RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
Sites: Minker, Stout, Cashel, Sullins, Quail Run, and Sontag Road (all in
Missouri).
Documents Reviewed:
I have reviewed the following documents which describe and analyze the
cost effectiveness of the remedial alternatives for the referenced sites.
- Study titled: Central Storage Site Report, Feasibility Study,
Missouri Dioxin Sites
- Study titled: Final Repcrt of the Missouri Dioxin Task Force
- Study titled: Draft-Phase I Feasibility Study, Minker/Stout -
Imperial, Missouri
- Study titled: Draft-Initial Remedial Measures, Minker Site -
Imperial, Missouri
- Study titled: Quick Response Engineering Assessment of Removal
Options for Quail Run Mobile Home Park
- Study titled: Quick Response Engineering Assessment of Removal
Options for Sontag Road
- Study titled: Quick Response Engineering Assessment of Removal
Options for Sullins Site
As discussed elsewhere in this document, two sites at which EPA intends
to act - Quail Run and Sontag Road - are not currently listed on the National
Priorities List. EPA therefore will conduct planned removals at these
sites. For planned removals, the National Contingency Plan does not require
an analysis of alternatives as is required for remedial actions. However,
because the actions recommended for Quail Run and Sontag Road are similiar
to those recommended for the other sites, EPA included Quail Run and Sontag
Road in the analysis of alternatives. This record of Decision will only
discuss these two sites separately where the fact that they are not on the
National Priorities List substantively affects the findings required or
actions allowed.
The interim storage facility will be located in Times Beach and will
have a limited capacity to store contaminated soil from only the highest
priority sites. An ongoing Feasibility Study for Times Beach will consider
the disposition of soil from the remaining sites in the State.
Description of Selected Option:
- Construction of an approximately 50,000 cubic yard interim storage
facility at Times Beach, Missouri. The facility will be a concrete
vault with a flexible cover. (Remedial Action),
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- Excavation of the TCDD-contamlnated sot! from the following National
Priorities List sites: Mlnker, Stout, Cashel, and Sul11ns, and
transport to Times Beach for temporary storage 1n the iritclm storage
facility (Remedial Action).
- Excavation of the TCDD-contami nated soil from the fol1ow1nj non-
National Priorities List sites: Quail Run and Sontag Road, and
transport to Times Beach for storage In the Interim storage facility.
(Planned Removal) and
- Necessary actions, within the authorities of the National Contingency
Plan to respond to the contamination of mobile homes at Quail Run
Mobile Home Park.
Declarations;
EPA has consulted the State of Missouri before determining the appro-
priate remedial action, as witnessed by the attached letter from the Director
of the Missouri Department of Natural Resources. Consistent with the
Comprehensive Environmental Response, Compensation, and Liability Act of
1980 (CERCLA) and the National Contingency Plan, 1 declare the following;
- The selected option 1s technically feasible, cost effective and
consistent with final remedial alternatives as presented 1 n the
feasibility study provided for public comment.
- The proposed remedial action at Mlnker, Stout, Cashel, ami Sullins
1s necessary to protect human health and the environment.
- The proposed planned removal actions at Quail Run and Sontag Road
are needed to mitigate the risk of exposure to dloxin by area resi-
dents and the environment. Further, pursuant to section 300.67(c)
of the National Contingency Plan, I find that 1t 1s necessary to
suspend the $1 million celling and 6 month limit for each site due
to the Immediate risk to public health, the immediate need„_for
continued response to mitigate the risk, and the fact that assist-
ance will not otherwise be provided on a timely basis. The actions
are necessary to mitigate direct contact and surface/subsurface
migration threats posed at the sites.
- The action being taken is appropriate when balanced against the
need to use Trust Fund money at other sites.
- 0ff-s1te transport of hazardous substances is more cost-
effective than other forms of remedial action, and, therefore,
consistent with Section 101(24) of CERCLA and section
300.70(c) of the National Contingency Plan.
Assistant Administrator.
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NARRATIVE SUMMARY
BACKGROUND
This summary documents the remedial and removal measures recommended
by Region VII and the State of Missouri for the Minker, Stout, Cashel,
Sullins, Quail Run, and Sontag Road sites. The six sites are residential
sites in St. Louis, Franklin, and Jefferson counties in Missouri. All are
contaminated with 2,3,7,8-tetrachlorodibenzo-p-dioxin (dioxin or TCDD),
and have been recommended as high priority sites by the Missouri Dioxin
Task Force and the Governor of Missouri.
The final report of the Missouri Dioxin Task Force was submitted to
the Governor on October 31, 1983. The Task Force developed recommendations
and priorities based on overall risk to residents, workers and the environ-
ment; exposure risk to residents (especially children) and workers; potential
for erosion and dusting; maintenance of neighborhoods and property values;
and long-term effects on Missouri and its citizens. Sontag Road and Quail
Run were assigned the highest priority with excavation and off-site interim
storage recommended as soon as possible. Minker, Stout, Saddle and Spur
Club, Cashel, Sullins, and Romaine Creek were assigned second priority
where excavation and off-site storage should be considered with short-term
stabilization actions in the interim. The Saddle and Spur Club will be
addressed through enforcement action. As a long-term state-wide solution,
the Task Force recommended secure central storage until proven technology
is available to destroy dioxin in contaminated soil with minimum risk to
public health and the environment.
To date there are 33 sites in Missouri known to be contaminated. The
majority of these sites are not residential sites. The Centers for Disease
Control (CDC) has recently released a report titled: Health_Implication_of
2,3,7,8-tetrachlorodibenzo-P-dioxin_(TCDD) Contamination_of Residential
Soil which concluded "that soil levels of T ppb TCDD in resTdential areas
is a reasonable level at which to express concern about health risks." The
conclusion applies to prolonged exposures and the six residential areas all
have dioxin concentrations greater than 1 ppb.
EPA has taken several actions at these six priority sites, including:
0 Draft Feasibility Study and a Draft Initial Remedial Measures
Report for Minker/Stout.
° Quick Response Engineering Assessment of Removal Options for
-Quail Run; Sontag Road; and Sullins sites.
° Permanent relocation offers for eleven families at the Minker/Stout
site.
° Temporary relocation offers to two Minker neighbors.
c Temporary relocation offers to about 100 residents of the Quail
Run Mobile Home Park.
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° Removal actions at Sontag Road, including application of dust
suppressants, vacuuming along roads and in residences, and paving
where the highest dioxin levels were found.
SITE_DESCRIPTIONS/EXTENTjOFjCONTAMI NAT I ON
a) Minker: South of the Minker house is a gulley where fill material
contaminated with TCDD was placed in an attempt to alleviate an erosion
problem. The Minker residence is located on the top of a ridge with
runoff draining into Romaine Creek. Visual observations indicate that
much of the fill material has eroded down the hill into the yards of
neighboring homes and into Romaine Creek. Four other residences are
located downhill from the Minker house and one other house 1s immedi-
ately adjacent to the Minker residence. Analyses of samples collected
from the Minker fill area, yards of down-gradient homes, and sediments
from Romaine Creek reveal that contamination from TCDD is widespread
over the approximately 3-acre Minker residential area, including approx-
imately 6,000 feet downstream in Romaine Creek.
During sampling, a topsoil depth of only 8 to 12 inches was.observed
in many locations over a jointed limestone and porous sandstone.
Vertical movement of surface water with soil particles from the Minker
site into the limestone is possible and could contaminate the shallow
aquifer above the Bushberg sandstone layer. The shallow ground water
may emerge in the gaining reach of Romaine Creek or its tributaries.
EPA has conducted extensive sampling in the Minker and Romaine Creek
areas. Of approximately 250 samples from the Minker site and adjacent
areas, 54 samples have shown concentrations above 1 ppb. Concentrations
over 300 ppb have been measured in the fill area itself.
Several homes are located across West Rock Creek Road from the Minker
site. Recent sampling revealed concentrations above 1 ppb in the yards
of two of these properties.
b) Stout: Contaminated soil from the Bubbling Springs Ranch was taken to
the Stout site at the same time it was being used as fill at the Minker
site. The fill material was used to make a level lot for two trailer
pads. EPA sampling found contamination throughout the fill from 1 ppb
to 200 ppb, down to a depth of 20 feet.
Runoff from the Stout site is thought to be primarily surface flow,
although subsurface flow has been noted in adjacent areas. The surface
flow is southerly toward Rock Creek. Samples between the fill area and
Rock Creek show that some surface migration is taking place. The site
1s located over a porous sandstone and jointed limestone.
