Waste and Underground Tank Management Bureau
Loveland Products, Inc. (Transbas, Incorporated)
FACILITY FACT SHEETLocation Map
SITE LOCATION AND HISTORY OF CONTAMINATION
The Loveland Productions, Inc. 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. Loveland Productions, Inc. has operated a 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.
The herbicide formulation procedures include blending or reacting phenoxyalkanoic acid herbicides, primarily dichlorophenoxyacetic acid (2,4-D), 2-methyl-4-chlorophenoxyacetic acid (MCPA), and 2-(2-methyl-4-chlorophenoxy)propionic acid (MCPP) with alcohols, solvents, amines, or water to produce commercial herbicide products.
Between 1978 and 1985, 2,4-D-contaminated wastewater, produced from the herbicide’s formulation and manufacturing process, was discharged to three surface impoundments to allow evaporation of the water and concentrations 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). Contaminants in the impoundments consisted primarily of 2,4-D, MCPA, MCPP, and their associated phenolic breakdown products. These impoundments were designed to receive diluted rinse water from the facility. Boiler blowdown and water softener regeneration waste products were also routed to the impoundments.
Loveland Productions, Inc. 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 was certified by the Department in 1987. An asphalt cap was added to the cover in 1991.
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 groundwater corrective action program was initiated in 1983 due to detection of hazardous waste constituents in the groundwater. Pumping wells removed contaminated groundwater, which was then sent through a carbon treatment system to remove 2,4-D and phenols. The treated water was then re-injected into the aquifer. This program was altered in 1987 to an in-situ bioremediation system and includes a series of recovery, pumping, and injection wells designed to control groundwater flow and aerate the groundwater to enhance biological degradation of the contamination. In September 2002, the aeration system was turned off due to its apparent inability to influence the remediation of contaminated groundwater. The contribution of contamination from the closed impoundments has been determined to be minimal and contamination does not appear to be moving off-site.
HAZARDOUS WASTE OPERATING PERMIT BACKGROUND
Under RCRA and Montana Hazardous Waste Act (MHWA) regulations, Loveland Productions, Inc. was required to obtain a hazardous waste operating permit from the State. In January 1993, the State of Montana issued a hazardous waste permit for the Loveland Productions, Inc. facility. Because of the presence of hazardous waste left in the surface impoundment, Loveland Productions, Inc. was required to have a post-closure permit that specifies the requirements and appropriate procedures for maintaining and monitoring the closed surface impoundments. Post-closure care currently includes groundwater monitoring and sampling and inspection programs.
The State of Montana reissued the post-closure permit for the Loveland Productions, Inc. Site on June 1, 2004. The current permit will expire in 10 years, June 1, 2014.
CORRECTIVE ACTION PERMIT BACKGROUND
The Environmental Protection Agency (EPA) issued a HSWA Permit for the Loveland Productions, Inc. site in 1993. The HSWA permit required Loveland Productions, Inc. to investigate site-wide contamination, as opposed to the surface impoundments regulated under the States’ permit. Loveland Productions, Inc. was required to develop a corrective action plan to clean up any contamination from past operations at the site. The corrective action process consists of several stages of investigation and clean-up. On December 26, 2000, the DEQ was authorized by EPA to implement the requirements of HSWA. The current hazardous waste permit incorporated corrective action requirements and replaced EPA's 1993 corrective action permit.
CHARACTERIZING THE SITE
Before a cleanup plan can be developed, it is necessary to conduct a thorough investigation of a hazardous waste site to determine the types and amounts of contamination that may be there and the hazards they may present.
Investigating the Site. Several assessments were conducted for the Loveland Productions, Inc. site, the main investigations are listed below:
- RCRA Facility Assessment
- RCRA Facility Investigation (RFI) Phase I
- RCRA Facility Investigation (RFI) Phase II
- Human Health Risk Characterization
- Ecological Risk Characterization/Assessment
FACILITY-WIDE CLEANUP PLAN
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 SWMUs / AOCs and make preliminary determinations about releases, the need for corrective action, and interim measures. The EPA completed the RFA for Loveland Productions, Inc. in 1990.
RCRA Facility Investigation (RFI)
The RFI takes place when releases, or potential releases, have been identified 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 Loveland Productions, Inc. 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. The risk assessment studies the health risks from potential exposure to the contaminants at the site. Loveland Productions, Inc. completed a screening level risk assessment in August 2005. Findings from the screening level risk assessment are summarized below:
Summary of Site Risks. As part of the RFI, Loveland Productions, Inc. conducted a Screening Level Human Health and Ecological Risk Assessment. A screening level risk assessment identifies whether potential adverse soil or groundwater risks exist for human and/or ecological receptors.
