PB95-964032
EPA/ROD/R04-95/248
February 1996
EPA Superfund
Record of Decision:
Carolawn Operable Unit 2 Site,
Fort Lawn, Chester County, SC
9/21/1995
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RECORD OF DECISION
FOR THE
CAROLAWN (OU2) SUPERFUND SITE
FORT LAWN, CHESTER COUNTY, SOUTH CAROLINA
SEPTEMBER 1995
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 (OU2) Site
Fort Lawn, Chester County, South Carolina
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action
for the Carolawn (OU2) Superfund Site (the Site), located in Fort
Lawn, Chester County, South Carolina, which was chosen in
accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA) , as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA) , 42
U.S.C. §§ 9601 et seq., and, to the extent practicable, the
National Oil and Hazardous Substances Contingency Plan (NCP), 40
C.F.R. Part 300 et sea. This decision is based on the
administrative record file for this Site.
The State of South Carolina concurs with the selected remedy.
DESCRIPTION OF THE SELECTED REMEDY
This remedy is the final action for the Site. In the absence of
any significant source of contamination in the soil, surface water
and sediment at the Site, the No Action alternative was selected as
the preferred alternative to address the soil, surface water and
sediment. In addition, a groundwater remedy has been selected under
a Record of Decision for Carolawn (OUl). However, should future
monitoring of the site (e.g. Five-Year Review) indicate that the
site poses an unacceptable risk to the environment, then EPA, in
consultation with the State of South Carolina, may initiate clean-
up actions under the authority of CERCLA and in accordance with the
National Oil and Hazardous Substances Pollution Contingency Plan.
STATUTORY DETERMINATIONS
Based on the results of the Remedial Investigation and Risk
Assessment conducted for the Carolawn (OU2) Site, EPA has
determined that no further action is necessary to ensure the
protection of human health and the environment, and the selected
remedy is protective of human health and the environment.
Richard D. Green, Associate Director Date
Office of Superfund and Emergency Response
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TABLE OF CONTENTS iii
SECTION . PAGE
1. 0 SITE LOCATION AND DESCRIPTION 1
2 . 0 SITE HISTORY -AND ENFORCEMENT ACTIVITIES 1
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION 5
4 . 0 SCOPE AND ROLE OF RESPONSE ACTION 6
5.0 SUMMARY OF SITE CHARACTERISTICS 6
5.1 Climatology 6
5.2 Surface Hydrology 7
5 . 3 Geologic and Hydrogeologic Setting 8
5.4 Nature and Extent of Contamination 9
6 . 0 SUMMARY OF SITE RISKS 15
A. Human Health Risks 15
A.I Contaminants of Concern 16
A. 2 Exposure Assessment , 16
A. 3 Toxicity Assessment 18
A. 4 Risk Characterization 19
B. Environmental Health 21
B.I Contaminant Identification 21
B.2 Ecological Exposure Assessment. 24
B.3 Ecological Toxicity Assessment 25
B.4 Risk Characterization 25
7.0 DESCRIPTION OF THE "NO FURTHER ACTION" ALTERNATIVE '.28
8 . 0 DOCUMENTATION OF SIGNIFICANT CHANGES 31
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LIST OF FIGURES
FIGURE PAGE
1 Site Location Map 2
2 Site Layout Map. . . . 4
3 Soil Sample Locations 9
4 Surface Water and Sediment Sample Locations 10
5 Electromagnetic Data Contour Map 15
LIST OF TABLES vii
TABLE PAGE
1 Human Health - Summary of COPCs 17
2 Environmental Health - Summary of ECOPCs 23
3 TRVs for the American Robin 26
4 TRVs for the Eastern Cottontail Rabbit. 27
5 Surface Soil HQ for the American Robin 29
6 Surface Soil HQ for the Eastern Cottontail Rabbit 30
LIST OF APPENDICES
APPENDIX A - ANALYTICAL DATA SUMMARIES
APPENDIX B - RESPONSIVENESS SUMMARY
APPENDIX C - STATE LETTER OF CONCURRENCE
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DECISION SUMMARY
CAROLAWN (OU2) SUPERFUND SITE
FORT LAWN, CHESTER COUNTY, SOUTH CAROLINA
1.0 SITE LOCATION AND DESCRIPTION
The Carolawn Site, located on approximately 60-acres of land, is an
abandoned, waste storage and disposal facility located in Fort
Lawn, Chester County, South Carolina. The site is situated less
than three miles west of Fort Lawn, and approximately one-half mile
south of South Carolina. Highway 9 (see Figure 1). Rural and
agricultural areas surround much of the site. The Lancaster &
Chester Railroad and County Road 841 border the site to the south
and Fishing Creek borders the site to the east. Wooded areas and
cultivated fields lie to the west and north of the site.
Approximately 30 permanent, single family residences are located
north of the site; most of which are situated along South Carolina
Highway 9. There are four residences located within 300 yards of
the fenced area with a fifth residence located approximately 1,000
yards west of the site.
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
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.
However, neither an incineration permit nor a storage/disposal
permit was issued to SEPCO by the South Carolina Department of
Health and Environmental Control (SCDHEC).
In January 1975, Columbia Organic Chemical Company (COCO was
contracted to clean up the SEPCO Plant in Clover, South Carolina.
As part of this clean up effort, COCC transported and stored the
waste of approximately 2,000 drums at the Carolawn Site. As
payment for services rendered during the cleanup of the plant in
Clover, South Carolina, COCC received the Carolawn property.
After 1975, South Carolina Recycling and Disposal, Inc. (SCRDI), a
subsidiary of COCC, controlled the site. During 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. After the disposal, SCRDI sold the 3-acre fenced
area of the site to the Carolawn Company.
In 1978, the Carolawn Company began the construction of two
incinerators on the site. With conditional approval of SCDHEC, a
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- Q
q
s
SEPA
FIGURE 1
SITE LOCATION MAP
CAROLAWN SITE
FT. LAWN, SOUTH CAROLINA
SOURCE: DELORME MAPPING, 1993
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Record of Decision
Carolawn (OU2) Superfund Site
Page 3
test burn was conducted with one incinerator; however, full scale
incineration never developed. At the time of abandonment of the
site by the Carolawn Company, the 3-acre 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. In 1979, SCRDI was notified by SCDHEC
that they would have to clean up the Carolawn site.
During the early 1980's, SCDHEC and EPA conducted site
investigations at the Carolawn site. These investigations included
collecting environmental and private residential well samples for
analysis. The results of these investigations showed the presence
of trichloroethane (TCE) and other solvents in nearby residential
wells. The results also indicated that the Site was contaminated
with high levels of metals and organic compounds. 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. The
cleanup activities continued through February 1982, and included
removal of contaminated soils, drums, and liquid waste from the
Site. Subsequently, in December 1982, the Site was proposed for
inclusion on the National Priorities List (NPL). The Carolawn Site
was finalized on the NPL in September, 1983. Since continued
sampling of local residential wells showed persistently high
levels of TCE, the Chester Municipal Sewer District's water
main from Highway 9 was extended to four of the five residences
living near the site. These four residents were connected to this
alternative water supply in 1985.
Due to the complexity of the Carolawn Site, and in order to
simplify the investigation and response activities, EPA divided the
Site into two discrete study areas known as Operable Units (Figure
2) . Operable Unit One (OUl) consists of source areas located on a
3-acre parcel within the fenced area of the Site and the
groundwater located beneath the entire Site (to include the
groundwater beneath Operable Unit Two-OU2). OU2 consists of the
land located immediately around the fenced area and the land
located north and west of the fenced area (north and west drum
areas).
On August 29, 1985, a group of Potentially Responsible Parties
(PRPs) (the Carolawn Generators Steering Committee) entered into a
Partial Consent Decree with the United States Government to conduct
a Remedial Investigation and Feasibility Study (RI/FS) for OUl.
The purpose of this RI/FS was to fully characterized the nature and
extent of the contamination present at the Site and to identify the
relevant alternatives for remedial action. Phase I and Phase II of
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OPERABLE UNIT
TWO
POWER
LINES
OPERABLE UNIT
TWO
WESF
DRUM
AREA
I
CAROLAWN SITE
OPERABLE UNIT ONE
150
SITE LAYOUT MAP
CAROLAWN SITE
FT. LAWN, SOUTH CAROLINA
Figure
2
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Record of Decision
Carolawn (OU2) Superfund Site
Page 5
the RI/FS, conducted at the Site between 1985 and 1989, confirmed
the presence of volatile organic compounds (VOCS) in the
groundwater exceeding Maximum Contaminant Levels ("MCLs") set by
the National Primary Drinking Water Regulations in the Safe
Drinking Water Act. On September 27, 1989, EPA issued a ROD for
OU1 which selected a groundwater interception and extraction system
as the remedy for groundwater contamination at the Site. It was
also determined that due to the effectiveness of the removal
actions, no source of contamination remained within the fenced area
of the site. However, the- findings documented in the ROD for OUl
indicated that limited soil data was collected from the west and
north drum areas located outside the fence; therefore, collection
of additional samples was necessary to confirm the presence or
absence of residual soil contamination in these areas.
In response to these concerns, EPA conducted a field investigation
at the Site in 1990. The purpose of the field investigation was to
provide additional information on the presence or absence of
contaminants in the subsurface soil at the former storage areas
situated outside the fenced area. The sampling results indicated
the presence of VOCs in the soil. Although this area was addressed
during an EPA removal action and again during the 1990 field
investigation by the EPA, Environmental Services Division, some
uncertainties still existed as to the presence or absence of soil
contamination. Based on EPA's review of all the available data, it
was determined, that a Remedial Investigation and Feasibility Study
(RI/FS) needed to be conducted on OU2 in order to develop a
baseline risk assessment which would be used to evaluate a final
remediation disposition for the OU2 area of concern. Therefore, EPA
conducted RI Field activities at the Site in May 1994 and in
October 1994.
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
The information repositories, which includes the Administrative
Record, were established at the Lancaster County Library in 1989
and the Chester County Library in 1995 and are available to the
public at both the information repositories maintained at the
Lancaster County Library, 313 South White Street, Lancaster, South
Carolina, the Chester County Library, 100 Center Street, Chester,
South Carolina and at the EPA, Region IV Library, 345 Courtland
Street, Atlanta, Georgia, 30365. The notice of availability of
these documents was published in "THE ROCKHILL HERALD", "THE
CHESTER NEWS" AND "THE LANCASTER NEWS" on July 24, 1995.
A public comment period for the proposed plan was held from July
24, 1995 to August 24, 1995. A public meeting was held on August
10, 1995, where representatives from EPA answered questions about
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Record of Decision
Carolawn (OU2) Superfund Site
Page 6
the findings of the RI and the Baseline Risk Assessment and
presented EPA's Proposed Plan for the Site.
EPA received oral comments during the August 10, 1995 public
meeting, and written comments during the 30 day public comment
period. Responses to the comments received by EPA are included in
the Responsiveness Summary (Appendix B).
This ROD presents EPA's selected remedial action for the Site,
chosen in accordance with CERCLA, as amended by SARA, and to the
extent practicable, the NCP. The remedial action selection for
this Site is based on information contained in the Administrative
Record. The public and State participation requirements under
Section 117 of CERCLA, 42 U.S.C. § 9617, have been met for this
Site.
4.0 SCOPE AND ROLE OF THIS ACTION WITHIN SITE STRATEGY
This ROD addresses the final response action for the Carolawn Site,
addressing soil, surface water and sediment. Groundwater has been
address under a separate ROD. The Baseline Risk Assessment
indicates that no principal threat exists at the Site, excluding
groundwater. The selected alternative in conjunction with the
previously selected groundwater remedy, will be protective of human
health and the environment and is consistent with the NCP (40 CFR
300.430(e)).
5.0 SUMMARY OF SITE CHARACTERISTICS
5.1 Climatology
The climate of the area is classified as humid-contential, with
long hot summers and short mild winters. The nearest
meteorological station is located in Chester, South Carolina,
approximately 15 miles from the Site. Examination of
meteorological data over a 30-year period indicate that the mean
monthly temperatures range from 42.2°F in January to 79.0°F in
July. The mean annual temperature is 61.1°F. The mean annual
precipitation is 47.11 inches, which is evenly distributed
throughout the year.
5.2 Surface Hydrology
The topography of the Site is somewhat sloped so rainfall runoff,
along with any leached contaminants, would tend to both stand and
percolate into the ground and run off into adjacent surface water
bodies. There are drainage ditches or drainage pipes which would
tend to concentrate and divert runoff directly into adjacent
surface water bodies such as Fishing Creek and the Catawba River.
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Record of Decision
Carolawn (OU2) Superfund Site
Page 7
Fishing Creek is a moderately-sized stream with flow rates of less
than 1000 cubic feet per second (cfs). The Catawba River is a
moderate to large river with an annual flow rate of 4351 cfs.
5.3 Geologic and Hydrogeoloqic 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 during the RI/FS
for OUl were as follows:
i) Alluvial deposits;
ii) Residual and Colluvial 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.
The major hydrostratigraphic unit beneath the Site is the
granodiorite bedrock. Saturated conditions were not encountered in
the Residuum/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.
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Carolawn (OU2) Superfund Site
Page 8
The actual direction of groundwater flow through the bedrock is
dependent upon the orientation of the joints and fractures. The
preferred direction of groundwater flow is to the northeast and
southeast. 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
does not influence, to any great degree, the hydrology of the site.
The estimated groundwater flow velocity is 1.96 x 10"4
centimeters/second (cm/sec) . This in 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.
5.4 Nature and Extent of Contamination
The purpose of the Remedial Investigation (RI) was to gather and
analyze sufficient data to characterize the Site in order to
perform the Baseline Risk Assessment, which determines the Site's
impact on human health and the environment. Both the RI and the
Baseline Risk Assessment are used to determine whether remedial
action is necessary at the Site.
The RI was designed to focus on the remaining areas of potential
contamination not addressed during the RI/FS for Car.olawn (GUI) .
The main portion of the RI was conducted in May 1994. Additional
field work was conducted in October 1994.
During this period, samples of soil, surface water and sediment
were collected to determine the nature and extent of contamination
at the Site. Groundwater was not evaluated in the RI or the
Baseline Risk Assessment, since a groundwater remedy addressing all
contaminated groundwater at the Site has been selected for the
Carolawn (OU1). Contamination at OU2 was characterized by multi-
media sampling. Soil (41 surface and 9 subsurface) samples were
collected from the area surrounding the three-acre fenced area (see
Figure 3) . In addition, one surface soil and one subsurface soil
sample was collected from an offsite location to establish
background conditions for the Site. Four surface water and sediment
samples were collected from Fishing Creek, which borders the site
to the east (see Figure 4) . One of the surface water and sediment
samples was collected upgradient of the Carolawn site to
established background conditions for the Site. All samples
collected during the RI were analyzed for volatile and extractable
organic compounds, pesticides, polychlorinated biphenyls (PCB's)
and metals. Additipnal RI activities included the following: an
ecological site reconnaissance of the Carolawn site and the
surrounding area was conducted in order to identify the various
habitats which are potentially affected by contaminant migration
from the Site; an ecological screening to identify endangered and
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i
BACKGROUND
SAMPLE
POWER
LINES
WEST
DRUM
AREA"
SMALL GRID BOXES = 50' x SO-
LARGE GRID BOXES - 100' x 100'
- SUBSURFACE SOIL
SAMPLE COLLECTED
- TREE LINE
®EPA
APPROXIMATE SCALE
ISO 0 75 ISO
< IN FEET ">
I Inch -ISO ft.
FIGURE 3
SOIL SAMPLE LOCATION MAP
CAROLAWN SITE
FT. LAWN, SOUTH CAROLINA
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-N-
LEGEND
SAMPLE LOCATION
SURFACE WATER AND SEDIMENT SAMPLE LOCATION MAP
CAROLAWN SITE
FT. LAWN.-SOUTH CAROLINA
Figure
4
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Record of Decision
Carolawn (OU2) Superfund Site
Page 11
threatened species within the site area; and an electromagnetic
investigation to locate any buried wastes or metal objects at the
site.
Surface Soil Sampling - The sampling results for surface soils are
presented in Appendix A. Composite surface soil samples were
collected from 41 grids on and around the site (see Figure 3) .
Purgeable organic compounds were detected in samples from nine of
the grids. Trichloroethylene was detected in sample 7-SLA at a
concentration of 27 J ug/kg. Tetrachloroethylene was detected in
four samples. The concentrations ranged from 3J ug/kg in sample
34-SLA to 10J ug/kg in sample 8-SLA. Toluene was detected in eight
samples and ranged in concentration from 2J ug/kg in sample 30-SLA
to 25J ug/kg in sample 7-SLA. Purgeable organic compounds were not
detected in the background sample, 45-SLA.
The pesticides 4,4'-DDT and 4,4'-DDE were detected in sample 3-SLA
at concentrations of 13 ug/kg and 28 ug/kg, respectively. 4,4-DDE
was detected in the background sample, 45-SLA, at a concentration
of 15J ug/kg.
PCB's were detected in nine samples. PCB-1254 was% detected in all
nine samples and ranged in concentration from 28J ug/kg in sample
15-SLA to 5.400C ug/kg in sample 1-SLA. Sample 1-SLA also
contained 440 ug/kg of PCB-1248 and 700C ug/kg of PCB-1260. PCB's
were not detected in the background sample.
Extractable organic compounds were detected in five surface soil
samples. Sample 1-SLA contained 4-nitroaniline, fluoranthene,
pyrene and chrysene at concentrations of 19OJ ug/kg, 92J ug/kg,
110J ug/kg and 180J ug/kg, respectively. Sample 15-SLA contained
790J ug/kg of bis(2-ethylhexyl)phthalate and sample 41-SLA
contained 3,800J ug/kg of 4-nitroaniline. Extractable organic
compounds were not detected in the background sample, 45-SLA.
Presumptive evidence of extractable organic compounds was detected
in all the surface soil samples except samples 2-SLA, 26-SLA and
32-SLA. Unidentified extractable organic compounds were detected
in all the samples except sample 10-SLA, 32-SLA, 38-SLA and 39-SLA.
Sample 4-SLA, 6-SLA and 8-SLA contained the presumptive evidence
of petroleum product. . ,
A variety of metals were detected in the surface soil samples
including: arsenic, barium, chromium, lead, mercury and magnesium.
Elevated concentrations of these metals were detected in one or
more samples. Arsenic was detected in most of the samples at
concentrations less than 5 mg/kg. The exception was sample 41-SLA
which contained 23 mg/kg. Sample 37-SLA also contained arsenic at
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Record of Decision
Carolawn (OU2) Superfund Site
Page 12
a concentration of 5.7 mg/kg. Arsenic was not detected in the
background sample, 45-SLA.
Barium was detected in every sample. With the exception of sample
28-SLA which contained 1,200 mg/kg, the concentrations ranged
between 24J mg/kg in sample and 400 mg/kg in sample 5-SLA. Barium
was detected at a concentration of 100 mg/kg in the background
sample.
Chromium was detected in every sample. Elevated concentrations
above background were detected in samples 4-SLA, 5-SLA, 6-SLA, 7-
SLA and 41-SLA. The concentrations in these samples ranged from
170 mg/kg in sample 5-SLA to 380 mg/kg in sample 4-SLA. Chromium
was detected at a concentration of 14 mg/kg in the background'
sample.
Lead was detected in all the surface soil samples. Seventeen
samples contained concentrations greater than 20 mg/kg. Five
samples including: 4-SLA, 5-SLA, 6-SLA, 7-SLA, 14-SLA and 41-SLA
contained concentrations greater than 100 mg/kg. Lead was detected
at a concentration of 22 mg/kg in the background sample.
Mercury was detected in nine samples including 2-SLA, 4-SLA, 5-SLA,
6-SLA, 7-SLA, 8-SLA, 12-SLA, 14-SLA and 15-SLA. The concentrations
ranged from 0.32 mg/kg in the background sample and sample 15-SLA
to 1.7 mg/kg in sample 6-SLA.
Magnesium was detected in all the samples. Sample 41-SLA contained
an elevated concentration at 26,000 mg/kg. The background sample
contained 4,800 mg/kg of magnesium.
Subsurface Soil Sampling - Nine subsurface soil samples were
collected from grids 1, 3, 5, 11, 13, 15, 26, 33 and 35 (see Figure
3) . The analytical results are included in Appendix A. No
purgeable organic compounds or pesticides were detected in any of
the samples. Sample 5-SLB contained 48 ug/kg of PCB-1254.
Presumptive evidence of extractable organic compounds was detected
in samples 1-SLB, 5-SLB, 15-SLB, 26-SLB, 33-SLB and 35-SLB. The
concentrations ranged from 80JN ug/kg of aminoanthracenedione in
sample 1-SLA to 4,OOOJN ug/kg of phenanthrenol in sample 26-SLB.
Phenathrenol was also detected at 4,OOOJN ug/kg in sample. 33-SLB.
Unidentified compounds were detected in samples 5-SLB, 15-SLB, 26-
SLB, 33-SLB and 35-SLB. Sample 5-SLB contained the presumptive
evidence of petroleum product. The background sample, 45-SLB, did
not contain any extractable organic compounds.
A variety of metals was detected in the subsurface soil samples.
Elevated concentrations of magnesium were detected in six of the
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Record of Decision
Carolawn (OU2) Superfund Site
Page 13
nine samples and ranged in concentration from 6,700 mg/kg in sample
11-SLB to 15,000 mg/kg in sample 3-SLB. The background sample, 45-
SLB, contained-3, 000 mg/kg of magnesium. An elevated concentration
of nickel, 56 mg/kg, was detected in sample 33-SLB. The background
sample contained 20 mg/kg of nickel.
Sediment Sampling - Four sediment samples were collected from
Fishing Creek at the locations indicated on Figure 4. Analytical
results are summarized in Appendix A. No purgeable organic
compounds, PCB's or pesticides were detected in any of the samples.
Two samples contained extractable organic compounds, Sample 2-SD
contained one unidentified compound at a concentration of 900J
ug/kg. Sample 4-SD contained 15 unidentified compounds and the
presumptive evidence of four additional compounds.
A variety of metals was detected in all of the samples.
Concentrations of the individual metals were consistent up and down
gradient of the site with the exception of sample 3-SD. Arsenic
and barium were detected in sample 3-SD at concentrations of 0.91J
mg/kg and 24 mg/kg, respectively. Neither of these metals was
detected in any other sample.
Surface Water Sampling - Four surface water samples were collected
from four locations in Fishing Creek as indicated on Figure 4'.
Analytical results are summarized in Appendix A. Sample 201-SW is
a duplicate of sample. 1-SW. No purgeable or extractable organic
compounds, pesticides or PCB's were detected in any of the samples.
Metals were detected in all of the samples. Primary MCL's were not
exceeded for any of the samples. The secondary MCL's for aluminum
(0.05-0.2 mg/1), manganese (0.05 mg/1) and iron (0.3 mg/1) were
exceeded in all of the samples. The field parameters of pH,
specific conductance and temperature were measured at each
location. Results are presented in Appendix A.
Ecological Screening - An endangered and threatened species and
critical habitat screening was conducted to identify listed
species that are found in the Carolawn Site vicinity. Data
regarding the actual, past, or potential presence of rare,
threatened, and endangered species have been obtained from the
United States Fish and Wildlife Service, as well a's the South
Carolina Department of Natural Resources. Several federally-
designated endangered or threatened species are thought to occur in
the central and eastern portions of South Carolina. However, there
are no critical habitats for federally/state-designated endangered
or threatened species on or near the Carolawn site.
Electromagnetic Investigation - The primary purpose of this
Electromagnetic investigation (EM) was to locate any buried waste
or metal objects at the site. The EM investigation was conducted at
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Record of Decision
Carolawn (OU2) Superfund Site
Pag'e 14
the site using a Geonics EM-31 which is a noncontacting ground
conductivity meter. A cartesian coordinate 25 feet by 25 feet grid
system was established. Measurements were obtained from the center
of each grid. The results of the EM conductivity survey performed
at 130 stations are presented as a computer generated contour map
on Figure 5.
The data generated consisted mostly of low values ranging from -2
to 98 mmhos/m. The highest value (98 mmhos/m) was due to
interference from the fence. Consequently, this value was not used
in preparing Figure 5. No magnetic anomalies were detected which
would indicate the presence of buried metal objects.
6.0 SUMMARY OF SITE RISKS
A Baseline Risk Assessment was conducted as part of the RI to
estimate the health or environmental threats that could result if
no further action were taken at the Carolawn (OU2) site. Results
are contained in the Final Baseline Risk Assessment Report. A
Baseline Risk Assessment represents an evaluation of the risk posed
if no remedial action is taken. The assessment considers
environmental media and exposure pathways that could result in
unacceptable levels of exposure now or in the foreseeable future.
Data collected and analyzed during the RI provided the basis for
the risk evaluation. The risk assessment process can be divided
into four components: contaminant identification, exposure
assessment, toxicity assessment, and risk characterization.
A. HUMAN HEALTH RISK ASSESSMENT
A.I Contaminants of Concern
Data collected during the RI were evaluated in the Baseline Risk
Assessment. Contaminants were not included in the Baseline Risk
Assessment evaluation if any of the following criteria applied:
• Inorganic chemicals were eliminated if the maximum detected
concentration was less than two times the average background
concentration. Organic chemicals were retained regardless of
the background concentration because they are not considered
to occur naturally.
• In absence of Region IV soil screening values, inorganic and
organic chemicals were eliminated from further consideration
if their maximum detected concentration did not exceed the EPA
Region III screening criteria for residential soil.
• EPA Region IV has not developed screening values for sediment
ingestion and dermal contact by humans. Therefore, inorganic
-------
O)
_c
ti
O
1038200.0-
1038100.0-
1038000.0-
1037900.0-
1037800.0-
1037700.0
• Data Point
Contour Line (mmhos/m)
2016700.0 2016800.0 2016900.0 2017000.0 2017100.0 2017200.0 2017300.0 2017400.0
Easting
FIGURE 5
ELECTROMAGNETIC DATA CONTOUR MAP
CAROLAWN SITE
FT. LAWN, SOUTH CAROLINA
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Carolawn (OU2) Superfund Site
Page 16
and organic chemicals were eliminated from further
consideration if their maximum, detected concentration did not
exceed EPA Region III screening criteria for residential soil.
Chemicals that were retained and evaluated in the Baseline Risk
Assessment are known as chemicals of potential concern (COPCs).
The following is a summary of the COPCs identified in each media
sampled. In addition, a summary table is presented as Table 1
showing all of the COPCs by medium.
