PB94-964001
EPA/ROD/R04-94/167
Julv 1994
EPA Superfund
Record of Decision:
Townsend Saw Chain Company Site,
Pontiac, SC
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RECORD OF DECISION
INTERIM REMEDIAL ACTION FOR OFFSITE GROUNDHATER MIGRATION
TONNSEND SAW CHAIN COMPANY SITE
PONTIAC, RICHLAND COUNTY
SOUTH CAROLINA
PREPARED BY:
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Townsend Saw Chain Company Site, Pontiac, Richland County, South
Carolina.
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected interim remedial
action for the Townsend Saw Chain Company Site, Pontiac, Richland
County, 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), and, to the extent practicable,
the National Oil and Hazardous Substances Contingency Plan (NCP).
This decision is based on the administrative record file for this
Site. The State of South Carolina concurs with the selected
remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
Site, if not addressed by implementing the response action selected
in this Record of Decision (ROD), may present an imminent and
substantial endangerment to public health, welfare, or the
environment.
DESCRIPTION OF THE REMEDY
The purpose of this interim action is to prevent the continued
off site migration of the plume of contaminated groundwater. As a
result of the Site remedial investigation, the offsite area
affected by chromium contamination in the surficial aquifer was
found to extend a much greater --distance from the Site than
previously known. Although the offsite groundwater data is
limited, concentrations at numerous distant sampling points
significantly exceed federal standards for chromium. The nearest
private water wells do not show contamination by chromium; however,
these wells are supplied from the underlying Middendorf Aquifer
and/or from lower portions of the surficial aquifer, thus
presenting a potential threat to human health. Additionally,
because the RI work to date has shown that the contaminated
groundwater discharges to a tributary and a creek, a potential
threat exists to the environment within and surrounding those
surface water bodies.
The interim action described in this Record of Decision will
expedite the mitigation of these threats through the design,
installation, and operation of a groundwater pump-and-treat
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- 11 -
system. The system will intercept the migrating groundwater along
the periphery of the plume, or at more appropriate locations as
determined from a pre-design-phase hydrogeologic study, and direct
the affected groundwater to onsite water treatment equipment.
Options for the ultimate disposal of the treated groundwater,
including discharge to a Publicly-Owned Treatment Works (POTW), to
a creek via NPDES permit, to an underground injection well system,
or another, to-be-determined disposal option, will be evaluated
during the design effort for this action, and may be further
developed in the final Site FS or in remedial design following the
final ROD.
The components of this interim action include:
1. Planning and timely execution of a pre-design-phase
hydrogeologic investigation, to accomplish such detailed
hydrogeologic characterization of the offsite groundwater
contamination as is necessary to support the remedial design
of a groundwater pump-and-treat system which will, as a
minimum, prevent further offsite migration and enlargement of
the contaminant plume; and
2. Expeditious design and construction of such a system, and
initiation of groundwater pump-and-treat operations.
This action is not the final remedial action for this Site.
Subsequent actions may be planned to fully address this and other
potential threats posed by conditions at the Site. These actions
will be defined when the RI/FS is complete. Other potential
threats at this Site include soil contamination and possible
ecological damage in the area of the unnamed, offsite tributary
northeast of the Site.
STATUTORY DETERMINATIONS
This interim action is protective of human health and the
environment, complies with Federal and State applicable or relevant
and appropriate requirements for this limited-scope action, and is
cost-effective. Although this interim action is not intended to
address fully the statutory mandate for permanence and treatment to
the maximum extent practicable, this interim action does utilize
treatment and thus is in furtherance of that statutory mandate.
Because this action does not constitute the final remedy for the
Site, the statutory preference for remedies that employ treatment
that reduces toxicity, mobility or volume as a principal element,
although partially addressed in this interim remedy, will be
addressed by the final response action. Subsequent actions are
planned to fully address the threats posed by the conditions at
this Site. Because contaminants present in groundwater will remain
above health-based levels until the final remediation is completed
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- iii -
at the Site, a review will be conducted within five years after
commencement of the remedial action, to ensure that the remedy
continues to provide adequate protection of human health and the
environment. Because this is an interim action ROD, review of this
Site and of this remedy will be ongoing as EPA continues to develop
final remedial alternatives for the Site.
The State of South Carolina concurs with the selection of this
interim remedial alternative.
Patrick M. Tobin Date
Acting Regional Administrator
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RECORD OF DECISION
INTERIM ACTION FOR OFFSITE GRODNDWATER MIGRATION
TOWNSEND SAW CHAIN COMPANY SITE
TABLE OF CONTENTS iv
TABLE OF CONTENTS iv
LIST OF FIGURES v
LIST OF TABLES V
1.0 INTRODUCTION 1
2 .0 SITE LOCATION AND DESCRIPTION 3
2.1 Site Topography and Drainage 3
2.2 Geologic and Hydrogeologic Setting 3
3.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES 6
4.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION 8
5.0 SCOPE AND ROLE OF THE INTERIM ACTION WITHIN SITE STRATEGY. 9
6.0 SUMMARY OF SITE CHARACTERISTICS 10
6.1 Site-Specific Geology and Hydrogeology 10
6.2 Preliminary RI Findings: Extent of Groundwater
Contamination 11
7.0 SUMMARY OF SITE RISKS 14
8.0 DESCRIPTION OF ALTERNATIVES 15
9.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 17
10.0 THE SELECTED REMEDY 20
10.1 Description of the Interim Remedial Action 20
10.2 Applicable or Relevant and Appropriate Requirements 23
10.2.1 Applicable Requirements 23
10.2.2 Relevant and Appropriate Requirements 26
10.2.3. "To Be Considered" (TBC) and Other Guidance 26
10.2.4 Other Requirements 28
10.3 Performance Standards 28
11.0 STATUTORY DETERMINATIONS 28
APPENDICES
APPENDIX A: RESPONSIVENESS SUMMARY
APPENDIX B: STATE OF SOUTH CAROLINA CONCURRENCE LETTER
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RECORD OF DECISION
INTERIM ACTION FOR OFFSITE GRODNDWATER MIGRATION
TOWNSEND SAW CHAIN COMPANY SITE
LIST OF FIGDRES
FIGURE PAGE
1 Site Location Map 2
2 Site Area Map 4
3 Site Layout Map 5
4 Offsite Groundwater Contamination 12
LIST OF TABT.ES
TABLE PAGE
1 Offsite Groundwater Sampling Results 13
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INTERIM ACTION RECORD OF DECISION
TOWNSEND SAW CHAIN COMPANY SITE
Pontiac„ Richland Countv. South Carolina
1.0 INTRODUCTION
The Townsend Saw Chain Site is a small manufacturing facility
located approximately 15 miles east-northeast of Columbia, South
Carolina (Figure 1). The facility is presently owned by Homelite
Division of Textron, Inc. ("Textron"), and managed by the Homelite
Division ("Homelite") located in Charlotte North Carolina. In
operation since 1972, the facility is used for the manufacture of
the saw chain and saw bar components of chain saws. Prior to 1972,
between 1965 and 1971, Dictaphone Corporation manufactured
specialized recording equipment at the facility.
Between 1966 and 1981, under both Dictaphone and Townsend Saw Chain
Company (later Textron), waste rinsewaters produced during metals-
plating processes were disposed of by direct discharge to the
ground surface in the low-lying "waste pond" areas adjacent to the
facility on the north side. These discharges caused contamination
of Site, groundwater, primarily by chromium.
The South Carolina Department of Health and Environmental Control
(SCDHEC) has overseen environmental investigations and ongoing
remediation of groundwater at the Site since 1982. The Site was
evaluated by EPA for possible inclusion on the National Priorities
List in 1987, using the Hazard Ranking System (HRS). Because of
the large number of people in the surrounding area served by water
wells, the Site was assigned an HRS score of 35.94, and was
proposed for listing on the NPL in June 1988. The Site was listed
on the NPL in February 1990.
In August 1991, Homelite Textron, Inc. agreed to perform a Remedial
Investigation/Feasibility Study (RI/FS) at the Townsend Site. RI
field work began in May 1992 and the RI Report is presently in
preparation. The major preliminary finding of the RI is that the
areal extent of chromium-contaminated groundwater in the surficial
aquifer is greater than previously believed. The precise extent of
groundwater contamination is not yet known, but current data
indicate that nearby potable water wells could be impacted at
levels above Federal and state groundwater quality standards,
unless measures are taken to intercept and/or control the offsite
movement of the contaminant plume. This future potential risk to
human health will be reduced or eliminated by the proposed Interim
Remedial Action described in this Record of Decision.
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Townsend Saw Chain Company Site
Page 2
FIGURE 1
SITE LOCATION MAP
TOWNSEND SAW CHAIN COMPANY SITE
SOUTH CAROLINA
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Towns end Saw Chain Company Site
Page 3
2.0 SITE LOCATION AND DESCRIPTION
The Site is located in Richland County, South Carolina,
approximately 15 miles east-northeast of Columbia, at the
intersection of Interstate Highway 20 and State Highway 53 (Spears
Creek Church Road). The nearest municipality is the town of
Pontiac. Fort Jackson military reservation is located across
Interstate 20 south of the Site (Figure 2).
The facility property consists of approximately 50 acres and is
surrounded by a barbed-wire fence. During the RI, the five study
areas shown on Figure 3 were investigated on the facility property.
Off site, across SC Road 53 (Spears Creek Church Road) approximately
600 feet northeast of the property boundary, a small seep or spring
forms the origin of an unnamed tributary of Spears Creek.
Throughout this document, the terms onsite and offsite are used to
denote locations within the facility property (onsite), and those
across SC Road 53 to the northeast, east and east-southeast
(offsite).
2. 1 SiteTopography and Drainage
The Site lies within the Upper Coastal Plain physiographic
province. Topographically, the region is characterized by flat or
gently rolling terrain dissected by densely vegetated streams and
creeks. Soils in the area consist predominantly of quartz sand,
resulting in high soil permeability and rapid infiltration of
rainwater into the underlying geologic units. There is little or
no surface runoff.
Elevations on Site range from 350 to 375 feet above mean sea level.
The Site is relatively flat. There is no direct (surface) drainage
of any portion of the Site to drainage features. The nearest
significant drainage is the above-mentioned spring, which feeds an
unnamed tributary of Spears Creek. The tributary flows
northeastward to its confluence with Spears Creek approximately
3700 feet northeast of the facility.
2.2 Geologic and Hydrogeologic Setting
The Upper Coastal Plain province is underlain by a seaward-dipping
wedge of unconsolidated sediments overlying crystalline bedrock.
The sandy surface soils (the Lakeland and Kershaw soil series) were
formed from Tertiary marine and eolian (wind-deposited) sands.
These soils are typically gray to white and give the White Sand
Hills region its name.
Underlying these soils is the upper Cretaceous Middendorf Formation
(previously designated the Tuscaloosa formation). The Middendorf
consists of sands and kaolinitic clays representing fluvial and
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MESSERS POND, 3. C,
N3400—W8045/7 5
FIGURE 2
SITE AREA MAP
TOWNSEND SAW CHAIN COMPANY SITE
CONTOUR INTERVAL 10 FEET
0«1UH 19 MEAN SCA LEVEL
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Approximate Spring Locations
:' A
—• To Interstate 23—•/! f\\—
Legend
Unnamed Tributary
("Offsite Tributary")
®-Sludg Area No. 1
Waste Pond Area
©-Study Area No. 2
Spray field .
®-S1udg Area. No. 3a
Septic Tank & OralnHeld
@-Study Area No. 3b
Septic Tank & Oralnfield
0-Study Area No. 4
Former Waste Pipe
©-Study Area No. 3b
Drainage Ditch
^-.C. State Road 53
I Spears Creek Church Road
0 180 200 300 400
From Interstate 20
FIGURE 3
SITE LAYOUT MAP
TOWNSEND SAW CHAIN COMPANY SITE
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Townsend Saw Chain Company Site
Page 6
deltaic environments. Subsurface structures present in these
sediments include stream channels, overbank deposits, channel
scours and fills, and floodplain deposits. Locally, such
structures may control groundwater flow patterns. The formation is
approximately 200 feet thick in the area of the Site.
Sand strata within the Middendorf are productive aquifers, and the
formation serves as a major aquifer in South Carolina. Yields of
10 to 25 gallons per minute (gpm) from wells screened at depths of
50-100 feet, and up to several hundred gpm from those screened from
150-200 feet, are obtained in the Fort Jackson area. Groundwater
in the area is classified by EPA as Class IIA and by South Carolina
as Class GB.
3.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
In 1964, Dictaphone Corporation purchased an approximately 100-acre
parcel 'of land, which eventually became the Site, and constructed
a small manufacturing facility to be used primarily for the
assembly of certain models of the company's line of office
recording equipment. Details of the operations used are
unavailable, but two permits issued by the State of South Carolina
indicate that wastewaters generated onsite contained low levels of
zinc, cyanide, chromium (chromate ion) and residues from acid and
alkali cleaning. Operations on site were permitted for the period
between June 1966 and June 1971.
Townsend Saw Chain Company purchased the Site in June of 1971.
Their operations onsite began in July 1972. From that time to the
present, the main operation of the facility has been the
manufacture and assembly of saw chains for chain saws. Processes
which comprise this overall operation include metal punch-pressing,
metal plating (chromium), heat treatment (heat quench bath), a
rust-preventative bath, and metal parts cleaning and finishing.
Wastewaters produced by these processes contained chromium,
cadmium, cyanide, nitrite and nitrate salts, and several volatile
organic compounds (VOCs).
Between 1966 and 1981, under both Dictaphone and Townsend Saw Chain
Company (later Textron), waste rinsewaters produced during the
metals-plating and other processes described above, were disposed
of by direct discharge to the ground surface in the low-lying
"waste pond" areas adjacent to the facility on the north side.
These discharges, which occurred over a period of approximately 15
years, are the origin of the onsite groundwater contamination. In
1982, after the South Carolina Department of Health and
Environmental Control (SCDHEC) investigated the site, Textron was
fined by the State for violations of the established wastewater
treatment rules. Investigations since 1982 have confirmed the
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Townsend Saw Chain Company Site
Page 7
presence of groundwater contaminated by chromium and nitrate onsite
and offsite, as well as trace groundwater concentrations of
volatile organic compounds (VOCs).
Since 1982, SCDHEC has continued to oversee Textron's remediation
program for groundwater. In 1982, a groundwater treatment system
was installed, consisting of five extraction (pumping) wells,
chemical treatment tanks, and a spray or irrigation field for
disposal of the treated water. This system is still in operation.
Groundwater is extracted, chemically treated to the applicable
South Carolina groundwater quality standard for chromium (0.050
mg/1), and then discharged to the spray field. Plant process
wastewater is also treated together with the contaminated
groundwater. Performance of the system and conditions at the spray
field are monitored by SCDHEC.
In 1987, SCDHEC identified problems in the treatment system's
design and performance. To address those deficiencies, a
subsequent 1988 modification to the 1982 Court Order directed
Homelite to further investigate and define the extent of
groundwater contamination, and to investigate Site hydrogeology as
necessary to modify the system's design. A report with design
revisions was submitted to SCDHEC in 1990, and following SCDHEC
review, again in December 1991. The redesign effort has been
completed and operation of the expanded pump-and-treat system
(referred to as the "enhanced system") will begin in February or
March 1994.
Between 1985 and 1988, SCDHEC and EPA took the necessary steps to
list the Site on the National Priorities List (NPL), which places
it in the Superfund program. A 1985 Preliminary Assessment/Site
Inspection (PA/SI) by SCDHEC revealed elevated and/or above-
background concentrations of chromium, lead, cadmium, arsenic,
cyanide, nickel, and four VOCs-- in - groundwater at the site.
Chromium, lead, cadmium and arsenic were present at elevated levels
in sediments within the waste pond area, and a stream water sample
taken just across Spears Creek Church Road north of the site
contained chromium and four VOCs. Based on these results, the Site
was then ranked by EPA in 1987 using the Hazard Ranking System
(HRS), which evaluates the potential for public exposure to site
contamination. Because of the potential for migration of
groundwater contaminants offsite, and the large number of people in
the surrounding area served by water wells, the Site was assigned
an HRS score of 35.94 and was proposed for listing on the NPL in
June 1988. The Site was finalized on the NPL in February 1990.
EPA and Homelite signed an agreement in October 1991 under which
Homelite agreed to conduct a Remedial Investigation/Feasibility
Study (RI/FS). Dictaphone Corporation was named as a Potentially
Responsible Party (PRP) by EPA when the Agency notified both
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Townsend Saw Chain Company Site
Page 8
Home lite and Dictaphone that an RI/FS was required for the Site.
Dictaphone has not participated in the RI/FS to date.
RI/FS field work began in early May 1992. The initial work
included a monitor well upgrade/abandonment program to insure the
reliability of the onsite and off site monitor wells, and an initial
sampling of Site soils and the monitor wells. The preliminary
results of these sampling activities were presented in the
"Preliminary Site Characterization Summary, " submitted by the PRP's
contractor to EPA in September, 1992.
Based on these initial ("Phase I") results, Homelite proposed
further investigation of site groundwater and soils. This effort
was designated "Phase II" and began in November 1992. Combined
Phase I and II activities have included the installation and
addition of 15 new monitoring wells to the previous 38-well
network. Sampling has included collection and laboratory analysis
of 73 groundwater samples, 17 surface water (stream) samples, 19
stream* sediment samples, 35 soil samples, 10 septic tank sludge
samples, 6 septic tank wastewater samples, and 10 air samples.
Additionally, between January and July 1993, three rounds of
offsite shallow groundwater sampling were performed. A total of 48
offsite groundwater samples were collected. After a delay during
which access to surrounding properties was obtained, offsite
groundwater sampling was continued during June and July 1993. In
late June 1993, EPA decided to move forward with an Interim Action
at the Site.
4.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
During the workplan preparation phase of the RI, EPA established an
information repository at the nearest library, the Richland County
Northeast Branch Library in east Columbia. Materials placed at the
repository at that time (April 1992) included background
information on Super fund and on the Site. Later, in December
1992, the Administrative Record (AR) for the Townsend Saw Chain
Site was established. Upon EPA approval of the PRP's RI/FS work
plans, the plans were then added to the AR.
An RI "kickoff" public meeting was held by EPA at Pontiac
Elementary School on April 22, 1992. Approximately 70 persons
attended this meeting. Most public questions and concerns centered
around two issues: the proximity of the Site to Pontiac Elementary
School, and the long period of groundwater cleanup that has
transpired without completion of the cleanup effort. EPA staff
explained the lack of any health threats to the school children
based on the known situation at that time, and that the RI work
included investigation of any such possibilities. EPA and SCDHEC
officials also explained the specific details of Homelite's
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Towns end Saw Chain Company Site
Page 9
groundwater remediation activities, their status, and EPA's RI
objectives in regards to groundwater contamination.
Following completion of Phase II field work in the summer of 1993,
EPA prepared a Fact Sheet to provide public notice of EPA's
proposed interim action, to establish a public comment period, and
to solicit public comments. The Proposed Plan Fact Sheet
established a public comment period from August 20, 1993, to
September 20, 1993. Prior to the start of the comment period, a
focused Feasibility Study document, prepared by the PRP's
contractor and entitled "Technical Memorandum on Interim Remedial
Action," was made available at the information repository. This
document outlines the specifics of the Interim Action to the degree
possible with current information, and provides preliminary
evaluations of the possible options for groundwater treatment and
disposal to be considered in full in the Interim Action. The
Technical Memorandum was then officially added to the AR on August
18, 1993. A notice to area citizens concerning the Proposed Plan
public' meeting was published in Columbia's daily newspaper, The
State, on August 20, 1993.
An Interim Action Proposed Plan public meeting was held to present
the Interim Remedial Action Proposed Plan to the public on August
31, 1993 / at Pontiac Elementary School. Approximately 70 persons
attended the meeting. The public expressed a great deal of
interest in the Interim Remedial Action. Most questions concerned
EPA's planned precautionary sampling of four private water wells
at the southwest end of Woodcreek Lake. Details concerning area
residents' concerns are provided in the Responsiveness Summary
comprising Appendix A to this ROD.
5.0 SCOPE AND ROLE OF THE INTERIM ACTION WITHIN SITE STRATEGY
The scope of the proposed action includes two components: 1)
expedited design and construction of a groundwater pump-and-treat
system to prevent or minimize continued offsite migration of
contaminated groundwater; and, prior to the design effort, 2)
planning and conduct of a focused hydrogeologic study to support
the design.
The Interim Action addresses groundwater contamination, which at
this time appears to be the principal threat posed by the Site.
However, this is not the final remedial action at this site.
