I S00164944

d

UPERFUND RECORDS

Record of Decision

RemedlTTAlternative Selection

Site; Rosalie and Callahan Properties, Elllsvlll e Area SU?

ElHsvllle, St. Louis County, Missouri

Documents Reviewed

I have reviewed the following documents describing the

cost-effectiveness of remedial alternatives for the Rosalie

Properties at the ElHsvllle Area Site.

--Study titled "Remedial Feasibility Study,

ElHsvllle Hazardous Waste Disposal Site,

ElHsvllle. Missouri," September 28, 1983.

--Study titled "Remedial Investigation,

ElHsvllle Hazardous Waste Disposal Site,

Elllsvllle , Missouri," September 21, 1983.

--Draft study titled, "Description of Current

Situation, ElHsvlll e Hazardous Waste Disposal

Site. ElHsvllle. Missouri," August 30. 19H?.

--Summary of Remedial Alternative Selection

--Staff summaries and recommendations.

--Recommendation by the Missouri Department of

Natural Resources

Description of Selected Remedy

A. Jean Ellen Callahan Property

w!

A remedial action should be Implemented for the Jean E

property to control erosion and slippage of the fill area

excavated during the 1981-82 Immediate removal action and t

vestiges of that action. The remnants of the plastic cover

fill area and the cover's hold-down blocks should be removpi

of. The soil 1n the fill area should be spread and regrade

slope over a larger area and covered with a compacted soil

should be reseeded. The barbed-wire fence around the fill

chain-link fence around the two drum storage areas should b

salvaged. The gravel 1n the two drum storage areas should

for possible salvage. The preliminary opinion of probable

action 1s $12.000.

analysis of

and Callahan

l en Callaha n

ere drum? were

i remove the

over the

and disposed

to a stable

ayer which

rea and the

removed and

Iso be removed

ost for this remedial
B. Rosalie Investment Company Property

The most cost-effective remedial action -- offslte dlspo

soil, burled drums, cans and other debris should be Implement

Investment Company property. Contaminated soil should be exc

locations on the property and transported 1n bulk to an offsl

hazardous waste disposal facility operating under RCRA permit

meeting CERCLA offslte policy. Drum Hds, cans and other deb

from three locations on the property and placed 1n drums. Ru

excavated and overpacked, with the drum contents sampled and

should be disposed of at an offslte commercial disposal fadl

RCRA permit or Interim status and meeting CERCLA offslte poll

testing and analysis to verify the effectiveness of the clean

should be placed and compacted 1n the excavated areas, with a

reseeded.

SbZ.OOO.

The preliminary opinion of probable cost for this

Declarations

Consistent with the Comprehensive Environmental Response

Liability Act of 1980, and the National 011 and Hazardous Sub

Plan (40 CFR Part 300), I have determined that at the Rosalie

Property, the excavation of contaminated soil, burled drums,

and offslte disposal at an appropriate commercial disposal

under RCRA permit or Interim status and meeting CERCLA offslt

an appropriate level of cleanup. At the Jean Ellen Cnllahan

determined that erosion control of the fil l area and removal

vestiges of the Immediate removal action provides an approprl

The actions taken are cost-effective remedies, and they

mitigate and minimize damage to, and provide adequate protect

welfare and the environment. I have also determined that the

appropriate when balanced against the need to use Trust Fund

In addition, the chosen remedy for the Rosalie Investment

with the requirements of Section 101(24) of CERCLA because

more cost-effective than potential onslte remedies and

health and the environment.

necessary

JUL 10 1985

/Si

Date Morris Ray

Regional Adm1n1sti

Region VII, ERA

al of contaminated

»d for the Rosalie

jvated from two

e commercial

or Interim status and

•1s should be removed

•led drums should be

.ested. The drums

ty operating under

:y. Following soil

p, borrow soil

1 disturbed areas

emedlal action 1s

Compensation and

tances Contingency

Investment Company

:ans and other debris

1ty operating

policy provides

'roperty, I have

)f the onslte

>te level of cleanup.

and reliably

on of public health,

actions taken are

noney at other sites.

Property complies

fsite disposal 1s

to protect public

fadl

effectively

Cor >any

of

ator
SUMMARY OF REMEDIAL ALTERNATIVE SELECT

ELLISVILLE AREA SITE

ROSALIE AND CALLAHAN PROPERTIES

SITE LOCATION AND DESCRIPTION

The Elllsvllle Area Site 1s located 1n west St. Louis

twenty miles west of downtown St. Louis, Missouri. The sit

Missouri, 1n Sections 31 and 32, Township 45 North, Range 4

Attachments A-l and A-2.

The site 1s comprised of three non-contiguous propertl

one-mile stretch along the watershed of Caulks Creek, a trl

which enters the Missouri River about one mile upstream of

waterworks Intake. The population within a one-mile radius

Imately 1,000. WHhln a three-mile radius the population 1

and within five miles the population Includes 8,000 to 10,0

1s being rapidly developed as a residential community. Mom s

1n subdivisions as well as on single lots.

