United StatM
EmfcoraMntal PretMten
Agency
Offlnof
EPA/ROO/R04-88/040
Augwt 1988
SEP A Superfund
Record of Decision;
Indendent Nail, SC
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I-
I
50272. "III
REPORT DOCUMENTAnON 11. REPORT NO.
PAGE I EPA/ROD/R04-88/040
4. Tltte end lulltltle
~(JPERFUND RECORD OF DECISION
-ependent Na~l, SC
I--~ond Remedial Action - Final
7. Author
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-PA/ROD/R04-88/040'
dependent Nail, SC
.econd Remedial Action - Final
16.
ABSTRACT (continued)
The selected remedial action for this site addressing ground water
remedy. The source control remedial action conducted at the site was
little or no impact on ground water quality in the area of the site.
action has no costs associated with it.
is a no action
determined to have
This remedial
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DECLARATION FOR THE RECORD OF DECISION
REMEDIAL ALTERNATIVE SELEcrION
Site
Independent Nail Ccrr.pany
Beaufort, Beaufort County, South Carolina
Statement of Purpose
This decision document presents the selected rew~ial action for this Site
developed in accordance with CERCIA as amended by SARA, and. to the extent
practicable, the National ContingenCy Plan.
Statement of Basis
This decision is based upon the administrative record for the Independent Nail
Canpany Site. The attached index identifies the items which ccmprise the
administrative record upon which the selection of a remedial action is based.
Description of Selected Remedy:
Operable Uni t Two for this site addresses groundwater. The remedial
investigation and endange~ent assessment support a no action alternative for
groundwater.
*
No Action
Operable Unit One for this site was a source control ~easure.
Decision for Operable Unit One was signed September 28, 1987,
action of solidification/stabilization was conducted in April
year.
The Record of
and the remedial
and May of this
Declaration
The selected remedy is protective of h~.an health and the environroent, attains
Federal and State requirements that are applicable or relevant and appropriate,
and is cost-effective. The statuatory preference. for treatrnent is not'
satisfied becaus~ treatment was found to be unnecessary. Contaminant levels in
groundwater were determined to present no Unffiinent or substantial threat to
h\..R'nan health or the environment; therefore, no treatment is necessary.
£(.~¥ 'jij
Greer C. Tidwell Date
Regional Administrator
':'\'. .,,- .
. "" t.',.
, d,:
'x.l.,,:
...). ::
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I:
I
,
SU~~Y 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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1.0
2.0.
3.0
4.0
5.0
6.0
7.0
8.0
TABLE OF CONTENTS
Page
Introduction[[[01
Site History[[[06
Analytical Results.................................................07
Endangerment Assessment............................................11
Enforcement
Analysis......................~.........................20
Community Relations History........................................20
State
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Figure 1-1
Figure 1-2
Figure 1-3
Figure 3-1
Table 3-1
.Table 4-1
Table 4-2
Attachment
Attachment 2 -
Attachment 3 -
LIST OF FIGURES AND TABLES
Location Plan...............................................02
Area Map[[[03
Drainage Map................................................04
Monitor Well Cluster Locatlons..............................08
Analytical
Results...........................................lO
Comparison of Contaminant Concentrations to Standards........18
Summary of Hazard Indices for Each Exposure Pathway..........21
ATTACHMENTS
1 -
. . . . . . .. . . . . . ... . . ... ............ .... Responsiveness SUlnmary
................................Administrative Record Index
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RECORD OF DECISION
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
INDEPENDENT NAIL COMP&~Y SITE
BEAUFORT COUNTY, SOUTH CAROLINA
1.0 Introduction
The.Independent Nail Company Site was added to the National Priorities List
(NPL) in September 1984. 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). The
Operable Unit 2 RI Report, which examines possible groundwater contamination at
the site, was issued June 20, 1988. The FS, which normally develops and
examines alternatives for remediation of the site, will not be performed at
this site due to the results of the RI and endangerment assessment.
The first Operable Unit remedial action consisted of solidification and
stabilization of contaminated soils/sediments at the Site, then ret~rning them
to the on-site lagoon two feet above the high water table.
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 is located near Beaufort, South Carolina on South
Carolina 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 00 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. A Seaboard Coast Line
Railroad spur parallels the site to the east. 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. The areas to the north, east and west are wooded. Major surface
waters with associated wetlands are located within 1.5 miles south of the
site. Other 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
south. Salt Creek may not be in the drainage path. A drainage map is shown on
Figure 1-3.
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-2-
LOCATION
PLAN
N
8000 0
. b--..J
1000
,
2000
,
SOOO I"E!T
,
LOCATION
INDEPENDEN PLAN
. ~- B~A~,FOR\ NAIL. CO. SIT
- c -~-=--~_~-=-C~ROLJNA E
I-I
,", ~-
,-
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-3-
.'
.
o ~ 100 150 200 250
l . , . , J
SCA1..E IN FEET
.
N.
FIGURE NO.
AREA MAP
INDEPENDENT NAIL CO. SI TE
BEAU FO.RT 'I S. CAROL' NA
1- 2
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-4-
~
--.
-~.:.~=!F---
~
ttI--..
"'--
MILES
~ WETLANDS
SOURCE: USGS. 1978
FIGURE NO.
.
DRAINAGE MAP
INDEPENDEN T NAI L CO. 51 TE
BEAUFORT. S. CAROLlhlA
1-3
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-5-
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 located around the area. Other local natural resources
incl~de sand and gravel pits and agricultural land scattered throughout the
area.
The U.S. Fish and Wildlife Service (1987) indicated that endangered and
threatened species may occur in the area of influence of the Independent Nail
Company Site. These species are the West Indian manatee, bald eagle, wood
stork and Arctic 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 groundwater ~ab1e. The Independent Nail Company plant is directly south of
the lagoon.
Groundwater is an important source of wat~r "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 groundwater 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 site 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.
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 map 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.
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2.0 Site History
PERMIT AND REGULATORY HISTORY
The Blake and Johnson Company (previous owners of the site) manufactured
metallic screws qnd 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 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. 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 iroundwater 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 groundwater was being affected by the wastes discharged to the lagoon.
Chromium, lead, iron, and mercury concentrations were found in excess of
applicable drinking water standards in some of these water samples.
Sampling per~ormed on April 21, 1980 indicated that concentrations of chromium
and lead in the groundwater 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 federal drinking water standards. Lead
concentrations were all below the federal drinking water standard. The federal
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 federal 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 federal drinking water standards, based on
local laboratory analytical data.
On June II, 1980, the Industrial and Agricultural Wastewater Division of SCDHEC
sent a letter to Blake and Johnson stating that groundwater at the facility
contained "chromium at approximately the concentration of the drinking water
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-7-
standard". Based on this information, there is little likelihood of finding
serious contamination of groundwater". The following day, a letter was sent by
SCDHEC to Independent Nail relating "we have recently completed evaluation of
groundwater 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 Groundwater 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".
3.0 Analytical Results
Monitor well clusters were installed at the Independent Nail Company Site to
document the presence or absence of groundwater contamination and to determine
the extent of contaminant migration (if any) from the lagoon area. After each
cluster was installed and developed, samples were collected and sent to a
subcontracted laboratory for metals analysis on a 48-hour turnaround basis.
Results from the subcontracted laboratory were used to determine locations for
subsequent well clusters.
A total of 27 monitor wells were installed in eight clusters (Figure 3-1).
Each cluster consists of one shallow (20-30'), one medium (45-55') and one deep
(69-82'). well screened in the unconsolidated sand above the Cooper Marl. Three
additional bedrock wells were installed in the Santee Limestone to monitor the
Floridan Aquifer at clusters 5, 6 and 8. The elevations of the screened
intervals are approximately the same for all shallow wells and all medium
wells. Deep wells are screened above the Cooper Marl, and therefore, the
screened interval depths of these wells vary with the depth to the Cooper ~arl
at each loc~tion. Water level measurements from piezometers installed during
the first operable unit investigation indicated that groundwater flows toward
the south. Consequently, well clusters were installed primarily in the
southern part of the site in an attempt to identify a contaminant plume.
Monitor well clusters 1, 2 and 3 (located south, west and east of the lagoon,
respectively) were installed and sampled first. Quick turnaround analysis of
groundwater samples from these clusters indicated no contamination. Based on
these results, only one additional downgradient well cluster was installed
(Cluster 7). Cluster 7 was located southeast of the lagoon near the
Independent Nail Company building where certain geophysical anomalies were
detected.
Additional clusters were installed near the old Beaufort County landfill,
upgradient from the lagoon, and in the area of the lagoon. Well cluster 6 was
located between cluster 2 and the old Beaufort County landfill to ensure that
no contaminants were migrating from the landfill toward the lagoon. Cluster 4
was installed to monitor groundwater north of the lagoon. Cluster 5 is located
at an upgradient location approximately 500 feet north of the lagoon, and
provides background soil and groundwater quality information. Cluster 8 was
-------
.. .._~--- ------
o ~O 100
)
I '
. .
u
. WELL
L.OCATION
MW-I\1
SC?I.S: IN FEET
REM It
MONITOR WELLS CLUSTER LOCATIONS
INDEPENDENT NAIL CO. SITE
8 E AUF 0 R T. S. C~ R 0 L I N A
- .0......-.-- ~ --- -- - -~
-.......----------
-
FIGURE NO]"'
3-1
--- - - - - - - -----===-=--- .
~- ---- -- ---
. -
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-9-
installed inside the fence. in the southern part of the former lagoon to
monitor the area where contaminated water had been discharged.
Groundwater samples were collected from each monitor well for metals and
cyanide analyses by CLP laboratories. The results of these analyses are shown
in Table 3-1.. Detection limits reported by the CLP laboratories varied
slightly from sample to sample. The detection limits shown in Table 3-1 are
the highest reported for each chemical from all of the samples. Actual
detection limits may be somewhat lower than those shown.
Monitoring wells MW-1S and MW-1M were sampled for target compound list (TCL)
organic compounds. Napthalene was detected in MW-1S at a concentration of 5
ug/l and was the only TCL organic compound detected in either sample.
The CLP groundwater data shown in Table 3-1 indicate that cyanide and many of
the TCL metals were detected at very low concentrations in some of the wells.
The data was compared to background concentrations found in monitor well
cluster 5. Because most metals were undetected in the ~ackground wells. the
detection limits were selected to represent background conditions. Most
detections were at concentrations that were just above the. detection limit and
were considered to approximate background conditions.
Detections that were elevated campared to background were arsenic and chromium
in MW-1S; mercury in MS-3S. MW-3M. MW-3D. ~~-6S. MW-6M. and MW-6D; and cyanide
in MW-6D. When compared to the Safe Drinking Water Act MCLs. only chromium and
mercury exceeded standards.
Chromium was detected just over the MCL of 0.050 mg/l at 0.058 mg/l in MW-1S.
Chromium contamination in MW-1S may be a result of wastewater disposal to the
lagoon because chromium is a known contaminant of the soil in the lagoon area,
and monitor well MW-1S is approximately 150 feet downgradient of the lagoon.
Mercury was detected at concentrations ranging from 0.0014 mg/l to 0.0034 mg/l
in monitor wells MW-3S. ~~-3M. ~~-3D and MW-6S. The MCL for mercury is 0.0002
mg/l. Mercury was not detected in groundwater samples from wells located in
the lagoon (cluster 8) or immediately downgradient of the lagoon (clusters 1
and 2) and was not detected in soil from the lagoon area. In addition. all
mercury detections carry the data qualifier "N". This quallfier identlfies
that there is an indication that mercury was present. however. the quality
control requirements necessary for confirmation were not met. The "N".
signifies that mercury was only tentatively identified in these samples.
4.0 Endangerment Assessment
Data obtained from upgradient well MW-5 is considered to be representative of
background concentrations of inorganic chemicals in the groundwater. These
data are shown in Table 3.1 together with the results of the CLP analyses of
groundwater from the other wells sampled during the investigation.
As has been noted above. the data in Table 3.1 shows that most chemicals
detected were at concentrations close to detection limits. Mercury was
tentatively identified at low concentrations in one set of samples (MW 6).
