Hargis + Associates Inc

CERCLA remedial and removal actions at historic waste disposal areas.

Apache Nitrogen Products, Inc. (ANP) has operated a nitrogen-based fertilizer and explosives manufacturing facility in rural Cochise County since 1921. Using a feedstock of anhydrous ammonia, current manufacturing processes produce nitric acid, solid and liquid ammonium nitrate, and various ammonium nitrate-based fertilizer products for regional mining and agricultural markets. Historically, ammonia, nitroglycerin and nitroglycerin-based explosives, detonating cord, safety fuse, sulfuric acid, carbon dioxide, and xanthate were also manufactured at the facility.

In 1990, the U.S. Environmental Protection Agency (EPA) designated the facility within the Apache Powder Superfund Site based on a Preliminary Investigation under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). In 1994, EPA issued a Record of Decision (ROD) and Unilateral Administrative Order (UAO) outlining remedial actions required for certain historic waste disposal areas at the site. ROD-designated “media components” included a waste storage and drum disposal area; dinitrotoluene (DNT) drum landfill; and various other DNT disposal areas across the site. In 1999, EPA issued a CERCLA Removal Action Memorandum (RAM) directing the removal of residuals from an improperly closed trinitrotoluene (TNT) recovery operation that pre-dated ANP’s operation.

Remedial implementation was performed from December 1999 through June 2000. The scope included on-site pre-treatment of potentially-explosive TNT wastes; removal of drummed and non-drummed liquids and debris; excavation of potentially-impacted soil; confirmatory sampling; waste profiling; and off-site disposal at approved hazardous and non-hazardous facilities. In total, these actions involved approximately 2,200 tons of waste materials, including approximately 1,200 tons of hazardous waste.

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