United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R04-91/084
September 1991
&EPA Superfund
Record of Decision:
Golden Strip Septic Tank, SC
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50272 101
.
REPORT DOCUMENTA T10N 1'; REPORT NO. I ~ 3. Aeciplenl'. Acc888Ian No.
PAGE EPA/ROD/R04-9L/084
4. TIlle IInd SubtIle 5. Report D8ta
SUPERFUND RECORD OF DECISION 09112/91
Golden Strip Septic Tank, SC 6.
First Remedial Action - Final
7. Author(.) 8. Performing Organlz81lon RepI. No.
8. Perfonning Orgainlz81lon Nama IInd Add,... 10. ProjectlTuklWort< UnIt No.
11. Contraet(C) or Gr8nt(0) No.
(C)
(0)
1 ~ Sponaorlng Organization Nama and Addre88 13. Type of Report & PerIod Covered
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
15. Supplement8ly NotH
16. AbaIr.ct (UmIt: 200 word.)
The 55-acre Golden Strip Septic Tank (GSST) site is an inactive waste hauling and
disposal facility in Simpsonville, Greenville County, South Carolina. Land use in
the area is predom,inant ly residential. The estimated 638 residents who reside within
a quarter-mile of the site use public water as their drinking water supply. From
1960 to 1975, GSST used the site to dispose of industrial and septic wastes in five
unlined lagoons. In 1975, GSST applied for an industrial solid waste permit to
dispose of liquid wastes, but the State denied the permit because the proposed
disposal method was unacceptable.' Subsequently, in 1978, GSST discontinued waste
collection, hauling, and disposal, and filled in three of the five lagoons by pushing
in surrounding berms. State investigations of the site began in 1972 and included a
site survey of lagoons and the surrounding area. The State continued its monitoring
after the lagoons were filled and graded in 1978, and the results of the monitoring
led to additional investigations by EPA in 1984 and 1986 and an RI and supplemental
RI from 1989 to 1990 and 1990 to 1991, respectively. EPA identified metal
contamination in lagoon soil and sludge, and limited contamination of ground water.
In addition, 27 abandoned drums that contained low levels of contaminants were found
(See Attached Page)
17. Document An8Jy8i. L Deecrlplora
Record of Decision - Golden Strip Septic Tank, SC
First Remedial Action - Final
Contaminated Media: soil, sludge, sw
Key Contaminants: VOCs (benzene, PCE, toluene, xylenes), other organics,
metals (arsenic, chromium, lead)
u. KanIUt8eflllup=tt-ClIUaU 'W'I88
c. COSA TI FleldJGroup
18. Availability Statement 18. SecI8'Ity CI... (Thla Report) 21. No. of P.gea
None 305
20. SecI8'Ity CI... (Thl. Page) 22. PrIce
Nonp.
)
(See ANSl-Z38.18)
See Instructions on Reve"",
(Fonnerty NTl5-35)
Department of Conmeree
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EPA/ROD/R04-91/084
Golden Strip Septic Tank, SC
First Remedial Action - Final
Abstract (Continued)
on the east side of the site. Six of the drums have been placed in overpack drums and
stored in an onsite temporary drum storage area. This Record of Decision (ROD)
.addresses remediation of contaminated soil, as well as sludge and surface water from
the lagoons, as a final remedy. Ground water contamination is expected to naturally
attenuate within 2 to 5 years after source remediation occurs. The primary
contaminants of concern affecting the soil, sludge, and surface water are VOCs
including benzene, PCE, toluene, and xylenes; other organics; and metals including
arsenic, chromium, and lead.
The selected remedial action for this site includes excavating and treating onsite
approximately 22,400 cubic yards of soil and 4,200 cubic yards of sludge using
solidification/fixation; backfilling the treated residuals, covering the area with
clean soil, and revegetating the site; discharging offsite 1.9 million gallons of
impounded surface water from Lagoons 1 and 4 to a publicly owned treatment works
(POTW); disposing of drummed liquids, along with other surface water; establishing
Alternate Concentration Limits (ACLs) for the MCLs that are periodically exceeded in
the ground water to ensure that source control measures have a positive effect on
ground water; conducting long-term ground water and surface water monitoring;
investigating further the contamination from the abandoned onsite drums; and
implementing institutional controls to control site development. The estimated
present worth cost for this remedial action is $4,529,000, which includes an annual
O&M cost of $991,500.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific soil clean-up goals are based on
health-based criteria and include arsenic 18 mg/kg, cadmium 65 mg/kg, chromium
580 mg/kg, lead 500 mg/kg, PCE 56 mg/kg, toluene 12,000 mg/kg, and
xylenes 120,000 mg/kg. Ground water ACLs will be established based on the arithmetic
mean of the first four samples of each constituent for that well. For means that do
not exceed the MCLs, the MCL will be the applicable standard against which ground
water monitoring results will be compared.
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RECORD OF DECISION
GOLDEN STRIP SEPTIC TANK SITE
Greenville County, Simpsonville, South Carolina
United States
Prepared By:
Environmental Protection
Region IV
Atlanta, Georgia
Agency.
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RECORD OF DECISION
DECLARATION
SITE NAME AND LOCATION
i
I
!
Golden Strip Septic Tank Site
Greenville County, Simpsonville, South Carolina
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action
for the Golden Strip Septic Tank Site near Simpsonville in
Greenville County, South Carolina, which was chosen in
accordance with CERCLA, as amended by SARA, and, to the extent
practicable, the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP). This decision is based on
the Administrative Record for this site.
The State of South Carolina concurs with the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from
this site, if not addressed by implementing the response
action selected in the Record of Decision (ROD), may present
an imminent and substantial endangerment to public health,
welfare, or the environment.
DESCRIPTION OF THE REMEDY
The selected remedy in this ROD addresses soils and lagoon
sludges that have been contaminated as a result of past waste
disposal activities at the site. Affected soils and lagoon
sludges have been identified as the principal threat posed by
the site. The selected remedy addresses the source of
contamination by treatment of the affected soils and lagoon
sludges. Alternate Concentration Limits (ACLs) for the
observed~ intermittent Maximum Contaminant Levels (MCLs)
exceedences in the ground water will be established and a
long-term ground water monitoring program will be developed to
ensure that treatment of the source material will result in a
positive influence on the ground water.
The major components of the selected remedy include:
Excavation and treatment of approximately 28,000 cubic
yards of contaminated soil and lagoon sludge by
solidification/fixation. Treatment of the affected
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~.
. -
soils and sludge will be in full accordance with the
Land Disposal Restrictions (LDRs) imposed under the
Resource, ConserVation and Recovery Act (RCRA), as
amended by the Hazardous and Solid Waste Amendments
(HSWA). Treated material will be backfilled into
on-site excavations within the defined Area of
Contamination.
Establishment of ACLs for 1,2-dichloroethane,
1,2-dichloropropane, chromium, and lead in the ground
water at the site. A long-term environmental
monitoring network will be developed to monitor the
effects of treatment of source material on the ground
water and nearby stream.
Discharge of approximately 1.9 million gallons of
surface water impounded in Lagoon Nos. 1 and 4 to the
local Publicly Owned Treatment Works (POTW).
Implementation of institutional controls and a
conservation easement that will grant control of the
site in perpetuity to a third party and prohibit
further development of the property.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. This remedy utilizes
permanent solutions and alternative treatment technology t~
the maximum extent practicable, and satisfies the statutory
preference for remedies that employ treatment that reduces
toxicity, mobility, or volume .as a principal element.
Because this remedy will result in a treated monolith of
hazardous substances remaining on-site, a review shall be
conducted no less often than every five years after -
commencement of remedial action at the site. The five-year
review will be conducted to ensure that the selected remedy
continues to provide adequate protection of human health and
the environment and to evaluate if Federal and State cleanup
standards are still adequate and protective.
- (;k-~tvz~
~Greer C. Tidwell
q 'Regional Administrator
u.S. Environmental Protection Agency
Region IV
SEP 1 2 1991
Date
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Section
1.0
2~0
3.0
4.0
5.0
6.0
7.0
SITE
1.1
1.2
1.3
SITE
2.1
2.2
2.3
TABLE ~F CONTENTS
Paqe
NAME, LOCATION, AND DESCRIPTION........................!
Surface Features.......................................1
Subsurface Features...............~....................5
Current Land Use....................................... 9
HISTORY AND ENFORCEMENT ACTIVITIES....................1!
Initial Investigations................................!1
Remedial Investigation.............~..................12
Supplemental Remedial Investigation................... .12
HIGHLIGHTS OF COMMUNITY PARTICIPATION..........~...........14
SCOPE AND ROLE OF RESPONSE ACTION..........................15
4.1 Contaminated Surface Soils/Lagoon Sludges.............15
4.2 Ground Water......................................... .15
4.3 Lagoon Surface Water..................................17
SUMMARY OF SITE CHARACTERISTICS............................18
5. 1 Source .Areas.....'..................................... 25
5 . 1. 1 Lagoon .Areas................................... 26
5.1.2 Additional Waste Characterization..............30
5.1.3 Potential Land Farming .Areas...................33
5.1.4 Affected Surface Soils.........................33
5.1.5 Abandoned Drum .Area......a.....................34
Surface Water and Stream Sediments....................35
Ground Water.......................................... 35
5.3.1 Ground Water Flow..............................36
5.3.2 Ground Water Quality...........................36
5.3.3 Supplemental Remedial Investigation............38
Air Meni tor ing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41
5.4.1 Background Monitoring..........................4!
5.4.2 On-Site Air Monitoring.........................41
Nature and Extent of Contamination....................42
5.2
5.3
5.4
5.5
.SUMMARY OF SITE RISKS................................ ...... .45
6.1 Contaminant Identification............................45
6.2 Exposure Assessment...................................45
6.2.1 Current Land Use...............................45
6.2.2 Future Land Use................................46
Toxicity Assessment...................................46
6 . 3 . 1 Carcinogens. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46
6.3.2 Non-Carcinogens................................47
Risk Characterization Summary.........................47
Environmental (Ecological) Risks......................49
6.3
6.4
6.5
DESCRIPTION OF ALTERNATIVES................................81
7.1 Alternative 1 - No Action.............................86
7.2 Alternative 2 - Institutional Controls................86
7.3 Alternative 3 - Containment of Soils and Sludges......87
7.4 Alternative 4 - Stabilization and Off-Site Disposal
of Soils and Sludges..................89
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Section
8.0
9.0
10.0
..
7.5
7.6
7.7
7.8
7.9
TABLE OF CONTENTS (con't}
Paqe
Alternative 5 - Stabilization and Off-Site Disposal
of Sludge and Capping of Soils........91
Alternative 6 - Excavation and On-Site Disposal of
Soils and Sludges.....................92
Alternative 7 - Treatment and On-Site Disposal of
Soils and Sludges.....................93
Alternative 8 - In Situ Treatment of Soils and
Sludges...............................97
Alternative 9 - Screening of Remedial Alternatives....99
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES.......... .101
8.1 Overall Protection of Human Health and the
8.2
8.3
8.4
8.5
8.6
8.7
8.8
8..9
Environment...... .... ...... ~.... ........... . ... . .... .105
Compliance with Applicable or Relevant and
Appropriate Requirements (ARARs).....................105
Long-Term Effectiveness and Permanence...............106
Reduction of. Toxicity, Mobility, or Volume...........106
Short-Term Effectiveness.............................107
Implementability......"....................... e._..... .107
Cost. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 108
State/Support Agency Acceptance......................108
Community Acceptance.................................108
THE SELECTED REMEDY...................................... .109
9.1 Contaminated Surface Soils/Lagoon Sludges............109
9.2 Ground Water........................................ .115
9.2.1 Aquifer Monitoring............................116
9.2.2 Stream Monitoring.............................119
Lagoon Surface Water.................................120
Long-Term Operation and Maintenance..................120
Cost Summary for the Selected Remedy.................122
9.3
9.4
9.5
STATUTORY DETERMINATIONS..................................125
10.1 Protection of Human Health and the Environment.......125
10.2 Compliance with Applicable or Relevant and
Appropriate Requirements (ARARs).....................125
10.2.1 Chemical-Specific ARARs......................126
10.2.2 Action-Specific ARARs........................126
10.2.3 Location-Specific ARARs.. .................... .126
10.3 Cost-Effectiveness...................................127
10.4 Utilization of Permanent Solutions and Alternative
Treatment Technologies or Resource Recovery
Technologies to the Maximum Extent Practicable (MEP).127
10.5 Preference for Treatment as a Principal Element......128
ATTACHMENT I - State of South Carolina Concurrence Letter
ATTACHMENT II - Responsiveness Summary
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. LIST OF FIGURES
Fiaure/Title
Paae
Figure 1 - General Location
Map. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
Figure 2
Figure 3
- Location Map.............................................3
Lagoon Area Location Map.................................4
Figure 4 - Hydrogeologic Cross-Section
Figure 5 - Hydrogeologic Cross~Section
A-A' . . . . . . . . . . . . . . . . . . . . . . . . .6
B- B' . . . . . . . . . . . . . . . . . . . . . . . . . 7
Figure 6 - Hydrogeologic Cross-Section
C-C'& D-D'...................8
Figure 7 - Waste Cross-Section E-E'&
Figure 8 - Waste Cross-Section G-G',
F- F'. . . . . . . . . . . . . . . . . . . . . . . . . . 27
H-H', & 1-1'..................28
Figure 9 - Plan View - Remediation Limits..........................82
Figure 10 - Wast.e Cross Section/Limits of Remedial Action..........83
Figure 11 - Waste Cross Section/Limits of Remedial Action..........84
Figure 12 - Conceptual Layout/Selected Remedy-GSST. Site...........112
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LIST - OF TABLES
Table/Name
Table 1 - Constituents Detected Within Sample
Page
Media................19
Table 2 - Concentration Ranges of Constituents.....................20
-Table 3 - Upgradient Sampling Results..............................24
Table 4 - Parameters Measured During Additional Waste
Characterization............... ... . ................. .. ...31
Table 5 - Constituents of Concern, Completed Pathways and Exposure
Concentrations: Current and Future Land Use.............50
Table 6 - Constituents of Concern, Toxicity Values: Potential
Carcinogenic Effects.....................................54
Table 7 - Constituents of Concern, Toxicity Values: Potential
Non-Carcinogenic Effects.................................55
Table 8 - Estimated Excess Upper Bound Lifetime Cancer Risks
For Current Land Use. '. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .58
Table 9 - Non-Carcinogenic Hazard Index Estimates for Current
Land Use........................... e.8................... .60
Table 10 -Estimated Excess Upper Bound Cancer Risks for Future
Land Use - Park Scenario.................................64
Table 11 -Non-Carcinogenic Hazard Index Estimates for Future
Land Use - Park Scenario.................................66
Table 12 -Estimated Excess Upper Bound Lifetime Cancer Risks for
Future Land Use - Residential Scena~o...................70
Table 13 -Non-Carcinogenic Hazard Index Estimates for
Future Land Use - Residential Scenario...................72
Table 14 -Risk Assessment
SUIDDlary. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ." . .76
Table 15 -Environmental Receptors-Comparison of Exposure to
NOAEL. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 78
Table 16 -Comparative Analysis of Alternatives....................l02
Table 17 -Comparison of Costs for Phase III Alternatives..........104
Table 18 -Remedial Action Target Concentrations, Soil and Sludge..110
Table 19 -TCLP Regulatory Limits, Treated/Solidified Waste........114
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LIST OF TABLES (can't)
Table/Name
Paqe
Table 20 -Applicable MCL, MCLG, SMCL Values for Constituents
of Concern............................................,;. 118
Table 21 -Long-Term Aquifer and Stream Monitoring program.........121
Table 22 -Selected Remedy, Detailed Estimation of probable Cost...123
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1.0
SITE NAME, LOCATION, AND DESCRIPTION
The Golden Strip Septic Tank (GSST) site is located on a 55-acre
parcel in Greenville County, South Carolina, approximately three
miles north of Simpsonville. The site is situated in a
semi-rural area on the central portion of a farm owned by Mrs.
Lucille Rice (refer to Figure 1) and is surrounded by the Holly
Tree residential subdivision on the east, west, and north sides.
The site consists of five inactive lagoons and the surrounding
area. Lagoon Nos~ 1 and 4 currently remain open, but inactive.
Lagoon Nos. 2, 3 and 5 have been filled with surrounding berm
material and graded as a result of site activities conducted in
the late 1970's. The site and locations of the lagoons are
shown on Figures 2 and 3. Total capacity of the five lagoons
was reported to be approximately 2.8 million gallons. Design
capacities for the individual lagoons are as follows:
1
2
3
.4
5
Capacity (gallons)
640,000
70,000
450,000
840,000
775,000
Lagoon
In the Spring of 1989, prior to the initiation of the Remedial
Investigation field activities, institutional controls were
implemented to restrict access to the site. These controls
included the construction of an eight-foot security fence around
the waste management area and placement of warning signs
approximately every 100 feet along the fenceline, as well as
other strategic locations throughout the property. The fenced
area includes approximately 10 acres containing the five
inactive waste lagoons. The truck turnaround area and the
abandoned drum area (see Figures 2 and 3 for location) are not
presently included in the fenced area, and as such, access to .
these areas remains unrestricted.
1.1
Surface Features
The topography and other relevant surface features of the site
are illustrated on Figures 2 and 3. The most prominent features
of the GSST site are the two remaining open lagoons (Nos. 1 and
4) and an unnamed stream which originates at a spring located
near the southwest corner of the site and flows from the south
to the north through the site. The unnamed stream is a
tributary of Gilder Creek, which flows west to east about 1100
feet north of the site. Gilder Creek flows into the Enoree
River about eight miles further downstream. Land surrounding
the unnamed stream is currently undeveloped.
-1-
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'"'\
GOLDEN STRIP SEPTIC
TANK SITE LOCATION
LOCAi10N MAP
,
IfIlll'NC. Approved By: ~
. Date: OCTOBER 1990
Proj. No.; 613.09
L
1
I
2
,
SCALE IN MIlES
3
,
AGURE 1
GOLDEN STRIP SEPTIC TANK SITE
LOCATION MAP
SCALE: NOTED
-2-
SOURCE: RMT, INC. 1991
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FIGURE 2
LOCATION MAP
... -- GOLDEN STRIP SEPTIC TANK
..
SOURCE: RMT,INC. 1991
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FIGURE 3
LAGOON AREA lOCATION MAP
GOLDEN STRIP SEPTIC TANK
SOURCE: RMT, INC. 1991
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The topography at and near the site consists of gently rolling
hills. Much of the site slopes to the west and northwest
towards the stream. West of the stream the land rises steeply.
Topographic elevation ranges from approximately 850 feet above
mean sea level (msl) at the southeastern edge of the site to 775.
feet above msl where the stream leaves the site to the north.
The southern portion of the site, including the lagoon area, the
Rice home, and adjacent pastureland, has been cleared with only
scattered stands of trees remaining. Portions of the site are
forested. The northeast corner has been cleared of trees and is
covered with thick scrub vegetation. Lagoon No.1 is located
near a ridgecrest and does not receive an appreciable quantity
of surface runoff. Lagoon No.4 receives some surface runoff
from the surrounding area. The three closed lagoons (Nos. 2, 3,
and 5) have been backfilled and are covered with patches of tall
grass. Except for a lack of brush and trees and intermittent
spots of bare ground, there is little in the way of surface
features to suggest the previous limits of the three closed
lagoons. An eight-foot high chain link fence was constructed by
the Potential Responsible Parties' contractor, to limit access
to the lagoon area.
Surface drainage at the GSST site occurs by overland flow and
through several gullies leading towards the unnamed stream. The
largest of the gullies originates in the southeast corner of the
site and follows the eastern property line before turning west
and intersecting the unnamed stream. Two smaller gullies
originate west of the lagoon area and trend to the west toward
the stream. Surface water flow occurs in these drainage gullies
after periods of heavy precipitation. .
1.2
Subsurface Features
The GSST site is located in the piedmont physiographic province
of South Carolina on the eastern slope of the southern
Appalachian Mountains. The first ridge of the mountains occurs
approximately 20 miles to the north, and the main ridge occurs
approximately 50 miles to the north. The Piedmont province is a
broad plateau ranging in elevation from 400 to 1200 feet above
mean sea level. The general geology of the area consists of
metamorphics, intruded by igneous rocks, such as granites. The
bedrock is overlain by residual soil, saprolite, slope wash
deposits, and alluvial fill material of variable thickness.
Specific geologic conditions at the site were determined by
visual examination of soil samples and rock cuttings observed
during ground water monitoring well drilling. Site geology is
illustrated on the cross-sections shown on Figures 4, 5 and 6.
Residual soils comprise most of the land surface. These soils
grade from a silty and sandy clay to a silty and clayey sand.
The residual soils are underlain by a saprolite unit overlying a
-5-
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I AGURE 4
HYDROGEOLOGIC CROSS-SEC. A-A'
GOLDEN STRIP SEPTIC TANK
SOURCE: RMT,INC. 1991
-------
8 8'
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AGURE 5
HYDROGEOLOGIC CROSS-SEC. 8oB'
GOLDEN STRIP SEPTIC TANK
SOURCE: RMT. INC, 1991
-------
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-------
metamorphic/igneous rock assemblage. The saprolite ranges in
thickness from approximately 60 feet in the southeast corner of
the site to 5 feet in the center portion of the site near the
intersection with the unnamed stream. The saprolite consists
primarily of silty sands with varying amounts of mica and zones
of silt, silty and sandy clay, and clayey sand. The silty sand
unit generally contains increasing amounts of mica content with
depth. The sands grade in texture from fine-medium to
fipe-coarse with some rock fragments.
Depth to bedrock varies across the site from 10 to 60 feet below
ground surface. Based on visual examination of core samples
taken from bedrock monitoring wells, bedrock beneath the site
generally consists of granite gneiss. Prominent minerals were
quartz, feldspar, and mica. The bedrock surface was found to be
irregular across the site. East of the unnamed stream, the
bedrock surface generally slopes upward to the east, .away from
the stream. To the west of the stream, the bedrock surface
rises steeply to the west with topography.
Groundwater flow is to the northwest over most of the site,
toward the unnamed stream, which flows in a south to north
direction. West of the stream, ground water flows to the
northeast toward the stream. Based on information collected
during the Remedial Investigation, the calculated values of
ground water velocity for the site range from 40 to 120 feet per
year.
1.3
Current Land Use
Land use to the east and west of the site is residential. Land
use to the north and southeast of the site is primarily
residential, although, at present, the areas are sparsely
populated. Land use to the southwest of the site is primarily
agricultural. Undeveloped land is heavily forested, while
residential and agricultural areas are generally cleared of
trees.
An elementary school is located approximately two miles west of
the site, and a middle school is located approximately two miles.
south of the site. A church and a YMCA facility are located
approximately one mile southwest of the site. . Another church is
located approximately 1.75 miles north of the site.
At this time, there are 203 single family residences within a
quarter-mile radius of the site. The areas north and south of
the site have the potential for about 60 additional single
family residences. Based on these figures and utilizing current
estimating techniques, the current population near the site is
638, and the potential future population is 826.
-9-
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Information was obtained from the South Carolina Water Resources
Commission to identify potential ground water users located
within a half-mile radius of the site. Records were available
for only one well, which is located on the upgradient, eastern
edge of the site. The well was reportedly drilled in 1986 to a .
depth of 410 feet. Public water is available for use by homes
in the subdivision. The source of the public water is
reservoirs located in the northern part of Greenville County
more than 20 miles from GSST.
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2.0
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The Golden Strip Septic Tank Service was a waste hauling and
disposal company operated primarily by Mr. Buck Rice. The GSST
service began accepting industrial and septic wastes in 1960.
Initially, two unlined impoundments (lagoons) were excavated and
used for storage of industrial wastewater and sludges. Three
additional unlined impoundments were later constructed. Site
operations by the GSST service were discontinued in 1975.
Locations of the impoundments are illustrated on Figure 3.
In January 1975, the Golden Strip Septic Tank Service applied to
the South Carolina Department of Health and Environmental
Control (SCDHEC) for a permit to collect and transport
industrial solid waste material and dispose of that material on
the Rice property. The type of waste materials listed for
disposal on the permit application were liquid (chromic acid and
water). SCDHEC denied the GSST Service permit application in a
letter dated May 15, 1975, and stated that the proposed method.
of handling industrial waste at GSST was not acceptable. SCDHEC
further indicated that should .GSST desire to continue handling
and disposing industrial wastes, a proposal should be submitted
for an alternative waste treatment system and that permits for
these activities would be necessary. The GSST Service
discontinued collection, hauling, and disposal of wastes in
1975. In 1978, three of the lagoons (Nos. 2,3, and 5) were
filled by pushing in the surrounding berms.
2.1
Initial Investiaations
Investigations of the GSST site began in 1972 when SCDHEC sent
field personnel to conduct interviews with Mr. Rice and perform
a site survey of the lagoons and surrounding area. SCDHEC
continued to perform monitoring of the site after the lagoons
were filled with soil and graded in 1978. Analyses of samples
collected by SCDHEC in 1981 from the water in the uncovered.
lagoons (Nos. 1 and 4) indicated the presence of heavy metals
such as chromium, lead, and copper in this area.
Prompted by these results, the United State Environmental
Protection Agency (EPA) performed a Site Inspection (SI) in
August 1984 to gather additional information on the site.
During the SI, samples were collected and analyzed from the
lagoon areas, on-site springs, the unnamed stream, and Gilder
Creek. The results of the SI indicated heavy metal
contamination in the lagoons and groundwater. The surface water
did not indicate.heavy metal contamination. Results of the SI
indicated that there was no immediate threat or endangerment to
residents living near the site.
In 1986, EPA conducted further confirmation testing at the site
as part of the SI to determine if the site should be considered
-11-
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for the Superfund Remedial Program. The Golden Strip Septic
Tank site received a Bazard Ranking System (BRS) score of 40.3
and was proposed for inclusion on the National Priorities List
(NPL) in January 1987. Due to the presence of these
constituents in preliminary sampling, and the potential threat
to human health and the environment posed by these constituents,
the GSST site was placed on the NPL in June 1987.
2.2
Remedial Investiaation
Seven Potentially Responsible Parties (PRPs) entered into an
Administrative Order on Consent (AOC) with EPA to perform the
Remedial Investigation/Feasibility Study (RI/FS) at the site
under the direction and oversight of EPA. The objective of the
RI/FS as stated in the AOC was "...to determine the nature and
extent of the threat to public health or welfare, or the
environment caused by the release or threatened release of
hazardous substances from the site." On July 22, 1988, Metal
Products Corp.; Sterling Drug, Inc.; Colonial Beights Packaging,
Inc.; E-Systems, Inc.; and W.R. Grace & Co.-Conn. signed the
AOC. On January 12, 1989, the AOC was modified to include BASF
Corporation and the Carolina Plating and Stamping Corporation as
parties to the AOC. These seven PRPs are known as the Golden
Strip Task Group.
The Golden Strip Task Group retained RMT, Inc. of Greenville,
South Carolina as their contractor to perform the Remedial
Investigation. The majority of RI field activities were
conducted from September 1989 to March 1990. The investigation
included the collection of 226 environmental samples. The media
sampled included visible lagoon waste, soil, air, ground water,
and surface water samples from selected locations across the
site. Seventeen ground water monitoring wells were installed
and sampled. The unnamed stream was also sampled for water and
sediments. The Draft Remedial Investigation Report was prepared
and submitted to the EPA and SCDBEC in November 1990. The RI
Report was given final approval by EPA and SCDBEC on June 10,
1991. The principal results and findings of the Remedial
Investigation are discussed in further detail in Section 5.0 -
Summary of Site Characteristics, of this document.
2.3
SUDDlemental Remedial Investiaation
A supplemental ground water investigation was conducted to
further define the nature and extent of ground water
contamination present at the site. The objective of the
Supplemental Remedial I~vestigation (SRI) was to further
investigate ground water flow characteristics and quality in the
downgradient, northern portion of the site. Specifically, much
of the work focused on determining if a ground water plume had
escaped detection by the monitoring well network previously
installed during the initial RI. SRI field activities began in
February 1991 and concluded in mid-March 1991.
-12~
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I" -
Five additional ground water monitoring wells were installed
downgradient from the existing network of monitoring wells.
Ground water samples were collected and analyzed from these five
new wells. The network of existing wells in the vicinity of the
lagoon areas were also resamp1ed and analyzed in order to
confirm previous sample results. The Draft SRI Report was
submitted to EPA and SCDHEC on May 1, 1991. The SRI Report was
given final approval by EPA and SCDHEC on July 8, 1991. The
principal results and findings of the SRI are discussed in
further detail in Section 5.0 - Summary of Site Characteristics
of this document. "
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3.0
HIGHLIGHTS OF COMMUNITY PARTICIPATION
In accordance with public participation requirements of CERCLA
Sections 113(k) (2) (B) (i-v) and 117, a comprehensive community
relations program was developed and implemented throughout the
remedial process at the Golden Strip Septic Tank site.
In July 1989, a Remedial Investigation/Feasibility Study (RI/FS)
Kick-Off Fact Sheet was prepared and delivered to interested citizens
and local officials included on the site's mailing list. This fact
sheet explained the overall process of Superfund, the upcoming RI/FS
at the GSST site, and opportunities for community involvement. A
RI/FS Kick-Off Public Meeting was held on September 12, 1989 with the
Holly Tree Homeowners Association to present the objectives of the
investigation, describe the activities, that were to take place as
part of the investigation, and to answer any questions the public had
regarding the upcoming investigation.
Following the completion of the RI in February 1991, a RI/FS Findings
Fact Sheet was prepared and released to the public in March 1991.
This fact sheet presented the findings of the investigation and
provided a explanation of the Feasibility Study. Findings of the
Baseline Risk Assessment were discussed as well as the future
direction,of the site.
The finalized RI/FS Reports and Proposed Plan .for the GSST site were
released to the public on June 17, 1991. These documents were made
available for public review at the EPA Region IV Records Center, the
Greenville Public Library, and the Simpsonville Branch Library. The
notice of availability of these documents and notification of the
Proposed Plan Public Meeting was announced in the Golden Strip Times
and the Simpsonville Tribune-Times on June 12 and June 19, 1991 and
in the Greenville News on June 16, 1991. The Proposed Plan Public
Meeting was held on June 20, 1991 at the Simpsonville Community
Building. At this meeting, representatives from EPA and SCDHEC
presented EPA's preferred alternative for cleanup of the site and
answered any questions the public had regarding the preferred
alternative, other alternatives considered in the FS or any other
concerns the public had related to the cleanup of this site.
The mandatory 30-day public comment period was held. from June 17 to
July 18, 1991. A response to the comments received during this
comment period is included in the Responsiveness Summary, which is
part of this Record of Decision. This decision document presents the
selected remedial action for the Golden Strip Septic Tank site in
Simpsonville, South Carolina, chosen in accordance with CERCLA, as
amended by SARA, and, to the extent practicable, the National
Contingency Plan. The decision for this site is based on the
Administrative Record for this site.
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1- -
4.0
SCOPE AND ROLE OF RESPONSE ACTION
EPA has identified the following remedial action objectives
for the cleanup of the Golden Strip Septic Tank site:
4.1
Contaminated Surface Soils/Laqoon Sludqes
The selected remedy in this ROD will address the
contaminated soils and lagoon sludge at the site that pose
the principal threat to human health and the environment.
The primary exposure threat to human health for this
contaminated material includes dermal contact with the waste
constituents in each of the inactive lagoons, and dermal
contact with waste constituents located in the surface soils
in the immediate vicinity of the lagoons. The contaminated
soil and lagoon sludges have been identified as constituent
source areas and, as such, represent the primary threat
posed to the environment. The estimated volume of affected
soil and lagoon waste requiring remedial action is
approximately 28,000 cubic yards.
4.2
Ground Water
The ground water results from the RI and SRI Report indicate
that limited migration of waste constituents from the
identified source areas has occurred. Based on the three
rounds of ground water sampling events, the effect on ground
water has been minimal even though the wastes have been
subject to infiltration for more than 15 years. .
Intermittent exceedances of Maximum Concentration Levels
(MCLs), established by the Safe Drinking Water Act, were
detected in the ground water at the site in a relatively
localized area in the immediate vicinity of the lagoons.
However, EPA believes that active remediation of ground
water (such as a ground water pump and treat system) in the
vicinity of the lagoons is not reasonable or technically
practicable for the following reasons:
1) No discernible plume - Analytical results of ground
water samples collected from the monitoring wells in
the immediate vicinity of the lagoons indicate that
there is no apparent pattern of constituent
concentration in the ground water. The areal extent
of the affected ground water is relatively localized
to the immediate vicinity of the lagoons. Ground
water quality within the bedrock was not observed to
be affected by past waste disposal activities
on-site. The areal extent of the affected ground
water is expected to decrease as a result of the
selected remedy in this document.
-15-
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2) There are known and" projected points of entry of site
groundwater into surface water - Information gathered
during -the RI indicate that ground water within the
saprolite downgradient of the lagoons tends to
discharge on-site to the unnamed tributary of Gilder
Creek.
3) On the basis of measurements, there is no
statistically significant increase of waste
constituents from site ground water in surface water
at the point of entry - Water samples taken from five
locations in the unnamed stream indicate there is no
increase in constituent concentrations over surface
water background concentrations.
4) The selected remedy includes enforceable measures
that will preclude human exposure to the contaminated
ground water - Institutional controls and a
conservation easement, or deed restriction, shall be
established to provide reliable control against
future use of the affected ground water until
constituent concentrations are no longer elevated
above acceptable limits~
5) The selected remedy which addresses the source
material will result in a positive influence on
ground water - The selected remedy to control
constituent pathways to human exposure and the
environment will result in decreases of constituent
concentrations over time. Chemical degradation,
dilution and sorption to soil particles in the
aquifer should be sufficient to naturally attenuate
constituent concentrations without impacting health
and the environment in a relatively short time-frame
of two to five years after source remediation occurs.
Based on the above conclusions, Alternate Concentration
Limits (ACLs) will be established, as part of this ROD, for
those constituents which exceeded MCLs during the three
ground water sampling events. These constituents are
1,2-dichloroethane, 1,2-dichloropropane, chromium, and
lead. Additionally, this response action will also include
a comprehensive long-term monitoring program utilizing the
existing monitoring well network. Long-term monitoring of
the ground water will provide a sufficient database for
evaluating the representative concentrations of constituents
in ground water. Periodic assessment of ground water -
quality could result in the need to evaluate additional
remedial action for ground water at the site.
-16-
"
.-.
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4.3
Laaoon Surface Water
Surface water contained in open Lagoon Nos. 1 and 4 will
also be addressed by this document. Water impounded in
these lagoons exceeded MCLs for cadmium and chromium. The
selected remedy will include collection and discharge of
surface water impounded in these lagoons to the local
Publicly Owned Treatment Works (POTW). Pretreatment of the
discharge may be required if constituent concentrations
exceed the local Authority's effluent standards. RI data
indicate pretreatment will not be required. The estimated
volume of surface water impounded in the lagoons is
approximately 1.9 million gallons.
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5.0
SUMMARY OF SITE CHARACTERISTICS
This section of the Record of Decision summarizes the results of
the site field investigations which were conducted as part of
the Remedial Investigation and the Supplemental Remedial
Investigation. The sampling plan for the GSST site was based on
the reported method of waste disposal, topographic drainage
characteristics, and results of previous regulatory site
investigations. The types of samples collected were lagoon and
drum wastes, subsurface soils below and adjacent to the lagoons,
surface soils, ground water, surface water, stream sediments,
and air. Areas identified as potential constituent sources
included the lagoon area, potential land farming areas, the
abandoned drum area, and a truck t~rnaround area.
The area in the immediate vicinity of the lagoons was designated
as Zone 1. The Zone 1 boundary is shown on Figure 3.
Analytical testing was performed on Zone 1 samples for
parameters on both the Target Compound List (TCL) and the Target
Analyte List (TAL), as well as cyanide amenable to
chlorination. Zone 2 sampling included the remaining areas of
the site. A modified list of analytical parameters was
developed for Zone 2 sampling based on several factors,
including :,
The 'concentration of the constituents in'the Zone 1
samples;
The relationship of the detected constituents to the
waste material analyses and background sample data;
Constituent concentrations relative to applicable or
relevant and appropriate requirements;
The potential toxicity or endangerment to human health
and the environment; and
Potential mobility.
Table 1 summarizes the compounds that were detected in the
various media during the course of the RI. The ranges of
concentrations for each compound are listed in Table 2.
Upgradient, or background samples, were collected in areas which
were thought not to have been affected by past waste disposal
activities on-site. These samples were-analyzed for the TAL,
TCL, and free cyanide and were used for comparison against
samples collected in Zone 1 and 2. Table 3 summarizes
analytical results for inorganic parameters from the upgradient
samples for the various media. Included in this table is the
range of selected inorganic compounds detected in soils in
Georgia, South Carolina, and North Carolina obtained from,
"Chemical Analyses of Soils and Other Surficial Materials of the
-18-
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TABLE 1
CONSTITUENTS DETECTED WITHIN SAMPLE MEDIA
GROUND WATER
Acetone, Chloroform, 1,2-OichJoroethane, 1,2-DichJoroethene (totaJ),
1.2-Dichloroprcpane, Methylene Chloride, 1,1,1-TrichJoroethane. Xylenes (tCta.~.
Bis(2«hylhexyQphthalate, Aluminum, Barium, BerylUum. Cadmium, Calcium.
Chromium, CobaJt, Copper, Iron, Lead, Magnesium, Manganese, Nickel,
Potassium, Sodium, Vanadium, Zinc
SURFACE WATER
Acetone, Aluminum, Cadmium, Chromium, Copper, Iron, ,Lead, Manganese.
Potassium, Sodium, Zinc
SOIL
Acetone, 2-Butanone, Carbon Disulfide, Chlorobenzene, 1,2-0ichloroethenes
(totaQ, Ethylbenzene, Methylene Chloride, 4-Methyl-2-pentanone, Styrene,
Tetrachloroethene, Toluene, 1,1, 1-Trichloroethane, Trichloroethene, Xylenes
(totaQ, Acenaphthene, Benzo(b)fluoranthene, Benzoic Acid, 2-Chloropheno~
Chrysene, 1,2-Oichlorobenzene, 1,3-DichJorobenzene, 1,4-Dichlorobenzene,
2,4-Dimethylphenol, Bis(2-ethylhexyQphthaJate, Fluoranthene,
2-Methylnaphthalene, 4-Methylphenol, Naphthalene,
N-nitroso-di-n-propylamine, Pyrene, 1,2,4- Trlchlorobenzene, Aldrin, 4,4' -DOO.
4,4'-DDE, 4,4'-ODT, Dieldrin, ArochIor-12S4. Aluminum, Antimony. Arsenic,
Barium, Beryllium. Cadmium, Calcium, Chromium. Cobalt, Copper. Iron. Lead,
Magnesium, Manganese. Mercury. Nickel. Potassium, Selenium, Silver,
Sodium. Vanadium, Zinc, Cyanide
WASTE
Acetone. Benzene. 2-Butanone. Chlorobenzene. 1.2-Oichloroethenes (totaQ,
Ethylbenzene. Methylene Chloride, Styrene. Tetrachloroethene, Toluene,
Xylenes (totaQ, Bis(2-ethylhexyQphthalate, Aluminum, Antimony, Arsenic,
Cadmium. Chromium, Copper. Iron, Lead. Manganese. Mercury, Nickel.
Vanadium. Zinc. Cyanide
SOURCE: RMT, INC. 1991
.'
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TABLE 2
CONCENTRA TtON RANGES OF CONSi1TUENTS1aJ
I I I CONCENTRATION I
CONSTITUENTS MEDIUM RANGE (ppm)!b)
Volatile Organic ConstJtuents
Acetone Ground Water ND - 0.027
So~ ND - 2.0
Lagoon Waste 0.016 - 0.50
Surface Water ND-0.011
Benzene Lagoon Waste ND - 0.088 I
2-Butanone Soil ND - 0.28 I
Lagoon Waste ND - 0.16
Carbon Disulfide Soil ND - 0.018 I
Chlorobenzene Soil . ND. 0.12
Lagoon Waste ND - 38.0
Chloroform Ground Water ND . 0.043
1 ,2-Dichloroethane Ground Water ND - 0.006
1,2 Dichloroethenes (total) Ground Water ND - 0.013
Soil ND - 0.077
Lagoon Waste ND . 0.043
1,2-Dichloropropane Ground Water ND - 0.014
Ethylbenzene Soil ND - 0.061
Lagoon Waste NO . 1.9
Methylene Chloride Ground Water ND . 0.046
Soil ND . 0.073
Lagoon Waste NO - 0.056
4-Methyl.2-pentanone Soil NO. 0.096
Styrene Soil . NO - 0.036
Lagoon Waste ND . 0.19
Tetrachloroethene Soil NO - 18.0
Toluene SoD NO . 12.0
Lagoon Waste NO - 3.7
1,1, 1-Trichloroethane Ground Water NO - 0.013
Soil NO. 0.15
Trichloroethene SoD NO - 0.042
Xylenes (total) Ground Water NO - 0.043
SoD NO - 4.2
Lagoon Waste NO - 11.0
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TABLE 2
CONCENTRATION RANGES OF C~NSTTTUENTS (Con't)
CONCENTRATION
CONSTTTUENTS MEDIUM RANGE (ppm)1bI
SemlvolatJle Organic ConstItUents
Acenaphthene Soil ND-U
Benzoic Acid Soil NO - 16.0 I
Benzo(b)fluoranthene Soil NO - 1.1 I
2-Chlorophenol Soil NO - 3.7 I
Chrysene Soil NO - 1.0 I
1,2-0ichlorobenzene Soil NO - 1.2 I
1,3-Dichlorobenzene Soil NO - 0.70 I
1,4-0ichlorobenzene Soil NO - 6.2
2,4-Dimethylphenol Soil NO - 7.6
bis (2-EthylhexyQ phthalats GrolJnd Water NO - 0.12
Soil NO - 130
Lagoon Waste NO - 42.0
Fluoranthene Soil NO - 0.83
2-Methylnaphthalene Soil NO - 1.3
4-Methylphenol Soil NO - 1.1
Naphthalene Soil NO -1.2
N-nitrOSo-di-n-propylaminfi! Soil NO - 1.1
Pyrene Soil ND - 3.0
1 ,2,4-Trichlorobenzene Soil ND - 3.5
Pestlcldes\PCBs
Aldrin Soil ND - 0.44
4,4' DDD Soil ND - 0.040
4,4' DDE Soil No- 0.044
4,4' DDT Soil ND - 0.023.
Dieldrin Soil ND - 0.46
Arochlor 1254 Soil ND - 0.27
-- . InorganIc Constituents
Aluminum Ground Water (filtered) NO - 3.24
Ground Water (no~ered) NO . 92.9
Soil 2790 . 66,200
Lagoon Waste 11,100.38,500
Surface Water NO . 0.265
Antimony Soil ND . 708
Lagoon Waste NO - 1940
-21-
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T AS LE 2
CONCENTRATION RANGES OF CONSTTTUENTS (Con't)
CON CENTRA TlON
CONSTmJENTS MEDIUM RANGE (ppm)!bl
Inorganic CoMtltuenta (Con't) I
Arsenic Soil NO - 76.1
Lagoon Waste NO - 23.6
Barium Ground Water (non-filtered) NO - 1.30 I
Soil NO - 397
Beryllium Ground Water (filtered) NO . 0.005 I
Ground Water (non-filtered) NO . 0.008
Soil NO - 7.0
Cadmium Soil NO. 3140
Ground Water (non-filtered) NO - 0.005
Lagoon Waste ,19.1.12,000
Surface Water NO - 0.078
Calcium Ground Water (filtered) NO . 66.5
Ground Water (non-filtered) NO - 65.1
Soil NO - 7380
Chromium Ground Water (filtered) NO - 0.061
Ground Water (non-filtered) NO - 0.279
Soil 7.7 . 35,800
Lagoon Waste 1370 . 97,200
Surface Water NO - 0.498
Cobalt Ground Water (filtered) NO . 0.051
Ground Water (non-filtered) NO -0.096
Soil NO . 111
Copper Ground Water (non-filtered) NO . 0.081
Soil ND .15]00
Lagoon Waste 787 . 69,900
Surface Water ND . 1.1
Cyanide Soil ND - 1,790
Lagoon Waste 6.6.4,520
Iron Ground Water (filtered) NO .2.71
Ground Water (non..filtered) 0.128 .110
Soil ND - 328,000
Lagoon Waste 13,200-95,700
Surface Water NO .11.5
Lead Ground Water (filtered) ND - 0.005
Ground Water (non-fittered) ND - 0.050
Soil 2.7 - 5290
Lagoon Waste 12.1 - 1900
Surface Water NO - 0.006
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TABLE 2
CONCENTRAT10N RANGES OF CONSi1TUENTS (Con't)
CONCENTRATION
CONSTITUENTS MEDIUM RANGE (ppm)lbl
Inorganic Constltuent8 (Con't) I
Magnesium Ground Water (filtered) NO - 24.9
Ground Water (non-filtered) NO . 36.9
Soil NO - 17100
Manganese Ground Water (filtered) NO . 5.30 I
Ground Water (non-fiItered) 0.041 - 5.11
Soil 30.1 . 2900
Lagoon Waste 61.4.572
Surface Water NO - 0.441
Mercury Soils NO . 3.8
Lagoon Waste 'NO. 13.8
Nickel Ground Water (filtered) NO. 0.147
, Ground Water (non-filtered) NO . 0.152
Soil NO -1690
Lagoon Waste NO . 6140
Potassium Ground Water (non-tiltered) NO . 35.8
Soil NO . 16,000
Surface Water NO . 36.6
Selenium Soil NO . 6.0
Silver Soil NO . 6.7
Sodium Ground Water (filtered) NO . 360
Ground Water (non-filtered) NO . 344
Soil NO. 1740
Surface Water NO . 228
Vanadium Ground Water (non-filtered) NO . 0.334
Soil NO . 356
Lagoon Waste NO . 134
Zinc Ground Waler (filtered) NO . 0.055
Ground W;tter (non-filtered) NO. 0.238
Soil 10.9 .26,500
Lagoon Waste 270 . 77,600
Surface Waler ND .2.68
[a] The analytical results from the water and waste. samples collected at the
abandoned drum area are not included in Table 2.
.[b] Results reported in ppm; mg/l for liquid samples or mg/kg for solid samples.
SOURCE: RMT, INC. 1991
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TABLE 3
UPGRADIENT 5AMPUNG RE5UL T5
PARAMETERI" GSST GROUND WATER G~T GSST REGIONAL
FIlTERED NON-FILTERED SURFACE WATER SOilSISEDIMENT8 RANGElbl
Aluminum NO . 3.24 0.542- 13.0 NO 8,640 . 48,400 3000 ->100,000
"'..nlo NoIc! ND ND NO 0.3 . 28
Barium ND No.o.217 ND ND-84.4 16: 700
Beryllium ND ND ND ND - 2.4 1.7
Calolum ND N~.10 NO ND 300 . 12,000
Chromium ND NO. 0.016 ND 59.8. 121 5-300
Cobalt ND NO NO NO. 111 3.60
Copper ND ND 0.026 ND . 43.0 2 - 100
Iron NO. 2.71 0.824 . 18.8 NO 13,800.328,000 3000 . 70,000
lead NO . 0.005 NO. 0.015 NO ..0 - 38.5 10 . 300
Magne.lum NO NO . 6.29 NO NO . 6870 100 . 10,000
Mangane.. 0.025 . 0.230 0.041 .0.862 NO 67.8 . 718 0.03 - 3,000
Merouly NO NO ND NO 0.02 .1
Nlokel NO NO NO NO. 18.0 5.160
POlaNium NO NO - 8.27 NO NO. 7610 100.31,000
Selenium NO ND NO ND <0.1.1.3
Sodium NO. 13.2 NO. 14.8 NO NO 600 .15,000
Thelllum NDlNAldJ NO/NA NO ND 4.41 .10.67
Vanadium NO NO NO 51.. .141 10 - 300
Zino NO . 0.030 NO - 0.053 NO 17.0 . 121 150,000 - 400,000
I"
IbJ
lei
141
Allruulte r.ported In ppm; mgIL for liquid .ampl.. Of mg/kg for IOlid .ample..
From Chemloal ~lIa of 80lla and Other Surficial Mat.rlala of the Conlarmlnou. United StaI.., U.S. Geological Survey Raport 81.197, 1981.
Nol Deteoted
Thallium W88 not d8leoted during fklt round .ampllng and w.. nollncluded In the lilt of an~a for the .econd round.
SOURCE: RMT, INC. 1991
I
~
N
I
-------
Conterminous united States" (Boerngren and Shacklette, 1981).
The range of concentrations in Table 3 includes samples
collected from foothill, piedmont, and coastal plain locations,
and is presented:for comparison with downgradient samples.
Upon comparison of Table 2 and 3, common inorganic constituents
perceived not to be related to waste disposal activities at the
site are: aluminum, barium, beryllium, calcium, cobalt, iron,
magnesium, manganese, potassium, selenium, silver, sodium and
vanadium. The concentration ranges of these compounds, as
summarized in Table 2, primarily correspond with the local and
regional background levels. .
5.1
Source Areas
Constituents to be addressed during the Remedial Investigation
were identified by locating and sampling the primary areas of
waste deposition. Available records indicate that the five
lagoons had received industrial wastewater and sludges. Soil
borings and test pits were used to investigate the horizontal
and vertical extent of waste deposition within the five
lagoons. Samples of waste were analyzed for the TAL/TCL
parameters to provide a characterization of the waste
materials. The. lagoon sludges, underlying sediments, and
affected surface soils were identified as the primary sources of
Constituents of Concern (COCa) at the GSST site.
There were unconfirmed reports of land farming at three areas
on-site. The location of these areas are illustrated on Figure
2. Surface soil samples were collected and analyzed to
investigate the nature of soils in these areas. During field
reconnaissance work for the RI, an area reported to have been
used as a truck turnaround area was identified. Location of the
truck turnaround area is shown on Figure 2. Surface soil
samples were collected in this area as part of the COC source
investigation.
During the field portion of the RI, an area containing
twenty-seven abandoned drums was discovered. All but five of
these drums were empty. What appeared to be rainwater.
accumulation was noted in four drums. One drum contained a
hardened residue of unknown compostion. An investigation of
this area was conducted which included collecting surface soil,
water, and waste samples to assess the impact of the drums and
their contents on the surrounding area. Location of the
abandoned drum area is shown on Figure 2.
Additional subsurface samples from Lagoon 2 and sludge samples
from Lagoons 1 and 4 were also collected. These samples were
subjected to a number of analytical procedures to further
characterize the waste present at the site.
,
-25-
-------
5.1.1
Laaoon Areas
Subsurface waste and soil samples were collected from within
Lagoons 1 through 5. Surface soil samples were collected
from the areas immediately adjacent to the lagoons. The
lateral extent of the closed lagoons, when active, was
estimated by test pit excavation.
Laaoon 1
Five soil borings were drilled, four lagoon bottom samples
and one surface soil sample were collected to inves~igate the
horizontal and vertical extent of the areas of waste
deposition in Lagoon 1. Boring and sample locations are
shown on Figures 2 and 3. The estimated configuration of the
lagoon bottom is indicated on waste cross sections E-E' and
I-I' on Figures 7 and 8. Lagoon 1 is deepest along its
western edge and is more shallow at the center. Waste, in
the form of a dark-colored sludge material, was encountered
in a layer approximately three inches thick on the lagoon
bottom.
Several Volatile Organic Compounds (VOCs) were detected at
low concentrations in the lagoon bottom samples. Acetone was
detected in samples collected from the four locations at
concentrations of less than 1 part per million (ppm). Three
of the lagoon bottom samples also contained 2-butanone,
chlorobenzene, toluene, bis(2-ethylhexyl)phthalate and
xylenes. Additional VOCs detected in the fourth sample
include berizene, 1,2-dichloroethene (total), ethylbenzene,
and tetrachloroethene.
The inorganic constituents antimony, arsenic, cadmium,
chromium, copper, lead, mercury, nickel, zinc, and cyanide
were found at highly elevated levels compared to background
levels in Table 3. The highest concentrations of. heavy
metals were found in sample W01. This is most likely related
to the close proximity of the sample location to a discharge
area used during past GSST Service activities at the northern
corner of Lagoon 1, and to the increased depth of the lagoon
in the area of W01. .
Laaoon 2
Three soil borings were drilled and one surface soil sample
was collected to investigate the Lagoon 2 area. Waste was
encountered during the drilling of SB-7 and SB-8A. Waste
cross sections E-E' and G-G' on Figures 7 and 8 illustrate
the depths and extent to which waste was encountered. The
areal extent of the waste was inferred from the results of
test pits TP-l through TP-ll.
-26-
-------
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FIGURE 7
WASTE CROSS-SEC. E-E' & F-P
GOlDEN STRIP SEPTIC TANK
SOURCE: RMT,INC. 1991
-------
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FIGURE 8
WASTE CROSS-SEC. G-G',H-H' & I-I'
GOlDEN STRIP SEPTIC TANK
SOURCE: RMT,INC. 1991
-------
Samples of the waste and the underlying soil were collected
from borings SB-7 and SB-8A. Xylenes, toluene,
tetrachloroethene, and bis(2-ethylhexyl)phthalate were the
most common VOCs detected. A wide range of semi-volatile.
organic compounds were detected in waste samples from Lagoon
2. The highest of these concentrations include
1,4-dichlorobenzene at 6.2 ppm and 2-chlorophenol at 3.7
ppm. Many of these compounds (1,3-dichlorobenzene, 2,4
.dimethylphenol, 2-methylnapthalene, 4-methyl-2 pentanone,
4-methylphenol, and naphthalene) were not detected at any
other location on the site. The samples of. waste from Lagoon
2 contained elevated concentrations of several inorganic
constituents. In general, the underlying soils contained
lower levels of inorganics; however, many of the levels
remained greater than background.
Laaoon 3
Six soil borings were drilled to investigate the Lagoon 3
area. Waste was not encountered in any of the borings, but
was suspected in one. The areal extent of Lagoon 3 was
estimated from the distribution of waste observed during the
excavation of test pits TP-23 through TP-26 (Figure 3). The
test pits indicate that the.waste in Lagoon 3 is less than
0.5 feet thick, and consists of a layer of dark, sludge-like
material that can be traced in the subsurface. The estimated
distribution of the waste is illustrated o~ waste
cross-section E-E' and F-F' (Figure 7). .
Composite samples collected from the soil borings indicated
the presence of bis(2-ethylhexyl)phthalate and trace levels
of acetone and carbon disulfide. The inorganic constituents
antimony, cadmium, chromium, and copper, were detected at
elevated levels exceeding background concentrations.
Surface soil samples were collected near the western edge of
Lagoon 3. . These areas are considered to have potential to
act as secondary sources due to overflow and/or spills from
Lagoon 3. The most common VOCs detected were
bis(2-ethylhexyl)phthalate and l,l,l-trichloroethane.
Several inorganic constituents such as cadmium, chromium,
copper, lead, zinc and cyanide were also detected at elevated
levels. . .
Laaoon 4
Samples collected from the soil borings, lagoon bottom, and
surface soils were used to characterize the nature and extent
of waste in and around Lagoon 4. Waste cross-section F-F',
H-H' and D-D' (Figures 7 and 8) illustrate the approximate
size and depth of the lagoon and the sample intervals.
Lagoon 4 was found to be deeper and less irregular than
Lagoon 1. Samples of the lagoon bottom were found to consist
of a dark, sludge-like material characterized as waste.
-29-
-------
The lagoon bottom samples contained a widespread group of
organic compounds at low concentrations. The highest
concentration of an organic compound was
bis(2-ethylhexyl)phthalate at 4.6 ppm. Typical inorganic
waste constituents included arsenic, antimony, cadmium,
chromium and cyanide.
Surface soil samples were collected to assess the potential
for these areas to serve as secondary sources due to lagoon
operations. Several organic compounds were detected at
levels below 0.1 ppm. Chromium, cadmium, and copper were the
most common inorganic constituents found at concentrations
greater than background levels.
Laqoon 5
Four soil borings were drilled to sample and characterize
waste in Lagoon 5. Waste was encountered at only two soil
borings. The estimated extent of waste in Lagoon 5 is
illustrated on waste cross-sections G-G' and B-H' (Figure
8). The areal extent of Lagoon 5, as shown on Figure 3 was
based on visual observation of test pits TP-12 through
TP-22. The waste was characterized as a thin (less than 0.5
feet) layer of dark, gray finely layered, silty and
sludg~-like material.
Two samples of the waste were collected at depths of 0 to 2
feet and 4.5 feet to 5.0 feet below ground surface.
Analytical results of these samples indicated the presence of
bis(2-ethylhexyl)phthalate at a concentration of 3.9 ppm.
Eleven inorganic constituents were detected at concentrations
exceeding the background levels for the site. The most
common inorganic constituents were chromium, copper and zinc.
5.1.2
Additional Waste Characterization
Additional sampling was performed in order to further
characterize the waste materials and sludges .contained in the
lagoons. Two samples were collected from the open and closed
lagoons to assess the tendency of volatile organic compounds,
metals, and cyanide to leach from these wastes. Sample W07
is a composite sample of wastes taken from Lagoon Nos. 1 and
4. Sample W08 is a composite sample of soil collected from
below the visible waste layer of Lagoon 2.
Each sample was analyzed for total and hexavalent chromium.
The Toxicity Characteristic Leachate Procedure (TCLP) zero
headspace and metals extractions were performed, followed by
analysis of the extracts, to evaluate the leaching potential
of volatile organic compounds and metals from the wastes. An
ASTM water leach was performed to extract cyanide from each
waste, followed by cyanide analysis of the leachate to
evaluate the potential of each waste to release soluble
cyanide. This analytical data is summarized in Table 4.
-30-
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TABLE 4
PARAMETERS MEASURED DURING ADOmONAL WASTE CHARACTERIZA TlON
PARAMETER (1) . SAMPLE REGULAiORY
Field Blank W07 WOS L:V:-L
Compositional
Chromium. hexavalent dissolved
-------
ASTM Water Leachinq Procedure
Both Samples W07 and woe were subjected to the ASTM Water
Leaching Procedure to evaluate the likelihood of cyanide
leaching from the waste or soil matrix. The resulting data
from these tests suggests that the cyanide does not leach
under these test conditions to any appreciable extent from
either the sludge or soil.
Hexavalent Chromium Analysis
Samples W07 and woe were analyzed for the presence of total
and hexavalent chromium as part of this additional waste
characterization testing. "Analytical results indicated that
total chromium was present in both samples at elevated
concentrations, however hexavalent chromium was not detected
in either sample above the method detection limit (0.5
mg/kg). This would indicate that the chromium present at the
site is all in the trivalent, or less toxic, form.
However, the analytical methodology utilized to determine the
presence of hexavalent chromium in site soils and sludges was
reviewed by EPA Region IV analytical experts. These experts
maintain that the analysis to quantify the hexavalent, or
more toxic form, of chromium in a soil matrix is uncertain.
The H~alth Assessment Staff of EPA Region IV believes it is
prudent, therefore to assume some portion of the soil
chromium to be hexavalent until a method is verified to
confirm/negate the presence of hexavalent chromium in a soil
matrix.
For purposes of the Risk Assessment at the site, EPA Region
IV believes based on consideration of available information,
that it is conservative, yet reasonable to assume for the
Golden Strip Septic Tank site that some of the total chromium
in the soil is hexavalent. EPA Region IV believes an
assumption of 10% of the total soil chromium being hexavalent
may be considered reasonably conservative.
Toxicity Characteristic Leachinq Procedure - Zero Headspace
Extraction
The analytical results from the zero headspace extraction
(ZHE) indicate that none of the TCLP ZHE constituents were
present above method detection limits. Acetone was detected
above the detection limit in woe, however, acetone is a
common laboratory artifact and is not a ZHE constituent.
Toxicity Characteristic Leachinq Procedure - Heavv Metals
The TCLP analytical results from samples W07 and woe indicate
that cadmium was present in the extract at levels above the
regulatory threshold. From this data, it was concluded that
waste present at the site will exhibit hazardous
characteristics for cadmium and a more thorough evaluation of
the leaching potential of the cac metals may be needed.
-32-
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5.1.3
Potential Land Farminq Areas
Three areas were identified as potential locations of former
land farming activities. Land farming may have been used as
a method of treating septic wastes. The three areas
investigated during this study are the area south of the
lagoons, the area east of the lagoons, and the northeastern
corner of the site. These areas are delineated on Figure 2.
"A total of thirteen surface soil samples were taken at the
three suspected areas of land farming. 50me trace levels of
organic and inorganic constituents were detected, however,
the levels of COCs in these areas are insufficient to suggest
that land farming was used as a method of waste disposal at
the site.
5.1.4
Affected 5urface Soils
During the surface soil investigation, which included
collection of samples at thirty-four locations within the
first foot below land surface, there were two areas
identified that may serve as secondary sources due to lagoon
operations and drainage patterns. These areas are referred
to as the "truck turnaround area" and "drainage swale area".
The locations of these areas are shown on Figure 3.
Truck Turnaround Area
Three surface soil samples, 515 through 517 (Figure 3), were
collected to investigate this area. The following organic
compounds were detected at levels of less than 1 ppm:
ethylbenzene, tetrachloroethene, toluene, xylenes, and
dieldrin. Bis(2-ethylhexyl)phthalate was found at
concentrations of 1.1 and 130 ppm in 516 and 517,
respectively. The highest concentrations of inorganics from
on-site surface soil samples were found in 517, including 798
ppm of cadmium, 7530 ppm chromium, 5290 ppm lead, 9550 ppm
zinc, and 186 ppm cyanide (total). Arsenic was detected at
53.4 ppm in 517, but was not detected in the duplicate sample
of 517. These levels of inorganics are highly elevated over
background concentrations shown in Table 3 for on-site
soils/sediments.
Drainaae 5wale
Two surface soil samples (525 & 527) and one stream sediment
sample (55-06) were collected to investigate this area.
