Skip to: 1980s 1990s 2000s 2010s 2020s 2015 EPA Human Health Risk Assessment
This is a chronological log of all known studies performed and other documents to assess the safety of the former Callahan property. I included other dates and events as may be relevant.
Summary of Information
The property at 210 Strecker Road was formerly known as the Callahan property. The Callahan property was formerly listed on the EPA’s National Priority List along with two other properties in Ellisville. The three properties together were known as the “Ellisville Site”. In 1981 and 2012 work known as “Remedial Action” (RA) was performed at the Callahan property to remove contamination. The Callahan site was successfully cleaned of all contamination in 2012 and was therefore delisted from the NPL in 2017. Confusion between the Callahan property and the other two properties has resulted in significant misinformation about the Callahan (210 Strecker Rd) property. The Callahan property is the ONLY of the three to have been delisted from the NPL.
The other two properties are the Bliss Property and the Rosalie property. The Rosalie property was cleaned in 1982 and was developed into a small lot residential neighborhood in Wildwood. The Bliss property still has contamination onsite and is NOT ready for unrestricted use.
Detailed History of 210 Strecker Rd.
1980s
1980, July 7 – Drums were discovered on the Rosalie property by an MSD employee installing a sewer line. The drums were reported to the MDNR and EPA with the EPA responding the same day. Investigation by MDNR indicated a potential serious threat to the public health and the environment. The Rosalie property is a separate site in Wildwood and is noncontiguous with the Callahan property. (EPA Record of Decision 1985)
1980, August – The Missouri Department of Natural Resources received a report from an eye witness that drums had been dumped in a gully on the Callahan property. (EPA Pollution Report #31 1982, Tetra Tech Removal Action Report 2013)
1981, October 23 – The EPA announces the Ellisville Area Site was on the Nation Priority List. The Ellisville Area Site included three Operable Units or subsites, the Bliss Site, the Rosalie Site, and the Callahan Site. (EPA Record of Decision 1985)
1981, December 14 – MoDNR initiated removal action of the drums found on the Callahan property with state funds and requested EPA funds on 12/17/81. (EPA Pollution Report #31)
1981, December 29 – EPA immediate removal funds were granted for emergency clean up activities at the Callahan property. (EPA Pollution Report #31 1982)
1982, January 4 – EPA Region VII initiated drum removal actions with Environmental Emergency Services as contractor at the Callahan site. In total 1,205 drums were found. An additional 8 drums were generated from screening analyses. (EPA Pollution Report #31 1982)
1982, January 12 – The Missouri Department of Natural Resources produced a Fact Sheet regarding the “Hazardous Waste Cleanup Project–Callahan Property”. The fact sheet discusses the need to take immediate action to remove the barrels from the ground and that additional future action will be needed when funds are available. (Fact Sheet 1982)
1982, February 18 – Drum removal action was completed at the Callahan property. A total of 1,205 drums were excavated. Of those 613 drums containing liquid and solid wastes were placed inside recovery drums and stored onsite and the remaining 592 were placed in bulk disposal containers and disposed at Bob’s Home Services. Upon completion of the interim clean up the area was backfilled and covered with plastic sheeting. (EPA Record of Decision 1985)
1982, June 30 – It was reported that a large portion of backfill from the prior clean up action had slid from beneath the plastic cover. (EPA Record of Decision 1985)
1982, July 21-27 – Environmental Emergency Services removed and disposed of 624 drums (613 original drums plus 8 additional drums containing wastes from the Immediate Removal) of hazardous waste stored onsite at the Callahan Site. (EPA Record of Decision 1985)
1982 – There is a document referenced by this 2008 Wildwood Data Review (Strecker Forest) as ‘Ecology and Environment 1982’. I was unable to locate this document.
