14744 N. Highway 79
Clarksville, MO 63336-2044
United States
Permanent Hard Copy Location(s)
Location of hard copies of regulatory mechanism(s) and any modifications, reports and other supporting documents.
Missouri Department of Natural Resources, Elm Street Conference Center, Jefferson City, MO 65102 (Submit a Sunshine Law Request to review or obtain copies of the department's files.)
U.S. Environmental Protection Agency, Information Resource Center, 11201 Renner Blvd., Lenexa, Kansas (Call 913-551-7241 to schedule an appointment)
Overview
Background/ History
The Holcim (US) Inc./Geocycle LLC site is located at 14744 Highway 79 North, two miles north of Clarksville. Holcim operated a wet process cement kiln, which produced clinker, the main ingredient in Portland cement. Holcim used mainly coke and coal to heat the kiln system. In 1986, Holcim began using a variety of liquid and solid hazardous waste-derived fuels, such as spent industrial chemical and petroleum-related materials, to supplement its fuel needs. The hazardous waste came from off-site hazardous waste generators or third party hazardous waste blenders or brokers. Geocycle operated the hazardous waste treatment and storage facility. Geocycle received the hazardous waste by both truck and railcar, “blended” the waste with other hazardous waste to meet fuel specifications, and stored the resulting wastes in tanks until they are used as liquid fuel.
Holcim/Geocycle operated under two hazardous waste permits, one issued by the department and one issued by the Environmental Protection Agency (EPA). The department issued the Missouri Hazardous Waste Management Facility Part I Permit, effective May 2, 2000. EPA issued the Hazardous and Solid Waste Amendments Part II Permit, effective June 16, 2000. The permits allowed Holcim/Geocycle to operate two hazardous waste container storage areas (the tank truck storage facility and the railcar storage facility), eight hazardous waste storage/treatment tanks, seven hazardous waste miscellaneous treatment processes and the kiln while burning blended hazardous wastes as alternate fuel. In November 2008, Holcim and Geocycle announced plans to close the cement production operations, including the use of hazardous waste derived fuels.
Cleanup Summary
Production stopped at the facility in 2009 and Holcim/Geocycle closed the hazardous waste management facility, which included the hazardous waste fuel facility, cement kiln and hazardous waste fuel feed system piping. The department accepted Holcim/Geocycle’s closure report and certification in October 2009. Closure activities for the remaining hazardous waste management units began in July 2012. The department accepted Holcim/Geocycle’s closure report and certification on July 5, 2013. Residual contamination left at some of the closed units was at levels requiring a deed notification but without restricting future use of the site. No post-closure activities were required.
The permits issued to Holcim/Geocycle also require them 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. Initial investigations identified a limited number of locations on site that involved potential releases of heavy metals, volatile organic compounds and semi-volatile organic compounds to soil, sediment, surface water and groundwater. Subsequent investigations and evaluations indicated that impacts to groundwater were highly unlikely. Residual contamination left after remediation efforts in two areas in 2012 and 2013, consists of polycyclic aromatic hydrocarbons and resulted in a determination to restrict future use of this area to industrial use only. Corrective action investigation and cleanup activities continued through 2017.
After a thorough technical review of several investigation reports and sampling results and opportunity for public comment, the department determined that Holcim/Geocycle closed its facility according to the approved closure plan and met the requirements of federal and state laws and regulations. On Feb. 9, 2023, the department approved the final remedy of no further corrective action with institutional controls. The institutional control is an enforceable Environmental Covenant for the facility property, which includes property activity and use limitations and continued long-term monitoring and maintenance of the engineered soil caps. In March 2023, the department and EPA terminated Holcim’s hazardous waste permits and released the facility from regulation as a hazardous waste treatment, storage and disposal facility subject to corrective action and permitting requirements. However, the activity and use limitations contained in the Environmental Covenant will continue to apply.
Operations
The Holcim/Geocycle site is located on about 3,600 acres at 14744 Highway 79 North, two miles north of Clarksville. In 1965, Dundee Cement Co. built the facility and began operating a cement plant at the site in 1967. The facility included a 760-foot wet process rotary cement kiln, numerous manufacturing structures, shipping facilities, an active quarry and other associated supporting activities. The kiln produced clinker, the main ingredient in Portland cement. The cement production process involved crushing and grinding raw material; such as limestone and shale; into a fine dust. Dundee then wet milled the raw materials by mixing the dust with water to form a slurry. The slurry was fed into the kiln and heated to the point to remove the water and start the chemical reaction that makes clinker. The clinker was then ground with gypsum to make cement.