However, this chemical. which was not detected in soils at the site during the
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C-~ snauNn WA~~ RE:Lti;
IHDE?ENDENT HAIL Ca~rAHY :!iE
BEHUFii.iT, SOOTH C;'iiQLI1fA
RE.'! II
TABLE 3-1
r . Of Sb As Be C~ Cr Cu p~ Hq Hi 5~ Aq T1 In
i: VEil. HD. :
j' ,
I' I U . 032J1f U U .O~ .011 U U .018 U U U
I: IIV-I:: US U
~
I II: ur U U U U .005 U .QOIJ U U U U U U
0: Ul U .006JH U U .005 U U U U U U U U
HV- 2S: .023r U U U U U U U U U U U U U
/I: ur U U U U U U U U U U U U U
D: ur U .OQ~JN U U U U U U U U U U U
IIIf-~S: .02 U U U U U U .0043 .003JN U U U U .0Si
II: U U U U U U U .OO~ .0014JN U U U U .09a
D: U U U U U U U .004J . OO:tJN U U U U .OS4
1111-45: Ul U U U U .007 U U U U OR U U U
It: ur U U U U U U U U U UR U. U U
0: US U U U U U U U U U UR U U U
/l1i-:5: Ul U U U U U U U U U UR U . . U U
II: ur U U U U U U U .OOO2AJ!I U UR U U U
0: Ul U U U U U U U U U UR U U U
F: ur U U U U U U U U U U U U .C~1
~ U U .u u u u u U .0034JH U U U U .048
'1[: U U U U U U U U .0002JH U U U U .061
0: .11 U U U U U U U .00022JH U U U U .0:5
F: UI U U U U .U U U U U UR U U U
P!r::: UI U .012JH U U U U U U U UR U U U
II: UI U U U U U U U U U UR U U U
0: u: U U U U .007 U U U U UR U U U
/IV-55: U: U U U u .ooa u .002 U .007 U U U .037
II: .03JI U U U .005 .005 U U U U U U U .075
0: U: U .010 U U U U U U U U U U .043
F: UI U U U U U U .002 U U U U U .042
I
- .
.ET~TIDH :
l/1IT ' (0.01 <0.031 (0.010 (0.003 <0.005 (0.006 (0.009 <0.007 <0.0002 <0.011 <0.005 <0.00: (0.010 <0.070 '
. I
. II c:a::C:l!nt:i~ians are 19/1
= undetet:!d
= estilated value
= pres~tive evidenc! of presenc! of laterial
= ac indicates that d.ta is unusable
= I!%teeaed laboratory holdinq tis!
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-12-
first operable unit investigation, is thought to be an artifact of the sampling
and laboratory procedures and. therefore. will not be considered further.
Chromium was detec~ed in at least one well. MW-1S. at a concentration elevated
above background (58 ug/l) and. therefore is selected for evaluation.
The concentration of chromium detected in well MW-7D (7 ug/l) may be less than
or at background since it was not detected in the background well at detection
limits of 6 to 7 ug/l.
Cyanide was detected in wells MW-2. 3. 6 and 8. The detected concentrations of
20 ug/l in wells MW-2. 3. and 8 were above background as cyanide was not
detected in MW-5 at a detection limit of 10 ug/l. Concentrations in MW-6D had
a concentration of 110 ug/l. Therefore. cyanide is selected for evaluation.
Zinc was detected in wells MW 3. 6. and 8 at concentrations ranging from 31 to
98 ug/l. Zinc was not detected (at a detection limit of 70 ug/l) in wells of
the background well cluster. Since zinc is present at concentrations slightly
above background in three downgradient wells. it is selected for evaluation..
Of the other chemicals detected. arsenic and lead were detected in all wells at
concentrations near or below detection limits (detection limits were 7 to 10
ug/l for arsenic and 5 to 7 ug/l for lead). Based on the above. and the fact
that these inorganic compounds/elements were not elevated above background in
soils at the site. these metals in groundwater are not considered to be related
to operations at the site and will not be considered further. In addition.
cadmi~m and nickel. metals which were detected at elevated concentrations in
site soils. were detected in groundwater only once or twice at concentrations
at or below detection limits. Due to this low frequency of detection and low
concentrations. these chemicals are unlikely to contribute to potential
exposures and associated risk. and therefore, will not be considered in this
assessment.
In summary. chromium. cyanide and zinc are selected as indicator contaminants
of potentia~ concern in groundwater for the Independent Nail Company site.
4.1 PHYSICAL AND CHEMICAL PROPERTIES OF THE CHEMICALS OF POTENTIAL CONCERN
The physical and chemical properties of the chemicals of potential concern in
groundwater are important factors in determining the environmental transport
and fate of these chemicals. The class of chemical compounds to which a
chemical belongs will influence its properties: chromium and zinc are metals.
'cyanide is an inorganic acid/conjugate base. The following is a summary of
these characteristics for the indicator contaminants selected for the site.
Chromium
The mobility of chromium in the environment depends. to a large extent. on the
oxidations of the element. Chromium is most commonly found in the +3 (Cr Ill)
and +6 (Cr VI) oxidation states. Cr IV is thought to be more mobile through
the environment than Cr III. This is likely because Cr III is more readily
adsorbed or completed to soil particles. metal oxides. or organic matter than
is Cr VI. rendering it relatively immobile. Most of the Cr III found in soils
is in the form of mixed Cr III and Fe III oxides or in the lattice of
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-13-
minerals. However, Cr III can be mobilized in very acidic media
(Kabata-Pendias and Pendias 1984). The reduction of Cr IV to Cr III, and hence
a decrease. in its mobility, was observed by Bartlett and Kimble (1976) only in
soils containing organic matter, and not in a soil which was characterized as
"organic free". Schroeder and Lee (1975) found that Cr VI reduction also
occurs in the presence of ferrous iron (Fe II), dissolved sulfides, and organic
compounds, especially those with sulfhydryl groups. Cr III oxidation was found
to occur only in the presence of large amounts o~ MnO and at a very slow
rate by atmospheric oxygen. Both the Electric Power ~esearch Institute (EPRI
1986), and Bartlett and James (1979) also observed oxidation of Cr III to Cr VI
in 80i18 with high MnO. Their results point to an oxidation-reduction-
reoxidation scenario wtth a steady state or equilibrium being reached.
Cyanide
The mobility of cyanide is influenced by the cations with which it is
associated. The more soluble salts, such as sodium or potassium cyanide, will
be more mobile. Complex anions of cyanide, such as ferrocyanide, can be mobile
in soils (Alesii and Fuller 1976). Cyanide mobility was found to be pH
dependent; low pH soils decrease the mobility of cyanide. In addition, higher
iion oxide and clay content were also found to decrease the mobility of
cyanide. In general, though, cyanide was found to be very mobiJe in soil.
Ultimately, cyanide in soil or groundwater will be biodegraded. Both anaerobic
and aerobic degradation of cyanide has been reported with the ultimate
breakdown products .being carbon dioxide and ammonia. The rate of the
metabolism is not known, but would be related to the presence of microorganisms
capable of metabolizing cyanide as well as the concentrations of cyanide in the
soil or groundwater.
Zinc
The soil chemistry of zinc is governed by the pH of the soil. In acidic soils,
zinc adsorption is related to cation exchange sites, while in alkaline soils
the chemistry is dominated by organic ligands. Cation exchange processes will
be influenced by the type of cations moving through the soil. This implies
that when there are mobile metals, competition for the binding sites will
occur, and zinc may be mobilized. In more alkaline soi15 zinc can form an
organo-zinc complex, which would also increase the metal's mobility.
(Kabatas-Pendias and Pendias 1984).
Metal oxid~s also influence the mobility of zinc in soils. Zinc was found to
be highly associated with oxides. Clay is also capable of sorbing zinc. Soils
that contain high levels of calcium and phosphorous immobilize the metal
(Kabatas-Pendias and Pendias 1984).
4.2 MECHANISMS OF MIGRATION
Contaminants dissolved in groundwater may migrate both horizontally within an
aquifer as well as vertically between aquifers. As has been discussed in the
RI report, the permeability of the water table aquifer is high, but horizontal
movement is slow due to the low hydraulic gradient. This is exemplified by the
fact that it is estimated that the plume of the contamination in the water
table aquifer would only extend 515 feet from the source areas in the direction
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-14-
of flow. (This modeling was performed using a worst-case scenario and assuming
the groundwater contamination originated in 1969). Vertical movement of
groundwater in the water table aquifer would appear to be significant as the
site is located within an area of recharge for the Floridan Aquifer. A
semi-confining layer of sandy clay separates the water table aquifer from the
Floridan Aquifer. This layer is reportedly not continuous in the area of the
site, so downward migration of contamination to the Floridan Aquifer from the
water table aquifer is possible.
The results from sampling at different depths within the water table aquifer
indicate that contaminant levels are very similar in the shallow, medium and
deep wells of this aquifer. In most cases, these values may represent natural
levels since, generally, levels detected were near the detection limits below
which constituents were found in the background well. Although, as stated
above, the potential exists for contamination of the Floridan Aquifer from the
overlying water table aquifer, this is not demonstrated by the existing data.
Because remedial measures have already begun at the Independent Nail Company
site, further infiltration of soil-contaminants to the groundwater is not
expected. Therefore, for all exposure pathways, the maximum concentrations
presently found in the groundwater will be us~d as the plausible maximum
exposure concentration. Use of these maximum concentrations may overestimate
risk because most concentrations detected were much lower. Well data are
available for 150 feet to the south and approximately 250 feet southwest of the
old lagoon (MW-1 and MW-6 respectively). Therefore, the detected concen-
trations in MW-l, 3, and 6 were used as the assumed maximum concentrations in
the groundwater.
4.3 HUMAN RISK CHARACTERIZATION
The following presents a discussion of the potential human health risks
associated with the contaminants of potential concern in groundwater; chromium,
cyanide and zinc at the Independent Nail Company site.
4.3.1 TOXICITY CHARACTERIZATION
Chromium
Although epidemiological studies of worker populations have clearly established
that chromium VI is a human carcinogen by inhalation exposure, chromium VI has
not been shown to be carcinogenic by the ora!3route (EPA 1984b). An oral
reference does (RfD) for chromium VI of 5xlO mg/kg/day has been established
(EPA 1988a). An RfD is an estimate of the daily exposure to the human
population (including sensitive subpopulations) that is likely to be without
appreciable risk of deleterious health effects during a lifetime.
Cyanide
The carcinogenicity of cyanide has not been established. EPA (1984d) has
classified cyanide as a Group D agent (i.e., not classified with respect to
carcinogenicity). The oral reference dose (RfD)'for free cyanide is 0.02
mg/kg/day (EPA 1988a).
-------
-15-
Zinc
With respect to carcinogenicity, zinc is categorized by EPA (EPA 1984e)
Group D agent (i.e., not classified). An oral reference dose (RfD) for
0.21 mg/kg/day has been derived by EPA (1984e).
as a
zinc of
4.5 COMPARISON TO STANDARDS AND CRITERIA
Guidance provided in the Superfund Public Health Evaluation Manual (EPA 1986a)
directs that concentrations of contaminants at exposure points be compared with
applicable or relevant and appropriate requirements (ARARs) that have been
developed to protect human health. EPA's interim guidance on ARARs (EPA 1987b)
definesARARs as follows:
Applicable Requirements includes those cleanup standards, standards of
control, and other substantive environmental protection requirements,
criteria, or limitations promulgated under Federal or State law that
specifically address a hazardous substance, pollutant, contaminant,
remedial action, location, or other circumstances at a CERCLA site.
"Applicability" implies
the site satisfy all of
requirement...
that the remedial action or the circumstances at
the jurisdictional prerequisites of a
Relevant and Appropriate Requirements include those cleanup standards,
standards of control, and other substantive environmental protection
requirements, criteria, or limitations promulgated under Federal or
State law that, while not "applicable" to a hazardous. substance,
pollutant, contaminants, remedial action, location, or other
circumstance at a CERCLA site, address problems or situations
sufficiently similar to those encountered at the CERCLA site that their
use is well suited to the particular site.
For water that is or may be used for drinking, the maximum contaminant levels
under the Safe Drinking Water Act are generally the applicable or relevant and
appropriate standard. At the Independent Nail Company Site, where the ground
water is a potential source of drinking water, Maximum Contaminant Levels
(MCLs), are the relevant and appropriate requirements for groundwater. MCLs
are concentration standards which are enforceable by law, Health Advisories and
secondary MCLs are nonenforceable health-based goals and guidelines,
respectively.