1982, August 30 – Black & Vaetch Engineers-Architects prepared a 66 page draft report “Description of Current Situation” for the EPA. SEMS Document ID:200550 I was unable to locate this document. (Documents Reviewed to Develop Record of Decision)
1982, September 21 – Black & Vaetch Engineers-Architects prepared a 333 page report “Remedial Investigation, Volume I: Summary Report and Volume II: Appendices” for the EPA. SEMS Document ID:200731. I was unable to locate this document. (Documents Reviewed to Develop Record of Decision)
1982, September 28 – Black & Vaetch Engineers-Architects prepared a 91 page report “Remedial Feasibility Study, Ellisville Hazardous Waste Disposal Site” for the EPA. SEMS Document ID:200731. I was unable to locate this document. (Documents Reviewed to Develop Record of Decision)
1982, Date unknown – US EPA prepared a 15 page report “Summary of Remedial Alternative Selection Ellisville Area Site, Rosalie and Callahan Properties” SEMS Document ID:30244814. I was unable to locate this document. (Documents Reviewed to Develop Record of Decision)
1982, December 28-29 – Black & Vaetch was contracted by the EPA to perform a RI/FS for each of the three subsites under the Ellisville Area Site. Reconnaissance was performed at the Callahan property to obtain information about the volume and physical & chemical characteristics of the fill in the area that previously contained drum wastes. Soil samples were conducted in each of these four areas: 1) in and around the fill area, 2) the drum storage areas, 3) surface water drainage ways downhill of the fill area, and 4) an area at the north side of the site. (EPA Record of Decision 1985)
1983, September 06 – Missouri Department of Natural Resources published an Ellisville Site Feasibility Study. A single page of which is available here. This excerpt provides a well composed introduction to the Callahan site. The complete document is on file in the MDNR archive.
1983, September 21 – Remedial Investigation by Black & Veatch Engineers-Architects (Black & Veatch), dated September 21, 1983. Field activities included collection of seven soil samples (ELL-21 through ELL-25, ELL-31, ELL-32) and two surface water samples (ELL-26 and Ell-27). Results for surface soil samples from ELL-31 and ELL-32 (collected from the former drum staging areas) exceeded EPA residential RSLs for methylene chloride and oxirane. Surface water results were non-detect. Excerpts from the 1983 Remedial Investigation Report are available here. (Remedial Action Report 2012)
1984, July – August – The RI/FS for the Rosalie and Callahan property was released for public comment in July. On August 9th a public hearing was conducted for such recommended remedial alternatives. No opposition was voiced by the public. No written comments were received. Both alternatives at the Callahan site include removal of vestiges of the 1981-82 removal action. Priority pollutant contaminants were identified in the area of the 1981-82 removal action. (EPA Record of Decision 1985)
1985, July 10 – EPA issued the Record of Decision , Remedial Alternative Selection related to the Rosalie and Callahan Properties. Alternative C-2 was selected for the Callahan site. This alternative as outlined within the RoD will remove the vestiges of the 1982 clean up action and stabilize the fill area where the drums were previously removed. The fill area would then be covered with a 6 inch layer of compacted soil and seeded. There would be no O&M at the Callahan site. No Future Actions are outlined within the RoD. ‘All vestiges of past remedial activities and all materials posing a threat to the public health, welfare, or the environment will be removed from the properties. No future remedial activities are anticipated.’ Page 25 Paragraph 4.2.1 states ‘No 2,3,7,8 TCDD was detected in the sample.’ and 4.2.4 Summary ‘Based on the analytical results, there are no contaminated soils on the Callahan property.’ (EPA Record of Decision 1985)
1986 to 1987 – The Villages at Winding Trails subdivision in Wildwood was constructed on the land that was the former Rosalie Property. According to maps currently available 1908 Prospector Ridge, 556 & 570 Red Rock Drive, and 1904 Still Creek Pass were areas of former contamination. These lots are now residential homes and have been continuously occupied for the past 35+/- years. These properties were constructed only after completing the St. Louis County review and permitting process. (St. Louis County Dir of Revenue) and (Mundell 2010)
1987, February 11 – Missouri Department of Natural Resources ordered additional dioxin testing be performed at the Callahan site in this internal letter.
