United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R04-93/158
September 1993
&EPA Superfund
Record of Decision:
Kalama Specialty, SC
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R04-93/158
3. Recipient1 s Accession No.
Title and Subtitle
SUPERFUND RECORD OF DECISION
Kalama Specialty, SC
First Remedial Action - Final
5. Report Date
09/28/93
7. Author(s)
6. Performing Organization Rept. No.
9. Performing Organization Nam* and Addreaa
10 Project Taskwork Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Nam* and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report* Period Covered
800/800
14.
15. Supplementary Notes
PB94-964033
16. Abstract (Limit: 200 words)
The 50-acre Kalama Specialty site is comprised of a former 16-acre manufacturing plant
and a 34-acre trailer park located in Beaufort, Beaufort County, South Carolina. Land
use in the area is predominantly industrial, as well as a mix of residential,
commercial, agricultural, and military. The site is predominantly flat and contains
several drainage ditches, old buildings, and concrete slabs. An estimated 40 residences
are located within a quarter mile of the site. In 1973, the Vega Chemical Company
began onsite operations, which included chemical repackaging, custom hydrogenations,
and manufacturing the herbicide, Krenite. Site operations generated wastewater,
comprised of cooling water runoff, boiler blowdown, and pump seal leakage and spillage,
which was disposed of onsite; and other non-aqueous and organic wastes, which were
disposed of offsite. Between 1973 and 1975, the wastewater was discharged to a
depression in the land, where it then percolated into the ground and contaminated
onsite soil and ground water. Between 1976 and 1979, the wastewater was treated onsite
by a land application system, pumped to a holding pond, stabilized in the pond, and
discharged to a large tile field. During the 1970s, other releases to onsite soil may
have occurred due to onsite incineration of non-chemical solid waste. Kalama Specialty
purchased the 16-acre property in 1979 and the inactive trailer park in 1980. Later in
(See Attached Page)
17. Document Analysis a. Descriptors
Record of Decision - Kalama Specialty, SC
First Remedial Action - Final
Contaminated Media: soil, sediment, gw
Key Contaminants: VOCs (benzene, toluene, xylenes), metals (chromium, lead)
b. Identifiers/Open-Ended Terms
c. COSATI Field/Group
18. Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None •
21. No. of Pages
98
22. Price
(See ANSI-Z39.18)
S*» Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTtS-35)
Department of Commerce
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EPA/ROD/R04-93/158
Kalama Specialty, SC
First Remedial Action - Final
Abstract (Continued)
1979, an onsite explosion and fire damaged several reactors and vessels containing
chemicals in various stages of manufacture. The estimated 200,000 gallons of water and
fire control foam that were used to fight the fire, became contaminated with organics from
the ruptured vessels, and migrated from the operations area, forming a pool onsite. This
pooled fire water was recovered, and pending offsite disposal, was held in tanks, pools,
and tankers. There was an effort to contain some of the material in the wastewater
holding pond, but it accidentally seeped into the tile field. During the 1970s, State
investigations resulted in the installation of a wastewater treatment system and the
initiation of a ground water monitoring program in 1976, and also identified buried drums
onsite. Further State investigations, in 1980, identified soil and ground water
contamination by VOCs and metals. The State initially ordered Kalama Specialty to cleanup
all of the identified contaminated areas. This was later modified and the company was
only required to perform studies to determine the extent of the soil and ground water
contamination and to design plans for conducting cleanup. In 1980, following abandonment
of the original bentonite-lined pond and tile field, Kalama Specialty constructed a
larger, plastic-lined lagoon to hold wastewater. Site operations ceased in 1983, and in
1986, Kalama Specialty leased the land to a local contractor for storing and staging of
heavy equipment, materials, old oil tanks, construction debris, and concrete. In
1989, the site was abandoned, and the area was fenced. This ROD addresses a first and
final action for the contaminated soil, sediment, and ground water. The primary
contaminants of concern affecting the soil, sediment, and ground water are VOCs, including
benzene, toluene, and xylenes; and metals, including chromium and lead.
The selected remedial action for this site includes sampling to ensure that all soil
contaminated at levels exceeding performance standards is removed; excavating 604 yd^ of
contaminated soil and 80 yd^ of sediment, and treating the soil onsite using
volatilization and solidification,- with replacement of the treated soil and sediment to
the excavated areas; backfilling, grading, seeding, and establishing a vegetative cover
for the excavated areas to control erosion and-surface water runoff; providing a
contingency for offsite disposal at a RCRA offsite landfill, if deemed more cost
effective; treating the air emissions resulting from volatilization to meet ambient air
quality standards, as necessary; pumping and treating contaminated ground water from the
sand aquifer onsite using precipitation and filtration to remove metals, followed by air
stripping to remove organic contaminants, and granular activated carbon as a polishing
step; discharging the treated water onsite to an infiltration gallery, sprayfield, or
surface water; collecting and temporarily storing dewatered solids from the filtration
process onsite pending disposal; and monitoring ground water and air. The estimated
present worth cost for this remedial action is $3,502,167, which includes an estimated
present worth O&M cost of $1,896,527 for 30 years. The estimated present worth cost for
the contingency remedy is $3,768,500.
PERFORMANCE STANDARDS OR GOALS:
Soil, sediment, and ground water cleanup goals are based on State and Federal standards or
health-based risk factors. Chemical-specific soil and sediment cleanup goals include
antimony 3 mg/kg; benzoic acid 25,000 mg/kg; chromium 40 mg/kg; 1,1-DCE 0.023 mg/kg;
ethylbenzene 7 mg/kg; lead 500 mg/kg; mercury 2 mg/kg; nickel 140 mg/kg; toluene 4 mg/kg;
and xylenes 60 mg/kg. Ground water cleanup goals are based on SDWA MCLs and include
benzene 5 ug/1; 1,2-DCA 5 ug/1; 1,1-DCE 7 ug/1; ethylbenzene 700 ug/1; methylene chloride
5 ug/1; and xylenes 10,000 ug/1.
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RECORD OF DECISION
KALAMA SPECIALTY CHEMICAL, INC.
SUPERFUND SITE
BEAUFORT, BEAUFORT COUNTY
SOUTH CAROLINA
PREPARED BY:
l»
t
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA
SEPTEMBER 28, 1993
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DECLARATION FOR THE RECORD OF DECISION
SITE HAMB AND LOCATION
Kalama Specialty Chemical, Inc.
Beaufort, Beaufort County, South Carolina
fYP HASIS AND PURPOSE
This decision document presents the selected remedial action for
the Kalama Specialty Chemical, Inc., Superfund Site (the Site) in
Beaufort, South Carolina, which was chosen in accordance with the
Comprehensive Environmental Response, Compensation and Liability
Act of 1980 (CERCLA) , as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), 42 U.S.C. S 9601 et sea. .
and, to the extent practicable?9' the National Oil and Hazardous
Substances Contingency Plan (NCP), 40 C.F.R. Part 300 et seq.
This decision is based on the administrative record file for this
Site.
*
The State of South Carolina concurs with the selected remedy.
ASSESS**HifJ.' OF T*TR 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 (ROD), may present an
imminent and substantial endangerment tb public health, welfare,
or the environment.
DESCRIPTION F
This remedial action addresses On-Site groundwater contamination/
as well as on-Site soil and sediment contamination.
The major components of the selected remedy include:
* Treatment of soils and sediments (both on the surface
and in the ditch) contaminated with volatile organic
compounds (VOCs) and metals by excavation,
volatilization, and solidification (or as a
contingency, the removal of contaminated soils from the
Site);
* Replacement of soils into the excavation;
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Extraction and treatment of groundwater to the KCLp for
contain in ants of concern; and
Additional monitoring of groundwater with additional
monitoring wells including new deep wells in the
limestone aquifer.
The selected soil and groundwater 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 n»**-
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TABLE OF
UUNTKNTS
SECTION ^ PAGE
1.0 KSCI SITE LOCATION AMD DESCRIPTION 1
1.1 Site Description 1
1.2 Site Topography and Drainage 1
1.3 Meteorology 4
1.4 Geologic and Hydrogeologic Setting 4
2.0 SITE HISTORY AHD ENFORCEMENT ACTIVITIES 5
2.1 Site History 5
2.2 Enforcement Activities 8
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION 9
4.0 SCOPE AHD ROLE OF THIS ACTION wiTttXM SITE STRATEGY 10
5.0 SUMMARY OF SITE CHARACTERISTICS 11
5.1 Site-Specific Geology and Hydrogeology 11
5.1.1 Geology 12
5.1.2 Hydrogeology 12
5.2 Nature and Extent of Contamination 14
5.2.1 Types of Contamination 14
5.2.2 Sources of Contamination 14
5.2.3 Fate and Transport 16
6.0 SUMMARY OF SITE RISKS f . , 16
6.1 Baseline Risk Assessment-Purpose & Methodology 18
6.2 rVr*n't'JMn'*TtJiT>'1'n of Concern ............................ 19
6.2.1 Soils 22
6.2.2 Sediments 22
6.2.3 Groundwater. .• .*.... 22
6.2.4 Surface Waters 23
6.2.5 fo*< •**»»"•» -nn-n-t-a of Concern Summary...............23
6.3 Exposure Assessment ." 1* ».. .24
6.4 Toxicity Assessment of Contaminants 25
6.5 Risk Characterization 27
6.5.1 Cancer Risk Estimates 28
6.5.2 Chronic Hazard Index Estimates 29
6.6 Environmental (Ecological) Risks 30
6.6.1 Summary of Potential
Environmental Exposures ...................31
6.7 Baseline Risk Assessment Results Summary 31
7.0 DESCRIPTION OF REMEDIAL ALTERNATIVES 33
7.1 Remedial Objectives and Goals 33
7.2 Development of Remedial Alternatives 34
7.3 Source Control Remedial Alternatives 34
7.3.1 No Action (SC-1) 34
7.3.2 Limited Action, Rezoning (SC-1A) 39
7.3.3 RCRA Cap, Fill In Ditch (SC-2) 39
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SECTION PASS
7.3.4 Clay Cap-Slurry Wall, Fill in
Ditch (SC-3) ............................. 40
7.3.5 Soil/Sediment Excavation
& Treatment: (SC-4) ...................... 40
7.3.6 Soil/Sediment Excavation & Disposal
in RCRA Landfill (SC-5) ................. 42
7.3.7 In situ Soil Treatment for VOCs (SC-6) ......... 42
7.4 Gronndwater p<«fiodi«i Alternatives .....................43
7.4.1 No Action (MM-1) ...................... . ......... 43
7.4.2 Limited Action, Deed Restrictions
and Plume Monitoring (MM-1A) .................... 45
7.4.3 Slurry Wall, Pump-Treat-Disposal to TfCLg
(MM-2) .......................................... 45
7.4.4 Snort Term PTD of Groundwater Concurrent
with Vacuum Extraction of Soils
at Hot Spots (MM-3) ............................. 46
7.4.5 PTD to MCL Concentrations (MM-4) ................ 47
7.5 Source & Migration Management Control
Alternative <"*<"«">•> •»Tiafrf?r>ipp .............................. 48
8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES .......... 50
8.1 Evaluation of Remedial Alternatives ................. 50
8.2 Threshold Criteria .................................. 52
8.3 Primary Balancing Criteria ........................... 52
8.4 Modifying Criteria ..... ............................. 53
8.5 Combined Alternatives Evaluation. ................... .53
9.0 THE SELECTED REMEDY .................... . ................. 66
9.1 Preferred & Contingency Alternatives ................. 66
9.2 Source Control ...... .................... . ........... 66
9.2.1 Description .......... . ....................... 69
9.2.2 Applicable or Relevant and Appropriate
Requirements (ARARs) .......................... 70
9.2.3 Performance Standards ........"............-.... 72
9.3 Groundwater Remediation ......... ..................... 73
9.3.1 Description .................................. 73
9.3.2 Applicable or Relevant and Appropriate
Requirements (ARARs) .......................... 75
9.3.3 Performance Standards ...... . ................. 78
9.4 fVwFiT-Bi Extent of Gronndwater Contamination ......... 78
9.5 Monitor Site Groundwater/Surf ace Water ............... 79
10 . 0 STATUTORY DETERMINATIONS ................................. 79
10.1 Selected Alternative ................................. 79
10.2 Contingency Alternative .............................. 82
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APPENDICES
APPENDIX A — RESPONSIVENESS SUMMARY
APPENDIX B — STATE IiETTER OF CONCURRENCE
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ATTACHMENTS
ATTACHMENT A — PROPOSED PLAN FOR KSCI HPL SITE
0 '
ATTACHMEHT B ~ PUBLIC NOTICES FOR PUBLIC MEETING & COMMENT
PERIODS
ATTACHMENT C ~ WRITTEN COMMENTS RECEIVED DURING COMMENT
PERIOD
ATTACHMENT D — PROPOSED PLAN PUBLIC MEETING SIGN-IN SHEETS
ATTACHMENT E — OFFICIAL TRANSCRIPT OF PUBLIC MEETING
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LIST OP FIGURES
FIGURE PAGE
1-1 General location Map 2
1-2 Study Area Location Map 3
1-3 Study Area Snowing Operational Features, 1979 7
5—1 Extent of Principal. Soil Contamination............... 15
5-2 Study Area Snowing Groundwater Impacted
by BTBX Compounds, 1,2-DCA & Methylene Chloride
Above Their MCLs in the Water Table Aquifer 17
7-1 Potential Extraction Well Locations and
Contaminant Plumes...................................49
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OF CABLES
TABLE
6-1 Chemicals of Potential Concern
in All Hedia 20
6-2 Exposure Pathways ............26
7-1 Remedial Goals 35
7-2 perogtf» gi Goals for Contaminants of Concern 35
7-3 Cleanup Goals Based on Leaching Potential 36
7-4 Cleanup Goals Based on Future Land Use (Health Based). 37
7-5 Summary of Source Control Alternatives 38
7-6 Summary of Management of Migration Alternatives 44
8-1 summary of Detailed Analyses of Alternatives 51
8-2 Summary of Evaluation of
Remedial Action Alternatives 54
9-1 Reasonable Estimate of Capital and
O 6 M Costs of Alternative 6 67
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1.0 KSCI SITE LOCATION MID DBSCRIPTIOH
The Kalama Specialty Chemical, Inc. (-the Site), Site is located
in Beaufort, Beaufort County, South Carolina, on Highway 21 four
miles from the City of Beaufort, across the highway from the
Marine Corps Air Station (Figure 1-1). The Site consists of
approximately fifty (50) acres, and includes the former Kalama
manufacturing plant Site and the former Benton Trailer Park
(Figure 1-2). The Kalama facility's operations included chemical
repackaging, custom hydrogenations, and manufacturing Krenite, a
herbicide. The facility was in operation from 1973 to 1983 under
the names of Vega Chemical (Vega) and Kalama Specialty Chemical,
Inc. (KSCI).
1.1 Site Description
The Site consists of two parcels, a 16-acre tract on which KSCI
operated and an adjacent 34-acre former mobile home park, the
Benton Trailer Park, that was purchased by Kalama Chemical, Inc.
The Site is predominately flat with several drainage ditches
within the Site, with several bid buildings and concrete slabs
remaining.
The Site is four miles north of Beaufort on US Highway 21. The
Site is bordered on the East by Highway 21 and to the West by the
Seaboard Coast Line Railroad. Across Highway 21 from the Site is
•the 5300 acre U.S. Marine Corps Air Station Beaufort (MCAS). The
Site lies within the airport noise zone. The area near the Site
developed without zoning and is 4*mix of residential, commercial,
industrial, agricultural, and military land uses. The Site is
zoned industrial. There are some forty (40) residences within a
quarter mile of the Site, as well as a concrete plant, a drive-in
theater, and a day care center. While salt marshes are a
predominant feature of the Low Country,'there are none located
less than one mile from the Site.
1.2 Site Topography **nd Dr** *****&
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Record of Decision
Kalama NPL Site
Page 2
MAP SHOWING
LOCATION OF
BEAUFORT COUNTY
IN
SOUTH CAROLINA
KALAMA SPECIALTY
: CHEMICALS. INC.
STUDY AREA
GENERAL LOCATION MAP
PBSJ
»CI POST. BUCKLEY. SCHUH ^ JERNIGAN. INC.
^> KALAMA SPECIALTY CHEMICALS. INC.
STUDY AREA
FIGURE 1-1
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Record of Decision
Kalama NPL Site
Page 3
'^S-: Qarrtirf
t^-r. r
APPROXIMATE
UMJT
STUDY AREA
I J
BEAUFORT COUNTY
LANDFILL
= INDEPENDENT
ROM: HEAUF IT. 8.C. AND LAUREL SAY, 8.C. 7.6 MINUTE QUADRANGLE MAPS
2000 0 2000 4000'
STUDY AREA LOCATION MAP
POST. BUCKLEY. SCHUH &. JERNIGAN. INC
KALAMA SPECIALTY CHEMICALS, INC.
STUDY AREA
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Record of Decision
Kalama NPL Site
Page 4
1.3 Meteorology'
The generalized climatic conditions for the Kalama study area as
reported by the U.S. Weather Service for monitoring stations are:
an annual precipitation of 51 inches, of which 32 inches (62
percent) occurs during April through September; an average
relative humidity ranging from a high of 84% at 4 AM to a low of
50% at 1 PM; an annual daily average maximum temperature of
74.5*F and an annual daily average minimum temperature of 58.7°F.
The average wind speed and direction is 5 knots out of the south.
During the study period of the initial RI activities from July
1989 through March 1990, the total rainfall was 46.77 inches,
which is above the annual average for the period of 37 inches.
The average temperature for this period was 65.3°F, which also is
slightly above the annual average for the period of 63.5°F. The
greatest single total monthly rainfall was 10.29 inches in August
1989.
Two unusual climatological events occurred during the study
period. Hurricane Hugo passed to^the north of the study area in
September 1989. Due to the extreme winds during the hurricane,
-it is possible that actual precipitation actually exceeded the
reported levels. During December; 1989, several inches of snow
were recorded and temperatures were well below average.
1.4 Geologic *nd Hvt*T'ogeoloqic Setti *MT
The near surface geology of the study area consists of two
aquifers, the water table aquifer and the Floridan Aquifer,
separated by clay materials of varying thickness and uniformity.
The water table aquifer (or "sand" aquifer) soils consist of
sands and clays. Beneath the sand aquifer is a non-continuous
layer of clay or silty clay materials, and beneath this is a
confined to semi-confined aquifer of sandy limestone.
The two most conspicuous subsurface hydrogeological structural
features in the Low Country and the Site are the Beaufort Arch (a
high) and the Ridgeland Trough (a low). They are important
because the confining beds overlying the aquifer are thicker in
structural basins or troughs, but are thinner over structural
highs. The shallow depth to the limestone aquifer over the
Beaufort Arch, the low yields of water available from the sand
aquifer, and the objectionable water quality found in the sand
aquifer have caused the local well drillers and owners to target
the limestone aquifer for water supplies, rather than the sand
aquifer. This limestone aquifer is the major regional water
supply aquifer for the area and is part of the Floridan Aquifer.
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Record of Decision
Kalama MFL Site
Page 5
The subsurface investigation at the Site found these Site-
specific lithologies:
* Fine to medium sand from land surface to 15-25 feet;
* Very fine sand occurs beneath to a depth of 60-65 feet,
clay content and lenses increase to the bottom of layer;
* Clay and sandy clay, although discontinuous, from 75-85
feet deep; and
* Sandy limestone at 85 feet, the top of Floridan Aquifer.
Operations began at the Site in 1973 .by a chemical company known
as Vega Chemicals (Vega), who leased the sixteen (16) acre tract
from the Beaufort County Development: Corporation. Vega spent
approximately two years constructing its operating facilities at
the Site, and began full scale operations in 1975.
In 1976, KSCI purchased a financial interest in Vega, and later
purchased the balance of the company in 1978. KSCI purchased the
sixteen (16) acre tract in 1979 from the Beaufort County
Development Corporation. A second parcel of property, a vacant
thirty- four (34) acre tract of land, adjacent to the 16 acre
tract, previously operated as a mobile home park known as the
Benton Trailer Park, was purchased by KSCI in 1980. KSCI
continued to operate at the Site until 1983 when it closed its
operations. The Site remained inactive until 1986, when KSCI
leased the sixteen (16) acre tract to a local contractor, F-loyd
Sears Construction, who used the Site for storage and staging of
heavy equipment, as well as a variety of materials, such as
preserved timbers (telephone poles), old oil tanks, construction
debris, and concrete from the MCAS Beaufort. Floyd Sears
Construction leased the property until 1989, at which point the
Site was abandoned.
The former operations area of the Site has been fenced with "No
Trespassing" signs posted identifying the property as a Superfund
Site. The fencing is currently inspected regularly by a local
security company.
The Site was operated by both Vega, and later KSCI, primarily in
the production of specialty chemicals. A wide range of chemicals
were produced in small, special-order batches. The principal
product manufactured at the Site was known as Krenite, an
herbicide made under contract with the DuPont Company. Wastes
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Record of Decision
Kalama NFL Site
Page 6
from the Site included wastewater, comprised of cooling water,
runoff, boiler blowdown, and pump seal leakage and spillage,
which was disposed of on-Site, and other non-aqueous and organic
wastes, which were disposed of at approved off-Site incineration
or disposal facilities.
During the period of 1973 through 1975, wastewater from the
facility was discharged from the production area of the facility
to a small depression in the land, where the wastewater then
percolated into the ground. Between 1976 and 1979, the
wastewater was treated on-Site by a land application system
consisting of an aerated, bentonite-lined holding pond and tile
field. A lift station pumped this wastewater from the operations
area to the holding pond via an underground six (6) inch diameter
PVC pipe. The wastewater was stabilized in the pond and
discharged to a large tile field, in an attempt to percolate
stabilized wastewater to the water table aquifer to prevent its
migration to surface waters off-Site.
