PB98-964024
EPA 541-R98-104
November 1998
EPA Supei fund
Record of Decision:
Calhoun Park Area
Charleston, SC
9/30/1998
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ENFORCEMENT
RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
CALHOUN PARK SUPERFUND SITE
CHARLESTON, CHARLESTON COUNTY
SOUTH CAROLINA
PREPARED BY:
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Calhoun Park Area Superfund Site
Charleston, Charleston County, South Carolina
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the Calhoun Park Area
Superfund Site (the Site) in Charleston, South Carolina, which was chosen in accordance
with the Comprehensive Environmental Response, Compensation, and Liability Act of
1980 (CERCLA), as amended by the Superfund Amendments and Reauthorization Act of
1986 (SARA), 42 U.S.C § 9601 etseq.. and, to the extent practicable, the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP), 40 C.F.R. Part 300 et seg. This
decision is based on the administrative record for this Site. The State of South Carolina,
acting as a support agency, concurs with the selected remedy.
ASSESSMENT OF THE SITE
Existing soil and groundwater contamination at this Site, consists mainly of BTEX and
PAHs, is attributable to the previous manufactured gas plant operations. Actual or
threatened releases of hazardous substances from this Site, if not • addressed by
implementing the response action selected in this Record of Decision (ROD), may present
an imminent and substantial endangerment to human health.
DESCRIPTION OF THE SELECTED REMEDY
This remedial action addresses NAPLs source areas, shallow groundwater contamination,
and contaminated soil as the principal threat at this Site. Sediment and surface water
contamination, in addition to intermediate groundwater contamination will be addressed
in a separate ROD.
The major components of the selected remedy include:
a Excavation and transportation of contaminated soils to a permitted landfill followed
by the backfilling of the excavated areas with clean fill;
G Source removal of NAPLs from both the shallow and intermediate aquifer;
D Treatment of groundwater plume through a combination of recovery wells/filtration
system and phytoremediation;
G Additional sampling of surface water and sediment, following mitigation of coal tar
discharge into Cooper River, to fully delineate extent of contamination and potential
threat to aquatic and terrestrial life.
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STATUTORY DETERMINATIONS
The selected remedy is protective of human health, complies with Federal and State
requirements that are legally applicable or relevant and appropriate to the remedial action,
and is cost effective. The groundwater portion of the remedy was based on EPA's
expectation that the remediation of groundwater to MCLs will be challenging given the
presence of NAPLs at this Site. Therefore a phased approach has been selected
consisting of removal or treatment of NAPL to the maximum extent practicable, followed
by containment of potentially non-restorable source areas, and restoration of aqueous
contaminant plumes.
This selected remedy will result in contaminated groundwater remaining on-Site above
health-based levels until remedy implementation is complete. Therefore, five (5) year
reviews will be conducted after initiation of remedial action to insure that the remedy
continues to provide-adequate protection of human health and the environment.
Richard Green
Division Director
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1.0 SITE NAME, LOCATION, AND DESCRIPTION 6
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES , 6
2.1 Previous Site Operations 6
2.3 Previous Investigations and Containment Measures 9
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION 11
4.0 ADDITIONAL EARLY RESPONSE ACTIONS 12
5.0 SUMMARY OF SITE CHARACTERISTICS 12
5.1 Physical Characteristics 13
5.1.1 Demography 13
5.1.2 Meteorology 13
5.1.4 Surface Water Hydrology 14
5.1.5 Geology/Hydrogeology 14
5.2 Nature and Extent of Impact 15
5.2.1 Surface/Subsurface Soils 19
5.2.2 Groundwater 19
5.2.3 NAPLs 25
5.2.4 Sediments 27
5.2.5 Surface Water 29
6.0 SUMMARY OF SITE RISKS 29
6.1 Human Health Baseline Risk Assessment 30
7.0 DESCRIPTION OF ALTERNATIVES 33
7.1 Development of Cleanup Levels 33
7.1.1 Soils 33
7.1.2 Groundwater/NAPL 34
7.2 Soil Alternatives 38
7.2.1 Alternative 1: No Action 38
7.2.2 Alternative 2: Natural Attenuation 38
7.2.3 Alternative 3: Surface Cover/Capping 39
7.2.4 Alternative 4: In Situ Bioremediation 39
7.2.5 Alternative 5: Excavation, Chemical/Biological Treatment,
& Replacement 39
7.2.6 Alternative 6: Excavation, Thermal Desorption, & Replacement
39
7.2.7 Alternative 7: Excavation & Off-Site Incineration 40
7.2.8 Alternative 8: Excavation & Off-Site Landfill 40
7.3 Shallow Groundwater 40
7.3.1 Alternative 1: No Action 40
7.3.2 Alternative 2: Institutional Controls 40
7.3.3 Alternative 3: Institutional Controls, Source Removal,
Phytoremediation, and Natural Attenuation 41
7.3.4 Alternative 4: Institutional Controls, Source Removal,
Phytoremediation. and In Situ Bioremediation 41
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7.3.5 Alternative 5: Institutional Controls. Source Removal,
Phytoremediation, Grout Curtain, Vertical Wells, Separation,
Filtration, GAC, and POTW Discharge 41
7.3.6 Alternative 6: Institutional Controls, Source Removal,
Phytoremediation, Sheet Piling, Vertical Wells, Separation,
Filtration, GAC, and POTW Discharge 41
7.3.7 Alternative 7: Institutional Controls, Source Removal,
Phytoremediation, Interceptor Trenches, Separation,
Filtration, GAC, and POTW Discharge 42
7.3.8 Alternative 8: Institutional Controls, Source Removal,
Phytoremediation, Vertical Wells, Separation, Filtration,
GAC, and POTW Discharge 42
7.4 Intermediate Groundwater 42
7.4.1 Alternative 1: No Action 42
7.4.2 Alternative 2: Institutional Controls 42
7.4.3 Alternative 3: Institutional Controls and Natural Attenuation ... 42
7.4.4 Alternative 4: Institutional Controls and In Situ Bioremediation . 43
7.4.5 Alternative 5: Institutional Controls, Vertical Wells,
Separation, Filtration, GAC, and POTW Discharge 43
8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 43
8.1 Overall Protection of Human Health & the Environment
43
8.1.1 Soil 44
8.1.2 Shallow Groundwater/NAPL 46
8.1.3 Intermediate Groundwater 50
8.8 STATE ACCEPTANCE . . . : 50
8.9 COMMUNITY ACCEPTANCE 51
9.0 THE SELECTED REMEDY 51
9.1 Soil - Excavation and Off-Site Disposal 51
9.2 Groundwater/NAPL 52
9.2.1 NAPL/Groundwater 52
9.3 Cost Summary 53
10.0 STATUTORY DETERMINATIONS 54
10.1 Protection of Human Health and the Environment 54
10.2 Compliance with Applicable or Relevant and Appropriate
Requirements : : 55
10.3 Cost Effectiveness 55
10.4 Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to the
Maximum Extent Practicable 56
10.5 Preference for Treatment as a Principal Element 56
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FIGURES
Figure 1-1 (Site Map) 7
Figure 5-1 (Stratigraphic Cross Section) 16
Figure 5-2 (Soil & Groundwater Sampling Locations) 17
Figure 5-3 (Sediment & Surface Water Sampling Locations) 18
Figure 5-4 (Benzene Isoconcentration Map for Shallow Groundwater) 22
Figure 5-5 (Total PAH Isoconcentration Map for Shallow Groundwater) 23
Figure 5-6 (Naphthalene Isoconcentration Map for Shallow Groundwater) 24
Figure 7-1 (NAPL/Groundwater Remediation Locations) 37
TABLES
Table 5-1 (Chemicals Detected in Soil) 20
Table 5-2 (Chemicals Detected in Shallow Groundwater) 21
Table 5-3 (Contaminants Detected in Intermediate Groundwater) 26
Table 6-1 (Carcinogenic & Non-Carcinogenic Risks) 32
Table 7-1 (Soil Preliminary Remediation Goals) 35
APPENDIX
Appendix A (State Concurrence Letter)
Appendix B (Responsiveness Summary)
Appendix C (Public Meeting Transcript)
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1.0 SITE NAME, LOCATION, AND DESCRIPTION
The Calhoun Park Area Superfund site (hereinafter referred to as "the site") is located in
Charleston, South Carolina. The general location of the site is depicted in Figure 1 -1. The
site consists of an electrical substation and an abandoned city park as well as portions of
the Ansonborough Homes housing project, Ludens Marine, and the National Park Service
property
The site under investigation initially consisted of an 18 acre area comprising an electrical
substation, an abandon city park, and the Ansonborough Homes housing project. Based
on initial sampling data the investigation was later expanded to include Ludens Marine, the
National Park Service property, the George E. Campsen property, Dockside
Condominiums, and the Deyton property. Presently these properties consists of a mixture
of industrial, commercial and residential land usage. A detailed figure of these properties
is illustrated in Figure 1-1.
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
2.1 Previous Site Operations
Historically the various properties which comprise the site have been used for several
purposes including a manufactured gas plant (MGP), a steam generating plant, a sawmill,
a rosin wood treating operation (Fernoline Chemical), and a shipyard. The MGP operated
on the location of the present electrical substation. The Ludens marine property originally
housed a steam plant supporting the MGP operations. This same building was later
converted to a ship repair/marine retail store known as Ludens Marine. Both the sawmill
and the rosin wood treating company operated at the present location of the abandon city
ballpark. The rosin wood treating operations also utilized portions of the Ansonborough
Homes property. Shipyard operations were previously performed at the present location
of the NPS property, Dockside condominiums, and the Deyton property.
While many of these past operations may have contributed to the environmental impact
upon this area, the MGP was the major contributor for contamination at this site. This is
evidenced from both the composition of waste present and the distribution of this waste
relative to the former MGP location. For these reasons the following historical information
focuses on the MGP operations.
Manufactured Gas Plant operations began at the site in the 1850's with the construction
of a Manufactured Gas Plant (MGP) located on the property presently occupied by the
electrical substation. Manufactured gas, also referred to as town gas, was produced at the
site under two basic processes known as coal carbonization and carbureted water gas.
The MGP was originally constructed in 1855 as a coal gasification plant and operated in
this manner until 1910 at which time operations were
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converted to a carbureted water plant which continued to produce gas until the plant
closed in 19571.
The coal carbonization process consisted of three steps where coal was first heated to
generate a gas. The gas was then collected and cooled using both a condenser and
scrubber. The gas was then purified by passing the gas through a filter material and finally
sent to a gas holder tank for storage. The carbureted gas operations consisted of passing
steam over a bed of hot coal which generated a product called "blue gas". To enrich the
heat value of blue gas, it was next passed through a carburetor unit. In this unit oil was
sprayed over hot bricks in the presence of blue gas. This process in turn produced an oil-
enriched blue gas. The oil-enriched gas was passed through a super-heater where the oil
vapors were "cracked" to simpler gasses. Finally the gas was then sent through the
condenser/scrubber/purifier process and sent to the gas holder tank for storage.
Waste areas typically associated with MGPs include the general area surrounding the gas
holder tanks. Here waste products consisting of oils and PAHs would precipitate out of the
. gas suspension, collect in the bottom of the gas holder tanks, and infiltrate into adjacent
soils. The location of the gas holder tank, in addition to a series of smaller tanks can be
seen in the northwest portion of Figure 1-1. As evidenced at this site these gas holders
were usually partially buried within the soils.
MGP operations also generated a waste fluids stream containing an emulsion of oils,
PAHs, and water. This emulsion would be sent to a water/oil separator to recover the oils
and discharge the water to a drying pond or nearby water body. The separator worked by
slowing the flow of the mixture which in turn allowed the oils and PAHs to float to the top
where they were removed with a skimmer and recycled or sold depending upon the quality
and/or the local demands for such mixtures. The water portion of this waste stream was
discharged to local water bodies. Historically there were problems associated with
incomplete separation of the emulsion. In general carbureted water-gas plants were
universally known to have^chronic problems with the separation process2 and that the
waste water containing oils and PAHs were typically discharged into streams with some
of the oils depositing on the banks of the stream3.
A plant design drawing dated April 28, 1941 revealed that in the past plant waste water
was discharged to the Cooper River via a pipe at a location corresponding to the pre-1940
'Draft Final Remedial Investigation Report, Calhoun Park Area Site, Volume 1,
dated September 1996, page 1-5.
•U.S. Production of Manufactured Gases: Assessment of Past Disposal
Practices, EPA/600/2-58/012, dated February 1968, pages 136-139.
'L/.S. Production of Manufactured Gases: Assessment of Past Disposal
Practices, EPA/600/2-58/012, dated February 1968, pages 65-69.
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shoreline4. It is of significance to note that prior to 1940 the Cooper River shoreline was
located immediately east of Concord Street. The shoreline was later extended to the east
between 1941 and 1942 with the addition of fill material, an action which created the
present day property currently owned by the NPS. The routing of this discharge pipe would
have placed the point of release in the general area of what is now the northwest corner
of the NPS property.
2.3 Previous Investigations and Containment Measures
Prior to the Rl, several investigations had been preformed on the various portions of the
properties associated with this site. These individual investigations covered a variety of
separate topics including air quality in the crawl space and apartment interiors of
Ansonborough Homes, analysis of soil and groundwater samples collected from Calhoun
Park and Ansonborough Homes, organic and inorganic analysis of surface water and
sediment samples collected from the Cooper River.
During this time a Site Screening Investigation was completed by SC DHEC on June 2,
1992 on the site to gather the necessary information required to prepare the Hazard
Ranking System (HRS) package. Based upon the results of this investigation, the site
receivecha HRS score of 48.9 due primarily to the human food chain threat5. Listing the site
on the National Priorities List (NPL) has been suspended based on the present
cooperation by SCE&G in performing the required site activities.
On January 22, 1993, SCE&G entered into an AOC with EPA to perform a Remedial
Investigation6. To the extent possible data from previous investigations were used for
planning the comprehensive sampling approach seen in the Remedial Investigation. The
Rl was also designed to sample additionally properties such as Ludens, NPS property,
Campsen property, Dockside Condominiums, and the Deyton property which had not been
sampled to date.
SCE&G retained Fluor Daniel GTI of East Pittsburgh, PA to conduct the work required to
complete the RI/FS process. EPA and SC DHEC provided oversight of work conducted
during the RI/FS. A complete listing of the documents generated during the RI/FS process
can be found in the Index to the Administrative Record for this site. This ROD is intended
to summarize key information from the Administrative Record and provide the rationale for
the selected response action specified in Section 9.0. The reader is referred to the site
Administrative Record for a more detailed account of the information presented in this
Engineering Drawing, dated February 1, 1936. Revised April 28, 1941.
5PREscore 1.0 - HRS Documentation Record, Calhoun Park/Ansonborough
Homes/Coal Gas, 6/10/92.
Administrative Order on Consent, dated January 22, 1993.
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document.
Three additional investigations were also performed concurrent with the Rl and later came
to influence the Rl activities. These included the Killam Report, the PSI Report, and the
Aquarium Containment Plan. During the early stages of the Rl EPA had planned to
investigate the NPS property under a separate investigation. Meanwhile both the City of
Charleston and the NPS were performing separate investigations on this property
concurrent with the Rl. These reports were titled the South Carolina Aquarium Site
Investigation Results7 and the Site Inspection Charleston Harbor Site8 respectively. Data
from these two reports were later included into the Rl and also used in support of risk
assessment calculations.
the general area within the City of Charleston where the site is located has been, and
continues to be, subject to aggressive construction efforts. Regulatory concerns over the
planned construction of a City aquarium on a contaminated portion of the site owned by
the NPS led to the creation of a containment plan. Ultimately this containment plan was
implemented to minimize potential discharges of contaminants from the construction
activities associated with the aquarium. The containment system as implemented
consisted of a sand blanket to minimize resuspension of contaminated sediments, a timber
lagging wall to limit discharge of particulates to the subtidal area, and a silt curtain to
contain sand from the sand blanket which might be disturbed during construction.
Following the completion of the subtidal construction activities a demonstrations report was
generated which documented the effectiveness of the containment system.
During the Rl the City of Charleston began work to relocate an old storm drain which
traversed a portion of the site. Because a portion of the storm drain traversing the site was
constructed of brick with deteriorating mortar joints it was acting in part as a groundwater
collection system. Storm water from off site properties, and portions of the site
groundwater which infiltrated the deteriorating pipe, was discharged into the Cooper River.
In order to mitigate this effect, and to prevent the gravel bed required for the replacement
pipe from acting in a similar manner, sheet piling was installed between the contaminated
shallow aquifer and the location of the new pipe. A groundwater monitoring plan was also
established to monitor the effectiveness of the sheet piling in preventing the future
infiltration of contaminated groundwater in this area.
A second sediment containment system was later installed on another portion of the NPS
property in support of the construction of a tour boat dock. This second containment
system, located south of the aquarium containment system, was designed to address
contaminated sediments present at the point where the old storm drain discharged into the
Cooper River.
7South Carolina Aquarium Site Investigation Reports, Killam Associates, dated
December 1994.
"Site Inspection Charleston Harbor Site, PSI Inc., dated April 1994.
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The investigations and containment measures associated with both the aquarium
construction and the storm drain were addressed during the early stages of the Rl. During
the completion of the IR an oily sheen was observed on the surface of the Cooper River.
This sheen was traced to seeps along the banks of Cooper River at end of Charlotte
Street. The seeps were observed to be discharging a oily tar substance with the lighter
fractions floating to the surface of the Cooper River while the heaver portions were
observed flowing underwater towards the river channel. Two actions were initiated by
SCE&G. The first consisted of the installation of a floating boom to contain the oily sheen
floating on the surface. The second action consisted of investigating the source of the
material contributing to the seeps. These activities have since been documented in a
report titled Charlotte Street Investigation Report9. The mitigation of the source area
responsible for these seeps, the contaminated sediments resulting from the seeps, and
sediment contamination documented in the Rl will be addressed in a separate ROD for this
site. On May 13, 1998 SCE&G signed a removal AOC which addresses an interim action
on these seeps. This interim action is currently underway to mitigate the discharge from
these seeps.
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
In May 1995, EPA issued a fact sheet to local citizens and public officials announcing the
initiation of RI/FS activities at the site. Concurrent with the release of this fact sheet, the
Final RI/FS Work Plan documents were submitted for public review to the information
repositories located at EPA's office in Atlanta, GA and the Charleston County Main Library
in Charleston, SC. On May 1995, EPA held an Rl Kick-Off Public Meeting at the
Charleston Public Works Building in Charleston, SC to provide a description of the
Superfund process, the work to be performed, and to answer any questions regarding the
site.
In January 1998, EPA released a public fact sheet to provide the public with a summary
of the findings of the Rl and the human health Baseline Risk Assessment. A public
information session was held on January 20, 1998, to discuss the information presented
in this fact sheet and to answer site specific questions from the public. During March 1998,
EPA released the proposed plan public fact sheet which presented the proposed remedial
action and also recapped the Rl and Baseline Risk Assessment finding. The Final Rl
Report, Final Human Health Baseline Risk Assessment (BRA), and other site related
documents were assembled in an Administrative Record (AR) and submitted to the
information repositories for public review concurrent with the release of the fact sheet.
A notice to area citizens regarding the proposed plan public meeting, the location of the
local information repository, and the initiation of a 60-day public comment period was
published in Charleston's daily newspaper, The Post and Courier, on March 1998. Due
to public interest and explicit requests expressed during the previous public information
'Charlotte Street Investigation Report, dated December 1997.
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session, the public comment period was opened for 60 days from March 16, 1998, to May
15, 1998. The proposed plan public meeting was held on March 16, 1998, at the
Charleston Public Works Building and was attended by approximately 50 people. At the
request of local area residents an additional public information session was held on April
28, 1998, to discuss risk assessment issues and groundwater conditions.
Public comments were received during the 60 day comment period. Each specific
comment, in addition to EPA's specific response to these comments, is provided as an
attachment to this ROD titled as "Responsiveness Summary". A transcript of the March 16,
1998, public meeting and a copy of all comments received during the 60-day public
comment period have been provided as an attachment to this ROD.
4.0 ADDITIONAL EARLY RESPONSE ACTIONS
Previous early response actions, in the form of sediment containment measures, have
been taken at this site and are described in section 2.3. Additional actions are also
planned for contaminated soils and seeps at Charlotte Street and are currently being
addressed under a Removal AOC. The rationale for this additional early response is two
fold. The City of Charleston will soon begin construction of the parking garage which when
built would cover a large portion of contaminated soils associated with this -site. In order
to remove the soils while still accessible, and to minimize exposure risk to the on-site
construction workers, the contaminated soils will be removed prior to beginning the garage
construction. Additionally the seeps located along the end of Charlotte Street have been
discharging coal tar waste into Cooper River since November 1997. As such, a response
action was deemed necessary.
According to the Removal AOC, which became effective May 22,1998, the work to be
performed will be as follows:
• Delineation, excavation, and disposal of contaminated soils as presented in the
Calhoun Park Feasibility Study dated November 1997, to a depth of 3 feet below
land surface and having an estimated volume of approximately 6,080 cubic yards;
• Further investigation and prevention or mitigation of the discharge of coal tar into
the Cooper River from seeps along Charlotte Street.
