jHfc _"l_ _ FACT SHEET ^5^0 rfTP^% Public Comment Period for Proposed RCRA Permit Renewal mmmu m m Grenada Solar, LLC/Beazer East, Inc. Facility 1 Koppers Drive, Grenada, Mississippi 38901 EPA ID # MSD 007 027 543 May 2023 EPA Region 4, Atlanta, GA INTRODUCTION Pursuant to the Resource Conservation and Recovery Act (RCRA) of 1976, as amended by the Hazardous and Solid Waste Amendments (HSWA) of 1984, the U.S. Environmental Protection Agency, Region 4, is proposing to renew a HSWA corrective action permit and select a final remedy for the Grenada Solar, LLC/Beazer East, Inc. facility (the Facility) located at 1 Koppers Drive, Grenada, Mississippi 38901. In Mississippi, implementation of the environmental permitting regulations under RCRA is shared between the Mississippi Department of Environmental Quality (MDEQ) and the EPA. The State of Mississippi has been authorized by the EPA to issue permits for the operation, closure, and post-closure care of Hazardous Waste Management Units (HWMUs), while the EPA retains authority to issue permits requiring corrective action for releases from Solid Waste Management Units (SWMUs) and Areas of Concern (AOCs). SWMUs are any units which have been used for the treatment, storage, or disposal of solid waste at any time, irrespective of whether the unit is or was intended for the management of solid waste. AOCs are areas having a probable release to the environment of a hazardous waste or hazardous constituent which is not associated with a SWMU and is determined to pose a current or potential threat to human health or the environment. This draft HSWA Permit will be a companion permit to the Hazardous Waste Post-Closure Permit issued by MDEQ. Together, the EPA and MDEQ permits constitute the full RCRA Permit for this Facility. PUBLIC COMMENT PERIOD AND REQUESTS FOR HEARING The EPA encourages the public to review and comment on this draft HSWA permit during a 45-day public comment period. The 45-day comment period begins on June 1, 2023 and ends at midnight on July 15, 2023. Written comments on the draft permit should be submitted to Harbhajan Singh, U.S. Environmental Protection Agency, Region 4, 61 Forsyth Street, SW, Atlanta, GA 30303, or via email to singh.harbhajan@epa.gov. Comments must be submitted before the end of the public comment period. In addition to submitting comments, the public may also request a formal public hearing on the draft HSWA Permit. Such a request must be made during the 45-day public comment period, must be in writing to the EPA contact listed above, and must state the nature of the issues to be raised at the hearing. If a public hearing is held, the time and place of the hearing will be published at least 30 days prior to the hearing. ADMINISTRATIVE RECORD The draft HSWA Permit, and other supporting documents, are contained in the Administrative Record and are available at the locations listed in Table 1 below. 1 ------- Tsihle 1. Locations lor Ailniinislr;ili\c Record Local EPA Online Elizabeth Jones Library 1050 Fairfield Avenue Grenada, Mississippi 38902 U.S. EPA, Region 4 Atlanta Federal Center 61 Forsyth Street, SW Atlanta, GA 30303 Phone: (662) 226-2072 Email: crystalosborne@elizabeth.lib.ms.us Hours: 8:30 a.m. - 4:30 p.m. (central time) Hours: 8:00 a.m. - 4:30 p.m. (eastern time) Contact: Harbhajan Singh Phone: (404) 562-8473 Email: singh. harbhaj anVvcpa. gov Contact: Crystal Osborne STATE httDs://scmsDiib.CDa. eov/src/collection/04/AR67335 Mississippi Department of Environmental Quality 515 East Amite Street Jackson, MS 39202 Hours: 8:00 a.m. - 4:30 p.m. (central time) Contact: Deidre Thompson Phone: (601) 961-5758 Email: dthompson@mdeq. ms. gov POST PUBLIC COMMENT PERIOD - FINAL DECISION The EPA will not finalize its decision until after review of and response to all comments received during the public comment period and the public hearing (if held). After the EPA's consideration of the public comments that are received, the comments will be summarized, and responses will be provided in a Response to Comments (RTC) document. The RTC document will be drafted after the conclusion of the public comment period and will be incorporated into the Administrative Record. Issuance of the final permit will be in accordance with 40 C.F.R. § 124.15. All persons submitting comments will be notified of the EPA's final decision. FACILITY BACKGROUND The Facility encompasses 