Superfund Record of Decision Beaunit Circular Knit and Dyeing Corporation Fountain Inn South Carolina


                                    EPA/ROD/R04-95/254
                                    1995
EPA Superfund
     Record of Decision:
     BEAUNIT CORP. (CIRCULAR KNIT & DYEING PLANT)
     EPA ID: SCD000447268
     OU01
     FOUNTAIN INN, SC
     09/29/1995

-------
           RECORD OF DECISION
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
     BEAUNIT CIRCULAR KNIT & DYEING
             SUPERFUND SITE
     FOUNTAIN INN, GREENVILLE COUNTY
             SOUTH CAROLINA
           
              PREPARED BY:
   U.S. ENVIRONMENTAL PROTECTION AGENCY
               REGION IV
           ATLANTA, GEORGIA
          SEPTEMBER 29, 1995

-------
DECLARATION FOR THE RECORD OF DECISION

SITE NAME AND LOCATION

Beaunit Circular Knit & Dyeing
Fountain Inn, Greenville County, South Carolina

STATEMENT OF BASIS AND PURPOSE

This decision document presents the selected remedial action for the Beaunit Circular Knit & Dyeing
Superfund Site (the Site) in Fountain Inn, 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 seg., and, to the extent
practicable, the National Oil and Hazardous Substances Contingency Plan (NCP), 40 C.F.R. Part 300 et seg.
This decision is based on the administrative record file for this Site.

The State of South Carolina concurs with the selected remedy.

ASSESSMENT OF THE SITE

Actual or threatened releases of hazardous substances from this Site, if not addressed by implementing
the response action selected in this Record of Decision (ROD), may present an imminent and substantial
endangerment to public health, welfare, or the environment.

DESCRIPTION OF THE SELECTED REMEDY

This remedial action addresses on-Site soil contamination.

The major components of the selected remedy include:

• Containment of soils and sediments contaminated with volatile organic compounds (VOCs) and
metals by capping of the lagoon area.

• Additional monitoring of groundwater and soils on a regular schedule to determine effects of
construction of lagoon cap, and to insure effectiveness of cap after constuction. Modifications
to the freguency or termination of continued monitoring will be determined during the Remedial
Action and the Five Year Review.

DECLARATION

The selected soil and groundwater remedy is protective of human health and the environment, complies with
Federal and State reguirements that are legally applicable or relevant and appropriate to the remedial
action, and is cost effective. This remedy utilizes permanent solutions and alternative treatment
technology to the maximum extent practicable for this Site. The selected remedy component satisfies the
preference for treatment. The remedy is protective of human health and the environment and meets
statutory findings.

Because selection of this remedy will result in contaminated soil remaining on-Site above health-based
levels while limiting exposure and mobility, a five year review will be conducted after commencement of
remedial action to ensure that the remedy continues to provide adeguate protection of human health and
the environment.

Richard D. Green Date
Associate Director
Office of Superfund & Emergency Response

-------
                              TABLE  OF CONTENTS

SECTION                                                            PAGE

  1.0   INTRODUCTION 	   1

  2.0   BEAUNIT NPL SITE LOCATION AND DESCRIPTION 	   1
        2.1     Site Location 	   2
        2.2     Topography 	   2
        2.3     Meteorology 	   3
        2.4     Regional Geology 	   3
        2.5     Regional Hydrogeology 	   5

  3.0   SITE  HISTORY AND REGULATORY HISTORY 	   6
        3.1     Site History 	   6
        3.2     Regulatory History 	   9

  4.0   HIGHLIGHTS OF COMMUNITY PARTICIPATION 	  10

  5.0   SCOPE AND ROLE OF THIS ACTION WITHIN SITE STRATEGY 	  11

  6. 0   SUMMARY OF SITE CHARACTERISTICS 	  12
        6.1     Surface Water Hydrology 	  12
        6.2     Site Hydrogeology 	  12
        6.3     Site Geology 	  14
        6.4     Site Soils 	  14
        6.5     Site Biota 	  15
        6.6     Vegetation 	  15
        6.6.1   Mixed Hardwood-Pine Forest 	  16
        6.6.2   Old Field/Scrub/Pasture 	  18
        6.7     Aguatic Life 	  18
        6.8     Wetland Resources 	  18
        6.9     Wildlife 	  19
        6.9.1   Endangered, Threatened,  and Special-Concern
                   Species 	  20

  7.0   SUMMARY OF SITE RISKS 	  20
        7.1     Remedial Investigation 	  20
        7.1.1   Remedial Investigation Field Activities 	  21
        7.2     Remedial Investigation Conclusions 	  22
        7.3     Summary of Risk Assessment 	  31
        7.3.1   Human Risk 	  31
        7.3.2   Environmental Risk 	  32
        7.3.3   Exposure Pathways & Receptors 	  34

        DESCRIPTION OF REMEDIAL ALTERNATIVES 	  35
        8.1     Scope of the Remedial Action 	  35
        8.2     Remedial Goal Options for Groundwater 	  36
        8.3     Remedial Goal Options for Surface Soil 	  36
        8.4     Development of Alternatives 	  37
        8.5     Summary of Alternatives 	  39
        8.5.1   No Action  (Alt-1) 	  39
        8.5.2   Groundwater,  Surface Water & Sediment Monitoring/
                Groundwater Use Restrictions/Deed Restrictions
                (Alt-2)  	  42
        8.5.3   Groundwater,  Surface Water, and Sediment Monitoring/
                Grading-Drainage Control-Capping of Site and Deed
                Restrictions
                (Alt-3)  	  43
        8.5.4   Groundwater Pumping and Treatment/Grading & Drainage
                Control-Capping of Site and Deed Restrictions
                (Alt-4)  	  44
        8.5.5   Groundwater,  Surface Water, and Sediment
                Monitoring/Excavation of "Hot Spots", Off-Site
                Disposal and Deed Restrictions
                (Alt-5)  	  48

-------
      8.5.6   Groundwater Pumping and Treatment/Excavation of
              "Hot Spots",  Off-Site Disposal and Deed Restrictions
              (Alt- 6)  	   50
      8.5.7   Groundwater,  Surface Water and Sediment
              Monitoring/Excavation of Site Surface Soils and Fill
              Area and Offsite Disposal
              (Alt-7)  	   52
      8.5.8   Groundwater Pumping and Treatment/Excavation of Site
              Surface Soils and Fill Area and Off-Site Disposal
              (Alt-8)  	   54

9.0   COMPARATIVE ANALYSIS  OF ALTERNATIVES 	   56
      9.1     Overall Protection of Human Health and the
              Environment 	   56
      9.2     Compliance with Applicable or
              Relevant and  Appropriate Reguirements (ARARs)  	   57
      9.3     Cost 	   58
      9.4     Implementability 	   58
      9.5     Short Term Effectiveness 	   59
      9.6     Long Term Effectiveness and Permanence 	   60
      9.7     Reduction of  Toxicity, Mobility,  and Volume 	   61
      9.8     State Acceptance 	   62
      9.9     Community Acceptance 	   62
10.0  SELECTED REMEDY 	   62
      10.1    Preferred Alternative Summary 	   62
      10.2    Applicable or Relevant and Appropriate
              Reguirements  (ARARs)  	   64
      10.2.1  Applicable Reguirements 	   64
      10.2.2  Relevant and  Appropriate Reguirements 	   65
      10.2.3  "To Be Considered" and Other Guidance 	   65
      10.2.4  Other Reguirements 	   80
      10.4    Statutory Determinations 	   81
      10.4.1  Protection of Human Health and the Environment ....   81
      10.4.2  Applicable or Relevant and Appropriate
              Reguirements  (ARARs)  	   82
      10.4.3  Cost Effectiveness 	   82
      10.4.4  Utilization of Permanent Solutions,
              and Alternative Treatment Technologies or
              Resource Recovery Technologies to the
              Maximum Extent Practicable 	   83
      10.4.5  Preference for Treatment as a
              Principal Remedy Element 	   83

-------
LIST OF FIGURES

Figure                                                             Page

1-Regional Topographic Map 	   4
2-Possible Locations of Wastewater Treatment Units 	   7
3-Streams & Ponds Near Be&unit Lagoon Site 	  13
4-Location a Distribution of Cover Types
     Near Be&unit Lagoon Site 	  17
5 & 6-Surface Water a Sediment Sample Locations
     with Analytical Data 	 23,24
7-Lagoon Surface Water and Sediment Sample
     Locations with Analytical Data 	  25
8, 9,  10-Monitoring Well Locations and Analytical
     Data of Groundwater Samples 	 26,27,28
11 & 12-Surface Soil Sampling Locations and
     Analytical Data 	 29,30
13-Conceptual Design and Location of Cap 	  45

LIST OF TABLE

Table                                                              Page

1-Baseline Risk Assessment Summary 	  33
2-Remediation Goal Options For Surface Soil 	  38
3-Remediation Goal Options For Groundwater 	  38
A-Remedial Action Alternatives 	  40
5-Comparison of Total Present Worth Costs for
     Remedial Alternatives 	  41
6-Remedial Technology Cost Estimates-Alternative 3 	  46
7-Federal Chemical-Specific ARARs 	 66-67
8-State Chemical Specific ARARs 	 68-69
9-Federal Action-Specific ARARs 	 70-74
10-State Action-Specific ARARs 	 75-76
11-Federal Location-Specific ARARs 	  77
12-Guidelines To Be Considered 	 78-79
APPENDICES

     APPENDIX   A   -  STATE LETTER OF CONCURRENCE

     APPENDIX   B   -  RESPONSIVENESS SUMMARY

     APPENDIX   C   -  PROPOSED PLAN

     APPENDIX   D   -  PUBLIC NOTICE OF PUBLIC COMMENT PERIOD

     APPENDIX   E   -  TRANSCRIPT OF PROPOSED PLAN PUBLIC MEETING

-------
                   LIST OF ACRONYMS AND ABBREVIATIONS
AOC
ARAR
BLS
GAG
CDM FPC
CERCLA
CFR
cf s
CLP
CRDL
CRQL
CWA
DQO
EEI
EPA
ES
BSD
FCR
FPDWS
FS
FSDWS
FSP
FWQC
GC
gpd
GPR
hr
HSWA
in
kg
L
MCL
MCLG
MDRD
ug
mm
MS
MSB
MSL
NCP

NOAA
NPL
OVA
PCB
PEL
ppb
PPM
PSCS
PVC
QA
QAPP
QC
RCRA
RfC
RfD
RI
RPD
RRF
SAP
SARA
SCDHEC
SCS
SDWA
Administrative Order by Consent
Applicable or Relevant and Appropriate Reguirements
below land surface
Carcinogen Assessment Group
CDM Federal Programs Corporation
Comprehensive Environmental Response,  Compensation and Liability Act of 1980
Code of Federal Regulations
cubic feet per second
Contract Laboratory Program
Contract Reguired Detection Limit
Contract Reguired Quantification Limit
Clean Water Act
Data Quality Objectives
Environmental Exploration, Inc.
Environmental Protection Agency
Engineering-Science, Inc.
Environmental Services Division
Field Change Reguest
Federal Primary Drinking Water Standards
Feasibility Study
Federal Secondary Drinking Water Standards
Field Sampling Plan
Federal Water Quality Criteria
gas chromatograph
gallons per day
ground penetrating radar
hour
Hazardous and Solid Waste Amendments of 1984
inch
kilogram
liter
Maximum Contaminant Levels
Maximum Contaminant Level Goals
Minimum Detectable Relative Difference
microgram
millimeters
matrix spike
matrix spike duplicate
mean sea level
National Oil and Hazardous Substances Pollution
Contingency Plan; Final Rule, 8 March 1990
National Oceanic and Atmospheric Administration
National Priorities List
Organic Vapor Analyzer
polychlorinated biphenyl
Permissible Exposure Limit
parts per billion
parts per million
Preliminary Site Characterization Summary
polyvinylchloride
Quality Assurance
Quality Assurance Project Plan
Quality Control
Resource Conservation and Recovery Act
Reference Concentration
Reference Dose
Remedial Investigation
Relative Percent Difference
Relative Response Factor
Sampling and Analysis Plan
Superfund Amendments and Reauthorization Act of 1986
South Carolina Department of Health and Environmental Control
Soil Conservation Service
Safe Drinking Water Act

-------
SMCL             Secondary Maximum Contaminant Level
SOW              Statement of Work
SVOC             Semivolatile Organic Compound
TBC              to be considered
TC               Toxicity Characteristic
TCLP             Toxicity Characteristic Leaching Procedure
TDS              Total Dissolved Solids
TLV              Threshold Limit Value
TOt              Total Organic Carbon
TSS              Total Suspended Solids
TWA              Time Weighted Average
USDA             U.S.  Department of Agriculture
USGS             U.S.  Geological Service
VOC              Volatile Organic Compound

-------
1.0 INTRODUCTION

The United States Environmental Protection Agency (EPA) is issuing this Record of Decision for the
Beaunit Circular Knit & Dyeing Superfund site in Fountain Inn, South Carolina. This Record of Decision
presents the alternatives that the EPA has considered for the surface soil and groundwater contamination
found at the Beaunit site.

EPA, in consultation with South Carolina Department of Health and Environmental Control (SCDHEC),
selected this final remedy for the site after publication of a Proposed Plan, a Public Meeting, and a
Public Comment period of two months. The fact sheet and notice of the Public Meeting were mailed to
those on a mailing list developed during initial public participation activities including extensive
interviews with local officials and area residents. The Public Comment period was extended from the
reguired one month to two months because of a reguest from the public. Changes to the preferred
alternative contained in the Proposed Plan, or a change from the preferred alternative to another, might
have been made if public comments or additional data indicated that such a change would result in a more
appropriate solution. The final decision regarding the selected remedy in this Record of Decision (ROD)
has taken into consideration all comments from SCDHEC and the public. The selected alternative has not
changed from that selected for the Proposed Plan. Several written comments were received from the
public. Those comments along with EPA's response is contained in the attached Responsiveness Summary.

EPA is issuing this Record of Decision as part of its public participation responsibilities under Section
117(a) of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). This
document summarizes information that can be found in greater detail in the Remedial Investigation/
Feasibility Study (RI/FS) Reports and other documents contained in the Administrative Record, located at
the Information Repository at the Fountain Inn Public Library located on Main Street in Fountain Inn,
South Carolina and at the Superfund Record Center at EPA Region 4 Headguarters located at 345 Courtland
Street, Atlanta, GA.

2.0 BEAUNIT NPL SITE LOCATION AND DESCRIPTION

The Beaunit site occupies approximately 1.3 acres on the northwest side of Fountain Inn, South Carolina.
Fountain Inn is 15 miles southeast of the City of Greenville. The site is the former wastewater lagoon,
and its surroundings, that Served a former knitting, dyeing, and finishing plant about 400 yards east of
the site. The wastewater lagoon was built in 1951 and ceased operations in 1977 when the adjacent plant
connected to municipal sewage. In 1980 the wastewater treatment structures around the lagoon were
demolished and the lagoon partially filled in. The Site is currently inactive and enclosed within a
secured fence. The adjacent plant currently is operated by Wilson Sporting Goods for the manufacture of
tennis balls.

The site is located off Valley View Road. Land use within one mile of the site includes small farms,
residential areas, several businesses, and industrial facilities. Within .25 miles of the site along
Valley View Road are Valley View Apartments, power lines, and a small pond. The nearest dwellings to the
site are the Valley View apartments located about 100 yards northeast of the site. Water is available to
area residents and businesses through a public water supply system. No groundwater supply wells exist at
.the site or in the vicinity.

2 .1 Site Location

The Site is located on the northwest side of Fountain Inn within Greenville County, South Carolina. The
City of Fountain Inn is approximately 15 miles southeast of Greenville, South Carolina. The Site is 1.3
acres at latitude 34o 41' 53.8" and longitude 820 12' 48.8". The Site is the former location of a sewage
treatment system, comprised of a sewage lagoon, sludge drying beds, and related treatment eguipment. The
Site is fenced with a locked gate and has signs posted identifying it as a Superfund Site.

2.2 Topography

Greenville County is located in the north central part of South Carolina in the Piedmont Physiographic
Province. The Piedmont Province is characterized by rolling rounded hills, and long rolling,
northeast-southwest trending ridges. Most of this area is gently sloped with area near creeks and
streams having more moderate to steep slopes. Greenville County generally slopes southeasterly, which is
the prevalent direction of drainage. While the highest point in Greenville County is 3,297 feet, the
elevation around the Site ranges from 700 to 1200 feet.

More specifically, the area around the Site is gently sloping to moderately steep. Elevations in the
immediate area range from approximately 900 feet MSL west of Fountain Inn to 790 feet northwest of the
Site along Howards Branch. The topography around the Site is shown in Figure 1.

-------
The elevation of the Site ranges between 860 feet at sampling location P7 at the east of the site to 819
feet at the surface water sampling station SW1 on Howards Branch. In general the Site slopes westerly
towards the unnamed creek west of the lagoon and toward the northwest and Howards Branch.

2.3 Meteorology

South Carolina has a climate with mild winters and warm humid summers. The average daily maximum
temperature for Greenville County is 71°F and the average daily minimum temperature is 52°F. In summer
the temperature rises above 90°F for an average of 56 days, but seldom reaches above 100°F. Winter in
Greenville County is mild and the temperatures are above freezing about 50 percent of the time.

Annual rainfall in Greenville County averages between 47 to 51 inches, well distributed through the year.
May and November receive the least average rainfall per month (approximately 3.0 inches). March and July
have the highest average rainfall per month (over 5.0 inches). Snowfall of over an inch occurs an
average of only four days per year.

Severe weather such as tornadoes, tropical storms, and hurricanes can occur in the area. No full-fledged
hurricanes have been recorded in Greenville County in the last 70 years. Violent storms with heavy rains
and damaging winds occur only once every 5 to 10 years. Prevailing winds in Greenville County are from
the northeast in the autumn and winter and from the southeast in spring and summer. The average wind
speed is about eight miles per hour.

2.4 Regional Geology

Greenville County lies within the Inner Piedmont Belt of the Piedmont Geologic Province. Most of
Greenville County is located on the inner Piedmont Belt of the Piedmont Plateau; whereas, the northern 25
percent of the county is located on the Blue Ridge mountains. The Blue Ridge and Piedmont are generally
made up of the same kind of rock. The geology of this area is characterized by medium to high grade
metamorphic rocks of Precambrian to early Paleozoic age. Some areas of alluvium exist along stream
valleys. The metamorphic rocks generally consist of meta-sediments and meta-igneous rocks including
horneblende-gneiss, granite, and schists. These rocks weather to clay-rich soils and saprolite. The
soils and saprolites range from approximately 5 to 100 feet thick in most areas and may be thicker along
some ridge areas. Structurally, the area is characterized by northeast trending lineations which
generally dip to the southeast. Structural features include recumbent folds, cross-folds which trend
northwest-southeast, faulting, and igneous intrusions. The rock units are highly deformed. Granitic and
gabbroic intrusions are common in the Piedmont Province. The inner Piedmont belt is the most intensely
deformed and metamorphosed segment of the Piedmont. The northeast-trending Bervard fault zone forms much
of the boundary between the Blue Ridge and Piedmont belts. Although this zone of strongly deformed rocks
is one of the major structural features in the southern Appalachians, its origin is poorly understood.

The regional geology consists of highly metamorphosed gneiss and schists, with igneous rock intrusions
that are covered by a mantle of weathered rock material called saprolite. Saprolite is a result of rocks
that have weathered in place as a result of chemical alteration from infiltration of rainwater.
Saprolite exhibits some structural and mineralogical characteristics of the underlying parent rock such
as foliation, bedding and fractures. The weathering of rock into saprolite has changed the mineralogy
3f the rock by more clayey and sandy conditions. These mineralogies have produced an upper soil horizon
in many places That has been further altered by decaying vegetation where the structures sometimes found
in deeper saprolite are no longer visible. There are eight geologic formations in Greenville County.
These formations are made of alluvium, fine-grained rocks, fine-grained to medium-grained rocks, and
coarse-grained rocks Alluvium consists of material recently deposited on flood plains. The fine-grained
rocks are diabase dikes that cut across formations of granite and gneiss. The fine-grained to medium-
grained rocks are biotite gneiss, biotite schist, and megmatite. The fine-grained to coarse-grained
rocks are biotite schist and hornblende gneiss. The medium-grained rocks are biotite granite gneiss and
granite undivided. The coarse-grained rocks are muscovite pegmatite dikes.

2.5 Regional Hydrogeology

The area hydrogeologic setting consists of an unsaturated zone consisting mostly of saprolite extending
from the surface down to a water table aguifer. The saprolite or in some places alluvium is recharged by
precipitation which infiltrates from the surface and moves downward to form the water table. The water
in the shallow water table aguifer moves downgradient until it discharges into springs and streams. The
surface of the water table is a subdued replica of the topographic surface and is generally near the
surface near streams (discharge areas) and is somewhat deeper beneath ridges and hills (recharge areas).

Groundwater in the Piedmont Province is found in alluvial materials, saprolite, and, to a limited extent,
in bedrock. Groundwater moves freely in the more permeable unconsolidated alluvium along stream valleys

-------
and river banks. Groundwater also moves fairly easily through the saprolite and weathered rock zones.
The availability of groundwater in an area depends upon rock type, thickness of soils and saprolite,
extent of fracturing, joints, schistosity in the rock, and the amount, distribution, and density of
rainfall.

3.0 SITE HISTORY AND REGULATORY HISTORY

3.1 Site History

A wastewater treatment plant, which consisted of a modified activated sludge system, was built at the
site location in 1951. It was constructed to treat industrial wastewater from a knitting, dyeing, and
finishing plant that was located approximately 400 yards to the east. The treatment plant units included
a bar screen, an aeration basin (lagoon), an aeroaccelerator, a clarifier, and a post aeration tank. "As
built" drawings for these units could not be located, but these units were believed to be located as
indicated on Figure 2. The original design of the plant was to provide treatment for an average flow
rate of 300,000 gallons per day (gpd) of textile wastewater. The lagoon had a volumetric capacity of
430,100 gallons and received wastewater via a pipeline (the influent pipe).

In 1973, wastewater from the plant was described as passing through an oil separator into the lagoon.
The lagoon was eguipped with five 15 h.p. aerators, which were also used to supply air to the
aeroaccelerator. The wastewater discharge may also have been treated with coagulants and neutralizers,
e.g., lime and alum, in the clarifier at the lagoon site. A suction pump was operated to return
collected sludge from the aeroaccelerator to the lagoon. A sludge drying bed, located approximately 20
yards north of the lagoon, was used to dry accumulated waste sludge from the treatment operation. The
lagoon was designed to discharge into an unnamed creek that is located to the west end of the lagoon.
There may also be a pipeline that bypassed flow around the lagoon and discharged flow to the unnamed
creek. The unnamed creek flows northwest and eventually joins Howards Branch.

-------
On November 7, 1973, SCDHEC conducted a public hearing to consider whether possible violations of South
Carolina's Water Classification System had occurred. SCDHEC conducted a site investigation on June 13,
1985, and reported detections of volatile organic compounds in surface water samples collected from the
lagoon and nearby unnamed creek, and PCBs and metals in the soil and sediment samples collected from the
Site. Based on the results obtained from SCDHEC's 1985 site investigation, EPA developed a Hazard
Ranking System (HRS) score of 32.44 for the Site. In June 1988, EPA proposed to include the Site on the
National Priorities List (NPL). The Site is ranked amongst the Group 18 sites (HRS scores 32.87 - 31.94)
on the NPL.

The United States Environmental Protection Agency (EPA) negotiated an Administrative Order by Consent
(AOC) with Continental Assurance Company, El Paso Natural Gas Company, Kayser-Roth Corporation, PepsiCo,
Inc., and Wilson Sporting Goods Co. (Respondents) regarding the Beaunit Corp. Circular Knit and Dyeing
Plant Site (Site). The AOC was negotiated under Sections 104, 122(a) and 122(d) (3) of the Comprehensive
Environmental Response, Compensation and Liability Act of 1980 (CERCLA), as amended, 42 U.S.C. §§9604,
9622(a) and 9622 (d) (3). The Respondents (hereinafter referred to as the Beaunit Lagoon Site Group)
agreed to comply with the AOC effective February 21, 1992.

The AOC and the Scope of Work (SOW) , incorporated therein by reference, reguired the Beaunit Lagoon Site
Group to conduct a remedial investigation and feasibility study (RI/FS) of the Site in accordance with
the National Oil and Hazardous Pollution Contingency Plan (NCP), as codified in the Code of Federal
Regulations, Title 40, Part 300 (40 CFR 300). The Beaunit Lagoon Site Group retained Engineering Science
to conduct the RI/FS of the Site.

The Beaunit Lagoon Site Group submitted a draft RI/FS Work Plan, a draft Sampling and Analysis Plan
(SAP), and a draft Health and Safety Plan (HSP) to EPA Region IV on May 29, 1992. EPA's review comments
on the draft RI/FS Work Plan and the draft SAP were addressed in a final RI/FS Work Plan and a final SAP
which were submitted to EPA Region IV on August 17, 1992. The comments on the draft HSP were addressed
in a final HSP. The Beaunit Lagoon Site Group received comments from EPA on the final RI/FS Work Plan
and the final SAP. The Beaunit Lagoon Site Group submitted a response to comments (i.e., EPA's review
comments on the final plans) to EPA Region IV on September 15, 1992. Also, the Beaunit Lagoon Site Group
submitted a revised final RI/FS Work Plan and a revised final SAP to EPA Region IV on September 30, 1992.
EPA approved the revised final RI/FS Work Plan and the revised final SAP on October 9, 1992.

Engineering-Science conducted initial site surveys (i.e., geophysical and topographical surveys) in April
1992. The information obtained from those surveys was used to prepare the RI/FS Work Plan and the SAP.
ES began mobilization on October 12, 1992 for performing the remaining RI ,field activities at the Site.
ES conducted field activities at the Site from October 19, 1992 to December 10, 1992. The Preliminary
Site Characterization Summary (PSCS) was submitted to EPA Region IV on February 16, 1993. All
information from the PSCS and additional findings on the fate and transport of contaminants are contained
in the RI report.

4.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION

Initial RI/FS community relations activities at the Beaunit Circular Knit & Dyeing NPL Site began with
extensive community interviews in Fountain Inn during May, 1992 and the finalization of a Community
Relations Plan in August, 1992. Area residents around the site, local government officials both elected
and appointed, local business leaders, and the local newspaper staff were all interviewed. There was
little knowledge about the site and some confusion with other remediation efforts from a mineral spirits
spill from the Wilson Sporting Goods Plant. There were unrelated concerns also expressed regarding odor
problems from the Wilson facility. There was some overall concern regarding children's exposure to the
site. All concerns raised were responded to during the interviews and later public meetings.
Additionally, an information repository was established at the Fountain Inn Public Library on Main
Street.

An initial fact sheet announcing the start of the RI/FS was issued in August, 1992. Community interest
during the RI/FS preparation was very low. EPA received only a few telephone calls regarding the Site or
the RI/FS study. EPA has regularly updated the Site Information at the Information Repository and posted
signs on the Site perimeter fencing and the gate listing contacts at EPA and SCDHEC. The Site is fenced
and routinely inspected for signs of trespassing.

Following completion of the RI and the FS, the Site mailing list was updated and the Proposed Plan was
mailed out in late October, 1994. Both the advertisement and the Proposed Plan stated that the Public
Comment period would be from November 7, 1994 to December 7, 1994.

The Proposed Plan public. meeting was held on November 14, 1994, to present the Agency's selection of
Preferred Alternatives for addressing contamination at the Site. The local newspaper, several citizens,
-------
and representatives from the Potentially Responsible Parties were present. In early December a request
was received to extend the public comment period to provide additional time for review of the Proposed
Plan and the RI/FS documents. EPA approved the request and extended the comment period to conclude on
January 13, 1995.

EPA received three written comments durinq the public comment period. EPA's responses to the comments
are contained in the Responsiveness Summary, Appendix B to this document. Other documents related to
public participation at this site includinq copies of the advertisements for the public meetinqs, the
initial comment period and its extension, as well as the transcript of the public meetinq are also
included in appendices to this document. This decision document presents the selected remedial action
for the Beaunit NPL Site, in Fountain Inn, South Carolina, chosen in accordance with CERCLA, as amended
by SARA and, to the extent practicable, the NCP. The decision of a remedial action for this Site is
based on the Administrative Record.

