Superfund Record of Decision: Carolawn, SC


United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R04-89/051
September 1989
Superfund
Record of Decision
Carolawn, SC

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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT Mtt
EPA/ROD/R04-89/051
X RecJpbnr* Acceeelon No.
4. TM* *nd SuMNe
SUPERFUND RECORD OF DECISION
Carolawn, SC
First Remedial Action
n«portD«le
09/27/89
7. Author(»)
a. Performing OrgmtaMlon R*pt No.
9. Performing Orgalnlatton Nun* «nd Addiee*
ia Pro|*cVTMfc/Work Unit No.
11. Canti»ct(O or
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* GPO 19830-381-526(8393) OPTIONAL FORM 272 BACK
(*-77)
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DO NOT PRINT THESE INSTRUCTIONS AS A PAGE IN A REPORT

INSTRUCTIONS
[lonal Form 272, Report Documentation Page la baaed on Guidellnea for Format and Production of Scientific and Technical Reports,
I Z39.18-1974 available from American National Standarda Institute, 1430 Broadway, New York, New York 10018. Each separately
nd report—for example, each volume In a multivolume sat—shall have Its unique Report Documentation Page.

1. Report Number. Each Individually bound report shall carry a unique alphanumeric designation assigned by the performing orga-
nization or provided by the sponsoring organization In accordance with American National Standard ANSI Z39.23-1974, Technical
Report Number (STRN). For registration of report code, contact NTIS Report Number Clearinghouse, Springfield, VA 22161. Use
uppercase letters, Arabic numerals, slashes, and hyphens only, aa In the following examplea: FASEB/NS-75/87 and FAA/
RD-75/09.
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3. Recipient*a Acceealon Number. Reserved tor use by each report recipient

. 4. Title and Subtitle. Title should Indicate clearly and briefly the subject coverage of the report, subordinate subtitle to the main
title. When a report la prepared In more than one volume, repeat the primary tine, add volume number and Include subtitle for
the specific volume.

5. Report Date. Each report shall carry a date Indicating at least month and year. Indicate the basis on which it was selected (e.g.,
date of Issue, date of approval, date of preparation, date published).

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the performing organization.

8. Performing organization Report Number. Insert If performing organizaton wishes to assign this number.

9. Performing Organization Name and Mailing Address. Give name, street, city, state, and ZIP code. List no more than two levels of
an organizational hlerachy. Display the name of the organization exactly aa It should appear In Government Indexea such as
Government Reports Announcements & Index (GRA & I).

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jContract/Grant Number. Insert contract or grant number under which report was prepared.

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16. Abstract Include a brief (200 words or less) factual summary of the moat significant Information contained In the report. If the
report contains a significant bibliography or literature survey, mention it here.

17*. Document Analysis, (a). Descriptors? Select horn the Thesaurus of Engineering and Scientific Terms the proper authorized terms
that Identify the major concept of the research and are sufficiently specific and precise to be used aa Index entries for cataloging.

"' (b). Identifiers and Open-Ended Terms. Use identifiers for project names, code names, equipment designatora, etc. Use open-
ended terms written In descriptor form for those subjects for which no descriptor exists.

(c). COSATI Field/Group. Field and Group assignments are to be taken form the 1964 COSATI Subject Category List. Since the
majority of documents are multldlsclpllnary In nature, the primary Reid/Group assignments) will be the specific discipline,
area of human endeavor, or type of physical object The appllcatlon(s) will be cross-referenced with secondary Raid/Group
assignments that will follow the primary postlng(s).

18. Distribution Statement Denote public releasabllity, for example "Release unlimited", or limitation for reasons other than
security. Cite any availability to the public, with address, order number and price, If known.

19. & 20 Security Classification. Enter US. Security Classification In accordance with U. S. Security Regulations (I.e., UNCLASSIFIED).

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i. Enter price In paper copy (PC) and/or microfiche (MF) if known.

19830-381-526(8393) OPTIONAL FORM 272 BACK
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EPA/ROD/R04-89/051
Carolawn, SC

16. Abstract (Continued)

The selected remedial action for this site includes ground water pumping and treatment
using one or more of the following methods: air stripping, biodegradation, activated
carbon filtration, and metals removal and will be determined during the remedial design
stage based on the level of contaminants found and the treated ground water discharge
point selected; implementing deed restrictions; plugging condemned wells; disposing the
two inactive incinerators and two remaining drums; and monitoring ground water and soil.
The estimated present worth cost for this remedial action ranges from $1,141,071 to
$1,356,305, with a present worth O&M cost for over 30 years ranging from $753,433 to
$916,723, depending on the extent of treatment and ultimate discharge point for the
treated water.
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ENFORCEMENT
RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
CAROLAWN SITE
FORT LAWN, CHESTER 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

Carolawn
Fort Lawn, Chester County, South Carolina

STATEMENT OF BASIS AND PURPOSE

This decision document represents the selected remedial action for the
Carolawn site in Fort Lawn, South Carolina chosen in accordance with CERCLA,
as amended by SARA and, to the extent practicable, the National Contingency
Plan. This decision is based upon the administrative record for the Carolawn
Site.

The State of South Carolina has concurred on the selected Remedy.

ASSESSMENT OF THE SITE

Actual or threatened releases of hazardous substances from the Carolawn site,
if not addressed by implementing the response action selected in this Record
of Decision, may present an imminent and substantial endangerment to public
health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY

MIGRATION CONTROL (Remediation of Contaminated Groundwater)

Review the existing groundwater monitoring system to insure proper
monitoring of groundwater. If deemed necessary, additional monitor wells
will be installed to mitigate any deficiencies in the existing groundwater
monitoring system.
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Appropriate institutional controls (deed restrictions) will be
implemented.

Upon the condemnation of the adjacent contaminated private, potable wells
by the County of Chester, these wells will be plugged in accordance to
South Carolina Department of Health and Environmental Control regulations.

SOURCE CONTROL (Remediation of Contaminated Soils)

Due to the effectiveness of the removal actions, no source of contamination
remains within the fenced area of the site. However, additional field work
is required in the disposal area north of the fenced area. This field work
will consist of the installation of confirmatory soil borings to verify the
presence or absence of contamination in this area. If no contamination is
found, there will no source control remediation required at the Carolawn
site, however, if contaminated soil is found, a second Record of Decision
will be necessary to address this source of contamination.

GENERAL SITE CLEANUP ACTIVITIES

The two inactive incinerators will be inspected and any remaining residue
will be sampled and analyzed. Also, wipe samples will be collected and
analyzed. The results of the analyses will determine the method of
disposition for the incinerators. The two remaining drums will also be
sampled and analyzed to determine how they will be disposed. In addition,
site cleanup will include closing of the equipment decontamination area
used during Phase I RI activities.
DECLARATION

The selected remedy is protective of human health and the environment,
complies with Federal and State requirements that are legally applicable or
relevant and appropriate to the remedial action, and is cost-effective. This
remedy utilizes permanent solutions and alternative treatment technologies to
the maximum extent practicable and satisfies the statutory preference for
remedies that employ treatment that reduces toxicity, mobility, or volume as
a principal element. Since this remedy may result in hazardous substances
remaining on-site above health-based levels, the five-year review will apply
to this action.
* 7 1999
Date Greer C. Tidwell
Regional Administrator
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TABLE OF CONTENTS

Page No.

1.0 Introduction 1

1.1 Site Location and Description 1
1.2 Site History 4
1.3 Demographics 6
2.0 Enforcement Analysis 8

3.0 Current Site Status 8

3.1 Hydrogeologic Setting 9
3.2 Site Contamination . 11
3.3 Air Contamination 11
3.4 Soil Contamination 15
3.5 Groundwater Contamination 15
3.6 Surface Water and Sediment Data 35
3.7 Risk Assessment Summary .. 35

4.0 Cleanup Criteria 61

4.1 Groundwater Remediation 61
4.2 Soil Remediation 61
4.3 Surface Water/Sediment Remediation 66

5.0 Alternatives Evaluated 66
5.1 Nine Point Evaluation Criteria for Evaluating
Remedial Action Alternatives 76
6.0 Recommended Alternatives 84
6.1 Description of Recommended Remedy 84
6.2 Operations and Maintenance 91
6.3 Cost of Recommended Alternative 91
6.4 Schedule 94
6.5 Future Actions 94
6.6 Consistency With Other Environmental Laws 94

7.0 Community Relations 94

8.0 State Involvement 95
Appendices

Appendix A - Responsiveness Summary
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
CAROLAWN SITE
FORT LAWN, CHESTER COUNTY
SOUTH CAROLINA
PREPARED BY:

U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA GEORGIA
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LIST OF FIGURES
PAGE NO.
Figure 1. Map Showing Site Location 2
Figure 2. Map Providing Site Vicinity 3
Figure 3. Map Illustrating Location of Adjacent Residents
and Residential Potable Wells 5
Figure 4. Map Showing Location of Former Waste Structures 7
Figure 5. Map Illustrating Magnetometer Survey Grid and Data 10
Figure 6. Map Providing Groundwater Level Contours Based on
August 31, 1988 Measurements 12
Figure 7. Map Providing Groundwater Level Contours Based on
October 17, 1988 Measurements 13
Figure 8. Map Providing Groundwater Level Contours Based on
October 17, 1988 Measurements 14
Figure 9. Map Showing Surface and Subsurface Soil Sampling
Locations 16
Figure 10 Map Showing Locations of Monitor Wells Installed
During Phase I 24
Figure 11. Map Showing Locations of Monitor Wells Installed
During Phase II 27
Figure 12. Map Illustrating Distribution of Organics in the
Groundwater According to Phase I Analytical Data 31
Figure 13. Map Illustrating Distribution of Inorganics in the
Groundwater According to Phase I Analytical Data 32
Figure 14. Map Illustrating Distribution of Acetone in the
Groundwater According to Phase II Analytical Data 33
Figure 15. Map Illustrating Distribution of Trichloroethene
in the Groundwater According to Phase II
Analytical Data 34
Figure 16. Map Showing Locations of the Hazardous Waste Site
Investigation Effort 36
Figure 17. Map Providing Locations of Phase I Surface Water
and Sediment Sampling Points 44
Figure 18. Map Providing Locations of Phase II Surface Water
and Levels on Contamination 45
Figure 19. Map Showing 100 Year Flood Plain for Fishing Creek
in the Vicinity of the Carol awn Site 49
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LIST OF TABLES
PAGE NO.
Table 1. summary of Detected Compounds in Phase I Surface
Soil Samples „ 17
Table 2. summary of Sub-surface Soil Samples for Phase I 21
Table 3 . Typical Elemental Composition of Soil 22
Table 4. Summary of Levels of Metals Found at the
Carolawn Site to Those Levels Presented
in Table 3 23
Table 5. Summary of Detected Compounds in Phase I Groundwater
Samples . 25
Table 6. summary of Organic Compounds Detected in Groundwater
Samples for Phase II 29
Table 7. Summary of Inorganic Compounds Detected in Groundwater
Samples for Phase II 30
Table 8. Description of Hazardous Waste Site Investigation
Sampling Locations . . 37
Table 9. Data Summary for Hazardous Waste Site Investigation
Samples and Concentration of Contaminants Found 38
Table 10. Data Summary for Hazardous Waste Site Investigation
Surface Water and Sediment Samples 41
Table 11. Summary of Detected Compounds in Surface Water
and Sediment Samples Collected During Phase I 46
Table 12. Summary of Detected Compounds in Surface Water
Samples Collected During Phase II 48
Table 13. Potential Exposure Pathways of Contaminants to the
Public and the Environment 51
Table 14. Summary of Potential Human Exposure Pathways to
Contaminants From the Site 52
Table 15. Estimated Health Risk Due to Site Related Chemicals by
Consumption of Groundwater from Wells Representing
Boundary Line Concentrations 55
Table 16. Projected Potential Future Health Impact from
Consumption of Contaminated Groundwater 56
Table 17. Phase I Groundwater Lead Concentrations 57
Table 18. Assumptions Used for Estimating Exposure and Risk
for Swimming in Fishing Croek .. 58
Table 19. Summary of Estimated Health Risks Due to Site
Related Chemicals from Swimming in Swimming Creek 60
Table 20. Assumptions for Fish Ingestion Scenario 62
Table 21. Summary of Estimated Health Risk Due to Site Related
Chemicals from Eating Fish from Fishing Creek 63
Table 22. Standards and Criteria for Contaminants of
Concern/Chemical Specific Applicable and
Revelant or Appropriate Requirements for
Water Quality 64
Table 23. Cleanup Goals for Contaminants Found in the Groundwater .. 65
Table 24. Groundwater Remedial Technologies and Process Options .... 67
Table 25. Screening of Groundwater Remedial Technologies 70
Table 26. Assembled Remedial Alternatives for Detailed Analysis .... 73
Table 27. Detailed Analysis Criteria and Factors 78
Table 28. Cost Sensitivity Analysis for 10 Years Versus
30 Year Duration 83
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LIST OF TABLES
(continued)
PAGE NO.

Table 29. Summary of the Detailed Analysis of remedial
Alternatives 85
Table 30. List of Federal and State Applicable or Relevant
and Appropriate Requirements 92
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ENFORCEMENT RECORD OF DECISION
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
CAROLAWN SITE
FORT LAWN, CHESTER COUNTY, SOUTH CAROLINA

1.0 INTRODUCTION

The Carol awn site, also known as the Fort Lawn site, was proposed for
inclusion on the National Priorities List (NPL) in December 1982 and was
finalized on the NPL, ranking 699, in September 1983. The Carol awn site has
been the subject of two Remedial Investigation and Feasibility Study (RI/FS)
undertakings by the Potentially Responsible Parties (PRPs). The first RI/FS,
which has subsequently been referred to as Phase I, was conducted from
September 1985 to March 1987. The second RI/FS, Phase II, began in the fall
of 1987 and was completed in September 1989. Phase II was deemed necessary
by the Agency after reviewing the Phase I RI/FS document. The review found
this document lacking sufficient data and information to support the
selection of a remedial alternative, consequently, Phase II was initiated in
September 1987.

The Phase II RI report, which is supplemented by the Phase I RI/FS report,
examined air, groundwater, soil, surface water, and sediment contamination at
the Site and the routes of exposure of these contaminants to the public and
environment. The Phase II RI report was completed in September 1989. The
Phase II FS document, which is also supplemented by the Phase I RI/FS report,
developed, examined and evaluated five (5) remedial alternatives. The draft
RI and FS reports were issued to the public in August 1989.

This Record of Decision (ROD) has been prepared to summarize the remedial
alternative selection process and to present the selected remedial
alternative.
1.1 SITE LOCATION AND DESCRIPTION

The Carolawn Site is an approximate 60-acre abandoned waste storage and
disposal facility located in Fort Lawn, Chester County, South Carolina
(Figure 1). The site, shown in Figure 2, is situated less than three miles
west of Fort Lawn, the closest population center to the site, and
approximately one-half mile south of South Carolina Highway 9 at latitude
34'41'IQ" north and longitude 80*56'35" west. Rural and agricultural areas
surround much of the site. The Lancaster & Chester Railroad and County Road
841 borders the site to the south and Fishing Creek borders the site to the
east. Fishing Creek is a tributary to the Catawba River. Wooded areas and
cultivated fields lie to the west and north of the site. Soybeans have been
historically planted in these fields. Fort Lawn had a population of 471
according to the 1980 U.S. Census.
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SOURCE^ RAND McNALLY
ROAD ATLAS, 1986
FIGURE 1 SITE LOCATION
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BASCOMVILLE
Cedar Shoali
SOURCE: S.C. DEPT. OF HIGHWAYS AMD TRANSPORTATION.
GENERAL HIGHWAY MAP, CHESTER COUNrY,
SOUTH CAROLINA. 1968
FIGURE 2 SITE VICINITY MAP
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-4-
Approximately five acres of the site were affected by the hazardous waste
storage and disposal activities, three of which have been enclosed in a
chain-linked fence. Disposal activities at the site began in 1970 and ended
in 1980, when the site was abandoned. Both Phase I and Phase II focused on
the fenced area.

Located within a two-mile radius of the site are approximately thirty (30)
permanent, single family residences; most of which are along South Carolina
Highway 9 (Figure 2). There are four residences located within 300 yards of
the fenced area with a fifth residence located approximately 1,000 yards to
the west of the site. One of these dwellings is located between the site and
Fishing Creek (Figure 3).

Natural resources in the area of the site include water, soils, flora, and
fauna. The waters of Fishing Creek are occasionally used for fishing and
other recreational activities but topography and poor accessibility limit the
use of the creek in the vicinity of the site. Fishing Creek flows southward
past the site and eventually empties into the Catawba River, eight miles
south of the site and above Great Falls, South Carolina, where approximately
2,500 people receive their water supply from the Catawba River.

The residential, commercial and industrial establishments within the City of
Fort Lawn receive their water supply from the Chester Metropolitan Sanitary
District (MSD), whose water intake on the Catawba River is approximately four
miles east of the site and above the confluence of Fishing Creek and Catawba
River. Three of the four residents adjacent to the site who used private
wells were provided an alternative water source in 1985 and connected to the
Chester MSD. The fourth resident declined the opportunity to be connected to
the Chester MSD system and elected to continue to use their private well. To
date, no contaminants have been found in this private well.
1.2 SITE HISTORY

The Carolawn site was originally owned by the Southeastern Pollution Control
Company (SEPCo) of Charlotte, North Carolina. Beginning in 1970, SEPCo used
the site as a storage facility for a solvent recovery plant located in
Clover, South Carolina. SEPCo went bankrupt in 1974 and abandoned the Site
leaving approximately 2,500 drums of solvents on site. SEPCo had been
storing the drummed solvents in anticipation of incinerating the waste.
Neither an incineration permit nor a storage/disposal permit were issued to
SEPCo by South Carolina Department of Health and Environmental Control
(SCDHEC). The drums were stacked one-or-two high on wooden pallets or
directly on the ground. No dikes or containment barriers were constructed.

In January 1975, Columbia Organic Chemical Company was contracted to clean up
the SEPCo Plant in Clover, South Carolina. As part of this clean up effort,
Columbia Organic transported and stored the waste at the Carolawn site.
Columbia Organics brought an additional 2,000 drums to the site. As payment
for services rendered during the cleanup of the plant in Clover, Columbia
Organics received the Carolawn property.
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tOO' 400'
LEGEND

• RESIDENTIAL WELL
LOCATION
SOURCE: SOIL AND MATERIAL ENGINEERS INC.
COLUMBIA. SOUTH CAROLINA
FIGURE 3 LOCATION OF ADJACENT RESIDENTS AND RESIDENTIAL POTABLE WELLS
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-6-
South Carolina Recycling and Disposal, Inc. (SCRDI), a subsidiary of Columbia
Organics, controlled the site. In 1978, SCRDI obtained a permit from SCDHEC
for a one-time disposal of 300-400 drums containing inert waste. In October
1978, SCRDI was given approval to dispose of empty drums on the 3-acre fenced
portion of the property. Also in 1978, SCRDI sold the 3-acre fenced area of
the site to the Carolawn Company.

The Carolawn Company began the construction of two incinerators on the site.
With conditional approval of SCDHEC, a test burn was conducted with one
incinerator. Full scale incineration never developed. At the time of
abandonment of the site by the Carolawn Company, the fenced area contained a
concrete loading dock, a diked area for storage of tanks and drums, two
incinerators, two storage trailers, 14 storage tanks, and as many as 480
drums containing liquid and solid wastes. An additional 660 drums and 11
storage tanks were located outside the fenced area to the north (Figure 4).
SCRDI was notified by SCDHEC in 1979 that they would have to clean up the
Carolawn site.

Both SCDHEC and the Agency conducted site investigations at the Carolawn
site. These investigations included collecting environmental samples for
analysis as well as pulling samples from nearby private residential wells.
Due to the elevated levels of contamination found and the potential threat
for imminent damage to public health and/or the environment, EPA initiated
cleanup activities at the site on December 1, 1981. Cleanup activities
included removing the drums, waste and contaminated soils. Cleanup
activities ended in February 1982. As part of the cleanup all nearby
residences were provided with an alternative water source; they were
connected to MSD.

When Phase I of the RI was initiated, there were 17 storage tanks on site.
Some of the tanks contained waste. The Carolawn Generators Steering
Committee, under an Administrative Order of Consent, took it upon themselves
to remove these tanks in May-June 1986. The tanks were cleaned, cut up and
sold as scrap metal, the waste was incinerated off-site, the water from
decontamination activities was treated and sent to the local publicly owned
treatment works (POTW), and contaminated soils were excavated and sent to
GSX, Pine wood, South Carolina for disposal. Presently, the only structures
on site are the concrete base of the tank farm, two inoperable incinerators
and miscellaneous debris such as drum lids and pallets.
1.3 DEMOGRAPHICS

The Site is located in a primarily rural area of Chester County (Figure 2).
Five households are located adjacent to the Site. Approximately 2,000 people
live within a four-mile radius of the Site, with an estimated 100 people
within a one-mile radius. Fort Lawn (population 471) is located 2.5 miles
east of the Site and Richburg (population 269) is located three (3) miles
west of the Site. The population estimations are based on the 1980 U.S.
census.
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Strca
Pit „•"»
Horizontal Tank
•v:
/•Y
• 1* •••
s \ /'
Drums LJ
(APPROX. 3 ACRES)

I F«nce
en ici I
Ponded Uarer
Horitontal Tankt
V
0)1 ^^
Uakage
Drums on Loading
'N PomtJd
y Uaf > J
Spillage ^-p
Inclncratoi
and
$Mll Tanki
Ph»nol
WllTCt
Paint tolventi
Druin
Trailer
[=1
TO nSHING CREZK

Str«»
Lancaster and Clutter Railroad
ftoad
I I
SOURCE: USER A. 1982
FIGURE 4 LOCATION OF FORMER WASTE STRUCTURES
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-8-
2.0 ENFORCEMENT ANALYSIS

The Carolawn site was proposed for inclusion on the first NPL in December
1982. The site was finalized on the NPL in September 1983 and ranked 699.
EPA assumed lead responsibility for the Site at this time.

Initial Notice Letters were sent to the identified PRPs in November 1981.
Additional notice letters were sent to additional PRPs, the transporters, in
September 1983

A Partial Consent Decree was entered into by the following PRPs with the
Agency and the Department of Justice in August 1985 to conduct the RI/FS.
The Settling Defendants were Aeroquip Corporation; Black & Decker, Inc.;
Burlington Industries, Inc.; Carolawn Company, Inc.; Cellu-Craft, Inc.;
Clarke Floor Equipment Company; Columbia Organic Chemical Company, Inc.; Cone
Mills Corporation; Cumberland County Hospital System, Inc.; Dart Industries,
Inc.; Eaton Corporation; General Electric Company; Georgia-Pacific
Corporation; Max G. Gergel; Inmont Corporation; Kerr Glass Manufacturing
Corporation; The Knight Publishing Company; James Q.A. McCigre; National
Health Laboratories, Inc.; National Starch & Chemical Corporation;
Measurements Group, Inc.; Melvin Ernest Nunnery; Mobil Chemical Company;
David M. Neill; Robert Riggs; South Carolina Recycling and Disposal, Inc.;
Stickhausen, Inc.; Technographics Printworld, Inc.; Henry M. Tischler; and
Bruce A. Whitten. The Partial Consent Decree required the PRPs to conduct
the RI/FS.

An Administrative Order of Consent was entered into by the PRPs in September
1985. The Administrative Order required the PRPs to remove the remaining
onsite tanks and their contents. The tanks and their contents were disposed
of in compliance to all applicable laws, including Resource Conservation &
Recovery Act (RCRA). The work conducted under this Administrative Order was
completed to the satisfaction of the Agency.
3.0 CURRENT SITE STATUS

This section summarizes the Site's characteristics.

The site was abandoned by the Carolawn Company in 1980. Following the two
removals, the first sponsored by EPA and the second by the PRPs, the site
lies vacant. A chain linked fence encompasses three of the five acres that
were affected by the storage and disposal activities. The fence is in
generally good condition. The other area affected by the storage and
disposal activities lies several hundred feet to the north of the fenced
area. This area was also cleaned up by EPA during the Agency's removal
action.

Due to the limited analytical soil data collected from the area north of the
fenced area, additional confirmatory samples needs to be done in this area to
confirm the presence or absence of residual soil contamination in this area.
-------
-9-
3.1 HYDROGEOLOGIC SETTING

The Carolawn site is located in the eastern Charlotte Belt of the Piedmont
Physiographic Province of South Carolina. This belt is characterized by
granitoid gneisses with strong compositional layering, probably derived from
sediments. The bedrock in the vicinity of the Site consists of Lower
Metadiorite and Metagabbros. This complex is cut by pegmatite, granite and
mafic dikes.

The stratigraphic units encountered at the site were:

i) Alluvial deposits;
ii) Residual and Coluvial clays;
iii) Residuum and Saprolite; and
iv) Bedrock.

The upper regions of the bedrock have been altered by in-situ weathering.
This weathering has produced a partially to highly decomposed mixture of rock
and soil which is referred to as saprolite. Saprolite retains the vestigial
mineralogy and structure of the original rock.

The bedrock beneath the Site has undergone several episodes of deformation.
These events have created joints and fractures. These structural features
influence groundwater flow within the crystalline bedrock. The major
structural features noted at the Carolawn site were joints and dikes. Joint
measurements revealed the presence of three joint sets with primary sets
striking N45*W and N5*W and a minor set striking at N35*W. All joint sets
had vertical to subvertical dips. The mafic dike identified strikes at
approximately N45*W and is moderately well fractured. Figure 5 provides the
orientation and profile lines as well as the data generated in the
magnetometer survey of the site and the orientation of the mafic dike that
runs through the site.

The major hydrostratigraphic unit beneath the Site is the Tanodiorite
bedrock, saturated conditions were not encountered in the lesiduum/Saprolite
unit. It may be possible that the Residuum/Saprolite unit may usually be
saturated but the RI was conducted during an extended drought and only
unsaturated conditions were encountered in this unit. The groundwater in the
bedrock is associated with the joints and fractures.

All groundwater in South Carolina is classified as Class GB Waters (South
Carolina Regulation 61-68). This classification means that all groundwater
meeting the definition of underground sources of drinking water (OSDW) meet
quality standards set forth in the State Primary Drinking Water Regulations
(R.61-58.5) . An USDW is defined as an aquifer or portion of an aquifer which
supplies, or contains, sufficient quantity of water to supply a public supply
system.

According to USEPA Groundwater Classification Guidelines of December 1986,
the bedrock aquifer beneath the site is classified as Class IIA. It is
classified as Class IIA since the aquifer was used as a source of drinking
water when the site was in operation. It is also anticipated that there are
-------
50
SO 100(t
LEGEND
DATA POINTS
EW-A(') PROFILE IINE WITH
COnHESPONDINO DATA POINT
SOURCE: SOIL AND MATERIAL ENGINEERS INC.
COLUMBIA. SOUTH CAROLINA
FIGURE 5 MAGNETOMETER SURVEY GRID AND DATA
-------
-11-
several private wells within the two-mile radius that are currently using
this aquifer as a source of potable water. Therefore, the groundwater should
be remediated to levels protective of public health and the environment.

