Rhodia/Solvay’s Silver Bow

#MASKINGMORETHANCHEMISTRY

 

There is one thing that is certain with major chemical industrial polluters, they not only pollute the environment and despoil people’s lives when in business, but when their plants and associated waste dumps are left behind, the toxic legacy is left with the communities who continue to suffer the blight.

In the case of Albright and Wilson, their former sites have all gone the same way after having been mothballed- about as much use and relevance as the organisation “Scientists for EU” you might say  😆 😆 😆 😆  . Some of these were taken on by the French company Rhodia, (without much change) and subsequently Solvay. Whitehaven, Portishead and Avonmouth have all gone, but other sites used in the production of White phosphorus abroad give some interesting clues as to what such plants emitted, as well as more interestingly to me, what lies beneath rattlechain lagoon!

The disastrous Long Harbour venture where Albright and Wilson blighted that community with pollution killing thousands of fish has been documented HERE. Another lesser known P4 production site which Rhodia and then Solvay took on and acquired into decommissioning is located in the state of Montana. It is known as the Silver Bow complex. This was no Christmas present gift wrapped type of affair however.

This site occupying approximately 1.25 square miles was originally a French owned “Rhöne-Poulènc” company site, of which the chemicals division was spun off into “Rhodia” in 1997 , who of course would take over Albright and Wilson just a couple of years later, only to be swallowed up by Solvay in 2011.

According to a formal EPA document,

“The Facility was constructed in the early 1950s to produce elemental phosphorus. The
crude phosphorus stored in the clarifier was a by-product of elemental phosphorus
production. During the operating life of the Facility, much of the crude phosphorus by-product collected in the clarifier was further processed on-site to recover any remaining
elemental phosphorus. In 1997, processing was terminated at the Facility and the crude
phosphorus sludge remaining in the clarifier, and other locations around the Facility, could no longer be processed on-site.”

Another large document

TOXICOLOGICAL PROFILE FOR WHITE PHOSPHORUS

Prepared by: Sciences International, Inc. Under Subcontract to: Research Triangle Institute Under Contract No. 205-93-0606 Prepared for: U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES Public Health Service Agency for Toxic Substances and Disease Registry September 1997

gives some interesting perspective about WP production sites in the US at the close of the millennium.

“4.1 PRODUCTION

The domestic production capacity of elemental phosphorus in 1992 was 294,000 tons (SRI 1992). The demand for elemental phosphorus is expected to decrease (l-2%) during this decade (CMR 1991). The three companies that presently manufacture elemental phosphorus in the United States for sale or distribution are FMC Corp., Pocatello, Idaho; Monsanto Co., Soda Springs, Idaho; and Rhone-Poulenc Inc., Silver Bow, Montana (SRI 1995).”

The operation of this site appears to have been a major blot on the landscape, aren’t they all, with over a million pounds of P4 stated to be on site.

Even worse, a reported 4,035 pounds of this chemical were apparently being emitted to air from this plant, source  Toxics Release Inventory (TR193 1995).

Another EPA report dated 2003 concerning the FMC Pocatello plant mentions the Silver Bow site several times in looking at other White phosphorus producing sites and historic ponds contaminated with this chemical in relation to potential treatments.

epa542r03013

  • “(Rhodia, Silver Bow, Montana) indicated that the ponds are not under corrective action.” executive summary
  • The ponds used were unlined. page 15
  • The method of manufacture at this site was the electric arc method, and a useful summary of this site was presented in a table.

“Phossy water was disposed of in unlined ponds at this site. In addition, sludge was disposed of in a concrete clarifier. The clarifier is approximately 100 ft in diameter, and is an open-topped, in-ground unit that is constructed of reinforced concrete, and contains 400,000 – 500,000 gallons of sludge, with an estimated 20 to 40 percent WP.
The clarifier may have a bottom, but it is believed to have leaked, and the exact integrity of the clarifier is not known. Rhodia does not want to remove and treat the wastes from the clarifier because they believe it would be too risky for workers and too
expensive. Corrective action alternatives for the clarifier are being reviewed under a RCRA § 7003 order, and corrective action is expected to be conducted under the order.”

