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Review of Final Remedy Decision



Statement of Issues

The Missouri Department of Health and Senior Services, in cooperation with the Agency forToxic Substances and Disease Registry, has prepared this health consultation at the request of theU.S. Environmental Protection Agency to review the health protectiveness of the final remedychosen for the TRW, Inc. (a.k.a. TRW- Sullivan Facility) Site.


From 1950 until 1983, TRW, Inc. (TRW) operated an automobile piston manufacturing facilityat 300 Ramsey Street in Sullivan, Franklin County, Missouri (1). The site encompassesapproximately 7 acres (1). A chrome plating system was operated at the facility and variousorganic solvents and petroleum-based products were used (1). In 1987, the facility was sold toSullivan Warehousing, Inc. and Sister Property, Inc. (1). Manufacturing operations continue atthe facility (1).

On April 1, 1993, TRW and the current owners entered into an Administrative Order on Consent(AOC) with the EPA (1). Since 1983, TRW has performed voluntary investigations andremediation activities at the facility (1). During the corrective action process, four interimmeasures plans were completed which include the groundwater monitoring plan, the surfaceimpoundments soils report, the drinking water contingency plan, and the pump and treatmentplan (2).

Historically, people were exposed to contaminated soils, surface water and groundwater at theTRW site. Based upon the data collected during a Resource Conservation and Recovery Act Facility Investigation (RFI) and associated health-based risk assessment studies, it was concludedthat groundwater was the current primary exposure pathway for facility-related contaminants (2).Confirmatory sampling was conducted to assure that soil excavations at contaminant source areashave adequately removed surficial soils and sediment that were above the soil action levels(SALs) at the facility (2). The SALs used at this site were protective of public health. In all casesthe action levels were lower than the Missouri Any Use Soil Levels (ASLs) and the ATSDREnvironmental Media Guidelines (EMEGs). The deep soil boring installed and sampled duringthe RFI did not indicate the presence of the contaminants of concern above the SALs (2). Therefore, soils are no longer part of an exposure pathway of health concern at this site. Surfacewater and sediment sampling conducted along Winsel Creek, which runs west of the formerTRW facility, also did not indicate the presence of the primary contaminants of concern aboveapplicable soil or groundwater regulatory guidance criteria (2). Therefore, surface water andsediments are no longer part of an exposure pathway of health concern at this site.

The RFI confirmed the presence of facility-related contaminants in groundwater above applicablegroundwater regulatory guidance criteria and assessed the horizontal and vertical extent of thegroundwater contamination caused by releases from the former TRW facility (2). To date, TRWhas installed a total of 41 monitoring wells at shallow (150 feet), intermediate (350 feet), anddeep (550 feet) levels on and surrounding the facility property, and has conducted geophysicallogging of the subsurface in selected monitoring wells (2). The RFI activities also determinedthat the primary contaminants of concern (trichloroethylene, 1,2-dichloroethene, 1,2-dichloroethane, lead and chromium) were present above applicable groundwater regulatoryguidance criteria at various depths within the aquifer that serves as the water supply for the cityof Sullivan (2). At present, there are no known completed exposure pathways to contaminateddrinking water above regulatory standards associated with this site. There are potential futureexposure pathways to the contaminated groundwater aquifers, but they are unlikely to occur. Thecity of Sullivan and TRW both sample and monitor drinking water supply quality from the city ofSullivan's wells to assure that the water supply meets State Water Quality Standards (2). Thecity and TRW provide quarterly monitoring reports to federal and state officials (2). In addition,numerous plans are already in place to protect the private and public drinking water supplies toassure that future exposures do not occur. These include deed restrictions, city of Sullivanordinances, pump and treat systems, and continued monitoring and sampling.

The proposed Groundwater Protection Standards, which are clean-up levels to be set forth in thestate-issued consent order (final remedy), are shown in Table 1 (2). The lead and chromiumconcentrations shown on Table 1 are total metals concentrations based on unfiltered groundwatersamples (2).

Table 1.

Groundwater Protection Standards for the TRW Facility (2)
Chemical Constituent Maximum Contaminant Level (ppb) Regulatory Basis
Barium 2000 a, b
Chromium 100 a, b
Lead 15 a, b
1,2-Dichloroethane 5 a, b
1,1-Dichloroethene 7 a, b
Cis-1,2-Dichloroethene 70 a, b
Trans-1,2-Dichloroethene 100 a, b
Trichloroethylene 5 a, b
Vinyl Chloride 2 a, b

a -Denotes limits obtained from state (10 CSR 60 Chapter 4) and federal public drinking water regulations, November 1997.
b - Denotes limits obtained from Missouri Water Quality Standards (10 CSR 20-7.031) for protection of groundwater, March 1994.

The proposed remedy contains seven components that TRW must carry out (2). Thesecomponents will be included as a part of the AOC (2). Two of the seven components pertain toprotection of public health (2):

  • Continuation and revision of the groundwater monitoring plan and drinking watercontingency plan that were previously developed under the federally issued consent order. This will include:
    • Detection and delineation of the horizontal and vertical extent of groundwatercontamination.
    • Determination and documentation of representative concentrations ofcontaminants of concern.

