United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R07-93/062
March 1993
&EPA Superfund
Record of Decision:
North U Drive
Well Contamination, MO
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50272.101
REPORT DOCUMENTATION
PAGE
11. REPORT NO.
EPA/ROD/R07-93/062
~
3. Recipient'. Ace_Ion No.
4. TItle and Subtitle
SUPERFUND RECORD OF DECISION
North U Drive Well Contamination, MO
First Remedial Action - Final
7. ,AWhor(l)
s
Report D8t8
03/31/93
6.
I.
Performing Organization Rept. No.
Q.
P8rtormlng Organization Name Ind Add,..
10 Project T88k/Work Unit No.
11. Contrad(C) or Grant(G) No.
(C)
(G)
12. Spon8orIng OrganIzation Name and Add.....
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Pwlod CovIl8d
Agency
800/800
14.
15. ~ary Hat.
PB94-964306
16. Abltrac:t (Umlt: 200 -W)
The North U Drive Well Contamination site is an area of ground water contamination
located approximately 1.25 miles north of Springfield, Greene County, Missouri. Land
use in the area is predominantly residential, with woodlands and manufacturing/
commercial businesses that include a few abandoned service stations and the Montgomery
Metal Craft Plant. Approximately 200 to 300 residents live within the area of ground
water contamination. Another Superfund site, the Fulbright Landfill, is located one-
quarter mile to the north of the site. AS part of its site operations, the Montgomery
Metal Craft plant handled, stored, and cleaned used underground petroleum storage
tanks, and utilized as many as three underground tanks on the property. The North U
Drive Well Contamination site was first identified as a potential hazard in late 1983
when, citizens using private wells complained of a chemical taste and odor in their
drinking water that resembled gasoline or petroleum. Subsequent sampling by the State
identified 12 onsite wells that were contaminated by gasoline constituents, including
benzene, toluene, ethylbenzene, xylenes, and methyl tertiary-butyl ether (MTBE), which
are constituents 'of gasoline. MTBE is used exclusively as an additive in gasoline and
'was not commercially available until 1979. Therefore, MTBE contamination is indicative
of contaminant release since 1979. Meta contamination also was detected in the soil
(See Attach~d Page)
17. Document An8Jy8Is a. D88criptors
Record of Decision - North U Drive
First Remedial Action - Final
Contaminated Medium: None
Key Contaminants: None
Well Contamination, MO
b.
Id8nIltlera/Op8noEnded T8t'mI
c.
COSATI FI8IdfGroup
11. AYlllabil1ty Stat8m8l1l
19. Security Class (ThII Report)
None
2D. Security aau (ThIs P~98)
None
21. No. of Page.
18
22. PrIce
(See ANSI-Z3SI.18)
SHIn8ttUt:fioM on R..,.,...
OPTIONAL FORM 272 (4-77)
(Fonnerfy NTIS-35)
Department of Commerce
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EPA/ROD/R07-93/062
North U Drive Well Contamination, MO
First Remed.ial Action - Final
Abstract (Continued)
and ground water, but most was within the range concentrations naturally found in the
area. In 1985, as part of a removal action, municipal water lines were installed to
provide an alternate water supply to affected residents, and 62 wells were plugged to
control the spread of contamination and prevent human consumption. Later in 1985, in an
unrelated action, PCB capacitors and PCB-contaminated soil were removed offsite from the
former Curtis Service Station, located near the site. This ROD addresses the contaminated
ground water at the site. EPA determined that it lacks jurisdiction in this case, and the
RI demonstrated that the site does not pose a significant threat to human health and the
environment; therefore, there are no contaminants of concern affecting this site.
The selected remedial action for this site is no further action because EPA, in
consultation with the State, has determined that it lacks jurisdiction to undertake or
require additional response actions to address the release of petroleum products.
Additional .response activities are precluded under CERCLA authority because:
(1) petrole~-related contaminants are excluded from CERCLA response activities; and
(2) substanl::es found naturally at a site are excluded from CERCLA response activities.
Additionally, the risk assessment conducted as part of the RI demonstrated that the
contaminant releases db not pose a significant threat to human health, or the environment.
There are nl) present worth or O&M costs associated with this no action remedy.
PERFORMANCE STANDARDS OR GOALS:
Not applicable.
