River Cement Co. - Selma Plant dba Buzzi Unicem USA
EPA ID# MOD050232560
DNR Contact: Sushmita Sharma, PE, 816-251-0703 or 1-800-361-4827
EPA Contact: Cynthia Hutchison, 913-551-7478 or 1-800-223-0425
Facility Contact: Brad Williams, 636-931-0900
Last Updated: August 23, 2013
- Former Company Name: None.
- Type of Facility: Former Interim Status Hazardous Waste Treatment, Storage, and Disposal – closed.
- Wastes Handled: Flammables, lead-bearing hazardous and non-hazardous wastes, organic sludges/solids, paint sludges, petroleum-contaminated wastes, solvents, and used oil, as well as various F-, K- D-, P- and U-listed hazardous wastes as specified in the Part A Permit Application.
- Treatment and Disposal Methods: Cement kiln, fuel blending, incineration, land disposal.
- Location of hard copies of hazardous waste permit application, reports, etc. and supporting documents:
Approved Remedy Issued: On Sept. 29, 2014, the department approved the proposed remedy of no further corrective action with institutional controls at the River Cement facility. As a result of that approval, the department is releasing the facility from regulation as a former interim status hazardous waste treatment, storage and disposal facility subject to the corrective action requirements of the Missouri Hazardous Waste Management Law and regulations. The department’s approved remedy and regulatory release decisions are effective immediately.
The public can review and copy the final remedy decision and summary and response to comments received during the public comment period and supporting documents at the Festus Public Library, 400 W. Main St., Festus, Missouri (during normal business hours) or the agency locations above.
Any parties adversely affected or aggrieved by the department’s decision to approve the remedy or release may be entitled to pursue an appeal before the Administrative Hearing Commission by filing a written petition by Oct. 3, 2014, according to the procedures outlined in Code of State Regulations 10 CSR 25-2.020 and Missouri Revised Statutes, Sections 260.395.11 and 621.250, RSMo. If the petition is sent by registered mail or certified mail, it will be deemed filed on the date it is mailed. If it is sent by any other method, it will be deemed filed on the date it is received by the Administrative Hearing Commission. Appeals must be sent to the Administrative Hearing Commission, Truman State Office Building, Room 640, 301 West High Street, P.O. Box 1557, Jefferson City, MO 65102, or by fax to 573-751-5018. 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.
The River Cement Co. site, doing business as Buzzi Unicem USA, is located on approximately 2,167 acres at 1000 River Cement Road, about three miles south of Festus. The Mississippi River Corp. built the facility in 1963. River Cement Company, a subsidiary of the Mississippi River Corp., began operating the cement plant and limestone quarry at the site in 1965. In 1979, R.C. Cement Co., Inc. purchased the facility. At that time R.C. Cement was 80 percent owned by IFI International S.A. (Luxembourg) and 20 percent by Unicem S.p.A. (Italy). R.C. Cement later became wholly-owned by Unicem S.p.A. In 2000, Unicem merged with Buzzi Cementi to form Buzzi Unicem S.p.A (Italy). In 2003, Buzzi Unicem S.p.A. gained controlling interest in Dyckerhoff AG, which owned, among other companies, Lone Star Industries Inc. In 2004, RC Lonestar Inc., owned by Buzzi Unicem S.p.A. and Dyckerhoff AG, became the US parent company of River Cement. River Cement remains a wholly-owned subsidiary of RC Lonestar Inc. and is licensed to do business in Missouri, and several other states, under the trade name “Buzzi Unicem USA.”
The River Cement site consists of buildings, a laboratory, storage silos, a limestone quarry, a preheater tower with calciner, a rotary kiln, three finish mills, one raw mill, railroad spur tracks, a barge loading facility and sheds used to store cement-related products. The rest of the site is mainly open fields with paved roadways. The railroad spur tracks are currently used for cement transport. The kiln produces clinker, the main ingredient in Portland cement. The cement production process involved drying limestone, clay and sandstone and mixing it with other raw materials containing aluminum, iron and silica. River Cement then crushes and grinds the mixture into a fine powder and feeds the material, in dry powder form, into a preheater/precalciner tower. The powder enters the kiln when it is heated to a point to start the chemical reaction that makes clinker. The clinker is then cooled, stored and later ground with gypsum to make cement.
A by-product of the cement production process is a fine chalky powder waste known as cement kiln dust. River Cement disposed of the dust, which could contain hazardous constituents, in several on-site landfills. The “old” landfill, which was roughly 400 ft x 3,000 ft x 25-50 ft deep, was located in the southeast corner of the facility. It operated from 1965 to 1982 and received kiln dust, sanitary waste, brick, crushed rock, clay, spent lubricants, general plant debris and similar industrial waste. The kiln dust landfill, which was roughly 1,300 ft x 700 ft by 25-100 ft deep, was located in the northwest corner of the facility. It began operating in 1982 and received pelletized kiln dust until 2009.
A tremendous amount of energy is required in the cement manufacturing process to achieve the extremely high temperatures in the kilns. River Cement uses mainly coke and natural gas to heat their kiln system. From January 1989 to 1997, River Cement used liquid hazardous wastes fuels to supplement its fuel needs. The hazardous waste came from off-site hazardous waste generators and third party hazardous waste blenders. An environmental management firm operated the hazardous waste fuel facility at the site. The hazardous waste fuel facility received the hazardous waste in bulk tanker trucks and railcars. The liquid hazardous wastes were blended with other hazardous waste to achieve the desired characteristics. The resulting wastes were stored in tanks until used as liquid fuel.
