PB94-964079
EPA/ROD/R04-94/213
March 1995
EPA Superfund
Record of Decision:
Rock Hill Chemical Co.
Rock Hill, SC
6/T7/1994
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RECORD OF DECISION
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
RUTLEOGE PROPERTY SUPERFOND SITE
ROCK HILL, YORK COUNTY,
SOUTH CAROLINA
PREPARED BY:
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA
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DECLARATION FOR THE RECORD OP DECISION
SITE NAME AND LOCATION
Rutledge Superfund Property Site
Rock Hill, York County, South Carolina
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Rutledge Property Superfund Site (the Site), located in Rock
Hill, York 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), 42 U.S.C.
§§ 9601 et seq.. and, to the extent practicable, the National Oil
and Hazardous Substances Pollution Contingency Plan (NCP),
40 C.F.R. Part 300 et seq. This record of decision is based on
the administrative record 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 SELECTED REMEDY
This remedial action addresses groundwater contamination.
The major components of the selected remedy include:
O Extraction of contaminated groundwater;
D Direct discharge to POTW of extracted groundwater;
D Deed restrictions;
D Long-term groundwater monitoring; and,
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D Additional work during the remedial design phase
including; determining the relationship of the
contamination detected in the private wells to the
contamination detected in the on-site monitoring wells,
collecting additional background surface soil samples
to confirm that the variance in manganese levels is
consistent with the environmental setting, and
collecting additional surface water and sediment
samples to determine if the selected background sample
is representative of true background conditions.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost effective. This remedy utilizes
permanent solutions to the maximum extent practicable for this
Site. The selected groundwater remedy satisfies the preference
for treatment for this Site.
Since selection of this remedy will result in contaminated
groundwater remaining on-site above health-based levels until the
remedial action is complete, a statutory five (5) year review
will be performed after commencement of the remedial action to
insure that the remedy continues to provide adequate protection
of human health and the environment.
John H. Hankinson, Jr. Date
Regional Administrator
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5 9 0003
ITS
SECTION PAGE
1. 0 SITE LOCATION AND DESCRIPTION 1
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES 4
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION 6
4.0 SCOPE AND ROLE OF THIS ACTION WITHIN SITE STRATEGY 7
5.0 SUMMARY OF SITE CHARACTERISTICS 7
5.1 Meteorology 7
5.2 Geologic and Hydrogeologic Setting 12
5.2.1 Geology/Soils 12
5.2.2 Hydrogeology 12
5.3 Nature and Extent of Contamination 13
6 .0 SUMMARY OF SITE RISKS 16
6.1 Contaminants of Concern 17
6.2 Exposure Assessment 18
6.3 Toxicity Assessment of Contaminants . 18
6.4 Risk Characterization 20
7 . 0 DESCRIPTION OF GROUNDWATER REMEDIAL ALTERNATIVES 22
7.1 No Action 24
7.2 Limited Action, Institutional Controls 25
7.3 Groundwater Extraction and Treatment,
Surface Water Discharge .25
7.4 Groundwater Extraction, POTW Discharge 26
8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 27
8.1 Groundwater Remediation Alternatives 28
8.1.1 Threshold Criteria 28
8.1.2 Primary Balancing Criteria 28
8.1.3 Modifying Criteria 30
9 . 0 THE SELECTED REMEDY 31
9.1 Groundwater Remediation 31
9.1.1 Description 31
9.1.2 Applicable or Relevant and Appropriate
Requirements (ARARs) 33
9.1.3 Performance Standards 35
9.2 Monitor Site Groundwater and Surface 35
10.0 STATUTORY DETERMINATIONS 37
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LIST OF APPENDICES ii
APPENDICES
APPENDIX A - RESPONSIVENESS SUMMARY
APPENDIX B - STATE LETTER OF CONCURRENCE
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5 9 0004
LIST OF FIGURES til
FIGURE PAGE
1 Site Location Map 2
2 Site Plan Map 3
3 Monitoring/Private Well Locations 8
4 Location of Surface Soil Samples 9
5 Location of Subsurface Soil Samples 10
6 Surface Water/Sediment Sample Locations 11
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LIST OF TABLES iv
TABLE PAGE
1 Groundwater Remediation Levels (Rls) 36
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5 9 0005
DECISION SUMMARY
RUTLEDGE PROPERTY SUPBRFUND SITE
ROCK HILL. YORK COUNTY, SOUTH CAROLINA Pace 1
1.0 SITE LOCATION AND DESCRIPTION
The Rutledge Property Site (the Site), is a 4.5 acre parcel
located between U.S. Highway 21 (Cherry Road) and Farlow Street,
just east of Cranford Street in Rock Hill, York County, South
Carolina (Figure 1). The Site's geographic coordinates are
34"57'50" north latitude and 80°59'55" west longitude.
The property occupies two (2) plats of land: one parcel, which
is owned by William C. Rutledge, Jr., encompasses the eastern
portion of the Site; and the second parcel, which is owned by
First Union National Bank of South Carolina, encompasses the
western portion of the Site (Figure 2). The Site is bounded by
Cherry Road and the Rock Hill Mall to the south; First Union
National Bank of South Carolina and fast-food restaurants to the
west; residential property (single-family dwellings) and an
unnamed stream to the north; and the York Shopping Plaza to the
east.
On-site drainage is controlled by topography and man-made
drainage features. The Site is drained by an unnamed stream,
which originates on the northern portion of the Site. There is
another smaller drainage ditch that intersects the larger unnamed
stream. The unnamed stream receives the ma'jority of surface
water from the 72-inch storm drain. The origin of surface water
that flows through the 72-inch storm drain includes open land
south of the Rock Hill Mall and surface water runoff from the
Rock Hill Mall property and Cherry Road. Another 40-inch storm
drain also intersects the unnamed stream, in the same area as the
72-inch drain. Water from this smaller drain, originates west of
the Site. Site runoff and surface water from the drainage ditch
also flow into the unnamed stream. Presently, all surface water
that reaches the unnamed stream flows along its course in a
northeasterly direction for 1.9 miles and discharges into the
Catawba River. Elevations across the Site vary from 606 feet
above mean sea level (msl) in the southern and western parts of
the Site, to 590 feet above msl in the northern portion of the
Site.
A majority of the Rock Hill residents receive potable water from
the City of Rock Hill utilities. The residents who do not
receive their potable water from the City of Rock Hill, use both
private or community wells.
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ROCK HILL,
YORK COUNTY
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1000 0 1000 2000
I
SCALE IN FEET
SOW T H
CAROLINA
CDMFEDERALPROGRAMSCORPORATION
amp Dnmcr
SITE LOCATION MAP
RUTLEDGE PROPERTY
CAROUNA
Figure No. 1
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100
YORK
SHOPPING
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HAPPY GARDEN
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RESTAURANT
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SURFACE WATER
SUBSURFACE
STORM DRAIN
----- SITE BOUNDARY
CDMFEDERALPROG^MSCORPORATION
a subsidurv of Camp Drtuer &, McKee Inc
SITE PLAN MAP
RUTLEDGE PROPERTY
CAROLINA
Figure No. 2
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Record of Decision
Rutledge Property Site
Page 4
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
The Rutledge Property (Rock Hill Chemical Company) Superfund Site
(the Site) is located on North Cherry Road, in Rock Hill, York
County, South Carolina. The Site covers approximately 4.5 acres
of land in a light commercial and residential area, across from
the Rock Hill Mall. From 1960 through 1964, the Site was the
location of the Rock Hill Chemical Company (RHCC), a facility
where paint solvents were distilled and reportedly, textile dye
products were recovered. While RHCC was operating, residue from
RHCC's distillation still bottoms, drum bottoms, and storage tank
bottoms, were placed in piles on the surface of the facility
property and later covered with fill dirt and construction
debris. During its operation, RHCC accepted waste oils and
solvents from generators, separated them, and sold the extracted
solvents and oils back to the generators.
The reclamation process used a single pot still, a filter press,
and a small steam generator. In this operation, waste fluids
were reprocessed by separating solvents from the oil phase,
filtering the oil through a charcoal filter press, and
repackaging the reclaimed oil for distribution to clients. The
waste fluids initially were contained in drums, but as the
process expanded, above ground storage tanks were added as
needed.
Paint sludges, textile dye products, still bottoms, and other
wastes generated during the reclamation process, were stored in
piles placed directly onto the ground. In some cases, waste
products were buried at the Site. Still bottoms generated from
the reclamation process, were incorporated into various layers of
fill dirt and construction debris was used to fill low areas of
the property to help support heavy machinery. Tanks that were
used to hold liquid wastes before reclamation had, on occasion,
leaked onto the ground, creating a potential source of
contamination. One such leak was caused by a faulty tank valve.
Another release occurred when a valve on one of the tanks was
deliberately opened by a trespasser, which caused chemicals to
spill onto the ground.
By late 1961, the demand by RHCC clients for reclaimed oil
diminished, and a surplus remained in inventory. Much of this
residual inventory was consumed by RHCC as fuel for its steam
generator until the company ceased operations late in 1964, or
was reprocessed and sold to various customers. In October 1964,
a fire at the facility caused drums of oil and chemicals to
explode, releasing their contents into the environment. After
the fire, the RHCC partnership was dissolved. Since that time,
no other industrial activity has taken place at the Site.
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5 9 0007
Record of Decision
Rutledge Property Site
Page 5
In 1984, First Federal Savings Bank began to construct a branch
office on the lots it purchased in 1972. The bank had made no
use of the property for the previous twelve (12) years it had
owned the land. During construction activities, it wag
discovered that the property was contaminated. At the time of
the 1984 discovery, First Federal Savings Bank promptly notified
the State of South Carolina Department of Health and
Environmental Control (SCDHEC) and employed consultants to
analyze the property and determine the extent of the
c ont aminat ion.
First Federal Savings Bank's consultants discovered distillation
still bottoms, metal drums, and other hazardous substances buried
beneath the surface of First Federal Savings Bank's property.
Under the supervision of SCDHEC, First Federal Savings Bank
conducted a removal action on its property which was completed in
November 1986, and received SCDHEC approval in December 1986.
During the 1986 removal action, the previously contaminated
portion of the property was excavated, the contaminated soil was
deposited in an approved landfill, and the affected portion of
First Federal Savings Bank's property was covered by a clay cap.
In late 1987, EPA's Emergency Response Team used CERCLA funds to
remove approximately 46,000 gallons of waste from the above
ground tanks, along with an unknown amount of contaminated soil.
This material was transferred to a RCRA-regulated facility.
Over the years, prior to the remedial investigation, there have
been fourteen (14) sampling investigations at the Site. These
investigations were directed by Federal, State and local agencies
in an attempt to characterize and determine the nature and extent
of environmental contamination. In these previous studies,
samples were collected from soil, groundwater, surface water,
sediment, as well as waste samples from drums and five (5) above-
ground storage tanks. Analytical results of these samples have
confirmed the presence of contaminants in all of the media
sampled.
Based upon this information, EPA proposed the Site for inclusion
on the National Priorities List (NPL) on June 24, 1988, and EPA
finalized the Site on the NPL on February 21, 1990, with a hazard
ranking score of 40.29.
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Record of Decision
Rutledge Property Site
Paae 6
On May 23, 1991, EPA issued special notice letters and
general/special notice letters pursuant to Section 122(e) of
CERCLA, 42 U.S.C. § 9622(6), along with CERCLA Section 104(e),
42 U.S.C. § 9604(e), information requests to all potentially
responsible parties (PRPs). The special notice letters and
general/special notice letters offered the PRPs the opportunity
to perform, finance or otherwise participate in the remedial
investigation/feasibility study (RI/FS) activities at the Site.
On August 21, 1991, however, the PRPs notified EPA that they were
not going to sign the Administrative Order on Consent for the
RI/FS. EPA notified the PRPs that EPA was conducting the RI/FS
utilizing money from the Hazardous Substance Superfund. Field
work for the RI began in March 1992.
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
An information repository for the Site, which includes the
Administrative Record, was established at the York County Library
in March 1992, and is available to the public at both the
information repository maintained at the York County Library,
138 East Black Street, Rock Hill, South Carolina, 29731, and at
EPA, Region IV Library, 345 Courtland Street, Atlanta, Georgia,
30365. A mailing list was established for the Site and a fact
sheet was mailed in March 1992. The fact sheet outlined the
following: the objectives of the RI, a summary of the Site
history, the various opportunities for public involvement
(including Technical Assistance Grants), the location of the
information repository, and an announcement of a public meeting
that was held in Rock Hill on March 19, 1992.
EPA issued a proposed plan in February 1994, which outlined EPA'a
preferred alternative. A public comment period for the proposed
plan was held from February 22, 1994, to March 24, 1994. EPA
held a public meeting on March 1, 1994, where EPA representatives
answered questions regarding the Site and the remedial
alternatives under consideration, which were outlined in the
proposed plan. EPA received a request for an extension to the
public comment period, and extended the comment period to April
25, 1994.
EPA received oral comments during the March 1, 1994, public
meeting, and written comments during the sixty (60) day public
comment period. Responses to the comments received by EPA are
included in the Responsiveness Summary (Appendix A).
This ROD presents EPA's selected remedial action for the Site,
chosen in accordance with CERCLA, as amended by SARA, and to the
extent practicable, the NCP. The remedial action selection for
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5 9 0008
Record of Decision
Rutledge Property Site
Pace 7
this Site is based on information contained in the Administrative
Record. The public and state participation requirements under
Section 117 of CERCLA, 42 U.S.C. S 9617, have been met for this
Site.
4.0 SCOPE AND ROLE OF THIS ACTION WITHIN SITE STRATEGY
Two (2) removals, one in 1986, and the other in 1987, reduced the
risk from exposure to contaminated soil as well as reduced the
leaching of contaminants from the soil to the groundwater. This
was confirmed during the remedial investigation. Therefore,
according to the Baseline Risk Assessment, no additional cleanup
of the Site soil is necessary.
The purpose of the remedial alternative selected in this ROD is
to reduce potential future risks at this Site from exposure to
contaminated groundwater. There is no unacceptable current risk
present at the Site. The groundwater remedial action is expected
to eliminate the potential future risks to an on-site resident,
that potentially could use contaminated groundwater for potable
water supply. This is the only ROD contemplated for this Site.
5.0 SUMMARY OF SITE CHARACTERISTICS
The RI investigated the nature and extent of contamination on and
near the Site, and defined the potential risks to human health
and the environment posed by the Site. A supporting RI objective
was to characterize the Site-specific geology and hydrogeology.
A total of sixty-five (65) soil samples, fifty-six (56)
groundwater samples, seven (7) surface water samples, and seven
(7) sediment samples were collected during the RI. Field work
for the RI began in March 1992, during which soil and surface
water samples were collected, and a well survey was conducted.
Monitoring wells were installed and sampled from June to July
1992, along with several private wells. Additional monitoring
wells were installed and sampled from December 1992, to January
1993. The final RI/FS report was completed in January 1994.
Locations of groundwater samples from monitoring wells and
private wells, surface soil, subsurface soil, surface water, and
sediment samples are shown in Figures 3 through 6.
5.1 Meteorology
The Site is located in the Piedmont physiographic province and
the Charlotte Belt geologic province of South Carolina. Summers
are long with warm weather generally lasting from Nay to
September. Winters are mild and relatively short with freezing
temperatures occurring about half of the days in winter. Average
annual daily maximum and minimum temperatures are 74°F and 50°F,
respectively. The average annual rainfall amount is 46.7 inches
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rORK
SHOPPING
PIAZA
-03
LOCATION
GAUGE
MONITOR/PRIVATE WELL LOCATIONS
RUTLEDGE PROPERTY
amp Dresser
ROCK HILL, SOUTH CAROLINA
Figure No. 3
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5 9
0009
100
YORK
SHOPPING
PLAZA
>-< CULVERT
^ . TREEUNE
SURFACE WATER
SUBSURFACE
STORM DRAIN
SAMPLE LOCATION
LOCATION OF SURFACE SOIL SAMPLES
RUTLEDGE PROPERTY
COM FEDERAL PROGRAMS CORPORATION anr-ir un i cmrru r AOniiMA
.,uteda«o.CampOre*r4McK«lnc HOCK MILL, SOUTH CAROLINA
Figure No. 4
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100
YORK
SHOPPING
PLAZA
HAPPY GARDEN
CHINESE
RESTAURANT
>•< CULVERT .
TREEUNE
SURFACE WATER
SUBSURFACE
STORM DRAIN
® SAMPLE LOCATION
LOCATION OF SUBSURFACE SOIL SAMPLES
RUTLEDGE PROPERTY
COM FEDERAL PROGRAMS CORPORATION onrtf Mil I QHIITM r&eni IMA
.«.to«.,,o,otan,pD«Kr*McK«inc. HOCK HILL, SOUTH CAROLINA
Figure No. 5
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0010
fete.* RP-SW/SO-08
100
RP-SW/SO-07
YORK
SHOPPING
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-APPY GARDEN
:HINESE
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>-< CULVERT
TREEUNE .
SURFACE WATER
SUBSURFACE
STORM DRAIN
SAMPLE LOCATION
CDMFEDERALPROGRAMSCORPORATION
a subudury of Omp Dnriser 4 McKcc Inc.
SURFACE WATER/SEDIMENT SAMPLE LOCATIONS
RUTLEDGE PROPERTY
RQCK
CAROLINA
Figure No. 6
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Record of Decision
Rutledge Property Site
Paqe 12
and the annual evaporation rate is 41 inches resulting in a
yearly net rainfall of 5.7 inches. The two-year, 24-hour
rainfall amount is 3.25 inches.
5 . 2 Geologic and Hydroaeolooic Setting
5.2.1 Geology/Soils
The Site is located in the Piedmont physiographic province and
the Charlotte Belt geologic province of South Carolina. The
Piedmont is a broad plateau ranging from 400 to 1200 feet above
sea level. Piedmont areas are characterized by low, rounded,
gently sloping hills having relatively deeply incised dendritic
drainage patterns. Piedmont sites typically have a thick layer
of highly weathered residual soil and weathered rock (saprolite)
overlying competent bedrock.
Residual materials at the Site generally consist of sandy, clayey
silt, fine sand and silt. The contact between the saprolite and
bedrock typically is gradational and is often characterized by a
zone of fractured rock material. Saprolite is weathered
decomposed in-place rock which is characterized by its retention
of the original fabric or structure of the parent bedrock. The
residual soil and saprolite thickness in the Piedmont is
variable, but may be greater than eighty (80) feet.
The Piedmont province is characterized by metamorphic rocks which
have been intruded by igneous rocks. The metamorphic rocks of
the Charlotte Belt include schist, gneiss, amphibolite, and meta-
gabbro. Igneous rocks range in composition from granite to
gabbro. Geologic mapping of the Rock Hill area indicates that
the Site is underlain by gabbro. Unconsolidated soils consist of
a surficial layer of alluvium underlain by saprolite. At the
Site, the alluvium consists of black-to-grey to green-to-blue..
sandy, clayey silt. The alluvium ranged in thickness from 5.5 to
9.0 feet. The underlying saprolite consists of green-to-tan-to-
brown fine sand and silt ranging in thickness from 3.4 to 22
feet.
5.2.2 Hydroaeoloay
Information on the hydrogeology of the Site was obtained from the
sixteen (16) monitoring wells installed during the RI and four
(4) existing wells. Groundwater at the Site is first encountered
in the unconsolidated soil zones overlying bedrock. The water
table was encountered at depths ranging from approximately five
(5) feet to approximately eight (8) feet below land surface. The
direction of groundwater flow within both aquifers is toward Site
surface water.
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5 9 0011
Record of Decision
Rutledge Property Site
__ Pace 13
The ability for groundwater to move horizontally through the
underlying aquifer system was evaluated using the hydraulic
conductivity values determined from the rising head tests made in
the soil and rock units. The average horizontal hydraulic
conductivity of the soil aquifer ranged from 0.14 to 2.62 feet
per day and averaged 1.07 feet per day. The horizontal hydraulic
conductivity in the rock wells ranged from 0.018 to 58.2 feet per
day and averaged 1.7 feet per day. Average hydraulic
conductivities were calculated using a geometric mean.
The ability for groundwater to move vertically through the soil
unit was evaluated by measuring the hydraulic conductivity of
four (4) Shelby tube samples collected during the subsurface
investigation. These Shelby tube samples were then sent to a
geotechnical laboratory and tested for vertical hydraulic
conductivity. The vertical hydraulic conductivity of the soil
unit ranged from 1.7 x 10~5 to 0.15 feet per day and averaged
1.45 x 10'2 feet per day. As previously mentioned, the average
value was calculated using a geometric mean.
The hydraulic gradient in the soil unit, based on the January 27,
1993, water level data, varies from 0.021 to 0.1 feet per foot
and averages 0.044 feet per foot. Using an average horizontal
hydraulic conductivity of 1.07 feet per dfcy, an average hydraulic
gradient of 0.044 feet per foot, and an average effective
porosity of 0.20 (typical for silty material), the average
horizontal groundwater seepage velocity for the soil aquifer is
0.24 feet per day.
The hydraulic gradient in the rock unit, based on the January 27,
1993, water level data, varies from 0.008 to 0.055 feet per foot
and averages 0.024 feet per foot. Using an average horizontal
hydraulic conductivity of 1.7 feet per day, an average hydraulic
gradient of 0.024 feet per foot, and an effective porosity of
0.05 (typical for highly weathered gabbro), the average seepage
velocity for the upper rock unit is 0.82 feet per day.
5.3 Nature and Extent of Contamination
Environmental contamination at the Site can be summarized as
follows :
Contamination. Sixteen ( 16 ) groundwater samples
from temporary wells were collected and analyzed for selected
parameters, prior to the installation of permanent monitoring
wells. Ten (10) permanent monitoring wells were installed during
the second phase of field work and were sampled and analyzed for
all target compound list /target analyte list (TCL/TAL)
parameters, along with three (3) previously existing monitoring
wells and four (4) private wells (July 1992). Six (6) additional
wells were installed during the third phase of field work
(December 1992 to January 1993). All sixteen (16) permanent
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Record of Decision
Rutledge Property Site
Paoe 14
monitoring wells were then sampled and analyzed for all TCL/TAL
parameters, along with the three (3) previously existing
monitoring wells and the four (4) private wells (January 1993).
Four (4) contaminants of concern (COCs), trichloroethene (TCE),
1,2-dichloroethene, vinyl chloride, and manganese, were detected
in the groundwater. These COCs were determined in the Baseline
Risk Assessment which is described below in Section 6.0.
TCE was the most common volatile organic contaminant as it was
detected in three (3) groundwater samples. 1,2-dichloroethene
was also detected in two (2) groundwater samples. The highest
volatile organic contaminant detected was TCE at 84,000
micrograms/ liter (^g/1), which is well above the maximum
contaminant level (MCL) of 5 A*g/l for this contaminant. The
highest detection level of 1,2-dichloroethene was 1200 A*g/l,
which is also well above its MCL of 70 /jg/1. Vinyl chloride was
detected at 26 Atg/1, which exceeds its MCL of 2 /*g/l, and the
highest detection for manganese was 3600 j*g/l, which greatly
exceeds the risk-based cleanup level of 200
Due to the fact that very low levels of Site-related
contamination were detected in the private wells ( Figure 3 ) ,
further evaluation of the construction characteristics of the
private wells will be required in the remedial design. The
primary private wells of concern are PW-03 and PW-04. Two
off -site private wells, PW-01 and PW-02, may also be studied.
If the screened depths of these private wells exceed the screened
depths of the on-site monitoring wells, additional monitoring
wells may be required. These additional monitoring wells will be
used to fully demonstrate that there is no Site related aquifer
contamination, at unacceptable risk levels, at the deeper
screened depths.
Surface and Subsurface Soil Contamination. A total of sixty-
five (65) soil samples were collected and analyzed for all
TCL/TAL parameters. There were no contaminants of concern as
determined in the Baseline Risk Assessment. A further discussion
of the Baseline Risk Assessment is described below in Section
6.0.
No volatile organic contaminants were detected in the surface
soil samples, however several volatile organic contaminants were
detected in the subsurface soil samples. The highest of these
was acetone, up to 2.2 milligrams/kilogram (mg/kg) estimated,
which was also found in a background sample. Several semi-
volatile organic contaminants were detected in the surface soil
samples, but only one was detected in a single subsurface soil
sample. All detected levels were below 1 mg/kg, however. A few
pesticides and polychlorinated biphenyls (PCBs) were detected at
very low levels, all were well below 1.0 mg/kg, in a few surface
and/or subsurface soil samples.
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5 9 0012
Record of Decision
Rutledge Property Site
Paoe 15
Several metals were detected in the surface and subsurface soil
samples at levels greater than two (2) times background, however
these levels were only found in a few samples. The remaining
sample locations in which these same metals were detected were
primarily below two (2) times background levels.
Manganese was detected in the surface soil samples and ranged
from 110 mg/kg to 4500 mg/kg. However, background surface soil
samples ranged from 370 mg/kg to 5900 mg/kg. The highest level
detected for lead was 340 mg/kg (estimated) in a surface soil
sample and 99 mg/kg (estimated) and 150 mg/kg (estimated, in a
duplicate of the same sample) in a subsurface soil sample. Zinc
was detected in the surface soil samples significantly above
background at 530 mg/kg.
Due to a concern over the high variance of manganese levels in
the surface soil background samples, additional sample(s) will be
collected during the remedial design phase to confirm that this
variance is consistent with the environmental setting.
Surface Water Contamination. Seven (7) surface water samples
from the unnamed stream and drainage ditch, and from inside the
72-inch drain, were collected and analyzed for all TCL/TAL
parameters. Surface water run-off from the Rock Hill Mall and
Cherry Road flow through the 72-inch drain and the unnamed
stream. There were no contaminants of concern as determined in
the Baseline Risk Assessment. A further discussion of the
Baseline Risk Assessment is described below in Section €.0.
No semi-volatile organic contaminants, pesticides, or PCBs were
detected in any of the samples. A few volatile organic
contaminants were detected in all of the samples, though a .
specific contaminant may have been detected in just one sample.
The highest level detected, Tetrachloroethene at 65 ug/1, was
from the background sample collected from inside the 72-inch
drain. This same contaminant was also detected further
downstream at lower concentrations. Because these contaminants
were detected in the "background" sample, additional surface
water sample(s) will be collected during the remedial design
phase to determine if this background sample is representative of
true background conditions. Several metals were also detected,
but were primarily found at less than two times background or at
levels representative of naturally occurring levels for this
area.
Sediment Contamination. Seven (7) sediment samples from the
unnamed stream and drainage ditch, and from inside the 72-inch
drain, in the same locations as the surface water samples, were
collected and analyzed for all TCL/TAL parameters. There were no
contaminants of concern as determined in the Baseline Risk
Assessment. A further discussion of the Baseline Risk Assessment
is described below in Section 6.0.
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Record of Decision
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Three (3) volatile organic contaminants were detected in three
(3) of the sediment samples. Tetrachloroethene was detected in
the background sample at 0.120 mg/kg, which was the highest
detected concentration, though it was also detected further
downstream. Because these contaminants were detected in the
background sample, additional sediment sample(s) will be
collected during the remedial design to determine if this
background sample is representative of true background
conditions.
Semi-volatile organic contaminants were detected in all of the
samples, with the highest levels found in sediment sample SO-03.
Fluoranthene at 4.8 mg/kg was the highest contaminant detected.
Most of the semi-volatile organic contaminants were also detected
at significant levels in the background sample. Metals were
detected in the samples. The maximum detected concentration was
lead at an estimated value of 0.58 mg/kg. The remaining metals
detected were primarily less than two times background.
6.0 SUMMARY OF SITE RISKS
A Baseline Risk Assessment was conducted to evaluate the risks
present at the Site to human health and the environment, under
present day conditions and under assumed future use conditions.
The purpose of a Baseline Risk Assessment is to provide a basis
for taking action and to identify the contaminants and the
exposure pathways that need to be addressed by the remedial
action. It serves as an indication of the risks posed by the
Site if no action were to be taken.
This section of the ROD contains a brief summary of the results
of the Baseline Risk Assessment conducted for the Site. The .Site
land use is currently commercial. There is, however, the
potential for part of the Site to become residential in a future
use scenario, and that a future resident potentially could
install a private well for potable use. This is based on the
fact that there are nearby residential areas adjacent to the
Site, and that some of these residents use groundwater as a
potable source of water.
Carcinogenic risk and noncarcinogenic Hazard Index (HI) ratios
were calculated for both the current land use scenario, with
residents near the Site (Site visitor), as well as on-site
workers, and the potential future land use scenario, which is
residential. The Baseline Risk Assessment determined that the
total cancer risk for the current Site visitor scenario is
3.34 x 10~6, and that the total cancer risk for the current on-
site worker scenario is 2.05 x 10~*. These risk levels only
slightly exceed the lower target level of 1 x 10"6, but is still
well within EPA's acceptable risk range of 1 x IQ~* to 1 x 10~*.
The Site, therefore, does not pose an unacceptable cancer risk
under the current exposure scenario. The total HI for the
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current Site visitor scenario is 0.31 and for the current on-site
worker scenario is 0.26. These His are below any level of
concern for noncarcinogens (1.0) and indicate that the Site does
not pose an unacceptable non-carcinogenic risk under the current
exposure scenario. Therefore, there is no unacceptable current
risk at the Site.
The Baseline Risk Assessment also determined that the total
cancer risk for the future Site residential scenario was
2.63 x 10'2. This risk level is not within EPA's acceptable risk
range (1 x 10'* to 1 x 10'6). The HI for the future Site
residential scenario was 400 for an adult and 950 for a child;
these levels exceed the acceptable HI of 1.0. The carcinogenic
and non-carcinogenic risks are attributable to the ingestion of
groundwater. No substantial risk to wildlife or the environment
was found to exist under present conditions or future conditions.
The Baseline Risk Assessment concluded that the surface soils,
the surface water, and the sediments at the Site are not media of
concern. During the FS, it was determined that the subsurface
soil was not a media of concern. The Baseline Risk Assessment
determined that the groundwater was the only media posing an
unacceptable level of risk to human health or the environment.
The actual or threatened releases of hazardous substances from
this Site, if not addressed by implementing the response action
selected in this Record of Decision, may present an imminent and
substantial endangerment to public welfare or the environment.
6.1 Contaminants of Concern
Data collected during the RI were evaluated in the Baseline Risk
Assessment. Contaminants were not included in the Baseline Risk
Assessment evaluation if any of the following criteria applied:
* If an inorganic compound or element, it was not
detected at or above twice the background
concentration.
* If an inorganic compound or element, it was detected at
low concentrations, had very low toxicity, and was
judged to be naturally occurring.
* The sampling data included analytical results flagged
as "N" (presumptive evidence) or "R" (not usable).
The results of the Baseline Risk Assessment concluded that the
only medium of concern was the groundwater, and that the
contaminants of concern were TCE, l,2-dichloroethenef vinyl
chloride, and manganese. Levels of the 1,2-dichloroethene ranged
from non-detect (the detection limit was normally 0.010 mg/1) to
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1200 fjg/I. TCE ranged from non-detect to 84,000 A*g/l. Vinyl
chloride levels ranged from non-detect to 26 pg/1, and manganese
levels ranged from non-detect to 3/600
For each contaminant of concern, exposure point concentrations
were determined in the Baseline Risk Assessment. The upper
ninety-five percent (95%) confidence limit of the arithmetic mean
of all detections was used, unless it exceeded the maximum
detected concentration. If this occurred, then the maximum
detected concentration was used. The exposure point
concentrations calculated in the Baseline Risk Assessment for
groundwater were 434 fjq/1 for 1,2-dichloroethene, 84,000 /*g/l for
TCE, 26 vg/1 for vinyl chloride, and 3600 /*g/l for manganese.
6 . 2 Exposure Assessment
The Site land use is currently commercial. There is, however,
the potential for part of the Site to become residential in a
future use scenario, and that a future resident potentially could
install a private well for potable use. This is based on the
fact that there are nearby residential areas adjacent to the
Site, and that some of these residents use groundwater as a
potable source of water. In addition, therp are other potable
wells within a half-mile radius of the Site. Municipal water,
however, is available to the area. The Baseline Risk Assessment
determined that the population that could potentially be exposed
to Site contaminants would be potential future on- site residents.
Based on this information, the Baseline Risk Assessment
determined that the reasonable exposure pathways consist of
ingestion of chemicals in contaminated groundwater and inhalation
of chemicals volatilized during non- ingestion domestic water use,
e.g. s hower ing .
The following future use scenario exposure assumptions were usedi
for exposure to the non-carcinogens by an adult resident, it was
assumed that the adult resident would ingest two (2) liters per
day of groundwater for a twenty-four (24) year period. It was
assumed that a child would be exposed for six (6) years, and
would only consume 1 liter per day of water. For carcinogens,
the time period used was seventy (70) years. An inhalation rate
of 0.83 cubic meter/hour was assumed for a 15-minute shower
duration .
6.3 Toxicitv Assessment of Contaminants
The purpose of the toxicity assessment is to assign toxicity
values (criteria) to each chemical evaluated in the Baseline Risk
Assessment. The toxicity values are used in combination with the
estimated doses to which a human could be exposed (as discussed
in the Risk Characterization subsection of the Baseline Risk
Assessment) to evaluate the potential human health risks
associated with each contaminant. Human health criteria
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developed by EPA (cancer slope factors and non-cancer reference
doses) were either obtained from the Integrated Risk Information
System (IRIS, 1993) or the 1992 Health Effects Assessment Summary
Tables (HEAST; EPA/ 1992). In some cases the Environmental
Criteria Assessment Office (ECAO, 1992) was contacted to obtain
criteria for chemicals which were not listed in IRIS or HEAST.
EPA has developed slope factors (SF) to estimate excess lifetime
cancer risks associated with exposure to potentially carcinogenic
contaminants of concern. Sfs, which are expressed as risk per
milligram per kilogram of dose, are multiplied by the estimated
intake of a potential carcinogen, in mg/kg-day, to provide an
upper-bound estimate of the excess lifetime cancer risk
associated with exposure at that intake level.
The term "upper bound" reflects the conservative estimate of the
risks calculated from the SF. Use of this approach makes
underestimation of the actual cancer risk highly unlikely. Slope
factors are derived from the results of human epidemiological
studies or chronic animal bioassay data to which mathematical
extrapolation from high to low dose, and from animal to human
dose, has been applied, and statistics to account for uncertainty
have been applied (e.g. to account for the use of animal data to
predict effects on humans). \
EPA has also developed reference doses (RfDs) to establish the
potential for adverse human health effects from exposure to the
contaminants of concern exhibiting noncarcinogenic effects.
RfDs, which are expressed in units of mg/kg-day, are estimates of
daily exposure levels for humans, including sensitive
subpopulations, that are likely to be without risk of adverse
effect. Estimated intakes of contaminants of concern from
environmental media (e.g. the amount of chemicals of concern
ingested from contaminated drinking water) can be compared to the
RfD. RfDs are derived from human epidemiological studies or
animal studies to which uncertainty factors have been applied
(e.g., to account for the use of animal data to predict effects
on humans).
Carcinogenic contaminants are classified according to EPA's
weight-of-evidence system. This classification scheme is
summarized below:
Group A: Known human carcinogen.
Group Bl: Probable human carcinogen, based on limited human
epidemiological evidence.
Group B2: Probable human carcinogen, based on inadequate
human epidemiological evidence but sufficient
evidence of carcinogenicity in animals.
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Group C: Possible human carcinogen, limited evidence of
carcinogenicity in animals.
Group D: Not classifiable due to insufficient data.
Group E: Not a human carcinogen, based on adequate
animal studies and/or human epidemiological
evidence.
TCE is classified as a B2 carcinogen. The oral slope factor used
for TCE was 1.10 x 10~2 and the inhalation slope factor was
1.70 x 10"2 (the reference used was Dollarhide, 1992). The oral
slope factor used for vinyl chloride was 1.90 and the inhalation
slope factor was 3.00 x 10'1 (HEAST, 1992). The reference dose
used for 1,2-dichloroethene, oral only, was 1.00 x 10"2 (HEAST,
1992). The reference dose used for TCE, oral only, was
6.00 x 10'3 (Dollarhide, 1992). The reference dose for
manganese, oral, was 5.00 x 10~3 (IRIS, 1993).
6.4 Risk Characterization
The final step of the Baseline Risk Assessment, the generation of
numerical estimates of risk, was accomplished by integrating the
exposure and toxicity information.