In addition to the release of wastewater at the Site, other
releases may have occurred because of on-Site incineration which
took place at the Site during the 1970s. Non-chemical solid
waste materials (cardboard, pallets, and fiber containers) were
periodically burned in a depressed location beyond the fence
•line, west of the operations area. Additionally, a
methanol/ethanol waste stream, possibly containing trace amounts
of ethyl chloride from the Krenitfe .manufacturing process, was
burned in a bentonite-lined pit on-Site. The pit also was used
by Kalama for fire-fighting training. The location of the pit,
which was reportedly filled in January 1979, has not been
precisely determined.
i
In January 1979, there was an explosion and fire at the Site
which resulted from a laboratory experiment. The explosion and
fire damaged a number of reactors and vessels containing
chemicals in various stages of manufacture. Chemicals ran off
the reactor pad principally to the west and northwest. It was
estimated that over 200,000 gallons of water and fire control
foam were used to fight the fire on the pad, and this fire water,
contaminated with organics from the ruptured vessels, also ran
off the operations area and pooled in low areas west and
northwest of the reactor pad. The majority of the pooled fire
water (contained by an earthen dam) was recovered, and pending
off-Site disposal, was held in tanks, pools, and tankers. An
effort was made to hold some of the material in the wastewater
holding pond, but due to a plug failure, this material seeped
into the tile field. Figure 1-3 shows the Site's features as
they existed in 1979.
Following the 1979 explosion and fire, use of the wastewater
treatment system was curtailed during plant rebuilding and start-
up. Any washdown or wastewater sent to the pond was held and
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HYDROGEN^-NITROGEN TANK
STORAGE/., i—HYDROGEN TANK
REACTOR
PAD
WAREHOUSE
KSCI FACILITY
K
PROPERTY LINE
ROAD
OIRT ROAD
FENCE LINE
M •
DRUM STORAGE AREAS • < moi* HTEwweTATON OP ACINI moroa
TAKEN ATTCM TIC f XPtOMM MNUAftV.
STUDY AREA SHOWING OPERATIONAL FEATURES, 1979
SCALE=I = IOO
PBS;
POST. BUCKLEY. SCHUH 8. JERNIGAN. INC.
KALAMA SPECIALTY CHEMICALS. INC.
STUDY AREA
BEAUFORT. SOUTH CAROLINA
FIGURE 1-3
JOB No: 18-017.65
PMOFAOOUCIS. IMC >» JI01*
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Record of Decision
Kalama NFL Site
Page 8
pimped into tankers for off-Site disposal, in 1980, following
abandonment of the original bentonite-lined pond and tile field,
KSCI constructed a larger, plastic-lined holding lagoon. This
pond had no discharge; wastewater was held for off-Site disposal.
This pond was utilized until 1983, when KSCI closed its
operations.
2.2 Enforcement Activities
During the 1970s, contamination problems at the Site came to the
attention of the State of South Carolina (the State), and were
investigated by the South Carolina Department of Health and
Environmental Controls (SCDHEC). SCDHEC ordered KSCI to install
a wastewater treatment system. Early inspections at the Site led
to the initiation of a groundwater monitoring program in 1976,
and the discovery of buried drums at the Site in 1979. Further
inspections led to the decommission of the inadequate pond and
tile field system in 1980 (all»sludge and contaminant structures
from these areas were sampled and disposed of in an approved
landfill, and are no longer evident) ,-.and the decommission of the
larger wastewater lagoon in 1983.
?
Soils at the Site were analyzed by the State, and were found to
•be contaminated with benzene, toluene, ethylbenzene and xylenes,
1,2-dichloroethane, acetone, methylene chloride, lead, nickel,
and mercury, with especially high*concentrations detected in
areas which received substantial runoff from the fire and
explosion in January 1979. State groundwater sampling at the
Site also detected ethylbenzene, xylenes, 1,2-dichloroethane,
acetone, and methylene chloride, all with the potential to affect
the Floridan aquifer. , '
In 1980, a Consent Order issued by SCDHEC to KSCI as a result of
frequent releases of wastewater'into the soils,-required the
characterization of soil and groundwater quality at the Site, and
called for a cleanup of all identified contaminated areas. This
Consent Order was later amended /to require KSCI to perform
studies on the extent to which soil and groundwater contamination
had occurred and to design plans to clean up the contamination.
Due to the presence of contaminants in soils -and shallow
groundwater, and the potential impact of these contaminants on
the Floridan Aquifer, EPA formally proposed the Site for listing
on the National Priorities List (NPL) (40 C.F.R. Part 300,
Appendix B), on September 8, 1983. The Site was finalized on the
NPL by publication in the Federal Register on September 21, 1984,
49 Fed. Reg. 37083, with a Hazard Ranking System (HRS) score of
59.9.
EPA and the State agreed that SCDHEC would have lead
responsibility for the disposition of the Site. From 1983 to
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Record of Decision
Kalama NPL Site
Page 9
1986, SCDHEC pursued the necessary studies and remedial
activities with^KSCI under the SCDHEC Consent Order. Overall,
however, KSCI experienced difficulty in meeting schedules and
completing work assignments. In an attempt to resolve these
difficulties, the State turned the lead for the Site over to
EPA's Superfund Enforcement Branch in late 1986.
After reviewing the work done previously by KSCI under the SCDHEC
Consent Order, EPA determined that further study was needed to
determine the nature and volume of the waste, pathways by which
contaminants would move or present the risk of exposure to human
health and the environment, and the hydrologic relationship
between the upper shallow layer of groundwater and the deeper
aquifer. As a result of this determination, EPA on January 13,
1988, entered into an Administrative Order on Consent (AOC) with
KSCI to perform a Remedial Investigation/Feasibility Study
(RI/FS) at the Site under EPA's oversight. KSCI provided EPA
with its final RI report in January 1993.
»* •
During the entire RI/FS process (a span of approximately five (5)
years), EPA experienced major difficulties in receiving
approvable documents from KSCI's contractor Post, Buckley, Schuh
and Jemigan, Inc. (PBS&J). PBS&J claimed the existence of a
continuous clay confining layer between the soils and deeper
•aquifer, the existence of which was disputed by both the State
and EPA. As a result, each revision submitted during this long
period, though somewhat more improved than the previous, remained
inadequate due to the characterization of the supposed clay
layer.
On December 14, 1992, EPA sent KSCI a letter informing it that
EPA would be taking back the Site, pursuant to the AOC, to
complete the RI/FS process due to the failure of KSCI to address
comments and concerns of both EPA and the State. Concurrently
with the letter, KSCI was informed that, as part of the "Dispute
Resolutions" section of the AOC, KSCI would be given the
opportunity to submit one final revised set of RI/FS documents
for EPA review within the twenty-eight (28) day period set forth
in the AOC. If this final set of documents was not approvable,
EPA would immediately begin work at the Site.
KSCI retained an additional consultant and new counsel in order
to address State and EPA concerns. KSCI was able to submit its
final revision of the documents on schedule, and has removed or
reworded the language regarding a confining clay layer to EPA's
and the State's satisfaction.
3.0 HIGHLIGBTS OF COMMUNITY PARTICIPATION
Initial RI/FS community relations activities at the Kalama
Specialty Chemical Site began with community interviews in
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Record of Decision
Kalama NPL Site
Page 10
Beaufort and the f inalization of a Community Relations Plan in
August 1987. Concerns expressed at that time included what
effects the Site 'would have on drinking water, agriculture,
aquatic life, and future development in the area. In addition,
an information repository was established in August 1987, at the
Beaufort County Library on Craven Street in Beaufort.
A "kickoff " fact sheet announcing the start of the RI/FS was
issued in early February 1988. Community interest during the
RI/FS preparation was very low. EPA received few letters or
telephone calls regarding the Site or the RI/FS study. EPA has
updated the Site information at the Information Repository and
posted signs on the Site perimeter listing contacts at EPA and
SCDHEC. Several calls that were received informed EPA of
trespassers on the Site. The Site now is patrolled by a local
security service to control trespassing.
Following completion of the RI and the FS, the Site mailing list
was updated and the Proposed Plan was mailed out in mid-June
1993. An advertisement was published in area newspapers on June
22, 1993. Both the advertisement and the Proposed Plan stated
that the Public Comment period would be held from June 22, 1993,
to July 22, 1993. -t
-The Proposed Plan public meeting was held on July 1, 1993, to
present the Agency's selection of. Preferred Alternatives for
addressing soil and groundwater contamination at the Site. The
local newspaper, several citizens, and a number of local
governmental representatives were present, as well as
representatives from local environmental groups. In early July
1993, a request was received to extend the public comment period
to provide additional time for review of the Proposed Plan and
RI/FS documents. EPA approved the request and extended the
comment period until August 23, 1993.
*»
Comments received by EPA through August 23, 1993, and EPA's
responses to the comments are contained in the Responsiveness
Summary, Appendix A to this document. This decision document
presents the selected remedial action for the Site, in Beaufort,
South Carolina, chosen in accordance with CERCLA, as amended by
SARA and, to the extent practicable, the NCP. The decision for
this Site is based on the Administrative Record.
4.0 SCOPE AF" Prn-.T? pp THIft At^PTQH WITHIN SITE STRATEGY
The Site principally poses a threat to human health and the
environment through contaminated soils and contaminated
groundwater in the surficial aquifer. These contaminated areas
could cause deleterious health effects directly through direct or
long-term exposure to the soils or indirectly by contaminants
leaching into the shallow groundwater aquifer that could be used
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Record of Decision
Kalama NFL Site
Page 11
as a potable water source. EPA's plan for remediation of the
KSCI Site will address all threats posed by the Site:
contaminated BOX! on-Site and groundwater contamination both on
and off -Site. This is the only ROD contemplated for this Site.
5«0 SUMMARY OF SITE
The RI investigated the nature and extent of contamination on and
near the Site, and defined the potential risks to human health
and the environment posed by the Site. The first series of Site
investigation field activities completed under the Work Plan
commenced on July 10, 1989, and was completed March 22, 1990. A
second series of field work was conducted under a Supplemental
Plan and commenced on September 16, 1991, and concluded on
October 11, 1991. The field investigation at the study area
consisted of the following activities:
Monitoring well integrity testing
Permeability (slug) testing
Drilling soil borings and collecting soil samples for
characterization >
Installing and developing ten new monitoring wells
Upgrading and/or abandoning- of selected existing
monitoring wells
Metal detection survey .v .
Soil, surface water, sediment, and groundwater sampling
Groundwater was sampled on four occasions (October 1989, December
1989, February 1990 and October 1991).
*
Principal groundwater contaminants detected during the sampling
events include BTEX compounds, 1,2 DCA, acetone, and methylene
chloride. The highest groundwater contamination occurred in
wells MW-46A and MN-46B, and Hydrocone location HC-6. Total BTEX
levels up to 24,000 ug/1 have been detected; 1,2 -DCA at
12,000 ug/1 is present in the MW-46 location. Acetone and
methylene chloride (2,500 ug/1 and 130 ug/1, respectively) also
are present.
5.1 Site— Specific Geology and Hydr-ooreolooy
The lithology beneath the KSCI study area is comprised of the
Floridan Aquifer and overlying units extending to the surface.
The lithologies are described from oldest to youngest - starting
with Eocene limestones and continuing with Miocene sands and
clays, and Pliocene-Holocene sands and clays. The Floridan
Aquifer corresponds with the Eocene limestones and the water
table aquifer with the Pliocene-Holocene sands. Many previous
investigations have been conducted in this area, including Hayes
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Record of Decision
Kalama NFL Site
Page 12
(1979), and Glowacz, et al. (1980).
5.1.1 Geoloov '
The Floridan Aquifer occupies a large geographical area in the
South Carolina Coastal Plain and supplies groundwater to hundreds
of wells. It is the principal aquifer in the region and was
estimated to supply over 99 percent of the groundwater and more
than 70 percent of all water used in Beaufort County in 1976
(Hayes, 1979). In the Central Coastal Plain, this aquifer occurs
at or near land surface and is tapped by many small-diameter
wells less than 100 feet deep. In the Low Country (including the
Beaufort area), the aquifer system occurs near the land surface,
and confining beds vary in thickness from being absent to being
more than 150 feet thick. Groundwater occurs mainly under
artesian conditions, but in some areas, confining beds are thin
or absent and partial confining conditions occur.
There are five water-bearing or* permeable zones (separated by
less permeable rock in the Floridan Aquifer. Only two of these
zones are present under the Site, the Upper and Lower Hydrologic
Units. These two units supply most'of the groundwater pumped
from the Floridan Aquifer in the Immediate Savannah area. The
upper unit of the Floridan Aquifer serves as a groundwater
•reservoir and is used as a water supply in this region. In some
areas of the coastal Low Country,-; water-bearing zones in the
lower Floridan Aquifer contain mineralized water and the upper
Floridan Aquifer is the only source of potable water. The depths
of wells that tap the upper unit range from less than 50 feet in
the vicinity of the Beaufort Arch to more than 200 feet in Jasper
County. In many areas, the upper portion of the upper unit is
the most permeable (Spigner and Ransom,* 1979).
5.1.2 Hydrocreoloay
• ** _
Historically, there have been three primary groundwater users in
the Port Royal Island vicinity: the Marine Corps Recruit Depot
(MCRD) on Parris Island; the former Beaufort Naval Air Station
(BNAS), now a U.S. Marine Corps Air Station (MCAS); and the local
municipalities of Beaufort and Port Royal. A fourth water use
was for agricultural irrigation, but no records exist documenting
the well locations, volumes pumped, or problems encountered.
Several reports document historical water quality and water level
problems encountered on Port Royal Island as water users sought
to obtain a dependable supply of fresh drinking water. The major
reports are:
• Mundorff (1944) wrote the first groundwater assessment
of the area for the U.S. Marine Corps and generated the
first local potentiometric map.
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Record of Decision
Kalama NFL Site
Page 13
• Burnett (1952) chronicled the installation of wells for
water supply as the Marines moved their well fields
farther and farther north of the Parris Island depot,
as they tried to develop a dependable water supply.
• Hazen and Sawyer (1956 and 1957) compared engineering
costs for several water supply alternatives for the
Beaufort area, including a groundwater supply from
across the Broad River and a surface water supply from
the Combahee River.
• Siple (1960) documented the groundwater resources of
the Low Country area, emphasizing the Floridan Aquifer
System.
• South Carolina Resources Commission (1972) investigated
the Port Royal Sound area to assess the impact of the
proposed deepening of the shipping channel in Port
Royal Sound on the local groundwater resources.
• Hayes (1979) provided an updated evaluation of the
Floridan Aquifer for the Capacity Use Investigation for
the Low Country Area, including aquifer hydraulics,
water levels, and water use.
• Spigner and Ransom (1979) addressed the requirements of
the Capacity Use Regulations, and drew heavily from
Hayes (1979) for technical data.
In 1944, all known wells in Beaufort county obtained water from
the Floridan Aquifer. However the history shows since 1899,
wells drilled into the limestone aquifer were prone to salt water
intrusion. Attempts to drill deeper wells beneath the aquifer
resulted in low salt content, but were objectionable because of
the temperature (90-100 °F), and because the water contained
excessive amounts of other minerals (fluoride and bicarbonate).
This history indicates that the Marine Corps kept moving their
well fields further north to seek fresh water after successive
wells and well fields became salty. In January 1965, the
Beaufort-Jasper Water Authority, with assistance from the local
military installations, constructed a surface-water supply plant
that pulled water from the Savannah River to provide water that
was independent of the groundwater supply to the area. The plant
was designed for a capacity of 8 million gallons per day (MGD),
was upgraded to a 16 MGD capacity in the 1980s, and currently
supplies an average of 8 to 9 MGD with a 12 MGD peak flow during
the summer peak.
According to the South Carolina Water Resources Commission, there
are currently no permitted Class A groundwater users on Port
Royal Island. All wells on the island that formerly supplied
public drinking water currently are abandoned or have been placed
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Record of Decision
Kalama NPL Site
Page 14
on stand-by status. The only water users that continue to use
groundwater supplies are rural homeowners, where city water is
not available, and certain small-scale commercial enterprises.
5.2 HRTDRE AND UTTRMT Of COHTAMIMATIOH
5. 2»1 TVPeS Of tnrtt-tmti Ti«j"ion
Soils at the operations area west and northwest of the reactor
pad have been impacted by VOCs (BTEX compounds), chlorinated
hydrocarbons (methylene chloride, 1,2-dichloroethane), semi-
volatile organic compounds (benzoic acid, benzyl alcohol), and
inorganic metals (lead, nickel, and mercury). Attached Figure
5-1 shows the area of soil contamination at the Site.
Groundwater in the water table aquifer has been impacted by VOCs
(BTEX compounds), methylene chloride, and 1,2-dichloroethane.
These compounds occur in two plumes that partially overlap with
separate source areas. The eastern plume contains benzene,
ethylbenzene, xylenes, 1,2-dichloroethane, and methylene chloride
above their m«»jmw» contaminant levels (MCLs); the western plume
contains benzene, toluene, ethylbenzene, and xylenes, but only
benzene is above its MCL. ^
•Greater detail on specific contaminants found at the Site is
provided in Chapter 6 of this document. Chapter 6, "Summary of
Site Risks , • discusses contaminants by media ( soil , sediments ,
groundwater, etc.), and discusses the associated risks. To avoid
a lengthy duplication of information, the reader is referred to
Chapter 6 for a more detailed discussion of Site contaminants
(see Sections 6.2.1 to 6.2.5).
*
5.2.1 owTT!g>g of Con1"*nn'*'nation
The portion of the operations area of the KSCI -facility from the
reactor pad west to the B-5A soil sampling location, and
northwest in the direction of contaminant flow and ponding from
the January 1979 explosion and fire, is a source of groundwater
contaminants and the source for 'the eastern plume.
The tile field, which received wastewater from the original
holding pond, also is a source of groundwater contaminants and is
the source for the western plume.
Drainage areas, drum storage areas, and areas of both documented
and alleged historical activities have been investigated as
potential contaminant sources, but no discrete source areas
distinguishable from the two plume sources stated above have been
identified.
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Record of Decision
Kalana NPL Site
Page 15
FIGURE 5-1
200
SCALE IN FEET
PRINCIPAL AREA OF SOIL
CONTAMINATION
SOIL SAMPLE LOCATION
U.S. NAVAL
RESERVE
EXTENT OF PRINCIPAL SOIL CONTAMINATION
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Record of Decision
Kalama NPL Site
Page 16
5.2.2 Fa-te and Transport
*
A contaminant plume extends approximately 700 feet northwest of
the tile field; a second plume, which partially overlaps the
first plume, extends approximately 550 feet northwest of the
operations area. The groundwater beneath the study area is
calculated to be moving at flow rates of 20 ft/year in the middle
unit of the water table aquifer and 28 ft/year in the deep unit.
However, as indicated by the transport model, the leading edge of
the plume is estimated to be traveling at rates up to 1.5 to 2
times the groundwater flow rates. The groundwater contaminant
plumes in the upper aquifer are shown in attached Figure 5-2.
There have been no contaminants detected above their MCLs in the
water table aquifer off-Site, although xylene and ethylbenzene
have been detected at below MCLs at one location immediately west
of the property boundary. The estimated travel time for benzene,
in the western plume, to reach*the nearest downgradient property
boundary at the MCT. level is two to six years.
Vertical migration of contaminants from the water table aquifer
to the Floridan Aquifer is partially inhibited, though not
entirely prevented, by the presence of clay materials in a
•confining layer throughout much of the study area. Low levels of
water table aquifer contaminants ^1,2-dichloroethene at 21 ug/1,
1,2-dichloroethane at 0.3 ug/1 (Jf, and 0.6 ug/1 (J)) have been
detected in the Floridan Aquifer' beneath the Site in three
samples. "J" qualifiers listed after detection values indicate
that the number should be considered an estimated value,
typically because the value while above zero is below the
quantification limit of the sample or the test equipment.
1,2-dichloroethane also has been detected at low levels in
limestone wells to the southwest of the Site, but it has not been
conclusively determined whether:this is related-to an on-Site
source area.
The intermittent, standing water; in the "L-shaped" ditch and the
sediments in a limited area of the ditch have been determined to
contain some of the chemicals of concern (COCs including BTEX,
1,2-DCA, and lead).
6.0 SUMMARY OF SITE RISKS
The preceding subsection discussed the contaminant source areas
and how the contaminants have been transported through and
beneath the Site. The important use of this information is the
effect the contaminants have upon human and animal life, and the
environment on and around the Site.
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Record of Decision
Kalama NPL Site
Page 17
FIGURE 5-2
MARINE CORF
AIH STATION
<^h.T •"• / \ KSCI FACILITY
^^^^^^T?ftl^^^ ' *-^£f^
•Oini^Sir^^^ .' ^XlfllVly.
<
LEGEND
LlHCJTOC *OU!FC> VELL5
SAND AOinr
MTMtXONC
SC1L
5u«»-»ct WATCO
lONCHCTC DM •$<"•*< T I
DWT C» UAVCl. «C*B
MUM
f«OP€«TT LIlC
tITCH 0* VATBtt CBOt
TBCC LDC
rtNCC
ClMTtMt L1HC
uftLlIT CONVtM'IKMV
JANltMT $[wl«
v*l£« L
,/ •*$%. STUDY AREA SHOWING GROUNDWATER
' rw IMPACTED BY BTEX COMPOUNDS. 1.2 IM'A..
AND METHYLENE CHLORIDE ABOVE TIIEIU
.
MTDBOCCOUk.U SECTION
MICPCNTT LINE C»»P«OIIH*1C>
FUoK CONVCNTIOMJ.
KMZCK
CTHTLKNZEMC
ITLCNC
L2-SC*
CMLORIBC
it si r-.j " "o"i&« »mv«.. i-
uit i "« II
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Record of Decision
Kalama NPL Site
Page 18
6.1 Basel •i'ne Risk Assessment— par-ose »*»d Methodology
The Baseline Risk Assessment (BRA) describes the risks to human
health and the environment which would result if the
contamination present at the Kalama Site is not cleaned up. The
BRA proceeds in a series of steps. First, a list is generated of
all the chemicals present and their concentrations. Next, the
BRA considers the present and projected future land uses of the
Site. From the present use of the Site and likely future use
scenarios (residential land uses), "pathways* through which
people could be exposed to the contaminants are developed.
Future use pathways at the Kalama Site include: 1) dermal
absorption (skin contact) and incidental ingestion of surface and
subsurface soils, sediment, and groundwater, 2) ingestion and
dermal absorption of groundwater, and 3) exposure through
inhalation of dust/particulates from contaminated soil and vapors
from contaminated groundwater.
i».
The pathways of exposure can be developed by making assumptions
such as the length and number of times exposed, the amount of
chemical ingested, and using certain other factors. Thus, a
calculation can be made using known effects and reasonable
exposure assumptions, and the health effects caused by the
•contaminant. For each pathway, two calculations are made to
account for the two general types -of contaminants; carcinogens,
substances suspected or known to.eause cancer, and
noncarcinogens , substances which are hazardous and cause damage
to human health through other effects.
