Hazardous Waste Program
EPA ID# MOD031005341
- Type of Facility: Former Interim Status Hazardous Waste Storage - closed.
- Treatment and Disposal Methods: None.
- Location of hardcopies of hazardous waste permit application, Part I and Part II Permits, modification requests, reports, etc. and supporting documents:
Ashland Inc. is implementing the approved final remedy for the groundwater contamination under a Letter of Agreement. The status of Ashland’s 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.
Ashland operated an interim status hazardous waste storage facility, located at 7710 Polk Street in St. Louis. The facility occupies about 17 acres in an area near the Mississippi River. Before 1963, it is believed that the site had been used by a garment manufacturer. Ashland bought the facility in 1963 and began chemical distribution operations in 1975.
Ashland’s use of the facility includes storage and packaging or repackaging of industrial chemicals and solvents for local distribution. Chlorinated and non-chlorinated solvents, glycerines, surfactants, acids and caustics are brought to the plant by rail and truck, then transferred to large above ground bulk storage tanks at the facility. The chemicals are distributed to the customers by either tank truck or by drumming and transferring by truck.
Corrective Action Status
The drummed wastes were stored at the hazardous waste container storage pad before being shipped off-site for disposal. The hazardous waste container storage area was clean-closed Nov. 18, 1993, according to their department-approved closure plan. The department accepted Ashland’s closure report and certification Aug. 1, 1994.
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. There are two known historical releases of hazardous waste at the facility. In January-June 1989, twenty cubic yards of perchloroethylene contaminated soil was transported off site in response to a 200-gallon spill. In 1990, an estimated 112 gallons of Hi-Sol 10 was released as the result of a leaking underground pipe during the unloading of a tanker car. The department and EPA performed several site investigations at Ashland. The Resource Conservation and Recovery Act, or RCRA, Facility Assessment Report identified one solid waste management unit, or SWMU, and three area's of concern, or AOCs, that required more investigation.
The department and Ashland voluntarily entered into a Letter of Agreement, which is the starting point for carrying out an expedited corrective action program at the facility. Ashland performed a RCRA Facility Investigation, or RFI, to define where the waste is located in the soil and groundwater. Phase I of the investigation was completed in 2003. Ashland submitted the Phase II RFI Report to the department in June 2005. The department approved the report March 2, 2006. Based on analytical results, the investigation concluded that no further cleanup of soil appeared necessary. Analytical results also indicated that natural attenuation was occurring at the on-site Hi-Sol 10 plume source and surrounding areas.
Ashland performed a Corrective Measures Study to identify and evaluate potential remedial alternatives for the contaminated groundwater. A final Corrective Measures Study/Corrective Measures Implementation Work Plan was submitted to the department Aug. 22, 2007. The report included Ashland’s preferred final remedy along with other remedial alternatives. The department, in coordination with EPA, selected the best remedy given site-specific considerations. The department prepared a Statement of Basis that summarized the remedial alternatives and the department’s basis of support for the proposed final remedy. The department invited the public to review and offer written comments on the proposed final remedy during a 45-day public comment period. On Sept. 30, 2010, the department, in coordination with EPA, approved the proposed final remedy, without modification. The approved final remedy includes no further action for the soil and monitored natural attenuation and institutional controls for the groundwater contamination. The next step in the corrective action process is to implement the approved final remedy for the groundwater contamination, according to Ashland’s Corrective Measures Study/Corrective Measures Implementation Work Plan.
Hazardous Waste Permit Status
Ashland operated the hazardous waste storage facility 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 were required to obtain a hazardous waste 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.
Ashland submitted their Part A permit application for hazardous waste storage in Nov. 24, 1980, and a Part B permit application in 1985. Ashland decided to close the hazardous waste container storage area, the only Hazardous Waste Management Unit included in their permit application. As part of the closure process, Ashland was required to investigate and clean up hazardous waste releases at their facility resulting from present and past hazardous waste handling practices. There are two known historical releases of hazardous waste at the facility. In an effort to simplify and streamline the corrective action, or cleanup, process, the department and Ashland voluntarily entered into a Letter of Agreement on Feb. 29, 2001. The Letter of Agreement is still in effect.