PB95-964013
EPA/ROD/R04-95/223
April 1995
EPA Superfund
Record of Decision:
Palmetto Recycling, Inc.
(O.U. 1), Columbia, SC
3/30/1995
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RECORD OF DECISION
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
March 1995
PALMETTO RECYCLING SUPERFUND SITE
COLUMBIA, RICBLAND COUNTY
SOUTH CAROLINA
PREPARED BY:
U. S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA
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"" -
DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Palmetto Recycling Site
Columbia, Richland County, South Carolina
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Palmetto Recycling Superfund Site (the Site), located in
Columbia, Richland County, South Carolina, which was chosen in
accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA), as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA), 42
U.S.C. ~~ 9601 et seg., and, to the extent practicable, the
National Oil and Hazardous Substances Contingency Plan (NCP), 40
C.F.R. Part 300 et seg. This decision is based on the
administrative record file for this Site.
The State of South Carolina concurs with the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
Site, if not addressed by implementing the response action selected
in this Record of Decision (ROD), may present an inuninent and
substantial endangerment to public health, welfare, or the
environment.
DESCRIPTION OF THE SELECTED REMEDY
This remedial action addresses surface soil contamination.
The major components of the selected remedy include:
SURFACE SOIL - SOURCE CONTROL
.
Excavation of contaminated surface soil that exceeds the
remediation level, with verification sampling;
.
The soil will be Toxicity Characteristic Leaching
Procedure (TCLP) tested. If the soil exceeds the Land
Disposal Restriction (LDR) of 5 ppm for Pb using the TCLP
test, then the soil will be transported to a RCRA
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Subtitle C Facility where it will be pretreated in order
to comply with the LDRs. If soil does not exceed the 5
ppm LDR, then the soil will be transported to a Subtitle
D solid waste landfill and disposed of directly without
pretreatment.
.
The excavated area shall be backfilled with clean soil,
properly recompacted, and the land regraded to the
natural slope. A vegetative cover will be established to
minimize undue surface water runoff and minimize erosion.
SITE MONITORING
.
Groundwater monitoring will be conducted on an annual
basis for at least five years to evaluate the site
progress. .
ADDITIONAL SAMPLING
Based on public health concerns generated during the public
comment period, EPA will obtain additional confirmation
samples from the adjacent residential yards and from the dirt
road that borders the site to the east to confirm the absence
of soil contamination through offsite migration.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that are
legally applicable or relevant and appropriate to the remedial
action, and is cost effective. This remedy utilizes permanent
solutions and al ternati ve treatment technology to the maximum
extent practicable for this Site. However, because treatment of the
contaminated soil was not found to be economical, the soil
remediation component of this remedy does not satisfy the statutory
preference for treatment as a principal element.
Since selection of this remedy will result in contaminated
groundwater remaining on-site above health-based levels, but below
Maximum Contaminant Levels, the Environmental Protection Agency
(EPA) will conduct a review within five years after commencement of
remedial action to ensure that the remedy continues to provide
adequate protection of human health and the environment.
~~.~
Richard D. Green
Associate Director
Office of Superfund and Emergency Response
2JJ ~~ '\S
Date
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SECTION
1.0
2.0
3.0
4.0
5.0
6.0
7.0
8.0
9.0
10.0
11.0
TABLE OF CONTENTS
iv
PAGE
SITE LOCATION AND DESCRIPTION ..... ..... ............ .......1
SITE HISTORY AND ENFORCEMENT ACTIVITIES ...................1
HIGHLIGHTS OF COMMUNITY PARTICIPATION .....................5
SCOPE AND ROLE OF THIS ACTION WITHIN SITE STRATEGY ........5
SUMMARY OF SITE CHARACTERISTICS ...........................5
5 .1 Meteorology......................................... 6
5.2 Geologic and Hydrogeologic Setting ..................6
5.2.1 Geology/Soils................................ 6
5.2.2 Site-Specific Geology. """ ....., """" ....7
5 . 2 . 3 Hydrogeology................................ .10
5 . 2 . 4 Ecological Screening......................... 13
5.3 Nature and Extent of Contamination .................14
SUMMARY OF SITE RISKS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .23
6.1 Contaminants of Concern ............................23
6 .2 Exposure Assessment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .24
6.3 Toxicity Assessment of Contaminants ..... ...........25
6.4 Risk Characterization ............ ..... .............26
DESCRIPTION OF SOIL REMEDIAL ALTERNATIVES....." ..........30
7 .1 No Action. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .34
7.2 Institutional Controls and Access Restrictions .....35
7.3 Excavation and Offsite Disposal... ........ ..........36
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES. . . . . . . . . .36
8.1 Surface Soil Remediation Alternatives.. .......... ..37
8.1.1 Threshold Criteria ... """""'" ..........37
8.1.2 Primary Balancing Criteria ....... ...........37
8.1.3 Modifying Criteria ... "'" ...... """" ....38
THE SELECTED REMEDY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39
9.1 Surface Soil Remediation ......... ...... """" ....39
9 .1.1 Description................................. 39
9.1.2 Applicable or Relevant and Appropriate
Requirements (ARARs) """" ...... "" ... ....41
9.1.3 Performance Standards """ ..... .......... ..44
STATUTORY DETERMINATIONS .... ...., """ ..... ........ ....44
DOCUMENTATION OF SIGNIFICANT CHANGES.... ....... ........ ..44
REFERENCES
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LIST OF APPENDICES
v
APPENDICES
APPENDIX A
APPENDIX B
RESPONSIVENESS SUMMARY
STATE LETTER OF CONCURRENCE
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. ~
I
LIST OF FIGURES
vi
FIGURE
PAGE
1
2
3
4
5
6
7
8
9
10
Site Location Map. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2
CUrrent Site Features Map.................... .........3
Locations of Soil Borings..... .......... ..............8
Geologic Cross Section B-B' ....... ..... ...... .........9
Locations of Groundwater Monitoring Wells.... ........11
Surface Soil Sample Locations..... ..... ...... .... ....15
Subsurface Soil Sample Locations.... ......... .... ....17
Monitoring Well Locations............................ 20
Surface Water/ Sediment Sample Locations..... ........22
Approximate Areal Extent of Lead Contamination
above Remediation Levels in Surface soil..... ........32
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LIST OF TABLES
vii
TABLE
PAGE
1
Rational for Surface Soil Sample locations ............... .16
Rational for Soil Boring Sample Locations............ ..... .18
2
3
Rational for the Selection of Monitor Well Locations.......21
4
Remedial Action Objectives for Surface Soil..... ...... .... .33
Development of Remedial Action Alternatives
For Surface Soil. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .33
5
6
Potential Chemical-Specific ARARS........ ...... ........... .46
Potential Location-Specific ARARS. . . . . . . . . . . . . . . . . . . . . . . . . .48
7
8
Potential Action-Specific ARARS. . . . . . . . . . . . . . . . . . . . . . . . . . . .49
OtherRequirements. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .51
9
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. DECISION SUMMARY
PALMETTO RECYCLING SUPERFUND SITE
COLUMBIA, RICHLAND COUNTY, SOUTH CAROLINA
1.0
SITE LOCATION AND DESCRIPTION
The Palmetto Recycling Site is located about 8 miles north of
Columbia, South Carolina, in rural Richland County. The site is
positioned between U.S. Routes 321 and 21 on the north side of Koon
Store Road (State Road S-40-61). As shown in Figure 1-1, a more
precise placement of the property location is given by the
coordinates defined by the Universal Transverse Mercator Grid
System, which are north 34° 7' 25" latitude and west 81° 00' 43"
longitude (USGS, 1990). It occupies approximately 1.5 acres and is
bounded by Koon Store Road to the south, an unnamed dirt road (and
farther removed, Dry Fork Creek) to the east, an unnamed tributary
of Dry Fork Creek to the north, and a residential lot and home to
the west (see Figure 1-2) .
Important physical features of the site include a 6-ft x 30-ft
concrete walkway, an office building, a 135-ft by 170-ft asphalt
pad with two concrete pads, a frame work shed, a concrete tank
saddle, and an unnamed tributary that flows to Dry Fork Creek (see
Figure 1-2). A previously, open excavation which was filled with
water associated with abandoned truck scales was sampled during the
RI field effort and found to be.uncontamipated. The water was
pumped to the unnamed tributary and the pit was backfilled with
clean soil and graded to prevent ponding. A sparse cover of
crushed rock was applied for soil erosion control. The waste
materials in the suspected dumping areas have been removed. In
addition, five groundwater monitor wells, installed by a contractor
for the Palmetto Recycling, Inc. during a 1981 hydrogeological
study, are located onsite. Dry Fork Creek, located east of the
site, flows toward the south into the North Branch of Crane Creek.
Dry Fork Creek receives drainage from an unnamed tributary located
north of the site.
2.0
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The property was purchased in 1979 by Palmetto Recycling, Inc. for
the purpose of operating a battery recycling company. From 1979 to
1983, the facility was involved in the reclamation of lead from
batteries. It is unknown what activities occurred onsite prior to
1979. A collection sump received wastewater contaminated with
sulfuric acid from various plant 'operations. The sump consisted of
a below-grade fiberglass tank in an unlined pit. Specific
neutralization process details are unknown, but at some point ,
Palmetto Recycling started discharging wastewater of unknown
composition to the local sewer system. In addition, a former
employee reported that during operations, liquid wastes were dumped
north of the site, outside the fenced area (Tanner, 1992).
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COLUMBIA
RICHLAND COUNTY
-N-
PALMETTO
RECYCLING
COM FPC ARCS IV
SITE LOCATION MAP
COM FEDERAL PROGRAMS CORPORATION PALMETTO RECYCLING
a sutmdiary of C&mp Dresser * MoKee Inc. COLUMBIA, SOUTH CAROLINA
FIGURE NO. 1
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CURRENT SITE FEATURES MAP
PALMETTO RECYCLING
RICH LAND COUNTY, SOUTH CAROLINA
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Record of Decision
Palmetto Recycling Superfund Site
Page 4
After discharging wastewater for an unknown period of time,
Palmetto Recycling attempted to obtain a discharge permit. In 1981,
the South Carolina Department of Health and Environmental Control
(SCDHEC) denied applications by Palmetto Recycling, Inc. to operate
a hazardous waste facility and to transport hazardous wastes. After
this attempt, some waste liquids were sent offsite to an acid
recycler and some were disposed of onsite. It is not known if these
wastes were neutralized before shipment or onsite disposal. The
quantities are also unknown. Plastic battery cases and lead plates
were eventually sold to other companies as reusable materials (EPA,
1992) .
A study conducted by the SCDHEC identified elevated concentrations
of lead and iron in the groundwater samples collected next to the
sump. High levels of lead, barium, and chromium were found in
sediment from the unnamed stream that runs north of the site. The
investigation also revealed the presence of elevated concentrations
of lead in on-site soils. SCDHEC noted the presence of a five-foot
deep, unlined acid pit containing 1,800 gallons of acid waste at
the site, as well as 100 drums of caustic waste and an unstablized
pile of battery casings.
On February 11, 1983, Palmetto Recycling filed for bankruptcy and
Ryan Hovis was appointed trustee. In 1984, workers removing
equipment from the site destroyed a section of the roof covering
the on-site collection sump that collected wastewater containing
lead oxide and sulfuric acid from the wash process. As a result of
this incident, sump water percolated through soils adjacent to the
pit area. To address immediate health and environmental risks
posed by the Site, three removal actions have occurred at the site.
On April 25, 1984, 10,800 gallons of contaminated water were
collected by Bryson Industries Services and taken to Alternate
Energy Resources. On April 1984, SCDHEC. informed the bankruptcy
trustee that additional measures would be necessary to bring the
site under control. Later in 1984, approximately 100 drums
containing liquid caustic waste were removed from the site. On
October 2, 1985, SCDHEC authorized Future Fuel Development, Inc.,
to remove site soils contaminated with lead and chromium. A total
of 365 tons of soils were removed from various areas on-site and
placed in off-site landfills during 1985 and 1986.
In 1986, EPA conducted a preliminary assessment of the site. EPA
proposed the site for inclusion on the National Priorities List
(NPL) in January 1987. The Palmetto Recycling site was formally
added to the NPL in July 1987.
In 1992, EPA negotiated with parties it had identified as
Potentially Responsible Parties (PRPs) for the site to conduct the
RIfFS. An agreement was not reached between EPA and the parties.
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Record of Decision
Palmetto Recycling Superfund Site
, Page 5
Therefore, EPA conducted RI Field activities at the Site from April
1993 through June 1993 and from March 1994 through July 1994.
3.0
HIGHLIGHTS OF COMHONITY PARTICIPATION
An information repository, which includes the Administrative
Record, was established at the Northeast Regional Library in 1994,
and is available to the public at both the information repository
maintained at the Northeast Regional Library, 7490 Parklane Road,
Columbia, South Carolina and at the EPA, Region IV Library, 345
Courtland Street, Atlanta, Georgia, 30365. The notice of
availability of these documents was published in "THE STATE" on
November 21,1994.
A public comment period for the proposed plan was held from
November 22, 1994 to January 23, 1995. A notice of an extension of
the public comment period was published in "THE STATE" on December
18, 1994. In addition, a notice of the extension was mailed to all
parties on the Site mailing list. A public meeting was held on
December 6, 1994, where representatives from EPA answered questions
regarding the Site and the remedial alternatives under
consideration, which were discussed in the proposed plan.
EPA received oral comments during the December 6, 1994, public
meeting, and written comments during the 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
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. ~ 9617, have been met for this
Site.
4.0
SCOPE AND ROLE OF THIS ACTION WITHIN SITE STRATEGY
The purpose of the remedial alternative selected in this ROD is to
reduce current and potential future risks at this Site. There is
an unacceptable current risk present at the Site. The soil
remedial action will remove current and potential future risks
posed by the contaminated surface soil. 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
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Record of Decision
Palmetto Recycling Superfund Site
Page 6
the environment posed by the Site. A supporting RI objective was
to characterize the Site-specific geology and hydrogeology. A
total of eighty-six (86) soil samples, twelve (12) groundwater
samples, three (3) surface water samples, and six (6) sediment
samples were collected during the RI. The main portion of the RI
was conducted from April 1993 to June 1993, March 1994, June 1994
and July 1994.
5.1
He teoro1OQ'V
Richland County is hot and generally humid in the summer because of
moist air from the Atlantic Ocean. Winter is moderately cold but
short, because cold waves from the north are impeded by the
mountains to the northwest of the county. During the summer, the
average daily temperature is 800 fahrenheit (F) and in the winter
it is 48°F. The day-to-day weather is controlled by the movement
of pressure systems across the country, although during the summer
there are relatively few complete exchanges of air masses, and
tropical maritime air masses persist for extended periods. During
most of the year, prevailing winds in the area are generally out of
the southwest. In the late summer and fall, prevailing winds are
out of the northeast.
Precipitation is evenly distributed throughout the year. Average
annual rainfall is approximately 47 inches, most of which falls
between April and September. The average relative humidity in mid-
afternoon is about 55 percent. Humidity is higher at night and the
average at dawn is about 90 percent. 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 (USDA, 1978).
5.2
GeoloQic and HvdroQeoloQic Setting
5.2.1
Geoloov/Soils
The site is situated in the Piedmont Physiographic Province and the
Carolina Slate Belt Geologic Province of South Carolina. The
Carolina Slate Belt is part of an extensive group of metamorphosed,
volcanic, and sedimentary rocks occurring along the southeast edge
of the Piedmont Province from Georgia to virginia. In the vicinity
of the site, these rocks consist of meta-argillite, phyllite,
volcanic tuff, and volcanic flows of the Asbill Pond Formation.
Most of these rocks are mantled by residual soil that is developed
through in-situ weathering of fractured or jointed metamorphic
rocks (Pooser and Johnson, 1961).
The site area is underlain by unconsolidated residual soil derived
directly from the in-situ weathering of meta-argillite/phyllite/
tuff rocks of the Carolina Slate Belt. The strike of bedding in
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Record of Decision
Palmetto Recycling Superfund Site
Page 7
the vicinity of the site is approximately north-south and dip is
toward the west. The original sediments comprising the meta-
argillite were muds and silts. Tuffaceous material and limestone
are important constituents in some meta-argillite beds. The
phyllite is derived from the same type of sedimentary rocks as the
meta-argillite and is considered to be the higher rank metamorphic
equivalent of meta-argillite. The volcanic rocks are classified as
lithic tuffs and rhyolitic/andesitic flows. Basaltic dikes and
aplitic intrusives are also fairly common.
5.2.2
Site-Specific Geoloqy
The initial assessment of geologic conditions at the facility was
conducted by SCDHEC (Knox, 1983). The assessment included the
interpretation of geophysical data and the drilling of soil borings
near an acid sump on the eastern side of the work shed. These data
indicated that the lithology at the site was primarily weathered
argillite to a depth of 60 feet. Sandy clay topsoil was also
observed in the vicinity of the soil borings.
Site specific characterization of the geologic strata underlying
the facility was developed during this RI with subsurface data
collected from ten soil borings. The location of each boring is
shown on Figure 3. Methods used to obtain soil .samples from the
soil borings included split-spoon sampling and rock coring.
Lithologic evaluation of split-spoon and core samples was conducted
with field descriptions and geotechnical tests and was limited to
the upper 84 feet of materials underlying the site.
Lithologic evaluation of split-spoon samples showed soils and
saprolite were composed of varying combinations of gravel, sand,
silt, and clay (see Figure 4). The dominant lithologies were clay
and silt, the primary constituents of argillite. However, due to
the interlayered nature of these sediments, zones of silty sand,
gravel, and clay can predominate locally. Sands were typically
fine-grained. Soil colors included red, yellow, gray, brown, and
green.
Petrologic evaluation of the core samples showed the rocks
underlying the unconsolidated soil and saprolite material was
primarily argillite. The argillite was generally gray-green to tan
and was highly fractured and slightly contorted. Secondary
mineralization along fractures was also common. Fractures
typically occurred at angles greater than 45 degrees. . Other rocks
identified in core samples include graywacke and volcanic tuff.
The lithologies which occur at the site include a soil layer
comprised of unconsolidated to semi-consolidated soils and
saprolite overlying a complex of sedimentary and/or volcanic rocks.
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LOCATIONS OF SOIL BORINGS
PALMETTO RECYCLING
COLUMBIA, SOUTH CAROLINA
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COM FEDERAL PROGRAMS CORPORATION
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COM FPC ARCS IV
GEOLOGIC CROSS SECTION A-Af
PALMETTO RECYCLING
COLUMBIA, SOUTH CAROLINA
FIGURE NO. 4
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Record of Decision
Palmetto Recycling Superfund Site
Page 10
The soil/saprolite layer consists primarily of residual materials
derived from the in-situ chemical weathering of the underlying
rock. Locally within stream basins near the site, residual soil
and/or rock have been chemically and mechanically weathered to form
alluvial deposits. Alluvial deposits generally overlie saprolite
along these surface water features.
5.2.3
Bvdroc:reo1 oc:rv
The initial assessment of hydrogeological conditions at the site
was conducted by SCOHEC. Groundwater data collected during this
assessment consisted of water table measurements collected from
five groundwater monitoring wells. Results of the measurements
indicated the depth to groundwater was 5 to 11 feet below ground
surface and the hydraulic gradient was 0.0265. Estimated water
table contours constructed with these data indicated the direction
of groundwater movement was southeast toward Dry Fork Creek.
Twelve groundwater monitoring wells were installed during this RI
to evaluate the hydraulic characteristics of the aquifer system at
the site. These were installed in clusters and each cluster was
composed of one shallow, one intermediate, and one deep well. One
cluster was installed at four different locations. The location of
each monitoring well is shown on Figure 5.
The shallow wells were completed in the shallow water-bearing zone,
the intermediate wells were completed in the intermediate water-
bearing zone, and the deep wells were completed in the deep water-
bearing zone. These water-bearing zones are considered to be
situated within a single water table aquifer. The aquifer is
comprised of a layer of saprolite overlying a unit of fractured
bedrock. The saprolite contains the shallow and intermediate
water-bearing zones; the deep water-bearing zone is located in the
fractured bedrock.
The horizontal movement of groundwater through the aquifer system
was evaluated using hydraulic conductivity values determined from
slug tests in each well. The results of these in-situ hydraulic
conductivity tests indicate that the average horizontal hydraulic
conductivities of the soil and rock were 0.053 and 0.48 feet per
day (ft/day), respectively.
The vertical movement of groundwater through the aquifer system and
hydraulic head differences at well clusters were evaluated by
measuring the hydraulic conductivity of samples collected in Shelby
tubes and sent to a laboratory during the subsurface investigation.
The results of the vertical hydraulic conductivity tests indicate
that values ranged from 0.001 to 0.167 ft/day and averaged 0.004
ft/day. Comparison of the hydraulic conductivity values shows that
-------
FIGURE NO.5
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-------
Record of Decision
Palmetto Recycling Superfund Site
Page 12
the horizontal hydraulic conductivity value for the shallow water
bearing zone exceeds the average vertical hydraulic conductivity by'
one order of magnitude, suggesting anisotropic conditions.
Groundwater is present in two distinct hydrostratigraphic units at
the facility. The uppermost unit consists of unconsolidated
sediments including clay and silt. These sediments are underlain by
a more indurated unit of argillite, a rock composed mainly of clay
minerals. Water in the upper unit is transmitted through effective
pore space in the unconsolidated sediments. Fractures and joints
serve as transmission pathways for groundwater present in the rock
unit. There are at least two water-bearing zones in the rock unit,
Based on lithological, hydrogeological, and hydraulic data
collected from the site, the shallow, intermediate, and deep water
bearing zones are part of the same aquifer. The aquifer includes
the upper 100 feet of bedrock and the overlying sediments
comprising the overburden. The upper 100 feet of bedrock was
included because fractures are generally concentrated in this
interval. The system is unconfined and exists under water-table
condi tions. Under these conditions, the water table is in
equilibrium with atmospheric pressure and is not confined above by
a lithologic unit of lower permeability.
The hydraulic gradient in the soil portion of the aquifer, based on
the June 2, 1993 water level data, varied from 0.010 to 0.053 feet
per foot (ft/ft) and averaged 0.033 ft/ft. Using an average
horizontal hydraulic conductivity of 0.053 ft/day, an average
hydraulic gradient of 0.033 ft/ft, and an average effective
porosity of 0.2 which is typical for silty materials (Dawson and
Istok, 1991), the average horizontal groundwater seepage velocity
for the soil portion of the aquifer is 0.009 ft/day.
The hydraulic gradient in the rock portion of the aquifer, based on
the June 2, 1993 water levels, varied from 0.037 to 0.041 ft/ft and
averaged 0.039 ft/ft. Using an average horizontal hydraulic
conductivity of 0.48 ft/day, an average hydraulic gradient of 0.039
ft/ft, and an average effective porosity of 0.1 which is typical
for fractured rock (Dawson and Istok, 1991), the average horizontal
groundwater seepage velocity for the rock portion of the aquifer is
0.187 ft/day.
In 14 years (the time since the beginning of operations at the
Palmetto Recycling facility), average contaminant migration would
thus be expected to be on the order of 50 feet in the soil portion
of the aquifer and 1000 feet in the rock portion of the aquifer.
The travel distances are based on the assumptions that contaminants
move as groundwater moves and that contaminants are somehow
introduced into each of these aquifer zones at the beginning of
-------
Record of Decision
Palmetto Recycling Superfund Site
Page 13
site operations. Actual contaminant movement, however, is expected
to be much less due to the contaminant retardation properties of
the aquifer system and the tendency for contaminants to move
vertically through the unsaturated zone before entering the
aquifer.
Hydraulic gradients in the shallow and deep water-bearing zones
show that the general direction of groundwater movement is toward
local surface waters. The actual direction of groundwater movement
in the deep water-bearing zone at any given location may vary from
the direction shown on the potentiometric surface maps due to the
anisotropic and 'heterogenous nature of the fractured argillite.
Groundwater movement in this unit is controlled by the geometry,
orientation, and interconnection of secondary porosity features
such as joints, fractures, faults, and bedding planes.
5.2.4
Ecoloaical Screeninq
An endangered and threatened species and critical habitat
screening was conducted to identify listed species that are found
in the Palmetto Recycling Site vicinity. State and federal
agencies were contacted concerning information available on the
wildlife and natural resources i~ and around the site. The U.S.
Fish and Wildlife Service and the South Carolina Wildlife & Marine
Resources Department provided information concerning the known
state and federally listed species of concern in Richland County,
South Carolina.
The South Carolina Wildlife & Marine Resources Department provided
a detailed list with accompanying maps of all known species in the
Richland County area. The list is based on reported sightings
within the appropriate geographic area and not based on a
systematic ecological survey of the entire county or of the site.
There are several federally listed endangered species whose
distribution may include Richland County. Several state threatened
species or species of concern may also live near the site. Two
animal species whose status is undetermined, the redlip shiner
(Notropis chiliticus) and the blacknose dace (Rhinichthys
atratulus) , are located along the surface water pathway
approximately 6 stream miles from the Palmetto Recycling property.
Due to the low levels of contamination identified along North
Bran,ch Crane Creek and the distance to the location of these
species from the site in stream miles, it is very unlikely that
these species of concern are being affected by the site
contaminants.
Based on the information collected from state and federal agencies,
the Palmetto Recycling Site does not pose a threat to any state or
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Record of Decision
Palmetto Recycling Superfund Site
Page 14
federally listed species. The site, however, may affect the
habitats and migratory paths of some species because of its rural
location and its close proximity to the North Branch Crane Creek,
but information gathered reveals no listed species are near the
site.
5.3
Nature and Extent of Contamination
Environmental
follows:
contamination at the Site
can be surmnarized as
Surface Soil Samplinq - Surface soil samples were collected from 24
locations as part of the RI field investigation - 7 by CDM Federal
and 17 by EPA (see Figure 6). Twenty-three of these samples were
collected to confirm or deny impacts reported by the previous
investigations. One surface soil sample was collected from an
offsite location to establish background conditions for the site.
All 7 samples collected by CDM Federal were sent to a Contract
Laboratory Program (CLP) laboratory for full Target Analyte List
(TAL) parameter analyses. In addition, 1 sample (the background
sample) collected by CDM Federal was also analyzed for full Target
Compound List (TCL) p~rameters. All 17 samples collected by EPA
were sent to the EPA Environmental Services Division (ESD)
laboratory for lead analysis. In addition, 9 of the 17 EPA samples
were also analyzed for all other TAL parameters except cyanide, and
one of the samples was also analyzed for all TCL parameters. Table
1 surmnarizes the rationale for the selection of surface soil
sampling locations.
One contaminant of concern, lead was detected above the background
concentration of 15.1 ppm in 78% of the non-background surface soil
samples. Levels of the lead ranged from 6.3 ppm to 6400 ppm. One
. volatile organic .1,2 -Dichloroethane was detected at a level of
0.0076 ppm (7 ppm is the screening level). Because 1,2-dichloro-
ethane was detected at a very low concentration, volatile organics
do not appear to significantly impact the surface soil at the site.
Subsurface Soil Sampling - A total of 62 subsurface soil samples
were collected from 10 locations during the RI field effort (see
Figure 7). Samples were collected from borings completed in and
adjacent to known contaminant source areas and potential onsite
source areas to refine estimated pre-RI source area boundaries.
Twelve of these were obtained from a soil boring drilled in an
offsite location to establish background conditions. All
subsurface soil samples were sent to a CLP laboratory and analyzed
for TAL parameters. In addition, approximately 25% of the samples
were subjected to TCL analysis. Table 2 summarizes the rationale
for the selection of soil boring sampling locations.
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LOCATIONS
PALMETTO RECYCLING
COLUMBIA, SOUTH CAROLINA
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TABLB 1
RATIONALB POR SURPACB SOIL SAMPLB LOCATIONS
PALMETTO RECYCLING SITE
COLUMBIA, SOUTH CAROLINA
. .
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SS-Ol
SS-02
SS-03
SS - 04
SS-05
SS-06
SS-07
SS-08
D1
D2
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PR-06
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Offsite near northwestern corner of Facility/characterize background conditions
Drainage ditch south of site in area of probable surface flow/confirm impacts reported by
previous investigation
Drainage ditch south of site in area of probable surface flow/confirm impacts reported by
previous investigation
Drainage ditch south of site in area of probable surface flow/confirm impacts reported by
previous investigation
West of work area/previous storage or disposal area where impacts have been reported by
previous investigation
North of facility in proximity to drainage feature discharging to Dry Fork Creek/former
employee reported waste dumping in this area
Northeastern portion of facility/previous truck trailer parking area
East of the lagoon and waste stockpile area where processing operations formerly existed
Northwestern portion of site to assess any impacts from past operations
West of work area/previous storage or disposal area where impacts have been reported by
previous investigation
South of work area/previous storage or disposal area to assess impacts from past operations
South of work area/previous storage or disposal area to assess impacts from past operations
South of work area/previous storage or disposal area to assess impacts from past operations
South of work area/previous storage or disposal area to assess impacts from past operations
Drainage ditch south of site in area of probable surface flow/confirm impacts reported by
previous investigation. Also to confirm results of SS-04.
Drainage ditch south of site in area of probable surface flow/confirm impacts reported by
previous investigation.
Under asphalt of previous work area to assess impacts from past operations
Under asphalt of previous work area to assess impacts from past operations
Under asphalt of previous work area to assess impacts from past operations
Under asphalt of previous work area to assess impacts from past operations
Northeastern portion of facility/previous truck trailer parking area
Northeastern portion of facility/previous truck trailer parking area
West of work area/previous storage or disposal area where impacts have been reported by
previous investigation
South of work area/previous storage or disposal area to assess impacts from past operations
16
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PALMETTO RECYCLING
COLUMBIA, SOUTH CAROLINA
50
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TABLE 2
RATIONALE FOR SOIL BORING SAMPLE LOCATIONS
PALMETTO RECYCLING SITE
COLUMBIA, SOUTH CAROLINA
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BH-Ol Near northwestern corner of property/characterize
background conditions and describe geology
BH- 02 Inside property boundary on east side of site/confirm
or deny impacts near existing waste pile
BH- 03 Outside of property boundary east of site/confirm or
deny impacts downgradient to site
BH-04 Inside property boundary northeast of former office
building/confirm or deny presence of impacts northeast
of former office building
BH-05 Northeastern corner of facility/confirm or deny
presence of impacts south of suspected dumping area
BH-06 Inside property boundary in northeastern quadrant of
site/confirm or deny presence of impacts northwest of
waste pile and south of suspected dumping area
BH- 07 Inside property boundary in central portion of
site/confirm or deny presence of impacts west of
asphalt pad and former work area; north-northwest of
drum storage area
BH-08 Outside property boundary due east of asphalt pad and
former work area/confirm or deny presence of impacts
adjacent to waste pile and lagoon area
BH-09 Inside property boundary southeast of former office
building/confirm or deny presence of impacts west of
asphalt pad and former work area
BH-IO Inside property boundary immediately south of asphalt
pad and former work area/confirm or deny presence of
impacts documented by a previous assessment
18
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Record of Decision
Palmetto Recycling Superfund Site
Page 19
Subsurface soil analyses indicate that two volatile organics
(toluene and acetone) and inorganic chemicals are present at levels
above background concentrations. Because acetone is normally a
laboratory contaminant and the concentration of toluene was very
low, volatile organics do not appear to have significantly impacted
subsurface soil at the site. Seventeen inorganics were detected
above background concentrations. The most frequently detected
constituents above background concentrations and those inorganics
thought to be of significance are arsenic, chromium, lead, and
vanadium; It appears that metals are concentrated in the
southeastern portion of the site. The maximum vertical extent of
inorganic constituents detected above background concentrations
(lead and arsenic) was at approximately 60 feet. Chromium and
vanadium were detected as deep as 35 feet. The thickest interval
which showed impact was estimated from 10 to 63 feet. Vertical
distribution of the metal constituents in each borehole was
sporadic and did not follow any trends.
Groundwater Contamination - A total of 12 new monitor wells (4
shallow, 4 intermediate, and 4 deep) were installed as part of the
field effort (see Figure 8). Groundwater samples were collected
from each of the new wells and shipped to a CLP laboratory and
analyzed for full TCL/TAL parameters. Table 3 summarizes the
rationale for the selection of monitor" well locations.
Three contaminants of concern, chloroform, arsenic, and chromium
were detected above the background concentration in" the
groundwater. Chloroform was detected in only one sample at 6 ppb,
which was below the Maximum Contaminant Level (MCL) of 100 ppb.
Levels of the arsenic were detected in two samples and ranged from
19 ppb to 38 ppb, which were below the MCL of 50 ppb. Levels of
chromium were detected in six samples and ranged from 3 ppb to 25
ppb, with two samples being detected above the background
concentration of 5 ppb, and all samples being detected below the
MCL of 100 ppb.
Surface Water and Sediment Sampling - A total of 3 surface water
and 6 sediment samples were collected from onsite and offsite
locations during the RI to evaluate surface water contaminant
migration pathways and the extent of surface water contamination
(see Figure 9). All surface water and sediment samples were sent
to a CLP laboratory and analyzed for TAL parameters. In addition,
2 of the samples were subjected to TCL analysis.
There were no contaminants of potential concern identif ied for
surface water and therefore this medium was dropped from the risk
analysis. However, dieldrin was detected in the truck scale
excavation pit surface water sample. The concentration measured
was very low and therefore, while some potential impact is
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MONITOR WELL LOCATIONS
PALMETTO RECYCLING
COLUMBIA, SOUTH CAROLINA
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PALMETTO RECYCLING
COLUMBIA, SOUTH CAROLINA
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TABLE 3
RATIONALE FOR THE SELECTION OF MONITOR WELL LOCATIONS
PALMETTO RECYCLING SITE
COLOMBIA, SOUTH CAROLINA
I "~l~ID lie.c . .
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MW-OlI
MW-OID
MW-02S
MW-02I
MW-02D
MW-03S
MW-03I
MW-03D
MW-04S
MW-04I
MW-04D
.'
Northwestern corner of facility/characterize background
conditions.
Inside property boundary on east side of site/confirm or deny
impacts in area adjacent to waste pile and lagoon.
Southeast of Main Recycling facility outside of property
boundary/ confirm or deny impacts in area downgradient of Main
Recycling facility.
South-southeast of Main Recycling facility outside property
boundary/ confirm or deny impacts in area downgradient of Main
Recycling facility.
MW - Monitor well
S - Shallow
I - Intermediate
D - Deep
indicated by the presence of this one pesticide, it appears that
contami-nation has not significantly impacted surface water. None
of the inorganics that were detected in the truck scale excavation
pit were at significant concentrations compared to Federal Ambient
Water Quality Standards. Six inorganics were detected in the one
stream surface water sample collected downgradient of the site.
However, none of these inorganics were detected above background
concentrations. Sediment analyses indicate that inorganic chemicals
are present at levels above background. It appears that the
constituents which were detected above background are concentrated
in the portions of the stream system situated between the
background location and downgradient location, suggesting that the
downstream extent of impacts has been successfully estimated.
Nickel and vanadium appear to be the most widespread constituents
detected above background. Consequently, the contaminants have not
significantly impacted the sediment at the site.
The areal extent of constituents in soil, surface water, sediment,
and groundwater was estimated. Future migration patterns of
constituents at land surface and in the soil and rock units of. the
underlying crystalline rock aquifer system were evaluated.
22
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Record of Decision
Palmetto Recycling Superfund Site
Page 23
Ecological Screening - An endangered and threatened species and
critical habitat screening was performed to identify listed species
within the site area. The screening was performed by contacting
local, state and federal agencies concerning wildlife and natural
resources identified in Richland County. The data from these
agencies were collected, reviewed and summarized as part of the
field effort.
The Ecological Assessment concluded that contaminants of concern
identified in the surface water and sediment of waterbodies located
in the Palmetto Recycling site area show a slight potential for
risk to aquatic organisms. The potential risks to terrestrial
receptors are expected to be low due to the limited size and
quality of the terrestrial habitat provided by the site.
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
media that need to be addressed by the remedial action. It serves
as an indication of the potential 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. Currently,
there is no one living on the Site. However, approximately 300
persons reside within a one-mile radius of the Site. There are
potable water supply wells within one mile of the Site, however,
there is also municipal water available. Future land use of the
area including the site will likely remain residential, with the
potential for future resident use of groundwater as a potable water
source.
6.1
Contaminants of Concern
Data collected during the RIwere 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.
-------
Record of Decision
Palmetto Recycling Superfund Site
Page 24
.
If an inorganic compound or element, it was detected at
low concentrations, had very low toxicity, and was judged
to be naturally occurring.
.
The data included analytical resul ts flagged as
(presumptive evidence) or "R" (not usable) .
"N"
The results of the Baseline Risk Assessment concluded that the only
media of concern was surface soil, and that the only contaminant of
concern was Lead. Levels of Lead ranged from 6.3 ppm to 6400 ppm.
For the contaminant of potential concern, an exposure point
concentration was determined in the Baseline Risk Assessment. The
upper ninety-five percent (95%) confidence limit of the arithmetic
means 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 concentration calculated
in the Baseline Risk Assessment was 1,968 ppm.
6.2
ExDosure Assessment
The Site is located in a residential area that is expected to
remain as such, though currently there is no on-site" resident.
CUrrently, there are no workers on-site. There is a possibility of
trespassers gaining access to the site through broken areas of the
perimeter fence. This population could be exposed to surface soil
and sediments on the site. Therefore, it was assumed that a
hypothetical youth trespasser (age 7-16 years) would be potentially
exposed to the media through dermal contact with and the incidental
ingestion of contaminants in surficial soils and sediment. A
trespasser would not be exposed to groundwater in any event.
Surface water exposure was not evaluated because all contaminant
levels are below background levels.
The area surrounding the site is classified as residential, so it
is appropriate to assume that future on-site land use could also be
residential. As a result, hypothetical future residents are
assumed to be exposed to sediment, surface soil, and groundwater.
the future child (1-6) and adult exposure pathways are incidental
ingestion and dermal contact w.:ith surface soil and sediment,
ingestion of groundwater, and nonjHingestion exposure to groundwater
(e. g ., inhalation of volatiles from showering, washing clothes, and
dishwashing) .
For exposure to site groundwater by a resident, it was assumed that
the resident would ingest two (2) liters per day of groundwater for
350 days a year for a thirty (30) year period. It was assumed that
a child would be exposed for the same time period, but would only
consume 1 liter per day of water.
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Record of Decision
Palmetto Recycling Superfund Site
Page 25
For exposure to site soil by a resident, it was assumed that the
adult resident would incidentally ingest one hundred (100)
milligrams of soil per day for 350 days per year for a thirty (30)
year period. It was assumed that the child resident would ingest
two hundred (200) milligrams of soil per day for 350 days per year
for a six (6) year period.
6.3
Toxicity 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
wi th each contaminant. Human health criteria developed by EPA
(cancer slope factors and non-cancer reference doses) were
preferentially 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.
Slope factors (SF) have been developed by EPA for estimating 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 calculat~d 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) .
Reference doses (RfDs) have been developed by EPA for indicating
the potential for adverse heal th effects from exposure to the
chemicals 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 a chemical of concern ingested from contaminated
-------
Record of Decision
Palmetto Recycling Superfund Site
Page 26
drinking water) can be compared to the RfD. RfDs are derived from
human epidemiological studies or from animal bioassay data to which
uncertainty factors have been appl ied (e. g ., to account for the use
of animal data to predict effects on humans) .
Chemicals are classified regarding their carcinogenic potential
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.
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.
Chloroform, 1,2-Dichloroethane, Beryllium and lead are classified
as B2 carcinogens. Arsenic and Chromium are classified as A
carcinogens.
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 life-time as
a result of exposure to the carcinogen. Excess life-time cancer
risk is calculated from the following equation:
Risk = CDI x CSF
where:
Risk = a unitless probability (e.g. 2 x 10-5) of an
individual developing cancer,
-------
Record of Decision
Palmetto Recycling Superfund Site
Page 27
CDI = chronic daily intake averaged over seventy (70)
years (mg/kg-day), and
CSF =
compound and route-specific carcinogenic slope
factor, expressed as (mg/kg-day)-l
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 maximum estimate, an
individual has a 1 in 1,000,000 chance of developing cancer as a
result of site-related exposure to a carcinogen over a seventy (70)
year lifetime under the specific exposure conditions at a Site.
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 the estimated exposure dose to the reference dose is
called the 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 HQs for all chemical(s) 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 HQs 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:
CDI = Chronic Daily Intake (average over the exposure
period) (mg/kg-day)
RfD = reference dose (mg/kg-day) i and
CDI and RfD are expressed in the same units and represent the same
period (i.e., chronic, subchronic, or short-term).
Carcinogenic risk and noncarcinogenic Hazard Index (HI) ratios were
calculated for both the current land use scenario, with residents
near the Site, and the anticipated future land use scenario, which
is residential use. The Baseline Risk Assessment determined that
the total cancer risk (using Reasonable Maximum Exposure) for the
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current residential scenario exceeded an individual risk of 1B-6 in
sediment. The cancer risk estimates associated with exposure to
sediment are 3B-6 for arsenic and 2B-6 for beryllium. This risk
level is within the BPA acceptable risk range (lB-4 to 1B-6).
However, BPA may decide that a baseline risk level less than 1E-4
(i.e a risk between 1B-4 and 1B-6) is unacceptable to site specific
conditions and that remedial action is warranted. However, for the
site, BPA believes that remediation of sediment would not be
required for protection of human health. The total Hazard Index for
the current resident is 0.02. This hazard index is well below any
level of concern for noncarcinogens (1.0) and indicates the Site
does not pose an' unacceptable non-carcinogenic risk under the
current exposure scenario evaluated in the Baseline Risk
Assessment. Therefore there is no unacceptable current non-
carcinogenic risk at the Palmetto Recycling Site.
The Baseline Risk Assessment also determined that the total cancer
risk for the future Site residential scenario was 6B-4. The
contributing exposure pathways were groundwater ingestion and
inhalation (6B-4), surface soil dust inhalation (3B-6), and surface
soil ingestion (2B-S) and dermal contact (2B-6). The contaminants
arsenic and chloroform exceeded a risk of 1B-6 in groundwater. The
cancer risk estimates associated .with exposure to groundwater
ingestion and inhalation totals are SE-4 for arsenic and 3B-S for
chloroform. However, the contaminants arsenic and chloroform in the
groundwater at the site were below federal and/or state MCL's.
Therefore, it has been determined that groundwater does not warrant
remediation. The cancer risk estimates associated with exposure to
surface soil dust inhalation, surface soil ingestion, and dermal
contact totals are 6B-6 for arsenic and 2E-S for beryllium. This
risk level is within the EPA acceptable risk range (lB-4 to 1B-6).
However, BPA may decide that a baseline risk level less than 1E-4
(i.e a risk between 1B-4 and 1B-6) is unacceptable to site specific
conditions and that remedial action is warranted. However, for the
site, BPA believes that remediation of surface soil for the
contaminants arsenic and beryllium, would not be required for
protection of human health. Lead is being considered separately
because it does not have toxicity values. The Hazard Index for the
future Site residential scenario was 2.0 for a child and 5.0 for an
adult exposed to groundwater; both of these levels exceed the
acceptable hazard index of 1.0. However, the contaminants arsenic
and chloroform in the groundwater at the site were below federal
and/oJ; state MCL' s. Therefore, it has been determined that
groundwater does not warrant remediation. The non-carcinogenic risk
is attributable to the ingestion of the arsenic and chromium
present in the groundwater. The Hazard Index for the future Site
residential scenario was 0.1 for a child and 0.01 for an adult
exposed to surface soils; both of these Hazard Indices are below
EPA's level of concern (HI of 1.0) for noncarcinogenic toxicity.
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In addition, Lead was also identified as a contaminant of concern.
Currently there is not an EPA slope factor or reference dose for
lead. EPA believes that the available studies in animals do not
provide sufficient quantitative information for their calculation
(ATSDR, 1990). Although lead is currently classified as a B2
carcinogen, the EPA considers the noncarcinogenic neurotoxic
effects in children to be the critical toxic effect in terms of
health based environmental cleanup. The neurotoxic effects of
chronic low-level lead exposure in children may occur at blood
levels as low as 10 ug/dl.
In the absence of lead health criteria, two approaches were
considered. The first was to predict mean lead blood levels in
children using the Lead Uptake/Biokinetic Model (version O. 99d,
U.S. EPA 1994). The second approach compares on-site mean level
concentration with applicable or relevant and appropriate
requirements (ARARs).
