Hazardous Waste Program
EPA ID# MOD084093368
DNR Contact: Christine Kump-Mitchell, PE, 314-416-2464 or 800-361-4827
EPA Contact: Wray Rohrman, 913-551-7543 or 800-223-0425
Facility Contact: Paul Nemanic, 609-860-4337
Last Updated: Sept. 18, 2013
- Former Company Name: Rhodia Inc.; Rhone-Poulenc; RTZ Corp.
- Type of Facility: Former Interim Status Hazardous Waste Storage – closed.
- Wastes Previously Handled: D001 (ignitable), D002 (corrosive), and D008 (lead).
- Treatment and Disposal Methods: On-site wastewater treatment plant.
- Location of hardcopies of hazardous waste permit application, Part I and Part II Permits, modification requests, reports, etc. and supporting documents:
Approved Remedy Issued: The department approved the proposed remedy of no further corrective action with institutional controls at the Alcolac facility. As a result of that approval, the department are 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 Sept. 18, 2013.
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 release may be entitled to pursue an appeal before the Administrative Hearing Commission by filing a written petition by Oct. 18, 2013, 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 Alcolac site is located on approximately 227.78 acres at 24732 Randall Rd. in Sedalia. In 1977, Alcolac began operating a specialty chemicals manufacturing facility at the site. Alcolac was acquired by RTZ Corp. in the 1980s and later purchased by Rhone-Poulenc SA in 1989. In 1999, Rhone-Poulenc spun Rhodia, Inc. off as a new company. Alcolac is a wholly owned subsidiary of Rhodia Inc.
Alcolac produced a broad range of products with a variety of end-use applications in approximately 20 different industries. Alcolac’s two major product lines included surface agents and functional monomers. Surface agents were used in cosmetics, toiletries, consumer and industrial cleaning products and a variety of textile operations. Functional monomers were used to prepare polymers for adhesives, paper coatings, textiles, plastics, surface coatings, petroleum recovery and municipal and industrial water treatment.
The facility consisted of a surfactant plant and a monomer plant, two incinerators, a lake, two cooling water ponds, four bio-oxidation ponds, three spray irrigation areas, two sedimentation ponds, a day pond and three salt ponds. The incinerators were installed in late 1977 or early 1978. One incinerator was used for the incineration of organic vapors and the other for liquid organic wastes. The liquid incinerator was never fully operational.
Alcolac used the lake for non-contact cooling water. In late 1977 or early 1978, Alcolac built two 250 ft x 250 ft x 10 ft cooling water return ponds to receive the non-contact water that originated from the lake. The bio-oxidation ponds contained effluent from the surfactant and monomer plants. The ponds were in series, each pond feeding into the next pond by gravity flow. When the effluent reached Pond 4, it was land treated by spray irrigation in one of three irrigation areas, which covered about 10 acres. Two sedimentation ponds were built in natural soils and collected storm water runoff from the facility and runoff from two of the irrigation areas.
In late 1977 or early 1978, Alcolac built a 50 ft x 50 ft x 8 ft day pond and an asphalt-lined salt pond. Two additional salt ponds were built in 1980. The day pond was originally designed to handle the water from backflushing the sand filters in the Environmental Control Building. In 1983, the day pond was converted to a salt pond and lined with a polypropylene liner. The original salt pond was also lined with a polypropylene liner in 1983. Brine from the processing of monomers was sent to the salt ponds, where the ponds were drained and salt allowed to dry before being shipped off site for disposal.
A variety of hazardous wastes were produced in the sulfation/sulfonation process used to produce the surface active agents and in the organic chemical operations, which produced the functional monomers. Alcolac stored these hazardous wastes in tanks and drums before shipping off site for disposal or sending to the facility’s on-site wastewater treatment plant. The hazardous wastes handled in the tank and container storage areas were D001 (ignitable), D002 (corrosive) and D008 (lead). Alcolac stored these hazardous wastes in two 6,000-gallon tanks, two 3,960-gallon tanks or one 288-square foot hazardous waste container storage area with a capacity of 142 fifty five-gallon drums.
Production operations at the plant stopped in 1991 and the equipment was dismantled in 1992. The facility is currently vacant and there are no active manufacturing operations. The former manufacturing portion of the facility is located on 56.39 acres and is currently owned by Alcolac. The remaining 171.39 acres consists of crop fields and is owned by JBK Farms LLC.
Closure and Corrective Action Status
Alcolac decontaminated the piping and feed tanks associated with the liquid incinerator in 1981. Closure of one of the three salt ponds occurred in 1983 and included filling the pond with clean soil. The storage feed tanks were removed in 1983 or 1984. The department accepted Alcolac’s closure certification for the hazardous waste container and tank storage areas in 1988.
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. In 1989, A.T. Kearney Inc. performed a Resource Conservation and Recovery Act, or RCRA, Facility Assessment for the facility property, 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 June 1993 RCRA Facility Assessment Report identified 24 solid waste management units and 7 potential areas of concern, of which 14 solid waste management units and 1 area of concern were recommended for more investigation.
