BCP Ingredients Inc. Facility in Verona, Missouri
On this page:
- Latest Actions
- Clean Air Act Oversight by EPA and Missouri Department of Natural Resources
- OSHA and Worker Safety
- EPA Actions to Address Ethylene Oxide
- EPA Clean Air Act Section 112(r) Risk Management Program Inspection
- Syntex Facility Superfund Site
- Additional Information Resources
- Related Documents
Latest Actions
EPA sent an Information Request letter to BCP Ingredients Inc. on March 27, 2023. An extension request was agreed upon. The schedule is provided in the following table. (See link to letter under Related Documents below.)
Request Number(s) | Date of Response |
---|---|
12, 13, 15, 16 (personal monitor and Drager data), 17, 18 and 19 | April 10, 2023 |
14 (stack test data) and 16 (ambient monitor data) | April 17, 2023 |
20 and 21 | April 21, 2023 |
1, 4, 5, 6, 7, 8, 9, 10 and 11 | April 26, 2023 |
2 and 3 | May 15, 2023 |
Clean Air Act Oversight by EPA and Missouri Department of Natural Resources
The responsibility for managing air quality in the U.S. is shared by EPA and state, local, and tribal air agencies. EPA has provided technical support to air agencies as part of this work. In Missouri, the state has primary responsibility for implementing the Clean Air Act (CAA). In Verona, this means that EPA is working with the Missouri Department of Natural Resources (MoDNR), the agency responsible for issuing CAA permits to BCP Ingredients Inc. and evaluating compliance with those permits.
While the state has primary responsibility for implementing the CAA, EPA has direct responsibility for some programs, including the Risk Management Program (RMP) Rule that implements Section 112(r) of the 1990 CAA amendments. This program requires facilities that use extremely hazardous substances to develop a Risk Management Plan and comply with the Chemical Accident Prevention Provisions at 40 Code of Federal Regulations (CFR) Part 68 (see RMP Rule website).
Information regarding the MoDNR Air Program is available on their website.
OSHA and Worker Safety
The Occupational Safety and Health Administration (OSHA) is the primary agency charged with ensuring worker safety at the BCP Ingredients Inc. facility. Additional OSHA information is available on their website.
Specific information related to OSHA inspections of the BCP facility is also available online: April 14-16, 2021 document and April 14, 2021 document.
EPA Actions to Address Ethylene Oxide
Ethylene oxide (EtO) is a flammable, colorless gas that is used to make a range of products, including antifreeze, textiles, plastics, detergents and adhesives. Ethylene oxide is also used to sterilize equipment and plastic devices that cannot be sterilized by steam, such as medical equipment. EPA is committed to reducing risks from ethylene oxide.
As EPA pursues its mission to protect human health and the environment, addressing ethylene oxide is a priority for the Agency. EPA is reviewing its current air regulations that limit the amount of EtO certain types of industries release into the outdoor air to determine whether legal standards for EtO emissions to the air should be further strengthened. There are ways industry can reduce emissions, and EPA is working with state, local, and tribal air agency partners and with companies to identify opportunities to reduce emissions faster than national regulations can achieve.
In 2016, EPA updated the risk values for ethylene oxide and, in 2018, released the updated National Air Toxics Assessment. After this, EPA Region 7 proactively engaged BCP Ingredients Inc. in Verona, Missouri, regarding ethylene oxide emissions at their facility. BCP Ingredients is a subsidiary company of Balchem Corporation. BCP manufactures and markets choline chloride, which requires ethylene oxide in its manufacturing process, and repackages ethylene oxide for other users.
EPA Region 7 worked with BCP Ingredients to review their operations, analyze their emissions, and conduct a specialized review of the air pollution controls at their facility. In 2019, EPA Region 7 also engaged with the Verona community to inform them of ethylene oxide risks and voluntary emission reduction measures to be taken. In October 2019, EPA presented information to the Verona City Council regarding ethylene oxide emission risks associated with the BCP Ingredients Inc. facility. In November 2019, EPA held an Open House at the Verona High School to provide the same information to the public at large. EPA followed up these meetings in December 2021 by providing an update to the Verona community.
BCP Ingredients has informed EPA that the company has begun evaluation of their air pollution control equipment and completed additional assessment of other sources of ethylene oxide emissions at the facility through implementation of a leak detection and repair program.
