VIA Electronic Mail
Jungho Ahn
Project Manager
Environmental Review, Inc.
P.O. Box 2756
Berkeley, CA 94702

Re: Approval of Class 2 Permit Modification, Bohler-Uddeholm Corporation, South Boston, Virginia
EPA ID No. VAD089022685

Dear Jungho Ahn,

The purpose of this letter is to notify you, a person on the facility’s list, of the Department of Environmental Quality’s (DEQ’s) decision to issue a Class 2 Permit Modification to the Bohler-Uddeholm Corporation facility’s Hazardous Waste Permit. Pursuant to Chapter 14, Section 10.1-1427, Code of Virginia (1950), as amended and regulations promulgated thereunder by the Department of Environmental Quality (hereinafter referred to as the Department), a Class 2 Permit Modification is issued to the Bohler-Uddeholm Corporation (hereinafter referred to as the Permit and the Permittees), for the Corrective Action of one hazardous waste management unit and one solid waste management unit. The facility is located in South Boston in Halifax County at 2306 Eastover Drive, South Boston, Virginia 24592. Final remedies, including the selected land use restrictions and institutional controls for the units are included in Section C of Module II of the final Corrective Action Permit. This final permit decision is in accordance with the Virginia Hazardous Waste Management Regulations (VHWMR), 9 VAC 20-60, 9 VAC-20-60-270, which incorporates 40 CFR Part 270 by reference.

A Public Notice of a 60-day comment period addressing the Class 2 Modification was published in the News and Record on June 29, 2017. A public meeting to disseminate information and exchange ideas relevant to the draft permit was held on July 23, 2017. The DEQ received no comments expressing the opinion that the Class 2 Modification issuance should be denied. Therefore, in accordance with 40 CFR § 270.42(b)(6), the Director of the DEQ has made a final permit decision to issue the Class 2 Modification. This final permit decision is based upon the supporting rationale provided in the enclosed "Comment Response Summary," dated August 31, 2017, for the Bohler-Uddeholm Corporation, South Boston facility which is in accordance with 40 CFR § 270.42(b)(6)(vi). The "Response to Comments Document" specifies which provisions of the Class 2 Modification, if any, have been changed in the final permit decision, and the reasons for the change. In addition, this document describes and responds to all significant comments on the Class 2 Modification which were raised during the public comment period. Please note that this final permit decision became effective on September 8, 2017 and may be appealed in accordance with the Administrative Process Act, Chapter 40, § 2.2-4000 et seq., of Title 2.2 of the Code of Virginia. All federal regulatory references to the appeals process or the EPA Environmental Appeals Board, such as in 40 CFR § 124.19, shall be construed to mean the administrative processes and appeals processes as specified by Virginia's Administrative Process Act. As provided by Rule 2A:2 of the Supreme Court of Virginia, an appeal may also be initiated by filing a notice of appeal within 30 days from the date of service of this decision to: David K. Paylor, Director, Department of Environmental Quality
629 East Main Street, P.O. Box 1105, Richmond, VA 23218 In the event that this decision is served to you by mail, the date of service will be calculated as three days after the postmark date. Please refer to Part 2A of the Rules of the Supreme Court of Virginia, which describes the required content of the Notice of Appeal, including specifications of the Circuit Court to which the appeal is taken, and additional requirements concerning appeals from decisions of administrative agencies. If you have any further questions concerning the information provided in this letter, please contact me at (804) 698-4467 or by e-mail at This email address is being protected from spambots. You need JavaScript enabled to view it..

Sincerely,

Ashby R. Scott, Hazardous Waste Permit Writer, Office of Financial Responsibility and Waste Programs
Attachments: Enclosure 1: Response to Comments Document, Enclosure 2 – Modified Corrective Action Permit for Bohler-Uddeholm Corporation, South Boston, Virginia
cc: Beth Lohman– DEQ, BRRO, Leslie Romanchik – DEQ, CO, CO File

Comment 1,

From Jungho Ahn - Environmental Review, Inc. – Page 4: For the RCRA Facility Investigation, the current placement of soil borings excluded former locations that are assessed in 2006. In order to investigate the change of soil contamination over time, shouldn’t the former locations also be analyzed?
Response: The data collected from both the 2006 initial assessment and the 2010 RFI determined the extent of the soil contamination including the range of concentrations and the vertical and horizontal limits. Since the proposed remedy consists of engineered and institutional controls which are considered protective of human health and the environment, there is no need to determine the change of soil contamination over time.

Comment 2, From Jungho Ahn - Environmental Review, Inc. – Page 4: To assess the effectiveness of the institutional controls (capping) and possible impact on groundwater, it is recommended that on-site groundwater monitoring wells be sampled and samples analyzed for constituents of possible concern. Sampling should be conducted quarterly for the first 2 years and annually, thereafter. In addition, surface water sampling should be conducted down gradient from the affected area during major storm events in the first year to assess whether soil contamination is migrating from the site.
Response: Existing data shows the on-site groundwater and down gradient surface water is not impacted above applicable health based screening criteria. The proposed remedy (capping) is expected to further limit stormwater infiltration into the soil and prevent migration of the contaminants, therefore additional groundwater and surface water monitoring is not warranted.

Comment 3, From Jungho Ahn - Environmental Review, Inc. – The investigations in the focus area addressed soil and groundwater. As the contaminated soil may affect the adjacent vegetation including trees, would it be appropriate to observe the vegetation for sign of stress related to contamination? Is uptake of contaminated groundwater by vegetation and trees a consern?
Response: Vegetation did not appear to be impacted by the soil contamination based on visual observations by VDEQ personnel during site visits to the facility.

Comment 4, From Jungho Ahn - Environmental Review, Inc. – Page 6: regarding point 3, as the adjacent vegetation can be affected by contaminated soil, would it be appropriate to observe the adjacent vegetation including trees for signs of stress or mobilization of contaminants?
Response: See response to comment #3 above.

Ashby Scott
DEQ Office of Financial Responsibility and Waste Programs
629 East Main St.
Richmond, VA 23219
E-mail: This email address is being protected from spambots. You need JavaScript enabled to view it.

Comments Provided to the Virginia Department of Environmental Quality, Hazardous Waste Management for the Bohler-Unddeholm facility, South Boston 8-15-17

Dear Ashby Scott,

Environmental Review, Inc. has reviewed the document and has the following comments:

1.       Page 4: for the Resource Conservation and Recovery Act (RCRA) Facility Investigation, the current placement of soil borings excluded former locations that are assessed in 2006. In order to investigate the change of soil contamination over time, shouldn’t the former locations also be analyzed?

2.       Page 4: to assess the effectiveness of the institutional controls (capping) and possible impact on groundwater, it is recommended that on-site groundwater monitoring wells be sampled and samples analyzed for constituents of possible concern. Sampling should be conducted quarterly for the first 2 years and annually, thereafter. In addition, surface water sampling should be conducted down gradient from the affected area during major storm events in the first year to assess whether soil contamination is migrating from the site.

3.       The investigations in the focus area addressed soil and groundwater. As the contaminated soil may affect the adjacent vegetation including trees, would it be appropriate to observe the vegetation for a sign of stress related to contamination? Is uptake of contaminated groundwater by vegetation and trees a concern?

4.       Page 6: regarding point 3, as the adjacent vegetation can be affected by contaminated soil, would it be appropriate to observe the adjacent vegetation including trees for signs of stress or mobilization of contaminants?

 Sincerely yours, Jungho Ahn - Project Manager,
ENVIRONMENTAL REVIEW, INC., 
P.O. Box 2756, Berkeley, CA 94702