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RECORD OF DECISION
NORTH U DRIVE WELL CONTAMINATION
DECLARATION
FINAL REMEDY SELECTION
SITE NAME AND LOCATION
North U Drive Well contamination
springfield, Missouri
STATEMENT OF BASIS AND PURPOSE
This decision document presents the final remedy selected for the North
U Drive Well contamination site in Springfield, Missouri, The u.S.
Environmental Protection Agency (EPA) , in consultation with the
Missouri Department of Natural Resources (MDNR) , selected the final
remedy in accordance with the requirements of the Comprehensive
Environmental Response, compensation and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and Reauthorization
Act of 1986 (SARA), and the National oil and Hazardous Substances
Pollution Contingency Plan (NCP) , 40 C.F.R. Part 300. The EPA bases
this decision upon the documents and information contained in the
Administrative Record for this site. Copies of the Administrative
Record are available for review during normal business hours in the
Docket Room at EPA Region VII Office, 726 Minnesota Avenue, Kansas
City, Kansas: at MDNR's Hazardous Waste Program File Room, 205
Jefferson Street, Jefferson city, Missouri: and at the Kearney Street
Branch Library, 630 West Kearney, Springfield, Missouri.
The State of Missouri (MDNR) has been the lead agency on this site and
conducted the Remedial Investigation (RI). The state and EPA jointly
recommended the preferred or recommended alternative identified in the
Proposed Plan, which is selected as the remedial action for this site
in this Record of Decision (ROD).
DESCRIPTION OF THE SELECTED REMEDY
The EPA, in consultation with the state of Missouri, has determined
that it lacks jurisdiction to undertake or require additional response
or remedial actions under CERCLA for the petroleum-related releases and
the elevated levels of metals in groundwater at the site. Therefore,
the final remedy for the site is "No Further Action." Since no
remedial action is necessary at this site, EPA has determined that its
response at the this site is complete. Therefore, the site now
qualifies for inclusion on the Construction Completion List. It should
be noted that in 1985, the EPA conducted a removal action at this site~. -
As part of the removal, municipal drinking water lines were extended to
provide drinking water to users of well which were contaminated.
Contaminated wells were then plugged in accordance with state
requirements.
1
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DECU.RATION
Under section 104 of CERCLA, the governmental response authority is
limit:ed to addressing a release of a "hazardous substance,"
"pollutant," or "contaminant."
The t.erm "hazardous substances" is defined in section 101 (14) CERCLA to
inclt.:.de approximately 714 toxic substances listed under five
environmental statutes, including CERCLA. The definition of a
hazardous substance excludes "petroleum including crude oil or any
fraction thereof," unless specifically listed under one of the five
statu.tes. Hazardous substances found at levels which exceed those
norma.lly found in such petroleum fractions, as well as substances not
norma.lly found in petroleum products, are not excluded from CERCLA
response actions.
In ad.dition, Section 104(a)(3) (A) of CERCLA does not allow for a
respcnd activity where there is a "release or threat of release of a
naturally occurring substance in its unaltered form, or altered solely
through naturally occurring processes or phenomena, from a location
where it is naturally found."
Additional response activities are therefore precluded under CERCLA
authority because (1) petroleum-related contaminants are excluded from
CERClA response activities: and (2) substances found naturally at a
site are excluded from CERCLA response activities. Therefore, no
further action is selected as the final remedy for the North U Drive
Well contamination site. Additionally, a Risk Assessment on the site'
was conducted a part of the RI and demonstrated that the contaminant
releases do not pose a significant threat to human health, welfare, or
the environment. Since no remedial action is necessary at this site,
it now qualifies for inclusion in the "sites awaiting deletion"
subcategory of the Construction Completion category of the National
Priorities List.
.f/3! /93
Date (
=c-
'/ ?'-<,l, I
William A. Spra
Director .
