United Stales Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R07-90/042
September 1990
Superfund
Record of Decision:
Shenandoah Stables, MO
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~272.101 I
REPORT DOCUMENTATION II. REPORT NO. I ~ 3. Recipienl'l Acce..ion No.
PAGE EPA/ROD/R07-90/042
4. Tille Ind Subll.. 5. Report Dlle
SUPERFUND RECORD OF DECISION 09/28/90
Shenandoah Stables, MO
Second Remedial Final 6.
Action -
7. Aulhor(l) 8. Perlorming Orglnizaaon Rept. No.
e. Performing Orglinizaaon Nome Ind Add",.. 10. ProjectITloklWork Unit No.
11. ControcllC) or aunt(a) No.
IC}
(a)
I ~ Sponeorlng Orglnizotion Nome Ind Addre.. 13. Type 01 Repon' Period Covered
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
15. Supplemenllry NOlel
18. Abolrlc1 (Urnil: 200 worete)
The Shenandoah Stables (SS) site is located in a rural area near Moscow Mills,
Lincoln County, Missouri, within the upper floodplain of Crooked Creek. The property
includes an enclosed arena and horse stables building, a number of single family
residences, a livestock operation, and other small businesses on approximately 5- to
10-acre land parcels around the facility. In 1971, the area inside the arena was
sprayed with approximately 1,500 gallons of dioxin-contaminated waste oil for dust
control purposes. Subsequently, a number of adverse effects were noted in horses '
other animals, and in humans. In two separate removals during 1971 and 1972,
approximately 24 to 26 inches of the contaminated materials were removed and disposed
of either offsite or onsite. EPA investigations in 1982 identified contamination at
the facility by dioxin levels greater than 1,750 ug /kg, with approximately 8,600 yd2
of interior and exterior site areas affected. A 1988 Record of Decision (ROD)
documented the remedial action, which involved excavating and interim onsite storage
of dioxin-contaminated soil exceeding Federal and State health-based levels. This
ROD addresses the final remedy for the site, the removal of 3,471 cubic yards of
contaminated materials currently stored onsite in 2,660 separate containers. The
primary contaminant of concern affecting the soil and debris is dioxin.
(See Attached Paae)
17. Documenl Anely8l1 .. Delcrlpto18
Record of Decision - Shenandoah Stables, MO
Second Remedial Action - Final
Contaminated Media: soil, debris
Key Contaminant: dioxin
b. ldenafiere/Open-Ended Torme
c. COSA TI FIeIdIaroup
18. Avoillbilly Stotemenl 11. Security CII.. (Thlo Report) 21. No. 01 PIgel
None 36
20. Security ClI.. (Thlo Plge) 22. Price
N()n~
'VHM 272 (4.77)
(See ANSI.Z3e.18)
See Inetruc"one on Re..-
(Formel1y NTIS-35)
Deportmenl 01 Commerce
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EPA!ROD!R07-90!042
Shenandoah Stables, MO
Second Remedial Action - Final
"
"
Abstract (Continued)
The selected remedial action for this site includes transporting of 3,471 cubic yards of
contaminated materials offsite to the Times Beach Superfund site for thermal treatment,
followed by land disposal of treatment residuals offsite; and restoring the Shenandoah
Stables site by decontaminating and dismantling the onsite storage buildings. The
estimated total cost for this remedial action is $2,800,000. There are no O&M costs
associated with this remedial action.
PERFORMANCE STANDARDS OR GOALS: Thermal treatment will ensure 99.9999% destruction and
removal of dioxin from the contaminated soil and debris.
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RECORD OF DECISION
FOR
FINAL MANAGEMENT OF
DIOXIN-CONTAMINATED SOIL
SHENANDOAH STABLES,
LINCOLN COUNTY, MISSOURI
Prepared by
u.s. ENVIRONMENTAL PROTECTION AGENCY
September 28, 1990
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section
I.
II.
III.
IV.
V.
VI.
VII.
CONTENTS
SITE NAME, LOCATION, AND DESCRIPTION
Paoe
1
1
4
5
6
7
8
11
19
19
21
SITE HISTORY AND ENFORCEMENT ACTIVITIES
COMMUNITY RELATIONS HISTORY
SCOPE AND ROLE OF RESPONSE ACTION
SITE CHARACTERISTICS
SITE RISKS
DESCRIPTION OF ALTERNATIVES
VIII. COMPARATIVE ANALYSIS OF ALTERNATIVES
IX.
X.
XI.
THE SELECTED REMEDY
STATUTORY DETERMINATIONS
DOCUMENTATION OF SIGNIFICANT CHANGES
ii
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I.
SITE NAME, LOCATION, AND DESCRIPTION
The Shenandoah Stables site is located in a rural area along
U.S. Highway 61 near Moscow Mills, Lincoln County, Missouri,
approximately 45 miles northwest of St. Louis, Missouri.
Shenandoah Stabies lies in the west 1/2, northeast 1/4 of section
17, township 48N, range lE of the Troy 7.5 minute USGS
quadrangle. The property lies on the upper flood plain terrace
of Crooked Creek in a primarily agricultural area. There are a
number of single family residences, a livestock operation and
other small businesses on approximately 5- to 10-acre parcels
around the facility. Approximately nine residences are located
within a quarter-mile radius of the site. The predominant land
use is pasture land which is primarily vegetated with fescue.
The property includes an enclosed arena and horse stables
building containing a 78.5-foot by 189-foot horse arena, and
nearly 100 boarding stalls. The arena structure is principally a
wood frame structure with wood poles and trusses and supports and
sheet metal walls. Figure 1 shows a diagram of the site as it
currently exists. The presence of dioxin (2,3,7,8-
tetrachlorodibenzo-p-dioxin) contamination has been identified at
the site.
II.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
Site History
During the early 1970's, activities at Shenandoah Stables
included the boarding, training and sale of horses, and the
staging of horse shows. Children periodically played in the
arena building. The area inside the arena was sprayed with
dioxin-contaminated waste oil on May 26, 1971, for dust control
purposes. It has been reported that 1,500 gallons of waste
material were applied at this time.
FOllowing this spraying, a number of adverse effects were
noted in horses, other animals, and in humans. In August of
1971, the facility owner reportedly removed 6 to 8 inches of the
contaminated arena soil. This material was disposed of in a fill
for a portion of U.S. Highway 61, which was under construction at
the time. Horses continued to die after the first excavation
effort. In March 1972, an additional 18 inches of materials were
reportedly removed by the site owner from the arena area and
buried onsite in a slough area about 75 feet southeast of the
arena structure.
Since the initial site sampling effort in May, 1982
confirmed the presence of dioxin at this site, a total of four
Page 1
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site investigations have been conducted by the EPA and one by the
U.S. Fish and Wildlife Service (USFWS). These investigations
detected exterior contamination of the facility by dioxin at
levels greater than 1750 parts per billion (ppb). Dioxin contam-
ination had spre~d from the original sprayed area to adjoining
portions of the enclosed facility and to outside areas. Sampling
and analysis confirmed contamination of approximately 8600 square
yards of interior and exterior site areas. In addition, the
USFWS sampling identified dioxin contamination in area wildlife
as high as 46 picograms/gram.
A Record of Decision {ROD} for the Shenandoah Stables site
was issued by EPA on July 28, 1988. This ROD selected a remedial
action involving excavation and interim onsite storage of dioxin-
contaminated soils exceeding health-based levels recommended by
Federal and State health agencies. Excavation continued until a
residual concentration of one part per billion (ppb) was reached
in areas outside the arena, and until a residual concentration of
five to ten ppb was reached at a depth greater than two feet in
the arena and slough areas. During this remedial action,
decontamination of the arena building was performed to meet
health agency recommendations. Implementation of this remedial
action was completed in May, 1989. A total of approximately
3,471 cubic yards of dioxin-contaminated materials resulting from
soil excavation and building decontamination are currently in
interim onsite storage inside fully enclosed wood-framed, steel
sided storage structures pending final management. .
