United States Environmental Protection Agency
Region III
POLLUTION REPORT

Subject: 

EPA continues removal actions to remove creosote and contaminated creosote soils from the Site.  Other hazardous substances at the Site which pose an imminent and substantial threat of release will be addressed later in this project.

At this time, efforts are being concentrated on the tank area which contains four vertical tanks.

ERRS and START demobilized from the Site during the weekend of 6/17-6/18/06 for their regularly scheduled break.  Operations resumed on Monday, 6/19/06.  OSCs Casillas and Ventura performed oversight of all activities as OSC Wagner was on phone duty and unable to oversee daily activities.

This week the Site was bombarded by heavy thunderstorms every afternoon.  On several days, work had to be suspended early due to the hazards posed by lightning strikes in the area.

Tank #1 was completed on 6/16/06.  For the purposes of Site activities, Tank #1 was the tank closest to the access road on the left side; Tank #2 is next to tank #1 on the right; Tank #3 is behind Tank #1, and Tank #4 is behind Tank #2.

Activities early in the week focused on decontaminating Tank #2.  Tank #2, was mostly solid sludge material which need to be shovelled from the tank.  In comparison, Tank #1 was mostly liquefied sludge.  As a result, only 11 drums of liquid were generated from Tank #2.  Nevertheless, Tank #2 had approximately 8 feet of product inside.  Tank #2 was completed on Wednesday, 6/21/06.  

On Thursday 6/22/06, Tanks #1 and #2 were toppled by ERRS.  A representative from Hazel Court Enterprises, Inc. removed the decontaminated tanks as scrap metal.

Also on 6/22/06, representatives from the City of Chesapeake Fire Marshall's Office visited the Site for a Site update.  

On Friday, 6/23/06, the OSC confirmed with EPA Region V that Ross Incineration, a disposal company in Ohio, is currently in compliance with state and federal regulations regarding the disposal of hazardous waste.  The OSC made the determination to use this facility for an initial phase of disposal in order to make room for additional activities at the Site.  The OSC gave ERRS approval to proceed with the disposal subcontract for the first 150 tons of material.  The OSC considers this need time-critical because operations cannot progress until more space is made on the Site for staging.

On Friday 5/23/06, EPA R. Sturgeon, Elizabeth River Project Coordinator, visited the Site with representatives of Amerada Hess, the neighboring facility.  The OSC received permission from the Site operator for these visitors to access the Site.  The purpose of this visit was for EPA to show Hess representatives creosote pipes discovered in the subsurface soils which lead over to and on to the Hess property.  The lines were cut and drained from the Hazel Court side; however, there is likely additional contaminated piping in this area on the Hess side.  These representatives also informed EPA that Hess is actively pumping creosote from the groundwater on their property and has collected a significant amount of product to date.  Hess is also operating a phytoremediation system to plant trees on the Hazel Court side of the property to uptake some of the creosote in the subsurface soils.

ERRS began to work on Tank #3 this week.

ERRS will continue to work on Tank #3 and then proceed to Tank #4.

Several key issues are currently of interest

Extent of Contamination - The cleanup goal of the signed Action Memo is no visible contamination.  However, groundwater is being encountered prior to meeting this goal.  The OSC has made the onsite determination to stop excavation at groundwater because digging below the groundwater table without protection measures in place may further adversely affect the groundwater and consequently, the Elizabeth River.


  Inability to comply with ARARs - Due to the situation stated above, the OSC will likely not be able to comply with the ARARs for cleanup goals.  However, post-excavation samples will be collected to provide state and local agencies information on the amount of contamination left behind.


  International Disposal - Since the waste generated from the Site is a listed hazardous waste, disposal options are limited.  The OSC is working closely with ORC to determine viable options.