United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R04-87/030
September 1987
SEP A
Superfund
Record of
Independent Nail, SC
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TECHNICAL REPORT DATA
/Please read Instructions on the revene bef~e co,""letlnl)
,. REPOAT NO. r. 3. ReCIPleNT'S ACCESSION NO.
-~~/ROD/R04-87/030
TLE ANO SUBTITLE 5. REPORT OATe
SUPERFUND RECORD OF DECISION September 28, 1987
Independent Nail, SC 8. peRFORMING ORGANIZATION cooe
First Remedial Action
7. AUTHORCSI 8. PERFORMING ORGANIZATION REPORT NO
9. peRFORMING OAGANIZATION NAME ANO AOORess 10. PROGRAM ELEMeNT NO.
". CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME ANO AOORess 13. TYPE OF REPORT ANO PERIOO COVEREO
U.S. Environmental Protection Agency Final ROD Report
401 M Street, S.W. ,.. SPONSORING AGENCY COOE
Washington, D.C. 20460 800/00
15. SUPPLEMENTARY NOTES
18. ABSTRACT
The Independent Nail Company site, occupying 24.6 acres, is located near Beaufort,
South Carolina. Land use in the vicinity of the site is a combination of fields,
woodlands and wetlands. Endangered and threatened species may occur within the area of
.
~'1fluence of the site, although habitation has not been confirmed. The previous owners
the site, the Blake and Johnson Company, manufactured metallic screws and fasteners.
A.S part of the manufacturing process, the company discharged approximately
33,000 gallons per day of plating wastewater into an unlined infiltration lagoon. The
lagoon was in use from approximately 1969 to 1980. The South Carolina Department of
Health and Environmental Control (SCDHEC) reported that the wastewater contained some
organic cleaning solvents, phosphate, cyanide, chromium, cadmium, lead, mercury, nickel,
zinc, copper and iron. In April 1980 the Blake and Johnson Company ceased operation.
Two months later the Independent Nail Company purchased the plant. They currently
operate a paneling nail coating process at the plant, but do not discharge any
wastewater to the lagoon. The primary contaminants of concern to the soil and sediment
include: cadmium, chromium, nickel and zinc.
The selected remedial action for this site includes: excavation of contaminat~d soils
and lagoon sediments; solidification/stabilization of excavated soils and sediments
(6,200 yd3); placement of treated soils and sediments back into the excavated lagoon
(See Attached Sheet)
17. KEY WOAOS AND OOCUMENT ANALYSIS
a. OESCPlIPTOAS b.IOENTIFIERS/OPEN ENOED TERMS C. COSATI Field/Group
Record of Decision
Independent Nail, SC
First Remedi~l Action
Contaminated Media: soil, sediment
Key contaminants: chromium, other heavy meta s
OISTRIBUTION STATEMENT 19. SECURITY CLASS (Tills R~ponl 21. NO. OF PAGES
None. 55
20. SECURITY CLASS (Tills pa'~1 22. PRICE
. None
Eft. POI'" 2220-1 (Re.. .-77)
,"".VIOUS ItOlTION IS 08S0L.I:TI:
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EPA/ROD/R04-87/030
Independent Nail, SC
. First Remedial Action
16.
ABSTRACT (continued)
and cover with 6 inches of top soil and seed. The estimated capital cost for this
remedial action is $1,032,000 with annual O&M of $22,500 for years 1-2 and $5,600 for
. years 3-30.
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DECLARATION FOR THE RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
Site:
Independent Nail Company
Beaufort, Beaufort County, South Carolina
Statement of Purpose:
This decision document represents the selected rem~dial action for this Site
developed in accordance with CERCLA as amended by SARA, and to the extent
practicable, the National Contingency Plan. The State of South Carolina
concurs with the selected remedy.
Statement of Basis
This decision is based upon the administrative record for the Independent Nail
Company Site. The attached index identifies the items which comprise the
administrative record upon which the selection of a remedial action is based.
Description of Selected Remedy:
* This is Operable Unit One of the Remedial Actions to be undertaken at
the Site. It is a source control measure to mitigate the threat of
off-site migration (via air pathways or groundwater) of metals
contamination. The RI/FS for groundwater (Operable Unit Two) is currently
underway.
* Soils/Lagoon Sediments
- Excavation of contaminated soils and lagoon sediments.
- Solidification/stabilization of excavated soils and sediments.
Baekfilling of excavated lagoon sediments with a bottom layer of clean
soil. .
- Return of treated soils and sediments to the lagoon at a level of
approximately two feet above the high groundwater table.
- Vegetation cover of top soil and grass seed over treated material.
- Based on the Endangerment Assessment performed for the site, this
remedy would entail treatment of a total of 6200 cubic yards_gf
soil/sediments to achieve a lifetime cancer risk level of 10 or
less.
Declaration
The selected remedy is protective of human health and the environment, attains
. Federal and State requirements that are applicable or relevant and appropriate,
and is cost-effective. This remedy satisfies the preference for treatment that
reduces toxicity, mobility, or volume as a principal element. Finally, it is
determined that this remedy utilizes permanent solutions and alternative
treatment technologies to the maximum extent practicable.
I have also determined that the action being taken 18 appropriate when balanced
against the availability of trust fund monies for use at other sites.
rit)?
~_? f!1.t-~ JjD
Lee A. DeHihns III
Acting Regional Administrator
Date
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
INDEPENDENT NAIL COMPANY SITE
BEAUFORT COUNTY, SOUTH CAROLINA
Prepared By:
U.S. Environmental Protection Agency
Region IV
Atlanta, Georgia
,"
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2.0
4~0
5.0
6.0
7.0
8.0
TABLE OF CONTENTS
Page
1.0
Introduction[[[01
Site
History[[[06
3.0
Site Contaminants..................................................09
Endangerment
Assessment............................................10
Enforcement Analysis...............................................17
Community Relations History........................................17
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Figure 1-1
Figure 1-2
Figure 1-3
Figure 1-4
Figure 1-5
Figure 3-1
Figure 3-2
Table 3-1
Table 7-1
Table 7-2
Table 7-3
LIST OF FIGURES & TABLES
Page
Location Plan...............................................02
Area Hap.................~..................................03
Drainage Map................................................04
Contour
Hap.................................................07
Area Topographic
Map. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .08
Soil Sample Locations Within the Fence......................11
Soil Sample Locations Outside the Fence.....................12
Detected Concentrations of Metals in Soil and Sediment......13
Summary of Soil Cleanup
Goals...............................19
Technologies Considered for Screening.......................21
Preliminary Cost
Es t1mates. . . . . . . . . . . . e.. . . . . . . . . . . . . . . . . . . . .22
ATTACHMENTS
Attachment 1 ~.....................................Responsiveness Summary
Attachment 2 - ......................................Administrative Record
Attachment 3 -
..............................State's
Letter of Concurrence
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RECORD OF DECISION
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
INDEPENDENT NAIL COMPANY SITE
BEAUFORT COUNTY, SOUTH CAROLINA
1.0 Introduction
The Independent Nail Company Site was added to the National Priorities List
(NPL) in September 1984. Thus far, Operable Unit 1 of the Independent Nail
Company Site has been the subject of a remedial investigation (RI) and
feasibility study (FS) performed by the Region IV REM II Contractor, Camp,
Dresser & McKee, Inc. (CDM). No monitor wells were installed to keep the costs
for the study within the predefined limit. Operable Unit 2, a RI/FS for
groundwater, is currently underway. The Operable Unit 1 RI Report, which
examines s01l and sediment contamination at the site, was 1ssued June 8, 1987.
The FS, which develops and examines alternatives for remediation of the site,
was issued in draft form to the public on July 27, 1987.
This Record of Decision has been prepared to summarize the remedial alternative
selection process and to present the selected remedial alternative.
