applic:ationh) will be crus)-r,"erenced with scl'un.J;try I idd/( ;ruul' ass'!!"I11""" Ihal will 11.11,,111
the primary postinS(s),
18. DISTRIBUTION STATEMENT
Denote releasabilit)' to the public or limitalion for reasons other Ihan security fur eXilm"le "Kd"..,,, t;..llIllIll'll." ('ill' any a~ailaIHhl)' III
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Insert the price set by the National rechnicallnformalion Servicc ur the Government Println!! Om!;e, If knuwn.
I! PA 'or", 2220-1 (R.... 4-77) (R....,..)
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RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
Sites: Minker, Stout, Cashel, Sullins, Quail Run, and Sontag Roa'd (all in
Missouri).
Documents Reviewed:
I have reviewed the following documents which describe and analyze the
cost effectiveness of the remedial alternatives for the referenced sites.
- Study titled: Central Storage Site Report, Feasibility Study,
Missouri Dioxin Sites
- Study titled:
Final Report of the Missouri Dioxin Task Force
- Study tit~ed: Draft-Phase I Feasibility Study, Minker/Stout -
Imperial, Missouri
- Study titled: Draft-Initial Remedial Measures, Minker Site -
Imperial, Missouri
- Study titled: Quick Response Engineering Assessment of Removal
Options for Quail Run Mobile Home Park
- Study titled: Quick Response Engineering Assessment of Removal
Options for Sontag Road
- Study titled: Quick Response Engineering Assessment of Removal
Options for Sullins Site
. As discussed elsewhere in this document, two sites at which EPA intends
to act - Quail Run and Sontag Road - are not currently listed on the National
Priorities List. EPA therefore will conduct planned removals at these
sites. For planned removals, the National Contingency Plan does not require
an analysis of alternatives as is required for remedial actions. However,
because the actions recommended for Quail Run and Sontag Road are similiar
to those recommended for the other sites, EPA included Quail Run and Sontag
Road in the analysis of alternatives. This record of Decision will only
discuss these two sites separately where the fact that they are not on the
National Priorities List substantively affects the findings required or
act ions allowed.
The interim storage facility will be located in Times Beach and will
have a limited capacity to store contamina~ed soil from only the highest
priority sites. An ongoing Feasibility Study for Times Beach will consider
the disposition of soil from the remaining sites in the State.
Descri ption of Selected Option:
o
- Construction of an approximately 50,000 cubic yard interim storage
facility at Times Beach, Missouri. The facility will be a concrete
vault with a flexible cover. (Remedial Action).
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- Excavati,on of the TCDD-contaminated soil from the following National
Priorities List sites: Minker, Stout, Cashel, and Sullins, and
transport to Times Beach for temporary storage in the interim storage
facility (Remedial Action).
Excavation of the TCDD-contaminated soil from the following
National Priorities List sites: Quail Run and Sontag Road,
transport to Times Beach for storage in the interim storage
(Planned Removal) and
non-
and
facility.
Necessary actions, within the authorities of the National Contingency
Plan to respond to the contamination of mobile homes at Quail Run
Mobile Home Park.
Declarat ions:
EPA has consulted the State of Missouri before determining the appro-
priate remedial 'action, as witnessed by the attached letter from the Director
of the Mi ssouri Department of Natural Resources. Consistent with the
Comprehensive Environmental Response, Compensation, and Liability Act of
1980 (CERCLA) and the National Contingency Plan, I declare the following:
- The selected option is technically feasible, cost effective and
consistent with final remedial alternatives as presented in the
feasibility study provided for public comment.
- The proposed remedial action at Minker, Stout, Cashel, and Sullins
is necessary to protect human health and the envi ronment. .
- The proposed planned removal actions at Quail Run and Sontag Road
are needed to mitigate the risk of exposure to dioxin by area resi-
dents and the environment. Further, pursuant to section 300.67(c)
of the National Contingency Plan, I find that it is necessary to
suspend the $1 million ceiling and 6 month limit for each site due
to the immediate risk to public health, the immediate need for
continued response to mitigate the risk, and the fact that assist-
ance will not otherwise be provided on a timely basis. The actions.
are necessary to mitigate direct contact and surface/subsurface
migration threats posed at the sites. .
- The action being taken is appropriate when balanced against the
need to use Trust Fund money at other sites.
- Off-site transport of hazardous substances is more cost-
effective than other forms of remedial action, and, therefore,
consistent with Section 101(24) of CERCLA and section
300.70(c) of the National Contingency Plan.
<.>
.i, "-~.~
Assistant Administrator
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NARRATIVE SUMMARY'
BACKGROUND
This summary documents the remedial and removal measures recommended
by Region VII and the State of Missouri for the Minker, Stout, Ca.shel,
Sullins, Quail Run, and Sontag Road sites. The six sites are residential
sites in St. louis, Franklin, and Jefferson counties in Missouri. All are
contaminated with 2,3,7,8-tetrachlorodibenzo-p-dioxin (dioxin or TCDD),
and have been recommended as high priority sites by the Missouri Dioxin
Task Force and the Governor of Missouri.