Soil. The results of the surfical soil analyses indicated that
there are several COPCs present in the soil cover. These compounds
include: arsenic, barium, beryllium, calcium, chromium, copper,
iron, lead, magnesium, manganese, sodium and polychlorinated
biphenyls (PCBs). The results of subsurface soil analyses indicate
that there are several COPCs. These compounds include: arsenic,
barium, copper, lead, manganese, mercury, zinc, PCBs,
tetrachloroethene and toluene. Other concentrations of inorganics
and organics were detected in the soil. However, the concentrations
of these contaminants were below the typical background
concentration ranges for native soils or were below the threshold
standards established by EPA.
Surface Water and Sediment. There were no COPCs identified for
surface water. In addition, no volatile and extractable organic
compounds, pesticides or PCBs were detected in any of the samples.
Metals were detected in all of the surface water samples. However,
the concentrations of these contaminants were below the typical
background concentration ranges.
The sediment analyses revealed that arsenic is the only chemical of
potential concern in sediment. In addition, no volatile organic
compounds, pesticides or PCBs were detected in any of the samples.
In summary, the results of the Baseline Risk Assessment concluded
that there were no chemicals that significantly contributed to the
exposure pathways having a Hazard Quotient above 1 or a cancer risk
outside of the EPA acceptable range (1E-6 to 1E-4).
A.2 Exposure Assessment
An exposure assessment was conducted to estimate the magnitude of
exposure to .the contaminants of potential concern at the Site and
the pathways through which these exposures could occur. The results
of this exposure assessment are combined with chemical-specific
toxicity information to characterize potential risks. Human
receptors on or near the site were characterized under current and
potential future land use (residential) scenarios. The exposure
pathways evaluated quantitatively for the current use scenario (for
-------
TABLE 1
HUMAN HEALTH
SUMMARY OF CHEMICALS OF POTENTIAL CONCERN
Chemical
Inorganics
Aluminum
Arsenic
Barium
Beryllium
Calcium
Chromium
Copper
Iron
Lead
Magnesium
Manganese
Potassium
Sodium
Vanadium
Pesticides/PCBs
PCBs
Surface Soil
X
X
X
X
X
X
X
X
X
X
X
Subsurface Soil
X
X
X
X
X
x
X
X
X
X
X
Sediment
X
There were no contaminants of potential concern identified for surface water.
17
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Page 18
adults and children) are incidental ingestion of surfical soil,
dermal contact with surfical soil, incidental ingestion of sediment
from Fishing Creek and dermal contact with sediment in Fishing
Creek. The. exposure pathways evaluated under the future use
scenario, include the four mentioned above as well as incidental
ingestion of subsurface soil, and dermal contact with subsurface
soil.
After exposure pathways were developed, the concentrations at the
exposure points were calculated. ' These exposure point
concentrations were based on the reasonably maximum exposure (RME)
scenario - that is, the highest exposure that is reasonably
expected to occur at a Site. The RME is calculated by taking the
95% upper confidence limit on the mean of the natural logarithm
(In) transformed data. The data are transformed because the data
are assumed to be lognormal.
Once exposure point concentrations were developed, the chemical
intake at each exposure point was calculated. These assumptions,
along with the exposure point concentrations are used in equations
to develop the Chronic Daily Intake (GDI) for each exposure
pathway.
A.3 Toxicity Assessment
The purpose of the toxicity assessment is to assign toxicity values
(criteria) to each chemical evaluated in the Baseline Risk
Assessment. The toxicity values are used in combination with the
estimated doses to which a human could be exposed to evaluate the
potential human health risks associated with each contaminant.
Human health criteria developed by EPA (cancer slope factors and
non-cancer reference doses) were preferentially obtained from the
Integrated Risk Information System (IRIS, 1993) or ttie 1992 Health
Effects Assessment Summary Tables (HEAST; EPA, 1992) . In some
cases the Environmental Criteria Assessment Office (ECAO, 1992) was
contacted to obtain criteria for chemicals which were not listed in
IRIS or HEAST.
Slope factors (SF) have been developed by EPA for estimating excess
lifetime cancer risks associated with exposure to potentially
carcinogenic contaminants of concern. SFs, which are expressed as
risk per milligram per kilogram day, are multiplied by the
estimated intake of a potential carcinogen, in mg/kg-day, to
provide an upper-bound estimate of the excess lifetime cancer risk
associated with exposure at that intake level. The term "upper
bound" reflects the conservative estimate of the risks calculated
from the SF. Use of this approach makes underestimation of the
actual cancer risk highly unlikely. Slope factors are derived from
the results of human epidemiological studies or chronic animal
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bioassay data to which mathematical extrapolation from high to low
dose, and from animal to human dose, has been applied, and
statistics to account for uncertainty-have been applied (e.g. to
account for the use of animal data to predict effects on humans).
Reference doses (RfDs) have been developed by EPA for indicating
the potential for adverse health effects from exposure to the
chemicals of concern exhibiting noncarcinogenic effects. RfDs,
which are expressed in units of mg/kg-day, are estimates of daily
exposure levels for humans, including sensitive subpopulations,
that are likely to be without risk of adverse effect. Estimated
intakes of contaminants of concern from environmental media (e.g.
the amount of a chemical of concern ingested from contaminated
drinking water) can be compared to the RfD. RfDs are derived from
human epidemiological studies or from animal bioassay data to which
uncertainty factors have been applied (e.g., to account for the use
of animal data to predict effects on humans).
A.4 Risk Characterization
In this final step of the risk assessment, the results of the
exposure and toxicity assessments are combined to provide numerical
estimates of the carcinogenic and non-carcinogenic risks for the
Site.
Cancer Risk is expressed as an incremental probability of an
individual developing Cancer over a lifetime as a result of
exposure to the potential carcinogen. Excess lifetime cancer risks
are determined by multiplying the intake level with the slope
factor. These risks are probabilities that are generally expressed
in scientific notation ( IE-06 or IxlO"6) . An- excess lifetime
cancer risk of IE-06 indicates that, as a plausible upper bound,
an individual has a one in one million additional chance of
developing cancer, over a 70 year lifetime, as a result of site-
related exposure to a carcinogen. The NCP states that sites should
be remediated to chemical concentrations that correspond to an
upper-bound lifetime cancer risk to an individual not exceeding
1E-06 to 1E-04 excess lifetime risk. Carcinogenic risk levels that
exceed this range indicate the need for performing remedial action
at the site.
The total incremental lifetime cancer risk for offsite residents
under current land use conditions was 1E-06. This represents the
sum of a child (age 1 to 6) , adolescent (age 7-16), and adult (age
7-30), who is exposed to surface soil and sediment. The risk is
primarily due to exposure of arsenic in surface soil and sediment.
This risk is at the risk level determined to be protective by EPA.
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The incremental cancer risk for future onsite workers was 6E-06.
This was the sum of both exposure pathway risks - incidental
ingestion of, and dermal contact with, surface soil. The risk was
due to incidental ingestion of, and dermal contact with, arsenic,
beryllium, and PCBs: This risk is within the risk range deemed
protective of human health by the EPA.
The lifetime excess cancer risk for future onsite construction
workers was 2E-06. This was the sum of all four exposure pathway
risks- incidental ingestion of surface and subsurface soil, and
dermal contact with surface and subsurface soil. The risk was due
to incidental ingestion of, and dermal contact with, arsenic,
beryllium, and PCBs (surface soil only) in both surface and
subsurface soil. This risk is within the risk range deemed
protective of human health by the EPA.
The total incremental lifetime cancer risk for future onsite
residents was 2E-05. This was the sum of all four pathway risks -
incidental ingestion of soil, dermal contact with soil, incidental
ingestion of sediment, and dermal contact with sediment for both
child and adult residents. The risk was due to incidental ingestion
of, and dermal contact with, arsenic in sediment, and arsenic,
beryllium, and PCBs in surface soil.
To characterize potential noncarcinogenic effects, estimated intake
levels are compared with toxicity values. Potential concern for
noncarinogenic effects of a single contaminant in a single medium
is expressed as a Hazard Quotient (HQ). A Hazard Quotient is
calculated for non-carcinogens to assess whether health problems,
other than cancer, might be associated with a Superfund site. It
is derived by dividing the chemical exposure level at the site by
the chemical level determined .to be safe. If the Hazard Quotient
is greater than 1 .there may be concern for potential health
effects. Hazard quotients are calculated for each chemical of
potential concern found at the site. To assess the overall
potential for non-carcinogenic effects posed by more than one
chemical, all of the hazard quotients calculated for each chemical
are added together. The sum of the hazard quotient is called a
hazard index (HI) . Like the hazard quotient, if the hazard index
is greater than 1.0 then the contaminants pose a possible health
risk.
An evaluation of the noncarcinogenic risk calculations presented in
the risk assessment indicates that all of the hazard indices under
the current and future use scenarios are less than 1.0.
The total HI for current adolescent trespassers was 0.03, primarily
due to incidental ingestion of, and dermal contact with arsenic,
chromium (VI), and PCBs in surface soil.
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Carolawn (OU2) Superfund Site
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The total HI for current offsite child residents (age 1 to 6) was
0.005, due to incidental ingestion of, and dermal contact with,
-arsenic in surface soil. The total HI for the current offsite
adult resident was 0.0007, also due to incidental ingestion and
dermal contact with arsenic in sediment.
The total HI for future onsite workers was 0.08, primarily due to
incidental ingestion of, and dermal contact with PCBs, arsenic,
chromium, and manganese in surface soil. Future onsite
construction workers exposed to both surface and subsurface soil
had a total HI of 0.7, primarily due to incidental ingestion of,
and dermal contact with PCBs, chromium, and arsenic in surface
soil; and aluminum, arsenic, chromium, and vanadium in subsurface
soil.
The total HI for future onsite child residents(age 1 to 6) was 0.7,
primarily due to incidental ingestion of, and dermal contact with,
arsenic, chromium, and PCBs in surface soil. The total HI for
future onsite adult residents (age 7 to 30) was 0.1, once again
primarily due to incidental ingestion of, and dermal contact with,
arsenic, chromium, and PCBs in surface soil.
To conclude, carcinogenic risk estimates for current and future
conditions are either below the lower limit 1E-6 or within EPA's
acceptable range (1E-6 to 1E-4). No non-carcinogenic hazard indices
exceeded EPA's acceptable level of 1.0. In summary, EPA has
determined that risks to human health from contaminants in the soil
and sediment are within EPA's acceptable risk range and that
remediation of the soil and sediment would not be required for the
protection of human health.
B. ECOLOGICAL RISK ASSESSMENT
B.I Contaminant Identification
A qualitative risk assessment was conducted to determine if
ecological chemicals of potential concern (ECOPCs) posed an
unacceptable risk to the ecological receptors on and near the Site.
ECOPCs are a subset of all chemicals positively identified at the
Site. The screening criteria that are used to select ecological
chemicals of potential concern are specific to ecological
receptors; therefore, ECOPCs may often include different individual
chemicals than the human health assessment. The chemicals at the
Site were evaluated as follows:
1) Chemicals were not listed if they were not .detected in the RI
environmental samples provided that the sample quantitation
limit (SQL) was not in excess of the appropriate screening
values;
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Carolawn (OU2) Superfund Site
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2) Inorganic chemicals were eliminated if the detected
concentrations did not exceed two times the background
concentration (provided that the background concentration did
not exceed screening levels);
3) All chemicals were eliminated if they were only tentatively
identified;
4) All chemicals with a low frequency of detection (less than 5
percent for any media being evaluated) were eliminated from
consideration;
5) Chemicals were eliminated from consideration if the maximum
detected concentration did not exceed the appropriate
screening value;
6) All inorganic chemicals in surface, soils for which the range
of detection did not exceed the chemicals natural background
concentrations were eliminated from consideration.
The following is a summary of the ECOPCs identified in each media
sampled. In addition, a summary table is presented as Table 2
showing all of the ECOPC by medium.
Soil. The results of the surficial soil analyses indicated that
there are several ECOPCs present in the soil cover. These
compounds include: arsenic, barium, copper, lead, manganese,
mercury, zinc, PCBs, tetrachloroethene, and toluene. Other
concentrations of inorganics and organics were detected in the
soil. However, the concentrations of these contaminants were below
the typical background concentration ranges for native soils or
were below the threshold standards established by EPA.
Sediment. With the exception of barium, all chemicals detected in
sediment were eliminated as an ECOPC. Barium was unable to be
eliminated from sediment during the screening process, because no
screening value or background concentration was available.for this
compound. However, barium is not likely to cause a threat to the
aquatic environment because it normally precipitates out of
solution as an insoluble salt and therefore is less bioavailable to
aquatic organisms. It should be noted that it is unlikely that
barium in sediment will pose a significant risk to terrestrial
organisms at the site. The rationale behind this statement is that
it is unlikely that terrestrial organisms will come in direct
contact with the sediment at the site. In addition, barium is not
known to bioaccumulate; therefore, this limits the possibility that
terrestrial as well as aquatic organisms will come into direct
contact with these contaminants through the food chain. For these
reasons, exposure of terrestrial and aquatic organisms to barium in
-------
TABLE 2
ENVIRONMENTAL HEALTH
SUMMARY OF ECOLOGICAL CHEMICALS OF POTENTIAL CONCERN
Chemical
Inorganics
Arsenic
Barium
Copper
Lead
Manganese
Mercury
Zinc
Pesticides/PCBs
PCBs
Purgeable Organics
Tetrachloroethene
Toluene
Surface Soil
X
X
X
X
X
X
X
x
X
X
Sediment
X
There were no contaminants of potential concern identified for surface water.
Barium was unable to be eliminated from sediment during the screening process,
because no screening value or background concentration was available for this
compound. In addition, barium is not known to bioaccumulate; therefore, this limits
the possibility that terrestrial as well as aquatic organisms will come into direct
contact with these contaminants through the food chain. For these reasons, exposure
of terrestrial and aquatic organisms to barium in sediment was not further evaluated
in this Baseline Risk Assessment.
23
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Record of Decision
Carolawn (OU2) Superfund Site
Page 24
sediment was not further evaluated in this Baseline Risk
Assessment.
B.2 Ecological Exposure Assessment
Once the contaminants have reached the habitat, one or more of
three possible exposure routes may come into play for a specific
receptor. These exposure routes are 1) ingestion, 2) respiration,'
and 3) direct contact. Ingestion of contaminants occurs when an
organism ingests contaminated food or incidentally ingests other
contaminated media while feeding or through incidental ingestion of
contaminated soil. Respiration of contaminants occurs when an
organism absorbs contaminants across a respiratory membrane.
Contaminants are also absorbed through direct contact with body
parts other than the respiratory organs.
In this particular study, the exposure route via ingestion (of
soils) was evaluated for the American robin (Turdus migratorius)
and the eastern cottontail rabbit (Sylvilagus floridanus) in order
to estimate the magnitude of actual or potential exposure to ECOPC
in the surface soil. Intake modeling was necessary to estimate the
actual dosage of contaminants that these species may be ingesting
from'the surface soil. Estimates of dosage were based on daily
intake rates and the exposure concentration.
Neither the exposure route via respiration or direct contact
(dermal) were estimated for terrestrial receptors. The air pathway
was not a concern in this particular study and was eliminated.
Also, both the inhalation and dermal exposure routes become very
complex to model (EPA, 1993).
The exposure point concentration (EPC) is the concentration of a
contaminant in an environmental medium to which a specific receptor
is exposed. .It is generally calculated using statistical
methodology from a set of data derived from environmental sampling.
The specific methodology used to derive the exposure point
concentrations in this Baseline Ecological Risk Assessment (BERA)
is presented below.
For ECOPC and media in which the number of samples was less
than 3, the maximum concentration detected was used to
represent the exposure point concentration.
For chemicals and media in which the number of samples was
equal to or greater than 3, the upper 95 percent confidence
limit (UCL) of the log normal arithmetic mean was used to
represent the exposure point concentration. In calculating
the UCL, one-half the value of the detection limit was used in
calculating the log normal mean for all non-detect samples.
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Carolawn (OU2) Superfund Site
Page 25
For chemicals and media in which the UCL exceeded the maximum
detected concentration, the maximum concentration detected was
used to represent the exposure point concentration.
In this particular study, the two surrogate terrestrial receptors
(American robin and eastern cottontail rabbit) chosen for study are
thought to be exposed to contaminated surface soils via either
incidental ingestion of the soil or by ingestion of contaminated
food. Total exposure of these organisms to the contaminated surface
soil was estimated by approximating how much of the contaminated
media and/or food the receptor is taking in on a daily basis. This
value is otherwise known as the daily intake (DI) dose. The
equation and process used to calculate the DI dose for each of
these species is presented in the Baseline Risk Assessment.
B.3 Ecological Toxicity Assessment
The ecological toxicity assessment involves determining the types
of adverse effects associated with contaminant exposures, the
relationship between the magnitude of exposure and adverse effects,
and the related uncertainties involved with the assessment.
Environmental toxicity data often comes in the form of the
concentration or dose necessary in order to induce some observed
effect or response. Quite frequently the observed effect is some
sort of mortality event such as the death of 50 percent of the
population in an experimental environment (i.e. LC50 or LD50) . In the
case of this ecological risk assessment, environmental toxicity
data often comes in the form of environmental benchmarks, such as
NOAELs or LOAELs, obtained from various research studies.
The Toxicity Values for the ECOPC contained in surface soil that
were used to gage relative risk in this BERA were obtained either
directly from the literature, from chemical specific documents
issued by the Agency of Toxic Substances and Disease Registry,
biological reports issued by the United States Fish and Wildlife
Service, from chronic No-Observed-Adverse-Effect-Level (NOAEL) or
chronic Lowest-Observed-Adverse-Effect-Level (LOAEL) obtained from
HEAST, March 1994, or Toxicological Benchmarks for Wildlife.
A safety factor of 10 was applied when converting from a chronic
LOAEL to a chronic NOAEL. A listing of TRVs for the American robin
and the eastern cottontail rabbit for each ECOPC in the surface
soil is presented in Table 3 .and 4, respectively.
B.4 Ecological Risk Characterization
Risk Characterization is the final phase of the risk assessment.
It is at this phase that the likelihood of adverse effects
occurring as a result of contaminant exposure to a contaminant is
evaluated. In order to give "risk" a numerical value, a Hazard
Quotient (HQ) for each ECOPC is "developed.
-------
TABLE 3
TRVs FOR THE AMERICAN ROBIN
CAROLAWN SITE (OU2) ECOLOGICAL RISK ASSESSMENT
FORT LAWN, SOUTH CAROLINA
CHEMICAL
INORGANICS
ARSENIC
COPPER
LEAD
MANGANESE
MERCURY
ZINC
ORGANICS
TETRACHLOROETHENE
TOLUENE
PESTICIDES/PCBs
PCBs
TRY
DERIVATION
SPECIES/REFERENCE
Brown-headed cowbird (2)
1 -day old chicks (3)
American Kestrel (2)
New Hampshire chicks (4)
Ring-necked pheasant (2)
Domestic hen (2)
Mouse (1)
Mouse (3)
Ring-necked Pheasant (3)
LOAEL VALUE
nig/kg/day
I.10EMJ2
3.32EI02
5.00E+02
7.2IEH12
4.20E-HM
2.03E+04
1.40E+02
2.60E+02
1.80E+00
NOAEL VALUE
mg/kg/day
I.IOEKM
3.32E^)I
. 5.00EJOI
7.2IEIOI
4.2UEIOO
2.03 E+03
1.40E+01
2.60E+OI
I.80E-OI
ROBIN
LOAEL TRV
1.10E-I02.
3.32K+02
5.00EI02
7.20EI02
4.2()EtOt
2.03E+04
1.40E+02
2.60E+02
1.80E+00
RODIN
NOAEL TRV
I.IOI-KH
3.32EK1I
5.()OEK)I
7.20F.K)!
4.201iK)0
2.03 E^03
I.40E+OI
2.60E-HJI
I.80E-01
(l)HEAST, March, 1994
(2) Eisler, January, 1988; April, 1988; April 1987; April, 1993
(3) Opresko, D.M.; B.E. Sample; O.W. Suter II. Toxicological Benckmarks for Wildlife : 1994 Revision
(4) Gallup, Willis D. and L.C. Norris
A safety factor of 10 was applied to the LOAEL value to extrapolate to a NOAEL value.
26
-------
TABLE 4
TRVS FOR THE EASTERN COTTONTAIL RABBIT
CAROLAWN SITE (OU2) ECOLOGICAL RISK ASSESSMENT
FORT LAWN, SOUTH CAROLINA
CHEMICAL
INORGANICS
ARSENIC
COPPER
LEAD
MANGANESE
MERCURY
ZINC
ORGANICS
TETRACHLOROETHENE
TOLUENE
PESTICIDES/PCBs
PCBs
TRY
DERIVATION
SPECIES/REFERENCE
Mouse (3)
Mink (3)
Rat (3)
Rat (3)
Mouse (3)
Rat (3)
Mouse (2)
Mouse (3)
Rat(l)
LOAEL VALUE
mg/kg/Jay
1.26E+00
1.17E+02
8.00E+01
8.80E+02
1.32E+02
1.60EH-03
1.40E+02
2.60E+02
l.OOE+01
NOAEL VALUE
mg/kg/day
1.26E-01
1.I7E+01
8.00E+00
8.80E+01
1.32E+01
1.60E+02
1.40E+01
2.60E+01
l.OOE+00
RABBIT
LOAEL TRY
1.26E+00
1.17E+02
8.00E-HJ1
8.80E-I-02
1.32E+02
1.60E+03
1.40E+02
2.60E+02
l.OOE+01
RABBIT
NOAEL TRV
1.26E-01
1.17E+01
8.00E+00
8.80E+01
1.32E+01
1.60E+02
1.40E+01
2.60E+01
l.OOE+00
TRV - Toidcity Reference Value
(1) Agency of Toxic Substances and Disease Registry (ATSDR)
(2) HEAST. March, 1994
(3) Opresko, D.M.; B.E. Sample; G.W. Suter II. Toxicological Benckmarks for Wildlife : 1994 Revision
A safety factor of 10 was applied to the LOAEL value to extrapolate to a NOAEL value.
27
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Record of Decision
Carolawn (OU2) Superfund Site
Page 28
The Hazard Quotient (HQ) method was used to define potential risk
to the two representative terrestrial receptors via the soil
exposure pathway. This method involves: 1) Estimating the
exposure of each receptor species to ECOPCs by ingestion of
contaminated food arid/or soil; 2) Determining from past scientific
studies the highest exposure level which produces no observed
adverse effects (NOAEL) and the lowest exposure level which
produces observed adverse effects (LOAEL) in the representative
species; and, 3) Dividing the estimated receptor species exposure
level by the NOAEL and LOAEL. A LOAEL based HQ greater than 1 is
indicative that there may be a potential for adverse effects on the
receptor species.
Using the american robin as a potential receptor for the soil
exposure pathway,, the LOAEL HQ values ranged from 4.7E-06 to 6.1E-
01 and the NOAEL HQ values ranged from 4.7E-05 to 6.1E+00 (See
Table 5) . In accordance with EPA's draft guidance (Ecological Risk
Assessment Guidance for Superfund - Process for Designing and
Conducting Ecological Risk Assessments) for Ecological Risk
Assessments, remedial goals for the protection of ecological
receptors should be bounded by the NOAEL value on the lower end and
the LOAEL value on the upper end. Thus, the risk range is between
6.IE-01 to 4.7E-05 which does not exceed EPA's acceptable level of
1.0 -.
Using the eastern cottontail rabbit, a potential receptor for the
soil exposure pathway, the LOAEL values ranged from 8.8E-08 to
6.2E-03 and the NOAEL values ranged from 8.8E-07 to 6.2E-Q2 (See
Table 6). In accordance with EPA's guidance for Ecological Risk
Assessments, remedial goals for the protection of ecological
receptors should be bounded by the NOAEL value on the lower end and
the LOAEL value on the upper end. Thus, the risk range is between
6.2E-03 to 8.8E-07 which does not exceed EPA's acceptable level of
1.0.
In summary, EPA has determined that risks to the ecological
receptors from contaminants in the soil are below EPA's acceptable
risk range and that remediation of the soil would not be required
for the protection of the environment.
7.0 DESCRIPTION OF "NO ACTION" SELECTED ALTERNATIVES
EPA has determined, based on the results of the Remedial
Investigation and the Baseline Risk Assessment, that no action is
needed for the soil, surface water or sediment. In addition, a
groundwater remedy has been selected under a Record of Decision
issued for Carolawn (OUl). However, should future monitoring of the
site (e.g. Five-Year Review) indicate that the site poses an
unacceptable risk to the environment, then EPA, in consultation
with the State of South Carolina, may initiate clean-up actions
under the authority of CERCLA and in accordance with the National
Oil and Hazardous substances Pollution Contingency Plan.
