United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R07-91/056
September 1991
Superfund
Record of Decision:
Ellisville Area (Amendment), MO
-------
"10272.101
REPORT DOCUMENTATION 1'. AEPOATNO.
PAGE EPA/ROD/R07-91/056
1d Subfte
u~PERFUND RECORD OF DECISION
Ellisville Area, MO
First Remedial Action - Amendment
7. Aulhor1a)
I ~
3. ReclpIent'a Acce88lon No.
4
5. Report Date
09/30/91
6.
6. Perfonnlng Organization Rept. No.
8. P8rformIng Org8lnlz8tlon Name end Add-
10. ProjectlTuklWork Unit No.
11. ContreC1(C) 01 Grant(G) No.
(C)
(G)
1~ Sponaoring Org8niDllon Name end Addre..
U~S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type o' RepoI1 & Period Covered
Agency
800/000
14.
15. Supplementary No...
. .
11. Ab81r8~ (Umft: 200 wolda)
The Ellisville Area site is a former waste oil disposal site in Ellisville, St. Louis
County, Missouri. The site consists of the 11.6-acre Bliss property and four
contiguous properties where hazardous substances have been identified. Land use in
the area is mixed residential, rural, and recreational. Surface runoff at the site
~ins to Caulks Creek, a tributary of Bonhornrne Creek, which enters the Missouri
ler about 1 mile upstream of a city of St. Louis waterworks intake. The site does
not lie in a floodplain, but flooding of Caulks Creek occurs during periods of heavy
rain. During the 1960's and 1970's, Bliss Waste Oil Company used the site to
transport and dispose of waste oil products (some of which were contaminated with
dioxin), industrial wastes, and chemical wastes. Liquid wastes were poured into
pits, applied to the ground surface, and stored in drums and buried.
Dioxin-contaminated waste oil was applied directly to surface soil for dust control,
and spillage from trucks also occurred. Investigations conducted from 1982 through
1983 concluded that site contamination was not affecting the ground water; however,
some onsite surface migration of contaminated soil and sediment had occurred. In
1985, the State constructed a diversion dike to redirect stormwater runoff, which
(See Attached Page)
17. Docum8nt An8/y8Ia L DHcrIpIora
Record of Decision - Ellisville Area, MO
First Remedial Action - Amendment
Contaminated Medium: soil
Key Contaminants: organics (dioxin)
b. IdIntlfler8/ep..-Encfed Tenne
~OSA 11 ReId1Group
lability Statement
18. Security CIa.. (Thia Report)
None
20. Security CIa.. (Thia Page)
Nnnp
21. No. of Pages
44
n Price
(See ANSl-Z3I.18)
See InalTuCtionlJ on Reverse
14- 7)
(Formelly NTI5-35)
Department O. Commerce
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EPA/ROD/R07-91/056
Ellisville Area, MO
F'-st Remedial Action - Amendment
i
tract (Continued)
flowed through a fill area containing buried drums; and fenced the site. A 1986 Record
of Decision (ROD) selected a final remedy for non-dioxin wastes at the site and an
interim remedy for dioxin waste at the site including excavation and interim onsite
storage of dioxin-contaminated materials. The interim remedy has not been implemented.
A 1988 ROD established the availability of a thermal treatment unit at the Times Beach
site to treat dioxin-contaminated sites in eastern Missouri including the Ellisville
area. This ROD amends the 1986 ROD because the pending availability of a thermal
treatment unit at Times Beach has prompted EPA to reconsider the need for excavation and
interim onsite storage. This ROD also provides a final remedy for dioxin-contaminated
soil, which involves excavation and direct transport of dioxin wastes offsite for
treatment. The 1986 remedy for non-dioxin wastes is not affected. The prima.ry
contaminant of concern affecting the soil is dioxin, an organic.
The amended remedial action for this site includes excavating, and direct transportation
of approximateiy-7,OOO cubic yards of dioxin-contaminated soil for treatment at an
offsite temporary thermal treatment unit constructed at the Times Beach site; disposing
of treatment residuals at the Times Beach site as nonhazardous solid waste, if delisting
criteria are met, or. retreating at Times Beach or managing residuals offsite as a
hazardous waste if delisting criteria are not met. No costs were provided for this
amended remedial action.
PERFORMANCE STANDARDS OR GOALS: Performance standards for the thermal treatment of soil
include six-nines (99.9999 percent) destruction and removal efficiency and delisting of
~ thermal treatment residue.
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RlCORD or DECISION DECLARATION
SITE ~ ~ LOCATION
Ellisville Area Site (Bliss portion), Ellisville,
St. Louis County, Missouri
STATEMENT Ql BASIS ~ PURPOSE
This decision documpnt presents the selected remedial action
for the Bliss-Ellisville site in St. Louis 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 Ql %II IllI
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 Ql THE SELECTED REMEDY
. .
This remedial action represents the final action for dioxin-
contaminated soils at the Bliss-Ellisville site. A Record of
Decision (ROD) issued by the Environmental Protection Agency
(EFA) in 1986 selected a remedy involving excavation and interj
onsite storage of 2,3,7,8-tetrachlorodibenzo-p-dioxin- (dioxin
contaminated materials at the site, pending final management. .
September 1988, EPA issued a ROD which established the
availability of a thermal treatment unit at Times Beach to treat
dioxin-contaminated materials from 27 eastern Missouri dioxin
sites, including the Bliss-Ellisville site. In consideration of
the pending availability of a.thermal treatment unit at Times
Beach, the Agency has reconsidered the need for excavation and
interim onsite storage. This ROD selects a final remedy for the
contaminated materials currently ~n.storage at the Bliss-
Ellisville site. The primary components of the selected remedy
include:
.
Excavation of approximately 7,000 cubic yards of dioxin-
contaminated soils,
Transportation of the excava~ed materials to the Times
Beach site,
.
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.
Thermal Treatment of these contaminated materials at a
temporary thermal treatment facility to be operated at
Times Beach, and
Final restoration of the Bliss-Ellisville site.
This remedial action addresses the principal threats at the
site through thermal treatment of dioxin~contaminated soils
exceeding health-based levels. Thermal treatment results in the
destruction of dioxin, permanently removing this contamination
from the environment.
DEC~R.I.TION
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 is a component of a comprehensive
cleanup that will not leave hazardous substances onsite above
health-based levels, the five-year review will not apply to this
action.
~r
Administrator
7-
Date
3C-'
- Cl
I
--
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RECORD OP DECISION
POR
PINAL KANAGEHENT OP
DIOZIN-CONTAMINATED MATERIALS
aluS
AMENDMENT
'1'0
SEPTEMBER 2', 1'86 .
RECORD or DECISION
ELLISVILLE AREA SITE (BLISS PORTION),
ST. LOUIS COUNTY, MISSOURI
Prepared by
u.s. ENVIRONMENTAL PROTECTION AGENCY
september 30, 1991
~ ,
J ,~' -
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I.
II.
III.
IV.
V.
VI.
VII.
CONTENTS
Section
~
INTRODUCTION
1
SITE NAME, LOCATION, AND DESCRIPTION
1
SITE HISTORY AND ENFORCEMENT ACTIVITIES
2
COMMUNITY RELATIONS HISTORY
5
SCOPE AND ROLE OF RESPONSE ACTION
6
SITE CHARACTERISTICS
7
SITE RISKS
7
DESCRIPTION OF ALTERNATIVES
8
VIII. COMPARATIVE ANALYSIS OF ALTERNATIVES
IX.
X.
XI.
10
THE SELECTED REMEDY
19
STATUTORY DETERMINATIONS
20
DOCUMENTATION OF SIGNIFICANT CHANGES
22
ii
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INTRODOCTION
The Bliss-Ellisville site is one of twenty-eight sites
located in eastern Missouri which were contaminated through the
application of dioxin-contaminated waste oil in the early 1970's,
or due to the subsequent movement of these contaminated soils.
In September 1986, the Environmental Protection Agency (EPA)
issued a Record of Decision (ROD) for the Bliss-Ellisville site.
This ROD formally selected a final remedy to be implemented for
the non-dioxin wastes at the site, and an interim remedy to be
implemented for the dioxin wastes at the site. The interim
remedy selected for the dioxin wastes involved excavation of
contaminated soils and temporary onsite storage awaiting final
management. This interim remedy for dioxin wastes at the B1iss-
Ellisville site has not yet been implemented.
On September 29, 1988, EPA issued the Record 2t Decision 12x
Final Manaaement 2t Dioxin-Contaminated ~ ADQ Final
DisDosition 2t Structures ADS Debris ~ Times Beach. Missouri ~
the Minker/Stout/Romaine Creek Site. Missouri (Times Beach ROD).
Other eastern Missouri dioxin sites were considered in the Times
Beach ROD in order to evaluate potential remedies for Times Beach
and Minker/Stout/Romaine Creek in the context of a comprehensive
remedy for all designated eastern Missouri dioxin sites.
Implementation of the Times Beach ROD will involve thermal
treatment (incineration) of dioxin-contaminated soil from the
Times Beach and Minker/Stout/Romaine Creek sites at a temporary
thermal treatment unit located at Times Beach. The Times Beach
ROD also establishes that the dioxin-contaminated soils from a
group of designated eastern Missouri sites, including the Bliss-
Ellisville site, can be transported to Times Beach for thermal
treatment. In consideration of the pending availability of a
thermal treatment unit at Times Beach to treat dioxin-
contaminated materials at the Bliss-Ellisville site, EPA has re-
evaluated th. need for interim storage of these materials at the
site.
