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Record of Decision System (RODS)

L.A. CLARKE & SON

Abstract

Site Name:  L.A. CLARKE & SON
Address:  ROUTE 608 
City & State:  SPOTSYLVANIA  VA  22553
County:  SPOTSYLVANIA
 
EPA ID:  VAD007972482
EPA Region:  03
 
NPL Status:  Currently on the Final NPL
 
ROD Type:  Record of Decision
ROD ID:  EPA/ROD/R03-88/040
ROD Date:  03/31/1988
Operable Unit(s):  01
 
Media:  SEDIMENTS SOIL
 
Contaminant:  BENZENE CREOSOTE, PNAS
 
Abstract:  THE 40-ACRE L.A. CLARKE SITE IS LOCATED IN SPOTSYLVANIA COUNTY, VIRGINIA. WOOD PRESERVING OPERATIONS BEGAN AT L.A. CLARKE & SON, INC. IN JUNE 1937 AND HAVE CONTINUED TO DATE WITH ONLY ONE INACTIVE PERIOD, FROM APRIL 1979 TO JUNE 1980. DURING THE PAST 50 YEARS, CREOSOTE CONTAMINATED SOIL AND SEDIMENTS RESULTED FROM FACILITY OPERATIONS SPILLS, WASTE STREAMS ENTERING THE DRAINAGE DITCHES, AND ONSITE DISPOSAL. HISTORICAL AERIAL PHOTOGRAPHY INDICATES THAT FROM AT LEAST 1953 THROUGH 1974 WASTEWATER WAS DISPOSED INTO TWO CONCRETE-LINED PITS. AN AREA LOCATED NORTH OF THE PROCESS FACILITY ALSO RECEIVED WASTES. OVERFLOW FROM THE CONCRETE PITS WAS STORED IN AN EARTHEN PIT. EXCESS WATER WAS DISCHARGED TO DRAINAGE DITCHES AND SPRAYED ON THE GROUND AROUND THE STORAGE YARD TO CONTROL DUST. AERIAL PHOTOGRAPHY IDENTIFIED FOUR ADDITIONAL WASTE WATER PITS WHICH DATE BACK TO 1937. THESE FOUR PITS WERE FILLED IN BY 1979. IN 1975, L.A. CLARKE & SON, INC. WAS ISSUED A NATIONAL POLLUTION DISCHARGE ELIMINATION SYSTEM (NPDES) PERMIT FOR OUTFALLS FROM TWO ONSITE DRAINAGE DITCHES. THESE PERMITS ARE STILL IN EFFECT. PHENOL IS THE ONLY TOXIC CONTAMINANT REGULATED BY THE PERMIT. IN 1980, L.A. CLARKE & SON, INC. WAS CLASSIFIED UNDER RCRA AS A TREATER OF HAZARDOUS WASTE DUE TO THE PRESENCE OF A WASTEWATER IMPOUNDMENT LAGOON. AS PART OF A STATE-MANDATED REMEDIAL ACTION IN 1982, APPROXIMATELY 1,400 YD3 OF SOIL WAS EXCAVATED FROM THE PROCESSING AREA TO CREATE A RCRA-REGULATED SOIL WASTE PILE. THE PRIMARY CONTAMINANTS OF CONCERN AFFECTING BOTH THE SOIL AND SEDIMENTS (TOTAL VOLUME OF 11,900 YD3) ARE CONSTITUENTS OF CREOSOTE INCLUDING PNAS AND BENZENE.

THE SELECTED REMEDIAL ACTION FOR THIS SITE INCLUDES; IN-SITU SOIL FLUSHING OF SUBSURFACE SOIL UNDERLYING THE PROCESS BUILDINGS FOLLOWED BY IN-SITU BIODEGRADATION IN THE CREOSOTE LAYER AREA; BIOLOGICAL DEGRADATION OF BOTTOM SEDIMENTS IN THE LAGOON; ONSITE LANDFARMING OF EXCAVATED SURFACE SOIL, SEDIMENTS, AND SUBSURFACE WETLAND SOIL; EXCAVATION, DREDGING, AND ONSITE CONSOLIDATION OF CONTAMINATED SEDIMENTS, SUBSURFACE WETLAND SOIL, BURIED PIT MATERIALS, AND SURFACE SOIL NOT REMEDIATED VIA IN-SITU FLUSHING; EROSION/SEDIMENTATION CONTROL; BACKFILLING EXCAVATED AREAS WITH TREATED SOIL AND SEDIMENT; AND GROUND WATER MONITORING. THE ESTIMATED CAPITAL COST FOR THIS REMEDIAL ACTION IS $21,080,000 WITH PRESENT WORTH O&M OF $33,900. SHOULD IT BE DETERMINED THAT THE ONSITE PROCESS BUILDING REQUIRES REMOVAL, LANDFARMING/BIODEGRADATION MAY BE IMPLEMENTED AT AN ADDED CAPITAL COST OF $910,900.
 