Primary and Secondary Maximum Contaminant Limits (MCLs and SMCLs). Primary
MCLs are Federal drinking water standards promulgated under the Safe Drinking
Water Act (SDWA). Generally, a MCL for a toxic chemical represents the
allowable lifetime exposure to the contaminant for a 70-kg adult who is assumed
to ingest two liters of water per day. In addition to health factors, a MCL is
required by law to reflect the technological and economic feasibility of
removing the contaminant from the water supply. The limit set must be feasible
given the best available technology and treatment techniques (EPA 1986a).
-------
-16-
Secondary drinking water regulations consist primarily of secondary maximum
contaminant levels (SMCLs) . contaminants that primarily affect the aesthetic
qualities (such as taste and odor) of drinking water. Secondary MCLs are not
Federally enforceable standards, they are intended as guidelines for use by
States in regulating water supplies.
The State of South Carolina has promulgated drinking water standards (MCLs) by
adopting the Federal MCLs developed under SDWA. According to EPA guidance on
the. use of MCLs as ARARs (EPA 1987b), MCLs are applicable at the tap where the
water will be provided directly to 25 or more people or will be supplied to 15
or more service connections, but in addition are relevant and appropriate
requirements against which to evaluate groundwater quality.
Drinking Water Health Advisories. In addition to MCLs and MCLGs, EPA provides
drinking water suppliers with guidance on various chemicals that may be
encountered in a water system. The Office of Drinking Water's nonregulatory
health advisories are concentrations of contaminants in drinking water at which
adverse effects would not be anticipated to occur. A margin of safety is
included to protect sensitive members of the population. The health advisory
numbers are developed from data describing noncarcinogenic and end points of
toxicity. They do not incorporate quantitatively any potential carcinogenic
risks from such exposure. Health Advisories are further described in EPA
(1986a), which states that "under certain circumstances and when the
.appropriate toxicological data are available, health advisories may be
developed for one-day, ten-day, longer-term (several months to several years),
and lifetime durations of exposure. One-day and ten-day advisories are
calculated for a 10 kg child (a one-year old infant) assumed to drink one liter
of water per day. Lifetime health advisories are calculated for a 70 kg adult,
assumed to drink two liters of water per day. Longer term health advisories
are calculated for both a 10 kg child and a 70 kg adult."
Chromium, cyanide, and zinc have been detected in groundwater at the
Independent Nail Company site at maximum concentrations of 0.058 mg/liter,
0.110 mg/li~er and 0.098 mg/liter, respectively. A comparison of these
contaminant concentrations with drinking water MCLs, SMCLs, and Health
Advisories indicates that total chromium is the only groundwater contaminant at
the Independent Nail Company site which exceeds any of these standards or
criteria.
The MCL for total chromium in drinking water are 0.05 mg/liter and 0.12
mg/liter, respectively (EPA 1985e). The I-day, 10-day and lifetime drinking
water Health Advisories for chromium are 1.4 mg/liter, 1.4 mg/liter, and 0.12
mg/liter, respectively (EPA 1987a). The longer term drinking water Health
Advisory for chromium for a.70 kg adult and a 10 kg child are 0.84 mg/liter and
0.24 mg/liter, respectively (EPA 1987a). Thus, the highest total Chromium
concentration detected in groundwater at the Independent Nail Company site
(0.058 mg/liter) slightly exceeds the current Federal and State MCL (0.05
mg/liter), but is lower than the proposed SMCL (0.12 mg/liter). It should be
noted that the proposed secondary MCL is more than twice the highest
concentration detected at the site.
-------
-17-
No MCLs have been established for cyanide; however. drinking water Health
Advisories have been derived (EPA 1987a). The I-day, 10-day. and lifetime
Health Advisories for cyanide are 0.22 mg!liter. 0.22 mg!liter. and 0.154
mg!liter. respectively. The longer term Health Advisory for cyanide for a 70
kg adult and 10 kg child are 0.77 mg!liter and 0.22 mg/liter, respectively (EPA
1987a). Thus, the highest concentration of cyanide detected at the Independent
Nail Company site (0.110 mg!liter) is below each of these Health Advisory
criteria.
A secondary.MCL of 5 mg/liter has been established for zinc based on
organoleptic (taste/odor) considerations (EPA 1986e). The highest
concentration of zinc detected in groundwater at the Independent Nail Company
site (0.098 mg/liter) is well below the secondary MCL. No primary MCLs, or
drinking water Health Advisories for zinc have been established.
Table 4-1 presents a comparison of contaminant concentrations in groundwater
and various drinking water standards and criteria.
4.6 ESTIMATION OF EXPOSURE AND RISK
Estimates of human exposure to contaminants at the Independent Nail Company
Site will b~ determined using conservative assumptions. Conservative
assumptions tend to overestimate exposure so that the upper end of the range of
actual exposures. Human exposure can be expressed in terms of a chronic daily
intake (CDI), which is the amount of a substance taken into the body per unit
weight per unit of time. or mg/kg/day. . For noncarcinogens. the CDI is
determined by averaging intake over the period of exposure.
In evaluating health risks from exposure to noncarcinogens (the category into
which the three chemicals of potential concern at the site fall). risk
reference doses (RfDs) will be used. The RfD, expressed in units of mg/kg/day.
is an estimate of the daily exposure to the human population (including
sensitive subpopulations) that is likely to be without an appreciable risk of
deleterious.effects during a lifetime. RfDs are typically derived either from
human studies involving workplace exposures or from experimental animal
studies.
Potential risks for noncarcinogens are presented as the ratio of the chronic
daily intake exposure to the risk reference dose (CDI:RfD). This is a useful
reference point for gauging the potential adverse noncarcinogenic health
effects that could potentially occur. A hazard index less than 1 indicates
that an adverse noncarcinogenic health effect is unlikely to occur. A clear
conclusion should not be categorically made, however, that all hazard indices
less than one are acceptable and that all hazard indices greater than one are
unacceptable. This is a consequence of the perhaps one order of magnitude or
greater uncertainty inherent in estimates of the RED and COL.
4.7 SUMMARY AND CONCLUSIONS
Human Exposures and Risks
Potential human health impacts associated with the chemicals of potential
-------
-18-
TABLE 4-1
COMPAIISOM 0' COMIAMIMAMI COMtiMllAllOMI 1M GlOUMOYAlfl 10 DIIM~IMG WAltl SIAMDAIDS AND CI.lf'IA
...1111 AdviaOl'~ (c;.
.. .... ................ .............-.... ... ........... ....... ..... ............o.......
C""I"""""'I
(118'1 lie,.
(118/11..,.
(118/111., .
I'De~ 10'D8~ Loneer'ler. Ufell.
......................... ..................
10 .. cllild 10.. A(t.,11
........... ...........
(8III/.tl/"'~.
1.4 1.4 0.24 O.M 0.12
0.22 0.22 0.22 0.11 O.IH
.iune,. C~en'ra.lon
Delec'cd in Groundwa.er
',I..r~ IICL
h'and8r~ IICL
...... .................................... "'.-
...............
.............
ChrClaiua VI
0.058
0.05 ('olal Cr. (al
CrNlldu
0.110
llnc
0.098
S (bl
I
I
I
(al (PA 1985c
(I>I (PA 1986e
(e) If A 1981a
-------
-19-
concern in the groundwater at the site were assessed by (1) comparison of the
maximum detected chemical concentrations ~o standards [Applicable or Relevant
and Appropriate Requirements (ARARS)] or other criteria developed for the
protection of human health, and (2) development of exposure associated with
various groundwater uses and to derive quantitative estimates of associated
risks.
The maximum groundwater concentrations of the chemicals of potential concern
were compared to ARARs .or other guidance - Federal Maximum Contaminant Levels
(MCLs), Secondary Maximum Contaminant Levels (SMCLs), and drinking water Health
Advisories. This comparison revealed that the highest chromium concentration
detected in groundwater (0.058 mg/liter) slightly exceeded the MCL of 0.05
mg/liter for total chromium. However, all other contaminant concentrations
were below currently available MCL, SMCL, and/or Health Advisory drinking water
standards.
For the quantitative assessment of risk, three potential exposure pathways were
identified was the Independent Nail Company site:
o
o
o
ingestion of groundwat~r
ingestion of milk;
ingestion of. beef.
The chemicals of potential concern are each noncarcinogens when ingested, and
therefore, potential health risks associated with each chemical for each of the
above exposures were expressed as the ratio of the chronic daily intake to the
reference dose (CDI:RfD). The CDI:RfD ratios for each chemical within a given
pathway were summed to derive the hazard index. Table 4-2 presents a summary
of the CDIs and oral RfDs used in the present analysis for evaluating the
potential health risks of each contaminants. Also included in Table 4-2 is a
su~nary of the hazard indices associated with chemicals of potential concern
for each of the three exposure pathways evaluated. The hazard index for each
pathway was less than one, indicating there is a low potential for adverse
noncarcinogenic health effects from ingestion of groundwater, milk, and/or beef
at the Independent Nail Company site.
Wildlife Exposures and Risks
Risks to aquatic and terrestrial species potentially exposed to chromium,
cyanide, and zinc also were assessed. Since no water quality data is available
from surface water, potential exposures to aquatic life were assessed assuming
that groundwater chemicals of potential concern may discharge into Salt Creek
and its associated wetlands at concentrations equal to the maximum
concentrations detected in groundwater. Risks were estimated by comparing
these groundwater concentrations to the ambient water quality criteria for each
chemical. Potential exposures for terrestrial species were assessed assuming
that cows or other wildlife use contaminated groundwater as a sole source of
drinking water and ingest an amount of water daily that is easily equivalent to
20 percent of their body weight. The maximum concentrations of the chemicals
of potential concern in groundwater were again used as exposure
concentrations. Risks were determined by comparing the estimated chemical
intakes or the water concentration to toxic levels or not effect levels
identified from the literature.
-------
!---
-20-
Maximum concentrations of chromium and cyanide in groundwater each exceeded its
acute and chronic ambient (surface) water quality criteria, whereas
concentrations of zinc in groundwater were below its criteria. However, it is
not believed that any of the chemicals of potential concern at the
concentrations detected in the groundwater in the monitoring wells at the
Independent Nail Company site will reach Salt Creek or surrounding wetlands in
concentrations associated with toxic effects in aquatic life due to dispersion
and dilution of concentrations within groundwater and surface water.
Terrestrial wildlife species do not appear to be at any increased health risks
from the ingestion of chromium, cyanide and zinc at the maximum concentrations
detected in groundwater at the site as the water concentrations or estimated
intake levels are well below those levels believed to be associated with toxic
effects.
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 Nail Company are the two identified
Potentially Responsible Parties. A notice letter was sent to the Independent
Nail Company in June 1985. Since they declined to participate, EPA proceeded
to conduct the RIfFS. The RIfFS commenced in June 1985.
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 24, 1987 editions of the Beaufort Gazette, a daily paper
determined to be the most widely read in the area.
-------
-21-
TABLE 4-2
SUMMARY OF HAZARD INDICES FOR EACH EXP~SURE PATHWAya
Exposure Pathway/Contaminant
Chroni c Daily
Intake (CDI)
Over 74 Years
(mg/kg/day)
Oral Reference
Dose (RfD)
(mg/kg/day)
CDI:RfD
Ingestion of Contaminated Ground water:
Chromium VI
Cyanide
Zinc
1.8xlO-3
-3
3.SxlO 3
3.1xlO-
SxlO-3c
2xlO_2c
2.1xlO-ld
-1
3.6xlO 1
1.7SxlO-2
1.48xlO-
------------
HAZARD INDEX
... ---
S.SxlO_l«l)
Ingestion of Contaminated Milk:b
Chromium VI
Zinc
-6
1.2xlO-3
2xlO
Sxl 0- 3c. .
2.1xlO-ld
2xlO_4
9.5xlO-3
HAZARD INDEX
Ingestion of contaminated Beef:b
--- .
9~7~io:3(~i)
Chromium VI
Zinc
1xlO-4
2.7xlO-3
SxlO-3c
2.1xlO-ld
2xlO-2
1.3xlO-2
3.3X10-lr
-------
-22-
*
A public n~tice as to the availability of the Operable Unit One ROD
and the Remedial Design for Operable Unit One ran in May 1988 in the
Beaufort Gazette.
*
A public notice as to the availability of the draft Operable Unit Two
RI report and the proposed plan was run on June 30, 1988. This
notice also provided the public with an opportunity for a public
meeting and notification of the opening of the public comment
period. This public notice ran in the the Beaufort Gazette.