In December 1982, CDC issued a health advisory for the six families at
the Minker site. On March 17, 1983, the CDC extended its findings of
a health risk to include the two trailers and three homes at the Stout
site. On April 7, 1983, C0C again extended its health advisory to
include a seventh household next to the Minker home and a house on
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Romaine Creek. On April 19, 1983, EPA authorized the Federal Emergency
Management Agency (FEMA) to offer permanent relocation to these families
as a result of a careful analysis of the health advisory and cost-
effectiveness of permanent versus temporary relocation. The CDC extended
its health advisory to include two additional families across West Rock
Creek Road and offers of temporary relocation have been made by EPA.
Cashel: The Cashel residence is located 0.3 miles north of the Minker
site on West Romaine Creek Road. When contaminated soil was excavated
from the Bubbling Springs Ranch Arena in 1973, Mr. Cashel flagged down
two departing trucks and thus obtained two loads of dirt, which were
deposited in his garden. Subsequently, nothing would grow in the
garden, and two apple trees died. The dirt was scraped up and deposited
in a pile along the edge of the property.
The property is located on a ridge with neighboring residences located
on both sides. The soil layer is relatively thin, only a few feet
thick, with a moderate to high permeability. Samples were taken near
the surface with one measurement as high as 250.ppb. Other samples
ranged from 10-70 ppb dioxin.
Sullins; The Sullins home is located about one mile west of the Bubbling
Springs Ranch Arena. About 14 cubic yards of contaminated soil from
the arena was used to fill a depression left from the removal of a
large tree. The fill area is about 20 feet from Romaine Creek. There
is one home directly across the street from the Sullins', and a trailer
court adjacent to the creek and downstream of the fill area. Initial
sampling showed contamination levels up to 99 ppb. Subsequent sampling
did not confirm migration of contamination but found levels as high as
820 ppb.
Quail_Run_Mobile_HomeJ3ark: The main road through the mobile home park
was sprayed with contaminated waste oil in the early 1970's. The oil
apparently was highly contaminated, based on the high TCDO levels
found at the site. The site was sampled a second time after screening
sampling revealed fairly widespread contamination. This widespread
contamination was caused when contaminated road materials were excavated
and used as fill material. Also, the contamination has spread as a
result of wind-borne dust and storm water transport. The mobile home
park covers approximately 27 acres and consists of 38 trailer pads and
currently 28 mobile homes. The entrance to the park is at the top of
a ridge and the site slopes toward Little Fox Creek. Of 315 samples
collected, 136 had dioxin levels greater than 1 ppb, with the highest
concentration at 1,100 ppb. In addition to Quail Run Road, residential
yards, and the fill area, concentrations greater than 1 ppb have been
measured in Little Fox Creek, dust samples from 18 mobile homes, areas
south of the park entrance, and the shoulder of Highway 100 opposite
the park entrance.
About 100 residents of the park were offered temporary relocation in
May 1983 as part of an immediate removal action. The site has been
proposed for addition to the National Priorities List (NPL). However,
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addition to the NPL is dependent on a change in the National Contingency
Plan.
f) Sontag_Road: Sontag Road is in the Castlewood subdivision located in
St. louis County. In the early 1970's, Bliss Oil Go. sprayed dioxin
contaminated waste oil on the two entrance driveways to the Castlewood
Swim Club as well as on Sontag Road for a distance approximately 2,000
feet west from New Ballwin Road. Since that time, the road has been
paved and the swim club has been closed.
The Sontag Road site consists of Sontag Road, shoulders along New
Ballwin Road, a large number of residences, the abandoned swim club, a
tavern, and a fire station. The site is in the Spring Branch Creek
Valley. The affected population within a 2,000-foot radius of the swim
club is about 700. The area is located just upstream of the confluence
of Spring Branch and Keifer Creek and about one mile from the Meramec
River. Sontag Road lies in the floodplain of the Spring Branch Creek.
Soil in the area is a silty clay underlain by a gravelly silty clay
with some sand. Surface soils are characterized as having moderately
high permeability, and thus present severe limitations for constructing
dikes, levees, and embankments due to seepage and ease of erosion.
EPA has initiated some temporary removal actions consisting of the
application of dust suppressant to road shoulders and gravel driveways,
using high-efficiency vacuum cleaners to clean up loose particles
around roads and residences, and paving where the highest TCDD levels
were found.
The Centers for Disease Control and the Missouri Division of Health
have issued health advisories for the six priority sites under consideration.
In general, these advisories cite the potential for adverse health effects
due to long-term exposure to contaminated soil under existing conditions
at these sites.
A no-action alterative is unacceptable due to the provisions of the
health advisories. A second alternative consists of relocation of the
residents who are directly affected by the health advisories. Permanent
relocation is currently underway for eleven families at the Minker site.
Permanent relocation offers have also been made to residents of Times
Beach and temporary relocation offers to Quail Run residents. Experience
shows that these voluntary relocations have not been completely successful
in removing all people from the contamination. Under the Comprehensive
Environmental Response Compensation, and Liability Act of 1980 (CERCLA),
permanent relocation can only be offered to residents at a site on the
National Priorities List. Thus, residents of Quail Run and Sontag Road
cannot receive permanent relocation offers. In addition, the six sites
under consideration are in residential areas and require measures to keep
neighboring residents from accidential exposure. The potential for surface
and subsurface migration of the contamination exists in various degrees at
the different sites. This problem is the most severe at the Minker site,
while evidence of surface spreading has been observed at Stout, Cashel,
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Quail Run, and Sontag Road. Therefore, unacceptable high public health and
environmental risks require consideration of response alternatives beyond
relocation of people from the sites.
FEAS IB I LITY_STUDY_ALTERNAT IVES
Remedial investigations at the six sites have been carried out over the
last 10 months. A Feasibility Study addressing all six sites and titled
"Central Storage Site Report, Feasibility Study, Missouri Dioxin Sites,"
was completed December 6, 1983. In that study, seven remedial alternatives,
including a no-action alternative, were considered. In accordance with the
National Contingency Plan, each alternative was examined according to three
criteria: (1) Engineering, (2) Health and Environment, and (3) Economics.
The no action alternative was determined to be unacceptable because it
would not adequately protect public health and the environment.
The other six alternatives considered in the Feasibility Study were:
The costs for the two on-site alternatives (A) and (B) include permanent
relocation for residents on the sites. Costs for the previous buy outs at
Minker and Stout are not included since these are costs that would apply
to any future actions. Costs for temporary relocations during excavation
are included for the off-site alternatives (C), (D), (E), and (F).
Treatment alternatives (D) and (E) have the advantage of reducing dioxin
levels and thus reducing the need for long-term monitoring and surveillance.
However, these alternatives require greater soil handling than containment
options and may present a greater exposure risk to workers. Solvent extrac-
tion would involve high risks associated with so 1ubi1ized dioxin. The
treatment technologies have not been demonstrated to be practical at this
time for contaminated soils. There are uncertainties as to whether the ash
or soil remaining after treatment could be delisted under RCRA. If the
soils are not delisted, they will still require disposal in a secure storage
facility or landfill, though these costs are not included in the estimates.
Costs for the treatment alternatives are considerably higher than those
for containment.
Containment alternatives (A) through (C) are technically feasible at
the present time. Alternatives (A) and (B) are on-site measures.' During
September 1983, a public meeting was held on proposed interim on-site
storage option at the Minker site. The comments from this meeting, and
also comments received for on-site interim storage proposals at Quail Run
and Sontag Road, indicated public opposition to on-site measures and support
for excavation and restoration of the sites. Further discussion of alter-
natives (A) and (B) is contained in the Off-site Disposal Analysis which
follows.
D - Incineration
E - Solvent Extraction
F - Interim Storage Off-site
A - Stabilize Soil In Place
B - Interim Storage On-site
C - Disposal Off-site
$41.5 M
$35.0 M
$32,2 M
$111.6 M
$151.6 M
$15.7 M
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Alternative (C), Disposal Off-site, assumes the availability of a
secure landfill. At the present time, there are no permitted hazardous
waste facilities in Missouri for the disposal of 50,000 cubic yards of
contaminated soi 1.
Based on the three criteria of the National Contingency Plan, Interim
Storage Off-site is the best alternative. It is technically feasible, it
is the least costly and most cost-effective approach, and it can be imple-
mented in such a way that protection of the environment will be ensured.
