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In April of 2004, EPA was contacted by the Virginia Department of Emergency Management and the City of Salem Fire Department regarding the alleged improper storage of drums and containers on the Site which were suspected to contain hazardous materials. EPA performed a windshield assessment at that time.
Following the windshield assessment, OSC Wagner met with VADEQ Brownfields Coordinator C. Evans. The City of Salem is interested in revitalization of this property, but is concerned of the past history of the Site (former Superfund removal Site) and current conditions.
On 4/26/04, OSC Wagner met with VA DEQ representatives and also representatives from a company interested interested in buying the property.
From the assessment, the OSC determined that a removal assessment was needed to determine if conditions at the Site posed an imminent and substantial threat to public health, welfare, or the environment due to the presence of hazardous substances, pollutants, or contaminants. The OSC discussed with DEQ the possibility of using removal assessment data in order to fill the information gaps regarding the Site being considered as a Brownfields candidate.
At the meeting, the parties discussed possible disposal of the drums. The owner of the drums would either need to sign drum characterization profiles based either of generator knowledge or on sampling data. EPA and DEQ agreed that sampling would be needed to determine RCRA characteristics and also TCLP sampling for disposal in accordance with land ban restrictions.
The prospective purchaser agreed to work with the property owner to obtain this information.
In September of 2004, the OSC contacted Mr. W. Klepper from VADEQ for a Site update. DEQ informed EPA that the drums had been removed, but no sampling had been performed.
In November of 2004, the OSC contacted the property representative, who indicated that the drums had been removed. The OSC stressed the need for surface soil sampling to determine if any releases had occurred, in the absence of Site operational records.
The OSC requested permission to perform sampling for a removal assessment. The OSC also informed the property representative that the data would be shared with the Brownfields representatives, with his approval.
On 12/14/04, OSC Wagner and START (E&E) performed a removal soil sampling assessment. The Site was roughly broken down into 9 areas, including the building in which the drums were stored. OSC and START collected 5-point composite samples from each of these 9 areas. The samples will be analyzed for volatile organic contaminants, semi-volatile organic contaminants, diesel and gasoline range-organics, metals, and PCBs. The OSC coordinated with the property representative on Site who granted access for the removal.
During the assessment, the OSC observed approximately 15 55-gallon drums on Site. However, upon investigation, the majority of drums appeared to be empty, based on weight. The drums which were marked were marked as oil and/or oil products. Several drums were unmarked; however, based on appearance, the OSC suspects these were also oil-type products.
The OSC will await analytical data. If there are areas which indicate high levels of contamination, the OSC will make a determination at that time.
With the property representative's permission, EPA will share the data with the Brownfields program.
The OSC experienced a 2-day delay in Site operations due to the inability to obtain a laboratory for VOC analysis through CLP procedures. These samples were collected on 12/16/04.
All costs to this date on this project should be considered assessment costs under CERCLA 104(b)
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