1987, February 24 – MDNR conducted sampling at the Callahan site. Two composite samples comprised of a total of 14 aliquots were submitted for laboratory analysis. Dioxin was not detected in the samples. (MDNR Report of Investigation Callahan Site Dioxin Sampling 1987)
1988 – Carriage Crossing Estates on Englebrook Court in Wildwood was constructed immediately adjacent to the Callahan site. The home at 1610 Englebrook was constructed within 50 feet of the drum removal area on land that was under control of the same individual that dumped waste at the Callahan site at the time the dumping occurred. These properties were constructed only after completing the St. Louis County review and permitting process. (St. Louis County Dir of Revenue) and (Mundell 2010)
1990s
1991, April 22 – The Missouri Department of Natural Resources provided Lisa Phillips, a neighbor to the Callahan property, a letter and Fact Sheet indicating there are no contaminants of concern present at the Callahan property. (Letter 1991)
1994, March 31 – EPA released the Federal Lien that had been in place on Real Property owned by Jean Ellen Callahan. (EPA Peterson 1994)
1999 – Brucker Engineering performed a Phase I Environmental Site Assessment and a Phase II ESA. including magnetometer survey. Samples were taken from the prior drum removal area, the two drum storage areas, the pond, the creek down hill from prior areas of concern, and areas around the barn. The study found no contaminants of concern except for in the area of the prior drum removal and subsequent fill. Here is the 1999 report from Brucker Engineering.
2000s
2005 Tetra Tech report that I was unable to obtain.
2005 MDNR Site Removal Evaluation Document that I was unable to obtain.
2005 MDNR Site Removal Evaluation Samples test results that I was unable to obtain as referenced by the HHRA in 2015.
2005, January 31 – February 2 – Tetra Tech START performed a magnetometer survey and monitored site activities for a Removal Site Evaluation (RSE) conducted by MDNR – including sampling of soil, sediment, and interior dust. A total of 29 soil samples and 5 sediment samples were collected in early 2005. A total of 34 soil samples were
collected. Dioxin, 8 RCRA metals, PCBs, semivolatile organic compounds (SVOCs) and volatile organic compounds (VOCs) were analyzed on one or more of the samples. Results exceeded the EPA’s April 2012 Regional Screening Level (RSL) Summary Table for soil at soil borings SB-25 (lead), SB-26 (bis-[2-ethylhexyl]phthalate), SB-27 (lead), SB-44 (benzo[a]anthracene, benzo[b]fluoranthene, ethylbenzene) and ditch grab #1 (arochlor 1248). (EPA 2012) (Tetra Tech Remedial Action Report 2012) The only contaminants of concern were identified in subsurface soils near the former drum burial area. (Tetra Tech 2005)
2005, August 25 – Tetra Tech produced a Removal Site Evaluation Report for the EPA. The report was made available to us as part 1 and part 2 of 2. The report includes testing results for the access road shoulders, the floor of the barn, the pond, and two drainage ways. Tetra Tech determined that based on test results follow up removal action may be warranted (The removal action was performed in Nov. 2012).
2008, May 1 – An unknown author produced this 2008 Wildwood Data Review for the City of Wildwood regarding the Strecker Forest site. There are several references to the Callahan site’s existing contamination in the fill soil near the drum removal area and the potential for ground water contamination. The contaminated soils referenced in this Data Review were later removed as part of the 2012 Remedial Action performed at the Callahan site and therefore are no longer of concern. (Tetra Tech Removal Action Report 2013)
2010s
2011, September – Tetra Tech performed surface soil sampling at the Callahan and Strecker Forest sites. All soil and groundwater samples were analyzed for SVOCs, RCRA metals, PCBs, and/or dioxin-related compounds. Three areas of concern were tested at the Callahan property including the area to the north of the barn and two areas to the west of the barn. With the exception of lead and chromium in the area that was later excavated, samples of surface soil, subsurface soil, and groundwater collected from the Callahan property did not exceed levels of concern for dioxins/furans, volatile organic compounds, semi-volatile organic compounds, metals, or PCBs. Additionally, a magnetometer survey was performed with exploratory trenching in areas of anomalies. Metal drum fragments were located in the area of the 1981 drum removal and were subsequently removed in 2012. (Tetra Tech Site Reassessment Report 2012) (2013 Removal Action Report)
2011, September 19 through October 18 – Three monitoring wells were installed on the Callahan property and three on the Strecker Forest property. All were drilled into bedrock to sample the uppermost aquifer. Well depths range from 98-168 feet. (2012 MDNR “Monitoring Well Installation Report)
2012, January 17 – MDNR published the “Monitoring Well Installation Report, Strecker Forest and Callahan Properties, Ellisville Site, St. Louis County, Missouri.“
2012, June 13th – Tetra Tech, as a contractor for the EPA, produced a Site Reassessment Report for an Expanded Site Review regarding the proposed Strecker Forest development site.