I have looked at this order further on in this post, but the volumes of p4 here once again show that this industry was inept at doing anything with the vast amount of toxic waste generated by this vile process.

The radioactive nuclides measured as a result of this process are noted. Several methods of remediation were being considered, but very little detail at that time.

What is apparent is that Rhodia were fined heavily for their poor handling of this plant as the article below from 2004 demonstrates. No wonder they did not want to move it.

Rhodia fined $18 million for polluting Montana | The Engineer The Engineer

“Rhodia had previously admitted that from January 1999 until August 2000, after the Silver Bow Plant was closed, it illegally stored elemental phosphorus sludge, a hazardous waste, at the site in a large concrete tank known as a 100-foot clarifier. Rhodia has also admitted that it illegally stored carbon brick and precipitator dust contaminated with elemental phosphorus waste, a hazardous waste. The carbon brick and precipitator dust had been discarded from a furnace at the site. The illegal activity was discovered in May 2000, when EPA and Montana Department of Environmental Quality (“DE”) executed a search warrant at the Silver Bow Plant.”

This sounds very much like the type of illegal activity that Albright and Wilson were carrying out at Portishead, and appears to be typical of the phosphorus industry at large. It is notable that these chemical companies attempt to hide their activities and liabilities from the regulators, who I would argue were poor at their jobs in failing to detect the issues for the many years of allowing the issue to build.

The article states that Rhodia were being made to remediate all of the hazardous waste including the clarifier waste on the site. “The criminal fine is the largest ever paid for criminal environmental violations in the District of Montana, and one of the largest ever paid for prosecution of hazardous waste crimes in the US.”

But just as Rhodia attempted to blame Albright and Wilson for their liabilities, it appears that they attempted to counter sue the previous owner, who had now become known as “Sanofi- Aventis”.

SANOFI-AVENTIS TO CONTEST RHODIA LAWSUITS IN US, BRAZIL (fdanews.com)

“Rhodia claims to have resolved a US$18mn US lawsuit, which obliged the company to carry out remedial work to contamination at the Silver Bow site. However, costs on the settlement appear to have risen to more than US$24mn, with no precise estimate of the expenses to be incurred on the clean up. Any legal action is thus likely to relate to whether previous agreements allow for further liabilities on sanofi-aventis’ part, while the extent of remedial work required at the Cubatao site remains unclear.”

The judgement is a long bore fest of a read, and a chemical industry squabble of which I do not intend to get into because they are all guilty of negligence as far as I am concerned with their activities, but there are some discernible pieces of information about the plant which are of note.

Rhodia

“Since acquiring the Silver Bow Site in 1998, Rhodia has incurred substantial costs related to its ongoing investigation and remediation of the Silver Bow Site. Compl. ¶¶ 27. In June 2000, the Environmental Protection Agency (“EPA”) issued an administrative order against Rhodia under Section 7003 of the Resource Conservation and Recovery Act (“RCRA”), requiring the stoppage of environmentally damaging elemental phosphorus leaks at the Silver Bow Site. Compl. ¶¶ 15-17. On December 22, 2003, the EPA issued a Corrective Action Order on Consent to Rhodia, requiring additional environmental clean-up at the Silver Bow Site. Compl. ¶¶ 18-20. On January 12, 2004, Rhodia agreed to a Montana Department of Environmental Quality demand to remove elemental phosphorus contamination at the Silver Bow Site. Compl. ¶¶ 21-22. In May 2004, the EPA issued another administrative order requiring the excavation and removal of sections of a wastewater discharge pipe and the remediation of identified soil pollution at the Silver Bow Site. Compl. ¶¶ 23-25. All of these actions are related to the release of waste when the Silver Bow Site was owned by RPI. Compl. ¶¶ 15-26.
Additionally, in 2004, Rhodia pled guilty to criminal charges and paid over $16 million in criminal fines related to environmental violations on the Silver Bow Site. Compl. ¶¶ 26.”

