L.A. CLARKE & SON
On this page:
- What Is Being Done to Clean Up the Site?
- What Is the Current Site Status?
- EPA’s Involvement at the Site
On related pages:
The 44-acre L.A. Clarke & Son site is located in Spotsylvania County, Virginia, about 4.5 miles Southeast of Fredericksburg. Wood preservation operations occurred at the Site from 1937 to 1988, except for one inactive period from April 1979 to June 1980. L.A. Clarke and Son, Inc. (L.A. Clarke) operated the wood treatment facility on the property from 1937 to 1988. Throughout the history of the Site, the property has changed hands many times. L.A. Clarke leased the property from the Richmond, Fredericksburg & Potomac Railroad (RF&P) until 1976 when the Clarke family bought the property. In 1980, the Clarke family sold the property to the Curtas family, who then continued to operate the facility on the property until it closed in 1988. The property was reacquired by RF&P in 1992. RF&P then sold the property to Commonwealth Atlantic Properties. A subsidiary of Commonwealth Atlantic Properties, Commonwealth Atlantic-Spotsylvania Inc. (CASI), has entered into an agreement with EPA to clean up the Site and is currently performing work at the Site
When operations were active, railroad ties, telephone poles, and fence posts were preserved at the wood treatment plant by injecting them with a mixture of creosote and coal tar in a sealed compartment under high temperature and pressure. EPA identified polycyclic aromatic hydrocarbons (PAHs) and benzene as the contaminants of concern (COCs) in surface soils and sediments at the Site. These COCs are typical of creosote wood treating. On May 20, 1986, EPA listed the Site on the National Priorities List (NPL). Sites placed on the NPL are eligible for long-term cleanup with federal funding as a part of the Superfund program.
What Is Being Done to Clean Up the Site?
EPA has organized the Site into five operable units (OUs) for purposes of implementing cleanup actions at the Site. The operable units are broken down below:
OU-1 addresses security at the Site. A fence was placed around the Site, except where the railroad exits and enters the Site boundary. Warning signs were placed at the Site boundaries to deter trespassers from entering and risking contact/exposure to any of the COCs. This work was completed in September 1989 and continues to be protective.
OU-2 includes demolition and decontamination of the Site. This work consisted of demolishing the former wood treatment facility in 1993; decommissioning the former wastewater treatment plant; removal, off-site treatment, and disposal of surface water, emulsion, and sludge in the wastewater impoundment in 1995; and excavating and off-site disposal of the contaminated soil at the Site in 1997.
OU-3 was intended to address controls for water at the site, however it was never implemented. The intent was to investigate the feasibility of minimizing the amount of stormwater running onto the Site. However, EPA determined that stormwater controls were not feasible at the Site.
OU-4 addresses site soils and sediments. Cleanup work at the Site is still being implemented. In 2001, contaminated sediments which exceeded the site-specific cleanup level were excavated from portions of the drainage ditches and floodplain areas and disposed of off-site. EPA directed CASI to re-sample the excavated areas to determine if soil and sediments have been re-contaminated with contaminated groundwater discharge. Sampling, which occurred in the summer of 2012, identified several areas where the site-specific cleanup levels were exceeded and required further cleanup. These re-contaminated areas will be addressed in the future.
OU-5 addresses groundwater, surface water and sediments otherwise not previously or fully addressed. These include dense non-aqueous phaseliquids (DNAPLs) that are present and may be mobile in the soils below the process area, the former surface impoundment, and the floodplain area of Massaponax Creek. EPA, in coordination with the Virginia Department of Environmental Quality (VDEQ), is overseeing the responsible party, CASI, as they conduct the investigations and studies to lead to cleanup actions for this OU.
EPA has conducted several Five Year Reviews of the Site’s remedy. These reviews ensure that the remedies put in place protect public health and the environment, and function as intended to meet cleanup standards. The most recent review concluded that the remedy is being implemented as designed and intended. However, EPA deferred protectiveness of the remedy until additional information can be obtained through confirmatory sampling of floodplain, drainage ditch and Westvaco Pond sediments.
For more information, please see the 2015 Explanation of Significant Differences (ESD) or access the Five Year Review Reports under the ‘Site Documents’ list.
What Is the Current Site Status?
Commonwealth Atlantic-Spotsylvania Inc. (CASI) is now the party responsible for fulfilling the cleanup obligations per the Consent Decree (Agreement) signed with EPA.
Dense non-aqueous phase liquids (DNAPLs) are present and may be mobile in the soils below the process area, the former surface impoundment, and floodplain area of Massaponax Creek. Sampling of the floodplain and on-site ditches in the summer of 2012 has shown that several areas require further sediment removal. Upcoming work at the site will address soil sampling and sediment removal.
An investigation in the summer of 2012 also indicated groundwater contamination is present on the south side of Massaponax Creek. In 2015 the EPA determined that the human health and ecological risk assessments had to be revised to ensure all site related contaminants were evaluated properly. The EPA also determined that groundwater monitoring is necessary at a minimum of four times per year. EPA has been working with CASI to start and ultimately complete the additional groundwater sampling and reevaluation of risk assessments as identified in 2015.
The Site’s long-term remedy includes excavation and biological treatment of some contaminated soil and sediment through landfarming; backfilling excavated areas; off-site disposal of contaminated wastewater and associated sludge; and groundwater monitoring. Remedy construction began in 1989, and is ongoing.
EPA’s Involvement at the Site
The U.S. Environmental Protection Agency is overseeing the cleanup of the L.A. Clarke & Son site where the wastewater impoundment was decommissioned in March 1997, including removal and off-site disposal of approximately 240,000 gallons of wastewater, approximately 153,000 gallons of emulsion and sludge, 172 tons of liner material, and 96 cubic yards of contaminated soil from underneath the impoundment liner.
A final cleanup decision for soils and sediments was reached between EPA and Virginia in March 1988. Shortly after, operations at the facility were terminated.
In July 1989, EPA and the Richmond, Fredericksburg, and Potomac (RF& P) Railroad entered into a Consent Decree to conduct the design and construction of the remedy. The cleanup decision was amended in December 1989 to reflect the planned demolition of the process buildings. Actual demolition was completed in 1993.
EPA and VADEQ are currently evaluating changes to work plans submitted for the investigation of ground water, assessing risk and evaluation of alternatives for clean up at the Site and will work with the PRP to ensure that steps will be taken to implement the appropriate remedy.