EPA Superfund
Record of Decision:
PB98-964021
EPA 541-R98-086
November 1998
Shuron Inc. Site
Barnwell, SC
9/9/1998
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RECORD OF DECISION
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
SHURON SUPERFDND SITE
BARNWELL, BARNWELL 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
Shuron Superfund Site
Barnwell, Barnwell County, South Carolina
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Shuron Superfund Site (the Site), located in Barnwell,
Barnwell 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 e_t sea., and, to the extent practicable, the National Oil
and Hazardous Substances Pollution Contingency Plan (NCP),
40 C.F.R. Part 300 et sea. This record of decision is based on
the administrative record for this Site.
The State of South Carolina concurs with the selected remedy, but
does not concur with the remedial goal for lead, which is based
on an assumed future industrial land use.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
Site, if not addressed by implementing the response action
selected in this record of decision (ROD), may present an
imminent and substantial endangerment to public health, welfare,
or the environment.
DESCRIPTION OF THE SELECTED REMEDY
This remedial action addresses surface and subsurface soil,
sediment, and groundwater contamination.
The major components of the selected remedy for groundwater and
soil are:
The remedy for the soil includes:
Excavation of contaminated soils; including surface and
subsurface soils, and sediments, that exceed Remedial Goals,
excluding a limited area of sediments in the Eastern Wetlands
portion of the site (approximately 13 acres) . This will be
followed by wetlands restoration. The following will then apply:
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D All soils will be either aggressively treated using
solidification/stabilization (S/S) and aeration and
left on-site or disposed off-site at an appropriate
hazardous waste facility. This will be determined from
Treatability Studies.
D Based on the results of the Treatability Studies, the
following will apply:
D Soils which cannot be treated to below RCRA
hazardous levels will be disposed off-site.
D Soils which can be treated such that
contaminants do not leach above drinking water
standards will be either treated and placed on-
site under an engineered cap or disposed off-site
at an appropriate disposal facility.
D- Soils which leach above drinking water
standards, but below RCRA hazardous levels, will
be either treated and placed into an on-site
Subtitle D landfill or disposed off-site at an
appropriate disposal facility.
The remedy for the groundwater includes:
D Temporary groundwater extraction to accomplish
dewatering of soils during source removal, and for an
additional four to six months after excavation.
D Data collection/aquifer evaluation.
D Active Groundwater Treatment (Pump & Treat, Air-
sparging, Re-circulation wells or any combination of
the three) of remaining (after dewatering) contaminated
groundwater.
D If determined to be applicable, Monitored Natural
Attenuation may be applied to the appropriate portions
of the contaminated groundwater plume.
Additional work during the remedial design phase
D The collection of additional soil samples from around
the wastewater lagoons and solids ponds, and other
uplands areas; additional surface and subsurface .soils
and sediment/surface water samples from the southern
wetlands (and southeast corner), to further fill in
data gaps.
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D Annual sampling of nearby municipal well at drinking-
water quantitation limits sufficient to quantify one
(1) part per billion, until EPA designates otherwise.
D Collection of additional groundwater samples from
existing and new wells (especially in the Southern
Wetlands, including south and southeast of the Solids
Lagoons to the South Drainage Ditch) .to more fully
delineate the extent of contamination.
n Site monitoring on a quarterly basis, to include water
level measurements and analysis of groundwater for
parameters described in Section 9 of this ROD, from
existing and new wells until the evaluation period is •
complete. Quarterly analysis of groundwater shall
begin prior to any source removal, and continue until
the completion of the evaluation period.
D Appropriate laboratory and field pilot test
treatability studies for S/S, to determine the most
effective reagent mixture for preventing the leaching
of contaminants above drinking water standards, from
soil to groundwater and to treat the organics and
metals.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with /Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost effective. This remedy utilizes
permanent solutions to the maximum extent practicable and
satisfies the statutory preference for remedies that employ
treatment that reduces toxicity, mobility, or volume as a
principal element for this Site.
Since selection of this remedy will result in contaminated
groundwater remaining on-site above health-based levels until the
remedial action is complete, and because the remedy may allow
material which could leach contaminants above drinking water
standards (based on leaching tests) to be contained (after
treatment) in an on-site RCRA Subtitle D landfill, statutory five
(5) year reviews will be performed after commencement of the
remedial action to insure that the remedy continues to provide
adequate protection of human health and the environment.
Richard Green; Director Date
Waste Management Division
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TABLE OP CONTENTS
SECTION PAGE
1. 0 SITE LOCATION AND DESCRIPTION 1
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES 1
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION 3
4.0 SCOPE AND ROLE OF THIS ACTION WITHIN SITE STRATEGY 4
i
5 . 0 SUMMARY OF SITE CHARACTERISTICS 4
5.1 Meteorology 5
5.2 Geologic and Hydrogeologic Setting 5
5.2.1 Geology/Soils 5
5.2.2 Hydrogeology 6
5.3 Nature and Extent of Contamination 6
6 . 0 SUMMARY OF SITE RISKS 12
6. l Contaminants of Concern 12
6 .2 Exposure Assessment 13
6.3 Toxicity Assessment of Contaminants 13
6.4 Risk Characterization 14
6.5 Ecological Risk Assessment 16
6.6 Remediation Goals 16
7 . 0 DESCRIPTION OF REMEDIAL ALTERNATIVES 18
Alternatives for Remediation of Groundwater
7.1 No Action 27
7.2 Source Removal with Groundwater Extraction During
. Excavation Period 27
7.3 Source Removal with Temporary Groundwater Extraction
for Dewatering, Data Collection/Aquifer Evaluation,
Active Groundwater Treatment of remaining contaminated
groundwater, and if applicable, Monitored Natural
Attenuation 28
7.4 Groundwater Extraction and Treatment in Source
Area 28
7.5 Groundwater Extraction and Treatment Near Property
Boundary 29
Alternatives for Remediation of Soil
7.6 No Action 29
7.7 Limited Action 30
7.8 Excavation and On-Site Capping with No Bottom
Liner 30
7.9 Excavation and On-Site Capping with Bottom
Liner for All Contaminated Soils 31
7.10 Excavation and On-Site Capping with Bottom
Liner for RCRA Non-Hazardous Soil and Off-Site
Disposal of RCRA Hazardous Soil 31
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7.11 Stabilization/Solidification 32
7.12 In Situ Treatment Followed by A) Containment;
or B) Stabilization/Solidification 33
7.13 Low Temperature Thermal Desorption Followed by
A) Containment or B) Stabilization/Solidification ..34
7.14 Excavation and Off-Site Disposal 34
8 .0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 35
8.1 Soil Remediation Alternatives 36
8.1.1 Threshold Criteria 36
8.1.2 Primary Balancing Criteria 37
8.1.3 Modifying Criteria 39
8.2 Groundwater Remediation Alternatives 39
8.2.1 Threshold Criteria 39
8.2.2 Primary Balancing Criteria 40
8.2.3 Modifying Criteria 41
9 . 0 THE SELECTED REMEDY 41
9 .1 Soil Remediation 42
9.1.1 Description .43
9.1.2 Applicable or Relevant and Appropriate
Requirements (ARARs) 46
9.1.3 Performance Standards 48
9.1.4 Monitoring 49
9.2 Groundwater Remediation 49
9.2.1 Description 50
9.2.2 Applicable or Relevant and Appropriate
Requirements (ARARs) 53
9.2.3 Performance Standards 54
9.2.4 Monitoring 54
9 .3 Documentation of Changes 56
10 . 0 STATUTORY DETERMINATIONS 56
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LIST OP APPENDICES ii
APPENDICES
APPENDIX A - RESPONSIVENESS SUMMARY
APPENDIX B - STATE LETTER OF CONCURRENCE
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LIST OP FIGURES
ill
FIGURE
1
2
PAGE
Site Location Map 2
Distribution of Selected Contaminants in Shallow
Groundwater 21
Areal Limits of Soil Potentially Requiring A
Response Action 22
LIST OP TABLES
Summary of RI Results By Media 7
Remedial Goals (RGs) 19,58
Groundwater Alternatives 23
Soil Alternatives " 24
TABLE
1
2
3
4
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DECISION SUMMARY
SHURON SUPERFUND SITE
BARNWELL, BARNWELL COUNTY, SOUTH CAROLINA
1.0 SITE LOCATION AND DESCRIPTION
The Shuron Site is located at 100 Clinton Street in Barnwell,
Barnwell County, South Carolina. Figure 1 presents a site
location map. Throughout this document, the entire 85-acre parcel'
will be referred to as "the Site." One main building (about
185,000 square feet) is located on an approximate 34-acre parcel
of land surrounded by a fence. Approximately one third of the
34-acre facility is paved or occupied by the main plant building.
The remainder of the property consists of approximately 51 acres
and is predominantly wetlands. The fence was partially extended
to enclose a portion of the 51 acres in 1996. A removal action
inside the building was completed by US EPA Region 4 Emergency
Response and Removal Branch in 1994, in which drums of hazardous
material left inside the building were removed.
The Shuron Site is bounded by residential properties immediately
northwest and north-northeast, wetlands and Turkey Creek to the
east, wetlands and a railroad right-of-way to the south, and
Clinton Street to the west. The nearest known water supply well
is the continuously-operating City of Barnwell Well No. 10,
located on the west side of Clinton Street approximately 375 feet
west of the southwest corner of the Shuron plant building. The
first screened interval is 180 feet below land surface.
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
The former Shuron Site was constructed and placed into operation
in 1958 as Shuron Continental Optical Company, a former division
of Textron Inc. The facility manufactured single and
multi-vision ocular lenses until 1991 (though the company was
sold by Textron in 1985). The manufacturing process involved
grinding and shaping of lenses using such material as aluminum
oxide and garnet, followed by polishing, with oxides containing
materials such as iron, cerium, and zirconium. Wastewater from
the process was discharged to a series of four Wastewater
Settling Lagoons immediately east of the building, the sediment
from which was periodically transferred to two Solids Ponds
located immediately south of the four Wastewater Settling
Lagoons. Facility operations produced about 270,000 gallons per
day (gpd) of wastewater containing the fine-grained grinding and
polishing compounds, which contained lead, solvents, and waste
oils. It is believed that a solvent (tetrachloroethene) was used
to clean the lenses after the grinding and polishing process.
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SOURCE: USCS 7-1/2 Minute Series Mops:
Barnwell. SC & Snelling. SC
Topographic Quadrangles
FIGURE 1
Site Location
Shuron Site, Bamwell, South Carolina
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There were several environmental investigations conducted at the
facility during the period from 1982 to 1993. Groundwater
sampling and analysis conducted by Westinghouse Environmental
Services, Inc. (WESI) for Shuron, Inc. in 1987 revealed the
presence of several metals and volatile organic compounds (VOC)
at concentrations exceeding maximum contaminant levels (MCL) in
monitoring wells near the Wastewater Settling Lagoons. Further
investigation by WESI, including a 1990 groundwater quality
assessment indicated the presence of elevated VOC and metals
concentrations in groundwater near the Solids Lagoons.
A Site Screening Investigation by the South Carolina Department
of Health and Environmental Control (SCDHEC) showed VOC and
metals in excess of MCL in one groundwater monitoring well
downgradient of the Solids Lagoons. In March 1994, the EPA
detected elevated metals, VOC, and semivolatile organic compound
(SVOC) concentrations in surface soil and sediment samples from
the site.
EPA ranked the Site and included it on the National Priorities
List Proposed Update in the Federal Register, Rule No. 20,
Vol.61, No. 117, on June 14, 1996. The Site was added to the
National Priorities List in the Federal Register, Rule No. 17,
Vol. 61, No. 247 on December 23 , 1996.
In November 1994, EPA and Textron signed an Administrative Order
on Consent, Docket No. 95-5-C, for a Removal Action and Remedial
Investigation (RI) and Feasibility Study (FS) at the Shuron Site.
3.0 HIGHLIGHTS OP COMMUNITY PARTICIPATION
An information repository for the Site, which includes the
Administrative Record (AR) , was established in February 1995 at
the Barnwell County Library, located at 2001 Haygood Avenue,
Barnwell, South Carolina, 29812. The AR is also available to the
public at US EPA Region IV Library, 61 Forsyth Street, Atlanta,
Georgia, 30303. A mailing list was established for the Site, and
a fact sheet was mailed in February 1995. The fact sheet
outlined the following: the objectives of the RI, a summary of
the Site history, the various opportunities for public
involvement (including Technical Assistance Grants), and the
location of the information repository. EPA also conducted
community interviews in March 1995 to inform the nearby residents
of future activities at the site and to determine their concerns.
Prior to issuance of the Proposed plan, EPA met with local
officials in April and May 1997, to inform them of the results of
the sampling activities and to discuss various options EPA was
evaluating to address the Site contamination and to solicit their
input. EPA also conducted an availability session in Barnwell on
November 20, 1997, to answer questions from the public concerning
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the site. After the availability session, EPA then issued the
proposed plan in November 1997, which outlined EPA's preferred
alternative. A public comment period for the proposed plan was
held from December 5, 1997, to January 5, 1998. EPA held two
public meetings on December 9, 1997 and January 22, 1998, where
EPA representatives answered questions regarding the Site and the
remedial alternatives under consideration, which were outlined in
the proposed plan. EPA received a request for an extension to
the public comment period, and extended the comment period
through February 4, 1998. EPA received oral comments during the
two public meetings, and one set of written comments during the
sixty (60) day public comment period. Responses to the comments
received by EPA are included in the Responsiveness Summary
(Appendix A).
This ROD presents EPA's selected remedial action for the Site,
chosen in accordance with CERCLA, as amended by SARA, and to the
extent practicable, the NCP. The remedial action selection for
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 alternatives selected in this ROD is
to reduce potential future risks at this Site from exposure to
contaminated surface and subsurface soil, sediment, and
groundwater. There is no unacceptable current human health risk
present at the Site. However, there is a current ecological
risk. The groundwater component of the remedial action is
expected to eliminate the potential future risk to an on-site
industrial worker, who represent persons who could potentially
use contaminated groundwater for a potable water supply. The
soil remedial action is expected to eliminated the potential
risks to future workers and ecological receptors from direct
exposure, as well as to prevent further leaching of contaminants
to groundwater. This is the only ROD contemplated for this Site.
The RI investigated the nature and extent of contamination on and
near the Site, and defined the potential risks to human health
and the environment posed by the Site. A supporting RI objective
was to characterize the Site-specific geology and hydrogeology.
A total of approximately 104 surface soil samples (some of which
are referred to as hydric soils) were collected and analyzed for
various contaminants. Six of these samples were collected from
background locations. Another 52 samples were analyzed for lead
only. Twenty-six additional samples were analyzed for lead,
chromium, and nickel, and another 16 samples were analyzed for
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arsenic, copper, lead, silver, and zinc. Ten samples were
analyzed for the eight RCRA metals (arsenic, barium, cadmium,
chromium, lead, mercury, selenium, and silver). Seven of these
samples were collected from background locations. A total of 103
subsurface soil samples were collected and analyzed for various
parameters.
Groundwater samples from twenty-five wells were collected and
analyzed for different compounds. Twenty-seven sediment samples
were collected from 25 locations and analyzed for various
contaminants. Surface water samples were collected from 34
locations and analyzed. The final Remedial Investigation (RI)
Report was completed in January 1997, and the Final Feasibility
Study (FS) Report was completed in April 1997.
5.1 Meteorology
The climate in the vicinity of Barnwell, South Carolina, is
temperate. Typical summer weather in the Barnwell area is warm
and humid. Daily high temperatures average from the upper 80s to
the low 90s (degrees F) , with nighttime lows in the upper 60s to
lower 70s. Summer has the most rainfall, with greater than one-
third of the total annual rainfall occurring during this period.
The rain generally occurs as afternoon showers or thunderstorms
except in the case of heavy rainfall associated with tropical
storms or hurricanes. Rainfall is generally lowest during the
fall months. The winter months, December through February, are
relatively mild with periods of rain. Average high temperatures
for the three-month period range from the mid 50s to upper 60s
with average low temperatures ranging from the low 30s to the mid
40s. Winter rainfall is generally light.
5.2 Geologic and Hydrogeologic Setting
5.2.1 Geology/Soils
The Shuron Site is located in the Atlantic Coastal Plain
Physiographic Province. The uppermost geologic units consist of
interbedded clayey to silty sand, sand, and silty fill material.
Groundwater in the uppermost unit is encountered at land surface
(wetlands) to approximately 3 feet below land surface (uplands) .
At approximately 20 to 30 feet bis, geologic units are
encountered which consists of a well sorted, clean to slightly
clayey or silty, sand. At about 65 feet bis, a coarsening
downward sequence of stiff clay, silty clay, and silt is
encountered.
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5.2.2 Hydrocreology
Regional groundwater flow in the coastal plain is controlled
primarily by the gentle seaward dip of the sediments and by the
location of principal recharge areas. Groundwater flow in the
upper most units is primarily toward the nearest surface water
drainage, which is the wetlands to the east and south of the
facility). Major marine transgressions and regressions in the
geologic past have created a series of relatively coarse-grained
units overlying and/or underlying relatively fine-grained units.
It is this sequence of deposition, coupled with large-scale
structural features, which produced the major aquifers and
confining units throughout the coastal plain. On a smaller
scale, water-bearing units and water-retarding units exist within
each aquifer system. In Barnwell County, the aquifer systems, in
order of increasing depth below the surface, include the
surficial aquifer, the upper and lower Floridan aquifer, the
Black Mingo aquifer, and the Cretaceous aquifers.
5.3 Nature and Extent of Contamination
More detailed information can be found in the RI and FS reports,
and in the Baseline Risk Assessment. The information below is
summarized in Table 1. Contamination at the Site can be
summarized as follows:
Groundwater Contamination.
The highest volatile organic compound (VOC) concentrations were
detected in the shallow groundwater (maximum concentrations are
given in parentheses) : vinyl chloride (3700J /zg/L) , 1,2-
dichloroethene, total (47,000 /zg/L), 1,2-dichloroethane (2,600
/zg/L), trichloroethene (61,000 /zg/L), tetrachloroethene (52,000
/zg/L), toluene (2.400J /zg/L), ethylbenzene (20,000 /zg/L) , and
xylenes (total) (93,000 /zg/L) . (The "J" qualifier indicates that
the number given is an estimate rather than a precise quantity.)
The maximum detected semivolatile organic compound (SVOC)
concentrations were bis (2-ethylhexyl)phthalate at 310 /zg/L in the
shallow groundwater and 610 /zg/L in the intermediate-depth
groundwater. Lead (Pb) was detected at a maximum concentration
of 124 /zg/L. Contaminant concentrations for all of the
contaminants listed violate the Maximum Contaminant Levels
(MCLs), or the EPA Action Level in the case of lead, which are
often referred to as "drinking water standards." Therefore,
Remedial Goals (RGs) for these contaminants were developed.
Surface Soil Contamination.
Six VOCs were detected in surface soils (which includes wetlands
sediments/hydric soils): 1,2-dichloroethene, total (estimated
(J) at 7.9J mg/kg), trichloroethene (0.85 mg/kg),
tetrachloroethene (4.2 mg/kg), toluene (0.18J mg/kg),
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TABLE 1
SUMMARY OF RI RESULTS BY MEDIA
SUMMARY OF GROUNDWATER RESULTS
CONTAMINANT
Vinyl chloride
1 ,2-d ichloroethene
1 ,2-dichloroethane
Trichloroethene
Tetrachloroethene
Toluene
Ethylbenzene
Xylenes (total)
Bis(2-ethylhexyl)phthalate
Lead
MAXIMUM
CONCENTRATIONS (ug/L)
3700J
47,000
2,600
61,000
52,000
2,400
20,000
93,000
610
124
MCL/ACTION LEVEL
2.0
5.0
70
5.0
5.0
1000
700
10,000
6.0
15
SUMMARY OF SURFACE SOIL RESULTS
CONTAMINANTS
1 ,2-d ichloroethene
Trichloroethene
Tetrachloroethene
Toluene
Ethylbenzene
Xylenes (total)
Bis(2-ethylhexyl)phthalate
Lead
Arsenic
Copper
Zinc
MAXIMUM CONCENTRATIONS (mg/lcg)
7.9J
0.8S
4.2
0.18J
0.038J
0.38J
230
14,600
136
741
5,170
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TABLE 1 (con't)
SUMMARY OF RI RESULTS BY MEDIA
SUMMARY OF SUBSURFACE SOIL RESULTS
CONTAMINANTS
Vinyl chloride
1 ,2-dichloroethene
Trichloroethene
Tetrachloroethene
Toluene
Ethylbenzene
Xylenes (total)
Bis(2-ethylhexyl)phthalate
Lead
Arsenic
Copper
Zinc
MAXIMUM CONCENTRATION
(mg/kg)
9.1
460
1,100
2,SOOJ
60
1,400
3,700
110
17,400
117
400
7,910
MAXIMUM DEPTH (ft)
(though contamination may be
deeper if deepest sample to
date still had contamination)
2
7.S
S
7
5
10
14
10
14
14
7.5
14
8
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TABLE 1 (con't)
SUMMARY OF RI RESULTS BY MEDIA
SUMMARY OF SEDIMENT (Ditch/ creek/ wetlands) RESULTS
CONTAMINANT
Vinyl chloride
1 ,2-dichloroethene
Toluene
Ethylbenzene
Xylenes (total)
Bis(2-ethylhexyl)phthalate
Lead
Arsenic
Copper
Zinc
MAXIMUM CONCENTRATIONS (mg/kg)
0.2
0.41
2J
16
68
11
7,470
S7.3
341J
2,080
SUMMARY QF SURFACE WATER RESULTS
CONTAMINANT
Vinyl chloride
1 ,2-dichloroethene
Trichloroethene
Tetrachloroethene
Toluene
Ethylbenzene
Xylenes (total)
Bis(2-ethylhexyl)phthalate
Lead
Arsenic
Copper
Zinc
MAXIMUM CONCENTRATIONS (ug/L)
(either lagoon (L) or wetlands (W))
52 (L)
1,400(W)
10J (L)
1SJ(L)
51 (W)
17J (L)
360 (L)
9SJ(W)
343 (W)
5.6 (L)
116(W)
1.770J (L)
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ethylbenzene (0.038J mg/kg), and xylenes, total (0.38J mg/kg).
Vinyl chloride and 1,2-dichloroethane were not detected in
surface soils. The maximum detected SVOC concentration in
surface soils was bis(2-ethylhexyl)phthalate at 230 mg/kg. The
maximum detected concentrations in surface/hydric soils are:
lead (14,600 mg/kg), arsenic (136 mg/kg), copper (741 mg/kg), and
zinc (5,170 mg/kg). Other contaminants were also detected.
Because of direct contact exposure to humans or the ecological
system, or because of the potential of the contaminants to leach
to groundwater, RGs were derived for these contaminants.
Subsurface Soil Contamination.
Listed below are the maximum concentrations of various
contaminants detected in subsurface soils. Also included is the
greatest depth to date that each contaminant was detected above
the respective RG. The maximum concentrations do not usually
correspond with the depths stated.
Subsurface detections included the following: vinyl chloride (9.1
mg/kg, maximum depth to 2 feet), trichloroethene (1,100 mg/kg,
maximum depth to 5 feet), 1,2-dichloroethene, total (460 mg/kg,
maximum depth to 7.5 feet), , tetrachloroethene (2,500J mg/kg,
maximum depth to 7 feet), toluene (60 mg/kg, maximum depth to 5
feet), ethylbenzene (1,400 mg/kg, maximum depth to 10 feet), and
xylenes, total (3,700 mg/kg, maximum depth to 14 feet). 1,2-
dichloroethane was not detected in subsurface soils.
The maximum detected SVOC, bis(2-ethylhexyl)phthalate, was
detected at a concentration of 110 mg/kg. The maximum depth at
which bis(2-ethylhexyl)phthalate was detected was 10 feet. The
maximum metal detections were: arsenic (117 mg/kg, maximum depth
to 7 feet), copper (400 mg/kg, maximum depth to 7.5 feet), lead
(17,400 mg/kg, maximum depth to 7 feet), and zinc (7,910 mg/kg,
maximum depth to 7 feet) . Other contaminants were also detected.
These contaminants have the potential to leach to drinking water
above drinking water standards, and therefore, RGs for
groundwater protection were developed for them. Also during
RD/RA, an RG based on protection of groundwater for lead may be
established. The RGs for the protection of groundwater for Ethyl
benzene, Toluene, and Xylenes (Total) may also be reevaluated.
The RGs derived for these contaminants were such that they should
not leach to groundwater above drinking water standards.
However, these derived contaminant levels exceed most of the
levels actually detected in soil samples, yet these contaminants
were detected in the groundwater.
Also during RD/RA, an RG based on protection of groundwater for
lead, may be established.
10
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Surface Water Contamination.
The maximum VOC concentrations detected in lagoon surface waters
were: vinyl chloride (52 /xg/L) , trichloroethene (10J /xg/L),
tetrachloroethene (15J /xg/L) , ethylbenzene (17J /zg/L) , and
xylenes (total) (360 jxg/L) . VOC contaminants 1,2-dichloroethene
(total) (1,400 /xg/L), and toluene (51 /xg/L) , were detected at
maximum concentrations in non-lagoon surface waters. The
compound 1,2-dichloroethane was not detected in lagoon or non-
lagoon surface waters. The SVOC bis(2-ethylhexyl) phthalate was
detected at a maximum concentration of 95J /xg/L in non-lagoon
surface waters. The maximum detected concentrations of metals in
surface water were: arsenic .(5.6 /xg/L) and zinc (1,770J /xg/L) in
lagoon surface waters and copper (116 /xg/L) and lead (343 /xg/L)
in non-lagoon surface water. In the selected remedy, surface
water contamination will be addressed through remediation of the
other contaminated media.
Sediment Contamination.
The maximum detected concentrations of VOCs in sediments were:
vinyl chloride (0.2 mg/kg) wetland sediments; and toluene (2J
mg/kg), ethylbenzene (16 and 1,2-dichloroethene (total) (0.41
mg/kg) in ditch/creek/ mg/kg), and xylenes (total) (68 mg/kg) in
lagoon sediments. The compounds 1,2-dichloroethane,
trichloroethene, and tetrachloroethane, were not detected in
ditch/creek/wetland or lagoon sediments (although
tetrachloroethane was detected in subsurface soils beneath the
lagoon sediments at a maximum concentration of 1.8 mg/kg). The
maximum detected SVOC concentrations in ditch/creek/wetland
sediments was bis(2-ethylhexyl)phthalate at 11 mg/kg. Four
inorganic (metals) contaminants were detected in sediments
(maximum concentrations are given in parentheses): arsenic (57.3
mg/kg), lead (7,470 mg/kg), and zinc (2,080 mg/kg) in lagoon
sediments; and copper (341J mg/kg) in ditch/creek/wetland
sediments. Groundwater protection RGs were developed for some
contaminants to prevent them from leaching to groundwater above
drinking water standards.
RGs for the protection of the ecological system were also
developed for the contaminated sediments, with one area of
exception. The contaminated sediments in the Eastern Wetlands
area (approximately 13 acres in the middle of the Eastern
Wetlands) also currently pose a threat to the ecological system.
However, after careful evaluation of the issues that would be
involved in any remediation effort, EPA believes it would more
11
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protective to the ecological system to not remediate that portion
of the wetlands. The most highly contaminated sediments in the
area (from the Northern Drainage Ditch Area) will be excavated,
thus preventing further migration of metals contaminants into the
Eastern Wetlands. In addition, the area is flooded for much of
the year, and cannot be easily reached, and as such, it would be
very difficult to conduct work there. Substantial destruction of
uncontaminated areas would occur in the process of attempting to
reach the contaminated sediments, from such activities as road
building. Also, the area is not contaminated with VOCs, which
could pose a risk to the groundwater via leaching. Lastly,
natural sediments will cover the contaminated metal sediments in
the Eastern Wetlands, since the higher contaminated source
material in the Northern Drainage Ditch area will be removed.
6.0 SUMMARY OP SITE RISKS
A Baseline Risk Assessment was conducted to evaluate the Site
risks to human health and the environment, under current and
reasonable future land uses. The Baseline Risk Assessment serves
to provide a basis for taking action, and identifies the specific
contaminants and the exposure media (soil, groundwater,
sediments) that need to be addressed by the remedial action. It
serves as an indication of the risks posed by the Site if no
action were to be taken.
This section of the ROD contains a summary of the Baseline Risk
Assessment conducted for the Site. The Baseline Risk Assessment
consists of the following components: identification of
contaminants of concern, exposure assessment, toxicity
assessment, and risk characterization. The ecological risk
assessment and remedial goals are also summarized below.
6.1 Contaminants of Concern
Data collected during the RI were evaluated in the Baseline Risk
Assessment. Contaminants were screened for the Baseline Risk
Assessment using stringent risk-based criteria and by comparison
to background levels for naturally occurring constituents.
Contaminants in the following media were evaluated for human
health risk: soil (surface and subsurface), groundwater (shallow,
intermediate, deep), surface water (lagoons, drainage ditches,
creek), and sediment (lagoons, drainage ditches, creek). The
risk assessment evaluated 34 different chemicals which failed the
risk-based screening in one or more of these media. Contaminants
were not included in the Baseline Risk Assessment evaluation if
any of the following criteria applied:
* For an inorganic compound or element, it was not
detected at or above twice the background
concentration.
12
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* For an inorganic compound or element, it was detected
at low concentrations, -had very low toxicity, and was
judged to be naturally occurring.
* The sampling data included analytical results flagged
as "N" (presumptive evidence) or "R" (not usable).
6.2 Exposure Assessment
Because the site is currently vacant, a trespasser was evaluated
as a receptor in the current use scenario. In this scenario, a 7
to 16 year old (9 year exposure duration) individual is assumed
to trespass onto the site up to 26 days per year (depending on
the area of the site). Incidental ingestion and skin contact
with contaminated soil, sediment, and surface water is assumed.
While the site land use may be commercial/industrial in the
future (as it has been in the past), there is also the potential
for part of the Site to become residential in a future use
scenario, and that a future resident potentially could install a
private well for potable use. This is based on the fact that
there are nearby residential areas. (However, municipal water,
is available to the area.) Therefore, since both a future worker
and a future resident could potentially be exposed to Site
contaminants, both populations were evaluated in the BRA. The
assumed exposure pathways consist of: ingestion of chemicals in
contaminated groundwater, inhalation of chemicals volatilized
during showering, and incidental contact (ingestion/dermal
contact) with soil contaminants.
The future site worker (exposure duration of 25 yrs) is assumed
to incidentally ingest and dermally contact surface soil and to
drink site groundwater while at work. The construction worker
(total exposure duration of 13 days) is assumed to contact
subsurface as well as surface soil. It was assumed that the
future adult resident would ingest two (2) liters per day of
groundwater for a twenty-four (24) year period, and that a child
would drink one liter of water per day for six years. The child
resident is assumed to incidentally ingest 200 mg of soil and to
breath 15 cubic meters (m3) of air per day. The adult resident
is assumed to incidentally ingest 100 mg of soil and to breath 20
m3 of air per day. (These are EPA default exposure assumptions
for the worker and resident.)
6.3 Toxicity Assessment of Contaminants
Under current EPA human risk assessment guidelines, the
likelihood of carcinogenic and noncarcinogenic effects are
considered separately. A brief summary of these separate
approaches follows.
13
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Chemicals are classified for carcinogenicity according to EPA's
weight-of-evidence system. This classification scheme is as
follows: Group A - Known human carcinogen; Group B - Probable
human carcinogen; Group C - Possible human carcinogen; Group D-
Not classifiable; Group E - Evidence of noncarcinogenicity for
humans.
Carcinogens. EPA has developed slope factors (SF) to estimate
excess lifetime cancer risks associated with exposure to
potentially carcinogenic contaminants of concern (Groups A, B,
C) . SFs, which are expressed as risk per milligram per kilogram
of daily dose, are multiplied by the estimated intake of a
potential carcinogen, in mg/kg-day, to provide an upper-bound
estimate of the excess lifetime cancer risk associated with
exposure at that intake level. The term "upper bound" reflects
the conservative estimate of the risks calculated from the SF.
Use of this approach makes underestimation of the actual cancer
risk highly unlikely. Slope factors are derived from the results
of human epidemiological studies or chronic animal bioassay data
to which mathematical extrapolation from high to low dose, and
from animal to human dose, has been applied.
Noncarcinogens. EPA has developed reference doses (RfDs) to
establish the potential for adverse human health effects from
exposure to. the contaminants of concern exhibiting
noncarcinogenic effects. RfDs, which are expressed in units of
mg/kg-day, are estimates of daily exposure levels for humans,
including sensitive subpopulations, that are likely to be without
appreciable risk of adverse effects. RfDs are derived from human
epidemiological studies or animal studies to which uncertainty
factors have been applied (i.e., to account for the use of animal
data to predict effects on humans).
The risk from exposure to lead is determined by calculating the
predicted blood lead level and comparing it to the EPA acceptable
criteria of no greater than 5% probability of exceeding 10 /xg/dL
lead in blood. EPA uses the I.E.U.B.K. model to predict the
blood lead level.
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 carcinogens, the result is expressed as the excess cancer
risk posed by Site contaminants. CERCLA establishes a range of
1 x 10"6 to 1 x 10"4 as the acceptable range for lifetime excess
carcinogenic risks. Excess risk in this range means that the
exposed person has a probability of one in one million (1 x 10'6)
to one in 10,000 (l x 10"4) additional risk of developing cancer
14
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over a lifetime over and above the risk of cancer from other
causes. The calculated cancer risks from all the Site
contaminants are added together to determine the total site risk.
The potential for noncarcinogenic effects is evaluated by
comparing an exposure level over a specified time period (e.g.,
25 year exposure to a worker) with a reference dose derived for a
similar exposure period. The ratio of exposure dose to the RfD
is called a hazard quotient (HQ). An HQ less than 1 indicates
that a receptor's dose of a single contaminant is less than the
RfD, and that toxic noncarcinogenic effects from that chemical
are unlikely. By adding the HQs for all contaminants of concern
that affect the same target organ (e.g. liver) by the same
mechanism, the Hazard Index (HI) is generated. An HI less than
1 indicates that noncarcinogenic toxic effects from all
contaminants are unlikely.
Carcinogenic risk and noncarcinogenic HI values were calculated
for both the current land use scenario, with residents living
near the Site, and the reasonably possible future land uses,
which include commercial/industrial, residential, and a
construction scenario (shorter duration of exposure). The
Baseline Risk Assessment determined that the total cancer risk
(using Reasonable Maximum Exposure) for the current scenario
(nearby resident who trespasses onto the Site) was less than 1 x
10"6; therefore, the Site does not pose an unacceptable cancer
risk under the current exposure scenario. The total HI for the
current scenario was less than 1.0, indicating that the Site does
not pose an unacceptable non-carcinogenic risk under the current
exposure scenario evaluated in the Baseline Risk Assessment.
Therefore, in summary, the Site does not pose any unacceptable
current risk to nearby residents.
The Baseline Risk Assessment determined that the total cancer
risk for the future onsite worker ranged from 7 x 10"5 to
3 x 10"2, depending on which portion of the groundwater is
assumed to be the source of drinking water for the worker. The
HI for the same receptor ranged from 0.3 to 200. Thus the risks
exceed EPA's acceptable risk criteria (carcinogenic and
noncarcinogenic) for the worker who drinks water from the
contaminated groundwater.
The risks estimated from the residential scenarios are also well
above EPA's acceptable risk values since the exposure is greater
for the onsite future resident than for a worker. The cancer
risk for the future onsite resident ranged from 2 x 10"4 to 2 x
10"1. The toxic HI ranged from 2 to 2000 for this receptor.
These risks all exceed EPA's acceptable risk range regardless of
the portion of the affected groundwater the resident was assumed
to have as their drinking water source. The majority of the
onsite risks (both cancer and noncarcinogenic) for the future
worker and residential scenarios are attributable to ingestion of
15
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volatile organic chemicals in the groundwater. In addition to
these risk exceedances, MCLs were exceeded for organic
contaminants and lead exceeded its action level in groundwater.
The construction worker scenario (assumed exposure to subsurface
as well as surface soils, but not to site groundwater) resulted
in acceptable cancer risk (no greater than 1 x 10"6) and HI (less
than l.O).
The future worker scenario assessed the lead in the site soil
using the Recommendations of the Technical Review Workgroup for
Lead for an Interim Approach to Assessing Risks Associated with
Adult Exposures to Lead in Soil (EPA, December 1996). The risks
from soil lead to this receptor were found to be unacceptable.
For the residential scenario, potential exposure of a child to
the lead in the soil and groundwater was assessed using the EPA
Integrated Exposure Uptake Biokinetic Model for Lead in Children
(IEUBK). The risks from soil and groundwater lead to this
receptor were found to be unacceptable.
The actual or threatened releases of hazardous substances from
this Site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
6.5 Ecological Risk Assessment
No state or federally designated endangered or threatened species
are found at the Site. However, the ecological assessment
indicated potential risks to invertebrates and amphibians in the
wetlands from exposure to metals contamination. The specific
contaminants causing risk include lead, zinc, arsenic, and
copper. This unacceptable risk was determined through toxicity
testing of sediment-dwelling invertebrates. For example, for
lead contamination, 700 mg/kg lead was found to be the
concentration at which 50% of the test population died. Higher
concentrations resulted in greater mortality. In addition,
elevated concentrations of arsenic, copper, and zinc were also
found in areas with elevated lead concentrations, which also
posed an unacceptable risk to ecological receptors. Remediation
of wetland areas based upon lead RGs should address areas
containing toxic levels of these other metals as well.
6.6 Remediation Goals
The results of the Baseline Risk Assessment concluded that the
media of concern are surface and subsurface soils, sediments,
surface water and groundwater. Exposure to these media that
exceed acceptable levels, resulted in risks to human health
(assuming an industrial future use), or to the environment. As a
16
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result, Remediation Goals (RGs) were developed for groundwater,
surface soils, subsurface soils (due to leaching of contaminants
to groundwater), and sediments, for protection of a future
industrial worker or for the protection of ecological receptors.
Surface water contamination would be addressed through the
remediation of the other media.
Presently, the Site is not in use. There is a 185,000-square-
foot building onsite, in fair condition, that could be used in
the future for industrial purposes. Discussions with nearby
residents frequently elicited questions such as "when is the
plant going to reopen" or statements to the effect that "we would
like a company to open a new facility so that nearby local
residents could be employed there." In addition, significant
cost may be incurred for removing the building, if the property
was to be converted for a residential use. EPA is therefore
remediating the Site to industrial cleanup standards.
EPA has established specific RGs (i.e. cleanup standards) for
soil, sediments, and groundwater contaminants. Surface water
exceedances will be addressed by addressing the groundwater.
Such standards are derived from several federal environmental
laws, including the Safe Drinking Water Act (for water systems
and potable water sources such as groundwater) and the Clean
Water Act (for surface waters). The State of South Carolina has
similar statutes. Contaminants regulated under these statutes
are present at this Site. In cases where there is no state or
federal standard, remediation goals can be developed based on the
Baseline Risk Assessment for human health (risk assessment
calculations) and the protection of the environment (such as
using toxicological studies). RGs for surface soil were
developed based on the site-specific Baseline Risk Assessment for
a future industrial worker. Subsurface soil RGs were developed
such that the contaminants would not leach to groundwater above
drinking water standards. RGs for the wetland sediments were
developed from toxicity testing conducted at the site for
protection of the environment.
Table 2 summarizes the remediation goals for soil and groundwater
at the Site. The areas potentially requiring remediation are
depicted on Figures 2 and 3, representing groundwater and soil
respectively. However, the exact areas requiring remediation
will be determined during Remedial Design/Remedial Action (RD/RA)
after further sampling is conducted. Also during RD/RA, an RG
based on protection of groundwater for lead in soils may be
established. The RGs for the protection of groundwater for Ethyl
benzene, Toluene, and Xylenes (Total) may also be reevaluated.
The RGs derived for these contaminants were such that they should
not leach to groundwater above drinking water standards.
However, these derived contaminant levels exceed most of the
levels actually detected in soil samples, yet these contaminants
were detected in the groundwater.
17
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In addition, the selected remedy (section 9 of this ROD) does not
include allowing materials classified as RCRA hazardous to remain
onsite. Therefore, such materials must "pass" the RCRA TCLP
test, which establishes whether a material is hazardous waste.
This would include material that is treated such that it "passes"
the RCRA TCLP test. In TCLP testing the following contaminant
levels in the leachate render a waste as RCRA Hazardous: For
lead leachate concentrations greater than or equal to 5 ppm. For
TCE greater than or equal to 0.5 ppm, PCE greater than or equal
to 0.7 ppm.
7.0 DESCRIPTION OP Bl^MEDIAL ALTERNATIVES
The FS considered a wide variety of general response actions and
technologies for remediating the various contaminated media. The
various technologies were screened and those listed below on
Table 3 were considered in the FS Report.
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/direct contact with surface soil,
sediment, and hydric soil having:
Carcinogen concentrations above levels that would
exceed an acceptable cancer risk range of 10~" to
10"6 and,
Noncarcinogen concentrations above Federal or
State standards, or in the absence of standards,
above levels that would exceed an acceptable
Hazard Index (HI) of 1.0.
• Prevent migration of contaminants from surface and
subsurface soils (uplands and wetlands) that would pose
a risk to human health due to leaching of contaminants
to groundwater in excess of Federal/State limits or
health-based levels.
18
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Table 2
REMEDIAL GOALS (RGs)
CONTAMINANTS OF CONCERN
Bis-2-ethylhexyl phthalate
1,2-Dichloroethane
1,2-Dichloroethene (Total)
Tetrachloroethene
Trichloroethene
Vinyl Chloride
Ethyl benzene
Toluene
Xylenes (Total)
Lead
CONTAMINANTS OF CONCERN
Bis-2-ethylhexyl phthalate
1 ,2-Dichloroethane
1,2-Dichloroethene (Total)
Tetrachloroethene
Trichloroethene
Vinyl Chloride
Ethyl benzene
Toluene
Xylenes (Total)
Lead
GROUNDWATER (RGs) UG/L
6.0
5.0
70
5.0
5.0
2.0
700
1000
10,000
15*
RGs for Protection of
Groundwater. Soil concentrations
below which leaching above MCLs
is not expected to occur (rag/kg)
Not detected in TCLP leachate, but
detected in total results of soil
samples. May be determined in
RD/RA.
Not detected in TCLP leachate
1.5
0.1
0.09
0.74
62
136
1400
May be determined during RD/RA
MCLs
(ug/l)
6.0
5.0
70
5.0
5.0
2.0
700
1000
10,000
15*
* Action Level
19
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CONTAMINANTS OF CONCERN
Lead - Industrial
Arsenic
Beryllium
CPAH (BAP-TE) (PolycycUc Aromatic Hydrocarbons)
RGs FOR SURFACE SOILS
(mg/kg)
1150
34
12
5
ECOLOGICAL RGs BASED dNTOXICITY STUDIES
CONTAMINANTS OF CONCERN
Lead
Arsenic
Copper
Zinc
mg/kg
700
15
150
350
The RGs for the protection of groundwater for Ethyl benzene, Toluene, and Xylenes (Total),
and bis-2-ethylhexyl phthalate may be reevaluated during RD/RA since the calculated levels
exceed most of the levels detected in the soil samples, yet these contaminants were detected in
the groundwater. Lead may have an RG established for protection of groundwater during
RD/RA.
20
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FIGURE 2
CD
CO
-------
rWTTCDON Or HUMAN NCA1TI
»IM fonwruL n> UAO
nccKAi. ua.
SOI. fXCttOMQ
"00 Of 7 ^^
wioitenoH of.lectcac*
ENSR CONSULTING A
L0
[POTENTIALLY REQuiRiNAREpoNSE
SCALE IN FE£T
T = 150-0*
-------
TABLE 3
GROUNDWATER ALTERNATIVES
7 of 9 Criteria
Overall
Protection
MectARAR*
Long-Tern
Protective uid
Permmnent
Reduce Toiklty,
Mobility A
Volume (TMV)
Through
Treatment
Short-Term
Effectiveness
Iraplemeatabiury
Coit (PW)
Alternative 1
No Action
Would not be overall protective
since no action is occurring, just
groundwaler monitoring.
Would not meet ARARS since
no action is occurring.
Would not be long-term
protective since no action is
occurring.
Would not reduce toxicity,
mobility or volume of
contaminants.
No short-term implementation
risk since no action is occurring.
No implementation difficulties
since there would be no action.
$1.35 million
Alternative 2
Limited Action
Would not be overall protective
since only a minimal amount of
contaminated, gw is removed
during source removal. No
action after this, only
institutional controls.
Would not meet ARARs since
most contamination is not
addressed
Would not be long-term
protective since most
contamination is not addressed.
Would not reduce toxicity,
mobility or volume or
contaminants, since most
contamination is not addressed.
No risk since minimal action is
occurring
Minimal implementation
difficulties since there would be
minimal action.
SI. 8 million
Alternative 3
Source Removal w/dewatering,
evaluation period, active (round
water treatment, and NaL Arten., If
applicable
Would be overall protective, since the
contaminated groundwater would be
addressed.
Would meet ARARs, since the
contaminated groundwater would be
addressed
Would be long-term protective, since
the contaminated groundwater would
be addressed.
Would reduce the TMV. since the
contaminated groundwater would be
addressed.
Some risk during excavation, and
during extraction of contaminated, gw.
Some w/ extraction.
$2.4-5.0 million
Alternative 4
Source removal w/
dcwalertnf , source area
eilractlon wells or
trenches
May not be overall
protective, since only the
source area contaminated
gw would be addressed.
The contaminated, gw that is
past the source area would
not be addressed (i.e.
between source area and
property boundaries).
May not meet ARARs, since
only the source area
contaminated gw would be
addressed, and not the
contaminated gw past the
source area.
May not be long-term
effective for reasons staled
above.
Would reduce the TMV of
some of the contaminated.
gw through treatment, but
not all contaminated, gw.
Some risk during
excavation, and during
extraction of contaminated
gw.
Some w/ extraction.
S3 8 • 4.7 million
Alternative S
Source removal w/ dewaterinc, property
boundary eitractton wells
Would be overall protective, since the
contaminated, gw would be addressed
However, it may take longer than other
alternative, since the source area
contaminated, gw would have to migrate to
the properly boundary to be addressed
Would meet ARARs, since the contaminated
gw would be addressed
Would be long-term protective since the
contaminated gw would be addressed.
Would reduce the TMV. since the
contaminated, gw would be addressed.
Some risk during excavation, and during
extraction of contaminated, gw.
Some w/ extraction.
$46 million
23
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TABLE 4
SOIL ALTERNATIVES
7 of 9 Criteria
Overall Protection
MeclARARi
Lone-Term
Protective and
Permanent
Reduce TMV
Through Treatment
Short-Term
Effectiveness
ImplemenUblliry
Cost(PW)
Alternative 1
No Action
Would not be overall protective
since no action is occurring.
Would not meet ARARs since no
action ii occurring.
Would not be long-tarn protective
since no action is occurring.
Would not reduce toxicity and
mobility or volume.
No risk since no action is occurring.
No implementation difficulties
since there would be no action.
SO
Alternative 2
Limited Action
Would not be overall protective since none of
the contaminated soil is addressed, just a deed
restriction informing future owners of the
contamination. Also, contaminants would
continue to leach to groundwater and there
would be a continuous risk to the environment.