( ounty, Missouri, about

lies west of Elllsvllle,

•ast, as shown In

s which He within a

utary of Bonhonme Creek,

City of St. Louis

of the site 1s approxcludes 5,000 people

0 people. The area

are being constructed

"Rosalie Site

One of the properties which comprise the site 1s owned

Company, a St. Louis County land development concern. The

located approximately 0.4 miles southwest of the Intersectl

and Strecker Road west. A housing development owned and op

Company, known as the Village of Winding Trails, occupies a

85.6 acre site. The actual siz e of the contaminated areas,

of 100-foot buffer zones, 1s 4.11 acres.

"Callahan Site

The Callihaii site 1s comprised of 8.02 acres located a

feet west of the corporate limits of the City of Elllsvllle

* pond, large barn and large wooded area are the

SITE HISTORY

On the morning of July 17, 1980, a contractor for the

Sewer District (MSD) encountered burled drums while excavat

line 1n a semi-rural area about one-half mile west of ElHs

drums were reported to the Missouri Department of Natural

the U.S. Environmental Protection Agency (EPA) emergency r

same day. A preliminary Invpstlgatlon by MONK and HSD of »

known as the Rosalie Investment Company property, Indicate

threat to public health and the environment. Subsequently

Identified by Informants or concerned citizens. The other

ON

by Rosalie Investment

roperty Is

n of Clayton Road

rated by Rosalie

major portion of this

Inclusive

proxlmately 1,000

Missouri.

feat ires of the property.

t. Louis Metropolitan

Ing for a new sewer

vllle, Missouri. The

fesources (HOUR) and

sponse groups that

site, which became

a potentially serious

two other areas were

areas are known as
the Callahan $1te and the Bliss site. Containerized and bulk Hpuld and solid

wastes were disposed of on these three properties reportedly durfng the 1970s. The

types of wastes Included solvents, oils, sludges, pesticides and] flammable gelatenous

materials.

On October 23, 1981, EPA announced that the ElUsvllle Area

National Priorities List. MDNR had applied for federal asslstar

1981. A cooperative agreement was awarded to the State on Marct

Site was on the

ce on September 25,

17, 1982, under

CERCLA. The objective of the cooperative agreement was to undertake a remedial

Investigation/feasibility study and to Implement appropriate remedial actions.

The site Investigation proceeded 1n four phases. The purpose oj Phase I, the

full field Investigation, was to characterize the wastes and define the extent

of contamination still remaining at the site. The purpose of Pllase II, the

feasibility study, was to determine remedial actions for the $1

cost/benefit analysis and recommend a preferred alternative. P

were completed by Black A Veatch. On September 28, 1983, the F

was released. Phases III and IV will be engineering design and

tatlon of the preferred remedial alternatives Identified 1n Pha

A. Rosalie Investment Company Property

e, conduct a

ase I and II

as1bH1ty Study

Implemen-

,e II.

Four dumping areas containing over 200 drums and one- and Hve-gallon

buckets of chemical wastes have been discovered on the property], some of which

were leaking wastes Into Caulks Creek. Some of the drums were removed from one

of the areas 1n August 1980, using federal funds available through Section 311

of the Clean Water Act. On August 6, 1980, the U.S. Coast GuarM-Karlne Safety

Office contracted with Western Environmental Services for removal and disposal

services of 4b (some reports say 47) drums suspected of containing hazardous

materials. On August 8, 1980, removal was complete. The remaining drums

containing trash from this area were removed and disposed at tile expense of the

Rosalie Investment Company. The remaining three areas were de

Ineligible for Section 311 funds. In June 1981, the State of

one hundred fifty-three (153) drums from two of the remaining

They were transported to the Environmental Emergency Services

Chesterfield, Missouri, for temporary offsite storage. The dr

under a MDNR emergency storage permit until arrangements could

disposal at a Subtitle C facUUy. The MDNR applied for Interim status for the

facility. In May and June of 1982, the 153 drums were transpcrted to two

licensed disposal facilities. Drums containing solids were tr

Home Service (BHS) 1n Wrlght City, Missouri,

transported to ENSCO 1n El Dorado, Arkansas.

Drums containing

ermlned to be

Missouri removed

.hree locations.

EES) facility 1n

jms were stored

be made for

On July 7, 1982, Black A Veatch, Woodward-Clyde Consulta

personnel visited the Rosalie property to view the four dump<

drums were seen, but drum lids and trash were observed. On

ansported to Bob's

liquids were

ts and MDNR

g locations. No

gust 30, 1982,
Black A Veatch stated 1n 1t$ "Draft Description of Current S1

that all of the containers found to date on the Rosalie site

from the property and disposed of. However, they felt that p

contaminated soil remained on the property at the four locatl

Between December 1982 and February 1983, a remedial flel

was conducted at the ElUsvllle Area Site. This 1nvest1gat1o

Black & Yeatch under contract to ERA. The objective of this

collect data to support the feasibility study for the ElHsvl

the course of the Investigation, a reconnaissance was conduct

three properties. Water, waste and air samples were obtained

chemical analysis.

