United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R04-91/081
May 1991
EPA Superfund
Record of Decision
Medley Farms, SC
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REPORT DOCUMENTATION 11. REPORT NO. 1 ~ 3. Reciplenl'a Acceaalon No.
PAGE EPA/ROD/R04-91/081
4. Tile 8IId !kbfte 5. A8port 081e
SUPERFUND RECORD OF DECISION OS/29/91
Medley Farms, SC 6.
First Remedial Action - Final
7. Aulhor{a) 8. P8rf0rmlng OrgenlZ81lon A8pL No.
II. P8rf0rmlng Orgalnlzatlon Name 8IId Add.... 10. PtojectlTa8lllWorII UnIt No.
11. Contr1ICI(C) or Gr8J1l{G) No.
(C)
(G)
1~ Sponaorlng Organization Name I11III Addraaa 13. Type of Raport I "-'loci Co...,..s
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
15. Suppiementa'Y No"'e
16. Abatrect (Umit: 200 worda)
The 7-acre Medley Farms site is a former waste disposal area located on a private
farm used as pasture 6 miles south of Gaffney, Cherokee County, South Carolina. Land
use in the area is predominantly agricultural and light residential, and six private
wells are within a 1-mile radius of the site. The site overlies a shallow saproli tic
and a deeper bedrock aquifer. All residents in the near vicinity of the site are
connected to the public water distribution system. From 1973 to 1976, the site was
used for disposal of drummed and other waste materials. In 1983, the State
identified approximately 2,000 deteriorating 55-gallon drums and numerous plastic
containers scattered throughout the site. Other observations included a chemical
odor in the air, several excavation pits containing discolored water and drums, and
stressed vegetation. Several State and EPA studies identified VOCs and other
organics in onsite soil. In 1983, EPA removed 5,383 fifty-five-gallon and
fifteen-gallon containers; disposed of empty drums offsite; bulked 24,000 gallons of
liquid wastes, with offsite incineration of the wastes, and crushed and disposed of
the empty drums offsite; excavated and disposed of 2,132 cubic yards of contaminated
soil offsite; drained 70,000 gallons of water from six small lagoons, followed by
(See Attached Page)
17. Document Analyaie L o.acriptora
Record of Decision - Medley Farms, SC
First Remedial Action - Final
Contaminated Media: soil, gw
Key Contaminants: VOCs (benzene, PCE, TCE), other organics (pesticides, PCBs)
b. IdentifieralOpen-Ended Terma
c. COSA TI FleIdiGroup
18. Aveilebllity Statement 111. SeC\8ity CI..e (1I1la Report) 21. No. of Pell"
None 184
20. Security CI... (1hia Page) 22. PrIce
. None
)
50272 101
(See ANS-Z311.18)
See InelTuclione on Rave-
(Formerly NTlS-35)
Department 01 Commerce
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EPA/ROD/R04-91/081
Medley Farms, SC
First Remedial Action - Final
Abstract (Continued)
treatment using a pressurized sand/gravel/activated carbon filtration system to remove
organic contaminants; and backfilled the lagoons with clean soil. Following this
removal action, EPA conducted a geological study to determine the potential for ground
water contamination. Subsequent EPA studies identified VOCs in both soil and ground
water. This Record of Decision (ROD) addresses soil and ground water contamination as
a final remedy. The primary contaminants of concern affecting the soil and ground
water are VOCs including benzene, PCE, and TCE; and other organics including pesticides
and PCBs.
The selected remedial action for this site includes treating contaminated soil onsite
using in-situ vapor extraction, and controlling air emissions using carbon adsorption;
regenerating or disposing of the spent carbon; pumping and treatment of contaminated
ground water using precipitation, flocculation, ion exchange, or some other method of
metal removal if necessary, followed by air stripping; discharging the treated water
onsite to surface water; and monitoring ground water, surface water, soil, and
sediment. If the ground water treatment system cannot meet the specified remediation
goals, contingency measures and goals will be implemented including engineering
controls or institutional controls, invoking chemical-specific ARAR waivers, or
reevaluating remedial technologies for ground water restoration. The estimated present
worth cost for this remedial action is $2,404,000, which includes an annual O&M cost of
$1,451,000 for 30 years.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific soil clean-up goals were derived
from calculations based on leachate modeling, and include PCE 1,600 ug/kg and
TCE 500 ug/kg. Chemical-specific ground water clean-up goals are based on SDWA MCLs
and proposed MCLs, and include benzene 5 ug/l (MCL), PCE 5 ug/l (MCL), and TCE 5 ug/l
(MCL) .
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,.
RECORD OF DECISION
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
MEDLEY FARM SUPERFUND SITE
GAFFNEY, CHEROKEE COUNTY
SOUTH CAROLINA
PREPARED BY:
u. S. ENVIRONMENTAL PROTECTION
REGION IV
ATLANTA, GEORGIA
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n_..a~J:mI POR 'ftIB RBOORD OF DBCJ:SJ:OB
SITE NAME AND LOCATION
Medley Farm
Gaffney, Cherokee County, South Carolina
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the Medley
Farm Superfund site in Gaffney, South Carolina chosen in accordance with the
Comprehensive Environmental Response, compensation, and Liability Act of
1980, as amended by the Superfund Amendments and Reauthorization Act of 1986
and, to the extent practicable, the National Contingency Plan. This decision
is based on the administrative record file for this Site.
The State of South Carolina concurs with the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this Site, if not
addressed by implementing the response action selected in this Record of
Decision, may present an imminent and substantial endangerment to public
health, welfare, or the environment. The principle threat at this Site
results from the unacceptable elevated levels of. volatile organics in the
groundwater.
DESCRIPTION OF THE SBLECTED REMEDY
This remedy addresses the principle threat posed by this Site. The principle
threat is the contaminated groundwater emanating from beneath the Site. This
remedial action will also address residual soil contamination which, if left
in place, would continue to adversely impact the quality of the groundwater
for 20 years.
The major components of the selected remedy include:
GROtJNDWATER
.
Extraction of groundwater across the entire Site that is
contaminated above Maximum Contaminant Levels or non-zero Maximum
Contaminant Level Goals which ever are more protective;
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-2-
On-site treatment of extracted groundwater via air stripping to
remove the volatile contaminants from the water column with the
of controlling off-gas from the air-stripper to be evaluated in
Remedial Design;
need
the
Off-site discharge of treated groundwater to Jones Creek via a
National Pollution Discharge Elimination System Permit; and
Continued analytical monitoring for contaminants in groundwater and
surface water.
SOIL
Installation of a network of air withdrawal (vacuum) wells in the
unsaturated zone;
.
Construction of a pump and manifold system of PVC pipes used for
applying a vacuum on the air extraction wells to remove the volatile
organic compounds and some semi-volatile organic compounds from the
soil; and
Implementation of an in-line water vapor removal system and an
in-line vapor phase carbon adsorption system to remove organic
compounds prior to releasing the extracted air to the environment.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the environment,
complies with Federal and State requirements that are legally applicable or
relevant and appropriate to the remedial action, and is cost-effective. This
remedy utilizes permanent solutions and alternative treatment technology to
the maximum extent practicable, and satisfie8 the statutory preference for
remedies that employ treatment that reduces toxicity, mobility, or volume ~s
a principal element. Since this remedy may result in hazardous substances
remaining on-site above health-based levels, a review will be conducted
within five years after commencement of remedial action to ensure that the
remedy continues to provide adequate protection of human health and the
environment.
Q~ Y'Yl~
~Greer C. Tidwell
!Regional Administrator
MAY 2 !l199i
Date
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THE DECISION SUMMARY
FOR THE
RECORD OF DECISION
MEDLEY FARM SUPERFUND SITE
GAFFNEY, CHEROKEE COUNTY
SOUTH CAROLINA
PREPARED BY:
U.s. BNVIRONMENTAL PROTECTION
REGION IV
ATLANTA, GBORGIA
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SBCTION
1.0
2.0
3.0
4.0
5.0
6.0
7.0
8.0
9.0
TABLE OP CONTBNTS
INTRODUCTION
................ ......................... ......... ...
SITE LOCATION AND DESCRIPTION
..... .................. ......... ....
SITE HISTORY
... ....... ........... -......... ........ .......... ....
ENFORCEMENT ACTIVITIES
.......... ........... ....... ...............
HIGHLIGHTS OF COMMUNITY PARTICIPATION ............................
SCOPE AND ROLE OF RESPONSE ACTION WITHIN SITE STRATEGY
...........
SUMMARY OF SITE CHARACTERISTICS
7.1 Residual Source Materials
7.2 Soils
7.2.1 Surface Soils........................................
7.2.2 Subsurface Soils .....................................
Groundwater. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Stream Sediment and Surface Water ...........................
Hydrogeological Setting .....................................
..........
.......... ..........
..........
......... ...........
....... ......... .... ..... .................
.............
7.3
7.4
7.5
SUMMARY OF SITE RISKS
8.1 Contaminants of Concern.....................................
8.2 Exposure Assessment .........................................
8.3 Toxicity Assessment of Contaminants .........................
8.4
8.S
....... ... ..... ....... ...... ... ..... ........
Risk Characterization .......................................
Environmental Risks
... .... ................ ........ ..... .....
DESCRIPTION OF ALTERNATIVES
9.1 Remedial Alternatives To Address Groundwater
Contamination. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
9.1.1 GWC-1: No Action.................................. . .
9.1.2 GWC-2: Long-term Monitoring and Deed
Re.tr iet ion. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
GWC-3: Recovery of Groundwater Across
Entire Site
9.1.3.1 GWC-3A: Recovery and Treatment of
Groundwater Across Entire Site
Using An Air Stripping Tower ................
GWC-3B: Recovery and Treatment of
Groundwater Across Entire Site
Using Activated Carbon ......................
GWC-3C: Recovery and Treatment of
Groundwater Across Entire Site
Using Chemical Oxidation ....................
Recovery and Treatment of Groundwater
Medley Farm Property Line .....................
... ...... .......... ......... ..........
9.1.3
...... ...... ......... ......... ....... .....
9.1.3.2
9.1.3.3
9.1.4
GWC-4:
at the
PAGB No.
1
1
4
10
12
13
13
14
14
26
26
31
42
42
51
52
52
57
57
65
65
68
68
68
69
69
71
71
71
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SBCTION
10.0
9.2
9.3
TABLE OP CORTBRTS
PAGB No.
Remediation Alternatives to Address Source Control.......... 72
9 . 2 . 1 SC-1 : No Act ion. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 72
9.2.2 SC-2: Institutional Controls ..~..................... 73
9.2.3 SC-3: Cap Source Areas .............................. 73
9.2.4 SC-4: Soil Vapor Extraction ......................... 74
Applicable or Relevant and Appropriate
Requ irement s ................................................ 77
9.3.1
Action-Specific Applicable or Relevant
and Appropriate Requirements ......................... 77
Location-Specific Applicable or Relevant
and Appropriate Requirements ......................... 78
9.3.2.1 Groundwater ................................. 78
9.3.2.2 Surface Soils ............................... 78
9.3.2.3 Subsurface Soils ............................ 80
9.3.2.4 Surface Waters .............................. 80
9.3.2.5 Sediments.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 80
Chemicals-Specific Applicable or Relevant
and Appropriate Requirements ......................... 80
9.3.2
9.3.3
SUMMARY OP COMPARATIVE ANALYSIS OP ALTERNATIVES .................. 80
10.1 Threshold Criteria ......................................... 80
10.2
10.3
10.1.1
overall Protection of Human Health and
the Environment.................................... 84
Compliance with Applicable or Relevant
and Appropriate Requirements ....................... 85
10.1.2.1 Action-Specific Applicable or
Relevant and Appropriate
10.1. 2
Requirements. . . . . . . . . . . . . . . . . . . . . . . . . . . .. 86
10.1.2.2
Chemical-Specific Applicable or
Relevant and Appropriate
Requirements. . . . . . . . . . . . . . . . . . . . . . . . . . . .. 86
10.1.2.3
Location-specific Applicable or
Relevant and Appropriate
Requirements. . . . . . . . . . . . . . . . . . . . . . . . . . . .. 86
10.1.2.4 Applicable or Relevant and
Appropriate Requirements Evaluation ...... 86
Pr~ Balancing Criteria ................................. 87
10.2.1 Long-term Effectiveness and Permanence ............. 88
10.2.2 Reduction of Toxicity, Mobility or Volume .......... 89
10.2.3 Short-term Effectiveness ........................... 89
10.2.4 Implementability ................................... 90
10.2.5 Cost. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 91
Modifying Criteria ......................................... 93
10.3.1 State of South Carolina Acceptance ................. 93
10.3.2 COmmunity Acceptance ............................... 93
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TABLE OF CONTBNTS
SBCTION
PAGB No.
11.0
DESCRIPTION OF THE SELECTED REMEDY............................... 93
11.1 Monitoring Existing Conditions ............................. 94
11.2 Groundwater Extraction, Treatment, and Discharge ........... 94
11.3 Source Remediation......................................... 97
11 . 4 Cost. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 98
12.0
STATUTORY DETERMINATION.......................................... 98
12.1 Protection of Human Health and the Environment ............. 98
12.2 Attainment of Applicable or Relevant
and Appropriate Requirements ............................... 98
12.3 Cost-Effectiveness ......................................... 98
12.4 Utilization of Permanent Solutions and Alternative
Treatment Technologies or Resource Recovery
Technologies to the Maximum Extent Practicable ............. 99
12.5 Prefence for Treatment as A Principal Element ....:......... 99
APPBIIDICBS
Appendix A
Responsiveness Summary
Appendix B
Risk Assessment certification
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FIGURE
Figure 1-
Figure 2.
Figure 3.
Figure 4.
Figure 5.
Figure 6.
Figure 7.
Figure 8.
Figure 9.
Figure 10.
Figure 11.
Figure 12.
Figure 13.
Figure 14.
Figure 15.
Figure 16.
Figure 17.
Figure 18.
Figure 19.
Figure 20.
Figure 21.
Figure 22.
Figure 23.
LIST OF FIGURES
PAGB No.
Site Location Map.......................................... 2
Approximate Boundaries of Medley Farm Property
and the Medley Farm Superfund Site ....................... 3
Topography of the Site and Surrounding Area
and Location of Local Surface Streams .................... 5
Domestic Wells in Vicinity of the Site and
Municipal Water Supply System ............................ 6
Summary of Electromagnetic Survey Results .................. 8
Approximate Boundaries of Contamination at the Site ........ 15
Location of Test Pits Excavated and Volatile
Organic compounds Found in Them .......................... 16
Location of Test Pits Excavated and Semi-Volatile
Organic Compounds and Inorganics Found in Them ........... 17
Location of Surface Soil Samples and the
Volatile and Semi-Volatile Organic
Compounds Found In These Samples ......................... 27
Locations and Concentrations of Polychlorinated
Biphenyls Found Across the Site .......................... 28
Soil Boring Locations and Volatile
Organic Compounds Found in These Soil
Bar ings ................................... ~ . . . . . . . . . . . . .. 29
Soil Boring Locations and Semi-Volatile
organic Compounds Found in These Soil
Bar ings .................................................. 30
Site Related Contaminants Detected in the
Saprolite Portion of the Aquifer ......................... 40
Site Related Contaminants Detected in the
Bedrock Portion of the Aquifer ........................... 41
Sampling Locations for Surface Water and Sediment .......... 43
Geologic Cross Section Locations ........................... 45
Geologic Cross Section A-A' ................................ 46
Geologic Cross Section B-B' ................................ 47
Geologic Cross Section C-C' ................................ 48
Water Table (Saprolite) Potentiometric Hap ................. 49
Bedrock Potentiometric Map ................................. 50
Groundwauer Water Recovery Schemes ......................... 70
Approximate Extent of Source Area Exceeding
Calculated Soil Remediation Levels ....................... 75
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TABLE
Table 1.
Table 2.
Table 3.
Table 4.
Table 5.
Table 6.
Table 7.
Table 8.
Table 9.
Table 10.
Table 11.
Table 12.
Table 13.
Table 14.
Table 15.
Table 16.
Table 17.
Table 18.
Table 19.
Table 20.
Table 21.
LIST OP 'PaRT R!i:
PAGB Ho.
Analytical Results for Groundwater Samples
Collected in 1984 ......................................... 9
Analytical Data Summary - Organic Compounds
Detected in Test Pit Soil Samples ......................... 18
Analytical Data Summary - Organic Compounds
Detected in Soil Boring Samples by Depth .................. 20
Analytical Data Summary - organic Compounds
Detected in Surface Soil Samples .......................... 23
Chemicals Detected in Soils ................................. 24
Analytical Data Summary for Contaminants Found
in the Groundwater ........................................ 32
Inorganics Detected in Groundwater - Saprolite Wells ........ 36
Inorganics Detected in Groundwater - Bedrock Wells .......... 37
Organic Contaminants Detected in the Saprolite
Monitoring Wells.......................................... 38
organic Contaminants Detected in the Bedrock
Monitoring Wells.......................................... 39
Chemicals of Potential Concern by Environmental Medium ...... 53
Exposure Point Concentrations for Surface Soil.............. 54
Exposure Point Concentrations for Groundwater ............... 55
Toxicity Values: carcinogenic Effects for Chemicals
of Concern................................................ 58
Toxicity Values: Noncarcinogenic Effects for Chemicals
of Concern................................................ 60
Groundwater Control Technology Summary ...................... 66
Source Control Technology Summary ........................... 67
Volatile Organic Soil Remediation Levels .................... 76
Groundwater Remediation Levels .............................. 79
Location-Specific Applicable or Relevant .
and Appropriate Requirements .............................. 81"
Retained Alternatives for Detailed Analysis ................. 84
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1.0
INTRODUCTION
The Medley Farm site was proposed for inclusion on the National
(NPL) in June 1986 and was finalized on the NPL in March 1990.
1990, the Site ranks 918 out of 1218 NPL sites with a Hazardous
System (HRS) score of 31.58.
Priority List
As of August
Ranking
The Remedial Investigation (RI) occurred in two phases. Phase I began in
January 1988 with the signing of the Administrative Order on Consent (AO) and
ended with the submission of a draft RI report in March 1990. Due to data
deficiencies identified in this report, the Potentially Responsible Parties
(PRPS) initiated Phase II of the RI. The revised draft RI report was
submitted to the Agency in November 1990 and the draft Feasibility Study (FS)
was delivered in December 1990. The Agency approved both the RI and the FS
in May 1991.
This Record of Decision (ROD) has been prepared to summarize the remedial
selection process and to present the selected remedial alternative.
2.0
SITE LOCATION AND DESCRIPTION
The Medley Farm site consists of an approximately seven-acre section of the
Ralph Medley Farm parcel that is situated on top of a hill. The Medley Farm
property consists of 61.9 acres of rural land located approximately six miles
south of Gaffney, South Carolina in Cherokee County on County Road 72 (Burnt
Gin Road). Figure 1 provides the general location of the Medley Farm
property and Figure 2 shows the approximate boundaries of the Medley Farm
property and the Site.
The approx~te center of the Site is located at latitude 34858'54" north and
longitude 81840'02" west. The surrounding land is hilly and consists mainly
of woods and pasture land. The land use in the vicinity of the Site is
prLmarily agricultural (farms and cattle) and light residential. No change
is expected in the use of the Medley Farm property in the near future. It is
anticipated that Kr. Ralph Medley will maintain ownership of this property.
Ground surface elevations at the Medley Farm property range in elevation from
El. 558 feet, National Geodetic Vertical Datum (NGVD), at Jones creek, to El.
689 feet NGVD at the highest point on the property. Topography of the Site
is relatively flat with slopes ranging from three to ten percent. The land
surrounding the Site slopes off steeply to the east and south with slopes
ranging from 10 to 52 percent. The Site is covered with weeds, briars, and
small scrub trees, but the remainder of the Medley property is mostly a dense
for~st of hard- and softwoods. Based on observations of Site topography,
surface drainage occurs to the northeast and east, to the southeast, and to
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Uk
\
•¥
UNION COUNTY
Scale 1' - 2 Miles
POOR QUA
ORIGINAL
Map showing location
if tit* and county in
"outh Carolina.
Figure i
Medley Farm Site
Cherokee County
Gaffney, South Carolina
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Approximate Farm
Property Boundary
USGS Pacolet Mills Quadrangle
Scale 1:24,000
Figure 2
Approximate Boundaries of
Medley Farm Site and Farm Property
Medley Farm Site Gaffney, South Carolina
-8-
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-4-
the south and southwest into two intermittent tributaries of Jones Creek.
All surface drainage eventually discharges to Jones Creek which in turn flows
into Thicketty Creek approximately 1.5 miles from the Medley property.
Figure 3 shows the topography of the Medley Farm property, the Medley Farm
site, and the surrounding area as well as the location of Jones Creek and the
two intermittent tributaries. One of the tributaries is to the northeast of
the Site and the other tributary is to the south.
Figure 4 shows the location of private wells within a one mile radius of the
Site as well as the municipal water lines supplied by Dyratonville Water
Works. All residents in the near vicinity of the Site are attached to the
public water distribution system. Natural resources in the area of the Site
include water, soils, flora and fauna. Jones Creek has minimal recreational
value due to its size and poor accessability. Base flow in Jones Creek near
the Site is 200 gallons per minute (gpm).
3.0
SITE HISTORY
The Medley Parm property is currently owned by Ralph C. Medley, who acquired
the property from William Medley in 1948. Prior to the mid 1970's, the
property was maintained as wood and pasture land. Based on available
information, the disposal of drummed and other waste materials began at the
Site in 1973 and was terminated in June of 1976. As a result of an anonymous
call, the South Carolina Department of Health and Environmental Control
(SCDBEC) visited the Site on May 3, 1983. At the time of the visit, SCDBEC
estimated that approximately 2,000 55-gallon drums were on-site in scattered,
random fashion. Drums were found in open pits, several small lagoons, and on
the ground. These drums were in various stages of deterioration. Other
notes/observations made during the May 3, 1983 SCDBEC visit included: a
chemical odor in the air, a number of shallow excavations (pits) containing
discolored standing water, drums standing or lying in the water in these
pits, and areas of stressed vegetation. In addition to the 55-gallon drums,
there were numerous plastic containers of various sizes. No formal records
of disposed waste materials were maintained by the PRPs.
Based on this visit/inspection, SCDBEC returned on Kay 19, 1983 to collect
soil samples for analysis. The results of these analyses showed the presence
of a number of volatile organic compounds (VOCS) including methylene
chloride, trichloroethylene (TCB), trans-l,2-dichloroethylene as well as
several semivolatile organic compounds (SVOCs).
SCDHBC informed the Bnvironmental Protection Agency (EPA) of the sampling
results and EPA visited the Site during the week of Kay 30, 1983. During the
EPA visit, additional samples were collected for analysis. Among the
contaminants detected in EPA's samples were: methylene chloride, vinyl
chloride, perchloroethylene (PCB), phenol, toluene, TCB, and
1,2-dichloroethane. one composite soil sample contained polychlorinated
biphenyls (PCBs) at low levels.
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-N-
Approximate Property Boundary
the Ralph Medley Farm
^^//,'/ •• V 1 '
i M<
TOPOGRAPHY
OF SITE AMI
SURFACE
STREAMS
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APPROXIMATE ONE MILE
RADIUS FROM THE
MEDLEY FARM SITE
LEGEND
APPROXIMATE LOCATION OF MEDLEY FARM SITE
APPROXIMATE LOCATION OF WATER SUPPLY WELLS
ON RECORD WITH S.C. DHEC AND S.C. WRC
OWNERS OF RECORD ARE IDENTIFIED AS FOLLOWS.
1 RALPH MEDLEY
a DOROTHY SPROUSE
3 JAN SARRETT
4 DAVIS FAMILY
5 ROBERT PITTMAN
6 ROBERT SOLESBEE
APPROXIMATE LOCATION OF MUNICIPAL
WATER SUPPLY LINES
APPROXIMATE LOCATION OF BUILDINGS
SHOWN ON uses TOPOGRAPHIC MAP
NOTES;
1. LOCATION OF WATER SUPPLY WELLS
OBTAINED FROM THE SOJTH CAROLINA •
DEPARTMENT OF HEALTH AND ENVIRONMENTAL
CONTROL AND THE SOUTH CAROLINA WATER
RESOURCES COMMISSION BY S1RRINE, NOV. 1990.
A DQOR-TO-DOOR SURVEY WAS NOT PERFORMED
FOR THIS STUDY.
8 LOCATION OF WATER LINES SUPPLIED BY
L'YSATONVILLE WATER WORKS, INC, NOV. 1990.
3. LOCATIONS OF BUILDINGS TAKEN FROM
USDS TOPOGRAPHIC MAP, PACOLET MILLS
QUADRANGLE, 1969.
SCM.C IN retl
r • txa rcn
FIGURE 4
MUNICIPAL WATER SUPPLY AND
DOMESTIC WELLS IN VICINITY QF
MEDLEY FARM SITE
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-7-
An ~ediate removal action was initiated on June 20, 1983 by EPA pursuant to
Section 104 and other provisions of the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA). A total of 5,383 55-gallon
drums and 15-gallon containers were removed from the Site. These included
full, partially full, and empty containers. Compatibility testing of drum
contents was done prior to bulking of liquid wastes. Empty drums were
crushed and taken to a sanitary landfill. The bulked liquids (24,000
gallons) were taken off-site by tanker and incinerated. The solid waste and
contaminated soils, totaling 2,132 cubic yards, were taken to an approved
hazardous waste landfill. Three drums containing PCBs (Arochlor 1254, 1260,
and 1248) were over packed and sent to an approved disposal facility.
Approximately 70,000 gallons of water were drained from the six small lagoons
and treated in a pressurized sand/gravel/activated carbon filtration system
for the removal of organics. The treated effluent was analyzed to ensure
that it met State discharge standards prior to release into Jones Creek. The
lagoons were backfilled with reportedly clean earth and graded to the natural
topography. The remedial action was completed on July 21, 1983.
Analytical testing of the drum contents, as well as the water and sediment in
the lagoons during the removal action, confirmed the presence of the
following contaminants: toluene, benzene, methylene chloride, PCE, and vinyl
chloride. Samples from adjacent homeowners' wells were collected by SCDHEC
on June 27, 1983 and a trace level of methylene chloride was detected in the
Sprouse well.
Pollowing the removal action, the Agency directed one its Contractors to
conduct a geological and geophysical study. This study was completed the
week of August 1, 1983. The study was designed to determine the potential of
groundwater contamination at the Site. The field study included electrical
resistivity soundings, a magnetometer survey, and an electromagnetic (EM)
survey. Anomalous areas identified by these geophysical surveys are
illustrated in Pigure 5. These anomalies correlated well with the former
drum storage and lagoon locations.
SCDHEC revisited the Site in April 1984 to perform a preliminary
investigation and install a monitoring well. Soil samples from two boreholes
and a groundwater sample collected from the newly installed monitoring well
were analyzed for volatile organic., primary metals, and acid and
base-neutral extractable.. The re.ults of the soil analyses showed the
presence of two quantifiable VOCs at a depth of 10 feet; the VOCs are
methylene chloride at 81.4 micrograms per kilogram (ug/kg) and
1,2-dichloroethane at 102 ug/kg. Results of the groundwater analysis for
VOCs for samples collected in April 1984 and July 1984 are presented in
Table 1. This table a180 provides the analytical results for groundwater
samples collected from the Sprouse well.
The Hedley Parm site was 8ubsequently evaluated by the BPA in June 1985,
using the BRS. A migration score of 31.58 was assigned based entirely on the
groundwater route. The Site was proposed for addition to the NPL in June
1986. In Karch 1990, the Site was finalized on the NPL and was ranked 850
(Pederal Register, Karch 14, 1990). As of August 1990, the Site was ranked
918 on the National Priority List (Pederal Register, August 30, 1990).
-------
600 ".
80t
-
-
WOODS
\
@
WOODS
@.
WOODS
I
CI8
I
o
o
~
o Approximate Location of Former Drum Storage Area
- Approximate Location of Former Lagoons
- Approximate Tre. Un.
Scale
50 Feet
Source: NUS Report on Geophysical Study TOO No. F'-8J07-0J
Figure 5
Medley Farm Site AI
Summary NUS Electromagnetic
Survey Results'
Gaffnev. South Caroli na
-------
Table 1
Medley Farm Site RI
SCDHEC Volatile Organic Ground-Water Analyses
SCDHEC MONITORING WELL ON THE MEDLEY FARM SITE:
Well MD2A
1) methylene chloride
2) 1,1-dichloroethene
3) 1,1-dichloroethane
4) trans-1,2-dichloroethene
5) chloroform
6) 1,2-dichloroethane
7). 1.1.1-trichloroethane
8) carbon tetrachloride
9) trichloroethene
10) 1,1,2-trichloroethane
11) toluene
12) perchloroethylene
Date of Collection
April 13. 1984 (1) Julv 18. 1984 (2)
39.05 ug/l
1,887.00 ug/l
160.5 ug/l
37.9 ug/L
8.0 ug/L
22.05 ug/l
3,362.00 ug/L
3,804.00 ug/l
6.6 ug/L
66.9 ug/L
29.6 ug/L
2.5 ug/l
9.22 ug/L
1,645.ooug/L
43.7 ug/L
28.0 ug/L
3.56 ug/L
7.53 ug/L
2,188.ooug/L
830.ooug/L
3.14ug/L
15.3 ug/L
, *
*
DOMESTIC WATER WELL IN MEDLEY FARM SITE VICINITY:
Sprouse Well (2)
1) methylene chloride
2) 1,2-dichloroethane
June 'ZT. 1983(2)
Date of Collection
SeDtember 12. 1983 (2)
Julv 18. 1984 (2)
14.0
o
678 ug/L
2.51 ug/L
*
*
* - No value given In SCDHEC analytical results.
References:
1. Workman, 1984(a)
2. Workman, 1984(b)
-9-
-------
-10-
4.0
ENFORCEMENT ACTIVITIES
As a result of SCOHEC's Hay 1983 investigation and EPA's June 1983
investigation, EPA initiated a removal action between June 1983 and July
1983. The removal action was conducted under the authority of Section 104 of
CERCLA. The cost of the removal action was approximately $675,000.
In 1983, EPA sent general notice letters, which included information requests
pursuant to Section 104(e) of CERCLA to 22 companies. The vast majority of
these companies were identified by drum labels found at the Site. In
response to the information requests, most of the companies alleged that they
had never had any contact or dealings with the Site or the owners/operators
thereof and that their product drums must have been re-used by their
customers without removing the labels.
In Hay 1985, EPA sent additional general notice and information request
letter to eight parties which were identified as PRPs through interviews with
the owners and operators and other witnesses.
In October 1985, BPA sent demand letters to Unisphere Chemical Corp.,
Hilliken Chemical Company, National Starch and Chemical Company, Ralph C.
Hedley, Clyde Hedley, and to other parties involved in this case.
In June 1986, pursuant to Section 107 of CERCLA, the United States filed a
complaint in a cost recovery action against the owner of the Site, Ralph C.
Hedley, and the following members of his family: Clyde Hedley, Grace Hedley,
and Barry Hedley (individually and doing business as Hedley Concrete Works).
The complaint also named the following generators, who were believed to have
shipped waste to the Site, as defendants:
1.
2.
3.
Hilliken and Company
National Starch and Chemical Corporation
Unishpere Chemical Corporation.
In a third-party complaint, the original defendants alleged that the
following companies also had sent hazardous substances to the Site and were
liable as generators under CBRCLA Section 107, 42 U.S.C. S 9607:
1.
2.
3.
4.
ABoo Industries, Incorporated
BASP Corporation
Bthox Chemicals, Incorporated
Polymer Industries, a division
Tanner Chemical Company.
of Korton-Thiokol
5.
After conducting approximately six months of discovery, the United States
moved for partial summary judgement on the issue of the defendants'
liability. By way of an Order, dated November 5, 1986, the Court granted the
government's motion for summary judgement, finding the defendants Ralph C.
Hedley and Clyde Hedley liable for all costs incurred by the United States in
responding to the release or threatened release of hazardous substances at
the Site, as well as for any future response costs which the United States
might incur.
-------
-11-
After several months of negotiations, the United States and the generator
defendants reached an agreement requiring the payment of $560,000, which was
approx~ately 83 percent of the past costs incurred by the United States in
the removal action. The agreement was memorialized in a Consent Decree,
dated June 30, 1987, filed with the United States District Court for the
District of South Carolina, Spartanburg Division (Civil Action No.
86-252-3). The Consent Decree did not include the Medley family
owner/operators.
Thereafter, the generators and the United States filed a Stipulation of
Dismissal with the District Court, which provided for the dismissal of the
United States' suit against the Medleys, both individually and doing business
as Medley's Concrete Works, for the response costs incurred by the United
States up to and including the date of entry of the Consent Decree. Since
the Stipulation of Dismissal was without prejudice and it provided for the
tolling of the statute of l~itations, the United States preserved its
ability to pursue the Medleys at a later time.
In July 1987, EPA sent special notice letters pursuant to Section 122(e) of
CERCLA to initiate the moratorium period in connection with the conduct of
the RI/FS to the following parties:
1-
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
Unishpere Chemical Corporation
Milliken and Company
Tanner Chemical Company
Charles S. Tanner Company
Polymer Industries
National Starch and Chemical Corporation
Ralph C. Medley
Grace Medley
Clyde Medley
Barry Medley
Medley Concrete Work.
Ethox Chemicals, Incorporated
BASP Corporation
ABCO .
A steering committee of PRPs was formed following the issuance of the special
notice letters. The steering committee made a good faith offer to conduct
the RI/PS by means of a letter to Region IV, EPA dated November 2, 1987. The
parties thereafter entered into an Administrative Order by Consent, dated
January 29, 1988, for conduct of the RI/PS.
-------
-12-
5.0
HIGHLIGHTS 01' COMMUNITY PARTICIPATION
Information Repositories/Administrative Records for this Site were
established at the Cherokee County Public Library in Gaffney and in the EPA,
Region IV Regional Information Center in Atlanta, Georgia. A Community
Relations Plan identifying a proactive public outreach strategy was developed
at the direction of EPA Region IV staff and submitted to the information
repositories prior to initiating RI field work. The following describes the
community relations activities conducted by the Agency for this Site.
Two Fact Sheets were distributed to the public during the latter part of
1988. The first Fact Sheet, released in October 1988, provided pertinent
background and historical information, and a brief description of the
Superfund process. This Pact Sheet also informed the public that an
Information Repository for the Medley Farm site had been established.
The second Pact Sheet, distributed in December 1988, described the upcoming
RI field activities and provided a schedule of work. The "Kick-Off" public
meeting was held on January 9, 1989. In each Fact Sheet and the "Kick-Off"
meeting, the Agency highlighted the opportunities for public involvement and
encouraged the public to become and remain involved with the Superfund
process at the Medley Parm site.
pollowing the submittal of the draft RI report to the Agency by the PRPs on
March 30, 1990, a third Pact Sheet was prepared. This Fact Sheet,
distributed in Kay 1990, highlighted the findings/conclusions stated in the
draft RI report. A public meeting was held on May 24, 1990 to share with the
public the information presented in the draft RI and inform the public of the
upcoming activities and provide a schedule for these activities.