Site Location and Description
The Independent Nail Site 1s located near Beaufort, South Carolina on South
Car~lina State Route 86, 3,200 feet west of Highway 21 (Figure 1-1 and Figure
1-2). The Independent Nail Company property occupies 24.6 acres. The site is
located at latitude N 32 -degrees 80'00" and longitude W 80 degrees 44'30" and
at N-230,750, E-2,079,500 based on the South Carolina Coordinate System, South
Zone. The area is rural with some light industry. Several residences are
located near the site on South Carolina Route 86. The old Beaufort County
Landfill is located near the site to the west. The U.S. Marine Corps Air
Station is located east of the site across Highway 21. Kalama Specialty
Chemicals was once located approximately one half mile north of the site. The
company is no longer in operation. The town of Beaufort, South Carolina is
approximately three miles to the southeast. Savannah, Georgia is approximately
40 miles to the southwest. It is estimated that less than 25 people live
within one quarter mile of the site.
Land use in the vicinity of the site is a combination of fields, woodlands and
wetlands. Major surface waters with associated wetlands are located within 1.5
miles south of the site. The nearest surface waters are Mulligan Creek which
is approximately two miles to the northeast and Salt Creek which is located
approximately 1.5 miles to the so~th. Salt Creek may not be in the drainage
path (EPA, 1983). A drainage map is shown on Figure 1-3.
Single family residences are located south of the site along South Carolina
Route 86. The largest residential development in the area is the Laurel Bay
Naval Housing Area located approximately three miles to the west.
Small commercial areas are located north and south along Route 21 in the
vicinity of the towns of Grays Hill and Burton, respectively. Several small
industries are also scattered around the area. Agricultural lands are found in
the surrounding area. An old borrow pit is located to the- north.
The U~S. Fish and Wildlife Service (1987) indicated that endangered and
threatened specie~ may ol:cu:r_11n. _the are;t. Qf In£l~eqs:e Qf 1;ne Independent Nait
Company Site. These species are the West Indian maftatee, bald ~agle, -
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.-
! .
I
I
I
I
.-2-
LOCATION
PLAN
N
116
IDOO
---
-- -
o
800 1000
__1000 PaT
. LOCATION
~NDEPENDEN PLAN
. - 8EAUFOR~ NtlL CO. SITE
. . .CAROLINA
I-I
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.AREA MAP
JNDEPENDENT NAIL. .CO. SITE
BEAUFO.RT, S. .CAROLINA .
-3-
."
~
o 50 100 150 200 2$0
ICAL£ IN FaT
..
i .
I
. - .
N
FIGURE NO.
1- 2
-
.- . . ~
- ~
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-4--
~
---
~-'e--- .
~~.:.-.-
.~
-- -
.-..._- ..
.-.- --.
- - -
.- ,.- ----
~"'~-.:...
--~-~
:-:.-:=.
- - --~-..._.. -:..~ ....-
..-.e~:- -:..- .=..~
~_. -=..~.~.
--~-
~J-.
.~~
=~
---
& -
~-
.-;:.
~~:
.'
!' ..... -.
~
.
MILES
~ WETLANDS
SOURCE: USGS, "78
FIGURE NO.
DRAINAGE MAP
INDEPENDENT NAIL CO. SITE
BEAUFORT, S. CA~OLINA
1-3
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-5-
wood stork aDd Artie peregrin falcon (endangered) and the American alligator
(threatened). However, these species have not been confirmed to be habitating
areas that may be impacted by the site.
The lagoon is presently inactive and is surrounded by a fence. Rain water
collects in the lagoon. The topography of the site is such that precipitation
which may come in contact with contaminants does not run off. The water level
in the lagoon varies at different times of the year depending on the level of
the ground water table. The Independent Nail Company plant is directly south
of the lagoon. .
The areas to the north, east and west are wooded. The old Beaufort County
landfill is located to the west and northwest. A Seaboard Coast Line Railroad
spur parallels the site to the east.
Ground water is an important source of water supply in the site vicinity for
private, municipal and commercial use. However, many wells are used only at
times of peak water demand and as backup wells. The Burton Well Field,
. approximately 2.5 miles southeast of the site, is used to handle peak demand
from May through September in combination with Savannah River water. The
Marine Corps Air Station, located east of the site, and the Laurel Bay Naval
Housing Area to the west, rely on wells placed in the deep Floridan Aquifer as
a backup water supply. Because these wells are deep and the ground water flow
through the site is parallel to the air station and housing area, it is
unlikely that these populations would be at risk from any contamination
emanating from the site. . Private homes immediately south of the sit~ are
connected to the municipal water supply, however several have private wells
that are likely used for lawn and garden watering. These wells may be screened
in the water table aquifer. Several industries in the local area also use well
water for their process waters (EPA, 1983).
Other local natural resources include sand and gravel pits and agricultural
land scattered throughout the area.
The topography of Beaufort County consists of nearly level lowland and low
ridges that have slopes of less than 2 percent. The area surrounding
Independent Nail Company Site is at an elevation of approximately 40 feet,
which is the high point of the area (US Geological Survey, 1979). The on-site
land surface slopes from approximately 38 to 40 feet above mean sea level at.
the fence surrounding the lagoon to less than 30 feet at the center of the
lagoon. A topographic ..p of the Independent Nail Company Site is presented as
Figure 1-4. Figure 1-5 shows the topography for the general area based on the
US Geological Survey map for the area.
2.0. Site History
PERMIT AND REGULATORY HISTORY
The Blake and Johnson Company (previous owners of the site) manufactured
metallic screws and fasteners. As part of the manufacturing process, the
company discharged approximately 33,000 gallons per day of plating wastewater
into an unlined infiltration lagoon (EPA, 1983). The discharge may have been
as high as approximately 75,000 gallons per day (South Carolina State Board of
Health and Pollution Control Authority, 1968). The lagoon was in use from
approximately 1969 to 1980. The South Carolina ~epartment of Health and
... . ~ .
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-;
-6-
Environmental Control (SCDHEC) reported that the wastewater contained some
organic cleaning solvents, phosphate, cyanide, chromium, cadmium, lead,
mercury, nickel, .zinc, copper and iron. In April 1980, the Blake and Johnson
Company ceased operation. Two months later, the Indepe~dent Nail Company
purchased the plant. The Independent Nail Company currently operates a
panelling nail coating process at the plant, but does not discharge any
wastewater to the lagoon.
A study done by SCDHEC from May 21 to 23, 1975 revealed that a break in the
side of the lagoon may have allowed wastewater from the lagoon to enter a
drainage ditch located north of the lagoon. Analysis of a sample collected
from this ditch in August 1975 showed cadmium and chromium contamination. The
break and resulting discharge appear to have been a single, short term
incident.
Beginning in August 1975, the state of South Carolina and a local engineering
firm (Davis and Floyd) conducted several ground water investigations. Monitor
wells were placed into the water table aquifer at various locations near the
lagoon. The results of these sampling efforts indicated that the quality of
the ground water was being affected by the wastes discharged to the lagoon.
Chromium, lead, iron, and mercury concentrations were found in excess of
drinking water standards in some of these water samples.
Sampling performed on April 21, 1980 indicated that concentrations of chromium
and lead in the ground water exceeded drinking water standards. The chromium
level in one well was 0.210 mg/l and the lead concentration in another was
0.150 mg/l. A second sampling of the same wells in May 1980 found chromium
levels in two wells exceeding dr~nking wate~ standards. . Lead concentrations
were all below the drinking water standard. The drinking water standard
(Maximum Contaminant Level) for both of these metals is 0.05 mg/l. Later in
May 1980, SCDHEC requested that three intermediate depth (40 to 50 feet). wells
be installed for monitoring. Chromium levels in all three of these wells
exceeded drinking water standards when sampled in June 1980. However, sampling
of these wells by REM II personnel in August 1985 showed no metal contamination
above drinking water standards, based on local laboratory analytical data.
On June 11, 1980, the Industrial and Agricultural Wastewater Division of SCDHEC
sent a letter to Blake and Johnson stating that ground water at the facility
contained "chromium at approximately the concentration of the drinking water
standard. Based on this information, there is little likelihood of finding
serious contamination of ground water". The following day, a letter was sent
by SCDHEC to Independent Nail relating "we have recently completed evaluation
of ground water at Blake and Johnson with favorable results".
EPA became involved with the site on February 26, 1981 with the preparation of
a Potential Hazardous Waste Site Investigation Report and Preliminary.