Would not meet ARARs since contamination is
not addressed.
Would not be long-term protective since
contamination is not addressed.
Would not reduce TMV of contaminants.
No shorl-lctm implcmcnlability risk since no
action is occurring.
No implementation difficulties since there
would be no action.
$120,000
Alternative 3
Eicavatlon and On-Slte Capping
with No Bottom Uner
Uncertainly that this is overall
protective since contaminated.
could leach to gw above MCLs.
Uncertainty that this alternative.
meets ARARs since contaminated.
could leach to gw above MCLs.
Uncertainty that this alternative, is
long-term protective and
permanent, since contaminated
may leach into the gw above MCLs.
Would not reduce TV of
contaminants, but should reduce the
mobility to some degree.
Some risk during excavation from
lead dust and VOCs in the air.
Minimal.
$7.7 million
Alternative 3A
Eicavatlon and On-Slte Capping with Bottom
Uner for RCRA Non-Hazardous Soil and Off-
Site Disposal of RCRA Hazardous Soil
May be overall protective, but there is some) concern
that the RCRA hazardous, waste may leach to gw
above MCLs.
May meet ARARs, but there is some concern that
the RCRA hazardous, waste may leach to gw above
MCLs.
May be long-term protective, but there a some
concern that the RCRA hazardous, waste may leach
to gw above MCLs.
Would not reduce TV of contaminants, but should
reduce the mobility to some degree.
Some risk during excavation.
Minimal.
$9.0 million
-------
TABLE 4 (con't)
SOIL ALTERNATIVES
7 of 9 Criteria
Overall Protection
Meet ARARj
Lonf-T«nn
Protective end
Permanent
Reduce TMV
Through Treatment
Short-Term
EITectlveneu
ImplemenUMttty
Cost (P\V)
Altenullve3B
Eicavatlon uid On Site
Capping with Bottom Uner
for RCRA Non-Huardoui
Soil, Oflstte RCRA
Hazardous SoU.
Should be overall protective,
since all had waste would be
removed from the site, and the
rest land filled, if the landfill u
maintained indefinitely.
Should meet ARARs, since all
haz waste would be removed
from the site, and the rest
landfilled; if the landfill u
maintained indefinitely.
Should be long-term protective
as described above.
Some if haz. waste disposed off-
site is treated.
Some risk during excavation.
Applies to all alternatives, but
Alternative) 1 and 2.
Minimal.
$11. 2 million
Alternative 4
StabUUattom//SoUdlfkatlon.
Would be overall protective though
there may be some diff
Stabilization/Solidification VOC
centime, soils such that they do not
leach contain, into the gw above
MCLs.
Would meet ARARs though there may
be some difficulty. Stabilization/
Solidification VOC contaminated soils
such that they do not leach
contamination into the groundwatcr
above MCU
Would be long-term protective though
there may be some diff.
Stabilization/Solidification VOC
contaminated, soils so that they do not
leach contaminated into the
groundwatcr above MCLs.
Would reduce toxicity and mobility
but not volume
Some risk during excavation and
Stabilization/Solidification activities.
Some difficulty during excavation and
Stabilization/ Solidification activities.
$10.6-20.3 million
Alternative 5
In-slru Thermal treatment w/
a) Containment or b)
Stabilization/ Solidification
According lo literature, it may be
overall protect.
According to literature, it may meet
ARARs.
According to literature, it may be
long-term protective.
If effective, it would reduce the TMV
of the organic contamination and
possibly the inorganic (if
Stabilization/Solidification used).
Minimal risk for the in-situ thermal
part, some risk if Stabilization/
Solidification utilized
May be difficult to implement due to
saturated clayey soils.
S 10 -15 million
Alternative 6
Thermal Desorption with
a) Containment orb)
SlablUzatton/ Solidification
Would be overall protective since
the organic soils are treated and the
metal soils are treated or contained
such that they should not leach lo
gw above MCLs.
Would meet ARARs since the
organic soils are treated and the
metal soils are treated or contained
such that they should not leach to
groundwater above MCLs.
Would be long-term protective
since the organic soils are treated
and the metal soils are treated or
contained such that they should not
leach to groundwater above MCLs.
Would reduce TMV of organics, &
T&M of inorganic soils if
Stabilization/Solidification. If
contained, will not reduce the TMV
of metal contaminants.
Some risk during excavation and
thermal desorption (and
Stabilization/Solidification if this
option is chosen).
Some difficulty during excavation
and greater difficulty w/ thermal.
$19.3-27.0 million
Alternative 7 v-
OfT Site Disposal
Would be overall plot since all
contain, soils would be removed from
the site. |
Would meet ARARs since all
contaminated soils would be removed
from (he site.
Would be long-term protective and
permanent, since all contaminated
soils would be removed from the site.
Some if waste disposed off-site is
treated
Some risk during excavation and
minimal during transport
Some difficulty during excavation
SI 1.8 million
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• Prevent concentrations of contaminants from exceeding
the applicable Federal and South Carolina Ambient Water
Quality Criteria for surface waters.
• Restore the groundwater system to potential productive
use, by cleanup to the standards described above, and
by minimizing the migration of the contaminants beyond
the existing limits of the contaminant plume.
• Prevent direct contact with sediments or hydric soils
that would result in an unacceptable risk to ecological
receptors.
• Prevent ingestion of contaminated groundwater from the
Site containing:
Carcinogen concentrations above Federal or State
standards, and above levels that would exceed an
acceptable cancer risk range of 10~4 to 10"6
(unless the risk manager decides that a risk level
less than 10~4 (i.e., a risk between 10~4 and 10~6)
is unacceptable due to site-specific conditions),
and
Noncarcinogen concentrations above Federal or
State standards, or in the absence of standards,
above levels that would exceed an acceptable
Hazard Index (HI) of 1.0.
Technologies considered potentially applicable to the various
contaminated media were further evaluated based upon their
effectiveness and implementability. Listed below are those
alternatives which passed this final screening, and were
considered for remediation in the FS Report. Costs for each
alternative are given as a total of the net present worth costs
("PW cost"), which includes a capital cost component (typically
for construction), added to an operations-and-maintenance ("O&M")
cost.
Alternatives for Remediation of Groupdwater. Five (5)
alternatives were developed to address groundwater contamination.
The components of Alternative 2, institutional controls and
groundwater and surface water monitoring, are implied for all
alternatives, except no action. A source removal as discussed in
the Soil Alternative 3B is also included with Alternatives 3 to
5. The costs for monitoring for all the alternatives, is for a
thirty (30) year period. For the alternatives which involve a
treatment technology, the cost is for a ten (10) year operating
period. For each alternative, remedial action objectives will be
considered met when the concentrations listed in Table 2 are not
exceeded in any monitoring wells, continuously.
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7.1 Alternative 1; No Action
Under the no action alternative, the Site is left "as is" and no
funds are expended for the control or cleanup of the contaminated
groundwater (including no source removal). If no action is
taken, future risks to potential persons living on or working at
the Site will remain. Because hazardous contaminants would
remain, five (5) year reviews would be required under CERCLA.
PW Cost: $1.35 million.
7.2 Alternative 2: Source Removal with Groundwater Extraction
During Excavation Period
This alternative includes the use of a wellpoint system to
dewater the soil/sediment source areas for excavation.
Excavation of source areas would be conducted in parallel and
includes: the Wastewater Lagoons, the Solids Lagoons area, the
Pill/Debris area, the Northern Drainage Ditch, and the Southern
Wetlands, including the southeast corner. Where groundwater
extraction is required for source removal, the water table must
be lowered approximately five (5) feet below the ground surface,
and deeper in some locations. Groundwater to be extracted from
these source areas contain the highest concentrations of
contaminants of concern (COCs, or chemicals for which RGs have
been established) on site. The groundwater extraction proposed
in this alternative would occur during the period of excavation
only. Extracted groundwater would be treated through an above-
ground portable treatment system possibly consisting of an air
stripper, liquid and vapor phase carbon, and a frac tank. The
treatment system effluent would be discharged to Turkey Creek
(through an NPDES permit), groundwater (through an underground
injection permit) , or the local POTW.
The institutional controls to be used are deed notations and well
permit restrictions. Deed notations limit future use of the
aquifer for such purposes as potable and industrial water
supplies, irrigation, and washing. Permit restrictions issued by
the State of South Carolina would restrict all well drilling
permits issued for new wells on properties that may draw water
from the contaminated groundwater plume. These restrictions
would be written into the property deeds to inform future
property owners of the possibility of contaminated groundwater
beneath their property. Groundwater monitoring would involve
monitoring existing wells and additional monitoring wells (as
well as the temporary extraction wells, unless EPA approves their
abandonment). Groundwater samples from the wells would be
collected and analyzed periodically to evaluate contaminant
concentrations and to monitor the extent and direction of
contaminant migration. In addition, surface water monitoring
(especially from the Southern Wetlands including the South Ditch)
would also be conducted to monitor the groundwater plume.
PW Cost: $1.8 million.
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7.3 Alternative 3: Source Removal with Temporary Groundwater
Extraction for Dewatering. Data. Collection/Aquifer Evaluation.
Active Groundwater Treatment of remaining contaminated
groundwater. and if applicable. Monitored Natural Attenuation.
Some of the contaminated soils to be excavated during the source
removal (as described in Soil Alternative 3B below) are located
below the water table, so that those areas will need to be
dewatered during excavation. A temporary groundwater recovery
and treatment system (as described in Groundwater Alternative 2)
will be used for dewatering purposes during the source removal.
For this alternative, the system will be operated for an
additional four to six months after completion of the soil
removal.
An evaluation period for gathering data to design a proactive
groundwater treatment system (pump and treat, recirculation
wells, air-sparging, or a combination) to achieve RGs throughout
the entire groundwater plume, will be conducted before, during
and after the source removal. If, during the evaluation period,
monitored natural attenuation can be demonstrated to be as
effective as active remediation (to be determined by EPA and in
accordance with EPA's guidance documents), within a comparable
time frame, then this approach may be applied to the appropriate
portions of the contaminated groundwater plume. If this occurs,
a ROD Amendment or ESD will be completed by EPA as determined
necessary by EPA or SCDHEC. This evaluation period will be
completed within 6 months of the shutdown of the temporary
system. This will be followed by construction and operation of
the groundwater system. PW Cost: $2.4 - $5.0 million.
7.4 Alternative 4 - Groundwater Extraction and Treatment in
Source Area
As described above for Alternative 3, since some of the
contaminated soils to be excavated during the source removal are
located below the water table, those areas will need to be
dewatered during excavation. A temporary groundwater recovery
and treatment system (as described in Groundwater Alternative 2)
will be used for dewatering purposes during the source removal.
The temporary groundwater extraction proposed in this alternative
would occur during the period of excavation only.
After the soil excavation, active treatment of groundwater
utilizing a pump and treat system (extraction trench(es) or
wells), would occur in the Fill/Debris area, the Solids Lagoon
area, and downgradient of the Solids Lagoon area. The extraction
system will create a zone of influence and prevent the further
migration of COCs from the source area. The contaminated
groundwater not within the capture zone, would continue to
migrate. PW Cost: $3.8 - 4.7 million.
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7.5 Alternative 5 - Groundwater Extraction and Treatment Near
Property Boundary
As with the alternatives described above, areas where
contaminated soils are below the water table will be dewatered
during excavation. A temporary groundwater recovery and
treatment system (as described in Groundwater Alternative 2) will
be used for dewatering purposes during the source removal. The
temporary groundwater extraction proposed in this alternative
would occur during the period of excavation only. To prevent
further migration of COCs, this alternative includes the
installation of an extraction well system near the property
boundary (railroad bed). The configuration may consist of an
irregular line of wells based on the COC concentrations. To
capture all of the flow paths which contain concentrations
exceeding MCLs near the property boundary or migrating towards
the property line, a line of extraction wells approximately 900
feet long may be required. The extraction wells may need to be
spaced at approximately 40-foot centers and installed to the
bottom of the shallow water-bearing unit (approximately 15 feet),
depending on the hydraulic properties of this shallow unit. This
spacing will require the installation of a number of extraction
wells near the property boundary. The exact number and
configuration of wells would be determined during RD/RA. This
alternative will take longer to reach the remediation goals
because of the time necessary for the contaminant plume to
migrate to the extraction wells. PW Cost: $4.6 million.
Alternatives for Remediation of Soil. Seven (7) alternatives
were developed to address soil contamination. The components of
Alternative 2, institutional controls and groundwater and surface
water monitoring, are implied for all alternatives, except the no
action alternative. A source removal consisting of excavation of
all soils which exceed RGs, as described in Soil Alternative 3B,
is considered a part of each of the soil Alternatives 3B through
7. Soil includes surface and subsurface soils from the upland
areas, as well as the wetland "hydric" soils and sediments,
referred to in the FS Report and subsurface soils from the
wetlands. For each alternative, remedial action objectives will
be considered met when the concentrations listed in Table 2 are
not exceeded.
7.6 Alternative 1: No Action
Under the no action alternative, the Site is left "as is" and no
funds are expended for the control or cleanup of the contaminated
surface and subsurface soils, and sediments. If no action is
taken, future risks to potential persons living on or working at
the Site will remain. Because hazardous contaminants would
remain, a five (5) year review would be required under CERCLA.
PW Cost: $0.
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7.7 Alternative 2; Limited Action
In this alternative, institutional controls would be implemented
and a fence would be constructed around the area within which
surface soils exceed RGs. The institutional controls would
include a deed or other restriction limiting uses and activities
of those portions of the property in which soils exceeding RGs
have been left in place. The deed restriction would serve as
notification to potential purchasers or developers of the
property that land use is restricted in these areas and the
location of the untreated soils. Fencing commonly used to limit
access is 6 or 8-foot high chain-link; barbed wire would be
strung along a top brace as an additional deterrent to
trespassers. Signs would be posted at regular intervals, warning
the trespasser of the potential danger. Routine inspection is
required to maintain the fence. PW Cost: $120,000.
7.8 Alternative 3; Excavation and On-Site Capping with No
Bottom Liner
Contaminated soil with concentrations exceeding RGs in Table 2,
including RCRA hazardous and RCRA non-hazardous soils, would
either be capped in place, for some of the metals-only-
contaminated soil (in or near the groundwater), with an
engineered cap; or excavated (soil containing both metals and
organics) and placed -under an engineered cap. The design and
construction of the capped areas would include a low permeability
Flexible Membrane Liner (FML) cap. Capped areas would be
isolated by fencing. Contaminated soils that are excavated would
be placed at least three feet above the seasonal high water table
in the areas set aside for construction of the cap(s). Clean
fill will be added if necessary to create this separation.
Initial lifts will be of metal contaminated soils passing the
RCRA TCLP test, and the upper lifts will consist of higher
concentration metals contamination (RCRA hazardous) and mixed
VOCs and metals contaminated soils (some of which would also be
RCRA hazardous).
Those soils to be excavated that are saturated (i.e. wet) would
be transported to a construction pad with controlled drainage
(collection and treatment), and mixed with drying agents such as
quicklime to absorb excess moisture and improve their physical
and load bearing characteristics. In addition, VOCs would be
released from the contaminated soils from the mixing process with
the dewatering reagent, as well as from materials handling
processes. During Remedial Design, laboratory treatability
testing and field pilot studies will be conducted to gather
volatilization data to predict emissions during full scale soil
excavation and modification activities, and to determine the
amount of VOCs remaining in the soils. Soil vapor extraction
(SVE) laterals may be placed throughout the organic contaminated
soils beneath the cap, unless limited volume and concentrations
30
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of VOCs remain or it is determined during remedial design that
SVE would not be effective due to permeability issues.
PW Cost: $7.7 million.
7.9 Alternative 3A; Excavation and On-Site Capping with Bottom
Liner for all Contaminated Soils
All contaminated soil with concentrations exceeding the RGs in
Table 2, including RCRA hazardous and RCRA non-hazardous soil,
would be excavated and moved to an engineered containment system
(cap). The design and construction of the containment areas
would include components such as a low permeability FML cap, an
underliner and a leachate collection system. Containment areas
would be isolated by fencing.
Excavated soils that are saturated would be transported to a
construction pad with controlled drainage (collection and
treatment) and mixed with drying agents such as quicklime to
absorb excess moisture and improve their physical and load
bearing characteristics. In addition, VOCs would be released
from the contaminated soils during the mixing process with the
dewatering reagent, as well as from materials handling processes.
During Remedial Design, laboratory treatability testing and field
pilot studies will be conducted to gather volatilization data to
predict emissions during full scale soil excavation and
modification activities, and to determine the amount of VOCs
remaining in the soils. Soil vapor extraction (SVE) laterals may
be placed throughout the organic contaminated soils beneath the
cap, unless limited volume and concentrations of VOCs remain or
it is determined during remedial design that SVE would not be
effective due to permeability issues. PW Cost: $9.0 million.
7.10 Alternative 3B; Excavation and On-Site Capping with Bottom
Liner for RCRA Non-Hazardous Soil and Off-Site Disposal of RCRA
Hazardous Soil
All contaminated soils that exceed RGs in Table 2 will be
excavated. Soils that remain designated as RCRA hazardous waste
would be disposed of off-site at an acceptable hazardous waste
facility. Soils which are RCRA non-hazardous would remain on-
site. The portion of the RCRA non-hazardous waste which leaches
above drinking water standards would be disposed in an on-site
RCRA Subtitle D landfill. Soils not leaching above MCLs would be
placed under an engineered cap, to prevent direct contact
exposure. The design and construction of the Subtitle D landfill
would include components such as a low permeability cap, an
underliner and a leachate collection system. Clean soil will be
added to bring the bottom of the landfill to at least three feet
above the seasonal high water table. The initial soil lifts will
be of metal contaminated soils, and the upper lifts will be mixed
VOC and metals contaminated soils.
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As with the alternatives above, excavated soils that are
saturated would be transported to a construction pad with
controlled drainage (collection and treatment) and mixed with
drying agents such as quicklime to absorb excess moisture and
improve their physical and load bearing characteristics. In
addition, VOCs would be released from the contaminated soils
during the mixing process with the dewatering reagent, as well as
from materials handling processes. During Remedial Design,
laboratory treatability testing and field pilot studies will be
conducted to gather volatilization data to predict emissions
during full scale soil excavation and modification activities,
and to determine the amount of VOCs remaining in the soils. Soil
vapor extraction (SVE) laterals may be placed throughout the
organic contaminated soils beneath the cap, unless limited volume
and concentrations of VOCs remain or it is determined during
remedial design that SVE would not be effective due to
permeability issues. PW Cost: $11.2 million.
7.11 Alternative 4; Stabilization/Solidification
All contaminated soils that exceed Remedial Goals in Table 2 will
be excavated. These soils would be treated using stabilization/
solidification (S/S). The soils would be excavated, treated and
consolidated on site in upland areas. Treatment effectiveness
would be evaluated using TCLP tests (regular and modified) , and
possibly other tests (such as the ASTM Water Leach, ASTM D3987-
85) and be compared to regulatory levels (RCRA hazardous, MCLs
and the Action Level for lead). Treated areas would be isolated
by fencing with signs, and would be covered with a cap.
The method of S/S (i.e., in-situ or ex-situ) used will depend on
the contaminated depth as well as the specific characteristics of
the soil and type of contamination, and will be determined during
design. The term stabilization refers to the technology where a
chemical agent, typically self-cementing (pozzolanic), is added
to a waste to reduce the hazard potential of that waste;
solidification refers to processes that convert liquid and semi-
solid wastes to a solid form (monolith) , typically binding
contaminants mechanically in the solid matrix.
Given the present knowledge of the soil characteristics, type and
depth of contamination (VOCs as wells as metals), ex-situ S/S,
would most likely be the most appropriate method for treating
contaminated soils, (especially for the VOC contaminated soils) .
It also provides a more uniform mixing of reagents with
contaminated soils. In addition, the soils will be aggressively
treated by aeration during the mixing process as well as from
materials handling processes. During Remedial Design, laboratory
treatability testing and field pilot studies will be conducted to
gather volatilization data to predict emissions during full scale
soil excavation and modification activities, and to determine the
amount, if any, of VOCs remaining in the soils.
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On a CERCLA site, treatment of RCRA materials in a vessel may
potentially trigger Land Disposal Restrictions (LDRs), if levels
after treatment still exceeded the Universal Treatment Standards
(UTS) . Because S/S may include use of a vessel, LDRs will need
to be adhered to. This may also include meeting the UTSs for any
underlying hazardous constituent levels for various contaminants
(such as lead). PW Cost: $10.6 - 20.3 million.
7.12 Alternative 5: In Situ Treatment Followed by A)
Containment; or B) Stabilization/Solidification
All contaminated soils that exceed RGs in Table 2, will be
excavated. These soils would be treated using an in situ thermal
treatment technology to reduce concentrations to below RGs as
described on Table 2. Inorganic contaminated soils would require
Stabilization/Solidification as described for Alternative 4,
and/or containment as described for Alternative 3B. Treated
areas would be isolated by fencing and would be covered with an
engineered cap.
Potential process options for thermally treating soils include
steam injection, hot air flushing, and six-phase soil heating
(SPSH). According to literature, SPSH has better performance
data for treating fine-textured material both in the vadose zone
and below the groundwater table. Therefore this will be the only
option discussed. Six-phase soil heating (SPSH) is a technique
that uses common low-frequency electricity to heat soils by
converting standard three-phase power to six-phase power.
Electrodes are inserted into the ground in circular arrays. Each
electrode is connected to a separate transformer with a separate
current phase. A seventh, neutral electrode is located at the
center of the array and doubles as a soil vent. As electricity
is applied, the soil heats, volatilizing organic compounds which
are removed through the central soil vent. Pore water in the
soil is the principal conductor of electricity. This technology
is a variation of radio frequency heating, using one-fifth to
one-tenth the power to achieve similar results.
The selection of a preferred process option would be determined
after pre-design sampling and analysis for geophysical parameters
in the areas requiring treatment. Each of these areas contain
different materials with varying moisture contents, and
potentially different COCs at different concentration ranges.
All of these factors will affect the layout of the electrode
system, the heating power per unit time, and the time to
remediate. Data collection programs during pre-design phases
would be designed to include collection of these data. Due to
the relatively high concentrations of COCs in the soils, it may
also be necessary to install .a temporary low permeability barrier
on the surface of the ground to prevent the uncontrolled release
of vapors during thermal treatment.PW Cost: $10.0 - 15.3 million.
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7.13 Alternative 6: Low Temperature Thermal Desorption Followed
by A) Containment; or B) Stabilization/Solidification
All contaminated soils that exceed RGs will be excavated. Those
soils with the potential to leach organic COCs in excess of the
MCLs would be treated ex-situ using low temperature thermal
desorption to reduce concentrations below the RGs listed on Table
2. Thermal desorption processes are designed to remove the
volatile and some semi-volatile organic compounds from soil,
based on the volatility of the target compounds and operating
temperatures of the treatment unit. Thermal desorption is
different from incineration in that the soils are heated to a
temperature at which the target compounds will volatilize but not
to temperatures in excess of that target temperature. Normal
target temperatures range from 200-1000°F. The excavated soils
would be heated to the target temperature. In addition to target
temperature, residence times must be sufficient to insure
volatilization is complete. Residuals generated from the
treatment include volatiles (VOCs) and offgas. Offgas is
typically treated to remove particulates, water vapor, and
volatile organics by one or more of the following methods:
afterburning, activated carbon, or recovery through condensation.
Depending on the type of offgas treatment used, additional
residuals may be generated including spent carbon or condensed
water. The spent carbon would be regenerated. Most remedial
actions employing low-temperature thermal desorption use a mobile
piece of equipment and complete the treatment on-site. A test
run may be necessary to determine the most appropriate size of
equipment, and operating temperature and residence time.
As thermal desorption does not treat inorganic-contaminated
soils, they would require treatment and/or containment. These
soils would either be: A) capped as otherwise described in
Alternative 3B; or B) stabilized/solidified as described in
Alternative 4.
pifferent areas on-site contain different materials with varying
moisture contents, and potentially different COCs at different
concentration ranges. All of these factors will affect the
degree of pretreatment required for the low temperature thermal
desorber feedstock, the operating temperatures, process rate, and
the resulting cost. Data collection programs during pre-design
phases would include collection of these data. It is common to
perform pilot-scale field tests using a thermal desorber prior to
establishing full-scale operating parameters. PW Cost: $22 - 27
million.
7.14 Alternative 7; Excavation and Off-Site Disposal
All contaminated soils that exceed Remedial Goals (RGs, Table 2),
would be excavated and disposed off-site. Facilities may
solidify the soils prior to disposal. Some of the contaminated
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soils from the Shuron site "pass" TCLP tests and would be
classified as RCRA non-hazardous. Some of the contaminated
soils, however, may "fail" the TCLP tests and would then be
classified as RCRA hazardous waste. PW Cost: $11.8 million.
8.0 COMPARATIVE ANALYSIS OP ALTERNATIVES
The fourteen (14) alternatives for remediation were evaluated
based upon the nine (9) criteria, described below, set forth in
40 C.F.R. § 300.430(e)(9) of the NCP. In the sections which
follow, brief summaries of how the alternatives were judged
against these criteria are presented. Seven (7) of the criteria
are based on environmental protection, cost, and engineering
feasibility issues. The preferred alternative is then further
evaluated based on the final two criteria, State and Community
acceptance.
Threshold Criteria; The first two (2) statutory requirements must
be met by the alternative:
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.
2. Compliance with applicable or relevant and appropriate
requirements (ARARs) addresses whether an alternative will meet
all of the requirements of Federal and State environmental laws
and regulations, as well as other laws, and/or justifies a waiver
from an ARAR. The specific ARARs which will govern the selected
remedy are listed and described in Section 9.0, the Selected
Remedy.
Primary Balancing Criteria; Five (5) criteria were used to weigh
the strengths and weaknesses of the 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.
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), direct that, when possible, EPA should choose a treatment
35
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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.
3. Short-term effectiveness refers to the potential for adverse
effects to human health or the environment posed by
implementation of the remedy.
4. Implementability considers the technical and administrative
feasibility of an alternative, including the availability of
materials and services necessary for implementation.
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.
Modifying Criteria: These two (2) considerations indicate the
acceptability of the alternative to the public, local, or state
officials.
l. State Acceptance addresses whether, based on its review of the
RI/FS and the Proposed Plan, the State concurs with, opposes, or
has no comments on the selected preferred alternative, or remedy.
2. Community Acceptance addresses whether the public agrees with
EPA's selection of the preferred alternative. Community
acceptance of the Proposed Plan was evaluated based on comments
received during the public meetings and during the public comment
period.
8 .1 SOIL REMEDIATION ALTERNATIVES
8.1.1 Threshold Criteria
Soil Alternatives 1 (No Action) and 2 (Institutional
Controls/Monitoring), do not meet the threshold criteria of
protecting human health and the environment and meeting ARARs,
since no remedial action is taken. There is high uncertainty
whether Soil Alternative 3 (Capping with no bottom liner) will be
overall protective of human health and the environment and will
meet ARARs, because of the potential for contaminants to leach to
the groundwater above MCLs (especially the VOCs). This is a
significant concern since the water table at the Site is very
shallow, about 3 feet below land surface, and much of the
contaminated soil is saturated. Soil Alternative 3A may meet the
threshold criteria, but there remains some uncertainty as to
whether hazardous waste, as defined by RCRA, will leach from the
containment system. RCRA regulations require that RCRA hazardous
waste be treated to meet Land Disposal Restrictions (LDRs)
Treatment Standards prior to being placed into a Subtitle D
landfill (ARAR) , and this alternative does not even include all
the requirements of a Subtitle D landfill. Alternative 3B
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(Excavation and On-Site Capping with Bottom Liner for RCRA Non-
Hazardous Soil and Off-Site Disposal of RCRA Hazardous Soils)
would probably be adequately protective, provided the landfill
was maintained indefinitely. Alternative 5 may meet the
threshold criteria according to the literature; however, there is
still some concern about its protectiveness since In-Situ Thermal
Treatment is a relatively new technology.
The other three (3) alternatives, Alternative 4 (Stabilization/
Solidification, Alternative 6 (Low Temperature Thermal Desorption
followed by A) Containment; or B) Stabilization/Solidification,
and Alternative 7 (Off-Site Disposal) will meet the two (2)
threshold criteria of being protective of human health and the
environment and meeting ARARs. A combination of Alternative 4
with Alternative 3B, may be more overall protective than either
alternative alone.
For instance, the soils could be aggressively aerated and treated
using S/S to treat the metals and most of the VOC contaminants,
so that they no longer leach above MCLs. Then alternative 3B
could be implemented such that those hazardous soils that
continue to leach above LDR treatment standards (UTS), would be
disposed of off-site. Those with TCLP leachate containing
contaminant levels between LDR treatment standards and MCLs,
expected to be soils containing VOCs primarily, could be placed
into a RCRA Subtitle D landfill. Those soils which no longer
leach above drinking water standards could be placed on the
ground under an engineered cap. Thus this combination would be
overall protective and meet ARARs, since the high level
contamination would be removed from the Site, and any
contaminants that could potentially still leach above MCLs, after
aggressive treatment, but at considerably lower levels than
before treatment, would be prevented from leaching into the
groundwater utilizing engineering controls.
8.1.2 Primary Balancing Criteria
Soil Alternatives 1 (No Action) and 2 (Institutional
Controls/Monitoring), will not meet the criteria for long-term
effectiveness and permanence, since no action will be taken.
There is high uncertainty that Soil Alternative 3 (Capping with
no bottom liner) and some uncertainty that Soil Alternative 3A
will be long-term effective for the same reasons stated above,
since the groundwater is so shallow. Alternative 3B (Excavation
and On-Site Capping with Bottom Liner for RCRA Non-Hazardous Soil
and Off-Site Disposal of RCRA Hazardous Soils) would probably be
long-term protective, under the conditions described above.
Alternatives 1, 2, 3, 3A, and 3B, do not meet the statutory
preference for the reduction of toxicity, mobility, or volume
through treatment. This preference directs that, when possible,
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EPA should choose a treatment process that permanently reduces
the level of toxicity of Site contaminants, eliminates or reduces
their migration away from the Site, and/or reduces their volume
on a Site.
Alternative 5 may be long-term effective, but this is based on
literature. It would also meet the statutory preference for
treatment and permanent solutions. Alternative 4 (S/S) would be
long-term effective and would meet the statutory preference for
treatment.
Alternative 6 (Thermal Desorption with S/S (for the inorganic
soils)) would also be long-term effective and permanent and would
most satisfy the statutory preference for treatment, since both
the organic and inorganic (metals) contaminants would be treated.
Thermal treatment with on-site containment of the metals soils
may be less long-term permanent than S/S of the metals soil, and
would not satisfy the preference for treatment as well as
treating both the metals and organic soils. As described above,
a combination of Alternatives 4 and 3B, may be more long-term
effective and permanent than either alternative alone.
Alternative 7 (Off-site disposal) would be long-term effective
and permanent in that the contaminated soil would be removed from
the site. Also, approved off-site disposal facilities are
typically secured, have personnel onsite to prevent trespassing,
are currently regulated, and already conduct monitoring. This
alternative may also partially satisfy the preference for
treatment if the off-site facility solidifies the soil prior to
placement into the landfill.
Balancing criteria also include implementability and short-term
risks. The alternative with the greatest implementability
difficulties and highest short term risk would be Alternative 6,
Thermal Desorption, due to the saturated clayey soils and the
complexity of the treatment unit. Alternative 4 (S/S) may have
some implementability difficulties for the same reasons, and also
may have a slightly higher short term risk than Alternatives 3 to
3B (Containment) , as well as Alternative 7 (Off-site disposal) ,
since no treatment is involved in the alternatives. Alternative
5 (In-situ thermal treatment) would not pose as much of a short
term risk as Alternatives 4 (S/S) and 6 (Ex-situ thermal) but
more than 3 to 3B (Containment) and 7 (Off-site disposal) . There
would, however, be implementability difficulties due to the
saturated clayey soils.
Cost, and cost-effectiveness, is a factor to be considered. The
least expensive alternatives (besides 1 and 2) are 3 ($7.7
million) and 3A ($9.0 million). The costs of Alternatives 3B, 4,
5, and 7 are very similar, approximately $11 to 12 million. The
cost of Alternative 4 could increase above this amount if special
additives are needed to treat the VOCs in the soil (up to
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approximately $20 million). Alternative 6 costs significantly
more than all the other alternatives, up to approximately $27
million.
A combination of Alternatives 3B and 4 provides a more cost-
effective and protective alternative than each of the
alternatives alone, since the soils are aggressively treated with
S/S and aeration, though not necessarily with high cost additives
such as organoclays or proprietary mixtures. In this case, those
soils that continue to leach above MCLs (but below RCRA hazardous
levels) , could be placed into a RCRA Subtitle D landfill to
prevent leaching of contaminants to groundwater. RCRA hazardous
soils would be disposed off-site.
8.1.3 Modifying Criteria
1. State acceptance: The State of South Carolina concurs with
the soil remedy, though not with the future use industrial RG for
lead. A copy of South Carolina's 'letter of concurrence is
attached as Appendix B to this ROD.
2. Community acceptance; Local officials have stated at the
two public meetings that they would prefer that the contaminated
soils be taken off-site because their long range vision may
include the possible conversion of the property to athletic
fields, if they can find a way to fund the raising of the on-site
building. However, they have also indicated less concern about
how the area of the site that is near the rear of the building,
where the wastewater lagoons and solids ponds are located, is
used. This is the area that EPA envisions the contaminated soils
will be placed after treatment. In addition, the remedy also
allows for the material to be taken off-site, if it is determined
to be more cost effective. Verbal comments were received at the
Shuron Site Proposed Plan public meeting, held on December 9,
1997 and the second public meeting held on January 22, 1998. The
public comment period opened on December 5, 1997 and closed on
February 4, 1998 (after a thirty (30) day extension) . Written
comments received concerning the Site, and those comments
expressed at the public meeting, are addressed in the
Responsiveness Summary attached as Appendix A to this ROD.
8.2 Groundwater Remediation Alternatives
8.2.1 Threshold Criteria
Groundwater Alternatives 1 (No Action) and 2 (Limited Action) do
not meet the threshold criteria of protecting human health and
the environment and meeting ARARs. Alternative 4 (Groundwater
Extraction and Treatment at the source area) will meet this
criteria for most of the contaminated groundwater, but may not
meet it for the portion of the contaminated groundwater that may
be located beyond the extraction system, and therefore, not
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addressed by active remediation. The other two alternatives,
Alternative 3 (Source Removal with Temporary Groundwater
Extraction for Dewatering, Data Collection/Aquifer Evaluation,
Active Groundwater Treatment of all remaining (after dewatering)
contaminated groundwater, and if applicable, Monitored Natural
Attenuation), and Alternative 5 (Groundwater Extraction and
Treatment near the property boundary) are expected to meet the
two (2) threshold criteria of being protective of human health
and the environment and meeting ARARs.
8.2.2 Primary Balancing Criteria
Alternative 1, No Action, and Alternative 2, Limited Action will
not provide long term effectiveness, since no treatment is
performed. Alternative 4 (Groundwater Extraction and Treatment
at the source area) will be long-term effective and permanent for
most of the contaminated groundwater, but may not meet this
criteria for the portion of the contaminated groundwater that has
already migrated past the extraction system. The other two (2)
alternatives, Alternative 3 (Source Removal with Temporary
Groundwater Extraction for Dewatering, Data Collection/Aquifer
Evaluation, Active Groundwater Treatment of all remaining (after
dewatering) contaminated groundwater, and if applicable,
Monitored Natural Attenuation), and Alternative 5 (Groundwater
Extraction and Treatment near the property boundary) are expected
to be long-term effective and permanent.
The Superfund Amendments and Reauthorization Act of 1986 (SARA)
requirements favor active remediation of contaminated
groundwater. Alternatives 1 and 2 involve no treatment, or
limited treatment. Therefore, these alternatives do not satisfy
the statutory preference for selecting remedial actions that
employ treatment technologies that permanently and significantly
reduce the toxicity, mobility, or volume of the contaminants.
Alternatives 3, 4, & 5 meet the criteria of reducing the
toxicity, mobility, and volume of contamination through
treatment. Alternatives 3 and 5 will treat more of the
contaminated groundwater since all of the groundwater would be
treated.
Alternatives 1 & 2, No Action and Limited Action, afford the
greatest level of short-term protection because they present the
least risk to remedial workers, the community, and the
environment, as these alternatives do not involve a remedial
action or only a limited one during the source removal. The
other Alternatives, numbers 3, 4 & 5, could release minimal
volatile emissions during construction of the extraction system
installation and/or treatment system construction. Standard
construction management techniques would address any potential
short-term fugitive emissions.
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Alternatives I (No Action) and 2 (Limited Action) would be the
easiest to implement. The construction technologies required to
implement Alternatives 3, 4, & 5, are well established and very
reliable. The extraction and treatment systems would have
additional operational requirements compared to Alternatives 1
and 2, because of the complexities of the continuous operation of
a groundwater extraction system, the operation of a multi-
component treatment system, and requisite discharge limits on the
resulting treated effluent. The technical implementability of
all the evaluated alternatives is reasonable. Technologies
required to implement the alternatives are readily available and
proven at full-scale in similar field efforts. Discharge
permits, or at least the criteria, may need to be obtained or
met, for the implementation of Alternatives 3-5, since they
include an on-site treatment system which may discharge to the
unnamed stream or into the groundwater.
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. Alternative l has
no capital costs since it is considered completed. Alternative 2
is lower in cost than Alternatives 3 and 4, since it involves
only the costs of dewatering during the source removal and of
monitoring the groundwater, and implementing deed and well
restrictions. Alternatives 4 and 5 are similar in costs, about
$4.7 million. Alternative 3 may cost less if natural
attenuation (MNA) is approved for use by EPA on appropriate
portions of the plume. This will require a demonstration during
RD/RA, to EPA's satisfaction, that MNA is occurring and can be
relied upon to effect treatment as effectively and within a
similar time frame as active treatment.
8.2.3 Modifying Criteria
1. State acceptance: The State of South Carolina concurs with
this remedy. A copy of South Carolina's letter of concurrence is
attached (Appendix B) to this ROD.
2. Community acceptance was indicated by the verbal comments
received at the Shuron Site Proposed Plan public meeting, held on
December 9, 1997. The public comment period opened on December
5, and closed on February 4, 1998 (after a thirty (30) day
extension). Written comments received concerning the Site, and
those comments expressed at the public meeting, are addressed in
the Responsiveness Summary attached as Appendix A to this ROD.
9.0 THE SELECTED REMEDY
Based upon consideration of the requirements of CERCLA, the NCP,
the detailed analysis of alternatives and public and state
comments, EPA has selected a remedy that addresses soil and
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groundwater contamination at this Site. At the completion of
this remedy, the risk remaining at this Site will be within EPA's
acceptable risk range of 1 x 10"4 to 1 x 10~6, which is considered
protective of human health and the environment.
The selected remedy for this Site is:
Soil Remediation: Alternatives 3B & 4: Off-site
disposal of RCRA hazardous waste and for RCRA non-
hazardous waste - S/S and placement into an on-site
RCRA Subtitle D landfill (if contaminants leach above
drinking water standards after S/S and under an
engineered cover if soils do not leach above drinking
water standards); Off-site disposal, if it is
determined to be more cost-effective for all or some of
the RCRA non-hazardous soils.
Groundwater Remediation: Alternative 3: Source Removal
with Temporary Groundwater Extraction for Dewatering,
Data Collection/ Aquifer Evaluation, Active Groundwater
Treatment of contaminated groundwater, and if
applicable, Monitored Natural Attenuation.
The estimated total present worth cost of the soil remedy is
$11 - 15 million and the estimated total present worth cost for
the groundwater remedy is $ 2.4 - 5.0 million.
9.1 Soil Remediation
A general description of this cleanup option follows, while a
more detailed description is presented below in Section 9.1.1.
Combination of Soil Alternatives 3B and 4; All soils, surface and
subsurface soils and sediments, including the uplands and
wetlands, exceeding their respective RGs, shall be excavated,
except for approximately 13 acres in the Eastern Wetlands. The
excavated/disturbed wetlands shall then be restored.
After this, whatever soils are determined to be RCRA hazardous
waste (unless treatment as described below renders the soils as
RCRA non-hazardous), shall be disposed off-site at an acceptable
hazardous waste facility.
All soils that are designated as RCRA non-hazardous (including
those so designated after treatment) , may remain on-site. Soils
that remain on-site will be aggressively treated using S/S and
aeration to reduce the contaminant concentrations, such that the
contaminants do not leach out of the soils above drinking water
standards. Pilot-scale treatability testing will be conducted
during RD/RA to determine the most effective reagent mixture to
prevent leaching of contaminants above drinking water standards.
If, after aggressive treatment, the RCRA non-hazardous waste
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continues to leach above MCLs, the waste will be disposed of in
an on-site RCRA Subtitle D landfill. Soils not leaching above
MCLs, would not require placement in an on-site RCRA Subtitle D
landfill, but will be placed under an engineered cap to prevent
direct contact exposure.
If it is determined during RD/RA, that it would be more cost
effective to take soils that leach above MCLs off-site, then
Alternative 7 (Off-Site Disposal) may be implemented versus a
combination of Alternatives 3B and 4.
9.1.1 Description
All contaminated soils, surface and subsurface soils and
sediments, including uplands and wetlands, which exceed the RGs
listed in Table 2, shall be excavated, except for some sediments
in the eastern wetlands (approximately 13 acres). The upland
surface soils shall be excavated to the RG levels for a future
industrial worker. The surface and subsurface soils in the
upland areas and the wetland areas, shall be excavated to the RG
levels.for the protection of groundwater, and the wetland
sediments shall also be excavated to the RG levels for the
protection of ecological receptors. The excavated/disturbed
wetlands will then be restorated. These areas include: the
upland soils, which may possibly include soils outside the fence
east of the two Solid Ponds but west of the wetlands boundary (as
depicted on Figure 3 but only after confirmational sampling), the
Northern Drainage Ditch (as depicted on Figure 3) , and the
Southern Wetlands, including the South Ditch and the southeast
corner (beginning at the corner of the most southern fence line
and continuing southeasterly to the South Ditch area).
All soils that are designated as RCRA hazardous waste will be
disposed of off-site at an acceptable hazardous waste facility,
unless treatment as described below, causes the waste to no
longer be considered RCRA Hazardous. This soil may remain
onsite, if it meets the Land Disposal Restriction Standards.
RCRA designation will be determined from RCRA TCLP tests.
Soils which would be designated as RCRA non-hazardous, may remain
on-site. If the soils remain on-site, they will be aggressively
treated by aeration and S/S such that the contaminants do not
leach from the soils above MCLs or the action level for lead
(drinking water standards). The term stabilization refers to the
technology where a chemical agent, typically self-cementing
(pozzolanic), is added to a waste to reduce the hazard potential
of that waste; solidification refers to processes that convert
solid wastes to a solid form (monolith), typically binding
contaminants mechanically in the solid matrix. Given the present
knowledge of the soil characteristics, type and depth of
contamination, it is expected that ex-situ S/S will be the most
appropriate method for treating contaminated soils at the Shuron
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Site to prevent leaching of contaminants into the groundwater
above drinking water standards. The most effective S/S reagent
mixture at preventing the leaching of contaminants to groundwater
above the federal and state drinking water standards, will be
determined from pilot-scale treatability studies conducted during
RD.
Following treatment, soils that do not leach above drinking water
standards, will be placed under an engineered cap to prevent
direct contact exposure. However, these soils that do not leach
above drinking water standards, could be placed into the Subtitle
D landfill if it is more cost-effective than constructing a
separate engineered cap. Those soils which continue to leach
above drinking water standards after aggressive treatment (this
is expected to be only soils with VOC contamination) , will be
disposed of in a RCRA Subtitle D landfill to be constructed on-
site. In order to be placed into the RCRA Subtitle D landfill,
the soils will have to comply with LDR requirements.
The design and construction of the Subtitle D landfill would
include components such as a low permeability cap, a bottomliner
and a leachate collection system. Clean soil will be added to
bring the bottom of the landfill to at least three feet above the
seasonably high water table. The initial soil lifts will be of
treated metal contaminated soils, and the upper lifts will be of
treated mixed VOC and metals soils.
Those soils to be excavated that are wet, would be transported to
a construction pad with controlled drainage (collection and
treatment) and mixed with drying agents such as quicklime, if
necessary, to absorb excess moisture and improve their physical
and load bearing characteristics. Since the soils will be
treated with S/S reagents, the drying agent prior to treatment,
as described for the other alternatives, may not be necessary.
In addition, all soils containing VOCs, will also be aggressively
treated by aeration to release the VOCs during the mixing process
with the reagent, as well as from materials handling processes.
During Remedial Design, laboratory treatability testing and field
pilot studies will be conducted for the following purposes:
(1) determining the most effective reagent mixture and (2) to
gather volatilization data to predict emissions during full scale
soil excavation and modification activities to ensure that State
and Federal air emission standards are not being exceeded. In
addition, the amount of contaminants that remain in the soils
after treatment will be determined in order to determine whether
the soils may remain on-site or whether they would need to be
disposed off-site at an appropriate hazardous waste facility.
Treatment effectiveness would be evaluated using tests such as
RCRA TCLP test procedures (to determine RCRA Hazardous) and
modified TCLP testing using site background groundwater to
determine if drinking water standards are met. Leachate tests
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will include testing of treated material that has cured for 28
days. Other tests may also be utilized for determining if
drinking water standards are being met (such as the ASTM water
leach test or EPA 1312 test), if EPA determines that these tests
would more accurately portray site conditions. The leachate
results will then be compared to drinking water standards.
Treated areas will be isolated and restricted to prevent exposure
by trespassers and potential future workers. This will include
utilizing fencing with signs placed at regular intervals.
The footprint of the landfill and any areas which have treated
soils (soil that does not need to be placed in the landfill since
contaminants do not leach from the soil above drinking water
standards), will be large enough to limit the height of the
landfill (or area of treated soils) as much as possible, but not
to exceed ten feet high above the current land surface, such that
it is not a visible eyesore or impediment.
During excavation and treatment, air emissions/odors shall be
monitored on-site and at the property boundary. If there are
complaints from the nearby residents concerning emissions/odors,
they shall be suppressed or, if suppression is not effective,
collected. If health based levels or State/Federal regulatory
levels are exceeded, then the emissions shall be collected.
If it is determined during RD or RA, that it would be more cost
effective to take all or some portion of the RCRA non-hazardous
soils off-site for disposal, then Alternative 7 (Off-Site
Disposal) may be implemented versus a combination of Alternatives
3B and 4.
Three VOC contaminants; ethyl benzene, toluene, and xylenes
(total), bis-2-ethylhexyl phthalate, and lead, may have their RGs
reevaluated, if determined necessary by EPA for the protection of
groundwater, during RD/RA. If so, these numbers shall be
established using the RCRA TCLP test and/or a modified TCLP test
using site background groundwater, consistent with the methods
employed during the RI/FS.
In addition, institutional controls would be implemented and a
fence would be constructed around the area with the treated soils
and the landfill. The institutional controls would also include
a deed or other restriction limiting uses and activities of those
portions of the property in which soils exceeding RGs have been
left in place as well as the areas of treated soils. The deed
restriction would serve as notification to potential purchasers
or developers of the property that land use is restricted in
these areas and the location of the untreated soils. Fencing
commonly used to limit access is 6 or 8-foot high chain-link;
barbed wire would be strung along a top brace as an additional
deterrent to trespassers. Signs would be posted at regular
intervals, warning the trespasser of the potential danger.
