Mid-Atlantic Corrective Action

Griffin Pipe Products Company

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• Status
• Background
• Contaminants and Risks
• Institutional Controls
• Documents and Reports
• Photos, Maps and Diagrams
• Reuse Information
• Questions

EPA ID:VAD065417008
Location:
10 Adams Street
Lynchburg, VA 24504
Property Area 11 acres
Congressional District: 6
Other Names:
Last Updated: December 2011

Contacts

Bulletin Board

Status

The Virginia Department of Environmental Quality (DEQ) is the lead agency for oversight of Resource Conservation and Recovery Act (RCRA) Corrective Action (CA) work at the Griffin Pipe Products Company (GPP) facility. The CA investigations and any necessary clean up activities at the facility are being implemented in accordance with the conditions and requirements of the Hazardous Waste Management Permit (Permit) issued to the facility.

The DEQ issued the GPP facility a Permit for the storage and treatment of hazardous waste in May 1997. From the manufacturing process of the ductile iron pipe, the facility had the potential to generate two hazardous wastes on a continuous basis that were discharged to the Harsell Cupola Baghouse; (1) the cupola dust emissions generated in the iron melting operation, and (2) the dust emissions from the molten iron desulphurization and magnesium treatment process.


In 2002, the DEQ allowed the GPP facility to amend their Permit to allow for in-duct treatment of the dust. The in-duct treatment rendered the dust non-hazardous at the point of generation. However, because DEQ allowed the GPP facility to maintain their Permit in the event the dust tested hazardous for lead or cadmium, all dust generated was assumed to be hazardous during the closure project.


The GPP facility no longer treats or stores hazardous waste and in April 2007, the hazardous waste treatment and storage units at the facility were certified clean closed by the DEQ. The GPP facility is required to maintain a permit while completing CA requirements under the Virginia Hazardous Waste Management Regulations (VHWMR) and RCRA. Therefore, on November 30, 2007, the DEQ issued a Hazardous Waste Management Permit for Corrective Action to the facility. The Permit for CA will remain in effect until November 30, 2017.


On December 4, 2007, the DEQ visited the GPP facility to meet with the GPP staff, their consultant, and to perform a CA site visit. The purpose of both the meeting and site visit was to discuss and identify all of the hazardous waste management units (HWMUs), solid waste management units (SWMUs), and areas of concern (AOCs) located on-site for the development of the RCRA Facility Investigation (RFI) Work Plan. GPP submitted a comprehensive SWMU/AOC list on February 19, 2008. It was approved by the DEQ and incorporated into the GPP Permit as a Class I Permit Modification on February 22, 2008.


The Phase I RFI Work Plan was submitted to the DEQ on May 5, 2008. The DEQ issued the facility technical review comments on the Phase I RFI Work Plan in a letter dated, August 8, 2008. The facility provided the DEQ with a response to the technical review comments in letters dated October 27, 2008, and November 21, 2008, respectively.


On December 10, 2008, the DEQ had a conference call with GPP personnel and their consultant, Groundwater & Environmental Services, Inc, to further discuss the facility's response to the DEQ's technical review comments. Based on this discussion, the DEQ, in a letter dated December 12, 2008, requested that GPP submit a revised response to comments document including a thorough response to each DEQ comment, in addition to revised draft sections, tables, and figures of the Phase I RFI Work Plan.


On March 17, 2009 the DEQ received GPP's Revised Response to Comments document. The DEQ reviewed this document and on June 4, 2009 requested, via electronic mail, supplemental information from GPP to assist the DEQ in completing its review.
On August 14, 2009, the DEQ received a Revised Phase I RFI Work Plan (Revised RFI Work


Plan), dated August 2009, which incorporated into it the DEQ comments dated December 12, 2008 and June 4, 2009. The DEQ approved the Revised RFI Work Plan on September 1, 2009. GPP is currently scheduling their field investigation activities for January and/or February 2010.

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Background

The GPP facility is located on approximately 11-acres in the City of Lynchburg on Adams Street along the south bank of the James River Upper Basin, just west of the John Lynch Memorial Bridge. GPP is a manufacturer of ductile pipe. Operations at the facility can be conducted twenty-four (24) hours per day, seven (7) days per week, and fifty-two (52) weeks per year. The facility manufacturers ductile iron pipe by melting scrap iron in a cupola using coke as fuel and treats the molten iron with additives to make ductile iron.


The GPP facility no longer treats or stores hazardous waste. The hazardous waste treatment and storage units were certified "clean closed" in April 2007 by the DEQ. The facility is required to maintain a permit while completing corrective action requirements under the VHWMR and RCRA.


On November 30, 2007, the DEQ issued the GPP facility a Permit for CA. The Permit for CA will remain in effect until November 30, 2017. The GPP facility is currently implementing the requirements set forth in their Permit for CA.

To date the following RCRA CA milestones have been completed at this facility:
- On November 30, 2007, the DEQ issued the GPP facility a Permit for CA. The Permit for CA will remain in effect until November 30, 2017.
- DEQ and GPP staff met on December 4, 2007, at the GPP facility to discuss and identify all of the HWMUs, SWMUs and AOCs located on-site for the development of the RFI Work Plan.
- GPP submitted a comprehensive SWMU/AOC list on February 19, 2008. It was approved by the DEQ and incorporated into the GPP Permit as a Class I Permit Modification on February 22, 2008.
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The Phase I RFI Work Plan was submitted to the DEQ on May 5, 2008. The DEQ issued the facility technical review comments on the Phase I RFI Work Plan in a letter dated, August 8, 2008. The facility provided the DEQ with a response to the technical review comments in letters dated October 27, 2008, and November 21, 2008, respectively. On December 10, 2008, the Department had a conference call with facility representatives to


On March 17, 2009 the DEQ received GPP's Revised Response to Comments document. The DEQ reviewed this document and on June 4, 2009 requested, via electronic mail, supplemental information from GPP to assist the DEQ in completing its review.
-
On August 14, 2009, the DEQ received the Revised RFI Work Plan, dated August 2009, which incorporated into it the DEQ comments dated December 12, 2008 and June 3, 2009. The DEQ approved the Revised RFI Work Plan on September 1, 2009. GPP is currently scheduling their field investigation activities for January and/or February 2010.

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Contaminants and Risks

• The primary contaminants of concern (COCs) based on past and present operations are lead (D008), cadmium (D006), Volatile Organic Compounds (VOCs) and Semi-Volatile Organic Compounds (SVOCs).

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Institutional Controls

The current Permit for CA was issued by the DEQ and became effective on November 30, 2007, and shall remain in effect until November 30, 2017. The Permit contains site-wide CA requirements under the VHWMR and RCRA.

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