PB98-963118
EPA 541-R98-087
November 1998
EPA Superfund
Record of Decision Amendment:
Geiger (C & M Oil) Site
Rantowles, SC
9/9/1998
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Amendment to the
Record of Decision
Summary of Remedial Alternative Selection
Geiger (C & M Oil) Site
Rantowles, South Carolina
Prepared by:
U.S. Environmental Protection Agency
Region IV
Atlanta, Georgia
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DECLARATION FOR THE
AMENDMENT TO THE
RECORD OF DECISION
SITE NAME AND LOCATION
Geiger (C & M Oil) Site
Rantowles, South Carolina
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action
for the Geiger (C & M Oil) Site, in Rantowles, South Carolina,
chosen in accordance with CERCLA, as amended by SARA and, to the
extent practicable, the National Contingency Plan. This .decision
is based on the administrative record file for this Site.
The State of South Carolina concurs on the selected remedy.
ASSESSMENT OF THE SITE
Since residually contaminated groundwater remains at the
site, the site groundwater needs to be monitored until RGs are
achieved.
DESCRIPTION OF THE REMEDY
This decision addresses the residual threat remaining at the
Site by monitoring the residually contaminated groundwater to
ensure the protection of human health and the environment.
The major components of the selected remedy include:
Monitored Natural Attenuation of residually
contaminated groundwater, including sampling selected
monitoring wells at the site.
DECLARATION
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.
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Because this remedy leaves contaminated groundwater, a review
will be conducted within five years after commencement of the
remedial action to ensure that the remedy continues to provide
adequate protection of human health and the environment.
Richard Green
Waste Management
Division Director
Date
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Amendment to the Record of Decision
Summary of Remedial Alternative Selection
Geiger (C & M Oil) NPL Site
Rantowles, South Carolina
1.0 INTRODUCTION
This Amendment to the Record of Decision and an earlier ROD
Amendment (1987 ROD and 1993 ROD Amendment), provides a current
status of activities that have been completed since the ROD was
signed for the Geiger (C & M Oil) Site on June 1, 1987, and the
ROD Amendment signed on July 13, 1993, documents the Agency's
decision to use Monitored Natural Attenuation to address residual
groundwater contamination, and incorporates the ROD and ROD
Amendment by reference (Appendices A and B). All other
provisions of the 1987 ROD and 1993 ROD Amendment • issued by EPA
not inconsistent with this ROD Amendment included herein remain
in full force and effect.
1.1 Site Location and Description
The Geiger Site (the Site) is located along Highway 162 in
Rantowles, Charleston County, South Carolina, approximately ten
(10) miles west of the City of Charleston (Figure 1) . The Site
is in a sparsely populated rural area. Approximately ten (10)
residences are located near the Site to the east and northeast.
The population in the immediate Site area is estimated at forty
(40) people. Several small businesses are located within a half
(0.5) mile of the Site along Highway 162. The property covers a
five (5) acre area of very little topographic relief, however,
the Site area is approximately one and one-half (1.5) acres in
size. This affected area is triangular in shape and is bounded
on two sides by ponds, and on the third side by a small rise,
approximately five (5) feet higher than the Site area.
Elevations on the Site range from approximately fifteen (15) to
thirty (30) feet above mean sea level.
1.2 Site History
On June 1, 1987, EPA selected a remedial alternative for the
Geiger (C & M Oil) Site cleanup which included:
- recovery of contaminated ground-water with on-site treatment
and discharge to an off-site stream;
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- on-site thermal treatment of excavated soils to remove organic
contaminants ;
- Solidification/Stabilization (S/S) of thermally-treated soil to
reduce mobility of metals;
- During Remedial Design S/S would be reviewed to determine if
S/S alone would achieve the remedial action goals; and
- During Remedial Design, soil cleanup goals would be refined.
A Potentially Responsible Party search conducted prior to the
commencement of the Remedial Investigation/Feasibility Study
(RI/FS) determined that there were no viable Potentially
Responsible Parties. EPA, therefore, conducted the RI/FS and,
since the signing of the ROD on June 1, 1987, EPA has conducted
additional field investigations in order to better characterize
and define the extent of the groundwater contamination. The
results of the analysis of the additional groundwater samples
showed only lead consistently above drinking water standards.
Based on the results of the additional groundwater samples and
because the revised remedy fundamentally changes the original
remedy, the Agency has decided to amend the 1987 ROD pursuant to
the National Contingency Plan (NCP), 40 C.F.R. §
300.435(c)(2)(ii).
1.3 Explanation of Fundamental Remedy Change
The 1987 ROD and 1993 ROD Amendment specified recovery of
contaminated groundwater with on-site treatment and discharge to
an on-site or off-site stream.
New information has been developed since the issuance of the 1987
ROD and 1993 ROD Amendment. First, the contaminated soils have
been treated to prevent further leaching of contaminants to
groundwater above drinking water standards. In addition, the
latest groundwater sample results have indicated that there is no
longer organic COCs iri any monitoring wells, and lead has been
the only inorganic COC consistently detected above drinking water
standards, and in only two out of approximately 27 monitoring
wells. Also, the level of lead has been decreasing in one of the
two contaminated wells, and is near drinking water standards.
The other monitoring well has had an increase in concentration,
however, temporary monitoring wells located between the site and
this monitoring well, did not show any detects of lead. In
addition, this well is located in an undeveloped area. Thus, it
does not appear that there is a definable "groundwater plume",
but very localized contamination, and thus, the area of
contamination is extensively smaller than originally thought.
Because the soil has been treated to prevent further leaching of
contamination to the groundwater, and because additional sampling
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conducted by EPA shows there is only one remaining COC,
consistently detected above drinking water standards in only two
very small localized areas, one of which is near drinking water
standards, EPA believes that the most cost-effective means to
address the residual groundwater contamination is Monitored
Natural Attenuation.
2.0 ENFORCEMENT ANALYSIS
A Potentially Responsible Party search was conducted in 1984
prior to the commencement of the RI/FS. It was determined that
there were no viable Potentially Responsible Parties.
3.0 COMMUNITY RELATIONS
EPA prepared a Record of Decision (ROD) on June 1, 1987, taking
into consideration the comments from the public. The most
environmentally sound and cost-effective remedy was then selected
as a part of the ROD phase of the Superfund process. EPA
selected thermal treatment of the soils to remediate the organic
contamination, S/S of the soils following thermal treatment to
remediate the inorganic contamination, and recovery of
contaminated ground-water with on-site treatment, and discharge
to an off-site stream. EPA also stated that during the Remedial
Design, S/S would be reviewed to determine if S/S alone would
achieve the remedial action goals. A public meeting was held in
January 1987 in which all the alternatives were presented. An
information repository was established and is located at the
Hollywood Town Hall in Hollywood, South Carolina, near Rantowles.
There was another public comment period for the first ROD
Amendment from May 25, 1993, until June 25, 1993. The Proposed
Plan for this ROD Amendment was available for review and comment
during the public comment period, June 30, 1998 to July 30, 1998,
and is a part of the Administrative Record File, as required by
CERCLA § 117, 42 U.S.C. § 9617, and the NCP, 40 C.F.R. §
300.825 (a) (2). No comments were received during the 1998 public
comment period and no requests were received for an extension of
the comment period or for a public meeting.
4.0 CURRENT SITE STATUS
4.1 Soil Contamination
The soil contamination at the Geiger Site has been addressed
using Solidification/Stabilization which involved using cement in
the reagent mixture. The area that was treated was triangular in
shape, as described for the old lagoon area, and was treated to a
depth of approximately ten feet below land surface. The purpose
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for treating the soils was to prevent further leaching of
contaminants to groundwater above drinking water standards, thus
protecting human health and the environment.
4.2 Hydrogeology
Groundwater Contaminants
The current areal and vertical extent of groundwater
contamination were delineated from several sources of
information. The original source of information was from the
Remedial Investigation (RI). Since that time,,additional
monitoring wells were installed in 1988. There are currently
twenty-seven (27) permanent monitoring wells on-site and off-
site, located in clusters of two to three wells, which range in
depth from approximately ten (10) to forty-five (45) feet below
land surface. After the new monitoring wells were installed,
these new wells and the wells installed during the RI were
sampled. There also have been several additional sampling events
since 1988; the last sampling event occurred in February 1997.
During the 1997 sampling event, the permanent monitoring wells
were sampled. In 1996 nine (9) temporary monitoring wells were
installed between the site and the one monitoring well that has
been increasing in lead concentration. Lead was not detected in
any of these temporary monitoring wells. The permanent
monitoring wells were also sampled at that time.
Sampling and analysis of the Monitoring wells from 1997 indicate
the following:
Lead was detected above Maximum Contaminant Levels (MCLs) in
wells MW-6s at 33 parts per billion (ppb) and MW-2s at 240 ppb.
It was not detected in any of the other monitoring wells in the
last two sampling events, either permanent or temporary.
No other contaminants of concern stated in the original 1987 ROD
were detected during the last two sampling events (1996 and 1997)
in samples collected from any of the permanent or temporary
monitoring wells. Cadmium, however, has been detected below or
just above its drinking water standard in MW-02s only, some of
the time.
Based on the sampling data, groundwater contamination has been
found primarily in the water-table wells located in the surficial
aquifer. There does not appear to be a definable "contaminant
plume", but two localized areas, one of which shows the
contamination is near MCLs.
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5.0 SUMMARY OF SITE RISKS
5.1 Public Health and Environmental Objectives
At the time the 1987 ROD was signed, there was no current public
health threat to off-site residents and no significant risk to
on-site workers under the reasonable case scenario via dermal
contact. Health risks associated with exposure by inhalation
were considered negligible. Nearby wells, which were located
upgradient, had not been affected by Site contaminants. There
are no nearby private wells located downgradient. Under the
future use scenario where the Site is developed and private wells
are installed, it was determined that soil remediation would be
necessary to prevent further leaching of contaminants into the
groundwater as well as recovery of the contaminated groundwater
in order to meet the remedial action objectives.
The waters of the surficial aquifer have been classified as Class
GB groundwater by the State. Class GB aquifers are considered
potential sources of drinking water and must be remediated to
levels that do not adversely affect human health and the
environment. Current sampling data indicates that one contaminant
in the groundwater consistently exceeds drinking water standards
(lead). At the present time, all residents have access to
municipal water.
6.0 ALTERNATIVES CONSIDERED FOR GROUNDWATER REMEDIATION IN
JUNE 1987 ROD
The present and proposed groundwater alternative being considered
for the Geiger Site are listed below in Table 2. For an in-depth
analysis of the other groundwater alternatives originally
considered, see pages 23 - 28 of the 1987 ROD.
6.1 Alternative Previously Selected For Groundwater
The selected remedy for groundwater, as specified in the 1987
ROD, was recovery of contaminated ground-water with on-site
treatment and discharge to an off-site stream. The 1983 ROD
Amendment allowed for the option of discharging to an on-site
stream. The selection of this alternative is now being
reevaluated because new information has been developed about the
nature and extent of the contamination at the Site and changes in
the relative costs of various remedies since the 1987 ROD and
1993 ROD Amendment.
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6.2 Description of Alternative Currently Being Considered
for Groundwater Remediation
Alternative A-l Monitored Natural Attenuation
Alternative A-2 Recovery of contaminated ground-
water with on-site treatment and
discharge to an on-site or off-site
stream.
6.2.1 Alternative A-l - Monitored Natural Attenuation
Alternative A-l consists of Monitored Natural Attenuation to
address the localized groundwater contamination. The area of
groundwater contamination has decreased significantly since the
original ROD was signed in 1987. In one location the lead
concentration has been decreasing, and is currently near MCLs.
The other monitoring well has shown an increase in lead
concentration, however, groundwater samples collected between
this well and the site, and behind the well also, have not shown
any lead contamination. In addition, the soils have been treated
to prevent further leaching of contaminants to groundwater.
For a detailed description of ARARs, see Sections 6.3(2) and 8.2
of this Amendment. The Monitored Natural Attenuation option is
currently estimated at $34,000 .
6.2.2 Alternative A-2 - Recovery of contaminated ground-water
with on-site treatment and discharge to an on-site or off-site
stream.
This alternative would consist of extracting contaminated
groundwater, treatment in an on-site treatment plant, and
discharge to an on-site or off-site stream.
At the time the 1987 ROD was signed, the estimated cost of the
groundwater remedy selected in the ROD was approximately $2.5
million. The estimated time period for this alternative is
greater than a year.
This alternative would treat the contaminants and reduce their
migration. For an in-depth analysis of this alternative,
including ARARs, see pages 23 - 28 of the 1987 ROD.
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6.3 Comparative Analysis
This analysis will compare the alternatives, A-l and A-2, for the
nine evaluation criteria detailed in the National Contingency
Plan (NCP). For a more detailed analysis of the remedy selected
in the 1987 ROD, see pages 23 - 28 of the 1987 ROD.
1. Overall protection of human health and the environment -
Both of the alternatives would provide overall protection by
reducing the residual threat by addressing the contaminated
groundwater. Both alternatives would meet the remediation goals
and be long-term protective of human health and the environment:
A-l by allowing Natural Attenuation process to address the
contaminated groundwater, and A-2 by extracting and treating the
contaminated groundwater.
2. Compliance with ARARs - Alternatives A-l and A-2 would meet
ARARs for groundwater. No waiver from ARARs would be necessary
to implement either cleanup alternative.
For an in-depth analysis of the application of ARARs to the
original remedy which would apply to the current preferred remedy
see page 36 of the 1987 ROD. This would include the Safe
Drinking Water Act.
3. Long-term effectiveness and performance - Both of the
alternatives would provide a permanent remedy for the groundwater
contamination. Therefore, either alternative would meet this
criterion and reduce the risk associated with groundwater
contamination at this Site.
4. Reduction of toxicity. mobility, and volume - Alternative
A-l would not reduce the toxicity, mobility, or volume of the
contamination through treatment, however, this alternative would
reduce the toxicity through a reduction in the contaminant
concentration levels in the groundwater through natural
attenuation processes. Alternative A-2 would reduce the
mobility and volume of contamination through treatment.
5. Short-term effectiveness - Alternative A-l would provide the
greatest short-term effectiveness, since this option only
consists of collecting groundwater samples. Alternative A-2,
however, would not be as short-term effective because of
construction activities of building the treatment plant and
installing the extraction wells.
6. Implementability - Both alternatives are technically
feasible. Since only groundwater sampling would occur for
Alternative A-l, this alternative is the most easily
implementable. Alternative A-2 is easily implementable and
reliable since extraction and treatment of groundwater has been
demonstrated at numerous sites.
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7. Cost - Both of the alternatives are protective of human
health and the environment. The costs associated with
Alternative A-l are significantly less than the costs associated
with Alternative A-2 and for this reason, Alternative A-l is the
most cost effective remedy.
8. State Acceptance - The State of South Carolina concurs with
the monitored natural attenuation alternative, A-l.
9. Community Acceptance - A public comment period was held from
June 30, 1998 to July 30, 1998. No comments were received during
this period nor was there a request for an extension to the
comment period.
7.0 SELECTED REMEDY
Based upon consideration of the requirements of CERCLA, the
detailed analysis of both alternatives, and public comments, EPA
has determined that Alternative A-l is the most appropriate
remedy for the contaminated groundwater at the Geiger Site in
Rantowles, South Carolina.
In addition, because most of the COCs stated in the original 1987
ROD have not been detected in the monitoring wells in the latest
sampling events, EPA is revising the COCs for the groundwater to
include only those contaminants detected above drinking water
standards in the latest sampling events. The revised list of
COCs will include the following contaminants and their respective
Remedial Goals (RGS) which are based on drinking water standards:
Lead - 15 ug/kg and Cadmium - 5 ug/kg.
The groundwater will be sampled for all of the groundwater COCs,
for the first five years. At that time, the parameters will be
revised to include only those that were detected in the
groundwater, above RGs, during the five year period. This is
expected to be inorganics only. Sampling of the groundwater will
occur twice a year for the first two years, and then annually for
3 years after this. At that time a different frequency may be
designated. Two additional monitoring wells shall be installed
between the Site and MW-02s. All the monitoring wells shall be
sampled during the first sampling event. If no COCs above RGs
are detected in the medium and deep monitoring wells, then only
the shallow monitoring wells shall be sampled for the remaining
five year period. If contaminants are detected above RGs in
these new wells or in the other monitoring wells (besides MW-06s
or MW-02s), on a consistent basis, at any time in the future,
this remedy will be re-evaluated. This remedy may also be re-
evaluated, if the detections in MW-06s or MW-02s continue to
increase significantly. In addition, groundwater samples from
the shallow monitoring wells located downgradient of the
solidified material shall be analyzed for the soil COCs and
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sulfate for the first two years. If the soil COCs (that are
different from the groundwater COCs) are detected in the wells,
then the wells will continue to be sampled and analyzed for the
soil COCs, and the remedy may be re-evaluated.
