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Hazardous Waste Cleanup: Virginia Department of Transportation Culpeper District Complex, Culpeper, Virginia

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In 1996, the Virginia Department of Environmental Quality (VADEQ) and Virginia Department of Transportation (VDOT) implemented a Compliance Agreement initiating compliance with Resource Conservation and Recovery Act (RCRA) requirements. The Agreement outlined the facility’s regulatory obligations associated with three solid waste management units (SWMUs) including the Sign Shop Vat, Paint Pit, and Hot Vat Stripper Ditch.

Cleanup Status

In 2016, the facility completed activities as part of its final corrective action remedy, which consisted of excavation at SWMU 8, the former salvage metal and debris storage area, and limited excavation at SWMU 9, the former battery storage area, meeting remedial cleanup goals for soil.  The facility continues to conduct post-closure care groundwater monitoring, and is currently developing an environmental covenant, which will meet requirements of the Uniform Environmental Covenants Act and will establish land use controls.  It is anticipated that the covenant will be executed by the end of 2017.  Post-closure groundwater monitoring is currently being implemented and will continue until post-closure care obligations detailed in the facility’s Hazardous Waste Management Permit for Post-Closure Care and Corrective Action have been met.

The facility’s remedy consists of constructing a low permeability cap at the former salvage metal and debris storage area (SWMU eight), limited excavation at the former battery storage area (SWMU nine), continued post-closure care groundwater monitoring, and institutional controls. It is anticipated that the facility will complete construction of its remedy in 2015. Post-closure groundwater monitoring is currently being implemented and will continue throughout the construction process.

Cleanup Background

The facility completed closure of the SWMUs and subsequently was issued a Permit in 2005 to continue post-closure care activities at the Sign Shop Vat and Paint Pit, which included groundwater monitoring. The facility’s Permit also included Corrective Action requirements.

On September 28, 2006, VADEQ completed an evaluation of the available information and data from closure activities and initial investigations and issued a “YES” determination for the “Human Exposures Under Control” Environmental Indicator (EI) under the Government Performance and Results Act (GPRA).

In 2009, the facility completed a RCRA Facility Investigation (RFI) characterizing environmental conditions site-wide. Based on results of the RFI, DEQ approved moving forward with interim measures to complete limited excavations to address contaminants in soil in 2011.

On December 1, 2011, VADEQ completed an evaluation of available information and issued a “YES” determination for the “Migration of Contaminated Groundwater Under Control” EI under the GPRA.

In 2013, the facility in coordination with VADEQ determined to implement interim measures as the facility’s final remedy for Corrective Action. Therefore in 2014, the facility pursued a Permit modification to incorporate the final remedy.

In September 2014, the facility completed a modification to its Permit incorporating its selected final remedy. The Permit modification included a 60 day public comment period, during which no comments were received.

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Site Description

Interactive Map of Virginia Department of Transportation Culpeper District Complex, Culpeper, VA

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The facility occupies 52.8 acres and is located on US Route 15 in the southern portion of the incorporated limits of the Town of Culpeper. Topography varies with the land sloping primarily to the north and east. Since the late 1930’s, various activities have been conducted at the facility including storage and maintenance of VDOT vehicles, storage of materials, used road sign refurbishing, and various administrative/dispatch services.

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Contaminants at this Facility

The primary contaminants of concern in soil and groundwater are 1,2-dichloropropane and chlorinated solvents.

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Institutional and Engineering Controls at this Facility

Anticipated institutional controls at the facility include a groundwater use restriction limiting the use of groundwater beneath the property to purposes necessary for clean-up activities and inspection and maintenance of the cap that will be constructed over SWMU eight. The facility met hazardous waste closure requirements for soil, therefore no controls are necessary for soil.

VDOT is currently developing an environmental covenant, which will meet requirements of the Uniform Environmental Covenants Act and will establish land use controls.  It is anticipated that the covenant will be executed by the end of 2017.  In addition the controls are included in the facility’s permit.  The land use controls include limiting groundwater use beneath the property and requiring vapor intrusion mitigation measures or alternate demonstration that vapor intrusion is not occurring for any newly constructed buildings within 100 feet of groundwater containing chlorinated solvents.  

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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 VADEQ with assistance from the EPA Region 3.

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