EPA ID# MOD085908259

MoDNR Contact: Chris Kump-Mitchell, 314-416-2464 or 800-361-4827
EPA Contact: Robert Aston, 913-551-7392 or 800-223-0425
Facility Contact: Louis Dell'Orco, 314-291-6720
Last Updated: Jan. 8, 2020

  • Former Company Name: Purina Mills Inc.
  • Type of Facility: Former Hazardous Waste Storage – closed.
  • Wastes Handled: Arsenic, pesticides (as specified in the Part A permit application), .
  • Treatment and Disposal Methods: Land disposal – closed.
  • Location of hard copies of hazardous waste permit application, Part I and Part II Permits, modification requests, reports, etc. and supporting documents:

Current Activities

Proposed Final Remedy Issued: The department, in coordination with the U.S. Environmental Protection Agency (EPA) Region 7, prepared a Statement of Basis in support of a proposed final remedy for the PM Resources Inc. facility. The department invites the public to review and offer written comments on the proposed final remedy until Feb. 7, 2020. During the public comment period, anyone can request a public meeting or public hearing about the proposed final remedy. For more information, please contact Christine Kump-Mitchell, PE, by telephone at 314-416-2464 or 800-361-4827.

PM Resources currently is conducting corrective action investigations and remediation activities at the site under a Consent Judgment with EPA. The status of PM Resources’ corrective action activities is described below. On Nov. 16, 2018, PM Resources submitted a Final Remedy Selection and Implementation Report, which identified and evaluated possible corrective measure alternatives, including PM Resources' preferred final remedy. After a thorough technical review of PM Resources' preferred final remedy and other remedial alternatives, the department, in coordination with EPA, prepared a Statement of Basis that summarizes the remedial alternatives and the department and EPA’s basis of support for the proposed final remedy. The proposed final remedy includes property activity and use limitations in the form of an enforceable Environmental Covenant and long-term groundwater monitoring.

The public can review and copy the Statement of Basis, draft Environmental Covenant and supporting documents at the St. Louis County Library's Bridgeton Trails Branch, 3455 McKelvey Road, Bridgeton, Missouri (during normal business hours) or the agency locations above.

 

The PM Resources Inc. facility is a closed hazardous waste storage facility, located on about 37 acres at 13001 St. Charles Rock Road in Bridgeton. Before 1970, the site was used for agriculture, mainly to grow various crops. In December 1970, Health Industries, which was part of the Chow Division of Ralston Purina, built the plant and began producing animal health products at the site. In October 1986, British Petroleum purchased the agricultural division of Ralston Purina and the facility’s official name became Purina Mills Inc. In 1993, PM Resources, a private Missouri corporation, purchased the facility and went public as AgriNutrition Group in 1994. In 1999, AgriNutrition Group merged with Virbac Corp., a U.S. corporation owned by Virbac SA headquartered in France.

The site consists of a three-story building, which houses office space, a processing building, and warehouses. Between 1970 and 2015, the facility was used to produce pharmaceuticals, medicated feeds, rodenticides, sanitizers, cleaners, and various pesticide products used on and around animals. Since about 2015, the facility strictly produces animal pharmaceuticals. A variety of hazardous wastes were produced as part of the facility operations. These hazardous wastes were stored in one container storage area, with a total maximum capacity of eighty 55-gallon drums, and one 16,000-gallon underground storage tank, located along the east side of the building. A 1,200-gallon concrete spill catchment tank was located at the off loading area to collect and contain spills. Wash water from production cleaning was stored in two above ground hazardous waste storage tanks. The wastes were ultimately shipped off-site for disposal at other facilities designed and permitted to handle that waste.

After a facility stops operating in an area on its property, that area goes through a closure period. During closure, facility owners and operators remove and clean their equipment, structures and soil. Health Industries closed a drum storage area outside the receiving warehouse in 1979 and disconnected a basin tank from the sewer system in 1986. In September 1994, PM Resources removed the spill catchment/tank system. In 1997, PM Resources closed the container storage area inside the process area and the 16,000-gallon underground storage tank in place, according to the department-approved closure plan.

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 to the environment from its facility resulting from present and past hazardous waste handling practices. While removing the spill catchment/tank system, it became apparent that a hazardous waste release had occurred at that location. Initial investigation results showed relatively high amounts of ethylbenzene, xylenes and TPH in the soil immediately surrounding the catchment/tank area. Several investigations and sampling results detected benzene, naphthalene, xylenes, chlorobenzene, methylene chloride, herbicides, pesticides and toxaphene in groundwater above site-specific screening levels. In 2001, Virbac, formerly PM Resources, submitted a remedial action plan to address the issues raised during the investigations.

In 2006, Virbac proposed to construct a new building over the location of the 16,000-gallon underground storage tank. The facility submitted a work plan to investigate the soil and groundwater in the vicinity of the tank. Low concentrations of miscellaneous volatile organic compounds were identified along the perimeter area. Between 2006 and 2007, the tank and approximately 213.5 tons of impacted soil were removed and properly disposed off-site. Approximately 1,200 gallons of groundwater was also removed from the borings for the piers and incinerated off site. Construction of the new building was completed in 2008.

At the department’s request, Virbac performed a human health risk assessment for the contaminated areas. This process involved gathering information and using risk factors to evaluate the risk posed to human health or the environment by the actual or potential release of specific hazardous wastes or hazardous substances. Virbac submitted the final risk assessment to the department and EPA in 2012. In 2014, Virbac conducted indoor air sampling to determine if vapors from residual contamination in soil and groundwater from the closed underground storage tank was traveling through the soil and entering the building. Sample results indicated workers at the facility were not at risk. In 2014, Virbac built a Research Lab next to the north side of the receiving warehouse. In 2015, eleven above ground storage tanks located northeast of the finished product warehouse were cleaned, removed and transported to a recycling facility for proper disposal. In 2016, while renovating and installing a new product line, approximately 290 tons of soil was removed and properly disposed off-site.

At the department's request, Virbac performed a corrective measures study to identify and evaluate possible remedial alternatives for the residual contamination. On behalf of Virbac, the RAM Group submitted a Remedy Selection Report to the department and EPA in May 2017, with revisions submitted in November 2018. The report included Virbac’s preferred final remedy along with other remedial alternatives. The department, in coordination with EPA, selected the best remedy given site-specific considerations for each area of concern. The department prepared a Statement of Basis that summarizes the remedial alternatives and the department’s basis of support for the proposed final remedy. The public has been invited to review and comment on the proposed final remedy during a 30-day public comment period, which ends Feb. 7, 2020.

When EPA implemented the federal hazardous waste laws under the Resource Conservation and Recovery Act (RCRA) in 1980, all existing facilities that treated, stored or disposed hazardous waste in a way that would require a hazardous waste permit were required to notify EPA and apply for the permit or close those operations. Because of the large number of existing facilities, Congress set up requirements that allowed these facilities to operate temporarily under “interim status” until it received its permit. The facility was granted interim status.

Purina Mills, and later PM Resources, operated at the site under two hazardous waste permits, one issued by the department and one issued by the Environmental Protection Agency (EPA), both effective May 25, 1987. The permits expired on May 25, 1997, and were not reissued. On Nov. 22, 1999, the St. Louis County Circuit Court authorized a Consent Judgment between the department and PM Resources, Cause No 98CC-003995. The Consent Judgment required PM Resources to close the hazardous waste management units and investigate and clean up releases of hazardous waste and hazardous constituents to the environment at their facility. The Consent Judgement is still in effect, and regulates the corrective action investigations and remediation activities at the site. Virbac facility operations are regulated by the Food and Drug Administration (FDA).