8.0 STATUTORY REQUIREMENTS
The U.S. EPA and SCDHEC believe that this remedy will satisfy the
statutory requirements of CERCLA § 121, 42 U.S.C. § 9621, and NCP
§ 300.430, 40 C.F.R. § 300.430, of providing protection of human
health and the environment, attaining Applicable or Relevant and
Appropriate Requirements (ARARs) of other environmental statutes,
and will be cost-effective. Sections 8.1 through 8.5 below
analyze the statutory requirements for this Site.
8.1 Protection of Human Health and the Environment
The selected remedy provides protection of the public health and
environment through Monitored Natural Attenuation.of the
residually contaminated groundwater. For a detailed analysis of
this requirement, see Section 6.3(1) of this Amendment.
8.2 Attainment of the Applicable or Relevant and Appropriate
Requirements (ARARs)
Remedial actions performed under CERCLA must comply with all
ARARs. All alternatives considered for the Geiger Site were
evaluated on the basis of the degree to which they complied with
these requirements. The selected remedy will comply with all
ARARs.
8.3 Cost Effectiveness
The remedy selected in the 1987 ROD is currently estimated to be
$1.33 million. Natural Attenuation of the contaminated
groundwater is currently estimated at $34,000, and therefore, is
the more cost effective remedy compared to the original remedy.
8.4 utilization of Permanent Solutions and Alternative
Treatment Technology or Resource Recovery Technologies
to the Maximum Extent Practicable
U.S. EPA believes the selected remedy is the most appropriate
cleanup solution for the contaminated groundwater at the Geiger
Site and provides the best balance among the evaluation criteria
for the remedial alternatives evaluated. This remedy provides
effective protection in both the short and long-term to potential
human and environmental receptors, is readily implementable, and
is cost effective.
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Monitored Natural Attenuation of the contaminated groundwater
represents a permanent solution which will effectively reduce
and/or eliminate hazardous substances into the environment.
8.5 Preference for Treatment as a Principal Element
This alternative does not include active treatment, however, it
will effectively prevent contaminants from posing a threat to
human health and the environment.
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APPENDIX A
RECORD OF DECISION, JUNE 1987
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SUMMARY Of REMEDIAL ALTERNATIVE SELECTION
t
GEIGER (C&M OIL) SITE
CHARLESTON COWIY, SOUTH CAROLINA
JUN 01 1987
Prepared By:
U.S. Environmental Protection Agency
Region IV
Atlanta, Georgia
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RECORD OF DECISION
Remedial Alternative Selection
SITE: Geiger (C&M Oil)
Hollywood, Charleston County, South Carolina
DOCUMENTS REVIEVED;
- Remedial Investigation Report, Geiger (C&M Oil) Site
i
- Feasibility Study, Geiger (C&M Oil) Site
- Summary of Remedial Alternative Selection
- Cocimunity Responsiveness Summary
- Staff Recommendations and Reviews
DESCRIPTION OF SELECTED REMEDY;
GROUNDWATER /
- Extraction of contaminated groundwater
- Onsite treatment of extracted groundwater
- Discharge of treated groundvater to off-site stream
- Excavation ot contaminated soil on tne site
- Groundvater remediation will be performed until all water
contaminated above the cleanup goals specified in the
attached Summary of Alternative Selection are reached
SOIL
- Onsite thermal treatment of excavated soil to remove organic
contaminants
- Solidification/stabilization of thermally-treated soil, if
necessary to reduce mobility of metals
- Backfilling of excavated areas with treated soil, followed by
grading aj>J covering with gravel
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Soil cleanup goals will be developed during remedial design;
the volume of soil to be treated will be dependent upon these
goals
Daring remedial design, solidification/stabilization (S/S) will
be reviewed to determine if S/S alone will achieve the remedial
action goals. Presently, data and information is not available
to justify utilizing S/S at this time. However, if such data
and information is available during the pre-oesign activities,
this data will be used to reevaluate the present alternative
under a second operable unit. <
DECLARATIONS
»
Consistent with the Comprehensive Environmental Response, Compensation,
and Liability Act of 1980 (CERCLA), the Superfund Amendments and Re-
authorization Act of 1986 (SARA), and the National Oil and Hazardous
Substances Contingency Plan (40 CFR Part 300), I have determined that the
extraction and treatment of groundwater and the excavation, onsite thermal
destruction, stabilization/solidification, and backfilling of contaminated
soils at the Geiger (C&M Oil) site is a cost-effective remedy which uses
alternative technologies and permanent solutions to the maximum extent
practicable, and provides adequate protection of human health and the
environment. The selected action will require no further operation and
maintenance activities, other than monitoring.
EPA will fund ninety percent of the cost of implementing this remedial
action, and the State of South Carolina will fund the remaining ten
percent. EPA will fund ninety percent of the costs of the first year of
monitoring following conpletion of remedial activities. The State will
fund the remaining ten percent,* and will fund one-hundred percent of the
costs of monitoring following this period.
The State of South Carolina has been consulted on the selection of this
remedy, and concurs with the selected remedial action.
I have also determined that the action being taken is appropriate when
balanced against the. availability of trust fund monies for use at other
sites.
Jack E. Ravan
Regional Administrator
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TABLE OF CONTENTS
1.0 INTRODUCTION 1
1.1 Site Location and Description 1
1.2 Site History 5
2.0 ENFORCEMENT ANALYSIS 7
3.0 CURRENT SITE STATUS 8
3.1 Hydrogeologic Setting 8
3.2 Soil Contamination 8
3.3 Surface Water and Sediment Contaminatfion 10
3.4 Groundwater Contamination 10
3.5 Receptors 15
3.6 Wallace River Wetlands 15
4.0 CLEAN-UP CRITERIA I 17
4.1 Groundwater Remediation . 17
4.2 Soil Remediation 20
4.3 Swamp Remediation 21
5.0 ALTERNATIVES EVALUATION. . 23
5.1 Groundwater Remediation 23
5.2 Soil Remediation 28
6.0 RECOMMENDED ALTERNATIVES 33
6.1 Description of Recommended Remedy 33
6.2 Operation and Maintenance 34
6.3 Cost of Reconroended Alternatives 34
6.4 Schedule. 34
6.5 Future Actions 35
6.6 Consistency with Other Environmental Laws .... 35
7.0 COMMUNITY RELATIONS. . 37
8.0 STATE INVOLVEMENT 38
APPENDIX A U.S. Fish and Wildlife Service Correspondence
APPENDIX B State Of South Carolina Correspondence
APPENDIX C Calculation of Preliminary Soil Cleanup Coals
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LIST OF FIGURES
FIGURE 1 Location Plan 2
FIGURE 2 Area Map * 3
FIGURE 3 Site Plan 4
t
FIGURE 4 Areas of Soil Contamination 9
FIGURE 5 Location of Monitor Vfells ,..'... 12
LIST OF TABLES
TABLE 1 Maximum Concentrations of Chemicals Detected in
Surface Soil Samples 11
TABLE 2 Contaminants Detected in Monitor Wells 13
TABLE 3 Groundwater Cleanup Goals 18
TABLE 4 Preliminary Soil Cleanup Goals .21
TABLE 5 Technologies Considered for Screening 24
TABLE 6 Summary of Present Vforth Costs 26
TABLE 7 State Cost Sharing Obligations 39
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RECORD OF DECISION
SUMMARY Of REMEDIAL ALTERNATIVE SELECTION
GEIGER (C&M OIL) SITE
CHARLESTON COUNTY, SOUTH CAROLINA
1.0 INTRODUCTION
The Geiger (C&M Oil) site was proposed for inclusion on the National Priori-
ties List (NPL) in Update Nunber 1, September* 1983, and ranks 588 out of 703
NPL sites. The Geiger site has been the subject of a remedial investigation
(RI) and feasibility study (FS) performed by the Region IV REM II contractor,
Camp, Dresser & McKee, Inc. (CEM). The RI report, which examines air, sedi-
ment, soil, surface water, and groundwater contamination at the site, was
issued July 1, 1986. The PS, which develops and examines alternatives for
remediation of the site, was issued in draft form to the'public on January 9,
1987.
This Record of Decision has been prepared to summarize the remedial alterna-
tive selection process and to.present the selected remedial alternative.
1.1 SITE LOCATION AND DESCRIPTION
The Geiger (C&M Oil) site is located in central Charleston bounty, South
Carolina, approximately ten miles west ot the city ot Charleston, along
Highway 162 (Figure 1). The site is in a sparsely populated rural area.
About ten residences are located adjacent to the site to the east and
northeast. The population in the immediate site area is estimated at
forty persons. Several snail businesses are located within one-half mile
of the site along Highway 162. The town of Hollywood is approximately
four miles west of the site.
Land use in the vicinity of the site is predominantly mixed coniferous and
deciduous forest. Estuarine streams and their associated tidal wetlands
are located approximately one mile to the north and south of the site.
There are no major industries or other sources of employment nearby.
Agricultural lands and borrow pits are scattered within a one-mile radius
of the site.
The site comprises a five-acre area of very little topographic relief.
Elevations on the site range from approximately fifteen to thirty feet
above mean sea level. Surface water drainage is into two onsite ponds
and to the west and northwest toward the Wallace River (Figures 2 and 3),
which flows into the Stono River. A marshy area is found west of the
site, and sensitive wetland environments are located in the Wallace River
vicinity. These wetlands are a critical habitat supporting several
federally listed endangered and threatened species.
Several lagoons were constructed on the site between 1969 and 1971 for
use in a waste oil incineration process. These unlined lagoons covered
a total area of approximately 5,000 square feet, and their bottoms were
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LOCATION PLAN
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AREA MAP
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CHARLESTON,SOUTH CAROLINA
FIGURE NO.
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at or near the groundwater surface. The lagoons were filled with waste
oil, and were later covered with local soils. The site is presently
being used for equipment storage by a pile driving company.
1.2 SITE HISTORY
In March 1969 the South Carolina Pollution Control Authority (SCPCA) per-
mitted Adams Ron Services, Inc. to incinerate waste oil at what is now
the Geiger site. Sometime between 1969 and*1971, eight unlined lagoons,
each approximately one foot deep and covering a total area 50 feet wide
by 100 feet long, were constructed for the purpose of holding waste oil
in connection with the incineration process. (
In late 1971 in response to complaints from area residents, SCPCA ordered
that all incineration and waste deposition activities at the site be
stopped, and the owner was to take action to prevent'Spillage, leakage,
or seepage of oil from the site.
«
In April 1974 a nearby property owner complained to the Charleston County
Health Department (CCHD) about oil overflowing from the lagoons on the
site. CCHD investigated and ordered the site closed, citing evidence of
recent oil dumping and overflowing oil. C&M Oil Distributors, Inc. then
purchased all reclaimable oil on the site and submitted recovery plans to
the South Carolina Department of Health and Environmental Control (SCDHEC).
There is no reply from SCDHEC on record.
In December 1979, SCDHEC requested C&M Oil to provide information on their
plans for cleaning up the site. C&M Oil replied that they were unable to
recover the waste oil and that they were not obligated to clean the site.
EPA Region IV began investigating the site in February 1980. Samples from
two monitoring wells installed downgradient of the site contained organic
compounds and metals which were also detected in the waste pits. Residen-
tial wells upgradient of the site were sampled, but no organic compounds
were detected. Metals in these residential samples were at background
levels. Haste oil in the lagoons was found to contain chemicals which
are similar to those associated with automotive crankcases, brake fluids,
and degreasing compounds. The total quantity of waste on the site was
estimated at 149,600 gallons, the equivalent of 2992 55-gallon druns.
The site was ranked using the Hazard Ranking System (HRS), and received
a score of 32.37.
The site was purchased in March 1982 by George Geiger, who is the present
owner. Mr. Geiger proposed excavation and disposal of contaminated soil
in the lagoons, but no final approval was given by SCDHEC.
In 1933 Mr. Geiger filled the lagoons with local soils, and the site has
been used since then for the storage of equipment used by his company,
Pile Drivers, Inc.
-5-
-------
O
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-20
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O
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o
•" - •• • t n' vvjj*" "
" *' " • ^
ADDITIONAL AREAS OF
SOIL CONTAMINATION
100 SO 0 30 IOO 130
SCALE IN FEET
-------
MW-6
O
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m
o
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2
O
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o
o
30
en
o
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o
ESTIMATED EXTENT
OF GROUNDHATER
CONTAMINATION PLUME
N
OIL STAINED
AREA
4"MONITOR WELL CLUSTER
• LOCATIONS
MW-2
-------
The Geiger (C&M Oil) site was placed on the National Priorities List on
SeptemDer 8, 1983. EPA issued a work assignment in October 1984 to the
REM II contractor, Camp, Dresser & M=Kee, Inc., to pertorm a renedial
investigation and feasibility study ot the site. This task was assigned
to C.C. Johnson & Malhotra, P.C., of Silver Spring, Maryland, a REM II
team member. The final RI report was issued July 1, 1986, and the or aft
FS was released to the public January 9, 1987.
The objectives of the site investigation were:
0 To determine the extent of contamination of the shallow aquifer;
0 To characterize the hydraulic characteristics of the shallow aquifer;
0 To determine the lateral extent and depth of soil contamination on
the site; . •
0 To determine whether contamination has migrated 'off-site via surface
water runoff; and
0 To determine if air contamination from the site is occurring.
Tne purpose of the feasibility study was to develop and examine remedial
alternatives for the site, and to screen these alternatives on the basis
of protection ot human health and the environment, cost-effectiveness, and
technical implementability. In accordance with the Comprehensive Environ-
mental Response, Compensation/ and Liability Act of 1980 (CERCIA), as
amended by the Super fund Anenoments and ^authorization Act of 1986 (SARA)
alternatives in which treatment would permanently and significantly reduce
the volume, toxicity, or mobility of the hazardous substances at the site
were preferred over those alternatives not involving such treatment.
Further investigation was performed in February 1987, to search for drums
which were reported to be buried on the site. This investigation was in
response to comments made at a public meeting held to discuss the remedial
alternatives under consideration. No buried drums were discovered on or
near the site.
-6-
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2.0 ENFORCEMENT ANALYSIS
The Geiger (C&M Oil) site was added to the National Priorities List (NPL)
in September 1983 and EPA assumed lead responsibility for the site at
that time. An EPA contractor completed a potentially responsible party
search in February 1984. Notice letters were sent out to potentially
responsible parties in October 1984. Since no viable PRPs were found,
EPA proceeded to conduct the RI/FS itself. The RI/FS commenced in July
1985.
-7-
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3.0 CURRENT SITE STATUS
3.1 HYD80GEOLOGIC SETTING
The Geiger (C&M Oil) site lies in the Atlantic Cbastal Plain physiographic
province. The uppermost aquiter at the site is a surficial, unconfirmed
aquifer, approximately 40 to 50 feet thick/ composed of clean to silty,
tine to medium sand with some mud lenses. Depth to the water surface
varies seasonally, reaching a minimun of one foot below the ground surface.
Groundwater flow across the site is generally to the west and northwest,
discharging to surface waters in the wetlands of the Wallace River.
A hydraulic conductivity of 6.7 feet per day was determined using a rising
head test. Assuming an average porosity of 41 percent for medium to fine
sand aquifers, and a hydraulic gradient of 0.003, a velocity of 0.05 feet
per day was calculated for groundwater flow. At this rate, groundwater at
the site would have moved approximately 300 feet since waste was deposited
on the site sixteen years ago.
*
Groundwater in the surficial aquifer has been classifed as Class 1 ground-
water under EPA Groundwater Protection Strategy (GtfPS) because it is highly
vulnerable to contamination and it discharges into wetlands inhabited by
endangered species. The South Carolina Department of Marine Resources and
the U.S. Fish and Wildlife Service have identified Bald eagles in the area,
and reported a likelihood of Mood storks and American alligators in the
wetlands. As Class I groundwater, a high degree of protection would be
afforded the aquifer, and very stringent clean-up goals must be met.
Groundwater in the surficial aquifer is also a source of drinking water
for residents living near the site. Approximately ten hones immediately
upgradient of the site have walls supplied by this aquifer. Several
residential wells are also located one mile or less downgradient of the
site. The aquifer classification and clean-up goals are discussed in
more detail in Section 4.0.