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TABLE 5
SURFACE SOIL HAZARD QUOTIENTS FOR THE AMERICAN ROBIN
CAROLAWN SITE (OU2) ECOLOGICAL RISK ASSESSMENT
FORT LAWN, SOUTH CAROLINA
INORGANICS
ARSENIC
9.06E-01
7.63E400
1.05E+00
I.10E+02
1.10E+01
8.2E-03
6.9E-02
9.5E-03
8.2E-02
6.9E-01
9.5E-02
COPPER
7.22E+00
5.19E+01
1.01E+01
3.32E+02
3.32E+01
2.2E-02
1.6E-01
3.0E-02
2.2E-01
1.6E+00
3.0E-01
LEAD
1.16E+01
7.41E+01
1.81E+01
5.00E+02
5.00E+01
2.3E-02
1.5E-01
3.6E-02
2.3E-01
1.5E4-00
3.6E-01
MANGANESE
4.44E+01
1.64E+02
6.83E+01
7.21E+02
7.21E+01
6.2E-02
2.3E-01
9.5E-02
6.2E-01
2.3E+00
9.5E-01
MERCURY
7.37E-02
S.64E-01
9.13E-02
4.20E+01
1.8E-03
1.3E-02
2.2E-03
1.8E-02
1.3E-01
2.2E-02
ZINC
8.40E+01
3.99E-I-02
1.01E+02
2.03E+04
2.03E+03
4.1E-03
2.0E-02
5.0E-03
4.1E-02
2.0E-01
5.0E-02
ORGANICS
TETRACHLOROETHENE
9.13E-04
9.54E-04
1.40E+02
1.40E+01
6.5E-06
1.1E-05
6.8E-06
1.1E-04
6.8E-05
TOLUENE
1.22E-03
4.76E-03
1.32E-03
2.60E+02
2.60E+01
4.7E-06
1.8E-OS
5.1E-06
4.7E-05
1.8E-04
5.1E-05
PESTICIDES/PCBs
PCBs
9.87E-03
1.09E+00
6.12E-02
1.80E+00
1.80E-OI
5.5E-03
6.1E-01
3.4E-02
J.5E-02
6.1E+00
3.4E-01
•(•Hazard quotients derived from LOAEL TRVs
•Hazard quotients derived from NOAEL TRVs
EPC - Exposure Point Concentrations
TRY • Toxicity Reference Values
HQ - Hazard Quotient
29
-------
TABLE 6
SURFACE SOIL HAZARD QUOTIENTS FOR THE EASTERN COTTONTAIL RABBIT
CAROLAWN SITE (OU2) ECOLOGICAL RISK ASSESSMENT
FORT LAWN, SOUTH CAROLINA
ARSENIC
9.34E-04
7.86E-03
1.08E-03
1.26E+00
1.26E-01
7.4E-04
6.2E-03
8.6E-04
7.4E-03
6.2E-02
8.6E-03
COPPER
6.50E-02
4.67E-01
9.12E-02
1.17E+02
1.17E+01
5.6E-04
4.0E-03
7.8E-04
5.6E-03
4.QE-02
7.8E-03
LEAD
2.39E-02
1.53E-01
3.73E-02
8.00E+01
8.00E+00
3.0E-04
1.9E-03
4.7E-04
3.0E-03
1.9E-02
4.7E-03
MANGANESE
1.4JE-01
5.37E-01
2.23E-01
8.80E+02
8.80E+OI
1.6E-04
6.1E-04
2.5E-04
1.6E-03
6.1E-03
2.5E-03
MERCURY
2.17E-04
1.66E-03
2.69E-04
1.32E+02
1.32E+01
1.6E-06
1.3E-05
2.0E-06
I.6E-05
1.3E-04
2.0E-05
ZINC
8.92E-02
4.23E-01
1.07E-01
1.60E+03
1.60E+02
5.6E-03
2.6E-04
6.7E-05
5.6E-04
2.6E-03
6.7E-04
ORGANICS
TETRACHLOROETHENE
2.09E-05
3.58E-05
2.19E-05
1.40E+02
1.40E+01
1.5E-07
2.6E-07
1.6E-07
1.5E-06
2.6E-06
l.GE-06
TOLUENE
2.29E-05
8.96E-05
2.48E-05
2.60E+02
2.60E+01
8.8E-08
3.4E-07
9.5E-08
8.8E-07
3.4E-06
9.3E-07
PESTICIDES/PCBs
PCBs
1.75E-04
1.93E4J2
l.OOE+01
l.OOE+00
1.8E-05
1.9E-03
1.1E-04
1.8E-04
1.9E-02
1.1E-03
^Hazard quotients derived fiom LOAEL TRVs
•Hazard quotients derived from NOAEL TRVs
EPC - Exposure Point Concentrations
TRV • Toxicity Reference Values
HQ - Hazard Quotient
30
-------
Record of Decision
Carolawn (OU2) Superfund Site
Page 31
8.0 DOCUMENTATION OF SIGNIFICANT CHANGES
The selected remedy as presented in this decision document has no
difference, significant or otherwise, from the preferred
alternative presented in the proposed plan. In addition, the State
of South Carolina concurs with this remedy. South Carolina's
letter of concurrence is provided in Appendix C to this ROD.
-------
APPENDIX A - ANALYTICAL DATA SUMMARIES
-------
Soil Analytical Data Summary
Carolawn
Ft. Lawn, South Carolina
INORGANIC ELEMENTS
ARSENIC
BARIUM
BERYLLIUM
CADMIUM
COBALT
CHROMIUM
COPPER
NICKEL
LEAD
VANADIUM
ZINC
MERCURY
ALUMINUM
MANGANESE
CALCIUM
MAGNESIUM
IRON
SODIUM
POTASSIUM
1-SLA
04/25/94
MG /KG
200
15
62
43
8.3
43
51
37 J
7900
760
1800
2000
18000
120
520
1-SLB
04/25/94
MG/KG
1.2J
90
23
38
9.3
9.3
100
13000
650
1100
33000
230
2-SLA
04/25/94
MG/KG
3.7
86
0.50J
21
83
130
8.5J
70
77
0.53
9400
600
1100
960
22000
400
3-SLA
3-SLB
04/25/94 04/25/94
MG/KG
4.1
64
0.44J
22
39
8.4
14
110
16000
490
870
1200
30000
570
MG/KG
1J
420
2.5JN
25
40
46
130
58J
29000
250
2600
15000
42000
6000
4-SLA
04/25/94
MG/KG
3
1200
0.75J
17
380
410
21
310
63
130J
0.98
12000
260
2600
3100
25000
550
5-SLA
04/25/94
MG/KG
400
0.45J
0.97J
10
170
230
22
220
50
72J
1.0
12000
210
2200
2700
19000
780
5-SLB
04/25/94
MG/KG
210
1.5
38
28
53
39
6.7
73
43J
16000
250
4700
7600
27000
1600
6-SLA
04/26/94
MG/KG,
3
290
0.75J
17
210
280
35
430
67
74J
1.7
15000
550
2600
3000
23000
880
7-SLA
04/26/94
MG/KG
1.7J
190
0.74J
13
220
230
14
350
53
120J
0.70
14000
180
3300
3800
20000
980
"FOOTNOTES***
J - ESTIMATED VALUE
-- - MATERIAL WAS ANALYZED FOR BUT NOT DETECTED
Appendix A -1
-------
Soil Analytical Data Summary (cont)
Carolawn
Ft. Lawn, South Carolina
PURGEABLE pRGANIC COMPOUNDS
TRICHLOROETHENE(TRICHLOROETHYLENE)
TETRACHLOROETHENE(TETRACHLOROETHYLENE)
TOLUENE
1-SLA
04/25/94
UG/KG
1-SLB
04/25/94
UG/KG
2-SLA
04/25/94
UG/KG
3-SLA
04/25/94
UG/KG
3-SLB
04/25/94
UG/KG
4-SLA
04/25/94
UG/KG
7J
5-SLA
04/25/94
UG/KG
5-SLB
04/25/94
UG/KG
6-SLA
04/26/94
UG/KG
7-SLA
04/26/94
UG/KG
27J
8J
25J
PESTICIDE/PCB COMPOUNDS
4,4'-DDT (P,P'-DDT)
4,4'-DDE (P,P'-DDE)
PCB-1254 (AROCLOR 1254)
PCB-1248 (AROCLOR 1248)
PCB-1260 (AROCLOR 1260)
UG/KG UG/KG UG/KG UG/KG UG/KG UG/KG UG/KG UG/KG UG/KG UG/KG
5400C
440
700C
13
28
2900C 440
48
320
•"FOOTNOTES***
J - ESTIMATED VALUE
-- - MATERIAL WAS ANALYZED FOR BUT NOT DETECTED
C - CONFIRMED BY GC/MS
Appendix A -2
-------
Soil Analytical Data Summary (cont)
Carolawn
Ft. Lawn, South Carolina
1-SLA 1-SLB 2-SLA 3-SLA 3-SLB 4-SLA 5-SLA 5-SLB
04/25/94 04/25/94 04/25/94 04/25/94 04/25/94 04/25/94 04/25/94 04/25/94
EXTRACTABLE ORGANIC COMPOUNDS
4-NITROANILINE
FLUORANTHENE
PYRENE
CHRYSENE
(3-AND/OR 4-1METHYLPHENOL
PHENOXYBIPHENYL (2 ISOMERS)
HEXACHLOROBIPHENYL (2 ISOMERS)
. (DIETHYLAMINO)PHENYLMETHANONE
AMINOANTHRACENEDIONE
DECAHYDROTRIMETHYLMETHYLENEMETHANO
AZULENE
HEXAHYDROHYDROXYTRIMETHYL(METHYLETHYL)
PHENANTHRENONE (2 ISOMERS)
CEDROL
YLANGENE
THUJOPSENE
QUATERPrfENYL
METHYLBENZOIC ACID
OXYBISBENZENE
CHLOROBIPHENYLOL
PHENOXYBIPHENYL
QUATERPHENYL (3 ISOMERS)
5 UNIDENTIFIED COMPOUNDS
9 UNIDENTIFIED COMPOUNDS
11 UNIDENTIFIED COMPOUNDS
13 UNIDENTIFIED COMPOUNDS
15 UNIDENTIFIED COMPOUNDS
17 UNIDENTIFIED COMPOUNDS
PETROLEUM PRODUCT
UG/KG
190J
92J
110J
180J
900JN
700JN
500JN
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
6-SLA
04/26/94
UG/KG
300J
7-SLA
04/26/94
UG/KG
80JN
2000JN
1000J
1000JN
400JN
500JN
300JN
700JN
8000J
2000JN
10000J
4000JN
2000JN
400JN
200000J
700JN
600JN
600JN
600JN
20000J
20000J
70000J
8000J
100000JN
800000J
•••FOOTNOTES***
J - ESTIMATED VALUE
N - PRESUMPTIVE EVIDENCE OF PRESENCE OF MATERIAL
-- - MATERIAL WAS ANALYZED FOR BUT NOT DETECTED
Appendix A -3
-------
Soil Analytical Data Summary (cont)
Carolawn
Ft. Lawn, South Carolina
INORGANIC ELEMENTS
SILVER
ARSENIC
BARIUM
BERYLLIUM
COBALT
CHROMIUM
COPPER
NICKEL
LEAD
VANADIUM
ZINC
MERCURY
ALUMINUM
MANGANESE
CALCIUM
MAGNESIUM
IRON
SODIUM
POTASSIUM
8 -SLA
04/26/94
MG/KG
._
2.2
110
0.84J
13
54
93
17
91
65
50J
0.76
15000
230
2800
4000
20000
--
820
9-SLA
04/26/94
MG/KG
..
--
94
0.51J
12
32
39
6.6
52
59
--
--
10000
610
1100
1700
18000
--
720
10-SLA
04/26/94
MG/KG
__
--
160
0.92J
21
33
--
36
6.7
69
--
--
15000
340
3600
8300
23000
--
3000
11-SLA
04/26/94
MG/KG
._
4.3
88
0.74J
7.7J
33
47
9.5J
59
58
--
--
15000
210
1700
4600
20000
--
1600
11-SLB
04/26/94
MG/KG
_.
4.3
140
--
10
9.3
33
9.3
11J
69
37
--
23000
190
1400
6700
25000
--
3000
12-SLA
04/26/94
MG/KG
..
--
220
0.88J
20
47
60
29
92 J
72
47
0.73
18000
430
5400
8700
25000
--
4200
13-SLA
04/26/94
MG/KG
._
3.5
77
0.80J
18
69
75
26
89J
75
38
--
14000
550
2900
5000
24000
--
530
13-SLB
04/26/94
MG/KG
..
--
170
0.89J
12
41
39
45
2.9J
63
43
--
19000
160
5300
13000
24000
--
360
14-SLA
04/26/94
MG/KG
__
3.4
77
0.42J
22
75
71
8.5
120J
72
36
0.59
13000
690
870
900
24000
--
360
15-SLA
04/26/94
MG/KG
..
2.4
51
0.35J
10
38
..
6.2
70J
42
--
0.32
8300
160
1700
1400
13000
--
540
15-SLB
04/26/94
MG/KG
2.8JN
1.6J
52
0.71J
9.5
40
..
12
33J
140
--
--
31000
160
--
1600
50000
160
1000
•"FOOTNOTES***
J - ESTIMATED VALUE
-- - MATERIAL WAS ANALYZED FOR BUT NOT DETECTED
Appendix A -4
-------
PURGEABLE ORGANIC COMPOUNDS
TETRACHLOROETHENE(TETRACHLOROETHYLENE)
PESTICIDE/PCB COMPOUNDS .
PCB-1254 (AROCLOR 1254)
Soil Analytical Data Summary (cont)
Carolawn
Ft. Lawn, South Carolina
8-SLA • 9-SLA 10-SLA 11-SLA 11-SLB 12-SLA 13-SLA 13-SLB 14-SLA 15-SLA 15-SLB
04/26/94 04/26/94 04/26/94 04/26/94 04/26/94 04/26/94 04/26/94 04/26/94 04/26/94 04/26/94 04/26/94
UG/KG UG/KG UG/KG UG/KG UG/KG UG/KG UG/KG UG/KG UG/KG UG/KG UG/KG
10J
UG/KG UG/KG UG/KG UG/KG UG/-KG UG/KG UG/KG UG/KG UG/KG UG/KG UG/KG
480 -- -- 77 -- -- -- -- 75 28J
•"FOOTNOTES***
J - ESTIMATED VALUE
-- - MATERIAL WAS ANALYZED FOR BUT NOT DETECTED
Appendix A -5
-------
Soil Analytical Data Summary (cont)
Carolawn
Ft. Lawn, South Carolina
8-SLA 9-SLA 10-SLA 11-SLA 11-SLB 12-SLA 13-SLA 13-SLB 14-SLA 15-SLA 15-SLB
04/26/94 04/26/94 04/26/94 04/26/94 04/26/94 04/26/94 04/26/94 04/26/94 04/26/94 04/26/94 04/26/94
EXTRACTABLE ORGANIC COMPOUNDS UG/KG UG/KG UG/KG UG/KG UG/KG UG/KG UG/KG UG/KG UG/KG UG/KG UG/KG
BISI2-ETHYLHEXYL) PHTHALATE -- -- -- -- -- -- -- -- -- 790J
METHYLIDYNEBENZENE - 300JN
QUATERPHENYL (3 ISOMERS) 1000JN
PHENYLTERPHENYL ' 300JN
DECAHYDROTRIMETHYLMETHANOAZULENE -- 800JN
HEXAHYDROHYDROXYTRIHETHYL(METHYLETHYL)
PHENANTHRENOL (2 ISOMERS) -- -- 900JN
HEXAHYDROHYDROXYTRIMETHYL(HETHYLETHYL)
PHENANTHRENONE . ' -- 300JN 100JN
METHYLHEXADIENE -- -- -- 300JN
PENTADECANOIC ACID -- -- --. 300JN
PHENANTHRENOL (2 ISOMERS) -- -- -- 400JN
METHYLBENZENESULFONAMIDE -- -- -- -- -- ' 300JN -- -- -- -- --.
DICHLORONITROANILINE -- -- -- -- -- -- 70JN
DIISOCYANATOMETHYLBENZENE -- -- -- -- -- -- -- -- 200JN
DECAHYDROTRIMETHYLMETHYLENEMETHANO -- -- -- ' — -- -- -- -- --- --
AZULENE -- -- -- -- -- -- -- -- 500JN
COPAENE - -- -- -- -- -- -- -- -- 200JN
CHLORO(PHENYLEMETHYL)PHENOL -- -- -- -- -- -- -- -- 200JN
OCTAHYDROTRIMETHYL(METHYLETHYL)
PHENANTHRENOL -- -- -- -- -- -- -- -- 1000JN
CHLORO(PHENYLMETHYL)PHENOL -- — -- -- -- -- -- -- -- 70JN
OCTAHYDROTRIMETHYL (METHYLETHYL) PHENANTHRENOL -- 2000JN -- -- -- -- -- -- -- 200JN
AMINOANTHRACENEDIONE -- 800JN -- -- -- -- 200JN -- -- 100JN
HEXADECANOIC ACID -- -- 80JN -- -- -- -- -- -- 200JN 300JN
1 UNIDENTIFIED COMPOUND -- 2000J -- -- -- -- 4000 -- -- -- 1000J
2 UNIDENTIFIED COMPOUNDS -- -- -- -- -- -- -- -- -- 1000J
4 UNIDENTIFIED COMPOUNDS -- -- -- 2000J -- 6000J
5 UNIDENTIFIED COMPOUNDS -- -- -- -- -- -- -- -- 3000J
8 UNIDENTIFIED COMPOUNDS SOOOJ
PETROLEUM PRODUCT N
**FOOTNOTES***
J - ESTIMATED VALUE
N - PRESUMPTIVE EVIDENCE OF PRESENCE OF MATERIAL
-- - MATERIAL WAS ANALYZED.FOR BUT NOT DETECTED
Appendix A -6
-------
Soil Analytical Data Summary (cent)
Carolawn
Ft. Lawn, South Carolina
16-SLA 17-SLA 18-SLA 19-SLA 20-SLA 21-SLA 22-SLA 23-SLA 24-SLA 25-SLA
04/26/94 04/26/94 04/26/94 04/27/94 04/27/94 04/27/94 04/26/94 04/26/94 04/26/94 04/26/94
INORGANIC ELEMENTS MG/KG MG/KG MG/KG MG/KG MG/KG MG/KG MG/KG HG/KG MG/KG MG/KG
ARSENIC 1.9J -- -- 1.7J -- -- 3.6 2.2J 1.8J 1.9J
BARIUM 43 43J 37J S2J 50J 31J 120 89 38 55
BERYLLIUM 0.42J . -- . 0.49J 0.58J 0.80J 0.48J -- 0.46J 0.69J 0.45J
COBALT 5.8 10 6.7 7.7 8.2 9.6 24 15 13 23
CHROMIUM 28 21 12 . 40 28 15 28 79 34 58
COPPER 40 -- -- -- -- -- -- 81
NICKEL 3.8 9.5 13 12 8.7 6.8 12 3.9 4.1 4.7J
LEAD ' 45J 7.7 6.3 73 9.8 4.8 17 69J 13J 18J
VANADIUM 59 32 22 60 63 29 65 39 48 63
ZINC -- -- -- 24
ALUMINUM 11000 7400 6300 14000 14000 9700 14000 7800 9500 13000
MANGANESE ' 100 130 130 120 89 ' 70 1100 740 360 500
CALCIUM • -- 850J 830J -- -- -- 1900 1100
MAGNESIUM • 1100 2000J 2300J 2400J 2500J 1600J 3300 640 480 590
IRON 20000 13000 8700 24000 24000 11000 21000 12000 16000 23000
POTASSIUM 450 630 300 840 1200 600 1300 320 280 380
*•*FOOTNOTES***
J - ESTIMATED VALUE
-- - MATERIAL WAS ANALYZED FOR BUT NOT DETECTED
Appendix A -7
-------
Soil Analytical Data Summary (cont)
Carolawn
Ft. Lawn, South Carolina
16-SLA 17-SLA 18-SLA 19-SLA 20-SLA
04/26/94 04/26/94 04/26/94 04/27/94 04/27/94
PURGEABLE ORGANIC COMPOUNDS
TOLUENE
UG/KG
5J
UG/KG
UG/KG
12
UG/KG
UG/KG
21-SLA
04/27/94
UG/KG
22-SLA 23-SLA 24-SLA 25-SLA
04/26/94 04/26/94 04/26/94 04/26/94
UG/KG
UG/KG
UG/KG
9J
UG/KG
PESTICIDE/PCB COMPOUNDS
NONE DETECTED
**'FOOTNOTES***
J
- ESTIMATED VALUE
- MATERIAL WAS ANALYZED FOR BUT NOT DETECTED
Appendix A -8
-------
Soil Analytical Data Summary (cont)
Carolawn
Ft. Lawn, South Carolina
EXTRACTABLE ORGANIC COMPOUNDS
DIISOCYANATOMETHYLBENZENE
DECAHYDROTRIMETHYLMETHANOAZULENE
(DIMETHYLETHYL)METHYLPHENOL
(HYDROXYPHENYL)ETHANONE
DECAHYDROTRIMETHYLMETHYLENE
METHANOAZULENE
(HYDROXYMETHYL)ETHANONE
PHENANTHRENOL
HEXAHYDROHYDRODXYTRIMETHYL(METHYLETHYL)
DECAHYDROTRIMETHYLMETHYLENEMETHANO
AZULENE
COPAENE
HEXADECANOIC ACID
OCTAHYDROTRIMETHYL(METHYLETHYL)PHENANTHRENE
OCTAHYDROTRIMETHYL(METHYLETHYL)PHENANTHRENOL
(2 ISOMERS)
DECAHYDROTRIMETHYLHETHYLENEMETHANOAZULENE
THUJOPSENE
. OCTADECANOIC ACID
OCTAHYDROTRIMETHYL(METHYLETHYL)
PHENANTHRENOL (2 ISOMERS)
METHYL(TRIMETHYLCYCLOPENTYL)BENZENE
OCTAHYDRODIMETHYL(METHYLETHYL)PHENANTHRENE
CARBOXYLIC ACID, METHYLESTER
HEXAHYDROHYDROXYTRIMETHYL(METHYLETHYL)
PHENANTHRENONE
2 UNIDENTIFIED COMPOUNDS
3 UNIDENTIFIED COMPOUNDS
4 UNIDENTIFIED COMPOUNDS
5 UNIDENTIFIED COMPOUNDS
6 UNIDENTIFIED COMPOUNDS
9 UNIDENTIFIED COMPOUNDS
11 UNIDENTIFIED COMPOUNDS
16-SLA
04/26/94
UG/KG
200JN
17-SLA
04/26/94
UG/KG
3000JN
5000JN
18-SLA
04/26/94
UG/KG
200JN
19-SLA
04/27/94
UG/KG
1000JN
1000JN
20-SLA
04/27/94
UG/KG
21-SLA
04/27/94
UG/KG
22-SLA
04/26/94
UG/KG
100JN
100JN
1QOJN
400JN
200JN
23-SLA
04/26/94
UG/KG
24-SLA
04/26/94
UG/KG
1000JN
300JN
300JN
200 JN
400JN
1000JN
900JN
200 JN
200JN
100JN
2000JN
10000J
300JN
700JN
3000J
2000J
8000J
3000JN; 3000JN
300JN
7000J
10000J
1000J
300JN
5000J
200JN
1000J
2S-SLA
04/26/94
UG/KG
700JN
300JN
300JN
5000JN
300JN
400JN
300JN
5000J
* "FOOTNOTES***
J - ESTIMATED VALUE
N - PRESUMPTIVE EVIDENCE OF PRESENCE OF MATERIAL
-- - MATERIAL WAS ANALYZED FOR BUT NOT DETECTED
Appendix A -9
-------
Soil Analytical Data Summary (cont)
Carolawn
Ft. Lawn, South Carolina
INORGANIC ELEMENTS
ARSENIC
BARIUM
BERYLLIUM
COBALT;
CHROMIUM
COPPER
NICKEL
LEAD
VANADIUM
ZINC
ALUMINUM
MANGANESE
CALCIUM
MAGNESIUM
IRON
POTASSIUM
26-SLA
04/27/94
MG/KG
2.6
53J
0.77J
8.1
25
--
7.3
20
69
--
16000
82
940J
1600J
25000
790
26-SLB
04/27/94
MG/KG
4
200J
4. UN
28
16
-- •
18
--
110
65
16000
300
5600J
9200J
41000
5200
27-SLA
04/27/94
MG/KG
--
40J
0.41J
3.5
16
--
4.8
14
45
--
14000
56
--
920J
17000
710
28-SLA
04/27/94
MG/KG
2J
24J
0.44J
2.1
13
17
3.6
6.5
41
--
9000
18
--
370J
14000
240
29-SLA
04/26/94
MG/KG
.-
35
0.38J
8
21
--
--
9.8J
44
9.6
7600
210
--
620
14000
310
30-SLA
04/27/94
MG/KG
2.8
66J
1.2
B.6
21
--
8.3
15
100
--
23000
84
--
1700J
35000
940
31-SLA
04/27/94
MG/KG
1.9J
50J
0.61J
3.7
17
--
4.7
12
44
--
10000
64
370J
480J
17000
410
32-SLA
04/27/94
MG/KG
2J
36J
0.48J
2.9
14
--
2.4J
13
53
15
10000
30
--
420J
18000
240
33-SLA
04/27/94
MG/KG
2.5
54J
0.62J
5.2
28
--
6.6
11
97
--
20000
70
--
1400J
35000
820
33-SLB
04/27/94
MG/KG
._
100J
U
14
93
--
56
6.7
73
53
25000
140
--
11000J
34000
1500
"FOOTNOTES***
J - ESTIMATED VALUE
-- - MATERIAL WAS ANALYZED FOR BUT NOT DETECTED
Appendix A -10
-------
Soil Analytical Data Summary (cont)
Carolawn
Ft. Lawn, South Carolina
EXTRACTABLE ORGANIC COMPOUNDS
OCTADECANOIC ACID
OCTAHYDRODIMETHYL(METHYLTHYL)PHENANTHRENE
CARBOXYLIC ACID, METHYLESTER
OCTAHYDRODIMETHYL(METHYLETHYL)
PHENANTHRENECARBOXYLIC ACID, METHYLESTER
OCTAHYDROTRIMETHYL(METHYLETHYL)PH^NANTHRENOL
(2 ISOMERS)
OCTAHYDROMETHYLMETHYLENE(METHYLETHYL)
METHANOINDENE
DECAHYDROTRIMETYULHYLMETHYLENEMETHANOAZULENE
OCTAHYDRODIMETHYL(METHYLETHYL)PHENANTHRENE
CARBOXYLIC ACID, METHYELESTER
YLANGENE
OCTAHYDROTETRAMETHYLCYCLOPROPANAPHTHALENONE
CEDROL
THUJOPSENE
METHYL(TRIMETHYLCYCLOPENTYL)BENZENE
HEXAHYDROTRIMETHYL(METHYLETHYL)
PHENANTHRENONE
PHENANTHRENOL
DECAHYDROTRIMETHYLMETHANOAZULENE
HEXADECANOIC ACID
OCTADECENOIC ACID
OCTAHYDROTRIMETHYL(METHYLETHYL)
PHENANTHRENOL (2 ISOMERS)
OCTAHYDRODIMETHYL9METHYLETHYL)PHENANTHRENE
CARBOXYLIC ACID, METHYLESTER (2 ISOMERS)
1 UNIDENTIFIED COMPOUND
2 UNIDENTIFIED COMPOUNDS
3 UNIDENTIFIED COMPOUNDS
4 UNIDENTIFIED COMPOUNDS
7 UNIDENTIFIED COMPOUNDS
9 UNIDENTIFIED COMPOUNDS
12 UNIDENTIFIED COMPOUNDS
26-SLA
04/27/94
UG/KG
26-SLB
04/27/94
UG/KG
300JN
300JN
27-SLA
04/27/94
UG/KG
300JN
28-SLA
04/27/94
UG/KG
29-SLA
04/26/94
UG/KG
30-SLA
04/27/94
UG/KG
4000JN
400JN
4000JN
900JN
400JN
600JN
3000JN
1000JN
900JN
800JN
700JN
200JN
300JN
200JN
200JN
3000JN
500JN
2000J
4000J
3000JN
6000J
6000JN
3000JN
31-SLA
04/27/94
UG/KG
32-SLA
04/27/94
UG/KG
33-SLA
04/27/94
UG/KG
33-SLB
04/27/94
UG/KG
400JN
400 JN
500JN
400JN
7000JN
1000JN
200JN
2000J
10000J
7000J
900JN
600JN
800JN
4000JN
1000JN
4000J
** FOOTNOTES***
J - ESTIMATED VALUE
N - PRESUMPTIVE EVIDENCE OF PRESENCE OF MATERIAL
-- - MATERIAL WAS ANALYZED FOR BUT NOT DETECTED
Appendix A -11
-------
Soil Analytical Data Summary (cont)
Carolawn
Ft. Lawn, South Carolina
26-SLA 26-SLB 27-SLA 28-SLA 29-SLA 30-SLA 31-SLA 32-SLA 33-SLA 33-SLB
04/27/94 04/27/94 04/27/94 04/27/94 04/26/94 04/27/94 04/27/94 04/27/94 04/27/94 04/27/94
PURGEABLE ORGANIC COMPOUNDS
TOLUENE
PESTICIDE/PCS COMPOUNDS
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
2J
UG/KG
UG/KG
UG/KG
UG/KG
NONE DETECTED
»*FOOTNOTES***
J - ESTIMATED VALUE
-- - MATERIAL WAS ANALYZED FOR BUT NOT DETECTED
Appendix A -12
-------
Soil Analytical Data Summary (cent)
Carolawn
. Ft. Lawn, South Carolina
INORGANIC ELEMENTS
ARSENIC
BARIUM
BERYLLIUM
COBALT
CHROMIUM
COPPER
NICKEL
LEAD
STRONTIUM
TITANIUM
VANADIUM
YTTRIUM
ZINC
MERCURY
ALUMINUM
MANGANESE
CALCIUM
MAGNESIUM
IRON
POTASSIUM
SODIUM
34-SLA
04/27/94
MG/KG
2.6
52J
--
13
14
--
2J.