For a carcinogen, risks are estimated as the incremental
probability of an individual developing cancer over a lifetime as
a result of exposure to the carcinogen. Excess lifetime cancer
risk is calculated from the following equations
Risk = GDI x SF
where:
Risk = a unit-less probability (e.g. 2 x 10~s) of an
individual developing cancer,
GDI = chronic daily intake averaged over seventy (70)
years (mg/kg-day), and
SF - slope-factor, expressed as (mg/kg-day)'1
These risks are probabilities that are generally expressed in
scientific notation (e.g. 1 x 10~6). An excess lifetime cancer
risk of 1 x 10'6 indicates that, as a reasonable m»»
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The potential for noncarcinogenic effects is evaluated by
comparing an exposure level over a specified time period (e.g.,
life-time) with a reference dose derived for a similar exposure
period. The ratio of exposure to toxicity is called a hazard
quotient (HQ). An HQ less than 1 indicates that a receptor's
dose of a single contaminant is less than the RfD, and that the
toxic noncarcinogenic effects from that chemical are unlikely.
By adding the Hgs for all contaminants of concern that affect the
same target organ (e.g. liver) within a medium or across all
media to which a given population may reasonably be exposed, the
Hazard Index (HI) is generated. An HI less than 1 indicates
that, based on the sum of all Hgs from different contaminants and
exposure routes, toxic noncarcinogenic effects from all
contaminants are unlikely.
The HQ is calculated as follows:
Non-cancer HQ = CDI/RfD
where:
GDI = Chronic Daily Intake
RfD = reference dose; and
the
GDI and RfD are expressed in the same units and represent
same period (i.e., chronic, subchronic, or short-term).
It was determined in the Baseline Risk Assessment that there is
no current unacceptable carcinogenic or non-carcinogenic risk at
the Site.
Under the future use scenario, the lifetime carcinogenic risk .
associated with all the exposure pathways is estimated to be
1.47 x 10-2 for an adult and 1.16 x 10'a for a child. The overall
carcinogenic risk for a future resident is 2.63 x 10~2. The
estimated lifetime carcinogenic risk is due primarily to the
potential ingestion and inhalation of contaminants in the
groundwater.
Under the future use scenario, the lifetime noncarcinogenic risk,
associated with all the exposure pathways is estimated to be HI «
400 for an adult resident, and 950 for a child resident. This
noncarcinogenic risk is due to the potential ingestion of
contaminants in the groundwater.
Because the land use adjacent to the Site is zoned for both
residential and commercial use, the ecological communities
surrounding the Site have been altered from their natural state.
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No state or federally designated endangered or threatened species
are found at the Site.
The actual or threatened releases of hazardous substances from
this Site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
7.0 DESCRIPTION OF GRODNDWATER REMEDIAL ALTERNATIVES
The FS considered a wide variety of general response actions and
technologies for remediating groundwater. No other media at the
Site require remedial action.
Based on the FS, Baseline Risk Assessment, and Applicable or
Relevant and Appropriate Requirements (ARARs), the remedial
action objectives (RAOs) listed below were established for the
Site. Alternatives were developed with the goal of attaining
these objectives:
• Reduce to acceptable levels the excess risk to humans
and environmental receptors associated with the medium
and contaminants of concern at the Site. This will be
accomplished by reducing the concentrations of
contaminants that result in excess risk to human health
and the environment.
• Reduce the potential for ingesting contaminants in the
groundwater or inhaling volatilized contaminants from
the groundwater from the Site where z
• Carcinogen concentrations are above Federal or-
State standards, or in the absence of standards,
are above levels that would exceed an acceptable
cancer risk range of 1 x 10"* ta 1 x 10"6;
• Noncarcinogen concentrations are above Federal or
State standards, or in the absence of standards,
are above levels that would exceed an acceptable
Hazard Index (HI) of 1.0.
Technologies considered potentially applicable to groundwater
contamination were further evaluated based upon their
effectiveness and implement ability. Listed below are those
alternatives which passed this final screening, and are proposed
for groundwater remediation.
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Alternative Is No Action
Alternative 2: Limited Action, institutional controls
Alternative 3: Groundwater extraction, treatment, and surface
water discharge
Alternative 4: Groundwater extraction, POTW discharge
Each of the four (4) alternatives is discussed below.
Alternatives 1 and 2 will not meet the remediation goals
presented in Section 9.1.3 of this ROD. Alternatives 3 and 4
will meet the remediation goals through treatment.
"O&M costs" refer to the costs of operating and maintaining the
treatment described in the alternative. The treatment period for
Alternatives 3 & 4 was assumed to be thirty (30) years.
Groundwater monitoring for Alternatives 1 & 2 was assumed for the
purposes of projecting costs, to be for the five (5) year reviews
only. Monitoring for Alternatives 3 & 4 was assumed, for the
purpose of projecting costs, to be once a week for the influent
and effluent for thirty (30) years and for the twenty (20)
monitoring wells, once a quarter for the first five (5) years and
semi-annually for the next twenty-five (25) years. O&M costs
were calculated using a seven percent (7%) discount rate per
year.
Certain sections of Federal and State environmental statutes (see
Section 9) are applicable, or relevant and appropriate
requirements (ARARs) for the Site, and must be met by the
selected remedial alternative or waived with justification
provided as to why that ARAR was waived. Site groundwater is
classified by South Carolina as Class GB (SC Water
Classifications and Standards, Regulation 61-68), and by EPA as
Class IIA (Guidelines for Ground Water Use and Classification,
EPA Ground Water Protection Strategy, US EPA 1986).
Alternatives 1 and 2 would not meet the relevant and appropriate
ARARs identified in Section 9, concerning groundwater as a
potable water source. The National Primary and Secondary
Drinking Water Standards, promulgated under 40 C.F.R. Parts 141-
143, and the State of South Carolina Primary Drinking Water
Regulations, SC Reg. 61-58, would not be met because Alternatives
1 and 2 do not involve treatment of the contaminated groundwater,
and contaminants in the Site groundwater violate the MCLs
specified in these Federal and State regulations. These ARARs
would be met by Alternatives 3 and 4.
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In addition, the CERCLA preference for treatment to reduce the
toxicity, mobility, or volume of the contaminants, wherever
possible, would not be satisfied by Alternatives 1 or 2 since no
treatment is involved. The remaining Alternatives, 3 and 4,
would achieve these standards, and would also meet the CERCLA
preference for treatment, since they are active treatment
technologies.
Alternative 3 would be subject to the following ARARs or criteria
to be considered (TBCs) because of the on-site treatment plant
aspect of the alternative: National Ambient Air Quality
Standards (NAAQS), 40 C.F.R. Part 50; National Emissions
Standards for Hazardous Air Pollutants (NESHAPs), 40 C.F.R. Part
61, TBC; South Carolina Ambient Air Quality Standards (S.C. Reg.
R61-62). Alternatives 3 and 4 would both be subject to the South
Carolina Well Standards and Regulations, (R61-71), since both
alternatives involve the installation of extraction wells.
Other ARARs for Alternative 3 include the Clean Water Act
Pretreatment Standards (40 C.F.R. Parts 122, 125, 129, 133, and
136), and the South Carolina NPOES Discharge Limitations for
treated water (R61-9), if discharge is to a stream.
T
The treatment system related to Alternative 3, may produce a
sludge, and possibly spent carbon, that may be subject to the
identification (40 C.F.R. Part 261, SCHWMR 61-79.261),
transportation (40 C.F.R. Part 262, SCHWMR 61-79.262),
manifestation (40 C.F.R. Part 263, SCHWMR 61-79.263), and land
disposal restriction (40 C.F.R. Part 268, SCHWMR 61-79.268)
requirements of the Solid Waste Disposal Act, as amended by the
Resource Conservation and Recovery Act (RCRA) 42 U.S.C. SS 6901
et seq., if the resulting sludge is determined to be a RCRA
hazardous waste.
7.1 Alternative It No Action
Under the no action alternative, the Site is left "as is" and no
funds are expended for the cleanup or control of the contaminated
groundwater. Monitoring of contaminants of concern and their
degradation contaminants, not including their innocuous
compounds, would be included as part of this alternative.
However, the costs associated with the monitoring are not
considered capital costs or O&M costs. Monitoring of the
contaminants would involve the collection and analysis of
groundwater samples from existing Site monitoring wells, at least
every five (5) years, to allow tracking of contaminant
concentrations and to monitor the speed, direction, and extent of
contaminant migration. The exact number and location of wells to
be sampled would be determined during remedial design. In
addition, the need for any additional monitoring wells, which may
be sampled for additional contaminants, would be determined
during the remedial design/remedial action phases. These wells
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may be added if it is determined later that groundwater
contamination has left the Site property or if further
characterization of the Site is needed. Future risks to persons
living on and near the Site will remain. Because hazardous
contaminants would remain on-site, five (5) year reviews would be
required under Section 121(c) of CERCLA, 42 U.S.C. S 9621(c).
Alternative 1: Capital Costs $ 0.00
Annual O&M Costs 0.00
Total Present Worth Cost: $ 0.00
The cost estimate for sampling the monitoring wells was
approximately $ 181,500.00.
7.2 Alternative 2t Limited Action. Institutional Controls
Under this alternative, institutional controls would be
implemented to restrict the withdrawal and use of contaminated
groundwater on-site. This alternative would also include
monitoring of the contaminants, as described in Alternative 1.
The institutional controls that would apply to the Site are deed
restrictions and well permit restrictions. Deed restrictions
would prevent future use of the contaminated groundwater for
purposes such as potable water supply or irrigation of edible
garden vegetables. These restrictions would be written into the
property deeds to inform future property owners of the
possibility of contaminated groundwater beneath the property.
Permit restrictions issued by the State of South Carolina would
restrict all well drilling permits issued for new wells on
properties that may draw water from the contaminated groundwater
for potable use or for the irrigation of edible garden
vegetables.
Alternative 2s Capital Costs $ 0.00
Annual O&M Costs 35,750.00
Total Present Worth Costs $ 181,456.00
7.3 Alternative 3s Groundwater Extraction. Tr«*»f™«*"^f
Surface Water Discharge
Alternative 3 involves placing extraction wells throughout the
contaminated groundwater, with overlapping cones of influence, to
actively remediate the aquifer. It would involve installing
extraction wells and removing contaminated water from the
aquifer, both horizontally and vertically, and treating the
extracted groundwater. The groundwater would be extracted until
the performance standards are met. This will also prevent
further migration of the contaminated groundwater. In addition,
the contaminated groundwater near the monitoring wells that had
the highest concentration of contaminants, MW-03, shall be
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remediated as quickly as possible, to prevent the migration of
the contaminated groundwater further into the bedrock, as well
as, prevent migration of the contaminated groundwater to other
parts of the Site. This may include installing several
extraction wells in this particular area, including into the
bedrock to the depth of the contamination. After extraction, the
water would go to an on-site treatment system that may include
neutralization, oxidation, sedimentation, filtration, and/or
carbon adsorption. The "clean" water from the treatment system
would then be discharged to the surface water. The groundwater
would be treated to remove inorganic and organic contaminants.
Modeling conducted during the RI, suggested that the pumping rate
would be about fifteen (15) to twenty (20) galIons/minute using
about 1-2 extraction wells for a period of about thirty (30)
years. The actual number of wells and pumping rates shall be
determined during the remedial design. However, in order to
quickly remove the contaminated groundwater, additional
extraction wells may need to be installed, especially near the
monitoring wells where the highest contamination was detected
(MW-03).
In addition to groundwater extraction and treatment,
institutional controls, as those described in Alternative 2,
would be implemented to limit current and future use of
groundwater until the performance standards are continuously
achieved. Groundwater monitoring will be conducted a minimum of
once a year, during the time of the year when the highest
contamination was detected during the RI (July or August).
Monitoring wells and possibly extraction wells, shall be sampled
and analyzed for all contaminants of concern and their
degradation contaminants, not including their innocuous
compounds, as determined during the remedial design. The amount
and frequency of sampling and contaminants to be sampled for,
shall be modified, if required by EPA. The influent and effluent
of the treatment system will be sampled as determined during the
remedial design/remedial action.
The cost below are approximate, and an average of the costs
determined for one and two extraction well scenarios.
Alternative 3: Capital Costs $ 900,000.00
Annual O&M Cost: 348,000.00
Total Present Worth Cost: $ 4,800,000.00
7.4 Alternative 4: Groundwater Extraction, POTW discharge
Alternative 4 involves placing extraction wells throughout the
contaminated groundwater, with overlapping cones of influence, to
actively remediate the aquifer as was described in Alternative 3.
This alternative would involve installing extraction wells and
removing contaminated water from the aquifer, both horizontally
and vertically. The groundwater would be extracted until the
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performance standards are met. This will also prevent further
migration of the contaminated groundwater. In addition, the
contaminated groundwater near the monitoring wells that had the
highest concentration of contaminants, MW-03, shall be remediated
as quickly as possible, to prevent the migration of the
contaminated groundwater further into the bedrock, as well as,
prevent migration of the contaminated groundwater to other parts
of the Site. This may include installing several extraction
wells in this particular area, including into the bedrock to the
depth of the contamination. Modeling conducted during the RI
suggested that the pumping rate would be about fifteen (15) to
twenty (20) galIons/minute using about 1-2 extraction wells for
a period of about thirty (30) years. The actual number of wells
and pumping rates shall be determined during the remedial design.
However, in order to quickly remove the contaminated groundwater,
additional extraction wells may need to be installed, especially
near the monitoring wells where the highest contamination was
detected (MW-03). As opposed to Alternative 3, this alternative
would discharge the contaminants, via sewer line, to the publicly
owned treatment works (POTW). No pretreatment is anticipated
before the contaminated groundwater is discharged to the sewer
line. In addition to groundwater extraction, institutional
controls, as described in Alternative 2, would be implemented to
limit current and future use of groundwater until the performance
standards are continuously achieved. Also, contaminant
monitoring would be performed to monitor the effectiveness of the
alternative in achieving the remediation goals, as described in
Alternative 3.
The cost below are approximate, and an average of the costs
determined during the FS, for one and two extraction well
scenarios.
Alternative 4: Capital Cost: $ 280,000.00
Annual O&M Cost: 225,000.00
Total Present Worth Cost: $ 2,300,000.00
8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES FOR
GROUNDWATER
The four (4) alternatives for groundwater remediation were
evaluated based upon the nine (9) criteria set forth in
40 C.F.R. S 300.430(e)(9) of the NCP. In the sections which
follow, brief summaries of how the alternatives were judged
against these nine (9) criteria are presented. In addition, the
sections are prefaced by brief descriptions of the criteria.
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8.1 Groundwater Remediation Alternatives
8.1.1 Threshold Criteria
Two (2) threshold criteria must be achieved by a remedial
alternative before it can be selected.
1. Overall protection of human health and the environment
addresses whether the alternative will adequately protect human
health and the environment from the risks posed by the Site.
Included is an assessment of how and whether the risks will be
properly eliminated, reduced, or controlled through treatment,
engineering controls, and/or institutional controls.
Alternative 1, No Action, will not provide overall protection of
human health and the environment, since contaminated groundwater
would be left on-site. Alternative 2, Limited Action
(Institutional Controls), would achieve limited protection of
human health from the contaminants by preventing exposure to
affected groundwater through deed restrictions that prohibit
future use of groundwater under the Site, but would not be
protective of the environment, nor off-site residents if the
groundwater contamination moved off-site. Alternatives 3 6 4,
Groundwater Extraction will provide overall protection of human
health and the environment through extraction of contaminated
groundwater and either on-site or off-site treatment of the
groundwater.
2. Compliance with applicable or relevant and appropriate
requirements (ARARs) addresses whether an alternative will meet
all of the requirements of Federal and State environmental laws
and regulations, as well as other laws, and/or justifies a waiver
from an ARAR. The specific ARARs which will govern the selected
remedy are listed and described in Section 9.0, the Selected •
Remedy.
The evaluation of the ability of the proposed alternatives to
comply with ARARs included a discussion of ARARs presented in
Section 7.0. Alternative 1, No Action, and Alternative 2,
Limited Action, Institutional Controls would not meet ARARs,
since contaminated groundwater is left on-site. Alternatives 3 &
4, Groundwater Extraction, are expected to meet ARARs, since they
are active treatment technologies.
8.1.2 Primary Balancing Criteria
Five (5) criteria were used to weigh the strengths and weaknesses
of the alternatives, and were used to select one of the four (4)
alternatives. Assuming satisfaction of the threshold criteria,
these five (5) criteria are EPA's main considerations in
selecting an alternative as the remedy.
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1. Long term effectiveness and permanence refers to the ability
of the alternative to maintain reliable protection of human
health and the environment over time, once the remediation goals
have been met. Alternative 1, No Action, and Alternative 2,
Limited Action. Institutional Controls, will not provide long
term effectiveness, since the remediation goals will not be met.
Alternatives 3 & 4, Groundwater Extraction, will achieve
permanent reduction in contaminants through the extraction and
treatment of the contaminated groundwater, and therefore, be
effective in the long-term.
addresses the anticipated performance of the treatment
technologies that an alternative may employ. The 1986 amendments
to CERCLA, the Superfund Amendments and Reauthorization Act
(SARA), direct that, when possible, EPA should choose a treatment
process that permanently reduces the level of toxicity of Site
contaminants, eliminates or reduces their migration away from the
Site, and/or reduces their volume on a Site.
Alternative 1, No Action, would not achieve a reduction in the
toxicity, mobility, or volume of the contaminants since the
alternative is considered complete at this time.
Alternative 2, Limited Action, Institutional Controls, is not a
treatment technology and, therefore, does not satisfy the
statutory preference for selecting remedial actions that employ
treatment technologies that permanently and significantly reduce
the toxicity, mobility, or volume of the contaminants.
Alternatives 3 and 4, GroundwaterExtraction. use active
treatment technologies to permanently reduce the toxicity,
mobility, and volume of the contaminated groundwater.
3. Short-term effectiveness refers to the potential for adverse
effects to human health or the environment posed by
implementation of the remedy.
Alternatives 1 & 2, No Action and T.imifce4 Action. Institutional
Controls, afford the greatest level of short-term protection
because they present the least risk to remedial workers, the
community, and the environment, since these alternatives do not
involve a remedial action. The other Alternatives, 3 & 4, could
release minimal volatile emissions during extraction well
installation and/or treatment system construction. Standard
construction management techniques would address any potential
short-term fugitive emissions.
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Rutledge Property Site
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4. Imp lenient ab i 11 ty considers the technical and administrative
feasibility of an alternative, including the availability of
materials and services necessary for implementation.
Alternatives 1 & 2, No Action and Limited Action. Institutional
Controls, will be the easiest to implement since they do not
involve the construction of a treatment system.
The construction technologies required to implement Alternatives
3 & 4, Groundwater Extraction, are well established and very
reliable. The extraction and treatment systems would have
additional operational requirements compared to Alternatives 1
and 2, because of the complexities of the continuous operation of
a groundwater extraction system, the operation of a multi-
component treatment system, and requisite discharge limits on the
resulting treated effluent. The extraction and treatment system
would be more difficult to operate and maintain than options
proposed under Alternatives 1 & 2.
The technical implementability of all the evaluated alternatives
is reasonable. Technologies required to implement the
alternatives are readily available and proven at full-scale in
similar field efforts. Discharge permits or at least the
criteria, may need to be obtained for the implementation of
Alternative 3, since it includes an on-site treatment system
which may discharge to the unnamed stream.
5. Cost includes both the capital (investment) costs to
implement an alternative, plus the long-term Q&M expenditures
applied over a projected period of operation. Alternative 1 has
no costs since it is completed. Alternative 2 is lower in cost
than Alternatives 3 and 4, since it involves only the costs of
monitoring the groundwater, implementing deed and well
restrictions. Alternative 4 is less than Alternative 3.
8.1.3 Modifying Criteria
State acceptance and community acceptance are two (2) additional
criteria that are considered in selecting a remedy, once public
comment has been received on the Proposed Plan.
1. State acceptancet The State of South Carolina concurs with
this remedy. A copy of South Carolina's letter of concurrence is
attached (Appendix B) to this ROD.
2. Community acceptance was indicated by the verbal comments
received at the Rutledge Property Site Proposed Plan public
meeting, held on March 1, 1994. The public comment period opened
on February 22, 1994, and closed on April 25, 1994 (after a
thirty (30) day extension). Written comments received concerning
the Site, and those comments expressed at the public meeting, are
addressed in the Responsiveness Summary attached as Appendix A to
this ROD.
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Record of Decision
Rutledge Property Site
Page 31
9.0 THE SELECTED REMEDY
9.1 Groundwater Remediation
Based upon consideration of the requirements of CERCLA/ the NCP,
the detailed analysis of the four (4) alternatives and public and
state comments, EPA has selected a remedy that addresses
groundwater contamination at this Site.
The selected remedy for the Site is:
Alternative 4, Groundwater Extraction, POTW discharge
Total present worth cost of the selected remedy is approximatelyt
$ 2,300,000.00
This remedy consists of groundwater extraction of contaminated
groundwater, followed by discharge to the POTW. The following
subsections describe this remedy component in detail, provide the
criteria (ARARs and TBC material) which shall apply, and
establish the performance standards for implementation.
9.1.1 Description
This remedy component consists of the design, construction and
operation of a groundwater extraction system, and development and
implementation of a Site monitoring plan to monitor the system's
performance. The groundwater alternative specified below shall
be continued until the performance standards listed in Section
9.1.3. are achieved, at a minimum, in all of the monitoring and
extraction wells that are associated with the Site.
This alternative involves placing extraction wells throughout the
entire area of contaminated groundwater, with overlapping cones
of influence, to actively remediate the aquifer.. It would
involve -installing extraction wells and removing contaminated
water from the aquifer, both horizontally and vertically. The
groundwater would be extracted until the performance standards
are met continuously. This will also prevent further migration
of the contaminated groundwater. In addition, the contaminated
groundwater near the monitoring wells that had the highest
concentration of contaminants, MW-03, shall be remediated as
quickly as possible, to prevent the migration of the contaminated
groundwater further into the bedrock, as well as, prevent
migration of the contaminated groundwater to other parts of the
Site. This may include installing several extraction wells in
this particular area, including into the bedrock to the depth of
the contamination. The actual number of wells, their depths, and
their pumping rates shall be determined during the remedial
design.
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The contaminated groundwater would then be discharged, via sewer
line, to the local POTW. No pretreatment is anticipated before
the contaminated groundwater would be discharged to the sewer
line.
In addition to the process described above, this alternative will
include implementation of all of the institutional controls and
contaminant monitoring requirements described below, thereby
monitoring the effectiveness of the alternative and limiting
future use of groundwater until clean-up goals are achieved.
Institutional controls that would apply to the Site, include deed
restrictions and well permit restrictions. Deed restrictions
would prevent the future use of the contaminated groundwater for
purposes such as potable water supply or irrigation of edible
garden vegetables. These restrictions will be written into the
property deeds to inform future property owners of the
possibility of contaminated groundwater beneath the property.
Permit restrictions, issued by the State of South Carolina, would
restrict all well drilling permits, issued for new wells on the
Site property, that may draw water from the contaminated
groundwater for potable water use or irrigation of edible
vegetables.
Monitoring of contaminants of concern and their degradation
contaminants, not including their innocuous compounds, would be
included as part of this alternative, at a minimum. EPA may
require additional contaminants, including all TCL/TAL
parameters, to be analyzed. Monitoring of the contaminants would
involve the collection and analysis at regular intervals, of
groundwater samples from existing Site monitoring wells, and
possibly extraction wells, to allow tracking of contaminant
concentrations and to monitor the speed, direction, and extent of
contaminant migration. The actual number and location of well
samples, and contaminants to be analyzed for, will be determined
during the remedial design/remedial action phases. Samples will
be collected and analyzed for contaminants of concern and their
degradation contaminants, at a minimum, however, once every year
(at the time of the year in which the highest level of
contamination was detected during the RI, July or August), unless
a different frequency is required by EPA. In addition, the need
for any additional monitoring wells, which may be sampled for
additional contaminants, will be determined during the remedial
design/remedial action phases. These wells may be added if it is
determined later, that groundwater contamination has left the
Site property, or that contamination is significantly above the
clean-up criteria in the outer monitoring wells, as determined by
EPA, or that further characterization of the Site is needed.
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Record of Decision
Rutledge Property Site
Page 33
The vertical extent of groundwater contamination will be
confirmed and/or updated during the remedial design. This may
require that additional monitoring wells, screened at various
depths, be installed. This will be determined by EPA during the
remedial design/remedial action phases. The goal of this
remedial action is to restore groundwater to its beneficial use
as a drinking water source. Based on the information collected
during the RI, and on a careful analysis of all remedial
alternatives/ EPA and the State of South Carolina believe that
the selected groundwater remedy, Alternative 4, will achieve this
goal.
If it is determined, on the basis of the preceding criteria and
the system performance data (after all attempts have been made as
determined by EPA), that certain portions of the aquifer cannot
be restored to their beneficial use, all or some of the following
measures involving long-term management may occur, for an
indefinite period of time, as a modification of the existing
system:
* engineering controls such as physical barriers as
containment measures;
* chemical-specific ARARs will be waived for the cleanup
of those portions of the aquifer based on the technical
impracticability of achieving further contaminant
reduction;
* institutional controls will be provided/maintained to
restrict access to those portions of the aquifer that
remain above remediation goals;
* continued monitoring of specified well locations; and
* periodic re-evaluation of remedial technologies for
groundwater restoration.
The decision to invoke any or all of these measures may be made
during a review of the remedial action, which will occur
minimally at five (5) year intervals in accordance with Section
121(c) of CERCLA, 42 U.S.C. S 9621(c).
9.1.2 Applicable or Relevant and Appropriate Requirements
fARARs1
Applicable Requirements. Groundwater remediation shall comply
with all applicable portions of the following Federal and State
of South Carolina regulations: SC Reg. 61-68, South Carolina
Water Classifications and Standards. These regulations establish
classifications for water use, and set numerical standards for
protecting state waters.
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Rutledge Property Site
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SC Reg. 61-71, South Carolina Well Standards and Regulations,
promulgated under the Safe Drinking Water Act, SC Code of Laws,
1976, as amended. Standards for well construction, location and
abandonment, are established for remedial work at environmental
or hazardous waste sites.
Relevant and Appropriate Requirements. The following regulations
are relevant to groundwater remediation at the Site.
40 C.F.R. Parts 141-143, National Primary and Secondary Drinking
Water Standards, promulgated under the authority of the Clean
Water Act. These regulations establish acceptable mrtylimim levels
of numerous substances in public drinking water supplies, whether
publicly owned or from other sources such as groundwater.
Maximum Contaminant Levels (MCLs) are specifically identified in
40 C.F.R. § 300.430(e)(2)(i)(B) of the NCP as remedial action
objectives for groundwater that are current or potential sources
of drinking water supply. Therefore, MCLs 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.
Criteria "To Be Considered" (TBC^ and Other Guidance. TBC
criteria were utilized and/or established in the Baseline Risk
Assessment and in the FS. Groundwater cleanup standards were
established based on these documents and both are thus considered
TBC.
In the Baseline Risk Assessment, TBC material used included
information concerning toxicity of, and exposure to, Site
contaminants. Sources of such data included the Integrated Risk
Information System (IRIS), Health Effects Assessment Summary
Tables (HEAST), and EPA guidance as specified in the Baseline
Risk Assessment.
In the FS, groundwater concentrations protective of human health
and the environment were calculated based on the Site-specific
risk calculations from the Baseline Risk Assessment. Certain of
these levels were established as remediation goals in cases where
there is no MCL for a particular contaminant. A specific
contaminant for which a health-based goal was established was
manganese. The groundwater remediation goals are established as
performance standards in the Section 9.1.3.
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Record of Decision
Rutledge Property Site
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Other TBC material include the following:
Guidelines for Groundwater Use and Classification. EPA
Groundwater 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 7.0, the groundwater at the Site is
classified by EPA as Class IIB and by South Carolina as Class GB
groundwater, indicating its potential as a source of drinking
water.
Other requirements. As described above in Section 9.1.2,
remedial design often includes the discovery and use of
unforeseeable but necessary requirements. Therefore, during
design of the groundwater component of the selected remedy, EPA
may, through a formal ROD modification process such as an
Explanation of Significant Differences or a ROD Amendment, elect
to designate further ARARs which apply, or are relevant and
appropriate, to groundwater remediation at this Site.
9.1.3 Performance Standards
The standards outlined in this section comprise the performance
standards defining successful implementation of the remedy. The
groundwater remediation goals in Table 1 below shall be the
performance standards for groundwater treatment.
9.2 Monitor Site Groundwater
Monitoring of contaminants of concern and their degradation
contaminants, not including their innocuous compounds, would be
included as part of Alternative 4, as was described above.
Monitoring of the contaminants would involve the collection and
analysis at regular intervals, of groundwater samples from
existing Site monitoring wells, to allow tracking of contaminant
concentrations and to monitor the speed, direction, and extent of
contaminant migration. The number and location of well samples
will be determined during remedial design. Samples will be
collected and analyzed for contaminants of concern and their
degradation contaminants, not including their innocuous
compounds, at a minimum, however, of once per year (during the
time of the year in which the highest level of contamination was
detected during the RI, July or August), unless a different
frequency is approved by EPA. This annual sampling will begin
after one of the following occurs; the signing of a consent
decree, a unilateral administrative order is issued, or a
Statement of Work is issued to an EPA Contractor. In addition,
the need for any additional monitoring wells, which may be
sampled for additional contaminants, will be determined during
the remedial design/remedial action phases. These wells may be
added if it is determined later that groundwater contamination
has left the Site property, or that contamination is
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Rutledge Property Site
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TABLE 1
CONTAMINANT
Volatile Orqanics
1,2 Dichloroethene
Vinyl Chloride
Trichloroethene
Inorganics
Manganese
Maximum
Concentration
Detected (ug/L)
1200
26
84000
I
3600
Remediation
Goal
(ug/L)
2*
5*
200
Maximum Contaminant Level (MCL)
(a) Groundwater samples were analyzed for
1,2 dichloroethene (total). The maximum contaminant
level for 1,2 dichloroethene (cis) was used since it is
more conservative than 1,2 dichloroethene (trans) at
100 ug/L.
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Record of Decision
Rutledge Property Site
Page 37
significantly above the clean-up criteria in the outer monitoring
wells/ as determined by EPA, or if further characterization of
the Site is needed. In addition, on a time frame to be
determined by EPA, and as part of the verification sampling, when
it is believed by EPA that the remedial action is complete, the
monitoring wells and extraction wells shall be sampled for all
TAL/TCL parameters over a period of time to be determined by EPA.
The vertical extent of groundwater contamination will be
confirmed and/or updated during the remedial design.
Other Requirements
Due to the fact that very low levels of Site-related
contamination were detected in the private wells (Figure 3),
further evaluation of the construction characteristics of the
private wells will be required in the remedial design. The
primary private wells of concern are PW-03 and PW-04. Two
off-site private wells, PW-01 and PW-02, may also be studied.
If the screened depths of these private wells exceed the screened
depths of the on-site monitoring wells, additional monitoring
wells may be required. These additional monitoring wells will be
used to fully demonstrate that there is no Site related aquifer
contamination, at levels of concern, at the deeper screened
depths.
Due to a concern over the high variance of manganese levels in
the surface soil background samples, additional sample(s) will be
collected during the remedial design to confirm that this
variance is consistent with the environmental setting.
Because organic contaminants were detected at elevated levels in
the background surface water and sediment samples, additional
surface water and sediment samples, from upstream, will be
collected during the remedial design to determine if this
background sample is representative of true background
conditions.
10.0 STATUTORY DETERMINATIONS
The selected remedy for this Site meets the statutory
requirements set forth at Section 121(b)(l) of CERCLA, 42 U.S.C.
S 9621(b)(l). This section states that the remedy must protect
human health and the environment; meet ARARs (unless waived); be
cost-effective; use permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum
extent practicable; and finally, wherever feasible, employ
treatment to reduce the toxicity, mobility or volume of the
contaminants. The following sections discuss how the remedy
fulfills these requirements.
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Rutledge Property Site
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Protection of human health and the environment: The groundwater
remediation alternative will extract the contaminated groundwater
and discharge it to the local POTW, thereby reducing and
eventually removing the future risks to human health which could
result from ingestion and inhalation of the groundwater. This
remedy would also reduce the potential risk to the environment.
Compliance with ARARst The selected remedy will meet ARARs,
which are listed in Sections 9.1.2 of this ROD.
Cost effectiveness; Among the groundwater alternatives that are
protective of human health and the environment and comply with
all ARARs, the selected alternative is the most cost-effective
choice because it uses a treatment technology to remediate the
contamination in basically the shortest time frame, at a cost
less than the other treatment alternative.
Utilization of permanent solutions * and alternative trea^'ment
technologies or resource recovery technologies to the maximum
extent practicable; The selected remedy represents the use of
treatment for a permanent solution. Among\the alternatives that
are protective of human health and the environment and comply
with all ARARs, EPA and the State of South Carolina have
determined that the selected remedy achieves the best balance of
trade-offs in terms of long-term effectiveness and permanence,
reduction of toxicity/mobility/volume, short-term effectiveness,
implementability, and cost. The selected groundwater action is
more readily implementable than the other treatment alternative
considered and the selected groundwater remediation alternative
will fulfill the preference for treatment as a principal element.
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5 9 0024
APPENDIX A
RESPONSIVENESS SUMMARY
RUTLEDGE PROPERTY SUPERFUND SITE
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5 9 0075
RDTLEDGE PROPERTY SUPERFUND SITE
1. Overview
The U. S. Environmental Protection Agency (EPA) held a public
comment period from February 22, 1994 to March 24, 1994, for
interested parties to comment on the remedial investigation/
feasibility study (RI/FS) results and the Proposed Plan for the
Rutledge Property Superfund Site located in Rock Hill, South
Carolina. Upon receipt of a request, the comment period was
extended an additional thirty (30) days. The comment period
closed on April 25, 1994.
EPA held a public meeting at 7:00 p.m. on March 1, 1994, at the
Rock Hill City Hall in South Carolina, to present the results of
the RI/FS and the Baseline Risk Assessment, to present EPA'a
Proposed Plan, and to receive comments from the public.
EPA proposed a remedy consisting of extraction of contaminated
groundwater with discharge to the POTW.
The Responsiveness Summary provides a summary of citizens'
comments and concerns identified and received 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 Rutledge Property
Superfund Site;
• Attachment B: Public Notices of Public Comment Period
& Extension of Public Comment Period;
• Attachment C: Written Public Comments Received During
the Public Comment Period;
• Attachment D: Official Transcript of the Proposed Plan
Public Meeting.
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2.
EPA's community relations program for the Site began in January
1992, when EPA conducted community interviews in order to develop
a community relations plan for the Site. At that time, residents
living adjacent to the Site voiced some concerns about Cranford
Park's water system that needed to be upgraded. Since that time
this issue has been resolved by the municipal water company.
Allegations from the single resident in the Dearwood Trailer Park
that contaminated well water was being furnished to his trailer,
were made. One resident was concerned about his child playing on
the Site property, and some concerns were raised about the use of
government money.
Throughout EPA's involvement, the community has been kept aware
and informed of Site activities and findings. Discussions have
taken place during visits to the area by EPA's remedial project
manager (RPM). Local officials were briefed during the community
interviews, and updated as needed. EPA has responded to
inquiries from the community and other interested parties.
3. SinimMJ-ry of Col™**"*-" Recei\
Period and Agency Responses
The Public Comment Period was opened on February 22, 1994, and
ended on March 24, 1993. Upon request, a thirty (30) day
extension was granted, which extended the comment period to April
25, 1994. Public notice announcements were'published in local
newspapers and copies of the announcements are included as
Attachment B.
On March 1, 1994, EPA held a public meeting to present the
Proposed Plan to the community and to receive comments. All
comments received at this public meeting and during the public
comment period are summarized below.
Summary and Response to local Community Concerns
The following issues and concerns were expressed at the Proposed
Plan Public Meeting, and during the public comment period.
COMMENT: A written comment stated that during the Remedial
Design phase, an Intermediate Design (60%) submittal would not be
necessary, and would not be an efficient use of funds.
RESPONSE: EPA, in general, agrees with this concept, however,
this will not be determined in the Record of Decision (ROD). The
purpose of the ROD is to document the chosen remedial action
alternative. A determination will be made during the RD phase
regarding the necessity for an intermediate design submittal.
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5 9 0026
COMMENT: Another written comment stated that the letter from the
POTW stating they would accept untreated groundwater, was not in
the Administrative Record.
RESPONSE: EPA checked both Administrative Records, one at EPA,
and one at the information repository in Rock Hill, and both
contained this letter.
COMMENT: A written comment stated that EPA's cleanup goal for
1,2-dichloroethene (1,2-DCE) is 70 ug/1. The commentator stated
that "1,2-DCE should be split into two standards to reflect the
MCLs of the cis- and trans- isomers of 1,2-DCE. The trans-
isomer has a higher MCL of 100 ug/1. The lower standard for the
cis-isomer would apply whenever analytical results are reported
as total 1,2-dichloroethene."