For carcinogens, the result is expressed as the excess cancer
risk posed by Site contaminants. EPA ha's established a range of
1 x 10"* to 1 x ID"* as acceptable limits for lifetime excess
carcinogenic risks. Excess risk in this range means that one
person in 10,000 (1 x 10~*) to one person in one-million
(1 x 10"6) will risk developing cancer after a lifetime of
exposure. For each pathway, the cancer risk from each individual
contaminant is added together, because in any exposure scenario a
person could be exposed through several or all of the possible
pathways.
Noncarcinogenic risk is expressed as a Hazard Index (HI). The
Hazard Index (HI) is the ratio of the amount of the chemical
taken in, divided by the reference dose, an intake amount below
which no adverse effects are known to occur. As for cancer risk,
for each pathway, the His for the individual contaminants are
added together.
Carcinogenic risk and noncarcinogenic His were calculated for
both the current land use scenario, with no residents at the
Site, but including trespassers (both adult and children)
accessing the Site, and for the anticipated future use scenario
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Record of Decision
Kalama NFL Site
Page 19
of the Kalama Site becoming a residential area.
In addition to the risks to human health, the environmental risks
from the study area also are evaluated in the BRA. The
environmental risk assessment is qualitative rather than
quantitative. The BRA finds that the primary exposure routes
affecting flora and fauna in the KSCI study area include dermal
contact with or ingestion of soils in the operations area and
dermal contact with or ingestion of surface waters, sediments,
and organic matter in the ditch. Secondary exposure routes for
predators include consumption of prey that have been affected by
the primary exposure routes and consumption of aquatic organisms.
More detailed information concerning Site risks is presented in
the Kalama Site's Baseline Risk Assessment, which is available at
the public information repositories for the Kalama Site located
at both the Beaufort County Library and EPA Region 4 offices in
Atlanta, Georgia.
i»
6.2 Contaminants of Concern
Based on RI data, contaminant concentrations to be included and
evaluated in the BRA were selected. Table 6-1 presents a summary
of these contaminants in all media sampled. The data analyzed in
'the preparation of the RI consisted of Contract Laboratory
Program (CLP) data from soil, sediment, surface water and
groundwater samples collected at.the KSCI study area. Tables 2-3
through 2-6 in the RI indicate the monitoring wells, sediment,
soil, and surface water locations sampled and the analyses for
each round of sampling. Sample collection methods used and
rationale, as well as the number and location of samples, are
discussed in detail in Volume. 1, Sections 3 and 4 of the RI
report. Only CLP target compound list (TCL) and target analyte
list (TAL) data were incorporated into the BRA. No historical
data (i.e., non-RI) nor data from the Hydrocone"sampling and
field laboratory were used in this evaluation because of
uncertainties in data validity.
*
t
A general review of the analytical results in Table 6-1 provides
evidence of chemical impact in the soils, sediments, surface
water and water table aquifer by aromatic hydrocarbons,
inorganics and chlorinated hydrocarbons. The chemically impacted
media are found primarily on an approximate 10-acre portion of
the study area, relative to the 50-acre study area. Based on
this data review, it appears the primary areas of concern at the
KSCI study area correspond to the KSCI operations area (i.e.,
reactor pad runoff from the 1979 explosion and fire and the old
lagoon and tile field) and the "ditch" in the vicinity of sample
location SW-2. The primary media of concern in these areas are
soils and groundwater.
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Record of Decision
Kalama NPL Site
Page 20
TABLE 6-1
SUMMARY OF CHEMICALS OF POTENTIAL CONCERN IN ALL MEDIA SAMPLED
KALAMA SPECIALTY CHEMICALS, INC. STUDY AREA
- 1 •
l&
i£
ifli.
lOJ
BayUtaa
0404-2.90
L
0.92-4.20
5.45-4* J6
L
L
L
041*4JO
0.00400
1.1500
L
L
040*44(6
L
0.1100
040100
0405-334
L
1J3-7.1I
3.17-34 J3
24-7300
514-51.0
L
04104J*
0403-25.0
L
L
L
64-1000
15400
14-34
24-294
42400 ,
L
L
L
L
L
L
041100
L
L
04002-1.7
L
2.15-11.94
442-I2.M
0417-1.65
0.005600
L
040*00
11000
0402-tJOO
0.20-704
0.1000
•4-554
14-130
200
10-1290
040-12400
230420
OJO-21.0
2400
L
54-1300
L
3.6-16.1
MMkgrtaCMaria:
Nttri
SUw
1.40-1UO
041049.0
149-15 JO
0410-142
04057-414
0.22-4.70
14-570-
l4.*0-26*47
L
L
L
L
L
04024.47
040100
L
OJMOO
L
L
L
0401-5*4
L
L
L
L
3.0-5.90
35400
L
OJO-2K
•400
0.10*1
1.10
L
04001-4.700
L
040-4500
34-1604
101400
5.50-l*.t$
274424
1.0-714
L
1400
34-174
774OO
5.0-64 "
1.0-160.0
L
. 34(10
L
L
L
10.4-3(4
44-25.0
7.0-6404
L
L
L
L
0.70414
L
54049.90
•4-195
0.24-143
14-1704
394424
L
L
L
164-214
L
040494
L
1400
L
L
OJO-2104
9400
L
L
10.000
L
L
L
43400
L
L
L
L
L
L
L
L
11.600
L '
L
L
L
L
L
L
L
34-29.9
11.5-74.5
L
L
L
L
L
L -
L
2400
L
L
L
L
L
L
041(54 JO
24.3600
2.IM2.6*
74745.14
0404-140
0.94-3JO
0.7600
0.13-54
L
2.5(4.00
0.9500
0.6400
L
L
0.2700
0.9100
349-15.03
3.14-43.67
0406-3.10
0.9600
L
L
L
0406-5JO
L
(J9-5964.6
54C-10.20
0.0654 J65
0404-1.10
24.9300
L
L
34*00
L
04300
04205-140
04600
04300
43M7.90
24000
0411-154
04214.067
N/A
L
N/A
L
04544JO
N/A
04(7-2.90
L
L
L
L
L
L
L
L
3.40-25 JO
N/A
L
L
L
04114429
L
041000
0.00(00
3.70-76.70
3.40-17.20
0.024.13
0.00200
L
L
043344(1
N/A
"L
L
0.003443*
04014403
L
N/A
L
L
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
K
L
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Record of Decision
Kalama NFL Site
Page 21
After the KSCI study area sampling investigation was completed, a
large quantity of analytical data was available. Each sample,
from the various media, was analyzed for the presence of TCL and
TAL constituents, and many of these chemicals were detected. EPA
guidance (1989) states that chemicals of concern may be
identified at a site under evaluation to streamline the exposure
assessment process and subsequent risk characterization. In
order to identify potential chemicals of concern (COCs),
standardized data evaluation procedures must be employed. These
procedures are:
Evaluation of analytical methods
Evaluation of quantitation limits
Evaluation of qualified and coded data
Evaluation of chemicals in blanks
Evaluation of tentatively identified compounds
Comparison of samples with background
The outcome of this evaluation.*for COCs.was (1) the
identification of a set of chemicals that are likely to be KSCI
Site-related and (2) reported concentrations that are of
acceptable quality for use in the quantitative risk assessment.
Chemicals remaining after this evaluation may be carried through
the quantitative risk assessment and are referred to as chemicals
•of potential concern.
As a result of the RI, specific locations of chemicals in the
groundwater, surface water, sediment and soil have been
identified. Chemicals detected at least once in each medium are
shown in Table 6-1 and are discussed in the following
subsections. A total of two hundred fifty-one
samples were collected from the various' media at the KSCI study
area. These samples were analyzed for TCL and TAL parameters
(over 100 compounds). Thirty-nine organic chemicals and twenty
inorganic chemicals were detected in these samples. A
description of the methodology and results of the environmental
monitoring investigation is presented in the RI, Volume 1 of the
RI/FS Report, which can be foun£ in the Information Repository.
Because of the potential for contact with these chemicals given
potential current and future land use exposure pathways, all
chemicals detected in their respective media were initially
considered in the selection of COCs. Chemicals of concern are
those chemicals detected which are most toxic, mobile,
persistent, and are present in significant concentrations.
Chemicals selected as COCs are the focus of the toxic ity
assessment, exposure assessment, and risk characterization.
Other factors considered in selection of COCs were frequency of
detection, physical properties of the chemicals, potential
carcinogenicity, and qualitative assessment of relative chemical
concentration and toxicity.
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6.2«I Potential Con.i''1*11"r>**T|'t8 of Concern i** Soils
Twenty-five organic and seventeen inorganic chemicals were
detected at least once in soils at the KSCI study area. The
frequency of detection, range of concentrations, and background
values for each chemical detected also are presented in Table 2-3
of the RI. Twenty of the organic chemicals identified in soil
samples have been included as COCs to be carried through the
quantitative risk assessment process. The remaining five organic
compounds (benzyl alcohol, 4-methyl-2-pentanone,
di-n-octylphthalate, styrene, 1,1,2-trichloroethane) were
excluded from the risk characterization because they either were
detected infrequently (i.e., once in eighty-three samples),
and/or were present at low concentrations (i.e., qualified as an
estimated value), and/or their relative toxicities were low. Ten
inorganic chemicals (arsenic, barium, cadmium, chromium, copper,
lead, manganese, mercury, nickel and vanadium) were carried
through the quantitative risk assessment.
The remaining seven inorganic compounds were excluded from the
risk characterization because they reflect naturally occurring
compounds, were detected below background levels, were detected
infrequently, and their toxicities were low.
6.2«2 Potential Con'*'*tTi"'T>*>T>ts of Concern j** Se^^^ents
#"
Table 2-6 of the RI lists each chemical detected at least once,
along with the frequency of detection, and range of
concentrations for each chemical detected in sediments at the
KSCI study area and the designated off-Site sampling points.
Twenty-five organic chemicals ,and nineteen inorganic chemicals
were detected in the sediment samples collected. Of the
twenty-five organic chemicals detected, twenty-one were carried
through the quantitative risk assessment. Butylbenzyl phthalate,
hexanone-2, 4-methyl-2-pentanone, and vinyl acetate were not
evaluated quantitatively in this risk assessment. These
chemicals were eliminated from the quantitative risk assessment
based primarily on frequency of detection (all four were detected
only once), qualitative assessment of concentration (only
estimated values were reported), and low toxicity. As with the
soils, arsenic, barium, cadmium, chromium, copper, lead,
manganese, mercury, nickel, vanadium, antimony, and beryllium
were included for evaluation during the risk assessment. The
remaining inorganic chemicals were eliminated from the
quantitative risk assessment based on evaluation of natural
occurrence, concentration, and toxicity.
6.2.3 Potential Cont*"»*****"ts of Concern **» crt>undwater
Twenty-eight organic chemicals and twenty-one inorganic chemicals
were detected in groundwater samples collected at the KSCI study
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area and designated off-Site wells. Table 2-5 of the RI lists
the chemicals detected, the frequency of detection, range of
concentrations detected, and drinking water criteria. Of the
twenty-eight organic chemicals detected, six (bromomethane,
2-hexanone, vinyl acetate, trans 1,3-dichloropropene, isophorone,
and 2,4-dimethylphenol) were excluded from the quantitative risk
characterization. These compounds were excluded from the
quantitative risk characterization based either on frequency of
detection (detected once or twice out of eighty-four samples)
and/or qualitative assessment of concentration (present at only
low, estimated value concentrations) and toxicity. Arsenic,
cadmium, chromium, lead, mercury, nickel, barium, beryllium,
copper, selenium, silver, and vanadium detected in groundwater
were included in this quantitative risk assessment. The
remaining inorganic constituents detected in the groundwater were
eliminated from the risk assessment based on evaluation of
natural occurrence, frequency of detection, concentration, and
toxicity.
6.2.4 Potential Con'fcJ*|B'*tiaT|^B of Concern in SMT*face Water
Table 2-6 of the FS lists each chemical detected in surface water
at the KSCI study area, or in the^ designated off -Site sample
point. It also includes the frequency of detection, range of
•concentration for each chemical, and the respective water quality
criteria value. Seventeen organic chemicals and nineteen
inorganic chemicals were detected? in surface water samples. Of
the seventeen organic chemicals detected, four (2-hexanone, vinyl
acetate, methyl phenol, and 4-methyl-2-pentanone) were excluded
from the qualitative risk assessment. These compounds were
excluded based on frequency of detection (detected only once) and
concentration. As has been the case with the previous media
discussed, antimony, arsenic, barium, beryllium, cadmium,
chromium, copper, lead, manganese, mercury, nickel, and silver
were evaluated during the quantitative risk assessment. The
remaining inorganics detected in surface water were eliminated
from the risk assessment based on evaluation of natural
occurrence, frequency of detection, concentration, and toxicity.
g,2.5 Identification of Coivfc*MB'i****T*'fc-s of Concern STtfnnia'rv
A number of steps were employed in order to develop confidence
that key Site-related COCs were identified in the RI. A summary
is presented below:
• Sample numbers, types, and locations were specified in an
EPA-approved Work Plan dated November 1988, a Project
Operation Plan dated February 1989, and a supplemental Work
Plan dated October 1991.
• Each medium was sampled for TCL/TAL constituents.
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• CLP protocol was used for sample analysis.
• Data quality was evaluated according to EPA guidance
(1989).
Selection of COCs is summarized here and detailed in Section
6.2.4. For soils, toxicologically significant inorganic analytes
were included in the evaluation if one of two concentration
guidelines was met. The analyte was included if the
concentration detected at a sampling Site exceeded that of a
designated background location, or, if the sample concentration
exceeded the expected inorganic background levels described in
United States Geological Survey Paper f!270 (Shacklette and
Boemgen, 1984). Exposure point concentrations were calculated
using the 95% upper confidence limit on the arithmetic average
assuming a log normal distributed contamination pattern.
For groundwater data, all inorganic target analytes were
addressed if their detected level at any sampling site exceeded
the applicable May Jim"" Contaminant Level (MCL) or Secondary
Contaminant Level (SMCL) standard. An exception was made
in the case of iron which exceeded the SMCL, but was not included
in the summary table. This compound was excluded from further
consideration because of its low potential toxicity and because
•its presence appears to be the result of high natural
concentrations of iron (i.e., found in background wells) rather
than from anthropogenic sources. * Inorganic target analytes
detected that are carcinogens also were addressed regardless of
the level detected at any sampling location. Similar criteria
were used for the inclusion of target organic compounds in the
selection of groundwater COCs. All organic compounds detected
that exceeded an applicable MCL or MCLG' (maximum contaminant
level goal) standard were included. All organic target compounds
detected that are carcinogens were addressed, regardless of the
level detected. ;
Additional evaluation criteria for inorganic and organic
compounds included frequency of /detection, physical properties of
the chemicals, potential carcinogenicity, and qualitative
assessment of relative chemical concentration and toxicity.
This evaluation produced groups of chemicals which are known or
suspect carcinogens and/or known or suspect causative agents of
chronic human health hazards . These groups of chemicals were
evaluated quantitatively to estimate potential risks to human
health associated with current and possible future use of the
KSCI study area.
6.3 ISxposwyg* Apsessment
An important step in determining potential risks to human health
and the environment is the identification of actual and potential
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exposure pathways. Only complete exposure pathways are
considered for the purpose of determining risks and for
developing target concentrations. To be complete, an exposure
pathway must have four components:
• A source of chemical release;
• An environmental transport medium;
• An exposure point for human or non-human receptors;
and,
• A likely exposure route.
If any one of these components is not present, the exposure
pathway is incomplete and would not contribute to the total
exposure from the Site.
Because complete exposure pathways are present at the KSCI study
area, an exposure assessment was conducted. Exposure pathways
are shown in Table 6-2. The objectives of the exposure
assessment included: „> .
• Identify actual or potential routes of exposures to
contaminants;
• Characterize exposed human and environmental
populations; and,
• Determine the extent of actual or potential exposure.
#'
6.4 To'^citv .Assessment of Con'*'*r|n''Tia'n'*'g
In Section 4 of the BRA, the toxic effects of contaminants were
investigated and evaluated. The critical variables needed to
calculate estimates of risk were obtained from the EPA
toxicological database (IRIS and BEAST). Critical toxicity
values for the Kalama Site contaminants are presented in Tables
4-2, 4-3, 4-4, and 4-5 within the BRA.
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 (mg/kg-day)'1,
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 uncertainty factors have been
applied. RfDs and slope values are listed in Table 7-4.
The reference dose (RfD) used in estimating non-carcinogenic risk
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Table 6-2
EXPOSURE PATHWAYS
BASELINE RISK ASSESSMENT
KSCI STUDY AREA
EXPOSURE MEDIUM/
EXPOSURE ROUTE
RESIDENTIAL
POPULATION
INDUSTRIAL
POPULATION
RECREATIONAL
POPULATION
CURRENT USE
ONSTTE SURFACE WATER/
INCIDENTAL INGESTION
DERMAL CONTACT
OFFSITE SURFACE WATER/
INCIDENTAL INGESTION
DERMAL CONTACT
ONSTTE SEDIMENT/
INCIDENTAL INGESTION
DERMAL CONTACT
OFFSITE SEDIMENT/
INaDENTALINGESnON
DERMAL CONTACT
SURFIdALSOIl/
INCIDENTAL INGESTION
DERMAL CONTACT
SUBSURFACE SOIL/
INODENTAL INGESTION
PARTICUIATE INHALATION
DERMAL CONTACT
ONSTTE SURFACE WATER/
INCIDENTAL INGESTION
DERMAL CONTACT
OFFSTTE SURFACE WATER/
INaDENTALINGESnON
DERMAL CONTACT
ONSTTE SEDIMENT/
INaDENTALINGESTION
DERMAL CONTACT
A
A
C
C
C
C
C
C
C
C
C
C
C
C
FUTURE USE
OFFSITE SEDIMENT/
INaDENTALINGESTION
DERMAL CONTACT
SURFIOALSOIU
INODENTAL INGESTION
DERMAL CONTACT
PARTICULATE INHALATION
SUBSURFACE SOIL/
DERMAL CONTACT
INODENTAL INGESTION
GROUNDWATER/
INODENTAL INGESTION
DERMAL CONTACT
VAPOR INHALATION
C
C
C
C
C
C
C
C
A.C
AC
A.C
AC
C
A.C
AC
A.C
C« eXNSUIlE m CWLOKEN MAY K StCNmCANILY CREAIElt THAN ADULTS
A. EXKSURE IN ADULTS
—•EXKBUIlEOFTHBPOrULATIOHVtATHBIlOUTESMOTLntEl.YTOOCCUIl
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is an estimate of the daily dose of a substance to which
individuals may^ be exposed without appreciable risk of health
effects. It is' expressed as mg/kg-day. RfDs are based on human
epidemiological studies or animal studies, and have built-in
uncertainty factors that prevent underestimation of potential
adverse effects.
In estimating carcinogenic risk, a slope factor (SF) is used to
estimate the Tnavjtn"tn excess cancer risk posed by a lifetime of
exposure to carcinogens. The SF is an estimate of the dose-
response curve at very low doses, and is extrapolated from dose-
response data at high doses.
Carcinogenic contaminants are classified according to EPA's
weight-of -evidence system. This classification scheme is
summarized below:
Group A: Known human carcinogen.
i* •
Group Bl: Probable human carcinogen, based on limited human
epidemiological evidence .
Group B2: Probable human carcinogen, based on inadequate
human epidemiological evidence but sufficient
evidence of carcinogenicity in animals.
v.
Group C: Possible human carcinogen, limited evidence of
carcinogenicity in animals.
Group D: Not classifiable due to insufficient data.
Group E: Mot a human carcinogen based on adequate animal
studies and/or human epidemiological evidence.
* **"
6.5 pi sic
The final step of the generation of numerical estimates of risk,
was accomplished by integrating the exposure and toxicity
information. Tables .5-1, 5-2, 5-3, and 5-4 of the Baseline Risk
Assessment present the total hazard quotient (non-carcinogenic
risk) and total cancer risk associated with the Site.
To estimate non-carcinogenic risk, hazard quotients (HQs) are
calculated for each contaminant in each exposure pathway. The HQ
is the ratio of the daily intake divided by the RfD. An HQ value
equal or close to unity, (1), indicates the potential for adverse
effects. For each pathway, the individual contaminant HQs are
added together to give a total hazard index (HI). Under a
reasonable worst-case scenario, a person could be exposed to more
than one pathway (for example, while gardening, dermal and
incidental ingestion of shallow soil). Therefore, the total HI
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for each population is a summation of all the exposure pathways
for each constituent. The El provides a useful reference point
for gauging the 'potential significance of multiple contaminant
exposures within a single medium or across media.
Carcinogenic risk estimates are generated in similar fashion for
exposure pathways and populations. EPA has established an excess
risk range of 1 x 10"4 to 1 x 10~* as acceptable and sufficiently
protective of human health and the environment. An excess
lifetime cancer risk of 1 x 10"6 indicates that, as a plausible
upperbound, 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.
To characterize potential risks to human health associated with
the KSCI study area, results of the toxicity and exposure
assessments have been integrated. Possible human intake, by
substance and pathway, is estimated in order to predict the
potential human health hazards posed by existing and potential
levels of chemicals of concern. The resultant quantitative
information, qualified with assumptions and uncertainties, is
intended to assist in the development of remedial alternatives
for the KSCI study area.
.
Known or suspect carcinogens identified at the KSCI study area
are:
Arsenic 1,2 -Dichloroethane
Benzene , ' 1,1-Dichloroethene
Beryllium Lead
Bis (2-Ethylhexyl) phthalate Nickel
Cadmium • Methylene Chloride
Carbon Tetrachloride Trichloroethene
Tetrachloroethene Vinyl Chloride
Chloroform
Chloromethane
Chromium VI
Cancer risk estimates were developed using the exposure pathways,
estimated GDI (chronic daily intake), and the toxicity values.
The cancer risk estimate for current land use is presented in
Table 5-1 of the BRA, and that for future land use is presented
in Table 5-2. Adult and child exposure pathways were summed to
obtain total cancer risks. All raw calculations of risk were
carried out to two or more decimal places. However, in
accordance with the Risk Assessment Guidance, all estimates of
risk are expressed as one significant figure only. Values were
rounded as follows: decimal values equal to or greater than .5
were rounded up to the next higher whole number, and decimal
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values less -than .5 were rounded down to the next lowest whole
number.