15
NA
NA
46
--
--
--
9300 •
120
--
510J
17000
400
--
3 5- SLA
04/27/94
MG/KG
-_
40J
0.5SJ
4.9
62
--
--
9.7
NA
NA
47
--
--
--
7800
66
--
--
20000
250
35-SLB
04/27/94
MG/KG
-.
36J
--
3.2
15
20
3.5
8
NA
NA
72
--
--
--
25000
40
...
1100J
29000
830
--
36-SLA
04/26/94
MG/KG
1.8J
51
0.42J
8.8
32
15
3.3J
15J
NA
NA
45
--
--
--
9200
410
800
520
15000
310
--
37-SLA
04/26/94
MG/KG
5.7
72
0.51J
12
38
--
8.9
14J
NA
NA
49
--
--
--
8600
430
1900
2100
15000
780
--
38-SLA
04/26/94
MG/KG
2.3J
130
0.89J
18
34
49
26
14J
NA
NA
75
--
--
--
17000
360
3300
6500
24000
1800
--
39-SLA
04/26/94
' MG/KG
2.9
98
1.1J '
22
85
30
14
17J
NA
NA
120
--
r-
--
14000
590
1500
2600
34000
750
--
40-SLA
04/26/94
MG/KG
2.9
85
0.49J
8.9
33
--
7
9.7J
NA
NA
57
--
--
--
10000
270
1400
2500
17000
920
--
41-SLA
04/26/94
MG/KG
23
140
--
7.3
220
68
8.7
280J
NA
NA
31
--
110
10000
230
49000
26000
16000
2200
--
45-SLA
10/25/94
MG/KG
100
--
12
14
30
11
22
47
1200
76
13
38
0.32
20000
230
2900
4800
25000
2400
--
45-SLB
10/25/94
MG/KG
58
__
5.3
42
39
20
7.7
34
720
34
11
34.
0.17
14000
120
830
3000
15000
2300
200
**FOOTNOTES'**
J - ESTIMATED VALUE
-- -- MATERIAL WAS ANALYZED FOR BUT NOT DETECTED
NA - NOT ANALYZED
Appendix A -13
-------
Soil Analytical Data Summary (cone)
Carolawn
Ft. Lawn, South Carolina
34-SLA 35-SLA 35-SLB 36-SLA 37-SLA 38-SLA 39-SLA 40-SLA 41-SLA 45-SLA 45-SLB
04/27/94 04/27/94 04/27/94 04/26/94 04/26/94 04/26/94 04/26/94 04/26/94 04/26/94 10/25/94 10/25/94
EXTRACTABLE ORGANIC COMPOUNDS UG/KG UG/KG UG/KG UG/KG UG/KG UG/KG UG/KG UG/KG UG/KG UG/KG UG/KG
4-NITROANILINE -- -- -- -- -- -- -- -- 3800J
OCTAHYDRODIMETHYLfMETHYLETHYL1PHENANTHRENE
CARBOXYLIC ACID, METHYLESTER (2 ISOMERS) 600JN
DECAHYDROTRIMETHYLMETHANOAZULENE -- 500JN
METHYL(TRIMETHYLCYCLOPENTYL)BENZENE -- 100JN
HEXADECANOIC ACID -- 500JN
HEXAHYDRODIMETHYL(METHYLETHYL)
NAPHTHALENE -- -- -- 100JN
OCTAHYDROTRIMETHYL(METHYLTHYL) '-- -- --
HEXAHYDROXYTRIMETHYL (METHYLETHYL) PHENANTHRENONE -- -- -- 100JN
(DIMETHYLETHYL)PHENOL -- -- -- -- 500JN
DECAHYDROTRIMETHYLMETHYLENEMETHANOAZULENE -- -- -- •-- -- 300JN
OCTAHYDROTRIMETHYL(METHYLETHYL)
PHENANTHRENOL (2 ISOMERS) -- -- -- 700JN -- 5000JN
METHYLTRIMETHYLCYCLOPENTYLBENZENE -- -- -- -- -- -- 200JN
METHYLPHENYLANTHRACENEDIONE -- -- -- -- -- -- 1000JN --
HEXAHYDROHYDROXYTRIMETHYLMETHYLETHYL
OCTAHYDROTRIMETHYL (METHYLETHYL) PHENANTHRENOL 300JN --- -- -- -- -- 7000JN
DECAHYDROTRIMETHYLMETHYLENEMETHANO -- -- -- -- -- -- -r
AZULENE -- -- -- -- -- -- 1000JN 2000JN
CEDROL • -- -- -- -- -- -- -- 400JN
THUJOPSENE -- -- -- -- -- -- -- 300JN
METHYL(TRIMETHYLCYCLOPENTYL)METHYLBENZENE -- -- -- -- -- -- -- 300JN
OCTAHYDROTRIMETHYL(METHYLETHYL) PHENANTHRENONE
(2 ISOMERS) -- . 2000JN -- -- -- -- -- 7000JN
HEXAHYDROHYDROXYTRIMETHYL(METHYLETHYL) -- -- -- -- -- --- -- . --- -- .
PHENANTHRENONE - -- -- -- -- 1000JN 800JN 600JN
(DIMETHYLETHYL) METHYLPHENOL -- -- 300JN -- -- -- -- -- 10000JN
ANTHRACENEDIONE -- -- -- -- -- -- -- -- 6000JN
1 UNIDENTIFIED COMPOUND -- -- -- -- 1000J
2 UNIDENTIFIED COMPOUNDS -- 3000J -- 4000J -- -- -- -- -- -- .. .
S UNIDENTIFIED COMPOUNDS 8000J
6 UNIDENTIFIED COMPOUNDS -- -- 10000J
8 .UNIDENTIFIED COMPOUNDS -- -- ..... .. .. .. 5000J 700000J
"FOOTNOTES***
J - ESTIMATED VALUE
N - PRESUMPTIVE EVIDENCE OF PRESENCE OF MATERIAL
-- - MATERIAL WAS ANALYZED FOR BUT NOT DETECTED
Appendix A -14
-------
Soil Analytical Data Summary (cont)
Carolawn
Ft. Lawn, South Carolina
34-SLA 35-SLA 35-SLB 36-SLA 37-SLA 38-SLA 39-SLA •40-SLA 41-SLA 45-SLA 45-SLB
04/27/94 04/27/94 04/27/94 04/26/94 04/26/94 04/26/94 04/26/94 04/26/94 04/26/94 10/25/94 10/25/94
PURGEABLE ORGANIC COMPOUNDS UG/KG UG/KG UG/KG OG/KG UG/KG UG/KG UG/KG UG/KG UG/KG UG/KG UG/KG
TETRACHLOROETHENE(TETRACHLOROETHYLENE) 3J 5J
TOLUENE 6J 11J
PESTICIDE/PCB COMPOUNDS UG/KG UG/KG UG/KG UG/KG UG/KG UG/KG UG/KG UG/KG UG/KG UG/KG UG/KG
FCB-1254 (AROCLOR 1254) -- -- -- -- -- -- — -- 780 --
4,4'-DDE -- -- • -- -- -- -- -- -- -- 15J
*«FOOTNOTES***
J - ESTIMATED VALUE
-- - MATERIAL WAS ANALYZED FOR BUT NOT DETECTED
Appendix A -15
-------
Sediment Analytical Data Summary
Carolawn
Ft. Lawn, South Carolina
1-SD 2-SD 3-SD
04/26/94 04/26/94 04/26/94
INORGANIC ELEMENTS
ARSENIC
BARIUM
BERYLLIUM
COBALT
CHROMIUM
LEAD
VANADIUM
ZINC
ALUMINUM
MANGANESE
IRON
POTASSIUM
MG/KG
0.30J
1.4J
7.1
1.8
15
1100
270
6200
76
MG/KG
3.1
11
2.1J
13
1600
290
5100
88
MG/KG
0.91J
24
3.3
15
2.1J
18
1500
310
7800
62
4-SD
04/26/94
MG/KG
3.7
6
1.8
12
14
1100
250
5500
140
PURGEABLE ORGANIC COMPOUNDS
PESTICIDE/PCS COMPOUNDS
EXTRACTABLE ORGANIC COMPOUNDS
NONE DETECTED
NONE DETECTED
UG/KG UG/KG
UG/KG
OCTAHVDROMETHYLMETHYLENEtMETHYLETHYL) NAPHTHALENE --
OCTADECENOIC ACID
OCTADECANOIC ACID
OCTAHYDROTRIMETHYL(METHYLETHYL)PHENANTHRENOL
(2 ISOMERS)
15 UNIDENTIFIED COMPOUNDS
1 UNIDENTIFIED COMPOUND
UG/KG
600 JN
900JN
900JN
8000JN
20000J
900J
"•FOOTNOTES***
- ESTIMATED VALUE
- MATERIAL WAS ANALYZED FOR BUT NOT DETECTED
Appendix A -16
-------
Surface Water Analytical Data Summary
Carolawn
Ft. Lawn, South Carolina
1-SW 2-SW 3-SW
04/26/94 04/26/94 04/26/94
INORGANIC ELEMENTS
BARIUM
STRONTIUM
TITANIUM
•ALUMINUM
MANGANESE .
CALCIUM
MAGNESIUM
IRON
SODIUM
POTASSIUM
UG/L
33
95
7.3
350
60
MG/L
9.3
3.8
0.86
7.9
1.5
UG/L
29
86
6.2
280
52
MG/L
8.4
3.5
0.76
7.2
1.4
UG/L
32
93
6.2
260
53
MG/L
9.1
3.8
0.80
7.9
1.6
4-SW
04/26/94
UG/L
30
89
5.8
240
59
MG/L
8.6
3.6
0.69
7.6
1.5
201-SW
04/26/94
UG/L
32
93
7.4
310
59
MG/L
9.1
3.8
0.85
7.8
1.6
401-TB
04/25/94
UG/L
NA
NA
NA •
NA
NA
MG/L
NA
NA
NA
NA
NA
PURGEABLE ORGANIC COMPOUNDS
PESTICIDE/PCB COMPOUNDS
EXTRACTABLE ORGANIC COMPOUNDS
NONE DETECTED
NONE DETECTED
NONE DETECTED
*••FOOTNOTES**"
NA - NOT ANALYZED
Appendix A -17
-------
Field Parameter Data Summary
Carolawn
Ft. Lawn, South Carolina
Sample pH Specific Conductance Temperature
Number (SU) (umhos/cm@25°C) (°C)
001-SW 6.9 202 19.5
002-SW 6.3 122 20.0
003-SW 6.3 121 21.6
004-SW 6.7 121 23.8
Appendix A -18
-------
APPENDIX B - RESPONSIVENESS SUMMARY
-------
RESPONSIVENESS SUMMARY
CAROLAWN (OU2) SUPERFUND SITE
1. Overview
The U. S. Environmental Protection Agency (EPA) held a public
comment period from July 24, 1995 to August 24, 1995, for
interested parties to comment on the Remedial Investigation and the
Baseline Risk Assessment results and the Proposed Plan for the
Carolawn (OU2) Superfund Site in Fort Lawn, South Carolina. The
comment period closed on August 24, 1995.
EPA held a public meeting at 7:00 p.m. on August 10, 1995 at the
Lewisville Elementary School in Fort Lawn, South Carolina to
present the results of the Remedial Investigation and the Baseline
Risk Assessment, to present the Proposed Plan and to receive
comments from the public.
In the absence of any significant source of contamination in the
soil, surface water and sediment at the Site, the No Action
alternative was proposed by EPA to address the soil, surface water
and sediment. In addition, a groundwater remedy has been selected
under a Record of Decision for Carolawn (OU1). However, should
future monitoring of the site (e.g. Five-Year Review) indicate that
the site poses an unacceptable risk to the environment, then EPA,
in consultation with the State of South Carolina, may initiate
clean-up actions under the authority of CERCLA and in accordance
with the National Oil and Hazardous substances Pollution
Contingency Plan. Judging from the comments received during the
public comment period, the residents and local officials in the
Fort Lawn, South Carolina area support the cleanup alternative
proposed by EPA.
The Responsiveness Summary provides a summary of citizens' comments
and concerns identified and received during the public comment
period, and EPA's response to those comments and concerns. These
sections and attachments follow:
• Background of Community Involvement
• Summary of Comments Received During the Public
Comment Period and EPA's Responses
• Attachment A: Proposed Plan for the Carolawn (OU2)
Superfund Site
• Attachment B: Public Notices of Public Comment Period
-------
• Attachment C: Written Public Comments Received During
the Public Comment Period
• Attachment D: Official Transcript of the Proposed Plan
Public Meeting
2. Background of Community Involvement
EPA's community relations program for the Site began in 1987, when
EPA conducted community interviews in order to develop a community
relations plan for the Site. At that time, residents living
adjacent to the Site were concerned about the Site and about any
health risks from the Site. In addition, residents did voice some
concerns about lack of information to the public during the removal
work at the Site and lack of response to earlier complaints about
the Site.
Throughout EPA's involvement, the community has been kept aware and
informed of Site activities and findings. Discussions have taken
place during visits to the area by the Remedial Project Manager
(RPM) and the Community Relations Coordinator (CRC). Concern
citizens and Local officials were briefed prior to the Proposed
Plan Public Meeting held on August 10, 1995 . The Site mailing list
was expanded to include additional residents living in close
proximity to the Site.
3. Summary of Comments Received During the Public Comment
Period and Agency Responses
The Public Comment Period was opened on July 24, 1995 and was ended
on August 24, 1995. Public Notices which were published in local
papers can be found in Attachment B.
On August 10, 1995, EPA held a public meeting to present the
Proposed Plan to the community and to receive comments thereupon.
All comments received at this public meeting and during the public
comment period are summarized below.
Summary and Response to Local Community Concerns
The following issues and concerns were expressed at the Proposed
Plan Public Meeting, and during the public comment period.
COMMENT: Several citizens expressed a concern that the Remedial
Investigation did not encompass the entire parcel of property of 60
acres and would like an additional investigation to take place on
the adjacent acreage. Moreover, several citizens are apprehensive
about the existence of buried drums and feel that an additional
investigation would alleviate their concerns.
-------
RESPONSE: Previous studies suggested that there were numerous
sources of contamination at the Site. Based on those studies,
several remedial actions have been performed to remove contaminated
soils, drums (some buried) and liquid waste from the Site. While
those levels of contamination were greatly reduced, several
Remedial Investigations were warranted to fully delineate all
contamination of known areas and to characterize the Site. Based on
the information obtained from the operational history of the
facility and the earlier investigations, including this Remedial
Investigation, EPA has characterized the Site and the nature of its
contaminants at all known areas of contamination. However, if
further information (i.e. , via the Citizen Advisory Group) suggests
additional sources of contamination exist, EPA will investigate the
area of concern to confirm the nature and extent of contamination
on any of the remaining acreage.
COMMENT: An attendee requested EPA to appoint a committee from the
community to participate with the agency in future efforts and
decisions for the Site.
RESPONSE: Based on citizen interest at the meeting, EPA will pursue
the establishment of a Citizen Advisory Group for the Carolawn
Site. Once this group is established, the Citizen Advisory Group
will participate with EPA in future efforts and decisions for the
Site. In addition, formation of the Citizens Advisory Group will
increase dissemination of information and provide viable feedback
from the community for on-going implementation issues as well as
determining the need for additional investigation on the remaining
acreage.
COMMENT: An attendee expressed a concern that the Carolawn Site was
cited as one of 114 sites in the United States that most needed
cleaning up.
RESPONSE: Upon completion of operational practices which occurred
during the 1970's, the Carolawn property was an area covered with
two incinerators, several storage tanks, two storage trailers and
many drums (both inside and outside the 3-acre fenced area). During
the early 1980's, SCDHEC and EPA conducted several site
investigations at the Carolawn Site. The results of these
investigations showed the presence of trichlorethane (TCE) and
other solvents in nearby residential wells. The results also
indicated that the Site was contaminated with high levels of metals
and organic compounds.
During the late 1970's and early 1980's, the Site could have been
perceived as one of the worst sites in the United States. However,
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.
The cleanup activities continued through February 1982, and
included removal of contaminated soils, drums (some buried), and
-------
liquid wastes from the Site. Due to "each of the response actions
that have occurred at the Site, the levels of contamination have
been greatly reduced.
Currently, the Site does not pose an imminent threat to public
health and/or the environment. However, the Site does pose a long-
term threat to the public health through exposure to the ground-
water. A remedy has been selected for groundwater remediation at
the Site and is expected to be implemented in the near future.
COMMENT: An attendee inquired about whether or not there is
additional funding to support any further testing of the other 60
acres of the Site.
RESPONSE: In response, EPA stated that the Agency's current status
for funding is questionable. Based on budget cuts and the
occurrence of a Recision Bill that was passed this year to
basically pull back funds allocated for 1995, Region IV has shut
down some starts of some sites in other states that were ready to
implement cleanup activities. As far as we know, EPA has funds for
next year. However, the Agency does not know how long the Superfund
program will have funds. Like other Federal agencies, funding for
EPA has to be appropriated each year. Unfortunately, the Superfund
Law does not expire, but the part of the Law that collects the tax
that generates the money to fund the program does expire. Thus, the
program could go on if there is funding in the trust fund to
continue on. At this time, the agency is not sure about
reauthorization or when the Superfund Law will be reauthorized.
Therefore, it is hard to commit to saying there will be funding for
the kinds of investigations we would have to do. Currently, EPA
will have to start prioritizing everything to the worst-case-first
scenario. That being the case, further investigation of this Site
might not break out as a worst-case-scenario if there are limited
funds. EPA will try to obtain additional funds and continue to go
forward and maybe even do some things in-house of a limited nature
with the existing resources in-house. If the Agency has solid
leads, we could also work through SCDHEC to try.to pursue things
that way. At this point, it is an unanswerable question but, there
are options available. We think the Agency will have funds, and we
think that if there is a' legitimate need, the Agency will go
forward and investigate those things.
4
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Attachment A
Proposed Plan for the Carolawn (OU2) Superfund Site
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SUPERFUND PROPOSED PLAN FACT SHEET
Carolawn Superfund Site-Operable Unit Two
Fort Lawn, Chester County, South Carolina
U.S. Environmental Protection Agency, Region IV, Atlanta, GA
July 1995
This fact sheet is one in a series designed to inform
residents and local officials of the ongoing cleanup efforts
at the Site. A number of terms specific to the Superfund
process (printed in bold print) are defined in the glossary
which begins on Page 12.
INTRODUCTION
The United States Environmental Protection Agency (EPA)
presents this Proposed Plan for no further action for the
Carolawn (OU2) Superfund Site ("the Site"), located in Fort
Lawn, Chester County, South Carolina. Contaminant levels
have been substantially reduced through implementation of
soil and source area cleanup activities conducted through a
Removal Action which occurred December 1981 through
February 1982. In addition, a groundwater remedy has
been selected for Carolawn (OU1). Studies to date indicate
that there is minimal contamination remaining at the Site.
Therefore, EPA is proposing that no further action is
necessary at this Site to provide protection of human health
or the environment. This Proposed Plan identifies the
reasoning for no further action and explains the rationale
for this preference.
The EPA's decision for no further action represents a
preliminary decision, subject to public review and comment
under Section 117(a) of the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA,
known as Superfund), as amended by the Superfund
Amendment and Reauthorization Act (SARA) of 1986.
This Proposed Plan is being distributed to the public in
order to solicit public input
EPA is initiating a thirty (30) day public comment period
from July 24, 1995 to August 24, 1995, to receive
comments on this Proposed Plan, the Remedial
Investigation (RI) Report and the Baseline Risk
Assessment (BRA) Report However, EPA will
accommodate requests for informal briefings during the
week of the Proposed Plan meeting. EPA, in consultation
with the South Carolina Department of Health and
Environmental Control (SCDHEC), will select a remedy for
the Site only after the public comment period has ended
and all information submitted to EPA during that time has
been reviewed and considered. As outlined in section
117(a) of CERCLA, EPA encourages public participation
by publishing Proposed Plans for addressing contamination
at Superfund sites, and by providing an opportunity for the
public to comment on the proposed remedial actions.
Changes to the preferred alternative, or a change from the
preferred alternative to another, may be made if public
comments or additional data indicate that such a change
would result in a more appropriate solution. The final
decision regarding the selected remedy will be documented
in a Record of Decision (ROD) after EPA has taken into
consideration all comments from the public. Upon timely
request, EPA will extend the public comment period by 30
additional days.
This fact sheet summarizes information that is explained in
greater detail in the Remedial Investigation Report dated
July 1995 and the Baseline Risk Assessment Report dated
July 1995. These documents and all other records utilized
by EPA to make the proposal specified in this document are
Public Comment Period:
Monday, July 24,1995
- Thursday, August 24,1995
Public Meeting
Date: Thursday, August 10,1995
Time: 7:00 PM.
Place: Lemsville High School
Highway 9
Richburg, SC
Provide written comments or call:
Yvonne Jones or Cynthia Peurifoy
US Environmental Protection Agency
North Superfund Remedial Branch
345 Courtland St, NE
Atlanta, Georgia 30365
1-800-435-9233
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contained in the administrative record for this Site. EPA
and SCDHEC encourage the public to review this
information, especially during the public comment period,
to better understand the Site, the Superfund process, and the
intent of this Proposed Plan. The administrative record is
available for public review during normal working hours,
locally at the site information repository, which is the
Lancaster County Library, the Chester County Library or in
the Record Center at EPA, Region IV's office in Atlanta,
Georgia (see page 11).
THIS PROPOSED PLAN:
1. Includes a brief history of the Site, the principle
findings of the RI and a summary of the Baseline
Risk Assessment;
2. Presents EPA's rationale for its preliminary
selection of the preferred alternative; and
3. Explains the opportunities for the public to
comment on the alternative for the Carolawn
(OU2) Superfund Site.
SITE DESCRIPTION AND HISTORY
The Carolawn Site, located on approximately 60-acres of
land, is an abandoned, waste storage and disposal facility
located in Fort Lawn, Chester County, South Carolina. The
site is situated less man three miles west of Fort Lawn, and
approximately one-half mile south of South Carolina
Highway 9 (see Figure 1.1). Rural and agricultural areas
surround much of the site. The Lancaster & Chester
Railroad and County Road 841 border the site to the south
and Fishing Creek borders the site to the east. Wooded
areas and cultivated fields lie to the west and north of the
site.
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. However, neither an incineration permit nor a
storage/disposal permit was issued to SEPCO by the
SCDHEC.
In January 1975, Columbia Organic Chemical Company
(COCC) was contracted to clean up die SEPCO Plant inj
Clover, South Carolina. As part of this clean up effort,
COCC transported and stored the waste of approximately
2,000 drums at the Carolawn Site. As payment for services
rendered during the cleanup of the plant in Clover, South
Carolina, COCC received the Carolawn property.
After 1975, South Carolina Recycling and Disposal, Inc.
(SCRDI), a subsidiary of COCC, controlled the site.
During 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. After the disposal, SCRDI sold the 3-acre fenced
area of the site to the Carolawn Company.
In 1978, 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;
however, full scale incineration never developed. At the
time of abandonment of the site by the Carolawn Company,
the 3-acre 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. AIM
additional 660 drums and 11 storage tanks were locate!
outside the fenced area to the north. In 1979, SCRDI was
notified by SCDHEC that they would have to clean up the
Carolawn site.
During the early 1980's, SCDHEC and EPA conducted site
investigations at the Carolawn site. These investigations .
included collecting environmental and private residential
well samples for analysis. The results of these
investigations showed the presence of trichloroethane (TCE)
and other solvents in nearby residential wells. The results
also indicated that the Site was contaminated with high
levels of metals and organic compounds. 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. The cleanup activities continued
through February 1982, and included removal of
contaminated soils, drums, and liquid waste from the site.
Subsequently, hi December 1982, the Site was proposed for
inclusion on the National Priorities List (NPL). The
Carolawn Site was finalized on the NPL in September,
1983. Since continued sampling of local residential wells
showed persistently high levels of TCE, the Chester
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Municipal Sewer District's water main from Highway 9 was
extended to four of the five residences living near the site.
These four residents were connected to this alternative
water supply in 1985.
Due to the complexity of the Carolawn Site, and in order to
simplify the investigation and response activities, EPA
divided the Site into two discrete study areas known as
Operable Units (Figure 2). Operable Unit One (OU1)
consists of source areas located on a 3-acre parcel within
the fenced area of the site and the groundwater located
beneath the entire Site (to include the groundwater beneath
OU2). Operable Unit Two (OU2) consists of the land
located immediately around the fenced area and the land
located north and west of the fenced area (north and west
drum areas).
