Hazardous Waste Program

Holcim (US) Inc./Geocycle, LLC

EPA ID# MOD029729688

DNR Contact:      David Walker, 573-751-3553 or 800-361-4827
EPA Contact:      Mary Reilly Grisolano, 913-551-7657 or 800-223-0425
Facility Contact:  Dennis Fox, 573-242-3571            
Last Updated:      February 18, 2014

Current Activities

Class 3 Permit Modification Request Received: On Jan. 29, 2014, Holcim (US) Inc./Geocycle, LLC submitted a Class 3 Permit Modification request to the the Missouri Department of Natural Resources, requesting to modify their existing Missouri Hazardous Waste Management Facility Part I Permit. Holcim/Geocycle is proposing to modify their current hazardous waste permit to remove approximately 3070 acres of the site from jurisdiction under the hazardous waste permit.

Holcim/Geocycle held a public meeting about the permit modification request on March 12, 2014. The department accepted written comments on the permit modification request until March 30, 2014. The department is conducting a technical review of the permit modification request. The public can review and copy the Part I Permit Modification request and supporting documents at the Clarksville City Hall, 111 Howard St., Clarksville, Missouri (please call ahead to 573-242-3336) or at the agency locations above.

Facility Description

The Holcim/Geocycle site is located on about 3,600 acres at 14744 Highway 79 North, two miles north of Clarksville. In 1965, Dundee Cement Co. built the facility and began operating a cement plant at the site in 1967. The facility included a 760-foot wet process rotary cement kiln, numerous manufacturing structures, shipping facilities, an active quarry and other associated supporting activities. The kiln produced clinker, the main ingredient in Portland cement. The cement production process involved crushing and grinding raw material; such as limestone and shale; into a fine dust. Dundee then wet milled the raw materials by mixing the dust with water to form a slurry. The slurry was fed into the kiln and heated to the point to remove the water and start the chemical reaction that makes clinker. The clinker was then ground with gypsum to make cement.

Large amounts of fuel were used to produce the high temperatures needed for cement production. Dundee used mainly coke/coal and fuel oil to heat the kiln system. To supplement its fuel needs, Dundee also used non-conventional fuels, such tires and other non-hazardous materials. In 1986, Dundee and McKesson Envirosystems jointly developed a supplemental fuels-blending program for the plant, involving a variety of liquid and solid hazardous waste-derived fuels, such as spent industrial chemical and petroleum-related materials. The department allowed Dundee to modify the fuel firing system in the kiln to use the supplemental fuel. The waste fuel program was in operation by fall of 1986.

McKesson operated the hazardous waste receiving and blending facility, located on a 2.1-acre plot, owned by Dundee, at the facility. The hazardous waste came from off-site hazardous waste generators or third party hazardous waste blenders or brokers. McKesson received, sampled, off-loaded, stored and processed the liquid and solid hazardous wastes received at the facility. The liquid hazardous wastes were “blended” with other hazardous waste to achieve desired fuel characteristics, such as BTU value and metals and chlorine content. The resulting wastes were stored in a hazardous waste storage tank, owned by Dundee, until fed to the rotary kiln as liquid fuel. The hazardous waste was stored under the “interim status” portions of the federal Resource Conservation and Recovery Act (RCRA) until permits were issued in 2000.

In April 1987, Safety-Kleen Corp. purchased McKesson’s Clarksville operation. In 1990, Dundee merged with Holderbank, who later organized all its operations in the United States under the corporate name of Holnam Inc. The Clarksville plant’s name was changed to Holnam Inc./Safety-Kleen.

A byproduct of the cement production process is a fine chalky powder waste known as cement kiln dust. The kiln dust was moved from the rotary kiln to a pug silo, which was a steel above ground storage tank. Holnam added water to the kiln dust at the silo, for dust suppression. The cement kiln dust was then transported to the on-site landfill by a belt-type assembly, which extended from the tank to an unloading area. The on-site landfills were former quarries where raw material was mined. Holnam regularly tested the dust to make sure it was exempt from being classified as a hazardous waste.

In December 2001, Holderbank organized its operations globally under the corporate name of Holcim Inc. In July 2003, Holcim purchased the Safety-Kleen operations and formed Energis LLC, which changed its name to Geocycle LLC in September 2007. The fuels receiving, blending and shipping areas were operated by Geocycle on land owned by Holcim. In total, Geocycle operated two hazardous waste container storage areas: a tank truck storage facility, with a maximum capacity of 52,000 gallons, and a railcar storage facility, with a maximum capacity of 64,000 gallons; ten 40,000-gallon hazardous waste blend tanks and seven miscellaneous hazardous waste treatment units: four grinder pumps, one attrition mill and two tank truck and railcar washout units. Holcim stored and treated the hazardous waste in one 150,000-gallon and two 250,000-gallon hazardous waste burn tanks.

