Beazer East Inc.
EPA ID# MOD007146517
- Former Company Name: Koppers Co. Inc., National Lumber and Creosote Co.
- Type of Facility: Former Permitted Hazardous Waste Storage – closed.
- Wastes Handled: Creosote and bottom sediment sludges from the treatment of wastewater processes that use creosote and pentachlorophenol.
- Treatment and Disposal Methods: None.
- Location of hard copies of hazardous waste permit application, Part I and Part II Permits, modification requests, reports, etc. and supporting documents:
Beazer East Inc. is implementing the final remedy for on- and off-site soil and groundwater contamination and performing long-term monitoring and maintenance of a closed hazardous waste container storage area under two hazardous waste permits. The status of Beazer’s post-closure and corrective action activities is described below. The public can review and copy paper copies of all permits, reports and supporting documents at the agency locations above.
The Beazer East Inc. site is located in the Blue Valley Industrial Corridor at 6740 Stadium Drive in Kansas City, Missouri, about 0.25 miles east of the Blue River. In the early 1920s, the National Lumber and Creosote Co. began operating a wood treating facility at the site, which originally covered about 36 acres. National Lumber used mainly creosote as a wood preservative to pressure treat railroad ties, posts and telephone poles.
The Koppers Co. Inc. purchased the facility in 1937 and continued similar wood treating operations. In addition to creosote, Koppers reportedly used pentachlorophenol in the late 1950s and early 1960s as a wood preservative. Sometime before 1980, Koppers built a hazardous waste container storage area to temporarily store 55-gallon drums of creosote and the bottom sediment sludges from the treatment of wastewater processes that use creosote and pentachlorophenol, which are both listed hazardous wastes. The container storage area was a 15 foot by 40 foot concrete pad built of wire mesh reinforced concrete that sloped towards two concrete walls on the north and south sides. The containers were stored until they could be shipped to an off-site disposal facility.
Koppers stopped operating at the facility in late 1987/early 1988 and partially demolished the plant operations. Beazer Materials and Services Inc., who changed their name to Beazer East Inc. in April 1990, purchased the facility in late 1988. From 1990 to 1992, Beazer continued dismantling all on-site structures and closed the container storage area. The facility property is now largely covered with gravel and native vegetation and is inactive except for on-going post-closure and corrective action activities.
Beazer submitted a closure plan for the hazardous waste container storage area to the department in August 1988. After several revisions, the department approved Beazer’s closure plan in August 1992. Closure of the hazardous waste container storage area occurred in December 1992 and included removing the concrete pad and walls and some soil beneath the pad. Thorough soil removal was prevented due to wet conditions. The department agreed to allow Beazer to close the area as a land disposal unit. Approximately 75 tons of clay was spread over the area as a cap. The department accepted Beazer’s closure report and certification for the container storage area in July 1995; however, because hazardous waste remained in place after closure, the area is also required to go through a period of post-closure care. As part of the post-closure care, Beazer is required to inspect and maintain the cap and sample the groundwater and surface water until the groundwater protection standards have been met for three consecutive years.
According to applicable state and federal hazardous waste laws and regulations, all hazardous waste treatment, storage and disposal facilities are required to investigate and clean up releases of hazardous waste and hazardous constituents to the environment at their facility resulting from present and past hazardous waste handling practices. The U.S. Environmental Protection Agency, or EPA, performed a Resource Conservation and Recovery Act, or RCRA, Facility Assessment for the site. The assessment was conducted to identify and gather information about potential or actual releases of hazardous waste to the environment. The 1991 RCRA Facility Assessment Report identified five solid waste management units and five areas of concern that required more investigation.
In response to the assessment, Beazer conducted a RCRA Facility Investigation to define the horizontal and vertical extent of any contamination at the closed hazardous waste container storage area, solid waste management units and areas of concern. Beazer submitted a RCRA Facility Investigation Report to the department and EPA in January 1999, with revisions submitted in June 2000. The sample results showed soil, sediment, surface water and groundwater in several areas of the facility contaminated with semi-volatile organic compounds, specifically polynuclear aromatic hydrocarbons, related to past wood treating operations. The report also identified two additional solid waste management units next to the facility. Based on these results, the investigation concluded that several of the solid waste management units and areas of concern required additional investigation and corrective action, or cleanup.