Locations of these samples are shown" on Figure 3. 5amples
525 and 55-06 indicated the presence of trace levels of
organic compounds. Additionally, 525 and 55-06 contained
concentrations of cadmium, chromium, copper, lead and zinc
well above background levels. This analytical data supports
the suspicion that the surface soils located near the
drainage swale have been affected by past waste disposal
activities and may be receiving an appreciable amount of
overland run-off from the lagoon area.
-33-
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5.1.5
Abandoned Drum Area
During the RI, twenty-seven abandoned drums were discovered
in an area along the eastern side of the site (Figure 3). .In
February 1990, six of these drums having legible markings
were removed from the area, placed in overpack drums, and
stored in the temporary drum storage area. An investigation
of the area included the collection of samples from the
surface soil, hardened residue noted near the drums, and a
composite sample of the liquid that had accumulated in four
of the drums.
Two composite surface samples were collected at locations'
downslope of the drum site. Sample S35 was collected from
surface soils within a ten-foot radius of the approximate
center of the abandoned.drum area. -Sample S36.wascollected
from surface soil within a fifty-foot radius.of the
approximate center of the drum area. Analysis of these
samples indicate the only organic compound detected in S35
and.S36 was toluene. Cadmium, chromium, copper, and cyanide
were detected in S35 at levels greater than site background
values. Sample S36 also contained cadmium at a concentration
greater than background. .
The re~u1ts from the hardened residue indicate the presence
of low levels of VOCs. The concentrations of VOCs observed
in the samples are not felt to be su~ficiently high to cause
concern from the standpoint of TCLP leachability. Assuming
100 percent leaching of the VOCs, the levels of VOCs present
would still characterize the material as a non-hazardous
waste. Of the metals which were detected in the residue
sample, chromium was observed at a concentration that might
cause concern from a TCLP standpoint. The hardened residue
has been contained in drums, awaiting final disposition.
The analyses of the liquid found in the abandoned drums
indicate the presence of cadmium at a concentration of 0.0074
ppm which exceeds the drinking water MCL for cadmium of 0.005
ppm. No other MCL exceedances were observed. This data
indicates that the liquid in the drums has low levels of
COCs, and disposition of this liquid should be addressed in a'
manner similar to other liquids observed at the site. These
liquids have been placed in containers, awaiting final
disposition.
The empty drums remaining at the site were placed in overpack
drums and transported to the drum storage area maintained in
the exclusion zone fencing of the site. OVerpack drums were
labeled, included on the existing inventory, and covered
until their disposition can be determined.
-34-
-------
5.2
Surface Water and Stream Sediments
Surface water samples were collected from the unnamed stream at
five locations, labeled SW-l through SW-5 on Figure 2. Sample
SW-l was collected to serve as an upgradient surface water
sample for the site. This sample was collected near the spring
house that Mrs. Rice uses for personal consumption. The only
compound found above the detection limit in SW-l was copper at
0.026 ppm. In general, only the lagoon water and the drainage
swale sediment samples indicated any effects from past waste
disposal activities. Stream surface water and sediments do not
appear to have been affected by disposal operations.
No organic compounds were detected from surface water samples
collected at points downstream from the spring area. Iron and
manganese were detected in these samples at concentrations of
less than 1 ppm. Aluminum and zinc appeared in one sample,
however, none of the detected compounds are included in the
National Primary Drinking Water Standards. Concentrations of
aluminum and iron are, in places, slightly greater than the
concentrations in the Secondary Drinking Water Regulations;
however, they are believed to be naturally occurring.
Surface water samples SW06 and SW07 were collected from open
Lagoons 1 and 4, respectively. The only organic compound
detected in the analyses was acetone at 0.011 ppm in SW06.
Concentrations of cadmium and chromium were detected at levels
exceeding MCLs. Cadmium (MCL-O.005 ppm) was detected at a level
of 0.078 ppm in SW06 and chromium (MCL=0.100 ppm) was found at
levels of 0.184 ppm in SW06 and 0.498 ppm in SW07.
Five stream sediment samples were collected from the unnamed
stream at locations adjacent to the surface water sampling
locations. Results from the analysis of these samples further
indicate that the stream has not been affected by past waste
disposal activities at the site. .
Stream sediment samples were also collected from the bottom of
the gullies that lead toward the unnamed stream at several
locations on-site. Of these six samples collected and analyzed,
sample SS-06 had the highest levels of COCs and contained levels
of cadmium, chromium, lead, mercury and zinc. that were greater
than site background concentrations. This sample is located in
the "drainage swale area" located west of Lagoon Nos. 3 and 4
and is shown on Figure 3.
5.3
Ground Water
Seventeen ground water monitoring wells were initially installed
as part of the RI. Wells were installed to investigate the
horizontal ground water flow rates and directions, vertical
ground water flow components, and water quality conditions.
Monitoring well locations are illustrated on Figures 2 and 3.
-35-
-------
Thirteen monitoring wells (MW-1 through MW-13) were installed as
shallow wells with the well screen intersecting the water
table. Wells MW-1, MW-2 and MW-2A were installed at apparent
upgradient well locations to obtain background water quality
data. Four wells (MW-2a, MW-4A, MW-6A, and MW-9A) were
installed as deep saprolite wells.
5.3.1 . Ground Water Flow
Water levels were measured for seven consecutive months from
April 1990 through October 1990. This water level data was
used to determine the water table configuration at the site.
Ground water in the vicinity of the site occurs under
unconfined conditions and the water table tends to mimic the
general contour of the ground surface. Ground water flow is
to the northwest over most of the -site,' toward the unnamed
stream. West of the stream, ground water flows to the
northeast toward the stream.
Hydraulic conductivity tests were performed on all monitoring
wells and used to estimate ground water velocity at the 5
site. HydJaulic conductivity values ranged from 5 X 10-
to 4 X 10- em/see across the site. The tverage for wells
screened within the saprolite was 4 X 10- em/sec.
The average hydraulic gradient for the site is 0.03 feet per
foot. The gradient is generally slightly lower near the
southern portion of the site (0.025 feet per foot) and
increases with proximity to the unnamed stream, where a
maximum of 0.04 feet per foot was calculated.
Ground water velocities were calculated using the formula
published by Freeze and Cherry (1979).
Vs = Ki/n
where
Vs
K
i
n
= Ground water velocity
= Hydraulic conductivity
= Hydraulic gradient
= effective porosity
An average gradient of 0.03 feet/ioot and an average
hydraulic conductivity of 4 X 10- em/see were used to
calculate ground water velocity. A range of effective
porosity values of 10 to 30 percent was chosen to represent
the variable subsurface conditions. The calculated values of
ground water velocity for the site range from 40 to 120 feet
per year.
5.3.2
Ground Water Oualitv
Two complete ground water sampling and analysis rounds were
performed as part of the initial RI. The first round of
samples was divided into two phases. Initial ground water
-36-
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samples were collected from all Zone 1 wells and background
wells MW-1, MW-2 and MW-2A in February 1990. The initial
round of ground water sampling at Zone 2 wells took place in
May 1990 after the list of ana1ytes was revised. A second
round of samples was collected on July 1990. Both filtered
and non-filtered samples were collected for inorganic
analyses, however, EPA Region IV only recognizes non-filtered
samples for the purposes of evaluating ground water quality
-at a site.
Concentrations of lead, chromium, 1,2-dichloropropane, and
1,2-dichloroethane were detected above MCLs or EPA clean-up
levels in rounds 1 and 2 of the ground water sampling
events. It should be noted that the proposed MCL for lead is
0.005 ppm. However, a June 21, 1990 memorandum to EPA Region
IV titled "Cleanup Level for Lead in Ground Water" from Henry
L. Longest, Director of the Office of Emergency and Remedial
Response, established the cleanup level for lead in ground
water at 0.015 ppm. The MCL or clean-up level for these four
constituents are as follows:
Constituent
MCL/Clean-uD Level (CDm)
Lead
Chromium
1,2-dichloropropane
1,2-dichloroethane
0.015
0.100
0.005
0.005
The following is a summary of the MCL exceedances in ground
water at the site for sampling events 1 and 2:
Well Location Round Constituent Level (DDm)
MW-03 1 Lead 0.021
MW-04 1 Lead 0.027
1 1,2-Dichloropropane 0.013
2 Lead 0.017
2 1,2-Dichloropropane 0.014
MW-05 1 Lead 0.020
MW-06 2 1,2-Dichloroethane 0.006
MW-09 1 Lead 0.016
MW-12 1 Lead 0.050
1 Chromium 0.279
2 Lead 0.032
2 Chromium 0.164
Temporal variations in the concentrations of organic
constituents in ground water is a common phenomenon. The
observed exceedance of the MCL for 1,2-dichloropropane at
MW-04 was confirmed when this compound was detected at 0.014
-37--
-------
ppm in the second sampling round. However,
1,2-dichloropropane was not detected in samples of the waste
or -soil. The volatile organic compound 1,2-dichloroethane
was detected during the second round above the MCL in the
sample collected from MW-06. The presence of
1,2-dichloroethane was not confirmed in the first round.
This compound was also not detected in samples of the waste
or soil.
Analytical results from these two sampling events indicate
limited migration of contaminants has occurred at the site.
Based upon results of these two sampling events, there is no
apparent pattern or discernible plume of contaminants at the
site. However, given the calculated ground water velocities
and the 15 to 30 years the contaminants identified in the
lagoon area had to migrate, it was suggested that the
monitoring well network installed as part of the RI might
have missed detecting a plume that had moved downgradient.
The ground water analytical results from MW-12 were of
particular interest. MW-12 is located on the west side of
the unnamed stream and was not suspected to be influenced by
the source areas (lagoons) located on the east side of the
stream. Review of the hydrogeologic cross~sections for this
area indicate that cross contamination from the lagoons to
MW-12 is highly unlikely. Total Suspended Solids (TSS) in
ground water can elevate concentrations of inorganic
constituents over the true concentrations of inorganics that
are transported in the ground water. Based upon the filtered
ground water results, it was suggested that the high levels
of lead and chromium detected in MW-12 and the elevated
levels of lead in MW-03, MW-04, MW-05, MW-09 were due to the
presence of suspended solids in the ground water samples.
It was mutually agreed in January 1991 by EPA, SCDHEC and the
Golden Strip Task Group that additional studies were required
to confirm the level and extent of ground water contamination
resulting from past waste disposal practices. This .
information would be included in a Supplemental Ground Water
RI Report and utilized to determine the need for the
evaluation of a ground water response action in the
Feasibility Study for the site.
5.3.3
SUDDlemental Remedial Investiqation (SRI)
In an effort to further define the nature and extent of
ground water contamination present at the site, RMT, Inc.
conducted the SRI under the direction of the EPA. The
objectives of the SRI were to confirm the findings presented
in the RI, determine if concentrations of inorganic -
constituents in the wells were due to elevated levels of
suspended solids, and to determine if a ground water plume
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had escaped detection by the monitoring well network
installed during the initial RI. SRI field activities began
in February 1991 and concluded in mid-March 1991.
The following activities were conducted as part of the SRI:
1) Drilling and installing five additional ground water
monitoring wells (MW-09B, MW-14, MW-14A, MW-1S and
MW-1SA) downgradient from the existing monitoring wells
(Figure 2);
2) Redeveloping existing wells MW-09 and MW-12, in an
effort to reduce the suspended solids in the well; and
3) Collecting and analyzing ground water samples from the
five new wells and the existing.network of wells in the
vicinity of the lagoons to confirm previous sample
results.
During the SRI, modifications to the sampling plan for metals
were made. The modifications included the implementation of
a less violent sampling procedure. Monitoring wells were
purged and sampled using a peristaltic pump instead of the
bailer method that was utilized during the initial RI. The
intent of th~ sampling modifications was to reduce the
concentration of suspended solids previously observed in site
monitoring wells during rounds 1 and 2. In this manner, it
was possible to more thoroughly evaluate the true condition
of the GSST site ground water.
Visual inspection of the samples collected during the SRI
indicated that the peristaltic pump method does yield a
sample with much-reduced levels of suspended solids. The
analytical results obtained from this third round of ground
water sampling are, therefore, considered more indicative of
actual ground water quality. The pump sampling technique is
the preferred method for acquiring samples which are
representative of the ground water as it exists within the
aquifer. .
Analyses of ground water samples collected during the SRI
support the conclusion that past waste disposal activity
conducted at GSST has had only a limited effect on the site
ground water resources. There were no constituents detected
during the third sampling event which had not been previously
identified during rounds 1 and 2.
There were two MCL ~xceedances detected during the third
sampling event. The organic compound 1,2-dichloropropane was
again detected at 0.011 ppm in the sample collected from
MW-04 at a concentration in excess of the MCL. The MCL for
1,2-dichloropropane (0.005 ppm) was exceeded in ground water
samples collected from MW-04 during rounds 1 and .2. Only
1,2-dichloropropane has been identified at levels in excess
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of the MCL in all three sampling events. Analysis of the
third sample collected from MW-06 no longer indicated the
presence of 1,2-dichloroethane. The exceedance of the MCL
for 1,2-dichloroethane in the second round appears to be
anomalous. Chromium was the only inorganic constituent found"
at a concentration in excess of its MCL (0.100 ppm).
Chromium was detected in the sample collected from MW-06 at a
concentration of 0.118 ppm. Analytical results from samples
collected from MW-06 indicate chromium was not detected above
method detection limits in round 2 and slightly below the MCL
during round 1.
During the SRI, MW-09 and MW-12 were redeveloped and
subsequently resampled using the peristaltic pump method.
Samples collected from MW-09 and MW-12 did not contain either
chromium or lead at concentrations above detection limits.
Sampling with the peristaltic pump was apparently successful
in minimi"zing the effect of suspended solids present in the
water column on metals analyses. The absence of lead in the
ground water at MW-09 and MW-12, and the absence of chromium
at MW-12 is considered to be more representative of true
ground water quality conditions at the site than the data
obtained during the RI in which elevated levels of suspended
solids were noted in the samples. "
Lead was detected above the MCL in samples collected from
MW-03, MW-04, and MW-OS in round 1 o~ the RI. Lead was not
detected above the MCL in samples collected from these wells
in round 3 using the peristaltic pump technique. These
levels above the MCL in round 1 are attributed to high levels
of suspended solids in the ground water samples.
Ground water samples collected from the five new wells
installed during the SRI showed no indications of having been
affected by GSST past waste disposal activity. The only
organic compound detected was acetone at a concentration of
0.012 ppm in the sample collected from MW-14A. Acetone was
not detected in the associated analytical method blank and is
attributed to laboratory procedures. These ~esults are
significant since they demonstrate that a plume of ground
water constituents has not moved off-site from the area of
the lagoons and only limited effects to the ground water at
GSST have occurred. .
The results of the SRI demonstrate that there is no data to
support an assumption that a ground water plume exists and
has escaped detection by the monitoring well network
installed during the RI. The results of the SRI further
confirm the total absence of a discernible plume of waste
constituents in the ground water. Only limited exceedances
of ground water MCLs within the immediate vicinity of the
lagoon area has been confirmed during the three rounds of
ground water sampling.
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5.4
Air Monitorina
Air samples were collected to investigate the presence of
airborne particulate matter, hydrocarbons, and other potentially
hazardous compounds at the site. Air monitoring consisted of
both background sampling and on-site monitoring during field
activities.
5.4.1
Backaround Monitorina
The initial background samples were taken to characterize
routine exposure at the site prior to field activities.
Representative sample locations were selected based on the
predominant wind direction at the time of the field study. A
meteorological station was established two days prior to the
sampling event. Measurements of wind speed, wind direction,
and ambient temperature were recorded the day of sampling.
Sampling for airborne metals was conducted at five locations
across the site. A sample was collected at the upwind, the
downwind, and each of the crosswind locations. A fifth
sample was collected in the lagoon area. Samples were
analyzed for twenty metallic constituents. Aluminum was
detected in one sample, iron in three samples, and magnesium
in one sample. The concentra3ions are at or just above the
detection limit of 0.001 mg/m of air.
Air sampling for organic vapors was conducted at the upwind
and downwind locations, as well as at the lagoon area
location. Halogenated hydrocarbons were detected at
concentrations in the parts per trillion (ppt) range.
Concentrations were generally consistent upwind, downwind,
and on-site. Carbon monoxide ranged from 134 to 342 parts
per billion (ppb) with the lower concentrations on-site.
Carbon dioxide concentrations ranged from 350 to 1450 ppb
with the lower concentrations off-site. Methane
concentrations were consistent for all sample location at
approximately 2 ppm. In addition, air samples were analyzed
for 74 non-halogenated hydrocarbons. Sixteen were detected
upwind and on-site, and 23 were detected downwind.
5.4.2
On-Site Air Monitorinq
On-site air monitoring was conducted routinely during
subsurface activities and other activities that were judged
by on-site personnel as having the potential to encounter
sources of organic gases or vapors. The personal hydrogen
cyanide monitors were also worn by site personnel during
subsurface activities.
During monitoring activities, organic vapor and HCN
concentrations were measured at less than the established
action levels for the majority of site work. However, during
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drilling of soil boring SB-8A, an unidentified odor was
detected at the drilling location. None of the monitoring
instruments responded to this odor. Because of the unknown
nature of the odor, work was stopped and restarted using
Level B personal protective equipment (Self Contained
Breathing Apparatus). Additional air monitoring was
conducted the following day using a personal sampling pump
and charcoal sampling media. Toluene was detected at less
that 1 ppm along with trace amounts of petroleum distillate.
The odor was not noted on the day sampling occurred.
Following receipt of sample results, work in Level B personal
protective equipment was discontinued.
5.5
Nature and Extent of Contamination
The following discussion is a summary of the nature and extent
of wastes and affected media at the Golden Strip Septic Tank
site.
- A Constituents of Concern (COC) list for the site has been
developed for purposes of the Baseline Risk Assessment
discussed in Section 6.0 - Summary of Site Risks and are to
be addressed through the selected remedy in this ROD. This
list includes those constituents that are related to the
lagoon operations, as indicated by the composition of the
waste, or have been detected repeatedly throughout the
site. Thirteen inorganic constituents that are apparently
not waste-related have been discussed at the beginning of
this section and were deleted from the COC list. The COC
list is as follows:
INORGANICS
ORGANICS
antimony
arsenic
cadmium
chromium
copper
lead
mercury
nickel
zinc
cyanide
acetone
bis(2-ethylhexyl)phthalate
2-butanone (a.k.a. methyl
ethyl ketone)
chlorobenzene
chloroform
1,2-dichloroethane
1,2-dichloroethene
1,2-dichloropropane
ethylbenzene
methylene chloride
styrene
tetrachloroethene
toluene
l,l,l-trichloroethane
xylenes .
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- Lagoon sludges and surface soils within the immediate
vicinity of the open and closed lagoons have been affected
by past waste disposal activities. Sludges and sediments
in the lagoons contain metal and cyanide concentrations
ranging from below observed site background levels to
substantially above site background conditions. Low
concentrations of several volatile and semi-volatile
organic compounds were also detected in the sludge and
sediments.
- Additional analyses of the lagoon waste and affected soil
demonstrated that it exhibits hazardous characteristics for
cadmium as determined by TCLP analysis.
- Surface soils in the suspected truck
near a drainage swale west of Lagoon
affected to a limited degree by past
practices.
turnaround area and
Nos. 3 and 4 have been
waste disposal
- A small area on the eastern side of the Rice Farm was
identified to contain 27 abandoned drums. Investigations
indicated that this area has been affected to a limited
degree by past waste disposal activities.
- Surface water contained in open Lagoon Nos. 1 and 4 has
been affected by past waste disposal activities The
quality of the surface water impounded in Lagoons 1 and 4
was found to exceed the Safe Drinking Water Act primary
standards established for cadmium (0.005 ppm) and chromium
(0.100 ppm). The highest observed levels of cadmium and
chromium were 0.08 ppm and 0.5 ppm, respectively.
Secondary drinking water standards for iron (0.3 ppm) and
manganese (0.05 ppm) were also exceeded at concentrations
of 11.5 ppm and 0.44 ppm, respectively.
- The unnamed stream that passes through the site has not
been affected. Analysis of water and sediment samples from
the stream show no indications of elevated levels of COCs
identified during the RI.. .
- Agricultural activities were conducted beyond the northern,
eastern, and southern boundaries of the active waste
disposal areas. These areas were sampled because aerial
photographs taken at GSST during the time of active site
operations showed these fields to be under cultivation,
raising the question of the potential for land farming
wastes. Analytical results from soil samples collected in
previously cultivated areas of the GSST site showed no
indications of elevated levels of COCs related to past
waste disposal activities to the north and south of the
lagoon areas. . .
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- Analytical results from three rounds of ground water
sampling indicate that ground water has been affected to a
limited extent by past waste disposal practices. Lead,
chromium, 1,2-dichloropropane, and 1,2-dichloroethane
exceeded promulgated Safe Drinking Water Act MCLs.
However, there is no apparent pattern of constituent
presence or concentration in the ground water analyses.
Based upon the ground water studies conducted to date,
Alternate Concentration Limits for the observed,
intermittent MCL exceedances will be established. In
addition, a long-term monitoring program .will be
established as part of this ROD to monitor the
concentrations of these constituents during implementation
of the selected source remedy contained in Section 9.0 of
this ROD. This comprehensive environmental monitoring
program will also ensure the selected remedy is effectively
immobilizing the identified waste and remains protective of
human health and the environment.
- Background and on-site air sampling indicates that local
ambient air has not been affected by past waste disposal
activities.
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6.0
SUMMARY OF SITE RISKS
A Baseline Risk Assessment was conducted as part of the Remedial
Investigation to assess the potential effect on public health and
welfare from the GSST waste constituents of concern that were.
identified during the investigation. The Baseline Risk
Assessment can be found in its entirety in Section 5 of the Final
Remedial Investigation Report. This section of the Record of
Decision presents a summary of site risks and consists of the
following sections: contaminant identification, exposure
assessment, toxicity assessment, risk characterization, and
environmental (ecological) assessment. Due. to the volume of
tables included in this section, the text is presented first and
is then followed by the referenced tables in an effort to
increase the readability of this section. .
6.1
Contaminant Identification
At the Golden Strip Septic Tank site the following media were
assessed for contamination: ground water, soil (surface and
subsurface), surface water (in lagoon and in stream), and lagoon
sludge.
For each contaminant of concern in a given medium, an exposure
point concentration was determined by calculating the statistical
upper confidence limit (UCL) of the sample results. If too few
data were available to calculate a UCL, the maximum detected
value was used as the exposure point concentration. Exposure
point concentrations are shown for each medium in Table.5.
6.2
EXDosure Assessment
Currently the site is enclosed by a secured fence. Individuals,
from residential areas to the north, east and west could trespass
onto the site. Because of the land use of the surrounding area,
it is feasible that in the future the site could become
residential or recreational. To quantify potential exposure, the
following current and future land use scenarios were developed:
6.2.1
Current Land Use
Assumes that a 6-12 year old child trespasses onto the site
180 days per year for 6 years. The child's average body weight
is 30 kg. Exposure occurs via dermal contact with an
incidental ingestion of the surface soil, dermal contact with
stream water/sediments and lagoon water/sludges, and ingestion
of lagoon surface water.
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6.2.2
Future Land Use
1) Assumes the site is developed into a public park. Exposure
to the site occurs via the same pathways as in the current use
scenario to an adult and to a child. The exposed child was
assumed to be aged 1-10, weigh an average of 22 kg, and to
visit the site 180 days per year for 9 years. The adult was
"assumed to weigh 70 kg and visit the site 180 days per year
for 30 years.
2) Assumes residential development on the site. Exposure is
assumed to occur to an adult and a child via all the pathways
listed for scenario #1, but with daily exposure. Additionally
this scenario included daily ingestion of on-site ground
water.
6.3
Toxicitv Assessment
Under current EPA guidelines, the likelihood of adverse effects
to occur in humans from carcinogens and noncarcinogens are
considered separately. These "are discussed below.
6.3.1
Carcinoqens
EPA uses a weight-of-evidence system to classify a chemical's
potential to cause cancer in humans. All evaluated chemicals
fall into one of the following categories: Class A- Known
Human Carcinogen; Class B- Probable Human Carcinogen- Bl means
there is limited" human "epidemiological evidence, and B2 means
there is sufficient evidence in animals and inadequate or no
evidence in humans; Class C- Possible Human Carcinogen; Class
D- Not classifiable as to Human Carcinogenicity; and Class E
-Evidence of noncarcinogenicity for Humans.
,
Cancer Slope Factors (SFs), indicative of carcinogenic
potency, are developed by EPA's Carcinogenic Assessment Group
to estimate excess lifetime cancer risks associated with"
exposure to potentially carcinogenic chemicals. SFs are
derived from the results" of human epidemiological studies or
chronic animal bioassays to which animal-to-human
extrapolation and uncertainty factors have bIen applied. SFs,
which are expressed in units of (mg/kg-day)- , are
multiplied by the estimated intake of a potential carcinogen
to provide an upper-bound estimate of the excess lifetime
cancer risk associated with exposure at that intake level. The
term "upper-bound" refers to the conservative estimate of the
risks calculated from the SF. This approach makes
underestimation of the actual cancer risk highly unlikely.
Table 6 lists all carcinogenic contaminants of concern along
with respective cancer classifications and slope factors.
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6.3.2
Noncarcinoaens
Reference Doses (RfDs) have been developed by EPA for
indicating the potential for adverse health effects other than
cancer. RfDs, which are expressed in units of mg/kd-day, are
estimates of chronic daily exposure for humans, including
sensitive individuals, that are thought to be free of any
adverse effects. RfDs are derived from human epidemiological
data or extrapolated from animal studies to which uncertainty
. factors have been applied. These uncertainty factors help
ensure. that the RfDs will not underestimate the potential for
adverse noncarcinogenic effects to occur. Estimated intake of
chemicals from environmental media can be compared to the RfD
for each of the contaminants.
Table 7 lists all contaminants of concern with their
respective RfDs.
6.4
Risk Characterization Summary
Excess lifetime cancer risks are determined by multiplying the
chronic daily intake (CDI) by the slope factor. These risks are
probabilities shat are generally expressed in scientific no~ation
(e.g., 1 x 10- or 1E-06). An excess lifetime cancer risk of
1E-06 indicates that, as an upperbound estimate, an individual
has a one in on~ million chance of developing cancer in his/her
lifetime as a result of exposure to a site related carcinogen
under the specific exposure conditions at a site.
The potential for noncarcinogenic effects from a single
contaminant in a single medium is expressed as a hazard quotient
(HO). The HO is the ratio of the estimated human intake to the
RfD for a particular contaminant. By adding the HOs for all
contaminants within a medium and then across all media to which a
given population may reasonably be exposed, the Hazard Index (HI)
can be generated. The HI provides a useful reference point for
assessing the potential significance of exposure to multiple
contaminants across multiple media.
The resultant risks and HI for the current land use-trespasser
scenario are shown, by pathway. and medium, in Tables 8 and 9,
respectively. The total risk for. this scenario is 2.3E-OS (2.3 in
100,000). The HI for this scenario is 8.2. .
The risks and HI for the future land use-park scenario are shown,
by pathway and medium, in Tables 10 and 11, respectively. The
total risk for this scenario is 9.3E-OS (9.3 in 100,000) and the
HI is 10.0.
The risks and the HI for the future land use-residential scenario
are shown, by pathway and medium, in Tables 12 and 13,
respectively. The total risk for this scenario is 1.8E-04 (1.8 in
10,000) and the HI is 20.0.
The pathway and total risks and HIs are shown in Table 14 for
each scenario.
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EPA's targeted risk range for cleanup of Superfund Sites is lE-04
to lE-06. Risks less than lE-06 are deemed acceptable and those
greater than lE-04 are unacceptable to EPA. Risks that fall
between lE-04 and lE-06 mayor may not warrant action, depending
on site-specific factors considered by the risk manager. .
Noncarcinogenic HI values greater than 1.0 indicate that remedial
action should be taken.
While the estimated risk for the current use scenario is within
the target risk range, the estimated risk from the two future use
scenarios are both approximately equal to the cutoff risk level
of 1E-04 (one in 10,000). Therefore remedial action should be
considered based on potential carcinogenic risks to future
populations. Exposure to arsenic in the soil and in the lagoon
sludge contributed significantly to this risk, with organic
contaminants in ground water contributing somewhat less
significantly.
The acceptable HI value of 1.0 is exceeded in the current land
use scenario, and more notably exceeded in each of the two future
land use scenarios. Therefore potential noncarcinogenic adverse
effects to exposed populations are indicated if no remedial
action is taken at the GSST site. The largest contribution to
the HI is from exposure to excessive metals (especially cadmium
and antimony) in the lagoon sludge and soil.
The risk assessment process contains inherent uncertainties.
Exposure parameters such as frequency and duration of exposure
and ingestion rate of contaminated media can vary between
individuals. Therefore, upperbound values were used to estimate
exposure, in order to be more protective of human health. Slope
factors and Reference Doses each involve extrapolation to which
conservative uncertainty factors are added in order to be
protective of sensitive humans. Some additional sources of
uncertainty in the GSST risk assessment include:
- Lack of quantification of hazard/risk fro~ exposure to lead
may underestimate the true risk; though no SF or RfD is
verified for lead, EPA has. established cleanup goals for
. lead in both ground water (0.015mg/L) and soil (500 mg/kg)
at Superfund sites.
- Level of each valence form of chromium in environmental
media at the GSST site. In addition to being a class A
carcinogen by the inhalation route of exposure, hexavalent
chromium [Cr(VI)] is estimated to exhibit noncarcinogenic
effects via the oral route at a 200-fold lower dose than the
trivalent form. Since quanti~ication of Cr(VI) is difficult
to verify in soil samples, a percentage of the total Cr was
assumed to be Cr(VI), in order to be conservative. This
uncertainty could over- or underestimate the true risk at
the site.
- Conservative assumptions were used to estimate exposure to
unexposed lagoon wastes. This may overestimate the true
risk.
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6.5
Environmental lEcoloqical\ Risks
Features at the site including a small stream, two lagoons,
wooded areas, and open fields provide a variety of ecological
habitats. No unique or sensitive habitats were identified at the
site, and no vegetative stress is evident.
To determine whether the site may have adverse effects on
environmental receptors, the exposure values were compared to
experimentally derived No Observed Adverse Effect Levels (NOAEL)
or Lowest Observed Adverse Effect Levels (LOAEL) in EPA's
toxicity database. This comparison, shown in Table 15, indicated
that inorganic (metal) contaminants in the lagoon water and in
the soil could have potential adverse impact on wildlife at the
site.
Based upon the information contained in the Baseline Risk
Assessment and summarized in this section, actual or threatened
releases of hazardous substances from this site, if not addressed
by implementing the response action selected in this Record of .
Decision, may present an imminent and substantial endangerment to
public health, welfare, or, the environment.
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TABLE 5
CONST1TUENTS OF CONCERN
COMPlETED PATHWAYS AND EXPOSURE CONCENTRATIONS:
CURRENT AND FUTURE LAND USE
Exposure
Populatlons!PathwaY8 Concentration CommentIBasls
Ingestion of Surface Soli and Dermal Contact with Surface 5011
Acetone 0.011 mg/kg 95 percent upper confidence limit 181
Ethylbenzene 0.023 Only detected in one sample (S-17)
Styrenelb] 0.008 95 percent upper confidence limit
Tetrachloroethene 0.069 95 percent upper confidence limit
TOluenelD] 0.023. 95 percent upper confidence limit
1,1,1- Trichloroethane 0.023 95 percent upper confidence limit
Xyleneslb] 0.029 95 percent upper confidence limit
-.
Bis (2-ethylhexyQ phthalate 2.61 95 percent upper confidence limit
Antimony 97.1 95 percent upper confidence limit
ArseniclDI 9.07 95 percent upper confidence limit
Cadmium 48.8 95 percent upper confidence limit
Chromium (totaQ 1,012 95 percent upper confidence limit
Copper 737 95 percent upper confidence limit
Cyanide[DI 31.4 95 percent upper confidence limit
Lead 126 . 95 percent upper confidence limit
,
Mercury[D] . 0.969 95 percent upper confidence limit
Nickel 47.8 . 95 percent upper confidence limit
Zinc 952 95 percent upper confidence limit
181 95% CL determined using log-probil analyaia.
(b] Skin absorption hazard
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TABLE 5
GSST CONSTITUENTS OF CONCERN
COMPlETED PATHWAYS AND EXPOSURE CONCENTRATIONS:
CURRENT AND FUTURE LAND USE (Con't)
Exposure
Populatlons/Pathweys Concentration Comment/Basls
Dermal Contact with Waste In Lagoon Bottoms
Acetone 0.5 mgfkg Maximum concentration detected in
lagoon waste.
Bis (2-ethylhexyQ phthalate 42 Maximum concentration detected in
. lagoon waste.
2-Butanone 0.16 Maximum concentration detected in
lagoon waste.
Chlorobenzene 38 Maximum concentration detected in
lagoon waste.
1,2-Dichloroethenes 0.043 Maximum concentration detected in
(totaQ lagoon waste.
Etnylbenzene 1.9 Maximum concentration detected in
lagoon waste.
Methylene chloride 0.056 Maximum concentration detected in
lagoon waste.
Styrene 0.19 Maximum concentration detected in
lagoon waste.
Tetrachloroethene 0.21 Maximum concentration detected in
lagoon waste.
Toluene 3.7 . Maximum.concentration detected in
lagoon waste.
Xylenes , 11 Maximum concentration detected in
la900n waste.
Antimony 1940 Maximum concentration detected in
lagoon waste.
Arsenic 23.6 Maximum concentration detected in
lagoon waste.
Cadmium 12,000 Maximum concentration detected in
lagoon waste.
Chromium (totaQ 97,200 Maximum concentration detected in
lagoon waste.
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- TABLE 5
GSST CONSTITUENTS OF CONCERN
COMPLETED PATHWAYS AND EXPOSURE CONCENTRATIONS:
CURRENT AND FUTURE LAND USE (Con't)
Exposure
Populatlons/Pathways ConcentratIon Comment/Basls
Dermal Contact with Waste In Lagoon Bottoms (Cont.)
Copper 69,900 Maximum concentration detected in
lagoon waste.
Cyanide. 4,520 Maximum concentration detected in
lagoon waste.
Lead 1900 Maximum concentration detected in
lagoon waste.
Mercury 13.8 Maximum concentration detected in
lagoon waste.
Nickel 6140 Maximum concentration detected in
lagoon waste.
Zinc 77,600 Maximum concentration detected in
lagoon waste.
Ingestion of Surface Water In Open Lagoons
Acetone 0.011 mg/l . Maximum concentration detected in
lagoon surface water.
Cadmium 0.078 Maximum concentration detected in -
lagoon surface water.
Chromium (totaQ 0.498 Maximum concentration detected in
lagoon surface water.
Copper 1.10 Maximum concentration detected in
\ lagoon surface water.
Lead 0.006 Maximum concentration detected in
lagoon surface water.
Zinc 2.68 Maximum concentration detected in
I lagoon surface water.
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. TABLE 5
GSST CONSTITUENTS OF CONCERN
COMPLETED PATHWAYS AND EXPOSURE CONCENTRATIONS:
CURRENT AND FUTURE LAND USE (Con't)
Exposure
PopulationsfPathways Concentration Comment/Basls
Dermal Contact with Sediments In Unnamed Tributary
Acetone 0.098 mg/kg Only detected In one sample (SS-1)
Toluene 0.22 Only detected in one sample (5S-1)
Chromium (totaQ 1,19 Maximum concentration (5S-1)
Copper 8.6 Only detected in one sample (SS-2)
Lead 8.0 Maximum concentration (SS-1)
Mercury 0.14 Only detected in one sample (5S-4)
Zinc 64.9 Maximum concentration (55-1)
Ground Water Pathway/Ingestion Route by Residents (Future land use. Maximum
exposure only)
Acetone 0.015 mg/l 95 percent upper confidence limit
Chloroform 0.040 Only detected in one sample (MW-9A)
1,2-Dichloroethane 0.005 95 percent upper confidence limit
1 ,2-Dichloroethenes 0.008 95 percent upper confidence limit .
1 ,2-Dichloropropane 0.013 95 percent upper confidence limit
Methylene Chloride 0.016 95 percent upper confidence limit -
1,1,1-Trichloroethane 0.013 Only detected in one sample (MW-5)
Xylenes 0.019 95 percent upper confidence limit
Bis(2-ethylhexyQ phthalate 0.031 95 percent upper confidence limit
Cadmium 0.005 Only detected in one sample (MW.13)
Chromium (totaQ 0.072 95 percent upper confidence limit.
Copper 0.047 95 percent upper confidence Umit
Lead 0.021 95 percent upper confidence limit
Nickel 0.116 95 percent upper confidence limit
Zinc 0.128 95 percent upper confidence limit
SOURCE: RMT, INC. 1991
. .
-53-
-------
TABLE 6
CONSTITUENTS OF CONCERN
TOXICITY VAlUES: POTENTIAl CARCINOGENIC EFFECTS
SLOPE FACTOR SLOPE
(SF) Woer&! FACTOR
CHEMICAL (mglkg-day) - 1 CLASS TYPE OF CANCER SOURCE
ORAL
Arsenic 1.75[b) A skin cancer IRIS
Lead NA Ic.dI B2 kidney IRIS
Bis(2-ethylhexyQ phthaJate 0.014 B2 hepatocellular carcinoma IRIS
Chloroform .0061 B2 kidney IRIS
1,2-Dichloroethane 0.091 B2 various IRIS
1,2-Dichloropropane 0.068 B2 liver HEAST
Methylene Chloride 0.0075 B2 hepatocellular carcinoma IRIS
Styrene 0.03 B2 lung and bronchi HEAST
Tetrachloroethene 0.051 B2 liver HEAST
INHALATION
Arsenic 50 A lung cancer HEAST
Cadmium 6.1 B1 lung cancer HEAST
Chloroform .081 B2 hepatocellular carcinoma IRIS
Chromium VI 41 A lung cancer HEAST
1,2-Dichloroethane 0.091 B2 - - IRIS
Methylene Chloride .014 B2 lung, liver IRIS
Nickel Dust \ 0.84 A lung/nasal cancer HEAST
Styrene 0.002 . B2 leukemia HEAST
Tetrachloroethene 0.0033 B2 leukemia, liver HEAST
IaI
Weight of Evidence
[b)
The .Iope factor wu calculated from the unit risk reported in IRIS u 5 x 10-5/p;!l assuming 2Uday ingestion by .
70 kg adult.
(c)
Not Available
lei)
IRIS indicate. that . numerical estimate of potential carcinogenicity risk not be uaed for ".d.
SOURCE: RMT, INC. 1991
-54-
-------
TABLE 7
CONSTITUENTS OF CONCERN
TOXICITY VALUES: POTENTIAL NON CARCINOGENIC EFFECTS
- I
CHRONIC
RIO CONFIDENCE. CRITICAL RID UNCERTAINTY MODIFYING
CHEMICAL (mn/k~J.d[lY) LEVEL EFFECT SOURCE FACTOR FACTOR
Or81 Roule
Acelone 0.1 low liver ellects, IRIS 1000 1
NephrotOlcicity
Chlorobenzene 0.02 Medium liver elleels IRIS 1000 1
Chlorolorm 0.01 Medium liver effects IRIS 1000 1
1,2.Dichloroelhethene (cis) 0.01 low Clinical chemislry IRIS 1000 1
Elhylbenzene 0.1 low liver and kidney IRIS 1000 1
loxlcity
Methylene Chloride 0.00 Medium Liver lox Icily IRIS 100 1
Melhyl ethyl ketone (2-butanone) 0.05 Medium None IRIS 1000 1
Slyrene 0.2 Medium Red blood cell effects IRIS 1000 1
and liver effects
T elrachloroelhylene 0.01 Medium liver loxicily IRIS 1000. 1
(T etrachloroelhene)
Toluene 0.2 Medium Clinical chemlslry and IRIS 1000 1
hematological
paramelers
1,1,1 Trichloroethane 0.09 Medium Growth relardation IRIS 10()0 1
Xylenes 2 Medium Hyperactivity, deer. IRIS 100 1
body M., Incr. mortality
Bls(2-elhylhexyl)phlhalate 0.02 Medium Increased liver weight IRIS 1000 1
I
an
an
I
-------
TABLE 7
CONSTITUENTS OF CONCERN
TOXICITY VALUES: P01ENTIAL NON-CARCINOGENIC EFFECTS (Con'l)
CHrtONIC
RIO CONFIDENCE II CRITICAL RID UNCERTAINTY MODIFYING
CHEMICAL (lI1fJ/k! ,.day) 1.EVEL EFFECT SOURCE FACTOR FACTOR
AI \timony . U.0004 Luw Longevity, tJlood IRIS 1000 1
glucose, and
choleslerol
Arsenic 0.001 Keralosis and HEAST 1 -
hypelpigmenlalion
Cadmium 0.0005 High Signilicanl amounls of IRIS 10 1
(waler) prolein in urine
0.001 (Iood) IRIS 10 1
Chromium III 1 (as low None IRIS ' 100 10
Insoluble
sail)
Chromium VI 0.005 low None IRIS 500 1
Copper 1.3 mg/L (Drinking waler siandard) As reported in HEAST, the drinking water criteria document
concluded toxicity data were inadequate 10 calculate an RID for copper.
Cyanide 0.02 Medium Weight loss, thyroid IRIS 100 5
. ellects, degeneration of
myelin
Lead (Inorganic) , As reported in IRIS, the EPA has determined that It Is Inappropriate to develop an RfD for inorganic
lead.
Mercury (inorganic) 0.00U3 - Cenlral nervous system HEAST 1000 -
ellects
Nickel (soluble Salls) 0.02 Medium Decreased body and IRIS 100 3
organ weights
Zinc 0.2 - Anemia HEAST 10 -
I
\0
LO
,
-------
TABLE 7
CONSTITUENTS OF CONCERN
TOXICITY VALUES: POIENTlAL NON-CARCINOGENIC EFFECTS (Con")
CHRONIC j
nlD CONFIDENCE J CRITICAL RIO UNCERTAINTY MODIFYING
CHEMICAL (1I1!J/k!J-rlav) LEVEl EFFECT SOURCE FACTOR FACTOR
Inhol8110n Route
Melhylene Chloritlo 3 . .--- liver toxicity HEAST 100 -
Chromium III 5.7 x 10' ---. Nasal mucosa atrophy HEAST 300 -
Chromium IV 5.7 x 10' -- Nasal mucosa atrophy HEAST 300 -
SOURCE: RMT, INC, 1991
I
r-
&1'1
I
-------
TABLE 8,
ESTIMATED EXCESS UPPER BOUND UFETIME CANCER RISKS FOR CURRENT LAND USE
~ Chemical
CDI Slope Factor Weight of Slope Factor Specific Pathway
Chemical (mglkg-day) (mg/kg-dayrl Evidence Source Risk Risk Total Risk
Exp08ure Pathway: IngosUon or surface soli.
Bis(2-ethylhexyl) 1.0 x 10" 1.4 X 10.2 02 IRIS 2.5 x 10"
phlhalale
Arsenic 6.3 x 10" 1.75 x 100 A IRIS 1.1 x 10.
Chromium VI 1.3 x 10. 4.1 x 101 . A HEAST 5.3 x 10"181
Styrene 5.5 X 10.10 3.0 X 10-2 B2 HEAST 1.7 X 10.11
Tetrachloroethene 4.8 x 10" 5.1 X 10'2 B2 HEAST 2.4 x 10.10
1.2 X 10.lbl
Exposure Pathway: Dermal contact with surface 0011.
Tetrachloroelhene 1.3 x 10" 5.1 X 10-2 B2 HEAST 1.3 x 10'"
Bis(2.e'hylhexyl) 5.1 x 10" 1.4 X 10-2 82 IRIS 1.0 x 10"
phlhalale
Arsenic 3.3 x 10. 1.75 x 100 A IRIS 5.8 x 10"
Styrene 2.3 x 10-' 3.0 x 10-2 B2 HEAST 6.9 x 10'"
5.8 x 10"
I
co
U1
I
-------
TABLE 8
ESTIMATED EXCESS UPPER BOUND UFETIME CANCER RI.SKS FOR CURRENT LAND USE (Cont.)
, Chemical
CDI Slope Factor Weight o' Slope Factor Specific Pathway
Chemical (mg/kg.day) (mg/kg.dayrl Evidence Source Risk Risk Total Risk
Exposure Pathway: Dermal contact with waste In 18900n bottoms.
Tetrachloroethene 5.6 x 10" 5.1 X 10.2 B2 HEAST 5.6 x 10.11
Bis(2-ethylhexyl) 1.1 x 10" 1.4 X 10.2 B2 IRIS 2.2 x 10"
phthalate
Methylene Chloride 1.5 x 10" 7.5 X 10-3 B2 IRIS 9.0 x 10.11
Arsonic 9.4 x 10. 1.75 x 1tf A IRIS 1.6 x 10"
Styrene 7.6 x 10" 3.0 X 10.2 B2 HEAST 2.3 X 10"
1.6 x 10"
Trespasser 8t site. Total Risk: 2.3 x 10"
I
0\
Il'I
I
18. C
01 end rI,k lor Chromium VI ere for Inhtletlon of lullec. .0U. ullng chromium Inhelttlon model provided by US EPA (I" Appendix ij.
Ibl Inc:lude. ,Ilk due 1o Inhlledon of Ch,omlum VI.
SOURCE: RMT,INC.1991
-------
Chemical COI RID Uncerlainly RID Hazard Palhway TOlal
(mg/kg-day) (mg/kg-day) Faclor Source quotient HI HI
Exposure Pathway: Ingesllon of surface Boll.
Acetone 0.9 x 10" 1 x 10" 1000 IRIS 8.9 x 10"
Ethylbenzene 1.9 x 10. 1 x 10" 1000 IRIS 1.9 x 10.7
Styrene 6.5 x 10" 2 x 10" 100 IRIS 3.3 x 10"
Tetrachloroethene 5.6 x 10" 1 x 10'2 1000 IRIS 5.6 x 10"
Toluene 1:9 x 10" 2x 10" 100 IRIS 9.3 x 10"
1.1.1-TrICfhloroethane 1.9 x 10" 9 X 10.2 1000 IRIS 2. 1 x 10.7
Xylenes 2.3 x 10. 2 x 10° 100 IRIS 1.2 x 10"
Bls(2-ethylhexyQ 2.1 x 10" 2 X 10'2 1000 IRIS 1.1 x 10"
phthalates
Antimony 7.0 x 10.11 4 x 10" 1000 IRIS 2.0 x 10"
Arsenic 7.3 x 10" 1 x 10'~ 1 HEAST 7.3 x 10~
Cadmium 4.0 x 10'5 1 x lO'~ 10 IRIS '4.0 x 10.2
Chromium III 7.4 x 10" 1 x 100 100 IRIS 2.5 x 10'''8'
Chromium VI 0.2 x 10'5 5 x lO'~ 500 IRIS 4.4 x 10'218'
Cyanide 5.1 x 10.5 ,2 X 10'2 100 IRIS 2.6 x 10'~
Mercury 7.0 x 10.7 3 x 10" 10 HEAST 2.6 x 10'~
Nickel 3.9 x 10-11 2 X 10'2 100 IRIS ,1.9 x 10~
Zinc 7.7 x 10" 2 X 10" 10 HEAST 3.9 x 10~
5.5 x 10.llb'
TABLE 9
NONCARCINOGENIC HAZARD INDEX ESTIMATES FOR CURRENT LAND USE
' J
I
o
\D
I
-------
TABLE 9
NONCARCINOGENIC HAZARD INDEX ESTIMATES FOR CURRENT LAND USE (cont'd)
, I
Chemical CDI RID Unceltainty RID Hazard Pathway Total
(mg/ku.(jay) (lOg/kg-day) Factor Source quotient HI HI
Exposure Pathway: Dermal contact with surface 6011.
Acetone 2.5 x 108 1 X 10" 1000 IRIS 2.5 x 10"
Ethylbenzene 5.2 x 10'8 1 X 10" '1000 IRIS 5.2 x 10"
T otrachloroethene 1.6 x 101 1 X 10'2 1000 IRIS 1.6 x 10"
1,1,1- Trichloroethane 5.2 x 108 9 x 102 1000 IRIS 5.8 x 10"
Bis(2-othylhexyl) 5.9 x 10" 2 X 102 1000 IRIS 2.9 x 10-11
phthalate
Styrene 2.7 x 10' 2x 10" 100 IRIS 1.4 x 10"
Toluene 7.0 x 10" 3 X 10" 100 IRIS 3.9 x 10"
Xylenes 9.0 x 10" 2 x 10" 100 IRIS 4.9 x 10"
Arsenic 3.1 X,lO'lI 1 x 10.3 1 HEAST 3.1 x 10-2
Antimony 2.2 x 10'11 4 x 10" 1000 IRIS 5.5 x 10-2
Cadmium 1.1 x 10.11 1 x 10-3 10 IRIS 1.1 x 10-2
Chromium III 2.1 x 10.4 1 x 1d' 100 IRIS 2.1 x 10"
Chromium VI 2.3 x 10,11 5 x 10'3 500 IRIS 4.6 x 10-3
Cyanide 1.1 x 10" 2 X 10'2 100 IRIS 5.5 x 10-3
Mercury 3.3 x 10. 3 x 10" 10 HEAST 1.1 x 10.2
Nickel 1.1 x 10'11 2 X 10'2 100 IRIS 5.4 x 10"
Zinc 2.2 x 10" 2 X 10" 10 HEAST 1.1 x 10-3
1.2 X 10"
I
.-4
\D
I
-------
TABLE 9
NONCARCINOGENIC HAZARD INDEX ESTIMATES FOR CURRENT lAND USE (cont'd)
Chemical COI RID Uncertainty RID Hazard Pathway Total
(mg/ky-day) (mg/kg-day) Factor Source quotient HI HI
Exposure Pathway: Dermal c.ontoct with waste In lagoon bottoms.
Acetone 1.6 x 1U' 1 X 10-' 1000 IRIS 1.6 x 10"
Ethylbenzene 5.9 x 10" 1 X 10" 1000 IRIS 5.9 x 10"
Tetrachloroethene 6.5 x 10" 1 X 10.2 1000 IRIS 6.5 x 10"
Chlorobenzene 1.2 x 10.' 2 x 102 .1000 IRIS 5.9 X 10"
Bis(2-ethylhexyQ 1.3 x 10.D 2 x 10'2 1000 IRIS 6.6 x 10"
phthalate
Methylene Chloride 1.7 x 10.1 6 x 10-2 _100 IRIS 2.9 x 10"
1 ,2-Dichloroethenes 1.3 x 10" 1 x 10-2 1000 IRIS 1.3 x 10"
(totaQ
2-Butanone 5.0 x 10. 5 X 10.2 1000 IRIS 1.0 x 10"
Styrene 0.9 x 10" 2 X 10" 100 IRIS 4.5 x 10"
Toluene 1.7 x 10-1 3 X 10" 100 IRIS 5.7 x 10-1
Xylenes 5.1 x 10-' 2xlO0 100 IRIS 2.6 x 10"'
Arsenic 1.1 x 10" 1 x 10~ 1 HEAST 1.1 x 10"
Antimony 6.0 x 10" 4 x 10" 1000 IRIS 1.5 x 10-0
Cadmium 3.7 x 10-3 1 x 10-3 10 IRIS 3.7 x 100
Chromium III 2.7 x 10.2 1 x 100 100 IRIS 2.7 x 10'2
Chromium VI 3.0 x 10-3 5 x 1 O~ 500 IRIS 6.1 x 10"
Cyanide 2.1 x 10.2 2 X 10.2 100 IRIS 1.1 x 10°
Mercury 6.4 x 10'5 3 x 10" 10 HEAST 2.1 x 10"
Nickel 1.9 x 10-3 2 X 10.2 100 IRIS 9.6 )( 1002
Zinc 2.4 x 10.2 2x 10" 10 HEAST 1.2 x 10" .
7.5 x 100
I
N
\D
I
-------
TABLE 9
NONCARCINOGENIC HAZARD INDEX ESTIMATES FOR CURRENT LAND USE (cont'd)
Chemical CDI RID Uncertainty RID Hazard Pathway Total
(my/kg-day) (mg/kg-day) Factor Source quotient HI HI
Exp08ure Palhway: II1ge8110n 0' surface water In open lagoon8 while 8wlmmlng.
Acetone 7.7 x 10. 1 X 10" 1000 IRIS 7.7 x 10"
Cadmium 6.5 x 10"' 1 x 10.3 10 IRIS 6.5 x 10.2
Chromium 1\1 3.2 x 10-4 1 x 100 100 IRIS 3.2 K 10"
Chromium VI 3.5 x 10"' 5 X 10.3 500 IRIS 7.0 x 104
Zinc 1.9 x 104 2 X 10" 10 HEAST 9.5 x 10-3
7.2 X 10.2
Exp08ure Palhway: Dermal conlact with 8edlmenl8 In unnamed Irlbutary.
Toluene 1.5 x 10" 3 x 10" 100 IRIS 5.0 x 10"
Acetone 4.6 K 10"' 1 x 10" 1000 IRIS 4.6 x 10"
Chromium III 5.0 x 10. 1 x 100 100 IRIS 5.0 x 10"
Chromium VI 5.6 x 10"' 5 X 10.3 500 IRIS 1.1 x 10"
Mercury 9.0 x 10" 3 x 10.4 10 HEAST 3.3 x 10"
Zinc 3.0 x 10' 2x 10"' 10 HEAST 1.5 x 10"
4.6 X 10"
Tre8paBler: Tolal Chronic Hazard Index. 8.2 J( 10'
I
,...,
\D
I
I-I
Hazard quotient Include. Inhllollon o' chromium In ,urfoce loll using chromium Inhal.Uon model provided bV US EPA (,e. AppendlK L)
~ .
Hazlrd Index Includ.. Inh.lallon o' Chromium III and Chromium VI In lurlaco loll.
SOURCE: RMT.INC.1991
-------
. TABLE 10
ESTIMATED EXCESS UPPER BOUND CANCER RISKS FOR
FUTURE LAND USE - PAF.l~ SCENARIO'
CD! SLOPE FACTOR WEIGHT OF SLOPE FACTOR CHEMICAL PATHWAY TOTAL
CHEMICAL (mg/kg-doy) ("!g/kg-doyr' EVIDENCE SOURCE SPECIFIC RISK RISK RISK
Exposure Pathway: Ingesllon or 8urface 8011 by park visitors
Bis(2-ethylhexyl)phthalate 2.0 x 10" 1.4 X 10.2 82 IRIS 2.8 x 10"
Arsenic 6.9 x 10" 1.75 x 10" A IRIS 1.2 x 10"
Chromium VI 2.9 x 10" 4.1 )( 101 A HEAST 1.2 x 10"lat
Styrene 6.0 x 10'10 3.0 X 10'1 82 HEAST 1.8 x 10'"
Tetrachloroethane 5.2 x 10" 5.1 X 10'2 82 HEAST 2.7 x 10.,0
1.3 x 10"'bl
Exposure Pathway: Dermal contact with eurface eoll bv park vlsllore
Tetrachloroethane 5.7 x 10" 5.1 X 10'2 82 HEAST 2.9 x 10.10
Bis(2-athylhaXY9phthaiate 2.1 x 10" 1.4 X 10'2 B2 IRIS 3.0 x 10"
Arsonic 1.1 x 10.$ 1.75 x 100 A IRIS 2.0 x 10"
Styrane 9.8 x 10' 3.0 X 10'2 B2 HEAST 2.9 x 10.10
2.0 x 10"
I
00:
"
I
.
-------
TABLE 10
ESTIMATED EXCESS UPPER BOUNq CANCER RISKS FOR
FUTURE LAND USE. PARK SCENARIO
(Con't)
CDI SLOPE FACTOR WEIGHT OF SLOPE FACTOR CHEMICAL PATHWAY TOTAL
CHEMICAL (mg/kg-day) (mg/kg-dayr' EVIDENCE SOURCE SPECIFIC RISK RISK RISK
Exposure Pathway: Dermal contact with waste In lagoon bottoms
Tetrachloroethene 2.4 x 10' 5.1 X 10-2 82 HEAST 1.2 x 10"
Bls(2-ethylhoxyl)phthalato 4.9 x 10. 1.4 X 10-2 82 IRIS 6.8 x 10"
Methylene Chloride 6.5 x 10-' 7.5 X 10-3 82 IRIS 4.9 x 10."
Arsenic 4.1 x 10-' 1.75 x 100 A IRIS 7.2 x 10"
Styrene 3.3 x 10.' 3.0 x 10-' 62 HEAST 9.9 x 10"
7.2 X 10.'
Visitor 10 park. Total Risk: 9.3 x 10"
I
an
\0
I
, 1-1
Ibl
CDI .nd flak lor Chromium VI ara lor Inh8lallon of .urtac. .011. ualng chromium Inhalallon model provided by US EPA (..e Appendix 1.).
InCllud.. rI.k due 10 Inhalallon 01 Chromium VI.
SOURCE: RMT, INC. 1991
-------
TABLE 11
NON-CARCINOGENIC HAZARD INDEX FOR
FUTURE LAND USE - PARK SCENARIO
I
I
COI RFO Uncertainly RFO ' Hazard Palhway Tolal
Chemical (mg/kg-day) (mg/kg-day) Faclor Source ' Quollenl HI HI
Exposure Palhway: Ingesllon 0' surface'soll by park vlsllors
Acetone 1.2 x 10'8 1 X 10" 1000 IRIS 1.2 x 10"
Ethylbenzene 2.6 x 10.8 1 X 10" 1000 IRIS 2.6 x 10"
Styrone 9.0 x 10'8 2 X 10" 100 IRIS 4.5 x 10"
Tetrachloroethene 7.7 x 10'8 1 X 10.2 1000 IRIS 7.7 x 10"
Toluene 2.6 x 10.8 2 X 10" 100 IRIS 1.3 x 10"'
1, 1,1-Trlchloroethane 2.6 x 10'8 9 x 10.2 1000 IRIS 2.9 x 10"
Xylenes 3.3 x 10" 2 x 10° 100 IRIS 6.5 X 10"
Bis(2-ethylhexyl)pIIUlalalo 2.9 x 10.8 2 x 10.2 1000 IRIS 1.5 x 10"
Antimony 1.1 x 10-4 4 X 10-4 1000 IRIS 2,8 x 10"'
Arsenic 1.0 x 10.11 1 X 10" 1 HEAST 1.0 X 10.2
Cadmium 5.5 x 10.11 1 x 10.3 10 IRIS 5.5 x 10.2
Chromium III 9.9 x 10.4 1 x 100 100 IRIS 3.4 x 10" 181
Chromium VI 1.1 x 10-4 5 x 10.3 500 IRIS 6.0 x 10" 181
Cyanide 3.5 x 10.11 2 X 10.2 100 IRIS 1.8 x 104
Mercury 1.1 x 10" 3 X 10-4 10 HEAST 3.7 x 10"
Nickel 5.4 x 10.11 2 x 10.2 100 IRIS 2.7 x 10"
Zinc 1.1 x 10.3 2 X 10" 10 HEAST 5.3 x 10"
7.6 x 10:' Ib)
I
\0
\0
I
-------
COI RFD Uncertainty} RFO Hazard Pathway Total
Chemical (mg/kg-day) (rng/kg-day) Factor Source Quollent HI HI
Exposure Pathway: Dermal contact wllh surface soli by park visitors.
Acetone 3.1 X '10.'8 1 X 10'\ 100.0. IRIS 3.1 )( 1 a.
Ethylbenzene 6.5 x 10.8 1 X 10" 10.0.0. IRIS 6.5 x 10..
Styrene 3.4 x 10.8 2x 10" 10.0. IRIS 1.7 x 10."
Tetrachloroethene , 2.0. x 10'8 1 X 10'2 10.0.0. IRIS 2.0. x 10."
Toluene 9.0 x 10.,8 3x 10" 10.0. IRIS 4.9 x 10."
1,1,1- Trichloroethene 6.5 x 10.8 9 X 10.'2 100.0. IRIS 7.2 x 10..
Xylenes 1.2 x 10." 2xlO° 10.0. IRIS 6.2 x 10..
Bls(2-ethylhexyQphthalato 7.4 x 10" 2 X 10'2 1000 IRIS 3.7 x 10..8
Antimony 2.8 x 10..11 4 x 1 a" 1000 IRIS 6.9 x 10..2
Arsonic 3.9 x 10.,11 1 X 10.3 1 HEAST 3.9 X 10.,2
Cadmium 1.4 x 10..11 1x 10.3 10. IRIS 1.4 )( 10.,2
Chromium III 2.6 x 10." 1 x 100 100 IRIS 2.6 x 10."
Chromium VI 2.9 x 10.11 5 X 10.3 50.0. IRIS 5.8)( 10.""
Cyanide 1.3 x 10." 2 )( 10'2 10.0. IRIS 6.5)( 10.""
Mercury 4.1 x 10." 3 x 1 A.. 10. HEAST 1.4 x 10.'2
Nickel 1.3 x 10.,11 2 x 10..2 10.0. IRIS 6.8 )( 1 A..
Zinc 2.7 x 10." 2x 10" 10. HEAST 1.4 x 10.""
1.5 x 10."
TABLE 11
NON-CARCINOGENIC HAZARD INDEX FOR
FUTURE LAND USE - PARK SCENARIO
(Con't)
I
,...
\0
I
-------
CDI RFD Uncertainly J RFD Hazard Palhway Tolal
Chemical (mg/kg-day) (mg/kg-day) Faclor Source QuoUenl HI HI
Exposure Palhway: Dermal conlacl wllh wasle In 10900n boUoms.