Additional information about the site, the history of
contamination, and the investigations that EPA has conducted is
presented in the feasibility studies and other documents in the
Administrative Record.
Enforcement
The potentially responsible parties (PRPs) for this site
(and the other Missouri dioxin sites which are the subject of
pending litigation) include the generators of the dioxin waste,
the transporter of the waste, and those who arranged for the
transport and spraying of the waste.
On April 30, 1983, an Administrative Order pursuant to
Section 106 of CERCLA was issued to the owner of the Shenandoah
Stables Arena requiring closure of the arena and stables building
and restricting access to the property. Subsequent compliance
inspections conducted by EPA confirmed that compliance with the
Administrative Order had been obtained.
Special Notice letters were issued to the Syntex defendants
and to Independent Petrochemical Corporation on March 31, 1988.
Page 3
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The moratorium required by Section 122(e) of the Superfund
Amendments and Reauthorization Act (SARA) began on the date of
issuance of this notice.
This site is one of the six dioxin sites originally included
in the U.S. ~ Biiss. et al, complaint, civil Action No. 84-200 C
(1), which was filed in the Federal District Court for the
Eastern District of Missouri on January 20, 1984. On March 1,
1989, 21 additional sites in eastern Missouri which became
contaminated by dioxin through similar means were added to this
litigation (Civil Action Nos. 89-351 C (1) through 89-571 C (1».
The cases were consolidated with the original case for discovery
and trial. On April 6, 1990, the United States commenced civil
Action No. 90-656c(1) which has been consolidated with the other
civil actions referenced in this paragraph.
The pleadings in the above litigation refer to 28 sites,
while EPA's technical documents sometimes refer to 27 sites.
discrepancy in numbers is due to a difference in nomenclature
used by EPA and the Department of Justice. The same group of
designated sites are represented by both lists.
The
Partial summary judgment pursuant to Section 107 of CERCLA
has been granted as to the Bliss, Northeastern Pharmaceutical and
Chemical Company (NEPACCO) and Independent Petrochemical Company
(IPC) defendants.
On July 20, 1990, a Consent Decree was lodged with the court
with the United States of America, the State of Missouri, and the
named Syntex defendants as signatories. This Consent Decree
makes possible a final comprehensive remedy for the eastern
Missouri dioxin sites referenced in the above civil actions. The
remedy specified by the Consent Decree is consistent with the
Times Beach ROD, and provides thermal treatment capacity at Times
Beach for all designated eastern Missouri dioxin sites, including
the Shenandoah Stables site. A pUblic comment period was
conducted for this consent decree from August 8, 1990, through
September 7, 1990.
A Consent Decree between the united States of America, the
State of Missouri, and the NEPACCO defendants was lodged on July
26, 1990. The NEPACCO consent decree provides for cash
settlement of the liability of the NEPACCO defendants. A public
comment period was conducted for the NEPACCO Consent Decree from
August 8, 1990, through September 7, 1990.
III.
COMMUNITY RELATIONS HISTORY
The public was first invited to comment on the concept of a
Page 4
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comprehensive solution for all of the eastern Missouri dioxin
sites at the September 5, 1986, public meeting for the
Minker/stout/Romaine Creek (M/s/RC) feasibility study. At that
meeting, it was announced that the State of Missouri had
recommended evaluation of Times Beach as a location for siting a
temporary thermal treatment unit and that EPA was evaluating this
possibility. A feasibility study to evaluate Times Beach as a
potential location for centralized thermal treatment of
designated eastern Missouri dioxin sites was to be completed and
released for public comment.
The Times Beach Feasibilitv StudY was released for public
comment from December 29, 1986, through March 27, 1987. A public
meeting was held on February 12, 1987, to discuss alternatives
evaluated in the study and to present the Agency's proposed
remedy.
The Proposed Plan for Times Beach and the M/s/RC sites was
released February 19, 1988. A public comment period was held
from February 19 through March 18, 1988, and a public meeting was
held in Eureka, Missouri March 10, 1988. A Record of Decision
was issued by EPA on September 29, 1988, selecting a remedy
involving centralized thermal treatment of dioxin-contaminated
materials at Times Beach. This Record of Decision established
that dioxin-contaminated materials from a designated group of
eastern Missouri sites, including the Shenandoah Stables site,
could be transported to Times Beach for thermal treatment.
On August 24, 1990, the EPA released the Proposed Plan for
Final Manaqement of Dioxin-Contaminated Soil. Shenandoah Stables.
Moscow Mills. Missouri. This Proposed Plan presented the EPA's
preferred remedy involving transportation of dioxin-contaminated
materials currently in storage at the Shenandoah Stables site to
Times Beach for thermal treatment using the temporary thermal
treatment unit established by the September 29, 1988 Times Beach
Record of Decision. A public meeting to discuss the Shenandoah
Stables Proposed Plan was conducted on September 19, 1990, at the
Moscow Mills Community Center. Public comments were accepted by
the Agency through September 24, 1990. A Responsiveness Summary
has been prepared which addresses all comments received during
the public comment period for the Shenandoah Stables Proposed
Plan.
The documents described above are included in the
Administrative Record and can be referred to for additional
information on public participation and response to previous
activities.
Page 5
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IV.
SCOPE AND ROLE OF RESPONSE ACTION
The overall remedy for the Shenandoah Stables site is being
performed in two operable units. These operable units are in-
tended to address the risks associated with the hazardous sub-
stances at the site.
The first operable unit, which was completed in May, 1989,
consisted of excavation and interim onsite storage of dioxin-
contaminated soils exceeding health-based levels and
decontamination of the arena structure. Contaminated materials
were excavated and placed in polyethylene-lined, polypropylene
containers. Each container holds approximately 1.3 cubic yards
of dioxin-contaminated materials. A total of 2660 such
containers were filled and placed in storage during the remedial
action.
The containerized wastes are currently in interim onsite
storage inside three wood-framed, steel sided storage structures
with bermed concrete floors. These buildings were constructed at
two separate locations near the arena buildings. Each compound
is surrounded by a six-foot chain link security fence. Both the
fences and buildings are locked at all times.
This Record of Decision selects the remedy for the second
operable unit, which addresses final management of dioxin-
contaminated materials currently in interim storage onsite.
V.
SITE CHARACTERISTICS
Dioxin (2,3,7,8 tetrachlorodibenzo-p-dioxin) is the only
contaminant identified at the site which exceeds health-based
levels. Prior to implementation of the first operable unit
response action, contamination existed at the site both inside
and outside of the arena building. Interior contamination
included surface soils and contaminated dust located on interior
surfaces. Exterior contamination was limited to surface soils in
close proximity of the arena and subsurface soils in the slough
area. Dioxin contamination of the slough area extended to a
depth of four feet with levels as high as 1730 parts per billion.
No contamination was identified in surface waters receiving
drainage from the site. Bonding of dioxin to surface soils
prevented ground water contamination from occurring.
During implementation of the first operable unit response
action, interior and exterior surface soils exceeding health-
based levels were excavated, containerized, and placed in secure
storage. Interior surfaces of the arena building were either
decontaminated, or removed, containerized, and placed in secure
Page 6
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onsite storage. Portions of the building interior that were
removed were replaced with clean materials.
All contaminants identified at the site have been
containerized ang placed in interim onsite storage. A total of
3,471 cubic yards of contaminated materials are currently in
storage in the three temporary storage buildings constructed at
the site. The storage structures comply with all substantive
requirements of the Resource Conservation and Recovery Act for
the storage of hazardous materials.
VI.