2012, September 13 – The EPA requested funding for immediate removal of contaminated soils in the vicinity of the previous drum removal area at the Callahan site. The last page of this document contains a site map showing original Remedial Action area. (EPA Action Memorandum Sept. 2012)
2012, November 29 – The EPA requested additional funding to continue removal action of contaminated soils in the vicinity of the 1981 drum removal area. The funding request increased the project ceiling from $152,550 to $553,664. (EPA Action Memorandum Nov. 2012)
2012, November 8 – Mundell & Associates created Technical Comments Regarding U.S. EPA Site Reassessment Report for an Expanded Site Review. This document is cited as showing existing contamination at the Callahan site. It is important to note this document was created prior to the 2012 remedial action performed at the Callahan site and therefore any concerns outlined within shall be invalid.
2012, November 12 through December 6 – Remedial actions (clean up of contaminated soils) were performed at the Callahan site by Environmental Restoration LLC. It is important to note any document created prior to December 2012 can not account for all remediation steps taken and therefore any concerns outlined within shall be discounted. RA activities included removal and disposal of contaminated soil, backfilling excavated areas, and site restoration. Summaries of analytical results are available in Appendix C of the 2013 Removal Action Report. Dump trucks were used to transport excavated contaminated soil to the Milam Landfill in IL. Real time PID and XRF readings were obtained. The final excavated area was approximately 21 feet long on the south, 75 feet on the east, 70 feet on the north, and 82 feet on the west. The depth of the excavated area ranged from 5 to 15 feet (down to bedrock). A total of 2,056 tons of contaminated soil was removed. Seven post excavation samples were collected from the perimeter of the excavation area. The highest PID reading was 2.0 PPM and XRF readings for lead ranged from 86-908 PPM. See page 5 of the report for addition details. The topsoil and backfill materials tested below RSLs except for arsenic. However, all arsenic results were below average background levels for St. Louis County soils. Page 8 of the 2013 Removal Action Report report states “No conditions are known to exist that would warrant further removal activities.” (Removal Action Report 2013)
2013, April 16 – Tetra Tech provided the EPA with the 2013 Removal Action Report. The report indicates all contaminants of concern were removed from the Callahan site during the late 2012 remedial action and that confirmatory testing was performed. “No conditions are known to exist that would warrant further removal activities.” (Removal Action Report 2013)
2014, August 15 – MDNR wrote the EPA in support of the partial deletion of the Callahan property (OU3) from the Ellisville NPL site. MDNR concluded that “Based on the available information, that the two removal actions performed at the Callahan property have resolved all concerns resulting from contamination that was placed at the property. We [MDNR] believe this [returning of the Callahan property to a condition which is suitable for any proposed future use without need for institutional controls] is a significant accomplishment for the EPA and the Department” (MDNR letter to EPA 2014)
2015, June 22 – The EPA released a Memorandum containing a Limited Human Health Risk Assessment (HHRA). The HHRA examined data from five data sets: 1) 1982-83 data collected after the 1982 removal action, 2) the 1999 samples from Brucker, 3) 2005 samples from the MDNR Sire Removal Evaluation, 4) 2011-2012 data collected for the Expanded Site Review, and 5) the 2012 confirmation data collected after the 2012 removal action. The HHRA concluded “that sufficient data are available from the five sampling events to characterize current conditions.” Concentrations of lead in surface soil are all well below RSL. Chromium exceeded the level of concern in some samples however there are two types of chromium. The RSL assumes 100% of the chromium is in the Hexavalent form rather than trivalent form which is a naturally occurring and essential element in humans. (EPA 2000) The dangerous Hexavalent form was not found during chromium speciation done on the property in 2012. The report concluded that contaminants of concern that may remain the surface and subsurface soils “are below a level of concern for all potential uses of the property, including residents.” (Memorandum HHRA 2015)
2015, August 6 – Tetra Tech provided the EPA the Removal Action Report for the remedial clean up actions performed at Strecker Forest in March – July of 2014. This report does not pertain to the Callahan property but I listed it here because other sources later incorrectly reference this report while discussing the 210 Strecker Rd property (the former Callahan Property).