An offslte Investigation was also conducted to evaluate

migration of wastes from the three ElUsvllle sites and to ob

help assess potential Impacts on human health resulting from

from these sites. The offslte Investigation was conducted 1n

first phase of the Investigation was the sampling of four dorm

water wells. The second phase was the collection of surface

five locations on Caulks Creek. (For a detailed assessment o

Attachment B-2: Remedial Investigation, Volume I: Summary Rep

1983, pp 39 and 40.)

B. Jean Ellen Callahan Property

*jn fcuguVl YV#o, YfcWfc receVvei * report tfootft puVt ftump^iT

property. An Investigation of the Callahan property was cond

September 16 and 17, 1980. The purpose of the Investigation

the property had been used for the disposal of hazardous wast«

least two Informants. The Investigation was conducted only 01

the property. No excavation was done. The Investigation rev<

uatlon" report

ad been removed

tentlally

ns.

Investigation

was performed by

nvestlgatlon was to

le Area Site. During

d at each of the

and submitted for

otentlal offslte

a1n Information to

aste migration

two phases. The

stlc drinking

ater samples from

data, refer to

rt, September 21,

on Yrre

cted by MDNR on

as to determine 1f

as alleged by at

the surface area of

aled thirty-eight

(38) 55-gallon drums either protruding from a filled ravine o1 below the filled

area. Positive responses from a metal detector were recordedlover the entire

fill area. Probing the soil with a metal rod Indicated burlef metallic

objects. Four additional drums were found exposed 1n the val eys south of

the fill.

In late 1981 and early 1982, an Immediate Removal action

property was Initiated by MDNR and completed by EPA. On Decenber 14, 1981, MDNR

obtained access to the Callahan property and Initiated excava

at the Callahan

drums, using state funds. The State of Missouri's contractor

Emergency Services. It became apparent to MDNR on December 1

additional funds were needed for cleanup when the original es

burled drums Increased to around 1,000. MDNR requested assls ance from EPA

Region VII on that date. An EPA Inspection team visited the

1on of burled

was Environmental

, 1981, that

1mates of 200

1te on December 18
and reported an Imminent hazard to public health and the envlro

Region VII submitted an Immediate Removal funding request to E

on December 24, 1981. On December 30, 1981, ERA announced the

$210,000 of Superfund money. EES signed a contract with ERA an

and staging activities on January 4, 1982. A total of 907 dru

storage either on the property or at BHS at the end of January

onslte drum storage areas were secured from public access with

fencing. ERA approved an additional $100,000 on January 27, 19

estimated number of drums Increased to 1300.

>nt. ERA

Headquarters

|va1 lability of

resumed removal

were 1n secure

I982. The two

haln link

[2, after the

The drum removal action was completed on February 18, 19821 One thousand

two hundred and five (1205) drums were excavated. A total of 613 drums

containing liquid and solid wastes were placed Inside recovery arums and stored

onslte. An additional eight (8) drums containing wastes from tjie Immediate

Removal were also stored onslte. The remaining 592 drums were placed

1n bulk disposal containers and disposed of at BHS. A total of

authorized by ERA for this removal action. Approximately $374,

by ERA and the State. Approximately 500 cubic yards of potentl

soil was placed back 1n the excavated area and covered with pla

$310,000 was

DOO was expended

illy contaminated

stlc sheets.

On June 30, 1982, 1t was reported that a large portion of khe backfilled

soil had slid from beneath the plastic cover. Black X Veatch, Woodward-Clyde

Consultants and MDNR personnel visited the Callahan property on July 7, 1982

to view the drums, the drum storage areas, the excavated and backfilled area

and the backfill slide. The excavated and backfilled area was enclosed by a

barbed-wire fence on July 21-22, 1982.

From July 21-27, 1983, Environmental Emergency Services r -

of the 624 drums of hazardous waste stored onslte at the Call a

total contractual cost of the removal was $87,360.

CURRENT SITE STATUS

A reconnaissance was made of the Jean Ellen Callahan prop

Remedial Investigation on December 28 and 29, 1982, to obtain

preparing an estimate of the volume and physical and chemical

area which previously contained drum wastes. It was noted th

which had been placed over the fill area was severely torn or

sampling was conducted 1n four general areas on the Callahan

areas were: 1) 1n and around the existing fill area, 2) the t

areas, 3) surface water dralnageways located downgradlent of

4) a potential borrow area for the construction of a surface

the north side of the site. (For a detailed assessment of th

Attachment B-3: Remedial Investigation, Volume I: Summary Re

1983, pp 28-30.)

moved and disposed

an Site. The

>rty during the

nformatlon useful 1n

ature of the fill

the plastic tarp

islntegrated. Soil

1te. These four

o fenced drum storage

he fill area, and

«p, located at

s data, refer to

ort, September 21,
The Remedial Investigation concluded that the soil In th

drums were excavated during the 1981-82 removal action was p

and susceptible to erosion. It was also determined that sol

areas on the Callahan property was not contaminated. The reTM

the Callahan property 1s to stabilize the soil mass at Us p

remove the vestiges of the Immediate Removal action at the s

removal and salvage of the chain-link and barbed wire fence

the two drum storage areas and removal of the plastic cover

blocks.

