Superfund
Record of Decision:
Ellisville, MO
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO. 12. 3. RECIPIENT'S ACCESSION NO.
EPA/ROD/R07-85/004
4. TITLE AND SUBTITLE 5. REPORT DATE
SUPERFUND RECORD OF DECISION July 10, 1985
Ellisville, MO 6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S) 8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.
". CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVERED
U.S. Environmental Protection Agency Final ROD Report
401 M Street, S.W. 14. SPONSORING AGENCY CODE
Washington, D.C. 20460 800/00
15. SUPPLEMENTARY NOTES
16. ABSTRACT
The Ellisville Area Site is located in St. Louis County, Missouri, about
twenty miles west of downtown St. Louis. The site is comprised of three non-
contiguous properties: the Rosalie Investment Company property, the Callahan
site and the Bliss si te . Containerized and bulk liquid and solid wastes were
reportedly disposed of on these properties during the 1970s. The types of wastes
include solvents, oils, sludges, pesticides, and flammable gelatenous materials.
The selected remedial action includes:
. Callahan Property. Stabilize and control erosion of the fill area;
remove and dispose the plastic cover over the fill area and the
cover's hold-down blocks; remove and salvage the barbed-wire and chain-
link fences around the site; and remove the gravel in the two drum
storage areas. Preliminary cost estimate for the remedial action is
$12,000.
7. KEY WORDS AND DOCUMENT ANAL YSIS
DESCRIPTORS b.IDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Record of Decision
Ellisville, MO
Contaminated Media: soil, sw
Key contaminants: solvents, oils,
sludges, pesticides, phenols, toluene
and flammable gelatenous materials
18. DISTRIBUTION STATEMENT 19. SECURITY CLASS (This Report) 21. NO. OF PAGES
None 49
20. SECURITY CLASS (This page) 22. PRICE
None
EPA FCHm 2220-1 (Rn. 4-77)
PREVIOUS EOITION IS OeSOL.ETE
-------
INSTRUCTIONS
1.
REPORT NUMBER
Insert the EPA report number as it appears on the conr of the publkation.
LEAVE BLANK
2.
3.
RECIPIENTS ACCESSION NUMBER
Reserved for use by each report redpient.
4.
TITLE AND SUBTITLE
Title should indicate dca~ly an~ brien~ th~ subject ,'overa~c 0,1' Ihc report. and b.: disl'lay,'J 1'llIl1Iin"IIII)', s,.t suhtilk. i!' m~',1. III smalkr
type or otherwise subordinate lito main tllie. When a report IS I'repared in mon' than ,'nc V
-------
16.
Abstract (Continued)
Rosalie Property. Offsite disposal of contaminated soil, buried drums,
cans and other debris; soil excavation; and soil testing and analysis.
Preliminary cost estimate for the remedial action is $52,000.
Bliss Property. U.S. EPA is currently working on an expanded
feasibility study for this site, since additional cleanup options
should be evaluated for the dioxin contaminated soil.
-
-------
,.
~ -,.. .
.. .-' ~"
1'"
Record of Decision
Remedial Alternative Selection
Site: Rosalie and Callahan Properties, Ellisville Area Site,
---- El1isvi1le, St. Louis County, Missouri
Documents Reviewed
I have reviewed the following documents describing the analysis of
cost-effectiveness of remedial alternatives for the Rosalie and Callahan
Properties at the Ellisvi1le Area Site.
--Study titled "Remedial Feasibility Study,
Ellisville Hazardous.Waste Disposal Site,
E1lisvil1e, Missouri," September 28, 1983.
--Study titled "Remedial Investigation,
E1lisville Hazardous Waste Disposal Site,
Ellisvi1le, Missouri," September 21, 1983.
--Draft study titled, "Description of Current
Situation, Ellisville Hazardous Waste Disposal
Site, El1isvi11e, Missouri," August 30, 1982.
--Summary of Remedial Alternative Selection
--Staff summaries and recommendations.
--Recommendation by the Missouri Department of
Natural Resources
Description of Selected Remedy
A.
Jean Ellen Callahan Property
A remedial action should be implemented for the Jean Ellen Callahan
property to control erosion and slippage of the fill area where drums were
excavated during the 1981-82 immediate removal action and to remove the
vestiges of that action. The remnants of the plastic cover over the
fill area and the cover's hold-down blocks should be removed and disposed
of. The soil in the fill area should be spread. and regraded to a stable
slope over a larger area and covered with a compacted 50i1 layer which
should be reseeded. The barbed-wire fence around the fill area and the
chain-link fence around the two drum storage areas should be removed and
salvaged. The gravel in the two drum storage areas should also be removed
for possible salvage. The preliminary opinion of probable cost for this remedial
action is $12,000.
-------
';'
B.
Rosalie Investment Company Property
The most cost-effective'remed1aT action -- offsite disposal of contaminated
soil, buried drums, cans and other debris should be implemented for the Rosalie
Investment Company property. Contaminated soil should be excavated from two
locations on the property and transported in bulk to an offsite commercial
hazardous waste disposal facility operating under RCRA permit or interim status and
meeting CERCLA offsite policy. Drum lids, cans and other debris should be removed
from three locations on the property and placed in drums. Buried drums should be
excavated and overpacked, with the drum contents sampled and tested. The drums
should be disposed of at an offsite commercial disposal facility operating under
RCRA permit or interim status and meeting CERCLA offsite policy. Following soil
testing and analysis to verify the effectiveness of the cleanup, borrow soil
should be placed and compacted in the excavated areas, with all disturbed areas
reseeded. The preliminary opinion of probable cost for this remedial action is
$52,000. .
Decl arat; ons
Consistent with the Comprehensive Environmental Response, Compensation and
Liability Act of 1980, and the National Oil and Hazardous Substances Contingency
Plan (40 CFR Part 300), I have determined that at the Rosalie Investment Company
Property, the excavation of contaminated soil, buried drums, cans and other debris
and offsite disposal at an appropriate commercial disposal facility operating
under RCRA permit or interim status and meeting CERCLA offsite policy provides
an appropriate level of cleanup. At the Jean Ellen Callahan Property, I ha\~
determined that erosion control of the fill area and removal of the onsite
vestiges of the immediate removal action provides an appropriate level of cleanup.
The actions taken are cost-effective remedies, and they effectively and reliably
mitigate and minimize damage to, and provide adequate protection of public health,
welfare and the environment. I have also determined that the actions taken are
appropriate when balanced against the need to use Trust Fund money at other sites.
In addition, the chosen remedy for the Rosalie Investment Company Property complies
with the requirements of Section 101(24) of CERCLA because offsite disposal is
more cost-effective than potential onsite remedies and necessary to protect public
health and the environment.
~
7- / 0- ~'5
Date
/:?:t:!--I (~
tYMorr1s y , -- J
Regional Administrator
Regi on VII, EPA
. '.
-------
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
ELLISVILLE AREA SITE
ROSALIE AND CALLAHAN PROPERTtES
SITE LOCATION AND DESCRIPTION
The Ellisville Area Site is located in west St. Louis County, Missouri, about
twenty miles west of downtown St. Louis, Missouri. The site lies west of Ellisville,
Missouri, in Sections 31 and 32, Township 45 North, Range 4 East, as shown in
Attachments A-I and A-2. .
The site is comprised of three non-contiguous properties which lie within a
one-mile stretch along the watershed of Caulks Creek, a tributary of Bo~homme Creek,
which enters the Missouri River about one mile upstream of a City of St. Louis
waterworks intake. The population within a one-mile radius of the site is approx-
imately 1,000. Within a three-mile radius the population includes 5,000 people
and within five miles the population includes 8,000 to 10,000 people. The area
is being rapidly developed as a residential community. Homes are being constructed
in subdivisions as well as on single lots.
°Rosalie Site
~
One of the properties which comprise the site is owned by Rosalie Investment
Company, a St. Louis County land development concern. The property is
located approximately 0.4 miles southwest of the intersection of Clayton Road
and Strecker Road west. A housing development owned and operated by Rosalie Inves,
Company, known as the Village of Winding Trails, occupies a major portion of this
85.6 acre site. The actual size of the contaminated areas, inclusive
of 100-foot buffer zones, is 4.11 acres.
°Callahan Site
The Callahan site is comprised of 8.02 acres located approximately 1,000
feet west of the corporate limits of the City of Ellisville, Missouri.
A pond, large barn and large wooded area are the major features of the property.
SITE HISTORY
On the morning of July 17, 1980, a contractor for the St. Louis Metropolitan
Sewer District (MSD) encountered buried drums while excavating for a new sewer
line in a semi-rural area about one-half mile west of Ellisville, Missouri. The
drums were reported to the Missouri Department of Natural Resources (MDNR) and
the U.S. Environmental Protection Agency (EPA) emergency response groups that
same day. A preliminary investigation by MDNR and MSD of that site, which became
known as the Rosalie Investment Company property, indicated a potentially serious
threat to public health and the environment. Subsequently, two other areas were
identified by informants or concerned citizens. The other areas are known as
-------
2
the Callahan site and the Bliss site. Containerized and bulk liquid and solid
wastes were disposed of on these three properties reportedly during the 1970s. The
types of wastes included solvents, oils, sludges, pesticides and flammable gelatenous
materials. .
On October 23, 1981, EPA announced that the Ellisville Area Site was on the
National Priorities List. MDNR had applied for federal assistance on September 25,
1981. A cooperative agreement was awarded to the State on March 17, 1982, under
CERCLA. The objective of the cooperative agreement was to undertake a remedial
investigation/feasibility study and to implement appropriate remedial actions.
The site investigation proceeded in four phases. The purpose of Phase I, the
full field investigation, was to characterize the wastes and define the extent
of contamination still remaining at the site. The purpose of Phase II, the
feasibility study, was to determine remedial actions for the site, conduct a
cost/benefit analysis and recommend a preferred alternative. Phase I and II
were completed by Black & Veatch. On September 28, 1983, the Feasibility Study
was released. Phases III and IV will be engineering design and implemen-
tation of the preferred remedial alternatives identified in Phase II.
A.
Rosalie Investment Company Property
.
Four dumping areas containi"ng over 200 drums and one- and five-gallon
buckets of chemical wastes have been discovered on the property, some of which
were leaking wastes into Caulks Creek. Some of the drums were removed from one
of the areas in August 1980, using federal funds available through Section 311
of the Clean Water Act. On August 6,1980, the U.S. Coast Guard-Marine Safety
Office contracted with Western Environmental Services for removal and disposal
services of 45 (some reports say 47) drums suspected of containing hazardous
materials. On August 8, 1980, removal was complete. The remaining drums
containing trash from this area were removed and disposed at the expense of the
Rosalie Investment Company. The remaining three areas were determined to be
ineligible for Section 311 funds. In June 1981, the State of Missouri removed
one hundred fifty-three (153) drums from two of the remaining three locations.
They were transported to the Environmental Emergency Services (EES) facility in
Chesterfield, Missouri, for temporary offsite storage. The drums were stored
under a MDNR emergency storage permit vntil arrangements could be made for
disposal at a Subtitle C facility. The MDNR applied for interim status for the
facility. . In May and June of 1982, the 153 drums were transported to two
licensed disposal facilities. Drums containing solids were transported to Bobls
Home Service (BHS) in Wright City, Missouri. Drums containing liquids were
transported to ENSCO in El Dorado, Arkansas.
On July 7, 1982, Black & Veatch, Woodward-Clyde Consultants and MDNR
personnel visited the Rosalie property to view the four dumping locations. No
drums were seen, but drum lids and trash were observed.' On August 30, 1982,
-------
3
Black & Veatch stated in its "Draft Description of Current Situation" report
that all of the containers found to date on the Rosalie site had been removed
from the property and disposed of. However, they felt that potentially
contaminated soil remained on the property at the four locations.
Between December 1982 and February 1983, a remedial field investigation'
was conducted at the E11isvi11e Area Site. This investigation was performed by.
Black & Veatch under contract to EPA. The objective of .this investigation was to
collect data to support the feasibility study for the E11isvi1le Area Site. During
the course of the investigation, a reconnaissance was conducted at each of the
three properties. Water, waste and air samples were obtained and submitted for
chemical analysis.