RESPONSE: During the RI, as is usually done, only total
1,2-dichloroethene was analyzed for, and not the individual
isomers. In doing so, it was tacitly assumed that all 1,2-DCE
was in the cis-isomer form, for risk assessment purposes. By
doing so, and by using the MCL for cis-1,2-DCE of 70 ug/1, EPA
has taken an environmentally conservative approach. Therefore,
EPA has chosen the slightly lower MCL of 70 ug/1 as the cleanup
standard for total 1,2-DCE versus 100 ug/1.
COMMENT: Another written comment said "The RI recommended
additional study of the ecological communities that could be
impacted by this site, even though the RI Report states that the
site does not pose a threat to any state or federally listed
species of concern. The RI's surface soil results show that
further migration of site contaminants to receiving waters is not
anticipated. The EPA's ecological screening did not identify any
sensitive ecological communities immediately downstream of the
site. An ecological study is therefore likely to be
unproductive, and the money for it would be better spent on
cleanup."
u
RESPONSE: This comment makes the erroneous assumption that money
spent on a study of ecological concerns will be money that is
unwisely spent. This is not the case. Any further study of
ecological communities or impacts attributable to the Site, will
be conducted, if required by EPA, in order to determine if
unacceptable levels of risk to biological receptors have been
fully identified. These potentially unacceptable levels of risk
would not necessarily be limited to threats to endangered or
threatened species, or to sensitive ecological communities. The
extent of potential threats to all biological receptors,
endangered or not, in all habitats, whether or not they are
"sensitive ecological communities," may be required to be fully
delineated.
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COMMENT: A written comment and one brought up at the public
meeting concerned the fact that contaminants similar to site-
related contaminants were detected in private wells PW-03 and PW-
04. The written commentator felt the monitoring well network was
extensive and sufficient to determine that the contaminants were
not site related. The commentator at the public meeting was not
sure that this was true, and that possible further
characterization was needed, since the deepest monitoring wells
at the site may not have been as deep as the private wells.
RESPONSE: EPA stated in the public meeting that during the
remedial design, the depth of PW-04 would be determined. Also
during the remedial design, the level of the water table in the
well will be measured. This will be compared with the water
levels of the monitoring wells on-site, to determine if the
groundwater would flow from the Site to the private well or from
the direction of the private well toward the Site. If after
this, it is determined by EPA that a potential migration -pathway
from the Site to PW-04 may exist, additional monitoring well(s)
may be installed.
COMMENT: A written comment stated that the depth of the
extraction wells was not stated in the proposed plan, and that
the wells should not be placed in the bedrock (at least no more
than a few feet), because it would be difficult and technically
impracticable to extract groundwater from bedrock fractures for
remediation purposes. \
RESPONSE: The exact depth and number of extraction wells will be
determined during the remedial design. At this time EPA does not
believe it is technically impracticable to extract groundwater
from bedrock fractures for remediation purposes, especially in
the vicinity of bedrock wells with known contamination.
COMMENT: At the public meeting a concern was expressed about
sending untreated groundwater to the POTW. It was felt that the
underground pipes to and from the treatment plant may leak
causing contaminants to get back into the groundwater which in
turn would get to private wells. The commentator was also
concerned that treated water from the treatment plant would not
really be clean and, as the plant discharged treated effluent to
the stream, contaminants from the site might get into the surface
water which would flow downstream to the point where the intake
pipe for the City of Rock Hill drinking water is, and they would
then be exposed to contamination. One commentator felt that
onsite treatment should be done to bring the water to "an
acceptable level for an acceptable dumping, wherever that site
may be."
RESPONSE: EPA believes that sending the extracted groundwater to
the POTW is an acceptable alternative. The personnel at the POTW
was contacted several times, both before and after the public
meeting, and is aware of the concentrations of contaminants
detected in the groundwater and has signed a letter saying they
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r. o p. n A i
*-> s u u *. /
will accept the untreated groundwater, and have reconfirmed this
verbally since the public meeting. In addition, three (3) of the
four (4) contaminants of concern are volatile organics which will
be effectively removed due to the aeration process at the
treatment plant, and therefore, will not likely be in water
discharged from the treatment plant. Also, when the extraction
system is in place, it will pull in water from all directions, so
that the average concentration of the water that would be sent to
the POTW should be significantly lower than the highest
concentration detected in the one well. Also, as was stated by
EPA at the public meeting, and as was confirmed in a phone
conversation with city personnel after the public meeting, the
groundwater infiltrates into the pipes versus water going from
the pipes into the groundwater. In addition, the volume of water
that will be sent to the POTW from the Site, approximately 28,000
gallons/day is very small in comparison to the overall flow from
other sources that goes to the treatment plant (approximately 5
million gallons/day). Lastly, the water from the sewage plant
(where the extracted groundwater is to be sent) discharges into
the Catawba River, far downstream of the drinking water intake.
COMMENT: Another concern expressed at the public meeting and
from an attendee in a letter to EPA, was that not all the soil
contamination had been removed and therefore, contaminants would
keep leaching into the groundwater.
RESPONSE: As was stated at the public meeting, there have been
two (2) removals at the Site, in which soil samples were
collected and analyzed before the removal and prior to the
excavations being backfilled with clean soil. These results were
used initially to determine the area of where the removals needed
to take place and was used to show that the removals adequately
removed the contaminated soil. In addition sixty-five (65) soil
samples were collected during the RI. The Baseline Risk
Assessment determined that there was not an unacceptable current
or future risk from the soil.
COMMENT: Another comment was that the Site should be posted with
signs and fenced off.
RESPONSE: The Baseline Risk Assessment determined that there was
no unacceptable current or future risk from the soil, therefore
EPA does not believe a fence is required at this Site. During a
remedial action, it is common to have a sign indicating the
activities currently underway at the Site. This type of sign
will probably be placed at the Site during the remedial action.
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Attachment A
Proposed Plan for Rutledge Property Superfund Site
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5 9 0029
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
SUPERFUND PROPOSED PLAN FACT SHEET
RUTLEDGE PROPERTY (ROCK HILL
CHEMICAL COMPANY) SUPERFUND SITE
Rock Hill, York County, South Carolina
February 1994
Thi* fact sheet is one in a eerie* designed to inform resident* and local official* of the ongoing cleanup
effort* at the Site. A number of term* specific to the Superfund process (printed in bold print) are defined
in a. glossary at the end of this publication.
INTRODUCTION
The United States Environmental Protection Agency (EPA) is proposing a cleanup plan,
referred to as the "preferred alternative", to address groundwater contamination at the
Rutledge Property Superfund Site (the Site) located in Rock Hill, South Carolina. This
document is being issued by EPA, the lead Agency for Site activities, and the South Carolina
Department of Environmental Health and Control (SCDHEC), the support Agency. SCDHEC
has reviewed this preferred alternative and concurs with EPA's recommendation.
This Proposed Plan summarizes the cleanup methods and technologies evaluated in the Site's
Feasibility Study (FS). In accordance with Section 117(a) of the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), known
as "Superfund", as amended by the Superfund Amendments and Reauthorization Act
of 1986 (SARA), EPA is publishing the Proposed Plan for the following reasons:
1) To provide an opportunity for the public's review and comment on all of the
PROPOSED PLAN PUBLIC MEETING
for the
RUTLEDGE PROPERTY SUPERFUND SITE
Tuesday, March 1,1994 - 7:00 P.M.
SULLIVAN MIDDLE SCHOOL - CAFETERIA
1825 Edin Terrace, Rock Hill, South Carolina
You are encourage to attend the public meeting to learn more about the cleanup
alternatives developed for the Rutledge Property Superfund Site, as well as the
alternative proposed by EPA. The public meeting will also provide an opportunity for
interested individuals to submit comments to EPA on the Feasibility Study and the
Proposed Plan. Representatives from EPA and the SCDHEC will be available to
answer questions. Please plan to attend.
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cleanup options, known as remedial alternatives, under consideration for the
Site.
2) To initiate a thirty (30) day public comment period from Friday, February 18,
1994, to Monday, March 21, 1994 to receive comments on this Proposed Plan
and the RI/FS reports.
EPA, in consultation with SCDHEC, will select a remedy for the Site only after the public
comment period has ended and all information submitted to EPA during that time has been
reviewed and considered.
As outlined in Section 117(a) of CERCLA, EPA encourages public participation by publishing
Proposed Plans for Superfund Sites, and by providing an opportunity for the public to
comment on the proposed remedial actions. As a result of such comments, EPA may modify,
or change, its preferred alternative before issuing a Record of Decision (ROD) for the Site.
This process is explained in more detail in the Public Participation Section of this document
which begins on page 16.
Scope and Role of this Action
Based on the previous soil removals, and the data present to date, EPA's plan for
remediation will address the principal threat remaining at the Site, contaminated
groundwater.
EPA's preferred alternative for cleanup of the Site's groundwater is Alternative 4-B,
Groundwater Pumping by two (2) Extraction Wells and Discharge to the City of Rock Hill
Publically Owned Treatment Works (POTW). This alternative achieves the best balance of
compliance with the criteria EPA uses to evaluate remedial alternatives. The preferred
alternative, as well as the others considered, are summarized in this fact sheet and presented
in its entirety in the FS.
This fact sheet also summarizes information that is explained, in greater detail in the
Remedial Investigation/Feasibility Study (RI/FS) Report, dated December 1993, and the
Baseline Risk Assessment (BRA), dated July 1993. These documents, and all other
records utilized by EPA to make the preferred alternative proposal, are contained in the
Administrative Record for this Site. EPA and SCDHEC encourage the public to review
this information, especially during the public comment period, and has established an
Information Repository near the site. Review of this material will further explain Site
characteristics, the Superfund process, and EPA's logic behind this Proposed Plan. The
Administrative Record is available for public review, during normal working hours, at the
following locations:
York County Library
138 East Black Street
Rock Hill, South Carolina 29731
(803)324-3055
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5 9 0030
Records Center
U.S. Environmental Protection Agency
345 Courtland Street, NE
Atlanta, GA 30365
(404)347-0506
This Proposed Plan:
1) Includes a brief history of the Site, the principal findings of the Remedial
Investigation (RI), and a summary of the Baseline Risk Assessment;
2) Presents the cleanup alternatives considered by EPA, and presented in the Feasibility
Study (FS);
3) Outlines the criteria used by EPA to recommend a preferred alternative for use at the
Site;
4) Provides a summary of the analysis of alternatives;
5) Presents EPA's rationale for its preliminary selection of a preferred alternative;
6) Explains the opportunities for the public to comment on the remedial alternatives,
and, hence, the cleanup method for the Rutledge Property Superfund Site.
SITE BACKGROUND
The Rutledge Property Site (the Site) is located between Cherry Road (U.S. Highway 21) and
Farlow Street, just east of Cranford Street in Rock Hill, York County, South Carolina. The
4.5 acre Rutledge Property is the location where Rock Hill Chemical Company (RHCC)
operated a solvent reclamation facility from 1960 to 1964 (Fig. 1).
Waste management practices during the company's existence were poor. Paint sludges,
textile dye products, used solvents, and other solid wastes generated during the reclamation
process were stored in piles placed directly on the ground. In some cases, waste products
were buried at the Site. On several occasions, tanks that were used to hold liquid wastes
before reclamation had leaked onto the ground, creating a potential source of contamination.
The Rock Hill Chemical Company ceased operations in the summer of 1964. The following
October, a fire at the facility caused drums of oil and chemicals to explode, releasing their
contents into the environment. In 1985, soil was removed from the western portion of the
Site, now occupied by First Union National Bank of South Carolina (FUNBSC). An
additional soil removal took place between 1987 and 1989, which included the removal of five
(5) storage tanks.
The Rutledge Property Site was proposed for the National Priorities List (NPL) in June
of 1988 and was listed final on the NPL in February 1990. In March 1992, EPA initiated the
RI/FS to address all potential source areas and associated contamination at the site.
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100
-N-
0 100 200
sss
SCALE IN FEET
YORK
SHOPPING
PLAZA
>-< CULVERT
TREEUNE
SURFACE WATER
SUBSURFACE
STORM DRAIN
----- SITE BOUNDARY
SITE PLAN MAP
RUTLEDGE PROPERTY
™^1S COW'ORAT'ON ROCK HILL. SOUTH CAROLINA
Figure No. 1
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5 9 0031
RESULTS OF THE REMEDIAL INVESTIGATION
The RI investigated the nature and extent of contamination on and near the Site, and defined
the potential risks to human health and the environment posed by the Site. A total of forty
one (41) groundwater, sixty five (65) soil, seven (7) surface water, and seven (7) sediment
samples were collected during the RI. More detailed information on the sampling locations,
procedures, and results can be found in the RI/FS report, as well as the Baseline Risk
Assessment.
Soil Contamination
Soil analyses indicate that volatile organic, semi-volatile organic, pesticide/PCB and
inorganic chemicals are present above background levels. However, as concluded by
the Baseline Risk Assessment and the RI, the levels of these contaminants are low
enough not to pose a threat to human health or the environment. Due to a concern
over the high variance of manganese levels in the surface soil background samples,
additional samples) will be taken during the Remedial Design to confirm that this
variance is consistent with the environmental setting.
Surface Water & Sediment Contamination
Surface water analyses indicate that volatile organic and inorganic chemicals are
present in the on-site drainage and the Unnamed Stream. Sediment analyses indicate
that volatile organic, semi-volatile organic, pesticide/PCB, and inorganic chemicals are
also present in the on-site drainage and the Unnamed Stream. As with soil, the levels
of these contaminants are low enough not to pose a threat to human health or the
environment. Because the volatile organic, tetrachloroethene, was detected at
elevated levels in the background surface water and sediment samples, additional
surface water and sediment samples) will be collected to ensure that the background
location used has not be impacted by Site characteristics.
Groundwater Contamination
Groundwater analyses indicate that volatile organic, pesticides, PCBs, and inorganic
chemicals are present above background levels. In contrast to the surface water,
sediment, and soils analyses, the Baseline Risk Assessment concluded that three (3)
volatile organics (trichloroethene, vinyl chloride, 1,2 dichloroethene) and one (1)
inorganic (manganese) pose a risk to human health and the environment. All three
(3) of the volatile organics exceeded the Maximum Contaminant Levels (MCLs)
promulgated under the Safe Drinking Water Act. The approximate area! extent of
groundwater contamination is illustrated in Figure 2. The levels of volatile
contamination indicate the likelihood of Dense Non-Aqueous Phase Liquids
(DNAPLs) within the groundwater media.
Due to the fact that Site-related contamination was detected at very low levels at PW-
04 (Fig. 2), further evaluation of the construction characteristics of this well will be
required in the Remedial Design. If the screening depth of this well exceeds the
screening depths of the on-Site wells, additional wells may be required to fully
demonstrate that there is no aquifer contamination at that screening depth that may
be of concern.
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too
-N-
0 100 200
SSE
SCALE IN FEET
YORK
SHOPPING
PIA2A
UW-UWi
o
LEGEND
>~( CULVERT
**** TREEUNE
...— SURFACE WATER
SUBSURFACE
STORU DRAIN
* WQJL UOCATON
A STA/T GAUGE
AREA OF
CONTAMINATION
APPROXIMATE AREAL EXTENT OF CONTAMINATION
ABOVE REMEDIATION LEVELS IN GROUNDWATER
: RUTLEDGE PROPERTY
ROCK HILL. SOUTH CAROLINA Figure No. 2
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5 9 0032
SUMMARY OF SITE RISKS
The Baseline Risk Assessment (BRA) describes the risks to human health and the
environment which would result were the contamination not remediated.
The BRA proceeds in a series of steps: Initially, Contaminants of Potential Concerns
(COPCs) are identified. This list of COPCs includes all chemicals present that may pose a
potential risk to human health or the environment. The Exposure Assessment .considers the
present population potentially exposed to Site-related hazards, including on-site workers, and
visitors. In addition, potential future use scenarios, such as a future residential scenario, are
developed to determine "pathways" through which persons could potentially be exposed to the
contaminants.
The pathways of exposure can be evaluated by making assumptions such as the length and
number of times persons may be exposed and how much of the chemical is ingested. Thus,
a calculation «*« be made using known health effects and reasonable exposure assumptions
for each contaminant.
Both carcinogens, substances known or suspected to cause cancer, and non-carcinogens,
substances which do not cause cancer, but are hazardous and cause damage to human health
through other effects, are considered in the Risk Assessment.
For carcinogens, the result is expressed as the excess cancer risk posed by Site contaminants.
EPA has established a range of IxlCT* to IxlO"6 as acceptable limits for lifetime excess
carcinogenic risks. Excess risk in this range means person^ exposed to Site contaminants
under the exposure scenarios evaluated stand a 1 in 10,000 to 1 in 1,000,000 chance of
developing cancer as a result of that exposure. For each pathway, the cancer risk from each
individual contaminant is added together because, in a "worst-case" scenario, a person could
be exposed through several, or all, of the possible pathways. Non-carcinogenic risk is
expressed as a Hazard Index (HI). The HI is the ratio of the amount of chemical taken in,
divided by the reference dose, which is an intake amount below which no adverse effects are
known to occur. As for cancer risk, for each pathway, the HI for the individual contaminants
are added together.
Carcinogenic risk and non-carcinogenic risk were calculated for the potential on-site future
residential use scenario. The future residential use scenario has a carcinogenic risk of 2xlO"2.
This level of risk results from exposure to contaminated groundwater via ingestion as
drinking water. This value is not within the acceptable risk limit. For the non-carcinogenic
risk, the future use HI is 950 which is also well above the EPA benchmark of 1.0. Likewise,
the HI is the result of ingestion of contaminated groundwater. The most serious pathway
and use at the Site is:
FUTURE RESIDENTIAL USE: Adult or child - Ingestion of groundwater
(carcinogenic and non-carcinogenic)
More detailed information on the Site risks is presented in the Baseline Risk Assessment.
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Actual or threatened releases of hazardous substances from this Site, if not addressed by the
preferred alternative, or one of the active measures considered, may present a current or
potential threat to public health, welfare, or the environment.
REMEDIAL OBJECTIVES AND ALTERNATIVES
Remedial Action Objectives
Based on the RI and the BRA, EPA has established the following remedial action objectives
for the Rutledge Property Superfund Site:
• Prevent ingestion of groundwater containing any carcinogen concentrations
above federal or state limits, or if there is no established limit, above levels
which would allow a remaining excess cancer risk greater than the 10~* to 10"6
range.
• Prevent ingestion of groundwater containing any non-carcinogen concentrations
above federal or state limits, or if there is no established limit, above levels
which would allow an unacceptable remaining non-carcinogenic threat (HI
greater than 1).
• Restore the groundwater system to potential productive use, by remediating
to the standards described above, and by preventing the migration of the
groundwater contamination beyond the existing limits of the contaminant
plume.
Establishment of Remediation Levels
EPA has established specific remediation levels (goals), or clean-up standards, for the
groundwater contaminants present within the plume at the Rutledge Property Site. Such
standards are established under several federal environmental laws including the Safe
Drinking Water Act (for water systems and potable water sources such as groundwater). The
State of South Carolina has similar statutes. Most of the contaminants present at the. Site
are regulated under these federal and state standards. In cases where there is no state or
federal standard, groundwater remediation levels were developed in the Feasibility Study
(FS) based on human health (BRA calculations). There are no soil remediation levels. Table
1 summarizes remediation levels for the groundwater at the Site.
8
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5
003
TABLE 1
GROUNDWATER REMEDIATION LEVELS
CONTAMINANT
Maximum
Concentration
Detected (ug/L)
Remediation
Goal
(ug/L)
Volatile Orsanics
1,2 Dichloroethene
Vinyl Chloride
Trichloroethene
Inorganics
Manganese
1200
26
84000
2*
5*
3600
200(b>
* Maximum Contaminant Level (MCL) \
(a) Groundwater samples were analyzed for 1,2 dichloroethene (total). The maximum.
contaminant level for 1,2 dichloroethene (cis) was used since it is more conservative
than 1,2 dichloroethene (trans) at 100 ug/L.
(b) The average background concentration was 185.5 ug/L. This value was rounded up to
200 ug/L for the remediation level based on potential MCL listings.
Development of Remedial Alternatives
In the FS, remedial alternatives were constructed and evaluated for groundwater
contamination. To formulate the alternatives for cleanup, all of the possible technologies,
processes, and methods which could be utilized in a cleanup effort were evaluated, and those
which could not be used at the Site were screened out. The screening criteria employed are
primarily site-specific factors that make some of the technologies or processes ineffective,
difficult to implement, or infeasible. Such factors include soil type, geology/hydrogeology, site
location, and the volume of the contaminated media. Technologies and processes considered
to be potentially useful were then grouped together into remedial alternatives to address
groundwater contamination. The resulting alternatives were then evaluated and compared
to one another in detail.
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SUMMARY OF REMEDIAL ALTERNATIVES
Six (6) alternatives to address groundwater contamination were developed and compared in
the FS. The first two (2) alternatives are "No Action" and "Limited Action". The next two
(2) alternatives provide groundwater extraction with treatment on-site, the difference being
the number of extraction wells used to extract the groundwater. The final two (2)
alternatives provide groundwater extraction with one (1) or two (2) wells and direct discharge
to the Publically Owned Treatment Works (POTW).
All of the alternatives considered were subject to the following assumptions and
requirements:
• Area of groundwater contamination is 239,000 ft2
• Depth of contamination is 54 ft
• Volume of contaminated water is approximately 7,338,000 gal
• Present Worth (PW) cost assumes an annual 7% discount (interest) rate
For each alternative, remedial action objectives will be considered satisfied when the
remediation goal standards are not exceeded in any of the monitoring wells. At the start of
the design phase, EPA or the Potentially Responsible Party (PRP) will initiate periodic
groundwater monitoring at the Site.
The cost given for each alternative is the Total Present Worth (PW) of capital costs plus
Operation and Maintenance (O&M) costs. More detailed descriptions of the strengths and
weaknesses of each alternative in terms of EPA's nine (9) standard criteria, can be found in
the FS.
Alternative 1 - No Action
CERCLA requires that EPA evaluate a "No Action" alternative to serve as a basis against
which other alternatives can be compared. Under this alternative, no actions are taken, nor
are funds expended, for control or remediation of the contaminated groundwater. Because
contaminants would be left on-Site under this alternative, a review is required every five (5)
years in accordance with the requirements of CERCLA. This alternative would also require
monitoring and the costs associated with laboratory analysis and report writing.
Under this alternative, Site conditions would remain unchanged. Therefore, contaminated
groundwater would continue to present an unacceptable health risk now and in the future.
Total Present Worth (PW) Cost: $170,000
Estimated Capital Cost: none
Estimated Annual O&M Cost: none
Implementation Timeframe (months): 0
10
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5 9 0034
Alternative 2 • Limited Action
Under this alternative, limited action (institutional controls) would be implemented to restrict
the withdrawal and use of groundwater from the contaminated plume. The institutional
controls would consist of deed restrictions to control future use of land and groundwater, and
long-term monitoring as presented in Alternative 1.
Deed restrictions would also be utilized to prevent future use of the aquifer for such purposes
as potable and industrial water supplies, irrigation, and washing. Permit restrictions issued
by the State of South Carolina would restrict all well drilling permits issued for public wells
on properties that may draw water from the contaminated groundwater plume. These
restrictions could be written into the property deeds to inform future property owners of the
possibility of contaminated groundwater beneath their property.
A second component of this alternative would be monitoring of Site groundwater conditions.
Groundwater samples from the wells would be collected and analyzed periodically to evaluate
contaminant concentrations and to monitor the extent and direction of contaminant direction.
Total Present Worth (PW) Cost: $170,000
Estimated Capital Cost: none
Estimated Annual O&M Cost: $ 35,750
Implementation Timeframe (months): 0
Alternative 3A • Groundwater Pumping by 1
Extraction Well and On-Site Treatment
With Discharge to Surface Water
Under this alternative, one (1) extraction well would be used to contain the contaminated
groundwater plume. The extraction well would be located on the northeast corner of the
property, near the downgradient edge of the plume. The contaminated groundwater would
flow into the well and would then get pumped to the surface. The water would then go
through an on-Site treatment system composed of neutralization, oxidation, sedimentation,
filtration, and carbon adsorption. As the contaminated water passes through this treatment
"train", the volatile organics 1,2 dichloroethene, trichlorethene, and vinyl chloride, as well as
the inorganic manganese, will be reduced to their respective remediation levels. The "clean"
water would then be discharged to the surface water in accordance with National Pollutant
Discharge Elimination System (NPDES) requirements. Deed restrictions and long-term
groundwater monitoring as described in Alternative 2 would also be enforced.
Total Present Worth (PW) Cost: $4,115,000
Estimated Capital Cost: $ 872,000
Estimated Annual O&M Cost: $ 348,000
Implementation Timeframe (months): 24
11
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Alternative 3B - Groundwater Pumping by 2 Extraction Wells and
On-Site Treatment With Discharge to Surface Water
This alternative is identical to Alternative 3A except for the fact that two (2) extraction
wells would be used to contain the contaminated groundwater plume instead of one (1).
As in Alternative 3A, one (1) well would be located on the downgradient edge of the
plume. An additional extraction well would be centrally located in the source area (Figure
2, MW-03). The advantage of adding an additional well in this location would be that the
contaminants are removed from the aquifer more quickly than if only one extraction well
is used to remove the contaminated groundwater. The treatment train, surface water
discharge, deed restrictions, and long-term groundwater monitoring would be enforced as
indicated in Alternative 3A.
Total Present Worth (PW) Cost: $4,159,000
Estimated Capital Cost: $ 915,000
Estimated Annual O&M Cost: $ 348,000
Implementation Timeframe (months): 24
Alternative 4A - Groundwater Pumping by 1
Extraction Well and Direct Discharge to POTW
Under this alternative, the groundwater contaminant plume would be contained by one
(1) extraction well located on the downgradient edge of the plume. As opposed to
Alternatives 3A and 3B, the contaminated groundwater would then be discharged, via
sewer line, to the local POTW. No pretreatment would be required prior to discharging
the contaminated groundwater to the sewer line. Again, deed restrictions, and long-term
groundwater monitoring would be enforced as in Alternatives 3A and 3B.
Total Present Worth (PW) Cost: $1,969,000
Estimated Capital Cost: $ 249,000
Estimated Annual O&M Cost: $ 225,000
Implementation Timeframe (months): 12
Alternative 4B - Groundwater Pumping by 2
Extraction Wells and Direct Discharge to POTW
Likewise, this alternative is identical to Alternative 4A, except for the fact that two (2)
extraction wells would be used to contain the contaminated groundwater plume instead of
one (1). Similarly, one (1) well would be located on the edge of the plume, while the other
located in the source area (Figure 2, MW-03). Discharge to sewer line (without
pretreatment), deed restrictions, and long-term groundwater monitoring would be enforced
as in Alternatives 3A, 3B, and 4A.
Total Present Worth (PW) Cost: $2,031,000
Estimated Capital Cost: $ 312,000
Estimated Annual O&M Cost: $ 225,000
Implementation Timeframe (months): 12
12
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5 9
0035
Please refer to Table 2 below for a brief summary of the remedial alternatives, and their
respective costs.
Table 2
REMEDIAL ALTERNATIVES COST
DESCRIPTION COST
1
2
3A
3B
4A
4B
No Action
Limited Action
Groundwater Extraction & Treatment
* On-Site
* One (1) Extraction Well
Groundwater Extraction & Treatment
* On-Site
* Two (2) Extraction Wells
Groundwater Extraction & Disch. to POTW
* One (1) Extraction Well
Groundwater Extraction & Disch. to POTW
* Two (2) Extraction Wells
$170,000
$170,000
$4,115,000
$4,159,000
$1,969,000
$2,031,000
Evaluation of Remedial Alternatives
In selecting its preferred alternative, EPA used the following criteria to evaluate the
alternatives developed in the FS. Seven (7) of the criteria were used to evaluate all of the
alternatives, based on environmental protection, cost, and engineering feasibility issues. The
preferred alternative, along with the other proposed alternatives, will be further evaluated
against the final two (2) modifying criteria, state and community acceptance, after the public
comment period has ended and all comments from the community and state have been
received.
THRESHOLD CRITERIA: The first two (2) statutory requirements must be met by the
alternative.
1. Overall Protection of Human Health and the Environment addresses the degree to
which an alternative meets the requirement that it be protective of human health and
the environment. This includes an assessment of how public health and
environmental risks are eliminated, reduced, or controlled.
13
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THRESHOLD CRITERIA: The first two (2) statutory requirements must be met by the
alternative.
1. Overall Protection of Human Health and the Environment addresses the degree to
which an .alternative meets the requirement that it be protective of human health and
the environment. This includes an assessment of how public health and
environmental risks are eliminated, reduced, or controlled.
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 remediation options at a specific site.
PRIMARY BALANCING CRITERIA: These five (5) considerations are used to develop the decision
as to which alternative should be selected.
3. Long-Term Effectiveness and Permanence refers to the ability of an alternative to
maintain reliable protection of human health and the environment, over time, once
the remediation levels are achieved.
4. Reduction of Toxicity, Mobility, and Volume (TIMIV) addresses the statutory
preference for selecting remedial actions that employ treatment technologies that
permanently and significantly reduce the tozicity, mobility, and volume of the
hazardous substance.
5. Short-Term Effectiveness addresses the impacts of the alternative on human health
and the environment during the construction and implementation phase, until
remedial action objectives have been met.
6. Implementability refers to the technical and administrative feasibility of
implementing an alternative, including the availability of various services and
materials required for its implementation.
7. Cost consists of the capital (initial) costs of implementing an alternative, plus the
costs to operate and maintain (O&M) the alternative over the long term. Under this
criteria, the cost effectiveness of the alternative can be evaluated.
MODIFYING CRITERIA: These two (2) considerations indicate the acceptability of the
alternative to the public, local, or state officials.
8. State Acceptance addresses whether, based on its review of the RI/FS and the
Proposed Plan, the State concurs with, opposes, or has no comments on the selected
preferred alternative, or remedy.
9. Community Acceptance addresses whether the public agrees with EPA's selection
of the preferred 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.
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5 9 0036
EPA'S PREFERRED ALTERNATIVE
After conducting a detailed analysis of all of the alternatives, EPA has selected the following
alternative for remediation of the Site:
Alternative 4-B
Groundwater: Extraction (2 wells) &
Direct Discharge to POTW
Total PW Cost: $2,031,000
Rationale for the Preferred Alternative
EPA has selected Alternative 4-B as the best alternative for use at the Rutledge Property
Site.
Of the six (6) alternatives reviewed by EPA, both Alternative 1 and Alternative 2 fail to meet
the threshold criteria of protecting human health and the environment, and compliance with
ARARs. Therefore, these two (2) alternatives were eliminated.
Of the remaining four (4) alternatives that meet the two aforementioned threshold criteria,
they all meet the five (5) primary balancing criteria of long-term effectiveness, reduction of
T/M/V, short-term effectiveness implementability, and cost, but to varying degrees. The
major differences being in short-term effectiveness, implementability, and cost.
Alternatives 4-A and 4-B do not require a treatment system to be built on-Site. Rather, the
contaminated groundwater would be pumped directly, via sewer line, to the local POTW and
treated by the POTW. Therefore, Alternatives 4-A and 4-B short-term effectiveness is
increased since it will be faster to implement due to the fact that the system does not require
a complex treatment system to be designed and built on-Site. Additionally, the ease of
implementability for Alternatives 4-A and 4-B are far greater than Alternatives 3-A and 3-B.
As a result, the cost of Alternative 4-A and 4-B is less than Alternatives 3-A and 3-B.
Between Alternatives 4-A and 4-B, the difference is merely the number of extraction wells
to be utilized. EPA feels that, by using multiple extraction wells, the groundwater
contamination will be removed from the contaminated media more rapidly, resulting in a
more expeditious remediation.
Therefore, based on these comparisons, EPA believes that based on the information currently
available, Alternative 4-B provides the best balance of compliance among the other
alternatives with respect to the evaluation criteria for the remediation of the contaminated
groundwater at the Rutledge Property Site. Employing this alternative will protect human
health and the environment, meet ARARs, be effective in the long-term, reduce contaminant
toxicity, mobility, and volume, be easy to implement, and will be very cost-effective.
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PUBLIC PARTICIPATION
EPA will hold a public meeting on Tuesday, March 1, 1994, to discuss the Preferred
Alternative and other alternatives evaluated in the FS. Officials from EPA and SCDHEC
will present a summary of the RI/FS, the remedial alternatives, and how the preferred
alternative was selected. The public is encouraged to attend this meeting.
EPA is also conducting a 30-day public comment period from Friday. February 18. 1994. to
Monday. March 21. 1994. in order to receive public input and comments on the preferred
alternative for remediation of the Rutledge Property Superfund Site. Comments on the
preferred alternative, the other alternatives, or other issues related to the Site remediation,
are welcomed, as they are an important part of the decision-making process. Please send all
comments to:
Mr. Samford T. Myers
North Superfund Remedial Branch
U.S. Environmental Protection Agency
Region IV, 345 Courtland Street, N.E.
Atlanta, Georgia 30365
EPA will review, and consider, all comments received during the public comment period and
the public meeting before reaching a final decision on the most appropriate remedial
alternative for the remediation of the Site. EPA's final decision will be issued in the Record
of Decision (ROD), a legal document which formally eets forth the remedy. A
Responsiveness Summary, which contains all of the public comments received and EPA's
response to them, is part of the ROD. A ROD is expected to be completed for the Rutledge
Property in the spring of 1994.
For more information. on community relations, the Superfund process, or this Site in
particular, please contact:
Ms. Cynthia Peurifoy
Public Relations Coordinator
U.S. Environmental Protection Agency
Region IV, 345 Courtland Street, N.E.
Atlanta, Georgia 30365
(404)347-7791 or (800)435-9233
FUTURE ACTIVITIES
Upon signature of the ROD at EPA Region IV in Atlanta, EPA will evaluate the situation
with regard to the Potentially Responsible Parties (PRPs) at this site. EPA will then
try to negotiate with the PRP(s) to secure performance and funding of the remedy under
EPA's oversight. If EPA cannot reach an agreement with the PRPs, then EPA will proceed
with Remedial Design/Remedial Action using CERCLA trust funds.
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5 9 0037
GLOSSARY
Administrative Record • A file which is maintained and contains all information used by the
EPA to make its decision on the selection of a response action under CERCLA. This file is
required to be available for public review and a copy is to be established at or near the site,
usually at the information repository. A duplicate file is maintained in a central location such
as a regional EPA and/or state office.
Applicable or Relevant and Appropriate Requirements (ARARs) - Requirements which must
be met by a response action selected by EPA as a site remedy. "Applicable" requirements are
those mandated under one or more Federal or State laws. "Relevant and appropriate"
requirements are those which, while not necessarily required, EPA judges to be appropriate for
use in that particular case.
Aquifer - An underground geological formation, or group of formations, containing usable
amounts of groundwater that can supply wells and springs.
Baseline Risk Assessment - An assessment which provides an evaluation of the potential risk
to human health and the environment in the absence of remedial action.
Carcinogens - Substances that cause or are suspected to cause cancer.
Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) -
A federal law passed in 1980 and modified in 1986 by the Superfund Amendments and
Reauthorization Act (SARA). The Acts create a trust fund, known as Superfund to investigate
and clean up abandoned or uncontrolled hazardous waste sites.
Dense Non-Aqueous Phase Liquids (ONAPL) • Dense non-aqueous liquids (DNAPLs) are
chemical compounds that are heavier than water in there pure form. DNAPL migration is gravity
driven and relatively unaffected by groundwater flow and often moves in a manner that is
independent of groundwater flow. DNAPL contaminants (especially chlorinated organic solvents)
migrate vertically through fractures in rock or clay formations and thus, can contaminate deep
aquifer systems.
Feasibility Study - See Remedial Investigation/Feasibility Study.
Groundwater - Underground water that fills pores in soils or openings in rocks. This water can
be used for drinking, irrigation, and other purposes.
Hazard Index -A term used in the Baseline Risk Assessment which estimates the exposure
effects to non-carcinogenic contaminants at a hazardous waste site. A HI less than 1.0 indicates
that a significant hazard is likely, a HI grater than 1.0 indicates that there may be a potential
hazard at the site.
17
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Information Repository - Materials on Superfund and a specific site located conveniently for
local residents.
Maximum Contaminant Levels (MCLs) - The maximum permissible level of a contaminant
in water that is consumed as drinking water. These levels are determined by EPA and are
applicable to all public water supplies.
