Background/ History
The Jefferson Products Co. site is located on 3.75 acres at 711 Industrial Ave. in Washington, Missouri. In 1953, Jefferson Products constructed the main building at the site and began manufacturing air conditioning and refrigeration components, such as filters, dehydrators, pressure regulating values, site glasses and oil level controls. Operations included all aspects of the manufacturing process, including machining, electroplating, painting and assembly of parts. Before 1984, Jefferson Products discharged plating wastewaters directly to the local sanitary sewer system. In 1984, the City of Washington established an industrial pretreatment program and required local industries to treat their wastewaters to meet specific discharge standards set by the city. In order to meet these requirements, Jefferson Products installed a wastewater treatment system to treat plating wastewaters.
A variety of hazardous wastes were produced as part of the facility operations, including spent/waste solvents and wastewater treatment sludges from the electroplating operations. Jefferson Products stored these wastes in two hazardous waste container storage areas before shipping off-site for disposal. Jefferson Products operated the hazardous waste container storage areas under the “interim status” portions of the federal Resource Conservation and Recovery Act (RCRA). In 1985, Jefferson Products made operational changes at the facility and no longer stores hazardous waste at the facility at the facility for more than 90 days. The containers are managed under generator storage requirements in 10 CSR 25-5.
Cleanup Summary
Jefferson Products closed the hazardous waste storage areas; however, the closure was not acceptable to the department because no decontamination was performed in the area where liquid wastes were stored. On April 25, 1990, Jefferson Products entered into a Consent Decree with the department, after the department issued numerous violations and no corrections were made. The decree required Jefferson Products to not accept off-site hazardous waste (with one exception), not store hazardous wastes in excess of 90 days and comply with the “interim status” requirements until the department approved the facility’s closure plan and closure was completed. Jefferson Products submitted revisions to their closure plan in August 1990 and the department gave final approval to the plan in April 1991. Between May and October 1991, Jefferson Products conducted closure activities for the hazardous waste storage areas. The department accepted Jefferson Products closure certification for the hazardous waste storage areas in June 1992. Jefferson Products 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 areas.
Jefferson Products is subject to corrective action because they completed closure of the interim status hazardous waste areas after the effective date of the federal Hazardous and Solid Waste Amendments. Initial investigations identified heavy metal contamination in several areas that required further investigation. Jefferson Products is currently a candidate for an administrative order or Letter of Agreement to investigate and possibly remediate the areas identified at the site.