171 acres and extends approximately 1.2 miles northwest to southeast and is 0.3 miles wide (see Figure 2-1). The Facility is bordered by the Carver Circle community to the east, the Illinois Central railway services to the west, and the Koppers Drive/Bailey Road community to the southwest. Two surface water streams flow across the Facility towards the Batupan Bogue: the Northern Stream to the north and the Central Ditch in the middle. Several private water supply wells are located within a two-mile radius of the Facility. Currently, the Facility and residents of adjacent communities are supplied with municipal drinking water. The Facility is a former wood treatment plant. It manufactured treated wood products such as railroad ties, poles, and lumber in pressurized cylinders using various conditioning and treating processes. The Facility was historically divided into three areas: (1) the Northern Area (wood storage area); (2) the Central Area (process area); and the Southern Area (wood storage area). Wood treating operations involved pentachlorophenol and creosote-based preservatives. The Facility ceased operations in 2012. 2 ------- The Facility has a long history of owners since the beginning of its operations in 1904. Currently, Beazer East, Inc., a former operator at the Facility, is conducting the corrective action activities under the HSWA Permit. In July 2021, the Facility was sold to Grenada Solar, LLC, which plans to operate a solar energy facility on the property. SUMMARY OF DRAFT HSWA PERMIT This draft HSWA Permit renewal is designed to update the existing HSWA Permit that was last renewed on June 17, 2012, and administratively continued pursuant to 40 C.F.R. § 270.51. Justifications for the currently required actions and decisions summarized below are contained in the Administrative Record for this draft permit. This draft HSWA Permit renewal contains the following components: > HSWA Permit Cover Page The Cover Page cites authority for issuance of the HSWA Permit and establishes the term of the permit, which is 10 years. > PART I. Standard Permit Conditions Part I of the HSWA Permit sets forth standard conditions applicable to all hazardous waste management facilities (e.g., duty to comply, duty to allow access, etc.). Each Condition specifies the exact authority to require the Permittee's compliance with the Condition. Unless otherwise specified, all citations refer to the regulations as codified in Title 40 of the Code of Federal Regulations (40 C.F.R.), which have been incorporated into Mississippi's authorized hazardous waste program at 11 Miss. Admin. Code Pt. 3, Ch. 1. > PART II. Corrective Action Part II of the HSWA Permit sets forth the specific corrective action requirements to address releases from SWMUs and AOCs that have been identified at the Facility. Specifically, HSWA Permits can require any of the following corrective action activities for any SWMUs or AOCs: o A SWMU or AOC Assessment Report to report and/or investigate a newly identified SWMU or AOC. o A RCRA Facility Investigation to determine the scope and extent of a release, o Confirmatory Sampling to determine if a release has occurred. o Interim Measures to minimize or prevent further contamination or exposure while long-term remedies are evaluated. o A Corrective Measures Study to identify and evaluate potential remedial alternatives for the releases that have been identified at the Facility, o A Remedy to implement corrective measures necessary for the protection of human health and the environment. Ultimately, there are two basic conclusions possible at any SWMU/AOC: 1) A remedy (cleanup) is needed to protect human health and/or the environment; or 2) No further action is required to protect human health and/or the environment. The initial HSWA Permit for the Facility, issued in 1988, identified 13 SWMUs at the Facility based on the information contained in the 1987 RCRA Facility Assessment (RFA) Report. At the time of the first HSWA permit renewal in 1998, a total of 17 SWMUs had been identified at the Facility (see Figure 2-2). Three (3) of these SWMUs have been addressed by MDEQ. The first, a hazardous waste surface impoundment (SWMU 2) that received and managed K001 listed hazardous waste, is currently regulated by the MDEQ Post-Closure Permit. The Spray Irrigation Field (SWMU 3) was closed under an MDEQ-approved Closure Plan. The Boiler 3 ------- Ash Landfill (SWMU 5) was closed pursuant to a negotiated Order with MDEQ. Several phases of RCRA Facility Investigation (RFI) have been conducted at the Facility to characterize the nature and extent of contamination in various media (soils, sediments, surface water, and groundwater). The Phase II RFI for the Facility was approved in 2005. The contaminants of concern at the Facility include polycyclic aromatic hydrocarbons (PAHs), dioxin/furans, and pentachlorophenol (PCP) in soils, and benzene, PAHs, and PCP in groundwater. Investigations have also identified releases of contaminants in the on-site and off-site portions of the Northern Stream and Central Ditch. The facility submitted a Site-specific Human Health Risk Assessment in the Complete RFI of 2003 and augmented in the Evaluation of Chemistry and Toxicity of Northern Stream Sediments in 2006. A sensitivity analysis was performed for the findings of the 2003 Human Health Risk Assessment and 2009 CMS Workplan due to changes in specific default parameters. Residential scenarios are not considered applicable to the Facility as the Facility is currently zoned heavy industrial. The corrective action objectives are based on future commercial/industrial land use. Interim Measures (IM) for the Former Wastewater Treatment System (SWMU 11) were implemented between 1999-2000 and included excavation of sediments, installation of a geobentonite liner, construction of sealed- joint, steel sheet-pile cutoff wall, implementation of a dense non-aqueous phase liquid (DNAPL) recovery system (ongoing), and sediment cap installation and annual inspections (ongoing). These IMs along with Monitored Natural Attenuation (MNA) for groundwater are being incorporated into the final Remedy for SWMU 11 being proposed with this permit renewal. Additional off-site sampling was also conducted in the Carver Circle community area, Tie Plant Road community, Grenada and Montgomery Counties, Simmons Road community, and Koppers Drive and Bailey Road community from 2010-2021. Corrective measures were implemented in the Carver Circle and Simmons Road community areas. The EPA issued several Fact Sheets documenting the findings of such investigations. Ultimately, the EPA determined that no further action was required in these community areas. A Corrective Measures Study (CMS)/Corrective Measures Implementation Plan (CMIP) was approved by the EPA in March 2022, pursuant to which Beazer evaluated remedial options and proposed a recommended remedy for the Facility. This draft HSWA Permit renewal proposes the selection and implementation of soil and groundwater corrective action remedies at several SWMUs. A more detailed discussion of the remedy alternatives evaluation and proposed remedies is contained in the Statement of Basis for this proposed HSWA Permit. The remedy for soils at SWMU 1 (Oil/Water Separator), SWMU 8 (Drip Track Area), SWMU 9 (Chemical Unloading Area), SWMU 10 (Underground Storage Tank), SWMU 16 (Old Oil/Water Separator), and SWMU 17 (Old South Drip Pad/Track) includes: (1) the installation of an engineered cover system comprised of either a six-inch thick section of aggregate or vegetative soil cover; and (2) preparation and implementation of institutional controls (Environmental Covenant and Materials Management Plan). The remedy for groundwater at SWMU 1 (Oil/Water Separator), SWMU 4 (Boiler), SWMU 8 (Drip Track Area), SWMU 9 (Chemical Unloading Area), SWMU 10 (Underground Storage Tank), SWMU 16 (Old Oil/Water Separator), and SWMU 17 (Old South Drip Pad/Track) includes: (1) Monitored Natural Attenuation (MNA); and (2) preparation and implementation of institutional controls (Environmental Covenant and Materials Management Plan). 4 ------- Based on current information, the EPA is making a "no further action" decision for the following SWMUs: • SWMU 2 (Surface Impoundment) • SWMU 3 (Spray Irrigation Field) • SWMU 5 (Boiler Ash Landfill) • SWMU 6 (Process Cooling Reservoir) • SWMU 7 (Container Storage Area) • SWMU 12 (North Waste Piles) • SWMU 13 (South Waste Piles) • SWMU 14 (Temporary Storage of Soil) • SWMU 15 (Two Soil Containment Structures) This draft HSWA Permit also includes provisions for notifying the EPA of newly identified releases, or newly identified SWMUs and AOCs, as well as provisions for financial assurance for completion of the cleanup. 5 ------- 6 ------- 7 ------- 8 ------- |