The actual direction of groundwater flow through the bedrock is dependent
upon the orientation of the joints and fractures. The groundwater contours
(Figures 6, 7, and 8) indicate that the preferred direction of groundwater
flow is to the north-east and south-east. Figure 6 presents groundwater
contours based on groundwater levels measured in August 1988. Figures 7 and
8 also show groundwater contours based on groundwater level measurements
collected in October 1988 and December 1988/ respectively.

Hydraulic data collected during the RI indicates that Fishing Creek is the
primary receptor of the groundwater flowing underneath the Site. This data
also indicates that the mafic dike identified in Figure 5 does not influence,
to any great degree, the hydrology of the site.

The estimated groundwater flow velocity is 1.96 x 10" centimeters/second
(cm/sec). This is equivalent to 0.56 feet/day. Based on this velocity, it
would take approximately six years for groundwater originating in the fenced
area to reach Fishing Creek.

3.2 SITE CONTAMINATION

Due to the effectiveness of the removal actions, no source contamination
remains within the fenced area of the site. However, some uncertainty exists
with respect to the area north of the fenced area that was used for storage.
Although this area was addressed during the Agency's removal action,
insufficient confirmatory data has been generated to substantiate the absence
or presence of soil contamination.

The analytical groundwater data indicates that contamination is entering
Fishing Creek via discharge of groundwater to the creek.

3.3 AIR CONTAMINATION

The most common sources of air contamination at hazardous waste sites are the
volatilization of toxic organic chemicals and the spread of airborne
contaminated dust particles. Due to the removal actions all contamination at
the surface has been eliminated. Therefore, as anticipated, no airborne
problems were encountered during either Phase of the RI. This statement is
supported by the fact that only background readings were recorded by site
personnel using the HNu photoionization analyzer while performing designated
RI tasks. The HNu was employed to monitor the air as a safety measure called
for by the Health and Safety Plan.
-------
\ (380.29)
\ FISHING CREEK
\ STATION No. 2

MW10A-8B
(386.82)
MW10B-BB
(388.19)
• MW9-B8
(405.33)
• MWS-88
(400.30)
LAC RAILROAD
. UW7-68
(399.99) +
O ROCKHOLT WELL
(4OI.24)
(382. OS)
MWIIA-B8
MW11B-8B*;
420-
(4J2.47)
PROPERTY LINE

MONITORING WELL (S It ME)

MONITORING WELL (CRA)

PRIVATE WELL

APPROXIMATE LOCATION OF MAFIC DIKE

GROUNOWATER CONTOUR

WATER LEVEL ELEVATION

ANOMOLOUSLY LOW VALUE WATER
LEVEL TAKEN TWO DAYS AFTER
DEVELOPMENT AND SAMPLING.
FISHING CREEK
STATION Ho. 1
(380.91)
FIGURE 6 GROUNDWATER LEVEL CONTOURS BASED ON AUGUST 31, 1989 MEASUREMENTS
-------
(jn?. 75)
nr.HIMG CRCFK
SIAIION No. 2
LECENQ

PROPFRTY

O MONITORING WO1 (S k

• MONITORING WTU (CRA)