This surticial aquifer is underlain by the Cooper Marl, which acts as a
confining layer in the area, separating the surf icial aquifer from lower
formations. The Cooper Marl is estimated to be 15 to 60 feet thick and
overlies several Tertiary formations. These formations are predominantly
pure to very impure limestone in the upper part of the section, and sand,
silt, and clay in the lower part. Below the Cooper Marl are additional
sand, silt, and clay formations down to the basement rock, which is well-
indurated sedimentary and igneous rock or pre-Cretaceous age.
3.2 SOIL CONTAMINATION
Soils at the site are predominantly sandy throughout their profile, and
possess rapid permeability. The area of highest soil contamination is in
the oil stained area shown in Figure 4, where the former lagoons were located.
-8-
-------
Soil contamination was found to a lesser degree in other areas shown in
this figure. Contaminants include various organic compounds, PCB-1254,
and heavy metals (Lead, Mercury, Chromium) . The contaminants and the
maximum concentrations detected in soil on the site are shown in Taole 1.
The depth of soil contamination is estimated to be five feet in the oil-
stained area and one foot in other areas of the site indicated in Figure 4.
The depth of contamination in the oil-stained area was estimated on the
basis of historical and visual evidence. Samples could not be obtained
below a depth of two feet because of the high groundwater level. The
contaminated soils are believed to behave as a source material, contributing
contamination to the ground-water.
i
3.3 SURFACE WATER AND SEDIMENT CONTAMINATION
Lead was detected at elevated concentrations in two surface water samples
trcm the swanp located northwest of the site, and elevated levels of Lead
were found in four sediment samples from this area. This contamination
is probably the result of past spills or of surface water runoff into the
swamp. Most run-off from the site would be intercepted by the onsite
ponds which showed no elevated levels of contaminants; however, limited
off-site surface migration may be presently occurring. This swamp is not
associated with the Wallace River wetlands, and is not considered to be a
critical habitat as the wetlands are.
3.4 GROUNDWATER CONTAMINATION
The approximate extent of groundwater contamination is shown in Figure 5.
Groundwater iron the onsite shallow well, MW-4S (Figure 5), was found to
be contaminated with several organic compounds. Benzene was detected at
25 ug/1, which is above the proposed Maximun Contaminant Level (PMCL) of
5 ug/1. Toluene was detected at the proposed MCL (PMCL) of 2000 ug/1.
Several other organic compounds were detected above background levels, as
shown in Table 2. Background conditions are represented by MW-1, located
hydraulically upgradient of the site.
Contaminants were detected at levels above background concentrations in
well cluster MW-5. Although not above appropriate standards, these
concentrations indicate migration of contaminated groundwater off-site.
Arsenic was detected at 66 ug/1, which is above the MCL of 50 ug/1, in
MW-2D. The presence of metals other than Arsenic was not confirmed be-
cause of sediments introduced into seme samples. These sediments could
be the source of the metals detected in Mtf-5 and MW-6.
Soil in the oil-stained area shown in Figure 4 is in contact with the
groundwater. This contaminated soil is considered to be a source material,
continually introducing contamination into the groundwater.
-------
TABLE 1
MAXIMUM CONCENTRATIONS OF CHEMICALS DETECTED
IN SURFACE SOIL SAMPLES
GEIGER (C&M OIL) SITE
CHARLESTON, SOUTH CAROLINA
CHEMICAL CONCENTRATION (ug/kg)
Benzo( a ) Anthracene
Benzo( a ) Pyrene
Benzo( Band/or K) Pluoranthene
Chrysene /
PCB (Aroclor 1254)
1 , 1-Dichloroe thane
Toluene
1,1, 1-Trichloroethane
Tr ichloroe thylene
Ethylbenzene
Lead
Mercury
Chromium
560
240
2000
1200
4000
9.6
460
36
230
17
740 rogAg
1.3 ragAg
1100 mg/kg
BACKGROUND RANGE
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
3.9-8 mgAg
ND
3.6 - 4.5 mgAg
ND - Not Detected
-11-
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TABLE 2
CONTAMINANTS DETECTED IN MONITOR WELLS
GEIGER (C&M OIL) SITE
CHARLESTON, SOUTH CAROLINA
WELL NUMBER CONTAMINANT CONCENTRATION (ug/1)
MW IS ' Arsenic ' 6
MW 1M Arsenic . 8-
Chloroform (1) . 5J
MW ID Di-n-Cctylphthalate . 3J
Chloroform (1) 32
MW 2S Chloroform (1) 20
MW 2M Branodichloramethane (1) 1J
MW 2D ' Dimethyl Phthalate 11
Chlorofonn (1) 22
Benzene 0.8J
Arsenic 66
MW 3S Arsenic/ 42
Di-n-Octylphthalate 3J
Chlorofonn (1) 14
MW 3M Chloroform (1) 2J
Bis(2-ethylhexyl) Phthalate (2) 1200
MW 3D Chloroform (1) 8
MW 4S 1,2-Dichlorobenzene 23
Naphthalene .18
Isophorone 1J
Benzoic acid (2) 18J
2-Methylphenol 32
4-Methylphenol 71
2-Msthyl naphthalene 8J
Chloroethane 250
1,1-Dichloroethane 130J
trans-lr2-Dichloroethylene 53J
Benzene 25J
Toluene 2000
Total Xylenes 25J
-------
TABLE 2 (continuea)
CONTAMINANTS DETECTED IN MONITOR WELLS
GEIGER (C&M OIL) SITE
CHARLESTON, SOUTH CAROLINA
NELL NUMBER CONTAMINANT CONCENTRATION (ug/1)
MW 4M Benzole acid (2) . 4J
Chloroform . 1J
Benzene 0.5J
MW 4D Chloroform (1) 7J
Benzene " 0.4J
MW 5S 2,4-Dimethylphenol 20
Benzene 5J
Toluene 1J
Lead (3) 53
MW 5M Not Defected
MW 5D 1,1-Dichloroethene 3J
Chloroform (1) 20
MW 6S Toluene (3) (4) 5.3
Lead (3) (2) 250
Cadmiun (3) (4) 13
MW 6M Not Detected
MW 6D Not Detected
(1) - Pound in drilling water
(2) - Laboratory contaminant or natural degradation product
(3) - Sediment in sample
(4) - Compounds not found in duplicate sample
J - Estimated value
_1 A-
-------
3.5 RECEPTORS
Receptors of contaminants on and near the Geiger (C&M Oil) site may be
exposed via four different routes: Air, soil, groundwater, and surface
water. Both environmental and human receptors have been identified.
The primary human receptors are onsite workers and residents who may come
into contact with contaminants through inhalation of dust generated by
wind erosion and vehicle traffic, and through direct dermal contact with
contaminated soil. Ingestion of contaminated soil is also possible,
especially if children were to play on the oil-stained area.
4
Potential human receptors identified under future-use scenarios include
those identified above, as well as those who may ingest or otherwise come
into contact with groundwater which could be produced from onsite wells.
No producing wells are present within the groundwater contamination plume
at this tune, but development of this site could lead to the placement of
wells for human use. Users of groundwater from off-site wells are also
potential receptors, as contaminated groundwater could migrate to residen-
tial wells if no remedial action is taken.
Environmental receptors include aquatic life coming into direct contact
with or ingesting surface water in the onsite ponds, the discharge stream,
the oily pit on the site, and the marshy area near the site. Plants and
amphibians may contact sediments in the marshy area near the site, and
wildlife may ingest or contact contaminated soil in the oily area.
The environmental receptors of greatest concern are endangered species in
the wetlands of the Wallace River. Groundwater frcm the site discharges
into these wetlands, and contaminants may affect wetlands wildlife by this
route. Contaminated groundwater has not yet reached these wetlands, but
may eventually migrate to this area if not remediated.
3.6 WALLACE RIVER WETLANDS
Wetlands of The Wallace River have been identified as a sensitive habitat
which may be atfeeted by the Geiger (C&M Oil) site. These wetlands, snown
in Figure 1, are located north and west ot the site, within a two-mile
radius of the site.
The following Federally listed endangered species were determined by the
U.S. Fish and Wildlife Service to possibly occur in the area of influence
of the site: Bald eagle (Haliaeetus leucocephalus), Wood stork (Mycteria
americana), Red-Cockaded woodpecker (Picoides borealis). The American
alligator (Alligator mississippiensis) is a threatened species which may
also occur in this area. These species are all protected under the Endan-
gered Species Act as amended by Public Law 97-304. Additionally, several
plants, amphibians, and birds are "status review" species which are not
legally protected at this time, but may be listed as endangered or threa-
tened in the future. These species are identified in correspondence
contained in Appendix A.
-Ti-
-------
The South Carolina Department ot Marine Rssources has identified Bald
eagles in the Wallace River wetlands. Adult plumage birds have been
spotted, and nesting is expected to be confirmed soon.
These wetlands may be impacted by the site because the surticial aquifer
discharges into the wetlands. It is this surficial aquifer which is
contaminated at the Geiger site. Contaminated groundwater was determined
to be migrating off-site in a generally westerly and northwesterly direc-
tion. Although contaminated groundwater has not reached the wetlands,
contaminated groundwater may migrate to that area if not remediated.
Under the EPA Groundwater Protection Strategy, groundwater in this surfi-
cial aquifer at the Geieger site has been classified as Class I groundwater
because it discharges into a sensitive environment, the Wallace River
wetlands, within a two-mile radius of the si,te.
-16-
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4.0 CLEANUP CRITERIA
The extent ot contamination was defined in Section 3.0, Current Site Status.
Tnis section examines the relevance and appropriateness ot water quality
criteria under the circuitstances of release of contaminants at this site.
Based upon criteria found to be relevant and appropriate, the minimum goals
of remedial action at this site have been developed.
4.1 GROUNDWATER REMEDIATION
4
In determining the degree ot groundwater cleanup, Section 121(d) of the
Superfund Amendments and Reauthorization Act of 1986 (SARA) requires that
the selected remedial actions establish a level or standard of control
which complies with all "applicable and relevant or appropriate regulations"
(ARARs).
Groundwater in the surficial aquifer is classified as Class I under draft
guidelines for groundwater classification under the EPA Groundwater Pro-
tection Strategy (GWPS). Class I groundwater includes tftat which is highly
vulnerable to contamination because of the hydrogeological characteristics
of the aquifer,-and that which is ecologically vital in that the ground-
water discharges to an area that supports a unique habitat. Groundwater
in the surficial aquifer discharges into wetlands of the Wallace River
within the Classification Review Area, encompassing a two-mile radius of
the site. The South Carolina Department of Marine Resources has documented
the use of these -wetlands as a feeding area for the Bald eagle, which is
on the national endangered species list (see Section 3.6). Adult plumage
birds have been identified, and it is expected that nesting will be
confirmed soon. The U.S. Fish and Wildlife Service has noted the likeli-
hood of the Bald eagle, Wood stork, and Red-Cockaded woodpecker in these
wetlands; all are endangered species.
The EPA GWPS advises that the value to society ot Class I groundwater sup-
ports restoration of this contaminated groundwater to levels protective
of huuan health and the environment. Several contaminants were detected
at elevated levels, as shown in Table 2. Based upon groundwater classiti-
cation, remediation of the groundwater to reduce contaminants to levels
protective of human health and the environment would be necessary.
Groundwater cleanup goals given in Table 3 meet these requirements.
The surficial aquifer at the Geiger (C&M Oil) site is also a current source
of drinking water. Nine residential water-supply wells are located upgra-
dient of the site within the two-mile Classification Review Area. Several
residential wells are located downgradient of the site within this area,
approximately three-*quarters of a mile west of the site. These wells are
completed in the surficial aquifer and are a present source of drinking
water. RCRA regulations require clean-up of contaminated groundwater to
background levels or MCLs for certain listed contaminants. The presence
of contaminants at elevated levels in groundwater at the Geiger site will
require treatment to reduce contaminants to appropriate levels as specified
in Table 3.
-17-
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TABLE 3
GRDUNLWATER CLEANUP GOALS
FOR INDICATOR CHEMICALS
GEIGER (C&M OIL) SITE
INDICATOR MAXIMUM DETECTED
CHEMICAL (ug/1)
Ben 20 (a) Pyrene
Benzo (a) Anthracene
Benzo (b and/or k) Fluor an the ne
PCB (Aroclor 1254)
Benzene
Trans-1, 2-Dichloroethylene
Chroniun
Lead
Toluene
1, 1-Dichlorobenzene
1 , 1-Dichloroethane
ND
ND
ND
ND
25
53
ND
53
2000
2
130
GROUNDWATER
CLEANUP LEVEL
(ug/1) •
O.UU3
U.003
0.003
0.0079
1.2
70
50
50
175
15.8
5
CRITERIA
ID •
b
b
b
b
a
d
d
c
c
e
CRITERIA
a - Proposed Recommended Maximun Contaminant Level (PRMCL or MCLG)
Federal Register, Vol. 50, No. 219, November 13, 1985, 46935
b - Equivalent to 10*"5 cancer risk
c - Aquatic Life Chronic Toxicity Value
d - Maximun Contaminant Level (MCL)
e - Required CLP detection level
-------
Future exposure to contaminated groundwater was estimated based on the
possibility of a well being placed on the site and producing water contain-
ing the maximum levels of contaminants which were detected in monitoring
wells during the remedial investigation. Lifetime cancer risks were
calculated under these assumptions for the indicator chemicals identified
in the Public Health Evaluation (PHE). An acceptable lifetime risk is
considered to be 1(H>. Larger values present an unacceptable risk from
exposure. Lifetime risks, as developed in the PHE, are above the 10~6
criteria. Because Section 121 of SARA requires consideration of potential
as well as current groundwater use, the levels of contaminants in the
groundwater must be reduced to acceptable levels.
The conclusion of the above discussion is that a no-action alternative
for groundwater would be out of compliance with Section 121 of SARA,
which requires clean-up of contaminated groundwater to levels which are
protective of human health and the environment. Classification of the
groundwater and the potential future use of the groundwater indicates that
present contaminant levels in the groundwater are not acceptable.
*
Indicator chemicals were used to establish cleanup goals for groundwater.
Indicator chemicals were selected on the basis of which chemicals pose the
greatest potential health risk at the Geiger site. These indicator chemi-
cals include those developed in the Public Health Evaluation. Toluene
and 1,1-Dichlorobenzene were included because maximum concentrations for
these compounds have been established based on aquatic life chronic toxicity
values. /
For carcinogenic contaminants, a 10~5 risk level was deemed appropriate
for groundwater remediation. EPA's draft "Guidance on Remedial Actions
for Contaminated Groundwater at Superfund Sites" (October 1986) specifies
that groundwater remediation should achieve a level of protection in the
10~4 to 10~7 excess cancer risk range, with 10~6 being used as a point of
departure. Groundwater in the contaminated surficial aquifer is not used
by human receptors immediately downgradient of the site, and natural
attenuation will lower contaminant concentrations before qroundwater
migrates from the site to existing residential wells or sensitive wetlands.
Therefore, a 10~5 risk level is sufficient for protection of human health
and the environment. A higher risk level would not be acceptable because
of the possiblity that wells may be placed near the site. The Geiger
site is in a lightly populated area, but residences are located near the site.
Levels presented as groundwater cleanup goals are based on four criteria:
Proposed recommended maximum contaminant levels (PRMCLs); 10~5 cancer risk
for carcinogens; maximum contaminant levels (MCLs) established under the
Safe Drinking Water Act; and aquatic life chronic toxicity values. Indi-
cator chemicals, maximum concentrations detected in groundwater at the
Geiger site, and the cleanup goals for these chemicals are presented in
Table 3.
Specific quantitative data for all polyarcmatic hydrocarbons (PAHs) is
not available, so all carcinogenic PAhs are considered to have a carcinogenic
potency equivalent to that of Benzo(a)pyrene.
-------
"mis forms the basis of the cleanup goal for BenaD{ a) anthracene and
Benzo(b and/or k)fluoranthene. The sum of all carcinogenic PAHs snould
not exceed a 10~6 risk level.
The PRMCL for Benzene is 5 ug/1, Dut the cleanup goal of 1.2 ug/1 represents
the 10~6 cancer risk. The PRMCL incorporates consideration ot available
technology and the practical quantitation level for routine laboratory
analysis.
Based on limited data, the EPA Environmental Criteria and Assessment Office
concluded that 1,1-Dichloroethane may have the potential for carcinogenic
activity in experimental animals. However, data were inadequate for
quantitative risk assessment. Therefore, the cleanup goal will be to the
lowest level practical, represented by the required CLP detection limit.
t
4.2 SOIL REMEDIATION
The Puolic Health Assessment in the RI Report determined that risks to
hunan health as a result of exposure to onsite contaminants via inhalation,;'
ingest ion, and dermal contact .are at acceptable levels under present-use
conditions at the site. However, under a future-use scenario in which
the site may be developed, an undue risk might be posed from exposure to
contaminants in the soil. Remediation or institional controls will be
necessary to assure that an increased risk to human health is not posed
in the future.