This document .elects the tinal management alternative for
dioxin-contaminated soils at the Bliss-Ellisville site. The
'selected remedy involves excavation of dioxin-contaminated soils
and direct transport to Times Beach for thermal destruction
without interim storage.
I.
SITE NAKE, LOCATION, AND DESCRIPTION
The Bliss-Ellisville site is located in west St. Louis
County, Missouri. The site is located approximately 20 miles
Page 1
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west of downtown St. Louis, and is comprised of the 11.6 acre
Bliss property, and four contiquous properties where hazardous
substances have been identified. Land use in the vicinity is a
mixture of residential, rural, and recreational. Residential
development of nearby areas is rapidly occurring. Structures
onsite include an occupied residence, two mobile homes, a large
indoor horse arena and stables, an outdoor riding arena, barns,
garages, and silos.
The .developed portion of the site lies in the central l.g
of a relatively flat "Y" shaped valley with hillside slopes which
vary from 25 to 50 percent. The developed portion consists of
four general areas: The Mid-America Arena and parking area, the
riding ring area, the northeast till area, and the northwest fill
area~ The site is located in an upland area underlain by
limestone bedrock which exhibits high water permeability along
solution-enlarged joints. A tributary of Caulks Creek drains the
property to the northwest. Caulks Creek is a tributary of
Bonhomrne Creek, which enters the Missouri River about one mile
upstream of a City of St. Louis waterworks intake. Generally,
there is ground water recharge on and adjacent to the site. The
site is not in a designated floodplain, but flooding of the creek
draining the site is likely during periods of heavy rains due to
rapid runoff.
The Bliss-Ellisville site consists primarily of alluvial
flat and colluvial slopes. Earth grading has :.reated relatively
flat areas and altered drainage. The surface is underlain by
about three to ten feet of silty clay. Soils on the Bliss
property are reported to have moderate permeability. The depth
to bedrock is about 10 to 15 feet. Based on information for
wells in the Bliss property vicinity, the ground water table
elevation is estimated to be ab~ut 560 feet. The elevation range
for the Bliss property is from 630 feet on the north to about 710
feet on the south. .
II.
SITE HISTORY ANn BNPORCEMZNT ACTIVITIES
~ Historv
During the 1960's and 1970's the site served as the
headquarters of the Bliss Waste oil Company, engaged in the'
transportation and disposal of waste oil products, industrial
wastes, and chemical wastes. Responding to reports of past
dumping activities, EPA and the Missouri Department of Natural
Resources (MDNR) conducted an investigation of the site in
September 1980, during which buried containers were discovered.
A subsequent MDNR investigation in June 1981, confirmed the
presence of buried drums containing hazardous substances and
Page 2
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provided evidence that liquid.wastes had been poured into pits
and applied to the ground surface. .
During operation of the Bliss Waste oil Company, surface soils
became contaminated with dioxin through the direct application of
dioxin-contaminated waste oil on the surface for dust control, or
due to spillage from tanker trucks.
In October 1981, EPA announced that the Ellisville Area
Site, including the Bliss-Ellisville properties and two separate
non-contiguous locations, was being added to the National
Priorities List.
A remedial investigation of the site was conducted from 1982
through 1983. In 1983, the remedial investigation report
concluded that the Ellisville Area Site is not contaminating
ground water, however some surface migration of contaminated
soils and sediments had occurred onsite.
Also ~n 1983, a feasibility study was released evaluating
remedial alternatives for the three portions of the Ellisville
Area Site. The 1983 feasibility study recommended either onsite
containment of dioxin-contaminated materials at the B11ss-
Ellisville site, or excavation and transport to the Times Beach
site for storage.
In 1986, a feasibility study was completed which evaluated
interim onsite storage options for the dioxin-contaminated
materials present at the Bliss-Ellisville site. A Record of
Decision was issued by EPA in September 1986, selecting
excavation and interim onsite storage of dioxin-contaminated
materials at the site. This remedy has not yet been implemented.
In Auqust 1985, MDNR constructed a diversion dike to reroute
stormwater runoff which flowed through a fill area containing'
buried drums. As part of this effort, a liner was installed
along the portion of the creek which flows through the area of
buried containers, in the northwest arm of the site. In April
1986, MDNR erected a 450-foot fence along a bike path adjacent to
the site. EPA completed installation of a perimeter fence in
August 1990.
Numerous other site investigations have been performed at
the Bliss-Ellisville site by EPA, MDNR, and others. The results
of the most recent investiqations are summarized in the current
Feasibility StudY t2X Final Manaaement 2t Dioxin-Contaminated
Materials == Bliss-Ellisville~. This feasiaility study was
released for public comment on July 26, 1991.
Page 3
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Enforcement Actions
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.
Six dioxin sites were originally included in the ~ ~
Bliss. ~~, complaint, Civil Action No. 84-200C(1), which was
filed in the Federal District Court for the Eastern District of
Missouri on January 20, 1984. This site is one of 21 additional
sites in eastern Missouri, which became contaminated with dioxin
through similar means, that were added to this litigation on
March 1, 1989, (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. 90-656 C (1) which has been
consolidated with the other related civil actions for a total of
28 eastern Missouri dioxin sites. Partial summary judgment
pursuant to Section 107 of CERCLA has been granted as to the
Bliss defendants for all the sites.
Special Notice letters were issued to the Syntex defendants
and to Independent Petrochemical Corporation on March 31, 1988.
The moratorium required by Section 122(e) of the Superfund
Amendments and Reauthorization Act (SARA) began on the date of
issuance of this notice.
The pleadings in the above litigation refer to 28 sites,
while EPA's technical documents designate 27 sites. The
. discrepancy in numbers is due to a differ'~nce in nomenclature
used by EPA and the Department of Justice. The same group of
designated sites are represented by both lists.
On December 31, 1990, a Consent Decree between the United
- States, State of Missouri, and the four Syntex defendants was
entered in Federal District Court for the Eastern District of
Missouri. This Consent Decree provides for implementation of a
comprehensive remedy for the 28 ea~tern Missouri dioxin sites
referenced in the above civil actions. The remedy is to be
implemented according to a mixed-work arrangement, in that the
EPA, State of Missouri, and syntex each have separate
responsibilities. The Consent Decree provides thermal treatment
capacity at Times Beach for all designated eastern Missouri
dioxin sites, including the Blias-Ellisville site.
The Syntex consent
of the eastern Missouri
provide for the implemen~
~ee does not select a remedy for any
:n sites. The Consent Decree does
~n of certain response actions at the
Page 4
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eastern Missouri dioxin sites, if these response actions are
selected by EPA through the conventional remedy selection
process.
Also on December 31, 1990, a Consent Decree between the
United States of America, the State of Missouri, and the
Northeast Pharmaceutical and Chemical Company (NEPACCO)
defendants was entered in Fe~eral District Court. The NEPACCO
Consent Decree provides for cash settlement of the NEPACCO
defendants' liability.
Litigation continues with the Bliss defendants and
Independent Petrochemical Corporation.
III.
COMMUNITY RELATIONS HISTORY
The preferred alternative for the Bliss-Ellisville site
presented in this document is a component of the overall remedy
for the e~stern Missouri dioxin sites which was considered in the
Times Beach ROD. Considerable public involvement has occurred
during the remedy selection process for the eastern Missouri
dioxin sites.
The public was first invited to comment on the concept of a
comprehensive solution for all of the eastern Missouri dioxin
sites at the September 5, 1986, public meeting, where it was
announced that Times Beach would be evaluated as a potential
location for siting a temporary thermal treatment unit. It was
announced that a feasibility study would be prepared to evaluate
Times Beach as a potential location for centralized thermal
:reatment of dioxin-contaminated soils from designated eastern
;issouri sites.
A feasibility study was released for Times Beach in December
1986, which evaluat.d centralized thermal treatment at Times
Beach. A public comment period was conducted for this
feasibility study from December 1986 through March 1987. A
public meeting was held on February 12, 1987, to discuss
alternatives evaluated in the study.
A public comment period for the Proposed Plan for Times
Beach and the Minker/Stout/Romaine Creek ,sites was conducted in
February and March of 1988. The remedy proposed by EPA involved
centralized thermal treatment at Times Beach of nearby dioxin-
contaminated soils. A public meeting was held in Eureka,
Missouri on March 10, 1988, to discuss the preferred alternative.
A Record of Decision was issued by EPA on September 29, 1988,
selecting centralized thermal treatment of dioxin-contaminated
materials at Times Beach. This Record of Decision established
Page 5
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that dioxin-contaminated mat~rials from a designated group .of
eastern Missouri sites, including the Bliss-Ellisville site,
could be transported to Times Beach for thermal treatment.
A public comment period tor the Proposed Plan and
Feasibilitv Study 1Qx Final Management 21 Dioxin-Contaminated
MateriaJA == Bliss-Ellisville ~ was initiated on July 26,
1991. The close of the public comment period was extended from
Auqust 26, 1991, to September 3, 1991. A public meeting was held
on Auqust 22, 1991, to present the feasibility study and Proposed
Plan. EPA's preferred remedy. involved transportation of dioxin-
contaminated materials at the Bliss-Ellisville site to Times
Beach for thermal treatment.
Public involvement also preceded entry of the Syntex and
NEPACCO Consent Decrees in Federal District Court. Public
comment periods were conducted for these Consent Decrees in
August and September 1990.
