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2.1.1 Narrative
The EPA Remedial Project Manager for the Site requested assistance from the EPA Region 3 Office of Preparedness and Response to mitigate the threat of creosote trapped in an underground storm drain and connecting pipe discharging to the Elizabeth River.
2.1.2 Response Actions to Date
In September of 2013, the OSC performed an assessment and made the determination that a response action was needed to prevent the creosote trapped in the storm drain box from migrating to the Elizabeth River.
In October of 2013, EPA ERRS contractor (WRSCompass) subcontracted the design and construction of a new storm drain box. This box was installed in October of 2013.
Remedial actions are ongoing at the Site. Over the next 6-24 months, onsite personnel, including the EPA RPM and the Army Corps of Engineers observed that creosote contamination was still migrating into the new box.
In August of 2015, the Director of the R3 Office of Preparedness and Response signed a request for ceiling increase, change in scope of work, and exemption from statutory limits to authorize funds for the OSC to replace or line the pipe.
EPA ERRS Contractor (ER LLC) hired a company to use flexible pipe video to inspect the pipe. The OSC determined that lining the pipe was the preferred response action. Replacing the pipe would have incurred significant additional costs including excavating Veneer Road, blocking access to the command post area, and installing recovery wells to keep groundwater from entering the work area.
ERRS subcontracted Tri-State Utilities to line the pipe with a self curing resin liner. This work was performed in February 2016.
The response action is complete. The EPA RPM will contact the OSC if any additional problems arise.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
Enforcement activity is consistent with the PRP search being performed under the Remedial Action.
2.1.4 Progress Metrics
10/30/13: 15 cubic yards contaminated solids transferred to onsite staging area.
2/26/16: 800 gallons of flush water disposed offsite
2/28/16: Approximately 100 cubic yards contaminated soils transferred to onsite staging area
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