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Hazardous Waste Cleanup: Sterling Hardware LLC in Abingdon, Virginia

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By Letter of Commitment dated August 21, 2002, Sterling notified the United States Environmental Protection Agency (EPA) and Virginia Department of Environmental Quality (VDEQ) of its willingness to participate in the EPA's Facility Lead Program to address the necessary Resource Conservation and Recovery Act (RCRA) Corrective Action (CA) work at the facility. 

    Cleanup Status

    A Corrective Action Determination of “Complete with Controls” was issued on May 11, 2010. The final remedy states that no further actions to clean up soil or groundwater are necessary, given current and reasonably anticipated future land use. However, the final remedy also requires the facility to maintain institutional and engineering controls because waste with hazardous substances will remain in four closed surface impoundments. On October 11, 2013, a fully executed Uniform Environmental Covenants Act (UECA) agreement was recorded in the Washington County, Virginia Circuit Court.  This document perpetuates activity and use limitations of the property. Therefore, the requirements of the post closure care plan were determined to be satisfied and the 2011 Order was terminated on March 5, 2014.  A long term inspection was conducted in July 2016, and found no outstanding issues with the maintenance of the final remedy.

    Cleanup Background

    The Sterling Casket facility is located in Abingdon, Washington County, Virginia, near the intersection of State Routes 704 and 879.  The site comprises approximately 4.9 acres of land and is improved with a process building, paved parking lot, and landscaped areas. The site is bound to the north by Tri-Tube Industries, to the east by State Route 704, to the south by State Route 879, and to the west by open, undeveloped land.

    The site has been owned and operated by Sterling Casket since 1963. Sterling Casket uses the site to manufacture casket hardware. On-site activities include molding, casting, electroplating, painting, and assembly of casket hardware parts. Although lead casting was performed in the past, only zinc casting is currently performed.

    Sterling Casket currently performs nickel and cyanide-based (copper and bronze) plating. The process building houses a machine shop, a casket hardware molding room, a shipping warehouse, a painting room, a flammable chemical storage room, several hardware assembly areas, and an electroplating process area.

    Several hazardous waste surface impoundments at the facility were closed with wastes in place on May 31, 1989.  The DEQ and Sterling Casket entered into a CO for post-closure care of the closed impoundments on September 30, 1994.  A Deed Notice is in place identifying the location of the hazardous waste surface impoundments closed with waste in place as a landfill.

    By Letter of Commitment dated August 21, 2002, Sterling notified the United States Environmental Protection Agency (EPA) and DEQ of its willingness to participate in the EPA’s Facility Lead Program to address the necessary RCRA Corrective Action (CA) work at the facility.  On September 9, 2004 the Groundwater and Human Health Environmental Indicators were given a “yes” determination by the DEQ.

    In a March 19, 2009 letter the DEQ: 1) concurred that Sterling Casket had satisfied the recommend clean-up action in the area around the Sump, 2) accepted the Phase I RCRA Facility Investigation (RFI) Report, and 3) concurred that the information submitted by Sterling Casket to the DEQ meets the criteria and standards of the Corrective Action Facility Lead Program, 4) advised that future land use on the facility property will still be restricted to industrial use only, and 5) advised that groundwater sampling must continue for at least three additional events to confirm the levels of hazardous constituents in groundwater.  

    In October 2009, EPA and DEQ prepared a Statement of Basis (SB) and Administrative Record (AR) proposing a Final Remedy for Sterling Casket.  The Final Remedy proposed is that no further actions to remediate soil, groundwater, or indoor air contamination are necessary to protect human health and the environment given current and reasonably anticipated future land use. The proposed final remedy would require Sterling Casket to develop and maintain certain property restrictions known as Institutional Controls (IC’s).  The IC’s at Sterling Casket would be put in place to restrict use of the facility soil and groundwater to prevent human exposure to contaminants while contaminants remain in place.  Sterling already has a Deed Notice with the Washington County Circuit Court Clerk’s Office, Deed Book 844, Page 767-768, identifying the location of the hazardous waste surface impoundments closed with waste in place as a landfill.  The Deed Notice will be incorporated into the Declaration of Restrictive Covenants to ensure that the cap will not be disturbed. 

    These controls will provide assurance that the land use, as currently known and anticipated, does not change without additional investigation or work and prior notification to the EPA. EPA’s proposed decision represents “Corrective Action Complete with Controls” as described in EPA’s “Final Guidance on Completion of Corrective Action Activities at RCRA Facilities”, (68 FR 8757, February 25, 2003).

    The Statement of Basis was public noticed in the Bristol Herald Courier on April 6, 2010.  The public comment period lasted thirty (30) days ending on May 6, 2010.  No comments were received during the public comment period therefore EPA issued a Corrective Action Determination of “Complete with Controls” on May 11, 2010.

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    Site Description

    Interactive Map of Sterling Hardware LLC, Abingdon, VA

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    The Sterling Casket facility is located in Abingdon, Washington County, Virginia, near the intersection of State Routes 704 and 879. The site comprises approximately 4.9 acres of land and is improved with a process building, paved parking lot, and landscaped areas. The site is bound to the north by Tri-Tube Industries, to the east by State Route 704, to the south by State Route 879, and to the west by open, undeveloped land. The site has been owned and operated by Sterling Casket since 1963. Sterling Casket uses the site to manufacture casket hardware. On-site activities include molding, casting, electroplating, painting, and assembly of casket hardware parts. Although lead casting was performed in the past, only zinc casting is currently performed.

    Sterling Casket currently performs nickel and cyanide-based (copper and bronze) plating. The process building houses a machine shop, a casket hardware molding room, a shipping warehouse, a painting room, a flammable chemical storage room, several hardware assembly areas, and an electroplating process area.

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    Contaminants at this Facility

    The primary contaminants of concern in the soil and groundwater were arsenic, cadmium, chromium, copper, lead, and, nickel.

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    Institutional and Engineering Controls at this Facility

    Institutional Controls include:

    • The cap on the hazardous waste surface impoundment area (landfill) shall not be disturbed.
    • Groundwater will continued to be monitored for contaminants.
    • No Construction shall take place at the facility without VDEQ/ EPA approval and residential dwellings/playgrounds are prohibited.
    • All excavation of soil be done by trained personnel , tested for hazardous waste, and if found: disposed according to RCRA hazardous waste rules.

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    Land Reuse Information at this Facility

    The facility is in continued use.

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    Site Responsibility at this Facility

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

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