Responsiveness summaries have been prepared to address a1l
comments received during the public comment periods described
above. These responsiveness summaries, and other documents
described in this section, are included in the Administrative
Record for the Bliss-Ellisville site, and can be referred to for
additional information on the history and background of the site.
IV.
SCOPE AND ROLE OF RESPONSE ACTION
The overall remedy for the Bliss-Ellisville site involves
re~~, tion of containerized non-dioxin wastes, soils
cc ..,. ~ated with non-dioxin wastes, and soils co"taminated with
di,. Investigations conducted to date have not indicated that
buri~~ containers or soil contaminated with other organic
compounds are also contaminated with dioxin. It is possible that
dioxin contamination may exist in overburden above the buried
containers or in soils above the former waste disposal pits.
The 1986 Record of Decision for the Bliss-Ellisville site
selected excavation and subsequent offsite treatment or disposal
for buried containers and 80ils contaminated with other organic
compounds (non-dioxin wastes). The 1986 ROD also selected
excavation and interim onsite storage of dioxin-contaminated
materials pending final management. This Record of Decision
addresses only final management of the dioxin-contaminated soils~
The remedy selected in 1986 for the non-dioxin wastes is not
affected, and will proceed according to the 1986 Bliss-Ellisville
ROD.
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The remedy selected in this current Record of Decision
eliminates interim storage of dioxin-contaminated materials due
to the pending availability of a thermal treatment unit at Times
Beach. Since the 1986 Bliss-Ellisville ROD selected interim
storage of the dioxin-contaminated materials, this document
serves as an amendment to that ROD. This document alao
represents a Record of Decision which aelects thermal treatment
at Times Beach as a final remedy.
V.
SITE CHARACTERISTICS
This 'remedy selection is limited to soils contaminated with
dioxin. The short-term potential for direct contact with 80ils
has been controlled by installation of a security fence
surrounding the dioxin-contaminated portion of the aite and
posting of the site perimeter with warning 8igns. The principal
current concern is for intruders, residents, or visitors who may
disturb or 'otherwise contact contaminated aoils.
In September 1986, the Agency for Toxic Substances and
Disease Registry (ATSDR) issued a health consultation to EPA
concerning the Bliss-Ellisville site. The consultation
recommended removal of dioxin-contaminated 'soils exceeding 1 part
per billion (ppb), but noted that the acceptable level may be
greater if the contaminated soil is located below the surface so
that direct contact may not occur. The ATSDR consultation a1so
recommended preventing access to the site, and concurred with
EPAls preferred interim storage remedy.
O~ 3anuary 16, 1987, EPA submitted to the Centers for
Disear ntrol, Center for Environmental Health (CDC/CEH), the
propcleanup criteria for dioxin contamination at the Bliss-
£llis\ ,site. According to the proposal, excavation would
proceed ~ntil reaching a residual concentration of 1 ppb, or
until a residual concentration of 5 to 10 ppb is reached after
removal of one foot of soil. Excavation would not proceed beyond
a total depth of four feet or once aolid bedrock was encountered.
All excavated areas woul~ be backfilled to oriqinal qrade with
clean soil;
The COC/CEH concurred with EPA'a proposed cleanup criteria
for the Bliss-Ellisville site on January 22, 1987. ATSDR further
supported the proposed cleanup criteria, and provided additional
discussion, in July 30, 1987, correspondence to EPA.
VI.
SITE RISKS
The contaminant addressed by this selected remedy is
2,3,7,8-tetrachlorodibenzo-p-dioxin (referred in this document to
paqe 7
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as dioxin). Dioxin is among the most toxic compounds yet
identified by EPA. Although dioxin has been highly toxic in all
species tested, there are large species differences in
sensitivity. Animal studies have also demonstrated that dioxin is
teratogenic (causes malformities) and fetotoxic (toxic to fetus)
in several species.
Since exposure to dioxin produced statistically significant
increased incidents of tumors in certain animal species, there is
sufficient evidence to conclude that dioxin is an animal
carcinogen. In consideration of the available animal'
carcinogenic and epidemiologic data, the overall weight-of-
,evidence classification (using EPA's interim classification
scheme) is that dioxin is 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
ten years 'or longer. 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.
The principal current concern would be for residents,
visitors, or intruders who may disturb contaminated soils.
Ingestion of soils or inhalation of particulates contaminated
with dioxin present the greatest threat to human health.
wildlife (deer, turkey, rabbits) entering the site area could be
susceptible to contamination.
Actua .' threatened releases of hazardous s~bstances from
this site," :.ot addressed by the preferred alt -native, may
present a c~ :ent or potential threat to public ._aalth, welfare,
or the environment.
VII.
DESCRIPTION OF ALTERNATIVES
The EPA evaluated four alternatives for management of
dioxin-contaminated materials at the Bliss-Ellisville site. The
'remedial alternatives considered during this evaluation were 1)
no action, 2) in-place containment, 3) excavation and interim
onsite storage pending final management, and 4) thermal treatment
at Times Beach. A description of the alternatives is provided
below.
Alternative 1 -- No Action
Under the no-action alternative, no additional remedial
actions would be taken at the site. Maintenance of the previous
Page 8
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. j
mitigation efforts, including bank stabilizations and fencing,
would not be provided. The nQ-action alternative is not
protective of human health and the environment. This alternative
has no additional capital or operation and maintenance costs. No
ARARs were identified for this alternative.
Alternative 2 -- In-Place Containment
Estimated Construction Cost: $774,000
Estimated Annual 0 , M Costs: $23,400
Estimated Present-Worth Costs: $1,130,000
Estimated Implementation Timeframe: 4-6 months
This alternative involves placement of a clean soil layer
and synthetic erosion control materials alonq eroded portions of
creek beds. Disturbed or eroded areas of the site would be
reseeded.Unpaved portions of the site with dioxin levels
exceedinq 1 ppb would also be mowed, fertilized, and reseeded.
Maintenance of the vegetation and cover systems would be
necessary to maintain the effectiveness of this remedy. No ARARs
were identified which have a major impact on implementation of
this alternative.
Alternative 3 -- Excavation and Onsite Storage
Estimated
Estimated
Estimated
Estimated
Construction Cost: $13,590,000
Annual 0 , M Costs: $25,000
Present-Worth Costs: $13,700,000
Implementation Timeframe: 6 months
This alt, ,ive involves exca~ation and onsite storaqe of
approximately ir~O cubic yards (cy) of dioxin-contaminated soils
pendinq final management. The storage facilities would not be
desiqned or constructed for the purpose of providinq permanent
storaqe. Continued operation and maintenance of the storaqe
facilities would be provided to control the potential for future
release of contaminants.
The primary ARARs pertaining to
hazardous waste storaqe requirements
Conservation and Recovery Act (RCRA)
Waste Manaqement Law (HWML).
this alternative are
under both the Resource
and the Missouri Hazardous
-
Alternative 4 -- Thermal Treatment at'Times Beach
Estimated Construction Cost:
Estimated Annual 0 , M Costs:
$17,SJU,000
$0
Page 9
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Estimated Present-Worth Costs~ $17,530,000
Estimated Implementation Timeframe: 6 months
This alternative involves excavation of approximately 7,000
cubic yards of dioxin-contaminated soils at the Bliss-Ellisville
site and transportation to the Times Beach site. A temporary
thermal treatment unit located at the Time~ Beach site would be
used to destroy dioxin contaminants in the soil.
The time to implement this alternative would be dependent
upon the operation schedule of the temporary thermal treatment
unit at Times Beach. No operation and maintenance activities
related to the dioxin contamination would be necessary following
implementation of this remedial alternative.
The primary ARARs associated with this alternative consist
of transportation, storage, and incinerator requirements under
RCRA and HWML, emissions requirements under the Clean Air Act,
Missouri Solid Waste Management Regulations, potential NPDES
requirements under the Clean Water Act, and Department of
Transportation requirements.
VIII.
COMPARATIVE ANALYSIS OF ALTERNATIVES
The alternatives described in Section 5 were evaluated using
nine evaluation criteria which relate directly to factors
mandated by Section 121 of CERCLA, as amen~ed. These include
threshold criteria of overall protection of human health and the
environment, and comr~ ~.ance with applicable or rel':ant and
appropriate requiremi;; ;;; (ARARs), primary balancir criteria of
long-term effectiver. ~nd permanence, reduction toxicity,
mobility, or volume ~"'\19h treatment, short-term ~~fectiveness,
implementability, cost, and modifying criteria of State
acceptance and community acceptance. The comparative evaluations
of alternatives are summarized below.
Protection 2! Human Health ~ 1hi 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 4, involving thermal treatment, provides the
highest overall protection of human health and the environment.
Thermal treatment is the only demonstrated technology with proven
effectiveness at destroying dioxin on a full scale. Thermal
treatment has been shown to be capable of destroying dioxin to
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/
non-detectable levels.
Short-term risks associated with potential air emissions
during thermal treatment operation are controlled through
continuous process and emissions monitoring and redundant safety
features. The thermal treatment unit at Times Beach will be
equipped with emergency shutdown systems which activate if
criteria specified by the operating permit are viol~ted, thereby
controlling the ~otential for release of hazardous substances due
to incinerator upsets.
EPA has determined that risks associated with the
transportation of dioxin-contaminated materials to Times Beach
are not significant. The dioxin-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 greatest extent possible. The contaminated soils
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 to prevent escape of the truck's contents.
Alternative 1, No Action, would not provide protection of
human health and the environment. Without continued maintenance,
the fencing and containment systems would eventually fail,
resulting in increased opportunity for human exposure to site
contaminants.