The following areas were decommissioned and closed according to the department’s Water Protection Program requirements, in coordination with the department’s Hazardous Waste Program. The day pond and second salt pond were closed in 1991 by filling with clean soil. The third salt pond and the four bio-oxidation ponds were closed in 2003, according to the department-approved Closure Plan, Bio-Oxidation Ponds and Salt Pond. A retention study of the clay liners for the bio-oxidations ponds was conducted during closure activities. This study determined that the clay-lined ponds had not leaked during operation.
In 2004, Alcolac anticipated selling off parts of the facility property that were not occupied by the former plant manufacturing operations. As a result, Alcolac submitted a Risk Evaluation for the Spray Irrigation Areas. The purpose of this investigation was to determine whether agricultural use of the former spray irrigation areas was safe for the farmer and consumers of crops grown in those areas. Based on this evaluation, the former spray irrigation areas were determined to be safe to use for agricultural purposes.
In 2006, Alcolac prepared a Description of Current Conditions Report, or DCCR, presenting all environmental sampling, investigation and unit closures conducted up to that time. The DCCR included a data screening, comparing the existing site subsurface characterization data to risk-based target levels in the then current version of the department’s Missouri Risk-Based Corrective Action Guidance document and the EPA Regional Screening Levels. At the department’s request, Alcolac also performed a Risk Assessment to evaluate residual levels of contaminants in the soil and groundwater to determine if they exceeded risk levels and to address remaining elements necessary to adequately characterize the site. The 2007 Risk Assessment Report concluded that allyl alcohol and methanol exceeded highly conservative default target levels in surface and subsurface soil at the Monomer Plant, but those levels were below their risk-based target levels for non-residential land use and below EPA screening levels for industrial use. Arsenic, which is naturally occurring in area soils, was the only metal detected above screening levels. From 1990 to 1993, monitoring of the shallow groundwater produced sporadic/inconsistent detections of methylene chloride, benzene, 1,2-dichloropropane and tetrahydrofuran that exceeded their respective risk-based target levels for domestic consumption, but were acceptable for residential or non-residential land use based on potential direct skin contact with groundwater and breathing vapors containing contaminants that could potentially volatilize from the groundwater and end up in indoor air. The Risk Assessment also concluded that any releases at the facility did not pose an unacceptable risk to human health or the environment. However, to err on the conservative side, the Risk Assessment proposed restricting the site to non-residential use and prohibiting the use of shallow groundwater for drinking water.
Based on the Risk Assessment recommendations, the department and Alcolac executed an Environmental Covenant for the facility property, restricting the property to non-residential land use and prohibiting the drilling or use of shallow groundwater for drinking water. Shallow groundwater is groundwater less than 50 feet below ground surface. The Environmental Covenant was filed with the Pettis County Recorder of Deeds on March 20, 2008.
The 2006 DCCR evaluated the historical groundwater data from 1990 to 1993. Due to the age of the groundwater data contained in the DCCR, the department and EPA requested that Alcolac conduct additional groundwater sampling to obtain data that represented current groundwater quality, to be used in support of a final regulatory determination. Alcolac sampled the six existing on-site groundwater monitoring wells in December 2010 and reported the findings in a Supplemental Groundwater Sampling Report, dated April 13, 2011. The sampling results for volatile and semi-volatile organic compounds, including those sporadically detected from 1990 to 1993, were below analytical detection limits in all on-site groundwater monitoring wells. Arsenic, cobalt, and manganese concentrations were detected above their respective comparison standards in one well, but their presence was localized and is likely attributable to background metals concentrations in the soil.
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 Alcolac facility and no further corrective action is necessary. The department prepared a Statement of Basis that summarized the basis of support for the proposed remedy of no further corrective action with institutional controls at the Alcolac facility. The institutional control is the 2008 Environmental Covenant. The department proposed to release 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 public was invited to review and comment on the proposed remedy and regulatory release during a 30-day public comment period, which began July 15, 2013, and ended Aug. 14, 2013. On Sept. 18, 2013, the department approved the proposed remedy. As a result of that approval, the department released Alcolac from regulation as a former interim status hazardous waste treatment, storage, and disposal facility subject to corrective action, effective immediately.
Hazardous Waste Permit Status
Alcolac stored hazardous waste under the interim status portions of the federal and state hazardous waste laws, 40 CFR Part 265 and 10 CSR 25-7.265. When Congress passed the federal law in 1980, all existing facilities that treated, stored or disposed of hazardous waste in a manner that would neccessitate 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.
Alcolac submitted their RCRA Part A permit application on Nov. 19, 1980 and RCRA Part B permit application on Feb. 16, 1983. Alcolac decided not to continue the hazardous waste permitting process and to close the container and tank storage areas. Alcolac is 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 units. Alcolac is subject to corrective action because they completed closure of the interim status hazardous waste management units after the effective date of the federal Hazardous and Solid Waste Amendments. Due to soil and groundwater contamination discovered as part of the closure process, Alcolac was required to perform corrective action, or cleanup, activities to protect human health and the environment.The department determined that Alcolac adequately addressed all issues associated with solid waste management units or areas of concern. On Sept. 18, 2013, the department approved the proposed remedy of no further corrective action with institutional controls. As a result of that approval, the department released Alcolac from regulation as a former interim status hazardous waste treatment, storage, and disposal facility subject to corrective action, effective immediately.