Acelone 1.9 x 10" 1 X 10" 1000 IRIS 1.9 x 10"
2-BUlanone 6. 1 x 10" 5 X 10'2 1000 IRIS 1.2 x 10"
Chlorobenzene 1.5 x 10.5 2 I( 10"2 1000 IRIS 7.3 x 10~
1,2-Dlchloroolhenes (Iolal) 1.6 x 10" 1 I( 10'2 1000 IRIS 1.6 x 10"
Ethylbenzene 7.3 x 10" 1 X 10'\ 1000 IRIS 7.3 x 10"
Melhylene Chloride 2.1 x 10" 6 x 10.2 100 IRIS 3.6 x 10"
Slyrene 1.1 x 10" 21( 10-\ 100 IRIS 5.5 x 10"
Telrachloroelhene 0.0 x 10" 1 I( 10'2 1000 IRIS 0.0 x 10"
Toluene 2.1 x 10.11 3 X 10'\ 100 IRIS 7.0 x 10"
Xylenes 6.3 x 10'" 2xHf' 100 IRIS 3.2 x 10"
Bis(2-elhylhexyQphU,alale 1.6 x 10.11 2 I( 10.2 1000 IRIS 0.0 x 10~
AnUmony 7.4 x 10~ 4 X 10" 1000 IRIS 1.9 x 100
Arsenic 1.4 x 10~ 1 x 10" 1 HEAST 1.4 X 10'\
Cadmium 4.6 x 10" 1 X 10" 10 IRIS 4.6 x 100
Chromium '" 3.3 x 10.2 1 I( 1(f' 100 IRIS 3.3 x 1002
Chromium VI 3.7 x 10'3 5 X 10" 500 IRIS 7.4 x 10"
Cyanide 2.6 x 10.2 2 X 10'2 100 IRIS 1.3 x 10«'
Mercury 7.9 x 10'" 3 x 10" 10 HEAST 2.6 x 10"
Nickel 2.4 x 10'3 2 X 10'2 100 IRIS 1.2 x 10"
Zinc 3.0 x 10'2 2 X 10'\ 10 HEAST 1.5 x 10'\
9.2 x 10«'
TABLE 11
NON-CARCINOGENIC HAZARD INDEX FOR
FUTURE LAND USE - PARK SCENARIO
(Con't)
,/
I
CD
\D
I
-------
COI RFO Uncertainty I RFO Hazard Pathway Total
Chemical (mg/kg-day) (mg/kg-day) Factor Source Quotient HI HI
Exp08ure Pathway: Inge8110n o. 8urface water In open lagoons while swimming.
Acetone 1.1 x 10-5 1 X 10" 1000 IRIS 1.1 x 10"
Cadmium 7.6 x 105 1 X 1 0.3 10 IRIS 7.6 x 10.2
Chromium III 4.3 x 10" 1 x 100 100 IRIS 4.3 x 10"
Chromium VI 4.8 x 10-5 5 X 10"3 500 IRIS 9.6 x 10-3
Zinc 2.6 x 10-3 2 X 10" 10 HEAST 1.3 x 10.2
9.9 X 10'2
Exp08ure p.thway: Dermal contact with 8edlment8 In unnamed tributary.
Acetone 5.6 x 10-' 1 X 10" 1000 IRIS 5.6 x 10"
Toluene 1.9 x 10.7 3 X 10" 100 IRIS 6.3 x 10.7
Chromium III 6.1 x 10" 1 x 100 100 IRIS 6.1 x 10"
Chromium VI 6.8 x 10.7 " 5 x 10-3 500 IRIS 1.4 x 10"
Mercury 1.2 x 10" 3 x 10" 10 HEAST 4.0 x "10"
Zinc 3.7 x 10" 2x 10" 10 HEAST 1.9x10"
4.0 x 10"
Site V18110r: Tolal Chronic Hazard Index 1.0 x 10'
TABLE 11
NON-CARCINOGENIC HAZARD INDEX FOR
FUTURE LAND USE - PARK SCENARIO
(Con't)
I
0\
\D
I
,.,
'bJ
Huard quou.nt 'nc'ud.. 'nhal.llon 0' chromium In .urfaca .011 usln~ chromium Inhalallon model provided by EPA (See Appendbc I,J.
Hazerd Indell Includ81 Inhalallon 0' chromium Uland chromium VI In surface 801/.
SOURCE: RMT, INC. 1991
-------
TABLE 12
ESTIMATED EXCESS UPPER BOUND LIFETIME CANCER RISKS FOR,
FUTURE LAND USE - RESIDENTIAL SCENARIO
CDI , Slope Factor Weight 0' Slope Factor Chemical Pathway Total
Chemical (mg/kg-day) ~ (mg/kg-day)"' Evidence Source Specific Risk Risk Risk
Exposure Pathway: Inoeallon 0' 8urface soli by residents.
6is(2-ethylhexyQphthalate 8.0 x 10-' 1.4 X 10'2 82 IRIS 1.1 x 10.
Arsenic 2.8 x 10" 1.75 x 10° A IRIS 4.9 x 10.
Chromium VI 1.2 x 10. 4.1 x 10' A HEAST 4.9 x 10.71.,
Styrene 2.4 x 10" 3.0 X 10'2 82 HEAST 7.2 x 10'"
Tetrachloroethene 2.1 x 10. 5.1 X 10'2 82 HEAST 1.1 x 10"
5.4 x 10"/bJ
Expoaur. Pathway: Dermal contact with 8urface .011 by r.aldent..
Tetrachloroethene 1.2 x 10. 5.1 X 10-2 62 HEAST 5.9' x 10',0
6Is(2-ethylhexyQphthalale 4.3 x 10" 1.4 X 10-2 02 IRIS 6.1 x 10"
Arsenic 2.3 x 10" 1.75 x 100 A IRIS 4.0 x 10"
Styrene 2.0 x 10. 3.0 X 10-2 62 HEAST 6.0 x 10-10
4.0 x 10"
Exposure Pathway: Dermal conlact with waale In lagoon boUom..
Tetrachloroethene 3.7 x 10. 5.1 X 10-2 02 HEAST 1.0)( 10"
Ois(2-8thylhexyQphthalale 7.3 x 10" 1.4 X 10-2 02 IRIS 1.0)( 10-'
Methylene Chloride 9.8 x 10. 7.5 X 10-3 02 IRIS 7.3 )( 10-"
Arsenic 6.2 x 10" 1.75 x 10' A IRIS 1.1 x 10"
Styrene 5.0 x 10" 3.0 X 10'2 82 HEAST 1.5 x 1~
1.1 X 1'0"
, .
.
I
o
l"-
I
-------
TABLE 12,
IESTIMA TED EXCESS UPPER BOUND LIFETIME CANCER RISKS FOR
FUTURE LAND USE - RESIDENTIAL SCENARIO
(Can't)
CDI Slope Factor Weight of Slope Factor Chemical Pathway Total
Chomlcal (mg/kg-day) (mg/kg-dayr' Evidence Source Specific Risk Risk Risk
Expo8ure Pathway: Inge8t1on 0' Con8t1tuents In drinking water.
Bis(2-ethylhexyQ 3.8 x 10" 1.4 X 10.1 B2 IRIS 5.3 x 10"
phthalate
Chloroform 4.9 x 10" 6.1x104 82 IRIS 3.0 x 10"
Methylene Chloride 2.0 x 10" 7.6 X 104 82 IRIS 1.6 x 10"
1,2-Dlchloroethenes 6.1 x 104 9.1 X 10. 82 IRIS 5.6 x 10"
1 ,2-DlchIoropropane 1.6 x 10" 6.8 X 10-1 82 HEAST 1.1 x 10"
2.6 x 10"
Resident at .ne. Total RI.k: 1.8 x 10"
I
.-4
~
I
tal
IbJ
COt U1d rllk '01 ohromlum VI are for Inhalallon of 8urfac. IOU. u.lng ohromlum InhalaUon mod.1 provided b1 EPA (See Append.. iJ.
Inolud.. rlell due to Inhala\lon of ohromlum VL
SOURCE: RMT, INC. 1991
-------
COI RFO Uncertainty RFO Hazard Pathway Total
Chemical (mg/kg-day) (mg/kg-day) Factor Source QuoUent HI HI
Exposure Pathway: Ingesllon 0' 8urface 8011 by residents.
Acelone 5.0 x 10" 1 x 10" 1000 IRIS 5.0 x 10"
Elhylbenzene 1.0 x 10" 1 x 10" 1000 IRIS 1.0 x 10"
Slyrene 3.6 x 10.8 2'x 10" 100 IRIS 1.8 x 10"
Telrachloroethene 3.1 x 10"' 1 X 10.2 1000 IRIS 3.1 x 10-8
Toluene 1.1 x 10" .2 x 10" 100 IRIS 5.2 x 10"
1,1, 1-Trichloroolhane 1.1 x 10.7 9 X 10'2 1000 IRIS 1.2 x 10"
Xylenes 1.3 x 10.7 2x Hf 100 IRIS 6.6 x 10"
Bis(2-elhylheXYQphlhalales 1.2 x 10'0 2 X 10.2 1000 IRIS 6.0 x 10"
Antimony 4.4 x 10" 4 x 10" 1000 IRIS' 1.1 x 100
Arsenic 4.1 x 10-0 1 X 10..:1 1 HEAST 4.1 x 10-a
Cadmium 2.2 x 10" 1 X 10..:1 10 IRIS 2.2 x 10"
Chromium III 4.1 x 10" 1xHf 100 IRIS 1.4 x 100'"
Chromium VI 4.6 x 10" 5 X 10..:1 500 IRIS 2.4 x 10'11"
Cyanide 1.4 x 10" 2 X 10'2 100 IRIS 7.0 x 10..:1
Mercury 4.4 x 10" 3 x 10" 10 HEAST 1.5 x 10'2
Nickel 2.2 x 10" 2 X 10.2 100 IRIS 1.1 x 10.2
Zinc 4.3 x 10' 2x 10" 10 HEAST 2.2 x 10.2
3.1 X 1 ct' Ib!
TABLE 13
NON-CARCINOGENIC HAZARD INDEX ESTIMATES FOR
FUTURE LAND USE - RESIDENTIAL SCENARIO
.,
I
C'
....
I
-------
Chemical COI RFO Uncertainty RFO Hazard Pathway Total
I Source Quotient HI HI
(mg/kg-day) (mg/kg-day) Factor
Exp08ure Pathway: Dermal contact wllh 8urface 8011 by residents.
Acetone 6.3 x 10.8 1 X 10" 1000 IRIS 6.3 x 10.
Elhylbenzene 1.3 x 10. 1 X 10" 1000 IRIS 1.3 x 10"
Tetrachloroolhene 4.0 x 10. 1 x 10'2 1000 IRIS 4.0 x 10"
1.1.1-Trlchloroelhane 1.3 x 10. 9 X 10.2 1000 IRIS 1.4 x 10"
Bls(2.elhylhexyl)phthalate 1.5 x 10" 2 X 10.2 1000 IRIS 7.5 x 10"
Styrene 6.9 x 10" 2 X 10" 100 IRIS ' 3.5 x 10"
Toluene 2.0 x 10" 3x 10" 100 IRIS 9.9 x 10"
Xylenes 2.5 x 10" 2xlO° 100 IRIS 1.3 x 10"
Arsenic 7.8 x 10-8 . 1 X 10'" 1 HEAST 7.8 x 10"
Antimony 5.6 x 10-8 4 x 10" 1000 IRIS 1.4 x 10" '
Cadmium 2.0 x 10" 1 X 10'" 10 IRIS 2.8 x 10"
Chromium III 5.2 x 10" 1 x 100. 100 'IRIS 6.2 x 10"
Chromium VI 6.0 x 10-8 5x 10'" 500 IRIS 1.2 x 10"
Cyanide 2.7 x 10" 2 X 10'2 100 IRIS 1.4 x 10"
Mercury 8.4 x 10. 3 x 10" 10 HEAST 2.8 x 10"
Nickel 2.8 x 10'11 2 X 10'2 100 IRIS 1.4 x 10'"
Zinc 5.5 x 10" 2x 10" 10 HEAST 2.7 x 10'"
3.0 x 10"
TABLE 13
NON-CARCINOGENIC HAZARD INDEX FOR
FUTURE LAND USE - RESIDENTIAL SCENARIO
(Con't)
,
rt)
.....
,
-------
TABLE 13
NON-CARCINOGENIC HAZARD INDEX FOR
FUTURE LAND USE - RESIDENTIAL SCENARIO
(Con't)
CDI RFD IUncertalnty RFD Hazard Pathway Total
Chemical (mg/kg-day) (mg/kg-day) Factor Source Quotient HI HI
Exposure Pathway: Dermal contact with waste In 18goon bottoms.
Acelone 2.9 J( 10" 1 X 10" 1000 IRIS 2.9 x 10"
Elhylbenzene 1.1 x 108 1 X 10" 1000 IRIS 1.1 x 10.11
Tetrachloroethane 1.2 )( 1U" 1 X 10'2 1000 IRIS 1.2 x 10"
Chlorobonzene 2.2 x 1U& 2 X 10'2 1000 IRIS 1.1 x 10.3
Bis(2-ethylhexyl)phlhalale 2.4 x 10'& 2 X 10'2 1000 IRIS 1.2 x 10-3
Methylene Chloride 3.2 x 10" 6 X 10'2 100 IRIS 5.4 x 10"
1 ,2-0ichloroethenes (to'al) 2.5 X 10.8 1 x 10-2 1000 IRIS 2.5 x 10"
2.Bulanone 9.2 x 10'8 5 X 10'2 1000 IRIS 1.8 x 10"
Slyrene 1.6 x 10" 2 X 10" 100 IRIS 8.0 x 10.
Toluene 3.2 x 10'& 3 X 10" 100 ' IRIS 1.1 x 10"
Xylenes 9.5 x 10'& 2 x 100 100 IRIS 4.8 x 10"
Arsenic 2.0 x 10" 1 X 10-3 1 HEAST 2.0 X 10"
Anllmony 1.1 x 10'3 4 x 10" 1000 IRIS 2.8 x 100
Cadmium 6.9 x 10.3 1 X 10.3 10 IRIS 6.9 x 10°
Chromium III 5.0 x 10'2 1 x 100 100 IRIS 5.0 x 10-2
Chromium VI 5.6 x 10.3 5 x 10-3 500 IAIS 1.1 x 100
Cyanide 3.9 x 10.2 2 X 10'2 100 IRIS 2.0 x 100
Mercury 1.2 x 10" 3 x 10" 10 HEAST 4.0 x 10"
Nickel 3.5 x 10'3 2 )( 10'2 100 IRIS 1.8 x 10"
Zinc 4.5 x 1U.2 2 X 10" 10 HEAST 2.2 x 10"
1.4 X 10'
Exp08ure Pathway: Inge8110n 0' 8urface water In open lagoons while 8wlmmlng.
Acetone ,1.6 x 10'& 1 X 10'\ 1000 IRIS 1.6 x 10"
Cadmium 1.1 x 10'4 1 x 10.3 10 IRIS 1.1 x 10"
Chromium III 6.6 x 10.4 1 x 100 100 IRIS 6.6 x 10"
Chromium VI 7.3 x 10'& 5 X 10.3 500 IRIS 1.5 x 10.2
Zinc 3.9 x 1U'3 2 X 10" 10 HEAST 2.0 x 10'2
1.5 X 10"
,
-------
TABLE 13
NON-CARCINOGENIC HAZARD INDEX FOR
FUTURE LAND USE - RESIDENTIAL SCENARIO
(Con't)
COI RFO ,Uncertainty RFO Hazard Palhway Total
Chemical (1I\g/kg-day) (mg/kg-day) Factor Source Quotient HI HI
Exposure Pathway: Oermal contact wllh sediments In unnamed tributary.
Acetone 8.4 x 10' 1 x 10' 1000 IRIS 8.4 x 10.
Chromium III 9.0 x 10. 1 x 100 100 IRIS 9.0 x 10.
Chromium VI 1.0 x 10. 5 X 10.:t 500 IRIS 2.0 x 10'"
Toluene 2.8 x 10" 3 x 10'\ 100 IRIS 9.3 x 10.7
Mercury . 1.8 x 10" 3 x 10'" 10 HEAST 6.0 x 10'"
Zinc 5.6 x 10. 2 X 10" 10 HEAST 2.8 x 10.
I I 8.4 x 10"' . I
Exposuro Pathway: Ingo8110n 0' drinking waler 'rom on-8lto well.
Acetone 1.4 x 10" 1 x 10'\ 1000 IRIS 1.4 x 10.:t
Chlorolorm 3.6.x 10' 1 x 10.2 1000 IRIS 3.6 x 10"
1,2-Dlchloroethenes 7.3 x 10'" 1 X 10.2 1000 IRIS . 7.3 x 1002
Methylene chloride 1.5 x 10" 6 X 10.2 100 IRIS 2.5 x 1002
1,1,1-Trichloroeihane 1.2 x 10" 9 X 10.2 1000 IRIS 1.3 x 1002
Xylenes 1.7 x 10.:t 2 x 10° 10 IRIS 8.5 x 10'"
Bis(2-ethylhexyQphthalate 2.0 x 10.3 2 X 10.2 1000 IRIS 1.4 x 10"
Cadmium . 4.5 X 10'" 5 x 10'" 10 IRIS 9.0 x 10'\
Chromium III 3.9 x 10" 1 x 100 100 IRIS 3.9 x 10-3
Chromium VI 6.5 x 10'" 5 X 1O.:t 500 IRIS 1.3 x 10"
Nickel 1.1 x 10'2 2 X 10'2 100 IRIS 5.5 x 10"
Zinc 1.2 x 10'2 2 x 10'\ 10 IRIS 6.0 x 10"
2.8 x 100
2.0 x 10'
I
an
r--
I
I"
Ibl
Hazard quotient Includel Inhllellon 01 chromium In lurtace loll using chromium Inhalellon model provided by US EPA (s.. Appendix L).
Hazard Ind.x Includ.. Inhalallon 01 Chromium III end Chromium VI In lurtlce loil.
. '/
SOURCE: RMT, INC. 1991
-------
TABLE 14
RISK ASSESSMENT SUMMARY
CARCINOGENIC NON CARCINOGENIC
PATHWAY RISK HAZARD INDEX
CURRENT LAND USE
Ingestion of Surface Soilra] 1.2 x 10-- 5.5 x 10-1
Dennal Contact with Surface Soil 5.8 x 1ae 1.2 x 10.1
Dermal Contact with Waste in Lagoon 1.6 x 1008 7.5 x 100 I
Bottoms
Ingestion of Lagoon Water while [b) 7.2 x 10-2
Swimming
Dennal Contact with Tributary [bJ 4.6 x 10~
Sediments
CURRENT LAND USE TOTAL 2.3 x 10"" 8.2 x 10°
.
FUTU~E LAND USE-
PARK SCENARIO
Ingestion of Surface Soilla] 1.3 x 10" 7.6 x 10"
Dennal Contact with Surface SOIl 2.0 x 10"" 1.5 x 10.1
Dermal Contact with Waste in Lagoon 7.2 x 1008 9.2 x 100
Bottoms -
Ingestion of Lagoon Water while [bJ 9.9 x 10.2
Swimming
Dennal Contact with Tributary [bJ 4.0 x 10~
Sediments
FUTURE LAND USE-PARK TOTAL 9.3 x 10"" 1.0 x 10'
-76-
-------
TABLE 14
RISK ASSESSMENT SUMMARY (Cont.)
CARCINOGENIC NON CARCINOGENIC
PATHWAY . RISK HAZARD INDEX
FUTURE LAND USE-
RESIDENTIAL SCENARIO
Ingestion of Surface sonIa) .5.4 x 10-- 3.1 x 100
Dermal Contact with Surface Soil 4.0 x 1cT' 3.0 x 10"'
Dermal Contact with Waste In Lagoon .1.1 x 1cr 1.4 X 10'
Bottoms
Ingestion of Lagoon Water while [b) .1.5 x 10"
Swimming
Dermal Contact with Tributary [b) 8.4 x 1~
Sediments
Ingestion of Unfiltered Ground Water 2.6 x 1008 2.8 x 100
RESIDENTIAL .SCENARIO TOTAL 1.8 x 1cr 2.0 x 10'
'8)
(tI)
Includ.. Inhalation of chromium In 8urface 8011.
Carcinogenic con8tituenta of concem not detected In lIiI medium.
SOURCE: RMT, INC. 1991
-77-
-------
TABLE 15
ENVIRONMENTAL RECEPTORS'-. COMPARISON OF EXPOSURE TO NOAEL
CHEMICAL EXPOSURE PATHWAY CDI NOAEL
Acetone SoiJ/Food Ingestion 6.0 x 10.
Dermal Absorption 6.9 x 10"'
Water Ingestion 1.1 x 1~
Total Exposure 1.1 x 1~ 2.0 x 1cr
Ethylbenzene Soil/Food Ingestion 1.3 x 1cr
Derma! Absorption 1.4 x 10"1
Total Exposure 1.3 x 1cr 9.7 x 10'
Styrene SoiI/Food Ingestion 4.4 x 10.5
Dermal Absorption 7.6 x 10.1
Total Exposure 4.4 X 10-5 1.0 x 1cr
Tetrachloroethane SOil/Food Ingestion 3.8 x 10~
Dermal Absorption 4.3 x 10"1
Total Exposure 3.8 x 10~ 1.4 X 10'
Toluene SoillFood Ingestion 1.3 x 1cr
Dermal Absorption 2.2 x 10"'
Total Exposure 1.3 x 1cr 2.9 x 10'
1,1,1 Trichloroethane Soil/Food Ingestion 1.3 x 10~
Dermal Absorption 1.4 x 10-'
Total Exposure 1.3 x 10~ 9.0 x 10'
Xylenes SoiI/Food Ingestion 1.6 x 1cr
Dermal Absorption 2.7 x 10.
Total Exposure 1.6x10~ 2.5 x 1cr
-78-
-------
TABLE 15
ENVIRONMENTAL RECEPTORS. COMPAR-ISON OF EXPOSURE TO NOAEL (Con't)
CHEMICAL EXPOSURE PATHWAY CDI NOAEL
Bis(2-ethylhexyQ phthalate SoiI/Food Ingestion 1.4 x 10-2
Dennal Absorption 1.6 x 1ae
Total Exposure 1.4 x 10-2 1.9 x 10' tal
Antimony SoiI/Food Ingestion 5.3 x 10"
Dennal Absorption 6.1 x 1cr
Total Exposure 5.3 x 1a' 3.5 x 1a' la)
Arsenic SoiVFood Ingestion 4.9 x 1 ~
Dermal Absorption 8.6 x 10~ ,
Total Exposure 5.0 x 10.2 [b]
Cadmium SoiVFood Ingestion 2.7 x 10" 1.0 X 10.2
Dermal Absorption 3.1 x 10~
Water Ingestion 7.8 x 10"" 5.0 x 10-3
Total Exposure 2.8 x 10" 1.0 X 10.2
Chromium III SoiVFood Ingestion 5.0 x 100
Dermal Absorption 5.7 x 104
Water Ingestion 5.0 x 10-2
Total Exposure 5.1 x 100 1.5x 1cY
Chromium VI SoillFood Ingestion 5.5 x 10"
Dermal Absorption 6.4 x 10~
Total Exposure 5.5 x 10" 2.4 x 100
Copper SoiVFood Ingestion 4.0 x 100
Dermal Absorption 4.6 x 10""
Water Ingestion 1.1 x 10"
Total Exposure 4.1 x 100 [e]
-79-
-------
TABLE 15
ENVIRONMENTAL RECEPTORS - COMPARISON OF EXPOSURE TO NOAEL (Con'l)
CHEMICAL EXPOSURE PATHWAY CDI NOAEL
Cyanide SoiVFood Ingestion 1.7 x 10"'
Dermal Absorption 3.0 x 1~
Total Exposure 1.7 X 10"' 1.1 x 10'
Lead SoiI/Food Ingestion . 6.9 x 10"'
Dermal Absorption 7.9 x 1cr
Water Ingestion 6.0 x 1cr
Total Exposure 6.9 x 10" 5.0 x 10-2 lei]
Mercury SoiVFood Ingestion. 5.3 x 10'"
Dermal Absorption 9.2 x 1005
Total Exposure 5.4 x 10'" 3.0 X 10" [0'
Nickel SoillFood Ingestion 2.6 x 10"
Cermal Absorption 3.0 x 1cr
Total Exposure 2.6 x 10" 5.0 x 100
-
Zinc SoiVFood Ingestion 5.2 x 100
Dermal Absorption 6.0 x 1~
Water Ingestion 2.7 x 10"'
Total Exposure 5.5 x 100 2.0 X 100101
. Lowelt Observed Adverse Effects Level (LOA~ .
tI Not found to be earcinogenic in anlinals (IRIS). No information concerning toxicity to anima/8 In IRIS or HEAST.
C No Information concerning toxicity to animal. In IRIS or HEAST. .
CI NOAEl (dietary) for monkeys. Rice. D. C., 1984. Toxicology and Applied Pharmacology. Vol. 77:201-210.
. Based on human reference dose (HEAST) X Uncertainty.
SOURCE: RMT,INC.1991
-80-
-------
7.0 ' DESCRIPTION OF ALTERNATIVES
A Feasibility Study (FS) was conducted to develop and evaluate
remedial alternatives to address the sludge materials contained
within the GSST lagoons, the underlying soils and affected surface
soils. The primary objective of the FS was to determine and evaluate
alternatives for the appropriate extent of remedial action to prevent
or'mitigate the migration or the release or threatened release of
hazardous substances from the site. The following section of this
ROD provides a summary of the eight alternatives that were developed
as part of the FS.
The FS was conducted in three phases. Phase I consisted of
identifying possible remedial action alternatives for each of the
affected media. Remedial action objectives were specified for the
site constituents using criteria that are protective of human health
and the environment. To achieve the objectives, general response
actions were identified for each medium, including soil, sludge, and
impounded surface water.
Remedial action target levels for affected surface soils and lagoon
sludges were established through the Baseline Risk Assessment
discussed in Section 6.0 of this document. These soil remedial
action target levels are delineated in Section 9.1 of this document.
The remedial action target levels are based on the unlimitgd exposure
scenario which establishes a maximum risk level of 1 X 10- for
carcinogens, except tge target level for arsenic which is based on a
risk level of 1 X 10- ; and a hazard index of 0.3 for
non-carcinogens, based on potential exposure to three non-carcinogens
at one time (HI/3). The unlimited exposure scenario assumes an
exposure frequency of 365 days/year and 50% of soil incidentally
ingested each day of exposure. A plan view of the remedial action
limits including the truck turnaround area and drainage swale are
delineated in Figure 9. Waste cross-sections indicating the
excavation limits of remedial activities are illustrated on Figures
10 and 11.
Surface areas and volumes of affected materials were estimated using
data obtained during the RI. The estimated volume of soil having
waste constituent concentrations exceeding remedial action target
levels is 24,400 cubic yards based on unlimited exposure to the waste
management area. The estimated volume of sludge is 4,200 cubic
yards. The estimated volume of impounded surface water in the
lagoons is approximately 1.9 million gallons.
Investigation of the abandoned drum area on the eastern side of the
Rice Farm indicated that concentrations of cadmium and chromium
exceeded remedial action target levels in one sample. The extent of
this contamination shall be further defined during the Remedial
Design/Remedial Action (RD/RA) phase of this project. It is expected
that the volume of this material requiring remediation will not
significantly increase the volumes noted above.
These material volumes and the locations in which the materials were
,found were used to select applicable remedial technologies for
-81-
-------
-z-
..;',"
.i-.
~
..
. ~--"'"
...
. ...-
II
Ia ...M:I" ltoI8'\l
....
.~. ""'1(1.''''''''''''''.
. ,..,. ....lit
'"r
. '1'" s-ftl
. IU"'"
..
H ....'"
- .,.aa I"C' ........
--- ~~,.
-.... ..... aCl- .M'I
u.-. .... ....
-. EE:':::=': :1':I:~.cI
,_"",I~,,1IItC
..
1IlW'II'.
..
...
...
-
".U"",,,,,,,'(l.1
,.,-
:1::'~....---'
:..-.::.: ...
AGURE 9
PLAN VIEW-REMEDIATION LIMITS
. GOLDEN STRIP SEPTIC TANK
SOURCE: RMT,INC. 1991
-------
~J ~I L_,
[
~ ~ ~ ~ ~ ['
w Ii
I E
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~ II
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.
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-j
, '
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~ .
~ ~
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....
...
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- .u"
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t---.-
--.. c....,. ,..
-- 1&.. ,.,
--
t:iU.
:'c~,,:,~c~:...
'.... C......'_I- f.
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..
...
.. .
n.nnnr..
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...--~....-
..
. ..... ........
,..... .'"
---.tC -
--
.,.-
FIGURE 10
WASTE CROSS-SECTION
LIMITS OF REMEDIAL ACTION
SOURCE: RMT,INC. 1991
-------
G '_1 .-, r: ...... I
Ii .1 I'
N II Ii s
m 1ft N Ii ii s
i I I ... I4S
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fill ""
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.0.
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i
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... i i ... ...... 1It1- l-'
... I
.. I III ..
IjI III I 0 in -- C818"""'" 1M' 11t'I.1
I I: ~:s.. .. ("0&1'18" Q.."'"
~ I 0 5 ,..., C8Q.,..t_,.
,n8 ,,""'"11..-
If I 110 ~
DO ...
~ - >
~ I ~ ,. 000 ...
I - . ..
... . ia ~-
tI ... ....'0II1Al ,UU-flll
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I: 80 J; ....ca.U8CCl8&''''.
80 6
5 ..
.. ..
.. . 80S >
a - a
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- ,..........
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no "".. FIGURE 11
7ft -....
-.... WASTE CROSS-SECTION
-...
1,..., fI, -'." LIMITS OF REMEDIAL ACTION
- ......-----.-r u.
SOURCE: RMT.INC 1991
-------
further consideration, and to eliminate those technologies that could
not be technically justified for implementation at the site. The
list of technologies that were identified through this screening
process were used to assemble eight alternatives representing a range
of no action, containment and treatment technologies.
In Phase II, specific components of each remedial alternative were
described in greater detail to evaluate the remedial alternatives
according to effectiveness, implementability, and cost. Following
this screening process, seven of the original eight were retained for
further consideration in Phase III of the FS.
Phase III consisted of a detailed evaluation of the remedial
alternatives based on the following nine criteria:
1) Overall Protection of BumanBealth"and the Environment,
2) Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs),
3) Long-Term Effectiveness and Permanence,
4) Reduction of Toxicity, Mobility, and Volume,
5) Short-Te~ Effectiveness,
6) Implementability,
7) Cost,
8) State/Support Agency Acceptance, and
9) Community Acceptance.
Phase III of the FS also included a comparative analysis of the
remaining remedial alternatives, which compared the alternatives with
each other.
Common Elements
Alternatives 2 through 8 include the establishment of Alternate
Concentration Limits for the observed, intermittent MCL exceedances
of lead, chromium, 1,2-dichloropropane, and 1,2-dichloroethane in the
ground water and the associated long-term ground water monitoring
program.
Alternatives 3 through 8 also include the collection and discharge of
surface water impounded in the waste lagoons to the local POTW.
Based on preliminary communications with the Western Carolina
Regional Sewer Authority (WCRSA) and Metropolitan Sewer District
(MSD), WCRSA and MSD officials agree to accept discharge from the
GSST site consistent with WCRSA's effluent discharge standards.
Pretreatment of the discharge would be required if constituents
exceed WCSRA's standards. RI data indicate that pretreatment will
not be required.
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The following sub-sections further describe the eight alternatives
developed and evaluated in the FS to address the lagoon sludges, and
surface and subsurface soils in the immediate vicinity of the waste
management area.
7.1
Alternative 1 - No Action
In accordance with the NCP, EPA has evaluated a "No Action"
alternative as part of the FS. The No Action alternative serves as a
basis against which other alternatives can be compared. Under the No
Action Alternative, no remedial response would be performed on any of
the media of concern (surface soil, lagoon sludge and lagoon water)
at the site. Waste disposal areas, as defined during the RI, would
remain in their present condition.
The only active component of this alternative is long-term ground
water, surface soil, and sediment monitoring. This program would be
implemented to assess the effect of waste constituents on the site
over a 30-year design life. Ground water quality at the site would
be monitored semiannually. for volatile organic compounds,
semi-volatile organics and inorganics. Surface soil and sediment
monitoring would be performed annually for the same constituents to
evaluate any possible migration of waste constituents.
Since thi~ remedy results in hazardous waste remaining on-site which
will not allow unlimited use and unrestricted exposure, CERCLA
requires that the site be reviewed every five years. During this
review, the monitoring program would be re-evaluated to assess the
appropriateness of the sampling program.
This alternative does not reduce the risk calculated by the Baseline
Risk Assessment. The NOsAction Alternative results in an excess
cancer risk of 2.3 X 10- and a hazard index for non-carcinogenic
effects of 8.2 for current land use, which are considered
unacceptable risk levels by the EPA.
The estimated present-worth, including 30-year O&M costs, of
Alternative 1 is $1,300,000. This includes $60,000 of capital for
engineering design services and approximately $83,000 annual
monitoring costs.
7.2
Alternative 2 - Institutional Controls
The Institutional Controls alternative establishes institutional
measures to block possible waste constituent exposure pathways
through the affected media: soil, sludge and lagoon surface water.
. These institutional controls include the following:
Fencing to limit access to affected solid materials and surface
impoundments; and
A conservation easement, or deed restriction, to control the
use of affected ground water and future development of the
site.
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Under this alternative, those areas of the site containing soils and
sludge with waste constituent concentrations exceeding remedial
action target concentrations would be fenced. The fence would
consist of a six-foot high chain link fence with at least one strand
of barbed wire extending along the top. The site would be posted and
gates would be kept locked.
In addition to fencing, legal actions would be taken to provide a
permanent easement restricting access and future site use. The
conservation easement will grant control of the land in perpetuity to
a third party and prohibit further development of the property. The
conservation easement could be granted well in advance of any
remedial action at the Site.
There are no chemical-specific, action-specific, or location-specific
ARARs for the constituents of concern. in soil, if left in place.
However, concentrations in the soil and sludge would"remain elevated
above remedial action target levels that are deemed protective of
human health and the environment. The impounded water in the two
existing lagoons will not attain ARARs for surface water due to the
reported concentrations of cadmium, chromium, copper, iron,
manganese, and zinc which exceed Water Quality Criteria for fresh
water aquatic life, for human exposure, or for both.
Review of the site would be conducted every five years since
hazardous substances are remaining on site and will not allow for
unlimited use and unrestricted exposure.
This alternative reduces the incremental risk for current site
conditions by restricting access to the affected media and by
preventing future land uses that would allow repeated, frequent
contact with the affected media. Implementation of institutional
controls at th5 Site wouldSreduce the site carcinogenic risk level
from 2.3 X 10- to 1 X 10- , and the hazard index for
noncarcinogens from 8.2 to 0.14. The resulting risk assessment
considers only those constituents in soil samples collected beyond
the area that would be fenced, since the fence will prevent direct
contact with the lagoons.
Environmental monitoring similar to that discussed under Alternative
1 would also be conducted as part of this alternative. The capital
cost associated with this alternative is $81,000 with annual costs of
$83,000. The total estimated present-worth cost for implementation
of Institutional Controls is $1,400,000.
7.3
Alternative 3 - Containment of Soils and Sludqes
This alternative combines the institutional actions outlined for
solid waste materials described in Alternative 2 with containment of
affected solid waste materials by capping. This alternative would
contain, in-place, the total volume of affected solids.
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Containment would leave affected soils in place with little or no
disturbance. A cap over affected materials at the surface would
minimize contact between percolating water and waste constituents,
thereby reducing the potential for migration of waste constituents to
the groundwater. In addition, a cap installed over the affected'
materials would prevent erosion of waste constituents by wind or
surface water runoff. A containment cover of this type would require
periodic maintenance and inspection. The cap would cover the soils
with waste constituent concentrations exceeding the surface soil
remedial action targets. The total area of the cap would be 7.4
acres. Approximately 10 acres would be disturbed by construction
activities. .
Two designs were considered for a containment cover under this
alternative:
Qction 3A - Composite Cover
The composite cover option would involve design of a cap
consisting of the following components:
6 inches of topsoil
12 inches of unaffected native
2 feet of compacted clay
A layer of geotextile material
soils
The clay layer would be compacted to reduce the permeability to
less than or equal to the permeability of the subsoils below the
lagoons as required by South Carolina hazardous waste
regulations. The final surface contours of the cap would be
graded to promote runoff and reduce infiltration during rainfall
events.
The composite cover would be sown with shallow-rooted grasses to
minimize cap erosion. Grasses would be selected to minimize
possible penetration of the protective clay layer by the elements.
Qction 3B - Multimedia Cover
The multimedia cover option would include cap design consisting of
the following components:
6 inches of topsoil
18 inches of unaffected soil
1 layer of geotextile fabric
1 layer of drainage material
1 layer of flexible membrane
2 feet of clay
liner
The multimedia cover design complies with SCDBEC requirements for
hazardous waste cover systems and would be designed to perform in
accordance with EPA minimum technology guidance. Like the
composite cover option, the multimedia cover would be graded to
promote surface drainage and sown with shallow-rooted grasses.
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The soil cover will comply with the RCRA action-specific requirements
for capping solid wastes in place. The cover would be designed to
divert surface water runoff from a 24-hour, 25-year storm. A
vegetative topsoil layer will reduce erosion and protect the
integrity of the clay barrier. Closure caps such as this also meet
the remedial action objectives of eliminating the potential for
dermal exposure and incidental ingestion of surface soils and
sludge. Additionally, surface water in the lagoons will be collected
and discharged to the local sewer authority for treatment. Surface
water ARARs will, therefore, be attained.
Containment of affected solids reduces the incremental. risk
calculated for current site conditions by preventing direct contact
with affected materials having waste constituent concentrations that
exceed remedial action target levels. Construction of the cap over
the affecSed soils would reduce .theSite cgrcinogenicrisk level from
2.3 X 10- for current land use to 1 X 10- , and the hazard index
for carcinogenic effects would decrease from 8.2 to 0.14. These are
considered acceptable risk levels by the EPA.
Since hazardous materials will be contained on site, a review of the
site will be conducted every five years. The review would focus on
whether the cap remains effective, the institutional controls remain
in place, and if protectiveness is being assured through exposure
protection. .
Construction of this remedial alternative is estimated to require 15
months to implement, allowing time for design, bidding, construction,
and unforeseen downtime during site activities.
Capital costs for both cap options are approximately $2,200,000 with
annual costs of $65,000 for monitoring. The estimated present-worth
costs for Options 3A and 3B of this alternative, including 30-year
O&M costs, are $3,200,000 and $3,500,000, respectively.
Alternative 4 - Stabilization and Off-Site DisDosal of
Soils and Sludaes
Alternative 4 consists of the institutional controls described in
Alternative 2, excavation of affected soils and sludge materials, and
off-site disposal in a secure Resource, Conservation and Recovery Act
(RCRA) landfill.
7.4
This alternative includes the removal of all affected solids with
waste constituent concentrations exceeding established surface soil
remedial action target levels. The volume to be excavated would be
approximately 28,600 cubic yards. The extent of excavation.would be
determined by collection and analyses of confirmation samples from
underlying soils after the removal of the sludge and visibly-affected
soils. Prior to excavation, a sampling program would be conducted to
determine the actual volumes of surface soil and overburden requiring
remedial action.
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Excavated wastes would be transported to a facility such as the
Laidlaw (GSX) facility in Pinewood, South Carolina. This facility
is in compliance with all applicable federal and state hazardous
waste requirements and has the capacity necessary to accommodate the
estimated volume of waste. The selected waste transporter would be
in full compliance with applicable federal and state environmental
and public health statutes. Vehicles transporting from the site
would also be approved by the Department of Transportation (DOT),
display the proper placard, and carry the proper manifests.
The lagoon areas would be closed by grading the excavations to
promote drainage, covering with a layer of topsoil, and seeding to
establish vegetative growth. Institutional controls would be
implemented by incorporation of a conservation easement and deed
restrictions to restrict future land uses in the waste management
area.
Action-specific ARARs, in particular the Land Disposal Restrictions
of 40 CFR Part 268, will be met by stabilization of the excavated
soils prior to leaving the site so that regulatory limits for
characteristic wastes are met. The potential receiving landfill is
a SCDHEC and EPA approved Subtitle C hazardous waste landfill that
meets location-specific ARARs. Results of TCLP analyses of. the
sludges and affected soils indicate that cadmium concentrations in
the leachate may require treatment to meet the applicable LDR
standard, for which stabilization is the Best Demonstrated Available
Technology (BDAT). Surface water in the lagoons will be collected
and discharged to the local POTW for treatment and will attain
surface water ARARs. .
Excavation, treatment, and off-site disposal of the affected soils
and sludge combined with the institutional controls for Alternative
2, reduces the incremental risk calculated for the Baseline Risk
Assessment. This altergative results in a maximum carcinogenic risk
level less than 1 X 10- and a hazard index less than 1.0.
Since hazardous materials will not remain on-site, the five-year
review is not applicable for this alternative
Excavation and grading activities .associated with this alternative
could take 12 months to implement, allowing time for design,
bidding, excavation, and unforeseen downtime during excavation and
grading.
Capital costs associated with this alternative are $11,500,000 with
annual costs of $65,000. The estimated present-worth cost of
Alternative 4 is $12,500,000.
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Alternative 5 - Stabilization and Off-Site Disnosal of Slud~e
and Cacnino of Soils
Alternative 5 consists of the institutional controls described in
Alternative 2; excavation of visible wastes (sludges) exceeding
acceptable risk levels and off-site disposal of these materials in a
secure RCRA landfill as described in Alternative 4; and capping of
the affected soils as described in Alternative 3.
7.5
Approximately 6,600 cubic yards of sludge and overburden would be
excavated, stabilized to meet applicable LDR concentration limits,
stockpiled, and transported by truck to the Laidlaw (GSX) Facility
discussed in Alternative 4. The site excavations would be filled by
pushing in the berms and surrounding soils. Sludge from the two
open lagoons would be dewatered and stockpiled with other soils and
sludge. Excavation would be limited .to the removal of. materials
visibly identifiable as sludge, and possibly some overburden from
the backfilled lagoons. Sludge at the site is typically a
grey-white color and ranges in consistency from a thick paste in the
wet lagoons to a soil-like texture in the backfilled lagoons. The
overburden would be sampled to determine if waste constituent
concentrations exceed remedial action target levels for subsurface
soils.
After completion of the excavation activities, a composite cap would
be constructed over all disposal areas containing waste residuals
having concentrations that exceed the target levels for surface
soils. The affected area requiring construction of a cap and cover
is approximately 7.4 acres. The security fence would be extended to
include those areas to be capped that are currently outside the
fencing, thereby providing an additional level of protectiveness to
the alternative.
Action-specific ARARs, in particular the Land Disposal Restrictions
of 40 CFR Part 268, will be met by stabilization of the excavated
sludge prior to leaving the site so that regulatory limits for
characteristic wastes are met. Action-specific ARARs will also be
met in the design and construction of the composite cap, which
comply with RCRA requirements for capping in-place, as described in
Alternative 3. The receiving .landfill is a SCDHEC and EPA approved
Subtitle C hazardous waste landfill that meets location-specific
ARARs. Surface water in the lagoons will be collected and
discharged to the local sewer authority for treatment and will
attain surface water ARARs.
Off-site management of wastes by landfilling would not reduce the
toxicity or volume of the materials. However, long-term mobility of
waste constituents would be reduced. Transporting wastes off-site
could potentially expose individuals using the same roads, or living
or working along the route, to affected GSST materials in the event
of an accidental spill or release. A greater risk is presented by
the amount of traffic required to bring the clay for cap
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construction and to haul the stabilized waste to the landfill.
alternative reduces the incremental risk, which was calculated
current site conditions, by restricting access to the affected
and by preventing future land uses that would allow repeated,
frequent contact with the affected media. Implementation of
Altsrnative 5 would reduce the site carcinogenic risk level to 1 X
10- , and the hazard index for noncarcinogens to 0.14. The
resulting risk assessment considers only those constituents in soil
samples collected beyond the area that would be fenced, since the
fence and clay cap will prevent direct contact with the lagoons.
The limited exposure scenario of future land use was used to
estimate the resulting risks.
A review of the composite cap placed over the affected surface soils
would take place every five years to assure it remains protective of
human health and the environment.
This
for
media
Construction activities associated with this alternative could take
twelve months to implement, allowing time for design, bidding, .
construction, and downtime during construction.
Capital costs of $5,100,00 are associated with this alternative.
Annual costs of $65,000 for 30-year O&M are also required. The.
total estimated present-worth cost of Alternative 5 is $6,100,000.
Alternative 6 - Excavation and On-Site Disposal of Soils
and Sludqes
The components of this alternative include the institutional
controls described in Alternative 2 and excavation and disposal of
affected soils and sludges. Sludge from the lagoons would. be
dredged and dewatered. Dewatered sludge would be combined with
affected soils, while filtrate liquids would be combined with the
collected lagoon water for discharge to the POTW. Soils that
contain constituents exceeding established surface soil target
concentrations would be excavated and transported to an on-site RCRA
land disposal unit. The RCRA land-disposal unit would be designed
and constructed specifically for the disposal of dewatered sludges
and affected soils with constituents exceeding the surface soil
concentrations. A landfill closure would be implemented soon after
the disposal action was completed. The lagoon areas would be closed
by grading to provide proper drainage, followed by seeding to
minimize erosion.
7.6
The on-site, double-lined landfill constructed for disposal of
affected solids would have a capacity of 50,000 cubic yards.
Landfill dimensions' would be approximately 235 feet by 235 feet at
grade. The depth of the landfill excavation below ground surface
would be approximately 15 feet, and the berm height around the
landfill would also be approximately 15 feet. The landfill would be
constructed according to regulatory requirements of the State of
South Carolina and the EPA. These requirements include construction
of a double liner with a leachate collection system above and
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between the liners. The top liner would be designed to prevent the
migration of waste constituents into the lower liner. The bottom
liner would be designed to prevent migration of waste constituents.
South Carolina Codes require a minimum of a three-foot thick layer
of recompacted clay or other natural material, as a bottom liner.
The permeability must be no more that 1 X 10- centimeters per.
second. The landfill cap is required to be less permeable than the
soils immediately below the landfill.
Landfill Operation and Maintenance (0 & M) would include a number of
tasks necessary to protect the integrity of the land disposal unit.
Semiannual inspections and periodic maintenance would be needed on
the site access road, the security fencing, the leachate collection
and treatment system, and the landfill cap and cover, which is
expected to cover approximately 2.' acres.
The long-term effectiveness. of thisa1ternative.wou1d be. provided by
proper maintenance of the on-site landfill. When compared to
capping affected materials in place, removal and 1andfi11ing on-site
offers no greater effectiveness for volume or toxicity reduction.
The mobility of waste constituents will be decreased by placement in
a secure landfill. The excavation of affected soils and sludges to
surface soil targets would result in5a maximum exposure for lifetime
excess cancer risk less than 1 X 10- and a hazard index less than
1.0, which are the criteria established for the risk-based remedial
action target concentrations.
The administrative feasibility of constructing a hazardous waste
landfill on-site at GSST for storage of lagoon sludges and affected
soils is doubtful. At GSST, the likely buffer to residential
dwellings would be approximately 300 feet, and the average depth to
the water table in the area chosen for the on-site landfill is
approximately 5 to 25 feet below land surface. These two factors
make the acceptability of installing a landfill facility at the GSST
site doubtful.
Total capital costs of this alternative are $5,888,000 with annual
monitoring costs of $69,500. The estimated present-worth cost of
Alternative 6 is $7,000,000.
Alternative 7 - Treatment and On-Site DisDosa1 of Soils
and Sludqes ..
Alternative 7 consists of excavation of affected solid materials as
described in Alternative 4; treatment of affected solid materials
using either vitrification, soil washing, or stabilization; and
backfilling of treated residuals into the excavations.
7.7
The following three process options were developed and selected
based on commercial availability and/or a history of prior
application to similar metal-bearing wastes:
ODtion 'A:
ODtion 7B:
ODtion 7C:
Thermal Treatment - Vitrification
Physical Separation - Soil Washing
Physical Stabilization - Solidification/fixation
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For the solid waste materials, the first step in this alternative
would include the excavation of sludge and affected soils having
waste constituent concentrations exceeding soil target
concentrations. Following excavation, the affected materials would
be temporarily stockpiled for processing prior to treatment. The
solid waste material requiring treatment is estimated to consist of
approximately 22,400 in-place cubic yards (28,000 loose cubic yards)
of affected soil and sludge. A sampling program would be conducted
prior to excavation to determine the actual volumes of surface soils
and overburden requiring remedial action. Treatment of soils and
sludge would be required to meet the limits imposed by the RCRA Land
Disposal Restrictions. Treated solids would be disposed of by
backfilling the excavations. A one-foot layer of unaffected native
soil, -and a six-inch layer of topsoil would be placed on top of the
treated residuals. The topsoil would be sown with shallow-rooted
grasses to minimize erosion.
Option 7A:
Thermal Treatment - vitrification
This option includes the use of a transportable vitrification
unit that would be located at the site by a commercial vendor.
The unit would be required-to meet the substantive requirements
of all applicable federal or state permit conditions. This
system would consist of the following unit operations:
Material preprocessing/sorting
vitrification unit
Hood for collecting gases and fumes
Scrubber water treatment
Mobilization and startup of this system may require more than
two years. Startup testing of the system prior to full-scale
operation may also require several months to complete. Assuming
an operation of 10 hours per day, 5 days per week, vitrification
of 22,400 cubic yards would require approximately 130 weeks of
operation.
The vitrification process has demonstrated limited success with
the more volatile metals, such as arsenic, cadmium, lead and
mercury. Arsenic and cadmium were identified in significant
quantities at the Site by the RI. Vitrification technology has
proven that 85-90 percent of the arsenic and 50-60 percent of
the cadmium can be retained in the vitrified monolith. The
vitrification system would be equipped with an air scrubber
system to reduce the emission of these metals in the exhaust
gases. State toxics requirements would have to be met by
emissions from the vitrification process.
Option 7B:
Physical Separation - Soil Washing
Soil washing is a batch process in which soils or sludges are
thoroughly mixed with successive rinse solutions formulated to
remove amenable fractions of waste constituents from the soils
and inert particles. Acid rinses are frequently used to
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1-
solubilize metals, transferring the metals from a solid or
sorbed state to an aqueous phase. The aqueous phase is then
separated from the solid matrix by decanting. The rinsate from
this step is then treated using conventional wastewater
technology for metals removal, such as pH adjustment,
flocculation, clarification, and dewatering. A soil washing
system would consist of the following unit operations:
Material processing/sorting
Reagent storage
Solids mixing
Solids reaction
Decanting and solids washing
Reagent recycling and reconditioning
Process wastewaters would be temporarily stored in on-site tanks
until recycled. Wastewater sludges would be dewatered and
stockpiled. Dewatered sludges would be transported to a RCRA -
approved facility for treatment and landfill disposal in the
event waste characterization of the sludg~ materials indicate
they are a characteristic hazardous waste. For 22,400 cubic
yards of affected solids, a soil washing operation of 10 hours
per day, 5 days per week would require 55 weeks of operation.
Option 7C: . Physical Stabilization - Solidification/Fixation
Physical stabilization is a remediation technology frequently
used for affected soil and sludge. New RCRA restrictions
banning land disposal of hazardous wastes recommend
stabilization, solidification, and/or fixation for a majority of
the characteristic hazardous wastes. This treatment would tend
to reduce the mobility of waste constituents by binding the soil
or sludge into a stable, often solid, matrix that would resist
leaching. Solidification results in the formation of a low
permeability monolith. This solid monolith is preferable to
stabilized, soil-like waste when routine access to the treated
waste is predicted. A solidification treatment system would
consist of the following unit operations:
Material processing/sorting
Setting agent storage.
Puqmill mixing
The effectiveness of solidification has been demonstrated at
many CERCLA sites for a wide variety of inorganic analytes.
Vendors of solidification processes have indicated that
available analytical data from the GSST site indicate that
potential interferences with traditional
stabilization/solidification agents are not present in
sufficient. quantities to impact treatment performance Leach
testing of treatability samples of sludge from the GSST Site was
conducted to determine the feasibility of providing a stabilized
waste exhibiting acceptable quantities and concentrations of
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leachate under test conditions. TCLP analyses of solidified
sludge indicate that solidification with Portland cement is
sufficient over a range of mix ratios to prevent the generation
of leachate exceeding hazardous waste limits. Compressive
strength testing suggests that this solidified material will
have acceptable geotechnical characteristics.
The equipment required for solidification would be similar to
that used for cement mixing. The trea~ed material would be
transported back to the excavation for disposal and curing.
Assuming an average throughput of 25 cubic yards per hour and an
operation of 10 hours per day, 5 days per week, solidification
would .require approximately 25 weeks of operation.
Chemical-specific ARARs are triggered by the action-specific ARARs
for land disposal once the affected soils and sludge are excavated.
The primary performance standards for the technologies analyzed for
this alternative are those imposed by the LDRs for waste
characteristics exhibited by TCLP analysis of the excavated
materials. However, any stabilized/solidified soils and sludges
which are replaced on-site must also not result in exceedances of
health based levels for those constituents established as remedial
action target levels (see Table 18). Results of treatability
studies will be reviewed during remedial design to assure the remedy
is protective of human health and the environment. For the
constituents of concern, LDR concentration-based standards for the
stabilized/solidified soils and sludge ~ust by met prior to
disposal. Location-specific ARARs for soils and sludge will be
attained. TCLP analyses of sludge and affected soils from the GSST
waste management area indicate that cadmium may require treatment to
meet the LDR standard of 1.0 mg/l in the extract. Stabilization is
the BDAT specified for cadmium. Once the LDR standards are met,
there are no ARARs for backfilling the treated residuals other than
local ordinances for erosion control. Backfilled areas will be
managed to comply with these ordinances. Surface water in the
lagoons will be collected and discharged to the local sewer
authority for treatment and will attain surface water ARARs.
Each of the three potential treatment options presented under this
alternative has been shown to be effective in reducing at least one
of the three waste characteristics: toxicity, mobility, or volume,
for one or more of the Site constituents of concern. . This
combination of waste treatment and capping the backfilled residuals
with a soil and vegetative cover meets the EPA's criteria of
permanent remedies that provide for protection of human health and
the environment. The incremental risk afteS implementation of any
of these treatment options would be 2 X.10- for carcinogenic
constituents and 0.17 for the hazard index. Both are within
accepted EPA guidelines for risk exposure.
Because these alternatives will result in treated hazardous
substances remaining on-site, a review will be conducted within five
years after commencement of remedial action at the site. The
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five-year review will be conducted to ensure that the alternatives
described under this section continue to provide adequate protection
of human health and the environment and to evaluate if Federal and
State cleanup standards are still adequate and protective.
Estimated present-worth costs are as follows:
Option 7A:
Option 7B:
Option 7C:
Total Capital Costs = $18,360,000
Present Worth, 30-year O&M c $991,500
Total Present Worth = $19,351,500
Total Capital Costs = $12,800,000
Present Worth, 30-year O&M - $991,500
Total Present Worth = $13,791,500
Total Capital Costs" -
Present Worth, 30-year O&M c
Total Present Worth -
$3,537,500
" $991,500
$4,529,000
7.8
Alternative 8 - In situ Treatment of Soils and Sludqes
Alternative 8 consists of treatment of affected soils and sludge in
place, or in situ. Affected soils located outside of the waste
management area (truck turnaround area and drainage swale area)
would be consol"idated to Lagoon No.4 in the waste management area
prior to treatment. Following treatment, individual treatment zones
will be covered with one foot of clean soil and sown with
shallow-rooted grasses to minimize erosion. Three process options
were selected based on commercial availability and/or history of
prior application for inorganic wastes:
O\Jtion 8A:
Option 8B:
Option 8C:
Thermal Treatment - In Situ Vitrification
Physical Stabilization - In Situ Solidification
Physical Stabilization - In Situ Precipitation
The "surface soil remedial action target concentrations would be used
to determine the treatment boundaries for surface soils. Treated
solids would remain in place. A six-inch layer of clean topsoil,
and a six-inch layer of unaffected native soils would be placed on
top of the residuals. The top soil would be sown with "
shallow-rooted grasses to minimize erosion.
Option 8A:
Thermal Treatment - In Situ vitrification
The In Situ Vitrification system would consist of the following
unit operations:
vitrification Unit
Hood for collecting gas~s and fumes
Scrubber water treatment
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The in situ vitrification process has exhibited a higher rate of
success in capturing volatile metals than the above-ground
process. As temperatures in the treatment zones exceed the
.melting temperature of the soil, the molten soil tends to
entrain many of the more volatile metals, such as lead and
cadmium.
Mobilization and startup may require in excess of two years due
to the lack of commercially available treatment units for
vitrification. Startup tests required prior to operation may
require several additional months. Throughput for vitrification
is slightly lower for in situ materials than for excavated
materials because the equipment must be relocated after each in
situ vitrification cycle. Assuming an operation of 10 hours per
day,S days per week, in situ vitrification of 22,400 cubic
yards would require over 200 weeks o~ operation.
Option BB:
Physical Solidification - In Situ Solidification
This option includes the use of deep soil mixing equipment that
delivers solidification reagent~ to the affected solids during
mixing operations. The process involves augering into the
affected solids to the desired depth using hollow-stem augers.
Treatment agents are injected into the disturbed matrix through
jets constructed in the auger blades. This system would consist
of the following unit operations:
Drill Assembly
Reagent Containers and Feed Systems
Drilling depths are limited, but depths up to 30 feet are
reportedly attainable. Treatment duration will vary by depth
and by the amount of mixing required to ensure adequate
solidification. Treatability studies would be necessary during
the remedial design phase to select the optimal reagent
composition and form. Testing of the solidified treatment
zones would also be necessary.to ensure that performance
requirements are being met.
Option BC: . Physical Stabilization - In Situ Precipitation
This option includes the addition of a precipitation agent to
the affected solids to bind the inorganics and reduce mobility.
Reagents are added to the soils in situ and allowed to percolate
without pressure. A physical stabilization system would
consist of the following unit operations:
Reagent Mix Tank
Reagent Delivery System
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,-
The expected efficiency for this 'option is site-specific.
Treatability studies are necessary for evaluation of in situ
precipitation prior to remedial action. In addition to
evaluating the parameter-specific effectiveness of the treatment
process, the treatability study would focus on such physical
properties as soil permeability and grain-size distribution.
According to EPA guidance on the applicability of LDRs to CERCLA
Response Actions, consolidation of the surface soils for treatment
with in situ wastes will not require a waiver for the RCRA Land
Disposal Restrictions. The LDRs will be met by treatment of the
consolidated surface soils in this alternative. Surface water in
the lagoons will be collected and discharged to the local sewer
authority for treatment and will attain surface water ARARs. A
portion of the lagoon water may be used as an ingredient of the
solidification process.' .
The minimum level of overgll protection provided by in situ
solidification is 1 X 10- for the lifetime excess cancer risk and
0.17 for the hazard index~ The additional protection offered by
stabilization/solidification is further enhanced by the short-term
protectiveness gained from treatment without excavation of waste
materials. Furthermore, the risk of potential releases off-site
during transportation to, and disposal at, a TSD facility will be
eliminated by t~is alternative.
Because these alternatives result in treated hazardous materials
remaining on-site, a review will be conducted within five years
after commencement of remedial action at the site. This review will
be conducted to ensure that the alternatives discussed above remain
effective in protecting human health and the environment.
Estimated present-worth costs are as follows:
Option 8A:
Total Capital Costs = $12,219,000
Present Worth, 30-year O&M - $991,50~
Total Present Worth = $13,210,500
Option 8B:
Total Capital Costs = $3,089,107.
Present Worth, 30-year O&M = $991,500
Total Present Worth = $4,080,607
Total Capital Costs = $3,314,807
Present Worth, 30-year O&M - $991,500
Total Present Worth = $4,306,307
Option 8C:
7.9
Screenina of Remedial Alternatives
Prior to the detailed analysis of alternatives in Phase III of the
FS, the eight alternatives presented in this section were screened
to eliminate alternatives that were inappropriate, not
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implementable, or clearly not cost-effective. The following
discussion provides the rationale for eliminating Alternatives 6,
7A, 7B, 8A, and 8C prior to the detailed and comparative analysis of
alternatives in Phase III of the FS.
Alternative 6, Stabilization and On-Site Disposal of Solids, was not
retained for further consideration. The administrative feasibility
of siting a hazardous waste landfill at the site is very doubtful
due to community acceptance and various technical complications.
Neither the volume nor toxicity of affected solids would be reduced
by the implementation of this alternative. Mobility would be
reduced in a properly-constructed landfill, but long-term
maintenance would be essential for protection of the environment.
Alternative 7, Option 7A, Thermal Treatment (Vitrification) and
On-Site Disposal of Solids, was not retained for further
consideration. This option's technical feasibility has not been
well demonstrated for metal-bearing soils and sludges. The process
does not appear capable of treating volatile metals, such as arsenic
and cadmium. The level of risk reduction associated with this
option can be achieved by other remedial alternatives in a more
cost-effective manner.
Alternative 7, Option 7B, Physical Separation (Soil Washing) and
On-Site D~sposal of Solids, was not retained for further
consideration. This option would reduce waste constituent
concentrations in solid materials. Its technical feasibility has
been demonstrated for many of the identified waste constituents. It
may provide an effective means of reducing toxicity and volume.
Treatability testing would be required. However, washing sludges
generates large quantities of hazardous wastewater that require
further treatment prior to disposal. "Treating sludges to generate
sludges" was not considered practical and therefore, not retained
for further consideration.
Alternative 8, Option 8A, In Situ Thermal Treatment (Vitrification),
was not retained for further consideration. This option's technical
feasibility has not been demonstrated in the field. The level of
risk reduction associated with this option can be achieved by other
remedial alternatives in a more cost-effective manner.
Alternative 8, Option 8C, In Situ Physical St~bilization
(Precipitation), was eliminated for detailed evaluation. The
effectiveness of this alternative is questionable at the GSST site
because of the .uncertainty of contact between waste constituents and
precipitation agents. Not enough is known about the long-term
effectiveness of precipitation to justify additional consideration.
