Hazardous Waste Program
EPA ID# MOD095038329
- Former Company Name: Hoffman-Taff Chemical Co., Syntex Agribusiness Inc., Clariant LSM, Archimica Inc.
- Type of Facility: Interim Status Hazardous Waste Treatment, Storage and Disposal - closing.
- Wastes Handled: aqueous wastes (contaminated groundwater).
- Treatment and Disposal Methods: Land disposal - closed.
- Location of hard copies of hazardous waste permit application, Part I and Part II Permits, modification requests, reports, etc. and supporting documents:
Euticals is implementing the approved remedy for on-site groundwater and soil contamination and performing long-term monitoring and maintenance of a closed surface impoundment under two hazardous waste permits. The status of Euticals’ post-closure and corrective action activities is described below. The public can review and copy paper copies of all permits, reports and supporting documents at the agency locations above.
The Euticals Inc. site is located at 2460 W. Bennett St., approximately one mile west of the intersection of Bennett Street and Kansas Expressway (U.S. Highway 13), in southwest Springfield. The facility was operated as a chemical manufacturing facility since 1949, under the names Hoffman-Taff Chemical Co., Syntex Agribusiness Inc., Clariant LSM and Archimica Inc. Before 1988, the facility occupied about 7.4 acres. Over the years the facility expanded and acquired additional property south and east of Jordan and Wilson creeks. The facility currently occupies approximately 72 acres.
Euticals currently operates a pharmaceutical chemical manufacturing facility on the site. A variety of compounds have been produced at the facility over the years. Some products include food additives, alcohol denaturants, disinfectants, herbicides and pharmaceutical products. Volatile organic compounds were often used as raw materials at the facility, including methylene chloride, toluene, xylene, 1,2-dichloroethane, methanol, benzene and chloroform. A by-product of some of the production lines was 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD).
Before 1960, waste from the facility was discharged through underground pipes that began at the production buildings and emptied into a ditch along the western side of the property. Around 1960, Hoffman-Taff built a 300,000 gallon, unlined hazardous waste surface impoundment along the former Jordan Creek stream channel. From about 1960 through 1965, the system of underground pipes was expanded to connect all buildings, the laboratory and a pilot plant. The system led to two common north-south underground vitrified clay pipes. One pipe emptied directly into the surface impoundment and one emptied into a brick-lined settling pit before discharging into the same surface impoundment. The surface impoundment then discharged directly into Jordan Creek. After 1965, an aeration basin was built and wastes were pumped from the surface impoundment and settling pit into the aeration basin before discharging to the City of Springfield sewer and publicly-owned treatment works.
The currently active portion of the facility occupies about seven acres and contains a number of buildings that house manufacturing, product and raw material storage facilities, quality control and process development laboratories, maintenance, and administrative buildings. The remaining acreage is undeveloped. Euticals currently stores the hazardous wastes produced as part of the facility operations in containers before being disposed off site. The containers are managed under generator storage requirements under 10 CSR 25-5.
Post-Closure and Corrective Action Status
Syntex acquired the facility from Hoffman-Taff in late 1969. In 1975, before regulatory requirements for closure were established, Syntex closed the southern half of the surface impoundment by filling it with native soil, rock and concrete and capped it with clay fill. The north half of the surface impoundment was used until March 1982. In 1983, Syntex began investigating possible groundwater contamination in conjunction with the closure and remediation of the northern half of the surface impoundment, which was closed according to applicable regulatory requirements in 1985. During closure, approximately 250,000 gallons of contaminated water and sediment were removed and the impoundment was backfilled with uncontaminated soil and covered with clay fill and a concrete cap. Soil sampling results indicated soil contamination immediately north and west of the former surface impoundment. Because the impoundment stopped receiving hazardous waste before Congress enacted the federal hazardous waste laws and regulations, the impoundment is regulated as a solid waste management unit. The department accepted Syntex’s closure report and certification for the former surface impoundment in 1990; however, corrective action and post-closure care activities continue at the facility due to soil and groundwater contamination.