Following completion of the FS, EPA will issue a Proposed Plan for
a final remedial action (remedy) at this Site. It will also
address environmental contamination in other media (soil, surface
water) in addition to groundwater. It will also consider the
adequacy of, or possible modifications to, the groundwater pump-
and-treat system proposed in this Interim Action, for effectively
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Interim Action Record of Decision
Townsend Saw Chain Company Site
Page 10
cleaning up all contaminated groundwater resulting from the Site.
Under the current schedule, a ROD would be issued by EPA in the
summer of 1994.
6.0 SUMMARY OF SITE CHARACTERISTICS
This Interim Action is concerned with the offsite migration of
contaminated groundwater. Therefore, this section provides a
summary of those site characteristics most related to this aspect
of Site contamination.
6.1 Site-Specific Geology and Hydroaeoloqv
Boring logs from the RI and from past investigations have been used
to develop an understanding of Site geology. Based on
stratigraphic and hydrogeologic characteristics, sediments
underlying the Site can be divided into three units:
Unit I is exposed at the surface and consists of interbedded
and alternating layers of sand, silty or clayey sand, and silt or
clay lenses. These various strata are apparently hydraulically
connected. Groundwater occurence and movement in Unit I is
controlled by the types of sediment strata present, and their
configuration. Perched water zones occur, for example, in the area
of the former waste ponds.
Unit II is a low-permeability confining unit consisting of
hard, dry, kaolinitic silty clays or clayey silt. Unit II appears
to be laterally continuous on the Site property. The RI work to
date has not revealed any locations where Unit II is absent;
however, its continuity" and extent in offsite areas has not yet
been determined.
Unit III consists of slightly-silty, fine- to medium-grained
sand. Because few Site borings to date have penetrated into Unit
III, its hydrogeologic and stratigraphic characteristics are not
well known. Two deep wells recently installed in the offsite area
will provide further information on unit III.
The lower portion of unit I, and all of units II and III are part
of the Hiddendorf Formation. It is important to note that the
simple, general outline of units I-III given above is not meant to
infer that simple patterns of groundwater flow and occurrence are
present. Viewed as a whole, the subsurface arrangement of various
sediment lenses and layers, having different grain sizes and
hydrologic properties, creates a complex geometry and complicates
attempts to locate plume boundaries or model Site groundwater flow
patterns.
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Townsend Saw Chain Company Site
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6.2 Preliminary RI Findings; Extent of Groundwater Contamination
The RI Report is presently in preparation. The following summary
provides a preliminary overview of the RI results to date,
particularly with respect to groundwater.
Sampling of the monitoring wells on the Site and across Spears
Creek Church Road confirmed that the chromium and nitrate
contamination extends offsite to the northeast. However, Phase II
offsite groundwater sampling further showed that the areal extent
of chromium-contaminated groundwater in the shallow (surficial)
aquifer is much larger than previously believed. The extent of
contamination by nitrate is not known, as the offsite sampling was
intended to identify the main Site contaminant of concern,
chromium. Figure 4 illustrates the areal extent of the
contamination defined to date, and the locations from which the 48
surficial aquifer samples were collected. No pattern was evident
in the distribution of the detected chromium levels. Levels of
chromium in the 48 offsite samples (Table 1) generally ranged from
0.20 mg/1 to 2.50 mg/1, although two samples (TW-6 and HP-20)
registered significantly higher. Delineation of the horizontal and
vertical boundaries of the contaminated groundwater (the "plume")
is currently underway.
The offsite groundwater sampling has, thus far, been accomplished
primarily by using direct-push techniques (DPT) in order to get
analytical data (Table 1) as rapidly as possible. Samples have
also been recovered from hand-auger borings with temporarily-
installed wells, and from surface seeps. Direct-push sample
collection involves the use of a special device which drives hollow
rods downward through the overlying soil or geologic unit to reach
groundwater or a desired depth. DPT samples can be collected
rapidly, inexpensively, and without disturbance to the ground
surface.
It should be noted that analytical data collected via DPT may have
limited accuracy due to inherent problems in the sampling methods
used. One common problem is that the analyses can show more
chromium than is actually present and moving in the groundwater,
due to recovery of samples high in turbidity (clays or other fine
particulates). Nonetheless, even with these limitations, the data
indicate that shallow groundwater across the large offsite area
shown on Figure 3 is contaminated by chromium at levels ranging up
to many times the maximum contaminant level (MCL). MCLs have been
established by EPA and the states pursuant to the Safe Drinking
Water Act of 1974, and specify the maximum permissible amount of a
substance in public potable water supplies, and within aquifers
used as potable water sources. EPA believes that a concentration
of a substance in potable water supplies at or below the respective
MCL will not cause unacceptable risk to human health. For
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LEGEND
Defined Extent (0.1 mg/L Chromium)
- - - Possible Extent Based on Offsite Data
SCALE: 1 inch •= 875 feet (320 m)
FIGURE 4
OFFSITE GROUNDWATER CONTAMINATION
TOWNSEND SAW CHAIN COMPANY SITE
CO P-
o> n
H-O
3 H
9 HI
10 O
S (D
in M n
3^ H-
(0 co co
(-• p-
ft O
10 (D 3
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Towns end Saw Chain Company Site
Paqe 13
TABLE 1
OFFSITE GROUNDWATER SAMPLING RESULTS
Sample Point (1)
HP-1
HP-2
HP-3
HP-4
HP-5
HP-6
HP-7
HP-8
HP-9
HP-10 '
HP-11
HP-12
HP-13
HP-14
HP-15
HP-16
HP-17
HP-18
HP-19
HP-20
HP-21
HP-22
HP-2 3
Seepage #1
Seepage #2
Seepage #3
Seepage #4
Seepage f5
Result (mg/L)
0.810
0.168
0.200
0.970
1.200
0.280
0.880
0.420
0.480
0.260
1.400
0.050
1.000
0.310
0.600
0.330
0.390
< 0.050
0.580
4.000
0.420
< 0.050
2.500
< 0.050
< 0.050
0.080
< 0.050
< 0.050
Sample Point
DPT1-27 t2)
DPT1-45
DPT3-37
DPT4-37
DPT5-30
DPT6-25
DPT8-47
DPT9-24
DPT10-24
DPT11-11
DPT12-9
DPT13-28
DPT14-52
TW-1
TW-2
TW-3
TW-4
TW-5
TW-6
TW-7
TW-8
TW-9
TW-10
- TW--11
TW-12
Result (mg/L)
< 0.050
< 0.050
0.530
0.740
0.310
0.510
0.670
0.260
0.930
< 0.050
1.800
< 0.050
0.240
< 0.050
0.340
> 0.050
0.240
0.120
11.200
0.180
0.330
< 0.050
0.070
< 0.050
< 0.050
All results are for total chromium.
NOTES:
1. HP: Samples collected using HydroPuncA® system.
OPT: Samples collected via HydroCone® system.
TW: Samples collected from temporary well boreholes.
HydroPunch* and HydroCone® are direct-push technologies.
2. For the DPT samples, depth of sample recovery is indicated by the
number following the sample number. For example, sample DPT1-27
was collected at 27 feet below ground surface.
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chromium/ the South Carolina MCL is 0.05 milligrams per liter
(mg/1), while the Federal MCL is 0.10 mg/1.
Reconnaissance of the off site area bounded by Interstate 20, Spears
Creek, and the unnamed tributary/ has revealed a number of
scattered/ small trash-dumping locations. The presence of these
trash dumps, the occurrence of the two unusually elevated
groundwater samples (11.20 mg/1 and 4.00 mg/1), and the lack of
historical knowledge about the offsite area, together support the
possibility that sources other than the Site could be contributing
contaminants to groundwater. This issue will be further
investigated during the Interim Action.
As a precaution/ Homelite sampled 7 private wells along the south
side of Interstate Highway 20. These samples all indicated less
than 0.004 mg/1 for chromium and below the quantification limit
(and below MCLs) for VOCs.
As noted above, the RI surface water samples also indicate
potential risks to the ecological health of the unnamed offsite
tributary. An upcoming Ecological Assessment (EA) by Homelite in
this area, with EPA involvement and oversight, should resolve the
issue of whether ecological damage has occurred. The EA results
will be considered in the FS for the Site.
7.0 SUMMARY OF SITE RISKS
At this time, the Baseline Risk Assessment has not yet been
completed. However, the groundwater sampling results clearly
indicate that chromium-contaminated groundwater is migrating
offsite in the direction of private water wells, located to the
southeast and east of the Site. As noted above, even allowing for
some inaccuracy in the direct-push sample results, chromium levels
in groundwater range up to 2.50 mg/1 (excluding two higher
samples)/ many times above the Federal and State MCLs (0.10 and
0.05 mg/1/ respectively). The main contaminant of concern is
chromium, although nitrate and several VOCs have been detected at
levels above MCLs in offsite wells.
While the contamination may be limited to the shallow aquifer,
nearby private water wells could still be impacted at levels above
the MCL, unless measures are taken to intercept and/or control the
offsite movement of the contaminant plume. Most wells registered
with the State of South Carolina draw water from the deeper aquifer
(the Middendorf Aquifer), from which no offsite data is available
yet. However/ the depths of some of the registered wells are not
known. EPA believes that water supply wells at some of the homes
surrounding Woodcreek Lake are fairly shallow, possibly drawing
water from the shallow aquifer. The purpose of the Interim Action
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is to minimize or prevent the continued offsite movement of
contaminated groundwater. Potential risks to human health posed by
consumption of contaminated groundwater will be reduced or
eliminated by the proposed Interim Action.
As noted above, the RI surface water samples also indicate risks to
the ecological health of the unnamed offsite tributary. An
Ecological Assessment in this area will be conducted as part of the
FS. The data collection portion of this Interim Action will
provide further information useful to the Ecological Assessment.
Also, depending on the actual well locations, the pump-and-treat
system may improve surface water quality by removing contaminated
groundwater, thus preventing it from reaching the tributary.
8.0 DESCRIPTION OF ALTERNATIVES
EPA considered two alternatives before proposing this Interim
Action'. The alternatives are briefly described below.
Alternative 1; No Action. CERCLA requires EPA to consider a "no-
action alternative" at every site for which remedial action is
proposed, to serve as a baseline for comparison with other
alternatives.
Under the No Action Alternative, EPA would take no actions to
minimize or prevent the continued offsite movement of contaminated
groundwater. However, because contamination would remain onsite,
EPA would require a review of this remedy every five years in
accordance with CERCLA. This would constitute an O&M cost, and the
only cost under this alternative.
Construction Cost: $ 0
Operation and Maintenance (O&M) Costs?
(six 5-year reviews over 30 years,
$15,000 each, discounted at 5%/year) S 41.700
Total Costs: $ 41,700
Time Required to Implement Remedy: None.
Alternative 2; Interim Action Pump-and-Treat System. In order to
minimize or prevent the continued offsite movement of contaminated
groundwater, a pump-and-treat system that will intercept and
capture the contaminated groundwater at the periphery of the plume,
or at other appropriate locations as determined during design, will
be designed and built. After groundwater is extracted, the system
will direct it to a treatment facility. The Interim Action Pump-
and-Treat System (hereafter referred to as the "Interim System")
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will, as a minimum, allow control over the off site migration of the
contaminated groundwater.
The Interim Action has two components:
1. Pre-Design Hydrogeologic Study
2. Design, Construction and Operation of the Interim Action
Pump-and-Treat System
The first component is a short, focused investigation of the
hydrogeologic characteristics of the offsite area. Detailed
hydrogeologic information beyond the scope of the RI/FS is needed
to successfully design a system that will accomplish the objectives
described above. Also, the locations of the worst chromium and VOC
contamination and any other highly contaminated areas (including,
possibly, soil contamination) must be determined. Approximately
three months will be required to complete this effort.
Design; .construction and operation of the Interim Groundwater Pump-
and-Treat System is the second component of the Interim Remedial
Action. The design will be expedited to correspond to the limited
objectives of the Interim Action; i.e., peripheral control of the
plume rather than the aggressive pumping and treating of all
contaminated groundwater in the off site area. Issues which must be
resolved during design include: the number and placement of pumping
wells; the type and degree of treatment required, including whether
treatment for VOCs is required in addition to chromium; where to
discharge the treated groundwater; and what standard must be
achieved to meet the influent requirements of the chosen discharge
option. These issues are interrelated; for example, the type of
discharge will strongly" affect the degree of treatment. The design
should take approximately four to five months to complete.
Construction and operation of the Interim System will immediately
follow EPA's approval of the design. The Interim System will
consist of between 6 and 8 wells, or another number as determined
during the remedial design, submersible or other appropriate pumps,
pipes /lines, a treatment unit to remove or reduce chromium, and
other appurtenances as necessary to complete the system. After the
groundwater is treated, it will be discharged to either: 1) a local
publicly-owned treatment works (POTW), 2) Spears Creek via an
appropriate NPDES permit (National Pollution Discharge Elimination
System), or 3) another, to-be-determined disposal option. As
stated above, the discharge option to be used will be determined in
the design phase. Three to five months will be needed to construct
the Interim System.
In accordance with CERCLA, federal and state requirements, referred
to as Applicable or Relevant and Appropriate Requirements (ARARs),
are recognized for this Interim Action. At this time, EPA believes
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that the Interim Action will meet all ARARs which pertain to
groundwater as a source for potable drinking water, and to the
treatment technologies which groundwater remediation will involve.
These ARARs include specific provisions of the Safe Drinking Water
Act, the South Carolina Safe Drinking Water Act, the Clean Water
Act, the South Carolina Pollution Control Act, the Resource
Conservation and Recovery Act, the South Carolina Hazardous Waste
Management Act, and the federal and state regulations which
implement these statutes. More detailed information concerning
ARARs is presented in Section 10.2.
The cost estimates presented below are based on the limited
information available at present. O&M costs after the first year
will depreciate at an estimated 7% per year. However, the present
worth cost of the O&M over an anticipated period of operation
cannot be calculated at this time, because the hydrogeologic data
and modelling necessary to make an estimate of the length of the
period of operation, are not yet available.
Design and Construction Cost (includes design cost
and treatment system equipment) 1,610,000
Operation and Maintenance (O&M) Costs: 280,050
Disposal Costs - Treated Groundwater 34.500
Total Cost Estimate $1,924,550
Time to Begin Pump-and-Treat Operations: 10 - 13 months
9.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
EPA uses nine criteria to evaluate the alternatives which could be
selected. The first seven are used to evaluate the alternatives
based on environmental protection-, cost, and engineering
feasibility issues. The preferred alternative is then further
evaluated based on the final two criteria. State and community
acceptance. To be selected by EPA, an alternative must meet the
first two "threshold" criteria, overall protection of human health
and the environment, and compliance with ARARs.
This evaluation is more limited in scope than would be the case if
the Interim Action was to be the final remedy at this Site. As
noted above, following completion of the FS, EPA will issue a
Proposed Plan for a final remedial action (remedy) for the Site.
The final remedy will reconsider the planning and design for the
groundwater pump-and-treat system proposed in this Interim Action,
and may propose system additions, modifications, or other actions,
to accomplish remediation of all contaminated groundwater
originating from this Site. Thus, this Interim Action will be
consistent with the final remedy.
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EPA's rationale for selecting this action is presented below, in
relation to each of the nine criteria. The site-specific rationale
is indicated by the " D " symbol.
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.
D The No Action Alternative would not be protective of human
health and the environment. Potential threats to private
water well users located east and southeast of the Site will
remain. Since this threshold criterion is not met, the No
Action alternative is not considered further in the evaluation
below.
D The Interim Action Pump-and-Treat System will achieve
protection of human health and the environment through
interception or control of the offsite groundwater plume's
movement, thereby preventing contamination of private water
wells. Treatment of the contaminated groundwater will also,
to some degree, reduce any ecological effects which may be
occurring in the unnamed tributary to Spears Creek.
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
ARAR cannot be met, the analysis of the alternative must provide
the grounds for invoking a statutory waiver.
D The Interim Action will meet ARARs concerning groundwater.
The major ARARs for this action include specific provisions of
the Clean Water Act, the South Carolina Water Pollution
Control Act, and the associated State and Federal regulations
that implement those two statutes.
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.
D Long-term effectiveness cannot be evaluated at this point, but
rather must be evaluated together with any additional
groundwater remedial actions which may be proposed in the
final Proposed Plan for this Site. The long-term
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effectiveness and permanence of all proposed groundwater
cleanup actions will be considered at that time.
4. Reduction of Toxicity f Mobility, and Volume addresses the
statutory preference for selecting remedial actions that employ
treatment technologies that permanently and significantly reduce
toxicity, mobility, or volume of the hazardous substance as their
principal element.
D Capture and/or control of the contaminant plume will reduce
the mobility of the contaminated groundwater. Treatment of
the groundwater will reduce both the toxicity and volume of
contaminated groundwater.
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.
D No adverse short-term effects are expected to result from this
action. Most of the off site area known to be affected is
presently undeveloped. Site work will adhere to a Site-
specific Health and Safety Plan to reduce any potential short-
term risks to workers and nearby residents.
6. Implement ability refers to the technical and administrative
feasibility of implementing an alternative, including the
availability of various services and materials required for its
implementation.
D The Interim Action should be easily implementable, in that the
materials and services needed to design and construct the
groundwater system are readily available.
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.
D The cost of the Interim Action is estimated at approximately
$1,924,550, which includes a first-year annual operating cost
of $280,050. The present net worth of long-term O&M costs
cannot be estimated yet, but is expected to constitute the
major portion of the overall cost of the action.
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 proposed by EPA as the selected
alternative (or "remedy").
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D The State of South Carolina concurs with this Interim Action.
9. Community Acceptance addresses whether the public agrees with
EPA's selection of the alternative.
D A public meeting was held on August 31, 1993, to present the
Proposed Plan for the Interim Remedial Action to the
community. Comments at the meeting were generally supportive
of the proposed action. Extension of the public comment
period has not been requested. There is strong local interest
and concern from residents living around Woodcreek Lake and
from those east of Spears Creek (Figure 4).
10.0 THE SEUBCTED REMEDY
Based upon consideration of the requirements of CERCLA, the NCP,
consideration of the alternatives, and public and state comments,
EPA has'selected an interim remedy that addresses off site migration
of contaminated groundwater at this Site. Although a numerical
estimate of the risks which will remain at the Site upon completion
of this remedy cannot be made at present, the achievement of the
MCLs for groundwater will insure that risks due to groundwater use
and consumption will be within EPA's acceptable risk range of 1 x
10"4 to 1 x 10"6 for carcinogens and below a hazard quotient of 1 for
noncarcinogens, which is considered protective of human health and
the environment.
The selected interim remedy for this Site is:
Alternative 2: Interim Action Pump-and-Treat System.
The estimated total cost of the remedy for the first year (design,
construction, 1-year operation) is- $1^-924,550.
10.1 Description of the Interim Remedial Action
As described in section 8.0, the Interim Remedial Action has two
components: 1) a pre-design hydrogeologic study, and 2) design,
construction and operation of an Interim Action pump-and-treat
system.
In order to expeditiously design a pump-and-treat system to achieve
the goals of this Interim Action, the hydrogeologic characteristics
of the off site area will be investigated. Hydrogeologic and other
information to be collected includes: 1) definition of the full
extent of the contaminated groundwater, 2) aquifer characteristics
including yield, transmissivity and storativity, 3) locations of
the worst-contaminated areas and/or preferred flow pathways, 4)
confirmation or determination of the vertical extent of groundwater
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contamination, 5) presence and extent of VOCs, 6) location and
nature of any other sources contributing to groundwater
contamination, and 7) data and modelling to investigate the
apparent mobility of trivalent chromium (Cr3+) in Site-area
groundwater, and the presence or absence of hexavalent chromium
(Cr 6*) .
The main component of this Interim Remedial Action is the design,
construction and operation of a pump-and-treat system that will
intercept and capture the contaminated groundwater and direct it to
a treatment facility, followed by discharge of the treated water.
The Interim Remedial Action Pump-and-Treat System, or "Interim
System" will, as a minimum, prevent, or provide control over, the
offsite migration of the contaminated groundwater.
Design of the Interim System will be based on the results of the
focused hydrogeologic study described above. Issues which must be
resolved during design include, as a minimum: 1) determination of
the number and placement of pumping wells, including determining
the optimal locations for preventing or limiting plume movement;
2) the type and degree of treatment required, including whether
treatment for VOCs is required in addition to chromium; 3) where
to discharge the treated groundwater, including identification of
what standard(s) must be achieved to meet the influent requirements
of the chosen discharge option. These issues are interrelated; for
example, the type of discharge will strongly affect the degree of
treatment required.
The method of discharge of the treated groundwater, item #3 above,
will also be decided in the design phase. Possible discharge
options include: 1) a local publicly-owned treatment works (POTW);
2) Spears Creek via an appropriate NPDES permit (National
Pollution Discharge Elimination System); or 3) another discharge
option investigated during design.-
The design for the Interim System will be reviewed and approved by
EPA. The design work will be expedited to correspond to the
limited objectives of the Interim Action; i.e., a rapid response
action to gain peripheral control of the plume. Construction and
operation of the Interim System will follow EPA's approval of the
design. The design is expected to take approximately four to five
months to complete.