2015, Aug 25 – The City of Wildwood prepared this letter to the EPA outlining resident’s concerns at the Callahan site. The EPA responded on 12/9/15 as can be found here. These concerns are further addressed in the 2017 Responsiveness Summary which outlines that almost 50 samples from the Callahan site were tested for dioxin but it was never detected. There were 33 samples tested for PCBs and all were below any screening level of concern. A ground water investigation in 2011 tested for dioxin, PCBs, VOCs, SVOCs, and metals including lead. All groundwater samples were non-detect for contaminants of concern. (Responsiveness Summary 2017)
2015 December 9th – The US EPA responded to this letter that outlined concerns that were voiced by Wildwood residents. The EPA issued this response to the City Letter. The EPA outlined that there were 5 sampling events that took place at the Callahan property. These sampling events provided sufficient data for the EPA. (Letter from EPA to Wildwood 2015)
2015 or 2016 – The EPA published the Notice of Intent for Partial Delisting (NOIPD) regarding the Callahan property. On 02/22/2016, The EPA mailed a Compact Disc containing documents supporting the Notice of Intent for Partial Delisting (NOIPD) to the Daniel Boone Branch (the site repository). They are currently located at the SLCL Headquarters.
2016, March 08 – The EPA published the Notice of Intent to Delete for the Callahan subsite in the Federal Register. 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. Twenty-five written comments were received before the closing date for comments on May 18, 2016. Many of the public comments can be found here. (EPA Responsiveness Summary 2017)
2016, March 14 – Environmental Stewardship Concepts produced this report for the City of Wildwood regarding the Bliss/Strecker Forest site. In the report ESC states they evaluated documents produced after the removal action performed at the Bliss/Strecker Forest site in 2014. The ESC report then later incorrectly references contaminate levels at the Bliss site as being at the Callahan site. ESC also references chemicals identified during a 2011 well installation. This well was installed in an area that was later excavated to bedrock and extensively tested during the 2012 remediation. (MDNR 2012) and (2013 Removal Action Report)
2016, March 25th – The EPA published a Notice of Intent for Partial Deletion (NOIPD). This formally announced the EPA’s declaration that the Callahan site is ready for reuse and that “all appropriate response actions at the Callahan property, OU3, under CERCLA, have been completed.” (St. Louis Post Dispatch 2016)
2016, April 18 – Wildwood drafted this letter to the EPA opposing the delisting of the Callahan subsite based on the EPA’s alleged failure to meet threshold criteria. In the letter several issues are raised. 1) The letter references “Item 7: Dioxin Results”. However, at no time has Dioxin been found at the Callahan property although almost 50 samples have been tested (EPA 2017). 2) The letter references “Item 10: Impacts Downslope”. Groundwater testing and surface water tests have produced no contaminants of concern (Tetra Tech 2013). 3) The letter also mentions “concerns Mundell raised” in his 2012 report. The 2012 report was produced PRIOR to the 2012 remediation at the Callahan site. Areas of concern in the Mundell report were address in the 2012 Remedial Action when over 2,000 tons of soil was removed. (Removal Action Report 2013)
2016, August 25 – The City of Wildwood prepared a “White Paper“. To date the City of Wildwood has not complied with our request to provide documentation supporting the opinions outlined within the document. You can click here for documentation refuting the opinions outlined within the white paper.