The results of the model predicted that 10.61% of the exposed
population would have a blood lead concentration above the cutoff
of 10 ug/dl. EPA generally requires further action if greater than
5% of the exposed population is predicted to have blood lead levels
higher than the cutoff point.
Mean concentrations were calculated for the groundwater and soil
media and were compared to the relevant applicable or relevant and
appropriate requirements (ARARs). The groundwater concentration of
10 ppb, calculated as the mean concentration, was approximately 33
percent lower than the current action level of 15 ppb published by
the Office of Drinking Water of EPA. Therefore, it has been
determined that groundwater does not warrant remediation. The mean
lead concentration of the soil at the site was 528 ppm which is 32
percent greater than the current screening level of 400 ppm as per
OSWER Directive 9355.4-12. The level of 400 ppm is design to
protect children from developing lead blood levels above 10 ug/dl.
As a result of the Baseline Risk Assessment, EPA has determined
that remediation of surface soil would be required for the
protection of human health and the environment. Thus, since the
screening level of 400 ppm is designed to protect children from
developing lead blood levels above 10 ug/dl, EPA has selected the
level of 400 ppm for lead as the remediation goal for surface soil.
No substantial risk to wildlife or the environment was found to
. exist under present or future conditions.
The Baseline Risk Assessment concluded that the subsurface soils,
the surface water, and the sediments at the Site are not media of
concern. During the FS, it was determined that the groundwater was
not a media of concern. The Baseline Risk Assessment determined
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that the surface soil 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 health or the environment.
7.0
DESCRIPTION OF SOIL REMEDIAL ALTERNATIVES
The FS would normally consider a wide variety of general response
actions and technologies for remediating surface soil at the Site.
However, due to the very focused scope of the FS and the small
extent of contamination, the screening of potential remedial
actions was limited. Several previous remedial actions have been
performed at the Palmetto Recycling Site to remove contaminated
sludge, soil, and wastewater. This FS focused on remediating the
remaining "hot spots" of contamination.
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:
.
Prevent ingestion, inhalation, or dermal contact with
surface soil that contains lead concentrations in excess
of the remediation level;
.
Control migration of lead from soil to groundwater;
Prevent ingestion or inhalation of soil particulates in
the air having lead concentrations in excess of the
remediation level;
.
.
Control migration of lead from surface soil to a surface
water body (via surface water runoff) that would result
in contamination to levels greater than the Ambient Water
Quality Criteria of 3.2 ~g/l for lead;
.
Control future releases of contaminants to ensure
protection of human health and the environment; and
.
Permanently and significantly reduce the mobility,
toxicity, or volume (M!T!V) of characteristic hazardous
waste with treatment.
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The results of the RI showed that the surface soil is contaminated
with lead above the remediation level of 400 mg/kg (see Table 4) .
The soil contamination extends over an estimated area- of
approximately 29,500 square feet. The estimated depth of
contamination is one foot. Therefore, the estimated volume of
surface soil contamination is approximately 1,100 cubic yards (see
Figure 10).
Since the volume of contamination is small, the only general
response actions that were considered are no action, institutional
actions, and removal followed by offsite treatment (if required)
and disposal (at a treatment, storage, and disposal Facility).
Onsite treatment such as solidification/stabilization was not
evaluated in this FS because the estimated quantity of contaminated
soil at this site falls short of the typical cut-off mark used
within the industry to size whether a project is more cost-
effectively treated onsite versus offsite (2000 tons ~ 15%).
The most appropriate technologies applicable to the contamination
found at the Palmetto Recycling Site were chosen for each of the
general response actions. Specific process options were then
selected to represent those technologies. Remedial action
al ternati ves were formulated considering the extent of surface soil
contamination, contaminant type, contaminant concentrations, and
applicable technologies. The alternatives assessed for this site
are presented in Table 5. These alternatives were evaluated on the
basis of overall protection of human health and the environment,
long-term effectiveness, compliance with ARARs, reduction of
mobility, toxicity, or volume through treatment, short-term
effectiveness, implementability, and cost.
Three alternatives were developed. These actions include: no
further action at the site beyond monitoring the surface soil and
groundwater (Alternative 1); implementing deed restrictions and
fencing to control public access to the soils (Alternative 2); and
removing the last potential source(s) of surface soil contamination
and disposing of the soils at a properly permitted offsite facility
(Alternative 3) .
Each of the three (3) alternatives is discussed below. Alternatives
1 and 2 will not meet the remediation goal presented in Section
9.1.3 of this ROD. Alternative 3 will meet the remediation goal.
Alternative 3 represents the highest level of protectiveness and
the maximum reduction of contaminant mobility and toxicity.
Alternative 2, Limited Action, is not expected to achieve a
reduction in surface soil contaminant toxicity or volume, but will
eliminate some exposure pathways through access restrictions.
-------
LEGEND
FENCE
IREELINE
COM FEDERAL SURFACE SOIL
SAMPLE LOCATIONS
EPA SURFACE SOIL
SAMPLE LOCATIONS
EXTENT OF CONTAMINATION
0)
CD
CI>M KKDKKAI. I'KOUKAM.S COKI'OKATION
u( Cain|i Dresser * McK.'e Inc
COM FPC ARCS IV
APPROXIMATE AREAL EXTENT OF
CONTAMINATION ABOVE REMEDIATION LEVELS
PALMETTO RECYCLING
COLUMBIA, SOUTH CAROLINA
LEAD
IN SURFACE
SOIL
FIGURE NO. 10
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TABLE 4
REMEDIAL ACTION OBJECTIVE POR SURFACE
PALMETTO RECYCLING SITE
COLUMBIA, SOtr.I'B CAROLIllA
SOIL
j:!',\;!!~~~f~~~~,~rf '
't,:,~~c:~~):~:';~~':,:~,
";~t.~;ll~~
Lead
400
OSWER Directive 9355.4-12
*This level was selected for this Site based on the OSWER Directive 9355.4-12
TABLE 5
DEVELOPMENT OF REMEDIAL ACTION ALTERNATIVES FOR SURFACE SOIL
PALMETTO RECYCLING SITE
COLUMBIA, SOtr.I'B CAROLINA
.~ "'. ~ .~. . .:": . "" ~ .' ' .' '. - :
. , ',' ',:<".r';' ':;,{':~:~>Sy,~~, ;~';: "<,\',,,:-.,'-- :. ',,' ~, "
Alterna-, , ',' ,,' ',/Descr~p,tiOD.9fProc:ess.',optionl3:Blllployed',.
'tive "", ';,'; :,,;;c;;~:~},,;;p;:,.:>,'::,;:,;, '::?~':"'< ,', "::'::;;:;, ::,:<' ''', ":.,, ,
-.:"
1
No Action
Long-term soil and groundwater monitoring for
30 years
Limited Action:
Deed restrictions
Fencing
Long-term soil and groundwater monitoring for 30
years
2
3
Excavation
Offsite Disposal at either:
a) Subtitle D landfill (if TCLP proves
nonhazardous)
b) Subtitle C treatment and disposal facility (if
TCLP proves hazardous)
Short-term groundwater monitoring for 5 years
33
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Alternative 1, No Action, is the least protective alternative, in
that it would not meet ARARs or eliminate exposure pathways.
"O&M costs" refer to the costs of operating and maintaining the
treatment described in the alternative, for an assumed period of 30
years. O&M costs were calculated using a seven percent (7%)
discount rate per year.
Alternatives 1 (No Action) and 2 (Limited Action) include long-term
soil and groundwater monitoring at the Site for a period of 30
years. Alternative 3 (Excavation and Offsite Disposal) includes
verification soil sampling to insure that all soil contaminated at
concentrations exceeding the remediation goal is removed for
treatment or disposal. Additionally, all al ternati ves except
Alternative 3 include six Five Year Reviews to be conducted during
the assumed 30-year O&M period.
Alternatives 1 and 2 would not comply with the Resource
Conservation and Recovery Act (RCRA) landfill closure requirements,
in 40 CFR Part 264 and in the South Carolina Hazardous Waste
Management Regulations (SCHWMR), Reg. 61-79.264, which require
removal of contamination "to the maximum extent possible."
Alternative 3 would, assuming successful implementation, comply
with the following major applicable ARARS. Alternative 3 involves
materials handling and potential generation of particulates, and
thus, must comply with the South Carolina Ambient Air Quality
Standards (AAQS) which implement the South Carolina Pollution
Control Act, and the National Emission Standards for Hazardous Air
Pollutants (NESHAP) under the Clean Air Act. Alternative 3 could
include landfill disposal of hazardous wastes and, therefore, could
be required to comply with RCRA land disposal restrictions (LDRS,
40 CFR Part 268, SCHWMR 61-79.268) if the soils are shown to be
hazardous wastes subject to land disposal requirements (40 CFR Part
261, SCHWNR-61-79.261). Finally, U.S. Department of Transportation
(DOT), EPA (40 CFR Part 262), and SCDHEC (SCHWMR 61-79.262)
regulations governing the transportation of hazardous materials
would also apply to alternatives 3 if the soils prove to be
hazardous waste.
7.1
Alternative 1:
No Action
CERCLA requires that EPA consider a "No Action" alternative to
serve as a basis against which other alternatives can be compared.
Under this alternative, no action would be taken to remedy the
contaminated surface soil at the site and to reduce (M/T/V) waste.
Because contaminants would be left on-site under this alternative,
the No Action Alternative would involve the continued monitoring of
the soil and groundwater quality at the site. Groundwater
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monitoring would be accomplished utilizing existing monitor wells.
These wells would be sampled for lead on a quarterly basis for the
first five years and annually for a remainder of twenty-five years.
Soil monitoring would consist of surface soil sampling for the same
parameter and frequency. Public health evaluations would be
conducted every five years and would allow BPA to assess the
ongoing risks to human health and the environment posed by the
site. The evaluations would be based on the data collected from
soil and groundwater monitoring.
Capital Cost:
Annual O&M Cost:
Total Present Worth Cost:
$ 0.00
$ 68,000.00
$612,000.00
*The estimated annual O&M cost is approximately $68,000 during the
first 5 years and $17,400 thereafter.
7.2
ALTERNATIVE 2 - LIMITED ACTION
This alternative is identical to the No Action Alternative
(Alternative 1) described above except that it includes
implementation of institutional measures to control, limit, and
monitor activities onsite. The objectives of institutional actions
are to prevent prolonged exposure to contaminant concentrations,
control future development or excavation at the site, and prevent
the installation of water supply wells within the boundaries of the
site. These objectives are accomplished by monitoring soil and
groundwater at the site and limiting use and access by placing
fences and deed restrictions on all properties within potentially
contaminated areas. The effectiveness of institutional actions
depends on their continued implementation.
Soil and groundwater monitoring can be used to evaluate the
effectiveness of any remedial action in controlling releases from
the site. Fences and deed restrictions are designed to prevent
access/exposure to soil by limiting what can be done at the site.
Restrictions would be placed on the site to limit its future use.
This could be accomplished by recording in the property deeds that
potentially hazardous surface soil is located on the property and
that use restrictions have been imposed. If implemented
correctly, they provide low-cost moderate protection against direct
contact with contaminants. Deed restrictions and fences are
potential mechanisms to limit and monitor activity on the property,
and ensure that all contact with potentially contaminated surface
soil is regulated and monitored.
Capital Cost:
Annual O&M Cost:
Total Present Worth Cost:
$ 53,000.00
$ 68,000.00
$668,000.00
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*The estimated annua~ O&M cost is approximately $68,000 during the
first 5 years and $17,400 thereafter.
7.3
ALTERNATIVE 3 - EXCAVATION AND OFFSITE DISPOSAL
Alternative 3 includes excavation of surface soil that exceeds the
remediation level and disposal in either a RCRA landfill or a solid
waste landfill. Conventional excavation will be used to remove the
top one foot of soil. The soil will be Toxicity Characteristic
Leaching Procedure (TCLP) tested. If the soil exceeds the Land
Disposal Restrictions (currently 5 ppm for lead), then the soil
will be transported to a RCRA Subtitle C disposal facility. Prior
to disposal, the facility will pretreat the soils using a
stabilizer/solidifier such as a cement or pozzolan based agent. If
the soil does not exceed the 5 ppm restriction, it can be
transported to a Subtitle D solid waste landfill and disposed of
directly without pretreatment. The excavated area would be
backfilled with clean topsoil.
Groundwater monitoring on an annual basis, for at least five years,
would be required to evaluate site progress.
If soils can go to a RCRA subtitle D (nonhazardous facility)
Capital Cost:
Annual O&M Cost:
Total Present Worth Cost
$158,000.00
$ 13,000.00
$237,000.00
*The estimated annual O&M cost is approximately $13,000 for 5
years.
If soils must go to a RCRA subtitle C (hazardous facility)
Capital Cost:
Annual O&M Cost:
Total Present Worth Cost:
$857,000.00
$ 13,000.00
$936,000.00
*The estimated annual O&M cost is approximately $13,000 for 5
years.
8.0
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVE
Overall Protection of Human Health and the Environment
The three (3) alternatives for surface soil remediation were
evaluated based upon the nine (9) criteria set forth in 40 C.F.R.
~ 300.430(e) (9) of the NCP. In the sections which follow, brief
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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.
8.1
Surface Soil Remediation Alternatives
For ease of reference, the three (3) surface soil remedial
alternatives that EPA considered are listed in Table 2.
8.1.1
Threshold Criteria
Two (2) threshold criteria must be
alternative before it can be selected.
achieved
by
a
remedial
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.
Regarding surface f:;oil concerns, Alternatives 1 and 2 do not
eliminate exposure pathways and reduce the level of risk. However,
Alternative 2 minimally reduces the level of human risk by way of
deed restrictions and fencing. Alternative 1 and Alternative 2 do
not limit migra~ion of or remove existing surface soil
contamination. Alternative 3 eliminates exposure pathways and
greatly reduces the level of risk. In addition, Alternative 3
removes contamination and eliminates further migration.
2. Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs) addresses whether an alternative will meet all
of therequire1I\ents. 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 chemical-specific,
action-specific and location-specific ARARs presented in Section 7.
Alternatives 1 and 2 will not meet chemical-specific ARAR's for
surface soil. Under Alternative 3, ARAR's will be met through
excavation and offsite disposal at a properly designed facility.
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 Three (3)
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alternatives. Assuming satisfaction of the threshold criteria,
these five (5) criteria are EPA's main considerations in selecting
an alternative as the remedy.
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. The continued exposure of onsite receptors to surface soils is
a potential long-term impact for Alternatives 1 and 2. Because
contaminated soil remains onsite under these two alternatives. The
remediation level derived for protection of human health and the
environment would not be met by Alternatives 1 and 2. Under
Alternative 3, removal of the soils will eliminate exposure
pathways. The residual risk is low because the surface soil that
exceeds the remediation level will be disposed of offsite. Landfill
disposal has been proven to be an effective solution for
containment of contaminated material over the long-term.
2. Reduction of toxicity. mobility. or volume through treatment
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), directs
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.
Alternatives 1 & 2 do not achieve a reduction in the toxicity,
mobility, or volume of the contaminants since these alternatives
are considered complete at this time. Alternative 3 will reduce the
mobility of contaminants, but the toxicity and volume will remain
the same.
3. Short-term effectiveness refers to the potential for adverse
effects to human health or the environment posed by implementation
of the remedy.
During the implementation of all the alternatives, both onsite
workers and people surrounding the site will be protected when
sampling the various media during review/reassessment every 5
years, when installing a fence around the site and from possible
impacts caused by excavation activities. Risks from soil
excavation and removal would be addressed in health and safety
plans. There is no risk to the environmental receptors from
implementation of any remedy, although, habitats could be disrupted
during excavation activities.
4. Implementability considers the technical and administrative
feasibility of an alternative, including the availability of
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materials and services necessary for implementation.
All components of each alternative are both technically and
administratively feasible. Alternative 1 and 2 can be implemented
immediately because fencing and monitoring equipment are readily
available. For Alternative 2 in administrative terms, implementing
this alternative may have its difficulties. Access restrictions
are subject to changes in pOlitical jurisdictions, legal
interpretations, and regulatory enforcement. As properties change
hands, it is imperative that owners are informed of the deed
restrictions and abide by them. Alternative 3 can be implemented.
Excavation and landfill disposal are proven technologies. There is
an identifiable RCRA Subtitle C facility that can properly treat
and dispose of the soils. Access to Subtitle D facilities is also
available. Excavation of the surface soil requires only
conventional equipment.
5. Cost includes both the capital (investment) costs to implement
an alternative, plus the long-term O&M expenditures applied over a
projected period of operation. The total present worth cost for
each of the four al ternati ves is presented in Table 3, and in
Section 7.
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 acceptance: The State of South Carolina concurs with
this remedy. South Carolina's letter of concurrence is provided in
Appendix B to this ROD.
2. Community acceptance was indicated by verbal comments received
at the Palmetto Recycling Site Proposed Plan public meeting, held
on December 6, 1994. The public comment period opened on November
22, 1994, and closed on January 23, 1995 (after a 30-day
extension). Written comments received concerning the Site, and
those comments expressed at the public meeting, are addressed in
the Responsiveness Summary attached in Appendix A to this ROD.
9.0
THE SELECTED REMEDY
Based upon consideration of the requirements of CERCLA, the NCP,
the detailed analysis of the three (3) alternatives and public and
state comments, EPA has selected a remedy that addresses surface
soil contamination at this Site. At the completion of this remedy,
the risk remaining at this Site will be considered protective of
human health and the environment.
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The selected remedy for the Site is:
Alternative 3, Excavation and Offsite Disposal
Total present worth cost of the seleqted remedy is:
If soils can go to a RCRA subtitle D (nonhazardous facility)
Total Present Worth Cost:
$237,000.00
If. soils must go to a RCRA subtitle C (hazardous facility)
Total Present Worth Cost:
$936,000.00
This remedy consists of excavation of surface soil and offsite
disposal in either a RCRA landfill or a solid waste landfill. The
following subsections describe this remedy in detail, provide the
criteria (ARARS and TBC material) which shall apply, and establish
the performance standards for implementation.
9.1 Surface Soil Contamination
This remedy component consists of excavation of contaminated soil,
verification sampling, and transport of the soil to either a
permitted RCRA Subtitle C disposal facility or a Subtitle D solid
waste landfill. The following subsections describe this remedy in
detail, provide the criteria (ARARS and TBC material) which shall
apply, and establish the performance standards for implementation.
For purposes of describing this portion of the remedy and
specifying the requirements which shall apply to it, it is assumed
. that some or all of the contaminated soils to be addressed will be
shown by laboratory analysis to be RCRA hazardous wastes. However,
TCLP tests could prove otherwise.
9.1.1 Description
On-Site work shall be performed in accordance with the OSHA health
and safety standards applicable to remedial activities. Proper
materials handling procedures shall be used during the excavation
and handling of soil. Such measures may include the use of water
to minimize dust emissions during soil excavation, transport, and
handling, and the use of tarps or plastic sheeting placed over
temporary soil stockpiles to minimize dust emissions and runoff.
Soil in the area of soil contamination shall be excavated until the
remaining soil achieves the concentrations established as
performance standards as described in Section 9.1.3 of this ROD.
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Prior to excavation, soil sampling sufficient to confirm the areal
extent of soil which exceeds these criteria, shall be conducted at
all three compass boundaries of the area shown in Figure 10 of this
ROD. Verification sampling shall be employed to ensure that all
soils contaminated at levels exceeding the performance standard are
removed.
After excavation, the soil will be Toxicity Characteristic Leaching
Procedure (TCLP) tested. If the soil exceeds the Land Disposal
Restrictions (currently 5 ppm for lead), then the soil will be
transported to a RCRA Subtitle C disposal facility. Prior to
disposal, the facility will pretreat the. soils using a
stabilizer/solidifier such as a cement or pozzolan based agent. If
the soil does not exceed the 5 ppm restriction, it can be
transported to a Subtitle D solid waste landfill and disposed of
directly without pretreatment.
Transport shall be accomplished in compliance with DOT regulations
governing transportation of hazardous materials.
Excavation work shall be staged and coordinated with
backfill/grading/seeding activities to minimize dust production and
surface water runoff. The on-Site excavation shall be backfilled
with clean soil, properly recompacted, and the land surface
regraded to the preexisting natural slope. A vegetative cover will
be established to minimize undue surface water runoff and minimize
erosion. .
Groundwater monitoring on an annual basis, for at least five years,
would be required to evaluate site progress.
This alternative represents the best balance among the criteria
used to evaluate remedies. Alternative 3 is believed to be
protective of human health and the environment, would attain ARARs,
would be cost effective, and would utilize permanent solutions and
alternative treatment technologies or resource technologies to the
maximum extent practicable.
9.1.2 Applicable or Relevant and Appropriate Re~irements (ARARs)
ARARs originate from applicable requirements intended to definitely
and specifically apply to a remedial action; or relevant and
approDriate requirements, which, while not intended to apply to the
specific situation in question, EPA judges to be applicable to a
remedial action. In addition, when establishing criteria for
ensuring the proper implementation of a remedial action, EPA may
develop requirements from other guidance documents or criteria,
sources often referred to as "To Be Considered" material (TBCs).
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Record of Decision
Palmetto Recycling Superfund Site
Page 42
Applicable Re~irements. Soil remediation shall comply with all
applicable portions of the followirig Federal and State of South
Carolina regulations listed in Tables 6-9 and below:
49 CFR Parts 107, 171-179, promulgated under the authority of the
Hazardous Materials Transportation Act. Regulates the labelling,
packaging, placarding, and transport of hazardous materials
offsite.
40 CFR Parts 261, 262 (Subparts A-D), 263, and 268, promulgated
under the authority of the Resource Conservation and Recovery Act.,
These regulations govern the identification, transportation,
manifestation, and land disposal restriction requirements of
hazardous wastes. If the contaminated soils fail TCLP, most
likely, the land disposal restrictions in 40 CFR Part 268 will
apply. However, if EP toxicity tests are performed and the
contaminated soils do not exceed EP toxicity limits, then the land
disposal restrictions in 40 CFR Part 268 will not apply, even
though the contaminated soils fail TCLP. In the event that the
Site soils requiring remediation do not test hazardous (i.e., do
not fail TCLP), the regulations listed here will be considered
relevant and appropriate rather than applicable.
SCHWMR 61-79.124, .261, .262, .263 and .268, South Carolina
Hazardous Waste Management Regulations, promulgated pursuant to the
Hazardous Waste Management Act, SC Code of Laws-, 1976, as amended,
establishes criteria for identifying and handling hazardous wastes,
as well as land disposal restrictions regulations will also become
relevant and appropriate in the remediation do not prove to be
event that the soils requiring hazardous, as described in the above
paragraph.
Relevant and Appropriate Re~irements. The following regulations
are "relevant and appropriate" to source control actions (soil
remediation) at the Palmetto Recycling Site. Applicability of
these air quality control regulations is due to the potential for
release of harmful particulates (metals) during soil excavation and
handling activities.
40 CFR Parts 60 and 61, promulgated under the authority of the
Clean Air Act. Included are the National Emissions Standards for
Hazarqous Air Pollutants (NESHAPs). Ambient air quality standards
for emissions to the atmosphere fall under these regulations.
SC Reg. 61-62, South Carolina Air Pollution Control Regulations and
Standards, promulgated pursuant to the S.C. Pollution Control Act,
SC Code of Laws, 1976, as amended. Establishes limits for
emissions of hazardous air pollutants and particulate matter, and
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Record of Decision
Palmetto Recycling Superfund Site
Page 43
establishes acceptable ambient air quality standards within South
Carolina.
"To Be Considered" and Other Guidance.
Revised Procedures for Planning and Implementing Off-site Response
Actions, OSWER Directive 9834.11, November 1987. This directive,
often referred to as "the off-site policy," requires EPA personnel
to take certain measures before CERCLA wastes are sent to any
facility for treatment, storage, or disposal. EPA personnel must
verify that the facility to be used is operating in compliance with
$ 3004 and $ 3005 of RCRA, as well as all other federal and state
regulations and requirements. Also, the permit 'under which the
facility operates must be checked to ensure that it authorizes (1)
the acceptance of the type of wastes to be sent, and (2) the type
of treatment to be performed on the wastes.
40 CFR Part 50, promulgated under the authority of the Clean Air
Act. This regulation includes the National Ambient Air Quality
Standards (NAAQS), and establishes a national baseline of ambient
air quality levels. The state regulation which implements this
regulation, South Carolina Reg. 62-61, is applicable to the source
control portion of the remedy.
Various TBC materials were utilized in the Baseline Risk Assessment
and in the Feasibility Study. Because cleanup standards were
established based on these documents, they are considered TBC.
In the Baseline Risk Assessment, TBC material included information
concerning toxicity of, and exposure to, Site contaminants. TBC
material included the Integrated Risk Information System (IRIS),
Health Effects Assessment Summary Tables (HEAST), and other EPA
guidance as specified in the Baseline Risk Assessment.
In the FS, soil concentrations protective of human health and the
environment were calculated based on the Site-specific risk
calculations from the Baseline Risk Assessment, using TBC
information as described above. These levels are established as
performance standards in the following section. There are no
established federal or state standards for acceptable levels of
Palmetto Recycling Site contaminants in surface or subsurface
soils.
The protective level for surface soils (0-1 feet) was established
for lead (Pb) which is equivalent to the EPA Region IV Level of
Concern 400 mg/kg for surface soils (0-1 feet). This criterion is
also designated TBC.
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Record of Decision
Palmetto Recycling Superfund Site
Page 44
Other requirements. Remedial design often includes the discovery
and use of unforeseeable, but necessary, requirements, which result
from the planning and investigation inherent in the design process
itself. Therefore, during design of the source control component
of the selected remedy, EPA may, through a formal ROD modification
process such as an Explanation of Significant Differences or a ROD
Amendment, elect to designate further ARARs which apply, or are
relevant and appropriate, to this portion of the remedy.
9.1.3 Performance Standards
The standards outlined in this section comprise the performance
standard defining succes~ful implementation of the remedy. The soil
remediation goal is 400 ppm for Lead for all areas across the site.
Excavation. The soil remediation goal (Table 4) is established as
a performance standard. The performance standard shall control the
excavation procedure described above. Additionally, all on-Site
excavation work shall comply with 29 CFR 1910.120, the OSHA health
and safety requirements applicable to remedial activities.
Transport of contaminated soil. Transportation
accomplished in compliance with the Hazardous
. Transportation Act (49 CFR 107, 171-179).
shall be
Materials
Disposal of contaminated soil. Disposal of contaminated Site soil
shall comply with the applicable, or relevant and appropriate, RCRA
regulations (40 CFR Parts 261, 262 (Subparts A-D), 263, and 268).
The determination of applicability, versus relevant and
appropriate, is described in Section 9.1.2, under" applicable
requirements," where the above regulations are cited. In any
circumstance, the disposal of contaminated soils shall be done at
a RCRA Subtitle C treatment, storage, and disposal facility.
Confirmation soil sampling will be conducted to insure that all
contaminated soil has been excavated.
10.
STATUTORY DETERMINATIONS
The selected remedy for this Site meets the statutory requirements
set forth at Section 121(b) (1) of CERCLA, 42 U.S.C. ~ 9621(b) (1).
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
r~source 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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Record of Decision
Palmetto Recycling Superfund Site
Page 45
Protection of human health and the environment: The surface soil
remediation alternative will include excavation of surface soil
that exceeds the remediation level of 400 ppm for Lead and disposal
in either a RCRA Landfill or a solid waste landfill, thereby
reducing and eventually removing the future risks to human health
which could result from ingestion of the surface soil.
Compliance with ARARs: The selected remedy will meet ARARs, which
are listed in Sections 9.1.2 of this ROD.
Cost effectiveness: Among the surface soil 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
similar to the other alternatives. .
Utilization of permanent solutions. and alternative treatment
technoloqies or resource recovery technoloqies 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 soil remedial action is
the most practical and easily implemented alternative, given the
relatively small volume of soil requiring remediation
(approximately 1100 cubic yards) .
Preference for treatment as a principal remedy element: The soil
remedial action will not satisfy the preference, because it was
determined that treatment of the small volume of soil requiring
remediation is not practical. Additionally, offsite disposal is
more feasible in that it does not result in creation of an onsite
waste cell that must be monitored for an extended period of time.
If the contaminated soils are treated prior to disposal at a RCRA
facility, then the preference will be satisfied.
11.
DOCUMENTATION OF SIGNIFICANT CHANGES
EPA issued a Proposed Plan (preferred alternative) for remediation
of the Palmetto Recycling Site on November 22, 1994. The selected
combination of remedies does not differ from the Proposed Plan.
However, it was determined that an adjustment needed to be made in
the cost estimates that were in the proposed plan.
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TABLE 6
POTENTIAL CHEMICAL-SPECIFIC ARARs
PALMETTO RECYCLING SITE
COLUMBIA, SOUTH CAROLINA
:%&'£t^^^
Souraa.
Requirement:
Status
Hater
Inorganic
chemicals in
drinking water:
40 CFR 141.11
40 CFR 141.62
40 CFR 141.50-51
SC Reg. 61-58.5 B
The maximum contaminant levels (MCLs) for Relevant
inorganic chemicals are the maximum permissible and
levels of a contaminant in water (mg/1) which is Appropriate
delivered to a free flowing outlet to the ultimate
user of a public water system.
Organic chemicals
in drinking
water:
40 CFR 141.61
SC Reg. 61-58.5
Ambient Water
Quality
Standards:
SC Reg. 61-68
The MCLs for organic chemicals are the maximum
permissible levels of a contaminant in water
(mg/1) which is delivered to a free flowing outlet
to the ultimate user of a public water system.
Dry Fork Creek is classified as a fresh water
stream to be protected for aquatic organisms.
Inetream concentration limits for heavy metals are
established by SCDHEC using EPA'e Gold Book of
quality criteria for water and a formula.
These requirements are not applicable since a public
water system (as defined in 40 CFR 141} is not involved.
They are relevant and appropriate to protect groundwater,
a potential drinking water source, from contaminants
found on the site. These contaminants might migrate or
leach into the underlying aquifer as a consequence of
various alternative actions. Maximum contaminant level
goals (MCLGs) are to be used when special circumstances,
such as where multiple contaminants in groundwater or
multiple pathways of exposure present extra-ordinary
risks, require a more stringent level than the MCL.
MCLGs for which the standard is zero are not considered
ARARs or TBCs.
Relevant These requirements are not applicable since a public
and water system (as defined in 40 CFR 141} is not involved.
Appropriate They are relevant and appropriate to protect groundwater,
(proposed a potential drinking water source, from contaminants
MCLs are TBC) found on the site. These contaminants might migrate or
leach into the underlying aquifer as a consequence of
various alternative actions. SC has not promulgated MCLs
for organic chemicals in drinking water that are more
stringent than the federal standards.
Applicable These standards for the contaminants of concern which may
be carried by storm water runoff into Dry Fork Creek are
applicable.
46
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TABLE 6 (continued)
POTENTIAL CHEMICAL-SPECIFIC ARARfl
PALMETTO RECYCLING SITE
COLUMBIA, SOUTH CAROLINA
Souroe
Requirement
Status
Chemicals in drinking
water (solid waste
disposal facility):
40 CFR 257.3-4
SC Reg. 61-79.264.94
A facility shall not contaminate an underground water
source beyond the solid waste boundary (outermost
perimeter of the waste). The concentration of chemicals
shall not exceed background levels or listed MCLs,
whichever is higher.
Applicable Oneite residuals of solid waste
(contaminated surface soil) might cause
migration into the underlying aquifer and
potentially contaminate drinking water
systems as a consequence of remedial
actions.
Air
Ambient Air Quality
Standards:
SC Reg. 62.5 Standard No.
2
Control of Fugitive
Particulate Matter
Statewide:
SC Reg. 62.6 Section III
Soil
OSWER Directive 9355.4-12:
Revised Interim Soil Lead
Guidance for CERCLA Sites
and RCRA Corrective Action
Facilities
The ambient air standard for lead as determined by Applicable
Federal Reference Methods is 1.5 mg/m1 (calendar
quarterly mean).
Emissions of fugitive dust shall be controlled in such a Applicable
manner and to the degree that it does not create an
undesirable level of air pollution.
The remediation level for lead in surface soil is 400 To Be
mg/kg. Considered
During remedial activities at the site,
lead in fugitive dust may be released.
The ambient air standard is applicable
statewide.
During remedial activities at the site,
fugitive dust may be released.
Lead levels for surface soil are not
established in promulgated regulations.
Therefore, this guidance will be utilized.
This requirement is designed to protect
children from developing blood lead levels
above 10 ug/dl from exposure to surface
soil.
47
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TABLE 7
POTENTIAL LOCATION-SPECIFIC ARARs
PALMETTO RECYCLING SITE
COLUMBIA, SOUTH CAROLINA
• Source
Status
Rational*
Fish and Wildlife Conservation
Act
16 USC Section 2901 et eeq.
Endangered Species Act of 1973
16 USC Section 1531 et aeq.
Wetlands Management Executive
Order
Executive Order 11990;
Protection of Wetlands
Requires states to identify significant
habitats and develop conservation plans
for these areas.
Requires action to conserve endangered
species or threatened species, including
consultation with the Department of
Interior.
Requires action to minimize the
destruction, loss, or degradation of
wetlands.
Relevant
and Appropriate
Relevant
and Appropriate
Relevant
and Appropriate
Confirmation with the responsible state agency
regarding the site being located in one of
these significant habitats is required.
Although threatened or endangered species or
critical habitats have not been identified at
the site, there are endangered plants and
animals listed for the county and state that
could potentially be affected by contamination
at the site.
Wetland areas are present within the vicinity
of the site.
48
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TABLE 8
POTENTIAL ACTION-SPECIFIC ARARS
PALMETTO RECYCLING SITE
COLUMBIA, SOUTH CAROLINA
Soura•
R«quir«ment
Status:
Discharge of storm water
runoff:
40 CFR 122.26
Discharge of treatment
system effluent:
40 CFR 125.104
Generators who transport
hazardous waste for offeite
T3D: 40 CFR 262.20-.23
Storm water from landfills, construction
sites, and industrial activities must be
monitored and controlled.
Best Management Practices (BMP)
Develop and implement a BMP program to
prevent the release of toxic or hazardous
pollutants to the waters of the U.S. The
BMP program must:
• Establish specific procedures for the
control of toxic and hazardous pollutant
spills and runoff
• Include a prediction of direction, rate of
flow, and total quantity of toxic and
hazardous pollutants where experience
indicated a reasonable potential for
equipment failure
Any generator who transports hazardous waste
for offsite TSD must originate and follow-up
the manifest for offsite shipments.
Applicable Required of all industrial waste sites and
construction sites of greater than 5 acres that
discharge storm water runoff to the waters of the
United States.
Relevant The requirement is not applicable because BMP under
and the National Pollutant Discharge Elimination System
Appropriate (NPDES) permit program applies only to ancillary
facilities of manufacturing units that might have
releases of toxic or hazardous pollutants. This
substantive permit requirement is relevant and
appropriate to the prevention of releases from spills
or runoff during the implementation of remedial
actions.
Applicable Any waste determined to be RCRA hazardous waste
removed from this site for offsite treatment, storage,
or disposal would be subject to the manifest
requirements.
49
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TABLE 8 (continued)
POTENTIAL ACTION-SPECIFIC ARARs
PALMETTO RECYCLING SITE
COLUMBIA, SOUTH CAROLINA
flourae
Requirement
Status
' Rationala* ;.
Closure of hazardous
waste TSD facility:
40 CFR 264 Subpart G
Land disposal
restrictions (LDRs):
40 CFR 268, Subpart D
Operator must close the facility in a manner
that:
• Minimizes the need for further maintenance
• Minimizes post-closure escape of hazardous
constituents
• Complies with specific unit type closure
requi remente
All contaminated equipment, structures, and
soils must be properly disposed of or
decontaminated.
Generally prohibits the placement of
restricted RCRA hazardous wastes in land-
based units such as landfills, surface
impoundments, waste piles and facilities,
unless one or more of the following are met:
• Wastes have been treated in accordance
with technology-based or concentration-
based standards specified in Subpart D
• The site manager can demonstrate that
another technology can achieve an
equivalent measure of performance in
accordance with 40 CFR 268.42
• The site manager has demonstrated that the
waste does not meet any of the criteria
under which the waste was listed and other
factors (including additional constituents
that might not cause the waste to be
hazardous.
Applicable
The site is a TSD facility in that hazardous materials
are present as contaminants of environmental media.
Remediation may involve treatment or storage of
hazardous wastes.
Applicable
The contaminated surface soil at this site is
restricted RCRA wastes that would be subject to the
LDRs for lead. Remediation may involve land disposal
of restricted hazardous wastes.
50
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TABLE 9
OTHER REQUIREMENTS*
PALMETTO RECYCLING SITE
COLUMBIA, SOUTH CAROLINA
.3oura«
H«
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Record of Decision
Palmetto Recycling Superfund Site
Page 52
The cost estimates, as documented in the proposed plan, for the
present worth of each alternative were calculated using a five
percent (5%) discount rate per year. However, pursuant to the OSWER
Directive 9355.3-20 (Revisions to OMB Circular A-94 on Guidelines
and Discount Rates for Benefit-Cost Analysis), the cost estimates,
as documented in this ROD, for the present worth of each alter-
native were calculated using a seven percent (7%) discount rate per
year.
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REFERENCES
COM Federal Programs Corporation, November 1994. Remedial
Investigation and Feasibility Study Report, Palmetto Recycling
Site, Columbia, South Carolina
Knox, RaYmond C., June 1983. Geohydrologic Assessment, Palmetto
Recycling, Inc., Richland County, South Carolina.
Pooser, W.K. and H.S. Johnson, 1961. Geology of the Fort Jackson
North Quadrangle, South Carolina. Division of Geology, South
Carolina State Development Board.
Tanner, T., 1992. Verbal Communication with Terry Tanner, Remedial
Project Manager for EPA, site meeting on July 19, 1992.
u.S. Department of Agriculture, 1978.
County, South Carolina.
Soil Survey of Richland
u.S. Environmental Protection Agency, 1992. Statement of Work for
the Palmetto Recycling Site
u.S.
Geological Survey Topographic Quadrangle Maps of
Carolina. Columbia North 1972, PR 1990; Irmo 1971, PR
Blythewood 1971,PR 1990; Fort Jackson 1972, PR 1990.
1;24,000.
South
1990;
Scale
Weston, October 1994. Final Baseline Risk Assessment, Palmetto
Recycling Site, Columbia, South Carolina.
53
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APPENDIX A
RESPONSIVENESS SUMMARY
FOR THE PALMETTO RECYCLING SUPERFUND SITE
54
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RESPONSIVENESS SUMMARY
PALMETTO RECYCLING SUPERFUND SITE
1.
Overview
The U. S. Environmental Protection Agency (EPA) held a public
comment period from November 22, 1994 to December 22, 1994, for
interested parties to comment on the Remedial Investigation/
Feasibility Study (RI/FS) results and the Proposed Plan for the
Palmetto Recycling Superfund Site in Columbia, South Carolina. Upon
receipt of a request, the comment period was extended an additional
30 days. The comment period closed on January 23, 1995.
EPA held a public meeting at 7:00 p.m. on December 6, 1994, at the
Fairlawn Community Center in Columbia, South Carolina to present
the results of the RI/FS and the Baseline Risk Assessment, to
present the Proposed Plan and to receive comments from the public.
EPA proposed excavation and offsite disposal to address
contaminated soil. Judging from the comments received during the
public comment period, the residents and local officials in the
Columbia, South Carolina area support the cleanup alternative
proposed by EPA.
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:
Superfund Site
Proposed Plan for the Palmetto Recycling
.
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:
Meeting
Official Transcript of the Proposed Plan Public
1
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2.
Backaround of Community Involvement
BPA's community relations program for the Site began on June 8,
1992, when BPA conducted community interviews in order to develop
a community relations plan for the Site. At that time, residents
living adjacent to the Site were concerned about the Site and about
any health risks from the Site. In addition, residents did voice
some concerns about lack of information to the public during the
removal work at the Site and lack of response to earlier complaints
about the Site.
Throughout BPA' 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 the Remedial Project Manager
(RPM) and the Community Relations Coordinator (CRC). Local
officials were briefed during the community interviews. The Site
mailing list was expande~ to include additional residents living in
close proximity to the Site.
3.
Summary of Comments Received Durina the Public Comment
Period and Aaencv ResDonses
The Public Comment Period was opened on November 22,1994 and was to
end on December 22, 1994. Upon request, a 30-day extension was
granted, which extended the comment period to January 23, 1995.
. Public Notices which were published in local papers can be found in
Attachment B.
On December 6, 1994, BPA held a public meeting to present the
Proposed Plan to the community and to receive comments thereupon.
All comments received at this public meeting and during the public
comment period are summarized below. Part I of this section
addresses those community concerns and comments that are non-
technical in nature. Responses to specific legal and technical
questions are provided in Part II.
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: An attendee asked a question regarding whether or not a
Private Well Survey was conducted.
RESPONSE: EPA conducted a private well survey of 52 homes and
residences during the Remedial Investigation. The Private Well
Water Use survey revealed that at least 36 private wells are
located within one mile of the site. Of these, 21 wells are
currently used for drinking water. The remainder are used for
household purposes, irrigation, or are not being used at all.
2
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COMMENT: An attendee asked a question regarding whether or not
testing was done under the asphalt pad.
RESPONSE: During the Remedial Investigation, EPA collected four
surface soil samples located under the asphalt pad. These samples
were collected under the asphalt of previous work areas to assess
the impacts from past operations.
COMMENT: An attendee claimed during the proposed plan meeting that
the Palmetto Recycling, Inc., owned approximately 20 acres of land
including. the site area. She was concerned that additional
contamination could be present on the other 181/2 acres of the
property.
RESPONSE: Previous studies suggested that there were numerous
sources of contamination at the Site. Based on those studies,
several previous remedial actions have been performed to remove the
contaminated sludge, soil, and wastewater from the site. While
those levels of contamination were greatly reduced, a Remedial
Investigation was warranted to fully delineate all contamination of
known areas and to characterize the site. Based on the information
obtained from the operational history of the facility and the
earlier investigations, including the Remedial Investigation, EPA
has characterized the site and the nature of its contaminants to
the best of its knowledge. However, if further information suggest
additional sources of contamination, EPA will do its best to
investigate the area and confirm the information.
COMMENT: An attendee asked a question regarding what was
considered onsite or offsite for the purposes of looking at risk at
the site.
RESPONSE: EPA stated during the public meeting that when we say
living on site we mean that if someone built a house on the site
and a child lived in that house and was in the yard every day
coming and going under normal conditions, including drinking the
water from the well on site and all of the other exposure pathways,
then, that person or family would experience a higher level of
exposure than a child who lives across the street or nearby. Onsite
simply means that someone can or will be exposed on a day to day
basis, not occasionally.
COMMENT: An attendee inquired about the likelihood of someone
getting cancer from the contaminants of concern at the site and
whether or not someone would have to be exposed for a period of ten
years or so before they would get cancer.
RESPONSE: EPA stated during the public meeting that there is no
clear evidence that lead is a carcinogen (a cancer causing agent) .
However, lead has very serious effects in other ways such as with
the central nervous system. Therefore you would not expect to see
cancer as a result of lead exposure. The only other contaminant
3
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mention in the Risk Assessment that had any significant levels and
might be a carcinogen is l,2-Dichloroethane. However, it was found
at such low levels that the risk associated with that is
infinitesimally small.
COMMENT: An attendee inquired about how long the clean up of the
site would take and whether or not there would be any exposure from
the dust during the clean-up activities.
RESPONSE: First there are several enforcement issues that by law
EPA would have to pursue to see if there are any viable parties out
there. At that time, EPA will negotiate with the responsible
parties to conduct the clean-up activities at the site. If
agreements can't be reached then, EPA will conduct the clean-up
activities. Because there are so many unknown factors involved, an
exact time can not be determined.
Second, EPA will take several measures to ensure that proper
handling procedures will be used during the excavation and handling
of soil. Such measures may include the use of water to minimize
dust emissions during the soil excavation, transport, and handling,
and use of tarps or plastic sheeting placed over temporary soil
stockpiles to minimize dust emissions and runoff. These measures
should greatly reduce the level of exposure.
Part II - Technical Response to Public Comments
Many questions were raised during the Public Comment period
regarding how the Palmetto Recycling Superfund Site Remedial
Investigation and Feasibility Study were conducted (ie., the
selection of sampling locations for background samples, soil boring
samples and monitoring wells; the selection of the cleanup goal and
the selection of the preferred alternative for remedial action).