5.0 SCOPE AND ROLE OF THIS ACTION WITHIN SITE STRATEGY

The site principally poses a threat to the environment throuqh contaminated surface soils. The
contaminated soils could cause deleterious effects to environmental receptors who inqest orqanisms livinq
in the contaminated soils. A possibility exists that contaminants in the soils could leach into the
shallow qroundwater aquifer. While the shallow qroundwater aquifer is not utilized as a potable water
source, it is used for irriqation from a few wells in the vicinity of the site. The contamination
at the site does not pose an unacceptable risk for human health at the site at present or in the unlikely
scenario of future residential usaqe at the site. EPA's plan for remediation of the Beaunit Site will
address all threats posed by the Site, namely contaminated soil on-Site and potential qroundwater
contamination by leachinq of the soils on-Site. This is the only ROD contemplated for this Site.

6.0 SUMMARY OF SITE CHARACTERISTICS

6.1 Surface Water Hydrology

Surface water is present at the Site in the laqoon, and in small streams, drainaqe pathways and a small
man-made pond adjacent to the Site. A small unnamed creek located west of the Site flows north and
discharqes to Howards Branch about 500 feet northwest of the Site. Howards Branch eventually joins
Durbin Creek. Durbin Creek is a tributary of the Enoree River. Both Durbin Creek and the Enoree River
are classified as Class B streams by South Carolina. Streams and ponds in the area of the site are
shown in Fiqure 3.

The laqoon currently is about 7,000 square feet, containinq rain water accumulation and qroundwater
infiltration from the water table. While the water level in the laqoon varies, it is never dry, and at
the time of the Remedial Investiqation was 3 feet in depth.

Sediments alonq the unnamed creek and Howards Branch were collected. The sediments were qenerally sands,
qravel, silts, and clay. The bottom of the laqoon contains a sludqe layer about one foot thick
containinq a small amount of textile threads. Below this sludqe layer are soils similar to other
collected elsewhere around the site.

6.2 Site Hydrogeology

Seven qroundwater monitorinq wells were installed at the Site durinq the RI field activities. A summary
of well construction and water-level data is presented in Table 2.2 of the Remedial Investiqation. Five
monitorinq wells are shallow (MW1S, MW2S, MW3S, MW4S, and MW5S) , ranqinq in depth from 20 to 27.S feet
BLS. Two monitorinq wells (MW1D and MW5D) are screened deeper (55 feet BLS and 57 feet BLS)to provide
information on the vertical direction of flow. The upqradient monitorinq wells are MW1S, MW1D, and MW2S.
The downqradient monitorinq wells are MW3S, MW4S, MW5S, and MW5D. Depth to qroundwater across the Site
ranqed from approximately 3 feet below the top of casinq in MW5S to 11 feet below top of casinq in MW2S.

General qroundwater flow directions across the Site are from south-southeast to north-northwest. The
movement of qroundwater at the Site qenerally follows the topoqraphy which slopes northwesterly.
Groundwater leavinq the Site discharqes into the unnamed creek and Howards Branch. The well pair (MW1S
and MW1D) located upqradient of the Site indicate that qroundwater in this area has a downward vertical
qradient, which is consistent with an area of qroundwater recharqe. The vertical qradient at the well
pair farthest downqradient of the Site (i.e., MW5S and MW5D near the unnamed creek) is upward, which is
consistent with an area of qroundwater discharqe. The horizontal qradient across the Site was determined
to be approximately 0.038 ft/ft. Sluq tests were performed on all monitorinq wells. The averaqe
-------
hydraulic conductivity was 11.41 ft/day and the average velocity of groundwater flow, for an effective
porosity of 0.15, was approximately 2.88 ft/day.

6.3 Site Geology

Soil borings were drilled at various locations across the Site. These borings ranged in depth from about
6 feet to 100 feet. The borings encountered fill materials and residual or saprolite soils consisting of
sands, silts, and clays, and weathered rock. Bedrock was encountered in only one of the borings drilled
near a rock outcrop during this investigation at a depth of 9 ft. Bedrock is a biotite gneiss, and is
probably deeper than 100 feet below land surface (BLS) over most of the Site. However, rock was
encountered very shallow at one location (SB3) north of the Site. In the immediate area of this boring
rock is exposed at the surface. Sand, silt and clay were encountered in several borings. Biotite and
guartz were the two major mineralogical constituents found in the soils at the Site. A micacaceous
saprolite exhibiting a gneissic texture was encountered at an average depth of 7.5 feet BLS.

6.4 Site Soils

The surficial soils in the vicinity of the Site have been identified as Cecil and Appling soils, which
consist of Cecil sandy and Appling sandy loam. These soils, are derived from saprolite that has
weathered from the underlying bedrock of granite, gneiss, or schist. The surficial soils are well
drained.

Cecil soils have a surface layer of dark-brown sandy loam. The subsurface soil is normally a
yellowish-red sandy clay loam in the upper part, red clay in the middle, and red sandy clay loam in the
lower part.

Appling soils have a surface layer of dark grayish-brown sandy loam. The subsurface soil is normally a
light yellowish-brown clay in the upper part, yellowish brown and reddish-yellow clay in the middle, and
mottled brownish-yellow, brown, and red clay in the lower part.

The soils at the Site have been identified as Cecil soils which consist of sandy loam. The estimated
soil depth is 0 to 6 feet. The soils at the Site are fairly permeable.

6.5 Site Biota

Investigative methods for establishing aguatic and terrestrial resource characteristics included a field
reconnaissance survey conducted April 6 and 7, 1993, contact with local resource authorities, and
compilations of existing information. The characterization investigations focused on the aguatic and
terrestrial resources of the Site and the area within a half-mile radius of the Site. A walk-through
survey of the Site was conducted. Five natural resource categories were examined: vegetation, aguatic
life, wetland resources, wildlife, and species of concern. Each resource description addresses general
community and habitat characteristics and environmentally sensitive areas or aspects. All descriptions
were based on a two-day field reconnaissance conducted by ES personnel, except where noted.

6.6 Vegetation

The type, composition, location and general appearance of vegetation were determined from observations
made during the field reconnaissance survey. Site aerial photographs (scales ranging from 1:1,900 to
1:5,400) and the USGS Fountain Inn Quadrangle (7.5 minute series) were used to locate and map boundaries
of each vegetation type that was identified in the field. Technical documents were also referenced to
support the field assessment.

The approximate location and extent of vegetative cover types are shown on Figure 4. A list of species
identified during the field reconnaissance is provided in Appendix B of the RI. There are no vegetation
types of major economic importance or that represent a resource of unigue or special concern. All types
are widely distributed and abundant throughout the vicinity. The mixed hardwood-pine forest and scrub or
old fields are described below.

6.6.1 Mixed Hardwood-Pine Forest

A natural plant community, the successional mixed hardwood-pine forest, was recognized outside the Site,
within the one-half mile radius of the Site. The predominance of this community is due primarily to the
fact that the study area is located on well-drained upland soils of two major soil series, the Appling
and Cecil series. Soils in these series consist of sandy loams. The soils are described as low in
natural fertility and slightly to moderately acidic. Water capacity is moderate and erosion is reported
as a moderate hazard (SCS 1975).
-------
A third soil type, the Wehadkee soils, is found along and adjacent to the streams and drainageways in the
study area. This poorly drained soil, has moderate organic content and moderate natural fertility.
Flooding is a major concern. The mixed hardwood-pine plant community is also supported on this soil with
an increase in the plants more tolerant of wetter soils (e.g., red maple, water oak).

The mixed hardwood-pine successional forest is characteristic of a very large portion of the Piedmont
physiographic region, especially where the soils are well drained and slightly to moderately acidic.
Random pH readings of 6 were noted for the soils in the study area. White oak, southern red oak, water
oak, sweet gum, tulip-poplar and shortleaf pine are common tree species in the vicinity of the Site.
Pines are generally absent along the stream corridors while sweet gum and red maple occur more freguently
in these areas. The subcanopy is composed of black cherry, Rubus sp., red cedar, and American holly.

Species diversity of ground cover in the forested areas appeared to be somewhat low. Most prominent in
the herbaceous layer were species such as spotted wintergreen, sphagnum moss, lycopodium, yellow wood
sorrel, blue violet, and bird's foot violet. Common vines observed in the area included poison ivy,
greenbrier, and Japanese honeysuckle. Kudzu occurred along Howard Branch, west of Valley View Road.
Cane was observed infreguently. Forest cover in the immediate vicinity of the Site is similar in
composition and condition to other forested areas observed throughout the one-half mile study area.

Portions of the plant community have been substantially altered due to road building, utility corridor
clearing, sewer routing/installation and home-building. Historic aerial photos indicate that much of the
forested area adjacent to the Site had been cleared and was utilized for agricultural purposes prior to
approximately 1965. Remnants of terracing were observed in wooded areas east of the Site during the
field reconnaissance.

6.6.2 Old Field/Scrub/Pasture

Deforestation and subseguent regeneration has occurred in several locations within the study area
resulting in the occurrence of old field and scrub vegetation. The Site, mowed routinely, is comprised
mainly of early successional herbaceous and woody plants. For example, willow is regenerating on some
portions of the Site. Shrubs occur around the perimeter of the lagoon and on the berm. Species included
willow, rush, honeysuckle, Rubus sp., greenbrier. The area bordering the west side of the lagoon outside
of the Site is within the power easement and the saplings and shrubs have been periodically cut.

6.7 Aquatic Life

Surface water is present in a lagoon at the Site and in small streams, drainage pathways and two small,
man-made ponds within the study area. Sections of the small streams and ponds in the study area may
support populations of aguatic organisms. According to Mr. Gene Hayes, District Fisheries Biologist with
the South Carolina Wildlife & Marine Resources Department (SCWMRD), no data is available for Howard
Branch or other water bodies within the study area. However, limited data exists for Durbin Creek into
which Howard Branch flows nearly 2.5 miles to the northeast of the Site. Physical conditions of the
streams and ponds within the study area were recorded and random observations of benthic life were noted.
The streams and ponds within a one-half mile radius of the Site are shown on Figure 3, included
previously in this Record of Decision.

6.8 Wetland Resources

Wetland resources were identified on the Site and within the study area using aerial photographs, the
USGS topographic map and the Greenville County soil survey (SCS 1975). Potential wetland areas were then
verified by field inspection. No jurisdictional delineations were conducted; however, wetland areas were
identified generally using criteria set forth in the U.S. Army Corps of Engineers (COE) 1987 Wetlands
Delineation Manual.

6.9 Wildlife

The presence and current status of wildlife resources were determined primarily by reviewing existing
information sources, by interviewing local authorities and agency personnel, and by conducting a field
reconnaissance. Typical wildlife habitats, uses, and prevalent species were noted during the field
reconnaissance. Availability of relevant data on wildlife species is limited. The presence and status
of endangered, threatened, and special-concern species were determined primarily by reviewing existing
information sources. Potential habitat occurrence within the vicinity of the site was also evaluated
during the field reconnaissance. Technical documents received from the SCWMPD Heritage Trust Section
(Boyle 1993) and the U.S. Fish and Wildlife Service (EuDaly 1993) were reviewed to identify the species
-------
of concern.

Numerous game and nongame species exist in the area of the site. The actual proportions of the wildlife
population are unknown. Larger species may be excluded from the Site due to a chainlink fence topped
with three-strand barbed wire surrounding the Site. Smaller animals may gain access to the Site under
the fence. No animals or signs were observed inside the fence and there was no evidence of burrowing on
the Site.

Typical animals that may be found in the area include rabbit, skunk, opossum, raccoon, deer, fox, and
sguirrel. During the field reconnaissance, signs (scats and tracks) of rabbit and raccoon were found
throughout the study area. A deadshrew was observed in a wooded area east of the substation. No signs
of deer were observed although the habitat conditions of the study area offer food and cover.

Birds noted in the area during the site reconnaissance include mourning dove, common crow, robin,
bluejay, mockingbird, wood thrush, red-tailed hawk, northern cardinal, common flicker, chickadee,
killdeer, downy woodpecker, Canada goose and green heron.

The site and surrounding area generally provides less than optimal wetland and riparian habitats to
accommodate waterfowl populations or uses. Waterfowl may utilize the pond adjacent to the Site and the
Howard Branch headwater pond for resting and foraging. Signs of wading birds were observed in the
unnamed creek downstream of the pond and in Howard Branch downstream of its confluence with the unnamed
creek. In addition, a green heron was observed near Howard Branch during the field reconnaissance.

There is no information available concerning reptiles and amphibians commonly found in the study area.
No reptiles or amphibians (other than tadpoles on the Site) were observed during the field
reconnaissance.

6.9.1 Endangered, Threatened, and Special-Concern Species

A status review was conducted of all potential plant, wildlife, and fish species reported from the
region. There are no known resident populations or designated critical habitats for any state or
Federally listed threatened or endangered species occurring on the Site or within a one-half mile radius
of the Site. In addition, no populations or supporting habitats were observed on the Site or in the
study area for species of special concern.

7.0 SUMMARY OF SITE RISKS

7.1 Remedial Investigation

The Beaunit Lagoon Site Group submitted a draft RI/FS Work Plan, a draft Sampling and Analysis Plan
(SAP), and a draft Health and Safety Plan (HSP) to EPA Region IV on May 29, 1992. EPA's review comments
on the draft RI/FS Work Plan and the draft SAP were addressed in a final RI/FS Work Plan and a final SAP
which were submitted to EPA Region IV on August 17, 1992. The comments on the draft HSP were addressed
in a final HSP. The Beaunit Lagoon Site Group received comments from EPA on the final RI/FS Work Plan
and the final SAP. The Beaunit Lagoon Site Group submitted a response to color, Lents (i.e., EPA's
review comments on the final plans) to EPA Region IV on September 15, 1992. Also, the Beaunit Lagoon
Site Group submitted a revised final RI/FS Work Plan and a revised final SAP to EPA Region IV on
September 30, 1992. EPA approved the revised final RI/FS Work Plan and the revised final SAP on October
9, 1992.

Engineering-Science conducted initial site surveys (i.e., geophysical and topographical surveys) in April
1992. The information obtained from those surveys was used to prepare the RI/FS Work Plan and the SAP.
ES began mobilization on October 12, 1992 for performing the remaining RI field activities at the Site.
ES conducted field activities at the Site from October 19, 1992 to December 10, 1992. The PSCS was
submitted to EPA Region IV on February 16, 1993. The information contained in the PSCS along with
information on the fate and transport of contaminants are presented in the RI report.
-------
7.1.1 Remedial Investigation Field Activities

The RI field activities were as follows:

• Topographical and geophysical surveys in April 1992 before preparing the draft RI Work Plan;

• Installed seven (three upgradient and four downgradient) monitoring wells;

• Collected groundwater samples from monitoring wells;

• Collected surface water and sediment samples from the lagoon, the unnamed creek, a pond (located
upstream of the unnamed creek), and Howards Branch;

• Collected surface soil samples from 24 locations that included 3 background surface soil
samples;

• Collected subsurface soil samples from 15 soil borings that included 3 background soil borings,
5 soil borings along the influent pipeline to the lagoon, 2 soil borings along an effluent
pipeline from the lagoon, 2 soil borings in the former sludge drying bed area, and 3 soil
borings in the fill material area;

• Surveyed monitoring wells and sampling locations; and conducted biota survey.

The sampling locations for surface water, sediment samples, groundwater samples, and surface soil
samples, and the data collected are shown in attached Figures 5, 6, 7, 8, 9, 10, 11, & 12.

7.2 Remedial Investigation Conclusions

The conclusions presented in this section are based on the site background and setting, the physical
characteristics of the study area, the nature and extent of contamination, and the fate and transport of
contaminants.

• The potential contaminants of concern for surface soil are polynuclear aromatic compounds
(PNAs), arsenic, and manganese.

• The potential contaminants of concern for subsurface soil are PNAs and manganese.

• The potential contaminants of concern for lagoon sediments are polychlorinated biphenyls (PCBs),
benzo(a)pyrene, antimony, beryllium, and manganese.

• The potential contaminants of concern for lagoon surface water are arsenic, barium, and
manganese; none of these metals exceed drinking water standards.

• The potential contaminants of concern for groundwater are barium, chromium, and manganese; none
of these metals exceed drinking water standards.

• The rock outcrops and the unnamed creek are the controlling features for the groundwater in the
vicinity of the Site; the groundwater flows towards the unnamed creek and has an upward
component near the unnamed creek.

• From the standpoint of human health or environmental risk the four elements of a migration
pathway, i.e., an affected source, a transport medium, an exposure pathway, and an exposure
source must occur for the pathway to be considered as complete. The evaluation of contaminant
transport from the affected areas at the site indicates that the potential contaminants of
concern are not likely to migrate. Therefore, the migration pathways for the potential
contaminants of concern at the site are not likely to be completed.

-------
7 . 3 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.

The Baseline Risk Assessment (BRA) for the Site was prepared by Roy F. Weston, Inc. for EPA Region IV.
The BRA was finalized on November 24, 1993. EPA determined as a result of the risk assessment that
potential future residential exposures to benzene, beryllium, chromium, manganese, 2-methylnaphthalene,
and naphthalene in groundwater were of concern. It should be noted these risk levels incorporated both
site related and background related risks (since some contaminants such as beryllium, chromium, and
manganese, existed in the study area naturally). EPA determined that the risks to human health from
contaminants in surface soils were within EPA's acceptable risk range and stated that remediation of
surface soils would not be reguired for the protection of human health. However, the BRA also determined
that site surface soils did present a risk to ecological receptors. Arsenic and nickel were identified
as the chemicals of concern. While EPA determined that there were no significant concerns over surface
soil contamination as applied to human health, the agency reguired that soil contamination still be
addressed in the feasibility study for the Site because of concern for ecological receptors. Subsurface
soil, surface water and sediments were not identified as media of concern for the Site. The contaminants
of concern, exposure concentrations, risk levels, and hazard indices are provided in Tables 1.1 & 1.2 of
the Feasibility Study.

Actual or threatened releases of contaminants from the site, if not addressed by one of the alternatives
in this plan, may present an imminent and substantial endangerment to public health, welfare or the
environment.

7.3.1 Human Risk

An evaluation was made of all potential exposure routes which could connect contaminants of concern
(COC's) at the Site with people living or working in the area. Exposure by each of these pathways was
mathematically modeled using generally conservative assumptions. Of the five media (surface water,
sediment, groundwater, surface soil, and subsurface soil) investigated during the RI, groundwater was
identified in the BRA as the only media of concern for human receptors.

The EPA determined that the contaminants of concern associated with groundwater were benzene, beryllium,
chromium VI, manganese, 2-methylnaphthalene, and naphthalene. Of these contaminants, benzene and
beryllium are classified as carcinogenic constituents and chromium VI, manganese, 2-methylnaphthalene,
and naphthalene are classified as noncarcinogenic constituents. Carcinogenic and noncarcinogenic risk
levels for contaminants in groundwater were presented in the final BRA. Carcinogenic risks are presented
as an incremental risk to a population subgroup, e.g., child, and noncarcinogenic risks are presented as
hazard indices in Table 1.

7.3.2 Environmental Risk

A gualitative risk assessment was conducted to determine if contaminants present at the site have
impacted plant life or animals in the area. Given the small size and industrial nature of the site,
significant impact to local plants and animals are not expected. While endangered or threatened species
have been identified in this area of the State, none were specifically located at the Site during the
RI/FS. Regardless, the environmental risk assessment did indicate that surface soil exposure to
environmental receptors would need to be addressed in the development of remediation alternatives.

Of the five media investigated during the RI, the baseline risk assessment determined that surface soil
is the only medium of concern for ecological receptors. Arsenic and nickel are identified as the
contaminants of concern (those that exceed an ecological hazard index of 1.0 in surface soil) in the
final BRA. The hazard indices for these contaminants are listed in Table 1.

The risk posed to terrestrial wildlife was based on arsenic and nickel detected in surface soil samples.
The arsenic and nickel concentrations used to compute risks were 9.71 mg/kg and 8.08 mg/kg, respectively.
The background arsenic concentrations at the Site are 3 mg/kg (SB1, 0-2 ft), 1.2 mg/kg (SB2, 0-2 ft), and
5.6 mg/kg (SB3, 0-2 ft). Nickel was detected only in the SB1 (0-2 ft) background sample at a
concentration of 4.2 mg/kg. Nickel was not detected at SB2 (0-2 ft, 1.9U mg/kg) and SB3 (0-2 ft, 7.1U
mg/kg). The average elemental concentrations for arsenic and nickel in United States soil and other
surficial materials are presented in Table 2.1 of the BRA. The site-specific averages for arsenic and
nickel are less than the reported average elemental concentrations in United States soil.
-------
Medium
Groundwater
Groundwater
Groundwater
Groundwater
Groundwater
Groundwater
Groundwater
Groundwater
Groundwater
Groundwater
Groundwater
Groundwater
Surface Soil
Surface Soil
Chemical
Table 1
Beaunit ROD
Baseline Risk Assessment Summary
RI/FS of Beaunit Corp. Circular Knit and Dyeing Plant Site
Fountain Inn, South Carolina
Risk Exposure
Type Concentration(1)
Benzene
Chromium
Manganese
Manganese
Manganese
2-Methylnaphthalene
2-Methylnaphthalene
2-Methylnaphthalene
Naphthalene
Naphthalene
Naphthalene
Beryllium
Arsenic
Nickel
Human Health
Carcinogenic
Noncarcinogenic
Noncarcinogenic
Noncarcinogenic
Noncarcinogenic
Noncarcinogenic
Noncarcinogenic
Noncarcinogenic
Noncarcinogenic
Noncarcinogenic
Noncarcinogenic
Carcinogenic
11 ug/L
39.7 ug/L
2620 ug/L
2620 ug/L
2620 ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
19,
19,
19,
77,
77.5
77.5
4.5 ug/L
Terrestrial Wildlife
na
na
9.71 mg/Kg
8.08 mg/Kg
Risk
Level
IE-OS
na
na
na
na
na
na
na
na
na
na
4E-04
na
na
Hazard
Index
na
1
67
22
14
7
2
1
27
9
6
na
80.9
1.85
Subgroup
Type
not specified
Child
Child
Youth
Adult
Child
Youth
Adult
Child
Youth
Adult
not specified
Least Shrew
Least Shrew
(1) 95% upper confidence limit of the arithmetic mean of detections and
or the maximum amount detected, whichever is less.
detection limit for nondetects,
-------
7.3.3 Exposure Pathways and Receptors

The exposure routes for both the groundwater and surface soil were presented in the final BRA. There are
no residents on the Site. The final BRA, however, states that there is the possibility of visitors
gaining access to the Site and the surrounding areas. Hypothetically, a visitor (youth, 7 to 16 years
old). is assumed to receive the maximum current chemical exposure from surface soil, surface water, and
sediment during recreational activities. The potential carcinogenic risk for the hypothetical visitor
does not exceed 1E-06, and the potential hazard index for the hypothetical visitor does not exceed 1.0.

The BRA also states that the Site has a reasonable potential to be developed for future residential use.
Potential soil and groundwater exposure pathways were evaluated for children (less than 7 years old),
youths (7-16 years old), and adults (older than 16 years) as future residents. The surface soil pathway
is based on exposure through incidental ingestion, dermal contact, and inhalation of airborne soil/dust.
Subsurface soil pathway was not addressed since, as described in the BRA, "Exposure to contaminants
detected in soil borings is not evaluated for either the current or future use scenarios because the
depth at which the samples were taken precludes direct contact." The Site is currently owned by a
Beaunit PRP. Therefore, the potential exposure to a hypothetical future resident could be eliminated
through access and deed restrictions. The groundwater pathway is based on future site residents being
exposed to the contaminants of concern through: (1) possible future off-site private drinking wells
containing contamination (in the vicinity of the Site) ; or (2) the installation of a residential well
onsite. The potential groundwater exposure pathways include ingestion of drinking water and
non-ingestion uses (i.e., showering). However, the probability for completion of groundwater exposure
pathways is very low because drinking water wells are not located on the Site or properties adjoining the
Site. In addition, the probability of a future resident using the groundwater for ingestion (e.g.,
drinking) and non-ingestion (e.g., showering) purposes is low because the City of Fountain Inn supplies
water to residents via a water distribution system. Therefore, a large uncertainty would be factored in
the assessment of any future risks that are based on the completion of the groundwater exposure pathway.

In addition to these pathways, exposure to surface water and sediment (while playing in the unnamed
creek, Howards Branch, and the lagoon) was evaluated for a resident youth (age 7-16 years old). These
pathways include incidental ingestion and dermal contact with sediment and dermal contact with water.

The final BRA stated that the hazard indices were greater than a value of 1.0 for the hypothetical future
child, youth, and adult resident due to the groundwater pathway. The final BRA also stated that the
carcinogenic risk exceeded 1E-06 for the unspecified, future, lifetime resident from the groundwater
pathway. It should be noted, however, that according to calculations conducted outside the BRA,
carcinogenic risk also exceeds 1E-06 for groundwater at background guality due to beryllium and chromium.
Additionally, according to calculations conducted outside the BRA, noncarcinogenic risks also exceeds a
hazard index of 1.0 for groundwater at background guality due to manganese.

The final BRA also presented the ecological risk to terrestrial wildlife. The Least Shrew was chosen as
the target species to represent terrestrial wildlife. The BRA determined that an adverse effect on the
Least Shrew could result from exposure to chemicals of concern in surface soil at the Site. The surface
soil and groundwater pathways and receptors are described in the following subsections.

8.0 DESCRIPTION OF REMEDIAL ALTERNATIVES

8.1 Scope of the Remedial Action

This Record of Decision for the Beaunit Superfund site addresses remedies for surface soil and
groundwater contamination present at the site. Sediments and surface water were also sampled during the
Remedial Investigation as well. The Remedial Action is necessary to protect the public and environmental
receptors from exposures to contaminated surface soils and groundwater. Additional sources or operable
units are not expected.

The FS for the Site included the following five phases: i) development of remedial action objectives
(RAOs); ii) development of general response actions; iii) identification of potential Technologies and
process options; iv) development and screening of potential technologies and process options; and v)
development and detailed analysis of the proposed remedial action alternatives. The RAOs for groundwater
and surface soil were developed based on the information provided to the Beaunit Lagoon Site Group by
EPA. The general response actions for groundwater included no action, institutional controls,
collection, and treatment. The general response actions for surface soil included no action, diversion
of surface water, containment, and removal/disposal.
-------
8.2 Remedial Goal Options for Groundwater (RGOs)

The Remedial Action Objective (RAO) for groundwater remediation at the Site is to prevent human exposure,
via any exposure route [ingestion and non ingestion (i.e., showering)] to groundwater containing
contaminants in concentrations that exceed ARARs and appropriate risk levels.

EPA reguired that the Remedial Investigation's terminology of Preliminary Remedial Goals (PRGs), be
referred to as remedial goal options (RGOs). The RGOs for groundwater at the Site were developed for the
future resident and they were calculated for the contaminants of concern in groundwater using the
following eguation:

RGO= (TR X EC)/CR

Where:

RGO Remedial Goal Options

TR Target risk level (HQ = 1.0 for noncarcinogenic
effects and risk level = 1E-06, 1E-
05, and 1E-04 for carcinogenic
effects).

EC Exposure concentration in soil and groundwater.
CR Calculated risk level

The RGO's for groundwater are shown in attached Table 2.

8.3 Remediation Goal Options for Surface Soil (RGOs)

The Remedial Action Objective (RAO) for surface soil remediation at the Site is to prevent exposure of
terrestrial species to the contaminants of concern in surface soils above appropriate risk levels.

The RGOs for surface soil were computed using the same eguation that was used for groundwater. The RGOs
for the contaminants of concern i.e., arsenic and nickel in surface soil for ecological risk calculated
based on a hazard index of 1 are presented in attached Table 3. The RGO for arsenic (0.1 mg/kg)
calculated based on a hazard index of 1 is one order of magnitude lower than the concentrations of
arsenic detected in background surface soil samples (SB1 3 mg/kg, SB2 1.2 mg/kg, and SB3 5.6 mg/kg).
ARGO for arsenic lower than background concentrations would lead to a cleanup of the Site to below
background value. Therefore, the RGO for arsenic should be based on background concentrations and not
on the concentration calculated based on a hazard index of 1. An average background concentration of 3.2
mg/kg could be used as a RGO for arsenic in surface soil.

The concentration of nickel in surface soil based on a hazard index of 1 is 4.4 mg/kg. The concentration
of nickel detected in background surface soil sample was 4.2 mg/kg. Therefore 4.4 mg/kg could be used as
the RGO for nickel in surface soil.