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Routine inspection is required to maintain the fence, the
landfill, and the cap areas.
9.1.2 Applicable or Relevant and Appropriate Requirements
(ARARs)
Applicable Requirements. Soil remediation shall comply with all
applicable portions of the following Federal and State of South
Carolina regulations:
49 CFR Parts 107, 171-179, promulgated under the authority of the
Hazardous Materials Transportation Act. Regulates the labeling,
packaging, placarding, and transport of hazardous materials
offsite.
40 CFR Parts 258, 261, 262.11, 262 (Subparts A-D), 263, 264, and
268, promulgated under the authority of the Resource Conservation
and Recovery Act. These regulations govern the identification,
transportation, manifestation, and land disposal requirements of
solid and hazardous wastes. If the contaminated soils fail TCLP,
the land disposal restrictions in 40 CFR Part 268 will apply.
However, if TCLP toxicity tests are performed and the
contaminated soils do not exceed TCLP toxicity limits, then the
land disposal restrictions in 40 CFR Part 268 will not apply. 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.
40 CFR 6 Appendix A (Protection of Floodplains) , 16 USC et seq.
(Fish and Wildlife Coordination Act) 40 CFR 6.302. Requirements
to be met by remedial actions that occur in a floodplain.
16 USC 1271 et. seq. (Fish and Wildlife Coordination Act) .
Requirements for measures to be taken to prevent, mitigate, or
compensate for losses of fish and wildlife resources.
Clean Water Act Section 404; 40 CFR 230, 33 CFR 320-330. 40 CFR
6, Appendix A. Requirements for actions taken in a wetlands.
U.S Army Corps of Engineers define wetlands and issue permits.
SCHWMR 61-79.124, .261, .262, .263, .264, .266 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.
South Carolina Non-Hazardous Waste Management Regulations, South
Carolina Code of Regulations (Chapter 61.61) . Regulations
require capping of non-hazardous, land disposal units.
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South Carolina Solid Waste Policy and Management Act of 1991;
South Carolina Code of Laws, Title 44. Applies to treatment
residuals that are not classified as hazardous waste.
Relevant and Appropriate Recruirements. The following regulations
are "relevant and appropriate" to source control actions (soil
remediation) at the Shuron Site. Applicability of these air
quality control regulations is due to the potential for release
of harmful particulates (metals) or VOCs during soil excavation
and handling activities.
40 CFR Parts 60, 61, and 70, promulgated under the authority of
the Clean Air Act. Included are the National Emissions Standards
for Hazardous Air Pollutants (NESHAPs). Ambient air quality
standards and standards for emissions to the atmosphere fall
under these regulations.
SC Reg. 61-62, South Carolina Air Pollution Control Regulations
and Standards, promulgated pursuant to the S.C. Pollution Control
Act, SC Code of Laws, 1976, as amended. Establishes limits for
emissions of hazardous air pollutants and particulate matter, and
establishes acceptable ambient air quality standards within South
Carolina.
29 CFR 1910 and 1926: OSHA Health and Safety Requirements.
Applies to all workers engaged in Remedial Activities.
40 CFR 264: RCRA regulations for the handling and placement of
hazardous waste.
"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.
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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
Shuron Site contaminants in surface or subsurface soils.
The protective levels for surface soils and sediments were
established for contaminants, based on the Baseline Risk
Assessment calculations, and toxicity studies. These RGs are
listed on Table 2. The protective level for lead (Pb) is 400
mg/kg for a future residential scenario and 1150 mg/kg for a
future industrial scenario for surface soils. These RGs are
designated TBC.
Subsurface soil protective levels (RGs) for the contaminants
listed on table 2 were based on the results of leaching tests
using Site-specific samples, conducted during the RI. The
contaminants listed in Table 2 show those contaminants in the
subsurface soil samples which violated drinking water standards;
and therefore, had RGs established. These RGs are TBC.
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
standards defining successful implementation of the remedy. The
soil remediation goals in Table 2 below, shall be the performance
standards for soil excavation. The future industrial RGs apply
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to the uplands surface soils; protection of groundwater RGs apply
to both uplands and wetlands surface soils, subsurface soils, and
sediments; and ecological RGs apply to wetland sediments.
Whatever soils are determined to be RCRA hazardous waste (unless
treatment renders the soils as RCRA non-hazardous), shall be
disposed off-site at an acceptable hazardous waste facility. All
soils allowed to remain on-site shall be treated such that the
soils do not leach contaminants above drinking water standards.
Following treatment, soils that do not leach above drinking water
standards, will be placed under an engineered cap to prevent
direct contact exposure. Those soils which continue to leach
above drinking water standards (this is expected to be only soils
with VOC contamination), will be disposed of in a RCRA Subtitle D
landfill to be constructed on-site. Soils placed into the RCRA
Subtitle D landfill shall comply with LDR requirements.
The levels of contamination detected in the leachate from the
RCRA TCLP test that would render a waste as RCRA Hazardous by
characteristic are as follows: lead greater than or equal to
5.0 ppm, TCE greater than or equal to 0.5 ppm, PCE greater than
or equal to 0.7 ppm. For soils that have mixed metals and VOC
contaminants, the concentration of lead in the the leachate would
have to meet the Universal Treatment Standard of 0.75 ppm or
below, since it be would an underlying hazardous constituent.
9.1.4 Monitoring
Additional soil samples will be collected from around the
wastewater lagoons and solids ponds and other uplands areas, and
additional surface and subsurface soil samples and sediment and
surface water samples, will be collected from the southern
wetlands and southeast corner to further characterize the extent
of contamination.
Real-time air monitoring will be conducted in several places
along the property boundary, especially in the direction of
nearby residents. In addition, air monitoring shall be conducted
for determining if air standards are being met and for protection
of workers.
9.2 Groundwater Remediation
A general description of this cleanup option follows, while a
more detailed description is presented below in Section 9.2.1.
This remedy consists of groundwater treatment using either; pump
& treat, air-sparging (trenches and/or wells), recirculation
wells or a combination, followed by discharge to Turkey Creek,
POTW, or reinjection (for extracted groundwater). If it is shown
during the evaluation period that natural attenuation is
occurring, and would remediate the contaminated groundwater
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within a similar time frame as active remediation, then this may
be implemented for the appropriate portions of the plume. The
following subsections describe this remedy component in detail,
provide the criteria (ARARs and TBC material) which shall apply,
and establish the performance standards for implementation.
9.2.1 Description
This remedy component consists of the design, construction and
operation of a groundwater treatment system throughout the
groundwater contaminant plume, and development and implementation
of a Site monitoring plan to monitor the system's performance.
The groundwater alternative specified below shall be continued
until the performance standards listed in Section 9.2.3. are
achieved continuously, at a minimum, in all of the existing and
new monitoring and extraction wells, that are or will be
associated with the Site.
Some of the contaminated soils to be excavated during the source
removal (as described in Soil Alternative 3B) will be below the
water table so that those areas will need to be dewatered during
excavation. A temporary groundwater recovery and treatment
system will be used for dewatering purposes during the source
removal. For this alternative, the system will be operated for
an additional four to six months after completion of the
excavation of the contaminated soil.
An evaluation period for gathering data to design a proactive
groundwater treatment system (pump and treat, recirculation
wells, air-sparging (trenches and/or wells), or a combination) to
achieve RGs throughout the entire groundwater plume, will be
conducted before, during and after the excavation of the
contaminated soil. This would most likely require that some of
the aquifer characteristic data be collected outside the areas of
the soil excavation (undisturbed areas) that would more
accurately portray conditions for the entire groundwater plume.
This should especially include those areas outside the source
removal areas that have shown higher concentrations of
groundwater contamination that most likely would be the target of
groundwater remediation.
During the evaluation period, if monitored natural attenuation
(MNA) can be demonstrated (in accordance with EPA's guidance
documents), to be as effective as active remediation (i.e. it is
occurring, and within a similar time frame as active
remediation), then this approach may be applied to the
appropriate portions of the contaminated groundwater plume. The
more aggressively the groundwater dewatering system is applied
both within the excavation areas and the adjacent impacted
groundwater areas during the evaluation period, the more
contaminant mass would be removed, thus providing additional
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argument for the applicability of MNA. If this occurs, a ROD
Amendment or BSD will be performed, if determined necessary by
EPA or SCDHEC. This evaluation period will be completed within
six months of the shutdown of the temporary dewatering system.
This will be followed by construction and operation of the
groundwater system.
In addition to the process described above, this alternative will
include implementation of all of the institutional controls and
contaminant monitoring requirements described below, thereby
monitoring the effectiveness of the alternative and limiting
future use of groundwater until clean-up goals are achieved.
Institutional controls that would apply to the Site, include deed
restrictions and well permit restrictions. Deed restrictions
would prevent the future use of the contaminated groundwater for
purposes such as potable water supply or irrigation of edible
garden vegetables. These restrictions will be written into the
property deeds to inform future property owners of the
possibility of contaminated groundwater beneath the property.
Permit restrictions, issued by the State of South Carolina, would
restrict all well drilling permits issued for new wells on the
Site property that may draw water from the contaminated
groundwater for potable water use or irrigation of edible
vegetables.
Monitoring of contaminants of concern and their degradation
contaminants, not including their innocuous compounds, would be
included as part of this alternative, at a minimum. EPA may
require additional contaminants, including all TCL/TAL
parameters, to be analyzed. Monitoring of the contaminants would
involve the collection and analysis at regular intervals, of
groundwater samples from existing and new Site monitoring wells
and, extraction wells (if installed), and surface water samples,
to allow tracking of contaminant concentrations and to monitor
the speed, direction, and extent of contaminant migration. The
actual number and location of well and surface water samples, and
any additional contaminants to be analyzed for, will be
determined during the remedial design/remedial action phases.
Samples will be collected and analyzed for contaminants of
concern and their degradation contaminants, at a minimum,
however, of once every year, when the highest contamination is
detected, unless a different frequency or time of the year is
required by EPA. Surface water samples, from the wetlands as
well as the drainage ditches, will be collected during the months
when the wetlands are the most wet (around March), unless EPA
designates another time of the year. In addition, the need for
any additional monitoring wells, which may be sampled for
additional contaminants, will be determined during the remedial
design/remedial action phases. These wells may be added if it is
determined later that, further characterization of the Site is
needed, there is data gaps, that groundwater contamination has
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left the Site property, or that contamination is significantly
above the clean-up criteria in the outer monitoring wells. It is
anticipated that additional monitoring wells will be required to
be installed between Solid Lagoon 2 and the railroad bed for
further plume delineation, as well as the replacement of those
wells that are abandoned during the excavation of the
contaminated soils.
The vertical extent of groundwater contamination will be
confirmed and/or updated during the remedial design. This may
require that additional monitoring wells, screened at various
depths, be installed. This will be determined by EPA during the
remedial design/remedial action phases. The goal of this
remedial action is to restore groundwater to its beneficial use
as a drinking water source. Based on the information collected
during the RI, and on a careful analysis of all remedial
alternatives, EPA and the State of South Carolina believe that
the selected groundwater remedy, Alternative 3, will achieve this
goal.
If it is determined, on the basis of the preceding criteria and
the system performance data (after all attempts have been made as
determined by EPA), that certain portions of the aquifer cannot
be restored to their beneficial use, all or some of the following
measures involving long-term management may occur, for an
indefinite period of time, as a modification of the existing
system:
* engineering controls which will provide containment
measures;
* chemical-specific ARARs will be waived for the cleanup
of those portions of the aquifer based on the technical
impracticability of achieving further contaminant
reduction;
* institutional controls will be provided/maintained to
restrict access to those portions of the aquifer that
remain above remediation goals;
* continued monitoring of specified well locations; and
* periodic re-evaluation of remedial technologies for
groundwater restoration.
The decision to invoke any or all of these measures may be made
during a review of the remedial action, which will occur at least
every five (5) years, in accordance with Section 121 (c) of
CERCLA, 42 U.S.C. § 9621(c).
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9.2.2 Applicable or Relevant and Appropriate Requirements
(ARARs)
Applicable Requirements. Groundwater remediation shall comply
with all applicable portions of the following Federal and State
of South Carolina regulations: SC Reg. 61-68, South Carolina
Water Classifications and Standards. These regulations establish
classifications for water use, and set numerical standards for
protecting state waters.
SC Reg. 61-71, South Carolina Well Standards and Regulations,
promulgated under the Safe Drinking Water Act, SC Code of Laws,
1976, as amended. Standards for well construction, location and
abandonment, are established for remedial work at environmental
or hazardous waste sites.
Relevant and Appropriate Requirements. The following regulations
are relevant to groundwater remediation at the Site.
40 C.F.R. Parts 141-143, National Primary and Secondary Drinking
Water Standards, promulgated under the authority of the Clean
Water Act. These regulations establish acceptable maximum levels
of numerous substances in public drinking water supplies, whether
publicly owned or from other sources such as groundwater.
Maximum Contaminant Levels (MCLs) are specifically identified in
40 C.F.R. § 300.430 (e) (2) (i) (B) of the NCP as a remedial action
objective for groundwater that is a current or potential source
of drinking water. Therefore, MCLs are relevant and appropriate
as criteria for groundwater remediation at this Site.
SC Reg. 61-58, South Carolina Primary Drinking Water Regulations,
promulgated pursuant to the Safe Drinking Water Act, SC Code of
Laws, 1976, as amended. These regulations are similar to the
federal regulations described above, and are relevant and
appropriate as remediation criteria for the same reasons set
forth above.
Criteria "To Be Considered" (TBC) and Other Guidance. TBC
criteria were utilized and/or established in the BRA and in the
FS. Groundwater cleanup standards were established based on
these documents and both are thus considered TBC.
In the Baseline Risk Assessment, TBC material used included
information concerning toxicity of, and exposure to. Site
contaminants. Sources of such data included the Integrated Risk
Information System (IRIS), Health Effects Assessment Summary
Tables (HEAST) , and EPA guidance as specified in the BRA.
Other TBC material include the following:
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Guidelines for Groundwater Use and Classification. EPA
Groundwater Protection Strategy. U.S. EPA, 1986. This document
outlines EPA's policy of considering a site's groundwater
classification in evaluating possible remedial response actions.
The groundwater at the Site is classified by EPA as Class IIB and
by South Carolina as Class GB groundwater, indicating its
potential as a source of drinking water.
Other requirements. As described above in Section 9.2.2,
remedial design often includes the discovery and use of
unforeseeable but necessary requirements. Therefore, during
design of the groundwater component of the selected remedy, EPA
may, through a formal ROD modification process such as an
Explanation of Significant Differences or a ROD Amendment, elect
to designate further ARARs which apply, or are relevant and
appropriate, to groundwater remediation at this Site.
9.2.3 Performance Standards
The standards outlined in this section comprise the performance
standards defining successful implementation of the remedy. The
groundwater remediation goals in Table 2 below shall be the
performance standards for groundwater treatment.
9.2.4 Monitoring
Monitoring of contaminants of concern and their degradation
contaminants, not including their innocuous compounds, will be
included as part of this alternative, at a minimum. EPA may
require additional contaminants, including all TCL/TAL
parameters, to be analyzed. Monitoring of the contaminants would
involve the collection and analysis at regular intervals, of
groundwater samples from existing and new Site monitoring wells
and extraction wells, and surface water samples, to allow
tracking of contaminant concentrations and to monitor the speed,
direction, and extent of contaminant migration. The actual
number and location of well and surface water samples, and any
additional contaminants to be analyzed for, will be determined
during the remedial design/remedial action phases
Samples will be collected and analyzed for contaminants of
concern and their degradation contaminants, at a minimum,
however, of once every year, when the highest contamination is
detected, unless a different frequency or time of the year is
required by EPA. Surface water samples, from the wetlands as
well as the drainage ditches, will be collected during the months
when the wetlands are the most wet (around March) , unless EPA
designates another time of the year. In addition, the need for
any additional monitoring wells, which may be sampled for
additional contaminants, will be determined during the remedial
design/remedial action phases. These wells may be added if it is
determined later, that further characterization of the Site is
54
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needed, that there are data gaps, that groundwater contamination
has left the Site property, or that contamination is
significantly above the clean-up criteria in the outer monitoring
wells. Currently EPA anticipates that this will include any
existing wells that are abandoned during the source removal, as
well as, several south of Solid Lagoon #2, in the Southern
Wetlands, between Solid Lagoon #2 and the southern drainage ditch
to better define the extent of the groundwater plume.
The vertical extent of groundwater contamination will be
confirmed and/or updated during the remedial design. This may
require that additional monitoring wells, screened at various
depths, be installed. This will be determined by EPA during the
remedial design/remedial action phases. The goal of this
remedial action is to restore groundwater to its beneficial use
as a drinking water source. Based on the information collected
during the RI, and on a careful analysis of all remedial
alternatives, EPA and the State of South Carolina believe that
the selected groundwater remedy, Alternative 3, will achieve this
goal.
For the purposes of the evaluation period and monitored natural
attenuation demonstration, the following shall be performed until
the evaluation period and MNA demonstration is complete: Obtain
baseline water level and analytical data for the natural
attenuation demonstration. Water level data will be obtained
from monitoring wells, the municipal well, and any wetland,
surface water or standing water at or near the site. This
baseline data shall be obtained prior to the source removal.
Quarterly analytical sampling and water level measurements shall
then continue after this time, from monitoring wells and surface
water locations, until after the evaluation period is completed;
when EPA accepts as final, the report for the evaluation period.
Monitoring well and surface water samples (including water level
measurements) shall be collected at the same time. The
groundwater samples from the monitoring wells shall also be
collected at that time. Also, monthly rainfall and temperature
data shall be obtained.
In addition, for the purpose of the natural attenuation
demonstration, the following parameters shall also be analyzed
for: Chlorides, ethene, methane, dissolved oxygen (DO), nitrate,
nitrite, iron(lll), iron(ll), sulfide, biological oxygen demand
(BOD), sulfate, oxidation reduction potential, and arsenic.
These parameters may be revised, if EPA determines that other or
less parameters are needed for the NA demonstration.
After the completion of the evaluation period, water level
measurements will be collected annually with the sampling of the
monitoring wells and the municipal well.
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EPA may require that samples be analyzed for all TAL/TCL
parameters, from all the monitoring and extraction wells (if
installed), the nearest municipal well, and the surface water,
for the five-year reviews.
When EPA believes that the remedial action is complete
(groundwater contamination is below RGs), EPA may require that
all the monitoring wells and extraction wells be sampled for all
TAL/TCL parameters, at a frequency to be determined by EPA.
Other Requirements
Due to the fact that VOCs were detected in the nearby municipal
well in the past, although they were very low levels, this well
shall be sampled annually, until EPA determines a less frequent
time frame, to ensure the contaminated groundwater does not pose
a risk to the well in the future. Drinking water sampling
techniques, as stated in EPA's SOP (Standard Operating
Procedures) Manual, shall be used for the municipal well
(detection limits for VOCs would be 1 part per billion).
9.3 Documentation of Changes
There was a change made to the selected remedy from the time the
Proposed Plan was released for public comment to the time of the
final selection of the remedy. The change involves revising the
universal treatment standard for lead. This change is due to
new LDR regulations (already an ARAR), finalized in the May 26,
1998 Federal Register. The new requirements changed the Universal
Treatment standard for lead to 0.75 ppm. For soils mixed with
VOCs and lead, the lead is an underlying hazardous constituent
and the maximum concentration that lead may leach at in order for
the contaminated soil to be disposed of into the on-site RCRA
Subtitle D landfill is now 0.75ppm (leachate). The previous
level stated in the Proposed plan of 0.370 ppm no longer applies.
Therefore, the ROD will reflect this revised criteria.
10.0 STATUTORY DETERMINATIONS
The selected remedy for this Site meets the statutory
requirements set forth at Section 121(b)(l) of CERCLA, 42 U.S.C.
§ 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 resource recovery technologies to the maximum
extent practicable; and finally, wherever feasible, employ
treatment to reduce the toxicity, mobility or volume of the
contaminants. The following sections discuss how the remedy
fulfills these requirements.
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Protection of human health and the environment; The groundwater
remediation alternative will remediate the contaminated
groundwater using pump & treat, air-sparging, or recirculation
wells (and, if applicable, natural attenuation for the
appropriate portions of the plume), thereby reducing and
eventually removing the future risks to human health which could
result from ingestion and inhalation of the groundwater. This
remedy would also reduce the potential risk to the environment.
The contaminated soil will be treated utilizing solidification/
stabilization and aeration. Only those soils that remain RCRA
hazardous would be taken off-site, and those soils that continue
to leach above drinking water standards will be placed into a
RCRA Subtitle D landfill on-site. However, if it is determined
to be more cost-effective during RD/RA, a portion or all of the
contaminated soils may be taken off-site. These soils may be
treated by the off-site facility.
Compliance with ARARs: The selected remedy will meet ARARs,
which are listed in Sections 9.1.2 and 9.2.2 of this ROD.
Cost effectiveness: Among the soil and groundwater alternatives
that are protective of human health and the environment and
comply with all ARARs, the selected alternatives are the most
cost-effective choices because they use treatment technology to
remediate the contamination in basically the shortest time frame,
at a cost similar to the other treatment alternatives.
Utilization of permanent solutions, and alternative treatment
technologies or resource recovery technologies to the maximum
extent practicable; The selected remedies represent 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 and groundwater
actions are more readily implementable than the other treatment
alternatives considered and the selected soil and groundwater
remediation alternatives will fulfill the preference for
treatment as a principal element.
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TABLE 2
REMEDIAL GOALS (RGs)
CONTAMINANTS OF CONCERN
Bis-2-ethylhexyl phthalate
1 ,2-Dichloroethane
1,2-Dichloroethene (Total)
Tetrachloroethene
Trichloroethene
Vinyl Chloride
Ethyl benzene
Toluene
Xylenes (Total)
Lead
'•:••:"::•:•'': ' . . -.:•:•:'.'•"""'•-
•:-..".': : . : . - •:•"•. ;: : :".'.." - '•
CONTAMINANTS OF CONCERN
Bis-2-ethylhexyl phthalate
1 ,2-Dichloroethane
1,2-Dichloroethene (Total)
Tetrachloroethene
Trichloroethene
Vinyl Chloride
Ethyl benzene
Toluene
Xylenes (Total)
Lead
GROUNDWATER (RGs) UG/L
6.0
5.0
70
5.0
5.0
2.0
700
1000
10,000
15*
RGs for Protection of
Groundwater. Soil concentrations
below which leaching above MCLs
is not expected to occur (mg/kg)
Not detected in TCLP leachate, but
detected in soil and groundwater
samples. May be determined in
RD/RA.
Not detected in TCLP leachate
1.5
0.1
0.09
0.74
62
136
1400
May be determined in RD/RA
MCLs
(ug/1)
6.0
5.0
70
5.0
5.0
2.0
700
1000
10,000
15*
Action Level
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TABLE 2 (con't)
REMEDIAL GOALS (RGs)
CONTAMINANTS OF CONCERN
Lead - Industrial
Arsenic
Beryllium
CPAH (BAP-TE)] (Polynuclear aromatic
hydrocarbons)
RGs FOR SURFACE SOILS
(ing/kg)
1150
34
12
5
ECOLOGICAL R6s BASED ON TOXICITY STUDIES
CONTAMINANTS OF CONCERN
Lead
Arsenic
Copper
Zinc
nig/kg
700
15
150
350
The RGs for the protection of groundwater for Ethyl benzene, Toluene, and Xylenes (Total), and
Bis-2-ethylhexyl phthalate, may be reevaluated during RD/RA since the calculated levels exceed
most of the levels detected in the soil samples, yet these contaminants were detected in the
groundwater. Lead may have an RG established for protection of groundwater, during RD/RA.
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APPENDIX A
RESPONSIVENESS SUMMARY
SHURON SUPERFUND SITE
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SHURON SUPERFUND SITE
1. Overview
The U. S. Environmental Protection Agency (EPA) held a public comment period from December
5, 1997 to January 5, 1998, for interested parties to comment on the remedial investigation/
feasibility study (RI/FS) results and the Proposed Plan for the Shuron Superfund Site located in
Bamwell, South Carolina. Upon receipt of a request, the comment period was extended an
additional thirty (30) days. The comment period closed on February 4, 1998.
EPA held several public meetings and an availability session. The availability session was held
prior to the start of the public comment period and occurred at 7:00 p.m. on November 22, 1997.
The first public meeting was at 7:00 p.m. on December 9, 1998, at the Barnwell County Council
Chambers in Barnwell, South Carolina, to present the results of the RI/FS and the Baseline Risk
Assessment, to present EPA's Proposed Plan, and to receive comments from the public. The
second public meeting was held on January 22, 1998 at the same time and place and again
presented the above information and solicited comments.
EPA proposed a soil and a groundwater remedy. The soil remedy consists of excavating all
contaminated soils exceeding RGS, followed by treatment of the soils and wetlands restoration.
These contaminated soils will be aerated and solidified/stabilized (S/S) to prevent the
contaminants in the soil from leaching above drinking water standards. If, after aggressive
treatment, the RCRA non-hazardous waste continues to leach above drinking water standards, it
will be disposed of in an on-site RCRA Subtitle D landfill. Soils that are designated as RCRA
hazardous waste, or if treated, remain RCRA hazardous, will be disposed of off-site at an
acceptable hazardous waste facility. Soils not leaching above MCLs, would not need to be placed
into a Subtitle D landfill, but if not, will be placed under an engineered cap to prevent direct
contact exposure. If it is determined during RD/RA, that it would be more cost effective to take
all or a portion of the soils that leach above MCLs off-site, then this alternative may be
implemented versus on-site treatment and construction of an on-site Subtitle D landfill.
The groundwater remedy consists of groundwater treatment using either; pump & treat, air-
sparging, recirculation wells or a combination, of all contaminated groundwater followed by
discharge to Turkey Creek, POTW, or remjection (for extracted groundwater). If it is shown
during the evaluation period that natural attenuation is occurring, and would remediate the
contaminated groundwater within a similar time frame, then this may be implemented for the
appropriate portions of the plume.
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:
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• Background of Community Involvement
• Summary of Comments Received During the Public
Comment Period and EPA's Responses;
• Attachment A: Proposed Plan for Shuron Superfund Site;
• Attachment B: Public Notices of Public Comment Period
& Extension of Public Comment Period;
• Attachment C: Written Public Comments Received During the Public Comment
Period;
• Attachment D: Official Transcript of the Proposed Plan Public Meeting and the
second public meeting.
2. Background of Community Involvement
EPA's community relations program for the Site began in February 1995, when EPA mailed out a
fact sheet and conducted community interviews, in order to develop a community relations plan
for the Site. At that time, residents living adjacent to the Site voiced concerns about loss of jobs
and revenue, and that they wanted the building to be used to bring jobs to the area or reopen the
old facility. The nearby residents commented on how they could walk to work in the past. Local
officials were concerned over lack of tax revenue generated by the plant and the unpaid back
taxes. Most residents and local officials were aware of the nearby municipal well and the local
officials were aware that contaminants had not been detected above drinking water levels in the
previous sampling events at that time. The residents EPA met with were informed of the results.
Local officials were concerned over the time it would take to investigate and cleanup the site.
One previous short term Shuron employee was concerned about asbestos that had been used
during operations.
Throughout EPA's involvement, the community has been kept aware and informed of Site
activities and findings. Local officials were briefed during the community interviews, and updated
as needed. EPA has responded to inquiries from the community and other interested parties.
3. Summary of Comments Received During the Public Comment
Period and Agency Responses
The Public Comment Period was opened on December 5, 1997, and ended on January 5, 1998.
Upon request, a thirty (30) day extension was granted, which extended the comment period to
February 4, 1998. Public notice announcements were published in local newspapers and copies of
the announcements are included as Attachment B.
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On December 9, 1997 EPA held a public meeting to present the Proposed Plan to the community
and to receive comments. Another meeting was held January 22, 1998. All comments received at
this public meetings and during the public comment period are summarized below.
Summary and Response to Local Community Concerns
The following issues and concerns were expressed at the Proposed Plan Public Meeting and the
second public meeting, and during the public comment period.
COMMENT: The cleanup number for lead in the uplands soils, for a future industrial scenario,
needs to be increased from 1150 ppm to 1500 ppm.
RESPONSE: The remedial level derived for the Shuron site is based on the assumption that a
pregnant women will work on-site, for 5 days/week, for a duration as short as 90 days (not
necessarily the whole pregnancy). While this scenario does not apply to the entire worker
population (not all workers are women and not all women workers are pregnant), the assumptions
are very reasonable for the woman who stays on the job for part or most of her pregnancy. EPA
feels strongly that this subgroup of the worker population should be protected.
COMMENT: The cleanup numbers for the organic contaminants detected in the subsurface soils
should not be determined at this point, but should be determined during Remedial Design/
Remedial Action after additional samples are collected.
RESPONSE: During the RI, numerous (approximately 50) samples were collected and analyzed
to determine the concentration of organic contaminants that could remain in the subsurface soils
and still be protective of groundwater. The data was then plotted on graphs and calculations
performed to determine what concentrations could remain while still protecting groundwater from
further contamination. Most of the contaminants showed good correlation between the total
concentration detected in the field and concentrations detected in the leachate. EPA does agree
that the cleanup goals for lead, as well as ethyl benzene, toluene, and xylene (total), may need to
be reevaluated during the RD/RA phase, because the numerical soil cleanup goals for the
organics, exceed most of the contaminant levels detected in the soil samples, yet these same
contaminants were detected in groundwater samples.
COMMENT: The area of wetlands stated in the Proposed Plan to be remediated, should not be
remediated because the benefits of wetland remediation are outweighed by the harm that would be
caused to the wetlands. Also, the cleanup number for lead is too low and should be increased
from 700 ppm to 2000 ppm, and should only be applied on a site-wide average basis.
RESPONSE: The areas designated for excavation of contaminated sediments (i.e., vicinity of the
North Drainage Ditch (NDD) and Southern wetlands) represent two of the most contaminated
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sediment areas. Removal of sediments in these source areas will decrease exposure of ecological
receptors to toxic contaminant levels and decrease the potential for further contaminant migration
through the wetlands and ditches. In addition, VOCs were also detected in the Southern Wetland
sediments and soils, which would continue to leach to groundwater above drinking water
standards. If these wetland areas were not remediated, they would continue to pose a risk to
both human health and the environment. Therefore, EPA has required remediation of these
areas. EPA also disagrees with the statement that the cleanup number for lead should be 2000
ppm and that the cleanup number should only be applied on a site-wide average basis . Through
toxicity testing of sediment-dwelling invertebrates, 700 mg/kg lead was found to be the
concentration at which 50% of the test population died. Higher concentrations resulted in greater
mortality. Sediment dwelling invertebrates are important components of the wetland ecosystem.
They are near the base of the food chain. Also, they are detrivores that feed upon organic matter,
thus helping to recycle nutrients. Since the sediment-dwelling invertebrates in the wetlands are
less mobile than higher animals (such as amphibians, mammals, and birds), the population as a
whole, would have more exposure to the large areas of contaminated wetlands. Therefore, it
would be inappropriate and not protective to apply the cleanup number on a site-wide average
basis.
In addition, elevated concentrations of arsenic, copper, and zinc were also found in areas with
elevated lead concentrations. Remediation of wetland areas based upon lead should also address
areas containing toxic levels of these other metals.
The wetland area east of the facility also contains high contaminant concentrations, much of it in
the NDD area. However, there are significant difficulties associated with excavating the
contaminated sediments out in the middle of the eastern wetlands because of accessibility issues
and because the area is significantly flooded for much of the year. Also, once the Northern
Drainage Ditch area is excavated, the highest concentration of contaminated sediments will have
been removed, thus eliminating the source of further contamination into the Eastern Wetlands.
Also, the sediments in the middle of the eastern wetlands, do not have organic contamination
leaching into the groundwater. Therefore, EPA is not requiring excavation of the contaminated
sediments in the eastern wetlands.
COMMENT: All excavated soils (RCRA hazardous and RCRA non-hazardous) should be
addressed by Soil Alternative 3 and not by the alternative stated in the Proposed Plan. [The
alternative recommended by EPA is a combination of alternatives 3B and 4; S/S and if necessary,
placement of soils in a Subtitle D landfill, if the contaminants continued to leach above MCLs.
Alternative 3, on the other hand, involves placing those soils that are excavated, directly on the
ground, three feet above the water table, with the metals contaminated soils as the initial lifts,
followed by lifts of mixed organic and metals soils, with an flexible membrane liner (FML) cover
layer. Some of the metals contaminated soils would not be excavated, but would be capped in
place]. Also, the commentor stated that it should not be a requirement that the hazardous waste
(as defined by RCRA) be disposed off-site. (RCRA is the primary federal law regulating the
handling, transport and disposal of hazardous wastes.)
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RESPONSE: Based on the information available to date, which indicates that (1) a large portion
of the soils are saturated clays contaminated with both organic and inorganic (metals)
contamination, and that (2) the water table is close to the land surface, EPA does not agree with
the commentor that Alternative 3, alone, would be protective of human health and the
environment. EPA does not accept, nor has it been demonstrated, that mixing the soils with
quicklime, prior to placement of the soils directly onto the ground, will prevent contaminants from
leaching to the groundwater above drinking water standards. Additionally, both EPA guidelines
and environmental-industry standards of environmental remediation call for prevention of further
leaching from source materials into groundwater; in other words, it is not acceptable to allow
leaching of additional contamination to already-contaminated groundwater.
However, since some portion of the contaminated soils will be able to be treated with S/S so that
they no longer leach contamination above drinking water standards (metals contaminated soils
especially), EPA will not require that these soils be placed into an onsite RCRA Subtitle D landfill
(as would normally be required), once it is demonstrated that the soils no longer leach above
drinking water standards. Allowing the hazardous waste to remain onsite would not comply with
RCRA ARARs, because under RCRA it is not considered protective to place hazardous waste
directly on the ground or even in a RCRA Subtitle D landfill. As with any CERCLA remedy, the
lead party or agency (in this case the PRP) is required to meet ARARs or obtain a waiver from
EPA. In this case, EPA does not believe it would be prudent to allow a waiver of this ARAR to
be less protective.
COMMENT: The proposed groundwater remedy should be modified to defer the decision on the
need for a proactive groundwater treatment system until after the implementation of the source
removal and completion of the groundwater evaluation period.
RESPONSE: Given the large amount of groundwater data collected during the RI/FS to date,
which indicate that some areas of the site have extremely high levels of contaminants in the
groundwater, an active remediation system of some kind will be required to address groundwater
contamination, as opposed to passive remediation only (monitored natural attenuation). EPA has
no basis to assume that the source removal component of the remedy will entirely remove and
eliminate the high contaminant levels in the groundwater; furthermore, EPA experience on other
sites' remedial actions argues against such an assumption. For this reason, EPA does not agree
that such a requirement is premature.
As the commentor notes, however, the source removal remedy component, which includes a
temporary dewatering system operating for an additional four to six months beyond the source
(soil) removal itself, should have a positive effect on the groundwater contamination. Therefore,
EPA has included in its remedy the requirement that an evaluation period be conducted to
determine the effectiveness of both the source removal and the effectiveness of monitored natural
attenuation (NA) to address contaminants in the groundwater. If it is determined to be effective,
then monitored NA could be applied to the appropriate portions of the plume.
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COMMENT: Local officials were concerned with the future use of the property stating that they
would like the future use to be recreational. They also were concerned with the building
remaining on the site and wanted it to be torn down. They did not believe a new company would
utilize the building in the future since it was not in the best of conditions. Also, the county has an
industrial park nearby that they would prefer to steer new companies towards. They also felt it
would be more appropriate to remove the contaminated soil off-site. Lastly, they wanted to know
if the city and/or county would be liable for costs of the cleanup.
RESPONSE: EPA is required to make a reasonable future use evaluation for the site. Presently
the site is not in use. There is a 185,000 square-foot building on the site, in fair condition, that
could be used for future industrial purposes. Discussions with nearby residents frequently elicited
questions such as "when is the plant going to reopen" or statements to the effect that "we would
like a company to open a new facility so that nearby local residents could be employed there." 1ft
addition, significant cost may be incurred for removing the building. Local sentiment from th£
nearby residents, appears to favor the facility remaining available for potential industrial use.
EPA does not have the authority to spend monies to tear down a building that does not pose aft
environmental risk or to make improvements to a property. Therefore, EPA believes that since
the building remains on site, and because of local sentiment, a future industrial use is the most
likely future use. However, EPA will continue to work closely with all stakeholders (i.e. local
government, nearby residents, PRP, etc) to implement the remedy in such a way as to facilitate the
pursuance of these expressed alternative uses of the property. EPA also has not precluded taking
the contaminated soil off-site if it is determined during the RD/RA phase that it would be more
cost-effective to do so. However, the Superfund program believes it is preferable to treat
materials at the site versus taking it off-site to someone else's "backyard". There is also the
possibility of future liability issues for the party that transports the waste to the off-site facilities.
In response to the local officials concerns of their incurring costs, EPA stated at the public
meeting that the law addressed owners, transporters, and operators that dealt with the generation
and disposal of waste. Therefore, if the city or county has not been involved in this capacity, they
would not be held liable.
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Attachment A
Proposed Plan for Shuron Superfund Site
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
SUPERFUND PROPOSED PLAN FACT SHEET
SHURON SUPERFUND SITE
Barnwell, Barnwell County, South Carolina November 1997
This fact cheat is one in a •cries designed to inform residents and local official* of the ongoing cleanup
efforts at the Site. A number of terms specific to the Superfund process (printed in italic* print are defined
in the glossary at the end of this publication.
INTRODUCTION
The United States Environmental Protection Agency (EPA) is proposing a cleanup plan, referred to as
the preferred alternative, to address contaminated surface and subsurface soils, and sediments (all are
combined together and referred to as soils), and groundwater at the Shuron Superfund Site (the Site)
located in Barnwell, Barnwell County, South Carolina. This document is being issued by EPA, the lead
agency for Site activities, and the South Carolina Department of Health and Environmental Control
(SCDHEC), the support agency. SCDHEC has reviewed EPA's preferred alternative and concurs with
EPA's recommendation.
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 of 1980, as amended by tlie Superfund Amendments and Reauthorization Act of 1986,
(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. EPA is
initiating a thirty (30) day public comment period from December 5,1997 to January 5,1998, to receive
comments on this Proposed Plan and the RI/FS Reports. EPA, in consultation with SCDHEC, will
PUBLIC MEETING
for the
SHURON SUPERFUND SITE
Tuesday, December 9,1997 - 7:00 PJVL
Barnwell County Council Chambers
Agricultural Building, 1603 Peckman
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select a remedy for the Site only after the public comment period has ended and all information
submitted to EPA during that time has been reviewed and considered. As outlined in Section 117(a) of
CERCLA, EPA encourages public participation by publishing Proposed Plans for addressing
contamination aFSuperfund sites, and by providing an opportunity for the public to comment on the
proposed remedial actions. As a result of such comments, EPA may modify or change its preferred
alternative before issuing a Record of Decision for the Site. This process is explained in more detail in
the Public Participation section of this document which begins on page 28. Contaminated surface soils,
subsurface soils, and sediments that exceed Remedial Goals, will be excavated, except for sediments in
the eastern wetlands (approximately 13 acres), followed by wetlands restoration. This will include the
areas seen on Figure 3, though further delineation will be conducted during Remedial Design/Remedial
Action (RD/RA), and will include; the four wastewater lagoons, two solid ponds, fill/debris area,
Northern Drainage Ditch and the Southern wetlands.
EPA's preferred alternative for the cleanup of these contaminated Site soils is a combination of_
Alternatives 3B and 4 (described below). This includes the following: Soils that cannot be treated to
below RCRA Hazardous waste characteristic levels, would be disposed of off-site at an acceptable
hazardous waste facility. Soils which are determined to be RCRA non-hazardous (before or after
treatment) could remain on-site. Soils that remain on-site would be aggressively treated by
solidification/stabilization (S/S) and aeration, to reduce the contaminant concentrations such that the
contaminants should not leach out of the soils above MCLs (drinking water standards). The exact
reagents to be used will be determined from laboratory and pilot scale treatability studies conducted
during RD to determine the most effective reagent mixture. If, after aggressive treatment, the RCRA
non-hazardous waste continues to leach above drinking water standards, (this is expected to be primarily
VOC contaminated soils), the waste will be disposed of in an on-site RCRA Subtitle D landfill. The
footprint of the landfill will be large enough to limit the height of the landfill as much as possible, but
not to exceed ten feet high above the current land surface, such that it is mostly hidden behind the on-site
building. Soils not leaching above MCLs, would not require placement in an on-site RCRA Subtitle D
landfill, but would be placed under an engineered cap to prevent direct contact exposure. If it is
determined during RD/RA, that it would be more cost effective to take soils that leach above MCLs off-
site, then Alternative 7 (Off-Site Disposal) may be implemented versus a combination of Alternatives 3B
and 4 (S/S and construction of an on-site RCRA Subtitle D landfill). During excavation and treatment,
air emissions shall be monitored on-site and at the property boundary, and if necessary, odors/emissions
shall be suppressed/collected.
The levels of contamination detected in the leachate from the RCRA TCLP test that would render a
waste as RCRA Hazardous are as follows: For the metals only soil, lead - 5 ppm. For soils that have
mixed metals and VOC contaminants, the total contaminant levels are: TCE - 6 ppm, PCE - 6 ppm, and
the leachate concentration for lead is 0.37 ppm.
EPA's preferred alternative for contaminated ground water is: temporary groundwater extraction for
the dewatering of soils during soil excavation, and for an additional time of between four and six months
after completion of the soil excavation, data collection/aquifer evaluation, followed by Active
Groundwater Treatment of remaining (after dewatering) contaminated groundwater (pump and treat,
recirculation wells, air-sparging or a combination). If applicable, Monitored Natural Attenuation may
be applied to the appropriate portions of the contaminated groundwater plume. If this occurs, a ROD
Amendment or ESD will be performed, if determined necessary by EPA or SCDHEC. This evaluation
period shall be completed within 6 months of the shutdown of the temporary system. This will be
followed by construction and operation of the groundwater system.
These alternatives (soil and groundwater) achieve the best balance of trade-offs among the criteria EPA
uses to evaluate remedial alternatives. The selection of a cleanup plan, or "preferred alternative,"
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represents a preliminary decision by EPA, subject to the public comment period. The preferred
alternative for the soils and groundwater, as well as the others considered, are summarized in this fact
sheet and presented more fully in the Feasibility Study (FS).
Scope and Role of this Action. The Site poses a potential future human health risk due to contaminants
in the surface and subsurface soils, sediments, surface water, and the groundwater. The site poses an
ecological risk due to contaminants in the sediments. EPA's plan for remediation of the Shuron Site will
address all threats posed by the contaminated soils and groundwater.
This fact sheet summarizes information that is explained in greater detail in the Remedial Investigation
(RI) Report, dated January 1997, which includes the Baseline Risk Assessment document, and the FS,
dated April 1997. These documents and all other records utilized by EPA to make the proposal specified
below 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
Bamwell Library or in the Record Center at EPA, Region IV's office in Atlanta, Georgia.
THIS PROPOSED PLAN:
1. Includes a brief history of the Site, the principle findings of the RI and a summary of the
Baseline Risk Assessment;
2. Presents the cleanup alternatives considered by EPA for the Site;
3. Outlines the criteria used by EPA to recommend the alternatives 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 Shuron Superfund Site.
SITE BACKGROUND
Site Description. The Shuron Site is located at 100 Clinton Street in Barnwell, Barnwell County, South
Carolina. Figure 1 presents a site location map. For this document, the entire 85-acre parcel will be
referred to as the Site. There is one main building (about 185,000 square feet) which is situated on an
approximate 34-acre parcel of land surrounded by a fence. Approximately one third of the 34-acre
facility is paved or occupied by the main plant building. The reminder of the property consists of
approximately 51 acres of mostly wetlands. The fence was partially extended to enclose a portion of the
51 acres in 1996. A removal action occurred inside the building under EPA's Emergency Response and
Removal Branch in 1994, in which the drums left inside the building were removed.
The Shuron Site is bounded by residential properties immediately northwest and north-northeast,
wetlands and then Turkey Creek to the east, wetlands and a railroad right-of-way to the south, and
Clinton Street to the west. The nearest known water supply well is the continuously operating City
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r iV^-i *TS
; SOURCE: USCS 7-1/2 UinuU Scries Mops:
Bomwctl. SC & Snclling. SC
Topographic OuodrongUs
Seal* in Maes
JS 1
^
Scale In KJomelera
FIGURE 1 .
Site Location
. . Shuron Site, Bamwell, South Carolina
CXUWN:
CHICDBY:
KEVB6O:
PfUXIECTNO:
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- 4
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of Barnwell, Well No. 10, located on the west side of Clinton Street approximately 375 feet west of the
southwest corner of the Shuron plant building. The first screen interval is 180 feet below land surface.
Site History. The former Shuron Site was constructed and placed into operation in 1958 as Shuron
Continental Optica^Company, a former division of Textron Inc. The facility manufactured single and
multi-vision ocular lenses until early 1992 (though the company was sold by Textron in 1985). The
manufacturing process involved grinding and shaping of lenses using primarily aluminum oxide and
garnet, followed by polishing, predominantly with oxides of iron, cerium, and zirconium. Wastewater
from the process was discharged to a series of four Wastewater Settling Lagoons immediately east of
the building, the sediment from which was periodically transferred to two Solids Lagoons located
immediately south of the Wastewater Settling Lagoons. Facility operations produced about 270,000
gallons per day (gpd) of wastewater containing the fine-grained grinding and polishing compounds,
which contained lead, solvents, and waste oils. It is believed that a solvent (tetrachloroethene) was used
to clean the lenses after the grinding and polishing process. EPA ranked the Site and included it on the
National Priorities List Proposed Update in the Federal Register, Rule No. 20, Vol.61, No. 117, on June
17,1996. The Site was added to the National Priorities List in the Federal Register, Rule No. 17, Vol. 61,
No. 247 on December 23 ,1996.
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 approximately 104
surface soil samples (some of which are referred to as hydric soils) were collected and analyzed for
various contaminants. Six of these samples were collected from background locations. Another 52
samples were analyzed for lead only. Twenty-six additional samples were analyzed for lead, chromium,
and nickel, and another 16 samples were analyzed for arsenic, copper, lead, silver, and zinc. Ten
samples were analyzed for the eight RCRA metals (arsenic, barium, cadmium, chromium, lead, mercury,
selenium, and silver). Seven of these samples were collected from background locations. A total of 103
subsurface soil samples were collected and analyzed for various parameters.
Groundwater samples from twenty-five wells were collected and analyzed for different compounds.
Twenty-seven sediment samples were collected from 25 locations and analyzed for various contaminants.
Surface water samples were collected from 34 locations and analyzed.
More detailed information can be found in the RI and FS reports, and in the Baseline Risk Assessment.
The sample results of the various media are summarized in Table 1.
Surface Soil Contamination. Six volatile organic compounds (VOCs), semivolatile organics (including
Polycyclic Aromatic Hydrocarbons (PAH's) and four metals were detected in the surface soils, which
in some cases are referred to as sediments/hydric soils. Because of direct contact exposure to humans
or the ecological system or because of the potential to leach to groundwater, these contaminants had
clean-up numbers derived for them.