O PRIVATT Wll

~~~ APmoxIMATt LOCATION OF MAFIC DIKE

4?0 ——— CROUNOWATtR CONTOUR

(4JI.J7) WATTR LF.VTL FUEVAT1ON
nSHING CRFPK
STATION No. t
(379 91)
FIGURE 7 GROUNDWATER LEVEL CONTOURS BASED ON OCTOBER 17, 1988 MEASUREMENTS
Source: Conestoga-Rovers & Associates
-------
(384. 73)
FISHING CRFFK -v
SIAIION No. 2 \^
/ / • V
I-"-' MW5-B8 \ \
x"1'/ (4IK.59) \\
(I \\
470-
LEGCND

PROITRIY LINE

MOMirORINC WFLL (S * MF.)

MONITORING WfLL (CRA)

PRIVATE WTI.L

APPROXIMAIi: LOCATION OF MAFIC DIKE

1 CROimnWATF.R CONTOUR

WATTR LEVFL ELEVATION
(4JI.84)

FIGURE 8 GROUNDWATER LEVEL CONTOURS BASED ON DECEMBER 14, 1988 MEASUREMENTS
(381.14)
MWIIA-88
MWIID-885*
FISHING CREEK
STAnON No. I
(.WO. 74)
Source: Conestoga-Rovers & Associates
-------
-15-
3.4 SOIL CONTAMINATION

Surficial and subsurface soil samples were collected and analyzed during
Phase I of the RI. Figure 9 provides the location of the sampling points and
the contaminants detected in the sample(s) collected from these points. All
soil samples were analyzed for the Priority Pollutant List compounds. A
summary of the detected compounds in the surface and sub-surface soil samples
is presented in Tables 1 and 2, respectively. Examination of Table 1
indicates that methylene chloride and acetone were detected in all surface
soil samples, however, these compounds were also detected in the laboratory
blanks. Therefore, these contaminants are likely the result of laboratory
contamination. The only base neutral extractable detected was bis(2-ethyl
hexyl)phthalate. There is good evidence that this too may have been a
contaminant introduced into the sample. It is the Agency's opinion that
these contaminants are not present in the soils of the site as the analytical
data would lead a person to believe but the result of cross-contamination.

Several metals were detected in the surficial soil samples. The highest
concentrations were for lead, chromium and barium. Without representative
background data, it is the Agency's contention that the elevated levels of
lead and chromium are the result of past activities at the site.

Table 3 presents the general range and typical medium concentrations of
various metals in soils. A comparison of the levels of metals collected at
the site with the average metal concentrations typically found in soil is
presented in Table 4.

In light of the above information, it is the Agency's opinion that the
removal actions have eliminated future sources of contamination at the site
within the fenced area. Some additional environmental sampling needs to be
performed in the storage area north of the fenced area (Figure 4} to confirm
the absence or presence of contamination. Although no source remediation is
required within che fenced area of the site, there is some question as to the
presence of residual soil contamination in this storage area north of the
fenced area. If contamination is foux d, then this ROD will need to be
amended.
3.5 GROUNDWATER CONTAMINATION

Two rounds of groundwater samples were collected during Phase I. The first
round was analyzed for USEPA Priority Pollutants and the second round was
analyzed for VOCs and selected inorganics. The wells sampled in Phase I were
monitor wells MW-1, MW-2, MW-3, MW-4 and private wells
RH1 (Rockholt), RW2 (Hunter), RH3 (M. Morrison), and RH4 (M. Morrison). The
location of these wells can be found in Figures 3 and 10. The analytical
data is presented in Table 5.

As part of Phase II activities, nine (9) additional monitor wells were
installed at seven (7) locations. The locations are shown on Figure 11.
Three rounds of samples were collected as part of Phase II activities.
During the first round of sampling wells MW5-88 and MW6-88 were analyzed for
-------
Arsenic 12 - 29
Chromium 3 - 7.5
Load 1.6 - 2.9
Arsenic 3.9
Chromium 56
Lead 160
£cetone 6.2
Arsenic 25
Chromium 18
Lead 2.4
Arsenic 16
to
T^TEST"! Chromium 28
Barlun 74
Chromium 12
Acetone 6.4
Arsenic 7.
Chromium 11
Lead 1.
Bin(2-ethyl hexyDphthalate 2200
I «»0
Arsenic 5.6
Chromium 7
Arsenic 24
Chromium 22
Lead 3
Arsenic 7.5
Lead 13
Bls(2-ethyl hexyl)phthalate 790
=rzr\ A:
Arsenic 3.2
Chromium 93
Lead 110
Acetone 21
Blo(2-ethyl hexyl)phthalata 55000
125
250(1
LEGEND
CLSS-10IC

SB-6/TH-1 BORING LOCATION
ARFCA OF COMPOSITE
SURFACE SOIL SAMPLE
Concentrations Shown
are in
milligrams/Kilograms
(nig/Kg)
SOURCE: SOIL AND MATERIAL ENGINEERS INC.
COLUMBIA. SOUTH CAROLINA
FIGURE 9 SURFACE AND SUBSURFACE SOIL SAMPLING LOCATIONS
-------
TABLE 1
Parameter

MeUU (ToUl)

Anttnom
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Detection
Limit
(mg/kg)
SUMMARY OF DETECTED COMPOUND-SURFACE SOIL SAMPLES
CAROLAWN SITE - FORT LAWN, SOUTH CAROLINA
Sample Location
CLSS-101A
CLSS-101B
CLSS-101C
CLSS-101D
CLSS-101E
CLSS-101F
0.05
0.05
10.0
0.20
0.10
0.50
1.0
0.50
0.002
1.0
0.10
050
0.50
0.20
U
3.9
74
U
U
12
34
U
U
112
U
U
U
24
U
5.6
70
U
U
7.0
11
U
. 0.0069
7.0
U
U
U
15
U
6.0
U
U
0.47
U
U
35
0.0055
U
U
U
U
U
U
7.5
U
U
U
U
U
13
0.008
U
U
U
U
U
U
3.2
320
U
0.77
93
190
110
0.12
11
U
U
U
57
1.2
3.9
40
U
0.40
56
75
160
0.019
U
U
U
U
U
VOLATiLESQig/kg)

Methylene Chloride
Acetone

SEMI-VOLATILES
(W5/kg)

BIstt ethyl hexyl)
phlhalale
11 B
6.4 B
2200
S.OB
U
U
22B
7.1 B
14000
19 B
U
790
Note*:
Samples were composited from aample* collected In dealgnated areas.
Samples collected on May 19-20,1985. Analyzed by CompuChem Laboratories.

U - Not detected within minimum, attainable detection limit of sample. Detection limit as Indicated
B - Analyte found In blank as well as sample. Possible/probable blank contamination.
D - Detection limit varies.
51 B
21 B
55000
12 B
6.2 B
U
-------
TABLE I
Parameter
Detection
Limit
(mg/kg)
Maximum
Detected
(mg/kg)
SUMMARY - SURFACE SOIL SAMPLING
WITHIN FENCED AREA (PHASE I)
CAROLAWN SITE
FORT LAWN, SOUTH CAROLINA

Number of Detections
Minimum Above Analytical
Detected Background
(ing/kg) (of 4 samples)*
Mean Soil
Concentrations
(mglkg)
ND = 0 ND-DL
Mfiials
Anlimony
Arsenic
Barium
Beryllium
Cailmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
0.05
0.05
10.0
0.20
0.10
0.50
1.0
0.50
0.002
1.0
0.10
0.50
0.50
0.20
U
7.5
74
U
0.47
12
34
35
0.008
112
U
U
U
24
U
3.9
70
U
U
7.0
11
13
0.0055
7.0
U
U
U
15
0
4
2
0
1
2
2
2
3
2
0
0
0
2
0
5.75
36
0
0.12
4.75
11.25
12
0.0051
29.75
0
0
0
19.5
0.05
5.75
41
0.20
0.19
5.0
11.75
12.25
0.0056
30.25
0.1
0.5
0.5
19.85
-------
TABLE I
Parameter
Metals.
Detection
Limit
Mcihylenc chloride 10
SemhYQlatlksJug/kg)

Dis (2-clhylhcxyl) 330
phthalale
SUMMARY - SUB-SURFACE SOIL SAMPLING
WITHIN AND OUTSIDE FENCED AREA (PHASE I)
CAROLAWN SITE
FORT LAWN, SOUTH CAROLINA
Maximum
Detected
(mg/kg)
10
330
Minimum
Detected
(mg/kg)
U
U
Number of Detections
Above Analytical
Background
(of 8 total)1
Mean of Detections Above
Analytical
Background
(mglkg)
Arsenic
Chromium
Copper
Cyanide
Lead
Volatiles (ue/k
0.25
1.50
1.0
1.0
0.25
R>
29
28
100
U
7.0

7.9
3.0
10
U
1.6

8
8
8
0
8

25.7
16.4
50.0
1.0
2.95

10
330
Notes:

Samples collected on June 5-12,1985. Analyzed by CompuChem Laboratories.

U - Not detected within minimum, attainable detection limit of sample. Detection limit as indicated.

(1) As shown on Figure 17. Based on Table I.
-------
TAULE I
Parameter
Detection
Limit
(•ng'kg)
Maximum
Detected
(mg/kg)
SUMMARY - SURFACE SOIL SAMPLING
WITHIN FENCED AREA (PHASE I)
CAROLAWN SITE
FORT LAWN, SOUTH CAROLINA

Number of Detections
Minimum Above Analytical
Detected Background
(mg/kg) (of 4 samples)1
Mean Soil
Concentrations
(mg/kg)
Yulatiks
Methylene chloride D
Acetone D
22B
7.1 B
8.0B
6.4B
0
0
0
0
D
D
Seml-Volatllea (pg/kg)
Bis (2-ethylhexyl)
phthalate
D
14,000
790
4247.5
D
Notes:

Samples were composited from samples collected in designated areas.
Samples collected on May 19-20,1985. Analyzed by Co.mpuChem Laboratories.

U - Not detected within minimum, attainable detection limit of sample. Detection limit as indicated.
B - Analyle found in blanks as well as sample. Possible/probable blank contamination.
D - Detection limit varies.
(1) Four soil sample locations; CLSS 101A to CLSS 101D, as shown in Figure 17.
Based on Table I •
-------
TABLE 2
SUMMARY OF SUB-SURFACE
CAROLAWN SITE - FORT LAWN, SOUTH CAROLINA
Equipment
Rinst
Boring Location'
Sample Mepth
Parameter
Melala (mg/kg)
Arsenic
Chromium
Copper
Cyanide
Lead
Detection
Limit

0.25
1.50
1.0
1.0
0.25
SB-1
3.0-4.4 ft

16
28
34
U
2.1
SB-2
3.0-5.9 ft.

24
22.0
100

3.7
SB-3
3.0-4.40 ft.

14.0
5.0
10

7.0
SB-4
2.8-6.8 ft.

29
7.5
21
U
2.9
SB-4
6.8-10.8 ft.

26
4.0
22
U
2.1
SB-4
10.8-14.8 ft

12
3.0
14
U
1.6
SB 5
3.0-6.3 ft.

25
18
77

2.4
SB-6
3.0-4.8 ft.

7.9
It
22
U
1.8
Drfoirizfff 1
(Kill

0.5.0
0.3

0.2
.5.0
Volatile*
-------
TABLE 3

TYPICAL ELEMENTAL COMPOSITION OF SOIL
CAROLAWN SITE-FORT LAWN, SOUTH CAROLINA

Concentration in Soils mg/kg (ppm)
Element Range Typical Medium Source

Antimony 0.2-150 6 1,2,3, & 4
Arsenic 0.1-194 11 5
Barium 100-3,000 500 1
Beryllium 0.01-40 0.3 1
Cadmium 0.01 - 7 0.5 6
Chromium 5-3,000 100 6
Copper 2-250 30 1
Iron 100-550,000 40,000 land 5
Lead LT1-888 29 5
Nickel 0.1-1,530 50 land 5
Selenium 0.1 -38 0.4 1 and 6
Silver 0.01-0.8 0.4 5
Thallium 0.1 - 0.8 0.2 1
Zinc 1 - 2,000 "90 1 and 5
1. BOWEN, M.J.M., "Environmental Chemistry of the Elements. Academic Press,
New York, 1979.

2. RAGAINT, R.C., et al, "Environmental Trace Contamination in Kellog Idaho near
Lead Smelting Complex," Envir SCI and Technol 11 773-780 1977.

3. LISK, D.J., Trace Metals in Soils, Plant and Animals,"
Adv Agron 24 267-311,1972.

4. "Geochemistry of Some Rocks, Soil Plant and Vegetables in the Conterminous
United States", Geological Survey Professional Paper 574 F 1975.

5. URE, A.M., et al "Elemental Constituents of Soils" Environmental Chemistry,
Vol 2, pp 94-204 ed H.J.M. BOWEN, Royal Society of Chemistry,
Burlington, London, U.K., 1983.

6. PARR, JAMES F., MARSH, PAUL B., ELA, JOANNE M.,
Land Treatment of Hazardous Wastes, Agricultural Environmental
Quality Institute, Agricultural Research Service, USDA,
Beltsville, Maryland, Moyes Data Coroporation
-------
TABLE 4

SUMMARY OF METALS IN SOILS (MG/KG)
CAROLAWN SITE - FORT LAWN, SOUH CAROLINA
Parameter
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Titanium
Zinc
Typical (1)
Medium

6
11
500
0.3
0.5
100
30
29
0.098
50
0.4
0.4
0.2
90
Surf ace Soil
Average (% ND)
Subsurface Soil
Average (% ND)
1.2
5
126
--
0.6
42
78
80
0.03
10
--
--
--
32
(83)
(0)
(33)
(100)
(50)
(33)
(33)
(33)
(17)
(50)
(100)
(100)
(100)
(50)
NA
19
NA
NA
NA
12
38
3
NA
NA
NA
NA
NA
NA
Range

(0)

(0)
(0)
(0)

1.2
3.2-2.9
40-320
0.40-0.77
3-93
11-190
1.6-160
0.0055-0.12
7-12
15-57
Notes:

(% ND) - percent of samples not included in the average because below detection limit
NA - not analyzed
(1)- from Table 5.3
-------
0 MO >00
\
\
\
.MWJ
\> 1
N V I
„ UW4
^

'*5.-_
* C RAIIROAP
wru
I INF

wra (s fc Mr)
O PRIVAir WI'IL

ACI'ROXIMAir lOCAHON OF MAFIC DIKE
FIGURE 10 LOCATION OF MONITOR WELLS INSTALLED DURING PHASE I
Source: Conestoga-Rovers & Associates
-------
Dmlt
Fmtfmtttr
DttitHou
Limit
TABLE 5

SUMMARY OF DETECTED COMPOUNDS • PHASE IGROUNDWATER
CAROLAWN SfTE - FORT LAWN, SOUTH CAROUNA
tVEUMWI

7/M 12/tt
WEU.MW2

7/M 7/M
12/M
WEU.MW3

7/M 12/M
tVELLMWV

7/M 12/M 12/M
WCURIVf
Rocftftolf
7/M 12/M
WEURM3
Nmter
7/M 12/M
7/M
Page I of 2

WELL RW«
Mori*
7/M
pH(field)
pH(lab)
Spec. Cond(2) (Held)
Spec. Cond (lab)
TDSmg/L
TOCmg/L
Sulfale mg/L
Chbridemg/L
Phenol* mg/L
Aluminum
Arwnic
Barium
Beryllium
Cadmium
Cakium
ChnxnhMn
Cobalt
Copper
Iron
Lead
Magneaium
Manga new
Mercury
Nickel
Putauium
Sodium
Vanadium
Zinc

05 mg/L

O.I
200
10
200
5
5
5000
10
SO
25
100
5
5000
15
0.2
70
5000
5000
50
20
7.04 7.24
73 6.9
279 220
310 260
210 224
U
14
9.7 10.7
U
U
U
U
S
U
30500
U
U
U
167
23 U
11.400
120
U
U
U
17.900

68
700
7.0
700
540
370
45
43
62
0.6
333
U
220
U
6.6
41200
120
U
U
435
27
24.400
17
U
U
6.600
24.300
U
192
7.00 6.95
7.0 65
700 400
540 600
390 417
35
43
62 715
U
297
U
214
U
6.6
41,900
10
U
U
452
28 10
24.200
17
U
U
6.700
24,400
U
SO
7.13
7.3
620
560
370
18
30
49
U
203
U
294
II
6.6
46,300
U
U
U
856
26
25.400
58
U
U
7.400
25,600
U
73
686 781
6.6 77
392 680
550 460
350 320
58
26
50.0 35
U
1.400
U
U
U
U
46.100
U
U
32
2.091
U 26
22500
151
U
U
5700
13900
U
2,160
704
6-
382
500
304
*

408

701 6.9-
7.3 6.9
520 430
580 650
460 420
3.8
43 19
65.0 60.2
U
3700
U
U
U
U
59.100
16
U
184
32.600
20 U
33,900
1010
U
61
5500
14.800
62
382
6.23 65
6.« 6.1
138 ISO-
ISO 5-fan
150 152
3
25
11 I3.«
U
U
U
U
U
U
10.100
U
U
45
2.100
U 14
4.830
U
U
U
U
10,500
U
1,059
6.5
7
1128
160
140
0.8
85
11
U
U
U
U
U
U
8.400
U
U
U
165
U
5,360
U
U
U
U
16.800
U
100
5.95
6.2
242
260
280
34
3
8
U
U
U
394
U
U
17^00
U
U
UU
3490
26
8
46
U
U
U
14.600
U
95
-------
r*ttmtlrr
DttrtMtm
Limit
WCI.L MWI

7/M 12/M
MTCU.MW2

7/M 7/M
TABLE 5
(continued)
SUMMARY or oircrrcn roMpouwns -
CAROIAWN StTC • FORT LAWN, SOUTH CAROLINA
12/M
WtU. MW3

7/M 12/M
WfLl MW4

7/M 12/M 12/M
Wtl t RWI
Rtxkholl
71 it 12/M
WtLLRWl
Hmmltr
7/M 12/M
wrti RWJ
M-Mum KM
7/M
Page 2 o(2
WCtl RW4
M-MorriMM
7/M
VoUrflr Organic*
Methylene Chloride
Acetone
Trant 1,2-Dichloroethene
Trichlororthene
I.I Dichloniethene
I.I Dichloruethrne
I.I.I Trichloniethane
Total Xylenra
Chloroform
Stml-VoUlllet
bis(7-ethylhe»yl>
phalale
50
10
5.0
50
50
SO
SO
50
5.0

10
Nolei:
50
10
5.0
50
50
SO
SO
50
U
U
U
U
U
U
U
U
SB
705 B
U
U
U
U
U
U
U
12 B
7.1
7.9
U
U
U
U
5
MB
78
7.9
U
U
U
U
U
126 B
U
U
U
U
U
U
17 U
U
U
460
71
U
120
U
9B
81 B
24
362
108
12
128
U
U
238
210
220 .
U
U
92
13
SB
U
483
411
21
8
26
U
6B
8B
467
439
22
8
30
U
U
U
76
230
U
U
U
U
7B
ISB
84
171
5
U
U
U
U
U
U
U
U
U
U
U
SB
24 B
16 C
21 C
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
350
(I) Concenlralioni in ng/L unleH olhcrwitr noted. S*mplei oollerttd |uly 9 through |uly II, I486; analyzed by CompuChcm Uboralorics.
Sample* rollerted December 17,19B6, analyzed by Davi* 4 Floyd Inc. All metal* analyaea were performed on unfiltered tamplei.
(2) Specific n>nductance in umhoa/rm
(3) IVrrvlion limit for reported volatile analyse* for umple from MW-3 rollected on 7/9/86 wat 17 |ig/L berauie of dilution factor.

U • Not drtrrtnt within minimum attainable detection limit of tampfe.
D • Analyle found in blank at well ai (ample. INnaible/probably blank contamination.
C • |'I>SM|>|I- i arryovrr conlaminalion from previous laboratory umple run. ai indicated by low malrii spike raroveriei for compound* aa flagged
-------
\
\\"
1C CRFFK \
STATION Nn. ? >v
MWlOA-flR
,MW)-8fl
o' too* lot*
/-"
/ •
/— "-^ Mws-ee
r*
i ouwr,-BS
\ .*, a —
\ '
\N
1 \t
• MW8-8B
N . . / L & C fi
\\
\ V
\V UW7-B8
o ROCKHOL r wri L
LCCCNQ
unr
a MONHORINC wrii (s & Mr)
• unnnoimic wru (CRA)
o cnivAir wi'iL
r KKAPOM or MAFIC DIKE
MWMA nn
MW11I1 fll)**-»
' ri'.IIINC CRtTK
sum IN HO i
FIGURE 11 LOCATION OF MONITOR WELLS INSTALLED DURING PHASE II
Source: Conestoga-Rovers & Associates
-------
-28-
the USEPA Target Compound List (TCL). The DSEPA TCL is equivalent to the
USEPA Priority Pollutant List. All the rest of the groundwater samples were
analyzed for TCL Volatile Organic Compounds (VOCs). A summary of the results
of the analyses are presented in Tables 6 and 7.

Below are brief descriptions of the findings of the groundwater
investigation.

For VOCs; Several TCL VOCs were detected in the monitor wells and domestic
wells sampled during both phases. The compounds found in the highest
concentrations included acetone and trichloroethylene (TCE). Other VOCs were
detected in a fewer number of wells. After reviewing the QA/QC data, it is
the Agency's opinion that the methylene chloride found in some of the
groundwater samples was due to laboratory cross-contamination and not a
constituent of the groundwater. This conclusion is supported by the fact
that methylene chloride was found in the laboratory blanks.

Figures 12 and 13 provide a visual presentation of groundwater contamination
detected in the two sampling rounds conducted during Phase I. Figure 12
depicts the distribution of organics in the groundwater and Figure 13, the
distribution of the inorganic contaminants. Figures 14 and 15 provide a
visual distribution of acetone and TCE contamination of groundwater found
during Phase II. Examination of these figures indicate that the contaminants
are being transported through the fractures and joints in the bedrock along
with the groundwater. As stated previously, the mafic dike has little effect
on groundwater flow and therefore, the distribution of the contaminants in
the groundwater.

For Base Neutral/Acid Extractables (BNAs): The only SNA detected in either
Phase I or II was in well MW-4. Bis(2-ethyl hexyl)phthalate, a common
cross-contaminant in monitor wells, was found in the first round of samples
collected during Phase I.

For Polvchlorinated Biphenvls (PCBs)/Pesticides; Neither PCBs nor pesticides
were detected in any groundwater samples collected during the RI.

For Metals; A number of TCL metals were detected in the Phase I samples and
in the groundwater samples pulled from MW5-88 and MW6-88 during Phase II.
Lead was detected at concentrations from 2.6 to 28.0 ug/1 in various monitor
wells in Phase I. Lead was also detected in round 1 sampling of Phase II in
MW5-88 and MW6-88 at concentrations of 8.2 micrograms per liter (ug/1) and
80 ug/1, respectively. This data is presented in Tables 5 and 7. The
present Maximum Concentration Limit (MCL) for lead is 50 ug/1 but in August,
1988, EPA proposed a MCL of 5 ug/1 (Federal Register: Volume 53, No. 160).
In addition, chromium was also detected in MH6 at a concentration of 80 ug/1
(Table 7) which exceeds the present MCL of 50 ug/1.
-------
TABLE 6
SUMMAKYOr DETECTED COMPOUNDS - WMSEII GROUND W4TU
CAHOIAWN SITE - FORT LAWN, SOUTH CAROLINA
VOIATItt ORGANIC
COMPOUNDS MWt
MWt
ROUND!

Action*
Chloroform
I.l-Dichloro*than*
I.l-Dichloroclhtn*
1,} Dichlorocthtn*
(Tolil)
I.I.I-
TrlchlorottruiM
TricMoroelhmc
11.000 J9JOOO
NDOSO) NO (1000)
NDQSO) NO 0000)
10 ND (1000)
ND (750) ND (IOCO)

ND QSO) ND (1000)

ND aSO) ND (1000)
MWJ
6.200
ND (170)
ND (170)
ND (170)
ND (170)

ND (170)

440
MWt
MWS-D
MWt
MWt-S
fjOOO 31X100 16.000
ND (170) ND (UO) ND (KM)
ND (170) ND (UO) ND (130)
ND (170) ND (830) ND (830)
470 ND (830) ND (830)

ND (170) ND (830) ND (830)

5*0 ND (830) ND (830)
NDOSO) NDCOO)
ND (35) ND (SO)
ND (35) ND (50)
70 70
400 440
MW7
MOO
NDO30)
ND(330)
NDI330)
370
MWI
64
ND(S)
ND(S)
ND(5)
ND(S)
MWt
MIM
MIM
MIM
6,300 100
ND (50) ND (8)
ND (50) ND (8)
ND (SO) 10
81 80
40 XX NDO30) ND(S) ND (SO) 10

1200 1,100 510 ND(5) XX SO
240 ND (50)
ND (12) I
ND (12) ND 0)
14 ND C)
110 ND (5)
MIM
530
ND07)
ND(IT)
ND(IT)
ND(IT)
RW-4
(DUP)
ND (50) ND (50)
ND (12) ND (12)
ND (12) ND (12)
ND02) ND(I2)
120 120
1* NOW ND(IT) ND02) ND(IJ)

M 13 XX 320 240
ROUND2

AcctoiM
1,1-Dlchloroclhin*
l.t-DkhlorotlhiM
U-DicrtloroclhfiM
(ToUl)
1.1,1-
TrkMoratthaM
Trichlorocthcni
ND00)
NDO1)
NDOI)
NDOI)
NDCO)
NDO)
NDC)
XX
ND Ol) ND O)
NDOI)
XX
NDOSO)
ND(2S)
77
ND0)

420
ND(130) «20
ND (13) ND 05)
ND (13) 18
280 230

ND (13) ND OS)
230
>JO
130
•
14
210

160
ND (SO) 1.400
ND (SO) ND (SO)
170 120
4SO 420
ND (250)
NO OS)
16
470
NDCO)
ND(S)
ND(5)
ND(S)
NDOSO) NA
ND (25) NA
ND (25) NA
67 NA
2,500 72
ND (SO) ND 6)
ND (SO) ND Q)
100 ND (5)
1700 ND (100)
ND CO) ND (10)
ND (SO) ND (10)
ND (SO) 150
64

880
66

•20
NDQS) ND(S) ND(2S) NA

620 ND (5) 45 NA
ND(SO) NDO) NDCO) ND(IO)

50 NDC) NDOO) 270
NA
NA
NA
NA

NA
NOTES: ND-Not detected rt
detection limit
XX • Compound detected, but btbw quMiltadoa Imfe
NA-Notuulyud
-------
TABLE 7

SUMMARY OF DETECTED COMPOUNDS - PHASE II GROUND WATER
CAROLAWN SITE - FORT LAWN, SOUTH CAROLINA
METALS
MWS
ROUND I ROUND 2
MW5-DUPL1CATE
ROUND I ROUND 2
MWS
ROUND I ROUND 2
MW6-SPIKE
ROUND 1 ROUND 2
Aluminum
Barium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Maganese
Nickel
Potassium
Silver
Sodium
Vanadium
Zinc
6,700
220
50,000
50
ND (50)
40
8,500
7.3
25,000
140
ND (40)
7,100
20
19,000
ND (50)
20
4,600
190
51,000
ND (20)
ND(50)
ND (10)
12,000
ND (50)
24,000
230
ND (40)
6,700
10
24,000
170
80
7,400
240
48,000
50
ND (50)
30
10,000
8.2
25,000
150
ND (40)
7,400
20
19,000
ND (50)
20
4,600
190
51,000
ND (20)
ND (50)
ND (10)
1,200
ND (50)
24,000
230
ND (40)
6,800
ND (10)
24,000
170
80
6,500
960
100,000
80
60
270
87,000
80.0
59,000
1,400
120
30,000
ND (10)
30,000
270
170
1,000
140
54,000
ND (20)
ND(50)
ND (10)
1,400
ND(50)
19,000
210
ND (40)
6,200
ND (10)
25,000
ND (50)
30
12,000
390
52,000
20
ND(50)
30
18,000
53.0
25,000
460
ND (40)
12,000
ND (10)
22,000
ND(50)
70
200
170
59,000
ND (20)
ND(50)
ND (10)
3,400
ND(50)
20,000
260
ND (40)
7,200
10
26,000
ND (50)
90
NOTES: ND - Not detected at stated detection limit
units ug/L
-------
Acetone
Trans 1,2-Dlchloroethene
Trichloroethene
7/86
12
7.2
7.9
7/86 12/87
33 126
7.8 N/D W
7.9 N/D ^

UW3
Acetone
Trans 1,2-Dlchloroethene
Trichloroethene
1,1-Dlchloroethane
1,1-Dlchloroethene
1,1,1-Trichloroethane
/.r A
7/86
Acetone N/D
O ROCXHOLI WCIL
PROPERTY UNE
o MONITORING MTU. (S * Mr)
PR!V*Tt WTIL
*woxiMAit
Acetone
Trana 1,2-Dlchloroethene
Trichloroethene
1,1-Dichloroethane
1,1-Dlchloroethene
1,1,1-Trichloroethane
Total Xylenea
Bia(2-ethyl hexyljphthalate
Acetone
Trana 1,2-Dlchloroethene
Trichloroethene
1.1-Dichlorouthane
7/86
N/D
76
310
N/D
too'
7/86
23
210
ooft
**w
N/D
N/D
9.2
13
350
12/87
N/D
483
21
8
26
N/D
N/D
— •=» i IIM r». • •se^^^ -^^^
12/87 ^''S^
8
467
22
8
30
N/D
N/D
or MAFIC DIKE
Concentrations Shown are in
micrograms/Liter (ug/L)
FIGURE 12 DISTRIBUTION OF ORGANICS IN THE GrtOUNDWATER ACCORDING TO PHASE I ANALYTICAL DATA
-------

Chromium
Lead
7/86
120
27
7/86
10
28
12/67
N/D
10
Lead
7/86
26
—
26
12/87
N/D
12/87
N/D
12/87
N/D
o ROCKHOU wnt
LCCtNO.
_ rRorrunr iiwr
o MnNIIORINC WTU (S ft ME)

O PRIVATT WTIl
~"J7~ APrnn»iM*tr IOTAPON or MAFIC o«KC
Concentrations Shown are in
micrograms/Liter (ug/L)
Chromium
7/B6
16
12/87
N/D
FIGURE 13 DISTRIBUTION OF INORGANICS IN THE GROUNDWATER ACCORDING TO PHASE I ANALYTICAL DATA
-------
. MW3
•I **•-* « ^-~»"1
• vT
W5-88 \ \ I
MW6-68
rND(Nll)|
[ Nn(ND)|
FISIIII-K; "CHEEK-v *
SIAIION No. 2 Nj
• MW8-88
LAC RAILROAD
\\ m UW7-88
\\
—I , -
J50(240>-u.
270
ND

FIGURE
PROPERTY LINE

MONITORING WELL (S It ME)

MONITORING WELL (CRA)

PRIVATE WELL

APPROXIMATE LOCATION OF MARC DIKE

TCE CONCENTRATION (ugA) ROUND 1
DUPLICATE
TCE CONCENTRATION (ugA) ROUND 2

NOT DETECTED

NOT ANALT7ED

COMPOUND DETECTED BUT BELOW OUANTITATION LIMIT
O ROCKHOLT WEU

ND(ND)
ND
14 DISTRIBUTION OF ACETONE IN THE GROUNDWATER ACCORDING TO PHASE II ANALYTICAL DATA
-------
I iii(i(ir,o)| \ \

\ ~ \\
- ^ Mwr.-flfli ,200(iioo) |\ \ o Mw4
v—" l^C'^Lr \ \—
LECENQ
O ROCKIIOLT WELL
f3?0(240)
|?;n--—
NO

XX
PROPfRTY LINE

MONITORING WELL (S Je ME)

MONITORING WELL (CRA)

PRIVATE WELL

APPROXIMATE LOCATION OF MARC DIKE

TCE CONCrNTOAllON (ugA) ROUND 1
DUPLICATE
TCE CONCENTRATION (ugA) ROUND 2

NOT DETECTED

NOT ANALY7ED

COMPOUND DETECTED BUT BELOW OUANHTATION LIMIT
320(240)
270
FIGURE 15 DISTRIBUTION OF TRICHLOROETHENE IN THE GROUNDWATER ACCORDING TO PHASE II ANALYTICAL DATA
-------
-35-
3.6 SURFACE WATER AND SEDIMENT

Surface water runoff from the Site is channeled into ditches that are located
in the north, east and west sides of the fenced area as can be seen in Figure
16. These ditches direct surface runoff to Fishing Creek and contain flowing
water only during wet periods. Figure 16 also shows the sampling location
for samples collected as part of the hazardous waste site investigation
(HHSI) conducted in August 1981. Table 8 provides a brief description of the
HWSI sampling locations. Tables 9 and 10 summarize the compounds detected in
the August 1981 HWSI.

Surface water and sediment samples were collected during both Phase I and II,
however, only Fishing Creek was sampled during Phase II. Figure 17 shows the
sampling locations in Phase I. Figure 18 identifies the sampling points for
samples collected from Fishing Creek during Phase II. The analytical results
of Phase I surface water/sediment sampling are given in Table 11 and the
results of Phase II sampling/analyses are presented in
Table 12.

The Phase I surface water data indicates that the concentrations of metals
and semi-volatile organic compounds were below minimum detection limits. The
only volatile organic compound detected, which also was found in the
laboratory blank, was methylene chloride.

The six sediment samples collected during Phase I indicate the presence of
acetone and elevated levels of lead and arsenic. The elevated metal levels
were detected in the sediment collected from the west ditch.

All Phase II surface water samples collected were analyzed for TCL VOCs.
Examination of these data indicates that only acetone was detected. No other
VOCs were detected. It is possible that the acetone is the result of
sampling and/or laboratory contamination as acetone was not detected in the
duplicate sample collected at Station 1 during Round 2 of sampling. However,
acetone is a confirmed contaminant in the groundwater that is discharging to
Fishing Creek.

The surface water analyses conducted during the RI indicates that the
discharge of groundwater to Fishing Creek has not had a measureable impact on
the water quality in Fishing Creek.

The geometric mean of flow in Fishing Creek is 45.45 cubic feet per second.
Figure 19 depicts the 100-year flood zone for Fishing Creek.

3.7 RISK ASSESSMENT SUMMARY

The chemicals of potential concern identified for the site are volatile
organic compounds and one heavy metal. More specifically: acetone,
1,1-Dichloroethane (1,1 DCA), 1,1-Dichloroethene (1,1 DCE),
1,2-Dichloroethene (1,2 DCE), 1,1,1-Trichloroethane (1,1,1 TCA),
Trichloroethene (TCE) and lead'.
-------

-------
TABLE 8
HWSI SAMPLING LOCATIONS
CAROLAWN SITE - FORT LAWN, SOUTH CAROLINA
Sample
Number
Sample
Type
Sampling
Location
FCU-101
Water, sediment
Fishing Creek upstream from site,
approximately 200 feet downstream
from Highway 9 bridge.
FCD-100
Water, sediment
Fishing Creek downstream from site,
approximately 200 feet upstream from
railroad tressel.
CD-102
Sediment
Drainage ditch at west end of property
downgrade from drums.
CD-103 Sediment
Drainage ditch east of site.
CD-104 Water, sediment
Diked area around large bulk storage
tanks.
CDW-105
Waste
Spillage in phenol trailer.
CDW-106
Waste
Spillage at edge of drum storage area
by loading dock.
CDW-107
Waste
Spillage from drum outside fence west
of site.
CDW-108
Waste
from tank in the incinerator
area at the northeast comer of the site.
Source - USEPA, 1981
-------
TABLE 9

DATA SUMMARY - WASH: SAMPLES
CAROLAWN SITE - FORT LAWN, SOUTH CAROLINA
Page 1 of 3
PURGLABI.E ORGANIC COMPOUNDS

1,1,1-Trichloroethanel
Hexane2

EXTRACTABLE ORGANIC COMPOUNDS (GC/MS)

Phenol1
Bis (2-clhyl hexyDphthalate1
C4 Alkyl pchnol2
C10 Alkyl phenol2
Dodccanoic acid2
1'erradecanoic acid2
Unidentified compounds**
Petroleum type compound

PESTICIDES, PCBs AND OTHER CHLORINATED
COMPOUNDS (GC/EC)

p,p'-DDEl
Alpha BHC1
Beta BHC1
Gama BHC1
Delta BHC1
o,p'-DDE
CDW-105
Phenol
trailer
(mg/kg)
ND
800
14,000
ND
18,000
54
150
38
8.9
6.7
20
CDW-W6
Loading
Jock
(mglkg)
ND
ND
ND
ND

26,000
<10,000
ND
ND
ND
ND
ND
CDW-W7
Drum West
offence
(mg/kg)
ND
130
ND
ND
ND
<320
16,000
ND
ND
ND
ND
ND
CDW-108
Leakage
from tank
(mg/kg)
ND
6,900
ND
ND
ND
ND
ND
ND
-------
TABLE 9
(continued)

DATA SUMMARY • WASTE SAMPLES
CAROLAWN SITE - FORT LAWN, SOUTH CAROLINA
Page 2 of 3
INORGANIC ELEMENTS ANC COMPOUNDS

Barium
Cadmium^
Chromium^
Copperl
Molybdenum
Nickel1
Lead
Tin
Strontium
Titanium
Vanadium
Yttrium
Zinc'
Aluminum
Manganese
Calcium
Magnesium
Iron
Sodium
Cyanide1
CDW-WS
Phenol
trailer
(mgfkg)
1,150
9
236
127
33
64
830
343
37
1,480
46
8
880
24,400
410
3,390
5,010
60,(XM)
ND
9.3
CDW-W6
Loading
dock
(mg/kg)
1
ND
0.3
0.2
ND
ND
0.8
ND
0.4
0.4
1
0.1
1.5
10
09
70
8
155
13
ND
CDW-W7
Drum West
offence
(mg/kg>
2
ND
1
2
ND
ND
ND
ND
1
55
1
ND
2
940
6
30
61
1,120
1,500
ND
CDW-108
Leakage
from tank
(mg/kg)
ND
ND
1
178
ND
ND
ND
ND
ND
2
ND
ND
1
13
ND
ND
ND
31
ND
ND
-------
PTOLE 9
(continued)
Page 3 of 3
DATA SUMMARY - WASTE SAMPLES
( AHOI.AWN SITE - H)K I LAWN, SOUTH CAROLINA

All waste concentrations arc calculated im ,i w»-l iv« ij I.I |i.»:.i-...

p - Indicates presence.
N A - Not analyzed.
NI) - None detected at or above the mininunn detection limit (MOD. II le Ml)|j> vary from sample to sample and from parameter to parameter, sec
analytical data sheets (Appendix A) for exact values.
I - Compound/element is on the NKDC list of priority pollutants.
2 - Tentative identification, estimated umtvnlralion.
.< - The value indicates the highest estimated concentration for a compound in this classification. The number in parentheses indicated the number of
compounds detected in this classification.
a - Presumptive evidence of material; not confirmed on CC/MS or second GC column. See footnote b.
I) - Confirmed on CC/MS. The lack of a footnote indicates that the compound was confirmed on two different CC columns.
-------
TABLE 10

DATA SUMMARY - WATEK AND SEDIMENT SAMPLES
CAROLAWN SITE FORT LAWN, SOUTH CAROLINA
Page 1 of 3
SH)IMi.NT
WATER
FCU-101 FCD-100
Fishing Or. Fishing Cr
upstream downstream
(ug/kg)
ND
-------
'ABLE 10
(continued)

DATA SUMMARY - WATER AND SEDIMENT SAMPLES
CAKOLAWN SITE - FORT LAWN, SOUTH CAROLINA
Page 2 of 3
SUHMKNT

FCU-101 FCD-100 CO-101
Fishing Cr. Fishing Cr Dilch West
upstream downstream of property
(ug/kg) (ug/kg) (ug/kg)
CD-101 CD KM FCU-101
Ditch East Diked Area Fishing Cr
of property around tanks upstream
(ug/kg) (ug/kg) (ug/l)
WATER

FCD-100
Fishing Cr
downstream
(ug/l)
INORGANIC ELEMENTS AND COMPOUNDS
Barium
Cadmium1
Chromium1
Copper*
Nickel1
Lead!
Molybdenum
Strontium
Titanium
Vanadium
Yttrium
Zinc1
Mercury1
Cyanide1
Aluminum
Manganese
Calcium
Magnesium
Iron
Sodium
CONVENTIONAL PARAMETERS
(Units as specified for each parameter)

Temperature (°C)
pll(SU)
25
6.9
25
7.4
CD-104
Diked Area
around tanks
(ug/l)
36
ND
9
2
ND
4
ND
3
185
13
3
12
ND
N.-
2,200
300
400
300
6,100
ND
32
ND
3
1
ND
ND
ND
3
122
10
3
10
ND
ND
1,470
350
250
383
3,100
ND
97
2
32
92
14
81
ND
39
712
33
6
41
0.33
0.43
11,600
180
2,100
1,800
11,800
ND
61
ND
23
26
14
8
ND
46
1,070
44
7
18
ND
0.29
8,300
215
3,700
3,100
13,200
250
164
ND
30
63
23
13
ND
91
977
40
9
30
ND
ND
19,800
95
7,600
3,100
13,800
1,200
36
ND
ND
ND
ND
ND
ND
87
61
ND
ND
11
ND
ND
2,800
75
9,100
4,000
2,700
6,000
38
ND
ND
ND
ND
ND
ND
87
93
10
ND
12
ND
ND
3,600
100
9,000
4,000
3,500
6,000
66
ND
ND
ND
ND
ND
ND
33
40
ND
ND
14
ND
ND
1,900
ND
3,600
2,700
1,500
40,000
29.5
8.3
-------
TABLE 10
(continued)
Page 3 of 3
DATA SUMMARY - WATER AND SEDIMENT SAMPLES
CAROLAWN SITE - FORT LAWN, SOUTH CAROLINA
NOTES:
All sediment concentrations are calculated on a dry weight basis.

P - Indicates presence.
NA - Not analyzed.
N D - Not detected at or above the minimum detection limit (MDU. The MDL's vary from sample to sample and from parameter to
parameter
1 - Compound/element is on the NRDC list of priority pollutants.
2 - Tentative identification, estimated concuntrations.
3 - The value indicates the highest csiimak'il«omcnlralion for a compound in this clussification. The number in parentheses indicated
the highest estimated concentration ik-lcclcil in (hi* classification.
a - Presumptive evidence of presence oi material, sot confirmed on GC/MS or second CC column. See footnote b.
b - Confirmed as GC/MS. The lack of a leachale indicates that the compound was confirmed on two different GC columns.
-------
m/nmu
.. _
/ ....--.. -jr-
'/ \ r ^ > < 1
-•-
"
.OVL*. y

500
lOOi
LEGEND

DCLSO-101 StDIMFNT SAMPLE COLLECTED