Assessment Report. In April 1981, a site inspection was undertaken, and as a
result, a Final Strategy Determination (May 18, 1981) stated that "no action
[was] needed" at the site. On November 6, 1981, a SCDHEC interagency memo from
the Ground Water Protection Division stated the seriousness of land disposal
practices in the vicinity of the site due to its location in a major recharge
zone. The memo also stated that the previous SCDHEC letters of June 11 and 12,
1980 were "not consistent with our assessment of the situation".
. .
. .
-
. 10 ~. .
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-7-
C4- JSmgAg
Cr - 77 mtAfl
Ni-aOmgAg
Zn -77 mq/ka
Cd- «5
Cr • 2000 mgAg
Nf. 1800 mflAg
19000 mg/kg
- <9mgAg
Cr-
fl^XisS jL
Ni- 2lmgAg
$pS$;|m •
J&ftSM Vsil-ll
Cfl- <: mg/kg
Cr-130
Ni • 2S
Zn-f7 mgAg
DISCHARGE
C4- <2 mg/kg
Cr - 61
Ni . 20 mg/»9
2n. MO mgAg
Cf - 72 mff/kff /
Ni . 25 maAo /
Zn-230 tuff At
^ LEGEND
* -CLP SAMPLE LOCATION
A -CLP SAMPLE LOCATION with ELEVATED METALS
0 25 SO 100 »50
\
\
SCALE IN FEET
SOIL SAMPLE LOCATIONS WITHIN THE FENCE
INDEPENDENT NAIL CO. SITE
BEAUFORT, S. CAROLINA
FIGURE NO
3-1
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-8-
^x ^ "" •
*=t* \5f-
? .'.^Sl^24 ^v
.
S?fM5:i*«S
A CLP SAMPLE LOCATION with
A" ELEVATED METALS O SO 100
• -CLP SAMPLE LOCATION
—— POTENTIAL DRAINAGE PATH SCALE IN
SOIL SAMPLE LOCATIONS OUTSIDE THE FENCE
FIGURE NO.
3-2
|ND£pENDENT
BEAUFORT, S.. .CAROLINA
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-9-
3.0 Site Contaminants
The several sampling efforts by SCDHEC indicated that metals are of main
concern at the site, particuarly lead, chromium, cadmium, nickel and zinc.
With the exception of lead, this was confirmed by REM II's RI.
Remedial Investigation
The remedial investigation study, conducted from September through November,
1986 determined the presence and extent of contamination in the soil, surface
waters and sediments on the site and in apparent drainage paths near the
lagoon. Samples were taken of each of the media to document the source of
contamination and its boundaries and the extent of on-site and off-site
contamination. Data were collected to characterize the site and support the
analysis of remedial alternatives during the feasibility study.
Soil Data - Soil contamination was primarily found in the lagoon and areas
within the fence and at two areas outside of the fence. Metal contamination,
particularly Cadmium, Chromium, Nickel and Zinc are of concern. Some organics
were found in some samples, however, there was no pattern of detection and
these are not believed to originate on-site. Unidentified compounds and
evidence of petroleum products were also found in numerous samples, again with
no pattern of detection. These compounds may be attributable to military
aircraft which often fly low over the area during take-offs and landings from
the nearby U.S. Marine Corps Air Station or may be a result of off-road
vehicles, truck traffic along Route 86 or from the nearby railroad spur.
Because organics do not appear to be a result of site operations, they will not
be considered for cleanup. '
Vertically, soil contamination was limited to surface samples. Subsurface
samples collected approximately 20 inches below the surface contained
background levels of contaminants. Soil 'was estimated to be contaminated to a
depth of one foot. Confirmatory soil sampling would be performed during the
implementation of a remediation. The depth of contamination in the lagoon
sediments could not be determined since only surface samples were taken.
Surface sediment samples taken from the lagoon are estimated to be contaminated
to a depth of two feet. Confirmatory sampling would be performed during
remediation.
Figures 3-1 and 3-2 delineate the areas investigated where soil samples
contained metals at concentrations an order of magnitude greater than
background. Concentrations of various metals found in the soils on-site
(within the fence) are shown in Table 3-1. The table gives the concentrations
of metals found in sample INC-SL-Ol-l which was taken at the abandoned
discharge pipe, the concentrations of metals in all other samples within the
fence (excluding sample INC-SL-01-1), and the geometric mean for all surface
soil samples taken from within the fence. The ranges of metal concentrations
in the lagoon sediment samples and background soil samples are also given.
Surface Water/Sediment Data - Surface water and sediment samples were taken
from two locations in the lagoon, from a ditch near the old Beaufort County
Landfill and from another ditch surrounding the landfill. The samples taken
from the ditches showed only Zinc in detectable quantities. The levels
detected were well below the secondary drinking water standard for Zinc
~g/l), but above ambient water quality criteria for protection of human
and aquatic life. Samples taken from within the lagoon showed elevated
(5,000
health
levels
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-10-
of Nickel and Zinc.
at 500 and 620 ug/l.
Nickel was detected at 100 ug/l in both samples and Zinc
Sediment samples were taken at the same locations as surface water samples.
Cadmium, chromium, nickel and zinc were detected in all sediment samples.
Maximum concentrations were detected in a sample taken from the lagoon. These
maximum concentrations are show in Table 3-1.
4.0 ENDANGERMENT ASSESSMENT
ICF/Clement Associates, Inc. performed an endangerment assessment for the site
based on analytical results for soils, surface water and sediment. Cadmium,
Chromium, Cyanide, Nickel and Zinc were identified as contaminants of concern.
The primary exposure pathways for these chemicals are in direct contact with
surface soils and the inhalation of airborne contaminated dust.
Toxicity of Contaminants
Brief descriptions of the toxic effects of the contaminants of concern are
given in the following paragraphs. Detailed descriptions and the cited
references can be found in the Remedial Investigation Report for the site
(Document Control No. 237-RI1-RT-EFPL, dated June 1, 1987).
Cadmium - Cadmium is an element of the transitional metal series that occurs
widely in nature, usually in lead or Zinc ores. Elemental Cadmium is insoluble
in water, although many Cadmium-salts are quite soluble (EPA 1985, a,b). The
general human population is exposed to Cadmium in drinking water and food;
cigarette smoke also contains high levels of Cadmium. Additional inhalation
exposure occurs in industrial set.tings (EPA 1985 a, b). .
The toxicology of Cadmium has been reviewed by Friberg, et a1. -(1974), the
International Agency for Research on Cancer (IARC) (1976), and EPA (1980, 1981,
1985b,c). Injection of Cadmium into laboratory animals results in
injection-site sarcomas and testicular tumors of the Leydig cells (EPA 1981).
A relationship between human exposure to Cadmium and cancer of the prostate,
lung, or kidney has been suggested by several epidemiological studies (Thun, et
a1. 1985, EPA 1985b). Cadmium may impair DNA repair, but has not been shown to
be mutagenic. It is a well-documented animal teratogen.
Cadmium bioccumulates in mammals, particularly in the kidney and liver (EPA
1981, 1985c). Epidemiological studies have revealed an association between
nonmalignant pulmonary diseases and inhalation of Cadmium. Renal tubular
disfunction, of which the first .sign is proteinuria, occurs at lower levels of
oral or inhalation exposure to Cadmium and may be the primary defect
responsible for the bone damage characteristic of Itai-Itai disease. It is
also suspected that chronic exposure to Cadmium produces hypertension, anemia,
sensory loss (particularly smell), endocrine alterations, and immunosuppression
in humans.
Cadmium and some of its compounds are known to be carcinogenic in experimental
animals exposed by injection or inhalation, but the carcinogenic effects are
absent when Cadmium is administered 0~al1y (EPA 1985b). It is not known which
cadmium. compounds are responsible for the inhalation carcinogenic effects in
humans.
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-11-
o
noun M
MMI
INOCPCNOCNT NAIL COMMNV
MOFMTY LINC
O SO 100 200
SCALE INFECT
OLD MAUFONT COUNTY LANDFILL
CONTOUR MAP
FI>iUR
1-4
INOEPENDEN.T NAIL CO. SITE
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-12-
AREA TOPOGRAPHIC MAP
INDEPENDENT NAIL CO. SITE
R F ft\ t ?r. RT, 5 f AR f>l IM ft
FIGURE NO.
