Nexeo Solutions LLC
EPA ID# MOD031005341
- Former Company Name: Ashland Inc., Ashland Chemical, Ashland Distribution Co., Ashland St. Louis Distribution Co.
- Type of Facility: Former Interim Status Hazardous Waste Storage - closed.
- Wastes Handled: Chlorinated and non-chlorinated solvents, glycerines, surfactants, acids and caustics
- Treatment and Disposal Methods: None.
- Location of hard copies of Letter of Agreements, reports, etc. and supporting documents:
Nexeo Solutions LLC, formerly Ashland Inc., is implementing the approved final remedy for the groundwater contamination under a Letter of Agreement. The status of Nexeo’s corrective action activities is described below. The public can review and copy paper copies of all reports and supporting documents at the agency locations above.
The Nexeo Solutions LLC site is 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 the site had been used by a garment manufacturer. Ashland Chemical Inc. bought the facility in 1963 and began chemical distribution operations in 1975. Ashland stored and packaged or repackaged industrial chemicals and solvents for local distribution. Chlorinated and non-chlorinated solvents, glycerines, surfactants, acids and caustics were brought to the plant, then transferred to large above ground bulk storage tanks at the facility. The chemicals were then delivered to the customers by either tank truck or by drumming and transferring by truck.
As a service to their customers, Ashland also accepted hazardous wastes, including spent solvents, acids and caustics. Drummed wastes were stored at an on-site hazardous waste container storage pad before being shipped off-site for disposal.
The hazardous waste container storage area was clean-closed in November 1993, according to their department-approved closure plan. The department accepted Ashland’s closure report and certification Aug. 1, 1994.
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. There are two known historical releases of hazardous waste at the facility. In 1989, twenty cubic yards of perchloroethylene contaminated soil was moved off site in response to a 200-gallon spill. In 1990, an estimated 112 gallons of Hi-Sol 10 was released during the unloading of a tanker car as the result of a leaking underground pipe. On July 29, 1991, Jacobs Engineering Group Inc. performed a Visual Site Inspection and Preliminary Assessment for the site, on behalf of EPA, as part of the EPA Environmental Priorities Initiative. The assessment was conducted to identify and gather information on actual and potential releases of hazardous waste and hazardous constituents to the environment. The May 1992 EPI Preliminary Assessment Report identified seven solid waste management units and 16 areas of concern that required more investigation. The department conducted additional investigations and prepared a Resource Conservation and Recovery Act, or RCRA, Facility Assessment Report Addendum, which is an addendum to the EPI Preliminary Assessment Report. The1996 RFA Report Addendum clarified that only one solid waste management unit and three areas of concern required further investigation.
In response to the assessment, Ashland performed a RCRA Facility Investigation, or RFI, to define the horizontal and vertical extent of any contamination 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. Based on the sample results, the investigation concluded that no further cleanup of soil appeared necessary. The sample results indicated that natural attenuation, a natural processes like biodegradation that reduce contaminant concentrations, was occurring at the on-site Hi-Sol 10 plume source and surrounding areas. Based on the groundwater results, the investigation concluded that contaminated groundwater required corrective action, or cleanup.
Ashland performed a Corrective Measures Study to identify and evaluate possible remedial alternatives for the contaminated groundwater. Ashland submitted a final Corrective Measures Study/Corrective Measures Implementation Work Plan to the department in August 2007. The report included Ashland’s preferred 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 remedy. The public was invited to review and comment on the proposed remedy during a 45-day public comment period. On Sept. 30, 2010, the department, in coordination with EPA, approved the proposed 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. Nexeo, formerly Ashland Inc., is implementing the approved final remedy for the groundwater contamination. A draft Environmental Covenant has been prepared, in order to place activity and use limitations on the property required by the final remedy.
Ashland operated the hazardous waste container storage area 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 hazardous waste laws, all facilities treating, storing or disposing of hazardous waste in a manner that would necessitate obtaining a hazardous waste permit were required to notify EPA and apply to get such a permit, unless the facility chose to close those operations. 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 permit application, but later decided not to continue the hazardous waste permitting process and to close the hazardous waste container storage area, the only hazardous waste management unit included in their permit application. Ashland 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.
Ashland 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. 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.