The final report of the Missouri Dioxin Task Force was submitted to
the Governor on October 31, 1983. The Task Force developed recommendations
and priorities based on overall risk to residents, workers and the environ-
ment; exposure risk to residents (especially children) and workers; potential
for erosion and ~usting; maintenance of neighborhoods and property values;
and long-tenn effects on Missouri and its citizens. Sontag Road and Quail
Run were assigned the highest priority with excavation and off-site interim
storage recommended as soon as possible. Minker, Stout, Saddle and Spur
Club, Cashel, Sullins, and Romaine Creek were assigned second priority
where excavation and off-site storage should be considered with short-term
stabilization actions in the interim. The Saddle and Spur Club will be
addressed through enforcement action. As a long-term state-wide solution,
the Task Force recommended secure central storage until proven technology
is available to destroy dioxin in contaminated soil with minimum risk to
public health and the environment.
To date there are 33 sites in Mi ssouri known to be contami nated. The
majority of these sites are not residential sites. The Centers for Disease
Control (CDC) has recently released a report titled: Health Implication of
. 2,3,7,8-tetrachlorodibenzo-P-dioxin (TCDD) Contamination of Residential
Soil which concluded "that soil levels of 1 ppb TCDD in residential areas
TS""'a reasonable level at which to express concern about health risks." The
conclusion applies to prolonged exposures and the six residential areas all
have dioxin concentrations greater than 1 ppb.
EPA has taken several actions at these six priority sites, including:
o
Draft Feasibility Study and a Draft Initial Remedial Measures
Report for Minker/Stout.
o
Quick Response Engi neeri ng Assessment of Removal Options for
Quail Run; Sontag Road; and Sullins sites.
Pennanent relocation offers for eleven families at the Minker/Stout
site.
o
o
Temporary relocation offers to two Minker neighbors.
Temporary relocation offers to about 100 residents of the Quail
Run Mobile Home Park.
o
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o Removal actions at Sontag Road, including application of dust
suppressants, vacuuming along roads and in residences, and paving
where the highest dioxin levels were found.
SITE DESCRIPTIONS/EXTENT OF CONTAMINATION
a) Minker: South of the Minker house is a gulley where fill material
contaminated with TCDD was placed in an attempt to alleviate an erosion
problem. The Minker residence is located on the top of a ridge with
runoff draining into Romaine Creek. Visual observations indicate that
much of the fill material has eroded down the hill into the yards of
neighboring homes and into Romaine Creek. Four other residences are
located downhill from the Minker house and one other house is immedi-
ately adjacent to the Minker residence. Analyses of samples collected
from the Minker fill area, yards of down-gradient homes, and sediments
from Romai.ne Creek reveal .that contami nation from TCDD is widespread
over the apPfox imately 3-acre Mi nker resi dent i al area, i ncl udi ng approx-
imately'6,000 feet downstream in Romaine Creek.
Duri ng sampl i ng, a topsoi 1 depth of only 8 to 12 inches was observed
in many locations over a jointed limestone and porous sandstone.
Vertical movement of surface water with soil particles from the Minker
site into the limestone is possible and could contaminate the shallow
aquifer above the Bushberg sandstone layer. The shallow ground water
may emerge in the g ai ni ng reach of Romai ne Creek or its tri butari es.
EPA has conducted extensive sampling in the Minker and Romaine Creek
areas. Of approximately 250 samples from the Minker site and adjacent
areas, 54 samples have shown concentrations above 1 ppb. Concentrations
over 300 ppb have been. measured in the fill area itself.
Several homes are located across West Rock Creek Road from the Minker
site. Recent sampling revealed concentrations above 1 ppb in the yards
of two of these properties.
b) Stout: Cant ami nated soil from the Bubbl i ng Spri ngs Ranch was taken to .
the Stout site at the same time it was being used as fill at the Minker
site. The fill material was used to make a level lot for two trailer
pads. EPA sampling found contamination throughout the fill from 1 ppb
to 200 ppb, down to a depth of 20 feet.
Runoff from the Stout site is thought to be primarily surface flow,
although subsurface flow has been noted in adjacent areas. The surface
flow is southerly toward Rock Creek. Samples between the fill area and
Rock Creek show that some surface migration is taking place. The site
is located over a porous sandstone and jointed limestone.