* *
For the current land use scenarios, the total exposure risk is
7 x 10~5 of which 6 x 10~5 represents the pathway risks for dermal
.contact with and ingestion of sediment. This total exposure risk
is within the Super fund remediation goal range of 10"4 to 10"* set
forth in the National Contingency Plan (KCP). In the future risk
scenarios, the total exposure risk is 6 x 10"3. That also is the
total pathway risk for ingestion of groundwater; excluding that
route, the sum of other future pathway risks is 9 x 10~5. The
potential cancer risk of 6 x 10~3 for future use is elevated in
comparison to NCP goals, resulting in a total exposure risk which
is out of the NCP range, unacceptable without remediation.
In addition to on-Site current and future land use scenarios,
cancer risk estimates were developed for of f -Site surface water
and sediment in the "L-shaped" ditch. For the current use
off -Site scenarios, the total ^exposure risk is 3 x 10~7. Dermal
contact with off -Site sediments (2 x 10~7) represents the primary
pathway risk. In the future risk off -Site scenarios, the total
exposure risk is 1 x 10"7. Dermal contact with off -Site
sediments (1 x 10~7) represents the primary pathway risk. Both
of these total exposure risks are less than the Superf und
-remediation goal range of 10"4 to 10"6.
The cancer risk associated with -ie KSCI study area is strongly
driven by the route of exposure,' with its attendant assumptions
and uncertainties. In either current or future use evaluation,
the total exposure risk is representative of one or two pathways ,
not the additive total of all pathways. In other words, one or
two pathways (dermal contact and ingestion of sediment for
present use; groundwater consumption for future use) constitute a
larger potential risk than the sum of other possible pathways.
. tiT*ni iaga-nd Index
In addition to known and suspec£ carcinogens, additional
contaminants of concern were identified based upon possible
non-carcinogenic health effects. Using the exposure pathways and
estimated GDI discussed in Section 3.4.2 of this ROD and the
toxicity values presented in Tables 4-2 and 4-3 of the BRA,
chronic hazard index estimates were developed. The estimated
chronic hazard index for current land use is presented in Table
5-3 of the BRA, that for future land use is presented in Table
5-4 of the BRA. Adult and child exposure pathways were summed to
obtain the total HI. All raw calculations of risk were carried
out to two or more decimal places. However, in accordance with
the Risk Assessment Guidance, all estimates of risk are expressed
as one significant figure only. Values were rounded as follows:
decimal values equal to or greater than 0.5 were rounded up to
the next higher whole number, and decimal values less than 0.5
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were rounded down -to the next lowest whole number.
For current land use scenarios, the estimated total non-cancer
hazard index is 2 x 10°, which exceeds the NCP goal of 1. The
major contributing pathway is ingest ion of on-Site sediments
(hazard index e 0.7); secondary pathways include ingestion of
surficial soil (hazard index = 0.2) and ingestion of on-Site
surface water (hazard index = 0.2). The influence of two primary
compounds, arsenic (hazard index = 0.4) and antimony (hazard
index = 0.5) was greatest. In the future use scenarios, the
estimated total non-cancer hazard index is 7 x 101. This total
risk is representative of a single exposure pathway, ingestion of
groundwater (hazard index = 7 x 101). For current and future use
chronic health hazards, risk appears to be directly related to
the route of exposure.
As with cancer risk estimates, chronic hazard index estimates
were developed for surface water and sediment in the "L-shaped"
ditch. For the current use off-Site scenarios, the total
exposure risk is 5 x 10"2, which primarily is representative of a
single exposure pathway, ingestion of off-Site sediment (hazard
index 3 x 10"2). In the future risk off-Site scenarios, the
total exposure risk is 1 x 10~2. Both the off-Site current and
future use total exposure risks are less than the NCP goal of 1.
6.6 Bnv»Tr*QTrmental (Ecological) Risks
_#
This section provides a qualitative appraisal of the actual or
potential effects of chemicals present at the KSCI study area on
the environment. The purpose of this section is to provide
information on threats to the natural environment associated with
the chemicals of concern under baseline'conditions (no-action).
The objectives of the environmental assessment were to:
• Conduct an environmental exposure analysis;
• Review ecotoxicity data; and
• Qualitatively characterize risk.
*
t
This exposure analysis focuses on three ecosystems identified for
the KSCI study, which are:
• The KSCI operations area, including the abandoned
lagoon system and tile field;
• The aquatic environment, comprising the abandoned
sanitary oxidation pond, Benton's smaller pond, and
ephemeral waters of the ditch and low areas of the
Site; and,
• The forested area, including all terrestrial/wetland
habitats in the study area other than the KSCI
operations area.
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There are no listed endangered species in the study area, and
there is no designated critical habitat for endangered species
near the Beaufort area.
6.6.X gmrmiary r>f Potential BHVJ T*O*»">ental ^TPO8P''^g»P
Based on evaluation of the environments on the KSCI study area,
the most important exposure routes affecting flora and fauna are:
• Dermal contact with or ingestion of soil and organic
matter at the operations area; and
• Dermal contact with or ingestion of surface waters,
sediments, and organic matter in the ditch.
Secondary exposures which will primarily affect predators from
all environments include:
• Consumption of prey that has had extended contact with
or ingested chemical-containing soil and organic
matter; and
• Consumption of aquatic organisms.
-Low-level or low-probability exposure includes:
• Fredation of contaminated organisms by migrating
animals, or animals with 'extended range.
Also of concern may be the chronic effects to the flora and fauna
of the KSCI study area as a result of bioaccumulation and
biomagnification of organic and inorganic compounds.
Comparison of these values with the calculated exposure point
concentrations used during the human health evaluation indicates
that - at least for these chemicals of concern - it is not likely
that exposure to concentrations found at the KSCI study area will
produce a significant adverse effect. In reviewing toxicity and
monitoring data for human health effects, risk estimates were
made for potential mammalian and/or human health effects due to
soil (Section 6.2.1), sediment (Section 6.2.2) and groundwater
(Section 6.2.3). These risk estimates, while primarily focused
on human health, provide a qualitative risk estimate for most
wildlife species found at or near the KSCI study area. It can be
concluded that aquatic organisms in surface water are not at risk
from exposure to these compounds.
For the current land use of the study area, the total
carcinogenic exposure risk is 7 x 10"5 of which 6 x 10~5
represents the pathway risk for dermal contact and ingestion of
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sediment. Because there is no current groundwater use, there is
no current pathway risk for ingestion of groundwater. In the
future risk scenarios (assuming a future residential use), the
total carcinogenic exposure risk is 6 x 10~3, which also is the
total pathway risk for ingestion of groundwater (assuming
residents drinking groundwater from the water table aquifer);
excluding that route, the sum of other future pathway risks is
9 x 10"5. The greatest contributor to the carcinogenic risk is
1,2-DCA with a value of 5 x 10~3. The potential cancer risk of
6 x 10~3 for future use is above the goals of EPA's National
Contingency Plan (NCP), Federal Regulations which guide cleanups
at Superfund Sites.
In addition to on-Site current and future land use scenarios, the
Baseline Risk Assessment develops cancer risk estimates for
off-Site surface water and sediment in the "L-shaped" ditch. For
the current use off-Site scenarios, the total exposure risk is
3 x 10~7. Dermal contact with off-Site sediment represents the
primary pathway risk (2 x 10~7)«> In the .future risk off-Site
scenarios, the total exposure risk is 1 x 10~7, which also is the
pathway risk for dermal contact with off-Site sediments.
The cancer risk associated with tlje KSCI Site is predicted based
on the route of exposure, with several assumptions and
-uncertainties. In both the current or future use evaluations,
the total exposure risk is representative of a single pathway,
not the additive total of all pathways. In other words, one
pathway (dermal contact for present%use; groundwater consumption
for future use) constitutes a larger potential risk than the sum
of other possible pathways.
For current land use scenarios,, the estimated total non-cancer
hazard index is 2, which exceeds the NCP goal of 1. This total
represents the additive sum of three primary exposure pathways:
ingestion of surficial soil (hazard index = 0.2)-; ingestion.of
on-Site sediments (hazard index = 0.7); ingestion of on-Site
surface water (hazard index « 0.2); and the influence of two
primary compounds t arsenic (hazard index = 0.4) and antimony
(hazard index = 0.5). In the future use scenarios, the estimated
total non-cancer hazard index is 70. This total risk is
representative of a single exposure pathway, ingestion of
groundwater (hazard «= 70). Thus current and future use chronic
health hazards are directly related to route of exposure.
Chemicals of concern that produced the greatest non-cancer risks
include ethylbenzene, mercury, antimony, 1,1-DCE, cadmium,
arsenic, and nickel.
Similarly to the calculation of cancer risk estimates, the BRA
also develops chronic hazard index estimates for surface water
and sediment in the "L-shaped" ditch. For the current use
off-Site scenarios, the total exposure risk is 5 x 10~2, which is
representative of the pathway risk for ingestion of off-Site
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sediment (HI = 3 x 10~2) . In the future risk off -Site scenarios,
the total exposure risk is 1 x 10~2. In the current and future
use off-Site scenarios, the non-cancer risks associated with
these media fall within the NCP Superfund goal range of less than
1. Comparison of textbook values with predicted concentrations
indicates that it is unlikely that either plant or wildlife at
the Site will be negatively affected.
Actual or threatened releases of hazardous substances from this
Site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
7.0 REMEDIAL ALTHHMATIVES
7.1 Romorf •? aJ. Objectives jmd Goals
Based on the RI and the Risk Assessment, the following two sets
of remedial action objectives for the Kalama Site were developed:
For Source Control
•jf,
* Prevent or mitigate the release of contaminants that
would result in groundwater concentrations at levels
above the M«XJ *"»•"" Contaminant Levels (MCLs).
*'
* Reduce risks to human health associated with dermal
contact or ingestion of the contaminated soils and
inhalation of soil particulates to less than one for
chronic hazard (HI) and to between 10"4 and 10"6 for
carcinogens . , ;
* Reduce contaminant concentration in the soil to levels
that are safe for environmental receptors that may come
in contact with soil contaminants.
For Gronndwater Control •
H^SflH^ —«^ ™»S-S5«^B»— t
* Prevent off-Site migration of groundwater containing
contaminants above HCLs •
* Prevent ingestion of groundwater from the water table
aquifer containing chemicals of concern where the
chronic hazard risk is more than one and the MCL is
exceeded.
EPA has established specific remediation goals (RGs, or cleanup
standards) for certain soil, groundwater, and surface water
contaminants. Such standards are established under several
federal environmental laws, including the Safe Drinking Water Act
(for water systems and potable water sources such as groundwater)
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and the Clean Water Act (surface waters). South Carolina has
similar statutes. Some of the contaminants regulated under these
standards are present at this Site. In cases where there is no
state or federal standard, such as soil and sediments,
remediation goals were developed in the FS based on human health
risks (risk assessment calculations) for direct contact with the
contaminant or the contaminants' leachability potential. This
second method produces a cleanup goal for the level of the
chemical in the soil based on acceptable concentration of the
chemical in the groundwater due to leaching.
Cleanup goals were calculated under both methods at the Kalama
Site with the more conservative cleanup goal retained. The
remedial goals and quantitative cleanup standards for the Kalama
Site are attached to this Record of Decision as Tables 7-1 and
7-2. Further discussion of how the standards were derived is
contained in Chapters 8 and 9 of this Record of Decision. Health
based target levels for soil clean-up (Table 7-3) and soil
cleanup goals based on leaching'(Table 7-4) were the basis for
the final soil cleanup levels.
7.2 Development of P^"*edial Alternatives
• In the Feasibility Study, separate remedial alternatives were
developed and evaluated for control of soil/sediment
contamination and groundwater contamination. To formulate the
cleanup alternatives, all of the'possible technologies, processes
and methods which could be utilized in a cleanup effort were
evaluated, and those which could not be used at the Kalama Site
were screened out. The screening criteria employed are primarily
Site-specific factors that make some technologies or processes
ineffective, difficult to implement, or infeasible. Such factors
include soil type, geology/hydrogeology, Site location, and the
area or volume of contaminated media. Technologies and processes
considered to be potentially useful were then grouped together
into various combinations of soil/sediment contamination remedial
alternatives (also identified as; source controls) and groundwater
remedial alternatives (migration controls). Then, the viable
combinations of alternatives were evaluated and compared against
one another in detail.
7.3 So«*T'ee Control Alternatives
This section provides a description of the seven alternatives
(SC-1 & SC-1A through SC-6) for source control (contaminated
soils and sediments). Table 7-5 summarizes the Source Control
Alternatives.
7.3.1 SC-1 - Ho-Action
The no-action source control alternative provides a baseline by
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Record of Decision
Kalnma HPL Site
Page 35
Tables 7-1 and 7-2
Table 7-1
REMEDIAL GOALS FOR
KSCI STUDY AREA
GROUNDWATER
• On site contaminants reduced to MCLs and a chronic hazard index of less than 1.
• Exposure to contaminated groundwater which presents an unacceptable risk is prevented.
SOILS/SEDIMENTS
• Migration will be prevented by removal, treatment or in-place capping of identified source areas.
• Contact with or ingestion of the remaining .contaminated soils that present an unacceptable risk is
prevented. ^».
Table 7-2
REMEDIAL GOALS FOR PRINCIPAL CONTAMINANTS OF CONCERN
Chemical
Groundwater fug/1)
Soil/Sediment (mg/kg)
VOCs *
Benzene
Toluene
Ethylbenzene
Xylenes
1 ,2-Dichloroethane
Metbylene Chloride
Vinyl Chloride
1,1-Dichloroethene
5
-
700
10.000
5
5
•
7 -
ND
4
7
60
ND
ND
- ND
0.023
SEMI- VOCs
Benzoic Acid
_
25.000
METALS
Antimony
^^f^rflmff*
Lf%d
Nickel
Mercury
•
.
_
_
-
Remedial goals shown in one significant figure, refer to tables 2-12 and
3
40
500
140
2
i 2-13 for calculated values.
NOTE:
ND: Calculated value below respective method detection limit and/or MCL. Non-detect results obtained
from validated CLP protocol will serve as cleanup goal.
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Record of Decision
Kalama NPL Site
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Table 7-3
Cleanup Goals for Organic Compounds in Soil
teased on Leaching of C intaminants from Soil into Groundwater
At the KSCI Study Area
I
1
i Chemical
! Acetone
•Benzene
Benzoic Acid
Bis(2-Ethylhexyl)Phthalate
Butanone.2-
Carbon Disulfide
i Carbon Tetrachloride
jChlorobenzene
iChloroethane
[Chloroform
Chloromethane
jDichloroethane.1 .2-
Dichloroethene.1.1-
Dichloroethene.1 .2-
Di-N-Butylphthalate
Dinitrophenol
•Ethylbenzene
IFluoranthene
Methylene Chloride
Phenanthrene
Pyrene
Tetrachloroethene
Toluene
Trichloroethane.1 .1 .1-
Trichloroethene
Vinyl Chloride
Xylene-m
Xylene-o
Xylene-p
Drinking
Water
MCL
(mg/1)
N/A
0.005
N/A
0.004 •
N/A
N/A
0.005 »
0.1
N/A
0.1
N/A *
0.005
0.007
0.07 j-
N/A '
N/A
0.7
N/A
0.005 *
N/A
N/A ;
0.005
1
0.2 ;
0.005
0.002
10 ••
10 ••
10 "•
Soil-Water
Equil. Coef.
Kd
0/kg)
0.0023
0.24
0.16
30
0.59
- 0.58
0.11
0.083
0.11
0.091
0.55
0.098
—
1.59
49
0.061
—
...
. 0.76
0.61
0.39
0.38
1.74
1.44
0.91
1.36
Potential
Target Soil
Concentration
(mg/kg)
N/A
0.0073
N/A
0.73 !
N/A
N/A
0.018
N/A
N/A
0.050
N/A
0.0027
0.023
0.042
N/A
N/A
6.7
N/A
0.0018
N/A
N/A j
0.023
3.7
0.47
0.011
0.021
87
55
82
Target soil concentrations based on attainment of ARARs in groundwater.
Assumptions: ;
Qp « volumetric flowrate of infiltration (ft3/day) •
Qgw m volumetric flow rate of groundwater (ft3/day) >
Soil MCL » MCLgw • Kd*(Qp * Qgw)/Qp
Notes:
28.6
144
• « Proposed MCL
• ° « MCL for total xylenes
N/A denotes chemical which does not have an established MCL or PMCL:
therefore, the compound was not carried through this evaluation.
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Record of Decision
Kalama NPL Site
Page 37
Table 7-4
POTENTIAL HEALTH BASED TARGET LEVELS FOR SOIL
RESIDENTIAL FUTURE USE CONDITIONS FOR DIRECT CONTACT
KSCI STUDY AREA
A. POTENTIAL CARCINOGENS
COMPOUND
SLOPE FACTOR
(MG/KG/DAYM
TARGET SOIL CONCENTRATION (me/kg)
TARGET RJSK LEVEL
(10-6)
.Benzene
1 Bb(2-EtbylhexyDPhthaUte
| Chloroform
: DkhloroeUune-1,2
• Diehloroethene-1,1
; Methylene chloride
! Vinyl Chloride
2.9E-02
1.4E-02
6.1E-03
9.1E-02
6.0E41
7.5E-03
43E+00
0.558
1.155
26.529
0.178
0.027
2.157
0.008
B. NONtARCINOGENS
i COMPOUND
i
Acetone
; Antimony
: Arsenic
• Barium
Benzok Acid
Bis(2-EthylhexyI)Phthalate
BuUoooe-2
Cadmiup*
Chlorobenzene
Chloroform
Chloromethane
Chromium
Dichloroethene-1,1
Pi-N-Putr'rhthatalT
Dinitropbeool
Ethyl benzene
Fhioranthene
Manganese
Mercury
Methylene chloride
Nickel
Pbenanthrene
ffu - , - •
i jicoe
Toluene
Trichloroethane-1,1,1
Vanadiom
Xylena
Lend
i REFERENCE
1 DOSE :
! (MG/KG/DAY)
l.OE-01
4.0E-04
3.0E4M
, 5.0E-02 '
4.0E+00
2.0E-02
5..0E-02
5.0E-04
2.0E-02
l.OE-02
1.DE43
5.0E-03
9.0E-03
l.OE-01
2.0E-03
l.OE-01
4.0E-02
l.OE-01
3.0E-04
6.0E-02
2.0E-02
6JE-02
3.0E-02
2.0E-01
9.0E-02
7.0E-03
Z.OEfOO
TARGET SOIL
CONCENTRATION
(mt/kz)
692.191
2.768 :
2.076
346.095
27687.646 :
138.438
346.095
3.461 -
138.438
69.219
6.921
34.609
62.297
692.191
13J43
692.191 1
276J76
692.191
2.076
415.315
138.438
470.690
207.657
1384.382
622.972
48.453
13843.823
500.00
Lead value from EPA guidance,
-------
SUMMARY OF ALTERNATIVE COMPONENTS SCREENING
KALAMA SPECIALTY CHEMICALS, INC. STUDY AREA
SOURCE CONTROL
g
M
ID
I
Ul
Alternative
Component
SC-I
SC-1A
SC-2
SC-3
SC-4
SC-5
SC4
\
±
Description
No Action
Limited Action
Construct RCRA cap on
source loih, Till ditch
Construct RCRA cap and
thirty will
Soil and tediment excavation,
enhanced volatilization and
solidification
Soil and sediment excavation;
off-site disposal in RCRA
landfill
h silu soil treatment for
volatile organic compounds
Effectiveness
Not effective for protection of human
health and the environment
May be effective for protection of
human health on site hut not the
environment
m » *
Effective and reliable with certain *
land restrictions
Effective and reliable with certain
land restrictions, slurry wall
effectiveness questionable due to
depth required
Effective and reliable. Certain land
restrictions may apply to solidified
soils
Effective and reliable for study area.
No effective reduction of
contaminant volume or concentration
Effective in removing volatile
organics; not effective in removing
non-volatile fraction
Implementability
Can be implemented
Can be implemented
»•
%•
•' 'Can be implemented
Slurry wall may'not be
effective because of
depth to confining
layer
Can be implemented
Can be implemented
but cosily
Can be implemented
Cost
Capital
-0-
$15.000
$195.000
$605,000
$189,000
$495,000
$141.000
Total O&M
•O-
-0-
$5,000
$5,000
$45.000
$5,000
$100,000
Present
Worth
-0-
$15,000
$200,000
$610,000
$234,000
$500,000
$241,000*"
"' Does not include cost for MM-3 which must be used in combination with this component.
to
CO
o
1 H
a
CO
If
ft H-
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Record of Decision
Kalama NPL Site
Page 39
which other source control components can be compared and is a
requirement of the National Contingency Plan (NCP). Under this
technology, no removal or treatment of the contaminated soil will
occur. No additional management controls, such as building
permit restrictions, will be implemented beyond the existing
chain link fence around the former operations area. No-action
would not be effective in reducing the toxicity, mobility, and
volume of the contaminants within the soil. The source areas
could continue to release contaminants into the surrounding
groundwater. The no-action alternative would not attain
remediation goals for soils. The risk of current and future
exposures to contaminated soil due to direct contact would
continue. In the long term, no-action would not be effective in
protecting on-Site workers and the public from future direct
contact with the affected media.
7.3.2 SCVLA — Limited Action. Rezonincr to Prohibit B
i » .• . :
The limited action source control alternative would not involve
any removal or treatment of contaminated soil. Additional
management controls, such as rezonihg from the current
residential zoning and building permit restrictions, would be
implemented to reduce the potential future exposure of on-Site
•workers. The source areas could continue to release contaminants
into the surrounding groundwater.^ Limited action would not
attain remediation goals for soils' v The management controls
would reduce but not eliminate risk of current and future
exposures of individuals to contaminated soil. Rezoning, deed
restrictions, and building restrictions would have to be
implemented at the local government level, with a present worth
cost (PW) of $15,000.
