This is the story about how any citizen can facilitate scientific understanding and documentation of environmental issues in a local watershed.
The Reichhold Chemicals Site
Reichhold Chemicals Inc. owns a 170-acre site located on the Black Warrior River in Holt, Alabama. Between 1950 and 1987, Reichhold manufactured industrial resins, organic chemicals, and chemical coatings at this location. A 40-acre operations area with production and related buildings lies along the south bank of the river, while a 130-acre area neighbors the productions area just to the south, uphill in hilly terrain.
During the 1980's, reporting by Reichhold and regulatory actions by ADEM "established that a multiple-celled landfill with three associated lagoons was used for onsite disposal of wastes". According to the most recent report by ADEM dated 9/23/2011, "no structures remain in the landfill area."
Many longtime Friends of Hurricane Creek expressed concerns about the confluence where the creek meets the Black Warrior River. I've heard stories of purple goo oozing up from the dirt and pools of lavender liquid with dead fish floating in the Warrior. So, earlier this year, a few of us began investigating the history of Reichhold Chemicals plant which once operated at the mouth of the creek. What we found was rather disconcerting.
Effects on Hurricane Creek
In March and April of 2011 in response to a Congressional request, ADEM inspected the Reichhold site to determine its potential to qualify as a Superfund, or CERCLA, site. There are 24 delineated wetland pathways along the surface-water pathway, totaling 12.5 miles of wetland frontage. One of these wetland areas is Hurricane Creek which lies to the east, and is specifically referenced at several points in ADEM's most recent report (see Section 4.2).
In February 2011, as a follow-up to the 2012 inspections, ADEM personnel performed a focused sampling event of surface water at the site. The samples were analyzed for volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), and dissolved metals.
Three water samples were collected- one from outfall zone 6, one from outfall zone 7, and one from the confluence of the Hurricane Creek and the river. Outfalls 6 and 7 drain into Hurricane Creek at short overland distances, 1,300 and 1,500 feet, respectively. In a sense, all three samples concerned the creek. Run-off from outfall 7 enters the creek at a southeastern portion of the site.
The water sample results reflect the presence of Chemicals of Concern (COC) at levels which range from mere presence, in which case they show up under Method Detection Limit (MDL), or significant presence to cause known harm, in which case they show up under Maximum Contaminant Level (MCL).
According to this report, Hurricane Creek is the most sensitive resource (i.e. "wetland") likely to be impacted by the surface-water pathway along Reichhold. Unfortunately, the end result for the stream's integrity remains unclear: "A release of hazardous materials from the Site the Surface Water Pathway (SWP) is suspected but not confirmed."
Michael Cruise's Site Inspection
The history of this industrial site is not a pleasant one for our creek. Surface soil tests in 1988 indicated elevated levels of chromium, lead, nickel, manganese, phenol, and pentachlorophenol. On April 5, 2010, Michael Cruise visited the site pursuant to the Congressional inquiry and discovered a number of issues of concern which FOHC cannot easily address due to lack of access to the Reichhold-bordered portion of the creek.
Among these concerns:
Due to the steep banks of Hurricane Creek, Michael was unable to check the creek banks for leachate (though they did return later for the soil samples with the help of Tuscaloosa EMA). He told his assistant that they would need canoes to reach this area and properly check Hurricane Creek before they could determine any contamination. We are grateful to him for his thorough reporting and observation.
The Deep Disposal Well
Records of an experimental deep disposal well drilled to dispose of toxic waste effluents from the Reichhold plant left no indication as to who was currently responsible for maintaining the 8,000 ft. wells. After asking hither and thither, no one seemed to know anything about the existence of these wells- except the all-knowing archivists at the GSA, who passed a Bulletin published in 1973 my way. To help me in my queries with scientists and specialists, I put together a report including all the available data on the Reichhold deep disposal well (see document below).
After speaking to the Oil and Gas Board of the GSA, I learned that the Reichhold deep disposal well had been filled with cement and closed. This still didn't answer any questions about how much waste had been poured into it, and whether this waste was a potential contaminant of our aquifer or the Warrior River. Oil and Gas suggested I speak to ADEM about this matter.
Working with ADEM to Learn More
If you've never spoken to officials at ADEM, I suggest you reserve an afternoon for making phone calls to various persons because, more than likely, you will be passed around like a hot potato. After speaking to at least five different persons, I finally got in touch with Michael Cruise, who handles CERCLA and, coincidentally, Reichhold.
When I first explained the deep disposal well and inquired about its precise location, Michael lost his cool- "I'm sorry, you cannot call here and tell me something like that without documentation, ma'am! I have walked that site so many times and I HAVE NEVER HEARD OF A deep disposal well at that location!"
Fortunately, I was able to quickly email the report above to him. Even after reading a few paragraphs and citations, he remained incredulous. He asked for all my contacts at the GSA, which I happily provided. He was clearly, understandably disconcerted.
Honestly, I think Michael got upset because he had no record and no knowledge of this well. He compared me to "people calling him excited about people in gas masks from the EPA sneaking through their basement at night". Rather than get upset, I laughed and reminded him that my call was a friendly one and I hoped he could help us get to the bottom of these mysterious wells.
The Good News
Several days later, Michael called me with good news. Ultimately, the news he provided was good enough to frame.
Holding a large paper file from a file cabinet, Michael reported that the Reichhold deep disposal well/s had never been used because surface retention ponds were deemed "less expensive" by Reichhold Industries. An unfortunate private-public partnership in which taxpayer dollars were used to fund something that was then quickly discarded? Or a blessing in disguise given the proximity of several fracking wells during the same time period? I do think there is still a mystery here, though I leave it for others to sort.
As the primary environmental scientist working on the Reichhold site, Michael is probably the closest thing to an Alabama expert on this matter as possible. No one knows more about the soils, chemicals, and wastes left by Reichhold. That's why it seemed important that he know about this disposal well. As he pointed out, "That's what I get paid for."
The Future of Reichhold Along Hurricane Creek
Michael recently reported to the EPA that the Reichhold site is not a Superfund, or CERCLA, site. You can read his thorough and very detailed 400-plus page Remedial Site Assessment Report online right here.
When I asked about land use restrictions given the past history of contamination, Michael told me that Reichhold is "not looking to sell that property". Thus Reichhold Chemical Industries remains responsible for this site. ADEM often has to use lawyers to get the rights to visit some of these industrial sites.
You can access Michael's other reports on Reichhold Chemicals at the Efile page on the ADEM website. Check the "Land" box and include E-file permit number ALD004002838. There should be more Reichhold than you can imagine for the picking.
Hopefully, the information about the disposal wells will be included in the Reichhold documents soon since a half-told story does not meet the demands of the scientific process.
To learn more about the fascinating and rather convoluted history of the Reichhold plant, consider the following articles:
"Pilgrimage" by Nancy Callahan