Greenfield Environmental Multistate Trust LLC - Springfield

According to applicable state and federal hazardous waste laws and regulations, after a hazardous waste treatment, storage and disposal facility stops operating in an area on its property, that area goes through a closure period. During closure, the facility owners and operators remove and clean their equipment, structures and soil. 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 early 1972, Vich Spring, a spring located northeast of the facility, began discharging a dense black substance after moderate to heavy rainfall. The U.S. Environmental Protection Agency (EPA) sampled both Vich Spring and water and sediment from the Kerr-McGee lagoons. Creosol, a component of creosote, was confirmed in samples from both locations. No corrective measures were taken because the creosote source, and how the creosote traveled from the facility to the spring, was not established. There were also no state or federal laws in existence at that time that regulated hazardous waste management. 

Kerr-McGee closed the original lagoon before the federal Resource Conservation and Recovery Act (RCRA) existed to regulate the company’s hazardous waste management activities. Closure occurred in 1973, shortly after the Kerr-McGee finished installing Lagoon 1, and included pumping the wastewater to the other lagoons and mixing the bottom sediment sludge with straw and sawdust. The bottom sediment sludge and most of the visibly contaminated soil was removed and stored on facility property in an above ground diked area. The excavated area was backfilled with clean soil from the facility property. 

In 1976, Kerr-McGee encountered continuously wet spots in the basin floor of Lagoon 3 during its construction. In order to lower the local water table, water was pumped from a trench excavated to bedrock just north of Lagoon 2. Kerr-McGee contacted EPA after oil was discovered seeping into the trench below ground level. Kerr-McGee extended the trench to 300 feet long and pumped the water out daily to a creosote reclamation tank. The oil-water mixture was processed through the oil/ water separator. The water was discharged to Lagoon 1 and the oil was recycled back into the plant process. The trench was changed to a recovery trench and a pre-cast concrete manhole was installed so the oil-water mixture could still be removed. 

After the federal hazardous waste laws were passed in 1976, EPA conducted a groundwater contamination abatement investigation at the facility property. The investigation was to evaluate the oil in the trench and determine if there was a connection between Vich Spring and releases originating on the facility property. The sample results showed aromatic hydrocarbons and coal tar derivatives in Vich Spring. The investigation concluded the oil was coming from leaks in the bottom of Lagoon 2. Kerr-McGee redesigned Lagoon 2 and installed new liners in Lagoons 1 and 2. The bottom sediment sludge, which contained a large amount of oil, was mixed with straw and stored on the west side of the facility property in an above ground diked area. 

In 1979, Kerr-McGee submitted a plan to the Missouri Department of Natural Resources for an experimental land treatment unit to treat creosote-contaminated soil through biological landfarming. The department approved the plan and allowed Kerr-McGee to treat the bottom sediment sludge from the original lagoon in a one-acre landfarm in the northwest corner of the facility property. The landfarm was divided into three experimental plots, which were routinely disked and sampled. No waste was disposed in one plot. The two remaining plots evaluated application rates of both waste and nutrients. Kerr-McGee applied the sludge yearly from 1979 to 1981. 

State and federal hazardous waste laws and regulations require facilities that currently or formerly treat, store or dispose hazardous waste in land-based units such as landfills, surface impoundments, land treatment units and some waste piles, to carry out a groundwater monitoring program to detect and measure releases to the environment from the land-based units. In 1981, Kerr-McGee installed a groundwater monitoring system to comply with the groundwater monitoring requirements. The 1984 Groundwater Quality Assessment Plan results indicated there was a black, oily substance in some of the monitoring wells, related to past facility operations. In October 1984, the department issued an Order to Abate Violations, Order No. HW-84-015, requiring Kerr-McGee to develop a multi-phase groundwater assessment program. The department approved Kerr-McGee’s program in April 1985, which included installing monitoring wells and excavating two inspection trenches. 

In June 1985, Kerr-McGee installed a 200-foot long inspection trench between Lagoons 2 and 3, which revealed an irregular bedrock surface with creosote oil collecting in low areas. In October 1985, Kerr-McGee installed a 400-foot long inspection trench north of Lagoon 3, which wrapped inside the northeast corner of the facility property lines. The 1986 Groundwater Corrective Action: Groundwater Quality Assessment Report indicated there were two groundwater contamination plumes. One plume was located in the shallow groundwater under the lagoons and the second in a deeper groundwater aquifer under the process area. The inspection trench north of Lagoon 3 was changed to a recovery trench to catch the contaminated groundwater. All collected groundwater was pumped back to the production process through the oil/ water separator, treated and discharged to the City of Springfield sewer system. 