5.0 SUMMARY OF SITE CHARACTERISTICS
This section provides a brief and concise overview of the site characteristics as assessed
during the site Rl. The majority of the field activities performed by SCE&G as presented
in the R I were performed between November 1993 and January 1994. As previously
mentioned there were two additional investigations performed concurrent with the Rl and
the information eventually assimilated into the Rl report. These investigations consisted
of the Killam Report and the PSI Report. Collectively these field investigations generated
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a voluminous data base. The results of these field programs and appropriate conclusions
have been presented in the following technical reports that are incorporated into the site
Administrative Record:
• Draft Final, Remedial Investigation Report, Calhoun Park Area Site, Volumes I &
2, Fluor Daniel GTI (September 1996)
Feasibility Study, Calhoun Park Area Site, Fluor Daniel GTI (November 1997)
• South Carolina Aquarium Site Investigation, Killam Assoc.(December 1994)
• Site Inspection Charleston Harbor Site, PSI Inc. (April 1994)
In the interest of brevity, the information presented in the above reports is not re-iterated
in this decision document. Rather, the conclusions of the Rl are presented in a more
qualitative summary format to provide the reader with an overview. Specific human health
risks posed by the site constituents are summarized in Section 6.1. Cleanup goals for all
media addressed by this response action are delineated in Section 7.1. The reader should
refer to the site Administrative Record for a more detailed account of this subject matter.
5.1 Physical Characteristics
This section provides a summary of information regarding the physical characteristics of
the site including demography, meteorology, topography, surface water hydrology, and
geology/hydrogeology.
5.1.1 Demography
The site is located in the downtown area of Charleston, South Carolina. Current land use
for the site, and adjacent properties consists of a mixture of commercial and light industrial
operations interspersed with pockets of residential areas. According to a document titled
Calhoun Street Corridor, prepared in 1989 by the City of Charleston planning commission,
plans are underway to construct a parking garage on the current Calhoun Park property.
Additional commercial development is planned for portions of the NPS property, the
Campsen property, and portions of the property previously occupied by the Ansonborough
Homes.
5.1.2 Meteorology
The climate in Charleston, SC is temperate and modified considerably by the proximity to
the Atlantic Ocean. The marine influence is noticeable during winter when the low
temperatures are sometimes 10-15°F higher on the peninsula than areas ten miles inland.
Likewise, summer high temperatures are generally a few degrees lower than inland areas.
The average daily maximum temperature ranges from 90.2 °F in July to 57.8 °F in
January. The average daily minimum temperature ranges from 72.7 °F in July to 37.7 °F
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in January. Prevailing winds are northerly in the fall and winter, and southerly in the
spring and summer. The average precipitation ranges from 8 inches or more in July to 3
inches or less in November. Late summer and early fall is the period of maximum threat
to the South Carolina coast from hurricanes.
5.1.4 Surface Water Hydrology
Much of Charleston County is tidal estuary, including the area in which the site is located.
The Charleston Harbor and the Cooper River are tidally influenced and have a semidiurnal
tide which averages 5.2 feet. The Cooper River borders the site to the east. The site lies
above normal high tide levels with the exception of localized tidal flooding of the storm
drain grates in the Ansonborough Homes area to the south and portions of Charlotte Street
to the north. The 50-year storm surge level for Charleston County is 11 feet above Mean
Sea Level (MSL). A storm surge to this elevation would cause complete flooding of the
site.
Surface water drainage at this site occurs as either overland flow or through a series of
storm water collection piping. While the old underground brick archway mentioned in
section 2.3 no longer exists, it did transect a portion of the site for a number of years and
influenced both surface water and groundwater hydrology. The old brick archway ran due
east along Calhoun Street collecting the majority of storm water from the site. This water
was eventually discharged into the Cooper River. Historically the old brick archway
terminated immediately east of the intersection of Calhoun Street and Concord Street as
the fill material comprising the NPS was not in place until 1941. Following the addition of
the fill the brick archway was then extended so that it could continue to discharge water
into the Cooper River.
5.1.5 Geology/Hydrogeology
The site is located in the discharge portion of the Atlantic Coastal Plain physiographic
province. The Cooper Marl clay formation, a regional confining unit approximately 260 feet
thick, is encountered at depths on-site ranging from 68 to 85 feet below land surface
(BLS). The Rl was limited to characterizing the shallow aquifer above the Cooper Marl
confining unit.
Three water-bearing units (shallow, intermediate, and deep sands) and two lower
permeability units (shallow and intermediate clays) were identified in the shallow aquifer
above the Cooper Marl. A representative stratigraphic model of the site is presented
graphically in Figure 5-1. From the land surface to the top of the Cooper Group, the
stratigraphic units beneath the site are 1 )artificial fill; 2)upper clay; 3)intermediate sands;
4)intermediate clay; 5)lower sands; and 6)the Cooper Group. The presence-and thickness
of these layers vary across the site.
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As seen in the stratigraphic cross-sections, the site is covered with a layer of fill which
contains sand, silt, shells, gravel, including wood scraps and building rubble. The fill varies
in thickness between 4 to 15 feet bis and has an average hydraulic conductivity of 6.1 x
10'3 cm/sec. . The water table stands within this unit at approximately 2 to 4 feet bis. The
"A"-level wells and piezometers are located within this unit. The fill unit is underlain by an
upper clay unit which begins between 5 to 20 feet bis and extends to between 30 to 40 feet
bis. In general the upper clay unit serves as a unit of lower permeability with an average
hydraulic conductivity of 3.4 x 10'7 cm/sec, however, the presence of course grain particles
and hydraulic data suggest that appreciable leakage may occur though this upper clay in
some areas. As an additional note the upper clay layer within the general vicinity of the
electrical substation was likely breached during the installation and/or removal of the gas
holder.
Beneath this uppermost clay layer exists an intermediate sand/silt layer which is
encountered between 30 to 40 feet and extends to 50 to 65 feet bis. This unit is a water
bearing zone with an average hydraulic conductivity of 5.6 x 10"3 cm/sec. The intermediate
sand/silt layer is underlain by an intermediate clay layer which is encountered between 50
to 65 feet extending to 60 to 75 feet bis. This clay layer serves as a unit of lower
permeability where present, however, it is not present as a distinct clay zone across the
entire site. Where present the average hydraulic conductivity is 2.1 x 10"8 cm/sec.
A lower sand/silt unit is found beneath the intermediate clay layer, encountered between
55 to 75 feet bis and extending to 60 to 85 feet bis before encountering the Ashley
Formation. The average hydraulic conductivity of the lower sand/silt unit is 5.6 x 10'3
cm/sec. The Ashley Formation is located beneath the lower sand/silt unit and is located
between 68 to 85 feet bis. This formation consists of a dense calcareous sand and has an
average hydraulic conductivity of 1.7 x 10'7 cm/sec. The intermediate sand and lower sand
unit may possibly be used locally within Charleston County as a water supply, but no
known shallow groundwater wells are in use within a four mile radius of the site. Drinking
water to this area is supplied by the City of Charleston.
5.2 Nature and Extent of Impact
The media investigated as part of the Rl included soils, groundwater, and surface
water/sediments. The sampling locations are presented in Figures 2-2, 2-3, & 2-4. The
following sections briefly discuss each media sampled and the corresponding
contamination present at the sampling locations.
-------
CONCORD
STREET
i-eio
JTyrS GRAVEL
SAND AND
CINDER
FILL
CINDER. COKE
GRAVEL SLAG
CLAYEY SANO
AND WOOD
CLAY (SOFT)
CLAY (DENSE)
CLAYEY SAND
INTERMEDIATE
SAND
CLAYEY SILT
CLAYEY. SILT
TO SILTY CLAY
INTERMEDIATE
CLAY
SHELLS AND SAND
SILTY CLAY
SANDY aAY
SILT WITH THIN
SAND LAYERS
CLAY WITH THIN
SAND LAYERS
ASHLEY FORMATION (COOPER GROUP)
DENSE SANDY TO CLAYEY SILT
200
500
700
800
1000
BORING
VIEW BASELINE'- FEET
LEGEND
V
BOTTOM OF
SAMPLED INTERVAL
GRADATIONAL
CONTACT
INFERRED
CONTACT
[7.3x101 - K VALUE MEASURED
1 ' BY SOIL PHYSICAL
TESTING (FT/MIN)
- K VALUE MEASURED
BY SLUG TESTING
(FT/MIN)
NOTE:
SEE FIGURE 2-7 FOR LOCATION
OF CROSS-SECTION LINES. KEY TO
LITHOLOGY SYMBOLS MAY BE FOUND
IN APPENDIX A.
GROUNDMTER
TECHNOLOGY.
CO
c
(3
Ul
CO
Q>
o
T»
2
o'
O
3
(/>
CO
CO
(D
O.
73
n
"S 3.
I 2,
•08*0
L> -i ft
3 . f*
* vO 5'
*o o
OO 3
-------
C 00
o o\
'5 Ov
'§ u
Q.8
U-, C
o 5
•S &
o u
8 c^
V
c£
C
o
8
O)
C
"5.
E-
ra
CO
ra
T3
c
o
6
(N
0)
3
O)
-------
Record of Decision
September 1998
Page 18
Figure 5-3 (Sediment/Surface Water Sampling Locations)
18/SW-18/18MS-MSD
D-2J/SW-21
Lights,?
SD-15/SW-15/
SD-12/SW-12
SD-13/SW-13
SD-tO/SW-10
(-H/SW-U /
•SD-16/SW-J6
/
Habitat Area' SI
Habitat Area #3
I
rSD-20/SW-20
.
-SD-19/SVM9
'
Piles
__, Bay
'layground
\O
i
is
-------
Record of Decision
September 1998
Page19
5.2.1 Surface/Subsurface Soils
Impact of the site to surface soils (defined as 0 to six inches BLS) and subsurface soils
(soils 6 inches or greater BLS) were characterized by the collection of soil borings.
Generally, this effort included the collection of samples from areas likely impacted by past
operations. These potential source areas of interest included the gas holder area, the
relief holder area, and the rosin wood treating operation (Fernoline Chemical). Samples
were also collected throughout other areas of the site. The sampling locations are
illustrated in Figure 5-2.
The majority of contaminants impacting the soils at this site consist primarily of volatile and
semi-volatile organic'compounds. The majority of the semi-volatile organic compounds
consist of PAHs, primarily Acenaphthene, Acenaphthylene, Anthracene,
Benzo(G,H,l)perylene, Fluoranthene, Fluorene, Naphthalene, Phenanthrene, Pyrene,
Benzo(A)anthracene, Benzo(A)pyrene, Benzo(B)fluoranthene, Benzo(K)fluoranthene,
Chrysene, Dibenz(A,H)anthracene, and lndeno(1,2,3-CD)pyrene. The group of volatile
organic compounds present are primarily the BTEX .group (benzene, toluene,
ethylbenzene, and xylene).
The areas most impacted by contaminants include the gas holder, the relief holder, and
soils surrounding the waste disposal pipe. Another concentrated area of contamination
was identified at the northwest corner of Ludens property. Contaminant concentration
ranges are presented in Table 5-1. Both the PAH and BTEX groups are commonly
associated with contamination present at manufactured gas plants.
5.2.2 Groundwater
Shallow Sand Aquifer
Evaluation of the extent of groundwater contamination was focused primarily on the fill
aquifer as evidenced by the 32 shallow "A" wells installed across the site. The primary
contaminants present in the fill aquifer consist of the BTEX group, the PAH group, and
several inorganic compounds. Organic contaminants in the fill aquifer exceeding the MCLs
include Benzene, 2,4-Dimethylphenol, Benzo(a)pyrene, Benzo(A)anthracene,
Benzo(B)fluoranthene, Benzo(K)fluoranthene, Chrysene, lndeno(1,2,3-CD)pyrene, Ethyl
benzene, Carbazole, Chrysene, Naphthalene, and Toluene. Inorganic contaminants
exceeding the MCLs include Arsenic Cyanide, Beryllium, Lead, Mercury, Chromium,
Nickel, and Copper. Isoconcentration maps for selected groundwater contaminant plumes
are presented in Figures 5-4, 5-5, & 5-6. These maps provide a general indicator as to the
extent of groundwater contamination associated with this site which exceed MCLs. As
evidenced from these maps, portions of the contaminated groundwater plume are
discharging into the Cooper River. Contaminant concentration ranges are presented in
Table 5-2.
-------
Record of Decision
September 1998
Page20
Table 5-1
Chemicals Detected in greater
than 5% of Soil Samples
Chemical
vni x-nt = CRGANICS
Acs'.or.c
Carbon DisulHdc
2-Butanonc
Benzene
Toluene
Ethylbenzcnc
Xytenes
nASF NF.UTRALORGANICS
Dibenzofuran
Di-n-hutyiphihalaic
Carb azoic
Dis(2-cihythexyi)phthalaic
CAlis
2-.Methyt naphthalene
Acenaphthcne
Accnaphihylcnc
Anthracene
Benzo(£ji,i)perylene
Fluorenthcnc
Fluorcnc
• Naphthalene
Phenanthrenc
Pyrcne
Bcnzo(a)anihncenc
Benzo(a)pyrcne
Ben7jo(b)(luoranihene
Benzo(|;)nuoranihene
Chrysenc
Dibenz(aji)anthracene
lndeno(1.13-cd)pyrcnc
INORGANICS
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Cyanide
Lead
Manganese
* Mcrcurv .
] . Nidcel'
| Selenium
j Thallium
j Vanadium
j Zinc
Frequency
of Detection
0;
21-53
5,53
11'53
13/53
10/53
13/53
9/53
20/53
3/53
15/53
8/53
29/53
S9/53
31'53
^1*53
39/53
51/53
25/53
34/53
48/53
48/53
49/53
48/53
47/53
44/53
49/53
29/53
45/53
7/53
47/53
35/53
5/53
ft/53
53/53
50/53
31/53
53/53
53/53
29/53
20/53
14,53
3V53
37/53
52/53
Rnnje of
Detection •
(m-'ka)
0.02 - 2
0.003-0.04
0.008-0.15
0.02-43
0.004 - 100
0.017- no
0.013 - 150
0.04-9
0.05-2
0.023 - 3
0.035 - 6
O.W1-9
0.053 - 26
6.029 - 69
0.024 - 37
0.034 - 17
0.030-52
0.053-59
0.051 - 160
0.046 - 140
0.042 - 69
0.037 - 38
0.049 - 28
0.034 - 30
0.020 - 16
0.050 - 35
0.021 - 6
0.025 - 17
3.1-36
3-3-250
47.6 • 1060
1.2-3.4
1.6-9.7
3-3 - 150
3.7-496
0.67-601
10.2 - 3530
14.1 - 1390
0.12- 14
9.6 - 1 13
1.7-153
1.2-9.2
112-75
15-2 - 1600
Avtrnje
Concentration (2)
(mj/ks)
0.4S
0.02
0.05
45
15
23
24
13
0.60
0.05
0.99
75
33
4.4
3.0
13
6.3
6.4
13.6
10
8.2 '
4.2
3.7
43
12
V
1'°
i?
15
24
204
10
3.4
18
94
45
397
154
1.4
26
4.8
55
23
270
Mc:in Rackground
Concentration (?)
(m;rtt«)
"*
0.16
0.03
ND
ND
ND
ND
ND
ND
ND
0.09
0.08
ND
ND
ND
0.05
031
0.97
ND
ND
030
058
033
033
0.78
0.41
037
0.11
034
ND
13
238
ND
ND
21
58
ND
824
94
13
ND
ND
ND
37.
506
Region III
Screcnin* Valuei (3)
-------
Record of Decision
September 1998
Page21
Table 5-2
Chemicals Detected in greater
than 5% of Groundwater Samples
VOI ATILE PRO ANICS
Acetone
Benzene
Toluene
Eihylbenzene
Xylcnes
BASE-NEUTRALQRGAN1CS
Phenol
2-Methylphenol
4-Methylphenol
2,4-Dimethylphenol
Dibenzoturan
Carbazole
B is(2-Et hylhcxyl)phl ha late
PAHs
2-Methylnaphthalene
Acenaphthcne
Acenaphthylene
Anthracene
Benzo(g,h,i)perylene
Fluoranihene
Fluorene
Naphthalene
Phenanthrene
Pyrenc
Qcnzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Cnryscnc
rndeno(1.2,3-cd)pyrene
INORGANICS
Arsenic
Barium
Beryllium
Chromium
Copper
Cyanide
Lead
Manganese
Mercury
Nickel
Vanadium
Zinc
Fnqatncj'
0)
6/32
14/32
i2m
14/32
13/32
3/32
3/32
2/32
2/32
16/32
13/32
3/32
17/32
21/32
11/32
19/32
7/32
21/32
20/32
21/32
23/32
21/32
13/32
8/32
13/32
11/32
7/32
21/32
21/32
2/32
21/32
10/32
14/32
17/32
32/32
27/32
7/32
8/32
25/32
Ruigt «f
Dtftedon
6-17
6-5200
2-1800
2-1200
4-1800
8-150
1-400
240 - 620
180. -890
3-140
0.8 • 150
1-22
I -1100
1-370
0.6 - 140
0.5 - 210
0.8-10
1-410
0.6-290
0.7 • 5500
0.8 - 970
1-480
0.8 - 180
1-38
1-130
2-160
0.9-12
4-88
203-1470
6-13
28-130
8-5080
11-4480
3-1920
178-3050
0.2-15
41 - 304
56-174
26-2610
Cone*nir»dMt (I)
("0")
11
571
214
200
280
58
197
430
535
40
49
8.0
157
66
23-
34
Z7
52
48
782
108
51
29
9.1
23
31
/ 3.1
23
487
9.3
35
567
832
322
959
3.5
110
91
678
M«if> B»cVjr»unJ
CmcrandMi (J)
(•CD
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ZO
ND
ND
ND
ND
ND
ND
25
47
ND
ND
7.3
ND
52
366
0.5
ND
10
81
RtflMI III
Semiring V.ltui (J)
(•Cfl)
370
0.36
75
130
1200
2200
180
18
73
NA
3.4
4.8
NA
220
•NA
1100
NA
150
150
150
NA
110
0.092
0.0092
0.092
9.2
0.092
0.04
260
0.016
18
140
73
NA
18
1
73
26
1100
MCL
Vilwi (4)
(•*»
NA
5
1000
700
10000
NA
NA
NA
NA
NA •
NA
NA
NA
NA
NA
NA
NA
NA
NA
• NA
NA
NA.
NA
0.2
NA
NA
NA
50
2000
4.0
100
1300*
200
15
50"
ZO.
100
NA
5000V
NA - N« Available
ND - Not Detected
• - Maximum Contaminant Level Coal
fl) Sampling date was January 1994.
m Average of detects only used when calculating average and background concentrations.
(3) These values were obtained from EPA Region HI Risk based concentrations technical guidance for selecting chemicals o( potential concern
I represent ta
(4) Maximum Contaminant Level (MCL)
-------
Record of Decision
September 1998
Page22
Figure 5-4
Benzene Isoconcentration Map
Shallow Groundwater Aquifer
-------
Record of Decision
September 1998
Page23
Figure 5-5
Total PAH Isoconcentration Map
Shallow Groundwater Aquifer
-------
Record of Decision
September 1998
Page24
Figure 5-6
Naphthalene Isoconcentration Map
Shallow Groundwater Aquifer
-------
Record of Decision
September 1998
Page25
Intermediate and Deep Sand Aquifers
Groundwater samples were collected from eleven intermediate and deep wells, designated
"B" and "D" respectively. The locations of these wells can be seen on the soil sampling
map designated as Figure 5-2. Constituents present in these wells include both BTEXs
and PAHs, some of which were present in concentrations in excess of MCLs. No plume
maps were presented for either of these aquifers due to the relatively small number of data
points taken. Because the extent of contamination within these aquifers were not well
defined during the Remedial Investigation, additional evaluation will be performed as part
of the remedial design to determine if additional cleanup actions are warranted.
Analytical results from all monitoring wells were compared to Maximum Contaminant
Levels (MCLs) which have been established to be protective of human health based on
the use of site groundwater as a drinking water source. This comparison is conservative
given that the water-bearing units do not have sufficient capacity and that the groundwater
near the Cooper River is either saline or brackish. MCL exceedances were noted in either
the shallow and/or intermediate water-bearing units for the following constituents: Arsenic,
Cyanide, Benzene, 2,4-Dimethylphenol, Benzo(a)pyrene, Ethylbenzene, Beryllium, Lead,
Mercury, Chrysene, Naphthalene, Chromium, Nickel, and Copper. Contaminant
concentration ranges are presented in Table 5-3.
An artesTan well, designated as sample MG-01M, was also sampled as part of this
investigation. Low levels of PAHs were detected within this well but were below their
corresponding MCLs. Dioxin sampling was also performed on the following three wells:
BM-01A (background), AM-04A (Ansonborough Homes), and CPMW-3 (Calhoun Park).
While eight of the PCDD/PCDF congeners were detected in the two on-site wells,
examination of the 2,3,7,8-TCDD Toxicity Equivalent Concentrations revealed that the
concentrations present (<2 pg/l) were below the MCL of 30 pg/l.
5.2.3 NAPLs
The following discussion is limited to the NAPL investigation as presented in the RI/FS.