National Priorities List (NPL) - EPA's b'st of uncontrolled or abandoned hazardous wastes sites
eligible for long-term clean up under the Superfund Remedial Program.
Plume - A three dimensional zone within the groundwater that contains contaminants and
generally moves in the direction of, and with, groundwater flow.
Potentially Responsible Parties (PRP's) - This may be an individual, a company or a group of
companies who may have contributed to the hazardous conditions at a site. These parties may
be held liable for costs of the remedial activities by the EPA through CERCLA Laws.
Public Comment Period - Time provided for the public to review and comment on a proposed
EPA action or rulemaking after it is pubb'shed as a Proposed Plan.
Record of Decision (ROD) - A public document that explains which cleanup alternative will be
used at a National Priorities List site and the reasons for choosing the cleanup alternative over
other possibilities.
Remedial Design/Remedial Action (RD/RA) - The remedial design (RD) is a plan formulated
by either the PRP or EPA or both to provide the appropriate measures to remediate a hazardous
waste site. This plan may be modified many times through negotiations between EPA an the
PRP. The remedial action (RA) is the implementation of the remedial design.
Remedial Investigation/Feasibility Study (RI/FS) - Two distinct but related studies, normally
conducted together, intended to define the nature and extent of contamination at a site and to
evaluate appropriate, site-specific remedies.
Superfund Amendments and Reauthorization Act (SARA) - Modifications to CERCLA
enacted on October 17, 1986.
18
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5 9
USE THIS SPACE TO WRITE YOUR COMMENTS
Four input on the Proposed Plan for the Rutledge Property Superfund Site is important in
helping EPA select a final remedy for the site. You may use the space below to write your
comments, then fold and mail. A response to your comment will be included in the
Responsiveness Summary.
REQUEST TO BE PLACED ON THE
RUTLEDGE PROPERTY SUPERFUND SITE MAILING LIST
If you would like your name and address placed on the mailing list for the Rutledge
Property Superfund Site, please complete this form and return to: Cynthia Peurtfby,
Community Relations Coordinator, EPA-Region TV, North Superfund Remedial Branch, 345
Courfland Street, Atlanta. Georgia 30365, or call 1-800-435-9233.
MAMR?
ADDRESS:
TELEPHONED
19
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United Mates Norm sapcrfond KcmedUl Branch Kegion 4
Environmental Protection MS Cowttand Street, NE
Agency Atlanta, GcortU 30365
Official ludntn
Pttultj for PrtnU Utt
SMt
Cyalhla fWirlfoj
Community RcUUofU Coordlnur
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Attachment B
Public Notices of Public Comment Period and Extension
of Public Comment Period
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5 9
0039
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f2C-The Herald. Tuesday. February 22. 1994 59 00*0
USB
U.S. ENVIRONMENTAL PROTECTION AGENCY
INVITES PUBLIC COMMENT ON THE PROPOSED CLEANUP
PLAN FOR THE RUTLEDGE PROPERTY SUPERFUND SITE, ;
ROCK HILL, YORK COUNTY, SOUTH CAROLINA ;
The U.S. Environmental Protection Agency is inviting public comment on the Proposed Plan for cleanup of
the Rutiedge Property/Rock Hill Chemical Company Superfund Site. The Remedial bwestigation/Feaslbffity
Study for me site have been completed. The Remedial Investigation determined the .nature and extent of
contamination at the sice. The Feasibility Study evaluated alternatives for addressing groundwater contam-
ination at the site; the principal threat posed by the site. . -- -
Six alternatives were considered in proposing this action. The figures in parentheses are the estimated
present worth costs for each alternative. The following alternatives ware considered:
Alternative 1: No Action ($170.000)
Alternatives: Limited Action ($170.000) •
Alternative 3 A: Groundwater Extraction & Treatment. On Site Treatment and Discharge.
One Extraction WeO ($4, 1 1 5.000)
After-native 3B: Groundwater Extraction & Treatment. On-Sfce Treatment and Discharge.
Two Extraction Wells ($4.1 59.000)
Alternative 4A: Groundwater Extraction & POTW Discharge. One Extraction WeO ($1 .969.000)^
Alternative 4B: Groundwater Extraction & POTW Discharge. Two Extraction Wells ($2,031 .000)
EPA is proposing implementation of Alternative 48. EPA believes that employing this alternative wffl pro-
tect human health and the environment, meet applicable or relevant and appropriate requirements, be ef-
fective in the long-term, reduce contaminant toxicity. mobility and volume, be easy to implement, end will
be cost effective.
The scope of the proposed action includes containment of the contaminated groundwater plume by two
extraction weds to be located on the down gradient edge of the plume. The contaminated groundwater
would then be discharged, via sewer fine, to a local publicly owned treatment works (POTW). No pretreat-
ment would be required before the contaminated groundwater is discharged to the sewer fine. Deed re-
strictions. and long/term groundwater monitoring would be enforced. It is estimated that it win take one
year to implement this remedy.
The Agency is holding a 3O-day comment period, which begins on Tuesday. February 22. 1994, and ends
on Thursday. March 24. 1994. Written comments, which must be postmarked no later than March 24.
1994. should be send to:
Mr. Sandy Myers, Remedial Project Manager ....
North Superfund_Remedial Branch
U.S. Environmental Protection Agency. Region IV
345 Courdand Street. N.E. . Atlanta, GA 3O365 - -
EPA has scheduled a public meeting to present the proposed plan and to discuss the status of the Reme-
dial Investigation/Feasibility Study. The meeting also provides the public an opportunity to submit ore! and
written comments on the proposed cleanup plan and the other alternatives considered. This meeting wffl
be:
Date: Tuesday. March 1, 1994 ,
Time: 7:00 p.m.
Place: SULUVAN MIDDLE SCHOOL
1825 Eden Terrace. Rock HiD. South Carolina
Copies of the proposed plan, as weO as the administrative record for the site, are available for review at
the site information repository, which is in the York County Library. 138 East Black Street. Rock HOI. SC.
803/324-3055. These documents are also available for review at the EPA Records Center. 345 Court-'
land Street. N.E.. Atlanta. GA 30365. 4O4-347-O5O6.
For additional information, or to be added to EPA's mailing list for the site, contact Cynthia 8. Peurifoy.
Community Relations Coordinator, at 1-8CO435-9233. or 404/347-7791.
-------
The Herald April 6> 199A
&WIUNITEP JSTAT^ .
•i^ - ri^,. - j- -^.- -fcn7pf foe Public.Commentfertod for the
Ruf&Jge Property Superfund Site,.*
••'•.; \? ;RtekJp;:YojkCw^ .-.'•:
' •• .'* • •• * ''"•tS'f!1* -^jc ^iPA".?* "* ' • ••*>••' i'^;"; '* ••* T.4ftf '4fM&$t*r •"«•'•.« * •'•* **•
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. ' • •• ••••'^•'•T'v^j-tiSpff-;*^*i' •.*-. • * ?•>••••• •-** .-THv?*t *»* '?." • *'*
The U. S. Environment PrqfiSclDon Agency ffPA) b mtenaTng 1ft» pertod of. time for
accepting pubic comments onh» A^er^tpropowddtomip plan, and ttwottw
altemorfnw eontieUmd fbif<)hft feultodgf PropanV Stp^fandgteto Mondov. Aori
25.1994. Written comrrwnfa, which must be postmojktd on or befbmApdl 25,1994,
. . .. .-.' s«a«,«i»:«">:.»:-;H-j-»"--; . -.',•--»...•..• '• . .-.v:, »»-'• •• •>.-.«. ......T: ..' ^
p dgddonjort^ iHirtl l.haiTtytawed and
fljfort*^ BoMd on jwMe corhnwr* or,newr,
oh
nos oovn pfopoMoL^iMfnOft), B.s KnpolKii to..convnMV
rrwde oac^ doc«*^;cortaln*d In tt» AdninWrdtv*.
f»coVtl confottt dl dpeuniontc, ropbrii, cndottwr mafwid ttw
reBed upon to reacting a Ctocidon on!fhe setecfion dfta proposed ptan.. The'
AdmlnbiratlYe Records, which includes fhefoosilnGfy riudy and ffA'sproposed pkn ;
Bock Hi, South CaTOftw2mif(«03)324:30S5
v:v:- .-'^i'?^:o^^i^:1it>^^u;^^ . ...
> These doewmnteara afco avciabtefoc wvi«wdtti» B»A Becorrft ponfer in Aflanta,'
Foe mom
. CyntWoPeuifoy,CommunityRelcfflon$Coordnafor : •'
U.S. EPA, Region IV, North SuporfuX* RemecBol Branch
N,En ABanta,
-------
5 9 0041
SOUTH CAROLINA BLACK MEDIA GROUP April 7-13,199* 9A
THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Announces an Extension of the Public Comment Period for the
Proposed Plan, Rutledge Property Superfund Site,
Rock Hill, York County, South Carol'na
The U. S. Environmental Protection Agency (EPA) to extending the period of time for
accepting public comments on the Agency's proposed cleanup plan, and the other
alternatives considered for the Rutledge Property Superfund Site to Monday. April
25.1994. Written comments, which must be postmarked on or before April 25.1994,
should be sent to:
Sheri Panabaker, Remedial Project Manager
U.S. EPA, Region IV, North Superfund Remedial Branch
345 Courtland Street, N.E., Atlanta, Georgia 90365
EPA win not moke a fined, cleanup decision for the stte unM ft has reviewed and
considered afl public comments H receives. Based on public comments or new
information, the EPA may decide on another alternative, rather than the plan that
has been proposed. Therefore. H is important to comment on the proposed plan
and the other alternatives evaluated in the feasibility study. Comments can also be
made on any documents contained in the Administrative Record for the site. The
administrative record contains all documents, reports, and other material the EPA
relied upon In reaching a decision on the selection of the proposed plan. The
Administrative Records, which includes the feasibility study and EPA's proposed plan
are available for public review at the Rutledge Site Information Repository located
at:
York County Library, 138 East Black Street,
Rock HDJ, South Caroina 29731, (803)324-3055
These documents are also available for review at the EPA Records Center in Atlanta,
GA. For more information, to request a copy of the proposed plan or to be added
to the site's mailing fist, please contact:
Cynthia PeurtJoy, Community Relations Coordnator
U.S. EPA. Region IV, North Superfund Remedial Branch
345 Courttand Street, N.E., Atlanta, Georgia 30365
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5 9 0042
Attachment C
Written Public Comments Received
During the Public Comment Period
-------
5O n n / -»
s U UH O
April 21, 1994
Mr. Samford T. Myers
North Superfund Remedial Branch
U S Environmental Protection Agency
Region IV
345 Courtland Street, NE
Atlanta, Georgia 30365
Subject: Rutledge Property (Rock Hill Chemical Company) Superfund Site
Rock Hill, South Carolina
Dear Mr. Myers:
RMT, Inc. reviewed the United States Environmental Protection Agency (EPA) Administrative Record
located at the York County Public Library for the Rutledge Property Superfund Site on behalf of the
following companies: BASF Inmont Corporation, Burlington Industries, Inc., Chase Packaging
Corporation, CTS Corporation, Engraph, Inc., FMC Corporation, Homelite Division of Textron, Inc..
Rexham, Inc., W.R. Grace and Company, and Celanese. The comments included below are being
submitted by these companies in response to EPA's Superfund Proposed Plan Fact Sheet for the
Rutledge Property (Rock Hill Chemical Company) Superfund Site, dated February 1994.
The EPA's Remedial Investigation and Feasibility Study (RI/FS) is summarized in the paragraphs below
to provide context for the comments that follow. By way of background, EPA's contractor conducted
a geophysical survey to identify buried objects, then collected 22 surface soil samples evenly spaced
across the site to identify potential hot spots. Afterwards, the contractor collected 40 subsurface soil
samples from 16 locations and installed five pairs of ground water monitoring wells on-site (each pair
consisted of a shallow well screened at the top of the surficial aquifer and a deep well screened at the
top of bedrock or several feet into the bedrock). EPA sampled the ten new wells, three existing
monitoring wells, one out-of-service commercial well, and three off-site private wells. EPA then
installed and sampled three more well pairs to fill data gaps in the monitoring well network. EPA also
sampled surface water and sediment in on-site drainage areas and conducted an ecological
screening.
EPA concluded from the investigation results that ground water contamination at the site presents an
unacceptable risk for a future residential land use scenario. The contaminants in ground water that
pose an alleged health risk are trichloroethene (TCE, max. concentration = 84,000 ug/I), 1.2-
dichloroethene (1,2-OCE, max concentration = 1,200 ug/I), vinyl chloride (VC, max concentration =
26 ug/I), and manganese (max concentration = 3,600 ug/I). EPA's risk calculations resulted in an
estimated excess cancer risk of approximately 5 x 10"8. EPA believes that manganese concentrations
present an unacceptable health risk based on a calculated hazard index of 25.
The baseline risk assessment showed that soils on-site are within acceptable risk limits. No risk-based
remedial goal options have been identified for surface soils. EPA determined that the hazard index for
manganese in soil, which it calculated as 5.75, was high but acceptable. Likewise, EPA concluded
that risks posed by volatile organic compound (VOC) and metals concentrations in the drainage areas
were acceptable.
li
RMT, INC - GREENVILLE, SC
lOOVoottBouimiD - 29607-3825
"«• P.O. Box 16778 - 29606-6778
803/281-0030 - 803/281-0288 FAX
-------
Mr. Samford T. Myers
US EPA Region IV
April 21, 1994
Page 2
The Feasibility Study (FS) contains EPA's preferred cleanup goals for ground water, which include the
promulgated Maximum Contaminant Levels (MCLs) for TCE, 1,2-DCE. and VC. For manganese, EPA
set a cleanup goal of 200 ug/l based on an average background concentration of 185 ug/l. In the FS,
EPA presented six possible remediation alternatives, including no action and limited action (deed
restrictions, long-term ground water monitoring). The four alternatives requiring action consisted of
ground water extraction and either 1) treatment on-site with discharge to surface waters or 2) no
treatment with discharge to the City of Rock Hill Publicly Owned Treatment Works (POTW).
EPA's Superfund Proposed Plan Fact Sheet for the Rutledge Property Superfund Site states EPA's
preference for Alternative 4-B, which includes extraction of ground water via two recovery wells,
discharge to the POTW, deed restrictions, and long-term ground water monitoring. While the Rl does
not provide evidence that any remedy is necessary, Alternative 4-6 appears to be a practical remedy
for the Rutledge site if one is required. However, while reviewing the Administrative Record, we noted
several issues that may impact the scope and cost of the remedy and which deserve comment
These issues include the following:
• The Record of Decision (ROD) should acknowledge that the Remedial Design for
Alternative 4-B can be simplified and shortened by eliminating the Intermediate Design
(60%) submittal. An intermediate submittal is unnecessary for such a straightforward
design. EPA will be able to judge the technical aspects of the design basis from the
Preliminary Design (30%) submittal. Since Alternative 4-B has no treatment
component, the only engineering review required for the design will be the extraction
wells and the connecting pipeline to the sewer system. These elements can easily be
reviewed and revised in conjunction with the Prefinal/Final Design reports.
• We did not find in the Administrative Record reference to an agreement between EPA
and the City of Rock Hill that the POTW would accept the extracted ground water.
Evidence of such an agreement should be reflected in the Record. If this has not
already been done, the POTW should be contacted to determine effluent acceptability
and to obtain such an agreement prior to issuing the Record of Decision.
• EPA's ground water cleanup goal for 1,2-dichloroethene is 70 ug/l. The Performance
Standard for 1,2-DCE should be split into two standards to reflect the MCLs of the'c/s-
and trans- isomers of 1,2-DCE. The trans- isomer has a higher MCL of 100 ug/L The
lower standard for the cis- isomer would apply whenever analytical results are
reported as total 1,2-dichloroethene.*
The Rl recommended additional study of the ecological communities that could be
impacted by this site, even though the Rl report states that the site does not pose a
threat to any state or federally listed species of concent The Rl's surface soil results
show that further migration of site contaminants to receiving waters is not anticipated.
The EPA's ecological screening did not identify any sensitive ecological communities
I.
••
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5 9 0044
Mr. Samford T. Myers
US EPA Region IV
April 21, 1994
Page 3
immediately downstream of the site. An ecological study is therefore likely to be
unproductive, and the money for it would be better spent on cleanup.
• The Rl Report recommended logging the depths of private wells PW-03 and PW-04 to
evaluate whether further characterization is needed, since chemicals detected in PW-
03 and PW-04 are similar to those detected on-site. The monitoring well network
constructed by EPA during the Rl is extensive and appears to be sufficient to make a
determination now that these constituents are not site related. Further ground water
investigation is unwarranted and will delay cleanup activities and divert funds that are
best spent on cleanup.
• The VOCs detected during the Rl were found in both top-of-rock and shallow wells.
The Superfund Proposed Plan Fact Sheet does not specify whether the extraction wells
will be constructed into rock. Extraction of ground water from bedrock fractures for
remediation purposes is difficult and, in most cases of Piedmont Irthology, technically
impracticable. At most, the two extraction wells proposed in Alternative 4-B should be
constructed into the first few feet of bedrock, where the rock is highly weathered and
fractured. The screen should be set to withdraw from both the saprolfte and the
weathered rock. Any attempt to construct wells that are screened in competent
bedrock is expected to result in a relatively useless extraction well, since the odds of
intercepting a producing fracture that is connected to the small plume found by EPA's
investigation are minute.
Please place these comments in the Administrative Record and consider them in the preparation of
the Record of Decision for the Rutledge Property Superfund Site.
Sincerely,
RMT, Inc.
Paul A. Furtick
Project Manager
cc: Rock Hill Chemical Company Site Generator PRPs
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April 25,1994
823 Standard St.
Rock Hill, S. C.
29730
Ms. Sheri Panabaker
Remedial Project Manager
U.S.EPA, Region IV
North Superfund Remedial Branch
345 Courtland St.
N.E. Atlanta, Georgia 30365
Dear Ms. Panabaker,
I received your handout advising me about an Extension
of the Public Comment Period for the Proposed Plan, Rutledge
Property Superfund Site, Rock Hill,S.C.I participated in
your meeting on March 1, 1994 concerning the above. The
input I added as well as other citizens, I hope will be
reviewed and consideration given our concerns.
In your notification of an extension , you indicated
that the EPA may decide on another alternative rather than
the plan that had been proposed. If this alternative plan
is different from those discussed on March 1, I would like
to be made aware of the plan chosen so that I and other
citizens may make further comments. At the meeting the
alternative plan being considered was Alternative Plan 4B -
Groundwater Pumping by 2 Extraction Wells and Direct
Discharge to POTW . MY concern with this method that was
tentatively selected,or any other method is that an
additional process such as pre-treatment on site of the
ground water be done before any other authority , whether
it be city or private , administers the final treatment as
required by the EPA Superfund Act.
You should also be concerned with the surrounding soil
within the borders of the affected area to eliminate further
problems down the road as you continue monotoring the
superfund site. This problem I understand existed over a
thirty year period. If you temporily clean the undergrond
water and not pay attention to the soil which contributed to
the problem, it would simply reoccur.
Other concerns that I have would be that more testing
be done opposite the site on Cherry Rd. and on any
bordering property that may be affected, and to insure the
safety of citizens in the area,the entire site should be
fenced off and signs need to be posted informing the public
of any possible danger.
In closing I would like to thank you for sending me
notification, and please keep me informed .
Sincerely,
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5 9 0045
Attachment D
Official Transcript of the Proposed Plan Public Meeting
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV PROPOSED PLAN MEETING FOR THE
RUTLEDGE PROPERTY (ROCK HILL CHEMICAL COMPANY)
SUPERFUND SITE
ROCK HILL, SOUTH CAROLINA
MARCH 1, 1994
REPORTER: KATHY STANFORD, CVR-CM
VERBATIM COURT REPORTING
P. O. Box 2711 CRS
ROCK HILL, S. C. 29730
(803) 328-9640
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1 PROCEEDINGS
2 ********
3 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
4 REGION IV PROPOSED PLAN MEETING FOR THE
5 RUTLEDGE PROPERTY (ROCK HILL CHEMICAL COMPANY)
6 SUPERFUND SITE
7 MARCH 1, 1994
8 7:10 P.M.
9 ********
10 " SANDY MYERS: GOOD EVENING AND WELCOME TO THE
11 PUBLIC MEETING, PROPOSED PLAN MEETING FOR THE RUTLEDGE
12 PROPERTY SITE. I APPRECIATE YOUR INTEREST IN COMING
13 TONIGHT AMID THE SEMI-MONSOON OUTSIDE. I REALLY DO
14 APPRECIATE IT. MY NAME IS SANDY MYERS, AND I'M THE
15 REMEDIAL PROJECT MANAGER WITH THE ENVIRONMENTAL
16 PROTECTION AGENCY REGION 4, BASED IN ATLANTA. WITH ME
17 TONIGHT ARE FELLOW EPA EMPLOYEES CYNTHIA PEURIFOY, SHE
18 IS THE COMMUNITY RELATIONS COORDINATOR; BERNIE HAYES,
19 WHO IS ANOTHER RPM OR REMEDIAL PROJECT MANAGER; AND MARK
20 DAVIS, WHO IS THE ATTORNEY FROM THE OFFICE OF REGIONAL
21 COUNSEL. ALSO WITH US TONIGHT FROM SOUTH CAROLINA
22 DEPARTMENT OF HEALTH AND ENVIRONMENTAL CONTROL CHUCK
23 GORMAN, BILLY BRITTON, AND RICHARD HAYNES. THE'AGENDA
24 FOR TONIGHT'S MEETING CONSISTS OF BASICALLY SIX
25 SEGMENTS. I'M OBVIOUSLY DOING THE WELCOME AND
26 INTRODUCTIONS. CYNTHIA IS GOING TO BRIEFLY DISCUSS THE
27 COMMUNITY RELATIONS PROGRAM. I'M GOING TO DISCUSS THE
28 SITE HISTORY. BERNIE HAYES IS GOING TO DISCUSS THE
29 BASELINE RISK ASSESSMENT PROCESS. I'M GOING TO COME
DALLAS REPORTING
Certified court Reporters
Rock Hill, South Carolina
(803) 328-9640
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004?
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BACK WITH THE REMEDIAL INVESTIGATION AND THE FEASIBILITY
STUDY, AND THEN WE'LL OPEN UP TO QUESTIONS AND ANSWERS.
WE'RE GOING TO DO OUR BEST TO LIMIT THIS MEETING TONIGHT
TO APPROXIMATELY 45. TO 50 MINUTES SO THAT WE CAN ALL BE
OUT. I WOULD LIKE TO NOW INTRODUCE CYNTHIA PEURIFOY.
SHE IS GOING TO EXPLAIN THE SUPERFUND PROCESS IN GENERAL
AND DISCUSS HOW AND WHY THE PUBLIC PLAYS SUCH AN
ESSENTIAL ROLE IN THE ULTIMATE DECISION MAKING PROCESS.
CYNTHIA PEURIFOY: GOOD EVENING. I WANT TO THANK
YOU FOR COMING OUT TONIGHT. AGAIN, MY NAME IS CYNTHIA
PEURIFOY, AND I AM THE COMMUNITY RELATIONS COORDINATOR
j
FOR THE SOUTH CAROLINA SECTION OF EPA'S REMEDIAL
PROGRAM. I WANTED TO FIRST OF ALL SET THE STAGE FOR
TONIGHT'S MEETING. THIS IS A PUBLIC HEARING, AND WE DO
NEED YOU TO COOPERATE WITH US TONIGHT BY WHEN YOU DO
HAVE A COMMENT OR A QUESTION, BY STANDING UP,
IDENTIFYING YOURSELF FOR OUR COURT REPORTER HERE AND
MAKING SURE THAT SHE IS ABLE TO HEAR WHAT YOU SAY.
THAT'S VERY IMPORTANT FOR US BECAUSE WE'RE HERE TO GET
YOUR COMMENTS AND YOUR CONCERNS ABOUT THE PROPOSED PLAN.
THE TRANSCRIPT THAT SHE IS GOING TO PRODUCE IS GOING TO
BE USED TO PREPARE WHAT WE CALL A RESPONSIVENESS SUMMARY
WHERE WE WILL SIT DOWN AND WE WILL RESPOND TO EVERY
CONCERN THAT WE HEAR HERE TONIGHT AND THROUGHOUT THIS
PUBLIC COMMENT PERIOD. SO PLEASE COOPERATE WITH HER AND
DALLAS REPORTING
Certified Court Reporters
Rock Bill, south Carolina
(803) 328-9640
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3
1 US BY MAKING SURE THAT WE CAN HEAR WHAT YOU HAVE TO SAY.
2 WE ARE IN A PUBLIC COMMENT PERIOD WHICH ENDS ON MARCH
3 24TH. HOWEVER, THERE IS A PROVISION THAT THAT COMMENT
4 PERIOD CAN BE EXTENDED FOR AN ADDITIONAL 30 DAYS. IF
5 YOU FIND THAT YOU NEED MORE TIME TO REVIEW THE DOCUMENTS
6 OR WHATEVER OR TO PREPARE YOUR COMMENTS, PLEASE GET IN
7 TOUCH WITH EITHER SANDY OR I AND WE WILL WORK WITH YOU
8 TO EXTEND THAT COMMENT PERIOD IF IT'S NEEDED. I WANTED
9 TO DRAW YOUR ATTENTION TO WHAT WE CALL THE SITE
10 INFORMATION REPOSITORY. IT IS AT THE YORK COUNTY
11 LIBRARY ON BLACK STREET. AND IN THAT LIBRARY, WE HAVE
12 PREPARED WHAT WE CALL OUR ADMINISTRATIVE RECORD, WHICH
13 IS A RECORD OF ALL THE DOCUMENTS THAT WERE COMPILED AND
14 USED BY SANDY AND THE OTHER PEOPLE WITHIN THE EPA AND
15 THE STATE TO PROPOSE THIS CLEANUP PLAN. THE REMEDIAL
16 INVESTIGATION AND FEASIBILITY STUDY REPORTS ARE THERE;
17 THE RISK ASSESSMENT IS THERE; EVERYTHING THAT YOU WILL
18 SEE REFERENCED IN THE PROPOSED PLAN FACT SHEET IS THERE
19 AND YOU CAN GO BY AND R£VIEW IT. I WANTED TO TALK A
20 LITTLE BIT ABOUT THE SUPERFUND PROCESS. AND I'M GOING
21 TO PUT THIS UP, AND I HOPE YOU CAN SEE IT, JUST TO LET
22 YOU KNOW THAT ON THIS PARTICULAR SITE WE HAVE BEEN
23 THROUGH SEVERAL STEPS OF THE SUPERFUND PROCESS. AND AS
24 YOU'LL SEE NUMBER 3, <», AND 5 HAVE BEEN CIRCLED BECAUSE
25 THAT'S REALLY WHERE WE ARE NOW. WE'RE MOVING OUT OF THE
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1 FEASIBILITY STUDY. WE'RE IN THE PROPOSED PLAN. WE'RE
2 .IN THE PUBLIC COMMENT PERIOD. A LOT HAS GONE ON THE
3 SITE. THE INVESTIGATION HAS BEEN COMPLETED. THE
4 FEASIBILITY STUDY HAS BEEN COMPLETED. THE PROPOSED PLAN
5 HAS BEEN SUBMITTED TO TEE PUBLIC. WHEN WE COMPLETE THIS
6 PUBLIC COMMENT PERIOD WE WILL BE DOING THE
7 RESPONSIVENESS SUMMARY AS I SAID EARLIER, AND TEEN WE
8 WILL BE PREPARING A RECORD OF DECISION. ONCE TEAT IS
9 DONE, WE WILL GO FORWARD WITH NEGOTIATIONS WITH
10 POTENTIALLY RESPONSIBL£ PARTIES. WE'LL MOVE INTO THE
11 REMEDIAL DESIGN AND IflTO THE CLEANUP. LET ME SAY A FEW
12 THINGS ABOUT THE COMMUNITY RELATIONS PROGRAM ITSELF. WE
13 HAVE A MAILING LIST FOR THE SITE. IF YOU'RE NOT ON THE
14 MAILING LIST, PLEASE SEE ME OR SIGN IN THAT SHEET BACK
15 THERE AND WE'LL GET YOU ON THE MAILING LIST. WE DO
16 PREPARE FACT SHEETS FROM TIME TO TIME. IF YOU HAVE THE
17 FACT SHEET THAT I SENT OUT RECENTLY YOU WILL SEE AN 800
18 NUMBER IN THAT FACT SHEET. WE ARE ALWAYS AVAILABLE AT
19 THAT NUMBER TO ANSWER ANY QUESTIONS OR CONCERNS YOU
20 MIGHT HAVE AND TO GET ANY FEEDBACK THAT YOU MIGHT HAVE
21 ON ANYTHING THAT YOU FEEL THAT WE NEED TO COVER ANY
22 INFORMATION THAT YOU DON'T HAVE THAT YOU'D LIKE TO HAVE.
23 ONE PROVISION OF THE SUPERFUND PROGRAM IS THAT
24 COMMUNITIES WHERE THERE ARE SUPERFUND SITES HAVE THE
25 ABILITY TO APPLY FOR A TECHNICAL ASSISTANCE GRANT. THAT
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1 IS A GRANT THAT WILL PROVIDE YOU THE ABILITY TO HIRE A
2 TECHNICAL ADVISOR TO ADVISE YOU ON THE DOCUMENTS AND
3 FINDINGS THAT EPA PUTS FORTH. SO IF ANYBODY HERE IS
4 INTERESTED IN LOOKING INTO THE TAG PROCESS, PLEASE FEEL
5 FREE TO SEE ME OR CALL ME ABOUT THAT. AND FINALLY, GIVE
6 ME YOUR FEEDBACK. LET ME KNOW HOW THIS MEETING IS, HOW
7 INFORMATIVE YOU THINK WE ARE. ARE WE OVER YOUR HEADS?
8 ARE WE NOT GETTING THE POINT ACROSS? WHATEVER. DO WE
9 NEED TO HAVE MORE MEETINGS? THAT IS MY ROLE TO MAKE
10 SURE THAT THE COMMUNITY IS INFORMED AND INVOLVED IN THE
11 PROCESS SO PLEASE HELP ME TO DO THAT FOR YOU, AND LET ME
12 KNOW WHAT YOU WOULD LIKE TO HAVE. THANK YOU.
13 SANDY MYERS: THANKS, CYNTHIA. I WOULD NOW LIKE TO
14 JUST GIVE A VERY BRIEF SITE HISTORY. THIS SITE,
15 HOPEFULLY YOU ALL CAN READ THIS, THIS SITE IS LOCATED ON
16 CHERRY ROAD AT THE CORNER OF CRANFORD STREET AND FARLOW
17 STREET. I HAVE ANOTHER SITE MAP THAT'S MORE OF A
18 CLOSEUP AND MIGHT BE OF SOME HELP. BETWEEN 1960 AND
19 1964, ROCK HILL CHEMICAL COMPANY OPERATED A SOLVENT
20 RECLAMATION FACILITY AT THAT SITE. CLASSIC WASTE
21 PRODUCTS SUCH AS PAINT SLUDGES, TEXTILE DYE PRODUCTS,
22 USED SOLVENTS, AND OTHER SOLID WASTES WERE GENERATED
23 DURING THE RECLAMATION PROCESS AND WERE STORED AND
24 . DISPOSED OF AT THE SITE. THE COMPANY CEASED OPERATIONS
25 IN THE SUMMER OF 1964. THE FOLLOWING OCTOBER A FIRE AT
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THE FACILITY CAUSED DRUMS OF OIL AND CHEMICALS TO
EXPLODE RELEASING THEIR CONTENTS INTO THE ENVIRONMENT.
TWO REMOVALS HAVE TAKEN PLACE AT THE SITE SINCE THEN.
IN 1985 A SOILS REMOVAL WAS DONE RIGHT IN THIS AREA HERE
BEHIND THE BANK. AND THEN BETWEEN 1987 AND '89 ANOTHER
SMALL SOILS REMOVALS AND A DRUM REMOVAL WAS DONE IN THIS
AREA HERE. THE SITE WAS LISTED ON THE NATIONAL
PRIORITIES LIST IN FEBRUARY OF 1990. THIS IS SIMPLY A
LIST OF CONTAMINATED SITES ACROSS THE UNITED STATES. IN
MARCH OF 1992, EPA INITIATED THE R.I.F.S., OR TEE
REMEDIAL INVESTIGATION FEASIBILITY STUDY. AND THIS IS
SIMPLY WE GO OUT AND WE FIGURE OUT THE EXTENT OF
CONTAMINATION, THE TYPE OF CONTAMINATION, AND WE ALSO
COME UP WITH A FEW ALTERNATIVES TO CLEAN THE PROBLEM UP.
I THINK IT'S VERY IMPORTANT TO NOTE RIGHT NOW IN THE
BEGINNING OF THIS TALK THAT THE RESULT OF THIS REMEDIAL
INVESTIGATION INDICATES THAT WE'VE ONLY GOT A
GROUNDWATER PROBLEM AT THE SITE, THEREFORE, GROUNDWATER
IS GOING TO BE THE ONLY MEDIA THAT WE REMEDIATE. " I WILL
DISCUSS IN MORE DETAIL THE R.I.F.S. IN A FEW MOMENTS.
FIRST, I'D LIKE TO INTRODUCE BERNIE HAYES. HE'S GOING
TO DISCUSS THE BASELINE RISK ASSESSMENT AND HOW IT
RELATES NOT ONLY TO SUPERFUND, BUT TO THE SITS IN
GENERAL.