*
A press release providing the same information as the June 30 public
notice was also prepared.
No opposition to the recommended action is anticipated.
7.0
STATE INVOLVEMENT
The State of South Carolina has been actively involved with the Independent
Nail Company site since it was first discovered.
They have been a part of official document reviews and have concurred with
activities at the site to date.
8.0
SELECTED RE~EDIAL ALT~RNATIVE
From an analysis of all available and pertinent information regarding the
Independent Nail Company Site, it is concluded that additional remedial actions
are not necessary for the protection of human health or the environment.
Therefore the selected remedial alternative at the site is No Action.
It is believed that the source control remedial action conducted March 28 - May
27, 1988 at the site had little or no impact on groundwater quality in the area
of the site. After a final round of sampling to confirm this, a decision as to
whether monitoring of the wells at the site should be continued or the wells
abandoned will be made.
-------
-23-
COST OF RECOMMENDED REMEDIAL ACTION
This remedial action has no costs associated with it.
The remaining sampling and well abandonment costs have been included as part of
the,Operable Unit One Remedial Action costs.
THE STATUATORY DETERMINATIONS
*
Protection of Human Health and The Environment
The selected remedy is protective of human health and the
environment, as conditions at the site were shown in the risk
as~essment to pose no threat.
No unacceptable short-term risks or cross-media impacts will be
caused by this remedy.
*
Attainment of ARARs
The selected remedy will att~in all applicable or relevant and
appropriate requirements.
The following were identified as the Federal and State ARARs for this
site:
*
Occupational Safety and Health Act (OSHA)
No health and safety plan will be necessary.
*
Safe Drinking Water Act (SDWA)
The maximum concentration of chromium detected in a well on-site
was 58 ppb.
This is above the MCL for chromium (SO ug/l), but
less than half of the MCLG.
All other wells had chromium
concentrations less than the MCL.
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-24-
*
Endangered Species Act
The recommended remedial alternative is protective of species
listed as endangered or threatened under the Endangered Species
Act.
*
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 have been addressed in this ROD.
*
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.
*
Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to the Maximum Extent
Practicable (MEP).
No alternatives were developed for Operable Unit Two at this site as
the endangerment assessment showed there was no risk to human health
or the environment from groundwater.
Additionally, all except one
well had metals (inorganics) at concentrations less than any ARAR.
The one well contained chromium at .008 ppm over the federal drinking
water standard of .05 ppm. This amount is within the analytical
variance of 20% for CLP labs and is therefore not considered adequate
to justify an expensive treatment at the site.
-------
-25-
This remedy is protective, effective, attains ARARs and is the most
cost effective solution for the site.
For the above reasons, treatment of groundwater at this site is
impracticable.
*
Preference for treatment as a Principal Element.
The preference for treatment as a principal element was not
satisfied, due to the "no action" alternative having been determined
to be the best solution for the site.
OPERATION ANU MAINTENANCE
No long-term operation and maintenance requirements are expected for this
alternative.
The Operable Unit One ROD mentions long~term monitoring as a
possibility due to the lack of data on the status of groundwater.
-------
ATTACHMENT 1
Responsiveness Summary
1.
Overview
A press release announcing the opportunity for a public meeting was issued on
June 29, 1988. Public notices announcing the opportunity for a public meeting
and the opening of the public comment period appeared in the June 30 issue of
the Beaufort Gazette, the most widely read newspaper in the area of the
Independent Nail Company Site.
No requests for the meeting or comments on the
Operable Unit Two Remedial Investigation Report were received.
2.
Community Profile and History of Community Involvement
The City of Beaufort is located on the southeast side of Beaufor~ County.
is forty-five miles northeast of Savannah. Georgia, and thirty miles
It
no~th-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
resorts in the county (including Hilton Head) noted for their boating and
golf. There are numerous rivers, creeks, and public ~nd 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 also a large military presence in the county, with approximately
15,000 military personnel living there. In addition to the Air Station, the
Mar~ne 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 terms. There is also a 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 Board/Commission that oversees
environmental matters.
-------
-2-
The principal State agency involved with the Site is the South Carolina
Department of Health and Environmental Control (SCDHEC). SCDHEC has a broad
array of responsibilities, including conducting restaurant inspections,
monitoring water quality, and handling solid and hazardous waste issues. One
elected official said that any resident complaints about environmental matters
concerning the Site would be referred to SCDHEC.
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 NPL. 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 that 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 groundwater. Further investigations in the cour$e 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 them, 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 eKpressed by local officials during community
interviews are presented below:
-------
-3-
1.
Groundwater Contamination
Even though the homes and businesses around the Independent Nail Site
are coqnected 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 groundwater
contamination 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 threatened.
2.
Preservation of the Natural Environment
According to local officials, many of the residents who live in the area
do so because of its natural beauty. No residents have expressed
concern about the effect of the Independent Nail Site on their
environment. They have been involved in other local environmental
issues, however, and officials feel this general interest could become
focused on this s1te once the public is aware of its existence. For.
this reason, officials feel that in order to avoid any unnecessary
concern, it 1s especially important that any publicity about the Site be
as accurate and objective as possible.
3.
Possible Financial Liability
According to Site files, Beaufort County once owned the land now
occupied by the ~ite, and leased it to Blake and Johnson. 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 says that the
county is no longer designated a PRP. County officials, however, are
still interested in the PRP search process and are concerned that the
appropriate parties pay for the cleanup.
4.
Preservation of Beaufort's Ability to Attract Industry
Currently, one of the major industries in Beaufort County is tourism;
according to one local official, there is o~ly one chemical company in
the area. Yet one Beaufort County Councilman said that the county needs
both tourism and other, heavier industries. He believes that industries
other than those found in the tourist trade can provide Beaufort County
residents with jobs that have higher salaries and more potential for
advancement In order to encourage a business growth and diversity, the
Councilman does not want the county to. gain a reputation for hostility
to non-tourism industries. Therefore, the Councilman is concerned that
publicity about cleaning up the Site and finding PRPs to pay for the
cleanup may give Beaufort a reputation for being anti-industry.
3.
Summary of Public Comments and Agency Responses
As no comments, oral or written, were received, this Section is not
applieable.
-------
-4-
4.
Remaining Concerns
No remaining concerns have been identified.
Community Relations activities to date are listed in the ROD.
-------
A'ITACHHENT 2
-------
ll!~~/87
I~d?, ~h-"~:oglcal O~d~r
Jt{)E?8'{)E:'lT AA! l Dccc:nen ts
".aq~: :
DoCC':1el!t Nu!!lber: It()-001-t692 To 8716
Date:
I I
Title: Final Cam:
-------
ur~/~
!nd,x C~ronolo~ical Order
nCEPt'Cer.- ~~!~ OoC1::ner:ts
Document NL'IIIber: !N>-001-1.337 To 1.337
Title: (Certified I'lill Receipt)
T~: ~ESfICN)OCf
Author: none: none
Recipient: none: none
Attached: IND-001-133B
ItO-t01-1339
/ I
DoCU!llent Number: INH'Jel-1343 To 1343
Titl!: CEnV!lop!)
TyPe: OTHER
P.:.J~'":: = ~~:;~:
Vi~~~:". !. ~:~ ':i-~
Recipient: Bennett. Giezelle S: US EPA
Pag~: 2
-
Date:
Parent: I~1-1341
Date:
I I
Dc.c~uer:t ~~~~~~: I~D~~-l:~~ T~ 1349
/ /
Title: (~~tic Retu~r. ReceiPt)
Type: CXFRESFOOE1'CE
Author: none: no~~
Rec:.pie::t: R..kers. Gerold L:
In~epenGe~t Nail of SC
Parert: nO-OO:-l348
Date:
Occ"~r:t N~",~er: 1~:-l3S3 To 1353
Oa~~:
Titl!: CR~celpt for Ce~tificatio~)
Typ~: OY~ESPO'C~CE
A~thor: none: none
Recipient: Baumberger. I'Iartha: County of SHufort s:
Pa:-e1":: HD-0JH.2SZ
~
-----------
/ /
Oocu:ner.t Nl!mber: I~l-1360 To l368
/ /
Title: (Dome~tic Return Receipt)
Type: C(f.r~ESrtN)OCE
Author: no~e: no~e
Reciplent: Sigmund. Paul: County of Beaufort s:
Parent: INH01-1359
Date:
-------
'~/e7
Index Chro~~lo~ical Order
I~DEPEt{)eIT NAIL Documents
~ ~
"')"~" ..
.. J." ..
Doccment N~~e!': Ir-IH'J01-1379 To 1379
Date:
Title: (Domestic Return ReceiPt)
Type: ~B'a
Author: illegible: none
Recipient: Radford. tt;)nnan D: Vinson & Elkins
Attached: IN>-e01-1380 It0-e01-l3B1
I I
Do~nt Number: It{\-001-l380 To 1380
Pil"tllt: It'D-001-l379
Date:
J I
Title: (Ce!'tified rail ~ecei't)
TYDe: a:f'.c:E~FttDe-~f
A~th~r: no~e: no~e
ReClplent: P~c~ord. ~()r7~~ D: Vlnson & El~~ns
Doct!:!IE!r.t N~:nber: I~Z~2se To 02~
Parent: IN>-00Z-02~
Date:
---------------------- ------..----------------
I I
itle: (~ndwrittep no~e~ wi~h address of r.:Oil!)
Type: artiER
A~th~r: no~~: n~~~
Reciple~t: r.one: r.or:e
Do(:":rP.r.~ Nt!~~.?~: !~r.-\'c~:-e~ "'!', ~3;1
Oat'?:
------------------------..---
I I
---
Ti!l~: (Le~~er a::~~a~yi~g a ~~~u~~t f~r co~:e~ of the dra~! Work Plan)
Type: CXP.C:~5FtK'EN:E
Au~h~r: Rava~. :?:~ ::
'.,:. : ?O.
Recipient: Radford. tt;)nnan D: Vinson & Elkins
DocL'~~! N!:::!ber: nD-002-f382 To 03B3
Dote:
I I
Title: (Letter denying the request in order to substa~~iate the claim of co~fid~~~iality)
Type: CCPRESPCt{)OCE
Author: Ravan. Jack. E: US EPA
Recipient: Johnson. Richard C: Camp Dresser & l'Id
-------
U/~/87
I~d~x C~~o,~l~sical Ord~r
Ir.DEPOOENT t¥\Il ~I!'llents
P2.~~: 4
t))cument Number: 1r()-002~'""91 To e4~8
Parent: 11'0-002-0390
Date:
1 1
Title: Suamary of RenediaJ. Alternative Selection
Type: .fIlM
Author: none:
Recipient: n~:
lis EM
none
. '
Occument N,,:u~er: IM>-002-0Z33 To 0Z93
Parer.t: U0-00Z-t229
Date: 12./01/67
Title: Lease - Beaufort Plant
Type: PlN~
. Author: none: no!!e
Rec~pier.t: nor.e: r.or:~
--------------------------------------------------.-------------
----- -.------- -....-- ...----... _._-
DoCC'ller.t Number: IND-00Z-0299 To 0362
Pare!'t: 1~2-0Z94
Date: lZ/01/67
Title: (Lease a9~~~ ~~~n Coun~ of ~aufort and flake & Jo~nso~ Co)
Tyt.e: lfGq~ ro~~E','T
Author: !1o,e: nor.e
Recipient: rore: nor~
DoCl"'P.~! Nt::!!~'?~: H~:-12~ !o 1255
Pare~!: 1~1-12611
Date: 'l3/20/f2
Title: (Let!'?~ a,=ct;:rr.~::;yi:;; a ch~6 for ~~'? bili!"'=E in ful!. of th~ pur~t:ase pric~ for th'? Ol~ ~~ar,\.li~!
Scrool Rd property)
Ty~e: CtPP~S?:tr.':~.r.:
Author: HaI"VE')'. W B: Harvey Harvey & Battey
Recipient: Levin. Julian S: County of Beaufort s:
t)):ulIP.nt Num~er: It&00Z-t227 To em
Date: VI3/20/f.JJ
Title: (letter acconpanying a check for the balance in full of the purchase price of the Old Shanklin
School Road property) ,
Type: CtPRESPCWOCE
Author: HaM')'. W B: HaM')' HaM"f & Battey .