What is clear from this is that all Rhodia staff in principle positions around the world must have been aware of this matter, including the lying bastards at Oldbury who were spinning us yarns about dying birds at this site, and hiding the fact that it was their white phosphorus in the sediment that was causing it in this very year. Certainly Clamadieu and the other high up Monsieurs in this frog company were fully aware of this matter and of similar issues at other sites around the world that they had acquired through takeover.

When the same site staff at Rhodia had merely transferred from Albright and Wilson, it is no good trying to blame the previous entity for “negligence” when it was those same staff who were negligent to start with. A similar thing occurred with Solvay when they were finally fined for the issues with the uncontrolled release of phosphine gas, many years after the incident had happened when the case had finally come to court. 

Marianne Walsh of the US Army chemical Core of engineers independently reviewed potential treatment technologies for the FMC site in 2009, and mention of the Silverbow site is again noted.

“At the Rhodia Silver Bow Plant near Butte, Montana, at least some excavation of P4-
contaminated soils was conducted. The following quote is from USEPA Region 8 Docket
No. RCRA-08-2004-0003: “Elemental phosphorus and phosphoric acid (collectively
“Phosphorous Material”) observed during excavation, will be drummed at the excavated site, or Pipe with such phosphorus material (and other materials requiring cleaning) will be transferred to the Plant for cleaning, followed by drumming of the removed phosphorus material. Each drum containing elemental phosphorus will be sent offsite for incineration.” Remediation of P4 contaminated matrices at FMC Pocatello , Idaho January 2009. 

It is stated in this report that Rhodia proposed to cap the rest of the P4 contaminated areas; however, the state of Montana wanted the wastes removed.  😐  We certainly are well aware of the Rhodia cheapskate way.

The following document appears to be a community update PR type piece about this site, and other matters relating to the Montana superfund area. “Interim clean up activities have been conducted to address many of the most immediate potential environmental hazards. A facility-wide investigation is in progress to determine appropriate long term remedies. “

This would appear to cover the paper from Marianne Walsh.

SBCButte_16-2011WinterUpdates

A further document from the EPA shows the issued document concerning the clarifier waste and some observations are highlighted below.

Proposed Clarifier Remedy Decision Solvay USA Inc., Silver Bow Plant, Butte, Montana Pursuant to Administrative Order EPA ID No. MTD 057 558 546

1817945

  • “Solvay has proposed this remedy as part of its obligation to address certain wastes at the Facility identified in an administrative order issued by the EPA, pursuant to section 7003 of the Resource Conservation and Recovery Act (RCRA), 42 U.S.C. § 6973, as amended in December 2000 (7003 Order). The EPA is proposing this remedy after consultation with the Montana Department of Environmental Quality (DEQ).”
  • “The 7003 Order required Rhodia Inc., and subsequently its corporate successor Solvay, to evaluate alternatives for closure of an existing waste management unit known as the clarifier. The clarifier is a 100-foot diameter open-topped concrete tank-like structure that holds approximately 500,000 gallons of phosphorus-bearing sludge. According to available information, the clarifier primarily contains sludge generated during production of elemental phosphorus. The materials in the clarifier are referred to as “clarifier sludge.” “
  • “Solvay evaluated closure alternatives for permanent disposition of the clarifier sludge. The alternatives presented in the Supplemental Waste Plan dated October 2015 (Waste Plan) are:
    (1) Enhanced RCRA Cap;
    (2) On-site Phosphorus Recovery using the Mud Still Process; and
    (3) Off-site Incineration.
    Solvay has proposed on-site phosphorus recovery using the Mud Still Process as the
    preferred remedy for the clarifier sludge. The EPA concludes that this on-site phosphorus recovery (hereafter called the Clarifier Remedy) should be proposed. “
  • “The 7003 Order required installation of fencing and signs around the clarifier and other measures, including:
    • installing an automatic water system that ensures a layer of water covers the
    surface of the clarifier sludge within the clarifier at all times;
    eliminating wildlife contact with the clarifier sludge by placing
    approximately 80,000 Bird Balls™ on the water to camouflage its surface; and
    • installation of a continuous phosphine gas monitoring system around the
    clarifier.”