Due to the data deficiencies identified in the draft RI report, a fourth Fact
Sheet was mailed out to inform the Public that a second phase, Phase II, of
the RI was necessary. This Pact Sheet briefly explained why there was a need
for Phase II, the field activities associated with this Phase, and a revised
schedule. Pollowing the completion of Phase II and the submittal of the
revised RI report on November 30, 1990, another Fact Sheet was prepared and
distributed to the public in January 1991. This Pact Sheet highlighted the
findings/conclusions stated in the revised RI report. Shortly after
distributing this Pact Sheet, the proposed Plan Pact Sheet was sent out to
the public on Pebruary 8, 1991. The information included in the Proposed
Plan was based on the draft FS document submitted to the Agency by the PRPs
on December 31, 1990.
The Public was informed through the Proposed Plan Fact Sheet and a Public
notice released by the Agency of the February 12, 1991 Proposed Plan public
meeting. The primary goals of this meeting were to review the remedial
alternatives developed by the PRPs, identify the Agency's preferred
alternative, provide the Agency's rationale for the selection of this
alternative, encourage the Public to voice their opinion with respect to the
Agency's selection or any other issue, and inform the public that the public
comment period on the Proposed Plan would run from February 13, 1991 to Karch
12,. 1991. The public was also informed that all comments received during the
-------
-13-
public comment period would be addressed in the Responsiveness Summary which
is an Appendix of the ROD.
The public comment period was extended an additional 30 days in response to a
request for an extension dated February 5, 1991. This extension is in
accordance with the National contingency Plan, C.F.R. S 300.430(f)(3)(i)(C).
As a result of this extension, the public comment period ended on April 13,
1991. The public was informed of this extension through a public notice in a
local newspaper and by means of a short Fact Sheet.
6.0 SCOPE AND ROLE OF RESPONSE ACTION WITHIN SITE STRATEGY
The intent of this remedial action presented in this ROD is to eliminate
future risks at this Site. This remedial action will remove the threat posed
by contaminated groundwater at the Site and remediate residual soil
contamination. Remediating residual soil contamination will prevent residual
contamination from adversely impacting groundwater and decrease the future
risk associated with Site soils. This is the only ROD contemplated for the
Site. No other operable units have been identified at this Site.
7.0
SUMMARY OF SITE CHARACTERISTICS
The RI found that the Medley Farm site is contaminated as follows; by VOCs,
SVOCs, and PCBs in surface and subsurface soils beneath the former disposal
areas; and VOCs in the groundwater beneath and downgradient of the former
disposal areas. No contaminants were detected above Contract Laboratory
Program (CLP) Contract Required Quantification Limits (CRQLs) in surface
water or sediment samples. Concentrations of inorganics detected in all
environmental media were consistent with naturally occurring levels found in
the vicinity of the Site as demonstrated by the analyses of background
samples. Background samples were collected for surface and subsurface soils,
groundwater, and surface water and sediment.
PCBs were detected at low levels in surface soils and composite samples of
residual wastes and soils collected from test pits. The highest detected
concentrations of PCBs at the Site were in subsurface soil samples collected
from'test pits 2 and 11. A concentration of 5.379 milligrams per kilogram
(mg/kg) was encounter in TP-2 and 2.442 mg/kg in sample designated TP-ll.
The highest surface 80il concentration of PCB, 1.9 mg/kg, was found at
sampling location SA-S. These concentrations are below the Toxic Substances
Control Act (TSCA) PCB Cleanup Policy level of 10 mg/kg or parts per million
(ppm). No PCBs were detected in groundwater.
Residual source materials remaining at the Site are restricted to very small,
limited areas and found only where former lagoons were once located. When
found, such materials consist of thin, isolated pockets of sludges and
debris.
-------
-14-
Contaminants present in the soils represent limited areas of direct, mostly
shallow disposal. Soil borings and test pits were installed to investigate
suspected lagoon and drum disposal areas. The primary contaminants observed
in soils at the Site are VOCs. The most significant occurrence of VOCe
correlate well with former lagoon locations and areas where heavy
concentrations of drums were stored (refer to Figure 5).
The total volume of contaminated soils present at the Site is approximately
53,000 cubic yards. This volume is based on the area of the Site, as defined
in Figure 6, and the depth down to groundwater which is approximately 60
feet. The total volume of groundwater impacted by the former disposal
activities at this Site is estimated to be 24.1 million gallons.
7.1
RESIDUAL SOURCE MATERIALS
Numerous test pits (refer to Figure 7) were excavated during the RI field
work to allow for source characterization and visual observations of the
underlying soil. Evidence of former lagoons were observed in test pits TP-3,
TP-4, TP-5, TP-7, TP-12, and TP-14. The evidence consisted of thin, isolated
pockets of sludge overlying matted vegetation, and other residual waste
materials. This material was typically encountered at depths of one-half to
two feet below ground surface. No other residual waste materials were
encountered in the trenches excavated for source characterization except for
occasional pieces of scattered debris such as plastic sheeting and rusted
drum fragments.
Shallow 80il samples were also collected from the test pits. These samples
provided additional analytical data to help characterize the Site. Figure 7
provides the locations of the test pits, the VOCe detected in a particular
te8t pit, and the concentration of each VOC detected. Figure 8 provides the
same degree of information as does Pigure 7, but for svocs, pesticides, and
inorganice.
7.2
SOILS
Tables 2, 3, and 4 identify the organic contaminants detected in the soil at
the Medley Farm site for samples collected from test pits, soil borings, and
the surface. The.e tables also provide the concentration encountered at each
sampling point. Table 2 lists the contaminants encountered in the test pits
and Table 3 lists the contaminants detected in samples collected from the
soil borings. Table 3 also provide. the depths the sample. were collected.
The analytical results for contaminants found in surface soil samples are
furnished in Table 4.
Table 5 lists the frequency of detection and the range of concentrations
detected for contaminants found in the soil at the Medley Parm site. Those
compound. listed in Table 5 which are marked with an asterisk were identified
as chemicals of potential concern. A chemical of potential concern is
-------
-N-
<
»-*
tn
APPROXIMATE PROPERTY BOUNDARY
OF THE RALPH MEDLEY FARM
APPROXIMATE LIMITS
OF THE FORMER DISPOSAL AREA
AT THE MEDLEY FARM SITE
FIOURE 6
APPROXIMATK
BOUNDARY OF
DISPOSAL
AREA
-------
69.0
31.0
250.0
10.0
15.0
70.0
250.0
Metnylana Chlorlda
1,2-Dlchloroathana (total)
Tatrachloroathana
Tol
TEST FIT
da
Ian* Chlorlda
Vinyl Chlorlda
hvla
Acatona
Carbon Dlaulflda
1,1-Dlchloroathana
Mathylana Chlorlda
atona
1,2-Dlchloroathana (total)
Trlchloroathana
1,1 -Dlchloroat hana
1, 1-
Banxana
Tatrachloroathane
Toluana
Chlorobaniana
Dlchloroathana
1,2-Dlchloroathana (total)
2-lut«nona
730.0
• 1.0
560.0
13.0
6,600.0
1. 1, 1-Trlchloroathana
Vinl Acatata
Btnylbanxana
Total xylanaa
Trlchloroathana
1,1,2-Trlchloroathana
•anzano
4-Hatbyl-2-Pantanona
Tatracbloroathana
Toluene
1,1,2,2-Tatrachloroathana
16.0
,400.
,300.
•thylbaniana
Styrana
Total xylanaa
TMT ttt »-13
Hathylana Chlorlda 24.0
HOT PIT TP-5
Trlchloroathana 8.0
, ^ TMT PIT TP-9
Acatona 1,100/560.
TMT PIT TP-1
Hathylana Chlorlda
PIT TP-2
Xylanaa 37.0
TMT PIT TP-15
Trlcbloroathana
TMT PIT TP-»
TrlchlorSthanl 390/260.0
• 70.0
1,000.0
390.0
170.0
atona
natanona
Hatby1-2-Pantanona
Total iylanaa
Location and Extent of Test
Pits Excavated During
Rl-Phase IA (Feb.-Mar., 1989)
Location and Extent of Test
Pits Excavated During
Rl-Phase IB (Dec.,1989)
Figure 7
100
100
SCAtC
CONTOUR IMTEnVAl T
concant rat lone mhovn «r« In
mlcrograma p»t kilogram (ug/kg)
Volatile Organic
Compounds Found
In Test Pits
!» **«UM ••< t«
-------
MS* PIT »-4
T18T PIT TP-1
PC» - 12S4 667.0
AluBlnuB 21,000.0
|F*Mlc 30.6
ChroaluB 6.2
Iron 26,500.0
14.1
TMT PI*
-Mathylnao
01 - 1254
TI8I FIX M-7
•xyDpbth
ChroaluB
Iron
Lead
JUualnuB
lUMnlc
ChroaluB
Iron
Location and Extant of Test
Pits Excavated During
Rl-Phase IA (Feb.-Mar., 1989)
Location and Extent of Test
Pits Excavated During
Rl-Phase IB (Dec.,1989)
Figure 8
100
100
SCAlf 1"-tOO'
CONTOUR MTCRVAl >'
Concentrations shown are in
nicrograme par kilogram (ug/kg)
Semi-Volatile Organic
Compounds Found
in Test Pits
-------
TABLE 2
MEDLEY FA AM SITE AI
ANAlYTICAlDATASUMMAAY
OAGANIC COMPOUNDS DETECTED
IN
SOILS luglllg)
,
...
-
I
SAMPLE ID TPI-I TP2-' TP3-' TP.-' TPS.I TP1-' TP8-1 TP9-' TPI2.1 TPI3-1 TPI.-I TPIS-I
COMPOUND
'. '-DIchIol'08lh8ne '.0 E ,.
I, '.Dlchlol'oelhllne .1
I, , , ,- T rk:hloroelhane 560 E
',' ,2-Trlchloroelhane 7'
',1,2:1- T .'r8Chloroe1hanl 3400 E
',2.Dlchlol'oethane 90
1,2-Dlchlol'oelh8ne (10'-1) 12000 E 730 E 250
2-BuI8none 81 1000
.-M81hyt-2-penlanone '6 390
AceIol18 '2 2300 E 810 580 DE
Benz.ne 600 E '60
CIIIbon Dlsullld8 4SO E
Chloroberuene 2500 E 360 E
El\ylbeN- '200 E 110 10
Melhr\8ne Chlol'lde 800 E 24 31
Styrene 110
Tetr8Chloroe1h8n8 (PC E) 61000 E 5400 E 3 J 10
ToIu- 12000 E '300 E '5
Trlchloroell- '2000 E 6600 E 8 280 D 3' 16
Vinyl Acelale 13
Vinyl ChIol'Ide 500 E 69
Xvtene (Total) 3.7 3900 E 620 E '70 250
Dela Flags:
[). Sa~" clluled for IhII 8'181yte.
E. EsUmated resull Analyl. conc;enlrallon .xceeded II. InaIrurnenl calibration range.
Noles:
No yolalile organic compounds _re detected In 101 sa~188 collected !tom lest pUs TP6, TP'O, TP", and TP'6.
-------
TABLE 2 (continued)
MEDLEY FARM SITE RI
ANALYTICAL DATA SUMMARY
ORGANIC COMPOUNDS DETECTED
IN
SOILS (ug/kg)
I
...
co
,
SAMPLE ID TP2-1 TP3-1 TP4-1 TPS-1 TP7-1
COMPOUND
2-Melhylnaphlhalene 550
1,2,4- T richlorobenzene 710000 D 240000 D
Acenaphlhalene 75000
Phenol 94000 D
Bisl2-Elhvlhexvl\Dhthalate 161000 630
Data Flags:
D - Sample diluted for this analyte.
Notes:
No semi-volatile organic cof11)OUnds were detected in soil samples oonected from test pits TP1 and TP9.
Soil samples collected from test pits TP6 and TP8 were not analyzed for semi-volatile organic compounds.
-------
TABLE 3
MEDLEY FARM SITE RI
ANALYTICAL DATA SUMMARY
ORGANIC COMPOUNDS DETECTED
IN
SOILS (ug1lcg)
1,I,2,2.TETRACHLOAOETHANE
METHYLENE CHLORIDE
Sample SoIl Boring Number
. OeDth SB2 SB5 SB6
5-7 . nd 6
10 - 12' 710 D nd .
15 - 17 97 D 9 nd
25 -27 74 D nd nd
Sample Soil Boring Number
OeDth SB3 SB4
5.7' . .
10.12' 50 10
15 - 17 nd 32
25 -27 nd 17
CHLOROFORM
TRICHLOROETHENE
I
..
o
I
Sample SoIl Boring Number
DeDth SB2 SB6
5 - 7 . 13
10 - 12' 600 D .
15.17 nd nd
25 - 27 nd nd
Sample Soil Boring Number
Oeplh SB4 SB7
5.7' . 24
10 - 12' 19 .
15 - IT 32 nd
25 -21' 17 nd
1,2-DICHLOROETHANE
Sample Soil Boring Number
Depth S94 S97 S99 S910
5 - 7 . 97 . 23
10 - 12' 3700 D . 47 .
15. 17 4SOOD nd 32' nd
25-27 680 D nd 99 nd
Data Flag.:
D- Sample diluted lor 1hI. anelyte.
E - E.llma.ed I'8lUll Analyte concen'rallon exceeded the Ins'Rlmen' callbrallon range.
No'es:
nd - Nol delec8lld
. . Nol analyzed.
2-Bu'aoone was delecled In boring S92 a.,5 - 178190 ug/l(g In'he diluled sample.
1,2-Dichloroelhene (Iolal) was delecled In boring SB3 al10 - 12' al17 ugJkg.
PCE was detecled In boring SB7 al 5 . 7' al 12 uglllg.
Results are reported only lor borings in which analytes were delected. Complele lables 01 analytical results are provided In Appendix L.
-------
TABLE :3 (conllnued)
MEDLEY FARM SITE RI
ANALYTICAL OAT A SUMMARY
ORGANIC COMPOUNDS DETECTED
IN
SOIL (ug/kg)
ACETONE
Sample Soil Boring Number
Depth SB2 SB3 S84 S85
5.7 . . . nd
10.12' 18000 DE 140 200 21
15.17 7300 DE 55 1900 0 570 0
25.27 750 0 1S 100 nd
ACETONE (conllnued)
t.:>
...
I
Sample 5011 Boring Number
Depth S8S 587 S88 S89 SB10
5.7 58 4700 0 86 . 31
10 . 12' . . . 94 4
15.17 nd 120 58 110 40
25.27 nd 18 250 0 nd 65
Deta Rags:
D- Sample cIIul8d 'or this analyte,
E . Esllmatltd result. Analyte co0C8mallon exceeded !he Ins!rume'" callbr.llon range.
Noles:
nd . Nol del8c8d
. . Nol analyzed
2.Bulan0n8 wes delecled In boring SB2 a115. 17 el90 uglkg In the diluted sample.
1,2-Dlchloroelhene (Iotal) was delected In boring SB3 al10 - 12' al17 uglkg.
PCE was delected In boring SB7 al 5 . 7' al 12 ug/kg.
Resulls ere reported only lor borings In which enalytes were detected. Complete tables 01 analylicalrelUlIs 8I'e provided In Appendl. L.
-------
TABLE 3 (continued)
MEDLEY FARM SITE RI
ANALYTICAL DATA SUMMARY
ORGANIC Co.1POJNOS DETECTED
IN
SOIL (uglkg)
1,2-DICHLOROBENZENE
NAPHnW..ENE
PH8\O..
Sample Soil Boring Number
DeDth SB3
5 . 7' .
10 . 12' nd
15 . 17' 480
25 .27' nd
Sample Soil Boring Number
DeDth SB3
5 - 7' .
10 - 12' nd
15 - 17' 410
25 -27' nd
Sample Soil Boring Numbe
Depth SB2
5 - 7' .
10 - 12' 77000
15 - 17' nd
25 -27' 690
1,4-DlCHlOROBENZENE
DIETHYLPHTHAlATE
BENZOIC ACID
I
N
eo
,
Sample Soil Boring Number
Deoth SB3
5 . 7' .
1 0 . 12' nd
15 . 17' 2300
25 -27' nd
Sample Soil Boring Number
DeDth SB3
5 - 7' .
10 - 12' nd
1 5 - 17' nd
25 -27' 3200
Sample Soil Boring Number
Deoth SB2
5 - 7' .
10 - 12' nd
1 5 - 17' nd
25 -27' 2600
1,2,4- TRICHlOROBENZENE
Sample Soil Boring Number
Deoth SB2 SB3
5 - 7' . .
10 - 12' nd 700
15 . 17' nd 12000
25-27' 5200 nd
Notes:
nd - Not detected
. - Not analyzed
Results are reported only for borings in which analytes were detected.
Complete tables of analytical results are provided in Appendix L.
-------
TABLE 4.
MEDLEY FARM SITE RI
ANAL YTICAl DATA SUMMARY
ORGANIC COMPOUNDS DETECTED
IN
SOilS (uWkg) - See Note
SAMPLE I.D. HA-1 HA-2 HA-3 HA-4 HA-5 HA~ HA-7 HA-11 HA~A
PARAMETER
1,1,2.2- Tetrachloroethane 91 85
1,1,2-Trichloroethane 160 110
1,2-Dichloroethene (total) 170 11 6 120 200
1,2-Dichloropropane 21
Ethylbenzene 7 33
Methylene chloride 6 23
Styrene 11
T etrachloroethene 37 69 53
Trichloroethene 14 50 7 70
Vinvl chloride 25 25 28 210
SAMPLE LOCATION HA1 1 HA3 I HAS I HA11
SAMPLE I.D. HA 1.21 HA3-21 HAS-21 H A 11-2
PARAMETER
Toxaphene 330
PCB-1254 200 1900 430
SAMPLE 1.0. HA.6 HA.6 HA-11
DILUTION
PARAMETER
1,2,4-Trichlorobenzene 990@ 1100 OJ 1200 @
bis(2-Ethylhexyl)phthalate 29000 E 33000 0
Butylbenzylphthalate 900@ 1100 OJ
Oi-n-butylphthalate 930@ 1100 OJ
Di-n~vlohthalate 5400 4900 DtaJ
Notes:
o - Sample diluted for this analyte.
J - Estimated result. Analyte detected at less than the sample quantitation limit.
E - Estimated result. Analyte concentration exceeded the instrument calibration range.
@ - Estimated result less than 5 times the detection timit.
-23-
-------
TABLE 5
CHEMICALS DETECTED IN SURFACE SOIL
MEDLEY FARM SITE
Frequency Contract Required Range of
Chemical of Detection Quantitation Limit Detected Concentrations
(ua/ko) (ua/ka) (c)
Volatile Oraanlc Compounds(a)
* 1,1,2- Trichloroethane 2/13 5 110-160
*1 ,1 ,2,2-Tetrachloroethane 2113 5 85-91
* 1,2-Dichloroethene (total) 6/13 5 4-200
*1,2-Dlchloropropane 1/13 5 21
Chlorobenzene 1/13 5 3
, Chloroform 1/13 5 3
tIO *Ethylbenzene 2113 5 7-33
.. *Methylene Chloride 11/13 5 2-23
I *Styrene 2113 5 3-11
*T etrachloroethene 4/13 5 5-69
Toluene 1/13 5 1
*Trlchloroethene 4/13 5 7-70
*Vinyl Chloride 4/13 10 25-210
Semi-Volatile Oroanlc Compounds(b)
1,2-Dlchlorobenzene 2115 330 190-200
*1,2,4- Trlchlorobenzene 4/15 330 810-1200
2-Methylnaphthalene 2115 330 140-160
*Butylbenzylphthalate 5/15 330 140-1100
-------
.
M
.,.
I
TABLE 5 (Cont'd)
CHEMICALS DETECTED IN SURFACE SOIL
MEDLEY FARM SITE
*DI-n-butylphthalate
*DI-n-octylphthalate
Dlethylphthalate
*bls(2-Ethylhexyl)phthalate
4/15
4/15
1/15
6/15
330
330
330
330
78-1100
3600-5400
110
82-33,000
Pesticides/PCB
*Toxaphene
*PCB-1254
330-520( d)
200-1900
2113
3/13
160
160
* Chemical of potential concern
(a)Volatlle organic compounds and pesticides/PCB are based on data from the following samples: HA-1 thru HA-12, and HA-
6-A.
(b) Semi-volatile organic compounds are based on data from the following samples: HA-1 thru HA-12, HA-6-A, HA-16, and HA-
16-A.
(c)The range of detected concentrations Include estimated results (chemical concentrations less than the contract-required
quanltation limit).
(d) Duplicate samples taken at same location.
-------
-26-
defined as any chemical detected at or above the CRQL at least once in a
given environmental medium. As stated above, concentrations of inorganics
detected in on-site soil samples were consistent with naturally occurring
levels.
7.2.1
Surface Soils
VOCs and SVOCs were detected in surface soil samples. Figure 9 shows the
locations where the surface soil samples were collected. This figure also
lists the contaminants identified at each sampling location as well as the
concentration of each identified contaminant.
PC8s were detected in several surface soil samples. These samples, with one
exception, are considered to be essentially within the limits of the former
disposal or drum storage areas at the Site. HA-ll, the exception, was
collected from an area which receives sediment runoff from the Site via
erosion. Figure 10 shows the location and lists the associated concentration
of PC8s found at the Site.
One pesticide was detected in one of the 15 surface soil samples.
level of Toxaphene at 330 ug/kg was found at sampling point HA-l.
A trace
7.2.2
Subsurface Soils
No vertical pattern of chemical distribution in subsurface soils is
apparent. Elevated contaminant concentrations were generally found in
samples collected from depths of less than 17 feet. Elevated levels of
VOCs, however, were noted at depths as great as 27 feet in soil borings (SB)
S8-2, S8-4, and SB-9. Low concentrations of SVOCs, ranging from no detection
to 77,000 ug/kg, were observed in SB-2, S8-3, and S8-9.
Figure 11 specifies the soil boring locations, the VOC contaminants detected
at each soil boring location, the concentrations of the contaminants
encountered, and the depths the samples were collected. Figure 12 provides
the same degree of information as Figure 11 does, but for SVOCs rather than
VOCs. Figure 12 a180 furnishe8 background concentrations for several metals
for samples collected from boring 58-1.
Due to the lack of 8teep topography in the immediate disposal areas, the
vegetative cover, and the nature of chemical residuals at the Site, overland
migration of residual chemica18 away from the former disposal area was not
significant. The immediate emergency removal action taken by EPA (June-July
1983) successfully removed the major portion of the source material and
highly contaminated 80ils.
-------
BUMFACB BOIL HA-1
l,2-Dlchloro«than« (total) 170
leal
A ._>:///' ~v
1.2-Dlchloroctbana (total) 11
vinyl Cblorld* 25
SUKfACI SOIL HA-6
Tatr«ohloroathan«
1, 1,
1
T«tr«chloro«ttian«
Trlchloroath«n«
, 1, 2, 2-
,1,2 -Tr loh loro.t h»n«
12.4-Trlchlorobansana
,.
bliU-athylhaxyllphthalata
.
29,000/31,000
,
900/1,100
910/1.100
5,400/4,900
Di-D-butyphthal«r.«
octylphth«lat«
II- liT_V\.Vtil» • I V.^V
8UWACI BOIL HA-6A
1,1,2,2-Tvtrachloroatharm
l,l,2-Trlnhloro«th«n«
l,2-Dlchloro«th»n» (total)
Tetrachloro«th«n«
Trlchlo
Vinyl Chlor
rcB-1254
1,2-Olcbloroathana (total) 120
N&tiiyi
Trlcbloroathan*
Ichloropropana
Nathylana Chlorlda
vu
FIGURE 9
VOLATILE
AND SEMI
VOLATILE
ORGANICS
FOUND IN
SURFACE
SOIL (HA
SAMPLES
-------
to
«o
I
Location and Extant ol Tast
Pita Excavated During
Rl-Phaae IA (Feb.-Mar.. 1989)
Location and Extent ol Tast
Pita Excavated During
Rl-Phase IB (Dec.,1989)
Hand Auger Surlac* Soil Sampling
Location
Figure 10
100 0 100
SCALE r-ioo'
CONTOUH INTERVAL f
200
Concentrations of PCB's In Soil
Medley Farms Site
Galfney. South Carolina
-------
' I V\\\V\\\V --- _"il
BOIL BOftlNO SB-2
coirrAMiiiAifr conoamuCTioii
10-12 ft Ac»ton«
10-12 ft 2-ButMion*
10-12 ft Chloroform
10-12 ft 1,1,2,2-Tatrachloroathana
15-17 ft 1,1,2,2-Tatrachlorosthanm
27 ft Aovtona
27 ft l,l,2,2-T«tr«chloro«th«n«
18,000
90
£00
710
7-38?
7?2
.0-12 ft l,2-Dlchlaroath«na
15-17 ft 1,2-Dichloroathana
25-27 ft 1,2-Dlchloroatbana
1,2-Dichloro«tb«n«
Chlorofora
3,000/3,700
"0
10-12 ft l,2-Dlohloro«th«n«
10-12 ft ttotbylwM Cliloclda
10-12 ft TrioblorcMtban*
13-17 ft l,2-Dlobloro«th«n«
li-17 It NBtkylM* Chlorldi
5-27 ft 1,2-OlchlorocthaiM
-27 ft Mitbrlan* Chlorlda
-27 It nio&lorocttana
COBTAMmAIIT
chloroform
l,l,2,2-T>tr«obloro«th«na
/I/ / .
//
SOIL BOKIMQ 8B-9
COHTAMlHMfr COKCHMTHATIOII
47
32
99
•Olt BOKIHQ BB-3
COHTAMIIIAirr COMCEHTOATIOH
10-12 ft Ac«ton« 140
10-12 ft l,2-01ohloroath«na 2
10-12 ft 1,2-Dicbloroothfaa (total) 17
10-12 ft ItothylMM Chlotld« SO
BOIL BOKIM SB-S
COKTAHIHAirr
10-12 ft Chloroform 5
15-17 ft I,l,2,2-T»trac61oro«th«n« 9
BOIL BOUM BB-7
oiPTH coimuniuurr
5-7 ft l,l,2,2-T«tr«cbloro«th«n«
15-17 ft Cblorob«ni»n«
12
2
Location of Soil Borings Drlllod
During Rl-Phas* IB (Jan.. 1990)
Concentrations shown are in
micrograms per kilogram (ug/kg)
\
Figure 11
100
too
CONTOIM MTCHVAl f
Volatile Organic
Compounds Detected in
Soil Samples from
Soil Borings
-------
BOIL BORINO 8B-1
cqmimmn cxmcmmaaicm
^J U\\
4-Trlchlorobanian«
•Oil, BORINO
CORMHWUR
M-3
CONCIKTRATIO*
,4-Trlchlorob«ni»n»
9-17 ft
5-17 ft
15-17 It
15-17 ft
1,2-Dlchlorob»ni«n«
1,4-Dlchlorobanzan*
Naphthalan*
l,2,4-Trlchlorob«n»n«
Dlathylphthftlata
ft bl»(2-«thylh«xyl)phth«l»t«
ft bl»(2-«thylh«»yl)phth«l«t«
ft bl«(2-«thylh«xyl)phth«lat«
BOII. BORIIIO 8B-5 ' J
CQWrMtlHMR COHCB1ITHATIOII y
15-17 ft bl«<2-«thylh«[yl)phth«l«t« 400
10-12 ft bl»(2-»thylh«*yl)phtlwl«t« 690
25-27 ft bi«(2-«thylh«Kyl)phtb«l«t» 460
5-7 ft bl«(2-«tbylhwcyl)phth«l«ta 1,2
5-7 ft l,2-Dlohlorob«niin.
5-7 ft trlchlotot>»na»na 24
15-17 ft bli(2-athylh*xyl)phthalata 510
25-27 ft bl«(2-«thylh«xyl)phtb«l«t« 510
CO*C1HTK»TIOII
blB(J-«thylh«»yl)p«ith«l«t« 1,400
bl«(2-«thylh«cyl)phth«l«t» 1,700
bl«(2-«thylh«Kyl)pbth«l«t» 660
toil, BORIIIO
COHTAMIHJUrr
cvgcnrnxria*
15-17 ft bl«(2-«thylh«xyl)phth«l«t« 370
Location of Soil Borings Drilled
During Hl-Phaae IB (Jan.. 19901
Concentration* shown are in
microgran* per kilogram (ug/kg)
Figure 12
too
tCALt f-IOO'
CONTOUN MTtMVAl '
Semi-Volatile Organic
Compounds Detected in
Soil Samples from
Soil Borings
-------
-31-
In summary, there appears to be no uniform vertical or horizontal
distribution of the residual chemicals present in the soils at the Site.
Instead, chemical residuals are concentrated in localized areas related to
former direct disposal activities (lagoons and/or drum disposal areas), refer
to Figure 5.
7.3
GROUNDWATER
Elevated concentrations of VOCs were noted in shallow monitoring wells (SW)
SW-3, SW-4, BW-2, SW-10e, and bedrock monitoring well (BW) BW-108. Trace
levels of VOCs were detected in SW-10l, BW-106, and BW-l09. No SVOCs,
pesticides, or PCBs were detected in groundwater. Samples collected from
monitoring wells installed during Phase IA were analyzed for inorganics.
Based on the analytical results, it was determined that any inorganics
present in the groundwater were not Site-related.
Table 6 provides a comprehensive list of VOCs detected in the groundwater and
their concentrations at the Medley Farm site. Table 7 lists the inorganics
and their concentrations for groundwater samples collected from the saprolite
wells and Table 8 lists the inorganics and their concentrations for
groundwater samples collected from the bedrock wells. Table 9 lists the
detection frequencies and the range of concentrations of VOCs found in the
saprolite aquifer. Table 10 provides the same degree of information as Table
9 but for VOCs detected in the bedrock aquifer. Those compounds listed in
Tables 9 and 10 with an asterisk placed in front of them were identified as
chemicals of potential concern.
Figure 13 depicts the contaminants found in each monitoring well completed in
the saprolite aquifer and Figure 14 lists the contaminants detected in each
bedrock monitoring well. These figures also provide the dates these samples
were collected.
Based on data collected during the RI, the horizontal extent of groundwater
contamination appears to be limited to portions of the aquifer directly
beneath and downgradient of the former disposal areas. VOCs in groundwater
are estimated to have traveled 500 to 600 feet in an east-southeasterly
direction from the disposal area, in the direction of groundwater flow.
COncentrations ob8erved at this distance are detectable, but below
established regulatory limits. The highest voc concentrations detected in
the saprolite were found in groundwater immediately beneath the former
disposal area with concentrations decreasing with distance from the disposal
area. Vertically, VOCe have also migrated into the bedrock zone of the
underlying aquifer. Within the confines of the former disposal area,
groundwater contamination extends from a depth of approximately 60 feet to a
depth of approximately 120 feet from land surface. Two deep bedrock wells
(BW-lll and BW-112) installed at the Site encountered competent bedrock
beginning at depths of approximately 160-170 feet beneath the Site;
consequently, these two deep wells are dry and therefore could not be
sampled.
-------
TABLE 6
MEDLEY FARM SITE RI- ANALYTICAL DATA SUMMARY
VOLATilE ORGANIC COMPOUNDS DETECTED ABOVE aUANTIT ATION LIMITS
IN GROUND WATER (ugJI), PHASE lA, PHASE IB, AND PHASE II (See Notes)
J
w
~
I
SAMPLE LOCATION BW1 SW1 BW2 SW3
SAMPLE 1.0. eBW1-3 BW1-4 SW1-4 BW2-1 BW2-2 BW2-3 SW3-1
SAMPLE DATE 09-28-90 11-27-90 11-27-90 08-09-89 01-10-90 09-28-90 08-08-89
PHASE PHASE II PHASE II PHASE II PHASEIA PHASEIB PHASE II PHASEIA
IResamDle' IRe'lmDle'
PARAMETER
Acetone 19 5BJ 18
Benzene
Carbon tetrachloride
Chloro'orm 10
Chloromethane
Methylene chloride 4BJ 3BJ 110 D
Tetrachloroethene 35 D 18 8 190
Toluene
Trlchloroethene 720 D 530 D 140 140
1,1,2,2- Tetrachloroethane
1,1,1- Trichloroethane 310 D 270 D 110
1,1,2- Trichloroethane
1 ,1-Dlchloroethene 440 D 340 D 130 8
1,2-Dlchloroethene (total) 9
1 ,1-Dlchloroethane
1,2-Dlchloroethane 290 D 260 D 120
2-Butanone
2-Hexanone
Notes:
1) No volatile organic compounds were detected above quantltatlon limits In samples BW4-1, SW1-1, BW1-1,
BW3-1, BW4-2, BW110-3, SW106-1., SW102-3, SW104-3, and SW109-3. Compounds identified as common
laboratory contaminants In EPA guidance were considered 10 be present In a sample only If the reported
concentration was greater than 10 times the concentration reported In any laboratory blank (see Section
5.10.2 'or discussion 0' data validation) In accordance with EPA guidance.
D- Sample diluted 'or this analyte.
E - Estimated result. Analyte concentration exceeded the Instrument calibration range.
B - Analyte detected In the associated blank. Result not corrected.
J - Estimated result. Analyte detected at les8 than the sample quantltatlon limit. Constituents detected at less
than quantitation limits are reported only 'or analytical results of BWI-4, SWI-4, BW4-4, and SW106-4
'or comparison to initial Phase II results at these locations.
- Raw data results for BWI-3, SWI-2, BW4-3 a~d SW106-3 were Inconsistent with concentrations
previously reported. These wells were subsequently resampled (Nov. 26 and 27, 1990) and
samples were submitted to Ecotek laboratory for analysis. The Ecotek results are indicated.
by the 'Resample' designation.
-------
TABLE 6 (continued)
MEDLEY FARM SITE RI- ANALYTICAL DATA SUMMARY
VOlATilE ORGANIC COMPOUNDS DETECTED ABOVE aUANTIT ATION LIMITS
IN GROUND WATER (ugJI), PHASE lA, PHASE IB, AND PHASE II (See Notes)
CoO
u
SAMPLE LOCATION SW3 SW4 SW4
SAMPLE I.D. SW3-2 SW3-3 *lIW4-3 SW4-" SW4-1 SW4-2 SW4-3
SAMPLE DATE 01-09-90 09-25-90 09-28-90 11-28-90 08-08-89 01-09-90 09-25-90
PHASE PHASE IS PHASE II PHASE II PHASE II PHASEIA PHASE IS PHASE II
(Reslmple)
PARAMETER
Acetone
Benzene
Carbon tetrachloride . 130
Chloroform 74
Chloromethlne 15
Methylene chloride 48J
T etrachloroethene 200 190
Toluene 9.5
Trlchloroethene 130 190 49
1,1,2,2- Tetrachloroethane 19
1,1,1- Trichloroethane 5.6 3400 D 2800 E 2500 D
1,1,2- Trichloroethane 18 8 13
1,1-Dlchloroethene 1800 D 2100 E 2200 D
1,2-Dlchloroethene (total) 5.4 31
1,1-Dlchloroethane 120 38
1,2-Dlchloroethane 13
2-Butanone
2-Hexanone
Notes:
1) No volatile organic compound. were detected above quantltatlon limit. In sample. BW4-1, SW1-1, BW1-1,
BW3-1, BW4-2, BW110-3, SW106-1, SW102-3, SW104.3, and SW109-3. Compounds identified a. common
laboratory contaminants In EPA guidance were considered to be present In a sample only If the reported
concentration was greater than 10 time. the concenlration reported In any laboratory blank (see Section
5.10.2 for discussion of data validation) In accordance with EPA guidance.
