Public Comment Period for Proposed Permit Termination

INTRODUCTION

EPA Region 7 and the Missouri Department of Natural Resources (MDNR) are proposing to terminate the former Solutia, J.F. Queeny facility’s hazardous waste permits and release the facility from regulation as a hazardous waste treatment, storage and disposal facility subject to the corrective action and permitting requirements of the Missouri Hazardous Waste Management Law and regulations, and federal Hazardous and Solid Waste Amendments to the Resource Conservation and Recovery Act (RCRA). EPA and MDNR invite the public to review and offer written comments on the proposal from May 10, 2019, through June 24, 2019.

BACKGROUND

The Solutia Inc., John F. Queeny Plant is located on 38 acres at 201 Russell Boulevard in St. Louis. The Queeny Plant was founded in 1901 under the name Monsanto Chemical Works. In 1933, Monsanto Chemical Works changed its name to Monsanto Chemical Co., then changed its name again in 1964 and became the Monsanto Co.

From 1901 until operations stopped in 2006, the facility manufactured over 200 products using over 800 raw materials. The major products included industrial chemicals, chemical intermediates, herbicides, pesticides, food additives, and pharmaceuticals. A variety of hazardous wastes were produced as part of the facility operations. The hazardous waste was stored in tanks and drums before being shipped off-site for disposal or treated in Monsanto’s incinerator. Monsanto operated under two hazardous waste permits, one issued by EPA and one issued by MDNR, both effective Nov. 8, 1989. MDNR issued the Missouri Hazardous Waste Management Facility Part I Permit. EPA issued the Hazardous and Solid Waste Amendments Part II Permit.

Between 1984 and 1996, Monsanto removed and properly disposed all drums containing hazardous waste from the site and closed the hazardous waste incinerator, tank storage area, and container storage areas. In 1997, Monsanto spun off its chemical divisions, which became Solutia Inc. Operations at the facility stopped in 2006, and Solutia removed all underground storage tanks from service and demolished the remaining structures on the property. In 2008, Solutia sold the majority of the facility property to SWH Investments II and Environmental Operations Inc. for redeveloping the site for light industrial and commercial use.

CORRECTIVE ACTION ACTIVITIES

According to applicable federal and state 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. Environmental Operations, in affiliation with SWH Investments, assumed responsibility for the environmental obligations for the property. In 2009, SWH Investments and Environmental Operations entered into a Corrective Action Order to complete site investigations and carry out corrective measures to address any site contamination.

Initial investigations identified soil and groundwater contaminated with herbicides, pesticides, metals, volatile and semi-volatile organic compounds, and polychlorinated biphenyls (PCBs), and several areas that required further investigation. Environmental Operations performed several corrective measures to minimize the further spread of contamination and clean up the hazardous waste releases. These corrective measures included removing several hundred tons of soil contaminated with PCBs and injecting oxygen-releasing material into the soil to remove volatile organic compounds from the soil and groundwater. As an added precaution, an Environmental Covenant, which imposes legally enforceable activity and use limitations on the property, and which will remain a permanent record in the chain-of-title for the property, was filed with the city of St. Louis Recorder of Deeds on April 26, 2018. The covenant restricts the property to non-residential use and prohibits drilling or using groundwater beneath the property and disturbing the soil.

On April 30, 2018, following required public notice and opportunity for public comment, EPA approved the Proposed Final Remedy of groundwater monitoring and land-use restrictions. Ultimately EPA determined there are no significant releases to the soil or groundwater at the Solutia, J.F. Queeny facility and no further corrective action is necessary.

PROPOSED PERMIT TERMINATION

The Solutia Queeny Part I and Part II permits expired Nov. 8, 1999. The hazardous waste permits were continued in effect, as allowed by Code of State Regulations 10 CSR 25-7.270(1) and Code of Federal Regulations 40 CFR 270.51. Since corrective action is no longer necessary at the facility, EPA and MDNR propose to terminate the hazardous waste permits and release the facility from regulation as a hazardous waste treatment, storage and disposal facility subject to the corrective action and permitting requirements of the Missouri Hazardous Waste Management Law and regulations, and federal Hazardous and Solid Waste Amendments to RCRA.

FOR COMMENTS AND MORE INFORMATION

EPA and MDNR invite the public to review the Administrative Record and offer written comments on the proposal from May 10, 2019, through June 24, 2019. The Administrative Record is available for review during normal business hours at these locations: