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Fact Sheet
August 2014
Public Comment for Statement of Basis and Proposed Final Remedy for Cleanup, BASF Corporation ‐ Hannibal Plant, 3150 Highway JJ, Palmyra, Marion County, Missouri
INTRODUCTION
EPA Region 7 invites the public to comment on the Resource Conservation and Recovery Act (RCRA) Statement of Basis and the proposed final remedy for the BASF Corporation (BASF) facility (EPA ID # MOD 050226075) in Palmyra, Missouri. The public comment period will run from August 27, 2014 through September 26, 2014.
Written comments should be mailed or emailed no later than September 26, 2014, and should be sent to:
Michael Dandurand
EPA Region 7 (AWMD/WRAP)
11201 Renner Blvd.
Lenexa, KS 66219
Email: dandurand.michael@epa.gov
BACKGROUND
BASF is located at 3150 Highway JJ, Palmyra, Missouri, in Marion County. The BASF property occupies approximately 1,800 acres located in Sections 10, 11, 14, 15, 22, and 23 Township 3 South, Range 5 West, of which approximately 250 acres is subject to corrective action (Facility). The site is bounded by surface waters to the northwest (South River), the north (Mississippi River), the west (North River), and to the east and southeast (Rock Ridge Slough and the Bay de Charles).
In 1990, EPA issued BASF a Part 2 Hazardous and Solid Waste Amendments Permit and a Part 1 Missouri Hazardous Waste Management Facility Permit for the operation of a hazardous waste treatment and storage facility.
Between 1965, when they purchased the property, and 1979, American Cyanamid Company, now known as Wyeth Holding Corporation (and currently owned by Pfizer), built facilities for the following:
- Ammonia storage and loading
- Ammonium nitrate production
- Nitric acid production
- Di-calcium phosphate production
- Insecticide production
In 1971, the di-calcium phosphate production facility and 12 acres in the north-central portion of the facility were leased to Alpharma, which manufactured animal feed intermediates at the AFI Plant. Alpharma's manufacturing operations at the AFI Plant were discontinued in 2003.
In 1978 and 1979, the herbicide plant area was constructed after an explosion destroyed the original herbicide plant in 1977. The facility currently manufactures agricultural chemicals including herbicides and insecticides.
BASF purchased the facility on July 1, 2000, and is the current owner and operator; however, Wyeth Holdings Corporation (Pfizer) retains financial responsibility for certain historical environmental matters.
ENVIRONMENTAL INVESTIGATIONS AT BASF
In 1987, a Preliminary Review/Visual Site Inspection Report (VSI) at the facility documented the identification and inspection of 42 SWMUs and six areas of concern (AOCs). EPA recommended additional action or investigation at three of the SWMUs and four of the AOCs.
- In December 1995 and January 1996, a Geoprobe™ Groundwater Assessment was completed in the eastern half of the Facility. The assessment included installation of 50 Geoprobe™ borings, collection and analysis of 50 groundwater samples for Volatile Organic Compounds (VOCs).
- In a March 23, 2000 letter, EPA required further investigation of the impacted groundwater which contained detectable concentrations of VOCs that were investigated during the 1995/1996 Geoprobe™ Groundwater Assessment.
- A focused source characterization program consisting of 36 source characterization borings was completed based on an extensive review of historical site operations and environmental data from previous investigations.
- During the Phase I RCRA Facility Investigation (RFI), 21 direct push borings were installed across the site in 2003 and 28 additional direct push borings were installed in 2004 as part of the groundwater characterization program to supplement and compare against groundwater quality data collected during the groundwater assessment in 1995 and 1996.
- The Phase II RFI fieldwork was conducted from July 2005 through May 2006. The Phase II RFI was a focused source area characterization program consisting of 57 soil source characterization borings.
Based on the results of the RFI conducted at the site, five confirmed soil source areas were identified. In addition, four possible soil source areas were identified but could not be confirmed because of the presence of shallow groundwater and local elevated shallow groundwater concentrations.
Groundwater sampling conducted during the RFI indicated that two of the constituents of concern (Chlorobenzene, also known as monochlorobenzene or MCB, and 1,2-dichloroethane or 1,2-DCA) are consistently reported in the groundwater at the site. The concentrations and areal extent of MCB and 1,2-DCA varies between the three primary hydrostratigraphic units (shallow, intermediate, and deep) underlying the site.
PROPOSED FINAL REMEDY
EPA is proposing the following corrective measures to address contamination at the BASF facility:
Facility Groundwater Contamination- Operate the current Interim Measure pump and treat system that incorporates air stripping technology to remove pollutants from groundwater and to manage groundwater migration.
- Monitored natural attenuation, which uses natural degradation processes to reduce contaminant mass.
- Utilize groundwater monitoring wells to document contaminant plume containment and reduction in contaminant concentrations.
- Annual status reports in accordance with permit conditions.
- Engineering controls to limit exposure to soil using existing buildings, piping and operational infrastructure.
- Establish work practice controls: Soil Excavation Management Plan and a Safety Work Permit Program to minimize exposure.
- Establish governmental controls following the Missouri Environmental Covenants Act to protect engineering controls.
- Soil source removal and in-situ treatment technologies will be used to remove soil contamination during future facility demolition, renovation or other activities that may expose soil contamination.
FOR MORE INFORMATION:
EPA encourages the public to review the Administrative Record and provide comments. Comments or requests should be submitted by September 26, 2014.
Guidelines for Commenting:- Explain your views.
- Tell us if you support or disagree with the recommendation. Please be specific.
- Can you provide alternatives?
The Administrative Record is available at:
EPA Region 7 Records Center
11201 Renner Blvd.
Lenexa, Kansas 66219
Phone: 913-551-7166
Hours: Mon - Fri., 9 a.m. - 3 p.m.
A public hearing has not been scheduled, but will be held if there is sufficient public interest. Requests for a public hearing must be made in writing to the EPA contact at the address listed above and must state the nature of issues to be raised at the hearing. EPA will evaluate any request and hold a formal hearing if EPA determines that a hearing will contribute to the decision-making process by clarifying significant issues affecting the remedy.
EPA will make the final remedy selection only after the public comment period ends and all comments are reviewed. EPA may modify the remedy based on any new information and comments from the public.
Individuals may write to the EPA contact below to join the mailing list. Joining the mailing list will allow an individual to receive any updated information directly throughout the permitting process. If you have questions or want to receive further information about the mailing list, please contact:
Emily Albano
Office of Public Affairs
U.S. EPA Region 7
11201 Renner Blvd.
Lenexa, KS 66219
Phone: 913-551-7860
Toll free: 1-800-223-0425
Email: albano.emily@epa.gov