I think that these three orders are important when looking at the situation at Rattlechain lagoon, as of course the sludge was ignitable, was known to poison wildlife, particularly birds, and viable for giving off toxic phosphine gas. Perhaps Rhodia should have been compelled by The Environment Agency to install bird balls. 

  • “Solvay has submitted a Human Health Risk Assessment and an Ecological Risk
    Assessment currently under review by the EPA. Groundwater is currently being monitored site-wide for the presence of hazardous constituents, on a semi-annual basis.”

We have of course seen the same labelled crap at Rattlechain, which was nothing of the sort.

  • “The clarifier is a 100-foot diameter, open topped, in-ground tank-like structure with
    reinforced concrete walls. The clarifier is approximately 12-feet deep and contains
    approximately 500,000 gallons of clarifier sludge. The clarifier sludge consists of elemental phosphorus, water and solids, such as phosphate dust, coke dust, and silica dust. Several feet of water cover the surface of the clarifier sludge to prevent the elemental phosphorus from igniting when exposed to air.”

This sounds very much like the effluent plants at Albright and Wilson, and also the historic waste content at Rattlechain, which was merely watered down to transport it there.

  • The recovery of phosphorus using the mudstill process, which the EPA approved of should ring instant alarm bells given the fact that this method was used by Albright and Wilson in the Portishead decommissioning operation and resulted in the P4 being enriched and creating radioactive dangerous conditions for workers and the wider public. 
  • There is no mention of this possibility in this consultation, so let’s hope Solvay found a better method for p4 recovery than the failed and dangerous Albright and Wilson one!
  • “The Mud Still Process will also produce solid residues containing phosphate ore, coke, silica and other inert materials. After completion of each batch, the mud still residues will be removed from the skip and transferred to containers for storage. Due to potentially leachable metals, this residue may be considered hazardous, or qualify as a hazardous waste. As part of our decision, the EPA will require characterization of the mud still residue during full-scale operation of the mud still to evaluate the potential need for treatment of the residue prior to final disposal”  🙄 

I have to state, that I find this EPA agreed proposal both ludicrous and ill conceived. If the idea was to punish this polluter, then why were they allowed to profit from their criminality by recovering the wastes that they had left behind? Solvay get their “silver lining” by recovering more white phosphorus to just start this environmental nightmare away from this place and time, and create another waste mountain somewhere else that will also have to be dealt with for a future time.  It appears that the containers of waste left behind would also be just more hazardous waste, that would not be free of white phosphorus in any case, whatever they claim.

Unfortunately, it appears that the EPA, like the EA in Britain, can be hoodwinked by chemical industry bull shitters at Solvay and a PR spin piece like this does little to instil any confidence in their regulatory role.

Solvay’s solution appears tailored to their profit margins, with constraints used as excuses, but hey, just stick a silver bow on it and wrap it up.

I’d be very interested to know if mud stilling was ever considered at Rattlechain lagoon for p4 recovery, and if not, if this is the claimed best available technique ,why  it was not employed there by this same global company?  Was it because it was deemed to be too near to the residential dwellings on the former sewage works, and therefore a risk to these occupiers ,where the foolish planning inspector who gave the nod for that development was unable and unquestioning to ask if the development would limit the scope of future remediation site options? 

Further summary of the above material can be read on the EPA website below. I am not sure what actions have been taken at this site since 2017, as there is no further information I have been able to find as to the current status of this so called “clean up”.

Hazardous Waste Cleanup: Solvay Silver Bow Plant in Butte, Montana | Corrective Action Sites around the Nation | US EPA

 

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