WEEK Or 05/19/85
CLSW-102 WATER AND SEDIMENT SAMPl
CLSO-102 COLLECTED WEEK OF 05/1 9/
ACLWS-107 WATER SAMPLE COLLECTED
ON 10/21/86
SOURCE: SOIL AND MATERIAL ENGINEERS INC
COLUMBIA. SOUTH CAROLINA
FIGURE 17 PHASE I SURFACE WATER AND SEDIMENT SAMPLING LOCATIONS
-------
MSHIMC cnrrx
SIAHON No. ?
o' no' »oo'
LAC RMIRDAf)
LCCCNO.
rRorrnnr IINF
a MMNiioniNC wru. (s tt MF)
• MONIIORIMC wru (CRA)
O PRIVATT WTIU
~ it i(x:AnoH or MAFIC OIKC
CRITK
IAIION No. I
FIGURE 18 PHASE II SURFACE WATER SAMPLING POINTS AND LEVELS OF CONTAMINATION
-------
TABLE 11

SUMMARY OF DEI ECTED COMPOUNDS 1'H A SO I
SIIHPACG WAII:H AND StDIMIJMl
CAHOIAWNSnii-H)HI I.AWN.SOimi CAROLINA
I'agc 1 of 2
Surfatt WaHrll)

Location Dtltction
D»te
ParomtttrO)
pll (field)
pll (K>t>)
Spec Cund (field>(4)
S|>ec Cund (Ub)(4)
Cliluiide
IDS
Antimony
Alumuuun
Arsenic
Barium
Beryllium
Cadmium
Chronuum
Cupper
Lead
Mercury
Nickel
Manganese
Selenium
Silver
Thallium
Zinc
Limit
<-,/L>

0.5

0005
002

0005

004
002

001
CLWS-107
Fitking Cr.
llpttrtfm
10/06
(""°
692
74
93
155
643
108

U
0178

U
CLWS 100
Fitking Cr.
Downitnnm
10/06
(mg/U
701
75
90
145
5.92
88

U
0200

Suifatl
nsw-102
Intermittent
i Fttttction
Limit
tmg,U

005

0.05
1.0
Oj02
001
005
010
005
00002
010

001
005
005
002
Slrtnm
5/05
0.,/U

U
U
U
II
II
II
II
II
II

II
II
U
004
\VaU,O)
CIStVIOS
1 liking I r.
Ufitrtam
5/05
I.«/U

U
U
II
II
U
U
II
II
U

II
11
II
(KM

CISW 106
I inking ( r.
Ooivnttnum
5/0i
(M£/J )

U
II
II
II
II
II
II
II
U

II
U
II
001

CISD10I
llil.h tvV.I
Dttedion
limit
f-|/»,)

05
100
02
(II
05
10
05
0002
10

01
05
05
02
of Hilt
5/85
Wt>

41
II
II
075
U
U
19
0016
11

11
U
U
U

cisn-102
InlrrmillMl
Slrtum
5/05
(-,/»«>

082
25
U
034
24
18
14
0007
11

U
U
U
83
Stdimtntnt
cisn-ioj
Jutermiltriil
Slttnm
5/05
(mglkgt

19
24
U
U
20
30
U
0015
30

1)
U
U
60

cisn-iM
Diltk F-tttt
of Silt
5/05
(mgllig)

60
72
U
U
13
25
38
00077
11

U
U
11
12

CLSDI05
fifking Cr.
Upttrtmm
5/05
(mglltg)

II
U
U
U
U
U
U
0011
U

U
U
U
U

cisn-106
F liking Cr.
Dotvnttnam
5/05
(mglkf)

U
U
U
U
U
U
U
00052
U

U
U
U
??(4)
-------
TABLE 11
(continued)
Page 2 of 2
SUMMARY OF DETECTED COMPOUNDS • PHASE I
SURFACE WATER AND SEDIMENT
CAROI.AWN SITE - FORT LAWN, SOUTH CAROLINA

Surfmci WnltHl) Surfmtt WnttrQl Semlmtmlffl
CltVS-107 C1WS 100 CLSMT-102 CLSW-US CLSW-106 CISD101 CISD-I02 CLSD-10J CISD-IW CLSD-105 CLSD-U*
tithing Cr. tithing Cr. Intermittent tithing Cr. tithing Cr. Ditch Wett Intermittent Intermittent Ditch Emit tithing Cr. tithing Cr.
Location Detection Ufttrtnm Duwntlream Detection Stream Ufttnnm Doumttnam Detection of Sit* Stream Strtum of Sit* Uftlrtnm Douinilrrnm
Dale Limit 10/86 10/86 Limit 5/85 5/85 5/05 Limit 5/05 5/05 5/05 5/05 5/05 5/05
Pa,amuter(3) (mg/L) (mg/L) (mgll) (M«/L) (mgILt (mglL) (mgll) (mglkg} (mg/kgt (mglkg) (mg/kg) (mglkg) (mglkg) (mglkg)
Volatile Orgenict (uglL) (ftgtL) (figlL) (figlL)

Melhylene Chloride 50 60 SO SO 57 U 30 SO 2IN I4B 6 IB 2SB I6B I9B
Acetone 100 50 7 7N H 7B S9B 9 7B 228 ' 458
Nulvs:

(I) Samples cullcctcd by SAME, Inc. on October 21, 1986, analyzed by IXivii. It Floyd. Inc.

(2) Samples collected by 11 AZTECH (he week of May 19, 1985; analyzed by CompuChcm laboratories.

(3) All inotdls analyzes were performed on unfillercd samples.

(4) SptMlic cunductanci! measurement in umhos/on.

U • Ntil delected within minimum attainable detection limit of sample.

0 • An.ilylr found in blank as well as sample. Possible/probable blank conliiinuulion
-------
-48-
TABLE 12
SUMMARY OF PHASE II SURFACE WATER SAMPLES
Sample
Location
Station 1
Station 2
Station 2
Duplicate
Station 1
Station 1
Duplicate
Station 2
Source
Fishing Creek
Fishing Creek
Fishing Creek
Fishing Creek
Fishing Creek
Fishing Creek
Date Contaminants Concentration
Same led Detected (microarams/ liter)
Round 1 None
Aug/Sept 1988
Round 1 None
Aug/Sept 1988
Round 1 None
Aug/Sept 1988
Round 2 Acetone
October 1988
Round 2 None
October 1988
Round 2 None
N/A
N/A
N/A
91.0
N/A
N/A
October 1988
-------
AREA WITHIN
100 YtAR n.000 PLAIN
" FISHING
CREEK
F: ITDFRAL FMERCENCf MANAGEMENT ACTENCf.
norm iNr.iiRAMCF. RATC MAP.
CMIMFR counnr. soum CAROUNA. 1982
FIGURE 19 FISHING CREEK 100 YEAR FLOOD PLAIN
-------
nnder present conditions, the risk posed by the inhalation of vapors and
suspended contaminated particulates in air has a very low probability.
Although the chemicals of concern for the site are volatile organics, the
removal of the contaminated soils and subsequent back filling with clean fill
by EPA in 1982 eliminated this pathway. EPA's 1982 removal was augmented by
the PRP sponsored 1986 removal action. Inorganics chemicals are reported in
surface soil but at levels that are typical for soils in general. Dust
exposure is further limited by a general covering of vegetation over the
site. This route of exposure may become important and require further
consideration if air stripping is used as part of the treatment train for
remediating contaminated groundwater.

Exposure to contaminated surface soil at the site was also evaluated. As
with the potential for exposure via the air pathway, the potential to
exposure to contaminated surface soils have also been eliminated by the
removal actions taken at the site. Therefore/ exposure to soil is not
considered a risk.

There is one domestic water supply wells drawing water from the bedrock
aquifer in the immediate vicinity of the site. The other residences adjacent
to the site which had private potable wells were connected to the public
water supply system in 1985 as an alternative water supply. The last time
the private well currently being used was sampled was in 1986. The
analytical data is presented in Table 5. This well is located upgradient of
the site and no contamination has been found in this residential well.
However, there are contaminants present in the groundwater downgradient and
beyond the property lines of the site at concentrations that exceed drinking
water standards and/or criteria. Since this land downgradient of the site is
privately owned, there is a possibility that some time in the future a
private water supply well could be installed downgradient of the site in the
contaminated aquifer. Therefore, potential future exposure pathways to
contaminated groundwater exist. They consist of consumption, inhalation and
dermal absorption.

Fishing in Fishing Creek can occur and since Fishing Creek is the primary
receptor of groundwater flowing beneath the site, contaminants emanating from
the site are entering the creek with the discharging groundwater. Therefore,
the exposure resulting from the consumption of fish from Fishing Creek was
evaluated.

Swimming in Fishing Creek is also a possible activity which could result in
exposure to contaminants originating from the site. Therefore, the exposure
to the surface waters in Fishing Creek was evaluated as a potential pathway
of exposure.

Table 13 summarizes the potential release mechanisms to the four primary,
environmental mediums of concern: air, surface water and sediment,
groundwater, and soils. Table 14 summarizes the identified potential human
exposure pathways associated with Carolawn site.
-------
-51-

TABLB 13

POTENTIAL PATHWAYS FOR EXPOSURE AT THE CAROLAWN SITE
RELEASE POTENTIAL RELEASE
MEDIUM RBT.gASB! SOURCE MECHANISM
RELEASE
TIME FRAME
RELEASE
PROBABILITY/AMOUNT*
Air
Contaminated
Surface Soil
Fugitive Dust
Volatilization
Chronic Low Probability/minor
Chronic Low Probability/minor
Surface Contaminated
Water Surface Soil
Groundwater
Surface Runoff
Groundwater
Chronic Low Probability/minor
Ground- Surface Soils Site Leaching Chronic 100% Probability/minor
water
Soil Surface Soils Site Leaching Chronic 100% Probability/minor
£ Wastes Direct Contact Episodic Low Probability/minor
* - Minor, moderate and major refer to comparison of release at this site and
do not attempt to quantify the release.
-------
TAB!
SUMMARY OF POTENTIAL HUMAN EXPOSURE PATHWAYS
TRANSPORT
MEDIUM SOURCE MECHANISM POINT
Air Surface Soil Volatilization Nearby
and Duet Residences
(Off-site)
On-site
Surface Water Contaminated Leaching River
Surface Soil Surface Runoff River
Ponds
Groundwoter Surface Soil Leaching Welle
t Ponds
Buried Wastes Leaching River (Surface
Discharge)
Soil Surface Soil Direct Contact On-site
(. Wastes
Off-site
HUMAN
ROUTE
Inhalation
Inhalation
Dermal
Pish Ingestion
Water Ingestion
Ingestion
(See Surface
Water)
Ingestion
Dermal
Inhalation
Ingestion
Dermal
Inhalation
SIZE OF
POPULATION
EXPOSED*
Small
Small
Small
Small
None
Hone
Small
Small
(See Air
On-site)
(See Air
Off-site)
PATHWAY
COMPLETE
NO
No
Yes
Yes
No
Yes
Yes
No
No

Estimated size of population involved at specific point of exposurei

Small - Less than 200
Medium - 200 to 2,000
Large - 2,000 to 20,000
Major - Over 20,000
-------
-53-
In summary, the media and exposure pathways which were examined are:

i) inhalation, consumption and dermal contact of contaminated
groundwater;
ii) inhalation, consumption and dermal contact of contaminated surface
water; and
iii) consumption of contaminated fish from Fishing Creek.

No endangered species were identified living on or near the site, and no
sensitive environments are impacted by the site.

Cancer potency factors (CPPa) have been developed by EPA's Carcinogenic
Assessment Group for estimates excess lifetime cancer risks associated with
exposure to potentially carcinogenic chemicals. CPFs, which are expressed in
units of (milligrams/kilogram-day)** , are multiplied by the estimated
intake of a potential carcinogen, in milligrams/kilogram-day, to provide an
upper-bound estimate of the excess lifetime cancer risk associated with
exposure at that intake level. The term "upper bound" reflects the
conservative estimate of the risks calculated from the CPF. Use of this
approach makes underestimation of the actual cancer risk highly unlikely.
Cancer potency factors are derived from the results of human epidemiological
studies or chronic animal bioassays to which animal-to-human extrapolation
and uncertainity factors have been applied.

Reference doses (R-Ds) have been developed by EPA for indicating the
potential for adverse health effects from exposure to chemicals exhibiting
noncarcinogenic effects. R£Ds, which are expressed in units of
milligrams/kilogram-day, are estimates of lifetime daily exposure levels for
humans, including sensitive individuals. Estimated intakes of chemicals from
environmental media (e.g., the amount of a chemical ingested from
contaminated drinking water) can be compared to the RfD. RfDs are
derived from human epidemiological studies or animal studies to which
uncertainity factors have been applied (e.g., to account for the use of
animal data to predict effects on humans). These uncertainity factors help
ensure that R-Ds will no4 underestimate the potential for adverse
noncarcinogenic effects to occur.

Excess lifetime cancer risks are determined by multiplying the intake level
with the cancer potency factor. These risks are probabilities that are
generally expressed in scientific notation (e.g., 1 x 10" or 1E-6). An
excess lifetime cancer risk of 1 x 10 indicates that, as a plausible
upper bound, an individual has a one in one million 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 a site.

Potential concern for noncarcinogenic effects of a single contaminant in a
single medium is expressed as the hazard quotient (HQ) (or the ratio of the
estimated intake derived from the contaminant concentration in a given medium
to the contaminant's RfD). By adding the HQs for all contaminants within a
medium or across all media to which a given population may reasonably be
exposed, the Hazard Index (HI) can be generated. The HI provides a useful
-------
-54-
reference point for gauging the potential significance of multiple
contaminant exposures within a single medium or across media.

3.7.1 Health Risk Associated with Groundwater

The health risk associated with exposure to contaminated groundwater off-site
ia summarized below.

1,1-Dichloroethene and trichloroethene exceed maximum concentration limits
(MCLs) in the groundwater off-site. Table 15 presents concentrations and
related estimated health risks in wells which represent the fence line
groundwater conditions. Estimates of future maximum concentrations of
groundwater concentrations immediately upgradient (toward the site) from
Fishing Creek and the related health risks are presented in Table 16.
Table 17 presents lead concentrations in groundwater. Estimates of mean
groundwater lead concentrations were determined by averaging detected lead
concentrations, and assigning the detection limit concentration of
5 micrograms/liter (ug/L) to samples with non-detect results. Mean of
19 ug/L and 9 ug/L were calculated for monitor wells MW-1 to MW-4 and
residential wells RW-1 to RW-4, respectively. These mean concentrations are
below the existing MCL of 50 ug/L but is above the proposed new MCL for lead
which is 5 ug/L.

The lifetime cancer risk due to exposure to these carcinogenic compounds at
present concentrations ranges from 1.64 x 10 to 8.40 x 10~5. This risk
range is above the range of risks (1 x 10 to 1 x 10" ) considered by
EPA to be protective of public health. Therefore, groundwater at these
levels of contamination are considered unacceptable for human consumption.
3.7.2 Health Risk Associated with Surface Water - Off-site

The health risk associated with exposure to contaminated surface water
off-site is summarized below.

The estimated lifetime cancer risk due to exposure of contaminant
concentrations that are and will be present in Fishing Creek ranges from
7.3 x 10"11 to 4.8 x 10~12 for swimmers. This is below the acceptable
range of 1 x 10~4 to 1 x 10~ . Consequently, there is no increase in
health risks to swimmers due to the exposure to the identified indicator
chemicals for the Carolawn site in Fishing Creek.

Table 18 provides the assumptions made for estimating exposure risks for
swimming in Fishing Creek and Table 19 summarizes the estimated health risk
due to each chemical.
-------
TABLE 15

ESTIMATED HEALTH RISK DUE TO SITE RELATED CHEMICALS
BY CONSUMPTION OF GROUNDWATER FROM WELLS REPRESENTING
BOUNDARY LINE CONCENTRATIONS
CAROLAWN SITE - FORT LAWN, S.C.
Chemical
MW3
Well Concentration W
(mgIL)
MW4 MW8
Added Cancer ^
Risk from Drinking
MW3
MW4
MW8
MW9
Exposure/ADI <3)

MW3 MW4 MW8
MW9
Acelone

1,1,1-TCA

1,2-DCE

1,1-DCA

1,1-DCE

TCE
3.23E+00 457E+00 5.7E-02 3.28E+00

1.17E-01 9.20E-02 5.0E-03 3.8E-02

UOE-01 3.75E-01 5.0E-03 7.4E-02

9.80E-02 9.20E-02 5.0E-03 3.8E-02

1.24E-01 9.20E-02 5.0E-03 3.8E-02

4.30E-01 3.95E-01 5.0E-03 4.5E-02
2.05E-03 1.52E-03 8.29E-05 6.30E-04

1.35E-04 1.24E-04 1.57E-06 1.41E-05
9.21E-01 1.31E+00 1.63E-02 9.37E-01

6.19E-03 4.87E-03 2.65E-04 2.01E-03

5.82E-03 1.98E-02 2.65E-04 3.92E-03

2.33E-03 2.19E-03 1.19E-04 9.05E-04
TOTALS 2.19E03 1.64E-03 8.40E-05 6.44E-04 9.35E-01 1.34E+00 1.70E-02 9.44E-01
NOTES:
(1J Mean concentration based on Phase II (Round 1 and 2) sampling results (Table 6)
(2) Added Cancer Risk - Based on assumptions and formula presented in Table 1.
(3) Exposure/Acceptable Intake Chronic ratio - Ratio below one (I) indicates no health concerns.
based on assumptions in Table 1.
Exposure
1,1,1-TCA — 1,1,l-Trichloroethane
1,1-DCE — l.l-Dichloroethene
TCE — Trichloroethene
1,1-DCA — 1,1-Dichloroethane
1,2-DCE — 1,2-Dichloroethene
-------
TABLE 16

PROJECTED POTENTIAL FUTURE HEALTH IMPACT
FROM CONSUMPTION OF CONTAMINATED GROUNDWATER
CAROLAWN SITE, FORT LAWN
SOUTH CAROLINA
Compound

Acetone
Creek Chemical
Concentration^ Exposure^) CPF
(mg/L) (mg/kg/day) (mg/kg/day)-^
6.52
0.179
1,1-Dichloroethane 5.0 x 10"3 1.43 x 10'4

1,1-Dichloroethene 9.0 x 10'2 2.57 x 10'3

1,2-Dichloroethene 3.4 xlO'1 9.71 x 10'3

1,1,1-Trichloroethane 3.6 xlO'2 1.03 xlO'3

Trichloroethene 7.9 x 10'1 2.26 x 10'2
5.80 x 10'1
l.lOxlO'2
ADI
(mg/kg/day)

l.OOxlO'1

1.20X10"1
2.0 x 10'2 <3>

5.40 x 10'1
Risk
1.49xlO'3
2.48 x 10-4
Exposure/
ADI

1.79

1.19X10'3
1.91 x lO"3
(1) As developed in Section 6 of -H* RI Report.
(2) Assumes consumption of 2.0 L groundwater per day by 70 kg adult.
(3) Based upon pMCL of 70 ug/L as given in 54 CFR 22062; May 22,1989.
-------
TABLE 17

PHASE I GROUNDWATER LEAD CONCENTRATIONS
CAROLAWN SITE - FORT LAWN, SOUTH CAROLINA
Sampling
Date MW-1 MW-2 MW-3 MVV-4 RW-1 RW-2 RW-3 RW~4

7/86 23 27 26 26 20 4 4 2.6

7/86 28

12/86 4 10 4 4 14
Monitoring Well Mean: 19
= 5ng/L)
Residential Well Mean: 9 Hg/L
Notes:

(1) This table summarizes lead concentrations given in Table
(2) Detection Limit = 5.
-------
TABLE 18

ASSUMPTIONS FOR ESTIMATING EXPOSURE AND
RISK FROM SWIMMING IN FISHING CREEK
CAROLAWN SITE - FORT LAWN, SOUTH CAROLINA
Page 1 of 2
ASSUMPTION
OLDER CHILD
6 TO IS YEARS
ADULT
19 TO 70 YEARS
Years Exposed
Body Weight (kg)

Swim Episodes:
• Times/Month
• Months/Year

Area of Body Exposed (on2)(2)
Absorption Rate (water)^

Percent Chemical Absorption^)
• Non-Carcinogens (%)
• Carcinogens (%)

Life Expectancy (years)
12
21
20
5

9,400
2mg/cm2/swim
1
50

70
35
70
20
5

18,000
2mg/on2/swim
1
50

70
Calculation to determine exposure for a carcinogen:

C x WA<1> x A x AF x Time x U.F.
CE--

where:

CE
C
WA
A
AF
Time

U.F.
BW x Days/Year x Years
BW
Days/Year
Years
Chemical Exposure (mg/kg/day)
Water Concentration (mg/L)
Water Absorption rate (mg/cm2/swim)
Area of the surface of the body (on2)
Absorption Factor • % chemical absorbed with the water x 100
Number of days exposed per year x number of years individual swims

u™tFactor=To5olnL
Body Weight (kg)
365 Days
Length of Lifetime (70 years)
Calculations of exposure for a non-carcinogen assumes the individual swims 5 times per week.
-------
Page 2 of 2
TABLE 19

ASSUMPTIONS FOR ESTIMATING EXPOSURE AND
RISK FROM SWIMMING IN FISHING CREEK
CAROLAWN SITE • FORT LAWN, SOUTH CAROLINA
2
The additional risk of cancer was calculated using the following formula:

R - CE x PF
Where:
R SB Lifetime additional risk of cancer from exposure CE
CE SB Chemical Exposure (mg/kg/day)
PF = Cancer Potency Factor (mg/kg/day)'1, Superfund Public Health Evaluation
Manual, Appendix C, Exhibit C-4

NOTE:

(1) Water-borne chemicals are assumed to be dermally absorbed at a rate equal to that of water.
This is supported in Chapter 6 of the Superfund Exposure Assessment Manual.

(2) Superfund Exposure Assessment Manual, April 1988, EPA/540/1-88/001.

(3) Hawley, J.K (1985) Risk Analysis. 5, No. 4, p. 295.
-------
TABLE 19

ESTIMATED HEALTH RISK
FROM SWIMMING IN FISHING CREEK
CAROLAWN SITE - FORT LAWN, SOUTH CAROLINA
CHEMICAL
Acetone
1 , 1 -Dichloroethane
1,1,-Dichloroethene
1 ,2-Dichloroethene
1,1,1-Trichloroethane
Trichloroethene
Totals
RIVER
FLOW*™
7
45
7
45
7
45
7
45
7
45
7
45
7
45
CONC. IN<2>
CREEK-mg/L
1.40E-03
2.00E-04
l.OOE-06
2.00E-07
2.00E-05
3.00E-06
8.00E-05
l.OOE-05
8.00E-06
l.OOE-06
1.80E-04
3.00E-05

ADDED"'
CANCER
RISK
NC
NC
NC
NC
4.09E-10
6.13E-11
NC
NC
NC
NC
6.97E-11
1.16E-11
4.78E-10
7.29E-11
EXPOSURE
6.27E-08
8.95E-08
3.73E-11
7.46E-12
NA
NA
6.63E-09
8.29E-10
6.27E-07
8.29E-11
NA
NA
6.34E-07
9.04E-08
W Creek flow on which groundwater dilution is based.

(2) Concentration estimate in creek based on groundwater flow and concentration estimates. See
Sections of *U BJ Rtport.

(3) Added Cancer Risk - Based on assumptions and formula presented in Table 18.

(4) Exposure/Acceptable Intake Chronic ratio. Ratio below one (1) indicates no health concerns.
Exposure based on assumptions in Table 18.
-------
-61-
3.7.3 Health Risk Associated with the Consumption of Piah

Using the assumptions that an individual consumes between 14 to 42 grams of
fish per day for his entire lifetime and that 10 percent of these fish
consumed come from Fishing Creek, the estimated increased lifetime risk of
cancer ranges from 1.7 x 10~8 to 2.7 x 10~9. This range also falls below
the acceptable range of 1 x 10 to Ix 10" . Consequently/ there is no
quantifiable increase in the health risk due to the consumption of fish
caught in Fishing Creek. Table 20 provides the assumptions used for
estimating exposure risks for consuming fish from Fishing Creek and
Table 21 summarizes the estimated health risk due to site related chemicals
from the consumption of fish from Fishing Creek.
4.0 CLEANUP CRITERIA

The extent of contamination was defined in Section 3.0, Current Site Status.
Section 4.0 examines the ARARs associated with the contaminants found on site
and the environmental medium contaminated. As discussed earlier, the primary
environmental medium of concern where concentrations of contaminants remain
that could prove detrimental to the public health and the environment is in
the groundwater. Table 22 provides a summary of the contaminants of concern
in the groundwater, the specific clean-up goal for each contaminant, and the
source for the specified ARAR.

Depending on the results from the confirmation soil sampling in the storage
area north of the fenced area, both Tables 22 and 23 may be expanded to
include soil cleanup goals. Table 23 provides the cleanup goals for the
contaminants of concern at the Carolawn site.
4.1 GROUNDWATER REMEDIATION

In determining the degree of groundwater clean-up, Section 121(d) of the
Superfund Amendment and Reauthorization Act of 1986 (SARA) requires that the
selected remedial action establish a level or standard of control which
complies with all ARARs, be cost-effective and achieve a clean-up level that
is protective of human health and the environment. Finally, the remedy
should utilize permanent treatment technologies to the maximum extent
practicable.

For those contaminants found in the groundwater at the site, Table 23
presents the remediation levels the remedial alternative needs to achieve.

4.2 SOIL REMEDIATION

The findings presented in the RI (the Public Health Evaluation {Chapter 7.0}
of the RI) indicates that the soils inside the fenced area do not pose a risk
to the public health or the environment. Therefore, no remediation is
proposed for this environmental medium.
-------
TABLE 20

ASSUMPTIONS FOR FISH INGESTION SCENARIO
CAROLAWN SITE
FORT LAWN, SOUTH CAROLINA
Chemical

Acetone

1,1-Dichloroethene

1,2-Dichloroethene

1,1,1 -Trichloroethane

Trichloroethene

Lead
Bioconcentration
Factor
Non-Carcinogen
Acceptable
Daily
Intake
Carcinogen
Unit
Cancer
Risk
>
-1
(BCF)
(I/kg)
NA
5.6
NA
cis-1.6
trans- 1.6
5.6
10.6
49
(ADD
(mg/kg/day)
1.00 E- 01
9.00 E - 03
120 E- 01
cis - 2.0E - 03*
trans - 2.9E - 03*
5.40 E- 01
NA
1.40 E- 03
(UCR)
(mg/kg/day)
NA
5.80 x 10'1
NA
NA
NA
NA
1.10 E - 02
NA
Quantity of fish consumed per day:
Average intake (chronic)
Maximum intake

Lifetime

Average Body Weight
14 grams
42 grams

70 years

70kg
* Based on EPA Proposed MCLs in 54 FR 22062; May 22,1989 for 1,2-Dichloroethene, 2.0L water
consumption per day, 70 kg total body mass.
-------
TABLE 21
ESTIMATED HEALTH RISK
FROM EATING FISH FROM FISHING CREEK
CAROLAWN SITE - FORT LAWN, SOUTH CAROLINA
CHEMICALS

Acetone

1,1 -Dichloroethane

1,1-Dichloroelhene

1,2-Dichloroethene

1,1,1-Trichloroethane

Trichloroethene

Totals

(1) Creek flow on which groundwater dilution is based.

(2) Concentration estimate In creek based on groundwater flow and concentration estimates. See Section 6 of
FLOW'1*
cf*
7
45
7
45
7
45
7
45
7
45
7
45
7
45
CONC. IN*2>
CREEK rng/L
1.40E-03
2.00E-04
1.00E-06
2.00E-07
2.00E-05
3.00E-06
8.00E-05
l.OOE-06
8.00E-06
l.OOE-06
1.80E-04
3.00E-05

ADDED CANCER
RISK <3>
LO INTAKE HI INTAKE
NC
NC
NC
NC
1.30E-08
1.95E-09
NC
NC
NC
NC
4.20E-0?
7.00E-10
. 1.72E-08
2.65E-09
NC
NC
NC
NC
3.90E-08
5.85E-09
NC
NC
NC
NC
1.26E-08
2.10E-09
5.16E-08
7.95E-09
EXPOSURE/AIC «>
LO INTAKE HI INTAKE
2.80E-06
4.00E-07
. 2.00E-10
400E-07
NA
NA
4.74E-08
5.98E-09
1.66E-08
2.07E-09
NA
NA
2.86E-06
4.08E-07
8.40E-06
1.20E-06
6.00E-10
1.20E-10
NA
NA
1.42E-07
1.78E-08
4.98E-08
6.22E-09
NA
NA
8.59E-06
1.22E-06
Rep««-f .
(3) Added Cancer Risk. Based on assumptions presented in Table 1 that individual eats the designated quantity of fish (Lo-14 grams per day;
Hi-42 grams per day) for 70 years lifetime.

<4) Exposure/ Acceptable Intake Ratio. If ratio is less than one (1) there is no health concern. Intake is based on same level of fish consumption
in Note (3' above.
-------
TABLE 2 2

CHEMICAL SPECIFIC ARARS
CAROLAWN SITE, FORT LAWN, SOUTH CAROLINA
Acetone

1,1-Dichloroethane

1,2-Dichloroethene

1,1-Dichloroethene

1,1,1 -Trichloroethane

Trichloroethene

Lead
MCI.™
NA
NA
NA
7
200
5
50
pMCL<5>
700(6)
NA
NA
NA
NA
NA
5(8)
WQC<»
3,500"
4,200*
350<4>
0.033
18,400
2.7
50
PMCLG<6>
NA
NA
cis-70
trans-100
NA
NA
NA
0(8)
Aquatic Lifea>
610,000
55,000
22,000
58,000
58,000
4,070
3.3<^
(1) WQC - Water Quality Criteria - FR Vol. 45, No. 231, Nov. 28,1980. For Protection of Human
Health from Drinking Water and Aquatic Food. Carcinogens - IxlO"6 added lifetime risk.
'Developed by application of AIC Limit, Exhibit A-6 of the Superfund Public Health Evaluation
Manual. Assume 70 kg man drinks 2 liters per day.

(2) MCL - Maximum Concentration Limits. The Manual Exhibit 4-5 and FR Vol. 52, No. 135,
July 8,1987.

NA = Not Available

(3) Criteria for Protection of Aquatic Life (Freshwater) FR Vol. 45, No. 231, Nov. 28, 1980.
If not available in FR reference, calcualted at l/10th the 96 hour LCso as reported in Verschieren,
Handbook of Environmental Data on Organic Chemicals, 2nd Edition, VanNostrand Rheinhold
Company, New York, 1983. •

(4) EPA Drinking Water Health Advisories - Lifetime. Exhibit 4-8. The Manual.

<5) Proposed Maximum Contaminant Level. EPA Proposed National Primary and Secondary Drinking
Water Regulations. 54 FR 22062; May 22, 1989.

(6) Proposed Maximum Contaminant Level Goals. EPA Proposed National Primary and Secondary
Drinking Water Regulations 54 FR 22062; May 22, 1989. 4

(7) Criterion at 100 p.g/L hardness as CaCO^.

(8) EPA Proposed MCLGs and National Primary Drinking Water Regulations for Lead and Copper.
53 FR 31516; August 18,1988.
-------
-65-
TABLB 23

CLEANUP GOALS FOR THE CONTAMINANTS POUND
AT THE CAROLAWN SUPERFUND SITE
LEVELS ARE IN MICROGRAMS/LITBR (ug/L)
CHEMICAL
CLEANUP GOAL
BASIS FOR CLEANUP GOAL
Acetone

1,1-Dichloroethane

1,1-Dichloroethene

1,2-Dichloroethene

1,1,1-Trichloroethane

Trichloroethene

Lead
700
70 - cis
100 - -brans

200

5
MCL

Proposed MCL
Proposed MCL

MCL

Proposed MCL
+ - The value of 700 ppb for acetone is a lifetime health advisory (LHA).

* - No firm cleanup criteria has been established but it is assumed that due
to 1,1-Dichloroethane similar chemical/physical characteristics with the
other contaminants present, the levels will decrease proportionally along
with the other contaminants.
-------
-66-

As discussed above, the soils in the area north of the fenced area, depending
on the confirmatory samples, may require remediation.

4.3 SURFACE WATER/SEDIMENT REMEDIATION

Only methylene chloride, which is believed to be a laboratory induced
contaminant based on QA/QC data, and acetone were detected in the surface
water samples. Acetone was found sporadically in the samples collected. No
other TCI. compounds were detected in the water column.

The sediment samples collected from the drainage courses near the site and
Fishing Creek did not contain any TCL organic compounds attributable to the
site. The total metals concentrations are within typical natural levels for
soils with similar geographical conditions as found as the Carolawn site.

Both these facts indicates that the overland flow and surface water runoff
from the site has not resulted in the accumulation of contamination in the
drainage courses. Even under 7Q1Q flow conditions, the rate and level of
discharge of contaminants with the groundwater into Fishing Creek will not
surpass the Ambient Water Quality Criteria (AWQC) for the contaminants of
concern. The AWQC are listed in Table 22.
5.0 ALTERNATIVES EVALUATED

The purpose of the remedial action at the Carolawn Site is to minimize, if
not mitigate contamination in the groundwater and to reduce, if not
eliminate, potential risks to human health and the environment. The
following clean-up objectives were determined based on regulatory
requirements and levels of contamination found at the Site:

* Prevent the near-term and future exposure of human receptors to
contaminated groundwater both on and off site;

* Restore the contaminated aquifer for future use by reducing
contaminant levels to those which will adequately protect human
health and the environment;

* Control contaminant migration so contaminant releases from
groundwater to Fishing Creek do not exceed clean up criteria to
human health and the environment;

* Monitor groundwater in a manner to verify effectiveness of remedial
measures; and

* Confirm absence/presence of soil contamination in storage'area north
of the fenced area.

Table 24 provides a list of possible remedial technologies applicable at the
Carolawn Site knowing the environmental media affected, the type of
-------
TABLE 24
Page 1 of 2
GROUNDWATER REMEDIAL TECHNOLOGIES AND PROCESS OPTIONS
CAROLAWN SITE, FORT LAWN, SOUTH CAROLINA
Applicable Response Action
Remedial Technology
Process Options
Alternate Water Supply
Groundwater Extraction
Containment
Groundwater Treatment
Connection of future users to municipal
water supply

Extraction of contaminated groundwater
from bedrock aquifer

Hydraulic containment by extraction
Physical Containment

Biological

Activated Carbon

Air Stripping
• Connect to existing supply line
• Connect to a new supply line to be constructed

• Pumped extraction wells
• Pipe and media drain

• Grout curtain

• Activated sludge
• Aerobic/facultative lagoons
• Fixed film systems
• Granular Activated Carbon (GAC)
• Powdered Activated Carbon (PAC)

• Packed tower stripper
• Aeration basin
-------
TABLE 2 4
(continued)

GROUNDWATER REMEDIAL TECHNOLOGIES AND PROCESS OPTIONS
CAROLAWN SITE, FORT LAWN, SOUTH CAROLINA
Page 2 of 2
Applicable Response Action

Ground water Treatment (conl'd.)
Groundwater Disposal
Remedial Technology
• Oxidation
• Ion Exchange
• Reverse Osmosis
• Evaporation
Disposal to POTW for treatment
Disposal at a RCRA facility
for treatment

Reinjection
Discharge to POTW
Discharge to surface waters
Disposal at a RCRA facility
Process Options
• Solar evaporation
• Spray evaporation
• Forcemain
• Bulk transportation by tanker truck
Injection wells
-------
-69-
contaminants present and the concentration of each contaminant in each
environmental medium. The initial screening evaluates the technologies on
the following technical parameters:
* implementability.
* reliability and effectiveness, and

* previous experience.

Table 25 provides a summary of the initial screening of the remedial
technologies and the rationale as to why certain technologies were eliminated
from future consideration.

These technologies address groundwater and best meet the criteria of Section
300.65 of the National Contingency Plan (NCP).

Following the initial screening of the individual technologies, these
technologies were combined to form a number of remedial action alternatives.
These remedial action alternatives are than screened and analyzed in relation
to the nine point criteria. Table 26 lists the five remedial alternatives
and remedial technologies (components) involved in each alternative.

5.0.1 Alternative 1 - No Action

The "No Action" alternative assumes that no remediation of the contaminated