Contaminants remaining in the £oil following ground water remediation may,
over time, leach into the ground water. A model was developed to calculate
contaminant concentrations in soil at the Geiger site that would not result
in future exceedences of groundwater cleanup goals. These soil contaminant
concentrations for indicator chemicals are shown in Table 4 and are consi-
dered to be preliminary soil cleanup goals.
These preliminary goals were developed using limited data, and will be
subject to refinement during remedial design. If information gathered
during design allows more accurate development of cleanup goals, these
levels will be revised accordingly.
The purpose of developing the preliminary goals was to determine the need
for and the extent of soil remediation. As Table 4 indicates, several of
the indicator chemicals are above the soil protective levels. If no soil ,
remediation was implemented, leaching of contaminants tram the soil into
the groundwater would occur, and contaminant levels in the groundwater
could exceed groundwater cleanup goals.
The areas shown in Figure 4 contain contaminants in excess of the protec-
tive levels in Table 4. Soil in these areas must be treated to reduce
contaminants to levels at or below the preliminary cleanup goals.
The development of the prelimary soil cleanup goals is discussed in more
detail in Appendix C.
-20-
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4.3 SWAMP REMEDIATION
Off-site migration ot metals has occurred into the swamp area west of the
site. Although lead was detected above aquatic life chronic toxicity
values in surface water in the swamp, no adverse environmental effects
have been noted to date. The contaminant levels in the swamp are expected
to gradually decline, as migration of contaminants is not likely to be
occurring at the present time. Most surface run-oft from the contaninted
soil is captured by the on-site ponds.
The swamp area will not be remediated because, adverse environmental
impacts associated with excavation of these areas would be greater than
benefits which would be attained. Excavation of contaminated sediments
would require clearing the vegetative cover and would disrupt the habitat
and feeding grounds of a wide variety of wildlife in this swamp. The
benefits to be obtained by swamp remediation would be exceeded by-the
adverse environmental impacts which would be realized. Thus, it was
concluded that remediation of this area is not necessary.
-21-
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TABLE 4
PRELIMINARY
SOIL CLEANUP GOALS
FOR INDICATOR CHEMICALS
GEIGER (C&M OIL) SITE
INDICATOR MAXIMUM DETECTED
CHEMICAL (ug/kg)
Benzo (a) Pyrene
* Benzo (a) Anthracene
* Benzo (b and/or ,.k) Fluoranthene
* PCB (Aroclor 1254)
Benzene
Trans-1, 2-Dichloroethylene
* Cnromiun
* Lead <
Toluene
1 , 1-Oichlorobenzene
* 1,1-Dichloroe thane
240
560
2000
4000
NO
ND
1100 mg/kg
740 ng/kg
460
ND
9.6
*
CLEANUP GOAL
(03/kg)
1,070
140
170
1,050
14.4
76
3.7 rag/kg
166.5 trg/kg
971
497
2.78
ND - Not Detected
* - Maximum detected concentration is
greater than the preliminary cleanup goal
-22-
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5.0 ALTERNATIVES EVALUATION
Tne purpose of remedial action at the Geiger (C&M Oil) site is to mitigate
and minimize contamination in the soils and groundwater, and to reduce
potential risks to hunan health and the environment. The following clean-
up objectives were determined based on regulatory requirements and levels
of contamination found at the site:
0 To protect the public health and the environment from exposure to
contaminated onsite soils through inhalation, direct contact, and
erosion of soils into surface waters and wetlands;
e To prevent off-site movement of contaninat*d groundwater.
0 To restore contaminated groundwater to levels protective of human
health and the environment.
t
An initial screening of applicable technologies was performed to identify
those which best meet the criteria of Section 3U0.63 of the National
Contingency Plan (NCP). Following the initial screening of technologies,
potential remedial action alternatives were identified and analyzed.
These alternatives were screened and those which best satisfied the
cleanup objectives, while also being cost effective and technically
feasible, were developed further.
Table 5 summarizes the results of the screening process. Each of the
ranaining alternatives for soil and groundwater remediation was evaluated
based upon cost, technical feasibility, institutional requirements, and
degree of protection of public health and the environment. A cost sumnary
is presented in Table 6.
5.1 GROUP A ALTERNATIVES - GROUNDWATER REMEDIATION
Alternative A-l: Groundwater Extraction, Optional Flocculation/
Sedimentation, Air Stripping, and Disposal
This alternative would treat groundwater at the site by removing volatile
organic compounds (VOCs). Groundwater would be treated to cleanup goals
established in Section 4.
All monitoring wells would be sampled and analyzed during or prior to
remedial design. Flocculation/sedimentation and filtering would be added
to the treatment system if metals are detected at levels which would pose
a risK to human health, or at levels which could be toxic to wildlife.
Groundwater would De pumped from several onsite wells at a rate of 60
gallons per minute (gpa). If flocculation/sedimentation is used, the
water would De put into a storage tank. Lime and a polymer would be
added to water taken from the tank, resulting in aggregation and settle-
ment of insoluble metal contaminants in the water.
-23-
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TABLE 5
TECHNOLOGIES CONSIDERED FOR SCREENING
GEIGER (C&M OIL) SITE
CHARLESTON, SOUTH CAROLINA
Eliminated (E)
Possible Technologies
or
Retained (R)
If Eliminated
Reason for
Doing So
I. Groundwater Technologies
A. Groundwater Containment
1. Slurry Wall
2. Grout Curtains
R
E
More expensive and less
effective than slurry
walls
B. Groundwater Recovery
1. Pumping (Extraction Wells)
2. Subsurface Drains /
C. Groundwater Treatment
1. Flocculation/Sedimentation
2. Filtration
3. Air Stripping
4. Spray Irrigation
5. Activated Carbon Adsorbtion
6. Ion Exchange/Sorptive Resins
7. Reverse Oanosis
8. Biological Treatment
D. Groundwater Disposal
1. Discharge to Surface Water
2. Re inject ion
3. Pump to Local Wastewater
Treatment Plant
R
E
R
R
R
R
R
R
E
R
E
R
Hydraulic conductivity
may be high
Expensive, dilute waste
stream
Complex and expensive
compared to surface
discharge
-24-
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TABLE 5 (continued)
Possible Technologies
eliminated (B)
or
Retained (R)
If Eliminated,
Reason tor
Doing So
II. Soil Technologies
1. Extraction (Soil Flushing)
2. Solidification/Stabilization
3. Attenuation
4. Imnobiiization
5. Incineration
6. Capping
7. Vegetative (Dover
8. Excavation and Off-site Disposal
9. Partial Excavation with
On-site Disposal
10. On-site Containment/Encapsulation
.
R«
E
R
R
R
R
R
R
Not applicable to
waste characteristics
Not applicable to
site characteristics
Unknown reliability
and effectiveness
-25-
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TABLE 6
SUMMARY OF PRESENT V»RTH COSTS
GEIGER (C&M OIL)SITE
CHARLESTON, SOUTH CAROLINA
CAPITAL COST PRESENT WORTH
REMEDIAL ALTERNATIVES $1000 O&M COST
$1000
GROUNDWATER ALTERNATIVES:
A-l Extraction, Air Stripping
and Disposal (1)
A-2 Extraction, Flocculation/
Sedimentation, Filtration,
Carbon Adsorption, and Disposal
A-3 Extraction and Treatment at POTW
A-4 Slurry Wall and Cap
SOILS ALTERNATIVES:
B-l Cap
B-2 Vegetative Cover /
Gravel Cover
B-3 Partial Excavation and Cap
B-4 Partial Excavation and
Vegetative Cover
Gravel Cover
B-5 Excavation, On-site Incineration,
and Solidification/Stabilization
B-6 Excavation and Off-site Disposal
NO ACTION
NO ACTION WITH MONITORING
392
(756)
930 ,
833
4,328
567
214
256
614
261
312
5,191
3,910
0
0
1,334
(1,474)
1,573
670
626
405
405
397
405
405
397
367
367
0
367
TOTAL PRESENT
WORTH COST
$1000
1,726
(2,230)
2,503
*
1,504 ,
4,954
972
619
653
1,019
666
710
5,558
4,277
0
367
(1) Nunbers in parentheses include cost for floccul at ion/sedimentation
•-26-
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The water would spread over plastic media in the column as it falls, while
air blown upward through the column removes the volatile contaminants by
mass transfer. The treated groundwater would be discharged to the stream
west of the site.
The recommended alternative is for extraction, treatment, and discharge ot
ground water. Extraction and discharge will be as outlined above, but the
actual treatment system will be chosen as a result of treatability studies
to be performed on contaminated groundwater from the site.
The volume of contaminated groundwater is estimated to be approximately
62 million gallons. Pumping would continue until the indicator chemical
concentrations are at or below the cleanup goals specified in Table 3.
Alternative A-2: Groundwater Extraction, Optional Flocculation/
Sedimentation, Carbon Adsorption, and Disposal
•
This alternative includes treatment of extracted groundwater by floccuia-
tion and sedimentation to remove metals if, during pre-design sampling of
monitoring wells, it is determined that metals are present above the
groundwater cleanup goals, or that discharge of water containing untreated
metals would present a threat to the environment. The carbon adsorption
process would remove volatile and extractable organics. All organic
contaminants would be removed to levels at or below cleanup goals estab-
lished in Section 4. If used, flocculation/ sedimentation would also
remove metals to levels below cleanup goals. Groundwater would be pumped
from several on-site wells at a rate of 60 GEM to a storage tank. If the
flocculation/ sedimentation option is used, lime and a polymer would be
added to water taken from the storage tank, resulting in aggregation and
settlement ot insoluble metal contaminants in the water. This water
would then pass through columns ot granular activated carbon (GAC), which
would adsorb organic compounds in the water. Treated water would be
discharged to the stream west of the site.
The estimated volume of water to be pumped under this alternative is 62
million gallons.
The recommended alternative is for extraction, treatment, and discharge of
groundwater. Extraction and discharge will be as outlined above, but the
actual treatment systeu will be chosen as a result of treatability studies
to be performed on contaminated groundwater from the site.
Alternative A-3 - Groundwater Extraction and Treatment
at Privately-Owned Treatment Works (POTW);
This alternative would involve treatment of groundwater at an existing
local publicly-owned treatment works (POTW). Groundwater would be
pumped from several on-site wells at a rate of 60 GPM and would be conveyed
by an iron pipeline to a sewer line six miles from the site.
-27-
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pumped from several on-site walls at a rate of 60 GPr-1 and would be conveyed
by an iron pipeline to a sewer line six miles from the site.
A risk of spreading contamination would exist, as leaks could occur in
the pipeline or sewer, allowing untreated groundwater to escape into tne
environment. The POTW does not currently accept industrial waste and has
indicated a reluctance in accepting waste from the Geiger (C&M Oil) site.
Also, alternative A-2 (above) provides the sane level of rauediation, at
relatively little cost increase, without the environmental risks associated
with off-site transport of contaminated groundwater. For these reasons,
this alternative has been rejected.
Alternative A-4 - Slurry Wall and Cap *
This alternative would not treat groundwater, but would reduce the migra-
tion of contamination by preventing groundwater movement through the area
enclosed by the slurry wall, and by reducing infiltration of surrace. water
Contaminated groundwater would remain on-site.
A circunferential slurry wall of low permeaoility would be placed around
the perimeter of the groundwater contamination plune. The wall would
extend into the Cooper Marl, a formation of low-permeability*which lies
at a depth of about 50 feet. A impermeable cap, consisting of 24 inches
of compacted clay, a 20-niil synthetic liner, 12 inches of gravel, a
geotextile fabric layer, and an 18-inch vegetated topsoil layer, would be
placed over the area bounded by the slurry wall. This cap would greatly
reduce infiltration of precipitation, and lateral and vertical migration
of contaminated groundwater would be impeded by the slurry wall and the
Cooper Marl, respectively. /
Soil remediation would not be required under this alternative, as the areas
of highest soil contamination would be covered oy the cap, preventing the
spread of contaminated soils. However, areas of lesser soil contamination
would remain in place and contaminated groundwater outside of the slurry
wall would continue to migrate off-site.
This alternative has been rejected because contaminated groundwater and
soils would remain on-site, and not all groundwater would be remediated.
In addition, the expected effective life of the slurry wall and cap is only
thirty years. Should failure occur, contaminants would be free to migrate
off-site.
5. 2 GROUP B ALTERNATIVES - SOIL REMEDIATION
Alternative B-l: Cap
This alternative would involve construction of a three-layered cap over the
area of highest soil contamination, thus reducing the risk of human and
environmental contact with contaninated soils. Infiltration of surface
water and the resultant production of leachate would be reduced.
-28-
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A cap conforming to RCRA guidelines would be constructed over a 1.2-acre
area of soil contamination. This would be the oil-stained area on the
site. The cap would consist of a two-foot thick compacted clay layer, a
twenty-mil synthetic liner, and a one-foot thick gravel drainage layer.
Overlying these would be geotextile fabric and eighteen inches of topsoil.
The topsoil would be graded to a two percent slope and vegetated to promote
run-off and control erosion. Human and environmental contact with
contaminated soil beneath the cap would be eliminated. Infiltration of
surface water would be greatly reduced due to the design ot the cap.
This alternative is eliminated from consideration because areas of soil
contamination outside the oil-stained area would still subject human and
environmental receptors to the risk of contact with contaminants. Also,
groundwater would continue to be contaminated as it flows laterally across
the site, caning into contact with the soil beneath the cap. Contaminants
would remain on-site and continue to act as a source of groundwater
contamination. Also a permanent remedy is practicable and meets the'
requirements of SARA, Section 121.
Alternative B-2: Vegetative or Gravel Cover
Under this alternative, a vegetative or gravel cover would be placed over
the highly-contaminated oil-stained area, preventing human and environmental
contact with the covered soil.
A vegetative cover would be constructed by placing an 18-inch layer of
topsoil over the oil-stained area/. This topsoil would be graded to a
2-percent slope and vegetated. A diversion ditch would be constructed at
the higher end of the cover to reduce run-on of surface water from other
areas of the site.
An optional cover of gravel rather than vegetated topsoil would allow
current use of the site for equipment storage to continue.
Both types of cover are eliminated from consideration because contaninated
soil would remain on-site and would act as a source of continuing
contamination of'groundwater. Contaninated soil outside'the oil-stained
area would remain in its current condition, posing a potential risk of
exposure to human and environmental receptors. Infiltration of precipita-
tion would continue, with the possibility of resultant leachate generation.
Groundwater would continue to come into contact with contaminated soil
beneath the cover. Also, a permanent remedy is practicable and meets the
requirements of SARA, Section 121.
-29-
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Alternative B-3: Partial Excavation, On-Site Disposal, and Cap
This alternative would involve placement of contaninated soils which are
outside the oil-stained area onto the oil-stained area, and then capping
the area.
Approximately 53,000 cubic feet of contaninated soil would be excavated
and placed over the contaminated soil in the oil-stained area. This area
is about 1.2 acres in size. A cap conforming to RCRA standards, as
described in Alternative B-l, would be constructed over this area.
This cap would prevent hunan and environmental contact with any contami-
nated soil on the site. However, contaminants would still be present as
a source material, contacting and contaminating the ground water. This is
not a permanent remedy, whereas a permanent remedy which meets the require-
ments of SARA, Section 121, is practicable at this site. Therefore, this
alternative is eliminated from consideration.
Alternative B-4: Partial Excavation, On-Site Disposal, and Vegetative or
Gravel Cover
Under this alternative, the oil-stained area would be covered with conta-
minated soils from other areas ot the site. A vegetative or gravel cover
would be placed over these soils in the manner described under Alternative
B-2. Human and environmental contact with contaninated soil would be
eliminated.
This alternative is eliminated from consideration because contaminants
would remain on the site as a source material, contributing to groundwater
contamination. Soils beneath the site would continue to contact ground-
water, and precipitation would continue to infiltrate the soils, producing
contaminated leachate. Also, a permanent remedy meeting the requirements
of SARA, Section 121, is practicable at this site.
Alternative B-5: Excavation, On-Site Thermal Destruction, and Stabilization/
Solidification
This alternative would consist of excavation of all contaninated soils on
the site, thermal destruction of these soils in an on-site mobile thermal
destruction unit, treatment of the organic contaminants in soil with
stabilization/solidification reagents, and then backfilling excavated
areas with the treated soil. Organic contaminants would be destroyed,
and metals would be stablized so they will not migrate.