SITE RISKS
contaminants of Concern
Dioxin (2,3,7,8 tetrachlorodibenzo-p-dioxin) is the only
contaminant identified at the site which exceeds health-based
levels. Dioxin is considered one of the most toxic compounds yet
identified. Although dioxin has been highly toxic in all species
tested, there are large species differences in sensitivity.
Toxicitv Assessment
Animal studies have demonstrated that dioxin is
teratogenic (causes malformities) and fetotoxic (toxic to fetus)
in mice, rats, rabbits, and ferrets. since exposure to dioxin
produced statistically significant increased incidents of tumors
in animal species, EPA has determined that there is sufficient
evidence to conclude that dioxin is an animal carcinogen. In
fact, dioxin is the most potent animal carcinogen evaluated to
date by the EPA carcinogen Assessment Group.
Considering the available animal carcinogenic and
epidemiologic data, the overall weight-of-evidence classification
categorizes dioxin (using EPA's interim classification scheme) as
a probable human carcinogen.
Dioxin will adsorb tightly to organic material in soil,
resulting in low mObility. Once in the soil, degradation
processes tend to be very slow, with half lives estimated to be
greater than ten years.
Experimental results show that dioxin will accumulate and
concentrate in fish and wildlife. In mammals, dioxin is readily
absorbed through the gastrointestinal tract. Absorption through
skin has also been reported. Absorption may decrease
dramatically if dioxin is adsorbed to particulate matter such as
activated carbon or soil. After absorption, dioxin is
distributed to tissues which are high in lipid content; however,
Page 7
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in many species the liver is a major storage area for dioxin.
Metabolism of dioxin occurs slowly, with metabolized dioxin
excreted in the urine and feces. Unmetabolized dioxin can be
eliminated in the feces.
Risks ~ Human Health and the Environment
Long-term potential for direct contact with soils was
controlled by the first operable unit which involved
containerization and secure onsite storage of contaminated
materials. The principal current concern would be for intruders
who may disturb contaminated soils, or failure of the interim
storage system. In these events, ingestion of soils or
inhalation of particulates contaminated with dioxin present the
greatest threat to human health. Wildlife (deer, turkey,
rabbits) entering th~ site area could be susceptible to
contamination in the event of failure of the storage system.
The site lies in the upper floodplain of Crooked Creek. In
the event of storage system failure, a potential exists for
surface contamination to reach Crooked Creek via stormwater.
Flooding of Crooked Creek could also cause damage to the storage
facilities.
During the previous response action, contaminated soils
exceeding health-based levels were excavated and placed in
interim onsite storage. These health-based cleanup levels were
based upon recommendations from Federal and State health
agencies.
Actual or threatened releases of hazardous substances from
this site, if not addressed by the preferred alternative, or one
of the other active measures considered, may present a current or
potential threat to public health, welfare, or the environment.
VII.
DESCRIPTION O' ALTERNATIVES
The EPA evaluated three alternatives for the final manage-
ment of stored dioxin-contaminated materials at the Shenandoah
Stables site. Further discussion concerning the previous
response action and the one part per billion cleanup level
contained in the July 28, 1988 Shenandoah Stables ROD. The final
remedial alternatives considered during this evaluation were 1)
no action, 2) continued onsite storage, and 3) thermal treatment
at Times Beach. A description of the alternatives is provided
below.
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Alternative 1 -- No Action
Evaluation of the no-action alternative is required in the
remedy selection process by the National contingency Plan. Under
the no-action al~ernative, no additional remedial actions would
be taken at the site. Maintenance of the st~rage facilities,
including the structures, containers, and fencing, would not be
provided.
This alternative has no additional capital or operation and
maintenance costs. Storage requirements for hazardous wastes
under the Resource Conservation and Recovery Act (RCRA) and the
Missouri Hazardous Waste Management Law (HWML), would not be
attained if no further action is taken at the site. This
alternative is not protective.
Alternative 2 -- continued Operation and Maintenance of Onsite
Storage
This alternative involves continued onsite storage of
contaminated materials pending final management. The storage
facilities were not designed and constructed for the purpose of
providing permanent storage. continued operation and maintenance
of the storage facilities would be provided to minimize the
potential for future release of contaminants.
The estimated ten-year operation and maintenance budget for
continued storage of contaminated materials at the Shenandoah
Stables site is $202,426. Major repair or replacement of the
storage structures would be required as the design life is met or
exceeded. The integrity of the storage containers would diminish
with time, increasing future material handling costs. No
immediate capital costs are associated with this remedy.
The primary ARARs pertaining to this alternative are RCRA
and Missouri HWML storage requirements for hazardous wastes.
Maintenance of the storage facilities and periodic inspections
would be provided in order to meet these requirements. This
alternative would be in compliance with all other identified
ARARs .
Alternative 3 -- Thermal Treatment at Times Beach
This alternative involves loading and transportation to
Times Beach of 3,471 cubic yards of stored dioxin-contaminated
materials at the Shenandoah Stables site. At Times Beach,
contaminated materials would be treated using a temporary thermal
treatment unit which is available to treat contaminated materials.
Page 9
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from a designated group of eastern Missouri dioxin sites.
designated sites are specified in the September 29, 1988,
Beach Record of Decision and July 18, 1990 Explanation of
Significant Differences for the Times Beach site.
These
Times
Residues from the thermal treatment of dioxin-contaminated
materials will be disposed as non-hazardous solid waste if RCRA
delisting criteria are achieved. Residues failing to meet
delisting criteria will be retreated or disposed of as hazardous
waste after meeting RCRA Land Disposal Restrictions (40 C.F.R.
Part 268). Following thermal treatment of dioxin-contaminated
materials from the designated eastern Missouri sites, the
temporary thermal treatment unit will be permanently removed from
Times Beach.
The three storage structures at the Shenandoah Stables site
where contaminated materials are being stored would be
decontaminated following removal of all stored materials. For
the purpose of this analysis, it is assumed that the three
storage structures will be dismantled and removed from the
Shenandoah Stables site following decontamination. The disturbed
portions of the site will be graded and revegetated. However, as
a condition of access, the site owner may elect to retain the
decontaminated buildings on the property.
The total capital cost associated with implementation of
this remedy is $2.8 million. Upon completion, all contaminants
exceeding health-based levels will have been removed or
destroyed. No operation and maintenance activities will be
necessary. Since all contaminants exceeding health-based levels
would be removed from the site and thermally destroyed, a five-
year review, pursuant to Section 121 of CERCLA, would not be
required.
The primary ARARs associated with this alternative consist
of transportation, storage, and thermal treatment requirements
under RCRA and HWML, emissions requirements for the thermal
treatment unit at Times Beach under the Clean Air Act, Missouri
Solid Waste Management Regulations, Department of Transportation
requirements, Occupational Safety and Health Administration
requirements for worker protection, and potentially National
Pollution Discharge Elimination System requirements under the
Clean Water Act, depending upon system design. This alternative
can be implemented in compliance with all identified ARARs. The
time to implement this alternative is dependent upon the
operation schedule of the temporary thermal treatment unit at
Times Beach.
It is anticipated that transport and treatment of 3471 cubic
yards of contaminated soils at the site could be completed within
Page 10
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two months during the six-year Times Beach project period assumed
in the Times Beach Record of Decision. The actual duration of
the project at Times Beach will be controlled by the operating
rate of the temporary thermal treatment unit. The transport and
treatment of materials from the Shenandoah Stables site will be
prioritized ~itn the other eastern Missouri dioxin site
materials, and could be scheduled at any time during the
operation of the thermal treatment unit.
VIII.
COMPARATIVE ANALYSIS OP ALTERNATIVES
The three alternatives described above were evaluated using
criteria presented in National contingency Plan. These criteria
relate directly to factors mandated by Section 121 of CERCLA, as
amended by the Superfund Amendments and Reauthorization Act of
1986, and considerations which measure the overall feasibility
and acceptability of the remedy.