An offsite investigation was also conducted to evaluate potential offsite
migration of wastes from the three E11isvi11e sites and to obtain information to
help assess potential impacts on human health resulting from waste migration
from these sites. The offsite investigation was conducted in two phases. The
first phase of the investigation was the sampling of four domestic drinking
water wells. The second phase was the collection of surface water samples.from
five locations on Caulks Creek. (For a detailed assessment of data, refer to
Attachment B-2: Remedial Investigation, Volume I: Summary Report, September 21,
1983, pp 39 and 40.)
.
B.
Jean Ellen Callahan Property
In August 1980, MDNR received a report about past dumping activities on the
property. An investigation of the Callahan property was conducted by MDNR on
September 16 and 17, 1980. The purpose of the investigation was to determine if
the property had been used for the disposal of hazardous waste as alleged by at
least two informants. The investigation was conducted only on the surface area of
the property. No excavation was done. The investigation revealed thirty-eight
(38) 55-gallon drums either protruding from a filled ravine or below the filled
area. Positive responses from a metal detector were recorded over the entire
fill area. Probing the soil with a metal rod indicated buried metallic
objects. Four additional drums were found exposed in the valleys south of
the fill.
In late 1981 and early 1982, an Immediate Removal action at the Callahan
property was initiated by MDNR and completed by EPA. On December 14, 1981, MDNR
obtained access to the Callahan property and initiated excavation of buried
drums, using state funds. The State of Missouri's contractor was Environmental
Emergency Services. It became apparent to MDNR on December 17, 1981, that
additional funds were needed for cleanup when the original estimates of 200
buried drums increased to around 1,000. MDNR requested assistance from EPA
Region VII on that date. An EPA inspection team visited the site on December 18
-------
.'>.
, .
4
and reported an imminent hazard to public health and the environment. EPA
Region VII submitted an Immediate Removal funding request to EPA Headquarters
on December 24, 1981. On December 30, 1981, EPA announced the availability of
$210,000 of Superfund money. EES signed a contract with EPA and resumed removal
and staging activities on January 4, 1982. A total of 907 drums were in secure
storage either on the property or at BHS at the end of January 1982. The two
onsite drum storage areas were ~ecured from public access with chain link
fencing. EPA approved an additional $100,000 on January 27, 1982, after the
estimated number of drums increased to 1300.
The drum removal action was completed on February 18, 1982. One thousand
two hundred and five (1205) drums were excavated. A total of 613 drums
containing liquid and solid wastes were placed inside recove~ drums and stored
onsite. An additional eight (8) drums containing wastes from the Immediate
Removal were also stored onsite. The remaining 592 drums were placed
in bulk disposal containers and disposed of at BHS. A total of $310,000 was
authorized by EPA for this removal action. Approximately $374,000 was expended
by EPA and the State. Approximately 500 cubic yards of potentially contaminated
soil was placed back in the excavated area and covered with plastic sheets.
On June 30, 1982, it was reported that a large portion of the backfilled
soil had slid from beneath the plastic cover. Black & Veatch, Woodward-Clyde
Consultants and MDNR personnel visited the Callahan property on July 7, 1982
to view the drums, the drum storage areas, the excavated and backfilled area
and the backfill slide. The excavated and backfilled area was enclosed by a
barbed-wire fence on July 21-22, 1982.
-
From July 21-27, 1983, Environmental Emergency Services removed and disposed
of the 624 drums of hazardous waste stored onsite at the Callahan Site. The
total contractual cost of the removal was $87,360.
CURRENT SITE STATUS
A reconnaissance was made of the Jean Ellen Callahan property during the
Remedial Investigation on December 28 and 29, 1982, to obtain information useful in
preparing an estimate of the volume and physical and chemical nature of the fill
area which previously contained drum wastes. It was noted that the plastic tarp
which had been placed over the fill area was severely torn or disintegrated. Soil
sampling was conducted in four general areas on the Callahan Site. These four
areas were: 1) in and around the existing fill area, 2) the two fenced drum storage
areas, 3) surface water drainageways located downgradient of the fill area, and
4) a potential borrow area for the construction of a surface cap, located at
the north side of the site. (For a detailed assessment of this data, refer to
Attachment B-3: Remedial Investigation, Volume I: Summary Report, September 21,
1983, pp 28-30.) "
-------
5
The Remedial Investigation concluded that the soil in the fill area where
drums were excavated during the 1981-82 removal action was physically unstable
and susceptible to erosion. It was also determined that soil at the drum storage~
areas on the Callahan property was not contaminated. The remedial objective for
the Callahan property is to stabilize the soil mass at its present location and to
remove the vestiges of the Immediate Removal action at the site. These include
removal and salvage of the chain-link and barbed wire fence and the gravel used in
the two drum storage' areas and removal of the plastic cover and its hold-down
blocks.
A reconnaissance survey was conducted during the Remedial Investigation on
the Rosalie Investment Company property on January 6, 1983. The purposes of this
reconnaissance were: 1) to define a route of access to the four waste disposal
locations on the Rosalie Site, 2) to identify each of the four waste disposal
locations on the Rosalie Site, 3) to mark the approximate limits of these four
locations, and 4) to note any remnants of past removal activities. Soil sampling
was performed on the site at the four waste disposal locations, in a dry pond
located downstream of the location designated as ELL-02, and in a portion of
the former nursery operated on the Rosalie property. A surface water sample was
obtained from a standing pool of water located in a ditch downstream from
ELL-01. (For a detailed assessment of this data, refer to Attachment B-1:
Remedial Investigation, Volume I Summary Report, pp 33-37.) In addition, a special
analysis for 2,3,7,8-TCDD was performed by Envirodyne Engineers on a composite of
the so;l samples collected from the Rosalie Investment Company property. No 2,3,7,
8-TCDD was detected at a 1 ppb detection level. The following hazardous waste
related problems were identified on the Rosalie Investment Company property: Location
ELL-01 -- Contaminated soil susceptible to erosion; Location ELL-02-- Orums and
contaminated soil; ELL-03 -- I-gallon cans and drum debris; and Location ELL-04 -
5-ga1lon cans.
Contaminated soils were detected at Location ELL-01 over an area of
360 square feet extending to a depth of two feet. Contaminated soils were
detected at Location ELL-02 over an area of 1450 square feet and to a
depth of four feet. Contaminants detected at these two locations are
summarized in Tables R-4 and R-6 of the Remedial Investigation (attachment B-4).
In addition, buried drums possibly containing hazardous substances were
identified at Location ELL-02.. Locations ELL-01 and ELL-02 are located
directly in surface water drainage ditches which are tributaries of
Caulks Creek. Undercutting of contaminated soil layers has been visually
observed at Location ELL-01. Priority pollutants in excess of EPA water
quality criteria for protection of human health and for toxicity to
freshwater aquatic life have been detected in surface water samp)es from
both the Callahan and Rosalie properties.
~
A release of hazardous substances to the envi ronment has been observed. at
the Rosalie property. Contaminants detected include substances of high
and moderate toxicity. Highly toxic substances detected on the Rosalie property
-------
6
include phenol and 4-methylphenol (4-cresol). Moderately toxic substances detected
in the Rosalie property include o-xylene, toluene, ethylbenzene and napthalene.
These toxic substances are h~ghly mobile in soil and could potentially migrate into
ground water.
The Ellisvil1e Area site is underlain by a limestone bedrock unit
known as the Bur1ington-Keokuk (B-K) Formation having a thickness of approximately
170 feet in the region. This bedrock exhibits high water permeability along
solution-enlarged joints. The pattern of these joints is generally random
and highly unpredictable. In consequence, surface water flows into the bedrock
(ground water recharge) and reappears on the surface (ground water discharge)
at other locations. At the Rosalie property, this bedrock is overlain by approximately
25-30 feet of moderately permeable soil. The bedrock at the Callahan property is
overlain by approximately 5-10 feet of moderately permeable soil. Depth to ground
water is estimated to range from 70 to 140 feet at the Callahan site and from near
surface to 150 feet at the Rosalie site. The bedrock aquifers receive substantial
recharge from infiltration and percolation of precipitation. The lower Fern Glen
Formation underlying the B-K formations may act as a aquitard because of its relative
impermeability.
~
Both the Callahan and Rosalie properties are located in the 18.72 square
mile Caulks Creek watershed. Caulks Creek has been classified as a losing
stream by the Missouri Department of Natural Resources/Division of Geology
and Land Survey. Some of its tributaries also appear to. be losing streams.
Due to the losing nature of the streams, water can disappear from the stream
bed and either reappear at the surfac~ or interflow with ground water. Through
this mechanism, contaminants which are introduced into Caulks Creek are likely
to enter the highly permeable alluvium in the bed of Caulks Creek and, hence,
enter the ground water. .
Ground water is an important resource of the region. It was estimated in 1982
that there were 70 wells in the Caulks Creek watershed, some of which are used for
potable water supply. Many domestic wells reportedly exist in the vicinity of the
El1isvil1e Area site. Some of these wells utilize the B-K or Fern Glen Formations
as their source of potable water. By the processes described above, contaminants
which enter Caulks Creek and its tributaries could potentially result in the
contamination of private domestic wells in the area. As a secondary pathway,
contaminants in contact with the B-K formations or their residuum and exposed to
water through fluctuation of the water table, local saturation during periods of
heavy runoff, or infiltration, are likely to enter the ground water.
ENFORCEMENT
Initially, Regional enforcement efforts were directed toward securing.
responsible party cleanup of each of the three properties comprising the Ellisville
area site simultaneously. Following identification of the site, a responsible party
search was conducted. Information obtained as a result of the search was forwarded
,.' . " ....
-------
7
to EPA Headquarters, and on December 21, 1981, notice letters were sent to
potentially responsible parties (PRPs). The PRPs identified as of that date with
respect to the Callahan site included the site owner, Jean Ellen Callahan;
transporter and di sposer of the wastes, Russell Marti n B 1 i ss, Jerry-Russell Bl i ss,
Inc., and American Can Company. Rosalie site PRPs notified were: former site
owner, Houlihan Nursery Company; present owner, Rosalie Investment Company;
transporter and disposer, Grover Callahan; and, Russell Martin Bliss, Jerry-Russell
Bliss, Inc., and American Can Company.
In the interim between the transmittal of PRP information to EPA Headquarters
and issuance of the notice letters on December 17, 1981, MDNR requested EPA
assistance to complete cleanup of the Callahan site. At the request of the
On-Scene Coordinator for the site, on December 28 and 29, 1981, the Office of
Regi onal Counsel contacted each of the Callahan site PRPs to advise them of the
necessity for immediate action to complete site cleanup and of the Agency's intent
to undertake such action absent their willingness to do so. All parties contacted
declined to undertake the response. Additionally, the site owner refused to
grant permission for access to the site. Consequently, on December 31, 1981, a
warrant for access was obtained from the United States District Court. Extensions
of the warrant were obtained on January 14, 1982, and February 5, 1982, as the
number of drums encountered during the removal action continued to exceed the
OSC's estimates. Upon completion of the response, the site owner was given a
receipt for all samples collected. On February 26, 1982, at the request of the
site owner, portions of all samples collected at the site were provided.
PRP Negotiations
Both during and after completion of the Immediate Removal, several meetings
were held with PRP generators of the wastes at the site to discuss possibilities
for settlement of their liability. (As a result of information obtained during
the Immediate Removal action, Kisco Company, Inc., The Orchard Corporation of
America and GK Technologies, Inc., were identified as additional PRPs.) These
negotiations failed to result in an acceptable offer of settlement.
..
Negotiations for responsi.ble party cleanup of the Rosalie site have been
conducted by the State and are ongoing. During a meeting with State officials
on June 28, 1985, Rosalie Investment Company offered payment of a fixed sum
toward future remedial action at the site. These negotiations will continue for
a period not to exceed thirty (30) days following approval of the Record of
Decision by the Regional Administrator.
Civil Actions
On August 30, 1981, a civil action for cost recovery was filed on behalf of
EPA in the United States District Court for the Eastern District of Missouri
[No. 84-2086(1)]. The action seeks reimbursement of $458,551.00 for actual costs
and expenses incurred by the government for response actions at the Callahan
site and a declaratory judgment for future costs and expenses. The case has been
consolidated with three cases filed by the State of Missouri for recovery of State
funds expended at each of the three Ellisville Area Site properties.