In December 1982, CDC issued a health advisory for the six families at
the Minker site. On March 17, 1983, the CDC extended its findings of
a health risk to include the two trailers and three homes at the Stout
site. On April 7, 1983, CDC again extended its health advisory to
include a seventh household next to the Mi nker home and a house on
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c)
Romaine Creek. On April 19, 1983, EPA authorized the Federal Emergency
Management Agency (FEMA) to offer permanent relocation to these famil i es
as a result ofa careful analysis of the health advisory and cost-
effectiveness of permanent versus temporary relocation. The CDC extended
its health advisory to include two additional families across. West Rock
Creek Road and offers of temporary re 1 ocat i on have been made .by EPA.
Cashe1: The Cashel residence is located 0.3 miles north of the Minker
site on West Romaine Creek Road. When contaminated soil was excavated
from the Bubbling Springs Ranch Arena in 1973, Mr. Cashel flagged down
two departing trucks and thus obtained two loads of dirt, which were
deposited in his garden. Subsequently, nothing would grow in the
garden, and two apple trees died. The dirt was scraped up and deposited
in a pile along the edge of the property.
The property is located on a ridge with neighboring residences located.
on both sides. The 50il layer is relatively thin, only a few feet
thick, with ,a moderate to high penneability. Samples were taken near
the surface with one measurement as high as 250 ppb. Other samples
ranged from 10-70 ppb di oxi n.
d)
Sullins: The Sullins home is located about one mile west of the Bubbling
Springs Ranch Arena. About 14 cubic yards of contaminated soil from
the arena was used to fill a depression left from the removal of a
large tree. The fill area is about 20 feet from Romaine Creek. There
is one home directly across the street from the Sullins', and a trailer
court adjacent to the creek and downstream of the fill area. Initial
sanp1ing showed contamination levels up to 99 ppb. Subsequent sampling
did not confirm migration of contamination but found levels as high as
820 ppb.
e)
Quail Run Mobile Home Park: The main road through the mobile home park
was sprayed with contaminated waste oil in the early 1970's. The oil
apparently was highly contaminated, based on the high TCDD levels
found at the site. The site was sampled a second time after screening
sampling revealed fairly widespread contamination. This widespread
contamination was caused when contaminated road materials were excavated-
and used as fill material. Also, the contamination has spread as a
result of wind-borne dust and storm water transport. The mobile home
park covers approximately 27 acres and consists of 38 trailer pads and
currently 28 mobile homes. The entrance to the park is at the top of
a ridge and the site slopes toward Little Fox Creek. Of 315 samples
collected, 136 had dioxin levels greater than 1 ppb, with the highest
concentration at 1,100 ppb. In addition to Quail Run Road, residential
yards, and the fill area, concentrations greater than 1 ppb have been
measured in Little Fox Creek, dust samples from 18 mobile homes, areas
south of the park entrance, and the shoulder of Highway 100 opposite
the park entrance.
About 100 residents of the park were offered temporary relocation in
May 1983 as part of an immediate removal action. The site has been
proposed for addition to the National Priorities List (NPL). However,
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addition to the NPL is dependent on a change in the National Contingency
P1 an.
f)
Sontag Road: Sontag Road is in the Cast1ewood subdivision located in
St. Louis County. In the early 1970's, Bliss Oil Co. spraye9 dioxin
contaminated waste oil on the two entrance driveways to the Cast1ewood
Swim Club as well as on Sontag Road for a distance approximately 2,000
feet west from New Ba11win Road. Since that time, the road has been
paved and the swim club has been closed.
The Sontag Road site consists of Sontag Road, shoulders along New
Ba11win Road, a large number of residences, the abandoned swim club, a
tavern, and a fi re station. The site is in the Spri ng Branch Creek
Valley. The affected population within a 2,000-foot radius of the swim
club is about 700. The area is located just upstream of the confluence
of Spring Branch and Keifer Creek and about one mile from the Meramec -
River. ,Sontag Road lies in the floodplain of the Spring Branch Creek.
50i1 in the area is a silty clay underlain by a gravelly silty clay
with some sand. Surface soils are characterized as having moderately
high permeability, and thus present severe limitations for constructing
dikes, levees, and embankments due to seepage and ease of erosion~
EPA has initiated some temporary removal actions consisting of the
application of dust suppressant to road shoulders and gravel driveways,
using high-efficiency vacuum cleaners to clean up loose particles
around roads and residences, and paving where the highest TCDD levels
were found.
\
The Centers for Di sease Control and the Mi ssouri Divi sion of Health
have issued health advisories for the six priority sites under consideration.
In general, these advisories cite the potential for adverse health effects
due to long-term exposure to contaminated soil under existing conditions
at these sites.
A no-action alterative is unacceptable due to the provisions of the
health advisories. A second alternative consists of relocation of the
residents who are directly affected by the health advisories. Permanent
relocation is currently underway for eleven families at the Minker site.