In addition, there was a suggestion for onsite treatment using
Fixation/stabilization and disposal. The written comments
concerning the previously mention questions are located in
Attachment C of this Responsiveness Summary.
Responses addressing the following topics: selection of sampling
locations for background samples, soil boring samples and
monitoring wells
Before the activities necessary to conduct a Remedial Investigation
and Feasibility Study can be planned, it is very important for EPA
to compile the available data that have previously been collected
for a Site. EPA's analysis of existing data serves to provide a
better understanding of the nature and extent of contamination and
aids in the design of several remedial investigation tasks (ie.,
identifying boundaries of the study area, determining the locations
4
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of background samples, soil (surface/subsurface) samples, sediment
samples, groundwater samples and surface water sediments) .
In the case of the Palmetto Recycling Site, several studies
suggested that there were numerous sources of contamination at the
Site. Based on those studies, several previous remedial actions
have been performed to remove the contaminated sludge, soil, and
wastewater from the site. While those levels of contamination were
greatly reduced, a Remedial Investigation was warranted to fully
delineate all contamination of known areas and to characterize the
site. Based on the information obtained from the operational
history of the facility and the earlier investigations, several
sampling locations, including background locations were selected
during the initial Remedial Investigation fieldwork. Based on the
analysis of the data obtained during phase 1 of the RI, additional
.surface soil samples were warranted in order to evaluate the extent
of surface soil contamination. For surface and subsurface soil
locations, one location for each of these background samples was
collected. Additional background soil samples could have been
obtained, but with results ranging from (6.4 mg/kg - 6400 mg/kg)
for the lead contaminant, it is very unlikely that an additional
background sample would have had a lead result equal to or greater
than 3400 mg/kg). Levels in the 6400 mg/kg range are not naturally
occurring in the boundaries of this Site. Based on information from
previous investigations, including Phase I of the Remedial
Investigation, an additional monitoring well cluster was not
installed north of well cluster #3 to monitor groundwater
downgradient of the suspected dumping area. Previous data does not
support occurring groundwater contamination from this area.
Therefore, installation of an additional well cluster was not
warranted.
Responses addressing the following topics: Approaches used to
determine the cleanup goal for lead at the Palmetto Recycling
Superfund Site.
Currently there'is not an EPA slope factor or reference dose for
lead. EPA believes that the available studies in' animals do not
provide sufficient quantitative information for their calculation
(ATSDR, 1990). Although lead is currently classified as a B2
carcinogen, the EPA considers the noncarcinogenic neurotoxic
effects' in children to be the critical toxic effect in terms of
health based environmental cleanup. The neurotoxic effects of
chronic low-level lead exposure in children may occur at blood
levels as low as 10 ug/dl.
In the absence of lead heal th cri teria, two approaches were
considered. The first was to predict mean lead blood levels in
children using the Lead Uptake/Biokinetic Model (version 0.99d,
u.S. EPA 1994) pursuant to the guidance OSWER Directive 9355.14-2.
5
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The second approach compares on-site mean level concentration with
applicable or relevant and appropriate requirements (ARARs).
Pursuant to the guidance OSWER Directive 9355.14-2 the on-site mean
level concentration for lead (528 mg/kg) was used as an input to
the model as opposed to the 95% UCL concentration of (1,968 mg/kg).
The results of the model predicted that 10.61% of the population
would have an unacceptable blood lead concentration. EPA generally
requires further action if greater than 5% of the population has
acceptable blood levels.
Consequently, it was suggested that the Lead Uptake/Biokinetic
Model be run iteratively until the acceptable blood lead levels and
population effects are reached (10 ug/dl and 5%, respectively). If
the current Lead Uptake/Biokinetic Model is run with 400 mg/kg as
the input for soil concentratio~s, the value approaches BPA's
acceptable criterion which is less than or equal to 5% of the
population exceeding the blood lead level concentration of 10
ug/dl. Based on this evaluation, a lead level concentration of 400
mg/kg was chosen as a cleanup goal to be used during remedial
action at the Palmetto Recycling Site.
Responses addressing the following topics: the selection of the
preferred alternative for remedial action (Excavation and offsite
disposal) verses onsite treatment using Fixation/stabilization and
disposal.
Although many remedial actions have been performed at the Palmetto
Recycling Site to remove contaminated sludge, soil and wastewater,
the results of the RI showed that several "hot spots" still exist.
The FS focused on remediating those remaining "hot spots" to a lead
remediation level of 400 mg/kg. Using a worst case scenario, the
estimated area of soil contamination extends over an area of
approximately 29,500 square feet. A depth of one foot was used to
calculate the estimated volume of surface soil contamination.
Based on the calculations ,surface soil contamination is
approximately 1,100 cubic yards. Please note that this estimate is
very conservative. Sampling during the remedial design is warrented
to completely delineate the lateral extent of contamination and
more accurrately determine the volume of contaminated surface soil.
Since the volume of contamination is small, the only Genral
Response Actions (GRAs) that will be considered are no action,
institutional actions, and removal followed by off site disposal and
subsequent treatment at a treatment, storage, and disposal (TSD)
facility. Onsite treatment such as solidification/stabilization
was not evaluated in this FS because the estimated quantity of
contaminated soil at this site falls short of the typical cut-off
mark used within the industry to size whether a project is more
6
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cost-effectively treated onsite versus offsite (2000 tons t 15% is
the cutoff mark used) .
The soil remedial action will not satisfy the preference, because
it was determined that treatment of the small volume of soil
requiring remediation is not practical. Additionally, offsite
disposal is more feasible in that it does not result in creation of
an onsite waste cell that must be monitored for an extended period
of time. If the contaminated soils are treated prior t disposal at
a RCRA facility, then the preference will be satisfied.
7
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Attachment A
Proposed Plan for the Pa~etto Recycling Superfund Site
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~
.
SUPERFUND PROPOSED PLAN FACT SHEET
Palmetto Recycling Superfund Site
Columbia, Richland County, South Carolina
November 1994
u. S. Environmental Protection Agency, Region IV, Atlanta, GA
This fact sheet is one in a series designed to inform
residents and local officials of the ongoing cleanup efforts
at the Site. A number of terms specific to the Superfund
process (printed in bold print) are dermed in the glossary
which begins on Page 16
INTRODUCfION
The United States Environmental Protection Agency (EPA),
is proposing a cleanup plan, referred to as the preferred
alternative, to address contaminated soil at the Palmetto
Recycling Superfund Site (the Site) located in Columbia,
Richland County, South Carolina. This document is being
iss.ued by EPA, the lead agency for Site activities, and the
South Carolina Department of Health and Environmental
Control (SCDHEC), the support agency.
This Proposed Plan summarizes the cleanup
methods/technologies evaluated in the Feasibility Study
(FS). In accordance with Section 117(a) of the
Comprehensive Environmental Response, Compensation,
and Liability Act 01 1980, as amended by the Superfund
Amendments and Reauthorization Act 011986, (CERCLA,
known as Superfund), EPA is publishing this Proposed
Plan to provide an opportunity for public review and
comment on all cleanup options (known as remedial
alternatives) under consideration for the Site, as developed
in the Feasibility Study, including EPA's preferred
alternative. EP A is initiating a thirty (30) day public
comment period from November 22 to December 22, to
receive comments on this Proposed Plan and the RIlFS
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 EP A during that
time has been reviewed and considered. As outlined in
section 117(a) of CERC LA , EPA encourages public
participation by publishing Proposed Plans for addressing
contamination at Superfund sites, and by providing an
opportunity for the public to comment on the proposed
remedial actions. Changes to the preferred altemative, or
a change from the preferred alternative to another, may be
made if public comments or additional data indicate that
such a change would result in a more appropriate solution.
The [mal decision regarding the selected remedy will be -
documented in a Record of Decision (ROD) after EPA haS
taken into consideration all comments from the public.
Upon timely request. EP A will extend the public comment
period by 30 additional days.
EPA's preferred' alternative for cleanup of Site surface soil
is: Excavation and Offsite Disposal. This alternative
achieves the best balance of trade-offs among the cnteria
EP A uses to evaluate remedial alternatives. The selection
of a cleanup plan, or "preferred alternative," represents a
preliminary decision by EP A, subject to a public comment
period. The preferred alternative for surface soil. as well as
the others considered. are summarized in this fact sheet and
presented more fully in the Feasibility Study (FS).
SCOPE OF THE PROPOSED ACTION. This Proposed
Plan for the Palmetto Recycling Superfund site addresses
remedies for surface soil contamination present at the site.
Groundwater, sediments and surface water were sampled
during the Remedial Investigation as well. The planned
action is necessary to protect the public and environmental
receptors from exposures to contaminated surface soils.
Additional sources or operable units are not expected.
Public Comment Period:
Tuesday, November 22, 1994
- Thursday, December 22 1994
Public Meeting
Date: TuesdLzy, December 6, 1994
Time: 7:00 PM.
Place: Fairlawn Community Center
9128 Wilson Boulevard
Columbia, SC
Provide written comments or call:
Yvonne Jams or Cynthia Peurifoy
US Environmental Protection Agency
North Superfund RemedIal Branch
345 Courtland St, NE
Atlanta. Georgia 30365
1-800-435-9233
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.........u .... .-..-. ........,............-...-.
. .._"..__.'..'.."''''--....'~_. -""._~...
This fact sheet summarizes. information that is explained in
greater detail in the Remedial Investigation (RI)/FeasibiUty
Reports (FS) Reports dated November 1994, and the
BaseUne Risk Assessment document dated November 1994.
These documents and all other records utilized by EP A to
make the proposal specified in this document 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, to better
understand the Site, the Superfund process, and the intent
of this Proposed Plan. The administrative record is
available for public review during normal working hours,
locally at the site information repository, which is the
Northeast Regional Library or.in the Record Center at EP A,
Region IV's office in Atlanta, Georgia (see page 15).
THIS PROPOSED PLAN:
1.
Includes a brief history of the Site, the
principle fmdings of the RI and a
summary of the Baseline Risk Assessment;
2.
Presents the cleanup alternatives
considered by EP A for the Site;
3.
Outlines the criteria used by EPA to
recommend an 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 the preferred
alternative; and
6.
Explains the opportunities for the public to
comment on the remedial alternatives, and
hence the cleanup of the Palmetto
Recycling Superfund Site.
SITE BACKGROUND
Site Description. The Site is located about 8 miles north of
Columbia, South Carolina, in rural Richland County. The
site is positioned between U.S. Highway 321 and U.S.
Highway 21 on the north side of Koon Store Road - State
. .'-,....-. -..-...--,,,.-,,,,"""""'-'.:...- - ,""."".'-.......-.-''''''''. ---...--..-.-.....o.-'..:.r..';,.' ~...!'..._~~..............._.t~~...........
Road S-40-61 (Figure 1). The Site occupies approximately
1.5 acres and is bounded by Koon Store Road to the south,
an unnamed dirt road (and farther removed, Dry Forie
Creek) to the east, an unnamed tributary of Dry Fork Creek
to the north, and a residential lot and home to the west
Figure 2 shows the location of the Site.
Land use in the area is rural residential, with ~uch of the
surrounding area comprised of scrub vegetation and pines.
According to the Hazard Ranking System (RRS)
evaluation, conducted in 1986, EP A estimates 5,300 people
live in a 3-mile radius of the site. Approximately 46
residences are located along Koon Store Road within 1 mile
of the site.
Important physiqal features of the site include a 6-ft x 30-ft
concrete walkway, an office building, a 135-ft by 170-ft
asphalt pad with two concrete pads, a frame worle shed, a
concrete tank saddle, and an unnamed tributary that flows
to Dry Fork Creek. A previously, open excavation which
was filled with water associated with abandoned truck
scales was sampled during the RI field effort and found to
be uncontaminated. The water was pumped to the unnamed
tributary and the pit was backfilled with clean soil and .
graded to prevent ponding. A sparse cover of crushed rock
was applied for soil erosion control. The waste materials
in the suspected dumping areas have been removed. In
addition, five groundwater monitor wells, installed by
Raymond Knox Consultants, are located onsite. Dry Fork
Creek, located east of the site, flows toward the south into
the North Branch of Crane Creek. Dry Fork Creek receives
drainage from an unnamed tributary located north of the
site.
Site Historv. The property was purchased in 1979 by
Palmetto Recycling, Inc. for the purpose of operating a
battery recycling company. From 1979 to 1983, the facility
was involved in the reclamation of lead from batteries. In
the process, the facility operations produced acid waste
which collected in a sump. The reclamation process also
produced wastewater from the washing of battery cases.
Specific neutralization process details are unknown, but at
some point. the facility discharged wastewater of unknown
composition to the local sewer system.
After discharging wastewater for an unknown period of
time, Palmetto Recycling attempted to obtain a discharge
permit. In 1981, the South Carolina Deparunent of Health
and Environmental Control (SCDHEC) denied applications
2
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COLUMBIA
RICHLAND COUNTY
-N-
PALMETTO
RECYCLING
COM FEDERAL PROGRAMS CORPORATION
a subsidiary of Camp Drener & McKee Inc.
COM FPC ARCS IV
SITE LOCATION MAP
PALMETTO RECYCLING
COLUMBIA, SOUTH CAROLINA
FIGURE No. 1
-------
(former
Irticli Scolc)
/' '
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NOTE: AH locations ora opproximols.
COM FPC ARCS IV
CURRENT SITE FEATURES MAP
PALMETTO RECYCLING
RICHLAND COUNTY, SOUTH CAROLINA
FIGURE NO. 2
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by Palmetto Recycling, Inc. to operate a hazardous waste
facility and to transport hazardous wastes. After this
attempt. some waste liquids were sent offsite to an acid
recycler and some were disposed of onsite. It is not known
if these wastes were neutralized before shipment or onsite
disposal. The quantities are also unknown. Plastic battery
cases and lead plates were eventually sold to other
companies as reusable materials (EPA, 1992).
A study conducted by the SCDHEC identified elevated
concentrations of lead and iron in the groundwater samples
collected next to the sump. High levels of lead, barium,
and chromium were in found in sediment from the unnamed
stream that runs north of the site. The investigation also
revealed the presence of elevated concentrations of lead in
on-site soils. SCDHEC noted the presence of a five-foot
deep, unlined acid pit containing 1,800 gallons of acid
waste at the site, as well as 100 drums of caustic waste and
unstablized pile battery casings.
On February 11, 1983, Palmetto Recycling filed for
bankruptcy and Ryan Hovis was appointed trustee. In
1984. workers removing equipment from the site destroyed
a section of the roof covering the on-site collection sump
that collected wastewater containing lead oxide and sulfuric
acid from the wash process. As a result of this incident,
sump water percolated through soils adjacent to the pit area.
To address immediate health and environmental risks posed
by the Site, three removal actions have occurred at the site.
On April 25. 1994. 10.800 gallons of contaminated water
were collected by the Bryson Industries Services and taken
to Alternate Energy Resources. On April 1984. SCDHEC
informed the bankruptcy trustee that additional measures
would be necessary to bring the site under control. Later
in 1984. the contractors removed approximately 100 drums
containing liquid caustic waste. On October 2. 1985.
SCDHEC authorized Future Fuel Development. Inc., to
remove site soils contaminated with lead and chromium. A
total of 365 tons of soils were removed from various areas
on-site and placed in off-site landfills during 1985 and
1986.
In 1986, EPA conducted a preliminary assessment of the
site. Based on the results of the assessment, EP A proposed
the site for inclusion on the National Priorities List (NPL)
in June 1988. The NFL identifies the most serious
abandoned or uncontrolled hazardous waste sites that
warrant further investigation to determine if they pose a
threat to human health and/or the environment. Sites
included on the NFL are eligible for clean-up funds under
the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA, more
commonly known"as "Superfund") of 1980 as amended by
the Superfund Amendments and Reauthorization Act
(SARA) of 1986. The Palmetto Recycling site was
formally added to the NFL on October 4, 1989.
In 1992, EPA negotiated with parties it bad identified as
Potentially Responsible Parties (PRPs) for the site to
conduct the RI/FS. An agreement was not reached between
EP A and the parties. Therefore, EP A conducted RI Field
activities at the Site from April 1993 through June 1993
and March 30, 1994 through July 25, 1994.
The RI field activities were as follows:
. .
Conducted a land survey to establish the
topographic variations across the site.
Installed twelve (4 shallow, 4 intermediate,
and 4 deep) monitoring wells;
Collected groundwater samples from the
monitoring wells;
Collected surface soil samples from 24
locations that included one background
surface soil sample;
.
Collected 62 subsurface soil samples from 10
locations that included twelve background
subsurface soil samples;
Collected 3 surface water and 6 sediment
samples from onsite and offsite locations;
.
Surveyed monitoring wells and sampling
locations;
Conducted Private Well/Water Use Survey
within a one-mile radius of the site; Each
available resident was surveyed to determine
the type of water supply and the uses of the
water;
Performed water level measurements in the 12
monitoring wells to determine the
groundwater flow direction. Two staff gauge
measurements were used to determine the
water level of Dry Fork Creek.
5
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Performed an Ecological screening to identify
endangered and threatened species within the
site area. The screening was performed by
contacting local, state and federal agencies
concerning the wildlife and natural resources
in Richland County. The data from these
agencies were collected, reviewed and
summarized as part of the field effort
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 eighty-six (86) soil, twelve (12) groundwater, three
(3) surface water, and six (6) sediment samples were
collected (see Figures 3,4,5 and 6). More detailed
information can be found in the RI and FS reports, and in
the Baseline Risk Assessment.
Soil Contamination. One contaminant of concern, lead was
detected above the background concentration of 15.1 ppm
in 78% of the non-background surface soil samples. Levels
of the lead ranged from 6.3 ppm to 6400 ppm. Lead
concentrations, detected at all of the sampling locations
exceeded the health risk-based concentration of 400 ppm,
in six of the surface soil samples. A level of 400 ppm and
below is designed to protect children from developing blood
lead levels above 10 ug/dl. All of the other inorganics
detected above baseline were detected very near the
baseline concentration and do not appear to have
significantly impacted the surface soil at the site. One
volatile organic 1,2-dichloroethane was detected at a level
of 0.0076 ppm (7 ppm is the screening level). Because 1,2-
dichloroethane was detected at a very low concentration,
volatile organics do not appear to significantly impact the
surface soil at the site.
Groundwater Contamination. Three contaminants of
concern, chloroform, arsenic, and chromium were detected
above the background concentration. Chloroform was
detected in only one sample at 6 ppb, which was below the
Maximum Contaminant Level (MCL) of 100 ppb.
Although, the MCL for chloroform was not exceeded, the
chloroform level of 6 ppb did exceed the health risk-based
concentration that was derived in the Baseline Risk
Assessment in one sample. Levels of the arsenic were
detected in two samples and ranged from 19 ppb to 38 ppb,
which were below the MCL of 50 ppb. Although, the MCL
for arsenic was not exceeded, the arsenic level of 38 ppb
did exceed the health risk-based concentration that was
derived in the Baseline Risk Assessment in one sample.
Levels of chromium were detected in six samples and
ranged from 3 ppb to 25 ppb, with two samples being
detected above the background concentration of 5 ppb, and
all samples being detected below the MCL of 100 ppb.
Although, the MCL for chromium was not exceeded, and
only two samples were detected above the background
concentration, the chromium levels did exceed the health
risk-based concentration that was derived in the Baseline
Risk Assessment. Based on the results of the Baseline Risk
Assessment, remedial goal options were identified for
chloroform, arsenic and chromium. . However,
concentrations of these chemicals of concern in the
groundwater at the site were well below the Federal
Drinking Water Standards of 100 ppb, 50 ppb and 100
ppb, respectively. In addition, due to the low frequency of
detection for each of the contaminants, there is no evidence
of a groundwater plume at the site. Consequently, the
contaminants have not significantly impacted the
groundwater at the site.
Surface Water Contamination. There were no contaminants
of concern identified for surface water and therefore this
medium was dropped from the risk analysis. However,
dieldrin was detected in the truck scale excavation pit
surface water sample. The concentration measured was
very low and therefore, while some potential impact is
indicated by the presence of this one pesticide, it appears
that contamination has not significantly impacted surface
water. None of the inorganics that were detected in the
truck scale excavation pit were at significant concentrations
compared to Federal Drinking Water Quality Standards. Six
inorganics were detected in the one stream surface water
sample collected downgradient of the site. However, none
of these inorganics were detected above background
concentrations.
Sediment Contamination. Sediment analyses indicate that
inorganic chemicals are present at levels above background.
It appears that the constituents which were detected above
background are concentrated in the portions of the stream
system situated between the background location and
downgradient location, suggesting that the downstream
extent of impacts has been successfully estimated. Nickel
and vanadium appear to be the most widespread
constituents detected above background. Consequently, the
contaminants have not significantly impacted the sediment
at the site.
-------
LEGEND
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COLUMBIA, SOUTH CAROLINA
FIGURE No.3
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FIGURE No.4
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COLUMBIA, SOUTH CAROLINA
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SUMMARY OF RISK ASSESSMENT
CERCLA directs EP A to protect human health and th.e
environment from current and potential future exposure to
hazardous substances at the site. A risk assessment was
conducted to evaluate the potential current and future risks
associated with exposure to the site contaminants. .
Human Risk
An evaluation was made of all potential exposure routes
which could connect contaminants of concern (COC's) at
the Site with people living. or working in the area.
Exposure by each of these pathways was mathematically
modeled using generally conservative assumptions.
The Baseline Risk Assessment (BRA) for the Site was
prepared by Roy F. Weston, Inc. for EPA Region IV. The
BRA was imalized in November, 1994. EPA determined
as a result of the risk assessment that potential future
exposure to lead in surface soils was of concern and stated
that remediation of surface soil would be required for the
protection of human health and the environment It should
be noted that the risk levels incorporated both site-related
and background-risks, since some contaminants existed in
the study area naturally.
EP A determined as a result of the risk assessment that
potential future residential exposures to chlorofonn, arsenic,
and chromium in groundwater were of some concern.
However, due to the low frequency of detection for each of
the contaminants, and the fact that the concentrations of
these contaminants are well below the Federal Drinking
Water Quality Standards, groundwater remediation will not
be required for the protection of human health. Based on
the current use scenario, the Baseline Risk Assessment
concluded that non
-------
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will remain. Because hazardous contaminants would remain,
a five (5) year would be required The No Action
Alternative would only involve the continued monitoring of
the soil and groundwater quality at the site. Groundwater
monitoring would be accomplished utilizing existing
monitor wells. These wells would be sampled for lead on
a quarterly basis for tbe first five years and annually for a
remainder of twenty-five years. Soil monitoring would
consist of swface soil sampling for the same parameter and
frequency. Public health assessments would be conducted
every five years and would allow EP A to assess the
ongoing risks to human health posed by the site. The
evaluations would be based on the data collected from soil
and groundwater monitoring.
The present worth costs of Alternative I are estimated to be
$704,000.
ALTERNATIVE 2 - LIMITED ACI10N
This alternative is identical to the No Action Alternative
(Alternative 1) described above except that it includes
implementation of institutional measures to control, limit,
and monitor activities onsite. The objectives of institutional
actions are to prevent prolonged exposure to contaminant
concentrations, control future development or excavation at
the site, and prevent the installation of water supply wells
within the boundaries of the site. These objectives are
accomplished by monitoring soil and groundwater at the
site and limiting use and access by placing fences and deed
restrictions on all properties within potentially contaminated
areas. The effectiveness of institutional actions depends on
their continued. implementation.
Soil and groundwater monitoring can be used to evaluate
the effectiveness of any remedial action in controlling
releases from the site. Fences and deed restrictions are
designed to prevent access/exposure to soil by limiting what
can be done at the site. Restrictions would be placed on
the site to limit its future use. This could be accomplished
by recording in the property deeds that potentially
hazardous surface soil is located on the property and that
use restrictions have been imposed. If implemented
correctly, they provide low-cost moderate protection against
direct contact with contaminants. Deed restrictions and
fences are potential mechanisms to limit and monitor
activity on the propeny, and ensure that all contact wilh
potentially contaminated surface soil is regulated and
monitored.
------._---~....:..c.....c.:":':-"'''~:,c......~..,.",~-~
The present worth costs of Alternative 2 are estimated to be
$761,000.
ALTERNATIVE 3 . EXCAVATION AND OFFSITE
DISPOSAL
Alternative 3 includes excavation of swface soil that
exceeds the remediation level and disposal in either a
RCRA landfill or a solid waste landfIll. Conventional
excavation will be used to remove the top one foot of soil.
The soil will be Toxicity Characteristic Leaching Procedure
(TCLP) tested. If the soil exceeds the Land Disposal
Restrictions (currently 5 ppm for lead), then the soil will be
transported to a RCRA Subtitle C disposal facility. Prior to
disposal, the facility will pretreat the soils using a
stabilizer/solidifier such as a cement or pozzolan based
agent If the soil'does °not exceed the 5 ppm restriction, it
can betransponed to a Subtitle D solid waste landfill and
disposed of directly without pretreatment. The excavated
area would be backfilled with clean topsoil.
Groundwater monitoring on an annual basis, for at least five
years, would be required to evaluate site progress.
The present worth costs of Alternative 3 if TCLP results
determine that Ihe 0 soils are to be transported to a RCRA
Subtitle D facility (nonhazardous landfill) are $241,000.
The present worth costs of Alternative 3 if TCLP results
determine that the soils are to be transported to a RCRA
Subtitle C facility (hazardous landfiIl) are $940,000.
COMPARATIVE ANALYSIS OF ALTERNATIVES
EP A has established criteria for use in comparing the
advantages/disadvantages of each alternative. The
alternatives are evaluated against one another by using the
nine criteria on Ihe following table. The nine evaluation
criteria fall into three groups: threshold criteria, primary
balancing criteria, and modifying criteria.
The following discussion compares the various alternatives
to the criteria.
OveralI Protection of Human Health and the Environment
Regarding surface soil concerns, Alternatives I and 2 do
not eliminate exposure pathways and reduce the level of
risk. However, Alternative 2 minimally reduces the level of
human risk by way of deed restrictions and fencing.
.12
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r_~.1'''''''''--
- ---;- -- .
..c.I-""'-""""'r~...:..._':.~'.---""""~"'~~ "~6' . £"""'~........-~..:..c-""';'''''''''~~~~''''~V.J'\':~
Alternative 1 and Alternative 2 do not limit migration of or
remove existing surface soil contamination. Alternative 3
eliminates exposure pathways and greatly reduces the level
of risk. In addition, Alternative 3 removes contamination
and eliminates further migration.
Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs)
Alternatives 1 and 2 will not meet chemical-specific
ARAR's for surface soil. Under Alternative 3, ARAR's
will be met through excavation and offsite disposal at a
properly designed facility.
Cost
A swnmary of the present worth cost which includes the
capital as well as the operation and maintenance cost for
each of the alternatives is presented within the explanation
of the alternative. Greater detail is provided in the
Feasibility Study.
Implementabilitv
The implementability of an alternative is based on technical
feasibility, administrative feasibility and the availability of
services and materials. All components of each alternative
are both technically and administratively feasible.
Alternative 1 and 2 can be implemented immediately
because fencing and monitoring equipment are readily
available. For Alternative 2 in administrative terms,
implementing this alternative may have its difficulties.
Access restrictions are subject to changes in political
jurisdictions, legal interpretations,. and regulatory
enforcement. As properties change hands, it is imperative
that owners are informed of the deed restrictions and abide
by them. Alternative 3 can be implemented. Excavation
and landfill disposal are proven technologies. There is an
identifiable RCRA Subtitle C facility that can properly treat
and dispose of the soils. Access to Subtitle D facilities is
also available. Excavation of the surface soil requires only
conventional equipment
Reduction of M/TN Through Treatment
Alternatives 1 & 2 do not achieve reduction in M/T/V of
the contaminants. Alternative 3 wiIl only reduce the
mobility of the contaminants.
CRITERIA FOR
EVALUATING
REMEDIAL
ALTERNATIVES
111 ulecting G preferred cleanup
aUernotWe, EPA U8e8 the following
criterio to er1caluate eacla of Uae
aUernatWe. deoeloped in Uae
Feasibility Study (FS). The fint
two criterio ore ell_tiol GIld mud
be met before 011 aUernotWe i8
COllllidered further. The nest (We .
ore used to further eoGluote all
OptWlIII that meet the fint two
criteria. The filial two criterio ore
ulled to further eoaluate EPA'.
propoaed pion offer the public
comment period lacu ended GIld
commenta (rom the community GIld
the State hcwe beell receioed. All
nine criterio ore ezploined in more
detoil here.
.OveraU Protection or Bam&D Health
aDd the Eoviroameot - ~ degree
to whlcb alternative eUminatell, reduc:es,
or cootrols health and eoviroomeotal
tbreats througb treatmeot, engineering
methods, or Instltotional controls.
"
.Compliaoce with AppUcable or
Relevant and Appropriate Requlrementll
(ARABs) - AssesaeII compliance with
Federal/State requiremeot&
.Cost- Weigblog orbeoefitll or a remedy
against the cost of implementation.
.Implemeotabllity - Rerel'll to the
technical reaslbility and admbustrative
ease or a remedy.
.Short-Term EfI'ectlveoess - Leogth of
time ror remedy to acbleve protection
and potential impact or eonstructloo
and implementatloo or the remedy.
.Long.Term Effectiveness and
PerfonnaDCe - Degree to which a
remedy can malntalo protectloo or
health and environmeot once cleanup
goals have heeo met.
.Reductioo of Toziclty, MoblUty, or
Volome Through Treatmeot - Refel'll to
expected performance or the treatmeot
technologies to lessen hannCul nature,
movement, or amouot or contamioBots.
.State Acceptance - Conslderatloo or
State's opinioo or the prefen-ed
alternatives.
.ComlDunity Acceptance ..
Consideration or public comments on
the Proposed Plan.
13
-------
"~-- ....... . .-~_~I.~##"_-~_..
"""'C ".J ...... '::";'''''M.:r-...:..:.;.:.......'';'/...<'~~~~~''',;.o....:,,-...~....:.Go..~~:.GI"~..::.v..,.....~....JoQo':~~'''''''' 'J -.. .~ "-":'.""""'''--~'''''.
~,~~'Io;
Short Term Effectiveness
During the implementation of all the alternatives, both
onsite workers and people sunounding the site will be
protected when sampling the various media during
review/reassessment every 5 years, when installing a fence
around the site and from possible impacts caused by
excavation activities. Risks from soil excavation and
removal would be addressed in health and safety plans.
There is no risk to the environmental receptors from
implementation of any remedy, although, habitats could be
disrupted during excavation activities.
Long Term Effectiveness and Permanence
The continued exposure of onsite receptors to surface soils
is a potential long-term impact for Alternatives I and 2.
The remediation level derived for protection of human
health and the environment would not be met by
Alternatives I and 2.
State Acceptance
The State of South Carolina's Department of Health and
Environmental Control was consulted during the drafting of
this Proposed Plan. They are in support of the Alternative
selected in this Proposed Plan.
Community Acceptance
The purpose of this Proposed Plan and the upcoming
comment period is to encourage input from the public
during the remedy selection process. Community
acceptance of the preferred alternative will be evaluated
after the public comment period and will be described in
" the Record of Decision for the Site.
EPA's PREFERRED ALTERNATIVE
In"summaJy, based on the information available at this time,
EPA is proposing Alternative 3: Excavation and Offsite
Disposal. Alternative 3 includes excavation of surface soil
that exceeds the remediation level (of 400 ppm) and
disposal in either a RCRA landfill or a solid waste landfill.
Conventional excavation will be used to remove the top one
foot of soil. The soil will be Toxicity Characteristic
Leaching Procedure (fCLP) tested. If the soil exceeds the
Land Disposal Restrictions (currently 5 ppm for lead), then
the soil will be transported to a RCRA Subtitle C disposal
facility. Prior to disposal, the facility will pretreat the soils
using a stabilizerlsolidifier such as a cement or pozzolan
based agent If the soil does not exceed the 5 ppm
restriction, it can be transported to a Subtitle D solid waste
landfill and disposed of directly without pretreatment. The
excavated area would be backfllled with clean topsoil.
Groundwater monitoring on an annual basis, for at least five
years, would be required to evaluate site progress.
This alternative represents the best balance among the
criteria used to evaluate remedies. Alternative 3 is believed
to be protective of human health and the environment,
would attain ARARs, would be cost effective, and woUld
utilize permanent solutions and alternative treatment
technologies or resource technologies to the maximum
extent practicable.
Based on comments received from the public during the
upcoming comment period, EP A, in consultation with
SCDHEC, may later further modify the preferred alternative
or select another remedial alternative presented in this
Proposed Plan. .
OPPORTUNITIES FOR PUBLIC
INVOLVEMENT
EP A has developed a community relations program under
Superfund to respond to citizens' concerns and needs for"
information as well as to enable residents and officials of a
site community to participate in the decision-making
process. Before EP A carries out or authorizes technical
work on a site, EP A staff and/or EP A contractors prepare
a Community Relations Plan (CRP) based upon
discussions in the community with local leaders and private
citizens. This plan identifies the techniques EP A will use to
commWlicate effectively with the community during the
remedial process. These communication efforts often
include telephone contacts, small informal meetings or
fonnal public meetings, news releases, correspondence and
fact sheets. The CRP is available for review at the site
information repository.
EPA establishes an administrative record and an
infonnation repository where reports and other documents
are made available to citizens. The administrative record is
a file which contains all information used by EP A to select
a response action for the site under the CERCLA. A
duplicate file is maintained at the Region IV EPA Office in "
Atlanta, Georgia. The information repository is a file that
contains current information such a technical reports and
reference documents regarding the site. The information
repository documents can be reviewed at the library listed
below. For information regarding the documents
maintained in the administrative record and information
repository, visit the library listed below or contact the EPA
commWlity relations coordinator for the site.
- 14
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. .~-''':'':-'',,';'' "".---"6'........................~.,It..'~~""'--~"'~"-""""''''''''''''''''.'-~'''''~''.4''".'..:'-:':..:.::'"~:':":.':...'.. .'';';'':':'''..;.... -.."" --.."X"..-~..--..-;r...;>-...c..~...~.....-..~..,-~..;"':":"':'-":'.w:__-.:-.o..:.:..:..;,,'.r..:"..""''''''~''
"""L'..'........."'~..
You are encouraged to visit the infonnation repository and
contact EPA and SCDHEC representatives listed in this
document for additional infonnation. EPA would also
accommodate requests for infonnal meetings during the
public comment period, to further explain the fIndings of
the RI/FS and the Proposed Plan. Individuals interested in
arranging briefmgs should contact EPA's Conununity
Relations Coordinator for the Site. .
TECHNICAL ASSISTANCE GRANTS ARE AVAILABLE
To assist conununities in interpreting the technical fIndings
at Superfund sites, conununities may apply for Technical
Assistance Grants of up to $50,000. Congress and EPA
have established requirements for the use of this grant
Citizens who are interested in a TAG may contact Ms.
Cynthia Peurifoy at 1-800-435-9233.
FOR FURTHER INFORMATION
Remedial Proiect Manager
Yvonne Jones
U.S. Envirorunental Protection Agency
345 Courtland Street, NE
Atlanta, Georgia 30365
(404) 347-7791 EXT. 4122 or (800) 435-923J .
CommunitY Relations Coordinator
Cynthia Peurifoy
U.S. Envirorunental Protection Agency
345 Courtland Street, NE
Atlanta, Georgia 30365
(404) 347-7791 or (800) 435-9233
Regional TAG Coordinator
Rosemary Patton
U.S. Envirorunental Protection Agency
345 Courtland Street, NE
Atlanta, Georgia 30365
(404) 347-3931 Ext 6107
South Carolina Project ManalZer
Adrienne Felder
South Carolina Department of Health & Environmental Control
2600 Bull Street
Columbia, South Carolina 29201
(803) 734-5487
Administrative Record and Information Repository
Northeast Regional Library
7490 Parklane Road
Columbia, SC 29223
(803) 736-6575
HOURS
Monday - Thursday
9:00 am - 9:00 pm
Friday & Saturday
9:00 am - 6:00 pm
- 15
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GLOSSARY
Administrative Record - A me which is maintained and contains all infonnation used by the EP A to make its decision on the
selection of a response action under CERCLA. 1bis file is required to be available for public review and a copy is to be
established at or near the site. usually at the infonnation repository. A duplicate me is maintained in a central location such
as a regional EP A 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. from taxes on chemical and petroleum companies. to investigate and clean up abandoned or uncontrolled hazardous
waste sites.
Feasib~lity Study (FS) - 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 Ranking System (HRS) - A scoring system used by EP A and the state to evaluate relative risks to public health and
the environment. A score is calculate based on actual or potential release of hazardous substances through the air. soils. surface
water or groundwater. If the site scores above 28.5, the site is proposed for inclusion on the National Priorities List
Information Repository - Materials on Superfund and a specific site located conveniently for local residents.
Maximum Contaminant Levels (MCLs) - The maximwn pennissible level of a contaminant in water that is consumed as
drinking water. These levels are determined by EP A and are applicable to all public water supplies.
National Priorities List (NPL) - EPA's list of uncontrolled or abandoned hazardous wastes sites eligible for long-term clean
up under the Superfund Remedial Program.
National Oil and Hazardous Substances Contingency Plan (NCP) - The Federal regulation that guides the Superfund
program.
Noncarcinogens - Substances that may cause other adverse health effects besides cancer.
Parts Per Billion (ppb)/Parts Per Million (ppm) - Units commonly used to express low concentrations of contaminants. For
example, I ounce of Chloroform in I million ounces of water is 1 ppm. If one drop of Chlorofonn's are mixed in a competition
sized swimming pool. the water will contain about I ppm Chlorofonn.
. 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.
-16
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.............-~~N"~"""~""~""';':--........~........o1.....~~
Public Comment Period - Time provided for the public to review and comment on a proposed EPA action or rulemaking after
it is published 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 DesignlRemedial 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 (RIfFS) - Two distinct but related studies, nonnally conducted together.. intended
to deime the nature and extent of contamination at a site and to evaluate appropriate, site-specific remedies.
Reasonable Maximum Exposure (RME) - A tenn used in the Baseline Risk Assessment. The RME is the highest exposure
to contaminants that is reasonably expected to occur at a site as is based on the professional judgement of the risk-assessor.
Responsiveness Summary - A summary of oral and/or written public comments received by EPA during a comment period
on key EPA documents and EPA's responses to those comments. The responsiveness summary is especially valuable during
the Record of Decision phase at a site on the National Priorities List when it highlights community concerns for EPA decision-
makers.
Resource Conservation and Recovery Act (RCRA) - A Federal law that establishes a regulatory system to track hazardous
substances from the time of generation to disposal. The law requires safe and secure procedures to be used in treating,
transporting, storing and disposing of hazardous substances. RCRA is designed to prevent the creation of new uncontrolled
hazardous waste sites.
Superfund Amendments and Reauthorization Act (SARA) - Modifications to CERCLA enacted on October 17, 1986.
Volatile Organic Compounds (VOCS) - Organic compounds which easily change from a liquid to a gas when exposed to the
atmosphere.
-17
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-_.-.-.-..._--_........._-_...~_...._.._~.....
.
---..--.'.....-:.. ",:,,,.....---.....,,,,!,~_.
I. ------'.......,'..'..;,',.....-.'-..'.'..'.~. '.'....' ,.I.
PALMETTO RECYCLING SUPERFUND SITE MAILING LIST COUPON
If you have had a change of address and would like to continue to receive site related
information or would like for EP A to add your name and address to the mailing list
for the Palmetto Recycling Superfund Site, please complete this self-addressed form.
If you have any questions regarding this mailing list, please call Cynthia Peurifoy at
1-800-435- 9233. .
NAME:
ADDRESS:
TELEPHONE: (
)
USE TInS SPACE TO WRITE YOUR COMMENTS
Your input on the Proposed Planfor the PaJmetto Recycling Super:fund Site is important in helping
EPA select afinal 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.
r: -
-------
~..-..~.~h.~<~ -~~........;.~/~~..;.::rh"'';'~'''';;W;~,,;.r,,,;,:,.''',j~-::.,..:-;r....~~/;c..:;.~''~W.:",':,:,;.:';~":':~..c;::";'.;~'~':;'~.'......;..~y;.,:.":t=.::.~:. :-:...:.-:.r~:;~...'''';'..,:,':''!- .' ','.- ,: '..:.~.."":.':;/ ':"~' :.':.'.'.."""":'.'~ ~......~.....,;"..._~6t .
I
-
PALME'lTO RECYCLING SUPERFUND SITE
PROPOSED PLAN PUBLIC COMMENT SHEET
------------------------------------------------------------------..----.---------......-...--...-..
------------------------------------------------------------------------------------------
Fold on dashed lines, staple, stamp and mail
Name
A~
~
State _Zip-
1=1
R-
Cynthia Peurifoy, Community Relations Coordinator
North Superfund Remedial BranchfWaste Division
U. S. EPA, Region 4
34S Courtland Street, NE
Atlanta, GA 30365
-------
Attachment B
Public Notices of Public Comment Period and Extension
of Public Comment Period
,
[ .
-------
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'.11"
'.
".', .
"'..1... " ..'; .;......,. ;""')~""'''''''''''''' ..' N"'" '. . ,'.' D . A",; ,,~~. ,,,' \' <1i!ii£i;.".;.",~..w~-(!...,UraM.t:t""'~1;F<"> ""NV'J:'&!'Ji~~1,;,;!'1[:' ;;(..," ,.',." .," . ;..
. '.' T ., .' , ..,; ~. .'~ . .'i:~~...~~vc~~,.~~:"".;~~i:O~~J~.V~1.,~wl~~b...NiJlli~t!g~~S~'~~f.ffJl~1!nr3:1l1JL?H.~MVlUtaW\~~tt5,\ti~}~f.~:~":'i- ~:~',./.:;",".fJ.r':';':r.1"
. '..'....' :' . .' ,;;:. '.' ~~',~:..'r)f;~~:~;'~';;~>'~;!":;}C"""~~"}ft~
'EYR'Of "E,:: ;I'y,;.'";'''
, ,', 'THEtSTATE' ," , ,'; ',', .
-\'..
UNITED STATES ENVIRONMENTAL
PROTECTION AGENCY
!111£O sr~~
~ ~"
. ..... .
~j
PUBLIC COMMENT PERIOD
Proposed Remedial Action Plan for the
PALMETTO RECYCLING SUPERFUND SITE
Columbia, Richland County, South Carolina
November 22 - December 22, 1994
PUBLIC MEETING
TUESDAY, DECEMBER 6,1994,7:00 p.m.
Fairlawn Community Center
9128 Wilson Boulevard
~olumbia, South Carolina
The U.S. Environmental Protection Agency (EPA) has developed a Proposed Plan for remediation of contaminated soli at the
Palmetto Recycling Superfund Site. The Proposed Plan summarizes the results of the Remedial Investigation of the Site and
the alternative cleanup methods evaluated under the Feasibility Study. Three alternatives were studied: Alternative I . No
Action, which provides only for continued monitoring of the Site: Alternative 2 . Limited Action, which' provides for
Institutional measures to control, limit, and monitor activities at the Site; and Alternative 3 . Excavation and OlTslle.Dlsposal
of contaminated 5011. After evaluating the alternatives against nine criteria, EPA and the South Carolina Depsrtment of
Heal.th and Environmental Control have IdentJned Alternative 3 as the preferred cleanup method. This alternative provides
for excavation of surface son that exceeds a contaminant level of 400 parts per million and disposal of the soli In an olTslte.
landOIl. .'
The Proposed Plan and other Site documents are available at the Palmetto Recycling Superfund Site Information Repository
in the Northeast Regional Library at 7490 Park Lane Road, Columbia, SC, (803) 776-0855. CItizens are encouraged to review
the Proposed Plan and comment on It during the Public Comment Period, which opens on November 22 and closes on
December 22. EPA.may extend the Public Comment Period by 30 days If they receive a timely request for extension.
EPA will hold a Public Meeting on Tuesday, December 6 at 7:00 p.m. to present the Proposed Plan, answer questions, and
discuss concerns. Interested citizens are encouraged to attend the Public Meeting, whlcb will be held at the Falrlawn
Community Center. Questions about the Site can be referred to Cynthia Peurlfoy, EPA Community Relations Coordinator, at
t.800-435.9233. Written comments should be postmarked by December 22,1994 and directed to:
Yvonne Jones, Remedial Project Manager
U.S. Environmental Protection Agency
345 Courtland Street, NE .
Atlanta, GA 30365
4081)'''''
. : ,;',:,; NOVEMBER 21.1994".
. ,.. '."". . . . ..; "", ~ ..,
':(:".'