BERNIE HAYES: THANK YOU, SANDY. YOU'LL HEAR A LOT
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1 OF TERMS TOSSED AROUND HERE TONIGHT. ONE OF TEEM IS
2 RISK ASSESSMENT SO I WANT TO TALK A LITTLE BIT ABOUT
3 WHAT EXACTLY THE RISK ASSESSMENT PROCESS CONSISTS OF.
4 I'LL TRY TO GO THROUGH THIS FAIRLY QUICKLY BECAUSE IT
5 CAN BE A LITTLE DRY. WHAT IS RISK ASSESSMENT? RISK
6 ASSESSMENT IS SIMPLY AN ATTEMPT BY TOXICOLOGISTS AND
7 HEALTH SCIENTISTS TO QUANTIFY THE POTENTIAL IMPACT TO
8 PUBLIC HEALTH RESULTING FROM CONTAMINATION AT THIS SITE
9 OR ANY OTHER SITE. IN OTHER WORDS, RISK ASSESSMENT IS
10 JUST LOOKING AT THE CONTAMINATION THAT EXISTS AT THE
11 SITE, LOOKING AT THE VARIOUS WAYS IN WHICH PEOPLE MIGHT
12 BE EXPOSED TO THAT CONTAMINATION, AND THEN TRYING TO
13 QUANTIFY OR PUT A NUMBER TO THE EFFECTS THAT MIGHT
14 RESULT FROM THAT CONTAMINATION. THE OTHER TERM YOU
15 MIGHT HEAR AND SEE IN THE REPOSITORY IS BASELINE RISK
16 ASSESSMENT. BASELINE RISK ASSESSMENT IS THE ESTIMATE OF
17 RISK TO THE PUBLIC HEALTH THAT WOULD RESULT IF THE SITE
18 WERE LEFT UNREMEDIATED. WE NOT ONLY LOOK AT THE CURRENT
19 RISK ASSOCIATED WITH THE SITE UNDER CURRENT LAND-USE AND
20 CURRENT EXPOSURE SCENARIOS, BUT WE ALSO LOOK AT WHAT
21 RISK WOULD RESULT IF WE JUST WALKED AWAY FROM THE SITE
22 IN THE FUTURE AND LEFT IT UNREMEDIATED. WE LOOK AT THE
23 RISK TO PUBLIC HEALTH UNDER FUTURE EXPOSURE SCENARIOS OF
24 VARIOUS TYPES. IT SAYS THAT WE TRY TO QUANTIFY THE
25 LEVELS OF RISK. AND HOW DO WE QUANTIFY THOSE LEVELS OF
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^ 5 9 0050
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1 RISK? WE ESTIMATE EXPOSURE LEVELS BY IDENTIFYING
2 COMPLETE EXPOSURE PATHWAYS LEADING FROM A SOURCE OF
3 CONTAMINATION AND SUPERFUND THE SITE TO A POINT OF HUMAN
4 OR PUBLIC EXPOSURE. IN OTHER WORDS, THERE HAS TO BE A
5 RELEASE OF CONTAMINANTS FROM THE SITE. THERE HAS TO BE
6 A WAY FOR THOSE CONTAMINANTS TO GET FROM THE SOURCE TO A
7 POINT OF EXPOSURE, AND THEN EXPOSUR£ TO THE PUBLIC HAS
8 TO TAKE PLACE. THIS IS AN EXAMPLE OF A COUPLE OF THE
9 TYPES OF EXPOSURE PATHWAYS WE LOOK AT IN A SUPERFUND
10 RISK ASSESSMENT. WE HAVE A SITE OR A SOURCE OF
11 CONTAMINATION SHOWN BY THESE DRUMS LYING ON THE GROUND
12 HERE. AND THERE ARE TWO PATHWAYS, COMPLETE EXPOSURE
13 PATHWAYS, ILLUSTRATED. ONE WOULD BE IF CONTAMINANTS
14 WERE RELEASED INTO THE AIR THROUGH VOLATILIZATION OR
15 SOME OTHER PROCESS. THE WIND WOULD THEN BLOW THEM TO A
16 POINT WHERE PEOPLE ROUTINELY WERE FOUND, AND PEOPLE
1.7 WOULD BREATHE IN THOSE CONTAMINANTS WITH THE AIR. THE
18 OTHER ONE AND THE ONE THAT IS MORE GERMANE TO THIS SITE
19 AS SANDY HAS ALREADY MENTIONED IS THE GROUNDWATER-
20 PATHWAY WHERE CONTAMINANTS FROM THE SITE COULD BE
21 RELEASED INTO THE GROUNDWATER, FLOWS WITH THE
22 GROUNDWATER TOWARDS TH£ WELL, IT'S DRAWN INTO TEE WELL,
23 AND SOMEBODY USING THAT WELL DRINKS IT OR IS EXPOSED TO
24 IT THROUGH SHOWERING OR WASHING OR ANY OTHER PATHWAY.
25 WE LOOK AT A LOT OF DIFFERENT PATHWAYS, NOT JUST THOSE
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9
1 THAT WERE IN THAT ILLUSTRATION. AND I APOLOGIZE FOR THE
2 CRUDITY OF THIS DRAWING HERE; IT LOOKS A LITTLE 3IT LIKE
3 ELVIS I THOUGHT. THE PRINCIPAL ROUTES OF HUMAN EXPOSURE
4 THAT WE LOOK AT ARE: INHALATION, BREATHING IN
5 CONTAMINANTS; INGESTION, WHICH MEANS ANYTHING TAKEN IN
6 BY MOUTH; AND DERMAL ABSORPTION, WHICH IS THE ONE THAT
7 NOT MANY PEOPLE MIGHT BE FAMILIAR WITH. DERMAL
8 ABSORPTION JUST MEANS THINGS THAT ARE ABSORBED THROUGH
9 THE SKIN, DIRECTLY THROUGH SKIN ON ANY PART OF THE BODY.
10 THE FIRST ONE IS INHALATION. THIS IS PRETTY BASIC
11 STUFF. INHALATION EXPOSURE OCCURS THROUGH THE BREATHING
12 OF VAPORS. AN EXAMPLE OF THAT MIGHT BE AT TEE GAS
13 STATION WHERE YOU'RE PUMPING GAS AND YOU SMELL THE
14 FUMES, THE ACTUAL GASEOuS SUBSTANCE THAT YOU BREATHE IN.
15 THE SECOND FORM OF INHALATION EXPOSURE OCCURS THROUGH
16 THE BREATHING IN OF CONTAMINATED DUST OR AIRBORNE
1-7 PARTICLES; SOIL THAT DRYS OUT, GETS BROKEN UP, AND IS
18 CARRIED IN THE WIND AND BREATHED IN IN THAT FASHION.
19 THE SECOND ONE, INGESTION, CAN HAPPEN IN A LOT OF WAYS
20 THAT WE MIGHT NOT THINK ABOUT. INGESTION CAN OCCUR
21 THROUGH EATING CONTAMINATED FOOD OR DRINKING
22 CONTAMINATED WATER WHICH ARE THE ROUTES OF EXPOSURE MOST
23 COMMONLY YOU MIGHT MOST COMMONLY THINK OF. WE
24 ALSO CAN HAVE INCIDENTAL OR ACCIDENTAL INGESTION OF
25 SOIL. PEOPLE ON THE SITE WHO GET SOIL ON THEIR HANDS OR
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ON THEIR BODY SOMEHOW AMD ACCIDENTLY GET IT IN THEIR
MOUTH. THE SAME THING IS TRUE WITH INCIDENTAL OR
ACCIDENTAL INGESTION OF CONTAMINATED WATER WHILE
SWIMMING OR BOATING OR WADING. AGAIN, ANY TIME YOU'RE
IN CONTACT WITH WATER DURING RECREATIONAL ACTIVITIES
THERE'S A CHANCE THAT YOU MIGHT ACTUALLY GET SOME OF IT
IN YOUR MOUTH. AND WE LOOKED AT ALL OF THESE EXPOSURE
PATHWAYS AS PART OF THIS RISK ASSESSMENT, AND I'LL TALK
ABOUT THE RESULTS OF SOME OF THESE EXPOSURE PATHWAYS IN
A SECOND. DERMAL ABSORPTION OCCURS WHEN CONTAMINANTS
ARE ABSORBED DIRECTLY THROUGH THE SKIN. SKIN IS A GOOD
BARRIER AGAINST WATER. IT'S A GOOD BARRIER AGAINST
BACTERIA; CERTAIN OTHER TYPES OF WHAT WE CALL INORGANIC
CONTAMINANTS, IN OTHER WORDS, METALS OR THINGS THAT
AREN'T ORGANIC IN NATURE, AND JUST SOILS AND DIRT AND
THINGS LIKE THAT. SKIS IS NOT A VERY EFFECTIVE BARRIER.
IT'S A MUCH LESS EFFECTIVE BARRIER AGAINST CERTAIN TYPES
OF ORGANIC CONTAMINANTS. A LOT OF TIMES WHEN YOU SEE
HOUSEHOLD CLEANERS OR HOUSEHOLD CHEMICALS THAT SAY IF
YOU GET IT ON YOUR SKIN WASH IT OFF, HOUSEHOLD
PESTICIDES, EVEN GASOLINE. SOME OF THE COMPONENTS OF
GASOLINE ARE A GOOD EXAMPLE. IF YOU GET IT ON YOUR
SKIN, IT CAN BE ABSORBED DIRECTLY THROUGH THE SKIN. SO
WHILE SKIN IS AS A HUMAN ORGANISM IS A PRETTY GOOD
BARRIER FOR CERTAIN TYPES OF CONTAMINANTS AND CERTAIN
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11
1 TYPES OF HEALTH THREATS, IT'S NOT A GOOD ONE FOR OTHERS.
2 TAKING INTO ACCOUNT DERMAL ABSORPTION, INHALATION, AND
3 INGESTION, WE LOOKED AT FOUR EXPOSURE PATHWAYS AT THE
4 RUTLEDGE PROPERTY SITE. THE FIRST IS JUST AN ON SITE
5 WORKER. ASSUMING THAT THERE MIGHT ACTUALLY BE THE
6 SITE MIGHT ACTUALLY BE USED FOR INDUSTRIAL OR COMMERCIAL
7 PURPOSES IN THE FUTURE. THE SECOND IS A SITE VISITOR.
8 ANOTHER WAY TO LOOK AT THE SITE VISITOR MIGHT BE SITE
9 TRESPASSER OR CHILDREN PLAYING ON THE SITE OR ANYONE
10 JUST WALKING THROUGH THE SITE. AND THEN THOSE TWO NOT
11 NOTED THERE ARE CURRENT EXPOSURE CONDITIONS THAT MIGHT
12 EXIST NOW, BUT WE ALSO LOOKED AT FUTURE EXPOSURE
13 CONDITIONS. WE LOOKED AT BOTH AN ADULT AND A CHILD WHO
14 MIGHT LIVE ON THE SITE IN THE FUTURE. AND AS I SAID, WE
15 LOOKED AT INHALATION, INGESTION, AND DERMAL EXPOSURE FOR
16 THE TWO CURRENT AND THE TWO FUTURE EXPOSURE SCENARIOS.
17 FOR THE ON SITE WORKER, WE JUST LOOKED AT TWO PATHWAYS.
18 WE LOOKED AT INCIDENTAL INGESTION OF SURFACE SOILS, IN
19 OTHER WORDS THE SOILS THAT ARE ON THE SURFACE TEAT ARE
20 CONTAMINATED, ACCIDENTAL INGESTION OF THOSE SOILS
21 THROUGH HAND TO MOUTH CONTACT WHILE SOMEONE MIGHT BE
22 WORKING THERE WHETHER IT BE SMOKING, EATING THEIR LUNCH,
23 WHATEVER WAY THAT THAT MIGHT HAPPEN. AND THEN IF THOSE
24 CONTAMINATED SOILS GET ON THEIR HANDS OR THEIR SKIN OR
25 THEIR FACE AND ABSORPTION FROM THE SOIL DIRECTLY THROUGH
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5 9 0052
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1 THE SKIN. FOR THE SITE VISITOR, WE ADDED - - - WE
2 LOOKED AT THOSE TWO PATHWAYS, BUT WE ADDED SOME OTHERS.
3 IN ADDITION TO THE INCIDENTAL INGESTION OF SOILS AND
4 DERMAL ABSORPTION OF CONTAMINANTS FROM SOILS, WE ALSO
5 ADDED INCIDENTAL INGESTION OF CONTAMINATED SEDIMENTS,
6 SEDIMENTS BEING THE MUD AND SOIL PARTICLES THAT LIE AT
7 THE BOTTOM OF THE STREAMS AND DRAINAGE PATHWAYS THAT ARE
8 ON THE SITE, AND ALSO THE INCIDENTAL INGESTION OF
9 SURFACE WATER, CONTAMINATED SURFACE WATER, AND THEN
10 DERMAL ABSORPTION FROM THOSE TWO SOURCES AS WELL.
11 AGAIN, THIS SITE VISITOR BEING SOMEONE WHO MIGHT JUST
12 WANDER ONTO THE SITE ArJD WADE OR PLAY AS A CHILD MIGHT
13 IN THE STREAMS THAT A£c£ OUT THERE. FOR THE ADULT
14 RESIDENT WE LOOKED AT THOSE CONTAMINANT PATHWAYS AND
15 THEN ADDED A FEW MORE. SO IN ADDITION TO THE ONES FOR
16 THE SITE VISITOR, INGESTION OF SURFACE SOILS, SURFACE
17 WATER, SEDIMENTS, WE ADDED GROUNDWATER. IN OTHER WORDS,
18 PRESUMING THAT SOMEBODY MIGHT BUILD A HOUSE THERE, DRILL
19 A WELL INTO THE CONTAMINATED GROUNDWATER PLUME, AND
20 DRINK THE WATER FROM TEAT WELL. IN ADDITION, WE ADDED
21 INHALATION OF VOLATILE CONTAMINANTS RELEASED WHILE
22 SHOWERING WHICH IS ALSO A GROUNDWATER PATHWAY. IF THE
23 WATER SUPPLY FOR A HOUSE BUILT ON THAT SITE WERE A WELL
24 DRILLED INTO THE CONTAMINATED GROUNDWATER, THAT WELL
25 WERE USED FOR SHOWERING, CERTAIN OF THE CONTAMINANTS
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13
1 THAT EXIST AT THE SITE WOULD BE RELEASED INTO THE AIR.
2 SOMEONE TAKING A SHOWER WOULD BREATHE THEM IN AND THEY
3 WOULD BE EXPOSED THROUGH INHALATION IN THAT MATTER. SO
4 WE ADDED IN ADDITION TO ALL THOSE OTHERS, THE
5 VOLATILIZATION OF CONTAMINANTS WHILE SHOWERING. FOR THE
6 CHILD RESIDENT, THESE PATHWAYS ARE EXACTLY THE SAME.
7 THE ONLY REASON I HAVE THIS SLIDE HERE IS TO EXPLAIN A
8 LITTLE BIT OF THE DIFFERENCE OF HOW WE LOOK AT CHILD
9 EXPOSURE VERSUS ADULT EXPOSURE. THESE ARE THE SAME
10 EXPOSURE SCENARIOS, THE SAME EXPOSURE PATHWAYS, BUT FOR
11 ADULTS AND CHILDREN WE QSE DIFFERENT EXPOSURE
12 FREQUENCIES, WE USE IN OTHER WORDS, THEY'RE
13 EXPOSED AT A DIFFERENT RATE. THEY'RE EXPOSED FOR A
14 DIFFERENT LENGTH OF TIME. WE EXTRAPOLATE THE EXPOSURE
15 ONLY OVER A CERTAIN FEW YEARS OF CHILDHOOD AS OPPOSED TC
16 AN ENTIRE LIFETIME, AND THEN ADD THAT ONTO TEE ADULT
17 EXPOSURE. AND PROBABLY THE MOST IMPORTANT THING IS THAT
18 WE ALSO LOOK AT THE BODY WEIGHT OF A CHILD AS OPPOSED TO
19 AN ADULT. THE SEVERITY OF EXPOSURE IS DEPENDENT TO SOME
20 EXTENT ON BODY WEIGHT. SOMEONE WHO IS HEAVIER, HAS A
21 GREATER MASS LIKE MYSELF, CAN BE EXPOSED TO A GREATER
22 LEVEL OF TOXIC CONTAMINANTS AND NOT EXPERIENCE ANY
23 ADVERSE EFFECTS. A CHILD WHO IS LIGHTER OR A LIGHTER
24 PERSON CAN ONLY EXPERIENCE PROPORTIONALLY LIGHTER OR
25 PROPORTIONALLY LESS EXPOSURE FOR THE SAME EFFECT. SO
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t> y 0053
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1 FOR CHILDREN, WE LOOK AT THAT LOWER BODY WEIGHT IN
2 EVALUATING THE CONTAMINANT EFFECTS. THIS IS A LIST OF
3 THE CONTAMINANTS THAT WERE FOUND AT THE SITE. AND
4 THERE'S A BIG LAUNDRY LIST OF THEM. THE IMPORTANT THING
5 IS NOT SO MUCH THE NUMBERS BECAUSE THE NUMBERS ARE ALL
6 OVER THE PLACE. THE IMPORTANT THING IS TO NOTE THAT WE
7 LOOKED AT A LARGE NUMBER OF CONTAMINANTS, ESSENTIALLY
8 ALL THE CONTAMINANTS THAT WERE FOUND ABOVE BACKGROUND
9 LEVELS OUT THERE. AND JUST FROM A QUALITATIVE SENSE,
10 I'LL SAY THAT FOR THE MOST PART, THESE LEVELS OF
11 CONTAMINATION ARE NOT PARTICULARLY HIGH OR TEAT IN
12 OTHER WORDS, THEY'RE SOT SIGNIFICANT IN TERMS OF RISK.
13 AS SANDY HAS ALREADY MENTIONED, THE ONLY ONES THAT ARE
14 SIGNIFICANT IN TERMS OF RISK ARE SOME OF THE GROUNDWATER
15 NUMBERS FOR JUST A PEW OF THE CONTAMINANTS, AND I'LL GO
16 INTO THAT IN A LITTLE MORE DETAIL IN A MINUTE. BUT FOR
17 MOST OF THE CONTAMINANTS AND FOR MOST OF THE MEDIA,
18 SURFACE SOIL, SURFACE WATER, AND SEDIMENTS, THE
19 CONTAMINANT LEVELS ARE NOT SIGNIFICANT IN TERMS OF RISK.
20 WHENEVER WE LOOK AT A BASELINE RISK ASSESSMENT, WE HAVE
21 TO LOOK AT THE TOXICITY OF THE CONTAMINANTS INVOLVED.
22 DIFFERENT CONTAMINANTS tiAVE DIFFERENT TOXIC EFFECTS.
23 HOW TOXIC ARE THE CONTAMINANTS THAT WE FOUND THERE AND
24 IN WHAT WAY ARE THEY TOXIC? WE GENERALLY LOOK AT TOXINS
25 AND SPLIT THEM UP INTO TWO CATEGORIES: CARCINOGENS
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1 VERSUS NON-CARCINOGENS. CARCINOGENS ARE CONTAMINANTS
2 WHICH ARE KNOWN TO CAUSE OR ARE SUSPECTED OF CAUSING THE
3 DEVELOPMENT OF CANCER. MANY CONTAMINANTS INCLUDING SOME
4 OF THE ONES FOUND HERE ARE NOT CONSIDERED TO BE
5 CARCINOGENIC, BUT HAVE OTHER ADVERSE HEALTH IMPACTS; FOR
6 INSTANCE, TOXIC EFFECTS ALL SPECIFIC ORGANS SUCH AS THE
7 KIDNEYS OR THE LIVER. THERE ARE SOME CONTAMINANTS WHICH
8 HAVE BOTH CARCINOGENIC AND NON-CARCINOGENIC EFFECTS. WE
9 TRY TO CONTROL EXPOSURE TO THOSE BASED ON WHICH OF THOSE
10 TWO IS THE MOST SEVERE OR THE MOST LIKELY. FOR NON-
11 CARCINOGENS, WE DEAL WITH THE EXPOSURE TO CARCINOGENS
12 AND NON-CARCINOGENS DIFFERENTLY. FOR NON-CARCINOGENS,
13 IT'S ASSUMED THAT AT CERTAIN LOW LEVELS OF EXPOSURE,
14 THERE ARE NO ADVERSE IMPACTS. IN OTHER WORDS, YOU CAN
15 BE EXPOSED TO A CERTAIN AMOUNT OF A NON-CARCINOGEN UP TO
16 A CERTAIN THRESHOLD LEVEL AND BELOW THAT THERE ARE NO
17 IMPACTS. YOUR BODY CAN HANDLE THAT EXPOSURE. ABOVE
18 THAT THRESHOLD LEVEL, THEN ADVERSE IMPACTS RESULT. AT
19 SUPERFUND SITES, WE'RE REQUIRED TO REDUCE NON-CARCINOGEN
20 RISK TO A LEVEL SUCH THAT THE HAZARD INDEX RESULTING
21 FROM EXPOSURE TO THOSE CONTAMINANTS IS LESS THAN ONE.
22 SOME CONFUSING TERMS THERE, BUT THE HAZARD INDEX IS
23 DEFINED AS THE RATIO OF THE LEVEL OF ACTUAL EXPOSURE
24 COMPARED TO THE SAFE LEVEL OF INTAKE FOR THAT GIVEN
25 CONTAMINANT. IN OTHER WORDS, IF YOU JUST PUT THE
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5_2 0054^
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1 EXPOSURE LEVEL DIVIDED BY THE SAFE LEVEL, IF THAT'S
2 GREATER THAN ONE, OBVIOUSLY YOU'RE OVER THE SAFE LEVEL
3 OF EXPOSURE AND THAT'S A PROBLEM. THIS SAFE INTAKE LEVEL
4 IS KNOWN AS THE REFERENCE DOSE, AND THAT REFERENCE DOSE
5 IS DEPENDENT LIKE THINGS LIKE BODY WEIGHT, IT'S
6 DEPENDENT ON AGE. WHEN WE DO A RISK ASSESSMENT, WE USE
7 THE MOST ESSENTIALLY A WORSE CASE EVALUATION OF
8 REFERENCE. IN OTHER WORDS, WE USE THE MOST STRINGENT OF
9 THE VARIOUS REFERENCE DOSES THAT MIGHT EXIST FOR A GIVEN
10 CONTAMINANT. CARCINOGENS ARE DIFFERENT. WHEN WE DO
11 TOXICITY ASSESSMENT FOR CARCINOGENS, WE ASSUME THAT ANY
12 CONTAMINATION TO A CARCINOGEN, NO MATTER HOW SMALL,
13 RESULTS IN A PROPORTIONAL LEVEL OF RISK. IN OTHER
14 WORDS, THERE IS NO ZERO RISK LEVEL OF EXPOSURE AS THERE
15 ARE FOR NON-CARCINOGENS. AT SUPERFUND SITES, WE'RE
16 REQUIRED TO REDUCE THE AISK ASSOCIATED WITH EXPOSURE TO
17 CARCINOGENS TO LESS THAN ONE TIMES TEN TO THE MINUS
18 FOUR. IN OTHER WORDS, IN TERMS OF ODDS, ONE IN TEN
19 THOUSAND. FOR THE RUTLEDGE SITE THIS MEANS TEAT-UNDER
20 EVEN THE MOST WORSE CASE AND STRINGENT EXPOSURE
21 SCENARIOS WHICH INCLUDES THE FUTURE EXPOSURE SCENARIO OF
22 PEOPLE LIVING ON THE SITE FOR THEIR ENTIRE LIVES, THAT
23 MEANS THOSE RESIDENTS SHOULD NOT HAVE A GREATER THAN ONE
24 IN TEN THOUSAND CHANCES OF CONTRACTING CANCER DUE TO
25 EXPOSURE TO SITE CONTAMINANTS. THAT'S AN IMPORTANT
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1 POINT, EXPOSURE TO SITE CONTAMINANTS. THIS ONE IN TEN
2 THOUSAND IS THE EXCESS RISK ASSOCIATED WITH THE SITE,
3 THE RISK ABOVE AND BEYOND THE RISK THAT WE ALL FACE
4 LIVING IN A MODERN ENVIRONMENT OF CONTRACTING CANCER.
5 THE RISK IS FAIRLY HIGH AS WE ALL KNOW. A VERY MANY
6 PEOPLE CONTRACT CANCER AND DIE FROM CANCER. AND IT'S
7 NOT CLEARLY UNDERSTOOD WHAT ALL THE CAUSES ARE OR WHAT
8 ALL THE REASONS WHY PEOPLE CONTRACT CANCER. BUT WHAT WE
9 TRY TO DO IN CONTROLLING CARCINOGENIC RISK FROM A
10 SUPERFUND SITE IS MAKE SURE THAT THE ADDITIONAL RISK
11 THAT ANYONE EXPERIENCES AS A RESULT OF SITE
12 CONTAMINATION IS ONE IN TEN THOUSAND. ACTUALLY, YOUR
13 RISK OF CONTRACTING CAiSlCER IF YOU LIVED TO A RIPS OLD
14 AGE IS PRETTY MUCH ONE IN FOUR OR OSE IN THREE. SO THE
15 EXCESS RISK THAT WE TRY TO CONTROL SITE EXPOSURE TO IS
16 MUCH, MUCH LESS THAN THE ENVIRONMENTAL RISK THAT WE ALL
1.7 EXPERIENCE FROM LIVING IN A MODERN WORLD. SO WE'RE NOT
18 SAYING THAT BY CONTROLLING THE RUTLEDGE PROPERTY
19 EXPOSURE THAT WE'RE GOING TO REDUCE EVERYBODY'S
20 INDIVIDUAL RISK OF CANCER TO ONE IN TEN THOUSAND; WE'RE
21 JUST GOING TO REDUCE THE RISK ASSOCIATED WITH THIS SITE
22 TO ONE IN TEN THOUSAND OR LESS. WITH THAT IN MIND, I'M
23 GOING TO JUMP RIGHT TO THE RESULTS OF THE RISK
24 ASSESSMENT. HERE'S A BREAKDOWN OF THE SITE RISKS, THE
25 FOUR EXPOSURE SCENARIOS, THE HAZARD INDEX, WHICH IS NON-
DALLAS REPORTING
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5-9 0055
- 18
1 CARCINOGENIC RISK, AND CARCINOGENIC RISK. FOR THE ON
2 SITE WORKER AND THE SITE VISITOR YOU CAN SEE THAT THE
3 HAZARD INDEX IS MUCH, MUCH LESS THAN ONE AND THAT THE
4 CARCINOGENIC RISK IS VERY LOW. NOW, CONVERTING THOSE
5 NUMBERS TO ODDS, THIS IS ABOUT ONE IN A HALF A MILLION
6 AND THIS IS ABOUT ONE IN FIVE MILLION. FOR TEE FUTURE
7 EXPOSURE SCENARIOS FOR THE ADULT RESIDENT AND THE CHILD
8 RESIDENT, THE HAZARD INDEX IS MUCH GREATER THAN ONE
9 WHICH MEANS THERE IS AN UNACCEPTABLE LEVEL OF RISK, AND
10 THE CARCINOGENIC RISK IS MUCH GREATER THAN ONE TIMES TEN
11 TO THE MINUS FOUR WHICH AGAIN MEANS THERE IS AN
12 UNACCEPTABLE CARCINOGENIC RISK. RATHER THAN COMPARED TO
13 THE ONE IN TEN THOUSAND, THIS IS ABOUT ONE IN SEVENTY
14 AND THIS IS ABOUT ONE Itt A HUNDRED. SO ONCE WE HAVE
15 DETERMINED THAT THERE IS AN UNACCEPTABLE LEVEL OF RISK
*
16 ASSOCIATED WITH THE SITE, WE TRIED TO LOOK AT WHERE IS
1-7 THAT RISK COMING FROM. AND REMEMBER FROM THAT PREVIOUS
18 SLIDE THE CURRENT RISK LEVELS ARE ACCEPTABLE; IT'S ONLY
19 THE FUTURE EXPOSURE SCENARIOS, THE IDEA THAT SOMEONE
20 WOULD COME THERE, BUILD A HOUSE ON THE SITE, SINK A WELL
21 INTO THE CONTAMINATED GROUNDWATER, AND USE THAT AS A
22 POTABLE WATER SUPPLY FOR DRINKING, COOKING, BATHING.
23 BUT EVEN UNDER THOSE EXPOSURE SCENARIOS, WE LOOK AT
24 WHERE THE RISK IS COMING FROM. AND AS SANDY HAS ALREADY
25 MENTIONED, IT'S ALL COMING FROM GROUNDWATER PATHWAYS,
DALLAS REPORTING
Certified Court Reporters
Rock Hill, South Carolina
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-------
19
1 DRINKING/ AND SHOWERING. THE HAZARD INDEX ASSOCIATED
2 WITH THAT PATHWAY IS 400. THE RISK IS ABOUT ONE IN
3 SEVENTY AGAIN. ALL THE OTHER PATHWAYS, THE CONTACT WITH
4 SOIL, THE ACCIDENTAL INGESTION OF SOIL, THE PLAYING IN
5 THE CREEKS, ALL THAT ADDS UP TO A HAZARD INDEX OF .32;
6 AGAIN MUCH LESS THAN ONE, AND A CARCINOGENIC RISK OF
7 ABOUT THREE TIMES TEN TO THE MINUS FIVE WHICH IS ABOUT
8 ONE IN THIRTY-THREE THOUSAND. SO IF WE COULD CONTROL
9 THE GROUNDWATER PATHWAY AND EXPOSURE TO CONTAMINATED
10 GROUNDWATER, WE CAN ESSENTIALLY ELIMINATE ALL OF THE
11 UNACCEPTABLE RISK ASSOCIATED WITH THIS SITE STILL
12 KEEPING IN MIND THAT THAT UNACCEPTABLE RISK IS STILL
13 BASED ONLY ON FUTURE EXPOSURE| SCENARIOS, EXPOSURE
14 SCENARIOS WHICH DON'T EXIST'NOW. THAT WAS FOR THE
15 ADULT. THIS IS THE SAME THING FOR THE CHILD. IT'S THE
16 SAME STORY, IT'S JUST THAT THE RISK NUMBERS ARE A LITTLE
1-7 HIGHER. THE HAZARD INDEX 948 RATHER THAN 400 JUST
18 REFLECTS AGAIN THE SMALLER BODY WEIGHT OF THE CHILD, THE
19 GREATER FREQUENCY THAT A CHILD MIGHT PLAY IN A CREEK AS
20 OPPOSED TO AN ADULT. HOPEFULLY, MOST ADULTS WOULDN'T GO
21 OUT AND PLAY IN THE CREEK EVEN IF THEY KNEW IT WAS - - -
22 WHETHER THEY KNEW IT WAS CONTAMINATED OR NOT. ALL THE
23 OTHER PATHWAYS WELL, FOR THE CHILD RESIDENT,
24 THERE'S STILL SOME UNACCEPTABLE RISK ASSOCIATED WITH
25 SOME OF THE OTHER PATHWAYS, BUT THIS AGAIN IS A FUTURE
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5 9 0056
20
1 EXPOSURE SCENARIO AND IS NOT OCCURRING NOW. AND THE
2 CARCINOGENIC RISK IS VERY LOW AGAIN/ ABOUT ONE IN
3 TWENTY-THREE THOUSAND. AND THEN THE FINAL QUESTION ONCE
4 WE IDENTIFY THAT THERE IS SOME RISK AT THE SITE, WHAT
5 CONTAMINANTS ARE CAUSING THE RISK. REMEMBER THAT BIG
6 LAUNDRY LIST OF CONTAMINANTS THAT WE HAD? I DON'T KNOW
7 EXACTLY HOW MANY, 25 OR 30, WHAT CONTAMINANTS ARE
8 CONTRIBUTING TO THE EXCESS RISK AT THE SITE? FOR THE
9 ADULT RESIDENT, 99.8 PERCENT OF THE NON-CARCINOGENIC
10 RISK COMES FROM THREE CONTAMINANTS IN THE GROUNDWATER:
11 MANGANESE, TRICHLOROETHENE EXCUSE ME, THREE
12 CONTAMINANTS, AND i,2 D1CHLOROETHENE. ONE HUNDRED OF
13 THE CARCINOGENIC RISK COMES PJROM TWO CONTAMINANTS:
14 TRICHLOROETHENE, WHICH IS ONE OF THE SAME FOR THE NON-
15 CARCINOGENIC RISK, AJND tflNYL CHLORIDE. FOR THE CHILD
16 RESIDENTS, THE SAME CONTAMINANTS CONTRIBUTE ALMOST
17 EXACTLY THE SAME LEVELS OF RISK. I MIGHT POINT OUT THAT
18 1,2 DICHLOROETHENE AND VINYL CHLORIDE ARE LIKELY TO BE
19 BREAKDOWN OR DEGRADATION PRODUCTS OF THE
20 TRICHLOROETHENE. SO PROBABLY THERE'S A TRICHLOROETHENE
21 PROBLEM THERE OR A DISPOSAL THERE AT ONE TIME. OVER THE
22 YEARS, NATURAL DEGRADATION PRODUCTS TEND TO BREAK THAT
23 DOWN INTO LESS COMPLEX MOLECULES, AND THOSE DEGRADATION
24 PRODUCTS TEND TO BE 1,2 DICHLOROETHENE AND VINYL
25 CHLORIDE. SO YOU'RE SEEING NOT ONLY THE ORIGINAL SOURCE
DALLAS REPORTING
Certified Court Reporters
Rock Bill, south Carolina
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-------
21
1 OF THE PROBLEM IN THE TRICHLOROETHENE, BUT ALSO IN THE
2 BREAKDOWN PRODUCTS OF THAT OVER TIME. SO FINALLY,
3 CONCLUSIONS ASSOCIATED WITH THE RUTLEDGE BASELINE RISK
4 ASSESSMENT, THERE IS NO UNACCEPTABLE RISK UNDER CURRENT
5 EXPOSURE CONDITIONS FOR THE SITE VISITOR OR THE ON SITE
6 WORKER. ALL THE UNACCEPTABLE RISK ASSOCIATED IS
7 ASSOCIATED WITH POTENTIAL FUTURE EXPOSURE SCENARIOS. IN
8 OTHER WORDS, PEOPLE LIVING ON THE SITE, AND EVEN THOSE
9 RISKS ARE ASSOCIATED ALMOST EXCLUSIVELY WITH EXPOSURE TO
10 CONTAMINATED DRINKING WATER, CONTAMINATED GROUNDWATER.
11 AND THE RISK LEVELS ARE PRIMARILY ASSOCIATED WITH
12 EXPOSURE TO MANGANESE, TRICHLOROETHENE, VINYL CHLORIDE,
13 AND 1,2 DICHLOROETHENE. SO I'LL LET SANDY GO BACK OVER
14 OUR PROPOSED PLAN FOR THE SITE', AND I'LL BE AROUND FOR
15 QUESTIONS REGARDING THE RISK ASSESSMENT LATER ON. THANK
16 . YOU.