Construction of the Interim System will involve installation of
approximately 6 to 8 extraction wells, or a different number of
wells according to the EPA-approved design; submersible or other
appropriate pumps, pipes/lines, and other appurtenances as
necessary to complete the system; and a treatment unit to remove or
reduce chromium. After the groundwater is treated, it will be
discharged via the discharge option selected during design. Based
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on past experience regarding the construction of the "enhanced"
pump-and-treat system on the Site (page 7), three to five months
are estimated for construction of the Interim System. This
timeline is contingent upon gaining appropriate access to the Site.
The specific treatment method to be used has not yet been
determined, but is expected to involve the use of physical and
chemical processes to remove inorganic contaminants. Typically *.
aeration, chemical reduction, and chemical precipitation are used
in combination with phase separation and filtration, to remove
metals from groundwater. Aeration of the water, normally by
sparging (bubbling) air, may be used as a pretreatment step. The
next process, chemical reduction, utilizes reducing agents to
reduce the valence state of metal contaminants (in this case,
chromium) to more easily precipitable forms. Chemical
precipitation, the next step, is achieved by adjusting the pH of
the groundwater to the optimum value for precipitation: metal
contaminants become less soluble and are precipitated out of the
water as solid particles.
Metal removal is then completed using phase separation and
filtration. Phase separation processes typically add a polymer to
the water to force metal precipitates to clump together or
flocculate. 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 through
sedimentation. 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; the liquids are usually pumped back to the head of the
treatment system. Dewatered solids are then collected and stored
onsite until disposal.
It is assumed, at present, that, the treatment of contaminated
groundwater will involve the physical methods generally described
above. In this case the solids produced by treatment will require
management as a hazardous waste, and disposal in a RCRA-regulated
landfill. Treatment and hazardous-waste management actions shall
comply with the ARARs described in the following section (Section
10.2) .
During the design of the Interim System, it may be determined that
treatment of contaminated groundwater for VOCs is warranted. If
this proves to be the case, treatment may include passage of the
groundwater through an air-, gas-, or steam-stripping unit to
remove or reduce the concentrations of VOCs. Alternatively, VOC
removal may involve using activated carbon, either for actual
removal or as a "polishing" unit. Handling of the spent carbon and
operation of the stripping unit shall comply with the ARARs
described under the appropriate subsections of Section 10.2.
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Following treatment, the groundwater shall be discharged to the
selected discharge appurtenance or location. Discharge shall
comply with all ARARs which are applicable, or relevant and
appropriate, to the particular option.
The goal of this interim remedial action is to intercept and/or
gain control over the offsite migration of contaminated
groundwater. 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 pump-and-treat system has
been Implemented, modified as necessary, and the natural
groundwater system's response monitored over time.
Because this is not the final remedy at this Site, contingency
measures, or potential system modifications to address deficiencies
of thife remedy which may be identified after some period of
operation, will not be addressed in this Interim Action ROD. The
Interim Remedial Action will be evaluated in this regard as part of
the final remedy selection process.
10.2 Applicable or Relevant and Appropriate Requirements (ARARs)
This section presents the ARARs likely to be involved in the
Interim Remedial Action. Because of the limited amount of data
currently available and the uncertainty concerning some details of
the Interim Remedial Action, the following discussion of ARARs is
necessarily general. In this manner, enough flexibility is given to
allow the specifics of the Interim Remedial Action to be developed
in the design phase.
10.2.1 Applicable Requirements. The specific ARARs applicable to
this Interim Action will depend on the treatment and discharge
options developed during the design phase. The following processes
and technologies are those expected by EPA to be used in the
Interim Remedial Action. Each is followed by the ARARs associated
with its use. Employment of other processes or technologies may be
required, however, due to development of new, unforeseen
information about the Site during the design phase of the Interim
Remedial Action.
Sludge generation (physical processes or VOC removal using
activated carbon: Groundwater remediation involving physical
processes as described above (Section 10.1) and intended to remove
inorganic contaminants (metals) from groundwater, and which produce
solid hazardous waste (sludge); or spent carbon used to remove
organic contaminants (VOCs), shall comply with all applicable
portions of the following federal and State of South Carolina regulations:
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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. In this case, the regulations would be
applicable to the sludges which will likely be produced as a
result of chemical treatment of groundwater, and to spent
carbon. Sludge from physical/chemical removal processes will,
in all likelihood, constitute hazardous waste based on its
characteristics. For the spent carbon, it is expected that
the material will fail TCLP, and thus the land disposal
restrictions in 40 CFR Part 268 will apply. However, if EP
toxicity tests are performed and the analytical results do not
exceed EP toxicity limits, then the land disposal restrictions
in 40 CFR Part 268 will not apply, even though the carbon
fails TCLP.
SC Reg1. 61-79.124, .261, .262, .263 and .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 are also applicable in exacly the same manner as
described above for the federal hazardous waste regulations.
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 offsite. These regulations are
applicable in the event hazardous wastes (sludges from
treatment) are transported off—site for treatment or disposal.
Groundwater treatment for VOCs using air stripping: If it is
determined during design that treatment of contaminated groundwater
for VOCs is warranted, and that air stripping is to be utilized,
the following ARARs will apply:
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
emissions from the air-, gas-, or steam-stripping unit if one
is used for groundwater treatment for VOCs.
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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, and only if treatment for VOCs is required.
Discharge of treated grounoVater to a surface water body: In the
event that this discharge option is accepted by EPA as the best
choice, the following ARAR shall apply.
40 CFR Part 122, 125, 129, 133 and 136, CWA Discharge Limitations
(CWA § 301), promulgated under the authority of the Clean Water
Act.
Applicable to any point discharges of wastewaters to waters of
the United States. At this Site, it is applicable to
discharge of treated waters from the groundwater treatment
system, to any surface water body.
SC Reg. 61-68, South Carolina Water Classifications and Standards,
promulgated pursuant to the Pollution Control Act, SC Code of Laws,
1976, as amended.
These regulations establish classifications for water use, and
set numerical standards for protecting state waters. SC Reg.
61-68 is also applicable to discharge of treated waters from
the groundwater treatment system, to any surface water body.
Discharge of the treated groundwater to a Publicly Owned Treatment
Works (POTW) : In the event that this-option is selected, discharge
of treated water will be accomplished in compliance with the
following ARAR:
40 CFR § 403.5, CWA Pretreatment Standards (CWA § 307), promulgated
under the authority of the Clean Water Act.
Regulates discharges of water to POTWs. This regulation would
be applicable to discharge of treated waters from the
groundwater treatment system to a local POTW.
SC Reg. 61-68, South Carolina Water Classifications and Standards,
as cited above.
These regulations establish classifications for water use, and
set numerical standards for protecting state waters. SC Reg.
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61-68 is applicable to discharge of treated waters from the
groundwater treatment system to a local POTW.
Finally, the ARAR listed below is applicable to all groundwater
remediation activities undertaken pursuant to this Interim Action
which involve monitoring or extraction wells.
SC Reg. 61-71, South Carolina Well Standards and Regulations,
promulgated under to the Safe Drinking Water Act, SC Code of Laws,
1976, as amended.
SC Reg. 61-71 establishes standards for well construction,
location and abandonment activities conducted as part of
investigation or cleanup operations, at all environmental or
hazardous waste sites in the State of South Carolina.
10.2.2 Relevant and Appropriate Requirements. The following
regulations are considered relevant and appropriate criteria
governing the groundwater remediation contemplated under this
Interim Action:
40 CFR Parts 141-143, National Primary and Secondary Drinking Water
Standards, promulgated under the authority of the Clean Water Act.
These regulations establish acceptable maximum levels of
numerous substances in public drinking water supplies, whether
publicly owned or from other sources such as groundwater.
Maximum Contaminant Levels (MCLs) and Maximum Contaminant
Level Goals (MCLGs) are specifically identified in the NCP as
remedial action objectives for ground waters that are current
or potential sources of drinking water supply (NCP 40 CFR §
300.430(a) (1) (ii) (F). Therefore, MCLs and MCLGs are relevant
and appropriate as criteria for groundwater remediation at
this Site.
SC Reg. 61-58, South Carolina Primary Drinking Water Regulations,
promulgated pursuant to the Safe Drinking Water Act, SC Code of
Laws, 1976, as amended.
These regulations are similar to the federal regulations
described above, and are relevant and appropriate as
remediation criteria for the same reasons set forth above.
10.2.3 "To Be Considered" (TBC) and Other Guidance.
The following references and regulations are designated "To Be
Considered" during the design and implementation of the Interim
Remedial Action.
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TBC criteria for groundwater remediation:
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. As described under Section 2.2, groundwater
at the Site is classified by EPA as Class IIA and by South
Carolina as Class GB groundwater, indicating its current and
potential use 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. While the Interim Action is not
intended to address the offsite ecosystem, the ER-L/ER-M
values should be considered when judging the potential impacts
of remediation efforts (particularly groundwater pumping from
wells) on the immediate environment in the offsite area.
40 CFR Part 131, Ambient Water Quality Criteria (CWA § 304),
promulgated under the authority of the Clean Water Act.
These regulations set numerical criteria for ambient water
quality based on toxicity to aquatic organisms and human
health. As with the NOAA values cited above, these
regulations should be considered when evaluating the effects
of any remediation or other activities in the offsite area.
TBC criteria for the use of air stripping to remove VOCs from
groundwater:
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, will be
considered applicable to the groundwater portion of the remedy
if treatment of groundwater for VOC removal via air-, gas- or
steam-stripping is utilized. Likewise, the NAAQS is
designated TBC only if VOCs treatment of groundwater is
undertaken.
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Interim Action Record of Decision
Townsend Saw Chain Company Site
Paqe 28
Clean Air Act, § 501 and 502, 1990 CAA Amendments, 42 U.S.C.
§ 7661 and § 7661(a).
The amendments will require that all "major sources" and
certain other sources regulated under the CAA obtain operating
permits. Although CERCLA § 121(e) exempts this remedy from
requiring such a permit, air /gas /steam 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. As with the
above-cited regulation, the 1990 CAA amendments will be
considered TBC only if groundwater treatment for VOCs is
performed.
10.2.4 Other requirements. Remedial design, especially when
conducted rapidly to achieve interim objectives such as those
outlined in this interim ROD, often includes the discovery and use
of unforeseeable but necessary requirements. Therefore, during
design of the selected interim remedy, EPA may elect to designate
further ARARs which apply, or are relevant and appropriate, to
groundwater remediation at this Site. This would be done through
a formal ROD modification process such as an Explanation of
Significant Differences (ESD) or a ROD Amendment. EPA may also
designate other ARARs which apply to this Action during design, or
in the final remedy (final ROD) for the Site.
10.3 Performance Standards
The standards defined in this section comprise the performance
standards defining successful implementation of this interim
remedy.
Performance Standard No. 1: Groundwater remediation performed
under this Interim Remedial Action shall prevent, or control, the
offsite migration of all groundwater contaminated by chromium at
levels above the applicable State of South Carolina MCL (50
micrograms (ug) per liter).
Performance Standard No. 2: Treated groundwater routed for
disposal via the selected discharge option shall meet the
applicable pretreatment standards or effluent limits, if any,
established for that particular discharge option.
11.0 STATUTORY DETERMINATIONS
Section 121(b)(l) of CERCLA, 42 U.S.C. § 9621(b)(l), states that a
selected 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
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Interim Action Record of Decision
Townsend Saw Chain Company Site
Page 29
technologies to the maximum extent practicable; and finally,
wherever feasible, employ treatment to reduce the toxicity,
mobility or volume of the contaminants. The selected interim
remedy for this Site meets the first two statutory requirements
given above, and partially fulfills the others. Since this is an
interim remedial action and not a final comprehensive remedy for
the Site, the degree to which all statutory requirements are met
cannot be assessed. The following sections discuss the degree to
which the interim remedy fulfills statutory requirements.
Protection of human health and the environment; The interim remedy
will remove or reduce current and future human health risks from
dermal contact or ingestion of contaminated groundwater. This will
be accomplished through the operation of a groundwater remediation
system which will prevent or control the offsite migration of
contaminated groundwater which could otherwise reach private water
wells. The extracted contaminated groundwater will be treated to
remove or reduce contamination. Additionally, although the Interim
Action 'is not intended to address ecological degradation, and the
presence of such effects has not yet been established, the Interim
Action is nonetheless expected to have some positive impact on the
local ecology by reducing the amount of contamination reaching
Spears Creek.
Compliance with ARARs; The interim remedy will meet the ARARs
listed in Section 10.2. of this interim ROD. The listed ARARs
apply only to groundwater remediation as described for this Interim
Action. Compliance with all ARARs which may apply to remediation
of this Site will be addressed in the final Site ROD.
Cost effectiveness; The interim remedy is cost effective in that
it will result in limiting the expansion of the area underlain by
contaminated groundwater. While the anticipated costs are large,
they could reasonably be expected to be greater if this Action were
not undertaken. Furthermore, the treatment technologies to be
considered for use are well proven and widely used.
Utilization of permanent solutions, and alternative treatment
technologies or resource recovery technologies to the maximum
extent practicable; Although this interim remedy is not the final
action for the Site, it does represent the maximum extent to which
permanent solutions and treatment can practicably be used for this
action. The treatment component of this Action will permanently
reduce contaminant concentrations in the groundwater, and is thus
considered a permanent solution to the problem of offsite migration
of contaminated groundwater. Permanence of the Interim Action, and
its long-term effectiveness, will be considered by EPA as it
develops a final remedy for the Site. In view of the present
groundwater situation and the need to move quickly to limit offsite
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Interim Action Record of Decision
Towns end Saw Chain Company Site
Page 30
groundwater movement, EPA and the State of South Carolina believe
that the selected interim remedy achieves the best possible balance
of trade-offs in terms of long-term effectiveness and permanence,
reduction of toxicity/mobility/volume, short-term effectiveness,
implementability, and cost.
Preference for treatment as a principal remedy element; Although
this Interim Action is not the final remedy for the Site, the
Interim System for groundwater remediation will fulfill the
preference for treatment as a principal element, through extraction
and treatment of contaminated groundwater.
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APPENDIX A
RESPONSIVENESS SUMMARY
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RESPONSIVENESS SUMMARY
TOWNSEND SAW CHAIN COMPANY SITE
1. Overview
The U. S. Environmental Protection Agency (EPA) held a public
comment period from August 20, 1993 to September 20, 1993, for
interested parties to comment on the preliminary Remedial
Investigation/ Feasibility Study (RI/FS) results and the Proposed
Plan for an Interim Remedial Action at the Towns end Saw Chain
Company Site in Pontiac, Richland County, South Carolina. During
this period there were no requests to extend the comment period
for an additional 30 days.
EPA held a public meeting at 7:00 p.m. on August 31, 1993, at
Pontiac Elementary School in Pontiac, South Carolina to present
the initial results of the RI/FS, to present the Proposed Plan
for the Interim Remedial Action and to receive comments and
questions from the public.
EPA proposed that an Interim Remedial Action be undertaken to
address,the offsite migration of contaminated groundwater. EPA
emphasized at this meeting that the proposed action was an
interim measure and not the final remedy for the Site. The
Interim Action consists of two parts: a short, focused
hydrogeologic study to support the design of a groundwater pump-
and-treat system, followed by expedited design and construction
of a pump-and-treat system which will, as a minimum, limit or
prevent the continued offsite movement of contaminated
groundwater toward private water well users living east of the
Site. Based on the comments received during the public comment
period, the residents and local officials in the Pontiac, South
Carolina area support the actions proposed by EPA.
This Responsiveness Summary provides a summary of citizens'
comments and concerns identified and received at the August 31,
1993 public meeting and during the public comment period, and
EPA's response to those comments and concerns. These sections
and attachments follow:
• Background of Community Involvement
• Summary of Comments Received During the Public
Comment Period and EPA's Responses
• Attachment A: Proposed ',Plan for Townsend Saw Chain
Company Superfund Site ;
• Attachment B: Public Notice of Public Comment Period
• Attachment C: Proposed Plan Public Meeting Sign In
Sheets
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• Attachment D: Official Transcript of the Proposed Plan
Public Meeting
2. Background of Comnnini'
EPA's community relations program for the Site began in December
of 1991, when EPA conducted community interviews with local
residents and officials in order to develop a community relations
plan for the Site. At that time, the main concerns expressed by
residents living in areas near the Site were as follows: (1) the
possibility of health threats to children attending Pontiac
Elementary School, which is located approximately 500 feet
northwest of the Site; and (2), concerns from persons living
near, particularly east of, the Site. Many residents were
surprised to learn that a final overall cleanup was not, in fact,
already underway, and asked why the cleanup is taking so long.
EPA personnel conducting the interviews, including the Remedial
Project Manager (RPM) and the Community Relations Coordinator
(CRC), explained the current status of work, at that time, on the
Site, why the Site was to be investigated under Superfund, and
what would occur once field work began.
During 1992 and 1993, EPA has taken steps to keep the local
community aware and informed of Site activities and findings
throughout a lengthy Remedial Investigation (RI). EPA held a
public "kickoff" meeting announcing the start of the RI on April
14, 1992. After the first phase of the RI was completed, EPA
added the Preliminary Site Characterization Summary to the
infomation repository, in Octobet 1992. During RI Phase II
groundwater sampling in the winter and spring 1992-1993, the
areal extent of groundwater contamination, in the east and
southeast directions, was found to be much larger than previously
known. Between this time and the 'August 1993 public meeting, the
RPM and CRC initiated regular and substantial telephone contact
with those landowners and residents located east of the Site.
The two main contacts were the past and current presidents of the
Woodcreek Lake Homeowners Association, which is comprised of
persons living around Woodcreek Lake. Eleven owners of land
parcels located east and south of the Site were contacted via
certified letter concerning the preliminary groundwater findings,
and requesting short-term access to their properties for
collecting samples.
To date, public attention concerning the Site has been limited.
The Site has received only infrequent coverage in the one major
newspaper published in the area. There have been occasional
requests to be added to the Site mailing list, which has been
expanded to include additional residents living in close
proximity to the Site.
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EPA issued a Proposed Plan Fact Sheet in August 1993, to present
the Interim Remedial Action to the public and receive public
comment. There were many questions from the public, primarily
concerning the possible effects to the land and groundwater in
the off site area affected by the groundwater contamination.
3. s™™"*ry of Connnents Received During the Public Comment
Period and Agency Responses
The Public Comment Period opened on August 20, 1993, and was
closed on September 20, 1993. The Public Notice which was
published in the area's local paper, The state, can be found in
Attachment B. No written comments were received during the
public comment period.
As noted above, on August 31, 1993, EPA held a public meeting to
present the Proposed Plan for the Interim Remedial Action to the
community and to receive comments. All comments received at this
public meeting are summarized below. The responses given are
essentially the same as those given at the meeting, although
certain ones have been reiterated or elaborated upon for the sake
of clarity. Part I of this section addresses those community
concerns and comments that are non-technical in nature.
Responses to specific legal and technical questions are provided
in Part II.
Part 1 - Summary and Response to Local Community Concerns
The following issues and concerns were expressed at the Interim
Action Proposed Plan Public Meeting. The majority of expressed
comments and concerns focused on the possible effects to the land
and groundwater in the offsite area affected by the groundwater
contamination.
Private Water Well and Surface Water Sampling, Woodcreek Lake
Area
(1) Several questions concerned what EPA's intentions were
regarding the lake and surrounding area. Several others
asked that EPA go ahead and sample all private water wells
around the lake.
RESPONSE: Based on the concerns raised at the meeting, the South
Carolina Department of Health and Environmental Control (SCDHEC)
decided to sample an additional 4 private wells. Since EPA
sampled four others, the result was that all eight of the full-
time residents' wells were sampled. Results from EPA and SCDHEC,
which were provided to Woodcreek Lake residents in October 1993,
indicated that no contamination from the Townsend Saw Chain
Company Site had reached any of the wells.
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(2) EPA personnel were asked if any work would be done to
address the potential for ecological damage in the offsite
area, and whether the Agency had determined if such damage
was causing, or could cause, a threat to the health of the
residents.
RESPONSE: At the meeting, EPA staff explained that an upcoming
Ecological Assessment, to be conducted by the PRP under EPA's
oversight, will show whether or not the wildlife in the offsite
area were being adversely impacted. The data available to date
do not suggest serious or large-scale ecological damage, but this
will be verified by the upcoming work.
(3) Two citizens asked if EPA would sample and analyze the lake
water, as well as conduct the planned sampling of four
private water wells.
