                 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                   REGION 7
                            11201 Renner Boulevard
                             Lenexa, Kansas  66219


                 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                   REGION 7
                            11201 Renner Boulevard
                             Lenexa, Kansas  66219



                                       


                                       

                                 May 22, 2017

Responsiveness Summary

Introduction
	
A Notice of Intent to Delete for the Callahan subsite of Ellisville Superfund Site was published in the Federal Register on March 18, 2016 (81 FR 14813-14817). The publication of this notice was intended to inform the public that the EPA planned to delete the subsite from the National Priorities List, and provide a 30-day public comment period on the proposed deletion. An additional 30-day public comment period was granted at the request of the city of Wildwood. The closing date for comments on the Notice of Intent to Delete was May 18, 2016. Twenty-five written comments were received (these comments are available in the Information Repositories); therefore, the EPA has prepared this Responsiveness Summary. In addition, all public comments were considered in the EPA's final decision to delete the Site from the NPL. 

Responsiveness Summary

The Responsiveness Summary has been prepared to provide responses to comments submitted to the EPA during the 60-day public comment period regarding the Notice of Intent to Delete [EPA-HQ-SFUND-1983-0002; FRL-9943-94-Region 7] the Callahan subsite of the Ellisville Superfund Site. The original comments are summarized below and are available at http://www.regulations.gov, Docket ID No. EPA-HQ-SFUND-1983-0002, with the support materials under document type "Public Submissions", and at the information repositories at the following addresses: U.S. Environmental Protection Agency, 11201 Renner Boulevard, Lenexa, KS 66219 and the Daniel Boone Branch Library, 300 Clarkson Road, Ellisville, MO, 63011.

Several commenters remain very concerned with the public health risks that may still remain within the Ellisville Superfund Site at this time, inclusive of each of its subsites; therefore, they strongly oppose any consideration for delisting until such time that the public health risks have been abated.

The partial deletion process, as outlined in the Federal Register on November 1, 1995 (60 FR 55466-55467), was started after the 2012 removal action when the EPA received a request from the property owner to delete their property from the National Priorities List (NPL). After receiving the request to delete, the EPA gathered all Callahan data and evaluated it in the 2015 Evaluation of Post-Removal and Historical Data Representative of Current Conditions. The 2015 Evaluation of Post-Removal and Historical Data Representative of Current Conditions determined all threats to public health and the environment requiring action have been addressed and that the Callahan subsite meets the criteria for nlimited use/unrestricted exposure (UU/UE). Based on an evaluation of all requirements under 40 CFR § 300.425(e) and 60 FR 55466-55467, the EPA concluded that the Callahan subsite could and should be deleted from the NPL. Since the Callahan subsite meets UU/UE requirements, a five-year review is not required for the Callahan subsite.

There are three subsites at the Ellisville Superfund Site. The three subsites that make up the Ellisville Superfund Site are Rosalie (OU1), Bliss (OU2), and Callahan (OU3). All three of these subsites are separate and non-contiguous, and only the Bliss subsite had dioxin contamination. Dioxin is not a contaminant of concern at the Callahan subsite. The contaminants of concern at the Callahan subsite consisted of paint wastes and solvents. Polychlorinated biphenyls (PCBs) were detected in soil at the Callahan subsite but were never above a screening level of concern. All contamination on the Callahan property has been addressed and the site is ready for reuse.

The first removal action at the Callahan subsite occurred in 1981 with a total of 1,205 drums removed from the subsite; a total of 613 of those drums contained hazardous waste. The second removal action was conducted from November 27, 2012 through December 6, 2012. Contaminated soil was removed by an excavator and then placed directly into dump trucks for disposal at the Milam Landfill. A total of 2,056.74 tons of contaminated soil and debris, including drum fragments and metal pieces, was excavated. The EPA removed all contaminated soil down to bedrock at the Callahan subsite, then collected confirmation samples on the sidewalls to confirm that clean-up was achieved both vertically and laterally. All details of the Callahan removal can be found in the Removal Action Report dated  April 16, 2013, at the information repositories. The EPA also conducted a groundwater investigation at the property where three wells were installed, then sampled. All groundwater samples at the Callahan subsite were non-detect for contaminants of concern. Details regarding the groundwater investigation can be found in the Site Reassessment Report dated June 13, 2012, at the information repositories. 