Approximately 11,300 cubic yards of contaninated soil would be excavated
on the site from the areas shown in Figure 4. The oil-stained area would
be excavated to a depth ot about b teet, while the additional areas would
be excavated to a depth of about 1 foot. Field analyses or a local lab
would be utilized during excavation to determine actual depths so that
all soils contaminated above the clean-up goals would be removed.
-30-
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The recommended alternative for groundwater remediation includes ground-
water extraction througn the use ot on-site wells; thus the soils would
De dewatered prior to excavation.
•
A mobile thermal destruction unit would be used to destroy organics in
the excavated soils. Following thermal treatment, the soils would be
treated by a stabilization/solidification (S/S) process which would
reduce the mobility and solubility of the metals in the soils. The S/S
process involves the use of chemical reagents which react with the metal
ions to form a chemically and mechanically stable solid.
The treated soil would be placed back into the excavated areas/ and the
site covered with gravel to allow present use of *the site to continue.
This alternative is a permanent remedy which would destroy or reduce the
mobility of all hazardous materials in the soils on the site. No risk of
human or environmental contact would exist atter remediation, and the
threat of groundwater being contaminated by the source material would.be
greatly reduced or eliminated. This alternative would not require long-
term maintenance. For these reasons, this alternative is the recommended
ranedy tor soil contamination at the Geiger (C&M Oil) site.
The preliminary soil cleanup goals given in Table 4 will be subject to
refinement during remedial design as additional data concerning degrada-
tion, attenuation, and migration of contaminants is developed. The final
cleanup goals will be such that contaminant levels remaining in the soil
.following treatment will not raise contaminant levels in the groundwater
above the cleanup goals established in Section 4.
Alternative B-6: Excavation and Off-Site Disposal
With this alternative, all contaminated soil on the site would be excava-
ted and disposed of at an off-site RCRA-approved hazardous waste landfill.
Approximately 11,300 cubic yards of soil would be excavated from the
areas shown in Figure 4. The oil-stained area would be excavated to a
depth of approximately 5 feet, with additional areas being excavated to
about one foot. Actual depths would be determined by use of a local or
mobile lab during excavation to assure that all contaminated soil above
cleanup goals is removed. Dewatering would be accomplished by use of the
recoranended groundwater alternative, which includes punping from on-site
wells. Excavated soil would be carried to an approved hazardous waste
landfill. The nearest approved landfill which has been identified is CSX
located at Pinewood, South Carolina. This location is approximately 90
miles from the site.
This alternative would result in the prevention of huoxan and environmental
contact with contaminated soil at the site. However, this is not a
permanent remedy, in that contaminated soil would be transferred from one
location to another. Under Section 121 of SARA, this will be the least-
preferred remedy when a permanent remedy is feasible. Because a viable
permanent remedy is available, this alternative is eliminated from conside-
ration.
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NO-ACTION ALTERNATIVE
Under the no-action alternative, groundwater and soil would not oe re-
mediated. Monitoring is an option which may or may not be implemented.
This alternative is presented to provide a base-level action, against
which other alternatives may be compared.
This no-action alternative would not be protective of human health and
the environment. Contaminated groundwater could eventually migrate to
residential wells downgradient of the site, and could discharge into the
Wallace River wetlands, which are inhabited by endangered species.
The no-action alternative is rejected for these reasons, and because it
would not comply with SARA requirements to reduce the volume, mobility,
or toxicity of hazardous substances when treatment to accomplish this is
feasible.
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6.0 RECOMM5NDED ALTERNATIVES
6.1 DESCRIPTION Of RECCCWQJDED REMEDY
The recommended alternatives for remediation of groundwater and soil con-
tamination at the Geiger (O.M Oil) site include extraction, treatment, and
discharge of groundwater; and excavation, on-site thermal treatment,
stabilization/solidification, and backfilling of contaminated soils on
the site. 4
Treatability studies will be performed to determine the groundwater treat-
ment system or systens which will be used. The,system(s) may include air
stripping, carbon adsorption, flocculation/sedimentation or other appro-
priate groundwater treatment technologies. All or any combination of
these may be included to assure that the indicator chemicals are reduced
to concentrations at or below the clean-up goals specified in Table 3.
The treatment systen(s) will also be selected and designed to assure that
concentrations of contaminants not included as indicator chenicals are
reduced in the same proportion as the indicator chemical concentrations.
Contaminated soil will be treated Dy use of an onsite thermal destruction
unit to destroy organic compounds in the soil. All soil containing
indicator organic chemicals at levels above the cleanup goals will be
excavated and thermally treated. Where indicator metals are above the
cleanup goals following treatment, the soil will also under go stabilization
/solidification. Following treatment, the soil will be placed back into -
the excavation and graded. At selected intervals during excavation, soil
sanples will be taken and will be analyzed by a local or mobile lab to
determine the limits of excavations. It should be noted that the action
levels in Table 4 are preliminary goals and are subject to refinement
during remedial design.
Before thermal treatment is implemented, solidification/stabilization
will be evaluated to determine its effectiveness in achieving the remedial
action goals.
These recommended alternatives meet the requirements of the National Oil
anJ Hazardous Substances Contingency Plan (ICP), 40 CFR 300.68 (j), and
the Superfund Amendments and {^authorization Act of 1986 (SARA). This
remedy permanently and significantly reduces the volune of hazardous
substances in the groundwater, and reduces the volune and/or mobility of
contaminants in the soil. No long-term maintenance will be required for
this remedy.
These alternatives are cost-effective when compared with other applicable
alternatives. Alternative A-3 has a high risk of spreading contamination;
A-4 does not remove source material and has an estimated effective life
of only 30 years. Alternatives B-l, B-2, B-3, and B-4 would leave source
material on-site, in contact with the groundwater; B-6 would remove conta-
minated soil from the site, but would landfill it off-site. Alternative
B-5 is considered cost-effective because it would be a permanent remedy,
providing the greatest protection to human health and the environment.
-------
6.2 OPERATION AMD MAINTENANCE
This remedy will require approximately 29 months for groundwater treatment
and 19 months for soil remediation, following design and contract award.
The total implementation time for these remedies will be approximatelv 3
years, when the remedy is completed, no long term operation and maintenance
(O&M) will be required.
Long term groundwater monitoring will be required to assure the effective-
ness and permanence of the soil and groundwater remedies. Monitoring
wells and residential wells on and off the site will be included in the
monitoring program. Groundwater sampling will be conducted quarterly for
the first two years, and yearly after that. Thirty years of monitoring
was included in cost estimates, but this period may be significantly
less.
6.3 COST OF RECOMMENDED ALTERNATIVES
Capital cost for groundwater remediation is $392,000 to $930,000, and
system operating costs are $1,334,000 to $1,573,000. Long-term operation
& maintenance (O&M) of this remedy is not required, but groundwater
monitoring will be necessary to assure the permanence of this remedy.
The present worth cost of monitoring was calculated to be $367,200 based
on thirty years of annual monitoring. The actual monitoring period may
be less if no unacceptable contamination levels are detected during the
initial years following site remediation. The total present worth cost
of this alternative is $1,736,000 to $2,503,000.
Capital cost for soil remediation/is $5,191,000 including actual system
operation. No long-term operation and maintenance will be required
following site remediation. Long-term groundwater monitoring will be
required to assure that this remedy is permanent. Monitoring costs are
given with the groundwater costs, and will not be duplicated for soil
treatment.
The total present worth cost of this remedy, including both soil and ground-
water remediation and long-term monitoring, is $6,917,000 to $7,693,400.
Cost-sharing responsibilities of the State of South Carolina are discussed
in Section 8.0.
6.4 SCHEDULE
The planned schedule for remedial activities at the Geiger (C&M Oil) site
is as follows:
May 1987 Approve Record of Decision
October 1987 Begin Remedial Design
July 1988 Complete Remedial Design and Begin Mobilization
January 1989 Complete Mobilization, Equipment Installation, and Testing
July 1991 Complete Remedial Activities
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6.5 FUTURE ACTIONS
Following completion of remedial activities, no further action will need
to be performed to maintain this renedy. The recommended alternatives are
a permanent remedy and will require no long term operation or maintenance.
Long term groundwater monitoring will be required to assure the effective-
ness of this remedy.
6.6 CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS
Remedial actions performed under CERCLA must comply with all applicable
federal and state regulations. All alternatives considered for the Geiger
(C&M Oil) site were evaluated on the basis of the degree to which they
complied with these regulations. The recommended alternatives were found
to meet or exceed all applicable environmental laws, as discussed below.
t
•
0 Resource Conservation and Recovery Act
The recommended remedy for soil contamination includes incineration,
which is regulated under the Resource Conservation and Recovery Act
(RCRA). Incineration will be conducted entirely onsite and' is therefore
exempt fron all Federal, State, and local permitting requirements, as
specified in SARA, Section 121(e}(l). However, ail substantive regulations
governing incineration will be complied with, even though a formal permit
is not required.
0 Clean Water Act /
Contaminants have been detected in a marshy area near the site, but adverse
environmental impacts associated with remediating these areas would be
greater than any benefits which might be obtained. Soil remediation is
aimed at source control, and implementation of the recommended alternative
would result in an end to further contamination of surface water.
0 Flocdplain Management Executive Order 11988
This site does not lie within a flocdplain and thus is not subject to the
requirements of E.O. 11988.
0 Department of Transportation
Transport of hazardous substances is regulated by the Department of Trans-
portation (DOT). It residual material results from the groundwater treat-
ment system, it will be shipped to an off-site disposal facility. If
tests on the material indicate the need for disposal in a hazardous waste
tacility, DOT regulations governing its shipment will be followed.
-35-
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0 Occupational Safety and Health Administration
A health and safey plan will be developed during remedial design and will
be followed during field activities to assure that regulations ot the
Occupational Safety and Health Administration (OSHA) are followed.
0 Safe Drinking Water Act
Maximum Contaminant Levels (MCLs) established under the Safe Drinking Water
Act were found to be relevant and appropriate to remedial action at the
Geiger site. The cleanup goals for groundwater established in Section 4
use MCLs or proposed MCLs as the goal when an MCL or PMCL has been set,
unless a more stringent criteria results in the use of a lower concentra-
tion limit.
0 National Pollutant Discharge Elimination System
Discharge of treated groundwater is part of the recommended remedial
alternative. This discharge will meet effluent limit requirements of the
National Pollutant Discharge Elimination System (NPDES). Aquatic life
chronic toxicity values, which are used in the NPDES permitting system,
were used in determining the groundwater cleanup goals in Section 4,
unless a more stringent criteria was used to set a lower concentration.
Bench-scale or pilot tests, including bioassays, will be conducted where
appropriate during design of this alternative to set effluent limits, and
to optimize the groundwater treatment system so that these effluent
limits are met. /
0 Endangered Species Act
The recommended remedial alternative is protective of species listed as
endangered or threatened under the Endangered Species Act. Itequirements
of the Interagency Section 7 Consultation Process, 50CFR, Part 402, will
be met. The Department of Interior, Fish and Wildlife Service, will be
consulted during remedial design to assure that endangered or threatened
species are not adversely impacted by implementation of this remedy.
0 Ambient Air Quality Standards
The incineration and groundwater treatment systems will be designed and
monitored to assure that air emissions meet all State and federal standards.
0 State Drinking Water Standards
Maximum contaminant levels established by State of South Carolina regula-
tions are adopted from those ot the federal Safe Drinking Water Act, and
will be met as discussed above.
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7.0 COMMUNITY RELATIONS
A. public meeting was held on January 29, 1987, at the Hollywood Town Hall
to discuss the remedial alternatives developed in the Feasibility Study.
EPA did not indicate a preferance for a particular alternative. Comments
from the public did not favor any particular alternatives, and none ot the
alternatives were opposed by anyone. No comments in regard to any ot the
alternatives were received during the three-week public comment period
which ended February 19, 1987.
The public did show a desire for remediation of the site, and seened to
favor removal or destruction of contamination fpund in the soil and
groundwater. No opposition frcm the public is expected if the recommended
remedial alternative is implemented.
A Responsiveness Summary has been prepared to summarize conmunity concerns
and EPA's community relations activities.
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8.0 STATE INVOLVEMENT
As required by CERCLA, Section 104(C), the State must assure payment of
ten percent of all costs of remedial action. Remedial action has been
defined in SARA as including all construciton and implementation activities
until site remediation is completed. Activities required to maintain the
effectiveness of the remedy following completion of the remedial action
is considered operation and maintenance (O&M). If surface water or
groundwater treatment is part of the remedy, only the first ten years of
such treatment will be considered as remedial action; the remaining period
of treatment will be a part of O&M activities. The State is required to
pay 100 percent of all O&M following completion of the remedial action.
EPA and the State may enter into an agreement whereby EPA would fund 90%
of O&M costs, for a period not to exceed one year*, until the remedy is
determined to be operational and functional.
A summary of State cost-sharing obligations for the recommended alternative
at the Geiqer (C&M Oil) site is shown in Table 7. The State of South*
Carolina's cost-sharing responsibility would be in the range of $809,600
to $876,600.
The State of South Carolina has been consulted on the selection of this
remedy. The State has concurred, but has pointed out that their funds
for cost-sharing are limited. Although the State presently has funding
to cover their share of this remedial action, they are concerned about
funding problems on future remedial actions at other NPL sites in the state.
The State's letter of concurrence may be found in Appendix B.
-38-
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TABLE 7
STATE COST-SHARING OBLIGATIONS
GEIGER (C&M OIL) SITE
EPA
STATE
TOTAL
DESIGN
CAPITAL COSTS
IMPLEMENTATION
FIRST-tfEAR MONITORING
LONG-TERM MONITORING
TOTAL
1,116,700-1,224,100
0 1,116,700-1,224,100
4,019,900-4,406,600 446,700-489,700 4,466,600-4,896,300
869,800-1,085,100 96,600-120,600 • 966,400-1,205,700
101,000
0
11,200
255,100
112,200
255,100
6,107,400-6,816,800 809,600-876,600 6,917,000-7,693,400
-39-
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APPENDIX B
RECORD OF DECISION AMENDMENT, JULY 1993
t
-------
Amendment to the
4
Record of Decision
i
Summary of Remedial Alternative Selection
Geiger (C & M Oil) Site
Rantowles, South Carolina
Prepared by:
U.S. Environmental Protection Agency
Region IV
Atlanta, Georgia
-------
DECLARATION FOR THE
AMENDMENT TO THE
RECORD OF DECISION
SITE NAME AND LOCATION
Geiger (C & M Oil) Site
Rantowles, South Carolina
STATEMENT OF BASIS AND PURPOSE
This decision document presents the,selected remedial action
for the Geiger (C & M Oil) Site, in Rantowles/ South Carolina,
chosen in accordance with CERCLA, as amended by SARA and, to the
extent practicable, the National Contingency Plan. This decision
is based on the administrative record fil'e for this Site.
The State of South Carolina concurs on the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from
this Site, if not addressed by implementing the response action
selected in this ROD Amendment, may present an imminent and
substantial endangerment to public health, welfare, or the
environment.
DESCRIPTION OF THE REMEDY
/
This decision addresses the principal threat remaining at
the Site by treating the most highly contaminated soils and
ground-water. The soils will be treated in situ using
solidification/stabilization, such that the Site's soils will not
require any long-term management. The contaminated ground-water
will be extracted, treated on-site, and disposed of either on-
site or off-site. Treated ground-water will be disposed of
either to an on-site stream which flows off-site or to the same
atearn off-site.
The major components of the selected remedy include:
- In Situ Stabilization/Solidification of contaminated
soils; and
- Extraction of contaminated ground-water, on-site
treatment of extracted ground-water, and discharge of
treated ground-water to either an on-site or off-site
stream.
DECLARATION
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
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-2-
are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. This remedy utilizes
permanent solutions and alternative treatment technologies to the
maximum extent practicable for this Site. This remedy does
satisfy the statutory preference for treatment as a principal
element of the remedy. However, because waste/ although treated,
is being left on-site, leachate from the stabilized/solidified
soil must be monitored.
Because this remedy leaves wastes on-site, a review will be
conducted within five years after commencement of the remedial
action to ensure that the remedy continues to provide adequate
protection of human health and the environment.
Patrick M. Tobin
Acting Regional Administrator
/9
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Amendment to the Record of Decision
Summary of Remedial Alternative Selection
Geiger (C & N Oil) NPL Site
Rantowles, South Carolina
1.0 INTRODUCTION
This Amendment to the Record of Decision (1987 ROD) provides a
current status of activities that have been completed since the
ROD was signed for the Geiger (C & M Oil) Site on June 1, 1987,
documents the Agency's decision to use Solidification/
Stabilization (S/S) alone to treat the contaminated soil instead
of incineration followed by S/S, and incorporates the ROD by
reference (Appendix A). All other provisions of the 1987 ROD
issued by EPA not inconsistent with the ROD Amendments included
herein remain in full force and effect.
