The Boeing Co. - Tract 1
EPA ID# MOD000818963
MoDNR Contact: Christine Kump-Mitchell, 314-416-2464 or 800-361-4827
Facility Contact: Mark Allen, 818-620-5986
Last Updated: Nov. 15, 2017
- Former Company Name: McDonnell Douglas Corp.
- Type of Facility: Permitted Hazardous Waste Storage - closed.
- Wastes Handled: Contaminated soil, corrosives, flammables, household hazardous waste, industrial wastewater, paint sludges, PCBs <50 ppm, petroleum-contaminated wastes, solvents, TCLP toxic metals and used oil.
- Location of hard copies of hazardous waste permit application, Part I Permit, modification requests, reports, etc. and supporting documents:
Final Permit Issued: On Nov. 15, 2017, the department approved the proposed final remedy for The Boeing Co. - Tract 1 facility and issued a final Missouri Hazardous Waste Management Facility Part I Permit, effective immediately. Boeing has been conducting corrective action investigations and remediation activities at the site under a department-issued Missouri Hazardous Waste Management Facility Part I Permit and U.S. Environmental Protection Agency (EPA)-issued Hazardous and Solid Waste Amendments Part II Permit. EPA decided not to issue a Part II Permit, since EPA has no site-specific conditions for the facility, beyond those contained in the Part I Permit, and Missouri is fully authorized for all permitting and corrective action activities at the facility. EPA intends to terminate the existing Part II Permit upon the issuance of the final Part I Permit.
On Feb. 28, 2007, Boeing submitted a permit application to the department and EPA to renew their existing hazardous waste permits. In July 2014, Boeing also submitted the final revision to a Corrective Measures Study Report, which identified and evaluated possible corrective measure alternatives for removal, control or treatment of the contamination that presented an unacceptable risk. After a thorough technical review of the permit application, Boeing’s preferred final remedy, other remedial alternatives and opportunity for public comment, the department approved the proposed final remedy and issued a final Part I Permit. The final permit requires Boeing to implement the approved final remedy for on-site soil and groundwater contamination and implement a facility-wide corrective action program, including the areas now owned by GKN Aerospace and St. Louis Lambert International Airport. The approved final remedy includes property activity and use limitations in the form of enforceable Environmental Covenants. The permit also requires corrective action in the event there is a newly identified release to the environment or if the contamination poses a threat due to further migration. The status of Boeing’s corrective action activities are described below.
The public can review and copy paper copies of the final Part I Permit, summary and response to comments received during the public comment period and supporting documents at the St. Louis County Library’s Prairie Commons Branch, 915 Utz Lane, Hazelwood, Mo. (during normal business hours) or agency locations above.
Any parties adversely affected or aggrieved by the department’s decision to issue the final Part I Permit, or specific conditions of the final Part I Permit, may be entitled to pursue an appeal before the Administrative Hearing Commission by filing a written petition by Dec. 15, 2017, as more fully described on page 7 of the final Part I Permit.
The Boeing Co. – Tract 1 site is located on about 210 acres at James S. McDonnell Blvd. and N. Lindbergh Blvd., next to St. Louis Lambert International Airport, in Hazelwood. In 1941, the McDonnell Douglas Corp. began operating an aerospace manufacturing facility at the site, known as Tract 1, which is divided into two sections. Tract 1 North is north of Banshee Road and Tract I South is south of Banshee Road.
McDonnell Douglas Corp. manufactured transport aircraft, aircraft components, space systems/missiles and combat aircraft, such as the F-15 Eagle, F/A-18 Hornet and the AV-8B Harrier. Other components were produced for the T45TS trainer, missile systems and C-17 transport plane. Aircraft manufacturing operations included fabricating aluminum, titanium, composite structures and other airframe material; chemical processing; metal cutting, forming and grinding; degreasing; painting and aircraft assembly, fueling and flight-testing.
Approximately 48 different hazardous waste streams were produced as part of the facility operations, including emulsified cutting oils, waste jet fuels, paint solids, solvents and paint wastes, wastewater treatment sludges and acidic and caustic wastes. McDonnell Douglas recovered spent methyl ethyl ketone, methyl isobutyl ketone and perchloroethylene through two distillation units located in building 48. These solvents were used to clean spray paint guns, lines and equipment. Waste still bottoms were collected in drums and transported to a permitted hazardous waste disposal facility.
