Region 3 GPRA Baseline RCRA Corrective Action Facility

Koppers Industries,  Inc.
4020 Koppers Road
Salem, Virginia 24153
Congressional District 9
EPA ID #: VAD003125770
Last Updated 12-30-05
Current RCRA CA Activities
In September 1996, the Virginia Department of Environmental Quality (DEQ) issued a Permit
pursuant to the Resource Conservation and Recovery Act (RCRA) to administer hazardous waste
activities at the facility.  In September 1998, EPA issued a Permit for Corrective Action and
Waste Minimization, which identified solid waste management units (SWMUs) and areas of
concern (AOC) at the facility. The Corrective Action Permit requires investigation of releases
from the SWMUs and AOC, and corrective action, if necessary. In 2000, DEQ was granted
authorization to administer the HSWA Corrective Action program.  As of October 2000, DEQ is
the lead agency for Corrective Action at the facility, with EPA providing technical support.

The DEQ issued a permit modification September 2002 requiring the installation of three
sentinel wells replacing three off-site wells (M-28, M-29A, and M-29C) inadvertently destroyed
and subsequently abandoned. A revised RCRA Facility Investigation (RFI) Work Plan was
submitted by Beazer East, Inc. to EPA and VDEQ and was approved by the Department on July
31, 2002. Field work associated with Phase I of the RFI Work Plan was conducted in  September-
October 2002. The draft RCRA Facility Investigation Report (RFI Report) was submitted on
September 24, 2003.

The facility completed a dye trace study using multiple non-toxic dyes  and submitted the results
to the DEQ, which were inconclusive. The facility requested and the DEQ approved to obtain
additional information concerning the hydrogeologic relationship between the site aquifer,
springs, seeps, creeks and the Roanoke River by performing an additional dye trace study using
larger quantities of the non-toxic dyes. The additional field work is contingent upon water levels
in the Roanoke River and is tentatively scheduled for January 2006.

By letter dated September 19, 2005, DEQ requested that Koppers/Beazer submit Part A and Part
B Application to renew its Post-closure Permit by March 29, 2006.  Subsequent communication
with the facility confirmed that the application and fee will be submitted as requested and
conform to the schedule.  The facility requested that the DEQ use its full time allotment in
reviewing the application to enable the addition of a corrective measures plan in the reissued
permit.

By letter dated September 30, 2005, DEQ provided comments on the groundwater aspects of the

-------
Koppers Industries- VAD003125770
December 31, 2005 RCRA CA Fact sheet

RFI Report and site characterization. By letter dated October 21, 2005, Koppers submitted
responses to DEQ's comments on the RFI Report wherein they proposed the additional dye-trace
work discussed above. Additionally, the facility proposed to discuss the remainder of the
comments subsequent to the results of the second dye-trace test, which the DEQ agreed with.
The Koppers Industries, Inc. (KII) facility is located 2.0 miles west of the City of Salem in
Roanoke County. It was operated by Koppers Company, Inc. from 1955 to 1988. In 1988 KII
purchased the facility from Koppers Company, Inc., which is now known as Beazer East, Inc.
(BEI).  Pursuant to the agreement to sell the property, BEI retained responsibility for pre-sale
environmental conditions, and KII took responsibility for post-sale environmental conditions.
BEI has retained lead responsibility for implementing clean-up activities under the Resource
Conservation  and Recovery Act program.

The facility occupies 85 acres on the north bank of the Roanoke River, which borders the facility
property to the west and south.  The Norfolk and Southern Railroad line runs in a northeast to
southwest direction along the northern edge of the property. East of the facility, the Kroger
Company owns and operates a warehouse and distribution center.

The facility produces treated wood products using creosote to pressure treat railroad cross ties,
bridge timbers and crossing panels.  The wood is treated by pressure injection of a creosote
solution, which is the only preservative that has been used since the plant began operations.


RCRA CA  Milestones

The following RCRA CA milestones have been achieved at this facility: A RFI Work Plan was
approved by DEQ on July 31, 2002. Field work associated with Phase I of the RFI Work Plan
was conducted in September-October 2002. The RFI Report was submitted for review in
September 2003 and comments were submitted to the facility in September 2005 requesting
additional investigation.


Environmental Indicator Status

Under the Government Performance and Results Act (GPRA), EPA has set national goals to
address high priority RCRA Corrective Action facilities by the year 2008. EPA is evaluating
two key indicators for each facility: Current Human Exposures Under Control and Migration of
Contaminated Groundwater Under Control. This facility is one of EPA Region Ill's high
priority facilities and falls under this initiative. As of September 30, 2004, the current evaluation

-------
Koppers Industries- VAD003 125770
December 31, 2005 RCRA CA Fact sheet

of Environmental Indicators for this facility is as follows:

•  Human Exposures Controlled Determination: The Current Human Exposures Under Control
   is a YE; however, we will require Koppers to implement interim measures for all areas where
   human exposures are found not to be under control.

•  Release  to Groundwater Controlled Determination: YE: Migration of Groundwater
   contaminants under control.
The primary contaminants in the groundwater and soils at the facility are polycyclic aromatic
hydrocarbons (PAH) and volatile organic compounds (VOC).  Results of ongoing groundwater
monitoring at the facility indicate that, although contaminated groundwater has migrated past the
facility boundary, there has been no change in the size of the plume over the last several years.
Community Involvement
The Roanoke Valley facility borders the Roanoke River, and is located in a light industrial and
residential setting.  VDEQ maintains a facility mailing list that is used to inform the public of
substantial issues regarding the facility.

Institutional Controls _

A Deed Notice is in place identifying the location of the hazardous waste surface impoundment
closed as a landfill with waste in place.
The Commonwealth of Virginia has the lead authority for this project. Please contact the state
project manager listed below for details on this project or the contents of this fact sheet.

DEQ Project Manager:
Ms. Julia M. King-Collins
Virginia Department of Environmental Quality
P. O. Box 10009
Richmond, VA 23240-0009
Phone: (804) 698-4237
Email: jmking-col@deq.virginia.gov

-------
Koppers Industries- VAD003125770
December 31, 2005 RCRA CA Fact sheet
EPA Project Manager:
Mr. Mike Joacobi-3WC23
U.S. EPA Region III
1650 Arch Street
Philadelphia, PA 19103-2029
Phone: (215) 814-3435
Email: jacobi.mike@epa.gov

The Facility Contact is:
Mr. Michael Slenska
Environmental Manager
Beazer East, Inc.
One Oxford Centre, Suite 3000
Pittsburgh, PA 15219-6401
Phone: (412) 208-8867
Email: slenska@hansonle.com

For more information about EPA's corrective action program, including Environmental
Indicators, please visit our site at: www.epa.gov/reg3wcmd/correctiveaction.htm
The previous factsheet was updated in July 2005.  The next update is scheduled for December
2006. Previous fact sheets may be obtained through the listed contacts.

-------