groundwater, other than by natural attenuation would occur. The NCP requires
the development of a No Action alternative as a basis for the comparison of
alternatives. This alternative would include maintenance of the existing
alternative water supply to the four affected residences and long-term
monitoring.

Since no remedial action is taken, there would be no additional risks poeed
to the community. However, it is estimated that the grovndwater between the
site and Fishing Creek would remain contaminated above MCLs for greater than
50 years. This alternative provides no reduction in the toxicity, mobility,
or volume of contaminants through treatment, therefore, the potential future
risk of exposure to off-site contaminated groundwater remains.

5.0.2 Alternative 2 - Alternative Water Supply and Institutional Controls

Alternative 2 will result in the construction of a new water supply line to
replace the existing line serving the residents adjacent to the site. As
part of this alternative, institutional controls (deed restrictions) will be
placed on all adjacent properties.
-------
TABLE 2 5
Page 1 of 3
SCREENING OF GROUNDWATER REMEDIAL TECHNOLOGIES
CAROLAWN SITE, FORT LAWN, SOUTH CAROLINA
Remedial Technology
Applicable As a
Remedial Alternative
Compotietu
Commett&s
1. Alternative Water Supply

« Connect to Existing Supply lane
• Connect to a New Supply Line
to be Constructed
No Existing community already connected.
Existing line does not have sufficient capacity
for future connections.
Yes Provides sufficient capacity for future connections.
2. Groundwater Extraction

• Extraction Wells
• Pipe and Media Drain
Yes Collects ground water and prevents future migration.
Will reduce levels of contamination over time.
May be ineffective in low permeability soils or
competent rock.

No Difficult and costly to construct.
3. Containment
Hydraulic containment
by extraction
• Physical Containment by
Grout Curtain
4. Groundwater Treatment

• Biological

i) Activated Sludge
Yes
No
No
Effectively same remedial technology as
ground water extraction.
Difficult to implement where competence of bedrock
is variable. Costly to construct Effectiveness is
typically poor for bedrock with variable competence
Difficult to sustain process with low levels of
hydrocarbon feed from groundwater environment.
-------
TABLE2 5
(continued)
SCREENING OF GROUNDWATER REMEDIAL TECHNOLOGIES
CAROLAWN SITE, FORT LAWN, SOUTH CAROLINA
Page 2 of 3
Remedial Technology
Applicable A» a
Remedial Alternative
Component
Comments
4. Groundwater Treatment (cont'd.)

• Biological

ii) Aerobic/facujtative lagoons Yes

iii) Fixed film systems No
Microbial community varied and more capable of
being self-sustaining with low levels of hydrocarbon
feed from groundwater.

Same limitations as for activated sludge.
« Activated Carbon (GAC or PAC)
Air Stripping

i) Packed Tower Stripper
ii) Aeration Basin
• Oxidation

• Ion Exchange

• Reverse Osmosis
Yes Effective in treating large array of organic
contaminants. Can be used as primary treatment
or as polisher in combination with other treatment
technologies.
Yes Effective in removing volatile compounds. May
require pretreatment or additional polishing
by other technology. Most effective for high
concentration of vola tiles.

Yes Effective in removing volatile compounds. Does
not require pretreatment. May require additional
polishing by other technology. Effective for low
concentrations of volatiles.

No Not effective in treating contaminants found
during waste characterization at this Site.

No Used to treat inorganic wastes (Le. metals),
therefore, not applicable at this Site.

No Used to treat inorganic waste (i.e. metals), and high
molecular weight organics therefore, not generally
applicable at this Site. Also, highly subject to
fouling by precipitates and biological growth.
-------
TABLE2 5
(continued)
SCREENING OF GROUNDWATER REMEDIAL TECHNOLOGIES
CAROLAWN SITE, FORT LAWN, SOUTH CAROLINA
Page 3 of 3
Remedial Technology
Applicable At a'
Remedial Alternative
Component
Comments
4. Groundwater Treatment (cont'd.)

• Evaporization

i) Solar Evaporization

ii) Spray Evaporization
• Discharge to POTW for Treatment
Disposal at a RCRA Facility
for Treatment
5. Groundwater Disposal

• Reinjection
No May be effective in treating volatile compounds
especially during summer months. Effectiveness
is difficult to evaluate

No May be effective in treating volatile compounds,
especially during summer months. Presence of other
non-volatile compounds may restrict use of this
technology. Effectiveness is difficult to evaluate.

Yes Would be restricted by operating permit
of POTW.
No Difficult to implement and maintain in long term.
Cost prohibitive.
No Injection of contaminants to a Class GB aquifer is
prohibited
• Disposal at a RCRA Facility
Discharge to Surface Water
Discharge to POTW
No Difficult to implement and maintain in long term.
Cost prohibitive. Not cost-effective if ground water
treated on-Site.

Yes Cost effective. Groundwater must meet
surface water criteria prior to discharge.

Yes Would be restricted by operating permit of POTW.
May not be required if groundwater treated on-Site.
-------
TABLE 2 6

ASSEMBLED REMEDIAL ALTERNATIVES FOR DETAILED ANALYSIS
CAROLAWN SITE, FORT LAWN, SOUTH CAROLINA
Page 1 of 1
Alternative
No.
Alternative Description
Remedial Components
I.
2.
3.
No Action
Alternate water supply
Groundwater Extraction with Discharge
toPOTW
Ground water Extraction with
Treatment (Aeration) and Discharge
to Fishing Creek
Groundwater Extraction with
Biological Treatment and Discharge
to Fishing Creek
• Institutional deed restriction
• Long term monitoring

• Institutional deed restriction
• Long term monitoring
• Construction of new water supply line
to service adjacent areas for future
development

• Institutional deed restriction
• Long term monitoring
• Installation of Groundwater Extraction
System
• Construction of Discharge Line to
POTW Collection System
• Extraction with Direct Discharge
to POTW System

• Institutional deed restriction
• Long term monitoring
• Installation of Groundwater Extraction
System
• Installation of Aeration Treatment System
• Extraction with treated discharge
to Fishing Creek

• Institutional deed restriction
• Long term monitoring
• Installation of Groundwater Extraction
System
• Construction of Aerobic/Facultative
Lagoons
• Extraction with treated discharge
to Fishing Creek
-------
-74-

Since this alternative does not require remedial activities for the
groundwater, there are no short term impacts associated with this
alternative. As with Alternative 1, this remedial alternative does not
directly address the contaminated groundwater below the site. Consequently,
the residual risk will remain unchanged as there is no reduction in toxicity,
mobility or volume.

The institutional controls may be effective for new residential developments
due to the public tendency to avoid the use of identified contaminated
water. This, however, may not be the case where a residence is constructed
away form the supply line and the cost to the property owner of connecting to
and using the supplied water is greater than the cost of installing a private
well.

This alternative is capable of protecting human health in the short-term due
to the measures which allow the community to avoid the use of the
contaminated groundwater. However, since this alternative does not directly
mitigate the groundwater transport pathway and/or contaminant levels, the
long term protection of human health will be limited by the ability to
enforce the institutional controls. The construction activities for this
alternative is not expected to pose any additional risk to the community.
5.0.3 Alternative 3 - Groundwater Extraction and Discharge to the POTW

Alternative 3 will consist of the installation of a groundwater extraction
system for hydraulic containment and active restoration of the groundwater,
and the construction of a forcemain to the local POTW collection system.
Specific remedial activities will include:

i) the construction of rough grade access roads to the extraction
well locations;

ii) the installation of groundwater extraction wells;

iii) the conducting of pumping tests on each extraction well;

iv) the construction of a pump station at each extraction well;

v) the construction of forcemains to convey the extracted groundwater
to the POTW; and

vi) long-term monitoring.

Due to the nature of the aquifer beneath the site (fractured bedrock), the
use of extraction wells is the only feasible method to achieve hydraulic
containment.

This alternative will result in the removal and treatment of contaminated
groundwater from beneath and downgradient of the site. Therefore, the
alternative is effective in reducing the potential future residual risk
-------
-75-
associated with exposure to contaminated groundwater. It is estimated that
approximately 10 years of pumping are required to achieve the cleanup goals
on site and off site.

This alternative will result in the reduction of toxicity, mobility and
volume of contaminants. Since the extracted groundwater will be discharged
to the sanitary sewer, treatment will occur to some degree within the
wastewater treatment plant. The mobility of the contaminants within the
groundwater to Fishing Creed is effectively eliminated by hydraulic capture
and the volume of contaminants in the groundwater is reduced over the life of
the remedy.

This alternative is protective of human health and the environment through
the collection of the contaminated groundwater and treatment of the
groundwater in the local POTW. This alternative also prevents the continued
migration of groundwater to Fishing Creek.

5.0.4 Alternative 4 - Groundwater Extraction with Aeration Treatment and
Discharge to Fishing Creek

Alternative 4 consists of groundwater extraction with treatment of the
extracted groundwater followed by discharge to Fishing Creek. This
alternative utilizes the same extraction system components previously
described for Alternative 3. However, instead of discharging directly to the
POTW system, the extracted groundwater is treated on-site using an aeration
system, then discharged to the adjacent surface water via a NPDES permit.

As discussed for Alternative 3, the extraction system will significantly
reduce the environmental mobility and volume of contaminants in the
groundwater. The treatment technology used in this alternative does not
directly result in the reduction of toxicity, mobility, or volume of
contaminants through treatment. Instead, the contaminants are removed from
the liquid medium and transferred to the gaseous medium. Some degree of
treatment is achieved subsequently through natural processes such as
photo-oxidation and environmental biodegradation.

This alternative is considered to be protective of human health and the
environment. The alternative addresses both the pathway of concern and the
contaminants of concern.
5.0.5 Alternative 5 - Groundwater Extraction with Biological Treatment and
Discharge to Fishing Creek

Alternative 5 consists of groundwater extraction with treatment of the
extracted groundwater followed by discharge to Fishing Creek. This
alternative is identical to Alternative 4, with the exception of the
treatment technology which is utilized. Treatment of the extracted
groundwater consists of biological treatment using an aerobic/facultative
lagoon.
-------
-76-
As discussed for Alternative 3, the extration system will significantly
reduce the environmental mobility and volume of contaminants in the
groundwater. the treatment technology used in this alternative will result
in the direct reduction of toxicity, mobility, or volume of contaminants
through biological treatment. Some additional degree of treatment is also
achieved in the lagoon through natural processes such as photo-oxidation and
evaporation.

This alternative is considered to be protective of human health and the
environment. The alternative addresses both the pathway of concern and the
contaminants of concern.
5.1 NINE POINT EVALUATION CRITERIA FOR EVALUATING REMEDIAL ACTION
ALTERATIVES

The five remedial alternatives were individually evaluated to determine which
alternative provides the "best balance" of tradeoffs with respect to the
following evaluation criteria:
Threshold Criteria
Primary Balancing
Criteria
Modifying Criteria
i) Overall protection of human health and the
environment; and
ii) Compliance with applicable or relevant and
appropriate requirements.

iii) Long-term effectiveness and permanence;
iv) Reduction of toxicity, mobility, or volume;
v) Short term effectiveness;
vi) Implementability; and
vii) Costs.

viii) State/support agency acceptance; and
ix) Community acceptance.
Based on the individual evaluations, the remedial alternatives were
subsequently compared for their relative performance against the evaluation
criteria. The two Modifying Criteria which could not be evaluated in the
Feasibility Study are included below.

Based on the statutory language and current U.S. EPA guidance, the nine
criteria used to evaluate the remedial alternatives listed above were:
-------
-77-
1. Overall Protection of Human Health and the Environment
addresses whether or not the remedy provides adequate
protection and describes how risks are eliminated, reduced or
controlled through treatment, engineering controls, or
institutional controls.

2. Compliance with ARARa addresses whether or not the remedy
will meet all of the applicable or relevant and appropriate
requirements of other environmental statues and/or provide
grounds for invoking a wavier.

3. Lono-Term effectiveness and permanence refers to the ability
of a remedy to maintain reliable protection of human health
and the environment over time once cleanup goals have been
met.

4. Reduction of toxicitv. mobility, or volume is the anticipated
performance of the treatment technologies a remedy may
employ.

5. Short-term effectiveness involves the period of time needed
to achieve protection and any adverse impacts on human health
and the environment that may be posed during the construction
and implementation periods until cleanup goals are achieved.

6. Implementabilitv is the technical and administrative
feasibility of a remedy including the availability of goods
and services needed to implement the chosen solution.

7. Cost includes capital and operation and maintenance costs.

8. Support Agency Acceptance indicates whether, based on its
review of the RI/FS and Proposed Plan, the support agency
(IDEM) concurs, opposes, or has no comment on the preferred
alternative.

9. Community Acceptance indicates the public support of a given
remedy. This criteria is discussed in the Responsiveness
Summary.

Table 27 summarizes the factors that are considered under each of the
nine evaluation criteria.
-------
-78-

TABLE 27

DETAILED ANALYSIS CRITERIA AMD FACTORS
EVALUATION CRITERIA

Threshold Criteria

Overall protection of
human health and the
environment

Compliance with
applicable or
relevant and
appropriate requirements

Primarv Balanci.no Criteria
EVALUATION FACTORS
* Elimination, reduction, or control of
risks
* Compliance with contaminant-specific
ARARS
* Compliance with action-specific
* Compliance with location-specific
Long-term effectiveness
and permanence;
Reduction of toxicity,
mobility, or volume;
Short-term effectiveness
Implementability
Costs
* Magnitude of residual risk
* Adequacy of controls
* Reliability of controls

* Treatment process used and materials
treated
* Amount of hazardous materials
destroyed or treated
* Type and quantity of residuals
remaining after treatment
* Degree of expected reductions in
toxicity, mobility, and volume
* Degree to which treatment is
irreversible

* Protection of community during
remedial action
* Protection of workers during remedial
action
* Time until objectives and protection
are achieved
* environmental impacts

* Technical feasibility
* Administrative feasibility
* Availability of services and
materials

* Total capital costs
* Operating and maintenance costs
* Total present worth cost at 5 percent
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-79-
TABLE 27
(continued)

DETAILED ANALYSIS CRITERIA AMD FACTORS
EVALUATION CRITERIA
EVALUATION FACTORS
Modifying Criteria

State/support agency

Community acceptance
* Level of community acceptance
* Specific comments of State
* Impact of the selected remedy on the
State and the community

* Level of community acceptance
* Specific comments from the Community
* Impact of the selected remedy on the
community
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-80-
All of the alternatives, with the exception of the no action alternative,
would provide adequate protection of human health and the environment by
eliminating, reducing, or controlling risk from the environment through
treatment, engineering controls or institutional controls. As the no action
alternative (Alternative 1) does not satisfy the remedial action goal to
provide adequate protection of human health and the environment, it is not
eligible for selection. Although Alternative 2 would be protective of human
health, the degree of protection is dependent on the ability to enforce the
identified institutional controls. Alternative 2 is eliminated from further
consideration for the following two factors: this alternative does not
address the remediation of groundwater, resulting in the continuing residual
risk of contamination of the groundwater remaining unchanged and secondly,
the limited ability of EPA, the State or the local government to strictly
enforce the institutional controls at the site.

Alternatives 3, 4, and 5 address the residual risk associated with
groundwater in terms of mitigating both the transport pathway and contaminant
levels. Consequently, they are deemed to provide the best overall protection
to human health and the environment. Due to the potential for minimal air
emissions from Alternative 4, this alternative is deemed to be marginally
less protective than the other two treatment alternatives during the period
of implementation.

The overall level of protection reduces accordingly with Alternative 2 and
Alternative 1 due to concerns over the adequacy of the institutional controls
and the failure to address the groundwater transport pathway and contaminant
levels.
5.1.2 COMPLIANCE WITH ARARS

The ARARs which were determined to be applicable to the remedial alternatives
included MCLs for the groundwater, surface water criteria for discharges to
Fishing Creek and pretreatment requirements for the POTW.

Alternatives 1 and 2 will not achieve MCLs for at least 50 years whereas
Alternatives 3, 4 and 5 are expected to achieve MCLs within ten years.

Alternatives 4 and 5 will achieve approximately the same level of compliance
with the surface water ARARs. Minor exceedances of the health-based criteria
will occur under the 7Q1Q flow condition, however, these are deemed to be
not significant.

Compliance with the POTW pretreatment requirements for Alternative was not
assessed and is not expected to be major hurdle.
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-81-
5.1.3 LONG-TERM EFFECTIVENESS AND PERMANENCE

Alternatives 3, 4 and 5 will result in long-term effective remedies which
will reduce the magnitude of the residual risk associated with the
contaminated groundwater. Since these three alternatives utilize the same
groundwater extraction component, they are deemed to be equivalent in terms
of long-term effectiveness and permanence.

Alternatives 1 and 2 do not directly address the contaminated groundwater;
consequently they are deemed to less effective in the long-term than the
other alternatives.
5.1.4 REDUCTION OP TOXICITY.. MOBILITY. OR VOLUME

The greatest degree of reduction of toxicity, mobility, or volume of
contaminants is achieved by Alternatives 3 and 5, followed by Alternative 4.
All three of these alternatives will reduce the mobility and volume of
contaminants within the groundwater flow system to the same extent. However,
Alternatives 3 and 5 utilize biological treatment to reduce the toxicity of
extracted contaminants whereas Alternative 4 indirectly achieves a reduction
in toxicity. Alternative 4 which employs air stripping, results in the
transfer of contaminants from the groundwater to the atmosphere.
Consequently, Alternative 4 is deemed to be less effective for this
evaluation factor.

Alternatives 1 and 2 do not require extraction and treatment of contaminated
groundwater; therefore these alternatives do not address this evaluation
factor.
5.1.5 SHORT-TERM EFFECTIVENESS

The degree of short-term effectiveness achieved by the alternatives which
involve remedial action on the groundwater is ei sentially the same for
Alternatives 3, 4 and 5 due to the identical groundwater remedial component
for each alternative. Of these three alternatives, Alternatives 4 and 5 will
have greater potential for environmental impacts, however, the estimated in
stream concentrations for these two alternatives indicate that this impact is
negligible. Alternative 4 will result in increased air emissions compared to
Alternative 5, however, the impact is not deemed to be significant.

Alternatives 1 and 2 do not directly address the contaminated groundwater;
consequently, they are deemed to be less effective in the short-term than the
other three alternatives.
5.1.6 IMPLEMENTABILITY

There are no major foreseeable implementability concerns for any of the
remedial alternatives. The technologies used for these alternatives rely on
standardized construction methods and demonstrated technologies. For the
-------
-82-
treatment alternatives, the administrative concerns include the ease of
obtaining NPDES permits for Alternatives 4 and 5, and the capabilities and
capacity of the POTW for Alternative 3. Based on the type and concentrations
of contaminants of concern, these concerns are not deemed to be sufficiently
significant to eliminate any of the treatment alternatives from further
cons iderat ion.
5.1.7 COST

The costs associated with implementation of the remedial alternatives are
lowest for the "no action" alternative and increase successively for
Alternatives 2, 4, 5, and 3. Since Alternative 1 does not involve capital
construction, the total present worth for this alternative is attributable to
leng-term monitoring and maintenance costs only. The total costs for the
other alternatives consists of capital and operation and maintenance costs.

For those alternatives involving capital construction, the capital cost
estimates range from $243,750 for Alternative 2 to $802,670 for
Alternative 3. The long-term operation and maintenance costs range from
$331,914 for Alternatives 1 and 2 to $645,833 for Alternative 5. For those
alternatives which consist of both capital and operation and maintenance
costs, the operation and maintenance cost components are significant, being
of the same order of magnitude as the capital costs.

The total present worth of the alternatives vary from a low of $331,914 to a
high of $1,365,305. In increasing order of total costs, the alternatives are
Alternative 1, Alternative 2, Alternative 4, Alternative 5, and
Alternative 3. The total costs for the treatment alternatives are all within
the same magnitude whereas the total costs for the other two alternatives are
only a fraction thereof.

Table 28 provides a comparison of costs for each alternative evaluated over a
10 year period and a 30 year period.
5.1.8 STATE ACCEPTANCE

The State of South of Carolina concurs with the selected remedial
alternative.
-------
TABLE 2 8

COST SENSITIVITY ANALYSIS
10 YR VS. 30 YR DURATION

CAROLAWN SITE, FORT LAWN, SOUTH CAROLINA
Percent
10 Year Period 30 Year Period Increase
Alternative Capital O&M Total Capital ObM Total in Total
Cost Cost Cost Cost Cost Cost Cost

1) No Action $0 $331,914 $331,914 $0 $331,914 $331,914 0%

2) Alternative Waler Supply $243,750 $331,914 $575,664 $243,750 $331,914 $575,664 0%

3) Direct Discharge to POTW $802,670 $553,635 $1,356,305 $802,669 $753,433 $1,556,102 15%

4) Aeration Treatment and Discharge to Fishing Creek $504,807 $636,264 $1,141,071 $504,806 $898,828 $1,403,634 23%

5) Facultative Lagoon Treatment and Discharge tc r Mng Creek $525,931 $645,833 $1,171,764 $525,931 $916,723 $1,442,654 23%
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-84-
5.1.9 COMMUNITY ACCEPTANCE

The draft RI and FS documents along with the Proposed Plan for the Carolawn
site were released to the public in August 1989. These three documents were
made available to the public in the administrative record file and an
information repository maintained at the EPA Docket Room in Region IV and at
the Lancaster County Public Library. The notice of the public meeting and
the availability for these two documents and the Administrative Record was
published in the Lancaster News on August 25, 1989 and the Chester News and
Reporter on August 28, 1989. A public comment period was held from
August 28, 1989 through September 22, 1989. In addition, a public meeting
was held at Lancaster County Public Library meeting room on August 30, 1989.
At this meeting, representatives from EPA and the South Carolina Department
of Health and Environmental Control answered questions about problems at the
site and the remedial alternatives under consideration. A response to the
comments received during this period is included in the Responsiveness
Summary, which is part of this ROD. The Responsiveness Summary also assesses
the community acceptance of the Agency's proposal. This decision document
presents the selected remedial action for the Carolawn site, in Fort Lawn,
South Carolina, chosen in accordance with CERCLA, as amended by SARA, and to
the extent practicable, the National Contingency Plan. This decision, for
this site, is based on the Carolawn administrative record file.
6.0 RECOMMENDED ALTERNATIVE

Table 29 furnishes a summary of the detailed analysis on the remedial
alternatives considered for the Carolawn Superfund site.

6.1 DESCRIPTION OF RECOMMENDED REMEDY

MIGRATION CONTROL (Remediation of Contaminated Groundwater)

Installation of a groundwater interception and extraction system at the
site. The level and degree of treatment of the extracted groundwater
will depend on 1) the ultimate discharge point of this water and 2) the
level of contaminants in the extracted groundwater. Three water
discharge alternatives for the treated groundwater are 1) the local sewer
system, (i.e., Publicly Owned Treatment Works), 2) Fishing Creek via a
National Pollution Discharge Elimination System permit or, 3) on-site
irrigation. A fourth discharge possibility is groundwater injection.
The range of treatment for the extracted groundwater includes air
stripping, biodegradation, filtration through activated carbon filter and
metal removal. The most cost effective combination for the point of
discharge and the degree of treatment will be determined in the Remedial
Design stage. The discharged water will meet all ARAR's. Concurrence on
the final design will be requested from the State of South Carolina.
Comments will also be solicited from the public on the final design.
-------
TABLE 29
SUMMARY OF DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES
CAROLAWN SITE, FORT LAWN, SOUTH CAROLINA
Page I of 6
[valuation Criteria
Alternative I
No Action
Alternative 2
Alternate Water Supply
Alternative 3
Groundwater Extraction
with Ditcliarge to POTW
Alternative 4
Groundwater Extraction
with Aeration ant
Discharge to Fishing
Creek
Alternative 5
Groundwater Extraction
with Biological Treatment
ana Discharge to fishing
Creek
Short-Term Effectiveness • NA |l)
Short-term impacts
typical of any construction
activities and are not of
corocm
Short-term impacts to
workers consist of contact
with contaminated
groundwalcr

No additional risk to
community

Short-term impacts
readily controlled
Short-term impacts to
workers consist of contact
with contaminated
groundwaler

Air emissions deemed
to be insignificant

Environmental Impact
from treated discharge to
surface water deemed
negligible

Short-term impacts
readily controlled
Short-term impacts to
workers consist of contact
with contaminated
groundwdtcr

Air emissions not
anticipated

Environmental impart
from treated discharge- to
surface water deemed
negligible

Short-term impacts
readily controlled
-------
TABLE 89
(continued)
SUMMARY OF DETAILED ANALYSIS OF REMEDIAL ALTIiHNATIVLS
CAROLAWN SITE, FOKT LAWN, SOUTH CAROLINA
Page 2 of 6
[valuation Criteria
Long-Term Effectiveness
and Permanence
Alternative' 1
No Action
• Residual risk associated
with contaminated
groundwater unchanged

• Groundwaler contaminant
concentrations will exceed
MCU for 50 years

• Long-term effectiveness
relies on Institutional
controls which may not be
effectively enforced In the
long-term
Alternative not effective
In long-term
Alternative 2
Alternate Water Supply
• Residual risk associated
with contaminated
groundwater unchanged

• Groundwater contaminant
concentrations will exceed
MCU lor 50 years

• Long-term effectiveness
relics partially on'
Institutional controls
which may not be
effectively enforced in
the long-term

• Effectiveness will depend
on available capacity of
new line and connection/
user costs which will
determine user acceptance
Alternative J
Groundwater Extraction
with Discharge to I'OTW
Residual risk associated
with contaminated
groundwaler reduced

Croundwalcr contaminant
concentrations will exceed
MCI.S for 10 years

Long-term effectiveness
relies partially on
institutional controls
during implementation
period
Post-implementation
effectiveness and
permanence will be
ensured through long-term
monitoring program
Alternative 4
Groundwater Extraction
with Aeration and
Discharge to Fishing
Creek

Residual risk associated
with contaminated
groundwaler reduced

Groundwaler contaminant
concentrations will exceed
MCI.S for 10 years

Long-term effectiveness
relies partially on
institutional controls
during implementation
period
Post-implementation
effectiveness and
permanence will be
ensured through long-term
monitoring program
Alternative S
Groundwater Extraction
with Biological Treatment
and Discharge to fishing
Creek

Residual risk associated
with contaminated
groundwaler reduced

Groundwaler contaminant
concentrations will exceed
MCLs for 10 years

Long-term effectiveness
relics partially on
Institutional controls
during implementation
period
Post-implementation
effectiveness ami
permanence will he
ensured through long-term
monitoring program
-------
TABLE 29
(continued)
SUMMARY OF DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES
CAROLAWN SITE, FORT LAWN, SOUTH CAROLINA
I'agc3of6
Evaluation Criteria
Alternative I
No Action
Alternative 2
Alternate Water Supply
Alternative J
Croundwater Extraction
with Ditcharge to POTW
Alternative %
Groundwater Extraction
with Aeration and
Discharge to Fithing
Creek
Alternative 5
<7rounifu>urrr Extraction
with Hiologtcal Treatment
and Discharge to fishing
Creek
Reduction of Toxicily
Mobility, or Volume
• No reduction achieved
• Effectiveness will depend
partially on maintenance
of supply system in the
long-term.

• Alternative may be
effective in long-term

• No reduction achieved