Beazer performed a Risk Assessment of the contaminated areas to determine if they exceeded risk levels. Areas that exceeded risk levels required additional investigation and interim measures to reduce or prevent unacceptable risks to human health and the environment. An interim measure is an action taken to temporarily control the contamination source or the path the contamination could take from the source to humans, animals or the environment, such as air, soil, water and food. As an interim measure, Beazer has recovered free product from the groundwater since 1996. Beazer also removed contaminated soil and sediment and rebuilt impacted surface water drainage ditches. Contaminated soil was also removed from several areas and consolidated. In 2000, Beazer coordinated with the City of Kansas City and the U.S. Army Corps of Engineers to reuse roughly 100,000 cubic yards of “clean” excavated soil from the Blue River Rechannelization Project. The “clean” soil was used to stabilize surface soil, address surface water drainage problems and cap contaminated soil, minimizing the potential for direct contact with residually contaminated soil.
At the department's request, Beazer performed a Corrective Measures Study to identify and evaluate possible remedial alternatives for the on- and off-site soil and groundwater contamination. Beazer submitted a Corrective Measures Study Report to the department and EPA in August 2001. The report included Beazer’s preferred final remedy along with other remedial alternatives. The department, in coordination with EPA, selected the best remedy given site-specific considerations for each solid waste management unit and area of concern. The department prepared a Statement of Basis that summarized the remedial alternatives and the department’s basis of support for the proposed final remedy. The department and EPA also incorporate the proposed final remedy into Beazer’s hazardous waste permits through draft permit modifications. The public was invited to review and comment on the proposed final remedy and draft permit modifications during a 45-day public comment period. On Sept. 25, 2005, the department, in coordination with EPA, approved the proposed final remedy and issued the final permit modifications. The approved final remedy included continued monitoring and maintenance of the closed hazardous waste container storage area, recovery well system, groundwater and surface water monitoring and institutional controls, such as a Deed Restriction or Environmental Covenant, to lessen future exposure to contaminants. As part of the permit modifications, the department and EPA also removed areas of the property that did not require corrective action from regulation under the permit. This was done in order to help speed up property redevelopment. The permitted site area was reduced to approximately eight acres.
Beazer submitted a Corrective Measures Implementation Work Plan in February 2006. This work plan provided detailed plans for implementing the approved final remedy. The department approved the plan in March 2006. Since that time, Beazer has installed and is operating the approved final remedy. Beazer currently samples the groundwater once a year as part of their monitoring program. The groundwater monitoring program is used to define the extent, rate of migration and magnitude of groundwater contamination at the site, in addition to determining the effectiveness of the approved final remedy. Currently the polynuclear aromatic hydrocarbons do not appear to be migrating from their source areas. When dense non-aqueous phase liquids are present in the groundwater, it is separated from the water and temporarily stored on site until shipped off-site for recycling. Dense non-aqueous phase liquids are recovered approximately twice a month.
Koppers operated the hazardous waste container storage area under the interim status portions of the of the federal hazardous waste laws, 40 CFR Part 265 and 10 CSR 25-7.265. When Congress passed the federal hazardous waste laws, all facilities treating, storing or disposing of hazardous waste in a manner that would necessitate obtaining a hazardous waste permit were required to notify EPA and apply to get such a permit, unless the facility chose to close those operations. Because of the large number of existing facilities, Congress set up requirements which allowed these facilities to operate temporarily under “interim status” until they received their permit. Koppers decided not to continue the hazardous waste permitting process and to close the unit. Beazer (formerly Koppers) is subject to the permitting requirements of the Missouri Hazardous Waste Management Law and federal Hazardous and Solid Waste Amendments for post-closure care because hazardous waste remained in place after closure. Beazer is also subject to corrective action because they completed closure after the effective date of the federal Hazardous and Solid Waste Amendments.
Beazer East Inc. is conducting post-closure and corrective action activities under two hazardous waste permits, one issued by the department and one issued by EPA. The permits were first issued in 1997. The department reissued the Missouri Hazardous Waste Management Facility Part I Permit, effective Sept. 30, 2011. EPA reissued the Hazardous and Solid Waste Amendments Part II Permit, effective Nov. 2, 2011. These permits require Beazer to continue to perform long-term monitoring and maintenance of the closed hazardous waste container storage area and corrective action for identified solid waste management units and areas of concern. These permits also require corrective action in the event there is a newly identified release of hazardous waste or hazardous constituents to the environment.