Air and Toxics Division
2
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RECORD OF DECISION
OORIH U DRIVE WEU. CONl'AMINATION SITE
SPRIN:;FIEID, MISsaJRI
Prepared by:
Missouri Department of Natural Resources (MDNR)
and
United States Environnental Protection Agency (EPA)
Region VII
March 1993
3
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TABLE OF CONI'OO'S
DECLARATION
TITLE PAGE
TABLE OF CONI'ENI'S
DECISION SUMMARY
Sect:ion 1, Site Background
1.1 Site Location and Description
1.2 Site History
Sect:ion 2, Camuni ty Participation
Sect;ion 3, Scope of Response Actions
Sect;ion 4, Site Characteristics
Sect;ion 5, Surmary of Site Risks
5.1 Definition of the Reasonable Maxilm.m1 Exposure (RME)
5.2 Noncarcinogenic Risks for the RME
5.3 carcinogenic Risk for the RME
5.4 Environmental Risk
Sect;ion 6, Statutory Authority Finding
FIG.JRES
Figure 1, weation of the Site
Figure 2, Site Features
Figure 3, Dye Injection and Dye Detector Locations
4
1
3
4
5
5
5
8
9
9
12
12
13
13
14
14
6
7
11
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RECORD OF DECISION
OORrH U DRIVE WELL CONl'AMINATION SITE
DECISION SUMMARY
SECl'ION 1, SITE BACKGROOND
1.1 Site Location and Description
The North U Drive Well Contamination site is located approximately 1.25 miles
north of Springfield, Greene County, Missouri (Figure Number 1). The site is
bounded on the north by North Stage Coach Road, on the east by Pea Ridge creek,
on the west by New Miss.ouri Highway 13, and. the south by the south property
line of the Montganery Metal Craft facility (Figure Number 2). The site and
its surroundings consist of a rural/residential neighborhood, woodlands, and
manufacturing and. carmercial businesses. The topography consists of ICM hills
and sane sinkholes. The area is in a karst setting. Karst refers to solution
features such as caves, sinkholes, and springs. Approximately 200-300 people
live in the area of groundwater contamination. The fonner Fulbright Landfill,
also a Superfund site, is located less than 1/4 mile north of the site. The
Fulbright ~ Station and Municipal Water Plant is located less than 1/4 mile
east of the site.
1.2 Site Historv
The North U Drive well Contamination site was first identified as a potentially
hazaIdous waste site in O:tober 1983, when citizens c~1ained of a chemical
taste and odor in their drinking water. C~laining residents, all of whan
used private drinking water wells, consistently described a petrolemn or
gasoline-type odor in their wells. 'lWeI ve wells were found to be
contaminated. One of the wells contained 470 ug/l benzene, which exceeds EPA's
Suggested No Adverse Response Isvel (SNARL) ten day limit of 350 ug/l.
5aIrpling by MDNR identified benzene, toluene, ethylbenzene, xylene, and methyl
tertiary butyl ether (Ml'BE) as the primary contaminants in the groundwater.
These catpJUnds are constituents of gasoline. Ml'BE is exclusively used as an
additive in gasoline, and was not carmercially available until 1979.
Therefore, MIBE contamination is indicative of contaminant release since 1979.
Water lines were installed in 1985 to provide Springfield city water to all
affected residents. In addition, 62 wells were plugged to control the spread
of contamination and to prevent residents fran drinking contaminated water.
These activities were conducted by the EPA Raooval Program. The EPA conducted
a separate, unrelated rencval of PCB capacitors and PCB contaminated soil at
the fonner curtis Service Station in September 1985.
5
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Scale
( feet)
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Prepared by Ma.r1t Mayo
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Source: USGS 7.5' Ebenz8r.
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(ey to Counllel
Figure 1 - LocAtion of
North U Drive Well Contamination Site
6
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7
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The source of contamination was not known at the time the site was listed on
the! National Priorities List (NFL) in June 1986. The release appeared to have
originated in the vicinity of the Montganery Metal Craft Plant. This finding
was based on the configuration of the plume and the direction of groundwater
flew. The fact that the contaminants are petroleum-related is also consistent
with operations at the Montganery Metal Craft Facility. Montgooery Metal Craft
has, as part of its operation, handled, stored, and cleaned used underground
petroleum storage tanks. They also have had as many as three underground
stc-rage tanks in use on their property. An autaoobile service station (fonner
Curtis Se.rvice Station) operated inmediately northeast of the Montgc:mery Metal
Cra.ft property until 1960. The extended period of time since the se.rvice
sta.tion closed, together with the presence of Ml'BE (not available until 1979),
mad.e the fODDer Curtis Service Station an unlikely source.
SECTION 2, CCM-nJNITY PARrICIPATION
The- RI and Proposed Plan for the North U Drive Well Contamination site were
released to the public on February 24, 1993. These two documents were included
in the administrative record file maintained at MDNR's Hazardous Waste ProgLant
File Roan (205 Jefferson Street) in Jefferson City, Missouri; at EPA's Region
VII Office (726 Mirmesota Avenue) in Kansas City, Kansas; and at the Kearney
StJ:eet Branch Library (630 West Keamey) in Springfield, Missouri.