..
I. .
-------
SUNDAY, DECEMBER
A20
THE STATE, COLUMBIA. S.C.
IJNITEP STATES ENVIRONMENTAL
PROTECTION AGENCY
EXTENSION OF PUBLIC COMMENT PERIOD
Proposed Remedial Action Plan for the
; PALMETTO RECYCLING SUPERFUND SITE
Columbia, Richland County, South Carolina
November 22,1994 - January 23,1995 -
The. U.S. Environmental -.Protection Agency (EPA) has extended the Public Comment Period for the
Proposed Plan for remediation of contaminated soil at the Palmetto Recycling Superfund Site. The Public
Comment Period, whith opened on November 22 -and was scheduled to close on December 22, will close on
January 23, 1995. - . ' -
The Proposed Plan summarizes the results of the Remedial Investigation of the Site and the alternative
cleanup methods .evaluated under the Feasibility Study. Three alternatives were studied: Alternative 1 - No
Action, which provides only for continued monitoring of the Site; Alternative 2 -Limited Action, which
provides for institutional measures to control, limit, and monitor activities at the Site; and Alternative 3 -
: Excavation .and Offsite Disposal of contaminated soil. After evaluating the alternatives against EPA's nine
. criteria, EPA and the South Carolina Department of Health and Environmental Control have identified
Alternative 3 as the preferred cleanup method. This alternative provides for excavation of surface soil that
: exceeds £ contaminant level of 400 parts per million and disposal of the soil in an ofTsite landfill. The
. estimated present worth cost of this alternative is $241,000 (nonhazardous waste landfill) to $940,000
. (hazardous waste landfill). , "
Proposed Plan and other Site documents are available at the Palmetto Recycling Superfund Site
;J£fonnation Repository in the Northeast Regional Library at 7490 Park Lane Road, Columbia, SC (803) 776-
• •Citizeris are encouraged to review the Proposed Plan and comment on it during the Public Comment
••/,' . ' . •• • . " . •
••,•'..-•••' ••,-•. -. ••
?ite can be referred to Cynthia Peurifoy, EPA Community Relations Coordinator, at 1-
comments should be postmarked by January 23, .1995 and directed to: •:-,-.
v .,- Yvonne Jones, Remedial Project Manager
"-• :U,S. Environmental Protection Agency .
345 Cburtland Street, NE .
Atlanta, GAS 30365- . '-~
-------
Attachment C
Written Public Comments Received
During the Public Comment Period
-------
South Carolina
DHEC
Commissioner: Douglas E. Bryant
Department 01 Health and Environmental ContrOl
Robert Mills Complex, Box 101106
Columbia. SC 29211
Board: Richard E. Jabbour. DDS. Chairman
Robert J. Stripling. Jr. Vice Chairman
Sandra J. Molander. Secretary
William E. Applegate. III.
John H.. Burriss
Tony Graham. Jr.. MD
John B. Pate. MD
Promoting Health. Protecting the Environment
Memorandum
TO:
Lovyst L. Luker
Project Administrator
A TSDR . Cooperative Agreement
Division of Health Hazard Evaluation
William T. Going, MPH~
Environmental Quality Manager
A TSDR Cooperative Agreement
Division of Health Hazard Evaluation
FROM:.
DATE:
January 10, 1995
RE:
Palmetto Recycling Record of Decision
.f:'&:
Attached are my comments for the Environmental Protection Agency's (EPA) draft Record
of Decision (ROD) for the Palmetto Recycling site. The EP A released the draft ROD on
November 22, 1994 to the public for comments by December 22, 1994. However, the EPA
granted the public an extension for comments with a deadline of January 23, 1995.
Overall the ROD appears to be in line with the public health assessment. The ROD proposes
to remediate surface soil that exceeds EPA's remediation levels for lead. The contaminated
soil will be disposed of in a Resource Conservation and Recovery Act (RCRA) landfill or in
a solid waste landfIll. The excavated area will be backfilled with clean topsoil. It also
proposes groundwater monitoring on an annual basis, for at least five years.
I feel like the soil. excavation is needed. However, I also feel that the proposed remedy will
not address public health concerns. related to off-site soil contamination or groundwater
contamination. I recommended that the EP A strengthen the remedy to include testing of
private drinking water wells and community education for groundwater. I also recommend
that additional off-site soil samples be collected from residential yards and from the dirt road
that borders the site to the east. I feel that these samples are needed to fully characterize the
extent of contamination at the site.
-------
. ... .. . ....
. . ". . .~. "..., ...' " , ."'..'
COMMENTS FOR THE DRAFf RECORD OF DECISION
PALMETIO RECYCLING SITE
The South Carolina Department of Health and Environmental Control under cooperative
agreement with the Agency for Toxic Substances and Disease Registry, submits the following
comments for the draft Record of Decision, dated November 22, 1994, for the Palmetto
Recycling site in Richland County, South Carolina.
1.0 SITE LOCATION AND DESCRIPTION
1)
. .
Paragraph 1. Second Sentence.
Please verify the longitude coordinate defmed for the site. It appears that it should be
reported at 81000'43".
2.0 SITE HISTORY AND ENFORCEMENT ACTMTIES
2)
Please insert the following narrative between the fourth and fifth paragraphs on
page 4:
In 1988, .SCDHEC under a cooperative agreement with the Agency for Toxic
Substances and Disease Registry (ATSDR), released a preliminary health assessment
for the Palmetto Recycling, .Inc. site. The site was classified as a potential public
health hazard based on the limited available data at the time. The preliminary health
assessment recommended that additional investigations be completed to better
characterize the site classification and to assess public health concerns.
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
3)
Please define the "XXXX" in the last sentence of the first paragraph.
5.0 SUMMARY OF SITE CHARACTERISTICS
4)
Page 5, 2nd sentence in paragraph that continues from previous page.
This sentence states that 86 soil samples were collected during the Remedial
Investigation (RI) and the last sentence of this paragraph states that the majority of the
work was performed in April 1993, June 1993, March 1994, June 1994, and July
1994. However, the draft RI report states that 69 soil samples were collected. Later
in the ROD (page 14, 5.3 Nature and Extent of Contamination, Surface Soil Samples,
paragraph 1), the ROD states CDM collected 69 soil samples and the EPA collected
1
-------
17 soil samples. However, it does not explain the rationale as to why, where, and
when the EP A samples were collected after the remedial activities were completed.
In addition, the same sentence states that 3 surface water samples were collected and
the draft RI states that 2 surface water samples were collected. Was the sample taken
after the draft RI? If so, when and where was this sample collected and why was it
collected?
6.0 SUMMARY OF SITE RISKS
5)
The EP A should give greater consideration to the groundwater pathway even though
the baseline risk calculations do not indicate that the contaminants in this pathway
pose an adequate risk to h~an health. This recomm
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. '. ,.,' . '. '.'.'.'.'. .'. .............- ..'~~~'~'_.::. .'..'":-';.,,.'..;... '''.' .. .'. '.' " '.'
7.3 ALTE~ATIVE 3 - EXCAVATION AND OFF SITE DISPOSAL
7)
The groundwater monitoring program under this option should be expanded to include
testing of area private drinking water well residents who desire this testing.
Community education should be considered to meet concerns expressed by the
community about the quality of their drinking water.
8)
We concur with the selected remedial activity - the excavation of on-site soil. .
However, we would like to see the community concerns of off-site soil contamination
and groundwater contamination more adequately addressed.
~:.
3
-------
Ml
M
\
LEGEND
«— fENCE
• IREELWE
A COM FEDERAL SURfACE SOIL
SAMPtt IOCA10NS
• EPA SURFACE SOI
SAMPLE LOCA1IONS
EXTENT OF CONIAWNA1ION
APPnOXIMATET.
CONTAMINATION ABOVE REME
COLUMBIA-
i\ ?:» *™^»^*»-* •'»:
LBAD S()|l
-------
South Carolina
DHEC
Commissioner: Douglas E. Bryant
Board: Richard E. Jabbour, DDS, Chairman
Robert J. Stripling, Jr" Vice Chairman
Sandra J. Molander, Secretary
John H. Burriss
William M. Hull, Jr" MD
Roger Leaks, Jr.
Burnet R. Maybank, III
Department of Health and Environmental Control
2600 Bull Street, Columbia, SC 29201
Promoting Health, Protecting the Environment
January 12, 1995
Ms. Yvonne Jones
Remedial Project Manager
USEPA
345 Courtland Street, NE
Atlanta, GA 30365
Dear Ms. Jones:
RE:
Proposed Plan Fact Sheet (November 1994)
Draft Record of ~isio:l (ROD) November 1994
Palmetto Recycling' NPL Site
SCD 037 398 120
Richland County
The above referenced documents for the Palmetto Recycling site have been reviewed by
the Department. Comments from Jim Bowman, SCDHEC Hydrologist, are attached in a
memorandum to Adrienne Felder.
PROPOSED PLAN FACT SHEET
1.
Page 5. Correct the date April 25, 1994 in the third paragraph, column one. It
should be rewritten as April 25, 1984.
2.
Page 11. Alternative 1 - No Action. Please review sentences two and three of
this section. Some rewording may be necessary for clarity.
3.
Page 13. Reduction of M/T/V Through Treatment. Please spell out M/T/V.
4.
Page 14. Short Term Effectiveness. Please review the first sentence in this
section. Some rewording may be necessary for clarity.
5.
Page 15. The correct phone number for Adrienne Felder, South Carolina Project
Manager, is (803) 896-4071.
DRAFT RECORD OF DECISION
1.
Page iv. Table of Contents. The title of Section 7.0 - Description of
Groundwater Remedial Alternatives should be rewritten as Section 7.0 -
Description of Soil Remedial Alternatives.
o ,,,cycl,,d pap",
-------
Ms. Yvonne Jones
January 12, 1995
Page 2
DRAFr RECORD OF DECISION
.5.
2.
Page 4. Third paragraph, fifth sentence. Correct the date to state April 25,
1984.
3.
Page 27. The fourth sentence in the second complete paragraph should be
rewritten for clarity.
4.
Page 37. Please define the .acronym TBC in the third paragraph of section 9.1.
. . .
Page 38. TWo ~tions .of 9.1.2 - ARARs appear on .page 38. The second
section of 9.1.2 should be section 9.1.3 - Performance Standards. Section 9.1.3
should include more discussion on soil excavation and confirmation soil sampling
following "the excavation to verify that soil remaining on site does not exceed
400 ppm.
6.
Page 40. Table 3 (Continued). The rationale for soil discusses protective blood
lead levels for children as 18 mg/dl. The protective blood lead levels for children
should be 10 ugl dl.
7.
Page 45. Section 10.0 - Documentation of Significant Changes should be
renumbered as Section H.O.
Please contact me regarding a letter of concurrence from the State of South Carolina.
If I can be of further assistance, contact me at 803/896-4071.
Enclosure
cc:
SA~:J1dt1
Adrienne Felder
Site Engineering Section
Division of Site Engineering & Screening
Bureau of Solid & Hazardous Waste
Management
Jim Bowman
R. Gary Stewart
-------
. ' ,
a, "._.""---,,,-".I"."""-~-~~."--~_._.''''--_U'
. ".,-.. .. ,..." -. .. .. .'-- Po -'-., -.'., ,-... '
.' .... .p- ......;..... - __"A ',',' ";0-,., ..............-..~,....,...'t'....
South Carolina. .
DH.EC'
Comrnlaloner: Douglas E. Bryant
Board: Richard E. Jabbour. DDS. Chainnan
Robert J. Stripling, Jr ~ Vice Chairman
Sandra J. Molander. Secretary
John H. Burriss
William M. Hull. Jr. MD
Roger Leaks. Jr.
Burnet R Maybenk, III
Department of Health and Environmental Control
2600 Bull Street, Columbia, SC 29201
Promoting Health, Protecting the Environment
RECEIVED'
TO:
MEMORANDUM
JAN 11 1995
FROM:
DATE:
RE:
Adrienne Felder, Engineer
site Engineer~ng section
Division of site Engineering and Screening
Bureau of Solid and Hazardous Waste Management
Jim Bowman" HYdrOlogist. 9 f3
Superfund SectioQ
Division of Hydrogeoiogy
Bureau of Solid and Hazardous Waste Management
SITE ENGINEERING & SCREENING
BSHWM
January 9, 1995
November 1994 and
dated November 16, 1994
Proposed Plan Fact Sheet dated
Draft Record of Decision (ROD)
Palmetto Recycling NPL Site
SCD 037 398 120
Richland County, South Carolina
'~~.
The Division of Hydrogeology has completed a review of the
above-referenced documents for the Palmetto Recycling NPL site.
Our comments on these documents are provided as follows:
A.
PROPOSED PLAN FACT SHEET
1. Site Backqround; 3rd Paraqraph. page 2: The Fact Sheet states
that five groundwater monitor wells, installed by Raymond Knox
Consultants, are located onsite. However, in September 1981, the
month in which these five wells were installed~ Raymond Knox was an
employee of the Groundwater Protection Division of the Department.
These five wells were installed by a contractor hired by Palmetto
Recycling, but this contractor was not Raymond Knox. Please
correct the statement concerning the five wells. We also recommend
that EPA state the purpose of the, five original monitor wells so
that these wells are not confused with the monitor wells that were
installed as part of the Remedial Investigation (RI).
SF950021.JAB
-------
B.
DRAFT ROD
1. Section 1.0. Site Location and Description. Second ParaaraDh.
paae 1: The Draft ROD states that five groundwater monitor wells,
installed by Raymond Knox Consultants, are located.onsite. Please
refer to Comment A.1. of this memorandum for our correction to this
statement in the ROD concerning the five. monitoring wells.
2. section 3.0. Hiahliahts of Community Participation. Daae 5:
Information regarding the extension to the public comment period
should be included in the second and third paragraphs of this
section. .
3. section 7.3. Alternative 3- Excavation and Off-Site Disposal.
page 33 and Section 9.1. Surface Soil Remediation. paae 37: These
sections should state that the soil excavation will be followed up
with soil testing for lead. The purpose of the soil testing is to
ensure that excavation is successful in removing lead cont~ination
above the remediation level (400 ppm) in the surface soil.
4. A list of references that are cited in Draft ROD should be
provided at the end of the document.
I.
SF95002LJAB
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JHH aa •«> ib = M p-2/5
AWT
Room B2060
Sencr ABtxnay 131 Morroom Road
Baekfig Rdfl*. NJ 07920
906 20*0435
FAX 908.aM-aS65
January 20,1995'
VIA FACSIMILE
Ms. Cynthia Peurifoy
U.S. Environmental Protection Agency
North Superfund Remedial Branch
345 Courtland Street, NE
Atlanta, Georgia 30365
Re: Palmetto Recycling Superfund Site
Dear Ms. Peurifoy:
As we discussed yesterday, I herewith provide AT&Ts comments on
the proposed plan for the subject site.
General Comments
In the Feasibility Study (FS) it is suggested at one point that the
remediation of toad-contaminated surface soil should be focused on the
removal of "hot spots." Elsewhere in the FS and in the proposed plan it Is
recommended or implied that gross excavation of soil take place. It is
recommended that the documents be revised to consistenUy suggest limited
hot spot removal.
The conclusion regarding ecological concerns contains the vague
recommendation that a further ecological study "may be necessary." It is
AT&Ts view that since the potential for adverse ecological effects is low. the
recommendation should be that further assessment is not warranted.
' R«cydeil PifMr
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............._~;.:..;-;.;......;.,..:..:.. ........'.."..."...:' .:........."-'.'_..::.._.....~..-..I"."'J'":''''''''';''',c;.:....'....;..;.,..-.:",.,.:"....;.;,.,;..,.......,..;,.~~.,~~", ,'. .. .
". '.... :..,::'~'.....'........." ,. ,.,. '.A"....."".,..."..'...:-..~'4;.~.l:'.....".:~',..~~'"
~.
~~
~
Ms. C. Peurifoy
01 f2C195
Page 2
~
'-'5
~
3-1
3-5
5-3
Specific Comments
Location
Final RQmedialinvesugatlonlFe8sibility Study Report
Comment
'H'
1}2
Table 3-1
Table 5-1
This section states that the amount of dust detected
at \he site did not vasy fram background conditions.
The amount of dust detected would not,be expected
to vSl'/. It i~ the incidence of leed absorbed to the
dust particlea that would be the measure of '
concern. Can a ooncentration of lead in the dust be
assumed to, evaluate the potential for eJiposure due
to alrbofne concentrations?
One background soil location will not adequately
desaibe background concrrtions. The numbsi' of
backgroln:t samples collected should be ,
statistically de!:&nnined as desaibec:l in Risk
Assessment Guidance for Superfund.
Additionally, several sa/Tlp!es collected from one
bOrehole do not constitute different backgrol.lXl
sampling locations. No solid borings were
conducted in the former suspected dumping IRa.
For completeness, subsurface soli conditions
should have been evaluated in this area.
~ was no well cluster installed north of well
cluster #3 to monitor gtOLn1water downgradient of
the suspected liquid waste"dlJl:nping area? "
..,..",- '.'...
,'.'.' - ....'..~ ,..-.. '.' , "'.
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.." ".'. "4_.~_"'~_. ... ...................,..._...~.......J"--"'.I'.JO"':-~.'''':'-'''"..:"'.',,..~,...'.'.<,... .....'.. ,..,.,., . ,.."
,-. . .. ,"-P....-,'..'
. ..'..'.'.",.. '...,. ,
Ms. C. Peurifoy
01120/95
Page 3
f!9!
Location
Comment
~ 8-13
Table 8-5
The logic far using 400 mgIkg as the cleanup goal
for lead in the surface soil is not oonaistent with the .
guidance OSWER Directive #93-55.14-2 in which it .
is suggested that the UBK model be run iteratively
until the acceptable blood lead levels and
papulation effects alB reached (10 ug/dl and 5%,
respectively), In the FS. the average lead
concentration (528 mgJkg) was used as input to the
model, as opposed to the 95% UCl concentration
(1,968 mgIkg).
11-4
'2
This section states that a discount rate of five
percent for present wcr1tI estimates was used.
" Recent correspondenCe WIth USEPA had indicated
that a disool.l'lt rate c1 7 pen:ent for feasibility study
present worth estJm8te8 is anently being used.
Propo88d PIIn
~~~.
Soil excavation and off-site dispaMI ... hi onty remedial action
oonsldered for the site soils. Two ~ ... oonIidered within the soil
excavation and disposal alternative Opbon, ~ soil disposal at the
Subtitle D solid waste facility at an 88Dm8t8d pr8Mnt worth cost of
$241,000. Option 2 involves soil diIpOuI.. . RCRA Subtitle C facinty at an
est/mated present worth cost of $941.000 In h F888ibiUty Study, it was
~. stated that other altematives such .. .. Qt\-eIC8 tnNIIment were not
considered because the volume of 101 ~ ~ation (1,110 cubic
yards) fell short of the 2.000 cubic ywd o.A-df typICally used within the
industry to eveluate whether soi is ~ CCI8t -.c:ti.. treated on site or off
site. However, since there is a s~ ~ -.0.. In cost between Option
1 and Option 2 end since it is likelY '* .... IY'G'8 emenslve ODtion will be
reooired (i.e., excavated soils will ~ ". 5 mgI1 TClP level for lead),
AT&T believes that on-slte tre~ .,., ..... could prove cost
effective. We recommend TCLP t88tIng ~ .. IUI'fac8 soil at the site prior
to selection of the final remedy k) d8t8rfn,.. If .. .. can be disposed 81 a
Subtitle D solid waste facility. If,.... '** ... I'Ie soil can be
diapoSed at a SUbtitle D facility, ItIen .. 8IIP8 Ih8t \he excavation and off-
site disposal alternative is the moIII ~.......... ...., ..ti..e, If test resulta
~
-------
P. 5/5
Ms. C. Peurifby
01/20/95
indicate that the soil must be treated and disposed at the RCRA Subtitle C
facility, then we recommend that on-site treatment and disposal be
evaluated. Based on the depth and total volume of soil above the 400 mg/k0
action level, on-ste treatment by fixation/stabilization could be implemented
using conventional earth-moving equipment Fixation/stabilization is a well-
demonstrated technology for the treatment of lead-contaminated soil.
Although a detailed cost evaluation has not been performed, it is anticipated
that on-site treatment and disposal could be implemented at a present worth
cost of approximately $350,000. This alternative would satisfy EPA's
preference for treatment and would minimize lead exposure via contact with
surface soils while eliminating the need to transport soils off site for disposal
in a landfill.
Please address any questions you may have to me.
Very truly yours,
cc: J. McCarthy
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I -
Attachment D
Official Transcript of the Proposed Plan Public Keeting
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14
15
16
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18
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20
21
22
23
24
25
1
1
STATE OF SOUTH CAROLINA)
)
)
2
COUNTY OF RICHLAND
3
4
- - -
5
UNITED STATES E~VIRONMENTAL
6
PROTECTION AGENCY
7
REGION IV
8
PUBLIC INFORMATION MEETING
9
FOR THE PALMETTO RECYCLING, INC.
10
SUPERFUND SITE
13
- - -
FAIRLAWN COMMUNITY CENTER
COLUMBIA, SOUTH CAROLINA
TUESDAY, DECEMBER 6, 1994
7:10 P.M. - 9:20 P.M.
- - -
COURT REPORTER:
SHEILA STAGGS, CCR (GA)
HANWELL REPORTING SERVICE
920 MOHEGAN TRAIL
WEST COLUMBIA, SOUTH CAROLINA
(803) 791-4127
29169
HANWELL REPORTING SERVICE
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11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
1
APPEARANCES:
2
3
4
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET, N.E.
ATLANTA, GEORGIA 30365
BY: CYNTHIA PEURIFOY, COMMUNITY RELATIONS
BERNIE HAYES
YVONNE JONES, PROJECT MANAGER
JAN ROGERS
5
6
7
8
9
SOUTH CAROLINA DEPARTMENT
AND ENVIRONMENTAL CONTROL
2600 BULL STREET
COLUMBIA, SOUTH CAROLINA
BY: ENAYET ULLAH
ERIC MELARO
GARY STEWART
GAIL JETER
ADRIENNE FELDER
CRAIG MARRINER
JIM BOWMAN
29201
OF HEALTH
E X H I BIT S
* * *
(NO EXHIBITS WERE MARKED)
* * *
HANWELL REPORTING SERVICE
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3
1
MS. PEURIFOY:
GOOD EVENING EVERYBODY.
2
MY NAME I~ CYNTHIA PEURIFOY AND I'M THE COMMUNITY
3
RELATIONS COORDINATOR FOR E.P.A. REGION IV SOUTH
4
CAROLINA SECTION OR THE NORTH SUPERFUND REMEDIAL
5
BRANCH.
WE'RE HERE TONIGHT TO TALK TO YOU ABOUT
6
OUR WORK AT THE PALMETTO RECYCLING SITE.
WE'RE
7
HERE TONIGH~ TO PRESENT YOU THE PROPOSED CLEAN UP
8
PLAN FOR THE SITE.
AND TO RECEIVE YOUR COMMENTS
9
AND QUESTIONS.
10
TONIGHT'S MEETING PURPOSE AS I JUST SAID,
11
WE'RE GOING TO SUMMARIZE THE REMEDIAL
12
INVESTIGATION.
WE'RE GOING TO GIVE YOU THE
13
BACKGROUND OF THE SITE, THE FINDINGS OF THE
14
REMEDIAL INVESTIGATION.
WE'RE GOING TO SUMMARIZE
15
THE BASE LINE RISK ASSESSMENT AND WE'RE GOING TO
16
SUMMARIZE THE FEASIBILITY STUDY.
WE'RE GOING TO
17
PRESENT CLEAN UP. ALTERNATIVES AND THEIR COSTS.
18
AND WE'RE GOING TO PRESENT TO YOU OUR PREFERRED
19
ALTERNATIVE FOR THE CLEAN UP OF THE SITE.
20
AND LAST BUT CERTAINLY NOT LEAST WE'RE GOING
21
TO SOLICIT YOUR INPUT, YOUR COMMENTS, YOUR
22
QUESTIONS, YOUR CONCERNS.
23
OKAY.
WE'RE HERE BECAUSE THIS IS A
24
SUPERFUND SITE.
SO I WANT TO GO OVER WITH YOU A
25
LITTLE BIT THE SUPERFUND PROCESS.
THIS SITE HAS
HANWELL REPORTING SERVICE
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. 4
1
GONE THROUGH QUITE A BIT OF THE PROCESS.
WHEN A
2
SITE IS DISCOVERED IT UNDERGOES A PROCESS WHERE
3
IT IS RANKED.
AND IF IT RANKS AND IT SCORES A
4
SCORE OF 28.5 OR HIGHER IT IS LISTED ON THE
5
NATIONAL PRIORITIES LIST.
AT THAT TIME A
6
REMEDIAL INVESTIGATION IS DONE AND A FEASIBILITY
7
STUDY.
8
AND THERE YOU SEE BLOCK FIVE.
WE HAVE
9
PUBLIC COMMENTS.
AND THAT'S WHY WE'RE HERE
10
TONIGHT.
I'M GOING TO GO AHEAD AND TELL YOU A
11
LITTLE BIT ABOUT WHAT'S GOING TO HAPPEN NEXT.
12
AFTER TONIGHT'S MEETING WE'RE GOING TO GO BACK.
13
WE'RE GOING TO COMPLETE THE COMMENT PERIOD WHICH
14
IS EXTENDABLE FOR ANOTHER 30 DAYS IF WE RECEIVE
15
THAT TYPE OF REQUEST.
AND THEN WE'RE GOING TO DO
16
WHAT IS CALLED A RESPONSIVENESS SUMMARY.
THAT IS
17
A RESPONSE TO ALL THE COMMENTS THAT WE RECEIVE
18
DURING THE COMMENT PERIOD.
THAT BECOMES PART OF
19
BLOCK 6, THE RECORD OF DECISION, WHICH IS A
20
PUBLIC DOCUMENT THAT WILL BE ADDED TO THE
21
INFORMATION REPOSITORY.
AT THAT TIME WE WILL GO
22
INTO NEGOTIATIONS AND WE WILL START WORKING ON
23
THE DESIGN OF THE CLEAN UP PLAN.
THAT'S BLOCK 7
24
UP THERE.
AND THEN WE WILL GO INTO THE ACTUAL
25
CLEAN UP PROCESS.
HANWELL REPORTING SERVICE
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oJ
1
NOW, I WANT TO GO OVER WITH YOU A LITTLE BIT
. 2
OF THE COMMUNITY RELATIONS HISTORY OF THE SITE.
3
WE WERE HERE IN JUNE OF '92 AND WE CONDUCTED
4
COMMUNITY INTERVIEWS.
WE HAD A PUBLIC MEETING
5
HERE IN AUGUST OF '92.
AND WE FINALIZE OUR
6
COMMUNITY RELATIONS PLAN IN SEPTEMBER OF 1992.
7
SOME OF THE THINGS THAT WE PUT IN THAT COMMUNITY
8
RELATIONS PLAN THAT WE WOULD DO, WE WERE GOING TO
9
ESTABLISH POINTS OF CONTACT WHICH WE DID BY
10
LETTING YOU KNOW WHO I AM AND WHO THE PROJECT
11
MANAGER WAS FOR THE SITE.
WE HAVE A TOLL FREE
12
NUMBER THAT YOU SHOULD ALL HAVE IN YOUR FACT
13
SHEETS WHERE YOU CAN CALL US ANY TIME WITH ANY
14
QUESTIONS OR CONCERNS.
WE'VE HAD MEETINGS.
15
PUBLIC MEETINGS.
WE'VE DONE FACT SHEETS.
16
WE'VE PUT OUT NEWS RELEASES TO TRY TO KEEP YOU
17
UP-TO-DATE ON WHAT'S GOING ON.
AND WE'VE
18
ESTABLISHED AN INFORMATION REPOSITORY.
WE
19
MAINTAIN A MAILING LIST FOR THE SITE.
AND OUR
20
COMMUNITY RELATIONS PLAN CALLS FOR REVISION AS
21
NEEDED.
22
I WANT TO ALSO TELL YOU A LITTLE BIT ABOUT
23
TECHNICAL ASSISTANCE GRANTS.
WE SPOKE ABOUT THIS
24
WHEN WE WERE HERE BEFORE.
TECHNICAL ASSISTANCE
25
GRANTS ARE $50,000 GRANTS THAT ARE AVAILABLE TO
HANWELL REPORTING SERVICE
-------
b
1
COMMUNITY GROUPS THAT LIVE NEAR SUPERFUND SITES.
2
IT IS GIVEN TO HIRE A TECHNICAL ADVISOR TO HELP
3
YOU INTERPRET AND UNDERSTAND SITE RELATED
4
TECHNICAL INFORMATION SUCH AS THE INFORMATION
5
THAT'S GOING TO BE PRESENTED HERE TONIGHT.
6
COMMUNITY GROUPS DO HAVE TO CONTRIBUTE 20
7
AND THAT CAN BE DONE THROUGH IN KIND
PERCENT.
8
SERVICES SUCH AS VOLUNTEERING YOUR TIME, PUTTING
9
OUT NEWSLETTERS OR WHATEVER.
IT'S NOT TOO LATE
10
FOR A TECHNICAL ASSISTANCE GRANT.
I WILL BE MORE
11
THAN HAPPY TO WORK WITH YOU ANY WAY I CAN TO HELP
12
YOU TO GET THAT DONE SHOULD YOU SO DESIRE.
13
NOW, I 'WANT .TO INTRODUCE SOME PEOPLE TO YOU
14
WHO ARE HERE TONIGHT FROM E.P.A. AND ALSO FROM
15
THE SOUTH CAROLINA DEPARTMENT OF HEALTH AND
16
ENVIRONMENTAL CONTROL.
FIRST OF ALL FROM E.P.A.
17
THE PROJECT MANAGER FOR THE SITE IS MS. YVONNE
18
JONES.
SHE'S BACK HERE IN THE REAR. ' SHE'S GOING
19
TO BE SPEAKING TO YOU QUITE A BIT TO~IGHT.
OUR
20
SECTION CHIEF FOR THE SOUTH CAROLINA SECTION IS
21
MR. JAN ROGERS AND HE'S IN THE REAR ALSO.
AND WE
22
HAVE WITH US ALSO FROM E.P.A. MR. BERNIE HAYES
23
WHO'S ANOTHER PROJECT MANAGER IN OUR SECTION.
24
NOW, FROM OUR COLLEAGUES AT THE DEPARTMENT
25
OF HEALTH AND ENVIRONMENTAL CONTROL WE HAVE
HANWELL REPORTING SERVICE
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7
1
WE HAVE MS. GAIL JETER.
WE
MR. GARY STEWART.
2
WE HAVE MR. JIM
HAVE MS. ADRIENNE FELDER.
3
AND WE HAVE MR. ERIC MELARO.
AND WE
BOWMAN.
4
HAVE MR. ENAYET ULLAH.
5
NOW, I'M GOING TO TURN THE PRESENTATION OVER
6
TO MS. JONES AND I WOULD ENCOURAGE YOU TO ASK
7
QUESTIONS, GIVE US FEEDBACK HOWEVER YOU SO
8
PLEASE MAKE SURE THAT WHEN YOU SPEAK
DESIRE.
9
TONIGHT THAT OUR COURT REPORTER CAN HEAR YOU AND
10
IDENTIFY YOURSELF BECAUSE WE ARE MAKING A
11
THANK YOU.
TRANSCRIPT OF THIS MEETING.
12
BASICALLY I'M NOT
MS. JONES:
HELLO.
13
REALLY USED TO WORKING WITH A MIKE SO IF AT ANY
14
TIME THAT IT MAY APPEAR THAT YOU CANNOT MAKE OUT
15
WHAT I AM SAYING FEEL FREE TO RAISE YOUR HAND..
16
AND I'LL TRY AND SPEAK A LITTLE LOUDER.
17
BASICALLY WHAT I WOULD LIKE TO DO TONIGHT IS FOR
18
THE MOST PART SUMMARIZE THE SITE HISTORY, .SITE
19
IN. ADDITION TO
BACKGROUND AND THE SITE LOCATION.
20
THAT I WOULD ALSO LIKE TO GIVE YOU A BRIEF
21
SUMMARY OF WHAT WAS DONE DURING THE REMEDIAL
22
INVESTIGATION AND WHAT THE RESULTS WERE FROM THE
23
CAN EVERYBODY HEAR ME?
REMEDIAL INVESTIGATION.
24
OKAY.
25
BASICALLY AS EVERYONE KNOWS THE PALMETTO
HANWELL REPORTING SERVICE
-------
B
1
RECYCLING SITE IS LOCATED APPROXIMATELY 8 MILES
2
NORTH OF COLUMBIA, SOUTH CAROLINA, IN RURAL
3
RICHLAND COUNTY.
THE SITE IS POSITIONED BETWEEN
4
U.S. ROUTES 321 AND U.S. ROUTE 21 ON THE NORTH
5
SIDE OF KOON STORE ROAD.
6
FEATURES OF THE SITE ARE BASICALLY TO THE
7
EAST OF THE SITE YOU HAVE A DIRT ROAD.
I'M 'SURE
8
EVERYONE,IS FAMILIAR WITH DRY FORK CREEK.
'TO THE
9
NORTH OF THE SITE YOU HAVE AN UNNAMED TRIBUTARY
10
WHICH IS UPSTREAM OF DRY FORK CREEK.
AS FAR AS
11
THE SITE ITSELF THERE IS I GUESS APPROXIMATELY
12
130 BY 170 FOOT ASPHALT PAD ON WHICH MOST OF THE
13
PRODUCTION PROCESS TOOK PLACE.
THERE WAS AN
14
OFFICE BUILDING.
AND AS EVERYONE IS PROBABLY
15
AWARE OF, THERE WAS ALSO AN EXCAVATED PIT AREA
16
WHICH NOW HAS BEEN BACK FILLED WITH SOIL WHICH IS
17
KNOWN AS -- WE WOULD CALL IT THE FORMER TRUCK
18
SCALE AREA.
19
IN ADDITION TO THIS PARTICULAR FIGURE THIS
20
IS THE WORK SHED OR IT HOUSED THE WORK SHED WHICH
21
IS REALLY WHERE A LOT ,OF THE PROCESS TOOK PLACE.
22
I BEG YOUR PARDON.
THE
MS. BROWN:
23
WORK PLACE WAS THE BACK ONE BACK THERE, THE BACK
24
THAT'S WHERE ALL THE WORK WENT ON.
AND
BLOCK.
25
THEY HAD A CONVEYOR BELT THAT WENT FROM THERE
HANWELL REPORTING SERVICE
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9
1
OVER "TO THE SUMP TANK.
2
MS. JONES:
THANK YOU.
CAN YOU SEE
3
THE TANKS WHERE yOU ~RE?
4
MS. BROWN:
YES, I CAN SEE IT.
5
MS. JONES:
AND ALSO THE TANK SADDLE
6
WHICH WAS PART OF THE PROCESS. . BASED ON I GUESS
7
INFORMATION FROM A PREVIOUS WORKER .FROM THE SITE
8
THIS PARTICULAR AREA WAS CONSIDERED AS THE
9
DUMPING AREA.
IT CONSISTED OF THE AREA WHICH
10
HELD MATERIAL FROM BATTERY CASINGS, GROUND
11
BATTERY CASINGS.
12
MS. BROWN:
CASINGS BEING BURNED.
13
MS. JONES:
CORRECT.
AS FAR AS
14
LOOKING AT SOME OF THE SITE HISTORY OF THE SITE,
15
PRIOR TO 1979 FROM THE DATA THAT I HAVE BASICALLY
16
READ THE OVERALL AREA OR THE AREA SURROUNDING THE
17
SITE WAS CONSIDERED TO BE RURAL RESIDENTIAL.
IN
18
1979 THE PROPERTY WAS PURCHASED BY A COMPANY BY
19
THE NAME OF PALMETTO RECYCLING INCORPORATED FOR
20
THE PURPOSE OF OPERATING A BATTERY RECYCLING
21
COMPANY.
FROM 1979 TO 1983 THE FACILITY WAS
22
INVOLVED IN THE RECLAMATION OF LEAD FROM THE
23
BATTERIES.
AS PART OF THE RECLAMATION PROCESS OF
24
LEAD FROM THE BATTERIES BASICALLY I GUESS IN A
25
NUTSHELL LEAD WAS BASICALLY RECLAIMED FROM TH~
HANWELL REPORTING SERVICE
-------
10
1
BATTERIES.
. 2
I DON'T KNOW IF ANY OF YOU HAVE EVER LOOKED
3
IN A BATTERY.
IT ,LITERALLY CONSISTS OF AN OUTER
4
CASING WITH METAL PRONGS THROUGHOUT THE BATTERY.
5
AND SULFURIC ACID DOWN, IN THE BATTERY.
WHAT
6
WOULD ACTUALLY TAKE PLACE IS I GUESS DURING THE
7
PROCESS THE LEAD WAS RECLAIMED AND BASICALLY THE
8
SULFURIC WASTE JUST IN A NUTSHELL WAS YOU KNOW
9
DISCHARGED.
10
IN 1981 OR AROUND THE AREA OF 1981 THE
11
PALMETTO RECYCLING INC. AND REALLY JUST AFTER A
12
PERIOD OF DISCHARGE TO THE LOCAL SEWER BASICALLY
13
APPLIED FOR AN APPLICATION TO DISCHARGE HAZARDOUS
14
WASTE WHICH I THINK EVERYONE HERE PRETTY MUCH
15
THAT PARTICULAR APPLICATION WAS
KNOWS ABOUT.
16
DENIED BY DHEC.
AND IN 1983 THE FACILITY FILED
17
FOR BANKRUPTCY.
18
IN 1984 AS A RESULT --
19
MS. BROWN:
MAY I INJECT SOMETHING
20
RIGHT HERE?
21
MS. JONES:
OKAY.
22
FROM 1979 TO 1983 THE
MS. BROWN:
23
COMPANY WAS NOT OPERATING ALL THAT TIME.
24
CORRECT.
BUT THEY WERE
MS. JONES:
25
TRYING TO APPLY FOR A PERMIT.,
HANWELL REPORTING SERVICE
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11
1
MS. BROWN:
AND DURING THE TIME THAT
2
THEY DID TRY TO OPERATE THEY WERE OPERATING
3
WITHOUT THE FIRST PERMIT, PERIOD.
4
MS. JONES:
CORRECT.
IN FACT FROM MY
5
READING THEY WERE ALREADY DISCHARGING WHEN THEY
6
7
MS. BROWN:
DISCHARGING AND PUTTING
8
ACID, BATTERY ACID, OVER AT OLDHAM'S GARAGE ON
9
321 AS WELL AS ON THEIR OWN PROPERTY.
10
MS. JONES:
CORRECT.
I'M NOT REALLY
11
FOR SURE WHY THEY EVEN MADE THE STATE AWARE BY
OBTAINING A PERMIT.
MS. BROWN: WELL, WHEN WE FOUND THE
RED TRUCK GOING UP AND DOWN THE ROAD THE ONES OF
12
13
14
15
US THAT NOTICED IT IS THE ONES THAT CALLED DHEC'S
16
ATTENTION TO IT IS HOW THEY FOUND THE BATTERY
17
ACID BEING DISCHARGED INTO THE DRY CREEK BED.
18
MS. JONES:
OKAY.
I GUESS 1984 -- I
19
GUESS YOU REMEMBER THE FIRE THAT OCCURRED.
20
MS. BROWN:
1984.
YES.
THAT'S WHEN
21
THEY WENT DOWN THERE WHENEVER THE PEOPLE
22
CONSIDERED THEIRS ELF BANKRUPT AND TRYING TO SELL
23
SOME OF THE PROPERTY AND THEY SET THE SHED ON
24
FIRE.
25
MS. JONES:
CORRECT.
AS A RESULT OF
HANWELL REPORTING SERVICE
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12
1
THAT THE SHED THAT WAS COVERING I GUESS THE PIT
2
AREA WHICH HELD THE SULFURIC ACID -- BECAUSE IT
3
WAS NOT PROTECTED IT WAS BASICALLY LEFT dPEN FOR
4
CONTAMINATED WASTE TO MAKE ITS WAY INTO THE
5
SOILS.
TO ADDRESS THIS IMMEDIATE HEALTH AND
6
ENVIRONMENTAL RISK POSED BY THE SITE THREE
7
ACTIONS WERE CONDUCTED BY DHEC.
THE FIRST
8
REMOVAL TOOK PLACE IN APRIL OF 1984.
AND IT
9
CONSISTED OF THE REMOVAL OF 10,000 GALLONS OF
10
CONTAMINATED WATER. AND APPROXIMATELY 100 DRUMS
11
CONTAINING LIQUID WASTE.
12
13
IN OCTOBER OF 1985 -- AND OF COURSE THIS WAS,
AFTER THE SITE WAS REASSESSED.
THE STATE REMOVED
14
A TOTAL OF 365 TONS FROM THE SITE OF SOILS WHICH
15
WERE CONTAMINATED.
16
IN 1986 --
17
MS. BROWN:
DO YOU BY ANY CHANCE HAVE
18
A MAP SHOWING WHERE THAT CONTAMINATION WAS
19
REMOVED?
20
MS. JONES:
I HAVE THOSE MAPS BUT I
21
DON'T HAVE THOSE WITH ME.
BASICALLY THE MAPS
22
.THAT I HAVE ARE JUST ROUGH SKETCHES.
I CAN KIND
23
OF SHOW YOU ABOUT WHERE IT IS USING A POINTER.
24
BASICALLY FROM THE MAPS THAT WE HAVE SEEN AND
25
AGAIN THOSE MAPS WERE LITERALLY HAND DRAWN SO YOU
HANWELL REPORTING SERVICE
-------
13
1
CAN'T REALLY GET AN ACCURATE -- THEY WERE NOT TO
2
SCALE.
BASICALLY IT LOOKED" LIKE A LOT OF THE
3
SOIL WAS REMOVED FROM THIS PART OF THE AREA TO
4
MAYBE -- IT'S KIND OF HARD WITH THE LASER -- TO
5
MAYBE OVER HERE AND MAYBE DOWN TO HERE.
OR JUST
6
TO SUM IT UP, RIGHT AROUND THE ASPHALT PAD.
THAT
7
MIGHT BE THE EASIEST WAY TO SAY IT.
8
MS. BROWN:
WAS ANY TESTING DONE UNDER
9
THE ASPHALT PAD?
10
MS. JONES:
DURING THIS INVESTIGATION?
11
MS. BROWN:
YES.
DURING THAT
12
INVESTIGATION OR SINCE.
13
MS. JONES:
NO, MA'AM.
THERE WAS SOME
14
DONE DURING THE REMEDIAL INVESTIGATION CONDUCTED
15
IN 1992.
16
MS. BROWN:
UNDER THE ASPHALT?
17
MS. JONES:
CORRECT.
BUT NOT AT THE
18
TIME THE REMOVAL WAS DONE.
IN 1986 E.P.A."
19
CONDUCTED A PRELIMINARY ASSESSMENT OF THE SITE
20
AND BASED ON THE RESULTS OF THIS ASSESSMENT
21
E.P.A. PROPOSED THE SITE FOR INCLUSION ON THE
22
NATIONAL PRIORITIES LIST IN JUNE OF 1988.
IN
23
1989 THE PALMETTO RECYCLING SITE WAS FORMALLY
24
ADDED TO THE NATIONAL PRIORITIES LIST WHICH FROM
25
NOW ON I'LL PROBABLY SAY NPL ON OCTOBER 4TH,
HANWELL REPORTING SERVICE
i
I
-------
14
1
1989.
IN 1992 E.P.A. NEGOTIATED WITH POTENTIALLY
2
RESPONSIBLE PARTIES WHICH FROM NOW ON I WILL SAY
3
AND BASICALLY WHAT I MEAN ABOUT
PRP'S.
4
POTENTIALLY RESPONSIBLE PARTIES, THEY WOULD BE
5
PARTIES THAT EITHER GENERATED THE WASTE OR
6
TRANSPORTED THE WASTE TO THIS PARTICULAR SITE.
7
HOWEVER, AFTER A SERIES OF NEGOTIATIONS THOSE
8
BROKE DOWN AND E.P.A. BASICALLY CONDUCTED THE
9
REMEDIAL INVESTIGATION AND THE FEASIBILITY STUDY
10
WHICH AT THIS POINT I'LL START CALLING IT THE
11
RIfFS.