On August 29, 1985, a group of Potentially Responsible
Parties (PRPs) (the Carolawn Generators Steering
Committee) entered into a Partial Consent Decree with the
United States Government to conduct a Remedial
Investigation and Feasibility Study (RI/FS) for OU1. The
purpose of this RI/FS was to fully characterized the nature
and extent of the contamination present at the Site and to
identify the relevant alternatives for remedial action. Phase
I and Phase II of the RI/FS, conducted at the Site between
1985 and 1989, confirmed the presence of volatile organic
compounds (VOCS) in the groundwater exceeding
Maximum Contaminant Levels ("MCLs") set by the
National Primary Drinking Water Regulations in the Safe
Drinking Water Act. On September 27,1989, EPA issued
a ROD for OU1 which selected a groundwater interception
and extraction system as the remedy for groundwater
contamination at the site. It was also determined that due
to the effectiveness of the removal actions, no source of
contamination remained within the fenced area of the site.
However, the findings documented in the ROD for OU1
indicated mat limited soil data was collected from the west
and north drum areas located outside the fence; therefore,
collection of additional samples was necessary to confirm
the presence or absence of residual soil contamination in
these areas. See the Section titled Update on OU1 on page
10 of this fact sheet for the current status of OU1.
In response to these concerns, EPA conducted a field
investigation at the Site in 1990. The purpose of the field
investigation was to provide additional information on the
presence of contaminants in the subsurface soil at the
former storage areas situated outside the fenced area. The
sampling results indicated the presence of VOCs in the soil.
Although this area was addressed during an EPA removal
action and again during the 1990 field investigation by tl4
EPA, Environmental Services Division, some uncertainties
still existed as to the presence or absence of soil
contamination. Based on EPA's review of all the available
data, it was determined that a Remedial Investigation and
Feasibility Study (RI/FS) needed to be conducted on OU2
in order to develop a baseline risk assessment and a sound
remediation plan.
The RI field activities were as follows:
• Collected surface soil samples from 42 locations
that included one background surface soil sample;
• Collected 10 subsurface soil samples from 10
locations that included one background subsurface
soil sample;
• Collected 4 surface water and 4 sediment samples
from offsite locations mat included one background
surface water sample and one background sediment .
sample;
• Conducted a site reconnaissance of the Carolawn
site and the surrounding area in order to identify
the various habitats which are potentially affect^j
by contaminant migration from the site;
• Performed an Ecological screening to identify
endangered and threatened species within the site
area. The screening was performed by contacting
the United States Fish and Wildlife Service. The
data from this agency was collected, reviewed and
summarized as part of the investigation.
• Conducted an electromagnetic investigation to
locate any buried wastes or drums at the site.
RESULTS OF THE REMEDIAL INVESTIGATION
The RI investigated the nature and extent of contamination
on and near the Site, and defined the potential risks to
human health and the environment posed by the Site. A
total of Fifty-two (52) soil, four (4) surface water, and four
(4) sediment samples were collected (see Figures 3 and 4).
As previously discussed, the ROD for OU1 selected a
groundwater interception and extraction system as the
remedy for groundwater contamination at the site. Since a
groundwater remedy has been selected for the Carolawn^
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OPERABLE UNIT
TWO
POWER
LINES
OPERABLE UNIT
TWO
i
CAROLAWN SITE
OPERABLE UNIT ONE
SITE LAYOUT MAP
CAROLAWN SITE
FT. LAWN, SOUTH CAROLINA
Figure
2 .
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OPERABLE UNIT
TWO
45
._,„- (BACKGROUND-
EE£T • SAMPLE) AREA
OPERABLE UNIT
TWO
XT'
SUAIL CRIO BOXES - SO' > SO'
LARCC CRIO BOILS - 100' • 100'
LEGEND
SAMPLE LOCATION
FENCC
POWER LINES — •
SOIL SAMPLE LOCATION MAP
CAROLAWN SITE
FT. LAWN, SOUTH CAROLINA
Figure
3
LEGEND
SAMPLE LOCATION
SURFACE WATER AND SEDIMENT SAMPLE LOCATION MAP
CAROLAWN SITE '
FT. LAWN. SOUTH CAROLINA
Kigure
4
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site, groundwater was not evaluated in the RI or the
Baseline Risk Assessment. All samples collected during the
RI were analyzed for volatile and extractable organic
compounds, pesticides, polychlorinated biphenyls (PCBs),
and metals.
Human Health
The laboratory results for all samples collected were
evaluated to identify compounds that exceeded threshold
concentrations (standards) established by EPA and
SCDHEC; or were statistically significant compared to
background concentrations. These compounds were
identified as chemicals of potential concern (COPCs). These
compounds were further evaluated to determine the human
health risks associated with their exposure to people. The
risks for each of these compounds was estimated in the
Baseline Risk Assessment Report.
The following is a summary of the chemicals of potential
concern identified in each media sampled.
Soil. The results of the surficial soil analyses indicated that
there are several COPCs present in the soil cover. These
compounds include: arsenic, barium, beryllium, calcium,
chromium, copper, iron, lead, magnesium, manganese,
sodium and polychlorinated biphenyls (PCBs). Other
concentrations of inorganics and organics were detected in
the soil. However, the concentrations of these contaminants
were below the typical background concentration ranges for
native soils or were below the threshold standards
established by EPA.
Surface Water and Sediment. There were no COPCs
identified for surface water. In addition, no volatile and
extractable organic compounds, pesticides or PCBs were
detected in any of the samples. Metals were detected in all
of the surface water samples. However, the concentrations
of these contaminants were below the typical background
concentration ranges..
The.sediment analyses revealed that arsenic is Uie only
chemical of potential concern in sediment. In addition, no
volatile organic compounds, pesticides or PCBs were
detected in any of the samples.
Environmental Health
Ecological Site Reconnaissance. Black & Veatch personnel
conducted a site reconnaissance of the Carolawn site and
the surrounding area in order to identify the various habitats
which are potentially affected by contaminant migration
from the site. The reconnaissance included rough
delineation of the various habitat zones present and
identification of dominant species within each habitat zone.
No quantitative measurements of species composition or
physicarcharacteristics of the various habitats were made
during this investigation. However, a baseline ecological
risk assessment was performed to determined if mere is any
present or potential risk to the environment from previous
site activities.
Similar to the human health risk assessment, the laboratory
results for all samples collected were evaluated to identify
compounds that exceeded threshold concentrations
(standards) established by EPA and SCDHEC; or were
statistically significant compared to background
concentrations. These compounds were identified as
ecological chemicals of potential concern (ECOPCs). These
compounds were further evaluated to determine the.
environmental risks associated with their exposure to
ecological receptors. The risks for each of these compounds
was estimated in the Baseline Risk Assessment Report.
The following is a summary of the ecological chemicals of
potential concern identified in each media sampled, the
screening criteria that are used to select ecological
chemicals of potential concern are specific to ecological
receptors; therefore, ECOPCs may often include different
individual chemicals than the human health assessment.
Soil. The results of the surficial soil analyses indicated that
there are several ECOPCs present in the soil cover. These
compounds include: arsenic, barium, copper, lead,
manganese, mercury, zinc, PCBs, tetrachloroethene, and
toluene. Other concentrations of inorganics and organics
were detected in the soil. However, the concentrations of
these contaminants were below the typical background
concentration ranges for native soils or were below the
threshold standards established by EPA.
Sediment. With the exception of barium, all chemicals
detected in sediment were eliminated as an ECOPC.
Barium was unable to be eliminated from sediment during
the screening process, because no screening value or
background concentration was available for this compound.
However, barium is not likely to cause a threat to the
aquatic environment because it normally precipitates out of
solution as an insoluble salt and therefore is less
bioavailable to aquatic organisms. It is unlikely that
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terrestrial organisms will come in direct contact with the
sediment at the site. Therefore, it should be noted that it is
unlikely that barium in sediment will pose a significant risk
to terrestrial organisms at the site. In addition, barium is not
known to bioaccumulate; therefore, this limits the
possibility that terrestrial as well as aquatic organisms will
come into direct contact with these contaminants through
the food chain. For these reasons, exposure of terrestrial
and aquatic organisms to barium in sediment was not
further evaluated in this Baseline Risk Assessment.
Electromagnetic Investigation. The primary purpose of this
Electromagnetic Investigation was to locate any buried
waste or metal objects at the site. No magnetic anomalies
were detected during the investigation. Detection of
magnetic anomalies would indicate the presence of buried
drums.
SUMMARY OF RISK ASSESSMENT
CERCLA directs EPA to protect human health and the
environment from current and potential future exposure to
hazardous substances at the site. A risk assessment was
conducted to evaluate the potential current and future risks
associated with exposure to the site contaminants.
Human Risk
AH of the chemicals of potential concern and the media
(soil and sediment) in which these chemicals were found
were evaluated in a Baseline Risk Assessment (BRA). A
Baseline Risk Assessment is performed at all Superfund
sites to determine whether the site poses a current or
potential risk to human health and the environment, in
absence of any clean-up. Both potential carcinogenic and
non-carcinogenic risks were estimated, with respect to
current conditions and possible future conditions.
Potential human exposure routes (for adults and children)
evaluated in the BRA included the following:
• Incidental ingestion of surfical soil
• Dermal (skin) contact with surfical soil
• Incidental ingestion of sediment from Fishing Creek
• Dermal (skin) contact with sediment in Fishing Creek
Future potential exposure routes for adults and children
associated with site development that were evaluated
included all of the scenarios listed above in addition to the
following:
• Incidental ingestion of subsurface soil
• Dermal (skin) contact with subsurface soil
Because carcinogens and non-carcinogens pose different
types of potential health risks, the EPA calculates two
different numbers when estimating health risks:
1. A Hazard Quotient is calculated for non-carcinogens to
assess whether health problems, other than cancer,
might be associated with a Superfund site. It is derived
by dividing the chemical exposure level at the site by
the chemical level determine to be safe. If the Hazard
Quotient is greater than 1 there may be concern for
potential health effects. Hazard quotients are calculated
for each chemical of potential concern found at the site.
To assess the overall potential for non-carcinogenic
effects posed by more than one chemical, all of the
hazard quotients calculated for each chemical are added
together. The sum of the hazard quotient is called a
hazard index. Like the hazard quotient, if the hazard
index is greater than 1.0 then the contaminants pose a
possible health risk.
2. Cancer Risk is expressed as an incremental probability
of an individual developing Cancer over a lifetime as a
result of exposure to the potential carcinogen.
Tables 1 and 2 below summarize the health risks estimated
for current and future exposure scenarios.
Table 1
POTENTIAL CARCINOGENIC RISK RANGE
Current Exposure
Pathways
Future Exposure
Pathways
9E-09 - 1E-07
9E-09 - IE-OS
Note: Unacceptable risks are those which have a
probability less than 1E-06. No action would be necessary
to be further protective of human health if the risk
probabilities are between 1E-04 and 1E-06.
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Table 2
POTENTIAL NON-CARCINOGENIC
HAZARD INDEX RANGE
Current Exposure
Pathways
Future Exposure
Pathways
2E-02 - 5E-05
6E-01 - SE-05
Note: Unacceptable risks are those which have a hazard
index above 1.0
Carcinogenic risk estimates for current and future
conditions are either below the lower limit 1E-6 or within
EPA's acceptable range (1E-6 to 1E-4). No non-
carcinogenic hazard indices exceeded EPA's acceptable
level of 1.0. In summary, EPA has determined that risks to
human health from contaminants in the soil and sediment
are within EPA's acceptable risk range and that remediation
of the soil and sediment would not be required for the
protection of human health. A more detailed discussion of
the exposure routes and presentation of the risk estimates
can be found in the Baseline Risk Assessment located in
the Administrative Record.
Environmental Risk
A qualitative risk assessment was conducted to determine
if ECOPCs posed an unacceptable risk to the ecological
receptors on and near the site. All ECOPCs and the media
of concern (surface soil) were evaluated in the ecological
section of the Baseline Risk Assessment.
At the Carolawn site, the terrestrial habitats present on the
site property include upland habitats. The american robin
and the eastern cottontail rabbit are common terrestrial
species inhabiting upland habitats. Because these two
species are common in upland habitats as well as the study
area, and a complete exposure pathway exists to these
receptors via soil, they were used as surrogates to represent
the terrestrial species exposed to contaminated surface soils
at the site.
The Hazard Quotient (HQ) method was used to define
potential risk to the two representative terrestrial receptors
via the soil exposure pathway. This method involves: 1)
Estimating the exposure of each receptor species to
ECOPCs by ingestion of contaminated food and/or soil; 2)
Determining from past scientific studies the highest
exposure level which produces no observed adverse effects
(NOAEL) and the lowest exposure level which produces
observed adverse effects (LOAEL) hi the representative
species; and, 3) Dividing the estimated receptor species
exposure level by the NOAEL and LOAEL. A LOAEL
based HQ greater man 1 is indicative that there may be a
potential for adverse effects on the receptor species.
Using the american robin as a potential receptor for the soil
exposure pathway, the LOAEL HQ values ranged from
6.8E-06 to 6.1E-01 and the NOAEL HQ values ranged from
6.8E-05 to 6.1E+00. In accordance with EPA's guidance for
Ecological Risk Assessments, remedial goals for the
protection of ecological receptors should be bounded by the
NOAEL value on the lower end and the LOAEL value on
the upper end. Thus, the risk range is between 3.8E-01 to
6.8E-05 which does not exceed EPA's acceptable level of
1.0.
Using the eastern cottontail rabbit, a potential receptor for
the soil exposure pathway, the LOAEL values ranged from
9.5E-08 to 6.2E-03 and the NOAEL values ranged from
9.5E-07 to 6.2E-02. In accordance with EPA's guidance for
Ecological Risk Assessments, remedial goals for the
protection of ecological receptors should be bounded by the
NOAEL value on the lower end and the LOAEL value on
the upper end. Thus, the risk range is between 6.2E-03 to
9.5E-07 which does not exceed EPA's acceptable level of
1.0.
In summary, EPA has determined that risks to the
ecological receptors from contaminants in the soil are below
EPA's acceptable risk range and that remediation of the soil
would not be required for the protection of the environment.
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PROPOSED FINAL ACTION
After careful evaluation of all the exposure routes,
estimated carcinogenic and non-carcinogenic health risks,
and ecological impacts, the EPA has concluded that the
Carolawn OU2 site does not pose an unacceptable risk to
human health or the environment. Based on the data
collected in the RI and the health and environmental risks
estimated in the Baseline Risk Assessment, EPA
recommends that no further action is necessary to provide
additional protection to human health or the environment.
The Baseline Risk Assessment shows no unacceptable
current or future risk for human health from exposure to the
soils or the sediment. The Baseline Risk Assessment shows
no unacceptable risk for ecological receptors from exposure
to the soils.
Based on the results of the Remedial Investigation and the
Baseline Risk Assessment Report, EPA is recommending no
further action at this site (OU2). However, should future
monitoring of the site (e.g. Five-Year Review) indicate that
the site poses an unacceptable risk to the environment, then
EPA may initiate clean-up actions under the authority of
CERCLA and in accordance with the National Oil and
Hazardous substances Pollution Contingency Plan.
UPDATE ON OU1
In response to concerns generated by citizens during a
public meeting held on January 10, 1995, EPA collected
two (2) sediment and one (1) surface water sample located
within the 3-acre fenced area. All samples were analyzed
for volatile and extractable organic compounds, pesticides,
polychlorinated biphenyls (PCBs) and metals.
The laboratory results for all samples collected were
evaluated to identify compounds that exceeded threshold
concentrations (standards) established by EPA and
SCDHEC; or were statistically significant compared to
background concentrations.. In summary all compounds
were within an acceptable range. The results are available
for your review at the site information repository.
Currently, EPA and the PRPs are continuing to work
toward implementing the groundwater clean-up for OU1.
Based on comments expressed by local residents and
officials, EPA is proposing that the Groundwater Treatment
System be constructed as outlined in the Final Remedial
Design, dated November 1992. Discharge to a Publically
Owned Treatment Works (POTW) does not appear to be
feasible or acceptable to local residents.
This design includes construction of a series of extraction
wells to collect contaminated ground water, a treatment
system design to remove contaminants which pose a risk to
human health or the environment, and discharge of treated
ground water to Fishing Creek. The extraction wells have
been constructed. Bids for construction of the treatment
system are expected to be solicited soon.
Individuals should feel free to include comments on the
Final Design for the ground water treatment system during
this comment period. The Final Design, as well as our
March 1994 Fact Sheet, which contains a more detailed
explanation of the ground water design, can be reviewed at
the site information repositories listed on page 11.
OPPORTUNITIES FOR PUBLIC
INVOLVEMENT
EPA has developed a community relations program under
Superfund to respond to citizens' concerns and needs for
information as well as to enable residents and officials of a
community to participate in the decision-making proces
Before EPA carries out or authorizes technical work
site, EPA staff and/or EPA contractors prepare a
Community Relations Plan (CRP) based upon discussions
in the community with local leaders and private citizens.
This plan identifies the techniques EPA will use to
communicate effectively with the community during the
remedial process. These communication efforts often
include telephone contacts, small informal meetings or
formal public meetings, news releases, correspondence and
fact sheets. The CRP is available for review at the site
information repository.
EPA establishes an administrative record and an
information repository where reports and other documents
are made available to citizens. The administrative record is
a file which contains all information used by EPA to select
a response action for the site under the CERCLA. A
duplicate file is maintained at the Region IV EPA Office in
Atlanta, Georgia. The .information repository is a file that
contains current information such as technical reports and
reference documents regarding the site. The information
repository documents can be reviewed at the library listed
below. For information regarding the documents
maintained in the administrative record and information
10
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repository, visit the library listed below or contact the EPA
community relations coordinator for the site.
You are encouraged to visit the information repository and
contact EPA and SCDHEC representatives listed in this
document for additional information. EPA would also
accommodate requests for informal meetings during the
public comment period, to further explain the findings of
the RI/FS and the Proposed Plan. Individuals interested in
arranging briefings should contact EPA's Community
Relations Coordinator for the Site.
TECHNICAL ASSISTANCE GRANTS ARE AVAILABLE
To assist communities in interpreting the technical findings
at Superfund sites, communities may apply for Technical
Assistance Grants of up to $50,000. Congress and EPA
have established requirements for the use of this grant.
Citizens who are interested in a TAG may contact Ms.
Cynthia Peurifoy at 1-800-435-9233.
Administrative Record and Information Repository
Lancaster County Library
313 South White Street
Lancaster, SC 29720
(803) 285-1502
HOURS
Chester County Library
100 Center Street
Chester, SC 29706
(803) 377-8145
HOURS
Monday - Thursday
9:00 am - 8:00 pm
Friday
9:00 am - 5:30 pm
Saturday
9:00 am - 5:00 pm
Sunday
Closed
Monday - Thursday
9:00 am - 7:00 pm
Friday - Saturday
9:00 am - 5:00 pm
Sunday
Closed
11
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FOR FURTHER INFORMATION
Remedial Project Managers
Operable Unit One - Alfred Cherry
Operable Unit Two - Yvonne Jones
U.S. Environmental Protection Agency
345 Courtland Street, NE
Atlanta, Georgia 30365
(404) 347-7791 or (800) 435-9233
Community Relations Coordinator
Cynthia Peurifoy
U.S. Environmental Protection Agency
345 Courtland Street, NE
Atlanta, Georgia 30365
(404) 347-7791 or (800) 435-9233
Regional TAG Coordinator
Rosemary Patton
U.S. Environmental Protection Agency
345 Courtland Street, NE
Atlanta, Georgia 30365
(404) 347-3931 Ext 6107
South Carolina Project Manager
Richard Haynes
District Engineer
South Carolina Department of Health & Environmental Control
2600 Bull Street
Columbia, South Carolina 29201
(803) 896-4070
GLOSSARY
Administrative Record - A file which is maintained and contains all information used by the EPA to make its decision on the
selection of a response action under CERCLA. This file is required to be available for public review and a copy is to be
established at or near the site, usually at the information repository. A duplicate file is maintained in a central location such
as a regional EPA and/or state office.
Baseline Risk Assessment (BRA) - An assessment which provides an evaluation of the potential risk to human health and the
environment in the absence of remedial action.
Carcinogens - Substances that cause or are suspected to cause cancer.
Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) - A federal law passed in 1980 and
modified hi 1986 by the Superfund Amendments and Reauthorization Act (SARA). The Acts create a trust fund, known as
Superfund, from taxes on chemical and petroleum companies, to investigate and clean up abandoned or uncontrolled hazardojg
waste sites.
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Information Repository - Materials on Superfund and a specific site located conveniently for local residents.
National Priorities List (NPL) - EPA's list of uncontrolled or abandoned hazardous wastes sites eligible for long-term clean
up under the Superfund Remedial Program.
National Oil and Hazardous Substances Contingency Plan (NCP) - The Federal regulation that guides the Superfund
program.
Noncarcinogens - Substances that may cause other adverse health effects besides cancer.
Parts Per Million (ppm) - Units commonly used to express low concentrations of contaminants. For example, 1 ounce of
Chloroform in 1 million ounces of water is 1 ppm. If one drop of Chloroform's are mixed in a.competition sized swimming
pool, the water will contain about 1 ppm Chloroform.
Potentially Responsible Parties (PRP's) - This may be an individual, a company or a group of companies who may
have contributed to the hazardous conditions at a site. These parties may be held liable for costs of the remedial activities by
the EPA through CERCLA Laws.
Public Comment Period - Time provided for the public to review and comment on a proposed EPA action or rulemaking after
it is published as a Proposed Plan.
Record of Decision (ROD) - A public document that explains which cleanup alternative will be used at a National Priorities
List site and the reasons for choosing the cleanup alternative over other possibilities.
Remedial Investigation/Feasibility Study (RI/FS) - Two distinct but related studies, normally conducted together, intended
to define the nature and extent of contamination at a site and to evaluate appropriate, site-specific remedies.
Reasonable Maximum Exposure (RME) - A term used in the Baseline Risk Assessment. The RME is the highest exposure
to contaminants that is reasonably expected to occur at a site as is based on the professional judgement of the risk-assessor.
Responsiveness Summary - A summary of oral and/or written public comments received by EPA during a comment period
on key EPA documents and EPA's responses to those comments. The responsiveness summary is especially valuable during
the Record of Decision phase at a site on the National Priorities List when it highlights community concerns for EPA decision-
makers. .
Safe Drinking Water Act (SDWA) - Federal law passed in 1974 to ensure water supply systems serving the public would meet
minimum standards for the protection of public health. The law was designed to achieve uniform safety and quality of drinking
water in the United States by identifying contaminants and establishing maximum acceptable levels.
Superfund Amendments and Reauthorization Act (SARA) - Modifications to CERCLA enacted on October 17, 1986.
Volatile Organic Compounds (VOCs) - Organic compounds which easily change from a liquid to a gas when exposed to the
atmosphere.
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CAROLAWN (OU2) SUPERFUND SITE MAILING LIST COUPON
If you have had a change of address and would like to continue to receive site related
information or would like for EPA to add your name and address to the mailing list
for the Carolawn (OU2) Superfund Site, please complete this self-addressed form.
If you have any questions regarding this mailing list, please call Cynthia Peurifoy at
1-800-435- 9233.
NAME: .
ADDRESS:
TELEPHONE: ( 1
USE THIS SPACE TO WRITE YOUR COMMENTS
Your input on the Proposed Plan for the Carolawn (OU2) Superfund Site is important in helping EPA
select a final remedy for the Site. You may use the space below to write your comments, then fold
and mail. A response to your comment will be included in the Responsiveness Summary.
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CAROLAWN (OU2) SUPERFUND SITE
PROPOSED PLAN PUBLIC COMMENT SHEET
Fold on dashed lines, staple, stamp and mail
Name
Address
City State Zip
Place
Sump
Here
Cynthia Peurifoy, Community Relations Coordinator
North Superfund Remedial Branch/Waste Division
U. S. EPA, Region 4
345 Courtland Street, NE.
Atlanta, GA 30365
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United Stales North Superfund Remedial Branch
Environmental Protection 345 Courtland Street, NE
Agency Atlanta, Georgia 30365
Region IV
Official Business
Penalty for Private Use
$300
Cynthia Peurifoy
Community Relations Coordinator
(Carolatm NPL Site)
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Attachment B
Public Notices of Public Comment Period and Extension
of Public Comment Period
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THE PROPOSED PLAN WAS PUBLISHED IN THE "CHESTER NEWS" ON JULY 21, 1995
lWENTAL PROTECTION AGENCY
P&??W^*^ "• ••'•'••• -~-'!il"' ;O;F:^:-
*'-^L^^^^^^ and the South
^I^th'i^l8n^f|m6nta! Control (DHEC), will conduct a PubJic
v---v.-.- -
ri «^?vfcVtf,'.V""-"
-------
,#<&W^V«Vr"
THE UNITED STATES ENVIR(5NiyiENTAL PROTECTION AGENCY
PUBLIQR/IEETING
'•:'..'.'•';'. ••!•?• °f. .-XW
Highways
South Carolina- • - - ^ ';''
Protection •Agency (EPA) and the South
itn^hm^l Control (DHEC), will conduct a Public
^CtZ^^J.:.p^P^i^.^.v#;j?.^^^ <••: •' ** •\..-r ':••„' -•.<.•.-.• •. .-t.^^Kf.'.t'•'J?S''j« M '.-"i?^
^L-?vVW-.'-v:AVHiV^<^/ifcA^'-'(^;;:-i^:«^^\^^^>i^v^ Ci./'a. v"i -'i'-; ci.';'." '-' ;;V :. > 'is' '*''| ; .'£..'-•
tstand concera^egardingithe^ prqli^
&£fei»j:w"i£'3B^)^££;^ji5M^
^^M^^TOr^hekGr^dwate
^
ManWaersifor the
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-------
-
• .y:-.,-s--'
5lhe Herald; Morufcy, Jur/ltfW
,. .
^
%medial*di0Sign'bf-:rt^.1^:
(OUiySuperfund Site; and thirdly, to .