The settling pit and aeration basin were decommissioned and decontaminated in 1984 when TCDD was detected. From 1984-1985, Syntex conducted extensive analysis of the soil and groundwater at the site. In January 1985, Syntex submitted to the department and EPA, a summary of the information on the monitoring wells and the results of the first sampling of the soil and groundwater at the facility. The results were sufficient to indicate that contamination was present in the soil and groundwater at the facility.
From 1985 to 1989, Syntex periodically sampled the monitoring wells. In 1989, the underground pipe system was replaced with overhead lines, the wastewater treatment system was replaced and an interim measures groundwater recovery and treatment system was implemented. On May 16, 1989, Syntex voluntarily entered into a 3008(h) Corrective Action Administrative Order on Consent with EPA, Docket Number VII-89-H-0017, because Missouri had not yet received final authorization for the corrective action portion of the federal hazardous waste law. The Consent Order initially identified one solid waste management unit as a possible release site.
In compliance with the Consent Order, Syntex conducted a RCRA Facility Investigation to define the horizontal and vertical extent of any contamination at eleven solid waste management units. Syntex submitted a final RCRA Facility Investigation Report to the department and EPA on June 14, 1996. The sample results showed soil and groundwater were contaminated; however, the contamination was contained on-site and posed no immediate threat to human health or the environment. Based on the sample results, the investigation concluded that seven solid waste management units required no further investigation; however, four solid waste management units required corrective action, or cleanup. Those units were the former settling pit, former surface impoundment, former underground pipe system, and the contaminated sewer pipes at Building 14.
Clariant LSM (Missouri) Inc. acquired the facility from Syntex and assumed the responsibilities of the Consent Order. Clariant performed a Corrective Measures Study to identify and evaluate possible remedial alternatives for the soil and groundwater contamination. Clariant submitted a Corrective Measures Study Report to the department and EPA on Jan. 9, 2002. The report included Clariant’s preferred remedy along with other remedial alternatives. The department and EPA jointly approved the report on March 28, 2005.
The department and EPA reviewed the proposed remedy and other remedial alternatives. The department, in coordination with EPA, selected the best remedy given site-specific considerations for each solid waste management unit. The department prepared a Statement of Basis that summarized the remedial alternatives and the department’s basis of support for the proposed remedy. The department and EPA incorporate the proposed remedy into draft hazardous waste permits for Archimica Inc., who acquired the facility from Clariant. The public was invited to review and comment on the proposed remedy and draft permits during a 45-day public comment period, which began Aug. 10, 2010, and ended Sept. 24, 2010. On Sept. 30, 2010, the department and EPA approved the proposed remedy, without modification, issued the final hazardous waste permits and terminated the Consent Order.
The next step in the corrective action process is to implement the approved remedy. Euticals acquired the facility from Archimica in April 2012 and has assumed the responsibilities of implementing the approved remedy. The approved remedy for on-site groundwater and soil contamination included enhanced institutional controls, dense non-aqueous phase liquid recovery, surface water monitoring, groundwater containment and monitoring. A groundwater pumping system is already installed and operating. Euticals is also required to continue monitoring and maintenance of the closed, capped former surface impoundment.
Hazardous Waste Permit Status
Euticals is conducting post-closure and corrective action activities under two hazardous waste permits, one issued by the department and one issued by EPA, both on Sept. 30, 2010. The department issued the Missouri Hazardous Waste Management Facility Part I Permit. EPA issued the Hazardous and Solid Waste Amendments Part II Permit. These permits require Euticals to implement the approved remedy for on-site groundwater and soil contamination and perform long-term monitoring and maintenance of the former surface impoundment. These permits also require corrective action in the event there is a newly identified release of hazardous waste or hazardous constituents to the environment or if the contaminated soil and groundwater poses a threat due to further migration.
On June 14, 2013, the department approved Euticals’ Class 2 Permit Modification request, allowing Euticals to add two point of compliance wells and modify hydraulic performance standards.