For purposes of the risk assessment, Loveland Productions, Inc. was divided into four exposure areas located within the confines of the facility. Site data obtained from soil and groundwater samples were evaluated by comparing the sample’s analytical results to specific screening standards.
The chemicals of potential concern in the risk assessment were based on site samples collected during the RFI. The chemicals of potential concern were chlorinated herbicides, semi-volatile organic compounds (including polycyclic aromatic hydrocarbons), and volatile organic compounds.
Human Health Risk Characterization
In the human health evaluation in the risk assessment, Loveland Productions, Inc. evaluated the potential risks to current and future on-site workers, future on-site construction workers, and residential use of the site. Exposure pathways evaluated were incidental ingestion of soil, dermal contact with soil, and inhalation of airborne particulates and volatile compounds released form soil to ambient air. Loveland Productions, Inc. completed a draft Human Health Risk Assessment in May 2002 and completed a Final Risk Assessment Addendum in August 2005.
The risk assessment found the following:
- Study Area 1, the industrial soil preliminary remediation goal (PRG) was exceeded for MCPA at one subsurface soil location.
- Study Area 2, 1,2,4-trimethylbenzene and 1,3,5-trimethylbenzene exceeded the industrial standard in surface soil at 2 locations and in the subsurface soil at 3 locations.
- Study Area 3, diallate exceeded the industrial standard in surface soil at 1 location and subsurface soil at 4 locations.
- Study Area 4 is site-wide groundwater and is being addressed in a separate CMS and Statement of Basis.
Site-Specific Risk Assessment
In 2007, during development of the corrective measures study (as described below), Loveland Productions, Inc. conducted a SESOIL site-specific risk assessment and a soil leaching model to further refine the assessment of the site pertaining to exposure and risk. The results of the site-specific risk assessment and SESOIL leaching model focused additional evaluation only on those areas with exceedances that were determined from previous risk assessment work (described in the bullets above).
SESOIL Conclusions. Through SESOIL modeling, Loveland Productions, Inc. was able to determine whether there was potential leaching of the maximum detected chemicals of concern (COC) concentrations in soil at the site. The modeling results showed all COCs are expected to leach to groundwater at levels below the established groundwater standard. Therefore, based on the findings of the SESOIL modeling, soil leaching to groundwater is not a concern and further evaluation was not required.
Site-Specific Risk Assessment Conclusions. Exposure assumptions for the site-specific risk-based action levels were based on current and anticipated site use for the industrial worker and construction worker. The exposure assumptions were used to develop intake factors and risk-based action levels.
Exposure pathways for the industrial worker and construction worker included incidental ingestion, dermal contact, and inhalation of particulates from soil. Both surface and subsurface soil exposure was considered for the construction worker, and surface soil exposures were considered for the industrial worker. Risk based action levels were developed for comparison to the specific site locations and chemical exceedances identified in the risk assessment.
Risk based action levels are concentrations in soil and groundwater that result in adverse health effects. However, risk based action levels differ from screening levels in that they have site-specific significance, integrating exposure and toxicological assumptions specific to the site.
To determine if potential risk is present, risk-based action levels were compared directly to concentrations detected at each sampling point. Through this process, it was determined that exceedances of MCPA in one sample location, at 6 feet below ground surface located in Study Area 1, exceeded the construction worker risk-based action level.
The screening level risk assessment exceedances found in study areas 2 and 3, as described in the bullets above, were found to be below their construction worker and industrial worker risk-based action levels from the site-specific risk assessment.
Ecological Risk Characterization
A screening level ecological risk assessment (SLERA) was conducted for the Loveland Productions, Inc. site in conjunction with the screening-level risk assessment completed in 2005. A SLERA is conducted as a tiered approach, in which the initial step assumes default exposure assumptions, and the second step refines the evaluation by using site-specific assumptions appropriate for the Loveland Productions, Inc. site. The results identified one analyte, Triallate, with a hazard rating above acceptable levels. However, the estimated risk for Triallate was based upon the maximum detected concentration observed at one location. Actual risks to ecological receptors would be considerably less, since the ecological receptor of concern, deer mice, is mobile and not expected to linger in any one location. Therefore, ecological risk is not expected to be significant.
Corrective Measures Study (CMS)
After the RFI is 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 for Loveland Productions, Inc. was completed in February 2008.
Throughout the cleanup process, the DEQ will keep the public informed through notices of public meetings and public comment periods in area newspapers.
FOR MORE INFORMATION
Ann M. Kron, Environmental Science Specialist
Montana Department of Environmental Quality
P.O. Box 200901
Helena, Montana 59620-0901
Hazardous Waste Currently Generated at the Site:
(Wastes currently generated are shipped off-site for treatment.)