Permanent relocation offers have also been made to residents of Times
Beach and temporary relocation offers to Quail Run residents. Experience
shows that these voluntary relocations have not been completely successful
in removi ng all peop1 e from the cont ami nati on. Under the Comprehensive
'- Envi ronment a1 Response Compensat i on, and Li abil ity Act of 1980 (CERCLA),
permanent relocation can only be offered to residents at a site on the
National Priorities List. Thus, residents of Quail Run and Sontag Road
cannot receive permanent relocation offers. In addition, the six sites
under consideration are in residential areas and require measure~ to keep
neighboring residents from accidentia1 exposure. The potential for surface
and subsurface migration of the contamination exists in various degrees at
the different sites. This problem is the most severe at the Minker site,
while evidence of surface spreading has been observed at Stout, Cashe1,
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Quail Run, and Sontag Road. Therefore, unacceptably high public health and
environmental risks require consideration of response alternatives beyond
relocation of people from the sites.
FEASIBILITY STUDY ALTERNATIVES
Remedial investigations at the six sites have been carried out over the
last 10 months. A Feasibility Study addressing all six sites and titled
"Central Storage Site Report, Feasibility Study, Missouri Dioxin Sites,"
was completed December 6, 1983. In that study, seven remedial alternatives,
includirrg a no-action alternative, were considered. In accordance with the
National Contingency Plan, each alternative was examined according to three
. criteria: (1) Engineering, (2) Health and Environment, and (3) Economics.
The no action alternative was determined to be unacceptable because it
woul d not adequately protect publ i chealth and the envi ronment.
The other six alternatives considered in the Feasibility Study were:
A -' St abil i ze Soil In Pl ace
B - Interim Storage On-site
C - Disposal Off-site
D - Incineration
E - Solvent Extraction
F - I nterim Storage Off- site
$41. 5 M
$35.0 M
$32.2 M
$111.6 M
$151.6 M
$15.7 M
The costs for the two on-site alternatives (A) and (B) include permanent
relocation for residents on the sites. Costs for the previous buyouts at
Mi nker and Stout are not included si nce these are costs that woul d apply
to any future actions. Costs for temporary relocations during excavation
are included for the off-site alternatives (C), (D), (E), and (F).
Treatment alternatives (D) and (E) have the advantage of reducing dioxi n
levels and thus reducing the need for long-term monitoring and surveillance.
However, these alternatives require greater soil handling than containment
options and may present a greater exposure risk to workers. Solvent extrac-
tion would involve high risks associated with solubilized dioxin. The
treatment technologies have not been demonstrated to be practical at this
time for contaminated soils. There are uncertainties as to whether the ash
or soil remaining after treatment could be de1isted under RCRA. If the
soils are not delisted, they will still require disposal in a secure storage
facility or landfill, though these costs are not included in the estimates.
Costs for the treatment alternatives are considerably higher than those
for cont ai nment.
Contai rrnent alternatives (A) through (C) are technically feasible at
the present time. Alternatives (A) and (B) are on-site measures. During
September 1983, a public meeting was held on proposed interim on-site
storage option at the Minker site. The comments from this meeting, and
also comments received for on-site interim storage proposals at Quail Run
and Sontag Road, indicated public opposition to on-site measures and support
for excavation and restoration of the sites. Further discussion of alter-
natives (A) and (B) is contained in the Off-site Disposal Analysis which
fo 11 ows.
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Alternative (C), Disposal Off-site, assumes the availability of a
secure landfill. At the present time, there are no permitted hazardous
waste facilities in Missouri for the disposal of 50,000 cubic yards of
contami nated soil.
Based on the three criteri a of the Nat ional Cont 1 ngency Pl an, Interim
Storage Off-site is the best alternative. It is technically feasible, it
is the least costly and most cost-effective approach, and it can be imple-
mented 1n such a way that protection of the environment will be ensured.
Although the facility will be conservatively designed to provide long-term
secure storage, the intent of this option includes an accelerated technology
evaluation phase directed toward a permanent disposition of the contaminated
soil and closure of the facility. Implementation of the alternative will
involve five steps:
Construct i on of an ap.proximately 50,000 cubi c yard temporary storag~
facility at Times Beach, Missouri.
--
- Temporary relocation of people living at or near the six sites.
Excavation of the contaminated soil and transportation to the
storage facility.
Restoration and re-inhabitation of the sites.
- Covering the storage facility with a flexible cover.
RELATION TO OTHER STUDIES
-
,
The Office of Technology Assessment (OTA) prepared a staff memorandum
in December 1983 reviewing the recommendations of the Missouri Dioxin Task
Force. The OTA report agrees with the Task Force's finding that feasible
technologies for the treatment of dioxin contaminated soils are not yet
fully proven. However, OTA asserts that additional technology evaluation
should be sponsored for at least one year before endorsing a long-term
strategy for storage of contaminated soil as an interim step until treatment
technologies can be successfully demonstrated. The OTA report suggests that
the State of Missouri and EPA consider the option of embarking on a high
priority program to further examine and evaluate technological options for
proceding directly toward a permanent .solution to the contaminated soil
problem. The report also suggests, in the interim, that necessary emergency
actions at sites which pose a health or environmental threat could be
pursued, and perhaps the first stage storage option could be constructed.
