Background/ History
The Forest City Facility site, formerly Exide Technologies, is located on approximately 370-acres at 25102 Liberty Road in Forest City. The Forest City Facility operates a secondary lead smelting plant, formerly known as the Exide Technologies Canon Hollow Recycling Center, on approximately 70 acres. The plant has been in operation since at least 1975 and was originally owned by Schuylkill Metals Corp. In 1996, Schuylkill became a division of Exide Corp. In 2000, Exide Corp. changed its name to Exide Technologies. In July 2020, Exide Technologies sold the Canon Hollow Facility to Battery BidCo LLC, and changed the facility name to Forest City Facility LLC. Forest City Facility LLC is an indirect subsidiary of Battery BidCo.
The Forest City Facility stores and recycles lead-acid batteries and other lead-bearing hazardous and non-hazardous wastes to recover the lead, trace metals, sulfuric acid, and polyethylene plastic. Forest City Facility uses four pot furnaces and a blast furnace to smelt the recoverable lead waste, which is then resold as secondary lead. Because lead ore and other lead-bearing materials are often not pure lead, fluxing agents, such as limestone, are used in the smelting process to react with the impurities and carry them off as slag. Before 1981, the waste smelter slag was stored in three slag storage areas.
Before 1983, waste battery acid went through neutralization and sedimentation in a series of concrete pits. The effluent, or wastewater, was then discharged into a series of four lagoons. The rubber chips from the broken battery cases were stockpiled in the rubber chip storage area. Landfill 1, which operated from 1981 to 1992, was used to dispose of smelter slag, dewatered waste treatment sludge and rubber battery case chips. Landfill 2, which began operating in 1991, is currently used for disposing of treated air pollution control scrubber sludge, wastewater sludge and other waste materials.
Used or “spent” lead-acid batteries are considered a hazardous waste under Resource Conservation and Recovery Act, or RCRA, because they exhibit the toxicity characteristic for lead and the corrosivity characteristic for the sulfuric acid electrolyte in the battery. The first phase of lead-acid battery recycling, the storage and disassembly of the lead-acid batteries, is regulated under the Missouri Hazardous Waste Management Law. The Forest City Facility is operating under two hazardous waste permits, one issued by the Missouri Department of Natural Resources and one issued by the Environmental Protection Agency (EPA). The permits were first issued in 1990. The department reissued the Missouri Hazardous Waste Management Facility Part I Permit, effective Sept. 23, 2009. EPA reissued the Hazardous and Solid Waste Amendments Part II Permit, effective Oct. 25, 2009. Under the permits, Exide, now Forest City Facility, is allowed to store whole batteries and hazardous waste in containers and containment buildings, treat hazardous waste in a stabilization unit and dispose of hazardous waste produced by the facility in an on-site landfill.
Cleanup Summary
The three slag storage areas and rubber chip storage area were closed in 1981. The rubber chips stockpile was removed from the storage area and landfilled. The four effluent lagoons (surface impoundments) were closed in 1983. The contents of the lagoons were removed and treated in a wastewater treatment plant, built on site in 1983. The lagoons were then backfilled and asphalt-capped or reseeded. Exide closed Landfill 1 in 1992. The department accepted Exide’s closure report and certification; however, because hazardous waste remained in place after closure, the area is also required to go through a period of post-closure care.
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. Exide, now Forest City Facility, is conducting post-closure and corrective action activities under the same two hazardous waste permits the facility is operating under. The post-closure care activities consist of maintaining the integrity of the final cap on the closed landfill and maintaining and monitoring the groundwater monitoring system. The department is currently reviewing several reports and plans with respect to a RCRA Facility Investigation, which will be used to define the horizontal and vertical extent of any contamination. If any corrective action activities are necessary, they will be based on the investigation results.