EPA, ERRS (Guardian), and START (TechLaw) are continuing removal actions to mitigate the threat to public health, welfare, and the environment posed by the uncontrolled release of creosote and creosote contaminated soils from the Site.
Site activities at this time are limited to the tank areas which face the Elizabeth River.
This polrep covers the time frame of 6/10/06 - 6/16/06. During this time, efforts focused on the cleaning of tanks #1 and #2, which are the front two tanks of the 4-tank area.
During excavation, crews are encountering groundwater before all contaminated soil is removed. The OSC has determined that excavation, at least for this phase of the project will be halted at the groundwater table. Excavating beyond the groundwater table without preventive countermeasures in place may add to the contamination in the groundwater.
On 6/12/06, ERRS dug several test pits throughout the Site. Since the extent of contamination extends significantly beyond the original estimated area, the OSC is trying to determine if the contamination is consistent throughout the entire Site or if the contamination is limited to the southeast portion of the Site.
Nine test pits were dug around the Site using the onsite excavator. Pit locations were chosen based on accessbility and an effort to follow the path from the tanks to the north end of the Site where a stream crosses the Site. The OSC has already determined that this stream is contaminated with creosote.
The findings of this crudely performed assessment seem to indicate that the creosote contamination is mostly contained to a large triangular portion of the Site. Former railroad tracks extend from the entrance to the Site in a northeast direction to the Elizabeth River. Consistently, visible creosote contamination was observed at all pits within this triangle which is delineated by the railroad tracks, the south end of the the property line adjacent to Hess, and the Elizabeth River. A rough estimate by the OSC and START predicts that this entire area is covered with approximately 18 inches of non-creosote-contaminated fill. At approximately 18 inches, the contamination is extensive at least to the groundwater table, which, in the areas tested, appears to be approximately 4 feet below the surface. The OSC has tasked START to provide rough calculations of this area.
During this assessment, a pipeline was discovered which crosses the stream on the northern end of the property. With the property owner's permission, ERRS cleared the vegetation of this area so that the pipe could be examined. The pipe appears to be a six-inch line which runs from the Hazel Court property to the Shotmeyer property. No visible product was evident in this area.
Also this week, ERRS provided the OSC with bids for initial disposal. The OSC is planning an initial round of disposal to make room on the Site for additional excavated soil. Two of the bids were for international disposal. The OSC is working closely with EPA Office of Regional Counsel for guidance on international disposal.
On 6/15/06, the Site was hammered with the impact of Tropical Storm Alberto. Over six inches of rain fell on the Site and completely flooded the access road leaving the Site. Fortunately, all workers were able to leave safely.
On this rainy day, EPA Elizabeth River Project Coordinator R. Sturgeon visited the Site along with a representative from the Elizabeth River Project. The Elizabeth River Project is a group dedicated to the cleanup and protection of the Elizabeth River (see link on this Site web page). Mr. J. Rieger of the ERP provided valuable information to the OSC on some of the history associated with the Site.
On Thursday, 6/16/06, ERRS completed the removal of sludge and product from Tank #1. 1850 gallons of liquid creosote and sludge was transferred to drums and staged for disposal. The OSC is not attempting to capture the volume of contaminated soil as this is being consolidated into a staging area on Site.
Next week, ERRS will continue working on the remaining three tanks. Tank #2 is scheduled to be addressed next. EPA, ERRS, and START are complying with OSHA confined space entry procedures for work inside the tanks. Confined space entry permits are being prepared on Site.
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.
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