8.4 Development of Alternatives

The NCP reguires that the following alternatives be considered for development in-the Feasibility Study
(FS) for a NPL site:

• An alternative that removes or destroys the hazardous constituents to the maximum extent
feasible and eliminates the need for long-term monitoring and management;

• One or more alternatives that reduce the toxicity, mobility, or volume of the hazardous
constituents;

• One or more alternatives that involve little or no treatment, but provide protection to human
health and the environment by containing the hazardous constituents to control exposure to the
wastes;

• One that involves innovative treatment technologies if those technologies offer the potential
for comparable or superior performance or implementability, fewer adverse effects, or lower
costs than demonstrated technologies; and

• The no action alternative.
-------
Process options were identified for groundwater and surface soil based on the general response actions
for each medium. The process options retained after initial screening phase for groundwater were natural
attenuation, monitoring, groundwater pumping, precipitation, filtration, ion exchange, adsorption,
and air stripping. The process options retained after the initial screening phase for soil were natural
attenuation, grading and drainage controls, native soil/clay cap, excavation of surface soil, excavation
of fill material, and off-site disposal.

The process options were further screened based on their effectiveness, implementability and cost. Eight
remedial action alternatives for the Site were developed based on the process options retained after the
screening phases. The remedial action alternatives are shown in Table 4.

Table 2
Beaunit ROD
Remediation Goal Options For Groundwater
RI/FS of Beaunit Corp. Circular Knit and Dyeing Plant Site
Fountain Inn, South Carolina

Remedial Goal Option

Contaminant Types of Risk Risk-Based(1) ARAR-Based

Human Health

Benzene Carcinogenic 2 to 200 ug/L 5 ug/L(2)

2-Methylnaphthalene Noncarcinogenic 3 ug/L NA

Naphthalene Noncarcinogenic 3 ug/L NA

Beryllium Carcinogenic 0.01 to 1 ug/L 4 ug/L(2)

Chromium VI Noncarcinogenic 40 ug/L 100 ug/L(3)

Manganese Noncarcinogenic 40 ug/L 200 ug/L(4)

(1) Carcinogenic risk-based remediation goals are based on the risk range 1E-6 to 1E-4
Noncarcinogenic risk-based remediation goals are based on a hazard index of 1.0.
(2) ARAR-Based goal is based on MCL
(3) ARAR-Based goal is for total chromium
(4) ARAR-Based goal is based on MCLG
NA - Not applicable

Table 3
Beaunit ROD
Remediation Goal Options For Surface Soil
RI/FS of Beaunit Corp. Circular Knit and Dyeing Plant Site
Fountain Inn, South Carolina

Remediation Goal Options (RGOs)

Contaminant Types of Risk Risk-Based ARAR-Based

Terrestrial Wildlife

Arsenic Noncarcinogenic 0.1 mg/Kg(l) NA

Nickel Noncarcinogenic 4.4 mg/Kg(2) NA

(1) Noncarcinogenic risk-based goal has been calculated based on a hazard index of 1.0. The
risk-based goal is lower than average background concentration by at least one order of magnitude.
Therefore, the average background concentration of 3.2 mg/kg could be used as the RGO for arsenic
in surface soil.

(2) Noncarcinogenic risk-based remediation goal has been calculated based on a hazard index of 1.0.
NA - Not applicable
-------
8.5 Summary of Alternatives

Based on the results of the RI/FS reports and the risk assessment, cleanup levels were developed that
would be protective of human health and the environment. These cleanup levels form the basis of any
remedial activity. Various alternatives were evaluated in the FS report using these cleanup levels as
goals for site cleanup. The ground water cleanup levels are based on state and federal standards,
referred to as Maximum Contaminant Levels (MCLs). The soil/source cleanup levels were established to
minimize site risks and insure future protection of ground water. The cleanup standards for the Beaunit
site are presented in Table 2 and 3.

The FS report evaluated a variety of cleanup methods that could be used at this site. As required by
CERCIA, a no further action alternative was evaluated to serve as a basis for comparison with the other
active cleanup methods. The cleanup methods to address site related contamination which exceeds the
cleanup goals are presented in this Record of Decision.

Costs shown in the Record of Decision for each alternative represent the midpoint of the low and high
estimates for each alternative which are provided in greater detail in the Feasibility Study. A summary
table of the high and low estimates for the costs of each alternative is attached as Table 5.

8.5.1 Alternative 1: No Action

A no action alternative is required by the NCP to be carried forward as a baseline for detailed
comparison. Under this alternative no remedial actions will be conducted for groundwater and surface
soil. Site monitor wells will be plugged and abandoned. The current site fence will not be actively
maintained under this program. No groundwater monitoring or remediation activities will be conducted.
This option does, however, include natural attenuation of groundwater and surface soil contaminants.
Under this option, organic contaminants in groundwater and surface soil will biodegrade naturally.
Metals will tend to persist in sediment and soils. Investigative derived waste (materials from well
drilling and soil sampling) from the RI will be disposed and the Site will remain in its current
condition. Mid-point of the range of costs for Alternative 1 in present worth is $5439.

8.5.2 Alternative 2 - Groundwater, Surface Water, and Sediment Monitoring and Groundwater Use
Restrictions/Deed Restrictions

Alternative 2 combines an institutional control general response action for groundwater and the no action
general response action for surface soil. Under this alternative, a monitoring program for groundwater,
stream surface water, and stream sediment will be implemented to provide a method for identifying changes
in the site conditions. Groundwater samples will be collected from six of the monitoring wells and from
three surface water and sediment sampling locations (from the unnamed creek); these samples will be
analyzed semi-annually for the first two years and annually for three years thereafter. The results will
be assessed for future monitoring requirements. Site monitoring will (1) provide early warning of
unacceptable contaminant migration, and (2) allow for a better understanding of the natural attenuation
rates. Based on currently available information, no remedial action will be conducted for groundwater
and surface soil. If future monitoring indicates a need for additional remedial action, such action will
be considered. This alternative does include natural attenuation and biodegradation of groundwater and
surface soil contaminants. Under this alternative, organic contaminants in groundwater and surface soils
will degrade naturally. Institutional controls would prevent use of the shallow groundwater and preclude
use of the site for new home construction. Contingent upon future groundwater monitoring results from
wells located on nearby properties, additional institutional controls (deed notice) may be considered for
such properties. Metals will not biodegrade and will tend to persist in soils. The investigative
derived waste from the RI will be disposed and the site area will be maintained in its current condition.
Mid-point of the range of present worth estimate costs for Alternative 2 is $276,887.
-------
Table 4
Beaunit ROD
Remedial Action Alternatives
RI/FS of Beaunit Corp. Circular Knit and Dyeing Plant Site
Fountain Inn, South Carolina
Alternative
Number
General Response Action
Remedial Alternative
No Action

Institutional Controls (gw) /
No Action (ss)

Institutional Controls (gw) /
Containment (ss)
Collection and Treatment
(gw)/
Containment (ss)
Institutional Controls
(gw)/Removal/Disposal of
"Hot Spots" (ss)
No Action Alternative

Groundwater, Surface Water, and Sediment
Monitoring and Groundwater Use Restrictions

Groundwater, Surface Water, and Sediment
Monitoring and Groundwater Use Restrictions /
Grading-Drainage Control-Soil and Clay Cap

Groundwater Pumping Treatment, Groundwater,
Surface Water, and Sediment Monitoring and
Groundwater Use Restrictions /
Grading-Drainage Control-Soil and Clay Cap

Groundwater, Surface Water, and Sediment
Monitoring and Groundwater Use
Restrictions/Mechanical Excavation of "Hot
Spots", Off-site Disposal of Excavated Material,
and Backfill and Grade
Collection and Treatment
(gw)/Removal/Disposal of
"Hot Spots" (ss)
Groundwater Pumping and Treatment,
Groundwater, Surface Water, and Sediment
Monitoring and Groundwater Use
Restrictions/Mechanical Excavation of "Hot
Spots", Off-site Disposal of Excavated Material,
and Backfill and Grade
Institutional Controls
(gw)/Removal/Disposal of
Site Surface Soils and Fill
Area (ss)
Groundwater, Surface Water, and Sediment
Monitoring and Groundwater Use
Restrictions/Mechanical Excavation of Site
Surface Soils and Fill Area, and Off-site
Disposal of Excavated Material, and Backfill
and Grade
Collection and Treatment
(gw)/Removal/Disposal of
Site Surface Soils and Fill
Area (ss)
Groundwater Pumping and Treatment,
Groundwater, Surface Water, and Sediment
Monitoring and Groundwater Use
Restrictions/Mechanical Excavation of Site
Surface Soils and Fill Area, Off-site Disposal of
Excavated Material, and Backfill and Grade
-------
Table 5
Beaunit ROD Comparison of Total Present Worth Costs for Remedial Alternatives
RI/FS of Beaunit Corp. Circular Knit and Dyeing Plant Site
Fountain Inn, South Carolina

Alternative High Low
Estimate Estimate

1 No Action $7,417 $3,461

2 Groundwater, Surface Water, and Sediment Monitoring and
Groundwater Use Restrictions $377,622 $176,151

3 Groundwater, Surface Water, and Sediment Monitoring and
Groundwater Use Restrictions/Grading-Drainage Control- $748,625 $349,159
Soil and Clay Cap

4 Groundwater Pumping Treatment, Groundwater, Surface
Water, and Sediment Monitoring and Groundwater Use $8,239,948 $3,845,376
Restrictions/Grading-Drainage Control-Soil and Clay Cap

5 Groundwater, Surface Water, and Sediment Monitoring and
Groundwater Use Restrictions/Mechanical Excavation of
"Hot Spots", Off-site Disposal of Excavated Material, and $1,370,675 $243,193
Backfill and Grade

6 Groundwater Pumping and Treatment, Groundwater, Surface
Water, and Sediment Monitoring, and Groundwater Use $8,865,058 $3,740,838
Restrictions/Mechanical Excavation of "Hot Spots", Off-site
Disposal of Excavated Material, and Backfill and Grade

7 Groundwater, Surface Water, and Sediment Monitoring, and
Groundwater Use Restrictions/Mechanical Excavation of $2,002,775 $934,429
Site Surface Soils and Fill Area, and Off-site Disposal of
Excavated Material, and Backfill and Grade

8 Groundwater Pumping and Treatment, Groundwater, Surface
Water, and Sediment Monitoring and Groundwater Use
Restrictions/Mechanical Excavation of Site Surface Soils $9,497,158 $4,432,074
and Fill Area, Off-site Disposal of Excavated Material, and
Backfill and Grade
-------
8.5.3 Alternative 3 - Groundwater, Surface Water, and Sediment Monitoring/Grading-Drainage Control-Soil
and Clay Cap and Deed Restrictions

Alternative 3 combines the institutional control general response action for groundwater and the
containment general response action for surface soil. Under this alternative, a monitoring program for
groundwater, stream surface water, and stream sediment will be implemented to provide a method for
identifying changes in the Site conditions. Groundwater samples will be collected from six of the
monitoring wells. Three surface water and sediment sampling locations (from the unnamed creek) will also
be sampled. Samples from these locations will be collected and analyzed semi-annually for the first two
years and annually for three years thereafter. The results will then be assessed for future monitoring
reguirements. Site monitoring will (1) provide early warning of unacceptable contaminant migration, and
(2) allow for a better understanding of the natural attenuation rates. If future monitoring indicates a
need for additional remedial action, such action will be considered. Contingent upon future groundwater
monitoring results from wells located on nearby properties, additional institutional controls (deed
notice) may be considered for such properties.

The "hot spot" at pipeline location P5 will be excavated and tested by TCLP procedures to insure that the
soil is not characteristically hazardous. Based on information gained during the RI, the soil should
pass TCLP criteria. If the "hot spot" soil fails the TCLP procedures and is characterized as hazardous,
then the soil will be excavated and sent to a RCRA Class C disposal facility. Assuming the criteria are
met, the excavated material will be placed within the fenced area. Initially a 5' by 5' grid will be
sampled. The extent of contamination will determine the amount of soil to be excavated. It is believed
that 2' of depth will be sufficient with an area 20' by 20' or less. A native soil/clay cap will be
placed over contaminated surface soil within the fenced area to serve as a barrier to potential
ecological receptors that may be exposed to the surface soils. The Site will be graded, the lagoon will
be backfilled, and 18 inches of clay will first be compacted over the graded surface soils. The waste
located on the east side of the lagoon will also be used to backfill the lagoon. The water currently in
the lagoon will not be removed. The cap will be placed over the filled lagoon. Then 12 inches of native
soil will be graded over the clay. The cap will have a maximum permeability of 1 x 10-5 cm/sec. The
natural soil will facilitate grass growth. Grass will provide erosion control. Approximately 5,000 yd3
of clay and 3,000 yd3 of soil will be reguired for the construction. These materials, at the reguired
thicknesses, will be spread and graded over the entire Site. The cap will be of appropriate gradient as
to facilitate direct stormwater run-off.

The grading work at the site will involve the use of heavy eguipment (such as dozers, loaders, scrapers,
and compactors) to spread and compact loose soil and modify the surface gradient. Grading the site will
control surface runoff and reduce erosion. After placement of a natural soil and clay cap, grass will
grow on the site and the site will be maintained by cutting the grass and periodically inspecting the cap
for damage. An earthen berm, ditch or other drainage control feature will also be constructed to divert
surface water away from and around the Site. Therefore, surface water run-off will not cause excessive
soil erosion and contaminant transport. Based on the gradient of the Site, drainage controls could be
constructed along the southern and southeastern border of the Site. The mid-point of the range of
present worth costs for Alternative 3 is $548,892.

A diagram of Alternative 3 is attached as Figure 13, and a detailed breakdown of the implementation costs
for this alternative is attached as Table 6.

8.5.4 Alternative 4 - Groundwater Pumping and Treatment/Grading & Drainage Control-Soil and Clay Cap
and Deed Restrictions

Alternative 4 combines the removal and treatment general response action for groundwater and the
containment general response action for surface soil. Deed restrictions are also included. Under this
alternative, groundwater will be pumped from monitoring wells that will be determined during the remedial
design. For cost and design estimation purposes, MW4S and MW5S have been designed as the extraction
wells. These wells will be pumped at a combined rate of approximately 5 gallons/minute. The
contaminants of concern include benzene, chromium VI, manganese, naphthalene, 2-methylnaphthalene, and
beryllium. To remove beryllium, chromium, and manganese a dual filtration cartridge system will be used.
The first cartridge will be a 3 micron filter. This cartridge will remove the larger particulate that
may foul the smaller (second) filtration cartridge. A precipitation system may also be needed prior to
the filtration system to remove silt or other larger particles, i.e., iron, manganese, and chromium.
-------
Table 6
Beaunit ROD
Remedial Technology Cost Estimates - Alternative 3
RI/FS of Beaunit Corp. Circular Knit and Dyeing Plant Site
Fountain Inn, South Carolina
Capital Cost
Annual Cost
Item
Technology
Grading, Drainage Control
Soil and Clay Cap (1)
Total

Technology
Groundwater and Surface
Water Monitoring (Years 1 & 2)
Total

Groundwater and Surface
Water Monitoring (Years 3 through 5)
Total

Engineering Management (Years 1 & 2)
Travel (2)
Per Diem (3)
Biannual Report Submittal (4)
Well Abandonment
Support Plans (H&S, SAP) (5)
RD Work Plan (6)
Design Plans (7)
Total

Engineering Management (Years 3 through 5)
Travel (2)
Per Diem (3)
Annual Report Submittal (4)
Total
High
Estimate
$225,000
$225,000

$1,312
$24,000
$24,000
$24,000
$73,312

$0
Low High
Estimate Estimate
$105,000 $3,750
$105,000 $3,750
$90,015
$0 $90,015
$58,500
$0 $58,500
$600
$1,800
$9, 600
$613
$11,200
$11,200
$11,200
$34,213 $12,000
$300
$900
$4,800
$0 $6,000
Low
Estimate
$1,750
$1,750
$42,007
$42,007
$27,300
$27,300
$280
$840
$4,480

$5, 600
$140
$420
$2,240
$2,800
-------
Construction Management
Bidding & Contracting (8)
Oversight (9)
Surveying (10)
TOTAL

Present Worth (Years 1 & 2)
Interest Rate
Number of Years
Present Worth Factor = [(1+i)-
Present Worth
$15,000
$24,000
$4,500
$43,500
(1+i) An
Present Worth (Years 3 through 5)
Interest Rate
Number of Years
Present Worth Factor = [ (1+i) An-l],/i (1+i) A (n+2)
Present Worth

Present Worth of Cap
Maintenance Cost (30 years)
Interest Rate
Number of Years
Present Worth Factor = [ (1+i) An-l]^i (1+i) An
Present Worth

Total Present Worth

Low and high estimates based on -30% to +50% variation.
(1) - Annual costs associated with maintenance activities
will accrue for 30 years.
(2) - Each trip, 4 days, $50/day
(3) - Each trip, 8 Man days, $75/day
(4) - Each report, 40 manhrs /report, $80/hr
(5) - 200 man-hr, $80/hr = $16,000
0.05
2
1.86
0.05
3
2.47
0.05
30
15.4
$7,000
$11,000
$2,100
$20,100
$0
$0
$531,560
$247,862
$159,315
$74,347
$57,750

$748,625
(6) - 200 man-hrs, $80/hr = $16,000
(7) - 200 man-hrs, $80/hr = $16,000
(8) - Lump Sum, $10,000
(9) - 200 man-hrs, $80/hr = $16000
(10) - Lump Sum, $3000
$26,950

$349,159
-------
The second filtration cartridge will be a 0.3-micron filter. This cartridge will remove the beryllium to
below 4 ug/L. The effluent from the submicron filtration cartridge will pass through a carbon adsorption
unit. The carbon adsorption unit will remove the benzene, naphthalene, and 2-methylnaphthalene. The
adsorption unit will hold approximately 180 Ibs. of carbon. The activated carbon system sized for the
groundwater characteristics and extraction rate from MW4S and MW5S will reguire carbon replacement every
60 days. The removed carbon will be sent off-site for regeneration or disposal. The effluent from the
carbon system will be discharged via a pipe to the unnamed creek. The entire water treatment unit will
be located on the Site property. A concrete foundation with a protective overhead shed will be
constructed to protect the units. The duration of groundwater treatment is based on the size of the
contaminated plume, pumping and treatment flow rates, and extraction efficiency (i.e., removal of
contaminants from the water bearing zone). The extent of contaminants in groundwater is expected to be
localized because the RI data did not indicate the existence of a significant plume. The pumping and
treatment flow rates are 5 gpm. For estimation purposes, it is assumed that water treatment would
continue for five years. Water samples will be collected monthly from the influent and effluent of the
treatment units to periodically verify that treatment standards are being met. Samples will be analyzed
for benzene, PNAs, beryllium, chromium VI, and manganese. After five years, an evaluation will be
conducted to determine if further treatment is necessary. After treatment has discontinued, a
groundwater, stream surface water, and stream sediment monitoring program similar to Alternative 2 will
be initiated. Treatment would not begin until each monitor well is sampled and groundwater samples are
analyzed at least one time to confirm the presence of the contaminants of concern (COCs) and their
concentrations. If future monitoring indicates a need for additional remedial action, such action will
be considered. Contingent upon future groundwater monitoring results from wells located on nearby
properties, additional institutional controls (deed notice) may be considered for such properties.

The "hot spot" at pipeline location P5 will be excavated, tested by TCLP procedures to insure it is not
characteristically hazardous. If the "hot spot" fails TCLP procedures and is characterized as hazardous,
then the soil will be excavated and sent to a RCRA Class C disposal facility. Assuming TCLP criteria are
met and the soil is not hazardous, then the excavated material will be placed within the fenced area. A
native soil/clay cap can be placed over contaminated surface soil within the fenced area to serve as a
barrier to potential ecological and human receptors that may be exposed to the surface soils. The Site
will be graded, the lagoon will be backfilled, and 18 inches of clay will first be compacted over the
graded surface soils. The waste located on the east side of the lagoon will also be used to backfill the
lagoon. The water currently in the lagoon will not be removed. The cap will be placed over the filled
lagoon. Then 12 inches of native soil will be graded over the clay. The cap will have a maximum
permeability of 1 x 10-5 cm/sec.

The natural soil will facilitate grass growth. Grass will provide erosion control. Approximately 5,000
yd3 of clay and 3,000 yd3 of soil will be reguired for the construction. These materials, at the
reguired thicknesses, will be spread and graded over the entire Site. The cap will be of appropriate
gradient as to facilitate direct stormwater run-off.

The grading at the Site involves the use of heavy eguipment (such as dozers, loaders, scrapers, and
compactors) to spread and compact loose soil and modify the surface gradient. Grading the site will
control surface runoff and reduce erosion. With the implementation of a natural soil and clay cap, grass
will grow on the site and the site will be maintained by cutting the grass and periodically inspecting
the cap for damage.

An earthen berm, ditch, or other drainage feature will be constructed to divert surface water away from
and around the Site. Therefore, excessive surface water run-off will be diverted from the Site and not
cause surface soil erosion and contaminant transport. Based on the gradient of the Site, drainage
control could be constructed along the southern and southeastern border of the Site. Deed restrictions
are also a component of Alternative 4. Costs for Alternative 4 in present worth have a mid-point of
$6,042,662.

8.5.5 Alternative 5 - Groundwater, Surface Water, and Sediment Monitoring/Excavation of "Hot Spots" and
Off-site Disposal and Deed Restrictions

Alternative 5 combines the institutional control general response action for groundwater and the removal
and off-site disposal general response actions for surface soil. Under this alternative, a monitoring
program for groundwater, stream surface water, and stream sediments will be implemented to provide a
method for identifying changes in the Site Conditions. Groundwater samples will be collected from six of
the monitoring wells. Three surface water and sediment sampling locations (from the unnamed creek) will
also be sampled. Samples from these locations will be collected and analyzed semiannually for the
first two years and annually for three years thereafter. The results will be assessed for future
monitoring reguirements. Site monitoring will (1) provide early warning of unacceptable contaminant
migration, and (2) allow for a better understanding of the natural attenuation rates. If future
-------
monitoring indicates a need for additional remedial action, such action will be considered. Contingent
upon future groundwater monitoring results from wells located on nearby properties, additional
institutional controls (deed notice) may be considered for such properties. Within the Site, surface
soil that contains COG concentrations above cleanup levels will be excavated and disposed at an off-site
landfill. Four surface soil samples collected during the RI had arsenic and/or nickel concentrations
above soil action levels. Additional soil samples will be collected in a 20-ft grid around the sampling
location. At the pipeline location P5, soil samples will be collected at the corners of a 5-ft grid.
The soil samples will be analyzed for arsenic and nickel and, if a sample from this additional sampling
exceeds the cleanup levels for arsenic or nickel, soil samples will be collected from a 20-ft grid around
that sampling location or a 5-ft grid for the pipeline location around the exceedance location.
Excavation will be completed within a boundary of soil sample locations that have nickel and arsenic
concentrations below their respective preliminary remediation goals.

A range of costs was developed for this option. The lower range assumes the surface soil excavation will
be limited to a volume of 20 ft by 20 ft by 2 ft around four RI sample locations (shown in Figure 3.6 of
the Feasibility Study) and a volume of 5 ft by 5 ft by 2 ft at pipeline location P5. This scenario
assumes all samples collected around the "hot spots" are below Remedial Goal Options (RGO's) for surface
soil. The total volume of excavation for this scenario is approximately 120 yd3. The higher range costs
for this Alternative assumes that all surface soils within the site will reguire excavation and disposal.
The total volume of excavation for this scenario is approximately 5,000 yd3. Additionally the cost of
surface soil sampling and analyses will be a significant part of the total cost of this option. Soil
will be excavated to a 2 ft. depth. The excavated soil will be transported to an off-site landfill for
disposal.

The soil may be disposed in a Subtitle D landfill if the soil is not characteristically hazardous. Based
on information gained during the RI, the soil would pass TCLP criteria and may be accepted for disposal
at an off-site solid waste landfill. If the soil should fail TCLP criteria and be characterized as
hazardous, the soils would be transported to a Subtitle C disposal facility, raising the cost of
Alternative 5 substantially.

The excavated areas will be backfilled and graded. The grading work at the site will involve the use of
heavy eguipment (such as dozers, loaders, scrapers, and compactors) to spread and compact loose soil and
modify the surface gradient. Grading the site will control surface runoff and reduce erosion. Grass
seeding will be used to grow grass within the excavated areas.

The extent of soil excavation will impact the number of analyses, amount of soil needing excavation,
amount of backfill reguired, and the amount of grading reguired following backfill.

The present worth costs of Alternative 5 are estimated to be in the range of $243,193 to $1,370,675, with
the mid-point of costs for this Alternative as $806,934.

8.5.6 Alternative 6 - Groundwater Pumping and Treatment/Excavation of "Hot Spots" and Off-site Disposal
and Deed Restrictions

Alternative 6 combines the removal and treatment general response action for groundwater and the removal
and disposal general response action for surface soil. Under this alternative groundwater will be pumped
from monitoring wells that will be determined during the remedial design. For cost and design estimation
purposes, MW4S and MW5S have been designed as the extraction wells. These wells will be pumped at a
combined rate of approximately 5 gallons/minute. The contaminants of concern include benzene, chromium
VI, manganese, naphthalene, 2-methylnaphthalene, and beryllium. To remove beryllium, a dual filtration
cartridge system will be used. The first cartridge will be a 3-micron filter. This cartridge will
remove the larger particulate that may foul the smaller (second) filtration cartridge. (A precipitation
system may also be needed prior to the filtration system to remove silt or other larger particles, e.g.,
iron, manganese, and chromium.) The second filtration cartridge will be a 0.3-micron filter. This
cartridge will remove beryllium to below 4 ug/L.

The effluent from the submicron filtration cartridge will pass through a carbon adsorption unit. The
carbon adsorption unit will remove the benzene, naphthalene, and 2-methylnaphthalene. The adsorption
unit will hold approximately 180 Ibs. of carbon. The activated carbon system sized for the groundwater
characteristics and extraction rate from MW4S and MWSS will reguire carbon replacement every 60 days.
The removed carbon will be sent off-site for regeneration or disposal. The effluent from the carbon
system will be discharged via a pipe to the unnamed creek.

The entire water treatment unit will be located on the Site property. A concrete foundation with a
protective overhead shed will be constructed to protect the units.
-------
The duration of groundwater treatment is based on the size of the contaminated plume, pumping and
treatment flow rates, and extraction efficiency (for example, removal of contaminants from the water
bearing zone). The extent of contaminants in groundwater is expected to be localized because the RI data
did not indicate the existence of a significant plume. The pumping and treatment flow rates are 5 gpm.
For estimation purposes, it is assumed that water treatment would continue for five years. Water samples
will be collected monthly from the influent and effluent of the treatment units to periodically verify
that treatment standards are being met. Samples will be analyzed for Benzene, poly nuclear aromatics
(PNA's), beryllium, chromium, and manganese. After five years, an evaluation will be conducted to
determine if further treatment is necessary. After treatment has discontinued, a groundwater, stream
surface water, and stream sediment monitoring program similar to Alternative 2 will be initiated.
Treatment will not begin until each monitoring well is sampled and analyzed at least one time to confirm
the presence of the COCs and their concentrations. If future monitoring indicates a need for additional
remedial action, such action will be considered. Contingent upon future groundwater monitoring results
from wells located on nearby properties, additional institutional controls (deed notice) may be
considered for such properties.

Within the Site, surface soil that contains COG concentrations above cleanup levels will be excavated and
disposed at an off-site landfill. Four surface soil samples collected during the RI had arsenic and/or
nickel concentrations above soil action levels. Additional soil samples will be collected in a 20-ft
grid around the sampling location. At the pipeline location P5, soil samples will be collected at the
corners of a 5-ft grid.

The soil samples will be analyzed for arsenic and nickel and, if a sample from this additional sampling
exceeds the cleanup levels for arsenic or nickel, soil samples will be collected from a 20-ft grid around
that sampling location or a 5-ft grid for the pipeline location around the exceedance location.
Excavation will be completed within a boundary of soil sample locations that have nickel and arsenic
concentrations below their respective preliminary remediation goals. A range of cost was developed for
this option. The lower range will assume the surface soil excavation will be limited to a volume of 20
ft by 20 ft by 2 ft around four RI sample locations and a volume of 5 ft by 5 ft by 2 ft at pipeline
location P5. This scenario assumes all samples collected around the "hot spots" are below RGOs for
surface soil. The total volume of excavation for this scenario is approximately 120 yd3. The higher
range units of excavation for removal of "hot spots" assumes that all surface soils within the site will
reguire excavation and disposal. The total volume of excavation for this scenario is approximately
5,000 yd3. Additionally the cost of surface soil sampling and analyses will be a significant part of the
total cost of this option. Soil will be excavated to a 2 ft. depth. The excavated soil will be
transported to an off-site landfill for disposal. The soil may be disposed in a Subtitle D landfill if
the soil is not characteristically hazardous. Based on information gained during the RI, the soil would
pass TCLP criteria and may be accepted for disposal at an off-site solid waste landfill. If the soil
should fail TCLP criteria and be characterized as hazardous, the soils would be transported to a Subtitle
C disposal facility, raising the cost of Alternative 6 substantially.

