International Paper Co.
EPA ID# MOD007129935
- Former Company Name: None.
- Type of Facility: Permitted Hazardous Waste Storage and Disposal – closed.
- Wastes Handled: Aqueous wastes.
- Treatment and Disposal Methods: Land disposal.
- Location of hard copies of hazardous waste permit application, Part I and Part II Permits, modification requests, reports, etc. and supporting documents:
International Paper is performing long-term monitoring and maintenance of a corrective action management unit and conducting corrective action activities under two hazardous waste permits. The status of International Paper’s post-closure and corrective action activities are described below. The public can review and copy paper copies of all permits, reports and supporting documents at the agency locations above.
The International Paper Co. site is located on about 98 acres at 2609 S. Rangeline Road (U.S. Hwy 71) in Joplin. Around the turn of the century, the site was largely used for underground lead and zinc mining. Rex Mining and Smelting Co. became the eventual owner. In 1937, Long-Bell Lumber Co. and American Lumber & Treating Co. purchased part of the property from Rex Mining and began wood treating operations at the facility. Long-Bell eventually purchased the entire property and continued operations until about 1956, when International Paper acquired the facility.
International Paper used an empty cell preservation process to pressure-treat telephone poles, piles and lumber in horizontal cylinders, or retorts, located outside on a concrete drip pad. International Paper treated exclusively with creosote until 1955, when pentachlorophenol, or PCP, was first used on a limited basis. The percentage of wood treated with PCP dissolved in wood treating oil steadily increased until 1979, when PCP completely replaced creosote as the treatment solution.
After the preserving process, the treated wood was removed from the retorts and staged on a drip pad before being stored for shipment in one of the facility’s outside storage yards. The preservative “drippage” from the treated poles collected on the drip pad. The excess preserving liquid and loose wood debris in the retorts were returned to the work tanks, where the concentration of the treating solution was adjusted for reuse and extraneous material was allowed to settle. The work tanks were cleaned once a year, at which time the tank bottoms were removed for disposal.
Two on-site solid waste landfills were used to dispose of treated and untreated wood, as well as assorted metal. The waste products produced as part of the facility operations were discharged to 11 unlined surface impoundments. These surface impoundments were used for long-term storage of creosote sludges, recovery of PCP-oil emulsion and tank bottom sediments, which are classified as K001 hazardous waste. International Paper deactivated and covered one surface impoundment in 1971 and another in 1980. The nine remaining surface impoundments were connected by culverts or aboveground pipes. Although several of the surface impoundments were used strictly to store wastes, all were operated as flow-through systems in order to periodically eliminate accumulated rainfall and run-on.
The nine remaining surface impoundments were taken out of active service in 1984 when the City of Joplin gave International Paper authorization to discharge pretreated wastewaters to the municipality’s sewer system. In June 1985, International Paper placed a process wastewater pretreatment plant on-line for treating all process wastewater, cylinder wastes and captured rainwater from the treatment area. Wastes were collected in a concrete sump and pumped into the pretreatment system. The effluent was discharged to Joplin’s city sewage system and solids were accumulated in a 250,000-gallon aboveground steel tank.
International Paper stopped wood treating operations in March 2006. The facility property is currently inactive except for ongoing post-closure and corrective action activities.
Post-Closure and Corrective Action Status
International Paper’s Joplin facility operated as a woodtreater long before the Resource Conservation and Recovery Act, or RCRA, came into existence to regulate the company’s activities. Because International Paper covered two of the surface impoundments before RCRA was implemented, those units were regulated under the Comprehensive Environmental Response, Compensation, and Liability Act, or CERCLA. The department placed the two inactive surface impoundments on the Registry of Confirmed Uncontrolled Hazardous Waste sites on June 14, 1984.
Sludges produced from the treatment of wastewaters from creosote and/or PCP wood preserving processes are regulated under RCRA. International Paper submitted a closure plan for the nine remaining surface impoundments to the department in July 1983, which the department rejected in October 1983. International Paper submitted a compromise closure plan in February 1984. In June 1984, the department presented International Paper with specific modifications to the closure plan, which the department approved on Aug. 28, 1984, in a Findings of Fact and Order to Clean Up Hazardous Substance.
There were many surface expressions left behind from the previous zinc and lead mining activities at the site, including shafts, vents, cave-ins and tailings piles. Some of the shafts filled with water and formed small, deep ponds. Large drifts laid beneath the site at depths over 100 feet. A few shafts and cave-ins existed within the surface impoundments. These cave-ins were capped in 1985. Closure of the 9 surface impoundments occurred in 1986 and included removing the free liquids, hazardous sludge and contaminated soil shipping it off site to an incinerator. The remaining contaminated soil was removed and placed into four lined land treatment units, or landfarms. The landfarms, numbered 1, 4, 5 and 7, covered approximately 11 acres total.