ALTERNATIVES EVALUATION
After completion of the Remedial Investigation, work on a Feasibility Study
began. The final version was dated September 28, 1983. The objectives of the
-------
,,",
. '.
8
Feasibility Study included the identification of remedial action objectives,
identification of remedial action alternatives and the selection of the most
effective remedial action alternatives for implementation at the E11isvi11e
Site.
A.
Rosalie Site
the
cost-
The remedial action objectives for the Rosalie property are to remove
drums, cans and debris from ELL-02, ELL-03 and ELL-04 and either (l) reduce the
concentrations of priority pollutants in soil at ELL-Ol and ELL-02 or
(2) remove the contaminated soil from ELL-Ol and ELL-02.
Table 3 of the Feasibility Study (Attachment C-l) lists remedial technologies'
for the contaminated soil, buried drums, cans and debris on the Rosalie property.
Table 3 also indicates whether the technology is appropriate for the Rosalie
property and the reason if it is not appropriate. All of the listed remedial
technologies are consistent with technologies presented in the National COMtingency
Plan (40 CFR 300.70) pertinent to the remedial action objectives.
An initial screening of the remedial technologies identified as appropriate in
Table 3 for the Rosalie Investment Company property was performed in consideration
of order of magnitude costs, effects of the alternative and acceptable engineering
practices. The number of alternatives was narrowed to four following the initial
screening.
Alternative
Estimated
Capital Cost
None
R-l:
R-2:
No Action
$97,000
Onsite biological treatment of contaminated soil
and off-site disposal of debris and buried drums.
Onsite disposal
$200,000
. $52,000
R-3:
R-4:
Offsite disposal
~
A detailed analysis of these four remedial alternatives was performed following
the initial screening. The following criteria were used to evaluate each of the
remedial alternatives during the detailed analysis:
-Probable cost
-Significant adverse environmental effects
-Adequate control or effectiveness
-Reliability
-Implementabi1ity
-------
9
-Operation and maintenance requirements
-Safety and regulatory requirements
-Public acceptance
In order to develop the alternatives and the evaluation criteria information,
it was assumed that the lateral extent of soil contamination was 360 sq. ft. at
ELL-Ol and 1,450 sq. ft. at ELL-02. The number of buried drums was assumed to
be 15.
The four remedial alternatives were evaluated in detail for the Rosalie Site.
These alternatives are summarized in Table 2 of the Feasibility Study
(Attachment G-l). Capping was not considered beyond the initial screening because
this alternative would be ineffective at remedying the threat posed by the buried
drums at ELl-02 and contaminated soil in the stream bank at ELl-Ol. Measures to
stabilize and contain the stream bank at ELL-Ol in combination with capping would
. prove far more costly than the alternatives evaluated in detail and would not
remove the contamination and threat of release. Alternative R-1 (no action)
would not remedy existing conditions which have the potential for causing
adverse environmental and public health effects. The results of the Remedial
Investigation indicated that the organic priority pollutant concentration in
the soil had not significantly decreased since July 1981. Also, the buried
drums would be left in place. The possibility of surface, ground and drinking
water contamination would still exist' from the contents of the drums. Alternative
R-2 (onsite biological treatment of contaminated soil using landfarming techniques
and offsite disposal of buried drums, drum lids, cans, and other debris), has
the second highest probable cost. There currently exists no type of biological
treatment which has been proven effective for the specific contaminants and
conditions present on the Rosalie Investment Company property. Development of
biological treatment technology would be costly and could prove ineffective.
Alternative R-3 (onsite disposal of contaminated soil, buried drums, cans,
metal fragments and trash in a secure landfill on the Rosalie property) has the
highest probable cost~ It would involve location of a landfill in a questionable
geologic setting. It also would require long-term monitoring and maintenance.
Alternative R-4 (offsite disposal of contaminated soil, buried drums, cans,
metal fragments and debris) has the lowest probable cost and would provide the
greatest benefit to public health and the environment. It would be the most
acceptable to the public and would have no long-term maintenance or monitoring
requirements. It is, therefore, recommended that Alternative R-4 be implemented
as the remedial action for the drums, cans and contaminated soil on the Rosalie
Investment Company property.
.
B.
Callahan Site
Remedial technologies for the unstable fill area on the Callahan property
are listed in Table 1 of the Feasibility Study (Attachment C-2) All, except for
in-situ mass soil stabilization, are technologies presented in the National
Contingency Plan (40 CFR 300.70) pertinent to the remedial action objectives.
Table 1 indicates whether the technology is appropriate for the Callahan propert~'
and the reason if it is not appropriate.
-------
10
A no-action alternative for the Callahan property was not evaluated in the
Feasibility Study. This alternative will be discussed in this section of the
. Record of Decision. During the Remedial Investigation, core samples were
collected from the Callahan fill area and surface soil and water samples were
collected downgrade of the fill area. Results of analyses of these samples
were presented in Tables C-3 and C-4 of the Remedial Investigation and are
presented in Attachment H. Priority pollutant contaminants detected on the
Callahan site during the Remedial Investigation include bis(2-ethy1hexyl)
phthalate, PCB-1254 and f1uorotrichloromethane. Numerous other organic priority
pollutant compounds were tentatively identified on the site. In addition, a
composite sample of the fill area and a fill runoff sample were collected.
during the 1981-82 removal action. Contaminants detected in these samples
include 2,4-dimethylphenol, phenol, napthalene, nitrobenzene, bis(2-ethylhexyl)
phthalate, di-n-octyl phthalate, ethyl benzene, toluene and tetrachloroethylene.
These results are presented in Attachment I. Contaminants detected on the
Callahan property constitute a release to the environment. The Feasibility Study
concludes that if stabilization of the fill area is not provided, erosion of
the fill material will continue to occur. This erosion will enter the drainage
way at the base of the fill and will result in continued offsite migration of
hazardous substances. Due to this consideration, the no-action alternative was
not selected for the Callahan fill area.
~
Both remedial alternatives evaluated for the Callahan property include.
removal of vestiges of the 1981-82 removal action. This action is required due
to a commitment made to the site owner to restore the property following removal
activities.
An initial screening of technologies identified in Table 1 as appropriate for
the Jean Ellen Callahan property was performed in consideration of order of
magnitude costs, effects of the alternative and acceptable engineering practices.
A detailed analysis was then performed on the following two remedial alternatives
using evaluation criteria presented above for the Rosalie Property alternative:
Estimated
Capital Cost
Alternative
C-l:
C-2:
Immediate Removal Action Closure
$6,000
$12,000
Fill Stabilization, Erosion Control
and Immediate Removal Action Closure
Both of the alternatives include onsite activities to remove the vestiges
of the immediate removal action. These onsite activities include the following:
-Removal and disposal of the plastic cover remnants over the fill area.
-Removal and salvage of the barbed-wire fence around the fill area.
-------
11
-Removal and salvage of the chain-link fence around the two drum
storage areas.
-Removal and possible salvage of the gravel in the two drum storage
areas.
The additional feature of Alternative C-2 is:
-Stabilization and erosion control measures for the soil mass in the fill area.
A comparison of the two alternatives appears in Table 4 of the Feasibility
Study (Attachment 6-2). In evaluating the two alternatives, alternative C-1
would not eliminate slippage a~d erosion of the soil mass in the excavated and
backfilled area. Alternative C-2 addresses this problem along with the need
for general closure activities which are common to both alternatives. The soil
mass would be spread over a larger area at its present location and graded to a
stable slope. A layer of top soil would be spread to a six inch depth over the
area and compacted. The area would then be seeded to control further erosion.
Selection of this remedial alternative will have no required operation and
maintenance. Alternative C-2 is more costly than Alternative C-l, but its
implementation would eliminate the potential for continued offsite migration of
hazardous substances. It is, therefore, recommended that Alternative C-2 be
implemented as the Remedial Action for the Callahan property.
.
COMMUNITY RELATIONS
The RIfFS for the Rosalie and Callahan portions of the E11isvi11e Area site
was released for public comment in July 1984. Announcements were published in
St. Louis area newspapers. On August 9, 1984, a public hearing was conducted at
the St. Louis County Library, Daniel Boone Branch, 300 Clarkson Road, El1isville,
Missouri, to describe the remedial alternatives for the Rosalie and Callahan
properties and the recommended remedial alternatives for site cleanup. Following
the presentation of alternatives, attendees were allowed to comment orally upon
the proposed remedial action. No opposition was voiced against the proposed
actions or their associated costs. Written comments were accepted until August 17,
1984. None were received. A responsiveness summary has been prepared by the
State (Attachment E). Citizens generally expressed a desire to allow state and
federal officials to take the necessary actions to clean up the site such that it
would pose no adverse effects to them or their children. They expressed concern
about obtaining the necessary formal approval from EPA Headquarters in Washington,
D.C., to implement the proposed Remedial Actions. Many wanted to know when
federal officials would endorse the action. Overall, citizens reacted positively.
We believe that implementation of alternative R-4 (offsite disposal)
will satisfy the concerns of citizens at the Rosalie Site. It has the
lowest probable cost and would provide the maximum benefit to the public. We'
believe that implementation of alternative C-2 will satisfy the concerns of
citizens at the Callahan site. It will correct the physical instability of the
-------
12
backfilled soil mass and remove the vestiges of the 1981-82 Immediate
Removal action. We believe that citizen concerns will be satisfied if the two
recommended methods for site'cleanup are implemented.
CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS
The recommended Remedial Action at the Rosalie and Callahan properties
involves offsite disposal of hazardous substances which pose a threat of
release into the environment. The offsite disposal will be performed in
.accordance with current CERCLA offsite policy which requires the use of a
recently inspected commercial disposal facility operating with an appropriate
RCRA permit or interim status which has no significant violations or other
environmental conditions which affect the satisfactory operation of the facility.
Contaminant levels at the Rosalie and Callahan.properties will not be
restored to background levels. However, the Centers for Disease Control has
advised that the contaminant levels which are anticipated to remain following
the Remedial Action do not represent a threat to public health. The substantial
threat of a release into the environment will be greatly reduced. Removal of
all contaminated material to achieve background concentrations in the soil would
result in a cost that is disproportionate to other alternatives and would not
provide a balance between the need for protection of public health, welfare and
the environment with the amount of money available in the Fund to respond to other
sites.
~
RECOMMENDED ALTERNATIVE
Section 300.68(j) of the National Contingency Plan (NCP) [47 FR 31180,
July 16, 1982] states that the appropriate extent of remedy shall be
determined by the lead agency's selection of the remedial alternative which
the agency determines is 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 or the environment. Based on our evaluation of the cost effectiveness
of each of the proposed alternatives, the comments received from the public,
information from the Remedial Investigation and Feasibility Study Reports. and
information from the State, we developed Alternative R-4 for the Rosalie site
and Alternative C-2 for the Callahan Slte.
The selected Remedial Action at the Rosalie Investment Company Property
involves excavation and offsite disposal of contaminated soil and buried drums
at Locations ELL-01 and ELL-02, and removal and offsite disposal of drum lids,
cans and other debris at locations ELL-02, ELL-03 and ELL-04. All onsite
activities will be carried out in accordance with a site-specific Site Safety Plan
developed during Remedial Design. Approximately twenty-seven (27) cubic yards of
contaminated soil will be excavated from Location ELL-01 extending over an area
of 360 square feet and to a depth of two (2) feet. An.estimated 15 drums and
215 cubic yards of contaminated soil extending over an area of 1450 square feet
-------
-..>
13
and to a depth of four (4) feet will be excavated from Location ELL-02. 50i1
samples will be collected from the perimeter and bottom of the excavations in
order to determine contaminant. levels which remain at Locations ELL-O! and ELL-02.
This sampling will be performed in accordance with a sampling plan developed
during Remedial Design and approved by the Centers for Disease Control (CDC).