^,:r^,i^^^rL:-:-^eCjSjon for noj
•vThe EPA is initiating.? thirty, (30) da^publiclcomrnent period.from July 24,1995 to;f
'August 24^1995,% receive\d6r^ipehts^r^ihis!-Pro[)osed Plan, the Remedialv;
.. jnvestigation (Rl) Report and the Baiselirie Risk Assessment "(BRA) Report. However,"
EPA will accommodate requests, for informal briefings during the week of the Proposed
Plan meeting. ERA, with concurrence from SCDHEC, will select a remedy for the Site
only after the public comment period has ended and all information submitted to EPA
i**
'vFbriadditjpni
^^nthia;;P&iuif;<>y^ at 800/435^9233, ^072>6r;4p4/347r7791, x2072^Ybu may also I
^contact 4EPAvs Remedial Prblect'Manaaers for the sltW A i — -
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Attachment C
Written Public Comments Received
During the Public Comment Period
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To: Cynthia Peurifoy, Community Relations Coordinator
Horth Superfund Remedial Branch,'Waste Division
From: Susan K. Helms
Date: August I. 1995
Topic: Toxic Cleanup
I would like to state my ideas concerning the proposed cleanup of the
toxic mess in my community.
i. The ground water within a mile radius of the site should be
treated with a permanent waste treatment plant which should be built
on tne site. The treated water should be pumped to the nearest
natural creek (Fishing Creek;. This plant should be built to allow
the community to use for future growth after the contaminated water
has oeen treated. The estimated time of completion should be within
an eignt year period.
2. The soil and waste including drums have not been completely
:'.-!eanec up as 'reported which was proven at the last puoiic hearing
with photos and reports of private citizens. The entire site snouia
be examined again especially for underground drums and further cleanup
of the area completed.
Thank you tor your support and investigation of the matter. I am
concerned for my sons and future grandchildren. I know you would be
also if you lived in my community.
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APPENDIX C - STATE LETTER OF CONCURRENCE
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r-KUI"l IU y 1404.54 Yl by b P. 02
South Carolina
DHEC
Commlftioner: Douglas E. Bryant
Board: John H. Burriaa. Chairman Richard E. Jabbour, DOS
William M. Hull. Jr.. MO, Vice Chairman Cyndi C. MoBtelter
... _ ._ . „ , Roger Uaks. Jr.. Secretary Brian K. Smith
Department o( Health and Environmental Control Rodney L Qrandv
2600 Bull Street Columbia. SC 29201 Promoting Health. Protecting the Environment
September 19, 1995
John H. Hankinson, Jr.
Regional Administrator
U.S. EPA, Region W
345 Courtland Street
Atlanta, GA 30365
RE: Carolawn OU-II - Record of Decision
Dear Mr. Hankinson:
The Department has reviewed and concurs with the revised Record of Decision (ROD) dated August 14,
1995 for the Carolawn Operable Unit II (OU-n) site. In concurring with this ROD, the South Carolina
Department of Health and Environment Control (SCDHEQ does not waive any right or authority it may
have under federal or state law. SCDHEC reserves any right or authority it may have to require
corrective action in accordance with the South Carolina Pollution Control Act. These rights include, but
are not limited to, the right to insure that all necessary permits are obtained, alt clean-up goals and
criteria are met, and to take separate action in the event clean-up goals and criteria are not met. Nothing
in the concurrence shall preclude SCDHEC from exercising any administrative, legal and equitable
remedies available to require additional response actions in the event that: (l)(a) previously unknown or
undetected conditions arise at the site, or (b) SCDHEC receives additional information not previously
available concerning the premises upon which SCDHEC relied in concurring with the selected alternative;
and (2) the implementation of the remedial alternative selected in the ROD is no longer protective of
public health and the environment.
The State concurs with the selected alternative of "No-Action". The State concurrence on this alternative
is based on the Baseline Human Health Risk Assessment, which determined that the Carolawn OU-II site
does not pose any unacceptable current or future risks to human health. This concurrence is also based
on the Department's above mentioned reservation of rights.
Sincerely,
R. Lewis Shaw, P.E.
Deputy Commissioner
Environmental Quality Control
cc: HartsHl Truesdale
Keith Lindler
Al Williams, Catawba EQC
Gary Stewart
Richard Haynes
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Attachment D
Official Transcript of the Proposed Plan Public Meeting
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
PROPOSED PLAN PUBLIC MEETING
FOR THE
CAROLAWN SUPERFUND SITE
TRANSCRIPT OF PROCEEDINGS
AUGUST 10. 1995
RICHBURG, SOUTH CAROLINA
REPORTER:
SUSAN WACHSMUTH, CVR
VERBATIM COURT REPORTING
P. O. Box 2711 CRS
ROCK HILL, S. C. 29730
(803) 328-9640
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2
1 PROCEEDINGS
2
3 United States Environmental Protection Agency
4
5 Region IV
6
7 Proposed Plan Public Meeting
8
9 for the
10
11 CAROLAWN SUPERFUND SITE
12
13 August 10, 1995 - 7:00 P.M.
14
15 Lewisville Elementary School
16 Richburg, South Carolina
17
is ***********
19
20 MS. PEURIFOY - Good evening, everybody. We're
21 ^ ;••
22 going to go ahead and get started. I am Cynthia
23 Peurifoy, and I'm the Community Relations Coordinator
24 for EPA, Region IV, with the South Carolina Section of
r
25 the North Superfund Remedial Branch. I'd like to
26 introduce some people that are here with me tonight:
27 Mr. Al Cherry, who is the Project Manager for Operable
28 Unit One of the Carolawn site; Ms. Yvonne Jones, who is
29 a Project Manager for Operable Unit Two of the Carolawn
30 site; Miss Marlene Tucker, who is our attorney for the
31 site; and Mr. Jan Rogers, who is the Chief of our
32 Section. We also have some people here with us from
33 the South Carolina Department of Health and
34 Environmental Control, Mr. Richard Haynes and Mr.
35 Enayet Ullah.
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1 I'd like to go over with you a little bit our
2 purpose for tonight's meeting. We're going to
3 summarize the remedial investigation and site
4 background, and we're going to talk about the study
5 findings. We're not going to spend a lot of time on
6 the site background tonight because we know that you're
7 really here to talk to us. We're going to summarize
8 the baseline risk assessment and we're going to talk
9 about EPA's preferred cleanup alternative, and we're
10 going to give you the rationale for what we're
11 proposing. We're then going to get into the summary of
12 the groundwater design, and then we're going to ask for
13 your comments, questions and concerns.
14 As you will'notice, we have a court reporter here
15 tonight; and we need to make sure that she's able to
16 get down everything that is said, so we're going ask
17 you to come to the microphone, identify yourself, and
18 say whatever you have to say. We're going to also ask
19 you not to interrupt people when they're talking,
20 because she will go crazy, she's already told me. So,
21 let's be very respectful of others and give her a
22 chance to do what she's here to do.
23 'I wanted to talk a little bit about community
24 relations issues. EPA gives Technical Assistance
25 Grants to communities where there are superfund sites.
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1 This is a grant of fifty thousand dollars to community
2 groups to hire technical advisors. You have to do a 20
3 percent match, which can be done through in-kind
4 services, cash - - - whatever form you like - - -
5 volunteer services. You must prepare a plan for how
6 you want to use the money, and you can also hire a
7 person to handle the grant for you, an administrator.
8 You cannot use the TAG grant to develop new information
9 or to conduct sampling or underwrite legal actions.
10 The group must be non-profit and must be.incorporated.
11 We have two information repositories set
12 up where you can find administrative records; they are
13 the Lancaster County Library and the Chester County
14 Library. You cart also find the groundwater design at
15 the Lancaster library. You have an 800 number, you can
16 call us at any time. It's 1-800-435-9233. Any time
17 you want an update on the site, any time you have any
18 questions or concerns, give us a call.
19 I'm now going to turn things over to Ms. Yvonne
20 Jones.
21 . MS. JONES - Basically, as Cynthia stated earlier,
22 due to the fact the majority of, I guess, the citizens
23 here - - - please correct me if I'm wrong - - - for the
24 most part pretty much have an understanding of what
25 took place in the background, as far as the Carolawn
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1 history - - - site history.
2 MR. CHERRY - Yvonne, they say they can't hear you.
3 Lower your mike a little bit.
4 ' MS. PEURIFOY - While we're doing this, can
5 everybody see the screen okay?
6 MS. JONES - We could also dim the lights if that
7 would be more appropriate. Basically, to summarize, I
8 think, a little bit of the history of the Carolawn
9 site, there was a company by the name of SEPCO Company
10 that, basically, had what we would call a storage and
11 disposal facility that operated on the whole entire
12 site, which we are estimating to be approximately five
13 acres - - - five to seven acres, I guess - - - which
14 would be named Carolawn.
15 Around mid-1970, SEPCO Company basically went
16 bankrupt, and another company by the name of the
17 Carolawn Company basically came in and also operated at
18 the site. Unlike the SEPCO Company, they did not
19 operate on the whole entire site - - - at least to our
20 knowledge they did not operate on the whole entire site
21 - - - but basically they pushed out the drums that were
22 on the inside of the fence, known as SEPCO drums; and,
23 of course, they started their operations within the
24 three acre portion of the fence. I don't know if
25 everyone can see that. Sometime in 1979, the Carolawn
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1 Company went bankrupt. Not only that, there was some
2 contamination, basically VOCs - - - at this particular
3 time is trichloroethane- - - that was found in a
4 citizen's well. That led to several investigations;
5 mainly SCDHEC, or South Carolina Department of Health
6 and Environmental Control, did a groundwater study. In
7 addition to that, that led to a removal conducted by
8 EPA in 1981.
9 Basically, as you can see, the areas where the
10 removal took place were, for the most part, within the
11 fenced in area. You can see that - - - to the west
12 portion of the site, which is what we would have
13 considered the West Drum Area and, of course, the North
14 Drum Area.
15 Basically, this is a photograph taken in 1984. As
16 you can see, there are still a.few horizontal tanks,
17 maybe one vertical tank that is still left on the site.
18 I do not have an aerial photograph that basically shows
19 the site as of this date. However, I can tell you that
20 there is at least one horizontal tank - - - in other
21 words, this is a tank that's fairly large and literally
22 horizontal - - - and, of course, we do have some
23 storage, I guess, drums out there; not really used, I
24 guess, for what they were using them for, but we use
25 them for our remedial investigation activities.
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1 Basically, the focus of this RI was to study the
2 area on the outside of the fence, and I guess I need to
3 talk a little bit about OU1 and OU2. Based on what
4 I've heard, there seems to be a little bit of concern
5 as to what was considered to be OU2 and what's
6 considered to be OU1. Basically, what we considered
7 OUl to be was the area within the fence. That is the
8 area where we felt - - - or that we know that Carolawn
9 operated on.. In addition to that, that also included
10 the groundwater, not only below the three acre fenced
11 in area, but also the groundwater beneath the entire
12 site.
13 As far as OU2, which is our focus - - - of this
14 investigation that we have currently completed - - -
15 basically, we looked at the West Drum area. I don't
16 know, can everyone see that? We also looked at the
17 North Drum area and, basically, the perimeter around
18 the site. Basically, the area of focus was
19 approximately two acres of land surrounding the chain
20 link fence. One of the reasons we did this was - - -
21 doing Operating Unit One, basically, you know, we
22 investigated the area within the fence. However, we
23 did not look at the areas right around the perimeter of
24 the fence. So, it included that. There was some
25 concern about whether or not the sediment or the
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1 surface water had been properly addressed, so we also
2 looked at the sediment and surface water.
3 Basically, we collected actually 52 soil samples.
4 42 of those samples were surface soil samples. In
5 other words, those samples were collected from zero to
6 six inches. We collected 10 subsurface soil samples,
7 four surface water samples, four sediment samples. In
8 addition to that, we also conducted what we would call
9 a site reconnaissance to basically determine the type
10 of ecological system that we have out there. We also
11 conducted what we call electromagnetic investigation.
12 And, in summary, what that is, it's really - - - it's
13 the way or it's a procedure that we use to determine
14 whether or not we have any buried metal objects below
15 the surface.
16 And, as you can see here - - - I'm a little out of
17 focus - - -but, basically, we've divided the site into
18 what we considered or called grids. Basically, in the
19 areas where we thought there was an indication of
20 contamination, we sampled in a 50 by 50 area,
21 basically, taking composite samples. In the areas
22 where based on the aerial photographs did not really
23 look like they had any - - - I guess, stressed
24 vegetation or indication that there was contamination
25 out there - - - we looked at on a 100 by 100 grid
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1 sample. And, basically, this is just a map or a
2 figure that shows where we collected the sediment or
3 surface water samples. Basically, on all samples taken
4 during the focus RI, we ran what we call full scan.
5 Basically, what that means is we scan for PCBs,
6 pesticides, metals, and, of course, all organics and
7 extractable inorganic. EPA - - - and of course, I
8 guess you could say EPA to begin with - - - has what we
9 call a set of screening levels that we consider to be
10 protective of human health and the environment. When
11 we get ready to do our Risk Assessment, basically what
12 we do is we say, do we have any contaminants that are
13 above those screening levels? In addition to that, we
14 also take what we call a background sample, where we
15 say, do we have any contaminants that are two times, I
16 guess, whatever our background levels are? If we do
17 have contaminants, we basically sum them up on a list
18 of what we call chemicals of potential concern. Now, I
19 just want to say.that does not mean that there's a
• • -
20 reason to be concerned. It basically means that, hey,
'21 you have some contaminants that are at elevated levels.
22 We don't really know how elevated, we don't even know
23 if there's really a risk that's, you know, been
24 generated. But we're going to look at them, in 'the
25 process of using the Risk Assessment, to determine if
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1 we do have an unacceptable risk. As you can see, there
2 were several inorganics, rather metals, in the surface
3 soil, subsurface soil, and, of course, we had arsenic
4 in the sediment.
5 Basically, in this particular Risk Assessment, we
6 also looked at the impact or whether or not there was
7 an impact on the ecological receptors out at the site.
8 Again, we also did a list of chemicals of potential
9 concern. I would like to say that, as you can see,
10 this list is not exactly the same as what you would see
11 for' human health. The reasons are - - - or one of -the
12 reasons is because, you know, we are humans and, of
13 course, we're likely to be susceptible or either more
14 or less to certain chemicals than, let's say, a rabbit
15 or a robin. So, that's why you'll see different
16 contaminants of potential concern than what you might
17 see for human health.
18 Basically, for human health, we looked at several
19 different scenarios. We wanted to see, you know, what
20 would the risk be if someone accidentally - - - I
21 shouldn't say accidentally, but actually ingested
22 surficial soil. What would happen if someone actually
23 came in contact with surficial soil that was
24 contaminated by the contaminants that I previously
25 mentioned. And, as you can see, we looked at what
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1 would happen to someone if they ingested sediment in
2 Fishing Creek or came in contact with the sediment in
3 Fishing Creek. That was what we looked at on the
4 potential exposure routes for adults and children. The
5 reason why I say potential at this particular case is,
6 you know, there's no one living on the site right now.
7 However, in the future there could be someone living on
8 the site. So, again, we also have to look at what the
9 chances are of someone ingesting the surficial soil,
10 dermal contact with soil sediment in Fishing Creek, and
11 so on. ;
12 I'm not going to really go into depth on that; however,
13 at the end of our presentations if you would like to
14 ask questions, please feel free to do so.
15 Basically, as far as from the environmental
16 standpoint, we basically looked at the ingestion of
17 either the American.robin or, as you can see, the
18 eastern cottontail rabbit for surficial soil. Can
19 everyone see that? It's kind of hard to see.
20 Basically, I guess, it's the same as what was in the
21 fact sheet, in case you might want to turn there. But,
22 in summary, on the current future exposure scenario, in
23 summary we had maybe, I think it was, nine out of a
24 trillion. The range went nine out of a trillion to one
25 out of one hundred thousand, as far as one being that
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1 person that could get cancer if they were exposed to
2 contaminants at the site.
3 And I guess at this particular point I'd like to
4 explain something. EPA has what we call an acceptable
5 risk range. Basically, that is that one person - - -
6 in addition to your additional population getting
7 cancer from the normal area, so to speak - - - could
8 get cancer out of ten thousand. As you can see, we
9 didn't have anything close to that. We had maybe one
10 person, I think - - - worst-case scenario we had one
11 person out of a million getting, you know, possibly
12 getting cancer. Which, of course, we take action if
13 it's one out of ten thousand. As far as looking at
14 what we call non*carcinogenic risks or, rather, risks
15 that are not cancer causing but are risks, basically
16 EPA has a boundary - - - and that boundary being
17 one - - - at which we would look at taking action. In
18 summary, our worst-case scenario was 0.6. So, again,
19 that's also well below what we would consider
20 unacceptable.
21 Basically, we did the same thing for the American
22 robin and, of course, the cottontail rabbits. It's
23 done a little bit differently because, unlike
24 humans - - - we're basically going out to a spot so
25 many times a day, and that's where they're getting
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1 their ingestion from. But, in summary, basically those
2 values also fell within EPA's acceptable range.
3 And, based on the results of the Remedial
4 Investigation, and also Baseline Risk Assessment
5 Report, EPA is recommending no further action at this
6 site, for Operable Unit 2, mainly just because we did
7 not have any unacceptable risk as far as human health
8 or environmental health. However, should future
9 monitoring of the site indicate that the site poses an
10 unacceptable risk to the environment, then EPA - - -
11 and I should say EPA in conjunction with the State^bf
12 South Carolina - - - may initiate clean-up actions.
13 MR. CHERRY - Hello, I'm Al Cherry, and I'm the
14 Remedial Project'Manager for Operable Unit 1. Operable
15 Unit 1 consists of a groundwater clean-up, within the
16 fence, of the site itself - - - in the site itself,
17 right inside the fence. So, for the last couple of
18 years we have been working to complete a design with
19 our consultant, which is Conestoga-Rovers. I think
20 they finally put a good design together, and we hope
21 that this will do the required job.
22 The Carolawn Groundwater Remediation System
23 consists of two treatment processes. One of them,
24 basically, is an Air Stripping/Clarification Process,
25 and the other process is an activated carbon with a bag
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1 filter process. The stripping process will be utilized
2 as a primary treatment system, and the activated
3 carbon, the bag filter, will be used as the secondary
4 system. The stripping process is basically designed
5 to handle up to 20 million gallons, and it is an Air
6 Stripping Unit which is basically designed to achieve
7 removal of the particulants of concern. The
8 groundwater system will receive the water from five
9 extraction wells, and these five extraction wells are
10 120 to 150 feet deep and will go down to what we call
11 bedrock. ;•'
12 Now, there are plans for another addition of five
13 wells, which will extend the capture plume to capture
14 all of the contaminants if it's necessary. These wells
15 are basically designed to produce a flow of one to two
16 million gallons, and we have five of these wells. The
17 treatment system, as I said before, is designed to
18 handle a flow of 10 to 20 million gallons. Each
19 extraction well is four inches in diameter. It has a
20 centrifugal, submergible pump, and it also has a check
21 valve. There's also on each well what they call
22 pressure transducers, and these pressure transducers
23 are installed so they can be incorpoitiLeu. iuLu Llns
24 automatic system itself. What these pressure
25 transducers will do is control the level of water in
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1 each one of the wells, and it will tell the pumps when
2 to operate and when not to operate, when to turn on and
3 when not to turn on.
4 So, now we have the wells. And after the wells we
5 have a tank which is called the equalization tank.
6 Basically, the equalization tank is designed to hold a
7 reservoir from the five pumps, from the five extraction
8 wells. This particular tank will hold up to 475
9 gallons of water that is extracted from these wells,
10 and basically what this does is it gives us a retention
11 time. In the tank itself we will have some solids; that
12 are being settled out while the water is sitting in the
13 tank, and we have a reservoir so once the controls from
14 the plant itself'decide that the air stripper needs a
15 certain amount of water, then these pumps will kick on
16 and pump water over into the air stripper. This thing
17 is basically designed that they would get a retention
18 of about 23 minutes, that the water coming from the
19 wells would sit and will just set in this tank for 20
20 full minutes. This will allow some settling of solids
21 that will fall out of this water that initially comes
22 from the well.
23 The next unit, which is the air stripper, it is
24 designed to handle 20 gallons per minute. Now, we have
25 control valves, and they are located downstream from
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1 the equalization tank. What they will do is, when told
2 by the control system, they will pump, say, 20 gallons
3 per minute of water to the air strippers. Then the way
4 that the air stripper is designed, you actually have
5 water coming in the top and you have air bubbles that
6 are being blown up from a blower from the bottom of
7 this tank, and the contaminated materials will, being
8 volatiles, will adhere to the water coining down in the
9 air going up, and you'll get volitization; and your
10 volatiles coming up the top of the stripper.
11 Now, our consultant will apply for an air permit,
12 if possible, but according to designing some of the
13 calculations, they don't think that we're going to have
14 enough contaminants coming off the top, volatiles
15 coming off the top of this air stripper, to require
16 that the stripper be permitted.
17 Okay, from that you will get removal of VOCs, as I
18 said before, by the bubbles, and the contaminants
19 attaching to the bubbles and going out the top of the
20 unit itself. And, according to some of the design
21 information that was conducted during the Feasibility
22 Study, the Remedial Investigation, .from a
23 manufacturer's rep we round out thctL Lhe aii tsLiippcsi"
24 will remove 90 percent of the TOC and 45 percent of the
25 DCE and 95 percent of the 1,2,DCE. The air stripper
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1 has a removal efficiency of 99.6 percent for TCE; 97t5
2 percent for 1,2,0GB; and 99 percent for 1,1, DCE.
3 These rates, again, are based on the required effluent
4 criteria and expected performance of the equipment
5 itself.
6 There are three water probes located in the unit,
7 and basically the water probes will turn the pumps on,
8 turn the pumps off, and give signals to the rest of the
9 system as to the status of the different units. So,
10 the air stripper would discharge the treated material
11 to the clarifier. Now, the second system consists ;bf
12 the bag filter and activated carbon. Now, this could
13 be used two different times. It would be used when
14 you're having soitle type of maintenance being conducted
15 on an air stripper or when you need to achieve
16 additional removal through the use of activated carbon.
17 Now, the streams are set up so that from the
18 equalization tank the flow goes into the air stripper,
19 you have solids coming off the equalization tank, and
20 you also have the volatile gases going off through the
21 .stack of the air stripper itself. Okay, that material
22 from the treated water from the air stripper will then
23 go into a clarifier, and the water from the clarifier
24 can go to the discharge channel and the solids can go
25 to the dry bed, to the sludge drying bed. Or, from v
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1 that it can go to the bag filter. The bag filter, what
2 it does basically, it filters solids and keeps from
3 overloading the activated carbon. And so you
4 actually - - - the bag filter has a disposable type
5 filter that you can take out if you need to take it
6 out. You can take it out and you clean it when you get
7 pressure across the filter, or you can run that
8 particular treated material into the activated carbon.
9 Now, the activated carbon has high-efficiency
10 removal, just like the air stripper itself. Very, very
11 seldom will you need to run both of these at the same
12 time, unless you have a failure in one of the systems.
13 Okay, we have an outfall, and the outfall to
14 Fishing Creek is'1,300 feet. There are several
15 manholes in that particular outfall, where we can take
16 samples and we will know what's going on inside. So,
17 back to the plan itself. We have the watering beds.
18 The sludge from the watering system, it can be disposed
19 into a hazardous-type landfill. We have all these
20 different controls on the system itself which will tell
21 us - - - actually it would take a system, send it back
22 to an operator, and we would have pre-set phone numbers
23 that if you call it would call the phone number. In
24 case of a fire alarm, it would call the phone number.
25 In case of a failure in the system, it would call. In
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1 case you have some type of intrusion, someone
2 interfering with the system.
3 Here, again, this system is also developed so we
4 can have additional extraction wells. So, we have a
5 capture plume now, we have a plume now where it looks
6 as though five wells will capture the contamination
7 that is in the groundwater underneath the site. But,
8 there are several things that can happen. If it's not
9 capturing it, we can build additional wells. We can
10 install additional wells to extend the plume. If it's
11 moving too slowly, additional wells may speed up the
12 capture, and we can look at it that way. So, we think
13 that this system will do the required job, and will do
14 the job that we need to do, that we're looking for.
15 In future design we actually have on this
16 particular drawing and diagram we have plans if
17 required where we could put in another activated carbon
18 unit along with additional wells. All through this
19 system itself we have what we call sample reports. We
20 can check the efficiency of the unit itself, like we
21 have sample reports after the equalization tank where
22 we can go in and take a sample. And we also have
23 sample reports after the air stripper. Now there
24 is - - - which I guess I would probably have to look
25 into it. There are some things that this automatic
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1 system can monitor/ like pH and maybe some inorganics,
2 and it will basically tell us if the stream coming into
3 this treatment system itself is changing. But that's
4 basically the advantage of an equalization tank, so if
5 you've got different wells pumping different amounts of
6 contaminants, once it gets into the equalization tank
7 you will have more of an even flow of - - - even fill,
8 even feed going into the different units itself.
9 Now, there have been some questions about whether
10 this plant can handle multiuse uses. I don't know, but
11 our consultants seem to feel that if the money was •
12 available and people were interested they may could do
13 some additional things to have this. But from what I
14 understand, I don't know if this type system would be
15 able to take municipal sewage or not. I don't think it
16 will, but our consultants are saying that it could be
17 possible, but I don't know what the expense will be.
18 Here, again, we're talking about removal of 90
19 percent. It would more than reach the criteria - - -
20 our criteria for discharge - - - that we should have
21 less than 26 micrograms per milliliter of
22 trichloroethylene, less than 25 micrograms per liter of
23 dichlorethene, and less than 30 micrograms per liter of
24 total solids. With the filters, with the clarifiers
25 that's located behind the equalization tank, and with
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1 the bag filter and the activated carbon itself, I don't
2 see how this system could not be able to meet this type
3 of discharge requirements from any of the equipment.
4 So, that's basically about it. I'll try to
5 summarize this. Again, what we have here, like I said
6 before, we've got proposed now, the system will consist
7 of five extraction wells, and these five extraction
8 wells will handle - - - each well will handle from one
9 to two gallons per minute. We have, then, from that it
10 would be going to an equalization tank, and the
11 equalization tank will hold 475 gallons. From the ;
12 equalization tank we go to the tray stripper, and the
13 stripper will, by streams of water going up and by
14 streams of water'coming down and pumped air going up,
15 the gases will attach to the water bubbles and go out
16 through the stack of the stripper. Then, from that
17 stripper we go to a transfer. We get solids removed
18 from the equalization tank, and they will come down and
19 go to a sand drying filter as they develop in the
20 equalization tank. And then from that, you know, air
21 stripper, and from the air stripper we have a
22 clarifier. There will be retention and settling in the
23 clarifier. The solids from the clarifier can go to the
24 drying bed. Then from the clarifier we will run this
25 material through a bag filter. It would filter again,
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1 and basically that material would also go down to the
2 dewatering bed. And then from that when you wanted to
3 get additional removal you could run this effluent
4 through an activated carbon filter and from there you
5 could go to your discharge channel and go out into the
6 stream and those solids would also you would take the
7 carbon out and send it to a landfill. So, you've got
<,
8 systems that will guarantee a high removal. So, I'm
9 pretty sure this is going to be a good system. I have
10 drawings in the back if anybody is interested in
11 looking at them. They seem to be real complicated;
12 they're real busy, but they have all of the valves and
13 controls and the control units that operate the plant
14 itself.
