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Hazardous Waste Cleanup: Upaco Adhesives Incorporated (Formerly: J. W. Fergusson and Sons LLC) in Richmond, Virginia

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The Virginia Department of Health (VDH), Division of Solid and Hazardous Waste Management, issued correspondence, dated December 14, 1983, formally requesting the Facility to submit a Resource Conservation and Recovery Act (RCRA) Part B Permit Application for management and storage of hazardous waste at the Facility.  The Facility decided to close the container storage area, and subsequently, this area was Certified Clean Closed in accordance with Virginia's Hazardous Waste Management Regulations on October 9, 1984.

    Cleanup Status

    The former J.W. Fergusson and Sons, Incorporated property is owned and operated by 4107 Castlewood Road, LLC, a SPE for W. F. Holdings, Inc. The property owner executed a covenant on August 28, 2014, that meets the requirements of the Uniform Environmental Covenants Act, VA Code, §10.1-1238, et seq, which imposes institutional controls in the form of land use restrictions.

    The final remedy selected by EPA and Department of Environmental Quality (DEQ) consists of institutional controls and biennial groundwater monitoring. A 30 day public notice period occurred between dates September 26, 2012 and October 26, 2012, which solicited comments on the proposed remedy. No comments were received during the period. Subsequently, EPA issued a Final Decision and Response to Comments, which selected the proposed remedy as the final remedy for the site on November 14, 2012.

    Worthen Industries continues to maintain the covenant with the City of Richmond and continues to conduct groundwater monitoring in accordance with the Groundwater Monitoring Plan, approved by DEQ on June 11, 2012.

    Cleanup Background

    The western most portion of the property, which was occupied by a solvent recovery system, was cleaned up in accordance with the Virginia Voluntary Remediation Program from 2004 to 2008 for which they received a Certificate of Satisfactory Completion and implemented land use controls.

    On September 9, 2009, DEQ completed an evaluation of available information and issued a “YES” determination for the “Current Human Exposures Under Control” Environmental Indicators (EIs) under the Government Performance and Results Act (GPRA).

    On November 19, 2010, DEQ completed an evaluation of available information and issued a “YES” determination for the “Migration of Contaminated Groundwater Under Control” in accordance with the Government Performance and Results Act (GPRA).

    A Groundwater Monitoring Plan was submitted to DEQ on May 31, 2012. DEQ approved the Plan on June 11, 2012.

    A Statement of Basis, which describes the final remedy, was developed on September 24, 2012. A public comment period occurred, which solicited comments on the Statement of Basis between dates September 26 and October 26, 2012. No comments were received

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    Site Description

    Interactive Map of  Upaco Adhesives Incorporated (Formerly: J. W. Fergusson & Sons LLC), Richmond, VA

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    The Facility consists of approximately 3.35 acres and is surrounded by a Dominion Virginia Power storage yard, Castlewood Road, a railroad, and commercial developments. The Site is zoned M-1-Light Industrial and is fenced on all sides to restrict access to the Site. J.W. Fergusson and Sons, Inc. purchased the Facility in 1962 and was a rotogravure printing press operation. Prior to this time, the Site was a vacant lot that had not been used in any prior business. The printing operations began in 1964. The Facility was used for that purpose until September 2006 at which time all operations ceased. All manufacturing equipment, process raw materials, and waste materials were removed and transported off-site for reclamation, re-use, or disposal. In addition, all process material tanks and waste tanks were decontaminated and closed in place or removed.

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    Contaminants at this Facility

    Contaminants in groundwater exceeding drinking water standards include benzene, 1,1-dichloroethylene, arsenic, and chromium.
    No unacceptable risks to human health and the environment from soil are present on-site.
    No impacts to air, surface water, or sediments were identified during the environmental investigations.

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    Institutional and Engineering Controls at this Facility

    Institutional /Engineering Control Summary
    Restrictions or Controls that Address: Yes No
    Groundwater Use
    Residential Use
    Vapor Intrusion
    Capped Area(s)
    Other Engineering Controls
    Other Restrictions

    The following Insitutional Controls for J W Fergusson are enforceable via an Environmental Covenant approved in August 2014:

    • Groundwater beneath the property may not be used from purposes other than environmental testing and monitoring.
    • The property may not be used for residential purposes.
    • Vapor mitigation measures must be utilized in or beneath any new structures intended for occupation within the area of contaminated groundwater unless it is demonstrated that such measures are not necessary to protect human health.
    • All earth moving activities, including excavation, drilling, etc., within Solid Waste Management Unit (SWMU) and Area of Concern (AOC) areas must be done in accordance with an agency approved Materials Management Plan.

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    Land Reuse Information at this Facility

    This property is an industrial use facility.

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    Site Responsibility at this Facility

    RCRA Corrective Action activities at this facility are being conducted under the direction of the Virginia DEQ with assistance from the EPA Region 3.

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