Shortly following the completion of the RI/FS, coal tar was observed discharging from
seeps near the north east portion of the site (see section 2.3 Containment Measures).
Subsequent investigative work has revealed the presence of additional NAPL source
areas, other than the ones discussed in the RI/FS, which are attributable to the MGP
operations. As of the writing of this ROD additional investigative work is currently
underway to determine the extent of these source areas and evaluate appropriate remedial
actions.
NAPLs comprise a broad class of compounds which are immiscible fluids with densities
greater than water (DNAPLs), including PAHs, or lighter than water (LNAPLs).
-------
Record of Decision
September 1998
Page26
Table 5-2
Contaminant Concentration Ranges
Intermediate Groundwater Samples
Calhoun Park Area Site
Risk Assessment
Chemical
VQLATILECRQAhllCS
Met ltylene Chloride
Acetone
Ctiloroform
llenzene
Toluene
Ethylbenzene
Xytenes
UASP, NmiTRALOROANICS
Phenol
2-Mefhylphenol
4-Methylphenol
2,4-DImethylphenol
Dlmethylphthalaie
Dlbenzofuran
DIelhylphthaUte
Carbazole
2>Methytnaphihalene
Aeenaphthene
Acenaphthylenc
Anthracene
,' Fluoranthene
1 1 Fluorene
^Naphthalene
Phenahlhrene
Pyrerte
Denzo(*)a nthneene
Oenzo(a)pyrcne
Denzo(b)fluoranthene
Chrysene •
INORGANICS
Chrofli Itfm
Cyanide
Manganese
Nickel
Frequency
of Detection
0)
l/ll
l/ll
1/11
.5/11
2/11
3/11
4/11
5/11
1/11
1/11
l/ll
1/11
2/11
1/11
2/11
2/11
3/11
2/11
2/11
2/11
2/11
6/11
3/11
2/11
1/11
1/11
1/11
l/ll
8/11
7/11
7/11
2/11
Range of
Detection
(ut/l)
•
17
11000
37
3-15000
160-490
250-3600
6-2500
0.9-91
12
37
130
17
2-28
34
3-81
210-370
0.9 - 42
26-62
3-9
2-12
16-54
3 - 3400
0.8 - 44
2-9
2
1
1
2
13-68
11 - 173
32-334
43-61
Average
Concentration (2)
17
11000
37
4981
325
1540
804
45
12
37
130
17-
JJ/5-
34 — -..
42
290
16
44
6.0
7.0
35
699
• 21
5.5
ZO
1.0
1-0 .
ZO
30
84
143
52
Mcin Dickground'
Concentration (2)
(ut/l>
ND
ND
ND
ND
ND
ND
ND
ND
ND • '
ND
ND
ND
ND
. ND
ND-
ND
ND
ND
ND
ND
ND
ND
2.0
ND
ND
ND
ND
ND
ND
ND
' 366
ND
Region HI.
Screening Valua (3)
4.1
370
0.15.
0.36
"75
130
1200
2200
180
18
73
37000
NA
2900
3.4
NA
220
NA
1100
150
150
150
NA
110
0.092
0.0092
0.092
9.2 .
18
73 '•
18
73
MCL
Values (4)
5
NA
NA
5
1000
700
10000
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
0.20
NA .
NA
100
200
50«
100
NA-Not'Available'
NO. Not Deeded
(I) Sampling date ww January 1994.
(2) Avenge of detects only used when calculating average and background concentrations.
(3) llheie values were obtained from EPA Region III Risk based concentrations technical guidance for selecting chemicals of potential concern.
All Values are based on a carcinogenic risk of 10-06 and noncarcinogenic hazard Index of 0.1. EPA Region III screening values arc based on a haznri
of 1.0 for noncarclnogcnlc compounds. However, In accordance with Region IV guidance, the concentrations of noncarclnoECnte compounds I
shown In the Region III tables have been adjusted by a factor of 0.1 to reflect a concentration that would produce a hazard quotient of 0.1.
The values listed represent lanwaicr criteria.
(4) Maximum Contaminant Level (MCL)
-------
Record of Decision
September 1998
Page27
Therefore, EPA adhered to the groundwater/NAPL site characterization strategy presented
in EPA OSWER Directive 9234.2-25, Guidance for Evaluating the Technical
Impracticability of Groundwater Restoration (EPA 1993). This guidance document
advocates a strategy which delineates three areas: 1) the NAPL entry location; 2) the
NAPL zone or source area; and 3) the aqueous contaminant plume. The entry locations
are those areas where NAPL may have entered the environment and, therefore, is likely
present in the subsurface. The NAPL zone or source area is defined by that portion of the
subsurface containing free-phase or residual NAPL. The aqueous contaminant plume
contains dissolved phase constituents down gradient from source areas. The Rl field
program focused on likely entry zones by utilizing information gathered on historical
operating procedures for the MGP. NAPL source areas and dissolved phase constituent
plumes were delineated through the installation of monitoring wells.
The general locations where measurable thicknesses of DNAPLs were observed during
the Rl include wells CPMW-3, MM-01A, MM-02B, and MZ-06A. Wells MM-01A and MM-
02B contained NAPLs layer greater than 0.5 feet. Additionally wells CM-05A, MZ-05A, and
MW-12, were observed as having visual traces of NAPLs. Consequently the occurrence
of NAPL as reported in the Rl can be grouped around the MGP; more specifically the
former gas holder, the former rail spur, and the former oil tanks. These areas constitute
both the NAPL entry location and the NAPL zone or source area. While NAPL was present
primarily~within the shallow aquifer, it was also observed in well MM-02B which is located
within the intermediate sand aquifer in the area adjacent to the gas holder.
5.2.4 Sediments
The following information is provided as an overview of the general sediment conditions
at the close of the RI/FS. With the recent release of coal tar via seeps into the Cooper
River, a new source of sediment contamination has occurred. Interim measures are
presently underway to stop this discharge. The extent of contamination associated with this
release is under investigation and will ultimately impact any future plans for remediating
the sediments. A second ROD will be issued to address the sediments once the sediment
investigation is complete.
The nature and extent of impact to the benthic community within the Cooper River was
determined by the analysis of seven sediment samples. Additional samples were also
collected at the Calhoun Street drain discharge point or outfall, the Calhoun Street
manhole, the Hassel Street outfall, and the Columbus Street outfall. The sediment
sampling locations are identified in Figure 5-3.
The analytical results were then compared to the relevant ecological screening criteria;
NOAA's Effects Range-Low (ERL). Effects Range-Median (ERM) and EPA's Sediment
Quality Criteria (for addressing equilibrium partitioning). In summary the data indicates that
the primary constituents present in site sediments which exceeds ERLs, ERMs, and EPA's
Sediment Quality Criteria would be the PAHs. Inorganic constituents including lead,
-------
Record of Decision
September 1998
Page28
arsenic, cadmium, and mercury were present in sediment samples in excess of ERLs. With
the exception of arsenic which appears in the soils in concentrated areas surrounding the
MGP, the remaining inorganic constituents do not appear to be associated with the MGP
operations.
Sediment samples which exceeded the screening levels are clustered around two primary
areas: the Calhoun Street drain outfall (SD-10) and the area adjacent to the NFS property.
The concentration of contaminated sediments adjacent to the NPS property can be readily
associated with the previous MGP operation of a discharge pipe as discussed previously
in section 2.1 Previous Site Operations.
The contaminated sediments located at the Calhoun Street drain outfall suggest that the
drain has acted as a conduit carrying contaminated water and/or sediment into the Cooper
River. A comparison of sediment concentrations from stations upgradient (sample SD-11
at corner of Elizabeth St. and Calhoun St.) and downgradient (sample SD-10 at drainage
outfall in Cooper River) of the site suggest that the source of contamination entered the
drain somewhere between these two sampling points. While the contamination is
consistent with the type of contamination associated with MGP operations (i.e. PAHs) an
evaluation of the data did not reveal any particular source or sources responsible for this
contamination because the construction of the drain pipe was such that it received water
not only from the street storm grates but also from adjacent groundwater which infiltrated
the pipe due to decaying mortar joints.
Ecological Assessment
An ecological assessment was performed on a portion of the Cooper River adjacent to the
site. This assessment consisted of an investigation on benthic macroinvertebrates to
evaluate their individual abundance as well as their number and types against a
background location. A summation of the findings at the close of the RI/FS indicated that
there were no significant differences between the on site stations versus the off site
stations. This conclusion was based on conditions at the close of the RI/FS and prior to
the recent release of coal tar via seeps into the Cooper River. This recent release
represents an additional contaminant source potentially threatening ecological receptors.
The effect of this source area will be evaluated during the sediment investigation and
discussed under the same ROD as the sediments.
5.2.5 Surface Water
The following information is provided as an overview of the general surface water
conditions at the close of the RI/FS. With the recent release of coal tar via seeps into the
Cooper River, a new source of surface water contamination has occurred and additional
investigative work is underway. Following completion of this ongoing investigation a
second ROD will be issued to address surface water/sediment contamination on human
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health and the environment.
Surface water samples were collected from flood water surrounding Ansonborough Homes,
Cooper River surface waters, and three storm water outfalls. BTEX, SVOCs, and PAHs
were detected at the point where the Calhoun Street drain outfall enters the Cooper River
(SW-10). Additionally dioxins were detected in surface water samples collected from the
Cooper River and the Calhoun Street drain. These results were compared to U.S. EPA
acute and chronic Ambient Water Quality Criteria (AWQC). While surface water
contamination was present in surface waters surrounding the site, the concentrations of
these contaminants did not exceed the AWQC standards. These same contaminants were
also present in low levels throughout the study area, including some of the background
locations. While there was no significant threat from surface water contamination to
humans from this site at the close of Rl, the recent release of contamination via seeps will
require additional investigation as mentioned in the preceding paragraph.
6.0 SUMMARY OF SITE RISKS
The human health baseline risk assessment process provides the basis for taking action
and identifies contaminants and the exposure pathways that need to be addressed by the
remedial action. It estimates what risks the site poses if no action were taken. This
section of the ROD summarizes the results of the human health baseline risk assessment
for this site. Environmental risks are presently unresolved due to the on-going discharge
of coal tar from seeps as discussed in section 4. The environmental risks resulting from
these seeps, in addition to the overall environmental risk associated with this Site, will be
evaluated under operable unit two and addressed in a second ROD for this site.
The evaluation of human health risk associated with this site is discussed within three
documents present in the Administrative Record: the Baseline Risk Assessment by Black
& Veatch, the Revision to Risk Assessment written by EPA, and the Assessment of Risk
for NPS which was also written by EPA. Typically the site risk is presented under one
document and titled as the Baseline Risk Assessment. A discussion as to why these three
documents are pertinent in assessing site risk is offered in the following paragraphs.
Initially the baseline risk assessment document was submitted to EPA in a draft format on
August 1994 with a revision submitted on October 1994 which was accepted as a final
version. EPA then discovered several errors which remained in this document. To address
these errors EPA generated the Revision to Risk Assessment dated July 1996. Meanwhile
the Killam Report and the PS I Report were generated. Following a review of these two
data sets, EPA initially decided to evaluate the data separate from the Rl data, and present
the results in the document titled "Assessment of Risk at the National Park Service
Property, December 11. 1995." This decision was based on two considerations: the highly
skewed sample locations, and that these soils would be removed during the aquarium
construction. The same exposed populations were examined, i.e., current trespassers,
future construction workers, and future residents, for contaminated soils. In general the
contaminant levels, specifically inorganics, PAHs and PCBs were found in higher
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concentrations in the ESI/Killam reports than in the Rl.
During the Feasibility Study EPA expanded this risk assessment strategy and required that
all future calculations for Preliminary Remediation Goals (PRGs) evaluate information
within all three data sets. As a result the Administrative Record actually contains three sets
of PRGs: those in the revised BRA, the Assessment of Risk at the National Park Service
Property, and those found in the FS. The PRGs present in the FS are the most
representative of the general site conditions and are therefore maintained throughout this
ROD. The following discussion provides a generic outline for the processes used in all
three documents.
6.1 Human Health Baseline Risk Assessment
The human health risk assessment process consists of the following major components:
exposure assessment, toxicity assessment, and risk characterization. The exposure
assessment involves the identification of potentially exposed populations and pathways,
calculation of media-specific exposure point concentrations from data generated during
the Rl, and development of assumptions regarding exposure frequency and duration. The
toxicity assessment utilizes existing chemical-specific toxicity information to determine the
types of adverse health effects associated with chemical exposures, and the relationship
between magnitude of exposure and adverse effects. Carcinogenic risks are evaluated
by factoring the intake of a chemical with the slope factor for that contaminant. Non-
carcinogenic risks are evaluated by comparing the intake of a chemical to the
corresponding reference dose of that compound. Risk characterization combines the
exposure and toxicity assessments to quantitatively and qualitatively evaluate the potential
risks posed. The risk assessment process concludes by the calculation of media-specific
cleanup levels that are adequately protective of human health. Cleanup levels are
discussed further in Section 7.1 below.
EPAemployed a reasonable maximum exposure (RME) approach to estimate the potential
exposures and associated risks at the site. The RME is the highest exposure that is
reasonably expected to occur at the site and is intended to estimate a conservative
exposure case that is still within the range of possible exposures. The exposure pathways
evaluated in this assessment included incidental ingestion and dermal contact with
surface/subsurface soils, sediments, and groundwater ingestion and inhalation.
EPA evaluated the chemicals detected on-site according to their potential to produce
either cancer and/or non-cancer health effects. The carcinogenic risk range EPA has set
for Superfund cleanups to be protective of human health is 1 x 10"4 to 1 x 10"6. For
example, a cancer risk of 1 x 10'6 indicates that an individual has a 1 in 1,000,000 (or 1 in
10,000 for 1 x 10"4) incremental chance of developing cancer as a result of site-related
exposure to a carcinogen over a 70 year lifetime under the specific exposure conditions
at the site. EPA generally uses the cumulative benchmark risk level of 1 x 10"4 for all
exposures relating to a particular medium to trigger action for that medium. In other words,
a carcinogenic risk greater than 1 x lO^for soil would indicate that remedial action for soil
is necessary. However, EPA may decide that a risk level less than 10'6(i.e., a risk between
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10"" and 10"6) is unacceptable due to site-specific conditions and that remedial action is
warranted.
Non-cancer exposure estimates were developed using EPA reference doses to calculate
a Hazard Index (HI). A HI greater that 1 indicates that constituents are present at
concentrations that may produce harmful effects. The resultant carcinogenic and non-
carcinogenic risks for the future on-site construction worker, future on-site worker and
future on-site resident are provided in Table 6-1.
The principle threat to human health and the environment at this Site is from exposure to
contaminated soils and groundwater. This is illustrated by the conceptual site model which
traces NAPLs migrating from MGP source areas through unsaturated soils and downward
to the groundwater. The migration of NAPLs would continue through the saturated zone
until encountering zones of lower permeability. This would result in exposure pathways
consisting of contaminated soils in the unsaturated and saturated zones, a dissolved
phase groundwater plume, and NAPL source areas.
Potentially exposed populations to these pathways could include both commercial workers
and residential populations. Commercial workers are most likely to be exposed to
contaminated surface and subsurface soils whereas future residential populations would
likely be exposed to contaminated surface soils and groundwater. It should be noted that
while both commercial and residential scenarios were evaluated the most likely use of the
property is commercial.
The evaluation of the commercial workers and future residential populations within these
exposure scenarios resulted in unacceptable risk levels from soils and groundwater. As
evidenced in Table 1, risks under the construction worker and long term worker scenarios
were largely driven by incidental ingestion and/or dermal contact with surface and
subsurface soils. The risk to future resident scenario was driven primarily by exposure to
groundwater. As footnoted in table one, the total risk values were calculated separately
regarding the shallow aquifer and the deep aquifer as it is not expected that a given child
would be exposed to both aquifers. The contaminants which contribute significantly to the
site risks are PAHs and arsenic.
For this Site, EPA believes that remedial action is warranted based on site-specific
conditions discussed above. The following sections evaluates the remedial alternatives
considered for this Site and their effectiveness in addressing these principal threats.
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TABLE 6-1
LIFETIME CARCINOGENIC AND NON-CARCINOGENIC RISKS
INDUSTRIAL AND RESIDENTIAL SCENARIOS
Exposure
Pathway
Construction
Worker
Cancer
Risk
Hazard
Index
On-Site Long Term
Worker
Cancer
Risk
Hazard
Index
Future Resident
(Child)
Cancer
Risk
Hazard
Index1
Surface Soil
Incidental
Ingestion
Dermal Contact
4-Oe-6
5.8"7
1.1e'1
7.4'3
1.0e'5
4.9e'6
5.2e"2
2.3e'2
6.2e'5
8.9G-6
1 ,4e+0
9.4e'2
Subsurface Soil
Incidental
Ingestion
Dermal Contact
7.8e'6
1.9e'6
3.9e'3
4. Be"4
NE
NE
NE
NE
NE
NE
NE
NE
Shallow Groundwater
Ingestion/
Inhalation
NE
NE
NE
NE
1 .4e'3
2.3*2
Deep Groundwater
Ingestion/
Inhalation
Total Risk
NE
2.4e'5
NE
0.12
NE
1.5-5 ,
NE
0.075
5.0e'3
5.08"3*
6.7e*3
6700*
Footnotes:
*Total risk values from exposure to deep groundwater. The total risk from shallow
groundwater calculated at 1 .4e'3 (carcinogenic) and 230 (non-carcinogenic).
NE - Not evaluated for this receptor.
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7.0 DESCRIPTION OF ALTERNATIVES
The following section provides a summary of the remedial alternatives for soils and
groundwater/NAPL that were evaluated in detail in the Feasibility Study Report. All
alternative cost estimates are expressed in 1997dollars and are based on conceptual
engineering, design and construction. Total present worth costs include capital costs and
operation/maintenance costs to completely finance the remedy over its planned life.
7.1 Development of Cleanup Levels
A Final Feasibility Study was completed in December 1997 to develop and evaluate
cleanup alternatives that provide adequate protection of human health. This effort required
the derivation of cleanup levels for the media of concern: soils and groundwater/NAPL.
Cleanup levels were necessary to identify areas to be addressed by EPA's response
action for the site. Based upon City of Charleston zoning plans and expected future
commercial land-use in the general site area, EPA has selected soil cleanup levels to be
protective of the construction worker under a future commercial land-use scenario. Given
the close proximity of the Dockside Condominiums to the site, potential exposure risks to
residents were also considered and as such ultimately factored into the final cleanup
levels.
In the final analysis the cleanup levels selected are actually protective for both
construction workers and future residents. This is possible because the cleanup levels
chosen were on the more protective end of the risk range for protecting the future
construction workers. As such they also fall within the acceptable range of risk values
which would be protective for on-site residents.
7.1.1 Soils
The Remedial Action Objectives (RAOs) for soils are focused on the protection of human
health and the protection of groundwater quality. From a human health perspective the
RAOs include ensuring that soils exposure concentrations levels are adequately protective
for the following scenarios: the future construction worker, the future long term worker, and
future residents. The FS developed cleanup levels for soils that were within EPA's
protective risk range of 1 x 10"4 to 1 x 10'6 for these three scenarios.
The corresponding Preliminary Remedial Goals (PRGs) were presented in the Rl and
summarized in Table 7-1. These values were based on data presented in the risk
assessment. The PRGs are not the concentrations above which all soils should be
remediated. The PRGs are based upon the Upper Confidence Limits10 (UCL) in the same
'"The UCL, which followed the identical approach used in the Human Health
Baseline Risk Assessment, defined the soil exposure point concentrations as the upper
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manner as the risk assessment used UCL in calculating the soil exposure point
concentrations for determining overall site risk. Because the UCL were used in calculating
the current site risk (3x10'5) it would follow that when back-calculating from an acceptable
site risk value (1x10"6) to a specific soil cleanup value, the resulting concentrations should
also reflect the UCL.
PRGs were initially developed for carcinogenic PAHs, arsenic and beryllium. Ultimately
beryllium was removed from further consideration. This decision was based on the
consideration that only two of the 43 subsurface soil samples exceeded the PRG
calculated for beryllium.
When evaluating the potential risk associated with exposure to carcinogenic PAHs, the
toxicity associated with benzo(a)pyrene is used as a point of reference. The concentration
of cPAHs can be evaluated by relating the toxicity of each cPAH to benzo(a)pyrene. For
example, benzo(a)anthracene has a relative potency factor of 0.1. If the
benzo(a)anthracene concentration is 5 rng/kg, it is lexicologically equivalent to a BaP
concentration of 0.5 mg/kg. These concentrations are referenced throughout the remainder
of this ROD as Benzo(a)Pyrene toxicity equivalents, or B(a)Peq. The selected PRG for
B(a)Peq is 1.7 ppm and the PRG for arsenic is 7.6 ppm.
Based orTSummers model results as presented in Section 8.2 of the Rl report, a cPAH soil
remedial goal protective of groundwater was not necessary since such a goal would be
several orders of magnitude greater than soil remediation levels associated with direct or
indirect exposures.