Although the facility will be conservatively designed to provide long-term
secure storage, the intent of this option includes an accelerated technology
evaluation phase directed toward a permanent disposition of the contaminated
soil and closure of the facility. Implementation of the alternative will
involve five steps:
- Construction of an approximately 50,000 cubic yard temporary storage
facility at Times Beach, Missouri.
- Temporary relocation of people living at or near the six sites.
- Excavation of the contaminated soil and transportation to the
storage facility.
- Restoration and re-inhabitation of the sites.
- Covering the storage facility with a flexible cover.
RELATI ON T0 0THER ST UDIE S
The Office of Technology Assessment (OTA) prepared a staff memorandum
in December 1983 reviewing the recommendations of the Missouri Dioxin Task
Force. The OTA report agrees with the Task Force's finding that feasible
technologies for the treatment of dioxin contaminated soils are not yet
fully proven. However, OTA asserts that additional technology evaluation
should be sponsored for at least one year before endorsing a long-term
strategy for storage of contaminated soil as an interim step until treatment
technologies can be successfully demonstrated. The OTA report suggests that
the State of Missouri and EPA consider the option of embarking on a high
priority program to further examine and evaluate technological options for
proceding directly toward a permanent solution to the contaminated soil
problem. The report also suggests, in the interim, that necessary emergency
actions at sites which pose a health or environmental threat could be
pursued, and perhaps the first stage storage option could be constructed.
The Agency's Dioxin Strategy document dated November 28, 1983, states
that the alternatives which appear to be most suitable for uncontrolled
sites are as follows:
1. Secure soil in place -- in situ soil fixation, subsurface perimeter
grout curtain, impermeable cap, diversion of surface runoff, resident
relocation from immediate area and monitoring.
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2. Consolidate and secure soil -- removal of soil to secure landfill; or *
containment of soi1 in a concrete vault, possibly on-site.
3. Incineration -- following excavation and transportation, a size reduc-
tion process is required before incineration.
4. Solvent Extraction — solvents would be used to extract dioxin from
the soil into a soluble form. Several different technologies could
then be used to destroy the dioxin.
The Dioxin Strategy report also states that several important questions
need to be addressed through pilot studies before these alternatives can be
fully evaluated. As a first step, ORD will consider including an absorption/
desorption study on contaminated soils as part of its research agenda to
determine dioxin release rates. While the treatment technologies (3) and
(4) may present the ultimate solution to contaminated media, they could
present significant health risks during processing. Thus, during the pilot
testing phase, the potential for further contamination must be assessed.
Based upon the success of the pilot testing phase, 0R0 will then be able
to implement the full field validation studies. The results of pilot test-
ing and full field validation will be used to evaluate alternatives for
clean-up given specific conditions of contamination and exposure.
The current remedial proposal is consistent with both the Agency
strategy and the OTA report. The proposed interim storage facility is
limited to approximately 50,000 cubic yards where the volume of contaminated
soil in the entire State has been estimated to be about 500,000 cubic yards.
This initial remedial project is focused on solving the short term health
problems at six sites and includes provisions to facilitate research on
the permanent destruction of the contaminated soils. Several sealed bins
of soil will be stored separately from the facility to provide small quan-
tities of soil for bench-scale studies and larger quantities for pilot
scale demonstrations, Additionally, to the extent possible, soils will be
segregated within the facility according to characteristics relevant to
future treatment.
The large volume of soil remaining at uncontrolled sites after exca-
vation of the priority sites will be addressed as part of a second phase
effort. At this time other studies are underway (Times Beach and El 1isville)
which will address the longer term solutions for other dioxin sites in the
State of Missouri. These studies will carefully evaluate the recommendations
contained in the OTA report and develop alternatives that are consistent
with with the Agency's Dioxin Strategy, the Missouri Dioxin Task Force
report and, to the extent possible, the OTA report. During the interim,
immediate on-site measures will be taken as needed at the confirmed sites
Including the horse arenas and related sites under enforcement action. The
on-site measures will focus on erosion control through surface water diver-
sion methods, porous cover materials, or in-place fixation.
POUCYJSSUES
Three issues are important to the AA in selecting the remedial alter-
native for the six sites.
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1. The storage facility is to be constructed in a f1oodplain. Several
comments received during the public comment period concerned this fact and
these comments are addressed in the Responsiveness Summary. The Feasibility
Study included an analysis of alternative sites for the facility. Twelve
locations were selected by EPA and the Missouri Department of Natural
Resources as potential sites for a central storage facility. This list of
12 sites was numerically evaluated against 8 criteria to develop a ranking.
The criteria related to site ownership, location in an area already contam-
inated with dioxin, proximity to the six priority sites, access considera-
tions, site isolation, environmental risk, land use, and compatibility with
the accelerated schedule. After assigning a score to each criteria, Times
Beach was determined to be the most desirable location with a point total
of 35, followed by Fort Crowder with 29, and 4 other sites with 24. One
advanatage of Times Beach is-its central location to the six priority sites,
while Fort Crowder is located about 275 miles away. Other advantages of
Times Beach include the fact that it is already contaminated with dioxin
{this 1s true for only two other sites considered) and thus will not result
in contaminating a clean area; it has good access; and the facility will
result in minimum land use impact. Also, the imminent State ownership of
Times Beach is extremely important with respect to the schedule for expe-
dited construction of the storage facility which is necessary to allow for
the excavation and restoration of some priority sites in the 1984 construc-
tion season. Under section 104(c)(3) of CERCLA, the State must assure the
availability of an acceptable hazardous waste disposal and the State of
Missouri has officially designated Times Beach as the site. In addition,
the Missouri Dioxin Task Force recommended that the search for a site be
limited to State-owned land to expedite construction of the facility.
Therefore, despite its location in the floodplain, Times Beach is uniquely
qualified, is the most feasible site, and is probably the only site at which
an interim storage facility can be constructed by next summer.
Executive Order 11988 and Appendix A of 40 CFR Part 6 provide guidance
for EPA activities carried out in a floodplain. In general, EPA should:
- Determine whether or not the proposed action is located in or will
likely affect a floodplain.
- Provide early public notice of the proposed action.
- If there is no practicable alternative to locating in or affecting
a floodplain, act to minimize potential harm to the floodplain.
- Prepare a Statement of Findings.
- Allow at least fifteen working days for public and interagency
review of the Statement of Findings.
- In those cases where an Environmental Assessment or an Environmental
Impact Statement is not prepared, prepare a Floodplain Assessment.
- Provide for public review of the Floodplain Assessment.
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- Construct any facilities in accordance with the National Flood
Insurance Program except to the extent that the NFIP standards are
demonstrated to be inappropriate.
- Undertake floodproofing and other flood protection measures for
newly constructed structures and facilities.
The analysis of alternative sites in the Feasibility Study adopted in
this decision, determined that there is no feasible alternative to locating
in the floodplain. A computer-aided hydraulics analysis by the US Army
Corps of Engineers has indicated that a storage facility can be located in
Times Beach without causing any significant impacts on flood heights. The
maximum impact of a storage facility would not exceed a 0.15 foot increase
in flood heights. Flood heights in the neighboring town of Eureka will not
be affected. A Statement of Findings is included as an attachment to this
document, and will be distributed through the appropriate clearinghouse
for public review.
Publication of the Feasibility Study, the public meeting December 13,
and the public comment period have served to provide early notice of the
proposed action. A Floodplain Assessment will be prepared to further
analyze flood impacts, design considerations (including floodproofing and
other protective measures), and actions to minimize any potential harm to
the floodplain. The assessment will discuss National1 Flood Insurance
Program requirements and compliance of the proposed facility. The assess-
ment will undergo public review prior to the start of construction.
2. If TCDD were a listed hazardous waste under the Resource Conserva-
tion and Recovery Act, a RCRA permit would be required for constructing and
utilizing a storage facility for that substance. However, TCDD is not
expected to be a RCRA waste until the summer of 1984, and this listing will
not become effective until six months later. In order to provide the public
with an opportunity to comment on the facility similar to the opportunities
that would occur if a RCRA permit were necessary,, a complete application
for a RCRA permit will be prepared and will be made available for public
comment. A public meeting will be held to discuss the application in con-
junction with a public hearing required under state regulations to address
the State's application for a state hazardous waste permit. The facility
will be designed according to RCRA regulations such t
permittable under existing RCRA regulations.
iat it would be fully
3. The cost estimates listed earlier are EPA's J>est approximations,
but are subject to error for the same reasons that any such estimates are.