.1-5
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-13-
TABLE Jr.l-
DETECTED CONCENTRATIO:~S OF METALS
IN SOIL AND SEDIMENT
INDEPENDENT NAIL CDr1PANY SITE
BEAUFORT, SOUTH CAROLINA
..
CONCENTRATION, MG/KG AND FREQUENCY OF DETECTION (#)
RANGE OF
ALL OTHER GEQ."1ETRIC MEAN RANGE OF RANGE OF
SURFACE SURFACE SOIL LAGOON BAC KGROUND
SAMPLE NEAR SO IL SAMPLES SAMPLES SEDIMENT SURFACE SOl L
METAL 01 SCHARGE PIPE W ITH I N FE NC E ~1I TH I N FENCE SAMPLES SAMPLES
Antimony 55JN U-16 (1) 4.6 U U
Arsenic (2) U U-19 (3) 1.4 U U
Berytl i um U U U U U
Cadmium 65JN U-15 (2) 2.9 22-27 (2) U-2.6 (1)
Chromium 2,000 U -1 30 (9) 44.8 93-310 (2) U-S.3 (1)
Copper 89 U-20 (1) 4.9 U-25 (1) U-8.9 (l)
Leqd 13 U-14 (12) 8.5 U-4.6 (I) 12-34 (4)
Mercury U U U U U
Nickel 1,800. 1- 3G (14) 13.8 19-150 (2) U-12 (2)
Selenium 5R U - 4R (12) 1.4R U U
S i1 ver 21 U 1.2 U U
Thall i urn U U U U U
Zinc 15,000 U-230J (6) 48.9 260-2,000 (2) U-2OJ (1)
Cyanide 77 U 0.8 U U
Total number of surface soil samples within fence = 15
Total number of lagoon sediment samples = 2
Total number of background surface samples = 4
All subsurface soil sampl es contained approximately background concentrations
J - Estimated value
N - Presumptive evidence
U - Undetec ted
R - Data not rel iable
of compound
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-14-
The evidence that exposure to airborne Cadmium compounds increases the risk of
cancer in humans is characterized as limited (lARC 1982, EPA 1985b). Although
several studies of exposed workers have suggested that airbourne Cadmium
increases the risk of cancer of the lung or prostate, most of the results have
been inconcl~sive because of small sample sizes, lack of statistical
significance, confounding effects of other exposures, or other factors. The
most recent study (Thun, et ale 1985), however, showed a significant increase
in the number of lung cancer deaths (16 observed versus 6.99 expected) among a
group of Cadmium smelter workers.
Although this finding may be somewhat confounded by the
exposure to arsenic, EPA (1985b) concluded that neither
sufficient to explain the observed effect.
effects of smoking and
of the latter was
Recent studies have firmly associated inhalation of airborne Cadmium with lung
cancer in animals. In a biossay in which male Wistar rats were administered
Cadmium Chloride aero~ols 23 hours/day for 18 months at concentrations of 9,
12.5, 25, and 50 ug/m , Takenaka et al.'s (1983) found a highly significant
dose-response relationship. The incidence of lung carcinomas was 0/38, 5/39,
20/38, and 25/35 in the four treatment groups. This marked response adds
further support to the evidence on the carcinogenicity of inhaled Cadmium and
justifies the use of Thun, et al.'s (1985) data as the basis for risk
assessments of airborne Cadmium. Like the injection-site sarcomas and
Leydigomas reported in animals (EPA 1985b), these lung carcinomas might be
interpreted as carcinogenic responses in the directly exposed tissue only.
Chromium - Chromium (Cr) is a steel-grey lustrous metal with the atomic
24 and an atomic weight of 52 g/mole. It can have a valence of 2, 3 or
Chromium is used in stainless and alloy steels, in corrosion-resistant
products, in pigments, and as a tanning agent for leather.
number
6.
Epidemiological studies of worker populations have clearly established that
inhaled Cr(VI) is a human carcinogen, with the respiratory passages and the
lungs as target organs. Convincing evidence for carcinogenicity of Cr(VI)
compounds in animals is not available, except for the induction of sarcomas at
the sites of implantation or injection of certain Chromium (VI) salts and
Chromium trioxide (EPA 1980, 1984a).
Neither Cr(III) or Cr(VI) compounds have been shown to be carcinogenic by the
oral route. Rats administered Chromium (III) oxide at doses up to 5 percent of
their diet for two years had no increase in tumor rates over control animals
(Ivankovic and Preussmann 1975 as cited in EPA 1984a). Dogs given Cr(VI) as
potassium chromate at concentrations of 0.45 to 11.2 mg/liter in drinking water
for 4 years h$d no observed adverse effects (Anwar, et ale 1961 as cited in EPA
1984a).
Chromium is an essential micronutient and is not toxic in trace quantities.
High levels of soluble Cr(VI) and Cr(III) produce kidney and liver damage.
Chronic inhalation exposure may led to respiratory system damage.
Epidemiological studies of workers exposed to Cr(VI) via inhalation demonstrate
that it is a human carcinogen. EPA's (1984b) quantitative risk assessment is
. based upon a single study of a cohort of workers exposed over a six year period
and followed for approximately 40 years. Smoking habits were aot considered in
the study. Assumptions and extrapolations included in the calculations lead to
a very wide range of uncertainty in the risk factor. The ~eJat.ive carcinogenic
potency of Cr.(III) has no~ been dcmons~rated~ .
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:yanide - Hydrogen cyanide and its simple salts, such as sodium cyanide, are
lighly toxic by all routes (AOGIH 1986, BPA 1980). Hany reports are available
~egarding acute poisonings in humans. Hydrogen Cyanid~ vapor is irr3tating at
rery low concentrations, is considered dangesous at 20 ppm (20 mg/m ), and is
:atal at concentrations of 100 ppm (100 mg/m ) for 1 hour. NIOSH (1976)
loted reports of chronic poisoning resulting in fatigue, weariness, and other
lubjective symptoms in workers, but these findings have been disputed by other
.nvestigators. Chronic exposure to low levels of Cyanide salts has been
~eported to cause enlargement of the thyroid gland in humans, apparently due to
.nefficient elimination of the Cyanide metobolite thiocyanate. NIOSH (1976)
:oncluded that there was no evidence of carcinogenicity, mutagenicity, or
:eratogenicity for Cyanides.
:yanide has been shown to produce chromosome breaks in a bean plant, Vicia
'aba. Because of its mechanism of action, inhibition of the electron transport
Iystem in oxidative phosphorylation, Cyanide is acutely toxic to almost all
'orms of life.
lickel - Nickel (Ni) is a lustrous white, hard metal with atomic number 28 and'
Ln atomic weight of 58.7 g/mole. It is used in welding, in electroplating, in
Itorage batteries, and in numerous high temperature and corrosion-resistant
Llloys.
~he occurrence of statistically significant excesses of nasal cavity and lung
~ancers in Nickel refinery workers has been conclusively demonstrated in a
Lumber of epidemiologic studies. It is 'generally believed that these excess
'isks are primarily due to inhalation of metallic Nickel, Nickel subsulfide,
rickel Oxide, and Nickel carbonyl. These conclusions have been supported by
Ibservations in experimental animals, and lARC has concluded that it is likely
.hat some forms of Nickel are carcinogenic to man by inhalation (lARC'1982).
lowever, because simultaneous exposure to several Nickel compounds usually
Iccurs in the workplace, it has been difficult to determine which specific
~ompounds are carcinogenic under these conditions.
bere is no evidence that Nickel is carcinogenic in humans when ingested, and
:PA (1985a) does not consider Nickel to be carcinogenic by ingestion.
,aboratory studies have demonstrated depressed weight gain, alterations in
Lematology parameters, and cytochrome oxidase activity following high-dose oral
~xposure to Nickel (EPA 1985a).
rickel salts are known to produce allergic contact derm1titis. In this
,llergic condition, symptoms may develop in 7 to 10 days following exposure to
rickel salts. However, Nickel dermatitis more frequently develops after
,everal years of continued low exposure (Klaassen and Amdur 1986). Once
,cquired, Nickel sensitivity tends to persist. Sensitized subjects may
:xperience allergic reactions at concentrations between 0.5 and 2 ug/ml Nickel
Clayton and Clayton 1981).