These soil samples will be analyzed for priority pollutants and the analytical
results provided to CDC for assessment. If CDC determines that contaminant
levels remaining onsite do not represent a threat to public health, then the
excavations will be backfilled and reseeded. If CDC recognizes a remaining
threat to public health, the contract will be modified to allow for the additional
required excavation. Soil sampling will again be performed in accordance with a
plan approved by CDC, and analytical results will be provided to CDC for assessment.
This process will be repeated until CDC determines that a threat to public health
no longer exists. All excavated soil will be transported in bulk to a commercial
hazardous waste land disposal facility operating under an appropriate RCRA permit
or interim status and meeting current CERCLA offsite policy, or if cost-effective,
to a commercial hazardous waste incineration facility operating under an appropriate
RCRA permit or interim status.
Results of soil sampling conducted during the Remedial Investigation have been
reviewed by the Centers for Disease Control (CDC). CDC has advised that on the
basis of the information presented in the Remedial Investigation, there does not
appear to be a threat to public health due to soil contaminants detected at
ELL-02 or those detected below a depth of two feet at ELL-OI. For this reason,
it is not anticipated that additional excavation will be required beyond the
240 cubic yards specified, if subsequent sampling confirms the soil conditions
which were determined during the Remedial Investigation. However, subsurface
conditions were not completely defined in the Remedial Investigation, and some
possibility does exist that additional excavation may be required.
.
Excavation of buried drums at Location ELL-02 will proceed concurrently with
soil excavation. When possible, duplicate samples will be collected from each
of the excavated drums. One sample from each drum will be analyzed for priority
pollutants and RCRA hazardous waste characteristics. Following sampling, each
drum will be overpacked in as-gallon recovery drums and temporarily stored onsite
in a secured drum holding area until receipt of analytical results. Drums containing
liquids will be disposed of by incineration at a commercial hazardous waste
incineration facility operating under an appropriate RCRA permit or interim status.
Drums containing solids will be disposed of at a commercial land disposal facility
operating under an appropriate RCRA permit or interim status and meeting current
CERClA offsite policy, or if cost-effective, at a commercial hazardous waste
incineration facility operating under an appropriate RCRA permit or interim
status. Drums observed to contain non-hazardous substances or wastes (i.e., trash,
garbage, debris, empty cans and other non-hazardous materials) may be disposed of
at a permitted sanitary landfill. Drum lids, empty cans and other debris collected
from locations ELl-02, Ell-03 and ELL-04 will be deposited in 55-gallon drums.
These drums may also be disposed of at a permitted sanitary landfill. Copies of
analytical data for sampled drums will be provided to the appropriate disposal
facility.
-------
14
The offsite disposal of hazardous wastes at the Rosalie property meets
the requirements of CERCLA Section 101(24). The alternative has been demonstrated
to be more cost-effective than the other alternatives, and is necessary to protect
public health, welfare and the environment from a present risk. Operation and
maintenance requirements for this alternative will be the responsibility of the
offsite permitted disposal facility. A breakdown of the capital costs appear in
Attachment 0-1. Alternative R-4 achieves the most reliable and effective
protection of public health and environment at the lowest relative cost.
Alternative C-2 (Jean Ellen Callahan Property) will implement a Remedial
Action to control erosion and slippage of the fill area where drums were excavated
during the 1981-82 Immediate Removal and remove the vestiges of that action. The
remnants of the plastic cover over the fill area and the cover's hold-down blocks
will be removed and disposed of. The soil in the fill area will be regraded to a
stable slope over a larger area, and covered with a 6 inch soil layer which will
be compacted and reseeded. The barbed-wire fence around the fill area and the
chain-link fence around the two drum storage areas will be removed and salvaged.
The gravel in the two drum storage areas will be removed for possible salvage.
The preliminary opinion of probable cost for this remedial action is $12,000.
Implementation of this alternative will result in no operation and maintenance
requirements. A breakdown of the capital cost estimates appears in Attachment
0-2. .
..
After giving careful consideration to the cost effectiveness of each
alternative and evaluating the public comments received, the Missouri Department
of Natural Resources recommended the following two alternatives: Alternative R-4
involving off-site disposal of contaminated soil, buried drums, cans and debris
at the Rosalie Investment Company Property and Alternative C-2 involving
stabilization and erosion control measures for the soil mass in the Callahan fill
area and removal of the vestiges of the Immediate Removal. A letter confirming
the State's decision appears on Attachment F.
OPERATION AND MAINTENANCE (O&M)
Recommended alternatives at the Rosalie and Callahan sites will require no O&M
activities.
SCHEDULE
Date
Approve Remedial Action (Sign ROD)
Amend/Award Cooperative Agreement for Remedial Design/
Remedial Action
June 21, 1985
August 2, 1985
Procure Design Contractor Under Class Deviation
September 6, 1985
November 29, 1985
Complete Design
Procure Construction Contractor
March 14, 1986
-------
15
Initiate Construction
March 28, 1986
Complete Construction
June 27, 1986
FUTURE ACTIONS
The recommended alternatives at the Rosalie and Callahan sites will constitute
a final action. All vestiges of past remedial activities and all materials posing
a threat to public health, welfare, or the environment will be removed from the
properties. No. future remedial activities are anticipated.
-------
ATTACHMENTS
<,
~
-------
."
-
(j)
c
;;0
rr1
SOURCE OF MAP'
MISSOURI HIGHWAY AND
TRANSPORTATION DEPT.
-------
went A-2
. , .
..
. ,
. ,
"
F.JwnE 2
"
-------
:
Rosalie Investment Company
Property
5.2 DATA ASSESSMENT
Organic compound analyses were performed by MeadCompuChem on the 16 soil
s<1.mples, the surface water sample, the background soil sample, and tpree
. field blank ,samples. The results of these~, analyses and field measure-
ments are tabulated in Appendix R of Vol~~e II. In addition, a special
analysis for 2,3,7, 8-TCDD was. performed by Envirodyne Engineers on a
composite of' the soil samples collected from the Rosalie Investment
Company propert.y. No 2,3,7,8-TCDD was detected in that'sample at a
nominal detection level of 1 part per billion. . . .
J
"
5.2.1 ILl-O"!
... .
~ .
As presented in' Table R-4, six priority pollutant organic compounds were
detected in the subsurface soil samples from Ell-01: 2, 4-dimethylphenol.,
phenol,' naphthalene: ethylbe~zene, methylene chloride, and toluene. Two
non-p'riority pollutant compounds were detected and several other
compounds were tentatively identified in the soil samplesj these
. compounds included listed hazardous materials such as o-xYlene, m-xylene,
and oxirane. In general, the soil samples collected from the 0-1 foot
and 1-2 foot depth ranges had higher measured concentrations of organic
compounds than the deeper soil samples. Ithylbenzene and o-xylene were
detected in bqth the subsurface soil samples collected at ElL-01 and the
surface water sample collected downgrade of ILl-01 and ElL-11.
ILl-Ol is located in a drainage ditch. The measured ~on;entrations of
\ phenol and naphthalene in upper 2 feet of the ditch bed were 40,000 and
.50,000 ppb, respectively. Layers of organic waste materials were
observed in the ditch banks where undercutting had occurred. The
analytical data indicate some migration of organic compounds has
occurred.
<;
.
5.2.2 ELl-02
:
Exposed drums containing trash and exposed drums having unknown contents
were observed at Ill-02. As ind£cated in Table R-6j thirteen priority
pollutant organic compounds were detected in the soil samples collected
at this location:
2,4-dimethylphenol
phenol
naphthalene
bis(2-ethylhexyl)phthalate
benzene
chlorobenzene
1,l,2-trichloroeth~ne
ethylben%'ene
methylene chloride
fluorotrichloromethane
tetr3chlorethylene
toluene.
trichloroethylene
The actu~l presence of methyle~e chloride and fluorotrichlorome~h~ne in
these samples is suspect, because the measured concentr~tions of these
compounds were less than th~t o~ the field blank samples.
-------
,Page 2
tight non-priority pollut.ant. organic compounds ~ere detected and many
other ,compounds were tentatively identified in the soil samples. These
compounds included listed in hazardous materials such as:
. --,.. :! .0':' ; : :0'.. t" . ...;':':
. .., . .
. .' .
'.. : '.:~.. :',1..:.-...
J
acetone .
methyl ethyl ketone (2-butanon,e) :.
4-met.hyl-2-pent.anone .
o-xylene
m-xylene
'I,3-diisocyanatomethylbenzene
I-butanol
2-but.anol
2-methyl-1-propanol
"
, '
':
';
In ge,neral, more, organic. compounds were detected or tent.atively
ident.ified at higher measured concentrations in tbe soils samples
collected from the 2-3 foot and 3-4 foot depth ranges than in the ,t'Wo
,shallower soil samples and in the soil sample from tbe 1-2 foot depth
range than in the shallowest soil sample. Only three compounds were
detected or identified at low concentrations in the shallowest soil
sample (0-1 foot. depth range). The actual presence of two of these
three compounds (methylene chloride. and fluorotrichloromethane) is
suspect, as stated earlier. "
-
Methylene chloride was detected and cyclohexane and octacosane we!'e
tentatively identified in the sediment sample collected ..from tbe pond
(ELL-OS) downgrade of ELL-02. As stated earlier, the actual presence of
met.hylene chloride in this sample is suspect. The other two organic:
compounds were not identified in the soil samples obtained from ELL-02~
ELL-02 is located in a drainage way. The analytical data does not
'indicate the past occurrence of or the potential for migration of organic
compounds due to surface water transport. Different compounds were
found in the downgrade pond sediment sample than at ELL-02. Soil. in the
layer most susceptible to erosion at ELL-02 was not contaminated.
~owever, tbe concentration~ of phenol and naphthalene measured in soil ;,
samples collected ,below I-foot depth were 16,000 and 5,600 ppb,
respectively. '
5.2.3 ELL-03
Several I-gallon cans and scattered drum debris were observed at ELL-03.
As presented in Table R-8,. nine priority pollutant organic compounds
were detected in the soil samples collected at this location:
bis(2-ethylher/l)pbth~l~te
benze:te
t=~as-l,2-dichloroethene
. ethylbenzene
methylene chloride
fluorotrichloromethane
tetr~chloroethylene
toluene
t=ichloroethylene
-------
..-
Rosalie Invest:m:mt Ccrrpany Property
Page 4
.'
5.~.6 Summary.
The following hazardou~.' waste related problel"1s were identified on the
Rosalie Investment Company property:
Location
ELL-Ol
J ELI.-02
ELL-03
. '.
ELL-04
.'
,.
\ '
)' ,
.0
) ,
..
. '
.. -, ..~ :.... I :.".'
~. .,
..
Ellisville Site
Remedi~l Investig~tion
Pages 33-37
"
Contaminated soil susceptible to erosion
Drums and contaminated soil
I-gallon cans and drum debris
~ 5-gallon cans
o
" .
.'
. .
~ .
- ,
00
., .
.
..
.
.
09/21/83
-------
j"\I.I.c..,-.."j;:',... :J-,
Off-Site Investigation
6.,2 DATA ASSESSIiENT
Organic' compound analyses were p~rformed by Caiifornia Analytical
laboratories, Inc. on the ground water samples from four drinking water
wells, the five Caulks Creek water samples, and a field blank sample. In
addition, the four:i drinking water samples and the blank sample we:e
analyzed for priority pollutant and other metals by Rocky Moun~a1.n
Analytical laboratories, Inc. The results of these analyses and f1eld
measurements are tabulated in Appendix N of Volume II.
6,2.1 Groundwater Samples
"
"
J '
As indicated in Tables N-2 and N-3, no organic compounds and only three
metals (boron, iron, and zinc) were detected in the ground water samples
from the four drinking water wells, Of the three metals dJtected, only
zinc is a priority pollutant; iron and zinc are covered by the National
Secondary Drinking ~,Water Regulation. The concentrations of iron and
zinc, measured in the samples were less than the secondary maximum
contaminant levels. In comparison to analytical results for samples
collected by others in .June' 1981 and .January 1982, these analyt;i.cal
results indicate that the ground water quality at the four wells is
unchanged or improving,
,6.2.2 :Caulks Creek Samples
.'
