Hazardous Waste Program
EPA ID# MOD096726484
- Former Company Name: Mallinckrodt Inc., Mallinckrodt Chemical Inc., Mallinckrodt Specialty Chemicals Co., Mallinckrodt Chemical Works
- Type of Facility: Permitted Hazardous Waste Storage – closing. *The facility no longer stores hazardous waste at the site for more than 90 days.
- Wastes Handled: Corrosives, flammables, reactives, solvents, TCLP toxic metals, as well as various F-, P- and U-listed hazardous wastes as specified in the Part A application.
- Treatment and Disposal Methods: None.
- Location of hard copies of hazardous waste permit application, Part I Permit, modification requests, reports, etc. and supporting documents:
Mallinckrodt is closing one hazardous waste management unit and conducting corrective action activities under a Missouri Hazardous Waste Management Facility Part I Permit. Due to the addition of a new container storage area and bulk storage tank for less than 90-day storage, the facility no longer stores hazardous waste at the site for more than 90 days. The status of Mallinckrodt’s corrective action activities is described below. The public can review and copy paper copies of all permits, reports and supporting documents at the agency locations above.
The Mallinckrodt site is located on about 45 acres at 3600 N. Second St. in St. Louis, about 300 feet west of the Mississippi River. A man-made levee, built by the Army Corps of Engineers, protects the facility along the riverfront from floodwater. The facility began operating in 1867, under the name Mallinckrodt Chemical Works. The name was later changed to Mallinckrodt Inc. during the late 1970s. In 1982, Mallinckrodt Inc. was purchased by Avon Products Inc. and became an independent subsidiary of Avon, but retained the name Mallinckrodt Inc. In 1986, International Minerals and Chemical Corp. purchased Mallinckrodt Inc. and divided it into two independent companies: Mallinckrodt Specialty Chemical Company and Mallinckrodt Medical Inc. Mallinckrodt Inc. retained ownership of the site. In 1994, International Minerals reorganized, changed its name to Mallinckrodt Group Inc. and changed the name of its specialty chemical subsidiary to Mallinckrodt Chemical Inc. In 1996, Mallinckrodt Chemical Inc. became the owner of the site. Mallinckrodt Group Inc. changed its name to Mallinckrodt Inc. In 1998, Mallinckrodt Chemical Inc. merged into an operating company named Mallinckrodt Inc. In June 2013, Mallinckrodt Inc. changed its name to Mallinckrodt LLC.
Mallinckrodt initially produced staple chemicals, such as aqua ammonia, spirits of nitrous ether and acetic and carbolic acids. The product line was soon expanded to include chloroform and burnt alum, used by makers of baking powder as a substitute for pure cream of tartar. In 1922, Mallinckrodt introduced a collection of reagents along with aluminum stearate, a fine powder which, when heated, formed lubricating gel systems that were used in automobiles. Mallinckrodt also developed lodeikon, the first x-ray contrast medium for visualizing the gall bladder.
From 1942 to 1957, Mallinckrodt performed uranium refining operations under contract with the Manhattan Engineering District and the Atomic Energy Commission, or AEC. The work included developing uranium processing techniques, producing forms of uranium compounds and metal and recovering uranium metal from residues and scrap. These operations and support activities occurred mainly in Plants 1, 2, 10 and later Plant 6 and 7. By July 1942, Mallinckrodt was producing tonnage quantities of uranium compounds for delivery to the University of Chicago for use in developing the first self-sustaining atomic reactor in December 1942. Mallinckrodt was the only source of purified uranium dioxide well into 1943, and continued to provide high-purity uranium for the Manhattan Project through the testing of the first nuclear weapon in the summer of 1945. After World War II, uranium refining at the St. Louis facility was performed under contract with the AEC at the former Destrehan Street plant, which was located in Plant 6. By 1957, all of the company’s uranium activities had been consolidated at the Weldon Spring, Missouri plant located west of St. Louis, Missouri.