fill area where

slcally unstable

at the drum storage

»d1al objective for

?sent location and to

e. These Include

id the gravel used 1n

id Its hold-down

A reconnaissance survey was conducted during the Renedl

the Rosalie Investment Company property on January 6, 1983.

reconnaissance were: 1) to define a route of access to the fo

locations on the Rosalie Site, 2) to Identify each of the fou

locations on the Rosalie Site, 3) to mark the approximate 1

locations, and 4) to note any remnants of past removal actlv

was performed on the site at the four waste disposal locatlor

located downstream of the location designated as ELL-02, and

the former nursery operated on the Rosalie property. A surf

obtained from a standing pool of water located 1n a ditch dow

ELL-01. (For a detailed assessment of this data, refer to At

Remedial Investigation, Volume I Summary Report, pp 33-37.)

analysis for 2,3,7,8-TCDD was performed by Envlrodyne Englnee

the soil samples collected from the Rosalie Investment Compa

8-TCOD was detected at a 1 ppb detection level. The foil owl

related problems were Identified on the Rosalie Investment

ELL-01 -- Contaminated soil susceptible to erosion; Location

contaminated soil; ELL-03 — 1-gallon cans and drum debris;

5-gallon cans.

Contaminated soils were detected at Location ELL-01 ove

360 square feet extending to a depth of two feet. Contamlna'

detected at Location ELL-02 over an area of 1450 square feet

depth of four feet. Contaminants detected at these two loca'

summarized 1n Tables R-4 and R-6 of the Remedial Invest1gat1

In addition, burled drums possibly containing hazardous subs'

Identified at Location ELL-02. Locations ELL-01 and ELL-02

directly 1n surface water drainage ditches which are trlbuta

Caulks Creek. Undercutting of contaminated soil layers has

observed at Location ELL-01. Priority pollutants 1n excess

quality criteria for protection of human health and for toxl

freshwater aquatic life have been detected 1n surface water

both the Callahan and Rosalie properties.

A release of hazardous substances to the environment ha

the Rosalie property. Contaminants detected Include substan

and moderate toxldty. Highly toxic substances detected on

Investigation on

he purposes of this

r waste disposal

• waste disposal

1nIts of these four

1es. Soil sampling

, 1n a dry pond

n a portion of

e water sample was

stream from

achment 8-1:

addition, a special

s on a composite of

property. No 2,3,7,

i hazardous waste

Ccfnpany property: Location

LL-02-- Drums and

id Location ELL-04 --

an area of

d soils were

and to a

ons are

n (attachment B-4),

nces were

re located

es of

en visually

ERA water

ty to

amples from

been observed at

es of high

he Rosalie property
Include phenol and 4-methylphenol (4-cresol). Moderately to

1n the Rosalie property Include o-xylene, toluene, ethylhenz

These toxic substances are highly mobile 1n soil and could

ground water.

1c substances detected

ene and napthalene.

pctentlally migrate Into

The ElUsvllle Area site 1s underlain by a limestone be;c rock

known as the Burllngton-Keokuk (B-K) Formation having a thickness

170 feet 1n the region. This bedrock exhibits high water permeabl

solution-enlarged Joints. The pattern of these joints 1s gererally

and highly unpredictable. In consequence, surface water flo*s

(ground water recharge) and reappears on the surface (ground

at other locations. At the Rosalie property, this bedrock 1s

25-30 feet of moderately permeable soil. The bedrock at the

overlain by approximately 5-10 feet of moderately permeable s

water 1s estimated to range from 70 to 140 feet at the Callafan

surface to 150 feet at the Rosalie site. The bedrock aquifer

recharge from Infiltration and percolation ot pretfp^tatYon.

Formation underlying the B-K formations may act as a aqultar

Impermeability.

unit

of approximately

Hty along

random

Into the bedrock

water discharge)

overlain by approximately

allahan property Is

oil. Depth to ground

site and from near

s receive substantial

Vne Yower Tern tTien

because of Its relative

Both the Callahan and Rosalie properties are located 1n

mile Caulks Creek watershed. Caulks Creek has been classUl

stream by the Missouri Department of Natural Resources/01 vis

and Land Survey. Some of Its tributaries also appear to be

Due to the losing nature of the streams, water can disappear

bed and either reappear at the surface or Interflow with gro

this mechanism, contaminants which are Introduced Into Caulk

to enter the highly permeable alluvium 1n the bed of Caulks

enter the ground water.