RESPONSE: EPA will consider sampling and further work involving
the lake, depending on the outcome of the planned Ecological
Assessment. At the public meeting, the SCDHEC project manager
for the Townsend Site referred to the results of two past
samplings of the lake, once in December 1991 and the most recent
from January 1993. Both results indicated that total chromium
was not detected at 10 micrograms per liter (ug/1). These
results do not indicate a cause for concern in Woodcreek Lake.
The December 1991 results were previously presented to the public
in EPA's Fact Sheet announcing the RI/FS, in April 1992.
Origin of the Contamination
(1) One citizen asked whether the processes which led to the
groundwater problem were continuing at this time.
RESPONSE: The process which led to the groundwater
contamination, specifically, improper disposal of wastewater, has
been discontinued and no longer poses a threat. Groundwater
contamination resulted from direct discharge to the ground
surface, between 1966 and 1981, of wastewaters containing
chromium and other substances. Since 1982, Homelite Textron has
been pumping and treating groundwater to remove the contaminants,
as well as using a chemical treatment process to remove
contaminants from its process wastewater. The water, consisting
of both process water and groundwater, is treated at the plant
prior to being reinfiltrated back to the groundwater via a
sprayfield. The treated water meets the drinking water standards
for chromium, and groundwater beneath the sprayfield is monitored
by SCDHEC to insure that acceptable groundwater quality is
maintained. These methods of wastewater treatment and disposal
do not cause environmental harm.
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Repository Information
(1) A Richland County Councilwoman asked that EPA make the
materials that are available to the public at the
repository, simpler and more easily understood. She
indicated that, in her view,'the length and scientific
content of the reports would be intimidating to most people.
RESPONSE: EPA is making, agency-wide, a number of efforts to
improve public participation in the Superfund process. Such
efforts will be made for this site as well, and will include the
following actions to promote understanding and involvement by the
public. First, EPA will insure that each major report, beginning
with the RI Report which has yet to be finalized, will have a
summary section at the front that will get the main points of the
document, including the conclusions, across to the general
reader. Second, EPA staff will insure that enough reference
material is at the repository to aid the general reader. All
reports will also have an index to the acronyms used. Finally,
EPA will hold availability sessions at key points, as progress on
the FS and the Interim Remedial Action warrant. These will
provide opportunities for Agency staff to explain specific
issues, reports, analytical data, or other items which may be
confusing.
Further Work at the Site
(1) A citizen asked if EPA intends to sample groundwater or
wells on the other side (south side) of Interstate
Highway 20. .
RESPONSE: As part of Interim Remedial Action, under EPA
oversight, the PRP's consultant will complete an expedited
hydrogeologic study which will identify the boundaries of the
contaminated groundwater. If the 'data from monitor wells
suggests that the boundary is south of 1-20, groundwater sampling
will be done south of 1-20 to define the boundary.
(2) A nearby resident asked when environmental work on this Site
will be completely finished, and a "clean bill of health"
can be expected.
RESPONSE: Based on experience at other sites, EPA believes that
completely cleaning up the contaminated groundwater will take
many years of pump-and treat operations. A timeframe of
approximately 30 years is often used, but until a groundwater
system is operated for some time, it cannot be reliably predicted
how long it will take to complete the cleanup.
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Part II - Comprehensive Response to Specific Legal and Technical
Questions
EPA Notification Letters to Property Owners
(1) A citizen living near the Site asked about the meaning of an
EPA letter he received concerning groundwater beneath his
property. The letter/ as he understood it, showed chromium
present at more than 7 times the drinking water standard.
Also, he asked whether he will get any sort of final report
or notification of what EPA's determination is, about the
groundwater.
RESPONSE: Two sets of letters were mailed out in August 1993,
one concerning shallow groundwater samples collected via direct-
push technology, and a second set concerning water well samples
from a group of residences and businesses south of Interstate
Highway 20. This question concerns a letter in the first set.
EPA sta.f f explained at the meeting that the data were preliminary
in nature, and subject to error in that they may be skewed high,
due to certain weaknesses in the methodology used. Nonetheless,
the data does suggest that groundwater beneath this and other
properties may be contaminated above acceptable levels. The
hydrogeologic study, which is a part of the Interim Remedial
Action, will determine the boundaries of the contaminated
groundwater. EPA will insure that the results are made publicly
available, and also that the affected property owners are
notified directly by letter.
(2) A resident living near the Site asked about an EPA letter
she recently received, which told her that Site-related
contamination had not been detected in her water well. The
wording of the letter caused some concern and an explanation
was requested. She also asked if EPA would resample the
wells which had been previously sampled.
RESPONSE: EPA staff at the meeting explained the letter in
detail so that the meaning of the results was clarified. The
sample results indicated that no contamination from the Site had
reached her well. The language in the letter was intended to
communicate that other contaminants besides those associated with
the Townsend Site, were not analyzed for. Thus EPA cannot be
sure that some problem unrelated to the Site, such as bacteria,
nitrogen compounds from septic tanks, etc. is not affecting the
well in question. EPA may take well samples again, if the
upcoming work in the off site area indicates the need. EPA will
insure that these results are also made publicly available.
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PRP Responsibility for Providing Drinking Hater
(1) A Woodcreek Lake resident asked what responsibilities the
Potentially Responsible Parties (PRPs) have as far as
providing alternate supplies of drinking water, if the plant
is shown to be affecting private water wells.
RESPONSE: EPA will insure that the use and consumption of
groundwater contaminated at unsafe levels is prevented. EPA and
the PRPs will coordinate closely to determine how the drinking
water would be provided/ in the event that private water wells
are found to be impacted by contamination from the Site.
Groundwater Movement
(1) A citizen asked how long it takes the groundwater to move
from the Site area, down to Woodcreek Lake.
RESPONSE: It is not known at this time what the velocity of the
groundwater is, as it moves down in the direction of Spears
Creek. This is an item that will be investigated during the
upcoming hydrogeologic study. It was explained at the meeting
that the rate of movement is very slow compared to surface water
flow. Groundwater flow rates vary widely; based on other sites
in the surrounding area, the rate is probably somewhere between
100 and 400 feet per year, or 1 foot or less per day.
Performance of Pump-and-Treat System in Preventing Offsite
Migration
(1) A part-time resident on Woodcreek" Lake" asked' how sure EPA is
that the spread of the plume of contaminated groundwater can
be contained, and the boundaries of it maintained.
RESPONSE: EPA's experience at other sites indicates that a pump-
and-treat system, if designed correctly based on an accurate
understanding of Site hydrogeology, can successfully capture all
of the affected groundwater needing treatment, and prevent
migration. The technologies for hydraulic capture of groundwater
using extraction wells, and for treatment by a variety of
processes, are both well proven at numerous sites in the United
States and overseas.
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Attachment A
Proposed Plan for Townsend Saw Chain Superfund Site
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UNITED STATES ENVmONMENTAI, PROTECTION AGENCY
INTERIM ACTION PROPOSED PLAN FACT SHEET
TOWNSEND SAW CHAIN SUPERFUND SITE
Pontiac, Richland County, South Carolina August 1993
INTRODUCTION
The United States Environmental Protection Agency, Region IV (EPA) has prepared this Fact Sheet to
propose an Interim Remedial Action to address offsite groundwater contamination at the Townsend Saw
Chain Superfund Site (the Site) in Pontiac, Richland County, South Carolina. EPA is the lead Agency for
remedial activities at the Site, and, in cooperation with the South Carolina Department of Health and
Environmental Control (SCDHEC), is currently investigating the Site. Words appearing in bold print are
defined in the glossary which begins on page 10 of this publication.
The purpose of the Interim Action outlined in this Proposed Plan is to minimize or prevent the continued
offsite movement of contaminated groundwater. To accomplish this, the Action includes the design,
construction and operation of a groundwater pump-and-treat system which will capture the groundwater
at the offsite periphery of the contaminated groundwater. The groundwater will then be pumped through
a treatment system prior to discharge. Initiation of this Interim Action, prior to completion of the Remedial
Investigation/Feasibility Study (RI/FS), will cause work to begin now on an expanded groundwater
cleanup operation, which will supplement those groundwater cleanup operations currently underway.
THIS PROPOSED PLAN:
1. Presents a summary of Site background and the findings of the Rf to date;
2. Describes EPA's initial evaluation of available alternatives for offsite groundwater cleanup, and
provides a summary analysis explaining why EPA is proposing the Action; and
3. Solicits public review and comment on this course of action.
PUBLIC MEETING
To Discuss the Interim Action and the
Status of the Remedial Investigation/Feasibility Study for the
TOWNSEND SAW CHAIN SUPERFUND SITE
August 31,1993 - 7:00 PJVL
PONTIAC ELEMENTARY SCHOOL
500 Spears Creek Church Road
Pontiac, South Carolina
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Since 1982, SCDHEC has continued to direct Textron to proceed with an investigation and cleanup
program for groundwater. In 1982, a groundwater treatment system was installed, consisting of five
extraction (pumping) wells, chemical treatment tanks, and a spray or irrigation field for disposal of the
treated water. Groundwater is extracted, chemically treated to acceptable standards, and then discharged
to the spray field. Performance of the system and conditions at the spray field are monitored by SCDHEC.
In 1987, SCDHEC identified problems in the treatment system's design and performance. To address
those deficiencies, a subsequent 1988 modification to the 1982 Court Order directed Homelite to further
investigate and define the extent of groundwater contamination, and to investigate Site hydrogeology as
necessary to modify the system's design. A report with design revisions was submitted to SCDHEC in
1990, and following SCDHEC review, again in December 1991. The redesign effort has been completed
and operation of the expanded pump-and-treat system will begin in February or March 1994.
Between 1985 and 1988, SCDHEC and EPA took the necessary steps to list the Site on the National
Priorities List (NPL), which places it in the Superfund program. During this period, investigations by
SCDHEC revealed above-background concentrations of lead, cadmium, arsenic, cyanide, nickel, and four
VOCs in groundwater at the site. Chromium, lead, cadmium and arsenic were present above background
levels in sediments within the waste pond area, and a stream water sample taken just across Spears Creek
Church Road north of the site contained chromium and four VOCs. Based on these results, the Site was
then ranked by EPA in 1987 using the Hazard Ranking System (HRS), which evaluates the potential for
public exposure to site contamination. Because of the potential for migration of groundwater contaminants
ofisrte, and the large number of people in the surrounding area served by water wells, the Site was
assigned a high HRS score and was proposed for listing on the NPL in June 1988. The Site was finalized
on the NPL'in February 1990.
EPA and Homelite signed an agreement in October 1991 under which Homelite agreed to conduct a
Remedial Investigation/Feasibility Study (RI/FS). Dictaphone Corporation was named as a Potentially
Responsible Party (PRP) by EPA when the Agency notified both Homelite and Dictaphone that an RI/FS
was required for the Site. Dictaphone has not participated in the RI/FS to date. As a PRP, Homelite may
pursue legal action to force Dictaphone to share the cost for the RI/FS and subsequent remediation.
Additionally, EPA retains the right to pursue legal action against Dictaphone.
An Rl "ktekoff" public meeting was held by EPA at Pontiac Elementary School on April 22, 1992. Field
work began in early May 1992. The initial ("Phase I") work included a monitor well upgrade/abandonment
program to insure the reliability of the onsite and offsrte monitor wells, and an initial sampling of Site soils
and the monitor wells. The preliminary results of these sampling activities were presented in the
"Preliminary Site Characterization Summary," submitted by the PRP's contractor to EPA in September,
1992. This document is part of the Administrative Record tor the Site, and is available for review by the
public at the Information repository (see page 10).
Based on these initial results, Homelite proposed further investigation of site groundwater and soils. This
effort was designated "Phase II" and began in October 1992. Combined Phase I and II activities have
included the installation and addition of 15 new monitoring wells to the previous 38-well network. Sampling
has included collection and laboratory analysis of 73 groundwater samples, 17 surface water (stream)
samples, 19 stream sediment samples, 35 soil samples, 10 septic tank sludge samples, 6 septic tank
wastewater samples, and 10 air samples. Additionally, between January and July 1993, three rounds of
offsite shallow groundwater sampling were performed using direct-push technology (DPT). A total of 49
offsite groundwater samples were collected, 37 of them by DPT. After a delay during which access to
surrounding properties was obtained, offsite groundwater sampling via DPT was continued during June and
July 1993. After discussions with Homelite in late June 1993, EPA decided to move forward with an Interim
Action at the Site.
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LECCTD
»*••"" *•-* Groundvater Plume Boundary
« * * Probable Limit of Plume
J J I Plume Boundary Uncertain
SCALE: 1 INCH - 1300 TOET
FIGURE 2 OFFSJTE GROUNDWATER CONTAMINATION
The unnamed tributary across Spears Creek Church Road from the Site exhibits contamination from the
Site. The tributary is recharged almost entirely by groundwater, and water and sediment samples from it
show clear impact from chromium-contaminated groundwater.
SUMMARY OF SITE RISKS
At this time, the draft Baseline Risk Assessment is being revised by EPA's risk assessment contractor.
However, the groundwater sampling results clearly indicate that chromium-contaminated groundwater is
migrating offsite in the direction of private water wells, located to the southeast and east of the Site. As
noted above, chromium levels in groundwater are many times above the drinking water standard. The
main contaminant of concern is chromium,, although several VOCs have been detected at levels above
MCLs in offsite wells.
While the contamination may be limited to the shallow aquifer, nearby wells could still possibly be impacted
at levels above the MCL, unless- measures are taken to intercept and/or control the offsite movement of
the contaminant plume. This future potentialrisk to human health will be reduced or eliminated by the
proposed Interim Action.
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Construction and operation of the Interim System will immediately follow EPA's approval of the design. The
Interim System will consist of between 6 and 8 wells, submersible or other appropriate pumps, pipes/lines,
a treatment unit to remove or reduce chromium, and other appurtenances as necessary to complete the
system. After the groundwater is treated, it will be discharged to either 1) a local publicly-owned treatment
works (POTW), 2) Spears Creek via an appropriate NPDES permit (National Pollution Discharge
Elimination System), or 3) another, to-be-determined disposal option. As stated above, the discharge
option to be used will be determined in the design phase: Three to five months will be needed to construct
the Interim System.
Design and Construction Cost (includes Design Cost
and Treatment System Equipment $1,610,000
Annual Operation and Maintenance (O&M) Costs: 280,050
Disposal Costs - Treated Groundwater 34.500
Total Costs $1,924,550
Time to Begin Pump-and-Treat Operations = 10-13 months
O&M costs after first year will depreciate at an estimated 7% per year. These preliminary cost estimates
are based on the limited information available at present.
EVALUATION OF THE ALTERNATIVES
EPA uses nine criteria to evaluate the alternatives which could be selected. The first seven are used to
evaluate the alternatives based on environmental protection, cost, and engineering feasibility issues. The
preferred alternative is then further evaluated based on the final two criteria. To be selected by EPA, an
alternative must meet the first two "threshold" criteria.
This evaluation is more limited in scope than would be the case if the Interim Action was to be the final
remedy at this Site. As noted above, following completion of the FS, EPA will issue a Proposed Plan for
a final remedial action (remedy) for the Site. The final remedy will reconsider the planning and design for
the groundwater pump-and-treat system proposed in this Interim Action, and may propose system additions,
modifications, or other actions, to accomplish remediation of all contaminated groundwater originating from
this Site. This Interim Action will be consistent with the final remedy.
EPA's rationale for selecting this action is presented below, in relation to each of the nine criteria. The site-
specific rationale is indicated by the" D" symbol. , .
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.
D The No Action Alternative would not be protective of human hearth and the environment, and
therefore is not considered further in the evaluation below. It is not protective because the
potential threats to private water well users located east and southeast of the Site will not be
reduced or eliminated.
The Interim Action Pump-and-Treat System will achieve protection of human health and the
environment through interception or control of the offsite groundwater plume's movement, thereby
-------
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 Rl, FS, and Proposed Plan, the
State concurs with, opposes, or has no comments on the alternative proposed by EPA as the selected
alternative (or "remedy").
D The State of South Carolina concurs with this Interim Action.
9. Community Acceptance addresses whether the public agrees with EPA's selection of the
alternative. Community acceptance of this Proposed Plan will be evaluated based on comments received
during the upcoming public meeting and during the public comment period.
PUBLIC/COMMUNITY REVIEW AND COMMENT
EPA will hold a Public Meeting on Tuesday, August 31,1993, to discuss the Interim Action. Officials from
EPA and SCDHEC will present a summary of the RI/FS progress to date, the remedial alternatives
considered for the present situation, and why EPA is proposing the Action. The public is encouraged to
attend this meeting.
EPA is also conducting a 30-day public comment period, from Friday, August 20, 1993 to Monday,
September 20,1993, in order to receive public input and comments on the Interim Action Proposed Plan.
Written comments on the RI/FS at this Site or other issues related to Site cleanup are welcomed and are
an important part of the decision-making process. Please send all comments to:
Ralph O. Howard, Jr., Remedial Project Manager
U.S. EPA Region IV, North Superfund Remedial Branch
345 Courtland Street, NE
Atlanta, GA 30365
404/347-7791. or 1-800-435-9233
EPA will review and consider all comments received during the comment period and the public meeting
before reaching a final decision on taking this Interim Action at the Townsend Saw Chain Site. The
Agency's final decision will be issued in the Interim Action Record of Decision, a legal document which
formally sets forth EPA's decision summary in selecting the Interim Action. A Responsiveness Summary,
which contains all of the public comments received and EPA's responses to them, is part of the Record
of Decision (ROD). An Interim ROD is expected to be-corhpleted for the Site in late September 1993.
For more information on community relations in the Superfund process or at this Site, please contact:
Cynthia Peurifoy, Community Relations Coordinator
U.S. EPA Region IV
North Superfund Remedial Branch
345 Courtland Street, NE
Atlanta, GA 30365
404/347-7791, or 1-800-435-9233
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Chromium - A lustrous, hard, steel-gray metallic element commonly found in the earth's crust. Chromium
is used in the production of stainless steel and for hardening other metals. Chromium solutions are used
in electrolytic plating operations to provide a hard, durable coating for metal parts.
Direct-Push Technology (PPT) - Refers generally to one of several methods of sampling groundwater.
Direct-push methods involve the use of hydraulic force to push hollow steel rods down into the ground until
the water table is encountered. Groundwater may then be sampled, or the rods pushed further to sample
deeper portions of the aquifer or other aquifers. Advantages of direct-push sampling include: speed, the
fact that no soil cuttings are produced, and that there is no disturbance to the ground surface at the
sampling location.
Feasibility Study (FS) - See Remedial Investigation/Feasibility Study.
Groundwater - Water found beneath the earth's surface that fills pores between materials such as sand,
soil, or gravel. In aquifers, groundwater occurs in sufficient quantities which can be used for drinking water,
irrigation and other purposes.
Hazard Ranking System (HRS) - A scoring system used by EPA and the state to evaluate relative risks
to public health and the environment from releases or threatened releases of hazardous substances. An
. HRS score is calculated based on actual or potential release of hazardous substances through the air,
soils, surface water or groundwater. This score is a primary factor used to decide if a hazardous waste
site should be placed on the National Priorities List.
Information Repository - A file containing current information, technical reports, and reference documents
regarding a Superfund site. The information repository is usually located in a public building that is
convenient for local residents - such as a public school, city hall, or library.
Interim Remedial Action - A remedial action that is intended to address immediate potential threats which
could become worse unless action is taken immediately. An interim action is not an emergency action; any
situation that is an immediate threat to the public health and safety is addressed by EPA or the State as
an "emergency response action." Such actions usually include removal of hazardous wastes and/or
contaminated soil; thus they are referred to as "removals".
Maximum Contaminant Level (MCL) - The maximum permissible level of a contaminant in water that is
consumed as drinking water. These levels have been determined by EPA to implement the Safe Drinking
Water Act of 1974, as amended in 1986.
Milligrams per Liter (mg/I) - Metric system units commonly used to express low concentrations of
contaminants, in terms of how much solid material, by weight, is dissolved in a given volume of water. One
gram weighs about the same as a postage stamp. One filer is about 3 3/4 gallons.
Monitoring Wells - Specially constructed water wells installed at specific locations on or near hazardous
waste sites. Groundwater samples for laboratory analysis, and water table measurements, are taken from
such wells. Monitoring wells thus provide valuable data concerning the direction of groundwater flow and
the types and amounts of contaminants present.
National Priorities List (NPL) - EPA's list of the most serious uncontrolled or abandoned hazardous waste
sites identified for possible long-term remedial response using money from the Trust Fund. The list is
based primarily on the score a site receives on the Hazard Ranking System.
11
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Safe Drinking Water Act (SDWA) - Federal law passed in 1974 to ensure water supply systems serving
the public would meet minimum standards for the protection of public health. The law was designed to
achieve uniform safety and quality of drinking water in the United States by identifying contaminants and
establishing maximum acceptable levels (see "MCL" above).
