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Hazardous Waste Cleanup: Public Works Service Center in Roanoke City, Roanoke, Virginia

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 Congress amended the Resource Conservation and Recovery Act (RCRA) in November 1984, expanding the Act's cleanup provisions and prompting EPA and its state partners to develop the RCRA Corrective Action Program. The program oversees the investigation and cleanup of nearly 4,000 hazardous waste sites across the country, including many with risks comparable to Superfund sites.

In the summer of 1997, a citizen's report of unpermitted land disposal of hazardous waste triggered an audit by the City's environmental consultant. The audit report indicated the existence of a surface water discharge from an active oil/water separator. The facility was initially issued a Notice of Violation (NOV) by the Virginia Department of Environmental Quality (VDEQ) on March 17, 1998, for the unpermitted treatment and discharge to State Waters; unpermitted storage, treatment, and disposal (TSD) of hazardous waste; and failure to notify the USEPA/VA DEQ of TSD activities.

    Cleanup Status

    A Final RCRA Site Visit Report was issued on May 21, 2008 for the Facility. A Statement of Basis (SOB) was noticed on August 28, 2009. The EPA issued its Final Decision regarding the Facility on September 30, 2009, stating that Corrective Action was Complete with Controls.

    Cleanup Background

    The City reported in 1997 that the oil/water separator discharged to the sanitary sewer system (local Publicly Owned Treatment Works (POTW)). This unit satisfied the definition of a tank under the Virginia Hazardous Waste Management Regulations (VHWMR) and RCRA; the discharge to the POTW qualified the unit and discharge for the wastewater treatment exclusion. The Virginia DEQ subsequently indicated the unit was not considered a hazardous waste unit requiring a permit, and therefore, the unit was allowed to continue to operate in accordance with the aforementioned RCRA exclusion.

    During a period from approximately the late 1970s through 1991, solid and hazardous wastes were disposed at the southern portion of the site. Some waste was placed on the surface of the ground while other waste was buried. The wastes disposed on-site included but were not limited to the following: contaminated soils, wood waste, automobile parts, waste tires, chain link fence, wood pallets, white goods, concrete with rebar, drum tops with bungs, license plate(s), road signs, metal tanks, pipes, pressure vessels, guardrails, 55-gallon drums and other containers. Some of the drums and containers contained solid waste, petroleum waste, and hazardous waste.

    Theses disposal activities were the subject of several Consent Orders (COs) issued by the VDEQ to the City. The first of these COs, signed March 21, 2000, required the facility to develop a Closure Plan for the characterization, removal, and proper disposal of the waste materials as well as the characterization of contaminated soils, proper disposal of contaminated soils, and evaluation and monitoring of the groundwater beneath the disposal areas or "Middle Lot" of the site. These requirements were established through the development of a Closure Plan, Contingent Closure Plan, and a Post-Closure Plan for the Solid Waste Management Units (SWMUs) of concern or areas of disposal. These SWMUs were designated as Hazardous Waste Management Units (HWMUs) Nos. 1 and 2 in the in the COs due to the disposal of hazardous waste in these units.

    In conjunction with the requisite site response activities, considerable excavation had already occurred within the southwestern portions of the site (HWMUs Nos. 1 and 2 or "Middle Lot" in the Consent Order). However, VDEQ was concerned about possible residual soils and/or groundwater contamination that may have been present elsewhere on the southern portion of the site. To address these concerns, the City sought "clean closure" of the entire southern portion of the site under the VHWMR and; therefore, filed revised Site Closure Plans with the VDEQ.

    The site Closure Plans (Rev 3, March, 12, 2001) were formally approved by VDEQ on May 8, 2001; this approval expanded the effective closure or remediation area beyond 2 HWMUs Nos. 1 and 2 or "Middle Lot" to across the remainder of the southern portion of the property.