Large amounts of fuel were used to produce the high temperatures needed for cement production. Dundee used mainly coke/coal and fuel oil to heat the kiln system. To supplement its fuel needs, Dundee also used non-conventional fuels, such tires and other non-hazardous materials. In 1986, Dundee and McKesson Envirosystems jointly developed a supplemental fuels-blending program for the plant, involving a variety of liquid and solid hazardous waste-derived fuels, such as spent industrial chemical and petroleum-related materials. The department allowed Dundee to modify the fuel firing system in the kiln to use the supplemental fuel. The waste fuel program was in operation by fall of 1986.
McKesson operated the hazardous waste receiving and blending facility, located on a 2.1-acre plot, owned by Dundee, at the facility. The hazardous waste came from off-site hazardous waste generators or third party hazardous waste blenders or brokers. McKesson received, sampled, off-loaded, stored and processed the liquid and solid hazardous wastes received at the facility. The liquid hazardous wastes were “blended” with other hazardous waste to achieve desired fuel characteristics, such as BTU value and metals and chlorine content. The resulting wastes were stored in a hazardous waste storage tank, owned by Dundee, until fed to the rotary kiln as liquid fuel. The hazardous waste was stored under the “interim status” portions of the federal Resource Conservation and Recovery Act (RCRA) until permits were issued in 2000.
In April 1987, Safety-Kleen Corp. purchased McKesson’s Clarksville operation. In 1990, Dundee merged with Holderbank, who later organized all its operations in the United States under the corporate name of Holnam Inc. The Clarksville plant’s name was changed to Holnam Inc./Safety-Kleen.
A byproduct of the cement production process is a fine chalky powder waste known as cement kiln dust. The kiln dust was moved from the rotary kiln to a pug silo, which was a steel above ground storage tank. Holnam added water to the kiln dust at the silo, for dust suppression. The cement kiln dust was then transported to the on-site landfill by a belt-type assembly, which extended from the tank to an unloading area. The on-site landfills were former quarries where raw material was mined. Holnam regularly tested the dust to make sure it was exempt from being classified as a hazardous waste.
In December 2001, Holderbank organized its operations globally under the corporate name of Holcim Inc. In July 2003, Holcim purchased the Safety-Kleen operations and formed Energis LLC, which changed its name to Geocycle LLC in September 2007. The fuels receiving, blending and shipping areas were operated by Geocycle on land owned by Holcim. In total, Geocycle operated two hazardous waste container storage areas: a tank truck storage facility, with a maximum capacity of 52,000 gallons, and a railcar storage facility, with a maximum capacity of 64,000 gallons; ten 40,000-gallon hazardous waste blend tanks and seven miscellaneous hazardous waste treatment units: four grinder pumps, one attrition mill and two tank truck and railcar washout units. Holcim stored and treated the hazardous waste in one 150,000-gallon and two 250,000-gallon hazardous waste burn tanks.
On March 23, 2010, the department, Attorney General’s Office and Holcim/Geocycle entered into a Settlement Agreement, allowing Holcim/Geocycle to place the facility in an “idle” state while Holcim/Geocycle evaluated potential options related to future facility operations. During the “idle” state, Holcim/Geocycle did not receive, store or blend hazardous waste. On Feb. 15, 2012, Holcim/Geocycle notified the department and EPA that the facility was closing. The facility property is currently inactive except for on-going monitoring and maintenance activities.
Closure & Cleanup
After a facility stops operating in an area on its property, that area goes through a closure period. During closure, the facility owners and operators put final covers or caps on landfills and remove and clean their equipment, structures and soil. According to applicable state and federal hazardous waste laws and regulations, all hazardous waste treatment, storage and disposal facilities are also required to investigate and clean up releases of hazardous waste to the environment at their facility resulting from present and past hazardous waste handling practices. Closure and corrective action investigations and remediation activities can occur at the same time.
In 1991, PRC Environmental Management 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 to the environment. The 1992 RCRA Facility Assessment Report identified five solid waste management units and two areas of concern that were recommended for more investigation.
In response to the assessment, and as part of Holnam’s permit application review process, the department conducted a site visit in March 1997 to observe and evaluate the solid waste management units and areas of concern identified for additional investigation. The department also evaluated the information contained in the assessment report, department’s files and supplemental sampling results provided by Holnam. In October 1997, the department determined no further action was required for the sludge pond at that time. Holnam built a new cement storage dome in the sludge pond area. In August 1998, the department determined the need for additional investigation of the remaining areas was not evident at that time.