Superfund - The common name used for the Comprehensive Environmental Response, Compensation,
and Liability Act of 1980 (see also "CERCLA" above), as amended by the Superfund Amendments and
Reauthorization Act (SARA) of 1986.
Volatile Organic Compound (VOC) - An organic (carbon-containing) compound that evaporates
(volatilizes) readily at room temperature. Many common industrial contaminants at environmental sites,
such as trichtoroethylene, tetrachloroethylene, and 1,1-dichtoroethylene, are VOCs.
REQUEST TO BE PLACED ON THE
TOWNSEND SAW CHAIN COMPANY SUPERFUND SITE MAILING LIST
If you would like your name and address placed on the mailing list for the Townsend Saw Chain Company
Superfund Site, please complete this form and return to: Cynthia Peurifoy, Community Relations
Coordinator, EPA-Region IV, North Superfund Remedial Branch, 345 Courtland Street, Atlanta, Georgia
30365, or call 1-800-435-9233.
NAME!
ADDRESS:
TELEPHONE:
AFFII IATION-
13
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REGION IV
INTERIM ACTION PROPOSED PLAN
PUBLIC INFORMATION MEETING
for the
TOWNSEND SAW CHAIN
SUPERFUND SITE
Pontiac Elementary School
500 Spears Creek Church Road
Pontiac, South Carolina
Tuesday, August 31,1993, 7:00 PJVL
-------
AGENDA
Interim Action Proposed Plan
Public Information Meeting
Townsend Chain Saw Superfund Site
August 31,1993
WELCOME & INTRODUCTIONS
SUPERFUND OVERVIEW
COMMUNITY RELATIONS
SITE HISTORY
PROPOSED INTERIM ACTION
WHAT HAPPENS NEXT?
QUESTIONS, ANSWERS AND COMMENTS
-------
NOTES
-------
Attachment B
Public Notice of Public Comment Period
-------
12A
Friday, August 20. 1993
NA1
Howard scientists to study bones
of colonial African-Americans
The Washington Pott
WASHINGTON
In life they were scorned as un-
worthy chattel. When they died, they
were buried In a desolate field outside
colonial New York City.
But early next month, the skeletal
•mm itecutnt: axey part of the Akkadi-
an empire, one of humanity's earliest
experiments at nationhood. The em-
pire, named for the Sargon of Akkad,
Services Administration stumbled
upon the graveyard as tt was clearing
the site for construction of a (276
million federal office tower. The
rights to excavate and study the booe*
were turned over to archaeologists at
K»Him «S flW*K«U*ll__ahlt.^3^BBB*B*BBBBBBBBBBBBBBBBBl'
L^Ii-^«np^J^SPA^TiSlffliyff^..^......l
CAIX: 254-4982
at THE BTATB FAKMKRS MARKET •
We now accept MC and VU«.
Black troops to get
Civil War marker
SUPER BACK TC
U.S. ENVIRONMENTAL PROTECTION A
INVITES PUBLIC COMMENT ON T
ENCY
E
PONTIAC, HIGHLAND COUNTY, SOUTH CAROLINA
The U.S. Environmental Protection Agency Is Inviting public
comment on the Interim Action Proposed Plan for the Townsend
Saw Chain Superfund Site. This Interim action Is being pro-
posed to address offsite groandwater contamination. Offslte
groundwater data obtalneo during the Remedial Investigation of
the site has indicated that the area affected Is larger tnanpre-
vlously believed. The proposed pump-and-treat system wm in-
tercept the migrating contaminated groundwater and prevent or
minimize Its movement offsite.
Two alternatives were considered in proposing this action:
Alternative 1 : No Action .. „
Alternative 2: interim Groundwater Pump-and-Treat System
EPA Is proposing implementation of Alternative 2. The scope of
the proposed action Includes two components: 1} expedited
design and construction of a groundwater pump-and-treat sys-
tem to prevent or minimize continued offsite migration of con-
taminated groundwater, and 2) a focused hydrogeotogte study
to support Die design, to be conducted prior to the design effort.
The agency Is holding a 30 day comment period, which begins
on Fnclay, August 20, 1993, and ends on Monday, September
20. 1993. Written comments, which must be postmarked no
later than September 20, 1993, should be sent to:
Mr. Ralph Howard. Remedial Prelect Manager
North Superfund Remedial Branch .
U.S. Environmental Protection Agency, Region IV
345 Courtland Street, N.E.
Atlanta, GA 303& • .
EPA has scheduled a public meeting to present the proposed
plan and to discuss the status of the Remedial Investiga-
tion/Feasibility Study. The meeting also provides the public an
opportunity to submit oral and written comments on the pro-
posed plan and other alternatives. The meeting will be:
Date: Tuesday, August 31, 1993
Time: 7:00 p.m.
Place: Pontiac Elementary School
500 Spears Creek Church Road
Pontiac, South Carolina
Copies of the proposed plan, as weii as the administrative re-
cord for the site, are availa ........
repository, which Isthe R
l Branch. 7490 Park
For additional Information, or to be added to EPA's mailing list
tor the site, contact Cynthia B. Peurifoy. .Community Relations
Coordinator, at 1-800-435-9233. v .
SVGA
COLOR
MONITOR
INCLUDED!
Red Hot Color TV Special!
25" Color TV/Monitor with
On-Screen Display
i%maar
Universal remote, sleep llmer, remote
Control ol piciore settings. SMZSOZ
CITADEL MALL, Charleston
INLET SQUARE MALL, Mur
'OLUMBfA MALL, Columbi;
OLUMBIANA MALL, Colur
NORTHWOODSMALL,Cha
MALL, Myrtle
|HANESMALL,Winston-Salei
JACKSONVILLE MALL, Jack
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-------
Attachment C
Proposed Plan Public Meeting Sign In Sheets
-------
TUWNSEND SAW CHIAN SUPERFUND SITE
INTERIM PROPOSED ACTION PUBLIC MEETING
AUGUST 31, 1993, PONTIAC, SC
SIGN-IN SHEET
NAMB/ADDRHSS/rcLETIIONB NUMBHR
RnPRJOSIJNnNO
ADD TO
MAILING UST7
HOW DID
you HOAR or
. C. f.
Y2Lc> T
iwtytf
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-------
TOWNSEND SAW CHIAN SUPERFUND SITE
INTERIM PROPOSED ACTION PUBLIC MEETING
AUGUST 31, 1993, PONTIAC, SC
SIGN-IN SHEET
NAME/ADDRKSS/TELmiONH NUMBER
RITPRBSINnNG
ADD TO
MAJUNOUSn
(PU2ASB dincx)
now om
YOU HEAR OP
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-------
TOWNSEND SAW CHIAN SUPERFUND SITE
INTERIM PROPOSED ACTION PUBLIC MEETING
AUGUST 31, 1993, PONTIAC, SC
SIGN-IN SHEET
NAMn/ADDRUSS/TCUjnrONH NUMBER
RTPRESUNnNG
ADD TO
MAIIJNO LJCT7
(ptnAsn amcx)
HOW DID
YOU HEAR OP
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-------
TUWNSliNJJ SAW CHiAN JJU^KKFUND SITE
INTERIM PROPOSED ACTION PUBLIC MEETING
AUGUST 31, 1993, PONTIAC, SC
SIGN-IN SHEET
NAMn/ADDRBSS/TUUmiONB NUMBER
ADD TO
MAIIJNO usn
HOW DID
YOU HEAR OF
u
'M. /)
-------
TUWNSEND SAW CH1AN SUPERFUND SHE
INTERIM PROPOSED ACTION PUBLIC MEETING
AUGUST 31, 1993, PONTIAC, SC
SIGN-IN SHEET
NAMn/ADDRUSS/IBUJPirONB NUMBER
REPRESENTING
ADD TO
MAIIJNOUCT?
(PLEASBaiECX)
HOW DID
YOU HEAR OP
Tins MEETING?
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-------
TOWNSEND SAW CHIAN SUPERFUND SITE
INTERIM PROPOSED ACTION PUBLIC MEETING
AUGUST 31, 1993, PONTIAC, SC
SIGN-IN SHEET
NAMC/ADDWJSS/TGLnniONB NUMBER
RnPRESHNTTNG
ADD TO
MAIUNOUST?
(puiAsn amac)
HOW DID
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-------
TOWNSEND SAW CHIAN SUPERFUND SITE
INTERIM PROPOSED ACTION PUBLIC MEETING
AUGUST 31, 1993, PONTIAC, SC
SIGN-IN SHEET
NAMB/ADDRHSS/TELEPHONB NUMBER
ADD TO
MAJIJNOUST7
(PLRASB dinCK)
HOW DID
YOU ICEAK OF
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-------
TUWNSKNIJ SAW CHiAN SUPERFUND SITE
INTERIM PROPOSED ACTION PUBLIC MEETING
AUGUST 31:, 1993, PONTIAC, SC
SIGN-fN SHEET
NAKCG/ADDRIKS/TEUintONB NUMBER
RnPRESKMTNO
ADD TO
MAIUNO USn
(PLRASH CHT-CK)
HOW DID
YOU HEAR OP
TinSMramNG?
-------
Attachment D
Official Transcript of the Proposed Plan Public Meeting
-------
ORIGINAL
UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION IV
INTERIM ACTION PROPOSED PLAN
PUBLIC INFORMATION MEETING
for the
TOWNSEND SAW CHAIN SUPERFUND SITE
Pontiac Elementary School
500 Spears Creek Church Road
Pontiac, South Carolina
Tuesday/ August 31, 1993
7:11 p.m. - 8:50 p.m.
CREEL COURT REPORTING
1110 Gregg Street / Columbia, SC 29201
(803) 252-3445
-------
TOWNSEND SAW CHAIN SUPERFUND SITE z
1 INTERIM ACTION PROPOSED PLAN
PUBLIC INFORMATION MEETING
2 TOWNSEND SAW CHAIN SUPERFUND SITE
AUGUST 31, 1993
3
4 WELCOME AND INTRODUCTIONS - Ralph Howard
5 Good evening. I'd like to welcome everyone to
6 tonight's meeting. We appreciate your presence here.
7 The agenda for tonight is on the screen behind me and,
8 I apologize, I hope everyone can read, particularly the
9 bottom, when we go through the items you see listed.
10 There is a sign in sheet in the back and I hope everyone
11 signed in.
12 Let me start by introducing some of the participants
13 from EPA and the South Carolina DHEC staff who are here
14 tonight. My name is Ralph Howard; I'm the Remedial
15 Project Manager for the EPA on this site. The South
16 Carolina section chief, my boss, Jan Rogers, is here to
17 my left. Seated next to him is Seth Bruckner. Seth is
18 the assigned attorney from the Office of Regional Counsel
19 within EPA Region IV. On my right is Cynthia Peurifoy.
20 Cynthia is the Community Relations Coordinator. She's
21 assigned to our group, South Carolina, also.
22 Also here tonight is personnel from South Carolina
23 DHEC. They have worked with us, in conjunction with us
24 on the site. Mr. Keith Lindler is on the front row here.
25 Also, Chuck Gorman is here. Butch Swygert is here this
CREEL COURT REPORTING
1110 Gregg Street / Columbia, SC 29201
(803) 252-3445
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1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
TOWNSEND SAW CHAIN SUPERFUNP SITE
evening, and also, Yanquing Mo, also on the front row,
and Tom Knight is here.
We also have officials here from Homelite Textron,
that are associated with the site, the PRP that's under
agreement to perform the work at the site. Mr. Tom
Griswold is here. Sloan Robinson is here. Let's see,
Mandy Ferrer is here from the plant. And one other
gentleman, who's name escapes me at the moment ...
ROBERT BRAYLEY: Robert Brayley
I can't say that.
ROBERT BRAYLEY: That's okay.
So, anyway, that's our personnel.
SUPERFUNP OVERVIEW - Ralph Howard.
The main purpose of our meeting tonight is to talk
about the Interim Action the EPA is proposing here at the
Townsend Saw Chain site. The purpose-of the meeting here
tonight is community relations, and I'm going to ask
Cynthia to say a little bit about community relations in
just a moment.
The highlight on this slide didn't come out as well
as I would have liked, but I wanted to point out the
steps of the Superfund process and how we got where we
are. Many of you attended the meeting we had last year
in April at the start of the Remedial Investigation.
CREEL COURT REPORTING
1110 Gregg Street / Columbia, SC 29201
(803) 252-3445
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TOWNSEND SAW CHAIN SUPERFUKD SITE *
1 When I say RI/FS, that's Remedial
2 Investigation/Feasibility Study. I'm going to have to
3 stay away from the acronyms here. That started last year
4 in May, the field work started. We had our meeting in
5 late April.
6 We are still in the Remedial Investigation phase of
7 work here. But, in Superfund, there is the prerogative,
8 the possibility of taking an Interim Action rather than
9 the final cleanup action on a site, and that's what we're
10 doing here tonight. We're proposing to step ahead of the
11 process a little bit, reach a decision based on facts
12 that are uncovered during the investigation. The facts
13 that led us to this, we're going to talk about in just
14 a moment and they concern groundwater.
15 We had the Potentially Responsible Party contractor
16 prepare a document that serves as a Feasibility Study.
17 It's a short, focused Feasibility Study, you could say.
18 And, based on that, we then propose an action, take
19 public comments on a proposed plan, which is what we're
20 presenting to you tonight, and then we write a Record of
21 Decision on that action, depending on public comment,
22 depending on a number of other factors that we'll go into
23 later, as to how we select the action.
24 in this case, it's an Interim Record, meaning that
25 it's not the final action of this site. There will be
CREEL COURT REPORTING
1110 Gregg Street / Columbia, SC 29201
(803) 252-3445
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TOWNSEND SAW CHAIN SUPERFUND SITE 3
1 another Record of Decision later that will close down,
2 if you will, the investigation phase of EPA's work here
3 and move into one final, you could say, overall site
4 cleanup. This Interim Action will be looked at at that
5 time again to make sure that it' s doing what it' s
6 supposed to and it's effective.
7 Most of you are familiar with the site. This is
8 just a map to, if you are aware of where it's located -
9 the intersection of 1-20 and Spears Creek Church Road,
10 just down the road from us by some five or six hundred
11 feet.
12 I'd like to briefly run through the site history.
13 But before I do that, I'm moving ahead of my agenda, I
14 want to ask Cynthia to come up and say a few words about
15 community relations, which is after all the point of our
16 meeting tonight. Cynthia.
17
18 COMMUNITY RELATIONS - Cynthia Peurifoy
19 Thank you, Ralph. Good evening, everybody. I would
20 like to welcome you also and thank YOU for coming out to
21 our meeting, and to basically cover a few points about
22 our community relations program. We are here tonight
23 because we're in the middle of a public comment period
24 on the Interim Action, which Ralph is going to be going
25 through with you in just a little bit.
CREEL COURT REPORTING
1110 Gregg Street / Columbia, SC 29201
(803) 252-3445
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TOWNSEND SAW CHAIN SUPERFUND SITE
1 I would like to point your attention to our site
2 information repository, which is at the Richland County
3 Library on Parklane Road. All the information that we've
4 gathered thus far on the site as well as a lot of
5 information on the Superfund process and our community
6 relations plan, information on public involvement, it's
7 all there for your review so please take some time when
8 ' you can and go by and take a look at that information.
9 The public comment period ends September 30 ... 20,
10 I'm sorry. If you have some comments that you don't get
11 to us tonight, I have some postage paid envelopes in the
12 back. Feel free to pick up one and mail it in to us.
13 There is a provision for an extension for an additional
14 30 days, if you so desire. If you feel you need you more
15 time to review the information or get in your comments,
16 please let us know in time.
17 I want to mention a few things about our ongoing
18 community relations activities. I'm sure some of you got
19 our Fact Sheets in the mail or have talked with us over
20 the period of time that we've been involved in the site.
21 I'd like to encourage you to call us at any time. We
22 have an 800 number that's on the Fact Sheets; they're
23 also on our business cards in the back. I would also
24 like to encourage you to give us your feedback, to let
25 us know if there's some additional information you'd like
CREEL COURT REPORTING
1110 Gregg Street / Columbia, SC 29201
(803) 252-3445
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TOWNSEKD SAW CHAIN SUPERFUND SITE7~
1 for us to review or if you have any suggestions on things
2 that you'd like for us to do, feel free.
3 When we start this meeting, I'd like to ask that if
4 you have some comments or questions, to please stand up
5 and identify yourself. If you represent a particular
6 group, also identify that group. We do have a reporter
7 here who's going to be trying to get everything we say,
8 so if you see her make a motion that she's not picking
9 up what you're saying, please clarify that or make sure
10 that she understands what you're saying. Thanks a lot.
11
12 SITE HISTORY - Ralph Howard
13 Thanks Cynthia. I want to emphasize again, please
14 make your name known to us so that we can have it
15 recorded for purposes of documenting the public input
16 into the decision.
17 I would like to briefly run through some history
18 about the site. Most of you are maybe somewhat familiar
19 with this. The site history really.dates back to 1966.
20 The owner at that time was Dictaphone Corporation. From
21 1972 forward, the owner was at that time Towns end Saw
22 Chain. Later, it was bought by Textron Corporation -
23 Sabre Textron and later Homelite Textron. Homelite
24 Textron currently owns the facility.
25 I won't read all this to you. The highlights are
CREEL COURT REPORTING
1110 Gregg Street / Columbia, SC 29201
(803) 252-3445
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TOWNSEND SAW CHAIN SUPERFUND SITE °
1 that the company did, in response to DHEC activities,
2 install a pump-and-treat system for cleaning up
3 groundwater in 1982. That system is currently in
4 operation. DHEC and EPA worked together during the mid
5 '80's to take the steps needed to list the site in the
6 Superfund program, primarily because of the large number
7 of people in the area that were served by private water
8 wells.
9 The site was proposed for listing on the National
10 Priorities List, which is a list of the nation's most
11 s.erious abandoned .. . not always abandoned, but hazardous
12 waste sites. The listing was made final in 1990.
13 There have been phases of activity, numerous phases,
14 by Homelite Textron concerning the site, under South
15 Carolina DHEC oversight and at their direction, since
16 1982, culminating in ... well, still ongoing, but in 1988
17 ... I guess as you saw on the previous slide, 1987, there
18 were deficiencies found-with the extraction system that
19 I mentioned is still pumping.. There was a redesign
20 effort and improvement effort that has recently completed
21 ... was recently completed. And, as you see here, that
22 was 1991, when the ... late 1991, the plans went in to
23 DHEC. They've recently been approved, things have been
24 worked out, and that system is set to begin pumping early
25 next year, I believe in March.
CREEL COURT REPORTING
1110 Gregg Street / Columbia, SC 29201
(803) 252-3445
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TOWNSEND SAW CHAIN SUPERFUND SITE y
1 And then the last two items have to do with the
2 Remedial Investigation. As I mentioned, we began the
3 work in May of 1993, the fieldwork. The agreement was
4 signed in August of 1991, work plan development and so
5 forth, and the fieldwork began in 1992, and brings us to
6 this point in 1993. We've had a two phase Remedial
7 Investigation, of which we'll talk about a portion
8 tonight. We'll talk mainly about groundwater tonight.
9 I want to use this slide to briefly set the stage.
10 The figure you see is a diagram of the plant itself. It
11 shows some of the study areas that have been looked at
12 for the Remedial Investigation. The crosshatched areas
13 at the top represent the former waste ponds or water
14 ponds that is the origin of the groundwater problem on
15 the site. In the period between 1966 and 1981, waste
16 liquids were disposed of in that area by direct discharge
17 to the ground, and that's the origin of the groundwater
18 problem. But this map is just meant to give you an
19 overview of where things are onsite.
20 The Remedial Investigation report is being prepared
21 now. There's not too many significant things to talk
22 about other than groundwater. We had air sampling done
23 as part of the Remedial Investigation. At this point,
24 the air sampling does not appear to be a problem or a
25 threat. We also found two small areas of soil
CREEL COURT REPORTING
1110 Gregg Street / Columbia, SC 29201
(803) 252-3445
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TOWNSEND SAW CHAIN SUPERFUND SITE
1 contamination that will have to be dealt with in the
2 Record of Decision, but those are not of particular note
3 or concern. They're not a risk outside the plant area..
4 Before I leave this, I want to point out the ...
5 this tributary, this unnamed tributary that is about 500
6 feet from the site, across Spears Creek Church Road.
7 It's fed by a spring. Approximately where I have my
8 pointer, sitting there, was at the time of the beginning
9 of the RI, the known limit of the groundwater
10 contamination in the uppermost unit; and by that I mean
11 closest to the ground surface. This shallow groundwater
12 is what I'm referring to and roughly in the area that I'm
13 pointing ... you can't see the mark. It's not going to
14 show. Approximately where my pointer is. This is just
15 to set the stage.