Kerr-McGee submitted a closure plan to the department for the three lagoons in February 1985. The department approved Kerr-McGee’s closure plan in 1986. Active closure of the lagoons began in 1987, and included pumping the wastewater back to the production process through the oil/ water separator, treating the wastewater and discharging to the City of Springfield sewer system. The bottom sediment sludge was processed through a creosote recovery system, which resulted in about 17,000 gallons of creosote recycled back to the production process. Non-recoverable creosote sludge, contaminated soil and piping were removed and shipped off site for proper disposal. The excavated lagoons were backfilled with clean soil and covered with clay caps, topsoil and vegetation. As part of the closure, a Deed Notice, filed with the Greene County Recorder of Deeds on Sept. 30, 1988, was placed in the property chain-of-title to notify any potential buyers that the closed lagoon area had been used to manage hazardous waste. The department accepted Kerr-McGee’s closure certification for the lagoons in September 1989. 

Since the creosote in the landfarm did not completely break down to non-hazardous levels, Kerr-McGee submitted a closure plan for the landfarm to the department in July 1989. The department approved Kerr-McGee’s closure plan in September 1989. Closure included grading the plots within the 12-inch dikes surrounding the landfarm and covering with vegetation. As part of the closure, a Deed Notice, filed with the Greene County Recorder of Deeds on March 9, 1990, was placed in the property chain-of-title in order to notify any potential buyers that the closed landfarm area had been used to manage hazardous waste. The department accepted Kerr-McGee’s closure certification for the landfarm in March 1991. 

Because contaminants remained in place after Kerr-McGee closed the lagoons and landfarm, these areas are required to go through a post-closure care period. As part of the post-closure care, Kerr-McGee was required to inspect and maintain the covers over the closed lagoons and landfarm, as well as operate and maintain the groundwater monitoring system. 

From 1987 to 2002, Kerr-McGee performed corrective action activities for the site under a 3008(a) Consent Order and a 3008(h) Corrective Action Order on Consent, both with EPA. The Orders required Kerr-McGee to gather information on the potential for contaminants to move to the northeast, beyond the facility property lines and carry out a corrective action program to design, build and operate technologies to clean up contaminated groundwater coming from the facility property. As also required by the Orders, Kerr-McGee submitted a Description of Current Conditions Report for the facility property to EPA. The 1989 report presented all known information regarding unit closures, environmental sampling and investigations and interim measures performed at the facility property up to that point.

As required by the Orders, Kerr-McGee also performed a RCRA Facility Investigation to determine the type and amount of waste released, where the waste was located both on and off the facility property (horizontal and vertical extent of contamination) and how fast the waste was moving (rate of migration). On behalf of Kerr-McGee, James L. Grant and Associates Inc. submitted a RCRA Facility Investigation Report to EPA in July 1992. The sample results showed soil and groundwater on the facility property and groundwater in some areas off facility property were contaminated with wastes related to the former wood treating operations. The report identified the contaminant sources as the process area, storage tank area, drip track, the original lagoon and the area where sludge from the original lagoon was temporarily stored after closure. The shallow groundwater contamination plume extended northeast and south, off the facility property. The deeper groundwater contamination plume did not extend off facility property. Contaminated sediments in the Clifton drainage, between Clifton St. and Kearney Ave., were thought to be partly related to past facility operations. Based on these results, the investigation concluded there was enough data to begin evaluating possible cleanup activities, also referred to as corrective action or remediation.

At EPA’s request, Kerr-McGee performed a Corrective Measures Study to identify and evaluate possible remedial alternatives for the soil and groundwater contamination. During this time, Kerr-McGee also performed interim measures in order to reduce or prevent unacceptable risks to human health and the environment. An interim measure is an action taken to temporarily control the contamination source or path the contamination could take from the source to humans, animals or the environment, such as air, soil, water and food. As an interim measure, Kerr-McGee changed the surface water drainage pattern near the closed lagoons, removed contaminated soil from the production process areas and installed groundwater extraction wells in the production process areas and along the northern edge of the original lagoon. On behalf of Kerr-McGee, James L. Grant and Associates Inc. submitted a Corrective Measures Study Report to EPA in July 1993. The report included Kerr-McGee’s preferred final remedy along with other remedial alternatives.

