Hazardous Waste Cleanup: Sims Metal in Suffolk, Virginia

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Cleanup Status
Site Description
Contaminants at this Facility
Institutional/Engineer Controls
Land Reuse
Site Responsibility

Historical and current operations at the Site have resulted in releases of hazardous wastes and/or hazardous constituents to the soil and groundwater. To address such releases, Sims Metal Management (SMM) entered into a Facility Lead Agreement (FLA) with EPA Region 3 in August 2006. The FLA encourages Resource Conservation and Recovery Act (RCRA) Corrective Action facilities to take the lead in identifying, investigating and remediating any site related contamination using a generic, non-enforceable, agreement which includes the same requirements, and relies on the same scope of work and policy as a permit or an order. Participating facilities invited into the program generally meet a number of the following factors: good enforcement record, state approval, financial and technical capability, a proactive approach to clean up, and a willingness to work with the Agency.

Cleanup Status

EPA’s review of available information indicates that there are no unaddressed releases of hazardous waste or hazardous constituents from the Facility. On June 27, 2013, announced its proposed remedy under the RCRA Corrective Action program for the Sims Metal Management (SMM) facility located at 1177 Hoiser Road in Suffolk, Virginia (Site). Future use of the Site is anticipated to be for industrial and/or commercial purposes. EPA’s proposed remedy, as documented in the June 4, 2013, Statement of Basis, was published in The Suffolk News-Herald newspaper on June 27, 2013 and posted on the EPA Region 3 Corrective Action website for public comment. The thirty (30) day public comment period ended on July 26, 2013. EPA received no comments on the proposed decision.

On August 14, 2013, EPA issued its final remedy for the Site in a document entitled the Final Decision and Response to Comments (Final Decision). Because some contaminants remain in the soil and groundwater at the Facility at levels which exceed residential use, EPA selected as its final remedy monitored natural attenuation for groundwater, in addition to land and groundwater use restrictions for the Site. The final remedy will be implemented through an Environmental Covenant entered into pursuant to the Virginia Uniform Environmental Covenants Act (UECA), § 10.1-1238, et seq. of the Code of Virginia which was recorded with the deed of the property on November 18, 2013.

EPA sets national goals to measure progress toward meeting the nation’s major environmental goals. For Corrective Action, EPA evaluates two key environmental indicators for each facility: (1) current human exposures under control and (2) migration of contaminated groundwater under control. Based on a review of all available information for the Site, EPA determined that the Facility met both of the EI indicators on September 1, 2010.

Cleanup Background

In December 2006, SMM submitted a Phase I RCRA Facility Investigation Work Plan (RFI Work Plan) to the EPA. The RFI Work Plan was developed for surface and subsurface soil and groundwater sampling at the Facility. Samples were analyzed for volatile and semi-volatile organic compounds, petroleum hydrocarbons (soil and sediment), RCRA metals (8), and polychlorinated biphenyls (PCBs). Results showed arsenic, chromium and lead contamination in both soils and groundwater at the site. However, based on EPA Region 3’s Risk Screening Levels (RSLs), the contamination at the site is acceptable for industrial use.

Sims followed up the RFI Work Plan with a Groundwater Monitoring Report submitted to the EPA in March 2010, which reported the results of groundwater sampling from monitoring wells W-3R, W-9R and W-11. Arsenic, chromium and lead were found to be above EPA’s Safe Drinking Water Maximum Contaminant Levels (MCLs). In addition to sampling monitoring wells W-3R, W-9R and W-11, samples were also collected from the drums of investigation derived waste (IDW), which consisted of development and purged groundwater from the monitoring wells. Petroleum related contaminants, such as benzene, ethylbenzene, xylenes, and methyl tert-butyl ether (MTBE), were detected in the samples collected from the IDW.

To determine whether the petroleum related constituents observed in the IDW are present in the groundwater and to confirm that the concentrations of arsenic, chromium and lead are consistent with previous sampling events, SMM conducted another round of groundwater sampling at monitoring wells W-3R, W-9R and W-11. The results of such sampling were presented to EPA in a Groundwater Monitoring Report submitted in February 2011. Arsenic, at a concentration slightly above the MCL, was the only metal detected in well W-3R. MTBE was also detected in well W-3R at a concentration significantly lower than the EPA Region 3 RSL. Sample results for well W-9R exceeded the MCL for benzene and arsenic and exceeded EPA Region 3’s Risk Screening Levels (RSLs) for ethylbenzne and MTBE. Arsenic was also detected in well W-9R at a concentration above the MCL. Well W-11 did not exhibit any detection of metals or volatile organic compounds. The presence of petroleum related constituents in the 2010 round of sampling for W-9R (but not groundwater sampling results prior to 2005), it was noted in the February 2011, Report as possibly the result of a minor spill or release of petroleum after 2005.

