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EngineeringSDM & S DocID 2095104 · PDF file qa/qc procedures implementation of qa/qc procedures closure cost estimate figure no. 1 general location map figure no. 2 sitemap figure

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Submitted to Commonwealth of Virginia
Department of Environmental Quality 5636 Southern Boulevard
Virginia Beach, VA 23462
195 South Rosemont Road Suite 118
Virginia Beach, VA 23452
^^sEngineering & ^ ^ E n v i r o n m e n t , Inc.
Oceana Salvage Inc. RAP, Burial Unit No. 1
4.3.1 Site Mobilization and Set Up 19 4.3.2 SWMU Sampling and Analysis 19 4.3.3 Excavation and Disposal of Contaminated Soil 28 4.3.4 Certification and Final Report 34 4.3.5 Closure Schedule 34
Oceana Salvage Inc. RAP, Burial Unit No. 1
^it*Environment, Inc. R^P. Burial Unit No. 1
Oceana Salvage, Inc. (OSI) has retained Engineering & Enviroimient, Inc. (E&E) to prepare a
Remedial Action Plan (RAP) for the Solid Waste Management Unit (SWMU) at the OSI facility
that is located in the vicinity of 1040 S. Oceana Boulevard in Virginia Beach, Virginia ("site").
This SWMU is known as Burial Unit #1. The RAP has been prepared in accordance with Item 2
of Appendix A, Schedule of Compliance of the Virginia Waste Management Board (VWMB)
Enforcement Action, Order by Consent, executed and signed through the Director of the Virginia
Department of Environmental Quality (VDEQ) on July 31, 2002 (Order). Accordingly, the RAP
is submitted to VDEQ for review. The following subsections provide information on the purpose
and the performance standards to be achieved by implementing this RAP.
The purpose of the RAP is to outline activities to be performed to achieve permanent closure of
the SWMU and to mitigate existing or potential future degradation of the environment. In
addition, the RAP has been developed to protect the health and the safety of the general public
and persons involved with the closure operations.
Upon approval and implementation, this Remedial Action Plan will close the SWMU in a
manner that:
• Remove and dispose of pieces of battery casing and Jfragments of other battery material on
surface and buried in the ground. '
• Remove and dispose of contaminated soil with total road content of more than 400 ppm.
The following subsections provide information concerning the Burial Unit #1.
The site is located in the vicinity of 1040 S. Oceana Boulevard, Virginia Beach, Virginia (refer
to Figure No. 1). The facility identified as "Oceana Salvage" spans across parts of two
^S^nvironxnent, Inc. f^P. Burial Unit No. 1
facility, Oceana Salvage, Inc (OSI). The facility in the past also occupied, adjacent lands
controlled by the United States Navy (Navy). The SWMU is located on Navy property. The OSI
land contain other waste management units identified by DEQ that are not addressed in this plan.
The entire OSI property encompasses approximately 13 acres. The Burial Unit #1 on Navy
property consists of approximately 0.25 acres. The part of the site on Na-vy property contains no
buildings and is used as woodland and accident protection / buffer zone for Oceana Naval Air
Station. One building is present on the OSI property (refer to Figure No. 2). This building is
used as shop and operations center for the salvage yard. The site is predominantly impaved, but
parts are covered with concrete, stone and various types of gravel fill. Poured concrete slabs
cover a small percentage of the OSI salvage yard. The central part of the site on Na-vy property is
unpaved, and covered with tall grass and bushes. A multi-sttand barbed wire fence separates the
OSI fi'om Navy property. This type of fencing also demarcates the boundaries of an access
corridor consisting a gravel-covered roadway fi-om Oceana Boulevard to OSI, through wooded
land. OSI is constructing a modest-height berm of earthen and fill materials along the shared
boimdary with Navy to control trespassing. The site is serviced by electric utilities, a septic
system, and a general-purpose water supply well. The facility is not regulated by any agency
(e.g., VDEQ) to handle, store, treat, or dispose of soHd or hazardous wastes. The site is
registered with DEQ and has been issued a stormwater discharge pennit. The site has been
issued identifications as VA0002298933 (EPA Facility ID) and VAR000008912 (Handler ID).
The OSI property is operated as auto salvage and recycle yard. The Navy property functions as
an imoccupied buffer zone (i.e., woodlands, wetlands, and open fields) for the airbase. Materials
of concem that are present on-site include buried lead acid batteries, battery casing parts, battery e"
tailings, and lead contaminated soil. These materials were accumulated in the course of
conducting salvaging and battery recycling operations during the early 1990's.