2016, August 26 – The EPA produced a power point presentation that is available here. This presentation provides information regarding the planned deletion of the Callahan site from the NPL. The presentation includes letters of support from MDNR and Mo Atty General. (EPA Power Point 2016)
2017, May 22 – The EPA produced the Responsiveness Summary to provide responses to comments submitted to the EPA during the 60-day public comment period. In the Responsiveness Summary the EPA provides supporting evidence that the Callahan subsite is safe and therefore should be removed from the NPL. Almost 50 samples from the Callahan site were tested for dioxin but it was never detected. There were 33 samples tested for PCBs and all were below any screening level of concern. A ground water investigation in 2011 tested for dioxin, PCBs, VOCs, SVOCs, and metals including lead. All groundwater samples were non-detect for contaminants of concern. Details of these tests are available in the Site Reassessment Report dated June 13, 2012 . The summary states that an extensive investigation of the Callahan subsite has been conducted that included investigating the barn. 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.” (EPA Responsiveness Summary 2017)
2017, July 17 – The US EPA published the Final Rule officially deleting the Callahan subsite from the National Priorities List. The Federal Register excerpt is available here.
2019, October 28 – Tetra Tech produced this Phase 1 Targeted Brownfields Assessment for the EPA. In this report Tetra Tech concluded “Based on results of this Phase I TBA, the HREC related to the property does not warrant further investigation prior to residential development.“
2020s
2020, November 30 – Geotechnology performed a Phase 1 Environmental Site Assessment. Geotech was paid by Wildwood to investigate an area along the north property line of the Callahan site that is the proposed site for a sidewalk. Geotech repeatedly and incorrectly referenced studies performed at the Bliss & Strecker Forest site and attributed contaminants at that site to the Callahan site.
2021, February 19 – Environmental Works performed a Phase 1 Environmental Site Assessment. The ESA included both the former Callahan site (210 Strecker) and the residential property to the east at 162 Strecker Rd. Environmental Works stated the Callahan property no longer posed unacceptable human risk for current or future exposure scenarios. On this basis, the Site’s identification as the Callahan Property associated with the Ellisville NPL Site is considered an HREC. (Environmental Works ESA 2021)
2021, June 7 – The City of Wildwood had a public hearing regarding several properties considered for inclusion into the Wildwood SCOD. The 210 Strecker property and several adjacent properties are included on this list. At this hearing Wildwood resident and environmental expert, Keith Piontek, presented. Mr. Piontek determined there is no evidence to support claims that the Callahan property is not safe for unrestricted use. (Piontek 2021) You can watch his testimony here. An additional 10 people spoke in person and 3 spoke via web in opposition of the application of the SCOD to one or more properties. No one spoke supporting the application of the SCOD.
2021, June 23 – Environmental Operations, Inc. was asked to review the documentation related to the former Callahan site. EOI concluded “no remaining environmental concerns exist at the property and that the property requires no additional investigation, no further remedial actions, no institutional controls, and no continued monitoring to be suitable for unlimited use and unrestricted exposure.” (EOI Memorandum 2021)
2021, June 30th – The Environmental Protection Agency produced a ‘Comfort Letter’ for the 210 Strecker Road property. In the letter the EPA outlines that “no further investigatory or cleanup action was warranted at Operable Unit 3.” Operable Unit 3 refers to the former Callahan, 210 Strecker Rd, site. The June 2021 letter is available here.
2021, September 01 – The Environmental Protection Agency met with Wildwood administrators via a virtual meeting. Laura Price for the EPA provided this copy of the EPA’s presentation including the current site boundary.
2021, August 19th – Letter from EPA to City of Wildwood to answer several questions the City had regarding the Callahan Property and the greater Ellisville Superfund Site. In the letter the EPA stated “the former Callahan property has been cleaned up to a standard suitable for unlimited use and unrestricted exposure.” and “EPA does not believe any further testing is needed for the former Callahan Subsite. Here is a copy of the August 19, 2021 Letter to Wildwood.
210 Strecker Road - Marquart Stables 