17 SANDY MYERS: THANK YOU, BERNIE. AT THIS POINT,
18 I'D LIKE TO BRIEFLY DISCUSS WHAT WE DID AT THE REMEDIAL
19 INVESTIGATION. HOW DID WE GO OUT AND STUDY THE SITE,
20 HOW DID WE COME UP WITH WHICH PATHWAYS WE THINK CREATE
21 THE MOST RISK. ESSENTIALLY, WE TOOK SEVEN SURFACE WATER
22 SAMPLES, SEVEN SEDIMENT SAMPLES, A TOTAL OF SIXTY-FIVE
23 SOIL SAMPLES, AND FORTY-ONE GROUNDWATER SAMPLES. I'M
24 GOING TO THROW UP A FEW CHARTS HERE TO SHOW YOU WHERE
25 THESE SAMPLES WERE TAKEN. IT'S A LITTLE DIFFICULT TO
DALLAS REPORTING
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5 9 0057
22
1 SEE; I APOLOGIZE. BUT THIS IS THE SITE MAP, AND -THESE
2 ARE THE LOCATIONS OF THE SURFACE WATER AND SEDIMENT
3 SAMPLES RIGHT HERE, HERE, THERE, THERE, AND HERE. THOSE
4 ARE THE SEVEN SPOTS. FOR THE 65 SOIL SAMPLES I'M NOT
5 GOING TO BE ABLE TO POINT EVERY ONE OUT TO YOU, BUT
6 THESE DOTS INDICATE WHERE WE TOOK SURFACE SOIL SAMPLES.
7 AS YOU CAN SEE, THEY'RE SCATTERED ALL OVER THE SITE.
8 AND THESE ROUND DOTS INDICATE WHERE WE TOOK SUBSURFACE
9 SOIL SAMPLES. THE POINT OF THESE FIGURES IS SIMPLY TO
10 SHOW YOU THAT WE SPREAD THESE SAMPLES OUT ALL OVER THE
11 SITE WHERE WE FEEL THE WASTE DISPOSAL PRACTICES
12 OCCURRED, AND WE FEEL LIKE WE SAMPLED THESE MEDIA PRETTY
13 WELL. FOR THE GROUNDWATER, WE SAMPLED IN THESE
14 LOCATIONS. AND AS YOU CAN SEE, YOU HAVE A SHALLOW WELL
15 AND A DEEP WELL OR A ROCK WELL SO YOU'VE GOT TWO WELLS
16 AT EACH ONE OF THESE LOCATIONS. WHEN WE SAMPLED THE
17 GROUNDWATER, WE CAME UP WITH LIKE BERNIE SAID, A LAUNDRY
18 LIST OF CONTAMINANTS. AND YOU RUN THOSE NUMBERS THROUGH
19 THE RISK ASSESSMENT, AND YOU DISCOVER WHERE THE PROBLEM
20 IS. AND IN DOING SO, ?OU END UP WITH AN AREA OF
21 CONTAMINATED GROUNDWATER CALLED THE PLUME. THIS FIGURE
22 HERE INDICATES THE GROUNDWATER CONTAMINANT PLUME IN
23 RELATION TO THE SITE BOUNDARY. AS YOU CAN SEE, THE
24 CONTAMINATED GROUNDWATER PLUME IS BASICALLY WITHIN THE
25 SITE BOUNDARY. THIS PLUME IS A COMBINATION OF ALL FOUR
DALLAS REPORTING
Certified Court Reporters
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23
1 CONTAMINANTS THAT WE'RE LOOKING AT: THE
2 TRICHLOROETHENE, THE 1,2 DICHLOROETHENE, MANGANESE, AND
3 VINYL CHLORIDE. ALL THOSE CONTAMINANTS ADDED TOGETHER
4 GIVE US THIS ONE PLUME. SO THIS TELLS US WHERE WE THINK
5 THE PLUME IS. WE FEEL VERY CONFIDENT THAT WE'VE DEFINED
6 THE PLUME IN THIS AREA. AND FROM THIS POINT, WE HAVE AN
7 IDEA OF WHAT WE'RE DEALING WITH. WE THEN EXAMINED THE
8 CONTAMINANTS THAT WE'RE TALKING ABOUT IN PARTICULAR.
9 THIS CHART HERE SHOWS 1'HE THREE VOLATILE ORGANICS AND
10 THE ONE INORGANIC, MANGANESE. IT ALSO SHOWS THE HIGHEST
11 LEVEL THAT WAS DETECTED ON SITE, AND IT SHOWS THE
12 REMEDIATION LEVELS THAI1 WE'RE GOING TO CLEAN THIS UP TO.
13 NOW, THESE THREE VOLATILE ORGANICS, THE CLEANUP LEVEL IS
14 SIMPLE. IT'S WHAT'S CALLED THE M.C.L. OR THE MAXIMUM
15 CONTAMINANT LEVEL. AiND FOR THOSE OF YOU THAT RECEIVED A
16 PROPOSED PLAN, IN THE BACK IT GIVES A DEFINITION OF
17 MAXIMUM CONTAMINANT LEVEL. BUT SIMPLY, IT'S A
18 PERMISSIBLE LEVEL THAT THE AGENCY ACCEPTS. THAT'S
19 ESSENTIALLY THE BOTTOM LINE. THESE LEVELS ARE WHAT
20 WE'RE GOING TO CLEAN UP TO FOR THESE THREE VOLATILIZE.
21 NOW FOR MANGANESE, WE'RE GOING TO CLEAN UP ABOUT 200.
22 THE UNITS ON THIS ARE MICROGRAMS PER LITER. THERE IS NO
23 M.C.L. FOR MANGANESE. HOW WE'VE COME UP WITH THIS
24 NUMBER IS IT'S APPROXIMATELY THE BACKGROUND
25 CONCENTRATION OF MANGANESE. YOU TAKE A SAMPLE FROM OFF
DALLAS REPORTING
Certified Court Reporters
Rock Hill, South Carolina
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-------
5 9 0058
••^M
24
1 SITE AND YOU COMPARE THAT TO WHAT YOU'VE GOT ON SITE.
2 WE HAD HIGH LEVELS OF MANGANESE ON SITE AT ABOUT 3,600.
3 WE NEED TO CLEAN UP TO BACKGROUND, WHICH IS ESSENTIALLY
4 200 MICROGRAMS PER LITER. SO THESE - - -
5 TONY JANNETTA: CAN WE ASK QUESTIONS AS YOU GO
6 ALONG OR DO YOU WANT TO WAIT UNTIL A CERTAIN TIME.
7 SANDY MYERS: NO, ABSOLUTELY. YOU CAN ASK
8 QUESTIONS NOW.
9 TONY JANNETTA: FROM THE BEGINNING THAT AUGHT TO BE
10 MADE KNOWN BECAUSE WE BAD QUESTIONS FROM THE PREVIOUS
11 SPEAKER. AT THE END, HALF OF US WILL FORGET HALF OF THE
12 PROGRAM. I DO HAVE SOME QUESTIONS ON THE AREA OF THE
13 CONTAMINATED SOURCE THAT WAS TESTED. MY NAME IS TONY
14 JANNETTA, AND THE QUESTIONS I HAVE WITH RESPECT TO THE
15 AREA THAT WAS TESTED AwD THE THREE, FOUR, OR FIVE
16 COMPOUNDS THAT WERE DETECTED TO HAVE CARCINOGENS IN THE
1.7 WATER, YOU'RE SAYING THE SOIL DOES NOT WE'RE NOT
18 WORRIED ABOUT THE SOIL AS OF NOW. WE'RE WORRIED ABOUT
19 THE WATER, UNDERGROUND WATER STREAMS. WAS THE
20 NEIGHBORHOOD ADEQUATELY TESTED IN ADDITION TO THE SITE
21 AREA AS TO HOW FAR THE PLUME WAS ON THE STRATOSPHERE OF
22 THE WATER?
23 SANDY MYERS: WE FEEL LIKE I WANT TO SHOW YOU
24 A MAP THAT HAS THE WELLS. WHAT WE'VE DONE AS YOU CAN
25 SEE UP HERE IN THE CORNER, THIS PRIVATE WELL WHICH IS
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25
1 APPROXIMATELY 500 FEET IN THAT DIRECTION, WE SAMPLED
2 THAT WELL. WE SAMPLED THIS PRIVATE WELL HERE. WE
3 SAMPLED A PRIVATE WELL THAT'S ON SITE; IT'S KIND OF HARD
4 TO SEE. AND WE SAMPLED THIS OTHER PRIVATE WELL HERE.
5 JERRY COLLINS: ARE THERE ANY OTHER PROPERTIES IN
6 THAT VICINITY IN THE PERIMETER WHERE THE PLUME IS THAT
7 ARE ON WELL WATER OR CITY WATER? MY NAME IS JERRY
8 COLLINS. MY QUESTION IS YOU'VE CHECKED THE WELLS AND
9 THE OUTER LOCATIONS MORE OR LESS IT SEEMS LIKE. THE
10 BIGGEST QUESTION, ARE THERE WELLS IN THE VICINITY JUST
11 OUTSIDE THAT PLUME OR IS EVERYONE THERE IN THAT AREA,
12 ARE THEY ON CITY WATER AND SEWAGE?
13 SANDY MYERS: THESE FOLKS RIGHT HERE ARE ON CITY
14 WATER. WE'VE BEEN INDICATED THEY'RE ON CITY WATER.
15 THIS ARROW HERE, BY THE WAY, INDICATES THE DIRECTION OF
16 GROUNDWATER FLOW. WHAT THAT'S TELLING YOU IS THAT'S
17 THIS IS THE DIRECTION THAT THE CONTAMINANTS ARE
18 MOVING ESSENTIALLY. WE SAMPLED THESE WELLS OUT HERE,
19 AND WE CAME UP WITH VERY LOW HITS OR VERY LOW
20 CONCENTRATIONS AT THIS ONE WELL. THE LEVELS OF THE
21 CONTAMINANT THAT WE FOUND HERE ARE ALREADY BELOW THE
22 FEDERAL M.C.L. OF FIVE MlCROGRAMS PER LITER. SO THERE
23 WAS A TRACE HIT THERE, YES, BUT THE LEVEL THAT WE FOUND
24 THERE IS SO LOW THAT TO THIS POINT IT'S NOT FIGURED IN
25 INTO THE SCOPE OF THIS GROUNDWATER PLUME.
DALLAS REPORTING
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Rock Sill, South Carolina
(803) 328-9640
-------
5 9 0059
26
1 TONY JANNETTA: THAT'S MOSTLY CONTAINED TO THE
2 SITE? MOSTLY THE PROBLEM IS CONTAINED TO THE SITE?
3 SANDY MYERS: YES, SIR. AT THIS POINT WE FEEL THAT
4 THE PLUME IS ESSENTIALLY THE SHADED AREA HERE. NOW, THE
5 VERY FIRST SLIDE THAT I SHOWED YOU ALL TONIGHT, THIS WAS
6 THE FIRST SLIDE, THIS SHOWS OTHER WELLS IN THE AREA.
7 NOW, WE WENT IN AND ASKED THESE RESIDENTS IF THEY WERE
8 USING THESE WELLS, AND WE TOOK WHAT'S CALLED A WELL
9 SURVEY. WE DID NOT SAMPLE THESE WELLS BECAUSE WE FELT
10 THAT THEY'RE APPROXIMATELY, IF YOU CAN SEE THE SCALE,
11 THEY'RE ANYWHERE FROM A QUARTER TO A HALF A MILE AWAY.
12 SO GIVEN A FEW CONSIDERATIONS LIKE THE GROUNDWATER
13 HYDROLOGY AND HOW THE SITE THE SITE CONCEPTUAL
14 MODEL, WHAT WE DID WAS SAMPLE THESE WELLS INSTEAD. THIS
15 WELL HERE IS SLIGHTLY DOWNGRADE FROM THE SITS, AND IT'S
16 ROUGHLY 500 FEET FROM THE SITE SO WE CHOSE TO SAMPLE
1.7 THAT WELL.
18 TONY JANNETTA: THE DEPTH WHEN YOU FIRST TRACED
19 CONTAMINANTS IN THE WELL WOULD BE WHAT FROM THE MINIMUM
20 TO THE DEEPEST POINT?
21 SANDY MYERS: THAT'S A GOOD QUESTION. THE DEPTH OF
22 THESE WELLS, OBVIOUSLY WE'VE GOT SHALLOW AND ROCK WELLS
23 AND ACROSS THE SITE THOSE DEPTHS ARE GOING TO VARY. I
24 BELIEVE OUR DEEPEST WELL IS ABOUT 58 FEET OR 56 FEET,
25 SOMEWHERE IN THAT NEIGHBORHOOD. AND OUR SHALLOW WELL
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27
1 MIGHT BE 25 FEET. BUT AGAIN, THE DEPTH OF THESE WELLS
2 VARY, BUT THAT GIVES YOU A BROAD RANGE.
3 TONY JANNETTA: DOES THAT CORRELATE WITH THE
4 HOMEOWNERS' WELLS AND HOW DEEP THEY WERE?
5 SANDY MYERS: THAT'S AN EXCELLENT QUESTION AND THAT
6 IS SOMETHING THAT WRITTEN IN THIS PROPOSED PLAN WE ARE
7 GOING TO INVESTIGATE THAT AT THE REMEDIAL DESIGN PHASE.
8 WHAT WE'RE GOING TO DO IS GO BACK IN PARTICULAR AND LOOK
9 AT THESE PRIVATE WELLS. IN PARTICULAR PRIVATE WELL 4,
10 WE'RE GOING TO GO BACK AND CHECK THE DEPTH OF THAT WELL.
11 AND IF THAT WELL IS SCREENED OR IF 'IT'S MUCH DEEPER THAN
12 THE WELLS THAT WE HAVE ON SITE, LET'S SAY IT'S AT 150
13 FEET OR 100 FEET, THEN WE'RE GOING TO HAVE TO GO BACK
14 AND PUT A DEEPER WELL TO MAKE SURE THAT THE CONTAMINANTS
15 AREN'T GOING UNDERNEATH THIS.
16 TONY JANNETTA: WHY HASN'T THIS BEEN DONE TO BEGIN
17 WITH? SEEMS LIKE IT'S ASS-BACKWARDS. I MEAN WE'RE
18 SPENDING EPA MONEY; WE'RE SPENDING TAXPAYERS' MONEY.
19 LOOKS LIKE TO ME TO GET AN ANALYSIS AND YOU'RE DIGGING
20 WELLS, YOU WOULD SURVEY THE WHOLE SITE AND IF THERE ARE
21 DEEPER WELLS, YOU WOULD GO DEEPER IF YOU FOUND TRACES AT
22 ALL IN THE RESIDENTIAL WELLS. SO YOU'RE REALLY
23 REDUPLICATING WHAT YOU'RE GOING TO HAVE TO DO IF THAT
24 HAPPENS. AND YOU'RE SAYING GROUNDWATER IS THE ONLY
25 CONTAMINATED SOURCE. HOW ABOUT THE CITY'S
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R 9 QQ60
28
1 INFRASTRUCTURE ON CHERRY ROAD, WATER AND SEWER. HAS
2 ANYTHING BEEN TESTED ACROSS THE ROAD TO SEE IF THERE'S
3 ANY CONTAMINANTS ON THE CITY SIDE PERTAINING TO THE
4 - CITY'S INFRASTRUCTURE, PERTAINING TO WATER AND SEWER?
5 THERE'S BEEN SITUATIONS WHERE YOU COULD HAVE
6 CONTAMINANTS INFILTRATING CITY SYSTEMS IN THE GROUND.
7 SO IF YOU'VE GOT A LOW WATER TABLE, WHICH IT VARIES FROM
8 TIME TO TIME, YOU MAY HAVE A BREAK IN THE CITY SYSTEM
9 WHERE YOU'VE GOT CONTAMINANTS FROM THE SITE GOING BACK
10 IN THE CITY SYSTEM. SO HAS THAT BEEN LOOKED AT?
11 SANDY MYERS: I'D LIKE TO ADDRESS YOUR FIRST
12 QUESTION FIRST. YOU SAID THAT IT SOUNDS LIKE WE'RE
13 GOING BACKWARDS HERE. WE'RE SAYING THAT WE'RE GOING TO
14 COME BACK AND LOOK AT THIS WELL, WE MIGHT HAVE TO END UP
15 PUTTING ANOTHER DEEP WELL. THAT IS TRUE, BUT TO THIS
16 POINT IF WE DO GO BACK AND DO THAT, IT'S NOT GOING TO
17 CHANGE OUR REMEDIAL ALTERNATIVE WHICH IS ESSENTIALLY
18 GOING TO BE GROUNDWATER TREATMENT.
19 TONY JANNETTA: OKAY, QUESTION. GROUNDWATER-
20 TREATMENT. YOU'VE ALREADY I WOULD ASSUME THAT
21 YOU'VE ALREADY DONE A BASIC TREATMENT OF THE GROUNDWATER
22 THAT EXISTS FROM SITE.
23 SANDY MYERS: NO, SIR. WE HAVE NOT.
24 TONY JANNETTA: YOU HAVE NOT DONE THAT YET?
25 SANDY MYERS: NO, SIR.
DALLAS REPORTING
Certified court Reporters
Rock Hill, south Carolina
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-------
29
1 TONY JANNETTA: YOU DON'T KNOW WHAT CHEMICALS OR
2 ANYTHING WILL NEUTRALIZE OR BRING INTO COMPATIBILITY
3 BEFORE YOU EVEN START DUMPING IT IN THE CITY SYSTEM OR
4 WHATEVER SYSTEM, METHOD YOU PLAN TO USE. NO METHOD HAS
5 BEEN USED WHEN YOU EXTRACTED THIS WATER OUT TO BRING IT
6 DOWN TO AN ACCEPTABLE LEVEL FOR AN ACCEPTABLE DUMPING,
7 WHEREVER THAT SITE MA* BE. HAS ANYTHING BEEN TRIED TO
8 NEUTRALIZE WHAT'S IN THE WATER SYSTEM NOW?
9 SANDY MYERS: NO, SIR. WE'RE SIMPLY IN THE
10 INVESTIGATION PHASE OF THE SUPERFUND PROCESS RIGHT NOW.
11 WE'RE LOOKING AT DIFFERENT ALTERNATIVES THAT WE CAN USE
12 TO REMEDIATE THE SITE. WE HAVE NOT EXTRACTED THE
13 GROUNDWATER FROM THE SITE.
14 TONY JANNETTA: IS THERE TECHNOLOGY ON THOSE
15 COMPOUNDS THAT YOU RELATED TO THAT WILL BRING IT TO AN
16 ACCEPTABLE LEVEL BEFORE YOU EVEN CONSIDER DUMPING IT
17 INTO THE CITY SYSTEM?
18 BERNIE HAYES: AS SANDY WAS SAYING, WE ARE RIGHT
19 NOW JUST TRYING TO DEFINE THE EXTENT OF THE
20 CONTAMINATION AND TO TRY AND TALK ABOUT TREATMENT
21 ALTERNATIVES OR TECHNOLOGIES THAT MIGHT ADDRESS IT. WE
22 HAVE A GOOD IDEA OF WHAT'S IN THE GROUNDWATER. WE
23 TESTED THE GROUNDWATER FOR HUNDREDS OF CONTAMINANTS AND
24 FOUND THE ONES THAT WE SAVE DESCRIBED ALREADY. WE KNOW
25 THAT THERE ARE TECHNOLOGIES THAT CAN DEAL WITH TAKING
DALLAS REPORTING
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THOSE CONTAMINANTS OUT OF THAT GROUNDWATER SO TEAT THE
WATER IS REMEDIATED TO A POINT WHERE IT'S NOT A PROBLEM
NO MATTER HOW YOU GET RID OF IT. BUT WE'RE SKIPPING WAY
AHEAD HERE AS FAR AS THE PROPOSED PLAN GOES. OBVIOUSLY
A LOT OF YOU HAVE ALREADY READ IT, BUT THE IDEA OF
PUTTING AN END TO THE TREATMENT SYSTEM THAT ALREADY
EXISTS AND THAT WILL £>E EFFECTIVE FOR REMOVING THOSE
CONTAMINANTS IS A VERY COST EFFECTIVE WAY OF DOING IT
RATHER THAN BUILDING A WHOLE OTHER TREATMENT SYSTEM TO
DEAL WITH IT SPECIFICALLY.
TONY JANNETTA: THE POINT ON THAT WOULD BE IF
YOU'RE GOING TO TAKE RAW UNDERGROUND WATER, WE DON'T
KNOW HOW LONG, HOW BIG THIS PLUME IS. DO WE KNOW THAT?
SANDY MYERS: IT'S AN ESTIMATION, LIKE I SAID
BEFORE. YES.
TONY JANNETTA: YOU WOULD KNOW WHERE THE BEGINNING
AND ENDING POINT WOULD BE ONCE YOU START PUMPING?
BERNIE HAYES: THAT'S REALLY A VERY DIFFICULT THING
TO DO. I MEAN THERE'S NOT IT'S VERY DIFFICULT TO
ESTIMATE HOW LONG IT WILL TAKE TO PUMP A GIVEN VOLUME OF
CONTAMINATION OUT OF THE GROUND.
TONY JANNETTA: YOu'RE ASKING THE CITY OF ROCK HILL
TO COME IN AND PUT ADDITIONAL CHEMICALS IN THEIR WATER
TO TREAT THIS UNDERGROUND WATER WITH THE BULK OF THE
CITY'S WATER, WITH THE CITY'S WATER ADDITIONAL
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31
1 CHEMICALS. I'M SAYING TEAT THIS IS A CONSIDERATION ARE
2 WE - - - WHERE WE MAY BE GOING ON CONSIDERING THIS
3 OPTION, I'M SAYING IT. WOULD BE BETTER TO TREAT IT BEFORE
4 YOU DUMP IT INTO THE CITY MAIN, CITY SEWER ON SITE TO
5 GET SOME OUT OF THE WAY. THEN THE CITY CAN TAKE IT FROM
6 THAT POINT IF THAT WAS AN OPTION.
7 BERNIE HAYES: THAT'S EXACTLY THE KIND 0? COMMENT
8 WE LIKE TO HEAR.
9 TONY JANNETTA: YOU'RE PUTTING THE CITY AT RISK BY
10 JUST RUNNING IT THROUGH THE CITY SYSTEM BECAUSE IT'S
11 PUTTING ADDITIONAL CHEMICALS IN THE CITY'S WATER
12 TREATMENT FILTER PLANT.
13 BERNIE HAYES: THAT'S A GOOD POINT, AND THOSE ARE
14 EXACTLY THE KIND OF COMMENTS THAT WE ARE HAVING THE
15 MEETING TO HEAR BECAUSE JUST AS THE DOCUMENT SAYS, THIS
16 IS A PROPOSED PLAN. WE HAVE NOT MADE FINAL DECISION
17 ABOUT WHAT WE'RE GOING TO DO WITH THIS GROUNDWATER OR
18 HOW WE'RE GOING TO REMEDIATE THE SITE. SO THESE ARE
19 EXACTLY THE KIND OF THINGS THAT WE NEED TO HEAR IS THE
20 PUBLIC'S REACTION OR THE PEOPLE'S REACTION TO THESE
21 VARIOUS TREATMENT OPTIONS AND THE PROBLEMS THAT THEY MAY
22 FORESEE WITH IT. I THINK WE NEED TO COME BACK TO THE
23 QUESTION OF TALKING ABOUT THE TREATMENT OPTIONS. AND
24 SANDY I'M SURE WILL COVER THAT AS PART OF THE
25 PRESENTATION. AND I KNOW IT'S DIFFICULT TO REMEMBER
DALLAS REPORTING
Certified Court Reporters
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-------
5 9 0062 32
1 YOUR QUESTIONS AS THINGS GO ALONG AND IF THERE'S ONE
2 THAT YOU DON'T THINK YOU CAN HOLD ON TO UNTIL THE END,
3 THEN CERTAINLY WE'LL TAKE IT. BUT LET'S GO AHEAD AND
4 GET THROUGH THE PRESENTATION AND MAYBE SOME OF THOSE
5 QUESTIONS WILL BE ANSWERED BY THE PRESENTATION ITSELF
6 AND THAT WAY WE WON'T HAVE TO BE HERE SO LONG. SO LET'S
7 GET THIS ONE THEN
8 JERRY COLLINS: MAY I ASK ONE QUESTION BEFORE WE GO
9 INTO TALKING ABOUT TREATMENT? YOU HAD MENTIONED THAT
10 THE PROPERTY THAT WAS A QUARTER MILE OR HALF MILE AWAY
11 FROM THE SITE THAT YOU HAD ASKED WHETHER THEY WERE USING
12 THE WELLS OR NOT. YOU DID NOT STATE WHETHER OR NOT THEY
13 WERE USING THE WELLS.
14 SANDY MYERS: THOSE PROPERTIES, THEY DID HAVE
15 DRINKING WELLS.
16 JERRY COLLINS: WERE THEY USING THEM?
17 SANDY MYERS: THE MAJORITY OF THEM, YES. I'M NOT
18 POSITIVE IF ALL OF THEM WERE, BUT I KNOW
19 JERRY COLLINS: BUT YOU DID NOT TEST ANY OF THOSE
20 WELLS?
21 SANDY MYERS: NO. WE DID NOT TEST THESE WELLS.
22 JERRY COLLINS: IT SOUNDS TO ME LIKE YOU'RE
23 INCONCLUSIVE ON YOUR COLLECTION.
24 SANDY MYERS: WHAT WE DID INSTEAD WAS WE PLACED
25 WELLS IN BETWEEN THE SITE SOURCE AREA WHICH WE BELIEVE
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IS RIGHT IN HERE IN THAT LOCATION. FOR INSTANCE, WE i
HAVE A MONITORING WELL 6 WHICH IS A SHALLOW AND A DEEP
WELL WHICH IS DIRECTLY BETWEEN THAT AREA, THE SOURCE
AREA, AND THE RESIDENTIAL WELLS. THAT WELL IS CLEAN.
JERRY COLLINS: THERE IS NO CONTAMINATION AT THAT
LEVEL?
SANDY MYERS: THERE IS NOT. SO THAT IS SORT OF AN
INDICATION THAT THE CONTAMINANT PLUME HAS NOT EXCEEDED
THE SITE BOUNDARY ON THIS SIDE OF THE PROPERTY.
JERRY COLLINS: ALSO, FROM WHAT I'VE READ IN THE
NEWSPAPER THAT THE FIRST UNION BANK PROPERTY WHEN IT WAS
CONSTRUCTED, THEY HAD EXTRACTED I THINK THREE FEET DEEP
OF SOIL BEFORE THEY BUILT THE FOUNDATION. THE PROPERTY,
THAT FIRST UNION BANK, IS NOT INCLUDED IN THAT PERIMETER
THAT USED TO BE PART OF THE ACTUAL PROPERTY OF THE
CHEMICAL COMPANY. IS THAT CORRECT? YOU HAVE A BOUNDARY
GOING AROUND THE BANK. IT'S NOT INCLUDED IN THAT
PERIMETER, IS IT?
SANDY MYERS: THAT'S CORRECT.
JERRY COLLINS: WHY IS THAT NOT IN THERE, BUT THAT
WAS PART OF THE ORIGINAL?
SANDY MYERS: I THINK THAT MARK MIGHT COULD HELP US
MORE WITH THIS QUESTION. BUT I THINK IT'S SIMPLY THE
FACT THAT THE BANK OWNS THIS PROPERTY. AND JUST FOR A
SITE BOUNDARY MAP, WE DID NOT INCLUDE THAT PART OF THE
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PROPERTY IN THIS BOUNDARY. HOWEVER, THE PLUME, AS YOU
CAN SEE, DOES GO OVER THAT PART OF THE SITE AND IT WILL
BE REMEDIATED.
JERRY COLLINS: BUT AS FAR AS THE CONTAMINATED SOIL
THAT WAS OWNED THE PROPERTY THAT WAS ORIGINALLY
OWNED BY THE COMPANY, THE CHEMICAL COMPANY, WAS THAT
AREA WHERE THE BANK SITS WAS INCLUDED IN THAT BUT THAT'S
NOT SHOWN?
SANDY MYERS: THAT'S CORRECT.
JERRY COLLINS: ACTUALLY THE ENTIRE AREA THAT WAS
PART OF THE CHEMICAL COMPANY?
SANDY MYERS: YOU'RE CORRECT.
JERRY COLLINS: AND YOU ALSO HAVE NOT STATED ABOUT
THAT FROM WHAT I READ IN THE PAPER THAT I BELIEVE IT WAS
THREE FEET OF SOIL WAS EXTRACTED IN '84 OR '86,
SOMETHING LIKE THAT, WAS BEFORE THEY BUILT THE
FOUNDATION TO THE BANK, AND THAT'S WHEN THEY FOUND THAT
THERE WAS CONTAMINATION LEVELS.
SANDY MYERS: RIGHT. EARLY ON IN THE TALK I 'HAD
MENTIONED THAT THERE WERE TWO REMOVALS THAT TOOK PLACE.
JERRY COLLINS: YOU STATED BEHIND THE BANK. YOU
DIDN'T SAY ABOUT THE PROPERTY WHERE THE BANK IS LOCATED.
THEY SAY IN THE PAPERS FROM WHAT I'VE READ THAT ACTUALLY
THEY HAD REMOVED SOIL FROM THE PROPERTY WHERE THE BANK
WAS BUILT ON THAT FOUNDATION AREA. AND YOU ALSO HAVEN'T
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DONE ANY SOIL TESTS IN TflE AREA PROBABLY BECAUSE IT'S
PAVED, I GUESS. ALL THAT AREA IS PROBABLY PAVED MORE
THAN LIKELY.
BERNIE HAYES: AGAIN, THAT'S SOMETHING, THAT'S
EXACTLY THE KIND OF THING THAT WE NEED TO HEAR IS
INFORMATION THAT WE MAY NOT HAVE BEEN FULLY AWARE OF OR
THINGS THAT WE NEED TO CHECK UP ON TO SEE IF THERE IS A
NEED TO SAMPLE UNDER THE FILL THAT THE BANK WAS PLACED
ON TO THE EXTENT THAT SOIL WAS REMOVED FROM UNDER THERE
SO THAT'S SOMETHING WE WILL
JERRY COLLINS; ALSO, WHY HASN'T IT BEEN BROUGHT UP
AS AN OPTION TO REMOVE THE SOIL IN THIS AREA BECAUSE
WHEN YOU REMOVE THE WATER FROM THIS PLUME, YOU'RE GOING
TO EVENTUALLY GET THE SAME BUILD UP IN WATER IS
JUST GOING TO BE A CONSTANT FILTRATION PROCESS. WHY NOT
REMOVE THE SOIL? THAT'S WHERE THE PROBLEM IS. THE
WATER IS THE RESULT OF IT. THE PROBLEM IS THE SOIL
WHERE THE CHEMICALS AREA. WHY NOT REMOVE THAT?
BERNIE HAYES: A GOOD POINT. AND AGAIN, IT'S
SOMETHING THAT I THINK HAY BE COVERED AS PART OF THE
FURTHER PRESENTATION SO LET'S GO AHEAD AND GET THAT OVER
WITH, AND THEN WE'LL COME BACK AND TALK ABOUT SOME OF
THESE THINGS BECAUSE THOSE ARE VERY GOOD POINTS. I MEAN
THOSE ARE EXACTLY THE KIND OF THINGS WE'RE HERE TO TALK
ABOUT AND WE WANT TO GET INPUT IN AS TO WHAT FOLKS THINK
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1 ABOUT THE REMEDY OF THE PROPOSAL.
2 SANDY MYERS: VERY QUICKLY, THESE ARE THE VARIOUS
3 ALTERNATIVES THAT WE LOOKED AT. ESSENTIALLY, WE HAVE
4 TWO TYPES OF ALTERNATIVES. WE'VE GOT ALTERNATIVE 3A AND
5 3B WHICH ARE GROUNDWATER EXTRACTION AND TREATMENT ON
6 SITE, AND 4A AND 4B WHICH ARE EXTRACTION WITH TREATMENT
7 AT THE P.O.T.W., SENDING THE CONTAMINATED WATER TO THE
8 P.O.T.W., THE DIFFERENCE BETWEEN EACH JUST BEING THE
9 NUMBER OF EXTRACTION LEVELS. THESE ARE THE ALTERNATIVES
10 THAT WE LOOKED AT AND EPA PROPOSED ALTERNATIVE 4B, WHICH
11 IS GROUNDWATER EXTRACTION USING APPROXIMATELY TWO WELLS
12 IN DIRECT DISCHARGE TO THE P.O.T.W. THE REASON THAT WE
13 CHOSE THIS ALTERNATIVE IS WE'VE GOT SIX REASONS: NUMBER
14 1, IT PROTECTS HUMAN HEALTH ANDVTHE ENVIRONMENT; NUMBER
15 2, IT MEETS APPLICABLE OR RELEVANT AND APPROPRIATE
16 REQUIREMENTS WHICH ARE SIMPLY TYPES OF RULES AND
1.7 REGULATIONS. THEY MEET THOSE REGULATIONS. THIS
18 ALTERNATIVE IS EFFECTIVE BOTH IN THE SHORT AND THE LONG
19 TERM. IT REDUCES CONTAMINANT TOXICITY, MOBILITY, AND
20 VOLUME. IT'S EASY TO IMPLEMENT, AND IT'S COST
21 EFFECTIVE. NOW COMING BACK TO THIS CHART HERE, YOU SEE
22 THE DIFFERENCE FROM TREATING IT ON SITE AND SENDING IT
23 DOWN THE P.O.T.W. AS FAR AS THE COST GOES. IN CHOOSING
24 THESE ALTERNATIVES, I FELT PERSONALLY THAT IF THE
25 P.O.T.W. CAN ACCEPT THIS GROUNDWATER, THEN THERE WAS NO
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1 NEED TO BUILD A TREATMENT PLANT ON SITE TO TREAT THE
2 WATER IF THEY WILL TREAT IT FOR US DOWN THE ROAD.
3 JERRY COLLINS: MAY I ASK A QUESTION WHILE WE'RE ON
4 THAT POINT RIGHT THERE? FIRST OFF, I'M PRETTY SURE
5 EVERYBODY IS AWARE OF THE FACT THAT THE WASTE TREATMENT
6 FACILITY ON DAVE LYLE GOT TO A POINT WHERE THEY COULD
7 NOT HANDLE THE CAPACITY OF THE WASTE. THEY HAD BEEN
8 SHIPPING IT TO, I BELIEVE, I MAY NOT HAVE MY FACTS
9 STRAIGHT, MAYBE LANCASTER OR CHESTER; AND THAT FACILITY
10 CLOSED DOWN. AND THIS IS ALSO THE SAME PROBLEM WHERE,
11 IT WAS NATIONAL NEWS, WHERE THEY WERE USING FECAL MATTER
12 THAT CAME OUT OF THE DAVE LYLE TREATMENT FACILITY AND
13 PUTTING IT ON SPREADING IT ON PASTURES AND LETTING
14 IT SIT STAGNANT FOR SO MANY YEARS BEFORE IT'S USABLE.
15 WELL NOW, YOU/RE GOING TO DUMP ALL THIS CHEMICAL IN THE
16 D.O.T. FACILITIES AND WHO'S TO SAY THAT MATTER IS NOT
L7 GOING TO BE SCOOPED UP AND THEN SPREAD ON PASTURES
18 AGAIN, FIELDS AGAIN. AND THE WORSE PART ABOUT IT IS
19 WHEN THEY EXTRACTED THIS WASTE AND SPREAD IT ON THE
20 FIELDS, THEY DIDN'T FIND OUT UNTIL LATER ON THAT THERE
21 WERE AIR POCKETS IN THE WASTE TREATMENT FACILITY AND THE
22 ACTUAL WASTE, THE FECAL HAD NOT DECOMPOSED THOROUGHLY
23 AND THERE WERE HUMAN SANITARY THINGS FOUND, BUT THEY
24 ALSO FOUND RAW FECAL MATTER ON THE FIELDS.
25 SANDY MYERS: RIGHT. I AM NOT FAMILIAR WITH THAT
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1 SITE AND THAT PROJECT.
2 JERRY COLLINS: ARE YOU NOT FAMILIAR WITH THAT
3 HEADLINE NEWS STORY THAT WAS NATIONAL? ROCK HILL HIT
4 NATIONAL NEWS FOR THAT.
5 SANDY MYERS: OFF THE TOP OF MY HEAD, NO; I'M SORRY
6 I'M NOT.
7 JERRY COLLINS: NOBODY SAW THAT STORY?
8 SANDY MYERS: NO. I'M NOT SAYING NO ONE SAW THE
9 STORY. I'M JUST SAYING I'M NOT FAMILIAR WITH THAT
10 STORY.
11 JERRY COLLINS: RIGHT, BUT THIS WAS NOT STUDIED
12 THAT MAYBE THE FACT THAT IF THEY'RE GOING TO PUMP THIS
13 TO THE D.O.T. CENTER THAT
14 SANDY MYERS: WE'RE TALKING ABOUT EXTRACTING THIS
15 GROUNDWATER AND SENDING IT VIA THE SEWER LINE TO THE
16 P.O.T.W. WHERE THEY TREAT WATER.
17 JERRY COLLINS: THIS IS AT DAVE LYLE. THIS IS THE
18 FACILITY ON DAVE LYLE IS WHERE IT WOULD GO THOUGH.
19 THAT'S THE SAME FACILITY WHERE THEY SCOOPED THIS WASTE
20 OUT AND IT WAS SPREAD ON PASTURES AS FERTILIZER.
21 BERNIE HAYES: THAT'S A VERY COMMON PRACTICE.
22 GLEN PELLETT: MY NAME IS GLEN PELLETT. TEE
23 MATERIAL THAT WAS REMOVED AND SENT TO SEVERAL FARMS IN
24 CHESTER AND YORK COUNTY WAS ACTUALLY MATERIAL THAT WAS
25 PLACED IN OLD LAGOONS PRE-1984 THAT HAD BASICALLY BEEN
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ABANDONED IN PLACE. THAT'S NOT FROM THE CURRENT
MANCHESTER PLANT. THAT SLUDGE IS TREATED TOTALLY
SEPARATELY. SO WHAT YOU'RE SPEAKING TO IS NOT THE
SLUDGE THAT'S GOING TO BE GENERATED FROM ANY OF THE
WATER THAT WOULD BE DISCHARGED TO THE P.O.T.W. ANOTHER
QUESTION I HAD, WE WERE TALKING ABOUT MAXIMUM
CONCENTRATIONS OF 84,000 MICROGRAMS PER LITER. DO YOU
HAVE A GUESS AS TO WHAT THE AVERAGE CONCENTRATION MIGHT
BE? IT'S GOT TO BE SIGNIFICANTLY LOWER THAN THAT.