The notice of availability for these two documents was published in the
~'inafield News-Leader on February 24 and 28, 1993. A public ccmnent period
was held iran February 24, 1993 through March 25, 1993. In addition, a public
hearing was held on March 9, 1993. At this IlEeting, representatives fran MIJIR,
the! Missouri Department of Health, and EPA explained the results of the RI,
presented the Proposed Plan, and answered questions regarding the RI am
Prop:>sed Plan. A response to the carrnents received during this pericx:i is
inc:luded in the Responsiveness SUImary, which is part of this Record of
Dec:ision.
As lead agency, MDNR conducted camunity relations for the North U Drive well
COIlltamination site. Prior to initiation of the RI, MDNR developed a CCJII1I.1nity
Relations Plan. The dcx:unent lists contacts and interested parties throughout
government and the local ccmnunity. It also identifies ccmmmity relations
acti vi ties which were conducted during the RI. Several fact sheets were issued
dw::ing the RI to apprise the camunity of significant developnents or of the
status of work at the site. On OCtober 2, 1991, an availability session was
held to answer questions fran the ~lic and to solicit info:c:nation fran arrf
cit:izen who may have infcmnation on the release of contaminants at the site.
This event was advertised in the 5Prinafield News-~er, am was covered by
the~ local print and television media. .
8
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SECTION 3, SCOPE OF RESPONSE ACTIONS
The Proposed Plan applies to the entire North U Drive Well Contamination site,
including all affected media (surface and groundwater, soil, bedrock, and
air). A separate removal of polychlorinated byphenyl (PCB) contaminated soil
was conducted by EPA at the North U Drive PCB site. This is considered a
separate site and not relevant to this decision or the North U Drive Well
Contamination site. The remedial action selected for this site in this ROD is
the final site renedy.
As stated previously, available data and infonnation indicate that the original
contamination at the site apparently was related to a'release of gasoline.
Therefore, Superfund's response activities are precluded because of the lack of
jurisdiction under the petroleum exclusion. Additionally, as will be presented
in Section 5, risks posed by all manmade contaminants at this site, including
petroleum contaminants, do not warrant further cleanup.
Elevated concentrations of sane metals were recognized in sane wells during the
RI and are considered a natural phenanenon resulting fran natural metals in
soils at the site. As such, the metals are not eligible for CERCIA response
actions under this scenario. '
Very low concentrations of a few organic contaminants which do not appear
petroleum-related were found in soils and groundwater. None of these
contaminants are present in sufficient concentrations to pose a significant
threat to human health or the envirorment. Also, they are not widespread, rot
generally are found only in isolated samples. Non-petroleum-related
contaminants are probably a result of small-scale spills, leaks, or other minor
releases.
SECl'ION 4, SITE ~STIC5
'!he RI at the site identified three main types of contaminants:
*
Petroleum-related contaminants, primarily benzene, toluene, ethy1benzene,
and xylene (Bl'EX). Bl'EX canpounds are constituents of, or additives to,
gasoline. These canpounds were detected in both groundwater am soils
during the RI, except for ethy1benzene, which was not detected in
groundwater. Other minor petroleum-related contaminants were detected in
trace quantities. Ml'BE was not detected during the RI.
Metals. Several metals were detected in significant quanti ties in total
metals analyses of groundwater. Generally, these same metals were either
not detected, or were present only in trace amunts in dissolved metals
analyses. In soil sanples, the sane suite of metals were also detected.
However, roost were within the range of concentrations naturally found in
Greene County soils.
*
*
Non-petroleum-related oraanic contaminants. In general, these canpounds
were detected at or near the limit of laboratory detection or in trace
quantities in both groundwater am soil sanples. None pose a significant
threat to human health or the environment.
9
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Contaminant concentrations in the groundwater changed significantly between the
tine of initial site activities and the time of the RI. In general, overall
contaminant concentrations decreased markedly during this period, with sane
contaminants not being detected at all during the RI. MrBE, one of the
ori.ginal five primary contaminants, was not detected in the RI, and
ethylbenzene was not detected in any groundwater sanples. Additionally, the
are!c31 extent of contamination did not expand, but appeared to decrease.