Alternative 2, in ~e containment, would provide greater
overall protection th; . action, but has a low degree of
permanence. The conta . \t system would reduce erosion
potential and provide a ~drtial barrier which would reduce.
exposure potential while maintained. Continued maintenance of
the security and containment measures would be required to
prevent future increased exposure potential.
Alternative 3 Provides a somewhat higher degree of
.permanence relative to in-place containment, due to increased
reliability of the storage systems. The storage facilities would
require continued maintenance to provide protection of human
health and the environment. Maintenance costs would be expected
to increase as the design life of the storage systems is
approached or surpassed. Without maintenance, the storage
systems would eventually fail, resulting in the release of
dioxin-contaminated materials to the environment. catastrophic
failure (flood, earthquake, etc.) could result in a release of
contaminants into the environment for both Alternatives 2 and 3,
regardless of maintenance.
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Compliance ~ Applicable ~ Relevant ~ Appropriate
Reauirements (ARARs)
Remedial actions conducted under CERCLA authority must
comply with applicable or relevant and appropriate requireme~1ts
or standards (ARARs) unde~ other Federal and State environmental
laws, or justify a waiver from these requirements. .
Requirements for protection of site workers under the
Occupational Safety and Health Act (OSHA) constitute ARARs which
are common to all action alternatives. Adherence to a site
health and safety plan will assure compliance with these OSHA
requirements. Also, National Pollution Discharge Elimination
System (NPDES) requirements may impact stormwater management
practices conduc~ed as part of the action alternatives. The
ARARs discussed below are those that have a major impact on the
implementation of the alternatives.
No ARARs were identified that have a major impact on the
implementation of alternatives 1 and 2. ARARs associated with
Alternative 3 include hazardous waste storage requirements under
RCRA and HWML. Alternative 4 involves activities at both the
Bliss-Ellisville site and Times Beach. No significant ARARs were
identified for excavation and loading of dioxin-contaminated
soils at the Bliss-Ellisville site. ARARs for transportation of
hazardous wastes exist under RCRA and Department of
Transportation regulations.
The primary ARARs asso('~ ~~";j with Alternative 4 are
requirements under RCRA and,:i!" for the operation of the thermal
treatment unit at Times BeaCl. These ARARs are summarized below,
and more fully explained in the 1988 Times Beach Record of
Decision, and the Explanation of Significant Differences for the
Times Beach site issued July 18, 1990. These documents are
included in the Administrative Record for the site.
CERCLA section 104(d) (4) 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. The EPA has
determined that the designated eastern Missouri dioxin sites are
related based on the threat posed, and should be treated as one
site for response purposes. Accordingly, the thermal treatment
of dioxin-contaminated materials from the designated locations at
a single, central location is considered to be an onsite action.
The consideration of the designated dioxin sites as one site
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. ,
is significant because onsite.actions must meet the substantive
requirements, but not the administrative requirements, of other
laws. The issuance of permits is generally considered an
administrative requirement. For the Times Beach thermal
treatment unit, however, permits will be issued pursuant to RCRA
and HWML, the Clean Air Act, and the Clean Water Act. The Agency
believes that these measures are responsive to concerns expressed
by the public regarding the duration of the project and limits on
the sources of materials to be transported to Times Beach.
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. As of July 15, 1986, certain dioxin-
containing wastes are specifically regulated under RCRA as
hazardous wastes. Certain requirements under RCRA are considered
applicable or relevant and appropriate to Alternatives 3 and 4.
The Missouri Hazardous Waste Management Law
implementing regulations are very similar to the
program in almost all respects. No requirements
those under RCRA were identified in the Missouri
Bliss-Ellisville site.
(HWML) and
Federal RCRA
additional to
Code for the
\
The RCRA Land Disposal Restrictions under 40 CFR Part 268
prohibit land disposal of dioxin-contaminated material after
November 8, 1988. A two-year extension of this date has now
expired. Land disposal of dio~;n wastes is not a component of
any of the four alternatives. r.mal treatment residues at
Times Beach will be te$ted to ~y that they are non-hazardous
and delisted prior to land dis." ".L. The RCM Land Disposal'
Restrictions therefore do not i~~act the four remedial "
alternatives currently being evaluated for the Bliss-Ellisville
site.
Federal a~d state Water Quality Criteria:
Alternatives 1, 2, and 3 involve no wastewater discharge of
any type. The thermal treatment unit at Times Beach, under
Alternative 4, may utilize wet air pollution control systems
which generate wastewater that must be discharged following
attainment of delisting criteria. In this event, the wastewater
discharge will be in accordance with an NPDES permit issued by
the State of Missouri. An NPDES permit is not required for
onsite actions, but will be issued in order to provide public
assurance regarding the safety of the thermal treatment unit.
Stormwater runoff may occur during implementation of
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excavation activities at the Bliss-Ellisville site. Diversion
systems will be placed to control the potential for stormwater
runoff from contacting contaminated portions of the site during
the response action. Measures will also be taken to control
potentially-contaminated stormwater runoff from leaving the site
during the response action. Management of stormwater runoff at
the Bliss-Ellisville site during the response action will be
performed in substantive compliance with all NPDES requirements.
Clean Air Act, Missouri Air Conservation Law:
The ,Clean Air Act and the Missouri Air Conservation Law
contain permitting requirements for 80urces of certain types and
quantities of air pollutants. Although the RCRA thermal
treatment performance standards are more stringent than Clean Air
Act requirements, in most respects, emissions of some of the more
conventional pollutants are not addressed by the RCRA standards.
The Federal Clean Air Act program is administered by the MDNR and
St. Louis ~ounty.
These requirements are applicable to Alternative 4 due to
potential air emissions from the thermal treatment unit at Times
Beach. Air emissions from the Times Beach thermal treatment unit
will comply with all substantive requirements of the Federal
Clean Air Act and Missouri Clean Air Act. A permit pursuant to
the Missouri Clean Air Act will be issued in order to provide
public assurance regarding the safety of any possible air
emissions.
Solid Waste Disposal Regulations:
Missouri solid waste management ','0"::' '~ations require that
solid waste, in general, be disposed'-;; .n a landfill meeting
design and operating requirements of a demolition or sanitary
landfill. These regulations are applicable to disposal of
thermal treatment residues at Times Beach. Missouri solid waste
management regulations also require that any landfill located in
a floodplain must be designed to prevent floodwater from
contacting the solid waste. An additional waste category,
"special waste," has been created for those solid wastes
requiring handling other than normal municipal wastes. Special
wastes are subject to waste-specific disposal requirements
established on a case-by-case basis. Incinerator ash is
generally considered a special waste.
Land disposal of delisted thermal treatment residue at Times
Beach will be performed in accordance with the substantive State
solid waste disposal requirements. Approval will be obtained
from the state prior to onsite land disposal of residue (ash)
from the thermal treatment process.
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Alternatives 2, 3, and 4 could be implemented in compliance
with the substantive requirements of all identified ARARs. As
described above, the administrative permitting requirements of
certain designated authorities will also be met to satisfy public
concerns regarding the duration and extent of the project.
Reduction 2! Toxicitv. Mobilitv ~Vo1ume throuah 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 4 involves thermal treatment of dioxin-
contaminated soils which exceed health-based levels. Thermal
treatment destroys dioxin, thereby eliminating the toxicity,
mobility, and volume of this contaminant.
Alternatives 1, 2, and 3 do not involve treatment, and do
not reduce toxicity of contaminants. Contaminant volumes may
actually increase under Alternatives 1, 2, or 3. The no action
alternative may result in increased volume of material to be
managed due to uncontrolled contaminant migration. Some
contaminant migration may also continue to occur after in-place
containment. In the event of storage system failure, Alternative
3 could release contaminants and increase the volume of materials
to be managed.
The mobility of the contaminants w~. ,~ remain the same for
the no action alternative. Alternative ,nd 3 would have
relative reductions in the mobility of minants.
Short-Term Effectiveness
. .
Short-term effectiveness addresses how well an alternative
is expected to perform, the time to achieve protection and the
potential adverse impacts of its implementation.
Short-term risks at Times Beach associated with Alternative
4 can be effectively controlled through process and emissions
monitoring. Short-term risks associated with transportation of
contaminated materials to Times Beach can also be controlled, as
discussed above.
There are no significant short-term risks~t the Bliss-
E11isville site associated with any of the alternatives. Short-
term risks would remain at the current level for the no action
alternative. Short-term risks associated with disturbance of
surface soils could be controlled by air monitoring, use of dust
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suppressants, and protective equipment for workers.
Lona-Term Effectiveness ADS Permanence
Long-term effec:iveness and permanence addresses the long-
term protection and reliability an alternative provides.
Alternative 4 permanently destroys the dioxin contamination,
providing the highest level of long-term protectiveness.
Alternative 1 involves no further action at the site, and
provides the lowest degree of long-term effectiveness.
The containment alternative and storage alternative are both
dependent upon continued maintenance to maintain their
effectiveness. Without continued maintenance, failure would
occur, resulting in a release of contaminants into the
environment. Alternatives 2 and 3 provide a low degree of
permanence. With continued maintenance, Alternatives 2 and 3
could provide a moderate degree of long-term protectiveness, but
future release due to catastrophic failure is possible.
Im'Olementabilitv
Implementability addresses how easy or difficult, feasible
or infeasible, an alternative would be to carry out from design
through construction, operation and maintenancp.