Site historical information was obtained fi'om the following sources provided by OSI, VDEQ and
the Navy:
Map Source: Virginia Beach - Princess Anne, Virginia Quadrangle U.S. Geological Survey 7.5" Minute Series Topographic Maps
ElfA "Espey, Huston &~Associates, Inc. Engineering & Environmental Consultants
11838 Rock Landing Drive SuH6 250 (757)596-8267 Newport News, Virginia 23606.4232 FAX (757) 596-8660
NN973402 AR100095
Engineering & Oceana Salvage inc. ^ ^ ^ n v i r o n m e n t . Inc. ^ P ' B'"''"' ^"'' o- '
Letter Report: "Oceana Salvage, Project Number 93115E.L2", dated October 22, 1993, prepared
by Keith M. Miller of EnviroSolutions, Corp of Virginia Beach, Virginia
• "Operations & Maintenance Plan for Oceana Salvage", estimated date of October 31, 1993,
prepared by Envirosolutions, Corp of Virginia Beach, Virginia
• "Summary of Oceana Salvage Yard Operations", dated December 12, 1993, by
Envirosolutions, Corp of Virginia Beach, Virginia
• Letter Report: "Oceana Salvage, Project Number 93115E.L2", dated December 15, 1993,
prepared by Keith M. Miller of Envirosolutions, Corp of Virginia Beach, Virginia
• "Remedial Action Report and Project Update for Oceana Salvage," dated January 24, 1994,
prepared by Envirosolutions, Corp of Virginia Beach, Virginia
• "Pilot Project Sunmiary- Solidification/Stabilization of Soil - Oceana Salvage Yard", dated
June 6, 1995, by Envirosolutions, Corp of Virginia Beach, Virginia
• "Evaluation of Cleanup to be Conducted, Oceana Salvage Battery Case Site," dated
September 6, 1994, prepared by Envirosolutions, Corp of Virginia Beach, Virginia
• "Remedial Action Report and Project Update for Oceana Salvage," Evaluation of Cleanup to
be Conducted , Oceana Salvage Battery Case Site," dated September 6, 1994, prepared by
Envirosolutions, Corp of Virginia Beach, Virginia
• "Groundwater Monitoring Plan, Oceana Salvage," dated October 24, 1997, prepared by
Espy, Huston & Associates, Inc., of Newport News, Virginia
^pTEnvironment, Inc. '^P- "'•'"' ^"'' ^°- ^
"Soil Sampling Report , Oceana Salvage, (RI-002576)," dated November 24, 1997, prepared
by Espy, Huston & Associates, Inc., of Newport News, Virginia
"Closure Plan, Hazardous Waste Management Unit #1, Oceana Salvage," dated December
24, 1997, prepared by Espy, Huston & Associates, Inc., of Newport News, Virginia
"Closure Plan, Hazardous Waste Management Unit #2, Oceana Salvage," dated December
24, 1997, prepared by Espy, Huston & Associates, Inc., of Newport News, Virginia
"Final Environmental Survey, Property Adjacent to Oceana Salvage Yard, Naval Air Station
Oceana, Virginia Beach, Virginia," dated June 1997, prepared by ABB Environmental
Services of Arlington, Virginia
• "Closure Plan, Hazardous Waste Management Unit #1 and Hazardous Waste Management
Unit #2, Oceana Salvage," dated May 8, 1998, prepared by PBS&J of Newport News,
In general, the site consists of an automobile salvage yard that is operated by OSI, and an
adjacent unoccupied area that is maintained as a buffer zone by Oceana Naval Air Station. The
salvage yard has operated at its current location for approximately 45 years. During part of this
time, OSI inadvertently encroached on Navy property and conducted various types of salvage
operations. Such operations included activities related to the recycling of lead-acid batteries and
the handling of other salvageable materials, primarily automobile parts. Currently OSI conducts
no salvaging operations on Navy property, and no activities related to battery recycling anywhere
on the site. Some waste materials from historic operations, however, remain on Na-vy property.
Although complete details on the battery-handling activities in this unit are not available,
anecdotal evidence suggests that the following activities were conducted at this site:
'^Environment, Inc. P^P- Burial Unit No. 1
(a) Temporarily storing whole batteries prior to disposal at an off-site authorized battery
reclamation facility.
(b) Crushing and temporarily storing "emptied" battery casings (i.e., carcasses after removal of
lead plates).
(c) Disposing of crushed battery casings and breakup tailings by burial and by use as fill
Apparently, a large volume of crushed battery casings was brought to the site in the 1960s and
either buried or used in fill materials. Reportedly, the burial of batteries and battery wastes
'occurred prior to enactment of RCRA Subtitle C. The site was also involved in "battery
cracking", the combined process of breaking open whole batteries, then removing and
temporarily storing the recyclable lead plates. Although the historical record is incomplete on
whether the entire process took place at the site, evidence suggests that at least some steps were
completed there.