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,-
8.0
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
During Phase III of the FS, the alternatives retained for further
consideration and described in Section 7.0 were analyzed in detail
using the nine evaluation criteria. A comparative analysis was
conducted to determine which alternative provides the best balance of
tradeoffs with respect to the following nine criteria:
Threshold Criteria -
1) Overall Protection of Human Health and the Environment;
2) Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs);
Primary Balancina Criteria -
3) Long-Term Effectiveness and Permanence;
4) Reduction of Toxicity, Mobility, and Volumei'
5) Short-Term Effectiveness;
6) Implementability;
7) Cost;
Modifvina Criteria -
8) State/Support Agency Acceptance, and;
9) Community Acceptance.
Table 16 provides a summary of the comparative analysis of
alternatives for the Golden Strip Septic Tank ~ite. The information
presented in Table 16 is presented to provide a site-specific
comparison between alternatives with respect to the Threshold and
Primary Balancing Criteria. To the extent that differentiation is
possible between remedial measures, the alternatives are ranked
according to the relative degree to which each satisfies the
criteria. Where the benefits of one alternative are similar to those
of another, the alternatives are assigned the same numeric value.
The numbers listed in the last row are cumulative scores of the
rankings for each alternative. These numbers are summed to show the
degree of relative, compliance with the seven Threshold and Primary
Balancing Criteria. The ranking system is designed so that the
alternative with the lowest score provides the greatest degree of
compliance with the seven criteria. The summary of alternative costs
is provided in Table 17.
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TABLE
16
COMPARATIVE ANALySIS OF AlT,ERNAnves
GOLDEN STRIP SEPTIC TANK FEASIBILITY STUDY
A"-.4 AIIemetIv. I AIem8IIwe ,
AI......,.. 3 Slebllb....... end OII-SIIe SI............. end ~ T........ end 0It-8Ie
AI.ntllv. I AI.,n8llll. 2 OIo_eI aI Sludge end AIenMIIw I
No AcIIon 1neIIuII...... eor..... ~... ..Solidi OI._eI aI 8GIIdo ConIeI- aI AI""" ..... 0I0pM0I" .... " .. T....... .. 8aId8
DeMrIptlon . Auurne. ......... ... 0.... _8IIan CoIled ~ .... .nd CotItd 18I1DOn .... end pump CoIItct I8goon - end CoIItcIC Itgoon ..... 8IId CoIItcIC Itgoon .... end pump
-.dIIIon. ...wno.-. tnd con- pump III _. O,td. 10 .-. Eoc.volt 8IId pump 10 .-. Eoc......"" pump III -. &c8v- It _. ContaIIdtIt.ocItd
tddllontltonclnll. end cop tIudgo .nd .loc.pIo .ludll' end eIIoct... tloc.", .Iudgt. SItbIIa. oIudgt end tIItcItd -. -'- 0010 Into Ugoono I
ell...... oaIt. 0.... .01.. 6101>ll1...nd II_pool tnd b.nopoll tIudgo 10 ...... T.... wIIh ooId8ottIon. end 4. T'."" 1811-
I c""tOlY.1Ion _0.-. .nd told. 10 01.". 1tncI1I. 0<- """11. 0.- end cop BtcId8......... Add C""" end 0010 -..........
contlntcl tddMIonel .nd odd Iopool. ..... ...... ...cIod...... Cr- IoptoI. II*! "'- end .... .........- 001 ....... Irov~
lonclnll. C,.... C0n88fY81kM1 e8Hm8nl con._oIIo.. -.. end 0.... _lion wUlln ... ooIdIIcalion. Add
contlruct ................... ..--. ........ ..... ..... - ....
c..... _t8Ion _monl
er.....
Owtt.. praltalon No chango In ""'ng ,.. .......... -.tel ,.. -....... -.tel ,.... "'nollvo ..... ,..... In 'hi. "..nollv. -.tel ..... In ThII ........... ..... ..... In "* ....... .... .... In
aI hum... ....... condlllon.. -... In on upptt bound ,..... 'In on upptf bound .n upptt bound ..... c.... ... upptt bound .c- - ... upptt bound - 811 upper bound --
-... 'ho CUII.nll8nd Ut. ...c_.-.... aI ..c... c- ,... aI .... lot. -. I . 10. tnd . tit. all . 10. end . ........ _.""alI810._. .... II 1 8 10. end . ........
_Of""'" - I... .... . . 10. end . ........ I . 10. - . ....... h..... 1ncIe. - II*! 1.0 lor Indo. aI 0.14 lor 1181"" ...... .. 0.17 lor ...... .. 0." lor
- ........ ...... .. 0.' 4 lor ....... aI 0.14 lor ........,cInogeItIo _. Thlo noM"OInog""". ThIo MM8fOInog"""" ThIo ---.......... ThIo
In on upptf bo..... _olnollonla 01_. noncarolnogorH .Iect.. "..nollv. pfe,vld.. ............. "..nollva ............ ............ ,.......... ........... pr"""'" ..............
..c... c-. rII. aI T" ............ .-.. 10 Thl. .. .....ello ... ..oct. ,..novel aI ... ........ told. ,tduc.. ... """Ittnt ... "" ",'_11_"'" -..... ...... toIdt
2 . 10' tnd . ........ p,,,,,,. cllroot -.01.... I... AIIo. 2.4.1, '. -. .oquIclng ,emtdlel tctIon, 11<11 bill ... thot\.- .... It ....... .... ........,. ttqWIIng......... ..... "I
...... all.' lor ... ..... .urtec8 "'.i bee.... 8ech MfV.. to ... .hool I..m ,10. It Ine....... II'.". ..... ... aI ... ... ,......., aoIIon. CII
........clnogonlo h_-. .... ..m."" hot pitY"" ...... cone... wilt OWIf Ala. I end a. PI ""n"""'. C4I
tII- (I) IIIIIt p"""",,,,, tBt. tho - -'IC. ..... ...
11"- ""m_c. "on
provld." by AI. 2 end ....
"""""m .... "'.n
provtdtd by AI. I 151
c:o.n,tI_. wIIh WII .oq'" . ....... W1I ..... ...... aI W8 _MARl. 1'1 WII- AMRa. "I W1I - AAAA8. III WII.... AAML III WII.- AAML ............
AIWIt of ourtooo .- .urt- -.. AAARo. lilt -.... '.....
NWIt. lilt ............... ... not
........ ............. 80 UIAI
...., oppIotIIIa. C'I
.
I
N
o
r'4
I
-------
TABLE
J
16
COMPARATIVE ANALYSIS OF ALTERNATIVES (conlt
GOLDEN STRIP SEPTIC TANK FEASIBIUTY STUDY
~4 . AII8m8IIw8 I ........ 7
........... end 0II-8II8 ........... end c»aII8 ,...... end Qo.8I8
Allemollw I All......... Z A""""'" 3 OIopouIoI 8Iudge MIl AI8nIIIIwe .
N. _on ..- c.... ~ 01 SoIIde OIopeMIoI ~ ~,. All........ ....... ,...... ".. ,-.. 01""
~ 0.--' - - ... ....... In _1ncN_~ -- ,..,.......- """--' .. .......... T_"_.. T.-.t.. ............ -
...~ .-..... .. ... --a8ne dIr... ....... - .... ......... br AI. Z - hi powIdecI br AI. 2 br ........... - ..... end ....... ..... ........ ......... - .....
....... In ........ ......., .end .......... br ............. lid ,. dIr... -tne end II"'" ..... ceppInf ... ...,..... - - ............ ........ ........,.
......... """..Ion 1uIuI. ............ ...... -151 .... -...... .......... ........ .......,.... ..... IIL-III..- 11a IIHI -- 11a
,,- .. ........ .... lit 8CtIon ......... Ila ......... ....... ........
..... .... ...!:It 41- 14.
-.Iootng .. be
........ In ........
......... ..... to
....... fill
.......... ,. - .............. -.....- _.........- 01 --_-.tel --.........- ,...... T"""""""-"'" 'N-"""""'-
....... """'... .- -... to ................. to .. - ..... c........... W .- ... end ..... to"'" _end- ........ - --. ---
- .. 1- ...... ..,.. - AI. I. lit _. - ",........., Of .....,. 1'1 --....... --..... ........ ............. ............ .............
............ '" ...... 01 ,,__,._AII.2. .....,wIng ..- II alt. - .1 .. ...,..,., Ila """'--10
doer"""'. III (!It - AI. 3. 14,
"*"'- No_on'" - .......... ..,.. 01 ... _II"''''' ... ........... - -..... ... ......-.- -..... ....-..- - ... ............ - .....
"'-...- -_In'" 11- ..~ V- 01 .... ....."",.oIIIe. V- 01 ....lit lb.. V--"'" -.................. II "I """8 ..... v..-,......
....... -.......... .............. ..... 10 hili II'" .-.- -- IruoIo II'" ....... ......... .... ........ ....... V... ,. .... II II1II II naI .......... ,........ IIIIf
....... ...... II hi If AI. 1. fit ...... ..........-. (!It ............ lit ohofHomI~ Pa ......... Pt ..... longer .... .. AI. 7. 14.
.............
........... Iia
III...,.. ....., IIMdIIW EquII..AI. 1.111 ....... ...., ..- .......oIIon II ....... ...... ........... ......... . 8.,..,... ,......... ,....... ~.."...
...,............. ..... ............... No""" II ..-...........,.. ...... 011 .......... II ~ .... - "'* 11..-. ~ 1?'lnlllllll....
..... 18ohnaIovr. TSO .....,......,. Pt ~ II ...... .......... ............ ........ """'.141 ~ No""" TID
Iia loci.,. Aoquhe .......... Pa ........., .. ...... ...... .............. MIghI be -
'8CI..,. ....... ......... ............... -- AI. ,
181 ...... UIAI cion' lIP",. Ii!I
Cool ~ honge III l- ..... fit l- 10 .......... A8ncJI PI ...... RInge VI .............. " ...... ...... ..... " .... .......... ....... C4a
OUIII 11~. -- 21 II 17 21 » II 17
SO~RCE: RMT, INC. 1991
.
I
M
o
....
I
-------
TABLE 17
COMPARISON OF COSTS
FOR PHASE III ALTERNATIVES
Annual Monitoring
Alternative Preaent-worth Capital Cost and Maintenance
Coat Cost (30-yr)
1. No action S 1,300,000 $ 60,000 $ 83,000
2. Institutional Controls $1,400,000 $ 81,000 . $ 83,000
3. Containment of solids -
a. Composite cover S 3,200,000 $ 2,200,000 $ 65,000
4. Treatment and off-site $ 12,500,000 $ 11,500,000 $.65,000
disposal 01 solids
5. Treatment and off-site
disposal 01 sludge and
containment of affected
sOils- $ 6,100,000 $ 5,100,000 $ 65,000
7. On-site treatment and -
disposal of solids
c. Stabil~ation $ 4,500,000 $ 3,500,000 $ 65,000
8. In Situ treatment of solids
_.
b. In situ stabilization $ 4,100,000 $ 3,100,000 $ 65,000
SOURCE: RMT, INC. 1991
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Discussion of the relative performance of the alternatives with
respect to the nine criteria is included below.
8.1
OVerall Protection of Human Health and the Environment
This criterion addresses whether a remedy provides adequate -
protection and describes how risks posed through each pathway are
eliminated, reduced, or controlled through treatment, engineering
control~, or institgtional controls. EPA has established a limit of
1 X 10- to 1 X 10- as acceptable limits for excess lifetime
carcinogenic risks. EPA has also established that a hazard index
rating exceeding 1.0 for non-carcinogenic constituents suggests
potential concern for toxic effects in sensitive portions of the
exposed population.
All alternatives, except Alternative 1 (No Action), bring the
exposure levels for carcinogenic and non-carcinogenic constituents,
within acceptable risk ranges for human health. Alternative 7C,
Solidification/Fixation and On-Site Disposal of Soils and Sludges,
and Alternative 8B, In Situ Solidification provide the greatest
degree of protectiveness of human health and the environment. -The
affected materials would be solidified to immobilize the waste
constituents, making the constituents unavailable for migration
through any pathway. The protectiveness is also increased by the
"capping effect" provided by the solidified materials over the less
affected subsoils containing waste constituents. Implementation of
these altesnatiyes would result in an upper bound excess cancer risk
of 2 X 10- and a hazard index of 0.17 for non-carcinogenic
effects.
Alternative 4, Stabilization and Off-Site Disposal of Soils and
Sludges, provides permanent-removal of the affected materials
requiring remedial action, but the short-term risk is increased due
to the volume of truck traffic necessary to transport the materials
off-site. Alternatives 2, 3 and 5 all provide the same degree of
protection of human health and the environment. Containment
alternatives provide some protection to the environment by minimizing
migration of waste constituents due to erosion pathways and
infiltration of precipitation. However, this protectiveness is less
than that provided by the treatment Alternatives 7 and 8.
ComDliance with ADDlicable or Relevant and ADDroDriate
Reauirements IARARs)
This criterion addresses whether alternatives will meet all of the
ARARs of other-Federal and State environmental laws and/or justifies
a waiver.
8.2
Alternatives 3 through 8 will comply with all chemical-specific,
location-specific, and action-specific applicable or relevant and
appropriate requirements through the respective remedial actions.
Alternative 1, No Action, and Alternative 2, Institutional Controls
do not comply with surface water ARARs since collection and discharge
of impounded surface water in Lagoon Nos. 1 and 4 is not included as
part of these alternatives.
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8.3
Lona-Term Effectiveness and Permanence
This evaluation criterion refers to expected residual risk and the
ability of the alternative to maintain reliable protection of human
health and the environment over time, once clean-up goals have been
met.
Alternatives 4, 7 and 8 provide the greatest degree of long-term
effectiveness and permanence. Alternatives 7 and 8 will effectively
immobilize waste constituent source areas, providing long-term
effectiveness. Alternative 4 will remove and treat affected soils
and sludges that exceed remedial action target levels and dispose of
the treated residuals in an approved RCRA landfill. These three
alternatives provide a greater degree of permanence than the other
alternatives considered in this comparative analysis.
Alternatives 2, 3 and 5 provide a lesser degree of long-term
effectiveness and permanence. Alternative 5, Stabilization and
Off-Site Disposal of Sludge and Containment of Affected Soils, will
eliminate constituent source areas, and will control direct contact
pathways with residuals through capping of affected soils.
Alternative 3 will provide greater long-term effectiveness than
Alternative 2 by eliminating the risk of-direct contact. However,
Alternatives 2 and 3 result in the most-concentrated source of waste
constituents remaining on-site with no treatment.
8.4
Reduction of Toxicity. Mobilitv. or Volume
This criterion takes into account the anticipated performance of the
treatment technology a remedial alternative may employ.
Alternatives 4, 7 and 8 provide the greatest degree of reduction in
toxicity, mobility, or volume. Alternative 4 will reduce the
mobility of both the excavated materials and the remaining soils.
The solidification process of Alternatives 7 and 8 will adequately
treat the COCs, resulting in a great reduction of mobility and
toxicity of waste constituents. Alternatives 7 and 8 greatly reduce
the exposure potential of waste constituents due to soil and sludge
treatment,- backfilling with treated soils, covering with clean soils,
establishing a vegetative cover and long-term monitoring-.
Solidification is estimated to increase the total volume by 5 to 50
percent, depending on the type and quantity of additives used.
Alternative 5 will reduce the mobility of the excavated sludge
material by stabilization and the remaining affected soils by
capping. Alternative 3 also consists of capping the entire waste
management area. Capping will minimize infiltration of precipitation
and prevent erosion. Toxicity and volume may be slightly reduced
over time to the extent that natural degradation of organic
constituents occurs. Institutional controls associated with
Alternative 2 reduces the waste characteristics to the same degree as
No Action.
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8.5
Short-Term Effectiveness
Alternative 1, No Action, presents no effect on the environment in
the short-term and, therefore, provides the greatest degree of
short-term effectiveness. Alternative 2 will provide a degree of
short-term effectiveness approximately equal to alternative 1.
Approximately 28,600 cubic yards of materials containing COCs at
concentrations exceeding remedial action levels will be excavated and
treated under Alternative 7. Site disturbances due to excavation and
material handling are extensive, but manageable. Dust emissions
during excavation and treatment can be effectively controlled with
standard engineering controls such as increasing the moisture content
of the materials. Alternative 8 provides approximately the same
degree of short-term effectiveness of alternative 7, however,.
fieldwork may take longer to complete than alternative 7.
Site disturbances for Alternatives 3, 4 and 5 are extensive due to
the volume of truck traffic. Alternative 3 requires extensive truck
usage due to the volume of clay required to construct the protective
clay cap. Source removal and off-site disposal of waste material
under Alternative 4 would require approximately 800-1000 truckloads
of stabilized waste at 20 tons per truckload. Alternative 5 would
pose similar truck traffic management problems. The volume of truck
traffic required for these three alternatives significantly reduces
the short-term effectiveness.
8.6
ImDlementabilitv
This criterion refers to the technical and administrative feasibility
of an alternative, including the availability of materials and
services needed to implement a particular option.
Alternatives 1 and 2 are easily implemented using existing
technology. Containment of waste constituents under Alternative 3
also utilizes existing technologies and does not require the usage of
a treatment, storage, and disposal facility.
The stabilization and solidification processes proposed for
Alternatives 4 through 8 have been routinely applied with successful
results to soils that are typical in the Piedmont region of South
Carolina. However, the in-situ solidification (Alternative 8)
process has not been well demonstrated for typical site soils or for
the large areas requiring treatment at the site. The materials
handling issues may be significant at the GSST site for alternatives
requiring dewatering of the sludge. Dewatering may be cost-effective
for stabilization of the sludge prior to transport and disposal
(Alternatives 4 and 5), since dewatering lowers the bulk density of
the stabilized materials. The solidification processes of
Alternatives 7 and 8 may also require dewatering of the sludge to
meet treatment standards. The stabilization and solidification
treatment processes proposed for the GSST site should prove to be
reliable, based on available information, although the in-situ
process is more likely to experience operational difficulties.
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8.7
Cost
This criterion estimates the total cost required to implement an
alternative and includes the estimated capital, Operation and
Maintenance (O&M) costs, and present-worth costs. Table 17 provides
a comparison of costs for all alternatives discussed in this section.
Alternatives 1 and 2 provide remedies that are in the low range, but
offer no treatment of the source material. The treatment
alternatives (Alternatives 7 and 8) provide remedies with a high
degree of permanence at costs that are mid-range for the alternatives
evaluated in Phase III of the FS. Containment alternatives achieve
the same level of risk reduction for approximately 40 percent less
cost, but with a lesser degree of permanence. The source removal
alternatives (Alternatives 4 and 5) also achieve substantial risk
reduction in terms of future exposure to waste constituents, but the.
short-term risks are greater than for the other alternatives, and the
costs are significantly higher.
8.8
State/Support Aqencv.Acceptance
The South Carolina Department of Health and Environmental Control
(SCDHEC) has been actively involved in the RI/FS and the remedy
selection process at the Golden Strip Septic Tank site. SCDHEC
provided valuable input during the finalization of the RI/FS document
and the Proposed Plan. SCDHEC has reviewed this Record of Decision
and concurs with all aspects of EPA's selected remedy except the
methodology utilized to determine the remedial action target level
for arsenic. SCDHEC's concurrence letter on the selected remedy for
the GSST site is." included as an attachment to this Record of Decision
document.
8.9
Communitv Acceptance
EPA solicited input from the community on the Proposed Plan for
clean-up of the GSST site. Although public comments indicated no
specific opposition to the preferred alternative, some local
residents did express concern over the actual degree of permanence of
the selected remedy and depressed property values in the neighboring
area. These issues are addressed individually in the attached
Responsiveness Summary. .
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9 . O. THE SELECTED REMEDY
EPA has selected Alternative 7C, Solidification/Fixation as the
remedy to address the contaminated surface soil and lagoon sludge at
the Golden Strip Septic Tank site. The remedy for the cleanup of the
Golden Strip Septic Tank site consists of the following components:
9.1
Contaminated Surface Soils/Laaoon Sludaes
Constituents of concern at the site were identified as part of the
Remedial Investigation and are listed in Section 5.5 of this ROD.
The Baseline Risk Assessment, which is summarized in Section 6.0 of
this document, developed remedial action target concentrations for
the identified COCs in the soil and lagoon sludge. Since no federal
standards exist for toxicants in soil, health risk-based calculations
(under the Future Land Use Scenario 12 which assume~ a residence at
the site) were used to derive cleanup levels for most contaminants in
soil and sludge at the site. Cleanup levels for lead are based on
other EPA guidance for Superfund sites. Table 18 displays these
remedial action target concentrations for contaminated soil and
sludge at the site.
For noncarcinogens, a target hazard quotient of 0.3 was used to allow
for exposure to multiple contaminants6whose effects may be additive.
A target carcinogenic risk of 1 X 10- wag used for all carcinogens
except arsenic. A target risk of 1 X 10- (still well within EPA's
targeted risk range) was used for arsenic for the following reasons:
- EPA believes that the relationship between the high
which the slope factor is derived and the low doses
occur as a result of site-related exposures may not
as is assumed in a risk calculation;
- There is some evidence suggesting that arsenic may be an
essential element for humans; and
doses from
that would
be as linear
Arsenic is naturally occurring in the environment.
A target risk of 1 X 10-5 for arsenic translates into a cleanup
concentration of 18 pgm. The State of South Carolina feels that a
risk level of 1 X 10- should be used to establish c.leanup levels
for arsenic at the si~e. Since the arsenic cleanup level calculated
for a risk of 1 X 10- would be below the background range for
surface soils at the site, the State feels the background range,
0-3.5 ppm, should be the cleanup level for arsenic at tge site. EPA
feels that a cleanup level of 18 ppm based on a 1 X 10- risk
calculation is adequately protective of human health and the
environment based on the reasons noted above. This cleanup level of
18 ppm for arsenic at the si~e is still within EPA's targeted risk
range of 1 X 10- to 1 X 10- . .
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TABLE 18
REMEDIAL ACTION TARGET CONCENTRATIONS [a]
SOIL AND SLUDGE
GOLDEN STRIP SEPTIC TANK
CONSTITUENT REMEDIATION TARGET [b]
CONCENTRATION (mg/kg)
Antimony 26
Arsen ic '8
Cadmium 65
Chromium [c] 580
Copper 2.400
Cyanide , ,300
Lead 500
Mercury 20
Nickel , ,300
Zinc' , 3,000
Acetone 6,000
bis (2-Ethyl hexy I) p hthala te 200
2-Butanone 3,000
Chlorobenzene , 200
1 ,2-Dichloroethene (total) , ,200 -
Ethylbenzene 6.000
Methylene Chloride 380
Styrene 95
Tetrachloroethene 56
Toluene 12,000
1,1, , -Trichloroethane 5,500
Xylenes (total) 120,000
[ a] . Remedial Action Target Concentrations based on a carcinogenic risk of 1 X 10.6
(arsenic is based on a carcinogenic risk of 1 X 10 - 5) or a hazard index of 0.3.
[ b ] - Remedial Action Target Concentrations based on most conservative exposure scenario
(Future Use Scenario #2) assuming a residence at the site, and is discussed in
Section 6.0 of this Record of Decision.
[ c) .Chromium concentration includes assumption that 10% of total chromium observed
is in the hexavalent state.
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The objective of this remedy will be to reduce the mobility of
waste-containing materials, while minimizing the potential for human
health and off-site environmental exposure to hazardous substances by
a combination of the following factors:
- Treatment by solidification of soil and sludge that exceed the
remedial action target concentrations listed in Table 18;
. -
Backfilling the treated residuals in the on-site excavations
that will result in a solid, low permeability monolith that
resists leaching;
- Covering the on-site excavations with clean soil;
- Establishing a vegetative cover that will prevent erosion; and
- Long-term monitoring to ensure the solidified monolith remains
effective in providing adequate protection of human health and
the environment.
The first step in implementing this remedy is materials excavation
and preprocessing. Approximately 22,400 cubic yards of soil and
4,200 cubic yards of sludge exceed the remedial action target
concentrations listed in Table 18. Investigation of the abandoned
drum area on the eastern side of the Rice Farm has indicated the
presence of cadMium and chromium at concentrations above remedial
action target levels. The extent of this contamination shall be
further investigated during the RD/RA phase of the project. Limited
remediation of this area is anticipated, however, the volume of
material exceeding target levels is not expected to significantly
increase the volumes noted above. Figure 12 illustrates the
conceptual layout of the remedy.
A sampling program shall be developed and conducted prior to
excavation to determine the actual volumes of surface soils,
overburden, and sludge requiring remedial action. Confirmation
sampling shall also be conducted following excavation and prior to
backfilling treated materials to ensure the underlying soils have
been excavated to the appropriate concentration$ listed in Table 18.
Placement of hazardous waste as defined by the .Resource Conservation
and Recovery Act (RCRA) Land Disposal Restrictions (LDRs) is not
applicable to this CERCLA response action. The Area of Contamination
(AOC) at the site shall.be delineated by the areal extent, or
boundary, of contiguous contamination. The AOC shall consist of
approximately 10 acres that includes the five waste lagoons, truck
turnaround area and the drainage swale area. According to RCRA,
placement does not occur when wastes are moved within a single AOC.
All excavated wastes as part of the selected remedy in this ROD shall
be consolidated, pre-processed and treated within the established
Area of Contamination.
-111-
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- --.
. .
. /u/:. I / .
- " v - '<'Y/ ,.N V'/ /
~"~ x ..... TO '/- ~~ ......, : ~
~ ~_~~d ~ ~'{::~-= ~~
~ ~ '-/ //.--....." ~ tf////'" ..... :
- "" , ':3f' //1 ~ r: rf///f~'/. . .,
-=- ~ f/ .~ 'j 0: /! ...
~" J - ~. /' \ ".;"Y (0:; '., ::-..-.
~~ 0':~'~'~~ ~r,'-' '("'~~~~~'0 " ~ ~~~f0: .. :. ....-
)/t i'\1 5.J \. '~~/~~~1 IW1 I ('( -='::~~..."..uouu'
1/) i ~ J- '/) ~\."-L---/:-s... .~i:J.\ ! .".-..-
II; ~~' )~~J'(r~ ~ ~< ~~. ~.' .~~~.~~ \~'I\~\~~ \ ~~~::~-
~ ~)i b ~> '- ~ :\:"'..~ . . ,., ,',11 , . --.-.----
.... a / "} L -", -=-- ~ ....1 .,...'. //L . ... IKU_"- ...- .-.
'" . ~ (// -'<:-" ../ . . ," '-..... I't,.. . : -....-
M ~ ~ ~ ~// '/ .~ f!;I; . r1.VII ' ........ [7: ,~
---:: ~\~?/J)" 'l"/~'0) V'- ((X ~}.l\' ~. ~ .-:s-
- ~~ '\.'\. "'f< J' [~/-0: // ~ - "'~ .:~ , ~~
:::::::::;:;-.~~~~\~~~~ ...)~..~~~.~ ~f'''~~~\\\'~~~ . --: ~, - ~ M
. '~t-2' ~///"'; , ~ ~~'i~.~,; "'-........ O~
~; ~~ ,,-~-.:;;;;~~~ . ~¥if.:~~ ~ ~~
~ ~~~~ ./'.~ 'Sd" TSWAlEAREA~ ~"- --....u-.J~~
. ; ~= ~ ~ M~ . 'f 'i\\~~"-..-::::~~!::f ~
-:/: .:.~ ~~ ._'~ ~~-,' ~~~ ::;;;r"!':::F:~ .
i ~.. ~~'< 7,' ~- \\\ ~'~~ =0.- -. ,.,- s:;~-=.
f? ~~~ ~ l ~\ ~ \ .' j.----- ~ ~.." :::...... --a
Icl~ '" ":' ~~ ... :--.\, ,l~\' ......,..''''. ~~ ......' FIGURE 12
7. '. . >--~ - ;~~""""---"--l,k ,.~'=.~~="~~: CONCEPTUAlLAYQUT
,i ~~~"~~i'\\'===-"""~~ ,.-//, E;;'-."" SB.ECTEDREMEDY-GSSTSITE
1- ~ SOURCE,RMT.INC'99'
-------
Additional waste characterization of lagoon waste was conducted as
part of the Remedial Investigation. TCLP analysis results of lagoon
sludges and affected soils indicate waste material at the site
exhibits hazardous characteristics for cadmium. Due to the presence
of characteristic RCRA waste at the site, LDRs are applicable to this
response action. Treatment by solidification shall render the waste
present at the site as "uncharacteristic" for the applicable Federal
regulatory standards. Established TCLP regulatory limits for the
COCs present at the site are delineated in Table 19. Treatment of
waste material at the site shall meet these promulgated Federal
standards. Furthermore, the solidified monolith must demonstrate the
applicable geotechnical standard for ultimate compressive strength of
50 psi.
Additionally, further assurances shall be conducted to ensure the
treated monolith leaches at a concentration that is protective. of
ground water at the site. This requirement is considered to be a
relevant and appropriate requirement of treatment by solidification.
Dispersion modelling shall be conducted to ensure the treated
monolith will not impact the ground water in an adverse way. If the
regulatory TCLP limits displayed in Table 19 are proven ineffective
in providing adequate protection of. ground water at the site, more
stringent levels shall be established that will be protective of the
ground water.
The effectiveness of solidification has been demonstrated at many
CERCLA sites for a wide variety of inorganic ~nd low level organic
analytes. Treatment of heavy metals by solidification is the Best
Demonstrated Available Technology (BDAT). Leach testing of
treatability samples of sludge from the site was conducted to
determine the effectiveness of solidification in providing a treated
monolith that would exhibit acceptable quantities and concentrations
of leachate under test conditions. TCLP analyses of solidified
sludge indicate that solidification with Portland cement is
sufficient over a range of mix ratios to prevent the generation of
leachate exceeding hazardous waste limits. Compressive strength
testing suggests that this solidified material will have acceptable
geotechnical characteristics.
Further treatability and leach. testing will be necessary to determine
the appropriate combination of solidification agents and additives to
provide a stabilized waste exhibiting acceptable quantities and
concentrations of leachate under test conditions. Field trials will
be required to confirm treatment effectiveness and to determine the
physical and chemical characteristics of the treated residuals.
Following treatment, the treated residuals shall be disposed of by
backfilling the on-site excavations. A one-foot layer of unaffected
native soil, and a six-inch layer of topsoil shall be placed on top
of the treated residuals. The topsoil shall then be sown with
shallow-rooted grasses to minimize erosion.
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TABLE 19
TOXICITY CHARACTERISTIC LEACHING PROCEDURE
REGULATORY LIMITS
TREATED/SOLIDIFIED WASTE
GOLDEN STRIP SEPTIC TANK
CONSTITUENT TCLP REGULATORY LEVEL
(mg/l)
Vinyl Chloride 0.2
1,1-Dichloroethene 0.7
Chloroform 6.0
1,2-Dichloroethane 0.5
2-Butanone 200.0
Carbon Tetrachloride 0.5
Trichloroethene 0.5
Benzene 0;5
Tetrachlorethene 0.7
Chlorobenzene 100.0
Arsen ic 5.0
Barium 100.0
Cadmium 1.0
Chromium, total 5.0
Lead 5.0
Mercury 0.2
Selenium 1.0
Silver 5.0
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Because this remedy will result in a treated monolith of hazardous
substances remaining on-site, a review shall be conducted no less
often than every five years after commencement of remedial action at
the site. The five-year review shall be conducted to ensure that the
selected remedy continues to provide adequate protection of human
health and the environment and to evaluate if Federal and State
cleanup standards are still adequate and protective.
9.2
Ground Water
Three rounds of ground water sampling and analysis were conducted as
part of the RI and Supplemental RI field activities. The ground
water results from these events indicated that limited migration of
waste constituents has occurred. Results from the RI sampling
indicated four contaminants in ground water that exceeded Maximum
Contaminant Levels (MCLs). These contaminants were chromium, lead,
1,2-Dichloropropane, and 1,2-Dichloroethane. Subsequent sampling,
which took place as part of the Supplemental RI, revealed that 'most
detections were not reproducible in individual wells, and few
detections exceeded MCLs. No contaminants were detected above
background concentrations in the nearby stream.
The establishment of Alternate Concentration Limits (ACLs) for ground
water at the site, as described in Section 121 of CERCLA, is included
as part of this response action. The applicability of ACLs at the
Golden Strip Septic Tank site is discussed in detail in Section 4.2
of this document. EPA believes that active aquifer remediation of
ground water at the site is not reasonable or technically
practicable. The low and sporadic detections in the aquifer, and the
absence of contaminants in the stream led to the decision to develop
ACLs for the ground water monitoring, rather than initiate aquifer
.;:'emediation. '
The ACLs will be based on two criteria; 1) that ground-water
contamination does not increase, and 2) the creek near the site is
not adversely impacted. Ground water samples from monitoring wells
will be collected and analyzed to determine if contamination is
increasing and stream samples will be collected to determine if
contaminant levels increase above background levels in the creek~
The National Contingency Plan (page 8732) states that;
"ACLs under CERCLA generally considers the factors specified for
establishing ACLs under RCRA with several additional
restrictions. The ground water must have a known or projected
point of entry to surface water with no statistically significant
increases in contaminant concentrations in surface water, or at
any point where there is reason to believe accumulation of
constituents may occur downstream. In addition, the remedial
action must include enforceable measures that will preclude human
exposure to the contaminated ground water at any point between the
facility boundary and all known and projected points of entry'of
such ground water into surface water."
-115-
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The RCRA ACL Guidance. Part II, (EPA/530-SW-87-031, OSWER Directive
9481.00-11) page xiv, states that "ACLs may be based on contaminant
discharge into a surface water body if a facility owns the property
up to the surface water body," and the conditions are met as follows:
1) the contaminant plume has already reached the surface water
body;
2) the contaminants do not cause a statistically significant
increase over background in the surface water concentrations of
those contaminants; and
3) the contaminants will n~t reach a receptor at an unsafe level
before they reach the surface water body.
Although no contaminants have been detected above site background
concentrations in the stream, wells adjacent to the stream have shown
detections of constituents. Therefore, it is concluded that
contaminants in the aquifer have reached the stream. The system of
monitoring both the surface water and the ground water provides
assurance that contamination concentrations increasing in the
aquifer, and in the stream, will be detected and evaluated
statistically. Institutional controls and a conservation easement,
which shall grant control of the site in. perpetuity to a third party
and prohibit further development of the property, shall be enforced
to insure that contaminants will not reach receptors before they
reach the surface water body; no one can install a well between the
site and the stream where the plume is discharging. This is
consistent with both RCRA and CERCLA requirements.
Statistical.procedures for evaluating concentrations in ground water
and surface water shall be adopted from the EPA guidance document,
Statistical Analvsis of Ground-Water Monitorinq Data at RCRA
Facilities. Interim Final Guidance. ADril 1989, and the above
referenced RCRA ACL guidance.
9.2.1
Aquifer Monitorinq
Nine points of compliance (POC) wells (MWs 14, 14A, 9, 9A, 9B, 6,
6A, 8, and 3 as identified in the Remedial Investigation (RI))
will be monitored to determine if statistically significant
increases of contaminants occur in exceedence of app~icable MCLs,
ACLs, and health-based drinking water levels. Intra-well
statistical comparisons shall be utilized to make these
evaluations.
The POC wells shall be monitored quarterly for the COCs identified
in the RI and in Section 5.5 of this ROD. An arithmetic mean of
the first four samples of each .constituent for each well will be
computed. The means exceeding MCLs will become the ACL for that
constituent, and for means that do not exceed MCLs, the MCL will
be the applicable standard. Separate wells may have a different
ACL value for a given constituent.
.-116-
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I' -
Applicable MCLs, Maximum Contaminant Level Goals (MCLGs), and
Secondary Maximum Contaminant Levels (SMCLs) for the COCs listed
in Section 5.5 of this ROD are delineated in Table 20. Finalized,
promulgated MCLs listed in this table will be the enforceable
levels used in the establishment of ACLs at the GSST site.
Proposed MCLs are listed for antimony, nickel, cyanide, and
methylene chloride. An MCLG value is listed for copper and a SMCL
value is listed for zinc. The listed proposed MCLs, MCLGs, and
.SMCL are not enforceable, but are "To Be Considered" ARARs. These
values should be considered when computing mean concentrations and
establishing ACLs/MCLs at the GSST site. MCLs, MCLGs or SMCL
values are not available for acetone, bis(2-ethylhexyl)phthalate,
and 2-butanone. Therefore, ACLs (or MCLs) will not be set for
these three constituents. However, the concentrations of these
three contaminants shall be monitored closely to ensure
statistical significant increases do not occur over time during
the long-term monitoring program.
Establishment of representative mean concentrations for the POC
wells shall be in full accordance with the two previously
referenced guidance documents in this section. During analysis of
a constituent, the reported concentration of the constituent may
be below the method detection limit (MDL) of the analytical
procedure. If this occurs, the actual MDL value will be
substituted as the actual concentration and the mean computed.
The first year of sampling (first 4 quarterly samples) will be
used to establish mean concentrations for the individual POC
wells. The first year of sampling shall begin upon commencement
of the Remedial Design phase of .this project.
Ground water samples collected after the first year will be
compared to the mean of the first years sampling to determine if
statistically significant increases have occurred above MCLs and
established ACLs. Samples for comparison will be collected
quarterly for three years after commencement of Remedial Action.
At that time, the frequency of monitoring will be reviewed to
determine if modifications are warranted. During this review, if
statistical decreases in the POC wells is evident, the frequency
of sampling will be reduced to semi-annual (twice yearly) up to
the five year review of the site. If statistical decreases are
not inherently obvious, quarterly sampling will continue through
the five year review. A comprehensive evaluation of the
monitoring program will occur during the five year review to
evaluate if changes in the program are warranted.
Due to the complexity and length of the statistical comparison
techniques required for this monitoring program, they are not
included in this document. Section 6 of the above referenced
statistical guidance describes procedures for comparisons with
MCLs or ACLs. The statistical comparison methods utilized as part
of this remedy shall be consistent and in full accordance with 'the
above referenced document.
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TABLE 20
APPUCABLE MCL, MCLG, SMCL VALUES FOR CONSTITUENTS OF CONCERN
GOLDEN STRIP SEPTIC TANK SITE
CONSTITUENT MCL (ppm)[a] MCLG (ppm)[b] SMCL (ppm)[cl
Antimony * 0.01/0.005
Arsenic 0.050
Cadmium 0.005
Chromium 0.1
Copper 1.3
I..eaj 0.015 [d)
Mercury 0.002
Nickel * .0.1
Zinc 5.0
Cyanide * 0.2
Acetone N/A
B is(2-ethyl h exyl) ph tha late N/A
2-Butanone N/A
Chlorobenzene 0.1.
Chloroform 0.1 [e]
1 ,2-Dichloroethane 0.005
1 .2-Dichloroethene (total) 0.07
. 1,2-Dichloropropane 0.005
Ethylbenzene 0.7
Methylene Chloride * 0.005
Styrene 0.1
T etrachloroethene 0.005
Toluene 1.0
1,1 ,1- Trichloroethane 0.2
Xylenes (total) 10.0
[a]- Maximum Contaminant Level (National Primary Drinking Water Regulations)
[b] - Maximum Contaminant Level Goal (National Primary Drinking Water Regulations)
[c] - Secondary Maximum C~ntaminant Level (Secondary Drinking Water Regulations)
[d]- "Cleanup Level for Lead In Groundwater, June 21,1990 Directive from EPA Headquarters,
Office of Emergency and Remedial Response.
[ e ] - MCL is for total Trihalomethanes.
* - Proposed MCL.
N/A- Valu~ is Not Availabl3.
-118-
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! -
If a significant increase in constituent concentration is
detected, another sample will be collected within a reasonably
short time frame to determine if the detection is a false
positive. This will be a checking system to confirm that sampling
error or analytical error has not caused a false positive.
If a significant increase above applicable ACLs, MCLs, or
health-based levels is confirmed, additional monitoring wells
. be installed in the area of the suspect well(s) to define the
extent of contamination, and determine if active ground water
remediation is necessary. .
will
Additionally, monitoring wells 4, 4A, 5, and 7 (as defined by the
RI) shall be sampled and analyzed during the implementation of
remedial action at the site. This "source area well" monitoring
will be conducted during three sampling events which will occur
during the second year of the five year program. . This will allow
adequate time for RD/RA negotiations and Remedial Design. The
first sampling event of the source area wells shall be conducted
prior to remedial action activities and samples collected from
these wells shall be analyzed for the TAL and TCL parameters,
excluding pesticides and PCBs. The second sampling event shall
occur during excavation activities and samples shall be analyzed
for the cac list. The third sampling event of these wells shall
be collected after excavation of waste material has occurred and
samples shall be analyzed for the TAL and TCL parameters,
excluding pesticides and PCBs. This sampling. regime will be
implemented in an effort to ensure that a slug of contaminants is
not released as a result of disruption of the underlying soil
during excavation of the identified waste layers. This additional
monitoring shall serve as an early warning device if the mobility
of the contaminants beneath the visible waste layers is increased
during implementation of remedial action.
Finally, monitoring wells 4, 4A, 5 and 7 shall be sampled during
the final sampling event of the proposed five year ground water
monitoring program. These samples will be analyzed for the full
TAL/TCL parameter list, excluding pesticides and PCBs. These
results will be utilized during the five year review to determine
if treatment of identified waste by solidification has been
effective in immobilizing waste constituents in a solid monolith
and to evaluate if source treatment by solidification remains to
be adequately protective of human health and the environment.
9.2.2
Stream Monitorinq
Stream monitoring will be conducted by comparing a background'
monitoring station (SW-1 from the RI Report) to stations (SW 2, 3,
and 4) in the area of suspected ground water discharge to the
stream. The current location of SW-3 will be relocated downstream
to an area due west of monitoring well pair MW-06/6A. This
relocation of SW-3 will provide a more strategic stream monitoring
network to monitor suspected areas of ground water discharge to
the stream. The above referenced guidance documents will be used
to determine if a statistically significant increase of
contaminant concentrations occurs from the upgradient sample to
-119-
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the downgradient samples. Sampling will be conducted on the same
schedule as the ground water sampling. The RCRA ACL guidance,
Part II, Case Study 4 describes comparable procedures to be
followed in monitoring the stream. .
Maximum allowable exposure concentrations for the contaminants of
concern will be developed for the waters of the creek. The
exposure pathways to be considered will be human ingestion of
drinking water, human ingestion of fish, and ambient water quality
criteria for aquatic life.
If statistically significant increases of contaminants occurs or
maximum allowable exposure concentrations are exceeded, the need
for active remediation of ground water will be re-evaluated to
determine if remediation is warranted.
Table 21 depicts the above described long-term monitoring program
for the P~C wells, source area wells, and stream stations.
9.3
Laaoon Surface Water
Analyses of water samples collected from open Lagoon Nos. 1 and 4
indicated the presence of cadmium and chromium at concentrations that
exceeded MCLs. Maximum Contamihant Levels established by the Safe
Drinking Water Act are applicable chemical-specific requirements for
surface water impounded in the open lagoons.
The selected remedy for the Golden Strip Septic Tank site shall
include collection and discharge of the surface water impounded in
these lagoons to the local Publicly Owned Treatment Works (POTW).
Preliminary discussions with Western Carolina Regional Sewer
Authority (WCRSA) and Metropolitan Sewer District (MSD), the local
regulatory authorities, indicate that the feasibility of discharging
the lagoon water to the POTW is both reasonable and cost-effective.
Pretreatment of the discharge will be required if constituents exceed
WCRSA's standards. Further sampling and analysis of the lagoon water
to be discharged shall be conducted to determine its quality. RI
data compiled thus far indicate pretreatment may not be necessary.
All surface water discharged to the local POTW shall be in full.
accordance with all applicable Federal, State and local regulations.
The estimated volume of surface water to be impounded in the lagoons
is approximately 1.9 million gallons.
9.4
Lona-Term ODeration and Maintenance
A Long-Term Operation and Maintenance (O&M) program shall also be
implemented as part of the selected remedy. This O&M program shall
be implemented to assess the effect of solidified waste constituents
on the site over a 30-year design life. Additionally, this program
shall ensure institutional controls of the site are maintained for
the 30-year period. The 30-year period is the maximUm period
recommended for analysis by EPAoRI/FS Guidance.
-120-
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TABLE 21
LONG-TERM AQUIFER AND STREAM MONITORING PROGRAM
POINT OF
COMPUANCE
WEU.S
...
...
...
0.0
0.0
w
u SJ..R:E
a: [a] [b}
::> AREA .
@ WE1l.S
W
-J
c..
~
en
STREAM ... ... ... 0.0 0.0
STATIONS
RD
SIGNATURE
1[C]
2
3
4
5-YEAR
REVIEW
TIME (YEARS)
LEGEND:
. - Sample Event; Samples are to be collected and analyzed for Constituent of Concern
List. .
. - Sample Event; Samples are to be collected and analyzed for T ALfTCL Ust.
(Excluding Pesticides and PCB's.)
o - Sample Event; Samples are to be collected and analyzed for Constituent of Concern
Ust if statistical decreases in contaminant concentrations are not observed during
review of monitoring program in Year 3.
. [a] - Sample shall be collected and analyzed prior to excavation of waste material.
[ b ] - Sample shall be collected and analyzed following excavation of waste material.
[ c] - First 4 quarterly samples will be used to establish mean concentrations for
individual Point of Compliance Wells.
-121-
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The O&M program will consist of long-term ground water monitoring,
surface soil, and sediment monitoring. The solidified monolith shall
also be monitored to ensure the selected remedy remains protective of
human health and the environment over the 30-year period. The
details of the 30-year O&M program shall be determined during the
Remedial Design phase of this project.
9.5
Cost Summary for the Selected Remedv
Associated costs for the selected remedy as outlined above are
delineated in detail in Table 22. Costs associated with the five
year aquifer and stream monitoring are not included in this
estimate. However, the costs associated with this program are not
expected to significantly increase the estimated total cost of
$4,530,000 for implementation of this remedy.
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TABLE 22
SELECTED REMEDY. GOlDEN STRIP SEPTIC TANK
SOUDIFICA TlON OF CONTAMINATED SOILS AND SLUDGE
- DETAILED ESTIMATION OF PROBABLE COST
-.-------.----.-..-..-.-.....-.---.-.-.-.....-----.----------....----.-.---......-....-.--.-......-.-.-....-------..----
I =ER r ITEM DESCRIPtION I UIIITS I a::~) I ClLWlTITY I SUB.TOTAUS) I TOTALCS)
----.------.....-.--------------....------...-.--......----.-.----------------..-.-...----.-...--.-.-.....--.-.----.-...
ICAPITAL CDSTS
Direct c.pital Costs
1.00 IMCIIILWTlCIIItIEMOIULIZATlCII
1.10 IEMEDIATlCII COIITRACTca
1.20 I TlfATMEIIT CONTRACTca
2.00 SITE PREPARATION
2.10 CLEAlUIG AIID GRUBBING. LAGOON AREAS/
YJ!K AREAS
2.20 I II'GIIADE ACCESS ROADSITURNARC1JND
2.30 INSTALL SITE FACILITIES/VEHICLE
1 All) PERSONNEL DECON UNITS
2.40 INSTALL AIID MAINTAIII TEMPcaARY
EROSION CONTROLS I
3.00 COIISTIIUCTION/SITE WORK
3.30 I INSTALL SURFACE WATER PUMPING/ I
DISCHARGE SYSTEM
3.31 I IIISTALL ,- DIA. PVC DISCHARGE I LS
'l'IIiG ~
3.32 I SEWER TIE, III FEES/COSTS I LS
3.33 I PRevIDE/MAINTAIN HOLDIIiG TAMK LS
I CFlAC TAIIK) I
3.34 PROVIDE PUMPS AND LEVEL CONTROLS LS
3.35 1 JETER AND METER lOX INSTALLATION I LS
3.40 CPWTE/MAINTAIII SURFACE WATER DAY
I NlPIIiGItIISCHARGE SYSTEM I
3.41 DISCHARGE SAMPLES ANALYSIS DAY
3.50 I DISASSEMBLY OF PUMPIIiGItIISCHARGE I LS
SYSTEM
3.60 RalJVAL OF LAGOON SOILS AND I
SI.1I)GES
3.61 SW!GE AND SOILS REMOVAL AND STAGING I a
3.63 CDNFIRMATION SAMPLING/ANALYSIS IN EA
LAGOONS AFTER SLUDGE REMOVAL I
3.80 ON-SITE TREATMENT OF SLUDGE AND
I SOILS
3.53 SOLIDIfICATION/STABILIZATION/
fIXATION TREATMENT
POST-TREATMEIIT SAMPLING AND
ANALYSIS Of SOILS
IACKFlLL AND CDMPACTION OF
TREATED RESIDUAL SOLIDS
PLAC! TCIPSOILIFUIAL GRADING
(68 THICXIOF'.SITE IORROW)
3.87 I£YEGETATtCII/SEEDIMG
6.DO OFF'SITE DISPOSAL
6.10 OFF-SITE TREATMENT AT POTU (WtRSA)
6.11 PERMITTING AT POTU (weRSA)
6.12 PIOCESSING FEE FOR CONSULTANT' M&E
6.13 ADDITIONAL DISCHARGE FEE ("$D)
7.00 COIITI.GENa (3OS)
3.84
3.85
3.86
S~0C8t, Direct Capitat Costs
----------
LS
LS
AC;!
LF
LS
LS
CY
EA
a
a
ACR
MGAL
LS
LS
GAL
LS
SloG,OOO.OO
17U,DOO.00
1',IJ75.00
I
I
I
I
I
I
110.00 I
112,000.00
112,800.00 I
I
I
1
1
10 I
1,500
1
1
1
65
65
1
22,200
40
21,750
90
25,530
7,200
,0
1,-
1
1
1,900,000
1
S40,OOO
170,000
110,750
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
16,380.00
15,550.00
sa,58Q.oo
111,500.00
115,750.00
S9OO.00
1150.00
12,500.00
14.50
Ino.oo
S40.00
1720.00
16.45
"9.79
12,700.00
11.89
11,000.00
15,000.00
SO.12
S61r6,292.25
115,000
112,000
I
, I
1
1
S12,800
I
I
16,380
15,550
S!,58O
In ,500 I
1~5,750
158,500
S9,750
52,500 -
199,900
128,800
11,110,000
164,800
"64,669
"42,488
127 , 000
13,591
11,000
15,000
S228,000
S61r6,292
12,800,600
-------
TABLE 22
(Can't)
SELECTED REMEDY - GOLDEN STRIP SEPTIC TANK
SOUDIACATION OF CONTAMINATED SOILS AND SLUDGE
DETAILED ESTIMATION OF PROBABLE COST
-----.-...------...----.---------.-.-.----.....-----.-----..----..---------------.....--.......--.----------.....-------
I I IIIIT
UIIITS cmTeS)
I~I
ITEM DESCRIPTION
------------.-.---------......----------.------...----.-....-...------.-------------........-.-.-...--....--.......--...
TOTALeS)
Indit'8C't C8pit8l Costs
8.00 ENGINEERIMG
8.10 DE$IGII
8.11 TlEATAlILIn m.IIT IT TREATMENT
CCNTIACTCR
8.20 CDSTIUtTION ASSIST.utCE
8.30 GEOTECHMICAL TtSTIMG SERVICES
8.31 STANDARD PRCXTCR
8.32 DalSIn CCMPACTIDII TESTING
8.40 SURVEYING SERVIas
10.00 STARTUP/SIlAKEDOWII eP\JMp I NGID ISCHARGE .
AJID TREATMENT)
11.DD CCIITUIGENCY (30%)
ISubt=t.l. Indirect tacit.l Costs
hOT AL CAP IT AL CDSTS .
I
IOPERATIDIIS AJID MAINTENANCE
Annual Costs. Monitoring e30 yr)
12.00 OPERATING LAlOR
12.10 PREPARATION FOR SAMPLING (GY only)
12.20 I TRAVEL TO AND FROM SITE
12.30 SAMPLING (GY only)
12.'0 I EVALUATION AND REPORT PREPARATION
15.00 PURCHASED SERVlaS
15.10 TRAVEL EXPENSES
15.20 SAMPLE ANALTSES
15.2' AlALTSIS OF GROUNDWATER SAMPLES
15.30 IOTTLES/FREI GHTIEXPENDAlLES
15.'0 I MAIITENAJiC! EXPOSES
15.'1 LAND SURFACE MAIMTENANCE
17.00 AOMIIUSTRATION
20.00 ANNUAL CONTINGENcye1S')
SubtOtal. Amual Monhorfng Cost
----------
PrHlnt Worth. JO'yr QUI costs
PrU8nt Worth. Toul 'roI~
LS 1170.000.00
LS 1100.000.00
WIC 14.050.00
EA S85. 00
U' 11.110.00
LS saoO.OO
U 123,250.00
LS 1'70.055.00
I
I
HR ..5...1
HR 155.00
HR 15S.oo
LS 16.000.00
DAT 170.00
U S2!,070.oo
LS 1400.00.
LS 11,000.00
ACI 1175.00
U S10.000.00
LS sa,412.75
I GUAJlTITT I SUI-TOTAL(I) I
1 1170,000
1 1100,000
671 S271.3.5 0
~ I GO
11,110
~ I saoo
123,250
1 I 1170,055 I
I S736,905 I
I
I
. I
20 11,';00 I
8 -t
54 S2, 97D
1 I S6,OOO
4 I S2801
~ I m,m I
S800
1 11,000 I
31 15,425
1 S10,OOO
1 sa,413
16/.,498
I
I
I
I
I
S3,537.!C5 I
I
I
I -
I
I
I
I
I
199'.'59
I
-.-.----..-.....-..-.-........--........................................-...............................................
14,528,96' I
~.-.
'.
-124-
SOURCE: RMT, INC. 1991
.
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10.0
STATUTORY DETERMINATIONS
EPA's primary responsibility at Superfund sites is to select remedial
actions that are protective of human health and the environment. In
addition, Section 121 of CERCLA establishes several other statutory
requirements and preferences. These specify that when complete, the
selected remedy for this site must comply with applicable or relevant
and appropriate environmental standards established under Federal and
St~te environmental laws unless a statutory waiver is justified. The
selected remedy also must be cost-effective and utilize permanent
solutions and alternative treatment technologies or resource recovery
technologies to the maximum extent practicable". Finally, the statute
includes a preference for remedies that employ treatment that
permanently and significantly reduce the volume, toxicity, or
mobility of hazardous wastes as their principal element. The
following sections discuss how the selected remedy for the Golden
Strip Septic Tank site meets these statutory determinations.
10.1
Protection of Human Health and the Environment
The selected remedy for the Golden Strip Septic Tank site protects
human health and the environment through treatment by solidification
of the lagoon wastes/sludge and contaminated soils. Dermal contact
with the waste constituents in the lagoon sludges and contaminated
soils is the primary exposure threat posed to human health.
Solidification of the identified waste constituents will eliminate
this threat by preventing direct contact with "the identified waste
constituents. Additionally, treatment of the contaminated soil and
lagoon waste by solidification will immobilize the continuing source
areas and the primary exposure threat to the environment.
The current risksSposed by the site are an upper bound carcinogenic
risk of 2.3 X 10- and a resultant non-carcinogenic risk, or Hazard
Index, of 8.2. The remedy selected in this ROD which provides ~ high
degree of permanence reduces the carcinogenic risk to 2.0 X 10-
and the non-carcinogenic" risk to 0.17. Both of these values are
within the acceptable range established by EPA.
Potential short-term risks posed by the selected remedy due to the
increased potential for erosion of affected materials by wind and
rain during excavation and staging, will be controlled by standard
engineering practices, such as dust control activities and silt
fences. No unacceptable short-term risks or cross-media impacts will
be caused by implementation of the selected remedy.
10.2
ComDliance with ADDlicable or Relevant and ADDroDriate
Reauirements
The selected remedy of excavation, treatment by solidification of
contaminated soil and lagoon sludge and on-site disposal by
backfilling will be in full compliance with all applicable or
-12S-
-------
relevant and appropriate chemical-, action-, and location-specific
requirements (ARARs). The ARARs are presented below.
10.2.1
Chemical-specific ARARs
There are no chemical-specific ARARs for soil and sediment for the
constituents of concern at the site. However, contaminated soils
and sludges present at the site will be remediated to the remedial
action target concentrations derived from the Baseline Risk
Assessment and the calculated risk potentials for both
carcinogenic and non-carcinogenic effects. These target
concentrations are delineated in Table 18 of this ROD.
Chemical-specific ARARs for ground water at the site are the Safe
Drinking Water Act (SDWA) Maximum Contaminant Levels (MCLs).
However, active aquifer remediation to attain MCLs in the ground
water at the site has been determined to be unreasonable and not
technically practicable. Pursuant to Section 121 of CERCLA,
establishment of Alternate Concentration Limits (ACLs) for the
ground water at the site have been determined to be the applicable
standard. The applicability for the establishment of ACLs at the
GSST has been developed in detail in Section 4.0 and 9.0 of this
document. Ground water at the site attains all applicable
requirements for the establishment of ACLs.
Chemical-specific ARARs for the surface water impounded in Lagoons
1 and 4 are the SDWA MCLs. This water will be collected and
discharged to the local POTW and will attain the applicable
standard.
10.2.2
Action-specific ARARs
Placement of hazardous waste as defined by the RCRA Land Disposal
Restrictions is not applicable to the selected remedy. Therefore,
Minimum Technology Requirements are not applicable. However,
waste present at the site has been determined to be
"characteristic". The performance standards as imposed by the
LDRs for waste characteristics exh~bited by the Toxicity
Characteristic Leaching Procedure analysis of the excavated
materials are applicable. LDR concentration-based standards (Best
Demonstrated Available Technology Levels) for the'
stabilized/solidified soils and sludge shall be met prior to
on-site disposal. These regulatory limits are delineated in Table
19 of this ROD.
Additionally, treatment by solidification of the waste
constituents that shall result 'in a level that is adequately
protective of the ground water at the site has been determined to
be relevant and appropriate.
10.2.3
Location-specific ARARs
None.
-126-
-------
10.3
Cost-Effectiveness
EPA believes the selected remedy is cost effective in mitigating the
principal risk posed to human health and the environment. The
selected remedy provides the highest degree of permanence at costs
that are mid-range when compared to other alternatives considered for
remedial action at the site. The selected remedy adequately meets
all evaluation criteria and provides overall effectiveness in
proportion to its cost. The estimated cost for the selected remedy
is approximately $4,500,000.
Utilization of Permanent Solutions and Alternative Treatment
Technoloaies or Resource Recoverv Technoloaies to the
Maximum Extent practicable (MEP)
EPA and the State of South Carolina have determined that the selected
remedy represents the maximum extent to which permanent solutions and
treatment technologies can be utilized in a cost-effective manne~ for
source control remediation at the Golden Strip Septic Tank site. Of
those alternatives that are protective of human health and the
environment and comply with ARARs, EPA and the State have determined
that the selected remedy provides the best overall balance of
tradeoffs in terms of the five balancing criteria: long-term
effectiveness and permanence; reduction of toxicity, mobility, or
volume; short-term effectiveness; implementability; and cost.
Additionally, the selected remedy fulfills the two modifying
criteria: state acceptance; and community acceptance.
10.4
The selected remedy meets the statutory preference to utilize
permanent solutions and treatment technologies, to the maximum extent
practicable. Containment by capping the waste constituent source
areas achieves the same level of risk reduction for approximately 40
percent less cost, but provides less permanence and long-term
effectiveness. Source removal also achieves substantial risk
reduction in terms of future exposure to waste constituents, but the
short-term risks are greater and the costs are much higher.
Treatment by solidification has been routinely applied with
successful results to soils'that are typical to this region of South
Carolina. However, in-situ solidification processes have not been
well demonstrated for the typical soils for this region or for the
large areas requiring remediation at the site. The selected remedy
can be implemented rapidly with proven technology and at less cost
than the other treatment alternatives considered. For these reasons,
excavation of affected materials, solidification of contaminated
soils and sludge, and on-site disposal by backfilling in on-site
excavations has ~een determined to be the most appropriate solution
for the Golden Strip Septic Tank site.
-127-
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10.5
Preference for Treatment as a PrinciDal Element
By treating the contaminated soils and lagoon sludges by
solidification, the selected remedy addresses the principal threats
posed to human health and the environment by the site through the use
of a proven treatment technology. Therefore, the statutory
preference for remedies that employ treatment as a principal element
is satisfied.
-128-
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ATTACHMENT I
SOUTH CAROLINA DEPARTMENT OF HEALTH AND ENVIRONMENTAL CONTROL
RECORD OF DECISION CONCURRENCE LETTER
Golden Strip Septic Tank Site
Greenville County, Simpsonville, South Carolina
-------
.
DHEC
Commla8lOner. Michael D. Jarrett
Board: John B. Pate. MD. Chairman
William E. Applegate. 11/. VICS Chairman
John H. Burriss, Secretary
Toney Graham. Jr.. MD
Richard E. Jabbour. DDS
Henry S. Jordan. MD
Robert J. Stripling, Jr.
Department 01 HeaIIh and ~ Control
2600 Bull Street. Columbia. SC 29201
Promoting Health. Protecting the Environment
September 11, 1991
Greer C. Tidwell
Regional Administrator
USEP A Region IV
345 Courtland Street
Atlanta, GA 30365
RE:
Golden Strip Septic Site - Record of Decision.
Dear Mr. Tidwell:
The Department has reviewed the revised Record of Decision (ROD) dated
August 28, 1991 for the Golden Strip Septic Tank site and concurs with the selected
remediation alternatives. However, the Department does not concur with the
selected clean-up levels for the site soils. In concurring with this ROD, the South
Carolina Department of Health and Environmental Control (SCDHEC) does not
waive any right or authority it may have under federal or state law. SCDHEC
reserves any right and authority it may have to require corrective action in
accordance with the South Carolina Hazardous Waste Management Act and the
South Carolina Pollution Control Act. These rights include, but are not limited to,
the right to ensure that all necessary permits are obtained, all clean-up goals and
criteria are met, and to take a separate action in the event clean-up goals and criteria
are not met. Nothing in the concurrence shall preclude SCDHEC from exercising
any administrative, legal and equitable remedies available to require additional
response actions in the event that: (l)(a) previously unknown or undetected
conditions arise at the site, or (b) SCDHEC receives additional information not
previously available concerning the premises upon which SCDHEC relied in
concurring with the selected remedial alternative; and (2) the implementation of the
remedial alternative selected in the ROD is no longer protective of public health and
the environment.