P.ec:i~ient: Levi!!. Julian 5: County of Beaufort s:
-------
1l/~/87
Index Chno~~logical Ord~r
I~EPOOENT ~IL DoC\l!lle!'!ts
Page: ~
Document Number: I~l-126Z To 126Z
Date: flj/ll/~
Title: (S!m1narizatio~s of test samoles taken)
Type: ~
Author: Gross. Robert G: SC Qept of Health & EnvironllP.ntal Co:ltrol
Recipitnt: Shephtrd. Willie: Blake & Johnson
Attached: I~{>-001-1Z63
. .
Docv:nt'llt NImIber: INH01-~~ To l.~
Date: fIj/ll/80
Title: (Letter regar~ins sar-,le~ sh~i~; cc~tacina~io:l f~ was,~J,er disp~~a! o~eratio:ls)
Type: CCPRESfIIJ'DOCE
Author: Gross. RIj~~rt G: :(. Cr!,t Of ~alth & Enviroml~i'lta! Co~trcl
Reclpien t: Shepherd. Willie: Blake & Johnson
Attachej: I~1-13~9
Ot-CL'mel!t No::";~r: N::~2-f2!.7 To 02.17
()zt~: 06/l.llf:OJ
Title: (L~!ter rega~di~~ s~,!~ analysl~\
TYDe: CCfRESPCt{)OCE .
Author: Gross. Ro~~rt G: $I: !)?::! (If lieal!~ & ~nvi~r!~,'~3.1 0:~~ro:
R~c:~ient: She~r.erc. Wlllle: 6:af~ & Johnson
Docl':Ip..~t Nl'mbe:-: I~-{\J~-CZZ2 To 0:12
Part'~ ~: I~~"t)2-02.20
Qate: e€/U/ilb
Title: (Le:ter regard:~g co~taiina,lon t~ be fo~nd thro~gh ~ll WJter s&~,le~)
Type: aPP.ESPCN:>EN:E
Author: ur~ss. F."~e...: u: SC Qeilt of Health & fnVlrO!1J!P.nral Co!l!rol
Recipient: Shepherd. Willie: Blake & Johnson
Document Number: INJ-001-13aZ To l305
Date: e2/2.6/81
Title: Potential Hazardous Waste Site Identification & Prel.il!'inary AssesSD1etIt
Type: PlPN
Author: none: US EPA
Recipient: none: none
-------
1l/?Id/87
Index Chronological Ord~r
I~EPE!«NT ~Il 1):,C'.''II'?n ts
Pag~: 6
--
- ----
Document Humber: IN>-001-1l92 To l300
Date: VJS/lB/81
Title: Potential Hazardo~s Waste Site Final Strategy Ce!e~ination
TYJIt: fIl.M
Author: illegible: US EPA
Recipient: none: none
Attached: IND-001-1301
Document NU!IIber: n(4l0Z~218 To 02.19
Dat!: U/I!6/81
Title: (letter regarding sal!I,le. of gl"OiJndwater)
Type: a:AAE'S~EN:E
Author: Duncan. Donald A: SC ~?~t ~' ~!l~~ ~ ~~viroM~nta1 Co~trol
Recipient: Shaw. Lewis: Bl!reau of Wastewater & Str?am Quality Control
Ooc~~nt N~~~,r: IND-001-028? T~ 0288
Pa!'!nt: I~~-€tOOl
Da!~: U/fl€/el
Titl~: (~ re~orting findin~s of contar.lnation of shal!~ aquifi~r)
Type: cx:PF.~~.~OCE
A!.!t~~r: Duncan. Do::ll.~~: 9: Deot o( Health & ~"vironnental Control
Reci~ier.t: Shaw. Lewis: SC Dept of Hel~~r. & Environmer:t.;l Cor:trol
Ooc~mer.t Nu~~~r: IND-0C:-1263 To 1263
Pa"l'Mt: I~~l-U52
Oa t ~ : 'l€ i:J..! 32.
Title: (Analytical services data sheet for solid Maste ar.d hydrolo;y)
Typ~: FINANCIAL/TECHNICAL
A::thor: none: 5C De~t of nealtn & Envirorurental Control
Recipient: none: none
Doc:unent Number: I~l-~ To l329
Parent: IH>-001-132S
Date: V£/21/B:.
Title: Analytical Servi~s Data Sheet for Solid Waste and I-ttdrology
Type: ~
Author: none: 9: Dept of Health & EnvirolWntaI Control
Recipient: none: none
-------
1/32/87
Ir,~~J. Chro~ol~;ical Ord~r
Ir{)E?~{)~IT r~IL DoClirre::ts
!"a~~: 7
--
Doa.'III!."nt NI!'IIber: I~Z~2.13 To 9216
Date: VIj/29/SA
Title: (Letter notifying of Potentially RfSpo:lsible Parties to und~rtake voluntary cleanup activities)
Type: CCPRE'SFQ()fM:f
Au~h~r: Oe-..ine. Thollas W: 1..5 EPA
Recipient: Rakers. Gerald l: Independent Nail of SC
DcCII~t NII'IIber:. I~l-l333 To 1334
Part"nt: I~l-l332
Date: 07/10/?I.
Title: ~~e~ter ackn~ledging recei~t o~ ~~~lier le~ter d~~ing any re~~o~si~i::!y or lia~i:ity fer
a~y ha:3r~ous sub~tar.ces on tne property)
Ty;;: ~.CI.~~o:rO~r.E
Author: P.akers. Gerald L: Independent Nail of ~
~~::~:~:-~: ~.ll~J. Gr~g~:y~: L~ :~~
-------..----------------------------------------
--------------.---------------------------------
(kCL"'IIE?r.~ Nt:,:,:ter: INJ-001-l33S To l3:?6
Date: 07/10/SA
'!i~:~: (~~_ll~te of 1~11~)
Ty~~: c::P,~ESPCWOC~
Aut~c~: Rake~s. Gerald~: Inde_~~1~~t ~ c~ SC
P.ec'::~:.~rt: FralE-Y. Gregory 0: US EPA
DoCl::ner.t NL'"':1ber: I~2~2Z0 To 0~
Date: 07/10/8'
Title: (Le~ter denying a~y re~;o~~~'ill!y or liability for a~ hazard~~s su~stance. !~t ray have
beer. relea~e~)
Type: cx:AAESP(N)eCE
Author: Rakers. Gerald L: Inde~endent Nail of SC
Reci~~ent: Fral~. Gregory D: US EPA
Attached: UO-00Z~Z2Z
Document Number: It{)-00Z~Z23 To e2Z3
Date: fJ9/J9/SA
Title: (Letter requesting an update of the status of Reference I4AW-ER)
Type: CCP.RESPCWOCf
Author: Rakers. Gerald l: Independent Nail of SC
P.ecipie!1t: Fra1~. Gre~ory D: US f?A
-------
- -- -
. - '-~'-
ut~/Pi7
Index Chronological Ord~r
I~EPOOE"':; MIL 1),C'1'IP.::tS
Page: 8
-----
-- ------
- ------
Document Number: HD-001-l332 To 1332
Date: 10/01/84
Ti tle: (Letter aCCQI1;1anying letters p.re'o'iously sent)
Type: OPAESPeJOOa. .
Author: Rakers. Gerald L: Inde~enden: Nail of SC
Recipient: Bennett. Giezelle S: US Ef'I\
Attached: IND-001-l333
Cocumer.t Number: I~D-002~224 to 8224
Date: 10/01/84
Title: (Letter respo~di~g to ea~lier cor~so~~d~n~)
Ty~e: CCflRES?Ct{)OCE
A~~h~r: ~3~~rs. S?r2~~ L: Ir.~~~~~~~~!'~il of SC
Recipier.t: Bennett. Giezelle S: US EPA
~:r'!l?~~ Nl ~~.~.: I'r.'-~1-::2? TO 1323
Pa~~!: I'~1-1:Z2
t'.Jte: 1~/::.'~
Ti~~e: {R:.:ew o~ ~ta!us cf ~~~roc~ of the facility)
Type: C;CPRf$"UlDfJ'CE
Author: genr:~!!. Glezelle s: L~ E~A
P.eclP~~~t: P;sLers. Ger~' L: In~e~ender!t Nail of ~
-------
OoCIJIIII?r.~ N~'11ber: Itt'-OO2~225 To 0::.2S
Date: 10/16/SiJ
Title: (Lette. regar~ing s~at~s u~~a:e)
T'(o~: CCP.~ESP!X)fJ'CE
Author: Bennett. Uiezelle S: US EPA
Recip.ier.t: Rakers. Gerlad L: Independent Nail of SC
Occ~mer.t Number: IND-001-l330 To 1331
Date: Vh/02/fI5
Title: Enforcement Profile
Type: PLAN
Author: none: none
Recipient: none: none
-------
'/30/87
.Index Chronol~gica.l Order
I~C~?~ C:;-'''' ~I L {):\~::'IP.!" ~s
Page: 9
-
-- ------ - -
-
~
I>Jcument Number: IM>-001-l333 To 1338
Parent: It{)-001-1337
Date: ~/20/ffi
Title: (Ro~ting and Transmit~al Slip)
Type:'~ ".
Author: AyaLJ. P: 110M
Recipient: Bennett. Giezelle S:
15EPA
DoCt!ment Number: IN)-OO2~ To VIlIb7
Date: e6/20/ffi
Title: {le~~er l1c~i!y.:.~~ of Po~el1t:a..!..:.) ~.~~~CI~::;l",~e Par<:.~~:
Type: CJ'?~S~OC~
A~~~:~: ~ii"e. :~~, 101: ~~ ~o~
Recipient: Sig~und. Paul: Cour.ty o! e~au!c~~ 9C
!):I~~'~-~ f"'''I~er: N:4'('l-12~ "'0 ~67
!)a~~: e6!26/~
~i!l~: :~~~~~- nc~i~yi~~ o~ ~:~:~~:~y ~~:po~:~~~~ ~~r~}
) .
. Ty~e: ~;'E5~OCE
Aut"cr': Devin~. Tl!ona.. "": US EPO
Recitl~~t: P~r:rs. ~ralc~: !"d~~e~d~~t ~~ o! SC
-----------------------------------------
Do~~mel1t Nu~~~!": It~.:-ll68 To 1271
Date: OS/26/$
Title: (L~~t~~ ~o~ifYl~g of Pote~t~ally R~~po~s:~le ?arty)
Typ~: cy.qES~EN:E
Au~hor: ~ii.ne. 7~ar.as \01: LOS EPA
Recipient: Si.~:nund. Paul: County of Beaufort SC
Document Nc~ber: I~1-1272 To l2lS
Dem: V:6IZ5!~
Title: (Letter notifying of Potentially Responsible Party)
Type: CCPRESfU'{)OCf
Aut~or: ~~ine. Thomas \01: 1.5 EPA
Recipient: BaL''I1berger. Martha: County of Beaufort 9C
-------
1l/?JlJ/87
Ind~x Chronolo9ical Ord~r
1~~c::'l)~.'" ~~:~ !nCt''''''r~s
?age: l~
-
---
- - -
- - ----- .-.-
Doculllel1t Number: 1~1-l339 To l340
Parer. t: IN>-00! -1337
Date: VIfJ/26/$
Title: (~tification that Independent Nail is a potentially responsible party)
Type: ~ESfttOOa
Author: Devine. Thallas W: US ~
Recipient: Rakers. Gerald L: Independent Nail. of ~
Document Nurnber: IKHel-1354 To 1358
Parent: INHI01-1."5Z
Date: e6/26/~
Title: (Notification of inten~ions a~d abilities und~r CERCLA)
Type: o:PRESP:WOCE
A!Jthor: Oevin~. Tt.ona:; W: t.IS EPA
~~cipier.t: Baumberger. Martha: County of Beaufort St.
