Air and Waste Management Bureau
FACILITY FACT SHEET
Transbas,
Incorporated
Billings, Montana
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Location Map
TRANSBAS INCORPORATED
Front view of the Transbas Facility and
The closed surface impoundments at Transbas,
covered by an asphalt cap
Click on Photo to Enlarge
SITE LOCATION AND HISTORY OF CONTAMINATION
The Transbas 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. Transbas 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.
Transbas 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 of 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. The contribution of contamination from the closed impoundments has been determined to be minimal
Hazardous Waste Operating Permit Background
Under RCRA and Montana Hazardous Waste Act (MHWA) regulations, Transbas 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 Transbas facility. Because of the presence of hazardous waste left in the surface impoundment, Transbas 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 is planning on updating and reissuing the post-closure permit for the Transbas Site in 2003.
Corrective Action Permit Background
Through the Hazardous and Solid Waste Amendments of 1984 (HSWA), the Environmental Protection Agency (EPA) issued a HSWA Permit for the Transbas site in 1993. The HSWA permit required Transbas to investigate site-wide contamination, as opposed to the surface impoundments regulated under the States’ permit. Transbas 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. The HSWA permit will be updated and incorporated into the State’s reissuance of the post-closure permit.
TopCHARACTERIZING 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 Transbas 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 Assessment (in progress)
- Ecological Risk Assessment (in progress)
Facility-Wide Cleanup Plan
The US EPA conducted a Visual Site Inspection and RCRA Facility Assessment in 1990 as part of the Transbas RCRA permit process. Sixteen Solid Waste Management Units (SWMUs) and fourteen Areas of Concern (AOCs) were identified as part of these inspections.
A Phase I RFI Work Plan was prepared in April 1994 to perform the investigations necessary to characterize the environmental setting at the Transbas facility. The Work Plan was intended to provide the basis for decision-making by the MDEQ and U.S. EPA relative to the need for additional activities at each of the investigation areas.
The Phase I RFI Report identified releases of chemicals to the soil and groundwater at several SWMUs and AOCs which required further investigation. The primary chemicals detected in soil and groundwater in the Phase I investigation were herbicides and phenols. The groundwater plume does not extend beyond the site boundary.
Data collected during the Phase I RFI were used to conduct a human health screening (HHS) evaluation. The objective of the HHS was to identify chemicals of potential concern. Chemicals of potential concern were defined as those constituents present at the site that would be carried through the human health risk assessment process and for which carcinogenic risks and noncarcinogenic hazards would be estimated. Human health and ecological risk was not estimated from the Phase I RFI data.
A Phase II RFI Work Plan was prepared and Phase II field investigation began in June 2000. The objectives of the Phase II RFI were: (1) to evaluate the magnitude, vertical, and horizontal extent of the impacts identified in the Phase I RFI, (2) to collect data for human health and ecological risk assessments, and (3) to support corrective actions at the Transbas facility. The Phase II RFI Work Plan consolidated the SWMUs and AOCs requiring further investigation into five Study Areas and presented a framework for addressing each of the study areas at the Transbas facility.
Phase II of the RFI addressed all SWMUs and AOCs listed as requiring further action. The Agencies agreed that SWMUs and AOCs designated as "No Further Action" had been adequately addressed in Phase I and need not be investigated further at that time. Those units and areas under Administrative controls were located in active operational areas and could not practicably be accessed for investigation during Phase II.
Currently, a human health risk assessment and ecological risk assessment are being conducted by Transbas.
PUBLIC INVOLVEMENT
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
DEQ Contact: 
Ann M. Kron, Hazardous Waste Specialist
Montana Department of Environmental Quality
P.O. Box 200901
Helena, Montana 59620-0901
406-444-5824
e-mail: akron@mt.gov
Hazardous Waste Currently Generated at the Site:
(Wastes currently generated are shipped off-site for treatment.)