1.1 Site Location and Description
The Geiger Site (the Site) is located along Highway 162 in
Rantowles, Charleston County, South Carolina, approximately ten
(10) miles west of the city of Charleston (Figure 1). The Site
is in a sparsely populated rural area. Approximately ten (10)
residences are located near the Site to the east and northeast.
The population in the immediate Site area is estimated at forty
(40) people. Several small businesses are located within a half
(0.5) mile of the Site along Highway 162. The property covers a
five (5) acre area of very little topographic relief, however,
the Site area is approximately one and one-half (1.5) acres in
size. This affected area is triangular in shape and is bounded
on two sides by ponds, and on the third side by a small rise,
approximately five (5) feet higher than the Site area.
Elevations on the Site range from approximately fifteen (15) to
thirty (30) feet above mean sea level.
1.2 Site History
On June 1, 1987, EPA selected a remedial alternative for the
Geiger (C & M Oil) Site cleanup which included:
- recovery of contaminated ground-water with on-site treatment
and discharge to an off-site stream;
- on-site thermal treatment of excavated soils to remove organic
contaminants;
- Solidification/Stabilization (S/S) of thermally-treated soil to
reduce mobility of metals;
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.r •:« '-.•*.* »..» .-
LOCATION PLAN
V
'-m^
(CBM OIL)
SITE
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-2-
- During Remedial Design S/S would be reviewed to determine if
S/S alone would achieve the remedial action goals; and
- During Remedial Design, soil cleanup goals would be refined.
A Potentially Responsible Party search conducted prior to the
commencement of the Remedial Investigation/Feasibility Study
(RI/FS) 'determined that there were no viable Potentially
Responsible Parties. EPA, therefore, conducted the RI/FS and
since the signing of the ROD on June 1, 1987, EPA has conducted
additional field investigations in orde^ to better characterize
and define the extent of the soil contamination. The results of
the analysis of the additional soil samples showed relatively low
levels of organic contaminants of concern (COCs) and that lead
and chromium were the primary COCs. During the development of
the Remedial Design for the soil, treatability testing and
modeling were conducted to determine if S/S alone would achieve
the remedial action goals and to refine the soil cleanup goals
(Table 1). Treatability studies, including the one performed by.
EBASCO, conducted on soils from the Site indicated that S/S alone
would meet the cleanup goals for the Geiger Site. The EBASCO
Study can be found in the Administrative Record (See Section 3.0
"Community Relations"). The determined soil cleanup levels fall
within EPA'S acceptable risk range, are protective of human
health and the environment, and will meet state water quality
standards at the point of discharge. Based on the results of
the additional soil samples, treatability studies, and because
the revised remedy, fundamentally changes the original remedy, the
Agency has decided to amend the 1987 ROD pursuant to the National
Contingency Plan (NCP), 40 C.F.R. § 300.435(c)(2)(ii).
1»3 Explanation of Fundamental Remedy Change
The 1987 ROD specified on-site thermal treatment of excavated
soils to remove organic contaminants and S/S of the thermally
treated soil to reduce mobility of the metals. The 1987 ROD also
stated that during the Remedial Design, S/S would be reviewed to
determine if S/S alone would achieve the remedial action goals.
The 1987 ROD stated that the action levels in the ROD were
preliminary goals and subject to refinement during the Remedial
Design.
New information has been developed since the issuance of the 1987
ROD. Additional soil sampling has indicated that the levels of
organic COCs were lower than previously described in the RI/FS
reports and the area of significant contamination is smaller than
originally thought. Extensive sampling has more precisely
defined the location of the contamination and shown that the main
soil contaminants are metals, which can be treated effectively
using S/S alone. Therefore, based on the results of the site-
specific treatability studies, the contaminants tha^. a.- e
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Table 1
TREATMENT CRITERIA
CHEMICAL
INDICATOR CHEMICAL
Benzo[a]pyrene
Benzo[a]anthracene
Benzo[b and/or kjfluoranthene
PCB (Arochlor 1254)
Benzene
trans-1,2-Dichloroethylene
Chromium
Lead
Toluene
1,2-Dichloroberizene "
1,1-Dichloroethane
Notes:
1 Criteria is Action Level.
2 Leachate criteria equal National Primary Drinking Water
Regulations latest and proposed Maximum Contaminant Levels
3 Criteria is" MCL for 1,2-Dichloroethane
Leachate Extraction Methodt TCLP
LEACHATE CRITERIA1 (uo/1)
10
10
,10
1
52
1002
150
15
10002
6002
53
PHYSICAL
Property
Unconfined Compressive Strength
Flexible Wall Permeability
Pass/Fail Criteria
> 50 psi
1 x 10'5 cm/sec
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currently found in the soil at the Site can be treated
effectively by the process of S/S alone. In addition, based on
current rates, incineration would be three to four times more
costly than S/S alone. In summary, the contaminants currently at
levels of concern at the Geiger (C & M Oil) Site can be treated
effectively solely using S/S.
1.4 Explanation of Significant Differences
The 1987 ROD also stated that ground-wa£er contamination would be
treated on-site and that the discharge of the treated ground-
water would be to an off-site stream. Since the signing of the
1987 ROD, it has been determined that because a portion of the
stream is on-site, discharge of the treated ground-water may be
appropriate to either an on-site or off-site part of the- stream.
The on-site discharge would be to the same stream as off-site
discharge and would meet the same substantive standards (ARARs)
as would off-site discharge. If discharge is to the off-site
part of the stream, an NPDES permit would be required, but if
discharge is to the part of the stream that is on-site, then the
substantive requirements of the NPDES permit would be met, but
the permit itself would not have to be obtained. Therefore, EPA
does not consider the issue of discharge location ,to be a
fundamental change to the 1987 ROD.
' " - -
2.0 ENFORCEMENT ANALYSIS /
A Potentially Responsible Party search was conducted in 1984
prior to the commencement of the RI/FS. It was determined that
there were no viable Potentially Responsible Parties.
3.0 COMMUNITY RELATIONS
EPA prepared a Record of Decision (ROD) on June 1, 1987, taking
into consideration the comments from the public and the results
of the FS. The most environmentally sound and cost-effective
remedy was then selected as a part of the ROD phase of the
Superfund process. EPA selected thermal treatment of the soil to
remedy the organic contamination, S/S of the soil following
thermal treatment to remedy the inorganic contamination, recovery
of contaminated ground-water with on-site treatment, and
discharge to an off-site stream. EPA also stated that during the
Remedial Design S/S would be reviewed to determine if S/S alone
would achieve the remedial action goals. A public meeting was
held in January 1987 in which all the alternatives were
presented, although a preferred remedy was not chosen. An
information repository was established and is located at the
Hollywood Town Hall in Hollywood, South Carolina, near Rantowles.
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This ROD Amendment was available for review and comment during
the public comment period, May 25, 1993, until June 25, 1993, and
will become part of the Administrative Record File, as required
by CERCLA S 117, 42 U.S.C. § 9617, and the NCP, 40 C.F.R.
S 300.825(a)(2). Mo comments were received during the public
comment period and no requests were received for an extension of
the comment period or for a public meeting.
4.0 CURRENT SITE STATUS
4.1 Hydroqeology
Ground-vater Contaminants
t
The current areal and vertical extent of ground-water
contamination were delineated from several sources of
information. The original source of information was from the
Remedial Investigation (RI). Since that time, additional
monitoring wells were installed in 1988. There are currently
twenty-seven (27) permanent monitoring wells on-site and off-
site, located in clusters of two to three wells, which range in
depth from approximately ten (10) to forty-five (45) feet below
land surface. After the new monitoring wells were installed,
these new wells and the wells installed during the RI were
sampled. There also have been several additional sampling events
since 1988; the last sampling event occurred during May 1992
through June 1992. During jbhe 1992 sampling event, the permanent
monitoring wells were sampled along with eleven (11) additional
temporary monitoring wells that were installed further
downgradient than the permanent wells, and at various locations
on-site and upgradient.
Sampling and analysis of the Monitoring wells indicate the
following:
Cadmium was detected above Maximum Contaminant Levels (MCLs) in
well MW-6s in the earlier sampling events. It was not detected
in the 1992 sampling event in any of the wells. Two metals which
were consistently detected above MCLs in all the sampling events
were the following:
Well Maximum Level MCLs
Contaminant No. Detected Federal/State)
chromium MW-2s 7.8 mg/L 0.100 mg/L
lead MW-6s 3.4 mg/L 0.015 mg/L
No contaminants of concern were detected during the last sampling
event in 1992 in samples collected from the additional permanent
monitoring wells located downgradient and north to northwest of
the Site.
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-5-
During the RI, organic contaminants, some of which exceeded MCLs,
were detected primarily in one monitoring well (MW-4s). However,
since the signing of the 1987 ROD, the results from five
additional post-ROD sampling events have not shown any organics
in this well. Only a few organics have been detected since that
time, sporadically in the wells installed during the RI, but no
organics were detected in the newer wells added in 1988. The
types of organics and the levels detected — mostly low and below
MCLs — varied with each sampling event and varied in each well.
Based on the sampling data, ground-water contamination has been
found primarily in the water-table wells located in the surficial
aquifer. The boundary of the contamination plume is defined by
those wells in which no contaminants were detected or were not
above background. The zone is bounded on the northwest side by
wells MW-08 to MW-11, on the west side by well MW-12, on. the
southwest side by well MW-03, and on the south side by temporary
well GT3BG2.
4.2 On-Site Soils
Since the 1987 ROD was signed, EPA has conducted additional field
investigations in order to better characterize and define the
extent of the soil contamination. The last sampling event
occurred in Hay 1992. The inorganics chromium and lead were
detected in most of the samples from the Site area.
Significantly high levels p'f the inorganics were detected,
especially at and near the location of the old lagoons. The
maximum chromium level detected was 6,275 mg/kg and the maximum
lead level detected was 730 mg/kg. A few organics, primarily
toluene and PCS, were detected in some of the samples collected
from the Site area near the old lagoon. The maximum levels,
respectively, of toluene and PCB detected in the soil samples
were 144 mg/kg and 10 mg/kg. Most soil sample levels of toluene
and PCB, however, were below 10 mg/kg and 1 mg/kg, respectively.
The results of the various field investigations show the area
needing treatment for soil contamination to be the triangular
area described in Section 1.1 of this Amendment. This triangular
area will be treated to a depth of ten (10) feet. Analytical
results from the RI are in the Remedial Investigation Report.
The analytical results from the additional field investigations
are in the In-Situ Solidification/Stabilization of Contaminated
Soil Remedial Design Report.
5.0 SUMMARY OP SITE RISKS
5*1 Public Health and Environmental Ob1<
At the time the 1987 ROD was signed, there was no current public
health threat to off-site residents and no significant -. Lsk to
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-6-
on-site workers under the reasonable case scenario via dermal
contact. Health risks associated with exposure by inhalation
were considered negligible. Nearby wells, which were located
upgradient, had not been affected by Site contaminants. There
are no nearby private wells located downgradient. Under the
future use scenario where the Site is developed and private wells
are installed, it was determined that soil remediation would be
necessary to prevent further leaching of contaminants into the
ground-water as well as recovery of the contaminated ground-water
in order to meet the remedial action objectives.
The waters of the surficial aquifer have been classified as Class
GB ground-water. Class GB aquifers are considered potential
sources of drinking water and must be remediated to levels that
do not adversely affect human health and; the environment.
Sampling data indicates that several contaminants in the- ground-
water plume exceed drinking water standards (chromium and lead) .
At the present time, all residents have access to municipal
water. In addition to being classified as a Class GB aquifer,
discharge of the untreated ground-water into the on-site ponds, :
which flow into an unnamed creek and thence into the Wallace
River, may potentially have an environmental impact on plant and
animal species in the various surface water bodies.
€.0 ALTERNATIVES CONSIDERED FOR SOIL REMEDIATION IN
JUNE 1987 ROD /
Soil remediation alternatives considered for the Geiger (C & M
Oil) Site are listed in Table 2 along with the reasons certain
alternatives were eliminated. For an in-depth analysis of the
other soil alternatives considered, see pages 23 - 32 of the 1987
ROD.
6.1 Alternative Previously Selected For Soil
The selected remedy for soil, as specified in the 1987 ROD, was
excavation, on-site thermal destruction, and Stabilization/
Solidification (S/S). The selection of this alternative is now
being reevaluated because new information has been developed
about the nature and extent of the contamination at the Site and
changes in the relative costs of various remedies since the 1987
ROD.
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Table 2
TECHNOLOGIES CONSIDERED FOR SCREENING
GEIGER (C & M OIL) SITE
RANTOWLES, SOUTH CAROLINA
'Possible Technologies
Eliminated (E)
or
Retained (R)
If Eliminated
Reason for
Doing So
I. Soil Technologies
1. Extraction (Soil Flushing)
2. Solidification/Stabilization
3. Attenuation
4. Immobilization
5. Incineration
6. Capping
7. Vegetative Cover
8. Excavation and Off-Site
Disposal
9. Partial Excavation with
On-Site Disposal
10. On-Site Containment/
Encapsulation
R
E
E
R
R
R
R
Not applicable to
waste characteristics
Not applicable to
Site characteristics
Unknown reliability
and effectiveness
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Table 2 (cont'd.)
Possible Technologies
Eliminated (E)
or
Retained (R)
If Eliminated
Reason for
Doing So
II. Groundwater Technologies
A. Groundwater Containment
1. Slurry Wall
2. Grout Curtains
B. Groundwater Recovery
1. Pumping (Extraction Wells)
2. Subsurface Drains
C. Groundwater Treatment
1. Flocettlation/Sedimentation
2. Filtration '
3. Air Stripping
4. Spray Irrigation
5. Activated Carbon
Adsorption
6. Ion Exchange/Sorptive
Resins
7. Reverse Osmosis
8. Biological Treatment
D. Groundwater Disposal
1. Discharge to Surface Water
2. Reinjection
R
' E
R
E
R
R
R
R
R
R
R
E
More expensive and
less effective than
slurry walls
Hydraulic conductivity
may be high
Expensive, dilute
waste stream
3. Pump to Local Wastewater R
Treatment Plant
Complex and expensive
compared to surface
discharge
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6*2 Description of Alternative Currently Being Considered
for Soil Remediation
Alternative 1 In-situ Stabilization/Solidification
Alternative 2 Excavation, on-site thermal destruction,
Stabilization/Solidification
6.2.1 Alternative 1 - In-Situ Stabilization/Solidification
*
Alternative 1 consists of the treatment of affected soil in place
by in-situ stabilization. This alternative involves the
stabilization of soil to a depth of tentfeet below land surface.
During the performance of the Remedial Design, it was determined
that in-situ stabilization would be more effective at the Site
than ex-situ stabilization since the ground-water was very
shallow, and because of dust and air emissions from excavation of
the contaminated soil.
In-situ stabilization includes the use of deep soil mixing
equipment that delivers stabilization reagents to the affected
soils during mixing operations. The process involves auguring
into the affected soils to the desired depth using hollow-stem
augers. The hollow-stem augers overlap and can vary from two to
five augers per assembly. A shallow soil mixing system also is
available and uses a single, wide diameter auger rather than an
assembly of overlapping augers. Treatment agents are introduced
into the disturbed matrix through jets constructed in the auger.
The reagents can be introduced in either a liquid or slurry form.
A system such as this could consist of the following typical unit
operations:
• Shallow Soil Mixing Assembly
• Reagent Containers and Feed Systems
Treatment duration will vary by depth and by the amount of mixing
required to ensure adequate S/S. The treatment duration
estimated for this Site is less than a year. Testing of the
solidified treatment zones also will be necessary to ensure that
performance requirements are being met. Low levels of organics
possibly may volatilize during the treatment process, therefore,
air monitoring equipment will be used. Treatability studies have
been completed using Site soils and these studies showed that
this alternative will effectively meet the remediation goals for
both the metals and the organics.
For a detailed description of ARARs, see Sections 6.3(2) and 0..?
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-8-
of this Amendment. The S/S alone treatment option is currently
estimated at $3.2 million (1992).
6*2*2 Alternative 2 - Excavation. On-Site Thermal Destruction.
Stabilisation/Solidification
This alternative would consist of excavation of all contaminated
soils on the Site (probably requiring a dewatering step), thermal
destruction of the organic contaminants in the soil in an on-site
mobile thermal destruction unit, treatment of the inorganic
contaminants in the soil with S/S reagents, and then backfilling
the excavated areas with the treated soil.
