Waste and Underground Tank Management Bureau
Loveland Products, Inc. (Transbas, Incorporated)
FACILITY FACT SHEET
Front view of the Loveland Productions, Inc. Facility
Click on Photo to Enlarge
SITE DESCRIPTION AND HISTORY
The Loveland Products, Inc. (LPI) facility occupies approximately 27 acres in Yellowstone County, outside the city limits of Billings, Montana, in the area known as Lockwood. The facility occupies Tracts 1A, 2, and 3A within Eric’s Industrial Subdivision, which is zoned heavy industrial. LPI has operated an herbicide manufacturing and formulation plant at the facility since 1975. Facility activities also include rail and truck transportation of incoming raw and intermediate materials, and outgoing finished products. LPI was formerly known as Transbas, Inc.
The herbicide formulation procedures include blending or reacting herbicides with alcohols, solvents, amines, or water to produce commercial herbicide products. Herbicides are primarily dichlorophenoxyacetic acid (2,4-D); 2-methyl-4-chlorophenoxyacetic acid (MCPA); 2-(2-methyl-4-chlorophenoxy)propionic acid (MCPP); 3,6-dichloro-2-methoxybenzoic acid (Dicamba); N-(phosphonomethyl)glycine (Glyphosate); and 4-Amino-3,5-dichloro-6-fluoro-2-pyridinyl oxy acetic acid (Fluroxypyr).
Between 1979 and 1985, 2,4-D contaminated wastewater produced from the herbicide’s formulation and manufacturing process was discharged to three surface impoundments on-site to allow evaporation of the water and concentration of the sludge. Wastes contained in the surface impoundments included liquid wastewater and sludge generated primarily in process equipment cleaning or accidental spill cleanup activities. The solid waste would be classified as hazardous wastes U240 (2,4-D, salts, and esters) and D016 (2,4-D) under the Resource Conservation and Recovery Act (RCRA).
LPI closed the surface impoundments by removing standing liquid, stabilizing the bottom sludge with lime and fly ash, and capping the impoundments with a polyethylene liner, sand, and compacted gravel. Closure of the surface impoundments was certified by the Department of Environmental Quality (DEQ) in 1987. An asphalt cap was added to the cover in 1991. In 2012, LPI excavated the solidified sludge, lime, and fly ash, and placed it in an off-site hazardous waste permitted landfill. Surrounding soil exceeding the industrial soil cleanup level for 2,4-D was also excavated and disposed off-site. The area was then backfilled to grade.
Wastewater is currently treated for process reuse in an on-site wastewater treatment system. Pre-treatment of the wastewater consists of pH adjustment, flocculation, and sedimentation to clarify the wastewater. The water is then photochemically treated using Ultra Violet (UV) light and a hydrogen peroxide oxidation process. The UV/hydrogen peroxide process destroys organic contaminants. Waste sludge generated from the treatment process is disposed at an off-site facility.
The Resource Conservation and Recovery Act (RCRA) is a Federal law which governs proper management and disposal of hazardous waste, including requirements for issuance of permits to facilities for specific on-site treatment, storage, or disposal of hazardous waste. In addition to waste management, RCRA requires cleanup of hazardous waste and hazardous constituents in environmental media at permitted hazardous waste facilities. Any off-site contamination originating from the facility must also be addressed.
The Montana Hazardous Waste Act (MHWA) is the Montana equivalent of RCRA. DEQ is the implementing state agency for MHWA.
Because hazardous waste remained in the surface impoundments when they were closed in 1987, LPI was required to have a post-closure permit that specified the requirements and appropriate procedures for long-term maintenance and monitoring of the closed surface impoundments. A hazardous waste permit was issued to LPI in 1995. The permit was replaced with a Corrective Action Order (CAO) in 2015.
As required by the previous hazardous waste permit and the current CAO, LPI must conduct facility-wide investigation and remediation of contaminated environmental media present on the facility and any contamination found off-site that originated from facility operations. Requirements of the CAO, along with other relevant regulations and guidance, provide the basis for current corrective action at the LPI facility.