Alternative will be
effective in long-term
• Direct reduction In
groundwaler contaminant
mass and mobility due to
extraction

• Direct reduction in loxicity
of extracted groundwatcr
through treatment in
POTW
Alternative will be
effective in long-term
Direct reduction in
groundwaler contaminant
mass and mobility due to
extraction

Indirect reduction in
loxicily of extracted
groundwaler through
natural processes such as
photo-oxidation and
environmental
biodegradalion
• Alternative will be
effective in long-term
• Direct reduction in
groundwaler contaminant
mass and mobility duo to
extraction

• -Direct reduction in loxicily
of extracted groundwaler
through treatment in
aerobic/facultative
lagoons
-------
TABLE 29
(continued)
SUMMARY OF DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES
CAROLAWN SITE, FORT LAWN, SOUTH CAROLINA
Page 4 of 6
Evaluation Criteria
Alternative I
No Action
Alternative 2
Alternate Water Supply
Alternative 3
Grouna'watrr Extraction
with Ditthorge to J'OTW
Alternative 4
Groundwater Extraction
with Aeration anil
Discharge to Flitting
Creek
Alternative S
Croundwater Extraction
with Biological Treatment
anil Discharge fa Fishing
Creek
ImplcmcnUblllty
• N/A
Costs (Present Worlh)
• Capital Costs:
• O&MCoatx
• Total:
N/A
331,914
331,914
No foreseeable major
concerns due to
standardized methods of
construction
• Capital Costs:
• O&MCosls
• Total:
$243,750
331.914
575,664
No foreseeable major
concerns due to
established technology
Capacity of POTW would
nerd to be assessed
Capital Costs: $802,670
O&M Costs: 553.635
Total: 1,356,316
No foreseeable major
concerns
Ease of obtaining NPDES
permit for treated surface
water discharge Is only
administrative concern

Capital Costs: $504,807
0AM Costs: 636,264
Total: 1,141X171
No foreseeable major
concerns
Ease of obtaining NI'DES
permit for treated surface
water discharge is only
administrative concern
• Capital Costs:
• O&M Costs:
• Total:
$525.931
645,833
1,171,764
-------
TABLE 29
(continued)
SUMMARY OF DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES
CAROLAWN SITE, FORT LAWN. SOUTH CAROLINA
Page Sol 6
Evaluation Criteria
Compliance with ARARs •
Alternative 1
No Action
Ground water concentrations
downgradlenl of Site will
not comply witK MCLs for
50 yean

Surface water ARARs will
be achieved through natural
attenuation throughout
50-year period
Alternative 2
Alternate Water Supply
Croundwatcr concentrations
downgradlenl of Site will
not comply with MCI.S lor
50 years

Surface water ARARs will
be achieved through natural
attenuation throughout
50-year period
Alternative 3
C,roundwater Extraction
with Discharge to f'OTW
Croundwatcr concentrations
will comply with MCLs
after 10 years
Compliance with
prclreatmenl requirements
of rOTW to be determined
Alternative 4
Groundwater Extraction
with Aeration ani
Discharge to tithing
Creek

Croundwatcr concentrations
will comply with MCLs
after 10 years
Insircam concentrations
complies with ambient
water standards and
health-based drinking
water criteria for average
flow In Fishing Creek

Instrcam concentrations
complies with ambient
water standards and
health-based drinking
water criteria for 7QIO flow
in Pishing Creek except
for 1,1-dichloroelhene;
excecdancc of health-based
drinking water criteria Is
marginal and can be waived
as an ARAR
Alternative 5
Groundwatrr Extraction
with Biological Treatment
and Discharge to I'ithing
Creelt

Croundwalcr concentrations
will comply with MCLs
afler 10 years
Instrcam concentrations
complies with ambient
water standards and
health-based drinking
water criteria for average
flow in Fishing Creek

Instream concentrations
complies with ambient
water standards and
health-based drinking
water criteria fnr 7QIO flow
In Fishing Creek except
for 1,1-dichloroelhenc
and 1,1-dirhloroelhanc;
cxccedancc of health-based
drinking water criteria is
margin.il and can be waived
as an AKAK
-------
TABLE 29
(continued)
SUMMARY Ok- DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES
CAROLAWN SITE, FORT LAWN, SOUTH CAROLINA
Page 6 oft
Evaluation Criteria
Overall Prelection of
Human Health and the
Environment
Alternative 1
No Action
• Protective of of human •
health and the environment,
however, protection of human
health In the long-term
cannot be ensured through
enforcement of Institutional
controls

• Don not address transport <
pathway or contaminants
of concern
Alternative 2
Alternate Water Supply
Protective of of human <
health and the environment,
however, protection of human
health In the long-term
cannot be ensured through
enforcement of institutional
controls

Protection relies on use <
avoidance
Does not address transport
pathway or contaminants
of concern
Alternative 3
GroHHfivater Extraction
with DtKharge to POTW
Protective of of human
health and the environment
in the long-term
Protective of of human
health and the environment
in the short-term, however,
protection of human he.illh
will rely on short-term
enforcement of institutional
controls

Addresses transport
pathway and contaminants
of concern
Alternatiet 4
Groundwater Extraction
with Aeration and
Discharge to Fithing
Creek

Protective of of human
health and the environment
in the long-term
Alternative 5
Protective of of human
health and the environment
in the short-term, however,
protection of human health
will rely on short-term
enforcement of institutional
controls

Addresses transport
pathway and contaminants
of concern
Protective of of human
health and the environment
in the long-term
Protective of of human
health and the environment
in the short-term, however,
protection of human health
will rely on short-term
enforcement of institutional
controls

Addresses transport
pathway and contaminants
of concern
Note:
III N/A - Not Applicable
-------
-91-
Review the existing groundwater monitoring system to insure proper
monitoring of groundwater. If deemed necessary, additional monitor wells
will be installed to mitigate any deficiencies in the existing
groundwater .monitoring system.

Appropriate institutional controls (deed restrictions) will be
implemented.

Upon the condemnation of the adjacent contaminated private, potable
wells by the County of Chester, these wells will be plugged in
accordance to South Carolina Department of Health and Environmental
Control regulations.

SOURCE CONTROL (Remediation of Contaminated Soils)

Due to the effectiveness of the removal actions, no source of
contamination remains within the fenced area of the site. However,
additional field work is required in the disposal area north of the
fenced area.. This field work will consist of the installation of
confirmatory soil borings to verify the presence or absence of
contamination in this area. If no contamination is found, there will no
source control remediation required at the Carolawn site, however, if
contaminated soil is found, a second Record of Decision will be necessary
to address this source of contamination.

GENERAL SITE CLEANUP ACTIVITIES

The two inactive incinerators will be inspected and any remaining residue
will be sampled and analyzed. Also, wipe samples will be collected and
analyzed. The results of the analyses will determine the method of
disposition for the incinerators. The two remaining drums will also be
sampled and analyzed to determine how they will be disposed. In
addition, site cleanup will include closing of the equipment
decontamination area used during Phase I RI activities.

6.2 OPERATIONS AND MAINTENANCE

Long term operation and maintenance (O&M) will concentrate on the groundwater
extraction, water treatment and groundwater monitoring systems.

6. 3 COST OP RECOMMENDED ALTERNATIVE

The estimated present worth cost for extracting and treating groundwater
ranges from $1,141,071 to $1,356,305 million, depending on the extent of
treatment and ultimate discharge point for the treated water. The capital
costs and present worth O&M costs over 30 years range from $121,369 to
$802,669 dollars and $753,433 to $916,723, respectively.
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-92-

TABLE 30

APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
Law, Regulation,
Policy and Standard
Application
Resource Conservation and Recovery Act fRCRA)

NONE
Clean Water Act (CWA)

40 CFR 122, 125:
National Pollutant Discharge
Elimination Systems (NPDES)
40 CFR 403:
Effluent Guidelines and
Standards: Pretreatment
Standards

Ambient Water Quality Criteria
CAA Section 109 and 40 CFR 50:
National Ambient Air Quality
Standards

40 CFR 404 (b)(1):
Wetland Protection
Discharges of extracted/treated
groundwater will be subject to
substantive requirements of the NPDBS
process if discharged to a local
stream. NPDES is administrative by the
state

Discharges of extracted/treated
groundwater will be subject to
pretreatment requirements if discharged
tot he POTW

AWQC may be used for discharge
requirements where there are no state
water quality standards

NAAQS for PMIO applied to fugitive dust
Protects the destruction of wetlands by
requiring no net lost of wetlands
Occupational Safety and Health Act

29 CFR 1910:
General standards for work
protection

29 CFR 1090:
Regulations for workers
involved in hazardous waste
operations
Worker safety for construction and
operation of remedial action
Worker safety for construction and
operation of remedial action
-------
-93-
TABLB 30
(continued)

APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
Law, Regulation,
Policv and Standard
Application
Intergovernmental Review of Federal

Fish and Wildlife Coordination Act

Endangered Species Act

Section 7(c)

Safe Drinking Water Act
REQUIREMENTS TO BE CONSIDERED

Executive Order 12372

40 CF : 29
Protection of fish and wildlife when
federal actions result in the control
or modification of a natural stream or
body of water
consultation with the fish and wildlife
service if action may impact endangered
species or critical habitat

Maximum Contaminant Levels (MCLs)
established under the Sate Drinking
Water Act were found to be relevant and
appropriate to remedial action at the
Cape Fear Site. The cleanup goals for
groundwater were established in Section
4.
State and local coordination and review
of proposed EPA assisted projects
Executive Orders for Flood Plains (BO 11988)
40 CFR Part 6, Subpart A
Executive Orders for Wetlands
(EO 11990)
Protection of flood plains affected by
remedial action
Protection of wetlands affected by
remedial action
-------
-94-
The present worth coat of the preferred remedy, Including all activities,
ranges from $1.4 to $1.6 million.
6.4
The planned schedule for remedial activities at the Cape Pear Site is as
follows:

September 1989 — Approve Record of Decision
October 1989 — Issue RD/RA Notice Letters and Initiate RD/RA
Moratorium Period
March 1990 — Initiate Remedial Design/Treatability Study
May 1990 — Complete Treatability Studies
August 1990 — Initiate Remedial Action for Addressing
Contaminated Groundwater and Other Specific
Cleanup Activities
6.5 FUTURE ACTIONS

Due to the limited analytical soil data collected from the storage area north
of the fenced area, additional confirmatory sampling will be conducted in
this area to confirm the presence or absence of residual soil contamination.

The only anticipated long-term action expected to be conducted at the site
following completion of the remedial action is periodic monitoring of
groundwater to insure remediated levels obtained during the remediation are
maintained.
6.6 CONSISTENT WITH OTHER ENVIRONMENTAL LAWS

A remedial action performed under CERCLA must comply with all applicable
Federal, State and local regulations. All alternatives considered for the
Carolawn Site were evaluated on the basis of the degree to which they
complied with these regulations. Table 30 lists the identified ARARs for the
Carolawn site. The recommended alternative meets or exceeds all applicable
environmental laws.
7.0 COMMUNITY RELATIONS

The Proposed Plan Fact sheets was transmitted to interested parties,
residents, media and local, state and federal officials on August 23, 1989.
The Agency also conducted the FS public meeting.

The Information Repository/Administrative Record was established at Lancaster
County Public Library located at 313 South White Street in Lancaster, South
Carolina.
-------
-95-
A public meeting was held on August 30, 1989, at the Lancaster County Public
Library in Lancaster, South Carolina. At this meeting, the remedial
alternatives developed in the PS were reviewed and discussed and EPA'a
preferred remedial alternative was disseminated. The groundwater mitigation
alternative was presented as described in Section 6.1 Description of
Recommended Alternative. In addition to discussing the groundwater
remediation alternative, activities to confirm the absence or presence of
soil contamination in the storage area north of the fenced area as well as
general house cleaning activities to be performed at the site were discussed.

The public comment period concluded on September 22, 1989.

The only comments received during the public comment period were those aired
and responded to at the public meeting. The Responsiveness Summary
summarizes the comments stated in the public meeting.

8.0 STATE INVOLVEMENT

The State involvement has been maintained throughout this lengthy RI/FS
process with reviewing pertinent documents such as the draft Remedial
Investigation Report, the draft Feasibility Study, the draft Record of
Decision and have been carbon copied all relevant correspondences.

The State of South Carolina supports the alternative stated in the
Declaration and Section 6.0.
-------
APPENDICES
-------
APPENDIX A
RESPONSIVENESS SUMMARY
-------
APPENDIX A
RESPONSIVENESS SUMMARY
This community responsiveness summary is divided into the following sections:

SECTION I. Overview. This section discusses EPA'a preferred
remedial action alternative and public reaction to
this alternative.
SECTION II.
Background on Commtinitv Involvement and Concerns.
This section provides a brief history of community
interest and concerns raised during remedial planning
activities at the Carolawn Site.
SECTION III.
SECTION IV.
Summary of Major Comments Received Purina the Public
Meeting and the Public Comment Period and EPA's
Responses to These Comments« Both the comments and
EPA's responses are provided.

Remaining Concerns. This section describes the
remaining community concerns that EPA should be aware
of in conducting the remedial design and remedial
action at the Carolawn Site.
SECTION V. Transcript of the Public Meeting. This section
provides a transcript of the Remedial
Investigation/Feasibility Study Public Meeting held
on August 30, 1989 at the Lancaster County Public
Library located near the site.
SECTION I. OVERVIEW
The public meeting at which EPA presented its preferred alternative to the
public initiated the public comment period which ended on September 22,
1989. The alternative addresses the groundwater contamination problem at the
Site. The preferred alternative specified in the Record of Decision (ROD)
includes: extraction and permanent treatment of contaminated groundwater,
confirmation soil sampling, and general site "house cleaning" activities.

In the public meeting, held August 30, 1989, five remedial alternatives were
described to the public for migration control. One of these five
alternatives was then proposed to the public as EPA's preferred remedial
alternative for the Carolawn site. The actual treatment train to be
installed to treat the extracted groundwater will be determined during the
Remedial Design stage of the Superfund process. The discharge location of
the treated groundwater will also be selected during the Remedial Design
stage.
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A-2
The community, in general, favors remedial action at the Site.

SECTION II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS

The Carolawn Site is an abandoned waste storage and disposal facility located
near Fishing Creek and South Carolina Highway 9, three miles west of Fort
Lawn in Chester County, South Carolina. The 60-acre site is situated in a
rural setting bordered to the south by the Lancaster/Chester railroad track
and to the north by a large wooded area. One-half mile east of the site is
Fishing Creek and the west is bordered by woodland.

Five households are located adjacent to the1Site. Approximately 2,000 people
live within a four-mile radius of the Site, with an estimated 100 people
within a one-mile radius. Fort Lawn (population 471) is located 2.5 miles
east of the Site and Richburg (population 269) is located three (3) miles
west of the Site. The population estimations are based on the 1980 U.S.
census.

Due to the rural nature of this region and the sparse population, coacern
over the events at the Carolawn site have been limited to the residents
living near the site. SCDHEC received its first complaint about the site in
1972 when chemical recycling was being done on-site. The residences made
informal and formal complaints to SCDHEC, the South Carolina Pollution
Control Authority, U.S. EPA and the local media. The local families
complained to local and state authorities about strong organic odors, fuming
drums and chemical vapors that reportedly could be seen 1/2 mile from the
site.

A primary concern in 1982 of local residents was the contamination of their
drinking water. To remedy the situation, a city water supply line was
extended from Chester to the adjacent residences in 1985. The Rockholt and
Hunter residences hooked up to the line but the Morrison home turned down the
offer. Their decision was based on a letter they received from SCDHEC in
L985/1986 stating that their potable well was contaminant free.

In 1987, the primary concern of area residents is the question of land
value. Underlying this concern is the confusion over groundwater
contamination. All of the parties who own property near the site have
expressed an interest in selling their land but all had doubts as to whether
this could be done successfully due to the condition of the groundwater.

Another chief interest expressed by area residents is the monitoring of
residential wells. Residents want to know whether this will be an ongoing
activity or whether all investigations are complete.
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A-3
III. SUMMARY OF PUBLIC COMMENTS RECEIVED DURING TBS PUBLIC MEETING AND THE
PUBLIC COMMENT PERIOD AND AGENCY RESPONSES

Comments raised during the Carolavm public meeting and public comment period
are summarized briefly below. The comment period was open from August 28 to
September 22, 1989 to receive comments from the public on the draft
Feasibility Study and proposed remedial alternative.

There was a moderate response from the community in the public meeting but no
comments were received during the pursueing the public comment period.
Summaries of the questions received during the public meeting are presented
below. A complete record of questions and responses that transpired during
the public meeting can be found in Section V - Transcript of the Public
Meeting.

Public Meeting

The public meeting was held on August 30, 1989 at the Lancaster County Public
Library meeting room. Questions and comments fell into the following
categories. They included the lack of initial communication with the public
prior to the commencement of an activity/ the preference of residents for
their well water over city supplied water, the start of clean up activities,
other disposal areas with no known association with the Carolawn site, the
level of lead found in the groundwater, the impact of discharging treated
groundwater to Fishing Creek, and the duration and sampling interval during
long term monitoring.

Public Comment Period

No comments were received by the Agency during the three week comment period
that ended on September 22, 1989.
IV. REMAINING PUBLIC CONCERNS

In addition to those concerns voiced at the public meeting, some additional
public concerns are described below.

* Additional sampling/analysis of residential wells for
site related contaminants and

* Location of Information Repository/Administrative
Record and future public meetings.

V. CAROLAWN REMEDIAL INVESTIGATION/FEASIBILITY STUDY PUBLIC MEETING

CAROLAWN PUBLIC MEETING
Lancaster, South Carolina
30 August 1989
7:00 PM
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MINUTES OF

CAROLAWN SUPERFUND SITE
•
REMEDIAL INVESTIGATION/FEASIBILITY STUDY

PUBLIC MEETING
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
AUGUST 30, 1989

7:00 - 9:00 P.M.

LANCASTER COUNTY PUBLIC LIBRARY
313 SOUTH WHITE STREET
LANCASTER, SOUTH CAROLINA
J
6
MEETING CONDUCTED BY MR. JON BORNHOLM

REMEDIAL PROJECT MANAGER,
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AND

PROJECT MANAGER, CAROLAWN SUPERFUND SITE
CYNTHIA S. ELEAZER. CVR
COURT REPORTER
POST OFFICE BOX 652
FLORENCE, SC 29503
(803) 667-0098
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1 The public meeting of the United States Environmental
2 Protection Agency Carolawn Superfund Site Remedial
3 Investigation/Feasibility Study was held at 7:00 P.M. on
4 August 30, 1989 at the Lancaster County Public Library,
5 313 South White Street, Lancaster, South Carolina,
6 conducted by Mr. Jon Bornholm, Remedial Project Manager for
7 the United States Environmental Protection Agency and
a Project Manager for the Carolawn Superfund Site.
9 MR. JON BORNHOLM: Good evening. My name is Jon
10 Bornholm. I am the Remedial Project Manager for the
11 Environmental Protection Agency. I am the Project Manager
12 for the Carolawn Superfund Site. I have been with the
13 Agency for a little bit over five years, serving in this
u role. I became the Project Manager for the Carolawn Site
15 in the fall of '87.
16 Briefly, this is what I hope to cover tonight. If you
17 have any questions during my presentation, please don't
18 hesitate ,to interrupt and ask them. We have a court
19 reporter up here who is recording the entire presentation,
20 the question and answer period, or the question and answer
21 session. This all becomes part of the administrative
22 record as well as part of the Record of Decision. There
23 are some sign-up sheets on either side of the table here.
24 I would appreciate it if everybody would sign in. Again,
25 this becomes part of the official record for this meeting
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1 and for the Carolawn Site. There are also handouts, one on
2 Superfund in general, two that I put together. One is the
3 fact sheet that I sent to individuals on the mailing list
A about three weeks or so ago and the other one is a copy of
5 the overheads that I'll be showing tonight.
6 Okay, basically, the purpose of this meeting is to
7 present to the public EPA's proposed preferred remedial
a alternative for the Carolawn Site. We have conducted and
9 are in the process of completing what we call a remedial
10 investigation and feasibility study. We use the acronym
11 RI/FS for the remedial investigation/feasibility study, so
12 if I slip to use that acronym, that's what we're talking
13 about, or what I'm talking about. It basically began back
u in late '85, early '86, and we're in the process of, as I
is said, finishing it up now.
16 I'll just briefly go through site history. According
17 to our records, the site was initially started to be used
is as a storage area back in 1970 for hazardous waste. They
19 had built the -- What we call potentially responsible
20 parties, the companies, the generators of the material as
21 well as the transporters, started to store hazardous waste
22 at the site in the 70's. In November of '80, due to
23 heightened awareness, the South Carolina Department of
24 Health and Environmental Control went out and did a study
25 of the site and their results are the discovery of one of
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1 contamination of private wells. EPA got involved in August

2 of '81. We did a hazardous waste site investigation and

3 this led to EPA's removal action in '81, '82 — It began in

4 the winter of '81 and it ended up in February of '82 -- in

5 which EPA removed drums and contaminated soil from the

6 site. The site was placed on the National Priorities List

7 which allows my program to basically become involved and

a expend monies at the site. It was placed on the National

9 Priorities List back in '83. Between '83 and '85,

10 discussions with PRP's, getting finances in order. The

11 Agency had the potentially responsible parties sign a

12 consent decree -- partial consent decree, directing the

13 potentially responsible parties to conduct the remedial

u investigation/feasibility study. Also in '85, for the

is public an alternate water supply was brought into the local

16 residences. As part of the initial phase of the potential-

17 ly responsible parties' remedial investigation/feasibility

is study, they removed the remaining tanks and the contents of

19 those tanks from the site. Those were left behind after

20 EPA's cleanup in '81. And as I mentioned earlier, the

21 initial RI/FS, what we call Phase I, was initiated in '86.

22 The potentially responsible parties submitted a report from

23 that study and in the spring of '87 EPA determined it was

24 insufficient, did not provide sufficient data to justify or

25 support the conclusions.reached in that decision, or in
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1 that document, so the Agency made the potentially

2 responsible parties go back out in the field and collect

3 additional data. That additional data question began in

4 the fall of '88 and we're now in the process of pooling all

s that information in together and completing the remedial

6 investigation/feasibility study.

7 Tonight, as I just mentioned, is the remedial

8 investigation/feasibility study public meeting. It is the

9 meeting that the Agency proposes to the public what we

10 feel, the Agency, is the most appropriate remedial

11 alternative for the site. We encourage public participa-

12 tion in this process and we are -- As part of that, there

13 is a public comment period set up for this to fulfill this

14 role and that public comment period ends on September 22nd.

15 MRS. MARGARET MORRISON: Mr. Bornholm —

16 MR. JON BORNHOLM: Yes, mam.

17 MRS. MARGARET MORRISON: -- before we go into that, I

is have a few questions I'd like to ask. I'm Margaret

19 Morrison and I am one of those people who live at the

20 Carolawn Site.

21 Going back to your groundwater investigation in 1980.

22 The first letter we got from DHEC told us in the letter

23 that we did have contaminants in our water and then they

24 said that we did not have them and the explanation for that

25 was because a previous test was done and the contaminated
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1 vials or what have you, whatever they do it with, was not
2 clean and it showed contaminants in our well test. And
3 then after that, they changed their minds and said we did
4 not have the waste chemicals in our well. And I have many
s letters telling us that we do not. Twice in 1983 there was
6 an article in The State paper, October the 2nd, 1983,
7 saying that EPA was going to do a study and all three
8 families had been told that their wells were contaminated
9 and not to drink the water from those wells. That was not
10 the case with us. We have not been told that ever. Then
11 your report comes out, we continue to get — In fact,
12 after that happened, I got a registered letter from DHEC
13 telling me that all was well. Then this report comes out
u and you're telling me again the Morrison and Hunter wells
15 were also contaminated by volatile organic compounds. So
16 this is very upsetting to me.
17 Mr. Faulkner, when the water line was put in, came to
18 me one morning at eleven o'clock, the first we had heard
19 from him about that particular thing, and he asked us if we
20 wanted the water. And I said, "Well, I don't know. I'll
21 have to talk with my husband," which was on the mail route.
22 And he said, "Well, I've got to know by four-thirty this
23 afternoon." So my husband got home at four-fifteen. We
24 had fifteen minutes to discuss it and get back to him with
25 what we had decided. So I flatly asked him if we had
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1 chemicals in our well water and he told me no.
2 So now I want to know once and for all, do we have
3 chemicals in our well or do we not?
4 MR. JON BORNHOLM: I can't give you a yes or no
5 because I don't have the data to show one way or the other.
6 That sampling that I have information on is back in '86 and
7 it showed no contamination in your well. I have asked our
a Environmental Services Division people, who are basically
9 our field support people, to come out and sample your well,
10 and that will be done in -- by the end of next month -- by
11 the end of September.
12 MRS. MARGARET MORRISON: Thank you.
13 MR. ARCHIE LUCAS: And I'm not going to stand up. I'm
u Archie Lucas and I am a representative of Chester County
15 Council in that district over there. And I don't remember
16 the exact dates, but Mr. and Mrs. Morrison and them,
17 they're my constituents also, and this thing was brought to
18 our attention. Mr. L. A. Swegerman, which represented
19 District 3 along the period of 1982, some time in there --
20 was it, Mrs. Morrison? -- and we went up and seen this.
21 Mrs. Rockholt -- Is she still living?
22 MRS. MARGARET MORRISON: Yes.
23 MR. ARCHIE LUCAS: Okay. They was having a lot of
24 health problems, or she was, and she was attributing it to
25 the groundwater. So we got involved, got DHEC up here.
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1 DHEC did not have the -- Chester County did not give DHEC

2 permission to go in there. They -- The Morrison family

3 had sold the property properly and they went in there and

4 they painted them a pretty picture. And the Mr. Morrison

5 that sold them the property, he has deceased since then and

6 he shared with me many times they painted them a picture of

7 roses there and they left a bad sore there. And we had to

8 get our House of Representatives at that time, Ernie

9 Nunnery, involved in it. We had to get DHEC involved in

10 it. We had a big hearing at the Chester County Courthouse

11 concerning this, and the people, as Mrs. Morrison said,

12 could not get a definite answer out of DHEC, was there

13 water level contaminated. Now I understand since then,

14 that since we got the grants out of Washington on the

15 Superfund, that they're on pipe water on our water system

16 over there now.

17 MR. JON BORNHOLM: The Rockholts.

18 MR. ARCHIE LUCAS: All of them.

19 MRS. MARGARET MORRISON: No.

20 MR. ARCHIE LUCAS: Y'all are not?

21 MRS. MARGARET MORRISON: No, we are not.

22 MR. ARCHIE LUCAS: Okay. And then my reading in

23 Monday's paper, was a week ago, concerning this, did y'all

24 not say in that paper that the water was contaminated?

25 . MR. JON BORNHOLM: The groundwater, which I'll get to,
8
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1 underneath the site is contaminated, yes.
2 MR. ARCHIE LUCAS: And I have -- really, I have