7.1.2 Groundwater/NAPL
A source area of subsurface NAPL in addition to an impacted area of groundwater have
been identified at the site. The presence of NAPL as reported in the Rl can be grouped
around the MGP; more specifically the former gas holder, the former rail spur, and the
former oil tanks. The NAPL source areas that will be addressed are illustrated on Figure
7-1. The general locations for the placement of recovery wells addressing the dissolved
phase plume are also shown in Figure 7-1. This figure represents general locations for
both NAPL recovery wells and groundwater recovery wells. The exact locations and
number of wells may be modified or expanded based on remedial design considerations.
limit of the 95 percent confidence interval of the arithmetic mean.
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Table 7-1
Soil Preliminary Remediation Goals
HYPOTHETICAL FUTURE RES
BSG-CAUQULAILC*.
II
II
ft
F
E
E
E
;
•4GESTION OF SOIL
1
,f
\
.F
:D
tw
tt
200
1.00E-06
1
365
6
15
25550
t
• >
JERMAL CONTACT
JA
^F
4490
0.6
EABAMETER.
EKA)Pe<»
Arsenic
EKA)P«q
Arsenic
B(A)Pe 7.3 9.1 0.01
) 1.8 8.8 0.001
': 0.6!MG^G
) 2.9;MG/KG
) '. 6.0 'MG/KG
}' 291MG/KG
PRG (1.0E04) '• «FMG/KG _ *
PRG(1.0E-04): 290~MC/KG _ >•
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EPA has adopted the long-term remediation objectives for sites where NAPL is
encountered in groundwater as presented in the EPA OSWER Directive 9234.2-25,
"Guidance for Evaluating the Technical Impracticability of Groundwater Restoration (EPA
1993)". In general EPA's groundwater/NAPL remediation objectives are:
• Removal or treatment of NAPL to the maximum extent practicable;
• Containment of potentially non-restorable source areas; and
• Restoration of aqueous contaminant plumes.
A phased approach for groundwater remediation will be used to achieve these objectives
at this Site. The initial effort will concentrate on removal or treatment of NAPLs previously
identified at the former gas holder, the former rail spur, and the former oil tanks. This would
typically consist of free-phase NAPL removal aided by pump-and -treat. Removal of NAPLs
is anticipated to have the effect of mitigating the primary contaminant source responsible
for groundwater contamination at this Site. Concurrent with the NAPL removal, additional
actions will be undertaken to restore the aqueous contaminant plumes to meet MCLs.
The NAPLs removal will be monitored to evaluate the practicability of such actions. Should
complete source removal or treatment prove impracticable, the use of migration controls
or containment measures will be taken for the non-restorable source areas. The
determination of technical impracticability will be made by EPA, in consultation with SC
DHEC, based on site-specific characterization data and remedy performance data. Such
data would include, but not necessarily be limited to:
A demonstration that contaminant sources have been removed and contained to the
maximum extent practicable;
An analysis of the performance of any ongoing or completed remedial actions;
Predictive analysis of the time frames to attain required cleanup levels using
available technologies; and
A demonstration that no other remedial technologies could attain the cleanup levels
within a reasonable time frame.
Should EPA ultimately make a determination of technical impracticability based on an
evaluation of the supporting data, the remedy would be re-evaluated and documented by
a ROD amendment. The groundwater/NAPL alternatives developed in the FS Report and
summarized in this ROD will focus on a phased approach to achieving the three
groundwater/NAPL remediation objectives listed above. Ultimately it is it is expected that
the MCLs listed below will apply to this Site. Carbazole is the one exception where the
value listed is based on risk-based calculation rather than an MCL.
-------
FLUOR DANIEL GTI
REV. NO.:
DRAWING DATE: | ACAO FILE:
2/4/98
- IMPACTED SOIL TO BE EXCAVATED
*
- PROPOSED DNAPL RECOVERY
LOCATION
~ PROPOSED RECOVERY WELL
o
o
c
a>
o'
D
O
o'
CO
•s .
g o
3 -^
8
0;
vo o
oo 3
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GROUNDWATER CONTAMINANTS (PPM)
Contaminant
Arsenic
Cyanide
Benzene
2,4-Dimethylphenol
Benzo(a)pyrene
Ethylbenzene
Beryllium
Lead
Carbazole
Mercury
Chrysene
Naphthalene
Chromium
Nickel
Copper
Toluene
Maximum Detected
0.088
4.5
5.2
0.89
0.038
1.2
0.013
1.9
0.15
0.015
0.16
5.'5
0.13
0.30
5.1
1.8 .
Cleanup Goal
0.05
0.2
0.005
0.7
0.0002*
0.7
0.004
0.015
0.005**
0.002
0.020
1.5
0.1
0.1
1.3
1.0
•Represents PAHs as a group.
"Based on actual risk calculation rather than MCL
7.2 Soil Alternatives
The following information presents the different cleanup alternatives which were initially
considered for remediating the contaminated soils at the Site.
7.2.1 Alternative 1: No Action
The No Action Alternative entails performing no remedial activities and is included in
accordance with the NCP.
7.2.2 Alternative 2: Natural Attenuation
This alternative would involve the processes of natural attenuation to degrade soil
contamination over time. Natural Attenuation is dependent upon demonstrating that
contaminant levels are decreasing due to natural processes. The use of Natural
Attenuation is dependent upon several factors including the monitoring of'contaminant
levels in soils, existing microbial populations, nutrient levels, and electron acceptor
conditions. This alternative will be eliminated from further consideration due to
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implementability constraints associated with the planned development for the Site,
specifically buildings and urban cover.
7.2.3 Alternative 3: Surface Cover/Capping
This alternative consists of utilizing a low permeability surface cover to isolate the
contaminated soil from direct human contact and reduce infiltration of surface waters
through these same area. The surface cover would be constructed of low permeability soils
or other man made materials. This alternative will be retained for further evaluation.
7.2.4 Alternative 4: In Situ Bioremediation
This alternative involves the application of an electron acceptor and nutrients to enhance
any naturally occurring biodegradation which may be occurring at the Site. Potential
electron acceptors and nutrients could include oxygen, hydrogen peroxide, or nitrate which
would be introduced into the contaminated soil. Due to implementability constraints
associated with buildings, an expected lengthy treatment duration, and lack of fit with the
planned site use, this alternative will be eliminated from further consideration.
7.2.5 Alternative 5: Excavation, Chemical/Biological Treatment, & Replacement
This alternative would initially involve the excavation of contaminated soil. Debris would
be steam cleaned and disposed of in" a landfill The soils would be added to a slurry
reactor along with a chemical oxidant. This slurry would then be dewatered followed by the
addition of nutrients and air into the reactors. Following this treatment the soil would be
dewatered and backfilled into the excavation. Due to implementability constraints including
limited available on-site space, this alternative will be eliminated from further
consideration.
7.2.6 Alternative 6: Excavation, Thermal Desorption, & Replacement
This alternative would consist of excavating the contaminated soil and treating the soil in
an on-site low temperature thermal desorption unit. This process requires heating the soil
to elevate the vapor pressure of the contaminants which would enable diffusion through,
and volatilization from, the soil. The treated soil would then be used to backfill the
excavation areas.
Thermal desorption is affected by several factors including the type of contaminants
present, their concentrations in the soil, their desorption temperature, and the duration of
treatment. Due to space limitations, possible recalcitrant contaminants, and public relation
concerns within this highly populated area, this alternative will be eliminated from further
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consideration.
7.2.7 Alternative 7: Excavation & Off-Site Incineration
This alternative would involve excavating the contaminated soil and transporting them to
an off-site facility for incineration. The excavated areas would then be backfilled with clean
fill material. This alternative is generally effective for treating similar sites and will be
retained for additional evaluation.
7.2.8 Alternative 8: Excavation & Off-Site Landfill
This alternative involves excavating the soils followed by transportation to an off-site
landfill. Following excavation, the area will be backfilled with clean fill. Presently the waste
associated with MGPs are not subject to the Land Disposal Restriction but are regulated
as hazardous because they typically exhibit a toxicity characteristic of hazardous waste,
most often due to the concentration of benzene. Overall this still remains a viable
alternative and will be retained for evaluation.
7.3 Shallow Groundwater
The following sections address the remedial alternatives for shallow groundwater. In the
context of the site wide groundwater objectives this requires addressing both the dissolved
phase portion of the plume in addition to the removal or treatment of NAPLs. The removal
or treatment of NAPLs is referenced to as source removal in these following sections.
7.3.1 Alternative 1: No Action
The No Action Alternative would leave the Site groundwater untreated. Long term
monitoring of the groundwater would be included to monitor site specific contaminants of
concern. The No Action alternative is retained throughout the FS in accordance with the
NCP.
7.3.2 Alternative 2: Institutional Controls
Under this alternative no remediation would be performed and site groundwater would
remain untreated. This alternative would involve imposing restrictions on the future uses
of groundwater at the Site. These institutional controls would consist of deed restrictions
and access restrictions. This alternative will not be retained for further evaluation as it is
not capable of meeting the three groundwater objectives stated in section 7.1 Development
of Cleanup Levels. While this alternative will be eliminated as a stand-alone alternative,
it will be combined with other alternatives to address contaminated shallow groundwater.
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7.3.3 Alternative 3: Institutional Controls, Source Removal, Phytoremediation, and
Natural Attenuation
This alternative utilizes institutional controls as mentioned in the preceding alternative in
combination with several other processes including source removal (NAPLs),
phytoremediation and natural attenuation. Source removal would consist of extracting
NAPL from known NAPLs locations via recovery wells followed by either reuse, energy
recovery, or destruction of recovered material. The phytoremediation would involve the
planting of specifically selected tree species which are theoretically capable of breaking
down the contaminants present in the grogndwater. The natural attenuation approach
would assess electron acceptors and nutrients in addition to evaluating the microbiological
populations and conditions. While there is no evidence that this particular combination of
processes would be effective for the site specific contaminants and conditions, it has the
potential to work under limited conditions. As such it will be retained for further evaluation.
7.3.4 Alternative 4: Institutional Controls, Source Removal, Phytoremediation, and
In Situ Bioremediation
This alternative would utilize those technologies/processes described in alternative 3 but
replace natural attenuation with in situ bioremediation. This would require the application
of an electron acceptor and nutrients to the shallow groundwater in order to stimulate
biological degradation of the contaminants. While this alternative is considered to be
marginally implementable due to constraints of placement and access to injection points,
it will be retained for further consideration.
7.3.5 Alternative 5: Institutional Controls, Source Removal, Phytoremediation, Grout
Curtain, Vertical Wells, Separation, Filtration, GAC, and POTW Discharge
This alternative would utilize a portion of the technologies/processes described in
alternative 4 (Institutional Controls, Source Removal, Phytoremediation) in combination
with a downgradient grout curtain to contain groundwater. Additionally this alternative also
includes the extraction of the dissolved phase groundwater plume. This extracted
groundwater would then undergo separation, filtration, and granular activated carbon
treatment before discharging to a sanitary sewer system (POTW). Although site specific
conditions would result in implementation constraints for this alternative (existing electrical
substation and underground utilities), this alternative will be retained for further evaluation.
7.3.6 Alternative 6: Institutional Controls, Source Removal, Phytoremediation, Sheet
Piling, Vertical Wells, Separation, Filtration, GAC, and POTW Discharge
This alternative would utilize the technologies/processes described in alternative 5 but
would substitute sheet piling for the grout curtain. The sheet piling would essentially act
to retain the groundwater in a manner similar to the grout curtain. This alternative has
been eliminated from further consideration due to the implementation difficulties, especially
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those associated with installing sheet piling in areas having underground utilities.
7.3.7 Alternative 7: Institutional Controls, Source Removal, Phytoremediation,
Interceptor Trenches, Separation, Filtration, GAC, and POTW Discharge
This alternative is a variation of alternative 6 and uses interceptor trenches instead of
sheet piling. The interceptor trench or trenches would act as a barrier to the migration of
shallow groundwater. Due to implementation difficulties associated with the presence of
underground utilities, this alternative was eliminated from further consideration.
7.3.8 Alternative 8: Institutional Controls, Source Removal, Phytoremediation,
. Vertical Wells, Separation, Filtration, GAC, and POTW Discharge
This alternative is similar to alternative 5 with the exception of omitting the grout curtain
and in turn depending entirely upon the use of vertical wells to attain hydraulic control.
Because this alternative would potentially address the groundwater objectives for this site,
it will be retained for further evaluation.
7.4 Intermediate Groundwater
This secTion presents alternatives developed to address contaminated groundwater in the
intermediate aquifer.
7.4.1 Alternative 1: No Action
The No Action alternative would leave the intermediate groundwater untreated. Long term
monitoring of the intermediate groundwater would be included to determine groundwater
conditions over time. This alternative is retained throughout the FS in accordance with the
NCP.
7.4.2 Alternative 2: Institutional Controls
Under this alternative no remediation would be performed and site groundwater would
remain untreated. This alternative would involve imposing restrictions on the future uses
of groundwater at the Site. These institutional controls would consist of deed restrictions
and access restrictions. This alternative will not be retained for further evaluation as it is
not capable of meeting the three groundwater objectives stated in section 7.1 Development
of Cleanup Levels. While this alternative will be eliminated as a stand-alone alternative,
it will be combined with other alternatives to address contaminated shallow groundwater.
7.4.3 Alternative 3: Institutional Controls and Natural Attenuation
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This alternative utilizes institutional controls as mentioned in the preceding alternative in
combination with natural attenuation. The natural attenuation approach would assess
electron acceptors and nutrients in addition to evaluating the microbial populations and
conditions. While there is no evidence that this particular combination of processes would
be effective for the site specific contaminants and conditions, it has the potential to work
under limited conditions. As such it will be retained for further evaluation.
7.4.4 Alternative 4: Institutional Controls and In Situ Bioremediation
This alternative would utilize the institutional controls described above in conjunction with
in situ bioremediation. Bioremediation would be approached through the application of an
electron acceptor and nutrients to the groundwater to stimulate biological degredation of
the contaminants. While this alternative is considered to be marginally implementable due
to constraints of placement and access to injection points, it will be retained for further
consideration.
7.4.5 Alternative 5: Institutional Controls, Vertical Wells, Separation, Filtration, GAC,
and POTW Discharge
In addition to the institutional controls this alternative would include the installation of
vertical wells to remove intermediate groundwater for treatment and hydraulic control.
Additionally this alternative also includes the extraction of the dissolved phase
groundwater plume. This extracted groundwater would then undergo separation, filtration,
and granular activated carbon treatment before discharging to a sanitary sewer system
(POTW). This alternative will be retained for further evaluation.
8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The objective of this section of the ROD is to evaluate the relative performance of the
alternatives with respect to the nine evaluation criteria, so that the advantages and
disadvantages of each are clearly understood. The Threshold Criteria must be met for an
alternative to be selected. These criteria are presented in Sections 8.1 and 8.2, followed
by a discussion presented in the following media-specific subsections: 1) soils; 2) shallow
groundwater; and 3) intermediate groundwater. Sections 8.3 through 8.7 present the
Balancing Criteria, which are used to weigh the major advantages and disadvantages of
each remedial alternative. The discussion in these Sections is organized using the same
media-specific subdivisions. Sections 8.8 and 8.9 discuss State Acceptance and
Community Acceptance, respectively.
8.1 Overall Protection of Human Health & the Environment
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Overall protection of human health and the environment addresses whether each
alternative provides adequate protection of human health and the environment and
describes how risks posed through each exposure pathway are eliminated, reduced, or
controlled through treatment, engineering controls, and/or institutional controls
9.1.1 Soil
Four remedial action alternatives for soil were retained for detailed evaluation. These
include:
Alternative 1: No Action;
Alternative 3: Surface Cover/Capping;
Alternative 7: Excavation & Off-Site Incineration; and
Alternative 8: Excavation & Off-Site Disposal
In the following analysis these alternatives are compared to one another against the nine
criteria. The relative advantages and disadvantages of each alternative are also
summarized in the following table.
COMPARISON OF SOIL CLEANUP OPTIONS
Cleanup Option
No Action
Cover/Capping
Off-Site
Incineration
Off-Site Landfill
Overall
Protection
X
o
•
•
Compliance
with ARARs
X
$
•
•
Long-term
effectiveness
X
&
•
&
Reduction of
toxicity, mobility.
& volume
X
o
•
®
Short-term
effectiveness
X
•
&
€>
Ability to
Implement
•
&
%
%
Cost
•
#
®
%
X - Fails Minimum Requirements, O - Nominally Acceptable, & - Moderately acceptable,
acceptable
- More
Overall Protection of Human Health and the Environment
Alternative 7, Excavation & Off-Site Incineration, and Alternative 8, Excavation & Off-Site
Land filling, both provide the most protection to human health and the environment through
the removal of impacted soil thereby preventing potential future exposure. Both of these
alternatives are considered the most effective alternatives in meeting this criteria.
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Alternative 3, Surface Cover/Capping, would provide limited protection for some exposure
pathways but not to the future on-site construction workers. It also does not address the
soil to groundwater pathway for migration of contaminants. The No-Action alternative
would not provide adequate protection of human health and the environment and is not
considered effective in meeting this criteria.
Compliance with Applicable or Relevant and Appropriate Requirements
Alternatives 7, and 8 could be designed appropriately to be in compliance with all federal
and state applicable or relevant and appropriate requirements (ARARs) and are all
considered effective in meeting this criteria. Alternative 3, Cover/Capping may meet action-
specific and location-specific ARARs but may not meet chemical-specific ARARs. The No
Action alternative does not meet the ARARs for protecting human health and the
environment and is considered ineffective in meeting this criteria.
Short-Term Effectiveness
While alternatives 3, 7, and 8, are capable of meeting this criteria to varying degrees,
Alternative 3, Surface Cover/Capping, would be the most effective in meeting this criteria.
Alternatives 7 and 8 are least effective in meeting this criteria due to short term risk
associated with worker exposure' during excavation and transportation activities.
Alternative 1, No Action, would have no short term effectiveness.
Long-Term Effectiveness
Alternatives 7 and 8 would both provide the greatest long-term effectiveness due to
removal of the impacted soil. Because Alternative 7 includes destruction of impacted soil
via incineration, it would be the best choice in meeting the long-term effectiveness criteria.
Alternative 3, Surface Cover/Capping, would be somewhat less effective over the long term
since it would rely on periodic maintenance of the cover/cap to maintain its integrity. The
No Action alternative would not provide any long term effectiveness.
Reduction of Toxicitv. Mobility, or Volume
Alternative 7, Excavation and Off-Site Incineration, would reduce the toxicity, mobility, and
volume of impacted soil and is considered to be the most effective alternative in meeting
this criteria. Alternative 8, Excavation & Off-Site Landfilling, provides a reduction in toxicity
and mobility but does not reduce the volume and is therefore slightly less effective in
meeting this criteria. Alternative 3, Cover/Capping, would also reduce mobility and toxicity.
The No Action alternative would not effectively meet this criteria.
Implementabilitv
The No Action alternative meets this criteria and would also be the easiest alternative to
implement. Alternative 3, Cover/Capping, is also readily implementable for this site.
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Alternative 7, Excavation & Off-Site Incineration, and Alternative 8, Excavation & Off-Site
Incineration, would be implementable but are also the most difficult of the alternatives to
implement.
Present Worth Costs
Since there would be no costs associated with the No Action alternative, it is inherently the
most desirable in meeting this criteria. Alternative 3, Cover/Capping ($458,000) is more
expensive than the No Action alternative but considerably less costly than alternatives 7
($7,570,000) and 8 ($2,280,000). Alternative 7, Excavation & Off-Site Incineration, and
Alternative 8, Excavation & Off-Site Incineration, would be considered the most expensive
to implement and are the least desirable from a cost alone consideration.
8.1.2 Shallow Groundwater/NAPL
As discussed previously in Section 7.1.2 the remedial action objectives for sites where
NAPL is encountered in groundwater consists of the following:
Removal or treatment of NAPL to the maximum extent practicable;
• Containment of potentially non-restorable source areas; and
• ~ Restoration of aqueous contaminant plumes.
Five alternatives were retained for comparative evaluation of the shallow groundwater.
These alternatives consist of the following:
• Alternative 1: No Action;
• Alternative 3: Institutional Controls, Source Removal, Phytoremediation,
and Natural Attenuation;
• Alternative 4: Institutional Controls, Source Removal, Phytoremediation,
and In Situ Bioremediation;
• Alternative 5: Institutional Controls, Source Removal, Phytoremediation,
Grout Curtain, Vertical Wells, Separation, Filtration, GAC, & POTW
Discharge; and
• Alternative 8: Institutional Controls, Source Removal, Phytoremediation,
Vertical Wells, Separation, Filtration, GAC, & POTW Discharge.
With the exception of Alternative 1, the No Action alternative, all remaining alternatives
include source removal in accordance with the first remedial action objective. The
remaining alternatives differ in their approach to addressing the remaining two objectives.
specifically that of containing potentially non-restorable source areas and restoration of
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the aqueous contaminant plume. These alternatives are summarized in the table below.
:COMPARISON OF SHALLOW GROUNDWATER CLEANUP OPTIONS
Cleanup Option
No Action
Source removal,
Phyto. Natural
Attenuation
Source removal,
Phyto,
Bioremediation
Source removal,
Phyto, Grout
Curtain, Recover
Wells with Filter
System
Source removal,
Phyto, Recover
Wells with Filter
System
Overall
Protection
X
;!>
%
•
•
Compliance
with ARARs
X
o
0
•
•
Long-term
effectiveness
X
^
&
•
•
Reduction of
toxicity, mobility.