Zinc - Zinc (Zn) is a silvery metal of low to intermediate hardness, atomic
number 30 and atomic weight 65.38 g/mole. Primary uses of zinc in industry are
as a component of dry cells and other batteries, in electrogalvanizing, and as
alloys. Zinc compounds are used therapeutically as topical a~tringents.
antidandruff products, antiseptics, and emetics.
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-16-
Zinc is an essential element and is present in a number of metalloenzymes,
including carbonic anhydrase carboxypeptidase, alcohol dehydrogenase, glutamic
dehydrogenase, lactic dehydrogenase, and alkaline phosphatase (Valle 1959 as
cited by Hammond and Beliles 1980). Zinc is 'necessary for normal growth and
development. Human dwarfism and a lack of sexual development have been related
to zinc deficiency (Halsted, et ale 1974 as cited by Hammond and Beliles 1980).
, There is no evidence that zinc is carcinogenic. Studies which have been
performed on zinc-containing organics failed to demonstrate teratogenic effects
(Stokinger 1981). Zinc salts of strong acids are astringent and corrosive.
Upon ingestion, they act a emetics, and they can cause symptoms of fever,
nausea, vomiting, stomach cramps and diarrhea.
Zinc chloride is caustic and causes severe and occasionally fatal irritation of
the epithelium lining, the trachea and bronchi. Acute interstitial fibrosis of
the lung occurred in one fatal case following inhalation of ZnC12 smoke from
a smoke generator (Millinken, et ale 1963). ,
Chronic administration of 0.5-34.4 mg zinc oxide per day for periods of one
month to one year failed to produce signs of toxicity in rats (Drinker, et al.-
1927 as sited by Stokinger 1981). In another study, 0.1 percent Zinc was
tolerated in the diet of rats, but more than 0.5 percent Zinc reduced their
capacity to reproduce, and one percent inhibited growth and. caused severe
anemia and death (Sutton and Nelson ~937 as cited by Stokinger 1981).
Risk Assessment
Two scenarios were developed for risk assessment. Under the current-use
scenario, the site remains as is and the intermittent'exposure of nearby
workers is considered. In the future-use scenario, the site.is developed for
residential use and nearby residents are regularly exposed throughout their
lifetimes. Each sce~ario was evaluated for exposure to both average case
(geometric mean) and maximum contaminant concentrations.
Under the, current-use scenario, direct contact with contaminated soils does not
appear to pose a human health risk. However, inhalation exposure to maximum
contami~gnt concentrations could pose an excess lifetime cancer risk greater
than 10 .
Incidental ingestion of contaminated soils does not represent a health risk
under the average case future-use scenario, although the concurrent ingestion
of soil contaminants at the maximum concentrations detected could endanger the
health of residents.
Inhal!Sion of airborne particulate matter may
as 10 under future-use scenarios. Chemical
site do not appear to endanger wildlife under
future-use scenarios.
pose excess cancer risks as high
contaminants in soil at the
plausible current-use or
5.0 Enforcement Analysis
The Independent Nail Company Site was added to the NPL in September 1984, and
EPA assumed lead responsibility for the site at that time. Due to the nature
of contamination at the site and its well-documented history, the Blake and
Johnson Company and the Independent Na1l Company are th~ tw~ identified
Potentially Responsible Parties. A notice letter was &ent to the Indepe~dent
~l1U C":rn.pl;ry.~, iI1! Jun,~ 199,~ ",-, ~;tn~f' th~" d~~l1n"~d t.C) pt\Tti.~.1 p'i1-,~ FPA pTor,~,edf>d .
-7 ,.;'=-t ~ "I Ie:
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-17-
6.0. Community Relations History
The following community relations activities were performed at the Independent
Nail Company Site:
* A Fact Sheet on the Site was prepared in November 1986.
* Community Relations Plan finalized January 1987
* An information repository was established in January at:
Beaufort County Library
710 Craven Street
Beaufort, South Carolina
(803) 525-7279
29902
Contact:
Ms. Julie Zachowski, Librarian
* A press release providing an opportunity for a public meeting and
information on the opening of the public comment period was issued July 21,-
1987.
* Public notices providing the same information ran in. the July 23 and July .
?4, 1987 editions of the Beaufort Gazette, a daily paper determined to be
the most widely read in the area.
Key Community Concerns
The primary concern expressed by every interviewee during development of the
Independent Nail Co. Site Community Relations Plan was the possibility of
contamination of area ground Water.
7.0 Alternative Evaluation
The purpose of the Operable Unit One remedial action at the Independent Nail
Company Site is to mitigate and minimize contamination in the soils and lagoon
sediment, and to reduce current and future potential risks to human health and
the environment. Based on the level of contaminants found at the site, the
endangerment assessment and regulatory requirements, the following cleanup
objectives were determined:
* To protect the public health and environment from exposure to.
contaminated soils through inhalation, direct contact and erosion of
soils.
* To prevent the spread of contaminants to other soils.
* To reduce or prevent contamination of ground water.
Cleanup goals were developed for the contaminated soil at the Independent Nail
Company Site based on applicable or relevant and appropriate requirements
(ARARs) of federal and state statutes or other guidelines (Table 7-1). The
goals were developed to prevent potential ground water contamination from
eX£6~ding ARARs and to reduce potential cancer risk from inhalation to below
10 .
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-18-
An initial screening of applicable technologies was performed to identify those
which best meet the criteria of section 300.68 of the National Contingency Plan
(NCP). Following the initial screening of technologies, potential remedial
action alternatives were identified and analyzed. These alternatives were
screened and those which best satisfied the cleanup objectives, while also
being cost effective and technically feasible, were developed further.
Table 7-2 summarizes the results of the screening process. Each of the
remaining alternatives for soils and sediment remediation was evaluated based
upon cost, technical feasibility, institutional requirements, and degree of
protection of public health and the environment. A cost summary is presented
in Table 7-3. All alternatives would involve remediation of approximately 6200
Cubic Yards of soil/sediment.
ALTERNATIVE 1:
SOIL WASHING AND VEGETATIVE COVER
EPA currently operates an experimental mobile soil washing unit. This unit has
been used to remove lead from soil, but has not been used for the removal of
the metals detected at the Independent Nail Company Site (i.e. cadmium,
chromium, nickel, and zinc). IT Corporation has a mobile centrifuge system
which has been used for washing/neutralization of sodium hydroxide
contamination in soil and a mobile inorganics treatment system which could be
used to treat the washing solution.. .
Costs generated for the treatability testing and process development of a
mobile soil washing system for the Independent Nail Company Site are based on
the use of IT Corporation mobile treatment units. Details of the full scale
soil washing system would be determined by laboratory testing. It is
anticipated that the laboratory testing would be conducted in two phases.
Phase I would involve preliminary range finding experiments with different
washing solutions to determine their effectiveness in reducing the metal
content of the soil. Phase II testing would examine the successful solution on
a bench scale, define metals removal from the solution and removal of the
washing solution from the soil, and preparation of a preliminary design, cost
and schedule estimates. .
The anticipated scope of Phase I would be to test the removal efficiency of
four different aqueous solutions:
*
*
*
*
Water
HCI, pH 3.5
Acetic Acid, pH 3.5
Na-EDTA, 5 EDTA/metals
molar ratio
These tests would involve laboratory shaker tests and result in the selection
of the most appropriate washing solution. Phase II would involve further
investigation of the process using the selected solution. The scope of Phase
II is expected to be:
*
Laboratory treatability tests of contaminated soils with the selected
solution
*
Laboratory treatability tests of the selected solution for metals
remcval
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-19-
TABLE 1-,1
SUMMARY OF SOIL CLEANUP GOALS
INDEPENDENT NAIL COMPANY SITE
BEAUFORT, ~OUTH CAROLINA
Soil C~eanup Goal (mg/kg)
Compound
Protection of
Ground Water
Future-use Maximum Case
Protection
Ingestion Inhalation
Local
Background
Regional
Background
(Maximum)
Goals
Selected
For Site
Remediation
Cadmium 0.6 112 3.5 2.6 11 2.6
Chromium 8.9 1,211 0.5 5.3 100 5.3
Cyanide 0.02 0.02
Nickel 53.5 1,211 18 12 10 18
Zinc 1,185 13,413 20 100 1,185
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-20-.