D - Sample diluted for this analyte.
E - Estimated result. Analyte concentration exceeded the Instrument calibration range.
B - Analyte detected In the associated blank. Result not corrected.
J . Estimated result. Analyte detected at Ie.. than the sample quantltatlon limit. Constituents detected at less
than quantitation limits are reported only for analytical results of BW1-4, SW1-4, BW4.4, and SW106.4
for comparison to Initial Phase II result. at these locations.
. Raw data results for BW1-3, SW1-2, BW4-3 and SW108.3 were Inconsistent with concentrations
previously reported. These wells were subsequently resampled (Nov. 26 and 21, 1990) and
samples were submitted to Ecotek Laboratory for analysis. The Ecotek results are indicated
by the 'Resample' designation.
-------
TABlE'6 (continued)
MEDLEY FARM SITE RI- ANAlYTICAL DATA SUMMARY
VOlATILE ORGANIC COMPOlJ\IOS DETECTED ABOVE QUANTIT A TION LIMITS
IN GROUND WATER (ugJI), PHASE lA, PHASE IB, AND PHASE II (See Notes)
,
..
~
,
SAMPLE LOCATION SW101 BW105 BW106 SW106
SAMPLE 1.0. SW101-3 BW105-1X BW105-1Z BW105-3 BW106-1 .SW106-3 SW106-4
SAMPLE OAr.: 09-26-90 09-19-90 09-18-80 10-15-90 09-28-90 09-27-90 11-28-90
PHASE PHASE II PHASE II PHASE II PHASE II PHASE II PHASE II PHASE II
lResamDle)
PARAMETER
Acetone 160 5 BJ
Benzene 95 11
Carbon tetrachloride
Chloro'orm
Chloromethane 110
Methylene chloride 4BJ
Telrachloroethene
Toluene 91
Trichloroethene
1,1,2,2-Tetrachloroethane
1,1,1- Trichloroethane 7 90 80 9 5.2 9.3
1.1.2- Trichloroethane
1 ,1-Dlchloroethene 27 39
1.2-Dlchloroethene (total)
1,1-Dlchloroethane
1,2-Dlchloroethane
2-Butanone 13 170
2-Hexanone 14
Notes:
1) No volatile organic compounds were detected above quantltation limits in samples BW4-1, SW1-1, BW1-1.
BW3-1, BW4-2, BW110-3. SW106-1, SW102-3, SW104.3, and SW109.3. Compounds Identified as common
laboratory contaminants In EPA guidance were considered to be present In a sample only If the reported
concentration was greater than 10 times the concentration reported In any laboralory blank (see Seclion
5.10.2 for discussion of data validation) In accordance wilh EPA guidance.
D- Sample diluted for this analyte.
E- Estimated result. Analyte concentration exceeded the Instrument calibration range.
B - Analyte detected In the associated blank. Result not corrected.
J - Estimated result. Analyte detected at less than the sample quantitallon limit. Constituents detected at less
Ihan quanlilation limits are reported only 'or analytical results of BW1.4. SW1-4, BW4.4, and SW106.4
for comparison to initial Phase II results at these locations.
. naw dala results for BW1-3. SW1-2. BW4-3 and SW106.3 were Inconsislent with concenlrations
previously reported. These wells were subsequently resampled (Nov. 26 and 27, 1990) and
samples were submitted to Ecotek laboralory for analysis. The Ecotek results are indicaled
by Ihe 'Res ample' designalion.
-------
TABLE 6 (continued)
MEDlEY FARM SITE RI - ANALYTICAL DATA SUMMARY
VOLATilE ORGANIC COMPOUNDS DETECTED ABOVE OUANTITATION LIMITS
IN GROUND WATER (ugll), PHASE lA, PHASE IB, AND PHASE II (See Notes)
,
eo.
C-"
I
SAMPLE LOCATION BW108 SW108 BW101
SAMPLE 1.0. BW108-3 SW108-3 BW109-3
SAMPLE DATE 10-02-90 09-25-90 10.15.90
PARAMETER
Acetone
Benzene
Carbon tetrachloride
Chloroform 6
Chloromethane 26
Methylene chloride
T etrachloroethene 230 30
Toluene
Trlchloroethene 380 45
1,1,2,2-Tetrachloroethane
1,1,1- Trichloroethane 15 13 6
1,1,2- Trichloroethane
1,1-Dlchloroethene 80 11
1,2.Dlchloroethene (total) 17
1,1-Dlchloroethane
1,2-Dlchloroethane 12
2-Butanone
2-Hexanone
Notes: .
1) No volatile organic compounds were detected above quantitatlon limits in samples BW4-1, SW1-1,
BW3-1, BW4-2, BW110-3, SW106-1, SW102.3, SW104-3, and SW109-3. Compounds Identified as commo
laboratory contaminants In EPA guidance were considered to be present in a sample only If the reported
concentration was greater than 10 times the concentration reported In any laboratory blank (.ee Section
5.10.2 for discussion of data validation) in accordance with EPA guidance.
D- Sample diluted for this analyte.
E - Estimated result. Analyte concentration exceeded the Instrument calibration range.
B. Analyte detected in the associated blank. Result not corrected.
J . Estimated result. Analyte detected at less than the sample quanlilatlon limit. Constituents detected at
than quantitation limits are reported only for analytical results of BW1-4, SW1-4, BW4-4, and SW106-4
for comparison to Initial Phase II results at these locations.
. Raw data results for BW1-3, SW1-2. BW4-3 and SW106-3 were inconsistent with concentrations
previously reported. These wells were subsequenlly resampled (Nov. 26 and 27, 1990) and
samples were submitted to Ecotek laboratory for analysis. The Ecolek results are indicaled
by the 'Res ample' designalion.
-------
TABLE 7
MEDLEY FARM SITE RI
ANAL YTleAL DATA SUMMARY
t.ETALS DETECTED
IN
GROUND WATER (u~ - See Noms
SAPROUTE WEUS
EPA Drinking Wlter Re
-------
TABLE 8
MEDLEY FARM SITE AI
NW.. YTICAL. DATA SUMMA.ClY
t.£T ALS DETECTC..D
IN
GROUND WATER (ug.1) . See Notes
BEDRXK'M3.1.S
EPA Drlnklna Water Reaulatlons
SAMPLE LOCATION BW1 BW2 BW4. Promulgated Proposed
SAMPLE J.D. BW1.1 BW1.3 BW2.1 BW4.1 MCLa (ualJ) MCLa (uall) .
PARAMETER
Aluminum, total 1730 3i5 500 5570 . .
Aluminum. dissolved BCX. (b)
Antimony, total BCX. (c) BCX. (c) ED.. (c) BCX. (c) . 10/5 (9)
Antimony, dissolved BCX. (c)
Arsenic, total BCX. (b) BCX. (c) ED.. (c) BCX. (c) 50 (d) .
Arsenic, dissolved 12.2
Barium, total BCX. (b) BCX. (b) ED.. (b) BCX. (b) 1000 (d) 2000 (h)
Barium, dissolved BCX. (b)
Beryllium, total BCX. (c) BCX. (c) ED.. (c) BCX. (c) . 1 (9)
Beryllium, dissolved BI1 (c)
Cadmium, total BCX. (c) BCX. (c) 10 BCX. (c) 5 (i) .
Cadmium. dissolved BCX. (c)
Calcium. total iUO 6iiO 7300 32200 . .
Calcium, dissolved 6770
Chromium, total BCX. (b) sa. (c) ED.. (c) BCX. (b) 100 (i) .
Chromium. dissolved sa. (b)
Cobalt. total sa. (b) sa. (c) ED.. (c) BCX. (b) . .
Cobalt, dissolved BCX. (c)
Copper, total sa. (b) sa. (c) ED.. (c) BCX. (c) 1000 (e) 1300 (I)
Copper, dissolved sa. (b)
Iron, total aoo 613 870 3410 300 (e) .
Iron, dissolved BI1 (b)
Lead, total 5.8 4 ED.. (b) BCX. (c) 50 (d) (15) (j)
Lead, dissolved sa. (b)
Magnesium, total sa. (b) sa. (b) ED.. (b) 13400 . .
Magnesium, dissolved sa. (b)
Manganese, total 5i.7 sa. (b) 33 183 50 (e) .
Manganesa, dissolved sa. (b)
Mercury, total sa. (c) sa. (c) ED.. (c) sa. (c) 2 (d) .
Mercury, dissolved sa. (c)
Nickel, total BCX. (c) sa. (c) ED.. (b) BCX. (c) . 100 (9)
Nickel, dissolved sa. (c)
Potassium, total BCX. (b) sa. (b) ED.. (b) BCX. (c) . .
Potassium, dissolved sa. (b)
Selenium, total sa. (c) sa. (c) ED.. (c) sa. (c) 50 (i) .
Selenium, dissolved sa. (c)
Silver, total sa. (b) sa. (c) ED.. (c) sa. (c) 100 (e) .
Silver, dissolved sa. (b)
Sodium, total 10700 iOOO 8400 12900 . .
Sodium, dissolved i100
Thallium, total sa. (c) sa. (c) ED.. (c) sa. (c) . 2/1 (9)
Thallium, dissolved sa. (c)
Vanadium, total sa. (b) ED. (b) ED.. (c) sa. (b) . .
Vanadium, dissolved sa. (b)
Zinc, total sa. (b) sa. (b) 1tO 38.7 (a) 5000 (e) .
Zinc. dissolved sa. (b)
Nol8s:
(a) Estimat8c:l result.
(b) Below contract required detection limit.
(c) Below Instrument detection limit
(d) Primary Maximum Contaminant Level (MCL)
(e) Secondary MCL for public water systems
(f) Federal Register, August 18, 1988
(g) Feeteral Register, July 25, 1990
(h) Federal Register, January 30, 1991
(I) Federal Register, January 30, 1991 (effective date July 30, 1992)
(j) Superfund cleanup level
-37-
-------
TABLE 9
CHEMICALS DETECTED IN GROUND WATER - SAPROUTE WELlS
MEDLEY FARM SITE
Chemical
Volatile Oraanic ComDOunds
.1.1-Dichloroethene
.1 .1-Dichloroethane
.1,1,1-Trichloroethane
.1,1,2-Trichloroethane
.1,2-Dichloroethene (total)
Acetone
Benzene
Bromomethane
Carbon Disulfide
Chlorobenzene
Chlorofor:n
.Chloromethane
.Methylene Chloride
*T etrachloroethene
Toluene
*Trichloroethene .
Semi-Volatile Oraanic ComDOunds
1.2,4- Trichlorobenzene
Frequency
of Detection
Contract Required
Quantitation Umit
(uaJ I )
Range of
Detected Concentrations
(uall \(a)
1.1-2200
38-120
1.5-3400
8-13
5.4-31
7
0.7
1.9-3
3
0.9
3-4
5.5-26
2.1-38
2-200
1-1.5
6-190
3
6/14
2114
9/14
2114
3/14
1/14
1/14
3/14
1/14
1/14
2114
3/14
3/14
5/14
2114
5/14
5
5
5
5
5
10
5
10
5
5
5
10
5
5
5
5
. Chemical of potential concem
(a) Detected concentrations include estimated results (chemical concentrations less than the contract-required quantitation limit).
1/2
10
-38-
-------
. .4 '.'. ~- - --
"'---.... -
TABLE 10
CHEMICALS DETECTED IN GROUND WATER - BEDROCK WELlS
MEDLEY FARM SITE
Chemical
Frequency
~ Detection
Contract Required
Quantitation Umlt
(uall )
Range of
Detected Concentrations
(uall ) (a)
Volatile Oraanic Compounds
*1,1.Dichloroethene
1,1-Dichloroethane
*1,1,1-Trlchloroethane
1,1,2.Trichloroethane
* 1 ,2.Dichloroethane
* 1 ,2.Dichloroethene (total)
*2-Butanone
*Acetone
*Benzene
Carbon Disulfide
Chlorobenzene
*Chloroform
Chloromethane
*Methylene Chloride
*Tetrachloroethene
TOluene(b)
-Trichloroethene
6/15
2/15
9/15
1/15
5/15
2/15
4/15
3/15
1/15
1/15
1/15
6115
1/15
3115
5/15
2/15
5/15
5
5
5
5
5
5
10
10
5
5
5
5
10
5
5
5
5
2.2-440
2-3
4-310
3
12.290
2-17
6.8-13
1-18
11
4
1
4-7
2
48-110
8-230
3-5
140-720
Semi-Volatile Oraanic ComDOunds
None detected
- Chemical or potential concem
(a)Cetected concentrations include estimated resultS (chemical concentrations less than the contract.required quantitation limit).
(b)Cetected concentrations ~ 5 uWlIs for a diluted sample with a Sample Quantltation Umit of 25 uWl.
-39-
-------
l«*A=5*'
;* •»!»?J-** t ***i f •- r~
.*""* —- _ „ i,,—,,, ^^ *
• -.^-^"-^fc •-,'
—tlf'^s-^. •--•Z^^if
\
-tto~
^1\ . ^>
••rs'Tfr'St ar\\*
•***•.
'^
;-t
.'*
LvTrH
'fe-
? :vnt^
-I« i-iXirr-
^
I '.V
•/a/«9 1/9/90
1,1,1-TrIchloroathana 3400 2iOO
1,1,2-TrIchloroathana • 13
1,1-Dichloroathana 1800 2100
1,2-Dlchloroathana (total) 31
1,1-Dichloroathana 120 31
9/25/90
2500*
2200
'««
~\
i==±i
^Pr^T^'
~Z3^-t>o~
r["//
*w
vx^-x--v -^o^t1
y\ \
V . • mo Datactlona—^ SM-104
'/>•-•
//I
\
BW-111
I
IttDIk (SCDHKC):
tsN-4
«v
ChloroaathaiM
T«trachloro«thana
Trlchloro«than«
1,1,1-Trlchlorovtliana
1,1-Dlchloroathana
W
/
Mi
^
#7
»
'/
^:
^^-^
>£; - *'•-
SK-102
\rsjfo
tiomp
Piaioaatar (PZ) ^
Saprollta Nail (8W) ^
Badrock Nail (BN) ^
******
Concentratlona ahown ara In
ug/1 (BjlcrograBB/lltax)
Date* aanipleB wara
collected ia alao provided.
******
SCALI
•o Oataetlo
\
,BW-3
9/28/90
•1,1,1-Tcichloroathana 7
^^;
"ZJr./
r8H-10C
\ \\\
/s^>
//%>>
f;::\
•(^
I V .
-^,
IcT
* rit
•Will
"*«OO ~.
^
,','/•»
FIGURE 13
VOLATILE ORGANICS DETECTED IN
WATER TABLE ZONE OF AQUIFER
-------
Trlchloroathana
1,1, 1 -Trlchloroathana
1,1-Dlchloroathana
1,2-Dlchloroathana (total) 17
1,2-Dlchloro.th.n. 12 1^% SltU
wjv^- -»^~——• —1^8' * ~\ illniJ
9/19/90 9/18/90 10/15/80
85 11
8/9/90 1/10/90 8/28/90
18
10
110
35 18
Aoton*
Chloroform
Nathylnw Chlorldto
Tvtrcotaloroatlwn*
Trlchloroathana
1,1,1-TrlchlorcMthuw
1,l-Dlchloro«than«
l-Trlchloro«th«n« 310 270 110
1,1-Dlchloroathana
1,2-Dlchloroathana
IflllH
Dry
rA\\^»ti ii^ss
1,1,1-Trlchloroathana
2-lutanona
M \f--JA
/ t;
i i *. r\i •
FIGURE
VOLATILE ORGANICS
1.101 IIP
(PI)
Siprollt* W«ll (BN)
••drook Wall (BN)
*•••**
Conontration* ahown >r> In
uq/1 (•lcrogr>M*/lltBr)
Data* aaaplaa war*
collacted la alao provided.
SCALE
-------
-42-
The presence of VOCs in both portions of the aquifer, the saprolite and
bedrock, is consistent with the interrelated nature of these two
water-bearing zones. The concentrations of VOCs decrease with depth. Based
on the observed distribution of VOCs, the primary path of contaminant
migration in groundwater is through the saprolite and the bedrock transition
zone into the fractured bedrock.
7.4
STREAM SEDIMENT/SURFACE WATER
No contaminants were detected in the surface water samples, the sediment
samples, or the monitoring wells closest to Jones Creek. However, based on
analytical data for samples collected from monitoring wells SW-I08, BW-10S,
and BW-I06, groundwater contaminated with VOCs may be entering tributaries to
Jones Creek. Even if this is the case, any VOCs discharging into either of
these tributaries along with the groundwater, are volatilizing from the water
column prior to commingling with the waters in Jones Creek. This is verified
by the analytical data for surface water and sediment samples collected from
Jones Creek. The locations of the surface water/sediment sampling points can
be found in Figure 15.
7.5
HYDROGEOLOGICAL SETTING
Residual soil at the Site is absent or occurs as a thin layer overlying the
saprolite. This soil layer ranges in thickness from zero to 11 feet and
typically consists of clayey silt with varying amounts of fine sand, clay,
mica flakes, and quartz gravel. In some areas, thin layers of clayey
silt/silty clay fill were encountered. The fill was probably placed on-site
during the 1983 immediate removal action and Site clean-up. The fill is not
significant in term. of overall Site geology.
The saprolite is relatively thick acro.. the Site, ranging from 50 to 70 feet
near the former disposal area. to 7 to 28 feet along Jones Creek at the
eastern boundary of the property. The lithologic characteristics of the
saprolite are similar to the residual soils and are relatively consistent
both vertically and horizontally. Saprolite observed in borings drilled at
the Site consists predominantly of a silt with varying amounts of fine to
coarse sand, clay, mica flakes, and quartz gravel. The predominant relict
(texture) and foliation indicate parent rocks of metasilt.tone, gneiss, and
mica schist, though in several instances, the parent rock was not
identifiable.
The bedrock was inve.tigated by continuous coring at numerous locations. The
bedrock consists primarily of a gneiss that varies from a schistose gneiss to
a quartzo-feldspathic and quartz-amphibole gneiss. The bedrock is
predominantly hard, .lightly weathered to fresh, gray, and fine to
medium-grained, with closely to moderately closely (0.5 to 2.5 feet) spaced
joints. The joints tend to be smooth to rough and moderately dipping (35 to
55 degrees). Foliation of the bedrock is moderately dipping (35 to 55
degrees) to steep (55 to 85 degrees).
-------
CS>
A .—«•-
A M.«M
A •—•"•«•
FIOURB 15
LOCATIONS
OF SURFACE
WATBR/
SEDIMENT
SAMPLES
-------
-44-
Auger refusal was encountered at depths ranging from approximately 70 to
100 feet within the former disposal area. The overburden thickness decreases
outward toward the boundaries of the Medley property, to a minimum of
approximately 20 feet adjacent to Jones Creek. Eo, .:ence of groundwater
movement through the bedrock was observed in the form of iron oxide staining
along joint surfaces.
Groundwater at the Medley Farm site occurs in the saprolite, in the zone of
highly fractured and weathered bedrock zone (identified as the transition
zone), and in moderately fractured bedrock underlying the Site. Depth to
groundwater at the Site is on the order of 56 to 68 feet in the disposal
area, decreasing to six to eight feet adjacent to Jones Creek.
Subsurface conditions encountered at the Site are depicted in several cross
sections of the Medley property. Figure 16 provides the orientation of the
cross sectional views A-A', B-B', and C-C'. Figure 17, Figure 18, and
Figure 19 show each cross sectional view, respectively.
In general, an aquifer system consisting of flow through both porous and
fractured media exists in the Piedmont Province and at the Medley Farm site.
The water table generally occurs in the saprolite across most of the Medley
Farm property, with the saprolite serving as a porous medium for groundwater
flow. In the vicinity of BW-2 at the eastern edge of the former disposal
area, the water table occurs in the bedrock transition zone. Although the
groundwater occuring in the saprolite and bedrock is part of an
interconnected aquifer system, the groundwater in the bedrock at the Site is
under semi-confined to confined conditions, with the exception of the BW-2
vicinity where the water table occurs in the bedrock.
The shallow saprolite has a higher porosity than the bedrock, but due to the
low hydraulic conductivity, the saprolite acts mainly as a storage and
recharge source for the bedrock. Yields from wells completed in the
saprolite are generally very low. Yields from bedrock wells are relatively
high, but depend on the nature, quantity, and interconnection of the
secondary (fracture) porosity the well encounters. The bedrock wells
completed in the moderately fractured bedrock at the Site demonstrate
relatively high yield. (5-7 gpm). Groundwater in the saprolite wells,
however, can be completely evacuated with a bailer requiring several hours
for complete recovery of the well.
Groundwater flow in the water-table aquifer at the Medley Parm site is
primarily to the southeast towards Jones Creek, as shown in Figure 20. The
hydraulic gradient change. 81ightly acr08S the Site, ranging from 0.056
beneath the former disposal area to 0.046 further downgradient. The primary
direction of groundwater flow in the bedrock aquifer is also to the
southeast, as shown in Pigure 21, with an average hydraulic gradient of
0.042. The calculated horizontal groundwater flow velocities are estimated
to range from 1.05 feet/day (384 feet/year) to 1.28 feet/day (486 feet/year)
for the saprolite and 0.31 feet/day (81 feet/year) for groundwater in the
bedrock.
-------
CROSS SECTIONS
LOCATION MAP
Medley Farm Site
Gaffnay, South Carolina
R»m«dl«l Inv.itlgitlon/
f«««lbimy Study
-------
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-------
FIGURE 20
WATER TABLE
POTENTIOMETRIC SURFACE
10/29 & 10/30/1990
Medley Farm Sit*
Gallnty. South Cuollni
Investigation/
F««llbliMy Study
-------
BEDROCK
POTENTIOMETRIC SURFACE
10/29 & 10/30/90
Medley Farm Site
Glllniv, Sou in Cirollnt
-------
-Sl-
The hydraulic data collected during the RI also showed that the Sprouse well
is located hydraulically upgradient of the Site. This was a concern as
methylene chloride was detected in samples collected by SCDHEC from the
Sprouse well in June 1983 and July 1984. At that time, this contamination
was suspected to be Site related. The findings of the RI confirmed that this
contamination did not originate from the Medley Farm Superfund site.
Water level measurements made in six saprolite/bedrock well clusters indicate
upward vertical hydraulic gradients of varying magnitude across most of the
Site. Upward vertical gradients were observed at four monitoring locations
(BW-l/SW-1, BW-10S/SW-4, BW-106/SW-106, and BW-108/SW-108). Downward
vertical gradients were observed at only two locations (BW-3/PZ1 and
BW-109/SW-109) monitored during October 1990. The presence of upward
vertical gradients indicate vertical migration of contaminants from the
Site. The presence of upward vertical gradients reduces the potential for
contaminants to move downward in the aquifer.
Jones Creek and its tributaries serve as zones of groundwater discharge from
the Medley Farm site. Base flow in Jones Creek at the Site is 200 gpm.
Water levels in the saprolite and bedrock adjacent to Jones Creek (PZ-1 and
BW-3) are consistently above water levels observed in Jones Creek at staff
gauge SL-1. Similarly, water levels in the saprolite and bedrock at SW-108
and BW-108 are greater than water levels observed in the tributary at staff
gauge SL-3. The water level in BW-106 is greater than the water level
observed in the tributary at staff gauge SL-S. However, the water level in
SW-106 is less than the water level observed at staff gauge SL-S, indicating
localized surface water recharge to the saprolite aquifer at this location.
Refer to Figure lS for the staff gauge locations.
8.0
SUMMARY OF SITE RISKS
Based upon reasonable maximum exposures to residual chemicals at the Medley
Farm Site, the risk assessment showed that there is neither significant
carcinogenic nor non-carcinogenic risk to either human health or the
environment under present day, baseline conditions. The cumulative
carcinogenic human health risk at the Site is estimated to be 8.6 x 10-7.
This baseline risk i. acceptable as this risk is below the 1 x 10-6 level
and the EPA remediation level goals of 10-4 to 10-6 for Site
remediation. This risk level of 8.6 x 10-7 is attributable to Site soils
as there are no groundwater receptors on the Site or downgradient near the
property boundary.
The potential for non-carcinogenic human health effects under present day
conditions (hazard index. 2.9 x 10-4) is below the EPA hazard quotient of
one. A value above one would indicate a potential for adverse effects. This
hazard index of 2.9 x 10-4 is also attributable to only soils as there are
no present groundwater receptors on or near the Site.
..
-------
-52-
A future use risk scenario was also developed for the Medley Farm site. The
future risk scenario assumed residential development of the Site including
the installation of potable wells and therefore, consumption of groundwater
at the Site would occur. Under this future use scenario, the total risk
becomes 1.1 x 10-1 which i8 greater than the acceptable risk range of
10-4 to 10-6. The hazard index under the future residential use scenario
becomes 5.6 which is above unity. This future risk is the basis for the
remedial action specified in this ROD.
No potential for significant risk to wildlife on the property is expected to
occur under present day conditions or under the future residential use
scenario.
8.1
CONTAMINANTS OF CONCERN
Table 11 provides a comprehensive list of the contaminants identified as
chemicals of potential concern. A contaminant was included in Table 11 if it
was detected at or above the CRQL at least once in a given environmental
media. Of the 23 chemicals detected at the Site, 17 were identified as
chemicals of potential concern. Tables 12 and 13 provide the exposure point
concentrations that were used in the risk calculations.
The primary chemical residuals observed in surface soils at the Site are
VOCs, which were detected above the CRQL in ten of the surface soil samples.
SVOCs were not as widely distributed. They were detected above the CRQL in
three samples and below the CRQL in two other samples. PCB-1254 was only
detected in three samples and toxaphene in one, in each instance above the
CRQL. The extent of site-related chemicals in surface soil is essentially
limited to the former disposal area.
Elevated concentrations of VOCs were detected in groundwater samples from 12
of the monitoring wells at the Site; SVOCs, pesticides, and PCBs were not
detected above the CRQL. The horizontal extent of site-related chemicals in
groundwater appear limited to the former disposal area and immediately
downgradient. Vertically, VOCs have been confirmed in both the saprolite and
bedrock portions of the aquifer.
8.2
EXPOSURE ASSESSMENT
The populations that potentially may be exposed to site-related chemicals are
residents living in the area surrounding the Medley property and tre8pa88ers
who may enter the property, including hunter8 and children. The closest
potentially exposed individuals consist of the property owners, who live on
the Medley property, approximately 100 feet we8t of the Site. Approximately
300 people live within a one-mile radius.
A complete exposure pathway includes a chemical source/release, retention or
transport medium, expo8ure point, and route of exposure. Two potential human
exposure pathways were identified: (1) exposure to site-related chemicals in
the 9roundwater; and (2) exposure to Site Boil.
-------
TABLE. 11
CHEMICALS OF POTENTIAL CONCERN BY MEDIUM
MEDLEY FARM SITE
Surface
Soil
Ground Water
(Saprolite)
Ground Water
(Bedrock)
Volatile Oraanic Compounds
1,1 ~Dichloroethene X X
1,1-Dichloroethane X
1,1,1- Trichloroethane X X
1,1,2- Trichloroethane X X
1,1,2,2- Tetrachloroethane X
1,2-Dichloroethane X
1,2-Dichloroethene (total) X X
1,2-Dichloropropane X
2-Butanone X
Acetone X
Benzene X
Chloroform X
Chloromethane X.
Ethylbenzene X
Methylene Chloride X X X
Styrene X
Tetrachloroethene X X X
Trichloroethene X X X
Vinyl Chloride X
Semi-Volatile Oraanic Compounds
1,2,4- Trichlorobenzene X
Butylbenzylphthalate X
Di-n-butylphthalate X
Di-n-octylphthalate X
bis(2-Ethylhexyl)phthalate X
Pesticides/PCB
Toxaphene X
PCB-1254 X
x = Chemical detected in that medium
-53-
-------
TABLE 12
EXPOSURE POINT CONCENTRATIONS - SURFACE SOil
MEDlEY FARM SITE
Concentration
Chemical (I£alka)
1,1,2-Trichloroethane 53.7
1,1,2.2- Tetrachloroethane 35.2
1,2-DichIoroethene (Total) 84.1
1,2-Dichloropropane 7.1
Ethylbenzene 10.3
Methylene Chloride 8.4
Styrene 4.6
Tetrachloroethene 28.3
Trichloroethene 25.8
Vinyl Chloride 59.8
1,2,4- Trichlorobenzene 557.9
ButylbenzylphthaJate 486.1
Di-n-butyiphthaJate 397.5
Di-n-octylphthalate 1,696.8
bis (2-EthyIh8xyI)phthalate 10,001.1
Toxaphene 164.8
PCB-1254 512.6
Concentrations are the 95 percent upper confidence limit on the arithmetic average of
measured concentrations in onsite surface soils.
-54-
-------
TABLE 13
EXPOSURE POINT CONCENTRATIONS - GROUND WATER
MEDLEY FARM SITE
Concentration
Chemical (Molliter)
1,1-Dichloroethene 1490.60
1,1-Dichloroethane 37.16
1,1,1-Trichloroethane 1636.35
1,1,2-Trichloroethane 5.96
1,2-Dichloroethane 113.66
1,2-Dichloroethene {totaQ 10.85
Acetone 8.36
Benzene 4.68
2-Butanone 5.79
Chloromethane 7.55
Methylene Chloride 32.68
Tetrachloroethene 107.60
TrichJoroethene 327.77
Concentrations are the 95 percent upper confidence limit on the arithmetic average of
measured concentrations in ground water wells SW3, SW4, SW109. BW2, BW105, and
BW109.
-55-
-------
1-
-56-
Human exposure to groundwater is of concern with respect to its potential use
by local residents as drinking water. Potential exposure points are private
wells that may be installed on the Site or downgradient from the Site and off
of the property, where ingestion of water would be the route of exposure.
There are currently no human receptors for groundwater at the Site nor at the
property boundary. There are four private domestic water wells within a one
mile radius of the Site (Figure 4). The nearest well, the Sprouse well, is
upgradient from the Site. The remaining three are at least one-half mile
. from the Site and are not directly downgradient. Municipal water supply
lines serve much of the area, running along all major roads (refer to Figure
4) .
Although there are no current human receptors, a future residential use of
groundwater scenario was developed for this Site because the groundwater is
classified as a current potable drinking water aquifer by the State of South
Carolina.
Potential direct contact with site-related chemicals in surface soil is
limited to local residents or unauthorized persons who could possibly enter
the Site. Probable exposure routes are through incidental ingestion and
dermal absorption. Particulate inhalation is an unlikely route of exposure
due to the thick vegetative cover at the Site. Off-site exposure to
site-related chemicals is unlikely due to the vegetative cover at the Site
which restricts off-site transfer either by overland runoff or atmospheric
transport of soil particles. Exposure due to vaporization of site-related
chemicals is considered to be minimal due to low concentration of volatile
contaminants in the soil and therefore was eliminated as a potential route
for exposure.
Other potential pathways for human exposure to site-related chemicals in
surface soil are through the food chain. One potential pathway of human
exposure is the direct ingestion of blackberries growing at the Site. A
second potential pathway of human exposure consists of hunters harvesting
and, along with family members, consuming wildlife that have fed on the
Site. Wildlife species that might be hunted and con8umed include white-tail
deer, rabbits and quail. These species could feed on vegetation that may
contain site-related chemicals through ingestion or dermal contact.
Potential receptors also are limited due to the sparsely populated rural
nature of the area. Furthermore, much of the Site is covered by clean fill,
thereby limiting potential uptake of site-related chemicals by vegetation.
COnsequently, these pathways are retained.
Summary of Exoosure Pathways for Ouantitative Evaluation
.
exposure to site-related chemicals in groundwater via ingestion of
drinking water; assuming a consumption rate of 2 liters per day, 365
days per year for 30 years.
.
contact with site-related chemicals
the ingestion and dermal absorption
of 0.2 grams per day (child) or 0.1
per year for 30 years.
in near-surface Site soils through
routes; assuming an ingestion rate
grams per day (adult), 365 days
-------
-57-
Summarv of Exposure pathwavs for Qualitative Evaluation
Exposure to site-related chemicals through the food chain
8.3 TOXICITY ASSESSMENT OF CONTAMINANTS
Cancer potency factors (CPFs) have been developed by EPA's Carcinogenic
Assessment Group for estimating excess lifetime cancer risks associated with
exposure to potentially carcinogenic chemicals. CPFs, which are expressed in
units of (milligrams per kilogram-day)-l {(mg/kg-day)-l}, are multiplied
by the estimated intake of a potential carcinogen, in mg/kg-day, to provide
an upper-bound estimate of the excess lifetime cancer risk associated with
exposure at that intake level. The term "upper bound" reflects the
conservative estimate of the risks calculated from the CPF. Use of this
approach makes underestimation of the actual cancer risk highly unlikely.
Cancer potency factors are derived from the results of human epidemiological
studies or chronic animal bioassays to which animal-to-human extrapolation
and uncertainity factors have been applied. CPFs for the Site contaminants
of concern are in Table 14.
Reference Dose (RfDS) have been developed by EPA for indicating the potential
for adverse health effects from exposure to chemicals exhibiting
noncarcinogenic effects. RfDs, which are expressed in units of mg/kg-day,
are estimates of lifetime daily exposure levels for humans, including
sensitive individuals. Estimated intakes of chemicals from environmental
media (e.g., the amount of a chemical ingested from contaminated drinking
water) can be compared to the RfD. RfDs are derived from human
epidemiological studies or animal studies to which uncertainity factors have
been applied (e.g., to account for the use of animal data effects on
humans). These uncertainity factors help ensure that the RfDs will not
underestimate the potential for adverse noncarcinogenic effects to occur.
RfDs for the Site contaminants of concern are in Table 15.
8.4 RISK CHARACTERIZATION
The risk characterization step of the baseline risk assessment process
integrates the toxicity and exposure assessments into quantitative and
qualitative expressions of risk. The output of this process is a
characterization of the site-related potential noncarcinogenic and
carcinogenic health effect..