McDonnell Douglas stored the other hazardous waste in several accumulation areas located on the facility property and in three hazardous waste container storage areas. Area 1, the scrap dock shelter, was divided into two sections by a 6-inch high curb. A maximum of 168 55-gallon drums of acids, alkalis and unwashed empty drums previously used for hazardous waste storage were stored in one section. The other section was used to store a maximum of 280 55-gallon drums of paint sludges, oils, solvents and unwashed empty drums that previously held oils or solvents. Area 2, the reactive cyanide and sulfide-bearing waste storage area, was a 22 ft. by 10 ft. building. First used in 1977, Area 2 was used to store a maximum of 31 55-gallon drums containing cyanide and sulfide-bearing waste. Waste storage in this area ended in 1989, due to water seepage into the shelter after heavy rains or snowmelt. In order to eliminate the potential hazard of water combining with reactive cyanide waste, McDonnell Douglas replaced the building with a fully enclosed, prefabricated storage building, with a maximum capacity of 28 55-gallon drums.In 1970, McDonnell Douglas began operating an industrial wastewater treatment plant, which consists of several in-ground, open-top sludge settling and equalization tanks. Rinse water from chemical process operations was pumped to the sludge settling tanks. Sludge from the settling tanks was pumped to an in-ground 120,000-gallon sludge-holding tank and then into to a filter press for dewatering. The filter cake produced from this process, which is a listed hazardous waste, was collected (for less than 90 days) in an open top roll-off container and transported to a permitted hazardous waste disposal facility.
In August 1997, McDonnell Douglas merged with Boeing, who has since stopped operating as a hazardous waste storage facility. All the hazardous waste storage units were either closed or referred to corrective action. In 2001, Boeing sold 87.88 acres of Tract 1 North to GKN Aerospace, who uses the site for developing and manufacturing aircraft structures, components and assemblies. In 2005, Boeing sold most of Tract 1 South, 75.99 acres, to St. Louis Lambert International Airport. Buildings and structures on a large part of that property were demolished to use the land as part of the runway protection zone. The airport leases the remaining buildings and property to tenants for commercial and light industrial use. Boeing retained ownership of 40.43 acres in Tract 1 North and 5.11 acres in Tract 1 South. This property includes a power plant and the industrial wastewater treatment plant, as well as office and warehouse facilities. The industrial wastewater treatment plant currently receives rinse water from chemical process operations in Tract 1 and GKN Aerospace.
McDonnell Douglas closed the original reactive cyanide and sulfide-bearing waste storage area in 1989. The department accepted the clean closure certification for this unit in November 1993.
According to applicable state and federal hazardous waste laws and regulations, all hazardous waste treatment, storage and disposal facilities are also 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. In 1994, Science Applications International Corp., on behalf of EPA, performed a Resource Conservation and Recovery Act (RCRA) Facility Assessment for the site. The assessment was conducted to identify and gather information on actual and potential releases of hazardous waste and hazardous constituents to the environment. The 1995 RCRA Facility Assessment Report identified 32 solid waste management units that were recommended for additional investigation.
Four of the solid waste management units identified in the assessment required stabilizing interim measures. 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 interim measures, Boeing, formerly McDonnell Douglas performed the following interim measures, which were completed in October and November 1997:
- Cleaned and removed the waste oil tank in Building 5.
- Cleaned the sumps and placed an asphalt lift over the paint booth satellite accumulation drum areas located outside the northwest side of Building 2.
- Cleaned and sealed cracks in the concrete floor of the “less-than-90-day” storage area in Building 40.
- Removed the leaking power transformer and impacted gravel and soil outside the northeast corner of Building 6.
In response to the RCRA Facility Assessment, Boeing performed a RCRA Facility Investigation to define the horizontal and vertical extent of any contamination. The investigation was conducted in a phased approach, dividing the site into nine areas based on the results of the previous assessments, investigations, location of solid waste management units and interim measures. Areas 1-5 and 9 are located in Tract 1 South and areas 6-8 are located in Tract 1 North. On behalf of Boeing, MACTEC Engineering and Consulting Inc. submitted a RCRA Facility Investigation Report to the department and EPA in June 1998, with revisions in December 2004. The sample results showed soil and groundwater in Tract 1 contaminated with volatile organic compounds, polynuclear aromatic hydrocarbons, polychlorinated byphenols (PCBs), metals and total petroleum hydrocarbons. The contamination is limited to the permitted facility and the contamination in Tract 1 North does not cross to Tract 1 South or vice versa.
The RCRA Facility Assessment, RCRA Facility Investigation and later investigations identified the following potential sources of contaminant release: 68 underground storage tanks, 3 fuel distillation sites, a power plant, the industrial wastewater treatment plant, 32 solid waste management units and multiple drum storage areas. Currently 44 groundwater monitoring wells are sampled twice a year. The groundwater monitoring results will be used to develop a long-term groundwater monitoring plan, which will become part of the corrective measures.