3 several questions. Why is it taking so long? This has
4 been five years -- at least five years. Why is it taking
s so long to -- I know that it's got to -- the tests have
6 got to continue to be done, but why is it taking so long to
7 do these things? These peoples' lives could be at stake
s here.
9 MRS. MARGARET MORRISON: We have already lost a
10 neighbor. Our closest neighbor died with liver cancer.
11 And has there been any kind of study done that you know of
12 or any concern as to whether or not she might have died
13 with what came out of her well? I went back over some of
u my material today and we were all interviewed one'time and
15 it said something about the Morrison well and the Morrisons
16 and the Rockholts were not drinking their water but the
17 Hunter -- Mrs.-Hunter was. And then in another paper —
18 another interview, it said that she said that, "Well, it
19 was only just a little paint thinner." So poor soul, she's
20 not with us today. But are there any kind of studies being
21 done concerning the health of the people who live near
22 there?
23 MR. JON BORNHOLM: To my recollection, there has not
24 been one. No.
25 MR. JOHN A. TIDDS: I mean why?
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1 MR. ARCHIE LUCAS: This says -- and this is August the
2 27th — It was saying the EPA is to hold off on family
3 well found tainted here.
4 Again, there's other questions that I would like to
5 ask. And I can respect the public forum that you're
6 holding, but why is it held here in Lancaster County
7 instead of Chester County where there's people that it
a affects?
9 MR. JON BORNHOLM: Basically, this is the closest
10 meeting place I could find.
11 MR. ARCHIE LUCAS: Chester County's got the same
12 facilities.
13 MR. JON BORNHOLM: It's my understanding this is a tad
u closer than Chester. I might be wrong, but --
15 MR. ARCHIE LUCAS: Well, you're wrong. I don't know
16 who led you wrong, but --
17 MR. JOHN A. TIDDS: Where do you live?
18 MR. JON BORNHOLM: Down in Atlanta.
19 MR. ARCHIE LUCAS: Chester County has a fine library,
20 it has a meeting room, that would have been glad to sponsor
21 it.
22 MR. JON BORNHOLM: I won't argue that point because I
23 don't know.
24 MR. ARCHIE LUCAS: And, you know, had I not read this
25 in the paper, this thing would have went untold to the
10
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1 people that are concerned about this thing. And being one

2 of those that brought it to the public's attention, it

3 still bothers me that our — this whole thing is over here

t> in Lancaster County, where it does not even pertain to

s Lancaster County. It pertains to Chester County and

6 Chester County residents and the people that are

7 responsible for this contamination. And out of this,

a Chester County drew an ordinance — drew up an ordinance

9 that prohibits this type of going on. This is not the

10 first dump that these people were involved in. They were

11 involved in one right across the Chester County line in

12 Fairfield County. They were involved in Carolawn. They

13 were involved in one up 21, still in Chester County. Now

u are these people going to continue to live a rebellious

15 life of going and intervening on other peoples' rights and

16 privileges and contaminations that's going to eventually

17 take their lives, or is the right agencies and the right

18 people going to say, "You're not going to do this anymore"?

19 MR. JON BORNHOLM: I'm hoping that that is what is

20 happening.

21 MR. ARCHIE LUCAS: You're hoping?

22 MR. JON BORNHOLM: My program is involved with the

23 cleanup of abandoned hazardous waste sites. I am not

24 privy -- I am not involved with ongoing activities.

25 That's another part of the Agency, as well as DHEC.
11
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1 MR. ARCHIE LUCAS: I'm not trying to give you a hard

2 time, young man, but I'm just -- it's just a question

3 that's a very concern to me because this area is still in

4 my representation over there.

s MR. JON BORNHOLM: And I don't have any answers for

6 you because I'm not involved with that --

7 MR. ARCHIE LUCAS: And the water is going into the —

8 The contaminated underground water level is going in --

9 continuing to go into Fishing Creek, which comes by our

10 living quarters. It comes through our community.

11 MR. JON BORNHOLM: I understand your concern and I'm

12 not -- I don't have the knowledge to answer your question.

13 I am hoping that the right people are doing the right

14 thing.

15 MR. JOHN JOHNSTON: Jon, if I may. I'm John Johnston.

16 John and I work together. I'm John's supervisor. You've

17 all got a lot of questions and undoubtedly a lot of

18 concerns. What I think we'd like to do is let John go

19 through what we know so far. Certainly, we're not going to

20 - sit here tonight and tell you we know everything or that

21 we're through trying to figure the situation out. We want

22 to get to the point of saying, "Well, here's what we know,"

23 be fair about what we don't know, and talk about how we're

24 going to deal with what we know and find out what we don't

25 know. You've asked a lot of questions. Obviously, there's
12
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1 a lot of concern. You've asked if, you know, these

2 activities are going to continue. Certainly, there's a

3 whole national program to try and keep that from happening.

4 Now the Environmental Protection Agency, one of the biggest

5 programs between EPA and the State Department of Health and

6 Environmental Control is in place to try and regulate those

7 activities. Now, you know, if somebody wants to run out

a and drop a drum off beside the road, you know, at night

9 sometime, not you, not me, not anybody is going to stop

10 them from doing that; but, certainly, yes, there's a whole

11 regulatory framework in place that was not in place in

12 1970. It wasn't in place really in 1980. It is in place

13 now. So when John says "he hopes," I can assure you that

u there are fairly massive regulatory program to track waste

15 from the cradle to the grave, the way we say it. So I

16 think it's more than a hope. I'm fairly certain that

17 that's not going to happen again, this type of situation.

18 Have we done individual studies on your neighbor and

19 the situation related to her passing? No. That is net to

20 say that we don't care, certainly. As a scientist, I'll

21 have to tell you what you probably already know. There

22 isn't a real good answer from anybody as to what causes a

23 particular person's cancer of any type. I think we all

24 know that. Why do -- you know, would one person get

25 leukemia and one person next door not? I can't tell you
13
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1 that. I'm a biologist with the Environmental Protection

2 Agency and people have spent lifetimes as physicians and

3 researchers trying to figure that out. I'd like to know

4 that myself, but the state of our information and the state

5 of science now is the only thing that can be done, that is

6 being done, at these and other sites are what we call

7 epidemiological studies, large — look at a large group of

8 people who all live in the same area and see if they're any

9 different than a similar group of people who don't live in

10 an area next to a hazardous waste site. There is a federal

11 agency that does those sorts of things, the Agency for

12 Toxic Substances and Disease Registry, and that's — you

13 know, who they are is not nearly as important as that

u they're there. They look at the information we have, they

15 work with the EPA to determine if that type or that level

16 of work needs to be done here versus any of the other

17 thousand or so sites that we're working on like this around

18 the country. Certainly I can tell you that they have taken

19 a look at the information. I don't know what they see

20 about this site versus another site. I can tell you that

21 once they've done an epidemiological survey, that they have

22 looked at the information and found that there is nothing

23 that they could do to answer that question, which is not to

24 say that they might find -- change their mind in the

25 future.
14
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1 I think what we can do is we can let Jon get through a

2 presentation on what we have done up to this point, what we

3 know, what we're proposing tonight. We can stay here as

4 late as anybody wants to stay and answer the questions we

s can answer, own up to the questions that we can't. I

6 apologize that we're not in Chester County. I c
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1 MR. JOHN A. TIDDS: But you still don't know if these
2 people have got toxics in their well right adjacent, two
3 hundred yards from the site?
4 MR. JOHN JOHNSTON: All the information that we have
5 says that they do not and certainly the information that we
6 have that was looked at incorrectly. Our information was
7 in Atlanta, Georgia that these folks were hooked up to the
8 city water supply. And now that's just to be quite frank
9 with you. If our information had been otherwise, that well
10 would have been sampled at least two years ago again to
11 confirm what was or was not in it, is or is not in it.
12 MR. JOHN A. TIDDS: You're saying that none of the
13 wells adjacent to this site have contamination in them as
u to your knowledge right now.
15 MR. JOHN JOHNSTON: No, I am not. And one of the
16 things that we have --
17 MR. JOHN A. TIDDS: You're not saying that?
18 MR. JOHN JOHNSTON: I'm not saying that at all. I'm
19 saying that what we found several years ago led to the
20 water line being placed in this area, led to the
21 connection, I believe, of three out of the four homes in
22 the area to the water line.
23 . MR. JOHN A. TIDDS: That's a little teeny band-aid on
24 a real big problem.
25 MR. JOHN JOHNSTON: We wouldn't --. I wouldn't argue
16
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1 with that for a minute. And what we're trying to do is get

2 a bigger band-aid on it right now and tell you what that

3 might look like and how we can find out what the ultimate

4 solution is. But I think what we need to do is then answer

s some specific questions, see if in his presentation Jon

6 answers some of those questions, where we don't — Let's

7 ask them here in a few minutes once we go through what we

8 can tell you and move on from there.

9 MR. JON BORNHOLM: Basically, the overall objective of

10 remedial investigation/feasibility studies is tc

11 characterize the nature of the waste and to define as best

12 we can the extent of the contamination at hazardous waste

13 sites. The objectives of the RI -- of the remedial

14 investigation is that first part, to characterize the waste

15 there present and find the extent, determine the pathways

16 of exposure to either the public or the environment. And

17 then the objective of the FS is to select the most cost

18 effective remedial alternative to address the problems at

19 the site.

20 For those who may not be familiar as to where the site

21 is, it's off of Route 9 on the east side of Fishing Creek.

22 This overhead locates with respect to the site, the private

23 wells that were in use back in 1980. And this is a

24 schematic of how the site looked during its operation.

25 EPA's removal or emergency reaction in 1981-82 removed
17
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1 contaminated soils within the fenced area as well as in
2 this area to the north, removed drums on top of the surface
3 as well as surface soils that were contaminated. The
4 Agency left, if my memory serves me from hearing the
5 information, is that this row of tanks were left on the
6 site following that removal and those were the tanks that
7 were removed by the potentially responsible parties in '86.
8 The next three drawings basically show direction of
9 groundwater, the flow of groundwater. The major flow is
10 headed to the -- towards Fishing Creek and each of these,
11 this drawing and the next two, are prepared from data
12 collected on different -- different times of the year.
13 This one's on --collected on August 31st. This one's
14. collected a few months later in October. And the last one
15 was based on data collected in December and, basically,
16 it's showing that the groundwater is flowing towards
17 Fishing Creek, to the east. As I mentioned earlier, the
18 remedial investigation/feasibility study occurred in two
19 phases. Phase I was basically between '86 and '87. During
20 that, those activities, soil samples, surface soil and
21 subsurface soils, were collected. This --
22 MR. JOHN A. TIDDS: Excuse me. When was this done?
23 MR. JON BORNHOLM: This was done during the '86/'87
24 time frame.
25 MR. JOHN A. TIDDS: Thank you.
18
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1 MR. JON BORNKOLM: Phase I of the RI/FS.
2 This map locates where those samples were collected as
3 well as the data — the analytical data. The contaminants
4 found on site were from the samples collected. And this is
s following the removals in '81 and '86, which removed the
6 source of contamination, the contamii ated soil as well as
7 the drums and tanks. Also, as far as the remedial
8 investigation of Phase I, four monitoring wells were
9 installed: Monitoring Well 1 and Monitoring Well 2,
10 Monitoring Well 3 and Monitoring Well 4. As part of
11 Phase II, additional monitoring wells were installed,
12 monitoring wells that were further out away from the site,
13 away from the periphery of the site.
u Okay. Some of the analytical data from Phase I of the
15 monitoring wells as well as the Rockholt or the Ventura
16 well are shown in this overhead. It shows the contaminants
17 present and the levels of contamination as well as the
18 sampling dates. From this overhead, the main contaminants
19 concerned, or group of contaminants of concern, are organic
20 volatile compounds. And this is the inorganic compounds
21 detected in those wells from Phase I data.
22 From the information we collected during Phase I, as I
23 mentioned, the Agency determined that the study was
24 incomplete. It did not provide sufficient information to
25 determine an effective remedial alternative for the site.
19
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1 We required the potentially responsible parties to go back

2 out to the field to collect additional information, data.

3 As part of that, they installed those additional wells.

4 The other determination that the Agency made from the

s Phase I data was that no source of contamination remains

6 within the fenced area. Okay. It's our belief that the

7 remedial -- the emergency actions, the removals done by the

8 Agency in '81 and the potentially responsible parties in

9 '86, removed all source within the fenced area so that the

10 only contaminants that remain are those that were in the

11 groundwater, and that was the driving force to get the

12 potentially responsible parties back out in the field to

13 install additional monitoring wells further away from the

u site so we could determine the extent of contamination in

15 the groundwater. We also made a determination that the

16 only group of contaminants of concern are the volatile

17 organics, with the exception of one inorganic, which is

18 lead.

19 This overhead shows the distribution of Acetone in the

20 groundwater and, as you can see, it has reached Fishing

21 • Creek in the groundwater. It has traveled in the ground

22 with the groundwater to Fishing Creek in both up this way

23 and this way, east of the site.

24 This overhead looks at this Trichloroethene, another

25 common solvent, organic volatile compound. And, again, the
20
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1 same conclusions can be reached, that contaminated

2 groundwater has reached Fishing Creek and discharging into

3 Fishing Creek.

4 MR. ARCHIE LUCAS: Jon, can I ask a question here?

5 Are these elements cancerous?

6 MR. JON BORNHOLM: Trichloroethene, I believe, is a

7 potential carcinogen. And Acetone?

8 MR. GLENN ADAMS: Yeah, and Acetone.

9 MR. JON BORNHOLM: Trichloroethene is believed to be

10 a -- or is classified as a potential carcinogen.

11 MR. JOHN JOHNSTON: Jon, what are the concentrations,

12 though, that was in the stream at the point of discharge?

13 MR. JON BORNHOLM: I have —

14 MR. JOHN JOHNSTON: Low?

15 MR. JON BORNHOLM: They're low.

16 MR. JOHN JOHNSTON: Yeah.

17 MR. JON BORNHOLM: Below any health criteria. I'll

is get to that and cover that in a minute.

19 I don't want to jump back and forth in time, but I try

20 to look at each environmental media together, the surface

21 water and sediment, groundwater, and soils and subsurface

22 soils. This overhead that we're looking at, sediment and

23 subwater samples collected. These were samples or sampling

24 locations collected back in '81 as part of the initial

25 hazardous waste site investigation. These are the
21
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1 locations of the surface water samples collected during
2 Phase I of the remedial investigation/feasibility study.
3 From the data provided by these samples, we were able to
u eliminate surface water and sediment as a pathway of
5 exposure to both the environment and the public.
6 Therefore, it was based on that decision — During
7 Phase II we collected surface water samples just from
s Fishing Creek to see what impact, if any, discharge of
9 contaminated groundwater was having to the creek, and this
10 is the sampling points and these were the analytical
11 results.
12 As part of the remedial investigation, we also devised
13 health standards, or cleanup goals might be a better term
u for it. These are levels -- If we have levels that exceed
15 these levels of contamination here, remedial action is
16 required. If it does not exceed that based on assessments
17 done by our health people, then no remediation is required.
is So these are the numbers that we use basically to draw a
19 line, whether or not we need to clean up the site or not.
20 Groundwater, our levels of contamination exceed these
21 levels. Now, as you can see, in the third column -- the
22 middle column for ambient water standards, no contamination
23 in Fishing Creek were found above those levels. That
24 basically concludes the information generated during the
25 remedial investigation.
22
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1 The feasibility study looks at a universal list of

2 possible remedial alternatives to clean up the site. From

3 that universal list, those that are not applicable to the

4 site — will not work on the site, are eliminated. Through

5 that process, these were the five remaining alternatives

6 that we considered for the site. We are required by the

7 Superfund Law to keep the no action alternative. That

a provides us a basis to measure the gains of the other

9 alternatives evaluated.

10 So the first alternative is no action, nothing is done

11 at the site except for long-term monitoring.

12 The second alternative was to bring in a larger water

13 supply line to meet future development of the area.

14 Alternatives three, four, and five all involved the

15 extraction of contaminated groundwater. The only

16 difference between each of alternatives three, four, and

17 five is what we do with that contaminated groundwater.

is Alternative three is to discharge -- run a line to the

19 publicly owned sewer plant — treatment works and let them

20 deal with it.

21 Alternative four and five involve on-site treatment of

22 the contaminated groundwater and then alternately

23 discharging to Fishing Creek upon treatment of the water.

24 Alternative four is running the contaminated water

25 through an aeration treatment process to remove the organic
23
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1 volatiles.

2 And then alternative five is a facultative lagoon

3 treatment system, running the contaminated water through

4 basically a mini sewer plant and letting bacteria degrade

s the volatile organics and then discharging to Fishing

6 Creek.

7 On the right-hand side are the cost estimates for each

8 alternative over a ten-year period and over a thirty-year

9 period.

10 What we have -- the Agency has settled upon as our

11 proposed remedial alternative for the site, again based on

12 the data generated during the remedial investigation, we

13 are not requiring any type of soil remediation within the

14 fenced area. It's our opinion, based on the data

15 generated, that there is no more source in that area.

16 There is some concern about that one disposal area -- or

17 not disposal area, but let me say storage area -- north of

18 the fenced area. Additional sampling will occur in that

19 area to confirm the presence or absence of contamination in

20 the soil in that area. As far as -- And that's the

21 storage area to the north, confirmation samples.

22 Addressing the contaminated groundwater, the Agency is

23 selecting extraction of the contaminated groundwater and

24 we're leaving open right now a range of treatments that may

25 include all or several. It'll be a treatment train,
24
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1 sets levels of contaminants that would be allowable to be
2 discharged into that stream. The other alternative could
3 be on-site irrigation. The decision will basically be made
4 during the next phase of the Superfund process, which is
s called the remedial design, which I'll talk about in a
6 second. Let me ge*: through this.
7 Other activities to be conducted on site will be
8 decide what to do with the defunct, inactive incinerators
9 on site, whether dismantle them or leave them standing.
10 There's two drums on site. We'll be sampling those and
11 determine what to do with those. And there is one little
12 pit near the fenced area that was constructed during
13 Phase I to decon the equipment used on the field -- out in
14 the field and we'll determine what to do with that
15 little -- It's like a ten by ten little lagoon a foot deep
16 or so.
17 What follows this is, following input from the
is community, the Agency generates a responsiveness summary.
19 Basically, we respond to all comments sent to us. That
20 becomes part of the record. Looking at — evaluating the
21 response we get may or may not alter this approach. We
22 can't say until we get a response.
23 Then the next step will be to begin negotiations with
24 the potentially responsible parties. It's the Agency's
25 goal to have them finance the actual cleanup of the site.
26
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1 per se, of air stripping, biodegradation, filtration
2 through a activated carbon filter, and, if necessary,
3 removal of metals from the water. So it will be extraction
4 of contaminated groundwater and treatment.
5 As with the treatment, we're also leaving open our
6 options of what to do with that groundwater — that treated
7 groundwater. Ideally, the easiest solution would be to
8 discharge to the publicly-owned treatment works, the local
9 sewer system. That may not be a feasible alternative. We
10 haven't discussed that idea with the operator and owners of
11 the treatment works. They may not accept it. It's a
12 possibility. That will be decided during the remedial
13 design phase.
u MR. ARCHIE LUCAS: Jon, would they be qualified to
is handle this type of stuff, though?
16 MR. JON BORNHOLM: Basically, what would be discharged
17 to the system would be clean water because we are going to
18 be treating the water on the site.
19 MR. ARCHIE LUCAS: Okay.
20 MR. JON BORNHOLM: The other two alternatives to
21 dispose -- discharge the treated groundwater to, would be
22 to Fishing Creek. If that method of discharge is selected,
23 we have to meet the technical requirements of what's called
24 the National Elimination -- National Pollution Elimination
25 Discharge System -- the acronym is NPDES -- permit and that
25
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1 And that's a hundred -- We allow ourselves a hundred and
2 twenty days to complete that negotiations.
3 Following that negotiations, we begin with remedial
4 design. If necessary, there'll be some — Additional data
s will be collected, if necessary, to design the extraction
6 system, to determine how to treat that groundwater,
7 knowing -- once we find out exactly what's in it after we
a run some pump tests, determine how to discharge that water.
9 Then we go into what's called the remedial action
10 stage, which is actually the cleanup. I am anticipating
11 that the remedial action stage should begin sometime next
12 summer.
13 That's the end of my prepared presentation. Some
14 gentlemen came up from Atlanta with me. Glenn Adams, who
is is our Regional Toxicologist, came up and Michael
16 Henderson, who is with our Community Relations program,
17 also came up. We're more than willing to answer any
18 questions you may have. Because this is being recorded for
19 the record, I would ask each of you to state your name,
20 basically what your relation to the site is, whether or not
21 you're a potentially responsible party or a concerned
22 citizen or reporter, so that we can keep track of that and
23 we'll stay here as long as we need to. Glenn, come on up.
24 MR. JOHN A. TIDDS: I'd like to ask you a question.
25 My name is John Tidds and I drink the well water. When was
27
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1 the Clean Air and Water Act passed?

2 MR. JON BORNHOLM: I don't know offhand.

3 MR. DICK DUBOSE: The Clean Air Act was passed in 1970

4 originally and it was amended several times after that,

5 about '74 and '77.

6 MR. JOHN A. TIDDS: Thank you. They never did do the

7 clean water part?

8 UNIDENTIFIED PERSON: The Safe Drinking Water Act was

9 in 1976.

10 MR. JOHN A. TIDDS: Okay. Thank you. I'd like to ask

11 Mr. Lucas, which site were you referring to on North 21 a

12 while ago?

13 MR. ARCHIE LUCAS: The one -- the same gentleman that

14 was from the York area was involved in the one off of --

15 You know where you cut through off to go over to Lancaster,

16 off of 21 down there, where that old filling station used

17 to sit? Back off down in there somewhere, John.

18 MR. JOHN A. TIDDS: Okay. That's all.

19 MR. ARCHIE LUCAS: It's right next to Fort Lawn down

20 there, that old white filling station.

21 MR. JOHN A. TIDDS: You don't know anything about

22 behind Colonel Frank's off 21?

23 MR. ARCHIE LUCAS: Well, not since the gentleman over

24 here --

25 MR. JOHN H. TIDDS: My name is Herb Tidds. I live in
28
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1 Great Falls. I have some property up on the-Fishing Creek

2 Lake. Did I understand you to say that this cleanup

3 program would start the summer of 1990?

4 MR. JON BORNHOLM: That would be about right. Yes.

s It would be the earliest it could start.

6 MR. JOHN H. TIDDS: Is this lag due to finances?

7 MR. JON BORNHOLM: No. We have -- First we try to —

8 We will enter into negotiations with the generators and

9 transporters of this hazardous waste, the potentially

10 responsible parties.

11 MR. JOHN A. TIDDS: Do you know who they are?

12 MR. JON BORNHOLM: Yes, we do. They're the ones who

13 financed the remedial investigation/feasibility study.

u MR. JOHN H. TIDDS: Do you propose to take any. samples

15 from the Morrison's well and analyze them?

16 MR. JON BORNHOLM: That will be done some time in

17 September -- of next month.

18 MR. WILLIAM W. MORRISON: That's what I was wanting to

19 ask yoa. I'm William W. Morrison. I don't know why we

20 didn't have some kind of discussion like this to let us

21 know what is going on before that pipeline was put in. I'd

22 rather have my well water if it was good like the man said

23 it was than that water that's coming in that pipeline, but

24 most everybody that gets it tells me the same thing and —

25 because I don't know what it's got in it.
29
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1 MR. JOHN A. TIDDS: You don't know what's in it,

2 either.

3 MR. WILLIAM W. MORRISON: Because -- They checked it.

4 They don't know what -- They ain't going to tell you

5 what's in it, anyway. But they said that we didn't have it

6 and they give us about six hours to decide whether we

7 wanted to drink our good well water that didn't have

8 anything in it or hook onto that pipeline.

9 MR. JON BORNHOLM: I --

10 MR. WILLIAM W. MORRISON: And then they go and build

11 these wells and I know what the wells cost -- about five

12 times what a well driller drills one. Then they don't want

13 to -- It costs too much to test our water, see, but those

u wells cost I don't how many thousands each.

15 MR. JON BORNHOLM: See, the reason — It was really a

16 miscommunication somewhere down the line.

17 MR. WILLIAM W. MORRISON: Well, he said it cost too

18 much to test our water. They won't test it anymore.

19 MR. JON BORNHOLM: Who is he?

20 MR. WILLIAM W. MORRISON: Then they go build the

21 wells --

22 MR. JON BORNHOLM: Who is he?

23 MR. WILLIAM W. MORRISON: -- to test the water. He

2u told her.

25 MRS. MARGARET MORRISON: The District man one day told
30
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1 me how much the equipment cost to test the water and how

2 much our tests cost each time we did it. So it sounded to

3 us like he was telling us we don't -- you know, "You're too

4 much bother to us." And then —

s MR. WILLIAM W. MORRISON: They never come there and

6 discussed anything —

7 MRS. MARGARET MORRISON: And then —

a MR. WILLIAM W. MORRISON: -- about what they're going

9 to do.

10 MRS. MARGARET MORRISON: And then the day he — No, I

11 think it was after that because I had written a letter to

12 the editor of The Chester Reporter because when this

13 last — in '83 when it came out that we were told that we

14 were not to drink our water, I was trying to find out where

15 they got their information, whether it came from EPA or

16 DHEC. And I called The Chester editor and he didn't seem

17 to — He said he didn't really know where it came from,

18 but he says, "Why don't you write a letter to the editor

19 cind let people in this county know what you people have

20 been going through," so I did. And during the time,

21 Mr. Parker called me on the telephone and told me not to

22 believe anything that I read in the paper, so I put that in

23 my letter what -- that he called. And when that letter

24 came out, he came back to me with two other men and he told

25 me that we would not get our well checked again. So that's
31
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1 the last we've seen of Mr. Parker.

2 MR. JON BORNHOLM: The last study that we have that

3 I've seen for your well is '86 and it showed no contamina-

4 tion. It would have been sampled from that point on until

5 now prior to tonight if we had known that you were still