The extent of soil excavation will impact the number of analyses, amount of soil needing excavation,
amount of backfill reguired, and the amount of grading reguired following backfill.

Present worth cost estimates for Alternative 6 range from $3,740,838 to $8,865,058, with a mid-point cost
of $6,302,948.

8.5.7 Alternative 7 - Groundwater, Surface Water, and Sediment Monitoring/Excavation of Site Surface
Soils and Fill Area and Offsite Disposal

Alternative 7 combines the institutional control general response action for groundwater and a second
combined removal and disposal general response action for surface soil. Under this alternative, a
monitoring program for groundwater, stream surface water, and stream sediment will be implemented to
provide a method of identifying changes in the Site conditions. Groundwater samples will be collected
from six of the seven RI monitoring wells and from three surface water and sediment sampling locations
(from the unnamed creek). The routines for sampling and analyses will be the same as in Alternative 5.
Site monitoring will (1) provide early warning of unacceptable contaminant migration, and (2) allow for a
better understanding of the natural attenuation rates, If future monitoring indicates a need for
additional remedial action, such action will be considered. Contingent upon future groundwater
monitoring results from wells located on nearby properties, additional institutional controls (deed
notice) may be considered for such properties.

Within the Site, all surface soil and the fill material (located east of the lagoon) will be excavated,
contained and disposed off-site. With this option, surface soils within the site boundaries and at
pipeline location P5 (5 ft by 5 ft) will be excavated to 2 ft depth. Approximately 5,000 yd3 of surface
soil would reguire excavation. The fill area is approximately 1,800 yd3. The fill extends to an average
-------
of approximately 10 ft. Therefore approximately 6,000 yd3 would require excavation. The excavated soil
will be contained for disposal. The soil may be disposed in a Subtitle D landfill if the soil is not
characteristically hazardous. Based on information gained during the RI, the soil should pass TCLP
criteria and may be accepted to an off-site solid waste landfill. The excavated areas would then be
backfilled with natural soil. If the soil should fail TCLP criteria and be characterized as hazardous,
the soils would be transported to a Subtitle C disposal facility, raising the cost of Alternative 7
substantially.

Under Alternative 7, the existing lagoon would be backfilled and the entire site will be graded. The
grading work at the site will involve the use of heavy equipment (such as dozers, loaders, scrapers, and
compactors) to spread and compact loose soil and modify the surface gradient. Grading the site will
control surface runoff and reduce erosion. Grass seeding will be used to grow grass within the site.

The estimated present worth costs for Alternative 7 range from a low of $934,429 to a high of $2,002,775,
with a mid-point of $1,468,602.

8.5.8 Alternative 8 - Groundwater Pumping and Treatment/Excavation of Site Surface Soils and Fill Area
and Off-site Disposal

Alternative 8 combines the removal and treatment general response action for groundwater and a second
combined removal and disposal general response action for surface soil. Under this alternative
groundwater will be pumped from Monitoring wells that will be determined during the remedial design. For
cost and design estimation purposes, MW4S and MWSS have been initially chosen as the extraction wells.
These wells will be pumped at a combined rate of approximately 5 gallons/minute. The contaminants of
concern include benzene, chromium VI, manganese, naphthalene, 2-methylnaphthalene, and beryllium. To
remove beryllium, a dual filtration cartridge system will be used. The first cartridge will be a 3
micron filter. This cartridge will remove the larger particulate that may foul the smaller (second)
filtration cartridge. (A precipitation system may also be needed prior the filtration system to remove
silt or other larger particles, i.e., iron, manganese, and chromium.) The second filtration cartridge
will be a 0.3-micron filter. This cartridge will remove the beryllium to below 4 ug/L.

The effluent from the submicron filtration cartridge will pass through a carbon adsorption unit. The
carbon adsorption unit will remove the benzene, naphthalene, and 2-methylnaphthalene. The adsorption
unit will hold approximately 180 Ibs. of carbon. The activated carbon system sized for the groundwater
characteristics and extraction rate from MW4S and MWSS will require carbon replacement every 60 days.
The removed carbon will be sent off-site for regeneration or disposal. The effluent from the carbon
system will be discharged via a pipe to the unnamed creek.

The entire water treatment unit will be located on the Site property. A concrete foundation with a
protective overhead shed will be constructed to protect the units.

The duration of groundwater treatment is based on the size of the contaminated plume, pumping and
treatment flow rates, and extraction efficiency. The extent of contaminants in groundwater is expected
to be localized because the RI data did not indicate the existence of a significant plume. The pumping
and treatment flow rates are 5 gpm. For estimation purposes, it is assumed that water treatment would
continue for five years. Water samples will be collected monthly from the influent and effluent of the
treatment units to periodically verify that treatment standards are being met. Samples will be analyzed
for benzene, PNAs, beryllium, chromium, and manganese. After five years, an evaluation will be conducted
to determine if further treatment is necessary. After treatment has discontinued, a groundwater, stream
surface water, and stream sediment monitoring program similar to Alternative 5 will be initiated. Prior
to treatment, each well will be sampled and analyzed at least one time to confirm the presence of the
COCs and their concentrations. If future monitoring indicates a need for additional remedial action,
such action will be considered. Contingent upon future groundwater monitoring results from wells located
on nearby properties, additional institutional controls (deed notice) may be considered for such
properties.

Within the Site, all surface soil and the fill material (located east of the lagoon) will be excavated,
contained and disposed off-site. With this option, surface soils within the site boundaries and at
pipeline location P5 (5 ft by 5 ft) will be excavated to 2 ft depth. Approximately 5,000 yd3 of surface
soil would require excavation. The Fill area is approximately 1,800 yd3. The fill extends to an average
of approximately 10 ft. Therefore approximately 6,000 yd3 would require excavation. The excavated soil
will be contained for disposal. The soil may be disposed in a Subtitle D landfill if the soil is not
characteristically hazardous. Based on information gained during the RI, the soil should pass TCLP
criteria and will be accepted to an off-site solid waste landfill. The excavated areas would then be
backfilled with natural soil. If the soil should fail TCLP criteria and be characterized as hazardous,
the soils would De transported to a Subtitle C disposal facility, raising the cost of Alternative 8
-------
substantially.

Under this alternative the existing lagoon will be backfilled and the entire site will be graded. The
grading, work at the site will involve the use of heavy eguipment (such as dozers, loaders, scrapers, and
compactors) to spread and compact loose soil and modify the surface gradient. Grading the site will
control surface runoff and reduce erosion. Grass seeding will be used to grow grass within the site.

The range of present worth costs for Alternative 8 range from a low of $4,432,074 to $9,497,158, with a
mid-point of $6,964,616.

9.0 COMPARATIVE ANALYSIS OF ALTERNATIVES

The NCP lists nine criteria to serve as the basis for conducting the alternative screening and detailed
analysis during the feasibility study, and for subsequently selecting an appropriate remedial action.
The evaluation criteria are as follows:

• Overall protection of human health and the environment

• Compliance with ARARs

• Long-term effectiveness and permanence

• Short-term effectiveness

• Reduction of toxicity, mobility, and volume through treatment

• Implementability

Cost

• State Acceptance

• Community Acceptance

EPA has established criteria for use in comparing the advantages/disadvantages of each alternative. The
nine evaluation criteria fall into three groups: threshold criteria, primary balancing criteria, and
modifying criteria. The first two criteria, threshold criteria, are essential and must be met before an
alternative is considered further. The next five criteria, primary balancing criteria, are used to
further evaluate all options that meet the first two criteria. The final two criteria, modifying
criteria, are used to further evaluate EPA' s Proposed Plan after public and State comments have been
received.

The following discussion compares the various alternatives to the criteria.

9.1 Overall Protection of Human Health and the Environment

This criterion is used to assess whether a remedial alternative provides adequate protection of human
health and the environment. The overall assessment takes into account the assessments conducted under
all other evaluation criteria, especially long and short-term effectiveness and compliance with ARARS.
The assessment of overall protection should focus on whether an alternative achieves adequate protection,
and should describe how site risks are reduced, controlled, or eliminated by the implementation of the
alternative.

Relative to groundwater concerns, the alternatives without groundwater pumping and treatment
(Alternatives 1,2,3,5,7) will have decreases in the concentrations of organic contaminants through
natural attenuation. While metals would tend to persist, migration of metals was not observed during the
RI. Alternatives with pump and treatment of groundwater (Alternatives 4,6) would enhance the speed of
the reduction of organic contaminants. Groundwater monitoring and use restrictions of all alternatives
except the no action alternative would preclude exposure to the groundwater and provide early warning of
unacceptable contaminant migration.

Relative to surface soil, alternatives 1 and 2 do not reduce risks to ecological receptors. All other
alternatives eliminate risk to area biota.
-------
9.2 Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)

This criterion is used to determine whether each remedial alternative complies with ARARS, as defined in
CERCLA Section 121 (d).

All non pump and treat alternatives will not immediately meet chemical-specific ARARs including MCLs, but
the concentrations of organic contaminants of concern in groundwater will decrease over time (about 5
years) through natural attenuation and will be in compliance with chemical specific ARARs. While metals
would tend to persist, monitoring and groundwater use restrictions would prevent exposure and provide
warning of contaminant migration, as yet undetected. Groundwater pump and treat alternatives would
provide compliance sooner than non pump and treat alternatives.

Relative to action-specific ARARs, Alternatives 3 through 8 comply with reguirements of the SC
Groundwater Use Act (Title 49, Chapter 5) and the SC Stormwater Management and Sediment Reduction Act
(Title 48, Chapter 14) relative to monitoring wells and excavation of surface soils. Alternatives 3
through 8 shall also comply with RCRA as an ARAR with the respective characterization of "hot spot" or
surface soils determining whether disposal can be on-site within the fence or off-site at a Subtitle C or
Subtitle D facility. Subtitle C facility disposal would be necessary for any soil characterized as
hazardous. Non-hazardous soils could be disposed at a Subtitle D landfill, or moved within the fenced
area. No location specific ARARs have been identified for the site.

9.3 Cost

The cost estimates for implementing an alternative are addressed by the following factors:

• Capital Costs: The direct and indirect capital costs for each remedial alternative are
evaluated. Direct capital costs may include construction, eguipment, land and site development,
buildings and services, and waste disposal costs. Indirect capital cost may include engineering
expenses, legal fees, license or permit costs, start-up costs, and contingency allowances.

• Operation and Maintenance Cost: Operation and maintenance (O&M) costs are post-construction
costs necessary to maintain the effectiveness of a remedial action. These costs include raw
material costs, maintenance materials and labor costs, operating labor costs, energy, disposal
of residues, insurance, taxes, costs of periodic site reviews, and licensing.

• Present Worth: Present worth analysis allows the evaluation of future expenditures for each
remedial alternative relative to a common base year. It is a combination of capital costs and
the present worth of operation and maintenance costs over the life of the remedy.

A summary of the present worth cost which includes the capital as well as the operation and maintenance
cost for each of the alternatives is presented within the explanation of the alternative.

9.4 Implementability

This criterion addresses the technical and administrative feasibility of implementing an alternative and
the availability of services and materials for its implementation. The following factors are analyzed by
this criterion:

• Technical feasibility: this factor addresses the difficulties and unknowns associated with the
remedial technologies proposed in each alternative as well as their reliability. Most treatment
alternatives will reguire some level of predesign testing. Bench and pilot-scale testing may be
reguired for technologies that are not proven.

• Administrative feasibility: this factor addresses the level of agency activity needed to
coordinate the implementation of an alternative.

• Availability of services and materials: this factor addresses the availability of adeguate
treatment, storage, or disposal facilities, the availability of vendors, and the availability of
necessary eguipment reguired for implementing an alternative.

The implementability of an alternative is based on technical feasibility, administrative feasibility and
the availability of services and materials. All components of each alternative are both technically and
administratively feasible. The design and construction of soil caps is commonly done. Soil excavation
and removal would be difficult and reguire significant administrative reguirements, but is commonly done.
Necessary technology, services, and materials are all readily available. Pump and treat remedies are
commonly installed at Superfund Sites, although due to the long term reguirements of these remedies,
-------
their effectiveness has not been fully determined at many other sites.

9.5 Short Term Effectiveness

This criterion addresses the effects of each alternative during the construction and implementation phase
until the remedial response objectives have been attained. The following factors of this criterion are
addressed for each remedial alternative:

• Potential impacts on the community during implementation of remedial alternatives: this factor
addresses risk that results from the implementation of remedial alternatives, such as air
pollutant emissions that might affect community health.

• Potential impacts on workers during implementation of remedial alternatives: this aspect of
short-term effectiveness addresses threats that might be posed to workers during the
implementation of a remedial alternative, as well as the effectiveness and reliability of
protective measures that will be implemented onsite to mitigate those threats.

• Potential environmental impacts: this factor addresses the potential adverse effects on the
environment resulting from the construction and implementation of an alternative, and the
effectiveness and reliability of measures that may be taken to mitigate the adverse effects.

• Time until protection is achieved: this factor addresses the time reguired from the time that a
technology is chosen until the remedial objectives are met. This factor also includes delays in
implementing the technology, as well as the period of time that the technology.

During the implementation of all the alternatives, both onsite workers and people surrounding the site
will be protected from possible impacts caused by construction activities. Risks from cap installation
or soil excavation and removal would be addressed in health and safety plans. Installation of a cap
would be immediately effective in reducing leaching from soils into the groundwater. There is no risk to
the environmental receptors from implementation of any remedy, although habitats would be disrupted
during installation activities. Community risks from construction truck traffic would be short term and
safety could be insured by additional signage and traffic control.

9.6 Long-Term Effectiveness and Permanence

This criterion addresses the extent of residual risk at the Site after the remedial objectives have been
met. In addition, this criterion will address whether conditions that pose unacceptable risks may
reoccur at some point after the remediation is complete. The following factors are addressed by this
criterion:

• Permanence: this factor addresses the permanence of remedies for the Site.

• Magnitude of total residual risk: this factor assesses the long-term risk associated with
exposure to treatment residuals and untreated residual contamination.

• Adeguacy and reliability of controls: this factor addresses the type and degree of long-term
management, monitoring, and operation and maintenance functions that must be performed. This
factor also addresses the ability of technologies to meet the reguired process efficiencies or
performance specifications.

• Need for periodic review: this factor addresses the adeguacy and suitability of controls, if
any, that are used to manage treatment residuals or untreated wastes that remain on-site. It
includes the assessment of potential exposure and the associated risks should the remedial
action need replacement.

• Certainty of Success: this factor addresses the level of confidence for the chosen technologies
to meet the remedial criteria.

All of the alternatives under consideration by EPA in this Record of Decision were evaluated for this
criteria under each of its components consisting of 1) permanence, 2) magnitude of residual risk, 3)
adeguacy and reliability of controls, 4) need for periodic review, and 5) certainty of success. Relative
to permanence and magnitude of residual risk, Alternatives 1,2,3,5, and 7 only reduce risk in groundwater
after natural attenuation processes are complete. Pump and treat Alternatives 4,6, & 8 will reduce risks
from groundwater more guickly. Alternatives 1 and 2 do not reduce ecological risks while all other
alternatives do. Adeguacy and reliability of controls for all alternatives is generally good with the
proviso that institutional controls in Alternative 2 are dependent on tight governmental control. All
-------
alternatives involving regular monitoring will reguire periodic review as will alternatives involving
capping the site. Alternatives involving excavation and soil replacement will not reguire periodic
review. All alternatives have approximately the same certainty of success wish the pump and treat
alternatives having the ability to meet Remedial Action Objectives more guickly.

9.7 Reduction of Toxicity, Mobility, and Volume

This criterion addresses the preference stated in CERCLA Section 121 that remedial alternatives be
selected which employ technologies that permanently and significantly reduce the toxicity, mobility, or
volume of contaminants. This preference is satisfied when treatment is used to reduce the principal
threats at a site through destruction of toxic contaminants, reduction of the total mass of toxic
contaminants, irreversible reduction in contaminant mobility, or reduction of total volume of
contaminated media. The following specific factors are taken into consideration:

• Treatment or recycling processes;

• Reduction of toxicity, mobility and volume of potential contaminants of concern in each medium
of concern; and

• Degree to which treatment is irreversible.

This criteria was evaluated for each of its components consisting of 1) treatment used, 2) reduction of
toxicity, mobility, or volume, 3) type and guantity of residuals remaining after treatment, and 4)
irreversibility of treatment. Only pump and treat alternatives involve treatment and are considered
irreversible. Such treatment will generate residuals which will reguire off-site disposal Alternatives
involving soil excavation and removal will reduce the toxicity, mobility, and volume by removal of the
contaminated soils. Capping alternatives will reduce the mobility of the contaminants, while soil
excavation remedies are considered irreversible.

9.8 State Acceptance

The State of South Carolina's Department of Health and Environmental Control was consulted during the
drafting of both the Proposed Plan and this Record of Decision. SCDHEC has concurred with this Record of
Decision. A copy of the State Concurrence letter is attached as Appendix A.

9.9 Community Acceptance

The purpose of this Record of Decision and the upcoming comment period is to encourage input from the
public during the remedy selection process. No adverse comments were received during the public comment
period to the then-Proposed Plan for the Site. The few comments that were received are contained with an
Agency response in the Responsiveness Summary attached to this document as Appendix B.

10.0 SELECTED REMEDY

10.1 Preferred Alternative Summary

In summary, based on all information available at this time, EPA has selected and supports a modification
to Alternative 3: Groundwater, Surface Water, and Sediment Monitoring and Groundwater Use
Restrictions/Grading-Drainage Control-Soil and Clay Cap and Deed Restrictions, as the selected remedy for
the Beaunit Site. The only modification to Alternative 3 as described earlier in this Record of Decision
and within the Feasibility Study is the design specifications for the Cap. Both EPA and SCDHEC concur
that the cap should be designed to meet a specification of 10-9 permeability, rather than the 10-5
permeability contained in the alternative as developed in the Feasibility Study. The change was based on
modeling the site with the Summers model, commonly used to predict effectiveness in caps to prevent
leaching from soils of contaminants. EPA and SCDHEC feel the higher degree of impermeability of a cap
built to 10-9 specifications would insure that the RGO's would be met in the groundwater. The exact
details of the construction of the cap will be determined during the Remedial Design. Several
assumptions were made during EPA/SCDHEC change in design specifications for the cap. Utilizing cost
comparisons to other recent 10-9 cap designs for sites in this area capital costs are estimated to be
$32,000 additional for the site remedy. Several modeling runs of caps that could achieve 10-9 were
performed on RACER software.(Remedial Action Cost Engineering and Reguirements System, Dept. of Air
Force, 1993). From those efforts, it is believed that the capital cost of the Modified Alternative 3
site cap would be between $212,000 to $220,000, below the $225,000 high range of the Feasibility Study
estimate of capital costs for the 10-9 cap. EPA believes that a conservative estimate of the total costs
for the Selected Remedy, the modified Alternative 3 is $580,882. This alternative represents the best
balance among the criteria used to evaluate remedies. Under this selected remedy a monitoring program
-------
for groundwater, stream surface water, and stream sediment will be implemented to provide a method of
identifying changes in the Site conditions. Groundwater samples will be collected from six of the seven
RI monitoring wells and from three surface water and sediment sampling locations (from the unnamed
creek) . Site monitoring will (1) provide early warning of unacceptable contaminant migration, and (2)
allow for a better understanding of the natural attenuation rates. If future monitoring indicates a need
for additional remedial action, such action will be considered. Contingent upon future groundwater
monitoring results from wells located on nearby properties, additional institutional controls (deed
notice) may be considered for such properties. The modified Alternative 3 is believed to be protective
of human health and the environment, would attain ARARs, would be cost effective, and would utilize
permanent solutions and alternative treatment technologies or resource technologies to the maximum extent
practicable.

Alternatives 1 and 2, i.e., no action and institutional controls, do not specifically address the risks
to potential ecological receptors. Alternatives 3 through 8 would achieve the RAOs for the Site.
Alternative 3 would achieve the RAOs for the Site more cost effectively than Alternatives 4 through 8.

10.2 Applicable or Relevant and Appropriate Requirements (ARARs)

ARARs originate from applicable reguirements, intended to definitely and specifically apply to a remedial
action; or relevant and appropriate reguirements, which, while not intended to apply to the specific
situation in guestion, EPA judges to be applicable to a remedial action. In addition, when establishing
criteria for ensuring the proper implementation of a remedial action, EPA may develop reguirements from
other guidance documents and criteria, sources often referred to as "To Be Considered" material (TBC).
Attached Tables 7, 8, 9, 10 and 11 summarize potential ARARs, both Federal and State. Table 12 lists "To
Be Considered" material.

10.2.1 Applicable Requirements

Soil remediation shall comply with all applicable portions of the following Federal and State of South
Carolina regulations:

49 CFR Parts 107, 171-179, promulgated under the authority of the Hazardous Materials Transportation Act.
Regulates the labeling, packaging, placarding, and transport of hazardous materials off-Site.

40 CFR Parts 261, 262 (Subparts A-D), 263, and 268, promulgated under the authority of the Resource
Conservation and Recovery Act. These regulations govern the identification, transportation,
manifestation, and land disposal restriction reguirements of hazardous wastes. If the contaminated soils
fail TCLP, most likely, the land disposal restrictions in 40 CFR Part 268 will apply. In the event that
the Site soils reguiring remediation do not test hazardous (i.e., do not fail TCLP), the regulations
listed here will be considered relevant and appropriate rather than applicable.

SCKWMR 61-79.124, 79.261, 79.262, 79.263 and 79.268, South Carolina Hazardous Waste Management
Regulations, promulgated pursuant to the Hazardous Waste Management Act, SC Code of Laws, 1976, as
amended, establishes criteria for identifying and handling hazardous wastes, as well as land disposal
restrictions. These regulations also will become relevant and appropriate in the event that the soils
reguiring remediation do not prove to be hazardous, as described in the above paragraph.

10.2.2 Relevant and Appropriate Requirements

The following regulations are "relevant and appropriate" to source control actions (soil remediation) at
the Site. Applicability of these air guality control regulations is due to the potential for release of
harmful particulates (metals) or VOCs during soil excavation and handling activities.

40 CFR Parts 60 and 61, 42 U.S.C. § 7401 et. seg. promulgated under the authority of the Clean Air Act.
Included are the National Emissions Standards for Hazardous Air Pollutants (NESHAPs). Ambient air
guality standards and standards for emissions to the atmosphere fall under these regulations.

SC Reg. 61-62, South Carolina Air Pollution Control Regulations and Standards, promulgated pursuant to
the S.C. Pollution Control Act, SC Code of Laws, 1976, as amended. Establishes limits for emissions of
hazardous air pollutants and particulate matter, and establishes acceptable ambient air guality standards
within South Carolina.
-------
Table 7
Beaunit ROD
Standard, Requirement,
Criteria, or Limitation

RESOURCE CONSERVATION
AND RECOVERY ACT

Identification and Listing
of Hazardous Waste
RCRA Maximum Concentration
Limits

Treatment Standards
SAFE DRINKING WATER ACT

SDWA Maximum Contaminant
Limits (MCL)

CLEAN WATER ACT

Ambient Water
of
Quality Criteria
lead to
Toxic Pollutant
Effluent Standards
Citation

42 USC 6901
40 CFR 261
Subparts C and D
40 CFR 264.94
40 CFR 268
Subpart D
42 USC 300

40 CFR 141 and 143

33 USC 1251-1376

(presented in CERCLA

Compliance...Manual

40 CFR 129
Federal Chemical-Specific ARARs
RI/FS Of Beaunit Corp. Circular Knit And Dyeing Plant Site
Fountain Inn, South Carolina
Applicable/
Relevant and
Description Appropriate
Defines those solid wastes that are subject to
and regulated as hazardous wastes under
40 CFR 124, 262-265, 268, 270, AND 271

Standards for 14 hazardous constituents as
a part of RCRA groundwater protection standards

Treatment standards for hazardous wastes
or hazardous waste extracts before land
disposal is allowed
Standards for select organic compounds, minerals,
or metals that are enforceable standards for
public drinking water systems
Suggested ambient standards for the protection

of human health and aguatic life
Establishes effluent standards or prohibitions
for certain toxic pollutants: aldrin/dieldrin,
DDT, endrin, toxaphene, benzidine, PCBs
No
No
No
Yes
Yes
Comment
RCRA ARARs may be applicable
should "hot spot" soils fail
TCLP procedures and are
characterized as hazardous

See above.
See above.
No
MCLs are relevant and appropriate for a
Class IIB groundwater designation
Some possible alternatives involve discharge

treatment residues into a drainage body which

larger water systems

These pollutants have not been identified as
chemicals of concern at the Site
-------
Table 7 (cont.)
Beaunit ROD
Standard, Requirement,
Criteria, or Limitation
Citation
Federal Chemical-Specific ARARs
RI/FS Of Beaunit Corp. Circular Knit And Dyeing Plant Site
Fountain Inn, South Carolina
Applicable/
Relevant and
Description Appropriate
Comment
CLEAN AIR ACT
42 USC 1857-18571
National Emission
Standards for Hazardous
Air Pollutants
40 CFR 61
Standards for specific constituents from
specific point sources
No
Air stripping was removed as an option.
FEDERAL INSECTICIDE,
FUNGICIDE, AND
RODENTICIDE ACT
7 USC 136
Pesticide Registration and
Classification Procedures
40 CFR 152
Defines those substances regulated under FIFRA
as pesticides
No
Tolerances and exemptions
from Tolerances for Pesticide
Chemicals In or On Raw
Agricultural Commodities
40 CFR 180
Sets allowable concentrations of residual pesticides,
including dicamba, in plant and animal commodities
No
-------
Standard, Requirement,
Criteria, or Limitation

SOUTH CAROLINA NPDES
PERMIT REGULATIONS

Toxic Pollutant Effluent Standards
Citation
Table 8
Beaunit ROD

Federal Chemical-Specific ARARs
RI/FS Of Beaunit Corp. Circular Knit And Dyeing Plant Site
Fountain Inn, South Carolina
Applicable/
Relevant and
Description Appropriate
Comment
Title 61
Chapter 9

Regulation 61-9.129
SOUTH CAROLINA
SAFE DRINKING WATER

REGULATIONS

Maximum Contaminant Levels in
Drinking Water
Chapter 61
Regulation 58.5
SOUTH CAROLINA WATER
CLASSIFICATION STANDARDS

General rules and standards
applicable to all waters

Class descriptions and specific
standards for surface waters

Class descriptions and specific

standards for groundwaters
Chapter 61

Regulation
Section E

Regulation
Section F

Regulation

Section G
Establishes effluent standards or prohibitions for
toxic pollutants.
Yes
Establishes the maximum concentration of
contaminants allowed in drinking water.
State standards that set contaminant levels for all Yes
state waters.

State class identification system and applicable Yes
surface water quality standards.

State class identification system and applicable Yes

groundwater quality standards.
The substantive requirements of the SC NPDES
Regulations may be relevant and appropriate
during Site remediation because some
alternatives will entail discharge of treated
effluent from a groundwater pump and treat
system.
Yes May be applicable because benzene,
beryllium and manganese were
detected in groundwater samples
at concentrations greater than
their respective State drinking
water standards
-------
Table 8 (cont.)
Beaunit ROD
Standard, Requirement,
Criteria, or Limitation
Citation
Federal Chemical-Specific ARARs
RI/FS Of Beaunit Corp. Circular Knit And Dyeing Plant Site
Fountain Inn, South Carolina
Description
Applicable/
Relevant and
Appropriate
Comment
Classified Waters
SOUTH CAROLINA
HAZARDOUS WASTE
MANAGEMENT REGULATIONS
Regulation 69

Chapter 61
Criteria and class listing for applicable streams in
the State of South Carolina.
Yes
An unnamed creek discharges to Howards
Branch which is a classified water.
Groundwater Protection:
Concentration Limits
Regulation 61-79.264
Subpart F
Section 264.94
Establishes concentration limits in the groundwater
for hazardous constituents.
Yes
SOUTH CAROLINA AMBIENT
AIR QUALITY CONTROL ACT

Ambient Air Quality Standards
Toxic Air Pollutants:
Toxic Air Emissions
Regulation 61-62.5
Standard No. 2
Standard No.
Section II
Establishes ambient air quality standards and No
analytical methods for sulfur dioxide, total
suspended particulates, PM10, carbon monoxide,
ozone, gaseous fluorides, nitrogen dioxide, and lead.