In 2020, EPA requested that BCP Ingredients conduct a retest of the facility’s primary air pollution control device (scrubber), and also requested information to substantiate earlier scrubber test results. This is known as a “stack test” and is an important tool used to determine a facility’s compliance with permitted emission limits or capture-and-control efficiencies established by the Clean Air Act. On Nov. 23, 2021, EPA held a meeting with BCP officials to discuss previous requests for information and emphasize the need for up-to-date, corroborating information related to the facility’s reported emissions. EPA reviewed BCP’s stack test plan in partnership with MoDNR.
BCP Ingredients performed a stack test on Feb. 13-17, 2023. Both EPA and MoDNR were on-site to observe the test. The data from this test must undergo standard quality control/quality assurance checks to be valid and reliable. However, preliminary observations from the February 2023 stack test raised questions about emissions related to the unloading and venting of railcars containing ethylene oxide. EPA and BCP discussed these questions and BCP took steps to change the work practice. The corrective actions that BCP will take to ensure a safe process are referenced in EPA’s letter dated March 8, 2023. (See link under Related Documents below.)
EPA Clean Air Act Section 112(r) Risk Management Program Inspection
In June 2022, EPA conducted an inspection to evaluate BCP’s compliance with the Clean Air Act Section 112(r) Risk Management Program requirements. EPA conducted this inspection as a result of the accidental release of ethylene oxide at the facility in April 2022. Risk Management Program and Chemical Accident Prevention Provisions are separate requirements in addition to air pollution control operating permits. The Post-Inspection Report is available below.
Syntex Facility Superfund Site
The BCP Ingredients Inc. facility sits on part of the approximately 180-acre Syntex Facility Superfund Site. BCP purchased the property and manufacturing facilities in May 2001. In the late 1960s to early 1970s, prior to BCP’s ownership, the facilities were used by multiple companies to produce an antibacterial agent and an herbicide. The herbicide was one component of the defoliant commonly referred to as Agent Orange. Dioxin was created as an unwanted by-product during production of both products. Chemical manufacturing waste residues were disposed of in several areas of the facility, contaminating the soil and groundwater with dioxin and other volatile organic compounds. Since 1980, federal and Potentially Responsible Party (PRP) actions have been taken to assess and address contamination at the Syntex Site.
EPA performs regular checkups of the site, called Five-Year Reviews, to ensure that past actions to address the contamination remain protective. In 2016, the PRP Syntex began performing additional investigations to resolve protectiveness questions that came up during one of EPA’s Five-Year Reviews. While the additional investigations have resolved the majority of the protectiveness concerns, the investigations led to the discovery of a plume of 1,4-dioxane-contaminated groundwater beneath the site. In 2019, EPA initiated a large-scale, domestic drinking water well sampling program to determine if 1,4-dioxane was present in their wells. To date, EPA has sampled over 90 wells in a 2-mile radius around the site. With the exception of two wells, 1,4-dioxane was not detected. In the two wells where 1,4-dioxane was found, it was at levels less that the relevant EPA health-based standards. EPA is currently negotiating with BCP and Syntex on an Order to conduct additional investigations to determine the source of the 1,4-dioxane and the extent of the 1,4-dioxane plume in the groundwater.
Additional information regarding the Syntex Facility Superfund Site is available on EPA's Site Profile Page.
Additional Information Resources
Additional health information is available online at the websites of the Missouri Department of Health and Senior Services (MDHSS) and federal Agency for Toxic Substances and Disease Registry (ATSDR).
Visit the MDHSS website. ATSDR’s ToxFAQs™ for ethylene oxide is available online.
Related Documents
- Voluntary Ethylene Oxide Scrubber Stack Test Report (pdf)
- Presentation at Verona Public Meeting/Availability Session (pdf)
- EPA Section 114 Information Request Letter to BCP Ingredients Inc. (pdf)
- EPA Letter to Stinson LLP, Representing BCP Ingredients Inc. (pdf)
- Presentation at Verona Public Meeting/Availability Session (pdf)
- Verona Air Monitoring Quality Assurance Project Plan (pdf)
- BCP Ingredients Order for Compliance (pdf)
- Presentation at Verona City Leaders Meeting (pdf)
- BCP Supplemental Response to EPA Section 114 Information Request, Received Aug. 19, 2022 (pdf)
- BCP Initial Response to EPA Section 114 Information Request, Received Aug. 19, 2022 (pdf)
- BCP Ingredients CAA Section 112(r) Post-Inspection Report, July 26, 2022 (pdf)