The principal area of concem for the proposed remedial action appears to be located
predominantly, possibly entirely, on Navy property; this area is referenced as Burial Unit #1.
Because the boundaries of Burial Unit #1 are not estabHshed (e.g., by existing engineered
features, such as concrete pads and survey markers), and because the Navy-OSI property
boundary was not controlled at the time that operations were conducted in Burial Unit #1, the
proposed remedial action may extend onto OSI property.
Debris^including scrap materials, salvageable auto parts, and battery waste has been accumulated
and buried in this unit. OSI removed a considerable amount, but not all, of these materials and
associated contaminated soils during cleanup actions in 1993-95. Fill may have been added to
the area afterwards, and the area was then re-graded. Consequently, wastes were incorporated
with and/or buried by native soils and fill materials. The resulting mixture of waste-bearing
materials appears to extend into the shallow subsurface. The major contaminant of concem is
lead; a material safety data sheet for lead is provided in Appendix A.
g^nvironment , Inc. P^P' """^ ^"" o-'
The history of regulatory agency's involvement in environmental issues at the OSI site dates
back to 1992. Potential environmental problems at the OSI site were first brought to the attention
of the Virginia Department of Waste Management in January 1992, in the form of a citizen's
complaint (# 002576). This complaint alleges that petroleum product was intentionally dumped
and that battery breaking was conducted at the site. In April 1992, a representative of the
Virginia State Water Control Board (VA SWCB) investigated a small spill of petroleum product
as Pollution Complaint #92-1830. A follow-up inspection in August 1992, foimd a continuance
of potential threats to the state's surface and ground waters related to poor practices for control
of fluids (e.g., pefroleum, antifreeze). The issue of on-site storage of lead-acid batteries and
battery wastes was first verified by a regulatory agency in Jime 1993, when the Virginia
Department of Environmental Quality (VDEQ) conducted a joint inspection with VA SWCB. In
July 1993, VDEQ issued a notification of violation and demanded that operations cease at the
unauthorized battery reclamation facility then referenced as RI002576. VDEQ required either (a)
the removal of all wastes disposed onsite at the un-permitted site and the closure of the site under
Virginia Solid Waste Management Regulations (VSWMR), or (b) the proper permitting of the
material reclamation facility in accordance with applicable VSWMR or Virginia Hazardous
Waste Management Regulations (VHWMR). VDEQ also requested that OSI institute a sampling
and analysis program to determine if operational practices at the site had adversely affected soil
and groundwater. The initial and the follow-up samples, taken in September and October 1993,
established the presence of environmental media impacted by a hazardous constituent. OSI then
was classified as a hazardous waste generator, and was issued an EPA facility identification
(U.S. EPA ID No. VA0002298933) and a RCRA Handler identification (VAR000008912).
VDEQ also requested fiirther soil sampling to delineate the lateral and vertical extent of r-
contamination near the former battery disposal area. Some of the batteries and casing rnaterials
were removed between 1993 and 1995 as part of the clean up effort by OSI.
In the second half of 1993 and first half of 1994, VDEQ also pursued remedies for OSI's
violations of Solid Waste Management Regulations related to the presence/storage on-site of
non-hazardous materials, including waste tires, recyclables (e.g., metals), petroleum
contaminated media, and trash. OSI's consultants evaluated the feasibility o.f conducting material
recovery operations (i.e., a tire recycling) and bioremediation (i.e., treatment of petroleum
contaminated wastes). Ultimately OSI choose removal and proper disposal of these materials off-
site, instead of dealing with them through regulated and permitted processes on-site. Interim
measures (e.g., segregation and compartmentalization of materials, use of absorbent pads) were
instituted to reduce the potential for hazards (e.g., fire) and environmental degradation (e.g.,
release of contaminants into the environment).
Following additional characterization and assessment studies of the former battery disposal area
in the summer of 1994, OSI's consultant proposed that the battery parts (i.e., mostly broken
casings and breakup tailings fill material) be removed from the Navy property, encased with
appropriate materials (e.g., Portland cement), and stored in a repository on OSI's property. Under
this scenario VDEQ required (a) that waste battery materials be segregated from the adjacent
soils and removed from Navy property with as little soil as possible, and (b) that the area of
contamination be delineated during the removal action. Additionally, VDEQ required that soil
moved during the removal action remain on Navy property, and that this disturbed soil be
smoothed out, and not left in mounds. Suitable fill would be added to excavated areas to restore
the land's surface to its original configuration. Pursuant to VDEQ's approval in March 1995,
OSI's consultant completed pilot studies on the solidification-stabilization freatment of waste
battery materials and soil in June 1995. Contingent on application of suitable quality confrol
measures, VDEQ approved use of the proposed technique in August 1995. The removal of
materials was completed in September 1995, and the former battery storage site was graded.