Potential concern for noncarcinogenic effects of a single contaminant in a
single medium is expressed as the hazard quotient (HQ) (or the ratio of the
estimated intake derived from the contaminant concentration in a given medium
to the contaminant's reference dose.) By adding the HQs for all contaminants
within a medium or across all media to which a given population may
reasonably be exposed, the Hazard Index (HI) can be generated. The HI
provides a useful reference point for gauging the potential significance of
multiple contaminant exposures within a single medium or across media. The
HI information for the Site contaminants of concern is summarized below:
-------
TABLE 14
TOXICITY VAlUES: CARCINOGENIC EFFECTS
CHEMICAlS OF CONCERN
MEDLEY FARM SITE
Oral Slope Weight~f Evidence
ChenicaI Factor Classification Source
(m(JIkgldayr 1
1,1 -Dichloroethene 6.0E-1 C IRIS
1,1-Dic:hloroethane (8) C IRIS
1,1,1- Trichloroethane 0 IRIS
1,1,2-TrichloroethiUne 5.7E-2 C IRIS
1,1,2,2- T etraChloroethiUne 2.0E-1 C IRIS
1,2-Dichloroethane 9.1 E-2 82 IRIS
1,2-Dichloroethene (totaQ (b) IRIS
1,2-Dichloropropane 6.8E-2(a) 82 HEAST
Acetone 0 IRIS
8enzene 2.9E-2 A IRIS
2-8utanone 0 IRIS
Chloroform 6.1 E-3 82 IRIS
Chloromethane 1.3E-2 C HEAST
Ethylbenzene 0 IRIS
Methylene Chloride 7.5E-3 82 IRIS
Styrene 3.0E-2(a) 82 . HEAST
T etrachloroethene 5.1 E-2(a) 82 HEAST
Trichloroethene 1.1 E-2 82 HEAST
V~I Chloride 2.3E+O A HEAST
1,2,4- Trichiorobenzel'le 0 IRIS
Butylbenzylphthalate NO C IRIS
Di-n-butylphthalate 0 IRIS
Di-n-octylphthalate (b) IRIS
bis(2-Ethylhexyl)phthalate 1.4E-2 82 IRIS
-58-
-------
TABLE 14 (CONTINUED)
TOXICITY VALUES: CARCINOGENIC EFFECTS
CHEMICALS OF CONCERN
MEDLEY FARM SITE
Chemical
Oral Slope
Fador
(mgIk~dayr1
Weight~f Evidence
Classification
Source
Toxaphene
PCBs
1.1 E+O
7.7E+O
B2
B2
IRIS
IRIS
(a) - Evaluation under review by EPA CRAVE Workgroup
(b) - Not evaluated by EPA
ND - Not detennined
IRIS -Integrated Risk Infonnation System (U.S. EPA. 199Oc)
HEAST - Health Effects Assessment Summary Tables (U.S. EPA, 1990b)
-59-
-------
TABLE 15
TOXICITY VAlUES: NONCARCINOGENIC EFFECTS
CHEMICAlS OF CONCERN
MEDLEY FARM SITE
Chronic Uncertainty
Oral RfD Confidence Critical and Modifying
Chemical (R9'kglday) Level Effect Factors Source
1,1-Dlchloroethene 9E-3 Medium Liver effects UF.1000 for H,A,L IRIS
MF.1
1, 1-Dlchloroethane 1E-1 UFxMF .1000 HEAST
1,1,1- Trichloroethane 9E-2 Low 10 Medium Growth retardation UF.1000 for H,A,S IRIS
MF.1
1,1,2- Trichloroethane 4E-3 Medium Liver and UF.1000 for A,S IRIS
, Immunologic effects MF.1
en
0 1,1,2,2- (eI) IRIS
I Tetrachloroethane
1,2-Dlchloroethane (b) IRIS
1,2-Dlchloroethene 2E-2 Hematologic effects UFxMF.100 HEAST
1,2-Dlchloropropane (b) HEAST
Acetone 1E.1 Low Liver and kidney UF.1000 for A, S IRIS
effects MF.1
Benzene (eI) IRIS
2-Butanone SE.2 Medium Fetotoxlcity UF.1000 for A, S IRIS
MF.1
Chloroform 1E.2 Medium Liver and UF.1000 for H.A.L IRIS
reproductive effects MF.1
Chloromethane (b)
-------
TABLE 15 (CONTINUED)
TOXICllY VAlUES: NONCARCINOGENIC EFFECTS
CHEMICALS OF CONCERN
MEDLEY FARM SITE
Chemical
Chronic
Oral RfD
(ntPWday)
Confidence
Level
Critical
Effect
Uncertainly
and Modifying
Factors
Source
E'hylbenzene 1E-1 Low Liver and kidney UF-1000 for A, S IRIS
ellee.s MF-1
Methylene Chloride 8E-2 Medium Liver effects UF-100 for A IRIS
MF-1
Styrene 2E-1 Medium Hematologic and UF-1000 for A,S IRIS
liver effects
I T etraehloroethene 1E-2 Medium Hepatic effects UF.1000 forA,S IRIS
6. MF.1
~
I
Trlchloroethene (8) IRIS
Vinyl Chloride (b) IRIS
1,2,4- Trichlorobenzene 2E-2(e) liver effects UF x MF.1000 HEAST
Butylbenzylphthalate 2E-1 Low liver effects UF.1000 for A,S IRIS
MF.1
DI-n-butylphthalate 1E-1 Low Increased mortality UF.1000 for H, A, S IRIS
MF.1
Di-n-octylphthalate 2E-2 liver and kidney UF x MF.1000 HEAST
elleets
bis(2Ethylhexyl) 2E-2 Medium liver effects UF.1000 for IRIS
phthalate H,A,S,L
MF.1
-------
TABLE 15 (CONTINUED)
TOXICITY VAlUES: NONCARCINOGENIC EFFECTS
CHEMICAlS OF CONCERN
MEDLEY FARM SITE
. Chemical
Chronic
Oral RfD
(mglkWday)
Confidence
level
Critical
Effect
Uncertainly
and Modifying
Factors
Source
Toxaphene
PCBs
(b)
(b)
IRIS
IRIS
I
.-
110
I
(a) - Under review by EPA
(b) - Not evM.lated by EPA
(c)-Withdrawn from IRIS pending further review
Uncertainty Adjustments: H . variation In ~man sensitivity
A . animal to ~man extrapolation
S . extrapolation from subchronic to chronic NOAEl
l . extrapolation from lOAEl to NOAEl
IRIS - 'ntegrated Risk 'nformation System (U.S. EPA, 199Oc)
HEAST . Heatth Effects Assessment Summary Tables (U.S. EPA, 199Ob)
-------
-63-
Non-carcinoaenic Effects Under Current Conditions
Exposure Pathway
Hazard Ouotient
Soil Ingestion
Dermal Absorption
2.6 X 10-5
2.6 X 10-4
TOTAL EXPOSURE HAZARD INDEX
2.9 X 10-4
Non-carcinoaenic Effects Under A Future Residential Scenario
Exposure Pathway
Hazard Ouotient
Ingestion of Groundwater
Soil Ingestion
Dermal Absorption
5.6
1. 4 x 10- 3
4.0 X 10-3
TOTAL EXPOSURE HAZARD INDEX
5.6
Excess lifetime cancer risks are determined by multiplying the intake level
with the cancer potency factor. These risks are probabilities that are
generally expressed in scientific notation (e.g., 1 x 10-6 or 1E-6). As
excess lifetime cancer risk of 1 x 10-6 indicates that, as a plausible
upper bound, an individual has a one in one million chance of developing
cancer as a result of site-related exposure to a carcinogen over a 70-year
lifetime under the specific exposure conditions at a site. The excess cancer
risk levels associated with the site contaminants and exposure pathways are
summarized below.
The Agency considers individual excess cancer risk in the range of 10-4 to
10-6 as protective; however, the midpoint risk (10-6) is generally used
as the point of departure for setting cleanup goals at Superfund sites.
Carcinoaenic Effects Under Current Conditions
BXPOsure Pathway
Risk
Soil Inge8tion
Dermal Ab80rption of Soil
7 . 7 x 10-'
7 . 8 x 10- 7
TOTAL BXPOSURE RISK
8.6 X 10-7
-------
-64-
Carcinoaenic Effects Under A Future Residential Scenario
Exposure Pathway
Risk
Ingestion of Groundwater
Soil Ingestion
Dermal Absorption of Soil
1. 1 x 10- 2
4.2 X 10-'
1.1 x 10- 5
TOTAL EXPOSURE RISK
1. 1 X 10- 2
There is no current risk associated with the ingestion of groundwater under
baseline conditions since the groundwater plume containing site-related
chemicals is presently located within the property boundary and no exposure
points exist on the Site or at the property boundary.
The total estimated carcinogenic risk due to soil ingestion is 7.7 x 10-1.
For dermal absorption of chemicals in soil, the total carcinogenic health
risk is 7.8 x 10-7. These risks are mainly the result of the presence of
PCBs in the soil. All of these risk levels are within or less than the EPA
remediation goals of 10-4 to 10-6 risk levels. Therefore, the sum of
current risks under current, baseline conditions, due to the contamination at
the Site is 8.6 x 10-7 or a chance of 8.6 excess cancers in a population of
10,000,000 over a 70-year period.
If the hazard index exceeds unity there may be concern for potential adverse
health effects. None of the hazard indices for the three exposure pathways
exceeds unity. Adding the hazard indices for all the pathways to exposure to
Site-related chemicals yields a total hazard index of 2.9 x 10-4 which is
mainly the result of the presence of bis (2-ethylhexyl) phthalate. This sum
is approximately four orders of magnitude below unity, thus there in no
concern for potential non-carcinogenic health effects under present day Site
conditions.
For the future on-site residential use scenario, estimated carcinogenic risk
due to exposure to site-related chemicals is 1.1 x 10-2 for all pathways
combined as can be s_n below. Virtually all of the risk is from ingestion
of groundwater containing 1,1-dichloroethylene. The risk level from direct
contact with soil is 4.2 x 10-6 for soil ingestion and 1.2 x 10-5 for
dermal absorption of chemicals in soil, both of which are within the
remediation level goals of 10-4 to 10-6. These risk levels are mainly
the result of the presence of PCBs in the soils. The total non-carcinogenic
hazard for future residential use of the Site i. e.ttmated to be 5.6 which
exceeds unity. Ingestion of groundwater containing 1,1-dichloroethylene is
responsible for virtually all of the non-carcinogenic hazard. Hazard indices
for soil ingestion, 1.4 x 10-3, and dermal contact with soil, 4.0.x 10-3,
are both less than one, indicating that there is no concern for potential
health effects from direct contact with residual on-site soil contamination.
Virtually all of the HI for soils results from the presence of bis
(2-ethylhexyl) phthalate.
-------
1-
-65-
Although residual on-site soil contamination does not pose a direct threat to
either human health or the environment, this residual on-site soil
contamination does pose a indirect threat to human health as shown above by
an estimated carcinogenic risk of 1.1 x 10-2 and non-carcinogenic hazard of
5.6. This indirect risk will persist until such time as the mass of
contaminants in the unsaturated soil is reduced to a point where they will no
longer adversely impact groundwater quality above MCLs.
Uncertainity:
The estimates of human health risks developed in the baseline risks
assessment required a considerable number of assumptions about exposure and
adverse human health effects.
8.5 ENVIRONMENTAL RISKS
Exposure to groundwater and soils containing site-related chemicals are
potential sources of environmental endangerment. As stated previously,
exposure to groundwater at the Site is not a present pathway of concern
because the groundwater plume containing site-related chemicals is presently
confined to the Site and no exposure points exist. The potential for
endangerment of the flora and fauna of Jones Creek, the stream along the
eastern end of the property, could exist if groundwater containing
site-related chemicals entered this stream. However, no site-related
chemicals were detected in the stream water samples, the sediment samples, or
the monitoring wells closest to Jones Creek.
Because much of the Site has been covered with clean fill and is covered with
vegetation, exposure of terrestrial animals to s011 by dermal contact and
ingestion is considered unlikely. Ingestion of plants potentially containing
site-related chemical. i. minimized because of the clean fill covering much
of the Site. For species with large home ranges (e.g. deer), ingestion of
plants growing on the Site will represent only a portion of their diets, thus
further minimizing their intake of site-related chemicals. In summary, no
potential for significant risk to wildlife population on or adjacent to the
Site was identified. Furthermore, no endangered species or critical habitats
are known to occur in the vicinity of the Site.
9.0 DESCRIPTION OP ALTERNATIVES
Tables 16 and 17 summarize the technologies considered for remediating/
controlling groundwater and source contamination, respectively at the Medley
Parm site. These tables also provide the rationale as to why certain
technologies were not retained for further consideration after the initial
screening. Surface water/sediment remediation technologies were not
evaluated a8 this environmental medium has not been impacted by the Site nor
is it expected to be in the future. Although air is not a present exposure
pathway, it may pose a risk during the implementation of either the
groundwater treatment system or during the remediation of the soils. Any
potential impact on air will be considered along with the description of each
individual remedial alternative.
-------
TECHNOLOGY
GROUNDWATER RECOVERY
EXTRACTION WELLS
SUBSURFACE DRAINS!
INTERCEPTION TRENCHES
ACLs
NO ACTION
I
..
- GROUNDWATER TREATMENT
I
TABLE 16
GROUND WATER CONTROL
TECHNOLOGY SUMMARY
STATUS
RETAINED
REJECTED
REJECTED
RETAINED
ACTIVATED CARBON ADSORPTION
CHEMICAL OXIDATION
BIOLOGICAl SYSTEM
AIR STRIPPING
LAND APPLICATION
GROUNDWATER DISCHARGE
RETAINED
RETAINED
REJECTED
RETAINED
REJECTED
SURFACE WATER (JONES CREEK)
GAFFNEY POTW
INFILTRATION GALLERY
INJECTION WELL
RETAINED
REJECTED
-RETAINED
RETAINED
REASON
CANNOT BE INSTALLED AT DEPTH IN BEDROCK
SITE CONDITIONS NOT APPROPRIATE
CHLORINATED VOCS RESISTANT TO BIODEGRADATION
RESISTANT COMPOUNDS, SEASONAL USE
DISTANCE TO SERVICE
PROVISIONALLY DEPENDING ON APPLICATION RATES
PROVISIONALLY DEPENDING ON APPLICATION RATES
-------
TABLE 17
SOURCE CONTROL
TECHNOLOGY SUMMARY
TECHNOLOGY
STATUS
REASON
DIRECT TREATMENT BIOREACTOR REJECTED EXCAVATION OF SITE TO REQUIRED
LAND TREATMENT REJECTED DEPTH IS CONSIDERED INFEASIBLE
SOIL WASHING REJECTED
CEMENT-BASED STABILIZATION REJECTED
SILICATE.BASED STABILIZATION REJECTED
PROPRIETARY CHEMICAl FIXATION REJECTED
LOW-TEMPERATURE DESORPTION REJECTED
, ROTARY KILNS REJECTED
- INFRARED THERMAL TREATMENT REJECTED
-.J FLUIDIZED BED INCINERATION REJECTED
.
IN-SITU TREATMENT ENHANCED BIODEGREDATION REJECTED PERMEABILITY, DEPTH OF SOILS
SOIL FLUSHING REJECTED FAILED EPA FIELD TEST, SOIL PERMEABILITY
SOIL VAPOR EXTRACTION RETAINED
VITRIFICATION REJECTED NOT SUFFICIENTLY DEMONSTRATED
OFF-SITE TMT/DISP COMMERCIAL LANDFILLING REJECTED EXCAVATION OF SITE TO REQUIRED
COMMERCIAL INCINERATION REJECTED DEPTH IS CONSIDERED INFEASIBLE
CONTAINMENT CAPPING RETAINED
SLURRY WALLS REJECTED FRACTURED BEDROCK PREVENTS EFFECTIVE USE
GROUTING REJECTED CANNOT BE EFFECTIVELY APPLIED
SHEET PILING REJECTED NOT APPLICABLE TO ROCKY SOILS. DEPTHS
BOTTOM SEALING REJECTED NOT FULLY DEVELOPED
NO ACTION RETAINED
-------
-68-
9.1
REMEDIAL ALTERNATIVES TO ADDRESS GROUNDWATER CONTAMINATION
Four sets of alternatives were developed to address groundwater contamination
at the Site. The four groundwater control (GWC) remedial alternatives are:
GWC-l:
GWC-2:
GWC-3 :
GWC-4:
No Action
Long-Term Monitoring and Institutional Control
Recovery and Treatment of Groundwater Across Entire
Recovery and Treatment of Groundwater at the Medley
Line.
Site
Farm Property
Both Alternatives GWC-3 and GWC-4 have a subset of corresponding treatment
approaches for the extracted groundwater. These alternatives and their
associated treatments are described below.
9.1.1
GWC-1:
No Action
The No Action alternative is included, as required by CERCLA and the NCP, to
serve as a baseline for comparison with other groundwater control measures.
This alternative would not involve any treatment or other remedial actions.
The description of this alternative is included in the following section.
9.1.2
GWC-2:
Lona-Term Monitorina and Deed Restriction
This alternative is identical to GWC-l but includes long-term monitoring of
Site groundwater and the placement of a deed restriction to reduce the
potential for the construction of potable wells on the property.
In Alternatives GWC-1 and GWC-2, Site conditions would remain unchanged.
Slight remediation of contaminated groundwater may occur through natural
processes such as bioremediation, adsorption, and dilution. Therefore,
levels of groundwater contamination would remain above MCLs for a minimum of
20 years.
Implementation of Alternative GWC-1 could begin immediately and would have no
negative impacts of future remedial actions. Operating costs would be
incurred because of the mandatory review every five years. Implementation of
Alternative GWC-2 may be delayed approximately one month as this approach may
include the installation of additional monitoring wells. In addition, under
GWC-2, a deed restriction would be placed on the property in an attempt to
limit the future use of the groundwater. Capital costs for GWC-2 would be
incurred for monitoring well construction, operating costs would include
periodic groundwater sampling, chemical analysis, and reviewing and
documenting Site conditions every five years; maintenance costs would be
incu7red for inspection of the monitoring wells.
Estimated Period of Operation:
30 years
Estimated Total COst (net present worth):
Alternative GWC-l $140,000
Alternative GWC-2 $790,000.
-------
-69-
9.1.3
GWC-3:
Recoverv of Groundwater Across Entire Site
This alternative considers the entire Site as the point of compliance;
therefore, under this alternative all groundwater exceeding MCLs at the
will be recovered through a system of extraction wells. The Site is
delineated by the extent of contamination in the groundwater.
Site
The treatment system for the extracted groundwater would involve installing
piping from each extraction well to a common treatment area, a specific
treatment system, and discharging the treated groundwater. The estimated
hydraulic flow for Option GWC-3 is 30 gallons per minute (gpm). Below are
descriptions of three treatment options evaluated for treating the extracted
groundwater for Option GWC-3. Figure 22 provides the tentative locations for
the extraction wells, identified by circles with a dot in their middle, for
this alternative.
Of the four (4) discharge options retained after the initial screening
discharging to Jones Creek via an NPDES discharge permit is the preferred
discharge option (refer to Table 16). Discharging to the local publicly
owned treatment works (POTW) was rejected due to the distance to the nearest
hook up point. Both infiltration galleries and injection wells are
technically feasible, but their usefulness is dependent on application rates
of the discharge effluent. Therefore, all of the groundwater remediation
alternatives discussed below will discharge treated groundwater is to Jones
Creek via an NPDES permit.
9.1.3.1
GWC-3A: Recoverv and Treatment of Groundwater Across Entire Site
Usina an Air Strippina Tower
Air stripping is a mass transfer procesB in which volatile compounds in a
water column are transferred to an air stream within a packed tower. The air
stripping tower will remove the volatile compounds to below quantation
limits. The maximum air emission rate for VOCs would be approximately 44
pounds per month. South Carolina Air Pollution Control Regulation (No. 62.1,
Section II, F.2g) states that VOC sources of less than 1,000 pounds per month
may not require permits but that source information must be supplied to the
Department. SCDHBC policy .tates that any source of air toxics must be
reviewed for potential impact to receptors. To satisfy South Carolina
requirements, calculated airborne concentrations at the stack were compared
with allowable State ambient concentration level. Air Pollution Control
Regulation (No. 62.5, Standard No.8, Toxic Air Pollutant.). The results of
an air dispersion model conducted to estimate the airborne concentrations at
the property line found that the contaminant levels would be below allowable
State levels by a factor of more than 1,000. Maximum air stripper emissions
from the Medley Farm site would therefore be protective of human health and
would not require control.
Estimated Period of Operation:
30 years
Estimated Total Cost (net present worth):
$1,900,000.
-------
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- . - - - . - - . - '$' - ~
,
103
<9
Alternative GWC-3 Anticipated
Arrangement of Extraction well.
I="IGURE 22
POTENTIAL GROUNDWATER
RECOVERY SCHEMES
MEDLEY FARM SITE
.
Alternative GWC-4 Anticipated
Arrangement of Extraction wells
-:~ F"IL£' NO zr... .'11.;' OOiH'{I"JP£':2 '~_I
-70-
-------
-71-
9.1.3.2
GWC-3B: Recovery and Treatment of Groundwater Across Entire Site
Usina Activated Carbon
In the carbon adsorption system, the contaminated groundwater is forced
through tanks containing activated carbon. Activated carbon is
specially-treated material that naturally attracts the molecules of
contaminating chemicals. As the groundwater moves through the filters, the
contaminants cling to the carbon and the groundwater is cleansed as it leaves
the system. The cost of replacing or reactivating the activated carbon 90
that it retains its effectiveness makes this option more costly to implement
than GWC-3A.
Estimated Period of Operation:
30 years
Estimated Total Cost (net present worth):
$2,500,000.
9.1.3.3
GWC-3C: Recovery and Treatment of Groundwater Across Entire Site
Usina Chemical Oxidation
Chemical oxidation is a process by which organic compounds, such as VOCs and
SVOCs, are broken down into carbon dioxide and water. Oxidation can be
achieved through a range of technologies.
Estimated Period of Operation:
30 years
Estimated Total Cost (net present worth):
$2,500,000.
9.1.4
GWC-4: Recovery and Treatment of Groundwater at the Medlev Farm
Propertv Line
This alternative is designed to address groundwater contamination at the
property line of the Medley Farm and not beneath the entire Site. using the
same range of treatment for extracted groundwater a8 described above in
Section 9.1.3, this alternative focuses on removing groundwater from the
perimeter of the property. The anticipated flow rate for this alternative is
15 gpm. The point of compliance for thi8 alternative is the Medley Farm
property line. Therefore, this alternative would insure that levels of
contaminant8 in the groundwater would not exceed MCLs at the property line of
the Medley Farm as presently owned by Mr. Ralph Medley. This alternative
would allow contaminants to remain above MCLs in the groundwater beneath and
just downqradient of the disposal area. The extraction wells represented by
solid circles in Figure 22 correspond to Alternative GWC-4.
This alternative is protective under present day conditions as there are no
receptors using the contaminated groundwater. However, this alternative
would not be protective of future use of the aquifer in the event that a
residence is built in the vicinity of the Site and the owner of such
residence installs a potable well near or downgradient of the Site. The cost
estimate for each of the treatment schemes discussed as part of Alternative
GWC-4 are stated below:
-------
-72-
Estimated Period of Operation:
30 years
Estimated Total Cost (net present worth):
GWC-4A (Air Stripping) $1,300,000
GWC-4B (Carbon Adsorption): $1,900,000
GWC-4C (Chemical Oxidation): $1,800,000.
9.2
REMEDIAL ALTERNATIVES TO ADDRESS SOURCE CONTROL
The following remedial action alternatives address contaminant source areas
that are (1) currently accessible to the public, (2) may become accessible
during the remedial action, or (3) act as a continuing source of
contamination to groundwater at the Medley Farm site. These source areas
must be remediated to the extent necessary to reduce the risks attendant to
exposure to chemical residuals, or they must be isolated to prevent
exposure. The four response actions to address source control (SC) at the
Medley Farm Site are:
SC-l:
SC-2:
SC-3:
SC-4:
No Action
Institutional COntrols
Cap Source Areas
Soil Vapor Extraction
Below are descriptions of each of the source control/remediation
alternatives.
9.2.1
SC-1
No Action
In the No Action alternative, no further remedial action would occur. A
slight reduction in the levels of the contaminants present may occur through
natural processes; and short-term effectiveness presents no additional risks
to the community or the environment. This alternative would not
significantly reduce the toxicity, mobility, or volume of contaminants at the
Site. Long-term effectiveness and permanence of this alternative would be
reviewed every five year. as required by Section 121(c) of CERCLA. Site
soils would not change significantly over time and would likely continue to
contribute chemicals to the groundwater above MCLs for up to 20 years.
The Baseline Risk A8s..sment under current conditions indicates that this
alternative would be protective of human health and the environment. The
current risk posed by Site under today'. conditions i8 8.6 x 10-7. The
Toxic Substances COntrol Act (TSCA) establi.hes remediation levels for PCBs
in areas of unrestricted acc.s., and the levels of PCBs encountered at the
Site are below the action level of 10 ppm.
However, under the future use scenario, the Site would pose a significant
risk. The risk, 1.1 x 10-2, is mainly the result of using the contaminated
aquifer beneath the Site for potable water. As in the risk assessment for
current conditions, soils, under the future use scenario, do not pose a
significant risk to human health.
-------
-73-
The No Action alternative could be readily implemented, and would not hinder
any future remedial actions. There are no construction costs associated with
this alternative. However, operation and maintenance (O&K) costs would
involve review of the remedy every five years.
Estimated Period of Operation:
30 years
Total Construction Costs:
Estimated Present Worth O&K Costs:
Estimated Total Costs (net present worth):
$0
5140.000
$140,000
9.2.2
SC-2:
Institutional Controls
Alternative SC-2 is similar to Alternative SC-l but includes the additional
requirement of initiating institutional controls. Under this alternative,
deed restrictions would be placed on the Medley property in an attempt to
control future use of the property and prevent inadvertent exposure to
chemical residuals.
Estimated Period of Operation:
30 years
Total Construction Costs:
Estimated Present Worth O&K Costs:
Estimated Total Costs (net present worth):
$0
5140.000
$140,000
9.2.3
SC-3:
Ca~ Source Areas
This alternative involve8 construction and operation of a low permeability
cap over Site soi18. Capping is the covering of contaminated wastes or
soils. In this approach, a layer of compacted soil would be used to cover
the area; this layer would be covered with an impermeable synthetic liner to
prevent wind, rain, and melting snow from carrying contaminants beyond their
primary location. This approach would also prevent direct human and animal
contact with contaminants. The finished cap would be covered with soil and
seeded for erosion control and to make it blend into the landscape.
Maintenance is minimal, requiring periodic inspections and the filling of
cracks or depressions, if they appear.
Construction of a cap would involve heavy earth moving and grading equipment
and the clearing of vegetation. Existing Site access would probably have to
be improved. DU8t control mea8ures would be taken to minimize short term
potential release of airborne particulates. In the implementation of this
option, groundwater observation wells not required for long-term monitoring
would be abandoned. Drainage swells and a security fence would be
constructed along the cap perimeter. Deed restrictions would be included in
the implementation of thi8 alternative in an attempt to control future use of
the Site.
-------
-74-
There are no ARARs for capping at the Site, and Resource Conservation and
Recovery Act (RCRA) disposal requirements are not applicable~ however, the
single synthetic liner cap design would meet an equivalent standard of
performance to RCRA requirements.
Long-term effectiveness and permanence of this approach would rely on regular
inspections to ensure the reliability of the cap~ an inspection and
maintenance schedule would be implemented following construction and continue
as long as chemical residuals remained at the Site. Evaluation of cap
effectiveness would be performed through periodic groundwater monitoring. If
deemed necessary during the design phase, gas vents will be incorporated into
the cap. Because residuals would remain at the Site, CERCLA Section 121(c)
requires a review of effectiveness and protectiveness be made every five
years.
Implementation of this alternative would not offer any reduction in toxicity
or volume of chemicals at the Site. Use of an impermeable layer to limit the
exposure of contaminants would help control migration if this alternative
were employed in conjunction with one of the groundwater control options.
Operating cost would be incurred to maintain the cap and to" develop reports
and reviews of the Site remedy every five years. Biannual sampling would be
conducted under this alternative.
Estimated Period of Operation:
30 years
Estimated Total Construction Costs:
Estimated Present Worth O&H Costs:
Estimated Total Cost (net present worth):
$580,000
5420.000
$1,000,000
9.2.4
SC-4:
Soil Vaoor Extraction
Source areas with chemical levels exceeding calculated levels that are
protective of the groundwater would be remediated through soil vapor
extraction (SVE). The.e calculated subsurface soil levels are based on a
compound's potential to impact groundwater above promulgated standards. A
leach model incorporating site-specific physical properties and environmental
fate considerations were used. The factors used were: annual infiltration~
chemical retardation~ fate mechanisms volatilization, biodegradation,
hydrolysis, soil type and properties; and groundwater flow.
Figure 23 identifies the area. of the Site where level. of residual .oil
contamination exceed the calculated concentrations that would be protective
of the underlying aquifer. These concentrations are based on a leaching
model which would protect the groundwater from being impacted above KCLs.
The model takes the following parameters into consideration: infiltration,
equilibrium, chemical partitioning, groundwater ARARs, and mixing of
infiltration with groundwater. The calculated concentrations of volatile
organics in the unsaturated subsurface soils that will be protective of Site
gr~undwater to KCLs are presented in Table 18. This table also lists the
locations where these soil remediation levels were exceeded.
-------
\TP 2
, SB 5.
WELt) «
) SW 4
"^
SB 8 \\
FIGURE 23
APPROXIMATE EXTENT O
SOURCE AREAS EXCEEDING
CALCULATED SOIL REMEDIATIO
LEVELS
MEDl EY FARM SITE
EXCEEDS SUBSURFACE LEVELS FOR VOCS
-------
,-
TA8LE 18
POTENTIAL VOLATILE ORGANIC SOIL REMEDIATION LEVELS
MEDLEY FARM SITE
Comcound
Soil Remediation
Level
(ua/kc)
Locations
Where Remediation
Level Exceeded
Acetone
1,1-Dichloroethane
1,2-Dichloroethane
1,1-Dichloroethene
1,2-Dichloroethene (total)
1,1,1- Trichloroethane
1,1,2-Trichloroethane
Trichloroethene
Tetrachloroethene
Chloroform
Methylene chloride
12,000
100
60
270
2,100
26,000
160
500
1,600
3,000
40
(582)
None
TP12, 584, (587), SS9
None
TP3
None
None
TP3, TP4
TP3, TP4
None
TP4, (583)
NOTE: Locations given in parentheses are considered a minimal risk to ~round water
based on site-specific conditions.
-76-
-------
-77-
SVE typically includes a series of slotted vertical injection vents connected
by a common manifold to an extraction pump or blower. Volatile compounds and
some SVOC's are withdrawn through an induced pressure gradient in the
subsurface. Air emissions from the SVE system may require treatment, such as
being scrubbed or sent through an activated carbon filter, prior to being
vented to the atmosphere. The need for an emission control would be
determined during the design. Upon completion of SVE activities, there would
no longer be a significant source of chemicals to impact groundwater quality
above the identified ARARs. The costs below anticipate that an air emission
control system will be required.
Estimated Period of Operation:
1 year
Estimated Total Construction Costs:
Estimated Present Worth O&M Costs:
Estimated Total Cost (net present worth):
$260,000
S360,000
$620,000
9.3
APPLICABLE OR RELEVANT AND APPROPRIATE REOUIREMENTS (ARARs)
The environmental setting and the extent and characteristics of the
contamination at the Hedley Farm Site were defined in Section 7.0. Section
8.0 highlights the primary environmental media of and the human health and
environmental risks posed by the Hedley Parm site. Table 11 lists the
contaminants of concern present in the groundwater and soils at the Site.
This Section examines the cleanup criteria (ARARs) associated with the
contaminants found on-site and the environmental media contaminated.
9.3.1
Action-Soecific ARARs
Action-specific requirements set controls/restrictions on the design,
performance, and other aspects for implementing a specific remedial
activity. Since action-specific ARARs apply to discrete remedial activities,
they are discussed in greater detail in Section 10.0. The three categories
for action-specific ARARs are:
. ARARs
. ARARs
. ARARs
for actions taken in all alternatives;
for an action involving soil treatment; and
for an action involving groundwater treatment.
The first category specifies requirements for safety and health, hazardous
waste facilities, and transportation. The second category covers soil vapor
extraction, capping, and related air emissions. The last category applies to
the extraction and treatment of groundwater, the discharge of the treated
groundwater, and related air emissions.
-------
-78-
9.3.2
Chemical-Scecific ARARs
Chemical-specific ARARs are concentration limits established by government
agencies for a number of contaminants in the environment. Chemical-specific
ARARs can also be derived in the Risk Assessment. Discussed below is each
environmental medium investigated at the Medley Farm site as part of the RI
and the associated chemcial-specific ARARs.
9.3.2.1
Groundwater
Groundwater at the Medley Farm site is designated as Class GB in accordance
with the South Carolina water classification system and Class IIA under USEPA
Groundwater Classification Guidelines (December 1986). The Class GB
classification means that all groundwater meeting the definition of
underground sources of drinking water meet quality standards set forth in the
State Primary Drinking Water Regulation (R.61-58.5). EPA classifies the
groundwater as Class IIA since the aquifer was and is being used as a source
of drinking water. Therefore, the groundwater needs to be remediated to a
level protective of public health and the environment as specified in Federal
and State regulations governing the quality and use of drinking water.
The Safe Drinking Water Act and the State Primary Water Regulations establish
MCLs and non-zero maximum contaminant level goals (HCLGs) for numerous
organic and inorganic constituents. The Cleanup Criteria shown in Table 19
were established based on MCLs, proposed HCLs and HCLGs. Where HCLs were not
available, risk based numbers were calculated as indicated by the appropriate
table footnotes.
9.3.2.2
Surface soils
The baseline risk assessment considered both present day conditions as well
as a future risk scenario involving the construction of a residence on th~
Site at some time in the future. Under both scenarios, it was determined
that the cumulative chemical concentrations of surficial soils at the Site do
not pose a significant risk to human health; therefore, concentrations of
individual chemicals would not present significant risks. consequently,
specific remediation levels for surficial soils were not developed.
The only contaminant detected in surface 80il samples at the Site for which
there is a promulgated Pederal or State standard is PCB8. The promulgated
standard of 10 milligrams/kilogram (mg/kg) for PCBs in area. of unrestricted
access is specified in the TSCA (40 C.P.R. 761.125). Concentrations of PCBs
detected in surface soil samples were all below 10 mg/kg. PCB levels at the
Site are therefore in compliance with this ARAR.
-------
'-
~I
~~~~
%1 Compound
I Acetooo
1~7 Benzene
~ ..:.'
2-Butanone
F.