At the time the 1987 ROD was signed, the estimated cost of the
soil remedy selected in the ROD was approximately $5.2 million.
At this time, using the current estimated volume, the remedy
selected in the 1987 ROD could cost approximately $10.0 to $12.0
million. The estimated time period for this alternative is
greater than a year. . •
This alternative would destroy the organic contaminants and
stabilize the metals so that they would not migrate. For an in-
depth analysis of this alternative, including ARARs, see pages
30 - 31 of the 1987 ROD.
6*3 Comparative Analysis /
This analysis will compare the alternatives, A-l and A-2, for the
nine evaluation criteria detailed in the National Contingency
Flan (NCP). For a more detailed analysis of the remedy selected
in the 1987 ROD, which has S/S as a component, see pages 30, 31,
and 33 - 36 of the 1987 ROD.
1. Overall protection of human health and the environment -
Both of the alternatives accomplish this criterion. Both of the
alternatives are within Agency guidelines and would provide
overall protection by reducing or controlling the threat by
remediating the contaminated soil. Both alternatives would meet
the remediation goals and be long-term protective of human health
and the environment: A-l by chemically and physically binding
the organic and inorganic contaminants using S/S alone, and A-2
using thermal treatment to destroy the organic contaminants and
S/S to bind the inorganic contaminants. The additional
protection offered by in-situ S/S is further enhanced by the
short-term protectiveness gained from treatment without
excavation of waste materials, which would not have the air
emission concerns associated with thermal treatment of soils.
2. Compliance with ARARs - Alternatives A-l and A-2 would meet-
ARARs for soil and ground-water. No waiver from ARARs would be
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necessary to implement either cleanup alternative.
ARARs for A-l Soil Treatment
Currently, 40 C.F.R. Parts 60 and 61, 42 U.S.C. S 7401 etj.. sea.,
which include the National Emissions Standards for Hazardous Air
Pollutants (NESHAPs), promulgated pursuant to the Clean Air Act
S 101 et. sea, as amended, and the South Carolina Air Pollution
Control Regulations and Standards, SC Reg. 61-62, promulgated
pursuant to the Pollution Control Act, SC Code of Laws, 1976, as
amended, do not apply to air emissions caused by mixing the soil
in-situ with stabilization reagents. SC Reg. 61-62 establishes
limits for emissions of hazardous air pollutants and particulate
matter, and establishes acceptable ambient air quality standards
within South Carolina. Because the selected treatment does not
include thermal treatment of the soil as proposed by the.1987
ROD, no ARARs apply to air emissions caused by stabilizing the
soil.
40 C.F.R. Part 261, Subpart C, Characteristics of Hazardous
Waste, promulgated pursuant to the Resource Conservation and
Recovery Act (RCRA) § 3001, 42 U.S.C. § 6921, and SC Reg. 61-
79.261, Subpart C, defines those solid wastes which are subject
to regulations as hazardous waste. Because the wastes were not
hazardous wastes, currently no RCRA regulations apply, including
Land Disposal Regulations. However, confirmation sampling will
be done to ensure that the Toxicity Characteristic Leaching
Procedure (TCLP) requirements are not exceeded and thus no RCRA
regulated hazardous wastes have been generated.
ARARs for Ground-Water
If the alternative to discharge treated ground-water on-site is
chosen, the substantive requirements of the NPDES program will be
met although no permit is required for on-site discharge of
treated ground-water. If the off-site alternative to discharge
ground-water is chosen, the substantive and administrative
requirements of the NPDES program will be met and a permit will
be obtained.
For an in-depth analysis of the application of ARARs to the
original remedy which included S/S, see pages 35 - 36 of the 1987
ROD.
3. Long-term effectiveness and performance - Both of the
alternatives would provide a permanent remedy for both organic
and inorganic contaminants. Therefore, either alternative would
meet this criterion and reduce the risk associated with soil
contamination at this Site.
4. Reduction of toxicitY* mobility, and volume - Both
alternatives would reduce the t.ox?city and mobility of soil
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-10-
contamination. Alternative A-l would accomplish this by binding,
both chemically and physically, the organic and inorganic
contaminants. Alternative A-2 would destroy the organic
contaminants and chemically and physically bind the inorganic
contaminants. Both alternatives would prevent the threat of
further degradation of the ground-water.
5. Short-term effectiveness - Alternative A-l would provide
short-term effectiveness. Emissions would be minimal since the
remedy is in-situ and does not require excavation of the waste
materials. Alternative A-2, however, would not be short-term
effective because there would be air emissions from the thermal
treatment unit and dust and volatilization of contaminants as a
result of excavation of the soil. In addition, A-l would be
completed in less time than A-2 since A-2 would require
additional time to excavate (including dewatering steps), return
the soil following treatment, and thermally treat it.
6. Implementabilitv - Both alternatives are technically
feasible. The reliability of in-situ stabilization equipment has
been demonstrated at several sites. Implementation of the
treatment process for Alternative A-l has some level of technical
problems that could lead to schedule delays, especially since the
treatment reagents must be equally distributed throughout each
treatment area. The primary uncertainty associated with-ifl-situ
stabilization is the variability of treatment throughout the
treatment zone. This concern will be addressed by requiring.
sufficient overlap between "treatment areas and by sampling of the
treated zone. This alternative will not require permitting or
coordinating with other offices or agencies. Special drilling
equipment capable of injecting treatment agents during drilling
is required for in-situ stabilization, however, several
commercial vendors offer the process. Alternative A-2 is a^
proven technology. Wastes would be fed into the thermal unit at
a rate providing sufficient retention time for complete
combustion of the organic contaminants. Air monitoring and
analysis equipment would be needed to monitor scrubber effluent,
solids residue, combustion gases, system pressure and
temperature, and air flow rates.
7. Cost - Both of the alternatives are protective of human
health and the environment. The costs associated with
Alternative A-l are less than the costs associated with
Alternative A-2 and for this reason, Alternative A-l is the most
cost effective remedy.
8. State Acceptance - The State of South Carolina concurs with
the S/S alone treatment alternative.
9. Community Acceptance - At the time the 1987 ROD was signed,
many members of the community were quite vocal in criticizing the
thermal treatment portion of the remedy. This information was
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-11-
obtained from past articles in the newspaper and from
conversations with local residents in the last year or two. They
cited a history of exposure to contaminants from the incinerator
that was previously located at the Site. There were no official
comments submitted during the public comment period opposing the
alternative selected in the 1987 ROD, however, during the public
comment period EPA had not indicated a preference for a
particular remedy in the proposed plan. Conversations with
nearby residents in the recent past about Alternative A-l
indicated that the residents were not opposed to S/S only of the
contaminated soil.
4
7.0 gRTJgpron REMEDY
Based upon consideration of the requirements of CERCLA, the
detailed analysis of both alternatives, and public comments, EPA
has determined that Alternative A-l is the most appropriate
remedy for the contaminated soil at the Geiger (C & M Oil) Site
in Rantowles, South Carolina.
The selected remedy consists of the treatment of affected soil in
place by in-situ stabilization. The area to be treated is the
triangular area described in Section 1.1 of this Amendment. This
area is bounded on two sides by ponds and on the third side by a
small rise, approximately 5 feet higher than the Site area.
Testing of the solidified treatment zones also will be necessary
to ensure that performance /requirements are being met .
Treatability studies have been completed using Site soils that
showed this alternative effectively will meet the remediation
goals for both the metals and the organics.
The selected remedy consists of the treatment of affected soil in
place by in-sat u stabilization. This alternative includes the
use of deep soil mixing equipment that delivers stabilization
reagents to the affected soils during mixing operations. The
process involves auguring into the affected soils to the desired
depth using hollow-stem augers. The hollow-stem augers overlap
and can vary from two to five augers per assembly. A shallow
soil mixing system also is available and uses a single, wide
diameter auger rather than an assembly of overlapping augers.
Treatment reagents are introduced into the disturbed matrix
through jets constructed in the auger. The reagents can be
introduced in either a liquid or slurry form.
8*0 STATUTORY REQUIREMENTS
The U.S. EPA and SCDHEC believe that this remedy will satisfy the
statutory requirements of CERCLA § 121, 42 U.S.C. § 9621, and NCP
S 300.430, 40 C.F.R. § 300.430, of providing protection of human-
health and the environment, attaining Applicable or Relevant and
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-12-
Appropriate Requirements (ARARs) of other environmental statutes,
will be cost-effective, and will utilize permanent solutions and
alternative treatment technologies or resource recovery
technologies to the maximum extent practicable. Sections 8.1
through 8.5 below analyze the statutory requirements for this
Site.
8*1 Protection of Hnfnan Health and the Environment
The selected remedy provides protection of the public health and
environment through Solidification/Stabilization treatment of
contaminated soil. For a detailed analysis of this requirement,
see Section 6.3(1) of this Amendment.
t
8.2 Attainment of the Applicable or Relevant and Appropriate
Requirements (ARARs)
Remedial actions performed under CERCLA must comply with all
ARARs. All alternatives considered for the Geiger Site were
evaluated on the basis of the degree to which they complied with
these requirements. The selected remedy will comply with all
ARARs. Although the selected treatment does not include thermal
treatment of the soil as proposed by the ,1357 ROD, the selected
remedy does envision possible volatizationVlqf,,the low
concentration organics when/the soil is mixed with the
stabilization reagents. Thus, confirmation sampling will be done
to ensure that the air quality remains good and that no ARARs
become applicable to the air aspect of the remedy. In addition,
because the wastes were not hazardous wastes, no Resource
Conservation and Recovery Act (RCRA) regulations apply. However,
confirmation sampling will be done to ensure that the TCLP
requirements are not exceeded and thus no RCRA regulated
hazardous wastes have been generated.
Treated ground-water may be discharged on-site or off-site. If
the on-site alternative is chosen, no NPDES permit is required,
but the substantive requirements of the NPDES permit will
continue to be in effect and these requirements will be met. The
reason for the ground-water discharge location contingency is
because EPA will not need access to discharge treated ground-
water on-site. In addition, there is no difference in
discharging the treated ground-water on-site as opposed to off-
site because it is the same stream.
8.3 Coat Effectiveness
The remedy selected in the 1987 ROD now could cost $10.0 to $12
million. The Stabilization/Solidification alone treatment option
is currently estimated at $3.2 million (1992), and therefore, is
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-13-
the more cost effective remedy compared to the original remedy.
8»4 Utilisation of Permanent Solutions and Alternative
Treatment Technology or Resource Recovery Technologies
to the Maximum Extent Practicable
U.S. EPA believes the selected remedy is the most appropriate
cleanup solution for the contaminated soils at the Geiger Site
and provides the best balance among the evaluation criteria for
the remedial alternatives evaluated. This remedy provides
effective protection in both the short and long-term to potential
human and environmental receptors, is readily implementable, and
is cost effective.
Stabilization/Solidification of the contaminated soil represents
a permanent solution (through treatment) which will effectively
reduce and/or eliminate mobility of hazardous wastes and
hazardous substances into the environment.
*
8.5 Preference for Treatment as a Principal Element
Treatment of the contaminants will effectively prevent them from
posing a threat by leaching to ground-water, and therefore,
satisfies the preference for treatment.
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APPENDIX C
PROPOSED PLAN FACT SHEET
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
SUPERFUND FACT SHEET-AMENDED PROPOSED PLAN
GEIGER (C & M OIL) SUPERFUND SITE
Rantowles, Charleston County, South Carolina ^^^^
JUNE 1998
T^ ftad>eethiaelot*aieiJca^p>cd In la/ana redJcalitad loot ogieitb of the aognlafdeiaup efforuu dxXite. AaunibcroficrautpeelSclai&cXupcrfuadpmacxifprittiaiin bald
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INTRODUCTION
This Fact Sheet has been prepared by the U.S. Environmental Protection
Agency - Region IV (EPA) to ajnend the Record of Decision (ROD)
issued for the Geiger (C&M Oil) Site on June 1, 1987 which was revised
in a ROD Amendment issued on July 13, 1993. These two documents
selected the following remedial alternatives for the Site, which included:
• Recovery of contaminated ground water with on-site
treatment and discharge to an on-site or off-site stream;
• Solidification/Stabilization (S/S) of contaminated soil to
reduce the toxicity and mobility of the contaminants;
PThe purpose of this fact sheet is to propose a change in the remedial
alternative selected for treatment of contaminated ground water, and to
change the contaminants of concern for ground water. This revaluation
of the originally selected ground water remedy is consistent with EPA's
updating remedies reform. In addition, based upon additional sampling
since the ROD and the first ROD Amendment, EPA is proposing
Monitored Natural Attenuation to address the residual contaminated
groundwater instead of recovery of contaminated ground water with on-
site treatment and discharge to an on-site or off-site stream, as selected
in the ROD. EPA is also proposing to revise the contaminants of
concern for the groundwater. AU other provisions of the ROD issued on
June 1, 1987 and the ROD Amendment issued on July 13, 1993, by
EPA, not inconsistent with this ROD Amendment included herein,
remain in full force and effect.
Asthelead Agency for oversight of remedial activities at the Site, EPA
has worked in conjunction with the South Carolina Department of Health
and Environmental Control (SCDHEC). Through this support role,
SCDHEC has reviewed this preferred alternative and concurs with EPA's
recommendations. In accordance with Section 117(a) of the
Comprehensive Environmental Response, Compensation, and
Liability Act (CERGLA), EPA Is publishing this amended proposed
plan to provide an opportunity for public review and comment on the
revised cleanup option under consideration for the Site.
This fact sheet provides a current status of activities that have been
completed since the ROD was signed for the Geiger (C & M Oil) 'Site'
ttnjune 1,1987 and the ROD Amendment on July 13,1993, documents
Be Agency's decision to revise the contaminants of concern, and to use
monitored Natural Attenuation to address the residual contaminated
groundwater instead of recovery and treatment, and incorporates the
ROD and earlier ROD Amendment by reference. The original ROD and
ROD Amendment are located in the Information Repository located
at the Hollywood Town Hall, 3616 Highway 162, Hollywood. South
Carolina, (803)889-3222.
SITE DESCRIPTION AND HISTORY
The Geiger Site is located along Highway 162 in Rantowles, Charleston
County, South Carolina, approximately ten (10) miles west of the City
of Charleston. The Site is in a sparsely populated rural area.
Approximately ten (10) residences are located near the Site to the east
and northeast. The property covers a five (5) acre area of very little
topographic relief. The Site area is approximately one and one-half (1.5)
acres in size.
From 1969 to 1971, the She was the location of a waste oil recycling and
incineration facility. A series of eight waste oil lagoons, or pits, were
used to contain the waste oil prior to the recycling or incineration
process. Incineration activities at the Site stopped in 1971. The Site
property was purchased in 1982 by Mr. George Geiger who filled in the
lagoons so that the Site could be used to store construction equipment
for his company.
The South Carolina Pollution Control Authority and the Charleston
County Health Department began monitoring the Site in 1970 in
response to complaints by nearby residents about odors from the Site.
Two complaints, in 1971 and 1974 respectively, resulted in
investigations by the Charleston County Health Department. It was
determined that a potential health hazard existed at the Site. In 1980, the
South Carolina Department of Health and Environmental Control
(SCDHEC) and EPA conducted investigations at the Site and discovered
that the waste oil residues in the pits mere similar to substances associated
with automotive crankcases, brake fluids, and degreasing compounds.
EPA's sampling of private wells upgradient and one well downgradient
from the Site, revealed no contamination; however, ground water near
the waste ofl lagoons was found to contain elevated metal concentrations
and some volatile organic compounds (VOCs). In 1983, the Site
was added to the Superrund National Priorities List (NPL).
In 1985, EPA began a Remedial Investigation of the She, which was
completed in July 1986. The RI determined that soil on the Site was
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contaminated with lead, chromium, mercury, and polychlorinated
biphenyls (PCBi). Further, metals, such as lead as well as VOCs and
other organic compounds were found in the ground water beneath the
Site. No contaminants were detected in residential wells.
Following the RI, a Feasibility Study was conducted. EPA then released
a summary of the Feasibility Study, which presented the cleanup
alternatives that were under consideration. After considering public
comments received during the public comment period, EPA selected the
deanup alternative described in its June 1987 Record of Decision for the
Site.
Since the signing of the ROD. EPA has collected additional ground water
samples. Of the twenty-seven monitoring wells sampled, only two wells
continue to show any ground water contamination. In addition, the only
contamination detected was lead. No other COCs above dean-up
standards, that were identified in the original ROD, have been detected
in the monitoring weDs during the last several sampling events. Based on
the results of these additional samples, EPA has decided to propose an
amendment to the June 1987 ROD.