7.3.3 SC-2 — nrRA ap on Source Soils /Fill In Ditch
Alternative SC-2 would use containment technologies to control
exposure to the soils in the former operations area and the
sediments in the "L-shaped" ditch. The cap over the soils that
are contaminated with VOCs and metals would be designed to meet
the requirements of the Resource Conservation and Recovery Act
(RCRA) . The sediments are not considered a source; therefore,
the clay cap would fulfill the intended function, which is to
prevent contact with the sediments. SC-2 would be effective for
reducing risks in the study area by eliminating or greatly
limiting exposure to the chemicals of concern in the soil.
Contaminated soils would be covered, eliminating the risk of
dermal contact, ingest ion, or inhalation of wind blown dust.
This alternative protects human health and the environment.
The clay cap over the soils in the former operations area would
help limit mobility of the contaminants by eliminating
infiltration of rainfall through the area of soil contamination.
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Record of Decision
Kalama NPL Site
Page 40
Leaching of the chemicals would be greatly reduced or eliminated
except where the water table is in contact with the contaminated
soils. Some continued leaching could be expected, hindering
groundwater remediation if such groundwater remediation is used
in combination with this alternative. The volume and toxicity of
the chemicals of concern would not, however, be reduced by this
alternative. This alternative would be effective in both the
short and long term so long as the clay cap is maintained.
This alternative is readily implementable with currently
available technology. Clay caps covered with soil have been
installed in many places, especially at landfills. However, to
minimize wetlands effects, capping and filling of the ditch would
require careful study. The PW cost of this alternative is
$200,000.
SC-3 adds additional source control for -leaching to the controls
proposed in SC-2 by adding a soil bentonite slurry wall. The
components of this alternative, except for the slurry wall, were
described under SC-2. A circumferential vertical barrier or
cut-off wall would be construetedyto surround the area of soil
contamination west of the former reactor pad. The wall would
-extend vertically from land surface to an approximate depth of
75-85 feet. The clay cap would extend over the edge of the
slurry wall, thus preventing infiltration of rainwater. Vertical
barriers can .be constructed from various low-permeability
materials. For the depth needed at the Site, a soil-bentonite
slurry wall is deemed to be the best option. This option would
be effective in providing protection for human health and the
environment by preventing or greatly reducing exposure to the
chemicals of concern. Soils would be covered, preventing dermal
contact, ingestion or inhalation of dust. It also would be more
effective in reducing the mobility of the contaminants than-SC-2
because the chemicals in the soil would be prevented from
directly contacting the uncontaminated groundwater in the water
table aquifer. Mobility of the .contaminated groundwater beneath
the soil would be greatly reduced in the horizontal plane due to
the low permeability of the material in the slurry wall. Because
the contaminated groundwater beneath the cap accounts for only
one percent of the total plume volume these flows would not be
significant. Like SC-2, this alternative would not reduce the
toxicity or volume of the chemicals of concern. The total
initial project cost for Alternative 3 is estimated to be
$610,000.
7.3.5 SC—4 — Soil/Sediment Excavation and Trea'*"tnsiit
This alternative would remove and treat the source soils and
sediments, preventing contact with the chemicals of concern and
eliminating further leaching into the groundwater. Soils in the
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Record of Decision
Kalama NFL Site
Page 41
study area are contaminated with volatile organic chemicals of
concern (VOCs) and metals of concern (lead, mercury/ and nickel).
SC-4 would excavate these sources and the VOCs would be treated
to reduce the contaminant levels to safe levels or non-detection.
An estimated 604 cubic yards of soil would be excavated and
treated along with the 80 cubic yards of sediments in the L-
shaped ditch requiring excavation. Because the organic chemicals
of concern are volatile, on-Site treatment methods that bring air
in contact with the soil piles could be employed to treat them.
The treated soils would be replaced into the excavations. About
50 cubic yards of new fill also would be required. Any soils
contaminated with excessive levels of the metals of concern would
be solidified (chemically fixed) aboveground and replaced into
the excavation. This source control alternative would be
effective in protecting human health and the environment because
it would eliminate dermal contact with chemicals of concern in
the soils/sediments and prevent further introduction of
contaminants into the groundwater system through leaching.
i*-
The mobility, toxicity, and volume of the VOC contaminants in the
soils would be eliminated by this remedial action alternative.
Solidification of the soils would fix the metals, eliminating
their mobility but not their volume or toxicity. Dermal contact,
ingestion or inhalation of dust would be very unlikely with the
-solidified mass. Sediments in the ditch could become
recontam ina ted if this alternative is not used in combination
with a component that controls groundwater contamination. High
groundwater levels are thought to be the source of sediment
contamination in the ditch. Excavation as a means of source
remediation is a technology that has been widely used at
contaminated Sites and can be accomplished with ordinary
earthmoving construction equipment such' as a backhoe or trackhoe
in combination with dump trucks. Treating the soils by enhanced
volatilization transfers contaminants to the air. Treatment
units for the air emissions, such as scrubbers,~can be added, if
necessary, to meet ambient air quality standards. It is not
currently anticipated that such treatment will be necessary.
Above ground solidification for-fixing metals contamination is a
proven technology that is readily implementable. Long-term
reliability of this method is not well known. Leaching tests
intended to simulate long-term conditions have indicated
acceptable results. Total capital costs for SC-4 are estimated
to be $234,000. This alternative was retained for the detailed
analysis.
Because of comments received during the public comment period, a
contingency soil remedy has been retained (SC-5). SC-4 has been
modified to: excavation of the wastes and then a determination
if the waste should be treated on-Site with replacement into the
excavation, or disposed of in a RCRA landfill pursuant to soil
alternative SC-5 below. This alternative was retained for the
detailed analysis. There is concern that while alternative SC-4
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Record of Decision
Kalama NPL Site
Page 42
appears -to be less costly than SC-5 and offers on-Site treatment
to the wastes, that the relatively low estimated volume of
contaminated soils (770 cubic yards), may not attract competitive
bidders for the remediation. Therefore, a contingency soil
treatment alternative (SC-5) has been retained by modifying SC-4
to allow for the disposition of the contaminated soil to be
determined after excavation and field testing.
7.3.6 SC—5 — Soil/Sediment: Excavation and Disnosal nt
This alternative for source control would excavate the soils in
the former operations area that are contaminated with VOCs and
metals, and sediments in the "L-shaped" ditch that are
contaminated with VOCs. These materials would be transported to
a RCRA landfill such as Pinewood, South Carolina, for disposal.
Like SC-4, this alternative would provide human health and
environmental protection for the Site by eliminating exposure to
the chemicals of concern in the soils .It also would prohibit
further leaching into the groundwater. SC-5 is readily
implementable both technically and administratively.
A RCRA landfill, such as the one jat Pinewood, South Carolina, is
permitted to accept soils that are contaminated with VOC's and
•metals. Soils and sediments from the KSCI study area could be
landfilled at Pinewood without pretreatment under the facility's
present permit conditions. The Finewood facility, as of August
1993, is closed to Superfund wastes and location of another RCRA
landfill utilized for any disposal of contaminated soils from the
Kalama Site may be necessary if Pinewood remains closed (and the
contingency soil remedy SC-5 is selected).
t
Total initial project costs for SC-5 are estimated to be
$500,000. This alternative would be ineffective at meeting the
stated program goal of minimizing untreated waste and is more
costly than SC-4, which does meet the goals. Thus, it was not
initially selected. As indicated above in SC-4, SC-5 is retained
as the contingency soil alternative providing disposal off-Site.
This alternative was retained for the detailed analysis.
7.3.7 SC—6 — In-situ Soil Trea*""**»T»t for VOCs
The in-situ vacuum extraction system alternative for the study
area, SC-6, would consist of one vapor extraction well located in
the former operations area near sampling point B-5A. The well
would be connected to a high vacuum pump discharging directly to
the atmosphere. It is anticipated that air quality could be
maintained at the Site without treatment of emissions. It would
be necessary to conduct air dispersion modeling of the
anticipated emissions prior to construction to ensure compliance
with South Carolina Air Pollution Control standards.
Institutional controls, such as fencing, would be used to prevent
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Record of Decision
Kalama NFL Site
Page 43
access to the area of contaminated soils.
The high groundwater table and the low permeability of the soils
at the KSCI study area would greatly limit the effectiveness of a
conventional vacuum extraction system. Under these Site
conditions, a dual extraction system that produces a drawdown of
the water table with a groundwater extraction well while the
vacuum system is operating in the unsaturated zone, must be used
for effective removal of VOCs. Groundwater pump, treat and
discharge (PTD) option MM-3, described later in this Record of
Decision, must be used in combination with SC-6 in order for SC-6
to be effective.
It is anticipated that the vacuum extraction system would operate
for eight months to one year to reach the remediation goals for
VOCs in soils. Total initial project costs for SC-6 are
estimated at $241,000. This alternative was retained for the
detailed analysis in combination with MM-3 (PTD at hot spots) and
MM-4 (PTD to MCLS). *'*•
A summary table of the Source Controls with descriptions,
effectiveness, implementability, and cost is attached as Table
7-5. ?
•4 f^T'OTiTidyater **T ratc?" i*«'n»Qgtii«»nt^ Alternatives
This section provides a description of the five migration
alternatives , MM-1 & MM-1A through MM-4 , and various methods to
control migration of contaminants in the groundwater. Table 7-6
attached, lists all groundwater (migration management)
alternatives .
i
7.4.1 ioc-i — Ho-Action
This no-action alternative would involve no attempt to control
migration of contaminated groundwater. The no-action alternative
would not involve any additional, management controls, except
periodic groundwater monitoring.; Under this alternative, a
groundwater monitoring program would be implemented to track
water quality and movement of the plumes. Selected existing
monitor wells and surface waters would be sampled quarterly for
the constituents of concern. The groundwater/surface water
monitoring program would be instituted at the study area for a
mpyiim«n of 30 years, which is consistent with the long-term
monitoring requirements for closure at RCRA facilities.
The no-action alternative would not be effective in reducing the
toxicity, mobility, and volume of the contaminants within the
groundwater. Therefore, the contaminants could continue to
migrate into the surrounding aquifer or drainage ditches. This
could result in unacceptable risks to public health. Hence, the
no-action activities would not attain any of the remediation
-------
(D
I
a\
SUMMARY OF ALTERNATIVE COMPONENT SCREENING
KALAMA SPECIALTY CHEMICALS, INC. STUDY AREA
MANAGEMENT OF MIGRATION
Alternative
MM 1
MM-IA
MM-2
MM-3
MM-4
Description
No Action
Limited action
Slurry will; pump, (real
•nd discharge In MCL
(30 yean, 20 gpm)
Pump, treat, discharge hot
spots (1 year) concurrent
with in silu toil treatment
Pump, treat, discharge to
MCL (30 yean, 20 gpm)
EITeclivenei*
Not effective
Somewltat effective in reducing
risk but does not meet gnats
Effective in preventing
migration and reducing overall
gruundwater cuntnminalinn*
Partially effective in reducing
overall gmundwaicr
contamination
Effective in reducing overall
groundwaler contamination
Implementahilily
Can he implemented
Can hejfrnplcmenlcjt
Can lie implemented
Can be implemented
Can he implemented
Cost
Capital
'••O-
$15.000
S3.04I.640
$542,000
$1,417.000
Total O&M
$325.124
$325.000
$1.851.527
$386,000
SI, 85 1,500
Present Worth
$325.124
$340.000
$4.893.167
$928.000
$3,268,500
o
o
1*5 p.
4^
fiS O
*w Hi
si
ft r*
(D O
I
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Record of Decision
y?i*ma NPL Site
Page 45
goals for groundwater. As a result, it would not be effective.
The estimated present worth (PW) cost associated with no action
is $325,124 for'monitoring and reporting.
The no-action alternative would not be effective, because it does
not attain remediation goals, protect the environment, or achieve
a reduction in toxicity, mobility, or volume. It is retained as
a baseline consideration, as required by the NCP.
7.4.2 KM—1A — Limited Action. Deed Restrictions and Pltnne
Under this alternative, no removal or treatment of the
contaminated groundwater would occur. The limited action
alternative would include some minimal actions consisting of
management controls, such as deed and well installation
restrictions. In addition, the periodic groundwater monitoring
program described in MM-1 would be implemented. The management
controls would decrease the riaR of current and future exposures
to contaminated groundwater. This limited action alternative by
itself, however, would not be effective in reducing the toxicity,
mobility, and volume of the contaminants within the groundwater.
Therefore, the contaminants could ^continue to migrate into the
groundwater and into the "It-shaped* ditch. This could result in
an unacceptable risk to public health. This limited action would
not attain any of the remediation^goals for groundwater.
Deed and well permit restrictions also would require the
cooperation of the local government. The estimated PW cost
associated with limited action is estimated at $340,000.
t
7.4.3 MM-2 — Sl"Ty Wall. PTD to *rc*r.
This migration management alternative would include installation
of a slurry wall around the plume to retard contaminant migration
and recovery of groundwater via extraction wells. The
groundwater would be treated and" discharged until the MCL
concentrations for contaminants of concern are reached. A low
permeability soil-bentonite slurry wall, approximately 5,000 feet
long and 80 feet deep, would be installed around the plume. The
slurry wall would reduce the mobility of the plume during the
pump and treat period. It is estimated that one to ten
extraction wells with a total flow of 20 gpm would be installed
within the wall. The extraction well system will be designed to
reverse the downward gradients, especially in the 1,2-
dichloroethane (DCA) plume, and effectively capture the
constituents in the plume. This design will eliminate flow into
the limestone aquifer. Pump tests and additional monitoring
wells during the RD/RA will determine the most effective system.
The water would be treated on-Site by two air stripping towers
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Record of Decision
Kalama NPL Site
Page 46
connected in series. The water effluent from the towers would
then be polished by granular activated carbon (GAC) . Effluent
from the treatment system would be disposed of in an on-Site
infiltration gallery or spray field, or be discharged to the
•L-shaped* ditch downstream of station SW-5. HM-2 would operate
until the MCLs for the groundwater contaminants of concern are
reached. Based on the calculation of the number of pore volumes
required to achieve a cleanup of the plumes, the remediation time
is estimated to be 30 years. The slurry wall may not increase
the effectiveness of the overall alternative if a properly
designed extraction network is implemented. MM-4 is the same
alternative without a slurry wall.
This alternative would be effective for protecting human health
and the environment because it would virtually eliminate the
mobility, toxicity, and volume of the contaminated groundwater.
By reversing the downward component of flow in the water table
aquifer, the migration or potential migration of contaminants
into the limestone aquifer would be eliminated. It would be a
permanent solution in that it would satisfy the remediation goals
for the study area, including prevention of groundwater
contaminated above MCLs from migrating off -Site. This
alternative can be implemented, jpirect discharge of the
treatment groundwater to an on-Site sprayf ield or the ditch will
•require compliance with South Carolina and federal discharge
standards. Air emissions from the stripping towers must meet
South Carolina's emission standards for air toxics. Total FW for
MM- 2 is estimated at $4,893,167.' This alternative is the most
expensive one screened, but was retained for the detailed
analysis .
7.4.4 MM— 3 — Short— Term PTD of (r>*OT''ndwRter CongnTent with
Extraction of Soils at Hot Sots
In order for vacuum extraction to be effective -as a soil
treatment technique at the KSCI study area, groundwater would
have to be withdrawn continuously for one year to increase the
depth of the unsaturated zone. *This alternative has the soil
treatment elements of SC-6, and adds groundwater treatment.
Groundwater would be recovered from the former operations area
near sampling point B-5A and from hot spots near monitor wells
MW-46 and MW-49. These areas contain high levels of VOC's. The
groundwater would be treated on Site by precipitation/ filtration,
air stripping and carbon adsorption, then discharged. The three
new extraction wells would have a total withdrawal rate of 9 gpm.
Effluent from the treatment system would be discharged to either
an on-Site infiltration gallery, an on-Site sprayfield, or to the
•L-shaped" ditch downstream of station SW-5.
Groundwater extraction wells would be located and designed to
maximize recovery rates for the contaminants. The controlling
contaminant for the design of the treatment system is 1,2-DCA.
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Record of Decision
Kalama NPL Site
Page 47
It is not anticipated that treatment of the emissions from the
air stripper would be required to maintain air quality during
remediation, but provisions would be made to treat off-gases, if
necessary. The groundwater extraction and treatment system would
be operated for the time required to complete the soil cleanup,
.estimated to be one year. This alternative could provide a
long-term permanent solution by removing and treating a high
percentage of the contaminants in the groundwater at the Site.
This alternative will provide some protection for the public, but
would not achieve the goals of groundwater quality and management
of migration. Discharge of the treated groundwater would result
in a small increase in the contaminants of concern downstream.
However, this discharge would have been treated sufficiently to
protect human health and the environment and to comply with water
quality requirements.
This alternative would reduce the volume and concentrations of
contaminants of concern in groundwater. The proposed treatment
facilities have no unusual -construction or operation
requirements. The estimated PW for this alternative is $928,000.
Although the actions taken under MM-3 would not achieve all the
remediation goals and, therefore,*would not be totally effective,
this alternative offers increased protection of public health
•from ingestion of contaminated groundwater. MM-3 also would be
necessary for dual vacuum extraction and, thus, is retained for
further analysis. .*
7.4.5 MM—4 — PTD to HCIi Concentration
This migration management alternative would be the operation of a
groundwater pump, treat and discharge system until reduction of
the contaminants of concern to MCLs. It is estimated that
groundwater would be withdrawn from extraction wells pumping a
total of 20 gpm. The exact number, locations and design of. the
extraction wells will reverse the downward contaminant movement,
especially in the 1,2-Dichloroethane (DCA) plume, and effectively
capture the contaminants in the /plume. This design will
eliminate flow into the limestone aquifer. Pump tests and
additional monitoring wells during the RD/RA will determine the
most effective system.
The water would be treated on-Site by a system like that
previously described in MM-2. Discharge could be to either an
on-Site sprayfield, an infiltration gallery, or the "L-shaped"
ditch downstream of station SW-5. This alternative would operate
until the MCL concentrations are reached for the groundwater
contaminants of concern. Based on an analysis of the recovery
well locations and the number of pore volumes required to achieve
a cleanup of the plumes, the remediation time is estimated at 30
years. The air stripping and activated carbon technology,
preceded by chemical precipitation/filtration, would be effective
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Record of Decision
Kalama NPL Site
Page 48
at protecting human health and the environment because it would
eliminate or greatly reduce the mobility, toxicity, and volume of
the contaminated groundwater. It would provide a permanent
solution by satisfying the remediation goals for the study area,
including prevention of groundwater contaminated above MCLs from
migrating off -Site. This alternative would provide significant
protection over a no-action alternative, at a total present worth
(PW) for MM-4 estimated at $3,268,500. Figure 7-1 shows
potential locations of groundwater extraction wells.
Attached Table 7-6 lists the migration management (groundwater)
alternatives with their descriptions and a discussion of their
effectiveness, implement ability, and costs.
y. 5 gonT*r*«» «nH Migration y****a*T°iPent Cont"1"ol .Alternative
Combinations
Seven combinations of the seven source control alternatives and
the five groundwater migration»control alternatives were
initially retained for thorough analysis in the Feasibility Study
(FS). Of the twenty total combinations of valid source and
groundwater migration control alternatives, thirteen (13) were
dropped from further consideration after an initial screening of
their anticipated effectiveness and implementability. A
-contingency alternative was developed for this ROD after comments
were received during the Public Comment Period. The seven
remedial action alternatives that*were retained for the detailed
analysis and the contingency alternative are described as
follows :
Alternative 1 (pq-i/MM-i)* No source control action; monitor the
groundwater plumes. Estimated PW cost 6f Alternative 1 is
$325,124.
Alternative 2 (pc-2/iPff-iA)8 Fill the "L-shaped* ditch on the
Benton Property. Construct a RCRA clay cap over the contaminated
soils in the former operations area. Implement deed
restrictions. Rezone the property and monitor the plumes. The
total PW cost of Alternative 2 is $524,848.
Alternative 3 (SC-4/MM-1A) ; Excavation and treatment of
soils /sediments for VOCs and metals by enhanced volatilization
and stabilization/solidification. Replace the treated soils into
the excavations. Implement deed restrictions. Rezone the
property and monitor the plumes. Total PW cost of Alternative 3
is $558,653.
Alternative 4 (SC-4/MM-2); Install slurry wall around plume.
Extraction and treatment of groundwater to the MCLs for chemicals
of concern. Excavation and treatment of soils /sediments for VOCs
and metals by enhanced volatilization and
stabilization/solidification. Total PW cost of Alternative 4 is
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Record of Decision
Kalama NPL Site
Page 49
Figure 7-1
200
BENZENE PLUME
(RISK EXCEEDS IO"4)
[77j 1,2-DCA PLUME
\* S M
(RISK EXCEEDS KT4)
U.S. NAVAL
RESERVE
Imnrrnm
POTENTIAL WELL LOCATIONS FOR REMEDIAL
ACTION COMPONENT MM-3 (3 WELLS; 9 gpm TOTAL)
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Record of Decision
Kalama NPL Site
Page 50
$5,127,167.
Alternative 5 (SC-»fi/*n*—3\« Treatment of soils contaminated with
VOCs by in-situ vacuum extraction. Extraction and treatment of
groundwater in the area of soil contamination (Dual Vacuum
Extraction) and in the "hot-spots" of groundwater contamination.
Rezone the property. Deed restrictions on water wells and
monitor the plumes. Total FW cost for Alternative 5 is
$1,170,000.
Contingency Alternative (SC—5/****— 4)t Excavation and off-Site
disposal of soils. Extraction and treatment of groundwater to
the MCLs for chemicals of concern. Estimated PW is $3,768,500..
Alternative 6 (SC—4/MM—4); Excavation and treatment of
soils/sediments for VOCs and metals by enhanced volatilization
and stabilization/solidification. Extraction and treatment of
groundwater to the MCLs for chemicals of concern. Total present
worth cost of the Alternative 6*is $3,502,197.
Alternative 7 (SC-6/MM-41t Treatment of soils for VOCs by in
situ vacuum extraction (Dual Vacuum Extraction). Extraction and
treatment of groundwater to the MOLs for chemicals of concern.
Total present worth cost of Alternative 7 is $3,509,217.
The "O&M cost" included for each alternative refers to the costs
of operating and maintaining the. treatment described in the
alternative, for an assumed period of 30 years. All alternatives
include sampling to ensure that all contaminated groundwater at
concentrations exceeding the remediation goals will not migrate
beyond Site boundaries. Additionally, all alternatives include
necessary Five Year Reviews to be conducted during the respective
30-year O&M period. The costs, including professional reports
and supporting inspections, sampling, and analytical work are
contained in the Operation and Maintenance Cost's (O 6 M) of- each
Alternative and were calculated using the same five percent
discount factor as other O&M costs.