II Chloromethane
~ Chloroform
[I
~* l,l-Dichloroethane
I
~ 1,2-Dichloroethane
" 1,1-Dichloroethene
1,2-Dichloroethene
Methylene Chloride
Tetrachloroethene
. ..'" .:....(,:~;~
Remediation ~m
(~:;~~ Source II
'::~;:;:;:;
?<:::$:~
(1) It
MCL it-ii
(1) I
( 2 ) ~!:!:m
~~~~~~~
MCL ~:::~:::::
::::::::::::
(3) i:ii
MCL 1]1
#1
x@
MCL b:~
;1
~
ij~
MCL >~¥.~
::::':«0:
MCL II
pMCL lfui~
MCL II
:*=*
i~:~
m~
::~<~
tJ
II
I
iI
Jii
I.:>.'~
~... :
t-:
~:::.:
.:..:..~..,-:;o;.:..:-: ,.,',',
Maximum
Concentration
(ug/L)
Well
18
BW2 350
BW105 5
BW106 2000
BW108 63
BW2 100
SW4 350
BW2 5
SW4 7
SW4 cis: 70
trans: 100-
BW2 5
SW3 5
SW4 200
BW4 5
BW2 5
11
13
26
10
120
290
2200
31
110
200
1,1,2-Trichloroethane
1,1,1-Trichloroethane 3400
18
Trichloroethene
720
MCL Safe Drinking Water Act Maximum Contaminant Level (40 cn Parts
141.61)
Remediation level derived from BPA's Reference Dose (RfD).
Remediation level represents a one in one hundred thousand excess
cancer risk, chloromethane is a Class C carcinogen
Remediation level derived from BPA's Reference Dose (RfD) with an
additional 10-fold safety factor. l,l-dichloroethane is a Class
C carcinogen.
- Proposed Maximum Contaminant Level (55 PR 30370)
-79-
-------
1-
-80-
9.3.2.3
Subsurface Soils
As specified in the Administrative Record, the levels of contaminants in the
unsaturated subsurface soils will continue to adversely impact groundwater
quality for an estimated 20 years. Therefore, the remediation levels for
contaminants found in the unsaturated soils were calculated. These
remediation levels would protect the groundwater from being impacted above
MCLs. These calculations were based on a leaching model. The remediation
goals for volatile organics in the unsaturated subsurface soils which would
be protective of Site groundwater to MCLs are presented in Table 18.
9.3.2.4
Surface Waters
The RI determined that Jones Creek has not been impacted by any site-related
chemicals. Therefore surface waters are not in violation of the Federal
Ambient Water Quality Criteria (AWQC; EPA, 1986). This ARAR protects aquatic
organisms.
Any discharge from a groundwater extraction and treatment system will be
discharged to Jones Creek via a NPDES discharge permit.
9.3.2.5
Sediments
There are no promulgated Federal or State quality standards for sediments.
No site-related chemicals were detected in sediment samples collected from
Jones Creek during the RI. Accordingly, sediment quality criteria are not
necessary.
9.3.3
Location-Specific ARARs
Location-specific ARARs consider Federal, State, and local requirements that
reflect the physiognomical and environmental characteristics of the Site or
the immediate area. Table 20 lists the location-specific ARARs that apply at
the Medley Farm Site.
10.0
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
Table 21 li.t. the remedial alternative. that were con.idered in the detailed
analysis of alternatives. Thi. section summarizes the evaluation of these
remedial alternatives as specified in the NCP.
10.1
THRESHOLD CRITERIA
An alternative must overall, be protective both of human health and the
environment and comply with ARARa, unless waived, in order to be eligible for
selection. If an alternative fails to protect human health or the
-------
TABLE 20
POTENTIAL lOCATION - SPECIFIC ARARs
MEDLEY FARM SITE
SITE FEA TUREA-OCATION
CITATION
REQUIREMENT SYNOPSIS
CONSIDERATION IN THIS FS
FEDERAL
Within 61 meters (200 feet) 01 a fault 40 CFR 264.18(a) New treatment, storage, or Not an ARAR since She Is not
displaced In Honocene time disposal 01 hazardous waste within 200 leet of a faull
prohibited: applies to RCRA displaced in Honocone time.
hazardous waste; treatment,
slorage, or disposal.
Whhin 100-year llood plain 40 CFR 264.18(b) Facility must be designed, Not an ARAR since Site is not in
constructed, operated, and a 1 OO-year flood plain.
I maintained to avoid washout;
CD applies to RCRA hazardous
.... waste; treatment, stored, or
disposal.
Within flood plain Protection of floodplains Action to avoid adverse effects, Not an ARAR since Site 15 not In
(40 CFR 6, Appendix A); minimize potentiat harm, restore a flood plain.
Fish and Wildlife and preserve natural and
Coordination Act (16 USC beneficiat vatutJs; applies to
661 mag.); 40 CFR aellon that will occur in a flood
6.302; Flood plains plain, I.e., lowlands, and
Executive Order (EO relatively flat areas adjoining
11988) Inland and coastal waters and
other flood prone areas.
Within area where action may cause National Historical Requires that action be taken to Not an ARAR since Site Is not a
I"eparable hann, loss Preservation Act (16 USC recover and preserve artifacts designated archaeological area.
or destruction o. significant artifacts Section 469); 36 CFR Part when alteration of te"ain
65 threatens significant scientific,
prehistorical, historical, or
archaeological data.
-------
TABLE 20 (CONTINUED)
POTENTIAL LOCATION - SPECIFIC ARARs
SITE FEATUREIlOCATION CITATION REQUIREMENT SYNOPSIS CONSIDERATION IN rnls FS
Critical habitat upon which Endangered Species Act " endangered or threatened Not an ARAR since Site does
endangered species or threatened ot 1973 (16 USC 1531 m species are present, action must not have endangered or
species depends ~.); 50 CFR Part 200, 50 be taken to conserve '''(~alened species.
CFR Part 402; Fish and endangered or threatened
Wildlile Coordinalion Act species, including consultation
(16 USC 661 m~.); 33 with the Department 01 Interior.
CFR Parts 320-330
Wetlands Clean Water Act Section For wetlands as defined by U.S. Not an ARAR since Site Is not In
404; 40 CFR Part 230, 33 Army Corps 01 Engineers a wetlands are and no bodies 01
CFR Parts 320-330 r~gulalions, mtJ!'t take action to water or wetlands are to be
prohibit discharge 01 dredged or modified.
IiII malerial into wetlands without
I permit.
-
N 40 CFR Part 6, Appendix A For action involving construction Not an ARAR since Site Is not In
, 01 facilities or management 01 a wetlands area.
property in wetlands (as defined
l.Jy 40 ~FR Part 6, Appendix A,
section 4(j»), action must be
taken to avoid adverse effects.
minimize potential harm. and
preserve and enhance
wetlands. to the extent possible.
Wilderness area Wildemess Act (16 use For Federally-owned area Not an ARAR since Site Is not In
1131 mseg.); 50 CFR 35.1 designated as wilderness area, a wilderness area.
m~. the area fJlJst be administered in
such manner as will leave .
unimpared as wilderness and to
preserve its wildemess.
Within area affecting national wild, Wild and Scenic Rivers Act For activities that affect or may Not an ARAR since Site Is not on
scenic. or recrealional river (16 USC 1271 m ~.); allect any o' the rivers specified or near a scenic river.
section 7 (a)); 40 CFR in section 1271(a), must avoid
6.302(e) laking or assisting in action that
will have direct adverse ellecl on
scenic river.
-------
SITE FEATUREILOCATION
Classification and potential use 0' an
aquifer
I
OD
w
I
Wdhln 100-year flood plain
Wetlands
TABLE 20 (CONTINUED)
POTENTIAL lOCATION - SPECIFIC ARARs
CITATION
. Guidelines for Ground
Water Classillcation, EPA
Ground Water Protection
Strategy. (USEPA, 1984;
USEPA, 1986)
S.C. R.61.264.18 (b)
S.C. Pollution Controt Act
REQUIREMENT SYNOPSIS
Consider Federal and State
aquifer classifications In the
assessment of remedial
response objectives.
STATE
Facility located within a 100-year
flood plain must be designed.
constructed, and maintained to
pennit washout of any waste
materials.
Facility must not be located In a
wetland.
CONSIDERATION IN THIS FS
TBC since drinking water wells
have been Installed and used In
the vicinity of the Site.
Note that this Is not an ARAR but
Is USEPA policy and therefore
lalls Into the category 01 other
criteria or guidelines to be
considered (TBC).
Not an ARAR since Sne Is not In
a 1 OO-year tlood plain.
Not an ARAR since Sne Is not In
a wetlands area.
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environment, or does not comply with ARARs, then. this alternative cannot be
selected. Below is a discussion of the screened alternatives in comparison
with the threshold criteria.
~
f.~~~-'
II GROUNDWATER CONTROL
Wffi.
or:
'~
TABLE 21
RETAINED ALTERNATIVES FOR DETAILED ANALYSIS
. ~~,~}}W.~%.i~~::m.'(.w.~::~~~
" """""". . -:.,....~;. ,,''', .;X' . t.. ... ~~*W~:.i~'E
No :::PnON . . . '" . -'I
Institutional Controls/Long-term monitorinqj@
MCLs across the Site Wt
MCLs at the property line r.t.M
::::::~:~:
m~
.1
Ii
~;~~
. ..;::::~
Wf~
.ource are.. Ii
. '. . ~ x < '. ~ ..,:~ 7~~::~:~~t1Ji~*
""':~::::::*
;t;::::~-;
III
~~::::~~
~ .ir.' ..$:':-'::
GWC-1
GWC-2
GWC-3
GWC-4
SOURCE CONTROL
DESCRIPTION
SC-1
SC-2
SC-3
SC-4
No action
Institutional Controls
Cap source areas
Soil vapor extraction of
10.1.1
Overall Protection of Human Health and the Environment
This criterion assesses the alternatives to determine whether they can
adequately protect human health and the environment from unacceptable risks
posed by the Site. Thi. asseesment considers both the short-term and
long-term t~e frames.
Alternative GWC-1 would be protective of human health and the environment
under present conditions ae there are no current receptors. However, this
alternative would not be protective of human health in the event ~hat the
Medley Farm property wa. developed into a residential area in the future.
Under this scenario, it i. assumed that any such residents would install
potable welle. As can be seen in Tablee 9 and 10, a number of contaminants
in the groundwater are above MCLs.
Alternative GWC-2 ie an extent ion of Alternative GWC-1 but this alternative
involves the use of institutional controls, such as deed restrictions, in an
attempt to reduce the potential for the installation of a potable well on the
Site in the future. The remainder of the evaluation for Alternative GWC-2
under this criterion would be the same as for Alternative GWC-1.
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Alternative GWC-3 would remediate all groundwater at the site to KCLs which
would be protective of human health in the future while Alternative GWC-4 was
designed to achieve KCLs at the Kedley Farm property line. Under present
conditions, these alternatives would be protective since there are no
receptors. However, under a future residential use scenario, GWC-4 would not
be protective of human health and GWC-3 would be protective of human health.
As documented in the Baseline Risk Assessment, Site soils do not represent a
significant risk to human health. Risks from soils to populations of either
flora or fauna could not be quantified but are limited because most of the
surface soil is clean fill which effectively reduces exposure via direct
contact to the residual contaminants in the unsaturated, subsurface soils at
the Site. Exposure of fauna populations is further reduced as animals do not
feed exclusively at the Site. Source control alteratives SC-l, no action,
and SC-2, institutional controls, would be protective of human health and
the environment.
Alternative SC-3, placing a cap over the Site, would significantly reduce the
leaching of residual contaminants from the unsaturated soils into groundwater
via infiltration of precipitation. This Alternative would limit the future
risks posed by soils to groundwater. The reduced leaching potential would
translate into lower chemical loadings into groundwater, hence lower risks to
potential downgradient receptors. The limited risk identified in the Risk
Assessment as vegetative uptake of contaminants would be eliminated by
Alternative SC-3 by removing existing vegetation and capping the major source
areas.
Even though Site soils do not pose a significant risk to either human health
or the environment, the FS did determine that residual VOCs will continue to
impact groundwater above KCLs for a minimum of 10 years and potentially up to
20 years. Alternative SC-4 requires the installation and implementation of a
soil vapor extraction (SVE) system. The SVE system would be operated until
remaining levels of contaminants in the soils would no longer impact the
groundwater above KCLs. Operation of the SVE system would satisfy South
Carolina ambient air requirements. Therefore, this alternative would be
protective of human health and the environment.
10.1. 2
Comoliance with ADDlicable or Relevant and Aoorooriate Reauirements
(ARARs)
This criterion assesses the alternatives to determine whether they attain
applicable or relevant and appropriate requirements (ARARs) under federal
environmental laws and state environmental or facility siting laws, or
provide justification for waiving an ARAR. Section 9.3 defines the three
types of ARARs: Action-Specific, Chemcial-Specific, and Location-Specific.
The Site specific ARARs are identified below.
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10.1.2.1
Action-Specific ARARs
The off-site discharge of treated groundwater to Jones Creek via a NPDES
permit must comply with the Clean Water Act (CWA), Section 402. As the
discharge will be a point source, the following sections of CWA will also
apply: 301, 304, 306, 307, 308, and 403. The NPDES program is implemented
under 40 CFR 122-125.
The required treatment for extracted groundwater in Alternatives GWC-3 and
GWC-4 is air stripping. ARARs for air stripping include: the Clean Air Act
(CAA), Section 109, National Ambient Air Quality Standards (NAAQS) (40 CFR
50); Resource Conservation and Recovery Act (RCRA) (40 CFR 264.251(f), 40 CFR
264 & 265 Subparts Y, Z, AA, & BB); and South Carolina Air Pollution Control
Regulations No. 62.1, Section II, F.2.g and No. 62.5, Standard No 8. Toxic
Air Pollutants.
10.1. 2.2
Chemical-Specific ARARs
Groundwater cleanup standards for this Site are set at the most stringent of
the following ARARs or To-Be-Considered guidelines (TBCs) since the aquifer.
has been and is continuing to be used as a source of drinking water: the RCRA
Maximum Concentration Limits (MCLs); the Safe Drinking Water Act (SDWA)
Maximum Contaminant Levels (MCLs), which include RCRA MCLs; the SDWA MCL
Goals (MCLGs); and federal and state Water Quality Criteria (WQC).
The second to the last column in Table 19 lists the cleanup goals for the
contaminants identified as chemicals of concern in the groundwater at the
Medley Farm site. The last column in this table provides the source for the
specific cleanup goal. The point of compliance for obtaining these cleanup
goals is the entire Site.
The cleanup goals calculated for contaminants found in the unsaturated
subsurface soils, TBCs, can be found in Table 18. These levels were based on
a leaching model conducted during the FS.
10.1. 2.3
Location-Soecific ARARs
Currently there are'no location-specific ARARs applicable to the Site,
including the Endangered species Act as there are no endangered species
currently within the area affected by the Site. Table 20 listed all the
location-specific ARAR8 reviewed with respect to the Medley Farm site.
10.1.2.4
ARAR Evaluation
All of the alternatives evaluated will comply with its particular set of
ARARs which are specified above. However, it is the time to achieve the
groundwater cleanup standards which distinguishes one alternative from
another as well. as by the fact that Alternatives GWC-l, GWC-2, SC-1, and SC-2
rely on natural attentuation to meet ARARs, rather than active restoration.
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As Alternative GWC-1 is a no action alternative, there are no action-specific
ARARs to be considered and Alternative GWC-1 does not violate any
location-specific ARARs. Alternative GWC-1 will not obtain MCLs in the
groundwater in the near future as it was estimated that leaching of
contaminants from the soil will continue to adversely impact groundwater
above MCLs for approximately 20 years. After this time frame, an
insufficient quantity of contaminants would remain in the unsaturated zone to
leach into the groundwater to result in levels above MCLs.
Alternative GWC-2 extends the requirements of Alternative GWC-1. Alternative
GWC-2 also requires periodical groundwater monitoring to verify that
contaminant concentrations at the Medley Farm property line are below MCLs.
Under Alternative GWC-3, all identified ARARs would be satisfied: MCLs in
groundwater, the effluent to Jones Creek via an NPDES permit, and air
emissions from the air stripping tower.
Alternative GWC-4 would not achieve MCLs across the Site, only at the Medley
Farm property line. Treated groundwater and the air emissions from the air
stripper would meet ARARs as specified above for Alternative GWC-3.
The only identified ARAR for contaminant8 detected in Site soi18 is the TSCA
remediation level of 10 mg/kg for PCB8 in areas of unre8tricted access. None
of the PCB soil 8amples were above the 10 mg/kg level. As there are neither
endangered species, nor area8 of 8ignificant historical importance,
Alternatives SC-l and SC-2 would not violate any location-specific ARARs.
And since Alternative SC-l is a no action alternative, there are no
action-specific ARARs for this alternative to be evaluated against.
All identified ARARs would be adhered to by Alternative SC-3. The single
synthetic liner cap design would meet an equivalent standard of performance
to RCRA requirements. All construction activities would take place above the
100-year flood plain. The Health and Safety Plan governing all remedial
activities would protect on-site workers. The implementation of Alternative
SC-3 would not pose an unacceptable risk to the community.
As with Alternative SC-3, Alternative SC-4 would adhere to ARARs. This
alternative would remediate sub8urface 80i18 to below calculated remediation
levels specified in Table 18. As stated earlier, operation of the SVE system
would conform to South Carolina air emission requirements. Spent activated
carbon from the in-line carbon adsorption system will be treated, regenerated
or dispo8ed of in an approved hazardou8 wa8te landfill. ARARs for RCRA,
including land disposal re.triction8 (LORS) for any sPent carbon will be
adhered to as part of Alternative SC-4. Potential location specific ARARs
would be as described for Alternative SC-3.
10.2
PRIMARY BALANCING CRITERIA
These criteria are used to evaluate the overall effectiveness of a particular
remedial alternative.
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10.2.1
Lona-term Effectiveness and Permanence
This criterion assesses the long-term effectiveness and permanence an
alternative will afford as well as the degree of certainty to which the
alternative will prove successful.
Under Alternatives GWC-1 and GWC-2, the risks posed by the residual
contamination would remain unchanged. Since residual contamination would
remain at the Site, review of the effectiveness of this alternative would be
required every five (5) years. Conditions at the Site are not anticipated to
change significantly over the first 5 year period. The additional activity
to be included for Alternative GWC-2 is the periodic monitoring of the
groundwater. Other than this, the activities remain the same as described
for Alternative GWC-l.
Under Alternative GWC-3 and Alternative GWC-4, extraction wells would achieve
removal of groundwater for subsequent treatment. Groundwater recovery via
extraction wells and submersible pumps is a readily implementable technology
with a certain degree of success. Air stripping is an effective and reliable
process for removing VOCs from water. Maintenance consists of periodic
inspection of the wells, pumps, control units, packing, blower, and transfer
pumps. A 5-year review of this remedy would not be required once the
remediation levels were maintained and verified for an extended period of
time.
Potential migration pathways for chemicals in Site soils are surface run-off
and leaching to groundwater. The RI determined that chemical migration via
surface run-off was not significant; however, VOCs, the primary chemicals of
concern, would leach from the unsaturated zone and impact groundwater above
MCLs. Since waste residuals would be left in place under Alternatives SC-1,
SC-2, and SC-3, review of the effectiveness and protectiveness of these
alternatives would be required at least every five years. Conditions at the
Site are not anticipated to change significantly during the first five year
period.
Chemical transport following the construction of a cap under Alterative SC-3
would be significantly less than under current coniditions. Remaining risks
associated with chemical residuals outside of the cap would not be
significant. Bvaluating the effectiveness of Alternative SC-3 could be
accomplished through periodic groundwater monitoring. Since landfill
residuals would remain at the Site, review of the effectiveness and
protectiveness of this alternative every five years would be required.
Inspection and maintenance records for the cap would be reviewed at this
time. Conditions at the Site are anticipated to improve with the placement
of the cap.
The SVB system as called for by Alternative SC-4 would be operated until the
levels specified in Table 18 were attained. Confirmation sampling may be
required to verify that the remediation levels had been achieved before the
SVE system was shut down. Following the completion of Alternative SC-4,
subsurface soils would no longer impact groundwater above remediation levels,
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therefore, no long-term management of the Site would be required following
implementation of this alternative. Even though soils would no longer
adversely impact groundwater, a five year review would still be required
because contaminant levels in the groundwater exceed ARARs.
10.2.2
Reduction of Toxicity. Mobility or Volume
This criterion assesses the degree to which the alternative employs
or treatment to reduce toxicity, mobility, or volume (TMV) of the
contaminants present at the Site.
recycling
Neither Alternative GWC-l nor Alternative GWC-2 would significantly reduce
the toxicity, mobility or volume of Site residuals. A slight level of
remediation may occur through natural processes, but site-related chemicals
would remain in both Site soils and the groundwater and have the potential to
discharge to Jones Creek under this alternative. However, such discharge
would not pose a significant risk.
Under Alternative GWC-3 and Alternative GWC-4, groundwater extraction would
reduce the volume of chemicals at the Site while the subsequent treatment
would reduce the toxicity of groundwater prior to discharge. The Feasibility
Study calculated that Alternative GWC-3 would reduce the total mass of VOCs
in the groundwater by more than 99 percent and Alternative GWC-4 would
achieye a 95 percent reduction.
Neither Alternative SC-l nor Alternative SC-2 would significantly reduce the
TMV of remaining Site residuals. Some remediation may occur through natural
processes such as biodegradation, adsorption, dilution, and volatilization.
Alternative SC-3 would greatly reduce the mobility and potential exposure of
chemicals above the water table. The mobility of chemicals below the water
table would not change significantly. There would be no reduction in
toxicity or volume of site-related chemicals.
Alternative SC-4 will permanently reduce the volume of VOCs in soils by more
than 95 percent, thereby addressing the risk soil contamination poses to
groundwater. Extracted VOC levels that exceed State ambient air limits would
be adsorbed onto activated carbon. The spent activated carbon could be
either incinerated or'regenerated, depending on a cost comparison to be
completed in the Remedial Design. Some reduction of SVOCs in the soils will
also be achieved through the implementation of this alternative.
10.2.3
Short-term Effectiveness
This criterion assesses the short-term impact of an alternative to human
health and the environment.
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Neither Alternative GWC-l nor Alternative GWC-2 present any risks to the
community, on-site workers, or the environment due to implementation. The
only difference between Alternative GWC-l and Alternative GWC-2 is that
Alternative GWC-l would probably require the installation of additional
monitoring wells.
The installation of extraction wells and the emissions from the air stripper
called for by Alternative GWC-3 and Alternative GWC-4 would pose no
significant threat to the community or on-site workers. During the actual
construction of the remedial action, the on-site workers would be protected
from potential risks through adherence to the remedial Health and Safety
Plan. It is estimated to take approximately three (3) months to implement
either of these alternatives.
Since neither Alternative SC-l nor SC-2 require that any type of activity be
implemented, these alternatives would not present additional risks to the
community, on-site workers or the environment due to implementation. These
alternatives can be implemented immediately.
In order to implement Alternative SC-3, grubbing and grading of the Site
would be necessary for construction of the cap. Dust control would need to
be exercised to minimize the potential release of air-borne particulates.
Worker safety can be controlled through adherence to the Health and Safety
Plan. It is estimated this alternative would take approximately three (3)
months to implement.
Alternative SC-4 presents no risks to either the community or on-site workers
during installation or operation. Emis8ions during operation would be
controlled to insure the mass of contaminants being released into the air is
below allowable ambient levels. Installation of the SVE system would require
approximately one month and start-up could require another month. It is
anticipated that SVE would reduce the residual contamination below soil
remediation levels in one year.
10.2.4
ImDlementabilitv
This criterion aS8eS8e8 the ease or difficulty of implementing the
alternative in terms of technical and administrative feasibility and the
availability of services and materials.
Alternative GWC-l is a no action alternative, and thu8 Can be implemented
immediately. Alternative GWC-2 would require a short period of time to
implement as it would only require the possible installation of additional
monitoring wells and the initiation of institutional controls.
No problems are anticipated in implementing either Alternative GWC-3 or
Alternative GWC-4. Thes8 alternatives may require the installation of
extraction wells and additional monitoring wells, if needed. Distribution
lines to the groundwater treatment system would be below grade and heat
traced to prevent potential freezing where placed above the frost line.
Installation of an air stripper for the anticipated flow of 30 gpm under
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Alternative GWC-3 or the flow of 15 qpm under Alternative GWC-4, would have
no special installation requirements and the groundwater treatment system
should be readily constructed.
Alternatives SC-1 and SC-2 can be implemented immediately, and neither would
hinder the implementation of any remedial actions in the future. No Site
maintenance would be required. As there would be no change in the TMV of the
soils, the Site would need to be reviewed every five years.
The construction of the cap as required by Alternative SC-3 is a
straightforward operation. Clearing the Site and establishment of access for
heavy machinery should pose no difficulties.
The installation of the SVE system as called for in Alternative SC-4 presents
no difficulties. The SVE vacuum and control system is designed to run
unattended. The only required utilities are electrical and telecommunication
services. Control of air emissions would be coordinated with SCDHEC.
Disposal of entrained water does not present any significant difficulties.
SVE is a demonstrated technology using standard equipment that is offered by
a number of vendors.
10.2.5
Cost
This criterion assesses the cost of an alternative in terms of capital costs,
annual operation and maintenance (O&M) costs, and net present value of
capital and O&M.costs.
Alternative GWC-1 involves no capital costs. Operating costs consist of a
review of the Site conditions every 5 years. There would be no maintenance
costs. A summary of the estimated costs is given below:
Total Construction Costs -
Present Worth O&M Costs -
Total Present Worth Costs -
$0
S140.000
$140,000
Capital costs for Alternative GWC-2 include the construction of up to four
additional monitor wells. Operating costs include periodic sampling of
selected monitoring wells, chemical analyses of these samples, and reporting
on, and reviewing the Site conditions every 5 years. Maintenance costs would
include inspection of the monitor wells. A summary of the estimated costs is
given below:
Total Construction Costs -
Present Worth O&M Costs -
Total Present Worth Costs -
$ 35,000
S750.000
$785,000
As discussed in Section 9, Alternative GWC-3 originally had three different
treatment options. They were:
GWC-3A - Air Stripping,
GWC-38 - Activated Carbon Adsorption, and
GWC-3C - Chemical Oxidation.
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Since alternatives GWC-3A, -38, and -3C achieve equivalent treatment of the
contaminated groundwater, the air stripping technology is preferred over the
two other alternatives due to a cost comparison, both 38 and 3C were
el~inated based on a cost comparison.
Construction costs associated with Alternative GWC-3 include mobilization;
extraction wells and the groundwater distribution system; the groundwater
treatment system; discharge line to Jones Creek; upgrading the Site roads;
and utility connections. Operating costs include power and maintenance for
the extraction wells; labor, power, and sampling for the treatment system;
and" groundwater monitoring. Maintenance costs include facility inspections
and equipment repair.
A summary of the est~ated costs is given below:
Total Construction Costs -
Present Worth O&H Costs -
Total Present Worth Costs -
$ 610,000
S 780,000
$1,390,000
Construction costs associated with Alternative GWC-4 include mobilization;
extraction wells and.the groundwater distribution system; the groundwater
treatment system; discharge line to Jones Creek; upgrading the Site roads;
and utility connections. Operating costs include power and maintenance for
the extraction wells; labor, power, and sampling for the treatment system;
and groundwater monitoring. Maintenance costs include facility inspections
and equipment repair.
A summary of the estimated costs is given below:
Total Construction Costs -
Present Worth O&H Costs -
Total Present Worth Co8ts -
$ 520,000
S 770,000
$1,290,000
There are no construction costs a8sociated with either Alternative SC-1 or
SC-2. Operating c08t8 consist of a review of the Site conditions every 5
years. There would be no maintenance costs. A summary of the est~ated
costs for both SC-1 and SC-2 i8 given below:
Total Construction Co8t8 -
Present Worth O&H Costs -
Total Present Worth Costs -
$ 0
5140.000
$140,000
Construction costs associated with Alternative SC-3 include mobilization,
excavation, grubbing, grading, earth work, material, and labor. Operating
COst8 include maintenance of the cap, reporting, and review of the Site every
five years. Maintenance costs include periodic inspections and grounds
keeping.
A summary of the estimated C08ts is given below:
. Total Construction Costs -
Present Worth O&H Costs -
Total Present Worth Costs -
$ 580,000
5 420,000
$1,000,000
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Construction costs associated with Alternative SC-4 include
materials for the SVE wells and manifold piping. "Operating
leasing of the SVE equipment, disposal of spent carbon, and
monitoring and maintenance.
installation and
costs include
regular
A summary of the estimated costs is given below:
Total Construction costs -
Present Worth O&M Costs -
Total Present worth Costs -
$260,000
5360,000
$620,000
10.3
MODIFYING CRITERIA
State and community acceptance are modifying criteria that shall be
considered in selecting the remedial action.
10.3.1
state of South Carolina Acceptance
The State of South Carolina concurs with the selected remedy.
10.3.2
Community Acceptance
A Proposed Plan Fact Sheet was distributed to interested entities on February
8, 1991. Copies of the Proposed Plan were sent to local residents, local
newspapers, local radio and TV stations, the PRP steering committee, and
local, State, and Federal officials. The Proposed Plan public meeting was
held on February 12, 1991.
The public comment period on the Proposed Plan was began on February 13, 1991
and was to close on March 14, 1991. However, due to a letter requesting an
extension to the public comment period, the comment period did not end until
April 12, 1991.
Only one set of written comments were received during the public comment
period. These commentB and the questions asked during the February 12 public
meeting are summarized in the attached Responsiveness Summary.
11.0
DESCRIPTION OF THE SELECTED REMEDY
The selected remedy for this Site is:
extraction and on-site treatment by air stripping of groundwater
contaminated acrOB. the entire Site;
off-site discharge of treated groundwater to Jones Creek via an NPDES
discharge permit;
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in-situ soil vapor extraction of contaminated soils (those above the
calculated soil remediation levels);
review the existing groundwater monitoring system to insure proper
monitoring of groundwater; if deemed necessary, additional monitoring
wells will be installed to mitigate any deficiencies in the existing
groundwater monitoring system; and
monitoring of soil, groundwater, and surface water.
This remedy will attain a 10-6 cancer risk level across the entire Site.
To obtain this risk level, this remedial action alternative requires the
extraction and treatment of groundwater above MCLs as well the removal of
residual soil contamination that would continue to adversely impact
groundwater above MCLs.
11.1
MONITORING EXISTING CONDITIONS
As part of the Remedial Design, the wells listed below, at a minimum, will be
sampled and analyzed on a quarterly basis. Samples from the following wells
will be analyzed for the same range of volatile organics as in the RI: SW-1,
BW-1, BW-4, SW-101, SW-I06, BW-106, SW-10B, and BW-10B. The following well
samples will also be analyzed for the same range of semi-volatile organics as
in the RI: SW-3, SW-4, BW-2, and BW-10S. If the first set of analyses for
semi-volatile organic8 verifies the findings of the RI, then the sampling and
analYBe. for Bemi-volatile organicB can be di8continued during the RD.
The two tributaries to Jones Creek that border the Site shall also be sampled
during the RD. The sampling point in the tributary that lieB to the
northeast of the Site shall be in the vicinity, downgradient of monitoring
well cluster SW-10B/BW-10B. The sampling point in the tributary that lies
south of the Site shall be in the vicinity, downgradient of monitoring well
cluster SW-106/BW-106. These .amples, both surface water and sediment, shall
be analyzed for volatile organics. This analytical data will confirm if
contaminated groundwater is diBcharging to these tributaries. If
contamination is found in either of these tributaries, then these sampling
points will be added to the overall monitoring scheme for the Site to be
developed in the RD.
11.2
GROUNDWATER EXTRACTION. TREATMENT. AND DISCHARGE
This remedial action will consist of a groundwater extraction and treatment
system, and an overall monitoring program for the Site. Groundwater
contaminated above MCLs will be extracted across the entire Site. This will
be accomplished by installing a serieB of extraction wells located within and
at the periphery of the contaminant plume in the saprolite and bedrock
portions of the aquifer.
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The estimated total volumetric flow is 43,200 gall~ns per day. This is based
on a 30 gpm groundwater extraction system operating 24 hours a day. More
precise groundwater withdrawal and discharge values will be developed as part
of the remedial design. As stated previously, the point of compliance is the
entire Site.
The extraction system will be developed in the remedial design. It is
anticipated that 7 extraction wells will be needed (refer to Figure 22).
Pump tests and groundwater modeling may be required for the design of the
extraction system.
Treatment of groundwater will be accomplished by means of an air stripping
tower. From the extraction wells, groundwater will be pumped into an
equalization tank before it is fed to the air stripping system. The air
stripper will remove the VOCs from the groundwater. If the treated
groundwater meets standards to be specified in the NPDES discharge permit, it
will be discharged to Jones Creek. Due to the potential of having
concentrations of metals above allowable levels in the effluent under the
NPDES program, it may be necessary to reduce metal concentrations in the
groundwater prior to discharge. Metal removal from the groundwater may
consist of precipitation, flocculation, ion exchange, or some other cost
effective method.
The following details will need to be addressed as part of the remedial
design: (1) the need to remove metals from the extracted groundwater prior to
discharging to Jones Creek; (2) the disposal of any waste stream associated
with the removal of metals; and (3) the need for controlling the off-gas of
the air stripper. The necessity for removing metals prior to discharging the
treated groundwater to Jones Creek will be addressed in the preparation for
obtaining the NPDES discharge permit. Data generated as part of the RD will
also confirm if the off-gas from the air stripper, laden with volatiles
stripped from the groundwater, will need to be controlled.
As stated previously, the goal of this remedial action is to restore
groundwater to its beneficial use as a drinking water source. Based on
information obtained during the RI and on a careful analysis of all remedial
alternatives, EPA and the State of South Carolina believe that the selected
remedy will achieve this goal. Groundwater contamination may be especially
persistent in the immediate vicinity of the contaminants' source, where
concentrations are relatively high. The ability to achieve cleanup goals at
all points throughout the area of the plume, cannot be determined until the
extraction system has been implemented, modified as necessary, and plume
response monitored over time. If the implemented groundwater extraction
system cannot meet the specified remediation goals, at any or all of the
monitoring points during implementation, the contingency measures and goals
described below may replace the selected remedy and goals for these portions
of the plume. Such contingency measures will, at a minimum, prevent further
migration of the plume and include a combination of containment technologies
and institutional controls. These measures are considered to be protective
of human health and the environment and are technically practicable under the
co~responding circumstances.
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The selected remedy will include groundwater extraction for an estimated
period of 30 years, during which time the system's performance will be
carefully monitored on a regular basis and adjusted as warranted by the
performance data collected during operation. Modifications may include any
or all of the following:
a)
alternating pumping at wells to eliminate stagnation points;
b)
pulse pumping to allow aquifer equilibration and to allow adsorbed
contaminants to partition into groundwater;
C)
installation of additional extraction wells to facilitate or
accelerate cleanup of the contaminant plume; and
d)
at individual wells where cleanup goals have been attained, and
after analytical confirmation, pumping may be discontinued.