12
BASICALLY AS YOU PROBABLY ALREADY KNOW A
13
REMEDIAL INVESTIGATION LITERALLY IS A SITE
14
INVESTIGATION WHICH BASICALLY GOES OUT, TRIES TO
15
CHARACTERIZE THE SITE SO WE CAN DETERMINE WHAT
16
THE EXACT NATURE AND EXTENT OF THE CONTAMINATION
17
WHEN WE CONDUCT OR PERFORM A
IS AT THE SITE.
18
KNOWN AS AN FS BASICALLY THAT
FEASIBILITY STUDY
19
LOOKS AT DIFFERENT ALTERNATIVES ON HOW WE SHOULD
20
OR HOW WE CAN CLEAN UP THE SITE.
21
AND IN 1992 E.P.A. CONDUCTED RI FIELD
22
AND THAT OCCURRED IN
ACTIVITIES AT THE SITE.
23
SINCE THEN THE E.P.A. BAS GONE BACK OUT TO
1992.
24
THE SITE IN JUNE OF 1994 AND ALSO JULY 1994.
25
MR. FOGLE:
CAN YOU IDENTIFY THE
HANWELL REPORTING SERVICE
-------
15
1
PRP'S?
IS THAT THE BANK THAT WAS HOLDING THE
2
MORTGAGE FOR THE PROPERTY OR ARE ,YOU UNABLE TO
3
IDENTIFY THEM?
4
MS. JONES:
WELL --.
5
MS. BROWN:
BECAUSE I LEARNED THAT
6
AT&T HAD A PART OF, IT.
7
WELL, I GUESS I' MIGHT
MS. JONES:
8
LEAVE THIS QUESTION TO MR. ROGERS.
9
MR. ROGERS:
THE FIVE PRP'S THAT WE
10
WERE TALKING TO BACK EARLY ON ARE THOSE THAT HAD
11
BEEN IDENTIFIED AS HAVING SHIPPED SOME WASTE
12
THERE.
13
MR. FOGLE:
THESE WERE PEOPLE WHO
14
SHIPPED WASTE?
15
MR. ROGERS:
YES.
THE FACILITY
16
OPERATORS WERE IN BANKRUPTCY AND THERE WERE OTHER
17
THINGS THAT WE COULD NOT DO WITH SOME OF THOSE
18
PEOPLE.
WE'VE SINCE -- WELL, THIS WILL COME
19
LATER, BUT WE BASICALLY DO A LITTLE MORE THOROUGH
20
PRP SEARCH AS WE FINISH UP THE RECORD OF DECISION
21
AND PURSUE IMPLEMENTATION JUST TO ENSURE THAT
22
WE'VE LOOKED AT ALL AVENUES OF GETTING
23
RESPONSIBLE PARTIES TO DO THE WORK.
ON THE FRONT
24
END WE TYPICALLY DO A QUICK SURVEY IN ORDER TO
25
FIGURE OUT WHO'S LIABLE OR WHO'S MOST LIKELY
HANWELL REPORTING SERVICE
-------
. 16
1
INVOLVED AT THE SITE, TRY TO NEGOTIATE WITH THEM.
2
AND IF WE CAN'T REACH A CONCLUSION WE GO ABEAD
3
AND DO THE STUDIES SUCH AS WE'VE DONE HERE.
4
THERE WERE FIVE AND I DON'T KNOW THE NAMES OF
5
THEM.
YVONNE MIGHT REMEMBER SOME OF THEM.
6
THAT'S IN THE PUBLIC RECORD.
7
MS. JONES:
THAT'S WHAT I WAS
8
WONDERING, IF WE WERE ALLOWED TO --
9
MR. FOGLE:
IT'S IN THE RECORD.
10
I'M JOHN GRANT.
MR. GRANT:
THE
11
QUESTION WAS WHAT BANK HAS A MORTGAGE OVER THERE.
12
I BELIEVE THAT I'VE SEEN ON A TAX MAP THAT WHAT
13
BANK WAS INVOLVED.
I DON'T KNOW IF I CAN GET MY
14
HAND~ ON THOSE READILY.
BUT I THINK THAT DID
15
HAVE ALL THE PROPERTY COMING UP AND DOWN THE
16
NORTH SIDE, TWO BANKS.
17
MR. ROGERS:
THAT TYPICALLY -- THOSE
18
ARE THE KINDS OF RECORDS WE WOULD USE TO MAKE
19
SURE WE HAD A COMPLETE SEARCH IN TRYING TO
20
EVALUATE ALL THE PEOPLE THAT WE SHOULD TRY TO NOW
21
DEAL WITH TO SEE IF THEY WANT TO COME FORWARD AND
22
PARTICIPATE IN THE CLEAN UP OF THE SITE.
IT'S
23
REALLY TWO MAIN AREAS OF TIME WHEN WE PURSUE
24
THAT.
BEFORE WE INITIATE A REMEDIAL
25
INVESTIGATION AND THEN AFTER WE'VE DONE A RECORD
HANWELL REPORTING SERVICE
-------
17
1
OF DECISION WE PURSUE THAT AGAIN TO SEE IF
:2
SOMEBODY WANTS TO STEP IN AT THAT POINT.
3
MS. JONES:
DO WE NORMALLY OR
4
TYPICALLY RELEASE THE NAMES?
5
MR. ROGERS:
THEY'RE IN THE RECORD I
6
THINK.
7
MS. JONES:
DOES THAT ANSWER --
OKAY.
8
BASICALLY TO SUMMARIZE THE RI ACTIVITIES E.P.A.
9
COLLECTED 86 SOIL SAMPLES WHICH 24 OF THOSE WERE
10
--
11
WAS THIS THIS YEAR?
MS. BROWN:
12
SOME WERE TAKEN BACK IN
MS. JONES:
13
MAY OF 1992.
AND ADDI~IONAL SAMPLES WERE
14
COLLECTED IN JUNE OF 1994 AND IN JULY OF 1994.
15
TWELVE GROUND WATER SAMPLES WERE COLLECTED.
16
THREE SURFACE WATER SAMPLES WERE COLLECTED.
17
SOME ON SITE AND SOME WERE DOWNSTREAM OFF SITE.
18
SIX SEDIMENT SAMPLES WER~ COLLECTED AND SOME OF
19
THOSE WERE ALSO ON SITE AND OFF SITE.
20
IN ADDITION TO THAT, E.P.A. CONDUCTED A
21
PRIVATE WELL WATER USE SURVEY WITHIN I GUESS
22
APPROXIMATELY A MILE RADIUS OF THE SITE.
23
MS. BROWN:
WAS IT INDIVIDUAL WELL
24
WATERS, THE PEOPLE THAT YOU TALKED TO ABOUT THAT
25
OR JUST --
HANWELL REPORTING SERVICE
-------
18
1
MS. JONES:
INDIVIDUAL WELL WATERS.
2
WHEN YOU CONDUCTED THE
MS. BROWN:
3
PRIVATE WELL WATER USE DID YOU TALK TO
4
INDIVIDUALS IN THE AREA OF KOON STORE ROAD OR YOU
5
HAD KNOWLEDGE THROUGH THE CITY THAT SOME OF US
6
WERE ON CITY WATER NOW?
7
MS. JONES:
INDIVIDUALS WERE SPOKEN TO
8
ON KOON STORE ROAD.
9
DO YOU KNOW WHO THOSE
MS. BROWN:
.
10
PEOPLE WERE?
11
I HAVE A LIST OF THEM.
MS. JONES:
12
APPROXIMATELY 36 TO 42 PEOPLE.
AND SOME WERE
13
ALSO LOCATED ON WILSON BOULEVARD.
AND BASICALLY
14
WHAT WE HAVE IT IS A PART OF THE RECORD WHERE
15
EACH PARTICULAR RESIDENT HAD THEIR OWN I GUESS --
16
ALL OF US AT ONE TIME HAD
MS. BROWN:
17
OUR WELLS UNTIL WE WENT WITH CITY WATER.
18
THAT'S REALLY WHAT THE
MS. JONES:
19
SURVEY --
20
HE WAS TELLING ME THAT HIS
MS. BROWN:
21
I WAS TELLING HIM MINE IS
WAS STILL OPERATING.
22
NOT BECAUSE THE PUMP IS BROKE.
23
REAL QUICK I CAN SHOW YOU
MS. JONES:
24
BASICALLY THESE
WHERE THE SAMPLES WERE TAKEN.
25
WERE THE SOIL BORINGS THAT WERE TAKEN.
BANWELL REPORTING SERVICE
-------
19
1
THE BORINGS WENT HOW DEEP?
MS. BROWN:
2
MS. JONES:
I THINK OUR DEEPEST ONE
3
WAS DOWN TO ABOUT 58 FEET.
MS. BROWN: 58 FEET?
MS. JONES: CORRECT. AND BASICALLY --
MS. BROWN: WELL TYPE BORINGS?
MS. JONES: CORRECT. THANK YOU.
4
5
6
7
8
BASICALLY I GUESS REAL QUICK WHEN YOU SEE
9
SOMETHING LIKE BH-6 OR BH-4, THAT'S JUST OUR WAY
10
OF LABELING WHAT EACH OF THOSE LOCATIONS WERE.
11
MS. BROWN:
THE LITTLE INDICATOR UP AT
12
THE TOP TELLS WHAT THOSE DIFFERENT THINGS ARE
13
THERE.
14
MS. JONES:
CORRECT.
BASICALLY WE USE
15
THIS TO TRY TO DETERMINE WHAT THE GENERAL I GUESS
16
GEOLOGICAL FORMATION WE HAVE.
17
MS. BROWN:
PUT THAT BACK UP THERE A
18
I WANT TO POINT OUT SOMETHING.
IN THE
MINUTE.
19
AREA RIGHT IN THE BACK OF WHERE THE FENCE IS
20
THERE OFF OF THE SCALES, THE FENCED IN AREA
21
THERE, IN BEHIND THAT AREA IS THE AREA THAT YOU
22
HAD ON YOUR OTHER MAP THAT YOU FOUND BEFORE YOU
23
GOT TO THAT UNNAMED DRY CREEK BED BACK THERE IS
24
WHAT WAS
WHERE THEY BURNED THE BATTERY CASINGS.
25
THERE'S NO BORING THERE.
NO SOIL
FOUND THERE?
HANWELL REPORTING SERVICE
-------
20
1
SAMPLE THERE AT ALL.
2
WELL, BASICALLY -- AND I
MS;. JONES:
3
GUESS I SKIPPED OVER IT A LITTLE BIT.
I'M GOING
4
TO SHOW ABOUT FOUR OR FIVE MORE SEGMENTS THAT
5
WILL SHOW ALL OF THE SAMPLES THAT WERE TAKEN.
6
THIS IS JUST SHOWING WHERE THE BORINGS WERE
7
BASICALLY WE WERE THINKING IF WE TRIED TO
TAKEN.
8
PUT ALL THE LOCATIONS ON ONE FIGURE IT WOULD
9
REALLY CROWD IT TO THE POINT WHERE YOU COULDN'T
10
REALLY SEE.
11
MS. BROWN:
ANOTHER QUESTION.
THIS
12
COMPANY YOU HAVE STATED THAT THEIR ON 1.5 ACRES.
13
BUT THESE PEOPLE BOUGHT 20 ACRESS.
WAS
THIS IS.
14
THERE ANY TESTING DONE IN THE REST OR ANY PARTS
15
OF THE EXTRA 20 ACRES?
16
THERE WERE
MS. JONES:
NO, MA'AM.
17
BASICALLY WHAT WE WERE CONSIDERING THE SITE.
NOT.
18
AS FAR AS THE CONTAMINATED AREA WAS THIS.
REALLY
19
SOME OF IT CONCERNING OR SOME OF IT CONTAINING OR
20
BEING A PART OF THE UNNAMED TRIBUTARY, A LITTLE
21
BIT OF DRY FORK CREEK.. THERE IS A DRAINAGE DITCH
22
WHICH YOU CAN BARELY SEE FROM WHERE YOU ARE
23
PROBABLY.
AND THEN EVERYTHING WITHIN THIS
24
SQUARE, APPROXIMATE SQUARE.
25
MS. BROWN:
WHEN THEY WENT BANKRUPT
HANWELL REPORTING SERVICE
-------
1
2
3
4
5
6
7
8
9
10
11
12
1'3
14
15
16
17
I'
,
18
19
20
21
22
23
24
25
II
THEY LOST ALL OF IT, DIDN'T THEY?
NOT JUST THAT
1.5 ACRES.
MS. JONES:
CORRECT.
WELL, TYPICALLY
OR I SHOULDN'T SAY TYPICALLY BUT TRADITIONALLY
WHAT E.P.A. WILL DO WHEN THEY GO OUT TO A SITE
BASED ON PAST INFORMATION OR PAST DATA WHAT THEY
WILL DO OR EVEN WHERE SAY FOR INSTANCE WHERE THE
MAIN PROCESSORS WERE, FROM THAT STANDPO'INT E. P. A.
WILL ACTUALLY ,GO OUT AND TRY TO CHARACTERIZE THE
SITE.
IF IT LOOKS LIKE THE DATA IS LEANING
TOWARDS MAYBE A HIGHER LEVEL CONTAMINATION AS YOU
GO AWAY FROM THE SITE, THEN WE WOULD CONTINUE.
WE WOULD INCREASE OUR SITE BOUNDARIES UNTIL WE
FULLY HAVE DETERMINED THE EXTENT OF THE
CONTAMINATION.
MS. BROWN:
THE SOIL SAMPLES, THE
WELLS AND WHAT HAVE YOU ARE ON THE 1.5 ACRES? '
MS. JONES:
AND SOME OF
CORRECT.
THOSE ARE LOCATED ON THE --
MS. BROWN:
ON THE CREED BED AND ON
ACROSS THE ROAD.
MS. JONES:
OKAY.
IF YOU'D LIKE WE
CAN GO THROUGH THEM.
MR. ROGERS:
GO THROUGH THE REST OF
THEM.
HANWELL REPORTING SERVICE
-------
II
1
MS. JONES:
BASICALLY, AND I'LL JUST
2
SUM THIS UP REALLY REALLY QUICKLY SO I CAN SHOW
3
YOU WHERE THE OTHER SAMPLES WERE TAKEN.
WHAT WE
4
FOUND FROM TAKING SEVERAL SOIL BORINGS AND ALSO
5
WHEN WE INSTALLED THE 12 MONITORING WELLS, JUST
6
LOOKING AT THE OVERALL GEOLOGICAL PICTURE, THE
7
OVERALL AREA SEEMS TO BE A MIXTURE OF CLAY AND I
8
AND SILT BEING THE MORE POROUS.
SO
GUESS SILT.
9
WITH SILT BEING THE MORE POROUS AND THEN OF
10
COURSE CLAY LOCATED WITHIN THIS AREA AND THEN OF
11
AND REAL QUICK I'LL GO THROUGH
COURSE SAND.
12
WHERE THE SURFACE SOIL SAMPLES WERE TAKEN.
13
BASICALLY THERE WERE 24 SURFACE SOIL SAMPLES
14
TAKEN RANGING FROM A DEPTH OF ZERO OR FROM 1 TO
15
12 INCHES.
16
THE RE~SON WHY WE HAVE SS DASH WHATEVER THE'
17
NUMBER IS VERSUS PR DASH WHATEVER THE NUMBER IS
18
MAINLY THAT WAS OUR WAY OF DETERMINING WHEN THAT
19
SAMPLE WAS TAKEN.
THE SAMPLES LABELED SS DASH
20
WHATEVER THE NUMBER WERE TAKEN BACK IN MAY OF
21
1992.
AND THE SAMPLES LOCATED PR DASH WHATEVER
22
THAT NUMBER IS WERE THE SAMPLES TAKEN LATER THIS
23
PAST SUMMER.
24
AND AGAIN REALLY THIS IS JUST THE SAME
25
DRAWING SHOW THE SUB SURFACE SOIL BORINGS.
HANWELL REPORTING SERVICE
-------
23
1
MR. HICKS:
WHAT WAS DONE IN THE
2
TESTING THAT WAS DONE THIS YEAR?
3
MR. ROGERS:
THAT GETS SUMMARIZED
4
LATER ON.
. 5
MR. HICKS:
OKAY.
6
BASICALLY THERE WERE 12
MS. JONES:
7
AND AS YOU NOTICED
MONITORING WELLS INSTALLED.
8
IT'S REALLY A CLUSTER OF THREE WELLS IN FOUR
9
WHAT MAYBE AN I WOULD MEAN OR
DIFFERENT AREAS.
10
AN S WOULD MEAN OR A D WOULD MEAN, S JUST MEANS
11
IT'S A SHALLOW WELL.
AND IT'S PROBABLY DOWN TO
12
ABOUT APPROXIMATELY 20 FEET.
AND I IS CONSIDERED
13
AN I~TERMEDIATE WELL WHICH IS EVEN FARTHER DOWN.
14
AND THEN OF COURSE A DEEP WELL CAN GO ALL THE WAY
15
DOWN TO 50, 60 FEET.
BASICALLY .WE DO THAT TO TRY
16
TO GET A FEEL OF WHAT'S HAPPENING TO GROUND WATER
17
AT CERTAIN LEVELS INSTEAD OF JUST ONE LOCATION
18
WHERE WE HAVE ONE DEPTH.
19
AND OF COURSE THIS PARTICULAR FIGURE IS JUST
20
SHOWING WHERE THE SURFACE WATER SAMPLES WERE
21
COLLECTED AND THE SEDIMENT SAMPLES WERE COLLECTED
22
WITHIN DRY FORK CREEK AND THE UNNAMED TRIBUTARY.
23
SOMETHING I WOULD LIKE TO ADD, ONE OF THE
24
SURFACE WATER SAMPLES WAS COLLECTED IN THE
25
EVACUATION PIT OVER WHERE THE TRUCK SCALES WHICH
HANWELL REPORTING SERVICE
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1
YOU MENTIONED EARLIER.
BASICALLY I GUESS DUE TO
2
OR JUST AS A SAFETY PRECAUTION THERE WAS WATER IN
3
THAT PARTICULAR PIT.
BASICALLY TO SAVEGUARD TO
4
MAKE SURE THAT WE DIDN'T HAVE ANY PROBLEMS E.P.A.
5
WENT OUT AND TESTED THE WATER TO MAKE CERTAIN IT
6
WASN'T CONTAMINATED.
BASED ON THE RESULTS OF THE
7
WATER IT WAS PUMPED OUT AND BACKFILLED WITH CLEAN
8
SOIL.
9
MS. BROWN:
THE CLEAN SOIL CAME FROM
10
WHERE?
11
MS. JONES:
USUALLY WE'LL BRING IT IN.
12
AND OF COURSE IT IS TESTED JUST TO MAKE CERTAIN
13
IT IS NOT CONTAMINATED.
14
MR. ROGERS:
IT CAME FROM OFF SITE.
15
IT WAS TRUCKED IN.
16
MS. JONES:
WE WOULDN'T TAKE IT FROM
17
THE SITE ITSELF.
BASICALLY I GUESS TO ANSWER
18
MR. HICKS' QUESTION, BASICALLY THERE WAS SOIL
19
CONTAMINATION AND IT WAS MOSTLY IN THE AREAS
20
NORTHWEST AND SOUTHEAST OF THE ASPHALT PAD.
THE
21
MAIN CONTAMINANTS OF CONCERN WERE LEAD, WHICH WE
22
FOUND RANGING FROM 6.3 PARTS PER MILLION TO .6400
23
PARTS PER MILLION.
IN ADDITION TO THAT WE DID
24
HAVE ONE HIT OF 1,2-DICHLOROETHANE AT A RESULT OF
25
.0076 PARTS PER MILLION.
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1
MS. BROWN: WHY WOULD THEY BE USING
THAT? WHAT WERE THEY DOING. WITH THAT OUT THERE?
MS. JONES: BASICALLY IT'S NORMALLY
NOT NATIVE TO A LEAD BATTERY RECLAMATION PROCESS.
2
3
4
5
MR. ROGERS:
THAT'S SUCH A SMALL
6
CONCENTRATION.
IT COULD HAVE JUST BEEN USED IN
7
THE SHOP AREA AS A DEGREASER OR SOMETHING ELSE.
8
AN ARTIFACT THAT SHOWED UP IN SOME QF THE
9
SAMPLES.
10
MS. BROWN:
AS A DEGREASER YOU SAY?
11
MR. ROGERS:
I THINK THAT'S ONE OF THE
12
USES OF IT.
13
MS. JONES:
MAYBE TO PUT THIS IN A
14
LITTLE BIT OF PERSPECTIVE, WHEN YOU LOOK AT LEAD
15
WHICH IS 6.3 OR WE FOUND 6.3 PARTS PER MILLION TO
16
6400 PARTS PER MILLION, CURRENTLY E.P.A. HAS A
17
PROPOSED SCREENING LEVEL OF 400 PARTS PER MILLION
18
WHICH IS CONSIDERED SAFE AND PROTECTIVE.
19
BASICALLY 78 PERCENT OF OUR SAMPLES WERE BELOW
20
THE 400 LEVEL.
AND WE HAVE ONE SAMPLE WHICH IS
21
THE 6400 AND THEN ANOTHER ONE WHICH WAS 1500
22
PARTS PER MILLION.
23
MS. JONES:
IN ADDITION TO THAT THE
24
GROUND WATER WAS SAMPLED AND THE 12 WELLS.
WHAT
25
THE CONTAMINANTS OF CONCERN THAT WE FOUND OUT
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1
THERE WERE CHLOROFROM, ARSENIC AND CHROMIUM.
2
CHLOROFORM WAS FOUND AND DETECTTED AT 6 PARTS PER
3
IT WAS ONLY DETECTED ONCE OUT OF 12
BILLION.
4
SAMPLES.
ARSENIC WAS DETECTED TWICE AND THE
5
RANGE WAS FROM 19 PARTS PER BILLION TO 38 PARTS
6
CHROMIUM WAS DETECTED SIX TIMES AND
PER BILLION.
7
THOSE RESULTS RANGED FROM THREE PARTS PER BILLION
8
TO 25 PARTS PER BILLION.
HOWEVER, ON.L Y TWO OF
9
THOSE SAMPLES WERE CONSIDERED TO BE ABOVE
10
BACKGROUND.
11
WELL, IS THIS CONSIDERED
MS. BROWN:
12
THE PORTIONS OF THE BATTERY ACID, WHAT WOULD BE
13
IN BATTERY ACID NORMALLY?
14
CHROMIUM COULD BE.
MR. HAYES:
15
MAYBE CHROMIUM IS THAT
MS. BROWN:
16
MUCH, BUT ARSENIC AND CHLOROFORM?
17
ARSENIC, NO, IS NOT
MR. HAYES:
18
TYPICALLY ASSOCIATED WITH A BATTERY CRACKING
19
AND THE CHLOROFORM, THAT'S A LITTLE
OPERATION.
20
YOU WOULDN'T EVEN USE THAT
DIFFICULT TO EXPLAIN.
21
AS A DEGREASER OR SOLVENT AT A SITE LIKE THIS.
22
SO THAT ONE'S A LITTLE BIT OF A MYSTERY.
THE
23
CHROMIUM COULD VERY WELL BE RELATED TO THE
24
BUT THE OTHER TWO,
BATTERY CRACKING OPERATION.
25
THE ARSENIC COULD VERY WELL BE NATURALLY
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,
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
OCCURRING AS WELL.
MS. BROWN:
NATURALLY OCCURRING IN THE
SOIL OR WHAT? .
MR. HAYES:
YES.
ARSENIC IS NOT AN
UNCOMMON SOIL COMPONENT.
IT'S AN ELEMENT THAT'S
FOUND JUST AS A NATURAL COMPONENT OF SOILS IN
SOME PLACES.
PARTICULARLY IN THE PIEDMONT WHICH
I KNOW WE'RE SORT OF ON THE BORDER OF THE
PIEDMONT HERE.
BUT PIEDMONT SOIL SAMPLES OFTEN
CONTAIN A LITTLE ARSENIC.
MR. GRANT:
THIS IS JOHN GRANT.
WOULD
CHLOROFORM POSSIBLY BE USED TO START UP SOME
EQUIPMENT THEY MIGHT HAVE HAD?
MR. HAYES:
I DON'T KNOW.
I KNOW THAT
THERE ARE -- I DON'T KNOW THAT I'VE EVER SEEN
CHLOROFORM USED FOR THAT.
MAYBE YOU HAVE.
BUT I
ALWAYS THOUGHT IT WAS SOME SORT OF ETHER THAT
THEY USED.
MR. ROGERS:
CHLOROFORM IS MORE OF A
PRESERVATIVE.
YOU SOMETIMES SEE IT AS A
LABORATORY ARTIFACT.
HERE IT SHOWED UP IN THE
SAMPLE.
IT COULDN'T BE WRITTEN OFF AS A
LABORATORY ARTIFACT.
WE CARRIED IT INTO THE
DATA.
IT'S WELL BELOW ANY HEALTH BASED LEVEL OF
CONCERN IN GROUND WATER.
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1
MS. BROWN:
BOTH OF .THEM ARE WELL
2
BELOW?
3
CORRECT.
FOR CHLOROFORM
MS. JONES:
4
WE HAD SIX AND THE PROTECTIVE LEVEL IS 100.
SO
5
THAT'S 94 PARTS PER BILLION LESS.
FOR ARSENIC
6
OUR HIGHEST HIT WAS 38 AND THE LEVEL WAS 50 PARTS
7
AND FOR CHROMIUM THE HIGHEST HIT
PER BILLION.
8
WAS 25 PARTS PER BILLION.
AND THE LEVEL FOR THAT
9
WHICH WOULD BE CONSIDERED PROTECTIVE IS 100.
10
MS. BROWN:
THAT'S E.P.A. STANDARDS?
11
MS. JONES:
THAT'S FEDERAL DRINKING
12
WATER STANDARDS.
IT WAS CONSIDERED SAFE TO HAVE
13
IN YOUR DRINKING WATER.
14
MR. HICKS:
IF YOU CONTINUE TO DRINK
15
THIS WATER WITH THIS 19 PERCENT ARSENIC FOR A
16
PERIOD OF TIME IT WOULD HAVE SOME KIND OF EFFECT
17
ON YOU, WOULDN'T IT?
18
NO.
THE MCL STANDARDS
MR. ROGERS:
19
ARE BASED ON LONG-TERM EXPOSURES.
THERE'S BEEN
20
NO DEMONSTRATED ADVERSE HEALTH RISK RELATED TO
21
THOSE LEVELS.
22
MS. HICKS:
MY NAME IS LOVOLA HICKS.
23
THE 12 WELLS THAT YOU MONITORED, ARE THEY PRIVATE
24
RESIDENTIAL WELLS OR DID YOU GO DRILL THOSE WELLS
25
YOURSELF JUST FOR THE TESTING?
HANWELL REPORTING SERVICE
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MS. JONES:
THOSE WERE INSTALLED FOR
2
THE PURPOSES OF THE TESTING.
3
MS. HICKS:
DID YOU ACTUALLY GO OUT TO
4
THE RESIDENCE AND CHECK THEIR WELLS TO THE PEOPLE
5
ON KOON STORE ROAD?
6
MS. JONES:
7
MS. HICKS:
8
CORRECT.
DO YOU HAVE A LISTING OF
THE PEOPLE THAT YOU CHECKED THEIR WATER?
9
MS. BROWN:
10
EARLIER.
11
MR. ROGERS:
12
ANY PRIVATE WELLS.
13
MS. JONES:
14
MS. HICKS:
15
I HAD ASKED HER THAT
SHE ASKED DID YOU SAMPLE
NO, MA'AM.
YOU DUG YOUR OWN WELLS AND
YOU CHECKED YOUR OWN WATER?
16
MS. JONES:
17
HEARING, UNDERSTANDING.
18
MR. HAYES:
19
CORRECT.
I THINK I'M
THE WELLS THAT WERE
SAMPLED WERE DRILLED SPECIFICALLY FOR THE
20
INVESTIGATION.
21
MS. HICKS:
22
SO YOU DIDN'T GO OUT AND
CHECK THE RESIDENTS OF CONCERN IN THE SURROUNDING
23
AREA?
24
MR. HAYES:
25
NO.
ALL THAT WE DID WAS
TO CHECK TO SEE IF THERE WERE WELLS IN USE.
NONE
HANWELL REPORTING SERVICE
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1
OF THOSE WELLS WERE SAMPLED.
2
MS. HICKS:
THAT'S WHAT I WANTED TO
3
KNOW.
4
SO THE WELLS THAT ARE IN
,
MR. HICKS:
5
USE NOW YOU DIDN'T WHICH MEANS THERE'S A
6
POSSIBILITY THEY COULD BE CONTAMINATED ~LSO?
7
MS. JONES:
MAINLY --
CORRECT.
8
MR. ROGERS:
THAT'S NOT REALLY
9
CORRECT.
THE REASON WE DON'T USE PRIVATE WELLS
10
IS THESE WELLS ARE INSTALLED WITH VERY SPECIFIC
11
STANDARDS OF MATERIALS AND OTHER THINGS BECAUSE
12
THE CONCENTRATIONS YOU'RE LOOKING AT ARE VERY
13
SMALL.
IF WE GO OUT AND TEST YOUR PRIVATE WELL
14
WE MAY FIND A HIT SOMEWHERE IN THESE ACTUAL
15
NUMBERS, NOT THE MCL BUT THE ACTUAL NUMBERS OF
16
SOME MATERIAL THAT WE HAVE NO WAY OF EXPLAINING
17
BECAUSE WE DON'T KNOW HOW YOUR WELL WAS PUT IN.
18
IT COULD BE INTRODUCED BY CONTAMINANTS IN THE
19
TYPES OF MATERIALS THAT WERE USED IN THE WELL OR
20
ANY NUMBER OF OTHER WAYS IT WAS INTRODUCED IN THE
21
WELL.
WHEN WE DO A STUDY OF A SITE WE PUT IN OUR
22
OWN WELLS THAT WE NO ARE BASICALLY PRISTINE CLEAN
23
TO LOOK AT THE AQUIFER FROM SEVERAL DIFFERENT
24
LEVELS AROUND THE SITE IN THE PREDOMINANT
25
DIRECTION OF GROUND WATER FLOW.
AND WE USE THE
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31
1
WELLS TO CONFIRM THAT THAT IS THE DIRECTION OF
2
GROUND WATER FLOW.
AND IT ALSO TELLS US A
3
PICTURE OF WHAT'S UNDER THE SITE.
AND IF YOU
4
KNOW ANYTHING ABOUT SUPERFUND SITES, THERE'S A
5
GREAT DEBATE AS TO WHETHER WE'LL EVER BE ABLE TO
6
CLEAN UP AQUIFERS THAT ARE CONTAMINATED BECAUSE
7
IT DOESN'T FLUSH OUT OF THERE CLEAN .AFTER IT'S
8
BEEN THROUGH THERE.
SO THE WELLS ON SITE SHOULD
9
HAVE SHOWN SOME ELEVATED CONTAMINATIONS IF THERE
10
WERE IN FACT A BIG PROBLEM THAT HAD PASSED
11
THROUGH AND MOVED OFF SITE.
SO TYPICALLY WE
12
START ON SITE AND AROUND THE SITE LOOKING AT THE
13
GROUND WATER THERE, SEE IF THERE'S ELEVATED
14
CONCENTRATIONS AND THEN WE WOULD FOLLOW IT OUT.
15
IN THIS CASE WE DIDN'T FIND ANY.
AND IT WOULD BE
16
EXTREMELY UNUSUAL FOR THOSE MATERIALS TO WASH OUT
17
CLEAN IF THERE HAD BEEN WHAT WE WOULD CALL A
18
PLUME IN THE GROUND WATER THAT HAD GONE THROUGH
19
THE AREA FROM A DISCHARGE AT THE SITE AND THEN
20
MOVED DOWN GRADIENT.
SO IT'S VERY UNLIKELY THAT
21
YOU HAVE ANYTHING IN YOUR WELLS.
BUT WE DON'T
22
RUN OUT AND CHECK --
23
MS. BROWN:
BEFORE THAT COMPANY WENT
24
IN DOWN THERE THAT WAS WOODS.
A WOODED AREA.
25
NOW, HOW WOULD THAT ARSENIC. AND CHLOROFORM GET
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2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
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32
INTO THAT AREA UNLESS IT WAS USED IN THAT AREA?
MR. ROGERS:
CHLOROFORM IN THAT LOW A
CONCENTRATION COULD BE LIKE I SAY ANY NUMBER OF
THINGS.
IT COULD BE LABORATORY ARTIFACT.
IT
COULD HAVE BEEN INTRODUCED IN THE LAB.
WE DON'T
THINK SO.
WE DO RUN CONTROLLED SAMPLES.
BUT THE
ARSENIC, IT CAN BE NATURALLY OCCURRING.
THE
CHROMIUM TO SOME EXTENT CAN SHOW UP NATURALLY.
JUST BASED ON THE WAY WE HAVE TO TAKE THE SAMPLES
WE TAKE THE SAMPLE OF GROUND WATER AND WE CANNOT
FILTER IT.
SO IF IT HAS SUSPENDED SEDIMENT IN IT
IT CAN INTRODUCE ARSENIC HITS AND OTHER THINGS.
MS. BROWN:
ISN'T CHROMIUM CONSIDERED
A HEAVY METAL?
MR. ROGERS:
YES.
ARSENIC AND
CHROMIUM AND LEAD ARE ALL HEAVY METALS.
MR. HAYES:
JUST A LITTLE FURTHER,
THESE ~RE THE WELLS THAT WERE SAMPLED AS PART OF
THE INVESTIGATION.
AND THESE ARE WELLS AS JAN
SAID THAT WERE DRILLED SPECIFICALLY FOR THE
PURPOSES OF INVESTIGATION.
THEY ARE NOT DRINKING
. WATER WELLS.
THEY WERE NEVER USED FOR DRINKING
WATER WELLS.
THEY WON'T EVER BE USED.
BUT THESE
WELLS THAT ARE RIGHT ON THE SITE AS JAN SAID, IF
THERE WAS GROUND WATER CONTAMINATION IT WOULD BE
HANWELL REPORTING SERVICE
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1
IN THESE WELLS BECAUSE THAT'S WHERE THE
2
CONTAMINATION WOULD BE COMING FROM.
3
MS. BROWN:
AND THE FLOW OF THE LAND
4
FALLS THAT WAY ANYWAY.
5
RIqHT.
SO IF WE DON'T GET
MR. HAYES:
6
ANY CONTAMINATION AS WE DIDN'T IN ANY OF THESE ON
7
SITE WELLS THEN THE ODDS OF ANY WELL FARTHER AWAY
8
BEING CONTAMINATED IS VERY REMOTE, ALMOST NON
9
EXISTENT.
SO AS JAN WAS SAYING IF WE CHECK ON
10
SITE AND WE DON'T GET ANY GROUND WATER
11
CONTAMINATION FROM WELLS, THAT WE DRILL ON SITE
12
SPECIFICALLY FOR THAT PURPOSE, THEN THERE'S
13
ALMOST NO CHANCE THAT ANY OFF SITE WELLS WERE
14
CONTAMINATED FRO~ THE SITE.
15
MS. JONES:
I GUESS I NEED TO CORRECT
16
MY ANSWER TO YOUR QUESTION.
I ANSWERED CORRECT
17
THAT WE DID NOT TEST YOUR WELLS BUT WE DID TEST
18
WELLS ON SITE.
19
MS. HICKS:
SO YOU'RE TELLING ME FROM
20
1979 TO 1983 WHEN THEY OPERATED AND THEN YOU CAME
21
ALONG IN 1994 AND 1992 AND TESTED -- WHEN DID YOU
22
,DIG THOSE WELLS?
23
MS. JONES:
MAY OF 1992.
24
SO FROM '79 TO '83 WHEN
MS. HICKS:
25
THEY OPERATED YOU'RE TELLING ME THAT THE WATER
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1
COULDN'T HAVE TRAVELLED ANY PLACE ELSE, THE SOIL
2
COULDN'T HAVE GONE ANY PLACE ELSE, BUT REMAINED
3
IN THAT AREA?
4
MS. JONES:
BASICALLY THE
CORRECT.
5
GROUND WATER FLOW FOR THIS PARTICULAR SITE IS AN
6
AVERAGE OF LIKE .00 --
7
MS. HICKS:
WHERE DID YOU GET THIS
8
INFORMATION FROM, WHAT BOOK?
9
IT'S A CALCULATED NUMBER
MR. ROGERS:
10
FROM ACTUAL SAMPLES THAT WERE DONE.
11
THERE'S NO PLACE I CAN GO
MS. HICKS:
12
AND LOOK IT UP?
13
IT'S IN THE RECORDS.
MR. ROGERS:
14
IT'S IN THE E.P.A. RECORD.
15
THIS IS E.P.A.
DHEC DID
MS. BROWN:
16
HAVE MONITORING WELLS DOWN THERE AT ONE TIME.
I
17
DON'T KNOW WHETHER OR NOT THEY'RE STILL DOWN
18
THERE.
19
MR. ROGERS:
AS PART OF THE REMEDIAL
20
INVESTIGATION WE REVIEWED THE TECHNICAL DOCUMENTS
21
THAT ARE IN THE .RECORD CENTER.
THE REMEDIAL
22
INVESTIGATION SHOULD SHOW RESULTS FROM ANY GIVEN
23
WELL AND IT SHOULD SHOW ALSO HAVE PROBABLY AN
24
APPENDIX OF THE CALCULATIONS OF ESTIMATED GROUND
25
WATER FLOWS AT THE SITE.
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1
GROUND WATER MOVES VERY
MR. HAYES:
2
VERY SLOWLY.
3
MS. HICKS:
THE OLD SAYING STILL WATER
4
RUNS DEEP DOESN'T APPLY ANYMORE?
5
MR. .HAYES:
THAT'S STILL TRUE.
NO.
6
MS. JONES:
ANY QUESTIONS REGARDING
7
THIS PARTICULAR SITE?
BASICALLY AS FAR AS
OKAY.
8
SEDIMENT CONTAMINATION, THERE WERE TWO
9
ONE WAS ARSENIC AND
CONTAMINANTS OF CONCERN.
10
THOSE CONTAMINANTS OF CONCERN HOWEVER
BERYLLIUM.
11
FROM A RISK STANDPOINT ARE WITHIN E.P.A. 'S
12
AND BASICALLY MR. HAYES
ACCEPTABLE TARGET RANGE.
13
WILL GO OVER THAT WITH YOU MORE IN DEPTH WHEN HE
14
TALKS ABOUT THE RISK ASSESSMENT.
15
AS FAR AS THE SURFACE WATER CONTAMINATION TO
16
TRY TO GET A FEEL OF WHAT SHOULD BE OUT AND WHAT
17
IS NORMAL FOR THAT PARTICULAR STREAM THERE WERE
18
NO CONTAMINANTS OF CONCERN WHICH EXISTED FOR THAT
19
AREA.
20
YOU DIDN'T FIND ANY LEAD
MS. BROWN:
21
AT ALL IN THAT FIRST CREEK?
22
NOT TO THE LEVEL WHICH
MS. JONES:
23
WOULD WARRANT CONCERN.
24
TYPICALLY YOU WOULDN'T
MR. ROGERS:
25
EXPECT THAT BECAUSE THAT IS A DYNAMIC ENVIRONMENT
HANWELL REPORTING SERVICE
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1
WHERE YOU HAVE THE SITE DIDN'T EXIST AFTER ABOUT
2
'83.
THE DHEC PEOPLE WENT IN AND DID A
3
SIGNIFICANT REMOVAL IN THE MID '80S AND IT REALLY
4
WAS VERY LIMITED FROM ANYTHING FROM THE SURFACE
5
TO ROLL OFF THE SITE INTO THOSE STREAMS.
6
BUT THEY HAD DUMPED INTO
MS. BROWN:
7
THAT CREEK?
8
MR. ROGERS:
I KNOW, BUT IT WILL WASH
9
OUT.
10
MS. BROWN:
LEAD DOESN'T THOUGH.
11
MR. ROGERS:
WELL, IT'S SOLUABLE
12
13
USUALLY.
WHERE YOU WILL SEE IT IS IN THE
SEDIMENT.
YOU WON'T SEE IT IN THE WATER BECAUSE
14
ALL THAT WATER IS JUST WATER FLUSHING THROUGH
15
THERE NOW.
IT WILL PICK UP CONTAMINATION OF THE
16
SEDIMENT BUT YOU GENERALLY WON'T SEE IT IN THE
17
WATER BECAUSE ALL THE CONTAMINATION OCCURRED
18
WHAT, TEN YEARS AGO.
IT'S ALL FLUSHED OUT.
19
MS. BROWN:
BERYLLIUM ALSO IS A HEAVY
20
METAL, ISN'T IT?
21
YES.
BOTH OF THOSE SHOW
MR. ROGERS:
22
,UP FREQUENTLY AT SITES AND THEY'RE NATURALLY
23
OCCURRING.
24
MS. JONES:
BASICALLY THIS CONCLUDES I
25
GUESS THE REMEDIAL INVESTIGATION FINDINGS.
AT
HANWELL REPORTING SERVICE
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37
1
THIS TIME MR. BERNIE HAYES WILL BASICALLY GO
2
THROUGH THE BASELINE RISK ASSESSMENT AND PRESENT
3
WHAT THE RISK WERE OR WERE NOT AT THE SITE.
4
MR. HAYES:
THANK YOU, YVONNE.
GOOD
5
EVENING.
MY NAME IS BERNIE HAYES AS YVONNE SAID.
6
I APPRECIATE YOU ALL COMING OUT TONIGHT.
I BET
7
YOU'RE STARTING TO WONDER WHETHER THEY BROUGHT ME
8
JUST TO FL~P THOSE SLIDES OR NOT.
9
I'M GOING TO TALK A LITTLE BIT ABOUT THE
10
RISK ASSESSMENT.
WE THROW THE TERM RISK
11
ASSESSMENT AROUND A LOT.
SO I'LL GIVE YOU A
12
LITTLE INTRODUCTORY DISCUSSION ON WHAT WE MEAN BY
13
SOME OF THESE TERMS.
RISK ASSESSMENT IS AN
14
ATTEMPT TO QUANTIFY THE RISKS THAT MIGHT RESULT
15
FROM THE CONTAMINATION OF THE SITE.
WE WANT TO
16
QUANTIFY THOSE RISKS SO THAT WE CAN COMPARE THEM
17
TO THE STANDARDS AND SAFE LEVELS AND MAKE AN
18
INFORMED EVALUATION OF WHETHER THERE ARE
19
UNACCEPTABLE PUBLIC HEALTH IMPACTS ASSOCIATED
20
WITH THE SITE OR NOT.
21
YOU ALSO HEAR US TALK ABOUT BASELINE RISK
22
ASSESSMENT AS IT'S USED IN SUPERFUNDS.
AND WHAT
23
A BASELINE RISK ASSESSMENT IS IS THE ESTIMATE OF
24
RISK TO PUBLIC HEALTH THAT WOULD RESULT IF THE
25
SITE WERE LEFT UNREMEDIATED.
IN OTHER WORDS, IF
HANWELL REPORTING SERVICE
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1
WE DIDN'T DO ANYTHING WITH THE SITE, IF WE DIDN'T
2
MAKE ANY RESPONSE, THE BASELINE RISK ASSESSMENT
3
GIVES US AN ESTIMATE OF WHAT THE RISK TO PUBLIC
4
HEALTH WOULD BE IN THAT UNREMEDIATED CONDITION.
5
AND HOW DO WE QUANTIFY THOSE LEVELS OF RISK.
6
WE ESTIMATE EXPOSURE LEVELS BY IDENTIFYING
7
COMPLETE EXPOSURE PATHWAYS LEADING FROM A SOURCE
8
AND WHEN WE'RE TALKING ABOUT
OF CONTAMINATION.
9
SUPERFUND SITES THAT SOURCE IS USUALLY THE SITE
10
ITSELF TO A POINT OF HUMAN OR PUBLIC EXPOSURE.
11
AND THE NEXT SLIDE I HAVE GIVES A FEW EXAMPLES OF
12
SOME OF THOSE COMPLETE EXPOSURE PATHWAYS THAT WE
13
NORMALLY LOOK AT.
14
IF YOU HAVE A SITE, A SOURCE OF
15
CONTAMINATION, YOU CAN HAVE RELEASES TO GROUND
16
WATER OF CONTAMINANTS THAT CAN ENTER A WELL AND
17
THE PUBLIC CAN BE EXPOSED TO DRINKING WATER FROM
1.8
THAT'S A COMPLETE
THAT CONTAMINATED WELL.
19
EXPOSURE PATHWAY LEADING FROM THE SITE TO GROUND
20
WATER TO THE WELL TO THE POINT OF PUBLIC
21
EXPOSURE.