»
»
8.0 Snmnuurtr of Caatoaxative Analvsi.8 of. Alternatives
EPA uses the following evaluation criteria for Superfund Sites to
select preferred remedial alternatives. The first seven criteria
are used to evaluate all the alternatives, based on environmental
protection, cost, and engineering feasibility issues. Table
8-1 graphically depicts how well each combination of source and
groundwater controls meets the seven criteria. The preferred
alternative is further evaluated based on the final two criteria,
State and Community Acceptance.
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Record of Decision
Kalana NPL Site
Page 51
Table 8-1
SUMMAKT OF B»*»TTJ
junursxs or
BKHJIXXVl
SPECXAUXZ
Criteria
PROTECT I VENESS :
Human Health
Environment
ARARs:
Soil
Groundwater
S-T
EFFECTIVENESS t
Community
Workers
Tine (years)
L-T
EFFECTIVENESS :
Residuals Risk
Reliablity
REDUCTION IN:
Toxicity
Mobility
Volume
IMFLEMENTABILITY :
Constructability
Availability
Monitoring
COST (thousands)
ALTERNATIVE
1
XX
zzz
zz
1
zzz
zzz
zzz
$325
2
ZZ
z
z
zzz
z
1
z
z
zzz
zzz
zzz
$525
3
ZZ
ZZZ
»
zzz
'zz
z
1
i
.ZZ
ZZ
ZZ
ZZ
ZZ
zzz
zzz
zzz
$559
4
ZZZ
zzz
zzz
xx*
ZZ
" V
zzz
30
zzz
zzz
ft
zzz
zzz
zzz
zzz
zzz
zzz
$5,127
NUMBER
5
ZZ
ZZZ
.-
ZZ
z
z
ZZ
1
•
ZZ
zz.
ZZ
ZZ
zzz
ZZ
ZZ
$1,118
6
zzz
zzz
zzz
ZZ
ZZ
ZZ
30
zzz
zzz
zzz
zzz
ZZ
zzz
zzz
zzz
$3,502
7
ZZ
ZZ
ZZ
ZZ
ZZ
ZZ
30
22
ZZX
ZZZ
Z
ZZ
zzz
ZZ
ZZ
$3,509
Contigency
Alternative
ZZZ
ZZZ
ZZZ
ZZ
ZZ
ZZ
30
ZZZ
ZZ
ZZ
ZZ
ZZ
zzz
zzz
zzz
$3,768
ZZZ - Completely satisfies criterion
ZZ - Substantially satisfies criterion
Z - Partially satisfies criterion
- T>o«»s not sntipfv criterion
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Record of Decision
Kalama NFL Site
Page 52
8.2 Th'Teshold Criteria
The first two statutory requirements must be met by the
alternative:
1. Overall Protection of Human Health and the Environment
addresses the degree to which an alternative meets the
requirement that it be protective of human health and the
environment. This includes an assessment of how public health and
environmental risks are properly eliminated, reduced or
controlled through treatment, engineering controls, or controls
placed on the property to restrict access and (future)
development.
2. Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs) addresses whether or not an alternative
complies with all state and federal environmental and public
health laws and requirements that apply or are relevant and
appropriate to the conditions and cleanup options at a specific
Site. If an Applicable or Relevant and Appropriate Requirement
(ARAR) cannot be met, the analysis of the alternative must
provide the grounds for invoking & statutory waiver.
-In evaluating compliance with ARARs, contaminated soil will be
analyzed to determine if it will be categorized as a hazardous
waste as defined under RCRA and the. South Carolina Hazardous
Waste Management Regulations (SCHNMR, 61) . Should the
contaminated soil fail the Toxicity Characteristic Leaching
Procedure (TCLP), then 40 CFR Parts 261, 262, 263, and the
corresponding parts under the SCHNMR, will apply. Also, if the
contaminated soil fails TCLP and Extraction Procedure (EP)
toxicity limits, the land disposal restrictions in 40 CFR Part
268 and SCHNMR 61-79.268 will apply. However, if EP toxicity
tests are performed and the contaminated sludge "and soils do not
exceed EP toxicity limits, then the land disposal restrictions
cited above will not apply, even though the contaminated soils
fail TCLP.
B.3 Pri»'*"*T*v BalaneiTiq Criteria
These five considerations are used to develop the decision as to
which alternative should be selected.
3. Long- Term Effectiveness and Permanence refers to the ability
of an alternative to maintain reliable protection of human health
and the environment over time once the cleanup goals have been
met.
4. Reduction of Toxicity, Mobility t and Volume addresses the
statutory preference for selecting remedial actions that employ
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Record of Decision
Kalama NPL Site
Page 53
•treatment technologies that permanently and significantly reduce
toxicity, mobility, or volume of the hazardous substance as their
principal element.
5. Short-Term effectiveness addresses the impacts of the
alternative on human health and the environment during the
construction and implementation phase, until remedial action
objectives have been met.
6. Jmplementability refers to the technical and administrative
feasibility of implementing an alternative, including the
availability of various services and materials required for its
implementation.
7. Cost consists of the capital (up-front) costs of implementing
an alternative, plus the costs to operate and maintain the
alternative over the long term. Under this criterion, the cost-
effectiveness of the alternative can be evaluated.
i*-
8.4 Modifying Criteria
These two considerations indicate the acceptability of the
alternative to the public, or local or State officials.
8. state Acceptance addresses whether, based on its review of
the RI, FS, and Proposed Plan, the State concurs with, opposes,
or has no comments on the alternative once it is proposed by EPA
as the selected alternative (or "remedy"). The State of South
Carolina concurs with this remedy. South Carolina's letter of
concurrence is provided in Appendix A to this ROD.
9. Community Acceptance addresses whether the public agrees with
EPA's selection of the alternative. Community acceptance was
indicated by the verbal comments received at the Kalama Specialty
Chemical, Inc., Site Proposed Plan public meeting, held on-July
1, 1993. The public comment period opened on June 22, 1993, and
was set to close on July 22, 1993. A request for an extension to
the Public Comment Period was received and the comment period was
extended 30 days and concluded on August 23, 1993. Several
written comments were received concerning the Kalama Site. Those
comments and comments expressed at the public meeting are
addressed in the Responsiveness Summary attached as Appendix B to
this ROD.
8.5 P«nit*ined Alternatives Evaluation
The seven combined initial alternatives and the contingency
alternative were evaluated based upon the nine criteria set forth
in the HCP, 40 C.F.R. S 300.430(e) (9). In the attached
Table 8-2, brief summaries are presented of how the combined
alternatives were judged against these nine criteria.
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(D
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10
SUMMARY OF EVALUATION OF REMEDIAL ACTION ALTERNATIVES
KALAMA SPECIALTY CHEMICALS, INC STUDY AREA
CRITERIA
ALTERNATIVE 1
No-Actlon
ALTERNATIVE 2
RCRA Cap On Source Soils/Fill Ditch
ALTERNATIVE 3
Soil and Sediment Excavation/Enhanced
Volatilization and Solidification
1. OVERALL reOTOCTTVENESS OF HUMAN HEALTH AND THfiENVmONMENT:
Human Health
- Direct Contact Soil/
Sediment Ingestlon
- Leachate Production
- Groundwater
Ingestion/Future UMTS
Environmental Protection
*» "" *
Institutional controls reduce risk of
exposure*
No reduction.
Institutional controls reduce risk.
Allows continued contamination of* soli
and groundwater, continued groundwater
migration.
»•
V •
Cap reduces risk of exposure to soils; nil
reduces dermal contact risk from sediments.
Leachate from vertical Infiltration is removed,
however large natural water table fluctuations
will continue to mobilize contaminants in the
lower portion of the source volume.
Institutional controls reduce risk.
Cap reduces contact with soils.
Contaminated groundwater remains and
continues to migrate.
1 COMPL^^ **-„'. ' ' -
Chronical-Specific
Action-and-Location-Speciflc
Does not comply with ARARs. 30-year
groundwater monitoring is planned.
i
Not relevant. No ARARs for institutional
controls.
'No compliance with groundwater ARARs.
30-year groundwater monitoring is planned.
Capping in wetlands must comply with
wetland regulations.
Excavation and treatment of soil reduces risk
to within NCP guidelines.
Source of leachate Is eliminated or (teed.
Institutional controls reduce risk.
Soils are remediated. Contaminated
groundwater remains and continues to
migrate.
v> ,
Attains remediation goals for soil, but not
ARARs for groundwater.
Air quality ARARs will be met possibly
through treatment. Wetland regulations must
be complied with for soil excavation.
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00
10
SUMMARY OF EVALUATION OF REMEDIAL ACTION ALTERNATIVES
KALAMA SPECIALTY CHEMICALS, INC. STUDY AREA
CRITERIA
ALTERNATIVE 1
No-Action
ALTERNATIVE 2
RCRA Cap On Source Soils/Fill Ditch
ALTERNATIVES
Soil and Sediment Excavation/Enhanced
Volatilization and Solidification
3. SHORT-TCRM EFFECTIVENESS: •"....
Community Protection
Worker Protection
Environmental Impact!
Time to Completion
No impacts on community from remedial
action.
*»
Minor risk during maintenance of fence.
Health and safety plan required.
Minimal, limited to maintenance of fence.
Less than sh months.
No Impacts on community. Possible dust
during capping of soils. « <
V
%-.•- .. -+t
Minor risk during Installation of cap. Health
and safety protection likely required during
RCRA cap construction.
Minimal, construction In wetland will have
impact, but, small area (0.5 acres).
Less than six months.
4. LONG-TERM EFFECTiVENBSSj - s- 'V- ' -'** ;^
Magnitude of Residual Rilk
- Soils
- Groundwater
Adequacy and Reliability of
Controls ,
Risk from soils must be managed long-
term.
Risks from GW must be managed long
term. >
Reliability of deed restrictions and
rezoning depends on enforcement.
Dermal contact risk reduced significantly.
Cap must be maintained long term to control
risk from contact/ingestion.
Risks from GW must be managed long-term.
High water table may periodically flush
contaminants Into groundwater.
Reliability of cap depends on maintenance.
Reliability of deed restrictions depends on
enforcement*
Possible impact from VOC emissions and
dust during removal and treatment of soils.
VOC emission will be treated.
Moderate risk to workers from VOCs and
dust. Requires sophisticated site health and
safety plan.
Some Impacts, but limited to disturbances and
traffic during remedial action for soils.
From two to four months.
C ,. v\\ " * ' •
Risks from sofl are greatly reduced or
eliminated.
Risk from GW must be managed long-term,
but levels should decrease with lime.
Treatment is reliable for soil contaminants.
Reliability for GW depends on enforcement.
•8
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in
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ft H-
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f-
§
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SUMMARY OF EVALUATION OF REMEDIAL ACTION ALTERNATIVES
KALAMA SPECIALTY CHEMICALS, INC. STUDY AREA
oo
i
10
to
CRITERIA
ALTERNATIVE 1
No-Action
ALTERNATIVE 2
RCRA Cap On Source Soils/Fill Ditch
ALTERNATIVES
Soil and Sediment Excavation/Enhanced
Volatilization and Solidification
5. REDUCTION OF MOBILITY TOXIOTY OR VOLUMR ,
Soils
Groundwater
6. IMPLEMENTABILITY:
Availability of Technology
Reliability
Availability of Treatment,
Storage, or Disposal Services
Ability to Monitor Effectiveness
No treatment utilized
No treatment utilized
u;!'J *\^%J£#& >&< ^ '
Readily available for numerous sources.
Depends on enforcement of institutional
controls. *
None required.
Groundwater monitoring will track quality
and location of plume.
No treatment of soil. Mobility of chemicals
in soil greatly reduced by cap. No reduction
in volume, biodegradable waste will decrease
No treatment of GW. Cap will reduce but
not eliminate source of contamination.
;^U^;, "V^-, * ^
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I
ST
00
I
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SUMMARY OF EVALUATION OF REMEDIAL ACTION ALTERNATIVES
KAIAMA SPECIALTY CHEMICALS, INC STUDY AREA
CRITERIA
7. COST: .••'•..•/"' •: ;'v
Capital
Annual O&M
Present Worth
ALTERNATIVE 1
No-Action
• ..••!..••.?.".?•:.•.
SO
$325,124
$325,124
ALTBRNATIVB2 »;
RCRA Cap On Source Soils/Fill Ditch
V- • HK
.. •:'. : :• • -;. • - :•!;•-.•• -,••:,..-..• '.-. ..<•
$196,000
$329,000
$525,000
ALTERNATIVE 3
Soil and Sediment Excavation/Enhanced
Volatilization and Solidification
..:, ' •'..•>• ' • . . ...
$188,000
$371,000
$559,000
P» aw MT
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SUMMARY OF EVALUATION OF REMEDIAL ACTION ALTERNATIVES
KALAMA SPECIALTY CHEMICALS, INC STUDY AREA
s
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I
10
CRITERIA
ALTERNATIVE 4
SoO Excavation/Enhanced Volatilization
. and Solidification, Slurry Wall, Pump,
PTD to MCL
ALTERNATIVE S
Dual Vacuum Extraction of Contaminated
Soils with Short-Term PTD of Contaminated
Groundwater "Hot Spots"
ALTERNATIVE 6
SoO Extraction/Enhanced Volatilization and
Solidification; PTD of Groundwater to MCL
1. OVERALL PROTECITVENESS OP HUMAN HEALTH AND THE ENVIRONMENT
Human Health
- Direct Contact Sofl/
Sediment Ingestion
• Leachate Production
- Groundwater
Ingestion/Future U
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SUMMARY OF EVALUATION OF REMEDIAL ACTION ALTERNATIVES
KALAMA SPECIALTY CHEMICALS, INC STUDY AREA
&
oo
I
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er»
CRITERIA
ALTERNATIVE 4
SoU Exctvarion/Bnhinced Volatilization
and Solidification, Slurry Wall, Pump,
PTDtoMCL
3. SHORT-TERM EFFECTIVENESS: < ; .,: r'** '> */ "
Community Protection
Worker Protection
Environmental Impacts
Time to Completion
Possible impact from VOC emissions and
dust during removal and treatment of
soils. VOC emission may be treated.
Moderate risk to workers from VOCs and
dust Requires aophifiicated the health
and safety plan.
t
Some Impacts, but limited to disturbances
and tralTIc during remedial action for toll*.
Slurry wall will have a potentially major
Impact on wetlands during construction.
From six months to one year Tor soil,
groundwater remediation may take 30
years. '
ALTERNATIVE S
Dual Vacuum Extraction of Contaminated
Soils with Short-Term PTD of Contaminated
Groundwater "Hot Spots"
'»»
\«,. " Mk.* X . ' '• ".-.
VOC emission from vacuum extraction may
be treated. Dust from construction activities
will be minimal and short-term.
VOC emission from vacuum extraction may •
be treated. Emissions from air stripper may
require treatment. Health and safety plan
required for site work*
Minor, limited to excavation of sods
containing metals during vacuum system
Installation and well drilling.
Soil treatment by in situ DVB to last 6
months to one year with concurrent PTD of
GW to run during same period.
ALTERNATIVE 6
Soil Extraction/Enhanced Volatilization and
Solidification; PTD of Groundwater to MCL
>•• •/:• . . .
VOC emission from soil treatment and dust
from construction activities will be minimal
and short-term.
VOC emission from soil treatment and
emissions front air snipper may require
treatment. Health and safety plan required
for site work.
Minor, limited to excavation of soils and
sediments during construction and well
drilling.
Soil remediation expected to take sot months
to one year. PTD of GW will show
reductions in contaminants in the short term
but overall cleanup will take a much longer
lime frame.
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00
i
10
SUMMARY OF EVALUATION OF REMEDIAL ACTION ALTERNATIVES
KALAMA SPECIALTY CHEMICALS, INC STUDY AREA
CRITERIA
: . ' : . • •.".'••
4. LONO-TBRM BFFECTtV
Magnitude of Residual Risk
• Soils
- Groundwtler
Adequacy and Reliability of
Controls
5, RfeDOetiON OFMOBII
Soils
Groundwater
ALTERNATIVE 4
Soil Excavation/Enhanced Volatilization
and Solidification, Slurry Wall, Pump,
PTDtoMCL
ENBSS: *V^:V''?VV;.'Yf' . '.. \
.. .* t '
»» .
RJska from aod ire greatly reduced or
eliminated.
Groundwater remediation eliminates risk
for groundwater.
Treatment U reliable for aod contaminants.
Treated groundwater lo MCL would need
no controls for that medium. Monitoring
required to assets effectiveness. ;
jtVtoxicrrV bR VbLOMR
770 yd1 of soil treated by enhanced
volatilization and solidification of metals.
VOCs treated lo detection level
Oroundwater treatment would eliminate
(Destroy) the contaminants.
ALTERNATIVE 5
Dual Vacuum Extraction of Contaminated
Soils with Short-Term PTD of Contaminated
Groundwater "Hot Spots"
> , ^ < f : - " "' • ^:'^
% * . . .
t-
V
Risk* from'VOCs in lW sofl are eliminated.
Risk* from metal* in sofl remain.
Risk from GW reduced by remediation in hot
spots. Time frame for management of GW
risk reduced.
Controls are permanent. Source to GW Is
remediated so levels should begin to decline.
- -"- -, - % * "
483 yd1 of soils treated with in situ vacuum
extraction to remove VOCs lo detection
levels.
5 lo 10 million gallons of GW treated by air
stripping from area of VOC soil
contamination and from hot spots in OW
plume.
' ALTERNATIVE 6
Soil Extraction/Enhanced Volatilization and
Solidification; PTD of Groundwater to MCL
•> % '' * % * •.
Risk from soils and sediments is eliminated
for both VOC* and metals.
Risk from GW reduced to MCL. Long-term
risk management not required after
remediation.
Controls are permanent.
X • ,
770 yd1 of soil treated by enhanced
volatilization and solidification of metals.
VOCs treated to detection level.
Groundwater treatment would eliminate
(destroy) the contaminant*.
1
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i
ST
00
I
ro
SUMMARY OF EVALUATION OF REMEDIAL ACTION ALTERNATIVES
KALAMA SPECIALTY CHEMICALS, INC. STUDY AREA
CRITERIA
ALTERNATIVE 4
Soil Excavation/Enhanced Volatilization and
Solidification, Slurry Wall, Pump, PTD to
MCL
ALTERNATIVE 5
Dual Vacuum Extraction of Contaminated
Soils with Short-Term PTD of Contaminated
Oroundwiter "Hot Spot*"
6; IMPLEMBNTABlLrTY!; V,X ^ ' \% -*5*VCt& \?" L - - ^\ ^s; ^ "•* V V ; > ^ ! f : *" » K^fi\ *" "
Availability ot Technology
Reliability
Aviilibility of Treatment,
Storage, or Diipoul Service*
Ability to Monitor Effectiveness
"7. CdST!
Cipitil
Annutl OAM
Present Worth
Readily available and broad experience with
implementation.
Slurry walli are lomewhit questionable
when Installed to a depth of 80 feet.
Groundwater treatment highly reliable for
contaminant* of concern. Long-term
reliability of solidification not well
ettibllihed; OW require* long-term
treatment but technology ii effective.
Spent carbon wffl require treatment.
Sampling will verify attainment of
remediation goali for toib. OW will alto
be monitored for effectivenei*.
r-
All component* are readily available from
numerous iqurces. w
Groundwater treatment i* highly reliable for
contaminants of concern. Dual vacuum
extraction technology readily available.,
Spent carbon will require treatment.
Degree of toil cleanup lomewhat difficult to
determine with In situ treatment proceti. GW
can be readily monitored for cleanup levels.
;*S.VV;IT*U^ ',, , — "• " , ^ -:% ~-,^:,^
\ v , * ,>' ^\K^,^ - !-. % 1 >% ••
$3,230,640
$1,696,527
$5,127,167
$683,000
$435,000
$1,118,000
ALTERNATIVE 6
Soil Extraction/Enhanced Volatilization and
Solidification; PTD of Groundwater to MCL
•. .. •• •.;• * * ~- $•• ••*•••.•••. '•**••
\ ^ ^ •• ^ ..^ •- \ -.* V ^ S ^ ^ s"1 s --V ^ ••
,\ -\ - -\,-* ^\vi-^--\s\i- v-Vi\- , ^ - \
All components are readUy available from
numerous sources.
Highly reliable for contaminant! of concern.
Long-term reliability of solidification not well
established.
Spent carbon will require treatment.
Soil cleanup can be assessed with confirmation
sampling. GW remediation can be assessed by
monitoring network already installed.
,' •••• < '•i'-. /'1-V^f*'< •> ,' %x \ , '
^^-A^ >r- :«„„", ^,
$1,605.640
$1.896.527
$3,502,167
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-------
CRITERIA
Human Health
- Direct Contact Soil/
Sediment Digestion
- Leachate Production
- Groundwater
Ingestion/Puture Uien
SUMMARY OF EVALUATION OF REMEDIAL ACTION ALTERNATIVES
KALAMA SPECIALTY CHEMICALS, INC. STUDY AREA
ALTERNATIVE 7
Dual Vacuum Extraction of Contaminated
Soib with PTD of Contaminated OW to
MCL
Environmental Protection
Treatment of toils reduces risk by VOCs to
MCL guidelines^ metals are not affected.
Source of VOC leachale is eliminated.
Elimination of risk via groundwater.
Soil. VOC contamination eliminated.
Restoration of OW quality to MCL will
eliminate migration potential. Some minor
air emissions.
*
Chemical-Specific
Actkm-and-Location-Specific
Attains remediation goals for VOCs and for
groundwater, but not ARARs for OW.
Discharge from vacuum extraction and air
stripper will meet air standards. Discharge
from OW treatment unit will meet MCLs or
WQS.
Contingency Alternative
Off-Site Disposal of Contaminated Soils
PTD of Contaminated OW to MCLs
Excavation and removal of soils reduces
Site risk tg NCP guidelines.
Source of VOC leachate is eliminated.
Elimination of risk via groundwaler.
Soil VOC contamination eliminated on-
Site. Restoration of OW quality to MCL
will eliminate migration potential. Some
minor air emissions possible.
Attains remediation goals for VOCs and
metals on-Site. attains OW ARARs.