16 The main finding of the Remedial Investigation thus
17 far has been that the extent of groundwater contamination
18 in the offsite direction, and by that I mean eastward
19 from the facility, is greatef than we previously
20 believed, greater than the data would have indicated.
21 i want to point out several things about this
22 figure. This figure is also in the Fact Sheet that many
23 of you have, but I want to make sure that the items on
24 here are clear in their meaning. The boundaries that you
25 . see indicated represent our best estimate at this point
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1 of the extent of groundwater contamination. Everywhere
2 that you see the little dark points and so forth on this
3 diagram represents a sampling point, and I'm going to
4 talk about the sampling points and the data in just a
5 moment, but this is to give you an overall idea.
6 The facility is here, and you can see the different
7 ponds and so forth. Woodcreek Lake is over here, and the
8 various ponds in the area. This is the tributary I
9 referred to a moment ago, and this is Spears Creek.
10 There's also a scale on this figure to give you an idea.
11 There's several things about this figure that I want to
12 make clear.
13 All the sampling points, or almost all the sampling
14 points that you see indicated here represent points where
15 we collected a groundwater sample using what we refer to
16 in the Fact Sheet as direct-push technology. Made
17 simple, that represents a point where a special device
18 pushes a rod down into the ground to reach the
19 groundwater, and then you sample it at that point.
20 Now, these sampling points are all that we have at
21 the current time, and that sampling method, the DPT -
22 Direct Push Technology - sampling method was used because
23 it's fast and it allows a lot of data to be gathered
24 rapidly, and it's a good way to get a handle on a large
25 area in a hurry. It is preliminary data, and by that I
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1 mean that this data needs to be confirmed in the Interim
2 Action, which I'm going to describe to you tonight what
3 that action is. But I think I should point -out that the
4 data are valid but they do need to be confirmed by more
5 sampling and they need to be confirmed by sampling from
6 monitoring wells rather than direct-push technology
7 sampling.
8
9 PROPOSED INTERIM ACTION - Ralph Howard
10 The Interim Action we are proposing tonight is
11 intended to intercept the groundwater movement offsite
12 to the east and to the southeast, on a figure you just
13 saw. To do that, the Interim Action consists ... well,
14 the purpose is stated here on this line.
15 The components of our Interim Action are to conduct
16 a short, very focused study in the area that we believe
17 may be affected and determine those characteristics we
18 need to do the next component, which I'll get to in a
19 moment. But a short, focused study has to be a component
20 of this action.
21 There are various issues ... the list of issues you
22 see here will make a little more sense in a moment. But
23 what we're proposing is in fact a pump-and-treat system
24 that will, as I said, intercept or control migration of
25 the groundwater offsite. And the issues that have got
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1 to be settled based on that study that I'm talking about
2 are those listed that you see here: the numbers and
3 locations of the wells; where they should best be placed;
4 where the groundwater contamination is precisely -meaning
5 boundaries and meaning concentrations; and the type of
6 treatment, whether it's only for the main contaminant
7 that is associated with the site, chromium, or whether
8 it's from something else in addition to that.
9 The second component is the Interim Action treatment
10 system itself. This is a groundwater pump-and-treat
11' system that would be similar, but probably larger, to the
12 current system that's in operation. As I mentioned, the
13 current system that's in operation is to be expanded.
14 But this would be larger than that and out in front of
15 that, and I'll come back to the figure in a moment,
16 explain that.
17 The system, as you might expect, will require wells,
18 pumps, pipelines and so forth, to pipe the water for
19 treatment, control equipment and treatment equipment to
20 actually do the treatment of groundwater, to treat it to
21 acceptable standards for groundwater.
22 The cleanup or the Interim Action has to be
23 consistent with the final action, that I mentioned will
24 come later. There will be a Final Record of Decision for
25 the site that will be looking at everything about the
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site rather than ... all facets of the site rather than
just groundwater. That at this point is expected next
spring, but this is an Interim Action to get out ahead
of that, to begin work on this system now, to get work
started now. It's a proactive step to get us going on
these issues which will have to be settled. And, as it
says, it will allow the overall cleanup to begin sooner
than it would otherwise, because the type of work we need
to do is not Remedial Investigation/Feasibility Study
type work. It's work that is based on the decision to
go ahead and pump-and-treat.
Here's some more specific facts about the Interim
Action. These are approximate time frames, but these are
our objectives as to how to accomplish the Interim
Action. The first part would be the focused study, find
out what we need to know about how best to attack the
problem out there, and also to verify precisely where the
boundaries are and precisely where the levels of
contamination are. This may result in verifying
boundaries that are different than those that you saw on
the map previously. We're not sure which way that's
going to go; that's got to be determined. And you see
here an approximate overall time frame of ten to thirteen
months, with three months for the study, four to five
months for a design, for an expedited design, and three
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to five to actually construct what the design calls for.
There are substantial costs associated with this
that will be borne by Homelite Textron. These estimates
of cost are very preliminary. They're based on some
assumptions, the details of which are in the document I
mentioned that is the short Feasibility Study, and that
is available at the information repository that Cynthia
mentioned. It's titled "Technical Memorandum on Interim
Remedial Action," and that document is at the Northeast
Richland Library.
Now that I have at least briefly gone over what it
is we have in mind, I want to hit a couple of more points
on this map to get some points across. As I mentioned,
one of the tasks to be performed in the focused study is
to make sure where the boundaries are, and, as I
mentioned, at this point the data is preliminary. It
needs to be verified from samples from monitoring wells
as to precise levels. " But at this time we think the
levels will still be above the drinking water standard,
which is why we are proceeding with the action rather
than waiting.
As you may have noticed also on the Fact Sheet, the
boundary that is shown on the other side of Spears Creek,
we believe that to be a probable boundary. We believe
that the contamination is not going beyond that point in
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1 the area where Spears Creek bounds the area on the east.
2 And the reason we say that is because we do have shallow
3 groundwater samples on that side there that are below
4 detection level. The other boundary, the boundary to the
5 southeast that is near Interstate 20, we're less sure of
6 that boundary.
7 There was a precautionary sampling done of water
8 wells, private water wells on the south side of
9 Interstate 20. Seven private wells were sampled by
10 Aquaterra, the consultant for Homelite Textron, and those
11 results were negative; meaning that there was no chromium
12 or volatile organics detected, below detection limits in
13 those samples. That was done this spring, and the
14 results were mailed out recently.
15 Also, the other point I wanted to make, which I was
16 trying to remember, was that as a precaution, EPA has
17 decided to go ahead and sample four private residence
18 wells that are near Woodcreek Lake. I really haven't
19 emphasized, but I should, that the potential risk for
20 water well users in the area of in the direction of plume
21 movement, which would be towards Woodcreek lake and
22 possibly down southward towards 1-20, that's the main
23 reason or overriding rationale for our proposed action,
24 because there is a potential threat, or there could be,
25 to water well users, and we want to take a proactive step
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here to get out in front of that groundwater plume, and
we want to do it the best way that will work, and that's
the reason for the short study; the short study instead
of just rushing out there right now.
Our knowledge of the entire offsite area that you
see is quite limited at this time, and that's got to be
taken care of. The EPA has elected to go ahead and
sample four private residences, which I'll indicate —
it doesn't look like it's going to show. Two homes on
the east side of Woodcreek Lake and two homes on the
south side here, near 1-20. Our rationale is that those
are the nearest to where we think the plume may be, and
we don't expect to find anything. It is precautionary
but it needs to be done.
WHAT HAPPENS NEXT - Ralph Howard
The further work that is going to occur here
involves the completion of the Remedial Investigation
itself and the Feasibility Study. The Feasibility Study
will look at what the best options are for cleanup not
only of groundwater but of other things that were found
at the site. I mentioned two areas of soil contamination
that are pretty small in size involving any risk. They
will be taken care of. There are other issues that need
to be wrapped up. We expect to do that at the end of the
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1 year. Next we will follow up with a post plan, similar
2 to this one, at which point we will talk about the site
3 as a whole, including groundwater, and that Record of
4 Decision ... I'm sorry, that proposed plan will let you
5 know that we're also going to look back at this Interim
6 Action to see how far it's come and is it on course.
7 The Final Record of Decision will tie this all
8 together, if you will, into what we can think of as one
9 overall site remedy for groundwater and for any other
10 contamination that's going to be taken care of; and we
11 expect to do that next spring. March may be a little
12 optimistic for the Record of Decision, but that's the
13 objective.
14
15 QUESTIONS. ANSWERS AND COMMENTS
16 RALPH HOWARD: I expect there are a lot of questions. This was
17 short and brief, but I hope we've at least given you an
18 idea of what we have in mind, and we'd like to entertain
19 questions at this time. And, as I mentioned, please let
20 us know your name so we can have it recorded.
21 FRANK MANN: I'm Frank Mann, a property owner on Woodcreek Lake.
22 You've been talking about contamination of shallow
23 aquifers and contamination of tributaries near the creek.
24 Are you planning to test the lake water at Woodcreek?
25 RALPH HOWARD: One thing I did not mention in talking about the
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1 other issues in the Remedial Investigation was that the
2 tributary itself is being evaluated for ecological
3 reasons, mainly. The data we have from the RI would
4 indicate that there may be some risk to the creatures
5 that live in and along the tributary.
6 We have done some sampling to date on the tributary,
7 and the sampling that we have to this point would not
8 lead us to sample the lake right away, based on what
9 we're seeing. The reason I say that is because the lake
10 ... for the lake to be impacted, the water that feeds the
11' lake would have to show contamination.
12 So what we've done is, we've started up close to the
13 plant, worked in the eastward direction, moving towards
14 Woodcreek Lake. And, in doing that, what we're seeing
15 in the way of chromium in the sediment is not of a nature
16 or a degree that would lead us to say the lake is
17 affected.
18 We've also ... South Carolina DHEC has taken
19 periodic samples from the bridge down ... near your home,
20 I believe, down over the creek, and the samples from the
21 creek and from sediment in the creek are low or below
22 detection limits. And that, when I say below detection
23 limits, in this case the detection limit is 10 parts per
24 billion, with the drinking water standard of 100. So we
25 don't see the contamination in the water leading into the
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1 creek ... leading into the lake, I'm sorry. Does that
2 make sense?
3 FRANK MANN: Yes, sir.
4 WALTER TYLER: I'm Walter Tyler. We have some property on the
5 south side of 1-20 — (inaudible) ... One sample was
6 taken from 47 feet from ground service, and it was .670
7 milligrams per liter, which is seven times above the
8 acceptable level.
9 RALPH HOWARD: It's above the drinking water standard, that's
10 correct. This point needed to come up, and it should,
11 ' and I want to make sure this is clear; I would like to
12 make it clear.
13 The sampling method we do, we use the direct-push
14 that I mentioned earlier, recover samples from the
15 groundwater in such a way that the sample is oftentimes
16 full of fine material like clay, like mud. Because of
17 the way the sample is recovered, when that sample is
18 analyzed there is potential, you know, sometimes for the
19 readings to be higher than what is actually present. At
20 this time, we don't know whether the sample, for example,
21 from your property is necessarily a whole lot higher than
22 what's there, or it could be a whole lot higher than what
23 is there.
24 The way to answer that question is already underway.
25 The way to answer the question is to get a better sample,
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1 and to do that you must take a sample from a properly
2 installed monitor well that actually represents for you
3 what the aquifer is like. So we haven't waited to do
4 that. Those wells have actually been installed.
5 There are ten new wells in the large area that I
6 showed, that was defined by that boundary. Those wells
7 are in varying depths into the ground. That sample will
8 be scheduled next week. I'm not real sure how soon we'll
9 have those in our hands, but that data could be two or
10 three months coming. And the reason for that is because
11 ' those samples are absolutely crucial because they will
12 answer your question. They will tell us whether or not
13 the level is real or whether we're seeing exaggerated
14 results in these direct-push samples.
15 I'm not sure I remember exactly where the Tyler
16 Construction property is, but there is a well on the
17 other side of 1-20 that is one of the ones to be sampled.
18 So the property owners to the south of 1-20 are, because
19 of that location and because we have a well near there,
20 we'll get a good answer of that and those results are
21 going to be made public. Those will be publicly
22 available.
23 BILL THOMPSON: I'm Bill Thompson. Just a superfluous question.
24 What is the velocity from here to Woodcreek lake of the
25 groundwater? How long does it take for groundwater from
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here to get to Woodcreek lake? It's a mile and a half.
RALPH HOWARD: At this point, we can't say with certainty what
that velocity is. In fact, you know, to be quite honest,
there are a number of things we've got to become experts
on, as it were, about the groundwater just in that area.
And it makes sense in a way because up until now all the
site work has been directed at areas close to the site.
And, for that reason, when you go out into a new area,
which this area is, the hydrogeology, the flow rates, the
water depths and so forth can be different; maybe not a
lot different but enough to affect how fast it flows and
so forth. If what we have out there is real, it may be
that it's down there. But that doesn't tell us how fast.
No real good answer for that one.
LEONE CASTLES: I'm Leone Castles, and we've got a house at
Woodcreek. It looks like we're going to be one of the
ones checked.
RALPH HOWARD: Well, I think you're next to Mr. Combs or Ms.
Dart.
LEONE CASTLES: Yes, I am next to Peggy Dart.
RALPH HOWARD: I think we're going to get Mr. Combs' well and
Peggy Dart's well.
LEONE CASTLES: Okay. When are you thinking that this work will
be completed? You know, you're talking to people here
and we are all concerned, and more and more. And this
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1 has been going on 25 years and it is something now that
2 is really raising attention. What is your due date for
3 finishing and giving us a clean bill of health? I mean,
4 you know, we don't understand all this.
5 RALPH HOWARD: I understand, yes, ma'am. That's a very good
6 question. To answer it honestly and truthfully,
7 groundwater cleanup is going to require some years here
8 because, to clean it up, as you can tell from listening
9 to us, it's got to be pumped out of the ground and
10 treated. That means that we're stuck with water well
11 ' technology, essentially, to remove the groundwater.
12 So if you ... even if you take a lot of wells and
13 put them in the area that you want to clean up and pump
14 all the water out, there's limitations to how much water
15 you could treat and ... and I'm not trying to dodge your
16 question. I'm trying to explain why it takes so long.
17 How much to treat, to which degree, do you want it
18 very clean or just barely clean enough - issues like that
19 mean that a lot of money will be spent and a lot of time
20 will pass to get the groundwater out and treat it. In
21 this case, it's hard to say specifically. Groundwater
22 cleanup in general ...
23 LEON CASTLES: What's your guess on time?
24 RALPH HOWARD: ... tends to go over years. At most Superfund
25 sites, we use an estimate like 30 years. It could be
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1 shorter in years, but there's no way to say yet if it's
2 going to be shorter ...
3 LEON CASTLES: Well now, there's one other ... (Inaudible) ...
4 JAN ROGERS: Just to avoid the worst possible twist you could
5 put on it, final cleanup is what Ralph is talking about.
6 As far as looking at the total investigation, he made you
7 an optimistic perspective of in another six months to a
8 year we could have an RI that deals with the overall
9 problem.
10 Going to the other gentleman's question about
11 sediment, we know there's a potential sediment problem.
12 This groundwater migrates down and surfaces to those
13 drainage systems to some extent, and can be contributing
14 to the lake. We don't think it's doing it via the water
15 path. We think it's doing it via transporting sediments.
16 But then there are factors in the food chain related to
17 the drainage system and possibly the head waters of the
18 lake and any number of-other issues.
19 The reason we're going forward with this part as an
20 Interim Action is, we know there's a groundwater plume
21 there. We always talk in terms of groundwater movement.
22 Nobody knows until they do some sophisticated studies of
23 an immediate area to determine just how fast groundwater
24 moves. But it's not fast in relative terms. It' s not
25 like it goes from the plant down to the lake in two
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weeks. It took a lot of years to get there.
Initially there were some estimates on what
groundwater was expected to be ... groundwater movement
would be expected to be in that area. The investigation
started out from the plant, and we found out it was much
farther down to some level of detectable contamination
than we would have thought. The plume, we would have
thought would have been tighter packed back towards the
plant itself.
There really aren't a whole lot of options dealing
with groundwater contamination. You put in water well
technology, might call in sophisticated technology, until
we come up with something better, especially for these
kinds of contaminants, and you would extract the
solubilized portion that is moving with the groundwater.
That way you can at least control it. You also would go
back and would at least explore, is there a way to go
back into this whole entire area that' s been impacted and
clean the entire aquifer with additional wells.
None of that will take place quickly as far as the
cleanup. The implementation could take place in a hurry,
in a relatively short time compared to 30 years. But the
reality of it is, the purap-and-treat will go on for a
period of time.
What we're looking at is, what are you the public
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exposed to? You're either directly exposed to it or
you're consuming it. We're concerned down towards the
lake and other areas across the interstate as far as the
consumption.
Can we get interceptor wells in there and impact the
flow of this material before it gets to your wells and
keep those wells from ever becoming contaminated? We
feel like at least if we do this action more quickly, we
have a chance of impacting that particular movement.
You're still going to have deal with the 30 years
or whatever it takes to clean up the aquifer. There's
a lot of technology that needs to be developed yet in
order to totally restore the aquifer, but nobody's
drinking that aquifer. We know where it's contaminated
and we'll make sure that nobody does drink it.
The other aspect is, if your well becomes
contaminated there are alternatives, in that you can go
to the public water .supply and other ways of dealing with
a well that's become contaminated. We don't want to get
into what if scenarios, but we need to take away any
exposure that we can identify that could be adverse to
your health.
So far, we've found the plume much further out than
we thought it would be. We want to refine the leading
edge of the parts of the plume, but we also want to start
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1 some activities on proactively going out and trying to
2 intercept and keep it from going any further with water
3 well technology.
4 That water, when it's recovered, has to be treated
5 and discharged. There aren't a whole lot of options out
6 there and, the other reason we wanted to start this early
7 was, one of those options includes the possibility of
8 treatment or discharge after treatment. And there's no
9 line that exists for that right now; that will take some
10 time, even if we could pump the water tomorrow and treat
11 ' it.
12 So there's some other things that will have to fall
13 into place and be considered during the design phase.
14 But we want to get everybody on even ground as far as
15 where we're going.
16 If we put out an Interim Record of Decision, we have
17 made the decision that we need to proactively impact this
18 groundwater plume, which means we're going to have to
19 pump it up and we're also going to have to look at all
20 of the alternatives for discharge that we'll deal with.
21 And we feel like working with the company, because
22 they've been very cooperative to date, we will deal with
23 exploring those options and what becomes the most
24 feasible option for the ultimate discharge of the water
25 after it's recovered and treated and has to be disposed
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1 Of.
2 LEON CASTLES: Is there any responsibility from the companies
3 involved to help secure city water, the lines and so
4 forth to go into this area that is contaminated?
5 RALPH HOWARD: Basically, we don't know what kind of
6 alternatives we're going to be looking at in terms of
7 whether or not those wells are contaminated. Liability-
8 wise, the company has been very cooperative and they will
9 be willing to implement any sort of alternatives that we
10 deem are necessary to prevent the public, you, from
11 • drinking contaminated water.
12 SETH BRUCKNER: Historically, if we show an adverse impact to
13 somebody's well, we certainly have to evaluate does it
14 create a health threat. If it creates a health threat,
15 there are different measures for dealing with that. Some
16 of it's due to toxicology, but it's very conservative
17 estimates that are going to be ... if we feel there's a
18 heath threat, and there.probably could be, we'll look at
19 it from a Superfund perspective of providing alternate
20 water supply.
21 It's just an option as to whether the PRP wants to
22 deal with that or not, and I'm not suggesting it will go
23 either way. If it doesn't occur by parties that are
24 participating with it, we will pursue it on our own.
25 On an abandoned site where we have no parties, we would
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1 pursue all this work plus any money dealing with the
2 issues, and then deal with the recovery of the money.
3 in this case, we have a very active PRP who's been very
4 cooperative in working all along with us. And I don't
5 want to get into speculation of what if's, but I think
6 it's very easily dealt with should it become a problem.
7 ROBERT SESSIONS: I hope you can hear me; I'm hoarse.
8 RALPH HOWARD: Can you tell me your name?
9 ROBERT SESSIONS: My name is Robert Sessions.
10 RALPH HOWARD: Robert ...
11 ' ROBERT SESSIONS: Sessions.
12 RALPH HOWARD: Sessions?
13 ROBERT SESSIONS: Right. I'm a property owner adjacent to the
14 school.
15 RALPH HOWARD: Right.
16 ROBERT SESSIONS: My question is about that tributary down there
17 being contaminated. What effect does that have on the
18 animals?
19 RALPH HOWARD: Now, which tributary ...
20 ROBERT SESSIONS: Directly in front of the school, right across
21 the street. I want to know what effect that will have
22 on the animals and what effect would the animals then
23 have on human consumption, because we do hunt and fish
24 and so does our children?