---------------------
Docu!lP.nt N!.':nb~:'": ll-{I~l-l35j. TO lx'":S
Par"'~!: I.(~:-:~.9
Dat~: VJ5!25/f£
Ti~1~, (t¥,.;f;r~tio' of i~~~~.ici~ a~~ a~iliti",. urod~r CERCLAi
'!'y;.:: ~,=::$PCN)~~~
Author: Devine. Thcxr.1S W: LIS EPA
~.e::~i~.~t: Siql1l;:r.~. Pad: i;:;r:y c~ eea~f:rt $:
Doc!.''IJI?nt Number: n.[~~:-oo): To 0011
c.n'?; V:61Zf./$
ritl~: (Letter notifying of Potentially R~.p~~sible Parties)
Type: OJ'J~ES?J'{)fJ(,E
Author: Oe'.,.in~. Th~s W: US EPA
Recipient: Baumberger. Martha: County of Beaufort St
DoCL':nent Number: IN:>-002-t012 To 0013
Dat~: V£t:'5/$
Title: (Letter notifying of Potentially Responsible Parties for the cont~nation and related problems)
Type: C(AAESPCN)OCE
A:Jthor: Oe'.,.ine. Thcxras W: US EPA
Recipient: Rakers. Gerald L: Independer.t Nail of.St
-------
_."'--- ----.- - - .--
1/)7)/87
Index Chronological Order
I.~E?~E'l. N4~L (»c~;re!1 rs
?ag~: 11
--------
...-------------
---. ..-----
Doccment Number: IM>-001-13)Z 10 ~
Date: VfJ/2.7/ffJ
Title: (Domestic Return Receipt)
Type: ~fSfOOOU
A!lthor: . illegible: none
Recipient: Baumberger. /'!artha: County of Beaufort 9:
Attached: IND-001-~ IND-001-~
Document Number: I~1-l3S9 To 1359
Date: VfJ/Z7/$
Title: (~s!i~ Ret~rr. ReteiDt]
Type: a:P.~ES~C~.c~
Author: illegible: no~e
Re~i~ie~t: Si~",~~. c3~:: C'u~~:& eea~fort $:
Attach~d: Ir~001'1~: !~~1-1361
---------... - ----.,.------------
DoCUJnl?nt Nu:r.~er: I~[o..OO:-l~€.c: To:: 12.~
Date: 07/0:,!~
Title: (Le!te~ a~~~cwle~;i~g ~~e ~~ei:! ~' a orevi,~s l~!ter l~~ui~i~~ ab~~t t~e release ~f h~21~~~~S
subs tances) .
Type: CORRESPOND:~E
Author: Si~"ur.c. ?a~l: Cour.~:' ~awfort SC
Reci~ie~~: ~.ir.~. i~~j W: ~~ E?~
Attac~e~: IND-0el-1265
---------------------------------------
~cu:nen NI:,~~r: I~2~~€ To 02.26
Date: 0!103/~
Title: (Lette~ stati~g that "0 facility had yet been built on the ~ite as of 03/08/68)
TYOIe: a:PF.ESPCt{)OCE .
Author: Sigmund. Paul: Coanry of Beaufort 9:
Recipient: Q:.vir!e. T~~S W: US EPA
Document NI:':1ber: Ir{)-OOZ-02.Z8 To 02.2.8
Date: 07/12/~
Title: (Letter confirming an extension until 01/08/85)
Type: CtRRESftWEJa
Author: McOill. James N: County of Beaufort SC
Recipient: /'\acfarlene. Kirlt: US EPA
-------
1l/~/87
Index Chronolo;ical Order
I~~:o~~~: NP.!L Do~~~~~s
Page: 12
...- -------
----.-..---
--------
DoCWDe!lt Number: Ir&e01-LZ58 To 1Z61
Date: 07/17/$
Title: (Letter addressl!lg se'~ral aspects of the Hazard Ranki!lg Package)
Type: c:x:RR~EN::f .
Author: Rakers. Ge!'ud L: !nde,endent Nail of 9:
Recipient: Bennett. Giezelle S: 1.6. EPA
DoCl'!IP.nt N\:~~~~: I~D-0C~-l3ZC: To l3Z7
Q.3te: f7/17!e5
Title: (Lett~r regar~i~g s~~ral aspects and conc~rns Of tn.e ha:ardous ranki.; ~3:~~;e)
TYDe: CCP.~E:,P(N)OCE
Au!~~r: P~kers. (;:rald L: indepe1ldent r-w.l of 51:
Recipient: Bennett. Giezelle S: US EPA
-------
-------
DoCU!II!r.t Number: INJ-00Z-eU9 To 0nz.
Date: 07/17/e5
Title: (Letter addressing sew-ral aspects of the Hazard Ranking Package)
Tyoe~ CCP.QE5P.:NJE:"t'E
Aut~or: Rakers. ~rald L:
I"de~eodent ~~ of SC
Re~~~ie~t: e~"~e!t. S:~:~lle S: US EPA
A~ta:hec: I~~2-e:3G
--------...-..-----------------
OoCU!ll!~t N~~ber: I~D-0L)Z-C:S4 To e:97
Da~e: 0:/3~!~
Title: (letter addressing Questio~s raised in letter of e6/26/e5j
Type: CCPRESfU\IJ&E
Author: !-bIP.ll. Ladson F: ~ll Gibson and Boney
Recipient: Oevine. Thar.u W: US fPA
Attached: I~L~::9S I~OOZ-0299
Document Number: I~l-0483 To to;83
Parent: I~~1.~
Da te: fJ3/26/ 'as
Title: (Letter transmitting InteriJI Report for Independent tWl)
Type: ~E$R:N)OCE
Author: Susan. ~5 A: CC Johnson & AssocL1tes
Recipient: Johnson. Richard C: Carap Dresser & /'Id(ee
-------
. .. ----'O --
. --------
- - - -.--- - -.. -..._-
1~/87
Index Chronolo;ical Ord~r
I~EPecENT t~!L OoCU!:Ie:1t5
Page: :'3
- --=:.z:
==~:_----
--
Document Nu!llber: I~l+U!l To 0511
Da~: VI3/27/e5
Cor. fidential
Title: Inter~ R~dial Inve~tigatio~/~ea5i~ility Study
Typt: fILM
Author: notle: none
Recip1tnt:~: US EM
Attached: IND-0el-0482
1~1-04e3
Oocumer.t NI!i"1ber: I~l~ To ~
Parer.t: J~l~l
Da te: fF:.t:.7/'f5
Title: (letter a~c~pa~yi~g 5u~mi55~~~ c' Interim Re,~rt)
Type: IXPRESFttDOCE
A~tho;: Jo~n$on. P~:~a~d c: ~, Dre$5er & McKee
Recipient: Wright. RU55ell L: l!5 EPA
------------------------------------------------------------------.-
--------------------
Oocument Nl!mber: J~l-12S6 To l2S7
Date: 10/21/~
:tle: (Letter re.~onding to e3~!ie~ co~cern5 a~o~t !he Hazard R~nrlng Package! .
Tyrce: W'.~E~FtN):.~E
Co~~itio~: ~LLEGIBLE
A~~~jr: Green. Rlchard D: US E?A
Rec:jie~t: Rak~r5. Ge~al~~: i~~:~end~~t r~il cf SC.
Do:;J~.?::t '~~r.'~~r: I~~171:6tJ ;~ 1351
Ca'e~t: 1~~~~1-134C
Ca~e: 1~/::/~.
Title: (Letter reg3r~:'I!~ corce:"l!~ at:)!Jt the Hazardous RanU.l!~ Pacl'.zg:s. ~h' P.e'medial In"'!stiQatior..'~ea.ib~~
Study and other Po~e~lZlly Responsible Partie~)
Type: CCJI.~ESPCN)OCE
Author: Green, Richard D: US EPA
Rt'cipient: P.3ker5, Gerald L: - Independent Nail of s:
Docllillent Number: I~Z-0014 To eelS
Date: 10/21/85
Title: (Letter addressing concerns about the Hazard Ranking Packages of the R~dial Investigation/Feasibility
Study)
Type: a:RRESPCN)E?CE
AI:~h:):": G~r.. Ri~~.a.r~ D: L': E?A
~ipient: Raker5, Gerald L: Independent Nail of s:
-------
!
1l/:tlJ/87
Index Chronolo~ic.U Order
I,{):?E..'.(j:,o~ ~.L Do:u~~~.
Page: 14
--
Document Number: INHJ01-l348 To l348
Date: 10/2.4jffi
Title: (Domestic Return Rece:pt)
Type: CXPJ{£SP(N)OCE
A~tho~: r.one: none
Recipient: Rakers. Gerald i..: Independent Nail of SC
Attached: INH01-1349 I~1-1350
DcC1.'~nt N~~er: I~1~S9 To 0480
Date: 10/2.8/85
:itl~: Da!a M~i.a~~~~ °la~
Ty~e: P~
A~thor: S~san. J~~. A:
Reci~ient: none: US EPA
At~ach~d: IND-001-0460
cc J~~rso~ & Asso~iates
I'{}.OOl-01€l
-------
DoculIII?nt Number: I~l~ To 046e
P~.-~~! :
H(~;;-+1S9
()Q~e: 1.0/28/85
Title: (Letter accom,anying submissior. c' Data Manag~~t ?~ar;j
Type: CXP.qESF\)'IJOCE
Author: Johnson. Ric~Qrd ::
Recicient: Cherry. Al: US EPA
~':'~ Dr~.ser & !'Io:Kee
----------
--------------
Docu~~~ N~~ber: !~~~:-0461 io 0451
Pa~e~t: i~(~;;.....'4:.9
Cate: le/28/$
Title: (~ transmitti~g draft Data Manaement Plan)
Type: a:PRESFtWOCE
A~thor: ~san. Jame. A: CC Jc~nsor: & Associates
Recipient: Johnson, Richa~ C: Ca.'IIP Dresser' Mee
!k>c~~r.t NI.'::I:ler: INHJ01-12.S4 To l2.56
Date: l1/VI5/85
Title: (Letter confinuing a phone call expressing a desire to participate in the Remedial Investigation/Feasibility
Study)
Type: CCRRESPCN)OCf
A~tho~: P2~~or~. ~b~r D: Vinsor. & Elkir.s
Recipient: Green, Richard 0: 1.5 EPA
-------
3fI!/87
Ind~x Chronological Order
I!IO:?OOENT MIL Doo.-rents
---
:Joannent Number: II'O-e01-1341 To 1342
Date: U/VI5/ffJ
Title: (let!er ~~~inn:ng phone ~~versation and stating a wish to participate in th~ Remedial I
nvestigation/feasibili~ Study)
Type: a::AAESPCt.()OCE
Author: Radford. Normn 0: Vinson & Elkins
Recipient: G~~r.. P~c~ard 0: US EPR
Attached: IH>-e01-l343
)oa.lfIIl"nt NU!IIber: I~Z-f363 To 0364
Date: U/VI5/ffJ
Title: (Letter confirming a Dr~.io~s ph~~~ call of participatio~ in the R~dial Inve~tiga!ion/Feas~ty
Study)
Type: a:AA~SPCt.()N:E
A~~h~~: Ra~/j~'. ~t.r.r~~~: Vi~s~r ~ Elkins
Re~ipient: Gr~n. P~chard D: ~S EPA
-----------------------
,=ulIII?nt Ni:;nber: H{}-ool-1.2S3 To l2S3
Date: 12/VIS/$
r:tle: (Ca~r l~!ier for a ieQY?~ted draft Wor~ ~lan)
:...:.:: ~.r>:s~r~::
A'~t~o-: [).?vine. Thcl'ns W: U'S EPA
~eclP~~'!: Ra~fOid. t~nr~r D: Vlnso~ & Elkins
--------
)::)C~lIII?nt Number: nD-OO!-1249 To 1250
Date: 01/09/$
Title: (letter reQuesting an a~d:!ior.al ~~irty days to ~nt C~ !~~. Pro,osed Plan of Actio~ for
the Remedial Invest:gation/Feasibility Study)
Typ~: C(P,RES~~E
Author: Radford. Norman 0: Vinson & Elkins
Re~ipient: ~iine. Thomas W: US EPA .
Pa~~: 15
-
-------...-
--------.
