EPA ID# MOD050226075
- Former Company Name: American Cyanamid Co.
- Type of Facility: Permitted Hazardous Waste Treatment, Storage and Disposal.
- Wastes Handled: Pesticide and herbicide waste (as specified in the Part A application).
- Treatment and Disposal Methods: Incineration.
- Location of hard copies of hazardous waste permit application, Part I and Part II Permits, modification requests, reports, etc. and supporting documents:
Class 2 Permit Modification Request Approved: On Aug. 17, 2016, BASF Corp. submitted a Class 2 Permit Modification request to the department. The request was to change the mode of thermal oxidizer combustion gas quenching in BASF’s “A” and “B” incinerators. Specifically, BASF requested flexibility to operate in either spray quench mode or submerged quench mode. Spray quench mode is when combustion gases are cooled as it exits the oxidation chamber by quench water sprayed through spray nozzles. Submerged quench mode is when combustion gases are cooled by being discharged subsurface into quench water in the incinerator’s quench tank. After a thorough technical review of the permit modification request and all comments received during the public comment period, the department approved BASF Corp.’s proposed permit modification with conditions, effective immediately. These permit modifications allow BASF to perform the requested changes. The public can review and copy the permit modification request, department approval and supporting documents at the agency locations above.
There were no comments made on the proposed Class 2 Permit Modification during the public comment period. Any parties adversely affected or aggrieved by the department’s decision to approve the modification request or specific conditions of the modification may be entitled to pursue an appeal before the Administrative Hearing Commission, according to Code of State Regulations 10 CSR 25-8.124(2). The written petition must be filed with the Administrative Hearing Commission by Dec. 14, 2016, according to the procedures outlined in 10 CSR 25-2.020 and Missouri Revised Statutes, Sections 260.395.11 and 621.250, RSMo. Contact information for the Administrative Hearing Commission can be found online at ahc.mo.gov, or by calling 573-751-2422. 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.
Permit Application for Renewal Complete: On Oct. 26, 1999, BASF Corp. submitted a permit application to the department and U.S. Environmental Protection Agency Region 7, to renew their existing Missouri Hazardous Waste Management Facility Part I Permit and Hazardous and Solid Waste Amendments Part II Permit. BASF replaced that application with a new application on March 4, 2003, and sent an amendment to the permit application on Jan. 29, 2010. The department determined the permit application was complete and invites the public to review and offer written comments on the permit application while the department conducts a technical review of the permit application.
The public can review and copy the permit application and supporting documents at the Palmyra Bicentennial Public Library, 212 S. Main St., Palmyra (during normal business hours) or the agency locations above. Comments on the permit application are more effective if they point out legal or technical issues. You may submit written comments online or by mail to Nathan Kraus, PE, Missouri Department of Natural Resources, Hazardous Waste Program, P.O. Box 176, Jefferson City, MO 65102-0176.
The BASF Corp. site, known as the BASF Hannibal Plant, is located on about 1,800 acres at 3150 Highway JJ, approximately five miles northeast of Palmyra, along the west bank of the Mississippi River. About 250 acres of the site are used for plant operations. The remaining land is used for flood protection levees and agriculture. Before 1965, the property was used for agricultural purposes. In 1965, American Cyanamid Co., now known as Wyeth Holding Corp. and currently owned by Pfizer, purchased the property and built an ammonia storage and loading facility, ammonium nitrate production facility and a nitric acid production facility on the site in order to manufacture fertilizer products. American Cyanamid manufactured fertilizer products, which included nitric acid, ammonium nitrate and di-calcium phosphate. In 1971, the di-calcium phosphate production facility and 12 acres in the north-central part of the facility were leased to Alpharma, who manufactured animal feed intermediates until 2003. American Cyanamid built an insecticide production area in 1977 and another nitric acid production facility in 1978 and began manufacturing insecticides and herbicides. The herbicide plant was destroyed in 1977 after an explosion, and rebuilt in 1978 and 1979.
BASF purchased the facility in July 2000. Amvac, purchased a BASF product line and currently operates at the BASF facility. BASF currently manufactures agricultural chemicals, including herbicides and insecticides, at the Hannibal Plant. Commercial products manufactured at BASF include:
- ARSENAL® Herbicide (Imazapyr).
- ASSERT® Herbicide (Imazamethabenz).
- CADRE® Herbicide (Imazapic).
- PROWL® Herbicide (Pendimethalin).
- PURSUIT® Herbicide (Imazethapyr).
- RAPTOR® Herbicide (Imazamox).
- SCEPTER® Herbicide (Imazaquin).