IN A SIMILAR MANNER IF THERE ARE
22
RELEASES OF GASES OR CONTAMINATED DUST FROM THE
23
SITE THE WIND COULD BLOW IT TO A POINT WHERE
24
PEOPLE LIVE OR WHERE PEOPLE NORMALLY ARE AND
25
PEOPLE COULD INHALE THAT GAS OR INHALE THAT
HANWELL REPORTING SERVICE
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1
CONTAMINATED DUST AND CREATE ANOTHER POINT OF
2
PUBLIC EXPOSURE.
THESE ARE TWO EXAMPLES OF
3
COMPLETE EXPOSURE PATHWAYS.
AND THERE ARE
4
NUMEROUS COMPLETE EXPOSURE PATHWAYS OTHER THAN
5
THESE.
I MEAN WE TRY TO LOOK AT ALL OF THEM WHEN
6
WE EVALUATE THE RISK ASSOCIATED WITH A SUPERFUND
7
SITE.
8
MS. BROWN:
SUCH AS BURNING BATTERY
9
CASINGS.
10
MR. HAYES:
POSSIBLY.
IF THERE WERE
11
WIND BLOWING TOWARD A HOUSE AND THERE WAS
12
CONTAMINANTS CREATED YOU COULD BE EXPOSED BY THAT
13
THAT'S RIGHT.
THESE ARE THE PRINCIPAL
ROUTE.
14
ROUTES OF HUMAN EXPOSURE.
YOU HAVE INHALATION,
15
WHICH IS THE BREATHING OF DUST OR VAPORS,
16
INGESTION WHICH IS YOU COULD DRINK CONTAMINATED
17
WATER OR GET CONTAMINATED SOIL IN YOUR MOUTH.
IN
18
ADDITION, SOMETIMES AT SITES THAT ARE NEAR RIVERS
19
OR STREAMS AND THE CONTAMINATION GETS IN THOSE
20
RIVERS OR STREAMS WE LOOK AT THE POSSIBILITY OF
21
CONTAMINATED FISH AND PEOPLE EATING THE FISH.
SO
22
THERE'S LOTS OF DIFFERENT WAYS BY WHICH INGESTION
23
CAN OCCUR.
DERMAL ABSORPTION IS ONE THAT YOU
24
DON"T HEAR ABOUT A LOT.
THERE ARE A LOT OF
25
CONTAMINANTS THAT CAN ACTUALLY MOVE THROUGH YOUR
HANWELL REPORTING SERVICE
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40
1
AND CREATE EXPOSURE IN
SKIN RELATIVELY EASILY.
2
THAT MANNER.
3
AND I HAVE A LITTLE SLIDE ABOUT EACH ONE OF
4
THOSE REAL QUICK.
INGESTION OCCURS THROUGH
5
EATING CONTAMINATED FOOD OR DRINKING CONTAMINATED
6
INCIDENTAL OR ACCIDENTAL INGESTION OF
WATER.
7
CONTAMINATED SOIL.
IN OTHER WORDS, IF SOMEBODY
8
GOES ON THE SITE BEFORE IT'S CLEANED UP THEY
9
MIGHT GET SOIL ON THEIR HANDS, PUT THEIR HANDS IN
10
INCIDENTAL OR
THEIR MOUTH.
THINGS LIKE THAT.
11
ACCIDENTAL INGESTION OF CONTAMINATED WATER DURING
12
SWIMMING OR BOATING OR OTHER RECREATIONAL
13
AGAIN, IF THE SITE IS NEAR A STREAM
ACTIVITIES.
14
OR RIVER OR LAKE AND THE WATER BECOMES
15
CONTAMINATED AND IF PEOPLE ARE SWIMMING, BOATING,
16
WHATEVER IN THAT WATER THEY MIGHT GET A LITTLE IN
17
THEIR MOUTHS AND SWALLOW IT ACCIDENTALLY.
18
INHALATION AS I SAID OCCURS THROUGH BREATHING OF
19
TOXIC VAPORS, GASES THAT MIGHT BE RELEASED FROM
20
THE SITE OR IF YOU HAVE CONTAMINATED DUST THAT'S
21
BLOWN FROM THE SITE YOU CAN BREATH IN THE
22
CONTAMINATED DUST AS WELL.
23
AND DERMAL ABSORPTION I THINK IS
24
INTERESTING.
AS I SAID, IT OCCURS WHEN
25
CONTAMINANTS ARE ABSORBED DIRECTLY THROUGH THE
HANWELL REPORTING SERVICE
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41
1
SKIN.
YOUR SKIN IS A GOOD BARRIER AGAINST WATER
2
ITSELF AND AGAINST BACTERIA, INORGANIC
3
CONTAMINANTS, HEAVY METALS AS SOME OF THE THINGS
4
AT THIS SITE.
AND ANYTHING THAT'S ATTACHED TO OR
5
ABSORBED THROUGH SOILS, CONTAMINATED SOILS.
NOW
6
YOUR SKIN IS A LESS EFFECTIVE BARRIER AGAINST
7
BENZENE IS A GOOD
CERTAIN ORGANIC CONTAMINANTS.
8
EXAMPLE.
WE DIDN'T HAVE BENZENE AT THIS SITE.
9
BUT AS YOU KNOW IF YOU GO FILL UP YOUR CAR WITH
10
GAS THERE ARE WARNING SIGNS ON THE PUMP SAYING
11
DON'T GET THE GASOLINE ON YOUR HANDS.
AVOID
12
CONTACT WITH SKIN.
THAT'S BECAUSE SOME OF THE
13
CONTAMINANTS LIKE BENZENE IN GASOLINE CAN BE
14
ABSORBED THROUGH YOUR SKIN.
15
WHEN WE FIND OUT WHAT CONTAMINANTS ARE
16
PRESENT ON THIS SITE THEN WE HAVE TO ASSESS THE
17
TOXICITY OF THOSE CONTAMINANTS.
AND WE GENERALLY
18
LOOK AT TWO DIFFERENT EFFECTS.
WE LOOK AT
19
CARCINOGENIC EFFECTS OR NON CARCINOGENIC EFFECTS.
20
CARCINOGENS ARE CONTAMINANTS WHICH ARE KNOWN TO
21
CAUSE OR SUSPECTED OF CAUSING THE DEVELOPMENT OF
22
CANCER.
23
MANY CONTAMINANTS ARE NOT CONSIDERED TO BE
24
CARCINOGENIC BUT HAVE OTHER ADVERSE HEALTH
25
IMPACTS.
THEY MAY HAVE TOXIC EFFECTS ON SPECIFIC
HANWELL REPORTING SERVICE
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~i.
1,
2
ORGANS BUT DON'T LEAD TO THE DEVELOPMENT OF
CANCER.
AND THERE ARE CONTAMINANTS WHICH HAVE
3
BOTH, CARCINOGENIC AND NON CARCINOGENIC EFFECTS.
4
WHEN WE DO TOXICITY ASSESSMENTS FOR CARCINOGENS
5
WE OPERATE UNDER A FAIRLY CONSERVATIVE
6
ASSUMPTION.
AND THAT ASSUMPTION IS THAT ANY
7
EXPOSURE TO A CARCINOGENIC CONTAMINANT, NO MATTER
8
HOW SMALL, CARRIES WITH IT A PROPORTIONAL LEVEL
9
OF RISK.
IN OTHER WORDS, THERE IS NO COMPLETELY
10
RISK FREE LEVEL OF EXPOSURE TO A CARCINOGEN.
ANY
11
EXPOSURE AT EVEN A VERY LOW RAT~ OR EVEN A ONE
12
TIME EXPOSURE CARRIES WITH IT A CERTAIN RISK.
13
NOW, THE IMPORTANT THING TO REMEMBER FROM THAT IS
14
NOT THAT ANY EXPOSURE CARRIES SOME RISK, BUT THAT
15
IF THE
THE RISK IS PROPORTIONAL TO THE EXPOSURE.
16
EXPOSURE IS LOW OR IF IT'S A ONE TIME EVENT, THEN
17
YOUR RISK IS VERY VERY LOW.
WE TRY TO CONTROL
18
RISKS ASSOCIATED WITH SUPERFUND SITES TO VERY LOW
19
LEVELS.
E.P.A. IS REQUIRED TO REDUCE THE RISKS
20
ASSOCIATED WITH EXPOSURE TO CARCINOGENS
21
ASSOCIATED WITH SITES TO LESS THAN 1 TIMES 10 TO
THE MINUS 4.
IN OTHER WORDS, THAT'S 1 IN 10,000.
23
WHAT THAT MEANS IS WE TRY TO CONTROL EXPOSURE AT
24
THE SITE SO THAT ANY PERSON WHO MAY BE EXPOSED
25
UNDER THE REMEDIATED SITE CONDITIONS HAS NO MORE
HANWELL REPORTING SERVICE
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q~
1
THAN A 1 IN 10,000 CHANCE OF CONTRACTING OR
2
DEVELOPING CANCER AS A RESULT.
AND WE USE VERY
3
CONSERVATIVE EVALUATION TECHNIQUES TO COME UP
4
WITH THAT ESTIMATE.
SO THAT ESTIMATE IS PROBABLY
5
A HIGH ESTIMATE.
IN FACT, THE RISK ASSOCIATED
6
WITH EXPOSURE TO THE SITE ONCE IT'S REMEDIATED IN
7
ALL LIKELIHOOD IS VERY MUCH LOWER.
8
FOR THE PALMETTO SITE THIS MEANS THAT UNDER
9
THE MOST STRINGENT EXPOSURE SCENARIO, WHICH I'LL
10
GET TO IN A SECOND, THAT WOULD BE, RESIDENTS
11
LIVING ON THE SITE FOR THEIR ENTIRE LIVES OF 70
12
YEARS, THOSE RESIDENTS SHOULD NOT HAVE A GREATER
13
THAN A 1 IN 10,000 CHANCE OF DEVELOPING CANCER
14
DUE TO EXPOSURE.
15
WHEN WE ASSESS THE TOXICITY OF NON
16
CARCINOGENS THERE'S A LITTLE BIT DIFFERENT WAY OF
17
LOOKING AT THEM.
AT LOW LEVELS OF EXPOSURE IT IS
18
ASSUMED THAT THERE ARE NO ADVERSE IMPACTS TO
19
HUMAN HEALTH.
IN OTHER WORDS, THERE IS A SAFE
20
EXPOSURE LEVEL THAT YOU CAN REPEATEDLY EXPERIENCE
21
WITHOUT ANY ADVERSE HEALTH IMPACT.
AND THAT GETS
22
BACK TO THE QUESTION ABOUT ARSENIC.
IT IS TRUE
23
THAT AT THOSE LOW LEVELS YOU COULD HAVE CONSTANT
24
EXPOSURE TO DRINKING' WATER AND NOT EXPERIENCE ANY
25
ADVERSE HEALTH EFFECTS.
THE DRINKING WATER
HANWELL REPORTING SERVICE
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~~
1
STANDARD OF 50 PARTS PER BILLION IS SET AT A
2
LEVEL WHICH IS PROTECTIVE AND ASSUMES THAT YOU'RE
3
EXPOSED TO THAT CONSTANTLY.
AND THAT THERE WOULD
4
BE NO ADVERSE HEALTH EFFECT AS A RESULT.
5
AT SUPERFUND SITES WE'RE REQUIRED TO REDUCE
6
NON CARCINOGENIC RISKS TO A LEVEL SUCH THAT THE
7
HAZARD INDEX IS LESS THAN ONE.
THE HAZARD INDEX
8
IS JUST A FANCY TERM FOR SAYING WE LOOK AT THE
9
RATIO OF THE EXPOSURE LEVEL THAT PEOPLE ARE
10
EXPERIENCING TO THE SAFE LEVEL.
IF THAT RATIO IS
11
GREATER THAN ONE THEN OBVIOUSLY YOUR EXPOSURE IS
12
GREATER THAN THE SAFE LEVEL AND WE WANT TO
13
CONTROL THAT EXPOSURE TO GET IT DOWN BELOW ONE.
14
OKAY.
WE LOOKED AT FOUR PRIMARY EXPOSURE
15
WE LOOKED AT A
PATHWAYS AT THE PALMETTO SITE.
16
TRESPASSER SCENARIO.
THAT'S THE CURRENT SITE
17
CURRENT SITE CONDITIONS, THERE'S
CONDITIONS.
18
THE PRIMARY ROUTE OF
NOBODY LIVING ON THE SITE.
19
EXPOSURE OR THE MOST STRINGENT ROUTE OF EXPOSURE
20
WOULD BE A TRESPASSER GOING ONTO THE SITE IN AN
21
UNCONTROLLED MANNER REPEATEDLY.
22
BUT WE ALSO WANT TO MAKE SURE THAT THE SITE
23
IS CLEANED UP SO THAT THE SITE IS SAFE FOR
24
POTENTIAL FUTURE USES AS WELL.
SO WE ALSO LOOKED
25
AT EXPOSURE SCENARIOS FOR RESIDENTS, FOR CHILDREN
HANWELL REPORTING SERVICE
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\
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12
13
14
15
16
17
18
19
20
21
22
23
24
25
4~
AND ADULTS.
THE YOUTH RESIDENT EXPOSURE SCENARIO
IS KIND OF A SPECIAL ONE AND I'LL TALK ABOUT THAT
A LITTLE MORE.
USUALLY THE GUIDING EXPOSURE
SCENARIOS FOR SETTING THE CLEAN UP LEVELS. AT
THESE SITES ARE BASED ON USING THE SITE FOR
RESIDENTIAL PURPOSES IN THE FUTURE.
AND VERY
AFTER THE CHILD RESIDENT BECAUSE CHILDREN ARE
OFTEN MORE SUSCEPTIBLE TO TOXIC EFFECTS.
THE
CHILD RESIDENT EXPOSURE SCENARIO IS VERY OFTEN
THE ONE THAT GUIDES THE REMEDIATION AND SETS THE
CLEAN UP GOALS.
AND THAT IN FACT WAS THE CASE AT
THIS SITE.
MS. BROWN:
GOING BACK TO YOUR
TRESPASSER, IS IT POSSIBLE THAT THE CONTAMINATION
THAT'S DOWN THERE NOW THAT PEOPLE DRIVING THEIR
CAR ON THAT TARMAC THERE FOR THE PLACE THERE,
. EDMOND'S, GOING IN THERE AND COMING OUT, WOULD
PICK UP CONTAMINATION?
MR. HAYES:
I'M NOT SURE WHERE YOU
MEAN.
BUT IT IS POSSIBLE THAT PEOPLE NEAR THE
SITE MIGHT EXPERIENCE SOME EXPOSURE.
BUT IT'S
UNLIKELY --
MS. BROWN:
I'M TALKING ABOUT GOING ON
THE TARMAC, WALKING ON THE TARMAC, DRIVING CARS
ON THE TARMAC, WOULD THEY GET EXPOSED TO THE LEAD
HANWELL REPORTING SERVICE
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40
1
AND THE OTHER --
2
MR. HAYES:
THE TARMAC ON THE SITE?
3
MS. BROWN:
YES.
4
MR. HAYES:
YES.
THAT'S PART OF THE
5
TRESPASSER EXPOSURE SCENARIO.
AND THE
6
ASSUMPTIONS THAT GOES INTO THE TRESPASSER
7
EXPOSURE SCENARIO ARE A LITTLE BIT MORE
8
CONSERVATIVE THAN SOMEONE WHO MIGHT JUST DRIVE
9
ONTO THE TARMAC AND WALK AROUND ON THE PAVED
10
AREA.
IT ASSUMES THAT PEOPLE ARE REPEATEDLY --
11
MS. BROWN:
WELL, THEY COME OUT ON
12
THAT DIRT, TOO, WHEN THEY WALK OUT THAT GATE.
13
MR. HAYES:
.THAT'S WHAT THE TRESPASSER
14
SCENARIO LOOKED AT.
IT LOOKS AT PEOPLE
15
REPEATEDLY GOING ON THE SITE OVER A LONG PERIOD
16
OF TIME, YEARS AND YEARS AND YEARS.
17
MS. BROWN:
THAT'S BEEN HAPPENING DOWN
18
THERE.
19
MR. HAYES:
THAT'S EXACTLY.WHAT THE
20
TRESPASSER EXPOSURE PATHWAY LOOKS AT.
BUT AS
21
I'LL TALK ABOUT A LITTLE BIT MORE, THE RISK
22
. ASSOCIATED WITH THAT EXPOSURE SCENARIO IS VERY
23
LOW AND WITHIN WHAT WE CONSIDER TO BE ACCEPTABLE
24
OR SAFE LIMITS.
THE ONLY EXPOSURE SCENARIO
25
THAT'S CREATED ANY UNACCEPTABLE RISK WAS THE
HANWELL REPORTING SERVICE
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47
1
CHILD RESIDENT EXPOSURE SCENARIO.
2
MS. ANDERSON:
3
LILLIE ANDERSON.
I'VE
WONDERED FROM THE BEGINNING WHAT EFFECT IF ANY
4
DID IT HAVE ON THE ROAD ITSELF ADJACENT TO WHERE
5
PEOPLE DRIVE?
6
MS. BROWN:
7
MR. HAYES:
8
WITH YOU.
9
MS. ANDERSON:
10
SHOULD BE LOOKED AT.
11
MR. ROGERS:
12
THE MAIN ROAD.
I DON'T KNOW TO BE HONEST
IT SEEMS LIKE THAT
THERE WERE SAMPLES OUT IN
THE ROADSIDE DITCH THAT INDICATE THAT THERE
13
WASN'T ANY SIGNIFICANT CONTAMINATION.
WE DID
14
HAVE A HIT WHICH WE COULDN'T REPRODUCE.
15
MS. ANDERSON:
16
BECAUSE AS THEY HAULED
THEY SPILLED AS THEY WENT ALONG ALL THE WAY.
17
MS. BROWN:
18
CASINGS, THE BATTERY ACID.
19
THE TRUCKS SPILLED THE
IN OTHER WORDS, THEY
WERE NOT COVERED AND ALL THAT WAS FLYING ALONG
20
THE ROAD.
ALL THAT WAS REPORTED TO DHEC.
21
MS. ANDERSON:
22
ALONG THERE.
23
MS. BROWN:
24
321.
IT WAS 21 COMING IN.
25
MR. ROGERS:
THEY WAS SPILLING ALL
IT WASN'T JUST COMING FROM
IN RELATIVE TERMS THAT
HANWELL REPORTING SERVICE
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48
1
WOULD BE A VERY SMALL AMOUNT.
THAT ROAD GETS
2
SCRAPED AND DIFFERENT THINGS OCCUR TO IT SUCH
3
THAT THERE WOULDN'T HAVE BEEN NOTICEABLE
4
ACCUMULATION THAT WOULD HAVE CAUSED THAT KIND OF
5
EXPOSURE.
6
MR. HAYES:
OKAY.
WE'LL COME BACK TO
7
THOSE QUESTIONS AND THOSE ARE GOOD QUESTIONS.
I
8
DON iT MEAN TO NOT ADDRESS THEM OR ANSWER THEM TO
9
YOUR SATISFACTION.
WE CAN COME BACK TO THAT
10
QUESTION.
11
YOU SAID TO ASK QUESTIONS.
MS. BROWN:
12
THAT'S WHAT WE'RE DOING.
13
GOOD.
I WANT TO GO
MR. HAYES:
14
THROUGH THE TRESPASSER AND YOUTH RESIDENT BECAUSE
15
THEY'RE SOMEWHAT SPECIAL CASES.
IN LOOKING AT
16
PATH SIZE AND LOOKING AT EXPOSURE SCENARIOS
17
ASSOCIATED WITH THE SITE IN THE PAST IT'S
18
E.P.A.'S EXPERIENCE THAT THE MOST RESTRICTIVE OR
19
THE MOST LIKELY EXPOSURE IS GOING TO OCCUR WITH
20
NOT A CHILD OR AN ADULT.
YOUNG CHILDREN BELOW
21
THE AGE OF 6 ARE NOT LIKELY TO BE ON THE SITE
22
.UNSUPERVISED.
ADULTS MAYBE KNOW A LITTLE BIT
23
BETTER THAN TO PLAY AROUND AN INDUSTRIAL SITE.
24
THE HIGHEST LEVELS OF EXPOSURE, THE GREATEST
25
RISKS UNDER A TRESPASSER SCENARIO OCCUR IN WHAT
HANWELL REPORTING SERVICE
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1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
i . 17
18
19
20
21
22
23
24
25
'*~
WE WOULD CALL A YOUTH OR TEENAGE YEARS.
AND THE
PATHWAYS EVALUATED WITH THAT WERE INCIDENTAL
INGESTION OF SURFACE SOIL AND SEDIMENT, DERMAL
ABSORPTION FROM CONTACT WITH THOSE CONTAMINATED
SOILS AND SEDIMENTS AND INHALATION OF
CONTAMINATED DUST AND SOILS.
WE ALSO LOOKED AT
OUR YOUTH RESIDENT BECAUSE AGAIN SOMEONE LIVING
ON THE SITE, A CHILD, IS NOT LIKELY TO RQAM
UNSUPERVISED AND GET INTO THE DITCHES AND CREEKS.
AN ADULT PROBABLY KNOWS BETTER.
BUT A YOUTH, A
KID OR A TEENAGER, MAY AT TIMES COME INTO CONTACT
WITH THE SEDIMENTS IN THOSE CREEKS AND DITCHES.
AND SO WE WANTED TO MAKE SURE WE COVERED THAT.
SO WE LOOKED AT A YOUTH RESIDENT SCENARIO WHICH
INVOLVED INCIDENTAL INGESTION OF CONTAMINATED
SEDIMENTS AND DERMAL CONTACT WITH THOSE SEDIMENTS
TO MAKE SURE WE COVERED ALL OUR BASES.
MS. BROWN:
ONE QUESTION.
MR. EARLE
IS HERE TONIGHT AND HIS CHILDREN ACROSS THE
STREET WERE TESTED BY DHEC FOR LEAD WHENEVER THE
BATTERY CASINGS WERE BURNED.
IS IT POSSIBLE THAT
THEY NEED TO BE RETESTED NOW BY E.P.A. SINCE THEY
ARE CHILDREN AND YOUNG TEENAGERS?
MR. HAYES:
WELL, THAT'S A VERY
DIFFICULT QUESTION TO ANSWER.
I WOULDN'T WANT TO
HANWELL REPORTING SERVICE
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~u
1
SAY THAT IT WOULDN'T DO ANY GOOD TO RETEST THEM.
2
BUT BASED ON THE EVALUATION AND THE RISK
3
ASSESSMENT THE ONLY CHILDREN THAT WOULD BE AT ANY
4
RISK ON THIS SITE WOULD BE IF THEY ACTUALLY LIVED
5
ON THE SITE EVERY DAY AND WERE EXPOSED AND
6
ANY EXPOSURE LESS
PLAYING ON THE SITE EVERY DAY.
7
THAN THAT IS NOT LIKELY TO HAVE CREATED AN
8
SO WHILE I CAN'T SAY
UNACCEPTABLE LEVEL OF RISK.
9
THAT IT WOULDN'T BE OF ANY PURPOSE TO HAVE THOSE
10
CHILDREN TESTED AGAIN OR TO HAVE ANYBODY WHO'S
11
BEEN ON THE SITE TESTED AGAIN, ALL I CAN SAY IS
12
THAT IT WOULD BE VERY UNLIKELY THAT THAT TYPE OF
13
EXPOSURE WOULD CREATE AN UNACCEPTABLE HEALTH
14
THERE IS SOME UNCERTAINTY ASSOCIATED WITH
RISK.
15
IT AFFECTS
HOW LEAD EXPOSURE EFFECTS PEOPLE.
16
DIFFERENT PEOPLE IN DIFFERENT WAYS AND AT
17
SO A LOWER LEVEL OF EXPOSURE
DIFFERENT LEVELS.
18
TO A CHILD WHO WAS VERY SUSCEPTIBLE TO THOSE
19
BUT
KINDS OF EFFECTS IT MIGHT CREATE A PROBLEM.
20
AND AGAIN
THE LIKELIHOOD OF THAT IS VERY SMALL.
21
I HAVE SOME SLIDES THAT MIGHT TALK ABOUT THAT A
22
AND AGAIN; WE CAN
LITTLE BIT MORE AS WE GO ON.
23
BUT AGAIN, THAT'S A VERY GOOD
COME BACK TO IT.
24
AND I'M NOT SURE I'M GOING TO BE ABLE
QUESTION.
25
TO SATISFACTORILY ANSWER ALL YOUR QUESTIONS ABOUT
HANWELL REPORTING SERVICE
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~l
1
LEAD TOXICITY AND HOW IT MAY AFFECT DIFFERENT
2
PEOPLE DIFFERENTLY.
BECAUSE IT'S NOT SOMETHING
3
THAT'S EASY TO UNDERSTAND.
IT'S NOT EVEN EASY
4
FOR ME TO UNDERSTAND.
5
MS. BROWN:
WELL, WOULDN'T E.P.A. AS
6
WELL AS THE NEIGHBORS BE SATISFIED IF THEY WERE
7
TESTED AGAIN TO MAKE SURE THAT THEY WERE NOT?
8
MR. HAYES:
WELL, I THINK THAT'S A
9
POSSIBILITY THAT WE CAN TALK ABOUT.
BUT I CAN '.T
10
TELL YOU WHETHER SOMETHING NEEDS TO BE DONE OR
11
NOT.
AND THAT'S SOMETHING WE CAN TAKE BACK WITH
12
US AND TALK ABOUT WHETHER IT'S SOMETHING THAT
13
WOULD BE A GOOD IDEA TO DO AS PART OF THE SITE
14
INVESTIGATION.
15
MS. BROWN:
BECAUSE THEY ARE ACROSS
16
THE ROAD FROM IT.
17
MR. HAYES:
THE ADULT RESIDENT PATHWAY
18
WE LOOKED AT AGAIN AVERY COMPREHENSIVE EXPOSURE
19
SCENARIO.
WE LOOKED AT INGESTION OF CONTAMINATED
20
SURFACE SOILS AND GROUND WATER.
IN OTHER WORDS,
21
ASSUMING THAT SOMEBODY WOULD BUILD A HOUSE ON THE
22
SITE, SINK A WELL ON THE SITE AND DRINK THE WATER
23
FROM THAT WELL.
WE ADDED DERMAL ABSORPTION FROM
24
CONTACT WITH THOSE CONTAMINATED SURFACE SOILS AND
25
INHALATION NOT ONLY FROM CONTAMINATED DUST AND
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I-~. -. - ---.
52
1
SOIL BUT FROM THE VOLATILE CONTAMINANTS THAT
2
MIGHT BE PRESENT IN THE GROUND WATER THAT COULD
3
BE RELEASED WHILE SOMEBODY IS TAKING A SHOWER AND
4
INHALED WHILE YOU'RE TAKING A SHOWER.
SO WE
5
TRIED TO BE VERY COMPREHENSIVE IN LOOKING AT ALL
6
THE VARIOUS EXPOSURE PATHWAYS.
7
AND THE EXPOSURE PATHWAYS FOR THE CHILD ARE
8
JUST THE SAME BUT THE DIFFERENCE IN HOW WE
9
EVALUATED THE RISK ASSOCIATED WITH A CHILD IS
10
THAT A CHILD DRINKS LESS WATER.
A CHILD HAS A
11
LOWER BODY WEIGHT.
AND SO IS LIKELY TO BE MORE
12
SUSCEPTIBLE.
AND THE TOXIC END POINTS OR THE
13
LEVEL AT WHICH TOXIC EFFECTS ARE EXPERIENCED BY A
14
CHILD GENERALLY TEND TO BE LOWER FOR MOST
15
CONTAMINANTS.
SO EVEN THOUGH THE PATHWAYS
16
EVALUATED ARE THE SAME, A LOT OF THE NUMBERS THAT
17
WENT INTO THOSE CALCULATIONS FOR A CHILD ARE
18
DIFFERENT THAN THEY ARE FOR AN ADULT.
19
ALL RIGHT.
A LOT OF CONTAMINANTS WERE FOUND
20
IN THE SAMPLES AT PALMETTO.
THERE WERE FOUR
21
ORGANICS FOUND IN EITHER SURFACE SOILS OR GROUND
22
WATER, ETC.
YVONNE ALREADY MENTIONED SHE GOT.
23
BUT SAMPLES WERE FOUND TO HAVE HAD SOME OF THESE
24
OTHER CONTAMINANTS IN THEM.
ALSO, A FAIRLY LARGE
25
NUMBER OF METALS WERE FOUND.
THE THING TO
HANWELL REPORTING SERVICE
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53
1
REMEMBER ABOUT THIS IS THAT WHEN WE RAN THESE
2
CONTAMINANTS THROUGH THE RISK ASSESSMENT NONE OF
3
THEM CREATED ANY THREAT TO. HEALTH OR ANY
4
UNACCEPTABLE RISK WITH ONE EXCEPTION.
AND THAT
5
EXCEPTION AS YOU MIGHT EXPECT WAS LEAD.
EVEN IN
6
THE GROUND WATER AS YVONNE POINTED OUT, WE DIDN'T
.7
FIND ANY LEAD ABOVE DRINKING WATER STANDARDS.
8
THERE WAS ONE SAMPLE THAT WAS A LITTLE BIT HIGH
9
BUT WHEN WE WENT BACK AND RESAMPLED THAT WELL A
10
COUPLE MORE TIMES WE DIDN'T FIND ANYTHING.
BUT
11
THE LEAD ASSOCIATED WITH THE SURFACE SOILS
12
CREATED AN UNACCEPTABLE LEVEL OF RISK FOR THE
13
CHILD RESIDENT EXPOSURE SCENARIO.
SO WE'LL TALK
14
ABOUT THAT A LITTLE BIT.
15
THE PRELIMINARY CONCLUSIONS FROM THE
OKAY.
16
RISK ASSESSMENT WERE THAT UNDER CURRENT EXPOSURE
17
CONDITIONS UNDER THE TRESPASSER SITUATION THERE
18
TaE
IS NO UNACCEPTABLE LEVEL OF RISK.
19
UNACCEPTABLE RISK ASSOCIATED WITH POTENTIAL
20
FUTURE EXPOSURE SCENARIOS IS DUE EXCLUSIVELY TO
21
CONTAMINATED SOILS.
AND THE RISK LEVELS ARE
22
ASSOCIATED WITH POTENTIAL EXPOSURE TO LEAD.
THE
23
OTHER CONTAMINANTS AND THE OTHER MEDIA DID NOT
24
CONTRIBUTE SIGNIFICANTLY TO ANY UNACCEPTABLE
25
RISK.
HANWELL REPORTING SERVICE
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S4
1
THIS IS THE SUMMARY OF THE HEALTH EFFECTS OF
2
AND THERE IS A HANDOUT ON THE BACK TABLE,
LEAD.
3
A FACT SHEET, ABOUT THE HEALTH EFFECTS.
IT GOES
4
INTO A LITTLE BIT MORE DETAIL.
EXPOSURE TO HIGH
5
LEVELS OF LEAD CAN CAUSE SEVERE BRAIN DAMAGE AND
6
KIDNEY DAMAGE.
CERTAINLY NOTHING LIKE THE LEVELS
7
OF EXPOSURE WE HAVE AT THIS SITE.
THAT WOULD BE
8
PERHAPS INDUSTRIAL EXPOSURE IN AN UNCONTROLLED
9
SITUATION.
CERTAINLY THOSE KINDS OF LEVELS ARE
10
NOTHING LIKE WHAT WE WOULD FIND AT THIS SITE.
11
THERE IS SOME EVIDENCE TO SUGGEST THAT LOWER
12
LEVELS OF EXPOSURE MAY CAUSE INCREASES IN BLOOD
13
PRESSURE IN MEN ALTHOUGH I THINK THERE'S A LOT OF
14
THINGS THAT CAUSE INCREASED BLOOD PRESSURE IN
15
MIDDLE AGED MEN.
I KNOW THAT I HAVE THAT
16
PROBLEM.
VERY HIGH LEVELS MAY ALSO EFFECT MALE
17
REPRODUCTIVE SYTEMS.
EXPOSURES OF PREGNANT WOMEN
18
CAN RESULT IN PREMATURE BIRTH, LOW BIRTH WEIGHT
19
OR EVEN MISCARRIAGE.
AND THIS IS THE IMPORTANT
20
ONE, THIS LAST ONE.
LEAD EXPOSURES IN INFANTS
21
AND YOUNG CHILDREN CAN SHOW DECREASED IQ SCORES,
.22
RETARD PHYSICAL GROWTH AND CAUSE HEARING
23
PROBLEMS.
24
NOW, LEAD IS A BAD. ACTOR.
THERE IS NO
25
QUESTION ABOUT IT.
AND THERE'S BEEN A LOT OF
HANWELL REPORTING SERVICE
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1
RESEARCH ON THE EFFECTS OF LEAD.
THAT'S ONE
2
REASON ~OR THOSE OF YOU WHO ARE OLD ENOUGH TO
3
REMEMBER WHY LEAD GASOLINE WAS PHASED OUT, WHY
4
LEAD PAINTS ARE NO LONGER USED.
ALL THAT WAS AS
5
ATTEMPT TO REDUCE THE PUBLIC'S EXPOSURE TO LEAD
6
BECAUSE OF THE ADVERSE AND IN SOME CASES SEVERE
7
HEALTH EFFECTS OF LEAD.
SO WE DON'T WANT TO
8
UNDERESTIMATE THE POTENTIAL HEALTH EFFECTS OF
9
LEAD.
IT IS A REAL PROBLEM.
10
OKAY.
THIS IS -- THE WAY THAT WE EVALUATE
11
THE EFFECTS OF LEAD ON THE PUBLIC OR ON HUMAN
12
HEALTH IS BY MEANS OF THIS LEAD UPTAKE BIOKINETIC
13
MODEL.
AND THAT'S JUST A FANCY TERM FOR A
14
COMPUTER PROGRAM THAT GIVEN THE EXPOSURE LEVELS
15
OF LEAD AT A SITE PREDICTS THE AVERAGE BLOOD
16
CONCENTRATIONS OF LEAD IN CHILDREN AGE 0 TO 6
17
YEARS.
18
THE RESEARCH THAT HAS BEEN DONE REGARDING
19
TOXIC EFFECTS OF LEAD HAS SHOWN THAT THE
20
NEUROTOXIC EFFECTS, THOSE LOW IQ SCORES, OTHER
21
CENTRAL NERVOUS SYSTEM EFFECTS, MAY OCCUR AT
22
BLOOD LEAD LEVELS AS LOW AS TEN MICROGRAMS PER
23
DECALITER.
THIS IS JUST A MEASUREMENT TOOL THAT
24
THE MEDICAL PROFESSION USES TO MEASURE
25
CONCENTRATIONS IN BLOOD.
THE NUMBER 10 IS WHAT
HANWELL REPORTING SERVICE
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1- -
:>0
1
TO REMEMBER.
AN'D E.P.A. 'S GOAL IS TO ENSURE THAT
2
BASED ON THIS BIOKINETIC MODEL, BASED ON THIS
3
COMPUTER PROGRAM, THAT 95 PERCENT OF EXPOSED
4
CHILDREN AT THE SITE HAVE BLOOD LEAD LEVELS LESS
5
THAN THIS RELATIVELY SAFE LEVEL OF 10 MICROGRAMS
6
SO THE tMPORTANT THING TO TAKE
PER DECALITER.
7
AWAY FROM THIS SLIDE IS THAT WE WANT TO CONTROL
8
BLOOD LEAD LEVELS TO BELOW TEN.
WE WANT TO MAKE
9
SURE THAT NO MORE THAN FIVE PERCENT OF THE
10
EXPOSED POPULATION WOULD BE PREDICTED TO HAVE
11
LEAD LEVELS ABOVE THAT.
AND THAT THIS MODEL IS
12
USED TO PREDICT THOSE BLOOD CONCENTRATIONS IN
13
CHILDREN.
14
THIS IS A GRAPH SHOWING THE RESULTS OF THAT
15
MODEL, OF THAT COMPUTER PROGRAM.
NOW, THIS LINE
16
IS TEN MICROGRAMS PER DECALITER, THE LEVEL AT
17
WHICH WE WANT TO CONTROL EXPOSURE.
WHAT THIS
18
LINE INDICATES IS THE PERCENTAGE OF CHILDREN THAT
19
WOULD HAVE A GIVEN CONCENTRATION OF LEAD IN THEIR
20
BLOOD UNDER EXPOSURES TO SITE CONDITIONS.
NOW, I
21
KNOW THIS CAN BE A LITTLE CONFUSING. BUT WHAT
THIS GRAPH MEANS IS THIS PEAK HERE IS THE AVERAGE
BLOOD LEVEL CONCENTRATION OR THE MOST FREQUENT
BLOOD LEVEL CONCENTRATION THAT WOULD RESULT AS AN
22
23
24
25
EXPOSURE TO THE SITE.
AND THAT NUMBER IS ABOUT
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1
5.6 MICROGRAMS PER DECALITER, WHICH IS WELL BELOW
2
THE 19.
WHAT THIS GRAPH ALSO SHOWS IS THAT ABOUT
3
10.6 PERCENT OF THE CHILDREN WHO ARE EXPOSED AT
4
THIS SITE WOULD HAVE BLOOD LEAD LEVELS ABOVE THIS
5
SAFE LEVEL OF 10.
AND UNDER E.P.A. GUIDELINES
6
AND UNDER E.P.A. PROTOCOLS THAT'S CONSIDERED AN
7
UNACCEPTABLE LEVEL OF RISK.
WE WANT TO CONTROL
8
THAT TO BE LESS THAN 5 PERCENT.
SO IN ORDER TO
9
DO THAT WE HAVE TO REDUCE THE LEAD AT THE SITE.
10
IN THIS GRAPH WERE SHIFTED BACK THIS WAY SO THAT
11
LESS OF IT WERE ON THE RIGHT OF THIS LINE OF 10
12
PERCENT THEN IT MIGHT BE THAT THE PERCENT WOULD
13
BE 5 PERCENT AND THE SITE WOULD BE OKAY.
BUT
14
SINCE IT IS GREATER THAN 5 PERCENT THAT'S
15
CONSIDERED AN UNACCEPTABLE LEVEL OF RISK FOR
16
CHILDREN EXPOSED TO LEAD AT THE SITE AND IT'S THE
17
BASIS FOR OUR PROPOSAL TO REMEDIATE SURFACE SOILS
18
AT THE SITE.
19
THE CLEAN UP LEVEL FOR LEAD, WHICH YVONNE
20
HAS ALREADY MENTIONED, IS PROPOSED AT 400
2.1
THAT'S BASED ON AGENCY
MILLIGRAMS PER KILOGRAM.
22
GUIDANCE.
THIS IS JUST AN INTERNAL GUIDANCE
23
DOCUMENT THAT WAS DEVELOPED TO HELP PEOPLE LIKE
24
YVONNE AND ME CHOOSE THE RIGHT CLEAN UP LEVEL.
25
AND THAT LEVEL OF 400 MILLIGRAMS PER KILOGRAM IS
HANWELL REPORTING SERVICE
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1
DESIGNED TO MEET THE GOAL OF 95 PERCENT BLOOD
2
LEVELS LESS .THAN 10 MICROGRAMS PER DECALITER.
3
THE CURRRENT SOIL LEAD CONCENTRATIONS
4
AVERAGE 528 MICROGRAMS PER KILOGRAM.
SOME OF THE
5
SAMPLES WERE MUCH HIGHER AS YVONNE SAID.
AND
6
THAT AVERAGE LEVEL IS 32 PERCENT GREATER THAN THE
7
PROPOSED CLEAN UP LEVEL OF 400 MILLIGRAMS PER
8
KILOGRAM.
9
THE IMPORTANT THING TO REMEMBER I THINK FROM
10
LOOKING AT THIS INFORMATION IS THAT EVEN UNDER
11
CURRENT SITE CONDITIONS A CHILD LIVING ON THE
12
SITE WOULD NOT BE LIKELY TO HAVE BLOOD LEAD
13
LEVELS THAT EXCEED THE SAFE LEVEL.
BUT A CERTAIN
14
PERCENTAGE OF CHILDREN MIGHT.
AND BECAUSE OF
15
THAT POSSIBILITY WE WANT TO MAKE SURE THAT WE
16
REMEDIATE THE SITE SO THAT THAT LIKELIHOOD IS
17
VERY, VERY SMALL.
18
I'LL TAKE A COUPLE QUICK QUESTIONS.
BUT IF
19
YOU DON'T MIND WE'LL LET YVONNE DO TH~ REST OF
20
HER PRESENTATIOON AND THEN ANSWER QUESTIONS IN
21
GENERAL AT THE END.
22
MR. EARLE:
OKAY.
MY QUICK QUESTION
23
IS YOU'RE SAYING ABOUT CHILDREN LIVING ON THE
24
SITE.
HOW MANY FEET WOULD A CHILD HAVE TO LIVE
25
BEFORE IT'S CONSIDERED LIVING OFF SITE?
HANWELL REPORTING SERVICE
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MR. HAYES:
WELL, WHEN WE SAY LIVING
2
ON SITE WE MEAN THAT rF SOMEBODY BUILT A HOUSE
3
AND THE CHILD LIVED IN THAT HOUSE AND WAS IN THAT
4
YARD EVERY DAY COMING AND GOING UNDER NORMAL
5
CONDITIONS AND THAT INCLUDES AS I SAID DRINKING
6
WATER FROM A WELL ON THAT SITE.
IT INCLUDES ALL
7
THE OTHER EXPOSURE PATHWAYS BASICALLY.
THE ONE
8
THAT REALLY CREATES THE PROBLEM IS THE
9
CONTAMINATED 'SOIL.
BUT I THINK THAT A CHILD THAT
10
DOESN'T LIVE RIGHT ON THE SITE IS NOT GOING TO
11
EXPERIENCE THE SAME LEVEL OF EXPOSURE AS A CHILD
12
WHO LIVES SAY ACROSS THE STREET OR NEARBY IF FOR
1'3
NO OTHER REASON THAN THE HOUSE ITSELF IS LIKELY
14
TO HAVE DUST IN IT AND IS CONTAMINATED WITH LEAD
15
AND IS MORE LIKELY TO HAVE THAT KIND OF PROBLEM
16
IF IT'S RIGHT ON THE SITE AS OPPOSED TO SOME
17
DI~TANCE AWAY.
18
MS. BROWN:
YOU'RE TALKING ABOUT THE
19
DUST.
NORMALLY WE HAVE SOUTHWEST WINDS WHICH
20
WOULD BLOW TO THE NORTH, NORTHEAST.
BUT HERE
21
LATELY WE'VE HAD NORTH NORTHEAST WINDS THAT WOULD
22
BLOW THAT DUST ACROSS INTO THE AREA OF
23
MR. EARLE'S AND THE OTHER PEOPLE LIVING ACROSS
24
THE ROAD.
THAT CONTAMINATED DUST WOULD BE BLOWN
25
INTO THEIR YARD INTO THEIR HOUSE.
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1
MR. HAYES:
YES.
2
MS. BROWN:
THAT'S WHY I ASKED YOU THE
3
FIRST TIME WOULDN'T IT BE OF INTEREST FOR THE
4
E.P.A. TO HAVE THOSE CHILDREN RETESTED AND PEOPLE
5
OVER 65 RETESTED IN THAT AREA?
- 6
MR. HAYES:
WELL, AGAIN, I'LL JUST
7
REPEAT THAT THAT MAY BE A GOOD IDEA.
I DON'T
8
WANT TO TELL YOU THAT -WE'RE GOING TO DO SOMETHING
9
OR NOT DO SOMETHING WITHOUT GOING BACK AND
10
THINKING ABOUT IT AND TRYING TO MAKE A DECISION
11
ABOUT WHAT'S THE BEST THING TO DO.
SO IT MAY BE
12
A GOOD IDEA.
AND THAT'S EXACTLY THE KIND OF
13
THING THAT WE NEED TO DO.
14
MS. BROWN:
BECAUSE YOU STOOD THERE
15
AND STATED THAT WE DO HAVE LEAD CONTAMINATION
16
THERE.
17
MR. HAYES:
BUT THE IMPORTANT THING TO
18
REMEMBER IS THAT TYPE OF EXPOSURE, WIND BLOWN
19
EXPOSURE OF DUST, IS GOING TO BE MUSH LESS THAN A
20
CHILD WHO IS LIVING AND PLAYING ON THE SITE EVERY
21
DAY FOR THE FIRST SIX YERAS OF ITS LIFE.
I THINK
22
THAT'S AGAIN -- IT HELPS ANSWER YOUR QUESTION.