To ensure that cleanup goals will be obtained and maintained, the aquifer
will be monitored at those wells where pumping has ceased initially every
year following discontinuation of groundwater extraction. This monitoring
will be incorporated into an overall Site monitoring program which will be .
fully delineated in the Operations and Maintenance portion of the Remedial
Design.
If it is determined, on the basis of the preceding criteria and the system
performance data, that certain portions of the aquifer cannot be restored to
their beneficial use, all of the following measures involving long-term
management may occur, for an indefinite period of time, as a modification of
the existing system:
a)
engineering controls such as physical barriers, or long-term
gradient control provided by low level pumping, as containment
measures;
b)
chemcial-specific ARAR. will be waived for the cleanup of those
portions of the aquifer based on the technical impracticability of
achieving further containment reduction;
c)
institutional controls will be provided/maintained to restrict
access to tho.e portions of the aquifer which remain above
health-ba.ed goal., .ince this aquifer is classified a. a potential
drinking water .ource;
d)
continued monitoring of specified wells; and
e)
periodic reevaluation of remedial technologies for groundwater
restoration.
The decision to invoke any or all of these measures may be made during a
periodic review of the remedial action, which will occur at intervals of at
least every five year8, in accordance with CBRCLA l2l(c). TO ensure State
and PUblic involvement in thi8 decision at this Site, any changes from the
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-97-
remediation goals identified in this ROD will be formalized in either an
Explanation of significant Difference document or 'an Amendment to this Record
of Decision thereby, providing an opportunity for State and public
participation.
11.3
SOURCE REMEDIATION
Although the Baseline Risk Assessment indicates that residual soil
contamination under present day conditions does not pose an unacceptable risk
to either human health or the environment, the soils will continue to
adversely impact the quality of groundwater above MCLs at the Site. This
leaching of contaminants from the unsaturated soils into groundwater results
in an unacceptable indirect risk under the future risk scenario,
consequently, SVE is warranted to remove contaminants from the soil.
A SVE system is an in-situ treatment process used to clean up soils that
contain VOCs and SVOCs by inducing a vacuum in the subsurface soils. The SVE
system consists of a network of air withdrawal (or vacuum) wells installed in
the unsaturated zone. A pump and manifold system of PVC pipes is used for
applying a vacuum on.the air withdrawal wells which feed into an in-line
water removal system and an in-line vapor phase carbon adsorption system for
VOC and SVOC removal. The subsurface vacuum propagates laterally, causing
in-situ volatilization of compounds that are adsorbed to soils. Vaporized
compounds and subsurface air migrate to the air extraction wells, essentially
air stripping the soils in-place.
At the Medley Farm site, the vacuum wells can be installed vertically to the
full depth of the contaminated unsaturated zone (approximately 60 feet below
surface level). Vertical wells were selected due to the depth of the soil
strata requiring remediation, geotechnical conditions, and the depth to
groundwater. .
Once the well system is installed and the vacuum becomes fully established in
the soil column, VOCs and some SVOCs are drawn out of the soil and through
the vacuum wells. In all SYE operations, the daily removal rates decrease as
contaminants are recovered from the soil. This treatment technology has been
prov~n effective at treating soils that contain elevated levels of organic
contaminants.
The application of SVB to the unsaturated zone remediation is a multi-step
process. Specifically, full-scale vacuum extraction systems are designed
with the aid of laboratory and pilot-scale VOC stripping tests. Further
testing will be performed as part of the remedial design.
The final disposition of the spent activated carbon from the in-line carbon
adsorption system will be specified in the remedial design. The three
options to be considered are treatment, disposal at an approved hazardous
waste landfill or regeneration of the carbon. compliance with ARARs for
RCRA, including LDRs for treatment, storage, and/or disposal of spent carbon
will be assured as part of the RD.
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-98-
11.4
COST
The total present worth cost for the selected alternative is $2,404,000.
break down of this cost is specified below.
The
The present worth cost for the groundwater extraction and air stripping
alternative is approximately $1,855,000. This cost includes a capital cost
of $609,000 for construction of the groundwater extraction system, the
treatment unit, treated groundwater discharge system, and all associated
piping. This cost also includes annual expenditures for operation and
maintenance of the system of $1,246,000 for 30 years.
The present worth cost for the SVE system with vapor phase carbon adsorption
is approximately $549,000. This cost includes a capital cost of $344,000 for
construction of the SVE system, the vapor phase carbon adsorption system, and
all associated piping. This cost also includes annual expenditures for
operation and maintenance of the system of $205,000 for 2 years.
Capital
Cost for Groundwater Extraction and Treatment System
Operation & Maintenance costs for 30 years
Capital Cost for the Soil Vapor Extraction System
Operation & Maintenance costs for 2 years
$ 609,000.00
$1,246,000.00
$ 334,000.00
$ 205,000.00
TOTAL PRESENT WORTH COST
$2,384,000.00
12.0
STATUTORY DETERMINATION
The selected remedy satisfies the requirements of Section 121 of CERCLA.
12.1
PROTECTION OP HUMAN HEALTH AND THE ENVIRONMENT
The selected remedy will permanently treat the groundwater and soil and
removes or minimize. the potential risk as.ociated with the wastes. Dermal,
ingestion, and inhalation contact with Site contaminants would be eliminated,
and risks posed by continued groundwater contamination would be reduced.
12.2
COMPLIANCE WITH ARARs
This alternative will be designed to meet all ARAR8 of Pederal and more
stringent State environmental law.. A complete di.cuss.ion of the ARARs
which are to be attained i. included in Sections 9.3 and 10.1.2. These
sections also describe the TBC requirement..
12.3
COST-EPFECTIVENESS
The selected groundwater and source remediation technologies are
cost-effective "than the other acceptable alternatives considered
because they provide greater benefit for the cost.
more
primarily
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-99-
12.4
UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT
TECHNOLOGIES OR RESOURCE RECOVERY TECHNOLOGIES TO THE MAXIMUM EXTENT
PRACTICABLE
The selected remedy represents the maximum extent to which permanent
solutions and treatment can be practicably utilized for this action. Of the
alternatives that are protective of human health and the environment and
comply with ARARs, EPA and the State have determined that the selected remedy
provides the best balance of trade-offs in terms of long-term effectiveness
and permanence; reduction in toxicity, mobility or volume achieved through
treatment; short-term effectiveness, implementability, and cost; State and
community acceptance; and the statutory preference for treatment as a
principal element.
12.5
PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT
The preference for treatment is satisfied by the use of a vacuum extraction
system to remove contamination from soil at the Site and the use of air
stripping to treat contaminated groundwater at the Site. The principal
threats at the Site will be mitigated by use of these treatment technologies.
-------
RBSPONSIVBHBSS SOJDmRY
FOR THE
PROPOSED REMEDIAL ACTION PLAN
AT THE
MEDLEY FAIU! SUPKRPURD SID
GAFFNEY, SOUTH CAROLINA
Public Comment:
February 13 through April 14, 1991
May 1991
Prepared for:
u.S. Environmental Protection Agency
Region IV
-------
MEDLEY FARM SUPERFUND SITE
RESPONSIVENESS SUMMARY
FOR THE
PROPOSED REMEDIAL ACTION PLAN
TABLB
OP
CONTENTS
PAGE
Overview
1
............... ............ .................. ................ -
Background. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 2
Part I:
Summary of Major Issues and Concerns Received as Comments ... 3
A.
B.
C.
Identification and Involvement of PRPs ....................... 3
Cleanup Costs................................................ 4
Selection of Remedy.......................................... 5
- -
Part II:
Comprehensive Response to Significant Comments ............. 6
A.
Selection of Remedy
.. ... ..... ..................... ..... ...... 7
ATTACHMENTS
Attachment A - Transcript of Public Meeting
Attachment B - Materials Distributed at Public Meeting
Attachment C - List of Local Community Members at Public Meeting
Attachment D - Copy of Public Notices
1. Public Meeting
2. Extension of Public Comment Period
Attachment E - Letter from Medley Farm Site Steering Committee to EPA, dated
April 12, 1991
Attachment F - Letter from EPA to Steering Committee, dated
May 6, 1991
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1-
RBSPORSIVBRBSS smamRY
for the u.s. EPA ReqioD :IV
Medley Parm Superfund Site Public Meetinq
Gaffuey Bi.qh School, Gaffaey, South CaroliDa
Pebruary 12, 1991
This community relations Responsiveness Summary is divided into the following
sections:
Overview:
Backaround:
Part I:
Part II:
OVBRVXD
This section discusses EPA's preferred alternatives for remedial
action.
This section provides a brief history of community interest and
concerns raised during remedial planninq at the Medley Farm
Superfund Site.
This section provides a summary of major issues and concerns
received in the comments, and expressly acknowledges and
responds. to those raised by the local community. "Local
community" may include local homeowners, businesses, the
municipality, and not infrequently, potentially responsible
parties (PRPs).
This section provides a comprehensive response to all
siqnificant comments and is comprised primarily of the specific
leqal and technical questions raised during the public comment
period. If necessary, this section will provide technical
details on answers presented in Part I.
EPA published its preferred remedial alternative for the Medley Parm
Superfund Site, located in Gaffney, South Carolina in the Proposed Plan Fact
Sheet, mailed to the public on Pebruary 8, 1991, and in the public notice
published in the Greenville News on February 10, 1991 (refer to Attachment
D). The pebruary 12 Public meeting initiated the public comment period.
EPA's preferred alternative addresses contamination of the qroundwater and
surface 80ils around the Site. The preferred remedy includes the following
technoloqie8 as described in the Feasibility Study completed in April 1991:
Treatment Usina Air Striggina: Recovery of qroundwater above
maximum contaminant levels (MCLs) and treatinq the extracted
qroundwater throuqh an air strippinq tower prior to discharginq to
Jones Creek via a National .Pollutant Discharge Elimination System
(NPDES) permit. If necessary to comply with applicable portions of
the Clean Air Act and the South Carolina Pollution Control Act, the
off-gas will be controlled using an activated carbon unit.
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-2-
So~l VapOr Extraction: Employ soil vapor extract~on in areas
exceed~ng calculated soil remediation levels. If necessary to comply
with applicable portions of the Clean Air. Act and the South Carolina
Pollution Control Act, the extracted vapors will be controlled using
an activated carbon unit.
EPA's preferred alternative for addressing groundwater contamination involves
extracting or removing contaminated water from the upper and bedrock portions
of the aquifer using extraction wells and treating the contaminated water by
'air stripp~ng. Air stripping is a process in wh~ch air is forced through
contaminated water, causing volatile organic compounds (VOCS) to evaporate.
Once this process is completed, extracted groundwater will be d~scharged to
Jones Creek via an NPDES permit.
EPA's preferred alternative for addressing contaminated soils is soil vapor
extraction (SVE). As proposed, the SVE treatment process will remove VOCs
and some semi-volatile organ~c compounds (SVOCS) from the so~l. A vacuum
extract~on system cons~sts of a network of air withdrawal (or vacuum) wells
installed ~n the unsaturated zone. A pump and manifold system of pipes ~s
used to apply a vacuum on the air wells that feed an in-line water removal
system, and an in-line vapor phase carbon adsorption system for VOC and SVOC
removal. Vacuum wells can either be installed vertically to the full depth
of the contaminated unsaturated zone or installed horizontally within the
contaminated unsaturated zone. Vertical wells were selected at this Site due
to the depth of the soil strata requiring remediation, geotechnical
conditions, and the depth to groundwater.
Although the Risk Assessment indicates that the soil, under present
conditions, does not pose an unacceptable risk to human health or the
environment, the remediation of soils is required as the soils will continue
to adversely impact the groundwater flowing beneath the Site above acceptable
levels. Therefore, the Agency has determined that SVE is warranted to remove
contaminants from the soil.
BACKGROUND
Community interest and concern about the Hedley Farm site has been moderate
over the past several years. EPA has sponsored a number of public meetings
and released six fact sheets to help the community understand its role in the
Superfund process and to share information regarding the direction and
technical objectives of data collection activities at the Site. A broad
cross-section of the community has been represented at these meetings,
including local government officials, community residents, and the PRPs.
To obtain public input on the Agency's proposed plan for remedial action at
the Hedley Farm site, EPA held a public comment period from February 13,
through April 14, 1991. The public comment period, originally scheduled to
end Karch 14, 1991, was extended 30 days at the request of the community, to
allow additional time to comment on the proposed plan.
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-3-
The following section provides details on the accumulative community
relations efforts conducted by the Agency. Information Repositories/
Administrative Records were established at the Cherokee County Public Library
in Gaffney and in the EPA, Region IV Regional Information Center in Atlanta,
Georgia. A Community Relations Plan identifying a positive public outreach
strategy was developed. The primary vehicle of disseminating information to
the public was through fact sheets and public meetings.
The first two Fact Sheets were distributed to the public during the latter
part of 1988. The first Fact Sheet, released in october 1988, provided
pertinent background and historical information, and a brief description of
the Superfund process. The second Fact Sheet, distributed in December 1988,
described the upcoming RI field activities and provided a schedule of work.
Following the submittal of the draft RI report to the Agency by the PRPs on
March 30, 1990, a third Fact Sheet was prepared. This Fact Sheet,
distributed in May 1990, highlighted the findings/conclusions stated in the
draft RI report. Due to the data deficiencies identified in the draft RI
report, a fourth Fact Sheet was mailed to inform the public that a second
phase, Phase II, of the RI was necessary. FOllowing the completion of Phase
II and the submittal of the revised RI report on November 30, 1990, another
Fact Sheet was prepared and distributed to the public in January 1991. This
Fact Sheet highlighted the findings/conclusions stated in the revised RI
report. Shortly after distributing this Fact Sheet, the Proposed Plan Fact
Sheet was sent out to the public on February 8, 1991.
In addition to the distribution of these fact sheets, the Agency conducted
three public meetings. The first public meeting, the ftKick-Offft meeting, was
held on January 9, 1989. A second Public meeting was held on May 24, 1990 to
share with the public the information presented in the draft RI and inform
the public of the upcoming activities and provide a schedule for these
activities. The Proposed Plan public meeting was held on February 12, 1991.
Public notices highlighting the proposed plan and availability of the
administrative record appeared in the Greenville News on February 10, 1991.
Another notice announcing the extension to the public comment period also
appeared in the Greenville News on March 19, 1991. A copy of these public
notices can be found in Attachment D.
PARr I: smamRY OP JmJOR ISSUBS AIm CORCBRlIS RBCB:tVJm AS OOIIMBR'rS
This section provides a summary of major issues and concerns received as
comments, and expressly acknowledges and responds to those raised by the
local community. The major issues and concerns on the proposed remedy for
the Medley Farm Site received at the public meeting on February 12, 1991, and
during the Public comment period, can be grouped into three areas:
A.
B.
c.
Identification and involvement
Cleanup costs, and
Selection of a remedy.
of PRPs,
-------
'-
-4-
A summary of the comments and EPA's responses are provided below. A complete
transcript of concerns raised during this segment of the meeting, along with
the responses, is included on pages 14-18 of the meeting transcript
(Attachment A). Jon Bornholm, Remedial Project Manager for EPA, Region IV,
responded to all questions.
A. Identification and Involvement of PRPs
B.
Q:
What companies, individuals, or other parties have been named as PRPs
and will there be any criminal charges filed against them?
A:
According to the Administrative Order, the following parties were
named prior to the Risk Assessment: Milliken and Company; Unisphere
Chemical Corporation; National .Starch and Chemical corporation; ABCO;
BASF Corporation; Polymer Industries; Tanner Chemical Company, and;
Ethox Chemical, Inc. The Medleys, including Ralph and Clyde Medley,
were subsequently added to the list. To the best of my knowledge, I
do not know if there will be any criminal charges filed against them.
Q:
Is the Agency going to recover the cost of the initial cleanup from
the PRPs?
A:
The majority of the cleanup costs is coming from the PRPs and has
been recovered. The PRPs have paid for all the investigation work
completed to date. The only costs the government has incurred right
now are oversight costs, and EPA will also be seeking to recover
those costs from the PRPs.
Q:
Will the EPA have to enter into negotiations with the PRPs?
A:
After the Agency PUblishes its decision, it then issues special
notice letters to all of the identified PRPs to begin negotiations on
the RD and RA, which usually lasts six months. A Consent Decree,
summarizing the results of those negotiations, is then produced and
becomes a record in the Federal court system. If a decision cannot
be reached during the six-month period of negotiations, the EPA will
issue a unilateral Administrative Order (UAO), forcing the PRPs to
implement a new RD and RA. If the PRPs refuse to comply with the UAO
then superfund will be implemented and the PRPs will become liable
for further damages.
Cleanup Costs
Q:
How much is the cost of the cleanup?
A:
The FS presented several scenarios. The 1D-year and 3D-year
scenarios for the extraction and treatment of groundwater are
estimated to be $1.2 million and $1.9 million, respectively.
The
-------
-5-
cost to treat the source through soil vapor extraction is set at
$550,000, a process which is estimated to be complete in one year.
Therefore, the total present cost for the lO-year and 30-year
scenarios for groundwater extraction and treatment with soil vapor
extraction is $1.8 million and $2.4 million, respectively.
Q:
What is the significance of the 10-year and 30-year scenarios?
A:
The remediation of groundwater is not a science. Sirrine
Environmental Consultants estimated that it will take 20 years, under
natural conditions, for the flushing of soils by rain to clean the
soils down to a level where there is no lonqer any natural
groundwater. OVer those 20 years, the groundwater also will be
treated to remove those contaminants entering it. The purpose of the
soil vapor extraction system is to shorten the period where organics
are allowed to enter the groundwater. The selected RA would cost at
least $1.8 million for the 10-year scenario and $2.4 million for the
30-year scenario.
C.
Selection of Remedv
Comment:
"Soil vapor extraction (SVE) (Alternative SC-3) should be eliminated
the plan for remedial action because it is neither necessary for
compliance with ARARs nor cost-effective". According to the entity
commenting, the great majority of chemical residues at the Site were
removed during the ~ediate removal action in 1983. The entity
commenting noted three problems with the proposed remedy:
from
Site conditions are consistent with aquifer and contaminant
characteristics that are likely to prolong aquifer restoration.
Therefore, the time necessary for cleanup will apply to pump and
treat the groundwater after the natural flushing period is
underestimated in the EPA proposal;
.
Remediation i. not necessary for compliance with ARARs because all
Site soils are le.. than the TSCA remediation level and they do not
pose a significant risk to human health or environment; and
.
The estimated cost. for remediation do not consider the longer
remediation period required for the EPA preferred remedy, therefore
cost savings are not accurate".
The entity commenting proposed that EPA instead use natural flushing
(Alternative SC-1) combined with groundwater recovery and treatment
(Alternative GWC-2A) as the remedy for the Site. The entity commenting
suggests that groundwater extraction alone can prevent potential future
risks, is technically justifiable based on EPA experience, and in
. conjunction with natural flushing is the most cost-effective remedy for
the Site.
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-6-
The letter to EPA documenting these comments on the selection of a
remedy, dated April 12, 1991, is attached as Attachment E to this
summary.
Response:
It is the Agency's opinion that the selected remedy is the best overall
choice for remediation of both soil and groundwater at the Site. The
natural flushing alternative is not acceptable because:
.
The time necessary to pump and treat the groundwater after the
natural flushing period is underestimated;
Cost savings from the commenting entity's proposal may not be
substantial and do not justify reliance on natural flushing; and
Technical publications strongly recommend addressing residual source
areas .using a companion technology with pump-and-treat, such as SVE.
EPA believes that eliminating the residual source areas by using SVE is
more logical than using natural flushing, since the areas are a potential
problem which would likely affect the pump-and-treat system.
In reviewing the feasibility of a remedy, EPA is required by legislation
to consider two criteria not addressed in the entity's comments: State
and community acceptance of the remedy. State and community
representatives will not support a natural flushing, or "No Action",
scenario. In fact, the South Carolina Department of Health and
Environmental Control (SCDHEC) has concurred with and supports the
selected remedy. It is therefore the Agency's opinion that the selected
remedy is the best overall choice for remediation of both soil and
groundwater at the Hedley Farm Site.
PARr II:
OOMPRBBBRSIVB RBSPORSB '1'0 SIGlIIFICAR'.r COIIIIBRTS
This, section provides a comprehensive response to all significant comments on
the Hedley Farm Superfund Site received during the public comment period.
The information presented in this section provides technical details for
issues discussed in Part I, specifically, issues raised regarding the
selection of a remedy for the Hedley Farm Superfund Site. Technical issues
are discussed in terms of the following:
.
Duration of the Response Action,
Cost Estimates, and
Companion Treatment System.
.
.
This discussion is presented in the section below.
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-7-
Duration of the Response Action
The Agency does not dispute the findings of the studies researched by the
entity commenting that the time required to pump and treat groundwater with
residual soil contaminants removed during the first year is underestimated.
The underestimation of time, however, also applies to pump and treat
groundwater 20 years in the future to remove the residual contaminants
entering the groundwater (natural flushing), not just SVE.
The assumption that a 50\ reduction in the concentrations of residual
contaminants present in the groundwater will be needed may not hold true,
since there are uncertainties associated with the assumptions required by the
computer models. Treating contaminants that enter the groundwater in the
20th year of natural flushing by the groundwater pump-and-treat system could
take an additional 10 years to be removed from the aquifer. The difference
in time frames between the natural flushing alternative and the SVE
alternative will be therefore greater than 11 years. In addition, further
pump-and-treat time may be necessary to remove the last contaminants entering
groundwater, and contaminants may continue to enter the groundwater beyond 20
years. This would delay further the attainment of cleanup goals.
Cost Estimates
The entity commenting claims that the cost estimates are inaccurate because
they are based on estimates of the duration of the remedial action. If only
five years were required to bring residual concentrations down to MCLs, the
additional costs for groundwater remediation at present worth costs would be
$539,000; if eight years were required they would be $601,000; and if ten
years were required they would be $638,000. Since the present worth cost for
SVE is $620,000, the estimated savings generated by natural flushing are thus
not greater than $200,000, but rather more likely range between $0 and
$81,000. These savings are not substantial when measured against the
estimated total cost (net present worth) of the remedy, or $1.2 million for
10 years and $1.8 million for 30 years, and are not enough to justify
selecting natural flushing as a source control remedy.
ComDanion Treatment System
EPA technical publications (refer to EPA letter, included as Attachment F,
for relevant publications) recommend that any and all residual source areas
be removed or addressed by a companion treatment system to enhance and
improve the effectivene.s of pump-and-treat systems. These Publications
support the Agency's opinion that preventing or minimizing the contaminant
mass from moving from the unsaturated zone to the saturated zone makes more
economic and environmental sense than waiting for the contamination to enter
groundwater and then attempting to remediate the contamination.
-------
ATTACBHBNT A - MBBTIHG TRANSCRIPT
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2
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4
5
6
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8
9
10
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15
16
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18
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25
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
MEDLEY FARM SUPERFUND SITE
PROPOSED PLAN PUBLIC MEETING
TUESDAY, FEBRUARY 12, 1991
7:00 O'CLOCK P.M.
GAFFNEY HIGH SCHOOL
GAFFNEY, SOUTH CAROLINA
RAY SWARTZ & ASSOCIATBS
P.O. BOX 38038 - CHARLBSTON, S.C. 29414-8406
(803) 556-2923 OR TOLL PRBB IN U.S.A. 1-800-822-8711
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EPA - MEDLEY FARM SUPERFUND SITE
Page 2
MR. JON BORNHOLM:
Good evening.
It's a
2
few minutes after 7:00 o'clock.
I'd. like to welcome you this
3
evening.
John
Bornholm.
I'm
with the Environmental
I'm
4
Protection
and
I'll be conducting this meeting this
Agency
5
evening.
6
There
a
few
are
7
people that I'd like to introduce.
Mr. Ralph Howard with the
8
Environmental
and
Mr. Glenn Adams, also
Protection
Agency
9
with
the
Agency, is present tonight.
Ms. Cynthia Peurifoy,
10
and
I've probably done a bad job of pronouncing her name, is
11
the
Coordinator
for the Environmental
community
Relations
12
Protection Agency.
13
I'd
like
to explain
14
the
that I will be presenting on the screen tonight.
graphs
15
This is the Medley Farm Site, the location of the site.
This
16
is
It's about six miles down the road.
the Town of Gaffney.
17
Most
of
I'm
going to be showing you have been
these
that
18
taken
of
the draft remedial investigation or the draft
out
19
report
that has been prepared for the responsible parties by
20
Sirrine Environmental Consultants.
21
We're
going
go
to
22
through
superfund
the
project itself.
Site discovery, PRP
23
search
the
responsible,
and
the
ranking
of
the
site,
24
potentially
responsible parties, the latter part of '87, the
25
potentially responsible parties signed what we call an
RAY SWARTZ & ASSOCIATES
P.O. BOX 38038 - CHARLESTON, S.C. 29414-8406
(803) 556-2923 OR TOLL PREE IN U.S.A. 1-800-822-8711
-------
EPA - MEDLEY FARM SUPERFUND SITE
Page 3
'2
Administrative order on consent, which we viewed with the
feasibility study in January of '88 and this will be based on
our input from the public on this meeting, and the remedial
J
4
investigation,
to develop what we call a regular decision or
5
ROD.
expect
right now to have that regular decision
We
a
6
signed
Following
our administrator at the end of March.
by
7
that
we
into
enter
negotiations
with
the
potentially
8
responsible
to
try to convince them of the
again,
parties
9
remedial
Following that decision we enter into the
design.
10
actual environmental cleanup.
11
Something I forgot to
handouts on the front table that
12
mention.
some
There
are
I J
basically
I'm
have
all the overheads that I will be using.
14
sorry I forgot to mention that beforehand.
15
This
is what we call
16
time line that identifies the activities that occur.
What
a
17
highlighted
is this meeting tonight, which is
I've
in
red
18
what
we
call
meeting.
Tonight is our Public
the
public
19
comment
period,
where we encourage the public to
which
is
20
voice their opinion with regard to the Medley Farm site.
The
21
public
If an additional thirty days
period ends March 15th.
22
is requested by the public, we would extend it another thirty
23
days.
Again, this is
That
would
extend it to April 15th.
24
being
a
made
of
the
record
this
part
evening.
Our
25
responsiveness summary, a transcript from tonight's meeting
RAY SWARTZ & ASSOCIATBS
P.O. BOX 38038 - CHARLBSTON, S.C. 29414-8406
(803) 556-2923 OR TOLL PREB IN U.S.A. 1-800-822-87~1
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EPA - MEDLEY FARM SUPERFUND SITE
Page 4
and
all
and our responses to those public
public
comments
2
That's
of
It becomes part of
our record.
comments.
part
J
it goes in the decision stage,
public
meeting.
Then
this
4
regional
administrator and it goes into the
by
signed
our
5
negotiations,
which is approximately a six
remedial
design
6
month
There is negotiation with the potentially
time frame.
7
responsible
parties and then if that fails there is a filing
8
with
Federal
court, and then following that we go into
the
9
the Court.
That gives you an idea of our time frames.
10
The
is
the
next
11
remedial objectives of the investigation; that is to identify
12
the contamination in both the soil and the groundwater.
This
1 J
will
give you an idea of the characteristics of the environ-
14
mental mediums at the site, the soils, the bedrock, to
15
determine
and
hydrogeological
chemical,
physical
16
characteristics;
or absence of
determine
the
to
presence
17
areas.
Again, we looked at the impact it would have
source
18
any
of
those potential
creek
and
identify
Jones
to
on
19
contaminants to the public.
20
accomplish
that
To
21
the
BPA
proposed to take soil borings.
The results of that
22
were published in April, I believe, of '90.
23
And
little
these
24
circles
water and the soil
the
locations
of
surface
are
25
boring locations.
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Page 5
This is just a review
2
of
they found at the site from the remedial investiga~
what
J
The soils of the disposal areas are contaminated with
tion.
4
volatile
site,
as well as semi-volatile
compounds
the
at
5
compounds.
Groundwater at the site and downgradient are con-
6
taminated
Metal was detected
with volatile compounds again.
7
in
The levels
groundwater,
but
that is natural occurring.
8
detected did not pose a risk.
The groundwater is moving in a
9
southeasterly direction and the sprouse well is hydraulically
10
upgradient
There were no contaminants found in
of the site.
! !
Jones Creek.
And Jones Creek is running through here.
12
And
this
overhead
1 J
shows
found in the bedrock portion of the
the
contaminants
14
aquifer.
Disposal activities occurred up in this area.
15
And
this
overhead
16
shows
direction of flow of water "in the bedrock portion
the
17
of
in the southeastern
the
aquifer
and
the
contaminants
18
direction towards Jones creek.
19
Basically
this shows
20
the
Again,
contaminants
found
in
the
soils at the site.
21
that's volatile as well as semi-volatile organic compounds at
22
the site.
23
This
you
the
gives
24
chemicals
The volatile organic compounds, 1,1,2-
detected.
25
Trichloroethane; out of thirteen it was detected in two of
RAY SWARTZ & ASSOCIATES
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Page 6
those
detections.
The
column,
that gives you the
second
2
range of detected concentrations found.
J
schedule
shows
This
4
the
chemicals
saprolite
wells and this schedule
found" in
5
identifies
chemicals
wells,
found
the
the
bedrock
in
6
including
number
the frequency of
of
detections
and
the
7
detections.
8
Part
of the remedial
9
investigation
a
called
risk
is
assessment
objectives.
10
Basically this looks at the contaminants detected, where they
11
detected
and
what possible pathway those contaminants
were
12
have
to
reach either the environment or the public.
And we
1 J
have quantitative as well as a qualitative.
14
Based on the informa-
15
tion
remedial investigation, the risk
provided during
the
16
document,
under today's conditions, the site does not pose a
17
risk
or
either
to
public
health
the
environment.
The
18
feasibility
states that the site does not pose a risk
study
19
in
the
future; that PRPs or potentially responsible parties
20
need
go
back
to
and
re-evaluate that if we feel that the
21
groundwater,
a
under
of
the
site
becoming
scenario
a
22
residential area, is considered.
23
The objectives of the
feasibility study is to look at potential technology to clean
24
25
up the site, and then narrowing down from that laundry list
RAY SWARTZ & ASSOCIATBS
P.O. BOX 38038 - CHARLBSTON, S.C. 29414-8406
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Page 7
the
technology
are applicable to the site.
There are
that
2
several
on
the
used
screening
factors
for
criteria
3
technology.
And
then once you've cleared that, you go down
4
to
smaller
we
go into a more detailed
list,
and
then
a
5
evaluation of those alternatives, which uses nine criteria to
evaluate alternatives.
They basically are threshold criteria
7
. . .let
me back up.
The
There are three levels of criteria.
8
first
one
threshold criteria.
is
These must be met by the
9
alternatives.
one being the overall attention to
first
The
10
human
health
environment and the second one is in
and
the
II
compliance
with
applicable
relevant
and
appropriate
or
12
requirements,
we
which
call
That's
actual! y. . .
AURs.
1 J
A-R-A-R-S.
We take these criteria and we look at them under
14
what
we
call
primary balancing criteria and those are long
15 term effectiveness
16 mobility or volume;
17 ness and then cost.
18
and
permanence;
reduction of toxicity,
implementability; short term effective-
I'd
like
to briefly
19
through
process.
that
whole
Potential
groundwater
go
20
remediation technology at the site, considering the no action
alternative at all sites based on the risk assessments, which
21
22
is a Baseline Risk Assessment.
We had
Groundwater recovery.
23
certain
recover
groundwater;
of
could
types
ways
we
24
extraction
wells,
drains
and
subsurface
and
trenches
25
alternative concentration limits.
we have identified several
RAY SWARTZ & ASSOCIATBS
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Page 8
ways
of
treating that groundwater once it is extracted from
2
the ground.
One is air stripping, activated carbon, chemical
3
oxidation, land treatment and biological treatment.
And once
4
have it out of the ground we need to do something with it
we
5
treated.
Discharge of extracted groundwater.
after
it
is
6
There
surface
water discharge; pump it through the
is
the
7
local
discharge
it out through an irrigation
sewer
plant;
8
into injection wells on the site.
And potential
process
or
9
technologies; again the no action alterna-
soil
remediation
10
tive.
in
place; soil vapor
In-situ
treatment,
treatment
11
extraction,
enhanced
biodegradation,
soil
flushing
and
12
vitrification.
And also the off-site treatment or disposal;
13
incineration or disposal at an approved hazardous waste site.
14
And
containment, which is capping, slurry walls around
then
15
the
grouting, sheet piling around it or bottom
containment,
16
sealing.
17
The
groundwater
18
control
summary, the ones highlighted in red, as
technology
19
to what was actually kept as far as potential alternatives to
20'
clean
a
rough cost estimate was
the
site.
And
then
up
21
performed
each of those alternatives and based on those
for
22
cost
were eliminated.
What
several
alternatives
amoun ts ,
23
these
alternatives consist of, again, no action at the site,
24
let
course.
The second one is no action;
take
nature
its
25
long term monitoring, which consists of, again, letting
RAY SWARTZ & ASSOCIATBS
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nature take its course, but we would require occasional
2 sampling of the monitoring wells to address or to measure ho~
3 quickly mother nature is cleaning up the site as well as to
4
make
we didn't miss anything or take care of something
sure
5
that
might
come up down the road.
The next is what we call
6
MCLS,
which
are maximum concentration levels or limits, and
7
those are levels of contaminants allowable in drinking water.
8
Under
this
scenario the pump and treat system would have to
9
attain
that
level
or be above that level across the entire
10
site and it was estimated that this scenario would include or
11
would
exceed up to pumping thirty gallons of groundwater per
12
minute.
And
for
of
extracted
then
treatment
that
13
groundwater, air stripping prior to discharge to Jones creek.
14
The
alternative
for groundwater that was considered
fourth
15
was the MCLs at the property line of the site and then
16
treating
that extracted groundwater with air stripping prior
17
to
discharging
the
groundwater to...or the treated ground-
18
water to Jones Creek.
This was estimated to be fifty gallons
19
minute.
control,
a no action
there
For
was
source
per
20
alternative.
the
second
scenario
for soils, there is
On
21
capping
the
That
would
rain from
prevent
source
area.
22
infiltrating the soils and therefore washing the contaminants
23
further
down
in the groundwater.
And the third alternative
24
is
soil
extraction.
That would be installing wells
vapor
25
into the saturated soils on the site, putting a vacuum on
RAY SWARTZ & ASSOCIATBS
P.O. BOX 38038 - CHARLBSTON, s.c. 29414-8406
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Page 10
those
wells
and drawing the organics out, which puts air in
2
and allows those to be drawn up and .out.
3
Based on the informa-
4
tion
provided in the feasibility study, basically the remedy
5
that
the
has
selected as the preferred alternative is
EPA
6
right
think
here
groundwater.
I think on the page that...I
for
not in the packet.
this
is
It's a loose page,
7
page
8
unfortunately,
that
did not get attached; so if you'll pick
9
up on the way out, that would be appreciated.