Additional sampling was conducted in September 2011, and August 2012, to monitor potential movement or degradation of the contaminant plume. Based on the results of these sampling events, EPA has determined that the plume is stable and the concentration of contaminants is decreasing. In addition, SMM implemented new containment measures and spill prevention practices in September 2010, designed to reduce the risk of such spills or releases, especially in the area of scrap automobile processing and flattening within the Car Process Building.

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Site Description

Interactive Map of Sims Metal, Suffolk, VA

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The subject ten-acre property is zoned as M-2 (heavy industrial) and located approximately 2 miles south of downtown Suffolk, Virginia. The first industrial use of the site was by Old Dominion Wood Preservers (Old Dominion), who occupied the site from January 1984 up to June 1990. Old Dominion treated wood with a chromated copper arsenate (CCA) solution and/or with a fire retardant solution of ammonium phosphate. Sierra Recycling, Inc. (dba Virginia Soils Reclamation, Inc.) acquired the site in 1993 and biologically treated petroleum contaminated soils until the mid-1990’s. Reportedly, a rubber shredding operation leased a portion of the site in the mid-1990’s; however, documentation to confirm such operations is not available. SMM purchased the Site in March 2006 and currently operates a scrap and iron metals recycling facility which includes the draining and flattening of scrap automobile to provide for their efficient shipment to other locations for further processing.

Historical and current operations at the Site have resulted in releases of hazardous wastes and/or hazardous constituents to the soil and groundwater. To address such releases, SMM entered into a Facility Lead Agreement (FLA) with EPA Region 3 in August 2006. The FLA encourages RCRA Corrective Action facilities to take the lead in identifying, investigating and remediating any site related contamination using a generic, non-enforceable, agreement which includes the same requirements, and relies on the same scope of work and policy as a permit or an order. Participating facilities invited into the program generally meet a number of the following factors: good enforcement record, state approval, financial and technical capability, a proactive approach to clean up, and a willingness to work with the Agency.

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Contaminants at this Facility

Primary contaminants of concern are metals, specifically arsenic, which is present in groundwater beneath the Site and detected at levels above EPA's Safe Drinking Water Maximum Contaminant Levels (MCLs) from monitoring wells W-3R, W-9R and W-11. In addition, petroleum related constituents (benzene, ethylbenzene, xylenes, and/or MTBE) have been detected in monitoring wells W-3R and W-9R.

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Institutional and Engineering Controls at this Facility

EPA’s final remedy required the establishment of land and groundwater use restrictions for the Site which will be implemented through an Environmental Covenant entered into pursuant to the Virginia Uniform Environmental Covenants Act (UECA), § 10.1-1238, et seq. of the Code of Virginia. The UECA Environmental Covenant for the Site was recorded with the deed of the property on November 18, 2013.

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

Institutional Controls established on November 18, 2013:

With the exception of the existing non-potable well located onsite (DW-1) that is constructed to a depth of approximately 600 feet below grade, groundwater at the Property shall not be used for any purpose other than the monitoring activities required by Virginia Department of Environmental Quality (VADEQ) and/or EPA, unless it is demonstrated to EPA, in consultation with VADEQ, that such use will not pose a threat to human health or the environment or adversely affect or interfere with the final remedy and EPA, in consultation with VADEQ, provides prior written approval for such use;
The Property shall not be used for residential, agricultural or recreational purposes unless it is demonstrated to EPA, in consultation with VADEQ, that such use will not pose a threat to human health or the environment or adversely affect or interfere with the final remedy, and EPA, in consultation with VADEQ, provides prior written approval for such use;
All earth moving activities including excavation, drilling and construction activities that would result in direct exposure to soil, in the areas at the Property where any contaminants remain in soils above EPA's Screening levels for non-residential use (as shown in Exhibit 3, attached hereto and incorporated herein by reference) shall be prohibited unless it is demonstrated to EPA, in consultation with VADEQ, that such activity will not pose a threat to human health or the environment or adversely affect or interfere with the final remedy, and EPA, in consultation with V ADEQ, provides prior written approval for such use;
No new wells will be installed on the Property unless it is demonstrated to EPA, in consultation with VADEQ, that such wells are necessary to implement the final remedy and EPA provides prior written approval to install such wells.
The property owners will continue the groundwater monitoring program already in place until groundwater clean-up standards are met through monitored natural attenuation.

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