On March 23, 2010, the department, Attorney General’s Office and Holcim/Geocycle entered into a Settlement Agreement, allowing Holcim/Geocycle to place the facility in an “idle” state while Holcim/Geocycle evaluated potential options related to future facility operations. During the “idle” state, Holcim/Geocycle did not receive, store or blend hazardous waste. On Feb. 15, 2012, Holcim/Geocycle notified the department and EPA that the facility was closing. The facility property is currently inactive except for on-going corrective action activities.

Closure and Corrective Action Status

All hazardous waste treatment, storage and disposal facilities are required to investigate and clean up hazardous waste releases at their facility resulting from present and past hazardous waste handling practices. In 1991, PRC Environmental Management Inc. performed a Resource Conservation and Recovery Act, or RCRA, Facility Assessment for the site, on behalf of EPA. The assessment was conducted to identify and gather information on actual and potential releases of hazardous waste and hazardous constituents to the environment. The 1992 RCRA Facility Assessment Report identified five solid waste management units and two areas of concern that were recommended for more investigation.

In response to the assessment, and as part of Holnam’s permit application review process, the department conducted a site visit in March 1997 to observe and evaluate the solid waste management units and areas of concern identified for additional investigation. The department also evaluated the information contained in the assessment report, department’s files and supplemental sampling results provided by Holnam. In October 1997, the department determined no further action was required for the sludge pond at that time. Holnam built a new cement storage dome in the sludge pond area. In August 1998, the department determined the need for additional investigation of the remaining areas was not evident at that time.

Holcim/Energis, formerly Holnam, closed the attrition mill in 2006 according to their department-approved closure plan. The department accepted Holcim/Energis’ closure report and certification in November 2006. Holcim/Geocycle closed the hazardous waste management facility in March 2009, which included the hazardous waste fuel facility, cement kiln and hazardous waste fuel feed system piping. The department accepted Holcim/Geocycle’s closure report and certification on October 23, 2009.

Closure activities for the remaining hazardous waste management units began in July 2012. All concrete and metal associated with the tank truck storage facility, railcar storage facility, hazardous waste blend tanks and miscellaneous hazardous waste treatment units was decontaminated and the metal was sent for scrap metal recycling. Closure confirmation sampling results indicated residual contamination, consisting of polycyclic aromatic hydrocarbons, was present in two areas. No post-closure activities were required; however, the levels resulted in a determination to restrict future use of this area to industrial use only. A Deed Notice, signed by the Pike County Register of Deeds on April 19, 2013, was placed on the property in order to inform potential future buyers of the property that the site had been used to manage hazardous wastes. The department accepted Holcim/Geocycle’s closure report and certification for the remaining units on July 5, 2013.

Holcim is currently performing additional corrective action activities at the site, including further investigation into the remaining solid waste management units and areas of concern. What, if any, corrective action, or cleanup, activities necessary will be based on the investigation results.

Regulatory Status

Holcim/Geocycle operated under two hazardous waste permits, one issued by the department and one issued by EPA. The department issued the Missouri Hazardous Waste Management Facility Part I Permit, effective May 2, 2000. EPA issued the Hazardous and Solid Waste Amendments Part II Permit, effective June 16, 2000. These permits allowed Holcim/Geocycle to store and treat “characteristic” hazardous waste, as well as various F-, K- P- and U-listed hazardous wastes as specified in the Part A application. The regulated units consisted of a tank truck storage facility, a railcar storage facility, ten hazardous waste blend tanks, three hazardous waste burn tanks and seven miscellaneous hazardous waste treatment units. These permits also required corrective action in the event there was a release of hazardous waste or hazardous constituents to the environment.

Holcim/Geocycle submitted a permit application on Oct. 29, 2009, for renewal of their existing hazardous waste permits. Holcim/Geocycle's existing Part I Permit expired May 2, 2010 and Part II Permit expired June 16, 2010. State and federal regulations, 40 CFR 270.51, allow the existing hazardous waste permits to continue in effect until the department and EPA issue or deny new hazardous waste permits. On Feb. 15, 2012, Holcim/Geocycle withdrew their permit application and began closing the facility. As of July 2013, all hazardous waste management units have been closed and Holcim/Geocycle is conducting corrective action activities under the same two hazardous waste permits the facility operated under. The hazardous waste permits will continue in effect until the department makes a determination regarding any corrective action, or cleanup.