EPA , in coordination with the department, selected the best remedy from the Corrective Measures Study Report, given site-specific considerations for each solid waste management unit and area of concern. EPA prepared a Statement of Basis that summarized the remedial alternatives and EPA’s basis of support for the proposed final remedy. In August 2002, following the opportunity for public review and comment, EPA, in coordination with the department, approved the proposed final remedy and issued a Final Remedy Decision. In addition to the interim measures already put in place, the approved final remedy included continued groundwater and surface water monitoring and placing activity and use limitations on the property. 

In September 2002, the department and EPA replaced the EPA Orders with hazardous waste permits, which included the approved final remedy, along with the post-closure requirements for the closed lagoons and landfarm. As part of their groundwater monitoring program, Kerr-McGee was required to sample the groundwater twice a year to make sure the extent of groundwater contamination and the migration rate remained defined, in addition to determining whether the approved final remedy was effective. Contaminated groundwater recovered from the wells and trenches was processed through the oil/ water separator, treated and discharged to the City of Springfield sewer system. Recovered preservative was recycled back to the production process until production operations at the facility stopped in 2003. Since then, recovered preservative has been stored on-site in a holding tank and then shipped off facility property for reuse in wood treating operations at other locations. 

In late 2004, after a heavy rainfall, the City of Springfield notified the department that possible creosote-like material was coming from Woodlawn Spring, a newly-formed spring to the west of Vich Spring and next to the Golden Hills residential subdivision, located north of the facility. During a site visit in January 2005, the department, City of Springfield and facility staff observed a surface water sheen with organic odor coming from a seep on the bank of a drainage ditch in the subdivision. At the department’s request, Tronox, formerly Kerr-McGee, investigated the subdivision’s storm water detention basin and a nearby pasture area and sampled yards in the residential area. On behalf of Kerr-McGee, ENSR Corp. submitted the Woodlawn Spring Study Area Investigation Report to the department and EPA in March 2006, with revisions in 2007. All sample results from residential yards indicated there were no health concerns. Chemical fingerprinting of the seep indicated a mix of contaminants coming from several sources, including weathered creosote, oil tar and residual oil. Areas where weathered creosote was found in sediment were underground or surrounded by a fence. Oil tar in the pasture area and residual oil contamination in Vich Spring sediment were determined to be from sources other than the facility. 

Tronox continued monitoring the Woodlawn Spring discharge area until 2009, when Tronox filed for Chapter 11 bankruptcy. After taking ownership and operational control of the facility property in 2011, Greenfield continued operating the groundwater recovery system and performing the required post-closure care of the facility with limited funds initially provided by the Tronox bankruptcy settlement. Following the fraudulent conveyance lawsuit settlement agreement in 2015, additional funds became available for Greenfield to perform a Remedial Action Optimization Investigation to update the environmental conditions at the facility property and determine whether additional corrective measures are needed. 

In 2016, Greenfield updated the groundwater recovery system by installing a new line from the northeast corner of the facility to the on-site groundwater treatment plant and completed Phase 1 of the Remedial Action Optimization Investigation. The sample results from several monitoring wells in the City of Springfield right-of-way and neighboring properties northeast of the facility showed shallow groundwater is contaminated with facility-related chemicals at levels indicating vapor intrusion was possible in nearby residences. Greenfield began a vapor intrusion investigation in December 2016. Groundwater, soil gas and sewer gas samples were collected both on and off the facility property. In July and August 2017, indoor air, outdoor air and sub-slab or crawl space samples were collected at a select residences northeast of the facility. The sample results showed naphthalene levels at all the residences sampled were above the response action level. However, initial sample results indicated vapor intrusion was not occurring from the sub-slab or crawl space. The naphthalene detected in the outdoor air was a likely source of the naphthalene levels in the indoor air. 

Naphthalene is a chemical that could be related to contamination at the facility. Elevated benzene, toluene, ethylbenzene, xylene and naphthalene levels were also found in certain sewer gas samples in the same neighborhood. The levels detected in the sewer gas sampled at the facility were much lower than what was found in the sewer lines further down from the facility, where other sources could discharge into the City of Springfield sewer system. On behalf of Greenfield, CH2M Hill performed additional indoor air sampling and investigated the outdoor naphthalene levels in December 2017. The Vapor Intrusion investigation will continue until fall 2018 or later. 

In 2020, investigation began to determine the extent of off-site migration of contaminants in the groundwater. The investigation is currently ongoing and includes soil borings and groundwater sampling on the neighboring Greene County Highway Department property. Groundwater sampling will also occur on other neighboring properties, if the owners allow.