Holcim/Energis, formerly Holnam, closed the attrition mill in 2006 according to their department-approved closure plan. The department accepted Holcim/Energis’ closure report and certification in November 2006. Holcim/Geocycle closed the hazardous waste management facility in March 2009, which included the hazardous waste fuel facility, cement kiln and hazardous waste fuel feed system piping. The department accepted Holcim/Geocycle’s closure report and certification on October 23, 2009.
Closure activities for the remaining hazardous waste management units began in July 2012. All concrete and metal associated with the tank truck storage facility, railcar storage facility, hazardous waste blend tanks and miscellaneous hazardous waste treatment units was decontaminated and the metal was sent for scrap metal recycling. Closure confirmation sampling results indicated residual contamination, consisting of polycyclic aromatic hydrocarbons, was present in two areas. No post-closure activities were required; however, the levels resulted in a determination to restrict future use of this area to industrial use only. A Deed Notice, signed by the Pike County Register of Deeds on April 19, 2013, was placed on the property in order to inform potential future buyers of the property that the site had been used to manage hazardous wastes. The department accepted Holcim/Geocycle’s closure report and certification for the remaining units on July 5, 2013.
Holcim performed additional corrective action activities at the site, including further investigation into the remaining solid waste management units and areas of concern. Based on currently available information, no additional cleanup is required at the facility. After a thorough technical review of several investigation reports and sampling results and opportunity for public comment, the department approved the final remedy of no further corrective action with institutional controls. The institutional control is an enforceable Environmental Covenant for the facility property, which includes property activity and use limitations and continued long-term monitoring and maintenance of the engineered soil caps.
Oversight
Holcim/Geocycle operated 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 May 2, 2000. EPA issued the Hazardous and Solid Waste Amendments Part II Permit, effective June 16, 2000. These permits allowed Holcim/Geocycle to store and treat “characteristic” hazardous waste, as well as various F-, K- P- and U-listed hazardous wastes as specified in the Part A application. The regulated units consisted of a tank truck storage facility, a railcar storage facility, ten hazardous waste blend tanks, three hazardous waste burn tanks and seven miscellaneous hazardous waste treatment units. These permits also required corrective action in the event there was a release of hazardous waste or hazardous constituents to the environment. On January 8, 2009, the department approved Holcim/Geocycle's Class 2 Permit Modification request, allowing the facility to build a 3-inch recirculation pipe to connect burn tanks two and three.
Holcim/Geocycle submitted a permit application on Oct. 29, 2009, to renew their existing hazardous waste permits. Holcim/Geocycle's existing Part I Permit expired May 2, 2010, and Part II Permit expired June 16, 2010. State and federal regulations, 40 CFR 270.51, allowed the existing hazardous waste permits to continue in effect until the department and EPA issued or deny new hazardous waste permits. On Feb. 15, 2012, Holcim/Geocycle withdrew their permit application and began closing the facility. The hazardous waste permits were continued in effect until the department made a final determination regarding any corrective action, or cleanup.
Holcim/Geocycle’s site closure and corrective action activities lasted through 2017, and occurred under the same two hazardous waste permits the facility operated under. On Feb. 9, 2023, the department approved the final remedy of no further corrective action with institutional controls. In March 2023, the department and EPA terminated Holcim’s hazardous waste permits and released the facility from regulation as a hazardous waste treatment, storage and disposal facility subject to corrective action and permitting requirements. However, the activity and use limitations contained in the Environmental Covenant will continue to apply.
Documents
Listed below are the currently effective regulatory mechanism(s) and any modifications, institutional controls and any supporting documents regarding this property that the department currently has available in electronic form. The department realizes some of the electronic files can be quite large, which may result in long download times for individuals with slow internet connections. If you have any problems accessing these documents, please contact the department’s Waste Management Program by telephone at 573-751-5401 or 800-361-4827, or by email at wmp@dnr.mo.gov.
You can review printed copies of all regulatory agreements, reports and other supporting documents at the department’s Elm Street Conference Center in Jefferson City, Missouri. To review or obtain copies of the department’s files, please submit a Sunshine Law Request.
Regulatory Agreement
| Other File(s) | Other File Date |
|---|---|
| Statement of Basis | |
| Approved Final Remedy Decision | |
| Executed Environmental Covenant |