The Agency's Dioxin Strategy document dated November 28, 1983, states
that the alternatives which appear to be most suitable for uncontrolled
sites are as follows:
1.
Secure soil in place -- in situ soil fixation, subsurface p~rimeter
grout curtain, impermeable cap, diversion of surface runoff, resident
relocation from immediate area and monitoring.
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2.
Consolidate and secure s011 -- removal of soil to secure landfill; or
containment of soil in a concrete vault, possibly on-site.
Incineration -- following excavation and transportation, a size reduc-
tion process is required before incineration.
3.
4.
Solvent Extraction -- solvents would be used to extract dioxin from
the soil into a soluble form. Several different technologies could
then be used to destroy the dioxin.
The Dioxin Strategy report also states that several important questions
need to be addressed through pilot studies before these alternatives can be
fully evaluated. As a first step, ORO will consider including an absorptionf
desorption study on contaminated soils as part of its research agenda to
determi ne dioxi n release rates.. While the treatment technologies (3) and
(4) may present the ultimate solution to contaminated media, they could
present significant health risks during processing. Thus, during the pilot
testing phase, the potential for further contamination must be assessed.
Based upon the success of the pilot testing phase, ORO will then be able
to implement the full field validation studies. The results of pilot test-
ing and full field validation will be used to evaluate alternatives for
clean-up given specific conditions of contamination and exposure.
The current remedial proposal is consistent with both the Agency
strategy and the OTA report. The proposed interim storage facility is
limited to approximately 50,000 cubic yards where the volume of contaminated
soil in the entire State has been estimated to be about 500,000 cubic yards.
This initial remedial project is focused on solving the short term health
problems at six sites and i.nc1udes provisions to facilitate research on
the permanent destruction of the contaminated soils. Several sealed bins
of soil will be stored separately from the facility to provide small quan-
tities of soil for bench-scale studies and larger quantities for pilot
scale demonstrations. Additionally, to the extent possible, soils will be
segregated within the facility according to characteristics relevant to
future treatment.
The large volume of soil remaining at uncontrolled sites after exca-
vation of the priority sites will be addressed as part of a second phase
effort. At this time other studies are underway (Times Beach and E11isvil1e)
which will address the longer term solutions for other dioxin sites in the
State of Missouri. These studies will carefully evaluate the recommendations
contained in the OTA report and develop alternatives that are consistent
with with the Agency's Dioxin Strategy, the Missouri Dioxin Task Force
. report and, to the extent possi bl e, the OTA report. Duri ng the interim,
- immediate on-site measures will be taken as needed at the confirmed sites
including the horse arenas and related sites under enforcement action. The
on-site measures will focus on erosion control through surface water diver-
sion methods, porous cover materials, or in-place fixation.
POLICY ISSUES
Three issues are important to the AA in selecting the remedial alter-
native for the six sites.
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1. The storage facility is to be constructed in a floodplain. Several
comments received during the public comment period concerned this fact and
these comments are addressed in the Responsiveness Summary. The Feasibility
Study included an analysis of alternative sites for the facility. Twelve
locations were selected by EPA and the Missouri Department of Natural
Resources as potential sites for a central storage facility. This list of
12 sites was numerically evaluated against 8 criteria to develop a ranking.
The criteria related to site ownership, location in an area already contam-
inated with dioxin, proximity to the six priority sites, access considera-
tions, site isolation, environmental risk, land use, and compatibility with
the accelerated schedule. After assigning a score to each criteria, Times
Beach was determined to be the most desirable location with a point total
of 35, followed by Fort Crowder with 29, and 4 other sites with 24. One
advanatage of Times Beach is its central location to the six priority sites,
while Fort Crowder is located about 275 miles away. Other advantages of
Times Beach include the fact that it is already contaminated with dioxin
(this is true" for only two other sites considered) and thus will not result
in contami nat i n9 a cl ean area; it has good access; and the facil ity wi 11
result in minimum land use impact. Also, the imminent State ownership of
Times Beach is extremely important with respect to the schedule for expe-
dited construction of the storage facility which is necessary to allow for
the excavation and restoration of some priority sites in the 1984 construc-
tion season. Under section 104{c){3) of CERCLA, the State must assure the
availability of an acceptable hazardous waste disposal and the State of
Missouri has officially designated Times Beach as the site. In addition,
the Missouri Dioxin Task Force recommended that the search for a site be
limited to State-owned land to expedite construction of the facility.
Therefore, despite its location in the floodplain, Times Beach is uniquely
qualified, is the most feasible site, and is probably the only site at which
an interim storage facility can be constructed by next summer.