The primary uncertainty is the actual volume of soil that must be excavated
from the sites. Previous sampling has indicated thatjdioxin contamination
exists at depths of up to five feet. However, the low water solubility and
strong soil binding properties of TCDD indicate that jt is unlikely that
TCDD could easily move that far into the soil. Recent unpublished results
from a study of soil sampling techniques by the Region VII Environmental
Services Division indicate that the previous results showing that TCDD
exists at depths below two feet may be in error, and that the errors might
have been caused by the sampling techniques used in the past. Because of
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the uncertainties that currently exist, it is not possible to predict
accurately the depth to which the contaminated soil will have to be excavated
at the six sites. The soil volume estimates used in preparing the cost
estimates assumed dioxin may exist at depths up to five f^et.
Lower soil volume will decrease the costs for alternatives involving
excavation and soil handling (B through F) while having little effect on
the inplace stabilization option since the extent of contamination will
not be affected. Therefore, this factor will not affect the results of
the cost effectiveness analysis. The volume estimates and other technical
questions will be subjects of continuing examination over the next several
months by a team of EPA, state, and contractor representatives who will
comprise an Extent of Remedy Work Group. This group will establish proce-
dures for temporary relocations addressing important public health questions
such as who should be relocated and for how long. A transportation plan
which is technically sound and acceptable to the public will be developed.
•The goal will be to minimize the potential of exposure through attention
to handling, transport, and routing alternatives.
Additional issues that will be resolved by the Extent of Remedy Group
include dust suppression assurance of contaminant removal, procedures for
cleaning houses, and others. In order to ensure effective communication
with the public, public affairs personnel from EPA, the State and the
REM/FIT contractor are members of the Extent of Remedy Group. Also, the
Community Relations Plan will define in detail the procedures to be followed
in disseminating information and addressing comment on these issues of
interest to residents near the sites and near transportation routes.
OFF-SITEJD ISPOSAL_ANALYSIS
At the public meeting on December 13, 1983, residents from Quail Run
and Sontag Road asked EPA to give additional consideration to in-place
stabilization of contaminated soil and permanent relocation of site residents.
This alternative was addressed in the Feasibility Study and estimated to
cost $41.5 million. An impervious cover was assumed with surface water
diversion and a double grout curtain around the Minker and Stout sites.
Residents on all six sites would receive permanent relocation and homes
would be demolished and buried. A long term monitoring program was assumed
at each site for 30 years.
Some cost savings could be realized for the stabilization alternative
by utilizing a porous cover instead of the impervious cover. This would
be most appropriate for the steep wooded slopes at the Minker site where a
porous cover would enable the trees to survive so their root structure
could continue to stabilize the hillside. However, an impervious cover is
preferable for most areas because it eliminates the potential for migration
associated with water percolation through the soil and it provides greater
assurance that contamination will not reach the surface. Porous covers
would require a greater monitoring effort and no substantial net cost
savings would result. The grout curtain at the Minker and Stout sites
would cost $15 million and it is possible that limestone fractures under
these sites could transmit contaminated soil. Additional testing would be
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necessary to assess the need for the curtain walls. However, even if they
were eliminated, the inplace stabi1ization alternative would cost $26.5
million compared to $15.8 million for the proposed interim off-site storage
option. The stabilization option Includes 30 years of monitoring at each
of the six sites. The cost for a similar monitoring program was not Included
for the interim storage alternative. However, this cost would be about
$0.5 million and would not affect the results of the cost-effectiveness
analysts.
An advantage of the proposed alternative is that the soil will be
excavated and centralized in one place for easy access should a treatment
alternative become available. A.lso, the impervious soil cover which would
be part of the inplace option would add considerably to the volume of con-
taminated material which would eventually have to be excavated and treated.
The proposed alternative, on the other hand, is consistent with the possi-
bility of the eventual destruction of dioxin once a feasible technology is
available. Most of the cost is attributable to soil excavation, transport-
ation, restoration, and temporary relocation of adjoining residents, all
of which would be necessary should treatment measures'be selected In the
future. 1
A second "on-site" alternative which would include permanent relocation
was also addressed in the Feasibility Study and consists of excavation and
containment 1n Individual storage facilities. To achieve economies of
scale, soil from the Stout, Cashel, and SulUns sites Iwould be hauled to
the Minker site. A monoflll storage facility was previously proposed for
the Minker site but it met with considerable public opposition. The cost
for on-site storage facilities is estimated as $35 million. Thus, the
proposed off-site alternative is more cost-effective than either of the
on-site alternatives, inplace stabilization or Individual storage facilities.
Finally, permanent relocation of Quail Run and Sontag Road residents Is
not currently within EPA's authority, since those sites are not on the
National Priorities List.
i
COMMUNITY_I NVOLVEMENT 1
The Feasibility Study was distributed to the public December 7, 1983,
and a public meeting to present and accept comments on the recommended
alternative was held December 13, 1983. Additional comments were accepted
in writing until December 27, 1983. A Responsiveness Summary detailing,
and addressing the comments has been prepared and is attached as an appendix
to the Record of Decision. The major comments and brief responses are:
° Several people reiterated earlier requests for a buy out rather than
remedial actions.
A buy out would adequately protect the health of the persons permanently
relocated. However, due to the potential for further migratlon of the
contamination, a buy out would not protect the health Jof other persons, nor
would it adequately protect the environment. EPA would still have to
clean up the sites. Thus, a buyout would be an additional expense, rather
than an alternative to the proposed actions. Moreover, a buy out is not
presently an option for the planned removals at Quail Run and Sontag Road.
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0 Several people, particularly residents of Eureka, wanted commitments
that the facility would not be used for other types of wastes and that
the facility would not be permanent.
EPA will commit to not using the facility for wastes other than those
from dioxin sites in Missouri. The facility will be temporary until a
means to destroy the dioxin is developed. EPA is developing a research
program to study means for destroying the dioxin, as part of the National
Dioxin Strategy.
° There were several comments that the facility should not be built in a
floodplain; that it would not be safe and that it would not be consistent
with government policy.
The safety of the facility will be assured by proper engineering and
detailed analysis of flood height impacts. Building the facility in a
floodplain is consistent with government policy under certain conditions
that are being met.
° There were several comments about the need for special precautions in
transporting the soil to Times Beach.
EPA is very much aware of the need for special measures. Applications
of standard methods will adequately address this problem and we have estab-
lished a process to work out transportation methods in concert with the
public.
° There were some requests, including one from the State Senate, that EPA
consider every avai1 able option rather than locating in a floodplain.
The Feasibility Study included a site-by-site analysis of every alter-
native site that could be identified. For reasons stated in the Feasiblity
Study, Times Beach was selected as the best site for the facility.
A Community Relations Plan is being prepared. Community relations
will be more complex for this response activity than for most because of
the number of sites involved, the residential nature of the sites, the
construction of a storage facility in a floodplain, the need to transport
the soil through adjoining residential areas, and the amount of information
that will have to be communicated to the public. The Community Relations
Plan and the activities it guides will be designed to address each of
these special public concerns.
ENFORCEMENT
The Department of Justice is about to file a lawsuit on behalf of EPA
for remedial actions at six sites in Missouri, none of wfrich is addressed
by this Record of Decision. However, current negotiations with one of the
probable responsible parties are aimed at seeking a solution to the total
Missouri dioxin problem. The results from these negotiations should be
known soon. The only enforcement action taken at the six sites addressed
by this Record of Decision were notice letters sent to potentially respon-
sible parties at Minker, Stout, and Sontag Road.
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Page 13
RECOMMENDED_ACTION
Section 300.68(j) of the National Contingency Plan [47 FR 31180,
July 16, 1983] states that the appropriate remedial action shall be deter-
mined by the lead agency's selection of the alternative which the agency
determines the most cost-effective (i.e., the lowest cost alternative that
is technologically feasible and reliable) and which effectively mitigates
and minimizes damage to and provides adequate protection of public health,
welfare, and the environment. Section 300.67(a)(2) of the NCP provides for
undertaking a planned removal when the lead agency determines that the
public and/or environment will be at risk from exposure to hazardous sub-
stances if response is delayed at a release not on the National Priorities
List. Based on our evaluation of the cost-effectiveness of the proposed
alternatives, the public and environmental risk from exposure to the dioxin
contaminated soil, (noting the CDC health advisories) and the comments
received from the public, we recommend the interim offsite storage alterna-
tive. This project entails construction of a 50,000 cubic yard interim
storage facility at Times Beach. The floodplain assessment, permit appli-
cations, design, bid packages, and construction management will be the
responsibility of CH2M Hill. The facility will be a concrete tank with a
flexible cover which is protected from flooding. Six sites will be restored
with the contaminated soil hauled to and stored in the Interim storage
facility. The work at each site includes excavation, temporary relocation,
and all necessary restoration leading to reinhabitation, Minker (including
the neighbors), Stout, Sullins, and Cashel will be addressed as remedial
projects and CH2M Hill will be responsible for subcontracting and construc-
tion management.