Subsurface Soil Contamination. Seven VOCs,Bis(2-ethylhexyl)phthaIate, and four metals were detected
in the subsurface soil samples. Most of these contaminants have the potential to leach to drinking water
above MCLs (Maximum Contaminant Levels, drinking water standards) and therefore had groundwater
protection clean-up numbers developed for them, or during the Remedial Design phase.
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TABLE 1
SUMMARY OF RI RESULTS BY MEDIA
"** SUMM ^RY OF GROlfNDWATER RESULTS '-'''-
' * f '
CONTAMINANT
Vinyl chloride
1 ,2-dichloroetheoe
1,2-dichloroethane
Trichloroethene
Tetrachloroetbene
Toluene
Ethyl benzene
Xylenes (total)
Bis(2-ethylhexyl)phthalate
Lead
MAXIMUM
CONCENTRATIONS (ug/L)
3700J
47,000
2,600
61,000
52,000
2,400
20,000
93,000
610
124
MCL
2.0
5.0
70
5.0
5.0
1000
700
10,000
6.0
15*
'::S-^&ii?i!9
• '• .•'• '. .''. ::;:"':'::: -• '••'-•'•i-,-~--: ";-•.-:-:-. •:•:•'•:" -•••••;•;•••:': .-.':'x: x'':;;.-:: •:•:•.- '•.• •.-.-:': •• :. '-•••-:•.•::-.-:':-,". .- ;:";- - ::; •::::.::::":v:::v:'.:: ••• : i •:-••:•;- -'-.: ':':. . :' •: ': •••••• • : :.' • -.-' ••" •• • :: : ''-.-"• '•'•:••'. :•••: x--:'- •>:•;•". •:-•": :-:::-:-'':':"'-:-:::':::-:::->x::'.: ••-'•--.:•'•:•'•'•' :":••": : •••';•• '•'•"•'•- -•
-. - -. ' '•'•:•::• •:•.-.•: •••:•••: .- :•• '/;••-: ••••: :•••:•:••;: :•'- '•<•_'•. '•: :-'•'•"• •-•'•-.'; ;".-,"; '•'''• '•'•'• '••:' '••:• '•:•:-.'•. '.'• '• '•: ' '••'• '-.•:•'•: :"v-;;:v;! '*•••••'.•'< '• '•'••- '-'• ••'••'•:'• ".•".:'•'.••,-'.',•.'.-•... •••.•;• -.-••• ;"-r.v;':-::.- -•-•••;'-;'. •••'•••••'.-••• - '•<;••••'• - '•<.- '.-•-'• '.-•• :.'•'.'.'•• " . •
'"• • "•".'•".".'• '•'• "•• •:-•::-•..•••••--•-•• -.•:•;•.•-.-.--:•. ; . ;v.; .• ; ;.;..-••;••::;::.•-: /.;.•_;.-.•. ;,•.•;.-._;-.--.•. ••.--.-.;-';.••.•.;-....;..•...-...;:•-•--..... .. ;. . -. . : ;.. . -... .;-;.-.;•.•.;-.•->:•.: •'•:•:- ;•'::"•-•.. >i-x '•'•'.•:•.•: -•.:'-"•;.••: •-..•-. . • . .. .
CONTAMINANTS
1,2-dicbloroethene
Tricbloroetbene
Tetrachloroetbene
Toluene
Ethyl benzene
Xylenes (total)
Bis(2.etbylhexyl)phthalate
Lead
Arsenic
Copper
Zinc
MAXIMUM CONCENTRATIONS (rog/kg)
7.9J
0.85
4-2
0.18J
0.038J
OJ8J
230
14,600
136
741
5,170
* An MCL has not been established for lead. However, at levels above the Action Level, EPA will require
action to reduce lead content or reduce exposure to the affected water.
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TABLE 1 (CQD't)
SUMMARY OF RI RESULTS BY MEDIA
SUMMARY QF SUBSURFACE SOIL FESii-TS
%
CONTAMINANTS"
Vinyl chloride
1,2-dichloroethene
Trichloroethene
Tetracbloroethene
Toluene
Ethyl benzene
Xylenes (total)
Bis(2-eth} IhexyDphthalate
Lead
Arsenic
Copper
Zinc
MAXIMUM CONCENTRATION
(mg/kg)
9.1
460
1,100
2400J
60
1,400
3,700
110
17,400
117
400
7,910
MAXIMUM DEPTH (though
contamination may be deeper if
deepest sample to date still had
contamination) (feet)
2
75
S
7
5
10
14
10
7
7
7.5
7
Maximum concentration does not necessarily correspond to maximum depth.
J • estimated
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TABLE 1 (con't)
SUMMARY OF RI RESULTS BY MEDIA
, J^UMMARY OF SEDIMENT fbitch/ creek/ w*flandsl RESULTS
' - " ' ' -,- , ...••• ' '
CONTAMINANT
Vinyl chloride
1,2-dichloroethene
Toluene
Ethyl benzene
Xylenes (total)
Bis(2-etbylbexyl)phthalate
Lead
Arsenic
Copper
Zinc
MAXIMUM CONCENTRATIONS (rag/kg)
(U
0.41
2J
16
68
11
7,470
S7J
341J
2,080
SUMMARY OF SURFACE WATER RESULTS
CONTAMINANT
Vinyl chloride
1,2-dichloroethene
Trichloroethene
Tetrachloroethene
Toluene
Ethyl benzene
Xylenes (total)
Bis(2-etbylhexyl)phthalate
Lead
Arsenic
Copper
Zinc
MAXIMUM CONCENTRATIONS (ug/L)
(either lagoon (L) or wetlands (W))
52 (L)
1,400 (W)
10J (L)
15J (L)
51 (W)
17J (L)
360 (L)
953 (W)
343 (W)
5.6 (L)
116 (W)
1.770J (L)
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flroundwater Contamination. Eight VOCs, Bis(2-ethylhexyl)phthalate, and lead were detected in the
groundwater. Contaminant concentrations for all of the contaminants listed violate the Maximum
Contaminant Levels (MCLs), which are often referred to as "drinking water standards." Therefore,
Rgs for these contaminants were developed.
Surface Water Contamination. Seven VOCs, Bis(2-ethylhexyl)phthalate, and four metals were detected
in the surface water. Surface water contamination will be addressed by the remediation of the other
media.
Sediment Contamination. Five VOCs, Bis(2-ethylhexyl)phthalate, and four metals were detected in the
sediment samples. Groundwater protection clean-up numbers were developed for some contaminants
to prevent leaching of contaminants to groundwater above drinking water standards. In addition, clean-
up numbers for the protection of the ecological system were developed. The contaminated sediments in
the Eastern Wetlands (approximately 13 acres) currently pose a threat to the ecological system.
However, because of the destruction that would occur in an attempt to remediate the sediments in the
middle of the wetlands, and because of the implementability issues that would occur due to the area
being flooded for much of the year, and because natural sediments will cover the contaminated sediments
after the source removal has taken place, EPA believes it would be more protective to the ecological
system to not remediate that portion of the wetlands.
Summary of Site Risks. The Baseline Risk Assessment describes the risks to human health and the
environment in the absence of any further cleanup of Site contamination. The human health risk
assessment considers both the current and future potential uses of the Site. For the current use scenario
(off site resident trespassing onto the site) the health risks were all within EPA's acceptable risk range.
For the future scenario, for a resident living on the site, the risks were unacceptable due to consumption
of site groundwater as well as incidental ingest ion of Site soil. Risks to a future onsite worker are also
unacceptable due to consumption of groundwater as well as incidental contact with Site soil. There is
also an unacceptable risk from exposure to surface water if exposure is also in conjunction with the
consumption of contaminated groundwater. The ecological assessment indicated potential risks to
invertebrates and amphibians in the wetlands from exposure to metals contamination. These include
lead, zinc, arsenic, and copper.
The risks to human health are determined by assessing exposure "pathways", through which
individuals are assumed to be exposed to the contaminants. The exposure doses to individual receptors
are calculated by using reasonable upper bound assumptions for the frequency of exposure, how much
of the site soil or water is contacted and/or ingested, as well as other relevant factors. The trespasser is
assumed to contact the surface soil or sediment and the surface water (in the wetland area). For onsite
residential exposure to groundwater (future scenario), the adult is assumed to drink two (2) liters
(slightly more than two (2) quarts) of water per day, for thirty (30) years (assumed duration of living at
the same location). The future worker is assumed to ingest and wash with the site groundwater each
workday (total of 250 days per year for 25 years). Both the future resident and the future worker are
assumed to get Site soil on the exposed skin and to incidentally ingest a nominal portion of that soil each
day they are residing or working onsite.
For each pathway, different calculations are made to account for the two (2) general types of
contaminants: carcinogens, which are suspected or known to cause cancer, and noncarcinogens,
substances which can cause other adverse health effects.
For carcinogens, the result is expressed as the excess cancer risk posed by Site contaminants. CERCLA
establishes a range of 1 x 10~* to 1 x 10"4 as the acceptable range for lifetime excess carcinogenic risks.
Excess risk in this range means that the exposed person has a probability of one in one million (1 x 10**)
to one in 10,000 (1 x 10*4) of developing cancer over a lifetime over and above the risk of cancer from
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other causes. The calculated cancer risks from all the Site contaminants are added together to determine
the total site risk. Noncarcinogenic risk is assessed by using a reference dose for each chemical. The
reference dose is the amount of the chemical to which EPA believes the human population can be
exposed without risk of toxic effects. The Hazard Index (HI) is the ratio of the amount of the chemical
exposure from the Site, divided by the reference dose. The HI value for the individual contaminants
which cause toxic effects on the same body system are added together. EPA generally considers a total
HI of no greater than 1.0 to be acceptable.
Carcinogenic risk and noncarcinogenic HI values were calculated for both the current land use scenario,
with residents living near the Site, and the reasonably possible future land uses, which include
commercial/industrial, residential, and a construction scenario (shorter duration of exposure). The
Baseline Risk Assessment determined that the total cancer risk (using Reasonable Maximum Exposure)
for the current scenario (nearby resident who trespasses onto the Site) was less than 1 x 10**; therefore,
the Site does not pose an unacceptable cancer risk under the current exposure scenario. The total HI
for the current scenario was less than 1.0, indicating that the Site does not pose an unacceptable non-
carcinogenic risk under the current exposure scenario evaluated in the Baseline Risk Assessment.
Therefore, in summary, the Site does not pose any unacceptable current risk to nearby residents.
The Baseline Risk Assessment determined that the total cancer risk for the future onsite worker ranged
from 7 x 105 to 3 x 102, depending on if the deeper portion or the shallower portion of the aquifer
(though it is all interconnected) is assumed to be the source of drinking water for the worker. This latter
risk level exceeds EPA's acceptable risk range (1 x 10"* to 1 x 10"*). The HI for the same receptor ranged
from 03 to 200. In addition to these risk exceedances, MCLs were exceeded for organic contaminants
and lead exceeded its action level in groundwater.
As would be expected, the risks estimated from the residential scenarios are also well above EPA's
acceptable risk values since the exposure is greater for the onsite future resident than for a worker. The
cancer risk for the future onsite resident ranged from 2 x 10~* to 2 x 10*1. The toxic HI ranged from 2
to 2000 for this receptor. These risks all exceed EPA's acceptable risk range regardless of whether a
potential future resident obtained drinking water from a well in the deeper or shallower portion of the
groundwater. The majority of the onsite risks (both cancer and noncarcinogenic) for the future worker
and residential scenarios are attributable to ingestion of volatile organic chemicals in the groundwater.
In addition to these risk exceedances, MCLs were exceeded for organic contaminants and lead exceeded
its action level in groundwater.
The construction worker scenario (assumed exposure to subsurface as well as surface soils, but not to
site groundwater) resulted in an acceptable cancer risk (no greater than 1 x 10'*) and HI (less than
1.0).
More detailed information concerning Site risks is presented in the Baseline Risk Assessment, which is
a part of the Remedial Investigation Report, and is available at the public information repository.
REMEDIAL ACTION OBJECTIVES AND ALTERNATIVES
Remedial Action Objectives. Based on the RI and the Baseline Risk Assessment, EPA has established
the following remedial action objectives for the Shuron Superfund Site:
• Prevent ingestion/direct contact with surface soils, surface water, and sediments, having:
Carcinogen concentrations above levels that would exceed an acceptable cancer
risk range of 10"4 to 10"*, and
10
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Noncarcinogen concentrations above levels that would exceed an acceptable
Hazard Index (HI) of 1.0.
Prevent migration of contaminants from surface and subsurface soils, and sediments,
tha£ would pose a risk to human health due to the leaching of contaminants to
groundwater in excess of Federal/State limits or health-based levels.
Prevent concentrations of contaminants from exceeding the applicable Federal and
South Carolina Ambient Water Quality Criteria for surface waters.
Restore the groundwater system to potential productive use, by cleanup to the standards
described above, and by minimizing the migration of the contaminants beyond the
existing limits of the contaminant plume.
Prevent direct contact with sediments or hydric soils that would result in an
unacceptable risk to ecological receptors.
Prevent ingestion of contaminated groundwater from the Site containing:
Carcinogen concentrations above Federal or State standards, and above levels
that would exceed an acceptable cancer risk range of 10*4 to 10"*, and
Noncarcinogen concentrations above Federal or State standards, or in the
absence of standards, above levels that would exceed an acceptable Hazard
Index (HI) of 1.0.
The Baseline Risk Assessment conducted by Textron's consultant, under EPA oversight, concluded that
groundwater, surface soils, subsurface soils, surface water, and sediments at the Site are media of
concern. Exposure to these media resulted in risk to human health (assuming an industrial future use,
or a residential future use), or to the environment, that exceeds acceptable levels. As a result,
Remediation Goals were developed for both future scenarios for groundwater, surface soils, subsurface
soils (due to leaching contaminants to groundwater), and sediments in the BRA. Surface water
contamination would be addressed by remediating the other media. Presently, the Site is not in use.
There is a 185,000-square-foot building onsite, in fair condition, that could be used in the future for
industrial purposes. Discussions with nearby residents frequently elicited questions such as "when is
the plant going to reopen" or statements to the effect that "we would like a company to open a new
facility so that nearby local residents could be employed there." In addition, significant cost may be
incurred, for removing the building, if the property was to be converted for a residential use. Even
though there are residents living nearby, local sentiment appears to favor the facility remaining
available for potential industrial use. Based on this potential benefit to the community and to the local
tax base, EPA is proposing to remediate the Site to industrial cleanup standards. This would mean that
some contaminated soil above residential standards, but below industrial standards, would not be
addressed. EPA is specifically requesting comments from the public on whether industrial or residential
cleanup standards should be used.
Establishment of Remediation Goals. EPA has established specific remediation goals (RGs) (i.e. cleanup
standards) for surface and subsurface soil, sediment, and groundwater contaminants. Such standards
are derived from several federal environmental laws, including the Safe Drinking Water Act (for water
systems and potable water sources such as groundwater) and the Clean Water Act (for surface waters).
The State of South Carolina has similar statutes. Contaminants regulated under these statutes are
present at this Site. In cases where there is no State or Federal standard, RGs can be developed based
11
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on the Baseline Risk Assessment for human health (risk assessment calculations) and the protection of
the environment (such as using toxicological studies). An RG for lead, in surface soil, was developed
based on EPA's IEUBK model, and for the other contaminants, in the Baseline Risk Assessment.
Subsurface soil RGs were developed such that the contaminants would not leach to groundwater above
drinking water standards. RGs for the wetland sediments were developed from toxicity testing
conducted at the site for protection of the environment
Table 2 summarizes the remediation goals for surface and subsurface soils, sediments, and groundwater
at the Site. The only exception would be lead in the drainage ditch outside the fence, north of the
waste water lagoons. The RG would be 400 ppm to protect nearby residents. The areas potentially
requiring remediation are depicted on Figures 2 and 3, groundwater and soil, respectively, though the
exact areas will be determined during Remedial Design/Remedial Action after further sampling is
conducted.
Development of Remedial Alternatives. In the FS, remedial alternatives were developed and evaluated
for soil (including surface and subsurface soils, and sediments) and groundwater contamination. Then,
the alternatives were compared against one another in detail.
EVALUATION OF REMEDIAL ALTERNATIVES
In selecting its preferred alternative, EPA used the following criteria to evaluate the alternatives
developed in the FS. Seven (7) of the criteria were used to evaluate all the alternatives, based on
environmental protection, cost, and engineering feasibility issues. The preferred alternative is further
evaluated based on the final two (2) criteria.
Threshold Criteria: The first two (2) statutory requirements must be met by the alternative:
1. Overall Protection of Human HeaUli and the Environment
2. Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)
Primary Balancing Criteria: These five (5) considerations were used to develop the decision as to which
alternative should be selected.
3. Long-Term Effectiveness and Permanence
4. Reduction of Toxicity, Mobility, and Volume through Treatment (TMV)
5. Short-Term Effectiveness
6. Implementability
7. Cost
Modifying Criteria: These two (2) considerations indicate the acceptability of the alternative to the
public, and/or local or State officials.
8. State Acceptance
9. Community Acceptance
SUMMARY OF THE REMEDIAL ALTERNATIVES
Below is presented the various alternative for addressing soil and groundwater contamination. They
are also summarized and compared against the seven criteria on Table 3.
12
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Table 2
REMEDIAL GOALS (RGs)
:-.•{>' - *
CONTAMINANTS OF CONCERN
Bis-2-ethylhexyl phthalate
1 ,2-Dichloroethane
1,2-Dichloroethene (Total)
Tetrachloroethene
Trichloroethene
Vinyl Chloride
Ethyl benzene
Toluene
Xylenes (Total)
Lead
CONTAMINANTS OF CONCERN
Bis-2-ethylhexyl phthalate
1,2-Dichloroethane
1,2-Dichloroethene (Total)
Tetrachloroethene
Trichloroethene
Vinyl Chloride
Ethyl benzene
Toluene
Xylenes (Total)
Lead
GROUNDWATER (RGs) UG/L
6.0
5.0
70
5.0
5.0
2.0
700
1000
10,000
15
RGs for Protection of
Groundvrater. Soil concentrations
below which leaching above MCLs
is not expected to occur (mg/kg)
Not detected in TCLP leachate, but
detected in total results of soil
samples
Not detected in TCLP leachate
1.5
0.1
0.09
0.74
62
136
1400
Shall be determined during RD/RA
MCLs
-------
CONTAMINANTS OF CONCERN
f ' / " ,* v> '• ; s -
Lead - Industrial
Arsenic
Beryllium
CPAH (BAP-TE) (Polycyclic Aramaic Hydrocufeom)
' , * , , * ' *, ' ,
RGs FOR SURFACE
(mg/kg)
SOILS
1150
34
12
5
ECOLOGICAL RGs BASED ON TOXICITY STUDIES
CONTAMINANTS OF CONCERN
Lead
Arsenic
Copper
Zinc
rag/kg
700
15
150
350
The RGs for the protection of groundwater for Ethyl benzene. Toluene, and Xylenes (Total), may be
reevaluated during RD/RA since the calculated levels exceed most of the levels detected in the soil
samples, yet these contaminants were detected in the groundwater. Lead will have an RG established
for protection of groundwater, during RD/RA.
14
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CNSR CONSULTING & ENGINEERING
DISTRIBUTION OF SELECTED CONTAMINANTS
IN SHALLOW GROU NDWATER
SHURON SITE
BARNWELL, SOUTH CAROUNA
SCALE IN FEET
1" - 250-0'
-------
arm
•CIUNM
«*f*ei tow, OCCCDMO MO
MAUN MCAU»
SHW0N PMWf
Mm POTDflUL TO ICAO
cvoc on in
SOL DlXlUtW ' . .... . i. •
- *oo or TOO rntAt UAO
.tcolcot*
CONSUimc A
AREAL UMITS OF SOIL
OTENT7ALLY REQUIRING A RESPONSE ACTION
SHURON SITE
OARNWELU SOUTH CAROUN/
-------
GROUNDWATER ALTERNATIVES
lot * Criteria
Overall
Protection
MectARARj
Ix>ng-Term
Protective end
Permanent
Reduc* Toikllf,
Mobility &
Volume (TMV)
Through
Treatment
Short-Term
Effectiveness
Implemenlabllllj
CoM(PW)
Alternative 1
No Action
Would not be overall protective
lince no action it occurring.
juit groundwater monitoring.
Would not meet ARARS «inc«
no action if occurring.
Would not be long-term
protective lince no action il
occurring.
Would not reduce loiicity.
mobility or volume of
contaminant!.
No short-term implementation
riik tince no action it
occurring.
No implements ion dilTicultiei
lince there would be no action.
SI. 35 million
Alternative 1
Limited Action
Would not be overall
protective lince only a
minimal amount of
contaminated, gw ii removed
during lource removal. No
action after Ihii. only
institutional controli.
Would not meet ARARi lince
moil contamination ii not
addreiied.
Would not be long-term
protective lince moit
contamination ii not
addressed.
Would not reduce loiicily,
mobility or volume of
conlaminanli. lince moil
contamination It not
addreiied.
No riik lince minimal action
ii occurring
Minimal implementation
difficulties lince there would
be minimal action.
$1.8 million
Alternative 3
Smirre Removal w/dewalerlng.
evaluation period, active ground
water treatment, and Nat. Allen., If
applicable
Would be overall protective, tince
the contaminated groundwater would
be addreiied.
Would meet ARARi. lince the
contaminated groundwater would be
addreiied.
Would be long-term protective, lince
the contaminated groundwaler would
be addreiied.
Would reduce the TMV. tince the
contaminated groundwiler would be
addreiied.
Some risk during excavation, and
during extraction of contaminated.
ew-
Some w/ extraction.
12 4- 50 million
Alternative 4
.Source removal w/
dewaterlng, murre are*
extract Ion wells or
trenches
May not be overall
protective, since only the
lource area contaminated.
gw would be addreiied.
The contaminated, gw that
ii pail the source area
would not be addreiied
(i.e. between source area
and property boundaries).
May not meet ARARi,
lince only the source area
contaminated, gw would be
addreiied. and not the
contaminated gw past the
lource area.
May not be long-term
effective for reasons Hated
above.
Would reduce the TMV of
tome of the contaminated.
gw through treatment, but
not all contaminated, gw.
Some riik during
excavation, and during
extraction of con laminated.
8W-
Some w/ extraction.
$3.8- 4.1 million
Alternative. £
Source removal w/dewalerlng, property
boundary extraction well*
Would be overall protective, since the
contaminated, gw would be addreiied.
However, il may lake longer than other
alternative, since the source area
contaminated, gw would have to migrate to
the property boundary to be addreiied.
Would meet ARARi. lince the
contaminated, gw would be addreiied.
Would be long-term protective since the
contaminated, gw would be addressed.
Would reduce the TMV. since the
contaminated, gw would be addressed.
Some risk during excavation, and during
extraction of contaminated, gw.
Some w/ extraction.
$4.6 million
17
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TAI»LE3(con'l)
SOIL ALTERNATIVES
• 7 of • Crlltrli
i
Overall Protection
i
MectARAR*
Lout-Term
Protective and
Permanent
Reduce TMV
Through Treatment
Short-Term
Effectiveness
Implementablllly
*•
Cosl(PW)
AJterpatlTe 1
No Action
Would not be overall protective
since no action it occurring.
Would not meet ARARt lince no
action it occurring.
Would not be long-term protective
lince no action i* occurring.
Would not reduce loxicily and
mobility or volume.
No riik lince no action ii
occurring.
No implementation difficultiei
lince there would be no action.
$0
AlltfDitlrci
Limited Action
Would not be overall protective since none of
the contaminated soil is addressed, just a deed
restriction informing future owners of the
contamination. Also, contaminants would
continue to leach to groundwaler and there
would be a continuous risk to the
environment
Would not meet ARARi since contamination
is not addressed.
Would not be long-term protective since
contamination is not addressed.
Would not reduce TMV of conluninanti.
No short-term implemenubilily risk since no
action is occurring.
No implementation difficulties since there
would be no action.
J 120.000
Al!ernAllvt }
Eicavallnn and On-Slte Capping
with No Bottom Liner
Uncertainty that this it overall
protective since contaminated.
could leach to gw above MCLs.
Uncertainly that this alternative.
meets ARARi since contaminated.
could leach to gw above MCL*.
Uncertainly that this alternative, it
long-term protective and
permanent, lince contaminated.
miy leach into the gw above
MCLs.
Would not reduce TV of
contaminants, but should reduce
the mobility lo some degree.
Some risk during excavation from
lead dust and VOCs in the air.
Minimal.
$7.7 million
Alternative 3A
Excavation and On-Slte Capping with Bottom
Liner for RCRA Non-Hazardous Soil and Off-
Site Disposal of RCRA Hazardous Sol
May be overall protective, but there is some
concern that the RCRA hazardous, waste may
leach to gw above MCLs.
May meet ARARi, but there is some concern that
the RCRA hazardous, waste may leach to gw
above MCLs.
May be long-term protective, but there it some
concern that the RCRA hazardous, waste may
leach to gw above MCLs.
Would not reduce TV of contaminants, but ihould
reduce the mobility to tome degree.
Some risk during excavation.
Minimal.
J9.0 million
-------
TAKLE3(con'0
SOIL ALTERNATIVES
7 flf J Criteria
„
Overall Prutccllon
MettARAR*
Long-Term
Protective and
Permaneol
Reduce TMV
Through Treatment
Short-Term
Erfectlrenen
Implementabllllv
Co.il (PW)
Alternative JB
Excavation and On-Slle
Capping with Bottom Liner
for RCRA Non-Hazardous
SoO, Offslte RCRA
Hazardous Soil.
Should be overall protective,
lince all had watte would be
removed from the the, and the
reil land filled; if the landfill ii
maintained indefinitely.
Should meet ARAR*. lince all
has waite would be removed
from the the. and the reit
landfilled; if the landfill ii
maintained indefinitely.
Should be long-term protective
ai described above.
Some if hat. waste diipoted
off-lite ii treated.
Some risk during excavation.
Applies to all alternative!, but
Alternative! 1 and 2.
Minimal.
SI 1.2 million
Alter native 4
SlablllMlk>ft//SnlkJincallon.
Would be overall protective though
there may be fome diff.
Stabilization/Solidification VOC
centime, soils luch that they do not
leach conlam. into the gw above
MCLi.
Would meet ARARi though there
may be tome dificulty; Stabilization/
Solidification VOC contaminated
toils Mich that they do not leach
contamination into the groundwaler
above MCLt.
Would be long-term protective
though there may be tome diff.
Stabilization/Solidification VOC
contaminated, soili to thai they do
not leach contaminated, into the
groundwater above MCLi.
Would reduce loxicily and mobility
but not volume
Some ritk during excavation and
Stabilization/Solidification activities.
Some difficulty during excavation
and Stabilization/ Solidification
activities.
S 10 n- 2H1 million
Altcrnaflve 5
In-sllu Thermal treatment w/
a) Containment orb)
SlablllMllon/ Solidification
According to literature, it may be
overall protect
According to literature, it may meet
ARARi.
According to literature, it may be
long-term protective.
If effective, it would reduce the
TMV of the organic contamination
and possibly the inorganic (if
Stabilization/Solidification used).
Minimal risk for the in-silu thermal
part, tome risk if Stabilization/
Solidification utilized.
May he difficult to implement due
to saturated clayey toils.
tlO H million
Alternative £
Thermal Dcwrptlon with
a) Containment or b)
Stabilization/ Solidification
Would be overall protective since
the organic soils are treated and
the metal soils are treated or
contained such that they should
not leach to gw above MCLi.
Would meet ARARi since the
organic soils are treated and the
metal soils are treated or contained
such that they should not leach to
groundwater above MCLi.
•Would be long-term protective
since the organic toils are treated
and the metal toils are treated or
contained such that they should
not leach to groundwater above
MCLi.
Would reduce TMV of organici,
& T&M of inorganic toils if
Stabilization/Solidification. If
contained, will not reduce the
TMV of metal contaminants.
Some risk during excavation and
thermal desorplion (and
Stabilization/Solidification if this
option it chosen).
Some difficulty during excavation
and greater difficulty w/ thermal.
J 19.3-27.0 million
Alternative. ^
OfT-Slte Dbposal
1
Would be overall plot lince all
contain, toils would be removed
from the site.
Would meet ARARi since all
contaminated toils would be
removed from the tile.
Would be long-term protective and
permanent, lince all contaminated
soils would be removed from the
tile.
Some if waste ditposed off-tile it
treated.
Some risk during excavation and
minimal during transport. '. •
Some difficulty during excavation
SI 1.8 million
19
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Alternatives for Remediation of Croundwatcr. Five (5) alternatives were developed to address
groundwater contamination. The components of Alternatives 1& 2, institutional controls, and
groundwater and surface water monitoring, are implied for all alternatives. A source removal as
discussed in Soil Alternative 3B, is also included with Groundwater Alternatives 2 to 5. The costs for
monitoring for all the alternatives is for a thirty (30) year period. For the alternatives which involve a
treatment technology, the cost is for a ten (10) year operating period. For each alternative, remedial
action objectives will be considered met when the concentrations listed in Table 2 are not exceeded in
any monitoring wells.
Alternative 1 - No Action Under the no action alternative, the Site is left "as is" and no funds are
expended for the control or cleanup of the contaminated groundwater (including no source removal).
If no action is taken, future risks to potential persons living on or working at the Site will remain.
Because hazardous contaminants would remain, a five (5) year review would be required under
CERCLA. Total Present Worth (PW) is $135 million.
Alternative 2 - Source Removal with fi round water Extraction During Excavation Period This
alternative includes the use of a wellpoint system to dewater the soil/sediment source areas for
excavation. The groundwater extraction proposed in this alternative would occur during the period of
excavation only. Extracted groundwater would be treated through an above-ground portable treatment
system possibly consisting of an air stripper, liquid and vapor phase carbon, and a frac tank. The
treatment system effluent would be discharged to Turkey Creek, groundwater, or the local POTVV.
The institutional controls to be used are deed restrictions and well permit restrictions. Deed restrictions
limit future use of the aquifer for such purposes as potable and industrial water supplies, irrigation, and
washing. Permit restrictions issued by the State of South Carolina would restrict all well drilling permits
issued for new wells on properties that may draw water from the contaminated groundwater plume.
These restrictions would be written into the property deeds to inform future property owners of the
possibility of contaminated groundwater beneath their property. PW Cost: $1.8 million.
Alternative 3 - Source Removal with Temporary Groundwater Extraction for Dewatering. Data
Collection/Aquifer Evaluation, Active Groundwater Treatment of remaining contaminated groundwaterf
and if applicable. Monitored Natural Attenuation.A temporary groundwater recovery and treatment
system will be used for dewatering purposes during the source removal as described in Groundwater
Alternative 2, and then will be operated for an additional four to six months after completion of the soil
removal.
An evaluation period for gathering data to design a proactive groundwater treatment system (pump and
treat, recirculation wells, air-sparging, or a combination) to achieve RGOs in the groundwater plume,
will be conducted before, during, and after the source removal. If, during the evaluation period,
monitored natural attenuation can be demonstrated to be as effective as active remediation, within a
comparable time frame, then this approach may be applied to the appropriate portions of the
contaminated groundwater plume. This will be followed by construction and operation of the
groundwater system. PW Cost: $2.4 - $5.0 million.
Alternative 4 - Groundwater Extraction and Treatment in Source Area A temporary groundwater
recovery and treatment system will be used for dewatering purposes during the source removal as
described in Groundwater Alternative 2. In addition, treatment of groundwater utilizing a pump and
treat system would occur in both the Fill/Debris area, the Solids Lagoon area and downgradient of the
Solids Lagoon area. The extraction system would create a zone of influence and prevent the further
migration of COCs. This alternative would take longer than other alternatives or a combination, to
reach the remediation goals because the part of the plume that would have migrated past the source area
extraction wells would only be reduced by natural attenuation. PW Cost: $3.8 - 4.7 million.
20
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Alternative S • Groundwater Extraction and Treatment Near Property Boundary A temporary
groundwater recovery and treatment system will be used for dewatering purposes during the source
removal as described in Groundwater Alternative 2. To prevent further migration or COCs, this
alternative includes the installation of an extraction well system near the property boundary. This
alternative will take longer than other alternatives or a combination of alternatives, to reach the
remediation goals because of the time necessary for the contaminant plume to reach the extraction wells.
PW Cost: $4.6 million.
Alternatives for Remediation of Soil. Seven (7) alternatives were developed to address soil
contamination. The components of Alternative 2, institutional controls and groundwater and surface
water monitoring, are implied for all alternatives. A source removal as discussed in the Soil Alternative
3B are also included with Alternatives 3B to 7. The costs for monitoring for all the alternatives, is for
a thirty (30) year period. For each alternative, remedial action objectives will be considered met when
the concentrations listed in Table 2 are not exceeded. Alternatives 3 to 7 also include the restoration of
all excavated wetlands.
Alternative 1 . No Action Under the no action alternative, the Site is left "as is" and no funds are
expended for the control or cleanup of the contaminated surface and subsurface soils, sediments, and
sludges (all referred to as soils). If no action is taken, future risks to potential persons living on or
working at the Site will remain. Because hazardous contaminants would remain, a five (5) year review
would be required under CERCLA. PW Cost: $0.
Alternative 2 • Limited Action A fence, typically 6 or 8-foot high chain-link, possibly with barbed wire,
would be constructed around the area within which surface soils exceed RGOs, with signs on the fence
notifying the public. The institutional controls would include a deed restriction limiting use of portions
of the property in which soils exceeding RGs have been left in place, and stating that contamination
remains and its location. The deed restriction would limit the activities that could potentially be
conducted in or around these areas. The deed restriction would serve as notification to potential
purchasers or developers of the property that land use is restricted in these areas. PW Cost: $120,000.
Alternative 3 • Excavation and On-Site Capping with No Bottom Liner Contaminated soil with
concentrations exceeding RGs in Table 2 would either be capped in place, for some of the metals only
soil, with an engineered cap (the soils would be in or near the groundwater), or the soils would be
excavated and placed under an engineered cap. This includes both RCRA hazardous and RCRA non-
hazardous waste. The design and construction of the capped areas would include a low permeability
FML cap. Contaminated soils which are excavated, would be placed at least three feet above the
seasonably high water table in the areas set aside for construction of the cap(s). Clean nil will be added,
if necessary to create this separation. Initial lifts will be of metal contaminated soils passing the RCRA
TCLP test, and the upper lifts will consist of mixed VOCs and metals contaminated soils. Capped areas
would be isolated by fencing.
Those soils to be excavated that are wet, would be transported to a construction pad with controlled
drainage (collection and treatment) and mixed with drying agents such as quicklime to absorb excess
moisture and improve their physical and load bearing characteristics. In addition, all VOC soils will
be aggressively treated by aeration to release VOCs during the mixing process with the dewatering
reagent, and from materials handling processes. During Remedial Design, laboratory treatability testing
and field pilot studies will be conducted to gather volatilization data to predict emissions during full
scale soil excavation and modification activities, and to determine the amount of VOCs remaining in the
soils. Soil vapor extraction (SVE) laterals may be placed throughout the organic contaminated soils
21
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beneath the cap, unless limited volume and concentrations of VOCs remain or it is determined during
remedial design that SVE would not be effective due to permeability issues. PW Cost: $7.7 million.
Alternative 3A - Excavation and On-Site Capping with Rnttnm Liner for all Contaminated Soils All
contaminated surface and subsurface soils and sediments, with concentrations exceeding RGs in Table
2, including RCRA hazardous and RCRA non-hazardous soil, would be excavated and moved to an
engineered containment system. The design and construction of the containment areas would include
components such as a low permeability FML cap, an underliner and a leachate collection system. Clean
soil will be added to bring the bottom of the containment systems to at least three feet above the
seasonably high water table. The initial soil lifts will be of metal contaminated soils, and the upper lifts
will consist of mixed VOC and metals soils.
The excavated wet soils would be transported to a construction pad with controlled drainage (collection
and treatment) and mixed with drying agents such as quicklime to absorb excess moisture and improve
their physical and load bearing characteristics. In addition, all VOC soil will be aggressively treated
by aeration to release VOCs during the mixing process with the dewatering reagent, and from materials
handling processes. During Remedial Design, laboratory treatability testing and field pilot studies will
be conducted to gather volatilization data to predict emissions during full scale soil excavation and
modification activities, and to determine the amount of VOCs remaining in the soils. Soil vapor
extraction (SVE) laterals may be placed throughout the organic contaminated soils beneath the cap,
unless limited volume and concentrations of VOCs remain or it is determined during remedial design
that SVE would not be effective due to permeability issues. PW Cost: $9.0 million.
Alternative 3B - Excavation and On-Site Capping with Bottom Liner for RCRA Non-Hazardous Soil and
Off-Site Disposal of RCRA Hazardous Soil All contaminated surface soils, subsurface soils, and
sediments that exceed Remedial Goals in Table 2, will be excavated. Soils that remain designated as
RCRA hazardous waste, would be disposed of off-site at an acceptable hazardous waste facility. Soils
which would be designated as RCRA non-hazardous would remain on-site. The RCRA non-hazardous
waste which leaches above drinking water standards, would be disposed in an on-site RCRA Subtitle D
landfill. Soils not leaching above MCLs, would not be placed into a Subtitle D landfill, but would be
placed under an engineered cap, to prevent direct contact exposure. The design and construction of the
Subtitle D landfill would include components such as a low permeability FML cap, an underliner and
a leachate collection system. Clean soil will be added to bring the bottom of the landfill to at least three
feet above the seasonably high water table. The initial soil lifts will be of metal contaminated soils, and
the upper lifts will be mixed VOC and metals soils.
The excavated wet soils would be transported to a construction pad with controlled drainage (collection
and treatment) and mixed with drying agents such as quicklime to absorb excess moisture and improve
their physical and load bearing characteristics. In addition, all VOC soil will be aggressively treated
br aeration to release VOCs during the mixing process with the dewatering reagent, as well as from
materials handling processes. During Remedial Design, laboratory treatability testing and field pilot
studies will be conducted to gather volatilization data to predict emissions during full scale soil
excavation and modification activities, and to determine the amount of VOCs remaining in the soils. Soil
vapor extraction (SVE) laterals may be placed throughout the organic contaminated soils beneath the
cap, unless limited volume and concentrations of VOCs remain or it is determined during remedial
design that SVE would not be effective due to permeability issues. PW Cost: $11.2 million.
22
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Alternative 4 - Stabilization/Solidification All contaminated surface soils, subsurface soils, and
sediments that exceed Remedial Goals in Table 2, will be excavated. These soils would be treated using
stabilization/solidification (Stabilization//Solidification). The soils would be excavated and treated and
consolidated on site in upland areas. Treatment effectiveness may be evaluated against RCRA TCLP
test results as well as_TCLP using site background ground water, and possibly other tests (possibly the
ASTTV1 water leach test or EPA 1312 test). The results will be compared to drinking water standards.
Treated areas would be isolated by fencing (with signs) and would be covered with a cap.
The term stabilization refers to the technology where a chemical agent, typically self-cementing
(pozzolanic), is added to a waste to reduce the hazard potential of that waste; solidification refers to
processes that convert liquid and semi-solid wastes to a solid form (monolith), typically binding
contaminants mechanically in the solid matrix and significantly reducing the permeability.
Given the present knowledge of the soil characteristics, type and depth of contamination, ex situ
Stabilization//Solidification, is probably the most appropriate method for treating contaminated soils
on the Shuron Site. In addition, the soils will be aggressively treated by aeration to release the VOCs
during the mixing of contaminated soils with the reagent, as well as from materials handling processes.
During Remedial Design, laboratory treatability testing and field pilot studies will be conducted to:
determine the most effective reagent mixture to prevent leaching of contaminants to groundwater above
MCLs, to gather volatilization data to predict emissions during full scale soil excavation and
modification activities, and to determine the amount, if any, of VOCs remaining in the soils.
On a CERCLA site, treatment of RCRA materials in a vessel may potentially trigger LDRs, if levels after
treatment still exceeded RCRA characteristic levels. Stabilization/Solidification may include use of a
vessel, therefore, LDRs may need to be met which include use of uniform treatment standard (UTS)
technologies for pretreatment, and the underlying hazardous constituent levels for various contaminants
(such as lead). PW Cost: $10.6 - 20.3 million.
Alternative S - In Situ Treatment Followed by \) Containment: or B1 Stabilization/Solidification All
contaminated surface soils, subsurface soils, and sediments that exceed Remedial Goals (RGs, Table 2),
will be excavated. The soils would be initially treated in situ using thermal treatment technology to
reduce concentrations to below RGs as described on Table 2. Inorganic contaminated soils would
require Stabilization/Solidification as described for Alternative 4 and/or containment, as described for
alternative 3B. Treated areas would be isolated by fencing and would be covered with a cap.
Potential process options for thermally treating soils include steam injection, hot air flushing, and six
phase soil heating (SPSH). According to literature, SPSH has better performance data for treating fine-
textured material both in the vadose zone and below the groundwater table. Therefore this will be the
only option discussed. Six-phase soil heating (SPSH) is a technique that uses common low-frequency
electricity to heat soils by converting standard three-phase power to six-phase power. Electrodes are
inserted into the ground in circular arrays. Each electrode is connected to a separate transformer with
a separate current phase. A seventh, neutral electrode is located at the center of the array and doubles
as a soil vent As electricity is applied, the soil heats, volatilizing organic compounds which are removed
through the central soil vent Pore water in the soil is the principle conductor of electricity. This
technology is a variation of radio frequency heating, using one-fifth to one-tenth the power to net similar
results. SPSH has been demonstrated on tight clayey soils for the removal of chlorinated compounds.
Removal efficiencies for TCE and PCE exceeded 99% using target soil temperatures of 100°C. PW Cost:
$10.0 -15.3 million.
23
-------
Alternative 6 - Low Temperature Thermal Desorption Followed by A^ Containment: or
B> Stabilization/Solidification All contaminated surface soils, subsurface soils, and sediments that
exceed Remedial Goals (RGs, Table 2), will be excavated. The organic soils would be initially treated
ex-situ using low temperature thermal desorption followed by Stabilization/Solidification or
Containment (3B).~Thermal desorption processes are designed to remove the volatile and some semi-
volatile organic compounds from soil. PW Cost: $22 - 27 million.
Alternative 7 - Excavation and Off-Site Disposal All contaminated surface soils, subsurface soils, and
sediments that exceed Remedial Goals (RGs, Table 2), would be excavated and disposed off-site at an
appropriate hazardous waste facility. Facilities may solidify the soils prior to disposal.
PW Cost: $11.8 million.
EPA'S PREFERRED ALTERNATIVE
After conducting a detailed analysis of all of the alternatives, EPA has a preference for the following
alternatives for soil and groundwater remediation of the Shuron Superfund Site:
Combination of Soil Alternatives 3B and 4t All soils exceeding RGs will be excavated and dewatered.
After this, whatever soils are determined to be RCRA hazardous waste, shall be disposed off-site, unless
through aggressive treatment (Stabilization/Solidification and aeration), the soils are determined to no
longer be RCRA hazardous. All soils that are designated as RCRA non-hazardous, may remain on-site.
These soils that remain on-site will be aggressively treated by Stabilization/Solidification and aeration
to reduce the contaminant concentrations, such that the contaminants do not leach out of the soils above
MCLs. The exact reagents to be used will be determined from laboratory and pilot scale treatability
studies conducted during RD to determine the most effective reagent mixture. If, after aggressive
treatment, the RCRA non-hazardous waste continues to leach above MCLs, (this is expected to be
primarily VOC contaminated soils), the waste will be disposed of in an on-site RCRA Subtitle D landfill.
Soils not leaching above MCLs, would not require placement in an on-site RCRA Subtitle D landfill, but
would be placed under an engineered cap to prevent direct contact exposure. If it is determined during
RD/RA, that it would be more cost effective to take soils that leach above MCLs off-site, then Alternative
7 (Off-Site Disposal) may be implemented versus a combination of Alternatives 3B and 4. After
excavation of the wetlands, the wetlands will be restored.
Total PW Cost: $11-15 million
Groundwater Alternative 3; Source Removal with Temporary Groundwater Extraction for Dewatering,
Data Collection/Aquifer Evaluation, Active Groundwater Treatment of contaminated groundwater, and
if applicable, Monitored Natural Attenuation.
Total PW Cost: $2.4 • 5.0 million
24
-------
RATIONALE FOR THE PREFERRED ALTERNATIVE
The fourteen (14) alternatives for 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 summaries of how the
alternatives were judged against these nine (9) criteria are presented.
ALTERNATIVES
Threshold Criteria
Soil Alternatives 1 (No Action) and 2 (Institutional Controls/Monitoring), do not meet the threshold
criteria of protecting human health and the environment and meeting ARARs, since no remedial action
is taken. There is high uncertainty that Soil Alternative 3 (Capping with no bottom liner) will be overall
protective of human health and the environment and will meet ARARs, because of the potential to leach
contaminants to the groundwater above MCLs. This is a significant concern since the groundwater at
the Site is very shallow, about 3 feet below land surface. Soil Alternative 3A may meet the threshold
criteria, but there is some uncertainty as to whether hazardous waste, as defined by RCRA, will leach
from the landfill. RCRA regulations do not allow a Subtitle D landfill to accept waste that leaches above
RCRA characteristic levels, and this alternative does not even include all the requirements of a Subtitle
D landfill. Alternative 3B (Excavation and On-Site Capping with Bottom Liner for RCRA Non-
Hazardous Soil and Off-Site Disposal of RCRA Hazardous Soils) should be overall protective, if the
landfill is maintained indefinitely. Alternative 5 may meet the threshold criteria, according to literature,
however, there is still some concern of its protectiveness since In-Situ Thermal Treatment is a relatively
new technology, which may be hindered by the reduced air flow through the soil.
The other three (3) alternatives, Alternative 4 (Stabilization/Solidification (In Situ and/or Ex Situ),
Alternative 6 (Low Temperature Thermal Desorption Followed by A) Containment; or B)
Stabilization/Solidification, and Alternative 7 (Off-Site Disposal) will meet the two (2) threshold criteria
of being protective of human health and the environment and meeting ARARs. A combination of
Alternative 4 with Alternative 3B, would be as overall protective as the other alternatives alone.
Using this combination of alternatives, the soils would be aggressively treated with aeration and
Stabilization/Solidification to treat the metals and most of the VOC contaminants, so that they no longer
leach above MCLs. Then alternative 3B could be implemented such that those soils that continue to
leach above RCRA hazardous levels, would be disposed of off-site. Those that are between RCRA
hazardous and MCLs, VOCs primarily, could be placed into a Subtitle D landfill. Thus this combination
would be overall protective and meet ARARs, since the high level contamination would be removed from
the Site, and any contaminants that may still leach above MCLs after aggressive treatment, but at
considerably lower levels than before treatment, would be prevented from leaching into the groundwater
utilizing engineering controls.
Balancin Criteria
Soil Alternatives 1 (No Action) and 2 (Institutional Controls/Monitoring), w ill not be long-term effective
and permanent for reasons stated above. Again, there is high uncertainty that Soil Alternative 3
(Capping with no bottom liner) and some uncertainty that Soil Alternative 3 A will be long-term effective
for the same reasons stated above since the groundwater is very shallow. Alternative 3B (Excavation
and On-Site Capping with Bottom Liner for RCRA Non-Hazardous Soil and Off-Site Disposal of RCRA
25
-------
Hazardous Soils) would probably be overall protective, under the conditions described above.