& volume
X
®
•®
•
•
Short-term
effectiveness
X
%>
©
®
®
Ability to
Implement
•
•
<$
O
&
Cost
•
•
<®
O
*
X - Fails Minimum Requirements, O - Nominally Acceptable, f: - Moderately acceptable, • - More
acceptable
Overall Protection of Human Health and the Environment
The primary component of this evaluation criterion is the ability of a remedial alternative
to achieve the remedial action objectives established for groundwater. This would consist
of the removal, treatment and containment of NAPL and the containment and restoration
of aqueous contaminant plumes. Alternatives 5 and 8 would meet these objectives and is
therefore considered to be two alternatives most protective of human health and the
environment. These technologies have been well established at other sites.
Alternatives 3 and 4 may be capable of meeting this criteria under controlled conditions,
however, such site specific conditions were not effectively established as of the writing of
this ROD. It would follow that there is some uncertainty as to their effectiveness in meeting
the criteria of overall protection of human health and the environment. Limitations on
locations for tree planting is limited and irregularly spaced which could impact the
effectiveness of phytoremediation.
Since the no-action alternative does not include active measures to address
groundwater/NAPL except for what is planned under the Interim Remedial Action, this
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alternative is not protective.
Compliance with ARARs
Section 121 (d) of CERCLA requires that remedial actions at CERCLA sites at least attain
legally applicable or relevant and appropriate federal and state requirements, standards,
.criteria and limitations which are collectively referred to as ARARs, unless such ARARs
are waived under CERCLA Section 121(d)(4). Applicable requirements are those
substantive environmental protection requirements, criteria, or limitations promulgated
under federal or state law that specifically address hazardous substances, the remedial
action to be implemented at the site, the location of the site, or other circumstances
present at the site. Relevant and appropriate requirements are those substantive
environmental protection requirements, criteria, or limitations promulgated under federal
or state law which, while not applicable to hazardous materials found at the site, the
remedial action itself, the site location or other circumstances at the site, nevertheless
address problems or situations sufficiently similar to those encountered at the site that
their use is well-suited to the site. Compliance with ARARs addresses whether a remedy
will meet all of the ARARs of other federal and state environmental statutes or provides
a basis for invoking a waiver.
Alternatives 3,4,5, and 8 were evaluated with respect to action-specific, chemical-specific,
and location-specific ARARs. Alternatives 3, 4, 5, and 8 all incorporate technologies to
contain and/or potentially recover NAPL and impacted groundwater from the source areas
on-site. While achievement of MCL-based cleanup levels maybe technically impracticable
at sites with NAPL contamination, Alternatives 5 and 8 incorporate a series of extraction
wells that are expected to have a beneficial impact on the restoration of dissolved-phase
aqueous plumes downstream of the source area in the former Treatment Area. Therefore,
Alternatives 5 and 8 provide the highest degree of compliance with ARARs.
Alternative 3 relies solely on phytoremediation and natural attenuation for groundwater
containment and restoration and therefore receives a lower rating for this criterion. While
research does indicate that phytoremediation via trees can successfully treat groundwater
contaminated with BTEX and some inorganic compounds under controlled conditions,
there is no research indicating their effectiveness on PAH contaminated groundwater.
Other phytoremediation studies, using grasses to remediate PAHs, have shown some
effectiveness on soils but not groundwater. Additionally these studies were limited to
anthracene and pyrene in soils and not groundwater. In a similar manner Alternative 4
relies entirely upon phytoremediation and in situ bioremediation for containment and
restoration and therefore receives a lower rating than alternatives 5 and 8.
Short-Term Effectiveness
Short-term effectiveness refers to the period of time needed to complete the remedy and
any adverse impacts on human health and the environment that may be posed during
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construction and implementation of the remedy until Performance Standards are achieved.
The primary factors influencing ratings for short-term effectiveness are potential adverse
impacts to the community and/or remediation workers during site construction activities,
potential environmental impacts and duration of remedy implementation activities.
None of the alternatives were significantly better than the others with regards to short-term
effectiveness. Alternatives 3 and 4 can be implemented quickly with minimal disruption yet
the growth period required for phytoremediation would require several growing seasons
to reach its maximum effectiveness. Alternatives 5 and 8 could be effective within a
relatively short time frame but would have potential short-term risk associated with worker
exposure to contaminated groundwater recovered during the initial installation. For these
reasons alternatives 3 and 4 received a slightly higher rating for short-term effectiveness
than alternatives 5 and 8. The No Action alternative would not be considered to have any
short-term effectiveness.
Long-Term Effectiveness
Long-term effectiveness and permanence refers to expected residual risk and the ability
of a remedy to maintain reliable protection of human health and the environment over time,
once Performance Standards have been met. This criterion includes the consideration or
residual risk and the adequacy and reliability of controls.
While alternatives 3, 4, 5, and 8 may all effectively meet this criteria, the long-term
effectiveness for alternatives 5 and 8 have been better documented than for alternatives
3 and 4. Once again it should be noted that the technologies associated with alternatives
3 and 4 may be capable of meeting this criteria under controlled conditions, however, such
site specific conditions have not been effectively established for this site to date. Due to
the uncertainty associated with alternatives 3 and 4, alternatives 5 and 8 received the
higher ratings for long-term effectiveness. The No Action alternative is considered
ineffective in regards to long-term effectiveness.
Reduction of Toxicitv. Mobility or Volume
This criterion evaluates the reduction in toxicity, mobility or volume through the treatment
technology components of the remedial alternatives.
Alternatives 5, and 8 will reduce the TMV of the contaminants of concern in shallow
groundwater and as such received the highest ratings among the alternatives when
evaluated against this criteria. Alternatives 3 and 4 will likely reduce the mobility, volume,
and to a lessor extent some of the toxicity associated with groundwater contamination via
phytoremediation. While phytoremediation may act to contain the groundwater it is not
expected to effectively degrade all the contaminants of concern. The No Action alternative
would not effectively reduce the TMV.
implementabilitv
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This criterion addresses the relative ease of remedy implementation and the availability
of treatment technologies necessary to meet Performance Standards.
The No Action alternative is considered the most effective in meeting this criteria. All the
remaining alternatives are implementable yet require varying degrees of effort for their
implementation. Alternative 3 would require the least amount of effort among the remaining
alternatives. Alternative 5 would be the least implementable due to the major construction
associated with the grout curtain.
Present Worth Costs
This criterion evaluates the present worth costs of the developed remedial alternatives.
Since there would be no cost associated with the No Action alternative other than
groundwater monitoring, it receives the highest rating among the alternatives for this
criteria at $307,000. Alternative 3 is the second least costly alternative ($1,426,000)
followed closely by alternative 4 ($1,931,000). The remaining alternatives (5 and 8)
represent a substantial increase cost over the other alternatives at $4,961,000 and
$5,463,000.
8.1.3 Intermediate Groundwater
The groundwater remedial action objectives for the intermediate groundwater are similar
to those applied to the shallow groundwater in section 8.1.2. The remedial action
objectives for sites where NAPL is encountered in groundwater consists of the following:
• Removal or treatment of NAPL to the maximum extent practicable;
• Containment of potentially non-restorable source areas; and
• Restoration of aqueous contaminant plumes.
The Rl revealed the presence of both NAPL and a dissolved phase contaminant plume
within the intermediate aquifer. While NAPL appears to be isolated within the area of the
gas holder, the extent of the dissolved phase contaminant plume was not well defined
during the Rl. Because the extent of the dissolved groundwater contaminant plume within
the intermediate aquifer was not well defined during the Remedial Investigation, additional
investigation will be performed to characterize the extent of this contamination and
presented as operable unit two under a separate ROD. This ROD will address the issue
of source removal (and disposition of this source) for the intermediate aquifer within the
Selected Remedy section of this ROD.
8.8 STATE ACCEPTANCE
SC DHEC does concur with EPA's selected remedy described in Section 9.0. The SC
DHEC concurrence letter is attached to this ROD as Appendix A. SC DHEC believes that
EPA's selected remedy will be of benefit in the reduction of risk at the site achieving long
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term protection of human health and the environment.
8.9 COMMUNITY ACCEPTANCE
A public meeting was held on March 1998 to discuss the remedial alternatives under
consideration and EPA's Proposed Plan for cleanup of the Calhoun Park Superfund Site.
A 60-day public comment period on EPA's Proposed Plan was held from March 16, 1998
to May 15, 1998. A copy of all comments received, EPA's response to these comments,
and a verbatim transcript of the March 1998 meeting are attached to this ROD as Appendix
B, The Responsiveness Summary. In general the community expressed acceptance with
EPA's Proposed Plan as presented during the public meetings.
9.0 THE SELECTED REMEDY
This section of the document provides a description of the components of EPA's selected
remedy on Operable Unit One for the Calhoun Park Superfund Site in Charleston, South
Carolina. The Performance Standards and other ARARs of EPA's selected remedy are
delineated in the sections that follow. The remedy described has been selected under the
authority granted in CERCLA and is consistent with the requirements of the NCP. EPA's
selected remedy is based upon a full consideration of remedial alternatives and all
comments received during the 60-day comment period on the Proposed Plan. Cost details
of EPA's selected remedy are delineated in Section 9.4.
9.1 Soil - Excavation and Off-Site Disposal
The overall objective of the soil component of EPA's selected remedy is to provide for
adequate protection of the construction worker under a future industrial land-use exposure
scenario. As discussed in Section 6.0 of this document, EPA's Human Health Baseline
Risk Assessment utilized conservative exposure pathways and assumptions to estimate
the potential risks posed to the future on-site worker. Under the future industrial exposure
scenario, unacceptable carcinogenic and non-carcinogenic risks were calculated for the
future on-site worker exposed to subsurface soils (six inches to water table). Exposure
pathways quantified were incidental ingestion of and dermal contact with soils.
EPA's Human Health Baseline Risk Assessment developed cleanup levels for surface and
subsurface soils within EPA's protective risk range of 1 x 10"4 to 1 x 10"6. The soil remedy
consists of the excavation of an estimated 6,080 tons of impacted soil with subsequent off-
site disposal in an approved landfill. EPA's selected soil remedy will eliminate exposure
to unacceptable concentrations of constituents in soil and permit beneficial future use of
the property.
All excavation activities shall be conducted in a manner which provides adequate short-
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term protection of on-site workers, and minimizes disruptions to local businesses and
adjacent neighborhoods. Air monitoring during active excavation shall be implemented for
the protection of on-site workers and to assess potential off-site impacts. As warranted,
dust and odor control measures shall be instituted to mitigate adverse impacts in the active
excavation areas, haul roads and adjacent off-site areas. On-site excavations shall be
backfilled and restored to a condition consistent with the intended future use of the
property.
All excavated soil shall be transported off-site for disposal in an approved hazardous
waste landfill. All transportation and off-site disposal activities shall be conducted in full
accordance with all ARARs, including but not limited to, RCRA and DOT regulations.
9.2 Groundwater/NAPL
EPA's groundwater/NAPL remediation strategy presented in this section applies to the
shallow aquifer described in Section 5.2. NAPL source removal, followed by either reuse,
energy recovery, or destruction of recovered material, will also be required for the
intermediate aquifer. Additional performance standards may be required for this
intermediate aquifer pending characterization of the dissolved phase contaminant plume.
Implementation of the groundwater/NAPL remedy at this site shall be consistent with
OSWER Directive 9234.2-25, Guidance for Evaluating the Technical Impracticability of
Groundwater Restoration (EPA 1993). This guidance promotes an iterative, phased
approach which includes early actions to remove contaminant sources, control plume
migration, and mitigate risks posed by impacted groundwater.
9.2.1 NAPL/Groundwater
The source areas of subsurface NAPL have been defined on-site, as presented in
Sections 5.2. These areas are referred to as the former gas holder, the former rail spur,
and the former oil tanks. The goal of EPA's groundwater/NAPL remedy is the restoration
of impacted groundwater at these source areas to the ARAR-based cleanup levels,
Maximum Contaminant Levels specified by the Safe Drinking Water Act. However, EPA
recognizes that restoration to these levels may be technically impracticable given the
characteristics of NAPL, limitations in remediation technology and/or complex
hydrogeology. Therefore, the groundwater/NAPL remedy in the three NAPL source areas
shall, at a minimum, achieve the following Performance Standards:
1) Removal or treatment of NAPL to the maximum extent practicable;
2) Containment of potentially non-restorable source areas; and
3) Containment and restoration of aqueous contaminant plumes.
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The above Performance Standards shall be achieved by the recovery of NAPL and
impacted groundwater by extraction wells installed in the shallow aquifer underlying the
three source areas. An additional extraction well or wells will be installed in the
intermediate aquifer in the area of the former gas holder. Figure 7-1 provides an illustration
of the source areas and general locations of extractions wells. Disposal options for the
recovered NAPLs material may include reuse, energy recovery, or destruction.
All groundwater recovered via this remedy component shall be treated to meet the ARARs
of the selected discharge option. It is envisioned that all recovered groundwater will be
conveyed to an on-site water treatment system. The water treatment system shall be
properly operated and maintained to meet the discharge requirements imposed by the
Charleston POTW.
The full-scale groundwater/NAPL remedy shall be monitored, modified and/or enhanced
where appropriate to demonstrate that best professional efforts have been made to
achieve ARAR-based cleanup levels and the applicable Performance Standards of this
remedy component. A comprehensive monitoring network will be established to delineate
the NAPL zone and aqueous contaminant plume. The data generated by this monitoring
program will be utilized to track the effectiveness of the remedy in achieving the
established objectives. The.conceptual remedy described herein may be modified and
enhanced as warranted based on review and analysis of monitoring data generated.
Recovery and treatment enhancements may include the installation of additional extraction
wells. EPA considers the full-scale groundwater/NAPL remedy to be an iterative process
which must be conducted for a sufficient period of time before its ability to meet applicable
cleanup levels and long-term Performance Standards can be fully evaluated. All decisions
regarding the technical impracticability of achieving ARAR-based cleanup levels and the
long-term Performance Standards at the three NAPL source areas shall be made by EPA,
with consultation by SC DHEC.
Phytore'mediation will also be used as a supplemental technology to the extraction
wells/separation/filtration system in the shallow aquifer. While the existing research does
not prove that trees would be effective upon all site-specific contaminants, this technology
would be effective on some of the contaminants thereby reducing the overall contaminant
mass and doing so in a low cost approach.
Because phytoremediation is a relatively new technology, its performance upon the
contaminants of concern under these site-specific conditions is untested. For this reason
this technology will be implemented on a limited basis, concurrent with an extraction well
recovery/treatment system, to evaluate its effectiveness on the dissolved phase portion of
the plume. Should phytoremediation prove effective in meeting the performance standards,
this technology could eventually be used to replace portions of the extraction
well/separation/filtration system.
9.3 Cost Summary
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Record of Decision
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This section of the document provides a cost summary for the key elements of EPA's
selected remedy at the Calhoun Park Superfund Site. The estimated capital costs for each
major remedy component, estimated operation and maintenance (O&M) costs, and total
net present worth over a 30-year period are provided below. All cost estimates are
expressed in 1997 dollars and are based upon conceptual engineering, design and
construction. The reader is referred to the Final FS Report for a more detailed breakout
of the cost information summarized below.
Soil and Drainage Ditch Sediments
Excavation of 6,080 tons $152,000
Transportation and off-site disposal of 6,080 tons $1,800,000
Backfill ..$121.600
Sub-Total Soil Component $2,280,000
Groundwater/NAPL
Source removal, recovery system and phytoremediation $997,000
Total Annual Operation & Maintenance $290.000
Present Worth Cost (Interest rate 5% over 30 yrs) $5,463,000
Total Estimated Cost of EPA's Selected Remedy $7>743,,000
10.0 STATUTORY DETERMINATIONS
Under CERCLA Section 121, EPA must select remedies that are protective of human
health and the environment, comply with applicable or relevant and appropriate
requirements (unless a statutory waiver is justified), are cost-effective, and utilize
permanent solutions and alternative treatment technologies or resource recovery
technologies to the maximum extent practicable. In addition, CERCLA includes a
preference for remedies that employ treatment that permanently and significantly reduces
the volume, toxicity, or mobility of hazardous wastes as a principal element. The following
sections discuss how the selected remedy meets these statutory requirements.
10.1 Protection of Human Health and the Environment
EPA's selected remedy protects human health and the environment through media-specific
components designed to eliminate or mitigate potential risks posed by the site. EPA's
remedy consists of: excavation and off-site disposal of 6,080 tons of impacted soil;
containment and recovery of NAPL and groundwater.
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PageSS
Excavation of 6,080 tons of the impacted soil will eliminate potential risks posed to the
future construction worker by exposure to surface/subsurface soils. All excavated soil will
be disposed off-site in a controlled and permitted landfill. The excavation and off-site
disposal of impacted soils provides a residual risk (post-remediation risk) of 1x10"6 which
is at the more protective end of EPA's acceptable risk range.
The Performance Standards developed for groundwater and NAPL at the source areas will
remove and treat NAPL to the maximum extent possible, contain potentially non-restorable
source areas, and contain/restore aqueous contaminant plumes. All recovered
groundwater will be treated to protective levels prior to discharge. Groundwater in the
shallow aquifer is not currently used for residential or industrial purposes, however, EPA's
selected remedy will eliminate risks posed by off-site transport to surface water bodies and
drainage ditches.
10.2 Compliance with Applicable or Relevant and Appropriate Requirements
EPA's selected response action will meet all ARARs discussed in Section 9.0 of this
document. These include, but are not limited to:
• RCRA Requirements for Identification, Management and Transportation of
Hazardous Waste (40 CFR 261, 262 and 263)
RCRA Land Disposal Restrictions (40 CFR 268)
DOT Hazardous Materials Regulations (49 CFR 107 and 171-179)
Safe Drinking Water Act (40 CFR 141)
Clean Water Act (40 CFR 403 and 404)
Coastal Zone Management Act (15 CFR 930)
OSHA Health and Safety Requirements (29 CFR 1910 and 1926)
10.3 Cost Effectiveness
EPA's selected response action will provide adequate protection of human health and the
environment at an estimated cost of $7,743,000. The soil component of EPA's selected
remedy involves the excavation and off-site disposal of 6,080 tons of impacted soil. EPA's
selected soil remedy provides an estimated residual risk, or post-remediation risk of 1 x
1Q-6 at an estimated cost of $2,280,000.
The groundwater/NAPL component addresses source removal (NAPLs) for both the
shallow and intermediate groundwater units and dissolved phase plume in the shallow
groundwater unit at an estimated present worth cost of $5,463,000. The decision to
incorporate phytoremediation as part of the groundwater treatment technology may provide
a substantial reduction in this estimated costs, should this technology prove effective, and
thereby enhance cost effectiveness.
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Based upon the above discussion, EPA has determined that the selected remedy provides
protectiveness that is proportionate to its costs and represents a reasonable value for the
money that will be spent.
10.4 Utilization of Permanent Solutions and Alternative Treatment Technologies or
Resource Recovery Technologies to the Maximum Extent Practicable
EPA has determined that the selected remedy represents the maximum extent to which
permanent solutions and treatment technologies can be utilized in a practicable manner
for the response action at the Calhoun Park Site. Of those alternatives that are protective
of human health and the environment and comply with ARARs, EPA has determined that
this selected remedy provides the best balance in terms of the five balancing criteria, while
also considering the statutory preference for treatment as a principal element and
considering state/community acceptance. The implementation of this remedy is also
expected to result in positive economical and environmental benefits to the local
community.
The groundwater/NAPL remedy component involves technologies that recover NAPL to
the maximum extent practicable at the three source areas on-site. All recovered
groundwater will be treated to. permanently reduce contaminant concentrations to
appropriate standards. This component also selects innovative phytoremediation
technology as a supplemental remedy for restoration and hydraulic- control of the
dissolved-phase aqueous contaminant plumes downgradient of NAPL source areas.
10.5 Preference for Treatment as a Principal Element
EPA's selected remedy will fulfill the preference for treatment as a principal element
through the recovery and treatment of impacted groundwater and NAPL. Furthermore, this
response action incorporates phytoremediation as an innovative groundwater treatment
in conjunction with an extraction well/recovery system.
-------
APPENDIX A
STATE CONCURRENCE LETTER
-------
09/30/08 WED 14:16 FAi 803 238 3302
SPRINCMAID BEACH
0)002
D H E C
PROMOTE PROTECT PROSPER
2600 Bull Street
Columbia. SC 29201-1708
September 30, 1998
COMMISSIONER:
. BfytM
.BOARD:
lohnHBmritt
Chiirmm
WiBi.jnM.HulI. Jr.. MD
Vice Chairman
Refer Le«k», Jr.
Secretary
MutB. Kcot
Cy*di C. MooeUer
Brian K. Smith
Rodney L. Onndy
John H. Hanldnaon, Jr.