-------
11/33/87
Index C~ronclo1ical Order
J~DE?END~ NAIL Doc~~nts
Page: 16
-
- ----------------
-- -------
Docullll'nt Number: Ir{Hl01-l344 To l345
Date: 01/f/$/$
Title: (ReQuest for thi~ty a~ditio~al days tc comment on the prop~se~ plan of action for t~e R~~ial
Investigation/Feasibility Study)
Type: (mRf'SP(J()OCE
Author: Radford. ft)rman 0: Vinson' Elkins
Recipient: Olovine. Thanas W: US EPA
Attached: INHJ01-l346
Document Number: INHJ01-l346 To 1347
Parent: INHJ01-l344
Date: el/09/ffi
Title: (ReQuest for a coPy of re~ords pursuant to the Freedom of Inforr.~tio" A~t re~uest)
Tyc.~: aYRfSCIQIOOCE
Author: Radford. Norman D:
ReciDier.t: none: US EPA
Vinson & Elkins
Docl''Ie:.t N~''''~.~r: N:-~:-B::3 T., ~x.4
Date: 02/24/r£
Ti tle: (?eQue:: r for e) :~'.. :i:-."' c.f '::m:(?~ ~ :c; ~::":)
Type: aY.~E:.~~r.:
Au~hlJr: F.;~ford. Norm3n D: V;'".s~"; '~':'''il1S
Recipient: Devine. i~ama~~: US E~A
eke!. ~~r N!.'o::~'er: l'(}-oo2-e;I:~. T~ C3-=.n
Date: 0i./24/r£
Title: (Re~uest fOi e~~e~sio~ ~f ri~ to conr.,?~~ O~ the prop~s~d ~:an of aC!lO~ fei !~e ~~~~~
Investigatior.)
Type: a:AAESPCW:N:E
Author: P.a~ford. Norma" 0: Vinson & Elkins
. Recipient: ~/ine. Thomas W: US EPA
Document Number: JI'{)-001-1381 To l.~
Parer:t: II'{)-001-1379
Da te: fJ3/ZlIF.J5
Title: (Letter regardlng srotus of the Remedial Investigatio~/Feasibility Study)
Type: CG'i:fSm.DEN:E
Author: Devine. Tnomas W: US EPA
Recipient: P4dfor~. Norman 0: Vinson & Elkins
-------
11/3a/87
Ind~x Chno~l~ical Order
l~C~~~~.~ ~~~L Ct.:~~rts
Pa~'?: 17
---
Qxument Number: If{)-001-l322 To l..-:qz
Date: 03/26/85
Title: (Letter of tra~s~ttal for bud~e! summa~)
Type: ~
Author: Susan. James A:
Recipient: Dixon. Tim thy:
Attached: IND-001-1323
c:c Johnson & Associates
L6fPA
DoculllE'nt NI.r"':~er: IrD-«l-1l2l To 1Z28
Parent: Ir~l-lZ.l9
Oa te: 0'3/2.7/85
!itl~: !"ter~ R:AA,'CERCLA ~:I...darIC~ On t-f'::~ntiguo:Js Sites & O~I-Site ~.anag~i'lt c! W3~te & Trea~i!t
F.esid~e
Ty~'?: ?Lo,~
Author: ~rte'. J Winston: US EPA
R'?cipient: file: ~~ ~?A
----
Doc~mer! N~~~e~: IND-00~-124t To 1Z4~
Pa~::t: I~(I-001-:'::39
Dote: 0t./1J2/::i.
Title: (l~'!e~ fX;"~.Sl'~ :~:er~.: :r. a ~~~i~~ i~ ~:lan:aJ
TY!'~: C(P.c'~S~EN:E
Au:~cr: Radfor~. '~nna~ D:
Reci~ier.t: ~:~~. ~r.~~s ft:
V':':1S0~, & EliUr.~
!,,'$ E?t.
-----------
------
DoCU'IP.~t N~:nt,,?;: I'C--OO:-:2:9 To 1239
Date: 04/1~.'e€
Title: !~~r shept f~' ~\
Type: Ct'f!RESFQ'VOCE
Author: none: none
P.~ciplent: none: none
Attached: IND-001-1Z40
DocUIIP.I'!t N!.''II~er: I~l-1236 To ~
Date: 04/11/85
Title: (Cover sheet for memo)
Type: Ct:FRE'Sftt{)OCf
Author: Radford. Norman 0:
Recipient: none: none
Atta~hed: I~!-1237
Vinson & Elkins
-------
1l/~/87
Ir.d~x C~~~ol~jical Ord~r
I~E?e-Ve\'T ~IL DoC'JrrP-r.ts
Pag~: 1:
Doculllt'nt Number: I~1-1237 To 1238
Parent: IN>-t01-lZ36
Date: 84/11/'(£,
Title: (Letter reQuesting c:ari~icatio~ of ~h~ ~~~rsh:~ resoo,sibility according to C~~-A)
Type: aPJI.ESPCt{)EH:f
Autho": Radford. "brmn D: Vinso;, & Elkins
Reci4lient: Devine. Thomas W: US EPA
. .."
Document Number: I~Z~~7 To 0?Jil
ODt~: 0f./U/f!15
Title: (Memo regarding Inde~e~de..~ Nail)
Type: a:f..~ESPCNJ:N:E
A~~~cr: n~~e: UF. EPA
Recipient: none: r.o~e
-----------------
Doc~ment N!.!l!1ber: N)-OO2-e353 To 0.})9
D.ate: 04/11/$
Title: (Let~er stating o~he; fi~dings)
Type: a:P.qE:,~VOCE
A~!h~r: Rac~Q':. '~~r. ~:
V:..r,5:1:1 & El~.:~,s
Recipient: Devine. Tr.CXI\3.s \oj: US EPA
-----------
Doccment Nu",~e~: Ir~-i~'l"'~~2 To i235
Parer.t: H(I-OO:-1229
Dat~: 04/29/'05
Title: Laboratory Analysls ReDort
Tyre: FI~~!AL/TECHN!CA~
Author: no~e: DavlS & Flajd
Recipient: none: Independent Nail of SC
DoC1J~nt Number: I~2-e373 To 0376
Parent: IN>-t02~370
Da te: 84/28/'(£,
Title: Laboratory Analysis Report
Type: FI~IAL/T~ICAl
Author: none: Davis & Floyd
Recipient: none: Independent Nail of SC
-------
1-
. - ----
-- -- - ----- ----
1l/)"lJ/87
Ind~x Chronclo;ical Ord~r
INJE?OOENT ~IL ~u~r.~s
Pag~: 15
-
DJcument ~r: IPC:H01-1229 To 1231
Date: VIS/2e/ffJ
Title: (CcM>r letter for re~nt Laboratory Analysis)
Type: CXFRESf(N)EN:E
Aut~or: Ra~ford. ~~I! D: Vinson & ElId"S
Recipient: DeYine. Thanas W: l.6 fIlA
Attach!d: IND-001-1232
Document Nt;t:I~~r: I~~2~37e To e37Z
Da te: 06/20/85
Title: :Le~t~r accom~a~ying lab ~~,les from th~ la9~~)
Type: CCPRES~EJ'CE
Au~~cr: P~GfOr~. No~J" 0:
Recipient: Devine. Thomas W:
Atta~h~~: IND-00:~~!j
Vi:lsc': & Eltins
us EPA
---------
Docu~nt NUllber: IN:'-OOl~93 To 0691
Oa !e: 05;'?Il.'$
.Title: Remedial Inve~tigatio~/Feasibility 'tudy
I
Type: ~
A~:~~r: Susan. J~j A: CC Jo~nsor. & Psso~te~
Reclcier.t: Wrlght. Russell L: ~~ EPA
-----
Do:~~r.t N~'I1!:!er: 1~{I..~:.::1.9 To 1220
Cate: 07/01/~
Tltle: (letter stating C~~C~~ regulations and th~ir effect on Remedial Actio~ at Ir.deD~"dent Nail)
~ype: CCFRE~!=?l)e-~E
Author: Radford. Norman 0: Vinson & Elkins
Recipient: Devine. Thomas W: US EFA
Attached: lND-001-l22l
Documnt Number: V(H)02~ To 8378
Cate: 07/01/ffJ
Title: (letter regarding $alllple results and request to /"eIrove Independent tW.l fror! the National
Priorities List)
Type: o:RRESPtWOCE
Author: P4~ford. Nonnan 0: Vinson & Elkins
Recipient: Devine. Thomas W: US EPA
-------
- ---..
---- - --~. ----...-
U/~/87
Ind~x C-h~!'Iolo1ical. Order
N)EPOO:N: rwL OOCI.'ments
Pag~: 2~
OocuIIIent Number: I~l-l2l8 To 1218
Date: VJ3/0l/fj£,
Title: (Letter in response to letter of ~/2.0/'r:FJ and 07/01/'r:FJ detailing the position on CERCLA regulatior!s)
Type: ~ESRJ()f1CE
Author: Tobin. Patrick "': US EM
Recipient: Radford. ~rman 0: Vinson' Elkins
DoCU'ller.t Nu:nber: It{)-00;;~379 To 0379
Date: VJ3/01/85
Title: (Formal reques~ to have ac~ss to r"d~~e~dent ~il fo~ the purpcse of conducti~g :he R~dlal
Investigation/Feasibillty Study activities)
Type: ~.~E$P(N)~~
Acthor: Tobin. Patrick~: L~ EPA
Reci.;rien t: R4c! (o.-d. Ncrr..a:. D: v':' ,1 SO;, & El1
-------
/)7)/87
Ind~x Chronological Order
I~E?OOENT MIL Docu'IE!!!ts
Pag~: 21
DoOllllt'ftt N\!:nber: I~1~Z91 To e292
Pa~nt:'lK>-001~
Da te: V13/12/f!1S
Title: (Ll"tt~r giving consent for US E?A entry onto leased pro~rty where lagOO:1 of concern is lo~ted)
Type: (XRRfSR:N)8U
A'Jthor: Radford. t~nnJn 0: Vinso:'l & Elkins
Recipient: Tobin. Patrick It: US EM
Document Nur.tler: IN:H01-l2l5 ;0 Ul5
Dite: fJOi 1~/f1S
Title: (Ca~r letter for th~ tenta!ive Field Sched~le for Ind~,~~d~ilt ttUl)
Type: Ct)U\ESfUIOOCE
A~thor: Roth. Th~1s~: L~ ~p~
Recipient: RG~.ers. Gerald L: Independer.t Nail of SC
OoC!.::tI'?nt Nl!rn~er: I/IIHI0Z-0~ To 0385
Date: fI3/~/P£i
Title: (Certified ~ R~celPt5)
Type: ~ESfUlO~(,E
Aut~r: none: none
Recipier.t: Be~~. M E: ro~e
Atta,=hed: II{)-0.~2-ex' NH~~:-e~
-------
Oocumen t N!:;nbe r: Pi.....oo: -13;:~ To 1321
Oa te: €f: / ::.:/ (;;.
Title: (Reqye~t for acce.~ to the property adjoining Ind~p~ndent r~il)
Tyre: a:PPES~DE1'(E
Author: Macfarlane. r~rk: US EPA
Recipient: none: none
DoC\.'!ller.t Number: I/IIHI02-f387 To 0387
Pa~nt: IM>-002-0?86
Dire: 08/~/f1S
Title: (Certified Mail Receipts)
Type: ~ESfUIOEN:f
Author: none: none
Recipient: Trask. Jc1!IIeS: none
-------
1l/~/87
Ind~x ChronOlogical Ord~r
I~:?OOOO ~rL DoCuments
Pag~: z.:
-----------
------------------------
Ooc\HAent Number: IN>-'tJ02~ To 8389
Parent: 1~2-<):B5
Date: VIJ/lE/'(b
Title: (Draft of a letter requesting access to property adjoi~1g Indep~~dent r~ to co~duct field
in~tigations)
Type: OF,RESfII:N)~a
Author: I'Iacfarlane. Kirk: US £FA
Re(ioient: Tras~. ~s: ~e
DoCt/ment Number: IN>-'tJ01-1114 To 1214
Da~: fIJ/2~/~
Title: Field "Activities at Independent ~(Li1 (partial listing of partic:oants in the R~dial Investiqa!i?~)
Typ~: a:P.P"E'S~DOCE
Author: Roth, Thona.~: iJS EPA
Recipler.!: P3~ers, Gerald~: Inde~~r.'~~t r~ of SC
Coc~mer,t N~~~er: I~~-1317 To 1317
Parent: I'~~-1316
Dc !~: 'l€!Z0/~
Ti~:e: ~Dom?~~ic R~t~;~ ~~;i:=~~
Typ~: tXPY::S?a'[E"r.E
A!Jth~r: illegible: ~one
R~cirlent: BP.~~, ~ E: r:o~~
Cocumeot N~~ber: IND-001-1~1~ '0 1315
Date: e€/2J./f!15
Title: (~:tic Ret~r" P.ecei~!)