Alternatives 1 to 3B do not meet the statutory preference for treatment Alternative 5 may be effective,
but this is based on literature. It would also meet the preference for treatment, if effective.
Alternative 4 (Stabilization//So!idification) would be long-term effective and would meet the statutory
preference for treatment Alternative 7 (Off-site disposal) would be long-term effective and permanent
since the contaminated soil would be removed from the site. Also, the off-site disposal facility would be
secured since it would have personnel onsite to ensure no trespassers, would be regulated, and already
conducts monitoring. It also may partially satisfy the preference for treatment if the off-site facility
solidifies the soil prior to placement into the landfill. Alternative 6 (Thermal Desorption with
Stabilization/Solidification (for the inorganic soils) would also be long-term effective and permanent and
would most satisfy the statutory preference for treatment, since both the organic and metals
contaminants would be treated (if metals soils were Stabilization/Solidification). Thermal treatment
with on-site containment of the metals soils, may be less long-term permanent, than
Stabilization/Solidification of the metals soil, and would not satisfy the preference for treatment as well
as treating both the metals and VOC soils. As described above, a combinations of Alternatives 4 and 3B,
would be as long-term effective and permanent as the other alternatives alone, and satisfy the statutory
preference for treatment
The greatest impletnentability difficulties and highest short term risk would be Alternative 6, Thermal
Desorption due to the saturated clayey soils. Alternative 4 (Stabilization/Solidification) may have some
implementability difficulties for the same reasons, and also may have a slightly higher short term risk
than Alternatives 3 to 3B (Containment), as well as Alternative 7 (Off-site disposal). Alternative 5 (In-
situ thermal treatment) may not pose as much of a short term risk as Alternatives 4
(Stabilization/Solidification) and 6 (Ex-situ thermal) but more than 3 to 3B (Containment) and 7 (Off-
site disposal). There would, however, be implementability difficulties due to the saturated clayey soils
for Alternative 5.
The least expensive alternatives (besides 1 and 2) are 3 ($7.7 million) and 3A ($9.0 million). The costs
of Alternatives 3B, 4,5, and 7 are similar, approximately $11 to 12 million. The cost of Alternative 4
could increase above this amount if special additives are needed to treat the VOCs in the soil (up to
approximately $20 million). Alternative 6 costs significantly more than all the other alternatives, up to
approximately $27 million. A combination of Alternatives 3B and 4 would probably be the most cost
effective, protective alternative, since the soils are aggressively treated with Stabilization/Solidification,
though not necessarily with high cost additives such as organoclays or proprietary mixtures. Then those
soils that continue to leach above MCLs, could be placed into a RCRA Subtitle D landfill to prevent
leaching of contaminants to groundwater.
Therefore, based on the seven criteria, EPA's preferred alternative is a combination of Alternatives 3B
and 4 (for RCRA non-hazardous soils • Excavation, Stabilization/Solidification, and Subtitle D landfill
and, for RCRA hazardous soils - Off-Site Disposal). Soils not leaching above MCLs, would not be placed
into a Subtitle D landfill, but would be placed under an engineered cap that will prevent direct contact
exposure. If it is determined to be more cost effective, the non-hazardous soils may also be disposed off-
site. This combination of alternatives would be overall protective and meet ARARs since the highest
contaminated soil would be removed from the site, and the remainder would be aggressively treated with
stabilization/ solidification and aeration to prevent leaching of contaminants above MCLs. A Subtitle
D landfill will be constructed for soils that continue to leach contaminants above drinking water
standards, only after aggressive treatment This combination provides a more cost effective and
26
-------
protective alternative than each of the alternatives alone. It would also satisfy the preference for
treatment for most of the soils. •
r.R nt nvmv ATER^LTERNATIVES
Threshold Criteria
Ground water Alternatives 1 (No Action) and 2 (Institutional Controls/Monitoring) do not meet the
threshold criteria of protecting human health and the environment and meeting ARARs. The other three
(3) alternatives, Alternative 3 (Source Removal with Temporary Ground water Extraction for
Dewatering, Data Col lection/ Aquifer Evaluation, Active Groundwater Treatment of remaining
contaminated groundwater, and if applicable, Monitored Natural Attenuation), Alternative 4
(Groundwater Extraction and Treatment at the source area), and Alternative 5 (Groundwater
Extraction and Treatment at the property boundary) will meet the two (2) threshold criteria of being
protective of human health and the environment and meeting ARARs.
Balancing Criteria
All alternatives should meet the Superfund Amendments and Reauthorization Act of 1986 (SARA)
requirements favoring active remediation of contaminated groundwater, which Alternatives 1 and 2 do
not Alternatives 3,4, & S meet the five (5) balancing criteria. Alternative 3 allows an evaluation period
for gathering data to design the most effective proactive treatment groundwater system (pump and treat,.
recirculation wells, air-sparging or a combination) to achieve RGs in the entire groundwater plume. If,
during the evaluation period, monitored natural attenuation can be demonstrated to be as effective as
active remediation, within a comparable time frame, then this approach may be applied to the
appropriate portions of the contaminated groundwater plume. Alternative 4, will probably take longer
to clean-up the groundwater and would only apply to a portion of the plume because only the source
area would be remediated. The portions of the plume not affected by the extraction system would not
be treated. Alternative 5 would take longer than alternative 3 because of the time necessary for the
entire contaminant plume to reach the extraction wells along the southern property boundary, near the
railroad bed.
In view of these comparisons, EPA believes that a combination of Soil Alternatives 3B and 4, and
Groundwater Alternative 3, are the best alternatives for remediation of the soils and groundwater at the
Site. Employing these Alternatives would protect human health and the environment and result in
meeting ARARs. The Alternatives are easily implementabie, will be effective in the long term, and
reduce contaminant toxicity and mobility by treating the soil and the groundwater.
STATE ACCEPTANCE:
The SCDHEC concurs with the selected groundwater remediation of Alternative 3. If monitored natural
attenuation is selected for a portion of the plume, a ROD Amendment or ESD will be performed, if
determined necessary by either EPA or SCDHEC.
SCDHEC concurs with the selected remediation option for soils of a combination of Alternatives 3B and
4 (described above). SCDHEC also concurs that if it is determined during RD/RA, that it would be more
cost effective to take soils that leach above MCLs off-site, then Alternative 7 (Off-Site Disposal) may be
27
-------
implemented versus a combination of Alternatives 36 and 4 (Stabilization/Solidification and
construction of an on-site RCRA Subtitle D landfill). However, acknowledging the current conflicting
views on the appropriate future use of the site, SCDHEC does not concur with the selected remedial goals
for soils. Therefore, SCDHEC will seek input from the community during the Proposed Plan public
meeting and comment period on the appropriate future use of the Site, as described above.
PUBLIC PARTICIPATION
EPA will hold a Public Meeting on Tuesday, December 9, 1997, to discuss the Preferred Alternative and
the other alternatives evaluated in the FS. Officials from EPA and SCDHEC will present a summary
of the RI/FS, the remedial alternatives, and how the preferred alternative was selected. The public is
encouraged to attend this meeting.
EPA is also conducting a thirty (30) day public comment period, from Friday, December 5,1997 to
Monday January 5,1998, in order to receive public input and comments on the preferred alternative
for cleanup of the Site. Comments on the preferred alternative, the other alternatives, or other issues
related to Site cleanup, are welcomed and are an important part of the decision-making process. Please
send all comments to:
Ms. Sheri Panabaker
Remedial Project Manager
U.S. Environmental Protection Agency
61 Forsyth St, SW, WMD-NSMB-SC
Atlanta, Georgia 30303
404-562-8810, or 1-800-435-9233
EPA will review and consider all comments received during the comment period and the public
meeting before reaching a final decision on the most appropriate remedial alternative for Site
cleanup (the "remedy"). EPA's final decision will be issued in a Record of Decision, a legal
document which formally sets forth the remedy. A Responsiveness Summary, which contains all of
the public comments received and EPA's responses to them, is part of the Record of Decision (ROD).
EPA representatives are available to provide briefings to residents living near the site, local officials
and others prior to the proposed plan public meeting. To request a briefing, or if you would like
more information on community relations in the Superfund process or at this Site, please contact:
Ms. Cynthia Peurifoy
Community Relations Coordinator
U.S. Environmental Protection Agency
61 Forsyth St, SW, WMD-NSMB-SC
Atlanta, Georgia 30303
(404) 562-8798, or 1-800-435-9233
28
-------
Attachment B
Public Notices of Public Comment Period and Extension
of Public Comment Period
-------
December 3. 1997
•P TO CREDITORS
97-ES-03-00075
;orte having claims against
ng estates are required to
mail their claims to the indi-
sonal Representatives, ap-
i administer these estates,
their claims on Form #371
he Probate Court of Allen-
ity. the address of which is
x 737, Altendale County
se, Allendale SC 29810, on
:he date that is eight months
date of the first publication
Dtice to Creditors Junless
operation of Section 62-3-
jch persons shall be lorev-
Leqals
er barred as to their claims. All claims
are required to be presented in writ-
ten statements, indicating the name
and the address of the claimant, the
basis of the claim, the amount
claimed, the date when the claim will
become due, the nature of any un-
certainty as to the amount claimed
and the date when due, and a descrip-
tion of any security as to the claim.
Estate: Ruth Albany Bing
Personal Representative: Otis
Bing, Sr.
Address: P. O. Box 845,
Fairfax, SC 29827
970231
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U.S. ENVIRONMENTAL PROTECTION AGENCY
INVITES PUBLIC COMMENT ON THE PROPOSED
CLEANUP PLAN FOR THE SHURON SITE, BARNWELL,
BARNWELL COUNTY, SOUTH CAROLINA
The U.S. Environmental protection Agency is inviting public com-
ment on the Proposed Plan for cleanup of the SHURON Superfund Site.
The Remedial Investigation/Feasibility Study for the site has been com-
pleted. The Remedial Investigation determined the nature and extent of
contamination at the site. The Feasibility Study (FS) evaluated alterna-
tives for addressing soil and groundwater contamination at the site.
Fourteen alternatives were considered in proposing this action. The
figures in parentheses are the estimated present worth costs for each al-
ternative. The following alternatives were considered:
Alternatives for Groundwater Remediation:
Alternative 1: No Action ($1.3 million)
Alternative 2: Source Removal and Groundwater Extraction During the
Excavation Period. ($1.8 million)
Alternative 3: Source Removal with Temporary Groundwater Extraction
for Dewatering. Data Collection/Aquifer Evaluation. Active Groundwa-
ter Treatment of Remaining Contaminated Groundwater, and if appli-
cable, Monitored Natural Attenuation. ($2.4 to $5.0 million)
Alternative 4: Groundwater Extraction & Treatment in Source Area. ($3.8
to $4.7 million)
Alternative 5: Groundwater Extraction & Treatment Near Property Bound-
ary. ($4.6 million)
Alternatives for Remodiation of Soil:
Alternative I: No Action. ($0)
Alternative 2: Limited Action - Institutional Controls. ($120,000)
Alternative 3: Excavation and On-Site Capping with No Bottom Liner.
($7.7 million)
Alternative 3A: Excavation and On-Site Capping for All Contaminated
Soils. ($9.0 million)
Alternative 3B: Excavation and On-Site Capping with Bottom Liner for
RCRA Non-Hazardous Soil and Off-Site Disposal of RCRA Hazardous
Soil. (SI 1.2 million)
Alternative 4: Stabilization/Solidification. ($10.6 to $20.3 million)
Alternative 5: In Situ (In Place) Treatment Followed by Containment or
Stabilization/Solidification. ($10.0 to $15.3 million)
Alternative 6: Low Temperature Thermal Desorption Followed by Con-
tainment or Stabilization/Solidification. ($22 to $27 million)
Alternative 7: Excavation and Off-Site Disposal. ($11.8 million)
After conducting a detailed analysis of all of the alternatives, EPA
has a preference for the following alternatives for soil and groundwater
remediation of the Shuron Superfund Site.
Combination of Soil Alternatives 3B and 4: All soils exceeding
Remediation Goals will be excavated and dewatered. After this, what-
ever soils are determined to be RCRA hazardous waste, shall be dis-
posed off-site, unless through aggressive treatment (S/S and aeration),
the soils are determined to be no longer be RCRA hazardous. All soils
that are designated as RCRA non-hazardous, may remain on-site. These
soils that remain on-site will be aggressively treated by S.S and aeration
to reduce the contaminant concentrations, such that the contaminants do
not leach out of the soils above MCLs (drinking water standards). The
exact reagents to be used will be determined from laboratory and pilot
scale treatability studies conducted during RD to determine the most
effective reagent mixture. If, after aggressive treatment, the RCRA non-
hazardous waste continues to leach above MCLs, (this is expected to be
primarily VOC contaminated soils), the waste will be disposed of in an
on-site RCRA Subtitle D landfill. Soils not leaching above MCLs, would
not require placement in an on-site RCRA Subtitle D landfill, but would
be placed under an engineered cap to prevent direct contact exposure. If
it is determined during RD/RA, that it would be more cost effective to
take soils that leach above MCLs off-site, then Alternative 7 (Off-Site
Disposal) may be implemented versus a combination of Alternatives 3B
and 4. After excavation of the wetlands, the wetlands will be restored.
Total PW Cost: SI US 15 million
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Alternative 3; Source Removal with Temporary
Groundwater Extraction for Dewatering, Data Collection/Aquifer Evalu-
ation. Active Groundwater Treatment of contaminated groundwat^r. and
if applicable. Monitored Natural Attenuation.
Total PW Cost: $2.4 - $5.O million . . :
EPA will hold a Public Meeting on Tuesday, December 9, 1997, at
7:00 p.m., in the Barnwell County Council Chambers, Bamwell Country
Agricultural Building, 1603 Peckman, to discuss the Preferred Alterna-
tives and the other alternatives evaluated in the FS. Officials form EPA
and SCDHBC will present a summary of the RI/FS. the remedial alterna-
tives, and how the preferred alternative was selected. The public is en-
couraged to attend this meeting and provide comments on the preferred
alternatives, as well as all alternatives evaluated in the FS.
EPA is also conducting a thirty (30) day public comment period, from
Friday, December 5, 1997 to Monday, January 5, 1998, in order to re-
ceive public input and comments on the preferred alternative for cleanup
of the Site. Comments on the preferred alternative, the other alternatives,
or other issues related to Site cleanup, are welcomed and are an impor-
tant pan of the decision-making process. Please send all comments to:
. Ms. Sheri Panabaker
Remedial Project Manager
U.S. Environmental Protection Agency
61 Forsyth St. SW, WMD-NSMB-SC
• Atlanta, Georgia 30303
404-562-8810, or 1 -800-435-9233
EPA will review and consider all comments received during the com-
ment period and the public meeting before reaching a final decision on
the most appropriate remedial alternative for Site cleanup (the "remedy").
For more information on community relations in the Superfund process
or at the Site, please contact Cynthia Peurifoy, Community Relations
Coordinator, at the above address or by phone at (404) 562-8798, or 1-
800-435-9233. Ms. Peurifoy can also arrange briefings for local officials
and residents near the site, as well as provide copies of the Proposed Plan
Fact Sheet, or add individuals to EPA's mailing list for the site.
Copies of the proposed plan, as well as the administrative record for
the site, are available for review at the site information repository, which
is in the Barnwell County Library, 2001 Hagood Avenue, Barnwell, SC
29812. These documents are also available for review at the EPA Records
Center, 61 Forsyth Street, S.W., Atlanta, GA 30303.
-------
7-37-1 99S 2-2SAM
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Electronic* Club, Kin Jnckion,
wvuiUd by Ttrrr WiUiMM; MiM
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eewrtwd by lUatldo Wrifht;
MiM Human Bcrriccs. Khonidu
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U. S. ENVIRONMENTAL FKO r ItCTION AGENCY
EXTENDS THF. PI JRI .1C COM MUM rUKlOiJ ON THE
PROPOSED CLUANUf ItAN FOR THE 5HURON SITE. BARNW5U..
BARNWELL COUNTY, SOUTH CAROLINA
I he U. S. Envnonuwmal Protection Afenvy ivvxteuUing Ihe publk comment pr.rio.1 on ihr Pmft.^wd lltn lor
clcnnup of th» Shuron SapcrfiinJ Sitr. UK comment period hn Vf.n rilc.nri in cod on Wednesday. February 4.
I WH I hi* extension WM onnouacfd at dw p«t)U: mtctinK tundwlnl vn Dcc«inbci 9. 1997. EPA will xtso
conduct another pobtic metilnf 10 pntmt ihc ilterniiiv«f I»i*d below, tod to receive putihr. commrjii« t -i'A
cm OUKJJCV »RM hy reudcnts, local otfKttli tut other inlEretKtf pH1(«S 19 tmni ihif nwciing are! provide tuinnietiu
m tlie pielerrod «lternibvu, u well M all atonutivH (valuadd in the PS.
PUBLIC MEETING:
THURSDAY, JANUAlty22. 1998
7K»P,M.
BAKNW8LL COUNTY rWTNCII., CHAMUUKi
' K ARNWEli. COUNTY AOKlfUti UKAL BUIU>C«C
uilwn attecAMiv;* vr.rr. rnniWkred iii propoaint this action. The fieuitt In pmeiUcm arc the estimated
prttcnt worth coib for Nth attarnahvt. Tht following aMmativei werv cpndrlranl-
.
Altemativei for Croundwater R«m»d>ttion-
AtentMlral: NoAtim(»l.3imfiim 1 UH-J ($7 7 Millmn)
BM»vatiunaiidOB.SileC'«pp)DffwAUrnnlnmnetadSoiliCi9.0 Million)
Excavation and On Sin Capplai wkh Bouom Liner r.n RCRA Nun.H*uiM<»n .Viil Mxt
AllctnMivr 7
SttbiU»atio«VSoli
-------
7-07-1998 2=38AM FROM BARNWELL REGION 803 2B9
v • "t
After conducting a detailed analysis of all of the alternatives, EPA has a preference for the following alternatives
for soil and groundwater Remediation of the Shuron Superfund Site:
of foil Alternatives 3Qb and 4; AH soils exceeding Remediation Goals will be excavated and
dewaiered. After this, whatever toils are determined to£e RCRA hazardous waste, shall be disposed off-site
unless through aggressive treatment (S/S and aeration), the soils are determined to no longer be RCRA hazardous.
All soils that are designated as RCRA non-hazardous, may remain on-site, Those coils that remain on-site will
be aggressively treated by S/S and aeration to reduce the contanujuwtfconcentradc>ns,$iic^ that the cooUBninants
do not leach out of the soils abow MCLs (drinking water standards). The exact reagents to be used, will be
determined from laboratory and pilot scale trwaaMlHy studies .conducted during RD to determine the most
effective reagent mixture, If, after aggressive treatment, the RCRA.aoa-bazardous waste continues to leach
above MCLs, (this is expected to be primarily VOC contaminated toils), the waste win be disposed of in an on-
site RCRA Subtitle D landfill. Soils not leaching above MCLs, would not require placement in an on-site RCRA
Subtitle D landfill, but would be placed under an engineered cap to prevent direct contact exposure. If it is
determined during RIVRA, that it would be more cost effective to take soils that leach above MCLs off-site, then
Alternative 7 (Off-Site Disposal) may be implemented versus a combination of Alternatives 3B and 4. After
excavation of the wetlands, the wetlands will be restored. ;
Total PW Cost: $11-million : \
Orpundwater Alternative 3:' Source Removal with Temporary Groundwater Extraction for Dewatering. Data
Collection/Aquifer Evaluation, Active Groundwater Treatment of contaminated groundwater, and if applicable,
Monitored Natural Attenuation. •' ;• ..
Total PW Cost: $2.4 - $5.0 million
As stated earlier, the extended public comment period will end on Wednesday, February 4.1998. Comments on
the preferred alternative, the other alternatives, or other issue* related to Site cleanup, are welcomed and are an
important part of the decision-making process. Please send all comments to:
Ms. Sheri Panabaker ;
Remedial Project Manager ; .
U. S. Environmental Protection Agency
61 Forsyth St. SW, WMD-NSMB-SC
Atlanta, Georgia 30303
404-562-8810, or 1-800-435-9233
EPA will review and consider all comments received during the comment period and the public meeting before
reaching a final decision on die moct appropriate remedial alternative for Site cleanup (the "remedy"). For more
information on community relations in the Superfuod process or at this Site, please contact Cynthia Peurifoy,
Community Relations, Coordinator, at the above address or by phone at (404) 562-8798, or 1-800-435-9233.
Ms. Peurifoy can also arrange briefings for local officials and residents near the site, as well as provide copies of
the Proposed Plan Fact Sheet, or add individuals to EPA's mailing list for the site.
; . ( . > . - -.«.-.'
Copies of the proposed plan, as well as the administrative record for the site, are available for review at the site
information repository, which is in the BaraweQ County Library, 200] Haygood Avenue, Darawdl. SC 29812.
These documents are also available for review at the EPA Records Center, 61 Porsytfa Street, S. W. Atlanta, GA
30303. . .
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY
EXTENDS THE PUBLIC COMMENT PERIOD ON THE
PROPOSED CLEANUP PLAN FOR THE SHURON SITE,
BARNWELL, BARNWELL COUNTY, SOUTH CAROLINA
The U. S. Environmental Protection Agency U extending the public comment period on the Proposed Plan for
the cleanup of the Shuron Superfur.d Site. The ..eminent period has been extended and will end on Wednesday,
February 4,1998. This extension was announced at the public meeting conducted on December 9,1997. EPA
Hill also conduct another public meeting to present the alternatives listed below, and to receive public comments.
EPA encourages nearby residents, local officials and other interested parties to attend this meeting and provide
comments on the preferred alternatives, as well as all alternatives evaluated in the FS.
PUBLIC MEETING:
THURSDAY, JANUARY 22,1998
7:00 P.M.
BARNWELL COUNTY COUNCIL CHAMBERS
BARNWELL COUNTY AGRICULTURAL BUILDING
1603 Peckman, Barnwell, SC
Fourteen alternatives were considered in proposing this action. The figures in parentheses are the estimated
present worth costs for each alternative. The following alternatives were considered:
•
Alternatives for Groundwater Remediation;
Alternative 1: No Action ($1.3 million)
Alternative 2: Source Removal and Groundwater Extraction During the Excavation Period
(S 1.8 million)
Alternative 3: Source Removal with Temporary Groundwater Extraction for Dewatering, Data
Collection/Aquifer Evaluation, Active Groundwater Treatment of Remaining
Contaminated Groundwater, and if applicable, Monitored Natural
Attenuation (S2.4 - SS.O million)
Alternative 4: Groundwater Extraction & Treatment in Source Area (S3.8 - S4.7 million)
Alternative 5: Groundwater Extraction & Treatment Near Property Boundary (S4.6 Million)
Alternatives for Remediation of Soil;
Alternative 1: No Action (SO)
Alternative 2: Limited Action - Institutional Controls (5120,000)
Alternative 3: Excavation and On-Site Capping with No Bottom Liner (S7.7 Million)
Alternative 3A: Excavation and On-Site Capping for All Contaminated Soils (S9.0 Million)
Alternative 3B: Excavation and On-Site Capping with Bottom Liner for RCRA Non-Hazardous
Soil and Off-Site Disposal of RCRA Hazardous Soil (SI 1.2 Million)
Alternative 4: Stabilization/Solidification (SIS) (S10.6 - S203 Million)
Alternative 5: In Situ (In Place) Thermal Treatment Followed by Containment or Stabilization/
Solidification (SI0.0 to S1S.3 Million)
Alternative 6: Low Temperature Thermal Desorption Followed by Containment or
Stabilization/Solidification (S22 - 27 Million)
Alternative 7: Excavation and Off-Site Disposal (SI 1.8 Million)
-------
After conducting a detailed analysis of aU of the alternatives, EPA has a preference for the following alternatives
for soil and groundwater remediation of the Shuron Superfund Site:
Combination of Soil Alternatives 3Bh and 4; All soils exceeding Remediation Goals will be excavated and
dewatered. After this, whatever soils are determined to be RCRA hazardous waste, shall be disposed off-site,
unless through aggressive treatment (SIS and aeration), the soils are determined to no longer be RCRA
hazardous. All soils that are designated as RCRA non-hazardous, may remain on-site. These soils that remain
on-site wiD be aggressively treated by S/S and aeration to reduce the contaminant concentrations, such that the
contaminants do not leach out of the soils above MCLs (drinking water standards). The exact reagents to be used
will be determined from laboratory and pilot scale treatability studies conducted during the Remedial Design
phase to determine the most effective reagent mixture. If, after aggres.
-------
Attachment C
Written Public Comments Received
During the Public Comment Period
-------
ssp
United States
Environmental Protection
Agency
North Site Management Branch
Region 4
61 Forsyth Street, S. W.
Atlanta, Georgia 30303-3104
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-------
COMMENTS OF TEXTRON INC. ON PROPOSED PLAN
FOR THE SHURON SUPERFUND SITE
Textron Inc. ("Textron") submits the following comments
on the United States Environmental Protection Agency's ("EPA's")
Proposed Plan for the Shuron Superfund Site in Barnwell, Barnwell
County, South Carolina. When EPA released the Proposed Plan in
November 1997, it also initiated a public comment period which it
later extended through February 4, 1998. Textron requests EPA's
consideration of these comments prior to EPA's selection of a
remedy and issuance of a Record of Decision.
INTRODUCTION
Textron has been involved in the remedial process at
the Shuron Site since before November 22, 1994, the effective
date of an Administrative Order on Consent with EPA, pursuant to
which Textron performed a Remedial Investigation and Feasibility
Study ("RI/FS") to investigate and to evaluate remedial
alternatives for the Shuron Site. During the course of the
RI/FS, Textron forwarded draft and final submittals,
correspondence and other documentary materials to EPA reflecting
Textron's views on various remedial alternatives and on other
1
-------
WILMER, CUTLER & PICKERING
DANIEL M SOURE
DIRECT LINE 12021 6«3-6OeO
M STREET. N.W.
WASHINGTON. D C 2OO37-I43O
TELEPHONE I2O8I SC3-6OOO
FACSIMILE 12031663-6363
February 3, 1998
IOOUGHT STPEE?
BALTIMORE. MO2I2O2
TELEPHONE l« 101 986-2800
FACSIMILE I*IO' 98e-2B26
« CABLTON CAROCNS
LONDON SWir 5»A
TELEPHONE Oil I«i7i r a7 3.. OOO
FACSIMILE Oil I*«I7I1 833 3537
RUE OE LA LOl 13 WCTSTRAAT
B- IO»O BRUSSELS
TELEPHONE OH 13221 285 *9OO
FACSIMILE Oil I3ZZI 289-49'»
FRlEORICHSTRASSE O5
O-IOII7 BERLIN
TCLEPMONC Oil M93OI 2O22O4OO
FACSIMILE Oil l«»3Ol 2O22-«5OO
VIA OVERNIGHT MAIL
Ms. Sheri L. Panabaker
Remedial Project Manager
U. S. Environmental Protection Agency
Region IV
Gl. Ferny"h Street, S. v7.. W^r-i;^>:3-SC
Atlanta, GA 30303
Re: Proposed Plan for Shuron Superfund Site
Dear Ms. Panabaker:
On behalf of Textron Inc., I am submitting the enclosed
comments on EPA's Proposed Plan for the Shuron Superfund Site in
Barnwell, Barnwell County, South Carolina.
Thank you for your consideration.
Sincerely,
cc: Robert C. Brayley
Gerald B. Benson
Warren J. Lyman
Jamieson M. Schiff, Esq.
-------
any event, it should be applied on a site-wide average basis.
Further, the potential benefits of excavating the wetland
sediments, as the Proposed Plan requires, are outweighed by the
harm to the wetlands. Third, after contaminated soils on-site
are excavated and treated, they should be permitted to be
disposed of on-site using containment measures that are
protective, but without requiring them to meet Subtitle D
landfill criteria.
With respect to groundwater, EPA's proposed remedy also
is deficient. Following source removal and temporary groundwater
extraction for dewatering and during an extended period
thereafter, Textron agrees with EPA that additional data should
be collected to evaluate the presence of residual groundwater
contamination and the potential effectiveness of monitored
natural attenuation as a groundwater remedy. Prior to such an
evaluation, however, EPA's decision to require installation of a
proactive groundwater treatment system is premature.
-------
SPECIFIC COMMENTS pN PROPOSED PLAN
Textron's specific comments on EPA's Proposed Plan for
the Shuron Site are as follows:
I. Issues Relating to the Proposed Remedy for Soils
The Proposed Plan establishes Remedial Goals ("RGs") or
cleanup standards for several contaminants of concern in soils
(including separate RGs for surface and subsurface soils in the
upland areas of the site, and hyciric soils or sediments ia c^e
wetland areas of the site) . All soils exceeding these RGs are to
be excavated and dewatered, treated through stabilization/-
solidification and aeration, and disposed of on-site or off-site.
In addition, following excavation of sediments from the wetlands,
the wetlands must be restored.
Soils that are RCRA hazardous ^vrt. b? dispose:3 cf off-
site. Soils that are RCRA non-hazardous must, at a minimum, be
placed under an engineered cap on-site to prevent direct contact
exposure; but if the soils leach above maximum contaminant levels
("MCLs"), they must be placed in an on-site cell meeting RCRA
Subtitle D landfill criteria. Alternatively, if it is determined
to be more cost-effective, soils that are RCRA non-hazardous may
be sent off-site for disposal.
-------
As explained below, the proposed soil remedy should be
modified in several key respects.
A. Excavation of Upland Areas
Textron agrees with EPA's application of industrial
cleanup standards to the upland areas of the site, but disagrees
with the proposed application of a lead cleanup standard of 1150
mg/kg, which is too low.
1. EPA correctly determined that the site should
be remediated to industrial standards.
Textron agrees with EPA's determination in the Proposed
Plan that the Shuron Site should be remediated to industrial
standards. EPA's determination is consistent with the NCP and
with EPA policy guidance (OSWER Directive 9355.7-04, Land Use
Guidance) requiring consideration of the most likely potential
future land use when selecting cleanup standards. Based on the
historic use of this property, its present and future condition
(regardless of the remedy), and the availability of other
locations in the vicinity for residential use, the most probable
future use of the Shuron Site is industrial.^
The FS Report analyzes remedies based solely on an
(continued...)
-------
The only possible suggestion to the contrary is
reflected in_ eleventh-hour statements from officials of Barnwell
County and the City of Barnwell, following completion of the
RI/FS process, in letters to EPA dated May 13, and May 20, 1997,
respectively, and in more recent statements to EPA, that future
residential use of the site might be appropriate. County and
City officials have left no room for doubt, however, that their
sole objective in this regard is to effectuate the removal of the
former manufacturing building Oil-site. Couuuy and CiLy wiiiiicials
also have indicated they would not oppose the application of
industrial cleanup standards to the portion of the site that is
the subject of the Proposed Plan, if the building were removed
•
from the site. As EPA has explained, however, the building was
not part of the RI/FS process and its fate is irrelevant to the
selection of ? rerr.^dy for rh--» ?=•>>.*».
V (. ..continued)
industrial use scenario. Therefore, if for some reason EPA were
to determine at this late date to apply a residential use
scenario, there would be no basis in the administrative record
for issuing a Record of Decision based on that scenario without
redoing the FS.
-------
2. The lead cleanup standard in surface soils
should be 1500 ma/kg, not 1150 mg/kg.
Although Textron, therefore, agrees with EPA's
application of industrial cleanup standards to the site, it takes
exception with the industrial cleanup standard EPA has proposed
for lead, i.e.. 1150 mg/kg. During the initial stages of the
RI/FS, Textron proposed an industrial cleanup standard of 1500
mg/kg for lead, based on the results of the Baseline Risk
Assessment performed as part of the RI/FS, EPA guidance on lead
exposure, and lead cleanup standards applied at other Superfund
sites. For the reasons reflected in Textron's earlier
submissions to EPA, it continues to believe that an industrial
lead cleanup standard of 1500 mg/kg should be applied at the
/
Shuron Site.
In its December 1995 comments to Textron on the Draft:
RI Report, EPA instructed Textron to apply a lead cleanup
standard of 1300 mg/kg, rather than 1500 mg/kg. EPA based its
cleanup standard on the goal of protecting the most sensitive
worker in the industrial use scenario, a pregnant woman assumed
to be working at the Shuron Site. EPA's assumptions underlying
its calculation of the 1300 mg/kg cleanup standard for lead,
however, were wholly unrealistic and, therefore, overly
-------
conservative.
In particular, EPA assumed that a pregnant woman would
be working outdoors at the site during all nine months of her
pregnancy, and would be working seven days per week; that she
would consume 50 mg of soil per day, all containing 1300 mg/kg
lead, and mostly in bioavailable form; that she would have an
average or above average blood lead level from other, non-site-
related exposures; and that her fetus would be among the top 5
percent of fetuses with regard to xead sensitivity. "me
simultaneous consideration of each of these factors probably
reflects a non-existent subpopulation of pregnant women; at most,
it reflects a very small subpopulation of pregnant women, and an
infinitesimal subpopulation of industrial workers.
Following EPA's calculation of a 1300 mg/kg lead
cleanup standard bnsed on these overly conssrvative ?.s"?urnp^ion9,
and after EPA's approval of the RI/FS which contained the 1300
mg/kg standard, EPA revised its calculation based on new
assumptions regarding the homogeneity of the local population
near the Shuron Site, and the application of more protective
values of two parameters (the geometric standard deviation and
the baseline blood level) to reach an even more conservative
cleanup standard of 1150 mg/kg. This lower cleanup"standard is
-------
even less defensible than the 1300 mg/kg standard previously
mandated byJEPA, especially given that the latter formed the
basis for the evaluation of remedial alternatives contained in
the RI/FS which was approved prior to EPA's recalculation of this
critical cleanup standard.
In short, Textron's proposed cleanup standard of 1500
mg/kg was based on realistic assumptions about the future use of
the site, consistent with the NCP and EPA guidance; EPA's 1300
mg/kg standard, mandated in the RI/FS, was based on overly
conservative assumptions that did not justify that lower cleanup
level; and EPA's further revision of the standard downward to
1150 mg/kg, following completion of the RI/FS, is even less
reflective of the realistic risk associated with the Shuron Site.
3. The cleanup standards in subsurface soils
should be refined during the remedial design.
EPA's Proposed Plan states that the lead cleanup level
in subsurface soils "shall be determined during RD/RA [Remedial
Design/Remedial Action]." Textron does not object to EPA's
decision to defer determination of the lead cleanup level, as
long as the cleanup level is based on leachability criteria
reflecting the potential impact of lead leaching to groundwater,
-------
and not on toxicity criteria. Textron reserves any additional
comments on the lead cleanup level pending EPA's determination
during the remedial design process.
With regard to the cleanup levels for organic
contaminants in subsurface soils, however, EPA likewise should
defer determination of the final cleanup levels pending the
collection of additional data during remedial design. The
cleanup levels that EPA has listed in the Proposed Plan were
based on a relatively limited number of data points. EPA snould
retain the flexibility to collect additional data for the purpose
of defining the cleanup levels for organic contaminants in
subsurface soils more carefully.
B. Excavation of Wetland Areas
Textron disagree? with EPA's determination that
remediation of wetlands sediments is required.. The proposed
application of a lead cleanup standard of 700 mg/kg is too low
and, in any event, should be applied on a site-wide average
basis. Moreover, whatever lead cleanup standard is applied, any
benefits of wetland remediation are outweighed by the harm that
would be caused to the wetlands.
10
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1. The lead cleanup standard in wetland
sediments should be at least 2000 mg/kg, not
700 mg/kg, and should be applied on a site-
wide average basis.
During the RI/FS, a Tier II Baseline Ecological Risk
Assessment ("BERA") was performed at the Shuron Site to determine
whether historical discharges into the forested floodplain east
of the facility pose potential hazards to that wetland habitat or
to the populations of ecological receptors that inhabit or
frequent that system. The BERA was based ori the extensive site
investigation performed during the RI, augmented with a focused
ecological field program that involved the collection of
additional site information on the ecology of the floodplain and
the performance of -empirical studies assessing the impact of
site-related contaminants on key ecological receptors.
Consistent with EPA policy, the BERA reviewed the
impact of site-related contaminants on population and community
endpoints, rather than on individual organism endpoints. EPA
policy provides for the consideration of individual organism
endpoints only where certain designated sensitive organisms
(e.g.. rare, threatened, or endangered species) are present at a
site. Since no such sensitive organisms are known to occur at or
in the immediate vicinity of the Shuron Site, it was appropriate
11
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to assess ecological risks to populations and communities of
ecological receptors.
The BERA indicated that lead is the primary contaminant
of ecological concern in the wetland areas, with concentrations
in sediments ranging from at or near background levels (10 to 36
mg/kg) to a maximum of approximately 10,000 mg/kg. Based on the
results of the empirical laboratory studies, food web exposure
modeling of upper trophic level vertebrate wildlife, and field
reconnaissance by experienced field ecoiogists, it was determir.aci
that historical discharges of site contaminants, in particular
lead, have had little or no substantive, adverse impact on the
forest floodplain wetland ecosystem or on the aquatic ecosystem
of nearby Turkey Creek. Likewise, it was determined that the
populations of ecological receptors inhabiting or frequenting
these wetland areas are not at significant risk from site-related
contaminants. Accordingly, the BERA as originally submitted by
Textron to EPA as part of the Draft RI Report in December 1995
concluded that it was not necessary to develop a remedial goal
objective ("RGO") for addressing ecological risk at the Shuron
Site.
Notwithstanding these conclusions, EPA subsequently
instructed Textron to develop an RGO for addressing lead in
12
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wetland sediments, and in particular, to develop an RGO that
would be protective of invertebrate receptors (i.e.. the lowest
ecological level of receptors) at the site. In accordance with
EPA's instructions, Textron revised portions of the Draft RI and
the Draft FS to develop an RGO for lead in wetland sediments,
which EPA selected as 700 mg/kg in the Proposed Plan. Throughout
the RI/FS process, however, Textron has maintained its position
that the potential site effects on the wetland ecosystem do not
justify active remediation at all, and certainly do not justify
the application of a 700 mg/kg lead cleanup standard.
To summarize Textron's position:
First, it is appropriate to measure the need for
remediation against the impact of site contaminants on the
ecosystem as a whole. From that system-wide ecological
perspective, neither the wetland ecosystem or the nearby aquatic.
ecosystem, nor the populations of ecological receptors therein,
have been significantly impacted by site contaminants to justify
remediation or the development of an RGO.
Second, even if the development of an RGO could be
justified, the preliminary remediation goals ("PRGs") established
for the ecological receptors at the site -- i.e.. avian receptors
(11,900 mg/kg), mammalian receptors (11,000 mg/kg), amphibian
13
-------
receptors (2,000 mg/kg), and invertebrate receptors (700 mg/kg)
-- exceed the existing average lead concentration of 1240 mg/kg
at the site", with the sole exception of invertebrates. It is
more appropriate to base an RGO on the higher levels of
ecological receptors, based on their importance to the food
chain, their mobility, and the greater reliability of the
ecological assessment studies that were performed on them.
Third, to the extent it were appropriate to base an RGO
on the invercebrace receptors, actual sice conditions do r.cz
support a finding that invertebrates will realistically be
subjected to lead levels above 700 mg/kg. The wetland areas with
lead concentrations above 700 mg/kg are generally covered by
organic vegetative mats that limit exposure to mammals,
amphibians and invertebrates to invertebrates. In contrast,
sediment samples used in invertebrate toxicity tests were
collected after the vegetative mat was removed, thus representing
an exposure inconsistent with site conditions. Further, even
apart from the location of contaminated sediments below the
vegetative mat, the existing average lead concentration at the
site is likely to be substantially lower than 1240 mg/kg, because
that figure is based on sampling results from the most
contaminated areas of the site.
14
-------
Fourth, if an RGO were selected for lead in wetland
sediments, it should be applied on a site-wide average basis.
Populations and communities of invertebrates, like other
receptors at the site, are generally exposed to site-wide lead
concentrations, rather than to individual "hot spots."
Consistent with the goal of basing risk management decisions on
criteria protective of populations and communities, not
individual organisms, at the Shuron Site, an RGO of 700 mg/kg or
otherwise for lead should be applied as a site-wide average.
That is, the need for remediation, if any, should be based on
whether the site-wide average lead concentration throughout the
wetland areas falls before the cleanup standard.
The site-wide average, by definition, should be
calculated for the entire wetland area, and not for each isolated
wetland area on-site. Further, it should take into account the
fact, as noted above, that existing wetland soil data reflect an
overly conservative, location-biased sampling plan designed to
take samples where concentrations of contaminants of concern were
expected to be elevated. For example, much of the eastern
portion of the wetland area was not sampled, because it did not
15
-------
appear to be affected by site contaminants.2/
2. The potential benefits of excavating the
wetland sediments are outweighed by the harm
to the wetlands.
For the reasons explained above, the ecological risk
assessment that has been performed at the Shuron Site does not
justify the selection of a lead cleanup standard for wetland
soils. Even if the remediation of wetland soils were otherwise
*' As referenced above, Textron has stated its
position to EPA on these issues throughout the RI/FS process.
For example, in an April 17, 1996 submission to EPA, Textron
explained its objection to EPA's inclination toward selecting a
700 mg/kg lead RGO, for reasons that included the following: the
wetland areas with lead concentrations above 700 mg/kg are
generally covered by organic vegetative mats that limit exposure
to mammals, amphibians and'invertebrates; sediment samples used
in invertebrate toxicity tests were collected after the
vegetative mat was removed, which represented an exposure
inconsistent with site conditions; exposures by mammals and
amphibians are limited due to flooding conuiLions; observations
by trained ecologists have not indicated any reduced population
activity by any species in wetlands at the site; tissue studies
of amphibians collected in the wetlands (which provide a more
realistic assessment of ecological exposure than the other
studies performed) did not indicate bioaccumulation of
unacceptable levels of lead; plant toxicity tests did not
indicate any phototoxicity from sediments in the wetland areas;
and the disruption of the wetlands caused by removing sediments
would create excessive damage. Textron expressly reserved its
right to raise these issues during the public comment period, and
it hereby incorporates its earlier submission into these comments
on the Proposed Plan.
16
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justified, however, the potential benefits of excavating the
wetland sediments are far outweighed by the ecological harm.
Both EPA and the Department of the Interior have
previously acknowledged the need to compare the potential
benefits of wetland remediation with the potential harm to the
wetland. For example, an EPA Science Advisory Board report on
relative ecological risks in 1990 recommended that EPA consider
the relative risks of remedial strategies, particularly as they
relate to natural ecosystem destruction. Thus, habit alteration
may result in greater relative risk to ecological receptor
populations and communities than environmental contamination.
Based on the lack of human health risk from exposure to
wetland soils at the Shuron Site, and the limited adverse
ecological impacts described in the BERA, the potential benefits
of wetland remediation at the site are, at most, relatively
modest. At the same time, however, remediation of lead in the
wetland soils would cause significant ecological impacts from
habitat alteration, including: the destruction of wetland
vegetation; the alteration of wetland hydrology; the alteration
or reduction of wildlife habitat (including food, shelter, over-
wintering, and breeding areas); and the alteration or reduction
of wetlands functions (including flood water storage, surface
17
-------
water purification, sediment pollution absorption, and sediment
load deposition).
Contrary to sound ecological policy and guidance from
within its own agency, EPA in its Proposed Plan does not even
evaluate the impacts of wetland alteration associated with the
proposed remediation. It is difficult to understand the
wholesale absence of such an evaluation, or how it is consistent
with EPA's obligation under the NCP to consider ecological
impacts in the remedial process. In short, even if wetland
remediation otherwise could be justified based on the ecological
risk assessment, which Textron disputes, EPA has not begun to
perform the necessary balancing of potential benefits and risks
associated with wetland alteration.
C. Disposal of Excavated and Treated Soils
Textron agrees with EPA's determination that off-site
disposal of RCRA non-hazardous soils should be permitted if,
during the remedial design and remedial action, it is determined
that off-site disposal would be more cost-effective than on-site
disposal.*/ Textron disagrees, however, with EPA's determination
17 As described in the FS Report, and in subsequent
(continued,
18
-------
that RCRA hazardous soils must be disposed of off-site. Textron
also disagrees with EPA's determination that soils disposed of
on-site must be contained in a cell meeting Subtitle D landfill
criteria.
1. All excavated soils should be allowed to be
disposed of on-site.
For reasons Textron has previously discussed with EPA,
and as explained in the FS Report, Soil Alternative 3 -- which
provides for placement of all excavated soils (i.e.. RCRA
hazardous and non-hazardous soils) under an engineered cap --
protects the environment and is cost-effective. In particular,
under Soil Alternative 3, excavated soils will be placed at least
three feet above the seasonably high water table in the areas
where the cap is to be constructed. Clean fill will be added if
ix {. . .continued)
submissions by Textron to EPA, the estimated costs associated
with off-site disposal are substantially higher than for off-site
disposal. Further, there is a much higher degree of uncertainty
associated with the costs for off-site disposal. Therefore,
unless it is determined during the remedial design and remedial
action that the costs of off-site disposal are lower than
anticipated (based, for example, on the volume and hazardous
component of contaminated soils), on-site disposal is the
preferred option. Textron hereby incorporates its earlier
submissions on costs into these comments on the Proposed Plan.
19
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necessary to create this separation. Initial lifts will be of
metals contaminated soils that are RCRA non-hazardous, and other
soils will be placed in upper lifts where they will be provided
maximum protection from coming in contact with groundwater. The
cap will include a low permeability, flexible membrane liner
("FML") cover layer. In addition, soil vapor extraction ("SVE")
laterals may be placed beneath the cap, through the soils
containing volatile organic compounds ("VOCs"), unless the
limited volume and concentrations of VOCs do not justify SVE or
it is determined during remedial design that SVE would not be
effective.
The design features of this alternative protect the
groundwater against the leaching of contaminated soil by placing
excavated soils well above the water table and by constructing a
engineered cap that significantly limits infiltration of surface
water. Further, in order to confirm the long-term effectiveness
of Soil Alternative 3, modeling of potential leaching effects was
performed using EPA's Hydrologic Evaluation of Leaching Potential
("HELP") model. The results of the modeling, presented in
Appendix E to the FS Report, demonstrated that leaching of soils
beneath the cap will not exceed MCLs in the groundwater. As
described below, following submission of the FS Report, Textron
20
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also responded to each of EPA's stated concerns about the
potential for leaching of site contaminants above MCLs.
In response to this careful technical analysis, EPA's
Proposed Plan states dismissively in one sentence that there is
"high uncertainty" this alternative will be sufficiently
protective, "because of the potential to leach contaminants to
the groundwater above MCLs." Proposed Plan, at 25.4/ EPA does
not explain, however, why the elements of the proposed design
will not reduce that potential to acceptable levels, or why the
HELP modeling does not accurately reflect potential leaching.
Based on uncontroverted information in the administrative record,
there is no legitimate technical basis to preclude the on-site
disposal of RCRA hazardous and non-hazardous soil underneath an
engineered cap.
4/ EPA also dismisses Soil Alternative 3A, which would
provide for the placement of RCRA hazardous and non-hazardous
soils in a containment cell with a bottom liner to provide
additional protection to groundwater, because "there is some
uncertainty as to whether [RCRA] hazardous waste . . . will leach
from the landfill." Proposed Plan, at 25. EPA's decision making
based on a subjective, unsubstantiated view of the various levels
of "uncertainty" is no substitute for sound technical review of
the data and modeling results.