Thermal treatment represents a relativel. c. :~plex operation,
involving many interrelated activities which c~~ 'oordinated in
order to effectively and safely destroy the dio.....n contamination.
Thermal treatment of contaminated soils has been successfully
demonstrated on more than 10 full-scale projects nationwide
- involving contaminated soils. Process controls and air
monitoring ensure that thermal treatment is conducted safely and
effectively.
Alternative 1 has no implementation necessary. Alternative
2 is easily implementable, incorporating common landscaping.
practices. Excavation and containerization activities associated
with Alternative 3 are more complex than Alternative 2, but can
be performed effectively and safely, as evidenced by similar
response actions taken at other eastern Missouri dioxin' sites.
Excavation and bulk transport associated with Alternative 4 are
conventional construction activities which could be accomplished
without difficulty.
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.....--
. All action alternatives would require a comparable amount of
time to implement. Alternatives 2 and 3 could be implemented
immediately. Implementation of Alternative 4 would be dependent
upon scheduling of other sites and upon the availability of the
thermal treatment facility at Times Beach.
~
CERCLA requires that EPA select the most cost-effective "(not
merely the lowest cost) alternative that is protective of human
health and the environment and meets other requirements of the
law.
No cost is associated with Alternative 1. In-place
containment has the lowest cost of any of the action alternatives
($1.1 million). Alternative 2, however, will have continuing
maintenance requirements to maintain the effectiveness of the
remedy. The cost of Alternative 4 is the highest of the
alternatives considered ($17.5 million), but provides a permanent
remedy for the dioxin contaminants destroyed. The annual cost of
interim onsite storage is somewhat lower ($13.6 million) than the
thermal treatment alternative, but final management of
contaminants would still be required. The costs associated with
maintenance of the storage systems can be expected to increase as
major repair of the storage facilities becomes necessary.
Community AcceDtance
This evaluation criteria addresses the degree to which
members of the local community support the remed: ,lternatives
being evaluated.
A public comment period was conducted from J~-f 26, 1991,
through September 3, 1991, for the Feasibilitv Study 12x Final
Manaqement 2t TCDD-Contaminated Materials and ProDosed ilAn 1Qr
Final Manaaement 2t Dioxin-Contaminated ~ for the Bliss-
Ellisville Site. A public meeting was conducted on Auqust 22, .
1991, in Ellisville, Missouri, to discuss the Feasibility Study
and Proposed Plan. A limited number of comments were received by
the Agency during the public comment period.
Oral comments received during the public meeting and written
comments received at the Regional office were generally
supportive of the Proposed Plan. Many community members were
interested in completing the project as quickly as possible to
minimize the impact to their community.
Some community members questioned the need for remediation
in consideration of a recent statement made by an official with
the Centers for Disease Control. A representative from the
Page 17
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Agency for
his agency
dioxin and
exposures.
Toxic Substances and Disease Registry responded .that
continues to be con~erned about human expo$ure to
will continue to support actions to minimize these
A responsiveness summary has been prepared which presents
EPA's response to all comments received during the comment
period.
Considerable public involvement preceded the 1988 Times
Beach remedy selection and entry of the 1990 Consent Decree,
which have established treatment capacity at Times Beach tor. the
materials at the Bliss-Ellisville site.
The local community near Times Beach has demonstrated
divided support for the various alternatives evaluated for
management of Times Beach contaminants, and materials from other
locations. These local concerns have primarily focused on short-
term remedial action impacts and aesthetic impacts. Many
residents in close proximity to Times Beach perceive "the
implementation of any disposal or thermal treatment alternatives
implemented at Times Beach as a threat to the economic
development and stability of their community. Some residents
have proposed a cover or cap over contaminated areas at Times
Beach, either as a final remedy, or as an interim remedy pending
development of alternative technologies.
Other local residents have indicated support of centralized
thermal treatment of soils from Times Beach and other eastern
Missouri dioxin sites due to the long-term protection and overall
benefit which would be provided to the st. Louis area. ~~~er
consideration of the comments received, and on the bas'.'. other
remedy selection criteria, a Record of Decision was is. . DY EPA
on September 29, 1988, selecting thermal treatment of Q.' .n-
contaminated materials from a designated group of eastern
Missouri dioxin sites at Times Beach.
State Acce~tance
The State acceptance criteria addresses the concern and
degree of support that the State government has expressed
regarding the selected remedial alternative. The Proposed Plan.
was provided to the State for comment in accordance with
statutory provisions of SARA, Section 121(f) (1)(G).
The State transmitted written comments regarding the
Feasibility Study and Proposed Plan to EPA on September 17, 1991.
In these comments, the State inc ~ated general concurrence with
the proposed remedy, contingent _.?on EPA's commitment to perform
a ground water investigation at the site and assurances that
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stabilization measures will be"maintained or implemented, as
necessary. In Auqust 22, 1991 correspondence to MDNR, EPA
committed to perform an investigation of the ground water at the
site. The Responsiveness Summary accompanying this Record of
Decision reaffirms EPA's commitment to perform a qround water
investigation and to assess the need for interim stabilization
measures at the site prior to implementation of the final remedy.
EPA is committed to performing response actions that are
determined to be necessary to control offsite migration of
contamination prior to the final remedy.
The State has historically supported thermal destruction of
dioxin-contamihated soils excavated from the eastern Mis.ouri
dioxin sites at a central location. Support of this concept was
initially advanced by former Missouri Governor Christopher Bond
in December 8, 1982, correspondence to EPA. In this
correspondence, it was requested that contaminated soils be
excavated and that the possibility of incineration should be
explored..
On February 14, 1983, Governor Bond, by executive order,
established a Governor's Task Force on Dioxin. The task force
submitted its final report on October 31, 1983, recommending that
dioxin-contaminated soil at sites in Missouri be excavated and
stored until a proven technology is available to assure a
comprehensive and permanent solution to dioxin contamination with
minimum risk to public health and the environment.
In correspondence of May 7, 1986, the State requested that
EPA evaluate Times Beach for establishment of a centraliz,
thermal treatment facility to accept dioxin-contaminated
fr~m designated sites in eastern Missouri. This alternati .
included in the september 1986, Times Beach Feasibilitv ~ -.
.s
The State of Missouri is a signatory to a Consent Decree
with the United States of America and the Syntex defendants named
in the ~ ~ Bliss civil action previously described. This
Consent Decree provides for implementation of a comprehensive
remedy for the designated eastern Missouri dioxin sites,
including the Bliss-Ellisville site. Under the mixed-work
arrangement, EPA, the State of Missouri, and Syntex share
responsibilities for implementation of the overall project. The
State-approved Consent Decree provides a means of implementing
the remedy selected in this Record of Decision.
IX.
THE SELECTED REMEDY
The Agency is selecting Alternative 4, excavation and
transportation of dioxin-contaminated soils to Times Beach for
thermal treatment. Following excavation and transportation of
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dioxin-contaminated materials, .final management of the non-dioxin
site contaminants will proceed, as specified in the 1986 ROD for
the Bliss-Ellisville site. Following removal of all site
contaminants, the site will be restored to enable beneficial use.
Residues from the thermal treatment of dioxin-contaminated
materials will be dispos~d at Times Beach as non-hazardous solid
waste if testing verifies that delisting criteria are achieved.
If delisting criteria are not achieved, the materials will be
retreated at Times Beach, or managed offsite as a hazardous
waste. Following thermal treatment of dioxin-contaminated
materials from the designated eastern Missouri aites, the
temporary thermal treatment unit will be permanently removed from
Times Beach.
The selected alternative, transport and thermal treatment of
dioxin-contaminated soils at Times Beach, provides the highest
degree of long-term protection of human health and the
environment of the alternatives evaluated. Thermal treatment
destroys dioxin contamination, eliminating the potential for
future exposure in excess of health-based levels.
The selected remedy satisfies the statutory preference for
remedies involving treatment which result in the permanent
reduction of the volume, toxicity, or mobility of hazardous
substances. Thermal treatment destroys the dioxin contamination,
thereby eliminating the toxicity of the contaminated soil. Since
the dioxin contamination is destroyed, the mobility and volume of
the contamination is also eliminated. The containment and
storage alternatives evaluated reduce the mObility of the
contaminated soil, although not to the extent provided by thermo
treatment. containment or storage do not reduce the toxicity r
the volume of hazardous substances. 0
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 0
extent practicable, and satisfies the statutory preference for
remedies involving treatment as a principal element.
Protection 2f Public Health ADS ~ Environment
The selected remedy for the Bliss-Ellisville site provides
a high degree of protection of public health and the environment
and permanence. No other alternative identified offers an
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equivalent degree of long-term.protection. The selected remedy
is the only alternative identified which permanently attains the
level of cleanup recommended for the Bliss-Ellisville site by
" state and Federal health agencies.
The primary environmental concern at the Bliss-Ellisville
site is the potential release of dioxin-contaminated soil into
the environment and subsequent exposure to environmental
receptors. 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 exposure is eliminated.
Attainment 2! 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 management 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 for
the 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 in~inerator in southwest Missouri and other similar
projects has indicated that these requirements can be achieved
with commercially-available thermal treatment technologies.
Preference tQx 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 hazardous substances which constitute 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
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Centralized thermal 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
provide~ 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 07 SIGNI7ICANT CBANGIS
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. .
-
Page 22
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..