Encasement in the repository was completed sometime in 1996. Apparently, the removal action
was conducted without performing the characterization and confirmation sampling needed to
identify the extent of contamination, and to verify the proper removal of contaminated materials.
A closure report was not submitted. Unauthorized actions taken during the removal-and-
tteatment episode include (a) in September 1995, moving the battery wastes and contaminated
soil to an unauthorized pile, without proper contaiimient, on Navy property, (b) in October 1995,
storing materials at this first unauthorized site without meeting regulatory requirements, (c) in
November 1995, fiirther moving these materials to an unauthorized site on OSI property adjacent
to the repository site, and (d) until burial, storing materials at this second unauthorized site
^^iEllgineering & Oceana Salvage Inc.
^ ^ E n v i r o n m e n t , Inc. P^P P"'''"' ^"'' ^ ° - '
without meeting regulatory requirements. The two sites used for storage of the battery wastes
had become unauthorized waste piles subject to VHWMR. In January 1996, VDEQ issued a
notification of violation and initiated enforcement actions to complete the cleanup activities and
to remedy the improper storage of wastes. Ultimately, the enforcement efforts resulted in the
previous owner of OSI, Mr. Rodney S. "Sonny" Malbon, entering into a Consent Order with
VDEQ in October 1997 to address the cleanup of buried wastes and contaminated soils at the
locations noted above.
In the fall of 1996, Navy initiated an envirormiental survey of the part of its property adjacent to
the OSI salvage yard. The final report of this survey was released in June 1997. Navy's
consultant collected soil samples from various parts of the property, including the original
battery accumulation area (i.e.. Burial Unit #1). Results from these samples indicated the
presence of elevated levels of lead in contaminated soil within the unit. In an effort to confirm
the completion of remediation in the unit, the previous owner of OSI collected soil samples from
three locations in September 1997. Results from these samples, however, also indicated high
levels of lead, and thereby established that remediation of the unit was incomplete. After entering
into the 1997 Consent Order, the previous owner of OSI filed a groundwater-monitoring plan for
the original battery accumulation area in October 1997, and closure plans for the two hazardous
waste management units in December 1997. He also sponsored a wide-ranging investigation of
the unit in November 1997. VDEQ coordinated the investigation that used a backhoe to excavate
more than 30 pits in Burial Unit #1. This work revealed that crushed battery casing and other
solid wastes remained buried in a significant portion of the unit. In conjunction with the
September sampling, the November 1997 investigation also demonstrated that a "previously
remediated" part of the unit (i.e., an area from which most of the crushed battery casing had been
removed) still contained lead-contaminated soil. An updated version of closure plans for the two
hazardous waste management units was filed in May 1998. No closure plan for the original
battery accumulation area was filed; cleanup and closure of the units was not completed in
accordance with the 1997 Consent Order. In September 1999, VDEQ determined that the
previous owner of OSI was personally financially incapable of paying but the corporation was
ip^^F.n crinee.T-in o & Oceana Salvage Inc. ^ ^ t n v i r o n m e n t . Inc. P^P- ""^^ ^"'' ^° '
death of OSI's previous owner in August 2001, OSI indicated its willingness to complete
cleanup and closure of the previously identified units. Consequently, VDEQ drafted a Consent
Order to OSI, and OSI signed said order in May 2002. This order became effective as of July 30,
2002 with tiie signing by VDEQ.
The area referenced as Burial Unit #1 is located on Navy property, adjacent to OSI's property.
Because of incomplete site investigations, the dimensions and characteristics of this unit have not
been adequately established. Preliminary data suggests crushed battery casings are contained
primarily in a contiguous, irregularly shaped area with maximum dimensions of approximately
100 feet by 60 feet (refer to Figure No. 2). Battery casings, battery wastes, and other solid wastes
(e.g., scrapped automobile parts) appear to be mixed with soil and gravel fill materials to a
maximum depth of 2 to 3 feet. A preliminary estimate of the volume of waste stored in the
irregularly shaped area of crushed casing is approximately 150 to 200 cubic yards. Lead-
contaminated soil seems to extend fiirther from the irregularly shaped area. Battery casing debris
and accompanying lead contaminated soil may also be present in an area outside of the
irregularly shaped area. Existing data suggests that the maximum area of contamination may be
as large as 175 feet by 75 feet. A preliminary estimate of the total volume of waste in the entfre
Burial Unit may be as high as 300 to 500 cubic yards.
A systematic investigation of Burial Unit #1 is needed to characterize the…

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