23
THIS IS BASED ON EFFECTS FOR CHILDREN 6 YEARS AND
24
YOUNGER.
THAT'S THE CRITICAL EXPOSURE SCENARIO.
25
I KNOW THAT THINGS ARE A LITTLE BIT DIFFERENT IN
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1
THE COUNTRY THAN THEY ARE IN ATLANTA, BUT I STILL
2
WOULD THINK THAT A CHILD THAT YOUNG IS NOT LIKELY
3
TO WANDER ACROSS THE STREET AND OUT OF ITS YARD
4
AND ONTO AN INDUSTRIAL SITE VERY OFTEN AT LEAST
5
UNTIL THEIR PARENTS WERE TO FIND OUT ABOUT IT AND
6
TRY TO REIN THEM IN A LITTLE BIT.
BUT THAT'S
7
DIFFERENT FROM SOMEBODY WHO'S LIVING ON THE SITE
8
AND A CHILD PLAYING IN THE YARD EVERY DAY.
SO IF
9
THE EXPOSURE ASSOCIATED WITH LIVING ON THE SITE
10
IS UNACCEPTABLE BUT SOMEWHAT WAS CLOSE TO BEING
11
ACCEPTABLE, WITHIN FIVE PERCENT OF BEING
12
ACCEPTABLE, THAN A CHILD LIVING ACROSS THE STREET
13
THAT YOUNG WHO'S NOT ON THE SITE EVERYDAY IS NOT
14
LIKELY TO BE EXPERIENCING THE SAME EXPOSURES.
15
WELL, MY CONCERN WAS
MR. EARLE:
16
BECAUSE FROM '83 TO THE TIME THE PLANT CLOSED
17
THESE PEOPLE OPERATED BETTER THAN TEN HOURS A
18
AND WHEN THEY HAD THOSE CONVEYOR BELTS
DAY.
19
RUNNING AND WHEN THE WIND WAS BLOWING I'M QUITE
20
SURE THERE WAS DUST AND THINGS IN THE AIR FOR THE
21
SO I MEAN WOULDN'T
DURATION THE PLANT WAS OPEN.
22
THAT BE SOMEWHAT DIFFERENT BASED ON THR FINDINGS
23
OF WHAT YOU FINDING ON THE SITE RIGHT NOW?
24
MR. HAYES:
IT WOULD BE DIFFERENT.
25
AND THE PROBLEM WITH THAT IS AND THERE LIKELY WAS
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1
EXPOSURE OCCURRING. AS A RESULT OF THAT.
THE
2
PROBLEM WITH THAT IS WE DON'T HAVE ANY WAY TO TRY
3
TO MEASURE OR ESTIMATE WHAT THOSE EFFECTS WERE.
4
MR. EARLE:
THEN FOR CLARIFICATION THE
5
POINT I WAS SAYING ABOUT WHAT YOU WERE SAYING
6
ABOUT AS FAR AS THE GROUND CONTAMINATION NOW
7
WHICH I CAN UNDERSTAND BUT IT STILL DOES NOT TELL
8
ME BASICALLY WHAT WAS HAPPENING IN THE TIME '83
9
LIKE I SAID, WHICH WOULD AFFECT THE CHILD AND
10
6 YEARS OLD.
CO~LD, POSSIBILITY.
THEN I CAN
11
LOOK AT IT ON THE OTHER HAND AND SAY WELL, MY
12
LITTLE DAUGHTER BORN IN 1978 DURING THE TIME THE
13
SITE WAS IN OPERATION.
14
MR. HAYES:
YOU'RE RIGHT.
THAT'S A
15
VERY GOOD POINT.
AND THE ONLY THING I CAN TELL
16
YOU IS EXPOSURE MAY HAVE OCCURRED IN THOSE
17
PERIODS.
AND THERE'S NO WAY FOR US TO MEASURE
18
THAT NOW OR EVEN TO TRY AND ESTIMATE IT.
AND 50
19
WE'RE LOOKING AT THE SITE AS THE WAY IT IS NOW
20
AND LEAVING IT UNREMEDIATED AND ASSESSING THE
21
RISKS THAT WOULD RESULT.
I DON'T THINK -- AND
22
THIS IS A QUESTION THAT COMES UP AT SITES A LOT.
23
WHAT ABOUT THE PERIOD WHEN IT WAS IN OPERATION.
24
WHAT ABOUT THE PERIOD BEFORE.
AND UNFORTUNATELY
25
THERE'S JUST NO REAL WAY FOR US TO ANSWER THOSE
HANWELL REPORTING SERVICE
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63
1
QUESTIONS FOR YOU SINCE THOSE TIMES ARE PAST.
2
THERE'S, NO WAY FOR US TO GATHER THAT EVIDENCE AND
3
MAKE ASSESSMENTS.
4
ONE FINAL QUESTION.
MR. EARLE:
YOU
5
DID MENTION SOMETHING ABOUT THE POSSIBILITY OF
6
CANCER.
WHAT IS THE LIKELIHOOD OF SOMEONE
7
GETTING CANCER AS FAR AS DURING THAT PARTICULAR
8
TIME OR DO THEY HAVE TO BE EXPOSED SAY FOR A
9
PERIOD OF TEN YEARS OR DO YOU KNOW ANYTHING ABOUT
10
THAT?
11
MR. HAYES:
WELL, THERE IS NO CLEAR
12
EVIDENCE THAT LEAD IS A CARCINOGEN.
LEAD HAS
13
VERY SERIOUS EFFECTS IN OTHER WAYS.
CENTRAL
14
NERVOUS SYSTEM EFFECTS AND SOME OF THE OTHERS
15
THAT I MENTIONED.
THERE IS NO CLEAR EVIDENCE
16
THAT LEAD IS A CARCINOGEN.
SO I GUESS THE ANSWER
17
TO YOUR QUESTION IS .WE WOULD NOT EXPECT TO SEE
18
CANCER AS A RESULT OF LEAD EXPOSURE.
NOW, THE
19
ONLY OTHER CONTAMINANT THAT WAS MENTIONED IN THE
20
RISK ASSESSMENT OR WAS CARRIED THROUGH THE RISK
21
ASSESSMENT THAT HAD ANY SIGNIFICANT LEVELS AND
22
MIGHT BE A CARCINOGEN IS THE 1,2-DICHLOROETHANE.
23
AND IT WAS FOUND AT SUCH LOW LEVELS THAT THE RISK
24
ASSOCIATED WITH THAT IS INFINITESIMALLY SMALL.
25
AND I DON'T THINK THAT YOU WOULD EXPERIENCE ANY
HANWELL REPORTING SERVICE
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64
1
SIGNIFICANT RISK FROM A LIFE TIME OF EXPOSURE TO
2
SOILS AT THOSE LOW LEVELS.
3
MS. HICKS:
WHAT DO YOU CONSIDER A
4
NORMAL LIFE TIME?
5
MR. HAYES:
WE USE 70 YEARS.
IF I
6
MAKE IT THAT LONG I WILL BE GREAT.
7
THE REASON I ASK THAT
MR. EARLE:
8
QUESTION I'M NOT SAYING IT WOULDN'T HAVE ANYTHING
9
TO DO WITH THAT BUT BY YOU HAVING CANCER IN YOUR
10
PRESENTATION AND THEN I CAN LOOK AT THE SITUATION
11
FROM MY WIFE WHO HAS IT IN 1988 AND I ASK WELL IS
12
THAT A POSSIBILITY OR IS IT NOT A POSSIBILITY?
13
I SEE WHAT YOU MEAN.
LET
MR. HAYES:
14
THE FIRST THING IS WE
ME ANSWER THAT TWO WAYS.
15
LOOKED AT THIS SITE UNDER VERY STRINGENT AND
16
CONSERVATIVE EXPOSURE SCENARIOS.
WE DIDN'T FIND
17
ANY CARCINOGENIC RISKS UNDER THE CURRENT
18
NOW, I KNOW THAT DOESN'T ADDRESS
CONDITIONS.
19
WHAT MIGHT HAVE GONE ON IN THE PAST.
SO FOR WHAT
20
THAT'S WORTH.
THE OTHER THING THAT I'LL SAY IS
21
THAT SINCE WE DIDN'T FIND ANY CARCINOGENIC RISKS
22
AT THIS SITE IT MIGHT HAVE BEEN BETTER IF I HAD
23
NOT TALKED ABOUT CARCINOGENIC RISKS AND RAISED
24
THOSE QUESTIONS.
ON THE OTHER HAND WE TRY TO BE
25
AS COMPLETE AS POSSIBLE WHEN WE TALK ABOUT RISKS
HANWELL REPORTING SERVICE
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65
1
ASSOCIATED WITH THE SITE AND TO BE HONEST THAT'S
2
JUST PART OF THE SHOW.
IT'S PART OF THE REGULAR
3
PRESENTATION I MAKE TO TALK ABOUT CARCINOGENIC
4
RISKS.
SO MAYBE IN THE FUTURE WHEN THERE ARE NO
5
CARCINOGENIC RISKS ASSOCIATED WITH THE SITE I MAY
6
PARE THAT PART OF THE TALK BACK A LITTLE BIT.
SO
7
,IF YOU DON'T MIND IF YOU HAVE ANY OTHER QUESTIONS
8
WE'RE GOING TO HAVE A QUESTION AND ANSWER SESSION
9
AT THE END AFTER YVONNE DOES THE REST OF HER
10
PRESENTATION.
AND I'LL STILL BE AROUND.
THANK
11
YOU.
12
MS. JONES:
OKAY.
AS MR. HAYES STATED
13
EARLIER 400 'MILLIGRAMS PER KILOGRAM WHICH IS THE
14
SAME AS 400 PARTS PER MILLION AND I'LL USE PARTS
15
PER MILLION BUT THEY'RE THE SAME THING, JUST'
16
ANOTHER TERM ANOTHER PERSON.
IS THE REMEDIATION
17
LEVEL FOR THE SOIL, SURFACE SOIL AT THE SITE.
18
BASED ON THIS DETERMINATION E.P.A. BASICALLY WENT
19
THROUGH AND LOOKED AT THE RESULTS OF THE DATA
20
PRESENTED TO US OR GATHERED FROM EACH OF THESE
21
SOIL SAMPLES AND DETERMINED OR TRIED TO DETERMINE
22
THE EXTENT OF LEAD CONTAMINATION AT THE SITE.
23
BASED ON THE DATA WE APPROXIMATED THAT PROBABLY
24
OR WE AT LEAST HAVE 1100 CUBIC YARDS OF
25
CONTAMINATED SOIL AT THE SITE THAT NEEDS TO BE
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66
1
REMEDIATED DOWN TO THE SAFE LEVEL OF 400 PARTS
2
PER MILLION.
3
MS. BROWN:
THE SHADED AREA IS WHAT
4
YOU'RE TALKING ABOUT NOW?
MS. JONES: CORRECT.
MS. BROWN: BOTH SHADED AREAS?
MS. JONES: CORRECT.
MS. BROWN: ALL RIGHT. PART OF THAT
IS THAT ON TOP OF THE TARMAC THERE ON THAT LOT?
MS. JONES: YES, MA'AM.
MS. BROWN: WAS IT. TESTED UNDER THE
TARMAC DOWN AT THAT AREA?
5
6
7
8
9
10
11
12
13
MS. JONES:
WELL, WE TESTED AT -- IF
14
YOU CAN ACTUALLY TELL IT, PR-04, PR-03 AND PR-02.
15
MS. BROWN:
BUT THAT WAS JUST ON THE
16
TARMAC, WASN'T IT?
17
MS. JONES:
CORRECT.
WELL, BASICALLY
18
WHAT WE DID WAS WE BORED DOWN THROUGH THE
19
ASPHALT.
20
MS. BROWN:
YOU DID BORE DOWN THROUGH
21
THAT.
MS. JONES:
CORRECT.
THE LEVEL THAT
23
YOU KNOW JUST THAT I CAN REMEMBER FOR THIS
24
PARTICULAR ONE HERE WAS 675.
THE LEVEL TAKEN AT
i5
THE SOIL SAMPLE LOCATION NUMBER 8 WHICH REALLY
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67
1
LOOKS LIKE IT'S ON THE TARMAC BUT ACTUALLY IT'S
2
THAT PARTICULAR RESULT WAS 425 OR 475.
OFF.
3
MS. BROWN:
IN OTHER WORDS, 400 PARTS
4
PER BILLION IS CONSIDERED SAFE?
5
MS. JONES:
PARTS PER MILLION,
6
CORRECT.
7
MS. BROWN:
IS CONSIDERED SAFE?
8
. MS. JONE S :
CORRECT.
9
AND YOU'RE SAYING THAT
MS. BROWN:
10
OVER THERE ON THE RIGHT ON THE SOIL AREA YOU
11
FOUND FOUR HUNDRED AND WHAT?
12
25.
IN OTHER WORDS, WE'RE
MS. JONES:
13
WANTING TO TAKE ALL AREAS THAT HAVE SOIL
14
CONTAMINATION ABOVE 400 AND REMEDIATE THOSE AREAS
15
DOWN TO 400.
400 PLUS.
16
MS. BROWN:
AND THEN THE FRONT AREA
17
THERE WHERE THE TANK USED TO SIT, YOU FOUND WHAT
18
THERE?
19
BASICALLY WE WERE GOING ON
MS. JONES:
20
SAMPLE LOCATION PR-01.
AND WHAT WE FOUND THERE
21
WAS 675.
22
MS. BROWN:
THAT'S WHERE THEY PUMPED
23
THE BATTERY ACID OUT OF THE SUMP UP INTO THAT
24
HOLDING TANK.
25
WHICH WOULD MAKE
MS. JONES:
CORRECT.
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68
1
SENSE WHY WE WOULD FIND A LEVEL ABOVE 400 THERE.
2
MS. BROWN:
WAS WAS THAT SUMP TANK
3
THEN UNLINED RIGHT THERE?
4
MS. JONES:
RIGHT HERE OR RIGHT THERE?
5
MS. BROWN:
BETWEEN THE BUILDING WHERE
6
YOU CALL THE WORK SHED.
7
MS. JONES:
OKAY.
OVER HERE?
8
MS. BROWN:
YES.
IN THERE WHERE THE
9
SUMP TANK WAS LOCATED.
WAS IT UNLINED?
10
MS. JONES:
IT WAS AN ASPHALT PAD
11
THERE BUT AT ONE TIME THE SUMP TANK WAS UNLINED.
12
IT WAS LITERALLY AN UNLINED PIT.
13
MS. BROWN:
DID YOU NOT CHECK THAT
14
AREA?
15
MS. JONES:
BASICALLY WE CHECKED THE
16
AREA HERE AND WE BASICALLY USED PR-01 TO TRY TO
17
ESTIMATE TO SEE IF THAT AREA WAS CONTAMINATED.
18
WHAT WE LOOKED AT IN LOOKING AT THE ASPHALT PAD
19
THERE WAS SEVERAL AREAS ON THE ASPHALT PAD WHERE
20
THERE WAS ACTUALLY I GUESS WHAT I WOULD CALL
21
STRESSED AREAS.
WHAT I MEAN BY STRESSED AREA IF
22
THERE WAS A SPILL OR IF THERE EVER WAS A SPILL
23
THERE IF THERE WERE ACTUALLY CRACKS IN THE
24
ASPHALT IT WOULD MAKE IT FAIRLY EASY FOR THE
25
CONTAMINATION TO FLOW DOWN TO THE SOIL.
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1
AND THE TARMAC IS NOT LIKE
MS. BROWN:
2
IT'S POROUS TO THE SENSE IT COULD HAVE
ASPHALT.
3
EVENTUALLY YEARS TO COME WOULD LEACH THROUGH.
4
CORRECT.
WHICH IS WHAT WE
MS. JONES:
5
FOUND IN THIS AREA, IN THESE AREAS.
6
MS. BROWN:
IS THIS AREA, WHAT WERE
7
YOUR FINDINGS THERE?
8
BASICALLY WE HAD A HIT OF
MS. JONES:
9
6500 PARTS PER MILLION.
10
THAT'S WHERE THEY BROUGHT
MS. BROWN:
11
THE TRUCKS IN AND DUMPTED THE BATTERIES
12
SUPPOSEDLY UNDERNEATH THAT SHED.
13
IN THIS AREA HERE I
MS. JONES:
OKAY.
14
THINK IT WAS AROUND 525 JUST OFF THE TOP OF MY
15
HEAD.
16
MS. BROWN:
THAT'S WHERE THEY HAD
17
WOODEN CRATES THAT THEY HAD THE GROUND UP BATTERY
18
CASINGS IN.
19
ALL OF THOSE DATA POINTS
MR. ROGERS:
20
ARE IN THE ACTUAL RECORD.
I THINK ONE POINT
21
YVONNE TRIED TO EMPHASIZE EARLIER WAS MOST OF THE
22
SAMPLES CAME IN BELOW THAT NUMBER.
23
MS. JONES:
THE MAJORITY OF THEM WERE
24
UNDER 400.
25
MR. ROGERS:
AND. IF THERE WERE ANY
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RESIDUALS FROM DUMPING AND THAT SORT OF THING
2
FROM LIQUIDS IN BATTERIES AND THAT SORT OF THING
3
YOU WOULD SEE IT WELL ABOVE THOSE LEVELS.
WHAT
4
WE SAW THROUGHOUT THE SITE IS RELATIVELY LOW
5
CONCENTRATIONS.
PARTIALLY BECAUSE THERE ALREADY
6
WE HAVE IDENTIFIED
WAS A CLEAN UP DONE THERE.
7
SOME THINGS THAT FOR THE MOST PART ARE SLIGHTLY
8
ABOVE OUR CLEAN UP GOAL OF 400.
THEREFORE WE ARE
9
PROPOSING TO GO OUT AND DO SOME REMEDIATION
10
DEALING WITH THAT.
THIS IS -- THE SKETCHED IN
11
AREA IS BASICALLY AN APPROXIMATION AND GUESS OF
12
THE ACTUAL AMOUNT OF CONTAMINATED SOIL BECAUSE AT
13
THIS STAGE WE DON'T HAVE ENOUGH SAMPLES TO
14
TOTALLY QUANTIFY THAT.
BUT WE DON'T REALLY NEED
15
WHEN WE GO IN THERE TO TRY TO
TO AT THIS POINT.
16
ACTUALLY REMEDIATE IT YOU COULD FURTHER QUANTIFY
17
THOSE STATIONS BETWEEN SAMPLE POINTS TO DETERMINE
18
JUST WHERE DO YOU HAVE CONTAMINATION ABOVE THE
19
400 AND DEAL WITH THE EXCAVATION AND REMOVAL OR
20
WHATEVER THE REMEDY HAPPENS TO BE.
THERE'S ONLY
21
TWO SAMPLES THAT WERE .ELEVATED AND ONE OF THOSE
22
COULDN'T BE REPRODUCED.
23
CORRECT.
WHICH WAS THIS
MS. JONES:
24
AREA.
25
MR. ROGERS:
BUT IN RELATIVE TERMS
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1
THERE'S A VERY LIGHT CONTAMINATION LEFT AT THIS
2
SITE BASED ON ALL THESE SAMPLE POINTS.
AND
3
THEREFORE YVONNE'S GOING TO GO INTO SLIDES
4
TALKING ABOUT CONSIDERATIONS OF DIFFERENT WAYS TO
5
DEAL WITH THIS SITE AND REMEDIATE IT.
AND AFTER
6
WE ACTUALLY SIGN THE RECORD OF DECISION WE'LL DO
7
SOME FURTHER ANALYSIS TO FIGURE OUT EXACTLY WHAT
8
SHOULD BE TAKEN OUT AND DEALT WITH AS WE REMEDY
9
IT.
10
MR. EARLE:
I HAVE ONE QUESTION.
I
11
THINK I HEARD EARLIER THESE PEOPLE OWNED 20
12
ACRES, RIGHT?
13
MS. BROWN:
RIGHT.
14
MR. EARLE:
AND MY QUESTION IS THAT
15
EVERYTHING THAT YOU HAVE DONE HAS BEEN DONE
16
AROUND ABOUT THE FIRST ONE POINT SOME ACRES
17
AROUND THE FRONT.
THESE PEOPLE HAVE BEEN GOING
18
APPROXIMATELY TWO AND A HALF MILES TO OLDHAM'S
19
GARAGE AND DUMPING ON THE BACK OF HIS PROPERTY.
. 20
NOW, IF THEY OWN 20 ACRES IF THEY WERE THAT
21
DEVIOUS TO DO IT ON SOMEONE ELSE'S PROPERTY WHY
22 .
. WOULD THEY NOT GO FURTHER BACK IN THOSE WOODS AND
23
DUMP IT ON PROPERTY THAT THEY OWN?
24
MS. BROWN:
THAT'S WHY I ASKED HAD
25
THEY TESTED BACK THERE.
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MR. ROGERS:
.WELL, THAT'S PROBABLY
2
TRUE FOR THE WHOLE NORTHWEST SECTOR OF COLUMBIA.
3
WHAT BASIS DO YOU USE TO GO OUT AND LOOK FOR
4
IF THERE'S INFORMATION
NEEDLES IN A HAYSTACK?
5
THAT HE WAS DUMPING SOMEWHERE ELSE USUALLY PEOPLE
6
AROUND THERE KNOW WHAT HE WAS DOING WHEN HE WAS
7
YOU SHOULD GET THAT INFORMATION TO US
OPERATING.
8
SO WE CAN PURSUE THOSE TIPS.
THERE'S NOTHING IN
9
THE RECORD THAT INDICATES THERE WAS ANY REASON TO
10
BELIEVE HE WENT OUT AND DID ANYTHING ON THE OTHER
11
PARTS OF THE ACRES THAT HE OWNED.
12
MR. EARLE:
WELL, YOU CAN HARDLY SEE
13
HIM IN THE RED TRUCK AND ASK HIM WHERE HE'S
14
GOING?
15
YES.
THAT'S WHAT I'M
MR. ROGERS:
16
THAT'S A WHOLE UNIVERSE.
AND THERE WOULD
SAYING
17
BE NO WAY OF IDENTIFYING WHERE TO START TO LOOK
18
FOR IT.
IF THERE WERE SOME KNOWLEDGE THAT
19
SOMETHING ELSE WAS GOING ON YOU CAN PASS THAT
20
BACK TO US AND WE CAN PURSUE IT.
BUT THE RECORD
21
AND STATE ACTIVITIES WITH THE STATE AND ANYTHING
22
ELSE FROM THE HISTORY OF THE SITE WOULD INDICATE
23
THAT HIS OPERATIONS AT THE SITE DEALT WITH THE
24
IMMEDIATE AREA THAT WAS INVESTIGATED.
AND YES
25
MAYBE HE DID SOMETHING OFF SITE.
IF YOU GIVE US
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1
MORE INFORMATION AS TO THAT WE'LL SEE THAT THAT'S
2
LOOKED INTO.
3
MR. HAYES:
THERE'S ONE OTHER THING
4
YOU MIGHT WANT TO REMEMBER ABOUT BATTERY CRACKING
5
OPERATIONS.
WE HAVE A LOT OF SUPERFUND SITES
6
THAT ARE BATTERY CRACKING OPERATIONS.
THEY WERE
7
CONDUCTING THE OPERATIONS TO RECLAIM THE LEAD.
8
SO THE ACTUAL LEAD PLATES THEY DIDN'T DISPOSE OF.
9
THAT'S WHAT THEY WANTED TO RESELL.
THE WASTE WAS
10
ASSOCIATED WITH THE SULFURIC ACID AND THE LIQUID
11
THAT THEY POURED OUT OF IT.
AND AT MOST- BATTERY
12
CRACKING SITES AND APPARENTLY AT THIS ONE, TOO,
13
THEY JUST DUMPED THAT RIGHT THERE WHERE THEY
14
CRACKED THE BATTERIES.
THERE WASN'T ANY POINT IN
15
TAKING THAT WASTE BACK IN THE WOODS AND POURING
16
IT OUT BECAUSE THEY WERE POURING IT OUT RIGHT
17
THERE AT THE SITE.
SO WHILE IT IS POSSIBLE THAT
18
THEY CONDUCTED SOME DISPOSAL OPERATIONS
19
ELSEWHERE, IF THIS SITE WAS LIKE MOST BATTERY --
20
MS. BROWN:
IT ISN'T POSSIBLE.
THEY
21
DID IT.
THEY WERE CAUGHT DOING IT.
22
MR. HAYES:
IF THIS SITE IS LIKE MOST
23
BATTERY CRACKING OPERATIONS THOUGH, THE REAL
24
PROBLEM IS THE WASTE ACID THAT THEY DUMPED RIGHT
25
ON THE SITE.
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1
MS. BROWN:
WELL, DHEC CAME TO MY
2
WE'RE BACK IN THAT PROPERTY.
ON THEIR
HOME.
3
PROPERTY WITHOUT THEIR KNOWLEDGE TO SEE IF THERE
4
WAS ANY ~OSSIBILITY THAT THEY HAD DUMPED BACK
5
THERE.
6
MR. ROGERS:
TYPICALLY IF THEY WERE TO
7
HAUL OFF THESE CASINGS YOU SHOULD HAVE SEEN
8
AS YOU SAID HE DUMPED IT RIGHT THERE.
EVIDENCE.
9
IT WAS JUST DUMPED IN THE CREEK OR IT WAS
10
CONTROLLED IN SOME PIT AND DEALT WITH AT A LATER
11
IN THAT BUSINESS THE LEAD IS PULLED OUT
POINT.
12
THEY'RE SENT OFF SITE.
ALL
AND RECYCLED.
13
THEY'RE DOING IS CUTTING OPEN BATTERY CASINGS AND
14
DRAINING THE LIQUID OUT AND DUMPING IT IN THAT
15
THE WASTE WAS CONTROLLED TO SOME EXTENT BY
AREA.
16
THE BIGGEST BULK OF WHAT IS LEFT IS
SOME TANKS.
17
THOSE PILE UP AND YOU HAVE TO DO
THE CASINGS.
18
YOU'RE SAYING THEY BURNED
SOMETHING WITH THEM.
19
THEM.
20
AND
MS. BROWN:
THEY GROUND THEM UP.
21
BEFORE THEY DID THAT WHEN
HELD THEM FOR A WHILE.
22
.DHEC CAUGHT THEM OR AT LEAST WHENEVER I CARRIED
23
THE SAMPLE TO DHEC TO SHOW THEM THAT THEY WERE
24
BURN~NG DOWN THERE ON THE PROPERTY.
25
THE ONLY THING THEY WOULD
MR. ROGERS:
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1
LATER AS THEY TRIED
BE BURNING WAS THE CASINGS.
2
TO CONTROL THE OPERATION WHILE THEY WERE PURSUING
3
PERMITTING THEY PUT THAT IN THE TRUCK AND WERE
4
TAKING IT SOMEWHERE.
5
, AND BEFORE THEY TOOK IT
MS. BROWN:
6
OVER THERE THEY WERE PUTTING IT UP IN THAT BIG
7
LONG TANK SITTING ON THE OUTSIDE BECAUSE THEY
8
WERE GETTING MORE THAN THE SUMP TANK WOULD HOLD.
9
MR. ROGERS:
IT'S ALSO CONCEIVABLE
10
IT'S NOT BEYOND THESE PEOPLE TO GO OUT AND JUST
11
DUMP IT IN THE SEWER.
12
MR. EARLE:
ANOTHER QUESTION I KNOW OF
13
THE RED TRUCK AND I KNOW THE RED TRUCK 'HAS PASSED
14
IT'S A NICE SIZED TRUCK.
IF YOU'RE
BY MY HOUSE.
15
GOING TO TAKE SOMETHING AWAY FROM YOUR PLACE AND
16
DUMP IT QUITE FRANKLY YOU'D HAVE THE WOODS RIG~T
17
YOU COULD NOT SEE
THERE.
IT'S THEIR PROPERTY.
18
WHAT WAS GOING ON BEHIND THEIR PROPERTY.
19
MR. ROGERS:
A LOT OF THINGS COULD BE
20
BACK THERE.
THERE'S A ROAD BACK INSIDE THE
21
PROPERTY.
22
IS IT POSSIBLE THAT E.P.A.
MS. BROWN:
23
WILL DO ANY TESTING ON THE REST OF THAT ACREAGE?
24
WE WOULDN'T WANT TO
MR. ROGERS:
25
COMMIT TO THAT RIGHT NOW.
WE'RE TRYING TO DEAL
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1
WITH THIS SITE, THE KNOWN SITE.
I THINK IF WE
2
HAD SOME CONFIRMATION
3
MS. BROWN:
YOU WERE TALKING ABOUT
4
TRYING TO TURN IT INTO A RESIDENTIAL AREA OR
5
SOMETHING THAT WOULD BE FEASIBLE FOR USE.
WHAT
6
WOULD SAY THAT THAT OTHER PART OF THE ACREAGE IS
7
NOT CONTAMINATED, TOO?
8
MR. ROGERS:
ALL WE'RE SAYING IS WE'RE
9
USING CLEAN UP STANDARDS BASED ON POTENTIAL
10
FUTURE USE OF RESIDENTIAL.
WE DON'T KNOW WHAT'S
11
GOING TO HAPPEN TO THAT PROPERTY.
WE HAVE NO
12
INTEREST IN IT OTHER THAN TO CLEAN IT UP TO WHAT
13
WE FEEL IS A PROTECTIVE LEVEL FOR A REALISTIC
14
FUTURE USE SCENARIO.
IT DOESN'T MEAN IT WILL
15
EVER BE USED FOR RESIDENTIAL.
16
MS. BROWN:
PROBABLY WON'T.
17
MR. ROGERS:
LET'S LET YVONNE FINISH
18
AND WE'LL BE MORE THAN HAPPY TO TALK TO YOU
19
AFTERWARDS ABOUT ANY OTHER CONCERNS OR ANY OTHER
20
THINGS YOU MIGHT HAVE.
21
MS. JONES:
TYPICALLY DURING THE
22
FEASIBILITY STUDY WHICH I WILL CAUSE THE FS FOR
23
THE DURATION OF THE MEETING, NORMALLY LOOKS AT
24
SEVERAL ALTERNATIVES IN ORDER TO REMEDIATE
25
CONTAMINATION AT THE SITE.
E.P.A. LOOKED AT
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77
1
THREE ALTERNATIVES.
AND THE REASON FOR THAT WAS
2
ONE THE AMOUNT OF CONTAMINATION ON THE SITE WAS
3
CONSIDERED LOW.
IN OTHER WORDS, USUALLY IF YOU
4
HAVE APPROXIMATELY 2,000 CUBIC YARDS OF SOIL THEN
5
YOU KNOW YOU'LL PROBABLY LOOK AT LEAVING IT ON
6
AND IN THIS CASE WE'RE ESTIMATING THAT WE
SITE.
7
HAVE APPROXIMATELY 1100 CUBIC YARDS OF SOIL.
THE
8
THREE ALTERNATIVES THAT WERE LOOKED AT WERE THE
9
FIRST ALT&RNATIVE BEING NO ACTION WHICH WOULD
10
AND BECAUSE OF THAT
LITERALLY BE DOING NOTHING.
11
WE WOULD BE LEAVING CONTAMINATION ON THE SITE.
12
BECAUSE WE ARE LEAVING CONTAMINATION ON THE SITE
13
WE'D H~VE TO DO LONG-TERM MONITORING OF THE SOIL
14
AND THAT LONG-TERM MONITORING
AND GROUND WATER.
15
BEING 30 YEARS.
AND OF COURSE THIS IS THE COST
16
ASSOCIATED WITH DOING NOTHING.
17
MS. BROWN:
E.P.A. WOULD BE
18
RESPONSIBLE FOR THE LONG-TERM CHECKING OF THE
19
MONITORING WELLS OR WHATEVER?
20
CORRECT.
AND AGAIN, YOU
MS. JONES:
21
WOULD BE LEAVING CONTAMINATION ON SITE.
THE
22
SECOND ALTERNATIVE TO BE CONSIDERED WAS LIMITED
23
ACTION WHICH WOULD CONSIST OF DEED RESTRICTIONS
24
ON THE SITE, PUTTING UP A FENCE AND OF COURSE
25
BECAUSE WE ARE LITERALLY STILL LEAVING
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1
CONTAMINATION ON THE SITE WE'D HAVE TO DO LONG
2
TERM MONITORING. OF THE SOIL AND GROUND WATER FOR
3
APPROXIMATELY 30 YEARS.
AND AS YOU CAN SEE, THE
4
COST ASSOCIATED WITH EITHER ONE OF THOSE IS LESS
5
THAN MAYBE $800,000.
IN OTHER WORDS, THE ONLY
6
THING YOU'RE DOING IN THIS PARTICULAR ALTERNATIVE
7
IS PUTTING UP A FENCE AND OF COURSE PUTTING DEED
8
RESTRICTIONS ON THAT SO THAT IT COULD NOT BE USED
9
AS RESIDENTIAL.
10
THE THIRD ALTERNATIVE WHICH E.P.A.
11
CONSIDERED WAS EVACUATION AND OFF SITE DISPOSAL
12
TO EITHER A NON HAZARDOUS LANDFILL OR A HAZARDOUS
13
LANDFILL.
BASICALLY IF THE CONTAMINATION WAS
14
REMOVED OFF SITE YOU WOULD NOT HAVE TO DO
15
LONG-TERM MONITORING OF THE SOIL BECAUSE YOU HAVE
16
REMOVED THE SOURCE LITERALLY.
HOWEVER, TO ENSURE
17
THAT WE ARE STILL BEING PROTECTIVE OF THE GROUND
18
WATER WHICH WAS THE CONCERN EARLIER E.P.A. WOULD
19
STILL MONITOR THE GROUND WATER ON AN ANNUAL BASIS
20
FOR FIVE YEARS.
BASICALLY THE REASON WHY WE HAVE
21
TWO DIFFERENT COSTS IS IF THE WASTE WINDS UP
22
GOING TO A NON HAZARDOUS LANDFILL THAT COST WOULD
23
BE APPROXIMATELY $241,000.
IF THE WASTE WAS TO
24
GO TO A HAZARDOUS LANDFILL -- IN OTHER WORDS ONCE
25
WE --
HANWELL REPORTING SERVICE
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79
1
MS. BROWN:
WHERE DO WE HAVE A
2
HAZARDOUS LANDFILL?
3
THE ONE THAT WE LOOKED AT
MS. JONES:
4
I'M NOT SAYING THAT'S
I THINK WAS IN DORCHESTER.
5
WHERE THIS WOULD GO.
WHAT WOULD HAPPEN IS -- AND
6
THAT'S WHY WE HAVE AN EITHER/OR HERE.
BASICALLY
7
WHAT WE DO WHEN WE GO OUT TO THE SITE WE WILL
8
BASICALL~ TEST THE SOIL TO SEE IF IT'S CONSIDERED
9
BASICALLY THERE ARE
HAZARDOUS OR NON HAZARDOUS.
10
CERTAIN REQUIREMENTS AND CERTAIN LEVELS THAT WE
11
HAVE TO OBTAIN AND THAT LEVEL WILL DETERMINE
12
WHETHER OR NOT IT WILL GO TO A HAZARDOUS OR NON
13
HAZARDOUS LANDFILL.
14
THE COST ASSOCIATED WITH IT GOING TO A
15
HAZARDOUS LANDFILL IS $940,000 AND THE REASON FOR
16
THAT INCREASE IS WE WOULD NOT BE TREATING IT ON
17
BUT OF COURSE IN ORDER FOR IT TO GO TO
SITE.
18
THAT HAZARDOUS LANDFILL THEY WOULD HAVE TO TREAT
19
IT THERE FOR PROPER DISPOSAL.
20
E.P.A. BASICALLY USES NINE CRITERIA IN
21
THE FIRST
EVALUATING THE DIFFERENT ALTERNATIVES.
22
. TWO CRITERIA ARE WHAT WE WOULD CALL THE THRESHOLD
23
CRITERIA.
BASICALLY THAT CONSISTS OF THE OVERALL
24
PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT IN
25
COMPLIANCE WITH APPLICABLE AND RELEVANT AND
HANWELL REPORTING SERVICE
-------
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1
APPROPRIATE REQUIREMENTS.
THESE TWO ARE THE MOST
2
IMPORTANT IN THAT THEY ARE TO ENSURE THAT THAT
3
PARTICULAR REMEDY IS BEING PROTECTIVE OF THE
4
PUBLIC HEALTH AND THE ENVIRONMENT.
BASED ON THE
5
EVALUATION, ALTERNATIVE 1 AND ALTERNATIVE 2 WERE
6
RULED OUT.
ONE BECAUSE ALTERNATIVE 1 WE WEREN'T
7
GOING TO LITERALLY BE DOING ANYTHING ON THE SITE.
8
WE DO HAVE LEVELS ABOVE 400 PARTS PER MILLION
9
WHICH AS MR. HAYES STATED BEFORE THAT IS
10
CONSIDERED VERY UNSAFE.
AND TWO, ALTERNATIVE 2,
11
EVEN THOUGH WE WOULD BE PUTTING UP FENCES AND
12
DEED RESTRICTIONS WE WOULD STILL BE LEAVING
13
CONTAMINATED WASTE ON SITE.
ALTERNATIVE 3 IS
14
PROTECTIVE OF THE ENVIRONMENT AND PUBLIC HEALTH.
15
E.P.A. ALSO USED WHAT WE WOULD CALL
16
BALANCING CRITERIA.
WE LOOK AT THE COSTS, HOW
17
EASY IT IS TO IMPLEMENT IT, THE SHORT TERM
18
EFFECTIVENESS, THE LONG-TERM EFFECTIVENESS.
IN
19
OTHER WORDS, IS IT GOING TO BE PERMANENT OR IS IT
20
SOMETHING THAT WE'RE GOING TO HAVE TO COME BACK
21
AND CHECK ON AND IF THERE'S STILL A PROBLEM STILL
22
DO SOMETHING.
IN ADDITION TO THAT WE ALSO LOOKED
23
AT THE REDUCTION OF TOXICITY, MOBILITY AND THE
24
VOLUME THROUGHOUT THE TREATMENT.
AT THIS TIME
25
E.P.A~ HAS USED THE FIRST SEVEN OF THE NINE
HANWELL REPORTING SERVICE
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81
1
CRITERIA TO EVALUATE THOSE ALTERNATIVES.
THE
2
OTHER ~WO CRITERIA CONSIST OF THE STATE
3
ACCEPTANCE WHICH IS CONSIDERATION OF THE 'STATE'S
4
OPINION OF THE PREFERRED ALTERNATIVE AND THE 9TH
5
CRITERIA IS COMMUNITY ACCEPTANCE WHICH IS THE
6
CONSIDERATION OF PUBLIC COMMENT ON THE PROPOSED
7
PLAN WHICH I'M SURE MANY OF YOU RECEIVED IN THE
8
MAIL.
9
BASICALLY E.P.A.'S PREFERRED ALTERNATIVE IS
10
ALTERNATIVE 3 WHICH CONSISTS OF EXCAVATION AND
11
OFF SITE DISPOSAL WH~CH INCLUDES EXCAVATION OF
12
SURFACE SOILS DOWN TO A LEVEL OF ONE FOOT.
AND
13
AGAIN AS I STATED BEFORE AND I GUESS WHICH I WAS
14
SHOWING THE AERIAL MAP OF THE EXTENT OF LEAD
15
CONTAMINATION WE WOULD BE LOOKING AT THOSE AREAS
16
TO REMEDIATE THEM DOWN TO A LEVEL OF 400 PARTS
17
PER MILLION.
18
AGAIN AT THIS TIME WE DO NOT KNOW WHETHER OR
19
NOT IT WILL BE -- WHETHER THE WASTE WILL BE SENT
20
TO A NON HAZARDOUS WASTE LANDFILL OR A HAZARDOUS
21
WASTE LANDFILL.
AT THE TIME THAT WE ACTUALLY GO
22
OUT AND EXCAVATE THE SOIL WILL BE TESTED.
AND
23
DEPENDING ON THAT NUMBER -- IN OTHER WORDS, IE
24
YOU KNOW THE SOIL OR LEACHABILITY OF THE SOIL
25
EXCEEDS 5 PARTS PER MILLION FOR LEAD -- AND I
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1
GUESS I SHOULD BACK UP.
IN OTHER WORDS, IF YOU
2
HAVE SOIL AND YOU HAVE SOIL I GUESS WITH LEAD
3
CONTAMINATION WITHIN SOIL.
WHAT LEACHABILITY
4
MEANS IS JUST THE ABILITY OF LEAD TO LEACH
5
THROUGH THE SOIL FARTHER DOWN AND JUST BE MOBILE
6
AND LEACH TO GROUND WATER.
THAT'S REALLY WHAT
7
LEACHABILITY MEANS.
8
AND.I GUESS AT THIS TIME THAT WOULD CONCLUDE
9
I GUESS OU~ ALTERNATIVESi
I GUESS NOW IS A GOOD
10
TIME FOR QUESTIONS.
11
MS. ANDERSON:
I'M JUST WONDERING WHY
12
THEY OPENED THE GATE THERE.
MS. JONES: .WHY THEY OPENED THE GATE?
MS. ANDERSON: YES.
MS. BROWN: WHY THE GATE IS OPEN NOW.
MR. NEILSEN: IT'S BEEN OPEN FOR ABOUT
THREE WEEKS. I THOUGHT SOMEONE WAS IN THERE
13
14
15
16
17
18
WORKING OR SOMETHING BECAUSE THE GATE IS ALWAYS
19
OPEN.
20
MS. JONES:
I DON'T THINK SO.
I DON'T
21
THINK WE'VE BEEN ON SI~E.
22
MR. NEILSEN:
IT'S BEEN OPEN FOR THREE
23
WEEKS.
FOUR WEEKS AGO WE WALKED BY AND IT WAS
24
CLOSED.
AND THEN THREE WEEKS AGO WE WALKED BY
25
AND IT WAS OPEN.
AND IT'S BEEN OPEN EVER SINCE.
HANWELL REPORTING SERVICE
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1
MS. HICKS:
EVEN WHEN THEY WAS
2
REPAIRING THE BRIDGE THE GATE WAS OPEN.
3
MS. JONES:
I GUESS SOMETHING 'THAT I
4
DID NOTICE REALLY EVEN THOUGH WE HAVE THAT GATE
5
THERE AS EVERYONE PROBABLY KNOWS RIGHT NOW ANYONE
6
CAN WALK ON THAT SITE.
I'M NOT REALLY FOR
7
.CERTAIN THAT --
8
MR. NEILSEN:
IT'S NOT A SECURE SITE.
9
MS. BROWN:
IT MAINLY STOPS CARS FROM
10
GOING IN THERE.
11
MR. ROGERS:
WHEN WE FIRST GOT
12
INVOLVED IN THE SITE ONE OF THE CONCERNS WAS THE
13
OPEN PIT IN WHERE THE SCALES USED TO BE.
AND THE
14
FACT THAT PEOPLE HUNG OUT IN THERE.
SO ONE OF
15
THE EFFORTS THAT WE DONE WAS TO GO IN AND TEST
16
WHAT WAS IN THE PIT TO MAKE SURE THERE WASN'T
17
ANYTHING HAZARDOUS IN THERE AND TO BACK FILL THE
18
HOLE.
WE ALSO PUT THAT GATE ACROSS THERE AND
19
DECIDED NOT TO FENCE THE SITE BECAUSE WE DIDN'T
20
KNOW HOW LONG THE FENCE WOULD STAY THERE BECAUSE
21
WE ASSUMED SOMEBODY WOULD TAKE IT.
AND IT'S NOT
22
THE MOST DESIRABLE PLACE TO HANG OUT.
AND AS
23
BERNIE WAS TALKING ABOUT SOMEBODY WALKING ON TRAT
24
SITE DOESN'T EXPERIENCE AN UNACCEPTABLE HEALTH
25
RISK WITH INFREQUENT TRESPASSING IS WHAT WE CALL
HANWELL REPORTING SERVICE
-------
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1
THAT'S LEGALLY WHAT IT IS.
BUT WE HAVEN'T
IT.
2
TAKEN ANY OTHER MEASURES BECAUSE NOW THAT WE'VE
3
BEEN THROUGH THE REMEDIAL INVESTIGATION AND FOUND
4
OUT WHAT IS TRULY AT THE SITE AND LOOKED AT THE
5
RISK ASSESSMENT APPROACH WE DON'T FEEL LIKE
6
THERE'S ANY CURRENT EXPOSURE ROUTE UNLESS YOU
7
STUCK SOMEBODY OUT THERE AND THEY BASICALLY LIVED
8
OUT THERE AND PLAYED IN THE SOIL.