*
Laboratory treatability tests of treated soil for washin~
solution removal
*
A process flow diagram and material balance for the selected process
scheme
*
Development of costs and schedule for the onsite remediation of 6,200
Cubic Yards of contaminated soil
Overall, project costs and schedules presented in this report are preliminary
and would be refined following the laboratory testing.
Contaminated soil would be excavated and temporarily stockpiled onsite. The
soil would be securely covered to prevent contact with precipitation. The
lagoon would then be partially backfilled to two feet above the assumed high
water table with clean local soil. Washed soil would then be placed in the
lagoon. A vegetative cover would be constructed as described in Alternative 6.
ALTERNATIVE 2:
ATTENUATION AND VEGETATIVE COVER
Attenuation. of the soil contamination would be accomplished by mixing clean -
soil with the contaminated soil. All contaminated soil would be excavated,
temporarily stockpiled onsite, and securely covered to prevent wind blown dust
and contact with precipitation. The lagoon would then be backfilled with clean
local soil to two feet above the assumed high water table. Clean soil.
-(preferrably high in organic and/or clay content) would then be spread in
layers over the lagoon area. A portion of the contaminated soil would b~mixed
with each layer of clean soil applied. Soil suspected of significantly higher
concentrations than the average (area near discharge pipe) may be segregated
and mixed with a larger volume of clean soil. Laboratory testing may be
required to ensure that contamination is being decreased to the levels.
necessary for the protection of ground water. A vegetative cover would then be
constructed as described in Alternative 6.
ALTERNATIVE 3 - SOLIDIFICATION/STABILIZATION
A silicate/cement-based process has been selected for evaluation of the
solidification/stabilization of soils at the Independent Nail Company Site.
These methods have the ability to stabilize materials containing high
concentrations of heavy metals, even under acidic conditions. Most processes
use two inorganic chemical reagents which react with polyvalent metal ions to
form a chemically and mechanically stable solid. The process is based on
reactions between soluble silicates and silicate setting agents under
controlled conditions to produce a solid matrix. Reagents commonly used
include sodium silicate, fly ash, kiln dust, and Portland cement (as the
setting agent). The resulting matrix is clay-like and displays properties of
high stability, low permeability, high alkalinity, high bearing strength, and
high cation exchange capacity. The resulting solid can be easily and
economically handled, transported and stored. The volume added to the waste by
the treatment process would be between 5 and 10 percent.
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TABLE 7-2
TECHNOLOGIES CONSIDERED FOR SCREENING
INDEPENDENT NAIL COMPANY SITE
BEAUFORT, SOUTH CAROLINA
Eliminated (E) (If Eliminated, Reason for
Doing So)
Technology
Retained (B.)
1.
Soil Flushing/Washing
R
2.
Attenuation
R
3. Immobilization
Solidification/Stabilization
Adsorption
Lime Addition
Clay Addition
4. Capping
5. Vegetative Cover
6. Subsurface Iaperaeable
Barriers
R
E
Not Applicable due to waste
characteristics
R
R
R
R
E
Not Applicable due to site
characteristics
7.
Encapsulation
E
Not Applicable due to waste
chat:acteristic
8.
Onsite Disposal
E
Not applicable due to site
characteristics
9.
Off-site Disposal
R
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TABLE 7-3
PRELIMINARY COST ESTIMATES
INDEPENDENT NAIL COMPANY SITE
BEAUFORT. SOUTH CAROLINA
Present Worth Present
Construction Worth O&M Total Present
Technology Cost. $1.000 Cost. $1.000 Worth $1.000 Ratio (1)
Soil Washing 2.221 101 2.322 3.2
Attenuation 658 101 758 1.0
Solidification/Stabilization 979 101 1.079 1.5
Immobilization by Clay Addition 785 101 886 1.2
immobilization by Lime Addition 801 101 902 1.2
Capping 1.321 144 1.465 2.0
Vegetative Cover 58~ 134 719 1.0
Off-site Disposal 2.696 101 2.796 3.9
(1) Ratio with technology of lowest cost
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This process is commercially offered as a complete, onsite, mobile treatment
unit. The units are usually outfitted with reagent tanks, metering equipment
and an operating console which monitors the entire process. All contaminated
soils would be excavated, slurried, then pumped to the treatment units where
mixing and chemical reaction with the reagents would occur. The treated
material would then be pumped to a holding structure constructed with the local
soil used to partially backfill the lagoon. The base of the holding structure
would be approxi~ately two feet above the assumed high ground water table.
Solidification generally occurs within 72 hours.
After the material had solidified, six inches of topsoil would be spread over
the material and vegetated with grass seed.
ALTERNATIVE 4 - iMMOBILIZATION BY CLAY ADDITION AND VEGETATIVE COVER
Contaminated soil would first be excavated and temporarily stockpiled onsite
for immobilization by clay addition. The soil would be securely covered to
prevent erosion and contact with precipitation. The lagoon would be backfilled
with clean local soil to two feet above the assumed high water table. The
stockpiled soil would then be mixed with clay and spread evenly over the fill
material. Mixing may be best accomplished with a pug mill mixer. For cost
purposes, a 1:1 mix of contaminated soil to clay is assumed. Adjustment of pH
by the addition of lime may also be necessary. Laboratory treatability testing
would be required to determine the quantity of clay required and to evaluate
the need and effect of pH adjustment.
A vegetative cover would be constructed over the contaminated soil/clay layer
as described in Alternative .6: Vegetative Cover. Areas outside of the lagoon
would be backfilled with topsoil and vegetated.
ALTERNATIVE 5 - IMMOBILIZATION BY LIME ADDITION AND VEGETATIVE COVER
Immobilization by lime addition would first involve .the excavation and onsite
stockpiling of all contaminated soil. Stockpiled soil would be securely
covered to prevent erosion and contact with precipitation. The lagoon would
then be backfilled with clean local soil to two feet above the assumed high
water table. The stockpiled soil would then be mixed with powdered lime and
spread evenly over the fill material. Mixing of the soil and lime may be best
accomplished with a pug mill mixer. Powdered lime would be added in quantities
sufficient for precipitation of metal hydroxides as determined by laboratory
treatability studies with onsite soils. A layer of crushed lime rock would
then be placed over the contaminated soil/lime mixture to maintain the soil and
soil water at the pH necessary to prevent resolubilization of the metals by
infiltrating rain water. The amount of lime rock required to maintain the
appropriate pH would also be determined in laboratory treatability tests. For
cost purposes, this layer is assumed to be 18 inches thick. Overlying the lime
rock would be a layer of geotextile fabric and a vegetative cover. The
geotextile fabric would stabilize the vegetative cover and prolong the
effectiveness of the lime rock by preventing topsoil from being carried into
the pore spaces of the lime rock.
Construction of the vegetative cover is described under Alternative 6:
Vegetative Cover.
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!
-24-
ALTERNATIVE 6:
VEGETATIVE COVER
The placement of a vegetative cover over the lagoon area ~ould involve the
backfilling of the lagoon and the placement and vegetation of an 18 inch layer
of topsoil over an area of approximately two acres. Contaminated soils located
outside the lagoon area would be excavated and placed in the area to be
covered. The topsoil would be graded to minimum of two percent slope from the
center of the lagoon and drainage swales would be constructed around the
perimeter of the area. Runoff collected in the swales would be directed to
existing drainage paths.
ALTERNATIVE 7:
CAPPING
Capping of the lagoon area would involve backfilling the lagoon and
construction of a three layered cap conforming to RCRA guidelines. The area to
be capped encompasses approximately two acres. Under this alternative. the
areas of soil contamination located outside the lagoon area as well as the
contaminated soil located below the assumed high water table would be excavated
and temporarily stockpiled onsite. The soil would be covered to prevent
erosion and contact with precipitation. The portion of the lagoon below the
assumed high water table would be backfilled with clean soil and the
contaminated soil placed in the lagoon two feet above the high water table.
The lagoon would then be further backfilled with clean soil. The' areas located
outside the lagoon would be backfilled with topsoil and vegetated.