15 MS. PEURIFOY - Thank you, Al. We have a comment
16 period going now. I missed one of my slides,, but it
17 ends August 24th. But it can be extended for an
18 additional 30 days should you make a timely request. I
19 want to do one more thing and we're going to start
20 taking your questions and comments. I want to extend a
21 hearty thanks to two wonderful people, the McMinn's
22 who have helped me so much in pulling this together and
23 changing schools and everything. I really appreciate
24 it, guys. Thanks a lot. Public comments, questions?
25 MS. LISENBY - My name is Donna Lisenby. For those
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1 of you who don't know me, I have spent some time with
2 the EPA people. I've been asking a lot of questions.
3 I've spent probably over, gosh, a hundred hours
4 studying this particular site. You know, four hours
5 today with the EPA officials answered my questions, so
•6 I'm not going to need to ask them any questions
7 tonight. I'm just going to read my comments to the EPA
8 for the record, and I'm just going to sit down.
9 Comments to the EPA: In your fact sheet in the
10 history section EPA stated that there were a record of
11 2900 drums dumped on the site. You also stated that
12 1140 drums were removed. This leaves the total of 1760
13 drums unaccounted for. You stated that only 7.5 out of
14 a total of 82 acres was electromagnetically scanned for
15 buried drums. EPA's aerial photos are dated in 1979,
16 from which EPA and SCDHEC state there appear to be no
17 off-site dumping, however dumping occurred on the
18 property from 1970 to 1979. There are no aerial photos
19 for 1970, 1971, 1972, all the way to 1978. A dump site
20 could have been considerably overgrown by the time an
21 aerial photo was flown nine years later. A known
22 method of disposal by the operators was to puncture
23 barrels, release the contents onto the ground, and
24 stockpile empty drums. The only way to determine if
25 this occurred on the other 60 acres that remains
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1 untested is if all groundwater for the entire site has
2 been tested. However, only approximately 10 acres have
3 been tested - - - groundwater has been tested. There
4 continues to be physical remains on the property:
5 parts of half-buried and rusting and corroded drums;
6 green, red, brown and gray unidentified solvents.
7 PCBs, solvents, and metals - - - heavy metals - - -
8 were all known site contaminants. These are
9 heavyweight contaminants. The operators were clearly
10 sloppy and indiscriminate in where and how they dumped.
11 Based on these facts, my comments to the EPA are as
12 follows: I do not feel a sufficient investigation of
13 the entire property has occurred. I think there's
14 clear evidence, facts, that could indicate the
15 possibility of hidden burial or dump sites somewhere on
16 the property. I feel very reassured by the redundant
17 and overdesign of the groundwater treatment system.
18 However, I feel strongly that the possibility exists
19 that further soil, subsoil and other, as yet
20 undetected, groundwater plumes could be present
21 somewhere on the remaining untested 60 acres.
22 Therefore, I would like to ask for further testing of
23 the entire site. While this could be going on, I would
24 also certainly like to see the groundwater get pumped
25 and treated with the treatment system that you have
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1 approved. I'd like to see that started as soon as
2 possible, before the contaminant plume moves into
3 Fishing Creek. As a matter of fact, tomorrow would not
4 have been fast enough for me for groundwater treatment.
5 My third and final comment is that I'd like to commend
6 some of the community members here tonight who would
7 like to see a municipal treatment capability added to
8 the system. I think that's very forward thinking and
9 positive. I support this idea, if the PRP's stated
10 criteria can be met. However, I feel the groundwater
11 needs to be treated as soon as possible. Thank you.
12 MS. HELMS - My name is Susan Helms, H-e-1-m-s, and
13 I am from Richburg, but I teach in Great Falls. I want
14 to thank you, the EPA, and the PRP for allowing the
15 community to give input to your proposal. I've written
16 you, and now I would like to state my recommendations
17 publicly concerning the proposed clean-up of the toxic
18 mess in our community. I feel the groundwater has to
19 be treated on the site immediately, as Donna said, and
20 believe the community deserves a permanent treatment
21 facility. This facility should be built to allow the
22 community to use for future growth after the
23 contaminated water has been treated. The estimated
24 time of completion of the decontaminated water should
25 be within an eight-year period. After hearing from
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1 residents of the community, I think the soil and the
2 waste, including drums, have not been completely
3 cleaned up as reported. This fact was proven at the
4 last public hearing, with photos and reports from
5 private citizens. The entire site should be examined
6 again, especially for underground drums and further"
7 cleanup of the ar~ea completed. Thank you for your
8 support and investigation of the matter. I am
9 concerned for my sons and my future grandchildren. I
10 know you would be also if you lived in my community.
11 MR. NICHOLS - Thank you for giving me the
12 opportunity to speak. My name is Barnett Nichols, I'm
13 on the town council for the town of Richburg. I want
14 to commend the EPA, Mr. Cherry, Yvonne, the whole
15 group, for coming back after January. They really did
16 take a licking and they really got their gall to come
17 back, but we thank them. I like Mr. Cherry's
18 presentation. This afternoon Ms. Yvonne asked me would
19 I go down to the site with her, meet her down there.
20 And I told her I would, I'd be there at 5:00. I didn't
21 have an opportunity to go over any of it, I just
22 stopped at the gate, but the fence had been changed a
23 little bit from when I was down there. In 1979, in
24 June, we had a tremendous fire down there and I was a
25 respondent, the first respondent, and I know where
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1 these chemicals went. A lot of them went into the air,
2 a lot of them burned, but a lot of them went into the
3 ground. The reason I asked the lady to put that back
4 on the screen was I want to kind of show you where the
5 fire was. When I arrived, there was a bulldozer in
6 this corner of the site pushing drums, knocking holes
7 in the drums, letting the chemicals out. That's what
8 created the fire. And they had a swell going around
9 this way for this runoff. And I have the documentation
10 from the newspaper that they stopped me from pumping
11 the water. And I told them I came down to put the •• fire
12 out, I was a firefighter. I didn't know anything about
13 hazardous materials, but I was a firefighter. I didn't
14 realize all this'was down there at that time, but it
15 was all kind of barrels, five or six hundred lying
16 against the fence. Old drums, you couldn't even pick
17 them up. But at that time there was three
18 trailers sitting there. I see two now, but it was
19 three. These - - - there wasn't that many tanks back
20 there. I think there was about three or four. But the
21 incinerator had not been built. I don't know what that
22 is, I think it's a barrel site over there, I do not
23 know. I have no knowledge of that. But I am
24 confident, I believe that I can stand here and tell you
25 that the drums are gone, because they were recycling
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1 the drums that day. That's what they were doing. They
2 were letting the chemicals out in the runoff. I can
3 attest to that, that's my belief. I don't believe
4 there's any barrels here or anywhere else on the site,
5 I just don't believe it. But I liked the presentation,
6 I liked the stripping, I liked the air filters. Are
7 those in tandem? Are both of those in line?
8 MR. CHERRY - Yes.
9 MR. NICHOLS - Both in line. Are there going to be
10 housed, Mr. Cherry?
11 MR. CHERRY - Yeah, they have a building to put
12 them in.
13 MR. NICHOLS - No vandalism can bother them?
14 MR. CHERRY * .Well, they're going to have a
15 security system. If someone comes in, it will set it
16 off.
17 MR. NICHOLS - I'm totally opposed to a sewer
18 plant. I don't like to see chemicals, I abhor
19 chemicals, you cannot get chemicals out of solids once
20 you put them into solids. And sewage is solids. It
21 would be a costly thing to put into operation a sewer
22 plant down there at this time. Let's get the water out
23 first, and then look at a sewer sys'tem. I thank you
24 for letting me speak.
25 MR. BRUCE - My name is Jim Bruce. I'm a resident
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1 of Richburg. It's amazing, you know. My wife and I
2 moved to Rock Hill, South Carolina in 1979 from
3 Memphis, Tennessee. We've lived in big cities all over
4 the United States in our 31 years of marriage. We got
5 to Rock Hill in 1979 and we said, man, that's it.
6 We're never going to go nowhere else. We're going to
7 stay in Rock Hill the rest of our lives. Well, after
8 about 15 years and the doubling of the Rock Hill
9 population, we said, God, we've got to do it again.
10 So, let's - - - for the sake of quality and for the
11 sake of our grandchildren, let's find a farm to move
12 on. So, we looked. And thanks to brother Jim Gaston
13 (phonetic) back there, he found us a little place below
14 Richburg >- - - about five miles below Richburg - - -
15 and September - - - I'm sorry> August, exactly a year
16 ago, my wife and I moved to that farm. Within three
17 months, our son Frank, his wife, and our three
18 grandchildren also moved onto the farm. Within two
19 more months, our daughter Debbie and her husband James
20 moved onto the farm. And within the next 90 days, our
21 son Jimmy and his little girls are going to move on.
22 Well, I was pretty shocked when I heard about
23 Carolawn. I mean, initially it really was no big deal,
24 but then I got wind that it was cited as one of 114
25 sites in the United States that most needed cleaning
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1 up. Well, I started getting involved, and I talked
2 with some folks. And I really appreciate what's
3 happened since the last meetings. I wasn't - - - I
4 missed the meetings because I wasn't aware of .it until
5 after - - - in fact, that's how I found out about
6 Carolawn.
7 I'm satisfied, from all the conversations that
8 I've had with numerous people, that what EPA has done
9 in that five to seven acres I think is commendable.
10 I'm okay with .the proposed fix. My only suggestion
11 there is let's get it cranked up, let's get it started,
12 let's get it cleaned up right away. But I've got a
13 real problem emotionally with the balance of the 60-
14 plus acres. I have talked to an awful lot of people in
15 the community. I genuinely believe from the bottom of
16 my heart that the same gusto that you tested those
17 seven acres should be applied to the balance of that
18 60; not only surface testing throughout the 60 acres,
19 but subsurface testing. I believe if you do that - - -
20 and please, give us the assurance that if there is
21 anything, any contaminants found that those problems
22 will be addressed at that time - - - while we are
23 addressing the five to seven acres, let's look at the
24 balance as well. I want my grandkids to grow up and
25 not be upset with me because their skin is turning
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1 green, okay. Thank you.
2 MS. MORRIS - I'm not very mechanically-minded, so
3 speaking for the people who live near the Carolawn
4 site, I didn't quite understand, Mr. Cherry, about this
5 air stripper. One of the things you said, that the
6 gases would go out of the side of the stripper, does
7 that mean that the pollution that's in the ground is
8 going to be coming out in air form?
9 MR. CHERRY - Not all of it. Most of it is going
10 to be coming out in solids, that's why I tried to
11 emphasize when you have the groundwater coming out-
12 going into the equalization tank, you're going to have
13 solids coming down.
14 MS. MORRIS *• But you will have some air pollution?
15 MR. CHERRY - Right. But according to some tests
16 that they've done - - - and they'll have to get a
17 permit - - - it won't be enough to create a problem.
18 It's below the standard that's allowed to come out of
19 that unit itself. And the way they're doing this - - -
20 if you can - - - is I hope - - - I hope that I will be
21 able to do it, is show that all of these units have to
22 have a certain retention time. See, it's only 20
23 gallons per minute that that first unit will take, but
24 they've got 400 gallons of material in that first tank.
25 And basically what that's in there for is retention
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1 time so that you get solids falling out.. Then it goes
2 from there and it also will go into, you know, the
3 clarifier. So, you don't have all of this material,
4 you have a very small amount of material coming out of
5 the stack itself.
6 MR. ROGERS - Can I just clarify a little bit of
7 that? The air stripper - - - the concentrations in the
8 groundwater, as we talked last time, aren't necessarily
9 what we'd say are real high. They exceed what would be
10 acceptable from long term use as a groundwater source,
11 and that's why we're basically instructed by the law
12 and feel like it's inappropriate to just leave it
13 without trying to remediate. But the
14 concentrations -'- - I think we talked last time that
15 when we combine all these fiber covered wells will be
16 about 115 parts per billion, which is, in relative
17 terms, very little. It's not good for long term
18 consumption, therefore we're' going to clean it up. But
19 as far as stripping that out in the air, you end up
20 with a very, very low concentration coining out of. the
21 airstream, and therefore it doesn't - - - we don't
22 expect it would trigger any kind of requirement for a
23 permit or even be regulated as a permitted discharge
24 because the concentration's so low that it wouldn't be
25 deemed to be able to cause any kind of adverse health
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1 effect.
2 MS. MORRIS -.Let's hope not.
3 MS. PEURIFOY - Would you give us your name,
4 please?
5 MS. MORRIS - I'm Margaret Morris.
6 MS. PEURIFOY - Thank you.
7 MR. ROGERS - Are there any other questions,
8 comments, or statements?
9 MR. NICHOLS - I appreciate the chance to get up
10 here one more time. I would like to see EPA appoint a
11 committee from the community to work with them on ;
12 setting up this air stripper, or whatever they want to
13 do. I'd like the community to be .involved, then we
14 wouldn't have to'be wondering what EPA was doing.
15 MR. CHERRY - I'd like -to get Donna in. I sure
16 would like to have her on my side. Where is she?
17 MR. NICHOLS - We need to be involved with the EPA,
18 the community needs to be involved.
19 MR. CHERRY - Yeah, well, she's been on our side.
20 MR. NICHOLS - Come on up here and give me your
21 opinion.
22 MR. ROGERS - That's, you know, what we talked
23 about this afternoon. From what I understand, we got a
24 flavor last night - - - from what Cynthia and Yvonne
25 talked to the community or some of the members of the
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1 community - - - that they would be more interested in a
2 constant interaction with us. One of the things that
3 was proposed last year in the rewrite of
4 Superfund - - -which never took effect because it
5 wasn't authorized, the bill was never passed, but we as
6 an agency are still looking at it as a tool and
7 implementing it where there's interest and it's
8 appropriate - — is what they're calling Citizen Action
9 Groups, which are - - - Citizen Advisory Groups, where
10 the agency tries to let the community around the site
11 set up a group that fairly represents everybody's :
12 interest, that continue to conduct an ongoing dialogue
13 with the agency as we conduct and implement things
14 related to the site. It's envisioned that it would
15 take place earlier than where we are with this site.
16 We certainly don't want to slow things down, we think -
17 - - when we were here last time, we certainly heard a
18 lot of opposition to the idea of which discharge option
19 we were talking about then. We've responded to that,
20 come back with the original concept of discharge to the
21 creek, and we seem to get a flavor that people don't
22 necessarily oppose that and would like to go forward
23 with' implementing the cleanup. So, I think an area
24 that's real ripe for the Citizen Advisory Group would
25 be this continuation of concern over other areas of
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1 contamination. It's kind of like taking 60 acres and
2 saying, let's go look for a needle in a haystack.
3 That's - - - I may not have any money to do .that. But
4 at least - - - one of the things that's been very
5 effective is you know more about the operations of
6 those sites over the years, because you can run down
7 the people who know something about it or were involved
8 with it or know this, that and the other. If we can
9 come up with some reasonably credible feedback to hone
10 in on some areas to explore, we can start focusing in
11 on any concerns about additional contamination at the
12 site. And it's very possible that the Citizen Advisory
13 Group would be a good way to go. So, I guess I'd throw
14 that out for consideration. I think Cynthia, since
15 she's our Community Relations Coordinator, I'm going to
16 talk to her about getting back to y'all and trying to
17 start initiating that. But my one warning is that it
18 can't be a focus group with a predetermined interest.
19 It needs to be a fair representation of the community
20 involved with that group. We would like to do it in a
21 way that it's not too burdensome on people's time, but
22 it does, therefore, keep you more involved with
23 interaction with us about the site. It's one of the
24 frustrating things we have is we come and do these
25 public meetings - - - partially, as has been pointed
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1 out earlier, because we're mandated by law - - - but we
2 do feel like we want to interact and find out and can
3 find out things from y'all that we'd have a hard time
4 finding and, you know, identifying in Atlanta. But we
5 generally have low turnout. The Citizen Advisory
6 Group, I think, gets at the issue of creating a more
7 consistent dialogue where you can get better
8 interchange along the way about the life of the site.
9 We would hope and believe this is sort of toward the
10 end of the site and that we can get the implementation
11 and.groundwork going. We don't feel like there's any
12 remaining problem at the old Operable Unit Two areas
13 outside of the site, realizing those are focused areas
14 that we're looking at. We can continue to explore the
15 remaining 60 acres if we can start to get an idea of
16 what makes sense to go out and explore. Basically,
17 this will go into an operational phase whereby the pump
18 and treat won't clean up the aquifer quickly. It will
19 have to operate and be monitored and be evaluated over
20 time as we implement that residue. There's a
21 continuing dialogue as to whether we really have the
22 technology to completely clean up the aquifer, but
23 we'll at least implement the existing technology to
24 date to improve it to the point where we feel like
25 we've done everything we can. And we will periodically
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1 evaluate it to determine when are we no longer being
2 effective in what we're doing, and that will be a very
3 good area for the Citizen Advisory Group to be involved
4 in, too. Because if we come back seven or eight years
5 from now and tell you we're going to shut it off
6 because we can't do any more, but we haven't cleaned up
7 the aquifer, you're going to be upset, I guess. If we
8 can involve you along the way and get a better
9 understanding of what's technically do-able and
10 what's - - - may, in fact, end up being impracticable.
\
11 We don't want to throw in the towel on the front erid,
12 because we think we can significantly improve that
13 groundwater. But we don't know that we can
14 accomplish - - -'absolutely don't know we can
15 accomplish the goal we've set, which is get it back
16 downstream. But that's something I want to throw out
17 to consider, because I think we will pursue the Citizen
.18 Advisory Group.
19 MS. LISENBY - Of the people in this room, could
20 all the people who reside in this area please stand.
21 MR. ROGERS - Define the area.
22 MS. LISENBY - Okay. If you live within a 15-mile
23 radius of the school, could you please stand. Okay.
24 Of those people - - - I'm just trying to, because I
25 know everybody isn't comfortable speaking - - - of
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1 those people, how many of you would like to see further
2 testing of the additional acreage? Could you please
3 also istand if you would like to see further testing.
4 Is there anybody who did not stand up again? Okay.
5 That's about 95 percent of the residents in this room
6 would like to see continued testing of the additional
7 acreage. Thank you.
8 MR. SMITH - Good evening. My name is Reid Smith,
9 I'm a realtor in Rock Hill. I do a lot of business in
10 the Fort Lawn, Richburg area. I have a question.
11 There's a possibility that at a date that the allowable
12 level of contamination will be raised and then SCDHEC
13 will say, well, this site does not warrant cleanup now
14 because we've raised the level of allowable
15 contaminants. Is that possible? I understand from the
16 last meeting it was right there close, and I think
17 you - - -
18 MR. CHERRY - I think you were talking about the
19 outside of the fence. Isn't that right?
20 MR. SMITH - No, the water. The groundwater.
21 MR. ROGERS - I guess my answer is no. The cleanup
22 goals are established based on health-based
23 evaluations. That comes from toxicology and other
i
24 disciplines that feed information to the agency. We're
25 not necessarily fully a health-based agency. Agency
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1 for toxic substances, disease registry, and other
2 people get involved in identifying toxic effects of the
3 chemicals in all environments. We utilize the
4 information that comes from that; such as, for
5 carcinogens, a thing called a Slope Factor is
6 established which tends to give you an ability in risk
7 assessment basis to weigh the nature of the toxicity of
8 that chemical so that you can incorporate it into the
9 Risk Evaluation at your site. If for some reason
10 additional health studies indicated the Slope Factor
11 was wrong, it could result in a different cleanup goal,
12 both lower and higher. That's about the only way you
13 would see a change. The MCLs are basically what we use
14 for groundwater,'you know, Maximum Contaminant Levels.
15 Some of those are health-based, some of those are
16 technology-based. When we run risk assessment on some
17 of those, they don't come out to be totally protective
18 in our program, but they're an accepted standard
19 throughout the agency for consumption of that material.
20 It's conceivable those could actually go down. If
21 things change in the future, it changes those numbers.
22 And in rare cases it's conceivable, as we develop
23 better knowledge of toxicology, some numbers could go
24 up. But I don't think that's going to be the general
25 trend.
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1 MR. SMITH - On this site.
2 MR. ROGERS - Well, any site. I mean, this is kind
3 of a generic issue. We're using the same toxicology
4 information on this site as we would on any site.
5 MR. SMITH - I realize that.
6 MR. ROGERS - The only difference is the exposure
7 that occurs beneath the site'.
8 MR. SMITH - So, it's definitely been cleaned up?
9 MR. ROGERS - Well, yeah, as far as we're
10 around - - - as long as we're around and as long as
11 there's a program to be implemented. And the DHEC ;
12 people we work very closely with who have a corollary
13 program regardless of whether we continue to be around
14 or not, if there's anything to pursue, the same issues
15 with the same types of approaches to cleanup.
16 MR. SMITH - Is there a time frame?
17 MR. ROGERS - For this site?
18 MR. CHERRY - Can you talk about the bids that went
19 out?
20 MR. ROGERS - For the cleanup or - - -
21 MR. SMITH - Filter and groundwater. Building the
22 air stripper and - - -
23 MR. ROGERS - We didn't want to talk about this
24 because we did want to get feedback on this, but the
V
25 PRP' s basically are ready to out and put this bid on
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1 the street; and they have, in fact, done it within the
2 last day or two.
3 MR. CHERRY - Went out on the seventh.
4 MR. ROGERS - And they're, I mean, as anxious to
5 get this thing built and implemented as anybody, since
6 they are doing this, not Federal funds but - - -
7 MR. SMITH - These are the companies that paid
8 before?
9 MR. ROGERS - Yeah, these are the responsible
10 parties we identified to come in and do the
11 evaluations, the testings, and implement the remedy.
12 They're ready to go and moving forward with the bid
13 process now.
14 MR. SMITH -'And they've explored every
15 possibility? I know going over to Lando was out. What
16 about Fort Lawn? Going down with a pumping station to
17 Fishing Creek and then going back up to - - - if you
18 have to expand on Fort Lawn's treatment system. It
19 would be that much better for the community down there.
20 MR. ROGERS - They explored some other options, the
21 biggest one being Great Falls. And the sewer line
22 isn't there, and they don't really feel an obligation
23 to lay the sewer lines1 10 or 11 miles up to the site.
24 So, I mean, other options as viable as could be
25 perceived were explored.
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1 MR. SMITH - Explored with the idea of maybe some
2 help from local or Federal government to - - - if you
3 had to expand on the sewer treatment system at any time
4 would it be - - - would they explore that possibility?
5 MR. ROGERS - They're not opposed to that. The
6 problem is we don't really have any direct authority to
7 initiate that kind of a process, and the reality of it
8 is: what we're building out there for the material
9 we're going to treat is completely different process-
10 wise than what you would deal with domestic sewage.
11 You're basically pumping water out of the ground that's
12 relatively clear, and the suspended solids basically is
13 a little sand that comes out from the well. Those fall
14 out in the equalization tank, and you basically have
15 clear water at this point that has solubilized
16 contamination. And therefore, the process from there
17 goes fairly simply. Domestic waste systems have to
18 deal with a very large load of solids coming in of a
19 very different nature, and a different treatment
20 process. So, to expand the system basically means to
21 build almost a parallel, totally different process
22 system to deal with domestic sewage.
23 .MR. SMITH - They don't have to fill it in on this
24 site; like I say, pump it to somewhere. I know
25 citizens down the road between here and Lando are
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1 opposed to it.
2 MR. ROGERS - Yeah. Generally, you know, there was
3 so much outcry that - - - we don't want.it pumped '
4 through our neighborhoods to get to the treatment
5 plant, we'd rather see you dump it in the creek. And
6 we have the technology that's available to do that. To
7 reach the standards and monitor it so we feel like it's
8 controllable and safe to discharge to Fishing Creek
9 without causing an undue threat of an exceedance or a
10 significant long-term release. So, we have basically
11 what seems to be the most logical place to go with;it.
12 And it's the quickest to implement.
13 MR. SMITH - Right now?
14 MR. ROGERS - At this point.
15 MS. TUCKER - I want to clarify something that
16 seems to have caused some great alarm. I'm Marlene
17 Tucker, and I'm the assigned attorney for EPA at this
18 site. And, having had the arduous task of trying to
19 piece together all the facts of how the various
20 owners - - - former owners of the site operated so I
21 could make a case to find who the Potentially
22 Responsible Parties are, I can tell you that the manner
23 in which the former owner, SEPCO, operated at the site
24 was very - - - was almost a shuffle game with the
25 waste. In fact, they owned more than one site, so a
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1 lot of waste went not only to the Carolawn site, but
2 all the sites that EPA has had to cleanup. I just
3 wanted to put some perspective on the .disparity between
4 the alleged amount of waste brought to the site - - -
5 drums and waste brought to the site - - - versus the
6 record of waste that was taken off site. A "lot of this
7 information is not hard and fast, and it's really hard
8 to put a premium on the estimated amount of waste that
9 the company brought to the site because the records
10 were so sketchy and, in terms of keeping inventory in
11 the 1970's, that wasn't a priority for the companyi'
12 So, what I really want to stress is that EPA did two
13 thorough removals between '81 and '82 covering the
14 entire site, and'I'm pretty confident that all the
15 drums were removed. We have no reason to think there
16 are any drums that weren't disposed of, taken offsite.
17 And as Jan had said before, if anyone who lived in the
18 community years and years ago who has any additional
19 information about possible drums on the site, you know,
20 please come forward with that information so we can
21 pursue it. But, as far as EPA is concerned, the site
22 is totally clean as to having any drums, and the
23 removal that was conducted in the '80s took care of any
24 drums that were buried or lying around on the site.
25 Thanks.
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1 MR. RAY - I'm Marcus Ray. I'm the mayor of Great
2 Falls. I only have one or two questions for Mr.
3 Cherry. What I would like to know is what the total
4 cost of this operation will be - - - projected total
5 cost of the five-year period. It says here three to
6 five years.