-
Executive Order 11988 and Appendix A of 40 eFR Part 6 provide guidance
for EPA activities carried out in a floodplain. In general, EPA should:
-
,
Determine whether or not the proposed action is located in or will
1 He 1y affect a f1 oodp1 ai n.
Provide early public notice of the proposed action.
If there is no practicable alternative to locating in or affecting
a floodplain, act to minimize potential harm to the floodplain.
Prepare a Statement of Fi ndi ngs.
Allow at least fifteen working days for public and interagency
revi ew of the St ateme nt of Fi ndi ng s.
In those cases where an Environmental Assessment or an Environmental
Impact Statement is not prepared, prepare a Floodplain Assessment.
- Provide for public review of the Floodplain Assessment.
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Page 9
- Construct any facilities in accordance with the National Flood
Insurance Program except to the extent that the NFIP standards are
demonstrated to be inappropriate.
- Undertake floodproofing and other flood protection measures for
newly constructed structures and facilities.
The analysis of alternative sites in the Feasibility Study adopted in
this decision. determined that there is no feasible alternative to locating
in the floodplain. A computer-aided hydraulics analysis by the US Army
Corps of Engineers has indicated that a storage facility can be located in
Times Beach without causing any significant impacts on flood heights. The
maximum impact of a storage facility would not exceed a 0.15 foot increase
in flood heights. Flood heights in the neighboring town of Eureka will not
be affected. A Statement of Findings is included as an attachment to this
document. and will be distributed through the appropriate clearinghouse
for public review.
Publication of the Feasibility Study. the public meeting December 13.
and the public comment period have served to provide early notice of the
proposed action. A Floodplain Assessment will be prepared to further
analyze flood impacts. design considerations (including floodproofing and
other protective measures), and actions to minimize any potential harm to
the floodplain. The assessment will discuss National Flood Insurance
Program requirements and compliance of the proposed facility. The assess-
ment will undergo public review prior to the start of construction.
2. If TCDD were a listed hazardous waste under the Resource Conserva-
tion and Recovery Act, a RCRA permit would be required for constructing and
utilizing a storage facility for that substance. However. TCDD is not
expected to be a RCRA waste until the summer of 1984, and this listing will
not become effective until six months later. In order to provide the public
with an opportunity to comment on the facility similar to the opportunities
that would occur if a RCRA permit were necessary. a complete application
for a RCRA permit will be prepared and will be made available for public
comment. A public meeting will be held to discuss the application in con-
junction with a public hearing required under state regulations to address
the State's application for a state hazardous waste permit. The facility -
will be designed according to RCRA regulations such that it would be fully
permittable under existing RCRA regulations.
3. The cost estimates listed earlier are EPAls best approximations,
but are subject to error for the same reasons that any such estimates are.
The primary uncertainty is the actual volume of soil that must be excavated
from the sites. Previous sampling has indicated that dioxin contamination
ex i sts at depths of up to five feet. However, the low water sol ubil ity and
strong soil binding properties of TCDD indicate that it is unlikely that
TCDD could easily move that far into the soil. Recent unpublished results
from a study of soil sampl i ng techniques by the Regi on VII Envi ronmental
Services Division indicate that the previous results showing that TCDD
exists at depths below two feet may be in error, and that the errors might
have been caused by the sampling techniques used in the past. Because of
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Page 10
'-
the uncertainties that currently exist, it is not possible to predict
accurately the depth to which the contami nated soil wi 11 have to be excavated
at the six sites. The soil volume estimates used in preparing the cost
estimates assumed dioxin may exist at depths up to five feet. -
lower soil volume will decrease the costs for alternatives fnvolving
excavation and soil handling (8 through F) while having little effect on
- the inplace stabilization option since the extent of contamination will
not be affected. Therefore, this factor will not affect the results of
the cost effectiveness analysis. The volume estimates and other technical
questions will be subjects of continuing examination over the next several
months by a team of EPA, state, and contractor representatives who will
comprise an Extent of Remedy Work Group. This group will establish proce-
dures for temporary relocations addressing important public health questions
such as who should be relocated and for how long. A transportation plan
which is technically sound and- acceptable to the public will be developed. .
The goal will be to minimize the potential of exposure through attention
to handling,. trahsport, and routing alternatives.
Additional issues that will be resolved by the Extent of Remedy Group
include dust suppression assurance of contaminant removal~ procedures for
cleaning houses, and others. In order to ensure effective communication
with the public, public affairs personnel from EPA, the State and the
REM/FIT contractor are members of the Extent of Remedy Group. Also, the
CommunitY.Relations Plan will define in detail the procedures to be followed
in disseminating information and addressing comment on these issues of
interest to residents near the sites and near transportation routes.
OFF-SITE DISPOSAL ANALYSIS
-
I
At the public meeting on December 13, 1983, residents from Quail Run
and Sontag Road asked EPA to give additional consideration to in-place
stabilization of contaminated soil and permanent relocation of site residents.
