Site activities continue in the stream which runs through the Site to the Elizabeth River. Stream excavation activities are approximately 90% complete. The OSC has noted that the extent of contamination increases significantly towards the mouth of the stream to the Elizabeth River.
ERRS is working this week on excavating creosote-contaminated sediments and soils from the stream which runs through the Site. All activities this week are focused on the north side of the stream. During excavation this week, three significant findings were made:
1. Creosote contamination in the north bank of the stream runs northward at least to the property line and likely beyond the property onto the adjoining property. A thick 6-8 inch layer of creosote exists beneath an approximate 3-foot overburden. Beneath this layer are native sands, which are not contaminated. The OSC made the decision not to remove the soil between the stream and the fence because doing so would likely double the amount of waste created. At this time, EPA does not have a disposal contract in place. Until the disposal costs are determined, actions will be limited to the contaminated soils within the banks of the stream.
2. The south bank of the stream is primarily fill material. The federal natural resource trustees recommended that this area be sloped back to a 2:1 bank and planted. However, EPA has discovered that the material beneath the bank is almost entirely fill material which appears to be from an old (historical) pier. Large wood pilings extend back toward the Site perpendicular to the stream. These materials cannot be safely removed without removing a significant portion of the Site base. Also, this action would likely cause more fill materials to spill into the stream. EPA will still implement soil and erosion controls where possible, but will be unable to create a 2:1 slope.
3. Based on observation, most of the creosote leaching to the stream from the banks (this is separate from the creosote already in the sediments) is leaching from the north side of the bank (away from the property) rather than the south side. Both banks are on Hazel Court property. However, this finding suggests that a significant amount of cresosote may be emanating from the next property.
The OSC consulted EPA Elizabeth River Liaison R. Sturgeon on the above issues. EPA is attempting to perfrom a PA/SI on the adjoining property. However, EPA currently does not have access to perform this work.
The OSC considers assessment of the adjoining property crucial to determining the extent of creosote contamination which is impacting the stream being cleaned.
OSC Wagner sent a "Notice of Intent to Export Hazardous Waste" request to EPA HQ. This is based on possible anticipated bids for disposal in Canada. However, no subcontracts for this work have been awarded at this time.
Work will continue on the stream including excavation, backfilling, and restoration activities. However, no excavation will be performed in the southern triangle of the Site until T&D of contaminated soil commences.
START has been tasked with sampling monitoring wells on Site. The purpose of this sampling will be to determine current groundwater conditions. The groundwater is not used on Site for drinking water.
START has also been tasked with performing sampling around the perimeter of the Site in areas where no further work is planned. This information will be provided to the City of Chesapeake and VDEQ to provide the stakeholders with information on Site conditions for possible future use. To the OSC's knowledge, there are no future use issues at this time.
Excavation of the contaminated stream sediments to continue.
Once the stream is excavated and graded, crews will demobilize until disposal arrangements are made. Disposal will likely resume in July.
NOTE: POLREP #15 inadvertendly listed the waste code as F014. The correct wast code should be F034. This was a typographical error.
The banks of the stream cannot be restored on a 2:1 slope as requested by the Natural Resource trustees. The south edge of the bank is fill material. Included in this fill material are large wood pilings which extend at least 12 feet back. The area cannot be properly sloped with the large percentage of fill contained.
The north end of the bank contains a significantly large vein of creosote which extends at least to the property fenceline and highly likely onto the adjoining property. Therefore, sand is being compacted against this bank as a temporary holding measure. The OSC has determined that installing a liner would not be effective as the creosote would run under the liner and into the sands. More containment may be necessary in this area. The OSC is awaiting a better cost estimate before determining future actions for this containment area.
The creosote leaching to the stream from the north bank extends and least to the property line and likely beyond. Access is needed to the adjoining property to determine this extent of contamination.
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