Hazardous Waste Program
Nestle Purina PetCare Co.
EPA ID# MOD000302281
DNR Contact: Christine Kump-Mitchell, PE, 314-416-2464 or 800-361-4827
EPA Contact: Christine Jump, LG, 913-551-7141 or 800-223-0425
Facility Contact: Steve Luthy, 314-982-2259
Last Updated: Jan. 16, 2014
- Former Company Name: Robinson-Danforth Commission Co., Raslton Purina Co.
- Type of Facility: Former Interim Status Hazardous Waste Storage – closed.
- Wastes Handled: corrosives, flammables, household hazardous wastes, pesticides and herbicides, petroleum-contaminated wastes, solvents, and used oil, as well as various P- and U-listed hazardous wastes.
- Treatment and Disposal Methods: None.
- Location of hard copies of hazardous waste permit application, reports, etc. and supporting documents:
Approved Remedy Issued: On Jan. 15, 2014, the department approved the proposed remedy of no further corrective action with institutional and engineering controls at the Nestle Purina PetCare Co. facility. As a result of that approval, the department is releasing the facility from regulation as a former interim status hazardous waste treatment, storage and disposal facility subject to the corrective action requirements of the Missouri Hazardous Waste Management Law and regulations. The department’s approved remedy and regulatory release decisions are effective immediately.
The public can review and copy the supporting documents at the St. Louis Public Library’s Central Library, 1301 Olive St., St. Louis, Missouri (during normal business hours) or the agency locations above. There were no comments made on the proposed remedy or regulatory release during the public comment period. Any parties adversely affected or aggrieved by the department’s decision to approve the remedy or regulatory release may be entitled to pursue an appeal before the Administrative Hearing Commission by filing a written petition by Feb. 14, 2014, according to the procedures outlined in Code of State Regulations 10 CSR 25-2.020 and Missouri Revised Statutes, Sections 260.395.11 and 621.250, RSMo. If the petition is sent by registered mail or certified mail, it will be deemed filed on the date it is mailed. If it is sent by any other method, it will be deemed filed on the date it is received by the Administrative Hearing Commission. Appeals must be sent to the Administrative Hearing Commission, Truman State Office Building, Room 640, 301 West High Street, P.O. Box 1557, Jefferson City, MO 65102, or by fax to 573-751-5018. The department also asks that a copy of the petition be provided to the Missouri Department of Natural Resources, ATTN: Hazardous Waste Program Director, P.O. Box 176, Jefferson City, MO 65102-0176, or by fax to 573-751-7869.
The Nestle Purina PetCare Co. site is located at Checkerboard Square in St. Louis. The company began in 1894 as the Robinson-Danforth Commission Co. and produced horse and mule feed. A tornado destroyed the original mill in 1896, which is believed to have been located close to the present site. In 1898, the company began manufacturing whole wheat cereal, endorsed by Dr. Ralston. In 1902, the company changed its name to Ralston Purina Co.
Ralston grew and expanded into the manufacturing of many types of human and pet foods. Ralston’s operations have included the use of a feed mill, grain elevators, offices, research facilities and research and testing laboratories. As part of the research facilities, Ralston operated an interim status hazardous waste container storage area for lab waste produced at the research and testing laboratories. The container storage area had a sunken concrete floor covered with a one-fourth inch thick, sparkproof and watertight epoxy coating. The area had the capacity for 29 fifty five-gallon drums and was used to consolidate and store characteristic and listed hazardous waste before shipping off site to a permitted treatment, storage and disposal facility. These hazardous wastes included items such as unused reagents, testing samples, contaminated glassware and spent solvents. Ralston closed the container storage area in 1996 and continued operating as a large quantity hazardous waste generator.
During their expansion, Ralston also purchased additional properties from various nearby businesses; such as retail sales, a stove manufacturer, several service and filling stations and a truck service center. In 2001, Ralston merged with Nestle and became Nestle Purina PetCare Co. Nestle Purina now covers about 50 acres and continues to manufacture and sell pet care products.
Closure and Corrective Action Status
According to applicable state and federal hazardous waste laws and regulations, all hazardous waste treatment, storage and disposal facilities are required to investigate and clean up releases of hazardous waste and hazardous constituents to the environment at their facility resulting from present and past hazardous waste handling practices. This includes the additional property Ralston purchased during expansion. Potential hazardous waste produced by Ralston’s many operations likely include insecticides, fumigants, grease and oil, in addition to the laboratory wastes. Potential hazardous waste produced by the companies that operated on property Ralston purchased include, among other things, adhesives, varnish, stain, dyes, inks, paint, spent solvents, waste oils, heavy metal dust, ignitable sludge, waste cutting fluids, sulfides, polyaromatic hydrocarbons and phenols.
A Resource Conservation and Recovery Act, or RCRA, Facility Assessment was conducted for the site to identify and gather information on actual and potential releases of hazardous waste and hazardous constituents to the environment. The assessment was prepared in two phases. CDM Federal Programs Corp. performed the Preliminary Assessment in March 1992, on behalf of EPA. The 1993 RCRA Facility Assessment Report, prepared by PRC Environmental Management Inc., on behalf of EPA, identified four areas of concern that EPA recommended for more investigation. Following the assessment and a visual site inspection, two additional areas of concern were identified by the department for further investigation. Ralston acquired three additional properties after the 1993 assessment that also needed additional investigation.