Ground water 1s an Important resource of the region. I

that there were 70 wells 1n the Caulks Creek watershed, some

potable water supply. Many domestic wells reportedly exist

ElUsvllle Area site. Some of these wells utilize the B-K o

as their source of potable water. By the processes describe

which enter Caulks Creek and Us tributaries could potential

contamination of private domestic wells 1n the area. As a s

contaminants 1n contact with the B-K formations or their res

water through fluctuation of the water table, local saturatl

heavy runoff, or Infiltration, are likely to enter the groun

ENFORCEMENT

Initially, Regional enforcement efforts were directed

responsible party cleanup of each of the three properties co

area site simultaneously. Following Identification of the s

search was conducted. Information obtained as a result of t

the 18.72 square

d as a losing

on of Geology

oslng streams,

from the stream

nd water. Through

Creek are likely

reek and, hence.

was estimated 1n 1982

of which are used for

n the vicinity of the

Fern Glen Formations

above, contaminants

y result 1n the

condary pathway,

duum and exposed to

n during periods of

weter.

t jward securing

iprlslng the ElUsvllle

te, a responsible party

e search was forwarded
to EPA Headquarters, and on December 21, 1981, notice letters we 'e sent to

potentially responsible parties (PRPs). The PKPs Identified as If that date with

respect to the Callahan site Included the site owner, Jean Ellenlcallahan'

.ransporter and disposer of the wastes, Russell Martin BUss, Je[ry-Ru$seil Bliss

Inc., and American Can Company. Rosalie site PRPs notified wcrel former site •*

owner, Houllhan Nursery Company; present owner. Rosalie Investment Company;

transporter and disposer, Grover Callahan; and, Russell Martin BMss, Jerry-Russell

Bliss, Inc., and American Can Company.

In the Interim between the transmlttal of PRP Information t3 EPA Headquarters

and Issuance of the notice letters on December 17, 19t>l, MONK requested EPA

assistance to complete cleanup of the Callahan site. At the request of the

On-Scene Coordinator for the site, on December 2ti and 29, 19B1,

Regional Counsel contacted each of the Callahan site PRPs to aa

necessity for Immediate action to complete site cleanup and of

to undertake such action absent their willingness to do so. All

declined to undertake the response. Additionally, the site owne

grant permission for access to the site. Consequently, on Decenber 31, 1981, a

warrant for access was obtained from the United States District

of the warrant were obtained on January 14, 1982, and February i

number of drums encountered durlny the renioval action continuedIto exceed the

OSC's estimates. Upon completion of the response, the site ownar was given a

receipt for all samples collected. On February 26, 1982, at the request of the

he Office of

se them of the

e Ayency's Intent

parties contacted

refused to

-ourt. Extensions

19«2. as the

site owner, portions of all samples collected at the site were

PRP Negotiations

rov1de.i.

Both during and after completion of the Immediate Removal, several meetings

were held with PRP generators of the wastes at the site to dlscJss possibilities

for settlement of their liability. (As a result of inf ormatlonlobtained during

iorporation of

the Immediate Reinoval action, Kisco Company, Inc., The Orchard

America and GK Technologies, Inc., were Identified as additiona

negotiations failed to result 1n an acceptable offer of settlemmt.

Negotiations for responsible party cleanup of the Rosalie

conducted by the State and are ongoing. During a meeting with

on June 28, 1985, Rosalie Investment Company offered paynent of

toward future remedial action at the site. These negotiations

a period not to exceed thirty (3U) days following approval of t|

Decision by the Regional Administrator.

Civil Actions

Un August 3D, 1961, a civil action for cost recovery was

EPA 1n the United States district Court for the Eastern Uistri

[No. 84-20<ib(l)]. The action seeks reimbursement of $4t>c$,b!>l.

and expenses Incurred by the government for response actions a

site and a declaratory judgntent for future costs and expenses.

consolidated with three cases filed by the State of Missouri f

funds expended at each of the three ElUsville Area Site prope

ALTERNATIVES EVALUATION

PRPs.) These

ite have been

tate officials

a fixed sum

ill continue for

e Kecord of

After completion of the Remedial Investigation, work on a

began. The final version was dated September 28, ly83. The o

iled on behalf of

t of Missouri

'0 for actual costs

the tallahan

The case has been

r recovery of State

ties.

Feasibility Study

jectives of the
8

Feasibility Study Included the Identification of remedial ac

Identification of remedial action alternatives and the selec

effective remedial action alternatives for Implementation at

Site.

A. Rosalie Site

The remedial action objectives for the Rosalie property

drums, cans and debris from ELL-02, ELL-03 and ELL-04 and e1

concentrations of priority pollutants 1n soil at ELL-01 and I

(2) remove the contaminated soil from ELL-01 and ELL-02.

Table 3 of the Feasibility Study (Attachment C-l) 11st

for the contaminated soil, burled drums, cans and debris on

Table 3 also Indicates whether the technology 1s appropriate

property and the reason 1f 1t 1s not appropriate. All of th

technologies are consistent with technologies presented 1n t

Plan (40 CFR 300.70) pertinent to the remedial action object

An Initial screening of the remedial technologies 1dent

Table 3 for the Rosalie Investment Company property was perf

of order of magnitude costs, effects of the alternative and

practices. The number of alternatives was narrowed to four

screening.