Basically
one
10
during
the remediation of the site, wells need to be sampled
11
on a periodic basis to insure that, one, we have captured the
12
groundwater
two,
to measure the possible remediation;
and,
13
Installation of a groundwater extraction system, in this case
14
we're
proposing
the
wells,
extraction
wells;
treating
15
extracted
an
air
tower to remove the
groundwater
through
16
volatile
organics
and then discharging that treated ground-
17
water
creek via an NPDES Discharge Permit.
NPDES
to
Jones
18
stands for National Discharge...National Pollutants Discharge
19
Elimination
That's what NPDES stands for.
I have a
system.
20
note
here.
standard for discharging
Metal
is
more. . . the
21
surface
water
is more stringent for metal than for organics
22
and
the levels of metal that may be in the groundwater, that
23
are
in groundwater, may cause a problem in surface waters to
24
aquatic
life;
for. metal may be necessary in
so
treatment
25
order to meet that discharge permit requirement.
And that's.
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Page 11
why
I have that little thing in parenthesis there.
And then
2
there
is
a
essentially
catch
all
re-evaluate
to
the
3
monitoring system that exists on site today to make sure that
4
we're
missing
there is the deed
anything.
And
then
not
5
restrictions,
which would prevent somebody from installing a
6
drinking well on the site.
7
And
source
for
8
remediation, to install a network of air withdrawal or vacuum
9
wells
that
were
identified as containing
in
those
areas
10
levels of contaminants high enough to impact groundwater.
As
11
I explained before, you put a vacuum on those wells to create
12
air
flow through the system to remove the organics up and
a
13
through
initial
system,
wells,
the
and
prior
to
discharge, or the
then
of
the
will
probably
start-up
it
be
14
15
generating
organics out of the soil, and the
quantities
of
16
extracted air will be sent through an activated carbon filter
17
process prior to being discharged into the environment.
18
And
will
then
we
19
sample
water and sediment in Jones Creek as well as
surface
20
the
Jones
creek to make sure the system is
tributaries
to
2 )
working;
so
if we're missing something with our groundwater
22
tracking
system, we would anticipate seeing it entering this
23
surface water.
24
Basically
the
two
25
groundwater extraction systems considered in the feasibility
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Page 12
study were, one, putting a line of groundwater extraction
2 along these two lines. This line would result in containing
3 the NCLs across the site, which would, as I mentioned
4 earlier, result in a thirty gallon per minute flow for
5
groundwater.
The
second
the
alternative
considered
in
6
feasibility
this
second line, the other line of
study
was
7
extraction.
This
would
meet
NCLs at the property
system
8
boundary
in
flow out of the ground of fifty
little red box is a location of
and
result
a
9
gallons
This
per
minute.
10
where the groundwater treatment system would be installed and
11
would
down
to Jones Creek, which
discharge,
with
piping,
12
would be down here somewhere.
It would be off the map.
13
This
map shows those
14
in the soils where concentrations of organics in soils
,areas
15
will
continue in groundwater above the maximum concentration
16
level,
areas
and
the
soil
these
the
where
vapor
are
17
extraction system would be employed.
18
And
just a
this
is
19
schematic of the soil vapor extraction system.
You have your
20
extraction wells, your vapor extraction wells all tied into a
21
central
manifold, which is attached to some type of
pump or blower, which is then tied into the
central
22
suction,
a
via
23
treatment
system, because you're also going to be extracting
24
water
as well, which will be collected and pumped off
vapor
25
and then the air stream will be piped through an activated
RAY SWARTZ & ASSOCIATBS
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carbon
filter
remove
volatile
the
to
organics and semi-
2
volatile
air stream prior to releasing
organics
from
that
J
that air stream through the environment.
4
And
I
think some of
5
the
misspelled on it.
If further information is
names
got
6
requested
am
desired,
the
primary
I
contact for the
or
7
Richard Haynes is the primary contact for the state,
Agency.
8
South
Environmental
Carolina
of
Health
Department
and
9
Control.
10
other
thing
One
I
II
need to mention, the Agency also has what we call a Technical
12
Assistance Branch program, which basically gives money, under
13
certain
to
be met, to the public in
conditions,
that
has
14
order
for the public to hire its own consultant to basically
J5
review the findings, a1l the documents in the superfund site,
J6
and
that information to the public in maybe a
then
provide
17
understandable
meaning.
But that grant is available.
more
J8
It's
made available for all superfund sites, and the contact
19
for
a technical assistance grant is Denise Bland, and that's
26
her address and telephone number.
21
Basically
that's
22
really
my
presentation.
Again,
this
meeting
is
being
23
reported
a
court
reporter.
We need to get an accurate
by
24
transcript.
am
opening
the
floor
for
any questions.
I
2S
Should you have a question, please state your name so that
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Page 14
the
court
reporter
can
get an accurate account of it, and
2
please
loud
so
enough
speak
that
she
can hear your
up
J
question so that she can put that down on paper as well.
Are
4
there any questions?
5
Cody
MR. CODY SOSSAMON:
Sossamon.
What
6
companies
individuals
individual
have
been
named,
or
7
companies
or parties, and will there be any criminal charges
8
filed against them in this?
9
Okay, the responsible
MR. JON BORNHOLM:
10
parties
I
have
at this time, the Administrative Order, are
11
Milliken
corporation,
and
unisphere
Chemical
Company,
12
National Starch and Chemical Corporation, Abco, BASF Corpora-
13
tion,
company, Ethox
POlymer
Industries,
Tanner
Chemical
14
Chemical,
Inc. ,
and
there are several others that were not
15
identified prior to the remedial action.
16
MR. CODY SOSSAMON:
of
the
Are
any
17
Medleys identified?
18
The
Medleys are also
MR. JON BORNHOLM:
19
identified as potential possible parties.
20
MR. CODY SOSSAMON:
And Ralph Medley?
21
MR. JON BORNHOLM:
Ralph
Clyde are
and
22
both identified as a potential possible party, too.
23
MR. CODY SOSSAMON:
ya'll
plan
to
Do
2.
bring criminal charges?
2S
MR. JON BORNHOLM:
To the best of my
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Page 15
knowledge I do not know.
I cannot say.
2
MR. CODY SOSSAMON:
Are
ya'll
going
to
J
try to recover the initial clean-up cost in this?
4
MR. JON BORNHOLM:
My
understanding
is
5
that
the
majority
of our clean-up costs is coming from the
6
responsible parties.
7
MR. CODY SOSSAMON:
From
those
that you
8
named?
9
MR. JON BORNHOLM:
From
the ones that I
10
listed off, yes.
How much each contributed, I do not know.
11
MR. CODY SOSSAMON:
You
don't
know
the
12
exact amounts?
1 J
MR. JON BORNHOLM:
I
don't remember all
14
of
them, but I know that the majority of our costs have been
15
recovered.
16
MR. CODY SOSSAMON:
What
have
they paid
17
for?
18
MR. JON BORNHOLM:
The
potentially
19
responsible
parties have paid for all the investigation work
20
done
to
date.
The
only
costs
that
the
government has
21 incurred right now are oversight costs and we will also be
22 seeking to recover those costs from the responsible parties
23 as well. Are there any other questions?
24 MR. MATT STAHL: Matt stahl with the
2S
Spartanburg Herald Journal.
How much is the cost of the
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Page 16
clean-up?
I know we've seen some figures, but just how much
2
is the cost?
3
The
costs
generated
MR. JON BORNHOLH:
4
from
feasibility study, several scenarios were put out.
the
5
The
first, a ten year scenario for this pumping and treating
6
of groundwater was calculated, and just to round off numbers,
7
that was estimated to 1.2 million dollars.
And that's on the
8
construction
of groundwater remediation by itself.
The same
9
groundwater remediation by itself, over a thirty year
thing,
10
period,
for
it's
construction
again
for
that
system,
11
estimated to be 1.9 million dollars.
For the source remedia-
12
tion,
vapor extraction process, the present costs were
soil
13
set
S550,000.00 and it was estimated to take one year to
at
14
do
contamination soil samples; so basically if you put those
15
numbers together, the present costs for ten years of pump and
16
treat
with
soil vapor extraction, it's 1.8 million dollars.
17
groundwater
extraction and treatment over a thirty year
For
18
period, along with soil vapor extraction, it was estimated to
19
be 2.4 million dollars.
20
MR. CODY SOSSAMON:
The ten years and the
21
thirty years, I'm not quite clear on what the...
22
MR. JON BORNHOLM:
The
of
significance
23
that?
24
MR. CODY SOSSAMON:
Yes.
25
MR. JON BORNHOLM:
The remediation of
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Page 17
groundwater is not a science; so basically what this is doing
2 is
3 to
4 tion
5 that
look at the process over a'thirty year period and try
to
generate
some costs that would take care of the remedia-
period.
The
idea here, at least for Medley Farms, is
it's been estimated by Sirrine that it will take twenty
6
under natural conditions, for the natural flushing of
years,
7
soils
to
by
rain
clean
the soils down to the level where
8
there
longer any natural groundwater.
That's twenty
is
no
9
years.
And at the same time they're gOing to be treating and
10
pumping
over
that twenty years to remove those contaminants
11
will
that
be
entering the groundwater.
The purpose of,the
12
soil vapor extraction system is to try to shorten that period
13
of
allowing organics to enter the groundwater, and hopefully
14
they can shorten that period.
Did that answer your question?
15
MR. CODY SOSSAMON:
Yes, I think so.
16
MR. JON BORNHOLM:
That's
it
how
long
17
takes to accomplish that.
18
MR. CODY SOSSAMON:
So the least it would
19
cost
then
1.8 million for ten years and 2.4 million for
is
20
thirty years?
21
MR. JON BORNHOLM:
Correct.
22
If
thirty
it
takes
MR. CODY SOSSAMON:
23
years it would go a little bit more?
2.
MR. JON BORNHOLM:
And
if it
Correct.
25
would only take twenty years, it would take somewhere in
RAY SWARTZ & ASSOCIATBS
P.O. BOX 38038 - CHARLBSTON, S.C. 29414-8406
(803) 556-2923 OR TOLL FREB IN U.S.A. 1-800-822-8711
-------
EPA - HEDLEY FARM SUPERFUND SITE
Page 18
between there.
2
HR. MATT STAHL:
Will
the EPA have to
3
enter into negotiations with the responsible parties?
4
HR. JON BORNHOLH:
FOllowing...after the
5
Agency publishes its decision, the Agency then issues special
6
notice
letters
all
of
potentially
the
identified
to
7
responsible
begin
negotiations on the remedial
parties
to
8
design
the
investigation, and that is a six month time
and
9
that needs to be allowed.
The document that hopefully
frame
10
out
of that process is what we call a Consent Degree,
comes
11
that
It's not
lodged
in the Federal Court system.
and
is
12
really
the EPA, but we ask the Federal Court to stand behind
13
it
as well.
Now, if we can't come to a conclusion following
14
the
six months, we will, more likely than not, issue what we
15
call
a
Unilateral
Administrative Order forcing the PRPs to
16
implement
design, a new remedial action, and then if
a
new
17
they
to do that then the superfund comes in and they
refuse
18
then liable for further damages, if they do not go ahead
are
19
and do them themselves.
2Q
Are
there
any other
21
questions?
22
Okay, if you have not
23
signed
on the attendance sheet, please do so on your way out
24
that
accurate record.
There are fact
have
so
we
can
an
2S
sheets that they sent out Friday.
Hopefully you've received
RAY SWARTZ & ASSOCIATBS
P.O. BO%38038 - CHARLBSTON, S.C. 29414-8406
(803) 556-2923 OR TOLL FUB IN U.S.A.. 1-800-822-8711
-------
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
2S
EPA - HEDLEY FARM SUPERFUND SITE
page 19
them by now.
If you haven't received one, please take one on
the
And
again,
there's
a copy of a lot of the
way
out.
overheads
Please feel free to take one
that I used tonight.
so
that I don't have have to carry them back to Atlanta with
me.
And with that, thank you.
************************************************************
RAY SWARTZ' ASSOCIATBS
P.O. BOX 38038 - CHARLBSTON, s.c. 29414-8406
.(803) 556-2923 OR TOLL FREB IN U.S.A. 1-800-822-8711
-------
EPA - MEDLEY FARM SUPERFUND SITE
Page 20
C-E-R-T-I-F-I-C-A-T-E:
2
3
4
I,
Pamela
Public and Court
McDaniel,
A.
Notary
5
Reporter,
certify that the foregoing pages constitute a true
6
and
accurate
transcript,
to the best of my ability, of the
7
proceedings
as
taken by me stenographically on the date and
8
at the time hereinbefore mentioned.
9
10
~
~~~ ~). ~)1~-,
.~OTARY PUBLIC FOR SOUTH CAROLINA
My Commission Expires: 12/18/95
t 1
12
13
14
15
16
17
18
19
20
21
22
23
24
2S
RAY SWARTZ & ASSOCIATBS
P.O. BOX 38038 - CHARLBSTON, S.C. 29414-8406
(803) 556-2923 OR TOLL FRSB IN U.S.A. 1-800-822-8711
-------
Arl'ACRJIRRT B - JmlD)()U'r JIATKIUALS
-------
WELCOHE TO TIlE
MEDLEY PARM SUPERFUND SITE
PROPOSED PLAN PUBLIC MEETING
,1tO 57'4 ~
~. ~,s.
~ ft ~
~ . %
$ ~./1 ~
~~~
~~}' - ~~
4If( PAO't.C,
TUESDAY, PEBRUARY 12, 1991
'7:00 PH
-------
Approximate Farm
Property Boundary
USGS'Pacolet Mills Quadrangle
Scale 1:24.000
-------
U88 I M.'~~,"U b~"~UU~& .u~
. . Jon Bornhol.
. 30-110,,-'0
r"ua-v.......... ......... . ............. ......, ...
let Plannln9 + Related Info Deleted
Schedule Pile I RI-PSNTa
, 11-
I PS SUllllAAY
III U.oII'I'
Duft III lIeport
lIe"lev Draft III Report
lIe"l.e III lIeport
Re"lev lIe"l.ed III lIep>rt
Appro"e Pinal RI Re~rt
P8 "1.011'1'
Draft P8 "eport
"e"lev Draft 'P8 Report
lIevl.e '8 lIeport
Re"lev "evl.ed PS Report
Approve 'Inal PS Report
'RI'S lIeport. to All Repoe1tory
Prepare Public Neetln9 IIotlce
publleh Public Meetln9 IIotlce
Prepare Prop. Plen 'act She.t
'rop. 'lan Pact Sheet I..ued
Public Coaaent Period
Public ....Un9
Ind of Public Coaaent Period
lIe.pon.lvene.. Suaeery
Draft lIecord of Decl.lon
IPA lIev lev IIOD
8tate Concur. Letter Received
ROD 811J118ture
ROD to ""In. Record
Clo.e out IIork A8.I~n8&nt
nlJlDIAL DISIGII SUIOIARY
lID ll1GOrIA'I'10N8
IIotU, DOJ of "'gotbtton.
Draft CD to IPA HO, DOJ
"0 Special IIotlce Ltr to PIIP.
lID IIoratorl-
Good 'alth Offer lIecelved
CD "'90UaUon.
lad lID IIoratorl_/Sl9n CD
81vned CD IIouted to 00.;
CD Reviewed bJ DOJ
CD Lodged vlth Court
Public Coaaent Period
".pon.lvene.a Suaeec,
CD Intered br Court
. PIIOJ8C'1' PLUIIIIIO
. COIDIUIIln ULA'I'IOU
IIIIIIIDIAL DISIGII
Draft 301 o.e1gn
301 0..19n 8ubel..lon
lIe"lev 301 0..19n
Draft lOt 0..19n
101 0..19n Bubel..lon
lIe"lev 101 o..lgn
Dreft '01 0..19n
'01 o.e19n Bubel.elon
lIe"lev '01 0..19n
Dreft Pinal 08.19"
Pinel 0..19n 8ubele.lon
tt.............. .."'.., "'fII'nn
Start
DIIte
End
Date
3-AU9-'0 25-118,-'1
3-Au9-'0 21-Nar-'1
3-Au9-'0 30-110,,-'0
l-Dec-'O 22-Jan-'1
23-Jan-'1 15-'eb-'1
ll-'eb-'l 17-Nar-'1
27-Nar-11 27-Nar-11
3-18p-IO 25-118,-11
3-8ep-IO 31-Dec-IO
I-Jan-II 5-'eb-ll
I-'eb-II 21-'eb-ll
I-Nar-Il I.-Nar-'l
21-Nar-11 21-Nar-ll
I-'eb-'I I-'eb-II
21-Nar-11 II-Apr-II
10-'eb-11 10-Peb-11
21-Jan-'1 '-Peb-'l
'-peb-'1 '-peb-'l
13-'eb-ll I.-Nar-II
12-Peb-11 12-Peb-'1
15-Nar-11 15-Nar-11
15-Nar-11 21-Nar-11
21-Jen-ll 21-Nar-'1
22-Nar-11 2'-Nar-'1
2'-Nar-'1 2'-Nar-'1
27-Nar-11 27-Nar-'1
27-Nar-ll 27-Nar-'1
27-Nar-11 25-118,-'1
21-Jan-'1 '-peb-'J
21-Jen-'1 17-118,-'2
21-Jen-'1 I-peb-'I
27-Nar-11 '-Apr-'l
17-Apr-11 l7-Apr-'1
'-Jun-II '-AU9-'1
I-Au9-11 I-Au9-'1
I-Au9-'1 I-Oct-'I
7-Oct-'1 7-Oct-'1
7-Oct-'1 20-Oct-11
21-Oct-11 ll-Nar-'2
1'-Nar-12 1'-Nar-'2
1'-Nar-'2 17-Apr-'2
II-Apr-'2 17-118,-'2
11-118,-'2 11-118,-'2
I-Au9-11 15-118,-'2
I-Aug-II l-Dec-'I
11-118,-'2 '-'eb-'J
11-118,-'2 12-Sep-'2
IJ-lep-12 IJ-8ep-'2
IJ-8ep-'2 12-Oct-'2
IJ-8ep-'2 12-Oct-'2
IJ-Oct-'2 IJ-Oct-'2
IJ-Oct-'2 11-110,,-'2
IJ-Oct-'2 Il-lIov-'2
12-110,,-'2 12-110,,-'2
12-1IoY-12 ll-Dec-'2
12-Dec-'2 10-Jan-'J
Il-Jan-'J II-Jen-']
11-,'''"-.' '-'eb-'Il
90 91
o.c Jan Feb Nar Apr lIa, Jun
I III III
...........................
...................
.
.1....~..=ill: : : :
. . UUU. . .
....i...i...i...:i...i...:
......
......
.IUI
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..
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Jul AU9
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Sep Oc t Nov
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92
Dee Jan Peb Mar
I I 1 1
Apr May Jun
1 I I
J". AUe) Sep
1 1 I
Oc t Moy Dee:
1 1 I
. . .
...
..
11111
. . .
. II
. II .
UIIUIII .
II.
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1111111111111111111111 .
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. II .
-------
REMEDIAL IRVBSTIG. ~~ ~ION FIHDIMGS
.
SOIL.!; IN TIlE IIIIIBDIATE VICIMITY OP DISPOSAL AREAS ARB
COR'l'AIIIRATBD wlm VOCs ARD SVOCs
.
GROURDWATBR 1M BOTH TIlE SAPROLITB ARD BBDROCK BBRBATII ARD
DOWNGRADIBR'l' OF '1'HB SIft ARB CORTAMIRATED WITH VOCs
.
IMORGAltICS (IIBTALS) DO MOT POSB A RISK
.
GROURDWATBR IS IIOVIRG IR A SOU'rlll5AS'HRLY DIRECTION ARD TIlE
SPROUSB WELL IS HYDRAULICALLY UPGRADIBRT OF TIIB SITE
.
MO CORTAMIRAIft'S JlAVE BBBN DB'.rBC'l'BD 1M JORS CRBBK
-------
-------
\VVW^i
-:&» e -g
'^^^^•..^''SS:
i>4rS^
f/it/tO t/H/tO IP/ISA I
M It
Cklorofon
Cklorld
TotracbloroatlMM
(rloklorootkWM
1-TrlokloroaUiaM 110 270 110
^**V • '•^X " ' ff 111- I'tll X N. \ *H>' V •* ' ^^^ *^,
fe~^*iTffl3L>\>V?\ ~-i!U -^.v;
^g^iC^te^"—
(rt|
••prollt* ••!!
••drook *•!! {••}
**••••
Conoantrktlona ihoMn «r« la
ug/1 (Blorogr**a/ltt*r|
Datsa •••pica »«r«
coll«otad !• alBO provided.
*•••*•
•CALt
COMTAMIMATIOH IN THB BEDROCK PORTION OP TOR AQUIFER
-------
CHEMICALS DETECTED IN SURFACE SOIL
MEDLEY FARM SrTE
Chemical
~pl8til. Or9anlc ComDOunds(a)
*1,1,2- Trichloro8th8ne
*1,1,2.2- Tetrachloroethane
*1,2-D1chIor0eth8ne (total)
*1,2-Dichloropropane
ChIorob8nz8ne
, Chloroform
*Ethytb8nz8n8
*M8thyfene Chloride
*Styrene
*T8trachloro8th8ne
Toluene
*Trtchlor08th8n8
*Vinyl Chloride
Frequency
of Detection.
Range of .
Detected Concentrations luaJka}(C)
2/'3
2/13
81'3
1/13
1/13
1/13
2/13
11'13
2/13
41'3
1/13
41'3
4113
11~180
85-81
4-200
21
3
3
7-33
2-23
3-11
we
1
7-70
25-210
Semi-Volatile Oraanic ComDOunds(b)
1,2-Dlchlor0b8nz8n8
*1.2.4- Trlchlarob8nz8ne
2-Methyinaphth8Jene
*ButylbenzylphthaJate
*Di-n-butylphthalate
*DI-n-octylphthalate
Dlethylphthalate
*bis(2-Ethyfhexyl)phthalate
PesticideslPCB
*Toxaphene
*PCB-'254
2/15
4115
2/15
5115
4115
4115
1/15
8115
1~200
81~1200
1e180
1e1100
71-1100
3800-5400
110
82-33.000
2/13
3/13
~(d)
200-1900
* Chemical of potential concern
(I)yolatile organic compounds and pestlcide8/PCB are ba88d on data from the following
samples: HA-1 ttvu HA-12. and HA-6-A.
(b)S8mi-volatl1e organic compounds are bas8d on data from the following sample.: HA-1
thru HA-12. HA~ HA-1e, 8nd HA-16-A.
(c)'fh8 range of d8t8d8d concentratlonalnclud8 88tImat8d r88UII8 (ch8mICaI concentrations
I8sa than the contract-required quanttation hit).
(d)Duplicate umpl88 taken at I8m8 location.
-------
CHEMICALS DETECTED IN GROUND WATER. BEDROCK WELLS
MEDLEY FARM SITE
Range of
~ ed Concentrations u (a)
Ie
*1.1-DIchIoroethene 8115 2.2-440
1.1-DIchIor.:»ethane 2115 2-3
*1.1.1- Trlchforoethane 9/15 4-310
*1.1.2- Trk:hloroethane 1/15 3
*1.2-D~\)8th8n8 5115 12-290
1.2-DlchIoroethene (total) 2115 2-17
*2-Butanone 4/15 8.8-13
* Acetone 3115 1-18
* Benzene 1/15 11
Carbon Dlsulftde 1/15 4
Chiorobenzene 1/15 1
*ChIoroform 6115 4-7
Chloromethane 1/15 2
*Methylene ChlorIde 3115 48-110
*Tetrachloroethene 5115 8-230
Toluene 2115 3-5
*TrIchIoroethene 5115 10-720
None detected
. Chemical of pot..,.. concern
(I)eetected ,~atIons Include estimated results (chemical concentrations less than the
contract-lequlred quantltatlon limit).
-------
PINDINGS OP THE RISK ASSESSMENT (BASELINE CONDITIONS)
. RO PRESBft SIGRIPICART CARCINOGENIC RISK DUB '1'0 EXPOSURE '1'0.
SIft-RBLA'l'BD CBBMICALS AT '.nIB SITE THROUGH ANY OP TIlE
BRVIROIDIBIft'AL IIBDIA
.
PRBLIIllRARY ASSESSIIBIft SROIIS 'l'HBRE IS .0 POTBIft'IAL POR .
SIGHIPICART RISK TO WILDLIPE POPULATIORS
.
PRPs REED m RE-EVALUATE '.nIB ~1rJ."uKB RISK SCENARIO POR HtJMAIf
CONSUllPTIOIi OP COIft'AlllRAUD GROUND1IAUR
-------
OVERVIEW OP TIIB. PBASIBILIft SlrJ."uuY
POTBRTIAL GROtnmWATBR PRMRDXATION 'l'BCBROLOGIBS
mmwATBR HE WRY
EXTRACTION 1fRT.T~
SUBSURFACB DRAIN ARD IRTBRCBPTIOH TRBRCBBS
AL'l'BRRATIVB CORCBlRRATIOH LDIITS
TREATKBBT P
AIR STRIPPIRG
GRARULAR ACTIVATED CARBON
CHldfTCAL OXIDATIOH (UV-oZORB)
BIOLOGICAL '.1'REATIIERT
LARD '.1'REATIIERT
~'I" .
~R
DI CHARGE P '!'ED GROtJRDWA'l'BR
StJRPACB WATER DISCHARGE
GAPPRBY PUBLICLY OWHBD TREATJIBRT WORKS
. BORIZOftAL IRRIGATIOR
IRJBC':rIOH 1fRT.T~
-------
. ............. ~...,
GROUND WATER CONTROL
TECHNOLOGY SUMMARY
TECHNOLOGY
STATUS
GROUNDWATER RECOVERY
EXTRACTION WEu.5
SUBSURFACE DRAINSI
INTERCEPTION TRENCHES
ACls
NOAC~
RETAINED
REJECTED
REJECTED
RETAINED
3ROUNDWATER mEATMENT
ACTIVATED CARBON ADSORPTION
CHEMICAL OXIDATION
BiOlOGICAL SYSTEM
AIR STRIPPING
lAND APPliCATION
RETAINED
RETAINED
REJECTED
RETAINED
REJECTED
3ROUNDWATER DlSCHA~GE
SURFACE WATER (JONES CREEK)
GAFFNEY POlW
f.jFLTRATION GALLERY
INJECTION well
RETAINED
REJECTED
RETAINED
RETAINED
REASON
CANNOT BE INSTAllED AT DEPTH IN BEDROCK
SITE CONDITIONS NOT APPROPRIATE
CI-LORINATED VOCS RESISTANT TO BIODEGRADATION
RESISTANT COMPOUNDS, SEASOt~Al USE
DISTANCE TO SERVICE
PROVISIONAllY DEPENDING ON APPliCATION RATES
PROVISIONAllY DEPENDING ON APPliCATION RATES
,.'
-------
ALTBRllATIVB
GWC-I
A
B
GIfC-2
A
B
C
GWC-3
A
B
C
SC-l
SC-2
~,..-"t
POrslft'IAL RBIIBDIAL ALTERRA'l'IVBS
DBSCRIPTION
GROmmwATBR COIft'ROL
RO AC'rION
80 ADDI'l'IORAL AC'rIVI'l'IBS
I8S'lITU'rs LONG-'l'BRII GROORD1lA'l'BR IIORI'l'ORING
RECOVERY OP .ALL GROURDIIA'l'BR ABOVE IlAXIIIOM
CONCBII'.rRA'l'IOR LBVBLS
TRBATIIBIft USIRG AIR STRIPPIRG
'.rRBATIIBR'l' USING CARBOR ADSORPTION
TRBA'l'IIBR'l' USING CBBIIICAL OXIDATION
RECOVERY OP .ALL GROURDWA'l'BR 'l'IIA'l' COULD BXCBBD Hel.s A'l'
TIIB PROPBRTY LIRE
TRBATllBtrl USIRG AIR SftIPPIRG
TRBATIIBtr.r USIRG CARBOR ADSO~IOR
'l'RBA~ USING ~MICAL OXIDATION
SOURCB COIft'ROL
RO AC'l'IOR
CAPPIRG SOURCB AREA
~nTT. VAPOR RX'l'RACTIOR IN ARRAS EXCEBDING CALCULATED
-------
ALURllA.TIVB
GWC-lA
GIfC-IB
GIIC-2A
GIIC-3A
SC-l
SC-2
SC-3
PRESENT ~
$100,000
UTAIHED ALURRATIVBS FOR DETAILED ANALYSIS
DESCRIP'l'IOR
RO ACTIOR FOR GROORDWATBR
RO ACTIOR; LORG-BRII IIORI'l'ORIRG
IICLs ACROSS SIB; AIR STRIPPING
IfCLs AT PROPBRTY LIRE J AIR S'l'RIPPIRG
80 ACTIOR FOR, SOURCE COR'l'ROL
CAP SOURCE ARBA
SOIL VAPOR ~IOR
$440,000
$1,600,000
$1,300,000
$100,000
$810,000 .
. $620,000
-------
1 4. ,\~ ~ " : , " - - - - - - - , , " " , \\ ....... \
'" \ -'-'-- \\ \ DRAFT
" " -"',' \
'~" "~, SW 3 ", \ \' \ \ \ \ "'-..
>\. " '\. ..... ...~, \..." \ \ " "
..A.,~" \:JP. \ " ... \ , \
" \ " \ \ , \
'- ,," \ ' \ \ \ '
\ ' \, \
l " \ '\ , ,
RA 2 " " \ '. \. '. \ .
" ' \ ~ ' \ '
,,' '. \ \ \ ,
" " \ \ \ " "
, " " " \ \ " ... "
" ,'" \ " , "
" 1-' '\" " ...
5B 1 0 ", >' \ \ " ",
))--, 0 {}7TP "~~" \'.\ ''.\ ~(\ \'.. "'"
" ' , '. \ v. \ '
, '" 0 "
" 1 3" \ , "...
"--------- ' \ , '
...., '\. \ \'"
'.. " , . , 6
.. . '.... B 4 :\ , .
~ --" )0. I \ \
..., '.... ~ I ...
"T -' ~' "
) TP 1 5 R" RA-3" ,\ ,
MD 2i ~ ------- ,/' \\ TP 2 \ '
't5.~J!,H~C WE r- S TP ~,SB 5t- /
: SW 4 TP 7 BW ?\\ :'
I S \\ I
~ ~ ,--660----- -- - --"'-.. fj \~\ Q
! TP 6~,'<' TP 1 0 1) "f::::i-"-~\~,'5B
: 5B 6: TP 1 1 \\
. 0,' \ \
: I' \ \
\ ,.. 58 8 \\
'Wi EXCEEDS SUBSUI~F ACE LEVELS FOR VOCS
~(I' 1<'0' I: ,\
--r---- -r'-- ----.
,
"
,
,
,
I
,
,
I
I
,
,
t
~"
.
I
I
I
,
I
TP 8'/
,
I
I
,
I
I
I
I
,
I
,
I
I
I
I
I
III~BJ~~
kt:..CONSULTANTS
.
FIGURE 4.2
APPROXIMATr EXTENT OF
SOURCE AREAj EXCEEDING
CALCULATED SOf.L REMEDIATION
LEV~LS
MEDLEY FARM SITE
G..tnvillt, Soulh Corollno
-------
1--
FOR l"'UK'.rI1AK DIPORJlATIOR ABOUT 'l'IIIS SITE
1Ir. Jon It. aornhola
lte8eCUal Project KaDager
o. S. BnviroII88ntal
Protection Agency
Reqion IV
345 CourtlaDd Street, HB
Atlanta, Georgia 30365
(404) 347-7791
1Ir. Chuck Pietro8evicz
Agency of Tonc Substance8 ~
Disease Registry Liaison
O.S. EnviroD818ntal
Protection Agency
Reqion IV
345 CourtlaDd Street, RB
Atlanta, Georgia 30365
(404) 347-1586
lIB. Deni.se Bland
Technical Assi8tance
Grants Coordinator
u. S . Envirollll8l1tal
Protection Agency
Reqion IV
345 Courtland Street, RB
Atlanta, Georgia 30365
(404)347-2234
lIB. Cynthia Peurifoy
Community Relations
Coordinator
o. S. Environmental
Protection Agency
Reqion IV .
345 Courtland Street, D
Atlanta, Georgia 30365
(40~) 347-7791
I
1Ir. Richard Baynes
State of South Carolina
DepartlleDt Health and
!I'.:r.rL.-o~21 Conucl
2600 Bull Street
Col1lllbia, SOUth Carolina
(803) 734-5200
1Ir. Keith T.fndler
State of South Carolina
Depart8ent Health and
Bnvirollll8ntal Control
2600 Bull Street
Col1lllbia, South Carolina
(803) 734-5200
JIr. TbaiI 8erz:y
Director, Divi8ion of
Jled.ia_Relations
State of South Carolina
Depart8ent Bealth and .
Bnviroll8BDtal Control
2600 Bull Street
Col1lllbia, South Carolina
(803) 734-5038
29201
29201
29201
-------
ATTACHMENT C - ATTENDANCE LIST
-------
APPENDIX C:
LIST OF MEETING ATTENDEES
~
Doug Blanstt
Cody Sossaman
T. Pierre
T. Valerio
Jim Chamness
Fred Spencer
Phil Sarata
Matt Stahl
Scott T. Peeler
Jimmie G. Peeler
Ed Gregory
Evelin Henderson
Mark Henderson
Angela Gorman
Richard Haynes
Yanging Mo
Address
SCDHEC, Div. of Health and Hazard Evaluation
Columbia, SC 29201
Gaffney Ledger
Gaffney, SC
WYFF-TV 4N/A
National Starch and Chemical Co.
10 Finderne Avenue
Bridgewater, NJ 08807
Sirrine Environmental
P.O. Box 24
Greenville, SC 29687
Gaffney, SCN/A
WAGI-FM
Gaffney, SC
2.9340
Spartanburg Herald-Journal
313 1/2 N. Limestone St.
G~ffney, SC 29240
SCDHEC, Div. of Health and Hazard Evaluation
Columbia, SC 29201
WSPA Radio
WSPA Radio
SCDHEC, Div. of Health and Hazard Evaluation
Columbia, SC 29201
SCDHEC, Div. of Health and Hazard Evaluation
Columbia, SC 29201
SCDHEC, Div. of Health and Hazard Evaluation
Columbia, SC 29201
Note:
None of the meeting attendees requested to be added to
the m~iling list.
-------
ATTACHMENT D - COPY OF PUBLIC NOTICES
-------
?ub1ished GREENVILLE NEWS, Sunday 2/10/91
-I
THE U.s. ENVIRONMENTAL PROTECTION AGENCY
INVITES PUBUC COMMENT ON
THE ADMINISTRATIVE RECORD AND PAOSPOSED PlAN FOR THE
MEDLEY FARM SUPERFUND SITE
IN CHEROKEE COUNTY, SOUTH CAROLINA
TU88d8y, FebN8Iy '2, '"' .. 7:00 p.m.