Sontag Road and Quail Run will be addressed as planned removals with
construction management by CH2M Hill or by the ERCS contractor. At Quail
Run, the proposed project includes necessary actions, within the authority
of the National Contingency Plan, to respond to the contamination of the
mobile homes. Before beginning construction, a State Superfund Contract
(SSC) will be negotiated with the State for the response actions. A draft
SSC has been prepared and sent to the State.
The proposed project also includes constrution of spur levees at Times
Beach to minimize and control erosion and transport of contaminated soil
particles already at the site in the event that flooding occurs before
response actions can be completed. The levees are independent of the interim
storage facility for the six sites and will be designed and constructed by
the U.S. Army Corps of Engineers.
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Page 14
Following is a summary of the projected costs:
Studies, design, investigations,
bid packages
Site preparation and storage
facility construction.
Minker, Stout, Sullins,
Cashel remedial actions
* with 25% contingency
Quail Run and Sontag Road
removal actions
Filling Storage tank and O&M
Spur levees
TOTAL
Cost *
(x $1000)
995
2,294
4,069
Cost *
(x $1000)
7,588
438
350
Si 5,734
* with 25% contingency
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Page 15
OTHERJDOCUMENT S
The following documents are attached.
1. Transmittal letter from the Region VII Administrator recommending the
selected option.
2. Letter from Fred Lafser, Director, Missouri Department of Natural
Resources giving the three necessary assurances and requesting the
planned removals at Sontag Road and quail Run.
3. Central_Storage Site_Report,_Feasibility^Studyt__Missouri_Dioxin__Sites.
December 6, 19ST.
4. Responsiveness Summary.
5. Fi n a 1_R epo rt_of_t he_Mi s sou r i_D i o x i n_Task_Force.
6. Draft_Phase_I_Feasibility_Study,_Minker/Stout_Imperial ,_Missouri.
7. Draft_Ini ti al_Remedi alJ"teasure,_Minker_Site,_Imperial ,_Mi ssouri.
8." Quick_ResporiseJEngineering_As$essment_ofJ*emovalJDptions_forJ3uan_Run,
9. Quick__Response_Engineering_Assessment_of_Removal__Options__for_Sontag
Road. "" .
10. Quick_Response_Engineering_Assessnent_of_Removal_Options_for_the_Sullins
Site.
11. Report on_Advance_Preparation/Emergency_Response (USACE "Spur Levee
Report"""}, November 1983.
i
12. Times__Beach Advance_Preparation/Emergency Response_Report_Review
(CH2M Hi 11)7 December 12, 1983.
13. Statement of Findings (a special decision document required by 40 CFR
6 Appendix A relevant to E.O. 11988). j
14. Missouri Clearinghouse Review on Interim Centra] Storage Facility
(Letter coming - TCR included).
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RESPONSIVENESS SUMMARY January 1984-Final
Interim Central Storage Facility
This document summarizes the comments received during the public meeting on
December 13, 1983, in Fenton, Missouri, and the written comments received
in the Office of Public Affairs, Environmental Protection Agency (EPA)
Region VII, Kansas City, Missouri, in response to the presentation of the
report titled, "Central Storage Site Report, Feasibility Study, Missouri
Dioxin Sites" prepared by CH2M Hill, This responsiveness summary has been
prepared as a part of the Record of Decision package that is required in
order to obligate Superfund money for remedial actions.
The comments are grouped into several categories, according to the topic
that they address. The topics include questions about hoy/ the project will
proceed, questions about the safety of the facility or the design of the
facility, other solutions proposed Instead of the central storage site
proposal, reasons to oppose the proposal, and assurances requested from the
government. _ ,
ASSURANCES REQUESTED
° Three comments were received which requested assurances from the federal
and/or state government that high priority would.be given to continued
research to find a means to destroy the dioxin.
Verbal assurances to this effect were given during the public meeting. EPA
already has committed to a research project under the auspices of the
National- Dioxin Strategy, which was announced on December 15, 1983, There
are other dioxin sites in the nation besides in Missouri. It will be "
desirable to develop a means to destroy dioxin in the soil which is both
economical and workable in order to enable the Agency to address these
other dioxin sites as well. EPA is committed to this goal.
' 1
° Four comments were received which requested federal and/or state assurances
that no wastes other than dioxin-contaminated wastes from dioxin sites will
be brought to Times Beach. The concern was that once the facility for
dioxin wastes is established "there, Times Beach will be viewed as an opportune
site for locating other waste facilities.
Assurances were given at the public meeting that EPAjdoes not view Times
Beach as a desirable site for waste facilities, other than for a temporary
facility for storing dioxin-contaminated wastes. i
° Six comments were received which addressed the length of time the
dioxin will remain in temporary storage. . ¦ j .
EPA views this as a temporary facility and the storage of the soil to be
temporary. The reason for. storing the soil is to enable EPA and the State
to remove it from inhabited areas and to eliminate the possibility of
continuing human exposure to the wastes. No practicable and affordable
method is currently available to destroy dioxin in soil. Until a means is
available to destroy the dioxin, the soil, will have to be stored.
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COMMENTS REGARDING THE SAFETY OF THE FACILITY
° Two comments were received which expressed concern that the long-term
Integrity of the facility could not be assured, and that the facility might
eventually fail.
The facility will begin as a concrete box, which wil 1 be filled with soil.
However, when finally completed, no part of the concrete box will be visible
nor will it be subject to failure by collapse of its concrete walls because
clean soil will be placed against the outside of the walls. The facility
will resemble a mound of dirt. The grass on top of the facility will be
maintained on a continuing basis.
The facility is being designed to withstand flooding, which is to be expected
within Times Beach. The existing embankments around Times Beach and the
proposed addition of some small levees to divert flows away from the facility,
will cause the velocities of floodwaters flowing around the facility to be
very low, even during the 100-year or larger flood. Thus, the facility
will not be subject to erosion or to failure by collapsing.
• One comment was received which stated that there is at least one water
supply intake downstream of Times Beach. The commentor went on to suggest
that the operation plans for the facility should include procedures for
notifying the operators of any downstream water supplies of "impending
contamination".
The operations manuals for the facility will include procedures for notifying
not only downstream water supplies of operations at the facility, but in
addition, will include procedures for notifying public safety personnel and
any other persons who might need to be kept aware,of the operation of the
facility. | .
° One comment was received in writing and one was made during the public
meeting which indicated that construction of the facility to the 100 year
flood stage would be insufficient and that the facility should instead be
constructed to a higher flood level.' j
; . I
The facility will be constructed so that the concrete walls, which will be
responsible for containing the dioxin during the time the facility is being
filled, will be built to a minimum of the 500-year flood level at the
location at which:the facility is built. , S
' : ' ' '
COMMENTS REGARDING THE CLEAN-UP PLANS :F0R THE SITES
i i • : |
* Four comments were received which addressed concerns about transportation
of the soil to Times Beach. One of the commentors requested that the public
be kept well informed and be involved in the development of the plans for
the transportation of the soils. Two comment's indicated that transportation
of the soil would involve too many risks. These two comments were associated
with other comments which stressed the desirability of leaving the contaminated
soil in place.
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.The transportation of the soils will involve several technical issues
which must be resolved. It should be stressed that the solution to these
problems will involve the use of existing methods. No new methods for
transporting the soil will have to be developed. Proper equipment. Including
sealed trucks and special techniques for loading and decontaminating the
trucks as they leave the sites, all exist and can be used in this project
as they have been in other projects. The Missouri Department of Natural
Resources and EPA will work with both the residents of the sites and other
interested parties in the development of the specific means by which the
soils will be transported, the routes over which the soils will be transported,
the means for decontaminating the trucks, and other technical issues, so as
to assure public confidence in the safety of the transportation methods
finally selected. i
° One comment was received which addressed the generation of dust during
the excavations. j
Standard methods are available for insuring that dust is not generated
during the excavation. These methods generally involve careful wetting of
the soil for some days prior to excavation. These techniques will be
incorporated in the methodology developed for the sites. In addition, EPA
is considering the need for monitoring particulate levels during the clean-ups.