.".
-------
Mr. Tidwell
September 11, 1991
Page 2
This concurrence for the selected remedy is contingent upon the State's above-
mentioned reservation of rights. The State concurs with the selected source
remediation alternatives of solidification/fixation for soils and lagoon sludges. The
State concurs with the selected remediation alternative for lagoon waters of discharge
to the local POlW. The State also concurs with the selected groundwater alternative
of establishing Alternate Concentration Limits (ACu). State concurrence is based
only on the remedies selected. The State does not concur with the selected clean-up
level for arsenic, which the State feels should be established at the background levels
found on the site.
Sincerely,
;:L-- ~
R. Lewis Shaw, P.E.
Deputy Commissioner
Environmental Quality Control
RLS/RH/vkb
cc:
Hartsill Truesdale
Lewis Bedenbaugh
Keith Lindler
Richard Haynes
Lorrie Brooks
Carla Bullard
File
-------
ATTACHMENT II
FINAL RESPONSIVENESS SUMMARY
COMMUNITY RELATIONS PROGRAM
Golden Strip Septic Tank Site.
Greenville County, Simpsonville, South Carolina
-------
.
I.
RESPONSIVENESS StOOWly OVERVIEW
The U.S. Environmental Protection Agency (EPA) held a public comment period from
June 17, through July 18, 1991 for interested parties to comment on the Remedial
Investigation/Feasibility Study (RI/FS) results and the Proposed Plan for the
Golden Strip Septic Tank Site (GSST Site or the site) in Greenville County, South
Carolina.
The Proposed Plan, included in Attachment A of this document, provides a summary
of the site's background information leading up to the public comment period.
Specifically, the Proposed Plan includes the fo~lowing sections: Introduction,
Site Background, Results of the Remedial Investigation, Scope and Role of this
Remedial Action, Summary of Site Risks, Summary of Alternatives, Evaluation of
Alternatives and EPA's Preferred Alternative, Community Participation and
Glossary of Terms.
Based on the analysis of alternatives presented in the Proposed Plan Fact Sheet,
EPA has identified Alternative 7, Option 7C - Solidification/Fixation as the
preferred alternative for addressing surface soil and sludge contamination at the
GSST Site.
EPA's preferred alternative, Alternative 7, Option 7C, consists of the following
components:
1)
Establishment of Alternative Concentration Levels (ACLs) for 1,2-
dichloroethane, l,2-dichloropropane, chromium, and lead in the
groundwater at the site. In addition to the establishment of ACts, a
long-term groundwater monitoring network will be developed by EPA and
South Carolina Department of Health and Environmental Control (SCDHEC)
to monitor the effects of solidification/fixation of affected soils and
sludS.. on the groundwater.
2)
Di8charg. of surface water impounded in Lagoon Nos. 1 & 4 to the local
publicly-owned treatment works (PON).
3)
Excavation and treatment of affected soils and lagoon sludges by
solidification/fixation. Treated materials will be backfilled into
excavations located .onsite.
1
-------
EPA's selection of Alternative 7, Option 7C - Solidification/Fixation is the
result of a comprehensive evaluation and screening process.
EPA held a public meeting at 7:00 p.m. on June 20, 1991 at the Simpsonville
Community Building, City Park, East Curtis Street in Simpsonville, South Carolina
to outline the RI/FS, describe EPA's proposed plan to address contamination at
the GSST Site and discuss other remedial alternatives considered for the GSST
Site. EPA stated that all comments received by EPA during the public comment
period would be considered in the final selection of a remedial alternative for
the areas of contamination at the GSST Site.
The Responsiveness Summary, required by the Superfund Law, provides a summary of
citizens' CODUDents and concerns identified and received during the public comment
period, and EPA's responses to those comments and concerns.
This Responsiveness
attachments:
II.
III.
IV.
Summary is organized into the. following sections and
1.
RESPONSIVENESS SUMMARY OVERVIEW: This section outlines the purposes
of the public comment period and the Responsiveness Summary. It 81so
references the appended background information leading up to the
public comment period.
BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS: This section
provides a brief history of community concerns and interest regarding
the GSST Site.
SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING THE PUBLIC
MEETING AND EPA' S RESPONSES TO THESE COMMENTS: This section
summarizes the oral cOlllllents received by EPA at the June 20, 1991
public meeting, and provides EPA's responses to these comments.
WRITTEN COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD AND EPA' S
RESPONSES TO THESE COMMENTS: This section contains letters received
by EPA containing written comments, as well as EPA's written response
to the letters.
ATTACHMENT A: Attachment A contains the Proposed Plan which was
distributed to the public during the public meeting held on June 20,
1991 and mailed to the information repository and those included on
the mailing list.
2
-------
I -
ATTACHMENT 8: Attachment 8 includes the sign in sheets frollthe
public meeting held on June 20, 1991 at the Simpsonville Community
8uilding, City Park, East Curtis Street in Slmpsonville, South
Carolina.
ATTACHMENT C: Attachment C includes names, addresses and phone
numbers of the information repository designated for the GSST Site.
ATTACHMENT D: Attachment D includes all public notices issued during
RI/FS and ROD activities.
ATTACHMENT E: Attachment D includes the official transcript of the
Public Hearing on the Proposed Plan for the Cleanup of the GSST Site
located in Greenville County, South Carolina.
II.
BACKGROUND ON COHKUNITY INVOLVEHENT AND CONCERNS
A.
Back2round on Community Involvement
The GSST Site became an issue in the community when the site was listed on the
National Priorities List (NPL) in June 1987. Articles in the Greenville Piedmont
(July 21, 1987) and the Greenville ~ (July 21, 1987) prompted citizen concern
about the quality of well water. Several local residents, whose wells were
tested by SCDHEC and EPA, reported that they had not received the test results
when the newspaper reported that contaminants were threatening local drinking
water wells.
In a petition dated July 27, 1987, 58 local residents called for the immediate
removal of the remaining liquid waste at the site. The petitioners cited the
fact that two local residents had developed cancer in a three year period and
that one had died from the disease.
The petition was sent to the Commissioner of SCDHEC, Michael Jarrett, with copies
to South Carolina's Governor Campbell and Lt. Governor Theodore, U.S. Senators
Thurmond and Hollings, State Senator David Thomas, and State Representative
Alexander. As a result of the petition, an informal meeting was held in the fall
of 1987 with SCDHEC officials, Senator Thomas, local residents, and the media in
attendance. The local SCDHEC District Director explained at the meeting that the
plume of contamination would most likely move in the opposite direction from
3
-------
their wells due to the location and topography of the site. He informed the
residents that additional testing would be performed by EPA. Several residents
who attended the meeting reported that none of the officials listened to them
until the media became involved. They expressed a lack of trust in the officials
who were dealing with the site.
Residents of the nearby subdivisions were not as concerned, however, one resident
reported that his neighbors were not aware of the site. He added that some
people knew about it, but the subdivisions were all on the public water system
so the level of concern was low. He reported that the bigges~ concern of
subdivision residents was the potential affect of the site on property values.
B. Community Concerns
Telephone and personal interviews conducted with local residents and officials
revealed the following concerns regarding the GSST Site.
Contamination of Drinking Vater:
Local residents were concerned that their
private wells had or may become contaminated by hazardous materials originating
from the site. Although most of the local wells had been tested by SCDHEC or EPA
and found not to be contaminated, several residents believe that the plume of
contamination was moving toward their wells.
Availability of Information: All parties contacted expressed a desire to receive
accurate and timely information about the site. Local officials stressed that
they wanted to work with EPA to ensure a good flow of information to the public
and to minimize unnecessary fears brought on by a lack of information.
Distrust of Officials:
Several of the residents contacted expressed a lack of
trust in the officials dealing with the site. They reported that they were not
given any information until the media became interested in the site and that sOllie
officials gave them contradictory information.
Property Values: The residents of the subdivisions surrounding the site were
concerned about the possible devaluing effects of the site on their property.
4
-------
All of the homes are connected to the public water supply; therefore, the
residents were less concerned about the public health threats than the effect on
property values.
New Development:
near the site.
Several new subdivisions were under construction or completed
Reports indicated that the developers of these areas were
concerned with the effect of the site on their ability to sell new homes.
II!.
SUHKAllY OF KAJOll QUESTIONS ARD COMMENTS RECEIVED DUllING THE PUBLIC
MEETING ARD EPA'. RESPONSES TO THESE COHHENTS
The following is a summary of the major verbal comments, concerns and questions
raised during the public meeting on June 20, 1991 by the local residents together
with EPA's responses.
COMMENT: A resident inquired about the length of time required to complete the
Remedial Action (RA) assuming that work begins in January 1992.
RESPONSE: EPA reminded attendees that January 1992 is the anticipated time to
commence the Remedial Design (RD), the RA will begin after completion of the RD.
If EPA's preferred alternative is chosen, the RA phase will require 20 to 2S
weeks, or 4 to S months for completion.
COMMENT: A resident questioned why the estimated cost for a 6-foot fence around
the site totals $1,400,000.
. RESPONSE: EPA stated that the actual fencing cost is not that high; however,
there are additional costs involved with obtaining a conservation easement and
30 years of operation and maintenance that are included in the estimate.
COMMENT: A resident questioned whether operation and maintenance costs are
included for each alternative.
RESPONSE: EPA confirmed that operation and maintenance costs are included for
a11 alternatives except the 8No Action8 alternative.
COMMENT: A resident questioned whether the possibility of pumping/removing the
source liquid with continued monitoring for further signs of leaching had been
considered since the III results indicated minimal health risks. The resident did
not believe this was one of the alternatives.
RESPONSE: EPA stated that Alternative 3, containment, would be the same as the
resident's description. Under this alternative, liquid would be pumped to a
publicly-owned treatment works (POTW) and the area would be capped.
5
-------
COMMENT:
cap.
A resident asked if EPA considered this alternative (#3) without the
RESPONSE: EPA stated that institutional controls would cost $1.4 million and
Alternative 3, containment, would cost $3.2 to $3.5 million. Alternative 3
provides a much more permanent treatment for the money.
COMMENT: A resident expressed concerns over costs stating that the site has been
in existence for over tWenty years and doesn't appear to pose a major health
risk. Therefore, money could be saved by simply pumping the source liquid to a
POTW and monitoring the wells already in place to confirm a significant reduction
of contaminants.
RESPONSE: EPA reminded attendees that they are looking for the best balance when
applying the evaluative criteria to each alternative.
COMMENT: A resident suggested that EPA pump the source liquid to a POTW and if
continued monitoring indicates that contamination still exists, EPA may take
further action at that time.
RESPONSE: EPA stated that source removal remediatio~ is preferred to address
groundwater contamination and that a balance is sought when selecting the
preferred alternative. The selected alternative must provide permanent treatment
and be protective of human health.
COMMENT: A resident asked which alternative would have been selected if the
evaluation were based solely on which was most protective of human health.
RESPONSE: EPA stated that all alternatives were protective of human health
except Alternative 1- No Action; however, they were not all equally protective.
Alternatives 7 and 8 rated the highest for overall protection of human health.
EPA added that Congress enacted the law to take a proactive stance at hazardous
waste sites. Therefore, leaving the hazardous wastes in place and simply
continuing to monitor the site is not proactive. Sites are listed on the NPL
based on current and potential use. Some sites, if left in the present
condition, may never pose a problem. However, as time passes, the situation may
change and the site could become a threat. Therefore, EPA chooses to remediate
listed sites now.
EPA continued that there are several methods available to avoid using Superfund
money to remediate a site. If the Potentially Responsible Parties (PRPs) choose
not to implement the selected remedy, EPA will implement a successional
negotiation IIOratorium to provide the PRPs an opportuni ty to agree to perform the
clean-up. In addition, when a PRP fails to agree to perform clean-up during the
negotiation moratorium, EPA may issue an Administrative Order requiring the PRPs
to perform the work.
COMMENT: A resident asked what type of future land use would be allowed if
Alternative 7-C is selected.
6
-------
RESPONSE: EPA stated that only the area within the conservation easement would
be restricted from further development, all other areas (e.g., the extreme north
portion of the site) could potentially be developed.
COMMENT: A resident asked if the possible extension of the public comment period
is limited to 30 days. The resident was interested in a 60-day extension. The
resident planned to travel to EPA offices in Cincinnati to demonstrate a new
remedial technology that may be applicable to the eSS! Site. Therefore,.
additional time is needed for demonstration and acceptance of the new technology.
RESPONSE: EPA stated that 30-day extensions are standard, however, they will
check into the possibility of a longer extension. EPA recommended that the
resident make a request for an extension in writing, explaining the reasons and
treatment technology.
COMMENT: A resident asked for an explanation of the nine evaluative criteria and
the weight given to each criterion.
RESPONSE: EPA stated that of the nine criteria, the first seven form the basis
for analysis. The first two are the -Threshold Criteria,- the middle five are
the -Balancing Criteria- and the last two are the "Modifying Criteria.- All
engineering decisions are based on the first seven and each criterion is given
equal weight. After EPA has selected a preferred alternative based on the first
seven criteria, EPA evaluates the preferred alternative against the two modifying
criteria. The remedy selected in the Record of Decision may be different than
the remedy proposed in the preferred alternative and can still be changed due to
state or community opinions, comments and/or suggestions..
.
COKKENT: The resident was dissatisfied with the response and further questioned
whether any of the criteria carry more weight than the others.
RESPONSE: EPA stated that the first seven criteria are weighted equally. Each
alternative is scored for each criterion. The scores are then added to obtain
a total score for each alternative. The scores indicate which alternative
provides the best balance of the seven criteria. The preferred alternative is
then presented to the state for further analysis and comments, and finally to the
public for additional comments.
COMMENT: A resident questioned what will happen to the heavy metals in the
source liquid when it is pumped to the POTW.
RESPONSE: EPA stated that negotiations with Metropolitan Sewer District
(Metropolitan) and Western Carolina Sewer Authority (Western) have occurred.
Both Metropolitan and Western operate under specific regulations regarding
influent or pre-treatment standards. As long as the source liquid meets the
PONs pre-treatment standards, it will be pumped to the PON and treated to meet
their requirements. The POTW operates under the same rigorous requirements as
EPA. The pre-treatment standards were developed because industry discharges to
the same PONs everyday.
COKKENT:
A resident asked where the pre-treatment of waste would take place.
7
-------
RESPONSE:
onsite.
EPA stated that if pre-treatment is necessary, it will be conducted
COMMENT:
A resident asked EPA to explain how pre-treatment is conducted.
RESPONSE: EPA stated that if the concentration of chemicals in the waste exceeds
the acceptable limits of the POTW, the waste generator must treat the waste;
reducing the chemical concentration to an acceptable level before discharging to
a POTW. Standard engineering practices used in treatment plants are a1so used
to pre-treat the waste.
EPA added that the constituents of concern in the lagoon water at the GSST Site
are cadmium and chromium. Both constituents were detected well below the
Hazardous Waste Criteria and should not present a problem for the treatment
faelli ty.
COMMENT:
A resident asked if the treatment facility had agreed to EPA's plan.
RESPONSE: EPA stated that officials at both Western and Metropolitan have been
contacted. The data was reviewed and the officials are in agreement with EPA's
plan. No discharges to the POTW will be made without prior approval.
COMMENT: A resident questioned whether any type of development will ever exist
within the conservation easement.
RESPONSE: EPA stated that it is very difficult to predict future use; however,
EPA will place severe constraints on the property so that improper use, as
determined at present, will not occur. The restrictions will be placed through
deed restrictions and deed notations to ensure that future .owners are aware of
the site's status. Perhaps in the future, theories will be developed to make use
of the property. For example, in the seventies, agencies developed methods for
reclaiming landfills. The property will probably never be residential, but other
viable uses may become apparent in the future.
COMMENT: A resident living adjacent to the site and owner of property through
which the unnamed stream flows, asked for assurance that his property is safe.
RESPONSE: EPA stated that residents should refer to the analytical data which
illustrates that the unnamed stream and adjacent areas were not affected by the
site.
COMMENT :
A resident asked if the analytical data are available to the public.
RESPONSE: EPA stated that the data can be found in Appendix I of Volume II of
the RI Report located in the site' s information repository. EPA recommended that
residents review the background samples and then look for elevated concentrations
of contaminants.
COMMENT: A resident stated that SDHEC denied the permit for using the lagoons
in 1975 and stopped all operations in 1978. The resident questioned why the
citizens who bought lots in the area after 1978 were not informed of the
8
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j-
potential problem. In addition, the resident asked whether private wells along
Adam's Kill Road were sampled.
RESPONSE: In response to the first question, EPA stated that the evolution of
environmental programs must be considered. The RCRA program, which regulates
generation and disposal of wastes at active facilities, was responsible for
denying the permit. At the time of permit denial, it was apparent that the site
was improperly used; however, there were no other laws in existence to apply to
the problems at the site. CERCLA/Superfund was passed in 1980 and revised in
1986. CERCLA was enacted because the Clean Water Act and other laws did not
address improper disposal of hazardous waste to the ground and the eventual
impact on subsurface drinking water. Superfund has. evolved during the past ten
years. The problem you have described is the basis for using institutional
controls and deed restrictions at NPL sites today.
In response to well sampling, it was stated that groundwater flows away from
Adams Kill Road. EPA added that all wells are recorded with SCDHEC and a survey
was conducted. According to the RI results, however, those wells should not be
affected. The spring on Krs. Rice's property was also sampled and determined
safe.
COMMENT: A resident asked if provisions can be made in the Record of Decision
(ROD) for review of new and emerging technologies.
RESPONSE: EPA expressed interest in obtaining additional written information
regarding new treatment technologies. When the information is received it will
be reviewed by EPA's Technology Innovation Office.
At this time, there are no such provisions that can be made to the ROD. If
during the RD, a new technology becomes available that is a substantial
improvement over the selected remedial alternative, it can be evaluated and
perhaps implemented. However, the new technology would receive very careful
scrutiny because if the ROD was changed, a great deal of work would have to be
redone and the focus of the program is to continue moving forward.
COMMENT: A resident stated that
concern regarding the preferred
public's input must carry little
remedial alternative.
the above issues have been raised to express
alternative. The resident stated that the
to no weight since EPA has already chosen a
RESPONSE: EPA stated that public input is valued. EPA is receptive to any
relevant infol'llation, concerns about the eight alternatives, clean-up in general,
and commenta regarding additional clean-up alternatives. EPA will not disregard
the concerna of the public and remains receptive to new technology. However, the
Superfund Program IlUSt operate within a stable, dependable system. New
technologies should be explained in writing and submitted to EPA for review. The
standard public comment period lasts for 30 days and can be extended for an
additional 30 days when a written request is made.
COMMENT: A resident asked how currently used treatment technologies were
discovered and put into practice.
9
-------
RESPONSE: EPA stated that currently used treatment technologies were developed
in the Superfund Innovative Technology Evaluation (SITE) program and based on
past experience in the field.
COKKENT: A resident asked if EPA considers the results of Toxicity
Characteristic Leaching Procedure (TCLP) tests import~nt. The resident had
possession of test results he wished to review with EPA.
RESPONSE: EPA stated that TCLP tests are considered very important. However,
the resident was using this information to obtain a longer public comment period
to present a newly developed treatment technology. EPA stated that the claims,
thus far. were unsubstantiated and did not warrant a delay in the. process. EPA
encouraged residents to submit written comments and they will be addressed in the
Responsiveness Summary to be included in the ROD. Residents may also make a
written request for an extension of the public comment period.
IV.
WRITTEN COMMENTS RECEIVED DURING THE PUBLIC COMMENT PEllIOD AND EPA'.
RESPONSES TO THESE COMMENTS
The written comments on the following pages were received from citizens during
the public comment period. EPA's responses to these comments are also attached
and were mailed directly to the citizens addressed.
10
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
September 12, 1991
4WD-NSRB
Mr. E.B. Paxton
1 York Circle
Greenville, South Carolina
29605
RE:
Golden Strip Septic Tank Superfund Site
Greenville County, Simpsonville, South Carolina
Dear Mr. Paxton:
This letter is to provide responses to concerns identified in your
correspondence dated July 15, 1991 and to clarify EPA's position
regarding the Proposed Plan for the cleanup of the Golden Strip
Septic Tank Site (the site).
In summary, your correspondence lists the following concerns
regarding the site:
1 )
Portland Cement will not permanently bind site-generated
metals to soil and the resultant leachate may contain
concentrations of hazardous wastes exceeding the maximum
allowable limits.
2)
The EPA's selected alternative, 7-C, is not a permanent
solution to the remediation of the site, Alternatives 4 and
7A seem to present permanent solutions.
In regard to the leachability of Portland Cement, according to
literature published by the Portland Cement Association (PCA), an
interview with a PCA staff engineer and Carl A. Keyser, Materials
Science in Enqineerinq, Second Ed., (Columbus, Ohio: Charles E.
Merrill Publishing Company, 1974), it does not appear that Portland
Cement is a leaching product. Precipitated salts may sometime appear
on the surface of concrete that are a result of efflorescence, or
evaporation of surface moisture. In addition, dissolved sulfates in
soil or groundwater and marine exposures can attack concrete causing
cracking and spalling. Type V Portland Cement is a sulfate-resisting
cement that should be used where soils. or groundwater have a high
,sulfate 'content.
It has already been demonstrated that Portland Cement will have
minimal leaching although efflorescence and mechanical deterioration
is possible, particularly if Type V cement is not used. The
permitted levels of various hazardous constituents are set based on
very detailed risk analyses, where the potential impact on 'human
Printed on Recycled Pacer
-------
-2-.
health and the environment is vigorously studied. Although it is
most desirable for levels of any contaminant to approach 0.00 ppm, it
is the desire of EPA as mandated by the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA), to minimize the
risk of any adverse effects from hazardous constituents present in
soil, air, groundwater or surface water.
In regard to the permanence of Alternative 7-C, solidification has
proven to be a very viable solution. Technologies for effectively
and economically disposing of hazardous waste are rapidly developing
and are dependent on the types of contaminants. present at a site.
Although solidification does not result in the destruction or
recovery of the hazardous waste, it has been determined to be the
Best Demonstrated Available Technology (BDAT) for halting the
migration of the types of constituents present at the Golden Strip
Septic Tank Site and for satisfactorily minimizing the risk of
potential adverse effects on human health and the environment.
Should you have any questions or comments, please contact Craig
Zeller, EPA Remedial Project Manager at (404) 347-7791.
(
Robert Jo an, Chief
North Superfund Remedial Branch
Waste Management Division
-------
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
September 12, 1991
4WD-NSRB
Joe and Hannah Smith
218 Holly Tree Lane
Simpsonville, South Carolina
29681
RE:
Golden Strip Septic Tank Superfund Site,
Greenville County,Simpsonville, South Carolina
Dear Joe and Hannah Smith:
This letter is to provide responses to concerns identified in your
correspondence dated July 17, 1991 and to clarify EPA's position
regarding the Proposed Plan for the cleanup of the Golden Strip
Septic Tank Site (the site).
In summary, your correspondence lists the following concerns
regarding the site:
1)
EPA's selected Alternative 7-C, appears to be a temporary
remedial measure and does not reclaim the land for use;
2)
There are wide variations in test results regarding the
water and sediments of the unnamed stream; and
The property values of land near the site appears to be
declining.
Although solidification does not result in the destruction or
recovery of the hazardous waste, it has been determined to be the
Best Demonstrated Available Technology (BDAT) for halting the
migration of the types of constituents present at the Golden Strip
Septic Tank Site and for satisfactorily minimizing the risk 'of
potential adverse effects on human health and the environment. The
Comprehensive Environmental Response, Compensation and Liability Act
(CERCLA) requires that risks to human health and the environment be
mitigated to a protective level. Potential negative effects caused
by the hazardous constituents present at the Golden Strip Septic Tank
Site have been vigorously studied during the National Priorities List
,(NPL) site ranking investigation stage, and during the risk
assessment stage. It is believed that solidification economically
and effectively minimizes any risks to acceptable levels. As for the
future use of the land, the proposed remedy does not eliminate the
possibility of future use of the land, but the intent is certainly to
restrict its use to appropriate applications.
3)
PrInted on Recycled Paper
-------
-2-
Water and sediment samples from the unnamed stream near your property
have been collected and analyzed throughout the remedial process at
the Golden Strip Septic Tank Site. Data gathered during the Site
Investigation in 1984 indicated the presence of heavy metals iri the
waste lagoons and the ground water. No confirmation of sediment and
water contamination from the unnamed stream was made during previous
site investigations, however, it was believed that there was a
potential for the stream to become contaminated due to discharge of
affected ground water into the unnamed stream. Subsequent sampling
of the stream sediments and water during the Remedial Investigation
indicated that the stream has not been affected by past waste
disposal activities.
Analytical test results from the water and sediments of the unnamed
stream near your house can be found in Volume II, Appendix I of the
Remedial Investigation Report for the Golden Strip Septic Tank Site.
This report is available for public review at the Site's two
information repositories located at the Greenville Public Library,
South Carolina Room, 300 College Street, Greenville, South Carolina
29601 and the Simpsonville Branch Library, 102 Academy Street,
Simpsonville, South Carolina 29618. Additionally, the most recent
sampling data available for the stream near your house may be
obtained by writing the u.S. EPA Region IV Freedom of Information Act
(FOIA) Office at 345 Courtland Street, N.E., Atlanta, Georgia 30365.
Long-term ground water monitoring is required for any post-closure
activity whether the remediation is permanent or temporary. It .is
necessary to ensure that any contaminant will not migrate to
surrounding soil, ground water, air or surface water. Long-term
ground water monitoring will be conducted at this site to ensure that
the preferred remedy remains adequately protective of human health
and the environment over the long-term. . Monitoring results collected
to date and future long-term monitoring results should assist
adjacent property owners in demonstrating that the site is not
impacting the surrounding land and therefore, minimizing the site's
impact on the local real estate market.
Should you have any questions or comments, please contact Craig
Zeller, EPA Remedial Project Manager at (404) 347-7791.
Sincerely,
~h~f
North Superfund Remedial Branch
Waste Management Division
-------
Attachment A
GOLDEN STRIP SEPTIC TANK SITE
PROPOSED PLAN
.
-------
SUPERFUND PROPOSED PLAN FAcr SHEET
EPA REGION IV
ATLANTA, GA
.;j-\~o sr...~
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GOLDEN STRIP SEPTIC TANK SITE
GREENVILLE COUN1Y, SOU1H CAROLINA
JUDe 1991
This fad sheet is one in a series designed to inform
residents and local officials of the ongoing de.anup
efforts at the Golden Strip Septic Tank Superfund
Site. Terms appearing in bold priDt are defined in
a glossary at t!l: end of ~ublicatioD.
INTRODUC'J10N
This Proposed Plan Fad Sheet has been prepared
by the U.s. EDvironmenw Protection Agency .
Region IV (ErA) to propose a de.an-up plan,
referred to IS a prefencd altenWiYe, to address
CODfAminAhon 11 the Goldea Strip Septic Tank
Superfund Site (the Site) located near the town of
SimpsonWie in GrceDViJlc CouDty, South CaroliDa.
A£ the lead Agency for CM:ISigbt of remedial
ac:tMties at the Site, EP A bas worked ill conjunction
with the South Carolina Department of Health and
Environmental Control (SCDHEC). Through this
suppon role, SCDHEC has ~ this preferred
alteraative and concan with EPA',
rea>mmcndatioDs. 1D ac:cordaDcc with SectioD
117(a) of the ComprUCllSm Eavironmeatal
Res~ CompeasatlOD, ud IJabOlI1 Ad
(CERCLA). £lA is publishi.Dg tIUs Proposed PIaD
to provide an opportunity for public review and
comment on aD the de.an-up options, known as
rcmedial alternatives, undcr consideration for the
Site.
The purpose of this Proposed Plan is to:
1) Summarize the resu1ts of the JW1t.edIaJ
IDYeStiptiOD
-------
,S) Provide iDtormaboD on how the public C&D be
Us"OIYcd.Us the remedy scJeaiOD procea.
This Proposed PIu hig"J:.,,,,s key iDtormatiOD that
is coDtaiDed iD the RJ and PS Reports. but does DOC
sene IS a subsWule for these documents. The RJ
ADd FS Reports are more. complete sourc:cs of
iDtormatiOD rcgardiDa the remediaJ ac:tMtics at the
Site and are part 01 the ,u""II',tratm Record for
the SUe. The AcImiaistratM Record c:oasisb of
tedmicaJ reports aDd rcCUCDCc documents that EPA
relied oa to compile the Proposed PIa.D aDd is
located Us two lDIormaUoa reposItories Dear the
Site. Loc:atioDS of the WormaDOD repositories are
iIlduded ill the COMMUNrrv PAR11C1PA 110~
sectioD of this fac:r sheet. The public is eDcouraaed
to c:oasuIt the A~ Record for . more
detaiJed ezpJanatioa of the Site and the remedial
altematives under coDSideratiOJL
The public is eDcouraged to submit commeDts OD all
altematiYcs diCl'Ttcsed Us this Proposed Plan. Public
iDput OD aD aJtematiYes. and OD the iDtormatioD that
supports the alteruatMa. is an importaat
CODtributiOD to the remedy sd.ectiOD process and.
. can iDfJueDCC EPA's prcfcreac:e. The fiDaJ remedial
acboa pIaD. IS prcscmed ill the Record of DedsJoa
(ROD) for the Site, could be di1rereDt from the
prcCem:d altcmatM, depeDdiDg upoD DCW
iDformatiOD or arguments EP A may coDSidcr IS a
result of public CODmlCDts.
Sm: BACKGROUND
The GoJdeD Strip Septic TaDk Site is located OD a
S5-aae pared apprm:i"'~dy three miles DOrtb of
SimpsouviDe, South CuoJiDa (See rJgUrc 1). The
pared is owned by Mrs. LualIe Rice aDd is
surrounded by the HoDyTree residential SUbdMsiOD
OD the cast. west &Del DOrtb ~ The Site CODSists
of ~ iDac:rM waste Iagooas and the area
surroUDdiDg tbese Jaaooas (See rJgUrc 2).
The GoIdeD Strip Scpcjc Tank (GSST) Scnia:,
operated primarily by Mr. Buct Rice, was u
industrial aDd septic waste hauJiDg and disposal
service that bcgaD acceptiDg wastes ill 1960 IDd
c:cascd operatioDS ill .1975. 1aWaDy, two UDJiaed
waslewater IagOODS were ea:avarcd and used for
storage of iDdustrial wastewa!ct and sludges Three
additional impoundmeats were later coDStnlcted.
1Wo of the liYe 1ag00DS (NOI. 1 and 4) currently
. -. ...
I
I
I
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-. 8JUI
,
L
1
FQIIIE ,
0CUI9I ImrIEl'n: ~ 8TI
LOC.c'Oc IW
ICA&,I; IGI8
I
I
1Cq. ...
remaiD opeD IDd CODtaiD liquid waste aDd sludge.
Lagooa NOL 2. 3 ADd 5 were dosed and 6Dcd with
surrnmwfi, soil ill 19'78. WaSte hauJiDg ADd
disposal ac:rMtics wcrc discoDtiDucd at the Site iD
1975. $iDee that time, the foUowiDg adMbes ha\'C
becD CODduc:rcd to fwtJa inestipte and address
POCCDtiaJ aMrOlUDeDtaJ alfects and associated
hWth riW at the Site:
1) SCDHEC performed moDitoriDg at the Site
after the lagooas (Nos. 2, 3, &: ,S) ~ 6Ded
with soil ud graded ill 19'78. ADaJyscs of
samples c:oDcc:red by SCDHEC ill 1981 &om
the water iD the UDcmcrcd IagooDS iDdic:ated
the prCSCDce of ~ metals suda IS
chromium, cadmium, lead and copper ill this
arc&.
2) Prompted by these results. EPA performed a
Site IDspectloa (SI) in August 1984 to ptber
addiboaaJ informatiOD OD the Site. Duriag the
SI, samples were c::oDccted and anaJr= &om
the IagOOD areas, OD-site springS, the lUlDllDed
2
.
-------
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.wI!L
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..
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.,
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-
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-
... --
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FIGURE 2
lAGOON AREA LOCAT1ON MAP
GOlDEN smlP SEPT1C TANe SITf
SOURCE: RMT,INC. 1991
-------
stream aJoD, the westen edac of the Site, IDd
GiJder CreeL The rcauhs. of the SI iDdicated
buY)' metal CIDGt.llliu~ ill the lagoou aad
JfoUDdwater. The surface water did DOt
iDdicate heavy meta.l CODWniDatioa. Results of
the SI iDdic:ared that there was DO immediate
threat or cadugermeDt to residCD1s living Deal'
the Site.
3) 1D'1986. EP A coDducted further CODfirmatioD
tcstiag II the Site u put of the $I to
dctcrmiac if the Site should be coasidered (or
the Superfuad Remedial Program. 1bc
GoIdeD Strip Septic TaDi: Site re=Md I
IIaz.Ud Ibn~.. System (HRS) score of 480.3
and was proposed (or incJusioa DO the NatloaaJ
PrIorities IJst (NPL) in January 1987. The
Site was referred to the SuperfuDd RemcdiaJ
Program and placed on the NPL iD JUDe 1987.
4) ID July 1988, an ,tdllllnlstratM Order oa
CODSeDt was joiDtJy dCYeJopcd, Degotiated aDd
agr= to by EPA and the PotCDdaU,
RaPODSfbIe PartIes (The GoIdcD Strip Task
Group). UDder this Consent Order, the
GoJdca Strip Task Group ap=d to coDduct an
RIfFS II the Site with EP A proYidiag 0YCtSigbt
of the RIfFS 1c:tMtics. The GoJdca Strip Task
Group rctaiDcd RMT.IDc. of G~ SouIh
Carow as their coDtractor. RI 6dd ac:tMties
begaa ill October and were completed in
February 199L
RESULTS OF-THE REMEDIAL INVE.cmGA nON
The primary objective o( the RI was to iDYcstigue
the nature IDd CIIeDt o( waste coostiruc:Dts II the
Site and to detcmaiuc the Dature IDd CItCDt of the
threat to public: health or wdlaR. or the
enviroDmCDt caused by the release or threateDed
release of hazardoas suhstaaccs &om the Site. The
in~ iDdadcd the collcc:Uoa and aaaJysis of
D6 eDvironmCDtal ampb.. The media sampled
iDc1uded ~le Jaaooa waste, soil, air, grouadwarer
IDd surface water samples from scleded Ioca.tioas
across the Site. Sew:mccu Jr'OlIDdwater IIIODJtortac
wells were inctaDed and sampled. Surface and
subsurface soil samples were coDcctcd. The
UDDamcd stream that Oows aJoag the westen edge
01 the Site was also sampled (or water and
sedimeDts. A derA~d discussioD of the RI results
can be fOaDd ill the RI Repon available II the Site
iDlDnDatioa repository. The principal rcauhs of the
RI iDcludc the following:
1) . Orp.a.k IDd 1D0I"pDk coDStitucDtS of CODCeI'D
have beeD idcatificd in the various media. The
primary COILStitueDtS of CODcena II the Site
iDclude: antimoDY. arsenic, cadmium.
chromiu.m, copper, lead, mercury, DicbJ, liDc,
eyuide. acetoac, bis(2-ethylhczyl)phthaJlle,
~."OIIt (a.k.a. methyl ethyl btoac),
chIorobenzz:ae, chloroform. 1,2-cfich1orocthue,
1,2-dida1oroethcae (total). 1,2-dichJoropropaac,
cthyIhP.ft7~1IC., methyleuc ~ styrcDe,
. tctrachJoroethcDe, tolucne, W-trichJol'OC'.tltan~.
and zyIcaes (total).
2) Surface soiJs and IagooD scdimems within the
immediate viciDity of the OpeD and backfiDcd
Iagooas JIm bccD affected by past waste
disposal ac:tiYibe&.
3) Surface soils in the suspected truck tul'DM0UDd
area ud Dear a draiDage swale west oILagooa
Nos.. 3 .t .. - bccD affected to I limited
degree by p.r waste disposal practicea.
") A small area OD the castcru side of the Rice
Farm was ~t16ed to CODtaia rT abandoned
drums. ID~ODSindicalcd that this area
Iw bcea ~cd to a limited degree by past
waste disposal ac:tMtiea (See F'agurc 2 for
Ioatioa).
5) Surface water mDtaiaed in l.agooa Nos. 1 A ..
Iw bcea affected by past waste di<;posaJ
actMtics. CoaCCDtratioas of cadmium IDd
chromium were detected II lads I"Y~Ai,,&
MaxImum Coatalllin-lilt I...neIJ (MCU) set by
the NatioaaJ Primary DriDkiag Wiler
Rcgul:u'oas iD the Sale DriDJdq Water Act
Cadmium (Ma.-O.oos parts per m1Woa) was
detected II I IcYcJ of 0.078 puts per miDioa
(ppm) iD a water sample taken from l.agooa
No. Iud chromium (MCL"O.l00 ppm) was
fOUDd II IcYds of 0.184 ppm and. 0.498 ppm
from water samples taken from LagooD Nos.. 1
A ", respcctftdy.
6) The lIDDamed stream thar passes through the
Site Iai.1 JIg! bcCD affected by past waste
disposal actiYitics.
4
.
-------
7) Badqvouad aad oD-site air wapliag iadicates
that local ambieat air JIu Jgi ~ affected by
past waste disposaJ a~
8)" It was matuaUy agreed - berweea EP A.
SCDHEC aad the Goidca Strip Task Group
that addiuoaaJ studies wue required to coafirm
the bel lad CJlCDt of gJ'ouadwater
CODtamiaatiOD resuJtiag from past waste
disposal practices. This iDlormatioa would be
iacJuded ia a SupplemCDtaJ Grouadwater RI
Report lad utilized to dctermiae the aced for
the evaJuatiou of I gJ'ouadwater fCSpOasc actioa
ia the Site FS.
In aa effort to further dcfiac the Dahlre and CJlcm
or grouadwatcr CODtamiaatioa prcsem at the Site.
RMT, lac. coaducted a SupplcmcataJ Grouadwater
RI UDdcr the directiOD of EP A The objCdivc of
the SupplemeDtaJ RI (SRI) was to further
investigate gJ'oUDdwater Oow charaderistics and
quality ia the dowogradieDt. DOrthcm portiOD of the
Site. Speci6caDy, much of the work focused OD
determiniag it I gJ'ouodwater plume had escaped
detectioa by the monitoring weD Detwork previously
iastaUed during the initial RI. SRI field activities
bcgU ia February 1991 aad concluded ia
mid-March 1991.
Duriag the SRI, five additioaaJ gJ'ouodwater
moaitoring weDs were instaDed dowa gradieDt hOlD
the mch~ Dctwork of moDitoriag .weIls.
GroUDdwater sampJc:s were collected lad anaJyzed
hOlD these five DCW weDs. The DCtwork of cxistiug
groUDdwater monitoring weDs ia the vicinity of thc
lagooD areas were also resampled aad a.naJyzcd ia
order to c:oafirm previous sample results. Duriag
the SRI, grouadwater samplca wue collected usiug
a pcristahic pump iastead 01 the bailer method that
was utilized dwiaa the iaitiaJ RL The peristaltic
pump method is a less rigorous wapliag teduUque
that results ia deaeascd lads 01 suspcaded solids
in the gJ'ouadwata- samples. The samples coDectcd
using the pc:ristaJtic pump tedmique wue
interpreted u beiDa more reprcseatatM of ldUaI
groundwater qaa6ty at the SiIc.' A detailed
discussioa of the SRI Ic:tivitjes lad rcsuJts caa be
found ia the SRI Rcport at the Site iDlormatioa
repository. The results hOlD three gJ'ouodwatcr
sampling events hom the RI aad SRI were used to
cooclude the foDowiag ia regard to gJ'oUDdwater
present at the Site: .
1) Grouadwater now is to the DC>rthv.aI OYer
most or the Site. toward the uuamed stream.
wbich Oows ia a south to aorth dite4ion. W cst
of the stream. gJ'oUDdwuer O~ to the
aorthe.ast toward the stream. Calc:uWed
gJ'OUDdwatcr vcloc:i1ies raase hOlD 40 to 120
fed/year la-ass the Site.
2) VcrtiaJ gJ'adieats iadicate that the WUWIIed
stream is. ia some areas. recciviag discJwge
&om the shaDow portioas 01 the aqaJl~ wbiIe
at other areas, the stream is appareaaJy
disdwgi.ag to the aquifer.
3) The groUDdwatcr resuJ1s preseated in the RI
aad SRI Reports show that 6mited migratioa of
waste c:oDStitueau from the Iagooas has
occurred and the efl'cct oa gJ'OUDdwater has
beeD minimal There is DO pancra, . or
discernible plume, of aft'ected grouadwatcr, but
coasUtucm CODceDlratioas ~tf;"g EPA
promulgated MCLs. v.uc observed in some
samples. Of the coasdtueau of CODCcro for the
Site, oaly l,2-dicbloroctbaDc,
l,2-dichJoropropane, chromium, aod lead
~Y"Cedcd MQ.s ill grouadwuer samples from
select weDs. These Me. ~ in
groundwater samples are tabulated in Table 1.
4) 1.2-dicbloropropaae was detected at
c:onc:eatraboas aboYc the Me. of o.oos ppm at
moaitoriag weD (MW}{M ia aD three sampliag
~ The obscrYCd c:oac=trabons were
0.013 ppm. 0.014 ppm. aad o.on ppm for the
three ocaureDCC$ of 1.2-dic.bJoropropaae in
MW.04. This is the' oaJy Ioc::atiou where
1.2-dich1oropropaae wu detected ia 101 of the
media at the Site. 1.2~ was
dct~ed ab
-------
rouad usiDg the peristahic pump method were
weD below the MC1a for lead and chromium.
Susples coIJecled a.siDa the peristaltic pump'
method are coDSidcrcd to be more
repr~St"'Jlt~ of true grouadwarer quality at
the Site.
S) Based UPOD the uaJytica1 results Crom the
grouadwater studies cooducted to date,
coDSideratioa of Altenaate CODCeDCratioa
Umlts (ACU) for the obsencd, intermineDt
MC1 r~edaDCe$ u recommeDded for the Site.
ACLs should be established for
1,2-dichloroethaDe, 1,2-dichloropropaDe,
chromium aod lead.
SCOPE AND ROLE OF THIS REMEDIAL
AcnON
Using the informatioD coOected during the Rl, the
SRI aDd the Ba!dbae RIsk Assessmen~ EP A
ideDtified the 100owiog remcdia.l action objectives
for the cleanup at the GoIdeD Strip Septic Taok
Site:
Groundwater
EPA believes that 1c:tiYc remediatiOD of
grouadwater (such as a grouodwater pump ad
treat I)'Stem) in the vic:ioiIy of the lagoons is DOt
reasonable or teAfticaDy practicable lor the
foOowiDg reasoas:
1) No disa:l'Dible plume
FT~ces of MC1& v.ae spatiaDy isolated 10
ODe sampliDg poim for any siDgle CODStitucDt,
eYeD though COGStitucIIt c:oaceotratioDS wac
eIcvaIed aboYc the obsenocd backgrouad I~
in ~ wdIs. Tbe areal ClIent of the
affected P'0UDdwater is rdatiYeJy ~li7.ed to
the imlftlld;'te W:iDiIy of the lagoons.
GroUDdwarer quality withio the bedrock was
DOC obsened to be affected by past waste
ma.aagemeor IdiYWcs 0IHite. The areaJ e:&tCDt
of the affected grouodwa1er is apected 10
decrease as a result of the preferred source
remedy.
'&81.1 ,
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'.. Du~--A~- ~_. o.-iii L-
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....... 1- NrJ'"' IW 8.1111 G.IIl'
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- I 11811 - - III" 11111
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- 1&110 IIQ 8.- ''''~::2!
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[,- .,.. 8ID . -... .. ~l't"... - 8.1n.
- &110 8ID - ....,'. .
- &110 - - 8'- 8111
-- ,- - 8ID UKI 8.1118
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- MI' 8ID _lOll 8.11'. ...-
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- 1&/10 - - '8al JItr
-- -. IW 11111 ...-
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-- - 8ID "" 110 ,,-
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-- 11811 8ID 8ID l1.li1. l1.li'8
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-- I"" "" III" 111)1'1 111)1'1
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WW12 """ .... 8ID :.u1l -. ~ .8.'-
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2) No poteDtia.l JI'OUDdwates- receptors
Grouadwater withiD the saprolite downgradieDt
of the lagooas tcDds to disdwge on-site ro the
UDDamed tribawy of Gilder Creet without a
$tllhctiaUy qg,.it;l'211t iDaease 0YCl surbce
water bac:kgrouDd CODcentrabons. There are
DO poteDbal JI'OUDdwates- receptors oa-site.
The GoIdeD Strip Task Group, or RcspoodeDU,
iDcludiog the 0WDCf of the Site, have apresscd
a WllIiIIlP'es5 10 establish iDstituDonaJ CODtroIs
(see diCl"l1c~ UDder AIteroatiYe 2 in the
SUMMARy OF AL TERNA TIVE..~ Sec:tioa),
where appropriate, to provide reliable coDtrol
against future use of the affected p'oUDdwater
UDtiJ CODStitucm CODCCDtradODS are DO longer
eJevared above acceptable limits.
3) Remedial ac:Uoa of the source material wiD
resuJt in a po:sitM iDfJueDce OD grouadwater
The preferred remedy to control constituent
pathways Duo groundwater wiD resuk in
6
.
-------
decreases of combtuCIII c:oactnttati01ll ova'
time. 01cmica1 degradatioa, dilutioa aDd
sorptioD to soil partidcs iD the aquifer UaouJd
be suffic:iCDt to urunDy attCDuate COD.Sbnleal
c:onccnuatioGs withoUt impactiDg health aDd the
environmeDt iD a rc1atndy short time-frame of
tWo to 6Yc years after source remedi.tinn
oa:urs. The ~ch"g mODiloriDg weD network
will be adequate for demODStratiDg the
improvemeDt o( groundwater quality with time.
Based on the aboYe CODdusioos. ACLI wiD be
established by EPA and SCDHEC for thole
CODStitueDtS which aa:cd MC1s during the three
groUDdwater sampliDg CYeD1S. These coosbruads
are l.2-dichJoroethue, 1.2-dichJoropropaac..
chromium. and lead.. A compreheasive Joag-ccrm
monitoring program IItiti7i"g the aistiDg moDi1oriD&
wdI netWOrk wiD be established by EP A aDd
SCDHEC to moDitor the conccotrations of these
coDStituents during implementation of the preferred
sourcc remedy aDd throughout tht Operation aDd
Ma1Dt~IUIlna' (0 " M) period of this projcc1.
Long-term monitoring of the grocmdwatcr wiD
provide a sufJic:icDt database for evaluating the
reprcscntative c:onccntratiODS of coDStitucD1s in
groundwater. Periodic ~u"'eDt of groundwa1er
quality c:ould result in the nced to CMhWe
addirlooaJ reme.diaJ action at the Site.
Actual ACU for the c:oDStitueats listed abcM aDd
the dctai1.s of the long-term monitoring program wiD
be ~Iopcd by EPA aDd SCDHEC iD the ROD
for the Site. The Aa.. cstablishmcat aDd associated
long-term moDitoriDg program for groundwater at
the Site is proposed for AhCtDa1iYcs 2 through 8
aDd iD the SUMMARY OF ALTERNATIVES
Section of this Proposed Plu Fact Shc:ct.
Lavoon Surface Wate!'
Surface water coataiDcd ill open Lagoon Nos. 1 &
4 ~ceeded MCLa for cadmium aDd chromium.
CoDCdiOD ad discharF of surfacc water
impounded ill tbese waste disposal lagoons to the
local PubUdJ 0wDed Tratmeat Works (POTW) is
proposed with Ahcrnativa 3 through 8 aDd
discussed in the SUMMARY OF
AL TERNA TJVES $e(lioo of this Proposed Plan
Fact Shc:ct. WestCt'D Carolina Regional Sewer
Authority (WCRSA) ud Mctropo6tan Sewer
District (MSD) offjcia1s ag1CC to accept disdwge
&om the Site, based CD WCRSA', em...
cIischarJc ltaDdards. PrctrcatmCIII of the cIischarJe
would be required it coastiIucats ezcecd WCRSA's
ltudarcls. RI data iIIdic:ate tba1 preUWmeat wiD
Dot be rcquirccL The estimated YOIume of sur1'ace
water ill the lagoons is approximately L9 miDiOD
gaDoDL
Affected Surface Soils~n SJud,es
A FS" was prepared to ~ aD appropriatc ruse
of remedial ac:tioD altemaiMs to address the areas
of affected surface soils and Jaaooa sludge& daat
('Y~~ remedial acDon target bds and is
availabJc for public review II the iDtormatioD
repositories. These remedial acUoa target IcYeIs for
atrected surface soils aDd Iagooa sludges were
established through the Baseline Risk AsscssmCDt
ud arc protcdiYc of humID health IDd the
environment. The areas., iIIcJudi.ac the suspcc:led
truck turnaround area aDd drainage swalc ftSt of
Lagoon Nos. 3 &: 4 arc delineated in rpc 3. The
estimated \'Olume of soil having waste c:onstit1Icat
concentrations ~,,~.di"g remediaJ action target
IeYeIs is 24,400 cubic yards. The estimated "OIume
of sludge e.xcu.ding the remcdiaJacbon target IeYds
is 4,(0) cubic yards.
Investigation of the abaDdoDCd drum area on the
casteI'D side of the Rice Farm indic:a1td that
concentrations of cadmium and chromium sJigbLJy
acccd soil remcdiatioD target cooc:cntrations in ODe
sampk. The csICDt of this CC)'It:lll'lilUlfiQa wiD be
furtber defiacd during the Remedial
Dcsip/Remcd1al AdiOD phase of this
project. It is C2peded that the wlumt of this
material rcquiriDg remediatioa wiD not sipificaD1Jy
macase tbc wlumcs DOted aboYe.
Thcsc matcrial wlumcs ud the locations in which
the materials were found were used to select
applicable remedial tcdmoJogics for further
consideration, ud to c1imiaate those tec:hDoiogic.s
that could Dot be tccbDic:aDy justified for
impJementatioD at the Site. The JUt of tedmoJosjca
that were identified through this saceniDg process
werc used to assemble eigbI aJrcruatiYcs
reprcseDtiog a range of treatmCDI aDd contaiDmCDt
altematM:s. These ahcruatiYcs arc disc:ussed ill the "
SUMMARY OF ALTERNA11VES Section of this
Proposed Plan Fact Sbcct. 'The long-term
7
-------
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SOURCE: AMY, .
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GOlDEN STRIP SEP
-------
JI'OUDdwaler mODiloriag program is indudcd for
A1tcrutM:s 2 throup 8 aDd discharsc ofimpouDded
IagooD surface watCt to the P01W is indudcd for
AJrcnwivcs 3 thtouP 8.
SUMMARY OF SITE RISKS
DwiDg the RJ, aD analysis was conducted to
estimate the humu health or euWODIDemaJ
problems that could result it the contAmm.tinn
id~..t1fied at the Site was DOt cleaned up. This
a.naJysis, mown as I BascliDe RiU As~$lftCDt,
focused on the poteutiaJ health effects &om
long-term direct exposure to the contAm,,,...t"
found II the Site. Ezposure sc:cuarios fOl both
cuneat land me and future land use were eYa1uat.cd
based on aD estimate of Rrasoaable MaDan..
Esposure (RME).
Uader the c:urTent land use scenario, potentiaJ
human receptors at the Site indude residenu in the
vicinity of the Site who may be occasional Site
trespassers. The Site is sunouadcd by resideDtiaJ
areas to the north, west and east. Residences are
prcseatJy being constructed in I new resideDtiaJ
d~lopmcD1 to the southeast of the Site across
from Adams MiD Road. Beyoad the r~..t1:aJ
areas immediately surrounding the Site. the JocaJ
area is Jess densely populated, and consists primariJy
of agricultura1land aDd forests.
Tbe most likely potCDtiaJ human receplors UDder
the current land use sa:aario are cbiJdrCD who
might climb the fence sunoundmg the property to
gain ac:a:ss. No private driDkiag water weDs wue
identified immediately dowagradicDt from the Site,
aDd no users of surface water for potable water
supplies were idtftf'~ downgradieD1 from the Site.
UDder CUl1'cD1 land use, the RME is reprCSCD1ed by
the individual that may be ~ by dirc:a contact
aDd iDcidea.tal iDgcs60D of surface soil. dirccr
COD1act with stream sedimCD1S ad sludges ill the
OpeD lagoons. and ~ of surface water iD the
lagooas.
PoteDtiaI eDwonmental receptors under the currem
land use scenario include the plaau and Anim:!J" at
the Site, induding domestic livestock. Site features,
including the smaD wmamed stream, two lagooas,
wooded areas and opeD fields, provide a variety of
habitats. No unique or scositiYe habitats ba~ been
identified at the Site. aDd DO ~ stR&s is
evidem.
Future laad uses for the Site were considtred to
iac:Judc development of the Site iDlo I resideDtiai
area or into I publit park. FOI the RME UDder
future Iaod use, a person who periodic:ally visits the
public park was coDSidercd. The ~ uufiYidual
UDder future laad use scenarios is usumed to be I
resideat 1Mq OD the Site. Uader both funJre 1aDd
IIIC sceaariol, the DIUDbet and type of
ezMrolUDCD1a1 receptors 8R likely to be more
limited tIwa UDder CWTCDt Iaad use SCCIWioI due to
rcductioD in CUl1'eD1 plants aadaaUu1s wociated
with n:sidcDtiaJ oc rcacatioaaJ de\odopmCDL
EPA has clctermined that elevated leYds of hea~
metals iD the lagoons aDd a.tfCCled soils pose the
primary hazard at the Site. Primary aposurc
pathways ror hea~ metals include dermal CODtad
with the waste constitueDts in each of the inactive
lagoons, and dermal contact v.ith waste CODStitueDts
loc:.a1ed in the surface soils in the immediate ,;Ciswy
of the lagoons. Air transport of parUculate matter
CODtaiaing coDStitucats of CODCCI'D is DOt of CODCCtD
beause the was&cs at the Site arc eUhcr UDder
water iD opeD lagoons 01 COYCI'ed with ~
Air sampliDg results indicated that airborne
constituents were Dot measured above baagrouad
~
The EP A bas established I range of 1 z ur 10 1 x
W as ac:=ptable limits for CKeSI &retime
c::udaoceak risks in the Natloaal 011 and
Hazardous Substances PoUUtlOD CoatlD&ac1 P\aa
(NCP), 40 a:R Part 300. Eu:css risk withiD EPA',
acceptable limits means that ODe perIOD ill 1O,«m (1
z ur) to ODe persoD in ODe aUDioD (1 z ~ wiII
risk d~loping amc::cr after I liCerlme of daily
czposure. A HazanI Jada (HI) "of 1.0 01 greater
has beeu established by EPA as the crilerioa
sugestiag I potCD.tiaJ fOl DOD-CUcioogeDic beahh
clJects.. Undu the -No ActioD8 scenario. (u.-1ft''''
the Site is DOt remcdiated) the estimated
carcinogenic risk for current Iaad use is 2 z 10".
The m for potential noa-carc:iDogCDit effects ODder
the same s.c:cnario is 8.1. The emmated excea
c:anccr risk calculated fOl the fumre 1aod use
sceaarios at the Site is 9 z IUS ror RME coDditioas
ancI 2 z 1«r for the maximum exposure (ME)
" CODditioas. The associated HIs for DODoCarCiJqeaic:
effects ODder these same SCCDarios are 10 (RME) "
9
8
-------
aDd 20 (ME). These calcu1a1ed risks c:sc:ccd the
acceptable risk IcYds established by EP A &Del arc
based OD the ISSWDpUOD thai DO c1wIup activities
have occu.mcL
Actual or thrutCDed releases of hazardous
substanCC$ from this Site. it DOt addressed by the
preferred ahematiYe or ODe of the «her actiYc
measures considered, may presem a c:urrCDI or
potCDtiaJ threat to the public health. welfare. or the
CllVirODJDCDL
SUMMARY or ALTERNATIVES
The fonowiDg sectiOD prcMdcs a summary of the
eigbI ahenwiYcs developed ill the FS Report to
address the surface soil aDd lagooo sludge
contamination 11 the GoldCD Strip SepUc Tank Site.
The primary objcetM of the FS was 10 determine
and ewluate alteruatiYes for the appropriate ex1ent
or remedial actioD to prc:veDt or m.itjga.tc the
migratioD or the te1e.ase or threatened release of
hazardous substanCC$ &om the Site. AC1s for the
obscrYed, iotermitteD1 Me. m:eechna:s of
. ].2-dichloroethaDe.1,2-dichJoropropane. chromium,
aDd lead ill IJ'OUDdwater and the associated
loDg-term monitoring program are proposed with
AIIernatMs 2 through 8 prcseD1ed ill this sedioD.
In addition, discharge of impounded surface water
in Lagoon Nos. 1 ct .. to the local P01W is also
proposed for AlternatMs 3 through 8 preKntcd in
this scaicm.
The foDowiDg dcscripUODS of remedial ahe~
arc summarizaboDL The FS Report coDtaiDs a
more detailed evaJuabOD of caeh altemarive and is
available for review in the iDformaboD repositories.
ALTERNATIVE 1- NO AcnON
By law, EPA is required to evaluate a ~o AdioD.
~ to ~ as a basis against wbic:h other
aItema1iYa cu be compared. UDder the No
Action Ahenaative, DO remedial respoase would be
perfonaed OD uy of the media 01 coac:ent (surface
soil. lagoon sJudge aDd Jagooa WIler) II the Site.
This altcrDativc does DOt reduce the risk cakulated
by the Baseline RUt AssessmeDL The No Action
AIIemative results in aD uccss c:aaccr risk of 2 x
ta6 aDd a hazard uulcx for DOD-CaJ'cinogcz1ie c1fcdS
of 8.1 for eurreat land use.
AL TERNA TIVE 2 - INSTITUTIONAL
COm'ROLS
The -wtitutioaal Controls. ahe.l'1WM establishes
iDstitutioaaJmUSW'CS to block possible waste
CODStitueDt aposure pathwa)'l through the affected
media: soil,sJud&e aDd lagoon surface water.
These iDstitutioaal controls include the foOowiq:
FCDc:iDa to limit ac::ccss to affected soils, sJudacs
aDd surface impouDdments; aDd
A COasenatiOD easement to CODttoi future Iaad
use.
Under this alterDatM. thOle arcu of the Site
cont~ining soils, sludges aDd Iqooe surface WIlen
with waste coDStitueDt coac:catraboas rxceeding
remedial actioD target CODCCDtratioDs would be
fenc:cci The fCDce wouJd CODSist of. sa-foo( high
c:haia link fCDce with at IeasI ODe strand of barbed
wire ateadiag aIoag the top. The COaservaboa
easement would grant cootroI of the laad in
perpetuity to a third party and prohibit. further
development of the property. The CODSCrvaboa
easement could be granted weD in .dvance of uy
remedial action 11 the SUe.
This altemative reduc:es the inaemCDtal risk for
currea1 Site conditioas by rcstric::bDg access to the
affected media aDd by preYCDtiDa fature land uses
that would allow repeated. frequent COD1ac:t with the
affected media. lmplemettt.tVw. of iDstitutioDa1
controls 11 the Site would reduce the Site
carcinogenic risk lad &om 2 J: 1a' to 1 x 1(T', aDd
the hazard iaclcx few DODc:arc:iDOgCD.S &om 8.1 to
0.14. The resuJtiDc risk as.sess-CDI considcrs oDly
those coasti1ucDts in soil samples coDected beyond
the area that would be fenced, since the fence
would prevent direct CODtac:t with the lagoons.
The estimated present-wortb cosl for
implcmentation of IDstitutioaa1 Controls is
S1.400,
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iD-plac:c, the total ~ame of alreaed soils ud
dudge$.
CAntaiDmeDt wouJd I~~ alfeaed soils and sludgea
in place with IittJc or no disturbance. A cap ~
alreacd soils at the swUce wouJd minimi7~ contact
betweeD percolatiug waler and waste coDStitueDts.
thereby reducing the potential for migratioa oJ
waste coDStitueDt.s to the groundwater. In additioa,
a cap instaDcd ~ the IOils and sludgc£ would
preYeDt erosioD of waste constituents by wind or
surface water runoff. The containmeDt CO\'U of this
type wouJd require periodic maintenancc and
iDspeaioD. The cap wouJd cover the soils with
waste cousWucDt CODCeDtraOODS eYtt.l"Aiw,g the
surface soiJ remedial actiOD targets. The tota! area
oJ the cap wouJd be 7.4 acres. Approximately 10
aac£ wouJd be disturbed by COnstructiOD activities.
1'No designs were considered for a coDtairunCDt
cover under this aJternative: .
ODtiOD 3A - Comrosite CoYer
The composite CO\IC1' option wouJd involve design of
a cap consisting or the 10Dawing components:
6 inches of topsoil;
12 inches of wWfeaed Dative soils;
2 feet of compacted clay; aDd
A layer or geotatiJe material
The day layer would be compacted to reduce
permeability to less than or equal to the
permeability or the subsoils below the lagooDS as
required by South CMoIiDa hazardous waste
rcguIatious. The final surface contours of the cap
wouJd be graded to promote runoff aDd reduce
iDfiJtratiOD during rainfall C'VeDts. .
The composite CO\W would be SOWD with
shaDow-rooted puses to lIIinimi7~ cap erosiOl1.
Grasses would be sdeded to lIIinj",i7~ possible
pcueb'ation oJ the ~ clay layer by the
dements.
