Background/ History
The SpecGX LLC site, formerly Mallinckrodt LLC, is located on approximately 45 acres at 3600 N. Second St. in St. Louis. The facility began operating in 1867, and initially produced staple chemicals, such as aqua ammonia, spirits of nitrous ether and acetic and carbolic acids. In 1922, Mallinckrodt introduced a collection of reagents along with aluminum stearate. From 1942 to 1957 Mallinckrodt performed uranium refining operations under contract with the Manhattan Engineering District and the Atomic Energy Commission. Between approximately 1960 and 1985, Mallinckrodt processed columbium-tantalum ores. This operation was conducted under a Nuclear Regulatory Commission license because the ores contain natural uranium and thorium. Currently Mallinckrodt produces and distributes products used in diagnostic procedures, specialty generics, pharmaceuticals and active pharmaceutical ingredients.
In 1984, Mallinckrodt built a hazardous waste storage area over an existing storage area, to store flammables, solvents, reactives, corrosives and oxidizers for more than 90 days until shipped off-site for disposal. Mallinckrodt operated under two hazardous waste permits, one issued by the department and one issued by the Environmental Protection Agency (EPA), originally issued in 1997. Mallinckrodt changed its name to SpecGX LLC in April 2017. The department reissued the Missouri Hazardous Waste Management Facility Part I Permit in 2013 and 2023. EPA has not reissued the Hazardous and Solid Waste Amendments Part II Permit since 1997, since EPA has no site-specific conditions for Mallinckrodt, now SpecGX, and Missouri is fully authorized for all permitting activities at the site.
Cleanup Summary
Mallinckrodt closed the hazardous waste storage area in 2010 and 2011. Mallinckrodt submitted a closure report and certification for the hazardous waste storage area on Jan. 18, 2012, which are pending final review and approval by the department. Due to procedural changes and the addition of a new container storage area and bulk storage tank for less than 90-day storage, the facility no longer stores hazardous waste at the site for more than 90 days. The containers are now managed under generator storage requirements in 10 CSR 25-5.
The permits issued to SpecGX LLC, formerly Mallinckrodt LLC, require them to investigate and clean up releases of hazardous waste and hazardous constituents to the environment at the facility resulting from present and past hazardous waste handling practices. The operations in parts of the facility involved radioactive materials and resulted in some areas of the facility having residual radiological and chemical contamination. As a result, the areas associated with residual radiological and chemical contamination are being characterized and remediated by the U.S. Army Corps of Engineers through the Formerly Utilized Sites Remedial Action Program (FUSRAP). The remaining areas at the site not under FUSRAP, are regulated under the Resource Conservation and Recovery Act (RCRA).
SpecGX is conducting corrective action activities at the site under a Missouri Hazardous Waste Management Facility Part I Permit, reissued Oct. 2023. Prior investigations identified several areas at the site as needing more investigation. Mallinckrodt installed a trench and sump system to remove free product associated with a fuel oil spill; removed, cleaned and properly disposed of laboratory bottles labeled “arsenic acid powder”; and removed the asphalt pavement and gravel layer for proper disposal after a chloroform waste spill. Mallinckrodt conducted a RCRA Facility Investigation to define the horizontal and vertical extent of any contamination. A draft RCRA Facility Investigation Report was submitted to the department and the Environmental Protection Agency (EPA) on March 31, 1999. The draft RCRA Facility Investigation Report, along with other related documents submitted in 1998 and 2001, are pending final review and approval by the department. What, if any, cleanup activities necessary will be based on the investigation results.