7 MR. CHERRY - Well, you know, since this is not
8 money - - - maybe someone else at the table will know -
9 - - since this is not money that we are spending - - -
10 it's not EPA money. You know, I don't know what the
11 total cost is going to be. What we try to do is make
12 sure that they give us a treatment system that would
13 get the result that we need. So, what we would pay for
14 it, as EPA, private company, you know, we would - - -
15 if we hired Conestoga-Rovers and it cost one thing. If
16 they, a private company, hire them, it doesn't cost
17 half as much as the government. So, I don't know.
18 I've got some estimations that I could reach back - - -
19 and feasibility studies and dig that out.
20 MR. RAY - Where would I find that?
21 MR. CHERRY - It's in the feasibility study in the
22 records. I can dig that out, but it's just still a
23 rough estimation. And this is an estimation that may
24 be in the millions of dollars, but I have to go back
25 and look. Do you happen to know what that is? I don't
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1 remember what that is, but - - -
2 - MR. ROGERS - Let me point out one other
3 sensitivity at this point: PRPs don't particularly
4 like to talk about what they think it will cost while
5 they're in a bidding process. So, you know, we have
6 some general numbers from the feasibility study, we
7 have some experience from other operations, we can
8 guess. We tend to caveat our dollars in terms of the
9 whole process of all five years of operation and
10 maintenance and a number of other considerations. It
11 makes it real difficult for us to really pinpoint a
12 number. And really, you know, there's a good reason
13 why the PRPs don't want to flaunt what they think it's
14 going to cost. You know they have - - - you know, for
15 them to bid it, they've got a contractor's estimate
16 right now of what it's going to cost them. But they're
17 not going to disclose that at this point in time.
18 MR. RAY - In the time span to pump these wells, as
19 I understood it when we were discussing it before, was
20 30 years or more. Now they're saying three to five.
21 MR. ROGERS - Yeah. For comparison reasons we
22 sometimes use that 30-year figure and just put all the
23 different considerations and various remedies in an
24 equal light. But, you know, nobody really knows how
25 long this pump and treat will last.
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1 MR. RAY - This was in our waste water boundary,
2 that's the reason I'm concerned. Another question is
3 operators - - - onsite operators. Mr. Cherry said
4 operators. Going to be one operator? Going to be an
5 around-the-clock operator? Is it a fully automated
6 plant?
7 MR. CHERRY - All that I know is that it would be a
8 certified wastewater treatment plant operator or water
9 treatment operator, and they will have - - - it's an
10 automatic system that will run 24 hours. What they
11 will do, they will work it out as to how much time :they
12 want this operator to spend at this site. Now, this
13 will be spelled out before we get into it, and if
14 there's some peop~le that are involved, we would give
15 that information to them.
16 MR. RAY - Well, as you and I know, automated
17 equipment can fail.
18 MR. CHERRY - No, it's not - - - automatic - - -
19 you know, it's not what it says. But, you know, they
20 are supposed to run it and they will have a start up,
21 they will hire people to be there, and it will be
22 determined how much time that this operation is going
23 to have to be there. Because we're also concerned
24 about, like you asked, there's going to be a security
25 problem, too. You put all this equipment out there,
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1 you just can't leave it out there. People shoot tanks.
2 I mean, it happens.
3 MR. RAY - Wastewater, that's my concern. How
4 much waste we're going to have spilled on the ground
5 before that alarm goes - - -
6 MR. CHERRY - Yeah, well, they're going to have to
7 sit down and - - -
8 MR. RAY - You people are going to police them
9 closely, is that what you're telling me?
10 MR. CHERRY - Well, it will be State, it will be
11 community, it will be all of us.
12 MR. ROGERS - One of the things that - - - we're
13 having to deal with this in a lot of pump and treat
14 systems related to Superfund on the groundwater, but
15 we're also having to deal with it from the underground
16 storage tank program and other methods or programs
17 where they're implementing small, confined pump and
18 treats. The technology and the computerization and the
19 electronics have evolved to such an extent that
20 basically the people who monitor and deal with operator
21 control of wastewater treatment plants are recognizing
22 some flexibility as to bring the plant up, show me that
23 you've got the duplicity and triplicate backups and
24 various things that electronically will shut the system
25 down should something go wrong, and demonstrate it on
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1 the early phase of the operation of the unit, and we
2 will show some leniency on whether you have to have a
3 full time operator sitting there 24 hours a day to
4 watch a relatively simple operation. So, you know,
5 it's an evolving science at this point. The technology
6 certainly is there that allows it to be done. Yes,
7 there are upsets occasionally where the technology
8 fails but, in a relative sense, this water is not toxic
9 directly. The reason we're dealing with it is long-
10 term consumption of this groundwater would be
11 considered to be adverse to people's health, so we;feel
12 like we should 'remediate the problem. If I drank a
13 little of it, it's not expected that it would have a
14 significantly adverse effect, so a spill would not
15 necessarily immediately cause an adverse effect. We
16 are really addressing the groundwater because if
17 somebody started to use that as a water supply and
18 tried to consume that water for a long period of time,
19 we do feel like it would have an adverse effect on
20 their health.
21 MR. HAYNES - It'll have a For example, the
22 old requirement to monitor - - -
23 MR. RAY - Do you have a pump - - -
24 MR. HAYNES - - - - the operator comes there daily
25 to inspect it and monitor that tells them what the
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1 flows are and all that. Licensed operator will have
2 to come in every day and inspect it, make sure
3 everything is working. If it shuts down any time an
4 operator has to come out before they can even start
5 back up.
6 MR. RAY - Wait a minute. I've got the mike. What
7 I'd like to know if you have another plant similar that
8 you could give me a cost on that plant. I'm sure
9 nationwide there must be - - -
10 MR. ROGERS - Could we do that privately?
11 MR. RAY - Well, you can write me a letter. She
12 has my card. MS. LISENBY - It's a public meeting and
13 the public's right to know.
14 MR. RAY - What I'm concerned about also is how
15 widespread is the aquifer under there where these wells
16 are drilled? Are they all the same depth? Are they
17 step drilled in different zones, or what? How
18 widespread is it underground?
19 MR. ROGERS - We do have experience with - - - let
20 me see if I can figure out what the question is. I
21 guess some discussions took place yesterday about a
22 similar system we have down near Columbia which we
23 implemented. It had some problems that caused the cost
24 to go up a little bit based on problems that occurred
25 along the way, but were not related to the technology
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1 or anything. But the bid was about two million dollars
2 for a system to go in that would - - - I don't know,
3 volume-wise it's probably in a similar size for
4 handling water flow, 10 to 20 gallons a minute. And it
5 was for operation for three or four years, was the
6 estimated life of that system. And that factors in
7 subcontractor costs and do you have an operator on the
8 site and do a number of other things. The hardware
9 costs really don't necessarily amount up to that much.
10 The design cost and some of the other labor of
11 continuing to visit the site on a periodic basis -;- -
12 MR. RAY - Through the years. You says it's
13 between three and five years, taking more than five
14 what would it cost?
15 MR. ROGERS - I don't really have a number for you
16 offhand on that. We can dig up some information for
17 you.
18 MR. RAY - Much safer and more secure than to have
19
20 MR. ROGERS - Well, as we learned last time,
21 there's pros and cons to that argument, but, yeah.
22 MR. RAY - That's all I had.
23 MS. BRYAN - My name is Nita Bryan, I live in
24 Edgemoor. I want to thank EPA and congratulate you on
25 your treatment center that's going in. I have a
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1 comment and a question. One, I thank y'all for going
2 with us today, especially John and Cynthia trucking
3 over there to the property. I got concerned. I wasn't
4 even going to speak, and then I heard again that there
5 are no more contaminants at this site, there's no more
6 drums. And I just want to say that I was there today.
7 Unless someone came in and cleaned them up after I left
8 today, they're still there. And there's materials that
9 are not identifiable in large quantity, and things that
10 neither Yvonne nor Cynthia could tell us what they
11 were. I'm not trying to put y'all on the spot, but
12 they did not know. There were drums under the ground,
13 you could see the edges of them. We stepped on them
14 and pushed them, 'they appeared to have been there for a
15 long time. So, there's still contaminants of some
16 sort. I don't know what they are, but they are there.
17 And although there have been two site cleanups, as I
18 understand from the report, they're still there after
19 all that groundscraping and all that removal. But my
20 question is that I'm hearing that the community is
21 saying, well, we want you to do continued testing, and
22 that/jyou're in agreement that we could do that. And
i';
23 yet,5(.after we talked today, my impression from you was
24 that there really isn't any money left to do that
25 testing. I guess I'd ask you to disclose that to the
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1 community as to whether or not there really is any more
2 finances to support any further testing of the other 60
3 acres.
4 MR ROGERS - Currently our status of where we are
5 in funding is sort of questionable. With budget cuts
6 and other things going on there was a recision bill
7 that was passed this year to basically pull back some
8 monies that were already allocated for 1985 - - - or,
9 1995. Which, at this point in the year, may not have
10 actually been spent anyway. But we did, in fact, as a
11 Region, shut down some starts of some sites in other
12 states that were ready to be started, because of that
13 effort to pull back the money and reduce spending for
14 the current fiscal year. As far as we know, we have
15 funds next year. We don't know how long we have them,
16 and we have other dilemmas to deal with. We, like
i •
17 every other Federal agency, have to be appropriated
18 money every year. We, unfortunately, also - - -
19 because of Superfund - - - have the dilemma of dealing
20 with a law that - - - the law really doesn't expire,
21 but part of it does, the part that collects the tax
22 that generates the money to fund the program. That
23 being the case, the program could go on if there's
24 money in the trust fund to continue on, but we don't
25 really know what's going to play out as far as
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1 reauthorization, when will it be reauthorized and what
2 kind of restraints will occur before the
3 reauthorization of Superfund. That being the case, it
4 makes us hard to commit to specifically saying we could
5 get our hands on money to do the kinds of investigation
6 we'd have to do. We certainly would try. And it would
7 certainly be hinged on right now we're going to have to
8 start prioritizing everything to the worst-case-first
9 scenario. That being the case, further investigation
10 of this site might not break out as the worst-case-
11 first scenario if there are limited funds. We don't
12 have the answer, that's the bottom line. We would try
13 to get the funds, we would try to go forward, we could
14 do some things in-house of a limited nature with our
15 existing resources in-house, but there are a lot of
16 caveats out there that could impact adversely our
17 ability to continue to do that. If we had some solid
18 leads, we can also work through DHEC to try to pursue
19 some things that way, too. It's an unanswerable
20 question but, I mean, there are options available that
21 we would continue to do along. Right now we're not
22 looking total doom and gloom. We think we'll have
23 fun.ds, and we think if there' s a legitimate need we can
24 go forward and investigate those things. But it's a
25 little more questionable at this point than it
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1 typically has been in the past.
2 MR. CAMP - My name is Don Camp, and I live in
3 Great Falls. From what I read here about the
4 contaminated water, it's no great risk to anyone right
5 now. Okay. If we're going to treat it and we're going
6 to say it's no great risk, then I'm wondering, are we
7 moving it from Fort Lawn/Richburg area and place it in
8 Fishing Creek and hoping the dilution will do a whole
9 lot. And that's my question. If that be the case, I
10 think we could contain it and dilute it in the Catawba
11 River, and the dilution would be much greater because
12 if you're familiar with Fishing Creek, that water gets
13 about this deep in areas, and all water flows to the
14 south from the area we're in. So, I really think we
15 should think again about putting it in Fishing Creek
16 right now. For the preservation of the southern farms.
17 MR. ROGERS - Certainly, as we've discussed, we
18 don't intend to dilute it in the creek, we intend to
19 treat it down to acceptable discharge level before that
/
20 option, just like any discharge for any facility would
21 be required to do.
22 MR. CAMP - Don't you ordinarily have discharges
23 though that have been fined because they're over limits
24 or - - - I mean, don't EPA and DHEC ordinarily have
25 unauthorized discharges?
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1 MR. ROGERS - Sure.
2 MR. CAMP - Okay. That's
3 MR. CHERRY - But this system is almost what they
4 call an advanced waste treatment system. The carbon
5 and the types of technology - - -
6 MR. CAMP - Almost? It is, or almost?
7 MR. CHERRY - Oh, it is. It is.
8 MR. CAMP - Well, you said it was almost - - -
9 MR. CHERRY - Yeah, but what I'm saying - - - I
10 hate to say it - - - well, it is when you start talking
11 about activated carbon and the type of technology - - -
12
13 MR. CAMP - When you talk of activated carbon, have
14 we found any carbon in the water?
15 MR. CHERRY - No, I mean activated carbon to remove
16 the impurities.
17 MR. CAMP - Remove them?
18 MR. CHERRY - Yeah.
19 MR. CAMP - Okay, so it would remain in the
20 carbon - - -
21 MR. CHERRY - Right.
22 MR. CAMP - - - - to be placed in another area.
23 MR. CHERRY - Well1, it would either -be generated or
24 - - - well, yeah, it would.
25 MR. CAMP - Okay. And when you speak of solids - -
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1 - we're speaking of water, so when we speak of solids,
2 what are we speaking of? Are we speaking of the mud,
3 the sediment, what type solids are we speaking of?
4 MR. CHERRY - No, we're speaking of the things that
5 are coming out. Actually, there's some of the
6 contaminants in the solids that's - - - you know, so,
7 actually a lot of this stuff is coming out in the
8 solids.
9 MR. CAMP - What type solids?
10 MR. CHERRY - Well, the volitus.
11 ' MR. CAMP - What solids?
12 MR. CHERRY - Well, it's basically only probably
13 five percent, 95 percent water.
14 MR. CAMP - What is it?
15 MR. ROGERS - Suspended solids from the well.
16 Particles from the well.
17 MR. CAMP - Suspended solids?
18 MR. ROGERS - Many - - - now, soil particles from
19 the well, because you're pumping the well and picking
20 up at least, because of the disturbance, some suspended
21 solids related to the material in the well.
22 MR. CAMP - Primarily mud?
23 MR. ROGERS - Not necessarily. Properly installed,
24 it wouldn't be mud.
25 MR. CAMP - Silt?
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1 MR. ROGERS - Probably silt and sand.
2 MR. CAMP - Silt and sand. Okay, that answered my
3 question.
4 CONGRESSMAN SPRATT - I've been asked these
5 questions individually. I'm John Spratt, and I'm the
6 Congressman who represents this District. We may as
7 well put it on the record to get some answers. First
8 of all, I think I knew this outfit, SEPCO. In fact, I
9 was about to sue them because they owned the plant up
10 near River Hills.
11 MS. PEURIFOY - You're talking about Hinson? ;
12 CONGRESSMAN SPRATT - Yeah. Hinson, is that the
13 name of it now?
14 MS. PEURIFOY - Correct. Vaughn Hinson owns the
15 company.
16 CONGRESSMAN SPRATT - Vaughn Hinson, that's exactly
17 right, yeah. We went there one day because every time
18 it rained these chemical fumes rose from the ground and
19 wafted all over the subdivision and people didn't know
20 what the problem was until I went there with an
21 engineer and we found an Austrian chemist by the name
22 of Behr (phonetic) . Maybe you found his name in the
23 records. I remember the guy.
24 MS. TUCKER - In fact, we tried to locate him.
25 CONGRESSMAN SPRATT - You have found him?
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1 MS. TUCKER - No, we've lost trail of him.
2 CONGRESSMAN SPRATT - Well, he was pretty
3 forthright, because I think he was about to be fired;
4 not because he was incompetent, but because I think
5 they were running pretty low on gas at that time. But
6 he explained the problem to us, and it was that they
7 were draining these residues from the North Carolina
8 furniture industry into this particular plant and they
9 were separating out the paint remover from the paint
10 sludge in the paint remover and reselling the paint
11 remover to the furniture industry. And then they had
12 the sludge left over, and they were shipping it down
13 here. He said every time they brought a barrel
14 in - - - a 55-gallon drum in - - - and get it off the
15 back of the truck, and there were no regular means of
16 conveyance, they tended to spill it on the site, all
17 over the site. And then anytime the - - - once they
18 got enough of that stuff spilt over the site it made it
19 pretty slick, and they would call Rock Hill Concrete
20 Company and say send them another load of gravel and
21 they'd just gravel over everything. So, the chemicals
22 were seeping down into the ground. That was a problem
23 up there, but it suggests the kind of way they did
24 business and raises some questions about this site down
25 here. I also happen to have a next-door neighbor who
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1 was kind of hard up for a job, and he had the job of
2 running the site down here for a short while. I'm not
3 sure the fire occurred when he was there. His~ name was
4 was Gregory, maybe you've seen his name somewhere. He
5 told me once a gruesome story of a dog who'd got
6 caught, stuck up in the goo, the viscous mess on the
7 back of this site. He said he almost killed the dog,
8 almost shot him. He was able to get it free, and I
9 think he brought the dog home with him for a time. But
10 that suggested to me that there was a lot of stuff
11 left. The image, the mental picture I have from the
12 way he described it, was that there was this viscous
13 sludge on a good part of the site, enough so that a
14 curious dog wandered into it and got mucked up in it;
15 and he couldn't get out, it was so deep and so sticky.
16 For whatever that's worth, I put that on the record.
17 Now, I'm interested in exactly, legally, where we
18 stand here. If this is the agreed upon remediation
19 solution, are the PRPs released by court order once
20 this solution is agreed upon as the remediation
21 solution for this site?
22 MS. TUCKER - Well, there are PRPs known as the
23 Carolawn Steering Committee, comprised of a group of
24 generations that were customers of the Carolawn Company
25 during the time that they owned the site. And their
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1 operating constraints consent decree which has been
2 entered in the District Courts that they have agreed to
3 conduct the remedy and pretty much build the system.
4 So, they're operating pursuant to an agreement with
5 EPA.
6 CONGRESSMAN SPRATT - Do they then go back to the
7 court and submit to the court this proposed solution,
8 and if EPA finds it to be an adequate solution you sign
9 off on the consent decree and then this becomes the law
10 of the case, there's no further remedy available? If
11 there's water contamination later found on the site,
12 you can't go back to the PRPs?
13 MR. ROGERS - Let me answer that. This is a unique
14 case. Most Superfund sites, yes, that's the case. I
15 was just alluding that this is a unique case in the
16 sense that we do have a consent decree for this cleanup
17 with the Carolawn group, but it's a partial consent
18 decree. Most sites would have a complete consent
19 decree that takes the site totally to conclusion and
20 provides for covenants and other waivers at the end
21 that you've done everything necessary to deal with this
22 site. The consent decree in place here, because of the
23 nature of the SEPCO operation versus the Carolawn
24 operation - - - and they were very much divisible,
25 especially after the drums and waste were pushed
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1 outside of the fenced area in Carolawn and continued to
2 work just inside of the fence - - - the Carolawn PRPs
3 made an argument that it wasn't fair for them to do all
4 this work. They would commit to designing and building
5 the pump and treat system, so we have a consent decree
6 lodged in court, entered in court, that carries them
7 through to operational activities at the pump and
8 treat. We don't have a consent decree in final form
9 that would settle the long-term operation and
10 maintenance at this site, because they wanted us to
11 bring in the SEPCO parties. And we did bring in the
12 SEPCO parties, and we did have an agreement, and we've
13 actually lodged a consent decree to deal with a joint
14 deal where SEPCO'parties - - - some SEPCO parties - - -
15 and the Carolawn group would continue on with the site,
16 with this activity. Unfortunately,. Hinson has now come
17 up, and the SEPCO people over at Hinson are a little
18 upset that they didn't realize they would - - - they
19 think they have double exposure. Nobody knows and can
20 account for where these drums actually ended up but, in
21 fact, their names show up in two places, and they feel
22 like that's a little unfair. They've caused us to
23 reevaluate where we are on that lodged consent decree.
24 So, this is still an open issue that we have to deal
25 with through some negotiations and some other matters
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1 that relates to Hinson, as well as - - -
2 CONGRESSMAN SPRATT - But if you finally settle
3 upon this as the remediation solution for this site, is
4 that final? Does it exonerate them from further
5 responsibility?
6 MR. ROGERS - Only related to the matters at hand.
7 And if this waste is somewhere else on the site, new
8 activity, totally unknown, it's conceivable we have an
9 opener in there. But, no, if - - - yes, if they - - -
10 if we found drums right under the site, we'd have a
11 problem. It'd be a fund-lead activity, they'd be ••-
12 exonerated. We don't expect that to be the case, but
13 we've tried to craft that in a narrow enough language
14 that it's matters at hand as identified. The public
15 here will want to look at the 60 acres, we've
16 identified the site as originally as a five to seven
17 acre site, so that's really what the investigation has
18 dealt with. I think we would have room to open one of
19 the others, the remaining part of the 60 acres.
20 CONGRESSMAN SPRATT - Now, to what extent does the
21 completion of this task depend upon EPA funding? How
22 much of this comes out of the PRP's pocket for
23 completion? What level of funding - - - to what extent
24 is the consummation of all this dependent upon your
25 being fully funded?
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1 MR. ROGERS - They're paying all the bills, and our
2 consent decree has them reimbursing us for our cost to
3 oversee all activities. We have to expend it out-of-
4 pocket and - - -
5 CONGRESSMAN SPRATT - Yours is mainly an overhead,
6 an oversight expense - - -
7 MR. ROGERS --Yes.
8 CONGRESSMAN SPRATT and how far you
9 can - - -
10 MR. ROGERS - At this point.
11 CONGRESSMAN SPRATT - Okay.
12 MR. ROGERS - If we trigger other investigations
13 outside of what we know as the site - - -
14 CONGRESSMAN'SPRATT - You've got to have the money
15 to undertake that?
16 MR. ROGERS - Yeah. That could be a fund-lead
17 activity, because I think we'll see a little resistance
18 from this group.
19 CONGRESSMAN SPRATT - Yeah.
20 MR. ROGERS - And therefore it does potentially
21 impair our ability to follow through on relevant leads.
22 CONGRESSMAN SPRATT - Well, you were polite enough
23 not to be specific, but the appropriation bill that
24 passed the House of Representatives, I did not vote for
25 it, if I can make that clear for the record. It would
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1 cut EPA's budget by 37 percent next year/ and it would
2 almost certainly have an impact on the conduct of
3 activities like that. Now, let's hope that doesn't
4 pass, but it certainly passed the House of
5 Representatives, so it doesn't indicate that you'll get
6 funded at the President's level of request for the next
7 fiscal year. That could truncate some of these
8 activities, that's what I understand you to say.
9 MR. ROGERS - Yeah, our guess is that that's a
10 signal that we think the Senate will moderate a little
11 bit, but we guess we're going to get a significant cut.
12 And that cut will impair our ability to deal with
13 everything on the plate, let alone new work. And we
14 don't know what extent that is until we find out what
15 the budget is. We have a double jeopardy. We have,
16 really, a problem with the reauthorization of
17 Superfund. The appropriation bill specifically - - -
18 Superfund says, you can have this money next year, but
19 you can't spend it past December 31st. If that goes
20 through and - - - you know, Superfund's probably a good
21 program to have a confrontation over; let's shut it
22 down for a while and see what happens. In retrospect,
23 in 1986--- I've been in this program for 21 years.
24 Emergency response and then this part, more
25 recently - - - in 1986 we suffered some severe damage,
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1 and probably a two to three year recovery period,
2 because of people who left over an unfunded issue with
3 reauthorization of Superfund. That's our concern.
4 CONGRESSMAN SPRATT - Thank you very much for
5 coming.
6 MS. JONES - Basically, I'd like to thank everyone
7 for being patient with me, so to speak. And, too,
8 Anita, do not worry about putting me down. You are
9 here to address and also - - - not to address but, for
10 the most part, give us your concern. I did go out to
11 the site with Anita and Donna today, actually Cynthia
12 and myself, and she is right, we did see what I would
13 call tops of drums, so to speak, what I would call
14 debris. Something that I did tell her that a lot of
15 times - - - I don't know exactly what it is, but a lot
16 of times when people see - - - this is really
17 interesting to me - - - but a lot of times when people
18 see either drums, or they know it's a Super fund site
19 or, you know, even like I said we have storage tanks
20 out there that we're using for our activities, their
21 perception is that it is hazardous. As I stated
22 before, we have tested the soil. We didn't test the
23 drum tops, you're right. That's something that we're
24 probably not going to do. But I also told her that we
25 do keep open - - - as if, for some odd reason, we do
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1 give what we would call a relevant - - - and I don't
2 know if you want to call it an inquiring, or someone
3 that actually says, I know it's here or we think it's
4 here. That's something that we will follow up on. I
5 know I also went out to the site with Mr. Nichols today
6 and, you know, he was considered an eyewitness. It
7 sort of, I guess, puts, you on the spot; but, again, I
8 did not hear that there were buried drums. And really,
9 at all times we would like to keep the channels open.
10 If you know someone who may not be here tonight but
11 who, you know, maybe was there when everything took
12 place, that, you know, has a pretty good feeling that -
13 - - I shouldn't say a good feeling - - - he knows - - -
14 he or she knows that they buried drums - - - not just
15 anywhere on the site, but they know that those drums
16 were buried or they saw where those drums were buried,
17 we would like to talk to them. But, basically, we
18 haven't heard that from the public. We have, you know,
19 people saying that, there's rumors, but we haven't
20 actually - - - we haven't actually had a person that
21 has said, there are buried drums on this site, and this
22 is where they are. We just haven't had that. Again,
23 anybody that you know or that may know something about
24 that, we would be interested in knowing that. But,
25 without that, I mean, we don't really have anything to
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1 follow up on. Thank you.
2 MS. PEURIFOY - Anybody else have anything to say?
3 We'd like to thank you for coining out tonight. All the
4 comments and questions and concerns that have been
5 raised tonight will be put into a document - - - and
6 it's called the Responsiveness Summary - - - that will
7 part of the Record of Decision. That will be placed in
8 the Information Repository. I will be sending you out
9 a notice when the final decision is made and let you
10 know what's going to happen next. Thank you for
11 coming,
12
'13
14
15
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CERTIFICATE OF REPORTER
State of South Carolina )
)
County of York )
I, Susan Wachsmuth, CVR, do hereby certify that
the aforesaid deponent was placed under oath; that I
reported by Stenomask the foregoing proceedings at the
time and place herein designated; that my tape was
thereafter reduced to typewriting under my supervision;
and that the foregoing pages numbered _^r through
fag' , inclusive, are a true, accurate and correct
transcript of the aforesaid proceedings.
I further certify that I am not a relative,
employee, attorney or counsel of any of the parties,
nor relative or employee of such attorney or counsel,
nor in anyway interested in the event of said cause.
This the^-/ day of c^^/3'7 . / 1995, in the
City of Rock Hill, County of York, State of South
Carolina.
Susan Wachsmuth, CVR
Court Reporter
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