Between approximately 1960 and 1985, Mallinckrodt used Plant 5 for processing columbium-tantalum ores. This operation was conducted under a Nuclear Regulatory Commission license since the ores contain natural uranium and thorium. Main operations conducted in Plant 5 included milling and dissolution of the ores, extraction of the tantalum and columbium, precipitation and drying of oxides or salts of these elements, collection and treatment of industrial liquid waste and temporary storage of the unwanted uranium and thorium contaminated solid waste produced during the dissolution of the ores and slags. The treated industrial liquid waste was discharged to the St. Louis Metropolitan Sewer District system. The solid waste was transported to a licensed uranium recovery facility or to a licensed disposal site. Columbium-tantalum production ended in 1985 with a short Research and Development run in 1987.
In January 1985, Mallinckrodt finished building a new 2,829 square foot hazardous waste storage area, over the existing storage area, located at the far eastern end of the facility near Building 700. The storage area was used to store hazardous waste for more than 90 days before shipping off site for disposal. The hazardous waste storage area was divided into three sections: Storage Area A, flammables and solvents; Storage Area B, reactives; and Storage Area C, corrosives and oxidizers. These three sections were separated by dikes to allow for storage of incompatible wastes. The storage area had 1,962 square feet of actual storage area, with a combined capacity of 416 55-gallon drums.
The plant’s on-site wastewater treatment system consists of two, one million-gallon equalization basins. For a period of time, the facility used spent caustic from area industries as a wastewater neutralization agent. This activity was authorized by the department under a Resource Recovery Certification. When this system was operating, spent caustic from the 5,000-gallon spent caustic storage tank, located on the east side of Building 238, was allowed to flow into the plant sewer system. Solids that accumulated as sludge in the bottom of the equalization basins were flushed once or twice per quarter with the approval of and under the direction of the St. Louis Metropolitan Sewer District.
Currently, Mallinckrodt consists of more than 50 manufacturing and support buildings covering approximately twelve city blocks. Mallinckrodt produces and distributes products used in diagnostic procedures, specialty generics, pharmaceuticals and active pharmaceutical ingredients including stearates, phosphates, and peptides, as well as analytical research samples for pharmaceutical companies and analytical laboratories. Plant support facilities include maintenance shops, research and control laboratories, warehouses, a boiler and a wastewater treatment plant. The facility also operates numerous aboveground tanks for the bulk storage of fuel and both organic and inorganic chemicals. Due to procedural changes and the addition of a new container storage area and bulk storage tank for less than 90-day storage, the facility no longer stores hazardous waste at the site for more than 90 days.
Closure and Corrective Action Status
The hazardous waste storage area was the only hazardous waste management unit located at the facility. Mallinckrodt submitted a draft closure plan for the hazardous waste storage area in September 2008, and amendments in July 2009. The department approved the closure plan, with conditions, in August 2009. Closure of the hazardous waste storage area occurred in 2010 and 2011 and included demolishing the concrete pad, excavating soil, backfilling the excavation area with clean soil and shoring some nearby structures. Mallinckrodt submitted a closure report and certification for the hazardous waste storage area in January 2012. The closure report and certification are pending final review and approval by the department.
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. The operations in Plants 1, 2, 6, 7 and 10 involved radioactive materials and resulted in some areas of the facility having residual radiological and chemical contamination. As a result, the areas associated with residual radiological and chemical contamination from AEC operations are being characterized and remediated through the Formerly Utilized Sites Remedial Action Program, or FUSRAP.