Gatfn8y Hiett Schoot Caf8e8n8
(803) 488-2544
~ .......
The u.s. EnYJrOllIft8ftt8l Prot8CllOn A98nCY (EPA) WIll IIOICI . DUDlIC "'888n9 on T-
08¥ Fetlruary 12. 1981.81 7:00 o.m. In - GafIn8¥ Higfl SdIooI C8IWWI&.. 805 E. F~
.,0 sn.. Gann." Sou1l'l ':aroIin& The DUrP088 Of - "'888n9 WIll 118 ID 0I8Cu8 -
PrQClCl880 "-iaI Ac1Ion Plan .nctudin9 - ~ acaon 8It8rn8IIW CI889Md ID
80<1- contamm8tIan . - MedI8Y Farm &,perfUnCI SIte. 0Ih8r CI8MuO 8II8m8Iiw8
..1\Id\ -- 8W8IIa8I8G In - ~ Stuo, (FS) wlllIIO 118......0. TheIl'lllllC.-
COUr8g811 to 8ft8nG. .. ~ and aft8r CO.MI8"."IN ~
The M8GI8¥ Farm SuperfUncI SIt8 00CUpI88 . 7_nct" lend Off HigfIw8\I 72. 8Dout
8 l11li88 ~ Of IN City Of Gaftn8,. Dunn9 ... period tram 1813 10 1878. ....., P8W4.
ana dI8mtc8I III8IIUf8c:IuIt .- ... cII8poaed Of on IN ....., Farm ... In May
1983. EPA condudl8d ~ . IN SIt8 ana ~Io.... en -~q ..-- 8CIIon
in ... "*-'9 rnontft. AIIIIr ~all"a . witft EPA. live 01 .. o)Co"',"" 188DOIWiitIIIt
P8I'1I88 (""P8) 80l'88Il to fIIncI ana eMfY out the A8nI8dI8IIm. II. ;~ Fe88IIIIIIy. Study
(FlIIFS) Iar IN SIt8. The draft FI1 - ",,_.IM to EPA In M8rct11880. ana .. SIt8-
DI8C8d on IN N8IIon8I PrIontI8a LiII (Nfl\,) tor . ~ d88nuo. .... on IN I'll
IIndtnga. IN EPA h_......o nine ...'-- toI .ddI...", grouncIW8W ana--
cont8nWl8llon .. IN SIIa.
"...... ..........
The cnfWNd ....., .A.- toI CI88IUP IIMIIII88:
. "-y Of eI ground ... trIIII exC88d8 --..m 001-.""" ..... ana
IrW8IIn8 1M GW8CI8d ground .... prtCIf to dI8cII8I8I1118 to Jon8 CI8k IIn:Iugft
811 - .... 8ower; ana
.8011 veoor 8odJ"".1n _..~111I118 ('81011'''' 8011.~ t...:..... ft--
... Of _-........ In .. ...... .. - 8bOIII8 -- 8IIOW8d Dr .... ..
CI88'I1W Act ent4/01 .. ... C8ratIn8 PaIutIon eon.at Act. lien .. .....,
V8IIOI8 .. tie P888d 8InIugII en.8CtI¥888d C8I'tIOft unII prtCIf to II8In8 ,....., to
1rI8en...,..-1IL
0lIl8' Ma....A.-'
0Ih8r ........ .... ...AI.- unoar 001 1111 .,8IlOl. IncIudIr:
. No 8CIIon
. T~ 01 ground ...., UIIng carbon r ,AIOI\
. T~ Of.,........ UIing CIWNC8 0XId8II0n
. T~ Of ground .... . III'OII8ftY 11M UIIng .. - .... ~ II888d
.....
.~..---
'"- "'.148- - .......64"" In" Fa.
IIUII88 c-.I.....
EP~ ....., -- . ... IIUIIIC --- period. tram FeOru8'y 13 to M8n:fI
t.. 1181, duItng wNaft 8nI8.. DUOIIC IaInwMll to,.,... ana -"'*" on" Admift8.
-- "-'I. IncIucIIng .. "...., Plan. I'll. ent4 FS I'8OOItL S8I8ctIon 01 ... final
~.. be II18II8.,.., COI~8IIQ.. oIellIUIIIC -.-.. on.. FlI/FS ana IN
PI'apoeed Plan. ana .. be iIooIlJ_.-s In .. A8con8 of D8cI8Ion tor.. SIt8.
to... 11 -U - ~
The AdnIiI..... --... IncIucIIng .. "...., Plan ana FlI/FS ~ 18
....... toIlIUIIIC ..... .. "1oIOIIIng Ioc8IIon:
...-....... u...,
.......... ....
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......... 01 -- ........... 01 -- -- ...... to ... SIt8 c:I88IuOo -- nI8iI
,our ..... 00IJU1Ii8ij~ -=
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(")M7.7711 .
Mr. IomtIotIn ,..., 8180 be COM.,IM lor fWth8r IIItonn8IIon 8bout IN SIt8. 01 far
~~ "IIUOIIcIll88llng801~toI~QUf\ L..IT'r
ORIGINAL
-------
~ ~'f\'n\lJillt News
-~':;~'10.~'?"'..L.'- -
.~..;.:,._-
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Tuesda . March 'i 9, 1991 7 : I
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UU.. 80.11" LIw tft w;tft ..~ 8f\tltmIX\. . C
t'nt'~.:['~..1 ~~~~~~~~ I... -'" '---
I
LEGAL NOTICES
TIW _Ie - _loCI -
- ..- fIIr ~ -lanai '
1hI"" Clan and will... an AIWII
111"1.
TIW "'- Plan ouIIl-
EPA',,,,,-,,,, decn8..-
thlt tar tbt II'" CD ..., CD -
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exC88dinll CIIIcu'- lOll .......
atlan I8v8IL II ...... III CDI1IanII-
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--.......".l1II8rtbt
C- AIr Act -''''' tbt SauIII
Carolina PalMian Cant"" Act.
tbt Ixtr'CICI'Id .--. will III
- IIw'auIII an actI- QIII'.
ban unit _III DIIr8 - to
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T1II - Farm -fund
SIII_a_acro rractaf
land all Hi8IIwaY 12. - ...
mUa - at tbt ClIY III Gattnn.
~~~"::~:.!
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_afan..._Fannsl...
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U.S. !...._.....nI\oI ~
--..
-'-- iIIIWI. II.!.
THE U.S. ENVIRONMENTAL
PROTECT 1011 AGENCY
ANNOUNaS EXTENSION OF
THE PUILIC COMMENT
PERIOD ON THE "RePOSED
P'LANANOADMIIIISTUTIVE
IIECtlItD FOil THE
MEDLEY FARM
SUPERFUND SITE
IIICH!IIOKIECOUIITl'
SOUTH CAIIOLINA AIIanIII. GA"
T1II U.s. EIIY"- ",-. C.., JO.mc
1Ioft~1IaI_"- wrtll8n - ..- III
1IC__..1118"", --- no........ ....1111
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.. ~ Il8Cllnltar... 1acI8d.. 1118 - - I8r
- Farm '-- sII8 In -lnI8rmaII8IIe.II'" sII8.
a.r.. CaunIY. SIuIII Caratlna. ......
.
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CALL 2Jl.7116. -, yr. alii. .,IM.
FOUND:CGOw-.GE- FOUND: ~ , . 2 yn. aid I
..-. Catl to lOIntity. DoW63I 01 mall - cat 1ft Su8ar Cr"" ,
2...-.-. II.CatI- .
OOR QUAL
ORIGINAl
-------
ATTACHMENT E - WRITTEN COMMENTS RECEIVED BY EPA
-------
KING & SPALDING
191 PEACHTREE STREET
ATLASL\.. GEORGIA
30303.1763
404/~72'-4600
TELEX: ~4'2IH7 KINGSP.'I.LD ATL
TELECOPIER: 404/~72.~100
1730 PESSSYLV"~SIA AVESl:E. s.w.
WASHISGTOS. DC 20006
TELEPHOSE: 202/737-0~00
TELECOP1ER: 202/626-3737
April 12, 1991
74~ FIFTH AVESl:E
SEW YORK. Sy 101~1
TELEPHOSE: 212/7~8-8700
TELECOPIER: 212/~93-3673
VIA HAND DELIVERY
Re:
Medley Farm Site
Mr. Jon K. Bornholm
Remedial Project Manager
United States Environmental
Protection Agency, Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Dear Mr. Bornholm:
I am writing on behalf of the Medley Farm Site Steering
Committee. In accordance with the National Contingency Plan, the
Steering Committee hereby submits comments on the Environmental
Protection Agency's ("EPA") proposed plan for remedial action at
the Medley Farm Site ("the Proposed Plan").
The Proposed Plan calls for:
°recovery and treatment of groundwater that exceeds
maximum contaminant levels at the Site; and
°soil vapor extraction to remove residual source
contamination.
. EPA has concluded that the low levels of contamination
remaining in the soils at the Site pose no significant risk to
human health and the environment. Nonetheless EPA has proposed
that the soils be remediated through soil vapor extraction (SVE)
to speed and enhance the groundwater remediation at the Site. The
Steering Committee and its consultant, Sirrine Environmental
Consultants, do not agree that soil remediation should be required
in addition to direct groundwater remediation.
Almost all soil contamination was removed in the emergency
removal action in 1983. The residual soil contamination remaining
at the Site will naturally flush through and be captured by the
-------
Mr. Jon K. Bornholm
April 12, 1991
Page 2
groundwater recovery and treatment system ~ith no significant
impact on the operational life of that system. Groundwater
remediation alone will result in a permanent reduction of Site
contaminants. The proposed soil vapor extraction remedy would,
therefore, add to the cost of remediation at the Site without
appreciably reducing the potential risks posed by the Site or the
length of time for full remediation to eliminate those potential
risks.
The Steering Committee believes that soil vapor extraction
should be eliminated from the plan for remedial action. We
propose that EPA instead select natural flushing combined with
groundwater recovery and treatment as the remedy for the Site.
The effectiveness of this remedy will be reviewed after five years
of implementation. The impact of natural flushing on the
groundwater remediation can be evaluated more effectively at that
time. At this point, the estimated impact is not significant
enough to require a source control remedy such as soil vapor
extraction.
The Steering Committee's position and alternative proposal
are discussed more fully in the attached comments. The Steering
Committee and Sirrine are available to answer any questions you
might have.
Sincerely,
Yl!~~~2Ld)~
MJN: lwb
Attachment
cc: Elaine Levine (w/attachment)
Keith Lindler (w/attachment)
Jim Cloonan (w/attachment)
Jim Chamness (w/attachment)
Medley Farm Site Steering Committee
(w/attachment)
-------
COMMENTS ON PROPOSED PLAN
FOR REMEDIAL ACTION AT THE
MEDLEY FARM SITE
APRIL 12, 1991
SUBMITTED
BY
THE MEDLEY FARM SITE STEERING COMMITTEE
-------
BACKGROUND
The U.S. Environmental Protection Agency (EPA) released a proposed
plan for remediation of the Medley Farm Site ("Site") in Gaffney,
South Carolina on February 7, 1991.
The preferred remedy
involves:
Treatment Usinq Air Striopinq:
Recovery of all ground water
above maximum contaminant levels ("MCLs") and treating the
extracted ground water prior to discharging to Jones Creek
through an air stripping tower (Alternative GWC-2A); and
Soil Vapor Extraction:
Soil vapor extraction in areas
exceeding calculated soil remediation levels.
If necessary
to comply with applicable portions of the Clean Air Act and
the South Carolina Pollution Control Act, the extracted
vapors will be controlled using an activated carbon unit
(Alternative SC-3).
The Medley Farm Site Steering Committee ("the Steering Committee")
represents the parties who agreed under an Administrative Order by
Consent to perform the Remedial Investigation/Feasibility Study
("RI/FS") for the Site.
Sirrine Environmental Consultants
("Sirrine") served as the Steering Conunittee's consultant for
performance of the RI/FS.
The Steering Committee and Sirrine have
reviewed the proposed plan.
The Steering Committee hereby submits
comments on the plan and requests consideration of changes in the
plan based on these comments.
-------
Specifically, the Steering Committee and Sirrine believe that
active remediation of Site soils is not necessary or cost-
effective.
The rationale for their disagreement with the proposed
plan and a proposed alternative are set forth below.
OBJECTION TO REMEDY:
NECESSITY OF SOURCE CONTROL
The great majority of chemical residuals at the Site were removed
during the immediate removal action in 1983.
Remaining
contaminants in soils consist of low levels (generally less than 1
mg/kg) of primarily volatile organic compounds (VOCS);
The
baseline risk assessment determined that Site soils do not pose. a
significant risk to human health or the environment through a
direct pathway.
The only risk posed by Site soils is the indirect risk that occurs
through the leaching of VOCs from certain areas of soils into
groundwater.
As rainwater infiltrates the soils, the VOCs are
naturally flushed in the groundwater (Alternative SC-1).
VOCs in
groundwater can then be recovered using extraction wells and
treated (Alternative GWC-2A).
Consequently, when the groundwater
extraction system is operational, site soils will no longer pose a
risk to potential receptors either directly or indirectly.
Remediation of Site soils is not necessary to protect human health
or the environment from direct or indirect risks.
All Site soils
are less than the TSCA remediation level of 10 mg/kg for PCBs, the
- 2 -
-------
only identified ARAR for Site soils.
Therefore, remediation of
Site soils is not necessary for compliance with ARARs.
Natural
flushing (Alternative SC-l) satisfies the threshold criteria given
by the National Contingency Plan ("NCP") for Protection of Human
Health and the Environment and Compliance with ARARs.
Natural
flushing is therefore a protective alternative that is eligible
for selection as a source control remedy.
Once the threshold criteria are satisfied, selection of a source
control remedy must be determined from among the NCP's primary
balancing criteria. Although the removal of VOCs from Site soils
might be accelerated through soil vapor extraction (SVE;
Alternative SC-3), the efficacy of SVE depends on whether it would
decrease the time required for overall (soils and groundwater)
Site remediation and therefore be cost effective as compared to
pump-and-treat alone (i.e., natural flushing).
The primary balancing criteria are:
o
long-term effectiveness and permanence
o
reduction of toxicity, mobility and volume
o
short-term effectiveness
o
implementability
o
cost
Evaluation of source control measures must be considered in the
context of the overall Site remedy, including groundwater
extraction and treatment.
In this perspective, natural flushing
- 3 -
-------
rates favorably within the balancing criteria.
Natural flushing
would effect a permanent reduction in the volume of VOCs in soils.
These VOCs would then be recovered by the groundwater extraction
system and treated, resulting in a net reduction in the toxicity
and volume of Site VOCs.
Natural flushing can be readily
implemented and would pose no risks to the community or the
environment during implementation.
As discussed below, natural
flushing is more cost effective than soil vapor extraction
(Alternative SC-3).
Alternative SC-l therefore achieves the best
aggregate agreement with the primary balancing criteria from among
the source control alternatives.
ESTIMATED DURATION OF GROUNDWATER EXTRACTION:
CASE HISTORIES
Given that soils do not pose a significant risk at the Site, the
only reason for source control is if it would accelerate the
overall remediation of the Site.
The Committee and Sirrine do not
believe that a source measure, such as SVE, will effect a
significant reduction in the time required to achieve remediation
levels in groundwater.
A number of recent EPA publications describing actual groundwater
remediation experiences indicate that remediation levels would not
be achieved long after theoretical models had predicted site
restoration.
A sampling of EPA documents describing the
protracted periods for groundwater remediation include:
- 4 -
-------
o
. U.S. EPA Evaluation of Groundwater Extraction Remedies.
Office of Solid Waste and Emergency Response; EPA/504/
0289/054; Washington, DC, 1989. .
o
U.S. EPA. 1989.
Consideration in Ground Water
Remediation at Superfund Sites.
Memorandum from
Jonathan Cannon to EPA Regional Offices, Directive
No. 9355-4-03, Office of Solid Waste and Emergency
Response 1989.
o
U.S. EPA.
1990.
Evaluation of Ground Water Extraction
Remedies, v. 2, Case Studies, EPA/540/2-89/054.
o
U.S. EPA.
1989.
Ground Water Issue, Performance
Evaluation of Pump-and-treat Remediations.
Office of
Research and Development.
o
Hall, C.W., "Limiting Factors in Ground Water
Remediation", 20th Annual Conference on Environmental
Law, March 1991, Keystone, Co. [NOTE: C.W. Hall is
Director of EPA's Robert S. Kerr Environmental Research
Labora tory. ]
A review of EPA and other technical publications on groundwater
remediation has concluded that restoration to MCLs is "currently
unachievable" (Travis and Doty, 1990).
The review determined that
not "a single aquifer in the United States has been confirmed to
be successfully restored through pumping and treating."
A
separate review article co-authored by EPA personnel (Haley, et
aI, 1991) identified the following impediments to achieving MCLs
in relatively short time frames:
- 5 -
-------
o
sorption of contaminants to saturated soils
o
aquifer properties, such as subsurface heterogeneity and
fractures
o
exceedingly low remediation levels
o
presence of "stagnation zones" within the groundwater
extraction system.
All of these conditions are applicable to the Site.
VOCs at the
Site have significant organic carbon/water partitioning
coefficients, indicating a tendency to sorb to soils.
The geology
consists of a low conductivity saprolite, a higher conductivity
transition zone, and fractured bedrock.
Experience at other sites
indicates that this heterogeneity will likely protract the time
required for aquifer restoration due to differing contaminant
desportion rates and discontinuities in hydraulic flow patterns.
The collective effect of these factors is to all but guarantee
that groundwater remediation at the Site may not achieve MCLs for
decades since MCLs at the Site are generally at the low parts per
billion range.
While groundwater recovery and treatment will
reduce contaminant levels significantly (90+%), MCLs will likely
not be achieved in predictable time frames with or without source
control.
Both review articles (Travis and DotYi Haley, et. al.) indicated
that:
o
plume containment and mass reduction should be primary
objectives of groundwater remediation and
- 6 -
-------
o
that restoration of a heterogeneous aquifer to MCLs is
not likely.
Numerous EPA documents based on a variety of case histories
confirm the technical realization that groundwater remediation is
apt to be a containment action that prevents migration.
Since
MCLs are not likely to be achieved with or without source control
in a predictable period of time, and since soils without treatment
present no direct risks to human health, the Steering Committee
questions the need for active source control measures at the Site.
Existing volatile organic compound (VOC) levels in groundwater are
evidence that natural flushing is occurring.
Contaminants will,
therefore, be recovered and treated by the groundwater remediation
system.
The proposed groundwater remediation system, with or
without source control, will reduce contaminant levels
significantly.
In addition, contaminants will also be contained
from migrating beyond Site boundaries and prevent any future risks
to potential downgradient receptors.
A source control remedy is
therefore not required for the remediation of Site soils.
OBJECTION TO REMEDY:
COST-EFFECTIVENESS
The cost-effectiveness of SVE can best be evaluated by comparing
its present worth costs with the additional groundwater
remediation costs associated with natural flushing.
Unsaturated
transport modeling can be used to predict the time required for
natural flushing to remediate Site soils.
A batch flushing model
can be used to estimate the groundwater remediation period
- 7 -
-------
following SVE and natural flushing.
The difference in remediatio~
periods represents the additional groundwater remediation costs
that SVE must be compared against.
Existinq Groundwater:
A batch flushing model (EPA, 1988) was used
to estimate the time required to achieve MCLs under current
'groundwater conditions.
Based on a 99.8 percent reduction of
total VOCs in groundwater, remediation of Site groundwater is
projected to take approximately 10 years assuming no flushing of
additional contaminants into the groundwater.
This time estimate
is almost certainly low, as evidenced by the previous discussion
regarding case histories and Site characteristics.
A protracted
groundwater extraction period would reduce any time and cost
savings associated with SVE.
Soil Vapor Extraction:
Remediation of Site soils to the
remediation levels given in the FS (Table 4.3) would require
approximately one year.
SVE would be conducted concurrently with
groundwater extraction.
Natural Flushinq:
Based on maximum site concentrations,
adsorption to soils, and MCL value, trichlorethene (TCE) would
determine the duration of natural flushing.
The leaching
potential of TCE can be estimated using the unsaturated transport
model presented in the FS (Appendix E).
Based on maximum soil
concentrations at the Site, TCE is projected to impact groundwater
above MCLs for approximately 20 years (see attached table).
- 8 -
-------
Therefore, the time estimate projected for groundwater remediation.
assuming natural flushing with no SVE would be approximately 20
years.
Final Groundwater Extraction with Natural Flushinq:
Groundwater
extraction would be required following completion of natural
flushing to remove residual levels of VOCs.
VOC levels after 20
years would be approximately at MCL levels (attached table),
considerably lower than for current conditions.
It is assumed
that a 50 percent reduction in VOCs would be required following
the completion of natural flushing to obtain MCLs.
Using the
batch flushing model, the additional groundwater extraction to
achieve the 50 percent reduction would require approximately one
year.
Final Groundwater Extraction with SVE:
SVE is estimated to be
completed within one year.
Groundwater remediation under current
conditions assuming no flushing of additional contaminants into
groundwater has been estimated to take 10 years.
VOC levels
remaining after SVE could not impact groundwater above MCLs.
No
further groundwater extraction past 10 years would be anticipated
if the remediation is accomplished as predicted by the
batch-flushing model.
Based on the lingering effects of residual
VOC levels in groundwater, the extraction period of 10 years is
likely an underestimate.
- 9 -
-------
Summary:
Natural flushing is projected to result in approximately
11 more years of groundwater extraction than if SVE were
conducted.
Since the model predicts that a minimum of 10 years of
groundwater extraction would be required to achieve MCLs based on
current groundwater conditions, the costs for additional
groundwater extraction required to address further leaching would
not begin until year 10.
Experience with groundwater remediation
at Superfund sites indicates that groundwater extraction and
treatment under current conditions will not likely achieve MCLs
within the 10 years projected by the model.
The difference in
groundwater extraction periods between SVE and natural flushing is
therefore likely to be an overestimate.
COST EVALUATION
The total present worth costs (PWC) for SVE (Alternative SC-3) and
annual groundwater remediation (Alternative GWC-2A) were estimated
in the FS to be:
o
SVE:
$620,000
o
Annual groundwater remediation costs:
$81,000
The present worth costs for SVE must be compared with the present
worth costs for the annualized series of groundwater remediation
costs for the additional 11 years of operation.
Calculation of
the present worth costs for the additional groundwater remediation
is a two step process:
o
Convert the annual series to one cost at year 10.
- 10 -
-------
o
Convert the cost at year 10 to a present worth basis
(year 0).
Present worth costs are evaluated at a discount rate of 5 percent,
per EPA guidance.
The calculation for the additional 11 years of
groundwater remediation is:
Groundwater remediation PWC = $81,000 (PIA, 11, 5%)(PF, 10, 5%)
= $81,000 (8.306)(0.6139)
= $410,000
COST EFFECTIVENESS DETERMINATION
The present worth costs for soil vapor extraction would be
approximately $620,000.
The present worth costs to conduct an
additional 11 years of groundwater remediation 10 years in the
future, as required for natural flushing, would be approximately
$410,000.
Natural flushing (Alternative SC-1) is therefore a more
cost effective source control remedy for the Medley Farm Site than
soil vapor extraction (Alternative SC-3).
The estimated
difference in present worth costs of approximately $210,000 is
almost certainly low since groundwater extraction at the Site will
likely require more than the estimated 10 years to achieve MCLs
with SVE.
Modeling predicts that aquifer restoration would require
approximately 21 years through natural flushing and groundwater
extraction.
Both Site soils and groundwater would be at
remediation levels at this time, thereby satisfying SARA's
preference for a permanent remedy.
The estimate of 10 years for
aquifer restoration through SVE and groundwater extraction is
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likely optimistic in light of EPA's evaluation of other
groundwater remediation projects.
The net result is that the
apparent difference of 11 years for aquifer restoration through
SVE is almost certainly overestimated and the difference in
remedial time frames will be less.
Any reduction in the
differential time for remediation would increase the
cost-effectiveness of natural flushing (Alternative SC-l).
OBJECTION TO REMEDY:
CONCLUSIONS
o
Direct remediation of Site soils (source control) is not
required because site soils do not pose a significant risk to
human health or the environment.
o
The evaluation of groundwater remediation projects by EPA and
independent authorities indicates that proJections of aquifer
restoration periods are greatly underestimated.
o
Site conditions are consistent with aquifer and contaminant
characteristics that are likely to prolong aquifer
restoration.
o
Natural flushing (Alternative SC-1) has estimated present
worth costs that are approximately $210,000 less than for SVE
(Alternative SC-3).
Because groundwater models tend to
underestimate the time for aquifer restoration, the
difference in costs is likely to be significantly higher.
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. --
I
o
Active source control is not warranted for the Site based on
risk, technical, or cost considerations.
o
Groundwater extraction alone can prevent potential future
risks, is technically justifiable based on EPA experience,
and in conjunction with natural flushing is the most cost-
effective remedy for the Site.
PROPOSED ALTERNATIVE
Knowledge of contaminant transport at the Site is based on two
sampling events conducted under passive conditions (no
remediation) and overly optimistic groundwater models.
The
Steering Committee'proposes that a remedy involving natural
flushing (Alternative SC-1) and groundwater control (Alternative
GWC-2A) be initiated at the Site.
The effects of leaching from
soils and groundwater extraction can be evaluated at the 5-year
review of remedy using results from regular monitoring events.
Projections of the impact of soils on groundwater quality and
aquifer restoration time frames can be conducted more effectively
at that time.
Should the results indicate a significant impact
from , soils and potential for achieving MCLs in groundwater, a
.
pilot-test for SVE could be conducted to assess its site-specific
effectiveness.
Full-scale SVE could be implemented once the
effectiveness was demonstrated and design parameters were
established.
This approach would be based on site-specific data
and would allow the most demonstrated approach for selection of
remedy.
Since Site contaminants have been flushing into
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groundwater for approximately 18 years, a review period of five
years should have no appreciable effect on Site conditions (any
variations in groundwater quality would be controlled by the
extraction system).
The absence of any risks to human health
further validates the appropriateness of this approach.
REFERENCES
EPA, Guidance on Remedial Actions for Groundwater at Superfund
Sites, EPA/540/G-88/003, Washington, DC, December 1988.
EPA, "Evaluation of Groundwater Extraction Remedies", EPA/504/
0289/054, Washington, DC, 1989.
Haley, J.L. et al, "Evaluating the Effectiveness of Ground Water
Extraction Systems", Ground Water Monitoring Review, Winter 1991,
pp. 119-124.
Travis, C.C. and C.B. Doty, "Can Contaminated Aquifers at
Superfund Sites Be Remediates?", Environmental Science and
Technology, Vol., 24, No. 10, 1990, pp. 1464-1466.
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ATTACHMENT F - LETTER FROM EPA TO STEERING COMMITTEE, DATED MAY 6, 1991
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTU""ID STREET'" E
ATLANTA. GEORG,A 30365
lAY ,1 mt
4WD-NsRB
Ms. Mary Jane Norville
King & Spalding
2500 Trust Company Tower
Atlanta, GA 30303
RE:
Response to Comments On the Proposed Plan for the Medley
Farm Superfund Site
Dear Ms. Norville:
The Agency received comments on the Proposed Plan from the
Potentially Responsible Parties (PRPs) on April 12, 1991. The
Agency presented the Proposed Plan to the public during a
public meeting held on February 12, 1991. This meeting
initiated the public comment period which ended on April 13,
1991, after a 30-day extension to the initial 30-day comment
period.
In the April 12 correspondence, the PRPs outline their
objections to the rationale used by EPA in selecting Soil
Vapor Extraction (SVE) as a source control remedial measure.
Their objections centered on two main points:
o
They question the necessity of source control
measures, since the Baseline Risk Assessment
indicates that Site soil contaminants do not pose
a direct risk. In addition, they point out that
recent EPA and other technical documents conclude
that the time frames for aquifer remediation are
underestLmated, and that true time frames will in
fact always exceed those made using models. The
PRPs believe that SVE will not shorten the estLmated
time required to remediate Site groundwater to MCLs.
A cost comparison between SVE with a pump-and-treat
system, and natural flushing with pump-and-treat,
led the PRPs to conclude that natural flushing was a
more cost-effective remedy.
o
The Agency agrees that the risk posed by contaminated site
soils is indirect, through leaching to the groundwater. In
selecting the proposed alternative, the Agency considered the
entire contaminated subsurface, both the saturated and
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unsaturated zones, as an integrated whole. The rationale of
this approach was to obtain cleanup goals as quickly as
technically and economically feasible.
The Agency agrees that levels of contaminants across parts of
the Site are less than 1 milligram per kilogram (mg/kg).
However, the Feasibility Study (FS) proposed installing the
SVE system in those areas of the Site where elevated levels of
contaminants in the soils were encountered. These areas are
defined in Figure 4.2 of the Feasibility Study.
The PRPs discussed thoroughly the ineffectiveness of
pumping/extracting groundwater as a clean-up method for
aquifers. The PRPs also emphasized that the time frames for
remediating the groundwater are generally underestimated.
They also quoted one publication which states that not "a
single aquifer in the United States has been confirmed to be
successfully restored through pumping and treating." Their
discussion was based on a review of technical studies of
groundwater remediation, including EPA studies.
The Agency does not dispute the findings of these studies.
However, the underestimation of time required for aquifer
cleanup applies not only to the pump-and-treat of groundwater
with residual soil contaminants having been removed during the
first year (SVE); it also applies to the pump-and-treat
undertaken 20 years later to remove the last contaminants
entering the groundwater (natural flushing). In addition, it
should be pointed out that one particular conclusion quoted by
the PRPs, that "plume containment and mass reduction should be
primary objectives of groundwater remediation", does not
correspond to either EPA policy or the requirements of the NCP
at this time.
In this regard, the PRPs note that trichloroethene (TCE) "is
projected to impact groundwater above MCLs for approximately
20 years" (page 8). This is the time estimated to be
required for natural flushing to remove all TCE (and other
contaminants) from the soil. It is then stated near the top
of this page that "remediation of Site groundwater is
projected to take approximately 10 years assuming no flushing
of additional contaminants into the groundwater."
The concentrations of contaminants which will be entering the
groundwater in the 20th year of natural flushing are not
known. The PRPs' assumption that only a 50% reduction in the
concentrations present in the groundwater will be needed may
not hold true; as they point out, there are uncertainties
associated with the assumptions required by the computer
models.
Therefore, based on the above, for TCE that enters the
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groundwater in the 20th year of natural flushing, the estimate
could range up to another 10 years for the contaminant to be
removed from the aquifer by the groundwater pump-and-treat
system, depending on the levels present in the groundwater.
Based on these provisions, the comparison made on page 10 and
page 11 should use ~ than 11 years as the difference in
time frames between the natural flushing alternative and the
SVE alternative:
20 yrs N. flushing
(incl. 10 yrs pump/treat)
+ 1 yr pump/treat for last
"50% reduction"
21 to ? yrs total
vs.
10 yrs pump/treat
(includes SVE)
10 yrs total
The difference will be greater than 11 years: both values have
the pump-and-treat "asymptote factor", described in the
studies, which will cause them to be underestimates. But, the
natural flushing alternative has an additional unknown: the
length of additional pump-and-treat time necessary to remove
the last TCE entering groundwater. The contaminant levels
produced by this leaching will likely be very low, but still
above MCLs: corresponding to those levels which take the
longest to reduce. Additionally, if the attenuation/leaching
model should also prove to have an "asymptote factor",
contaminants may continue to enter the groundwater beyond 20
years, thus further delaying attainment of cleanup goals.
If only 5 years were required to bring residual concentrations
down to MCLs, the additional costs for groundwater remediation
at present worth costs (GR-PWC)* would be:
GR-PWC = $81,000 (P/A: 16, 5%) (P/F: 10, 5%)
= $81,000 (10.8378) (0.6139)
= $539.000
If 8 years were required, GR-PWC would equal $601.000, and if
10 years were necessary, $638.000.
The present worth cost for SVE is $620,000. The estimated
savings generated by natural flushing are thus not greater
than $200,000~ rather, the estimate more likely ranges between
o and $81,000. Such savings, if valid, are not substantial
when measured against the estimated total cost (net present
worth) of the remedy: $1.2 million (10 yrS), $1.8 million
(30 yrS).
* Same formula as used by PRPs.
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These possible cost savings are not enough to justify
selecting natural flushing as a source control remedy,
essentially equates to a "No Action" remedy for the
contaminated soil areas.
which
In selecting a remedy, the Agency must evaluate two other
criteria not mentioned by the PRPs. These are:
o
o
state acceptance/input
community acceptance/input
State and community representatives will not support this type
of "No Action" scenario. The South Carolina Department of
Health and Environmental Control (SCDHEC) has already verbally
concurred with, and supports, the selected remedy.
Additionally, technical recommendations were considered.
EPA technical publications which concern pump-and-treat
systems are:
Two
o
Basics of PumD-and-Treat Ground-Water Remediation
Technoloay. EPA/600/8-90/003, March 1990.
o
Evaluation of Ground-Water Extraction Remedies.
EPA/540/2-89/054, September 1989.
The latter document was referenced in the PRPs' comments.
Both of these documents make clear recommendations that any
and all residual source areas, whether above or below the
water table, be removed or addressed by another treatment
system. Use of multiple treatment technologies, such as that
outlined in the remedy selected for this site, is common' at
CERCLA sites. In both documents, the recommendations are
offered as methods to enhance and improve the effectiveness of
pump-and-treat systems.
These recommendations, and the documents in general, support
the Agency'S opinion that, given the uncertainties associated
with pump-and-treat remediation of contaminated groundwater,
it makes sound economic and environmental sense to prevent or
at least minLmize the contaminant mass from moving from the
unsaturated zone to the saturated zone, rather than waiting
for the contamination to enter groundwater and then attempting
to remediate the contamination. SVE is a proven technology
which can remove VOCs and prevent them from migrating into the
groundwater.
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In summary, it is the Agency's opinion that the selected
remedy is the best overall choice for remediation of both
and groundwater at the Medley Farms Site. The natural
flushing alternative is not acceptable because:
soi1
o
the underestimation of the time necessary for
cleanup will apply to the groundwater
pump-and-treat undertaken at the end of the natural
flushing period, which is required to capture
residual contaminants entering groundwater late in
the 20-year natural flushing period
o
the cost savings may not be substantial and do not
justify reliance on natural flushing
technical publications strongly recommend
addressing residual source areas using a companion
technology along with pump-and-treat (such as SVE)
o
o
the Agency believes it to be more logical to
eliminate the residual source areas, since they are
a potential problem which would likely affect the
pump-and-treat system, by using SVE to remediate
those areas.
Please address any questions or comments to the. undersigned,
or to Ralph Howard, the Remedial Project Manager who will be
taking over guidance of the site following finalization of the
Record of Decision.
Sincerely,
/~~'IK
~~~
v
Jon K. Bornholm
Remedial Project Manager
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