This overall reduction in the extent of contamination is probably a result of
two factors: ( 1) groundwater beneath the site rooves very rapidly, which is
cor.sistent with the karst setting of the site. Three dye traces were conducted
as part of the RI, and in two cases, dye injected near the suspected point of
release was detected at North U Spring, approximately 1/4 mile fran the point
of injection in less than 3 weeks (Figure Number 3). ('nle third dye was not
det.ected, probably due to masking by a previously injected dye.) North U
Spring is a discharge point for the upper aquifer. This rapid groWldwater flow
may have flushed contaminants fran the site or diluted the contaminated
grcundwater. ( 2) the primary contaminants are lighter than water, allowing
them to "float." This probably enhanced their ability to be transported
through the hydrologic systan. These two factors probably worked to dilute
contaminant levels below detection limits over IlUlch of the site. .
A good example of the reduction in the concentrations of groundwater
contamination is the groundwater beneath the Curtis Service Station. In 1984,
approximately one foot of petroleum was observed floating at the top of the
water table beneath this property. However, during the RI, not only was
free-floating petroleum absent, but dissolved BTEX cCDp)W1ds were present only
in trace quantities. Moreover, En'EX carp>unds were detected in only the first
of two sanpling rounds during the RI. In addition, this property was the onlY
location where En'EX carp:nmds were detected in wells during the RI.
Another inportant change was that the concentrations of MrBE and ethylbenzene
decreased mre significantly than the other contaminants. 'Ibis is probably
explained by the physical arrj chemical properties of these two carpmrxis. MrBE
is IIUlch mre soluble than the other primary contaminants (Bl'EX). 'lberefore,
JlDSt or all MmE has probably solubilized and subsequently left the site
through the fast-rooving hydrologic system. Ethylbenzene canoonly degrades into
other carpounds, such as benzene and toluene. The aroount of time elapsed since
thE~ release may have been sufficient to allow roost or all ethylbenzene to break
cD.irn into other ~.
Metals were not included as contaminants of concern at the site at the time the
site was listed on the NPL. ~ing the RI, however, it bec:a1Ie apparent that
netals concentrations were elevated in sane water salTples.
'!he RI concluded that this was a natural phenarenon. First, no evidence exists
to suggest a release of netals has occurred at the site, and the types of
netals found are inconsistent with industrial/cannercial activities at the
site.
10
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EXPLANATION
N
NORTH U DR~VE
SP~~NGfijElfD, MijSSOUR~
A
DYE DETECTOR
.
DYE INJECTION LOCATION
i
\ (
1'10TE:
DYE INJECTION CONDUCTED BY MISSOURI DGLS
GROUNDWATER FLOW
DIRECTION
Prepared by Mark Mayo
Ecology &. Environment, Inc.
Source: USGS 7,5' Ebenzer,
1.40 Quad. rev. 1 Q76
Figure 3,
Dye Injection and Dye Detector Locations
11
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Also, it was documented. that the phenanenon was restricted. to relatively turbid
samples. :-1etals in Greene County soils are generally present in sufficient
concentrations to cause the observed. phenomenon if entrained. in a water
sample. This is supported. by the fact that the phenanenon is restricted to
wells which are not in use. Wells which are not pumped regularly accurm..1l.ate
sediment in the borehole and fractures around the well. When purged and
sanpled, the sediment is entrained, causing turbidity.
Non-petrolelD11 organic contaminants generally were found only in isolated
locations. Since the contaminants are not distributed in a pattern suggestive
of a significant spill or plume, they probably represent small-scale spills or
leaks. . Many of these ccmpounds are polycyclic araratic hydrocarbons (PAHs).
PAfifs are formed during the incaTlplete burning of coal, oil and gas, garbage, or
oth.er organic substances. They can be mamnade or occur naturally. PAHs may be
fou11d in the heavy, tarry fraction of, petroleum prcx:tucts. It therefore is
possible that the PAHs at the site are related to a petroleum release.
SECTION 5, SUMMARY OF SITE RISKS
Because c:::ERC:[A lacks authority for addressing releases of contaminants of
con.cern at the North U Drive Well Contamination site, an assessment of site
risks was not required. Nonetheless, a Risk Assessment was conducted to
provide the public with info:cnation on potential health concerns, and for the
use by any other agencies which may have regulatory authority over the site.
The Risk Assessnent considered only manmade contaminants, and did not assess
risks associated with naturally occurring metals.