Plants 1 and 2 were involved in uranium processing from 1942 to 1945. Decontamination activities occurred from 1948 to 1950. The plants were released to the owners in 1951 without radiological restrictions. Plant 6, which replaced Plant 1, was involved in uranium processing from 1946 to 1957. Following decontamination activities, the plant was released to the owners in 1962 for use with no radiological restrictions. Plant 7, was in operation from 1951 to 1957 and was involved in storing reactor cores, uranium processing, and continuous processing of furnace green salt. Following decontamination activities, the plant was released to the owners in 1961-1962 for use with no radiological restrictions. Plant 7 is currently used primarily for storage. Plant 10 (formerly Plant 4) was involved in uranium processing from 1942 to 1956. Following decontamination activities, the plant was released to the owners in 1962 for use with no radiological restrictions. All decontamination efforts were focused to meet AEC criteria in effect at the time of the decontamination activity. Since 1962, some of the buildings have been razed and new buildings have been constructed.
The remaining areas at the site, not under FUSRAP, are regulated under the Resource Conservation and Recovery Act, or RCRA. In 1993, Metcalf & Eddy 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. A total of 28 solid waste management units and 14 areas of concern were identified during the assessment. The 1993 RCRA Facility Assessment Report identified eight solid waste management units and two areas of concern that were recommended for more investigation. In January 1998, Mallinckrodt submitted an assessment report for eight newly-identified solid waste management units at the facility, which were identified based on historic practices.
Responsibility for oversight of FUSRAP at this site was originally under the jurisdiction of the U.S. Department of Energy, or DOE, and was later transferred to the U.S. Army Corps of Engineers, or USACE, in the late 1990s. While DOE and USACE are responsible for the remediation activities associated with FUSRAP, Mallinckrodt is responsible for performing any necessary corrective action for releases of hazardous waste and hazardous constituents to the environment attributable to solid waste management units or areas of concern in FUSRAP areas that are not explicitly the responsibility of DOE. Mallinckrodt identified nine additional solid waste management units within the FUSRAP areas that needed to be investigated. Since this assessment, Mallinckrodt has identified several additional solid waste management units and areas of concern at the site.
Mallinckrodt completed several interim measures at the site in order to reduce or prevent unacceptable risks to human health and the environment from hazardous waste releases. An interim measure is an action taken to temporarily control the contamination source or the path the contamination could take from the source to humans, animals or the environment. Mallinckrodt installed a trench and sump system to remove free product associated with the No. 6 fuel oil spill; removed, cleaned and properly disposed of laboratory bottles labeled “arsenic acid powder” from the Unreacted Ore Burial excavation; and removed the asphalt pavement and gravel layer for proper disposal after a chloroform waste spill.
Between 1998 and 2001, URS Greiner Woodward Clyde conducted Phase I of a RCRA Facility Investigation, on behalf of Mallinckrodt, to define the horizontal and vertical extent of any contamination. URS submitted a draft RCRA Facility Investigation Report to the department and EPA on March 31, 1999. This report, along with other related documents submitted in 1998 and 2001 is considered to be the consolidated draft Phase I RCRA Facility Investigation Report. A total of 46 solid waste management units and 16 areas of concern have been evaluated or investigated at the facility. The department’s final review of the consolidated report and Mallinckrodt’s 2009 responses to the departments’ comments are still pending. If any corrective action, or cleanup, activities are necessary, they will be based on the investigation results.
Mallinckrodt operated the hazardous waste storage area under two hazardous waste permits issued in 1997. Mallinckrodt is currently closing one hazardous waste management unit and conducting corrective action activities under a department-issued Missouri Hazardous Waste Management Facility Part I Permit, effective Sept. 30, 2013. Mallinckrodt originally operated the Hazardous Waste Storage Area under two hazardous waste permits issued in 1997, one issued by the department and one issued by EPA. Due to the addition of a new container storage area and bulk storage tank for less than 90-day storage, the facility no longer stores hazardous waste at the site in excess of 90 days. EPA did not reissue the Hazardous and Solid Waste Amendments Part II Permit, since EPA has no site-specific conditions for Mallinckrodt and Missouri is fully authorized for all permitting activities at the site. The final Part I Permit requires Mallinckrodt to continue to perform corrective action activities at the site. Mallinckrodt will store hazardous waste under the hazardous waste generator requirements.