Establishes allowable ambient air concentrations for No
toxic air pollutants.
-------
Table 9
Beaunit ROD

Federal Chemical-Specific ARARs
RI/FS Of Beaunit Corp. Circular Knit And Dyeing Plant Site
Fountain Inn, South Carolina
Standard, Requirement,
Criteria, or Limitation

RESOURCE CONSERVATION
AND RECOVERY ACT
Citation

42 USC 6901-6987
Description
Applicable/
Relevant and
Appropriate
Comment
Guidelines for the Thermal Processing 40 CFR 240
of Solid Wastes
Guidelines for the Land Disposal of
Solid Wastes
40 CFR 241
Guidelines for the Storage and 40 CFR 243
Collection of Residential, Commercial,
and Institutional Solid waste
Establishes guidelines applicable to thermal
processing (incineration) facilities designed to
process 50 tons or more of municipal solid wastes

Establishes minimum guidelines applicable to land
disposal facilities receiving nonhazardous solid
wastes, including siting, access, design, and
operating conditions

Establishes guidelines for the collection of
residential, commercial, and institutional solid
wastes, including guidelines on the types of
containers and collection frequency
No
No
No
Criteria for Classification of Solid 40 CFR 257
Waste Disposal Facilities and Practices
Establishes criteria for use in determining which
solid waste disposal facilities and practices pose a
reasonable probability of adverse effects on health or
the environment
No
Criteria for Municipal Solid Waste
Landfills
40 CFR 258
Establishes minimum national criteria for municipal
solid waste landfills to ensure protection of human
health and the environment, including siting
restrictions, monitoring, corrective action, and post-
closure care
No
Hazardous Waste Management
Systems General
40 CFR 260
Establishes procedures and criteria for modification
or revocation of any provision in 40 CFR 260-26.5
No
Standards Applicable to Generation of 40 CFR 262
Hazardous Waste
Establishes standards for generators of hazardous
waste
No
Standards Applicable to Transporters 40 CFR 263
of Hazardous Waste
Establishes standards which apply to persons
transporting hazardous waste within the U.S. if the
transportation requires a manifest under 40 CFR
262.
No
-------
Standard, Requirement,
Criteria, or Limitation
Citation
Table 9 (cont.)
Beaunit ROD

Federal Chemical-Specific ARARs
RI/FS Of Beaunit Corp. Circular Knit And Dyeing Plant Site
Fountain Inn, South Carolina
Description
Applicable/
Relevant and
Appropriate
Comment
Standards for Owners and Operation of 40 CFR 264
Hazardous Waste Treatment, Storage,
and Disposal Facilities
General Facility Standards Subpart B

Preparedness and Prevention Subpart C

Contingency Plan end Emergency Subpart D
Procedures

Manifest System Record-keeping, Subpart E
and Reporting

Releases from Solid Waste Subpart F
Management Units

Closure and Post-closure Subpart G

Financial Requirements Subpart H

Use and Management of Subpart I
Containers

Tanks Subpart J

Surface Impoundments Subpart K

Waste Piles Subpart L

Land Treatment Subpart M

Landfills Subpart N

Incinerators Subpart 0

Miscellaneous Units Subpart X
Establishes minimum national standards which
define the acceptable management of hazardous
waste for owners and operators of facilities which
treat, store, or dispose of hazardous waste
No
No

No
-------
Table 9 (cont.)
Beaunit ROD
Standard, Requirement,
Criteria, or Limitation

Interim Standards for Owners and
Operators of Hazardous Waste
Treatment, Storage, and Disposal
Facilities
Citation

40 CFR 265
Federal Chemical-Specific ARARs
RI/FS Of Beaunit Corp. Circular Knit And Dyeing Plant Site
Fountain Inn, South Carolina
Description
Applicable/
Relevant and
Appropriate
Established minimum national standards that define
acceptable management of hazardous waste during
the period of interim status and until certification of
final closure or, if the facility is subject to post-
closure requirements, until post-closure
responsibilities are fulfilled
No
Comment

Remedies should be consistent with
the more stringent Part 264
standards as these represent the
ultimate RCRA compliance
standards and are consistent with
CERCLA's goal of long-term
protection of human health and the
environment
Standards for the management of
Specific Hazardous Wastes and
Specific Types of Hazardous Waste
Management Facilities
40 CFR 266
Establishes requirements which apply to recyclable
material that are reclaimed to recover economically
significant amounts of precious metals, including
gold and silver
No
Interim Standards for owners and
Operators of New Hazardous Land
disposal Facilities
40 CFR 267
Establishes minimum national standards that define
acceptable management of hazardous waste for new
land disposal facilities
No
Remedies should be consistent with
the more stringent Part 264
standards as these represent the
ultimate RCRA compliance
standards and are consistent with
CERCLA's goal of long-term
protection of human health and the
environment
Land Disposal

Hazardous Waste Permit Program
40 CFR 268
40 CFR 270
Establishes a timetable for restriction of burial of No
wastes and hazardous materials

Establishes provision covering basic EPA No
permitting requirements
Substantive requirements are
addressed in 40 CFR 264
A permit is not required for on-site
CERCLA response action.
Underground Storage Tanks
40 CFR 280
Establishes regulations related to underground
storage tanks
No
-------
Table 9 (cont.)
Beaunit ROD
Standard, Requirement,
Criteria, or Limitation
Citation
Federal Chemical-Specific ARARs
RI/FS Of Beaunit Corp. Circular Knit And Dyeing Plant Site
Fountain Inn, South Carolina
Description
Applicable/
Relevant and
Appropriate
Comment
SAFE DRINKING WATER ACT

National Primary Drinking Water
Regulations

Underground Injection Control
Regulations

CLEAN WATER ACT

National Pollutant Discharge
Elimination System
National Pretreatment Standards
40 USC 300

40 CFR 141

40 CFR 144-147

33 USC 1251-1376

40 CFR 125
40 CFR Part 403
Specifies sampling, analytical, and monitoring
requirements

Provides for protection of underground sources of
drinking water
Requires permits for the discharge of pollutants
from any point source into waters of the United
States.
Sets standards to control pollutants which pass
through or interfere with treatment processes in
publicly owned treatment works or which may
contaminate sewage sludge
No
No
Yes
No
A permit is not required for on-site
CERCLA response actions, but the
substantive requirements would
apply
CLEAN AIR ACT
42 USC 1857-18571
Standards of Performance for
incinerators

National Emission Standards for
Hazardous Air Pollutants

OCCUPATIONAL SAFETY AND
HEALTH ACT
40 CFR 60
Subpart E

40 CFR 61
29 USC 651-678
Sets performance standards and test methods for No
evaluation of performance

Stipulates monitoring requirements for emissions of No
specific contaminants

Regulates worker health and safety Yes
Under 40 CFR 300,150,
requirements of the Act apply to all
response activities under the NCP
-------
Table 9 (cont.)
Beaunit ROD
Federal Chemical-Specific ARARs
RI/FS Of Beaunit Corp. Circular Knit And Dyeing Plant Site
Fountain Inn, South Carolina
Standard, Requirement,
Criteria, or Limitation
Citation
Description
Applicable/
Relevant and
Appropriate
Comment
HAZARDOUS MATERIALS
TRANSPORTATION ACT
40 USC 1801-1813
Hazardous Materials Transportation
Regulations
49 CFR 107, 171-177
Regulates transportation of hazardous materials
FEDERAL INSECTICIDE,
FUNGICIDE, AND RODENTICIDE
ACT
Yes May be relevant and appropriate for
transportation of contaminated soils
or fill materials from the Site to an
off-site landfill. Alternatives 5
through 8 include the off-site
disposal option.
7 USC 136
Regulation for the Acceptance of
Certain Pesticides and Recommended
Procedures for the Disposal and
Storage of Pesticides and Pesticides
Containers
40 CFR 165
Recommended procedures for pesticides and
pesticides containers disposal
No
-------
Table 10
Beaunit ROD
Standard, Requirement,
Criteria, or Limitation

SOUTH CAROLINA
POLLUTION CONTROL ACT
SOUTH CAROLINA
GROUNDWATER USE ACT
SOUTH CAROLINA
STORMWATER MANAGEMENT
AND SEDIMENT REDUCTION
surface soils.
Citation

Title 48
Chapter 1

Section 48-1-100
Section 48-1-110
Title 49
Chapter 5
Title 48
Chapter 14
Federal Chemical-Specific ARARs
RI/FS Of Beaunit Corp. Circular Knit And Dyeing Plant Site
Fountain Inn, South Carolina
Description
Permits for discharge of water or air contaminants;
jurisdiction of Department.
Permits required for construction or alteration of
disposal system; classification; unlawful operation
or discharges

Establishes procedures to be followed to obtain a
permits to withdraw, obtain, or use groundwater and
for the submission of information concerning the
amount of groundwater withdrawal, its intended use,
and proposed aquifers.

Establishes criteria for the acceptable management
of stormwater and sediments during land disturbing
activities.
Applicable/
Relevant and
Appropriate
Comment
Yes
No
Yes
Yes
Substantive requirements may be relevant and
appropriate during Site remediation because some
alternatives will entail discharge of treated effluent
from a groundwater pump and treat system.
Relevant and appropriate for institutional controls
such as abandonment of monitoring wells.
May be relevant and appropriate during Site
remediation because some alternatives entail actions
that will disturb land surface, e.g., excavation of
SOUTH CAROLINA NPDES
PERMIT REGULATIONS
SOUTH CAROLINA SAFE
DRINKING WATER
REGULATIONS
Title 61
Chapter 9
Chapter 61
Establishes treatment standards and permitting
requirements.
Establishes criteria and standards to ensure the
safety of public water supplies.
Yes NPDES permitting is not required at CERCLA sites;
however, substantive requirements may be relevant
and appropriate during site remediation.

Yes May be relevant and appropriate.
-------
Table 10 (cont.)
Beaunit ROD
Standard, Requirement,
Criteria, or Limitation

SOUTH CAROLINA
STORMWATER MANAGEMENT
REGULATIONS

SOUTH CAROLINA SOLID
WASTE MANAGEMENT ACT

Approval procedures for special
wastes.
Citation

Chapter 72
Title 44
Chapter 96

Section 44-96-390
Federal Chemical-Specific ARARs
RI/FS Of Beaunit Corp. Circular Knit And Dyeing Plant Site
Fountain Inn, South Carolina
Description

Establishes standards for the acceptable
management of stormwater and sediments during
land disturbing activities.
Defines special wastes and delineates the minimum
requirements for the waste analysis plan and
approval procedures for the disposal of special
wastes.
Applicable/
Relevant and
Appropriate

Yes
Comment

May be relevant and appropriate during Site
remediation.
No
SOUTH CAROLINA
HAZARDOUS WASTE
REGULATION
SOUTH CAROLINA AMBIENT
AIR QUALITY CONTROL ACT
Chapter 61
Regulations 79.124-
79.270
Regulation 61-62.5
Establishes minimum state standards which define
the acceptable management of hazardous wastes for
owners and operators of facilities which treat, store,
dispose of hazardous wastes.
No
Toxic Air Pollutants: Controls
Standard No.
Section III
A source will be required to reduce emissions by
implementing controls, altering the process, or
limiting production if site-specific modeling
indicates that maximum allowable concentrations
are exceeded.
No This standard is not an ARAR because the activities
proposed for the Site do not meet the definition of a
source.
-------
Table 10
Beaunit ROD
Standard, Requirement,
Criteria, or Limitation

SOUTH CAROLINA
POLLUTION CONTROL ACT
SOUTH CAROLINA
GROUNDWATER USE ACT
SOUTH CAROLINA
STORMWATER MANAGEMENT
AND SEDIMENT REDUCTION
ACT
Citation

Title 48
Chapter 1

Section 48-1-100
Section 48-1-110
Title 49
Chapter 5
Title 48
Chapter 14
Federal Chemical-Specific ARARs
RI/FS Of Beaunit Corp. Circular Knit And Dyeing Plant Site
Fountain Inn, South Carolina
Description
Permits for discharge of water or air contaminants;
jurisdiction of Department
Permits required for construction or alternation of
disposal systems; classification; unlawful operation
or discharges

Establishes procedures to be followed to obtain a
permit to withdraw, obtain, or use groundwater and
for the submission of information concerning the
amount of groundwater withdrawal, its intended use,
and proposed aquifers.

Establishes criteria for the acceptable management
of stormwater and sediments during land disturbing
activities.
Applicable/
Relevant and
Appropriate
Comment
Yes
No
Yes
Yes
Substantive requirements may be relevant and
appropriate during Site remediation because some
alternatives will entail discharge of treated
effluent from a groundwater pump and treat system.
Relevant and appropriate for institutional controls
such as abandonment of monitoring wells.
May be relevant and appropriate during Site remediation
because some alternatives entail actions that will
disturb land surface, e.g., excavation of surface
soils.
SOUTH CAROLINA NPDES
PERMIT REGULATIONS
SOUTH CAROLINA SAFE
DRINKING WATER
REGULATIONS
Title 61
Chapter 9
Chapter 61
Establishes treatment standards and permitting
requirements.
Establishes criteria and standards to ensure the
safety of public water supplies.
Yes NPDES permitting is not required at CERCLA sites;
however, substantive requirements may be relevant
and appropriate during site remediation.

Yes May be relevant and appropriate.
-------
Table 10 (cont.)
Beaunit ROD
Standard, Requirement,
Criteria, or Limitation

SOUTH CAROLINA
STORMWATER MANAGEMENT
REGULATIONS

SOUTH CAROLINA SOLID
WASTE MANAGEMENT ACT

Approval procedures for special
wastes.
Citation

Chapter 71
Title 44
Chapter 96

Section 44-96-390
Federal Chemical-Specific ARARs
RI/FS Of Beaunit Corp. Circular Knit And Dyeing Plant Site
Fountain Inn, South Carolina
Description

Yes
Comment

May be relevant and appropriate during Site
remediation.
No
SOUTH CAROLINA
HAZARDOUS WASTE
REGULATION
SOUTH CAROLINA AMBIENT
AIR QUALITY CONTROL ACT
Chapter 61
Regulations 79-124-
79.270
Regulation 61-62.5
Establishes minimum state standards which define
the acceptable management of hazardous wastes for
owners and operators of facilities which treat, store,
dispose of hazardous wastes.
No
Toxic Air Pollutants: Controls
Standard No.
Section III
A source will be required to reduce emissions by
implementing controls, altering the process, or
limiting production if site-specific modeling
indicates that maximum allowable concentrations
are exceeded.
No This standard is not an ARAR because the activities
proposed for the Site do not meet the definition of
a source.
-------
Standard, Requirement,
Criteria, or Limitation
NATIONAL HISTORIC
PRESERVATION ACT
ARCHEOLOGICAL AND
HISTORIC PRESERVATION ACT
HISTORIC SITES, BUILDINGS,
AND ANTIQUITIES ACT
Citation

16 USC 470

40 CFR 6.301 (b)

36 CFR 800

16 USC 469
16 USC 461-467
Table 11
Beaunit ROD

Federal Chemical-Specific ARARs
RI/FS Of Beaunit Corp. Circular Knit And Dyeing Plant Site
Fountain Inn, South Carolina
Description

Requires federal aqencies to take into account the No
effect of any federally assisted undertakinq or
licensinq on any district site buildinq, structure, or
object that is included in or eliqible for inclusion in
the National Reqister of Historic Places.

Establishes procedures to provide for preservation of No
historical and archeoloqical data which miqht be
destroyed throuqh alteration of terrain as a result of a
federal construction project or a federally licensed
activity or proqram.

Requires federal aqencies to consider the existence No
and location of landmarks on the National Reqistry of
National Landmarks to avoid undesirable impacts on
such landmarks.
Applicable/
Relevant and
Appropriate
Comment
No alternative affect any district, site, buildinq,
structure or object listed on or eliqible for the
National Reqister.
No alternatives affect historical or archeoloqical
data.
No alternatives affect any National Landmark.
FISH AND WILDLIFE
COORDINATION ACT
16 USC 661-666
Requires consultation when a federally permitted or
licensed department or aqency proposes or authorizes
any modification of any stream or ether water body
and adequate provision for protection of fish and
wildlife resources.
No
No modification to a stream or water body is
proposed.
ENDANGERED SPECIES ACT
CLEAN WATER ACT

Dredqe or Fill Requirements
(Section 404)
alternative.
16 USC 1531
50 CFR 200
33 USC

40 CFR 230, 231
Requires action to conserve endanqered species No
within critical habitats on which endanqered species
depend and includes consultation with Department of
Interior.
Requires permits for discharqe of dredqed or fill No
material into naviqable waters.
No known resident population or desiqnated critical
habitats for any state or federally listed
threatened or endanqered species were identified as
occurrinq on the site or within % mile of the site.
There will be no discharqe of dredqed or fill
material into a naviqable waters as part of any
-------
Table 12 Guidelines To Be Considered
Beaunit ROD RI/FS of Beaunit Corp. Circular Knit And Dyeing Plant Site
Fountain Inn, South Carolina

Federal Criteria, Advisories, and Procedures

1. Integrated Risk Information System (IRIS) Chemical Files, USEPA, Office of Health
and Environmental Assessment, Office of Research and Development, Washington,
B.C. 20460.

2. Drinking Water Eguivalent Levels (DWELs), medium-specific drinking water levels
derived from RfDs, USEPA Health Advisories, Office of Drinking Water, 1987.

3. Maximum Contaminant Level Goals, Safe Drinking Water Act (SDWA) , 40 CFR
141, and Federal Recommended Maximum Concentration Limits (RMCLs).

4. Federal Water Quality Criteria (FWQC) for evaluating toxic effects on human health
and aguatic organisms.

5. Toxic Substances and Control Act (TSCA) health data and chemical advisories.

6. Public health criteria on which the decision, to list pollutants as hazardous under
Section 112 of the Clean Air Act, was based.

7. Health Advisories, non enforceable contaminant limits derived from DWELs,
published by USEPA, Office of Drinking Water.

8. Advisories of the Fish and Wildlife Service and the National Wildlife Federation
under the Fish and Wildlife Coordination Act.

9. TSCA Compliance Program Policy, "TSCA Enforcement Guidance Manual - Policy
Compendium," USEPA Office of Enforcement and Compliance Monitoring, 1985.

10. Guidelines for Groundwater Classification under the EPA Groundwater Protection
Strategy.

11. Executive Order related to Wetlands (11990) as implemented by EPA's August 6,
1985 Policy on Floodplain and Wetlands Assessments for CERCLA.

USEPA RCRA Design Guidelines

12. Design Guidelines for Surface Impoundments, Liners Systems, Final Cover and
Freeboard Control (1987).

Technical Resource Documents

13. Evaluating Cover Systems for Solid and Hazardous Waste (1982) .

14. Soil Properties, Classification, and Hydraulic Conductivity Testing (1984).

Test Methods for Evaluating Solid Waste

15. Solid Waste Leaching Procedure Manual (1984).

16. Methods for the Prediction of Leachate Plume Migration and Mixing.

17. Test Methods for Evaluating Solid Wastes, USEPA Office of Research and
Development, third edition (1986) SW-846.

18. Lab protocols developed pursuant to the Clean Water Act, Section 304(h).
-------
USEPA Office of Water Guidance Documents

Pretreatment Guidance Document

19. Section 304(g) Guidance Document: Revised Pretreatment Guidelines, Volumes I,
II, III.

Water Quality Guidance Documents

20. Technical Support Manual: Waterbody Surveys and Assessments for Conduction
Use Attainability Analyses (1983).

21. Technical Support Document for Water Quality-Based Toxics Control.

22. Water-Related Environmental Fate of 129 Priority Pollutants (1979).

23. The Water Quality Control (WQC) Standards Handbook (1983).

Water Quality Guidance Documents (continued)

24. USEPA Water Quality Advisories, EPA Office of Water, Criteria and Standards
Division.

NPDES Guidance Documents

25. NPDES Best Management Practices Guidance Manual (June 1981).

26. Case studies on toxicity reduction evaluation (May 1983).
-------
10.2.3 "To Be Considered" and Other Guidance

Revised Procedures for Planning and Implementing Off-Site Response Actions, OSWER Directive 9834.11,
November 1987. This directive, often referred to as "the off-Site policy," reguires EPA personnel to
take certain measures before CERCLA wastes are sent to any facility for treatment, storage, or disposal.
EPA personnel must verify that the facility to be used is operating in compliance with Sections 3004 and
3005 of RCRA, 42 U.S.C. §§ 6924 and 6925, as well as all other federal and state regulations and
reguirements. Also, the permit under which the facility operates must be checked to ensure that it
authorizes (1) the acceptance of the type of wastes to be sent, and (2) the type of treatment to be
performed on the wastes.

40 CFR Part 50, promulgated under the authority of the Clean Air Act. This regulation includes the
National Ambient Air Quality Standards (NAAQS) , and establishes a national baseline of ambient air
guality levels. The state regulation which implements this regulation, South Carolina Reg. 62-61, is
applicable to the source control portion of the remedy.

Various TBC materials were utilized in the Baseline Risk Assessment and in the Feasibility Study.
Because cleanup standards were established based on these documents, they are considered TBC.

In the Baseline Risk Assessment, TBC material included information concerning toxicity of, and exposure
to, Site contaminants. TBC material included the Integrated Risk Information System (IRIS), Health
Effects Assessment Summary Tables (HEAST), and other EPA guidance as specified in the Baseline Risk
Assessment.

In the FS, soil concentrations protective of human health and the environment were calculated based on
the Site-specific risk calculations from the Baseline Risk Assessment, using TBC information as described
above. There are no established federal or state standards for acceptable levels of Beaunit Site
contaminants in surface or subsurface soils or sediments.

For soils/sediments, the leachate-based and health-based models were both considered. In order to be
most protective, the lower of the two was targeted. The chemical-specific goals produced through the
leachate-based model were found to be lower, except for vinyl chloride. Due to the conservative nature
of the health-based and the leachate models, certain chemical-specific cleanup goals were calculated
below respective method detection limits and MCL values.

10.2.4 Other Requirements

Remedial design often includes the discovery and use of unforeseeable but necessary reguirements which
result from the planning and investigation inherent in the design process itself. Therefore, during
design of the source control component of the selected remedy, EPA may, through a formal ROD modification
process such as an Explanation of Significant Differences or a ROD Amendment, elect to designate further
ARARs which apply, or are relevant and appropriate, to this portion of the remedy.

10.3 Performance Standards

The standards outlined in this section comprise the performance standards defining successful
implementation of this portion of the remedy.

Excavation. The soil remediation goals (Table 3) are established as performance standards. The
performance standards shall control the excavation procedure described above. Additionally, all on-Site
excavation work shall comply with 29 CFR § 1910.120, the OSHA health and safety reguirements applicable
to remedial activities. Transport of contaminated soil. Transportation shall be accomplished in
compliance with the Hazardous Materials Transportation Act (49 CFR §§ 107, 171-179).

Disposal of contaminated soil. Disposal of contaminated Site soil shall comply with the applicable, or
relevant and appropriate, RCRA regulations (40 CFR Parts 261, 262 (Subparts A-D), 263, and 268). The
potential disposal of characteristically hazardous soils (as determined by TCLP procedures) shall be done
at a RCRA Subtitle C treatment, storage, and disposal facility. Non-hazardous soils may be disposed at
RCRA Subtitle D landfills, or placed within the fenced area, in the case of the selected alternative.

Monitoring. Table 2 contains performance standards to be utilized in the evaluation of monitoring data
to determine any impact on the groundwater and area surface waters during the construction of the lagoon
cap and the effectiveness of the cap after construction.
-------
10.4 Statutory Determinations

The selected remedy for this Site meets the statutory requirements set forth at Section 121 of CERCLA, 42
U.S.C. § 9621. This section states that the remedy must protect human health and the environment; meet
ARARs (unless waived); be cost-effective; use permanent solutions, and alternative treatment technologies
or resource recovery technologies to the maximum extent practicable; and finally, wherever feasible,
employ treatment to reduce the toxicity, mobility or volume of the contaminants. The following
subsections discuss how the remedy fulfills these requirements.

10.4.1 Protection of Human Health and the Environment

The selected remedy will eliminate, reduce, or control risks posed by eliminating exposure pathways
through the capping of the site and deed restrictions and thus ensure adequate protection of human health
and the environment. The cap will eliminate direct exposure to potential human or ecological
receptors. Potential risks will be either eliminated, reduced, or controlled by the remedial action.

The installation of a cap will minimize the amount of leachate generated and will place a barrier between
the contaminated surface soils such that surface water will not be allowed to percolate through the
contaminated soils. The installation of a site cap designed to 10-9 permeability will prevent leaching
from the contaminated soils and eliminate the potential for contaminating groundwater and possible
migration off-Site. Limited access and deed restrictions will protect the cap and insure its
effectiveness into the future. Contingent upon future groundwater monitoring results from wells located
on nearby properties, additional institutional controls (deed notice) may be considered for such
properties.

Site future risks will be reduced to within the 10-6 to 10-4 range for carcinogens and the Hazard Indices
total for non-carcinogens will be less than 1.0.

10.4.2 Applicable or Relevant and Appropriate Requirements (ARARs)

The selected alternative shall comply will all ARARs as described earlier in this Record of Decision.
Remedial design often includes the discovery and use of unforeseeable, but necessary, requirements, which
result from the planning and investigation inherent in the design process itself. Therefore, during
design of the site cap, EPA may, through a formal ROD modification process such as an Explanation of
Significant Differences or a ROD Amendment, elect to designate further ARARs which are applicable, or
relevant and appropriate, to this remedy.

10.4.3 Cost effectiveness

Among the alternatives that are protective of human health and the environment and comply with ARARs, the
selected alternative is the most cost-effective choice because it uses a treatment technology to address
the contaminated soils, eliminating exposure to environmental receptors and eliminating the potential for
contaminant leaching to the aquifer.

The selected remedy is cost-effective because it has been determined to provide overall effectiveness
proportioned to its costs. The modification to Alternative 3 is the only alternative that will prevent
both the generation of leachate and exposure to the contaminated soils.

10.4.4 Utilization of permanent solutions, and alternative treatment technologies or resource recovery
technologies to the maximum extent practicable

EPA has determined that the selected remedy represents the maximum extent to which permanent solutions
and treatment technologies can be utilized in a cost-effective manner.

Based upon the information presented, the selected remedy will protect environmental receptors, surface
water and groundwater quality by reducing exposure leachate production. It provides the best balance
among all evaluation criteria, with the following being the most important considerations for the Site:

1. Compliance with applicable or relevant and appropriate requirements;

2. Availability of equipment and materials;

3. Cost of construction, 0 & M;

4. Elimination of rain water infiltration and, thus, reduction in the volume of leachate and potentially
contaminated groundwater released to the environment; and,
-------
5. Elimination of direct contact by environmental receptors

6. Continued monitoring to ensure the remedy continues to be protective of human health and the
environment.

10.4.5 Preference for treatment as a principal remedy element

The selected remedy does not satisfy the statutory preference for treatment because treatment of soils at
the Beaunit Site considering the minor risk is considered impractical. The remedy does not include
treatment of any contaminated soils. Treatment of the source of contamination (the entire lagoon area)
is impracticable, because of the large volume of material and the low average contaminant concentrations
present. The excavation of such materials would increase the potential for exposure to environmental
receptors and temporarily increase the potential for leaching to area groundwater.
-------
APPENDIX A

STATE OF SOUTH CAROLINA

LETTER OF CONCURRENCE
-------
South Carolina
Department of Health and Environmental Control
2600 Bull Street, Columbia, SC 29201
Commissioner: Douglas E. Bryant DHEC
Board: John H. Burriss, Chairman
Richard E. Jabbour, DOS
William M. Hull, Jr., MD. Vice Chairman
Cyndi C. Hosteller
Roger Leaks, Jr., Secretary
Brian K. Smith
Rodney L. Grandy
Promoting Health, Protecting the Environment
September 29, 1995

John H. Hankinson, Jr.
Regional Administrator
U.S. EPA, Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365

RE: Beaunit Circular Knit and Dyeing Superfund Site
Record of Decision

Dear Mr. Hankinson:

The Department has reviewed the Draft Record of Decision (ROD), dated September 29, 1995, for the Beaunit
Circular Knit and Dyeing site and concurs with the selected remedial alternative. The selected
alternative includes source remediation by means of capping contaminated surface and subsurface soil.
EPA's selected alternative also includes deed restrictions to preclude the use of the site for future
residential use and the restriction of groundwater use beneath the site for potable purposes. In
addition, the Department concurs with the decision to grade the site prior to capping and construct
drainage control features to divert surface water away from and around the site. The Department also
concurs with the proposals for future monitoring of groundwater, surface water and sediment to determine
the effectiveness of the remedial action.