5 .1 Definition of the Reasonable Maximum Exoosure (RME)
Info:cnation and data indicate that the site cw:rently does not pose any
potentially significant threat to the envirorm:mt. The baseline Risk
Assessment therefore focused. on the carcinogenic and noncarcinogenic risk to
h1man health, which could result fran both current and future land uses and
exposures at the site.
Pursuant to the National Contingency Plan, 40 C. F . R., Part 300, in evaluating
risks at the site, the potential health risk for a reasonable maximJm exposed
irrlividual (RME) was used. RME exposures are used. to deteDnine if renedial
actions are required at sites where CERCIA authority exists. RME exposures
generally include not only current exposures given existing land uses, but also
exposures which might reasonably be predicted based upon expected or logical
fut.w:e land uses.
ThE! RME for this site includes certain exposures which may not currently
exist. MOOR am EPA believes it is reasonable to expect such exposures could
occ:u.r in the future.
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MDNR and EPA identified two likely current and future RME scenarios,
residential and industrial/carmercial. This is consistent with the current
makeup of the site. Because land use is not likely to change in the future,
they are also considered appropriate for future exposure scenarios.
Contaminant concentrations were assumed to ranain constant overtime. This may
be a conservative asstJlli"tion, however, because Bl'EX contaminant levels in the
shallow aquifer have dropped dramatically since the time of the original
release, and may drop further.
The residential scenario assumes an adult lives on the site 365 days per year
over a 30 year pericxi, ingesting groundwater, incidentally ingesting
contaminated soil, and directly contacting contaminated soil. The occupational
scenario consists of an adult eq>loyee working on the Montganery Metal Craft
property 250 days per year over a 25 year pericxi. The adult E!!fIi)loyee
incidentally ingests and directly contacts contaminated soil on the Montganery
Metal Craft property at the site.
Excessively tw:bid water sartq;)les were not considered in the Risk Assessment.
As indicated previously, tw:bidity was caused by entrained natural sedimants,
which in tw:n contained metals in sufficient concentrations to cause the
observed levels. Water containing excessive tumidity is generally
aesthetically unacceptable for drinking. Public surface water supplies can
have no roore than 1.0 nephelanetric turbidity units (NlU), because excessive
turbidity can mask the presence of bacteria. 10 NIU was selected as a
criterion of the suitability of well water or grourx1wa.ter at this site for
drinking. Therefore, sarrples with tw:bidity exceeding 10 NlU were not
considered in the Risk Assessment. It should be noted that none of the wells
exhibiting excessive turbidity were in current use as a water source. In soil
sanples, only metals present in concentrations above background concentrations
for Greene County were considered in the Risk Assessment.
5.2 Noncarcinoaenic Risks for the RME
The Total Hazard Index for the residential and industrial/ coomercial exposure
scenarios are 1.0 and 0.013, respectively. Human health risks may exist if the
Total Hazard Index exceeds 1.0. Therefore, health risks for noncarcinogenic
contaminants at the site are considered unlikely.
5.3 carcinoaenic Risk for the RME
The Excess Lifetima cancer Risk for the residential exposure scenario is 7.3 in
1,000,000 in the RME's lifetime risk of cancer. '!be Excess Lifetima Cancer
Risk for the occupational exposure scenario is 9.5 in 10,000,000. Both are
well below the level (carcinogenic risk of one in ten thousarrl) at which the
National Contingency Plan suggests that remedial actions under Superf\n:i are
warranted. .
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5.4 Environmental Risk
Past releases of contaminants at this site do not appear to present a current
or future threat to the environment. 'lbroughout the histozy of this site, the
only significant contamination was found in the groundwater. Furthenoore,
concentrations of contaminants in groundwater dropped dramatically between the
time of site discovezy and the RI, indicating that natural processes are
attenuating contaminant levels.
SECTION 6, srA'lUl'ORY AIJrnORI'lY FINDI:OO
Under Section 104 of CERCIA, Superfund response authority is dependent upon a
release, or potential release, of a hazardous substance, pollutant, or
contaminant.
The tenn "hazardous substances" is defined under CERCIA Section 101(14) to
include 714 toxic substances listed under CERCIA and four other environmental
statutes. The definition of a hazardous substance excludes "petroleum,
including crude oil or any fraction thereof," unless specifically listed W1der
one of the five statutes. FurtheDOOre, as defined by case law, hazardous
substances noDnally found in refined petroleum fractions are excluded fran
CER:IA response actions. Hazardous substances found at levels which exceed
those nonnally found. in such petroleum fractions, as well as substances not
normally found in petroleum products, are not excluded fran CERC[A response
actions.