The evaluation criteria include threshold criteria of
overall protection of human health and the environment, and
compliance with applicable or relevant and appropriate
requirements (ARARs), primary balancing criteria of long-term
effectiveness and permanence, reduction of toxicity, mobility, or
volume through treatment, short-term effectiveness,
implementability, and cost, and modifying criteria of State
acceptance and community acceptance. These evaluations are
summarized below.
Protection Q! Human Health gng ~ Environment
Protection of human health and the environment is the
central mandate of CERCLA, as amended by SARA. Protection is
achieved by reducing risks to acceptable levels and taking action
to ensure that there will be no future unacceptable risks to
human health and the environment through any exposure pathway.
Alternative 3, involving thermal treatment, provides the
highest overall protection of human health and the environment.
The Office of Solid Waste has identified Thermal treatment as the
Best Demonstrated Available Technology for dioxin destruction.
Short-term risks during thermal treatment operation associated
with emissions are controlled through continuous process and
emissions monitoring and redundant safety features. The thermal
treatment unit will be equipped with emergency shutdown systems
which activate if permit-controlled process criteria are
violated, thereby controlling the potential for release of
hazardous substances due to incinerator upsets.
Page 11
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EPA has considered the risks associated with transportation
of the dioxin-contaminated materials to Times Beach for thermal
treatment, and determined that the transportation of these
materials to Times Beach does not represent a significant risk.
The contaminated materials are relatively immobile in the
environment. Any spill of contaminated materials during
transport could be immediately and effectively cleaned up and
removed. Transportation risks will be further reduced by
designating haul routes which avoid population centers to the
extent possible. Further, the contaminated soils, which are
containerized in storage bags, will be hauled in lined truck
beds. The truck bed liner will be gathered and secured above the
contaminated soils, and covered with a tarp which will be tightly
fastened to the exterior bed walls.
Alternative 1, No Action, would not provide protection of
human health and the environment. without continued maintenance,
the stQrage systems would eventually fail, resulting in the
release of dioxin-contaminated materials to the environment.
Alternative 2, Continued Operation and Maintenance, would provide
greater overall protection than No Action, but the potential for
catastrophic failure (flood, earthquake, etc.) of the storage
facility would remain at current levels or increase as storage
systems deteriorate.
Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs)
Section 121(d) of CERCLA, as amended by SARA, requires
remedial actions comply with applicable or relevant and
appropriate requirements (ARARs) under Federal and State
environmental laws.
that
CERCLA section l04(d) (4) and CERCLA policy allows EPA to
treat two or more non-contiguous facilities as one site, where
the facilities are reasonably related on the basis of either
geography or the threat posed to human health and the
environment. EPA has determined that the eastern Missouri dioxin
sites designated above are related based on the threat posed, and
should be treated as one site for response -purposes. EPA has
also determined that a combined response action for eastern
Missouri dioxin sites will be cost-effective and protective of
human health and the environment. Accordingly, the thermal
treatment at Times Beach of dioxin-contaminated materials from
the designated locations, including Shenandoah Stables, is
considered an on-site action.
In response to public comments received during previous
public participation, EPA intends for the thermal treatment unit.
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at Times Beach to be operated under a RCRA/HWML permit. During
the public comment period for the Times Beach Proposed Plan, a
primary concern expressed was the desire to limit the operation
of the thermal treatment unit in both duration and sources of
materials which woul~ be treated. An operating permit for the
thermal treatment unit issued under RCRA and the Missouri HWML
would provide these limits on the operation of the thermal
treatment unit. Further discussion regarding the procedural
impact of the on-site determination on thermal treatment at Times
Beach is included in the Explanation of Significant Differences
for the Times Beach site (July 18, 1990) and Shenandoah Stables
Proposed Plan which appear in the Shenandoah Stables
administrative record.
The residues from an onsite thermal treatment unit located
at Times Beach must be delisted prior to disposal at Times Beach
as a non-hazardous solid waste. Because the designated dioxin
sites have been aggregated under CERCLA section 104(d) (4) and the
disposal of those residues is considered to be an on-site action,
the delisting of the residues is subject to the procedures of
CERCLA and the NCP, rather than those that would apply under
RCRA. Thus, the administrative process under RCRA for delisting
a waste -- including a formal rulemaking process -- need not be
met for Superfund wastes that will remain on-site.
Resource Conservation and Recovery Act (RCRA):
RCRA, as amended by the Hazardous and Solid Waste Amendments
(HSWA) of 1984, regulates the generation, transportation,
treatment, storage, and disposal of hazardous wastes as defined
in 40 CFR Part 261. The Missouri Hazardous Waste Management Law
(HWML) and implementing regulations are very similar to the
Federal RCRA program in almost all respects. As of July 15,
1986, certain dioxin-containing wastes are specifically regulated
under RCRA as hazardous wastes (the "dioxin rule," 50 FR January
14, 1985). certain requirements under RCRA are considered
applicable to the containerized dioxin-contaminated materials at
the Shenandoah Stables site.
The RCRA land disposal ban under 40 CFR Part 268 prohibits
land disposal of dioxin-contaminated material after November 8,
1988. Due to a national lack of treatment capacity, a two year
extension of this date to November 8, 1990 has been granted for
soil and debris generated during Superfund actions. The so-
called RCRA "Land Ban" does not constitute an ARAR for
alternatives 1 and 2 since land disposal of RCRA hazardous wastes
is not included in these alternatives. The RCRA Land Ban will be
complied with by the selected alternative by delisting of the
thermal treatment residue prior to land disposal.
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Alternatives 2 and 3 are in compliance with all identified
ARARs under RCRA. Alternative 3 can be implemented in accordance
with requirements under 40 CFR Part 264 for owners and operators
of hazardous waste treatment, storage, and disposal facilities,
and 40 CFR Part 263 for transporters of hazardous waste and
applicable requirements administered by the Department of
Transportation. The primary requirements to be met prior to
thermal treatment of dioxin-contaminated soil under RCRA and HWML
include demonstration of six-nines destruction and removal
efficiency and delisting of the thermal treatment residue.
Compliance with requirements under 40 CFR Part 264, Subpart
I for the use and management of containers would not be
maintained if the no-action alternative were selected.
Federal and State Water Quality Criteria:
Federal ambient water quality criteria (established pursuant
to Section 303 of the Clean Water Act at 40 CFR Part 120) provide
an estimate of the ambient surface water concentration that will
not result in adverse health effects in humans, or the
concentrations associated with certain incremental cancer risks.
The federal and state ambient water quality criteria for 2,3,7,8-
TCDD is zero. Federal and state ambient water quality criteria
are applicable to any alternative involving wastewater discharge
to surface waters or land application in excess of consumptive
rates.
Runoff carrying contaminated soil particles would be
controlled during implementation of the preferred remedial action
in order to eliminate non-point discharges.
Alternatives land 2 involve no wastewater discharge of any
type. Alternative 3 may utilize wet air pOllution control sys-
tems which generate wastewater that must be discharged following
attainment of delisting criteria. In this event, the wastewater
discharge will be in compliance with the substantive provisions
of the Clean Water Act and Missouri Clean Water Law.
Federal and state Air Pollution Control Requirements:
The Federal and Missouri Clean Air Acts specify air quality
standards and regulate hazardous substance emissions from
stationary sources. The Missouri Air Pollution Control
Regulations, administered by the Air Conservation Commission at
10 CSR 10, regulate contaminant and particulate air emissions
from a variety of sources. Regulations under RCRA (40 C.F.R.
Page 14
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Part 264, Subpart 0) also stipulate emission limits for
incinerators.