Regional Administrator
U.S. EPA, Region IV
61ForsyihSt.,SW
Atlanta. GA 30303
RE: Calhoun Park Superfund Site - Record of Decision
Dear Mr. Haokinson:
The Department has reviewed and concurs with all parts of the revised Record of Decision
(ROD) dated September 23, 1998 for the Calhoun Park located in Charleston, S.C. In
concurring with this ROD, the South Carolina Department of Health and Environment
Control (SCDHEC) does not waive any right or authority it may have under federal or slate
law. SCDHEC reserves any right or authority it may have to require corrective action in
accordance with the South Carolina Pollution Control Act. These rights include, but are not
limited to, the right to insure that all necessary permits are obtained, all clean-up goals and
criteria are met, and to take separate action in the event clean-up goals and criteria are not
met Nothing in the concurrence shall preclude SCDHEC from exercising any administrative,
legal and equitable remedies available to require additional response actions in the event that:
OXa) previously unknown or undetected conditions arise at the site, or (b) SCDHEC receives
additional information not previously available concerning the premises upon which SCDHEC
relied in concurring with the selected alternative; and (2) me implementation of the remedial
alternative selected in the ROD is no longer protective of public health and the environment
SCDHEC concurs with the selected alternative for contaminated soils consisting of excavation
and disposal in a permitted landfill followed by the backfilling of the excavated areas with
clean fill. SCDHEC concurs with the selected groundwater alternative consisting of source
removal of NAPLs from both the shallow and intermediate aquifer and treatment of the
groundwater plume through a combination of recovery wells/filtration system and
Phytoremedianon.
Sincerely,
R. Lewis Shaw, P.E.
Deputy Commissioner
Environmental Quality Control
cc: Hartsill Truesdale .
Keith Lindler
Wayne Fanning, Trident EQC
Gary Stewart
u r Aonr IN A nRPARTMF. NTOFHEALTH AND ENVIRON MENTAL CONTROL
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APPENDIX B
RESPONSIVENESS SUMMARY
-------
RESPONSIVENESS SUMMARY
CALHOUN PARK SUPERFUND SITE
CHARLESTON, SOUTH CAROLINA
1 Comment: Correspondence from the South Carolina Department of Health &
Environmental Controls Office of Ocean and Coastal Resource Management
(OCRM) group dated March 26, 1998, requests that EPA comply with the
Federal Consistency provisions of the Coastal Zone Management Act, 15 CFR
930.
Response: All activities will be performed to meet the substantive requirements
for State of South Carolina's OOCRM for activities occurring in coastal zone.
Such activities would include, but not necessarily be limited to, the management
of surface water run-off during remedial actions. The OOCRM will receive work
plans associated with these activities for comment. Letter sent to OOCRM
reflecting this response.
2. Comment: Dr. Arthur LaBruce writes to suggest the possible use of a calcium
sulfate product produced by E&C Williams, Inc. as a possible clean up option.
Response: The referenced product identified as "Enthrall" acts primarily by
converting inorganic oxides to less reactive sulfides and has shown some
usefulness in treating inorganic contaminated soils and wastewater. Enthrall's
effectiveness in treating organic contamination, or more specifically the
polyaromatic hydrocarbons associated with the coal tar waste present at the
Calhoun Park site, has not been tested. Enthrall's most likely application here
could be reducing the RCRA characteristic nature of the inorganic waste
contaminants (i.e. leachability) so that the waste could be placed in a subtitle "D"
landfill instead of a subtitle "C" landfill. As such the parties performing the
cleanup (SCE&G) may pursue such a product's usefulness at that time.
3 Comment: Fluor Daniel GTI, on behalf of SCE&G, submitted a letter and
attachments dated May 14 ,1998, recommending phytoremediation over pump &
treatment. The general points to be derived from these submittals suggest that
a) when pump & treatment technology is implemented at sites where DNAPL is
present, the cleanup levels are seldom attained, and b) phytoremediation will
both contain and treat the site specific contaminants of concern present on
groundwater.
Response: With regards to the first point, DNAPL sites are particularly difficult to
remediate regardless of any technology used. This is a substantial point yet one
which was not considered within SCE&Gs letter or attachments. Td address the
technical issue surrounding the remediation of sites containing NAPL
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contamination, EPA published Directive 9234.2-25 titled Guidance for Evaluating
the Technical Impracticability of Ground-Water Restoration, September 1993.
The presence of DNAPL at the Calhoun Park site will likely result in a Tl
approach which is precisely the reason EPA has pursued the threefold
groundwater objective of 1) Removal or treatment of NAPL to the maximum
extent practicable, 2) Containment of non-restorable source areas; and 3)
Restoration of the aqueous plume. To this end pump & treatment would be
effective in meeting these objectives over a broad range of sites.
The groundwater objectives as listed above also become crucial in evaluating
the manner in which any cleanup technology will be implemented at such sites.
Any design document would therefore be based upon these objectives and
should discuss specific components required for a Tl evaluation including:
identification of the specific ARARs or media cleanup standards for which Tl
determinations are sought, spatial area over which the Tl decision will apply,
and a conceptual site model.
Because of the lack of actual site data supporting the effectiveness of
phytoremediation on PAH contaminated groundwater, the discussions have
been limited to theoretical evaluations. These evaluations covered groundwater
fFbw conditions, depth of aquifer, contaminant concentrations, and general
research papers on phytoremediation on soils, rather than groundwater. A vital
area of concern which has been repeatedly mentioned by EPA but not
addressed in any deliverable is the effectiveness of phytoremediation in treating
all site specific contaminants of concern. Research does indicate that
phytoremediation can successfully treat groundwater contaminated with BTEX
and some inorganic compounds under controlled conditions, however there is
no research data proving that phytoremediation is effective on PAH
contaminated groundwater, nor on its effectiveness through the use of trees.
In effect SCE&G is assuming that phytoremediation will remediate groundwater
because of research by Reilley (1996) indicates that plants were effective in
reducing concentrations of anthracene and pyrene in soil. A study using grasses
to treat two non-carcinogenic PAH compounds in soils would not have any
substantive application in predicting the effectiveness of trees on groundwater
contaminated with carcinogenic PAHs. SCE&G's assumption that trees would be
effective at this site because grasses were effective on another site is
unfounded. There is also the additional assumption relating a method that works
for soils as being applicable to groundwater. Such an assumption is also
unfounded. In effect that which works on soil does not necessarily work on
groundwater and that which works through grasses does not necessarily work
through trees. Overall the proposal is speculative and therefore are not a solid
basis for acceptance as a sole source remedy.
-------
Another problematic issue is also mentioned within Reilley's research yet
omitted from the summary offered by SCE&G. The original research paper notes
that "Although there is little evidence that microbial growth can be sustained in
presence of PAHs with four or more rings as a sole substrate, they may be
degraded by cometabolism". Here it is unclear under what conditions for which
these higher ring compounds could be expected to degrade if at all. This point
simply brings to light yet another unanswered question relating to predicting the
possible effectiveness of phytoremediation.
The issue of achieving hydrological containment for the groundwater plume has
not been adequately demonstrated for phytoremediation, either by theoretical or
empirical means. While a given number of trees can be estimated to remove a
predicted volume of water from the vados zone, containing the areal extent of
the plume will likely be compromised due to the limited available surface area for
planting trees relative to the location of the plume. In other words, while we may
be theoretically able to plant enough trees, the ability to place them in strategic
locations would be compromised due to existing and/or planned future use of the
site.
In summary EPA would not endorsed phytoremediation as a sole source remedy
for groundwater at this site based on the research information presented to date.
This does not imply that phytoremediation is without merit, but simply that the
weight of evidence is not such that EPA is willing to implement this technology
as a sole source remedy for this particular site. For these reasons the proposed
plan and the Record of Decision includes pump & treatment in conjunction with
phytoremediation. The pump & treatment would be installed first to address
early cleanup action. Meanwhile a phytoremediation system would be
established and its effect on contamination monitored. If phytoremediation
proves effective in meeting the cleanup strategy, the pump & treatment system
could be replaced by phytoremediation at that time.
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APPENDIX C
PUBLIC MEETING TRANSCRIPT
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1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
IN RE: CALHOUN PARK AREA
SUPERFUND SITE
PUBLIC MEETING
DATE :
TIME:
LOCATION:
TAKEN BY:
REPORTED BY:
M A 1
i I -4 r\ L
March 16, 1998
7:00 PM
Charleston Public Works Building
103 St. Philip Street
Charleston, SC
EPA
LORA L. McDANIEL,
Registered Professional Reporter
Computer-Aided Transcription By:
A. WILLIAM ROBERTS, JR., & ASSOCIATES
Charleston, SC
(803) 722-8414
Greenville, SC
(864) 234-7030
Columbia, SC
(803) 731-5224
Charlotte, NC
(704) 573-3919
A. WILLIAM ROBERTS, JR. & ASSOCIATES
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1 APPEARANCES:
2
TERRY TANNER, EPA Project Manager
3 CYNTHIA PEURIFOY, EPA Community
Involvement Coordinator
4
5 CONCERNED CITIZENS:
6 BARBARA JOHNSON
PAUL CAMPBELL
7 RICK RICHTER
PAT McGOWEN
8 LORRAINE PERRY
DIANE OLDSTON
9 ' ROBERT WELLS
ALLEN COHEN
10 CRAIG ZELLER
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
A. WILLIAM ROBERTS, JR. & ASSOCIATES
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1 MR. TANNER: Folks, if I can have your
2 attention. On behalf of the Environmental Protection
3 Agency, I would like to welcome you-all to the
4 meeting here tonight on the Calhoun Park Superfund
5 Site. We've got a couple of things that we are going
6 to be talking about tonight. And I've got at least
7 three objectives that I hope we can cover tonight
8 during the course of this meeting; the first is an
9 introduction to the environmental district of this
10 particular area of the site. I've got some overheads
11 on the slide; I am going to show you that a little
12 bit later on.
13 We are also going to talk about
14 contamination and the risk posed by that
15 contamination as well as a proposed cleanup method
16 for this site. Before I go any further, I would like
17 to introduce to you another important part of this
18 team, and that is a lady by the name of Cynthia
19 Peurifoy.
20 Cynthia is our community relations
21 coordinator. She makes sure all of us bonehead
22 scientists with our slide rulers communicate a little
23 bit better for folks who don't do this every day.
24 She does a very good job.
25 Cynthia, would you like to say a few
A. WILLIAM ROBERTS, JR. & ASSOCIATES
-------
1 words?
2 MS. PEURIFOY: Sure, I will just stand
3 over here, if you don't mind. I want to welcome
4 you-all to this proposed plan meeting and encourage
5 you to participate, ask questions and be a part of
6 this decision-making process. As Terry has told you,
7 he's got a lot to cover, and we want you to know this
8 is an extended comment period. We've got 60 days
9 starting today to get your input in.
10 So take a part of this process. We have
11 an information repository set up at the John Dart
12 Library. There you.will find the administrative
13 records, which has all the documentation that led to
14 the decisions that's being made or proposed here
15 tonight. So take some time and go by and take a look
16 at some of those documents.
17 I also want to tell you we have an 800
18 number; it's listed there in the fact sheet. Call
19 them. If you go through something, if you have a
20 question .or concern, feel free to call and ask a
21 question. We are available for that; Terry and I
22 both can be reached at that number.
23 We have a court reporter here tonight.
24 When you speak tonight, please identify yourself so
25 that she can record what you are saying and we can
A. WILLIAM ROBERTS, JR. & ASSOCIATES
-------
1 have a good record of this because part of this
2 process is to respond to your questions and concerns.
3 With that, I think that's all I have to say; Terry,
4 thanks.
5 MR. TANNER: Thank you, Cynthia. I will
6 use a slide here to give you a quick view of the site
7 we are talking about tonight. The site consists of
8 the current -- I will describe things in its current
9 context. There's an electrical substation located at
10 the intersection of Charlotte Street and Concord
11 Street. This is also adjacent to the old ballpark.
12 Some of you might have seen it. It's rather grown up
13 and abandoned, but I believe there still is a ball
14 diamond here and a backstop.
15 Directly across the street we have what
16 used to be the Ansonborough Homes in this area here.
17 These were recently demolished, I think, in the past
18 seven or eight months ago; therefore, none of these
19 structures exist. We also have, as part of the site,
20 as an example, the former Detyen's property, Dockside
21 Condominiums, as well as private land here owned by
22 the Park Service.
23 If you folks have been keeping up with
24 the news, you've probably heard a lot about the
25 aquarium that they are building in Charleston; you
A. WILLIAM ROBERTS, JR. & ASSOCIATES
-------
1 almost have to live under a rock not to. The
2 aquarium itself is located here. It's a source of a
3 lot of ongoing construction activities. We've also
4 got in this area Luden's Marine and Supply. It's a
5 rather old building. They are an outdoor/fishing
6 supply outfitter.
7 This, in essence, is one of the sites we
8 are going to talk about. This was a very active site
9 over the last 100 years. Some of the industries that
10 have operated within this plot that we know about are
11 an old gas manufacturing plant used to supply town
12 gas to the City of Charleston by the burning of coal;
13 we will get into that a little bit more when we start
14 talking about contamination.
15 We also had, at one time, a turpentine
16 plant located here. You can see the outline of where
17 the building used to be. We have in this area -- let
18 me get my bearings. We have an old Navy shipyard
19 that was very active during World War II that
20 serviced minesweepers, as I understand it. And those
21 are the big ones.
22 Any questions so far? I want to
23 encourage you to ask questions as this goes on. I
24 don't want this to turn into some formalized,
25 complicated thing.
A. WILLIAM ROBERTS, JR. & ASSOCIATES
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1 MS. JOHNSON: Could you point to the site
2 that's now the Maritime Center and say that's part of
3 it?
4 MR. TANNER: The Maritime Center would
5 actually be located, I think, further down here.
6 UNIDENTIFIED SPEAKER: Right where your
7 hand is.
8 MS. JOHNSON: That's not part of it?
9 MR. TANNER: No, ma'am. I think there
10 has been some environmental sampling that has gone on
11 at the Maritime Center but not as part of this
12 project.
13 What we found in doing our investigation
14 at this site, and you can see -- perhaps you can see
15 it a little better if I dim these lights slightly;
16 see what happens. That's a little bit better.
17 We literally peppered the site with
18 sampling locations. All of these places where you
19 see triangles and circles with Xs are essentially
20 sampling points. And what we found as we went out
21 and sampled this area was a large volume of a
22 particular group of compounds, which I will
23 abbreviate, polyaromatic hydrocarbons.
24 And we also found another group;
25 Benzene, toluene, ethene and xylene. Now, both of
A. WILLIAM ROBERTS, JR. & ASSOCIATES
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8
1 these groups -- and I will talk about these
2 interchangeably tonight -- are very common
3 contaminants from old manufacturing gas plants.
4 What the plant used to do -- and the
5 plant actually operated on this portion of the
6 property here -- is they would take coal out of coal
7 mines, ship it in by rail, which you can see here is
8 part of an old rail strip. They would run the coal
9 into this large container, remove the oxygen and heat
10 the coal.
11 Now, as part of that process, w.hat it
12 does is it extracts this very flammable gas 'out of
13 the coal itself. And because you are doing it in the
14 absence of oxygen, it doesn't actually blow up on
15 you. What it produces is, again, a very flammable
16 gas, which was distributed throughout the Charleston
17 area for use of the gas line.
18 Now, as an unfortunate byproduct of this
19 process, it also produced a lot of waste that, again,
20 we call PAHs; polyaromatic hydrocarbons. They are
21 essentially a large family of carbon type materials
22 that runs from the range of being very soupy-like
23 water all the way to the thick, heavier substances
24 you see in road tar. We have a wide range of
25 viscosity, especially with this material, as well as
A. WILLIAM ROBERTS, JR. & ASSOCIATES
-------
1 varying compositions of contaminants found within
2 this group of contamination.
3 What we've seen -- and I will focus in a
4 little bit -- is that when we took our samples, not
5 surprisingly enough, most of the contamination that
6 we noted with regard to soils start there, was along
7 this area here and here and here.
8 What we also found when we looked at the
9 groundwater samples is, not surprisingly enough, with
.10 groundwater flow this way, we found a large dissolved
11 plume-contaminated groundwater, and it goes right
12 through this drawing, something like this, which is
13 not surprising given the sources of contamination.
14 This will give you a little bit better
15 drawing of what happens environmentally at the site.
16 Initially, you have your release of contamination
17 here. And as it is continually injected into the
18 soil -- poured, dumped, however it may be -- it
19 eventually begins to saturate, and it flows down
20 into -- you can almost read that. What happens, the
21 contamination comes in contact with the soil, goes
22 right on down meantime into the groundwater table.
23 If you can imagine this as being a solid
24 table of soil, from here to here where the clay ends
25 down here to contain the groundwater, and then here
A. WILLIAM ROBERTS, JR. & ASSOCIATES
-------
10
1 you have a layer of water which is perched upon the
2 ground, perched upon the clay, and on top of that you
3 have nonsaturated soils.
4 What happens in sites just like this is
5 that the contamination comes in contact with the soil
6 and continues to seep down into the soil. It
7 eventually comes into contact with the groundwater.
8 When it does, you get -- in this direction, you have
9 clean groundwater; here, as it passes through the
10 soil, which is ladened with contamination, you
11 develop contaminated groundwater; thus you end up
12 with a plume like this, much like you see at the
13 site.
14 Here is an actual drawing of the
15 contamination. It's something like this. Again, you
16 can see where it's corresponding to what we believe
17 to be the source of the contamination here.
18 MS. JOHNSON: How far down is the plume?
19 How far below the ground level is the plume?
20 MR. TANNER: There's actually two
21 instances where I believe the contamination is down
22 as deep as 50, 60 foot. Let me ask the drawers, the
23 experts. How far down would you say that is? Do you
24 happen to recall how deep that groundwater
25 contamination is; just in that one area?
A. WILLIAM ROBERTS, JR. & ASSOCIATES
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11
1 MS. CANOVA: I think your estimate is
2 close enough.
3 MR. TANNER: Okay. What we actually have
4 at this site is a couple of things going on with
5 regards to the soil. I hope to shed some light on
6 this issue. We have/ as we mentioned before, clay
7 here. And this particular site, the clay layer
8 terminates at about -- this is land surface. We've
9 got this clay layer down, I think it starts about 12
10 foot more or less, and it terminates down -- it may
11 run about seven to ten foot.
12 And we have another layer of soil down
13 here. And then below that, even deeper, another
.14 layer of clay. What is happening at the site is
15 we've got not only the contamination, which is down
16 and is perched on top of this clay layer, we also
17 have at one point on the site a hole. And the clay
18 begins itself where initial contamination has come --
19 and contamination has come and now it's down into
20 this deeper layer as well.
21 MS. JOHNSON: How fast is that moving,
22 can you tell, the plume? Is it getting bigger? Is
23 it moving in one direction?
24 MR. TANNER: Well, we can tell that it is
25 moving simply by the earlier figure where you can
A. WILLIAM ROBERTS, JR. & ASSOCIATES
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12
1 look at the groundwater. If this was the original
2 source, it spread at least this far. We can tell
3 that from the wells that we have monitoring it.
4 In summation, what we have is both soil
5 contamination and groundwater contamination at this
6 site. Are there any questions, at least on this
7 point, before we move on and talk about what we
8 looked at in cleaning up the site?
9 UNIDENTIFIED SPEAKER: Quick question.
.10 MR. TANNER: Yes.
11 UNIDENTIFIED SPEAKER: Is there
12 separation between the soil contamination and the
13 groundwater based on PAHs and BTEX? Is one more
14 permeable than the other?
15 MR. TANNER: Well, in general, the BTEXs
16 tend to enter into the groundwater a little more
17 readily than the PAHs, but we do have both. On this
18 drawing here/ I believe this is actually an outline
19 of the/ I think, the benzene.
20 If you were to look at the PAH
21 contamination, because it doesn't absorb in the water
22 quite as readily as the BTEX, we've got PAH; it's
23 looking something like -- little different
24 concentrations -- something like this, and you may
25 have a little bit right there, much like that.
A. WILLIAM ROBERTS, JR. & ASSOCIATES
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13
1 THE COURT REPORTER: Please state your
2 name.
3 MR. CAMPBELL: My name is Paul Campbell,
4 I'm with the College of Charleston graduate program.
5 So a majority of the groundwater contamination is
6 going to be cleaned up?
7 MR. TANNER: Yes.
""^-.^^
\ -/
8 MR. CAMPBELL: BTEXs are as much as 50
9 feet?
10 MR. TANNER: I would say that the
11 majority of the size of the plume is certainly BTEX;
12 at least to the further extent. BTEX has migrated
13 faster and further than PAHs.
14 Yes.
15 MR. RICHTER: Rick Richter, Trident EQC
16 here in Charleston with DHEC. How is the seepage on
17 Charlotte Street going to fit into the overall
18 picture? Have you-all been able to tie that in yet?
19 Do you have seepage going into the harbor down there?
20 MR. TANNER: Yes, we have. That's one
21 thing that I will touch on. I will go ahead and do
22 that now. About six months ago, we found, to give
23 you a reference point -- this is, again, where the
24 old gas plant and current site of the electrical
25 substation is now. This is the Cooper River.