RESPONSIVENESS StJMMARy
RECORD OP DBCISION
POR
PINAL KANAGBKBNT OP
DIOXIN-CONTAMINATBD MATBRIALS
and
AMENDMENT
TO
SBPTEMBBR 29, 1986
RECORD OP DECISION
BLLISVILLB AREA SITB (BLISS PORTION),
ST. LOUIS COUNTY, MISSOURI
Prepared by
u.s. ENVIRONMENTAL PROTECTION AGENCY
September 27, 1991
-------
RESPONSIVENESS SUMMARY
Record of Decision
for Final Management of Dioxin-Contaminated Materials
and
Amendment to
September 29, 1986 Record of Decision
Bliss-Ellisville site
St. Louis County, Missouri
INTRODUCTION
A public comment period for the ProDosed ilan for Final
Manaaement of Dioxin-contaminated SQil and the Feasibility Study
for Manaaement Qt TCDD-Contaminated Materials for the Bliss-
Ellisville site was conducted from July 26, 1991 through
September 3, 1991. A public meeting to present the proposed Plan
and Feasibility Study was conducted on August 22, 1991, at the
Daniel Boone Library in Ellisville, Missouri. The original
closing date of the public comment period was extended to allow
more time for comments following the public meeting.
This document presents the responses of the Environmental
Protection Agency (EPA) to comments received during the public
comment period for the Feasibility Study and Proposed Plan.
Comments have been grouped into categories of those received at
the public meeting, written comments received at the Regional
Office, and written comments received from the State of Missouri.
COMMENTS UCBIVBD AI DI PUBLIC DARING
In this section, the public comments received by EPA at the
public hearing on August 22 are summarized. EPA responses to the
comments are provided.
A commentor noted the path next to the site does
not have any warning signs posted. B8 also noted
he had seen children playing near the fence and had
-------
seen sections of tbe fence wbicb bave been bent
down wbere intruders bad apparently tried to gain
access to tbe site.
EPA requested thecommentor to point out the specific area
of concern, and indicated that action would be taken to
maintain safety and security. Subsequent to the meetinq, an
EPA representative visited the site to inspect the fence for
siqns of intruders. Two areas were noted where erosion has
created an openinq beneath the fence. Measures will be
taken to secure these areas. The fence is currently posted
with warninq siqns. Additional siqns will be considered for
the areas of concern.
A commentor questioned wby tbe original
contaminated .oil volume estimate of 20,000 cubic
yards bad been revised to 7,000 cubic yard..
EPA told the commentor the revised fiqure of 7,000 cubic
yards was based on recent statistical samplinq which
determines concentrations at a 95 percent upper confidence
level. Earlier estimates were based on non-statistical
samples collected in 1982 and 1983. The recent samplinq we
performed, which involves determining 95 percent upper
confidence level measures, is the method which is used to
quide excavation during the actual site cleanup, and
provides a more accurate basis upon which to estimate
projected soil volumes. For that reason, the projected soil
volume has been adjusted to 7,000 cubic yards.
A commentor wanted to go on record indicating be
supports tbe tbermal program. Be had spoken with a
representative from t4e University of Missouri at
Columbia who told him the only effective way to
deal with the problem was to thermally process it.
EPA indicated they appreciated his comments.
SPA was asked why the site CaD't be fenced in and
left alone because of the uncertainty surrounding
tbe tozicity of diozin.
EPA has relied upon the recommendations of Federal and State
health agencies establish the need for response actions at
the eastern Missouri dioxin sites. The proposed actions at
the Bliss-Ellisville site continue to be supported by these
health agencies. The Agency for Toxic Substances and
Disease Registry has prepared an agency position paper on
the toxicity of dioxin (Attachment 1).
- 2 -
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A commentor wanted to know if dioxin is so
dangerous, why is BPA letting people rent the
property.
Federal and state health agencies have not recommended
relocating residents at the site. The EPA has installed a
perimeter fence and posted warning signs in an attempt to
limit exposure. Residents at the site are aware of the
hazard and choose to remain.
A commentor said they were not aware of the dioxin
until after they moved into their homes. Commentor
noted she lived in an older section of the adjacent
subdivision - perhaps 10 or 11 years old.
The E~lisville Area site was added to EPA's National
Priorities List in 1981. During the period when the state
originally was the lead agency for this site, site
stabilization measures were taken and perimeter fencing was
installed to limit access and exposure potential. EPA
completed the perimeter fence when the extent of the surface
contamination had been defined by the 95 percent confidence
sampling. MDNR noted at the public meeting that at the time
that the site was discovered, and in the early stages, many
of the homes now near the site were not yet constructed. In
recent years, development has been approaching the site, and
a decision was made to take additional measures to limit
access.
A Commentor - state Representative Linton - noted
that EPA had spent $30 million on the buy-out at
Times Beach, over $400 million in research on
dioxin, and about $120 .illi~n on an incinerator.
Be stated his position that the agreement between
EPA, syntex and the Department of Natural Resources
had been negotiated in secrecy. Be also noted that
EPA was trying to change directions at the Bliss-
Ellisville site by eliminating the interim storage
remedy. Representative Linton described how he
perceived the site safety precautions at Times
Beach to be less stringent now than when the site
was initially discovered, and noted that a letter
has been written to XDNR asting for an explanation
as to why the project was proceeding in
consideration of recent statements made by an
official with the Centers for Disease control.
The permanent relocation of businesses and residents at
Times Beach was announced in 1983. EPA made this decision
on the basis of recommendations from the Centers for Disease
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Control. The EPA must make decisions to take response
action on the basis of the best scientific information
available at the time. EPA believes that the permanent
relocation of residents at Times Beach was warranted on the
basis of recommendations from the Federal health agency.
EPA does not dispute that a substantial amount of money has
been directed at research into the toxicity of dioxin. It
is worth noting that despite the tremendous amount of
resources directed at this topic, there still remains a
great deal of disagreement in the scientific community
regarding the toxicity of dioxin.
A Record of Decision issued by EPA in 1988 selected
centralized thermal treatment at Times Beach and established
the availability of this thermal treatment unit to treat
dioxin-contaminated soils from 'the Bliss-Ellisville site.
EPA has determined that this remedy best attains the remedy
selection criteria under the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) and the
National Contingency Plan, including cost effectiveness.
The Consent Decree between the Federal government, the State
of Missouri, and syntex entities was negotiated under a
confidentiality agreement. The City of Eureka was invited
to participate in the negotiations, but declined. Prior to
entry of the consent decree, a public comment period was
conducted, and a responsiveness summary was prepared. It
should be noted that this consent decree did not select any
portion of the remedy for any site in eastern Missouri. The
thermal treatment unit at Times Beach was established by a
Record of Decision issued by EPA in 1988 in a remedy
selection process which included public comment. Likewise,
the final remedy for the Bliss-Ellisville site is the
subject of the current remedy sele~tion process. The
consent decree with Syntex provides a means to implement
certain remedies, if selected by EPA.
EPA acknowledges that the interim storage phase will be
eliminated at the Bliss-Ellisville site by the current
remedy. EPA has determined that the selected remedy is
protective of human health and the environment, and
satisfies all other remedy selection criteria.
Health and safety procedures at Times Beach continue to be
conducted in accordance with an approved Health and Safety
Plan which assures protection of site workers and visitors.
EPA acknowledges that a letter was written to MDNR from
several local officials. The response of MDNR and the
Missouri Department of Health is attached (Attachment 2).
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Representative Linton acknowledged that Governor
Ashcroft had written a letter to the City of Bureka
inviting their participa~ion in the ongoing
negotiations with the Syntez entities, and had been
assured that the local community would have input
into the process.
EPA believes that the public was given an opportunity for
input into the proposed Consent Decree. Prior to entering
the consent decree in Federal Court, a public comment period
.was announced, and a responsiveness summary was prepared
which addressed all comments received.
Representative Linton noted they wanted to ask
questions during the preparation of the document
and they were not given that opportunity.
MDNR noted at the public meeting that
Director of the Department of Natural
both the City of Eureka and Fenton to
lawsuit.. They declined to intervene.
G. Tracy Mehan,
Resources, invited
intervene in the
Representative Linton stated that the cities of
Eureka and Penton are primarily worried about a
permanent diozin incinerator installation.
Controls have been put into the Consent Decree which prevent
the temporary thermal treatment unit at Times Beach from
becoming a permanent facility. These include permit
restrictions and actual language in the Consent Decree which
establishes milestones and requires removal of the unit and
site restoration following completion of the project. In
addition, the state of Missouri has developed a five-point
plan directed specifically at limiting cperation of the
thermal treatment unit at Times Beach to only dioxin-
contaminated soils from the eastern Missouri dioxin sites.
Representative Linton noted that to handle the
amount of soil that's qoinq to be brouqht to
Eureta, the incinerator will have to be constructed
and then torn down, unlike the Blue Goo.e which is
a mobile unit. - .
EPA acknowledges that the EPA Mobile Incineration System,
sometimes referred to as the Blue Goose, does not have
sufficient capacity to be considered for use at Times Beach.
However, transportable thermal treatment units are available
for projects of this size, and it is anticipated that one of
these existing units will be temporarily utilized at Times
Beach.
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A commentor asted if there had been any testing at
the Bliss 8ite 8ince AUgu8t of 1990.
~PA responded that the 1990 sampling is the most recent
testing for dioxin which has been conducted at the Bliss-
Ellisville site.
A commentor a8ted if there are any plan8 for future
te8ting prior to removal of the dioxin.
EPA noted there would be a continued need to assess the site
to make sure conditions do not deteriorate. Presently,
there has not been any detected offsite migration of any
contamination.