These requirements are applicable to Alternative 3 which may
result in emissi9ns ~f fugitive particulate matter (dust), and
air emissions from the thermal treatment unit. Dust control
measures will be implemented as necessary during material
handling in order to minimize the potential for generation of
fugitive dust. Air emissions will be in compliance with
substantive requirements of the Federal Clean Air Act and
Missouri Clean Air Act.
Reduction of Toxicity. Mobilitv or Volume throuqh treatment
This evaluation criteria relates to the performance of a
technology or remedial alternative in terms of eliminating or
controlling risks posed by the toxicity, mobility, or volume of
hazardous substances.
Alternative 3 involves thermal treatment of all site
contaminants which exceed health-based levels. Thermal treatment
destroys the contamination, thereby eliminating the toxicity,
mObility, and volume of contaminants. Thermal ,treatment will
result in only a slight volume reduction of the soil matrix which
contains the contamination prior to treatment, due to destruction
of the organic matter in the soil.
Alternatives 1 and 2 do not involve treatment, and do not
reduce toxicity, mobility, or volume of contaminants. In the
event of storage system failure resulting in a release, the
volume and mobility of site contaminants may be increased.
Short-Term Effectiveness
Short-term effectiveness addresses the time to achieve
protection and the potential adverse impacts of its
implementation.
Short-term risks at Times Beach associated with thermal
treatment can be effectively controlled through process and
emissions monitoring. Long-term protectiveness will be achieved
at the Shenandoah Stables site following transport of
contaminated materials from the site and decontamination of the
structures. The schedule for transport of materials to Times
Beach is dependent upon the schedule for operation of the
temporary thermal treatment unit. Short-term risks associated
with transportation of contaminated materials to Times Beach are'
discussed above.
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Short-term risks associated with interim storage prior to
thermal treatment are the equivalent of short-term risks
associated with Alternative 2.
Alternatives 1 and 2 involve no material handling or
disturbance, resulting in minimal short-term impacts.
Lonq-Term Effectiveness and Permanence
Long-term effectiveness and permanence addresses the long-
term protection and reliability an alternative affords.
Alternative 3 involves thermal treatment, which permanently
destroys the dioxin contamination, providing the highest level of
long-term protectiveness.
Alternatives 1 and 2 do not constitute permanent remedies.
Alternative 1 involves no further action at the site. Without
continued maintenance of the storage facilities, the storage
containers and buildings would eventually fail, resulting in a
release of contaminants into the environment. This alternative
does not provide long-term protectiveness. Alternative 2
provides continued maintenance of the storage facilities, but
future release due to catastrophic failure is possible.
Furthermore, without treatment to reduce contaminant levels, the
stored materials would continue to be highly toxic.
ImDlementabilitv
Implementability addresses how easy or difficult, feasible
or infeasible, an alternative would be to carry out from design
through construction, operation and maintenance.
Thermal treatment represents a relatively complex operation,
involving many interrelated activities which must be coordinated
in order to effectively and safely destroy the dioxin
contamination. Thermal treatment of contaminated soils has,
however, been successfully demonstrated on at least 10 full-scale
projects nationwide, and has been selected for implementation at
more than 50 projects involving hazardous materials. Process
controls and monitoring assure that thermal treatment is
conducted safely and effectively.
Alternatives 2 involves continued maintenance of the storage
facilities. This maintenance will become increasingly difficult
and costly as the storage systems reach and exceed their design
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lives. Alternative 1 involves no action, and requires no
implementation.
Cost
CERCLA requires that EPA select the most cost-effective (not
merely the lowest cost) alternative that protects human health
and the environment and meets other requirements of the law.
The total cost of alternative 3 is largely dependent upon
the actual unit cost of thermal treatment. Thermal treatment
cost estimates have ranged from less than $200 per cubic yard to
over $1,000 per cubic yard. The cost of ancillary operations and
requirements such as flood protection, soil handling and
preparation, and ash disposal are additional and increase the
total projected unit treatment cost. This alternative offers a
high degree of protectiveness relative to its cost.
The cost of Alternative 3 has the highest cost of the
alternatives considered. The annual cost of Alternative 2 is
relatively low. However, these costs can be expected to increase
as major repair of the storage facilities becomes necessary. No
cost is associated with the no action alternative.
Community AcceDtance
This evaluation criteria addresses the degree to which
members of the local community support the remedial alternatives
being evaluated.
Public comment periods were conducted concurrently for the
Shenandoah Stables Feasibility Study and Shenandoah Stables
Proposed Plan. No written comments were received from residents
near the Shenandoah Stables site. Two sets of comments were
received from the Mayor and City Attorney of Fenton, Missouri,
located near the Times Beach site. These written comments
expressed concern about possible adverse impacts of operation of
a temporary thermal treatment unit at Times Beach.
During the September 19, 1990, public meeting conducted for
the Shenandoah Stables Feasibility Study and Proposed Plan, local
residents indicated support for the project. The Lincoln County
Commission also expressed support of the project during a
separate meeting conducted on September 19, 1990. One individual
at the September 19, 1990, public meeting did express concern
regarding potential adverse impacts of operating a thermal
treatment unit at Times Beach. Written comments were also
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received from this individual.
considerable public involvement preceded the Times Beach
remedy selection which established treatment capacity at Times
Beach for the materials at the Shenandoah Stables site. The
local community.near Times Beach has demonstrated divided support
for the various alternatives evaluated due to short-term remedial
action impacts and aesthetic impacts. Many residents of the
neighboring community of Eureka perceive the implementation of
any onsite disposal or thermal treatment alternative as a threat
to the economic development and stability of their community.
Some Eureka residents proposed that a remedial action be
implemented at Times Beach consisting of installation of an
impermeable membrane covered with a vegetated soil layer.
other residents near the Times Beach site have supported
centralized thermal treatment of soils from Times Beach and other
eastern Missouri dioxin sites.
Thermal treatment conducted onsite at the Shenandoah Stables
property was rejected during screening of potential remedial
alternatives. In 1983, upon discovery of contamination at the
site, operation of the ongoing business at the site was ordered
closed until contaminated soils were excavated and placed in
interim onsite storage. A significant loss of revenue to the
site owner resulted during this extended period of business
closure. Following completion of the Operable Unit Remedial
Action in May, 1989, health-based levels were achieved by
excavation and containment of contaminated soils exceeding
health-based levels, and business operations were allowed to
resume. Onsite thermal treatment at Shenandoah could not be
implemented without further disruption of business activities at
the site.
In addition, the Shenandoah Stables Feasibility Study
eliminates this alternative during the screening process due to
the high cost relative to thermal treatment at a centralized
location. Economies of scale are gained by treating contaminated
materials from eastern Missouri locations at a single
centralized site. Costs associated with site preparation,
mobilization, demobilization, and closure represent a substantial
portion of the overall cost of the project. By thermally
treating contaminated materials from a number of sites at a
centralized location, these fixed costs can be distributed
between the various sites.
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State AcceDtance
The state acceptance criteria addresses the concern and
degree of support that the state government has expressed
regarding the remedial alternatives being evaluated.
The State of Missouri is a party to a Consent Decree with
the United States of America and the Syntex defendants named in
the U.S. y Bliss civil action described above. This Consent
Decree provides for a mixed-work settlement for the designated
eastern Missouri dioxin sites, including Shenandoah Stables.
Under the mixed-work arrangement, EPA, the State of Missouri, and
Syntex have responsibilities for various portions of the overall
project. The remedy described by this proposed plan is
consistent with the Consent Decree, which has been approved by
the State of Missouri.
The Shenandoah Stables Proposed Plan was provided ~o the
State of Missouri for comment in accordance with statutory
provisions of SARA, Section 121(f) (1) (G). The State has
indicated support of the selected remedy.
IX.