OotiOD 38 - MuJtimccfia ~
The multimedia COYer option wouJd include .cap
desigD consisting of the (oDawing components:
6 inches or topsoil;
18 inches of wWf'eacd soil;
1 layer of geotcuiJc fabric;
1 layer of drainage material;
1 layer of flexible membrane liner; and
2 feet of clay.
The muJtimcdia COYer design complies with
SCDHEC requirements for hazardow waste CO\W
$)'Stems and wouJdbe dcsigocd to perform iD
iccordauce with EPA miDimam technology
guidauc:c. Like the composite COYer optjoa, the
multimedia cow:r woaId be graded to promote
surface cfrainasc and sown with dWlow-rooted
grassa.
Coot2inmCDt oJ afl'eacd solids . rcdu= the
iDaemCDt&l risk caJcu1ated for CUf1'CDt Site
conditioDS by pl'C\leDtUlg direa contact with afreacd
materials having waste coDStitueDt CODCCDtraboas
that cxc:ced remedial actiOD Wget 1eYe1s.'
ConstructiOD of the cap over the afreacd soils and
sludges would reduce the Site carcinogenic risk IeYeI
from 2:1t 10'" for CUITCDt laud use to 1 :It lu', and
the hazard indcz for carciDogenic effects would
deaeasc &om 8.1 to 0.14. These are considend
acceptable risk IeYds by the EPA.
The estimated prCSCD!-wortJI COSts for OptjODS ]A
and 3B of this altetDatM arcSJ,200,oo> and
S3,5OO,(XX), respectiYdy.
ALTERNA 11VE 4 - STABIUZA nON AND
OFF-SITE DISPOSAL OF seas AND
SLUDGES
AI1emative .. l'nnft!ts of the instituUonaJ controls
dcsc:ribcd iD Alternative ~ cxcavabou of afreaed
soils and sludge materials, and ofI'-site disposal in a
SCQIre Rao~ CoIucnatfOD and RecoYa)' Ad
CRCRA).permined 1aud6D.
This alternative iDcJudcs the removal of aD afreaed
solids with waste coDStituCDt COOCCD1raUoDS
~-r.~g established sumce soil remedial ac:tioa
WJet IcYc1s. The volame to be acavatcd would be
approzima1cJy 28,600 cubic yards. The =eat or
excavatiOD would be clelcrmmed by CODectiOD and
analyses of CODfirmation samples &om underlying
soils after the remO\'lJ oJ the sludge and
visibly-affected soils. Prior to acavatioa, a
sampling program woald be condUcted to determine
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the .c:tua1 volumes of surface soil and overburdeD
requiri.ag remedial .ctioa.
Stabilization is the Best Demonstrated Available
Technology (BDAT) for cadmium contaminated
soils and sludge&. OD-site stabilization of soils and
sludges would coDSist of properly mixing the
affected material with kilD dust prior to transport to
the disposal facility.
&cavated wastes wuld be transponed to the
Laidlaw (GSX) facility ill PiDcwood. South CMoIiDa.
This facility is ill compJiaDc:e with aD applicable
Federal and state hazardous waste requircmCD1S &Del
has the capacity necessary to accommodate the
estimated volume of WIStC. The selected wastc
transporter wouJd be ill faD compliance with
applicable FedcraJ aDd state cnvironmeDtaJ and
public health statutes. Vchidcs transporting from
the Site would also be apprOYed by the DepartmCDt
of Transportation (DOT) and .wouJd display the
proper placard. '
TcWdty Characteristic Lea,.hln& Procedure (TCLP)
. analyses of lagoon sludges aDd affected soils
indicate that cadmium may ach from these media
at concentrations that czcecd the La ppm standard
for charaae~ as . RCRA hazardous waste.
The Laad Disposal Ratridiou (LDRs) may
requite treatment of the cr.c:avatcd wastes prior to
disposal. StabilizatioD is the Best Demonstrated
Available Technology (BDAT) for nODwa:stcwater
cadmium wastes.
The lagoon areas would be dosed by grading the
excavations to promote draiDage. cov=ing with .
layer of topsoil. and scediDg to establish ~
growth. IDstitutioaa1 COD1rOIs would be
implemented by inc:orporabaD of . CODSCJ'\'3Uoa
easemCD1 aDd deed restridioas to restrid future
laDd uses ill the wastc maDaCClDCD1 area.
&caWOOD. t:reatmem. aDd olI'-site disposal or the
affected soils aDd sludges combiDed with the
institutioaaJ CODb'OIs for Ahemative ~ reduces the
inaemeD1aJ risk calculated for the Baseline Risk
~ccmeDt This aIt~ results in a maximum
carcinogenic risk level less than 1 J: 10"5 aDd a
hazard inda less than 1.0.
The estimated prcscD1-wonh cost of AltcraatiYe 4 is
$12,SOO,OO>.
AL TERNA 11VE S - STABI1.IZA nON AND
OFF-SrrE DISPOSAL OF SLUDGE AND
CAPPING OF AFFECTED SOn.s
Alterna~ S consists of the. iastitutiotW COatroIs
described in AlteraatiYe 2; escavatioa of \'iaibIc
wastes (sludges) acec'Ai~g acc:cptabie risk levds8Dd
off-site disposal of these materials ill a ICQue
RCRA-permitted landfiD as cIcscribcd iIIAhCl'DatiYe
4; &Del capping of the affected soils as described ill
Altenaab9c 3.
Approximately 6,600 cubic yards of sludge ud
o~ would be c:zc:avated, stabilized to IDCCt
applicable LDR concentration limits, stockpi]e.d, and
transported by trud: to the Laidlaw (GSX) FICIlity
discusvd in AltCrnatM.c. The Sitc aavatioas
would be 6Ded by pushiDg ill the bcrma and
SWTOUOding soils. Sludge &om the two opaa
lagoons would be dewatered prior to stabili:zatioD.
ExcavatioD woUld be limited to the removal of
materials visibly identifiable as sludge, aDd posaDIy
some OYcrburden from the backfilled Iagooas.
Sludge at the Site is typicaDy . grey-white color and
raDgC$ ill consistency &om a thid: paste ill the wa
lagoons to a soil-like t=ure ill the backfilled
lagoons. The overburden would be sampled to
determine if waste coDStitueD1 concentrations exceed
remedi.aJ action target levels for subsurface soils.
AftQ completion of the a.c:avati01i actiYibcs, a
composite cap would be coastructcd OYer all
disposal areas CODtaiDiDg waste residuals haviDg
CODcentrations that exceed the target levels for
surface soils. Tbe affected area requiring
CODSt:nICtioD ofa cap and amr is approximately 7.4
acres. The security fence would be a1cndcd to
include those areas to be capped that are curreD1Iy
outside the fencing. thereby providiDg aD addibooaJ
1cvc1 of protectiYcaess to the aItenwiYc.
Off-sitc managcmcDt of wastes by 1aDd611iag would
Dot reduce the toxicity or \'OIumc of the matcriaJs.
H~, long-term mobility of waste coDStitueD1s
would be reduced. Transporting wastes oif-sitc
could potentiaDy expose individuals using the same
roads, or IMng or working along the route, to .
affected Site materials m the ~ of aD accideD1al
spin or release. A greater risk is presented by the
amoUDt of traffic required to bring the day for cap
coastruc:tioa and to haul the stabilized wastc to the
laDd611. This alternative reduces the macmeatal
12
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risk. which was calculated for CUITCDt Site
condiuoD&, by rcatrictia& access to the affected
media aDd by prevcDtiDg future laud uses that would
allow repeated. &eqUCDt coDtaet with the affected
media. ImplemCDtatioa of AlteruiM S would
reduce the Site can:iDogCDic risk lnd to 1 x IUS,
aDd the hazard iDdcz for DODcarciaogens to 0.14.
The resultiDg risk ~u"'eDt considers oaJy those
constitueDts iD sOil samples coUected beyond the
area that would be fenced, liace the fcuce aDd day
cap wiD prevcDt direc:t coD1aet with the lagooas.
The limited ezposUR scelWio of future laud use
was used to estimate the resulting risks.
The estimated prCSCDt-worth cost of Aheraabve S is
$6,100,(XX).
ALTERNATIVE 6 - EXCAVATION AND
ON-SITE DISPOSAL OF SOILS AND
SLUDGES
The components of this alternative include the
iastituuoaaI coDtrols described in AlternabYc 2 and
excavatioo aDd disposal of affected soils and sludges.
Sludge &om the lagoons would be dredged and
dcwatered. Dewa1ered sludge would be combined
with affected soils, wbi1e filtrate liquids would be
combined with the coDected lagoon water f~
discharge to the P01W. Soils that coataiD
constituents ~"I¥-fi"g established surface soil target
conceatrations would be excavated and transported
to an oo-site RCRA laad disposal wUt. The RCRA
land-disposa1 UDit would be dcsigoed and
CODStrUeted speci6caDy for the disposal of
dcwatered sludges aDd affected soils with
constituents exceeding the surface soil
concentratioDS. A 1aodfiJ1 c10surc would be
implemCDted sooa after the disposal ac:tioo was
completed. The Iagooo areas would be dosed by
grading to provide proper draiDage, foUowed by
5t'#Ai"g to min""i7~ erosioIL
The on-sUe., doGb1e-tined IaudfiD coDStrUCtcd for
disposal of affected solids would ba\'e a capacity of
SO,(XX) cubic yudL 'ndfjD dimensions would be
approximately 23S feet by 23S feet at grade. The
depth of the IaadfiD excavatioo below ground
surface would be approximately 15 feet, aDd the
berm height around the JaodfiU would also be
approximately 15 feeL The IaadfiD would be
c:oDStnleted according to regulatory requiremeots of
the State of South Carolina aDd EP A These
requiremeots inclade CODStrUcUon of . double ]inQ
with . leachate coDectioo system aboYe and betweeD
the liners. Tbe top liner would be desiped to
prC"f'CDt the migra1ioa of waste constituents into the
lower liner. The bottom liner would be designed to
prev=t migration of waste coDStitucD1s. South
Caroli.aa Codes require a minimum of. tbtce.fOQ(
thick layer of reccmpaded clay or other Datura!
material as a bonom liDer. The permeability must
be DO more that 1 x 10"7 ceoUmeters per secoad.
The laadfiD cap is required to be less permeable
tbaa the soils immediately below the laadfill.
'..,.dfiP 0 eft M would iDdude a Dumber 01 tasks
oeceswy to protect the iDtegrity of the laud
disposal unit. Semiannual inspections and periodic
maiDteauce wouid be required 00 the Site ac:.cess
road, the security fenc:iag. the leachate CODcctiOD
and treatmeDt system, and the JaodfiD cap and
~r. which is apeded to aMr approzimate1y 2.7
8~ .
The long-term effe.c:tivcncss of tiis alternaiM would
be provided by proper mamteoaace 01 the on-site
laad6D. When compared to capping affected
materials in place, removal and Jaodfilliag oa-site
ofI'ers DO grearer cff'~css for ~Iume or toDcity
reduction. The mobility of waste c:.oastitueD1S wiJ]
. be decreased by placemeDt in a secure laadfi1l. The
acavaUoo of affected soils and sludges to surface
soil targets would result in . maximum aposure for
tiCetime excess caoc:er risk Jess thaD 1 X 10"5 and a
ID less than LO, which are the aiteria established
for the risk-based remedial ac:tioo target
coocentraboDS.
The estimated preseDt-worth cost of Alternative 6 is
$7,000,000.
ALTERNATIVE 7 - TREATMENT AND
ON-SrrE DISPOSAL OF SOILS AND
SLUDGES
Aherzwn.c 7 coDSists of cuavauoo of afl'ccted solid
materials as described in AheraaiM 4; treatmeot of
affected solid materials using either vitrificaUOD, soil
wasbin& or stabilization; and bat'Hini"g of treated
residuals into the ac:avatiODS.
The three foUowing process opUons were developed
and selected based 00 commerc:iaJ availabilityaodj or
. history of prior applic:atioa to similar
meta1-beariDg wastes:
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, .
OprioD 7A: Thermal TIQtmCDt- Vitrification; ,
OmioD 7B: Physical SeparaUOD - Soil WashiDg;
OprioD 7C: Pbysical Stabi1iz.atioD -
SolidilicaUoa/FmaUOIL
For the solid waste matcriak, the first step in this
alternative would iaclude the excavation of sludge
aDd a.fJccted soils baviDg waste constituent
CODc:eDtrations ~"I¥~Ai"g soil target CODc:eDtra1iODS.
FoUowiag excavation, the affected matcriaJs would
be temporarily stockpiled for prO«~C;"g prior to
trcatmCDL The solid waste material requiriDa
treatmeDt is estimated to c.oasist 01 appronmately
22.,400 in-place cubic yards (28,(XX) loose cubic
yards) of a.fJcctcd soils and sludges. A sampq
program would be coDducted prior to acavatiOD to
dctcrmme the actual wlumes 01 surfacc soils and
OYCtburdeD requiring remedial actioD. TreatmcDt of
soils and sludges would be required to meet the
limits imposed by the RCRA LDRs. Treated solids
would be disposed of by b,rifrning thc cxcavatiODS.
A oDe-foo( layer of unaffected aatM soil, and a
six-inch layer of topsoil would be placed OD top ol
the treated residuals. The topsoil would be sown
with shaDow-roo(ed grasses to mi.aimiz.c erosion.
OptioD 7A:. Thermal TreatmeDt - VitrificatiOD
This option includes the use of a transportable
WriJicatiOD unit that would be located at the Site by
a commercial vendor. The UDit would be required
to meet the substaDtM: requiremCDts of aD
applicable Federal or state permit conditioDS. This
system wouJd consist of the foDowing unit
operations:
Material prepr()t"~CCi"slsortiDg; -
VitrificatioD unit;
Hood for coUcctiDg gases and fumes; and
Saubber water treatmCDt.
MobilizatioD aDd startup of this system could
require more th.m two)alL Startup tcstmg of the
system prior to full-scale operatioD may also require
several months to complete. ASS11ming aD operation
olIO bours per day,S days per week, vitrificatiOD of
22.,400 cubic yards would require approximately 1.30
weeks of operatiolL
The vitrificatioD process bas demonstrated limited
succ:css with the more wlatile metals. such as
arsenic, cadmium, lead and merc:wy. Arsenic and
cadmium were icfCDtified ill Ugaificut quantities at
the Site by the RL VlUUlClboa technology has
prCMD that 8S-90 perccm of the arsenic aDd '5().a)
petCCDt ol the cadmium CID be retained ill the
vitrified moaoUtIL The vitrificatioD system would be
equipped with aD air scrubber system to reduce the
emissioa of these metals in the cmaust gases. Stale
-Iaxies rcquiremCDtl would ha~ to be met by
emissions from the viui6catiOD process.
~OD 7B: Pbygca! Separation - Soil WJI~hin,
Soil washing is . batch process in which soils or
sludges are thoroaply maed with successiYe rinse
solutions formulated to remoyc amenable fractioas
of waste coDStinJeDts from the soils aDd iacrt
puticJe$. Acid rinses arc frequeDtly used to
solubilize metals, traDSfcniDg the metals from a
solid or sorbed state 10 aD aqueous phase. The
aqueous phase is then separated from the solid
matrix by dec:aabDg. The riDsate from this step is
theD treated usiDg CODYCDtionai wastewater
tccbDology for metals remowl, such as pH
adjustmeat, floc:aa1atioa., clarification. and
dcwaleriag. A soil washing system would consist of
the foDowiDg uni1 opuatioDs:
MatcriaJ pro<-ci~slsortiag;
ReageDt storage;
Solids ~
Solids readioD;
~nhng aDd solids wasbiDg; aDd
Reagent rccydiDg aDd recoDditioning.
Process wastewaters would be lemporarily stored in
on-site tanks umiI reeydcd. Wastewater sludges
would 'be dewa1ercd and stcx:kpiled. Dcwatcred
sludges would be traDsponcd to a RCRA -
approved fac:illiy for treatment and IaDdfiDed
disposal in the CYCD1 waste characterizatioD of the
sludge materials indicated they were a characteristic
hazardous waste. For 22.400 cubic yards of affected
solids. a soil washing opcratioD olIO hours per day,
5 days per week would require SS weeks of
operatioa.
OptiOD 7C: Phvsica1 Stabiti~tioD/SolidificatioDI
rlXatioD
PbysicaJ stabilization is . remediatioD tcd1Dology
frcqueDtJy used for affected soil aDd sludge. New
RCRA restricnoDS banDiDg 1aad disposal Of
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bazardous wastes recommead stabilizatioa.
IOlidificatioD, aDd/or 6xaboa for a majority of the
c.baraderistic hazardous wastes. 1'1Us treatmem
would tCDd to reduce the mobility o( waste
COnstituCDts by biDdiag the soil or sludge with
solidifying agCDts into a IQbIe, ofteD solid, matrix
that would resist leaching. Solidification results in
the (ormation of a low permcabilily monolith. This
solid monolith is pre(erable to stabiIiz.cd, soil-like
waste wheD routine ac:cess to the treated waste is
prccfidcd. A solidification treatment system would
consist of the foDowiag UDit opcrabODS:
Material prOCt'cd"g/sortiDg:
Setting agent storage; aDd
PugmiD mixing.
The effcc:tiYCDcss of solidification has been
demonstrated at many CERCLA Sites for a wide
variety of inorganic aDd low Ievd organic anaIytcs.
Leach testing 01 treatability samples of sludge &om
the Site was conduded to determine the feasibility
of providing a solidified waste exhibiting acceptable
quantities and concentrations of leachate under test
. conditioDS. TCLP anaJyscs of solidified sludge
indicate that solidification with Port1and cement is
sufficient over a range of mix ratios to prC't'eDt the
gCDCratiOD of leachate a~i"g hazardous waste
&milS. ComprcssiYe strength testing suggests that
this solidified matcriaJ wiD have acceptable
geotechnical charadcristics.
The equipmem required for solidification would be
similar to thai used for cemCD1 mixing. The treated
matcriaJ would be traDSportcd back to the
ucavabon for curing aDd disposal Assum.iDg aD
average throughput of 2S cubic yards per hour aDd
aD operation ol10 hours per day, S days per week,
solidification would require apprmimatcJy 2S weeb
of operation.
Each of the three potential treatmcnt options
prcscDted UDder this aI1ernaUYc has beeD shown to
be effcctM ill redDCiag at least ODe of the three
waste cbaraderistics: tCDicity, mobility, or volume.
for ODC or more of thc Site c:oastirueDts of CODcern.
This combination of waste treatment aDd capping
the backfilled residuals with a soil aDd vegctatm
cover meets EPA's criteria ol permanent remedies
that provide for protCdioD ol human health and the
CDwoDlDeDt. Tbeincremental risk after
implementation of any of these treatmcnt options
would be 2 z 1US for c:arciDogenic c:oastiriaeDts aDd
0.17 for the HI. Both are within accepted EPA
guidc1iDes for risk aposure.
Estimated prcscAt-wattb c:osu ue as foUows:
Option 7A; S19,cm,(XX);
Option 7B: S13,8OO,(xx); and
Option 7C: S4,5OO,(XX).
ALTERNATIVE 8 - IN-SrnJ TR.EA TMENT OF
SOn.s AND SLUDGES
AI1~ 8 co"dctf of treatmem of affected soils
aDd sJudge in-place, CX' in-situ. FoDowiDg trea!meD1,
individual treatmCD1 mDCS would be covered with.
ODe foot of dean soil aDd sown with shaDow-rooted
grasses to mi"i",i7~ erosion. Three proca.s options
were selected based on commerc:iaJ naiIabiIity
and/or history of prior application for iDorganic
wastes:
Oorion SA: Thermal TreatmcDt - ID-Situ
V1tri6catioa;
QpriOD 8B: Physical Stabilization. - lD-5itu
'SolidificatioD; aDd
Option 8C: Physical Stabffization . ID-Situ
PrecipitatiOIL
The surface IoiI rcmedial .ctiOll target
concentrations would be used to dctcrmiDc the
treatmCD1 boUDdarics for surface soil&. Treated
solids would remain iD place. A sa-inch layer of
clean topsoil, and a six-inch layer of unaffCded
naUvc soils would be pbccd on top of the residuals.
The top soil wou1d be SOWD with shaDow-rooted
grasses to mi"i",i7~ erosiOIL
ODtion SA: Thermal Treatment. la-Situ
Vitrification
The In-Situ Vatrific:atioD system would consist of the
foDowiag unit operatioDs:
Vitrification Unit;
Hood for coDectiDg gases aDd fumes; aDd
Sc:rubbcr water trcatmCDt.
The in-situ vitrificatioD process bas emibited I
higher rate of success in capturing volatile metals
thaD the abcn-e-ground process. As tcmperatures in
the treatmeDt ZODCS acccd the melting temperature
15
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of the soil. the moltCA soil tCAds to eDtram awl)' of
the more ~tiJe metals. such IS ad aDd cadmium.
MobilizatioD aDd startup may require iD C%CCSS of
two years due to the lack of commerc:ially available
trealJDeDt UDits (or Yitri6catiOlL Startup tests
required prior to operatioD may require se-.uaJ
additional months. Throughput (or YitrificatioD is
slightly lower for iD-situ materials than for acavaled
materials because the cquipmem must be rdoc:ated
after each iD-siru WrificatioD qdc. ~n",il\B aD
operation of 10 houn per day, S days per Met, ill-
situ YitrificatioD o( 22,400 cubic yards would require .
OYer 200 weeks of operatioD.
Qption 8B: P~vsical SolidifiabOD - ID-Situ
SolidifiatiOD
This option includes the use of deep soiJ mhiDg
equipmeDt that delivers solidifiatioD reageDtS to the
affected solids during mixing .operano&. The
process involves augering into the affected Solids to
the desired depth using hoDow-stem augers.
Treatmem agcnts are injected into thc disturbed
matrix through jcu constructed in the auger blades.
This systcm would consist of thc foDowiDg unit
operations:
Drill Assembly; aDd
ReageDt CoDtaiDers and Feed Systems.
DriJliDg depths arc limited, but depths up to 30 feet
arc reportedly attainable. TrcatmcDt duratioD wiD
vary by depth and by the amount of mixiDg required
to cnsure adequatc solidific:atioa. Trcatabi1i!y
studies would be a=essary during the remedial
desip phase to sc1cct the optimal reageD1
compositiOD aDd form. TcstiDs of the solidified
treatmCD1 zones would also be nc=ssaty to CDSure
that performance requirements are met.
Qption Be: Phvsical StabJ'i7~tiOD - In-Situ
PreqpitatioD
This option iDcIudes the addition of a precipitation
agcnt to the affected solids to bind the inorganics
and reduce mobility. Reagcnts are added to the
soils iD-situ and aDowed to percolate without
pressure. A physical stabilization system would
consist of the foOowing unit operations:
R~ Miz Tank; aDd
R~ Dc1iYcIy System.
The c.zpccted dlicieacy for this optiaG is
Site-specific. Treatability studies arc _.--c..sry for
evaluation o( in-situ precipitation prior to Rmedial
ac:tiOD. ID addition to cvaJuabDg the
parameter-specific effcctiYcDCS5 of the treatmeDt
process. the treatabi1il:y study would (ocus on such"
physical properties II soil permeability aDd
gram-size cfistribubaa.
Estimated prcsem-worth costs arc IS (oOows:
Optioa SA: $13,200,000;
0pti0D 88: $4,100,000; aDd
Optioa 8C: $4,300,«m.
EVALUATION OF ALTERNATIVES AND EPA'S
PREFERRED ALTERNATIVE
Based on thc analysis of alternatives presented in
this Proposed Plan Fact Sheet, EP A has ideDtified
Alternative 7, Option 7C - Solidification/F"aabon as
thc preferred ahCl'DatiYc for addressing surface soil
and sludge c:ont.min:ation at thc Golden Strip Septic
Tank Site.
EP A's preferred altemative, AltcraatM: 7 - OptiOD
7C, coDSisu of the following componCD1S:
1) Establishmc:Dt of ACLs for 1.2-dich10r0cthaDc,
1.2-
-------
uaJyz.e the altCtD&tMs considered for addrcssiaa
cont....iluatioD II the Site. The PS Report for the
Site dcscribcs. ill detail. the ahCJ'DIIM.s coDSidercd.,
as wcIJ as the proc:css aDd c:riIcria EPA used (0
DarrOW the list to eight potcntial alterDaUYes (0
address contam.iDated surface soil and sludge.
EP A used the fonowiDg Dille aiteria to evaluate
alternatives ideDtificd in the FS. While ovuaIl
protection of human health and the enwonmCDt are
the primary objectMs of the remedial ac:tioa, the
remccfia1 altcrnatM(s) selected for the Site must
acbiCYC the best balance among the evaluation
criteria considering scope and relatiYc degree of the
contamination II the Site.
The first two criteria are significaot in tcrms or
statutory requiremcnts. These -rhrcshold Critcria.
must be met and are desaibed as fonows:
1) Overall Protection of HUmaD Health and the
EnWonmc.nt: EPA as~ the degree to
which each alternative eliminates, reduces, or
controls threats to public health and the
enWonmem through b'eatmeD1., eogiDeeriDg
methods or institutional controls.
2) Compliance with Applicable or Relevant and
Appropria1e Requirements (ARARs): The
alternatives are evaJuated for compliance with
an Fcde.raJ and state enwonmentaJ and public
health laws and requirements that apply or are
relevant aDd appropriate to the Site conditions.
The next 1M c:riIeria form the basis for the analysis.
Tbcsc are refened 10 as "Balancing Criteria" and
include the folJowiDc:
3) Short-Term Effcc:tr.uess: The length of time
needed to implemem each altel11atiYc is
considcrcd, and EP A ISSelseI the risks that
may be poled to workers and nearby resjdents
during c.oastruction and implementation.
4) Long-Term Efl'ediYeness: The alternatives are
evalUaIed based on their ability to maintain
reliable protection 0( public health and the
enwonmeD1 over time once the cleanup goals
have been met..
S) Reductioa or Toxicity, Mobility, or Volume:
EP A cwhwes the anrlcipated perfOJ'JIWJCC 01
the .specific tre.atment tedmolosica an
alteraatM may employ.
6) Implemenubility. EPA evaluates the techDical
and adrniniurative feasibility of alteraatM:s and
the availability of ~uired resource$.
1) Colt: This ~~~em evaluates the c:apita1,
UDual 0 It M, and present-worth costs of each
a1t~
The remaining two c:riIeria are evaluated by EPA
and are c:oDSidercd to be -Modifying Criteria".
These include:
8) State Acceptance: EP A requests lUte
comments on the RJ aDd FS Reports, IS weD as
the Proposed PIan. and considers any
preferenC'eS or concerns the state may have
about thc altc:matna. .
9) Commwdty Acceptance: To ensure thai the
public bas aD adequate opportDDity to provide
iDput. EP A holds a public commem period and
c:oDSiden and responds to aD commCDU
rcc:ciYed hom the commwdty prior to the fiDa1
selcctioD of a remedia1 actioD.
Table 2 01 this Proposed Plan Fad Sheet
summarizes how the altematM& were evaluated
against the ~olcr and -S~ Criteria. In
Table 2, the altematiYCS are ruked acx:ordiDg to the
relative degree to which each satisfies the criteria.
Where the benefits 0( ODe aherDa1iYc are similar to
those of another. the altema1M:s are .~S""'~ the
same numeric value. The numbers listed in the last
raw arc cumulative SCOI'C$ of the rankiDgs for each
ahemative. These numben arc summed to show
the degree of relative compliance with th~ 5a'en
-rhrcshold" and "Balancing" Criteria. The ra.nkiD.g
system is dcsiped so that the alternative with the
lowest score proYidcs the pcatCSl degree of
compliaDce, for the seveD alternatives, with the
c:riIeria.
Tbe final two aiteria, or -M~ Criteria wiD
be addressed iD the ROD ODCC comments ba~
been received by SCDHEC and the public.
SCDHEC bas reviewed this Proposed I'1an and
concurs with EP A's preferred ahemative. EPA and
SCDHEC will continue to work together during the
17
.
-------
TABLE 2
COMPAAATM! ANAlnrs 0' AlTERNA11VES
GOLDEN 8TR'~ 8EPnc TANK 'EAS'SIUTY STUDY
~
00
........ . ........ I ......,
~, ........ . ........ . ......... .... 0888 ......... .... 0hI8 ,........ .... ....
~ " ....... .... ........ I
....... IIIoIIoII8MI c... c:...w.~. ...... ~".... c.o--.." ~.... .......".... to.. ,-"....
, \O.~ ------ o...M!I"'~ c.-... ...... - .... c.-... ....... - .... ,.... c.-... ....... - 8M 00l8oI""'" -.... Ce8MI""", - .... ,....
---- -......-... ,...... _. ...... .. -. e.-...... po-." -. ~.... po-." -. "..... ..-. ~......
........ .......... 8M .. ....... .... ....... ....... .... ...... ......,.......... ..... ....... .... ...... ..... -- .... ..... &....,. ,
........ - ~ ..... ................... - ........ ....... ....... ,........ lJr W~ - _4. ,-..---
J .1 r .64\"""'''' .... .. ---............ ............ .... .. ............. AM ........ - .... -....
-- ........ .... eM ...... -.... ...... - eo- ....... .... ... - .... ---- -..... .......
......... CM8I8..tee. "1ft ---. ...-.~. .......... CNI8 MIL... AI -..- -- --- -
........ ............... --.II. ............. 8M""
CI8IIIII...!IoA .AU---'
0tIIItI
0-1""" ... ....... .. ..... TNt............... TNt ........ ..... TNt"""""""''''''' TNt .....- ..... .... .. TNt"""''''''''''" TNt ............ ......
" '-- ..... ......... .-oft .. ......, ..... .-oft .. .. ....,...... ..~.....-- .. --....... -- III --....... - ..~.......--
...... nw......... - __IWI"'. __IWI"'. IWI 10M... ,. ,.. 8M . IWI " , . ,.. 8M ...... - .... ".. ,.. 8M . .... " 1 . ,.. .... . ....
.AuL- III .......... ".8M . ..... ...." '0. 8M . II880It .... " ..... .... 10M 11M ,... ..... "0. ,. .. ..... ..... ".. " .. ..... " .." ..
11 -.....--.. ..,. .. n~ lj""'" .. ,. .. 1\8......," ~.. P-...AI."",~"", 1NI --.AI......."'" 1N8 _...4I~."'" 1N8 --............ 1N8
.. III -- ....... ...... TNo""'" ...... 'NIl""",,, .......... ........ ~ ....... to. . ... .......... ............... ........,...... ~
-_....~ -.. ....... ..... .. ...... ..Ala .. .... --"........... ....- .. ....- ....... " .. ................. ----"...........
I. to. .......... ........... - r. ... 0 ...... ... ........ ...... 88l1li\ W ... .. .......... .... .. ....... ...... It, ........ --.. ...... ..,
... "I.t .. ...... --=...... -....-...... .. ...... .... .... .......... ..-... hi""'"
_tA"'''' ......,.... ....... MIl" - - MIl. , ...... tII ""'1'" JJ. ....
..... PI ~ ... tit. ...... -....-
~...- 11M""""
~ . . .... 10M --.
_...._~~
.1"
1f ,,,~ II .. WII ......... WII"", .... " WII ...... MMa. It. WII .... AMRa. ... WII.... MMa. ft, WII.... MMt..... WII- MMa. "'--"
INII8 " ........... ...... - MMa. lit -......."
INI/I& lit ,NI.,L..J..A-1I' .... ...
....... ,......, .. ......
-, ......... et,
.
SOURCE: RMT,INC. 1991
-------
TABLE 2
COMPAAA1M! ANAlYSIS OF AlTERNA11VES (cone)
GOLDEN STRIP IEPnc TANK FEA81UIUTY STUDY
~
o
--...... ~. ........ ,
......... . .......... ~I .....,. - 8M 011... .....- 8M 011... ,.......... 8M 0...-.
~......... 8M ~.
...~ ........... c... ,~., ,A~A ..... 0I0pe0eI" ... e»........- .. ~ ... ....... ....... .,..,-......
~ .....- W8 .. ....... III W8 --,......... WII--.... " .A """-"" .. ....... ..... ,............ -. ,....... .. ..............
- ..... M'" .......... .. ........ ......... _""~~.I -.... ........ ~ M . ~ ...-.... - - 8M ......... --......... ~--
. ....... .. ---. ........ 8M ..-.. ~ .......... .... ...... ~ 8M""""'" ........ .. ......... - -............. ,...... .......
................ ....... ,"., . .. ..... -lit ............. ~ -~- -- dr. .. ...... Ct. ~A -Ct.
............. -fit ..... ........ ft. ........ ,...... ....-
........ IItJ" ....."
-...... .. ..
....... .. ---.
.......... .... ..
....... fit
......... .. W8 ..... ...... W8 .......... W8 .... ........... WII__--.. WII .... ......... ....... ,-............. ,_.............
......~. . .... 11 --.. ---. ,......... - ..... .... ...-. "~ .... .... ... 8M ..... .. ...... .Md ........ ~ ........... ----.... ~--
...... lie -.... ....... .. fit ... .... ..... ....., . ....... ft. - --........... ....... ....... ........ .......
~ ~...... ...... -.... - I. .........- Ilk. _Il.o.4l ". f .-.1') IlJlI ,..- ft.
... j ... ... r lit " '-.1."
---- ... .......... WII,...... ...... .. ~~ - 8881\1 .. ....,,-..,...... - .....,., .. 6Ut1il080.A - ...., .. 4118Y1t.J.. 111 .. .. .............. - ......
- t ..4 .A.b. _AIR" "... 1. .... fl. "., ......... ....... ... ... ¥1811818" . - ".. ~....... .......... ....... - .... -J. ... --....-
..................... ~ l 1II'i.""" ..... ~ ............ ................ --- ..... ~A-""'" ~"_II.... .. - ........ """"'"" ....,
..... .... .. .... ..... lit .. --- - 1 -4. till ~I. 1 ..... " .......... "'I. .J. ~ " ......... " ... ..... '-.. . J. fit
..........
."',,,.. -. 1'1'
t -' r""~ '-'" --..- ,. fl. ........ ~..- iii . '"II 'I ............... ......... ........... Ire-:! 1'1 n ......... ,........ ......, .. ., ...
. ,..-11 ........... ut .. ~. ... ...... It ~..........,. ......... ......... It ~ lot> 11 ~ II,.... . r- 6 .. .... .. ...
..... ......... go 1aIIIW....,... " ........ .. ........... ........... fWI8a... ............ ~_......J. ......... go
1'1' 1aIIIW. ....... ........ PJ ......., .. ...... ..... 1aIIIW....... MeN"-
1aIIIW. ....... I "". . T ' ~'--,
fit ---- tDI'I...,...". ..
o.e '- ..... Ct. '- .... lit '-........ .... fit ..... ..... PJ ...... ..... fit a-.. ....... ..... fit a-.. ....... ..... fit
II.".'" 11',408.'" IIUDO.'" "'I.IDO.-. "'.'00'-' ......... "'.'111.'"
~ . - .... - . rr - . .. "
.
SOURCE: RMT, INC. 1991
-------
ROD Phase aDd the remainder o( the remedial
process at the GoideD Strip Septic TaDk Sile.
CommODity participation a.od acccptaDce is further
elaborated in tbe COMMUNITY
PARTICIPATION section o( this Prop0se4 Plu
Faa Sheet.
AD alternatives, except Altel'DatM 1, provide
adequate protection o( humaD bealth aDd the
enwomneDL Treatment AlternarMs 7 It. 8 ~
cweraD proteaiven~ aDd risk reduc:boD by
pcrmaDently treati.Dg the waste aDd using the
treated materials to pre~nt contact with less
affected soils beneath the treatment uea
Removal AhenwiYes .. It. 5 also permaDentJy treat
the waste aDd remo~ waste materials Crom the Sile.
H~, aD ina-cased risk of injury to the general
public: is significant because of the number of
~hic:1es required to transport the stabilized waste
materials to aD off-site disposal facility, thus
signific:antly rcdudng the short-term effectiveDcss o(
these removal alternatives.
Ahemativc 6 was not retained for further
consideration. Neither the YOlume nor tOJicity of
affected solids would be reduced by the
implementation of this altemativc. Mobility would
be reduced in a properly-construc:ted laDd6D, but
long-term maiateDaDce would be "senti21 for
protCdion o( the enwomnenl III addition, the
atlminiarative feasibility of siting I hazardous waste
IaDdfiD at the Sile is ~ry doubtful. "
Treatment AltematiYcs 7 It. 8 aDd Altcraa1M:: ..
provide a high degree oflong-term cffcctMncss aDd
reduction of toxicity, mobilliy, or 't'Oiumc.
Treatment of the affected areas or off-site disposal
wiD eliminate waste source areas, providing
long-term effcaiYcDes.s aDd a reduc:tioD in the
toxicity aDd mobility o( waste constituents.
Containment AltcmatiYes 2., 3 aDd 5 reduce the
migration of waste constituents, but do not reduce
the toxicity of the waste at the Site.
The stabiIizabaa aDd solidificatioD processes
proposed (or AhenwiYes .. through 7 baYC been
routinely applied with suc:=ssIuJ results to soils that
arc typical to this partic:u1ar region of South
Carolina. However, the in-situ processes of
Alternative 8 baYC not been weD demonstrated for
the large areas requiring treatment at the Sile aDd
arc more likely to cxpcriCDCe operational
diftic:uJties. The stabilization aDd solidWcatioa
treatment process of Alternative 7 - Optioa 7C,
should prOYC to be reliable aDd effcctM, based oa
the available information.
Treatment Alternative 7 - OptioD 7C provides
perma.ocnt remedies at costs that are mid-range (or
the eight remedial action alternatM:s. Containment
achiCYCa the same IcYCl o( risk reduction for
approDmately 40 percent less cost, but with less
permanence. The source removaJ altcnwiYes
(Ahernati\u .. " S) also achieYC substantial risk
reductioa in terms of future exposure to waste
coDStitucnts, but the short -term risb arc greater
thaD for the other alternatiYCs, aDd the costs arc
higher.
The EP A bcli~ that the preferred alternatiYC,
StabiIization/F"aabon of affected surface soils aDd
sludges is effective in protecting bumaD bealth aDd
the enviroDlDent, complies with aD ARARs, is cost
eff~ uti1izes permaDent::; solutions and
altemabve treatment or resource rCCOYery
tcdmologies to the maximum extent practicable, aDd
satisfies the statutory preferencc for treatment IS
the principal clement.
COMMUN11Y PARTICIPATION
EPA wiD bold a public: informational meeting at
7:00 PM, oa Thursday, June 20, 1991, at the
SimpsooWle Community Building in Simpsoaville,
South Carolina to describe the preferred altcmatiYC
aDd the other altematiYes cvaJuated in the PS. The
public: is eDcouragcd to attend this" meeting to bear
the presentations aDO to ask qucstioas.
EP A is conducting a JG.day public: c:omment period,
from June 17, 1991 to July 18, 1991, to provide aD
opportunity for public: in~Jvement in the 6DaJ
cleanup dccisioa for the Sile. EP A may extend this
comment period upon receipt of a timely request.
Public: inpw on aD altcrnatiYCs, aDd oa the
information that supportS the a1tcrna~ is aD
im portant contributiOD to the remedy selection
process. During this comment period, the public: is
invited to review this Proposed PIaD aDd the RI.
SRI and PS Reports, aDd offer comments to EP A.
These reportS aDd other Site-related documents arc
located at the informatioa repositories listed below.
The acruaJ remedial ac:tion, as presented in the
Record of Decision, could be different Crom the
20
.
-------
1-
preferred aJlcmatiYc, depeadiDa UpoD Dew
wormatioa or UJUmCDlS EPA may coasjder IS ..
resuJI o( pubic mmmcau.
U. after revicwiag the iaformatioD OD the Site, you
would like to coinmeD! ia writiag OD EP A's
preferred aI1cnwM, aDY of the other deanup
alternatives under consideratioa. or other issues
rclcvaat to the Site deanup, pJcasc submit your
commeDts to EP A at the publk meetiug or mail
your writtca comments (postmarked ao later thaD
July 18, 1991) to:
Craig R. ZcDer
Remedial Projc.d Manager
U.s. EPA . Regioa IV
WasteDMsioa
North Superfund Remedial Branch
345 Courtland Street, N.E.
Atlanta, GA 3036S
(404) 347.1791
EPA will rC\'icw aD commeats rccciYcd from the
public as part of the process o( reaching a final
dccisioa OD the most appropriate remedial
a1te~ for deaaup ol the Site. EPA's 6naJ
choice o( a remedy for the Site wiD be issued ia a
Record of Deasioa scheduled (or the CDd o( August
1991. A cIoc:umCDt, caDcd a RespoaslveDeS5
Sum~ which summarizes EPA's responses to aD
commeDts rcceiYcd duriag the public commCDt
period, also wiD be issued with the ROD. Once the
ROD is sjgned by the EPA Rcgioaal Adminictrator,
it wiD bec:omc pan of the Adminictra1iYc Record.
The Adminisarative Rec:ard coDtaias aD documents
used by EP A to choose a final remedy for the Site.
The Adminisarative Record is contaiaed ia the
wormatioD rcposi1ory and caa be found at the
(oDawing locaboas:
GreeDviIIc Public Libruy
South CaroIiDa Room
300 eon. Street
Grccavillc. SC 29601
(803) 2A2,.5CXX)
SimpsonWic Branch Library
102 Academy Sired
SimpsoaWlc, SC 29618
(803) 963-9031
For further iaformaUoa ia regard to community
partic:ipatiOD at the Site, please coat&Ct:
C)'uthia PeuriCoy
Community Rc1atioDS Coordinator
U.s. EP A . Regioa IV
Waste DMsiOD
North Superfund Remedial Branch
345 CowtJaad Street, H.E.
A1Jaata. GA 3036S
(404) 347.1791
GLOSSARY OF TERMS
.4dmlnlctntlve Ordu OD CODSCDt (AOC) . A lcp1
and enforceable agrcemeD! siped betwcea EP A
aDd po(eatiaJ respoDsible panics (pRPs) whereby
PRPs agree to perform or pay the COSt of Site
dcaaup. The agreemeDt dcsaibcs actions to be
rateD at a Site aud may be subjc.d to a public
commCDt period. Ualike. CoaseD! Deaee., aa
AdminicfFatM Order oa CoaseD! docs DO( have to
be apprOYcd by a judge.
.4dmlnlstntm Record. A file which is maiataiaed
aad coDtaias aD wormatioD used by the lead ageacy
to make its dcc:isioD oa the seJectioa of I ccspoasc
ac:tioa UDder CERQA This 6Ic is required to be
available for public review aDd a copy is to be
established at or DCU the Site, v.suaIJy at the
iDfOrmaboo repository. A duplicate file is
maiDtaiDed ia a ceDtral Joc:atiou such as I regioaaJ
EPA aDd/or state office.
Alienate CODteDtJ'atiOD UaaJt (ACL) .
Grouudwater CODtami,u,nt CODceDtratiODS that arc
aDowcd to ac.ccd Maximum CoDr2min:anf Levels
(M~) or humau health based CODCCDtratiODS oaJy
OD the property of the hazardous waste Site
prOYided oace the groundwarer coatamiDatioa
reaches humaD rcc.cptors or aquatic life, it DO longer
poses a health threat to that rcc.cptor. The
red1Jdjoa ia tcmcity is usually attnoUled to
dcgradatioa, aaturaJ atteDuatioD aDd/or diJutiOD of
the contJlminJint
AquUer . AD uadergrouDd roct formatioa
composed of materials such as saad, soil or gravd
that caa store aDd supply grouudwater to weDs aad
spriDgs. Most aquifers used iD the UDited States
are within a tboUSaDd feet of the earth's surface.
21
.
-------
Back&rouDd. RcCers to samples that are coDcded
away from bow CODtamiDated areas of a hazardous
waste Site. Background samples arc used IS a
means or compariDg bOWD coDtaminated areas to
bOWD clean areas in order to d~t~rmiDe the
relative contaminatioD of a Site.
BaseliDe Risk A.Ssessmcot . A mcans or estimating
the amount or damage a Superfund Site could cause
to human hc:a1th and the cDvironmeDL Obj~
01 a risk ~scmeDt arc to: help determine the
oc:cd for actioa; help determine the Je\ds of
chemicals thai caD remaia OD the Site and stiD
project bc:a1th and the eDvironmeDt; and prOYidc a
basis for comparing differcDt cleanup method&.
CardD08CD. a substance that causes cancer.
ComprcbCDsln EDvlroomcotal Respoosc.
CompensaUoD, and Uabmt)' Act (CERCLA) . A
Federal law passed in 1980 and modified in 1986 by
the Superfund AmeDdmeDts and ReauthorizatioD
A&:L The Acts aeated a special tax that goes into
a Trust Fund, commonly bawD IS Superfund, to
investigate and clean up abandoned or uncontroDed
hazardous waste Sites. Uader the program.. EPA
caD either. 1) Pay for Site clc.aDup when parties
responsible for the contAminAtion cannot be located
or arc unwilling or unable to perform the work. or
2) Take legal actioD to force parties rcsponsible for
Site contaminatioD to dean up the Site or pay back
the: Federal govunment for the cost of the cleanup.
£mucot. Treated or untreated wastcwat~r which
Oows from a treatment plant. sewer, or iDdustriaJ
outfall. GeDeraDy rcCers to wastes d.iscJwgcd into
surface water.
FeasibUit)' Study (FS)
IDYeStigatioDfFeasibility Study.
See:
Remedial
GrouDdwater - Water found beoeath the earth's
surface that fiIk pores bctweco materials such as
sand, soil, or gra\'d. ID aquifcn, groundwater
occurs in sufficient quantities which can be used for
cIriokiog water, irrigatioD and other purpose:$.
Grouodwater MODltoriq Wells - See: groundwater
aDd monitoring wells. .
Hazard loda (HI) . A term used iD the Basclioc
Risk AsCl".umeot which estimates the esposurc
effects to DODcarciDogeDic CODtamilu,ntc at a
haz.atdous waste Site. A HI less than 1.0 indicales
that a sipificant hazard is 1ULIikcJy, a ID gre.ater
than 1.0 iDdicatcs that there may be a poteotial
hazard at the Site. .
Hazard ItaDldq System (HIS) - A scoring system
used by EP A and the state to evaluate relative rUb
to public health aDd the environment from rclcua
or thrc.a1eDed releases of hazardous substaoccs. AD
HRS score is caku1ated based CD actual or potCDbaJ
rclcasc: of hazardous svhctmcn through the air,
soils, surface water or groundwater. This score is a
primary (actor used to decide it . hazardous waste
Site should be placed OD the NatiooaJ Priorities List.
lDorpDlc - Compounds that do Dot contain the
elemtDt carboD..
IDformaUOD Reposltof7. A file contai.n.iog c:urrcot
information., teanicaJ reports, aDd referc:occ
documc:ots regardiog a SupcrfuDd Site. Tbc:
informatioD repository is usuaDy located in a public
buildiog that is coDvcDieDt for Ioc:aI residents such
as a publie schoo~ city baD or library.
Laud DIsposal RcstrictiOGS (LORI). Prohibits the
land disposal of hazardous wastes ioto or OD the
land unless EP A finds that it will Dot cDdanger
buman bc:a1th aDd the enwonmeDL EP A bas
d~pcd levels and methods of treatment that
substaD1iaDy diminich the toDc:ity of the waste or
the likelihood that haDrdous constituents wiD
migrate from the waste that must be met before the
wastc is land disposed.
MaxImum CODtamlnant Level (MCL) . The
maximum permissible Jeo.td 01 . coDtAminAnt in
water that is consumed as driDking water. Tbcsc:
levels are determined by EP A aDd arc applicable to
all public water supplies. .
MooJtoriq WeDs. Spc:ciaJ weDs drilled at specific
locations OD or off a hazardous waste Site where
groundwater caD be sampled at selected depths aDd
studied to determine such things as the directiOD or
groundwater flow and the: types and amounts of
conf:lminAnts prCSCDL
MODoUth. Term frcqueotly used with Solidification.
Solidified waste. once mizcd with PortJaod cement,
wiD be used as backfiD for on-site excavatioo,
22
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resulUDg iD . solid. massM aDd uniform concrete
matrix reCcned to as . monolith. "
NatJoaal au aDd Hazardous SubstaDca
ContJD&eacy PI&D eNCl'). The Federal regulatioD
that guides the Superfuad program.
NatJoo.a1 PrioritJes Ust (NPL) . EP A's list of the
most serious uncol1t1oUcd or abandODed hazardous
waste Sites ideDtified Cor possible 10Dg-tUID
remedial respoa.sc usiDg money &om the Trust
Fund. The list is based primarily on the score .
Site receives OD the Hazard Ranking System.
OpuatJOD aad MalDtcuDce (0 & M). Ac:tMbcs
conducted at a Site after a rcspoase action oc.cun.,
to easurc that the cleanup or contaimnent system is
functioning properly.
Orgaalc . Compounds c:pntaUUng the clement
carbon.
Parts Per SilUOD (Ppb)fParts Per MillioD (ppm).
Units commonly used to express low conceDtraboas
of contamiDaDrs. For example, one gallOD of a
solvent iD one billion pDons oC water is equal to .
ODC part per billion.
Plume - A three dimCDSiooaJ zone within the
groundwater that contaias cont:amiuntc aDd
geDcrally moves in the direaiOD or, aDd with,
groundwater flow.
Potentially Rapoaslble Parties (PRPs) . AJ1y
indMdua1(s) or compaay(s) (such as ownCl'S,
operators., transporters or geDeralon) po«cmiaDy
rcspoasible for, or contributing to, the
contamination problems II a Superfund Site.
Whenever possible. EP A requires PRPs, through
adminiu.ratiYe and IcpJ actioas, to dca.a up
hazardous waste Sites they ba~ conWDinatcd.
PubUcIy Owned Tratmeat Works (P01W) . A
wastewater trea1lDCDI Cacility which is owned by .
state. municipalily, or iDtcrmunicipaJ or intcnute
agency.
Pump and Treat System. AJ1 active groundwater
treatmenl system which extracts conbmin:ated
groundwaler from the subsurface by a network of
CXlrac1ion wells aDd relDOYCS the coatamioaDts from
the lfOundwater by various prCWCD tccboolosicL
R.euoDable Maximum Exposure (1lME). A term
used in the BascliDe Risk As~uneaL The RME
is the highest czposure to COIIt.min~nU that is
rC&SOGlbly czpcctcd to occur II a Site and is based
OD the proCessional judgemcnt of the fisk.uuc$Of.
Record 01 Deds10D (ROD) . A public document
that ezplains wbicb deuup allera.atiYes(s) wiD be
used II National Priorities List Sitca where the
Trust f'uDd pays for the deanup. The ROD is
based on informatiOn aDd IcchDic:aJ anaJyses
geDeraled. duriDg tbe remedial
in~OD/feasaDiJity study aDd consideratioa 01
publk comments and community CODCCrDS.
RemedIal AdJOD (RA) . The actual CODStruc:OOa or
implementation phase that foDows thc. remedial
dcs.igD ot the selected clcaaup aJrernatiYe at a Sitc
on the National Priorities List.
Remedial Deslp (RD). An engineering phase that
CoDows the Record 01 Decision when tcdmical
drawings and specifica1ioas are ~pcd Cor the
subsequeDt remedial action at a Site on the National
Priorities List.
Remed1alID~tlptiOD/FeaslbWt1 Study (RIfFS).
Two distinct but related studiC&. They are usaaDy
performed at thc samc time, aDd logdher referred
to as the "RI/FS.. They are inteDded to pther the
data ~.N'C.Clry 10 determinc thc type and alcDI of
c:ont~min.tion II . Superfund Site; establish ailcria
Cor dcaaiog up the Site; idcnUfy and screen c1canup
aJl~ for remedial adiou; and analyze ill
detail the tcdmology and costs of thc aJ.tcrnatnu.
Resource. CoasenatJOD, aDd Reco~ Ad (RCRA)
. A Federal law dw established a regulatory system
10 track hazardous substances &om the time of
gencratioD to disposa1. The law requires safe and
secure procedures to be used ill trcatiag.
transportiDg. storiag and disposmg of hazardous
substances. RCRA is designed to pr~nt DeW
uncol1t1oDed hazardous waste Sites.
RespoasIYeDess SamllW1 . A summary of oral
and/or written publk comments rcc:eived by EPA
during a commcDI period OD key EP A documCDU
and EPA's responses to those comments. The
23
.
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responsiveDCSS summary is espec:iaJly valuable
duriD.g the Record o( DecisiOD phase at a Sire on
the Natiooal Priorities List wheD it hisJ'ligJIts
commuoiry CODccms (or EPA decisioD-makers.
Sale DrioJdn& Water Act (SDWA) - Federal law
passed.in 1974 to ensure warer supply systems
scniog the public would meet minimum staDdards
for the protection of public health. The law was
designed to achicyc UDitorm safety aDd qualiry of
driokiog water in the United States by ideotif'yias
coDumin~ts~d~b~m~uma~~
level&.
Site InspectiOD (SI) - A techD.icaJ phase that follows
a preliminary ~cment designed to coDect more
extensive informatioD on a hazardous waste Site.
The information is used to score the Sire with the
Hazard RaokiDg System to derermioe whether
response actioD is Deeded.
Siudae: AAy heavy, slimy deposit. sediment or
mass, as the waste resuJtiog from the preapitare of
a remedial process such as acid Deutralization, oil
rcfioiog. or mud brought up from a driDiog
operation.
Superfund - The common name used for the
ComprchcDsivc EnviroDmcntal Responsc,
Compensation, and Liabiliry ad. also referred to as
the Trust Fund.
Total SuspeDded SoUds (TSS) - The DODr.Jtcrable
residue that is retained on a glass-fiber disk after
filtration of a sample of water or groundwater.
TozidtyCbanderistic 1 ,"(folnl Procedure (TCLP)
. A testing procedurc used to detcrmioe whether a
wastc is baDrdous ud/or requires treatmCDL
TCLP tcst is also used as a monitoring tedmique to
determinc wbdber a treated wastc meets the
applicable waste cxuac:t treatment staDdard.
..
24
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MAILING UST ADDmONS
To be placed OD the mailiag list to receM wormaLiOD OD the
Golden Strip SepLic Tank Superfund Site
please complete this (orm ud mail to:
Cynthia PeuriCoy
Community ReJaLioas Coordinator
WasleDMsioa
North SuperfuDd Bruch
U.s. EP A . RegiOD IV
345 CourtJaad Street, N.E.
Atlanta, Georgia 3036S
Name:
Address:
AfiiliaLiOD:
TelephoDc:
.
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. -
-; - .-.-..-.
0- .
--'-"'-.--
- -
United States
Environmental Protection Agency
R.egion 4
North Superfund R.emedial Branch
345 Courtland S tree t, N. E. .
Atlanta, GA 30365
Official Business
Penalty for Private Use
$300
.
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Attachment B
GOLDEN STRIP SEPTIC TANK SITE
PUBLIC MEETING
SIGN IN SHEETS
.
-------
~
~-, J.I]J~
i C. ~L-E. C A-'" r p, E' u <.. ~ II'-
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1"\r. <4- 1'\... ~.,.....c:.c" ~c.'c.'t" /It... Bv-:""YWJood DY".
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c!..;~ ~iS :Lt ~o B~ sf ~( ,2.C(2.D)
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UUA..J-X~ - d~q h~s j.,{;11 KJ
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Attachment C
GOLDEN STRIP SEPTIC TANK SITE
INFORMATION REPOSITORY LOCATIONS
.
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GOLDEN STRIP SEPTIC TANK SITE
. INFORMATION REPOSITORY LOCATIONS
Greenville Public Library
South Carolina Room
300 College Street
Greenvi1le, SC 29601
(803) 242-5000
Simpsonville Branch Library
102 Academy Street
Simpsonville, SC 29618
(803) 963-9031
EPA Record Center
345 Courtland Street, N.E.
Atlanta, GA 30365
(404) 347-0506
.
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Attachment D
GOLDEN STRIP SEPTIC TANK SITE
PUBLIC NOTICES
.
-------
Tribune-TImes' Wedne5day. June 12. I990P ~
The United Stales Environmental Protection Agency ,
invites public comments on the proposed plan
and the administrative record for the
Golden Strip Septic Tank Site
Greenville County, South Carolina
',:1
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United States Environmental Protection Agency ;:,~
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Public Information Meeting :-':
Thursday, June 20,1991.7:00 p.m. ',~
Simpsonville Community Building : :;\
CJty Park. East Curtis Street :.~I
Simpsonville. South Carolloa . ;~~I
The C.5. Environmental Protection Agency (EPA) will hold a Public Information Meeting :0 ""1
present and receive comments on the Proposed Plan for the cleanup of the Golden Strip ~ ~I
Septic Tank Superfund Site in Greenville County, South Carolina. The other alternatives evai-' ~'.~
uated In the Feasibillty Study conlluc:ed for [he Site will also be discussed. The public is ." ::
encouraged to attend the meeting, ask questions and offer comments. : .::i
The Golden Strip Septic Tank Site (GSST) is located on a 5:Hicre parcel of land approx- ~ ':1
Imatcly three miles north 01 Simpsonville. South Carolina. The Site consists of five inactive: ::
waste lagoons and the area surrounding these lagoons. GSST was an industrial and septic ". "
waste hauling and disposal service that began accepting waste in 1960. and ceased opera- :::.~~
tlons in 1975. In January 1987. alter Investigations by the South Carolina Department of Health; ::-.~
and Environmental Control and the EPA. the Site was placed on the National Priorities Ust. In ",:' .
July 1988. an Administrative Order by Consent was entered into by EPAand the potentially :~:~
responsible parties (The Golden Strip Task Group). Under this Consent Order. a Remedial :', .~
Investigation/Feasibility Study (RI/FS) began in October 1989 and was completed In February: '.;'
1991.
A Supplemental Rl was conducted during February and March o( 1991. to (urther Inves- - "
ugate groundwater flow characteristics and quality In the down gradient. northern portion o( ::
the Site. Five additional groundwater monitoring wells were inStalled down gradient of the ~
existing network of monitoring wells and samples were collected and analyzed (rom the new ~
and existing wells. Based upon the RI, the Supplemental RI and the Baseline RIsk Assessment ~
conducted for the Site. EPA believes that active remediation of groundwater (such as a pump ~
and treat system) In the vicinity 01 the lagoons Is not reasonable or technically practicable. ~
Based on the findings o( the RI, the supplemental RI. and the Baseline Risk Assessment. ~
EPA reviewed eight alternatives (or addressing surface soil and lagoon sludge contamination:
at the Site. EPA"s preferred alternative (or cleanup o( the contaminated surface soil and lagoon:
sludge at the Site Involves: ~
Phv~lc~1 Stablliz:lt\on Solidill('~tlon/Fix:ltlon: This alternative would Include' excavation ::
of allected materials, stockpiling. prior to processing. solidUlcation o( allected materials using ~:
portland cement and backfilling 01 solidified materials in on-site excavations. Physical stablf~ ::
zation Is a remediation technology frequently used (or allected soil and sludge. This treat- :.
ment would tend to reduce the mobility o( waste constltuent.s by binding the 5011 or sludge .;
Into a stable. often solid. m:ltrix that would resist leaching. The ellectiveness of solidification - ~
has been demonstrated at many Superfund sites (or a wide variety o( inorganic analytes. .- :'
The estimated present worth cost (or the preferred alternative is 54.5 mlilion doliars.
EPA is conducting a 3
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2 . Golden Stno ri1T\e5 . lu~ t 2. 991
I
The United State. Environmental Prutect10n Agency I,
Invites publ1c comments OD the proposed plan . .
and the adm1oJ.strat.lve record for the '. 'I'
Golden Strip Septic Tank Site
GreeoviUe County, South Carolloa '..1
United States Environmental Protection Agency .:.~ I
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I
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PubUc Information Meeting
Thursday, June 20, 1991,7:00 p.m.
Simpsonville Community Building
City Park. East Curtis Street
Slmpsonvllle. South Carol1Da
The l:.5. Environmental Protection Agency fEPA) will hold a Public Information Meeting :0
present and receive comments on the Proposed Plan for the cleanup of the Golden Strip .
Septic Tank Superfund Site in Greenville County. South Carolina. The other alternatives eval- - i
uated In the Feasibility Stuc1y conduc:tec1 lor the .site will also be discussed. The public is I
encouraged to attend the meeting. ask questlor.s and oifer comments. !
The Golden Strip Septic Tank Site (GSST) is iocated on a 55-acre parcel 01 land approx. "1'
imately three miles north 01 Simpsonvllie. SoutO Carolina. The Site consists 01 live inactlve .. I
waste lagoons and the area surrounding these lagoons. GSST was an industrial and septic " I
waste hauling and disposal service that began accepting waste In 1960. and ceased opera- - ,
tlons in 1975. In January 1987, after investigations by the South Carollna'Department 01 Health. ..
and Environmental Control and the EPA. the Site was placed on the National Priorities List. In
July 1988. an Administrative Order by Consent was entered into by EPA and the potentially
responsible parties (The Golden Strip Task Group). Under this Consent Order. a Remedial .
Investigation/Feasibility Study (Rl/FS) began in October 1989 and was completed In February ..-
I~I. .-
A Supplemental RI was conducted during :=ebruary and March of 1991. to lurther inves-
tigate groundwater flow characteristics and quaiity in the down gradient. northern portion of .,.,
the Site. Five additional groundwater monitoring wells were installed down gradient of the
existing network of mcnitoring wells and sampies were collected and a~alyzed from the new
and existing wells. Based upon the RJ. the Suppiemental RJ and the Baseline RIsk Assessment ...
conducted for the Site. EPA believes that active remediation 01 groundwater (such as a pump
and treat system) In the vicinity of the lagoons is not reasonable or technically practicable.
Based on the findings of the RI. the supplemental RI, and the Baseline Risk Assessment.
EPA reviewed eight alternatives for addressing surface 5011 and lagoon sludge contamination 'Ow
at the Site. EPA's preferred alternative for cleanup of the contaminated surface soil and lagoon '"
sludge at the Site Involves: . ..