Remedy:  THE SELECTED REMEDY ADDRESSES THE PRINCIPAL THREATS AT THE SITE BY CONTROLLING CONTAMINANT SOURCES. AN ESTIMATED 118,000 CUBIC YARDS OF SOIL AND SEDIMENT REQUIRE REMEDIATION. SOURCES TO BE REMEDIATED INCLUDE TWO RESOURCE CONSERVATION AND RECOVERY ACT REGULATED UNITS WHICH CONSTITUTE AN ESTIMATED 2% OF THIS VOLUME. ADDITIONAL REMEDIAL ACTION ADDRESSING CONTAMINANT MIGRATION PATHWAYS (GROUNDWATER AND DOWNGRADIENT SEDIMENT) SHALL BE DETERMINED IN A SECOND OPERABLE UNIT RECORD OF DECISION.

THE SELECTED REMEDY INCLUDES THE FOLLOWING MAJOR ELEMENTS;

- IN SITU SOIL FLUSHING, UTILIZING A SURFACTANT SOLUTION, OF SUBSURFACE SOILS (CREOSOTE LAYER) UNDERLYING THE PROCESS BUILDINGS;
- INJECTION/RECOVERY WELLS TO DIRECT WASHING SOLUTIONS TO THE CONTAMINATED SOILS AND THEN RECOVER THE CONTAMINANT-LADEN WASH SOLUTION.
- DESIGN AND USE OF A WELL SYSTEM TO ATTAIN A SELF-CONTAINED FLUSHING SCHEME TO PREVENT ENVIRONMENTAL IMPACTS.
- A WASTEWATER TREATMENT SYSTEM TO REMOVE CONTAMINANTS FROM WASHING SOLUTIONS FOR RECYCLING OF SOLUTION BACK INTO THE PROCESS. DISPOSAL OF TREATMENT RESIDUALS IS DEPENDENT ON POST-TREATMENT CHARACTERIZATION.

- IN SITU BIODEGRADATION IN THE CREOSOTE LAYER AREA (FOLLOWING THE IN SITU FLUSHING);
- NUTRIENT AND OXYGEN-RICH COMPOUNDS SHALL BE INJECTED VIA THE WELL SYSTEM DESCRIBED ABOVE.

- ON-SITE LAND FARMING OF EXCAVATED SURFACE SOILS, SEDIMENTS, AND SUBSURFACE WETLAND SOILS. THE MAIN LAND FARMING OPERATION WILL BE PLACED IN NORTHEAST AREA OF SITE. SOME SOILS MAY BE LAND FARMED INPLACE. THE RCRA REGULATED SOIL PILE AND WESTVACO POND SEDIMENT SHALL BE LANDTREATED IN PLACE.

- CREOSOTE CONTAMINATED BOTTOM SEDIMENT IN THE RCRA REGULATED LAGOON SHALL BE BIOLOGICALLY DEGRADED IN A TANK.

- EXCAVATION/DREDGING AND CONSOLIDATION OF CONTAMINATED SEDIMENTS (DITCHES 1, 2, AND 3, AND WETLANDS), SUBSURFACE WETLANDS SOILS, BURIED PIT MATERIALS, AND SURFACE SOILS THAT ARE NOT REMEDIATED VIA IN SITU FLUSHING/BIODEGRADATION AND CANNOT BE LAND TREATED IN PLACE;
- GEOTEXTILE SILT FENCES, SEDIMENTATION BASINS, AND/OR DIVERSION/SURFACE MANAGEMENT TO CONTROL OFF-SITE SOIL TRANSPORT AND DIVERT SURFACE-WATER FLOWS.
- ORGANIC VAPOR MONITORING.
- DEWATERING OF SEDIMENTS, TREATMENT OF WATER (IF REQUIRED), AND
ON-SITE DISCHARGE OF TREATED WATER.

- EROSION/SEDIMENTATION CONTROL (AS DESCRIBED FOR EXCAVATION).

- BACKFILL EXCAVATED AREAS WITH TREATED SOIL AND SEDIMENT. COVER BACKFILLED AREAS WITH TOPSOIL AND REVEGETATE.

- DURING AND POST TREATMENT GROUNDWATER MONITORING.

SHOULD THE ON-SITE PROCESS BUILDING BE REMOVED, ALTERNATIVE 4, LANDFARMING/BIODEGRADATION (AS DESCRIBED IN THIS DOCUMENT) WOULD BE AN EQUALLY PREFERABLE ALTERNATIVE AND MAY THEREFORE BE IMPLEMENTED. THE COMMONWEALTH OF VIRGINIA CONCURS WITH THIS DECISION.

THE EPA AND THE COMMONWEALTH OF VIRGINIA ARE CURRENTLY PURSUING MEASURES TO ENSURE THAT ON-GOING WOOD TREATMENT OPERATIONS AT THE L.A. CLARKE SITE WILL NOT RESULT IN FURTHER CONTAMINATION OF SOILS AND SEDIMENTS, AND AS A RESULT, GROUNDWATER AND SURFACE WATER.
 
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