25 RALPH HOWARD: Right. As far as the fish, at this time we don't
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1 think fish are a concern, and I'll explain why. We have
2 water samples from the stream, from the little tributary,
3 and we have those at about, I think it's seven locations,
4 moving downward to the . .. with the most farthest
5 downstream closest to Spears Creek being right at Spears
6 Creek. So we've got seven scattered on that tributary
7 and there is contamination in the stream water at levels
8 that are above a drinking water standard, which, you
9 know, is for humans.
10 As to whether that level is above a level that would
11. hurt animals and creatures and so forth is really not
12 clear at this time, and that's because we have guidance
13 that, where if it's a certain level, it is to trigger our
14 attention to look into it.
15 Now, if you just want to say did it trigger
16 anybody's attention, it does but it's not what we
17 consider a high level. It's just a level ... if you're
18 talking about levels, it could be like between 100 and
19 160 parts per billion; the drinking standard being 100.
20 We have samples of the water, as I mentioned, all the way
21 down to Spears Creek, and the ones near Spears Creek, the
22 one at Spears Creek in fact, is below the drinking water
23 standard as far as people are concerned.
24 But the better answer is, that has to be looked into
J5 and that's one of the things we're doing in the
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1 Feasibility Study. What we're doing, the company is
2 going to do, is an ecological assessment; and what that
3 involves, in short form, is a taking of stream water.
4 They take stream sediment and they take a group of
5 animals, probably fish, maybe a plant and maybe an
6 invertebrate, like a worm or a small animal, and they
7 will expose the animals to the water and the sediment.
8 They're looking for toxicity, they're looking to see if
9 there is an effect. And at this point, there's just no
10 way to know whether there is an effect. We have to find
11 ' that out and we designed this eco assessment, ecological
12 assessment with the one objective of giving us a thumbs
13 up or a thumbs down - either there is toxicity or there
14 is not. But, at this point, there's just no way to
15 speculate. Every stream is different, the hardness of
16 the water, the mineral content of the water, the ... and
17 other physical things about the stream water will control
1.8 that and the sediment will control that also. So we
19 just don't know yet whether there is.
20 But the reason that we're not concerned ...
21 obviously, we're concerned. The reason we don't think
22 the lake is being impacted yet is because we don't see
23 the chromium reaching Woodcreek Lake through the stream
24 water. And if it was in the stream water in a sizeable
25 quantity, that would tell us we've got to go look at that
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1 because there's a way to get it into the lake. But
2 without seeing a way into the lake, we don't have any
3 grounds to think that it' s in the lake or even
4 accumulated in the lake.
5 Does that make sense? So that' s why we haven' t
6 proposed more on the lake itself as yet, but it's a ...
7 you know, it's something that could happen, depending on
8 what we find.
9 ROBERT SESSIONS: My concern is the inhabitants of the lake, be
10 it deer, rabbit, squirrel, coon. People hunt in those
11 areas and if we consume these animals, is there a threat
12 to humans?
13 JAN ROGERS: That's what the eco study is going to prove out.
14 But I guess what Ralph's trying to say is, we've seen a
15 little impact on the sediment of the drainage system.
16 It's not extremely high levels, but we now have to go
17 back and assure that it's not entering the food chain and
18 working its way up or.creating its own toxic effect.
19 The other thing, and I don't off the top of my head
20 remember chromium completely on the toxicological
21 perspective, but I don't believe it's material bio-
22 accumulates. Organics, a lot of organic pollution tends
23 to go into the body, be stored in the fatty tissue of the
24 body and tend to accumulate. Chromium and the other
25 metals tend to have either direct effects or be passed
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1 through the body, if I'm remembering right. I don't
2 think it tends to accumulate a lot, and that's a concern.
3 We do have a concern on the small aquatic organisms.
4 It' s conceivable they could pick up some from the
5 sediments and then work its way up the food chain. But
6 it think it' s more a concern over immediate toxicity and
7 impact on the ecosystem than it would be accumulation in
8 the bio ... bio-accumulation in the food chain, working
9 its way up. The concentrations we're looking at, I
10 highly doubt that you would see anything in squirrels,
11 • rabbits, those sorts of things., of any concern.
12 JIM CANTEY: I'm Jim Cantey. My family owns some property on
13 the far side of the lake from the plant on Woodcreek
14 Lake, and I'm also the president this year of the
15 homeowners' association. I would like to thank the EPA
16 for being involved in this thing.
17 As Ms. Castles said, it's been going on for some
18 time now. All the people here, I think I speak for all
19 of them, are concerned about the safety factors involved
20 - what's going to happen to our drinking water and, as
21 Mr. Sessions said, what's going to happen to the animals,
22 the fish we eat, our children swimming in the lake, and
23 this kind of thing.
24 it seems to me the practical thing to do, in looking
25 at the map there, not only Woodcreek Lake is affected but
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1 there are also other lakes and other streams there, that
2 perhaps in the interest of calming us, the public, down
3 somewhat is if you could take some samples directly from
4 the lake, perhaps take some fish samples.
5 why not check more than just four wells? You already
6 have them in place there. I don't know what the cost of
7 drilling a sample well is. I don't know what the cost
8 of a push type well is, but I would think it would be a
9 lot more than just taking a sample, and I know I'm
10 oversimplifying the fact.
11 • I know fish samples are taken from lakes frequently.
12 I know water samples are taken from lakes and from
13 private wells and this kind of thing. It seems to me
14 like a practical thing to do and to assimilate this
15 information would be just to take more than just a few
16 samples.
17 I realize that you have sediment problems and many
18 other type problems involved in it as well. But at the
19 same point, I think that if you told me my well probably
20 is safe and if you told me we've checked your well and
21 it's safe to drink from it, I'd feel a lot more
22 comfortable with the latter. Or if you told me it's all
23 right for my children to swim in the lake or it's all
24 right for me to fish out of the lake, whatever, it would
25 make me feel a lot better and would make a lot of us feel
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1 a lot better if you would do that.
2 Perhaps that is an oversimplification of it, but I
3 think that that's something you ought to ... from a cost
4 standpoint, I don't think it would be prohibitive and,
5 also, it would make us feel a lot better.
6 RALPH HOWARD: The reason we haven't proposed sampling more
7 wells than the ones we've proposed is because we ...
8 there's several reasons. For one thing, you do have to
9 move outward from a site, go to the areas that are
10 closest to where you think the problem may be. And the
11 • geology of the area is such and the nature of the aquifer
12 is such, with sand being a primary component is such that
13 we don't see a possibility for contamination to go around
14 the wells that we're going to sample and show up
15 somewhere else. That's why we haven't proposed sampling,
16 you know, just to all the wells.
17 There is the issue of, we have no cause to think
18 that there's anything, else out there. But if you bring
19 in a whole lot of samples at one time, you bring in the
20 possibility of other things that are completely unrelated
21 to this Superfund site.
22 Even in the area that' s of f site where the tributary
23 is, that you saw outlined on a diagram, there are
24 scattered, small places out there with trash ponds. And
25 I should have noted this earlier, but there is the
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1 possibility that some of those are contributing, or could
2 be, to the groundwater problem that we see out there.
3 There is the issue of bringing in those things.
4 I guess the best reason is that it really is
5 precautionary at this point. We don't really know with
6 certainty, you could say, that the extent that you saw
7 on my diagram reaches as far as it does. We have got
8 wells in place now that will answer that question, of
9 whether or not it is that far out.
10 That knowledge could change things. It could lead
11 us to go back to the area of the owners of Woodcreek Lake
12 and sample it again; that or something untoward in the
13 samples. But geologically it just ... we don't see a way
14 to miss it in those private water wells.
15 JIM CANTEY: What about the fish in there?
16 RALPH HOWARD: The possibility of a sample from the lake might
17 be a good idea. That's been done periodically at least
18 in the past and we would consider that.
19 Yes?
20 YANQUING MO: I'd like to ... (inaudible) ...
21 RALPH HOWARD: You've got to speak up, we can't hear you.
22 YANQUING MO: DHEC has taken some samples from the lake. The
23 latest sample was taken in January of '93, and on the
24 previous samples and the '93 sample showed no
25 contamination of the lake. So a sampling of surface
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1 water in the lake ... (inaudible) ... chromium, there's
2 been no detection in it.
3 So right now we have some information that shows
4 that the lake hasn't been impacted yet. And I think in
5 the ecological assessment, Aguaterra has some proposal
6 to take some sediment and surface water from the creek
7 to see if there are any impact there and what is the
8 impact to the food chain or other life forms there. So
9 those will provide information to what kind of ecological
10 impact has been happening by the contamination on the
11 • site. So I hope this will help.
12 JIM CANTEY: Thank you.
13 JAN ROGERS: From a swimming perspective, we're not seeing it
14 in any significant concentration in the water. It
15 shouldn't be piling up in the lake and it's not a
16 material that's readily absorbed through the skin. So
17 that's, you know, that's very remote as a concern for an
18 exposure route. . .
19 I think the biggest concern right now is, the stream
20 is a relatively low flow, especially the upper branch.
21 Spears Creek actually has a pretty decent flow and
22 probably wouldn't expect to be able to find much chromium
23 in that.
24 Our theory is that chromium has slowly migrated
25 through the groundwater and, at various points, it
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1 outcrops into that drainage system. But realizing
2 groundwater moves very slowly compared to any flowing
3 stream, there's a tremendous dilution effect there. We
4 want to go ahead and start these measures to contain it.
5 And, in theory, there is some potential for impact of
6 what we call the ecosystem for sediments in the various
7 components of that drainage system.
8 More importantly, we want to intercept it and make
9 sure it doesn't impact somebody's well at the leading
10 edge for right now, and that's what the Interim Action
11 ' is about. The ecosystem study will go forward and deal
12 with just what is the impact along that drainage system.
13 We can detect it/ but we can detect extremely low levels.
14 Then the question becomes, how do you interpret the
15 amount that we've detected and to what degree is it going
16 to cause a problem? Well, the amounts of concentrations
17 you're talking about, it's very likely that you'll have
18 a minimal impact right -now on the drainage system. You
19 may have accumulated some sediments in the lake, but even
20 that's kind of questionable because you're ... you're not
21 seeing a lot of ... you do have natural -filtration
22 through there. You're getting some sedimentation moving
23 down there, but it also gets knocked down before it gets
24 to the lake.
25 The ecosystem hopefully will tie up some of those
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1 issues. And again/ it's material that generally ...
2 chromium is kind of a strange beast in it' s toxicological
3 issues. But, you know, we want to do this Interim Action
4 while we complete the studies to deal with those other
5 issues.
6 From the well perspective, that gets into a lot of
7 other issues. When we go out and sample wells, we're
8 running analyses on contaminants related to our site.
9 We're probably not going to run any analysis related to
10 bacteria, and I assume you've got septic tanks out there.
11 Health departments generally deal with that on a local
12 level and they try to make sure that septic tanks are far
13 enough away from the well that they don't short circuit.
14 But in ray emergency response days, I found a lot of them
15 that didn't. And usually there was a big train
16 derailment that was accused of causing the shutdown of
17 the well, but it was shut down by the local health
18 department because of bacteria. It just happened to be
19 unfortunate timing that they looked at the well while we
20 were looking at the derailment, and the two, to the
21 public coincided, therefore they were related.
22 We tend to look at the leading edge. We've got
23 several homes there that we don't really think should
24 be impacted, but we want to sample those wells to see if
25 there's any direct exposure of them while we deal with
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the rest of this delineation of the aquifer.
Most of the data we're gathering is technical data
related to draw down tests and other things to see where
you place recovery wells, how far do they have to be
spaced, to impact the leading edge. We've got to be able
to draw any contaminated water coming down and draining
into those wells before it passes through that area, and
that requires some technical issues on better defining
the nature of the soils and the water yields and those
sorts of things.
WALTER ROBERTS: I'm Walter Roberts. I've got a house down at
* • •
RALPH HOWARD: Could you say your name one more time?
WALTER ROBERTS: Roberts.
RALPH HOWARD: Roberts?
WALTER ROBERTS: Walter Roberts. I hope this doesn't sound like
it's addictive speculation, and it calls for speculation
on your part. But I don't think anything had been done
between 1966 and 1981, when this could have been done but
was not done. But since 1981, do you think that the
efforts that have been made have contributed to the
continuing contamination or do you think they have been
adequately keeping the continuing contamination from
occurring?
RALPH HOWARD: Well, the first thing that should be kept in
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1 mind, and it's very important, is that the contamination
2 is, as far as its origin is pre-1982. By that I mean
3 that at that point the company was looked into by DHEC.
4 They were fined, I think. They did put in the extraction
5 system to pump-and-treat groundwater. There has been a
6 lot of groundwater removed, treated and discharged back
7 to the aquifer.
8 As you may be aware, they have a spray field where
9 water infiltrates back down. And it's important to keep
10 in mind that the treated water that goes through there
11 is below the drinking water standard. It's at the South
12 Carolina drinking water standard, which is 50 parts per
13 billion; ours is 100 parts per billion. But there have
14 been efforts, as you say, since 1982 to deal with the
15 problem.
16 You know, when you say was it sufficient or not, to
17 my knowledge, to my belief, it was sufficient as we've
18 progressed in knowledge - about where the contamination
19 was. I didn't highlight this when I put ray diagram up
20 that showed the facility outline, and I tried to draw
21 where the groundwater plume was known to exist when we
22 started the Remedial Investigation, but that is an
23 interesting case in point. The company had about ... at
24 the time of the RI, some 50 wells on the site and there
25 are still 35 or so wells on the site; some of the older
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wells were abandoned.
But the point I'm leading to is that the well
network defined where the plume was, or so we all
believed, and there's no easy answer as to why the extent
appears to be beyond what we had as a closed off, you
could say, monitor well network. Typically ... so
anyway, what I was leading to is, the effort that's been
put against the problem has been proportional to the size
of the problem and so forth. The deficiencies that were
found by DHEC in 1987 and early '88, when they got to
working again, were to the best of everybody's knowledge
going to correct the deficiency.
HALTER ROBERTS: You mean there was a state of the art sort of
thing at that time?
RALPH HOWARD: There was some state of the art, and there is
some imprecision in puraping-and-treating the groundwater,
and there' s no way to get around that. You can be
conservative in your .assumptions, as we are on the
regulatory side. But even so, it is possible for the
geology to fool you, as it were, and your data will tell
you, your information will tell you that you're getting
it all but, in fact, you're not.
I wouldn't want to characterize the whole thing as
just a complete ... we were completely blind-sided, or
the company was completely blind-sided. But I think it
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is fair to say that in large measure all the work to that
point would have led to the conclusion we had, which was
that we had the boundary of it. And I think it should
be kept in mind also that when you're pumping the water
out from a certain area, that is an area that you've
influenced and caused to fall into, you could think of,
fall into your well, your pumping well. And what that
does is, that puts a stop point in the ground. It puts
a hydraulic barrier, is what we refer to it as.
So there was ... there's some imprecision and some
questions about where the extent of that barrier was, but
it' s ... you know, I think it' s fair to say that it' s not
as if the effort was known to be short.
WALTER ROBERTS: To the best of your knowledge now, what is in
place then is adequate to prevent further contamination.
Is that what you're saying?
RALPH HOWARD: No, definitely not.
JAN ROGERS: No. What we're proposing should be. A couple of
other variables you have to take into consideration.
Superfund was passed in 1980. Nobody bothered to have
any ... or Congress didn't have any legislation dealing
with multimedia issues up until that point. We had air
laws, we had surface water laws. We had virtually no
groundwater laws. The legislation at the federal level
started with Superfund, which said hazardous waste like
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1 is out here, we have to look at both surface soils,
2 surface waters, groundwater, and subsurface soils as an
3 entirety as far as dealing with the problem. That only
4 started with legislation. The program started slowly.
5 The states typically are behind us on their
6 legislation, following would be the federal legislation
7 to delegate and implement at the state level. So there' s
8 been a bit of legislation growth from the early '80's.
9 A lot of authority hasn't existed to do much of anything
10 until well into the '80's.
11 ' The other variable is the technology. You didn't
12 have any targets across the street. You had an
13 estimation that there was really slow movement, somewhat
14 identified and contained in that immediate area. There's
15 nobody using the water over there until you go way down
16 stream, and most people don't expect contamination across
17 other streams. They tend to be, especially on
18 topographic relief areas, a nice outcrop of groundwater
19 movement.
20 And this technology that we're using hasn't really
21 been available to us except for maybe the last two years.
22 It's a way to go out and cheaply poke holes and take
23 samples of groundwater as a snapshot only. And you pull
24 that rod back out and you can't go back and get another
25 sample. You've got your sample and that's it.
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It' s a quick investigative tool that . . . the nature
of this business has been evolving for the last, really
13, 14 years, and it's one of those tools that allows us
to take quicker samples and take quicker looks to try to
find the leading edge of something and get the outer
bounds more readily. But we always go back and put in
permanent wells. Those can be duplicated in their
sampling. The kinds of levels we're talking about, you
can mess them up real easily, just like taking the sample
wrong, cross-contaminating. And typically, if we took
a sample of your well tomorrow and it showed
contamination, we'd come back and take another sample
because we want to make sure we're seeing a consistent
level that's not been impacted from any other outside
source, including the sampling technique, the sampling
jar or anything else. If we can show two samples in
somebody's well that are of a concern level, we start
moving forward. . .
But we're talking very, very small numbers here, and
the technology to do field investigations has been
evolving. You know, one person mentioned 25 years. The
fact of the matter is, we couldn't have done anything
about this for those first 15 years because there wasn't
any law out there that gave us any authority to ...
WALTER ROBERTS: I don't mean to interrupt you, but I think you
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1 missed the point of my question. Is contamination at the
2 plant continuing?
3 JAN ROGERS: No, and the system that's in place via the state
4 order was oriented toward going at what I would call
5 source control. The plant had those ponds. There was
6 percolation into the ground from those ponds/ creating
7 probably some fairly high levels of contamination right
8 below, in the groundwater of those ponds.
9 The system the state has put in, has been working
10 on putting in and enhancing is oriented toward that gross
11 ' contamination. The stuff down in the rest of this plume
12 is at a much lower concentration, but it's still a
13 concentration of concern compared to normal drinking
14 water standards that exist. And what we want to do is
15 use this action to supplement what the state action had
16 already been working on back at the plant, to get a
17 handle on this leading edge, lower concentration. But
18 the source has been being addressed by the state since
19 1982, and really on to '88 with the expanded version of
20 that, where they went across the street.
21 So there's really two different components going on.
22 The state's been doing some actions and we actually
23 didn't do anything on the site until it was granted as
24 an NPL, which it was not until later on. And these
25 actions are oriented toward downgrading contamination,
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1 trying to get a handle on it. You know, there were
2 people consuming groundwater downgradient and there's a
3 discharge going into the lake and the tributary that
4 could be adversely impacted by just not doing anything.
5 RALPH HOWARD: I also wanted to point out that I did mention,
6 i remember when I was going through the history of the
7 site, I mentioned about the pump-and-treat system that
8 Jan was referring to. It's referred to as the enhanced
9 system by the company in the documents that you may see
10 at the repository. That system consists of, I guess it's
11 • two additional wells on the other side of Spears Creek,
12 and that's the ones that will pick up pumping in probably
13 March of next year, and those are close to the site.
14 And, for that reason, like he was saying, they will catch
15 groundwater that is closer to the site. And the
16 groundwater that is closest to the site is the most
17 contaminated, based on the data from past studies.
18 But there's not contamination still going on at the
19 site. It's not as if things are still being putting onto
20 the ground or in the water or air or anything else that
21 are continuing to cause a problem. That is not the case.
22 WALTER ROBERTS: You're satisfied about that?
23 RALPH HOWARD: Yes, sir, because their waste water practices
24 have been substantially changed, radically since the time
25 that the rinse waste waters were essentially going out
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1 of the back of the facility. But yes, we're ...
2 TOM GRISWOLD: Ralph, could we further address that?
3 RALPH HOWARD: We can ...
4 TOM GRISWOLD: We'd be glad to speak on that issue.
5 RALPH HOWARD: About the change in the ...
6 TOM GRISWOLD: No, in answer to the question that was asked just
7 a minute ago as to whether the plant is continuing to
8 contribute to the problem. The answer is emphatically,
9 no. There is a state of the art treatment system for
10 treatment of the industrial waste water, which the plant
11 does naturally have as part of its production process.
12 It is a permitted facility that is a permit that is
13 granted to us by the state of South Carolina, a permit
14 which we meet the requirements of. So in answer to your
15 question, no.
16 JAN ROGERS: That's what Ralph was trying to say, is they've
17 changed their whole waste water treatment scheme, where
18 they no longer discharge untreated waste into the ponds.
19 They were the original source. There's no longer that
20 kind of ongoing activity, and what we're trying to do is
21 deal with the results of those past practices.