... #
Six priority pollutant organic compounds'--dibutyl phtha.late, 'methylene
chloride, tetrachloroethylene,' aldrin, heptachlor, and _lindane--were
detected in the samples of water collected from Cauiks Creek, as
presented in Table N-S. Four of these--dibutyl phthalate, methylene
chloride, tetrachloroethylene, and lindane--were detected in the water
sample collected from Caulks Creek upstream of the Ellisville site
(ELL-9S); in the downstream samples, the concentrations of these
compounds were essentially the same as in the upstream sample or these
compounds were not detected., Aldrin and heptachlor were detected in the
, wa ter sample collected from Caulks Creek downstream of the confluence
with the Callahan property drainage way (ELL-96), but were not detected
in the other upstream or downstFeam samples. This could indicate the
Callahan property as the source lor the aldrin and heptachlor; however,
these compounds were detected in the samples collected from the Callahan
property.
The concentra tions of lindane measured in four of ttie Caulks Creek
,samples (the exception being the sample c.ollected downstream of Lewis
Spring) were in excess of the EPA 24-hour average criterion to protect
freshwater aquatic life. The concentration of heptachor in the sample
collected at Ell-96 exceeded the EPA 24-hour average criterion for
freshwater aquatic life protection, while the concent.r:1tion of dibiityl
phthalate exceeded the E?A criterion for chronic toxicity to freshwater
aquatic life. Howe'ler, these conce:1tr:1tions were less t~:1n the EPA
m:1xi~um or acute toxici~J criteria.
Based on the collected evideac=, the Ellisville site is not cont:1mi~:1ting
ne:1rby dri:lking W:1ter wells and C:1U~k..~ Creek.
\Ellisville Site
Re~edi:11 Investig3tion
Pages 39-40
09/21/83
..." -
J
.
.; C:
..
-
"
,.
-------
-. _I... u u 1.8 J j .:. ~ J
we.. ~ I; c..~~CJ~.
:. Ur-'t.::. -J
"
4.2 DATA ASSE,SS~!ENT
, .
Organic compound analyses were perf~rmed by MeadCompuChem on the seven
. soil/sediment samples, two water samples, and three 'field blank samples.
The results ol these analyses and field measurements are tabulated ir,~
'Appendix Cof:Voluroe II. In addition, a special analysis for 2,3,7,8-:
TCDD was perf~~ed by Envirodyne Engineers on the composi~e soil s~mple;
collected from the fill area (ELL-21).
4.2.1 Fill Area
J As indic~ted in Table C-3, the only priority'pollutant detected in the
composite soil sample collected,from the fill (ELL-21) was bis(2-ethyl-
hexyl) phthalate. The phthalate con~entration in this sample was 13,000
. ppb. The phthalate, concentration represents a total of about 13 pounds
of the.compound in ~he 300 cubic yard fill. No 2,3,7,8-!CDD was detected
. in the sample at a nominal detection level of 1 part per' billion. '
Cyclohexane, a listed'hazardous material, and other tentatively identi-
fied organic compounds were also found in the soil sample from the fill.
The evidence indicates the fill material is not contaminated.
Bis(2-ethylhe~/1)phthalate was also found, along with PCB-1254, in the
composite soil sample collected from a band 5 feet outside the fill
(ELL-22). The concentrations of the phthalate and PCB in this sample
were 1,400 and 189 ppb, respectively.- 'No priority pollutant organic
compounds were detected in the composite soil sample co+lected from a
band 15 feet outside the fill (ELL-23). The results of the organic
compound analyses on these samples indicate that very little lateral
. migration of organic compounds from' the fill has 9ccurred into the
Ldjacent valley walls.
I- .: .
'-4.2.2 Downgrade of Fill Area
The organic compound analysis results
water samples co11ec~ed downgrad,e of
C-4.
.
for the two soil/sediment and two
the fill are presented in Table
. .. . .
. '
Bis(2-ethYlhexyl)ph~ha1ate and fiuorotrichloromethane were the only
priority pollutants detected in t.ne soil/sediment sample collected in
t.he drainage way about. 20 feet downgrade of the fill (ELL-24). The
actual presence of f1uorotrichloromethane is suspect because the measured
concentration was less than that found in a field blank sample. Similar
concentrations of bis (2-ethylhexyl)'Phthalate were found in' the soil
samples collected from the fill (tLL-21) and 20 feet downgrade of the
filL Th'e tentatively identified compound 1,3,5-cyc1oheptatriene was
found ~n the samples collected at both ELL-21 and ELt-24j however, the
measured concentration of this compound in the sample collected 20 feet
downgrade of the fill was about 1 percent of th~t in the sample from'the
fill. Cyclohe~ane was identified in the sample from the fill, while an
oxid~tion product of th~t compound--cyclohe~~nol--was identified in
s.1mple collec:ed 20 feet. do\~grade of the fill. A listed h.1Z:1rdous
materi~1--1,3-diisocj~n.1tomethylbenzene--and other tent.1tively identi-
fied org.1nic compounds were also found in the sample collected at £Ll-24.
.. . . .
'-
-------
Jean Ellen Callahan Property
Page 2
~ -
Similar to the sample from E1L-24, bis(2-ethylhexyl)phthalate and
fluorotrichloromethane were the only priority pollutants detected in ,the'
soi1/sedim~nt sample collected in the drainage way about 180 feet d(~~-' "
grade of t~e, fill (ELL-25). As before, the actual presence of f1uQ~o-
trichlorome~hane is suspect. The measured concentration of the phthalate
in the sample collected at ELL-25 was about 7 percent of that in the
samples collected upgrade at ELL-21 and ELL-24.
No organic compounds were detected or identified in the surface or
Jal1uvial water samples collected from the creek at two locations
downgrade of the fill's drainage way (Ell-26 and ELl-27).
'~
"
These data indicate that some migration of organic compounds from the
, . . fill ha.s occurred. :This is probably due to surface water transport of
soil particles eroded from the fill. The data indicate that the extent
of migration has not reached the creek which drains the Callahan
propert.y.
4.2.3 Drum St~rage Areas
, ,
The organic compound analy'sis results for the two soil samples obtained
from the two drum storage areas are present.ed in Table C-5. Three
priority poll~tant organic compounds=-isophorone" bis (2-ethylhexyl)
phthala te, and methylene chloride--were detected in the ,two.. soil samples. '
Two listed hazardous materials--oxirane and m-xylene--and other
tentatively ,ident.ified compounds were also found in the soil sample
obtained frOID the west drum storage area.
-
,- ..
"'
4.2.4 Summary
Based on the" analytical results, there are no contaminated soils on the
Jean Ellen Callahan property. .' ..
"
.'
...
Ellisvi11e Site
Remedial Iavest.ig3tioa
Pages 28-30
09/21/83
. . -\.- ';. . ."..-.:! .
-------
Depth Cft):
SaDlple No.:
Traffic Report:
nate:
Detection Limit*:
Priority Pollutant Compound!
Ad d Compounds:
2,4-dimelhylphenol
phenol
oLher acid compounds
Base/Neut ral Compounds:
naphthalene
other base/neutral compounds
VohUlea:
ethyJbenzene
.ethylene chloride
toluene.
other yohti les
Pesticides:
Dlo;.;!ns:*
Non-Prlorlt~utant Co.pound.
Ad d COMpounlls:
4-lIethylphenol
other acid compounds
. ..- _.---- ...- --'.'.------- -_._. ....- --."----- ---.-....... .-.. . '0'
. .-....-. --- ..----.
...- ..- - -. ._--
..--..-----_u..- --.--
TABLE R-4 (Page 1 of 3)
ELLJSVIJ.T.E SITE: ROSAtlE PROPERTY
ORGANTC COMPOUND ANALYSIS RESULTS FOR ELL-OI AREA SAMPT.ES
Cue: 1434 Laboratory: Mead CompuChem
(See Table R-12 for list of analyzed compounds and detection limits)
,=
Soil concentration in parts pel' billion Cpp") wet basis
Water Concentration in
micrograms pe~ litre (ug/L)
0-1
ELt-Ol-SS-01
T1765
1/11/83
(1)
1-2
ELL-OI-SS-02
TI766
1/11/83
(I)
2-3
ELJ.-O I-SS-03
T1767
1/11/83
(1)
3-4
F.T.t-O l-ss-04
TI768
1/11/83
(2)
ELt-ll-SW-Ol
T1777
1/14/83
(3)
nd** 4,800 nd* nd ntf
16,000* 40,000 nd** nd IIlI
nd',Hr nd n,I-:'"* nd nd
I
38,000 56,000 nil nd nd
nd nd nd nd nd
nd 1,600 nil .' nil 6.2
nd 270 32 11,000 nd
250 580 nd nd nr!
nr! . nd nil nd nr!
nd nd nd nd nd
nd nd nd nd nd
7,800*
nd-:'-k
ndH
nd*
nd
lid
nr!
nr!
18,000
nr!
-------
Depth (ft):
Sample No.:
Tuffic Report:
Date:
Detection Limit*:
Non-Priority 1'0lJutant Compounds
Bue/Neutral Compounds:
Vohtilea:
o-xylene
olher vohtiles
Tentatively Identified Compound.
l-ethyl-2-methylhenzene
2-ethyl-l,4-dimethy1benzene
I,J-dimethylbenzene (m-xylene)
1,2,J-trimethylbenzene
1,2,4-trimethylbeozene
I,J,S-trjmethyJb~nzelle
benzofllun
7-methylbenzofuran
methyl cyclohex.o~
2-lIelhoxyethallol
- _____0_-
..., . ... . ~..." ".-
. -- .--..-..- .-----._--
;,
TABLE R-4 (Page 2 of 3)
ELttSVILLE SITE: ROSALIE PROPERTY
ORGANIC COtll'OUND ANALYSIS RESULTS FOR ELL-Ol AREA SAMPLES
Cue: 1434 I.sboratory: Head C!!mpuChem
(See Table R-12 for li8t of an.lyzed' compounds and detection limits)
..
"
'..
Soil concentration in parts per billion (pp") wet ba8f8
Uater Concentration i" ~
~grams per Ii tre (ug/L) .
0-1
[LL-Ol-SS-01
T1765
1/11/83
(1)
1-2
, £J.T.-01-SS-02
T1766
1/11/83
(1)
2-3
ELL-Ol-SS-03
T1767
1/11/83
(I)
3-4
F.U.-01-sS-04
T1768
1/11/83
(2)
f.J.T.-l1-SU..Ol
TI777
1/14/83
(3)
'."
nd nd nd nd n.1
4,800 5,800 nd ntf 23
lid nd nel nd ""
210 52,000 nf nf nf
nf 25,000 nf nf IIf
300 48,000 nf nf nf
nf 71 ,000 nf nf nf
460 nf nf nf nf
280 32,000 nf nf nf
nf 20,000 nf of nf
nf 52,000 nf nf nf
nf nf 860 nf nf
nf nf nf 8,600 IIf
-------
. ... ---.--...-_____'R ._.--_._._.._~. ....-.------ .--- ...-..- .,. -.-..-...
. ...... ----.-.- ..------.-..-.. ...
. .,.-...... -
..---._____RO -
. - . ...0
TADLE R-4 (Page 3 of 3)
ELtTSVIT.LE SITE: ROSALIE PROPERTY
ORGANIC COMPOUND ANAIXSIS RESULTS FOR ELL-Ol AREA SAMPLES
Case: 1434 f.abor.tory: Mead ComruChem
(See Table R-12 for liat of analyzed comrounds and detection limite)
Soil concentration in 'parte per hi 11 ion (ppb) wet buh
Depth (ft): 0-1 1-2 2-3 3-4
S'8Iple No.: !Lt-Ol-SS-0l ELI.-Ol-SS-02 P.tL-Ol-SS-03 ET.t-O I-SS-04
Traffic Report: T1765 T1766 T1767 T1768
Uate: 1/11/83 1/11/83 1/11/83 1/11/83
Detection tfmit*: (IL (1) (1) (2)
Tent.tlvely Identified Compound!