In concurring with this ROD, the Department does not waive any right or authority it may have under
federal or state law. The Department reserves any right and authority it may have to reguire corrective
action in accordance with the South Carolina Hazardous Waste Management Act and the South Carolina
Pollution Control Act. These rights include, but are not limited to, the right to ensure that all
necessary permits are obtained, all clean-up goals and criteria are met, and to take a separate action in
the event clean-up goals and criteria are not met. Nothing in the concurrence shall preclude the
Department from exercising any administrative, legal and eguitable remedies available to reguire
additional response actions in the event that: (1) (a) previously unknown or undetected conditions arise
at the site, or (b) the Department receives additional information not previously available concerning
the premises upon which the Department relied in concurring with the selected remedial alternative; and
(2) the implementation of the remedial alternative selected in the ROD is no longer protective of public
health and the environment.

This concurrence with the selected remedy for the Beaunit Circular Knit and Dyeing Site is contingent
upon the Department's above-mentioned reservation of rights. If you have any guestions, please feel free
to contact Mr. Gary Stewart at (803) 896-4054.

Sincerely,

R. Lewis Shaw, P.E.
Deputy Commissioner
Environmental Quality Control

RLS/JAB
Harry Mathis
Kent Coleman
Keith Lindler
Mary Anderson
Gary Stewart
-------
APPENDIX B

RESPONSIVENESS SUMMARY

Overview

The Environmental Protection Agency (EPA) held an initial public comment period from November 7, 1994 to
December 7, 1994, for interested parties to comment on the Proposed Plan which was based on the findings
of the Remedial Investigation/Feasibility Study (RI/FS) for the Beaunit Circular Knit & Dyeing Superfund
Site in Fountain Inn, South Carolina. A reguest was made for an extension to the comment period, and the
comment period was extended until January 19, 1995.

EPA held a public meeting at 7:00 p.m. on November 14, 1994 at the Fountain Inn Activity Center in
Fountain Inn, South Carolina, to overview the results of the RI/FS and the Baseline Risk Assessment, to
present the Proposed Plan, and to receive comments from the public.

EPA proposed a remedy consisting of: 1) Groundwater, Surface Water, and Sediment Monitoring/
Grading-Drainage Control, and 2) Capping of the Site and Deed Restrictions. Judging from the comments
received during the public comment period and the public meeting, the residents and local officials in
the Fountain Inn, South Carolina area support the cleanup alternatives proposed by EPA. It should be
noted that the Remedy was modified from Alternative Three as developed in the Feasibility Study. The
modification was done in consultation with the South Carolina Department of Health and Environmental
Control. The design for the cap was modified from a specification of 10-5 to 10-9.

This Responsiveness Summary provides a summary of citizen and agency comments, concerns, and guestions
identified and received during the public comment period, and EPA's responses to those comments and
concerns. Section 5.5 of the ROD contains a history of public participation activities during the RI/FS.
Other appendices to this document contain related documents including the Proposed Plan, Public Notices,
the Official Transcript of the Proposed Plan Public Meeting, and copies of the actual comments received.

2. Response to Public Concerns

During the preparation of the Remedial Investigation and the Feasibility Study, EPA's initial Community
Interviews, the Proposed Plan Public Meeting, and the Comment Period with its subseguent extension, there
was little concern or prior knowledge expressed regarding the Beaunit NPL Site. There was a general
confusion among the public regarding other reguired environmental response actions involving the former
Beaunit Plant that previously generated sewage that was treated at the former wastewater lagoon that has
become the current NPL Site. Area residents expressed concerns regarding odors from the old Beaunit
Plant, currently owned and operated by Wilson Sporting Goods for the manufacture of tennis balls. A leak
of mineral spirits from the facility resulted in a contaminant plume and subseguent remedial action under
separate State/Federal control under the RCRA Statutes. That mineral spirit spill and the reguired
response led to a series of monitoring wells and later groundwater extraction wells to be installed
throughout the area in a Northeastern direction from the Wilson Sporting Goods plant on Georgia Street.
The Beaunit NPL Site, located off Valley View Road, has not caused a contaminant plume off-site, and
groundwater contamination has not been shown to be a concern at the site itself. Furthermore, the
groundwater flow from the Beaunit Lagoon is to the Northwest. Despite these facts, some area residents
remain concerned about the Wilson Sporting Goods Plant and any regulatory agency activities in the area,
confusing the two separate actions as one. EPA received three comments during the public comment period
on the Beaunit NPL Site, all three of which reflect this general confusion.

Responses to Comments Received During Public Comment Period

Comment No. 1: A resident of N. Main Street wrote and stated that she wanted her property put back in
the condition it was before pollution occurred.

EPA Response to Comment No. 1: As stated above, the Beaunit Lagoon is not the source of any
contamination beyond its boundaries. This resident's comment will be brought to the attention of Wilson
Sporting Goods and the district office of SCDHEC. The resident's property was disturbed by the response
actions for the mineral spirit spill, not any activities related to the Beaunit Superfund Site.

Comment No. 2: A resident of Georgia Street wrote with several concerns. As a neighbor of the Wilson
Sporting Goods Plant, she was concerned about contamination and the effect on her home's value. She
expressed concern regarding the deaths of several neighbors from cancer. She specifically asked about
the presence of contaminants from the site near her home, if the contaminants were cancer causing or a
threat, and lastly, if there would be a cleanup.
-------
EPA Response to Comment No. 2: The resident's location is near Wilson Sporting Goods Plant, on Georgia
Street, not the Beaunit Lagoon, located off Valley View Road. Her comment will be forwarded to the
SCDHEC Division of Health Hazard Evaluation. The Beaunit RI/FS did not detect any migration of
contaminants, either carcinogenic or noncarcinogenic off-site. Furthermore, as to future cleanup
activities the Beaunit Lagoon will be capped to prevent the potential for any leaching of contaminants
detected in the soil into the groundwater.

Comment No. 3: The SCDHEC Division of Health Hazard Evaluation commented on the Beaunit Proposed Plan,
after it had been issued. The majority of comments received offered grammatical or word phrasing
recommendations. The comments also reguested a definition of the NCP. The last item in the comments
reguested that the Beaunit Superfund Site's Remedial Action include the monitoring of private drinking
wells in the area. It should be noted that the reviewer prefaced this reguest after stating that "we
have not evaluated the most recent data to the extent that we can make a complete assessment of public
health and how EPA's selected remedy will mitigate any public health implications..."

EPA's Response to Comment No. 3: Since the majority of comments were received after the Proposed Plan
was issued, the comments regarding grammar and phrasing were not timely and can't be addressed. In
answer to the reguest for a definition of the NCP, this ROD has included a glossary following the Table
of Contents. The NCP is the National Contingency Plan, the specific regulations published in the Federal
Register outlining how EPA is to implement CERCLA, commonly known as Superfund. Relative to the reguest
for reguired monitoring of area private drinking wells, EPA wishes to again note that the SCDHEC agency
comment's preface stated a lack of evaluation of the data. The data showed no off-site groundwater
contamination, therefore any detection of contamination in a private drinking well would be from another
source, and beyond the scope of the Beaunit RI/FS and this ROD. The comment has been referred to the
local SCDHEC District Office for their attention.
-------
South Carolina Commissioner: Douglas E. Bryant DHEC
Department of Health and Environmental Control Board: Richard E. Jabbour, DOS, Chairman
William E. Applegate, III,
Robert J. Stripling Jr., Vice Chairman
John H. Burriss
Robert Mills Complex, Box 101106 Sandra J. Molander, Secretary
Tony Graham, Jr., MD
Columbia, SC 29211 John B. Pate, MD

Promoting Health, Protecting the Environment
Memorandum

TO: Steve Sandier
Remedial Project Manager
Environmental Protection Agency

FROM: Lovyst L. Luker
Project Administrator
ATSDR Cooperative Agreement
Division of Health Hazard Evaluation

DATE: January 10, 1995

RE: Beaunit Proposed Plan

The South Carolina Department of Health and Environmental Control, Division of Health Hazard Evaluation,
under a cooperative agreement with the Agency for Toxic Substances and Disease Registry reviewed the
Proposed Plan Fact Sheet for the Beaunit site. We appreciate the opportunity to review and comment on
this document.

We are submitting a memorandum for your consideration of the comments that we are providing for the
proposed plan for this site. We are also requesting to be added to your mailing list to receive a ROD
when it is in draft form so that we can provide comments at that time. If you have any guestions about
our comments, or would like more information, please call Todd Going at 737-4175.

cc. Richard Kauffman, ATSDR
Bob Safay, Regional Representative
-------
South Carolina
Department of Health and Environmental Control
Robert Mills Complex, Box 101106

Columbia, SC 29211
Commissioner: Douglas E. Bryant DHEC
Board: Richard E. Jabbour, DOS, Chairman
William E. Applegate, III,
Robert J. Stripling Jr., Vice Chairman
John H. Burriss
Sandra J. Molander, Secretary
Tony Graham, Jr., MD
John B. Pate, MD
Promoting Health, Protecting the Environment
Memorandum

TO:
FROM:
DATE:

E:
Lovyst L. Luker
Project Administrator
ATSDR Cooperative Agreement
Division of Health Hazard Evaluation

William T. Going, MPH
Environmental Quality Manager
ATSDR Cooperative Agreement
Division of Health Hazard Evaluation

January 10, 1995

Beaunit Proposed Plan Fact Sheet Comments
Please find attached a copy of the comments for the Beaunit Proposed Plan Fact Sheet. The Environmental
Protection Agency (EPA) released this document in November 1994 and the public comment period will end on
January 17, 1995. Our review of this document represents an addition to our Fiscal Year 1995 workplan.

The Agency for Toxic Substances and Disease Registry (ATSDR) reguested that we review the Record of
Decision (ROD) for this site during first guarter, FY 1995. However, the ROD has not been finalized and
we do not expect to receive it until after January 1995. Enayet Ullah reguested that the EPA mail a copy
of the ROD to our office for review. We will review the ROD and provide comments while it is in the
draft version.
-------
COMMENTS FOR THE PROPOSED PLAN FACT SHEET

BEAUNIT CIRCULAR KNIT & DYEING SUPERFUND SITE

The South Carolina Department of Health and Environmental Control under a cooperative agreement with the
Agency for Toxic Substances and Disease Registry, submit the following comments for the Proposed Plan
Fact Sheet, dated November 1994, for the Beaunit Circular Knit & Dyeing Superfund site in Greenville
County, South Carolina.

Site History

1) Third Paragraph, Second Sentence. "Records available do not..."

Please consider changing this sentence to read "Available records do not..."

2) Fifth Paragraph, First Sentence. "In 1979, the plant operators determined that the
former...should be razed..."

Please consider changing the word "razed" to "demolished," "torn down," etc.

3) Please consider adding the following narrative between the sixth and seventh paragraphs.

In 1991, SCDHEC, under a cooperative agreement with the Agency for Toxic
Substances and Disease Registry (ATSDR) , released a preliminary health assessment
for the Beaunit site. The preliminary health assessment classified the site as an
indeterminate public health hazard and recommended that additional environmental
samples be collected.

Summary of Alternatives

4) Alternative 1: No Action, First Paragraph, First Sentence. "A no action alternative is
reguired by the NCP..."

Please define NCP. Also, please consider writing the document in the active voice
instead of the passive voice. The active voice will allow the writer to use less words
to make his/her point and will enable the reader to grasp the meaning of the sentence easier.

EPA's Preferred Alternative

5) We have not evaluated the most recent data to the extent that we can make a complete
assessment of public health and how EPA' s selected remedy will mitigate any public
health implications from exposure to contamination at the Beaunit site. However, we
feel that the groundwater monitoring program in EPA's preferred alternative should
be expanded to include private drinking water wells in the area. The community has
expressed concerns about adverse health effects from exposure to contaminants in
their drinking water. Therefore, EPA's monitoring of private well water will help to
alleviate community health concerns about the site.
-------
BEAUNIT 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 Beaunit Superfund Site, please complete this self-addressed form. If you have
any guestions regarding this mailing list, please call Cynthia Peurifoy at 1-800-435-
9233.

NAME:
ADDRESS:
TELEPHONE: ( )
USE THIS SPACE TO WRITE YOUR COMMENTS

Your input on the Proposed Plan for the Beaunit 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.

I want my property put back in the condition
it was before this pollution occurred.

Edna L. Reece
-------
200 Georgia Street
Fountain Inn, SC 29644
November 29, 1994

Ms. Cynthia Peurifoy
Environmental Protection Agency
North Superfund Remedial Brands
345 Courtland Street NE
Atlanta, Georgia 30365

Dear Ms. Peurifoy:

I am a resident of Fountain Inn near the Wilson Sporting Goods manufacturing facility which was formerly
the site of the Beaunit Textile plant. My concern is whether or not this has been determined to be a
contaminated area.

A year or two ago, my next-door neighbor applied for a low-interest loan for home repairs and was
informed that one of several particulars pending approval was the outcome of an investigation of possible
contamination at or near her home. (At least, this is the best I could understand what she stated.)
Obviously, I am concerned about how this affects the value of my own property.

Also, during the eleven years I have lived here, there have been five deaths of very close neighbors
having cancer and yet another who has been diagnosed with some form of cancer of which type I don't know.
All of these live within a few hundred feet to a few hundred yards of my own home. Most recent, was Mr.
Campbell who lived on Andrews Lane who died only two or three months ago with cancer of the esophagus.
There may have been more cancer related deaths, but these are the ones of which I am aware. This seems
to me to be a high percentage of cancer-related deaths for such a small area and is becoming a growing
concern to me.

My guestions are: 1) Have contaminants been found? 2) If so, are there any cancer-causing contaminants
that would be a threat to the health of those of us living in near proximity of the area? 3) If so, are
there any plans for a clean-up?

These matters are respectfully submitted for your consideration, and I trust I will hear from you soon.

Sincerely yours,

Carolyn Rumfelt

mtf
-------

APPENDIX C

PROPOSED PLAN
-------
SUPERFUND PROPOSED PLAN FACT SHEET

Beaunit Circular Knit & Dyeing Superfund Site
Fountain Inn, Greenville County, South Carolina
U.S. Environmental Protection Agency, Region IV, Atlanta, GA
November 1994
Fountain Inn is 15 miles southeast of the City of Greenville
The United States Environmental Protection Agency (EPA)
is issuing this Proposed Plan Fact Sheet for the Beaunit
Circular Knit & Dyeing Superfund site in Fountain Inn,
South Carolina. This Proposed Plan is issued to present the
alternatives that the EPA has considered for the surface soil
and groundwater contamination found at the Beaunit site.
EPA, in consultation with South Carolina Department of
Health and Environmental Control (SCDHEC) will select
a final remedy for the site after the public comment period
has ended and the information submitted during this time
has been reviewed and considered. Changes to the
preferred alternative, or a change from the preferred
alternative to another, may be made i f 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.
Terms in bold print are defined in a glossary on page 12 of
this fact sheet.
(See Figure 1-1, page 13). The Site consists of the former
wastewater lagoon, and its surroundings, that serve a
former knitting, dyeing, and finishing plant about 400 yards
east of the Site. The wastewater lagoon was built in 1951
and ceased operations in 1977 when the adj acent plant
connected to municipal sewage. In 1980 the wastewater
treatment structures around the lagoon were demolished and
the lagoon was partially filled in. The Site is currently
inactive and enclosed within a secured fence. The adj acent
plant currently is operated by Wilson Sporting Goods for
the manufacture of tennis balls.

The Site is located off Valley View Road. Land use within
one mile of the Site includes small farms, residential areas,
several businesses, and industrial facilities. Within .25
miles of the Site along Valley View Road are Valley View
Apartments, power lines, and a small pond. The nearest
dwellings to the Site are the Valley View apartments
located about 100 yards northeast of the Site. Water is
available to area residents and businesses through a public
water supply system. No groundwater supply wells exist at
EPA is issuing this Proposed Plan as part of its public
participation responsibilities under Section 117 (a) of the
Comprehensive Environmental Response, Compensation
and Liability Act (CERCLA). This document summarizes
information that can be found in greater detail in the
Remedial Investigation/Feasibility Study (RI/FS) Reports
and other documents contained in the Administrative
Record, located at the Information Repository.

The information used in proposing the response action is
available at Fountain Inn Public Library located at 400
Main Street in Fountain Inn, South Carolina (803-862-251-
1376) and at the Superfund Record Center at EPA Region
TV Office located at 345 Courtland Street, Atlanta, GA
(404-437-0506) .

DESCRIPTION AND HISTORY
Public Comment Period:
Monday, November 7, 1994
- Wednesday, December 7, 1994

Public Meeting
Monday, November 14, 1994
Time: 7:00 P.M.
Fountain Inn Activity Center
200 N. Main Street
Fountain Inn, SC
Provide written comments or call:
Steven Sandier or Cynthia Peuri foy
U.S. Environmental Protection Agenc
North Superfund Remedial Branch
345 Courtland St, NE
Atlanta, Georgia 30365
1-800-435-9233
-------
Site History

A wastewater treatment plant, which consisted of a modified
activated sludge system, was built at the location in 1951. It
was constructed to treat industrial wastewater from the knitting
dyeing, and finishing plant that was located approximately 400
yards to the east. The treatment plant units included a bar
screen, an aeration basin (lagoon), an aeroaccelerator, a
clari fier, and a post aeration tank. "As built" drawings for
these units could not be located, but these units were believed
to be located as indicated on Figure 1.2 (page 14). The
original design of the plant was to provide treatment for an
average flow rate of 300,000 gallons per day (gpd) of textile
wastewater. The lagoon had a volumetric capacity of 430,100
gallons and received wastewater via a pipeline (the influent
pipe).

In 1973, wastewater from the plant was described as passing
through an oil separator into the lagoon. The lagoon was
equipped with five 15 h.p. aerators, which were also used to
supply air to the aeroaccelerator. The wastewater discharge
may also have been treated with coagulants and neutralizers,
e.g., lime and alum, in the clari fier at the lagoon Site. A
suction pump was operated to return collected sludge from the
aeroaccelerator to the lagoon. A sludge drying bed, located
approximately 20 yards north of the lagoon, was used to dry
accumulated waste sludge from the treatment operation. The
lagoon was designed to discharge into an unnamed creek that
is located to the west end of the lagoon. There may also be a
pipeline that bypassed flow around the lagoon and discharged
flow directly to the unnamed creek. The unnamed creek flows
northwest and eventually j oins Howards Branch.

The lagoon was originally put into operation in October 1952
and accepted treated wastewater from knitting and dyeing
operations for a textile plant manufacturing fabric for wearing
apparel. Records available do not permit an accurate
summation of the chemicals used or quantities discharged.
However, the following substances were germane to the textile
knitting industry and may have been used: soluble and
insolubili zed wetting agents, dispersing agents, surfactants,
defearners, soaps, detergents, weightors, naphthol, acid, and
disperse dyes and pH adjusters. Although the aforementioned
materials may have been used in the process, it is unlikely that
all of them would be present in the wastewater. These
materials were highly diluted by successive rinses. Others
reacted and were neutral!zed or precipitated out during the
dyeing process, prior to the subsequent final treatment through
the wastewater treatment system. Many substances were
absorbed in the materials being dyed, particularly the dyes.
The flow rates to the treatment plant varied with the
production rate of the plant. The design capacity of the
treatment plant, constructed in 1951, was 300,000 gpd. By
1963, the discharge flow rate increased to 750,000 gpd. In
1963, the design capacity of the treatment plant was rate at
600,000 gpd. In 1976, the permitted discharge flow rate was
540,000 gpd. In September/October 1977, the discharge of
wastewater to the lagoon from the knitting, dyeing, and
finishing plant was discontinued due to the plant's shutdown.
From December 1977 until sometime in 1988, the discharge to
the lagoon consisted of water from roof drains, a cooling tower
blowdown, and chiller overflow.

In 1979, the plant operators determined that the former
wastewater treatment structures on the Site should be razed,
and that the then-existing lagoon be filled. The City of
Fountain Inn demolished a small brick building and
miscellaneous structures on Site, graded the Site, and partially
filled the lagoon with the demolition debris and surrounding
soil. Additional fill from the tennis ball manufacturing facility
was placed in the lagoon and was comprised of thin sheet of
blue polyethylene, rubber tennis ball and racquet ball flashing
and cores, tennis and racquet ball containers, excess tennis ball
felt, goIf balls, old roofing material, wooden pallets, and
surrounding soils. The current features of the Site are
presented on Figure 1.3 (page 15).

During a site inspection in 1985, South Carolina Department
of Health and Environmental Control (SCDHEC) personnel
noted that a portion of the Site fence was missing. Wilson
Sporting Goods (tennis ball manufacturer) subsequently
repaired the Site fence. The fence is inspected on a regular
basis. The Site has remained inactive since 1988 and access
is restricted by the fence and locked gate.

Regulatory involvement on the Site began in the early 1970's
when citizens complained to SCDHEC regarding discoloration
of the "stream below Beaunit" (probably referring to the
unnamed creek and Howards Branch). On November 7, 1973,
SCDHEC conducted a public hearing to consider whether
possible violations of South Carolina's Water Class!fication
System had occurred. SCDHEC conducted a site investigation
on June 13, 1985, and reported detections of volatile organic
compounds in surface water samples collected from the lagoon
and nearby unnamed creek, and PCBs and metals in the soil
and sediment samples collected from the Site. Based on the
results obtained from SCDHEC's 1985 Site Investigation, EPA
developed a Hazard Ranking System (HRS) score of 32.44 for
the Site. In June 1988, EPA proposed to include the Site on
the National Priorities List (NPL). The Site is ranked amongst
the Group 18 Sites (HRS scores 32.87 - 31.94) on the NPL.
-------
Engineering-Science, an Atlanta consulting firm retained by the
Potentially Responsible Parties, conducted RI field activities
at the Site in April 1992 and from October 19, 1992 to
December 10, 1992.
found at this depth except for one location. Bedrock was
between 60 to 100 feet beneath the surface. This finding
eliminated concern that contaminants from the Site might sink
and travel across a shallow bedrock layer beneath the Site.
Performed topographical and geophysical surveys in
April 1992 before preparing the draft RI Work Plan;
2. Volatile organics were not found to be a concern and were
not retained as contaminants of concern. The potential
volatilization of chemicals from any media at the Site is not a
concern.
Installed seven (three upgradient and four
downgradient) monitoring wells;
3. Lead and cadmium, detected in earlier SCDHEC sampling
of lagoon sediments, were found not to be a concern.
Collected surface water and sediment samples from
the lagoon, the unnamed creek, a pond (located
upstream of the unnamed creek), and Howards Branch;
4. Potential contaminants of concern were as follows: a)
surface soil-polynuclear aromatic compounds (PNA1s) and
metals (arsenic and manganese), b) subsurface soil-PNA's and
manganese, c) lagoon sediments-polychlorinated biphenyls
(PCBs), benzo(a)pyrene, and metals (antimony, beryllium, and
manganese) and d) groundwater-barium, chromium, and manganese.
Collected subsurface soil samples from 15 soil
borings that included 3 background soil borings, 5 soil
borings along the influent pipeline to the lagoon, 2
soil borings along an effluent pipeline from the
lagoon, 2 soil boring in the former sludge drying bed
area, and 3 soil borings in the fill material area;

Surveyed monitoring wells and sampling locations;
and
The sampling locations are shown on Figure 1.3. The results
of the RI field activities were presented to EPA in the RI
report .
RESULTS OF THE REMEDIAL INVESTIGATION

Based on the work listed above, a conceptual model was
developed for the Site. There were several differences
between what was believed to exist at the Site before the
investigation and what the Remedial Investigation showed.
5. Beryllium was detected in one groundwater samples at 4.5
ug/L (federal drinking water MCL is 4.0 ug/L.) Manganese
was detected above MCLG1s in samples from three wells, one
of which was a background well. No other metals exceeded
federal drinking water standards that were found.

6. The RI data indicated that a) the two primary pathways that
site contaminants of concern may travel were surface runoff
and infiltration/leachate migration and b) a secondary pathway
of migration of the contaminants would be groundwater
discharge to surface waters from the former sludge drying beds
or fill areas. Factoring these migration paths into the risk
assessment work done at the Site, it was determined that the
contaminants of concern are not likely to migrate because the
four necessary elements to comprise a total migration pathway
are not likely to be completed at the Site.
This Proposed Plan for the Beaunit Superfund Site addresses
remedies for surface soil and groundwater contamination
present at the Site. Sediments and surface water were sampled
during the Remedial Investigation as well.
is necessary to protect the public, and in particular,
environmental receptors from exposures to contaminated
surface soils and groundw^" ^ T\^^-I 4--; -~
units are not expected.
The planned action
rater. Additional sources or operable
-------
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
An evaluation was made of all potential exposure routes
which could connect contaminants of concern (COG's) at the
Site with people living or working in the area. Exposure by
each of these pathways was mathematically modeled using
generally conservative assumptions.

The Baseline Risk Assessment (BRA) for the Site was
prepared by Roy F. Weston, Inc. for EPA Region IV. The
BRA was finalized on November 24, 1993. EPA determined
as a result of the risk assessment that potential future
residential exposures to benzene, beryllium, chromium,
manganese, 2-methylnaphthalene, and naphthalene in
groundwater were of concern. It should be noted these risk
levels incorporated both site-related and background-related
risks (since some contaminants, such as beryllium, chromium,
and manganese, existed in the study area naturally). In the
BRA, EPA determined that the risks to human health from
contaminants in surface soils were within EPA1s acceptable
risk range and stated that remediation of surface soils would
not be required for the protection of human health. However,
the BRA also determined that site surface soils did present a
risk to ecological receptors. Arsenic and nickel were identi fled
as the chemicals of concern. While EPA determined that there
were no signi fleant concerns over surface soil contamination
as applied to human health, the Agency required that soil
contamination still be addressed in the feasibility study for the
Site because of concern for ecological receptors. Subsurface
soil, surface water and sediments were not identi fled as media
of concern for the Site. The contaminants of concern,
exposure concentrations, risk levels, and hazard indices are
provided in Tables 1.1 & 1.2 of the Feasibility Study.

Actual or threatened releases of contaminants from the Site, if
not addressed by one of the alternatives in this plan, may
present an imminent and substantial endangerment to public
health, welfare or the environment.

Environmental Risk

A qualitative risk assessment was conducted to determine i f
contaminants present at the Site have impacted plant life or
animals in the area. Given the small si ze and industrial nature
of the Site, significant impact to local plants and animals are
not expected. While endangered or threatened species have
been identified in this area of the State, none were speci fically
located at the Site during the RI/FS. Regardless, the
environmental risk assessment did indicate that surface soil
exposure to environmental receptors would need to be
addressed in the development of remediation alternatives.

SUMMARY OF ALTERNATIVES

Based on the results of the RI/FS reports and the risk
assessment, cleanup levels were developed that would be
protective of human health and the environment. These
cleanup levels will form the basis of any remedial activity.
Various alternatives were evaluated in the FS report using
these cleanup levels as goals for Site cleanup. The ground
water cleanup levels are based on state and federal standards,
referred to as Maximum Contaminant Levels (MCLs). The
soil/source cleanup levels were established to minimi ze Site
risks and insure future protection of ground water. The
cleanup standards for the Beaunit Site are presented in Table
A (see page 16).

The FS report evaluated a variety of cleanup methods that
could be used at this site. As required by CERCLA, a no
further action alternative was evaluated to serve as a basis for
comparison with the other active cleanup methods. The
cleanup methods to address site related contamination which
exceeds the cleanup goals are presented in this Proposed Plan.

Costs shown in the Proposed Plan for each alternative
represent the midpoint of the low and high estimates for each
alternative which are provided in greater detail in the
Feasibility Study.

Alternative 1: No Action

A no action alternative is required by the NCP to be carried
forward as a baseline for detailed comparison. Under this
alternative no remedial actions will be conducted for
groundwater and surface soil. Site monitor wells will be
plugged and abandoned. The current fencing will not be
actively maintained under this program. No groundwater
monitoring or remediation activities will be conducted. This
option does, however, include natural attenuation of
groundwater and surface soil contaminants. Under this option,
organic contaminants in groundwater and surface soil will
biodegrade naturally. Metals will tend to persist in sediment
and soils. Investigative derived waste (materials from well
drilling and soil sampling) from the RI which are currently
being stored on-site will be disposed and the Site will remain
-------
in its current condition.