With respect to sane of the elevated concentrations of metals in unfiltered am
excessively turbid groundwater sanples, Section 104(a) (3) (A) of CER:IA does not
allow for a response activity where there is a "release or threat of release of
a naturally occurring substance in its unaltered fo:cn, or altered solely
through naturally occurring processes or phenaIEna, fran a location where it is
naturally found."
'Ibe:refore, because of the lack of jurisdiction to .address petroleum-related
con~tamination and natural substances under CERCIA, no further action will be
taJo:m under the Superfund Prog,Lcub to address the North U Drive well
Contamination site. Additionally, an assesSIlElt of site risks deteDnined that,
even if authority existed, no action would be required based on an absence of
significant potential human health am environmental risk.
14
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RESPONSIVENESS SUMMARY
Record of Decision for the
North U Drive Well Contamination Site
This Responsiveness Sunmary presents the responses of the Missouri
Department of Natural Resources (MDNR) and the Envirorunental Protection Agency
(EPA) to public caments received regarding the Superfund Proposed Plan at the
North U Drive Superfund site near Springfield, Missouri. This document
addresses all ccmnents received by MDNR and EPA during the public carmant
period conducted as part of the remedy selection process.
A Remedial Investigation (RI) was conducted at the site by MONR. A Risk
Assessnent was conducted as part of the RI by the Missouri Department of Health
(M[X)H) . A Proposed Plan was developed by MDNR and EPA, which reccmtlIDded that
no .further action be perfoDtEd at the site using CERCIA authority. The RI a.rx1
Proposed Plan were released for public review and carment for a 30-day pericxi
which began on February 24, 1993 with a public notice in the Sprinqfield News
Leader. A public meeting was held in Springfield at the Northview MultiplrpOSe
Center on March 9, 1993 at 7 p.m. A few caments were received by MDNR and EPA
during that public meeting. Also, a few carments were received by letter anj
telephone following the public meeting.
The following are the substantive public ccmnents, and MDNR and EPA' s
response to the RI and the Proposed Plan:
Carment: A carmenter asked if MDNR and EPA have given up hope for finding the
source of contamination in the North U Drive neighborhood.
MDNR and EPA Response: Nine potential sow:ces were initially identified in the
RI. Many of these weJ:e roled out in the review of the RI data, which included
dye trace studies, geophysical investigation techniques, and the collection and
analysis of soil, soil gas, and groundwater sanples. A full discussion of all
of the potential contaminant sources is beyorxi the scope of a Responsiveness
SUrrmary, and readers are referred to the RI Report which does provide this
discussion.
In sunma.ry though, the t-Um and EPA have concluded that the MontgareI:y Metal
Craft (Me) facility is probably a source of the oxgarUc contaminants in the
growldwater. 'Ibis is based upon soil sanples taken fran the MM: facility which
contain sane of the sane contaminants found in groundwater beneath the site,
the site hydrogeology, the direction of groundwater flow, the roovement history
of the groundwater plume, and upon the nature of operations and materials
handled at the MM: facility and other facilities at or near the site.
1
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Of the nine source areas originally identified at the beginning of the RI, one
of the rrore likely was thought to be the former Curtis Service Station. Many
of the early citizen ccmplaints with respect to contaminated well water
occurred near this facility. In addition, there were visual observations of a
product (probably gasoline or other petrolemn product) layer on top of the
water table in a well located at this facility. However, EPA and MDNR have
concluded that the CUrtis Service Station appears unlikely to have been a
significant source of the groundwater contamination. Specific reasons for this
conclusion are given in the last ccmnent of this Res{X)nsiveness Sumnary.
Cament: '!be sane ccmnenter asked if chemicals sprayed on animals at the
Dickmon Park Zoo, and/or chanicals used in cleaning the zoo grounds, could
have! been the source of contamination. He also asked what chemicals are used
at the zoo, and whether or not a dye trace was Perfonned at the zoo.