SO I THINK I'M
9
LESS CONCERNED ABOUT WHETHER THEY CAN WALK AROUND
10
THE GATE VERSUS WHY IS THE GATE OPEN.
AND THEY
11
CAN GO BY TOMORROW AND CHECK AND SEE WHY IT'S
12
OPEN AND WE CAN PUT A PADLOCK BACK ON.
BUT WE
13
MIGHT WANT TO LOOK INTO WHY SOMEBODY IS IN THERE
14
AT ALL.
15
MS. JONES:
ONE QUICK THING THAT I
16
NEED TO ADD, AGAIN THIS IS E.P.A.'S PREFERRED.
17
ALTERNATIVE.
AND AS I STATED BEFORE YOU KNOW
18
BEFORE FINALIZING ANYTHING WE WOULD TAKE COMMENTS
19
FROM THE STATE AND ALSO COMMENTS FROM THE
20
CITIZENS TO SEE HOW DO YOU FEEL.
DO YOU FEEL
21
COMFORTABLE WITH THIS ALTERNATIVE.
AS EVERYONE
22
PROBABLY KNOWS THE COMMENT PERIOD STARTED ON
23
NOVEMBER 22ND AND AS OF RIGHT NOW IT WOULD BE
24
CONTINUED THROUGH DECEMBER 22.
IF AN EXTENSION
25
HAS NOT BEEN REQUESTED BY THAT TIME E.P.A. WILL
HANWELL REPORTING SERVICE
-------
~~
1
BASICALLY MOVE TOWARDS WHAT WE WOULD CALL A
2
RECORD OF DECISION.
BASICALLY WHAT THAT IS IS A
3
DECISION AS TO WHAT REMEDY WILL BE USED TO
4
REMEDIATE THE SITE.
AS CYNTHIA STATED EARLIER AN
5
EXTENSION CAN BE REQUESTED AT ANY TIME DURING THE
6
PUBLIC COMMENT PERIOD.
7
MR. MOSSER:
MY NAME IS GLEN MOSSER. I
8
LIVE ABOUT FOUR MILES FROM THE SITE.
AND I WANT
9
TO SAY THAT I AGREE WITH YOUR ALTERNATIVE AND I
10
APPRECIATE THE GOVERNMENT'S CONTINUING TO FOLLOW
11
THIS THING THROUGH TO A SATISFACTORY CONCLUSION
12
FOR US.
I'VE GOT A COUPLE OF QUESTIONS THOUGH.
13
IF YOU DON'T HAVE ANY EXTENDED COMMENT PERIOD AND
14
YOU DECIDE TO GO AHEAD WITH THIS ALTERNATIVE WHEN
15
WOULD THE WORK BEGIN, HOW LONG WOULD IT TAKE AND
16
WOULD THERE BE ANY EXPOSURE TO THE PEOPLE THAT
17
LIVED IN THE IMMEDIATE AREA AND SPECIFICALLY
18
ACROSS THE STREET AND UP THE HILL WHILE THIS WAS
19
BEING DISLODGED AND LOADED IN TRUCKS AND SOMEBODY
20
WAS TALKING ABOUT WIND BLOWING AND CREATING DUST.
21
IS THERE ANY HAZARD TO THE FOLKS WHILE THE
22
REMEDIATION IS GOING ON?
23
MS. JONES:
I GUESS THE FIRST PART OF
24
YOUR QUESTION AS FAR AS WHEN WOULD THE WORK TAKE
25
PLACE OR A HOW LONG WOULD IT TAKE PLACE,
HANWELL REPORTING SERVICE
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1
BASICALLY AS WE TALKED ABOUT EARLIER THERE ARE
2
POTENTIALLY RESPONSIBLE PARTIES WHICH WE WILL
3
HAVE TO NOTICE UPON THE SIGNING OF THE RECORD OF
4
DECISION.
AT THAT TIME THEY ARE GIVEN A CERTAIN
5
TIME LIMIT TO ACTUALLY DETERMINE WHETHER OR NOT
6
THEY WOULD LIKE TO CONDUCT THE CLEAN UP
7
THEMSELVES OF COURSE WITH E.P.A.'S OVERSIGHT OR
8
WHETHER OR NOT THEY DO NOT WANT TO CONDUCT IT.
9
TYPICALLY NEGOTIATIONS WHICH IS WHAT WE WOULD
10
CALL THAT MAY LAST ANYWHERE FROM -- REALLY JUST
11
DEPENDS ON THE PARTIES THAT YOU'RE WORKING WITH.
12
BUT YOU KNOW AT LENGTH YOU'RE PROBABLY LOOKING AT
13'
A THREE TO FOUR MONTH TIME PERIOD BEFORE THAT
14
WOULD BE WORKED OUT.
15
AS FAR AS THE ACTUAL WORK BEING DONE ON THE
16
SITE YOU PROBABLY WILL NOT SEE THAT DUE TO ITS A
17
BEHIND THE SCENES PROCESS GOING ON.
YOU PROBABLY
18
WOULDN'T SEE THAT UNTIL MAYBE EARLY -- LATE
19
SUMMER OR EARLY FALL.
IT REALLY JUST DEPENDS ON
20
THE OUTCOME OF THAT.
21
THERE'S A LOT OF UNKNOWNS
MR. ROGERS:
22
IN THERE.
THE ENFORCEMENT ISSUE WE WOULD HAVE TO
23
BY LAW PURSUE IF THERE ARE VIABLE PARTIES OUT
24
THERE.
IT MAY BE THEY JUST WON'T WANT TO TALK TO
25
US OR WHATEVER.
THAT COULD TAKE UP A SMALL PART
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18
19
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t) I
OF TIME OR A LONG PERIOD OF TIME.
IF WE DO THE
WORK WE ARE GOING TO HAVE TO HAVE A DESIGN
CONTRACTOR COME IN AND DO A LITTLE DESIGN WORK TO
BETTER IDENTIFY THE AREA THAT NEEDS TO BE
EXCAVATED.
THAT WILL BE WORKED OUT IN THE
DESIGN.
WE TRY TO STREAMLINE THAT AND SHORTEN IT
BUT IT JUST TAKES A COUPLE OF MONTHS TO GET THOSE
TYPES OF CONTRACTORS IN ORDER TO ENSU~E WE GET
THE BEST PRICE AND THEN PURSUING IMPLEMENTATION.
IT REALLY CAN BE DONE IN A COUPLE OF WEEKS.
IT'S
NOT A BIG JOB.
BUT DURING THAT TYPE OF WORK
WHICH IS WHAT I DID FOR FIVE YEARS IN THE AGENCY~
YOU CAN DO FOGGING TO DO DUST CONTROL SHOULD
THERE BE CONCERN OF THINGS BLOWING OFF SITE WHILE
YOU'RE DOING EXCAVATION.
SO THERE'S REALLY
SIMPLE TECHNIQUES FOR CONTROLLING THAT DURING THE
EXCAVATION.
THE ONLY CONCERN WOULD BE SOME KIND
OF WIND TRANSPORTING IT DURING THE EXCAVATION AND
HAULING IT OUT.
MR. MOSSER:
CAN I MAKE ONE OTHER
COMMENT?
I THINK PART OF THE PROBLEM DEALING
WITH STATE GOVERNMENT AND LOCAL GOVERNMENT AND
FEDERAL GOVERNMENT, PART OF THE COMMUNITY'S
CONCERN WAS THAT WE THOUGHT IT WAS A BAD
SITUATION TO START WITH AND TRIED TO GET THE
HANWELL REPORTING SERVICE
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~~
1
AUTHORITIES TO AGREE WITH US AND THEY JUST SORT
2
OF RAN OVER US AND WE WOUND UP BEING A SUPERFUND
3
SITE.
THAT'S ONE OF THE REASONS WE'RE NOT REAL
4
COMFORTABLE WITH THE GOVERNMENT'S APPROACH TO
5
BUT YOU BRING UP A POINT THAT I AS A
THINGS.
6
CONTRACTOR WOULD HAVE A CONCERN OR ANY OTHER OF
7
US WHO ARE NOW USING RECYCLING CENTERS AND TAKING
8
OIL TO THESE COLLECTION PLACES.
WHAT YOU'RE
9
REALLY SAYtNG IS THAT THIS OPERATION AT ONE TIME
10
WAS DEEMED TO BE ACCEPTABLE AND DESIRABLE TO
11
RECYCLE THINGS.
12 .
MR. ROGERS:
NO.
13
MR. MOSSER:
MY QUESTION IS IS THERE
14
GOING TO BE A POINT IN TIME WHEN THE GOVERNMENT
15
IS GOING TO COME BACK TO ME BECAUSE I PUT FIVE
16
QUARTS OF OIL IN A RECYCLING CENTER SOMEWHERE AND
17
THIS STUFF IS BACK.
WE WANT YOU TO HELP CLEAN IT
18
UP NOW.
19
MR. ROGERS:
THAT'S TWO QUESTIONS.
20
THE FIRST ONE IS NO.
THE SECOND ONE IS I DON'T
21
KNOW.
WE DO HAVE THAT PROBLEM WITH RECYCLING.
22
SOME OF THEM GO UNDER.
IT'S A PROBLEM THAT
23
UNFORTUNATELY THIS OCCURRED IN THE EARLY '80S.
24
THE GOVERNMENT WASN'T DOING A WHOLE LOT TO
25
CONTROL THAT KIND OF OPERATION BACK THEN.
THERE
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WERE A LOT OF GOOD INTENDING FACILITIES THAT DID
2
MARGINAL WORK IN THEIR HARDWARE INVESTMENTS,
3
THEIR CAPITAL INVESTMENTS AND ENDED UP FOLDING.
4
AND YOU CAN SPECULATE AS TO WHY.
THEY'RE
5
FLY-BY-NIGHT OR DIDN'T HAVE ANY BETTER GUIDANCE.
6
THERE'S A WHOLE LOT MORE CONCERN ABOUT REGULATION
7
IN THAT MATERIAL AND THOSE RECYCLING CENTERS
8
TODAY SUCH THA~ EVERYBODY WAS ON THE BAND WAGON
9
TO RECYCLE A YEAR AGO.
NOW WE'RE FINDING THAT
10
WE'RE ACCUMULATING THINGS THAT THERE IS NO MARKET
11
TO RECYCLE.
RECYCLERS ARE CUTTING BACK ON THE
12
MATERIAL THEY WANT TO TAKE BECAUSE OF LIABILITY,
13
BECAUSE OF THE INABILITY TO MAKE ANY MONEY OFF OF
14
IT.
WASTE OIL HAS BEEN A PROBLEM FOR AT LEAST
15
FIVE YEARS BECAUSE OF CONTROLS ON THE PRICES THEY
16
COULD CHARGE FOR THE OIL WHEN IT WAS RECYCLED AND
17
THEY DID GENERATE A LARGE AMOUNT OF WASTE, FAIRLY
18
TOXIC WASTE, IN RECYCLING WASTE OIL.
AND YES, WE
19
GENERALLY AVOID GOING AFTER INDIVIDUALS WHO ARE
20
RECYCLING.
BUT THAT'S ONE OF THE CONTROVERSIES
21
OF THE SUPERFUND.
IT'S A RETROACTIVE LAW THAT
22
GOES BACK TO AND TRIES TO GO AFTER ANYBODY WHO
23
GENERATED OR TRANSPORTED OR COOPERATED WITH IN
24
ANY WAY THAT FACILITY.
THAT'S PROBABLY GOING TO
25
CHANGE IN THE NEAR FUTURE.
THE INDIVIDUAL IS NOT
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A MAJOR CONCERN IF YOU'RE GOING TO A RELIABLE
2
BUT ,YOU WOULDN'T JUST GIVE STUFF TO
COMPANY.
3
SOMEBODY THAT GOES DOWN THE ROAD AND ASSUME
4
YOU'RE DOING THE RIGHT THING.
THEY NEED TO LOOK
5
LIKE A RELIABLE COMPANY WITH REASONABLE
6
INVESTIGATION ON YOUR PART.
THIS SITE WAS NEVER
7
SANCTIONED BY THE ENVIRONMENTAL AGENCIES. ' IT'S
8
IT APPROACHED DHEC FOR A
STARTED ON ITS OWN.
9
PERMIT TO DISCHARGE AND WAS REFUSED A PERMIT AND
10
NEVER WAS A PERMITTED FACILITY.
11
MS. BROWN:
IT NEVER WAS PERMITTED?
12
MR. ROGERS:
NO, THEY NEVER WERE.
13
THEY DIDN'T GET ~HE FIRST
MS. BROWN:
14
ONE, LET ALONE THE LAST ONE.
15
MR. ROGERS:
SO YOU CAN'T REALLY SAY
16
17
MR. MOSSER:
IT WAS NOT EFFECTIVELY
18
SHUT DOWN.
19
MR. ROGERS:
UNFORTUNATELY THE LAWS
20
DON'T GIVE US DICTATORIAL AUTHORITY.
AND IN
21
FACT THE STATE WENT IN AND DID A LOT OF THINGS.
22
THE STATE TOOK ACTION EARLY ON.
IT DID A
23
SIGNIFICANT AMOUNT OF CLEAN UP.
I WORKED IN THE
24
EMERGENCY RESPONSE PROGRAM FOR DBEC MANY YEARS.
25
WE WENT OUT.
BUT THERE WAS INABILITY FOR YEARS
HANWELL REPORTING SERVICE
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TO COME UP WITH HOW CLEAN IS CLEAN.
THE RISK
2
ASSESSMENT APPROACH DOES THAT BUT IT'S A VERY
3
COMPLICATED AND LABORIOUS APPROACH THAT HAS TO BE
4
GONE THROUGH ON THE REMEDIATION SIDE TO FIGURE
5
OUT WHAT'S LEFT.
WHAT WE'RE SAYING IS "YOU HAVE
6
RELATIVELY LOW CONTAMINATION OUT THERE WHICH IS
7
WHY I WOULDN'T GET TOO EXCITED ABOUT DUST BLOWING
8
ACROSS THE STREET.
IT BARELY ABOVE FOR THE MOST
9
PART OUR CLEAN UP GOAL OF 400.
BUT WE DID HAVE A
10
COUPLE OF HITS AND ONE OF WHICH WE CAN'T
11
REPRODUCE.
SO THERE'S VERY SPORADIC
12
CONTAMINATION.
13
MS". BROWN:
YOU COULDN'T GO BACK IN
14
THE SAME SPOT AND GET THE SAME AMOUNT AGAIN?
15
MR. ROGERS:
OUT OF THE ROAD SIDE
16
DITCH WE COULD NOT WHICH TELLS YOU THERE'S VERY
17
SPORADIC CONTAMINATION OUT THERE.
BUT TO BE ON
18
THE SAFE SIDE WHEN WE WENT BACK AGAIN" AND LOOKED
19
AT THE SITE THERE WAS A RELATIVELY HIGH HIT AND
20
WE BASICALLY DECIDED THAT IT THREW OUR AVERAGE UP
21
HIGH ENOUGH THAT WE SHOULD GO IN AND DO SOME
22
REMEDIATION OF THE SOIL.
AT ONE POINT IN TIME WE
23
THOUGHT THIS SITE WAS A NO ACTION SITE BECAUSE IT
24
IS MARGINALLY CONTAMINATED ABOVE WHAT WE WOULD
25
CONSIDER A SAFE LEVEL.
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MR. MOSSER:
JUST A POINT OF
2
INFORMATION, IS YOUR REASONING FOR NOT
I
3
.DELINEATING ANYTHING ON THE DEED OR TALKING ABOUT
4
RESTRICTIONS INDIFFERENT TO THE PROPERTY OWNERS
5
AROUND THE SITE?
IF SOMEWHERE DOWN THE ROAD IT
6
DEVALUES THEIR PROPERTY BECAUSE YOU GOT THIS.
7
MR. ROGERS:
NO.
WE'RE CHARGED WITH
8
CLEANING IT UP TO A SAFE FUTURE USE SCENARIO.
A
9
REASONABLE FUTURE USE SCENARIO.
WHAT WE'RE USING
10
IS FUTURE RESIDENTIAL BECAUSE IT'S NOT BEYOND
11
IMAGINATION THAT THAT SITE GOES MORE RESIDENTIAL
12
THAN COMMERCIAL.
MY ARGUMENT FOR THE SPECIFIC
13
SITE IS IT'S A LITTLE LESS OBVIOUS FOR THAT SITE
14
BECAUSE MOST PEOPLE AREN'T GOING TO SPEND THE
15
MONEY TO BUILD A HOUSE AND FILL IN WHEN YOU CAN
16
GO RIGHT UP THE ROAD AND BUILD A HOUSE OVER
17
THERE.
SO YOU KNOW IT'S -- WE'RE USING FUTURE
18
RESIDENTIAL BECAUSE THE AREA COULD GO
19
RESIDENTIAL.
NOT THE MOST LIKELY THING THAT WILL
20
EVER HAPPEN.
21
MR. HAYES:
PLUS REMEMBER THAT THE
. 22
DEED RESTRICTION WAS PART OF THE ALTERNATIVE THAT
23
DIDN'T INVOLVE ANY SITE CLEAN UP.
SINCE WE'RE
24
PROPOSING TO CLEAN THE SITE UP IF WE DO THERE
25
WON'T BE ANY NEED FOR DEED RESTRICTIONS.
THE
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SITE COULD REALLY BE USED FOR ANY PURPOSE.
2
MR. ROGERS:
THE REASON WE AVOID DEED
3
RESTRICTIONS ON THE CLEAN UP SITE IS IT'S MORE
4
PROTECTIVE AND WE'RE NOT GOING TO ENSURE THOSE
5
DEED RESTRICTIONS AND IN THIS CASE WE CAN JUST GO
6
IN AND REMEDIATE THE SITE AND DEAL WITH IT.
7
THERE'S NO REASON TO NEED THE DEED RESTRICTIONS
8
OTHER THAN THE PLACE WILL ALWAYS BE IDENTIFIED AS
9
HAVING BEEN A HAZARDOUS WASTE SITE AND THAT IN
10
BUT FOR ALL PRACTICAL
AND OF ITSELF TAINTS IT.
11
PURPOSES IT WILL BE CLEAN.
THAT'S THE EXTENT OF
12
WHAT WE'RE TRYING TO DO.
AND WE REALLY ARE IN NO
13
WAY TAXED BY THE LAW TQ GET INVOLVED IN ZONING OR
14
REHAB OF THE PROPERTY VERSUS JUST CLEANING IT UP
15
FOR A SAFE CLEAN UP.
16
MS. BROWN:
THE PEOPLE THAT OWNED IT
17
PLUS THE PEOPLE THAT'S BACKED IT ARE THEY GOING
18
TO BE ABLE TO BE FORCED TO PAY?
19
MR. ROGERS:
WE CBRTAINLY PURSUE ALL
20
THOSE.
BUT IN ORDER TO GET THINGS MOVING WE DO
21
QUICK SEARCHES TO FIGURE OUT WHO COULD BE LIABLE
22
AND WE DO NEGOTIATIONS.
WE START USING FEDERAL
23
MONEY TO PURSUE IT.
ANY TIME WE SPEND FEDERAL
24
MONEY WE ALWAYS TRY TO GET IT BACK FROM ANYBODY
25
WHO HAS INVOLVMENT IN THE SITE.
BUT WE START
HANWELL REPORTING SERVICE
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1
WE FINISH THE RI/FS WHEN WE
WITH THE PROCESS.
2
COULD HAVE SPENT TWO YEARS MESSING AROUND WITH
3
TRYING TO NEGOTIATE AND FIND PEOPLE.
4
NOW BY THIS POINT IN TIME WE'VE USUALLY
5
SPENT THE LAST TWO YEARS DOING MORE THOROUGH PRP
6
SEARCHES SO THAT WE'RE READY TO DO NEGOTIATIONS
7
AND DEAL WITH THOSE ISSUES AS WE SIGN THE RECORD
8
OF DECISION AND WANT TO START PURSUING DESIGN AND
9
IMPLEMENTATION.
WE DO HAVE A FAIRLY LENGTHY LIST
10
OF NAMES.
ONE OF THE PROBLEMS IS USUALLY
11
DOCUMENTATION IS NOT VERY GOOD.
AND MOST OF
12
THOSE PEOPLE WERE VERY --
13
MS.. BROWN:
WHY NOT?
14
MR. ROGERS:
THESE ARE. RECORDS THAT WE
15
JUST FIND.
THERE'S NOT GREAT RECORDS FROM WHO
16
SPENT WHAT WHERE.
THE S.B.A. STILL HAS A LARGE
17
CHUNK.
18
BUT THE PEOPLE WHO TOOK
MR. MOSSER:
19
THE BATTERIES OUT OF THE CARS AND SENT THEM OVER
20
THERE ARE THE ONES THEY'RE GOING TO GO LOOKING
21
FOR.
22
MR. ROGERS:
WE HAVE AVOIDED THAT FOR
23
OBVIOUS REASONS.
24
MS. BROWN:
BUT THERE WAS SEVERAL
25
COMPANIES THAT WERE BACKING THIS.
HANWELL REPORTING SERVICE
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95
1
MR. ROGERS:
ULTIMATELY WE WILL SPEND
2
THE MONEY TO TAKE ACTION SHOULD WE NOT BE ABLE TO
3
GET SOMEBODY ELSE TO DO IT.
WE',RE NOT GOING TO
4
ARGUE IN COURT FOREVER.
WE'RE GOING TO GO AHEAD
5
AND START THE WORK.
WE CAN ALWAYS GO BACK AND
6
PURSUE RECOVERY OF THE MONEY.
IN ALL CASES WHERE
7
WE SPENT MONEY A SIGNIFICANT REVIEW OF THE RECORD
8
IS MADE TO DETERMINE WHETHER OR NOT THERE IS
9
ANYONE TO GO BACK AND PURSUE FOR THOSE COSTS.
10
MS. BROWN:
I NOTICE THEY SAY YOU
11
CAN'T GET BLOOD OUT OF A TURNIP.
I'M ONE WHO
12
THINKS THOSE PEOPLE OUGHT TO , BE MADE TO PAY FOR
13
THIS.
14
MR. ROGERS:
WE'LL HAVE TO FOLLOW THE
15
LEGAL PROCEDURES AND WHERE WE CAN GO AFTER THEM
16
WE'LL GO.
17
MR. FOGLE:
I'VE GOT A FEW QUESTIONS.
18
JOHN VOGLE.
MY FIRST QUESTION IS WHO IS THE
19
DEED, HOLDS THE DEED TO THAT PROPERTY AT THIS
20
TIME?
WHO IS THE RESPONSIBLE PARTY?
21
MR. ROGERS:
WELL, THERE'S A LOT OF
22
,PRP'S BUT WHO HOLDS THE DEED, WE'VE GOT AN
23
ATTORNEY WORKING ON THAT NOW.
24
MR. FOGLE:
THE QUESTION THAT I HAVE
25
IS IF THAT PERSON WHETHER IT BE A BANK OR AN
HANWELL REPORTING SERVICE
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96
1
INDIVIDUAL OR WHATEVER, HAVE THEY BEEN ASKED TO'
2
ATTEND THESE MEETINGS AND WHY DIDN'T THEY AT~END
3
THEM?
4
MS. JONES:
I DON'T THINK WE CAN FORCE
5
PEOPLE -- PLEASE CORRECT ME IF I'M WRONG -- TO
6
ATTEND.
7
MR. FOGLE:
I DON'T THINK FORCING --
8
MS. JONES:
YOU'RE TALKING ABOUT THE
9
NEGOTIATIONS?
10
MR. ROGERS:
THE QUESTION IS WHETHER
11
WE NOTICED ANYBODY WHO IS A PRP ABOUT THE
12
MEETING.
13
MS. JONES:
YES, WE DID.
WE DID SEND
14
THEM THE PROPOSED PLAN OF ACTION.
15
MR. FOGLE:
AND THEY NEGLECTED OR
16
DECLINED TO ATTEND AS FAR AS I KNOW.
NOBODY IN
17
HERE IS GOING TO LAY CLAIM TO THAT.
18
MS. PEURIFOY:
WE CAN'T SAY THAT WE
19
ACTUALLY NOTICED WHO OWNS THE PROPERTY RIGHT NOW.
20
WE DID HAVE A LIST OF POTENTIALLY RESPONSIBLE
21
PARTIES.
22
MR. FOGLE:
WELL, I'M NOT CONCERNED
23
WITH THEM.
I THINK YOU ALREADY KNOW WHO THEY
24
ARE.
I THINK THE PEOPLE -- IF IT WAS FINANCED
25
THROUGH THE BANK AND IT WAS, DECLARED IN A
HANWELL REPORTING SERVICE
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97
1
BANKRUPTCY IT'S GONE INTO RECEIVERSHIP.
WHAT I
2
WANT TO KNOW IS WHO AFTER THIS IS OVER WITH IS
3
GOING TO HOLD THE DEED TO THAT PROPERTY.
4
MS. JONES:
IN OTHER WORDS YOU WANT TO
5
KNOW IF IT IS A BANK WHICH BANK IS HOLDING IT?
6
MS. BROWN:
THAT'S RIGHT.
7
MR. FOGLE:
AND THE REPLY TO -- WHAT I
8
WOULD LIKE TO KNOW IS WHY AREN'T THEY
9
REPRESENTED?
IF I COULD HAVE A NAME I WOULD CALL
10
THEM AND ASK THEM.
YOU KNOW?
I THINK THAT THEY
11
OWE AN OBLIGATION TO THIS COMMUNITY TO GET
12
INVOLVED IN THIS PROGRAM.
THAT IT HAS BEEN
13
TOTALLY CARRIED BY A FEW P~OPLE IN THIS
14
COMMUNITY.
AND FINALLY ARRIVED AT THIS POINT
15
WHERE THEY ARE.
THE OTHER QUESTION IS UP TO THIS
16
POINT FROM HERE ON IF YOU SPEND THE MAXIMUM
17
AMOUNT YOU'RE GOING TO SPEND $900,000.
HOW MUCH
18
HAVE YOU SPENT UP TO THIS POINT?
AND MY QUESTION
19
TO THE STATE REPRESENTATIVES OVER THERE IS HOW
20
MUCH HAVE YOU SPENT UP TO THIS POINT?
ARE WE AT
21
A PLACE OF TWO MILLION, THREE MILLION, FOUR
22
MILLION DOLLARS ON 1.5 ACRES?
23
AS FAR AS THE RIfFS AND
MS. JONES:
24
BASED ON THE DATA -- AND THIS IS JUST AN ESTIMATE
25
BECAUSE EVEN NOW WE ARE INCURRING COSTS BUT I
HANWELL REPORTING SERVICE
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1
THINK IT WAS APPROXIMATELY $524,000.
THAT
2
CONSISTS OF ALL THE INVESTIGATION THAT WAS DONE
3
PRIOR TO EVEN GETTING SITE RANKED ON THE NATIONAL
4
PRIORITY LIST.
ACTUALLY THERE WERE TWO. 'THEY
5
WENT BACK AND REVISED IT.
SO APPROXIMATELY
6
THAT'S THE COST.
7
MR. ROGERS:
A DECENT CHUNK OF THAT
8
WAS SPENT JUST TO GET IT ON THE NPI.
9
MS. JONES:
RIGHT.
JUST TO RANK IT.
10
MR. ROGERS:
I FORGET THE COST OF THE
11
STUDY BUT THE RELATIVE COSTS OF THE STUDY WERE
12
TRIED TO BE KEPT TO A MINIMUM.
13
MS. BROWN:
HE'S NOT TALKING ABOUT THE
14
COST OF THE STUDY.
HE'S TALKING ABOUT THE CLEAN
15
UP.
16
MR. FOGLE:
WELL, I'M TALKING ABOUT
17
THE TOTAL.
JUST LEAVING IT THERE YOU ARE RIGHT
18
NOW CLOSE TO 1.5 MILLION DOLLARS.
I'M T,ALKING
19
ABOUT JUST THE FEDERAL SUPERFUND SITE WHAT THE
20
FEDERAL GOVERNMENT HAS TIED UP IN IT.
WORST CASE
21
IT WOULD BE 1.5 MILLION DOLLARS, THEREABOUTS GIVE
22
OR TAKE A COUPLE HUNDRED THOUSAND.
WE CAN TALK
23
ABOUT THAT.
I WOULD LIKE TO KNOW IF ANYONE FROM
24
THE STATE HAS AN IDEA -- THEY REMOVED SOIL.
THEY
25
DID TESTING.
THEY SPENT TIME.
WOULD YOUR
HANWELL REPORTING SERVICE
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99
1
ESTIMATE BE THAT YOU SPENT ANOTHER $500,000 AT
2
THAT SITE?
3
MR. STEWART:
WE WERE JUST DISCUSSING
4
WHETHER IT WAS THE STATE WHO SPEND THE MONEY OR
5
WHETHER THE STATE OVERSAW THE COMPANY ACTUALLY DO
6
SOME OF THE EXCAVATION.
THE ONES OF US HERE
7
TONIGHT AREN'T SURE.
I CAN TELL YOU FOR SURE IT
8
WOULD HAVE BEEN MUCH LESS THAN $500,000.
9
MR. ROGERS:
THAT CLEAN UP WAS DONE IN
10
THE MID '80S.
CHEAP TIMES.
11
MR. STEWART:
I WOULD SAY PROBABLY
12
LESS THAN $500,000.
13
MR. FOGLE:
I THINK THAT EVERYBODY
14
SHOULD TAKE A LESSON FROM THIS.
WHEN THEY SEE
15
SOMETHING LIKE THIS GOING ON AND THEY'VE GOT A
16
QUESTION YOU KNOW WE NEED TO GET INVOLVED WITH
17
THESE STATE FOLKS AND FEDERAL FOLKS.
YOU KNOW
18
SOMEWHERE IN HERE I WOULD BE CONVINCED THAT TWO
19
MILLION DOLLARS HAS BEEN SPENT ON 1.5 ACRES.
I
20
HAVE 1.5 ACRES I'LL LET YOU HOLD FOR TWO MILLION
21
DOLLARS TONIGHT.
22
MS. BROWN:
THE PEOPLE THAT OWNED IT
23
DOWN THERE HAD A MILLION DOLLAR INSURANCE POLICY
24
ON THE PROPERTY FOR SUCH --
25
MR. ROGERS:
UNFORTUNATELY FROM WHEN
HANWELL REPORTING SERVICE
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1
WE FIRST STARTED WORKING ON THE SITE UNTIL NOW
2
THE COST OF CLEANING UP THE SITE IS MUCH MORE
3
I WOULD GUESS THE STATE CLEAN UP
SIGNIFICANT.
4
WOULD HAVE BEEN $50, 100,000.
NOW, IT'S HARD TO
5
SAY.
ONE OF THE THINGS ON THE DISPOSAL LIST MY
6
GUESS FROM HAVING CLEANED UP SITES OVER THE YEARS
7
THAT SOIL WOULDN'T BE CONSIDERED HAZARDOUS WASTE
8
BECAUSE OF THE LEACHABILITY TEST AND THEREFORE IT
9
WILL GO TO AN INDUSTRIAL GRADE LANDFILL.
IT
10
WON'T GO TO A MUNICIPAL" LANDFILL I DON'T BELIEVE.
11
BUT THERE ARE SOME INDUSTRIAL LANDFILLS THAT ARE
12
AROUND AND MORE SECURE AND APPROPRIATE FOR THAT
13
KIND OF MATERIAL AT A MUCH SIGNIFICANTLY REDUCED
14
COST.
15
WHAT DO YOU HAVE TO DO --
MR. GRANT:
16
I CAN'T HEAR BACK HERE.
THE REPORTER:
17
HIS QUESTIONS WAS WHAT DO
MR. ROGERS:
18
YOU HAVE TO DO TO DECONTAMINATE THE SOIL THAT HAS
19
LEAD IN IT.
THERE'S REALLY SOME REAL
20
SOPHISTICATED TECHNOLOGIES THAT ARE INVOLVED THAT
21
AREN'T APPROVED TO WORK IN THE FIELD YET WHERE
22
YOU ACTUALLY WASH THE EXCAVATION AND THEN DISPOSE
23
OF IT.
WE DON'T REALLY USE A LOT OF THAT YET.
24
SO WHAT YOU WANT TO SEE HAPPEN IS THE SOIL IS
25
SHIPPED TO A DISPOSAL FACILITY AND IF IT DOES
HANWELL REPORTING SERVICE
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. 22
101
1
EXCEED THE CHARACTERISTIC LEACHABILITY TEST THEN
2
IT MIGHT VERY WELL HAVE TO BE DEEMED HAZARDOUS.
I .
3
IT'S NOT GOING
IT DOESN'T MOVE IN WATER.
4
WE'VE DONE THAT WHERE IT'S APPROPRIATE
ANYWHERE.
5
AT SOME SUPERFUND SITES AND WE'VE ALSO TAKEN IT
6
OFF SITE.
YOU JUST TAKE IT OFF AND LANDFILL IT.
7
YOU MENTIONED INCINERATION.
INCINERATION DOESN'T
8
THEY JUST BLOW OUT THE STACK. SO
WORK ON METALS.
9
THAT WOULDN'T BE APPROPRIATE.
10
WHAT'S PROZZOLAN, HOW
MS. BROWN:
11
WOULD IT STABLIZE LEAD?
12
MS. JONES:
BASICALLY IT'S PRETTY MUCH
.13
THE SAME OR SAME TYPE OF TEXTURE AS CONCRETE.
14
IT'S NOT LITERALLY THE SAME AS THIS CONCRETE.
15
MS. BROWN:
BUT IT STABLIZES THE LEAD
16
SO IT WON'T FLOW?
17
MR. ROGERS:
IT MAKES IT SO IT'S NOT
18
SOLUABLE AND CAN'T LEACH.
19
MR. MOSSER:
I MOVE WE ADJOURN.
20
MR. STEWART:
A COUPLE PEOPLE
21
MENTIONED THINGS ABOUT PRIVATE WELLS.
ARE THERE
ANY PEOPLE HERE WHO ARE CURRENTLY DRINKING WELL
23
WATER? IF WE CAN HAVE YOUR NAMES AFTERWARDS,
24
ADDRESS AND PHONE NUMBER.
DHEC CAN COLLECT
25
SAMPLES FROM PRIVATE WELLS AND HAS THEM ANALYZED.
HANWELL REPORTING SERVICE
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102
1
MR. HICKS:
I APPRECIATE THAT.
2
BECAUSE I'D LIKE TO KNOW.
3
MR. MOSSER:
HOW ABOUT THE GENTLEMAN
4
HERE THAT'S CONCERNED ABOUT HIS CHILDREN AND THE
5
LEAD CONTENT AND WANTING THEM RETESTED.
A SIMPLE
6
PHYSICIAN CAN DO THAT WITH A BLOOD TEST.
7
I'M ELIZABETH HOLLIS~
MS. HOLLIS:
8
AND DHEC DID SEND A NURSE OUT TO COLLECT THE
9
BLOOD SPECIMENS OF THE CHILD IN THE COMMUNITY AT
10
THAT TIME.
I THINK IT WOULD BE A GOOD IDEA AS A
11
FOLLOW-UP SUMMARY IF THIS IS GOING TO BE RESOLVED
12
IN ANY WAY TO FOLLOW-UP ON THOSE CHILDREN OR
13
PROBABLY I'M SURE NOW ADULTS WHO HAD THESE LEVELS
14
DRAWN.
15
MS. BROWN:
DHEC DOES HAVE THAT RECORD
16
AT THE DHEC OFFICE.
17
MR. ROGERS:
THAT'S AN APPROPRIATE
18
FUNCTION OF DHEC.
WE DON'T LIKE TO SPEAK FOR
19
THEM.
THERE'S SOME THINGS WE CAN PURSUE AND TALK
20
ABOUT TO THAT END.
OBVIOUSLY THE EXPOSURE OF
21
BURNING BATTERIES AND DOING OTHER THINGS WAS
22
OCCURRING THEN AT ITS MAXIMUM EXTENT AND IF THEY
23
DID BLOOD WORK THEN YOU SHOULD HAVE SEEN SOME
24
ACCUMULATION THEN.
25
MS. BROWN:
BUT EVEN THEN IT WOULD NOT.
HANWELL REPORTING SERVICE
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103
1
SHOW UP AS MUCH AS LATER.
2
MR. HAYES:
THAT'S NOT TRUE.
IT'S
3
REVERSIBLE.
4
MR. ROGERS:
IT'S GOING TO SHOW UP
5
PRETTY QUICKLY IF YOU'RE BREATHING IT.
6
MS. BROWN:
IT WOULD SHOW UP
7
IMMEDIATELY?
8
MR. ROGERS:
YES.
9
MR. HAYES:
HERE'S WHAT WE'RE LOOKING
10
AT.
CHILDREN NEAR THE SITE MIGHT HAVE BEEN
11
TESTED THEN.
AND WHATEVER THEIR BLOOD LEVELS
12
WERE IF THEY DON'T LIVE NEAR THE SITE NOW THEN
13
OBVIOUSLY THEIR EXPOSURE HAS CEASED IF THEY'RE
14
GROWN UP.
15
MS. BROWN:
WELL, THEY STILL DO.
16
MR. HAYES:
WELL, I'M NOT SAYING IT'S
17
A BAD IDEA TO MAYBE TEST THEM.
18
MS. BROWN:
THAT'S WHY I ASKED E.P.A.
19
IF THEY WOULD RETEST THOSE CHILDREN.
20
MR. HAYES:
BUT IF THE EXPOSURE IS NOT
21
CONTINUING THEN THEIR BLOOD LEVELS WOULD HAVE
22
DROPPED.
23
MS. BROWN: IT STILL WOULDN'T HURT
E.P.A. TO TEST THOSE CHILDREN.
MR. ROGERS: THAT'S SOMETHING WE CAN
24
25
HANWELL REPORTING SERVICE
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104
1
LOOK INTO.
THERE ARE SOME OTHER AVENUES TO
. 2
PURSUE" THAT.
IF YOU CAN IF
ANY OTHER QUESTIONS?
3
YOU THINK OF ANYTHING ELSE YOU CAN STILL USE I
4
GUESS THE BACK OF THE FACT SHEET AND SEND IN ANY
5
ADDITIONAL QUESTIONS OR CONCERNS TO US.
6
MS. PEURIFOY:
CALL US AT THE 800
7
NUMBER IF YOU HAVE ANY QUESTIONS.
DECEMBER 22ND
8
IS THE END OF THE COMMENT PERIOD.
9
MR. ROGERS:
WE DON'T BRING ALL THE
10
DETA~LED TECHNICAL DOCUMENTS TO THESE MEETINGS
11
BECAUSE IT WOULD BE TOO LONG BUT THEY ARE
12
AVAILABLE IN THE REPOSITORY AND CYNTHIA CAN TELL
13
YOU WHERE THAT IS.
14
MS.. PEURIFOY:
THANK YOU ALL FOR
15
COMING.
THANK YOU.
16
17
(THEREUPON, AT 9:20 P.M.
18
THE TAKING OF THE FOREGOING
19
HEARING WAS CONCLUDED)
20
21
" 22
23
24
25
HANWELL REPORTING SERVICE
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105
1
CERTIFICATE OF REPORTER
2
3
STATE OF SOUTH CAROLINA
4
COUNTY OF LEXINGTON
5
6
I, SHEILA STAGGS, CERTIFIED 'COURT REPORTER
7
(GA) AND NOTARY PUBLIC IN AND FOR THE STATE OF SOUTH
8
CAROLINA AT LARGE, DO HEREBY CERTIFY THAT I WAS
9
AUTHORIZED TO REPORT THE E.P.A. HEARING
10
AT THE TIME AND PLACE HEREINABOVE SET FORTH; THAT
11
THE WITNESSES WERE FIRST DULY SWORN BY ME TO TELL THE
12
WHOLE TRUTH; AND THAT THE FOREGOING PAGES NUMBERED
13
3 THROUGH 104 INCLUSIVE, CONSTITUTE A TRUE AND
14
CORRECT TRANSCRIPTION OF MY STENOGRAPHIC REPORT OF
15
THE TESTIMONY OF SAID WITNESS.
16
I FURTHER CERTIFY THAT I AM NEITHER
17
ATTORNEY NOR COUNSEL FOR, NOR RELATED TO OR
18
EMPLOYED BY ANY OF THE PARTIES CONNECTED TO THE
19
APPLICATION, NOR AM I FINANCIALLY INTERESTED IN
20
THE APPLICATION.
21
WITNESS MY HAND AT COLUMBIA, SOUTH
22
CAROLINA, THIS 21ST
DAY OF(DECEMBER-~994.
/ / .' /' i'-
I 1 / )i;:'
I '\ I..> ~ i " " . :. /' ,-
,-.1.--1/1 1..( '/' \ . {i.. r .:
-'''X______K --....,.,.----------
~~ . .- (~
SHEILA STAGGS, CCR (GA)
23
24
25
OCTOBER 29, 2002.
MY COMMISSION EXPIRES:
HANWELL REPORTING SERVICE
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.-
,
APPEND:IX B
STATE OF SOUTH CAROL:INA CONCURRENCE LETTER
PALHETTO RECYCLmG SUPERFUND S:ITE
-------
DHEC
CClmnf..'Q *. DoUglas £ 8ryant
~ of HeaIIII and E/WitOftIMIIIaI Control
2600 Bull Street. Columbia. SC 29201
8II8rd: Richard E. JabbOllr,oDS. Q\airrNJn
Rabert J. Stripling. Jr. Vice CNinnan
s.ndra ,J. Molander. SecI'8lBrf
JOlIn H. BurriSs
Willilun M. Hun. Jr - MO
Roger leBIca, Jr.
Burnet R Mayllenk. In
PromotirTg HNII/t. P,otKt1t1f1 the Environment
March 28, 1995
John H. Hankinson, Jr.
Reqional Administrator
U.s. EPA, Region IV
345 courtland street
Atlanta, GA 30365
RE:
Record of Decision
Palmetto Recycling NPL site
Richland County'
Dear Mr. Hankinson:
I .
The Department has reviewed the revised Record of Decision (ROD)
dated March 21, 1995 for the Palmetto Recyclinq site and concurs
wi~ the ROD. In concurring with this ROD, the South carolina
Department of Health and Environmental Control (SCDBEC) does not
waive any right or authority it may have under Federal or state
law. SCDHEC reserves any riqht and authority it may have to require
corrective action in accordance with the South Carolina Hazardous
Waste Manaqement Act and t.he Sout.h Carolina Pollution Control Act.
These riqhts include, but are not limited to, the riqht to ensure
that all necessary permits are obtained, all clean-up qoals and
criteria are met, and to take a separate action in the event clean-
up qoals and criteria are not met. Nothinq in the concurrence shall
preclude SCDHEC from exercising any admini:;Jtrative, leqal 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) SCDBEC receives additional
information not previously available concerning the premises upon
which SCDHEC relied in concurrinC) with the selected remedial
alternative; and (2) the implementation of the remedial alternative
selected' in the ROD is no lonqer protect.ive of public health and
the environment.
The State concurs with the selected surface sail source control
alternative of excavation of contaminated surface soi1 that exceeds.
the remediation level for lead, with verification sampling. The
. soil will be Toxicit.y Characteristic Leaching Procedure (TCLP)
tested. If the soil exceeds the Land Disposal Restriction (LDR) of
5 ppm. for lead, then the soil will be transported to a RCRA
Subtitle CF~cility where it will be pretreated in order to comply
o rp~~
-------
~--- - --~----
Mr. John H. Hankinson, Jr.
Palmetto Recycling NPL site
March 28, 1995
paqe 2
with the LORs. If the soil does not exceed the 5 ppm LOR, then the
soil will be transported to a Subtitle D solid was~e landfill and
disposed of direc~ly without pretreatment. The excavated area
shall be backfilled with clean soil, properly recompacted, and the
land reqraded to the natural slope. A vegetative .cover will be
established to minimize undue surface water runoff and minimize
erosion. Groundwater monitorinq will be conduc~ed on an annual
basis for at least five years to evaluate the site proqr~ss.
state concurrence on this remedial alternative is based on the
alternative meeting all applic::a1:»le clean-up criteria. . This
concurrence with the above selected remedy for the Palmetto,
Recyclinq NPL Site is contingent upon the state'sabeve mentioned
reservation of rights. .
Sincerely,
II;L-
44
R. Lewis Shaw, P.E.
Deputy commissioner
Environmental Quality Conuel
RLS I am.f
cc:
Hartsill Truesdale
Reith Lindler
Gary Stewart
Adrienne Felder
Lewis Bedenbauqh,
Central Midlands EQC
TOTAL P.03
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