22 RALPH HOWARD: More questions? Yes, ma'am.
23 VERA GLADDEN: I'm Vera Gladden and I live on Spears Creek
24 Church Lane, right off of Spears Creek Road, about a half
25 a mile from Townsend Saw Chain. My well water has been
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1 tested and I've received a letter from you, and I'd like
2 an explanation.
3 RALPH HOWARD: Sure.
4 VERA GLADDEN: It says that when the water sample was tested,
5 it said that the analyses indicate that no elevated or
6 no unusual levels of either type of contaminant. Now,
7 would you please give me precisely the answer to that?
8 RALPH HOWARD: I thought I took the word unusual out. It was
9 meant to be elevated, and by that ... and I'm glad you
10 asked this question. If we give you an answer and we
11 ' say, well, everything in your sample was low, that's ...
12 you cannot say that, because normal drinking water, as
13 long as it's local quality water, it has a variety of
14 mineral content. So we can't go back to even say, well,
15 everything was low except the iron or the magnesium.
16 Well, those things may be harmless, but you don't want
17 to hear that they're high. But, in fact, by comparisons
18 to some other thing, they will be.
19 What I meant there was that, by elevated or unusual
20 I mean of any concern as regard to health. They're below
21 the drinking water standards and they're not elevated,
22 so there's nothing there to draw our interest or say you
23 have a possible contamination problem. The first thing
24 we check them against is' the drinking water standard.
25 VERA GLADDEN: The essence of what you're saying, is it safe for
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1 me to drink my water?
2 RALPH HOWARD: It is. Yes, ma'am, it is.
3 JAN ROGERS: Let me explain it like this. You have that in the
4 letter, and I told him to take it out because we didn't
5 test your well for bacteria. Your well might have other
6 things that are really unrelated to what we're
7 investigating in it ...
8 VERA GLADDEN: We're not talking about bacteria. We're talking
9 about contamination ...
.0 JAN ROGERS: That's right.
.1 VERA GLADDEN . . . from Town send Saw Chain.
.2 JAN ROGERS: Well, bacteria is a contamination but, I mean ...
.3 VERA GLADDEN: That's true.
,4 JAN ROGERS: Yeah, that's why I told him, state it as such that
5 we see no impact from the contamination problem we're
6 studying on your well. That's really all we're doing in
7 this study. We're not going out and telling everybody
8 they don't have a bacteria problem or some other
9 unrelated issue to drinking water standards that we
0 really don't, we're not authorized to look at. There are
1 other programs that deal with those issues. And I said,
2 sure as anything, we'll get to the public meeting, she'll
3 stand up and say the county came by, tested the water and
4 said it's unsafe to drink because of bacteria, and she'll
5 have this letter saying we said it was safe to drink.
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1 So, you know, we tried to context that letter ...
2 VERA GLADDEN: I just asked for an answer.
3 JAN ROGERS: Yeah.
4 VERA GLADDEN: The letter was written and I'd just like ...
5 JAN ROGERS: That's all we're saying, it is below any concern
6 used on public water supplies for chromium. It's below
7 the safe drinking water standard, and those are using
8 very conservative numbers that are developed for lifetime
9 exposure.
10 VERA GLADDEN: Do you plan to check the water again?
11 ' JAN ROGERS: I think it depends on what comes out of this study
12 and confirmation with some permanent wells on the aquifer
13 itself. But I would guess that we will probably do some
14 other periodic sampling just to be sure that nobody is
15 being impacted, and that's also why we try looking at a
16 . lead edge. It minimizes the cost, because there is a
17 cost involved in running those samples. And
18 periodically, it's not going to change overnight, we may
19 go back and look at it again as it pans out and we get
20 more details about that aquifer down there and implement
21 the system.
22 RALPH HOWARD: More questions? Yes, sir.
23 RAYBURN ROGERS: I have a question. My name is Rayburn Rogers.
24 I own a lot on Woodcreek, by the lake. My question is
25 this: you mentioned that the Proposed Interim Action
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1 Plan, that you will get it into place probably in
2 thirteen months; is that correct?
3 RALPH HOWARD: The Remedial Action itself. The plan is kind of
4 only outlined in the Fact Sheet and so forth, but yes,
5 sir.
6 RAYBURN ROGERS: Once you get that in operation, how sure are
7 you that the plume boundaries will not expand over and
8 beyond where they are now, and that the groundwater
9 migration will cease to remain in that boundary?
10 RALPH HOWARD: The boundary itself is, as I mentioned, kind of
11 ' a best approximation at this point. The way we operate
12 is that even if ... as I mentioned earlier, even if that
13 data is high, even if those results are high, we believe
14 they're going to exceed the drinking water standard or
15 we wouldn't be doing this tonight. If we didn't have
16 confidence in that data, we wouldn't proceed with this.
17 The boundary may be located closer back to the site
18 or it could be, even though our current data says that
19 it's not, on the other side of Spears Creek, for example.
20 With regard to 1-20 and so forth, we're less certain.
21 But we do have to establish where the boundary is.
22 Now as far as the certainty of preventing the
23 migration, that I have a great degree of certainty in
24 because it is achievable and it ... and we also use ...
25 what we do to verify is, we don't just, you know, we
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don't just take it on it's word. We will put sampling
in place/ probably monitor ... well, there will be
monitor wells that are located behind where we say the
boundary is, because, to successfully do one of these
operations, you have to have what we call a compliance
point or a check point. So the idea there is, if I have
a monitor well and it's behind where I say the boundary
is, then that well should not come up contaminated.
That's how we prove to our satisfaction that it is not
going to go beyond.
And that's a good question. With the imprecision
that I've already mentioned, there should be some way of
being certain that's it' s not migrating and that is how
we do it. That, there's not really imprecision with the
monitoring. There's imprecision with the characterizing
part. That's what makes it difficult.
More questions?
SANDRA MARTIN: My name is,Sandra Martin, and I live a mile and
a half from here. I work for the Pontiac school. We own
property on a personal road straight to 1-20, and I was
just wondering if there's contamination ... (inaudible)
... I know it says on the bottom right here, the plume
boundary is uncertain. Are you all going to be testing
on that side?
RALPH HOWARD: The little marks that you see on the diagram,
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1 plus the ones on the Fact Sheets, those are sampling
2 areas. It's kind of hard on the eyes to read it, but
3 there's a little DPT there; those are all sampling
4 points. So, as you see, we've drawn the boundary on the
5 other side, meaning that those sampling points do show
6 levels above the drinking water standard, with the
7 uncertainty that I mentioned earlier. But yes, they do
8 show.
9 Now, as far as whether that contamination is real,
10 that we still don't know. We have data that says there
11 is a chance that that is, there's a possibility that that
12 level is higher than it should be. So do we know for
13 sure? No. Do we suspect that it is? Yes, ma'am.
14 SANDRA MARTIN: What's the alternative? If I have my well water
15 tested, what should I do?
16 RALPH HOWARD: Well, and I really didn't highlight this but I
17 know that I mentioned it. We ... actually, the company,
18 as a precaution went -ahead/ with our approval, and
19 sampled seven of the private wells over there. They
20 sampled ... I guess I won't go through the names, but
21 they sampled all of the private wells that they could
22 find anyone in a home to account for. They got them all
23 except maybe one, and those were the ones I mentioned
24 were below detection levels.
25 It has to be kept in mind that most of those wells
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1 are deep in the sense that they are deeper than our
2 samples are. Our samples are all from just the water
3 table/ which is the first place that you hit the water
4 going downward. And most of those wells are deeper, but
5 one or two of them are not particularly very much deeper.
6 So it's not clear what that means yet. It could be
7 that the samples are reading way high, but probably not
8 everywhere, they're not reading way high. That's what
9 we have to find out, which is real. So it's not clear
10 whether that property between 1-20, again, is a boundary.
11 It may be a boundary, but we're going to find that out.
12 That's what part of this Interim Action is about.
13 More questions?
14 WALTER TYLER: This is Walter Tyler. This may get into a legal
15 question, but our property has been up for sale for two
16 years. If I have a prospective buyer, I'd certainly want
17 to show him this letter. It's elevated levels.
18 RALPH HOWARD: Right, and that's true, and if you sold the
19 property soon, you should. But that will not be the last
20 word on this.
21 WALTER TYLER: We will have ... (inaudible) ...
22 RALPH HOWARD: When we determine if the levels are real out
23 there, the findings of that, you will know those.
24 WALTER TYLER: But it's the well, not the site. It could be
25 tested ...
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RALPH HOWARD: Right ...
HALTER TYLER: A sample hasn't been taken out of the well to
check ...
RALPH HOWARD: I'm not, honestly I'm not sure really why yours
was not sampled. I don't know if you were contacted by
Aquaterra about that or not.
WALTER TYLER: They went on the property and drilled two
samples, but they didn't ...
RALPH HOWARD: Right, for which we ... right, that was in our
agreement, but I can't say why your well was not sampled.
But it's possibly because it wasn't being used, because
it wasn't in operation, if water's not being used from
it. But I think it would be a mistake not to draw a
conclusion from those seven wells. The conclusion we
draw for now is that we don't see it in the private
wells. But that doesn't mean we're going to just accept
that as the end of the thing.
WALTER TYLER: We'll have some future documentation on our
property?
RALPH HOWARD: You'll have some future documentation that refers
either directly to you or you will be able to see, you
know, your property is affected or is not, yes, sir. We
will not just publish the results and not make the
property owners aware. We will make you aware.
More questions? Yes, sir.
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1 BILL BOWERS: My name is Bill Bowers. I am one of the full time
2 residents on this property on Woodcreek Lake. There's
3 really only eight full time residents over there, and the
4 four wells that you're trying to look at cover only the
5 full time residents. It seems to me that it couldn't be
6 too expensive to look at all the wells and check all
7 those wells, at least for full time residents. We drink
8 the water every day. I mean, it don't seem to me like
9 it would take that much ... (inaudible) ... to test the
10 water or take that much time ... (inaudible) ... Of
11 ' course, we could see what we have over there and we also
12 would know ... (inaudible) ... At one of the first
13 meetings that we had, some discussions came up ...
14 (inaudible) ... we talked about specifically the surface
15 water ... (inaudible) ...
16 RALPH HOWARD: Please speak louder. I know she's having trouble
17 reading you.
18 BILL BOWERS: Okay, I'm sorry.- There is a concern, of course,
19 with it getting into the drinking water and the fish ...
20 (inaudible) ... so far the lake sample, you know, the
21 state sampled ... (inaudible) ... about a year and a half
22 ago ... (inaudible) ... But the great concern is the
23 fish, because there's some bream ... (inaudible) ... and
24 the bream come down the stream ... (inaudible) ... We
25 don't know that. I think the confidence level, I think
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the people would feel much better if we say ... if you
only inspect it for bacteria or things other than what
... (inaudible) ... If you don't, I believe that we will
ask the property owners to take matters into their own
hands and test it ourselves. I think it would be much
wiser for you people to do it ... (inaudible) ... Jim is
out there, he's my neighbor. He's out there all the time
and he would probably consider himself permanent.
There's probably about twenty drinking water wells around
there. I think at least the eight full time residents
should be tested ... (inaudible) ... The people who don't
live there permanently probably feel the same way about
it. It would give the people a little more confidence
level if the wells that are consistently, constantly used
were tested ... (inaudible) ...
RALPH HOWARD: The best answer is that that is a consideration,
and it shouldn't be thought of that these four wells
we're going to sample is the final thing. This is a
start. Whether it leads to sampling all of them, I caa't
say. I guess at this point I can't promise you. But we
will not avoid sampling those wells just because we don't
want to do it. The cost is not ... we' re not avoiding
it because of cost; that's not the issue.
But we have to proceed kind of in a step wise,
logical manner, and I'm not really sure it's possible to
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1 completely satisfy you in that regard. But we do have
2 some things that need to come out, where we have limited
3 information and we're kind of acting in the dark here.
4 One is the ecological assessment, but also there is the
5 issue of exactly where is boundary; and by that I mean,
6 it cannot reach those wells but through groundwater
7 migration. And a lot of what we're going to learn now
8 is precisely that, is groundwater migration and extent.
9 So I guess what I'm saying is, we're not ruling out
10 sampling all the wells, but, you know, we need to find
11 ' out where that limit is or where the best data to show
12 us that it is and then we could proceed to go ahead and
13 get them all. It is precautionary. Like I said, we
14 don't expect anything to come up with these wells.
15 BILL POWERS: We are all pleased that you're doing what you're
16 doing. But most of us know ... (inaudible) ... over 90
17 percent ... (inaudible) ... we do want to contain it in
18 that area ... (inaudible) ... To me, the ... (inaudible)
19 ... thing to do is to get out where people are drinking
20 water, get that cleared up. Continue with what you're
21 doing, if you can do it, but I'd say that ... (inaudible)
22 ... day it would take to check the water in the wells
23 where people live. It couldn't take more than a day ...
24 (inaudible) ... It couldn't take more than a day to get
25 a sample, and I don't know how long it takes ...
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1 (inaudible) ... to check those twenty wells —
2 (inaudible) , .. that facility over there in a half a day.
3 JAN ROGERS: We hear your argument. Can we defer an answer?
4 We hear your concern and I think we can look into it.
5 One of the things I'll pick up, we need to look at the
6 various other alternatives to get some of those wells
7 sampled.
8 Right now, resources, you know, the company is
9 paying for these things and we' d have to talk to the
10 company. We'd also have to look at some other routes to
11 ' getting something like that done that are available to
12 us.
13 So we hear your comment. From a technical basis,
14 we think we have a rationale as to why we only go out and
15 look at that front edge perimeter. But we need to
16 explore that other approach too.
17 RALPH HOWARD: I also want to point out and make sure ...
18 because one thing you said that I want to take note of
19 with the map, and that is that we have some wells that
20 are actually closer, which would be those wells on the
21 other side of 1-20. At the time, we didn't even have the
22 direct-push samples that you see on the other side of I-
23 20. The company did propose to us that they go get those
24 wells and sample them, and we said yes; so they did
25 respond quickly. And there was such great uncertainty
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about the possible effect with little or no data, and
they were willing to do that, which was the appropriate
thing to do.
We didn't know what to expect in those wells, those
seven private wells. And I think that that should be
pointed out, that we have reacted to what we saw as the
nearest, closest wells. At that time, the data were
still leading away to the east, towards Spears Creek, and
this is sort of a continuation of that idea of a
precautionary response.
But that' s not to say that the data may not lead us
in that direction. We really have to consider, okay,
what about the others? But as I mentioned earlier when
I was talking to the one gentleman, the science of it
tells us that it's unlikely that the contamination will
simply go around and get to people who are more distant,
because we know in this case where it's coming from. So
by starting at where -it's coming from and working
outward, we look for a route and a pathway and a
direction of movement, you could say. And that's what
leads us, as a precautionary move, to get those wells and
not just some others at random, because of their location
and their position.
SHARON JACKSON: I'm Sharon Jackson with the Richland County
Council, and I ... (inaudible) ...
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RALPH HOWARD: Can you speak louder? She's ...
SHARON JACKSON: I wanted to ask about getting the rest of them
checked because not too long ago you mentioned that some
wells would test positive, others would test negative.
I'm sure the county would be willing to help you any way
they can, and will, to get these wells tested. You keep
saying on the other hand. Well, on the other hand, these
people are living here from day to day not knowing if the
water they drink is safe. I am willing to work with you
and I'm sure the county will work with you to get these
wells tested. I don't think we need to put this off any
longer.
And I would also like to see the documents that you
have at the library, I would like to see them more
simplified so people can understand them when we read
them. We would appreciate you making them this thick
(indicating), simplifying them a little bit where they
can understand what they're reading and doesn't get ...
(inaudible) ... where you fall asleep once you get past
fifteen or twenty pages.
RALPH HOWARD: We have that problem quite often, to be honest.
JAN ROGERS: We really would like some suggestions on how to ...
(inaudible) ... But, yeah, that's a dilemma. I mean,
it's very, our standard way of doing business —
(inaudible) ... out to the public as far as —
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1 (inaudible) ...
2 RALPH HOWARD: You know, it's not something we can resolve
3 tonight. I can't stand here and tell you we're going to
4 do it, but these are the concerns that we need to hear.
5 This is why we do this. We've got to find out how people
6 feel.
7 SETH BRUCKNER: Please keep in mind that our office is available
8 to answer any questions ... (inaudible) ... If there's
9 something there that you can't figure out, there's a toll
10 free number on the back of this document ... (inaudible)
11 "...
12 RALPH HOWARD: Please do call us. I get quite a few calls, and,
13 you know, it's part of the job. I enjoy it and I'd be
14 happy to explain in details, in simple terms. But we'll
15 take your recommendation under advisement.
16 Any more questions, please?
17 I appreciate it tonight. I wish you would stay if
18 you like. We could-answer any questions one-on-one, in
19 whatever depth you'd like.
20 I want to close by thanking Mr. Inabinet, Richard
21 Inabinet and his staff for providing our meeting place
22 tonight. This is a beautiful school and, despite their
23 initial reservations, we were able to convince them to
24 let us meet here about the Townsend Saw Chain site, and
25 it's been wonderful. It's a beautiful facility.
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1 Compared to some of the ones we have to use from time to
2 time, this is a palace.
3 if you would like to send in comments, please do in
4 writing to me. There are additional Fact Sheets in the
5 back if you do not have one. In the Fact Sheet, my
6 address and so forth is in there. September 20th is when
7 we'd like to get your comments by. However, if there is
8 something that you would like to have further considered
9 by us, then request an extension of that comment period.
10 Just tell us in writing that that's what you're doing and
11 • here's why, what it is that you'd like to see addressed,
12 and we'll proceed from there. Your comments get response
13 and the Record of Decision has in it the comments that
14 I receive from you, and I do mean every single one. So
15 do not hesitate to write in.
16 And also, I want to mention that the Interim Record
17 of Decision for this, after your comments are
18 incorporated, plus the Feasibility Study which will have
19 the ecological results in it, they're going to be added
20 to that information repository down there at the library
21 as things go along. And, depending on what we find out
22 with this ecological work, we may choose to have another
23 public meeting; because I hear a lot of interest about
24 that tonight, and we may have some sort of public forum
25 for that, a meeting or availability session.
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1 Thank you for coming tonight. We appreciate it.
2 (There being no further discussion, the hearing was concluded
3 at 8:50 p.m.)
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CERTIFICATE
This is to certify that the Interim Action Proposed Plan
Public Information Meeting for the Townsend Saw Chain Superfund
Site/ consisting of Sixty-five (65) pages, is a true and correct
transcript of said meeting; said meeting was reported by the
method of Stenomask with Backup.
I further certify that I am neither employed by nor related
to any of the parties in this matter or their counsel; nor do
I have any interest, financial or otherwise, in the outcome of
same.
IN WITNESS WHEREOF I have hereunto set my hand and seal this
14th day of September, 1993.
Patricia Hall
Court Reporter
Notary Public for South Carolina
My-Commission Expires: Jan. 21, 2002
(Recorded deposition tapes are retained for six (6) months from
date of deposition or until transcript has been signed in cases
where signature is not waived).
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APPENDIX B
STATE OF SOUTH CAROLINA CONCURRENCE LETTER
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South Carolina ——•— commissioner: Douglas E. Bryant
DHEC
Board: Richard E. Jabbour. DOS. Chairman William E. Applegate. Id.
Robert J. Stripling. Jr, Vice Chairman John K Burriss
Sandra J. Molander, Secretary Tony Graham. Jr., MO
Oepartment at Health and Environmental Control John B. Pate, MO
2600 Bull Street Columbia, SC 29201 Promoting Health. Protecting the Environment
November 3, 1993
Mr. Patrick Tobin
Acting Regional Administrator
US EPA, Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
RE: Revised Interim Record of Decision (IROD)
Townsend Saw Chain Site
Richland County, South Carolina
Dear Mr. Tobin:
The Department has reviewed, commented on, and concurs with
the Interim Record of Decision (IROD) for the alternative selected
for the interim remedial action at the Townsend Saw Chain site.
The alternatives for the interim remedial activities selected by
EPA include extraction and treatment of contaminated groundwater.
The treated groundwater will be discharged to either a local
publicly-owned treatment works, Spears Creek or another discharge
option as determined appropriate. The purpose of the interim
remedial action is to prevent or control the off-site migration of
contaminated groundwater.
In concurring with this IROD, 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 IROD is
no longer protective of public health and the environment.
SF93O589. YM {tout 2 pages!
f\
^j ttCYClCd D*Df
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This concurrence with the selected remedy for the Townsend Saw
Chain 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,
R. Lewis Shaw, P.E.
Deputy Commissioner
Environmental Quality Control
CC: Hartsill Truesdale
Lewis Bedenbaugh
Keith Lindler
Rebecca Dotterer
Harry Mathis
Charles Gorman
Bill Galardi
Yanqing Mo
SF33OS89, YM (tota
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