(2-methoxyethoxy) ethene nf nf nf 68,000
melhylester formic .cid nf nf nf 5,000
1,3,3-trimethyl-bicyclo(2.2.11hept.n-2-one 2,300 2,200 nf nf '
1,7,7-trimethyl-bicycloI2.2.I)heplan-2-one 3,300 nf nf nf
2,3-dlhydro-I"-indene 150 IIf nf nf
2,3-dlhydro-4-methyl-1lI-lndene 83 nf nf nf
lI'-indene nf 44,000 nf nf
benzonitrf1e nf 1,800 nf nf
oxlr.ne IIf nf nf 9,600
4-(1 ,I ,3,3-tetr.methylbutyl)phenol nf nf nf nf
3-phenyl-2-propell~1 220 nf nf nf
dimethyl disulfide nf nf nf nf
NOTES:
"'f)etect Ion 1 'ml t nllliber ci ted refers
't-:'-EPA Regioll 7 recolwended that data
nd Not detected
nf Nol found
to column nllmber in Table R-12
be rejected due to low surrogate recoverie.
I:
'"
0-
r
r
I'
r
Water Concentration in r
micrograms per litre (ug/L)f'
-- .
, r
ELT.-ll-5W-Ol
11771
1/14/83
(3)
l
II
.t
,
r
c
.
.
r
C
"
nf
nr
nf
nf
nf
nf
nf
nt
nf
71
nf
3.7
. .
-------
Priority Pollutant Compounds
Add Compounds:
2,4-dl~ethylphenol
phenol
other add compound.
Base/Neutral Compounds:
naphthaJene
bis (2-ethyJhexyJ) phthalate
other base/neutral compounds
VohtiJea:
benzene
chlorobenzene
1,I,2-trichloroethane
ethylbeuzene
methylene chloride
fluorotrichloromethane
tetrachloroethylene
toluene
trichloroethylrne
otller vohtiJes
.. . ...-__0""
---____n___-_-----"-- --.
.~.______n. ---
I:
TABtE R-6 (Page I of 4)
ELLISVILLE SITE: ROSALIE PROPERTY
ORGANIC COHPOUND ANALYSIS RESULTS FOR £1.1.-02 AREA SAtfPLES
Case: 1434 Laboratory: Head CompuChem
(See Table R-12 for Jist of analyzed compounds and detection
limits)
Depth (ft):
SampJe No.:
Traffic Report:
Date:
Detection Limlt*:
0-1
ELL-02-SS-01
T1760
1/11/83
(1)
Concentration in parts
1-2
ELL-02-SS-02
T1761
1/11/83
(1)
per billion (Pflb) wet
2-3
ET.I.-02-SS-03
TI762
1/11/83
(1)
ELL-05-SI.-
T1770 -
1/11/83
(1)
bas Is
3-4
ET.T.-02-SS-04
TI763
1/11/83
(I)
nd 800 1,100 . 1,700"""* nd
nd 4,900 11,000 16 , OOO":'-~ . .nd
nd nd nd nd.H; nd
nd 3,000 5,600 560 nd
nd nd 1,500 550 nd
nd nd ... nd nd nd
nd nd 5.2 3.0 nd
nd nd 4.1 nd nd
nd nd 5.9 nd nd
nd - 2.5 930 580 nd
18 23 40 910 3.3
3.6 nd nd 2.5 nd
nd 5.6 n,1 nil nd
nd nd 720 910 nd
nd nd nd 12 nd
ud nd nil nd nd
.p
-------
Priority Pollutant Compounds (cont.)
Pesticides:
Diodna**:
Non-Priority Pollut.~t Compound!
Acid Compounds:
2-.ethylphenol
4-lIethylphenol
other acid compoundl
Bile/Neutral Compounds
2-.ethylnaphthalene
other base/neutral compounds
Volatiles .
acetone
2-buunone
1o-liethyl-2-pentanone
Ityrene
o-xylene
other volatiles
.........---.-. -".,
'. ,. .-. _.. ..-..-- -.--..--.......-....- ...-.__.
. -, --..-"--"-------
... -. ..---.-..-..--------
I:
TABLE R-6 (Page 2 of 4)
ELtISVJLI.E SITE: nOSALly. PIIOPERTY
ORGANIC COHPOUND ANALYSIS RESUJ.TS FOR ELL-02 AR!A SAMPLES
Case: 11034 J.aboratory: tlead CompnChem
(See Table R-12 for list of analyzed compounds and detection
limits)
Depth (ft):
Saalple No.:
Traffic Report:
Date:
Detection Limit*:
0-1
ELL-02-SS-01
T1760
1/11/83
(1)
Concentration in parts
1-2
ELL-02-SS-02
11761
1/11/83
(1)
per billion (epb) vet basis
2-3 3-4
ELL-02-SS-03 ELL-02-SS-04
T1162 T1763
1/11/83 1/11/83
(1) (1)
EI.L-05-SLI
TI1701
1/11/831
(1)
nd
nd
n,1
nd
nd
.~
nd
nd
nd
nd
nd
.'
nd
nd
nd
720
160
nd
920
3,800
nd
11,OOO'!'-'\-
8, /.00-:'-:'-
nd~.-f..
nd
nd
nd
nd
nd
nd
. nd
1,100
nd
nd
nd
nd
nd
nd nd 1,200 2,100 nd
nd nd 920 3,500 nIl
nd nd 190 8,200 nd
nd nd 74 nd nd
nd 8.8 5,800 1,600 nIl
nd . nd nd nfl nd
-------
I:
TABLE R-6 (Page 3 of 4)
ELLISVILLE SITE: ROSALIE PROPERTY
ORGANIC COMPOUND ANALYSIS RESULTS FOR ELL-02 AREA SAMPLES
Cue: 1434 Labontory: Head COlllpuChem
(See Table R-12 for list of analyzed compounds and detection
limits)
Concentration in parts per billion (ppb) vet basis
Depth (ft): 0-1 1-2 2-3 3-4
Sample No.: ELL-02-SS-01 EtL-02-SS-02 EL'L-02-SS-03 ELT.-02-SS-04 ET.L-05-f
Tnffic Report: T1760 T1761 T1762 T1763 T17~
Date: 1/11/83 1/11/83 1/11/83 1/11/83 1/11/1
Detection Limit*: (1) (1) (1) (1) (1)
Tentative!y Identified COllpounds
dfelhyl benzene nf nf 4,000 nf
1,2-dlethylbenzene nf 3,000 nf nf
l,3-dlmelhylbenzene C.-xylene) nf 8,400 2,200 590
."
l-elhyl-2-methylhenzene nf nf 5,700 380
l-ethyl-3-methylbenzene nf nf 20,000 nf
2-ethyl-I,4-dimethylbenzene nf 4,700 4,300 nf
(l-methylethy1) benzene nf nf 1,100 360
I-melhyl-2-(2-propenyl) benzene nf 410 nf nf
propyl benzene nf nf 4,800 300
1,2,3-trimethylbenzene nf nf 12,000 nf
1,2,4-trimethylbenzene nf 6",000 nf 800
1,3, 5-t rilnethy I henzene nf 15,000 10,000 800
1,3-dii 50cyanatomethylbenzene nf 430 nf nf
l-butanol nf nf 4.8 nf
2-butano 1 nf nf 58 31
3-melhyl-2-butanone nf nf 0.4 nf
cyc1 ohexane nf nf nf nf 24,
l-chlorodecane 90 nf nf nf
..
..
~
'.
-------
!!~tltivel~enti(ied Compounds
. .--....-...----..----- ...---...,-- .-- ----_._--~. '.'."
h'." ....-..
. .. . ....-. -.
.. . .,. n -.. ,- .
TABLE R-6 (Plte 4 of 4)
ElLISVILLE SITE: ROSALIE PROPERTY
ORGANIC COMPOUND ANALYSIS RESUI.TS FOil EI.L-02 AREA SAHPJ.RS
Cue: 1434 J.lboratory: Hesd CompuChem
(See Table R-12 (or lilt of Inalyzed compounds anrl detection
liMita)
Depth (ft):
Sallple No.:
Traffic Report:
Date:
Detection Limit*:
(cont.)
0-1
ELl-02-SS-01
T1760
1/11/83
(I)
Concentration in parts
1-2
Etr.-02-SS-02
T1761
1/11/83
(1)
per billion (ppb) wet
2-3
EU.-02-SS-03
TI762
1/11/83
( I)
2-ethoxyethanol
2.2-dillethyl-3-methylene-bicyclo (2.2.1) heptane
1.7.7-trimethyl-bicyc!0 (2.2.1) heptan-2-one
5-methyl-2-hexanone
2.3-dihydro-JII-indene
octlcosane
4-methyl-2-pentlnol
4-lIethyl-4~penten-2-one
2.3-dimelhylphenol
3-elhylphenol
2-.ethylpropanal
2-methyl-J-propanol
2-proplnol
3-phenyl-2-propenll
nf
"nf
nf
nf
nf
nf
nf
IIf
nf
nf
nf
nf
nf
nf
nf
nf
nf
nf
950
nf
nf
nf
nf
nf
nf
nf
nf
nf
5,800
4.4
23
nf
nf
nf
nf
nr
nf
5,200
nf
nf
57
1,500
*Detection limit number cited reCera to column number in Table R-12.
**EPA Region 7 recommended thlt data be rejected due to 10\1 8urrogate
nf tlot found
nd Not detected
Hotel:
recoveriea -
,.."..--- -. '-.'-.
i I
bas is
3-1,
ELL-02-SS-04
TI763
]/11/83
(1 )
nf
nf
of
42
nf
nf
64,
2.6
41,0
2,700
3.3
2.6
15
nr
t':' '
n
o
='
rt
Po ,
.......'
ELL-OS-Sf)
TI710
1/]1/8:
(1)
",
nf
nf
nf
nf
nf
850
nf
nf
nf
or
nf
nf
nf"
nf
-------
..>--<:11....1.11<::.1- ",,--
'I:ABlE 3
REMEDIAL TECHNOLOGIES FOR ROSALIE INVESTHENTCONPANY PROPERTY
Not. appropriate: mobile equipment. not'
available .
Appropriate for onsite contai~e~t
'. and capping
'~ Not appropriate: clay
. Not appropriate: clay
de'gradation Appropriate for onsite
Remedial Technol igies
oJ
A. Surface Water Cont.rols
1. Surface seals
2. Surface water diversion
and collection systems
3. Grading
4. Revegetation
B. Subsurface Controls
1. Impermeable barriers, such
as slurry walls
2. Permeable treatme~t beds
3. Groundwater pumping
4. leachate control, such as
liners
C. Insitu Treatment
1. Solution mining
2. Detoxification
3. Microbiological degradat.ion
... ,
D. Onsite Treatment
1. Incinerat.ion/wet
oxidation,
2. Solidification/
encapsula tion ,
3. Soil washing
. 4. Detoxification.
5. Microbiological
air
E. Soil Removal
1. Excavation
2. Hydraulic dredging
3. Mech~nical dredging
F. Offsite Transport for Secure
Disposal
Ellisvil1e Site
Feasibility Study
:
Remarks
t
:Appropriate for onsite disposal
Appropriate for onsite disposal
Appropriate for all onsite actions
Appropriate for all onsite actions
"
Not appropria'.:.e
contamination
Not appropriate:
contamination
Not appropriate:
, 'contamination
for near surface,
,water table below
. ,
water table below
Appropriate for onsite disposal
Not appropriate: clay soil,
hydrogeological setting.
"Not appropriate: . clay soil
Not appropriate: contamination too
deep ,
soil
soil
treatment
"
.
Appropriate for onsite treatme~t,
onsite disposal, and offsite disposal
Not appropriate: above vater table
Not appropriate: above vater t3ble
Appropriate for offsite dis?osal
18
09/28/83
.~ ;-. '.', -. .,
-------
r ... ("
Attachment c- 2
TABLE 1
:.. .
REtlEDIAL TECHNOLOGIES FOR .JEAN ELLEN C~~L~
-------
<.
. . ,
.". -
(contd)
Remedial Technolo~ies
2.
Hydraulic dredgin~
3.
Mec.hanical dredg/.ag
F.
TABLE 1
(continuedj
Insitu Soil Mass Stabilization
1. Surface compaction
oJ
2.
Vibrator! compaction
G.
Offsite Transport for Secure
..
.'Disposal .
. .
Ellisville Site
Fe~sibili~1 Study
.'
'.
.
Remarks
Not appropriate:
table .