6 using your well, between that time frame — between '85 and

7 now, there's truly a --

8 MR. WILLIAM W. MORRISON: There's no record of who

9 hooked onto that pipeline? How's all these things done and

10 nobody knows what's going on?

11 MR. JOHN A. TIDDS: I bet somebody did some work down

12 there in a month.

13 MRS. MARGARET MORRISON: What he's talking about is,

u does DHEC not report to you people what they do?

15 MR. ARCHIE LUCAS: DHEC don't report to nobody.

16 MR. JON BORNHOLM: I can't speak for DHEC.

17 MRS. MARGARET MORRISON: If they don't, I don't see

18 how you know what you're doing.

19 MR. JOHN JOHNSTON: Well, we do avail ourselves of all

20 the information we can, working with the State, their

21 efforts, our efforts. In fact, something was wrong, quite

22 frankly. What Jon is saying is we understood you to be on

23 the city water well. There's no way anybody can stand up

24 in front of you and say that that wasn't a mistake and that

25 that doesn't potentially affect you. Nobody was, you know,
32
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1 going to come here tonight and say different. We would --
2 As Jon said, we should have been taking samples from this
3 well. Now those other -- Unless you want to hear it,
4 there's no need to go into why we construct very expensive
s groundwater monitoring wells instead of coming by and using
6 your wells for sampling. There are technical reasons, but
7 my point is that your drinking water, that we should know
8 what was in it today. And what we're going to do is, as
9 quick as we can get out there, we're going to go find out
10 what's in it today. We're also, I can assure you, will be
11 approaching the responsible parties who conducted this
12 study to see if they want to go back to where we were a few
13 years ago and offer again to connect you to the city water
u supply. I can assure you that -- I mean people -- I think
15 what I've heard said is two hundred million people can
16 drink out of the city water supplies around the country,
17 then they're known to be as safe as state and federal
18 government can make them. So if you're concerned about
19 what's coming through that pipe, they're sampled regularly
20 by law and forwarded to the state, Safe Drinking Water
21 folks and federal folks, so we've got a way of finding out
22 what's in that pipe on a regular basis. And that, quite
23 frankly and obviously, we haven't had as far as what's
24 coming out of your well. Now if they said that -- Once
25 again, what we -- the information that we do have today
33
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1 holds this, that there wasn't anything found in your well,
2 but I know if it was ray well that that wouldn't
3 make -- wouldn't answer my questions. So what we want to
4 do is get out as quickly as the federal government can and
5 find out for you what's in your well while we're also
6 talking to the people who could come out and hook you up to
7 that water supply.
8 Yes, sir.
9 MR. ARCHIE LUCAS: Do you not think, though, that it
10 would have been well if they would have let the local
11 people know what's happening with them or either the county
12 officials or at least the county supervisor so he could
13 relay the messages on to the people of concern what's been
u happening with the EPA monitoring?
15 MR. JOHN JOHNSTON: Yes, sir.
16 MR. ARCHIE LUCAS: And none of this has transpired?
17 MR. JOHN JOHNSTON: Yes, sir. You're exactly right.
18 There should be more effort on our part to find who you
19 are. That's just a point. It's not an excuse. It's not a
20 reason, but we're in Atlanta and it's difficult to find
21 everybody. We should do what you're describing and we will
22 be doing what you're describing. We want to find out more
23 about who to talk to. I'm not going to sit here and tell
24 you that I know everything and who's who in your county.
25 We should know and, quite frankly, I do not. I'm hoping
34
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1 that we will know so that we can do a better job with that.

2 I was speaking to ray boss on the way over here and that's

3 something that we ought to do a better job with.

4 Basically, I'm responsible for forty-two some of these

5 sites and it is difficult to keep up with that level of

6 information from Atlanta, but, again, that's not an excuse.

7 We need to. That's what I get paid for. That's what Jon

8 gets paid for and we want to do better. I'm certain that

9 the folks who are here tonight can help us do that better.

10 We've had -- I would imagine we had a public meeting when

11 we had a work plan concerning this site? I don't know, but

12 probably that was the last time we had this type of

13 meeting. What I want to do is be sure when we ask you to

u sign up and give us an address -- The very reason that we

15 ask you to do that on nights like this, so we know at least

16 who wanted -- who came out to the meeting, that we can

17 contact you. You know more people, you can tell us. We

18 obviously need your help to do that, to get into your

19 community and do a better job of letting you know what

20 we're up to and finding out what your concerns are.

21 MR. ARCHIE LUCAS: Another good question that comes to

22 my thought on this going into -- discharging into Fishing

23 Creek, the information of possible contamination that might

24 be there. How does this affect the fish that we might

25 catch and eat there?
35
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1 MR. JOHN JOHNSTON: Well, certainly, we would not
2 discharge anything in Fishing Creek that would create a
3 problem. I can guarantee that.
4 MR. ARCHIE LUCAS: But then the groundwater level
5 might already have it there.
6 MR. JOHN JOHNSTON: Well, what we know of what's going
7 . into the creek and — from the groundwater, we know that
a those levels are not a problem. When we say volatile
9 organic compounds, we're talking about -- First of all,
10 the material, it isn't going to stay in the creek a great
11 deal of time. It volatilizes. It's up in the air. It
12 dissipates quite rapidly. But we also know that what is
13 discharging out is at levels that don't pose a hazard
u either through the fish or through direct contact with that
15 water, and we're not going to do anything, believe me --
16 In terms of solving one problem, we're not going to move
17 that problem out of the ground water into Fishing Creek.
18 That's not a solution. That's not what we get paid to do.
19 We get paid to treat the material, to take care of it.
20 What goes into the creek has to meet some incredibly
21 stringent standards, so it's not -- we're not going to
22 relocate the problem, believe me.
23 MR. JON BORNHOLM: I think you have a question?
24 MR. AL WILLIAMS: No, I was going to make a comment.
25 My name is Al Williams. I'm District Director of the South
36
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1 Carolina Department of Health and Environmental Control.
2 In relationship to Mrs. Morrison's question about her well,
3 I'm not sure where all the miscommunication has derived
4 from, but our records clearly state that her well did not
5 contain contamination. It has been sampled a number of
6 times over a period of time and, like I say, in terms of
7 any verbal conversation you had with other people, I can't
s address that, but our record clearly states that there was
9 no contamination in it.
10 MR. JOHN H. TIDDS: When was the last sampling done?
11 MR. AL WILLIAMS: I don't have that information with
12 me.
13 MRS. MARGARET MORRISON: 1985, sometime before the --
u MR. JOHN H. TIDDS: 1985?
15 MRS. MARGARET MORRISON: — water line was —
16 MR. JOHN H. TIDDS: It could be by now.
17 MR. AL WILLIAMS: Of course, we'll be happy to do it
18 again. Sure. But in terms of continuous sampling, I would
19 assume that once the determination was made over a period
20 of time of successive samplings, that being no indication
21 of contamination, that that was the reason no further
22 sampling was deemed necessary.
23 MR. JOHN H. TIDDS: It takes some time for this
24 groundwater to migrate, doesn't it?
25 MR. JON BORNKOLM: Yes, sir.
37
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1 MR. JOHN H. TIDDS: In some cases.

2 MR. JON BORNHOLM: Yes, sir.

3 MR. JOHN H. TIDDS: So what you say may or may not be

4 valid.

5 MR. AL WILLIAMS: I'm saying that she was talking

6 about reading later on that her well contained

7 contamination. This fact report states here that under

8 repeated sampling that those wells showed contamination and

9 that is not accurate. The initial sampling showed a trace

10 in your well, which was attributed to maybe sampling

11 protocol or inadequate purging of equipment. All those are

12 possibilities. Normally, we would not -- We would always

13 pull a confirmation sample to support the first examination

H if -- which we did and we sampled thereafter, so --

15 MR. JOHN H. TIDDS: It looks to me like as long as

16 there's a possibility of contamination in the groundwater

17 that samples would be taken periodically until it was

18 firmly established that there was no further contamination

19 or migration of that contamination.

20 MR. AL WILLIAMS: Well, the Department reached that

21 decision to do that.

22 MR. JIM FERGUSON: With the information that the

23 Morrisons are not on city water, that can be done through

24 the remainder of this process?

25 MR. JOHN JOHNSTON: Sure. That will be done.
38
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1 MR. JOHN A. TIDDS: I want to address this to both of
2 y'all, your part. You represent DHEC?
3 MR. AL WILLIAMS: I am with DHEC, yes.
4 MR. JOHN A. TIDDS: Department of Environmental Health
s Control? Do y'all sample the Catawba River —
6 MR. AL WILLIAMS: Yes, sir. We do.
r MR. JOHN A. TIDDS: — and the bottom thereof?
a MR. AL WILLIAMS: Yes, sir. We do.
9 MR. JOHN A. TIDDS: You do? And how many different
10 compounds do you check for there, if you call those
11 compounds or whatever?
12 MR. AL WILLIAMS: You sure you want to get into this?
13 MR. JOHN JOHNSTON: Well, I don't know that there's a
u relationship between that site and the Catawba River.
15" MR. AL WILLIAMS: I mean I'll be glad to furnish you
16 that information, but I don't think maybe that it's
17 appropriate.
18 MR. JOHN JOHNSTON: The short answer is when they run
19 analysis of the river -- when we run analysis, normally
20 they're running a wandering list of chemical compounds, but
21 it depends upon what the river's being sampled for. I
22 don't know if there's a connection between this site —
23 what we're here to discuss and the Catawba River, but the
24 short answer --
25 MR. JOHN A. TIDDS: It's all the same water.
39
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1 MR. JOHN JOHNSTON: Certainly. But the contamina-

2 tion -- What we're supposed to be determining is does this

3 site and anything coming from this site get that far down

4 the stream. From what I understand from our study is the

5 answer would be no.

6 MR. JOHN A. TIDDS: Okay. I have one more question

7 and then I'm going to hush up. Do either one of your

8 parties knowledgeable about the dump site behind Colonel

9 Frank's off of U. S. 21 almost to the Chester County line?

10 MR. JOHN JOHNSTON: I tell you what, it would be kind

11 of hard for me to answer standing here. I'll tell you for

12 me, for Jon, I know the answer is no. We've got a list in

13 the Southeast of four or five thousand different sites that

u we're working on, trying to figure out if any of them are a

15 problem like this one might be, less of a problem, more of

16 a problem, so it may be on there, it may be under investi-

17 gation at some level. I can't tell you. What I do -- I

18 can tell you is before we leave this evening, somebody is

19 going to need that description again so that I can make

20 sure it's not --

21 MR. JOHN A. TIDDS: See, it's right on Duke Power's

22 right-of-way underneath their towers and they put drums in

23 there in '81 and '82 after all these rules were supposed to

24 be in place. There's row after row after row after row of

25 55-gallon drums buried on that right-of-way. It .looks like
40
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1 Duke Power or you people, DHEC, or somebody ought of knew

2 about it.

3 MR. JOHN JOHNSTON: It's possible that we do.

4 MR. JOHN A. TIDDS: I asked the Sheriff about it. He

5 said he didn't know nothing about it.

6 MR. JOHN JOHNSTON: Well, I tell you what, let's see

7 if we can't -- see if there's any more questions and then

8 I'd like to get that, what you just said, so I can jot down

9 as to where it might be.

10 MR. ARCHIE LUCAS: Who legally owned this property,

11 the chemical waste dump?

12 MR. JOHN H. TIDDS: What was your question, Archie? I

13 didn't hear that, sir.

u MR. ARCHIE LUCAS: Who legally owns the property, the

15 chemical waste dump? The people declared bankruptcy and at

16 that time Representative -- State Representative, again

17 Ernie Nunnery at that time, he had to go through a whole

18 lot of hassle to get this thing and I think he had some --

19 in this thing in order to get it done. Somebody had to

20 take the responsibility and he put his neck out on the

21 chopping block. But now that this thing has been in the

22 cleanup stage for approximately six years, who legally owns

23 this property?

24 MR. JOHN JOHNSTON: I don't really think we legally

25 know. That's why, quite frankly, I'm going to back off of
41
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1 that because it doesn't -- That's why we have thirty or

2 forty lawyers that we can call upon to go find out for

3 sure. I don't think I've got it today -- an answer for

4 you. Now we know -- The people we've been working with --

5 MR. JOHN A. TIDDS: Do you know who's responsible?

6 MR. JOHN JOHNSTON: — made the waste, put it out

7 there, are responsible for this local site.

a MR. JOHN A. TIDDS: But you know who's responsible for

9 putting it there, though.

10 MR. JOHN JOHNSTON: Yeah. That we know.

11 MR. JOHN H. TIDDS: That brings up the question with

12 me of who is responsible. This question may be a little

13 bit redundant, but yet it could be important to the future.

14 I might want to dump a few barrels myself.

15 MR. JOHN JOHNSTON: I hope not.

16 MR. JOHN H. TIDDS: But does bankruptcy exonerate the

17 operators of these dump sites from any further liability?

18 It seems to me like you people been --

19 MR. JOHN JOHNSTON: You're talking to an engineer and

20 a biologist. Now I've done a lot of enforcing over the

21 last dozen years. Okay? So I can't give you an attorney's

22 answer and I wouldn't presume to. My experience is that it

23 depends upon the conditions of the bankruptcy and, quite

24 frankly, the bankruptcy judge that conducts the hearing.

25 If you ask for specific examples, I can tell you both yes
42
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1 and no. Okay.

2 MR. JOHN H. TIDDS: That's a good answer.

3 MR. JOHN JOHNSTON: That's the legal system. I'm a

4 biologist.

5 MRS. MARGARET MORRISON: I would like to ask you about

6 the lead. You have a five up there and I'm not a chemist

7 at all. Is that in the ratio of a small amount, a medium

8 amount, or a large amount? I'm very concerned about lead.

9 MR. GLENN ADAMS: I'll answer. That's a very small

10 amount. In parts per billion it's -- I'll explain it.

11 The only way I can think to relate it is, you know,

12 millions -- or a billion stars in the sky and you're

13 looking at one of them and there's five of them. Five —

u Our present standard for lead right now is fifty parts per

15 billion and in August the 18th of 1988 EPA proposed a new

16 standard of five parts per billion in public water supplies

17 at the source, which would be at the distribution point,

18 and ten is per a household. And we are recommending that

19 they go with this five parts per billion as a cleanup goal

20 because in the near future that will be our standard

21 instead of fifty. Does that answer you?

22 MRS. MARGARET MORRISON: I understand that lead cannot

23 be extracted from water. Is that right?

24 MR. GLENN ADAMS: No, mam. It can be.

25 MRS. MARGARET MORRISON: It can be?
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1 MR. GLENN ADAMS: Yes, mam.
2 MR. JOHN H. TI.DDS: But it is accumulative. It is
3 accumulative.
4 MR. GLENN ADAMS: In the body?
s MR. JOHN H. TIDDS: Yeah.
6 MR. GLENN ADAMS: Yeah. That's why we have such a low
7 number for it. The samples where we derived this five from
8 was studied by ATSDR, the Agency for Toxic Substances and
9 Disease Registry, which Jon had mentioned before, did an
10 epidemiological study with lead and determined it for blood
11 levels in children, say lead paint, and the numbers were
12 back calculated to derive these numbers. That's why
13 they're being more stringent.
H MR. ARCHIE LUCAS: If this monitoring continues for
15 the thirty-year period, how often will this site be
16 actually monitored? Soil samples, water samples? How
17 often would it have to be done, Jon?
is MR. JON BORNHOLM: Initially, it'll probably be yearly
19 until we get a data base to base what the extraction system
20 is doing and then it might become every other year and once
21 in every five years. That has not been determined, the
22 exact monitoring sequence yet. But initially it will be --
23 Other sites have been bi-yearly or yearly to start off
24 with.
25 MR. ARCHIE LUCAS: I have a reason for asking that
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1 question, because y'all know very well that Subtitle D is

2 coming down and if we're going to be liable for it for

3 thirty years -- and everybody thinks that that's going to

4 be increased -- and if y'all are going to say y'all have

5 got to do it, then what are y'all going to do with y'all's

6 thirty-year program? That's the reason I asked this

7 question.

8 MR. JOHN JOHNSTON: Quite frankly,-our thirty-year

9 program might be fifty years. It might be five years. Our

10 program is based less on what's in a law than what is

11 needed to clean up the site. The effectiveness of the

12 remedy that we're talking about will determine how long we

13 have to do this and how long we have to monitor it.

14 MR. ARCHIE LUCAS: And, again, will the local people

15 be informed of this monitoring?

16 MR. JOHN JOHNSTON: Yeah.

17 MR. ARCHIE LUCAS: I think that's a big plus, not only

is on y'all's part, but DHEC's, too, to keep the local people

19 there informed of what is and is not.

20 MR. JON BORNHOLM: The information depository for this

21 particular site is located here at this library.

22 MR. ARCHIE LUCAS: Again, why is it in this library

23 and not that library?

24 MR. JOHN JOHNSTON: We'll talk about that. We can do

25 both.
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1 MR. JON BORNHOLM: Other questions, concerns anyone
2 wants to voice now? Okay, as mentioned before, we are in
3 the public comment period for the proposed remedy for the
4 Carolawn site. The public comment period closes on
s September 22nd. That information, your response will be
6 evaluated. Responses will be sent to the people who submit
7 comments to us. We will respond to those. As a collective
8 group, they will be evaluated and taken into consideration.
9 MR. JOHN A. TIDDS: You represent the federal
10 government, right?
11 MR. JOHN JOHNSTON: Yes, sir.
12 MR. JOHN A. TIDDS: And this gentleman down here
13 represents the State of South Carolina, this gentleman
u right here represents Chester County, and I don't know who
15 all these other people are in here. But the fact that you
16 people will tell me you're not aware of a large chemical
17 dump ten miles from the one we're talking about on a power
18 line right-of-way. If somebody had two little pot plants
19 out there, I bet everybody'd know about it. But the fact
20 that we've got three agencies represented here and
21 everybody's telling me they don't know anything about these
22 hundreds and hundreds of drums, that bothers me.
23 MR. JOHN JOHNSTON: Well, first of all, let's say that
24 we're -- there are thousands of people in this country and
25 hundreds of people in this region who are responsible for
46
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1 investigating that type of situation. The fact that I or

2 Jon may not be one of those people does not mean that the

3 federal and the state and the county government aren't

4 working on them, aren't aware of them. My response is I

5 can't tell -- I can't answer your specific question about

6 that particular spot and that's not to say that it is --

7 that we are unaware of it now. That's why I say what I

a want to know is so I can -- I can answer that question

9 once I have a good description of the location where I can

10 pull the map out when I go back to the office and tell the

11 people who are supposed to know, "Do you or do you not?"

12 But if -- To put it this way, I've worked in the Discovery

13 Program for years. I've worked in and managed a program

14 that decided which of these sites needed to go onto the

15 National Priorities List to be the subject of this type of

16 work. I'll guarantee you that there are hazardous waste

17 sites that the federal and state government are not aware

18 of. I'd like to believe that there are sites that -- that

19 those are not causing a problem, but I don't know that uf

20 I'm not aware of it. It's a big country. There are a lot

21 of people. I would have to say if there's anyone in this

22 room who knows about a potential hazardous waste site, the

23 best way to make sure that the federal and state government

24 know about it is to write them or call them and we've got a

25 lot of ways to try and get you to do that.
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1 MR. DICK DUBOSE: That's a key point, John, that we
2 depend very much on this type of information flowing to us.
3 We don't know where all these places are. This is very
4 helpful information for us. It's our main resource.
s MR. JOHN A. TIDDS: It's real hard to take three or
6 four bulldozers and earth-moving machines and dump trucks
7 and twenty-five or thirty people and camouflage them all
s day long where can't nobody see them. That's why I know
9 about it.
10 MR. JOHN JOHNSTON: Sure. And it's not hard to
11 camouflage them from Columbia and it's absolutely easy to
12 camouflage them from Atlanta unless somebody who lives in
13 Chester County can let us know about it. And that's really
u what we want to do. That's why I say when you bring up
15 this sort of information -- I'm real anxious to get the
16 record down and find out if we know about it so I can take
17 it on — talk to the people at DHEC, get somebody out to
is take a look at it. I mean we do have some people here that
19 are capable of doing that.
20 MR. MICHAEL HENDERSON: Yes, sir. We can't more than
21 emphasize this thing of your input because we don't have
22 district officers here. Everything of ours basically works
23 out of Atlanta and we cover eight states, so we don't have
24 people here so we don't know, so this is why we do need
25 your input. I can understand your concern, but if we don't
48
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1 have people, we don't know unless you tell us.

2 MR. AL WILLIAMS: Please, I would like to clear the

3 record. Mr. Tidds has indicated that the we are — that

4 the State is unaware. The site that he describes is

s Landfill, Incorporated. The State has been aware of it

6 from day one. It has been continuously monitored The EPA

7 is aware of it. They have had representatives there. It's

8 inspected annually, monitored monthly and quarterly.

9 MR. JOHN A. TIDDS: Well, if all those drums start

10 leaking, y'all going to run up there and mop them up right

11 quick and they're under the dirt?

12 MR. AL WILLIAMS: I wanted to clear the record in

13 terms of awareness. You have implied that the Department

14 is not aware of it. I'm sure Mr. Lucas —

15 MR. JOHN A. TIDDS: I bet you DHEC don't know about

16 it. .

17 MR. AL WILLIAMS: Chester County is the one that

is passed an ordinance prohibiting —

19 MR. JOHN A. TIDDS: You're the first person admitted

20 to knowing about it.

21 MR. AL WILLIAMS: But I just wanted to clear the

22 record concerning that.

23 MR. JOHN JOHNSTON: Thank you.

24 MR. JON BORNHOLM: Any other questions? I thank you

25 for coming and sharing your evening with us.
49
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1 MR. JOHN H. TIDDS: when are we going to meet again?

2 MR. JOHN A. TIDDS: It's on your menu there.

3 MR. JON BORNHOLM: The next public meeting will be

4 associated with the remedial design, when we have something

s to show the public what is going to be built out there.

6 But we will be --

7 MR. ARCHIE LUCAS: Jon, I have one question on my

8 part.

9 MR. JON BORNHOLM: If there is important information,

10 it'll be sent out in the form of a fact sheet.

11 MR. ARCHIE LUCAS: Who will decide what of the four

12 options will be taken? Who will decide that?

13 MR. JOHN JOHNSTON: The person that signs that

14 decision is a regional administrator, a man named Greer

15 Tidwell out of Atlanta. He's Regional Administrator in

16 charge of the Southeastern Region of the United States --

17 MR. ARCHIE LUCAS: Final decision?

18 MR. JOHN JOHNSTON: -- EPA.

19 MR. ARCHIE LUCAS: Final decision?

20 MR. JOHN JOHNSTON: Final decision, exactly. What

21 you're seeing and taking part in tonight is we're trying --

22 I'm trying to do the job of getting information out so you

23 can say, "I like number four and part of number three,." or

24 make whatever comments that we should take into account

25 when we make a recommendation, Jon, myself, Dick Dubose.
50
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1 And the State has to be consulted. We ask their — for
2 their concurrence. The final decision, if you will, is
3 made by EPA in Atlanta.
4 MR. JON BORNHOLM: I'd like to comment on what John is
5 saying. Some decisions may need to be postponed until the
6 actual design. We won't have time and we drn't have
7 sufficient data right now to talk with the local — the
8 owners or runners of the local sewer treatment plant to
9 tell them or to ask them whether or not they'll help with
10 it. So the decision point -- I guess the remedy that's \
11 actually -- we're discussing is, we are proposing to
12 extract and treat the groundwater, but the final discharge
13 point may not be determined until the remedial design
14 phase.
15 MR. JOHN A. TIDDS: Do I understand that today -- I'm
16 just listening to what's been said collectively -- today
17 that people can go bury these 55-gallon drums as long as
18 everybody knows about it and they monitor them?
19 MR. JOHN JOHNSTON: No, sir.
20 MR. JOHN A. TIDDS: Just drill a bunch of holes and
21 you can put what you want in there?
22 MR. JOHN JOHNSTON: No, sir. By no means. By no
23 means. There are stringent standards for disposal
24 facilities, depending on the type of materials going into
25 the disposal facility. There's a whole host of regulations
51
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1 over the site enforcing capability. To say that anyone can

2 do whatever they want as long as everybody knows about it,

3 no. That's not the case. That would take another evening

4 to try and describe all the things that people have to do

s to get legally into that business.

6 MR. JOHN A. 'TIDDS: But it's evidently being done

7 from, you know, what I'm hearing now about this site up

s behind Colonel Frank's.

9 MR. JOHN JOHNSTON: Not to the best of my knowledge.

10 And what I've just heard is that this a permitted and

11 regulated landfill now.

12 MR. AL WILLIAMS: No, it's closed.

13 MR. JOHN JOHNSTON: It's closed.

14 MR. AL WILLIAMS: It has been for a number of years.

15 MR. JOHN A. TIDDS: Well, that's the way it was when I

16 was in there. There's nothing in there. It's covered up

17 with dirt and it's closed, you know. And if you drill some

is test holes around it -- But still you can't get it back.

19 You tried to get it back from underground at Carolawn in

20 the 70's. You can't get it back out of there. And you it

21 know as well as I do that after it leaks out the drum, it's

22 a little too late to close the barn door.

23 MR. JOHN JOHNSTON: Certainly we're trying to keep

24 that from happening.

25 MR. JOHN A. TIDDS: And carbon steel 55-gallon drums
52
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1 don't have a great history for lasting a long time in the
2 ground.
3 MR. ARCHIE LUCAS: John, let me retract that. I told
4 you I thought this other waste dump was off to the right
5 down at the filling station. What he's doing is
6 confirming -- The one that you're referring to is the one
7 that took us into court on our ordinance. That site's been
a stopped since 1985, I guess, or '84.
9 MR. AL WILLIAMS: Yeah.
10 MR. ARCHIE LUCAS: Somewhere in that period of time.
11 MR. JOHN A. TIDDS: But they didn't take the drums
12 back with them when they stopped.
13 MR. ARCHIE LUCAS: Now I don't know —
u MR. JOHN A. TIDDS: They closed the gate —
15 MR. ARCHIE LUCAS: No. No.
16 MR. JOHN A. TIDDS: -- and put a lock on it and the
17 weeds grew up, but it's still sitting there.
18 MR. ARCHIE LUCAS: But the gentleman was ceased from
19 putting it there. And it's not on a cleanup as this
20 Carolawn is.
21 MR. JOHN A. TIDDS: No, because the drums ain't busted
22 yet.
23 MR. ARCHIE LUCAS: Yeah. It's not on the cleanup
24 program as Carolawn is.
25 MR. JOHN JOHNSTON: Let me suggest --
53
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1 MR. ARCHIE LUCAS: That's a total separate dump from

2 this one.

3 MR. JOHN A. TIDDS: I understand all that.

MR. JOHN JOHNSTON: Okay, if there's no further

5 questions on this issue, I'm here to stay folks. We'll be

6 around. Anybody, if you want to, take your leave; or if

7 you want to, stay and talk about the landfill after anybody

8 else -- we'll stay.

9 THERE BEING NO FURTHER FORMAL DISCUSSION, THE MEETING WAS

10 CONCLUDED.
54
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STATE OF SOUTH CAROLINA )
) CERTIFICATE
COUNTY OF FLORENCE )

I, Cynthia S. Eleazer, Notary Public in and for the

State of South Carolina, certify that I was present at the

public meeting of the United States Environmental

Protection Agency Carolawn Superfund Site Remedial

Investigation/Feasibility Study held at 7:00 P.M. on

August 30, 1989 at the Lancaster County Public Library,

313 South White Street, Lancaster, South Carolina, and that

the foregoing pages constitute a true and accurate

transcript of the meeting in its entirety held at that time

and place.

IN WITNESS WHEREOF, I have hereunto set my hand and.

seal this the 5th day of September, 1989.
CYNTHIA S. ELEAZER, CVR'
Notary Public for South Carolina

(My commission expires 5/28/92)
55
ERRB
•pfsra
EPA - REGION IV
ATLANTA. GA.
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