Alternative

R-l: No Action

R-2: Onslte biological treatment of contaminated soil

and off-site disposal of debris and burled drums.

R-3: Onslte disposal

R-4: Offslte disposal

A detailed analysis of these four remedial alternatives

the Initial screening. The following criteria were used to

remedial alternatives during the detailed analysis:

-Probable cost

-Significant adverse environmental effects

-Adequate control or effectiveness

-Reliability

-Implementability

fon objectives, the

Ion of the most costthe ElHsvllle

fere to remove

Jher (1) reduce the

L-02 or

remedial technologies

t|he Rosalie property,

or the Rosalie

listed remedial

le National Contingency

ves.

fled as appropriate 1n

rmed 1n consideration

cceptable engineering

ollowlng the Initial

Estimated

Capital Cost

None

$97.000

$200,000

$52,000

was performed following

valuate each of the
-Operation and maintenance requirements

-Safety and regulatory requirements

-Public acceptance

In order to develop the alternatives and the evaluation

1t was assumed that the lateral extent of soil contamination

ELL-01 and 1,450 sq. ft. at ELL-02. The number of burled dru

be 15.

The four remedial alternatives were evaluated 1n detail

These alternatives are summarized 1n Table 2 of the Feas1b1l1

(Attachment G-l). Capping was not considered beyond the 1n1t

this alternative would be Ineffective at remedying the threat

drums at ELL-02 and contaminated soil 1n the stream bank at £

stabilize and contain the stream bank at ELL-01 1n comblnatlo

prove far more costly than the alternatives evaluated 1n deta

remove the contamination and threat of release. Alternative

would not remedy existing conditions which have the potential

adverse environmental and public health effects. The results

Investigation Indicated that the organic priority pollutant c

the soil had not significantly decreased since July 1981. Al

drums would be left 1n place. The possibility of surface, gr

water contamination would still exist from the contents of th

R-2 (onslte biological treatment of contaminated soil using 1

and offslte disposal of burled drums, drum Hds, cans, and ot

the second highest probable cost. There currently exists no

treatment which has been proven effective for the specific co

conditions present on the Rosalie Investment Company property

biological treatment technology would be costly and could pro

Alternative R-3 (onslte disposal of contaminated soil, burled

metal fragments and trash 1n a secure landfill on the Rosalie

highest probable cost. It would Involve location of a landf

geologic setting. It also would require long-term monltoMnc

Alternative R-4- (offsite disposal of contaminated soil, burl

metal fragments and debris) has the lowest probable cost and

greatest benefit to public health and the environment. It we

acceptable to the public and would have no long-term ma1nten^

requirements. It 1s, therefore, recommended that Alternat1v<

as the remedial action for the drums, cans and contaminated s

Investment Company property.

B. Callahan Site

Remedial technologies for the unstable fill area on the

are listed 1n Table 1 of the Feasibility Study (Attachment C

1n-s1tu mass soil stabilization, are technologies presented

Contingency Plan (40 CFR 300.70) pertinent to the remedial a

Table 1 Indicates whether the technology 1s appropriate for

and the reason 1f 1t 1s not appropriate.

rlterla Information,

as 360 sq. ft. at

was assumed to

or the Rosalie Site,

y Study

al screening because

posed by the burled

L-01. Measures to

with capping would

1 and would not

-1 (no action)

for causing

of the Remedial

ncentration 1n

o, the burled

und and drinking

drums. Alternative

ndfarming techniques

er debris), has

ype of biological

tamlnants and

Development of

e Ineffective,

drums, cans,

property) has the

1 1n a questionable

and maintenance.

drums, cans,

ould provide the

Id be the most

ce or monitoring

R-4 be Implemented

ill on the Rosalie

allahan property

) All, except for

n the National

1on objectives.

he Callahan property
10

A no-action alternative for the Callahan property was not

Feasibility Study. This alternative will be discussed 1n this

Record of Decision. During the Remedial Investigation, core

collected from the Callahan fill area and surface soil and wat

collected downgrade of the fill area. Results of analyses of

were presented 1n Tables C-3 and C-4 of the Remedial Investlga

presented 1n Attachment H. Priority pollutant contaminants de

Callahan site during the Remedial Investigation Include b1s(2

phthalate, PCB-1254 and fluorotrlchloromethane. Numerous other

pollutant compounds were tentatively Identified on the site,

composite sample of the fill area and a fill runoff sample werje

during the 1981-82 removal action. Contaminants detected 1n

Include 2,4-d1methylphenol, phenol, napthalene, nitrobenzene,

phthalate, d1-n-octyl phthalate, ethylbenzene, toluene and tet

These results are presented 1n Attachment I. Contaminants

Callahan property constitute a release to the environment,

concludes that 1f stabilization of the fill area Is not provl

the fill material will continue to occur. This erosion will

way at the base of the fill and will result 1n continued offsl

hazardous substances. Due to this consideration, the no-act1<n

not selected for the Callahan fill area.

evaluated 1n the

section of the

simples were

r samples were

hese samples

1on and are

ected on the

thylhexyl)

organic priority

n addition, a

collected

t lese samples

1s(2-ethylhe*yl)

achloroethylene.

detected on the

Feasibility Study

d, erosion of

enter the drainage

te migration of

alternative was

Th

Both remedial alternatives evaluated for the Callahan

removal of vestiges of the 1981-82 removal action. This actltn

to a conmltment made to the site owner to restore the propert)

activities.