21
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2. Soils that are disposed of on-site need not
be contained in an on-site cell meeting RCRA
Subtitle D landfill criteria.
For the reasons described above, even if RCRA hazardous
and non-hazardous soil- is disposed of on-site, placement of
contaminated soils above the water table and underneath an FML
cap is protective of the environment. Even more clearly, if only
RCRA non-hazardous sc-il is disposed of on-site (consistent with
EPA's Proposed Plan), placement of those soils underneath an
engineered cap is protective.
EPA's Proposed Plan nonetheless adopts Soil Alternative
3B, which requires the placement of RCRA non-hazardous soils that
leach above MCLs in an on-site cell meeting RCRA Subtitle D
landfill criteria. Following approval of the Final FS Report,
EPA expressed several concerns to Textron about the placement of
excavated soils beneath an engineered cap, without meeting RCRA
Subtitle D landfill criteria. These concerns related broadly to
the impact on groundwater of (1) short-term, transient drainage
following placement of the excavated soils, and (2) rainfall-
related leachate generation.
Textron responded to each of these concerns, however,
at a meeting with EPA on August 6, 1997, and in other discussions
and written submissions prior to EPA's issuance of the Proposed
22
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Plan. As explained below, and again based on uncontroverted
information in the administrative record, there is no legitimate
technical basis to require the construction of an on-site
containment cell meeting Subtitle D landfill criteria.
First. with respect to impact of short-term, transient
drainage, EPA had explained its concern that if contaminated
soils from the saturated zone were excavated and placed directly
beneath a cap without removing any of the water in the soil
pores, then excessive amounts of water would drain from the soils
to groundwater during the initial weeks to months and would
potentially exceed MCLs. In connection with that concern, EPA
also stated that Textron had failed to demonstrate in the Final
FS Report the effectiveness of the soil drying that would occur
prior to placement of the soils under the cap in Alternatives 3,
3A and 3B.
In fact, however, dewatering of soil with lime or other
chemical agents is a well-established remedial process.a/ It is
more appropriate to conduct a site-specific treatability test
5/ For example, documentation of the demonstrated nature
of drying operations for soils can be found in EPA's technical
resource document, Solidification/Stabilization and its
Application to Waste Materials, Report No. EPA/530/R-93/012, June
1993.
23
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(i.e. . to select the best chemical agent and optimum dosage) in
the remedial design phase, rather than during the FS process.
Further, it is reasonable to assume for FS purposes that a drying
operation for the soils at the Shuron Site can be implemented to
essentially eliminate all moisture above the field capacity of
the soil (i.e. , any free water that would otherwise drain out of
the soil) .&/ Indeed, even before any chemical drying of the
soils, much of the free water in soils from the saturated zone
may be removed via soil dewatering in the areas to be excavated;
natural drainage during the excavation process; and drainage
during temporary stockpiling of the soils on a construction pad
with controlled drainage.
Given all of these factors, there is only a remote
likelihood of any significant drainage of residual pore water
following the on-site placement of soils excavated and dried at
the Shuron Site. In contrast, EPA's concern about transient
&/ EPA has estimated that the field capacities of the
soils at the Shuron Site range from .22 to .378 (i.e. , 22% to
37.8% by volume). W. O'Steen Memorandum to S. Panabaker, Re:
Review of HELP Analysis of Soil Remedial Alternative 3, Shuron
Site, Barnwell, South Carolina (July 2, 1997) . It should only be
necessary to reduce the moisture content of the soils below those
volume percentages to reach a condition that will result in no
soil drainage. A well-operated drying operation with adequate
mixing should be able to reduce the moisture content well below
these levels.
24
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drainage is based on an assumption (in EPA's own modeling
analysis) that there will be no drying of the soils prior to
placement in the on-site containment areas. That basic premise
of EPA's modeling analysis is wrong.27 Likewise, EPA's concern
about the need to consider the effect of site-specific conditions
(e.g.. the use of three separate containment areas) and soil
emplacement scenarios (e.g.. the non-uniform mixing or layering
of wastes) is misplaced, because those issues become a factor
only under the incorrect assumption that the soils will be placed
without draining or drying.fi/
Moreover, even under the most unlikely circumstances,
11 To account for this critical deficiency, EPA has noted
that, even if the amount of projected transient drainage (based
on EPA's modeling analysis) were reduced by a factor of ten (10),
some MCL exceedances for the contaminants DCE and TCE were
predicted. In fact, however, this reduction by a factor of ten
(10) does not adequately reflect the effect of the drying
process. For example, application of EPA's reduction factor to
the soils in the fill/debris areas of the Shuron Site would
reduce the moisture content from 46.3% to 25.5%. This is an
unreasonably low drying efficiency to assume from site
dewatering, and soil excavation, stockpiling and drying.
Further, the drying process does not need to reach zero moisture
to eliminate drainage; it has only to reach the field capacity
(23.2% in the example provided).
47 In addition, even EPA's modeling analysis concluded
that the total transient drainage from beneath the capped areas
is roughly the same, regardless of the soil emplacement scenario.
25
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if there were some measurable transient drainage following
placement of excavated soils, this would lead only to a brief
extension of the time during which certain contaminants in the
groundwater exceed MCLs in certain locations. Any time extension
would be on the order of a few weeks to a few months -- compared
to the lengthy period of years during which the groundwater has
already been impacted by site contaminants and will continue to
be impacted in the future. The incremental impacts of transient
drainage, if any, would be negligible.
Second. EPA also had expressed its concern about the
possible impact of rainfall-related leachate generation on
groundwater. In response, however, Textron used a combination of
laboratory data and modeling to show that any such leaching would
not cause MCLs to be exceeded outside of a reasonable mixing
zone. The basic approach and modeling tools used in this
analysis were the same as EPA used in analyzing the impact of
transient drainage: the HELP model to predict the amount of
water that will infiltrate soil and migrate to groundwater; and
the Summers model to estimate the resulting concentrations of
site contaminants in the groundwater after a reasonable amount of
local dilution.
Textron's model calculations assumed an overly
26
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conservative leakage of rainfall through the cap covering the
contaminated soils, higher than that which would be expected from
a properly installed and maintained cap. Nevertheless, EPA
expressed a concern about Textron's evaluation of rainfall-
related leachate generation based on modeling results, without
actual treatability data. As explained above, however, it is
more appropriate to conduct a site-specific treatability test (or
a bench or pilot scale demonstration) in the remedial design
phase. Further, if EPA deemed it necessary, it could expressly
require treatability studies or establish performance criteria in
the selected remedy.
EPA also expressed a concern that the use of average
concentrations of soil contaminants, rather than maximum
concentrations, to estimate initial leachate concentrations in
the model calculations was not sufficiently conservative. In
fact, however, the model calculations in the Final FS Report used
"average" contaminant concentrations that were biased high by the
exclusion of values below the Remedial Goal Objectives for each
contaminant. Accordingly, these "averages" were higher than the
actual average concentrations of contaminants to be disposed of
on-site. Further, the commingling of contaminated soils, the
commingling of leachate from different areas of contaminated
27
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soils, and the•subsequent mixing with the groundwater, will
average out any peaks in the leachate concentrations .2/ For all
of these reasons, the use of average concentrations of soil
contaminants is the most reasonable approach.w
II. Issues Relating to the Proposed Remedy for Groundwater
The Proposed Plan requires the removal of contaminated
soils from contact with the groundwater, and the use of a
temporary groundwater recovery and treatment system for
dewatering purposes during the source removal and for an
additional four to six months thereafter. The proposed remedy
also includes an evaluation period for gathering data to design a
proactive groundwater treatment system (pump and treat,
recirculation wells, air-sparging, or a combination). If, during
the evaluation period, monitored natural attenuation can be
demonstrated to be as effective as active remediation, within a
comparable time frame, then that approach will be applied to the
appropriate portions of the contaminated groundwater plume.
2/ Textron explained these points in a letter to EPA dated
June 6, 1997. Textron hereby incorporates its earlier submission
into these comments on the Proposed Plan.
i£/ Indeed, EPA's own model calculations used average
concentrations of soil contaminants, which were also biased high.
28
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Certain aspects of the groundwater remedy -- i.e.,
source removal, the use of a groundwater treatment system for
dewatering and for an additional period of several months, and
the evaluation of groundwater conditions following these
activities -- are reasonable. As explained below, however, EPA's
decision to design and install a proactive groundwater treatment
system prior to completion of the groundwater evaluation has no
support in the administrative record.
In particular, a proactive groundwater treatment system
cannot be justified at this juncture, because: (1) there is no
current use and there is no reasonably foreseeable future use of
site groundwater for human purposes; (2) there is no evidence of
off-site migration of the groundwater contamination plume; (3)
the source removal and temporary groundwater treatment will
significantly improve groundwater conditions; and (4) following
those activities, it is anticipated that natural attenuation will
dissipate any remaining groundwater contamination over a
reasonable time frame.
To summarize Textron's position:
First. there is no realistic exposure to human
receptors from the groundwater contamination plume on the Shuron
Site. There are no water supply wells on-site, and the closest
29
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water supply wells are a City of Barnwell well upgradient of the
site and only one private well within one-half mile of the site.
Further, based on the availability of municipal water in the
area, and the industrial character of the site, there would be
little or no incentive for a future site owner or tenant to
install an on-site well for any purpose.
Hydrogeological limitations at the Shuron Site also
would discourage installation of an on-site well. As explained
in the RI Report, pump test data indicate that the aquifer
underlying the site has a relatively low yield and would not be
very productive.
Likewise, institutional controls, present or future,
would restrict groundwater use at the site. Based on information
from the City of Barnwell, Textron believes that groundwater
extraction from the site may already be restricted by local
ordinance. In any event, EPA's proposed remedy provides for the
imposition of deed restrictions and well permit restrictions that
would preclude groundwater use.
Second, there is no evidence that the groundwater
contamination plume is migrating off-site. The only potential
indication to the contrary is reflected in questionable data from
two shallow monitoring wells, MW-245 and MW-247, on the southern
30
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side of the site, which show only low parts-per-billion
concentrations of a few VOCs. A second sampling of one of those
wells, however, showed no detectable level of VOCs, and data from
intermediate and deep groundwater wells show no evidence of any
off-site migration.
In addition, hydrogeological data for the site indicate
that most of the shallow groundwater, especially in areas with
VOC contamination, discharges to the wetlands or to the southern
drainage ditch (where the VOCs volatilize) and will not be
transported to off-site areas south of the old railroad bed. The
hydrogeological data also indicate that significant portions of
the intermediate and deep groundwater also may discharge to the
southern drainage ditch. These hydrogeological data undermine
any suggestion that an appreciable portion of the groundwater
contamination plume, if any, is migrating off-site.
Moreover, even if there were a legitimate issue whether
off-site migration were occurring, based on the limited available
data, those limited data are far from sufficient to be the basis
for a major decision on groundwater remediation. Essentially all
of the available groundwater data result from one or two sampling
rounds in the summer of 1995. The concentrations of groundwater
contaminants and the groundwater flow regime could change
31
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significantly over time, and from season to season. Absent
additional data, certainly, EPA should not be selecting an
extensive, proactive groundwater remediation system that may have
little, if any, marginal benefit.^
Third, there is very strong reason to expect that the
proposed remedial actions other than proactive groundwater
remediation will have a very positive impact on groundwater
quality at the site. Groundwater quality will benefit both from
the removal and containment of source material (i.e.. the
contaminated soils that would otherwise continue to leach
contaminants into the groundwater) and the temporary groundwater
system for dewatering activities and-additional treatment.
Soils contaminated with VOCs are acting as an active
source of groundwater contamination. Based on available data, a
majority of these soils may be located below the water table,
n-x Likewise, even if additional data were to show a
marginal off-site impact, that would not necessarily justify a
proactive groundwater remediation system. An evaluation of
groundwater remedial alternatives (including the use of natural
attenuation) must balance several NCP criteria, including the
risks associated with any off-site migration, and the likely
effectiveness and costs of the various alternatives. Especially
at the Shuron Site, where any off-site migration would likely
affect, at most, a small area of a downgradient wetland area
whose groundwater is not being used, any evidence of off-site
migration should not be dispositive.
32
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within the shallow aquifer. Excavation and removal of these
soils, therefore, will have a significant beneficial impact on
groundwater conditions. Further, the dewatering activities,
which are a necessary adjunct to source removal, will result in a
major, additional reduction in the mass of contaminants in
groundwater. The proposed remedy provides for an extensive,
dewatering wellpoint system (with an estimated 63 wellpoints) to
dewater the source areas during excavation and for a period of
four to six months thereafter.
Textron has previously submitted to EPA estimates of
the reduction of mass contaminants in groundwater from source
removal and dewatering activities, and model calculations showing
that the potential for off-site contaminant migration will
thereby be substantially reduced. Absent actual field data
following source removal and dewatering, it is difficult to
quantify the beneficial effects of these activities. Based on
the expected, substantial improvement in groundwater quality,
however, EPA should not decide the need for a proactive
groundwater system without the benefit of additional data.
Fourth, active groundwater remediation is not necessary
at the Shuron Site unless natural attenuation, properly monitored
over a sufficient period of time, is determined to be
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substantially less effective. The movement in groundwater of
VOCs, the only site-related contaminants that have any
significant potential for off-site migration, is attenuated via a
combination of soil sorption and biodegradation. Given
sufficient time and favorable natural conditions, these
attenuation mechanisms can reduce contaminant concentrations in
groundwater by orders of magnitude.
At the Shuron Site, there is no question that
attenuation mechanisms are operative. For example, the RI Report
contains data showing the extent of soil sorption.^ It also
contains evidence of biodegradation based on the presence of
biodegradation products of various VOCs in the groundwater (e.g..
dichloroethylene and vinyl chloride as breakdown products of
trichloroethylene and tetrachloroethylene). Model calculations
also indicate that natural attenuation mechanisms may be of
a' An aspect of soil sorption that is not documented in
the RI Report is contaminant sequestration (i.e.. permanent
sorption) in the soils. Recent studies have shown that
significant fractions of sorbed contaminants are essentially
permanently bound to the soils and are not easily, if at all,
released to the surrounding groundwater. The extent of such
sequestration likely increases with time. References for this
phenomenon include: Pignatello, J.J. and B. Xing, "Mechanisms of
Slow Sorption of Organic Chemicals to Natural Particles,"
Environ. Sci . Technol. 30(1): 1-11 (1996); Linz, D.G. and O.K.
Nakles, Environmentally Acceptable Endpoints in Soil. American
Academy of Environmental Engineers, Annapolis, MD (1997).
34
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comparable effectiveness as proactive groundwater remediation.
Additional evaluation of the natural attenuation remedy
before selecting a proactive groundwater remedy is also directly
supported by EPA's new guidance document on the subject.1^ The
policy document explains that natural attenuation is particularly
appropriate in conjunction with source control and removal
activities, and where the groundwater contamination plume is not
expanding and the risks to human and ecological receptors are
acceptable.^ Further, the impacts of any ongoing or proposed
remediation "should be factored into the analysis of natural
attenuation's effectiveness;" and with regard to chlorinated
solvents, in particular, "the potential for cutting off sources
of organic carbon (which are critical to biodegradation of the
solvents) should be carefully evaluated."^' Generally, a
decision to employ monitored natural attenuation "should be
thoroughly and adequately supported with site-specific
Ai/ Use of Monitored Natural Attenuation at Superfund, RCRA
Correction Action, and Underground Storage Tank Sites, OSWER
Directive 9200.4-17 (November 1997).
& Id. at 13, 15.
& Id. at 12.
35
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characterization data and analysis."^
Each of these considerations under EPA's new policy
document favors more active evaluation of monitored natural
attenuation as the groundwater remedy at the Shuron Site.
Especially in light of the proposed source removal and dewatering
activities, which will enhance natural attenuation by
significantly lowering the strength of the source, EPA should
defer a decision on the need for proactive groundwater
remediation until after the completion of the soils remedy and
the collection of additional groundwater data. At that time, EPA
will be in a better position to compare the effectiveness of
alternative groundwater remedies, including their remediation
time frames -- which EPA's policy document emphasizes127 and which
EPA's Proposed Plan also notes as a critical issue.
Indeed, EPA acknowledges in its Proposed Plan that,
following the soils remedy, monitored natural attenuation may be
demonstrated to be as effective as active remediation, within a
comparable time frame. If the collection of additional data may
soon demonstrate a preference for natural attenuation, however,
Id. at 10-11.
Id. at 15-16.
36
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the selection of a proactive system now cannot possibly be
justified. The need for additional data for sound decision
making outweighs any administrative convenience associated with
selecting a remedy prematurely.
CONCLUSION
Although EPA's Proposed Plan contains several
reasonable components, it nonetheless requires modification to be
consistent with the NCP, to find support in the administrative
record, and to reflect rational remedial decision making.
\
As explained in detail above, the proposed soils remedy
should be modified to increase the cleanup level for lead in
surface soils, and to allow for refinement of cleanup levels in
subsurface soils during remedial design; to avoid remediation of
wetland sediments, or at least to reduce the area of remediation
by increasing the cleanup standard for lead and applying it on a
site-wide average basis; and to permit disposal of all
contaminated soils in an on-site containment area that is
protective of the environment, but is not required to meet
Subtitle D landfill criteria. The proposed groundwater remedy
should be modified to defer a decision on the need for proactive
groundwater remediation until after the implementation of source
37
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removal and dewatering activities, so that additional data can be
collected to evaluate the improvement in groundwater conditions
and the potential effectiveness of monitored natural attenuation.
Textron respectfully submits these comments to EPA for
its consideration.
38
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Attachment D
Official Transcripts of the Proposed Plan Public Meetings
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SHURON SUPERFUND SITE PROPOSED PLAN MEETING
before Alice D. Boni, Court Reporter
held at the Barnwell County Council Chambers
Barnwell, South Carolina
on Tuesday the 9th day of December 1997
commencing at 7:00 p.m.
FOR THE EPA:
FOR S.C. DHEC:
FOR U.S. AGENCY FOR
TOXIC SUBSTANCES AND
DISEASE REGISTRY:
APPEARANCES
Sheri Panabaker
Jan Rogers
Cynthia Peurifoy
Kevin Koporec
Ralph Howard
Gary Stewart
Yanqing Mo
Eric Melaro
AIKEN REPORTING SERVICE, INC.
Post Office Box 2474
Aiken, South Carolina 29802-2474
(803) 648-9434
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PROPOSED PLAN MEETING - DECEMBER 9, 1997
1 MS. PEURIFOY: Good evening, everybody. My
2 name is Cynthia Peurifoy. I'm with the Environmental
3 Protection Agency in Atlanta, Georgia, the Superfund
4 Program, and I'd like to welcome you this evening for the
5 Proposed Plant Meeting for the Shuron site that's located
6 here in Barnwell County, South Carolina.
7 I'd like to start off by thanking the
officials of Barnwell County, Mr. Gripp and the County
Ccaiicil, for allowing us to have t^2 rraeting here tonirht
10 and helping us in making all the arrangements necessary
11 for this meeting.
12 And I'd also like to do some
13 introductions. First of all, I'll start off with all the
14 individuals that are here from EPA. First of all, we
15 have Sheri Panabaker, who is the Remedial Project Manager
16 for the site. She's going to be speaking to you quite a
17 bit this evening. We also have Jan Rogers, who's the
18 Chief of the South Carolina section of the Superfund
19 Program in Atlanta. We also have Ralph Howard here,
20 who's another Project Manager who's assisted on this
21 site. We have Kevin Koporec who is from our Risk
22 Assessment Office, who's also going to be speaking to you
2 3 tonight.
24 From the South Carolina Department of
25 Health and Environmental Control, Gary Stewart is here;
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AIKEN REPORTING SERVICE, INC.
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PROPOSED PLAN MEETING - DECEMBER 9, 1997
1 he^s the Chief of the South Carolina section of the
2 Superfund Program. And also Yanqing Mo is here, who's a
3 hydrologist for the State. And also Eric Melaro, who is
4 with the Health Hazard Evaluation Section of DHEC.
5 Did I miss anybody?
6 MR. HOWARD: That's all.
7 MS. PEURIFOY: Okay. Now, as you see, we have
8 quite a full agenda tonight, so we're not going to spend
9 too much time. I just wanted to go over a few things
10 with you.
11 First of all, I'm going to talk a little
12 bit about the Superfund process, and just to say, as you
13 can see, we've done quite a bit so far on the Superfund
14 process on this site. The site is on the National
15 Priorities List. We've done the remedial investigation
16 and feasibility study, and we're now, which is block five
17 here, we're at the public comment period to gather
18 comments on what has transpired so far on this site.
19 After that, I'm going to go a little
20 later, but you can see there are some other steps, but
21 after Sheri's presentation, I'm going to talk a little
22 bit about what happens next after tonight's meeting.
23 I wanted to go over a few community
24 relations highlights with you, and I'm going to start off
25 with something that I think is really important to talk
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AIKEN REPORTING SERVICE, INC.
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PROPOSED PLAN MEETING - DECEMBER 9, 1997
1 about. It's the Technical Assistance Grants Program.
2 It's a program that EPA established to give communities
3 an opportunity to have a technical advisor available to
4 help you go through all those volumes of information that
5 we produce in evaluating and coming up with alternatives
6 to clean up the site.
7 It's a $50,000 grant. You have to do a
8 20 percent match, but you can do that through in-kind
9 services, donations, things o£ I: •?..':. v!.-_Li..z-i. " You must
10 prepare a plan. You have to have a written plan, but we
11 can help you with that if you want to apply. We can help
12 you with the plan. It just kind of shows what you're
13 going to do with the funds and how you plan to address
14 other community concerns, bring the larger community into
15 the fold.
16 You can also hire what we call a grant
17 administrator who handles all your paperwork, sends in
18 the reports that EPA has to have whenever we give out a
19 grant of this nature.
20 You cannot use a TAG grant to develop
21 information regarding a lawsuit, and you cannot use a TAG
22 grant to do your own sampling of the Superfund site. The
23 group must be incorporated and must be non-profit, and
24 must represent people who live near the site.
25 I also wanted to cover with you that we
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V
PROPOSED PLAN MEETING - DECEMBER 9, 1997
1 have an information repository set up for this site here
2 in Barnwell at the Barnwell Library on Hagood Avenue.
3 That is a file that contains all the documents that were
4 put together on the remedial investigation and
5 feasibility study, and many other documents that make up
6 what EPA used in making this decision to propose the
7 alternatives that we're going to be talking about
8 tonight.
9 I also want to mention to you that we've
10 already extended, have a request and we have extended the
11 public comment period. Right now, it will end February
12 4th. We have also been asked by Mr. Gripp to do an
13 additional meeting to gather additional community
14 comments, and we do plan to do that also sometime—I
15 think it's going to be sometime mid to late January, but
16 we'll get a date.
17 If you haven't gotten anything in the
18 mail from us directly, if you pick up a facts sheet
19 tonight, there's a—if you didn't, there's some outside.
20 If you would fill out the little block on the back page
21 that talks about the mailing list for the site and give
22 it to me before tonight is over, I will make sure you get
23 on our mailing list and we'll get that out to you so
24 you'll be notified of the next meeting.
25 I think, with that, I just want to set
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PROPOSED PLAN MEETING - DECEMBER 9, 1997
1 th« stage for tonight's meeting. We do have a lot of
2 information to cover. We're going to ask you to not
3 necessarily don't ask questions until the end, but if you
4 have something that you need clarification on during the
5 presentation, then we don't mind those type of questions,
6 but if you have comments about the proposed plan, itself,
7 or just general statements you'd like to make on the
8 record, if you'll wait until the presentations are over,
5 that would help us a lot to keep thir.gr moving.
10 And I think that's it. I think I will
11 turn it over to Ms. Panabaker.
12 MS. PANABAKER: Thanks, Cynthia. Hopefully,
13 all of you have got an agenda. She had it up on the
14 overhead a minute ago, the questions I want to mention
15 tonight as I go through my presentation. I'm going to
16 give a little site history, followed by the sampling that
17 we did and the results that we found, followed by the—
18 you can't hear me. Is this any better?
19 Anyway, we'll go through the sampling
20 we've conducted and the results that we've gotten from
21 that; the risks posed by the site, which is not a current
22 risk. There's not a current risk to nearby residents,
23 but there is a future risk. This will be followed up by
24 the various ways we looked at to clean up the site and
25 then the way EPA thinks is the best way to clean up the
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1 site and why we think so, and then I'll open it up for
2 questions.
3 The site is located at 100 Clinton Street
4 and it consists of one main building of about 180,000
5 square feet. There's a fence around most of the
6 building, or around the building, and also down through
7 the wetlands quite a ways.
8 There was a removal action done inside
9 the building in 1994, in which drums were removed that
10 had been left by Shuron, Inc.
11 The facility began operations in about
12 1958 and operated until around 1992. Textron owned it
13 from around '58 to 1985, and then it was sold to Shuron,
14 Inc., who operated it until bankruptcy in '91/'92. They
15 manufactured eyeglass lenses and some frames and used
16 grinding and polishing compounds which were discharged
17 into—were put into a wastewater treatment plant and
18 discharged into four wastewater lagoons out back. When
19 the lagoons would get filled, they would—the solids
20 would be removed and placed into what are called solid
21 ponds. The wastewater, itself, was discharged through an
22 MPDS permit towards Turkey Creek.
23 The site was final on the National
24 Priorities List in December of 1996. However, we got an
25 early action started on this project in November of 1994
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1 with—between Textron and EPA for Textron to do the
2 remedial investigation and feasibility study. An order
3 was signed in 1994. EPA did oversight of the work done
4 by Textron.
5 The first phase of that work was to go
6 out and collect surface soil, subsurface soil, sediment
7 and surface water and groundwater samples to determine
8 contamination. We collected samples and determined that
9 there vus approximately seven or sirjht volatile organics
10 located in the soils and the groundwater. In the soils
11 was four metals; lead, copper, arsenic, and zinc.
12 This chart shows you the maximum
13 concentrations that we found of each of the individual
14 contaminants, of the main contaminants that were found
15 out there. The top right chart also shows the comparison
16 of what was in the groundwater to the drinking water
17 standards.
18 We also learned that a lot of the soils
19 are clay and saturated where the contamination is.
20 That's the result of subsurface samples. Subsurface
21 samples are anything one foot or greater below land
22 surface.
23 The next figure shows the areas that we
24 found soil contamination. Those are the main areas. The
25 upper top right corner is what we're calling the north
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1 drainage ditch, which is where the wastewater was
2 discharged, in that direction. The top four lagoons are
3 the four wastewater lagoons, and the two underneath it
4 are the solid ponds. Contamination was also found out in
5 the southern wetlands, or what we're calling the southern
6 wetlands, which is the lower half of this figure.
7 The next figure shows where we found
8 groundwater contamination. Clinton Street is to the
9 left. We also sampled the City well and it did not show
10 any site contamination in it.
11 Once we collect samples, we then do
12 what's called a baseline risk assessment which serves as
13 determining if there's any current or future risk posed
14 by the contamination at the site. And at this time, I'd
15 like Kevin to come up and tell you a little bit about
16 that.
17 MR. KOPOREC: The risk assessment process is
18 one of the tools that EPA—can you hear me all right from
19 here? I've got a pretty loud voice. Risk assessment is
20 just one tool that EPA uses to determine the need for
21 cleanup and also the amount of cleanup that needs to be
22 done as far as chemical specific levels at a given site.
23 And here's just a little schematic which shows you the
24 risk assessment process.
25 Where we start off La identifying the
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1 hazard, which is basically what Sheri has been talking
2 about; looking at the different chemicals that we find on
3 the site and all the different media, and determining
4 what's there that could be a problem, as far as a risk
5 goes; as far as what we know about toxicity and cancer-
6 causing agents.
7 What we do then is we calculate an
8 exposure assessment where we look at different scenarios
9 where people could be exposed either in a—both in a
10 current scenario, what's going on now at the site, and
11 what could happen in the future at the site, if it stays
12 as it is now.
13 Then we put that together with the
14 toxicity information that we have about the different
15 chemicals from the site, what's called a dose-response
16 assessment. And putting those two things together, we
17 come up with a risk, what we call risk characterization,
18 which basically the risk—the risk numbers that you
19 probably heard about, one in a million, one in ten
20 thousand, those types of risks that we use to describe
21 cancer risk, and we have other numbers we use to describe
22 non-cancer risk.
23 As far as the different scenarios, I
24 don't have any site specific things here, but if you want
25 to, you could look in your—if you want to look in your
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1 proposed plan fact sheet on page nine and ten, you don't
2 need to spend time with it now, but if you want to look
3 at it later, that goes into a lot more detail as far as
4 the risks that were calculated for the site, and I'll be
5 glad to answer any specific questions you have, too,
6 tonight, but I'm just going to be pretty brief now.
7 But basically what we did for this site
8 is we decided that—we looked at the current use of the
9 site and, of course, it's an inactive site, so the
10 current scenario that we have would be—would be someone
11 trespassing on this site and getting incidental exposure
12 to soil and surface water and sediment that way.
13 And then, for the future, we looked at
14 someone potentially working on the site, it becoming an
15 active facility again and someone working there and being
16 exposed to those same media, as well as groundwater,
17 thinking that a future facility could put a groundwater
18 well in and then the future workers could drink that
19 water while they're at work.
20 And then we also had to be protective,
21 since there's a lot of residences near the site, we also
22 looked at the potential that someone could live on the
23 site in the future. And, of course, from a realistic
24 standpoint, if someone was to live on the site, then the
25 site would have to go through a lot of changes; you know,
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1 the ponds, the former ponds being filled in, and changes
2 in grade and all that. So, certainly some changes would
3 happen at the site if that happened. But what we assumed
4 for the risk assessment, kind of a worse case, is if the
5 site stays as it is and someone lived there and had
6 regular exposure to the site.
7 And what we found when we looked at these
8 different scenarios, as Sheri alluded to earlier, for the
9 current scenario, where you just had someone trespassing
10 on the site on an infrequent, but regular basis, the risk
11 from that scenario was deemed by EPA to be acceptable; in
12 other words, there wasn't any more than a ten to the
13 minus six, or one in a million risk for cancer in point,
14 and for the non-cancer causing chemicals, we didn't see
15 any problem with the calculated exposure to any of those
16 either.
17 Then we looked at the future scenarios
18 where we had—let me just look specifics up here. But
19 then we looked at the future scenarios where we would
20 have someone working on the site, and then we had someone
21 living on the site, potentially; and also, a construction
22 worker, where that would give the person exposure to the
23 subsurface soil where the other receptors wouldn't get
24 that exposure. And for, both, the worker and the future
25 resident, we did have an unacceptable risk, and that was
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1 based on primarily/ if not totally, on potential
2 consumption of the groundwater, thinking that a resident
3 or a worker, in either case, they're going to be
4 consuming that groundwater every day, like, for 25 years
5 for a worker and for 30 years for a resident, and that
6 the levels of compounds, levels of volatile organics in
7 that groundwater would cause them to have a risk that EPA
8 deems to be unacceptable; that was greater than one in
9 ten thousand, basically, is what we determined for that.
10 And also, the other chemical which gave
11 an unacceptable risk for both of those scenarios was lead
12 in the soil. There is some real high levels of lead in
13 certain areas of the site, and if a person had regular
14 exposure to that lead, both for a worker—
15 And what we do for lead is a little bit
16 different. We have a way to assess lead—well, for the
17 resident, where we look at potential blood lead levels,
18 that's really what we're concerned about, and effects on
19 central nervous system of lead to the young child, and
20 for the resident, we determined, basically, that it's
21 about 400 parts per million that a resident should not be
22 exposed to, as far as somebody having lead right in their
23 yard. Which, of course, is not the case at the site
24 right now. That was just a hypothetical scenario.
25 And also, for the future worker, what we
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1 assume there is to get at a sensitive receptor. We look
2 at a woman who's working on site who becomes pregnant and
3 then they have exposure to the fetus while they're
4 working at the site on a regular basis, again; you know,
5 a five-day-a-week job for, you know, several months at
6 least. And for both of those scenarios, the risks from
7 lead were deemed to be unacceptable also, for a person
8 that has regular exposure to, you know, the worst areas
9 of the site where the high levels of lead are.
10 And from those scenarios, or, you know,
11 from all that risk assessment work, then we came up with
12 risk base levels to clean up to, which I guess Sheri is
13 going to talk about now. You want to talk about those?
14 MS. PANABAKER: If you're done.
15 MR. KOPOREC: Yes, I am.
16 MS. PANABAKER: One other point that we look at
17 in the risk assessment also is exposures and risks to
18 ecological receptors, and we—the toxicity testing at the
19 site for the contaminated sediments in the wetlands, and
20 determined there was a. risk to ecological receptors.
21 As Kevin was talking about the remedial
22 roles which are into cleanup numbers, those are
23 determined based on Federal and State laws, as well as
24 the risk assessment, and as he said, there was a risk to
25 a future industrial worker from lead above 1150 to a
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1 worker who was exposed to those soils all day long.
2 ~ The subsurface soil numbers were derived
3 from protection of groundwater, what concentration could
4 be in the soils that no longer leaches above the
5 groundwater—excuse me, drinking water standards. And
6 groundwater pretty much came from the drinking water
7 regulations.
8 Table II, which is in your facts sheet
9 and up here, the first half of it anyway, shows the
10 groundwater and the protection of groundwater remedial
11 goals. We used the future industrial scenario because
12 there's 180,000 square foot building on the property and
13 it's surrounded on two sides by wetlands, and also, when
14 we had come back here earlier, when we were up here
15 earlier a year or two ago, we had talked to residents who
16 expressed a great interest in a facility coming back out
17 there and starting up another company so they could, of
18 course, get jobs and stuff.
19 Again, those are the cleanup numbers for
20 surface soils and for—one other point I forgot; in the
21 south wetlands, that—we did not use a future industrial
22 or residential scenario, we were protecting the
23 ecological receptors, since it is a wetlands, and this
24 bottom part of the chart shows the numbers that EPA
25 believes to be protective of the ecological receptors.
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1 - The figures that you saw earlier, two and
2 three, showing the areas of soil contamination and
3 groundwater contamination are the areas we believe need
4 to be remediated and addressed based on those cleanup
5 numbers.
6 Once EPA comes up with cleanup numbers,
7 we then look at different ways to address the various
8 soil and groundwater contamination, and when we come up
9 with them, we compare them to nine criteria. The first
10 two of the criteria are called threshold criteria, and
11 it's overall protection of human health in the
12 environment and compliance with applicable or relevant
13 and appropriate requirements. These are other Federal
14 and State laws.
15 For an alternative to be considered in
16 the feasibility study report, they have to meet these
17 first two threshold criteria. Now, there are two
18 exceptions that we usually have in our reports. One is
19 called no action, and which the site would be left as is
20 and nothing done, and this is required to be in our
21 reports as a baseline, serve as a baseline for comparing
22 the other alternatives to. And the other one we usually
23 have is one called—well, it's up here as limited action,
24 but it's insufficient controls where we would put a fence
25 and signs up and a notation on the deed to let future
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1 owners know that there is contamination already on the
2 site. But neither of them would involve a cleanup of any
3 sort.
4 The next two criteria are called primary
5 balancing criteria, and once alternatives meet the first
6 two, they're compared against each other with these other
7 five. They are long-term effectiveness and permanence,
8 reduction in the toxicity mobility and volume of the
9 contaminants through treatment, short-term effectiveness,
10 which is what's the short-term risk to nearby residents,
11 et cetera, and workers while implementing the
12 alternative.
13 The next one is how insurmountable it is;
14 is it easy to do, is it going to be difficult, are there
15 things at this site that would make one alternative
16 harder than another. And the other one we look at, of
17 course, is cost. After that, we look at what's called
18 the modifying criteria, and these are State and community
19 acceptances of the alternatives.
20 Explaining the no-action and limited
21 action alternatives, we have nine soil alternatives that
22 we've looked at and three other groundwater. I'm going
23 to go through the groundwaters first because they're a
24 little bit shorter than the soil numbers.
25 And I'm going to start with alternative
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1 number four; source removal with dewatering in the source
2 area with extraction wells or trenches. During the
3 removal of the contaminated source, if it's in the
4 wetlands, we would be doing dewatering, but this
5 alternative mainly would be where we place either
6 extraction wells or trenches around the main source area,
7 and that's south of the solid ponds number two and south
8 of those four wastewater lagoons. This would be done by
9 extracting the groundwater, treating it and discharging
10 it either to a POTW or a—through an MPDS permit, or
11 injection, re-injection back into the groundwater.
12 This would address the contaminated
13 groundwater up in the source area; however, that part of
14 the plume that had gotten—that would be beyond where
15 these wells were would not be addressed by this
16 alternative.
17 The next one I'm going to look at is
18 alternative five where we would do a source removal again
19 and there would be dewatering in the area while we did
20 the source removal, but the extraction wells would be
21 placed along the periphery of the plume near the property
22 line, and this would allow all the contaminated
23 groundwater to migrate to these plumes where they would
24 be extracted and treated as described earlier. It would
25 probably take longer than other alternatives because the
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1 groundwater plume would have to migrate down to the edge
2 of the property line.
3 And the last alternative would be number
4 three that I'm going to describe. It's got a nice long
5 title; source removal in which there would be a temporary
6 groundwater extraction system that would be used for
7 dewatering the area that will have the source removed out
8 of it, but it would also then run for an additional four
9 to six months afterwards while there was an evaluation
10 period.
11 During this evaluation period, we would
12 gather more information on the aquifer and figure out
13 what the best treatment technology would be to remediate
14 the groundwater, such as either pump and treat, like
15 described earlier, or recirculation wells, which are a
16 well that extracts water from one part of it, treats it
17 and discharges it from another part of the well. Or air
18 sparging, which would bubble air through the water to get
19 the volatile organics out of the water.
20 Also during this evaluation period, we
21 would look at natural attenuation to determine if it's
22 being effective at the site in a similar time frame. And
23 if so, then we may use natural attenuation for those
24 appropriate portions of the plume.
25 The costs are at the bottom. Four is
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1 running 3.8 to 4.7 million, and the alternative five is
2 4.6 million, and alternative three would be 2.4 to 5
3 million, depending on how much of the plume would be
4 naturally attenuated, or which alternative, or human
5 technology we'd look at.
6 The next thing I would like to talk about
7 is the soil. We have seven alternatives described.
8 Three of them, alternative three, three-A and three-B are
9 containment alternatives. Three would involve leaving
10 some of the material in place near the groundwater,
11 capping it and preventing any further infiltration of
12 groundwater to it. The mixed—that would primarily be
13 metal soils. The mixed volatile organics and metals
14 would also be excavated, mixed with quick lime, placed on
15 the ground with a cap on top of it. Quick lime is a
16 dewatering agent.
17 Three-A would involve excavating all of
18 the contaminated soils, including what is called RCRA
19 hazardous waste. RCRA is the part of EPA that regulates
20 active facilities, and they determine some—for them,
21 some of the soil would be considered hazardous and some
22 of it would be considered not hazardous, and this is done
23 by doing a leach test where you crush the material, run
24 an acid through it, get the liquid at the bottom and test
25 it, and if it's above a certain number, it's considered
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1 hazardous by RCRA.
2 ~ And alternative three-A, even though this
3 material may be considered hazardous by RCRA, it would
4 remain on site, be mixed with quick lime, placed in a
5 containment system with a bottom liner and a leak-check
6 collection system and a cap.
7 And the third, three-B, would involve
8 excavating all the material again, but the RCRA hazardous
9 stuff would be taken off site to a hazardous waste
10 facility, and the remaining material would be mixed with
11 the quick lime and placed in a Subtitle D landfill.
12 Those—the cost of those vary between
13 seven for three-A, or three, to about nine for three-A
14 and eleven for three-B.
15 The next alternatives are treatment
16 alternatives, except for the last one. Alternative four
17 is solidification stabilization in which the material is
18 excavated and solidified with a reagent that would
19 prevent the materials and contaminations from leaching
20 out of the soils above drinking water standards, or MCLs
21 again.
22 The reagent mixture that would be used
23 would be determined during design and would be whatever
24 one was the most effective in preventing leaching above
25 MCLs. That can run anywhere between 10 and 20 million
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1 dollars, depending on if we do it in situ or mix the
2 material in the ground, or whether we do it ex situ and
3 stick it in a pug mill and then mix it with the
4 solidification reagents and place it back on the ground.
5 Alternative five is an innovative
6 technology; it's in situ treatment for the volatile
7 organic soils. It hasn't been used in a lot of sites,
8 it's still relatively new. We're not 100 percent sure
9 how well it would work at this particular site, and we
10 would have difficulties due to the fact that a lot of the
11 soils are saturated. Once the volatiles, however, were
12 treated, we would either contain them or solidify them.
13 Alternative six is thermal desorption.
14 It involves excavating the soils and placing it in the
15 thermal desorber which heats the soils and separates
16 organics and contamination from the soils, concentrates
17 it and, most of the time, the concentrated material is
18 taken off site. What would be left would be metals
19 contaminated soils, which could then either be contained
20 or solidified.
21 The last alternative doesn't involve
22 treatment at the site. It would be excavating all the
23 material that exceeds cleanup numbers and taking it off
24 site to a hazardous waste facility, some of which
25 solidified the material before they placed it in their
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1 facility, landfills. Alternative five runs between 10
2 and 15 million; alternative six is anywhere between about
3 19 to 47 million. It could be—it would also be
4 difficult to implement six because of the saturated
5 soils. And alternative seven runs around 11.8 million.
6 After EPA looked at all these different
7 alternatives, we felt that each of these alone may not be
8 the best cost effective best remedy, and we felt like a
9 combination of three-B and four would be the most
10 effective. The way this would work is all the soils
11 would be excavated and they would be solidified. If they
12 could not be—if they still were above the RCRA hazardous
13 waste level, they would be taken off site. So the most
14 contaminated soils would go off site. If they could be
15 solidified so that they no longer reached above drinking
16 water standards, then they would be placed in the ground
17 with an engineered cap on top. And if they were still
18 solidified and still leaching above MCLs, but below the
19 RCRA hazardous levels, they could be placed on site in a
20 Subtitle D landfill.
21 Solidifying the metals is usually not
22 difficult and it's been done on many, many sites. The
23 volatiles are the material that we're concerned about,
24 and we're really concerned because the groundwater at the
25 site is about two to three feet below land surface, so
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1 there's no room for attenuation as much as in other sites
2 where maybe the groundwater is 30 feet below land
3 surface.
4 And groundwater alternative number three,
5 source removal of the temporary groundwater extraction
6 for dewatering for the evaluation period, then picking of
7 the best treatment technology out there and using natural
8 attenuation, if applicable, is the alternative that EPA
9 feels is the best for the groundwater.
10 The State has concurred with the remedies
11 selected; however, they disagree with the lead cleanup
12 number for industrial use. They have a number of 895,
13 whereas EPA's number is 1150; however, we believe that,
14 by the time we excavate the contaminated soil out there,
15 this number only applied from zero to one foot of soil,
16 that both numbers—that the contamination that would be
17 left behind would be way below both of these numbers.
18 We have assumed at this time that the
19 future industrial use is the future land use for this
20 site; however, we would like to hear comments from the
21 public on whether or not they feel that that is the most
22 appropriate future land use.
23 That's the end of my presentation.
24 MS. PEORIPOY: Well, with that, I think we're
25 going to go through the questions and answers. I do have
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1 some things to tell you about what happens next, but I
2 th~ink we'll do that first and then I'll talk about those.
3 Questions? Comments? And please
4 identify yourself when you speak.
5 BILL GRIFFIN: My name is Bill Griffin; I'm the
6 County administrator. County Council met last Tuesday
7 and we tried to postpone this; as you know, I made
8 contact with you. And the reason that we tried to
9 postpone it was because of the holiday season and the
10 public involvement. So please don't consider this the
11 public concern with the small crowd here. That's why we
12 requested additional time.
13 Barnwell County has, in the past, been
14 involved in cleanup efforts, and that's still costing
15 Barnwell County. It cost us in excess of a million
16 dollars, and costs us monthly also. We realize that
17 EPA's involvement is to clean up the site to acceptable
18 standards.
19 One of our problems are what are we going
20 to do with the site afterwards. What I'm envisioning
21 right now is a chain link fence, a condemned building and
22 no future land use. I do not believe, nor does the
23 majority of Council, that this is a viable industrial
24 area, especially since it's right next to a residential
25 area. So those are our concerns.
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1 _ I did meet this afternoon with
2 representatives from Textron and we've started discussing
3 future land use of that site. I realize this is two
4 separate issues per EPA, but it is a very big concern to
5 the citizens of Barnwell County. What are we going to do
6 with that property afterwards? And if all we're going to
7 have is a condemned site, I don't think that's fair to
8 the citizens of Barnwell County. Also, our concern is
9 what future liabilities or contaminations is there at
10 that site to our citizens here in the County.
11 So these are the concerns of Barnwell,
12 Barnwell County Council, and I would like to reserve that
13 30-day extension so that we can get more public
14 participation and we can address these other issues, and
15 then leave us time so that we can discuss with Textron
16 what we're going to do with the rest of the property.
17 Right now, it seems like it's a very healthy dialogue
18 with Textron, and I welcome input from them, and I think
19 that we can come to an acceptable plan for Barnwell,
20 Textron and EPA.
21 Thank you.
22 MS. PANABAKER: I do need to make one more
23 point I sort of forgot. In this alternative that was
24 preferred, we also have in there that if it's more cost
25 effective to remove the material off site and off site
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1 dispose it, we may do that instead of the solidification
2 at the Subtitle D landfill.
3 MS. PEURIFOY: Any other comments?
4 TIM MOORE: Has there been any determination on
5 the cost effectiveness on those two alternatives?
6 MS. PANABAKER: We have looked at both costs
7 and we are—you know, the solidification and then
8 Subtitle D landfill, we think will run between 11 and 15
9 million. Off site disposal might run around 12 million,
10 but the question is we don't know—we have an
11 approximation of the volume and we have an approximation
12 of the types of contamination, but you really don't know
13 that, as well, until you've dug it up and done some
14 things to really determine how much is going to be
15 volatile organic soils and mixed with metals versus how
16 much is really just metal soil. Solidification of metals
17 is a lot easier than mixing it with the volatiles and the
18 metals. So that would be more determined during the
19 actual remedial design or remedial action phase because
20 of volume difficulties in determining those numbers.
21 TIM MOORE: It would seem that if the costs are
22 relatively the same that, considering the location of the
23 site, in a residential area, that it would be, with that
24 much difference, much better to move it somewhere else to
25 a landfill rather than put a landfill right in the middle
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1 of- town. That would kind of preclude any other activity
2 and use of the site. Assuming if it were out in the
3 country somewhere/ maybe that would be the thing to do,
4 to bury it right there, but right where it is, it doesn't
5 seem to be the thing to do.
6 MR. JAN ROGERS: One of the—yeah, on the
7 surface, that sounds true and that certainly would be
8 considered, but one of the problems with taking it off
9 site is because of the nature of how the Superfund works.
10 Taking it off site somewhere, if it becomes a problem,
11 where you take it creates additional liability, possibly
12 to the tune of, you know, significant negotiation,
13 litigation and other things if it went to a commercial
14 hazardous waste disposal facility. It's not just the
15 cost of dealing with it, but the factoring of who's going
16 to deal with what portion of it.
17 And that tends to be a problem in all
18 Superfund cleanups that gets overlooked. There is a
19 potential failure off site that could result in
20 additional liability back for the same waste. And
21 legitimately so. The people spending the money worry .