This alternative was addressed in the Feasibility Study and estimated to
cost $41.5 million. An impervious cover was assumed with surface water
diversion and a double grout curtain around the Minker and Stout sites.
Residents on all six sites would receive permanent relocation and homes
would be demolished and buried. A long term monitoring program was assumed
at each site for 30 years.
Some cost savings could be realized for the stabilization alternative
by utilizing a porous cover instead of the impervious cover. This would
be most appropriate for the steep wooded slopes at the Minker site where a
porous cover would enable the trees to survive so their root structure
- could continue to stabilize the hillside. However, an impervious cover is
preferable for most areas because it eliminates the potential for migration
associated with water percolation through the soil and it provides greater
assurance that contamination will not reach the surface. Porous covers
would require a greater monitoring effort and no substantial net tost
savings would result. The grout curtain at the Minker and Stout sites
would cost $15 million and it is possible that limestone fractures under
these sites could transmit contaminated soil. Additional testing would be
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Page 11
necessary to assess the need for the curtain walls. However, even if they
were eliminated, the inp1ace stabilization alternative would cost $26.5
million compared to $15.8 million for the proposed interim off-site storage
option. The stabilization option includes 30 years of monitoring at each
of the six sites. The cost for a similar monitoring program was 'not included
for the interim storage alternative. However, this cost would b~ about
$0.5 million and would not affect the results of the cost-effectiveness
ana1ysi s.
An advantage of the proposed alternative is that the soil will be
excavated and centralized in one place for easy access should a treatment
alternative become available. Also, the impervious soil cover which would
. be part of the inp1ace option would add considerably to the volume of con-
tani nated material which waul d eventually have to be excavated and treated.
The proposed alternative, on the other hand, is consistent with the possi-
bility of the eventual destruction of dioxin once a feasible technology is
available. Most of the cost is attributable to soil excavation, transport-.
ation, restoratipn, and temporary relocation of adjoining residents, all
of which would be necessary should treatment measures be selected in the
future.
A second "on-site" alternative which would include permanent relocation
was also addressed in the Feasibility Study and consists of excavation and
cont ai nment in i ndivi du a1 storage facil it i es. To achi eve economi es of
scale, soil from the Stout, Cashe1, and Sullins sites would be hauled to
the Minker site. A monofill storage facility was previously proposed for
the Minker site but it met with considerable public opposition. The cost
for on-site storage facilities is estimated as $35 million. Thus, the
proposed off-site alternative is .more cost-effective than either of the
on-site alternatives, inp1ace stabilization or individual storage facilities.
Finally, permanent relocation of Quail Run and Sontag Road residents is
not currently within EPA's authority, since those sites are not on the
National Priorities list.
COMMUNITY INVOLVEMENT
The Feasibility Study was distributed to the public December 7, 1983,
and a public meeting to present and accept comments on the recommended
alternative was held December 13, 1983. Additional comments were accepted
in writing until December 27, 1983. A Responsiveness Summary detailing
and addressing the comments has been prepared and is attached as an appendix
to the Record of Decision. The major comments and brief responses are:
o Several people reiterated earlier requests for a buyout rather than
remedial actions.
A buyout would adequately protect the health of the persons permanently
relocated. However, due to the potential for further migration of the
contamination, a buyout would not protect the health of other persons, nor
would it adequately protect the environment. EPA would still have to
clean up the sites. Thus, a buyout would be an additional expense, rather
than an alternative to the proposed actions. Moreover, a buyout is not
presently an option for the planned removals at Quail Run and Sontag Road.
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Page 12
o Several people, particularly residents of Eureka, wanted commitments
that the facility would not be used for other types of wastes and that
the facility would not be permanent.
EPA will commit to not using the facility for wastes other ~han those
from dioxin sites in Missouri. The facility will be temporary until a
means to destroy the dioxin is developed. EPA is developing a research
program to study means for destroying the dioxi n,as part of the National
Di ox in St rategy.
o There were several comments that the facility should not be built in a
floodplain; that it would not be safe and that it would not be consistent
with government policy.
The safety of the facil ity wi 11 be assured by proper eng i neeri ng and
detailed analysis of flood height impacts. Building the facility in a
floodplain is consistent with government policy under certain conditions
that are being met.
o There were several comments about the need for special precautions in
transporting the soil to Times Beach.
EPA is very much aware of the need for special measures. Applications
of standard methods will adequately address this problem and we have estab-
lished a process to work out transportation methods in concert with the
publ i c.
o There were some requests, including one from the State Senate, that EPA
consider every available option rather than locating in a floodplain.
\
The Feasibility Study included a site-by-site analysis of every alter-
native site that could be identified. For reasons stated in the Feasiblity
Study, Times Beach was selected as the best site for the facility.