THE SELECTED REMEDY
The Agency has selected Alternative 3, Thermal Treatment at
Times Beach, for final management of dioxin-contaminated
materials at the Shenandoah Stables site. Alternative 3 involves
transportation of 3,471 cubic yards of dioxin-contaminated soils
currently in storage at the Shenandoah Stables site to Times
Beach for thermal treatment. Thermal treatment residues will be
land disposed onsite in accordance with the approved delisting
petition and RCRA Land Disposal Restrictions. Following
transport of dioxin-contaminated materials to Times Beach for
treatment, the storage buildings constructed at the Shenandoah
Stables Site will be decontaminated and removed from the site, if
necessary. Following removal of the storage facility, this
portion of the site would be restored.
x.
STATUTORY DETERMINATIONS
Based upon available information, the selected remedy
satisfies the remedy selection requirements under CERCLA, as
amended by SARA and the National Contingency Plan. The remedy
provides protection of public health and the environment,
achieves all applicable or relevant and appropriate requirements,
is cost-effective, utilizes permanent solutions to the maximum
extent practicable, and satisfies the statutory preference for
remedies involving treatment as a principal element.
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Protection of Public Health and the Environment
The selected remedy for the Shenandoah Stables site provides
a high degree of protection of public health and the environment
and permanence. No other alternative identified offers an
equivalent degree of long-term protection. The selected remedy
is the only alternative identified which permanently attains the
level of cleanup recommended for Shenandoah Stables by state and
Federal health agencies.
The primary environmental concern at the Shenandoah Stables
site is the potential release of dioxin-contaminated soil into
the environment and subsequent exposure to environmental
receptors. Release of contamination into the environment is
currently controlled by the interim storage systems. Continued
monitoring and maintenance pending implementation of the selected
remedy will control the potential for release. Any spills of
contaminated materials which may occur during transport of
materials to Times Beach can be immediately and effectively
cleaned up, and the spilled contaminated materials transported to
Times Beach for treatment. The selected remedy involves thermal
treatment which permanently destroys the site contaminants. Once
destroyed, the potential for environmental exposure is
eliminated. .
Attainment of ARARs
The selected remedy will achieve the provisions of all
applicable, or relevant and appropriate requirement (ARARs) for
the protection of public health and the environment. Thermal
treatment at Times Beach can be performed in compliance with
hazardous waste requirements under RCRA and HWML, emissions
requirements under the federal and state clean air laws and
federal and state clean water laws, and all applicable
transportation requirements. Primary requirements to be met
prior to thermal treatment of soil include demonstration of six-
nines destruction and removal efficiency and delisting of the
thermal treatment residue. Prior experience by the Agency with
the EPA mobile incinerator in southwest Missouri and other
similar projects has indicated that these requirements can be
achieved with commercially-available thermal treatment
technologies.
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Preference for Treatment
The selected remedy satisfies the statutory preference
(established by SARA) for remedies involving treatment which
result in the permanent reduction of the volume, toxicity, or
mobility of haz~rdous substances which constitutes the principal
threat at the site. Thermal treatment destroys the dioxin
contamination, thereby eliminating the toxicity of the treated
soil. Since the dioxin contamination in the treated soil is
destroyed, the potential mobility of this contamination is also
eliminated.
Cost Effectiveness
Centralized the~al treatment of contaminated soils from the
designated eastern Missouri dioxin sites provides substantial
economies of scale, resulting in a cost-effective comprehensive
remedy for the identified eastern Missouri dioxin sites.
Although the selected remedy has the highest associated cost of
any of the alternatives evaluated, no other remedial alternative
provides this high level of protection at a lesser cost. In
consideration of the benefits provided by thermal treatment, the
selected remedy has been determined to be cost-effective.
XI.
DOCUMENTATION OP SIGNIPICANT CHANGES
The EPA has selected a remedy consisting of treatment of
dioxin-contaminated soil at a temporary thermal treatment
facility to be operated at Times Beach. This selected remedy is
identical to the remedy proposed in the Proposed Plan of
August ,24, 1990.
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RESPONSIVENESS SUMMARY
RECORD OF DECISION
POR
PINAL MANAGEMENT OF
DIOXIN-CONTAMINATED SOIL
SHENANDOAH STABLES
LINCOLN COUNTY, MISSOURI
Prepared by
u.s. ENVIRONMENTAL PROTECTION AGENCY
september 28, 1990
-------
RESPONSIVENESS SUMMARY
Record of Decision for
FinaJ. 'Manageme~t of Dioxin-contaminated Soil
Shenandoah Stables
Lincoln County, Missouri
This document addresses all comments received by the
Environmental Protection Agency (EPA) during the public comment
period conducted as part of the remedy selection process for the
final operable unit for the Shenandoah Stables site.
INTRODUCTION
On August 24, 1990, EPA released the Feasibility StudY for
the Shenandoah Stables Site and the ProDosed Plan for Final
Manaqement of Dioxin-Contaminated Soil. Shenandoah Stables.
Lincoln County. Missouri for public comment. According to the
proposed plan for the final management of dioxin-contaminated
materials at the Shenandoah Stables site, materials containerized
and placed in interim onsite storage during a previous response
action (Operable Unit no. 1) would be transported to Times Beach
for thermal treatment. Following transport of containerized
materials from the site, the storage structures would be
decontaminated and removed. Portions of the site disturbed by
the remedial action would be restored.
PUBLIC PARTICIPATION
Public comments regarding the Shenandoah Stables Feasibility
Study and Proposed Plan were accepted by the Agency from August 24,
1990 through September 24, 1990. In addition, a pUblic meeting
was conducted at 7:30 p.m., September 19, 1990 at the Moscow
Mills Community Center to present the Feasibility Study and
Proposed Plan and accept public comment. During the public
meeting, written materials were submitted for the record by one
attendee. These materials have been reviewed by EPA and included
in the administrative record. A transcript of the public meeting
has also been prepared and placed in the administrative record.
During the public comment period, two sets of written
comments were received by the Agency. These comments have been
-------
added to the administrative record for this site. This
responsiveness summary has been prepared to address these
comments.
This Responsiveness Summary represents a component of the
Record of Decision (ROD) package, which also includes the ROD
declaration, RO~ summary, and index to the administrative record.
Formal selection of the final management alternative to be
implemented at the Shenandoah Stables site occurs by signature of
the ROD declaration by the Regional Administrator for EPA Region 7.
WRITTEN COMMENTS RECEIVED rBQM THE PUBLIC
Many of the written comments received by the Agency
dealt with the use of the temporary thermal treatment unit at
Times Beach to treat dioxin-contaminated materials from the
Shenandoah Stables site. The decision that the Times Beach
thermal treatment unit would be available to treat materials from
the Shenandoah Stables site was included in the September 29,
1988, Record of Decision for the Times Beach site. The
availability of the thermal treatment unit at Times Beach to
treat materials from other designated eastern Missouri dioxin
sites, including Shenandoah Stables, was established during the
1988 remedy selection process. Many of the comments received by
the Agency, therefore, do not pertain to the immediate remedy
selection under consideration for the Shenandoah Stables site.
Nevertheless, responses will be provided to these comments in
instances where similar comments were not received during the
public comment period preceding issuance of the Times Beach
Record of Decision.
Two comment letters were received during the public comment
period. Individual comments and the Agency's responses to these
comments follow:
Comment: "The pUblic hearing on this matter was not widely
advertised."
Response: On September 12, 1990, an announcement of the
September 19, 1990, public meeting was directly mailed to all
parties listed in the Shenandoah Stables Community Relations
Plan. This list includes area residents, local officials, state
and 'federal legislators, area newspapers, and area television and
radio stations. EPA believes that sufficient notice was provided
prior to the public meeting.
Comment: "There has been no cost-benefit analysis of any
alternatives to burning dioxin at Times Beach."