IPA was asted in what year the thermal treatment at
Times Beach of dioxin-contaminated 80i18 from the
Bliss-Illisville site vould be performed.
EPA explained that under the terms of the Consent Decree,
Syntex .i9 the party that's responsible for bringing a
thermal treatment onsite and temporarily operating it in
order to destroy the dioxin contamination and the soils from
the 28 sites. Their first step is the procurement of the
contractor to provide these services, then apply to EPA and
the state for a permit. The permitting process includes an
opportunity for public involvement and an agency review
process prior to issuance of a permit. It could be from one
to three years before a permit could be issued, but it is
not possible to project a certain date since approval of the
permit application is required.
Worse site first will be a likely approach to prioritizing
3ites for thermal treatment at Times Beach once the thermal
treatment unit becomes operational. Since the~e is
continued exposure potential at the Bliss-Ellisville site,
EPA will consider removing that material early in the
process, perhaps by 1995 or 1996.
BPA va8 a8ted about the non-dioxin contaminant8 on the site.
There i. no .ention to di8po.e of them.
The current remedy selection process addresses only the
dioxin-contaminated surface soils. EPA noted there was a
final remedy selection for the non-dioxin contaminants in
1986. At that time, EPA decided those materials would be
excavated and transported offsite for treatment or disposal
at an offsite facility. At the Bliss-Ellisville site, there
is surface dioxin-contamination in some areas which must be
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removed to access the non-dioxin contamination.
EPA vas asked if the non-dioxin contaminants can be .
removed alonq with the dioxin.
EPA responded it was currently planned to remove the dioxin
and non-dioxin contaminants in a coordinated action.
Several commentors wanted to qo on record 8tatinq
they were in favor of r..ovinq the dioxin from the
site.
The owner of the Callahan portioD of the Bllisville
Area site asked when BPA would complete the cleanup
of his property.
The state of Missouri is currently the lead agency for this
portion of the site. The state committed to getting the
information to the property owner.
A commentor wanted to tnow if BPA would decide to
manaqe car tires similar to barrels and prohibit
their disposal in landfills..
EPA noted the question referred to the new state law that
refers to how tires are to be managed. EPA stated that
there was provision to use many of the tires as part of a
recycling project and part of asphalting and paving of
highways in the state of Missouri. EPA also noted there
were places beginning to receive and recycle tires.
state Representative Linton mentioned a law passed last year
to .. up districts for recycling and reuse.
, ~ommentor asked KPA to identify the non-dioxin
.(';Jntaminants.
The current data indicate that the non-dioxin contaminants
are primarily volatile and semi-volatile organic compounds.
EPA also stated that some of the buried containers were
deposited in the 1970s or earlier, and that bulk disposal of
liquid wastes was conducted in pits at the site.
BPA was asked how much soil would be removed and
how the site would be restored.
EPA responded that approximately 70,000 cubic yards of
dioxin-contaminated soil has already been excavated of the
total estimated 100,000 cubic yards. Through this
experience, EPA has found that in areas that have not been
disturbed since the original application of dioxin-
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contaminated waste oil, contamination has not migrated
vertically beyond approximately the upper foot of soil. In
areas which have been contaminated through migration,
contamination is generally limited to the upper several
inches. EPA noted sampling would be performed to verify
that health-based clean up goals are achieved. Following
excavation of contaminated soils, all excavated areas will
be backfilled to the original grade and re-vegetated.
A co...ntor acknowledged the controversy
surrounding the carcinogenic properties of dioxin,
and asked for comment regarding the fetotoxicity
and the teratogenic properties of dioxin. .
The representative from ATSDR noted there were a lot of
studi~s going on relating to the effect of dioxin on unborn
children, and that his agency is awaiting the results of
these studies.
A co--entor asked about drums located outside the
perimeter of the site. 80.e drums lie near the
retention pond area.
EPA is aware of the possibility that some drum fragments
have washed down into that area, but is not aware of the
presence of any intact drums. The presence of drum
fragments will be assessed and appropriate response actions
will be taken in the near future. All buried drums
identified at the site will be addressed in the
.
implementation of the remedy for these materials selected in
the 1986 Record of Decision. If EPA determines that the
prese"ce of these drums presents an unacceptable risk to
humao ,lth or the environment, interim measures will be
con: d prior to final management.
A v4mmentor asked when BPA learned of the presence
of buried containers that are indicated on a fiqure
in the feasibility 8tudy outside the peri.eter
fence surrounding the site. .
EPA told the commentor the information was generated in 1983
when a remedial investigation was performed for the overall
Ellisville area site. These locations were overlain over
the dioxin map which EPA has more recently generated.
A co..entor asked if ground water aonitoring had
been perforaed. .
Samples were collected in 1990 from two private wells near
the Bliss-Ellisville site and from nearby Lewis spring.
These samples were analyzed for volatile compounds. No
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volatiles were detected in any of the three samples
collected.
In correspondence of August 22, 1991, EPA committed to
perform an investigation of the ground water at the Bliss-
Ellisville site. A representative from the state Department
of Health offered at the public meeting that samples
collected by that agency had detected trace levels of TCE, a
common industrial solvent, in the local ground water, but
that the contamination could not be linked to the Bliss-
Ellisville site.
A commentor asked what transport route would be
used to haul contaminated .aterial. fro. the .ite.
EPA responded that the specific haul routes would be
determined during the remedial design. It would appear to.
be preferable to haul the contaminated materials to strecker
Road for offsite transport rather than bringing the
contaminated materials through the more densely populated
Turnbury subdivision.
A commentor asked how long ezcavation of the site
would take.
EPA responded that a rate of 100 cubic yards per day would
be. reasonable to assume. This would result in 70 days of
excavation, plus additional time for site mobilization,
restor~tion, and demobilization.
A comment or asked who is liable for the clean up of
those ~~..rials that are discovered beyond the site
perbu ~. ..-
The clean -~ ~s planned to be conducted as a fund-lead
activity. A number of potentially responsible parties have
been identified as defendants in ongoing litigation related
to this si~e. Additional information may be discovered when
the buried containers are uncovered which may identify
additional potentially responsible parties. It is not
typical for EPA to pursue homeowners as potentially
responsible parties.
A co..entor asked if cities were held re.ponsible
for cleanup oosts.
EPA noted that there have been occasions where cities have
operated landfills and have been held responsible. EPA
generally attempts to pursue those that are most directly
responsible for causing the problem.
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A commentor asked why the people purchasing homes
in the area were not notified of the existence of
the site.
EPA responded that the site was included in EPA's National
Priorities List and the Missouri Registry of Abandoned or
Uncontrolled Hazardous Waste Sites. In addition, many
newspaper articles have. appeared regarding this site.
A commentor s.id she had no~iced the tarp in the
creek was torn.
EPA acknowledged that the erosion had damaged the liner in
the creek in places. EPA will perform an assessment to
determine if measures are necessary to stabilize the site to
control the potential for offsite migration of contaminants
prior to implementation of the final remedy.
A commentor asked if notice would be provided to
near~y re.ident. prior to the use of their .treets
to implement the r..edy.
EPA responded that notice would be provided in advance of
any response actions involving transport of contaminated
materials at the site.
A commentor asked what quarantee existed that the
thermal treatment unit at Times Beach would be
removed upon completion of the project.
MDNR responded by saying there would be several safeguards
built into thf~~cinerator. The unit would be permitted by
the State of ~uri. The permit will limit the duration
of operation.lR stated that under current State law,
operation of ~ unit is limited to five years. Second, the
permit will restrict the feedstock to only dioxin-
contaminated materials from the designated eastern Missouri
sites. Another safequard is State ownership of the Times
Beach property and control over access to the property
through a license agreement with Syntex. The license
agreement can be revoked at any time. Also the Consent
Decree itself provides restrictions on the operation of the
thermal treatment unit at Times Beach, making it illegal to
exceed the scope of the project. The Consent Decree is
enforceable in Federal Court.
COMMENTS RECEIVED lBQII DI PUBLIC
A commentor wanted to endorse the thermal treatment
of dioxin-contaminated materials at the site.
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Water utility Service company OVDS and operates an
a-inch water main that traverses the northwest
portion of the Bliss-Bllisville site. Since
remedial excavation is planned in this area to
remove dioxin-contaminated .oil. aDd buried drums,
the Water utility Service Company anticipate. that
the ezcavation activities will uncover the exi.tinq
water .ain. In order to avoid potential
contamination of the public water .upply from
either ezistinq conditions or the fu~ure excavation
activitie., the Company proposes to permanently
abandon that portion of the .ain within the site.
It will be necessary to reconnect the remaininq
portion of the main at an offsite location. The
estimated expen.e for the propo.ed reconnect ion and
abandonment is $34,541. The company i. requestinq
preauthorization approval for this claim to be
submitted against the Fund.
Preauthorization of the cost to abandon and relocate the
water line cannot be granted by EPA at this time. This
action is not included in the selected remedy, and cannot be
considered a component of the current remedy selection. In
addition, it is unlikely that abandonment of the water main
will be required during excavation of the dioxin-
contaminated soil. Dioxin contamination at the site is not
expected to extend below a depth of approximately one foot.
Since the water main is installed at a greater depth,
excavation of the dioxin-contaminated soil should not
interfere with the main.