22 about that concern even to the extent the Superfund, in
23 some parts of the legislation, encourages treating and
24 dealing with disposal of the material on the site so you
25 don't move it to somebody else's backyard.
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1 But it becomes a fine balance in trying
2 to balance out what's the most appropriate for any given
3 site. That's what we've tried to do here, but we've
4 structured this in such a way that there are alternatives
5 as we do the design, as we get a better feel for the
6 treatability of the material. We've encouraged
7 aggressive treatment for the volatile organics to get
8 them out of the matrix. If it becomes more of a metals
9 matrix only, metals and soil, that's a pretty well-known
10 matrix for dealing with treatment and dependability of
11 the effects of treatment.
12 And then it also becomes an issue at that
13 time; what are the costs of the disposal for that
14 material if it leaches above MCLs. We feel like it's
15 still groundwater if the leach agent after treatment gets
16 above MCLs, but if it's below criteria for hazardous
17 waste, we've said Subtitle D facility, which is the kind
18 of facility typically used to control that kind of waste
19 on site. We haven't precluded going off site to a
20 similar type facility, if that makes more sense. And in
21 part because of the shallow groundwater.
22 TIM MOORE: If you did put it there, what
23 percentage or what portion of the site would be used for
24 landfill? Would there be something left over to be used
25 for something else?
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1 _ MS. PANABAKER: Yes. We're looking at the fact
2 the four wastewater lagoons is the area, and then right
3 the other side of the building, so it'd be behind the
4 building. You still have areas out in front of the
5 building, near the parking lot and that area, that has
6 not been used that could be turned and used into
7 something else.
8 MR. ROGERS: There was a conceptual drawing
9 done to estimate where the estimated volumes could be put
10 or placed and that was perceived to be doable around the
11 side and possibly even behind the building, but basically
12 out of the usable part of the property.
13 MS. PANABAKER: The areas we're looking at are
14 back in this area and then back in here.
15 DOUG KROGB: How much surface soil would have
16 to be removed over the entire area in order to get down
17 below the contaminant lines?
18 MS. PANABAKER: The total estimated volume to
19 date, which includes subsurface soils, is around 40,000
20 [inaudible].
21 DOUG KROGH: Can you give us a perspective in
22 depth?
23 MS. PANABAKER: The upper part is about one
24 foot of surface soils. The four wastewater lagoons are
25 probably about two feet and to the bottom of them. The
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1 solid pond, one is probably about eight feet or so; ten
2 feet. The solid pond is probably something similar. And
3 the others out in that wetlands area are probably, at the
4 most, five feet, but a lot of that would be one foot
5 also. Everything in the wetlands, that would be one foot
6 or so unless it's vol? organics, and then it might be
7 three or four feet in some places.
8 DREW WILDER: Is it EPA's position that you
9 want to keep this an industrial site, and so that's the
10 only use you see for this property in the future, is an
11 industrial as opposed to residential, or playground, or
12 anything like this; correct?
13 MR. ROGERS: We don't have a preference for
14 where it goes, but by law, we're required to clean it up
15 to a reasonable expectation of future use. And I guess,
16 you know, there's certainly been a lot of discussion both
17 ways as to what—what would be best suited for the public
18 isn't necessarily the criteria; what would be the most
19 logical use, future use, because someone is being held
20 responsible for paying for the cleanup, regardless of who
21 does it. Whether the responsible parties do it up front,
22 or whether the Federal Government cleans it up, we will
23 pursue cost recovery of any money we would spend. And
24 the law says clean it up to a reasonable future use.
25 A lot of that hinges on the issue of
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1 there's a building there. We went back and actually
2 looked at the building. The building is in a
3 deteriorating condition, but it's not falling to the
4 ground. It's a usable capital investment if somebody
5 chose to want to go in there and use it. And this is, to
6 some extent, crystal ball. It's anybody's, you know,
7 opinion of what future use could be. But while that
8 building is there, it suggests a strong tendency toward a
9 commercial use of the property, and we don't see a
10 particular reason to, as part of cleanup, knock the
11 building down and take it away. It's not necessary to
12 get to the contamination or deal with the contamination,
13 and the funds that we would access, or the law that
14 suggests cleaning up the site, deals with cleaning up the
15 contamination problem, not necessarily improving the
16 useability of the property.
17 So it's sort of forced us to say the
18 realistic future use remains probably commercial as long
19 as that building is there. We're not saying it can't go
20 some other route, and we wouldn't want to preclude it
21 going that route, we would just want to make sure people
22 realize, if you're going to convert it to another use,
23 there may be some additional concerns in dealing with
24 that.
25 But again, most of this contamination is
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1 over behind the building, out of the way, and that's a
2 fairly large parcel of property such that this cleanup
3 could still take place and possible other uses be
4 implemented, even if some material were left on site.
5 EDWARD LEMON: Has the building—underneath the
.6 building been tested, the ground underneath the building?
7 MR. ROGERS: Not directly under it. There was
8 some testing around it.
9 MS. PANABAKER: There was testing around the
10 building and we did not find anything in that area around
11 the building.
12 EDWARD LEMON: Could it not be contaminants
13 under the building without it leaching out underneath
14 there? I mean, is there a possibility of that or not?
15 MR. ROGERS: Minimal. We looked around the
16 building edge and basically found--the majority of the
17 contamination was out on the surface soils, away from the
18 building, or right behind the building where there
19 appeared to be some burial or some dunking, or both. But
20 there's nothing to suggest significant contamination
21 under the building. If there was anything significant,
22 certainly, it would be migrating because of the shallow
2 3 groundwater.
24 HAROLD BUCKMON: Ladies and gentlemen, my name
25 is Harold Buckmon and I'm the chairman of Barnwell County
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1 Council. Let me speak on behalf of what the Council
2 would like to have done.
3 Being a lifelong resident of this
4 particular County/ I played in that particular area where
5 that particular plant is right now, fished in those
6 little lagoons, as they call them.
7 I see very serious problems that we have,
8 and first of all, the building has no industrial type use
9 for us right now whatsoever. The cost would just be too
10 astronomical to repair. You don't know what the
11 contaminants are up under that building.
12 We vision a residential type area in the
13 future. That is ours and we know that we have to work
14 with people. Let there be no misunderstanding that we
15 want it as clean as possible; as clean as possible for
16 the simple reason that's the way it was when they came
17 here, and we don't want it left here and for future
18 generations to deal with. We're dealing with an unknown.
19 Yes, we say the probability of one in a million, but who
20 is that one in a million? We have to look at the thing
21 futuristic. Simply put, we don't want it, we don't need
22 it. We want to work with anybody or whoever, but we just
23 now—we just don't need that type of thing as a legacy
24 for our generation to come.
25 Again, we're going to be working with
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1 people in any way that we can, but let there be no
2 misunderstanding, we don't want it and we don't need it.
3 And with that, I'm going to get supper.
4 STEPHEN GUILFOYLE: Has there been any ruling
5 on who's responsible for the contamination and
6 financially responsible for cleaning it up?
7 MS. PANABAKER: We're in the middle of a
8 research to determine who all the potentially responsible
9 parties are.
10 DREW WILDER: Can one assume that one of the
11 responsible parties would not be the City or County of
12 Barnwell?
13 MS. PANABAKER: Well, our next step, which
14 she'll go into a little bit, is that we will negotiate
15 with the company PRPs for consent decree for them to do
16 the cleanup of the work. Or, as always, EPA will do it
17 if we don't have anybody willing to do the work.
18 MR. ROGERS: But even more to that question, I
19 don't believe we see the City or County being identified
20 as—we always call them potentially responsible parties,
21 because no court has decided that, but we don't view
22 that—I don't think we know of any information that we
23 would view it that way.
24 DREW WILDER: You see Textron and Shuron, Inc.?
25 MR. ROGERS: They're the two primary ones that
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1 were identified early on. We're going to—we always re-
2 visit the responsible party search before we go into
3 negotiations after making the remedy decision to make
4 sure that we have all the parties that appropriately
5 should be identified at the table. But, yes, those are
6 the two that have been—
7 DREW WILDER: One of those being bankrupt now.
8 MR. ROGERS: Yes.
9 DREW WILDER: But Textron is a viable company
10 and they have accepted some responsibility by paying for
11 the remedial study; correct?
12 MR. ROGERS: Yes. They've cooperated up front
13 and participated in the investigation, the remedial
14 investigation and feasibility study to date.
15 STEPHEN GUILFOYLE: In your proposal, too, you
16 also said that there is no action, that you'd usually
17 base it on comparison, and there's a price tag for that
18 [inaudible].
19 MS. PANABAKER: That was for surface water,
20 and—and one of them had, I think, something. That was
21 surface water and groundwater monitoring.
22 DOUG KROGH: If the option was taken that we
23 remove the material, the contaminated material, from the
24 site and put it to a different site, would Barnwell
25 County at that point become one of the entities that are
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1 liable?
2 MS. PANABAKER: If we took it off site to a
3 hazardous waste facility?
4 DOUGH KROGH: Yeah, if you took it to another
5 facility, or another burial ground. He had mentioned
6 before that the liability concern about removing it after
7 it's brought out of the site and put somewhere else is
8 not necessarily disappeared, and I just wondered does
9 Barnwell County, in itself, keep that liability if it is
10 removed from here, or we have nothing to do with it?
11 MR. ROGERS: The law speaks to owners,
12 transporters and operators that dealt with the generation
13 and disposal of the waste. So, thus far, Barnwell County
14 has not been involved in that aspect of it, to our
15 knowledge.
16 If the remedy calls for it to be placed
17 off site, it would be taken to what was considered to be
18 an appropriate facility for that material and it would
19 only create liability to the people disposing of it off
20 site and the people receiving it. So, typically, the
21 answer would be no unless the receiving facility were a
22 Barnwell County facility, you know, something like that.
23 But, no, the County really—there should be no way that
24 the County is pulled into this from a liability
25 perspective unless they were to take over the facility,
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1 run the facility, you know, numbers of things that really
2 become more actively involved in dealing with waste and
3 disposal of waste.
4 DOUG KROGH: I guess I would hope not because
5 we have already—you know, as a taxpayer, we already put
6 up the money for the Super fund, and if we get it from
7 Barnwell County also, then we've got to pay for that,
8 too; we're getting double-dipped.
9 MR. ROGERS: Well, very little money in the
10 Superfund is taxpayer money. Most of that money is
11 generated—in the trust fund that runs Superfund is a tax
12 on industries that generates the kind of materials that
13 ultimately became these kinds of waste. So the majority
14 of the Superfund money is usually from people who deal
15 with those chemicals, manufacturing and distribution of
16 those chemicals. And, to a great extent, the program is
17 run in such a way now that we have the responsible
18 parties do a lot of the work up front, so our daily cost
19 of running the program, we take off the fund, and then we
20 recover them and are reimbursed for them along the way.
21 So most of this is paid by the industry that created the
22 problem. That's the way the law is set up.
23 STEPHEN GUILFOYLE: How much has been spent on
24 the site so far?
25 MR. ROGERS: We really don't know the numbers
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1 because we're not paying for the work, we're just
2 overseeing the work to make sure it's done properly.
3 That's something that the responsible parties can tell
4 you. You know, we can tell you what we've spent, but
5 most of our money is basically just our resources; our
6 staff and our time in dealing with overseeing and
7 reviewing everything that's been done.
8 MS. PEURIFOY: Any more questions or comments?
9 DREW WILDER: Are you going to take us now to
10 where we go from here, I guess?
11 MS. PEURIFOY: Yeah, I guess it's about that
12 time.
13 Where do we go from here? First of all,
14 we've made a commitment to come back up and have another
15 hearing as you work out your plans for future use, so we
16 will be coming back up, I'm thinking probably sometime
17 mid to late January. The comment period will be ending
18 February 4th. So we'll be working to set that up and
19 everyone will be notified of that. We'll get it back in
20 the paper again. We'll also be putting a notice in the
21 paper that the comment period has been extended.
22 Again, if you're not on our mailing list,
23 you didn't get a fact sheet in the mail from us, I
24 encourage you to fill out the addition to the mailing
25 list slip that's in the back of the fact sheet and give
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PROPOSED PLAN MEETING - DECEMBER 9, 1997
1 it~to me tonight so that you will start receiving mail
2 directly from EPA on what we're doing and what's going on
3 with this site.
4 Once the comment period ends, we will
5 consider all the comments received, and what Sheri will
6 have to do is prepare what we call a responsiveness
7 summary, and that's a document in which all comments
8 received during the comment period are responded to.
9 That document becomes a part of what we call the record
10 of decision, which is the document that says what the
11 final decision is for a cleanup of the site. That
12 information will be made available to you. We'll send
13 out notices letting you know what the record of decision
14 says, what has been selected as a final remedy for this
15 site. That will also be published in the paper.
16 After all that's done, then we go into
17 what was just discussed before, into negotiation period
18 to get the potentially responsible parties on board to
19 sign an agreement with us to do the work that's carried
20 out in the record of decision. And we, again, will also
21 make you aware of that; what's going on there, when this
22 agreement is signed. And all that, again, will be made a
23 part of the information repository at the library. All
24 those documents will be put there when they're finalized.
25 And we will go on from there into designing the cleanup
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1 and you'll be kept informed of all that as well
2 So that's pretty much it. We encourage
3 you to call us, let us know if you have specific
4 questions as you go through this proposed plan. If you
5 see something there, we do have an 800 number that's in
6 the fact sheet. Please call us any time and let us know
7 if you have any concerns or questions or just need some
8 additional information.
9 With that, I thank you again for coming
10 out tonight, and we'll see you in January.
11 [PROCEEDING CONCLUDED AT 8:00 P.M.]
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PROPOSED PLAN MEETING - DECEMBER 9, 1997
CERTIFICATE
SOUTH CAROLINA
BARNWELL COUNTY
I hereby certify that the foregoing Public Hearing was
reported, as stated in the caption, by the method of
Stenomask with backup and reduced to typewriting by me or
under my direction; that the foregoing pages 1 through 41
represent a true, correct, and complete transcript of the
proceeding held on the 9th day of December, 1997.
This 12th day of December 1997.
0 '£,
*,y. L-'-y^)
ALICE D. BONI, CVR
CERTIFIED COURT REPORTER
NSVRA CERTIFIED
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SHURON SUPBRFUND SITE PROPOSED PLAN MEETING
before Alice D. Boni, Court Reporter
held at the Barnwell County Council Chambers
Barnwell, South Carolina
on Thursday the 22nd day of January 1998
commencing at 7:10 p.m.
FOR THE EPA:
FOR S.C. DHEC:
FOR D.S. AGENCY FOR
TOXIC SUBSTANCES AND
DISEASE REGISTRY:
APPEARANCES
Sheri Panabaker
Jan Rogers
Gary Stewart
Kent Coleman
Enayet Ullah
Yanqing Mo
Darrell Weston
Eric Melaro
AIKEN REPORTING SERVICE, INC.
Post Office Box 2474
Aiken, South Carolina 29802-2474
(803) 648-9434
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PROPOSED PLAN MEETING - JANUARY 22, 1998
1 MS. PANABAKER: My name is Sheri Panabaker and
2 I'm from EPA in Atlanta, Georgia. I'm the project
3 manager for the site. With me tonight is Jan Rogers, who
4 is the South Carolina section chief, also EPA.
5 There are a number of people here from
6 the State, and if I forget one, somebody yell. We have
7 Gary Stewart and we have Darrell West on, Kent Coleman,
8 Yanqing Mo, Eric Melaro and Enayet Ullah, also with the
10 We're in the middle of our 60-day comment
11 period that started December 5th and will end February
12 4th. We've been here two other times and we were
13 requested to come back again, so we're here for the third
14 time. We have an administrative record that contains all
15 the information about the site. One is located at the
16 Barnwell Library and the other one is located in Atlanta,
17 Georgia.
18 - There's nany steps in the Superfund
19 process. We've been through the first four and we're
20 currently in the fifth part where it's public comment.
21 The site was ranked. The remedial investigation actually
22 started prior to the site being ranked. That was done in
23 '95 and '96, and the feasibility study finished up in
24 '97. And as I said, we're currently in the public
25 comment period. After the end of the public comment
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1 period, the next steps are to make a decision on how to
2 clean up the site, which will be written up in a record
3 of decision, followed by designing how to clean it up and
4 actually implementing the clean-up plan.
5 As I said, we did the remedial
6 investigation in 1995 and 1996, and we collected soil and
7 groundwater samples. Soil samples would be anything;
8 surface soils zero to one foot, subsurface and sediment.
9 • When I say soil, I'm talking all those.
10 What we found during the R.I. was that
11 there was about seven or eight organics and four metals
12 detected in the soils. And those are the areas that we
13 believe need to be addressed based on our soil sampling.
14 After we collect the samples, we do
15 what's called a risk assessment. What we determine, if
16 there's any current or future risks to nearby residences,
17 or if it was an active facility, on-site workers or
18 whatever. Since it's not an active facility, the current
19 scenario that we evaluated was a trespasser and we
20 determined that there was not a current risk to a
21 trespasser.
22 There was, however, determined to be a
23 future risk for either a worker or a resident if they
24 built a house on the property, so we had to come up with
25 different alternatives on how to address soils and
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1 groundwaters because of the potential future risk.
2 And we also put monitoring wells in the
3 ground and collected groundwater samples and found the
4 same seven or eight organics, as well as some lead, and
5 that's approximately where the groundwater plume is
6 currently. This will all be further determined and
7 verified during the cleanup portion of the project, which
8 will be the designing and actual remedial action phases.
• 2 - ^-~~ ' "-•'•• •- "'- So c;:cs we ciewt^ihcd w-lii'l^tfhe • '
10 contaminants were and the areas that needed to be
11 remediated, we came up with different and various
12 alternatives. I'm going to start—oh, quickly, in your
13 fact sheet, it shows—once we come up with the
14 contaminants in the areas, we also come up, of course,
15 with what we need to clean them up to. These are the
16 groundwater remedial goals. For the most part, they
17 coiaply with the State and Federal standards drinking
18 water regulations, and their drinking water levels.
19 The soil numbers primarily came from
20 either protection of the ecological receptors out in the
21 wetlands, at the bottom, or for surface soil for
22 protection of the future industrial worker. Since
23 there's a building on the site that we feel could be
24 reused, or opened for something else, we picked
25 industrial cleanup standards, and we have 1150 for lead
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PROPOSED PLAN MEETING - JANUARY 22, 1998
1 and, as you can see, the rest of them.
2 We had 14 alternatives, total; we had
3 five groundwater and nine soil. For both soils and
4 groundwater, they all have a no-action alternative that
5 you could do, which serves as a baseline to compare the
6 other alternatives to. A no-action alternative is that
7 we would not do anything at the site, would not clean it
8 up, just leave it as is.
9 The second alternative that is also for
10 groundwater and soils, which are included in most of our
11 feasibility study reports, is called—well, here, it's
12 called limited action, but it's institutional controls;
13 it's like putting a fence up with deed restriction to
14 prevent people from drinking water; signs that tell
15 people there's contaminated soil in here.
16 Besides those two alternatives, there's
17 three other groundwater alternatives we looked at.
18 Number three—all the soil alternatives, there will be a
19 source removal, since a lot of the contaminated soil is
20 in the wetlands. There will have to be dewatering to
21 excavate the soils. So, for alternatives three, four and
22 five, they all have this dewatering period, but for
23 alternative three, it's going to extent four to six
24 months past when the soil is excavated. This will give
25 us a chance to have an evaluation period to determine
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PROPOSED PLAN MEETING - JANUARY 22, 1998
what the best treatment technology is for remediated
groundwater, whether it could be air sparging, which
would be bubbling air through the water and it releases
the volatile organics, or pump and treat, where you would
extract the groundwater and then put it in a treatment
plant, treat it and discharge it. And the third one was
recirculation wells, which are wells that extract water
from one part of it, treat it, and discharge it out of
ahother "pkrtT -c'f that same wall.- -•>> -.*'•* -.' .-
We'd also be evaluating natural
attenuation to see if it's occurring at the site and if
it's occurring at a similar time frame as an active
treatment. And if it would, then that could be applied
to those appropriate parts of the plume.
Alternative four, again, would have the
source removal and dewatering just for the period of the
source removal, and then extraction walls or trenches
will be placed in the highest contaminated groundwater
area, around the source area, and the groundwater be
extracted and treated and discharged. It's not going to
treat what's already past where that trench would be, or
the wells, it would treat the very heavily contaminated
groundwater.
Alternative five would be putting
extraction wells, or trenches, but probably wells down by
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PROPOSED PLAN MEETING - JANUARY 22, 1998
1 th« property boundary where the edge of the plume is, and
2 it would intersect all of the contaminated groundwater
3 coining towards it. It would just take a little longer
4 than possibly other alternatives.
5 After that, we looked at soil
6 alternatives. Again, the no-action and an institution of
7 controls. Alternatives three, three-A and three-B are
8 all containment alternatives. Three would be where most
9 of the soil was excavated, but some of the metals on this
10 soil would be capped in place. The rest of it would be
11 excavated, mixed with quick lime, because a lot of the
12 soils are very wet, especially the ones coming out of the
13 wetlands, and so they would need to be mixed with a
14 drying agent, such as quick lime. And then they would be
15 placed in the ground and a cap placed over them. One
16 other thing that you need to know is that the groundwater
17 is, like, two feet below land surface around the site.
18 Alternative three-A would be that all
19 soils were excavated, including the metal soils, and they
20 would also be mixed with quick lime, and they would be
21 put in a containment system where they would have a liner
22 on the bottom, a leak-check collection system, and a cap
23 on top. But this would include all soils, including
24 what's considered RCRA hazardous waste.
25 RCRA defines some waste as hazardous and
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1 some waste as not hazardous, based on a leaching test
2 where they take soil, pour an acid through it, collect
3 the liquid underneath and analyze it. If the amount of
4 contamination in that liquid is higher than a certain
5 number, then the soil is considered hazardous.
6 Under alternative three, the RCRA
7 hazardous waste would also be put in a containment cell,
8 which is not a full Subtitle D landfill, which is a
' .• 9——*-. .* litcT-fer stricter tiiari vlrat aitcrr.^t"ivo"~t:Ii^-a£»f> h*st
10 envisioned in it. RCRA doesn't allow hazardous waste to
11 go into Subtitle D landfills. They want something a
12 little more stringent than that.
13 Three-B, therefore, has, as part of its
14 remedy, that the hazardous waste will be taken off-site.
15 So the highest contaminated soils would be removed from
16 the site and the lower contaminated soils would remain on
17 site in a Subtitle D landfill.- which RCRA would normally
18 allow. - -
19 The fourth alternative is solidification
20 stabilization in which a reagent is mixed with the
21 contaminated soil so that the material, when it's
22 finished being mixed and cures, would not leach above
23 drinking water standards. Usually, a lot of times,
24 cement is used, but there's other reagent mixtures out
25 there that have been proven successful on other sites.
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1 _ Number five is called in situ thermal
2 treatment. That's for the volatile organics only. It
3 doesn't do anything for the metals. So, what that
4 involves is placing electrodes in the ground, heating the
5 soil, which would release the volatile organics, and then
6 the metal soils, which would be left, would either be
7 solidified, like in alternative four, or it would be
8 contained like alternative three-B.
9 ' Number six'was thermal desorption with,
10 again, containment and solidification because thermal
11 desorption also only works on volatile organics. And
12 that's a process where you heat the soils, which causes
13 the volatile organics to separate from the soil, and then
14 they are concentrated. And that's usually taken off
15 site. Then you would be left with metal soils that are
16 either solidified or contained, like in alternative
17 three-B. And number seven would be taking all the
18 contaminated soil off site.
19 Our regulations prefer that we treat the
20 soil on site, which is why we have all these on site
21 various choices. What EPA picked is what they believe is
22 the best alternative for groundwater, was alternative
23 three, which gives us the dewatering scenario for four to
24 six months after the source removal so that we can have
25 the evaluation period and evaluate the best treatment
•
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1 technology and to also evaluate natural attenuation.
2 Our estimate right now is somewhere
3 between two and a half and five million dollars for that
4 alternative, based on which treatment technology turns
5 out to be the most effective and how much could be
6 naturally attenuated with the plume, et cetera.
7 The best alternative, we felt, for the
8 soils was a combination of alternatives three-B and four.
*? * The"fi€>il»-*thc.tr*Were'-cc;itar.\ii:i-:;iii ibova* 'ilis- rcnr.^dl-trl
10 goals, which is on table two in your fact sheet, all of
11 it would be excavated. It would be solidified and
12 aerated to treat the volatiles and the metals. If, after
13 treatment, or if we knew it because it was so high we
14 knew treatment couldn't handle it, we would take—and it
15 was, therefore, above RCRA hazardous levels, that
16 material would be taken off site. If we treated it with
17 solidification and aeration and it was no.longer leaching
18 above drinking water standards, we'd place it on the
19 ground with an engineered cap on top.
20 If it was still leaching above drinking
21 water standards, but below what's considered RCRA
22 hazardous, we would place that into a Subtitle D
23 landfill. And that, we've estimated—I don't have that
24 sheet up there, but it's somewhere between 11 and 15
25 million, is our guess right now.
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1 - Anyway, that's my whole presentation, so
2 if y'all have questions, feel free.
3 MR. FLOWE TREXLER: Ma'am, is the building
4 contaminated also?
5 MS. PANABAKER: The building had a removal—I'm
6 sorry, I should have mentioned it. There was a removal
7 done inside the building in 1994 in which the hazardous
8 drums that had been left there by Shuron, Inc. were
9 removed, so—and all the property, I think, when they
10 went bankrupt, they sold all the stuff in there. All
11 that's left is the building, itself.
12 MR. FLOWE TREXLER: And is it safe?
13 MS. PANABAKER: Is there contamination still
14 left in there?
15 MR. FLOWE TREXLER: Yes.
16 MS. PANABAKER: As far as I know, there's not.
17 Removal took care of what was left in there.
18 MR. FLOWE TREXLER: Now, they had trenches in
19 that building. Has anybody checked them? Underground
20 trenches?
21 MS. PANABAKER: I know there was a wastewater
22 treatment plant that discharged out into the wastewater
23 lagoons. Don't know if I know of anything else.
24 MR. JAN ROGERS: Trenches or basins?
25 MR. FLOWE TREXLER: I think it was trenches. I
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1 don't think there was a basin, I think there was
2 trenches, and I don't—I could walk in them. They were
3 big enough to walk through. And I believe they led to
4 the lagoons, I think.
5 MS. PANABAKER: There was piping to the
6 lagoons.
7 MR. FLOWS TREXLER: Well, then, maybe the
8 piping was in those trenches.
3 ---•»•• —•. • •' MS.' £flKiU3AK£i;.::•" I don•' c.' kuow tibeuv^&ny '
10 trenches. We did investigate the soil around the
11 building and we investigated the soil in the four
12 wastewater lagoons.
13 MR. FLOWE TREXLER: Well, the last time I rode
14 by there, there was still water barrels in the back yard,
15 the back dock. Are they still there?
16 MS. PANABAKER: I guess so. I see a nodding
17 head ever here from a-State person.
18 [Inaudible conversation from State personnel]
19 UNIDENTIFIED STATE PERSON: You put it in the
20 barrel and then they test it to see whether it's bad or
21 not.
22 MR. FLOWS TREXLER: But eventually, those
23 barrels will disappear?
24 UNIDENTIFIED STATE PERSON: Yes.
25 MR. JAN ROGERS: Yeah. Basically, it's called
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1 investigation derived waste, and typically it's just
2 accumulated on site. It's not necessarily real high
3 concentration or a real problem, it's just a matter of
4 typically you want to dispose of it when it's a
5 convenient time to dispose of it for handling purposes
6 and other reasons.
7 MR. FLOWE TREXLER: Now, forgive me for asking
8 these questions, but I'm just curious. If you took that
9 soil out and disposed of it, completely made it
10 disappear, are you going to put some more soil back in
11 the place of it, or are you going to leave it fenced, or
12 lagoons? What will you do?
13 MS. PANABAKER: What's anticipated is we would
14 excavate the wastewater lagoons, the four wastewater
15 lagoons, the two solid ponds, treat the material and put
16 clean fill to get it three feet above the water table,
17 and then put the solidified material back on the ground,
18 or put it in a Subtitle D, which will be in that
19 location. That's what's anticipated conceptionally right
20 now.
21 MR. FLOWE TREXLER: I'm not sure I understood
22 you. You're going to put fresh soil back in at what
23 level of the water table?
24 MS. PANABAKER: To bring it three feet above
25 the water table.
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1 MR.'FLOWE TREXLER: And then what are you going
2 to put in above that?
3 MS. PANABAKER: Then we put either solidified
4 material, if it doesn't leach above drinking water
5 levels, which is like five parts per billion, those
6 levels, and if it still does, then we'll put it inside a
7 Subtitle D landfill which will be a bottom liner, a leach
8 check collection system, and the solidified material
9~" "wouid" govch tc
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PROPOSED PLAN MEETING - JANUARY 22, 1998
1 from the groundwater, then come back and build whatever
2 is appropriate for placement of the soil, and then any of
3 the soil left on site would have a cover put on it,
4 whether it was just earthen cover or a more sophisticated
5 cover. We typically wouldn't leave big holes.
6 MR. FLOHE TREXLER: Okay, now, that stuff you
7 left mounded up, would that be safe?
8 MR. JAN ROGERS: Wouldn't—well, we—oh, yeah,
9 okay,-in some cases, it could actually come above ground
10 level.
11 MR. FLOHE TREXLER: See, I envision that one
12 good use for this property would be playgrounds. It's
13 something we need desperately in Barnwell. And if you
14 did that, you wouldn't want to mound the dirt there,
15 you'd want it to be fairly level.
16 MR. JAN ROGERS: Well, you wouldn't necessarily
17 put the playground on top of it, but the design would be
18 oriented toward putting it in a portion of the property
19 where you really wouldn't necessarily need to use that
20 property'anyway, and keep the rest of the recreational
21 activity away from there on the rest of the property.
22 That's—you know, I know some of the side discussions
23 going on between some of the local authorities, and that
24 may or may not come about.
25 We're having to look at it right now as a
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1 site with a plant building on it that has reasonable
2 integrity such that we can't really go off and say,
3 "Knock it down." I mean, it's expensive to knock it down
4 and it's not really a contamination problem at this
5 point. But it tends to lead us to look at future use
6 scenarios for cleanup purposes of industrial because, in
7 fact, it could be used for industrial, and more likely
8 would be used for industrial if the building stays there.
-C-- - *—Hrf .-t-he- building go^s c-v*:iy ^.iid it- c;cs3 ";.:-.-icW»:>ti£.l:,
10 certainly the conversion to that could occur in such a
11 way that it could be done safely; not residential, but
12 playground or recreational.
13 MR. FLOWS TREXLER: Well, playground and
14 residential is virtually the same specs, I think.
15 MR. JAN ROGERS: Yeah. From our perspective,
16 it changes a little because of how we calculate risk
17 assessments. We, in essence, try to., figure out what is
18 the likely exposure mechanism that occurs with the
19 activity that occurs. Recreational is a little different
20 than residential with a young child playing in the
21 background every afternoon, that sort of thing. So it
22 changes exposure scenarios. But yeah, the degree of
23 cleanup ends up being roughly the same.
24 MR. W.A. GRIPP: Is this the question and
25 answer or public comment?
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1 _ MS. PANABAKER: It's both.
2 MR. JAN ROGERS: It's both.
3 MS. PANABAKER: It'll be included on the
4 record. All of this is in there.
5 MR. JAN ROGERS: All of this is official public
6 comment, but it's question and answer.
7 MR. H.A. GRIPP: Well, I'd just like to address
8 everybody that the decisions made by EPA and from the
9 citizens of Barnwell County are extremely important, but
10 the EPA goes back to what Textron does, or fails to do,
11 and it definitely impacts Barnwell County. The last
12 meeting, I reported that I was in negotiations with
13 Textron. Unfortunately, that did not pan out. In fact,
14 we just received our offer the day before yesterday, and
15 were speaking again this afternoon, and it just did not
16 pan out.
17 But I'd just like to say a couple of
18 things on Textron and what we're looking here so that
19 everybody is aware of what's going on. One, Textron
20 comes to our County and builds a plant and employs
21 people. We welcome any industry in Barnwell County that
22 is a corporate citizen and contributes to the County; we
23 welcome that. We welcome the jobs and the growth.
24 But I'm going to paint a little bit
25 different picture right now because I want to tell you
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1 something that I have learned and I have researched.
2 One, there is a letter that was written to Textron from a
3 law firm in New York. I've been trying to find this
4 letter. And apparently, this letter is stated as,
5 "Divest yourself of these properties because of these
6 environmental issues." So, we're not talking this
7 corporate citizen that—and poor old Textron here.
8 Many of the contaminants and a million
9 • -•* do'll'Brrt i.c«£wci-ianur s.t cur 1 -"c'.f;'J_.l ^;::^-:/£c^e, and "ho p=\^
10 for that? Barnwell County paid for that. What myself,
11 as well as others in this County, don't want to see is •
12 that piece of property that, I'm sorry, sir, I have to
13 disagree with you as being used for industrial purposes
14 for future use; I /don't see that, nor do a lot of other
15 people see that. But what we're going to look at is what
16 is left behind is a building, a contaminated or quasi
17 . Subtitle D landfill that was probably kno_wn to be
18 contaminated—or could have been; let me put it that way.
19 I've been in contact with a former County
20 administration, Mr. Robert Bolin, today who tells me that
21 that letter does exist. I've also been in contact with
22 the former County attorney that is a resident here of
23 Barnwell, and I've made contact today with an
24 environmental attorney in Atlanta, Georgia who was
25 covering that case.
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1 The bottom line is, I believe, there's
2 reason to believe that that site was contaminated before.
3 Nobody stepped up from Textron to pay for the cleanup or
4 participate in that cleanup at our landfill. I feel
5 resistance to get that area clean. And I see Barnwell
6 County citizens bearing the cost of future use of that
7 property, and that's why I'm so adamant about getting
8 that property clean.
9 I am requesting,. not only from the
10 County, but as a citizen of Barnwell, also; I would like
11 to see that site to residential standards. Take the
12 contaminants out of Barnwell, get them out of Barnwell
13 County and remove it all. We have enough contaminants,
14 we don't need another Subtitle D landfill, and we
15 definitely don't need future costs and liabilities on
16 that stuff.
17 MR. JAN ROGERS: To that end, the legislation
18 is set up to where there should not be any liabilities
19 that extend to the County. There's basically no way for
20 them to get out of the liabilities if there's property--
21 or there's material left-on site, it, in essence,
22 requires long-term, what we call, O&M, operation and
23 maintenance monitoring, making sure the cap stays—
24 maintains, retains his integrity, and those kinds of
25 issues. There's really no way, other than a legal faux
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1 pas down the road somewhere that it becomes a burden of
2 the County.
3 Some of the issues you mentioned are
4 theoretical issues that deal with the whole
5 implementation of the Superfund legislation. The law was
6 passed in an unusual way that has—it assigns retroactive
7 liability to the people who generally were associated
8 with causing the problem to deal with cleaning up the
2—..- .•pr'cislissi if it's couKJ.dor£d Lc crtartfe an u::^^rjfc^_i.abic .
10 risk.
11 The disposals, the activities and those
12 sorts of things weren't necessarily illegal or improper
13 at the time. If they were, we have other ways of
14 following through 'in enforcement actions on that. But a
15 lot of these things occurred when there were no laws and
16 regulations on what to do with this waste. So it becomes
17 kind of .a-hypothetical issue of, yeah,-Congress ^aid
18 you're going to hold anybody who ovr.sd it, operated it or
19 transported the waste liable, retroactively, which is
20 unusual in U.S. Code, for now taking care of making that
21 site safe. It's not—well, and it's basically oriented
22 toward looking at past disposals that are now, in today's
23 time, viewed as inappropriate and unacceptable from human
24 health or in ecological risk perspective, and making them
25 right.
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1 - Now, the problem with hauling it all off,
2 and the theoretical issue that has evolved over years of
3 Superfund implementation, is most people would say, "Just
4 pick it up and take it away from me." Well, when you
5 take it away from you, it goes to somebody else's back
6 yard, so to speak. And there's this not-in-my-back-yard
7 syndrome that emerged whereby preference was sort of
8 given toward dealing with the problem and dealing with it
9 on site as much as 'possible because, if you do pick it up
10 and move it, you basically are taking it to somebody
11 else's area and dumping that problem on them. Now,
12 that's very hypothetical.
13 MR. W.A. GRIPP: Right, but, sir, aren't there
14 not landfills that can take that waste?
15 MR. JAN ROGERS: Sure.
16 MR. W.A. GRIPP: And designed for the disposal
17 of that waste and the treatment of that leaching and
18 those contaminants?
19 MR. JAN ROGERS: Yeah.
20 MR. W.A. GRIPP: So what I'm saying is—what
21 I'm envisioning in my mind is that we're going to have
22 that contaminated building, a rusted chain link fence
23 with a lock on it, with a little mini Subtitle D landfill
24 sitting over here that has no future use for Barnwell
25 County, that we can't do anything with. And what I was
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1 proposing is doing something with that.
2 MR. JAN ROGERS: Removal of the waste won't
3 change that. You'll still have a rusted dilapidated
4 building with a rusted fence.
5 MR. W.A. GRIPP: Well, that's right, and that
6 may be another legal issue.
7 MR. JAN ROGERS: Of course, we've given you
8 some links to some other Federal programs that might
S actually b*. afcrls 4to help -dial .v.-ic:-. tliist isrsae* .
10 MR. W.A. GRIPP: Such as Brown—
11 MR. JAN ROGERS: Well, not just Brown Fields,
12 but HUD and some other redevelopment initiatives that
13 might actually be able to help you, as a County, with
14 that issue. /
15 MR. W.A. GRIPP: And are those matching funds,
16 or—
1.7 .. . ..MR... JAM. ROGERS: Oh, I don't know.. They're
18 Federal programs and I just know that it might be a way
19 for—I mean, this wouldn't be an unusual issue for any
20 County. You have to have old abandoned buildings that
21 are rundown and dilapidated and it, unfortunately,
22 becomes the burden of the local community to deal with
23 it, without the waste.
24 MR. W.A. GRIPP: Right. And that's what—we're
25 trying to avoid that and incur any more burden or
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1 problem.
2 MR. JAN ROGERS: And, you know, the problem we
3 have is the legislation doesn't allow us to go out and
4 improve property. It basically tells us to deal with the
5 contamination that exists and remove any health risks
6 that may be associated with it for current use or future
7 use, which is kind of a crystal ball thing.
8 MR. W.A. GRIPP: And these may be legal issues
9 that surpass the EPA, what we're asking for. -
10 MR. JAN ROGERS: Yeah, and we're not—I mean,
11 we' re not—
12 MR. W.A. GRIPP: But there's two different--
13 MR. JAN ROGERS: We don't disagree with the
14 concept that the County would like to go with a
15 recreational facility. How much we can drive that and
16 how much the County has to drive that on its own is the
17 issue.
18 MR. W.A. GRIPP: But then, on your part, the
19 cleaner that site could be, sir, the far easier it would
20 be for Barnwell County to develop it into some
21 residential standard type facility, whether it be
22 housing, recreational park, or whatever, but doing the
23 minimum or the cheapest, or whatever, would not be
24 advantageous to Barnwell County by leaving contaminants
25 on the site.
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1 - MR. JAN ROGERS: The cheapest might actually be
2 off site.
3 MR. H.A. GRIPP: Okay, well—and that may be
4 the best—
5 MS. PANABAKER: And, well, remember that
6 there's a twist to this alternative where, if it is more
7 cost-effective to take it off site, that's still an
8 option. It's not precluding—
2- -_ ._• .--•«-.•.'• .LILT* JAN ROGSRS: tta'vts striae cured 11:is i.!.i.-.,- co
10 where it gives preference for treatment in making it
11 nonhazardous. It really doesn't give preference for
12 leaving it on site, but it leaves the ability to leave
13 some of it on site, but it also leaves the opening to
14 take some of it off, especially if it were more
15 economical. It doesn't make any sense to leave it on
16 site if it were more economical. It's not necessarily an
17 ill-fought remedy so much as there are.still unknowns and
18 variables that come into play that will occur two and
19 three years from now, as the implementation takes place,
20 that will dictate what is the most logical way to deal
21 with it at that time.
22 MR. W.A. GRIPP: As for the water contaminants
23 that have been found, that area, I do believe, is on
24 water and sewer; however, that water, as it migrates, how
25 can we be assured that that water will be drinkable for
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1 those standards to wells in the area?
2 MS. PANABAKER: Well, we have monitoring wells
3 all over that site. And there is one between the plume
4 and your nearest municipal well, as deep as your nearest
5 municipal well. So it's going to show up there before it
6 would ever show up in your well. Plus the direction of
7 ground flow is you're not towards your well.
8 MR. W.A. GRIPP: Okay, so, it goes towards—
9 MS. PANABAKER: The wetlands.
10 MR. W.A. GRIPP: —Turkey Creek.
11 MR. JAN ROGERS: Yeah.
12 MR. W.A. GRIPP: Turkey Creek goes
13 MS. PANABAKER: That's a long way to Turkey
14 Creek. /
15 MR. JAN ROGERS: The remedy is oriented—the
16 goal of the remedy on groundwater is to restore it to
17 usable standards/ which are basically drinking water
18 standards, or potentially surface water quality standards
19 in the stream, which we don't really envision as probably
20 being a problem; mostly drinking water.
21 We also envision a high degree of
22 unlikeliness that it'll ever be used for drinking water
23 because the path of the material is going through a
24 swamp, or under a swamp, and a wetland and headed toward
25 the creek. And the dynamics of discharge of groundwater
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1 to~ the creek basically will dilute it out, if it ever got
2 that far, but the goal remains proactively going in
3 there, recovering certainly as much of the high
4 concentration of groundwater contamination as possible,
5 and then — because you're going to have to dewater anyway
6 to excavate the contaminated soil, some of it which is
7 behind the building and fairly deep — not deep, but down
8 in the groundwater.
10 look after the dewatering and the excavation to see how
11 much of the high concentration groundwater has been
12 cleaned up, what is left, and what are some appropriate
13 ways to deal with those residual parts. We know some
14 concentration figures that are out toward, I guess, into
15 the marsh, the wetlands.
16 MS. PANABAKER: Right near the south drainage
17 ditch by- -the .river beds
18 MR. JAN ROGERS: But if it's a small finger of
19 contamination, it's conceivable, one other way of dealing
20 with it, and actually as efficiently as going in and
21 putting wells and trying to recover it, would be to
22 monitor it and make sure that it goes away either
23 through — what we call natural attenuation is a
24 combination of things. There could be biodegradation
25 going on; not a lot, but there could be some. But there
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1 could be also some dissolution and dispersion going on
2 which would bring it down below acceptable standards
3 before it gets near any kind of receptor that could
4 possibly use it. But that would all be a part of the
5 groundwater remedy as it plays out.
6 And the reality of it is trying to take a
7 crystal ball and say today, "This is exactly how this
8 remedy should be implemented," is pretty difficult
9 because the fact of the matter is it needs to be fine-
10 tuned as it's implemented and revisited as to when are
11 you spending good money to effectively remove waste from
12 the environment versus when did you reach a point where
13 you're throwing an awful lot of good money and not
14 recovering much of anything from the environment.
15 Now, what the goal still is, ultimately,
16 to get it cleaned up to usable standards, but there are a
17 number of getting there, both proactively and otherwise.
18 Of course, we're not proponents of dilution, but it is a
19 reality of life.
20 MR. DOUG KROGH: Two issues that I'd like to
21 bring out, one being that ten years ago, I suspect it was
22 around ten years ago, we didn't even have the laws that
23 said the contaminants that are out there were bad, or
24 such as minerals, you know, where they'd come down
25 reasonably, as far as nickel quantities being harmful, so
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1 therefore, you've got to clean up that site. There's
2 nothing to say that five years down the road that even
3 the acceptable levels now have got to be cleaned up, so
4 therefore, you know, what businessman in his right mind
5 would put himself into a building, even if it was the Taj
6 Mahal, on that ground out there, knowing that there could
7 be potential problems in the future where he'd have to
8 move or get involved with cleaning up. So, therefore,
"9 "' 'ilhat •"*» "a. deterrent for anybody t.o want to get. iaL^ c.;-;u-
10 building.
11 As far as the building's condition, it
12 wouldn't be in the sad shape that it is now if a normal
13 company would have just moved out and another company
14 have moved in, and it sat there because nobody was
15 allowed to repair it and keep the maintenance on it, so
16 therefore, it has become a shamble.
17 Sc, therefore, if Baravail Ccunty,- or if
18 anybody—I mean, if they do decide to make that another
19 industry, a manufacturing building or area, it will
20 probably sit there like another unused building because
21 of the liability issues.
22 MR. JAN ROGERS: From Superfund—lacking re-
23 authorization, Superfund is a law, like a lot of
24 environmental laws today, are passed with sort of some
25 drop-dead dates on it. Congress gives them about a five-
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1 year life and has to re-authorize them over time. In our
2 case, it's very necessary because our funding is based on
3 a five-year funding mechanism. Actually, which doesn't
4 exist right now. But there's a lot of debate over re-
5 authorization and making Superfund more fair. It's a
6 retroactive liability law; a lot of people have a lot of
7 problems with that. And they have a lot of problems with
8 all the other liability issues, the joint-and-several,
9 one person can be held totally responsible for all of it;
10 new owners, a bank comes in, deep pocket, we can go after
11 them if they took ownership of the property.
12 In the interim of re-authorization to
13 straighten all that out, because we can't change what the
14 law says or how it's interpreted, but we can—we've
15 implemented some of what we call reforms that basically
16 say, "We'll give out perspective purchaser agreements,"
17 where, in essence, we're saying, as an agency, "We don't
18 think the law was ever intended to go after a new owner
19 who wants to come in and reutilize the property under
20 certain circumstances. We certainly won't give that to
21 the people who did it, but a third party, sort of the
22 Brown Field scenario, where there's an encouragement of
23 industry to go in and redevelop what otherwise looks
24 contaminated, a lot of that has been cut off because of
25 the broad-based liability associated with Superfund.
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1 — And there are some ways today to shield
2 that liability and encourage people to go in and do that.
3 This administration, through the reforms and other things
4 they've done, in interpreting the Superfund legislation,
5 has tried to help stimulate that. Not just on Superfund
6 sites, but there are sites that are going to drop out of
7 our domain in Superfund that are still slightly
8 contaminated, that local government wants to encourage
9 reuse-oi.- i-iost people' ::*.id, I:v'o don't v-nt;. to:.tc.aAh it
10 because of the liability questions." Those are getting
11 straightened out, for the most part.
12 The other half of your question I thought
13 you were headed toward, which you really didn't go there,
14 was suppose environmental standards change in five years.
15 Good choice of time frame. Part of the Superfund
16 program, or process, is we're going to clean it up. If
1? • we-leave any-waste on site that causes the site to have a
18 restricted use of any nature, such as if we bury things
19 and leave them there, there's a restricted use. It
20 causes a reevaluation of the site every five years to
21 assure that it remains protective of public health and
22 the environment. As long as that site, when it's cleaned
23 up, is left in a condition that is not—I forget the
24 wording in the law, but basically, it talks at the issue
25 backwards. If the site is left in any condition that
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1 does not allow it to have completely unrestricted use,
2 then you have to continue to do five-year reviews
3 throughout the life of the site until it does reach a
4 state where there's unrestricted use.