MDNR and EPA RespOnse: The Dickerson Park Zoo was not considered a probable
source of contamination because we had no evidence of a contaminant release
fran the zoo, and because the zoo is over 1 mile away fran the site. MDNR and
EPA has no infonnation regarding the use of chemicals, if aIrf, at the subject
zoo; but the regional hydrogeology indicates that it is very unlikely that the
zoo could have been a source of contaminants found at the North U Drive well
contamination site. MDNR' s Division of Geology and Land Survey perfozmed a dye
trac:e near the zoo, as part of an unrelated investigation. Dye was injected
into a losing stream downstream of the zoo, near Pea Ridge Creek. The dye
reappeared in Ritter Spring, which is west of the zoo. This deoonstrates that
arrf contaminants which might originate at the zoo, and be introduced into the
shallOW' aquifer, would not travel to the North U Drive neighborhood but would
travel to Ritter Spring instead.
..
CamEnt: A cc:mnenter asked if the water in the North U Drive neighborhood is
suitable for drinking.
MOOR an::l EPA Response: '!be Risk Assessment conducted by MIXH concluded that
litt:le or no risk is associated with the current co~on of groundwater
beneath the North U Drive site. However, it is reamnended that residents
cont.im1e to use the public drinking water systan rather than private wells.
'!be quality of water fran the public drinking water system is constantly
maint:.ained ani monitoxed and provides a greater assurance that contaminants
will not be ingested. Nonetheless, should a site resident still wish to
coru:nme well water, it is recamerDed that their well (if not in current use)
be thoroughly flushed before being used for drinking. Proper flushing should
remJVe roost neta1-containing sediment.
Ccmtent: '!be sane ccmnenter expressed dismay that EPA plugged roost of the
private drinking water wells in the North U Drive neighborhood. He considers
the wells a loss since the "water is not contaminated."
2
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MDNR and. EPA Resoonse: The plugging of wells was a prodent measure regardless
of the reduction in contaminant levels in the shallow aquifer. First, a
primary reason for plugging wells was to protect the deep aquifer, the priJnaJ:y
water source for Springfield, fran contamination. The original contamination
was, for the roost part, limited to the shallow groundwater aquifer. The
numerous open, uncased wells presented a situation where contaminants could
travel downward fran the shallow to the deep aquifer. Second, because a public
drinking water source was being provided, the wells were considered
wmecessary. Plugging them was the only way to ensure they would no longer be
used, especially by persons unaware of the site history (e.g., new residents).
Carment: A ccmnenter indicated he witnessed a release of gasoline at the old
curtis Service Station (comer of North U Drive and Old Bolivar Road) in 1953
or 1954. The carmenter said a pipe fran an aboveground storage tank released
gasoline for several years. The carmenter said analysis of a water semple fran
the carmenter's well was confiD1e::i to have gasoline in it. The carmenter
expressed concern that Montganery Metal Craft is being wrongly blamed for the
problem.
MOOR and EPA Resoonse: D1ring the RI, several residents said that groundwater
contamination problems have been a recurring problem in the neighborhood since
at least the 1950's. Also, MDNR and. EPA have received similar accounts of past
petroleum releases, roost of which occurred prior to 1960 at the Curtis service
Station. ~ and EPA do not believe these events caused the roost recent
problem, which arose in 1983, for the following reasons: One of the
contaminants detected after the 1983-85 event was Methyl Tertiary Butyl Ether
(Ml'BE) . MlBE is used alIIDst exclusively as an additive in gasoline, rot was
not camerciall v available until 1979. 'lhe CUrtis Service Station closed in
1960. 'lberefore, any MIBE-containing gasoline could not have been released at
the site prior to 1979 am could not be related to the old Curtis service
Station. Since water carplaints were not received until 1983, sane
twenty-three yean; after the curtis service Station closed, the Curtis service
Station is not likely to have been the sow:ce of the groundwater contamination,
given the relatively rapid speed at which groundwater flows at this site.
After the first well becane contaminated in 1983, the problan spread to several
others within a few roonths. This is consistent with a large, discreet release
of petrolemn into a fast"'1lDVing hydrologic system. SUch behavior is SUWOrted
by the dye traces conducted during the RI. '!he dye traces dem:>nstrated that
even a small quantity of "contaminant" (dye) moves extranely quickly at the
site. Dye introduced in the suspected source area travelled over 1/4 mile in
less than three weeks. It is therefore unlikely that a release fran the
service station, which in 1983 had been closed for 23 years, could have caused
such a sudden and large groundwater problan.
3
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