Mid-point of the range of costs for Alternative 1 in present
worth is $5439.
Alternative 2 combines an institutional control general response
action for groundwater and the no action general response
action for surface soil. Under this alternative, a monitoring
program for groundwater, stream surface water, and stream
sediment will be implemented to provide a method for
identi fying changes in the site conditions. Groundwater
samples will be collected from six of the monitoring wells and
from three surface water and sediment sampling locations
from the unnamed creek); these samples will be analyzed
semi-annually for the first two years and annually for three
years thereafter. The results will be assessed for future
monitoring requirements. Site monitoring will (1) provide
early warning of unacceptable contaminant migration, and (2)
allow for a better understanding of the natural attenuation rates,
No remedial action will be conducted for groundwater and
surface soil. This alternative does include natural attenuation
and biodegradation of groundwater and surface soil
contaminants. Under this alternative, organic contaminants in
groundwater and surface soils will degrade naturally.
Institutional controls would prevent use of the shallow
groundwater and preclude use of the Site for residential
construction since metals will not biodegrade and would tend
to persist in soils. The investigative derived waste from the RI
will be disposed and the site area will be maintained in its
current condition.
Alternative 3 - Groundwater, Surface Water, and Sediment
Monitoring/Grading-Drainage Control-Capping of Site and
Deed Restrictions

Alternative 3 combines the institutional control general
response action for groundwater and the containment general
response action for surface soil. Under this alternative, a
monitoring program for groundwater, stream surface water, and
stream sediment will be implemented to provide a method for
identi fying changes in the site conditions. Groundwater
samples will be collected from six of the monitoring wells and
from three surface water and sediment sampling locations
from the unnamed creek). Samples from those locations will
be collected and analyzed semi-annually for the first two years
and annually for three years thereafter. The results will then
be assessed for future monitoring requirements. Site
monitoring will (1) provide early warning of unacceptable
contaminant migration, and (2) allow for a better understanding
of the natural attenuation rates.

The "hot spot" at pipeline location P5 will be excavated and
the excavated material will be placed within the fenced area.
Initially a 5' by 5' grid will be sampled. The extent of
contamination will determine the amount of soil to be
excavated. It is believed that 2' of depth will be sufficient
with an area 20' by 20' or less.

A cap designed to meet a sped fication of 10-9 permeability
will be placed over the entire area within the fence.
Alternative 3, as developed in the Feasibility Study, included
a native soil/clay cap designed to meet a 10-5 permeability.
Both EPA and SCDHEC concur that the cap should be
designed to meet a sped fication of 10-9 permeability, rather
than the 10-5 permeability contained in the alternative as
developed in the Feasibility Study. The change was based on
modeling the Site with the Sommers model, commonly used to
predict effectiveness in caps to prevent leaching from soils of
contaminants. EPA and SCDHEC feel the higher degree of
impermeability of a cap built to 10-9 specification would insure
that the RGO's would be met in the groundwater. The exact
details of the construction of the cap will be determined during
the Remedial Design, but to meet a design specification of 10-9
will probably require the use of synthetic materials as part of
a multiple component layer cap over the Site, rather than just
native soil and clay. The cap will be placed over contaminated
surface soil within the fenced area to serve as a barrier to
potential ecological receptors that may be exposed to the
surface soils. The Site will be graded and the lagoon will be
backfilled. The waste located on the east side of the lagoon
will also be used to backfill the lagoon. The water currently
in the lagoon will not be removed. The cap will be placed
over the filled lagoon. The cap will be of appropriate
gradient as to facilitate direct stormwater run-off.

The grading work at the Site will involve the use of heavy
equipment (such as dozers, loaders, scrapers, and compactors)
to spread and compact loose soil and modi fy the surface
gradient. Grading the Site will control surface runoff and
reduce erosion.

After placement of the cap, grass will grow on the Site and the
Site will be maintained by cutting the grass and periodically
inspecting the cap for damage.
-------
around the Site. Therefore, surface water run-off will not
cause excessive soil erosion and contaminant transport. Based
on the gradient of the Site, drainage controls could be
constructed along the southern and southeastern border of the
Site .

Deed restrictions would prevent new construction on the Site
Several assumptions were made during EPA/SCDHEC change
in design specifications for the cap. Utili zing cost comparisons
to other recent 10-9 cap designs for sites in this area capital
costs are estimated to be $32,000 additional for the Site
remedy. Several computer models of caps that could achieve
10-9 were run on RACER software (Remedial Action Cost
Engineering and Requirements System, Dept. of Air Force,
1993). From those efforts, it is believed that the capital cost
of the Modified Alternative 3 Site cap would be between
$212,000 to $220,000, below the $225,000 high range of the
Feasibility Study estimate of capital costs for the 10-5 cap.
EPA believes that a conservative estimate of the total costs for
the Selected Remedy, the modified Alternative 3 is $580,882.

Alternative 4 - Groundwater Pumping and
Treatment/Grading and Drainage Control-Capping of Site
and Deed Restrictions .

Alternative 4 combines the removal and treatment general
response action for groundwater and the containment general
response action for surface soil. Deed restrictions are also
included. Under this alternative, groundwater will be pumped
from monitoring wells that will be determined during the
remedial design. For cost and design estimation purposes,
MW4S and MW5S have been designed as the extraction wells.
These wells will be pumped at a combined rate of
approximately 5 gallons/minute. The contaminants of concern
include benzene, chromium VI, manganese, naphthalene, 2-
methylnaphthalene, and beryllium. To remove beryllium,
chromium, and manganese, a dual filtration cartridge system
will be used. The first cartridge will be a 3 micron filter.
This cartridge will remove the larger particulate that may foul
the smaller (second) filtration cartridge. A precipitation system
may also be needed prior to the filtration system to remove silt
or other larger particles, i.e., iron, manganese, and chromium.
The second filtration cartridge will be a 0.3-micron filter. This
cartridge will remove the beryllium to below 4 ug/L.

The effluent from the submicron filtration cartridge will pass
through a carbon adsorption unit. The carbon adsorption unit
will remove the benzene, naphthalene, and 2-
methylnaphthalene. The adsorption unit will hold
approximately 180 Ibs. of carbon. The activated carbon system
sized for the groundwater characteristics and extraction rate
from MW4 S and MW5S will require carbon replacement every
60 days. The removed carbon will be sent off-site for
regeneration or disposal. The effluent from the carbon system
will be discharged via a pipe to the unnamed creek.

The entire water treatment unit will be located on the Sites
property. A concrete foundation with a protection overhead
shed will be constructed to protect the units.

The duration of groundwater treatment is based on the size of
the contaminated plume, pumping and treatment flow rates,
and extraction efficiency (i.e., removal of contaminants from
the water bearing zone). The extent of contaminants in
groundwater is expected to be localized because the RI data
did not indicate the existence of a signi fleant plume. The
pumping and treatment flow rates are 5 gpm. For estimation
purposes, it is assumed that water treatment would continue for
five years. Water samples will be collected monthly from the
influent and effluent of the treatment units to periodically
veri fy that treatment standards are being met. Samples will be
analyzed for benzene, PNAs, beryllium, chromium VI, and
manganese. After five years, an evaluation will be conducted
to determine if further treatment is necessary. After treatment
has discontinued, a groundwater, stream surface water and
stream sediment monitoring program similar to Alternative 2
will be initiated. Treatment would not begin until each
monitor well is sampled and groundwater samples are analyzed
at least one time to confirm the presence of the contaminants
of concern (COCs) and their concentrations.

The "hot spot" at pipeline location P5 will be excavated and
the excavated material will be placed within the fenced area.
A native soil/clay cap will be placed over contaminated surface
soil within the fenced area to serve as a barrier to potential
ecological and human receptors that may be exposed to the
surface soils. The Site will be graded the lagoon will be
backfilled and 18 inches of clay will first be compacted over
the graded surface soils. The waste located on the east side of
the lagoon will also be used to backfill the lagoon. The water
currently in the lagoon will not be removed. The cap will be
placed over the filled lagoon. Then 12 inches of native soil
will be graded over the clay. The cap will have a maximum
permeability of 1 x 10-5 cm/sec.

The natural soil will facilitate grass growth. Grass will provide
erosion control. Approximately 5,000 yd3 of clay and 3,000
yd3 of soil will be required for the construction. These
materials, at the required thicknesses, will be spread and
graded over the entire site. The cap will be of appropriate
gradient as to facilitate direct stormwater run-off.
-------
With the implementation of a natural soil and clay cap, grass
will grow on the Site and the Site will be maintained by
cutting the grass and periodically inspecting the cap for
damage.
An earthen berm, ditch, or other drainage feature will b
surface water
constructed to divert surface water away from and around the
Site. Therefore,
re, excessive surface water run-off will be
diverted from the Site and not cause surface soil erosion and
contaminant transport. Based on the gradient of the Site,
drainage control could be constructed along the southern and
southeastern border of the Site. Deed restrictions are also a
component of Alternative 4.
Alternative 5 - Groundwater, Surface Water, and Sediment
Monitoring/Excavation of "Hot Spots" and Off-Site
Disposal and Deed Restrictions

Within the Site, surface soil that contains COC concentrations
above cleanup levels, discussed in the Feasibility Study and in
the Table in this fact sheet (RGO's), will be excavated and
disposed at an off-site landfill. Four surface soil samples
collected during the RI had arsenic and/or nickel
concentrations above soil action levels. Additional soil
samples will be collected in a 20-ft grid around the sampling
location. At the pipeline location P5, soil samples will be
collected at the corners of a 5-ft grid. The soil samples will be
analyzed for arsenic and nickel and, if a sample from this
additional sampling exceeds the cleanup levels for arsenic or
nickel, soil samples will be collected from a 20-ft grid around
that sampling location or a 5-ft grid for the pipeline location
around the exceedance location. Excavation will be completed
within a boundary of soil sample locations that have nickel and
arsenic concentrations below their respective preliminary
remediation goals.

A range of costs was developed for this option. The lower
range assumes the surface soil excavation will be limited to a
volume of 20 ft by 20 ft by 2 ft around four RI sample
locations (shown in Figure 3.6 of the Feasibility Study) and a
volume of 5 ft by 5 ft by 2 ft at pipeline location P5. This
scenario assumes all samples collected around the "hot spots"
are below Remedial Goal Options (RGO's) for surface soil.
The total volume of excavation for this scenario is
approximately 120 yd3. The higher range costs for this
Alternative assumes that all surface soils within the Site will
require excavation and disposal. The total volume of
excavation for this scenario is approximately 5,000 yd3.
Additionally the cost of surface soil sampling and analyses will
be a significant part of the total cost of this option. Soil will
be excavated to a 2 ft. depth. The excavated soil will be
transported to an off-site landfill for disposal. The soil may be
disposed in a Subtitle D landfill if the soil is not
characteristically hazardous. Based on information gained
during the RI, the soil will pass TC criteria and may be
accepted for disposal at an off-site solid waste landfill.

The excavated areas will be backfilled and graded. The
grading work at the Site will involve the use of heavy
equipment (such as dozers, loaders, scrapers, and compactors)
to spread and compact loose soil and modi fy the surface
gradient. Grading the Site will control surface runoff and
with the excavated areas.

The extent of soil excavation will impact the number of
analyses, amount of soil needing excavation, amount of
backfill. Once again, deed restrictions would prevent future
construction at the Site.

The present worth costs of Alternative 5 are estimated to be in
the range of $243,193 to $1,370,675, with the mid-point of
costs for this Alternative as $806,934.

Alternative 6 - Groundwater Pumping and Treatment/
Excavation of "Hot Spots" and Off-site Disposal and Deed
Restrictions

Alternative 6 combines the removal and treatment general
response action for groundwater and the removal and disposal
general response action for surface soil. Under this alternative
-------
groundwater will be pumped from monitoring wells that will
be determined during the remedial design. For cost and design
estimation purposes, MW4 S and MW5S have been designed as
the extraction wells. These wells will be pumped at a
combined rate of approximately 5 galIons/minute. The
contaminants of concern include benzene, chromium VI,
manganese, naphthalene, 2-methylnaphthalene, and beryllium.
To remove beryllium, a dual filtration cartridge system will be
used. The first cartridge will be a 3-micron filter. This
cartridge will remove the larger particulate that may foul the
smaller (second) filtration cartridge. (A precipitation system
may also be needed prior to the filtration system to remove silt
or other larger particles, e.g., iron, manganese, and chromium.)
The second filtration cartridge will be a 0.3-micron filter. This
cartridge will remove beryllium to below 4 ug/L.

The effluent from the submicron filtration cartridge will pass
through a carbon adsorption unit. The carbon adsorption unit
will remove the benzene, naphthalene, and 2-
methylnaphthalene. The adsorption unit will hold
approximately 180 Ibs. of carbon. The activated carbon system
properly sized for the groundwater characteristics and
extraction rate from MW4 S and MW5S would require carbon
replacement every 60 days. The removed carbon will be sent
off-site for regeneration or disposal. The effluent from the
carbon system will be discharged via a pipe to the unnamed
creek.

The entire water treatment unit will be located on the site
property. A concrete foundation with a protective overhead
shed will be constructed to protec the units.

The duration of groundwater is based on the size of
the contaminated plume, pumping and treatment flow rates,
and extraction efficiency (in other words, removal of
contaminants from the water bearing zone). The extent of
contaminants in groundwater is expected to be localized
because the RI data did not indicate the existence of a
signi fleant plume. The pumping and treatment flow rates are
5 gpm. For estimation purposes, it is assumed that water
treatment would continue for five years. Water samples will
be collected monthly from the influent and effluent of the
treatment units to periodically veri fy that treatment standards
are being met. Samples will be analyzed for benzene, poly
nuclear aromatics (PNA1s), beryllium, chromium, and
manganese. After five years, an evaluation will be conducted
to determine if further treatment is necessary. After treatment
has discontinued, a groundwater, stream surface water, and
stream sediment monitoring program similar to Alternative 2
will be initiated. Treatment will not begin until each
monitoring well is sampled and analyzed at least one time to
confirm the presence of the COCs and their concentrations.
Within the Site, surface soil that contains COC concentrations
above cleanup levels will be excavated and disposed at an off-
site landfill. Four surface soil samples collected during the RI
had arsenic and/or nickel concentrations above soil action
levels. Additional soil samples will be collected in a 20-ft grid
around the sampling location. At the pipeline location P5, soil
samples will be collected at the corners of a 5-ft grid. The soil
samples will be analyzed for arsenic and nickel and, if a
sample from this additional sampling exceeds the cleanup
levels for arsenic or nickel, soil samples will be collected from
a 20-ft grid around that sampling location or a 5-ft grid for the
pipeline location around the exceedance location. Excavation
will be completed within a boundary of soil sample locations
that have nickel and arsenic concentrations below their
respective preliminary remediation goals. A range of cost was
developed for this option. The lower range will assume the
surface soil excavation will be limited to a volume of 20 ft by
20 ft by 2 ft around four RI sample locations and a volume of
5 ft by 5 ft by 2 ft at pipeline location P5. This scenario
assumes all samples collected around the "hot spots" are below
RGOs for surface soil. The total volume of excavation for this
scenario is approximately 120 yd3. The higher range units of
excavation for removal of "hot spots" assumes that all surface
soils within the Site will require excavation and disposal. The
total volume of excavation for this scenario is approximately
5,000 yd3. Additionally the cost of surface soil sampling and
analyses will be a signi fleant part of the total cost of this
option. Soil will be excavated to a 2 ft. depth. The excavated
soil will be transported to an off-site landfill for disposal. The
soil may be disposed in a Subtitle D landfill if the soil is not
characteristically hazardous. Based on information gained
during the RI, the soil will pass TC criteria and may be
accepted for disposal at an off-site solid waste landfill.

The extent of soil excavation will impact the number of
analyses, amount of soil needing excavation, amount of
backfill required, and the amount of grading required following
backfill.
Alternative 7 - Groundwater, Surface Water, and Sediment
Monitoring/Excavation of Site Surface Soils and Fill Area
and Off/site Disposal

Within the Site, all surface soil and the fill material (located
east of the lagoon) will be excavated, contained and disposed
off-site. With this option, surface soils within the site
boundaries and at pipeline location P5 (5 ft by 5 ft) will be
excavated to 2 ft depth. Approximately 5,000 yd3 of surface
soil would require excavation. The surface area of fill material
is approximately 1,800 yd2 with the fill extending to an
average of approximately 10 ft. These soils total
approximately 6,000 yd3 that would require excavation. The
excavated soil will be contained for disposal. The soil may be
disposed in a Subtitle D landfill if the soil is not
characteristically hazardous. Based on information gained
during the RI, the soil will pass TC criteria and may be
accepted to an off-site solid waste landfill. The excavated
areas would then be backfilled with natural soil.

Under Alternative 7, the existing lagoon would be backfilled
and the entire Site will be graded. The grading work at the
Site will involve the use of heavy equipment (such as dozers,
loaders, scrapers, and compactors) to spread and compact loose
soil and modi fy the surface gradient. Grading the Site will
control surface runoff and reduce erosion. Grass seeding will
be used to grow grass within the Site.
The estimated present worth costs for Alternative 7 range from
a low of $934,429 to a high of $2,002,775, with a mid-point
of $1,468,602 .

Alternative 8 - Groundwater Pumping and
Treatment/Excavation of Site Surface Soils and Fill Area
and Off-site Disposal

Alternative 8 combines the removal and treatment general
response action for groundwater and a second combined
removal and disposal general response action for surface soil.
Under this alternative groundwater will be pumped from
monitoring wells that will be determined during the remedial
design. For cost and design estimation purposes, MW4 S and
MW5S have been initially chosen as the extraction wells
These wells will be pumped at a combined rate of
approximately 5 gallons/minute. The contaminants of concern
include benzene, chromium VI, manganese, naphthalene, 2-
methylnaphthalene, and beryllium. To remove beryllium, a
dual filtration cartridge system will be used. The first
cartridge will be a 3 micron filter. This cartridge will remove
the larger particulate that may foul the smaller (second)
filtration cartridge. (A precipitation system may also be needed
prior the filtration system to remove silt or other larger
particles, i.e., iron, manganese, and chromium.) The second
will remove the beryllium to below 4 ug/L.

The effluent from the submicron filtration cartridge will pass
through a carbon adsorption unit. The carbon adsorption unit
will remove the benzene, naphthalene, and 2-
methylnaphthalene. The adsorption unit will hold
approximately 180 Ibs. of carbon. The activated carbon system
sized for the groundwater characteristics and extraction rate
from MW4 S and MW5S will require carbon replacement every
60 days. The removed carbon will be sent off-site for
regeneration or disposal. The effluent from the carbon system
will be discharged via a pipe to the unnamed creek.

The entire water treatment unit will be located on the site
property. A concrete foundation with a protective overhead
shed will be constructed to protect the units.

The duration of groundwater treatment is based on the size of
the contaminated plume, pumping and treatment flow rates,
and extraction efficiency. The extent of contaminants in
groundwater is expected to be localized because the RI data
did not indicate the existence of a signi fleant plume. The
plumping and treatment flow rates are 5 gpm. For estimation
purposes, it is assumed that water treatment would continue for
five years. Water samples will be collected monthly from the
influent and effluent of the treatment units to periodically
veri fy that treatment standards are being met. Samples will be
analyzed for benzene, PNAs, beryllium, chromium, and
manganese. After five years, an evaluation will be conducted
to determine if further treatment is necessary. After treatment
has discontinued, a groundwater, stream surface water, and
stream sediment monitoring program similar to Alternative 5
will be initiated. Prior to treatment, each well will be sampled
and analyzed at least one time to confirm the presence of the
COCs and their concentrations.

Within the Site, all surface soil and the fill material (located
east of the lagoon) will be excavated, contained and disposed
off-site. With this option, surface soils within the site
boundaries and at pipeline location P5 (5 ft by 5 ft) will be
excavated to 2 ft depth. Approximately 5,000 yd3 of surface
soil would require excavation. The Fill area is approximately
1,800 yd2. The fill extends to an average of approximately 10
ft. Therefore approximately 6,000 yd3 would require
excavation. The excavated soil will be contained for disposal.
The soil may be disposed in a Subtitle D landfill if the soil is
not characteristically hazardous. Based on information gained
-------
during the RI, the soil will pass TC criteria and will be
accepted to an off-site solid waste landfill. The excavated
areas would then be backfilled with natural soil.

Under this alternative the existing lagoon will be backfilled and
the entire Site will be graded. The grading work at the Site
will involve the use of heavy equipment (such as dozers,
loaders, scrapers, and compactors) to spread and compact loose
soil and modi fy the surface gradient. Grading the Site will
control surface runoff and reduce erosion. Grass seeding will
be used to grow grass within the Site.

The range of present worth costs for Alternative 8 range from
a low of $4,432,074 to $9,497,158, with a mid-point of
$6,964,616.
COMPARATIVE ANALYSIS OF ALTERNATIVES

EPA has established criteria for use in comparing the
advantages/disadvantages of each alternative. The alternatives
are evaluated against one another by using the nine criteria on
the following table. The nine evaluation criteria fall into the
groups: threshold criteria, primary balancing criteria, and
modi fying criteria.
immediately meet chemical-specific ARARs including MCLs,
but the concentrations of organic contaminants of concerr
groundwater will decrease over time (about 5 years) through
natural attenuation and will be in compliance with chemical
sped fie ARARs. While metals would tend to persist,
monitoring and groundwater use restrictions would prevent
exposure and provide warning of contaminant migration, as yet
undetected. Groundwater pump and treat alternatives would
provide compliance sooner than non-pump and treat
alternatives.
Relative to action-sped fie ARARs, alternatives 3 through 8
comply with requirements for 1) abandonment of wells in the
SC Groundwater Use Act, 2) the SC Groundwater Use Act for
Well Development, and 3) the South Carolina Stormwater
Regulations for soil disturbance. No location sped fie ARARs
have been identi fied for the Site.
A summary of the present worth cost which includes the
capital as well as the operation and maintenance cost for each
of the alternatives is presented within the explanation of the
alternative. Greater detail is provided in the Feasibility Study,
which is located in the Administrative Record.
Overall Protection of Human Health and the Environment

Relative to groundwater concerns, the alternatives without
groundwater pumping and treatment (Alternatives 1, 2, 3, 5, 7)
will have decreases in the concentrations of organic
contaminants through natural attenuation. While metals would
tend to persist, migration of metals was not observed during
the RI. Alternatives with pump and treatment of groundwater
(Alternatives 4, 6) would enhance the speed of the reduction
of organic contaminants. Groundwater monitoring and use
restrictions of all alternatives except the no action alternative
would preclude exposure to the groundwater and provide early
warning of unacceptable contaminant migration.
Implementability

The implementability of an alternative is based on technical
feasibility, administrative feasibility and the availability of
services and materials. All components of each alternative are
both technically and administratively feasible. The design and
construction of soil caps with synthetic materials is commonly
done. Soil excavation and removal would be difficult and
would require compliance with significant administrative
requirements, but it is commonly done. Necessary technology,
services, and materials are all readily available. Pump and
treat remedies are commonly installed at Superfund Sites,
although due to the long term requirements of these remedies,
their effectiveness has not been fully determined at many other
sites .
Relative to surface soil, alternatives 1 and 2 do not reduce
risks to ecological receptors. All other alternatives eliminate
risk to area biota.

Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs)
The purpose of this Proposed Plan and the upcoming comment
is to encourage input from the public during the
selection process. Community acceptance of the preferred
alternative will be evaluated after the public comment: period
and will be described in the Record of Decision for the Site.
All non pump and treat groundwater alternatives will not
-------
CRITERIA FOR EVALUATING
REMEDIAL ALTERNATIVES

In selecting a preferred cleanup alternative, EPA uses the following criteria to evaluate each of the
alternatives developed in the Feasibility Study (FS). The first two criteria are essential and must
be met before an alternative is considered further. The next five are used to further evaluate all
options that meet the first two criteria. The final two criteria are used to further evaluate EPA's
proposed plan after the public comment period has ended and comments from the community and
the State have been received. All nine criteria are explained in more detail here.

• Overall Protection of Human Health and the Environment - Assesses degree to which alternative
eliminates, reduces, or controls health and environmental threats through treatment, engineering
methods, or institutional controls.

• Compliance with Applicable or Relevant and Appropriate Reguirements (ARARs) - Assesses
compliance with Federal/State reguirements.

• Cost - Weighing of benefits of a remedy against the cost of implementation.

• Implementability - Refers to the technical feasibility and administrative case of a remedy.

• Short-Term Effectiveness - Length of time, for remedy to achieve protection and potential impact
of construction and implementation of the remedy.

• Long-Term Effectiveness and Performance - Degree to which a remedy can maintain protection of
health and environment once cleanup goals have been met.

• Reduction of Toxicity, Mobility, or Volume Through Treatment - Refers to expected performance of
the treatment technologies to lessen harmful nature, movement, or amount of contaminants.

• State Acceptance - Consideration of State's opinion of the preferred alternatives.

• Community Acceptance -- Consideration of public comments on the Proposed Plan.

Short Term Effectiveness

During the implementation of all the alternatives, both on-site workers and people surrounding the Site
will be protected from possible impacts caused by construction activities. Risks from cap installation
or soil excavation and removal would be addressed in health and safety plans. There is no risk to the
environmental receptors from implementation of any remedy, although habitats would be disrupted during
installation activities. Community risks from construction truck traffic would be short term and safety
could be insured by additional signage and traffic control. Installation of a cap would be immediately
effective in reducing leaching from soils into the groundwater.

Long-Term Effectiveness and Permanence

All of the alternatives under consideration by EPA in this Proposed Plan were evaluated for this criteria
under each of its components consisting of 1) permanence, 2) magnitude of residual risk, 3) adeguacy and
reliability of controls, 4) need for periodic review, and 5) certainty of success. Relative to
permanence and magnitude of residual risk, Alternatives 1, 2, 3, 5, and 7 only reduce risk in groundwater
after natural attenuation processes are complete. Pump and treat Alternatives 4, 6, and 8 will reduce
risks from groundwater more guickly. Alternatives 1 and 2 do not reduce ecological risks while all other
alternatives do. Adeguacy and reliability of controls for all alternatives are generally good if
institutional controls (such as Alternative 2) are enforced. All alternatives involving regular
monitoring will reguire periodic review as will alternatives involving capping the Site. Alternatives
involving excavation and soil replacement will not reguire periodic review. All alternatives have
approximately the same certainty of success with the pump and treat alternatives having the ability to
meet Remedial Action Objectives more guickly.

Reduction of Toxicity, Mobility, and Volume

This criteria was evaluated for each of its components consisting of 1) treatment used, 2) reduction of
toxicity, mobility, or volume, 3) type and guantity of residuals remaining after treatment, and 4)
irreversibility of treatment. Only pump and treat alternatives involve treatment and are considered
irreversible. Such treatment will generate residuals which will reguire off-site disposal Alternatives
involving soil excavation and removal will reduce the toxicity, mobility, and volume by removal of the
-------
contaminated soils. Capping alternatives will reduce the mobility of the contaminants, while soil
excavation remedies are considered irreversible.

State Acceptance

The State of South Carolina's Department of Health and Environmental Control was consulted during the
drafting of this Proposed Plan. They are in support of the Alternative selected in this Proposed Plan.
-------
EPA's PREFERRED ALTERNATIVE

In summary, based on the information available at this time,
EPA is proposing Alternative 3: Groundwater, Surface
Water, and Sediment Monitoring and Groundwater Use
Restrictions/Grading-Drainage Control-10-9 Site Cap and
Deed Restrictions, as the proposed remedy for the Beaunit
Site. The only modification to Alternative 3 as described
earlier in this fact sheet and in the Feasibility Study is the
design specifications and construction materials for the Cap.
Both EPA and SCDHEC concur that the cap should be
designed to meet a specification of 10-9 permeability, rather
than the 10-5 permeability contained in the alternative as
developed in the Feasibility Study. The change was based on
modeling the Site with the Sommers model, commonly used to
predict effectiveness in caps to prevent leaching from
contaminated soils. EPA and SCDHEC feel the higher degree
of impermeability of a cap built to 10-9 specification would
insure that the RGO's would be met in the groundwater. The
exact details of the construction of the cap will be determined
during the Remedial Design.

Several assumptions were made during EPA/SCDHEC change
in design specifications for the cap. Utilizing cost comparisons
to other recent 10-9 cap designs for sites in this area capital
costs are estimated to be $32,000 additional for the site
remedy. Several modeling runs of caps were performed on
RACER software (Remedial Action Cost Engineering and
Reguirements System, Dept. of Air Force, 1993) . From those
efforts, it is believed that the capital cost of the Modified
Alternative 3 Site Cap would be between $212,000 to
$220,000, below the $225,000 high range of the Feasibility
Study estimate of capital costs for the 10-5 cap. EPA believes
that a conservative estimate of the total costs for the Selected
Remedy, the modified Alternative 3, $580,882.

This alternative represents the best balance among the criteria
used to evaluate remedies. The modified Alternative 3 is
believed to be protective of human health and the environment,
would attain ARARs, would be cost effective, and would
utilize permanent solutions and alternative treatment
technologies or resource technologies to the maximum extent
practicable.

Based on comments received from the public during the
upcoming comment period, EPA, in consultation with
SCDHEC, may later further modify the preferred alternative or
select another remedial alternative presented in this Proposed
Plan.