5 Groundwater, that makes sense.
6 Groundwater, ultimately, will be solved. And when it's
7 solved, there becomes an unrestricted use, and therefore,
8 you wouldn't necessarily need to continue to review the
9 site from every five years after that.
10 If you bury things, you're looking at
11 perpetuity, Every five years, you're going to go back,
12 reevaluate. Part of the reevaluation is let's look at
13 any toxicological changes related to these materials;
14 have we progressed in our understanding of toxicology
15 that we think this stuff is worse than it was, and the
16 numbers that tweak how clean is clean drop to lower
17 levels that might cause us to go back there and
18 reevaluate additional cleanup.
19 So there's a process in there to make
20 sure that if something is left on site, it's not left for
21 the local community to be burdened by, it's basically
22 left for the responsible parties to deal with. And it's
23 monitored as long as necessary until there's completely
24 unrestricted use of that property.
25 And/ you know, the contamination, you
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1 have to realize, is behind the building towards the
2 wetlands and off to the side of the building towards the
3 wetlands, and in the wetlands. That's not the ideal part
4 of the property to try to utilize, whether it's
5 industrial or goes recreational. There are concepts that
6 could be contrived where it could be done in such a way
7 that it could be left safe and not interfere with
8 recreational use because you've got a lot of acreage out
9 there act necessarily causing e gre^t Jcol of pi":•->-.-\:.-.- z•:
10 utilize that acreage that's tucked up right against the
11 wetlands, and, in fact, you may have problems doing too
12 much over there because you could cause an adverse impact
13 to the wetlands; sediment runoff and a number of other
14 things.
15 MR. W.A. GRIPP: So, basically, what you're
16 proposing is, then, clean the site, possibly keep
1-7 - whatever is on the site., the rontaminants that you can,
18 and hope that it could someday be used for an industrial
19 park, or an industrial area?
20 MR. JAN ROGERS: Yeah. We're trying to do it
21 in such a way that we don't interfere with it being used
22 for industrial, or if you want it to convert to
23 residential or recreational, we're trying to do it in
24 such a way that it would not impair that use.
25 MR. W.A. GRIPP: Has the EPA the authority—
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1 does that building impact the EPA's decision at all?
2 MR. JAN ROGERS: Only in the—
3 MR. W.A. GRIPP: What would it have to do to
4 impact the EPA's decision?
5 MR. JAN ROGERS: Well, only in the—well, it
6 only impacts us from the perspective of considering
7 future use, of what's a reasonable assumption of future
8 use. This is crystal ball stuff, what's a reasonable
9 assumption.
10 MR. H.A. GRIPP: Right, and I understand that.
11 And that's where I'm going. Okay, therefore—now, I know
12 I visited that site with Sheri and so on, but have you
13 had an engineer, or someone with economic development, or
14 those specialty fields, look at that site? Realizing
15 that we give property away at the industrial site, now,
16 that's uncontaminated.
17 MR. JAN ROGERS: We're not economists.
18 MR. W.A. GRIPP: It is there for the taking,
19 bring your business and bring it to Barnwell, and here it
20 is.
21 MR. JAN ROGERS: Yeah. And we're aware of
22 that.
23 MR. W.A. GRIPP: Now, has anyone been contacted
24 from any of those fields to take a look at it from a
25 development standpoint, of what future use, or is that
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1 just a judgment call from—
2 MR. JAN ROGERS: Who did we have out there?
3 MS. PANABAKER: Richard.
4 MR. JAN ROGERS: Okay. We specifically made a
5 trip down to look in the building to determine is it a
6 dilapidated falling-down building that's a hazard to the
7 public, or is it just a building in ill repair.
8 MR. W.A. GRIPP: And that was that gentleman
9 f rcm -i/HECT
10 MR. JAN ROGERS: Yeah.
11 MR. W.A. GRIPP: And is he an engineer, or—
12 MR. JAN ROGERS: Actually, he's an engineer,
13 but that's not his profession as far as—
14 MS. PANABAKER: But he's not for examining
15 buildings.
16 MR. JAN ROGERS: Building integrity is not, you
17 . , know, his profession. You know... the whole issue of
18 future use is s. gut call. You try to weigh all the
19 positives and negatives.
20 MR. W.A. GRIPP: If Barnwell County were to
21 hire a person, or whatever, to take a look at that to
22 represent Barnwell County as to meet with our economic
23 development people, the Tri-County Alliance, and a
24 specialty outside of the Barnwell County, would you
25 accept a recommendation from them?
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1 _ MR. JAN ROGERS: No. Because, to some extent,
2 it becomes bias, but that's not really the main reason.
3 There's just as hard, as difficult an ability to view a
4 real demand for the property for residential. We've had
5 those discussions internally. We don't see that going
6 residential. Ballpark makes some sense. Recreational,
7 maybe, if there's really a demand for it. But, you knowf
8 it's a tough issue of cutting, you know—us going out—we
9 take on some personal potential liability of going out
10 and saying, "Well, we think it's a good idea, let's just
11 go out and knock the building down and deal with that."
12 It's not a contamination problem.
13 MR. W.A. GRIPP: Well, that's why I'm saying an
14 independent, an independent agency take a look at that
15 and give a recommendation, if that is their professional
16 forte.
17 MS. PANABAKER: _ One other main point, though,
18 when we're picking between residential and industrial, a
19 resident is saying there's a child under six sitting in
20 the back yard every day, X hours a day, eating X dirt.
21 You don't have that same child doing that at a ballpark.
22 The kids do not go to the ballpark every single day, sit
23 six hours in the dirt and eat whatever. So—
24 MR. W.A. GRIPP: But right now, I'm talking—
25 right now, I'm just talking about the building issue.
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1 That's why I'm asking if you would entertain a
2 professional with that's his forte to investigate that,
3 and would that have any impact on the EPA agency?
4 MR. JAN ROGERS: Well, it would be additional
5 information we would consider. It wouldn't drive the
6 decision necessarily.
7 MR. W.A. GRIPP: Well, I'm not say drive the
8 decision, but at least that you could look at.
S ' - :-:£.. VL.-ST -ROGERS: Yeah. Be~au&«=/ you know, I m
10 going to sit here and say, well, you wouldn't like it as
11 a community, maybe, but somebody might come in here and
12 want to use that just to store junk, or close to it,
13 because you were willing—
14 MR. W.A. GRIPP: I'd like to know who that
15 somebody is.
16 MR. JAN ROGERS: Well, no, because you were
-17 • willing—my guess is it ends up ir. ycur hands fcr taj:
18 default.
19 MR. H.A. GRIPP: It does.
20 MR. JAN ROGERS: And you were willing to give
21 away the property if somebody was willing to come in and
22 fix up the building and turn it into some useful purpose.
23 They're not going to put a lot of money into it, maybe,
24 but turn it back into a useful purpose, you may cut that
25 deal. You know, there's a lot of what-ifs that we could
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1 get into, and scenarios. It makes it very difficult to
2 deal with—
3 MR. W.A» GRIPP: Well, my only question was,
4 sir, would you consider that fact from an independent?
5 MR. JAN ROGERS: Sure.
6 MR. W.A. GRIPP: Not from Barnwell County, not
7 from—I'm just saying an independent that that is his
8 forte; that building, what future use you could have.
9 MR. JAN ROGERS: Okay, the problem is, all that
10 does is change our cleanup goal. We're still not going
11 to knock the building down. So—and Sheri's best guess
12 is it probably—you know, it's a best guess. Even if we
13 drop the cleanup goal, which is predominantly lead, from
14 1150 to 400, we're not talking a lot of extra volume.
15 MS. PANABAKER: It doesn't change how we clean
16 up the site, it just changes a little bit of soil. A
17 little bit more soil might be picked up.
18 MR. JAN ROGERS: Yeah, it just changes the
19 amount of soil we have to address and what concentrations
20 we leave on the surface, a difference between 1150 and
21 400, maybe. Even if we chose to say, "Okay, this makes
22 sense," and I'm not sure 400 is a good number for
23 recreational. That's a residential number and those are
24 calculated based on realistic—well, realistic guess of
25 what's a rational exposure frequency. Recreational
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1 people are going to be out there maybe an hour or two,
2 two or three times a week, but that's different from a
3 child playing in the back yard type thing.
4 And typically, children playing in the
5 back yard, to be most conservative, we look at zero to
6 six years old. Most six-year-olds, you may see at the
7 ball park, or recreational park, but you won't see two-
8 year-olds out there a lot.
9 So we would h:y<" to rcialculat«: ovt;: I'^r
10 recreation on what would be the cleanup goal. It would
11 only change how much soil needs to be dealt with and what
12 would be the residual. The residual contamination left
13 on the surface around the site that wouldn't be dealt
14 with. It wouldn't change the idea that some of it could
15 be left on site. But we think we structured it in such a
16 way that the stuff to be left on site is relatively non-
17 imposing. The stuff that would be left with basically
18 just a cover isn't much of a threat to public health,
19 it's really a threat to groundwater.
20 MS. ELLEN FITZENRIDER: I'll give Bill a chance
21 to catch his breath. My name is Ellen Fitzenrider. I am
22 a chiropractor here in town. I'm also the chairman of
23 the Board of Directors of Chamber of Commerce. I am also
24 in the process of organizing Barnwell County's first
25 Earth Day this coming April.
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1 _ And first, I'd like to address a comment
2 that you made. Barnwell County residents know all about
3 the not-in-my-back-yard syndrome. We've got SRS here,
4 we've had Chem Nuclear here. Chem Nuclear is a facility
5 that was built for what it does. It's a containment
6 situation. It's regulated and it's there. And I get
7 newspaper clippings from my relatives up north about this
8 radioactive waste in the Barnwell dump. Well, it's New
9 Jersey's low level radioactive waste that is being sent _
10 here. So we know what it's like to have something in our
11 back yard.
12 MR. JAN ROGERS: Yeah. Actually, it shouldn't
13 be New Jersey's, but it takes the Southeast compact.
14 MS. ELLEN FITZENRIDER: I've heard that they
15 have received other than up in the northeast, where
16 there's a place in Oregon that they have gotten stuff
17 from; other places, but just as an illustration.
18 I guess the cap you're talking about is a
19 cement cap, something—
20 MR. JAN ROGERS: No, it could be earthen.
21 MS. ELLEN FITZENRIDER: Earthen?
22 MR. JAN ROGERS: Just basically to take away
23 direct contact.
24 MS. ELLEN FITZENRIDER: So, for example, this
25 arsenic and lead that's in the soil, how long will it be
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1 thare underneath this earthen cap?
2 MR. JAN ROGERS: Some of the arsenic is there
3 naturally and it'll be there indefinitely because metals,
4 they don't break down.
5 MS. PANABAKER: But it'll be treated with the
6 solidification process.
7 MS. ELLEN FITZENRIDER: I'm not too familiar
8 with those metals as far as what Shuron was using it for,
9 brt. for example, 30 ye:;rs *gcr they were usin
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1 conclusion, that the Shuron building was not in the type
2 of shape that they could readily rent it. There was
3 asbestos also in the building, and it's an awkward size
4 and it just was not rentable or usable to their
5 standards. They're expanding out towards the airport. I
6 don't know if anybody was aware of that.
7 I've been living in Barnwell now for
8 almost seven years. I've seen residential areas being
9 expanded out that way, I've seen residential areas
10 expanding that way, industry is going that way, and it's
11 growing. A few years ago when all the layoffs hit SRS
12 and everybody panicked, we thought, "What's going to
13 happen to Barnwell County?" Well, it's kind of nice down
14 the road to see what has happened to Barnwell County, and
15 all the things people were afraid about didn't come to
16 pass. We've gotten businesses. Now, the SRS is talking
17 about other things, but we are growing and we'll continue
18 to grow and expand, and we're heading that way. And that
19 site's not that far out of town. It's around the corner
20 from Reid's.
21 In this booklet, you also mention
22 something about—I'm trying to think. I'll tell you
23 what, I'll finish off with something else I wanted to,
24 and if I remember anything else, I'll just raise my hand
25 again.
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1 - MR. JAN ROGERS: That's fine.
2 MS. ELLEN FITZENRIDER: Just a personal comment
3 that many native American religions, I guess, or beliefs,
4 base their actions on the fact that—consider all your
5 decisions on the impact it will have for the next seven
6 generations to come, and some, they say, forever. And I
7 don't—I guess I'll leave it at that.
8 MR. JAN ROGERS: To talk about the metals
9 isuu&f' the iiUiiaio :,.•;--.iii.T.I • y zre there. Arsenic i~ a
10 naturally occurring metal. Probably not in the form it's
11 in. I believe it's related to buffing compounds they
12 used in some kind of a salt. But they don't go away.
13 Typically, the technology used is to immobilize them,
14 make them unavailable for exposure, and the simplistic
15 technology is probably more understandable cementation.
16 We call it solidification, fixation. You can get real
17 ••--• sophisticated, you can do all kinds of thing_s. ..but if you
18 put it in cement, generally, it's made unavailable for
19 two reasons; most metals, other than sodium, tend to not
20 be very water soluble in a very alkaline environmental,
21 which is what cement is.
22 So it works very effective, even for
23 metals that tend to migrate in a soluble form, such as
24 certain forms of chromium. And because it is solidified,
25 typically, it would not be left on the surface, it would
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1 be_solidified, subsurface covered, and that sort of gets
2 into the issue of how much engineering do you throw into
3 your cover. It's based on what did you put there in the
4 first place.
5 You know, years ago, the technology was
6 dig a hole in the ground where it looked like there was a
7 little clay and bury your waste. Some sort of
8 landfilling was related that way, too; for our domestic
9 waste. Things evolve. Even domestic waste landfills are
10 now seeing liners and other things put in them because of
11 the lack of control of what goes in there.
12 Typically, we're going to put fairly high
13 engineering controls on anything we put on site, but if
14 you look at the remedy, it's structured such that if it's
15 truly still hazardous; whether you treat it or not, if
16 it's a hazardous waste by definition of environmental
17 law, it's going off site. The only thing that would stay
18 on site is something that no longer is a hazardous waste,
19 but still poses a potential hazard. Which you're talking
20 about relatively low concentrations.
21 And the hazard typically is oriented
22 towards its leachability and it's ability to adversely
23 impact groundwater. The way we structured this is that
24 site has groundwater to about three to five feet. It's
25 readily impacted by anything that leaches. So anything
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1 irr the treated or even the natural state after it's
2 excavated that leaches above drinking water standards, we
3 said you would have to put in engineering controls and,
4 in essence, encapsulate it in an envelope to leave it on
5 site. That's not a desirable thing to do, and it's a
6 pretty expensive thing to do for smaller volumes of
7 waste, which drives the issue of economic comparison to
8 off site. That waste can be taken off site to
9 appropriate facilities and landfiiied wh'ezre they're
10 monitored and they're checked and they're watched and
11 they're supposed to take that kind of waste.
12 But we still have to look at cost.
13 There's a balance here of optimization between cost and
14 making sure it's protective. Either way, it's
15 protective, but we would also look, and I think even the
16 responsible party when they were doing it would look at
17 - long-term cost's. If you leave it-on site, you've got to
18 monitor it a long time. You've got to spend a lot of
19 money doing that. If it's cheap to go off site, we've
20 left the door open for it to go off site even in a
21 treated form. Even if it—well, at least if it doesn't
22 leach above MCLs, or drinking water standards, there's
23 really no reason for it to go off site, but even that's
24 open. I realize off site can be expensive. The disposal
25 fees off site have been dropping. Just as unemployment
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1 probably went up with the changes at Savannah River,
2 things change and, suddenly, you don't necessarily see
3 that impact.
4 Disposal fees for hazardous and other
5 waste have been dropping in some regards because of the
6 lack of volume. A lot of the environmental programs are
7 oriented toward giving industry incentives not to
8 generate the waste today. That doesn't solve the problem
9 with the past, but at least you have less generated. If
10 you have less generated, you have less going to the
11 facilities that were set up to take it, and they're still
12 in business, trying to stay alive, and they'll drop their
13 price to get more volume to deal with the economics of
14 the situation.
15 Those are things we don't know. We don't
16 know what it'll be two years from now. Neither does the
17 responsible party. We're tasked with creating a remedy
18 that is sound for protection of public health, considers
19 both on site, off site, considers future use as to how
20 clean is clean, and considers the economic part of it
21 because, in theory, the Government could be building
22 this, too. We don't anticipate that at this site, but in
23 theory, the responsible parties can back off and say, "We
24 don't like your remedy, you build it," and suddenly, we
25 have to use Federal money to build the same thing. We
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1 want it to be cost effective and protective, and it
2 creates the tug and pull of balance between how much
3 stays on site and how much goes off site and how do you
4 deal with those issues.
5 From a public perspective, it tends to
6 get emotional. The public would always like to see all
7 of it elsewhere. That's a normal response. And I've
8 only seen that occur once where somebody actually—a
9 public group stood up and said, "We don't want you to
10 take it to somebody else's back yard." Never happened
11 more than once that I know of.
12 But these concentrations we're talking
13 about are low. We're not talking about hot waste, we're
14 talking about residuals. Anything hot is leaving anyway.
15 And you're right; go out in the fields and you'll find
16 arsenic if you sample because it was used as a pesticide.
17 And so you irave, in essence, background levels of
18 arsenic/ which also creates a problem of, in other cases,
19 where a risk would suggest clean up to a certain level,
20 but that level is below background. You cannot clean up
21 below background. You don't know where to stop.
22 So, you know, there's a number of
23 considerations we have to make in figuring out the best
24 solution. We do want to hear the public input, and we do
25 consider all that input and, in fact, we'll try to
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1 finesse it as much as we can, but we do have some
2 barriers in that we don't have to authority to go out
3 and, say, knock down a building unless it were a chemical
4 problem, which we don't really see that.
5 So changing the use only changes how much
6 we clean up, and it really doesn't necessarily change—we
7 give some consideration, but we still look at the economy
8 as a scale.
9 MR-. W.A. GRIPP: And I just go back to dollars
10 and cents and that issue, that that is a major obstacle
11 in that future use of that property is questionable, and
12 what can we do with it? And also, I understand that you
13 have the contamination concerns, as well as we do, but
14 the cleaner that site is, the more options Barnwell
15 County will have to develop that for future use.
16 MR. JAN ROGERS: That's true, but some of it's
17 stigma and it's hard for us to deal with that.
18 MR. W.A. GRIPP: And because of that stigma,
19 that's why I'm saying that it's probably not going to be
20 an industrial park.
21 MR. JAN ROGERS: Oh, I know. You know, the
22 problem is you've got a building there. You know, the
23 majority of that property could be turned into a
24 recreational facility tomorrow. There's a big chunk out
25 in front of that building and it could be kept separated,
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1 so-, you know, it's not undoable.
2 MS. GALE KROGH: Would you like it in your
3 little town?
4 MR. JAN ROGERS: Pardon?
5 MS. GALE KROGH: Would you like it in your
6 little town?
7 MR. JAN ROGERS: Some people have it in their
8 little town.
3 MS. GALE KROGH: I didn't say tliaf, I said
10 would you like it?
11 MR. JAN ROGERS: It doesn't matter. Like I
12 said, the normal response from the public is, "I don't
13 want it in my back yard." That's a proven response, and
14 that's an understandable response. But we've got to
15 weigh all the considerations. We can't say, at any cost,
16 take it elsewhere. And if you run the economies right
17 • -new, taking -it elsewhere is sigr.if-icant-Iy different in
18 cost.
19 MS. PANABAKER: No, they're about the same
20 right now.
21 MR. JAN ROGERS: In some scenarios, yeah.
22 MR. H.A. GRIPP: There are areas, landfills,
23 for exactly that purpose, to take those contaminations.
24 MR. JAN ROGERS: Another—
25 MR. W.A. GRIPP: But I don't want to take up
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1 somebody else's--
2 MR. JAN ROGERS: Yeah, if you—let me get one
3 other theoretical issue in here. To a responsible party,
4 they sometimes raise the question of, "We don't want it
5 going somewhere else because of Superfund liability. If
6 you take my waste over there and that site goes bad five
7 years from now, I'll be in one heck of a litigation
8 battle over something I had no control of and may not
9 have even contributed to, but somebody will have a record
10 my waste went there." And that's a very difficult factor
11 to weigh into cost—economy is a scale on cost balancing.
12 But that's another factor that most people will overlook.
13 You take it somewhere else and it's not like there's ever
14 been—there's never been a RCRA facility that didn't go
15 bad. There's a few notable ones, actually, around.
16 MR. RONNIE RUTHERFORD: I have a question about
17 the building. I've never been in it and don't know the
18 condition or the size of it, but say for worst case
19 scenario, we decide to turn it in to, like, a recreation
20 park with a skating rink, bowling alley, putt-putt golf
21 course, or—is it feasible that the building could be
22 used for something like that for use in the town, or—I
23 don't know, I've never been in the building.
24 MR. JAN ROGERS: Yeah, the big debate right now
25 seems to be that it's going to be—the roof leaks. It's
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1 go-ing to be fairly expensive to fix the roof, is what we
2 heard from a quick look.
3 MR. W.A. GRIPP: It's been gutted and the roof
4 more than leaks.
5 MS. PANABAKBR: Buildings can all be fixed,
6 it's just how much money. If it turns out it's cheaper
7 to knock it down and build a new one than fix the one you
8 have, but I don't—we can't—we don't know.
9 " " " MR. RONNIE Roi'nERFORD: Well, that was my next
10 question. Is there enough area left, if you didn't use
11 the existing building, to could build in front of it,
12 maybe a bowling alley or skating rink or something like
13 that that could be used for the teenagers in town, a
14 place of them to go? Is that a possibility?
15 MR. JAN ROGERS: There should be a map in here
16 that shows the property. It's a pretty good chunk of
17" * property out in front of it. It gfe'cs a little odd with—
18 I mean, it basically makes the building totally unusable
19 if you do that in some scenarios, but it's certainly
20 better if the building is not there, but there's a big
21 chunk of property out there.
22 MR. RANDY REECE: Randy Reece from Barnwell
23 High School. As far as the cleanup goes, who covers the
24 cost for that?
25 MR. JAN ROGERS: Superfund has a trust fund
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1 that basically is there to allow the Government to clean
2 up sites. But the thrust of the program is toward trying
3 to find the people who are responsible for the liability
4 associated with the cleanup, as is the way the law is
5 worded. It's basically owners, operators and any
6 transporters who had anything to deal with generating or
7 carrying the waste there. We go to them and basically
8 try to enter into agreements whereby they do the work.
9 Now, that's what happened on the front end of this; they
10 actually did the studies, but they didn't just do them on
11 their own, we basically oversee it, review it and direct
12 it, make sure it suits our needs as far as being unbiased
13 and a true evaluation of the problem at the site. But
14 it's their money paying for the work.
15 And then, when we sign the record of
16 decision, which will lay out, "This is what we think
17 needs to be done at this site," we'll re-enter
18 negotiations for the responsible parties to implement the
19 work. They can enter into an agreement to do that, or
20 they could decide not to; we would go build it and then
21 pursue litigation to recover those monies.
22 And the trust fund is really not even
23 taxpayer money at that—initially. It's tax on industry;
24 it was until it lapsed. So the original trust fund that
25 runs the program is generated by a tax on the industry
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1 that typically deals with the kinds of chemicals that
2 creates hazardous waste problems. We feed off of that
3 money to run the program and implement the program, but
4 we also try to get enforcement first and get the
5 responsible parties to do as much of that under orders
6 and agreements.
7 MR. RANDY REECE: As far as what goes there,
8 I'm president of FCA, Fellowship of Christian Athletes at
5 Darnweil High School, and I go to a lot o± students-
10 houses and talk to them, the ones that are having
11 troubles and stuff, and supposedly 75 percent of them say
12 that their lives would probably be different if there was
13 somewhere in Barnwell to go because people don't have
14 transportation or; for some reason, can't get out of town
15 to go to, like, Aiken or Augusta, and so they say that
16 they don't think they'd be as troubled if they had
17- something-to do because, when they don't have something
18 to do, they go off with the wrong crowd and do some
19 things they shouldn't. So I do think it'd be a pretty
20 good idea for a recreational facility.
21 MR. JAN ROGERS: Like I say, we have no reason
22 to oppose that, and any implementation would be—we would
23 attempt to do it in such a way that it shouldn't hinder
24 it, as best we envision what we would do today.
25 MR. WENDELL GIBSON: You mentioned awhile ago
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1 that there was different standards—I'm Wendy Gibson, I
2 live on Camelia Street right near the site.
3 MR. JAN ROGERS: All right, finally somebody
4 that lives near it.
5 MR. WENDELL GIBSON: You mentioned that there
6 were different standards for residential and recreation.
7 MR. JAN ROGERS: Well, it's not a standard, per
8 se. There's very few regulated standards on what's
9 acceptable exposure. Most of it relates to drinking
10 water; that's a well-known issue. When it comes to soil
11 and consumption and exposure to solid type material
12 that's potentially a hazard, the methodology is what we
13 call risk assessment. You figure out the exposure
14 mechanisms, the paths by which it would be absorbed and
15 dosed; you buy the material, you figure out what is a
16 realistic dose. You go out and take 100 samples, it'd be
17 100 different concentrations. You've got to use some
18 statistical averaging and other things and come up with
19 what's a reasonable expectation for the activity that
20 occurs there.
21 And what we typically do is look at a lot
22 of them. We'll look at residential, which typically, the
23 most extreme residential is a zero- to six-year-old child
24 in the back yard playing in the dirt, and there's known
25 effects of how much soil they tend to consume in that
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1 activity.
2 Industrial, you've got workers there
3 eight hours a day, or ten hours a day, wandering the
4 place five days a week, doing something outside. So,
5 there's different assumptions on some of the factors that
6 create the exposure. That has to be considered to figure
7 out, first of all, how much are you being exposed to so
8 we can calculate the equation to say is it an
9 unacceptable risk based on the chemical's specific nature
10 of exposure.
11 Once we determine it's not acceptable,
12 you've triggered Superfund response, and in order to
13 figure out what is acceptable, we tend to put in what is
14 the goal for risks, an acceptable risk, and back
15 calculate to a concentration that you would have to clean
16 up to. And that's where you see, quote, the standards—
17 they're not really standards, they're calculated numbers
18 to determine how much would you have to remove in order
19 to make the site safe for the expected use.
20 MR. WENDELL GIBSON: There will always be zero-
21 to six-year-olds sitting on the sidelines eating the dirt
22 while their older siblings are out taking part in the
23 recreation at a ballfield, something like that.
24 MR. JAN ROGERS: Sure, but they're only there
25 two or three days a week, maybe. I mean, if it's a
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1 child, we're going to put them in the back yard seven
2 days a week at a residence, so it does change the amount
3 of exposure and, therefore, the amount of chemical
4 they're exposed to because of the frequency.
5 MR. WENDELL GIBSON: Now, they say that the
6 roof is leaking now.
7 MR. JAN ROGERS: Yeah.
8 MR. WENDELL GIBSON: If we go through with your
9 choice and your preferred method of dealing with this,
10 what time frame are we looking at before it may be used
11 for, say, as an industrial site in the future? What—do
12 you have a proposed time frame for the cleanup period?
13 MR. JAN ROGERS: We really avoid giving out
14 those kinds of answers because we're always wrong.
15 MS. PANABAKER: I've learned that.
16 MR. WENDELL GIBSON: I'm only saying that
17 whatever it is, perhaps the roof caves in by that time,
18 which the demolition costs, most contractors will tell
19 you that it would be almost as physically achievable to
20 build a new building rather than go in and take one out
21 and start over, and so, you know, what's the—why are we
22 trying to save this dilapidated 40-year-old building with
23 the leaking roof?
24 MR. JAN ROGERS: We're not trying to save it so
25 much as we're saying the building is there. The building
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1 is. an impediment to recreational use in some ways. If
2 you want to use all the property, the building's in the
3 way. And nothing we're going to do from cleaning up the
4 site should have us over there removing the building, as
5 best we understand it today, because it's not a chemical
6 problem, it's a derelict building problem. And local
7 governments deal with that somehow, someway, and I'm sure
8 there must be Federal money, which we've--you know, we've
9 tried to give some ideas of places to look;
10 We're not against the building going
11 away, but it gets down to what is a reasonable future
12 use. Recreational has some merit, but the building sort
13 of impairs that. And we don't see the building going
14 away, and we're not going to take it away, and we can't
15 order the responsible party—in our mind, we don't think
16 we should be ordering the responsible party to do it
17 because it's not a chemical problem.
18 MR. WENDELL GIBSON: It's going to fall in
19 sooner or later.
20 MR. JAN ROGERS: There will be other buildings
21 in Barnwell that do that same thing that have to be dealt
22 with, probably, is my guess.
23 MR. RONNIE RUTHERFORD: Well, what I was going
24 to say is like Ellen said, 75 or 100 years from now, it's
25 now going to be turned into a residential area, so why
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1 not go ahead and clean it up like it's going to be
2 residential to start with?
3 MR. JAN ROGERS: Well, if we clean it up and
4 leave anything on site, we'll leave D notations such
5 that, in theory, people trying to convert it to
6 residential will know that it's there and shouldn't be,
7 but it's not our plan to restrict use of property. We
8 don't know what 100 years will be like. There may be a
9 tremendous demand on property around here 100 years from
10 now and somebody might want to pay the difference to
11 clean up the difference to make it residential.
12 MR. RONNIE RUTHERFORD: That's what I'm saying,
13 while you're getting the cost from whoever's--like,
14 Shuron, if they're liable, or whoever—
15 MR. JAN ROGERS: They're not liable for that.
16 That sounds like a free ride.
17 MR. RONNIE RUTHERFORD: Okay, whoever is
18 liable, in other words, while you're getting the cost to
19 clean it up, go ahead and get it cleaned like it should
20 be instead of paying 10 times the cost 20 years down the
21 road.
22 MR. JAN ROGERS: Okay, but you're saying it
23 should be residential. What we're saying is we have to
24 make an informed decision about what's the realistic—I
25 think the real terminology, the reasonable future use
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1 scenario.
2 MR. RONNIE RUTHERFORD: I would think, over the
3 years, like Ellen said before, 50 or 75 years down the
4 road, there's a good chance it would be residential out
5 there.
6 MS. ELLEN FITZENRIDER: In fact, that road,
7 that's the only industrial site. Everything nearby is
8 all residential around there.
9 MR. JAJcT ROGERS: It would be a county
10 maintenance area, too.
11 MS. ELLEN FITZENRIDER: As opposed to other
12 areas that's—
13 MR. W.A. GRIPP: I don't want that. I've got
14 enough contamination.
15 MR. JAN ROGERS: I mean, you know, this is
16 cheap property. I can see some things going on here.
17 No, you know, there's no problem with people comia
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PROPOSED PLAN MEETING - JANUARY 22, 1998
1 but it's our feeling that the difference is a relatively
2 small volume, and if it were a relatively small volume—
3 MR. W.A. GRIPP: Well, I think that's a very
4 major barrier in this whole thing.
5 MS. ELLEN FITZENRIDER: Didn't you say at the
6 beginning that the cost of removing everything is about
7 the same as what your proposal is?
8 MR. JAN ROGERS: Yeah, but these numbers are
9 pretty soft. I mean, they're—
10 MS. ELLEN FITZENRIDER: Well, more or less.
11 It's not like you're asking them to spend three times as
12 much money as—
13 MS. PANABAKER: But it's like he talked about
14 earlier, we don't know what the liability would be if
15 they take it somewhere else.
16 MR. JAN ROGERS: Yeah, and, see, that's the
17 thing we can't write off.
18 MS. PANABAKER: And we've left it both ways to
19 figure it out better when we're actually doing the
20 cleanup and we actually know the volume of soil. We're
21 guessing on the volume now, we're guessing what it would
22 cost to go off site, we're guessing what it will cost to
23 solidify it. There's nothing written down, "This is my
24 fixed price bid, I'm sticking to this no matter what."
25 So—
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1 - MR. W.A. GRIPP: And also, the Three Rivers
2 landfill that will be opening up, those are not fixed
3 price right now. They are for the member counties for
4 household waste, but not—not for any type of hazardous
5 waste.
6 MR. JAN ROGERS: Yeah, that'll always
7 fluctuate. And that won't be hazardous, it'll just be
8 industrial waste, won't it? They're not hazardous waste
9 j.anol£ills, are they, per se?
10 MR. W.A. GRIPP: No.
11 MR. JAN ROGERS: They're industrial, at best?
12 MR. W.A. GRIPP: Right.
13 MR. JAN ROGERS: And, you know, that's—the law
14 is there to create a cleanup of problems that occurred in
15 the past that weren't illegal. Generally, there's—you
16 know, there's a lot of these things around the country.
17 The law is there to clean them up and restore them to a
18 protective level for the public. Where it gets into the
19 big debate is what's the future use. Future use can be
20 debated a long time and, you know, people will take
21 positions. You should have heard some of our internal
22 discussions about this site. You've got a new industrial
23 park. You're not going to push anybody over towards that
24 building.
25 MR. W.A. GRIPP: Hell, no. why would you?
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1 Sir, have you visited the site?
2 MR. JAN ROGERS: Yeah. Haven't been in the
3 building, itself, but I've been around the building.
4 And, you know, I've seen the area. I want to come back
5 and look at it some more, but the—
6 MR. W.A. GRIPP: I'd be more than happy to take
7 you through a tour.
8 MR. JAN ROGERS: Well, Sheri wants to, too.
9 MR. W.A. GRIPP: Okay.
10 MR. JAN ROGERS: But you ought to think about
11 that. That's a good county maintenance yard area.
12 MR. W.A. GRIPP: No, sir. Barnwell County has
13 enough problems without taking on any more of EPA's.
14 MR. JAN ROGERS: Are there other—
15 MR. FLOWE TREXLER: Let me ask a question. My
16 name is Flowe Trexler and I'm with the County Council.
17 On your page 18 and 19, are those figures inclusive to go
18 from one to seven and add up to 11.8 million?
19 MR. JAN ROGERS: No.
20 MS. PANABAKER: No, each one—read it down—
21 MR. FLOWE TREXLER: Oh, you've got to add each
22 one—
23 MR. JAN ROGERS: No, no.
24 MS. PANABAKER: No, no. This is the cost for
25 this remedy, this is the cost for this remedy. It just
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1 goes straight down the page.
2 MR. FLOWE TREXLER: Well, what I'm trying to
3 decide, I don't know that I can read it well enough to
4 say—are we talking about a 12 million dollar job, or are
5 we talking about a 20 million dollar job?
6 MS. PANABAKER: The groundwater, you add it to
7 the soil. If that was your adding question, yes.
8 MR. JAN ROGERS: Yeah, they're two components.
9 Now just the soil, each alternative has different costs
10 for the soils. Whichever one is picked has a cost. The
11 groundwater—
12 MR. FLOWE TREXLER: Well, when are they going
13 to move along and make a final decision?
14 MR. JAN ROGERS: Pretty soon.
15 MR. FLOWE TREXLER: Then you can get around to
16 Wendy's thing of the time when you're going to get it
17 done, then.-
18 MR. JAN ROGERS: That's right. Yeah, I need to
19 go into that. I'll give you a general concept of it,
20 which we're trying to speed up, because it's so
21 embarrassingly slow. But the remedy is, what, in the 12
22 million range?
23 MS. PANABAKER: The soil part.
24 MR. JAN ROGERS: The whole remedy is where?
25 MS. PANABAKER: The whole remedy is—let's see,
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1 soil is 11 to 15 and the groundwater is two and a half to
2 five.
3 MR. JAN ROGERS: Yeah. The two and a half to
4 five is a broad range because it could go a long time, or
5 it could go a short time. Changing the time changes the
6 cost. But you're talking 15 million dollars which is not
7 just, you know, pocket change for a little site.
8 MR. H.A. GRIPP: And an awful large
9 corporation.
10 MR. JAN ROGERS: Yeah, well, we're not allowed
11 to use that factor. It could be the Government paying
12 it, although we'll sue them and spend three times as much
13 getting it back, but—in litigation costs.
14 Time line; we sign a record of decision.
15 We'll go out with a notice to the responsible parties,
16 which, in this case, is pretty much Textron, and
17 basically notice them that a decision has been made, we
18 want to enter into negotiations for them to do the—
19 implement the remedy.
20 Depending on how we do that, we could do
21 it with a unilateral order that might get them started
22 quicker versus negotiating a consent decree, which the
23 system does allow for negotiation with consent decree.
24 That's not necessarily advantageous in all cases, and we
25 can't make them sign a consent decree, so some of the
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1 things we're doing in the program now is trying to find
2 ways to issue the order and give the opportunity to
3 negotiate consent decrees at the same time so we can move
4 the work forward.
5 But, in essence, what you—that usually
6 takes up to six months, and in a real bad day, it takes a
7 year and a half. So, that's something we're trying to
8 work on, is not so much down time for negotiations versus
9 yviL them committed to doing it, or else we'ro c^Lvr io
10 commit to do it, and get somebody tasked with starting to
11 design it out.
12 The design phases typically takes a year
13 because you do have to go back and do some field proofing
14 of the data, make sure things haven't changed, now that
15 you've honed in on a specific remedy. In this case,
16 we've suggested treatment. There needs to be some
17 treatability studies, bench scale and otherwise, to look
18 at how successful would they be at immobilizing the
19 leachability of these compounds.
20 So, you know, those things have to be
21 done. This isn't just design like design a building;
22 this is do some additional finessing of the remedy that's
23 now selected, and then design how would you implement it,
24 which starts to give you the footprint of where would you
25 place it, how much of a footprint is it going to create
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1 on_the property.
2 To some extent, that's still a challenge,
3 though, because we've made this a three-tiered system.
4 If it's still hazardous, it's out. We don't know how
5 much of it is still hazardous till after you dig it up.
6 The stuff you treat, if it comes in at one treatment
7 scheme, you've got to build a Subtitle D facility to
8 leave it on site, or pay to send it off site. Those are
9 pretty realistic options when you're, you know, from a
10 technical field perspective and spend the money.
11 And if you can treat it down to causing
12 no threat, to groundwater or anything else, you might
13 consider leaving it on site. Nobody is going to know
14 what those volumes are without doing a little more coring
15 and sampling and treatability studies. And even then,
16 it's a guess. Until you dig it up, you don't know.
17 And another thing that our division
18 director has already mentioned is don't implement
19 anything that creates a big pile and leaves it there for
20 awhile because the community will go crazy. So, you
21 know, the design phase has to consider a lot of things of
22 the logistics of how do you do this and get it done
23 appropriately when there will always be a certain amount
24 of unknown about the volumes you're going to deal with
25 until you dig it up and treat it.
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1 - MR. FLOWE TREXLER: Sir, if I'm reading you
2 right, though, you're talking about two and a half years
3 before you remove any dirt.
4 MS. PANABAKER: Probably so.
5 MR. JAN ROGERS: Possibly two years. Could be
6 two years or more.
7 MR. FLOWE TREXLER: And it'll take you another
8 year to clean the site up; you know, the building may
9 fall down.
10 MR. JAN ROGERS: Well, that's true. Then we'll
11 have a hazard for the workers working out there. No.
12 It—the building is sort of a separate issue. But no,
13 realistically, it probably will be a couple of years
14 before you see cleanup. We're going to try to find ways
15 to speed that up, but if you look at the--even the recent
16 history of the program, it will be a little while before
17 you see people digging up soil and dealing with it.
18 Now, we'll still have monitoring, we'll
19 still make sure it's not going anywhere and adversely
20 impacting anybody. It's not really doing that at this
21 point. Groundwater doesn't migrate quickly, so that's
22 not necessarily a problem in the interim.
23 MR. FLOWE TREXLER: I came to this meeting
24 tonight hoping that I was going to find out that y'all
25 were going to start next month.
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1 MR. JAN ROGERS: That's sort of like optimism.
2 We'll work on that.
3 MS. PANABAKER: I used to have optimism.
4 MR. JAN ROGERS: No, we would like to be
5 signing a ROD next month/ but even that might be
6 debatable. Public comment, what, closes—
7 MS. PANABAKER: The 4th.
8 MR. JAN ROGERS: —the 4th of February. We've
9 still got to take all the comments, do a responsiveness
10 summary and kind of—that all becomes part of the record,
11 as to how we respond to the comments and the
12 considerations and everything because we don't really—
13 people go away thinking we just ignore the public
14 comment. We don't ignore it.
15 MR. FLOWE TREXLER: Just joking, but you've got
16 job tenure just on this one site.
17 MR. JAN ROGERS: No, no, this Congress wants to
18 change that, too. No, that's not the goal, the goal is
19 to get it cleaned up as quick as possible, and we're
20 trying to do some creative things to get it done more
21 quickly. But you can't just run out and dig either.
22 The reason our division director said
23 don't put a pile there is because we did in another state
24 at another kind of site, dug up an awful lot of soil and
25 left a pile there, and it has created a huge number of
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1 problems for the last three and a half years. So, there
2 does need to be some thought and work done in the design
3 phase.
4 Any other questions?
5 MS. ELLEN FITZENRIDER: What type of hazard do
6 you see right now, not necessarily groundwater, but with
7 the marsh waters and the wetlands in there as far as
8 downstream?
9 MR. JAN ROGERS: Snakes.
10 MS. PANABAKER: We have ecological cleanup
11 numbers established for the wetlands to protect the flora
12 receptors.
13 MS. ELLEN FITZENRIDER: I mean, I'm just
14 curious as to what has been going on, or what type of
15 impact has it had?
16 MR. JAN ROGERS: Have we actually seen an
17 impact? I don't think we've—
18 MS. PANABAKER: I haven't seen one, no.
19 MR. JAN ROGERS: We expect there are
20 concentrations of the polishing compound, which is mostly
21 metals, are elevated enough that we'd propose taking a
22 significant amount of the compounds out in the marsh out
23 because they would be adverse to the community of
24 organisms out there. But it's not like you see
25 everything devoid of organisms.
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1 _ The organics that are in the groundwater,
2 there may be a little bit of leaching into the marsh at
3 the fringe.
4 MS. PANABAKER: Well, in the source area, it's
5 down below the water table, so that continues to leach
6 into the groundwater; that needs to come out.
7 MR. JAN ROGERS: But interestingly enough, the
8 organics have less impact, I guess, on the eco part than
9 the metals do, in a theoretical sense. It's not like you
10 can go out there and see dead animals or see impact. We
11 don't see that kind of—
12 MS. ELLEN FITZENRIDER: Not any fish or
13 anything?
14 MR. JAN ROGERS: No. I mean, she's walked the
15 marsh, I haven't. I don't want to walk the marsh because
16 I don't like snakes, and there are a lot of them in
17 there.
18 MS. PANABAKER: Any more?
19 MR. JAN ROGERS: Yeah, why don't we go ahead
20 and—unless you have some more questions, why don't we go
21 ahead and cut off the formality of the meeting, and we're
22 still here if y'all want to ask more questions informally
23 or anything.
24 MS. PANABAKER: Thanks for coming.
25 [PROCEEDING CONCLUDED AT 8:32 P.M.]
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CERTIFICATE
SOUTH CAROLINA
BARNWELL COUNTY
I hereby certify that the foregoing Public Hearing was
reported/ as stated in the caption, by the method of
Stenomask with backup and reduced to typewriting by me or
under my direction; Lha'c lii« fOTegoing pages 1 through 69
represent a true, correct, and complete transcript of the
proceeding held on the 22nd day of January, 1998.
This 27th day of January 1998.
/0.
ALICE D. BONI, CVR
CERTIFIED COURT REPORTER
NSVRA CERTIFIED
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APPENDIX B
STATE OF SOUTH CAROLINA CONCURRENCE LETTER
SHURON SUPERFUND SITE
-------
D H E C
MOTE PROTECT PROSPER
2600 Bull Street
Columbia, SC 29201-1708
July 17, 1998
VC
CO
rr:
Mr. John H. Hankinson, Jr.
Regional Administrator
U.S. EPA, Region IV
Atlanta Federal Center
61ForsythSt.,SW
Atlanta, GA 30303
RE: Shuron Superfund Site - Record of Decision
Dear Mr. Hankinson:
The Department has reviewed the revised Record of Decision (ROD) dated June
11, 1998 for the Shuron site located in Bamwell, S.C. and concurs with all parts
of the remedy, except for the Remedial Goal for lead contaminated soils. The
Department has determined that an acceptable lead cleanup goal in soils is 895ppm.
If the implementation of the remedy selected in the ROD does not achieve this
cleanup goal, the Department may take a separate action to ensure the remedial
goal is met.
In concurring with this ROD, the South Carolina Department of Health and
Environment Control (SCDHEC) does not waive any right or authority it may have
under federal or state law. SCDHEC reserves any right or authority it may have
to require corrective action in accordance with the South Carolina Pollution
Control Act. These rights include, but are not limited to, the right to insure that all
necessary permits are obtained, all clean-up goals and criteria are met, and to take
separate action in the event clean-up goals and criteria are not met. Nothing in the
concurrence shall preclude SCDHEC from exercising any administrative, legal and
equitable remedies available to require additional response actions in the event that:
(l)(a) previously unknown or undetected conditions arise at the site, or (b)
SCDHEC receives additional information not previously available concerning the
premises upon which SCDHEC relied in concurring with the selected alternative;
and (2) the implementation of the remedial alternative selected in the ROD is no
longer protective of public health and the environment.
SCDHEC concurs with the selected alternative for contaminated soils and
sediments consisting of excavation and disposal. All soils designated as RCRA
hazardous waste will be disposed of at an off-site hazardous waste facility. Soils
determined to be RCRA non-hazardous waste will be either treated onsite or
disposed of at an approved off-site disposal facility. Soils remaining onsite will be
treated using solidification/stabilization and aeration. Treated soils that do not leach
SOUTH CAROLINA DEPARTMENT OF HEALTH AND ENVIRONMENTAL CONTROL
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John H. Hankinson
July 17, 1998
Page 2
above drinking water standards may be disposed onsite with an engineered cap. Treated soils that
continue to leach above drinking water standards will be disposed of in a RCRA Subtitle D landfill
to be constructed onsite. The determination of onsite versus offsite disposal will be made in the
Remedial Design phase based on cost. All wetlands that require remediation will be restored.
SCDHEC concurs with all remedial goals for contaminated media except for the lead remedial
goal in surface soils. The EPA has selected a remedial goal of 1150 mg/kg for lead in surface soil.
SCDHEC has selected a remedial goal of 895 mg/kg for lead in surface soil using a different
exposure parameter than EPA in the Region IV Lead Uptake Model for Industrial Exposure.
However, SCDHEC feels that the selected remedy will be protective of human health after the full
remedy is implemented.
SCDHEC concurs with the selected remedy for contaminated groundwater consisting of temporary
extraction for dewatering of soils during source removal and for an additional four to six months
after excavation. After the temporary extraction phase, a data gathering and evaluation phase will
be implemented. If determined to be applicable, Monitored Natural Attenuation may be applied
to the appropriate portions of the groundwater plume. Active groundwater treatment will be
implemented for all remaining areas of contaminated groundwater. If Monitored Natural
Attenuation is selected, a ROD Amendment or ESD will be performed if EPA or SCDHEC
determines either is necessary.
Sincerely,
R. Lewis Shaw, P.E.
Deputy Commissioner
Environmental Quality Control
cc: Hartsill Truesdale
Keith Lindler
Myra Reece, .Lower Savannah EQC
Gary Stewart
Richard Haynes
Yanqing Mo
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