A. WILLIAM ROBERTS, JR. & ASSOCIATES
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14
1 As I was saying earlier, about six months
2 ago we noticed that there was a sheen here on the
3 river. We went back and traced the source to a
4. seepage, an outbreak. Along the shoreline here were
5 a series of hairline cracks. It's probably not the
6 correct technical term; it's close enough.
7 Throughout these cracks, coal tar was
8 found discharging. The majority of it appears to be
9 heavier than water; therefore, it's flowing down into
10 the sediment. However, a portion of it is floating
11 on the surface and can be observed as a sheen on the
12 water itself.
13 Now, we thought at the time that we had,
14 at least, most of the contamination identified. I'm
15 beginning to feel like Brier Rabbit in a tar patch.
16 What we discovered was there's some additional source
17 area that is feeding these seeps that appears to be
18 coming from the gas holder itself. And this issue,
19 which will not be covered as part of the proposed
20 plan, is under investigation.
21 And when I say under investigation, I
22 have been working with the gas company, and they have
23 agreed to go in and take some type of interim action,
24 stop this flow while we go on with the normal
25 process of the rest of the site itself.
A. WILLIAM ROBERTS, JR. & ASSOCIATES
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15
1 MS. JOHNSON: Is that green line in front
2 of the Columbus Street terminal site? Is that where
3 that is?
4 MR. TANNER: Are you talking about the
5 Ports Authority terminal? Is that the same?
6 MS. JOHNSON: Yes.
7 MR. TANNER: Yes, it is. Actually, the
8 large cement structures themselves would start
9 about -- this is not, of course, to scale. This is
10 the street, and Charlotte Street terminates here.
11 The seeps are right along this area, feeding out here
12 and the Ports Authority, the actual large pier
13 itself, starts here.
14 MS. JOHNSON: Is that why Charlotte
15 Street is closed off now at that point?
16 UNIDENTIFIED SPEAKER: No, that's
17 construction.
18 MR. TANNER: Yes, I believe they are
19 actually storing -- there is a current, I think,
20 fence and has been a fence all along here. It's
21 actually preventing access to that, but recently due
22 to the construction activities you mentioned, they
23 closed this off and are storing equipment back there
24 at this time. I will just leave that up there so we
25 can continue to reference it.
A. WILLIAM ROBERTS, JR. & ASSOCIATES
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16
1 Let's talk a little bit about -- we've
2 covered the history, the contamination and the risk.
3 What we do once we generate all these sampling data
4 is go back and say, well, what kind of threat is this
5 to the public? What does it mean? What do all these
6 numbers mean?
7 We take the numbers and through
8 mathematical modeling we determine, statistically,
9 what the risk is to people living in the area. In
10 this site, we looked at a couple of different
11 scenarios. We said, well, if you have people living
12 on the site such as Dockside Condominiums and
13 Ansonborough Homes, there were children out there
14 playing, would there be a risk to them?
15 We also looked at commercial construction
16 workers. We said, well, if you've got this area
17 covered in commercial property and you have
18 construction workers out there dealing in soil every
19 day, what is the actual risk to them? And we also
20 looked at the trespassers. What is the likelihood of
21 people just wandering up and coming in contact with
22 the soil? What's the risk to them?
23 And what we found is, in looking at all
24 of those possible situations, the more probable use
25 of this land was commercial. And we said, given
A. WILLIAM ROBERTS, JR. & ASSOCIATES
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17
1 that, what is the risk to the construction worker
2 because he is the most likely person that's going to
3 come into contact with contaminated soils? So what
4 we did is crunch the numbers on that and came up with
5 these areas here.
6 Let me see if I can put this on. What we
7 found out after all our foo.t and ticking was that
8 these areas here — and here you can see them
9 slightly shaded; and if you have the flyer that was
10 sent in the mail, the same figure that's on that back
11 page -- you will see that these areas are the ones
12 that posed the greatest risk on the site. Now, this
13 is with regards to soil. We will get into
14 groundwater in a minute. Any questions?
15 UNIDENTIFIED SPEAKER: Which ones are you
16 talking about, soil?
17 MR. TANNER: The soils, yes. Let me get
18 this up a little bit higher. See the shaded area
19 here?
20 UNIDENTIFIED SPEAKER: Looks just like in
21 the pamphlet.
22 MR. TANNER: It's here and here.
23 UNIDENTIFIED SPEAKER: Thank you.
24 MR. TANNER: And for groundwater, as
25 I've shown you earlier on this figure, the
A. WILLIAM ROBERTS, JR. & ASSOCIATES
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18
1 contaminated groundwater that will have to be
2 addressed is essentially something like this here.
3 MS. JOHNSON: Is this including the
4 groundwater contamination map in the handout? Can
5 you print it up? It's a nice companion piece to this
6 soil. That's really nice.
7 MR. TANNER: Yes, I can do that. Would
8 you like a particular copy of that?
9 MS. JOHNSON: Yes, this one; at your
10 convenience. Yes, that would be nice.
11 MR. TANNER: Let's quickly review;
12 history, contamination, risk, proposed cleanup
13 methods .
14 Are there any questions today before I
15 move into those areas?
16 MS. JOHNSON: Groundwater risk; a little
17 bit more about that. Is there anything more to say
18 about that, let's put it that way?
19 MR. TANNER: Well, we actually took the
20 numbers and ran a risk assessment on the groundwater,
21 and no surprise, we found out that the groundwater
22 does pose a risk. For cleanup numbers -- well, I'll
23 get into cleanup numbers in a bit. Yes, to answer
24 your question. Yes, the groundwater numbers pose a
25 risk.
A. WILLIAM ROBERTS, JR. & ASSOCIATES
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19
1 MS. JOHNSON: I wi'll probably ask a
2 definite question sometime later on, how is that risk
3 modified by the tendency to flood in the area, lot of
4 standing water certain times of the year. Does that
5 change the risk at all, make it a greater risk at
6 certain times during the flooding period, et cetera?
7 MR. TANNER: What it would tend to do is
8 actually flush the contaminated groundwater out of
9 the more concentrated areas into lower concentrated
10 areas. Use this figure here. Anytime you have rain
11 or flooding, it would percolate down through the soil
12 and increase the amount of water coming into contact
13 with the contaminated material. And the groundwater
14 table would actually rise.
15 Now, this area is a little more
16 complicated than that because you've got tidal.
17 That's a very simplistic picture.
18 On most of these sites, Superfund sites
19 in general, we usually have a wide choice of cleanup
20 options available to us. This site is a little
21 unique. In fact, the group of PAHs are unique in
22 that the treatment options we have available to us
23 are very limited. These compounds are very
24 persistent, very hard to neutralize or destroy
25 chemically, and there's just not a lot of options,
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1 again, that we can do with them when they are in the
2 soil.
3 The options that we did look into for
4 this site include a couple of things. We looked at
5 capping it; that is coming back here and placing some
6 type of permeable cap over the material itself. As
7 you can imagine, it might be somewhat effective for
8 the portion of the soil above the groundwater but
9 doesn't do much for the portion below it.
10 We also looked at bioremediation. That's
11 an issue that's been getting more and more press
12 lately. Bioremediation is where we actually take
13 bugs, or bacteria we should call them, expose them to
14 the soil, and if conditions are favorable to those
15 bugs, they will actually help to break down the
16 contaminants.
17 We looked at thermal destruction/ which
18 is a fancy term for burning the soil. And we looked
19 at landfill; that is literally excavating the soil,
20 getting it up from this area and putting it in a
21 containerized cell to control the landfill.
22 With regards to the groundwater portion
23 of this, we looked at several different choices; one
24 we looked at, deed restrictions, which is very common
25 to do; simply attach deeds to the land saying don't
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1 drink the water.
2 We looked at phytoremediation. Again,
3 that's a relatively new technology where plants are
4 used to actually help treat the groundwater by
5 infiltration. Roots come down, and through several
6 different means, are actually able to provide some
7 effect in treating this groundwater.
8 There's a couple different ways it works.
9 The plants in some instances with some contamination
.10 are able to actually absorb and concentrate the
11 contamination into the root system and the plant
12 bodies themselves.
13 There's another mechanism where you also
14 have bacteria that tends to colonize the ground roots
15 themselves. In some instances, that's very effective
16 on contaminants. It can be very effective if the
17 bugs do tend to like that contamination and can
18 digest it; again, a very simplistic, crude
19 explanation of phytoremediation.
20 We looked at natural attenuation; that is
21 what would happen if we left the site as is and what
22 would happen to it. Under some very controlled
23 conditions, natural attenuation can be an effective
24 remedy. Again, there are some factors that really
25 have to be balanced very carefully in order for it to
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1 work.
2 What else did we look at? We looked at,
3 again, bioremediation, just like soil except this
4 time it will be groundwater; looking for bugs that
5 can actually be introduced to the groundwater and
6 that live in the soil or can live in this particular
7 type of soil and might potentially be effective in
8 breaking down a contamination.
9 We also looked at a very standard
10 practice of pump and treat where a series of recovery
11 wells are installed; this being the well and slots in
12 the well itself. Groundwater enters the well, is
13 pumped up and on to some type of treatment process --
14 it's a filtering mechanism — and then sent to
15 usually the sewer or, depending upon how clean it is,
16 can even be introduced back into the streams.
17 Questions, comments about the options?
18 Yes.
19 MS. OLDSTON: Diane Oldston with the
20 environmental science program, College of Charleston.
21 I have a question. Bioremediation, I understand, is
22 a very quick multiplication of bacteria numbers that
23 might be effective in breaking down the network of
24 contamination very quickly but if bioremediation is a
25 very lengthy process where the root systems have to
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1 take . . .
2 MR. TANNER: Yes, it is. It actually
3 involves several seasons for a particular root to
4 establish itself, and, therefore, it's probably not
5 as quick and a little more difficult to monitor the
6 effectiveness because we can't go out today.
7 MS. OLDSTON: What is the time line the
8 EPA is focusing on for the treatment? Is there some
9 sort of time line in which you are hoping to
10 remediate?
11 MR. TANNER: As far as actually
12 implementing a strategy, yes, we will have that
13 implemented within the next ten to 12 months. But
14 because, in this instance I am using the one for
15 groundwater, you can't get down there using the
16 existing technology that we have effectively enough
17 to have the entire area cleaned up in six to 12 or
18 eight months, whatever interval that we are choosing,
19 say, for the soils. What we typically do, we come
20 in, we can treat the soils relatively quickly.
21 The groundwater is another issue.
22 Depending upon the technology, it takes much longer.
23 It may take a period of years before we can make a
24 dent in the contamination level. That's one area
25 where technology is really lagging behind,
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1 environmentally speaking. Once contamination gets in
2 the groundwater, it's very difficult to get to and to
3 treat. It can be done, but it's very expensive.
4 MS. JOHNSON: I have another question
5 about the groundwater remediation processes. How
6 does the use configuration of these properties affect
7 the selective or the optimum method; being one method
8 might be very good for a forest or a meadow but this
9 is not?
10 . MR. TANNER: Yes, it does. The actual
11 use of the property comes into play and actually at
12 two points: One is when we are trying to determine
13 how clean should we clean this up to; that is^, what
14 standard should we use, commercial standard, should
15 we use residential standards; and two is, when we've
16 gotten past that and decided to actually implement
17 the remedy, how is the remedy going to work within
18 the existing conditions.
19 As we can see out here, the area being by
20 and large commercial where we are certainly limited
21 to options to put in place to do that. So it plays a
22 very good part. Yes.
23 MS. PERRY: Lorraine Perry from MESNE
24 Register. I have a question. You keep saying that
25 this property is going to be commercial. My
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1 understanding is that a lot of this property,
2 especially where the Ansonborough Homes was, is being
3 considered for a park. So that would seem to me that
4. the level of cleanup would be different. And if you
5 look at what the city plans for most of the area,
6 where Ansonborough is, in back of Harris Teeter, in
7 that whole area, if the Ports Authority does leave,
8 is to combine it to be partially residential and
9 partially commercial.
10 MR. TANNER: Let's look at the areas
11 where we have contamination. Yes, you do bring up a
12 good point. There are areas out there now that are
13 residential; Dockside Condominiums is one of J:hem.
14 When we looked at the risk and we were
15 assessing the risk, we knew that the electrical
16 substation here was going to be -- actually,
17 technically would be industrial, but from a risk
18 standpoint, it's the same thing as commercial.
19 There's usually no difference.
20 In this piece of property here we knew
21 there was going to be industrial or commercial. We
22 also knew that with regards to the Park Service
23 property, which is here, that it was also going to be
24 commercial or industrial.
25 MS. PERRY: How can that be commercial
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1 when you are talking about an aquarium, talking about
2 bringing in umpteen trillion kids every day? I mean,
3 I realize it's commercial because it's going to be a
4 business but you closed this one area next to the
5 gas, SCE&G, where they are going to put a parking
6 garage where the kids play soccer because they
7 couldn't play there because it was too contaminated
8 so you closed them down; just like they closed the
9 Ansonborough Homes down because it was contaminated.
10 And now the mayor says we are going to have a
11 symphony hall on there surrounded by parks for the
12 children.
13 MR. TANNER: Okay. I think I can^answer
14 your question.
15 MS. PERRY: Good.
16 MR. TANNER: When we went in and did the
17 risk assessment, what we did essentially, we measured
18 the existing soil concentration; not only at the
19 surface, we also measured them down deeper as well.
20 What we found was that in these areas, in this group
21 of samples here, that there was no -- well, I should
22 say that, in general, none of the soil is pristine;
23 it all has levels of PAHs. Again, what we found, it
24 seems to be concentrated in the area here.
25 Now, we did find PAHs in this area in the
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1 surface soils, but it was not at levels creating an
2 unacceptable risk; that is, children could live here,
3 they could play here, they could go out and eat the
4 dirt if they want to in this area, and it is safe.
5 What we di'd find out is that was not the case for the
6 areas here.
7 Now, going back to your question of how
8 do you say, like, for instance —
9 MS. PERRY: The aquarium.
10 MR. TANNER: Okay, the aquarium here. I
11 am losing my train of thought.
12 What is going to happen -and the reason
13 why we are calling this commercial at the aquarium
14 is, when we did our first round of sampling, if this
15 was the surface soil, we knew that -- well, it's
16 almost a moot point because these areas here from a
17 surface standpoint are also safe; that is, kids can
18 play on this; it's not a problem.
19 Going out a little bit further, even if
20 it was, this soil will actually be covered, I think,
21 with a three-foot layer of additional fill material
22 for the landscaping. But I think it's a moot point
23 because, again, these soils do not exceed residential
24 standards.
25 I believe the only case where that
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1 actually occurred was on the substation itself. I
2 have some reports here I can quickly check —
3 hopefully, I can quickly check -- to see if they
4 exceeded in this area as well. I don't believe they
5 did; I think the only place they actually posed a
6 threat, surface soil samples, was the actual
7 electrical station itself.
8 Does that make sense?
9 MS. PERRY: It makes sense now. It was a
10 different story at the time they changed it, when
11 they tore down the homes, threw all those people out
12 because it was too contaminated. Since.the city
13 bought the property, now it's no longer contaminated.
14 MR. TANNER: As I understand it, the
15 decision to move the people out of that Ansonborough
16 Homes was based on a couple of factors: Potential
17 threat of contamination as well as substandard
18 building practices. The homes were in bad shape;
19 there was flooding continually. I think it was a
20 little bit of both of those factors together
21 involved, but I am speaking out of school and
22 speaking on behalf of HUD.
23 MS. PERRY: Okay.
24 MR. TANNER: Other questions?
25 MR. WELLS: I am Robert Wells,
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1 Preservation Society. I understand the sites are
2 contaminated. Are there any opportunities to do
3 archeological work? These are sites from the 1800s.
4 Is there any opportunity at all to monitor as you do
5 the cleanup; can archeologists work in that
6 environment or have any input?
7 MR. TANNER: I .believe that is one of the
8 requirements of doing actual cleanup actions. I will
9 have to go back and check that. We did a couple of
10 archeological digs across these areas here. I
11 believe there were two trenches; here and here. We
12 actually have someone from the Park Service; if you
13 can comment on that, John, from the Park Service;
14 comment on that archeological dig.
15 UNIDENTIFIED SPEAKER: As part of our
16 development, we are a federal agency, we are required
17 to go through what is referred to as the Wother
18 Process. (Phonetic) We did archeological work on
19 our sites. The two excavations that Terry alluded to
20 were completed back in, I believe it was 1988. We
21 found no remains of any significant structures
22 there. And that determination was made in accordance
23 with the federal guidelines as well as the state's
24 preservation office. The only thing that we found on
25 the site that we did do a site documentation for was
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1 the turpentine building located down in the very
2 southwest corner that was remnants of that particular
3 site. It wasn't found as being worthy for any
4 further exploration in that area.
5 MR. TANNER: Thanks, John.
6 Going back to your question, I think what
7 you are asking, when we come in and do the actual
8 soil removal, will we? I don't know. I will check.
9 MR. WELLS: The sites have been occupied
10 since 1867; there may be some very interesting things
11 in the soil we would like to see.
12 MR. TANNER: If we were to base it on - -
13 well, we have an additional sampling grid thaj: goes
14 something like this in the area where we came in and
15 did some additional sampling; as you can see, we
16 really peppered the site. It doesn't mean it's
17 loaded with artifacts; haven't found anything yet.
18 In answer to your question, I don't know. I will
19 check.
20 MR. WELLS: How would we follow through
21 with that? Can you give me a call?
22 MR. TANNER: Yes, I will exchange phone
23 calls.
24 MR. WELLS: At the end of the meeting.
25 MR. TANNER: And we will follow up.
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1 MR. WELLS: Thank you.
2 MS. JOHNSON: Before we go off on another
3 topic, I found the things that you threw in in an ad
4 hoc way very interesting. In addition to the map
5 showing the groundwater contamination, it would be
6 nice to see the entire site with some markings on it
7 as to not only where the contamination is found but
8 those sites that are not contaminated so that the
9 whole Calhoun Park picture -- these are not, these
10 are not, these are, these are — all in one place,
11 that would be nice because it's the information we
12 came here to talk about.
13 MR. TANNER: I agree. These drawings are
14 very piecemeal. Prior to the conclusion, I will get
15 some type of figure that shows the study area in a
16 much more presentable manner rather than what we are
17 seeing now because, obviously, the site is now
18 expanding off of here.
19 MS. JOHNSON: That's right. Thank you.
20 MR. TANNER: Administratively what we
21 will do as part of what we are required by law is,
22 essentially, make sure that we keep you folks
23 up-to-date on what we do know and what we are
24 proposing for those areas that we do know about.
25 I will digress a little bit before I get
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1 to the last method. As part of EPAs process, we work
2 with the community. What we do is we go through an
3 outline much like this, come to the public and say,
4 this is the contamination, this is what we propose to
5 do .
6 Unless it is an emergency action, we tend
7 to go through steps like that and make sure that you
8 folks stay involved; you know what we are doing. We
9 are not out there doing something that you don't know
10 about.
11 Let's go into this last item and then we
12 will just open up the meeting to general cojnments or
13 feedback or whatever. In looking at all of 'the
14 possible options, both the cleanup of soils and the
15 groundwater and something which I've neglected to
16 mention, which is this dark pool of stuff that's
17 sitting down here that is in these handouts. What we
18 are proposing to do is three things.
19 With regards to the soils, after
20 considering the entire universe of options, we are
21 proposing to excavate the soils, take them to a
22 controlled landfill.
23 With regards to the contaminated
24 groundwater, we are actually trying a two-fold
25 approach: One is the standard pump and treat. We
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1 are also going to work as best we can with
2 phytoremediation in with that. We are going to use
3 essentially the pump and treat as the frontline
4 treatment.
5 MS. JOHNSON: Is that source removal?
6 Pump and treat means source removal?
7 MR. TANNER: No, ma'am. That would
8 actually be another issue. Irwill mention that next.
9 That's a third thing.
10 With regard to this dissolved phase of
.11 the groundwater, it will essentially be a two-fold
12 approach. We will use pump and treat until we can
13 get phytoremediation established underground.
14 Hopefully, what we would like to do is, if we can get
15 out there and show that, yes, indeed, the tree roots
16 are coming down and they are beginning to destroy the
17 contamination, we can back off this additional pump
18 and treat mode. At that time, we will come back to
19 the public and say, this is what we found; it works
20 or it doesn't work. This is what we are going to
21 continue to do.
22 Now, the third item is the dark liquid
23 here. This is actual saturated contamination liquid
24 pools of these PAHs, this coal tar and BTEX as well.
25 And what we are going to do on these areas, because
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1 it's so concentrated, get right to it; we are going
2 to go in with a well; literally seep it right down in
3 this area.
4 So the opening here is actually
5 collecting this product. It's more of a way where we
6 can pump on this and pump and pump, and it's not
7 going to be nearly as effective as a combination of
8 going in and actually going after the actual source
9 itself. That in a nutshell is the proposed plan.
10 UNIDENTIFIED SPEAKER: How big is this
11 excavation? Are we just going to see this massive
12 excavation ten or 15 feet down and planting trees in
13 it?
14 MR. TANNER: What we are going to do, you
15 will be seeing this excavation rather soon. We are
16 actually going down from land surface. We are going
17 down to about three foot, which in this case is
18 virtually right on top of the water table.