Soil removal off-Site provides ARAR
compliance on-Site.
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I
SUMMARY OF EVALUATION OF REMEDIAL ACTION ALTERNATIVES
KALAMA SPECIALTY CHEMICALS, INC STUDY AREA
CRITERIA
S W$$i §^vfe|^Ws*f A^ *\ ' ' IP* W
i^^^j^^^"?^sl>';^y!i?*lly^
Community Protection
• *
Worker Protection
Environment*] Impacts
Time to Completion
ALTERNATIVE 7
Dual Vacuum Extraction of Contaminated
Soils with PTD of Contaminated OW to
MCL
VOC emission from vacuum extraction may
be treated. Dust from construction activities
will be minimal and short-term.
*• • -Hi
VOC emission from vacuum extraction will
be treated. Emissions from air stripper may
require treatment Health and safety plan
required for site work.
Minor, limited to excavation of wits
containing metals during vacuum system
installation and well drilling.
Soil remediation expected to take six
months to one year. PTD of OW to last
approximately 30 yean.
Contingency Alternative
Off-Site Disposal of Contaminated Soils
PTD of Contaminated OW to MCLs
Dust & traffic increases possible during
soil removal. Dust will be minimized in
short-term with proper construction
practices.
Minor risk to workers from VOC emissions
and dust during soil removal. Emissions
from air stripper may require treatment.
Health and Safety Plan required for Site
work. '
Some impacts, but limited to minor
disturbances and traffic increases during
remedial action for soils.
Soil removal expected to lake less than two
months. PTD of OW to last approximately
30 yean.
•o
•
M
O
-------
SUMMARY OF EVALUATION OF REMEDIAL ACTION ALTERNATIVES
KALAMA SPECIALTY CHEMICALS, INC. STUDY AREA
*
H»
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M
CRITERIA
ALTERNATIVE 7
Dual Vacuum Extraction of Contaminated
Soils with PTD of Contaminated OW to
MCL
Magnitude of Retidud Risk
. Soib
- Groundwater
Adequacy and Reliability of
Controls
Risks from VOCs in the soil are eliminated.
Risk from metals in soil remain untreated.
Risks from OW eliminated. -Long term
management not required after remediation.
Controls are permanent Source to OW is
removed. OW cleaned to MCL.
Soils
Oroundwater
483 yd1 of soils treated with in situ vacuum
extraction to remove VOCs to cleanup
level..
Treatment will eliminate mobility, toxicity
and volume to acceptable standards
(ARARs).
Contingency Alternative
Off-Site Disposal of Contaminated Soils
PTD of Contaminated OW to MCLs
Risks ftpm soil eliminated totally on-Site.
Risks from OW eliminated. Long term
management not required after remediation.
Controls are permanent Source to GW is
removed. OW cleaned to MCLs.
No treatment of soib. No reduction in
volume of contmainants, although soil is
moved off-Site. Removal of soil from Site
eliminates contaminant mobility to GW.
Treatment will eliminate mobility, toxicity
and volume to acceptable standards
(ARARs).
m
to
H-o
ft •*
9 n
-------
CRITERIA
Availability of Technology
Reliability
Ability to Permit
Availability of Treatment,
Storage, or Disposal Services
SUMMARY OF EVALUATION OF REMEDIAL ACTION ALTERNATIVES
KALAMA SPECIALTY CHEMICALS, INC. STUDY AREA
Ability to Monitor Effectiveness
ALTERNATIVE 7
Duil Vacuum Extraction of Contaminated
Soils with PTD of Contaminated OW to
MCL
All components are readily available from
numeroui sources.
Oroundwater treatment it highly reliable for
contAminanti of iconcem. Dual vacuum
extraction technology readily available.
Wetland permit may be required Tor
excavation of soils containing metals.
Vacuum unit and air stripper emissions may
require treatment to permit
Spent carbon will require treatment
Degree pf soil cleanup somewhat difficult to
determine with in situ treatment process.
OW can be readily monitored for cleanup
levels.
Capital
Annual OAM
Present Worth
$1,606,000
$1.902.528
$3,509.217
Contingency Alternative
Off-Site Disposal of Contaminated Soils
PTD of Contaminated GW to MCLs
All components are readily available from
numerous sources.
Oroundwater treatment is highly reliable
for contaminants of concern. Equipment
for soil removal readily available.
Wetland permits may be required for soil
excavation. Air strippers emissions may
require that substantive requirements of
permit to .be met
Landfills available for soil disposal. Spent
carbon, if utilized, will require treatment.
Degree of soil cleanup easily determined
by confirmatory sampling. OW can be
readily monitored for cleanup levels.
$1,860.283
$1,907,528
$3,768,500
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Record of Decision
Kalama NPL Site
Page 66
9-0 THE SELECTED REMEDY
EPA has selected the Remedial Action Alternative 6 as the
preferred combination of controls for use at the Kalama Site.
Remedial Action Alternative 6 incorporates the components SC-4
and MM-4 to treat soils by excavating, enhanced volatilization
and solidification in the source area (or the SC-5 Contingency of
of f -Site disposal of excavated soil ) , and to pump and treat
groundwater to the MCLs. Alternative 6 requires implementation
of the following:
* Treatment of soils and sediments (both on the
surface and in the ditch) contaminated with VOCs
and metals by excavation, with either 1)
volatilization, solidification, and replacement of
soils into the excavation OR as a contingency, 2)
removal of the excavated 'soils to a RCRA landfill
if soil characteristics and cost effectiveness
deem of f -Site disposal more feasible;
* Extraction and treatment of groundwater to the
MCLs for contaminants of concern; and
* Additional monitoring with new deep wells in the
limestone aquifer*
Table 9-1 provides details of a Reasonable Cost Estimate of the
Capital and Associated Costs of Alternative 6, assuming on-Site
treatment and disposal. The cost for the preferred alternative
is $3,502,197. If off-Site disposal of the soils is implemented,
the estimated cost of the contingency alternative will be
$3,768,500. /
9.2
This remedy component consists of. excavation of contaminated
soil, verification sampling, and either on-Site volatization,
solidification, and replacement into the excavations, or
transport of the soil off-Site to a permitted RCRA hazardous
waste landfill. The following subsections describe this remedy
component in detail, provide the criteria (ARARs and TBC
material) which shall apply, and establish the performance
standards for implementation.
For purposes of describing this portion of the remedy and
specifying the requirements which shall apply to it, it is
assumed that some or all of the contaminated soils to be
addressed will be shown by laboratory analysis to be RCRA
hazardous wastes. With that assumption, the majority of ARARs
apply. It should be noted that to date tests of cuttings have
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Record of Decision
Kalama NPL Site
Page 67
Table 9-1, p.l
REASONABLE ESTIMATE OF CAPITAL AND ASSOCIATED COSTS
KALAMA SPECIALTY CHEMICALS. INC. - ALTERNATIVE NO. 6
Cost Element
Extraction Wells (1-10)
Storage Tank (25,000 gal)
Small Tank (3000 gal)
Large tank mixer
Small tank mixer
Metals Complexing Reagent Syste
Submersible and Feed Pumps
Air Strippers with Blowers
Variable Speed Drives
Adsorber Pumps
In-line Filters
GAC Adsorption Units (10,000 f)
Process and Well Piping
Subtotal: Equipment (EC)
Labor (50% x EC)
Electrical and Instros. (20% x EC)
Site Work (5% x EC)
Mobilization\Demobilization (10%
Quantity Unit Cost
10
1
1
1
1
1
13
2 *'
5 -
4
2
2
•11
>
xEC) <
$8,900
26,100
6,500
8,900
6,600
5,500
1.250
50,000
1,800
1.250
1.100
55,000
96,000
Remove and Treat Soils & Sediments (Alt 3)
Subtotal/Total
Contingency (15%)
Total Construction Costs (CoC)
Design Services (15% x CoC)
Construction and Start-up Services
' •
.
9
t
(10% x CoC)
Hydrogeologk and Geotech Services
Health and Safety Plan
Deed Restriction and Rtroning
Permitting
Subtotal: Associated Project Costs
Total Capital Costs
Total Present Value of Opn & Mm
Total Present Value of Alternative
(Table 4 - 8B)
Total
Per Element
$89.000
26,100
6,500
8,900
6.600
5,500'
16.250
100,000
9,000
5.000
2,200
110,000
96.000
$481.050
240,525
96.210
24.053
48.105
67.720
$476.6'f3
165.197
110.131
165.000
39,000
15,000
10.000
$504,328
Totals
$957,66?
143,649
$1.101,312
$504.328
$1,605.640
$1.896,527
$3,502,167
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Record of Decision
Kalama NFL Site
Page 68
Table 9-1, p.2
REASONABLE ESTIMATE OF OPERATING AND MAINTENANCE COSTS
KALAMA SPECIALTY CHEMICALS. INC. - ALTERNATIVE NO. 6
Cost Element
Maintenance
Equipment
Site
Operation
Labor
Utilities k >
Analytical
Professional Envr. Report
Miscellaneous - chemicals, etc.
Carbon Replacement y
Total 1st Year
Total Present Value of Future O & M •
Total Present Value
Estimated
1st Year
Amount
$22.900
6.000
62.800
10.000
29.700
22,000
10.000
20.000
$183,400
$1,713.127
$1.896.527
Estimated
Later Year
.Basis
$22,900
6,000
26,800
10,000
13,200
•
10.000
20,000
$108.900
Note:
• Environmental Report is included every five yean.
Year Amount Present $
Year Amount Present $
2
3
4
5
6
7
8
9y
10 '
11
12
13
14
15
108,900
108.900
108,900
130.900
108.900
108,900
108,900
108,900
130.900
108.900
108,900
108,900
108.900
130,900
103,714
98,776
94,072
107,692
85.326
81,263
77,393
73,708
84.379
66.855
63,672
60,640
57,752
66.113
Subtotals
Discount Rate of
$1,121,354
5 percent.
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
108,900
108,900
108.900
108.900
130,900
108,900
108,900
108,900
108,900
130,900
108,900
108,900
108,900
108,900
130.900
52383
49,888
47,513
45,250
51,802
41,043
39.089
37,227
35.455
40,588
32,158
30.627
29,169
27,780
31.802
$591,773
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Record of Decision
Kalama NPL Site
Page 69
not indicated that hazardous wastes, as defined under RCRA, are
present.
9.2.1 Description
On-Site work shall be performed in accordance with the OSHA
health and safety standards applicable to remedial activities.
Proper materials handling procedures shall be used during the
excavation and handling of soil. Such measures may include the
use of water to minimize dust emissions during soil excavation,
transport, and handling, and the use of tarps or plastic sheeting
placed over temporary soil stockpiles to minimize dust emissions
and runoff.
Soil in the area of soil contamination shall be excavated until
the remaining soil achieves the concentrations established as
performance standards as described in Section 9.2.3 of this ROD
or the water table is encountered.
i»
Prior to excavation, soil sampling sufficient to confirm the
areal extent of soil which exceeds these criteria, shall be
conducted at all four compass boundaries of the area shown in
Figure 1-2 of this ROD. Verification sampling shall be employed
to ensure that all soils contaminated at levels exceeding the
•performance standards are removed.
s,
After excavation, measurement of. ^he volume of contaminated soils
will be made and the characteristics of the soil shall be
determined to determine if it is more cost effective to
volatilize and solidify the soil on-Site, or remove it to a
permitted RCRA landfill. Assuming it is deemed more cost
effective to dispose of the soil off-Site, the excavated soil, if
necessary, shall be treated, then transported to a permitted RCRA
hazardous waste (RCRA Subtitle C) landfill facility for disposal.
A RCRA Subtitle C facility is deemed appropriate because of- the
health risks posed by direct contact with the soils.
Transport shall be accomplished ,"in compliance with DOT
regulations governing transportation of hazardous materials.
Excavation work shall be staged and coordinated with
backfill/grading/seeding activities to minimize dust production
and surface water runoff. The on-Site excavation shall be
backfilled with clean soil, properly recompacted, and the land
surface regraded to the preexisting natural slope. A vegetative
cover will be established to minimize undue surface water runoff
and minimize erosion.
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Record of Decision
Kalama NFL Site
Page 70
ARARs originate from applicable requirements, intended to
definitely and specifically apply to a remedial action; or
relevant and appropriate requirements, which, while not intended
to apply to the specific situation in question, EPA judges to be
applicable to a remedial action. In addition, when establishing
criteria for ensuring the proper implementation of a remedial
action, EPA may develop requirements from other guidance
documents and criteria, sources often referred to as "To Be
Considered* material (TBC).
9.2.2.1 Applicable Reou*Tr«=m*ents
Soil remediation shall comply with all applicable portions of the
following Federal and State of South Carolina regulations:
**•
49 CFR Parts 107, 171-179, promulgated under the authority of the
Hazardous Materials Transportation Act. Regulates the labelling,
packaging, placarding, and transport of hazardous materials off-
Site. 3
-40 CFR Parts 261, 262 (Subparts A-D), 263, and 268, promulgated
under the authority of the Resource Conservation and Recovery
Act. These regulations govern the identification,
transportation, manifestation, and land disposal restriction
requirements of hazardous wastes. If the contaminated soils fail
TCLP, most likely, the land disposal restrictions in 40 CFR Part
268 will apply. However, if EP toxicity tests are performed and
the contaminated soils do not .exceed EP • toxicity limits, then the
land disposal restrictions in 40 CFR Part 268 will not apply,
even though the contaminated soils fail TCLP. In the event that
the Site soils requiring remediation do not test hazardous 4i.e.,
do not fail TCLP), the regulations listed-here will be considered
relevant and appropriate rather .than applicable.
SCHWMR 61-79.124, 79.261, 79.262, 79.263 and 79.268, South
Carolina Hazardous Waste Management Regulations, promulgated
pursuant to the Hazardous Waste Management Act, SC Code of Laws,
1976, as amended, establishes criteria for identifying and
handling hazardous wastes, as well as land disposal restrictions.
These regulations also will become relevant and appropriate in
the event that the soils requiring remediation do not prove to be
hazardous, as described in the above paragraph.
9.2.2.2 Relevant and Appropriate Reonijreinents
The following regulations are "relevant and appropriate" to
source control actions (soil remediation) at the Site.
Applicability of these air quality control regulations is due to
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Record of Decision
Kalama KPL Site
Page 71
the potential for release of harmful participates (metals) or
VOCs daring soil.excavation and handling activities.
40 CFR Parts 60 and 61, 42 U.S.C. S 7401 et. seg. promulgated
under the authority of the Clean Air Act. Included are the
National Emissions Standards for Hazardous Air Pollutants
(NESHAPs). Ambient air quality standards and standards for
emissions to the atmosphere fall under these regulations.
SC Reg. 61-62, South Carolina Air Pollution Control Regulations
and Standards, promulgated pursuant to the S.C. Pollution Control
Act, SC Code of Laws/ 1976, as amended. Establishes limits for
emissions of hazardous air pollutants and particulate matter, and
establishes acceptable ambient air quality standards within South
Carolina.
9.2.2.3 "To Be Considered* <**»d Other Guidance
Revised Procedures for Planning" and Implementing Off-Site
Response Actions, OSWER Directive 9834.11, November 1987. This
directive, often referred to as "the off-Site policy," requires
EPA personnel to take certain measures before CERCLA wastes are
sent to any facility for treatment, storage, or disposal. EPA
personnel must verify that the facility to be used is operating
-in compliance with Sections 3004 and 3005 of RCRA, 42 U.S.C.
SS 6924 and 6925, as well as all other federal and state
regulations and requirements. Also, the permit under which the
facility operates must be checked to ensure that it authorizes
(1) the acceptance of the type of wastes to be sent, and (2) the
type of treatment to be performed on 'the wastes.
40 CFR Part 50, promulgated under the authority of the Clean Air
Act. This regulation includes the National Ambient Air Quality
Standards (NAAQS), and establishes a national baseline of ambient
air quality levels. The state regulation which* implements -this
regulation, South Carolina Reg. 62-61, is applicable to the
source control portion of the remedy.
9
t
Various TBC materials were utilized in the Baseline Risk
Assessment and in the Feasibility Study. Because cleanup
standards were established based on these documents, they are
considered TBC.
In the Baseline Risk Assessment, TBC material included
information concerning toxicity of, and exposure to. Site
contaminants. TBC material included the Integrated Risk
Information System (IRIS), Health Effects Assessment Summary
Tables (HEAST), and other EPA guidance as specified in the
Baseline Risk Assessment.
In the FS, soil concentrations protective of human health and the
environment were calculated based on the Site-specific risk
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Record of Decision
Kalama NFL Site
Page 72
calculations from the Baseline Risk Assessment, using TBC
information as described above. These levels are established as
performance standards in Section 9.2.3. There are no established
federal or state standards for acceptable levels of Kalama Site
contaminants in surface or subsurface soils or sediments.
For soils/sediments, the leachate-based and health-based models
were both considered. In order to be most protective, the lower
of the two was targeted. The chemical-specific goals produced
through the leachate-based model were found to be lower, except
for vinyl chloride. Due to the conservative nature of the
health-based and the leachate models, certain chemical-specific
cleanup goals were calculated below respective method detection
limits and MCL values. This is the case with methylene chloride,
benzene, vinyl chloride, and 1,2-DCA. None of these compounds
were detected in background samples during the RI. Therefore,
the remedial goal for these chemicals is a non-detectable result
obtained from analyses using validated CLP protocol.
»* •
9.2.2.4 Other Requirements
Remedial design often includes the discovery and use of
unforeseeable but necessary requirements which result from the
planning and investigation inherent in the design process itself.
"Therefore, during design of the source control component of the
selected remedy, EPA may, through v a formal ROD modification
process such as an Explanation of 'Significant Differences or a
ROD Amendment, elect to designate further ARARs which apply, or
are relevant and appropriate, to this portion of the remedy.
» 2 « 3 Perf OT*ntJ*
The standards outlined in this section comprise the performance
standards defining successful implementation of this portion of
the remedy. '
Excavation. The soil remediation goals (Table 7-2) are
established as performance standards. The performance standards
shall control the excavation procedure described above.
Additionally, all on-Site excavation work shall comply with
29 CFR S 1910.120, the OSHA health and safety requirements
applicable to remedial activities.
Transport of contaminated soil. Transportation shall be
accomplished in compliance with the Hazardous Materials
Transportation Act (49 CFR SS 107, 171-179).
Disposal of contaminated soil. Disposal of contaminated Site
soil shall comply with the applicable, or relevant and
appropriate, RCRA regulations (40 CFR Parts 261, 262 (Subparts A
D), 263, and 268). The determination of applicability, versus
relevant and appropriate, is described in Section 9.1.2, under
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Record of Decision
Kalama NFL Site
Page 73
"applicable requirements , * where the above regulations are cited.
In any circumstance, the disposal of contaminated soils shall be
done at a RCRA Subtitle C treatment, storage, and disposal
facility.
Whether the Selected or the Contingency Alternative is
implemented, confirmation soil sampling will be conducted to
insure that all contaminated soil has been excavated.
9.3 Gror>'ndwater
9.3.1 Description
The groundwater component of the remedy includes extraction of
contaminated groundwater from the sand aquifer, removal of metals
by precipitation and filtration, adsorption with granular
activated carbon (GAC) for organic compounds, air stripping to
remove organic contaminants, and discharge of the treated water
to either an on-Site infiltration gallery or sprayfield, or
surface water discharge.
This remedy component consists of the design, construction and
operation of a groundwater extraction and treatment system, and
development and implementation of a Site monitoring plan to
'monitor the system's performance. The groundwater treatment
specified below shall be continued until the performance
standards listed in Section 9. 3. Tare achieved at all of the
extraction and monitoring wells on or associated with the Site.
The point of compliance for this action shall be the entire Site.
Extraction wells shall be used for hydraulic capture of
contaminated groundwater from -the surface aquifer, following
confirmation of the extent of contamination (Section 9.4 below).
Preliminary modeling in the FS analyzed scenarios of a single
well or three extraction wells.' Actual numbers* and placement of
extraction wells will be determined during the remedial design.
Metal removal then is completed 'us ing precipitation and
filtration. Phase separation processes typically add polymers to
the water to force metal precipitates to clump together to form a
floe. Then, a sedimentation process is used to settle out the
large floe particles. Finally, the supernatant is filtered to
remove any other suspended particles not removed by the
sedimentation process. The settled floe particles and the
particles removed by the filter are typically transferred to a
solids holding tank. Solids from the holding tank are then
dewatered via filter press with the liquids usually pumped back
to the head of the treatment system. Dewatered solids will be
collected and stored on-Site until disposal. These solids may
require management as a hazardous waste with disposal in a RCRA-
regulated landfill. These actions shall comply with the ARARs
described in the following section (Section 9.3.2).
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Record of Decision
Kalama NPL Site
Page 74
After metals removal, the groundwater will be passed through two
air stripping units to remove or reduce the concentrations of
VOCs. The final treatment step shall route the water through an
activated carbon "polishing" unit to remove any VOCs not stripped
out and to provide secondary, back-up capability to the stripping
unit. Operation of the stripping unit shall comply with the
ARARs described in Section 9.3.2.
Following treatment, the groundwater shall be discharged to
either an on-Site infiltration gallery or spray field, or
discharged to the "L-shaped" ditch downstream of station SW-5.
Discharge of the treated groundwater shall comply with any
effluent limits established by EPA or SCDHEC.
Remedial design shall include the design of the treatment system
described above, as well as the necessary pipelines, electrical
lines, pump systems, treatment equipment, treatment facility, and
other appurtenances as required; Additional monitoring wells at
varying depths northwest of the'MW-46 well cluster and several
deep monitoring wells into the limestone aquifer will be
installed at locations both on-Site and off-Site.
The goal of this remedial action is to restore the groundwater to
its beneficial use as a drinking water source. Based on the
-information collected during the RI and on a careful analysis of
all remedial alternatives, EPA and the State of South Carolina
believe that the selected groundwater remedy will achieve this
goal. However, the remedy's ability to achieve the remediation
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.
i
The selected remedy will include groundwater extraction for an
estimated period, during which the system's performance will be
carefully monitored on a regular basis and adjusted as warranted
by the performance data collected during -operation. Modification
may include any or all of the following:
9
* Pumping may be discontinued at individual wells where
cleanup goals. have been attained;
* Alternating pumping at wells to eliminate stagnation
points;
* Pulse pumping to allow aquifer equilibration and
encourage adsorbed contaminants to partition into
groundwater; and
* Installation of additional extraction wells to facilitate
or accelerate cleanup of the contaminant plume.