Phvslr~1 Stabilization - C;olic1lfiral ion/Fi-i,alion: This alternative would include excavation
01 affected materials. stockpiling prior to processing. solidification 01 affected materials using -.
portland cement and backfilling 01 solidilied materials in on-slte excavations. Physical stab ill- .::
zatlon Is a remediation technology Irequently used for affected soli and sludge. This treat.
ment would tend to reduce the mobility of waste constituents by binding the soli or sludge
Into a stable. olten solid. matrix that would resist leaching. The effectiveness of solidification ....
has been demonstrated at many Superfund sites for a wide variety 01 Inorganic analytes. .""
The estimated present worth cost for the prelerred alternative Is S4.S million dollars.
EPA Is conducting a 3O-day public comment period.lrom JIIOP 17 199\ 10 Julv III 1991 to
provide an opportunity (or public involvement in the final cleanup decision for the Site. EPA
may extend this comment period upon receipt 01 a timely request. During this time, the public:
Is Invited to review and comment on the Administrative Record, Including the Proposed Plan, .,
the RI and the FS. Selection of the final ~medy will be made after consideration of all public
comments, and comments will be addressed in the Responsiveness Summary Section of the
Record 01 DecisIon lor the Site.
The Administrative Record, Including copies 01 the Proposed Plan Fact Sheet and the
R1/f'S documents. are available for public review at the following Information repositories lor ''''
the site:
Greenville Public Ubrary
South Carolina Room
300 College Street
Greenville, SC 29601
(803) 242-5000 (803) 963-9031
II after reviewing the Inlormation on the Site. you would like to comment in writing on . ,
EPA's prelerred alternative. any of the other cleanup alternatives under consideration. or oth. -
er Issues relevant to the Site cleanup. please submit your comments to EPA at the public
meeting on June 20. or by mail (to hI' nmtmarkl!!d no lat!'r than Julv III 1991) to:
Simpsonville Branch Library
102 Academy Street
Simpsonville. SC 29681
Craig R. Zeller. Remedial Project Manager
North Superlund Remedial Branch
U.S. Environmental Protection Agency
Region IV
345 Courtland Street, N.£..
Atlanta. GA 30365
..
..
..
"
"
..
"
..
'"
'"
..
..
. For further Information In regard to the public meeting, the proposed plan or community
Involvement at the GSST Site. please contact Craig R. Zeller, Remedial Project Manager. or
Cynthia Peurlloy, Community Relations Coordinator. at the address above or by phone at
(404)347-7791.
.,
: ~
..
"
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48 . \!he ~'t'ttt\L!illt Nnvs
Sunday, June 15. 1991
~ 17.,..
. ft..
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THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
INVITES PUBLIC COMMENTS ON THE PROPOSED PLAN
AND THE ADMINISTRATIVE RcCORD FOR THE
GOLDEN STRIP SEPTtC TANK SITE
: GREENVILLE COUNTY, SOUTH CAROLINA
PUBLIC INFORMATtON MEETING
Thursday, June 20,1991,7:00 p,m.
SIMPSONVILLE COMMUNITY BUILDING
City Park. East Curtis Street
Simpsonvllle, South Carolina
The U.S. E:wironmemal Prot~ion Agency (E?A) will r.oica Public Intcrmation Meeting :0 prese:.! ane
receive comments on the Proposed Plan for the cleanup of the Golcen Strip Seotic Tank Suceriu..c Site
in Gr~nville County, Sout~ Caroiina. The other aiternanves evaluated in :he F=sasibiiity StUdy c::::ncuc!=~
for the Site will also be discussed. ihe public is encourag~ to artenc the meeting, ask questions ane
oHer comments.
The Golden Strip Septic Tank Site (GSST) is 10cate
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IrtOune-nmes.weonesday.june 19.1991'91\,
The United States Environmental Protection Agency
Invites public commenls on the proposed plan .
and the administrative record for the
Golden Strip Septic Tank Site
Greenvllle County, South Carolina
.'
:.
"
United States Environmental Protection Agency .'.(~
'..
Public Information Meeting
Thursday, June 20, 1991,7:00 p.m,
Simpsonville Community Building
City Park, East Curtis Street
Simpsonvllle, South Carolina
.'.
'..
".
:")
'..
The U.S. Environmental Protection Agency (EPA) will hold a Public Information Meeting to .;
present and receive comments on the Proposed Plan lor the cleanup 01 the Golden Strip ,;;
Septic Tank superlund site,ln Greenville County, South Carolina. The other alternatives eval- .:"
ualed In the Feasibility Study conducted lor the Site will also be discussed. The public Is
encouraged to attend the meeting, ask questions and oller comments. ; ,
The Golden Strip Septic Tank Site (GSS1) Is located on a 5S-acre parcel of land approx- "
imalely three miles north olsimpsonville, South Carolina. The Site consists 01 five inactive ..~.
waste lagoons and the area surrounding these lagoons. GSST was an Industrial and septic ;:
waste hauling and diSposal service that began accepting waste In 1960, and ceased opera- .:
tlonsln 1975. In January 1987, alter Investigations by the South Carolina Department 01 Health ,;
and Environmental Control and Ihe EPA. the Site was placed on the National Priorities Ust.ln ,,;
July 1988, an Administrative Order by Consent was entered Into by EPA and the potentially I..j
responsible parties (The Golden Strip Task Group). Under this Consent Order, a Remedial "J
Investigation/Feasibility Study (RI/Fs) began In October 1989 and was completed In February '-.
1991. . ,
A Supplemental RI was conducted during February and March of 1991. to further inves- .'
tigate groundwater lIow characteristics and quality In the down gradient, northern portion of ..,
the Site. Five additional groundwater monitoring wells were Installed down gradient 01 the ::'
existing network 01 m:mltorlng wells and samples were collected and analyzed from the new
and existing wells. Based upon the RI, the Supplemental RI and the Baseline Risk Assessment
conducted lor the Site, EPA believes that active remediation of groundwater (such as a pump
and treat system) In the ~clnity of the lagoons Is not reasonable or technically practicable. ,..
Based on the IIndlngs 01 the RI, the supplementttl RI, and the Baseline Risk Assessment, 'u
EPA reviewed eight alternatives for addressing surface soli and lagoon sludge cor.tamlnatlon
at the Site. EPA's preferred alternative lor cleanup 01 the contaminated surface soil and lagoon.,,,.
sludge at the Site Involves: '~
Phv.lral Stabilization Solidlllratlon/Flxatlon' This alternative would Include excavation -
01 allected materials. stockpiling prior to processing, solidification of affected materials using
portland cement and backfilling olsolldilled materials In on-site excavations. Physical stabUI- ,
zation Is a remediation technology Irequently used for allected soil and sludge. This treat- ' .;'
ment would tend to reduce the mobility of waste constituents by binding the soil or sludge" .
into a stable. often solid, matrix that would resist leaching. The ellectiveness of solidification,' .
has been demonstrated at many Superfund sites lor a wide variety of Inorganic analytes. "'~
The estimated present worth cost lor the preferred alternative is S4.5 million dollars.
EPA Is conducting a 3!k1ay public comment perlod,from June 17 1991 to Julv 18 1991, to ,.'
provide an opportunity for public Involvement In the IInal cleanup decision for the Site. EPA .;;
may extend this comment period upon receipt 01 a timely request. During this time, the public -
is Invited to review and comment on the Administrative Record, Including the Proposed Plan, ~ ,
the R1 and the FS. Selection olthe IInal remedy will be made alter consideration 01 all public j.!
comments. and comments will be addressed In the Responsiveness Summary Section of the,
Record of Decision for the Site. .
The Administrative Record. Including copies of the Proposed Plan Fact Sheet and the. '\
Rl/FS documents. are available lor public review at the following Information repositories lor'.: I
the site: " :.;
Greenville Public Ubrary
South Carolina Room
300 College Street
Greenville. SC 29601
(803) 242-5000 (803) 963-9031
II alter reviewing the Inlormation on the Site. you would like to comment In writing on
EPA's preferred alternative, any of the other cleanup alternatives under consideration, or Otl1-
er Issues relevant to the Site cleanup, please submit your commenls to EPA at the public 1
meeting on June '20. or by mall (to hI' nostmarkl'd no later than Julv 18 1991) to: I
I
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,
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simpsonville Branch Ubrary
102 Academy Street
simpsonville. SC 29681
\
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Craig R. Zeller. Remedial Project Manager
North Superfund Remedial Branch
U.S. Environmental Protection Agency
Region IV
345 Courtland Street. N.£.
Atlanta, GA 30365
For further Information In regard to the public meeting, the proposed plan or community
Involvement at the GSST Site. please contact Craig R Zeller. Remedial Project Manager, or
Cynthia Peurlloy, Community Relations Coordinator, at the address above or by phone at
(404) 347.7791.
.
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GoldenStT1pilmes'june 19.1991 '.7..
The United States Environmental Protection Agency
invites pubUc commenta on the proposed plan
and the admlnlatratIve record for the
Golden Ship SeptIc: Tank Site
GreenvlUe County, South Carol1na
:t
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United States Environmental Protection Agency:'''
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The u.s. Environmental Protection Agency (EPA) will hold a Public Inlormatlon Meeting to ~ : :
present and receive comments on the Proposed Plan lor the cleanup 01 the Golden Strip ; : :
Septic 'nuIk Superlund Site In Greenville County, South CarollnL The other _alternatives eval- ~: :
uated In the Feasibility Study conducted lor the Site will also be discussed. The public Is '
encouraged to attend the meeting, ask questions and oUer comments. . ,; ;
The Golden Strip Septic Tank Site (GSS1) Is located on a 5>acre parcel 01 land approx-
Imately three miles north 01 Slmpsonville, South Carolina. The Site consl4ts 01 live Inactive
waste lagoons and the area surrounding these lagoons. GSST was an Industrial and septic
waste hauling and disposal service that began accepting waste In 1960, and ceased opera-
tions In 1975. In January 1987. after Investigations by the South Carolina Department 01 Health
and Environmental Control and the EPA. the Site was placed on the National Priorities Ust. In
July 1988, an Administrative Order by Consent was entered Into by EPA and the potentially
responsible parties (The Golden Strip Task Group). Under this Consent Order, a Remedial
Investigation/Feasibility Study (RJIFS) began In October 1989 and was completed In February
1991.
A Supplemental RI was conducted during February and March 01 1991, to lurther Inves-
tigate groundwater now characteristics and quality In the down gradient, northern portion 01 .
the Site. Five additional groundwater monitoring wells were Installed down gradient 01 the :
existing network 01 monitoring wells and samples were collected and analyzed Irom the new :
and existing wells. Based upon the RI, the Supplemental RI and the Baseline Risk Assessment ..; :
conducted lor the Site, EPA believes that active remediation 01 groundwater (such as a pump '-- I
and treat system) In the vicinity 01 the lagoons Is not reasonable or technically practicable.
Based on the findings 01 the RI, the supplemental Rf. and the Baseline RIsk Assessment. "
EPA reviewed eight alternatives lor addressing surlace Soli and lagoon sludge contamination J
at the Site. EPA's prelerred alternative lor cleanup 01 the contaminated surlace soil and lagoon,
sludge at the Site Involves:' "JII
h
Phvslc-al SlabUization Solidification/FIxation; This alternative would Include excavation ;)"
01 alleeted materials, stockpiling prior to processing, solidification 01 allected materials using ,..,
portland cement and backfilling 01 solldilled materials In on-slte excavaUons. PhysIcal stablU. .",-
zatlon Is a remediation technology lrequently used lor aClected soU and "udge. Thl. treat- ..,!I'
men 1 would tend to reduce the mobility 01 waste constituents by binding the soli or sludge _.
Into a stable, ollen solid, matrix that would resist leaching. The ellectlveness 01 solidification
has been demonstrated at ml1llY Superfund sites lor a wide variety 01 Inorganic analytes.
The estimated present worth cost lor the prelerred alternative Is S4.5 million doUars. -
EPA I. conducting a JO.
-------
Attachment E
GOLDEN STRIP SEPTIC TANK SITE
OFFICIAL PUBLIC MEETING
TRANSCRIPT
-------
CCO(p1f
VERBATIM TRANSCRIPT
OF
GOLDEN STRIP SEPTIC TANK SITE
SUPERFUND SITE
GREENVILLE COUNTY, SOUTH CAROLINA
PROPOSED PLAN PUBLIC MEETING
THURSDAY, JUNE 20, 1991
7:00 P.M. TO 9:15 P.M.
Deborah Garrison
Courl Reporler
245-D Easl Broad Sireet
Green\lillf'. S.C. 29601
(803) 244-0973
.
-------
VERBATIM TRANSCRIPT
OF
GOLDEN STRIP SE~TIC TANK SITE
SUPERFUND SITE
GREENVILLE COUNTY, SOUTH CAROLINA
PROPOSED PLAN PUBLIC MEETING
THURSDAY, JUNE 20, 1991
7:00 P.M. TO 9:15 P.M.
.
-------
I:
!
. .
2
ENVIRONMENTAL PROTECTION AGENCY
OFFICIALS IN ATTENDANCE
Craig Zeller, Remedial Project Manager
Kevin Koporec, Toxicologist
Teresa Atkins, Office of Regional Counsel
Jan Rogers, Chief of the South Carolina Remedial Section
Cynthia Peurifoy, Community Relations Coordinator
ALSO ATTENDING:
Bill stephens, Project Manager of RMT
REPORTED BY:
B. Dale Campbell, Associate Reporter
.
-------
12
13
20
21
22
23
24
25
,
2
INDEX
3
. . . .
4
3
4
Opening Address by Mr. Zeller. . .
. . . . .
. . . .
7
Community Relations Program by Ms. Peurifoy.
5
6
By Mr. Zeller:
. . 10
. . 42
Proposed Selected Remedy, Alternative 7-C. . . . . . 57
.
. . 70
. .110
Program Past and Present. . .
. . . .
. . . . .
7
Feasibility study Alternatives 1 to 8.
. . . . .
8
9
Public Comment Period. . . .
. . .
.......
10
Certificate of Notary Public
. . . . .
. . . . .
~ .
14
15
16
17
18
19
-------
10
13
14
4
1
BY MR. ZELLER:
2
3
Hello.
I guess it's a little after seven o'clock
I'm going to give this thing a shot here and
here.
4
try not to keep you guys as little -- take up as
5
6
little time as I can here.
First of all, can you
all hear me very well?
We've got this public ad-
7
dress system here that's got a lot of feedback, so
I'll just try to speak loudly and I've never a prob-
8
9
lem with my voice carrying.
In fact, people try to
tell me to shush a little bit, because I hurt their
1 1
12
e~~~, but -- [p~us~).
My name is Craig Zeller.
I'm the EPA Remedial pro--
ject Manager out of Atlanta, Georgia.
And it's my
job -- I guess my responsibilities here tonight are
15
basically to inform interested citizens and the
16
public and try and summarize everything that's on
17
that table over there in about forty-five minutes.
18
19
I'll do my best job, that I can.
With me tonight I
also have Cynthia Peurifoy, who is the EPA Community
20
Relations Coordinator; Kevin Koporec, who is a toxi-
21
.
cologist, basically his responsibilities on this
site thus far have been to address the health is-
22
23
. sues, risk issues, that type of thing; and Teresa
24
25
Atkins is with the Office of Regional Counsel in
EPA, basically she's the attorney on the site deal-
.
-------
5
1
2
ing with" legal issues; and Jan Rogers is the Chief
of the South Carolina Remedial Section, and is my
3
supervisor.
Also, we have some representatives from
4
5
RMT, Bill Stephens, who has been the Project Manager
on this site.
And later, after we're all done here,
6
if there's any questions you would like to ask Bill,
7
he'll be glad to answer them.
8
9
And just moving on here, I wanted to briefly -- I'm
going to show you what we have for an agenda.
10
Again, like I say, my name is Craig Zeller.
Please
1 j
Ieel free to interrupt me at ~ny time;) if you &la.."e
any questions, if I'm not being -- I'm being a lit-"
12
13
tle too vague for you'all. "I would like to touch
14
real briefly here tonight, first of all, on the
15
Community Relations Program that we have .estab-
16
lished.
We do our best to try and keep the communi-
17
ty informed throughout the Remedial process, all the
18
way from RIFS stage all the way up to completion and
19
20
deletion from the National Priorities List.
Cynthia
Peurifoy will touch on that here briefly.
From
21
22
.
there out, go into a little background, a little
Remedial Investigation summary to try to bring you
. up to date on what has happened up to this time.
23
24
From there we'll go into the Feasibility Study re-
25
sults, which is, essentially, a nice report that was
.
-------
10
°11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
6
1
put together summarizing eight alternatives that we
have looked at and evaluated in an effort to try and
2
3
address the contamination that has been identified
4
at the Golden Strip Septic Tank Site.
From there,
5
6
we will identify the Preferred Alternative that was
also delineated in the Fact Sheet that I hope most
7
of you have received about a week ago.
And after
8
9
that, we'll go into where do we go from here looking
forward in the next week, the next three months, the
next three years a little bit.
Give you a little
foresight of whac's g9ing on there.
And tnen after
that, I'll try to expedite that as much as possible,
just try to hit the highlights.
I won't go into too
much detail and we'll answer -- address any further
questions you all might have, in the question and
answer period.
And I'm sure you 'all have plenty of
questions, and I encourage that.
I'm glad to see a good size crowd here.
It's always
nice and very encouraging to see interested citizens
in the environment.
That is what we do best.
And
with that, I'll turn it over to Cynthia very quickly
here and she'll touch on the Community Relations
. issues.
BY MS. PEURIFOY:
Thank you.
I would like to also
Good evening.
.
-------
7
1
2
welcome you to our public meeting and thank you for
coming out tonight.
I wanted to tell you a little
3
about our Community Relations Program.
As Craig
4
said, our purpose is to try to get information out
5
6
to the communities affected by Superfund sites.
We
do a lot of things to try to do that.
We do things
7
such as this, the Public Meeting, Fact Sheets, we
8
9
establish Information Repositories, and we have
different Work Shops.
Recently, we established some
10
special information repositories for you at two of
1 1
your local libraries.
There are twu binde~s in each
12
13
library, at the Simpsonville Branch Library and the
Greenville Public Library in the South Carolina
14
Room, that contain all the Fact Sheets on this site.
15
16
There are several Fact Sheets on the Superfund pro-
cess.
There's a multitude of information and there
17
are multiple copies of those Fact Sheet~.
So, when
18
you have a little free time, go by the library and
19
take a look at that and you might find some infor-
mation that you'll find very helpful.
20
21
Let's see, I wanted to tell you a little bit about
22
23
Most of you have already seen them,
the handouts.
. so I'm not going to go into that a lot.
But if
24
there's anything that we've given out of, that you
25
want -- I think we're just about out of the NPL
.
-------
8
1
books or are out -- just let me know and I'll get
you additional copies of it.
2
3
Mailing Lists.
Several of you gave me forms for the
4
5
mailing list.
There are some forms over there.
If
you want to be on the mailing list for this site,
6
just fill one out and give it to me.
I'll be glad
7
to add you to the mailing list.
We had a lot of
8
9
returns the last time we sent out Fact Sheets in
March, a lot of them came back,. so we had addresses
10.
that were no longer valid.
So if you've gotten
jj
somethiug before and you didn't get it this time,
12
13
that's why, because things came back.
So just give
us your new address.
14
Again, there are handouts.
There's a package that
15
16
shows you all the overheads that Craig is going to
be using tonight so, hopefully, it'll help you to
17
follow along.
18
19
I also wanted to mention to you that during the
Remedial Action -- Remedial Design/Remedial Action
20
21
stage, we will be revising the Community Relations
Plan for this site and if you'd like to have some
22
23
input in that, just see me after the meeting, or
fill out one of the comment cards, or let me know.
24
25
I wanted to remind you that the Public Comment peri-
cd ends on July 18th.
There is a provision for a
.
-------
16
l'
18
19
20
21
22
23
24
25
5
6
,
8
9
10
"I"j
12
13
14
15
9
1
30-day extension of that.
Craig is going to talk
2
3
about that later.
But there are Some envelopes,
postage paid envelopes, on the table over there.
4
If you have some comments you'd like to have consid-
ered, and you don't give them to us tonight, feel
free to take one of those envelopes and send it back
in to us.
~d, again, thank yo~ for coming.
BY MR. ZELLER:
Okay.
Let's see if we can get to the nuts and bolts
of why we're all here.
The Golden Strip Septic Tank
Slt~, where is it, and wha~ is it?
'this is a map
that you all have probably seen before.
The Golden
Strip Septic Tank Site approximately three miles
north of where we're all standing right now.
It's
off of South Carolina Route 14, right off of Adams
Mill Road.
~t's a 55-acre parcel of land that is
currently owned Ms. Lucille Rice.
I have a map here
that I hope comes out okay.
If not, this, again, as
Cynthia mentioned is in your handout.
Some site features, I guess, to try and bring you up
to date, on what we have.
Again, this is 55 acres
approximately where this solid line off to the right
. here (indicating).
It's bounded on its north, east,
and west side by the Hollow Tree Subdivision, proba-
bly a lot of "you live in that area.
It's bounded on
.
-------
1
I" 2
3
4
S
6
7
8
9
10
"11
12
13
14
1S
16
17
18
19
20
21
22
23
24
2S
10
the south by Adams Mill Road coming in here.
And
Mrs. Rice's residence and her other farm dwellings
are in the southeastern corner, western corner.
Essentially, there is a focus, and particular areas
of interest during the remedial investigation, where
what we are calling the source areas, five lagoons.
Basically, this is Lagoon 1, this is Lagoon 4.
currently remain open and do contain liquid and
They
liquid waste.
Lagoons 2, 3, and S are right here.
I have a better slide I'll show you in a moment.
T~ey were tilleu in 1978.
w~ hav~ -- "another area
of interest was an unnamed stream that basically
starts from the spring-house right about here, and
travels to the north, off the site here on the
north, north boundary, and then connects with Gilder
Creek, which is actually off this map here.
We --
that was a focus of our investigation as well.
There is an abandoned drum area that was identified
at the start of Remedial Investigation on the east
sid~ of the property.
That basically contained 27
abandoned drums that I'll get into later.
That was
investigated rather thoroughly by RMT and I'll get
. into the results of that stuff later.
And, just moving on here, this a better map, I
guess, a little bit more blown up, yet. It kind of
.
-------
11
1
gives you an idea of the major focus of this inves-
2
3
tigation was the five lagoon areas.
These five
lagoons were constructed to hold industrial and
4
5
It received industrial and sep-
septic tank waste.
tic waste from 1960 to 1965.
It was owned and oper-
6
ated, I guess, by a gentleman named Mr. Buck Rice.
7
He called his operation the Golden Strip Septic Tank
8
9
Service.
These five lagoons -- the first two lagoons that
10
were constructed were Lagoons 1 and 2.
And actu-
'1
ally, what happened, we learned from our history
12
search, was the trucks would pull in off Adams Mill
13
Road and actually pump in the waste.
Later Lagoons
14
3, 4, and 5 were also constructed and additionally
15
16
held septic waste as well.
Total capacity for all
five lagoons is reported to be about 2.8 million
17
They never did receive that much waste.
gallons.
18
That's what they were actually reported to hold.
19
20
Some brief history, again, it's located on a 55-acre
parc;:e 1.
This is the five inactive waste lagoons
21
that received waste from '60 to 75.
Initially, two
22
23
unlined lagoons were used for storage of waste and
. three lagoons were later constructed.
In January of
24
25
1975, Mr. Buck Rice and The Golden Strip Septic
Service applied for a permit to the South Carolina
.
-------
12
1
2
Department of Health and Environmental Control.
From here on out I'll refer to them as DHEC.
It's a
3
lot easier, a little shorter that way.
The permit
4
was denied in March of '75 due to instances of poor
5
6
handling, and there was also recommendation by DHEC
at that time that Mr. Buck Rice should look at a
7
treatment system upgrade.
Essentially, at that
8
9
time, the technology was just five lagoons dug in
the ground, unlined virtually, and they are actually
10
That stuff would be just
evaporation lagoons.
1 1
dumped in there, settle out in the bottom, ana some
of it would evaporate, but most of it,. as we found
12
13
in our Remedial Investigation, just kind of sat at
14
15
the bottom there.
In 1978, Lagoons 2, 3, and 5, the ones I showed you
16
previously, under the supervision of South Carolina
17 -
Department of Health and Environmental Control were
18
19
backfilled.
Essentially, what happened there was
there a birmed area, just surrounding soil of the
lagoons, that was just basically pushed on in.
20
21
As a part of that, moving on, DHEC continued to
22
23
monitor the site through '78 up until '81.
In 1981,
they indicated some presence of some heavy metals
24
2S
actually in the surface water from open lagoons,
Lagoons 1 and 4.
From that point on, they recom-
.
-------
13
1
2
mended that the EPA go in and take a further look at
it.
The program at the site at that time, was re-
3
4
ferred to what we call the Pre-Remedial Program.
It
is essentially the phase right before it reaches us.
5
6
They actually went out and conducted a site investi-
gationi we call it an SI.
What they do at that
7
"8
point in time, they'll go out in the field and
they'll take a real brief look "at it, they'll take
9
some samples in an effort to gather further informa-
tion and try to get a better handle on what's going
10
j i
We useu ~hat information to actually run it
on.
12
through a scoring system, called a Hazard Ranking
13
We mention it in the Fact Sheets.
At that
System.
14
point in time, it receives a score.
If it receives
15
16
above a certain score, it is "actually placed on the
National Priorities List.
And the National Priori-
17
ties List, basically, is a list that recommends it
18
At that point in time Craig
to Superfund.
Okay.
19
20
Zeller enters into the picture and now it's my ball
game.
.
21
22
In addition to that, we also take a look at it and
say, 'Okay, does this site pose an immediate endang-
23
24
erment to the residents living in nearby or the
environment?'
We decided at that point in time in
25
looking at it, with us and the South Carolina De-
-------
I - -
14
1
partment of Health and Environmental Control, we
looked at it and said, 'there is no immediate endan-
2
3
germent to the public out there.'
If there was
4
deemed and it was necessary that we should go out
and do something in the short term, it would have
S
6
been referred to the Removal Program and they would
have went in and actually addressed whatever it was
7
8
9
causing the problems.
However, that was not deemed
necessary and it was included on the final National
10
That's when it was entered
Priorities List in 1987.
1 1
into Superfund.
From there, in 1988, the potential responsible par-
12
13
ties who we have referred to as the Golden Strip
14
1S
It's the
Task Group, agreed to conduct the RIFS.
first stage of the Superfund Program; it's the Reme-
16
17
dial Investigation Feasibility Study.
What we do
out there, is we'll go and gather samples from all
18
19
different medias and try and determine the nature
and extent of the contamination present at the site.
20
21
The. field activities began in September of 1989;
they were completed in '91. I should touch on a
22
23
brief point here just for a little clarification.
At this point in time, entering into the RIFS,
24
2S
there's two ways the system can be split:
One is
what we call a Fund Lead RIFS.
That is where we
.
-------
15
1
actually -- we cannot either identify any potential
responsible parties -- and what I mean by a PRP is
2
3
we have actually identified certain companies that
we can say, 'yes, you did contribute to this problem
4
5
6
out here; you did dump this waste here; you trans-
ported this waste here; you're an owner of this
7
site,' that type of thing.
If they refuse to do it,
8
9
they don't want to do it, they don't have any money
10
to do it, we will actually take the lead -- EPA will
take the lead -- and we will take money out of the
.j i
Superfund, which is basically a big trust fund.
It
12
has lots of money in it out there for us to spend to
13
The other way to go, and
clean up the environment.
14
it's the way we prefer to go, is actually approach
the PRP Group -- in this case there's actually seven
15
16
identified parties -- that came forward and said,
17
'EPA, we would like to conduct this.'
They're
18
19
being very responsible and said, 'EPA, we would like
to conduct this Remedial Investigation.'
So we
20
21
enter into what we call an Administrative Order on
Consent, an AOC, which is basically a consent agree-
ment saying, 'we will conduct this investigation.'
22
23
All the monthly reporting requirements are in there,
24
25
all sorts of legal documents that we need to see to.
make our decision on the site.
And that began in
.
-------
! -
16
1
2
September of '89.
From there, The Gold Strip Task Group retained RMT
3
4
as their contractor.
RMT is out of Greenville,
South Carolina, and they conducted all the Remedial
Investigation field activities under the direction
5
6
and oversight of the EPA.
The actual main objec-
,
tives -- there are three main objectives, very gen-
8
9
eral objectives, of the Remedial Investigation:
The
first one being to characterize the site conditions.
10
What's the topography?
Do we have surface streams
11
running through?
What's
Do we have surface water?
12
What's the subsurface look
the ground condition?
13
How far to ground water?
How far to bedrock?
like?
14
15
All of that nice stuff, just very general site con-
dition.
Secondly, we like to go in and determine
16
l'
the nature and extent of contamination.
How far had
How serious is it?
the contamination spread?
Is it
18
We don't know that going in at that
even a problem?
19
20
We have a general idea.
We use a
point in time.
lot.of information that we have previously collected
21
22
and use that to help direct our investigation.
And
then, thirdly, but very important, we go in and we
actually assess the risk to the human health and to
23
24
the environment.
And that's done as part of the
25
Remedial Investigation.
It's actually included in
.
-------
17
1
2
the Remedial Investigation report.
We call that a
Baseline Risk Assessment.
And that's what Kevin
3
4
Koporec has done extensive review on and if there's
any questions -- I'lL touch on that briefly here
very soon and if there's any further questions about
5
6
that, Kevin will be prepared to handle any other
questions you might have.
7
8
9
The Remedial Investigation sampling, basically in-
eluded the collection of 226 samples from all dif-
10
ferent types of media.
We looked at subsurface
,.,'
soils by taking -- drilling borings actually into
12
13
the ground, by digging test pits, trying to char-
acterize whether actual waste has been deposited,
14
how thick is it, how serious of contamination do we
15
16
have.
We took actual surface soils down to the
first probably about six inches or so on the surface
17
soil by taking a grab sample and actually analyzing
18
19
. that.
We looked at some stream sediments from that
unnamed stream that runs through the middle of the
20
21
site to the north.
We looked at the ground water
We characterized that.
present at the site.
We
22
23
also looked at the surface water, not only in the
stream, but also in the open lagoons, number 1 and
24
25
4.
And we also took some samples from the actual --
the waste that's laying in the bottom of the lagoon.
.
-------
18
1
2
You say, 'Okay, Craig, 226 samples?
What did you
find out?'
Well, I'll make an attempt here to try
3
and summarize up what we found.
The surface soils
4
and sludge that are in the immediate vicinity of the
lagoon areas have been affected by past waste dis-
5
6
posal activities out 'there.
Basically, what we're
7
finding, the majority of the contaminants out there
8
9
are what we call heavy metals.
Contaminants such as
lead, chromium, cadmium, that kind of stuff.
10
There's also lower concentrations of some, what we
'j i '
call, vola~ile oryanics, cleaning solvents, that
12
type of thing, and also some semi-volatiles.
13
From that, we try to identify what we call constit-
14
uents of concern.
This is what we found.
A lot of
15
16
these chemicals probably won't mean a lot to you.
In fact, they probably don't mean a lot to me ei-
17
ther.
However, we start off with 150 chemicals that
18
They're called the TAL/TCL list.
It's
we look for.
19
a big long list of chemicals.
And the first round
20
21
of sampling that was done out there, we did a full
screen.
And what we try to do is narrow it down,
22
23
We don't want to
make our job a little bit easier.
be looking for contaminant number A, when contami-
24
25
It's a waste of
nant number A is not even there.
money, and we want to try and shrink that list down.
.
-------
. 12
19
1
2
Well, we've basically shrank that list of 150 con-
taminants of concern or actual total chemicals that
3
4
there are analyses for into a list of 20. Basically,
the metals, again, were of most concern, we found
5
6
levels of metals were the highest concentrations out
there, but we also had significant, I guess, quanti-
7
ty of organics that were also present.
Getting into
8
9
the second bullet here, the surface soils in the
suspected truck turnaround areas and the drainage
10
soil have .been affected by past waste disposal ac-
1 j
tivities.
Okay.
Let me see it I can show you where
that is in relation to the site.
The truck turn-
13
around area -- maybe I can get a better -- this is
14
actually a better slide to show you.
The truck
15
16
turnaround area, essentially, what it amounted to is
as the trucks were done dumping their waste and
17
pumping it into these lagoons, they came around here
and actually turned around in this area and went
18
19
back off Adams Mill Road and went about their busi-
20
Well, what was happening is, as they turned
ness.
21
around there may have been a little slopping, some
22
23
stuff falling off the trucks, and so this area had
been impacted to a limited degree.
We found some --
24
25
from some of our surface samples out there, we found
some affected soils that are going to need to be
.
-------
20
1
addressed as a part of this Remedial Action.
Also, the area we call the drainage swale is in this.
2
3
area right here.
There's a pretty steep little
4
gully and actually, in periods of high rains, will
actually drain into the unnamed stream that runs
5
6
this way.
Effectively, what we have been able to
7
determine was probably happening, in periods of high
8
9
rainfall some of the contaminated soils that are in
10
this area of the lagoons probably ran off as it ran
into that drain, have probably ran off and now have
I 1
been deposited in there.
Again, we took some sur-
12
face samples there and that's -- the surface soils
that are contained in this area will also need to be
13
14
addressed during the scope of this Remedial Action.
The abandoned drum area that I mentioned previously
15
16
has been affected to a limited degree by the past
17
remedial or the past disposal activities out there.
I'll try and show you where that's at again, and
18
19
touch on it a little bit more.
The abandoned drum
20
21
area was up in this area here (indicating) on the
east side, not too far from some properties.
What
22
23
we found out there is, RMT, when they were out there
conducting their Remedial Investigation, stumbled
24
25
upon 27 abandoned drums.
And these abandoned drums
did not necessarily contain any liquid waste or
.
-------
21
~
2
liquid hazardous and solid waste as such; they did
contain a lot of residual rainwater.
From just
3
4
sitting open, they had collected some rainwater.
There was one drum that had spilled over and it
5
6
contained like a hardened resin -- it looked like it
had spilled over -- and almost like a molasses or a
7
syrup-type material.
It had spread out and then all
8
9
of a sudden had solidified and it was just probably
extended out another 12 inches or so.
10
So, what they did, RMT, actually collected these
drums, put them in over-packed -- what they call
1 1
12
over-pack and they actually took them to the actual
interior of the site and they sampled the rainwater;
13
14
they sampled some of the waste they had found there;
15
and they also sampled the surrounding soils.
Well,
16
what we found in the waste were nothing -~ nothing
17
really of significant concern.
Actually, the water
18
1'9
was -- had some trace contaminants, nothing of major
concern.
The waste that we characterized -- that
20
21
And there was
little resin material was fine.
some -- there was actually two composite samples
from the surface that were taken there, 535 and 536.
22
23
535 was taken in just a small little radius where
24
25
the abandoned drum area was found, and it was found
to contain some elevated levels of cadmium and chro-
.
-------
! -
1
2
3
4
S
6
7
8
9
10
1 1
12
13
14
1S
16
17
18
19
20
21
22
23
24
2S
22
mium in the soil.
50, that was kind of discovered
about the time we got that analysis back -- it was
kind of discovered late in the process, and this is
going to have to be further addressed in the Remedi-
al Design Phase, where we go from here.
But, again,
this will have to be addressed as part of this Reme-
dial Action that we have planned here.
This last part of this slide here, the quality of
the surface water contained in Lagoons 1 and 4 was
sampled for that full list to try to determine what
was actually in there.
We did find some levels that
actually exceed what we call Maximum Contaminant
Levels.
Those are federally established levels that
actually are set out there to be deemed to be pro-
tective of human health.
They actually did exceed
those levels for cadmium and chromium.
50, again,
since we foUnd that to be affected.
We feel that
has to be addressed as part of this Remedial Action.
Moving on to some more findings here.
The analysis
-- this is very important.
The analysis of the
water and sediment samples, taken from the unnamed
stream, indicate that the stream has not been af-
. tected by past waste disposal activities.
We actu-
ally sampled the stream and the sediments in six
different locations throughout the site, beginning
.
-------
23
1
2
at the actual spring-house that Mrs. Rice takes her
water out of.
We sampled that to make sure that it
3
4
was protective of her health and it turned out to be
very clean.
And, we sampled at five more locations
5
6
downstream until we got off the site, and that
turned out to be very clean..
The ambient air around the site has not been. affect-
ed. That would kind of lead us to believe -- we
7
8
9
thought that was probably the case, since most of
this contamination is buried beneath the overburden
10
1 '1
and soil is on cop of the wast~, ambient air has not
12
been affected.
13
14
We took a look at ground water, and that was of
particular concern to us, because what we have going
15
16
there, is when you have lagoon -~ when you have
-
waste that's buried in the ground you would expect
17
-- as, you know, over a period of time, since this
18
stuff has been out there for as long as since 1960,
basically 30 years -- you would expect a little
19
20
21
contamination to occur as a result of water coming
down on top of lagoons and actual infiltration as it
passes through the waste, you would expect the water
22
23
to kind of pick up a little bit of this contamina-
24
25
tion and move on with the ground water.
So we
looked at the ground water wells.
In fact, we put
.
-------
24
1
17 ground water monitoring wells in the first round
and we sampled those for two times, two periods.
2
3
Actually, we got two sampling events from that.
We
4
were -- there was some confusion as far as what we
5
6
actually had there in ground water.
We -- there was
some illustrations that we had some exceedances of
7
MCLs, Maximum Contaminant Levels, and -- but we felt
8
9
that we -- there were some intermittent exceedances,
and we really didn't have a full grasp of what was
10
going on there, so we went and we approached RMT and
the Task Group and we said, 'we would like to have
11
12
some more ground water monitoring wells put in and
13
sample that and the existing wells one more time, to
14
get a third round of sampling, and to try and fur-
15
16
ther get a handle on the ground water contamination
we had at the site.'
So we sat down -- I guess, it
17
was at the end of January of this year, and said,
18
19
'that would work.'
They agreed to it, and actually
agreed to put five more wells in down -- further
20
21
down gradient.
decided that.
And that took place in January, we
And this was going to take place in
22
23
what we call the Supplemental Remedial Investiga-
tion.
Okay.
What did that consist of, you ask.
24
25
Okay.
It consisted of five additional ground water
monitoring wells that were constructed further down
.
-------
1
2
3
4
S
6
7
8
9
10
11
12
13
14
1S
16
l'
18
19
20
21
22
23
24
25
2S
gradient of the site.
Prior to the Supplemental
Remedial Investigation, basically, our ground water
monitoring wells -- our furt~est down gradient
well -- again, this is the source area (indicating)
and ground water basically moves on this side of the
stream here (indicating) -- basically moves in this
direction and has been shown to discharge to the
unnamed stream.
On this side, the ground water
would flow this direction (indicating) and also
discharge into the unnamed stream.
So if you were
going to look for contaminants, you woula w~nt to
look in the ground water.
Now, you'd want to look
down gradient as it would be traveling and carrying
it to the unnamed stream.
Well, at that point in time, we had -- the furthest
down gradient well was approximately in this area
(indicating), and we felt maybe we should look fur-
ther down gradient, maybe we should look down here
in the northern most property to ensure that, in
fact, contamination is not moving off the site and
further -- maybe endangering these people out here
(indicating).
. down gradient.
50 we did.
We put five more wells
We sampled the existing wells in the
lagoon area, right in that five lagoon area.
We
sampled those in an effort to get one more sampling
.
-------
1- --
I
I
! .
26
1
2
of that to get three total samplings of that from
ground water.
3
4
And, I guess, probably the most important thing I'd
like to touch on, is that this round of sampling was
5
6
-- the wells were sampled actually using this peri-
staltic pump technique, as opposed to the bailing
7
method.
And you're saying, 'what's that mean?'
8
9
I'll see if I can touch on that a little bit.
Okay.
What we saw out there, was we had some levels of
10
11
metals actually, some lead and chromium. that were
showing up on actually relatively high levels of
12
13
contamination in strange places.
There was --
across the stream, down
here, (indicating> there
14
was a monitoring well, I believe it was monitoring
15
16
well number 12 that was showing high levels of con-
tamination for cadmium, chromiUm, and lead.
And
17
that didn't really make any sense, because we have-
n't -- we haven't seen the ground water actually
18
19
sneaking out of the stream and coming back on the
20
21
other side.
And you all live out there, you've
probably been by the site.
You'll see that the
22
23
terrain actually falls off pretty steep from each
direction, so you wouldn't really -- common sense
24
25
will tell you that's not what's going on.
Well, RMT
made the suggestion that we feel -- and they said
.
-------
27
1
"2
they felt the contamination resulting in those wells
was not actually contamination at all.
In fact,
3
4
what they attributed it to, was high levels of sus-
pended sediments in the ground water sampling.
What
5
6
that means is there's actually little sediment so
they're in the water.
Okay.
And those are actually
7
-- will be transported along with the" ground water.
Well, we suggested to them that if that's your
8
9
claim, then we would like to see you use a less
10
1 1
rigorous sampling approach.
When you use. the bailer
method, which was used in the first two rounds,
12
13
basically you drop a little aluminum bailer, what
it's called, a little aluminum bailer, in the wells
14
and you splash that down in there to the water level
and take out -- purge out all the static water and
15
16
then take your water sample using that.
Well, what
17
that does is stir up all that suspended sediment in
18
19
the water and it can give you actual false posi-
tives.
It can give you actually contaminants that
20
are. actually chemicals that are naturally occurring
21
down there.
50 what we used was the peristaltic
22
23
pump technique in the third round to see if this is
actually what was happening.
And what we -- what
24
25
the peristaltic pump technique is, is actually a
little pump that's driven.
We have a little plat
.
-------
I -
28
1
tube on it that goes down to the ground water moni-
toring well, instead of dropping something down
2
3
there and stirring up all this s~uff, this pump
actually very slowly pumped out the water and we
4
5
6
took our samples that way.
Well, what we found,
7
after using that technique, was that the levels in
those wells did significantly decrease, that there
8
9
wasn't the levels of contamination dealing with the
heavy metals that we thought there was.
So basi-
10
cally the RI and the SI results indicate that limit-
1 1
ed migration of contaminants in the ground water has
12
occurred, and there also has been minimal affect on
13
There is no evidence of a plume
the ground waters.
14
of contamination, however, MCL exceedances were
15
16
observed in some wells for four contaminants, 1,2-
Dichloroethane, 1, 2-Dichloropropane, chromium, and
17
lead.
18
19
What do I mean by a plume?
EPA and I have studied
at plenty of sites before, where we will see, actu-
ally a plume of contamination, where you're getting
20
21
very good agreement between all your sampling rounds
when you get -- actually a real definable pattern,
22
23
where you can actually see this stuff migrating off
24
25
site.
That was not the case at Golden Strip here.
We were seeing some real spot -- you know, we'd see
.
-------
29
1
2
a hit here, we'd see some little contamination here,
but it wasn't really a plume.
So it'd be ve~y, very
3
difficult, if not technically impractical, .to go out
4
there and actually retrieve this stuff.
So we have
5
6
seen that there are actually -- although there was
some MCL exceedances for these four contaminants,
7
there is not a definable plume or a definite pattern
of the contamination.
8
9
So we sat down did a backtrack.
Actually, the Sup-
10
plemental Remedial Investigation results, we had.
those in our hand about the middle of March, end of
11
12
March of this year.
So we sat down, sat down with
13
Kevin and our ground water experts there at EPA and
14
we said,
'what are we going to do about the ground
15
16
water?'
Something -- we had a pretty good idea what
17
we needed to" do with the lagoon, sludges, and sedi-
ment, we feel those need to be addressed in the
18
19
Feasibility Study.
We know that we need to do some-
thing to the lagoon waters..
We knew that the stream
20
21
'What are we going to do
had. not been affected.
about the ground water?'
What we decided to do with the ground waters is,
22
23
based on the results of these three sampling events,
we thought we had a real good database to rely on,
24
25
that were going to set ultimate concentration limits
.
-------
I
I .
30
1
2
for the observed intermittent MCL exceedances.
Okay.
What that means, an ACL, or an Alternate
3
4
Concentration Limit, is an actual alternate limit
that is established.
It's allowed to exceed the
S
6
MCL, given that as soon as -- it's based on basical-
ly three things, three or four things.
What you
7
need to show for Alternate Concentration Limits to
8
9
be effective are that removal of the source, okay,
of the lagoon waste, will actually result in a posi-
10
tive influence on the ground water.
We feel and we
11
do know as a result of all those samples that have
12
.
been taken out there in the RI, that removal or some
13
kind of treatment or some kind of active remediation
14
to the source area will result in a positive influ-
1S
ence on the ground water.
We feel that actually
16
removing that source or treating that source in any
way, we'll see those ground water levels decrease.
17
18
19
Also, you need to show that where the ground water
is discharging into a known surface water body, in
20
21
this case the unnamed stream, we have shown that the
ground water actually is discharging to the unnamed
stream and that there is no statistically signifi-
22
23
. cant increase in the level of contaminants.
24
2S
One would expect that if there is contaminants in
the ground water, and it is discharging to a body
.
-------
31
1
2
that you know, that you should see elevated levels
in this stream.
Well, that's not the case here.
3
4
The levels in the groundwater contamination are so
minimal, they're not even affecting the actual
5
They're not affecting the actual ecologic,
stream.
6
the ecology of the creek, and as it discharges in to
Gilder Creek we're not seeing any elevated levels
7
8
9
Also, you need to prove that there is no
there.
discernable plume.
So, essentially ,it is techni-
10
1 1
cally impracticable to go out there and do anything.
What we will do, in association with establishing
12
ACL, is we'll establish a long-term monitoring well
13
14
And basically what that will consist of is
program.
monitoring these wells (indicating) over a period of
15
16
We have wells that are established.
There's
time.
approximately one. here, here, and all the way
17
through here (indicating).
We'll monitor those
18
wells over a period of time to ensure that, in fact,
'yes, we are correct, that this ground water is not
19
20
migrating off site.'
21
Moving on, as part of the Remedial Investigation, we
22
23
also looked -- I mentioned earlier -- at the Base-
iine Risk Assessment, the BRA.
And this is included
24
25
in Section V of the actual Remedial Investigation.
And what we found out there, essentially, was the
.
.
-------
32
1
2
primary hazard to human health and the environment
is posed by direct contact with those lagoon sludges
3
4
and contaminated or affected sediments.
I'll see if I can make a quick summary of how we
S
6
look at this Baseline Risk Assessment.
The EPA has
established what we call Acceptable Risk Range.
7
There's two types of contaminants.
One type of
8
9
contaminant is a carcinogenic, which is a cancer-
causing chemical, okay.
And what we have estab-
10
1 1
lished as acceptable range is what we call the one
times ten to tne minus four to one times ten to the
12
13
minus six.
If the risk falls between those levels,
it is acceptable to EPA.
What that actually trans-
14
15
lates to, one person in ten thousand to one person
in one million will risk developing cancer, after a
16
lifetime of expOsure to these contaminants at the
17
particular site.
Okay.
That is the acceptable
18
19
range.
Now, the other index we use is for non-carcinogenic.
20
21
Essentially, a non-cancer causing chemical.
Those
would traditionally be your heavy metals, okay,
which we have a problem out of there with actual
22
23
metals, the lead, the cadmium, the chromium, that
24
2S
type of thing.
What we use as our break point for
that is the Hazard Index of one is what we call our
.
-------
33
1
cut off point.
If it's less than one we feel that's
2
3
okay.
That's in our acceptable range.
Now, if it's
over. one, the HI, the Hazard Index, is over one,
4
then we feel there is a potential for the human, or
the exposed individual, whether it be an animal or
5
6
what have you, then there is some potential effects,
potential toxicological effects on the exposed indi-
7
8
9
vidual.
50 we look at this.
How the land is being
10
currently used now, and how the land should be cur-
rently used in the future, to establish an actual
'-
1 1
12
driving mechanism to actually say, 'okay, EPA,
should you go in and actually address clean up at
13
the site?'
Okay.
50 this' is a process; it's a long
14
process that you actually compile all sorts of num-
15
16
bers and the toxicologists stay up all night long
trying to get all these numbers, and they come out
17
with a Result in Risk Factor.
And we use
Okay.
18
19
that to compare it to our Acceptable Risk Levels.
Okay.
Under the current land use scenario, which
20
21
means what is going on out there right now, if noth-
ing was done from. now until the end of time, the
22
23
carcinogenic, the lifetime excess cancer risk, is
two times ten to the minus five, which is in accept-
24
25
able risk range for EPA.
However, the Hazard Index
for non-carcinogenics is 8.1, which is essentially
..
-------
34
1
2
eight times what we would call the acceptable limit.
So that tells us right there we have a problem,
3
4
okay, with the non-carcinogenics.
And that makes
sense given the fact that we have again, like I
said, the heavy metals, the leads, the cadmiums, all
5
6
concentrated in this lagoon waste.
So right there,
7
that gives us basically the authority, or gives us a
driving mechanism to go in and say, 'this site
8
9
should be addressed for some sort of Remedial Ac-
10
tion. '
Okay.
And essentially, this is what this
1 1
slide summarizes (indicating).
12
It says, "Under conservative exposure scenarios
13
contact with the affected media," the lagoon slud-
ges, and the soils, "pose a potential threat to
14
15
human health and the environment at the site.
For
16
that reason w~ feel a Remedial Action or Remedial
17
Response should be considered for those particular
18
19
media."
So in summary, after all those slides, bringing this
into a conclusion here real briefly, 'What are we
20
21
going to do out there?
What's going to be our fo-
22
23
cus?'
Okay.
Well water, just to summarize up here,
ACL, Alternate Concentration.Limits will be estab-
lished for the four contaminants that exceeded MCLs,
24
2S
that's 1,2-Dichloroethane, 1,2-Dichloropropane,
.
-------
35
1
2
chromium, and lead.
Also as I mentioned, a long-term ground water moni-
toring network to ensure that, in fact, these con-
3
4
taminants are not migrating off site and actually
they are decreasing, will be established by EPA and
5
6
South Carolina Department of Health and Environmen-
7
tal Control in the Record of Decision phase.
After
8
9
we have actually selected our remedy, okay, we have
eight alternatives, we're going-to narrow it down to
10
11
one, and basically that's what we're here to do
tonight, is to say, 'Public, this is what we reel,
12
13
this is the preferred alternative.
We feel this
would most appropriately address the contamination
14
1S
at the site.'
After we get that decision documented
in the ROD, we'll actually go ahead and develop that
long-term ground water monitoring program together.
16
17
We feel that the lagoon surface water has been im-
pacted, as I mentioned before, and that water actu-
18
19
ally in the Lagoons Number 1 and 4 is about 1.9
million gallons; that's the current estimate right
20
21
now.
22
23
What we propose to do with that, is discharge that
to what we call the local Publicly Owned Treatment
24
25
Based
Works.
Basically -- and we call that a POTW.
on preliminary discussions with the Metropolitan
.
-------
. .
36
1
Sewer District and the Western Carolina Sewer Au-
2
3
thority, they have actually looked at the data from
Lagoons 1 and 4 and they have made a decision that,
4
'yes, they can accept that water into their sewer
5
6
system. '
And what that will be dOing -- what will
7
happen is that stuff will be piped off to the actual
public -- the Treatment Works and be treated at that
8
9
point in time.
They have what they call pre-treatment standards,
10
They have actual numbers, okay, from the
okay.
'"
Now, if it exceeded these numbers
contaminants.
12
13
then pre-treatment of this water might be necessary.
Preliminary indications, they've actually reviewed
14
15
all our data, and they have actually indicated to us
that pre-treatment will not be necessary, so we'll
16
17
be able to actually pump that lagoon water right
into the sewer line.
18
19
And then finally, as I mentioned before, the surface
soils and lagoon sludge, as I mentioned, do pose a
20
21
potential risk to the human health and the environ-
mente
So we feel that they should be addressed.
22
23
Actually, 28,000 cubic yards of material are out
there, and we feel that we need to address that.
24
25
What has happened at this point in time, we feel
that, 'okay, we've identified the problem.
Okay,
.
-------
37
1
now what are we going to do with it?'
that, we don't really know for sure.
Going into
Our mind -- we
2
3
kind of sit there, we kind of sit back and we have a
4
little reflection time, okay.
What we do then is we
5
6
move into the Feasibility study Phase.
Okay.
At that time what we do is, we submit numerous al-
7
ternatives ranging from no action to containment to .
institutional controls, all the way up to very ac-
8
9
tive of treatment, okay, more of a permanent solu-
10
And we look at those, we cost them out, we
tion.
i I
l~k ac lite implementability, all this iun'stuff,
take a look at that, arid try to make our decision
12
13
14
from there.
And briefly, I'm going to go through all of our
15
16
eight alternatives that are considered in the Feasi-
bility study.
17
Alternative 1, is actually an alternative that we
18
are required to do by law.
We required RMT to actu-
19
ally take a look at the No Action Alternative.
Und~r the No Action Alternative, nothing is done
20
21
just as the name would imply.
No action on soil, no
22
23
action on the sludge, no action on the surface wa-
. ter.
I'd like to emphasize that the risks posed by
24
25
this alternative are still unacceptable given the
mild carcinogenic effects.
Again, that exceeds the
f
-------
38
1
2
1.0 and we are about 8.1 with that.
Again, that's
3
just basically the baseline of our analysis here.
We are required to do that by law.
4
5
Moving on into Alternative 2, is what we call In-
stitutional Controls.
What that means, is basical-
6
ly, institutional controls will be developed for
areas containing potentially affected soils and
7
8
9
sludges, the lagoon areas, and institution controls
for the areas that contain the affected surface
10
water, okay, all coupled with long-term monitoring.
i i
. tf&1at that is, a map -- ~e1Jresentatioa1 ot it, is
12
basically Institutional Controls consists of two
13
One, first and foremost, I guess, is the
things:
14
15
fence.
We would establish a fence that would elimi-
nate the actual exposure scenario of an actual tres-
16
passer, okay, around all the lagoons and all this
17
affected surface areas.
This is the fence right
18
19
here (indicating).
The fence would be six foot
high, just a chain-link fence, with strands of
20
21
barbed wire on top.
And also, in association with
that, we also established what we call a Conserva-
22
23
tion Movement.
This is this dashed line here (indi-
. eating).
Again, if you can't see this very well,
24
25
this should be in your handouts.
What the Conserva-
tion Movement is it's more of a legal matter, more
.
-------
39
1
2
of a legal document that actually controls the fu-
ture use of the site.
It's attached to the deed of
3
4
the property and said, 'this property contains haz-
ardous waste and we are controlling the future use.'
5
6
Basically, everything would remain that way; we
would just cut off the exposure pathways.
Okay.
7
Actually, the cost associated with this alternative
for putting up the fence and the long-term monitor-
8
9
ing associated with. it and the Conservation Ease-
10
ment, I believe are 1.4 million dollars.
11
12
Mo~ing on to Alternate 3, this is wnat we call the
Containment of Solids Alternative.
Basically, now
13
14
we're starting to get into more active measures.
Instead of leaving the stuff there, here's' what
1S
16
we're going to do to this.
We would develop Insti-
tutional Controls for the areas containing affected
17
solids.
Okay.
Again, the same Institutional Con-
18
19
trols I just mentioned.
We would grade the areas
containing affected soils and sludges and put a cap
20
21
over them.
Okay.
We would collect the surface wa-
ter, discharge to the local POTW, we've mentioned
22
23
that before, and a150 coupled with the long-term
monitoring.
Okay.
I'll try to explain to you a
24
2S
little bit what that means.
There's a map that
illustrates what would be done for Alternative 3.
.
-------
.
1
2
3
4
5
6
7
8
9
10
1°i
12
13
14
15
16
17
18
19
20
21
22
23
24
25
40
Essentially, again, you see the Conservation Move- .
ment, a fence coupled with Alternative Number 2, and
this shaded area here is the area that we would cap
(indicating> .
Okay.
What I mean by capping, essen-
tially what you're doing -- we looked at two differ-
ent caps, which are right here.
I'll touch on those
in a second.
Essentialy, what you're doing is plac-
ing a clay layer -- okay, you have six inches of
actual topsoil, another twelve inches of native
soil, and under the first capped option you would a-
ctually place two feet of compacted clay over ap-
proximately 7.4 acres.
Okay.
Now, what that actu-
ally does, is it removes -- it actually removes the
mechanism for infiltration. Okay.
As the rain would
fall on the lagoon, we would hope that it actually
-- it would go off the cap and kind of around and
not actually directly infiltrate through the actual
contamination that was present.
We looked at two
different alternatives:
One, Alternative A, Cap Op-
tioD A, basically again was just the two layers of
soil and a big layer of clay.
Then Alternative 3-B
was more kind of a cadillac of caps, I guess you
could call it, it had more of a geotechnical or geo-
textile membrane, more expensive materials, subse-
quently it would actually obviously cost more.
The
.
-------
4'
1
2
cost associated with this-alternative for option A
was 3.2 million dollars and for option B was 3.5
3
million dollars and that was Alternative Number 3.
4
5
Moving- into Alternative Number 4, it's a little -more
active here.
This is actually stabilization and
6
off-site disposal of all the soils out there, okay,
the 28,000 cubic yards of material that we have
7
8
9
identified as being affected. Essentially, what
would happen is, we would dig all these materials
10
up, excavate all the defective materials to the
i 1
actual Remedial Action target concentrations, to the
12
13
concentration that we said are protective of human
health.
Okay.
We would dig all those up, de-water
14
15
the sludge -- actually, when you dig that stuff up
you're going to have -- some of the stuff is going
16
to be actually rather muddy.
You would filter the
17
18
water off of that, that would go with the surface
water, and discharge to the local POTW.
Then you'd
19
20
actually take the -- again, at that point in time
take the solids from that filter and actually trans-
21
22
port to an off-site treatment facility, okay, what
we call the GSX Facility.
Essentially, it would
23
24
entail trucking about 28,000 cubic yards of material
off site, require a long, long, long, long train of
25
trucks essentially, probably close to a thousand or
-------
42
1
2
more.of trucks actually to haul all of that material
off site.
And, consequently" given the actual --
3
4
the cost of the trucking, and actually, the fee that
you must pay at the landfill, the cost of this al-
'5
6
ternative are right in the neighborhood of 12 mil-
lion dollars, it was actually 12.5 was the number
7
that was calculated for this.
Again, this is just
8
9
kind of a schematic of Alternative 4 (indicating).
We would basically excavate the five lagoons that
10
we've identified the waste at, excavate -- scrape
1 j
tile:! actual truck turnaround area, and the drain
12
13
swale area, bring our trucks in, and haul it off
site to an actual permitted landfill, a landfill
that is acceptable that can actually handle this
14
15
16
waste.
Moving into Alternative Number 5.
Alternative Num-
17
b~r 5 is kind of a combination of 3 and 4.
Basical-
18
'okay,
ly, what we looked at this way, we said,
19
20
what's driving the cost of Alternative 4 so high is
the. actual trucking cost.
Let's see if you can
21
22
reduce the actual quantity that we need to haul
off. .
What we'd do for that then is -- this is
23
24
Alternative 5, this is actually off-site disposal of
the actual lagoon sludges, okay.
We would take the
25
most contaminated sediments, put them in our trucks,
-------
43
1
2
and haul them off to the p.rmitted landfill, okay.
The affected solids, we would cap them as we did in
3
4
Alternative Number 3.
And, again, associated with
the actual Remedial Action for the surface water and
S
6
the long-term monitoring.
I'll show you what this
7
woufd entail, a very similar picture. Again, exca-
vation of the actual areas of concern. Okay. You'd
cap the whole area again, like we did in Alternative
Number 3, but haul off approximately, I believe,
8
9
10
6600 cubic yards of solid sludge, okay.
"11
~oYing in to Altenldtiv~ G, we said, 'okay, it's
12
costing us a lot to transport this stuff off.
What
13
14
if we construct our own ha;ardous waste landfill on
site in an effort to reduce this cost.'
Okay, so
1S
16
what this site -- what this actually entails, is
excavation of all affected sludges and soils, dis-
17
charge of the surface water to the local POTW, and,
18
again, as with all the alternatives, the "Institu-
19
tional Controls.
Okay.
What this looks like is all
20
21
the. sludges, all the affected material would be
excavated again to the same concentrations that we
talked about before, and actually instead of trans-
22
23
Porting them, would be disposed of in this landfill
24
2S
here, okay.
It was
approximately 23S feet in diam-
eter, basically a square, and we would just dispose
-------
1- -
44
1
of that stuff there (indicating).
"We would meet all
2
3
requirem~nts.
Essentially, what I'm talking about
here is our double-lined landfill we call minimal
4
technology requirements, so it'd be in accordance
S
6
with all EPA and South Carolina requirements.
The
associated cost for that was right around seven
7
million dollars.
The only thing that kind of turned
8
9
us off about this is that actua11y the possibilities
of EPA or DHEC actually being able to site the Haz-
10
ardous Waste Landfill in this property are slim to
11
none, and actually it would be an administrative
nightmare and, in fact, probably could not be done.
12
13
We would not want to affect the -- and actually
affect the -- and leave that for the next 30 years
14
1S
16
and affect the actual Holly Tree residents.
Moving on into Alternative 7, which is more in the
17
Now, we've went all the way from no
treatment end.
18
19
action up to containment, up into those areas, and
kind of a mixture of all those.
Now, we're going to
20
21
look at, 'okay, let's look at a permanent solution
to this stuff.'
Let's look at the treatment alter-
22
23
"native.
Let me see if I can get this on here a
little better.
24
2S
Again, what we're talking about is some of
Okay.
the same thing.
I don't want to be repetitive.
-------
45
1
2
I'll try to get through this as soon as possible.
There's again collect surface water and that's going
3
to POTW; again we would excavate the soils and the
sludges that exceeded the Intermediate Action Target
4
5
6
Concentrations, the same as I was talking about
before.
And we looked at -- for treatment we looked
7
at basically three applicable remedial action tech-
8
9
nolegies.