19 We are going to excavate down from the
20 land surface, down to right at three foot on these
21 areas that you will see here, here. Let me put up
22 the areas it's in. These have been merged; is that
23 correct? It's more like one or something like that.
24 There's another area here.
25 Our concept is go after the highly
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1 contaminated concentrated areas.
2 MR. COHEN: I have a question for you.
3 My name is Allen Cohen. You seem to focus mainly on
4 the rehab. Do you have any free product here? Is
5 there free product versus you focus where there's
6 apparently some contaminants in the aqueous phase?
7 Is there a second phase on top of the water table?
8 Do you have any gasoline or gasoline type products?
9 MR. TANNER: At one point in the
10 investigation, we did notice some type of product,
11 and it would probably be -- I will use this.
12 A little background on the gentleman's
13 question. Most chemicals are either heavier than.
14 water or lighter than water. The ones that are
.15 heavier, (sic) obviously, float and form the NAPLs
16 that we talked about. The BTEXs that we also have at
17 the site tend to be lighter than groundwater and they
18 float. What we've seen based on this particular site
19 history is the sinkers tend to be in this area here.
20 Now, at one point we did observe some
21 floaters out in one of these wells, I think it was
22 MW12. We've since gone back, at least once if not
23 twice, and I have not seen any floaters since then.
24 Now, does that mean that they were there
25 because of one freak incident? I don't know; we will
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1 continue to monitor this to make sure they don't pop
2 back up, if there is not some other little pocket
3 source area out here that we are not seeing.
4 MR. COHEN: Are you getting any
5 downgrading of those wells? I don't know which way
6 the water is flowing in that direction.
7 MR. TANNER: Groundwater is flowing this
8 way, directly towards the river. And your question
9 was ?
10 MR. COHEN: I was just wondering, in
11 response to your answer, do you think it could have
12 migrated past that.well? Do you have any wells like
13 that well more than you once did?
14 MR. TANNER: Yes. The question is, is
15 the contamination migrating past this last well. On
16 some of the samples, yes. On some of the sampling,
17 yes; on others, no. So what that tells us, going
18 back to this plume, is that depending upon, I guess,
19 the site conditions, at any given time, the season
20 probably has as much effect on this as anything.
21 As you can see, this is a -- I will try
22 to enhance it a little bit. We've got 100 micrograms
23 per liter. I shouldn't do that; I don't know what it
24 is. You can see it ends right here.
25 I guess beyond here we really don't know.
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1 We came back in and sampled those particular wells
2 again, and we weren't getting -- well, the
3 concentrations were different. They weren't
4 extending all the way out. But there's a good chance
5 we could come back in two months again, resample, and
6 it will look just like this.
7 Groundwater is in a very dynamic state; a
8 lot of things going on. Obviously, what we hope to
9 do is, based on our actions taken, to stop this plume
10 from discharging into the river.
11 That's the three big items. Now, at this
12 point, this is going to end the formalized
13 presentation. Let's open it up to general questions.
14 I am sure there's a load of things I might have
15 glossed over or whatever. Question?
16 MR. CAMPBELL: You might want to put the
17 slide back up of the recovery well sites. My name
18 again is Paul Campbell, I am with the College of
19 Charleston. The way in which the screen is set up
20 with the proposed recovery wells, we've got two in
21 the back that kind of look like little linebackers.
22 Is there a purpose? Is there a preferential back
23 way?
24 MR. TANNER: Yes, we have. This other
25 groundwater slide, this slide, is easier to address
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1 the general concept of this issue here. These would
2 be crude estimates. The points might actually work
3 out to be something like this, this and this. Who
4 knows?
5 We will do all our groundwater models
6 that will tell us where we should best put them.
7 Maybe it works out to be something like that; again,
8 just an estimate; something to get the idea across
9 that something is going on here, again, in the same
10 place as we noted as those floaters before.
11 MR. CAMPBELL: We didn't expect the
12 screen of wells that you've got, the ones that are
13 boxed, those two that are set back, to collect
14 groundwater plume and perhaps capture those; those
15 two further back.
16 MR. TANNER: Yes, that is our intent.
17 What we are running up against is, if you get too
18 close to the river, you start recovering water from
19 this way --
20 MR. CAMPBELL: Right.
21 MR. TANNER: -- rather than that way. We
22 want to avoid pumping the Cooper River and cleaning
23 it up although that may not necessarily be a bad
24 idea. I don't think it would be appropriate to ask
25 the gas company to do that in this case.
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1 UNIDENTIFIED SPEAKER: That would be a
2 big project.
3 MR. CAMPBELL: What's the life cycle on
4 these? What's the estimated time it's going to take
5 to do the groundwater cleanup work?
6 ' MR. TANNER: We don't know. We will
7 install the system probably within the next ten to 12
8 months. As far as how the aquifers is going to
9 respond, they all respond a little bit differently.
10 MR. CAMPBELL: Was that included in the
11 estimate cost and the options?
12 MR. TANNER: Yes, it was. I believe for
13 estimation purposes; the cost was pu.t out at 30 years
14 of operation.
15 MR. CAMPBELL: That's a lot of work.
16 MS. JOHNSON: That's kind of a leading
17 question. You just used the word aquifer the first
18 time. You just said it was a lot of work. Talk
19 about the amount of water; talk about the direction
20 of the flow. Where is it coming from? What is the
21 water pressure? What is the velocity of the flow
22 through there?
23 MR. TANNER: I am not sure I can answer
24 all of your questions. I will try to answer the ones
25 that I can and see if we can get you additional
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1 brainpower from the room. Groundwater at this site
2 tends to flow as in throughout all the peninsula. It
3 tends to flow from inland out towards the river.
4 That occurs through a variety of actions.
5 On this particular piece of property,
6 groundwater is flowing this way. Judy, do you happen
7 to remember any of those specifics about flow rates?
8 MS. CANOVA: I think we were looking
9 around 100 feet per year. We have to look it up;
10 that was the general idea;.100 feet per year.
11 MR. TANNER: Keep in mind that what this
12 means, although the groundwater may be flowing at
13 100 foot per year -- there's my scale -- that
14 doesn't necessarily mean that the contamination is
15 keeping up with that.
16 What happens is the contamination tends
17 to attract the soil. There's a lot of factors going
18 on. It's not flowing, obviously, 200 feet per year.
19 If it were, this site has been in operation or did
20 operate over a one-hundred-year period, this would be
21 washed clean.
22 I can get you specifics on those numbers.
23 I just don't have them.
24 MS. JOHNSON: Sure. Thank you. Another
25 question; the brochure for this meeting said that you
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1 were in the process of selecting remediation methods
2 and yet you are kind of talking about you have
3 already selected the remediation method.
4 MR. TANNER: What we've done is that --
5 to answer your question/ what we actually do during
6 this meeting is propose cleanup methods. I may have
7 used those two words interchangeably; if I did, my
8 apology.
9 MS. JOHNSON: Looking at the chart, which
10 one is closest to the proposal?
11 MR. TANNER: Talking about the
12 groundwater?
13 MS. JOHNSON: Yeah. Which one is
14 closest to your preference right now, put it that
15 way? What seems to you to be the best?
16 MR. TANNER: The one that would be the
17 closest would be the one just before the last one,
18 the source removal, phytoremediation, the grout
19 curtain, which has been eliminated.
20 MS. JOHNSON: Why was that eliminated?
21 UNIDENTIFIED SPEAKER: More work.
22 MR. TANNER: There wasn't any great
23 benefit from having it in there. It is a rather
24 expensive part of that package.
25 What actually happens when we get a study
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1 in that evaluates all these options is, the
2 responsible parties, potentially responsible parties,
3 send us a document that says, here is what we think
4 are some reasonable options.
5 And we all sit down, and we look at those
6 options and we evaluate it from an engineering
7 standpoint and say, well, this one looks reasonable
8 from this perspective, but it has some shortcomings
9 here.
10 And on the chart it essentially lists out
11 the way we evaluate. We try to do them as fair and
12 as objectively as humanly possible.
13 MS. McGOWEN: Is it cost effective
14 analysis and whether financially it'll be feasible to
15 actually get it done and do the job?
16 MR. TANNER: Yes. The cost of it is part
17 of it as well.
18 MS. JOHNSON: Four and 5 look the same.
19 MR. TANNER: My apologies, yes. The one
20 that we are implementing is actually the last one.
21 MS. JOHNSON: As far as the soil cleanup
22 option, I think you said the landfill, off-site
23 landfill, was the preferred?
24 MR. TANNER: Right.
25 MS. JOHNSON: Where are there landfills
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1 that would take stuff like this? Are there any
2 places ?
3 UNIDENTIFIED SPEAKER: Laidlaw.
4 MR. TANNER: Laidlaw is still operating.
5 MS. JOHNSON: You are naming a company.
6 I am saying where.
7 MR. RICHTER: Some of that goes to
8 Chambers Oakridge. I'm a hazardous waste consultant
9 for DHEC.
10 MS. JOHNSON: For the project?
11 MR. RICHTER: For this district. We
12 oversee the disposal of soil. Some of that soil
13 could go to Chambers Oakridge. It doesn't exhibit
14 the characteristics of a hazardous waste. It's not a
15 listed waste. In some cases it doesn't meet the
16 characteristics. So it can go to a subtitle D
17 landfill. A lot of it probably has already gone
18 there. That landfill has check control.
19 MS. McGOWEN: Oakridge where?
20 MR. RICHTER: Chambers Oakridge up in
21 Dorchester County.
22 MR. TANNER: What we'll actually do is
23 characterize the waste. Actually we've done some
24 preremoval characterization of the waste.
25 Because of the expense involved in
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1 sending it to a, quote, unquote — I am trying to
2 avoid all the nomenclature and buzz words in the
3 environmental group. There's a difference between
4 contaminated waste versus RCRA contaminated waste.
5- They have to be handled a little bit differently.
6 The waste that is a RCRA contaminated waste has to be
7 sent to a special facility.
8 MS. JOHNSON: What was the word again?
9 MR. TANNER: RCRA. It's Resource
10 Conservation something.
11 MS. McGOWEN: Resource Conservation.
12 MS. JOHNSON: I would like the person in
13 charge here to answer the question. Go ahead.
14 MR. TANNER: Okay. Let me go back and
15 get a global view of what we are doing with the
16 waste. The waste, obviously, is not all contaminated
17 in a uniform manner. There are areas that are very
18 hot cleanup goals as well as there are other areas
19 that are not as hot as those but still exceed the
20 cleanup criteria. You might have some that are --
21 and I don't know the actual RCRA numbers, but we will
22 when we actually put it in these disposal facilities.
23 You might have some of these areas that are 100,000
24 parts per million or greater in these little pockets
25 but what you will find is it's not all uniformly
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1 contaminated.
2 What we try to do for cost purposes is to
3 say, where can we send this waste if we don't all
4 have to send it to a place that charges us $50 a ton.
5 And this is one area of waste disposal that is also
6 regulated by the Environmental Protection Agency as
7 well as DHEC.
8 We say, where can we send the waste. Do
9 we all have to send it to a subtitle D facility or
10 can we send a portion of it to a subtitle C facility?
11 They both offer containerized storage; one just
12 offers a much more higher level because the waste in
13 turn is more hazardous. I'm hesitant to use the term
14 more hazardous because it's all hazardous. We get in
15 there with little subtleties of what we are doing
16 here; a disposal that is cost effective.
17 MS. JOHNSON: Now we are at the point
18 where I can ask the question again: Where are the
19 sites that can take, for example, class C and class D
20 contaminants?
21 MR. TANNER: Pinewood, South Carolina is
22 subtitle C.
23 MS. JOHNSON: Thank you.
24 MR. RICHTER: Chambers Oakridge in
25 Dorchester County is subtitle D. They got a line.
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MS. JOHNSON: Where is that, please?
MR. RICHTER: Dorchester County, South
Carolina .
MS. JOHNSON: You used a name, Chambers?
MR.. RICHTER: Oakridge.
MS. JOHNSON: Chambers Oakridge. That's
a place name, Chambers Oakridge?
MR. RICHTER: Uh-huh.
MR. TANNER: If it's any comfort --
MS. JOHNSON: That's B you said?
MR. RICHTER: No, that's a subtitle D.
MR. TANNER: They have smart people on --
like this gentleman -- the project so people like me
aren't making the decision. We can say, these are
the levels, where can we dispose of them?
MR. RICHTER: Can I ask a question before
we quit?
MR. TANNER: Yes.
MR. RICHTER: The future parking garage
fits right along the edge of the contaminated soils
that's going to be excavated. Is that drawn like
that because the soil is going to be excavated before
the future parking garage is built, or does it
actually run straight down in a line like that?
MR. TANNER: It's not exactly a.straight
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1 line, but the garage looks something like this. And
2 it will be excavated prior to the garage going in
3 place. The garage itself is -- I don't know --
4 something like this. There's about a 20-foot
5 quarter, I believe, in this area here where we are
6 going to be moving that.
7 UNIDENTIFIED SPEAKER: That is actually
8 under the parking garage where you are going to move
9 it?
10 MR. TANNER: It's going to be close, it's
11 not exactly under. The removal will precede the
12 construction of the garage itself. We may be out
13 there digging around and find a little pocket righ.t
14 here and come out that far; something like that. But
15 after we are done with that, the garage will come
16 back and cover this. It would probably have been a
17 more descriptive figure if this wasn't here, if
18 that's causing some confusion.
19 MS. JOHNSON: According to the City of
20 Charleston, the size of the parking garage -- this
21 was public information at a zoning meeting ten days
22 ago -- the configuration of the garage was related to
23 your remediation plans, if that's what you said.
24 Is there any chance that with some
25 possible change in the remediation plan that will
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1 impact it? I am not asking an alarming question with
2 everything still in a developmental stage here.
3 Is there any chance that there may be
4 other changes in the use of that area -- the size of
5 the garage, how far it extends into the area that's
6 requiring remediation, in the whole configuration?
7 Is there any chance that there will be further
8 modifications of the planned construction, do you
9 think? I am asking a what do you think question.
10 MR. TANNER: Let me see if I understand
11 your question.
12 MS. JOHNSON: Sure.
13 MR. TANNER: Would changes to the garage
14 blueprint itself affect--
15 MS. JOHNSON: No, the remediation plans;
16 are there additional further developed remediation
17 plans? Will they impact the garage site, the
18 configuration of the site, do you think?
19 MR. TANNER: I don't think so.
20 MS. JOHNSON: You think you are far
21 enough along so that you feel sure? You have enough
22 area for pumping and digging wells and the various
23 methods, enough space to do all that? I guess that's
24 the question. Do you have enough space to do all
25 those things?
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1 MR. TANNER: Yes, we do. It's been a
2 juggling act, working with all the different agencies
3 to make sure that we can clean the site up, put it
4 back into productive use. Even if things change
5. again, we will modify whatever we are doing to a
6 limited amount; obviously, not going to go in and
7 completely change the remedy because of something and
8 then go out and do it.
9 MR. ZELLER: Along that line, actual
10 cleanup numbers that are issued, maybe to help answer
11 the question, if the number is 50 for PAHs, all soil
12 that is greater than 50 would be excavated, just for
13 an example.
14 So as Terry mentioned, had they estimated
15 a certain amount of volume above 50, that will have
16 to be excavated. If that number goes up, excavate
17 everything above 50. Once they are done with that,
18 they have to backfill in or whatever. It's not a
19 manual situation. They can come back in and develop
20 it as the aquarium and parking garage and everything
21 else.
22 MR. TANNER: Yes. These cleanup numbers
23 are driven by risks so we have to follow up.
24 MR. ZELLER: Of course, it%'s unknown to
25 some degree; shouldn't tripl.e or quadruple.
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1 MR. TANNER: There's one group here --
2 let me introduce this group. Mike Hammerpart is on
3 this project with the State of South Carolina, and
4 he's sitting in the front row. I would like them to
5 introduce themselves. This is the group here in
6 South Carolina that I work with.
7 MR. COLEMAN: My name is Ken Coleman, I
8 am the manager of the Superfund in South Carolina.
9 MR. HAYNES: Richard Haynes, I'm the
10 state project manager for the Superfund.
11 MS. CANOVA: Judy Canova, project
12 geologist.
13 MR. MALERO: Eric Malero, Division of.
14 Health Hazard Evaluation.
.15 MS. JOHNSON: Do you have your operating
16 offices nearby?
17 MR. HAYNES: Columbia.
18 MR. TANNER: Thanks. I work with these
19 folks a good deal on the sites. When we get the
20 reports in, we get together and we review them and we
21 go back to comments, work out the technical details
22 to make sure that we are in agreement. It's a system
23 of checks and balances.
24 Yes.
25 MS. MAREKI: Do you know yet what kind of
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1 plants you are going to use for the phytoremediation?
2 MR. TANNER: We have looked at oak trees.
3 And I don't know if we've looked at any other
4 specific species beyond that. Walter, could you
5 elaborate on that?
6 ' UNIDENTIFIED SPEAKER: We've looked at
7 several different species working with the City of
8 Charleston on the type of criteria that they have on
9 the listing of approvable trees. So we are trying to
10 stick with the same type of vegetation they have
11 around the city and around the area/ but there's
12 going to be a couple different; not just one species.
13 MR. TANNER: Yes.
14 UNIDENTIFIED SPEAKER: It seems that if
15 the roots of the tree are sucking up all this stuff,
16 the tree would die.
17 MR. TANNER: In certain concentrations,
18 it would be toxic, obviously. The levels that we are
19 seeing here in the groundwater don't appear to be
20 toxic to the plants.
21 Now, if we were to plug down a tree right
22 into this heavily contaminated soil area, it might
23 kill it. But if we are looking at phytoremediation
24 from the perspective of groundwater, we wouldn't do
25 that. Again, on these groundwater concentrations we
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1 are seeing here, we don't think it's going to affect
2 it. The bigger concern is, will it work.
3 A couple of things I wanted to mention
4 briefly while I'm on this subject before our meeting
5- draws to a close. We have done some sampling out
6 here in the sediments and found that we've got some
7 contamination, let's see, here, and this isn't
8 exactly to scale; it's more or less; and we found
9 some more here. And, of course, with the outbreak of
10 this seep here, it's a good bet we've got some
11 contamination out here as well. I will be back to
12 discuss that at a future meeting.
13 One of the things I wanted to do.for
14 purposes of this meeting was to address specifically
15 the soils and the groundwater. We want to get moving
16 on that. And we will be addressing those soils at
17 another point in time.
18 What you guys are going to see within the
19 next month or two months is some activity on these
20 soils here. SCE&G has agreed to go in and do a
21 removal action on these soils concurrent with the
22 proposed plan. We are also working with them to take
23 some type of action on these seeps at that same time.
24 So, again, within the next couple of months, you are
25 going to see a good deal of activity out here; just
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1 know that that's what it's for. Questions, comments?
2 If not, we will try to wrap this thing up and get
3 home. Yes.
4 UNIDENTIFIED SPEAKER: Could we have a
5. little bit more advance notice? I received this
6 Friday.
7 MR. TANNER: Yes, my apologies. That
8 should have been handled better.
9 MS. JOHNSON: This has been a good
10 meeting. This will be on my desire to hear more.
11 MR. TANNER: I hope it's been helpful.
12 At least you've got some idea of what's going on.
13 Yes.
14 MS. McGOWEN; If I can beg the group's
15 indulgence for a moment. I have been trying to get
16 some help with a problem. I thought maybe I might
17 collar the right people in this room.
18 I own Turkey Creek in Sumter, one of the
19 most polluted areas in the state. We've got
20 pollution for almost 40 years; cadmium, lead,
21 mercury, chromium. Our numbers are a lot higher than
22 what you got on this sheet.
23 We've had eight corporations polluting us
24 with impunity; no one has even looked at cleaning up
25 the problem. It flows into the Pocotaligo River.
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1 The City of Sumter is thinking about taking some
2 dredges and going in and opening up the waterway
3 without permit or notifying the right people and will
4 probably resuspend a lot of stuff that you don't want
5 resuspended.
6 The reason they are doing this is because
7 they have got almost 60 acres of my property under
8 water now, and I'm drowning. This is the last
9 battleground of the Civil War and the 54th regiment,
10 the Glory guys, are buried on my land, and I need
11 some help. And I hope that lady over there is typing
12 this. So to go on record, my phone number is
13 556-9487, and I expect some phone caj.ls in the
14 morning. Thank you.
15 MR. TANNER: I don't get that at every
16 meeting. I will, ma'am. I will call you.
17 MS. McGOWEN: Thank you so much. Your
18 name?
19 MR. TANNER: Terry Tanner. I will meet
20 you after this.
21 MS. McGOWEN: We will do lunch.
22 MR. TANNER: Everybody has my number.
23 (Thereupon, the hearing was concluded at
24 8:30 p.m.)
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1
2 CERTIFICATE OF REPORTER
3
4 I, Lora L. McDaniel, Registered
5 Professional Reporter and Notary Public for the State
6 of South Carolina at Large, do hereby certify that
7 the foregoing transcript is a true, accurate and
8 complete record.
9 I further certify that I am neither
10 related to nor counsel for any party to the cause
11 pending or interested in the events thereof.
12
13
14
15 APRIL 6, 1998
16
17
19 Itsura L. McDaniel
Registered Professional Reporter
20 My Commission expires
November 12, 2006
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