CHARACTERIZING THE SITE
The owner/operator of a hazardous waste permitted facility must identify and characterize the nature and extent of all contamination present on-site and any contamination off-site that originated from the facility. They also must evaluate potential risks of that contamination to human and ecological receptors. If characterization and assessment of risk indicate cleanup is necessary, remediation technologies and engineering and/or institutional controls are evaluated to determine the best approach to cleaning up the facility. A final cleanup remedy is chosen by DEQ and is then implemented by the facility owner/operator.
Several assessments were conducted for the Loveland Productions, Inc. site, the main investigations are listed below:
RCRA Facility Assessment (RFA)
Often the first activity in the corrective action process is the RFA. The objective of the RFA is to identify potential and actual releases from areas referred to as Solid Waste Management Units (SWMUs) or Areas of Concern (AOCs) and make preliminary determinations about releases, the need for corrective action, and interim measures. Corrective action was initiated in 1990 at the LPI facility when EPA conducted an RFA to identify areas of actual and potential releases to both soil and groundwater.
RCRA Facility Investigation (RFI)
The RFI takes place when releases, or potential releases, have been identified in the RFI and further investigation is necessary. The purpose of the RFI is to gather enough data to fully characterize the nature, extent, and rate of migration of contaminants to determine the appropriate response action.
A Phase I RFI at LPI investigated 16 SWMUs and 14 AOCs. A report was completed in January 1996 and revised in April 1999. The Phase I RFI was a preliminary study to develop a further understanding of the nature and extent of the contaminant releases at the site.
A Phase II RFI report, completed in January 2002, further investigated the lateral and vertical extent of contaminants in soil and groundwater.
A site-wide risk assessment is also conducted as part of the RFI process. The risk assessment studies the health risks from potential exposure to the contaminants at the site. A screening level risk assessment identifies whether potential adverse soil or groundwater risk exists for human and/or ecological receptors. Chemicals of potential concern are identified based on samples collected during the RFI. The on-site concentrations of those chemicals are then compared to risk-based concentration limits to help determine whether cleanup of contaminants is necessary. LPI completed a screening level risk assessment in August 2005.
Corrective Measures Study (CMS)
After the RFI and Risk Assessment are completed and the regulatory agency determines if cleanup is necessary, the regulatory agency may request the owner/operator to conduct a CMS. The purpose of the CMS is to identify and evaluate cleanup alternatives, called corrective measures and/or remedies, for releases at the facility. The recommended measures are reviewed by the regulatory agency. The regulatory agency then selects what it believes is the best remedy, given the site-specific considerations.
The Soils CMS was completed in February 2008. The groundwater CMS was completed in October 2012, with an Addendum submitted November 2013.
Corrective Measures Implementation (CMI)
Once the CMS is complete, DEQ selects a cleanup remedy based on the alternatives provided in the CMS. DEQ’s proposed remedy is provided to the public for comment prior to finalization. After finalization of the cleanup remedy, a CMI Work Plan is completed, detailing the process in which the selected remedy will be constructed and implemented.
A soil cleanup remedy was provided for public comment April 1 through May 19, 2010. No comments were received and DEQ finalized the selected remedy on June 1, 2010. The selected remedy included excavation and source removal for contaminated subsurface soil in accessible areas. For subsurface soil beneath active portions of the facility, deferral of a remedy until plan closure or construction allows safe access to contaminated subsurface soil. DEQ approved the soil cleanup as complete on February 14, 2011.
A groundwater cleanup remedy is currently out for public comment; the public comment period ends July 6, 2014. The proposed groundwater remedy includes monitored natural attenuation, institutional controls, and localized enhanced bioremediation. The localized enhanced bioremediation will be implemented intermittently as determined by concentrations in groundwater monitoring wells. In addition, the proposed remedy includes requirements for further investigation and remediation of environmental media, if necessary, in all of the deferred areas at the facility. Deferred areas are inaccessible at this time due to plant operations.
A Statement of Basis and environmental assessment for the groundwater cleanup remedy are also available on DEQ’s website: http://deq.mt.gov/pubcom.mcpx and http://deq.mt.gov/ea/WasteMgt.mcpx. Instructions on submitting comments on the groundwater cleanup remedy are included in the Statement of Basis.
FOR MORE INFORMATION
Ann M. Kron
Environmental Science Specialist
Montana Department of Environmental Quality
P.O. Box 200901
Helena, Montana 59620-0901