One being vegefication, two being soil
washing, and three being solidification or stabili-
10
zation or fixation.
'j 1
. Le t: 's touch ou chose.
Optiou '1-;' was vegeiicacl.on.
12
13
Essentially, what vegefication is, is you're turning
that liquid waste or the solid waste into molten
14
glass.
Essentially, you are encapsulating it, okay,
15
16
by sticking electrodes in the ground, okay, and
actually putting a lot of heat on that stuff and
17
actually solidifying it in to just a big piece of
molten glass or a big molten blob of waste that
18
19
resists leeching.
There would be -- and associated
20
21
with that again you'd have your -- we'd backfill
that up, throw some shallow rotted grass on that to
22
23
minimize erosion, soil washing would be -- actually
you excavate, again, the affected materials.
You
24
25
would actually attempt to wash the organics or the
organics and the metals off of the soil particles
-------
46
1
2
and separate them that way.
Stabilization, solidification is actually when you
3
4
utilize -- you kind of mimic a cement mixing pro-
cedure. Actually, what you do is you excavate the
5
6
stuff, mix it all up like you're making cement, and
actually place it back in the excavations and the
7
result is a solid mass of monolith, what we call it,
just a big unit that actually again resists leech-
8
9
ing.
The associated cost with this, for vege-
10
fication given the heat necessary and the length of
time of operation ran about '19 million dollars.
'j I
-12
13
Soil washing, since it is so labor intensive, I
think ran in the neighborhood of 13 million and a
stabilization by fixation and fluification resulted
14
15
in 4.5 million.
Again, just real briefly, what we
16
had there, was excavation of these affected materi-
17
als combined with the Conservation Easement and the
18
19
actual fence.
Okay.
Moving on to Alternative 8, this is what we call the
20
21
In Situ alternative.
Basically, the only difference
22
this one posed, was instead of excavating this
stuff, we're going to actually treat it in situ.
23
24
Okay, what I mean by in situ is safe for solidifica-
tion.
What we would do, instead of digging the
25
stuff up, we would drill down with a big auger it
-------
47
1
would have a hollow stem in it and pump this cement
2
3
down in the ground.
Okay. ,Instead of excavating
4
it, we would pump it down in the ground and mix it
up and hope that we had reached the waste effective-
S
6
ly and have solidified it effectively.
The technology required for these three alternatives
7
8
is still developing, actually, and there was not a
lot known about this.
And actually right away the
9
applicability of these three alternatives was ques-
tioned from the onset and we didn't really explore
10
, 1
very nluc.::h ~ul:ther 'than that, just becaus-d we didn' to
12
13
have the information on it.
Where do we go from there is into evaluation of
14
the~e things?
This is kind of where it all comes
1S
out in the wash, okay.
We talked over all eight
16
17
alternatives, and now what are we going to do with
that stuff.
Well, EPA has established nine criteria
18
19
to evaluate these, okay, and we try to achieve the
best balance of all these criteria that we can.
We
20
put. a little scoring mechanism on them and actually,
the one that comes out the best, more than likely is
21
22
the one that actually is selected as EPA's preferred
23
. remedy.
The first seven perform actually, the basis
24
of the comparison, okay, of the analysis.
Overall
2S
protection of human health, okay, how protective is
-------
48
1
it of human health?
Does it meet tPA's acceptable
2
3
risk standards?
We look at compliance, what
Okay.
we call ARAs, Applicable or Relevant and Appropriate
4
5
Requirements.
Those are EPA requirements; those a~e
state requirements.
Okay.
We also looked, is this
6
remedy going to be effective over the long term,
over the next '40 years after we're dead and gone out
7
8
9
of this place, is it still going to be effective.
What's the permanence of it?
Okay.
That's the kind
10
our criteria is.
Does it reduce -- going to
Okay.
Of i
four -- does it reduce the toxicity, the mobility,
12
and the volume?
An example of this, a capping al-
13
14
ternative, a more -- a less ,active alternative would
not really reduce the toxicity; it would not reduce
15
16
the mobility -- to a certain degree I guess it
would.
It definitely would not reduce the volume.
17
18
You're leaving it in place.
When, in fact, a more
active, a more pro-active treatment would actually
reduce the toxicity, because you're solidifying it
19
20
in some way, you're actually immobilizing it.
You're reducing the toxicity and in some instances
21
22
you might increase the volume a little bit.
The
23
24
short term effectiveness is, okay, while you're
implementing the chosen remedy, what type of effec-
25
tiveness are you going to find on the workers who
-------
21
. 22
49
1
2
are actually doing the work.
Actually, is the exca-
vation of this material actually going to make the
3
problem worse?
Or is that going to put the
Okay.
4
actually neighboring citizens into an exceptional
5
6
risk at that time that we can't afford.
Implement-
ability is how easy it is to do.
Is this impOssi-
7
ble?
Do we have the technology to do this?
Do we
8
9
have the knowledge to do this?
Where do we sit on
that?
Sometimes you might have the knowledge and
10
technology to do it, but the equipment might not be
Ii
necessary or we not be able to get our hands on it,
12
that type of thing.
And, also, taken into consider-
13
14
ation is cost.
Okay.
Obviously, all ranging from
the actual No Action cost or the No Action Alterna-
15
16
tive, which was virtually nothing, all the way up to
vegefication which costs close to 19 million dol-
17
18
lars.
And the final two of the criteria are very impor-
19
20
tanto
One, I guess number eight is state accep-
We worked closely with the state of South
tance.
Carolina, Department of Health and Environmental
Control, throughout this process, and we will con-
23
24
tinue to do so throughout the remainder of this
process here.
They will actually take a look at all
25
the documents as we do, take a look at the Remedial
-------
I .
1
2
3
4
5
6
7
8
9
10
j 1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
50
Investigation, take a look at the Feasibility Study,
and they will concur with EPA's Preferred Remedy or
they might give us some suggestions and say, 'well,
EPA, we don't like to see that done.
This is our
state.
We do have some authority on what goes on
We would like to take a further look at
here.
this. '
Well, in this case, we've worked with them
very closely and they do concur.
They agree with us
that this problem -- our Proposed Alternative is
probably the best way to go.
And then last, but not
least, is Community Acceptance.
What we're --
that's basically why I'm here tonight is that we
bring our Proposed Plan in front of the public and
see what you all think about it.
And basically what
we do is we open up that alternatives, not only the
Preferred Alternative, all the other alternatives
considered, and any other concerns that you may
have.
Maybe you have something that was left out
that you feel needs to be addressed.
What we do at
that point in time, we have a 30-day public comment
period, where the, public is encouraged to submit
comments, written comments to myself and to my ad-
dress, that's actually in that Fact Sheet.
If you
don't have it, I will give it to you, and EPA will
consider all those comments.
Okay.
After we ran it
-------
51
1
2
through all those criteria, one through seven,
eight, and nine as we're currently doing right now,
3
4
we came up -- the conclusion is -- drum roll, please
-- Alternative 7, 7-C, what we're calling Solidifi-
5
6
cation and Fixation of that waste.
Okay.
What this
actually is going to consist of, again, to be repet-
itive just a little bit, establishment of ACLs for
7
8
9
the four contaminants that have exceeded MCLs, also
the Long-Term Monitoring Program that I've previous-
10
ly discussed about.
Discharge of the surface water
i ~
In pond Lagoons 1 and 4 to the local P~~.
}u.d
12
13
then, the section where we're going to deal with
that is the actual fixation.
What do we mean by
14
stabilization and fixation, is actually the ex~ava-
tion and treatment of all of the affected soils and
15
16
.sludges that I've mentioned.
And these treated
17
18
materials will be backfilled into the excavations
located on site.
What we'll do is we'll have to
19
20
excavate that material -- 1'11 show you what we're
talking about again to drive the point home.
These
21
22
are the Remedial Action Limits.
You can see the
dash lines around here (indicating).
We're going to
23
24
excavate all the soils and sludges from all these
lagoons and the drainage swale, and further inves-
25
tigate the abandoned drum area, and actually -- 1'11
-------
°52
1
2
show you what those numbers translate into.
Basi-
cally we're looking at this column here (indicat-
3
4
ing), okay.
These are all our constituents of
concern that we have out there.
The one -- the list
.5
6
that I showed you earlier tonight.
And what this
means is that this is our target concentration,
7
okay.
When we dig down in those waste -- say, for
8
9
example, lead will be cleaned up to a level of 500
parts per million, okay.
That's a way we actually
10
, 0'
measure a concentration in the soil.
What we'll do
is we'll dig down, we'll keep digging, we'll keep
12
digging, keep digging until we meet all these re-
13
We have calculated~ based on RMT
quirements, okay.
14
studies, that it's going to actually require excava-
15
16
tion of approximately 28,000 cubic yards of materi-
al.
Okay.
What we'll do with that is temporarily
17
° store it on site, what we call stockpile it, then
we'll actually mimic a cement-mixing product, okay,
18
19
or a process.
We'll take that stuff in what they
20
21
call a pug-mill mixer, we'll run that actual affect-
ed soils and slud~es through, mix it with basically
22
23
street cement, as you would, you know, normally see
on your streets.
We're actually mix that in there,
24
25
okay, and you're going to get a matrix, now, of
cement and actually affected soils and sludges.
-------
53
1
That stuff will be placed back in the excavated pit,
2
3
okay, and will be allowed to settle.
The
Okay.
4
result is going to be one big solid, continuous,
massive block of concrete that resists leeching.
5
6
Basically, what that does is immobilize all the
7
contaminants, makes them unavailable for leeching,
and we 'feel that will actually cut the source areas
8
9
off and result in a pOsitive influence on the ground
water.
We have actually went forward with, what we
10
call a Treatability study to look at the actual
1 1
eriect.s.
Will this
okay, welve selected this,
12
now, 'is this going to be effective?'
By the
Okay.
13
time we got through with the Feasibility study it
looks like the one that's going to turn out to be
14
15
the best one after evaluating through all the crite-
ria is Option 7-C, so let's take a look at it.
16
17
Let's try and mimic site conditions, let's try and
mimic what's going to happen in real life.
18
19
50 RMT, under the direction of EPA, actually took
20
21
soils of representative waste in Lagoons 1 and 4,
they actually took samples of this waste that's
22
23
present out there, and they played around with it,
okay, by mixing some cement in there.
They played
24
25
around with the different ratios, okay.
How much
cement is going to be necessary to mix with this
-------
I
\ .
54
1
2
80il and this sludge to get an effective monolith,
okay.
3
4
There's basically two criteria that you need to meet
in doing this.
The first one, which is not neces-
5
6
sarily the governing one, but it is the structural
end, the physical end.
When that stuff solidifies.
7
8
it must have a compressive strength of 50 psi, okay,
50 pounds per square inch, which is very minimal,
9
very minimal.
That's no problem to meet.
But the
10
trigger to the whole thing is that we must show that
this stuff -- when we say compliance with A~s,
11
12
13
Appropriate Requirements, this stuff if you run it
through that TCLP Test, it's called Toxicity Charac-
14
teristic Leeching Procedure, what you're doing is
15
16
basically mimicking site leeching procedures.
Okay.
You're actually -- you actually crack your cylinders
of waste, okay, that you have, you have this cement
17
18
here.
You actually .crack that stuff and mimic rain-
19
20
falls and acid rainfalls and see what's actually
coming out of that stuff, see what's coming out,
.
21
22
what's going to b~ going into our ground water.
Is
it going to be clean or did it not work?
Okay.
23
24
well, we ran those tests and we got the data, the
data is actually in the RI and the FS and we ,have
2S
shown that they meet all applicable requirements,
-------
55
1
solidification and fixation of these type of wastes,
of the organic -- of low-level organics in the con-
2
3
centrations that we've seen in the inorganics 18
what they call. the Best Demonstrative Available
4
5
6
Technology for dealing with this.
They call that
BDAT.
What it means, is information that we now
7
have available, the technology is out there right
now for us to utilize, it is the best method to use
8
9
in solidifying these type of contaminants.
50 we
10
l'
feel very strongly that this is the best way to
handle this material.
We know a lot about it.
The
12
actual -- the technology is very easy to get to.
13
14
It's actually very cost effective.
I'll get into
that in a second.
But also, last but not least, is
15
16
the Institutional Controls and the Conservation
Easement to control the future use of the site prop-
17
18
erly.
Institutional Controls is a fancy 'way of
saying, 'we're going to put a fence around there and
we're a1so going to establish a Conservation Ease-
19
20
ment, which is going to basically grab control of
that property to a third party, a task group, and
21
22
Mrs. Rice. And it's going to be attached to the
23
24
deed.
It says, 'there is residual hazardous waste
that has been solidified on the property and it's
25
buried 30 feet under the ground.'
Just so
Okay.
-------
I
I.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
S6
that it's controlling the use so John Q. Citizen ~-
somebody says, 'I'm going to buy this property.
I'm
going to put my dream house on it and put a well in
it,' okay, 'and put the ground monitoring well in
it,' and,
'oh, my god, he's got contamination.'
Or
he starts to dig his basement and he hits a big
chunk of concrete, that type of thing.
Okay.
That's basically what that's going to be, it's to
control the future use.
Okay.
Why do we believe Alternative 7-C, Solidi-
tication and Fixation is preferred?
For the fol-
lowing reasons:
As I've mentioned, it is very pro-
tective of the human health and environment, the
resulting risk from the carcinogenic and the non-
carcinogenic are well within EPA's accepted limits.
Okay.
Again, we have proven through our Treatabili-
ty Studies that it does meet all Applicable, Rele-
vant, and Appropriate requirements.
I've mentioned
the TCLP Test and the 50 psi that we must meet.
has. been effectively shown to handle that.
It
Going on, again t~is is kind of running it through
the criteria that I mentioned earlier, we feel that
the treatment -- and we have shown, the treatment
will immobilize and eliminate the waste constituent
source areas, i.e. the lagoons and their affected
-------
57
1
2
soils.
And it shall provide long-term effectiveness
with minimal risk during construction and implemen-
3
4
tation.
I mean, not only minimal risk to the con-
struction workers but also minimal risk to the ex-
5
6
posed population in the Holly Tree Subdivision and
any nearby residents.
Number four here, is it uti-
7
lizes a proven and widely available technology that
8
9
is easy to implement.
Solidification, as I men-
10
tioned, and all guidance and all the knowledge that
we do have on this right now is what they call the
1
j I
Best Demonstrative Available Technology.
1t has
12
13
been proven many, many times at other Superfund
sites across the country.
We have lots of data to
14
15
rely on that says, 'yes, this is effective.
this does work.'
EPA,
16
In addition to that, it reduces the toxicity and the
17
mobility of the contaminated soils and sludges
18
19
through treatment.
If we were to go to, say, Alter-
native Number 3, it doesn't really reduce the toxic-
20
21
itYi it doesn't really reduce the mobility.
You're
essentially leavi~g that stuff there.
You're just
22
23
kind of taking a secondary measure and placing a cap
over it to try and reduce the mobility a little bit,
24
25
but it effectively doesn't do it as well as treat-
It is very cost effective.
ment does.
Basically,
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1
2
we looked at a range from zero dollars up to nine-
teen million dollars, okay.
Granted, vegefication
3
4
can be, in certain applications, very effective.
Okay, it has been used at nuclear sites across the
S
6
country, but it cost nineteen million dollars.
Does
the contamination we have at the site actually con-
7
stitute vegefication?
We don't believe so.
It's
8
9
cost effective, four and a half million dollars.
Some of you are saying, 'is that cost effective?
My
10
god, it's a lot of money.
I wish I had that much
.j 1
money. '
But it does .fit in the low to medium range.
12
13
And, also last, but it is basically our preference
and it does satisfy our preference for a permanent
14
15
After we're dead and gone, we feel
solution, okay.
that this remedy will still be effective in reducing
the contamination that is exposed to the nearby
16
17
populations.
And it also satisfies our preference
18
19
for treatment as a principle element.
In all cases
where we can, where it does prove cost effective,
and. it meets all other applicable requirements, we
20
21
do like to go out and actually physically treat the
22
23
waste.
Okay.
I guess that kind of sums it up there.
I'm going to
24
2S
I'm getting -- you're probably
wrap this up here.
getting sick of hearing me talk to you, but, 'where
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do we go from here?'
I've identified -- I've tried
to bring you up to date on what has happened since
1960 up to where we are now, and identified the
Preferr.ed Alternative.
I guess now I'd like to kind
of illustrate where we go now in the next week and
onward.
Okay.
The Public Comment Period for this started this
Monday on the 17th, okay.
And the 30-day public
comment period will go until July 18th.
And what we
would like to do is encourage the public to submit
any comments, writ~en preferably to me, and they
will be actually incorporated into what they call a
Responsiveness Summary.
I'll get to that down here.
Actually, if there is a timely request for an exten-
sion of this 30-day comment period, EPA will extend
the public comment period another 30 days for a
total of 60 days.
And if the public feels they need
more time to review the Alternative, and we're given
a timely request, we will extend that to 60 days.
EPA,will respond to all comments received during
this 30- or 60-day case, whatever it may be.
We
will respond to all these comments received and they
. will be summarized in a document called the Respon-
siveness Summary.
That, basically will sum-
Okay.
marize all the comments we received during the pub-
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60
1
2
lic comment period and we will actually address
those, okay, the best way we. can.
3
4
Okay.
After we have received all the comments, the
public comment period is over, EPA will actually
5
6
issue what we call a Record of Decision.
A Record
of Decision basically finalizes what the selected
7
remedy is at the ~ld Strip Septic Tank.
It says in
8
9
a legal document, legally binding, it says, 'EPA
feels that Alternative X is the best alternative to
10
1 1
address contamination at the Golden Strip Septic
Tank Site.'
The Responsiveness Summary will be part
All this community participation as it
12
of the ROD.
13
14
is a serious evaluation criteria of ours. is always
included in the ROD.
Once the ROD is signed by the
15
16
EPA Regionai Administrator, the EPA Regional Admin-
istrator in Atlanta will review the Record of Deci~
17
18
sion and he will give his concurrence and. sign it.
And once it's signed it will become part of the
Administrative Record at the Information Reposito-
19
20
ries that Cynthia has touched on earlier.
And, okay, after that's signed, okay, where do we
21
22
go?
Well, that is basically -- once the ROD is
23
24
signed, that triggers what we call the Remedial
Design and Remedial Action phase of the Superfund.
25
We are now completed with the RIFS.
We are no lon-
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ger done -- Remedial Investigation, the Feasibility
Study is now completed, it kicks us into what we
2
3
call RDRA.
And what that is, is basically implemen-
4
5
tation and construction of the selected remedy that
was documented in the ROD.
Okay.
We expect the
6
Record of Decision to be signed in September of this
7
year, okay.
Once that is done, we will actually go
8
9
into negotiations with the PRPs to whatever the
selected remedy was chosen, we will actually go to
10
the PRPs and say, 'this is the remedy that we have
1 1
chosen, do you choose to pay for it?'
We
Okay.
12
13
will go through negotiations with them we feel --
and try to come to some agreement.
That usually
14
15
takes 90 days, three months, excuse me.
And there
is an actual other extension for 30 days, so that
16
17
So if you're look-
can go up to four months, okay.
18
ing at a Record of Decision signed, say, the begin-
ning of September, that will take you through
19
20
Christmas and probably into the end of January,
before actually Remedial Design of the selected
21
22
remedy will take place.
By that time then what is
generated is the nice engineering drawings, okay.
23
Okay.
All of a sudden now we've started to develop
24
25
our plan, saying 'we're going to excavate this,'
'stockpile it here,' or whatever the case may be,
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and actually document that in a Remedial Design
Report that, again, will be released to the public.
3
4
And from there we'll go on to Remedial Action which
actually implements the Remedial Design and then,
5
6
hopefully, as quickly as possible we will have that
stuff taken care of out there for you.
,
That's about it.
I've done a lot of talking here
8
9
and probably overloaded you all with information at
this point in time.
I'm going to get this'bright
light out of my face and open it up for any ques-
tions.
I'll be able to answer any questions you may
have.
If you feel that Jan -- or it's a health
assessment question, that toxicology may be able to
answer it, Kevin can address it.
Legal issues,
Teresa can answer it.
If there's a question you
would like the Task Group members or Bill Stephens
of RMT, who actually conducted this investigation
they probably know a lot more about this than I do
since they were out there all summer long.
Bill'
wil~ handle any of your questions and there's also
some representatives from the State here, too.
This
will be a very good opportunity for any of you all
. to answer any questions.
BY MR. JOHN C. STEVENSON:
Saying every.thing goes along on schedule and, you
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know, toward the end of January you begin Remedial
Action, you start working on the site, you start and
3
you take the plans and everything, how long then,
4
5
would it take for work there to be completed?
How
6
long before it is a slab of concrete 30 feet under-
ground and the fence is up and everybody is gone?
,
BY MR. ZELLER:
8
9
Everybody is happy.
Okay.
Actually, like I say,
let's just use that end of January date, just for a
fictitious number, but that's rather -- I think it's
probably -- looking at whera we are now, that's
probably a pretty real number o~ real date.
What
we'll do then, is enter into Remedial Design phase,
okay, all the engineering blueprints will be con-
structed, we'll sit down with RMT and kind of get
our plan toge.ther.
It depends on what is selected,
and I really wouldn't have a general -- I wouldn't
even -- I hate to even give you a number as far as
how many months that will take to get that RD phase.
RMT.might be able to tell you more about that.
But
once that is actually done, we'll go into Remedial
22
23
What I can tell you about it, once we.do
Action.
. begin Remedial Action, we're actually mobilized, we
24
25
have the treatment system all there, the number that
I was given was 20 to 25 weeks for completion of
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that stuff.
So that's four or five months.
And
it'll be a result -- yes, sir?
3
4
BY MR. BRUCE MEYER:
Why does cost a $1,400,000 to put a six-foot fence
5
6
around that site, Option Number 1 -- or Option Num-
. ber 2, I mean?
7
BY MR. ZELLER:
Option Number 2, the alternative, Institutional
8
9
Controls?
BY MR. MEYER:
Right.
BY MR. ZELLER:
I would have to look at the actual -- that's rather
expensive, the actual -- the sampling that's re~
quired.
Yeah, the monitoring.
What that is is
16
17
basically -- it's associated with -- not the actual
fence doesn't cost that much.
There are some legal
18
19
costs that would be associated with actually getting
the conservation easement and everything estab-
lished, but this stuff has been projected for a 30-
year operation and maintenance phase, which is the
long-term monitoring phase.
BY MR. MEYER:
But you're going to have that maintenance phase and
monitoring with any of these alternatives.
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BY MR. ZELLER:
Right.
And that's all incorp?rated in there in all
3
4
those cost figures.
Basically, No Action went to
nothing, okay, there was nothing done, no action on
5
6
everything.
Through Institutional Controls we actu-
ally do kick in the actual fencing and the long-term
7
monitoring and management.
8
9
BY MR. MEYER:
One more question then, if the results so far are
minimal as far as health dangers are concerned, why
10
11
not consider just pumping the liquid and continuing
12
13
to monitor to see whether the leeching continues
once the source -- basic source is removed?
14
BY MR. ZELLER:
15
16
Okay.
We looked at that.
BY MR. MEYER:
17
I don't see that as an alternative up there.
18
19
BY MR. ZELLER:
That was essentially what Alternative 3 was.
Alter-
nat~ve 3 is what we call Containment.
Okay.
That
was essentially pumping the liquid out to the POTW,
okay, getting rid of the water in Lagoons 1 and 4
. and, actually, effectively capping it.
ing everything there
Okay.
Leav-
BY MR. MEYER:
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But I mean without the capping portion of it.
No.
3
BY MR. . ZELLER:
Without the capping portion of it?
4
5
BY MR. MEYER:
Absolutely.
6
BY MR. ZELLER:
,
We -- that would be essentially Institutional Con-
8
9
Actually, Institutional Controls,
trols then, okay.
the water was taken care -- actually the water was
not pumped off, but it was left there and essential-
ly the only difference is we're talking the water.
And Institutional Controls is 1.4, the capping was
3.2 to 3.5.
We felt, that tor that additional .mon-
ey, you would get a-very permanent treatment, okay,
something that establishes a lot of permanence,
something that is very long term and will be taken
l'
care of after we're dead and gone from this place.
So, again, it's ---
BY MR. MEYER:
All.I'm saying is, it's been there for 20 years
already, and to pump the stuff out of there and see
if in the next few years that sampling and the wells
. that have already been drilled don't reduce the
levels of acceptable -- acceptability and save all
of the expense.
Because in the event -- as I under-
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stand it then, in the event that the group that has
paid for it so far, elects not to pay for it, then
3
4
it would have to come out of the Superfund funding
for a site that is extremely, in my opinion, from
5
6
what you all -- the information you provided me,
very, very minimal in terms of health risks.
And
7
I'm not convi~ced that we're looking at the most
economical ways to handle the problem.
8
9
BY MR. ZELLER:
I realize I was ---
BY MR. MEYER:
After all, we wind up with a fence around there
anyway.
BY MR. ZELLER:
Right.
I understand what you're saying.
It is --
you must understand that the evaluation of the cri-
teria is a balancing, okay.
There's some certain
criteria that are going to look really good from the
cost prospective.
It might look very cost
Okay.
eff~cient.
BY MR. MEYER:
Yeah.
But two or three years later you can still
. come back in and do the same thing that you're talk-
ing about doing immediately if the samples continue
to be negative or positive, I mean.
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BY MR. ZELLER:
3
So, again, you try and balance as much as possible.
And given the RI, we have actually identified that
4
as, okay, as actually the source areas, and it is
S
6
contributing, we feel, at this point in time a lim-
ited degree to the ground water contamination that
7
8
is present.
And we feel that it should be addressed
appropriately in some sort of active remediation or
active treatment.
I understand.what you're saying
it is a tough process.
Actually, when you do assem-
ble your alternatives, you just kind of throw up
your hands and wonder which one is going to come
out, because you must treat everyone -- each one
objectively and -- yes?
BY MS. PEURIFOY:
One thing, when you make a comment please identify
yourself for the court reporter.
Please give her
your name.
Thank you.
BY MR. ZELLER:
But, again, I guess I got off my train of thought,
but actually some treatments might look good com-
pared. to cost, some treatments -- they all have
. their one or two criteria that really do look favor-
able.
We try to get a well-rounded balance if some-
thing -- it is cost effective; it provides permanent
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69
1
treatment, and is obviously protective of human
2
3
health.
You had a question?
BY MR. JERRY CAMPBELL:
4
5
Yes.
My name is Jerry Campbell.
If you just use
one criteria to evaluate these options, and that's
the criteria of being overall protection of human
6
7
health, which one would have won, which option would
have come out best?
8
9
BY MR. ZELLER:
10
Overall protection of human health.
They're all
11
protective of human -- of -- actually except for
14
BY MR. CAMPBELL:
Equally?
15
16
BY MR. ZELLER:
With the exception of Alternative 1.
17
18
BY MR. CAMPBELL:
All equally?
19
BY MR. ZELLER:
20
21
They're not all equal, there's -- there is ---
BY MR. CAMPBELL:
I'm just saying, though, if you just used that one
22
23
. criteria which option would have been chosen?
BY MR. ZELLER:
It was actually a tie.
Actually, in that Fact
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17
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2
Sheet, if you'll look in Table 2, actually they were
all -- they were all rated (or overall protection of
3
4
human health, okay, and given a number.
And, actu-
ally, Alternative 7 and 8 actually rated the highest
out of overall protection of human health.
5
6
BY MS. ATKINS:
7
Craig, we have"a few comments.
8
9
BY MR. ZELLER:
What's that?
BY MR. ROGERS:
Going back to your other question.
You have to
realize, when Congress identified that there was a
problem with waste sites, and basically jnstructed
the law for the government to become proactive and
remove that problem, a lot of the National Priority
List sites don't currently pose unreasonable risks.
But yet -- and, therefore, taking your scenario, we
18
19
could just sit back and leave them alone and moni-
tor.
That's not really considered to be a proactive
res~nse to the problem.
They are ranked on the
NTL, based on current potential as well as future
22
23
use potential.
The idea is, get involved, identify
. these tentative problems, and rectify the problem
today, because if you waited and monitored for two
24
25
years, you could very well allow the problem to
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1
2
fester out further and create the thing -- a more
extensive cleanup.
Yes, if you were a betting per-
3
4
son, you could say it might never cause a problem,
but there are a lot of scenarios that you can bring
up, they could, in fact, cause a scenario both now
5
6
and in the future.
7
The other p~oblem, and the preference for actual
treatment would be and institutional controls is
8
9
we're all going away some day.
.We will go somewhere
else.
You will move.
Everybody's knowledge will
disappear and in a situation such as those well
known ones, Love Canal.
It was a great idea at the
time and it was in the middle of nowhere and sudden-
ly 20 years later everybody was building basements
all around it.
You know, the Congress basically set
the program up to be proactive and remove the prob-
lem and not go into a monitoring-type role, but they
also threw in all these other factors to make sure
that it's done in a reasonable fashion.
BY MS. A~INS:
Also, just to clarify for your information, I think
you said that the only other alternative EPA would
. have would be to use Superfund money if the PRPs,
Potentially Responsible Parties, chose not to imple-
ment the remedy.
Well, we will have the negotiation
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period.
EPA will implement a successional negotia-
tion moratorium, whereby we will agree not to take
any action, and give the Potentially Responsible
3
4
Parties an opportunity to come in and agree to the
5
6
clean up.
EPA also has another alternative, if
Potentially Responsible Parties do not agree, under
a negotiation moratorium period to perform the work,
7
8
EPA has the right to issue an Administrative Order
requiring and ordering Potentially Responsible Par-
9
ties to perform the work.
That has no implication
on this site, but that's just for your general in~
formation.
BY MR. MEYER:
Thank you.
BY MR. ZELLER:
In back, sir?
BY MR. CALVIN GUIGER:
If Alternative 7-C is chosen, what would be the
potential to future uses of the land that would
allowed?
BY MR. ZELLER:
Okay.
The conservation easement would basically
. restrict the use of that actual site, okay, that
actual area that's under the conservation easement.
Everything else, okay, the extreme north ends would
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be fine, okay.
We talked about that today with the
City Mayor actually.
3
Let me see if I can find a slide on here that has
4,
the conservation easement on it.
This is the con-
5
6
servation easement right here.
It basically encom-
passes the affected area.
That would be controlled
7
for future development, so there would be no resi-
dential development on there, however, everything
8
9
else around here would be fine (indicating).
are opening it up -- in back, sir?
50 you
BY MR. G.D. CROWE:
Yes, sir.
After the comment period is over, is
there only one 30-day extension period allowed?
BY MR. ZELLER:
Teresa, what is that actually?
BY MS. ATKINS:
To my knowledge, that's correct.
I would be more
than happy to check into that if you would like to -
- a further response to it.
BY MR. ~OWE:
Well, let me explain why I asked that.
My name is
G.D. Crowe.
The reason I ask that, it's .in the mill
. for me to .90 to EPA in Cincinnati, to do a demon-
stration with a new technology' that -- it really
fits the bill for this particular job.
And I'm just
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1
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wondering -- it's going to take a little ~onger than'
30 days to get all this done and I needed 60 days, I
3
4
was wondering if we could get it.
And I'd like for
this to go on the record that the new technology
will be available.
5
6
BY MS. ATKINS:
7
What we would like to request that you do, is any
request for an extension of time or any comments you
8
9
have, provide those to us in writing and we will
certainly respond to those.
10
11
BY MR. CROWE:
Thank you.
BY MR. ZELLER:
14
15
Mr. Paxton?
BY.MR. ED PAXTON:
16
I'd like for you to explain the formula
Ed Paxton.
17
that you used to evaluate these Alternatives on.
In
18
19
other words, you have set out nine steps in your
presentation.
And one of them, of course, is money;
one of them is community participation.
What weight
.
do each one of these bear upon making the decision?
BY MR. ZELLER:
. Okay.
I'll turn
I understand your question.
Okay.
to the specific -- my slides are allover the place,
but I think I found the one that we need tq talk
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2
about here.
Okay.
These are the nine criteria that
are evaluated in the FS, okay.
The first seven,.
3
4
form the basis of the analysis, okay.
The first two
are called the Threshold Criteria, the middle five
5
6
are called the Balancing Criteria, the last two are
called the Modifying Criteria, okay.
We make all
7
the engineering decisions on the first seven, okay.
Now, after we make the engineering decisions and all
8
9
these basically -- the first two are obviously the
10
most important, okay.
BOttOM line is protective of
11
human health.
Secondly, does it comply with all of
12
our standards and state standards.
And these form
13
These are actually the
So we need -- I guess
the basis of the analysis.
14
15
engineering analysis, okay.
would not come -- they're all -- all these first
16
17
seven actually have equal weight.
That's how they
were actually evaluated in that table, okay.
They
18
were all given -- they were all combined to each
19
other, okay.
Now, when we get back down to eight
20
and. nine, now those are called modifying, okay.
After we make the decision, after we choose a Pre-
21
22
23
ferred Alternative after evaluating for one through
seven, we'will and we have changed our minds, given
24
25
state opinions, state comments, state suggestions,
and actually community comments.
We have, in fact,
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went.in -- it's been documented many times -- and
actually changed the remedy from what we'd call a
3
preferred -- something -- say, Alternative 3 now
4
becomes preferred.
We have done that.
So ,. I guess
5
6
to answer your question they're all very important
in their own way.
7
BY MR. PAXTON:
8
9
That's not a satisfactory answer.
Does any of them
carry as much as a 50 percent weight and another one
carry a 10 percent?
formula?
Does one of them -- what is the
BY MR. ZELLER:
No.
What we'll do in the engineering analysis
No.
in the Feasibilit~ Study, okay, we don't actually
know anything about this.
We do on the state.
We
don't actually know anything about the community,
okay.
So we take one through seven and we run each
alternative through one through seven.
carry, at that time, an equal weight.
And they all
If you'll
not;ce in that table that I refer to in the Fact
Sheet at the end they all are compared relative to
each other.
If they're -- if they happen to be the
same in cost, they're all taken
-- the high score in this case is bad.
If it scored
nine that was bad.
What you're looking for when
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1
2
you've ran this comparison through all of them,
okay, is it protective human health and the environ-
3
4
ment.
We look at that.
If it is, and if they're
all equally -- if they were all equally protective
of human health they would all score a one, in this
5
6
case, okay.
If they all fell out of the acceptable
7
8
ranges they would all score a nine, okay.
In com-
pliance with ARARs do they all -- would they all
9
10
comply with ARARs.
If they all did, they'd all get
a one.
Now, would Alternative 7 comply more with
11
ARARs than Alternative 5, then it would get a one,
Alternative 5 would get a two, okay, and so on, and
12
13
so forth.
It's like -- it's like stacking them in
14
order, okay.
So at the very end, actually 7, as
15
16
you'll notice in the Fact Sheet, in Table 2 of the
Fact Sheet, all the numbers are a~ded up and at the
17
end you get a cost or actually a total score.
Say,
18
19
for example, after we've rated them, all through --
one through seven, Alternative 7 scored 16.
Alter-
.t:
20
native 8 scored 17.
Alternative 5, for instance,
21
scored 32.
That gives us an indication of what our
22
23
preferred alternative would do.
It provides the
. best balance over all seven criteria.
And then we
24
25
take that Preferred Alternative, we go to the state
with it and say, 'state of South Carolina, .what do
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you feel?
How do you feel about this?
Do you agree
with our analysis?'
And they either say yes, or we
would like to see this change or they make their
recommendations to us.
And we also take it to the
public, 'do you agree that this Preferred Alterna-
tive achieves the best balance of all the criteria
around?'
Keep in mind that no one alternative can
score one on all seven criteria.
But you must keep
in mind that it is the best overall balance for all
of them.
And there is no weighted formulas, as far
as you take. the score of one take it times point
five, take a score of two and take it times point
one four.
There's no weighted alternative.
Actual-
ly one through seven are all weighted equally.
sir?
Yes,
BY MR. M.O. ALEXANDER:
M.O. Alexander.
I'd like to know -- under your
proposal, you're going to pump the water out of the
lagoons into the waste treatment plants, all right.
Wha~'s going to happen to these heavy metals when
they get into the plant?
Now, we're aware that DHEC
requires Western Carolina to remove phosphates and
. had to spend hundreds of thousands of dollars.
Has
then been followed through?
What is going to happen
to those metals?
Are they going to be diluted to
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1
2
the point that they're not hazardous or are they
going to be removed?
What's going to happen to them
3
4
when they go into the waste treatment plant?
That's
my conc.ern.
5
6
BY MR. ZELLER:
Okay.
I can answer that.
I might want to refer
7
that to Bill Stephens at RMT.
They've actually had
8
9
the negotiations with Metropolitan Sewer District
and Western Carolina Sewer Authority.
I can gener-
10
11
ally answer your question.
The Metropolitan Sewer
District and Western Carolina Sewer Authority, have
actually regulations, like you said, they are moni-
13
tored by the state of South Carolina, Greenville
County, and Metropolitan Sewer District, they all
have their rules that they're under, too.
Okay.
16
17
They have actually what they call influent, what's
coming into the system, influent criteria, what they
18
19
call pre-treatment standards, okay.
They have their
criteria.
Now, if it exceeds that, it needs to be
20
pre~treated before it's actually dumped into the
POTW, into the sewer line, okay.
21
22
23
Now, based on the assumption if you meet their pre-
. treatment requirements, meaning that you do not need
24
25
pre-treatment, it will go on to the sewer line and
Metropolitan Sewer District will treat that to meet
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80
1
all their requirements, okay.
So at that time, they
2
3
are going to handle it.
It .will be treated in their
treatment system to meet their requirements and will
4
5
inevitably be treated and discharged.
So it will be
-- comply with all ARARs.
Is that essentially what
6
your discussions are based on, Bill?
,
BY MR. STEPHENS:
(Affirmative gesture).
8
9
BY MR. M.O. ALEXANDER:
I still have a little concerr. about it.
It may be
BY MR. ZELLER:
Yeah.
I can understand, but that's -- they're es-
sentially under the same rules and regs that we are,
okay.
If we wanted to -- if EPA wanted to go out
there and discharge the stuff into the unnamed
stream, okay, we would have to meet those 'require-
menta, what they call an actual MPDES discharge,
okay.
And that actually is issued by the State of
Sou~h Carolina.
And there's actually very, very
rigorous requirements to meet that.
But, no, we are
actually -- we would be under the same requirements
. that anybody would be under.
BY MR. ROGERS:
I mean, those standards are applied across the board
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to anybody discharging to the treatment plant, in-
eluding all of your iridustries.
That's really what
3
has generated the development of those pre-treatment
standards, because industry on a daily basis dis-
4
S
charges to those same plants and there has to be a
pre-treatment scheme to make sure a significant
6
7
level of the contaminant is removed before the re-
8
9
sulting water is discharged to the sewage treatment
plant.
BY MR. OWEN:
10
1 1
Where will that pre-treatment take place?
BY MR. ROGERS:
12
13
Well, if it were needed, it would be done on the
site.
BY MR. OWEN:
Okay.
I'm satisfied.
BY MR. CALVIN GUIGER:
How is pre-treatment brought about?
BY MR. ZELLER:
I wc;>uldn't ---
BY MR. CALVIN GUIGER:
Explain pre-treatment, if you would.
BY kR~ ZELLER:
Okay.
Pre-treatment, okay, means that Metropolitan
Sewer District has a regulation say for -- let's
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just say for lead, let's just throw out a number.
We're just call it 50 units, okay, parts per mil-
3
4
lion.
Say it's 50 parts per million, okay, just 50
units of concentration.
We have detected, in that
5
6
water, that we have 60, okay.
That is an exceedance
7
of their requirement, which means we need to treat
it to at least 50, preferably below, before we can
8
9
actually discharge it into POTW.
In this case, we
have found that all levels of contamination there
are well below their level 50.
BY MR. GUIGER:
But let me stop you for a minute.
You're not saying
pre-treatment, you're saying reduce it and then it's
going to the facility?
BY MR. ZELLER:
That's pre-treatment essentially.
What I'm saying
is, if we were in exceedance of their actual re-
quirements of their number, of, what, 50, the number
I was using, if we were at 70 we would have to pre-
treat that stuff on site some way by using standard
.
engineering practices that are -- have been utilized
now for many years in water treatment plants, okay,
. who have to treat that stuff to less than 50 before
we actually put it in that sewer.
BY MR. GUIGER:
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I think the general public would call it pre-
treatment, dissolve it, or disposing of these met-
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also
And that's -- you're confusing ---
BY MR. ZELLER:
S
6
That's essentially what we're doing.
We're taking a
certain amount of contamination out of there so we
,
can and we are in compliance with their pre-treat-
ment program.
8
9
BY MR. STEPHENS:
Craig, if I could just clarify something.
BY MR. ZELLER:
Yeah.
BY MR. STEPHENS:
If you turn to Page 4 of the tan handout, the book-
let, and look at Number 5 on the right-hand column
of Page 4.
It talks about the concentrations of the
constituents that's been found in the lagoon water.
And what we find, really are the only constituents
of concern there are cadmium and chromium.
Cadmium
is just a little under two times the drinking water
standard or what's called an MCL, Maximum Contami-
nant Level, and chromium is somewhere between two
. times and about five times the drinking water stan-
dard or what's called.the MCL.
That's way below the
Hazardous Waste Criteria.
The Hazardous Waste Cri-
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teria is a hundred times the drinking water 8tan~
dards, so first of all it would be -- you want to
3
4
compare that to Hazardous Waste Standards it's way,
way below.
Secondly, I don't think these are at
5
6
levels that Western Carolina would require pre-
treatment anyway.
7
BY MR. GUIGER:
Has Mr. Pappas agreed to this?
8
9
BY MR. STEPHENS:
As pre-treatment criteria?
BY MR. GUIGER:
Run by the ---
BY COURT REPORTER:
Excuse me.
I can't hear more than one person at a
time.
I can't hear you.
16
BY MR. STEPHENS:
We have talked with Western Carolina have seen these
data.
I'm sorry.
BY THE COURT REPORTER:
I didn't hear the comment or you.
BY MR.
GUIGER:
I just asked if Mr. Pappas who is the manager of
. Western Carolina has agreed to this plan that you
have here.
BY MR. STEPHENS:
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Yeah.
We've talked with, not Mr. Pappas, but the
people -- his people at West~rn Carolina and also
the people at the Metropolitan Sewer District, gone
3
4
over the data with them and they're in agreement.
5
6
BY MR. GUIGER:
Well, Mr. pappas is the one I'm really concerned
7
with.
I would like to know that he is the one that
8
9
approved this, because he's the one that has the
technical know how there at Western Carolina and
I've always relied on him.
BY MR. ROGERS:
Of course, it would never be carried out, until. the
appropriate approvals.
And this is basi~ally a
preliminary finding in discussions with those people
15
who -- for that alternative.
And it certainly would
have to be approved by the authority before it was
done.
18
19
. BY MR. ZELLER:
Yes, sir?
BY MR. JOHN STEVENSON:
.
I'm John Stevenson.
You mentioned earlier that you
said at no time would a residential development ever
. be on this property.
I'm, again, thinking of the
long-term use.
Will anything ever be on this prop-
erty?
Will there ever be a Bi-Lo on this property
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or will it always -- within that easement will it
always have nothing on it?
3.
BY MR. ZELLER:
Will there be a softball field, or a gold course
4
5
driving range, that kind of stuff?
6
BY MR. STEVENSON:
Anything.
7
8
9
BY MR. ZELLER:
Kevin, how would you handle that in a situation like
-- I don't actually know the -- Jan?
I mean,
there's ---
BY MR. ROGERS:
It's an unanswerable question.
BY MR. ZELLER:
Yeah.
BY MR. ROGERS:
17
I mean, the reality of it is, we're going to put
severe constraints on that property so that some-
thing improper, as we view it today, doesn't happen.
It doesn't mean that we won't develop some theories
.
down the road on a viable way to make use of that
22
23
property for some purpose.
Rest assured it's proba-
. bly never going to be residential inhabitants.
But,
you know, as we saw in the seventies, the agencies
came up with ideas on reclaiming landfills.
We were
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going to put ball fields and other recreational
facilities on top of them.
They're doing that in
3
Florida today.
There's a number of those things
4
that -- not everything has to be residential.
There
S
6
are potentially other uses.
So it's an unanswerable
question in that those things have yet to be devel-
7
oped, because right now the big concern over any NPL
8
9
. site is legal liability.
Nobody in their right mind
would touch it from any prospective, because it has
the connotation that it was hazardous, therefore,
will always be hazardous.
And, you know, those
things have yet to pan out in the development and
implementation of the Superfund Program.
I think
sooner or later people will come to the realization
that, yes, these sites are being addressed, they are
safe, and there can probably be some constructive
ways of utilizing the property versus leaving it
totally without.
But there's going to be some very
serious constraints on it and we're going to do it
by ~eed restrictions and deed notations and other
methods to make sure that it can't change ownership
without people being very aware of what they're
. getting into.
BY MR. STEVENSON:
Okay.
Thank you.
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BY MR. ZELLER:
Yes, sir?
3
4
BY MR. JOE SMITH:
Joe Smith.
I own the property where the unnamed
S
6
stream runs through.
And I just want to know what
7
kind of assurance can you give us for prospective
buyers if I decide to sell my house that it is --
8
9
this property is safe, that my property is safe?
BY MR. ZELLER:
As far as actual assurances, you know, EPA -- this
is a big issue at Love Canal and EPA went in there
and said -- probably the most known site, this site-
in history -- where EPA went out there and we cannot
actually make that assurance.
We can go in there
and actually actively do something, but the best
thing to -- i! you were to show a prospective buyer
17
that you wanted to sell your house and say, 'here's
18
19
the samples that were collected.'
Show them the
actual clean samples, okay, what we call background.
Show them background, show them the levels that were
.
collected from the stream and if they're not elevat-
ed then that's -- basically there has been no effect
. to that unnamed stream.
And we have seen that all
throughout that unnamed stream that there has been
no,. what they say, statistically significant in-
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crease of contaminants.
That we have not seen any
effect whatsoever on the streams.
So that's, I
3
4
guess, my assurance that I can tell, I guess, just
let the. numbers speak for themselves, is about the
5
6
assurance that I can give you.
And I think that's
assurance enough actually, because we did look at
7
it.
Now, we expected that there might be some im-
8
9
pact there, but that wasn't the case at all and it
was a pleasant surprise, believe me.
BY MR. RON CLYDE:
Could Joe Smith and myself have access to that data?
BY MR. ZELLER:
Sure.
BY MR. CLYDE:
Is it a part of the public record now?
BY MR. ZELLER:
. Yeah, yeah.
It's actually in the appendices of the
RI.
Actually it's -- I think it's actually in Ap-
pendix I of Volume II of the Remedial Investigation.
It's all in there.
Actually it'll show you -- they
.
have background concentrations.
And you can your-
self, just like we do, we sit there and we say -- as
. a part of every investigation you want to try and
obtain a clean sample, get some place where there
wasn't any waste disposal activities, take a clean
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water sample and say, 'this is what we call back-
ground. '
Okay.
Background i~ going to vary from
3
4
South Carolina to North Carolina to California just
given the nature of the soils and the water that are
5
6
there.
But -- and just do what we do, we look at
that and if there's no elevated concentration that
7
8
leads us to believe that has not been affected.
And
that -- yeah, that information is readily available.
No problem.
BY MR. DALE BIRK:
Dale Birk.
If DHEC denied the permit for Buck Price
to stop using those lagoons as a dumping site in
1975, and then they stopped anything in '78, most of
those lots along the affected areas were not sold
until after that time, why weren't the residents who
bought those lots notified that there was a pot en-
tial problem?
And, number two, were any of the well
water sampled or people that were along wells, say
along Adams Mill Road or areas close to the site,
and what was the findings there?
BY MR. ZELLER:
Question two, RMT can probably handle as far as the
. well question 90es.
As far as well waters in that
area, actually ---
BY MR. STEVE WEBB:
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Well, the ground water flows in a direction away
from Adams Mill Road.
It doesn't even flow in a
3
direction towards that road.
4
BY MR. ZELLER:
5
6
It flows to the north, northwest there actu-
And I guess your first question, it's been a
Yeah.
ally.
7
8
I think everybody reads about that
serious concern.
in the paper these days and I think everybody can
sympathize.
I mean, everybody has a story about --
in Georgia there was a lady that actually bought a
house and then sooner or later she was -- she found
out she had barrels of hazardous waste on it.
She
bought the property for like l50,OOO.
The county
came back out and appraised her value at $10,000,
you know, that case.
And, fortunately, this hasn't
happened here.
Fortunately that hasn't been the
17
Why the citizens were not informed -at that
case.
point in time I can't actually address that.
I
don't actually know what our liability is on that.
Jan~ you could probably elaborate further on that.
BY MR. ROGERS:
You have to look at the evolution of the environ-
. mental programs.
The program that really denied
that permit to him was the RCRA Program, which deals
with the generation and disposal of waste from ac-
.
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tive operations, treatment and disposal.
And there
are laws passed in '76.
It took them a few years to
3
4
get some guidance out and policy.
You're talking
about the early stages of the whole environmental
5
6
program and hazardous waste.
I mean, EPA didn't
exist until 1970.
I think what you see is they
7
denied him a permit because it became obvious that
he was doing things improperly, but there was no law
8
9
available for them to do much else about it.
There
10
are laws on the books, on the state books today,
there's federal laws today that create a lot of
11
12
liabilities, but it's took quite a while for those
laws to develop and pass through the appropriate
13
14
legislative groups-
Superfund didn't exist until
15
16
1980.
It basically got passed very quickly over the
realization in '78 and '79, that the Clean Water Act
17
and other laws did not really address the improper
18
disposal of hazardous waste on ground, and the im-
19
pact on subsurface drinking water.
Most of the laws
20
21
of those days dealt with spills to surface water.
.
Superfund really had to be refined in 1986.
It got
22
23
an extremely slow start, for a number of reasons and
. it has evolved over the last ten years.
There had
24
25
to be a lot of development of, how clean is clean,
risk assessment methodologies that the toxicologists
.
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disagree on, that really would be appropriate to
even determine what the level of risk was.
That
3
4
didn't exist in the early '80s, in as far as any
consensus of agreement.
So you've seen a long evo-
5
6
lution, and that's frequently a question from a lot
of people, 'if there are regulatory groups out
7
there, why didn't they tell me?'
It's hard to say.
8
9
That's one of the reasons why you see a strong em-
phasis toward institutional controls in most of the
remedies, to make sure that if there's any kind of
concern notations are made in deeds, other things
are done, to warn people, such as the system doesn't
necessarily have to warn them.
But I don't think
that's going to solve your problem with the people
who live next to it.
Total, that's a problem that
is out there that I don't know that anybody knows a
good answer.
BY MR. ZELLER:
I guess to further address your question, the second
par~ of your question with the wells, actually there
was a survey done of -- all water wells are recorded
with DHEC, the South Carolina Department.of Health
. and Environmental Control, and those are all record-
ed, and there was an actual survey of the neighbor-
ing residents.
The only one that actually was indi-
.
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cated was this house here on the east side of the
property.
It showed that the well was actually 400
3
4
feet in depth, which is very, very, very deep.
Most
of our wells out there -- which is severely into the
5
6
bedrock out there.
Bedrock starts about 60 to 70
feet on the average across the site, a low ground
7
surface.
And the contamination in the ground water
8
9
we did find wasn't even -- it was actually in what
they call a shallow saprolite well, 30 to 40 foot
deep, and, again, it's what we call upgrading of the
site again.
Here's the source area and basically
the ground water contamination is flowing in this
direction (indicating).
We have shown that through-
out the RI.
There would be every reason to believe
that that well is not contaminated in no way shape
or form.
In fact, not at least from this site, for
that instance.
The actual contamination of the
source is here and it's moving in this direction and
I guess your question, Adams Mill Road, again it's
here and then as Steve pointed out, that if there
are any wells in that area, our survey did not indi-
cate that, but -- so ground water moving that way,
. given the data that we have is, would not be a ---
BY MR. STEPHENS:
We also have the spring.
.
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BY MR. ZELLER:
Excuse me?
3
4
BY MR. STEPHENS:
We got a sampling of the spring.
5
6
BY MR. ZELLER:
And we also have a sampling of the spring which Mrs.
Rice still gets her water out of, and it was clean
7
8
throughout.
Is there any other questions we can
answer?
Mr. Paxton.
BY MR. PAXTON:
Craig, the -- I'd like to ask if it's possible that
we could have provisions in the ROD to address "new .
and emerging technology.
As I understand the ROD,
today it's virtually impossible once the decision is
made to address a different technology irrespective
of how great it might be when the time comes up.
BY MR. ZELLER:
We're very interested in hearing what this -- the
new and innovative technology that you may have.
We'll be very receptive to that.
If we could get it
.
actually in written description of what you have in
mind, we have actually a Technology Innovation Of-
. fice that's headed up by Walter Covalick that actu-
ally reviews that stuff.
I don't know if you've
been given that name.
And actually, there's a part
.
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of that program -- it's also referred to what they
call the Site Programs to provide innovative tech-
3
And that's -- that's all referred and han-
nology.
4
5
dled in that case.
I'll be happy and ---
6
BY MR. PAXTON:
Again, if it's not -- that provision is not in the
7
ROD, it cannot be considered, as I understand it.
8
9
BY MR. ZELLER:
Provision in a ROD.
BY MR. ROGERS:
Ed, I don't know that there's any history on
that.
You can philosophize about it, but the
thrust of the program is, the program has to go
forward and implement solutions at these sites.
Part of the process is getting toa Record of
Decision, going through design, and getting
into construction.
You have to make your deci-
sion based on the best available information
today and, you know, you and I have talked be-
fore.
I know there's a lot of vendors out
.
there working on a lot of things, and there
will be some good ideas coming forward in the
. future.
There will also be some good ideas
that don't pan out.
The agency has set up a
system to evaluate those kinds of systems, to
.
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validate whether they have any potential and
what the limitations might be.
And as they get
3
4
through that process, they're made available to
us.
I would say, if we get down the road into
5
6
design, and some innovative"method came up that
had a significant improvement over a lot of the
7
considerations, and I would guess one of the
most significant ones might be cost, as well as
8
9
-- I don't know how you can get that much bet-
10
ter in protectiveness than some of the other
1 1
remedies, but it would have to be evaluated and
12
13
see what the potential was.
And I mean, if it
14
was that good I think the agency, the responsi-
ble parties, and anybody else would be willing
15
16
to entertain it, realizing that it would have
to stop.
Everything would have to be done
17
over, not everything, but a lot of things would
18
19
have to backtrack or start over.
That's not
really what Congress wants us doing.
They want
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us ~o implement these remedies and go forward
and as the other things become available we
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will consider them and implement them.
So I'm
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. not -- I'm just saying, historically there is
no history to be able to tell whether a change
could take place.
But there is no ability to
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write. that into a Record of Decision.
BY MR. PAXTON:
My purpose for asking that question is just simply
this, this is a Public Meeting to take comments.
BY MR. ROGERS:
Yes.
BY MR. ZELLER:
Yeah.
BY MR. PAXTON:
Yet, at the same time, we are -- our comments are
being directed to eight alternates or whatever the
number is and those eight alternates, are basically
alternates which have been presented by the drafter
of the RIFS.
The public needs to have some way to
put input and perhaps areas to reserve.
BY MR. ZELLER:
No. That's -- this is the mechanism that we would
entertain, though, suggestions at this point in
time.
BY MR. P~TON:
Then the advertisement in Sunday's paper which basi-
cally says that comments will be accepted -- if I
. can pull it out here ---
BY MR. ZELLER:
I believe the correct wording on that, I wrote that
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article, and actually I believe the correct wording,
that the EPA representatives wi~l be available to
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answer any questions on the alternatives considered,
the pre'ferred alternative, and any other concerns
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the citizens may have relevant to the cleanup of
this site, something to that nature.
7
BY MR. PAXTON:
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Well, if it -- the wording that' I am referring to,
it says, "After review of the information, if you
would like to comment on the preferred alternate or
any other cleanup alternate under consideration."
The word "under consideration" precludes you accept:
ing a ninth or tenth alternate?
BY MR. ZELLER:
True.
That's what I meant by any other con-
Yes.
cerns.
BY MR. PAXTON:
50 any input from the public is meaningless?
BY MR. ZELLER:
Now, Mr. Paxton, that's not what that means.
Actu-
.
ally what that ---
BY MR. PAXTON:
. That's what it says.
BY MR. ZELLER:
We are very receptive to any information, as Jan has
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reiterated, to any information that i8 relevant, not
only to the eight alternativ~s that were under con-
sideration, the preferred alternative, but also any
other concerns that might be relative to clean up
this site, and that includes a ninth or a tenth or
eleventh alternative.
We are very receptive.
I
mean, the environmental arena, as it is now, is
developing, constantly developing, new information
is being discovered every day.
The PCB issue, the
Quick Line handles PCBs.
I'd like to draw the com-
parison to that -- it's an evolving technology.
'You
know, we would be -- it would be actually a disre- .
gard for knowledge and information iftheEPA said,
'no, we're not going to listen to you, we're going
to go on in a tunnel vision sort of way.'
That
would be just a blatant disregard for technology and
science.
It's constantly developing and that's what
we're here to do, is actually receive any comments.
And if you have some suggestions, the way we handle
that is I would like to see it in paper. I'm very
.
interested, and actually I'd like to hear what
you're ninth alternative would be.
I'm just ---
BY MR~ PAXTON:
I wasn't offering an alternative.
I was just asking
if it could be left open.
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BY MR. ZELLER:
Sure.
There are -- I'm very, very curious.
Okay.
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If you have some comments or some other alternative
that should have been considered you feel, we're
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very receptive to that.
I would like to see it in
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writing.
BY MR. PAXTON:
I encourage you to do that.
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That was why I was asking if we could get a second
30 days extension on time.
BY MR. ZELLER:
A second one in addition to the first one?
BY MR. PAXTON:
If we need it.
BY MR. ZELLER:
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I don't know how that's actually handled.
The way I
believe it's actually just the 60 day comment peri-
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ode
BY MR. PAXTON:
There is a better way.
There's better technology.
It can be done.
.
BY MR. ROGERS:
There is a process.
The process is there's a 30 day
. comment period, there's pretty much a routine 30 day
comment period, and then the Agency will make a
determination whether there is reason to grant any
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And that will not be based on a vendor making
more.
claims that mayor may not be substantiated.
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BY MR. PAXTON:
But, Jan, let me ask you a question.
How did you'-
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all come -- how did you arrive at a decision to take
these comments or these alternatives you've got
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here?
Now, somebody presents technology to you,
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correct?
BY MR. ROGERS:
No.
BY MS. ATKINS:
No, sir.
BY MR. PAXTON:
How did you do it? .
BY MR. ROGERS:
Basically, the information coming out of the Sites
Program on various technologies, based on past expe-
rience, based on a number of things that have al-
ready been done in the field.
BY MR. PAXTON:
Does TCLP tests, do they mean anything to you peo-
ple, the results of those?
BY MR; ROGERS:
Well, you know they do.
BY MR. PAXTON:
.
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TCLP tests, results I'm talking about.
BY MR. ROGERS:
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Yes.
BY MR. PAXTON:
Would you like to look at some after this meeting?
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BY MR. ROGERS:
Well, I mean, let's let the public deal with other
7
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questions.
I mean, I know where you all are coming
from and you've given us nothing., and you're asking
for delays with unsubstantiated ---
BY MR. PAXTON:
Well, I'll bring you some.
BY MR. ROGERS:
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We've given you the opportunity to submit comments,
to submit whatever, and they will be addressed in.
16
the Responsiveness Summar~ that will be included in
the ROD, and they will be addressed accordingly for
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whenever we receive it.
BY MR. PAXTON:
Jan, that's why I asked for the second 30 days.
I
.
think it's going to take longer than 30 days to get
a demonstration done at EPA in Cincinnati.
And
. that's what I'm asking about.
BY MR. ROGERS:
Oh, I guarantee you it's going to take longer than
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that. .And it's going to take longer than that to get
any kind of substantiated results.
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BY MR. PAXTON:
That's why I'm asking for the second 30 day period.
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BY MR. ROGERS:
You're not going to get it for that.
You will get
,
one extension and then the agency will make a deter-
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mination based on request.
And when the request
comes in, we'll make that determination.
But that
is not high on the criteria for granting it.
11
BY MR. ZELLER:
We'd encourage you -- I mean, if you're talking TCL~
results and something that is a part of a technology
that you might have in the back of your mind, we
encourage you to submit that now.
The 30 day com-
16
That's our
ment period is essentially for that.
l'
ninth criteria, our ninth and last one.
And it is
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just equally as important as one through ---
BY MR. PAXTON:
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Who, you people?
.
BY MR. ZELLER:
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Yes, to me.
BY MR. PAXTON:
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That's fine.
That's what I'm getting around
Okay.
to.
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BY MR. ZELLER:
Yes.
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BY MRS. JERRY CAMPBELL:
In writing.
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BY MR. ZELLER:
Send it to me in writing.
I have a card here that
7
you can send it ---
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BY MR. PAXTON:
I might can get something for you to fix it there,
Craig.
BY MR. ZELLER:
Okay.
No problem.
Is there anything else that we -
can address at this point in time?
Going once, twice -- we'll be around here for as
long -- we'll stay out here and talk to you as long
as you want to.
Appreciate you coming out.
(CONCLUDED AT 9:15 P.M.)
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state of South Carolina
County of Greenville
This is to certify that the within Public Hear-
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ing was held on the 20th day of June, 1991;
That the foregoing is an accurate transcription
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of the said proceedings;
That no exhibits were entered herein or made a
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part of this record;
That the undersigned court reporter, a Notary
Public for the State of South Carolina, is not an employ-
ee or relative of any of the parties, counselor witness
and is not in any manner interested in the outcome of
this action;
IN WITNESS WHEREOF, I have hereunto set my Hand
and Seal at Greenville, South Carolina this 28th day of
June, 1991.
tO~
Commission expires: 1-10-2001
(SEAL)
.
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