To ensure that cleanup goals continue to be maintained, the
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aquifer will be monitored at those wells where pumping has ceased
on a regular periodic basis, following discontinuation of
groundwater extraction. The intervals between groundwater
sampling/analysis events will be established in the Remedial
Action Work Plan.
A periodic review of the remedial action (Five Year Review) will
occur at five year intervals in accordance with Section 121 (c) of
CERCLA, 42 U.S.C. S 9621(c).
9.3.2 Applic***>le or Relevant and Appropriate Requirements
(ARARs)
9.3.2.1 Applic^fole Reon* T**aitnents
Groundwater remediation shall comply with all applicable portions
of the following Federal and State of South Carolina regulations:
«* * •
40 CFR Parts 261, 262 (Subparts A-D), 263, and 268, promulgated
under the authority of the Resource Conservation and Recovery
Act. These regulations govern the identification,
transportation, manifestation, and land disposal restriction
requirements of hazardous wastes, and will be applicable to any
sludges which may be produced as a result of chemical treatment
of groundwater, and to spent carbon generated by the carbon
polishing unit. For either of these materials, if the material
fails TCLP, most likely, the land disposal restrictions in 40 CFR
Part 268 will apply. However, if EP toxicity tests are performed
and the material does not exceed EP toxicity limits, then the
land disposal restrictions in 40 CFR Part 268 will not apply,
even though the material fails TCLP. In the event that either
material does not test hazardous (i.e., does not fail TCLP), the
regulations listed here will be-considered relevant and
appropriate rather than applicable, for that material.
SC Reg. 61-79.124, 79.261, 79.262, 79.263 and 79.268, South
Carolina Hazardous Waste Management Regulations, promulgated
pursuant to the Hazardous Waste 'Management Act, SC Code of Laws,
1976, as amended, establishes criteria for identifying and
handling hazardous wastes, as well as land disposal restrictions.
These regulations apply as described above.
49 CFR Part 107, 171-179, promulgated under the authority of the
Hazardous Materials Transportation Act, regulates the labelling,
packaging, placarding, and transport of hazardous materials off-
Site.
40 CFR Parts 60 and 61, promulgated under the authority of the
Clean Air Act, includes the National Emissions Standards for
Hazardous Air Pollutants (NESHAPs). Standards for emissions to
the atmosphere fall under these regulations. Applicable to the
air stripping unit to be used for groundwater treatment.
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SC Reg. 61-62, South Carolina Air Pollution Control Regulations
and Standards, promulgated pursuant to the Pollution Control Act,
SC Code of Laws', 1976, as amended, establishes limits for
emissions of hazardous air pollutants and particulate matter, and
establishes acceptable ambient air quality standards within South
Carolina. This regulation is applicable in the same manner as
the federal regulation cited above.
40 CFR Parts 122, 125, 129, 133 and 136, Clean Water Act
Discharge Limitations (CWA S 301), promulgated under the
authority of the Clean Water Act, applicable to any point
discharges of wastewaters to waters of the United States. These
regulations apply to discharge of treated waters. The discharge
of the treated groundwater on the Site must substantially comply
with the KPDES discharge requirements of these regulations.
40 CFR S 403.5, CWA Pretreatment Standards (CWA S 307),
promulgated under the authority of the Clean Water Act.
Regulates discharges of water tb Publically Operated Treatment
Works (POTWs).
SC Reg. 61-68, South Carolina Water Classifications and
Standards, promulgated pursuant tp the Pollution Control Act, SC
Code of Laws, 1976, as amended, establishes classifications for
-•water use and sets numerical standards for protecting state
waters. ••
#'
SC Reg. 61-71, South Carolina Well Standards and Regulations,
promulgated under the Safe Drinking Water Act, SC Code of Laws,
1976, as amended, establishes standards for well construction,
location and abandonment for remedial work at environmental or
hazardous waste Sites. > "
9.3.2.2 Relev»'"t J»*»d Appropriate
< •••
The following regulations are relevant to- the groundwater
remediation at the Kalama Specialty Chemical, Inc., Site.
»
40 CFR Part 131, Ambient Water Quality Criteria (CWA S 304),
promulgated under the authority of the Clean Water Act, sets
numerical criteria for ambient water quality based on toxicity to
aquatic organisms and human health.
40 CFR Parts 141-143, National Primary and Secondary Drinking
Water Standards, promulgated under the authority of the Safe
Drinking Water Act establishes acceptable maximum levels of
numerous substances in public drinking water supplies, whether
publicly owned or from other sources such as groundwater.
May Timiin Contaminant Levels (MCLs) and Maytnnmn Contaminant Level
Goals (MCLGs) are specifically identified in the NCP as remedial
action objectives for groundwaters that are current or potential
sources of drinking water supplies
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(NCP, 40 CFR S 300.430(a)(l)(iii)(F)). Therefore, MCLs and MCLGs
are relevant and,appropriate as criteria for groundwater
remediation at £his Site.
SC Reg. 61-58, South Carolina Primary Drinking Water Regulations,
promulgated pursuant to the Safe Drinking Hater Act, SC Code of
Laws, 1976, as amended, is similar to the federal regulations
described above, and is relevant and appropriate as remediation
criteria for the same reasons set forth above.
As noted above, TBC criteria were utilized and/or established in
the Baseline Risk Assessment and in the Feasibility Study.
Groundwater cleanup standards were established based on these
documents and both are thus considered TBC.
In the Baseline Risk Assessment, TBC material used included
information concerning toxicity'of, and-exposure to, Site
contaminants. Sources of such data included the Integrated Risk
Information System (IRIS), Health Effects Assessment Summary
Tables (HEAST), and EPA guidance as specified in the Risk
Assessment. *
-In the FS, the remedial goals for the KSCI study area are the
reduction of on-Site contaminants, to MCLs and a chronic hazard
index (HI) of less than one. In Conjunction with this chemical-
specific goal, there is the goal of preventing any exposure which
may present an unacceptable risk. The groundwater remediation
goals are established as performance standards in Section 9.2.3.
Other TBC material includes the following:
Guidelines for Ground Water Use.and Classification, EPA Ground
Water Protection Strategy, U.S.-.EPA, 1986. This document .
outlines EPA's policy of considering a Site's groundwater
classification in evaluating possible remedial response actions.
The groundwater at the Site is classified by EPA as Class II-B
and by South Carolina as Class GB groundwater, indicating its
potential as a source of drinking water.
National Oceanic and Atmospheric Administration (NOAA) ER-L/ER-M
Values. These guidelines were developed as screening criteria
for sediment contamination in surface water bodies and are based
on toxicity to aquatic life.
40 CFR Part 50, National Ambient Air Quality Standards (NAAQS),
promulgated under the authority of the Clean Air Act. This
regulation includes the National Ambient Air Quality Standards
(NAAQS) and establishes a national baseline of ambient air
quality levels. The state regulation which implements this
regulation, South Carolina Reg. 62-61, is applicable to the
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groundwater portion of the remedy.
Sections 501 and 502 of the Clean Air Act, 1990 CAA Amendments,
42 D.S.C. SS 7661 and 7661a. These amendments require that all
•major sources* and certain other sources regulated under the CAA
obtain operating permits. Although Section 121 (e) of CERCIA
exempts this remedy from requiring such a permit because all
activity is to be done on-Site, air stripping at this Site may
have to comply with any substantive standards associated with
such permits. Regulations have been proposed, but not
promulgated, for the operating permit program.
9 » 3 » 2 « 4 Other reoui
As described above in Section 9.2.2.4, remedial design often
includes the discovery and use of unforeseeable but necessary
requirements. Therefore, during design of the groundwater
component of the selected remedy, EPA may, through a formal ROD
modification process such as ah 'Explanation of Significant
Differences or a ROD Amendment, elect to designate further ARARs
which apply, or are relevant and appropriate, to groundwater
remediation at this Site.
a
9.3.3 Perf Q
The standards outlined in this section comprise the performance
standards defining successful implementation of this portion of
the remedy.
Groundwater treatment. The groundwater remediation goals in
Table 7-2 shall be the performance standards for groundwater
treatment .
9.4 ConfiT> Extent of Growidwater Con'*'-*11'"*"*'*^*™
Upon initiation of the remedial design, sufficient additional
groundwater and surface water data shall be collected to achieve
the following objectives: 7
A. Verify the presence or absence of Site contaminants to the
lower limestone aquifer, both on-Site and off -Site. A
minimum of four new monitoring wells will be installed.
B. Confirm the areal extent of groundwater contamination in the
surface aquifer, and the areal (horizontal) and the vertical
extent of contamination in the limestone aquifer off -Site.
Attainment of these objectives must be accomplished during the
first portion of remedial design so that design of the extraction
and treatment system has, as its basis, an accurate conceptual
model of Site conditions. Confirmation of the extent of
contamination also will require collection of further information
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and data for characterizing the specific hydrogeology of the
Site, and will include aquifer testing and modeling as
appropriate. Confirmation sampling for the soil also will be
conducted ( Section 9.2.3).
9.5 Monitor Site ^"oundwater and Surface Water
Beginning with initiation of the remedial design, groundwater and
surface water samples shall be collected and analyzed on a
regular quarterly schedule. Analytical parameters for
groundwater and surface water samples will include all the known
Kalama Specialty Chemical, Inc., Site contaminants of concern.
The specific wells to be sampled and methodology for off-Site
sample collection will be determined during design. Surface
water samples will be collected, as a minimum, from the "L-shaped
ditch" and the ponds on the former Benton Trailer Park, as
necessary to monitor the contamination. The analytical data
generated from the quarterly sampling events will be used to
track the concentrations and movement of groundwater contaminants
until a long-term Site monitoring plan is implemented in the
remedial action phase.
"10.0 STATUTORY
The selected remedy and the contingency remedy for this Site both
meet the statutory requirements set forth in Section 121(b)(l) of
CERCLA, 42 D.S.C. S 9621(b)(l). This section states that the
remedy must: protect human health and the environment; meet
ARARs (unless waived) ; be cost-effective; use permanent
solutions, and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable; and
finally, wherever feasible, employ treatment to reduce the
toxicity, mobility or volume of : the contaminants. The following
sections discuss how both the selected and the contingency remedy
fulfill these requirements.
»
/
10.1 Selected R«*"»edy (SC-4/MM-4)
Overall Protection of Human Health and the Environment
Alternative 6 reduces exposure to soil contaminants in the source
area, with the groundwater remediation continuing until MCLs in
groundwater are attained. Alternative 6 also effectively
eliminates flow from the water table aquifer to the limestone
aquifer. It therefore provides protection of human health and
the environment for both VOCs and metals, and attains the
remediation goals for the KSCI study area . This alternative
enhances both environmental protection and a reduction in the
risk to human health.
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Compliance with ARARs
This remedial action alternative allows attainment of the goals
for soils contaminated with VOCs and metals and, in addition,
reaches the goals for groundwater remediation, it also attains
the ARARs for contaminants of concern. The discharge from the
air stripper may require treatment to attain air ARARs. The
groundwater discharge will meet the MCLs.
Short-Term Effectiveness
Impacts on the community are expected to be minimal during the
remedial action. The discharge of VOCs from the soil treatment
unit and possibly the air stripper may need to be treated.
Workers' exposure is not expected to be significant and will be
limited to possible volatiles during the well drilling operations
and during the installation of the soil treatment system. These
exposures can be minimized with a Site Health and Safety Plan.
-'*•
Alternative 6 includes the excavation of contaminated soils,
raising the possibility of community -and on-Site worker exposure
to the contaminants. Because many of the chemicals of concern
are volatile, worker exposure is 9 real possibility that will
require a strict Site Health and Safety Plan with air monitoring
-and respirators, or other engineering controls to limit exposure.
Wind blown dust can be controlled by keeping the material wet or
covered. Since the nearest residence is over 100 yards away,
community airborne exposure is not expected to exceed safe
levels.
The public water supply provides protection during remediation.
While a pilot test is needed to better estimate the time required
for soil treatment, experience from other Sites where this
technology was used suggests a time frame of 12 months or less
for soil remediation. Groundwater extraction and treatment, is
expected to require 30 years to achieve the MCLs for contaminants
of concern.
9
Long-Term Effectiveness
It is estimated to take up to 30 years of pumping 1 to 10 wells
at a cumulative pumping rate of 20 gpm to reach the MCLs for
contaminants of concern in the groundwater. The treatment of
soils will remove residual risks from VOCs and metals exposures.
This alternative reduces the risk for ingestion of groundwater
and reduces this risk into the range required under the NCP.
With the available public water supply, a monitoring system may
not be required under this alternative to manage residual
groundwater risks. Additional deep wells to the limestone
aquifer will be constructed and monitored to ensure no
contaminants reach the lower aquifer, thus verifying the
effectiveness of the remedy.
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Reduction of Mobility. Toxicitv or Volume
Alternative 6 reduces the mobility, toxicity and volume of VOCs
and the mobility of metals in the soils. The in-place volume is
estimated at 770 yds3. Groundwater remediation under this
alternative will reach the ARARs (MCLs). It is estimated that 30
years will be required to reach MCLs for groundwater and that 160
million gallons of groundwater will have to be pumped over that
period.
Implementability
All of the elements required under Alternative 6 are readily
available from a variety of vendors. The nationwide cleanup
program for underground storage tanks and the leakage of solvents
such as TCE and PCE from a variety of sources has resulted in
broad experience with enhanced volatilization to cleanup soils.
The Superfund Program has experience with the fixation of metals
in soils. A bench scale test to" determine stabilizing agents and
mix ratios will be required for this alternative. The long-term
reliability of the fixation process is unknown at this time;
however, bench scale tests designed to mimic accelerated time
frames have predicted good results' over the long-term. The
effectiveness of the soil treatment in groundwater quality will
"be determined from water quality monitoring done in the water
table.
*
Emissions from the air stripper must attain ARARs for air.
Treatment of the emissions can be undertaken if necessary.
Effluent from the groundwater treatment system must meet state
and federal standards for discharge.
Confirmation sampling can monitor the effectiveness of the soil
cleanup. In addition, groundwater monitoring of the existing
wells and new proposed well network can be used "to assess the
degree of reduction in groundwater contaminant levels.
Cost
Table 9-1 of the ROD presents an itemized breakdown of costs for
Alternative 6. Total initial project costs are estimated at
$1,605,640. Annual O&M costs are estimated at $1,896,527,
resulting in a total present worth in 1992 dollars of $3,502,167
for a 30 year service life and a five percent discount rate.
State Acceptance
The State has concurred with the remedy selected and the State
concurrence letter is attached as Appendix B. State concerns
regarding sediment remediation in the ditch and construction of
new deep wells to the lower aquifer already have been
incorporated into this Record of Decision.
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Page 82
Accetance
During the comment period and the extension to the comment
period, there was no opposition to the remedy selected by EPA in
the Proposed Plan. This Record of Decision includes a
Contingency Remedy based on comments received. All comments
received and EPA's responses are contained in the Responsiveness
Summary, attached as Appendix A.
10.2 Contingency Pennedv (SC-5/MM-4)
Overall Protection of Human Health and the Environment
The Contingency Remedy reduces exposure to soil contaminants in
the source area, with the groundwater remediation continuing
until KCLs in groundwater are attained. The Contingency Remedy
also effectively eliminates flow from the water table aquifer to
the limestone aquifer. It therefore provides protection of human
health and the environment for^both VOCs and metals, and attains
the remediation goals for the KSCI study area. This alternative
enhances both environmental protection and a reduction in the
risk to human health.
*
Compliance with ARARs
This remedial action alternative .allows attainment on-Site of the
goals for soils contaminated with* VOCs and metals with removal of
the contaminated soil and, in addition, reaches the goals for
groundwater remediation. It also attains the ARARs for
contaminants of concern. The discharge from the air stripper may
require treatment to attain air ARARs. The groundwater discharge
will meet the MCLs. , '
Short— Term Effectiveness
, •»•
Impacts on the community are expected to be minimal during the
remedial action. The possible discharge of VOCs from the air
stripper may need to be treated,' Workers' exposure is not
expected to be significant and will be limited to possible
volatiles during the well drilling operations. Dust particles
from soil removal activities will be short term and minimized by
proper procedures during the excavation and removal of the soils.
There will be secondary impacts caused by an increase in area
traffic from trucks removing the contaminated soils. These
exposures and impacts can be minimized with a Site Health and
Safety Plan.
The Contingency Remedy includes the excavation of contaminated
soils, raising the possibility of community and on-Site worker
exposure to the contaminants. Because many of the chemicals of
concern are volatile, worker exposure is a real possibility that.
will require a strict Site Health and Safety Plan with air
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Kalama NFL Site
Page 83
monitoring and respirators, or other engineering controls to
limit exposure. ^ .Hind blown dust can be controlled by keeping the
material wet or'covered. Because the nearest residence is over
100 yards away, community airborne exposure is not expected to
exceed safe levels.
The public water supply provides protection during remediation.
Groundwater extraction and treatment is expected to require 30
years to achieve the MCLs for contaminants of concern.
Long—Term Effectiveness
It is estimated to take up to 30 years of pumping 1 to 10 wells
at a cumulative pumping rate of 20 gpm to reach the MCLs for
contaminants of concern in the groundwater. The removal of
contaminated soils will remove residual risks from VOCs and
metals exposures on-Site. This alternative reduces the risk for
ingest ion of groundwater and reduces this risk into the range
required under the NCP. With the available public water supply,
a monitoring system may not be required under this alternative to
manage residual groundwater risks. Additional deep wells to the
limestone aquifer will be constructed and monitored to ensure no
contaminants reach the lower aquifer, thus verifying the
effectiveness of the remedy.
Reduction of Mobility. Toxicitv or Volume
• -,
The Contingency Remedy does not reduce the mobility, toxicity and
volume of VOCs and the mobility of metals in the soils. It does
however remove the contaminated soil from the Site. The in-place
volume is estimated at 770 yds3. Groundwater remediation under
this alternative will reach the ARARs (MCLs). It is estimated
that 30 years will be required to reach MCLs for groundwater and
that 160 million gallons of groundwater will have to be pumped
over that period. '
Implementability
*
f
All of the elements required under the Contingency Remedy are
readily available from a variety of vendors. The nationwide
cleanup program for underground storage tanks and the leakage of
solvents such as TCE and PCE from a variety of sources has
resulted in broad experience with enhanced volatilization to
cleanup soils. The effectiveness of the soil removal and its
impact on groundwater quality will be determined from water
quality monitoring done in the water table.
Effluent from the groundwater treatment system must meet state
and federal standards for discharge.
Confirmation sampling can monitor the effectiveness of the soil
removal. In addition, groundwater monitoring of the existing
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Kalama KPL Site
Page 84
wells and new proposed well network can be used to assess the
degree of reduction in groundwater contaminant levels.
Total initial project costs for the soil removal portion of the
Contingency Remedy are estimated at $495,000 and a one year soil
O&K cost of $5000. The total present worth in 1992 dollars is
$3,768,500 for a 30 year service life and a five percent discount
rate.
State Acceptance
The State has concurred with the Selected and Contingency
Remedies and the State concurrence letter is attached as Appendix
B. State concerns regarding sediment remediation in the ditch
and construction of new deep wells to the lower aquifer already
have been incorporated into this Record of Decision.
Community Acceptance
During the comment period and the extension to the comment
period, there was no opposition to the remedy selected by EPA in
the Proposed Plan. The Record of Decision includes this
'Contingency Remedy based on comments received. All comments
received and EPA's responses are contained in the Responsiveness
Summary, attached as Appendix A. • -
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APPENDIX B
STATE OF SOUTH CAROLINA. CONCURRENCE LETTER
KALAMA SPECIALTY CHEMICAL, INC., SUPBRFUND SITE
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.SEP-2g-1993 08:59 FROM
TO
914043471695
P.02
. South Carolina
DHEC
ffetart & Jtttour.
Robvt A Bbfefci* jr. vie*
2800 Bun StrMt CoUitnbu. SC 29201
AnolvcttA? fM
ToayGnfcmvJr.f
Jam a N*. MO
September 27, 1993
Mr. Patrick Tobin
Acting Regional Administrator
US EPA, Region TV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
RE: Final Record of Decision (ROD)
Kalama Specialty Chemicals KPL Site
Beaufort County »>
Dear Mr. Tobin:
The Department has reviewed, commented on, and concurs with
the Record of Decision (ROD) for the alternatives selected for
remedial action at the Kalama Specialty Chemicals NPL Site. The
alternatives for remedial activities selected by EPA include
excavation and treatment of contaminated soils using volatilization
and solidification or as a contingency, the removal of contaminated
soils from the site. EPA*s selected remedial activities also
include extraction and treatment of contaminated groundwater until
MCLs are reached.
In concurring with this ROD, the South Carolina Department of
Health and Environmental Control (SCDHEC) does not waive any right
or authority it may have to require corrective action in accordance
with the south Carolina Hazardous Waste Management Act and the
South Carolina Pollution Control Act. These rights include, but
are not limited to, the right to ensure that all necessary permits
are obtained, all clean-up goals and criteria are met, and to take
a separate action in the event clean-up goals and criteria are not
met. Nothing in the concurrence shall preclude SCDHEC from
exercising any administrative, legal and equitable remedies
available to require additional response actions in the event that:
(1) (a) previously unknown or undetected conditions arise at the
site, or (b) SCDHEC receives additional information not previously
available concerning the premises upon which SCDHEC relied in
concurring with the selected remedial alternative; and (2) the
implementation of the remedial alternative selected in the ROD is
no longer protective of public health and the environment.
SFSUOSU.WE8
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MB: 59 FROM TO 914043471695 P. 03
Mr. Patrick Tobin
September 27, 1993
Page 2
This concurrence with the selected remedy for the Kalama
specialty Chemicals NPL Site is contingent upon the state's above-
mentioned reservation of rights. If you have any questions, please
feel free to contact Mr. Lewis Bedenbaugh at (803)734-5211.
Sincerely,
/f
R. Lewis Shaw, P.E.
Deputy Commissioner
Environmental Quality Control
cc: Hartsill Truesdale
Lewis Bedenbaugh
Keith Lindler
Rebecca Dotterer
Harry Mathis
Charles Gorman
Billy Britton
Jim White
SHOCait.WfB
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