If the property was sold and excavation work for new homes did occur, there would be no threat to human health at the site because all soil contamination, even at depth, was removed from the subsite. Minor detections in soil were found down slope of the excavation but were below any level of concern. Indoor air sampling was not conducted at residential homes near the Callahan subsite since all impacted soil was removed from the site and the groundwater is not impacted with contamination. The Callahan subsite does not border Caulks Creek nor could any contamination leak into the creek from the subsite since all contamination has been addressed.

As the EPA has discussed in previous meetings with the City and concerned community members, the EPA is not proposing to delete either of the other subsites at this time. The EPA will continue to work collaboratively with the City and State of Missouri as circumstances warrant on these other subsites. The EPA will also continue dialogue on the active portions of the Ellisville Superfund Site to ensure that local, state, and federal authorities are aware of activities on the Site. It is important to note that the partial deletion of the Callahan subsite from the NPL is more administrative than substantive in nature. In accordance with the CERCLA law, the EPA retains the authority to respond if new information or evidence comes to our attention that warrants additional action.  

Several commenters stated that additional time to observe the site is warranted to assure any possible long-term effects are assessed.

The EPA removed all contaminated soil down to bedrock at the Callahan subsite, then collected confirmation samples on the sidewalls to confirm that clean-up was achieved both vertically and laterally. All details of the Callahan removal can be found in the Removal Action Report dated April 16, 2013. The EPA also conducted a groundwater investigation at the property where three wells were installed, then sampled. All groundwater samples at the Callahan subsite were non-detect for contaminants of concern. Details regarding the groundwater investigation can be found in the Site Reassessment Report dated June 13, 2012, in the information repositories. The 2015 Evaluation of Post-Removal and Historical Data Representative of Current Conditions determined all threats to public health and the environment requiring action have been addressed and that the Callahan subsite meets the criteria for unlimited use/unrestricted exposure (UU/UE). Based on an evaluation of all requirements under 40 CFR § 300.425(e) and 60 FR 55466-55467, the EPA concluded that the Callahan subsite could and should be deleted from the NPL. Since the Callahan subsite meets UU/UE requirements, a five-year review is not required for the Callahan subsite. Indoor air sampling was not conducted at residential homes near the Callahan subsite since all impacted soil was removed from the site and the groundwater is not impacted with contamination. The Callahan subsite does not border Caulks Creek nor could any contamination leak into the creek from the subsite since all contamination has been addressed.

Several commenters stated their concern that construction will disturb contaminants left at the site.  Dust may be hazardous.  Recontamination may occur.

The EPA removed all contaminated soil down to bedrock at the Callahan subsite, then collected confirmation samples on the sidewalls to confirm that clean-up was achieved both vertically and laterally. All details of the Callahan removal can be found in the Removal Action Report dated April 16, 2013. The EPA also conducted a groundwater investigation at the property where three wells were installed then sampled. All groundwater samples at the Callahan subsite were non-detect for contaminants of concern. Details regarding the groundwater investigation can be found in the Site Reassessment Report dated June 13, 2012, in the information repositories. The 2015 Evaluation of Post-Removal and Historical Data Representative of Current Conditions determined all threats to public health and the environment requiring action have been addressed and that the Callahan subsite meets the criteria for unlimited use/unrestricted exposure (UU/UE). Based on an evaluation of all requirements under 40 CFR § 300.425(e) and 60 FR 55466-55467, the EPA concluded that the Callahan subsite could and should be deleted from the NPL. Since the Callahan subsite meets UU/UE requirements, a five-year review is not required for the Callahan subsite. Indoor air sampling was not conducted at residential homes near the Callahan subsite since all impacted soil was removed from the site and the groundwater is not impacted with contamination. The Callahan subsite does not border Caulks Creek nor could any contamination leak into the creek from the subsite since all contamination has been addressed.

Several commenters stated that dioxin contaminants were not evaluated or were being left in place at the Callahan subsite.

There are three subsites at the Ellisville Superfund Site. The three subsites that make up the Ellisville Superfund Site are Rosalie (OU1), Bliss (OU2), and Callahan (OU3). All three of these subsites are separate and non-contiguous, and only the Bliss subsite had dioxin contamination. Dioxin is not a contaminant of concern at the Callahan subsite. The EPA and MDNR have collected and analyzed almost 50 soil samples for dioxin at the Callahan subsite and dioxin has never been detected. The contaminants of concern at the Callahan subsite consisted of paint wastes and solvents.

Several commenters stated that PCB contaminants were being left in place at the Callahan subsite.

There were 33 soil samples analyzed for PCBs at the Callahan subsite. Only nine of these soil samples had detections for PCBs and they were all below any screening level of concern. These minor detections of PCBs do not constitute soil impacts which require response actions to protect human health and the environment.
Several commenters stated that groundwater was not evaluated at the Callahan subsite.