Response:
The evaluation of alternatives performed in the
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feasibility studies prepared for the Times Beach and Shenandoah
Stables sites included a cost analysis. The cost analyses
performed in these studies did consider alternatives to thermal
treatment of dioxin-contaminated materials from designated
eastern Missouri sites at Times Beach. The Agency has determined
that the selected remedy for the Shenandoah Stables site is cost-
effective.
Comment:
areas;"
"--no incineration at Times Beach of dioxin from other
Response: The availability of the Times Beach thermal treatment
unit to treat dioxin-contaminated soils from a designated group
of eastern Missouri sites was established by the September 29,
1988, Times Beach Record of Decision. The Agency addressed this
issue extensively during the public comment period prior to
issuance of the Times Beach Record of Decision. The Agency's
response to this comment is presented in the September 28, 1988,
Times Beach Responsiveness Summary. This document has been
included in the administrative record file for the Shenandoah
Stables site.
Comment:
"...no illeqal use of the floodplain;"
Response: A ring levee will be constructed to protect the
temporary thermal treatment unit from flooding. Implementation
of the remedy at Times Beach is not illegal. The selected
remedies for Times Beach and the Shenandoah Stables site comply
with CERCLA and all applicable or relevant and appropriate
federal and state requirements (ARARs).
Comment: "...no aqreements consummated behind closed doors;...no
more deceitful government gestures."
Response: Remedy selection for final management of dioxin-
contaminated materials from eastern Missouri has been, and will
continue to be, subject to public participation requirements
under the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA), as amended, and the National
Contingency Plan.
A public comment period for the Shenandoah Stables
Feasibility study and Proposed Plan was conducted from August 24,
1990 through September 24, 1990. A public meeting was held
September 19, 1990, at the Moscow Mills Community Center to
discuss these documents.
The PUblic was also afforded an opportunity to provide
comments regarding the Consent Decree between the federal and
state governments and Syntex entities for the designated eastern.
Missouri sites. This public comment period began on August 8,
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1990, and closed September 7, 1990.
Comment:
". . . no
pol1ut.ion of our vat.er 8upply and air;1I
Response: The Agency has previously provided a response to this
comment in the ~eptember 28, 1988, Times Beach Responsiveness
Summary. This document has been included in the administrative
record file for the Shenandoah Stables site. Protection of human
health and the environment is a threshold criteria for remedial
actions under CERCLA. The remedy selected for the Shenandoah
Stables site is protective. A component of the selected remedy
involves thermal treatment of contaminated soils. Air pollution
control equipment and measures taken to control wastewater emis-
sions from the thermal treatment unit will assure that no release
of contaminants occurs which endangers public health and the
environment.
Comment:
"...no stiqma for our area"
Response: The remedy selected for Times Beach is intended to
remove the stigma of a hazardous waste site from the area. Once
the dioxin contamination is destroyed, the abandoned structures
and debris are disposed of, and the area is restored, this stigma
can and will be removed from Times Beach and the eastern Missouri
dioxin sites.
Comment: "...no more decisions to .erve syntex and not the
resident.s;"
Response: Syntex entities are potentially responsible parties
that are signatories to a Consent Decree lodged with federal
court for a comprehensive cleanup of eastern Missouri dioxin
sites. This Consent Decree is independent of the
Agency's remedy selection process. The Consent Decree partially
resolves civil litigation pending since January, 1984, in the
Federal District Court for the Eastern District of Missouri. The
remedy selected in the Times Beach Record of Decision and the
remedy presented in the Shenandoah Stables Proposed Plan do not
serve the interests of Syntex. If the remedy as set forth in the
Consent Decree is implemented, Syntex will incur considerable
expense in performing aspects of the cleanup which are their
responsibility under the Decree.
Comment: Remedy selection for the Time. Beach site should be
deferred until additional techDoloqy develops.
Response:
selection.
Times Beach
record. As
there is no
This comment pertains to the 1988 Times Beach remedy
The commentor is referred to the September 28, 1988,
Responsiveness Summary included in the administrative
explained in the Times Beach responsiveness summary,
assurance that an alternate technology capable of
Page 4
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achieving the cleanup goals will be identified in the near
future. The storage facilities are not designed to perform
indefinitely. Thermal treatment represents a safe, reliable, and
effective solution to the eastern Missouri dioxin problem.
Comment: "The p~oposed plan places too qreat an emphasis on the
cost effectiveness as opposed to the economic effect on local
communities."
Response: Remedy selection at the Shenandoah Stables site is
subject to requirements of CERCLA and the National Contingency
Plan. Remedial alternatives are evaluated in terms of nine
specified criteria. Cost is included among these criteria. In
addition, the Agency must make the determination that the
selected remedy is cost-effective. The selected remedy at the
Shenandoah Stables site meets the requirements and goals of
CERCLA and the Natior-al contingency Plan.
Comment: "The proposed plan does not have as its principal
concern public safety."
Response: One of two threshold criteria considered in the CERCLA
remedy selection process is protection of human health and the
environment. The second threshold criterion consists of
compliance with ARARs. These two criteria are the principal
considerations during the remedy selection process, and must be
attained for all CERCLA remedies. These criteria are achieved by
the remedy selected for the Shenandoah Stables site.
Comment: "The proposed plan disturbs dioxin that is isolated and
contained, and moves it to Times Beach."
Response: Transport of dioxin-contaminated materials from the
Shenandoah Stables site to Times Beach will involve loading of
the containerized materials currently in storage buildings onto
trucks and transportation to Times Beach. Precautions will be
taken during the loading and transport operations to control the
potential for spillage of contaminated materials. In the event
of a spill of contaminated materials, emergency response
personnel will immediately contain the spilled material and
recontainerize the spilled material for transport to Times Beach.
This consideration was included in the shott-term effectiveness
evaluation performed during the remedy selection process.
Removal of the containerized materials in temporary storage at
the Shenandoah Stables site will not endanger public health or
the environment.
Comment: "The proposed plan brings aore dioxin into a heavily
populate4 economic growth center."
Response:
This comment pertains to the 1988 remedy selection for
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the Times Beach site. The commentor is referred to the September
28, 1988, Times Beach Responsiveness Summary included in the
administrative record.
EPA acknowledges that the remedy selected in the 1988 Times
Beach Record of Decision potentially brings dioxin-contaminated
materials from designated eastern Missouri sites to Times Beach
for thermal treatment. However, as explained in the 1988 Times
Beach Record of Decision, the selected remedy best satisfies the
statutory and regulatory goals and requirements of CERCLA and the
National Contingency Plan. The Agency believes that the remedy
can be implemented safely.
Comment: "Transporting dioxin from other sites to Times Beach
will constitute major traffic and health hazards."
Response: This comment pertains to the 1988 Times Beach remedy
selection. The commentor is referred to the September 28, 1988,
Times Beach Responsiveness Summary included in the administrative
record.
As indicated during the public meeting preceding the 1988
Times Beach Record of Decision, haul routes for any materials
transported to Times Beach will be designated on the basis of a
Transportation Study. This transportation study evaluates the
characteristics of alternate routes from each of the eastern
Missouri dioxin sites to Times Beach. In addition, safety
measures will be taken during transportation operations to assure
that health hazards are not created. Traffic hazards will be
controlled through route selection and transport during non-peak
hours. .
Comment: "The fact that Times Beach is in the flood plain makes
it an inappropriate site to:
a.
Transport dioxin-contaminated 80il from other sites:
Store dioxin-contaminated 80i1 from other sites; and
)).
c.
Operate an incinerator."
Response: This comment pertains to the 1988 Times Beach remedy
selection. The commentor is referred to the September 28, 1988
Times Beach Responsiveness Summary included in the administrative
record. The thermal treatment unit, and ancillary operations
such as the soil staging area, will be protected from flooding by
a ring levee constructed prior to mobilization.
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Comment: ".e request that the
participation or level thereof
by the NCP, in particular with
agreement."