--
It is also uncertair whether the water main crosses areas of
non-dioxin contamir." ~.i..:.~. . The non-dioxin wastes are
generally located .~:", :..:. :~crete subsurface areas. Depending
on the relative dat~'. f water main installation and waste
disposal, either the ~astes would have been encountered when
installing the water main, or the water main would have been
encountered when the pits were excavated for disposal of the
wastes. It is conceivable that migration of contaminants
through the soil could have resulted in the contamination of
soils surrounding the water main, but this does not
necessarily require abandonment of the main. Soil removal
procedures, such as vacuum techniques, exist which are
capable of removing the surrounding soil without
disturbing the water main.
COMMENTS RECBIVED PROM fII STATB OP MISSOURI
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written comments on the Feasibilitv study X2x Manaaement.2!
TCDD-Contaminated Materials ~nd Proposed Plan for the Bliss-
Ellisville site were received from the Missouri Department
of Natural Resources (MDNR). These comments and the
corresponding EPAresponses are included in this section.
EPA has liaited the scope of the Peasibility study (PS)
and Proposed Plan for the Bliss-Bllisville site to
the aanaq..ent of TCDD (diozin)-contaminated
materials at the site. The proposed r..edy affects
the aanaq..ent of the non-diozin contaainated
material at the site. .e do not believe the tvo
vaste streams can really be separated. As a result
of decisions 8ade regarding the diozin, the non-
diozin vaste vill also be left in place several
years before r..edial activities commence.
The scope of the feasibility study and proposed plan are
appropriately limited to the final management of dioxin-
contaminated materials at the site. This is the only
remaining component of a comprehensive final remedy for the
site. Interim management of dioxin-contaminated materials
and final management of non-dioxin-contaminated materials
were addressed in the 1986 Record of Decision for the Bliss-
Ellisville site.
The current remedy selection does not necessarily delay
implementation of response actions for the non-dioxin
contamination. Measures to address the non-dioxin
contaminants at the site can proceed independently of the
dioxin remediation. . will conduct investigations to
determine if interim . ~es are required to address the
dioxin or non-dioxin ~ minants at the site pending
implementation of a fin~. remedy. EPA will assess the
continued effectiveness of the stabilization measures
implemented by the state in 1985. An investigation will
also be conducted to determine if site contaminants are
migrating to the ground water. Appropriate interim response
actions will ~e conducted to assure protection of human
health and the environment pending implementation of the
final remedy.
At several points in tbe ps, it is assumed tbat the
site vas only sprayed vitb diozin. Due to tbe
unknowns reqardinq tbe site history and tbe
"knowns" reqardinq Bliss's past disposal practices,
this assumption may not be a safe one.
The feasibility study considered the non-dioxin contaminants at
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the site to the extent that the presence of these materials has
an impact on the management of dioxin-contaminated materials.
Sampling of dioxin-contaminated areas in the past has not
detected the presence of significant concentrations of other
contaminants.
In the Remedial Investiqation (RI) conducted in
1983, dioxin was found at a 20-foot depth. This
indicates, at the least, the dioxin-contaainated
materials were disposed of deeper than suspected.
The 1983 Remedial Investigation did report a 2,3,7,8-TCDD'
concentration of 8.7 ppb in a core sample collected from the
15 to 20 foot depth interval at location ELL-49. Since
1983, EPA has gained considerable experience in the
collection of representative subsurface samples for dioxin
analysis. , The procedures used to collect the 1983 sample
that yielded these results are no longer considered valid
for the collection of subsurface samples for dioxin
analysis. Evaluation of these sampling procedures has
indicated that cross-contamination of dioxin between depth
intervals occurs, thus invalidating the sample results.
Upon review of the sample collection procedures employed in
1983, EPA believes that the 2,3,7,S-TCDD data reported for
subsurface samples collected at ELL-49 are not valid due to
the likelihood of cross-contamination having occurred.
This may mean the wastes are co-minqled. The issue
of whether the wastes are co-minqled is important
to the mobility of the dioxin. Diozin is normally
not very mobile, but if it is mixed with substances
such as solvents which a~. present at this site, it
can ~ecome mobile and m~". :",~.e to qround water. We
have seen this happen .'. ~:':A~exls sprinqfield '
laqoon. '
As discussed above, the data collected at the Bliss-
Ellisville site to date do not indicate that co-minqlinq of
dioxin with significant concentrations of non-dioxin
contaminants has occurred. The situation at the B1iss-
Ellisville site is very different from the Springfield site,
where dioxin and non-dioxin wastes, including solvents, were
co-disposed in an unlined lagoon. Ground water samples
collected to date from private wells located near the Bliss-'
Ellisville site and Lewis Spring have not indicated that
contamination is migratinq to the qround water.
, .
The qround water situation at the .ite needs to be
characterized in order to determine the
advisability of leavinq the wastes in place for an
extended period of time. The state believes it is
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critical to see a specific commitment to perform a
remedial investigation of the ground vater at the
Bliss-Bllisville site in. the ROD.
The EPA is committed to performing an investigation of the
ground water at the Bliss-Ellisville site. This commitment
was reaffirmed in an August 22, 1991 letter from EPA to MDNR
(Attachment 3). The ground water investigation will be
directed at determining if a release into the ground water
is occurring, and if response actions prior to final
management of the dioxin wastes are necessary to assure
protection of human health and the environment.
It is not appropriate to perform a remedial investigation of
the ground water at this time. A remedial investigation is
a component of a long-term remedial planning process which.
includes development of a feasibility study to evaluate
various alternatives, development of a proposed plan, public
comment on these documents, and remedy selection in a Record
of Decision. The ground water investigation would be
greatly expedited if it were to proceed under a separate
response authority which EPA administers.
Another concern the state has i. ero.ion at the
site. It appear. that the ero.ion ia occurring
near an area vhere ZPA found fairly high levels of
diozin contamination in the borings. Creek A is a
losing stream and erosion into it vill spread the
contamination, threaten ground vater, and increase
the volume of material to be .anaged. BPA needs to
commit in the ROD to evaluating the erosion problem
and performing appropriate interim erosion control
measures.
EPA is committed to taking act that are necessary to
protect the health of nearby re~_~ents until final
management of the dioxin and non-dioxin contaminants is
performed. .This includes an assessment of the site to
determine if additional stabilization measures are required
to control offsite migration of contamination.
Stabilization measures found to be necessary will be
implemented using EPA response authority. Additionally, EPA
is required to perform annual removal assessments at sites
on the National Priorities List (including Bliss-Ellisville)
to determine if response actions are necessary to protect
human health and the environment until a final remedy is
implemented. This activity will continue.
The feasibility study states that composite vater
sample. shoved contamination vith hazardous
substances in September 1980. This .tatement vould
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seem to lend credence to the concern over water
quality at the site. It should be explained where
these samples were taken.
The feasibility study mentions composite soil samples and
water samples. The samples referred to by the state are two
discrete surface water samples collected from the Bliss-
Ellisville site. One sample was collected from a creek 200
yards east of the arena. The second sample was collected.
from a pond adjacent to the arena on the west side.
Analyses of these samples detected very low concentrations'
of non-dioxin organic compounds, and do not reflect on
ground water quality. This data will be forwarded to the
State~ .
Analytical results of ground water sample.
collected by BPA in 1990 were not pre.ented in the
feasibility study.
Water samples were collected by EPA in 1990 from two nearby
private wells and Lewis Spring. These samples were analyzed
for volatile compounds. No volatile compounds were detected
in any of the three samples. This data will be forwarded to
the State.
The stated conclusion that the estimated average
depth of dioxin contamination equal to or greater
than 1 ppb is about 1.5 feet should not shroud the
fact that dioxin has been found at a depth of up to
20 feet.
Sampling conducted at the Bliss-Ellis~~tle site in 1989 and
1990 indicate that dioxin contamination is limited to
surface soils. As explained previously, the sampling
procedures used in 1983 to collect subsurfac~ samples are
not considered reliable for determining the vertical extent
of contamination.
The location of the bore hole. appearing in Piqure
2-5 of the feasibility study .hould be more
preci.ely identified.
More precise information relating to the locations of the
boreholes appearing in Fiqure 2-5 has been requested, and
will be forwarded to the State.
The state would like to review the data from the
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1990 samplinq of the cr..k and cr..k s.di..nts.
Additional samplinq .ay b.warranted if non. has
been perform.d ainc. .rosion was oba.rv.d in 1990.
The information requested will be forwarded to the State for
review.
Du. to the nature of this site, it is quite
possible that removal of dioxin qreater than 4 f.et
d.ep may need to take place aa waa done at the
stout site where dioxin contaminated fill material
was found.
Removal of soil at depths greater than four feet at the
stout site was performed due to the concern for "pockets" of
contamination which could possibly exist in various portions
of the fill area. EPA does not have any information that
would indicate that dioxin-contaminated material has been
used for fill at the site. As explained previously, data
collected in 1989 and 1990 indicate that dioxin
contamination is limited to surface soils.
Cleanup criteria have been established for dioxin-
contaminated surface soils at the B1iss-El1isvi1le site on
the basis of recommendations from State and Federal health
agencies. Excavation of dioxin-contaminated soils will
continue until reaching a residual concentration of less
than 1 part per billion in the initial foot, less than 10
parts per billion at depths greater tha- ~ne foot, or
encountering bedrock. Excavation will proceed beyond a
total depth of four feet. If data be~ available which
indicates that dioxin contamination ma} .st .in discrete
pockets exceeding health-based levels beneath the surface,
or otherwise pose an unacceptable risk to human health or
the environment, this data will be evaluated as new
information, and the need for response measures will be
assessed.
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