An Initial screening of technologies Identified 1n Table

the Jean Ellen Callahan property was performed 1n cons1derat1<n

magnitude costs, effects of the alternative and acceptable en

A detailed analysis was then performed on the following two

using evaluation criteria presented above for the Rosalie

EstlmaAlternative

C-l: Immediate Removal Action Closure

C-2: Fill Stabilization, Erosion Control

and Immediate Removal Action Closure

Capital

$6,

$12.

Both of the alternatives Include onslte activities to re

of the Immediate removal action. These onslte activities 1nc

-Removal and disposal of the plastic cover remnants over

-Removal and salvage of the barbed-wire fence around the

property Include

1s required due

following removal

as appropriate for

of order of

1neer1ng practices,

n medial alternatives

Proferty alternative:

ost

00

00

10ve the vestiges

ude the following:

the fill area,

fill area.
11

-Removal and salvage of the chain-link fence around the t

storage areas.

-Removal and possible salvage of the yravel In the two dr

areas.

The additional feature of Alternative C-2 1s:

-Stabilization and erosion control measures for the soil

A comparison of the two alternatives appears 1n Table 4 i

Study (Attachment G-2). In evaluating the two alternatives, a

would not eliminate slippage and erosion of the soil mass 1n t

bactcf 1lled area. Alternative C-2 addresses this problem along

for general closure activities which are common to both altern

mass would be spread over a larger area at Its present locatlo

stable slope. A layer of top soil would be spread to a six In

area and compacted. The area would then be seeded to control

Selection of this remedial alternative will have no required o

maintenance. Alternative C-2 1s more costly than Alternative

Implementation would eliminate the potential for continued off

hazardous substances. It Is, therefore, recomr.iended that Alte

Implemented as the Remedial Action for the Callahan property.

COMMUNITY RELATIONS

The RI/FS for the Rosalie and Callahan portions of the £1

was released for public comrnent In July 1984. Announcements

St. Louis area newspapers. On August 9, 1984, a public hearln

the St. Louis County Library, Daniel Boone Brancn, 300 Clarkso

Missouri, to describe the remedial alternatives for the Rosall

properties and the recommended remedial alternatives for site

the presentation of alternatives, attendees were allowed to cor

the proposed remedial action. No opposition was voiced a^

actions or their associated costs. Written comments were acce

1984. None were received. A responsiveness summary has been

State (Attachment E). Citizens generally expressed a Jeslre

federal officials to take the necessary actions to clean up th

would pose no adverse effects to them or their children. They

about obtaining the necessary formal approval from EPA Keadqua

O.C., to Implement the proposed Remedial Actions. Many wanted

federal officials would endorse the action. Overall, citizens

We believe that Implementation of alternative R-4 (offslt

will satisfy the concerns of citizens at the Rosalie Site. It

lowest probable cost and would provide the maximum benefit to

believe that Implementation of alternative C-2 will satisfy th

citizens at the Callahan site. It will correct the physical 1

o drum

m storage

ass 1n the fill area.

the Feasibility

ternatlve C-l

excavated and

with the need

tlves. The soil

and graded to a

h depth over the

urther erosion,

eratlon and

-1, but Its

Ite migration of

native C-2 be

1sv1lle Area site

w< re published 1n

was conducted at

Road, Ell1sv1lle,

and Callahan

leanup. Following

nent orally upon

the proposed

ted until August 17,

repared by the

allow state and

site such that It

expressed concern

ters 1n Washington,

to know when

reacted positively.

disposal)

rias the

he public. We

concerns of

stability of the
13

and to a depth of four (4) feet will be excavated from Locat

samples will be collected from the perimeter and bottom of t

order to determine contaminant levels which remain at Locatf

This sampling will be performed 1n accordance with a sampHn

during Remedial Design and approved by the Centers for D1$ea

These soil samples will be analyzed for priority pollutants

results provided to CDC for assessment. If CDC determines tl

levels remaining onslte do not represent a threat to public !

excavations will be backfilled and reseeded. If CDC recognl

threat to public health, the contract will be modified to al

required excavation. Soil sampling will again be performed

plan approved by CDC, and analytical results will be provide

This process will be repeated until CDC determines that a th

no longer exists. All excavated soil will be transported 1n

hazardous waste land disposal facility operating under an api

or Interim status and meeting current CERCLA offsHe policy,

to a commercial hazardous waste Incineration facility operat

RCRA permit or Interim status.