BERNIE HAYES: I'M SURE IT WOULD BE. AGAIN, IT'S
DIFFICULT TO DO THAT UNTIL WE DO SOME PUMP TESTS, UNTIL
WE TRY TO DO SOME DETERMINATION OF WHAT THE AVERAGE
INFLUENT MIGHT BE. I THINK JUST TO TRY AND WRAP ALL
THIS UP, NORMAL SEWAGE TxtEATMENT PLANTS, P.O.T.W.'S,
WHATEVER YOU CALL THEM, ARE VERY EFFECTIVE AT REMOVING
CERTAIN TYPES OF CONTAMINANTS, PARTICULARLY VOLATILE
ORGANICS, WHICH THREE OUT OF FOUR CONTAMINANTS WE HAVE
HERE ARE VOLATILE ORGANICS. THEY TEND TO COME OUT IN
WHAT'S CALLED THE ACTIVATED SLUDGE WHERE THEY BUBBLE A
LOT OF OXYGEN AND A LOT OF AIR THROUGH THIS SEWAGE IN
ORDER TO PROVIDE OXYGEN FOR THE BACTERIA THAT LIVE IN
THERE AND THAT BREAK DOWN THE CONTAMINANTS THAT ARE
NORMALLY IN THE SLUDGE. AT THE SAME TIME, THAT BUBBLING
ACTION, ALL THAT AERATION THAT GOES ON IN THE ACTIVATED
SLUDGE HAS THE BENEFICIAL EFFECT OF REMOVING VOLATILE
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1 CONTAMINANTS. SO IT'S UNLIKELY THAT ANY OF THESE
2 VOLATILES IN THEIR CURRENT FORM ARE GOING TO END UP IN
3 THE SLUDGE OR IN THE WATER THAT'S GOING OUT OF THE
4 PLANT. THE SECOND THING TO KEEP IN MIND IS THAT IN
5 ORDER TO CONTROL THE MIGRATION OF THIS PLUME, AGAIN
6 WE'RE GETTING AHEAD OF OURSELVES HERE, WE'RE PROBABLY
7 NOT GOING TO HAVE TO POhP A WHOLE LOT OF WATER. I MEAN
8 THIS IS NOT WHAT YOU'D CALL A VERY PRODUCTIVE AQUIFER.
9 IT'S NOT THE KIND OF THING THAT IN ORDER TO CREATE DRAW-
10 DOWN IN THE EXTRACTION WELLS YOU HAVE TO PUMP THOUSANDS
11 AND THOUSANDS OF GALLONS OF WATER. SO THE AMOUNT OF
12 FLOW THAT WILL BE GENERATED BY CREATING A CONTAINMENT OR
13 REMEDIATION GROUNDWATER EXTRACTION SYSTEM FOR THIS PLUME
14 WILL BE VERY LITTLE IM COMPARISON TO THE OVERALL FLOW
15 THAT'S GOING INTO SUCH TREATMENT PLANT. SO WHETHER OR
16 NOT THIS SYSTEM WHEN IT'S IN PLACE WHETHER IT'S RUNNING
17 OR NOT RUNNING IT WILL BE VERY DIFFICULT FOR THE PLANT
18 EVEN TO KNOW IT IN TERMS OF THE VOLUME THAT THEY'D BE
19 RECEIVING. NOW, IF IN FACT THE PLANT HAS A CAPACITY
20 PROBLEM, THAT'S SOMETHING WE NEED TO CHECK ON. AND I'M
21 GLAD TO HEAR THOSE KINDS OF THINGS BROUGHT OUT SO THAT
22 WE CAN GO BACK AND MAKE SURE THAT WE'RE NOT GETTING
23 OURSELVES INTO SOME KIND OF PROBLEM. SO THESE ARE
24 EXACTLY THE KIND OF THINGS WE WANT TO HEAR. IF THERE IS
25 A COMPLIANCE PROBLEM WITH THIS PLANT WE NEED TO KNOW, WE
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1 NEED TO FIND OUT, ALTHOUGH I THINK THAT WE'VE ALREADY
2 DETERMINED THAT IT'S IN COMPLIANCE. IF THERE WAS A
3 SLUDGE PROBLEM/ A SLUDGE DISPOSAL PROBLEM, TEAT'S
4 ANOTHER THING THAT WE WEED TO FIND OUT ABOUT. SO THESE
5 ARE THE THINGS WE CAN GO BACK AND CHECK ON TO MAKE SURE
6 THAT WE'RE NOT GETTING OURSELVES INTO A BIGGER PROBLEM
7 THEN WE ALREADY HAVE BY IMPLEMENTING THIS PREFERRED
8 DISPOSAL OPTION. DID YOU HAVE ANY MORE?
9 SANDY MYERS: ACTUALLY, THIS WAS OUR PREFERRED
10 ALTERNATIVE. THIS WAS ESSENTIALLY THE END OF MY TALK.
11 BERNIE HAYES: OKAY. WELL, LET'S TAKE QUESTIONS
12 NOW.
13 LARRY CRUMP: IF YOU'RE GOING TO PUMP THE WATER
14 OUT, HOW ARE YOU GOING TO STOP THE WATER IN TE2R2
15 BECOMING CONTAMINATED SINCE THE CONTAMINATION IS IN THE
16 SOIL? BY THE WAY, WOULD YOU TAKE YOUR CHILD AND BRING
17. HIM TO FOOTBALL OR SOFTBALL IN THAT FIELD TODAY? CAN ME
18 AND MY SON GO ACROSS THE STREET AND PASS THE FOOTBALL TO
19 SOME OF MY FAMILY?
20 BERNIE HAYES: TO ANSWER YOUR QUESTION, I WOULD SAY
21 YES. THE SITE VISITOR SCENARIO THAT WE EXAMINED
22 LARRY CRUMP: WE'RE NOT VISITORS. WE'RE THERE
23 EVERY DAY.
24 BERNIE HAYES: WELL, A VERY FREQUENT EXPOSURE
25 IT'S NOT JUST THE TYPE OF EXPOSURE OF SOMEONE WALKING
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ACROSS THE SITE ONCE A YEAR OR SOMETHING LIKE THAT. FOR
FREQUENCY OF EXPOSURE AND THAT SITE VISITOR THING IS
GENERALLY I THINK TWO TIMES A WEEK, SEVEN MONTHS OUT OF
THE YEAR. SO UNLESS YOU'RE OVER THERE PLAYING ON THAT
PROPERTY OR VISITING THAT PROPERTY MORE THAN TWO OR
THREE TIMES A WEEK, THEN THE ANSWER IS YES, THEN THE
RISK ASSOCIATED WITH EXPOSURE TO THE SURFACE SOIL FROM
AN INCIDENTAL BASIS IS VERY LOW.
LARRY CRUMP: P.C.P. IS SOMETHING THAT REALLY
WORRIES ME. I HAVE, A TEN YEAR OLD SON I HAVE A HARD
TIME KEEPING AN EYE ON TWENTY-FOUR HOURS AROUND THE
CLOCK.
BERNIE HAYES: I UNDERSTAND THAT. AND AT A LOT OF
SITES THAT'S A PROBLEM. AND I THINK THE RISK ASSESSMENT
WOULD INDICATE - - - THE RESULTS OF THE RISK ASSESSMENT
TELL US THAT EVEN UNDER VERY FREQUENT EXPOSURE FROM A
SITE VISITOR CHILD PLAYING, SITE TRESPASSER, WHATEVER
YOU WANT TO CALL IT BASIS, THE RISK ASSOCIATED WITH THAT
KIND OF EXPOSURE IS VERY LOW. I'M NOT SAYING I WOULD
LET YOUR SON GO OVER THERE AND PLAY FOOTBALL BECAUSE
IT'S SOMEBODY ELSE'S PROPERTY AND HE COULD GET HURT. I
MEAN THINGS BESIDES ANY CONTAMINATION THAT HE MIGHT
EXPERIENCE OR ANY EXPOSURE HE MIGHT EXPERIENCE. I'M NOT
SAYING YOU SHOULD LET HIM GO OVER THERE AND PLAY
FOOTBALL. I'M SAYING IF HE GOES OVER THERE AND PLAYS ON
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1 THE SITE ONCE IN A WHILE, THE LEVEL OF CONTAMINATION
2 THAT EXISTS OVER THERE IS NOT GOING TO BE A SUBJECT OP
3 RISK TO HIS HEALTH.
4 BILL RUTLEDGE: WE'VE HAD THE PROPERTY POSTED FOR
5 SEVERAL YEARS WITH MANY SIGNS THAT HAVE BEEN TORN DOWN.
6 LARRY CRUMP: A FENCE WOULD BE MORE APPROPRIATE.
7 I'M LARRY CRUMP. AND I'M SURE MR. RUTLEDGE HAS PUT
8 SIGNS UP BEFORE BECAUSE I'VE SEEN THEM .UP BEFORE.
9 SOMETIMES IT'S PEOPLE. THERE ARE STILL PEOPLE THAT'S
10 ILLITERATE. THERE ARE STILL PEOPLE THAT DON'T PAY NO
11 ATTENTION TO THE SIGNS. THEY MAY BE WALKING AROUND
12 LOOKING AT THE GROUND NOT SEEING A SIGN. BUT A FENCE, A
13 FENCE MAY KEEP PEOPLE fROM GOI^IG ACROSS IT. IT MAY KEEP
14 MY SON OUT OF IT TOO.
15 JANE DAVENPORT: HAS THE CITY OF ROCK HILL BEEN
16 ADVISED OF THE PROPOSED PUMPING OF THE CHEMICAL
17 CONTAMINATIONS AND HAVE THEY AGREED TO PARTICIPATE?
18 SANDY MYERS: YES, MA'AM, THEY HAVE.
19 JANE DAVENPORT: HAS THERE BEEN ENGINEERING COST
20 ESTIMATES DONE ON WHAT THE COST WILL BE TO DO THIS?
21 SANDY MYERS: THOSE COST ESTIMATES WERE LISTED HERE
22 ON THIS CHART. WE'RE PROPOSING ALTERNATIVE 43 WHICH IS
23 ROUGHLY TWO MILLION DOLLARS.
24 JANE DAVENPORT: WHO DID THE ESTIMATE?
25 . SANDY MYERS: IT WAS A PRIVATE CONTRACTOR THE EPA
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HIRED, COM, INC., BASED OUT OF ATLANTA.
JANE DAVENPORT: IS THERE A COPY OF THAT REPORT OR
THAT ESTIMATE AVAILABLE?
SANDY MYERS: YES, MA'AM. THAT IS IN WHAT'S CALLED
THE REMEDIAL INVESTIGATION FEASIBILITY STUDY. THAT'S IN
THE FEASIBILITY STUDY PORTION OF THAT DOCUMENT.
TONY JANNETTA: AGAIN, IT SEEMS LIKE THE DIRECTION
OF SOLVING THE PROBLEM, WHICH I AGREE THE PROBLEM NEEDS
TO BE SOLVED AND IT'S NOT GOING TO GO AWAY, SO ONE OF
THE ALTERNATIVES IS GOING TO BE SUGGESTED AND IT SOUNDS
LIKE IT'S GOING TO BE DUMPING IT INTO THE CITY'S SEWAGE
SYSTEM FOR THE CITY TO TREAT IT AT ITS OWN FACILITIES.
MY SUGGESTION WOULD BE EPA AND THE CITY MAKE SURE THAT
THE INFRASTRUCTURE THAT YOU'RE DUMPING THE CONTAMINATED
WATER IN IS PROPERLY SECURED AND TIGHT AND IS NOT ANY
KIND OF INFILTRATION FROM GROUNDWATER INTO THE SYSTEMS
THAT YOU'RE DUMPING THE WATER IN. AND MY QUESTION WOULD
BE WILL THE EPA INVESTIGATE THE CITY'S LATERAL LINES
CONCERNING THE SEWER IF THERE'S GOING TO BE A SEWER DROP
OR WILL THE CITY PROVIDE THE NECESSARY VIDEO INSPECTIONS
OF THE LINE TO MAKE CERTAIN THAT THOSE LINES ARE NOT
LEACHING WATER, WHICH IF YOU DUMP WATER IN IT WOULD
LEACH BACK OUT INTO THE GROUNDWATER GROUND AGAIN AND YOU
HAVE TO REDUPLICATE THE PROCESS SOMEWHERE DOWN THE LINE.
SO YOU'RE GOING TO HAVE TO MAKE CERTAIN IF THE CITY'S
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1 GOING TO USE THEIR SYSTEMS, THEIR LINES ARE PROPERLY
2 INTACT BECAUSE I DON'T KNOW WHAT THE DISTANCE WOULD BE
3 FROM THERE TO THE TREATMENT PLANT. AND RIGHT NOW, WE
4 HAVE A TREATMENT PLANT OUT HERE ON CHERRY ROAD AND DO
5 YOU KNOW THE DEPTH OF THAT? THAT COULD BE A PROBLEM.
6 SANDY MYERS: I HEAR YOUR CONCERN. IT'S ON THE
7 RECORD.
8 TONY JANNETTA: AND ALL THOSE CONCERNS AUGHT TO BE
9 ADDRESSED BY THE EPA AND THE CITY BEFORE THEY ACCEPT
10 THIS MONUMENTAL CONTRACT BECAUSE I STILL SAY ON SITE
11 CLEANING OF THE CONTAMINATION THEN DUMPING IT INTO THE
12 SYSTEM WOULD PROVIDE A SAFER ENVIRONMENTAL SITUATION.
13 MY QUESTION WOULD BE IS THE CITY STILL TREATING THEIR
14 TREATED WATER, ARE THEY TREATING THEIR WATER WITH
15 CHEMICALS THAT YOU HAVE ALLUDED TO THAT ARE IN THE
16 GROUNDWATER NOW? ARE 'i'BEY TREATING THE CITY'S WATER
17 WITH CHEMICALS THE WAY IT WOULD DEVIATE OUR DRINKING
18 WATER? IF THAT WERE THE CASE, THEY WOULD HAVE THE
19 FACILITIES TO DO IT AND THE KNOWLEDGE TO DO IT. "
20 SANDY MYERS: RIGHT. LET ME SAY THIS TREATMENT
21 FACILITY IS VERY WELL AWARE OF WHAT TYPE CONTAMINANTS
22 WE'VE GOT AT THIS SITE, AND THEY'RE ALSO VERY WELL AWARE
23 THAT THEY CAN TREAT THESE CONTAMINANTS. THESE
24 CONTAMINANTS ARE NOT VERY DIFFICULT TO TREAT. AS BERNIE
25 MENTIONED BEFORE, THE TREATMENT SYSTEMS THAT THEY
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1 ALREADY HAVE IN PLACE, SUCH AS ACTIVATED SLUDGE, THAT
2 ALONE CAN TAKE CARE OF THESE CONTAMINANTS.
3 TONY JANNETTA: YOU'RE LOOKING AT SOME OLD LATERAL
4 LINES THAT YOU MAY BE DUMPING INTO THAT MAY HAVE A
5 PROBLEM.
6 SANDY MYERS: RIGHT. THAT'S A DIFFERENT ISSUE THAN
7 WHETHER THE TREATMENT PLANT CAN TREAT THE WATER. AND I
8 AGREE WITH YOU, THAT'S SOMETHING I'LL HAVE TO LOOK INTO.
9 BERNIE HAYES: JUST ONE CLARIFICATION THERE.
10 CERTAINLY SEWER LINES ARE NOT PRESSURE LINES SO YOU CAN
11 HAVE WATER LEAK INTO THEM OR WATER LEAK OUT OF THEM. IN
12 THIS PART OF THE COUNTRY, WATER LEAKING OUT OF SEWER
13 LINES IS USUALLY NOT THE PROBLEM; USUALLY IT'S WATER
14 LEAKING INTO THE SEWER LINES. SO IT'S SOMETHING WE
15 PROBABLY COULD TAKE A LOOK AT DURING THE DESIGN PHASE TO
16 MAKE SURE THAT WE'RE NOT GOING TO CREATE ANY WHAT YOU
L7 CALL EX-FILTRATION PROBLEMS FROM SEWER LINES. BUT IN
18 THIS PART OF THE COUNTRY, YOU USUALLY HAVE MUCH MORE OF
19 A PROBLEM WITH LEAKING INTO THE SEWER LINES. SO WHILE
20 YOU'RE RIGHT IF WE TREATED IT ON SITE IT WOULD
21 COMPLETELY ELIMINATE THAT PROBLEM, IT'S PROBABLY NOT A
22 SERIOUS PROBLEM, BUT IT'S SOMETHING WE CAN LOOK AT
23 DURING THE DESIGN.
24 TONY JANNETTA: YOU HAVE VIDEO CAMERAS THAT GO DOWN
25 THE LINE AND CHECK IT IN ITS ENTIRETY.
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1 BERNIE HAYES: THOSE DO EXIST, BUT WHETHER OR NOT
2 IT'S SOMETHING THAT'S NECESSARY TO BE DONE IS SOMETHING
3 WE'LL JUST HAVE TO LOOK AT.
4 JERRY COLLINS: MY NAME IS JERRY COLLINS. THE ONLY
5 LAST QUESTION I HAVE IS THAT I'M CONCERNED WITH JUST
6 DUMPING THE CHEMICAL AT THE D.O.T. BECAUSE NATIONAL
7 STATUS HAS JUST RELEASED THAT IT'S EITHER LIKE 900
8 TREATMENT FACILITIES IN SOUTH CAROLINA ARE NOT UP TO PAR
9 FOR FRESH DRINKING WATER. SO RIGHT NOW, WE DON'T KNOW
10 WHETHER WE'RE GETTING ADEQUATE TREATMENT OF THE WATER AS
11 IT IS. I'M CONCERNED WITH WHAT I'M DRINKING NOW. I HAD
12 MEN WITH ROCK HILL, THE CITY, AND TEST MY WATER IN THE
13 HOUSE I JUST BOUGHT BECAUSE IT'S BEEN TASTING FUNNY EVER
14 SINCE I BOUGHT THE HOUSE. SO MY CONCERN IS THE WATER
15 I'M DRINKING NOW WITH THE NATIONAL AVERAGES THEY SAY
16 THAT ALL THE STATES, NORTH CAROLINA AND SOUTH CAROLINA
17 INCLUDED, THE WATER TREATMENT IS NOT UP TO PAR AND IT'S
18 NOT MEETING STANDARDS. SO YOU'RE GOING TO DUMP THIS
19 CHEMICAL IN ON TOP OF IT AND I'M GOING TO DRINK THAT FOR
20 30 YEARS. IN 30 YEARS YOU'RE GOING TO TREAT, RUN THIS
21 SYSTEM, 30 YEARS 15 HOW LONG IT WOULD TAKE BEFORE I
22 FOUND OUT WHETHER I HAVE CANCER OR NOT PROBABLY. THAT'S
23 MY BIGGEST CONCERN THAT YOU'RE GOING TO DUMP THIS IN ON
24 TOP OF WHAT ALREADY THEY'RE TRYING TO TREAT NOW WHICH I
25 DON'T THINK MY BELIEF IS INADEQUATE ANYWAY.
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1 SANDY MYERS: YOU'VE ALLUDED TO A HANDFUL OF
2 ISSUES.
3 JERRY COLLINS: BUT ALL I'M SAYING IS I THINK IT
4 SHOULD BE TREATED ON SITE AND THEN DUMPED. THAT'S THE
5 BOTTOM LINE.
6 BERNIE HAYES: JUST ONE QUICK RESPONSE TO THAT. I
7 DON'T WANT Y'ALL TO GET THE IMPRESSION THAT WE'RE JUST
8 TRYING TO SAY THAT NONE OF YOUR CONCERNS ARE YOU SHOULD
9 BE CONCERNED ABOUT THEM, BECAUSE THAT'S NOT TRUE. BUT
10 WE NEED TO BE CAREFUL THAT WE KEEP SEWAGE TREATMENT AND
11 WATER TREATMENT SEPARATE. THIS WATER IS GOING TO A
12 SEWAGE TREATMENT PLANT AND NOT A DRINKING WATER PLANT.
13 JERRY COLLINS: WfiERE DOES THE LIQUID THAT IS BEING
14 RUN OFF FROM THAT WASTE TREATMENT, WHERE IS IT GOING?
15 BERNIE HAYES: WELL, IT'S GOING TO GO BACK, YOU'RE
16 RIGHT, INTO A RIVER OR CREEK SOMEWHERE AND DEPENDING ON
1.7 WHAT WATER SOURCE IS USED FOR
18 JERRY COLLINS: WELL, I UNDERSTAND THAT. THAT
19 LIQUID WAS BEING CLEANED AND THAT IS YOUR. DRINKING
20 WATER. THAT IS INCORRECT?
21 BERNIE HAYES: NO. IN A LOT OF CASES, IT IS. BUT
22 IT DEPENDS ON WHERE YOU ARE IN RELATION TO THE DISCHARGE
23 FROM THIS PLANT. I DON'T KNOW WHERE THE WATER SUPPLIED
24 FOR THE CITY AROUND HERE IS. IS IT SURFACE WATER OR
25 GROUNDWATER?
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1 AUDIENCE: RIVER.
2 JANE DAVENPORT: WOULD A STUDY NOT BE DONE TO MAKE
3 SURE THAT IT DOESN'T GET BACK IN OUR DRINKING WATER? I
4 WOULD THINK THAT WOULD BE PART OF THE PROCESS.
5 SANDY MYERS: I THINK A STUDY OF THAT NATURE IS
6 VIRTUALLY IMPOSSIBLE. I THINK THAT IF YOU'RE GOING TO
7 TAKE WATER IN A SEWAGE TREATMENT PLANT THAT THEY
8 DISCHARGE INTO A CREEK AND THEN SOMEHOW OR ANOTHER TRACK
9 THAT WATER DOWN TO A DRINKING WATER PLANT THROUGH THE
10 PLANT DOWN THE LINES TO YOUR TAP, THAT'S VERY DIFFICULT.
11 BERNIE HAYES: AND LET'S KEEP THIS IN PROSPECTIVE.
12 OKAY? IF YOU HAVE A DRINKING WATER PLANT THAT'S DRAWING
13 FROM A RIVER IN THIS AREA, IT'S NOT AS IF THE EFFLUENT
14 FROM THE SITE IS GOING TO GO DIRECTLY INTO THAT RIVER.
15 OR EVEN IF YOU ASSUME IT'S GOING TO BE TREATED, THAT
16 THAT'S THE ONLY THING THAT'S GOING INTO THAT RIVER AND
17 IT'S THE ONLY THING THAT THAT WATER TREATMENT PLANT HAS
18 TO DEAL WITH. YOU COULDN'T GO DOWN TO THE RIVER AND
19 DRINK RIGHT OUT OF IT. THAT WATER TREATMENT PLANT IS
20 RESPONSIBLE FOR TREATING THAT WATER AND REMOVING
21 WHATEVER IS IN THERE TO MAKE THAT WATER SAFE, UNDER THE
22 SAFE DRINKING WATER ACT, NO MATTER WHAT'S IN THERE, NO
23 MATTER WHERE IT'S COMING FROM. SO YOU DO HAVE THIS
24 ROUTE, THIS POTENTIAL ROUTE OF CONTAMINANTS FROM THIS
25 SITE SOMEHOW GETTING THROUGH THE SEWER SYSTEM AND INTO
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1 THE RIVER AND BACK INTO THE DRINKING WATER PLANT, BUT
2 WHAT YOU HAVE IS UNLESS THEY'RE UPSTREAM FROM ONE
3 ANOTHER, WHICH IS WHAT I THINK THIS GENTLEMAN HAS
4 ALLUDED TO, BUT EVEN IF THAT WERE THE CASE, YOU'VE GOT A
5 SEWAGE TREATMENT PLANT THAT'S DESIGNED TO REMOVE THE
6 CONTAMINANT BEFORE IT GOES INTO THE RIVER AND YOU'VE GOT
7 A WATER TREATMENT PLANT DESIGNED TO REMOVE THE
8 CONTAMINANTS AS THEY COME OUT OF THE RIVER. AND BOTH OF
9 THOSE PLANTS ARE REGULATED BY THE STATE OF SOUTH
10 CAROLINA AND OVER YOU ALL BY EPA TO MAKE SURE THAT THEY
11 ARE FUNCTIONING PROPERLY. AND I'M NOT GOING TO SAY THAT
12 THEY ALWAYS FUNCTION PROPERLY, BUT
13 JERRY COLLINS: IN THE NATURAL STATUS OF RELEASE
14 THEY SAID THAT THE MAJORITY OF THEM WERE NOT UP TO PAR.
15 HOW DO WE FIND THAT OUT IS MY NEXT QUESTION?
16 BERNIE HAYES: WELL, THAT'S PART OF
1.7 JERRY COLLINS: WE MAY NOT DRINK THE WATER OUT OF
18 THAT WELL, OUT OF THAT PLUME, BUT WE'RE STILL DRINKING
19 TREATED WATER. DOESN'T MATTER WHAT'S BEEN DUMPED IN IT;
20 WE'RE DRINKING IT, AND WE DON'T KNOW WHAT WE'RE
21 DRINKING.
22 BERNIE HAYES: WELL, YOU CAN FIND THAT OUT. THE
23 MONITORING AND COMPLIANCE RECORDS FOR A PUBLIC WATER
24 SUPPLY ARE A MATTER OF
25 JERRY COLLINS: WELL, I'VE HAD THE WATER TESTED,
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1 BUT I'M NOT SATISFIED STILL. I'VE HAD THEM COME OUT AND
2 TEST IT TWICE, AND MY WATER STILL TASTES FUNNY.
3 BERNIE HAYES: THE OTHER THING YOU CAN DO IS ASK
4 THE PUBLIC WATER SUPPLY FOR THEIR RECORDS OF THEIR
5 TESTING AND THAT'S A MATTER OF PUBLIC RECORD. IF YOU
6 HAVE A PROBLEM WITH THEM, I IMAGINE DHEC COULD HELP YOU
7 WITH IT, THE STATE COULD HELP YOU WITH GETTING THOSE
8 RECORDS. THEY'RE REQUIRED TO TEST THE WATER FOR A WIDE
9 RANGE OF CONTAMINANTS ON A REGULAR BASIS
10 JERRY COLLINS: SUT THEY POLICE THEMSELVES; NOBODY
11 POLICES THEM.
12 BERNIE HAYES: NO. THE STATE POLICES THEM AND TO
13 SOME EXTENT THE EPA POLICES THEM.
14 JANE DAVENPORT: I HAVE A QUESTION. THAT GENTLEMAN
15 SAID SOMETHING ABOUT IF THE SOIL IS NOT REMOVED THAT THE
16 CONTAMINANTS ARE CONTAINED IN THE SOIL AND IF TEE SOIL
17 ON THE SITE IS NOT REMOVED, WON'T THE WATER BE
18 CONTAMINATED AGAIN? AND I DIDN'T HEAR A RESPONSE TO
19 THAT.
20 SANDY MYERS: OKAY. I MIGHT ASK YOU TO CLARIFY,
21 BUT I THINK I CAN ANSWER YOUR QUESTION. THERE IS
22 CONTAMINATION PRESENT IN THE SUBSURFACE AND SURFACE
23 SOILS; BUT THE CONTAMINATION THAT'S PRESENT, THEY'RE NOT
24 AT LEVELS THAT POSE Ati UNACCEPTABLE RISK.
25 JERRY COLLINS: BUT I WAS THE ONE THAT ASKED THAT
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1 QUESTION. MY QUESTION WAS IS THAT THE WATER IS BEING
2 CONTAMINATED FROM THE CHEMICALS IN THE SURFACE SOIL. IS
3 THAT CORRECT?
4 SANDY MYERS: NOT NECESSARILY, NO.
5 JERRY COLLINS: HOW IS THE WATER BEING
6 CONTAMINATED?
7 SANDY MYERS: THE CONTAMINANTS CAN BE INTRODUCED AT
8 THE SURFACE SOILS, AND THEY CAN LEACH DOWN TO THE
9 GROUNDWATER OVER A PERIOD OF 30 YEARS.
10 JERRY COLLINS: RIGHT, BUT THE WATER IS BEING
11 CONTAMINATED FROM THE SOIL THAT'S ON THE PROPERTY.
12 RIGHT?
13 SANDY MYERS: NOT NECESSARILY, NO. I MEAN THE
14 CONTAMINANTS CAN BE DOwsi IN THE GROUNDWATER.
15 TONY JANNETTA: WAS IT DUMPED IN THE WELL OR DID IT
16 GO THROUGH THE SOIL?
17 SANDY MYERS: IT WENT THROUGH THE SOIL.
18 JERRY COLLINS: BUT THE CHEMICALS ARE STILL IN THE
19 SOIL. CORRECT?
20 SANDY MYERS: YES. THERE ARE CHEMICALS IN THE
21 SOIL.
22 JERRY COLLINS: ALL RIGHT, BUT WHAT YOU'RE
23 BASICALLY GOING TO BE DOING THOUGH IS THE CONSTANTLY
24 FILTRATION SYSTEM WHER£ THE WATER GOES DOWN THROUGH THE
25 SOIL GETS DOWN TO WHERE THE PLUME IS AND YOU PUMP IT OUT
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1 AND IT'S JUST A CONSTANT - - - YOU'RE LETTING THE DIRT
2 BASICALLY FILTER OUT THE CHEMICAL. EVENTUALLY YOU'RE
3 HOPING THERE WILL BE NO MORE CHEMICAL LEFT TO GET DOWN
4 TO THAT WATER LEVEL. RIGHT?
5 SANDY MYERS: NO. THAT'S NOT THE WAY THAT I SEE
6 THIS.
7 JANE DAVENPORT: THE WATER CANNOT BE CONTAMINATED
8 AGAIN ONCE THIS IS DONE?
9 SANDY MYERS: I WOULD NEVER MAKE THAT STATEMENT. I
10 CAN'T WALK INTO THAT ONE. BUT I CAN SAY
11 LARRY CRUMP: I'M LARRY CRUMP. WHY DO YOU KEEP
12 BEATING AROUND THE BUSH AROUND NOT TAKING THE SOIL OUT
13 OF THERE? THERE'S WHERE THE CONTAMINATION IS COMING
14 FROM.
15 BERNIE HAYES: I THINK THE ANSWER TO THAT IS THE
16 VAST MAJORITY OF CONTAMINATED SOIL HAS ALREADY BEEN
1.7 REMOVED. I THINK IT'S A VALID COMMENT AND A VALID
18 CONCERN ON YOUR ALL'S PART THAT WE MAKE SURE THAT THAT'S
19 BEEN SUFFICIENTLY DONE. AND THAT'S SOMETHING WE'CAN
20 TAKE BACK MAKE SOME DECISION ABOUT. I'M NOT GOING TO
21 SIT HERE AND PROMISE YOU THAT WE'RE GOING TO LOOK AT
22 WHAT SOIL IS LEFT THERE AND TAKE MORE OF IT OUT, BUT
23 THAT'S PART OF THE PUBLIC PARTICIPATION PROCESS IS TO
24 LISTEN TO THESE COMMENTS, GO BACK, LOOK AT THE DATA
25 AGAIN, TRY TO MAKE A DECISION ABOUT WHETHER OR NOT
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1 ADEQUATE SOIL REMOVAL HAS BEEN DONE. AND YOU KNOW WHEN
2 WE MAKE' A DECISION ABOUT WHAT TO DO AT THE SITE, LET
3 Y'ALL KNOW THEN AGAIN WHAT THE DECISION IS. BUT THE
4 BOTTOM LINE, THE BASIC ANSWER TO YOUR QUESTION RIGHT NOW
5 IS THE VAST MAJORITY OF CONTAMINATED SOIL HAS ALREADY
6 BEEN REMOVED FROM THE SITE. LIKE SANDY SAYS, WE CAN'T
7 SIT HERE AND PROMISE YOU THAT EVERY LAST PARTICLE HAS
8 BEEN REMOVED TO THE POINT WHERE NO FURTHER LEACHING INTO
9 GROUNDWATER WILL TAKE PLACE, BUT
10 JERRY COLLINS: wHY ARE THE LEVELS SO HIGH STILL
11 THEN IP THE SOIL HAS BEEN REMOVED, AND THIS WAS A LONG
12 TIME AGO THAT THE SOIL WAS REMOVED? WHY ARE THE LEVELS
13 SO HIGH THEN IN THE WATER? IF IT'S THAT HIGH, 17,000
14 MILLIPARTS OR WHATEVER.
15 BERNIE HAYES: GROUNDWATER TAKES A VERY LONG TIME
16 TO CLEAN ITSELF UP, IF YOU WILL. I MEAN THAT'S NOT EVEN
17 THE RIGHT TERM TO USE.
18 JERRY COLLINS: IT'S NOT JUST GOING TO SIT THERE;
19 IT'S GOT TO GO SOMEWHERE, THAT WATER.
20 BERNIE HAYES: IT CAN SIT THERE FOR A VERY LONG
21 TIME.
22 JERRY COLLINS: IT'S GOT TO GO SOMEWHERE. IT'S
23 GOING TO BUILD UP TO THE POINT THAT WATER HAS TO GO
24 SOMEWHERE, EITHER INTO A WELL SYSTEM OR MOVE ON TO OTHER
25 GROUNDS OR CREEKS OR SOMETHING.
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SANDY MYERS: ONE POINT I'D LIKE TO MAKE IS THAT
THE PHYSICAL CHARACTERISTICS OF THE CHEMICALS TEAT WE'RE
TALKING ABOUT, ESPECIALLY THE THREE VOLATILES, THEIR
DENSITY IS HEAVY THAN WATER. WHAT THAT MEANS IS
ESSENTIALLY THEY SINK. SO THESE CONTAMINANTS, THEY HAVE
THE ABILITY TO SINK THROUGH THE SURFACE SOILS, THROUGH
THE SEDIMENT I MEAN THROUGH THE SUBSURFACE SOILS
DOWN IN THROUGH THE GROUNDWATER. THEY HAVE THE ABILITY
TO SINK LIKE THAT. THEY DON'T NECESSARILY JUST FLOW OFF
THE SITE SOMEWHERE. THAT'S HOW YOU CAN REACH SUCH HIGH
CONCENTRATIONS AFTER A 30 YEAR PERIOD.
JERRY COLLINS: WELL, I'M SURE THEY'RE BELOW THAT
WATER LEVEL, AND THEY'LL PROBABLY STAY THERE AND KEEP ON
SINKING DOWN INTO THE HARTH HOPEFULLY AND CLEAN
THEMSELVES UP.
SANDY MYERS: THAT'S A GOOD POINT.
BERNIE HAYES: YOU'RE HITTING THE NAIL RIGHT ON THE
HEAD WITH HOW DIFFICULT THIS REMEDIATION OF GROU^DWATER
CONTAMINATION IN THIS FASHION CAN BE.
JERRY COLLINS: BUT IN NONE OF THESE STUDIES ANYONE
HAS SAID ABOUT FURTHER REMOVAL OF DIRT. ALL YOU'RE
TALKING ABOUT IS PUMPIwG WATER OUT. YOU'RE NOT TALKING
ABOUT CLEANING UP THE SOIL THAT'S THERE, REMOVING IT.
SANDY MYERS: THAT'S CORRECT. AND THE REASON WE'RE
SAYING THAT IS BECAUSE THE LEVELS OF CONTAMINATION THAT
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WE HAVE IN THE SOILS DO NOT POSE AN UNACCEPTABLE RISK.
GLEN PELLETT: MY NAME IS GLEN PELLETT AGAIN. ONE
THING WE MAY BE MISSING IS THAT IT WASN'T THE SOIL THAT
CONTAMINATED THE GROUNDWATER; IT WAS WASTE THAT WAS
PLACED IN AND ON THAT SOIL, AND I BELIEVE ALL THE WASTE
HAS BEEN REMOVED. IS THAT CORRECT?
SANDY MYERS: WELL, THE ABOVE GROUND STORAGE TANKS
HAVE BEEN REMOVED. YES. AND SOME OF THE OBVIOUS SOIL
- - - IN THE PAST REMOVALS, SOME OF THE SOILS, WE HAD
THE REMOVALS WHERE THEY TOOK OUT THE SOILS.
GLEN PELLETT: SO THAT WAS SORT OF THE SOURCE OF
THE CONCENTRATION.
JERRY COLLINS: EVERY TIME YOU CHANGE YOUR OIL AND
DUMP IT IN YOUR BACKYARD AND FIVE YEARS FROM NOW DIG A
WELL AND DRINK THAT WATER. DIG THE DIRT UP FIRST THOUGH
AND PUT SOME FRESH DIRT DOWN, BUT THEN DRINK THAT WATER.
YOU'RE NOT GOING TO GET IT OUT. IT'S IN THAT DIRT AND
THAT'S SEEPING DOWN, IT'S CONTINUALLY SEEPING, BLEEDING
DOWN AS A FILTERING SYSTEM BASICALLY, THE SOIL IS. YOU
CAN ONLY GET SO MUCH DIRT OUT. YOU CAN'T DIG DOWN 54
FEET AND TAKE OUT ALL THAT SOIL DOWN TO THE WATER LEVEL.
TONY JANNETTA: I'D LIKE TO ASK A QUESTION IN
REFERENCE TO ONCE THIS IS DONE WHETHER YOU DUMP IT AND
TREAT THE WATER AND YOU REMOVE THE AREA OF THE PLUME AND
YOU FEEL COMFORTABLE THAT YOU'VE REMOVED THAT MUCH WATER
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1 AND IT'S SUFFICIENT AND EVERYTHING TESTS OUT OKAY AT A
2 CERTAIN POINT IN TIME, WHAT WILL THE EPA AND THE STATE
3 DO TO MAKE CERTAIN THAT THE PROBLEM DOES NOT EXIST IN
4 THE FUTURE. WILL THEY STILL REMAIN --- WILL THERE BE
5 TESTING AFTERWARDS?
6 SANDY MYERS: YES. THERE WILL BE LONG TERM
7 MONITORING. WE WILL MAKE SURE THAT THE PROBLEM DOESN'T
8 POP UP AGAIN. THAT'S THE WHOLE PURPOSE OF OUR
9 MONITORING PROGRAM. YES.
10 TONY JANNETTA: THROUGHOUT THE SITE? THROUGHOUT
11 THE NEIGHBORHOOD?
12 SANDY MYERS: YES, THROUGH THE WELLS THAT WE WILL
13 HAVE ON THE SITE. AT THIS POINT, WE DON'T KNOW EXACTLY
14 WHERE THE WELLS ARE GOING TO BE. WE DECIDE THAT IN THE
15 DESIGN PHASE. WE'LL DECIDE WHERE THE ACTUAL WELLS WILL
16 BE PLACED, BUT THERE WILL BE COMPLIANCE WELLS PLACED,
1.7 AND WE'LL MONITOR THOSE WELLS.
18 TONY JANNETTA: SINCE WE KNOW THOSE CHEMICALS A*Z
19 DEEPER THAN THE WATER STRATUM, WILL THERE BE DEEPER
20 WELLS?
21 SANDY MYERS: SINCE ---
22 LARRY CRUMP: HOW DID THAT BANK GET BUILT THERE :»
23 THAT SOIL IF THE KIND OF CONTAMINATION EXISTED?
24 JERRY COLLINS: THEY TRIED TO CLEAN IT UP. THEY
25 DUG UP THREE FEET.
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1 LARRY CRUMP: THEY DIDN'T DIG DEEP ENOUGH, MY
2 FRIEND.
3 JERRY COLLINS: I KNOW THAT.
4 LARRY CRUMP: THEY STILL BUILT.
5 JERRY COLLINS: AND THEY'RE NOT INCLUDING THIS
6 BANK, THAT PROPERTY, IN THIS CLEANUP. IF THE PLUME DOES
7 GO UNDERNEATH THE PROPERTY OF THAT BANK, THE SOIL THREE
8 FEET UNDER WHERE THEY EXTRACTED THAT SOIL, IT'S STILL
9 CONTAMINATED AND HOPEFULLY IT WILL BE CLEANED UP ON ITS
10 OWN WHEN IT FILTRATES OUT. BUT IT'S GOT CONCRETE
11 COVERING THAT SOIL OVER THAT WHERE THE SITE IS AND I
12 DON'T SEE HOW THE RAINWATER, THE WATER TABLE, WHATEVER, |
13 CAN FILTER THAT OUT. THAT'S TRAPPED UNDER THAT
14 CONCRETE.
15 SANDY MYERS: WE'LL HAVE TO LOOK INTO THAT.
16 MARK DAVIS: LET ME CLARIFY THAT. THE BANK REMOVES
17 THAT SOIL WHICH WAS CONTAMINATED, AND THEY DID THAT
18 REMOVAL WITH OVERSIGHT FROM EPA AND THE STATE OF SOLTH
19 CAROLINA.
20 JERRY COLLINS: RIGHT, BUT THEY ONLY TOOK OUT ABOUT
21 THREE FEET OF SOIL.
22 MARK DAVIS: THEY TOOK OUT THE HOT SPOTS, THE ASEAS
23 THAT HAD THE CONTAMINATED SOIL. THEY REMOVED ALL THAT
24 SOIL.
25 JERRY COLLINS; THREE FEET OF IT. THEY ONLY TOCK
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1 OUT THREE FEET.