While conducting the facility assessment and investigation, McDonnell Douglas, and later Boeing, closed the remaining hazardous waste storage units at the facility. Boeing closed both the scrap dock shelter and new reactive cyanide and sulfide-bearing waste storage area in 2001. The new reactive cyanide and sulfide-bearing waste storage area was “clean closed.” Groundwater samples collected during the closure of the scrap dock shelter showed contamination above screening levels; however, it was determined the contaminated groundwater was from a nearby area of concern. The department accepted closure certifications for both units in November 2001, with the provision that institutional controls prohibiting groundwater use be put into place for the scrap dock shelter, as part of the final remedy. The department accepted closure certifications for most of the other units in 1993, 1995, 2001 and 2003. The remaining units are being addressed under corrective action.
At the department’s request, Boeing performed a risk assessment of the contaminated areas to determine if they exceeded risk levels and to address remaining elements necessary to adequately characterize the site. The risk assessment subdivided the nine areas of the site into 23 subareas, each characterized by similarities in factors that affect human health under current and reasonable future land use conditions. The risk assessment generally followed the Missouri Risk-Based Corrective Action (MRBCA) process. On behalf of Boeing, RAM Group submitted a Risk Assessment Report to the department and EPA in September 2004, with revisions in 2009. The report concluded the cumulative risks were below the department and EPA target risk levels for all scenarios except non-residential workers and construction workers. The report identified nine subareas that exceeded risk levels and required interim measures. As an interim measure, contaminated soil was removed from five subareas in May and June 2006:, which included the perchloroethylene (PCE) transfer area outside Building 51, former jet fuel underground storage tank farm immediately west of Building 41, 1000-gallon diesel underground storage tank next to Building 2, trash compactor located at the northwest corner of Building 220 and scrap metal recycling dock. Interim measures included removing the impacted soil and transporting it to a permitted hazardous waste disposal facility. The excavated areas were then backfilled with gravel.
As part of EPA’s independent review of the Risk Assessment Report, EPA asked Tetra Tech to perform a risk assessment of selected areas using the EPA Risk Assessment Guidance for Superfund (RAGS) process. The intent was to compare the results obtained from the MRBCA and RAGS risk assessment approaches. Tetra Tech submitted a Risk Assessment Report to the department and EPA in March 2008. The report concluded that generally the two risk assessment approaches resulted in similar risk management decisions. The report also identified two additional subareas that exceeded risk levels and required interim measures.At the department’s request, Boeing performed a Corrective Measures Study to identify and evaluate possible remedial alternatives for the remaining soil and groundwater contamination. On behalf of Boeing, RAM Group submitted the final Corrective Measures Study Report to the department and EPA in February 2012, with revisions in November 2012, July 2013 and July 2014. The report included Boeing’s preferred final remedy along with other remedial alternatives. The department selected the best remedy from the Corrective Measures Study Report, given site-specific considerations for each solid waste management unit and area of concern. The department prepared a Statement of Basis that summarizes the remedial alternatives and the department’s basis of support for the proposed final remedy. The department incorporated the proposed final remedy into Boeing’s draft hazardous waste permit during the permit renewal. The public was invited to review and comment on the proposed remedy and draft permit during a 45-day public comment period. On Nov. 15, 2017, the department, in coordination with EPA, approved the proposed final remedy and issued the final permit. The approved final remedy includes property activity and use limitations, which will be in the form of enforceable Environmental Covenants. The covenants are clauses listed in the chain-of-title for the affected properties, which will notify in perpetuity, any potential purchaser of the environmental conditions of the properties. The Environmental Covenants will be executed by the department and each property owner and filed with the St. Louis County Recorder of Deeds.
McDonnell Douglas Corp., and later Boeing, operated under a department-issued Missouri Hazardous Waste Management Facility Part I Permit and EPA-issued Hazardous and Solid Waste Amendments Part II Permit, originally issued in 1984 and renewed in 1997. Boeing is currently conducting corrective action activities under the same department-issued Missouri Hazardous Waste Management Facility Part I Permit it operated under, which was renewed Nov. 15, 2017. EPA decided not to renew the Part II Permit, since EPA had no site-specific conditions for the facility, beyond those contained in the renewed Part I Permit, and Missouri is fully authorized for all permitting and corrective action activities at the facility. The Part I Permit requires Boeing to implement the approved final remedy for on-site soil and groundwater contamination and implement a facility-wide corrective action program, including the areas now owned by GKN Aerospace and St. Louis Lambert International Airport. The permit also requires corrective action in the event there is a newly identified release to the environment or if the contamination poses a threat due to further migration.