UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION III
STATEMENT OF BASIS
Former Proctor and Gamble Site
3600 Elm Ave
Portsmouth, Virginia
EPA ID NO. VAD003174810
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TABLE OF CONTENTS
SECTION PAGE
I. Introduction 1
A. Facility Name 1
B. Proposed Decision 1
C. Importance of Public Input 1
II. Facility Background 2
III. Summary of the Environmental History 2
IV. Evaluation of EPA's Proposed Decision 3
V. Public Participation 3
I. Introduction
A. Facility Name
The United States Environmental Protection Agency (EPA) has prepared this Statement
of Basis (SB) for the Former Proctor and Gamble site (Facility) located in Portsmouth, Virginia.
The Facility is subject to the Corrective Action program under the Solid Waste Disposal
Act, as amended by the Resource Conservation and Recovery Act (RCRA) of 1976, and the
Hazardous and Solid Waste Amendments (HSWA) of 1984, 42 U.S.C. Sections 6901 to 6992k.
The Corrective Action program is designed to ensure that certain facilities subject to RCRA have
investigated and cleaned up any releases of hazardous waste and hazardous constituents that
have occurred at their property.
Information on the Corrective Action program as well as a fact sheet for the Facility can
be found by navigating http://www.epa.gov/reg3wcmd/correctiveaction.htm.
B. Proposed Decision
This SB explains EPA's proposed decision that Corrective Action is complete and no
land use controls are required for the Facility. EPA's proposed decision is based on a review of
EPA and Virginia Department of Environmental Equality (VDEQ) files regarding the
environmental history of the Facility as presented in the Final RCRA Site Report for the Former
Proctor and Gamble Site (Currently ARREFF Terminals) Portsmouth, Virginia, dated January
22, 2009. Based on this review, EPA has concluded that there are no current or unaddressed
releases of hazardous waste or hazardous constituents from the Facility.
C. Importance of Public Input
Before EPA makes a final decision on its proposal for the Facility, the public may
participate in the remedy selection process by reviewing this SB and documents contained in the
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Administrative Record (AR) for the Facility. The AR contains the complete set of reports that
document Facility conditions, including a map of the Facility, in support of EPA's proposed
decision. EPA encourages anyone interested to review the AR. The AR is available for public
review at the EPA Region III office. The address for the EPA Region III office is provided in
Section V, below.
EPA will address all significant comments received during the public comment period. If
EPA determines that new information or public comments warrant a modification to the
proposed decision, EPA will modify the proposed decision or select other alternatives based on
such new information and/or public comments. EPA will approve its final decision in a
document entitled the Final Decision and Response to Comments (FDRTC).
II. Facility Background
The 21-acre Facility is located at 3600 Elm Ave. in Portsmouth, Virginia. The Facility is
surrounded by the Portsmouth Naval Reservation. The Facility utilized an 11,000 square
foot, multi-story plant building to manufacture and package peanut butter beginning in 1931.
The site is currently occupied by ARREFF Terminals Inc., with a number of shipping
containers present on the site. ARREFF Terminals provides transloading / warehousing for
the Virginia Port Authority.
III. Summary of Environmental History
The P&G facility operated a hazardous waste management unit (HWMU) container
storage area with a capacity of 550 gallons from November 19, 1980 to June 30, 1993. This
HWMU container storage area was identified by P&G in a RCRA Part A Permit Application,
dated November 17, 1980, and a SWMU response letter, dated May 30, 1986. The HWMU
operated under Interim Status under the RCRA Regulations from November 19, 1980, until
the HWMU achieved clean closure approval in June 1989. P& G correspondence, dated
July 7, 1988, documented that the facility intended to close the HWMU and did not intend to
seek an operating Permit for the HWMU.
A Closure Plan was submitted for the HWMU by P&G, dated July 19, 1988. On August 18,
1988, the public notice was published for the Closure Plan. On October 6, 1988, the Virginia
Department of Waste Management (VDWM), predecessor to the VDEQ, provided P&G with
comments on the initially submitted Closure Plan. P&G submitted the revised Closure Plan,
dated October 14, 1988. The VDWM approved the revised Closure Plan on October 27,
1988. The VDWM received the closure certification according to the Closure Plan on March
28, 1989, and the facility requested the closure verification inspection by the VDWM. The
Closure verification inspection by the VDWM staff occurred on June 2, 1989. Interim Status
was officially terminated for the HWMU by the VDWM on June 19, 1989.
Apparently, the same HWMU container storage area was operated under both a large
quantity generator (LQG) and a small quantity generator (SQG) status under 40 CFR §
262.34, until the P&G facility closed. P&G deactivated the entire facility on May 22, 1995.
The container storage area mat and fence were moved as one unit by ARREFF from its original
location on the west side of the building to the southwest corner of the site and is not currently
used by the facility.
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A RCRA Corrective Action Facility Assessment including file reviews, interviews with
property owners, and two site visits conducted by EPA and VDEQ in November 2007, and
November 2008, evaluated a number of SWMUs and AOCs. No evidence of releases was
obtained during the investigative process either from historical documentation or from visual
observations. Documentation of the findings of the facility assessment is provided in the
Final RCRA Site Report, Former Proctor and Gamble Site (CurrentlyARREFF Terminals),
3600 Elm Avenue, Portsmouth, Virginia, 23704, EPA ID No. VAD003174810, by U.S.
Army Corps of Engineers, dated January 22, 2009.
Based on the information gathered it does not appear that the facility property has been
contaminated by releases from past waste management or manufacturing activities that
would pose a threat to human health or the environment. Therefore, Corrective Action
Complete Without Controls is recommended for this facility under the RCRA Corrective
Action Program.
IV. Evaluation of EPA's Proposed Decision
EPA has determined that its proposed decision for the Facility is protective of human
health and the environment and that no further corrective action or controls are necessary at this
time.
V. Public Participation
Interested persons are invited to comment on EPA's proposed decision. The public
comment period will last thirty (30) calendar days from the date that notice is published in a
local newspaper. Comments may be submitted by mail, fax, e-mail, or phone to Mr. Bill
Wentworth at the address listed below.
A public meeting will be held upon request. Requests for a public meeting should be
made to Mr. Bill Wentworth at the address listed below. A meeting will not be scheduled unless
one is requested.
The Administrative Record contains all the information considered by EPA for the
proposed decision at this Facility. The Administrative Record is available at the following
location:
U.S. EPA Region III
1650 Arch Street
Philadelphia, PA 19103
Contact: Mr. Bill Wentworth (3LC20)
Phone: (215)814-3184
Fax: (215)814-3113
Email: wentworth.william@epa.gov
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