The EPA conducted a groundwater investigation at the Callahan property in September/October 2011. Three wells were installed at the Callahan property. Groundwater samples were collected from each well using low flow sampling and analyzed for dioxins/furans, volatile organic compounds, semi-volatile compounds, metals (arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver) and PCBs. All groundwater sample results were non-detect for all contaminants of concern. Details regarding the groundwater investigation can be found in the Site Reassessment Report dated June 13, 2012, at the information repositories.

Some commenters stated that vapor intrusion issues were not evaluated at the Callahan Subsite.

Indoor air sampling was not conducted at residential homes near the Callahan subsite since all impacted soil was removed from the site and the groundwater is not impacted with contamination.

Some commenters stated that because only one operable unit of the Ellisville site has been remediated, there should not be a partial deletion until the other two operable units have been remediated.

The partial deletion process, as outlined in the Federal Register on November 1, 1995 (60 FR 55466-55467), was started after the 2012 removal action when the EPA received a request from the property owner to delete their property from National Priorities List (NPL). After receiving the request to delete, the EPA gathered all Callahan data and evaluated it in the 2015 Evaluation of Post-Removal and Historical Data Representative of Current Conditions. The 2015 Evaluation of Post-Removal and Historical Data Representative of Current Conditions determined all threats to public health and the environment requiring action have been addressed, and that the Callahan subsite meets the criteria for unlimited use/unrestricted exposure (UU/UE). Based on an evaluation of all requirements under 40 CFR § 300.425(e) and 60 FR 55466-55467, the EPA concluded that the Callahan subsite could and should be deleted from the NPL. Since the Callahan subsite meets UU/UE requirements, a five-year review is not required for the Callahan subsite.

Several commenters requested that five-year reviews be conducted at the Callahan subsite.

The partial deletion process, as outlined in the Federal Register on November 1, 1995 (60 FR 55466-55467), was started after the 2012 removal action when the EPA received a request from the property owner to delete their property from National Priorities List (NPL). After receiving the request to delete, the EPA gathered all Callahan data and evaluated it in the 2015 Evaluation of Post-Removal and Historical Data Representative of Current Conditions. The 2015 Evaluation of Post-Removal and Historical Data Representative of Current Conditions determined all threats to public health and the environment requiring action have been addressed and that the Callahan subsite meets the criteria for unlimited use/unrestricted exposure (UU/UE). Based on an evaluation of all requirements under 40 CFR § 300.425(e) and 60 FR 55466-55467, the EPA concluded that the Callahan subsite could and should be deleted from the NPL. Since the Callahan subsite meets UU/UE requirements, a five-year review is not required for the Callahan subsite.




Several commenters confused contamination found at the Bliss subsite with the Callahan subsite.

The Bliss subsite and its contamination is often confused with the Callahan subsite. The contamination at the Bliss/Strecker subsite is separate from the Callahan subsite. The Callahan subsite is a separate, non-contiguous subsite of the Ellisville Superfund Site. All contamination on the Callahan property has been addressed and the site is ready for reuse, whereas the Bliss subsite is still being investigated. All the recent reports of potential contamination in the last two years pertained to the Bliss subsite and have nothing to do with the Callahan subsite.

One commenter stated that sampling was not conducted inside the barn at the Callahan subsite.

An extensive investigation of the Callahan subsite has been conducted that included investigating the barn. Six samples (CS-04, CS-05, CS-06, SB-1, W-1, and W-2) were collected in 2005 from the barn and analyzed for dioxin; all were non-detect.

One commenter stated that contamination from the Callahan subsite is leaking into Caulks Creek.

The Callahan subsite does not border Caulks Creek nor could any contamination leak into the creek from the subsite since all contamination has been addressed.

Commenter states that the Callahan site was contaminated by the Bliss Waste Oil Company.

There are three subsites at the Ellisville Superfund Site. The three subsites that make up the Ellisville Superfund Site are Rosalie (OU1), Bliss (OU2), and Callahan (OU3). All three of these subsites are separate and non-contiguous, and only the Bliss subsite had dioxin contamination. Dioxin is not a contaminant of concern at the Callahan subsite. The contaminants of concern at the Callahan subsite consisted of paint wastes and solvents. A few PCBs were detected in soil at the Callahan subsite but were never above a screening level of concern. All contamination on the Callahan property has been addressed and the site is ready for reuse, whereas the Bliss subsite is still being investigated. 