Type: aJ1,RESPCI'DOCE
Author: illegible: DOne
ReClplent: Bellamy. Caroline: none
Attached: IN>-'tJ01-1317
Doc~':lP.nt Nu"'~e~: I~l-l3lB To 1319
Da te: fJ3/27/f!JS
Title: (Letter regarding pennission to conduct an investigatio~ on Independent r~)
Type: aJ1,RESAN)0Cf
Author: Howell. Ladson F: tbfell Gibson and Boney
Recipier.t: I'\lcfarune. Kirk: US fPA
-------
i/)a/87
Ind~x Chronological Order
I~EPOOEJ'IT N4Il Doa.'!IIl'nts
Page: Z3
- -
...--. --
--- ...-::::::.:.
DoclI1IIent Number: IP(H}01-1064 To 1109
Da te: Vl?1'Z!)/~ . Cor. f ider. ti.1l
Title: Project Operatio~s Plan
Type: fIUIH
Au!hor: noli!: no~
Recipient: none: US EllA
DoCl'IIP.r.t Nt.:mbe~: n(H)01~1.9 ic l~
Date: 09/24/80
Title: Re{ised Projec! Operatio~s Pla~
Type: P'LPN
A'lt~or: f!fJlI£>: Ca."':' Dress£>!'" & "1cr.ee
Recipient: none: US EPA
Document NL!m~ei: 1t{)-001~371 To 0380
Date: 10/14/~
"itle: Cont~~r.ant Trar.~DfJrt Analyse~ ~randum. RemP.dial In¥e~ti;3tio~/Feasibility S~udy
Type: PlRo!
~::'cr: jo~nso~. P~c~o~~ c: ea..~ ure~s:; ~ ~~:ee
Recipier.t: Roth. ThOit~s r.: US EPA
------------......--
--------
Occurre"t ~~c.,~~r: r'{)~1~::=-1 To 0<158
Dc te: 12,'Vf:J/f;;5
Title: (~~ re;a~~:~9 characterizo!i~~ c~ :noependent Nail)
Type: OYF.::.;:I(NJErCE
Au:~or: Susan. J~~. A: CC Johnsen & P.~sociate.
Recipient: Roth. Thanas 1'1: US EPA
Occ~~r.t N~~~er: I~~l-e3S3 To 8378
Date: 01/'/15/87
Ti tle: Remedial Al terna tvies/T echnologies for I ndependent Nail
Type: ~
Author: .Johnson. Richard C: Camp Dresser & McKee
Recipient: Roth. Thcmas 1'1: US EPA
-------
- - - -- .
. - -~----- -- -
11/'33/87
Index Chronological Order
n()EFe-DOO MIL Doccller.ts
Pog~: 24
-
Docunent Number: IN>-001-l213 To 1213
Date: 01/12./87
11 !le: (CoYer letter for th~ Camtuni ty Relations Plan)
Type: cx:P.P.~
Author: Roth. ThQllas 1'1: US EPA
Recipient: Rakers. Gerald L: Ind~dent Nail of ~
Qxument Number: II'{)-€I01-1312 To 1312
Date: 01/2.t/87
Title: (Request to establish an Infol"lllatio!! Repository at the Bea!lfo,.t Cc:mty library)
Type: IXPP.E:.~OCE
A~~hor: Ro~h. Thor~s~: ~S EPA
P.eC:t'ient: eishop. Emna: CoU/'Ity of Beal!fort 9:
--------------------.--
Cocunent Number: I~l~13 To 0513
Parent: I~l-€'SU
Date: &4/14/87
Title: (Letter accom~anyinq submlssion of Technologies Screening ~rand~)
Type: a:P.R5PCl':OOCE
A"t1ljr: ,joronson. F".lc~;a'd c: Cc.:';" ~ie~~H & :..;).i'i:
Rt>ciDient: Roth. Tr.cmas /'I: US EPA
Docunent N~mber: It~1-051~ To 0514
Paren t: IN)..00i ~U
Date: 0'./14/87
Title: (Letter transmitting Technologies Screening Memorandum)
Type:' IXPPE:;f?DOCE
Author: Susan. Ja.nes A: a: Johnson' Associates
Recipient: Lee. Charles H: Camp Dresser & ~
, ,"
DoC\l1llent NulJ1ber: I~l-1llZ To l2l2
Date: &4/14/87
Title: (CoYer letter for the Draft Remedial Investigation Report of Independent Nail)
Type: a:RRESPCWOCE
Author: Roth. ThoMs 1'1: US EPA
Recipient: Rakers. Gerakd l: Independent Nail of s:
-------
.- ------- --.--- --
"- -. - --. -
. . .
~/)3/~
Index C?lronologica.l Order
It{)EPOOOO ~I!. l1ocvmer.ts
Pag~: 25
Doc:ument Number: INH01-l3U To 1311
OUt: 14/14/87
Title: (Letter aCCOIIIpanying the Draft Remedial Inwstigation R~port for Indept'nd~nt Nail)
Type: CCAA£SPCt()fM;E
AtJ~hor: Rc~h.. ~har.1.!'I: US EPA
Recipient: Geitner. Hi~: US Otpt of the Interior
~
.,
Document Nu~b~r: .I~~~-1310 To 1318
Date: 04/15/87
Title: (Letter reQu~.ti"g a list of endang~red and threatened spt'cies in the Asheville. He ~rea)
Type: a:RP.E'SRN>Ef'a
Author: Ro!h. Thanas~: US EPA
Recipient: Frid~ll. John: US ~t 01 the Interior
Document Number: I~1-l30I3 To 1308
Oate: 04/Z3/67
Title: (Letter concerning Remedial Investigation)
Ty~e: CCf.q5~m:~
Author: C~rrie. Ro~~rt R: US Oept of !~e Interior
Recipi~r.t: Rot~. :hor.~s~: US EPA
. Attached: H£'-OOl-n!t:
DxuIlP.:'!t Nu~~e~: N>-0e14)2S9 To 0290
Paren t: I(I(j-tJ01 ~1
Oate: Vh/Vb/87
Title: (Letter sublllitting CQII1I?nts on e4/10/~ Draft First ~rable Unit RenP.dial Investigation Reoort)
Type: C(P.P.~SRN>OCE
Author: Radford. tf:)11IW1 0: Vinson & Elkins
Recipient: Roth. Tlmas 1'1: US fPA .~. . . . -.: ,,,'!i-' -
. '.:.,...~-~.;.;.
. I
- ..... . .
Document NU!llber: INHJ014)001 To i2I!3/B
. Date: ftj/«3/~
Co::!idential
Title: First Operable Unit R.elrP.dial Inwstigation Report
::~
Type: ~ '.
Author: Johnson. Richard C: CalRp Dresser & I'\d(ee
Recipient: Roth. Thanas M: US EPA
Attached: 1~1-02S4' I~1-02a) 1~1-fZ87
1~1-0289
I~1-0291
1~1-f293
-------
---------_.~.__.. ..
ll/3'b/87
Index Chror.ological Order
INDEPENDENT NAIL Do~umP.nts
Page: 26
DoC1ml?nt ttJr.:)'!r: I~l-t29f3 To 83SZ
Date: V1S/~/'O!
Title: Ouality Assurance Project Plan For ~ia1 Investigation/Feasibility Study
Type: PlAN
A!lthor: Susan. JanP.s A: CC Jo!'l!!SO!l & Associates
Recipient: none: US EPA
Document Nt;-mber: I~l-0Z84 To eZB4
Pa~nt: IttfH01-e001
Date: to/le/S7
Title: Facsimdle Reque~1 and Ca~r Sheet
Type: OTHER
P.!.Ithor: Roth. Tht;X1\3.: \.,";- EPA
Recipient: illegible: I..!$ E?A
-------- ----
-------.-----------------------.-..
Document Number: IND-001-0285 To 0286
Parent: 11'0-001-0001
Date: VIS/le/87
Title: (~ regarding authority to select site ~dy with attached delegation .briefing which susmmarize~
results of Remec~~ investigatior.)
Ty~e: C(f'-R:srom,;'.(:
Author: P4van. Jack: if.: EPA
R~~i,:~nt: ~::e~. : w:~j~Q~: ~; EPA
-----
--------
Occu~~t N\;~t~r: I~~~-e;:7 To Q753
D.a te: VJ5/12/S7
Title: O~ality A~sura"~ Project ?lan for Reme~ial Investi9ati~~/Fel.i~ility 5tu~y
Type: PlAN
Author: /'Icr.enzie. Will.iam H: Car.1D Dresser & P'IdCee
Recipient: none: US EPA
Document Number: U{H01-f293 To 0Z9S
Parent: I~1-t001
Date: fI3/17/87
Title: (Letter providing initial comments on 05/03/87 draft Feasibility Study for first operable
unit)
Type: c:xFRESPCWOCE
Author: Radford. Nonnan D: Vinson & Elkins
Recipient: Roth. Thomas M: US EPA
-------
llI~jB7
Index Chronological Order
I~ ~Il DoCl:ments
Page: 27
"-
Document Number: If00-e01~ To Il97
Date: flSj13l87 .
Title: (letter aCCDllpanying I draft of _Ie studies tdth cmnents reflecting negatiw feelings
.bout the report) ~
T~: CXFP.ESPCN)frCE
Author: Rikers. Gerald L: Independent Nail of SC
Recipient: Roth. 7hcm1s!'\: US EPA
Document P~.nnber: IKHI0Z~ To e0I3
Date: 07/20/'OT
Title: Comments on Independent Nail Superfund Site Cleanup
Type: CCfRES~OCE
Author: Glenn. /'1ichelle: 115 EPA
P.ecipient: no~~: r.o"~
1nC\.''IIE?r.t N!:~~e": J~~Z-m1 To 0001
D.: ~e: C-:.'21/:!
. Ti tIe: E:1viro!11:Y?~~o..l ~.(,?w~
Type: O'!'-!S
Aut~or: no~e: ~~ :~A
Re:ioier.t: ~or~: r.or.e
DocU'llE?~t N~"!~~r: It'{\~~Z~1S io 02J2
Oat~: 0ll:.?,':]
Title: O~;f~ ~~~sed Fe~::b:li~ Study
T ~e: Pl...AN
Author: none: none
P2cipient: none: none
~
DoCl'IIP.nt Number: I~l~ To 0592
Date: V13/14is7
Title: Technologies Screening ~randum
Type: ~
Author: Susan. James A:
R.ecipient: none: US EPA
Attached: IND-001-0513
CC .Johnson & Associ.atfS
IND-001-0514
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-..---- --------- ._- -.....----. - - -
1J./~/87
In~x Chrooological Or~r
IN>EPEM>OO ~IL ~ts
Pall'!: 2S
--
-
OocuEnt Nualber: IKHeZ-«398 To 8398
Da te: fJ9/~/87
Title: Declaration for the Record of Decision - RenP.dial Alternative Selection
#"
..
Type: OMR
Autllor: De Hihns. lee A: US ffR
Recipient: none: none
Attached: 1~2-G1 INH02-t428
. .
.
nxument Number: Ir-0-002-04Z6 To 04Z7
Date: fJ9/?llJ/~
Title: (Letter with Ctm1P.nts fraP. de:»art!len! upon !'e'{iew of Recor~ o~ ~d.sio:l stating concurrenc
by State of 9:)
Ty,e: CC'AAESPCt.()~E
Author: Shaw. P. Lewis: 9: De,t of Health & Envit"Ol':IIl"fltal Control
R~ci,ient: De Ul~~s. ~~ A: ~S E?A
Oc,=um'?nt Nu:nber.: Nj-002~Z9 To 0439
Parent: IND-002~28
Date: 10/'1.6/87
:i!le: (~ co~!ai~i~g ~~e r~q~es~~d He~!~ AssessmP.r.t)
Type: c::f'.~E5PCt.()OCE
Aut~or: Kno:Jse. R ..~illia.'7I: L'5 :'?~~ of Health & H!JIIU!1 Services
~~':i.~ier~: Pietrosewicz. C..a~isl1E'~ V: US EPA
------
~~~~t ~"~~er: I~-002~Z8 To ~~8
Pa~r.t: ItC>-OO2~~
Date: 10/20/87
Title: (~ e~,=losing final ~Py of f~nnal Health Assess~n! for seil O~era~le Unit to be included
in Administrative Record)
Type: CtFJ',E$PCNJOCE
Author: Pietrosewicz. Casimer V:
Recipient: Glenm. /'Iichelle: US fFA
Attached: IND-002-0429
0./
L5 Dept of HP.alth & "i\l!!'an Services
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AITACHMENT 3
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