Results of soil sampling conducted during the Remedial

reviewed by the Centers for Disease Control (CDC). CDC has <

basis of the Information presented 1n the Remedial Investlgat

appear to be a threat to public health due to soil contamlna

ELL-02 or those detected below a depth of two feet at ELL-01

1t 1s not anticipated that additional excavation will be req

240 cubic yards specified, 1f subsequent sampling confirms t

which were determined during the Remedial Investigation. Hovever

conditions were not completely defined 1n the Remedial Inves

possibility does exist that additional excavation may be req

Excavation of burled drums at Location ELL-02 will proc

soil excavation. When possible, duplicate samples will be c

of the excavated drums. One sample from each drum will be a

pollutants and RCRA hazardous waste characteristics. Follow

drum will be overpacked 1n 85-gallon recovery drums and temp

1n a secured drum holding area until receipt of analytical r

liquids will be disposed of by Incineration at a commercial

Incineration facility operating under an appropriate RCRA pe

Drums containing sol Ids will be disposed of at a commercial

operating under an appropriate RCRA permit or Interim status

CERCLA offslte policy, or 1f cost-effective, at a commercial

Incineration facility operating under an appropriate RCRA

status. Drums observed to contain non-hazardous substances

garbage, debris, empty cans and other non-hazardous material

at a permitted sanitary landfill. Drum lids, empty cans and

from Locations ELL-02, ELL-03 and ELL-04 will be deposited 1

These drums may also be disposed of at a permitted sanitary

analytical data for sampled drums will be provided to the ap

facility.

on ELL-02. Soil

e excavations 1n

ns ELL-01 and ELL-02.

plan developed

e Control (CDC).

nd the analytical

at contaminant

ealth, then the

es a remaining

ow for the additional

n accordance with a

to CDC for assessment,

eat to public health

bulk to a commercial

roprlate RCRA permit

or 1f cost-effective,

ng under an appropriate

nvestlgatlon have been

dvlsed that on the

1on, there does not

ts detected at

For this reason,

1red beyond the

soil conditions

, subsurface

Igatlon, and some

1red.

ed concurrently with

llected from each

alyzed for priority

ng sampling, each

rarlly stored onslte

suits. Drums containing

azardous waste

m1t or Interim status,

and disposal facility

and meeting current

hazardous waste

pelm1t or Interim

r wastes (I.e., trash,

) may be disposed of

other debris collected

55-gallon drums,

andflll. Copies of

roprlate disposal
The offslte disposal of hazardous wastes at the Rosalie | roperty meets

the requirements of CEKCLA Section 101(24). The alternative r

to be more cost-effective than the other alternatives, and 1s

public health, welfare and the environment from a present rlsl

maintenance requirements for this alternative will be the resp

offslte permitted disposal facility. A breakdown of the capl

Attachment 0-1. Alternative R-4 achieves the most reliable ar

protection of public health and environment at the lowest rel.

Alternative C-2 (Jean tllen Callahan Property) will 1mpl

Action to control erosion and slippage of the fill area where

during the 1981-82 Immediate Renoval and remove the vestiges

remnants of the plastic cover over the fill area and the cove

will be removed and disposed of. The soil 1n the fill area w1

stable slope over a larger area, and covered with a 6 Inch sol

be compacted and reseeded. The barbed-wire fence around the f

chain-link fence around the two drum storage areas will be rem

The gravel In the two drum storage areas will be rer.oved for p

The preliminary opinion of probable cost for this rer.iedial act

Implementation of this alternative will result 1n no operation

requirements. A breakdown of the capital cost, estimates appea

D-2.

After giving careful consideration to the cost effectiven

alternative and evaluating the public coroMents received, the M

of Natural Resources recommended the following two alternative;

Involving off-site disposal of contaminated soil, buried druws

at the Rosalie Investment Company Property anr! Alternative C-2

stabilization and erosion control measures for the soil n^jss 1i

area and removal of the vestiges of the Immediate Removal. A

the State's decision appears on Attachrent F.

OPERATION AND MAINTENANCE (U&M)

Recommenced alternatives at the Rosalie and Callalian site;

activities.

SCHEDULE

Approve Remedial Action (Sign ROD)

Amend/Award Cooperative Agreement for Remedial Design/

Remedial Action

Procure Design Contractor Under Class Deviation

Complete Design

Procure Construction Contractor

as been demonstrated

necessary to protect

Operation and

onsibllity of the

al costs appear 1n

effective

;1ve cost.

nt a Remedial

rums were excavated

that action. The

s hold-down blocks

I be regraded to a

layer which will

II area and the

»ved and salvaged.

>ss1ble salvage,

on is $12,0uu.

and maintenance

•s in Attachment

ss of each

ssouri Department

: Alternative R-4

cans and debris

involving

t he Callahan fil l

etter confirming

wi11 require no

Date

June 21, I98t>

August 2, 19Hb

6, 198[>

November 29,

March 14,
IS

Initiate Construction

Complete Construction

FUTURE ACTIONS

The recommended alternatives at the Rosalie and Callah

a final action. All vestiges of past remedial activities an

a threat to public health, welfare, or the environment will

properties. No future remedial activities are anticipated.

March 28, 1986

June 27, 1986

sites will constitute

all materials posing

e removed from the