In January 1995, Burns & McDonnell Waste Consultants Inc. submitted a closure plan to the department, on behalf of Ralston, for the hazardous waste container storage area. The department approved Ralston’s closure plan in January 1996. Closure of the hazardous waste container storage area occurred in February 1996 and included cleaning the surfaces followed by three rinses and sampling of the final rinsate and concrete floors. The department accepted Ralston’s closure report and certification for the hazardous waste container storage area in September 1996. Ralston repaired the floor from the concrete sampling and the room was returned to service as a temporary storage room for containers of hazardous waste before shipping off-site for disposal. Since the waste was stored for less than 90 days, the storage room was not required to be permitted. Instead, Ralston was required to follow hazardous waste generator regulations.
In December 2004, the department notified Nestle Purina (formerly Ralston) that they were required to perform corrective action, or cleanup, under RCRA and Missouri’s hazardous waste law and regulations and obligated to address the nine previously identified areas of concern. In response to the letter, Burns & McDonnell, on behalf of Nestle Purina, submitted an updated RCRA Facility Assessment Report to the department on July 28, 2006. The updated assessment included additional information on the nine areas of concern and concluded that six of the areas did not require further action at that time.
In November 2007, the department requested that Nestle Purina submit additional information on the three areas of concern that required additional investigation: former grain elevator/storage bins, former Magic Chef and former truck service center. The department also agreed with Nestle Purina’s conclusions that the other six areas of concern did not require further action. Nestle Purina submitted the additional information in March 2008. Nestle Purina also requested no further investigation at the truck service center and presented a scope of work for soil investigation activities at the former grain elevator/storage bins and Magic Chef areas. In April 2008, the department approved the scope of work and determined that the additional information regarding the former truck service center was acceptable and no further investigation was necessary for that area.
There are no known releases of contamination to groundwater at the site. In July 2008, Nestle Purina sampled the soil at the former grain elevator/storage bins and Magic Chef areas. In February 2009, Burns & McDonnell submitted an RFA Soil Investigation Report to the department, on behalf of Nestle Purina. The soil sample results were below the screening levels for protection of groundwater. Based on the sample results from the Magic Chef area, no further action was determined to be necessary in this area. In the former storage bins/grain elevator area, Toxaphene was the only pesticide detected above screening levels for residential use and industrial use. Several semi-volatile organic compounds were detected above screening levels for industrial use; however, the crushed asphalt within the fill beneath the surface of the parking lot, and present in the samples during collection, was determined to be the likely source. The 2009 report proposed implementing Activity and Use Limitations for the former storage bins/grain elevator area. The department approved the RFA Soil Investigation Report on June 24, 2009.
Ultimately, the department determined that there are no significant releases from the solid waste management units and areas of concern to the soil and groundwater at the Nestle Purina facility and no further corrective action was necessary. On Jan. 15, 2014, the department approved the proposed remedy of no further corrective action with institutional and engineering controls. The institutional and engineering controls are in the form of an enforceable Environmental Covenant containing certain property activity and use limitations for the facility, including specific limitations related to the former grain elevator/storage bins area. The Environmental Covenant was executed by the department and Nestle Purina and filed with the St. Louis City Recorder of Deeds on Sept. 26, 2013. The Environmental Covenant prohibits residential use of the facility property, prohibits disturbance of the soil in the former Grain Elevator/Storage Bins AOC without written approval from the Department, requires maintenance of the existing asphalt cap in the former Grain Elevator/Storage Bins AOC and continued compliance with the City of St. Louis Ordinance #66777. The City of St. Louis Ordinance #66777 prohibits the use of groundwater and drilling of wells for a potable water supply. These restrictions will ensure that unacceptable exposure to residual contamination do not occur in the future.
Ralston Purina operated the hazardous waste container storage area under the interim status portions of the federal and state hazardous waste laws and regulations, 40 CFR Part 265 and 10 CSR 25-7.265. When Congress passed the federal hazardous waste law in 1980, all existing facilities that treated, stored or disposed of hazardous waste in a manner that would necessitate a hazardous waste permit were required to get such a permit. Because of the large number of existing facilities, Congress set up requirements which allowed these facilities to operate temporarily under “interim status” until they received their permit.
Ralston submitted their RCRA Part A permit application on Nov. 13, 1980, and Part B on Oct. 24, 1988. In 1995, Ralston decided not to continue the hazardous waste permitting process and to close the hazardous waste container storage area, the only hazardous waste management unit included in their permit application. Nestle Purina (formerly Ralston) was not subject to the permitting requirements of the Missouri Hazardous Waste Management Law or federal Hazardous and Solid Waste Amendments for post-closure care because they “clean closed” the interim status hazardous waste management unit.
Nestle Purina was subject to corrective action because they completed closure of the interim status hazardous waste management unit after the effective date of the federal Hazardous and Solid Waste Amendments. The department determined that Nestle Purina adequately addressed all issues associated with solid waste management units and areas of concern. On Jan. 15, 2014, following required public notice and opportunity for comment, the department approved the proposed remedy of no further corrective action with institutional and engineering controls. As a result of that approval, the department released the facility from regulation as a former interim status hazardous waste treatment, storage and disposal facility subject to the corrective action requirements of the Missouri Hazardous Waste Management Law and regulations, effective immediately.