2 MARK DAVIS: THAT'S RIGHT. THAT'S ALL THEY TOOK
3 OUT.
4 JERRY COLLINS: FROM THE TIME THAT THAT LIQUID, THE
5 CHEMICALS, WERE LEAKING FROM 1964, WHO'S TO SAY IT
6 DIDN'T GO FOUR FEET, FIVE FEET, IN THAT SITE IN THAT
7 AREA?
8 TONY JANNETTA: THEY WERE NOT TESTING WELLS AT THAT
9 POINT IN TIME.
10 MARK DAVIS: THEY WEREN'T ANY TESTS OF WELLS, BUT
11 THERE WAS SOIL TESTING.
12 JERRY COLLINS: THEY DIDN'T DO ANY SOIL TESTING ON
13 THAT SITE WHERE THAT BANK IS.
14 MARK DAVIS: BACK WHEN THEY DID THE REMOVAL, YES,
15 THEY DID.
16 JERRY COLLINS: BACK IN THE REMOVAL. WHAT ABOUT
11 NOW?
18 MARK DAVIS: RIGHT. THEY HAD GOTTEN A CLEAN BILL
19 OF HEALTH FROM THE STATE OF SOUTH CAROLINA STATING THAT
20 THAT SOIL THAT WAS LEFT AFTER THE EXCAVATION WAS CLEAN
21
22 JERRY COLLINS: BACK THEN. WHAT ABOUT NOW? NO ONE
23 DID ANY TESTS ON THAT PROPERTY NOW. THEY'RE NOT EVEN
24 - - -
25 BERNIE HAYES: IF IT WAS CLEAN THEN IT'S CERTAINLY
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1 NOT GOING TO GET ANY WORSE OVER TIME. IT'S ONLY GOING
2 TO GET BETTER.
3 LARRY CRUMP: HOW DO YOU KNOW IT'S CLEAN NOW?
4 TONY JANNETTA: WHY DON'T YOU BUILD A DIAGONAL WELL
5 AND GO UP UNDER THE BANK AND SEE IF THERE'S ANYTHING
6
7 MARK DAVIS: WE KNOW THERE'S GROUNDWATER
8 CONTAMINATION UNDER THAT BANK PROPERTY. THAT'S GOING TO
9 BE EXTRACTED ALONG WITH THE REST OF THE GROUNDWATER
10 DURING THE REMEDIATION.
11 JERRY COLLINS: YOU DIDN'T EVEN TELL US IN THE
12 BEGINNING THAT THAT PROPERTY THAT THAT BANK IS SITTING
13 ON WAS ORIGINALLY OWNED BY THAT CHEMICAL COMPANY.
14 YOU'VE GOT A BARRIER DRAWN AROUND THAT PROPERTY.
15 MARK DAVIS: THAT PROPERTY WASN'T OWNED - - - THE
16 CHEMICAL COMPANY DIDN'T OWN ANY OF THAT PROPERTY. THE
17 CHEMICAL COMPANY OPERATED ITS FACILITY ON THAT AREA, BUT
18 THAT PART WHERE THE BANK IS WAS NOT THE PHYSICAL
19 LOCATION OF THE CHEMICAL COMPANY. ACTUALLY, THE JTWO HOT
20 SPOTS THAT THE REMOVAL WAS DONE THAT SANDY MENTIONED
21 EARLIER, THAT IS THE LOCATION OF THE CHEMICAL COMPANY'S
22 OPERATIONS. FOR SOME UNKNOWN REASON, THE OPERATOR OF
23 THAT CHEMICAL COMPANY TOOK ITS CHEMICALS AND TRANSFERRED
24 OVER TO THE AREA WHERE THE BANK IS.
25 JERRY COLLINS: YOU'RE SAYING THAT THEY NEVER OWNED
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1 THE PROPERTY WHERE THE BANK IS SITTING?
2 _ MARK DAVIS: THE CHEMICAL COMPANY NEVER OWNED ANY
3 OF THAT PROPERTY.
4 JERRY COLLINS: IT' S JUST OUT OF THE WAY OF THE
5 BOUNDARY THAT'S DRAWN OUT AROUND IT, IT LOOKS LIKE IT
6 WOULD BE A FULL BLOCK OR WHATEVER.
7 MARK DAVIS: THE REASON THAT WAS DRAWN OUT IS
'8 BECAUSE IT WAS NOT PART OF THE CHEMICAL COMPANY'S
9 OPERATIONS, NUMBER ONE.
10 JERRY COLLINS: OPERATIONS, BUT THEY NEVER OWNED
11 THAT PROPERTY?
12 MARK DAVIS: RIGhT. THEY DIDN'T OWN THAT PROPERTY,
13 BUT THEY OPERATED ON THAT PROPERTY.
14 JANE DAVENPORT: THEY DUMPED ON IT.
15 MARK DAVIS: THEY DUMPED ON IT. THEY WERE LIKE A
16 MIDNIGHT DUMPER, WHAT YOU WOULD CALL A MIDNIGHT DUMPER
17 ON THE PROPERTY WHERE THE BANK WAS LOCATED.
18 JERRY COLLINS: WHAT IT SAID IN THE PAPERS THAT
19 THIS WAS NOT JUST WHERE THEY WERE STORING THE CHEMICALS.
20 THEY WERE TRYING TO CLEAN IT UP. THIS IS A COMPANY THAT
21 CLEANED CHEMICALS, CLEANED UP THE WASTE, THAT THEY WSP»
22 ACTUALLY DUMPING IT ON SITE. SINCE 1964, THERE'S NO
23 TELLING HOW MUCH IS IN THAT SOIL DOWN THERE.
24 MARK DAVIS: WE HAVE DONE SOIL SAMPLING THROUGKCVT
25 THAT WHOLE AREA.
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1 JERRY COLLINS: ESPECIALLY WHERE THE BANK'S AT,
2 YOU'RE SAYING THAT'S WHERE THEY WERE DUMPING IT AT.
3 MARK DAVIS: THAT'S WHERE THEY DID DUMPING. THAT'S
4 WHERE THE BANK EXCAVATION
5 JERRY COLLINS: IT'S KIND OF ODD THAT THREE FEET OF
6 SOIL WAS REMOVED THEN BOOM, THE BUILDING WAS BUILT ON
7 TOP OF THAT. THAT'S A HOT SPOT.
8 TONY JANNETTA: YOU'RE NOT BEING CONCLUSIVE AFTER
9 GOING THROUGH ALL THIS AND PUMP ALL THIS SOMEWHERE, AND
10 THERE'S ANOTHER PROBLEM SOMEWHERE ELSE. YOU WANT TO BE
11 CONCLUSIVE IN THE OTHER AREAS BEFORE YOU SINK IN TWO
12 MILLION DOLLARS TO DO SOMETHING WHEN YOU MIGHT HAVE TO
13 REDO IT AGAIN.
14 SANDY MYERS: CERTAINLY. ABSOLUTELY.
15 TONY JANNETTA: YOU WANT TO BE SURE ABOUT IT.
16 . SANDY MYERS: WE 60RE DO.
17 BERNIE HAYES: LIKE I SAID, THIS IS GOOD
18 DISCUSSION. IT'S IMPORTANT THAT WE GET THESE THINGS ON
19 THE TABLE SO THAT WE CAN • I MEAN WE CAN'T ANSWER
20 YOUR QUESTIONS ABOUT WHETHER OR NOT SUFFICIENT SOIL
21 REMOVAL WAS DONE UNDER THE BANK. OBVIOUSLY WE FROM OUR
22 INVESTIGATIONS FEEL THAT THERE WAS. BUT THE FACT THAT
23 IT'S SUCH A MAJOR POINT OF CONCERN FOR SEVERAL PEOPLE
24 HERE MEANS THAT WE NEED TO GO BACK AND TAKE A LOOK AT
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JERRY COLLINS: YOU DIDN'T CHECK IT OUT. YOU JUST
LOOKED AT OLD REPORTS SAYING THAT THEY WERE CONCLUSIVE
BACK IN 1985. YOU DIDN'T DO ANY STUDIES, RESEARCH SOIL
SAMPLES NOW.
BERNIE HAYES: THAT MAY BE A VALID CRITICISM, AND
WE CAN GO BACK AND TAKE A LOOK AND DETERMINE WHETHER OR
NOT WE IN FACT NEED TO DO MORE WORK THERE.
TONY JANNETTA: YOU'VE GOT PROPERTY IN THE AREA
THAT MAY BE REDEVELOPED, MY BUSINESS, ALL OF OUR HOMES.
LET'S JUST SAY FOR BUSINESS PRACTICE. AND THEY'RE GOING
TO HAVE TO GO THROUGH THE SAME PROCEDURE KNOWING THAT
THAT'S A CONTAMINATED AREA, THAT'S GOING TO BE RIGHT UP
FRONT. THEY'RE GOING TO HAVE TO HAVE ALL KINDS OF
ANALYSIS DONE BEFORE THEY CAN GET PERMITS AND EVERYTHING
TO MAKE SURE THAT THEIR PROPERTY IS SAFE. AND YOU'VE
GOT SOME UNDEVELOPED LASD AROUND THERE THAT'S GOING TO
BE DEVELOPED ONE OF THESE DAYS, AND THIS MAY COME BACK
TO HAUNT THEM AND Y'ALL.
JERRY COLLINS: WHAT IF THIS PROPERTY IS EVER SOLD
WHERE THE BANK SITS? THE FRESH CITY WATER COMING UP
THROUGH THAT PROPERTY, THAT'S WHERE THE PLUME AREA IS.
I CERTAINLY WOULDN'T EVER WANT TO WORK THERE AND GO IN
TO USE THE BATHROOM AND DRINK WATER OR SOMETHING LIKE
THAT. I CERTAINLY WOULDN'T WANT TO WORK THERE.
MARK DAVIS: LET ME CLARIFY SOMETHING. SIMPLY
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1 BECAUSE THE MAP THAT SANDY HAS DRAWN CARVED OUT THE BANK
2 DOESN'T MEAN THAT THAT GROUNDWATER THAT IS LOCATED
3 UNDERNEATH THE BANK IS NOT GOING TO BE CLEANED UP. THAT
4 IS ALL GOING TO BE PART OF THE OVERALL CLEANUP. WE'RE
5 TALKING ABOUT ONE OBSTACLE
6 JERRY COLLINS: WATER EXTRACTION ONLY. THE SOIL IS
7 NOT GOING TO BE CLEANED UP.
8 MARK DAVIS: THE SOIL RECEIVED A CLEAN BILL OF
9 HEALTH.
10 JERRY COLLINS: BACK IN '85, THREE FEET OF IT.
11 BERNIE HAYES: AGAIN, LET'S TRY TO PULL BACK FROM
12 THIS A LITTLE BIT AND TRY TO KEEP IT IN PROSPECTIVE. WE
1.3 SAMPLED THE SOILS.
14 JERRY COLLINS: THAT PROPERTY WILL GO REAL CHEAP.
15 BERNIE HAYES: THE ONLY
16 LARRY CRUMP: DID if'ALL DO A SAMPLE UP AROUND BY
1.7 THE BANK? HOW COME Y'ALL DIDN'T DRILL A WELL UP THERE
18 BY THE BANK, NEAR ITS PROPERTY?
19 BERNIE HAYES: AGAIN, LET'S KEEP THIS IN
20 . PROSPECTIVE.. MORE WELLS WOULD ONLY TELL US
21 LARRY CRUMP: THE BANK IS IN PROSPECTIVE HERE. AS
22 I'M ASKING QUESTIONS I WOULD LIKE TO HAVE ANSWERS FOR
23 AND I DON'T WANT TO BE BEAT AROUND THE BUSH ABOUT IT.
24 BERNIE HAYES: SOME OF THE THINGS THAT Y'ALL ARE
25 BRING UP ARE THINGS WE CAN'T ANSWER RIGHT NOW. YOUR
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1 OPINION IS AND THE COMMENTS THAT YOU'RE EXPRESSING HERE
2 ARE THAT WE DIDN'T DO ENOUGH TO INVESTIGATE CERTAIN
3 ASPECTS OF THIS SITE. THAT MAY BE. ALL WE CAN TELL YOU
4 IS WE'LL GO BACK, WE'LL LOOK AT THE DATA THAT WE HAVE,
5 WE'LL HAVE OTHER PEOPLE LOOK AT THE DATA THAT WE HAVE
6 AND SEE IF IN FACT THAT IS THE CASE. BUT FOR US TO SIT
7 HERE AND TELL YOU THAT BECAUSE OF YOUR CONCERNS ABOUT
8 THE EXTENT AND THE INVESTIGATION THAT WAS DONE OR THE
9 LACK OF IT THAT WE'RE GOING TO GO OUT AND DO MORE WORK,
10 IT WOULDN'T BE A GOOD IDEA FOR US SPENDING YOUR MONEY TO
11 MAKE A BLANKET COMMITMENT TO THAT RIGHT HERE TONIGHT
12 WITHOUT GOING BACK AND LOOKING AT THE SITUATION AND
13 LOOKING AT THE DATA THAT WE HAVE. SO AGAIN, I'LL TELL
14 YOU THESE ARE VALID COMMENTS. THERE'S REASON FOR US TO
15 GO BACK AND LOOK AT WHAT WE'VE DONE AND DETERMINE
16 WHETHER OR NOT IN FACT AS YOU ALL HAVE EXPRESSED WE
1.7 MAYBE SHOULD HAVE DONE MORE. BUT IT WOULD BE
18 IRRESPONSIBLE FOR US TO COMMIT TO YOU OR TO TELL YOU
19 THAT IN FACT THAT'S WHAT WE'RE GOING TO DO SIMPLY ON THE
20 BASIS OF YOUR COMMENTS TONIGHT AND MAKE A SNAP DECISION
21 HERE IN THIS ROOM TO SPEND ANOTHER SEVERAL HUNDRED
22 THOUSANDS DOLLARS OF TAXPAYER MONEY. SO IN A SENSE,
23 WE'RE TRYING TO ANSWER YOUR QUESTIONS, BUT IN ANOTHER
24 SENSE WHEN YOU SAY WE HAVEN'T DONE ENOUGH AND WE NEED TO
25 DO MORE, WE CAN'T ANSWER THAT TONIGHT OTHER THAN TO SAY
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THOSE ARE THE KIND OF COMMENTS WE WANT TO HEAR AND WE'LL
GO BACK AND WE'LL LOOK AT THE DATA WE HAVE AND TRY TO
MAKE A DECISION WHETHER THAT IN FACT IS THE CASE. AND
THAT'S WHAT WE'LL DO.
LARRY CRUMP: HOW WILL WE KNOW WHAT THAT DECISION
WILL BE?
BERNIE HAYES: WELL, THERE WILL BE OTHER PUBLIC
MEETINGS AND OTHER OPPORTUNITIES FOR PUBLIC
PARTICIPATION.
LARRY CRUMP: THIS IS NOT THE FINAL ONE?
BERNIE HAYES: NO, BY NO MEANS.
JERRY COLLINS: HAS ANYONE IN THE EPA WHEN THEY HAD
THE MEETINGS IN THE MINUTES AND RECORDS, HAS ANYONE IN
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THE EPA EVER RECOMMENDED REMOVING OF THAT SOIL. NOWHERE
IN HERE DOES IT SAY ANYTHING ABOUT REMOVING THE SOIL.
AND IT SAYS OPTIONS THAT THEY SAID WERE UNSATISFACTORY
ABOUT LIKE LEAVING IT DORMANT, NOT DOING ANYTHING WITH
IT. THAT'S UNSATISFACTORY. THE FIRST TWO CHOICES WERE
UNSATISFACTORY. WAS REMOVAL OF THE SOIL EVER BROUGHT UP
BY SOMEONE ON THE EPA COMMITTEE OR WHOEVER, BY AN
OUTSIDER? IS THERE ANY PUBLIC RECORDS OF ANYBODY
SUGGESTING THAT THE SOIL BE REMOVED?
BERNIE HAYES: SANDY, CAN YOU
SANDY MYERS: AGAIN, WE'D HAVE TO GO BACK AND LOOK
THROUGH THE RECORDS TO SEE.
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JERRY COLLINS: TO MY UNDERSTANDING I GUESS I CAN
SEE THAT IT WOULD BE VERY EXPENSIVE TO REMOVE TEAT SOIL
AND THEN YOU HAVE TO TAKE THAT SOIL TO ANOTHER FACILITY
AND BURY IT.
TONY JANNETTA: DO YOU BURY IT OR DO YOU INCINERATE
IT?
SANDY MYERS: THAT'S A QUESTION THAT WOULD BE
ANSWERED IN THE FEASIBILITY STUDY WHERE WE GO IN AND
LOOK AT DIFFERENT ALTERNATIVES.
TONY JANNETTA: ISN'T THERE TECHNOLOGY THAT IF
YOU'VE GOT CONTAMINATED SOIL, WE DON'T KNOW IT, YOU
CAN'T OBLIGATE WHAT METHOD WOULD BE USED?
SANDY MYERS: YES. THERE.ARE ALTERNATIVES TO CLEAN
UP CONTAMINATED SOIL.
TONY JANNETTA: WE SAD A SCHOOL HERE THAT HAD
BURIED TANKS, AND THE SOIL WAS DUG UP AND INCINERATED
AND BROUGHT IT BACK TO LIFE WHERE YOU COULD REUSE IT
AGAIN. SO I'M SURE TECHNOLOGY IS THERE.
SANDY MYERS: YES. THERE ARE OPTIONS. THERE ARE
TECHNOLOGIES AVAILABLE TO CLEAN UP CONTAMINATED SOIL.
TONY JANNETTA: IT SOUNDS LIKE TO ME YOU'RE LEAVING
SOMETHING UNDONE.
JERRY COLLINS: IT SOUNDS TO ME LIKE THERE'S A
LITTLE BIT OF LET'S GET THIS SMOOTHED OVER, LET'S GET IT
OUT OF THE WAY HERE. LET'S LET THESE PEOPLE THINK THAT
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1 EVERYTHING'S BEING TAKEN CARE OF.
2 SANDY MYERS: I CERTAINLY RESPECT YOUR OPINION.
3 JERRY COLLINS: THE SOIL IS A PRIMARY CONCERN,
4 ISSUE. SURE YOU WANT THAT WATER CLEANED UP, BUT WHAT'S
5 CAUSING THAT WATER. IT'S THE CHEMICAL THAT IS STILL
6 LEFT IN THAT SOIL.
7 TONY JANNETTA: IT'S A SPONGE, THE SOIL.
8 JERRY COLLINS: YOU CAN THINK OF IT
9 BILL RUTLEDGE: I'M BILL RUTLEDGE, AND I'D JUST
10 LIKE TO SAY A COUPLE OF THINGS, MAYBE IT WILL HELP.
11 SOME OF THESE FOLKS HAVE A BETTER UNDERSTANDING. PART
12 OF THEIR CONCERN I THIWK IS CAUSED BY LACK OF KNOWLEDGE
13 AND UNDERSTANDING AT JUST WHAT HAS BEEN DONE AND WHAT'S
14 PLANNED FOR THE FUTURE. A LOT OF TESTING OF SOIL
15 FOLLOWED THE REMOVAL OF THE LIQUIDS ON SITE, AND SOIL
16 HAS BEEN REMOVED. AND WHAT HAS BEEN DONE IS EXACTLY
17 WHAT THE GENTLEMAN SAID WHY WOULDN'T IT BE DONE, AND
18 THAT IS TESTING AND REMOVAL OF SOME SOIL, EXTENSIVE
19 TESTING OF THE SITE BEHIND THE BANK BUILDING THAT .YOU
20 HAVE CUT OUT THERE. THERE'S TWO SEPARATE SITES FOR THE
21 BANK, IF I MIGHT JUST ADDRESS THAT IN A POSITIVE WAY,
22 WAS NEVER OWNED OR CONTROLLED IN ANY WAY BY THE CHEMICAL
23 COMPANY. THE FRONT SITE THAT'S ON THE HIGHWAY, THE SITE
24 BEHIND IT WAS A LOW AND IT WAS USED AS A FILL OF
25 CONSTRUCTION MATERIAL ABOUT FOUR OR FIVE DRUMS OF STILL
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1 BOTTOMS, WHICH WAS PAINTS OR DYES, GOT OVER THERE AND
2 THEY PROBABLY HAD TEN OR FIFTEEN GALLONS OF DRIED
3 IF YOU'VE EVER HAD AN OLD PAINT CAN AND IT DRIED OUT,
4 YOU KNOW WHAT I'M TAKING ABOUT, WHAT'S LEFT AFTER ALL
5 THE SOLVENTS AND LIQUIDS HAVE DISSIPATED. AND THAT'S
6 EXACTLY WHAT WAS BEHIND WHAT IS NOW THE VACANT BANK
7 BUILDING. IT WASN'T BURIED THERE AS A DUMP. I DON'T
8 LIKE THAT MIDNIGHT DUMPING. I SAY THAT IN HUMOR BECAUSE
9 I KNOW WHAT YOU'RE TALKING ABOUT. IT WAS JUST ONE OF
10 THOSE THINGS. I WAS IS THE CONSTRUCTION BUSINESS. WE
11 WERE DUMPING ASPHALT BACK THERE. WE WERE DUMPING ROCKS.
12 WE WERE DUMPING SAND, DIRT, AND WHATNOT, AND THAT'S ALL
13 THAT GOT BACK THERE. THAT WAS NOT FOUND WHEN THEY DUG
14 THE FOUNDATIONS. LAW ENGINEERING WENT BACK IS THERE TO
15 DO SOME SITE STUDIES WITH DRILLING EQUIPMENT. THESE
16 DRUMS WERE FOUND, SOME OF THEM, AND THEY WERE IN
17 DIFFERENT LOCATIONS. THEY WEREN'T CONCENTRATED. SO THE
18 BANK DECIDED JUST TO GO IN THERE AND STRIP THE WHOLE
19 SITE. THEY STRIPPED THAT WHOLE SITE, TOOK THE DlST OUT,
20 HAULED PART OF IT TO THE FILL DOWNSTATE AND PART OF IT
21 TO THE COUNTY LANDFILL. AND THEY HAULED IN RED CLAY ON
22 THAT SITE. THEY DID EXTENSIVE SOIL TESTING TO DETERMINE
23 AT WHAT LEVEL THEY QUIT EXCAVATING. AND EPA AND DHEC
24 WERE ON SITE. IT WAS iiONITORED. I THOUGHT THEY DID AN
25 AWFUL LOT MYSELF, AND ALSO ON THE SITE NEXT DOOR WE DID
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1 THE SAME THING. WE EXCAVATED AND HAULED OUT. SO THERE
2 HAS TO BE SOME BOUNDARY SOMEWHERE. SO A LOT OF TIME,
3 MONEY, AND EFFORT HAS BEEN PUT FORTH TO GET IT TO THE
4 POINT THAT IT IS. THERE'S NO WAY ANY SOIL, IF YOU JUST
5 GO ON ANY SOIL ALMOST YOU FIND IN ANYWHERE, THERE ARE
6 SOME LEVELS OF CONTAMINATION. SOME OF THEM ARE METALS.
7 WE FIND SILVER, MANGANESE, IRON IN SOILS. AND SOME OF
8 THEM ARE AT A YOU HAVE TO SAY THERE'S AN
9 ACCEPTABLE LEVEL. YOU CAN'T GUARANTEE ANYTHING AND
10 EVERYTHING. WHEN WE WALK OUT OF HERE TONIGHT, THE ROADS
11 HAVE BEEN PROVIDED FOR OUR SAFETY, THE STOP SIGNS, THE
12 HIGHWAY PATROL; BUT IT DOESN'T GUARANTEE ME SAFE PASSAGE
13 HOME. I MAY BE KILLED BEFORE I GET THERE. SO YOU CAN'T
14 JUST YOU CAN'T GO TO CHINA TO GET RID OF THE
15 CONTAMINATED SOIL.
16 JERRY COLLINS: YOU'RE MR. RUTLEDGE?
17 BILL RUTLEDGE: YOU NEED TO ADDRESS THEM IF YOU
18 HAVE A QUESTION.
19 JERRY COLLINS: IS THIS MR. RUTLEDGE HERE?
20 BILL RUTLEDGE: I AM BILL RUTLEDGE.
21 JERRY COLLINS: DO YOU OWN THIS PROPERTY?
22 BILL RUTLEDGE: THE CORPORATION OWNS THE PROPERTY.
23 I DON'T.
24 JERRY COLLINS: DO YOU OWN THE CORPORATION?
25 SANDY MYERS: LET'S NOT GET INTO A DEBATE
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1 JERRY COLLINS: WHAT I'M GETTING AT, IT SOUNDS VERY
2 CONVINCING, BUT I BELIEVE THIS MAN OWNS THIS PROPERTY.
3 AND THAT FROM WHAT I'VE READ IS MR. RUTLEDGE AND THE TEN
4 OTHER COMPANIES THAT ARE RESPONSIBLE FOR DELIVERING THE
5 CHEMICALS EVEN THOUGH THEY DIDN'T DUMP THE CHEMICALS ON
6 SITE, THEY'RE RESPONSIBLE FOR THE CLEANUP COSTS BECAUSE
7 THEY HAVE CONTRIBUTED TO LIKE ONE OF THEM IS
8 CELANESE, I BELIEVE. CELANESE HERE IN ROCK HILL WAS
9 PART OF ONE OF THOSE TEN COMPANIES THAT DELIVERED
10 CHEMICALS TO THEM. SO HIS STORY SOUNDS VERY GOOD, BUT
11 FROM WHAT I UNDERSTAND HE OWNS THIS PROPERTY OR HAS
12 SOMETHING TO DO WITH IT STILL AND HE IS ALSO HAVING TO
13 PAY FOR THIS CLEANUP. SO DON'T JUST BE FOOLED.
14 SANDY MYERS: ARE THERE ANY OTHER QUESTIONS OR
15 CONCERNS?
16 TONY JANNETTA: THE DIFFERENCE IN PRICE BETWEEN AN
1.7 ON SITE CLEANING AND USING THE CITY'S FACILITIES, WHAT
18 WAS THAT DETERMINATION?
19 SANDY MYERS: IT'S ROUGHLY HALF. TREATING ON SITE
20 WAS ABOUT IN THE NEIGHBORHOOD OF FOUR MILLION DOLLARS
21 AND DIRECT DISCHARGE WAS ABOUT TWO MILLION DOLLARS.
22 TONY JANNETTA: YOU KNOW, THE CITY HAS A NEW POLICY
23 NOW. BACK THEN WHEN THEY DID IT, WHEN THE CHEMICAL
24 COMPANIES WERE AROUND, THEY DID IT THEIR WAY. THE
25 CITIES DID NOT HAVE THE REGULATIONS THAT THEY HAVE NOW.
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1 THE REGULATIONS ARE CHANGING AS OF TODAY, DAY TO DAY.
2 CHEMICAL COMPANIES NOW HAVE TO TREAT THEIR WASTE TO AN
3 ACCEPTABLE CITY STANDARDS, STATE STANDARDS, BEFORE IT'S
4 DUMPED INTO THE CITY'S SEWER SYSTEM. THIS IS WHERE I GO
5 BACK IF YOU TREAT IT ON SITE TO AN ACCEPTABLE LEVEL .
6 PRIOR TO DUMPING IT IN THE CITY SEWER SYSTEM THAT'S NOW
7 BEING USED THAT IS NOW BEING ADDRESSED TO OTHER
8 COMPANIES THAT ARE ESTABLISHING HERE IN ROCK HILL, THAT
9 WOULD PROVIDE OUR SAFEGUARD IN ADDITION TO THE CITY'S
10 TREATMENT SYSTEM.
11 SANDY MYERS: I APPRECIATE YOUR COMMENT. ARE THERE
12 ANY OTHER QUESTIONS?
13 JERRY COLLINS: I HAVE JUST ONE QUESTION RELATED TO
14 WHAT I SAID ABOUT THE TEN COMPANIES THAT ARE GOING TO BE
15 RESPONSIBLE FOR CLEANING UP. HOW COME THIS HAS NOT BEEN
16 BROUGHT UP AS FAR AS WHO IS PAYING FOR THIS? IT'S NOT
1.7 THE CITY OF ROCK HILL THAT'S GOING TO PAY FOR THIS?
18 MARK DAVIS: NO. IT IS NOT. THE PARTIES
19 RESPONSIBLE FOR THE CONTAMINATION WILL PAY FOR ALL THE
20 COSTS, ALL THE PAST COSTS, ALL THE FUTURE COSTS.
21 JERRY COLLINS: HE WILL?
22 MARK DAVIS: ALL THE PARTIES RESPONSIBLE.
23 JERRY COLLINS: WHO ARE THOSE PARTIES?
24 MARK DAVIS: I THINK YOU MENTIONED TEN OF THOSE
25 TEN COMPANIES THAT YOU KNEW OF.
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1 JERRY COLLINS: IS BILL RUTLEDGE ONE OF THESE
2 PARTIES?
3 MARK DAVIS: WE HAVE NOT FILED A LAWSUIT AS OF YET
4 SO I CAN'T NAME WHO. WE'RE GOING TO GO AFTER EVERYBODY
5 WHO WE CAN WHO WE CAN RECOVER MONEY FROM.
6 JERRY COLLINS: DID THE COMPANY, I WANT TO SAY
7 BILL RUTLEDGE'S COMPANY, DID THEY ILLEGALLY DUMP THIS
8 CHEMICAL ON THE LOCATION WHERE THE BANK IS AT?
9 MARK DAVIS: NO.
10 JERRY COLLINS: THEY DO NOT OWN THAT PROPERTY SO
11 THEY WERE DUMPING IT, SOMEBODY WAS DUMPING IT ILLEGALLY
12 IF THEY DIDN'T OWN IT.
13 MARK DAVIS: YOU HAVE TO UNDERSTAND WHEN THIS
14 COMPANY WENT OUT OF BUSINESS BACK IN 1964, SUPERFUND LAW
15 WAS NOT ENACTED UNTIL 1980. AND AT THE TIME THEY DID
16 THE DUMPING, THERE WAS NO SUCH THING AS ILLEGAL DUMPING;
17 THEY JUST DID WHAT WAS COMMON BUSINESS PRACTICE AT THE
18 TIME SO THERE WAS NO ILLEGAL DUMPING THAT WAS GOING ON.
19 THERE ARE COMPANIES AND THERE ARE PARTIES OUT THERE WHO
20 ARE RESPONSIBLE FOR THE CONTAMINATION OF IT.
21 JERRY COLLINS: IS THIS GENTLEMAN ONE OF THEM?
22 MARK DAVIS: HE IS THE CURRENT OWNER OF THE
23 PROPERTY UNDER THE SUPERFUND LAW
24 LARRY CRUMP: YOU KNOW IT DOESN'T REALLY MATTER IF
25 MR. RUTLEDGE IS RESPONSIBLE FOR THIS OR NOT. WE'RE NOT
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HERE TONIGHT OVER WHO IS TO ARGUE WHO IS RESPONSIBLE.
WE'RE TRYING TO CLEAN IT UP. THIRTY YEARS AGO E2 HAD NO
KNOWLEDGE OF WHAT COULD BECOME OF CHEMICALS BEING DUMPED
IN THE GROUND. THIS IS 1994. LET'S KEEP THE SUBJECT IN
1994.
JERRY COLLINS: WHY IS THIS MAN HERE? WHY IS THIS
MAN HERE?
LARRY CRUMP: BECAUSE HE CARES EVIDENTLY. I HAVE
THE GREATEST RESPECT AND ADMIRATION FOR HIM BEING HERE
TONIGHT.
JERRY COLLINS: HE'S JUST PAINTING A PRETTY PICTURE;
FOR EVERYBODY.
LARRY CRUMP: WELL, I DON'T THINK HE'S THAT WAY.
BERNIE HAYES: WELL GENTLEMEN, THANKS. THOSE
COMMENTS ARE WELL TAKEw ON BOTH SIDES SO LET'S NOT FALL
INTO A DEBATING SOCIETY HERE.
SANDY MYERS: WE CERTAINLY DON'T WANT TO HAVE A
DEBATE BETWEEN THE DIFFERENT - - - IF THERE ARE NO CTVFP
QUESTIONS, THEN THIS MEETING IS ADJOURNED. I APPRECIATE
YOUR ATTENDANCE AND YOUR INTEREST.
WHEREUPON, THE MEETING WAS ADJOURNED- AT 8:50 ?.-.
KATHY STANFORD, CVR-CM
COURT REPORTER
(RECORDED TAPES RETAINED FOR FIFTEEN DAYS FROM DATE OF
CERTIFICATION UNLESS OTHERWISE REQUESTED)
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5 9 0084
APPENDIX B
STATE OF SOUTH CAROLINA CONCURRENCE LETTER
RUTLEOGE PROPERTY SUPERFUND SITE
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DHEC
South Carolina CommiMfcner. Douglas E. Bryant
Board: Richard E. Jabbour, DOS. Chairman William E. Applegate, III.
Robert J. Stripling. Jr.. Vice Chairman John H. Burriss
Sandra J. Molander, Secretary Tony Graham. Jr, MD
Department ol Health and Environmental Control john a paje^ MD
2600 Bull Street, Columbia, SC 29201 Promoting Health, Protecting the Environment
June 14, 1994
John H. Hankinson, Jr.
Regional Administrator
U.S. EPA, Region IV
345 Courtland Street
Atlanta, GA 30365
RE: Rutledge Property - Record of Decision
Dear Mr. Hankinson:
The Department has reviewed the revised Record of Decision (ROD)
dated June 2, 1994 for the Rutledge Property site and concurs with
the ROD. In concurring with this ROD, the South Carolina Department
of Health and Environmental Control (SCDHEC) does not waive any
right or authority it may have under federal or state law. SCDHEC
reserves any right and 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
ar^e 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; a'nd
(2) the implementation of the remedial alternative selected in the
ROD is no longer protective of public health and the environment.
The State concurs with the selected groundwater remediation
alternative of extraction and direct discharge to the local POTW.
The State also concurs with the additional investigative work to be
completed during the Remedial Design phase. This includes:
determining the relationship between the contamination detected in
the private wells and the contamination detected in the on-site
monitoring wells, collecting additional background surface soil
samples to confirm that the variance in manganese is consistent
with the environmental setting, and collecting additional surface
water and sediment samples to determine if the selected background
sample is representative of true background conditions.
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•age 2
4r. John H. Hankinson, Jr.
Xutledge Property - ROD
Tune 14, 1994
State concurrence on this remedial alternative is based on the
alternative meeting all applicable clean-up criteria. Concurrence
Is also contingent upon the results of the additional investigative
fork to be completed during the Remedial Design phase. Depending on
;he results of the investigative work, an Explanation of
Significant Differences (ESD) and/or ROD Amendment may be required.
to ESD and/or ROD Amendment would require State concurrence.
Sincerely,
R. Lewis Shaw, P.E.
Deputy Commissioner
Environmental Quality Control
Hartsill Truesdale
Keith Lindler
Gary Stewart
Richard Haynes
Billy Britton
Al Williams, Catawba EQC
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