The public will be kept informed of the methodologies developed for dust
suppression and dust monitoring. j
• One comment was received which addressed plans for temporary relocations.
Specifically, would the temporary relocations be sequenced so that not
everyone from a particular site would be temporarily relocated for the
entire time that the excavation was taking place.
The response to this comment at the public meeting was, that in an area as
large as Sontag Road* it should be possible to do a segment at a time.
Thus, the entire community would not be affected at one time. It will be
necessary to ensure that this can be done safely.
° Two comments were received which addressed the Missouri Registry of
Confirmed, Abandoned or Uncontrolled Hazardous Waste Disposal Sites. The
question was, will the properties be sampled as they are cleaned up to
assure that the clean-up is effective?
EPA will sample all! sites as they are cleaned up to ensure that the dioxin-
contaminated soil is removed down to the level required to protect public
health and the environment. Any questions about the registry should be
addressed by the state.
• Two comments were received which questioned what the Agency's options
would'be if the property owners refused to allow access to their property
to remove the contaminated soil. |
I
!
Should this occur, there are two options that would :be available: 1. The
Agency could use its authority for access to enter and perform remedial
actions, as granted under 42 U.S.C.A. §0604, ct. seq. 2. Alternatively,
the Agency could find the property owner to be a responsible party as defined
by law, and issue an Administrative Order nuking it jthe responsibility of
the property owner to clean up the property at his own expense.
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0 One comment was received which noted that in the evacuation at Seveso,
Italy,, a lower standard than 1 ppb was used as the cutoff point for clean-
up. The question was, would the 1 ppb standard, which has been established
by the Centers for Disease Control, be changed in light of this fact?
The current advice of the Centers for Disease Control 1s that 1 ppb is
a maximum level of clean-up that will be required to protect public health.
In situations in which exposure to the soil will be unlikely, it may not
be necessary to remove soil to this level. , '
COMMENTS EXPRESSING REASONS TO OPPOSE THE PROJECT, AS PROPOSED
" ' ' , . I
1 I
0 Six comments were received which expressed concerns about the safety of
building the facility in a floodp'lain. Five of these comments expressed
opposition to building in a floodplain, and one of the comments expressed
a desire that there be a further study of the floodplain impacts.
EPA is required to make a detailed analysis of any and all impacts on a
floodplain caused by carrying out any activity within a floodplain. EPA
has been working with the the U.S. Army Corps of Engineers for four months
studying flood profiles in and around Times Beach. A detailed history of
the flooding of Times Beach has been developed by the Corps. This history
includes peak flow rates and flood profiles for various kinds of- floods.
In addition, detailed topographical maps of Times Beach and parts of Eureka
have been developed. This topographical mapping has allowed the Corps of
Engineers to develop improved understanding of the paths of flow through
and around Times Beach during a flood, and also has allowed the Corps of
Engineers to make detailed and accurate predictions of the effects of any
construction in the Times Beach area. !
Using the information which has recently been developed, the Corps of
Engineers has been examining the probable impacts of'constructing a facility
for storing dioxin-contaminated soil at Times Beach, j After.assessing many
possible locations within the city, the Corps has identified only two
locations where the facility would have significant ^mpacts on flood heights.
EPA will locate the temporary facility in an area acceptable to the Corps
with estimated impacts of no more than 0.15 foot.
There are other natural values of a floodplain which'must be considered by
EPA. At this time it appears that the proposed facility has little potential
for causing other negative impacts. However, EPA will continue to evaluate
this matter^and will jpre'pare a Floodplain: Assessment which addresses
•" possible adverse impacts of the facility.' Any such impacts, if identified,
will bd considered and, when possible*
: i '-M ¦: ' ¦ -| : 'i
° Two comments were received which opposed the project, as proposed,
because it is not a complete solution to all of Missouri's dioxin problems.
One comment specifically noted that clean-up of Times Beach is not included
in the 'plan.
It was not EPA's intention with this proposal to address all of Missouri's
dioxin problems. The full extent of Missouri's dioxijn problems is not
known at this time, nor will it be known with certainty until additional
investigations of potential dioxin sites are completed. Currently, an
\
i
I
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extensive remedial investigation and study of possible alternatives for
addressing the dioxin contamination at Times Reach is underway. Until that
study is complete, the exact quantity of contaminated soil and the feasible
alternatives for addressing the problems at Times Reach will remain unknown.
Other dioxin-contaminated sites will require additional extensive investigations
before clean-ups are possible. The six sites proposed for the temporary
facility, however, have been studied extensively and it is possible at this
time to roughly estimate the amount of soil that will need to be cleaned up
and to make preparations for storing that soil. The 'public interest would
not be served by delaying the clean-up of these sites until all sites are
sufficiently investigated.
° Several comments were received which addressed the visibility and
aesthetics of the facility.
When completed, the facility will have the appearance of an ordinary grass
covered mound of dirt. In addition, the heavy vegetation which exists at
Times Beach, including many medium and large trees, will serve as an effective
screen during the spring and summer and will serve to some extent as a screen
during the winter. The sloped sides and the grass covering of the facility
will project the appearance of an earthen levee. If desirable, additional
trees could be planted around the facility to obscure it even further.
# Four comments were received which questioned the effect of the facility
on property values in Eureka.
As mentioned earlier, estimates from the Corps of Engineers indicate that
the facility will not cause significant adverse impacts on flood heights in
Eureka and the facility will not have an objectionable physical appearance.
0 Two comments were received which addressed the long-term maintenance of
the facility* One comment noted that maintenance would be required for the
lifetime of the facility. The other comment stated that no provisions for
the maintenance of the facility have been made.,
A provision of the Superfund law states that it will be necessary for the
states to accept responsibility for long-term maintenance of any remedial
measures taken at hazardous waste sites. The State of Missouri has committed
by letter to accept responsibility for the maintenance of the facility, A
State Superfund Contract between the State of Missouri and the EP.\ will be
i necessary in order to fund the construction and the clean-ups. The State
! Superfund Contract will include binding commitments by the State of Missouri
? to maintain the facility. [
I . J
° One comment was received which stated that the facility should not be
locate<| in a populated area or in a park land. j
Any area proposed for a hazardous waste facility or other controversial
facility is in general populated by someone. Usually, only public lands
are an exception to this rule. If the facility is not located in either a
populated area or a parkland, there are few additional sites to consider.
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SAFETY IN TIMES BEACH
• Four comments were received which addressed current safety and fire
hazards at Time Beach. Two specific questions were these: who will be
responsible for cleaning up the debris that exists at Times Beach, and who
will pay in the future for fire and medical response protection for the
Times Beach area?
Removing the debris from Times Beach will probably be included as a part of
the remedial actions taken to address the contamination problem tn Times
Beach. That remedial action cannot begin until the Remedial Investigation
and Feasibility Study are completed next summer and agreements are reached
between the State of Missouri and the EPA on the actions to be taken. The
Agency would like to see the current safety and fire hazards addressed as
expeditiously as possible. However, there are legal limitations on what
the agency can and cannot do and the processes that it must adhere to in
reaching a decision to undertake remedial actions at a hazardous waste
site. These limitations will make it difficult for EPA to address safety
Issues at Times Beadh at this time.
In the meantime, the Agency is interested in doing whatever it can to
minimize any safety and fire hazards which exist. To that end, EPA's
contractor has been assigned to review safety and security measures currently
in effect, to assess fire hazards caused by the weeds at Time Beach, and to
examine the possibility of demolishing the structures as they are purchased.
These studies are still underway and will be made public when they are
completed. EPA will continue to work with the State of Missouri to seek
ways to minimize any safety and fire hazards at ¦Times Beach.
BUY-OUT/RELOCATION
° There were several comments addressing the desirability of buying out
and relocating the people at the. six sites rather than trying to solve the
contamination problem at. the sites. Four comments were received which
stated that everyone living at the sites now should be offered temporary
relocation immediately. Three of the comments recommended an immediate
buy-out of the sites rather than remedial actions.
When the decision to buy-out Times Beach was made, there was no storage
site available. Since that time, additional knowledge has been gained about
dioxi n, and site clean-up now appears to be a feasible alternative. EPA
believes that clean-up and restoration can be accomplished and represent the
most cost-effective way to address the numerous dioxin sites in Missouri,
and adequately address public health and environmental concerns.