EXPLANATION OF FUND AMENTA! REMFfYy f HANftF
The June 1987 ROD, specified recovery and treatment of contaminated
ground water, and discharge to a stream.
New information has been developed since the issuance of the 1987
ROD and 1993 ROD Amendment. First, the contaminated soils have
been treated to prevent further leaching of contaminants to ground water
above drinking water standards. In addition, ground water samples from
the latest sampling events, have indicated that there are no longer organic
COCs in any monitoring wells and lead has been the only inorganic COC
consistently detected above drinking water standards, and in only two
out of approximately 27 monitoring wells. These two wells are not near
each other, but on opposite sides of the site. In addition, the lead level
has been decreasing in one of the two contaminated wells, and is near
drinking water standards.
The other monitoring well has shown an increase in the lead
concentration, however, temporary monitoring wells located between
the site and this monitoring well, did not show any detections of lead.
Cadmium has also been detected in this well, (but no other well,
including the above mentioned temporary wells). Also, the level
detected is not always in exceedance of its drinking water standard, and
if so, only by a slight amount. In addition, this well is not located near
any residents, but is in an undeveloped area.
It does not appear, based on the latest sampling data, that there is a
definable "groundwater plume', but very localized contamination,
extensively smaller fat size than originally thought. In addition the cost of
extracting and treating the ground water is approximately forty times the
cost of Monitored Natural Attenuation. Therefore, because the soil has
been treated to prevent further leaching of contaminants to the
ground water, and because additional sampling conducted by EPA shows
groundwater contamination in only two very small localized areas, one
area of which is near drinking water standards, EPA believes that the
most cost-effective means to address the remaining residual groundwater
contamination fa Monitored Natural Attenuation.
Because most of the COCs stated in the original 1987 ROD have not
been detected in the monitoring wells in the latest sampling events, EPA
is revising the COCs for the groundwater to include only those
contaminants detected above drinking water standards in the latest
sampling events. The revised list of COCs will include the following
contaminants and their respective Remedial Goals (RGs) which are based
on drinking water standards: Lead - 15 ug/kg and Cadmium - 5 ug/kg.
The groundwater will be sampled for all of the groundwater COCs, for
the first five years. At that time, the parameters will be revised to
include only those that were detected in the groundwater during the five
year period. This is expected to be inorganics only. Sampling of the
groundwater will occur twice a year for the first two years, and
annually for 3 years after this. At that time a different frequency rr il
designated. Two additional monitoring wells shall be installed between
the Site and M W-02s. All the monitoring wells shall be sampled during
the first sampling event. If no COCs above RGs are detected in the,
medium and deep monitoring wells, then only the shallow morutoring
wells shall be sampled for the five year period. If contaminants are
detected above RGs in these new wells or in the other monitoring wells .
(besides MW-06s or MW-02s), on a consistent basis, at any time in the
future, this remedy will be re-evaluated. This remedy may also be re-
evaluated, if the detections in MW-06i or MW-02s continue to increase
significantly. In addition, groundwater samples from the shallow
monitoring wells located downgradient of the solidified material shall be
analyzed for the soil COCs and sulfate for the first two years. If the soil
COCs (that are different from the groundwater COCs) are detected in
the wells, then the wells will continue to be sampled and analyzed for the
soil COCs, and the remedy may be re-evaluated.
CURRENT SITE STATUS
Soil Contamination
•
The soil contamination at the Geiger Site has been addressed using
Solidification/Stabilization which involved using cement in a reagent
mixture. The area that was treated was triangular in shape, as was the
old lagoon area, and was treated to a depth of approximately ten feet
below land surface. The purpose for treating the soils was to prevent
further leaching of contaminants to groundwater, thus protecting human
health and the environment.
Ground tvater Contaminants
The current area! and vertical extent of groundwater contamination were
delineated from several sources of information. The original source of
information was from the Remedial Investigation (RI). Since that time,
additional monitoring wells were installed in 1988. There are currently
twenty-seven (27) permanent monitoring wells on-site and off-site.
These wells are located in clusters of two to three wells, which range in
depth from approximately ten (10) to forty-five (45) feet below lind
surface. Current sampling data shows a significant decrease in the
number of contaminants and area of groundwater contamination,
compared to the information obtained during the RI/FS in 1986. Only
one contaminant, lead, consistently exceeds its drinking water standard.
Cadmium exceeds it's standard slightly, in one well, only some of the
time. At the present time, all nearby residents have access to municipal
water.
ALTERNATIVES
FOREGROUND- WATER
REMEDIATION IN IUNE 1987 ROD
The present and proposed groundwater alternative being considered for
the Geiger (C & M Oil) She are listed below. For an in-depth analysis of
the other groundwater alternatives originally considered, see pages 2 3 -
28 of the 1987 ROD.
Amative Previously Selected For GyoiiRdwfltejr
The selected remedy for groundwater, as specified in the 1987 ROD and
1993 ROD Amendment, was recovery of contaminated groundwi
with on-site treatment and discharge to an on-site or off-site stream.
The selection of this alternative is now being reevaluated as a result of
additional information now known about the nature and extent of the
contamination at the Site, and changes in the relative costs of various
remedies since the ROD was signed in 1987.
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DESCRIPTION OF ALTERNATIVES CURRENTLY BEING
CONSIDERED FOR SOIL REMEDIATION
Alternative A-1
Monitored Natural Attenuation
Alternative A-2
Recovery of contaminated groundwater with on-rite treatment and
discharge to an on-rite or off-rite stream.
Alternative A—I • Monitored Natural Attenuation
Alternative A-l consists of Monitored Natural Attenuation to address the
localized groundwater contamination. The area of groundwater
contamination has decreased significantly since the original ROD was
signed in 1987. In one location the lead concentration has been
decreasing, and is currently near MCLs. The other monitoring well has
shown an increase in lead concentration, however, groundwater samples
collected between this well and the site, have not shown any lead
contamination. It does not appear that there is a definable 'groundwater
plume', but a very localized area of contamination, which is extensively
smaller than originally thought. The well is not located near any
residents, but on undeveloped land. In addition, the soils have been
treated to prevent further leaching of contaminants to groundwater. The
Monitored Natural Attenuation option is currently estimated at J 34,000.
This alternative would consist of allowing natural processes to address
the groundwater contamination. Selected monitoring wells would be
sampled periodically, as described above, to ensure protection of human
health and the environment until the groundwater contamination is
remediated.
[Alternative A-2 - Recovery and Treatment of Groundwater
Recovery of contaminated groundwater with on-rite treatment and
discharge to an on-rite or off-site stream. Extraction -well* would be
installed in the area of groundwater contamination and the groundwater
would be recovered. The water would then go to an on-ritc treatment
plant, which would treat the contamination. After treatment, the water
would be discharged to an on-rite or off-rite stream nearby. The
monitoring and extraction wells, along with the discharge point from the
treatment plant, would be sampled periodically to ensure that the
groundwater is being treated. The extraction and treatment of
groundwater is currently estimated at $ 1.33 million.
COMPARATIVE ANALYSIS
This analysis will compare the Alternatives, A-l and A-2, for the nine
evaluation criteria detailed in the National Contingency Plan (NCP).
For a more detailed analysis of the remedy originally selected in the
ROD, see pages 23-28 of the ROD.
1 . Qv»*ra^ pmrffripn nf human tvjlth and thf rnvironmcnt - Both of the
alternatives would provide overall protection by reducing the residual
threat by addressing the contaminated groundwater. Both alternatives
would meet the remediation goals and be long-term protective of human
health and the environment: A-l by allowing the natural attenuation
process to address the lead in the groundwater, and A-2 by extracting
and treating the lead contamination in the groundwater.
2. rnmpTii»nce with ARAR« . Alternatives A-l and A-2 would meet
ARARs for groundwater. No waiver from ARARs would be necessary
to implement either cleanup alternative.
For an in-depth analysis of the application of ARARs to the original
remedy which would apply to the current preferred remedy, see page 3 6
of the 1 987 ROD. This would include the Safe Drinking Water Act.
3. T ^ng-terrr\ efT<»r*iv£ng<« and perfnrmanrg - Both of the alternatives
would provide a permanent remedy for the lead contamination.
Therefore, either alternative would meet this criterion and reduce the
risk associated with groundwater contamination at this Site.
4. R^ducrinn nFtf>«rityl
vnlutng - Alternative A-l would
not reduce the toxicity, mobility, or volume of contamination through
treatment, however, this alternative would reduce the toxicity through
a reduction in the lead concentration levels in the groundwater through
natural attenuation processes. Alternative A-2 would reduce the
mobility and volume of contamination through treatment.
S. Shnrt-trrm rftrctivrnff* . Alternative A-l would be the most
short-term effective, since this option only consists of collecting
groundwater samples. Alternative A-2, however, would not be as short-
term effective because of risks posed by activities during construction of
the treatment plant and installation of the extraction wells.
6. Implfmgntability . Both alternatives are technically feasible. Since
only groundwater sampling would occur for Alternative A- 1 , this
alternative is the most easily implementable. Alternative A-2 is
reasonably implementable and reliable since extraction and treatment of
groundwater has been demonstrated at numerous sites.
7. Cost - Both of the alternatives are protective of human health and the
environment. The costs associated with Alternative A- 1 are significantly
less than the costs associated with Alternative A-2 and for this reason,
Alternative A- 1 is the most cost effective remedy.
8. Statf Arvyptance - The State of South Carolina concurs with the
monitored natural attenuation alternative, A-l .
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OPPORTUNITY FOR COMMUNITY INVOLVEMENT
GLOSSARY
EPA is conducting a 30-day public comment period, from Jung 30 .
1998 to July 30r 1998. to provide am opportunity for public involvement
in the final cleanup decision for the Site. EPA may extend this comment
period based upon receipt of a timely request.
EPA will provide the opportunity for a public meeting upon request.
Individuals desiring a public meeting should contact either of the EPA
contacts listed below as soon as possible.
Public input is an important contribution to the remedy selection
process. During the comment period, the public is invited to review this
fact sheet, and other supporting documents at the repository, and offer
comments to EPA. If, after reviewing the information on the Site, you
would like to comment in writing on EPA's preferred alternative, on
other information presented in this document, or on other issues relevant
to Site cleanup, please submit your comments, to be postmarked no later
than July 30, 199Rtor
Ms. Sheri Panabaker
Remedial Project Manager
U. S. Environmental Protection Agency
61 Forsyth Street. WD-NSMB
Atlanta, Georgia 30303
EPA will review all comments received from the public as part of the
process of reaching a final decision on the most appropriate remedial
alternative for cleanup of the Site. EPA's final choice of a remedy for the
Site will be issued in an amendment to the Record of Decision.
FOR FURTHER INFORMATION CONTACT:
Sheri Panabaker
Remedial Project Manager
&
Cynthia Pcurifoy
Community Involvement Coordinator
(404)562-8798 or 1-800-435-9233
U.S. Environmental Protection Agency
61 Forsyth Street. WD-NSMB
Atlanta, Georgia 30303
•»*»»*•»»••••»»»»*»»*»
Administrative Record and
Information Repository
Hollywood Town Hall
6316 Highway 162
Hollywood, SC 29449
(803)889-3222
Administrative Record - A file which is maintained and contain^
information used by the EPA to make its decision on the selection a
response action under CERCLA. This file is required to be available for
public review and a copy is to be established at or near the site, usually
at the information repository. A duplicate file is maintained in a central
location such as a regional EPA and/or state office.
Applicable or Relevant and Appropriate Requirements
(ARARs) - Requirements which must be met by a response action
selected by EPA as a site remedy. "Applicable" requirements are those
mandated under one or more Federal or State laws. "Relevant and
appropriate" requirements are those which, while not necessarily
required, EPA judges to be appropriate for use in that particular case.
Aquifer - An underground geological formation, or group of
formations, containing usable amounts of ground water that can supply
wells and springs.
Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA) •
A federal law passed in 1980 and modified in 1986 by the Superfund
Amendments and Reauthorization Act (SARA). The Acts create a trust
fund, known as Superfund to investigate and dean up abandoned or
uncontrolled hazardous waste sites.
Ground water - Underground water that fills pores in soils or openings
in rocks. This water can be used for drinking, irrigation, and other
purposes.
Information Repository - Materials on Superfund and a specific s|
located conveniently for local residents.
National Priorities List (NPL) - EPA's list of uncontrolled or
abandoned hazardous wastes sites eligible for long-term clean up under
the Superfund Remedial Program.
National Oil and Hazardous Substances Contingency Plan
(NCP) - The Federal regulation that guides the Superfund program.
Public Comment Period - Time provided for the public to review and
comment on a proposed EPA action or rulemaking after it is published
as a Proposed Plan.
Record of Decision (ROD) - A public document that explains which
cleanup alternative will be used at a National Priorities List site and the
reasons for choosing the cleanup alternative over other possibilities.
Remedial Design/Remedial Action (RD/RA) - The remedial
design (RD) is a plan formulated by either the PRP or EPA or both to
provide the appropriate measures to remediate a hazardous waste site.
This plan may be modified many times through negotiations between
EPA an the PRP. The remedial action (RA) is the implementation of the
remedial design.
Solidification/Stabilization • conversion of active organic matter
into inert, harmless material and depositing residuals into a solid mass.
Volatile Organic Compounds (VOCs) - An organic (carboi
containing) compound that evaporates (volatilizes) readily at room
temperature.
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COMMENTS ON THE AMENDED PROPOSED PLAN FOR THE GEIGER (C& M OIL) SUPERFUND SITE:
COMMENTS SUBMITTED BY:
REQUEST TO BE PLACED ON THE
GEIGER (C & M OIL) SUPERFUND SITE MAILING LIST
If you would like your name and address placed on the mailing list for the Geiger (C & M Oil) Superfund Site, please complete
this form and return to: Cynthia Peurifoy, Community Relations Coordinator, EPA-Region IV, North Site Management Branch,
61 Forsyth Street, Atlanta, Georgia 30303, or call 1-800-43S-9233.
NTAMF.
TFT FPHOMF.
AFFTTTATinM.
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United States North Site Management Branch Region 4
Environmental Protection 61 Forsyth Street, NE
Agency Atlanta, Georgia 30303
Official Business
Penalty for Private Use
$300
Cynthia Peurifoy
Community Relations Coordinator
(Geiger Amended Proposed Plan, June 1998)
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APPENDIX D
STATE CONCURRENCE LETTER
-------
E C
SEP 1 8 1998
ROMOTE PROTECT PROSPER
500 Bull Street
:oIumbia,SC 29201-1708
September 8,1998
ttMMISSIONER:
Xwglas E. Bryant
WARD:
John H. Buniss
Chairman
William M.Hull, Jr.. MD
Vice Chairman
Roger Leaks, Jr.
Secretary
Mark B. Kent
Cyndi C. Mosteller
Brian K. Smith
Rodney L. Grandy
Mr. John Hankinson
Regional Administrator
US EPA, Region IV
61 Forsyth Street
Atlanta, GA 30303
__ CO
*' *-' C/")
p -^
<".'. "';
RE: Amendment to the Record of Decision for the Ground water-Remedy
Geiger (C & M Oil) NPL Site ^
Charleston County
Dear Mr. Hankinson:
The Department has reviewed and concurs with the Amendment to the Record of
Decision (ROD) for remedial action at the Geiger (C & M Oil) NPL Site: The
modified alternative for remedial action selected by EPA includes Monitored Natural
Attenuation of contaminated groundwater in lieu of an active pump and treat remedy.
In concurring with this ROD Amendment, the South Carolina Department of Health
and Environmental Control (SCDHEC) does not waive any right or authority it may
have to require additional corrective action in accordance with the South Carolina
Hazardous Waste Management Act and the Pollution Control Act. These rights
include, but are not limited to, the right to ensure that all necessary permits are
obtained and all cleanup goals and criteria are met, and the right to take a separate
action in the event cleanup goals and criteria are not met. Nothing in this 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 remedial alternative; and (2)
the implementation of the remedial alternative selected in the ROD Amendment is no
longer protective of public health and the environment.
This concurrence is contingent upon the State's above-mentioned reservation of
rights. If you have any questions, please feel free to contact Mr. Gary Stewart at
(803) 896-4054.
Sincerely,
/)
f\
R. Lewis Shaw, P.E.
Deputy Commissioner
Environmental Quality Control
cc. Hartsill Truesdale
Keith Lindler
Gary Stewart
Billy Britton
Rick Richter
r- ,,c * T TH AND ENVIRONMENTAL CONTROL
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