Not appropriate:
table
Not appropriate:
deep
Not appropriate:
Not.appropriate:
nated .soil .
. .
12
above water
above wate:::-
soil mass to
clay soil
no'contami-
~
.
09/23/83
. .. ,.... o.
-------
Rosalie Investment Company Property
Cost Estimate-Alternative R-4
Capital Cost of theR.ecomme~~e(Altern~.!.ive
Alternative R~4~
Offsite disposal
'!
Mobilization, decontamination, and dem;bilizatioa:
Drum U.ds, cans, buckets, metal fragements,
aad miscellaneous debris removal:
6 :man-days @ $10 per hour x 2.5
Buried drum excavation:
15 drums @ $140 per drum ..
Drum sampling and screening analyses:
15 drums @ $40 per drum
Disposal drum purchase:
J ,
10 55-gallon drums @ $20 per drum
15 85-gallon drums @ $85 per drum
Overpacking of excavated drucs: .'
15 drums @ $20 per drum
loading of drums 'on truck:'
25 drums @ $20 per drum
Transport of drums to BHS:
1 load @ $165 per load
Contaminated soil excavation:
240 cy @.$8 per cy
Transport of contaminated. soil to BHS:
240 cy; 15 cy loads; 90% full
.18 l~ads @ $165 per load
Disposal at BHS:' ,
10 55-gallon drums @ $30 per drum
15 85-gallon drums @ $47 per drum
18 x 15 cy @ $49 per cy
Borrow soil excavation, transport, placement,
and compaction (on-site borrow):
240 cy @ $S per cy
Reseeding of excavated areas:
200 sy @ $0.40 per sy .
Profit on transport and disposal subcontracts' (10%):
, , a Subtotal
... ."
Contingencies (10%):
Subtotal
.
. ,
Engineering design services:
Iotal
Preliminary opinion of probable cost:
Ellisville Site
Feasibility Study
.
..
. Attachment 0-1
..
..
. $ 10,000
~
1,200
2,100
600
200
1,300
.~. .. ~
t, 300
500
200
1,900
3,000 .
300
. ',700
13,200
1,200
100
1,700
$' 38,500
3,900
$ 42,400 ;,
I
10,000 .
$ 52,400
$ 52,000
09/23/83
-------
" )
Jean Ellen Callahan Property
Cost Estimate-Alternative C-2
Capit~l .~ost of .ttJe RecOmmende~ Alternative
Alternative C-2:
Erosion Control
- ~obilization and demobilization:
Plastic cover debris and hold-down block removal:
~ 4 man-days @ $10 per ~our, X 2.5
~isposal drum purchase:
\ 10 55-gallon drums @ $20 per drum
Transport of drums to BHS:
1 load @ $165 per load
Disposal of drums at BHS:
10 drums @ $30.20 per drum
Borrow soil excavation, transport, placement,
and compaction (on-site borrow):
. 170 cy @ $5 per cy .
Rough grading, sprea~ing, and:seeding:
1,000 sy @ $1.40 per sy " ,
Cha~n-link fence removal and salvage:
745 feet @ $1.75 per foot
Gravel stockpiling:
'. 290 cy @ $0.75 per cubic yard
Barbed-wire fence removal and salvage:
800 feet @ $1.50 per foot
Subtotal
Contingen~ies (10%):
Subtotal
Engineering design services:
Total
Preliminarl opinion of probable
cost:
,. -
. .
Ellisville Si~e
Feasibility Study
Attachment 0-2
..
'$2,000
800
.'
200
200
..
300
900
1,400
1,300
200 ' .
1,200
$8,500
900 .
$9,400
2.500
. $11 ,900
$12',000
'.
,
09/28/83
-------
~ .J
t
... "
RESPONS I VENESS SUMMARY
Attachment E
D. [} l\ C 'Y ,
~\a",1 L
J
- On August 9, 198q, 'the Missouri Department of Natural Resources
. '(MDNR) and the United States Environmental Protection Agency (U.S.
EPA) conducted a public meeting at the Daniel Boone Branch of the St.
louis County library, 300 Clarkson Road, Ellisville, Missouri. The
purpose of the meeting was to invite the public to comment on
proposals for completing cleanups at two 'areas of the Ellisville Area
Site !n St. louis County. One of the sites is located on property
ow~ed by Jean Ellen Callahan. More than twelve hundred (1200) drums
~ere excavated from a ravine on this property in 1982. The other
site is located on property owned by the Rosalie Investment Company.
About two hundred (200) drums were removed from this property in
1981. The tw~ sites are ~ear Caulks Creek, north of Manchester Road
an~ west of Strecker Road. The third area of the Ellisville Area
Site is located on property owned by Russell and Evelyn Bliss and
adjacent owners. It is the only site of the three where dioxin has
been found. The U.S. EPA is currently working on an expanded
Feasibility Study for this site, since both MDNR and U.S. EPA decided
that additional cleanup options should be evaluated for the dioxin
contaminated soil.
At the Jean Ellen Callahan property, the recommended remedial
alternative presented by state and federal officials called for
erosion control of the fill area and removal of the onsite vestiges
of the 1981-82 immediate removal action. Tne remnants of the plastic
cover over the fill area ~ould be removed and disposed of. The
, barbed-wire fence around the fill area and the chain-link fence
around the 'two drum storage areas would be removed and salvaged. The
;ravel in the two drum storage areas would be scraped up and
stockpiled on the property. The soil in the fill area would be
spread and reeraded to a stable slope, covered with a compacted soil
layer, and reseeded. The probable cost for this remedial action was
estimated to be $12,000.
-,
At the Rosalie Investment Company property, the recommended remedial,
alternative presented by state and federal officials called for ,.
offsite disposal of contaminated soil, buried drums, cans, and
debris. Contaminated soil would be excavated and transported in bulk
to an offsite permitted hazardous waste landfill. Drum lids, cans,
debris, etc. would be placed in drums. Any buried drums encountered
durin~ excavation would be placed in overpack drums, and the contents
would be sampled and analyzed.The drums would be transported to
permitted disposal facilities accordin~ to the characteristics of
their contents. Borrow soil would be placed and compacted in the
excavated areas with all disturbed areas reseeded. The probable cos~
of this,remedial action was estimated to be $52,000. '
.. . ~: . ,
-------
.. ,
. .i
Attachment E (contd)
~..."" r,
to j ."..,
L. "3";
~q F T
Responsiveness Su~mary
Page 2
October 16, 1984
,.
J
. " (
Following the presentation of the two recommended remedial
alternatives, the public ~~s allowed to comment orally on the
proposals. The consensus of public opinion was that state and
federal officials should be allowed to complete the cleanups at the'
two sites. They wanted the government to do whatever was necessary
to cleanup the sites, so that they would be safe for the~selves and
particularly their children. They expressed concern that the
necessary federal approval might not be obtained. They were aware
that the' m::mey needed for cleanups could be allocated to a higher.. ....
priority site, if EPA headquarters decided the proposed actions were .".~
no~ necessary or cost-effective. "
Another concern of the public was the benefit that responsible
parties would derive from the proposed remedial actions. Their
property would be restored to unrestricted use without expenditure of
funds on their part. Many citizens felt that the responsible parties
should be compelled to contribute toward the costs of cleaning up the
. two sites. Citizens wanted to know how much had been spent by state
. and federal officials. It was explained to citizens that both
.: " agencies were attempting to recover ~leanup expenditures from the
responsible parties.
In summary, officials determined that local citizens were not opposed
to the two recommended remedial alternatives or their associated
costs. Following public input, the recommendations were"not
modified. Based on the positive response received, we believe that
the two alternatives for site cleanups, if chosen to be implemented,
will be acceptable to the community.
After July 9, 1984, the Feasibility Study was available for public"
review at the Daniel Boone Branch for the St. Louis County Library. .
The public was allowed "to provide written comments until August 17,
1984. The MDNR did not receive any written comments.
JS:ss
~
,"
.. -. :"1.."
-------
'lJ-=
~ ~ ~
Cf)
w
o
~
::> J
o
en
w
~
--1
«N
~N
.::> ~
r-..L
«~
.Z~
LL '-'. .
ON
J-~
Z.~
W.5
~g
.r-~
~~
~U
wa
O~
-
--
~~
:::)-0
O~
(f)(
(f)~
22
State Recommendation
.
Mr. Morris Kay
Regionaf Administrator
U.S. EPA Regi on VII
324 East Eleventh Street
Kansas City, MO 64106
,;
I
Dear Mr. Kay:
This letter is to provide Missouri's official position concerning
implementation of remedial actions to clean up contamination at the
Ellisville site. We have ~eviewed the EPA contractor's feasibility
study which considers various alternatives and recommends specific
remedial actions. The State of Missouri is in agreement .with all
recommended alternatives except for the recommendati~ns fo~ handling
dioxin contaminated soils. ~ .
Si.nce the Feasibil ity Study was drafted, the Mi ssouri Dioxi n Task
Force has presented their findings and recommendations and the
Governor has adopted those Task Force recommendations as official
state policy. The Task Force recommendations recommend secure
temporary storage of dioxin contaminated soils as most appropr~ate
. unti 1 a fi nal . trea.tment .or di sposal technology is developed.
. ..
In view of these developments, we strongly recommend the implementa-
tion of secure temporary .on-site storage of the dioxin contaminated
soils. We feel the cost of such an alternative would be similar to
the c~sts currently estimated for the recommended alternatives. .
Secure temporary storage may in fact be the lowest cost alternative,
and it is an alternative which is technologically feasible and which
effectively minimizes damage to and provides adequate protection of
public health, welfare, and the environment. We feel a remedial
action to provide secure temporary on-site storage of these materials
would be consistent with the State's policies for dealing with dioxin
sites.
~
Sincerely,
.. .
~
DEPARTMENT OF NATURAL RESOURCES
OR!GI:'IAL SIGNED SY .
P.~N KU;;E::tA
Fred A. Lafser
Director
FAt: sjd
cc:
Waste Management Program
Christopher S. Bond Governor
,
Fred A. Lofser Director
. "--' . ". ~.'" ',r.. ~
-------
~Itlv!
C-l: Jlllllle-
dlale Removil
Actl"n Closure
C-2:
£r0510n
ConLrol
'.
Preliminary
Opinion of
I'robable
Cosl
$ 6,000
$ 12 ,ODD
Significant
Adverse Envlron-
~Ul Effects
Yould leave loll
in unstabJe condi-
tion, increulng
"o85lbl lIty of
further erosion &
aJoughing
Jlone
.,
'.
TAnI,F. 2
COtIPARJSON OF CALLAIIAN PROPERTY ALTEmlATJVES
Adequate Control
~~£!i.!~
Yould not control
physically
unstable Boll
IDasa
Yes
Reliobi1 fly
YouJd have no
control of
erosion or
aloughing
Good
Jmplelllentability
Good
Gootl
~
Operation anti
tla intenance
Requlremenl'
tlone
None
I:
Safety and
Regulatory
Requl-rements
Disregards
None
>
IT
IT
1\1
n
i'
ID
::1
IT
C')
I
......
Public
Accel'tance
I.eavln"g soil
In physlcal1"
un' table con'
tI on not
acceptable
Good
-------
~ !!!!!!!!.!!!
R-I:
Jlo action
R-2: Onslte blo-
'Iolie.l tre.tment
ilnd offsile
Jilipoul of
containers and
contcllts
R-3: Onsfte
disposal III .
seCIIU lalldf ill
R-~: Offahe
dill,os.1 at
pcr.itted disposal
hci I ily
Prell.'nny
O"inion of
I'f(.hahle
f.Olil
$
o
$ 91,000
$200,000
$ 52,000
Sllnl Helnt
Adllerse
[nlliron.ental
!fU!:~!!-
Yea -ne.ludat I on
of IlIrhce,
arollild and
drinking "ater
'1".1 iL Y 1'0:1-
lIihle
Yes-Potential
for are. test
.1 r 1)11111 it Y
deSudAtion
Yes-QI/estlonahle Yea
geolollieal
selLllIg
Jlone 'pparent
..