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 1987, A. T. Kearney Inc. performed a 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 1987 RCRA Facility Assessment Report identified 28 solid waste management units and 19 areas of concern that were recommended for additional investigation. It was evident from the visual site inspection that releases of hazardous waste to soil and groundwater continued to occur from multiple sources.
The previous mining activities at the site made it more difficult to trace and contain contamination. The abandoned mine cave-ins beneath the surface impoundments resulted in groundwater contaminated with PCP, naphthalene, fluoranthene, benzo(a)pyrene and other hazardous constituents. In 1993, International Paper began operating a groundwater remediation system. The system included monitoring and extraction wells placed in mine cavities and other formations to collect the contaminated groundwater and an on-site pretreatment wastewater system. International Paper also added leachate collection systems to the landfarms. Additional landfarm improvements were completed in 1994. Four large roof structures, totaling ten acres, were built over the landfarms to control runoff and enhance soil bioremediation activity. In this case, bioremediation involved mixing the contaminated soil with cow, pig or horse manure or similar substances to increase microbial activity. The microbes then break down the contaminants. Pilot-scale operations of the landfarm bioremediation activities began in 1996 and continued into 2001.
International Paper was granted permission for Brownfield Redevelopment of the landfarms following the treatment of approximately 30,000 cubic yards of contaminated soil. In 2001, the entire contents of Landfarms 1 and 4, including the leachate collection equipment and soil drainage layers, were relocated into Landfarms 5 and 7, which became a corrective action management unit. Landfarms 1 and 4 were sampled and backfilled with clean fill and certified closed with no post-closure care required. Landfarms 5 and 7 were covered with concrete caps and certified closed; however, because hazardous waste remained in place after closure, Landfarms 5 and 7 are required to go through a period of post-closure care. The soil in the corrective action management unit is contaminated with wood treating chemicals such as creosote, arsenic, barium, cadmium, lead and polycyclic aromatic hydrocarbons including PCP.
As part of the post-closure care, International Paper is required to operate the groundwater remediation system until 2045, or until they can show the contaminant levels have been below the maximum concentration limits specified in their hazardous waste permit for three consecutive years. A total of 47 active monitoring wells, of which three are extraction wells, continue to monitor the groundwater at the corrective action management unit and throughout the site. Sampling results have shown that International Paper’s groundwater extraction system is performing the intended job of maintaining control of the groundwater plume.
International Paper continues to work with the department and EPA on corrective action for the remaining contaminated soil and groundwater. Because Missouri did not adopt all the listed wastes associated with woodtreating, the facility’s former drip pad area and main treatment area are being closed under EPA authority. EPA enforces the federal regulatory requirements that Missouri has not yet adopted or been authorized by EPA to implement. The concrete drip pad outside the pressure retort area and main treatment area are planned to be cleaned and capped by 2014.
Potential off-site surface water and groundwater contamination is a concern, which is being addressed by ongoing remediation activities and permit requirements. It appears that some past off-site releases from the facility may have been covered during past (decades ago) off-site construction activities. Due to new construction in the area, contaminated soils are being “rediscovered.” On behalf of International Paper, EarthCon Consultants Inc. performed a RCRA Facility Investigation to define the horizontal and vertical extent of any groundwater and soil contamination. EarthCon submitted a RCRA Facility Investigation Report to the department and EPA on Oct. 6, 2008, with a supplemental submission on Aug. 2, 2011. The department and EPA are currently reviewing these documents. What, if any, corrective action, or cleanup, activities are necessary will be based on the investigation results.
International Paper operated the surface impoundments under the interim status portions of the of the federal hazardous waste laws, 40 CFR Part 265 and 10 CSR 25-7.265. When Congress passed the hazardous waste federal 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. International Paper decided not to continue the hazardous waste permitting process and to close the units. International Paper is subject to the permitting requirements of the Missouri Hazardous Waste Management Law and federal Hazardous and Solid Waste Amendments for post-closure care because hazardous waste remained in place. International Paper is also 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.
International Paper is currently conducting post-closure and corrective action activities under two hazardous waste permits, one issued by the department and one issued by EPA. The permits were first issued in 1994. The department reissued the Missouri Hazardous Waste Management Facility Part I Permit, effective Sept. 30, 2013. EPA reissued the Hazardous and Solid Waste Amendments Part II Permit, effective Nov. 4, 2013. The permits require International Paper to continue long-term monitoring and maintenance of the corrective action management unit, continue groundwater remediation activities and begin closure activities and post-closure care of the former kick-back area and drip pad. The 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 or groundwater poses a threat due to further migration.