The construction of the cap would follow the complete backfilling of the lagoon
and involve the placement of a two~foot clay layer. compacted, in six-inch.
lifts. A twenty-mil synthetic liner would then be placed over the clay. Next,
a one-foot thick drainage layer of gravel would be spread and overlain with
geotextile fabric. The geotextile fabric would maintain the drainage layer and
help to stabilize a final layer of eighteen inches of topsoil by keeping fine
topsoil particles from filling the pore space of the gravel layer. The topsoil
would be vegetated to prevent erosion. The cap would have a minimum slope of
two percent from the center of the lagoon. The lagoon would be backfilled to
an elevation that would place the gravel drainage layer at approximately the
elevation of the surrounding ground. A drainage swale would be constructed
around the perimeter of the cap to direct surface runoff to the existing area
drainage paths. Precipitation that percolates through the topsoil would flow
laterally through the gravel and over the impermeable synthetic and clay
barrier and into the drainage swales.
ALTERNATIVE 8:
OFF-SITE DISPOSAL
This alternative requires the excavation of all contaminated soil and the
disposal of the waste in an off-site RCRA permitted facility. Approximately
6.200 cubic yards of contaminated soil would be excavated; 5.000 cubic yards
from the lagoon and 1.200 cubic yards from the other areas of soil
contamination. Some soil within the lagoon may be saturated during
excavation. This soil would be placed in a pile near the excavated area and
allowed to drain prior to loading into trucks. Water would drain from the soil
into the excavated area. The lagoon would be backfilled with clean fill
material to an elevation approximately six inches less than the surrounding
grade. The upper six inches would be backfilled with topsoil and vegetated.
Areas of excavation outside of thp. lagoon would be backfilled with topsoil and'
vegetated. '.
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GSX of Pinewood, s.c. was contacted and indicated available capacity and
interest in managing the soil removed from the Independent Nail Company Site.
This facility is located approximately 125 miles from the site. However, due
to a current "out of compliance" status with the Resource Conservation and
Recovery Act, this facility cannot be utilized at this time.
ALTERNATIVE 9:
NO ACTION
Under the no action alternative, soil would remain contaminated with toxic
substances regulated by local, state and federal law. Two variations of this
alternative will be considered: no action with periodic monitoring and no
action without periodic monitoring. Neither alternative would provide remedial
action to reduce mobility, toxicity or volume of contaminated soil. However,
with the former, ground water at and adjacent to the site would be monitored.
Possible socioeconomic impacts of either no action alternative include the
following: .
*
*
*
*
*
*
Decline in property values
Expenditure for legal services
Depressed area growth
Restricted access to the site
Public and environmental eXP9sures
Monitoring expenses
8.0 RECOMMENDED ALTERNATIVE
The recommended alternative for remediation of soil and sediment contamination
at the Independent Nail Company Site includes solidification and stabilization
and backfilling of treated material on the Site.
Contaminated soil will be treated using stabilization/solidification. Following
treatment, the soil/sediment will be placed back into the excavated lagoon, be
covered with six inches of top soil and then seeded to provide vegetative
cover. At selected intervals, during excavation, soil samples will be
collected and will be analyzed to determine the limits of excavations. It
should also be noted that the action levels in Table 7-1 are preliminary goals
and are subject to refinement during remedial design.
This recommended alternative meets the requirements of the National Oil and
Hazardous Substances Contingency Plan (NCP), 40 CFR, 300.68(j) and the
Superfund Amendments and Reauthorization Act of 1986 (SARA). This alternative
permanently and aignificantly reduces the mobility of hazardous contaminants in
the soil and the sediments in the lagoon. The results of the Operable Unit Two
groundwater investigation will determine the necessity for long-term monitoring
and maintenance in association with this remedy.
The alternative is cost-effective when compared with other applicable
alternatives. The technology has been proven and the alternative is
implement able at the Site. It is estimated this alternative could be
implemented within twelve months. Alternatives 1, 2, 4 and 5 would require
from one to twelve additional months for implementation. Alternative 8 would
be out of line with EPA's off-site policy. Alternative 6 would not prevent
. on-going contamination of ground-water as no soil would be relocated.
Alternative 7 would not util~ze alternative" treatment technologies and would
not result iu ~eduction iL toxicity, mobility or volume of the waste at the
Sitt!.
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! --
-26-
OTHER STATUATORY REQUIREMENTS
* Occupational Safety and Health Administration (OSHA)
A health and safety plan will be developed during remedial design and
will be followed during field activities to assure that regulations of
OSHA are followed.
* Safe Drinking Water Act (SDWA)
Possible groundwater contamination at the Site will be investigated
during the Operable Unit Two remedial investigation. A feasibility study
to determine the appropriate cleaup alternative will include measures to
ensure conformance with the SDWA.
* National Pollutant Discharge. Elimination System (NPDES)
The chosen alternative does not include any discharges. therefore this
does not apply.
* Endangered Species Act
The recommended remedial alternatives is protective of species listed as
endangered or threatened under the Endangered Species Act. Requirements
of the Interagency Section 7 Consultation Process. 50 CFR. Part 402. .
will be met. The Department of Interior. Fish and Wildlife Service. will
be consulted during the remedial design and Operable Unit Two RI/FS to .
assure that endangered or threatened species are not adversely impacted
by implementation of this remedy.
* Ambient Air Quality Standards
The soil/sediment treatment system will be designed and monitored to
assure that air emissions meet all State and Federal standards.
* State Drinking Water Standards
Maximum contaminant levels established by the State of South Carolina
regulations are adopted from those of the Federal Safe Drinking Water
Act, and will be addressed in Operable Unit Two RI/FS at the Site.
CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS
Remedial actions performed under CERCLA and SARA must comply with all
applicable Federal and State regulations. All.alternatives considered for the
Independent Nail Company Site were evaluated on the basis of the degree to
which they complied with these regulations. The recommended alternatives were
found to meet or exceed all applicable environmental laws, as discussed below.
* Resource Conservation and Recovery Act (RCRA)
The recommended remedy for soil/sediment contamination is not regulated
under RCRA, therefore it 'does not apply.
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-27-
* Clean Water Act
Soil remediation is aimed at source control, and implementation of the
recommended alternative would result in an end to potential
contamination of surface water.
* Floodplain Management Executive Order 11988
This Site does not lie within a floodplain and, thus, is not subject to
the requirements of E.O. 11988.
* Department of Transportation
Transport of hazardous substances is regulated by the Department of
Transportation (DOT). No off-site disposal is anticipated at this Site,
therefore no DOT regulations will apply.
OPERATION AND MAINTENANCE
No long-term operation and maintenance requirements are expected for this
alternative.
Groundwater monitoring would be required in conjunction with this alternative.
Monitoring would help determine the effectiveness of the alternative at
reducing migration to the groundwater. Five well clusters of three wells each
would be installed. Each of these wells would be sampled on a quarterly basis
for t:he first two years after the alternative is initiated, and yearly'
thereafter for 28 years. Samples would be analyzed for the Target Compound
List metals plus cyanide. Air monitoring during construction would be .
necessary to ensure that a safe working environment is maintained and that no
threat to the public health or the environment is created by air emissions
during construction..
OFF-SITE DISPOSAL, PERMITS AND TRANSPORTATION
This alternative does not include the transport or off-site disposal of
hazardous wastes. Thus, it is not anticipated that any hazardous waste permits
would be required.
Health and Safety
Health and safety requirements during the implementation of this alternative
include periodic air monitoring and the use of personal protection equipment by
all construction personnel. It is anticipated that Level D personal protection
would be required with a contingency to upgrade to Level C if necessary.
It is anticipated that construction can be completed in such a manner that very
little heavy equipment decontamination would be required. Personnel
decontaminB.tion facilities would be necessary.
Preliminary Schedule of Activities
The schedule
the topsoil.
fall. Also,
time of year
of this alternative must provide for ~he immediate vegetation of
Seeding is usually most successful in the late summer or early
it may be advantageous for excavation to be perf~~ed du~ing a
when the groundwater table is low.