TAnT.F. It
COt'PARTSON OF RO~Ar.n: "/lOI'ERTY AT.TF.RNATTVY.S
Ade'lilite
Conlrol or
[ffectlve~~~~
Questlonal,l e,
natl/nl mech-
111I18I11S halle not
been a'iown to
definitely
attenuate
conta.inatlon
Yea. f f proven
effective hy
t rea t.bU i ly
IItucly
Yea
~el hhl1lty
QI/eatlon.hle
dl/e to slispect
assllmption of
nKtural degr.-
clation
ReUabJe if'
prollen effective
hy treatability
Itlldy
Rel'abJe 8. long
IS integrity of
the lan"flll
)Iner and e.p la
maintaIned
Coo.,
Jlllplelllent-
!!!.!.!!!y-
Cood
Cood
Questionable
geoloeic.l
letting dl/e
to b 18h he,l-
rock (orlla-
tlon
Cood
"
Operation .nd
"ailllenance
!~~I/ i re~n-!.!
None
,",ollld require
monitor'ng anti
testlnr after
'n'lial treat-
ment
,",ould rel)ulre
long term monl-
torins .nd
"L,-ntenance
an,l restrictive
lalld use
Respon. ""I f ty
of the olhhe
peroa'Lte,1
d Isposa I
hci Ii ly
Safety 8nd
/lesuhtnry
/I e 'I !.!..!!!!!!~!!~
nlsregar,'s
,",ould re'!I/'re
a fence to
restrict
access to
areas beinp;
trealed
,",01/ 1 tI re,!I/' re
monitorillg
"ell 'nsta'-
lation
Responslbflily
of the o((sile
peroni Lted
disposal
facililY.
"
'>
fT
rt
I\)
n
i
ro.
::1
fT'
C)
,
N
pl/bJ'c
~£E!r!!~!
Prohably negatfve
since sofl contaml
nalion and some dr
wOl/ld slil) reonain
Prnhahly pos'tlve
if air 'I/iflity
Iii> not. noticeably
:alfecte,1
Prohahly nesatlve t
contilll/ed presence
of hazardous waste.
in a residential
area, even il
waste. are conta'ne.
in a secl/re land fj I ,
Probahly positive t~
remollal of h.zardolls
waste Irolll a
~esfdentjal area
-------
','
TAntE C-3 (Pace 1 of 2)
EU.ISVIJ.T.l~ srm: CAT.T.AHA}r PROPERTY
ORGANIC COtIPOUND ANALYSIS R1~sur:rS FOR FIJ.L-ARF.A SUn!mnrACE SO IT. SAtlPT.ES
Case: )1.33 J.aborntory: ~'ent1 CompuChem
(See TobIe C-7 for] ist of analyzet1 compount1!: and detection limits)
Concentration in parts per billion (rph) wet hasis
T.oea tion:
Sample }lo.:
Traffic Report:
Date:
netection Limit*:
Inside Fill
EU.-21-SS-01
T1730
12/29/R2
(1)
5' from fill.
EJ.T.-22-SS-01
'ftR!.8
2/15/83
(2)
15' from fi 1.1
EU.-23-SS-01
Tt 8la I)
2/16/83
(3)
Priority pollutant CO!!!p"~ds
Vola tiles:
nft
nl1 nit
1 ,!tOO nd
nd nil
,,.
nit nil
1M nil
nil nd
nd".. nd
.~
>
H
nil nd H
>
. CI
nt1 nil ~
IT!
~
nil n,l ~
Acid Compounc's:
net
nose/Ueutral Compounds:
bis (2-ethylhexyl)phthalate
other hose/neutral compounds
13,000
nt)
Volat lIes:
nd
Pesti cicles:
PCn-12~/,
other 'pesticides
Oi ox ins':"';:
ncl
nd
nlf
}lon-Priori t~11ut8nt Co~pollnl18
Acid Compounds:
nl1
'Ua fle/Heutral Comrount1s:
nd
'.'
"
..'
.
-------
~~
~~I
~:
,.. ..
~
~
.:.:~-.
~I
'---"'
t-a,:..:-'
u:-..;;...
'''~ _I.'"
........~...
.~
TAnLR C-3 (Page 2 of 2)
F.T.T.JSVIU.F. SJTJ~: CAT.T.AtlAN {)ROPERTY
ORGANIC cmlPomm ANALYSIS RESur.'1'S FOR FILL-AREA SunstmFACE SOU. SAtlrr.F.S
Case: 1',33 T.nhoratory: tlead CompuChem
(See Tahle C-7 Cor list of analyzetJ compounds nl"t detection limits)
toca ti on:
Sample Ho.:
Trn r Hc Report:
Date:
netection T.imit*:
Te'!.tative1y Identified Compounds
2,6-his(1,1-dimethy1ethyl)-/.-methylphenol
1,3,S-cycloheptatriene
cyclohexane
11-decyldocosane
1,3-tJimethylhenzene (m-xylene)
eicosane
hexatriacontane
pentacosane
2 -p ropeny Ildenecyc 101)11 tene
NOTES:
*netection limf.t number cite,) refers
~-;;EPA Region 7 recolMlelHled that data
nd Not detected
nf Hot found
Concentration in parts !~r hill ion Cpp") wet hasis
Insi(le Fill
ET.T.-21-SS-01 .
1'1730
12/29/82
('I)
5' fr.om H]rA
ET.T,-22-SS-01
1'IMR
2/15/1\3
. (2)
15' from flU
EI.T.-2J-SS-01
T1 R/.9
2/16/83
(3)
5,500
20,000
660,000
27,000
nf
50,000
1,3,000
90,000
nf
nf
3RO
nf
nf
300
nf
nf
nf
nf
of
nf
of
of
of
nf
of
IIf
21\0
to colunm nmnher in Table C-7
he rejected dne to low surrogate recoveries
>
H
H
.>
~
~
~
I'"
n
o
::3
rt
~
-------
TADLR C-4 (Page 1 of 2)
1!LT.JSVIT.U~ SITE: CAT.T.AHAN PROPERTY
ORGAUIC COHPOUNO ANALYSIS RESUT.TS FOR SAMPLES DO~'N'-GRAnE flF FlU.
Case: 1433' Laboratory: Mead Compu Chem
(See Table C-7 for list of analyzed compounds and detecti.on Hmits)
Location:
Soil Concentration
in parts reI' billion (ppb) wet basis
North End of South End of
Drainageway Drainageway
ELL-24-SL-Ol ELL-25-SL-01
T1726 .' T1729
12/30/8212/30/82
(4) (3)
Water Concentration
micrograms per litre (ug/T.)
Creek at Creek at West
Drainageway Property Boundary
ELL-26-SW-Ol ELL-27-SW-Ol
T1741 T1742
1/5/83 1/5/83
(5) (5)
i.n
Sample No.:
Traffic Report:
Date:
Detection Limit*:
Priori ty Polluta!!.t C~ounds
Acid Compounds:
net nd nd;':--k n d~-'+
16,000 1,000 nd nd
nd nil nd nil
3.8 3.9 nd nd
nd nd nd nd
nd nd na nil
nd nd n8 nct
Base/Neutral Compounds:
bis (2-ethylhexyl) phthalate
other base/neutral compounds
Volatiles:
fluorot ri ch 10 romethane
other volatiles
Pesticides:
Dioxins*"k:
Non-Priority Pollutant Compounds
Acid Compounds:
. nd
nd
nct**
nd.»
-
'r
I
~
.
~
t-i
»
i
~
p::
'"
n
o
::J
"
-
-------
~
~
.~
.~
Non-Priori t~]utant
Dase/Neutral Compounds:
. Volatiles:
~
.~
'~
.~
~j
, .. .
'~~~4...i
~
...,;;:.-!.::J
:-:.~
---'
. -~...
TAntF. C-4 (Page 2 of 2)
ET.LTSVIU.E SITE: CAJ.LAJJAN PROPERTY
ORGANIC cOtlpmnm ANAT.YSIS RESUI.TS FOR SAMPLES DOWN-GRADE OF FU.L
Case: 1'.33 Laboratory: tlead Compu Chem J
(See Table C-7 for list of analyzed compounds,and detection limits)
I.oca tion:
Sample ~lo.:
'fraffic Report:
Date:
Detection Limit*:
Compounds (Cont'd)
Tentative]y Identified Compounds
1.3.5-cycloheptatriene
cyclohexanol
N-cy~lohexylcyclohexanamine
1.3-diisocyanatomethyJhenzene
1.3-1 sobenzofurandione
hexadecanoic acid
*Detection limit numher cited refers
~-kE:PA Region 7 reconunended tha t da ta
na Not analyzed
nd Not detected
nf }fot found
NOTES:
...
Soil Concentration
in parts per billion (ppb) wet basis
North End of South End of
Drainageway Drainngeway
ELL-24-SL-Ol EtL-25-SL-Ol
11728 T1729
12/30/82 12/30/82
(4) (3)
Water Concentration
micrograms per litre (uS/L)
Creek at Creek at West
Drainageway Property, noundary
ELL-26-SW-01 ELL-27-SW-01
T1741 11742
1/5/83 1/5/83
(5) (5)
in
nd
nd
nd
nd
."
'...
nil
nd
ntI
nd
170
170
990
200
510
nf
nf
nf
nf
nf
nf
1,100
nf
nf
nf
nf
nf
nf
nf
nf
'nf
nf
nf
nf
to column numl)er in Table C-7.
be rejected due to low surrogate recoveries.
>
t-i
t-i
>
n
~
M
z
I-:!
:x:
""'
n
o
::s
rt
'-'
-------
TAm.l~ 6
-,
JF.AN EI.T.EN CAT.T.AHAN PROPERTY SMIPT.E ANAT.YSIS RESULTS SUtIHARY'
nETECTED ORGANIC PluOHn'y POLLUTANTS
Composite Composite Fill. FU I Runoff
,--Drllm Snmple - ,... Soil-'Samp Ie "----'---Sample
~/16/RO 2/9/82 --2/16/80
(ppm) (ppm) (ppb)
-- .----'-"
......-- --...--.... ..........
J dent i fj cd CCllrlpollnfls
2 ,/,-d i me lhy 1 phenol
phenol
1,2,4-trichlorohenzene
isophorone
napthalene
nitrobenzene
his (2-ethylhexyl) phtha1clte
di-n-b~ltyl phthalate", .
di-n-octyl phthnlatp.
diethyl pht\lalitte '
dimethyl phthulate
hcnzelle ,
l,l,l-trichloroethane
.~ 1, 2-lralls-fli ch lOl'oethylene
elhylhcnzelle
methylcne chloride
tolllcne
.~ tetrachlorocthylenc
vinyl chloride
IItIC-a 1 pha
IIIIC- cnllulla
NR
un
NR
NR
.2
,trR ,
'5,310
17
NR
29
369
NR
UR
Nn
Hn
UR
It
UR
It
tm
lilt
9./,
15.5
NR
Nn
0.9
N'R
20.3
Nn
16, 1
1m
1m
tm
NR
NR
2.3
1.7
62.9
1.9.
NR
un
Nn
J
i
:, AU. OTHER ORGANIC PRIORITY POT.T.UTAUTS NOT RI~POnTED OR
I It - Reported presc'nt in drllm sample (1/20/62)
UR tlot reportetl in availahle dala.
tin Hot detected
, .., .:; Same liS reported for luboratory hlan1(
Sur.face '-later
Haximurns .
Unknown Locations
Onsite'
12/23/61
(ppb)
Fill T.eachate EPA Water
'--'Sample--Qua li ty-rri ter
1/5/62 \llIman Health
, (pph) (ppb)
"
Nn 27 ,.563 /,00
-' -
20,000 676 . /.,020 3,500
NR 3' UR I --
150 337 700 .- 5 ,200
NR NO HR
760. Nl/ ' , tlR ,19,800
nn 120 590 .15,000
Nn 1 NR 34,000
Nn }, 20 Nn .--
NR 3 tlR ' 350,000
NR lID Nil
NR !,I\ * Hn 6.6
NH /,6* un 18,/.00
un 5 Nn
Nn 15 60 1,400
Nit 1,810' 5/.0 1.9
NR 5,910 . 6,950 14,300
un N1) un
Nn uo un
Nn 0.013 1m 0.092
NR 0.005 un 0,186
HOT DtTECTEO .
'---.....
..
-
..
..'
------- |