River Cement operated one hazardous waste container storage area, with a capacity of 80 fifty-five gallon drums (4,400 gallons); one tank farm consisting of three 22,000-gallon and three 39,000-gallon hazardous waste storage tanks, with a combined capacity of 183,000 gallons; two tank truck off-loading areas, with a capacity for three trucks per unloading station; one railcar off-loading area; one railcar cleaning area; a direct burn system; a 430-foot high preheater tower with calciner and a 212-foot rotary kiln, as well as the necessary ancillary equipment such as pumps, piping systems and process control systems. River Cement stored and treated characteristic hazardous waste as well as various F-, K-, D-, P-, and U-listed hazardous wastes, as specified in their Part A permit application.
River Cement stopped burning hazardous waste fuels in May 1997. River Cement continued operating the kiln without using hazardous waste fuels until 2009. The kiln was shut down when a new kiln came online. The "old" landfill area is capped with approximately four feet of rock and the facility’s quarry haul road currently crosses this area.
Closure and Corrective Action Status
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 May 1989, River Cement submitted a Solid Waste Management Unit Review Report to the Missouri Department of Natural Resources, to be inserted in their October 1988 Part B Permit Application. The report identified 19 solid waste management units.
In February 1991, Metcalf & Eddy Inc. performed a Resource Conservation and Recovery Act, or 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 from the solid waste management units and areas of concern to the environment. The final RCRA Facility Assessment Report identified 19 solid waste management units and one area of concern that were recommended for more investigation.
In May 1997, River Cement submitted a notification letter to the department and EPA, indicating that hazardous waste fuels were no longer being used at the facility. River Cement also intended to begin closing the hazardous waste management facility, which included the hazardous waste fuel facility, two cement kilns and hazardous waste fuel feed system piping. The hazardous waste fuel facility included a tank farm, two tank truck unloading areas, a railcar unloading area and a hazardous waste container storage area. In June 1997, River Cement submitted a closure plan to the department, which the department approved on Nov. 25, 1997. Closure occurred in 1998 and the department accepted River Cement’s closure report and certification on Dec. 8, 1998.
On June 30, 1999, the department visited the facility to visually inspect all solid waste management units identified in the RCRA Facility Assessment Report and the permit application that potentially required further corrective action. The inspection was conducted to verify the existing/current locations and the physical integrity of the units. Based on the inspection, the department determined that 11 solid waste management units required further corrective action. The department and River Cement voluntarily entered into a Letter of Agreement on March 11, 2003, in an effort to simplify and streamline the corrective action process for the remaining solid waste management units identified as requiring further corrective action.
As required by the Letter of Agreement, River Cement conducted a RCRA Facility Investigation to define the horizontal and vertical extent of any contamination at the solid waste management units. River Cement submitted a RCRA Facility Investigation Report to the department and EPA in July 2005, with an addendum report in May 2009. The reports presented the results of the surface water, sediment, surficial soil, subsurface soil and groundwater samples that were collected at the facility. The groundwater sample results did not show contamination above acceptable standards. Based on the sample results and data screening from the industrial and kiln dust landfills, no further action was determined to be necessary in these areas. In the "old" landfill area, arsenic was detected in soil and sediment samples above screening levels for both residential and industrial use; however they were below natural background concentrations in Jefferson County. Benzo(a)anthracene was detected in soil samples above screening levels for residential use, but below screening levels for industrial use. Benzo(a)pyrene was detected in one sediment sample above screening levels for both residential and industrial use. The "old" landfill area is currently capped with approximately four feet of rock and the facility’s quarry haul road crosses this area. The RCRA Facility Investigation Report Addendum proposed executing an Environmental Covenant for the "old" landfill area, in order to place activity and use limitations on the property to address the contamination above unrestricted use levels. The department approved the report addendum on Feb. 15, 2011.
The Environmental Covenant for the "old" landfill area was signed by the department and River Cement and filed with the Jefferson County Recorder of Deeds in the property chain-of-title on Sept. 26, 2013. The Environmental Covenant restricts the property to non-residential land use, prohibits soil disturbance without written permission from the Department and requires notice to construction workers performing work in this area. These restrictions will ensure that unacceptable exposure to residual contamination do not occur in the future.
On Sept. 29, 2014, following required public notice and opportunity for comment, the department approved the proposed remedy of no further corrective action with institutional controls at River Cement. The department also released the facility from regulation as a former interim status hazardous waste treatment, storage, and disposal facility subject to the corrective action requirements of the Missouri Hazardous Waste Management Law and regulations. However, the activity and use limitations for the facility property (institutional and engineering controls) contained in the Environmental Covenant will continue to apply in the future.
Hazardous Waste Permit Status
River Cement previously operated a hazardous waste fuel facility and two cement kilns under the interim status portions of the federal and state hazardous waste laws and regulations, 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.
River Cement submitted their RCRA Part A Permit Application on Nov. 24, 1986, and RCRA Part B Permit Application in October 1988, with revisions submitted in December 1996. In May 1997, River Cement decided not to continue the hazardous waste permitting process and to close the hazardous waste management facility. River Cement 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.
River Cement took the steps necessary to identify, investigate, and remediate all solid waste management units and areas of concern resulting from past waste management practices. On Sept. 29, 2014, based on currently available information, the department determined no further corrective action or additional institutional controls were necessary at the facility and released the facility from regulation as a former interim status hazardous waste treatment, storage, and disposal facility subject to the corrective action requirements of the Missouri Hazardous Waste Management Law and regulations. The department’s approved remedy and regulatory release decisions were effective immediately.