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Allowing six months for design and contractor selection, it is anticipated that
this alternative could be completed in approximately thirteen months. Two
months would be required to prepare the site (excavation of contaminated soil
and partial backfi~l of lagoon) and to mobilize. the Solidification/
Stabilization (S/S) equipment. One additional month would be necessary for the
S/S of the soil and three months to complete backfilling of the lagoon and
vegetation of the topsoil. This schedule assumes that weat~er does not cause
extreme delays.
Cost Estimate
Solidification/stabilization is expected to have a total present worth cost of
approximately $1,132,000. This estimate assumes a cost of $50 per cubic yard
for S/S bringing the total construction costs to approximately $1,032,000.
Monitoring cost of $22,500 each year for two years after implementation and
$5,600 and each year thereafter for 28 years amount to approximately $100,000.
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ATTACHMENT 1
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I.
I
ATTACHMENT 1
Responsiveness Summary
1.
Overview
A press release announcing the opportunity for a public meeting was iss~ed on
July 21, 1987. Public notices announcing the opportunity for a public meeting
and the opening of the public comment period appeared in the July 23 and 24
issues of the Beaufort Gazette, the most widely read newspaper in the area of
the Independent Nail Company Site. No requests for the aeeting or comments on
the Feasibility Study Report were received. .
2.
Community Profile and History of Community Involvement
.
The City of Beaufort is located on the southeast side of Beaufort County. It
is forty-five miles northeast of Savannah, Georgia, and thirty miles
north-northeast of Hilton Head, South Carolina. Beaufort County consists
largely of a collection of sixty-eight islands, defined by a complex network of
waterways. The county is an extremely sensitive environmental area --
according to one local official, it is one of the last "pristine" environments
on the east coast.
Tourism, recreation, and fishing are major local industries, with several
~esorts in the county (including Hilton Head) noted for their boating and
golf. There are numerous rivers, creeks, and public and private beaches and
golf courses found throughout the county. Several international golf and
tennis tournaments are held at Hilton Head each year. There is both
recreational and commercial fishing, and local residents are proud of the
county's reputation for good seafood.
There is a180 a large military presence in the county, with approximately
15,000 military personnel living there. In addition to the Air Station, the
Marine Corps has a large training camp at Parris Island, which is immediately
south of Port Royal Island. According to the Beaufort County Joint Planning
Commission (BCJPC), 22,000 recruits are trained at Parris Island each year.
There is also a large naval hospital in Beaufort County.
While the county is now considered relatively rural, commercial and residential
development is occurring rapidly. According to BCJPC, the county's population
has grown 28% since 1980 -- growth in the City of Beaufort has been lower than
28%, while that in the resort areas such as Hilton Head has been much higher.
Both the city and county governments are located in the City of Beaufort. The
city is governed by a Mayor and a five-member City Council, all of whom serve
four-year teras. There is 81so 8 City Manager who is responsible for most of
the day-to-day tasks of running the city. The county is run by a County
Administrator and a nine-member County Council. These Council members serve
two year terms; four are selected at large, five by district. The County
Council has a one-member Coastal Council B~ard/Commission that oversees
environmental matters.
The principal State agency involved with the Site is the South Carolina -
Departm~nt of Health and Environmental Co~trol (SCDHEC). SCDHEC has a broad
array' 01 -responsibilities, including conducting restaurant inspections,
mont.toring water quality, and handling solid and hazardous waste issues. One
elected ~fficial said that any resident complaints about envircnmental matters
.ICO~~I ',~ '~.I."~ -\::d/I, ,'"-.
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County residents, however, have expressed virtually no interest in this site --
no complaints have been received by local officials. There has also been very
little publicity about the site -- the only newspaper articles on the site
appeared when the site was listed on the NFL. However, officials noted that
this seeming lack of specific concern could change rapidly if there is
sufficient adverse publicity. on the site. The source of this potential,
according to local officials, is that the citizens are very interested in
environmental issues in general. The county's rapid rate of development has
heightened this concern. Many people live in the area because of its natural
beauty and recreation opportunities, and they do not want these characteristics
ruined. Furthermore, one official commented that many residents, especially in
the resort areas, are well-educated retirees who have the time, inclination,
and expertise to become heavily involved in local environmental issues. As
evidence of this interest, local officials point to heavy attendance at public
meetings on issues such as local development projects and a proposal to build a
county incinerator.
According to local officials, more residents are concerned about the Wamchem
Site then about the Independent Nail Site because of the contaminants involved
and Wamchem's proximity to residents. One resident contacted during the
preparation of this plan was not aware of the Independent Nail Site; because of
his proximity to the Wamchem Site and nearby McCalley Creek, however, he was
quite concerned about the contaminants emanating from Wamchem. Even though
there has been little publicity or outward evidence of citizen concern about
the Wamchem Site, this resident estimated th~t dozens of residents are directly
affected by the Wamchem Site. He thought residents would contact their County
Councilman, State Legislator, or SCDHEC if. they wanted to register their
concerns. This resident also is interested in environmental issues in general
and would like to receive any information EPA distributes on the Independent
Nail 'Site.
Key Community Concerns.
The primary concern expressed by every interview was the possible contamination
of area g~oundwater. Further investigations in the course of preparing the
community relations plan, however, revealed additional concerns dealing with
the local industrial base and financial responsibility for the cleaup. These
additional concerns currently do not seem to be pressing. According to the
people who expressed thea, however, these concerns could flare up quickly if
activities at the Site or adverse publicity about the Site's affect on the
local environment warrant an increase in community concern.
Detail descriptions of concerns expressed by local officials during community
inte~views are presented below:
1.
Groundwater Contamination
Even though the homes and businesses around the Independent Nail Site
are connected to the city water supply, local officials stated that
some residents there may use private wells. While officials have yet
to receive a complaint concerning the quality of the water from any
private well, they want to be sure that this water is not
contaminated. Furthermore, local officials are concerned that any
ground~ater contamina~ion problem could extend far beyond the immediate
site area. Because the Site rests over the Floridan aquifer, officials
want to be sure that this significant source of drinking water is not
threaten.ed.
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2.
Preservation of the Natur.al ;:::"viro,,:-'::".::
According to local official's, many of ::l~e :-L:sidents \o.'ha live 'in the
area do so because of its natural bea!'.':y. ;:0 residents have expressed
concern about the effect of the Inde?c~~ent Kail Sit~ on their
environment. They have beeu involveQ :~ vtl:2r local envi,-onmental
issues, however, and officials feel t;'~s gen~r.al interest could become
focused on thia site once the public ~~ e~are of its existence. For
this reason~ officials feel that in c~~er to avoid any u~necessary
concern, it is especially important that an: publicity about the Site
be as accurate and objective as possib:e.
3.
Possible Financial Liability
According to Site files, Beaufort Coun~y cn~e owned the land now occupied
by the Site, and leased it to Blake ar.-' Jchns;Jn. EPA at one time
identified the county as a PRP because of this relationship. The county,
however, has insisted that it had no connections with the operations at the
Site, and the County Administrator sa:"; th~t the county is no longer
designated a PRP. County officials, ,.::,,'evcr, are still interested in the
PRP search process and are concerned ~':~t t~~ appropriate parties pay for
the cleanup.
4.
Preservation of Beaufort's ~bility ~~ A~~ra~t Industry
Currently, one of the major indust=i~0 in Beaufort County is tourism;
according to one local off:~ial, thc~~ is c~ly one chemical company in the
area. Yet one Beaufort County Counc'l~an seid that the county needs both
tourism and other, heavier ind~strie~" H2 believes that industries other
than those found in the tourist tr~!' C~~ ~rovide Beaufor~ County
residents with jobs that have highe:- ~~:ari~s and more potential for
advancement In order to encourage a :~siness growth and diversity, the
Councilman does not want the county L0 gain a reputation fer hostility to
non-tourism industries. Therefore, ::~e Councilman is concerned that
publicity about cleaning up the Sitc ~nd finding PRPs to pay for the
cleanup may give Beaufort a ~~putati~n for b~ing anti-industry.
3.
Summary of Public Comments and Agency Responses
As no comments, oral or written, wer~
applicable.
:~~C~iV8d)
this Section is not
4.
Remaining Concerns
No remaining concerns have been iden~ified.
Community Relations activities to da::~ are listed in the ROD.
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