Buying out or relocating the people from the dioxin sites would not solve
the environmental problems. Buy-out is not an alternative to cleaning up
these sites. Rather, it would be an additional expense beyond the cost of
clean-up. Thus comments that the money allocated for site clean-ups would
be better spent on buy-outs does not address the actual problem.
" There were several comments regarding the Times Beach buy-out. One
commentor recommended that 0*A keep in mind that the buy-out at Times Beach
is intended to be voluntary and that actions taken to build the facility at
Times Beach might compromise the voluntary nature of the buyout. Three
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commentors suggested that the Times Beach buy-out should be accelerated and
one comment was received which stated that the Times Beach buy-out is the
primary limiting factor in the schedule established for construction of the
facility at Times Beach.
The buy-out at Times Beach, after some initial start-up delays, has been
proceeding quite well. Three hundred and forty families, as of this date,
have accepted the initial offers from FEMA. Over 400 offers have been made
on fixed residences at Times Beach, There were only 452 fixed residences
in Times Beach. :
EPA is committed to the voluntary nature of the buy-out. There are still
some families living in Times Beach. It is EPA's hope that the purchase of
these homes can be completed before construction of the facility would begin.
While the progress of the buy-out is an important factor, it does not appear
that it will be necessary to have purchased every piece of property in
Times Beach before the facility can be built.
FUTURE UTILIZATION OF TIMES BEACH
° Four comments were received which suggested specific future uses for the
land at Times Beach. Two commentors suggested that the area should be an
industrial park. Another comment, which EPA had also received previously,
suggested that the area should be developed into a reliever airport. One
comment recommended that the land be used as a federal parkland.
Times Beach will eventually belong to the State of Missouri. The future
use of the land at Times Beach will not be an EPA decision. At this time,
EPA is interested in ensuring that whatever actions are taken in Times
Beach are consistent with potential future uses. This will ensure that the
State has maximum flexibility in deciding the future use of the area. To
this end, for example, EPA has been in communication with the Missouri-St.
Louis Metropolitan Airport Authority to discuss their plans for a reliever ,
airport. Probable alignments for runways in such anjairport have been
discussed in order to enable EPA to assess sites within Times Beach for
locating a storage facility which will not later make it more difficult to
develop the area as an airport. Another example is that EPA has been
investigating the possibility of cleaning up Times Beach in a manner which
preserves the maximum amount of the existing vegetation. If the area is to
be used as a park in the future, it will be valuable!to save as many of the
trees in the city as possible. EPA will continue to;seek to ensure that
actions taken at Times Beach do not preclude any of the possible future
"uses of the area.. ' . . f ,
s • <
COMMUNITY RELATIONS I
: . ¦ -I
0 Two commentors expressed a desire to be included.on any future advisory
board. j
The State of Missouri and EPA are working together to develop extensive
plans for community relations regarding this project. EPA and the state
will seek advice and comments from the public on many aspects of the project.
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° One comment was received which recommended that a list of people involved
in the decision-making process for this project be published.
The large number of persons statewide, regionally, and nationally, who will
be involved in this project precludes the publishing of such a list. The
State of Missouri may be contacted by calling the Missouri Dioxin Hotline,
800/3DIOXIN, or by calling or writing to Ms. Beth Rice, 314/751-3241. If
the public wishes to contact EPA about this project, they may contact the
Regional Office through the dioxin hotline 800/892-5009, through Mr. Stephen
Wurtz 1n the Public Affairs Office, 816/374-5894, or through Mr. Steven Wilhelm
in the Superfund Section, 816/374-6864. Correspondence may be addressed to
either Mr. Wurtz or Mr. Wilhelm at the following address:
EPA, Region VII ! ;
i 324 East 11th Street
s Kansas City, Missouri 64106
OTHER APPROACHES
Many comments were received which offer alternative approaches or specific
processes and/or products to be used in the clean-up.
° Four comments were received which recommended destroying the dioxin in
place rather than moving the soi1 and storing it.
Destruction of the dioxin would be the first choice. It would be more cost-
effective and, if it could be done on-site, the transportation difficulties
inherent in moving the soil to a central storage facility would be avoided.
However, there 1s not currently available a practicable and affordable,
method for large scale destruction of dioxin in.soil.
° Three comments were received which suggested leaving the soil in place
rather than moving 1t. One of these comments suggested buying everyone out
and building retaining walls and covering the dioxin-contaminated soil with
dirt. ; Two other comments merely said leave the dirt1 where it is and buy
everyone out.
As noted earlier, buying people out and removing them from the site does
not solve the contamination problem and would not sufficiently protect
public health or the environment. EPA and the State, of Missouri would
still be responsible for cleaning up the sites. Something must be done
with tfve contaminated soils. At this time, storage of the soils is the
only option. I - : '
° One comment was received which merely said dig tie soil up and "take
It someplace else.",
' 1 ¦ 1 ' '
Experience has shown that "someplace else" is almost;always inhabited or
owned by someone. There simply is no place to take hazardous waste where
there will not be opposition. Recommendations to take the soil someplace
else must be more specific. A suitable site must be'suggested.
° A proposal was made at the public meeting to build a special facility
1n a nearby community to contain the soil. Three comments supported this
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idea. :Six comments were received which opposed building a facility in
Crescent.
Questions were raised about the geology of Crescent. Specifically, state-
ments were made that there may be karst topography, sink holes, and cracked
limestone underneath the site. Some of the people who opposed constructing
the facility in Crescent objected on the basis that Crescent is not now
contaminated, that it is "an historic area," and that it is a scenic area
that should not be burdened with a hazardous waste facility.
p
The major difficulty with the proposal is timing. EPA is seeking to protect
public health and the environment by moving the contaminated soils from the
six high priority sites during the next construction season. This will
require having the facility constructed by early summer. The proposal is
not sufficiently developed at this time in order to make it feasible to
have the facility constructed by next summer.
EPA may later adopt the recommendation of the Governor and the Missouri
Diqxin Task Force to store all the soil, including the soil from Times Beach.
This will be a matter of continuing study. Any proposals received will be
considered in light of the possible need for a larger storage facility at a
later time.
° .One comment was received which recommended not bringing more contaminated
soil to Times. Beach. Rather the commenter prefered th.it EPA clean-up Times
Beach and remove the "stiginj."
EPA agrees it will be desirjble to expedite tlie clean-up at Times Beach as
much as possible. It is not clear at this time whether an off-site storage
or disposal area for the soil at Times Beach can be located. Thus, it may
be necessary to store the Times Beach soil at Times Beach until a destruction
method is developed.
MISCELLANEOUS COMMENTS ¦
° sQne commenter asked how many "bunkers" might be necessary in order to
store all of the dioxin-containinated soil in Missouri.
I • "
The proposed facility would have a 50,000 cubic yard capacity. Thus, if
all the soil in Missouri was to be stored, as suggested by the Missouri
Dioxin Task Force and the Governor, at least two facilities would be required.
It may be more appropriate, from an engineering point of view, to build
several small facilities at a central site rather than one large facility.
? Thi$ will be a matter for further study. 1
¦ ! 1' ' ¦ ;
° Several comments were received suggesting that the pub]ic comment period
was too short, and/or that the project as proposed is not completely thought
out. j ....
As previously stated, the goal is to clean up the six sites during the next
construction season in order to best protect public health and the environment.
This puts very strict time requirements on the EPA and the State of Missouri
to begin the planning, design, and other necessary steps to build the
facility by early summer. The time available for public comment was,
therefore, somewhat abbreviated.
There are several technical mottor^ which will be resolved during the next
several months; ihr'uc"n9 texact design of the facility, plans for the
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excavations at the sites, plans for temporary relocations during the exca-
vations, and plans for transportation of the soil to the central storage
facility. EPA will work in close consultation with the public in resolving
these details. Thus, the close of the public comment period does not
represent the end of opportunities for the public to be involved in this
process.
° One comment questioned whether an Environmental Impact Statement would
be necessary for this project.
EPA's Office of General Counsel has determined that the RCRA permit process
and the Floodplain Assessment process taken together are functionally
equivalent to an Environmental Impact Statement. Thus, a separate EIS will
not be necessary for this project.