  • Preparation of a corrective measure work plan that addresses the necessary actions for theeffective and efficient implementation of the final remedy. This will include:
    • Identification of the extent of the contamination plume by installing three or moreadditional monitoring wells at various depths.
    • Detail of the design, location and installation schedule for an on-site,intermediate-depth recovery well to be incorporated into their ongoing shallowgroundwater recovery and treatment system.
    • Placement of groundwater use restrictions (deed restrictions) in the propertychain-of title prohibiting the installation of wells for domestic or industrial use onthe former TRW property.
    • Detailing of the design documents for water treatment systems installed, or in theprocess of being installed, on Municipal Wells No. 2 and No. 8 (both currentlyclosed).


Groundwater contamination at depth is currently the primary area of concern at the TRW site. Past corrective actions have removed contamination sources in soils. The final remedy requires apump and treat system for the intermediate groundwater aquifer. The pump and treat system willbe added to the system already in place for shallow groundwater. This will assist in the removalof contaminants from groundwater in these zones. The final remedy calls for continuedmonitoring of the deep groundwater aquifer that serves the city of Sullivan. Because nocompleted exposures are known to be occurring, and potential exposures have been addressedand are unlikely, the final remedy is protective of public health.


Upon review of the final remedy, it was determined that children and sensitive populations arenot impacted by this site more than any other group of people that may be exposed tocontaminants. Therefore, there are no increased risks for adverse health effects to children orsensitive populations at this site. A sensitive population will exhibit a different or enhancedresponse to hazardous chemicals than will most persons exposed to the same level of hazardouschemicals in the environment. Reasons may include genetic makeup, age, health and nutritional status, and exposure to other toxic substances. In general the elderly, with declining organfunction and the young, with immature and developing organs, will be more vulnerable to toxicsubstances than healthy adults (3).


Based on available data, and likely exposure scenarios, DHSS has determined that the proposedfinal remedy for the site is protective of public health and that the site poses no public healthhazard. This is based on the following conclusions:

  1. There are no current completed exposure pathways to groundwater.
  2. The final remedy includes several plans and contingencies to protect public and privatedrinking water supplies, which will eliminate the potential for completed pathways in thefuture.


Proceed with the final remedy at the TRW, Inc., site.


This public health action plan (PHAP) for the TRW, Inc. site contains a description of actions to be taken by the Missouri Department of Health and Senior Services (DHSS), the Agency forToxic Substances and Disease Registry (ATSDR), and others. The purpose of the PHAP is toensure that this health consultation not only identifies public health hazards, but also provides an action plan to mitigate and prevent adverse human health effects resulting from past, present,and/or future exposures to hazardous substances at or near the site. Included is a commitmentfrom DHSS and/or ATSDR to follow up on this plan to ensure that it is implemented. Thepublic health actions to be implemented by DHSS, ATSDR, and/or cooperators are as follows:

Ongoing Activities

  1. DHSS/ATSDR will coordinate with the appropriate environmental agencies tocontinue to address community health concerns as they arise and provide health educationas needed.
  2. DHSS/ATSDR will continue to monitor the data from the public water supply from thecity of Sullivan.
  3. DHSS/ATSDR will continue to work with the appropriate environmental agencies toprovide technical assistance as necessary.

Future Activities

  1. DHSS/ATSDR will attend future public meetings and availability sessions to meetwith community members, address their health concerns and provide health education asneeded.
  2. DHSS/ATSDR will evaluate any further data that becomes available about humanexposures or contaminants at this site.


Sara Colboth, Gale Carlson, Missouri Department of Health and Senior Services.


  1. O'Brien and Gere Engineers, Inc. Final report, RCRA facility, TRW Inc., SullivanMissouri. Syracuse, NY: O'Brien and Gere Engineers Inc.;1997, Mar.
  2. US Environmental Protection Agency. Final remedy decision. TRW, Inc. Sullivan,Missouri, Washington DC: US Environmental Protection Agency; 2001 Sep.
  3. Agency for Toxic Substances and Disease Registry. Toxicological Profile for Trichloroethylene, update. Atlanta: US Department of Health and Human Services; 1997 Sep.


This TRW, Inc. site health consultation was prepared by the Missouri Department of Health andSenior Services (DHSS) under a cooperative agreement with the Agency for Toxic Substancesand Disease Registry (ATSDR). It is in accordance with approved methodology and proceduresexisting at the time this health consultation was initiated.

Roberta Erlwein
Technical Project Officer, SPS, SSAB, DHAC

Richard Gillig
Section Chief, SPS, SSAB, DHAC, ATSDR

Table of Contents The U.S. Government's Official Web PortalDepartment of Health and Human Services
Agency for Toxic Substances and Disease Registry, 4770 Buford Hwy NE, Atlanta, GA 30341
Contact CDC: 800-232-4636 / TTY: 888-232-6348

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