    VDEQ granted risk-based "clean closure" for unsaturated and saturated (groundwater) soils in HWMU No. 1 on August 1 and 2, 2002; respectively. HWMU No. 2 was granted a risk-based restricted "clean closure" for unsaturated soils in a letter from VDEQ to the City on July 11, 2002, while "clean closure" for saturated soils (groundwater) was granted on August 2, 2002

    Subsequent to the "clean closure" of HWMUs Nos. 1 and 2, the City became aware of significant structural deterioration of the Victory Stadium (circa 1940s) due to age and exposure to recurrent flooding. The City considered several locations for the development of a new stadium-amphitheater complex; the southern portion of the site was deemed most appropriate due to its centralized location and prominent position adjacent to Interstate 581.

    The City began to prepare the southern portion of the site for redevelopment as a new stadium-amphitheater in mid-2003. Several buried drums were identified during excavation activities in this area, as described below. Documentation provided by the City's environmental consultant in 2003 indicated that the disposal of the containers (discovered in 2003) most likely occurred in the mid-to late 1970s.

    A July 2, 2004,  CO issued to the City by the VDEQ documented the nature of the material discovered and its removal. On July 9, 2004, the VDEQ issued a civil penalty of $3,000 to the City. In accordance with the terms of the July 2004 CO, the Order terminated upon receipt of the funds from the City.

    On February 17, 2004, the City Council decided to cease further development of the stadium-amphitheater project, citing the need for newly elected, incoming members of Council to consider the renovation of Victory Stadium as an alternative to the planned new construction at the southern portion of the site. The stadium-amphitheater site excavation and re-grading activities were more than 95% complete at the time this decision was issued. Due to the previous investigation and remediation conducted in this area, the City determined that the southern portion of the site did not warrant further investigation or corrective actions.

    The City's Economic Development Department listed the southern portion of the site as available for redevelopment and, at the time of the May 21, 2008 Final Site Visit Report, the City Council was prepared to negotiate with interested parties.

    In summary, Clean Closure was granted for HWMUs No. 1. HWMU No. 2 was granted a risk-based restricted "clean closure" for unsaturated soils while the unit was granted a "clean closure" for saturated soils (groundwater). The signed and certified "notice of land use limitation" or "deed restriction" associated with the soils for HWMU No. 2, is identified with Tax map No. 3070316.

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    Site Description

    Interactive Map of Public Works Service Center, Roanoke City, Roanoke, VA

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    The Public Works Service Center, for the City of Roanoke, Virginia (PWSC Roanoke) is a vehicle, street, and building maintenance facility, which includes warehousing, refueling, fleet vehicle maintenance, and vehicle washing operations.

    PWSC Roanoke is located at 1802 Courtland Avenue in Roanoke, VA, 24012 (hereinafter referred to as the Facility). Facility construction began in 1974 on an approximately 20-acre parcel of former agricultural land. The facility property subsequently expanded to approximately 36 acres. However, only 17 acres are currently used for the PWSC Roanoke; approximately 15 acres, located at the southern portion of site, are currently for sale by the City. The facility utilizes the public water supply and sanitary sewer systems, which are operated and maintained by the Western Virginia Water Authority. The facility is currently a Small Quantity Generator (SQG) of Hazardous Waste, effective January 2003. The facility was previously a large quantity generator (LQG), in 2001.

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    Contaminants at this Facility

    PWSC Roanoke disposed of solid and hazardous wastes in the southern portion of the Facility. The wastes disposed of at the Facility included contaminated soils, wood waste, automobile parts, waste tires, chain link fence, wood pallets, appliances, concrete with rebar, drum tops with bungs, license plates, road signs, metal tanks, pipes, pressure vessels, guardrails, 55-gallon drums and other containers. Some of the drums and containers contained solid waste, petroleum waste, and hazardous waste.

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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

      Institutional Controls for the site are focused on Hazardous Waste Management Unit #2 (Roanoke Tax Map ID No. 3070316) and include:

      • Residential Land Use Restriction: No Construction and occupancy of residential dwellings, nor Playgrounds for children, nor Childcare centers, and no Public garden spaces.
      • Excavation Restrictions: All soil removed from HWMU No. 2 shall be tested and if found to be a RCRA hazardous waste, shall be treated and disposed of as such. All workers involved in disturbing the soils by digging from HWMU No. 2 shall be properly trained and provided with proper personal protective equipment before they engage in any such activity.

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      Land Reuse Information at this Facility

      The site's future use is yet to be determined.

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      Site Responsiblity 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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