° Two comments were received which identified non-uniform treatment of
the various sites as a problem. Buy-outs at some sites versus remedial
actions at others was mentioned as an example. One of the comments recommended
developing a single overall solution, rather than site-specific solutions.
The State of Missouri,has recommended on several occasions that
EPA administratively group all the dioxin sites in Missouri as a single
site, and develop one plan for addressing all of the sites. EPA has responded
by saying that this is not possible under the laws and regulations which
govern the Superfund program.
0 One comment was received which asked about Times Beach residents still
living in Times Beach when the facility is built.
All of the residents at Times Beach have been offered temporary relocation
during the progress of the buy-out. The goal is to complete the purchase
of the homes in Times Beach which are still occupied prior to construction
of the facility. However, EPA does not believe that it will be necessary
for Times Beach to be totally unoccupied in order for construction to
commence, or that the health and safety of these residents will be compromised
by construction of the facility.
9 One comment was received which stated that the costs projected for the
project are "astronomical."
EPA believes that this comment focused on the overall per-yard cost for the
project. The need to temporarily relocate people, the need to transport
contaminated materials in special trucks, the need for for personal protective
devices for, the workers, problems with excessively hot,, cold, or wet weather
and other difficulties contribute to very expensive costs for cleaning up
hazardous waste sites. The average cost nationally for cleaning up a
hazardous waste site at this time is running over $3 million. The project,
as proposed, would clean-up six hazardous waste sites for a total cost of
$1,5.8 million. Thus, the costs are well in line with national averages.
° One comment was received which recommended completing the excavations
and returning residents to their homes before school starts. The commentor
noted that the timeline for the project indicates that the excavations
would not be completed until late fall.
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EPA is sensitive to the family needs in this regard. As the schedules are
developed for the site excavations, EPA will do everything possible to
minimize the disruption to the school year. However, under the present
schedule some people will likely be out of their homes during the beginning
of the school year.
DETAILED COMMENTS AND AN ALTERNATIVE PROPOSAL FROM A PRIVATE COMPANY
General Comments ,
In a meeting at the Region VII Office on December 12, 1983, and at the
public meeting on December 13, a private firm presented a proposal to EPA
that addresses the overall dioxin problem in Missouri. In a written comment
submitted after the public meeting, the company addressed the EPA proposal
and extended earlier explanations of the advantages of their proposal.
The obvious advantages of building a storage facility largely out of dirt are
a strong argument in favor of this approach. Construction of the facility
proposed by EPA out of dirt rather than concrete would likely be cheaper.
However, dirt fill is a difficult material to work with in some types of
weather, and the short schedule available for constructing the small facility
will not allow for substantial weather related delays. Poured concrete,
while slightly more expensive than dirt fill, wi11 allow the facility to be
constucted even if adverse weather is encountered.
However, if EPA decides in the future to adopt the recommendations of the
Missouri Dioxin Task Force and the Governor for a larger facility to store
all of the remainder of the dioxin contaminated soil, it appears that the
size of that facility and the longer time-frame that will be available
for its construction would support the concept of dirt fill construction.
Besides timing, one additional general comment on the proposal can be made.
Review of the documents submitted to EPA indicates that the proposal has, •
not at this time reached a state of development such that it can be effectively
analyzed. A great deal of geologic and engineering'ground work would be
required to demonstrate the feasibility of the proposal. Several months
were required for these investigations at Times Beach, and at least as much
time would be required in Crescent, due to the much more questionble geography.
If the company were to begin the necessary investigations now, and if they
were willing to invest the $300,000 to $500,000 that would likely be required
to develop their proposal to a state such that it could be adequately
interpreted by EPA, it might be possible to have a complete proposal by
September of this year. EPA would not be permitted jto spend Superfund
money 'to develop a private enterprise concept into a workable solution.
Specific Responses ' j
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There are several specific points in the written comments submitted by the company
that should be addressed.
The company stated that the proposed facility cannot be made environmentally
safe. This is not true. It is not the case that such a facility should
never be built in a floodplain. The floodplain causes certain special
problems that must be carefully addressed in designing any structure.
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especially a hazardous waste facility. However, it is not an automatic bar
to construction. EPA is well aware of the floodplain concerns raised and
1s taking steps to address them.
The company stated that the proposal is not cost effective, because construction
on the floodplain will require additional costs for raising the facility
above the floodplain. There will be some differences in the construction
of the facility to accommodate the exigencies inherent in building In the
floodplain. However, these costs are small, especially in comparison to
any costs for acquiring and investigating an alternative site for a facility.
The company stated that the proposed facility would create additional flood-
plain problems for surrounding land owners. This is not true. The facility
can be located in Times Beach without causing any measurable increase in
flood heights in or around Times Beach. The facility will simply be too
small to have the indicated effects. Very little of the flow volume of a
100 year flood actually passes through Times Beach; nearly all of the flow
1s confined to the river channel. Most of the city is a dead-water area,
and thus even a large facility would not be likely to Increase flood
heights because it would not restrict flows.
The company stated that the facility will be aesthetically unattractive.
This point is addressed earlier 1n the Responsiveness Summary.
The company stated that the proposal will "perpetuate a blighted community
in St. Louis County." It is not obvious what the facility proposed by the
State of Missouri and EPA would do to Times Beach that the alternative
proposal would not do to Crescent, which is at the present time not a
"blighted community".
The company stated that the proposed facility eliminates any recoupment
of the costs of the Times Beach buy-out. This not true. As stated earlier
in the Responsiveness Summary, EPA is working to ensure to the extent
possible, that none of the actions undertaken at Times Beach are inconsistent
with any potential future uses of the land. The proposed facility will
cover only approximately four acres of the 413 acres in the city; will be
located off to one side of the dty so as to not restrict future development,
if any; will not be aesthetically unattractive; and, will not be inconsistent
with any potential future uses of Time Beach.
The company stated that the proposed facility destroys ope of the most
valuable uncontaminated portions of Times Beach. The company assumes that
the facility will be located in the area of the mobile home parks. The
location of the facility is not yet decided. While the mobile home parks
are a suitable location in some ways, it Is not at all certain that the
parksjcould be acquired in the time necessary for the completion of this
project. Additionally, It Is not accurate to say that the facility would
"destroy" any part of Times Beach. The facility would occupy part of Times
Beach.
The company makes a valid point when they note that floodplain issues may
have to be addressed again when a method becomes available to destroy the
dioxin. However, while it might be convenient to locate any treatment
process close to the storage location of the dioxin contaminated soil, this
i
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would not be a requirement. Actually, siting of a treatment facility at a
later date will be a whole new issue with a variety of concerns to be addressed.
Proximity to the storage point will likely not be an over-riding concern.
The company indicated that there may be some problem with paying for the
clean-up of the dioxin sites in Missouri. EPA cannot make a commitment at
this time to contribute 90% of the costs for all of the dioxin clean-ups in
Missouri, However, before EPA makes any commitments to clean up any particular
sites, the Agency will have the money in hand to carry out the clean-up.
EPA has not been authorized by the Congress to incur debts. The financing
proposal by the company seems to constitute such a loan. Thus, EPA is
probably not in a position to accept the offer of financing for this or any
other projects. If the State of Missouri cannot find the resources to
contribute the required 10$ in matching funds, that will be a problem for
the State Legislature to address. In any case, the necessary federal funds
for the proposed facility are available.
The company stated that their proposal would provide total protection to
the surrounding environment. Much more study and investigative work will
be required to support this statement.
The company stated that their proposal will be less expensive than the
design developed for EPA. It is not possible to compare the two proposals,
because they address different problems. The EPA proposal is for a small
facility to facilitate the clean-up of six sites. The alternative proposal
seems to be for a much larger facility that would be used to contain all of
the contaminated soil In Missouri. No cost figures are given for the
alternative proposal, and EPA has not developed any estimates for, a total
cleanup of the dioxin sites in Missouri. It should be stressed that the
cost figures for the Interim Central Storage Facility project include all
costs for the temporary relocations, the site clean-ups and the restorations
of the sites. The cost estimate for the facility fs $2.7 million of the
$15.8 million total.
Finally, the company stated that their proposal will achieve community arid
governmental support. EPA feels that it is too early, and that the alter-
native proposal is too underdeveloped to predict the ultimate level of support
that might be obtained.
Conclusion
EPA does not intend either to encourage or discourage the company in further
i development of their proposal. There seems to be sufficient time to develop
proposals for addressing the contamination problem at Times Beach, for
example, because the Feasibility Study for that site-will not be concluded
until next summer. '
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