- ALVERDE® Insecticide (Metaflumizone).
- COUNTER® Insecticide (Terbufos).
- PHANTOM® Insecticide (Chlorfenzpyr).
- THIMET® Insecticide (Phorate).
A variety of hazardous wastes are produced as part of the facility operations. BASF stores and incinerates both off-specification or expired product returned through their product stewardship program and waste created during the manufacture processes. BASF currently operates three hazardous waste container storage areas, with a combined capacity of 4,800 55-gallon containers, and four hazardous waste incinerators. The main raw materials currently and previously used at the facility that are considered hazardous constituents include monochlorobenzene (MCB), chloroform, 1,2-dichloroethane (1,2-DCA), methylene chloride, toluene and naphthalene.
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. BASF is the current owner and operator; however, Wyeth Holdings Corp. (Pfizer) retains financial responsibility for certain historical environmental matters. In 1987, AT. Kearney performed a Preliminary Review/Visual Site Inspection for the site, on behalf of EPA. The inspection was conducted to identify and gather information on actual and potential releases of hazardous waste and hazardous constituents to the environment. The report identified 42 solid waste management units and six areas of concern, of which EPA recommended additional investigation at three of the solid waste management units and four areas of concern.
The Fire Training Lagoon was investigated in October 1989. The subsurface sample results showed detections of total petroleum hydrocarbons. In December 1995 and January 1996, Geraghty & Miller Inc. performed a Geoprobe™ Groundwater Assessment in the eastern half of the facility. The sample results showed detectable concentrations of 1,1-dichloroethane (1,1-DCA), 1,2-DCA, trans-1,2-dichloroethene (trans-1,2-DCE), chloroform, ethylbenzene, MCB and total xylene. In March 2000, EPA required further investigation of the impacted groundwater.
On behalf of BASF, Arcadis conducted a Phase I RCRA Facility Investigation, or RFI, from October through November 2003, and from September through March 2005. Arcadis conducted a Phase II RFI from July 2005 through May 2006. The main goal of the Phase I and Phase II RFI’s was to confirm and define the horizontal and vertical extent of any contamination source areas throughout the site. Based on analytical results, the investigation concluded the groundwater at the site is contaminated and identified five confirmed and four possible soil sources of contaminant release. The groundwater contamination includes 1,2-DCA, 1,1-dichloroethylene, benzene, MCB, tetrachloroethene, trichloroethylene, toluene and vinyl chloride.
BASF completed interim measures at the site in order to reduce or prevent unacceptable risks to human health and the environment. An interim measure is an action taken to temporarily control the contamination source or path the contamination could take from the source to humans, animals, or the environment, such as air, soil, water, and food. As an interim measure, BASF installed a groundwater pump and treat system in July 2010. The system uses extraction wells to remove the contaminated groundwater and then treats the water through air stripping.
BASF performed a Corrective Measures Study to identify and evaluate possible remedial alternatives for the soil and groundwater contamination. BASF submitted the final Corrective Measures Study Report to the department and EPA in October 2011. The report includes BASF’s preferred final remedy along with other remedial alternatives. EPA, in coordination with the department, selected the best remedy given site-specific considerations for each solid waste management unit and area of concern. EPA prepared a Statement of Basis that summarized the remedial alternatives and EPA’s basis of support for the proposed final remedy. The public was invited to review and comment on the proposed final remedy during a 30-day public comment period. EPA is reviewing all written comments and will decide on the approved final remedy.
BASF is operating and conducting corrective action activities under two hazardous waste permits, one issued by the department and one issued by EPA. The department issued the Missouri Hazardous Waste Management Facility Part I Permit, effective April 25, 1990. EPA issued the Hazardous and Solid Waste Amendments Part II Permit, effective May 30, 1990. These permits allow BASF to store and incinerate both off-specification or expired product returned through their product stewardship program and waste created during the production processes. The regulated units consist of four hazardous waste incinerators and two hazardous waste container storage areas. These permits also require corrective action for releases of hazardous waste and hazardous constituents to the environment.
BASF submitted a permit application on Oct. 26, 1999, to renew their existing hazardous waste permits. The facility's existing Part I Permit expired April 25, 2000, and Part II Permit expired May 25, 2000. State and federal regulations, 40 CFR 270.51, allow the existing hazardous waste permits to continue in effect until the department and EPA issue or deny new hazardous waste permits. The department determined the permit application was not complete. BASF replaced that application with a new application on March 4, 2003, and sent an amendment to the permit application on Jan. 29, 2010. The department determined the permit application was complete on May 5, 2010. The department is conducting a technical review of the permit application.