EPA in the ROD demonstrate the
of local communities as required
reference to the confidentiality
Response: Public participation that occurred during the
Shenandoah Stables remedy selection process for final management
of dioxin-contaminated materials is described in the Record of
Decision for the Shenandoah Stables site and further described in
this Responsiveness Summary.
The confidentiality agreement mentioned in the comment is an
apparent reference to the agreement which was entered into
between the federal, state, and local governments and potentially
responsible parties during settlement negotiations related to
litigation on the eastern Missouri dioxin sites. These
settlement negotiations are independent of the CERCLA remedy
selection process. These settlement negotiations did not involve
selection of a remedy, but rather concerned the implementation of
the EPA-selected remedies to clean up the eastern
Missouri dioxin sites and return them to beneficial use.
Comment: We request the EPA fully direct their consideration of
dechlorination in general and the Apeg-Plus process in particular
as a proposed remedial action.
Response: During the remedy selection process for Times
Beach, alternative technologies were considered for treatment of
dioxin-contaminated materials in eastern Missouri. The APEG
technology is among the technologies evaluated in the Times Beach
Feasibility Study, released December 14, 1986. At the time of
the Times Beach remedy selection, EPA made the determination that
thermal treatment was the only full-scale technology that had
demonstrated the capability of safe, reliable and complete dioxin
destruction in contaminated soils.
Since the issuance of the Times Beach Record of Decision,
EPA has continued to evaluate emerging technologies for dioxin
destruction. The APEG-Plus process is a type of chemical
dechlorination process that has demonstrated effectiveness for
certain waste streams during the past several years. Included in
the Shenandoah Stables administrative record are documents
further describing these processes. To date, chemical
dechlorination processes have not demonstrated the ability to
reliably destroy dioxin-contaminated materials similar in volume
and nature to the contaminated materials from the eastern
Missouri dioxin sites.
During the remedy selection process for the Shenandoah
Stables site, EPA has determined, in consideration of information
reported since 1988 concerning the performance of chemical
Page 7
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dechlorination processes, that thermal treatment remains the only
treatment technology which is capable of safe, reliable, and
complete destruction of dioxin in the eastern Missouri
contaminated soils. Thermal treatment best satisfies the remedy
selection criteria under CERCLA and the National contingency
Plan, and attain~ the statutory mandates and goals of CERCLA.
The non-homogeneity of the eastern Missouri dioxin-
contaminated materials is a primary consideration in the
selection of treatment technology. In addition to the different
soil types which have become contaminated throughout eastern
Missouri, a substantial volume of non-soil material have also
become contaminated and will require treatment. These materials
include concrete, wood, steel, rubber tires, plastics, and
fabrics. Full-scale chemical dechlorination processes have not
been effectively demonstrated on waste streams as varied as the
eastern Missouri dioxin-contaminated materials.
Federal laws and regulations control the disposal of
specified hazardous wastes which appear on a number of lists in
the federal regulations. Dioxin-contaminated soils from the
eastern Missouri dioxin sites constitute a listed hazardous
waste. All treatment technologies which could be used to reduce
the toxicity of these materials will unavoidably produce a
treatment residue. Before a residue from the treatment of a
listed hazardous waste can be land disposed as a non-hazardous
solid waste, it must be "delisted". Delisting involves a
demonstration through testing that the material no longer
contains hazardous constituents and does not display hazardous
characteristics.
An important consideration in the decision to select.
thermal treatment is the demonstrated ability of this technology
to attain delisting levels. Thermal treatment has attained
delisting levels for waste streams similar to the different types
of dioxin-contaminated materials in eastern Missouri. Following
thermal treatment of eastern Missouri dioxin-contaminated
materials, EPA anticipates that the treatment residue can be
delisted and land-disposed on-site at Times Beach as a non-
hazardous solid waste.
Chemical dechlorination has not effectively demonstrated
that delisting levels can be consistently achieved for materials
similar in nature to the eastern Missouri dioxin-contaminated
materials. If delisting can not be achieved, the treatment
residues must be subsequently managed at a hazardous waste
facility which is permitted for dioxin wastes. There currently
are no facilities in the country which have been issued the
necessary permits to receive dioxin wastes. Regardless of the
lack of permitted facilities, offsite disposal of hazardous
treatment residue would substantially increase the cost of the
project.
Page 8
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RECORD OF DECISION DECLARATION
BITE NAME AND LOCATION
Shenandoah Stables, Lincoln County, Missouri
STATEMENT OF BASIS .AND PURPOSE
This decision document presents the selected remedial action
for the Shenandoah Stables site in Lincoln County, Missouri,
developed in accordance with the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA), as
amended by the Superfund Amendments and Reauthorization Act of
1986 (SARA), and, to the extent practicable, the National Contin-
gency Plan (NCP). This decision is based on the administrative
record for this site. The State of Missouri concurs with the
selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this Record of Decision (ROD), may present an immi-
nent and substantial endangerment to public health, welfare, or
the environment. .
DESCRIPTION OF THE SELECTED REMEDY
This remedial action represents the final action for dioxin-
contaminated soils at the Shenandoah Stables site. During a
previous operable unit, dioxin-contaminated materials exceeding
health-based levels at Shenandoah Stables were excavated,
containerized, and placed into interim onsite storage pending
final management. This ROD selects a final remedy for the
contaminated materials currently in storage at the Shenandoah
Stables site. The primary components of the selected remedy
include:
.
Transportation of 3,471 cubic yards of contaminated
materials to the Times Beach site,
.
Thermal Treatment of these contaminated materials at a
temporary thermal treatment facility to be operated at
Times Beach, and
.
Final restoration of the Shenandoah Stables site.
This remedial action addresses the principal threats at the
site by thermal treatment of soils exceeding health-based levels.
Thermal treatment results in the destruction of dioxin in the
treated soils, permanently removing this contamination from the
environment.
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DECLARATION
The selected remedy is protective of human health and the
environment, complies with Federal and state requirements that
are applicable or relevant and appropriate to this remedial
action, and is cost-effective. This remedy utilizes permanent
solutions and alternative treatment technology to the maximum
extent practicable, and satisfies the statutory preference for
remedies that employ treatment that reduces toxicity, mobility or
volume as a principal element.
Because this remedy will not leave hazardous substances
onsite above health-based levels, the five-year review will not
apply to this action.
~ / {~y
Administrator
1'2-9'-~D
Date
-------
JOHN ASHCROFT
~
DIVISIon of Enc:rg\"
Dhision 0( En",ronrnc:nuJ Q\W.aIY
Di",Slon of G<:olog- ~nd L1nd Su~.
Division 0( M;uu~mc:nt Sc:I"\KeS
Di",sion of Parlc.s Recreation.
and H.istOnc PreSC=I"\':Iuon
G. TRACY MEHA.'\T III
RECti v. ~iJ
STATE OF MISSOL'RI
DEPARTMENT OF NA 11.JRAL RESOURCES
OFFICE OF THE DlREcrOR
P.O. Box 176
Jdferson Oty. MO 65102
314.'"'51-4422
~tor
nr,T 1 9 1990
REGIOAAl ADMINISTRATQB
o~tober 10, 1990
Mr. Morris Kay
Regional Administrator
U. S. Environmental Protection
Agency, Region VII
726 Minnesota Avenue
Kansas City, KS 66101
Dear Mr. Kay:
The Missouri Department of Natural Resources has reviewed the draft Record
of Decision for the Shenandoah stables site in Lincoln County, Missouri.
The Department concurs with the preferred alternative of thermal treatment
at Times Beach--Alternative *3 as described in the draft Record of
Decision.
If you have any questions concerning this matter, please do not hesitate
to contact me.
,-
f
WtL
Very truly yours,
GTM: jbh
cc:
Mr. Robert Morby, USEPA
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