-
I'
A Community Relations Plan is being prepared. Community relations
will be more complex for this response activity than for most because of
the number of sites involved, the residential nature of the sites, the
construction of a storage facility in a floodplain, the need to transport
the soil through adjoining residential areas, and the amount of information
that will have to be communicated to the public. The Community Relations
Plan and the activities it guides will be designed to address each of
these special public concerns.
ENFORCEMENT
The Department of Justice is about to file a lawsuit on behalf of EPA
for remedial actions at six sites in Missouri, none of which is addressed
by this Record of Decision. However, current negotiations with 9ne of the
probable responsible parties are aimed at seeking a solution to the total
Missouri dioxin problem. The results from these negotiations should be
known soon. The only enforcement action taken at the six sites addressed
by this Record of Decision were notice letters sent to potentially respon-
sible parties at Minker, Stout, and Sontag .Road.
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.
RECOMMENDED ACTION
Section 300.68(j) of the National Contingency Plan [47 FR 31180,
July 16, 1983J states that the appropri ate remedi al action shall .be deter-
mi ned by the lead agency's selection of the alternative which the agency
determines the most cost-effective (i.e., the lowest cost alternative that
is technologically feasible and reliable) and which effectively mitigates
and minimizes damage to and provides adequate protection of public health,
welfare, and the environment. Section 300.67(a)(2) of the NCP provides for
undertaking a planned removal when the lead agency determines that the
public and/or environment will be at risk from exposure to hazardous sub-
stances if response is delayed at a release not on the National Priorities
List. Based on our evaluation of the cost-effectiveness of the proposed
alternatives, the public and environmental risk from exposure to the dioxin
cont ami nated soil, (noting the CDC health advi sori es) and the comments
received from the public, we r-ecommend the interim offsite storage alterna-.
tive. This project entails construction of a 50,000 cubic yard interim
storage facility' at Times Beach. The floodplain assessment, permit appli-
cations, design, bid packages, and construction management will be the
responsibility of CH2M Hill. The facility will be a concrete tank with a
flexible cover which is protected from flooding. Six sites will be restored
with the contaminated soil hauled to and stored in the interim storage
facility. The work at each site includes excavation, temporary relocation,
and all necessary restoration leading to reinhabitation. Minker (inc.luding
the neighbors), Stout, Sullins, and Cashel will be addressed as remedial
projects and CH2M Hill will be responsible for subcontracting and construc-
t ion management.
Sontag Road and Quail Run will be addressed as planned removals with
construction management by,CH2M Hill or by the ERCS contractor. At Quail
Run, the proposed project includes necessary actions, within the authority
of the National Contingency Plan, to respond to the contamination of the
mobile homes. Before begi nni ng construct ion, a State Superfund Contract
(SSC) will be negotiated with the State for the response actions. A draft
SSC has been prepared and sent to the State.
The proposed project also includes constrution of spur levees at Times
Beach to minimize and control erosion and transport of contaminated soil
particles already at the site in the event that flooding occurs before
response actions can be completed. The levees are independent of the interim
storage facility for the six sites and will be designed and constructed by
the U.S. Army Corps of Engi neers.
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Page 14
Following is a summary of the projected costs:
Studies. design. investigations.
bi d pack ag es
Site preparation and storage
facility construction.
Minker. Stout. Sullins.
Cashel remedial actions
* with 25% cont,i ngency
'-
Quail Run and Sontag Road
removal act ions
Fi 11; ng Storage tank and O&M
Spur levees
TOTAL
* with 25% contingency
-
I'
Cost *
(x $1000)
995
2.294
4.069
Cost *
(x $1000)
7.588
438
350
$15 . 7 34
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OTHER DOCUMENTS
The followi ng documents are attached.
1.
Transmittal letter from the Region VII Administrator recommending the
selected option.
Letter from Fred Lafser. Director. Missouri Department of Natural
Resources giving the three necessary assurances and requesting the
planned removals at Sontag Road and Quail Run.
3.
Central Storage Site Report. Feasibility Study. Missouri Dioxin Sites.
December 6. 1983. -
4.
5.
Responsiveness Summary.
Final Report of the Missouri Dioxin Task Force.
Draft Phase I Feasibility Study. Minker/Stout Imperial. Missouri.
6.
7.
Draft Initial Remedial Measure. Minker Site. Imperial. Missouri.
8. Quick Response Eng i neeri ng Assessment of Removal Options for Qu ail Ru n.
9. Quick Response Eng i neeri ng Assessment of Removal Opt ions for Sontag
Road.
10. Quick Response Engineering Assessment of Removal Opt ions for the Sullins
~ite.
(USACE "Spur Levee
Rev i ew
13. Statement of Findings (a special decision document required by 40 CFR
6 Appendix A relevant to E.O. 11988).
14. Missouri Clearinghouse Review on Interim Central Storage Facility
(Letter coming - TCR included).
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