TECHNICAL ASSISTANCE GRANTS ARE AVAILABLE
who are interested in a TAG may contact Ms. Cynthia Peurifoy
at 1-800-435-9233.

GLOSSARY

Administrative Record: An official compilation of information that is
considered important to the status of Superfund decisions. The record is
placed in the information repository to allow public access to the material.

Applicable or Relevant and Appropriate Reguirements (ARARs):
Reguirements which must be met by a response action selected by EPA as a
site remedy. "Applicable" reguirements are those mandated under one or
more Federal or State laws. "Relevant and appropriate" reguirements are
those which, while not necessarily reguired, EPA judges to be appropriate
for use in that particular case.

Baseline Risk Assessment: An assessment which provides an evaluation
of the potential risk to human health and the environment in the absence of
remedial action.

Biota: The animal and plant life of a given region.

Comprehensive, Environmental, Response, Compensation and
Liability Act (CERCLA): A Federal law passed in 1980 and modified in
1986 by the Superfund Amendments and Reauthorization Act (SARA),
known as Superfund, to investigate and clean up abandoned or uncontrolled
hazardous waste sites.
waste sites.

Contaminants of Concern (COC's): Contaminants, identified during
site investigations and risk assessments, that pose a potential risk to human
health and the environment because of their toxicity and potential routes of
exposure.

Exposure Route: Path for contaminants to reach people either working or
residing near a site.

Groundwater: Water found beneath the earth's surface that fills the pores
between materials such as sand, soil, or gravel.

Hazard Ranking System (HRS): A scoring system used by EPA and
the states to evaluate relative risks to public health and the environment
from releases or threatened releases of hazardous substances. An HRS
score is calculated based on actual or potential release of hazardous
substances through the air, soils, surface water or groundwater. This score
is a primary factor used to decide if a hazardous waste site should be placed
on the National Priorities List.

Information Repository: A library or other location where information
related to a Superfund Site is placed for public access.
-------
To assist communities in interpreting the technical finding at
Superfund Sites, communities may apply for Technical
Assistance Grants of up to $50,000. Congress and EPA have
established reguirements for the use of this grant. Citizens

Permeability: The rate at which liguids pass through soil or other
materials in a specified direction.

Polynuclear Aromatics (PNA's) - also know as Polynuclear
Aromatic Hydrocarbons (PAH's): A class of organic compounds whose
structure consists of joined rings of carbon atoms. PNAs/PAHs are often
associated with wood-treating operations such as creosote treatment.

Record of Decision (ROD): A public document describing EPA's
rationale for selection of a Superfund cleanup alternative.

Remedial Investigation/Feasibility Study (RI/FS): A two part study of
hazardous waste site that supports the selection of a remedial action for the
site. The first part, or the RI, identifying that type and extent of
contamination. The second part, or the FS, identifies and evaluates
alternatives for addressing site contamination, based on the results of the RI.
-------
APPENDIX D

PUBLIC NOTICE OF COMMENT PERIOD

Published November 6, 1994, Greenville News
Published November 9, 1994, Golden Strip Times/Tribune Times

U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION IV
INVITES PUBLIC COMMENT ON THE PROPOSED CLEANUP PLAN FOR THE
BEAUNIT CIRCULAR KNIT A DYEING SUPERFUND SITE,
FOUNTAIN INN, GREENVILLE COUNTY, SOUTH CAROLINA

The U.S. Environmental Protection Agency is inviting public comment on the Proposed Plan for cleanup of
the Beaunit Circular Knit & Dyeing Superfund Site. The Remedial Investigation and Feasibility Study for
the site have been completed. The Remedial Investigation determined the nature and extent of
contamination at the site. The Feasibility Study evaluated alternatives for addressing surface soil and
groundwater contamination at the site, the principal threats posed by the site.

EPA evaluated eight alternatives that were considered in the Feasibility Study. The costs shown in
parentheses below represent the midpoint of the low and high present worth cost estimates for each
alternative. The following alternatives were considered:

Alternative 1: No Action ($5439)
Alternative 2: Groundwater, Surface Water, and Sediment Monitoring/Groundwater Use
Restrictions/Deed Restrictions ($276,887)
Alternative 3: Groundwater, Surface Water, and Sediment Monitoring/Grading-Drainage
Control-Capping of Site and Deed Restrictions ($580,822)
Alternative 4: Groundwater Pumping and Treatment/Grading & Drainage Control-Capping of Site and
Deed Restrictions ($6,042,662)
Alternative 5: Groundwater, Surface Water, and Sediment Monitoring/Excavation of "Hot Spots"/
Off-site Disposal and Deed Restrictions ($806,934)
Alternative 6: Groundwater Pumping and Treatment/Excavation of "Hot Spots", Off-Site Disposal and
Deed Restrictions ($6,302,948)
Alternative 7: Groundwater, Surface Water and Sediment Monitoring/Excavation of Site Surface Soils
and Fill Area and Offsite Disposal ($1,468,602)
Alternative 8: Groundwater Pumping and Treatment/Excavation of Site Surface Soils and Fill Area
and Off-site Disposal ($6,964,616)

EPA is proposing Implementation of Alternative 3: Groundwater, Surface Water, and Sediment Monitoring
and Groundwater Use Restrictions/Grading and Drainage Control-Capping of Site and Deed Restrictions.
Under the alternative, a monitoring program for groundwater, stream surface water, and stream sediment
will be implemented to provide a method for identifying changes in the Site conditions. The "hot spot"
at pipeline location P5 will be excavated and the excavated material will be placed within the fenced
area. A cap will be placed over the entire area within the fence. EPA is proposes a change to the design
specifications for Alternative 3, as written in the Feasibility Study. EPA and SCDHEC propose that the
cap should be designed to meet a specification of 10-9 permeability, rather than the 10-5 permeability as
contained in the alternative as developed in the Feasibility Study. The design of a 10-9 cap will
probably reguire synthetic materials in addition to soil and clay. EPA and SCDHEC believe that the
higher degree of impermeability would insure that Remedial Goal Options for groundwater would be met.
EPA believes that the proposed remedy will be protective of human health and the environment, meet
applicable or relevant and appropriate reguirements, be effective in the long-term, reduce contaminant,
mobility, be easy to implement, and will be cost effective.

The Agency is holding a 30 day comment period, which begins on Monday, November 7, 1994, and ends on
Wednesday, December 7, 1994. Upon receipt of a timely reguest, the comment period can be extended for an
additional 30 days. Written comments, which must be postmarked no later than December 7, 1994, should be
sent to:

Mr. Steven Sandier, Remedial Project Manager
of Cynthia Peurifoy, Community Relations Coordinator
North Superfund Remedial Branch
U.S. Environmental Protection Agency, Region IV
345 Courtland Street, N.E., Atlanta, GA 30365
-------
EPA has scheduled a public meeting to present the proposed plan and to answer questions regarding the
Remedial Investigation, Feasibility Study and other documentation contained in the Administrative Record.
The meeting also provides the public an opportunity to submit oral and written comments on the proposed
cleanup plan and the other alternatives considered. The meeting will be:

Date: Monday, November 14, 1994
Time: 7:00 p.m.
Place: FOUNTAIN INN ACTIVITY CENTER
200 N. Main Street, Fountain Inn, South Carolina

Copies of the proposed plan, as well as the administrative record for the site, are available for review
at the site information repository, which is in the Fountain Inn Branch Library, 400 North Main Street
Fountain Inn, SC, 803-862-2576. These documents are also available for review at the EPA Records Center,
345 Courtland Street, N.E., Atlanta, GA 30365, 404-347-0506.

For additional information, or to be added to EPA's mailing list for the site, contact Cynthia B.
Peurifoy, Community Relations Coordinator, at 1-800-435-9233, or 404/347-7791, x4102.
-------
Published November 27, 1994, Greenville News
Published November 30, 1994, Golden Strip Times/Tribune Times

The U.S. Environmental Protection Agency has extended the public comment period for the Proposed Plan for
the Beaunit Circular Knit and Dyeing Superfund Site. The comment period which opened on November 7, and
was scheduled to close on December 7, will close on January 13, 1995. EPA continues to inviting public
comment on the Proposed Plan for cleanup of the Beaunit Circular Knit & Dyeing Superfund Site. EPA held
a public meeting on November 14, 1994 to present the proposed plan and to receive public input.

EPA and the South Carolina Department of Health and Environmental Control, evaluated eight alternatives
that were considered in the Feasibility Study conducted for the site. The costs shown in parentheses
below represent the midpoint of the low and high present worth cost estimates for each alternative. The
following alternatives were considered:

Alternative 1: No Action ($5439)
Alternative 2: Groundwater, Surface Water, and Sediment Monitoring/Groundwater Use
Restrictions/Deed Restrictions ($276,887)
Alternative 3: Groundwater, Surface Water, and Sediment Monitoring/Grading-Drainage
Control-Capping of Site and Deed Restrictions ($580,822)
Alternative 4: Groundwater Pumping and Treatment/Grading & Drainage Control-Capping of Site
and Deed Restrictions ($6,042,662)
Alternative 5: Groundwater, Surface Water, and Sediment Monitoring/Excavation of "Hot
Spots"/0ff-site Disposal and Deed Restrictions ($806,934)
Alternative 6: Groundwater Pumping and Treatment/Excavation of "Hot Spots", Off-Site Disposal
and Deed Restrictions ($6,302,948)
Alternative 7: Groundwater, Surface Water and Sediment Monitoring/Excavation of Site Surface
Soils and Fill Area and Offsite Disposal ($1,468,602)
Alternative 8: Groundwater Pumping and Treatment/Excavation of Site Surface Soils and Fill
Area and Off-site Disposal ($6,964,616)

EPA is proposing Implementation of Alternative 3: Groundwater, Surface Water, and Sediment Monitoring
and Groundwater Use Restrictions/Grading and Drainage Control-Capping of Site and Deed Restrictions.
Under this alternative, a monitoring program for groundwater, stream surface water, and stream sediment
will be implemented to provide a method for identifying changes in the Site conditions. The "hot spot"
at pipeline location P5 will be excavated and the excavated material will be placed within the fenced
area. A cap will be placed over the entire area within the fence. EPA is proposes a change to the
design specifications for Alternative 3, as written in the Feasibility Study. EPA and SCDHEC propose
that the cap should be designed to meet a specification of 10-9 permeability, rather than the 10-6
permeability as contained in the alternative as developed in the Feasibility Study. The design of a
10-9 cap will probably reguire synthetic materials in addition to soil and clay. EPA and SCDHEC believe
that the higher degree of impermeability would insure that Remedial Goal Options for groundwater would be
met. EPA believes that the proposed remedy will be protective of human health and the environment, meet
applicable or relevant and appropriate reguirements, be effective in the long-term, reduce contaminant,
mobility, be easy to implement, and will be cost effective.

Written comments, which must be postmarked no later than January 13, 1995, should be sent to:

TRANSCRIPT OF THE PROPOSED PLAN PUBLIC MEETING

U.S. ENVIRONMENTAL PROTECTION AGENCY

REGION IV

ATLANTA, GEORGIA

PUBLIC HEARING

NOVEMBER 14, 1994 @ 7:00 P.M.

BEAUNIT CIRCULAR KNIT & DYEING SUPERFUND SITE

FOUNTAIN INN, SOUTH CAROLINA
Deborah Garrison
Court Reporter
245-D East Broad Street
Greenville, S.C. 29601
(803) 244-0973
-------
1 BY CYNTHIA PEURIFOY:
2 Good evening. My name is Cynthia Peurifoy and I'm
3 the Community Relations Coordinator with the South
4 Carolina section of the Superfund Program of EPA out
5 of Atlanta, Georgia.
6 I welcome you here tonight to hear the proposed plan
7 concerning the Beaunit Circular Knit & Dyeing Super-
8 fund Site.
9 Before we get started, I want to make some introduc-
10 tions to you.
11 First of all, I would like to introduce to you Ste-
12 ven Sandier. He is the Remedial Project Manager of
13 the site for EPA.
14 I would also like to introduce Jan Rogers, who is
15 managing coordinator for EPA, South Carolina sec-
16 tion.
17 We have some colleagues of ours from the South Caro-
18 lina Department of Health and Environmental Control
19 with us tonight. They are Craig Marriner and Jim
2 0 Bowman.
21 Before we get started, I would also like to cover a
22 little bit with you about the Superfund's Community
23 Relations Program. I know that some of you are
24 familiar with the community interviews that we did
25 in preparation for our work on the site. We do have
1 a community relations plan outlined that we felt we
2 should do in order to communicate with the community
3 and keep you informed. And I know that a lot of you
4 got the Fact Sheet that we mailed out that announced
5 our Proposed Plan.
6 I also want to make sure that you have the informa-
7 tion that is at the Fountain Inn Library here in
8 Fountain Inn.
9 We are in the public comment period on this proposed
10 plan. That comment period ends on December 7th.
11 There is a provision for a thirty-day extension of
12 that comment period, if you so desire.
13 I would also like to point your attention to our
14 court reporter tonight, who is Deborah Garrison. I
15 would like to ask that at any time you would like to
16 make a statement or ask a guestion that you identify
17 yourself and make sure that she can hear you clear-
18 ly, whatever statement that you would make.
19 Finally, I would like to just ask that if at any
20 time we can do anything for you, or answer any gues-
21 tions for you, that you can reach us at our 800-
22 Number, which is on the Fact Sheet. Let us know of
23 anything that we can do to answer guestions or to
24 answer any concerns that you have.
25 At this time, I would like to turn the meeting over
-------
1 to Steven Sandier, our Remedial Project Manager.
2 BY MR. SANDLER:
3 Thank you very much, Cynthia. And thank you, too,
4 everyone who came out tonight to listen to what we
5 are going to be proposing for the cleanup of the
6 Beaunit Circular Knit & Dyeing Site.
7 I have a few photographs that I am going to put out
8 on the table, which some of you may wish to take a
9 look at after I make the presentation; because many
10 people may not be familiar with the site, because it
11 is not on a main road and it is not quite on the
12 road.
13 The Site is located off of Valley View Road. I have
14 a picture here and you can see some tire tracks, and
15 that shows where the entrance to the Site is.
16 I also have some other photographs that show the
17 interior of the site, (placing on table for public
18 viewing).
19 Briefly, I will go through a little bit of the his-
20 tory of the Site, the regulatory history of the
21 Site; some of the Site features; what we did during
22 the investigation of the Site; and the development
23 of the alternatives to clean up the Site; and what
24 the Agency selected, in conjunction without coun-
25 terparts at the South Carolina Department of Health
1 & Environmental Control; and give you an indication
2 of some of the upcoming events in the cleanup of
3 this Site.
4 Last, and certainly not least, we will have plenty
5 of time for questions and answers at the conclusion
6 of the presentation.
7 Just briefly, the site history:
8 In 1951, there was a wastewater treatment plant in
9 the woods off of Valley View Road, some four hundred
10 yards from what is now the Wilson Sporting Goods
11 plant.
12 In 1952, the wastewater treatment plant was put into
13 operation. It had a capacity then of 300,000 gal-
14 Ions per day.
15 In 1953, the capacity was increased.
16 In 1977, the plant was shut down and the operation
17 of the wastewater treatment plant, which included a
18 wastewater lagoon, ended.
19 And sometime in between 1977 and 1988, all discharge
20 to the lagoon from the plant stopped. Even though
21 the lagoon was not used for sewage treatment opera-
22 tions, there was a pipeline that connected the cur-
23 rent Wilson Sporting Goods plant to the lagoon and
24 there were some materials that were discharged into
25 the lagoon.
-------
1 In between 1979 and 1980 the wastewater treatment
2 plant, the structures above the ground, were de-
3 stroyed and for the most part were bulldozed into
4 the lagoon. There was some concern then that the
5 lagoon represented an unsafe condition. As it was
6 explained to the parties who were involved at this
7 time when the lagoon was filled in, it was so that
8 it would not pose so much of a hazard.
9 A number of governmental agencies have been involved
10 in this site for a period of time. And like any
11 history, there are some certain variations in the
12 years. I have seen one report saying that as early
13 as the early '60s that some citizens had complained
14 about an odor problem. But there were some com-
15 plaints in the early 70's about stream discolor-
16 ation. I should add that the lagoon has a pipeline
17 that connects it with the plant and it also had a
18 discharge pipe where, after the sewage had been
19 treated, it would be discharged to an unnamed stream
20 that eventually went into another stream called
21 Howard's Branch.
22 In 1973, the state agency DHEC had a public hearing
23 on the violations.
24 And in 1985, they did a site investigation and sam-
25 pled the site. I should add that there were very,
1 very few samples that were taken in 1985. But the
2 site was still ranked according to a Hazardous Rank-
3 ing score and proposed for listing on the National
4 Priorities List, which is the list of sites which
5 enable facilities to be studied under the CERCLA
6 law.
7 I will apologize, as I do in every single meeting,
8 for inadvertently using many acronyms and abbrevia-
9 tions. "CERCLA" is the formal name for what we all
10 call "Superfund". The law has a fund of money which
11 provides for the study and cleanup of sites if no
12 potentially responsible parties (RPRs) are found.
13 Or if they are found, it will attempt to seek cost
14 recovery in negotiation with potentially responsible
15 parties to get the site cleaned up.
16 We have five companies that at various points in
17 time either directly owned or operated the plant and
18 the wastewater treatment lagoon, or later bought a
19 company that operated the plant and the wastewater
20 lagoon. Those five PRP's, as we call them, are El
21 Paso Natural Gas, Kaiser Corporation, Pepsi Inc.,
22 Wilson Sporting Goods and Continental Assurance.
23 I am getting a little bit ahead of myself, but as
24 you can see, in 1990 the site was listed on the
25 National Priorities List as a Superfund site.
-------
1 And by 1992 all the PRP's and EPA successfully nego-
2 tiated and signed an AOC, which stands for an Ad-
3 ministrative Order Under Consent. That is a con-
4 tractual agreement between the PRP's and EPA which
5 outlines, in this case, an agreement where the PRP's
6 agree to study the site and propose solutions to
7 clean it up with EPA and DHEC oversight.
8 (Displaying Figure 1.1 map via overhead projec-
9 tor/indicating), this is where the Wilson Sporting
10 Goods plant is. And this little sguare is where the
11 site is. You can see the center of Fountain Inn is
12 over here (indicating lower right of Figure 1.1).
13 Just to mention some of the characteristics of the
14 site, it is 1.3 acres. This is the former waste-
15 water plant and lagoon area.
16 This is what it looks like right now, with the la-
17 goon partially filled in. As I said, I brought some
18 photographs so that you can take a look at it.
19 There is a large amount of manufacturing debris from
20 the manufacturer of tennis balls, which is non-
21 hazardous but is nevertheless piled up in the area.
22 You see a lot of pieces of a synthetic material,
23 like Swiss cheese, so to speak, with circular cut-
24 out's taken out of it, which are the parts that are
25 used in the manufacture of tennis balls.
1 Because the area was used as a sewage treatment
2 lagoon, some of the exact site features and the
3 location of things are a bit uncertain as far as the
4 exact dimensions. But we generally know where they
5 are. As I said earlier, We will show you a blow-up
6 of the site to illustrate that.
7 The site had a pipeline going in from the factory
8 and it also had a pipeline going out.
9 The area is currently fenced, locked, and it is
10 posted as a Superfund site.
11 The nearest residence is the Valley View Apartments
12 and they are some one hundred yards northeast.
13 There is runoff on the site, generally to the north-
14 west, on the surface and also in the groundwater.
15 The entire area served by municipal water and sew-
16 age.
17 We had conducted, as part of the remedial investiga-
18 tion, a feasibility study by a survey of the area
19 which does not show any signs of animal life. But
20 within the fenced area are aquatic life and are
21 adjacent to the lagoon. We did not have individual
22 stations there for a long period of time. This is a
23 habitat for a number of species and that fact played
24 a part in our decision as to what to do in cleaning
25 up the site.
-------
1 (Displaying Figure 1.2 map on overhead projector).
2 This is a copy of a map which was done for both
3 remedial investigation and then the feasibility
4 study. To re-emphasize what Cynthia had indicated,
5 in the Public Library you will find a vast number of
6 documents regarding the work that has gone on on
7 this site, including an Administrative Index or an
8 Administrative Record which has all of the documents
9 which were used to formulate the decision on how to
10 clean up the site. That includes all correspondence
11 to myself from people doing the study, any comments
12 that I received from other EPA and State parties,
13 and a review of the documents. So all of the items
14 that help make the decision are available for public
15 scrutiny.
16 Back to the site itself, the lagoon is only a frag-
17 ment of the size that it once was. You see that
18 when the lagoon was entirely filled in that it was
19 approximately this size (indicating broken lines
20 forming sguare on map.) Now it is much smaller
21 (indicating present size on map.)
22 This is the pipe exit of the lagoon area and there
23 were a number of sewage treatment plant operations.
24 There was a clarifier (indicating), an aero accela-
25 tor (indicating) and there were some valves. Then
1 this was foam (sic) material -- or rather the sludge
2 drying beds. Excuse me. It's hard to read when
3 you're staring at the light.
4 To explain, you may see on the sign-in list some
5 names of entities or when you go and look at the Ad-
6 ministrative Record you will see names of the con-
7 suiting firms that you should be aware of.
8 When the PRP's signed the EPA Administrative Order
9 Under Consent they, in turn, retained a consulting
10 firm by the name of Parsons Engineering Science.
11 They did the remedial investigation and the feasi-
12 bility study, according to an approved workplan that
13 EPA reviewed and negotiated with the PRP's.
14 EPA retains the -- we retain certain
15 responsibilities when a remedial investigation and
16 feasibility study are done. One of those responsi-
17 bilities is community relations, which is why some
18 of you saw Cynthia and I as we came to certain in-
19 dividuals' homes and we did interviews. We went
20 through the neighborhoods around the plant. We also
21 met with a number of people in the Fountain Inn
22 government. All of those things came into play in
23 our decision.
24 We also retain responsibility for doing a very im-
25 portant part of the study, and that is called the
-------
1 Baseline Risk Assessment. EPA retained and later
2 seeks reimbursement for the cost of doing that.
3 That document was prepared by Roy F. Weston and,
4 lastly, -- we have a number of sites and it is dif-
5 ficult to do all of the oversight to make sure that
6 the samples have been collected properly. I can't
7 do all of that work myself, nor would it be cost-
8 effective to do it. So we retained another consult-
9 ing firm, EPA, which was in this case was Camp
10 Dresser & McKee (CDM) to do the oversight for us.
11 They also reviewed documents. So when you review
12 the documents you may see many names with Engineer-
13 ing Science or Weston or McKee on it and I just
14 wanted to point that out. All of these individuals
15 were very active in doing the studies.
16 What was done with the study? (Changing overhead
17 slides). First of all, with most Superfund sites,
18 you end up finding out that groundwater may or may
19 not be contaminated. And you also have soil that
20 also may or may not be contaminated. We refer to
21 these things as "media". There are surface soils,
22 there's subsurface soils, there's sediment along the
23 banks of the lagoon and the banks of area streams.
24 And there is also the air which is sometimes moni-
25 tored, if that is suggested as being a concern.
1 In the case of this site, there were seven monitor-
2 ing wells installed. There were three upgradient,
3 or above, or in the opposite direction of the
4 groundwater flow. Those can give you an indication
5 of what the background conditions are. Quite often
6 you find out that the background conditions show
7 some contamination; so there is an contamination in
8 the area which may not be from the site itself. It
9 also gives you a basis on which to judge how signif-
10 icant the contamination might be.
11 We also installed four downgradient wells. Wells
12 were also installed — and some of these wells were
13 at different depths, because this site, as many
14 sites, has an upper and lower aguifer and you want
15 to see if any contamination has potentially reached
16 the lower aguifer.
17 As you can read for yourself, as far as surface soil
18 samples, we collected at twenty-four locations with
19 three background locations.
20 As I said, there was an incoming pipeline going into
21 the lagoon and an effluent pipeline. It was sampled
22 along the pipelines, both going in and coming out.
23 There were also soil samples, subsurface soil sam-
24 pies, taken in that sludge drying bed. This was
25 used for wastewater — a byproduct of wastewater
-------
1 treatment is the production of sludge. The residue
2 that settles out of the sewage, it has to be dis-
3 posed of. Quite often in the past, and in the pres-
4 ent, at a number of sewage treatment plants, you put
5 it out in areas to dry. It is compressed. Like
6 anything, once you get the water out of it, it is
7 far less bulkier, easier to handle and to properly
8 dispose of.
9 Within the fenced in area, there were also other
10 areas -- because there was a minor breach in the
11 wall of the lagoon and there were some leakage of
12 materials in the past. The lagoon wall had been
13 fixed in the past and there was some indication of
14 leakage of materials. So that had been sampled.
15 The next thing on the overhead, which is very impor-
16 tant and which we want to emphasize to the public,
17 is the fact that although EPA and PRP's do an awful
18 lot of work, how would we know that the results are
19 valid? That is the point that I put on this slide,
20 collection and analysis, guality control.
21 We have site samples, split samples and they test
22 part and we test part to make sure that the results
23 match. We also reguire an extensive amount of docu-
24 mentation from laboratories that they use, as well
25 as we have the responsibility to approve the labora-
1 tories that they use and to make sure that the re-
2 suits are valid and that there is something we can
3 make a decision on.
4 The next item that was done under the RI was survey-
5 ing and mapping, so that we had accurate maps so
6 that we would know where samples were taken. As I
7 have already mentioned, we did our own survey and
8 then they did it. It was fed into the risk assess-
9 ment for about a half a mile radius around the Site.
10 The area around the site was a number of different
11 habitats: fields, wooded areas. There was a poten-
12 tial for a wide variety of animal life in the area,
13 which we were concerned with. As I said, Engineer-
14 ing Science worked with the PRP's and, with over-
15 sight conducted by EPA and DHEC, and also Camp
16 Dresser & McKee, our oversight contractor.
17 On this map we have — this is reproduced in the
18 copy of the Proposed Plan, and we have extra copies
19 of the proposed plan.
20 Just to point out some of the monitoring well loca-
21 tions. As I said, the direction of the flow tends
22 to be to the northwest, and here is the lagoon area
23 here (indicating). We had a shallow monitoring well
24 right here and a deep monitoring well here. We had
25 a shallow monitoring well here. We had another
-------
1 swallow monitoring well right over here (indicat-
2 ing). And we had a number of ones downgradient.
3 These are some of the upgradient ones, (indicating).
4 And we had one over here. We had one over here and
5 over here (indicating). I believe that's it. Some
6 of the ones that I indicated had both shallow and --
7 there were seven wells, I think, here.
8 And what did we find out from all of this? We found
9 out a number of things. When you start a project,
10 you form a conceptual model of what you think the
11 site is like and we found out a number of things
12 were not what we thought that they would be. One,
13 we thought that the bedrock would be lot closer to
14 the surface and that ended up not being the case.
15 We thought that the bedrock might only be twenty or
16 twenty-five, thirty feet down. But as it turns out,
17 we got a phone call the first day that drilling was
18 going on out on the site and they were down a hun-
19 dred feet and hadn't hit anything. Bedrock gener-
20 ally is sixty to hundred feet. What difference does
21 this make? Quite often if you have bedrock closer
22 to the surface that has been fractured, you can have
23 contaminants that reach and travel across the rock
24 to another location, or you could also have frac-
25 tures which may make it very difficult.
1 Another thing that we found out about -- as I said,
2 this site was put on the National Priorities List
3 based on a very, very few samples that were collect-
4 ed. It was thought that of all the organic compo-
5 nents that we find at a lot of sites wouldn't be a
6 concern at this site. If you look at point number
7 four on page three of the Proposed Plan it talks
8 about contaminants. And I don't want to alarm any-
9 one but these go into a very laborious detailed
10 process for anything that might be a problem because
11 you have a detection of it or we think that it may
12 be detected it is also retained as a contaminant.
13 It is also retained because they are more signifi-
14 cant things that cause problems.
15 If you found -- the key word that I want you to keep
16 in mind is "potential." There were a number of
17 things that were potential that were found not to be
18 problems at this site.
19 As you can see, lead and cadmium was detected earli-
20 er by DHEC, as well as PCBs, but were not found to.
21 be significant enough to be a concern.
22 One contaminant, Beryllium, was detected in one
23 groundwater sample at 4.5 milligrams per liter. We
24 have a standard, which is called the maximum stan-
25 dard level, of just 4, so it was only slightly above
-------
1 the MC level.
2 And we also had Manganese which also was detected in
3 the sampling from three wells, one of which was a
4 background well. As I have already indicated to
5 you, we sampled the background wells to see if there
6 were already some contaminants in the area. No
7 other metals were found that exceeded the federal
8 drinking water standards.
9 Manganese is mainly a problem in actually washing of
10 clothes because of staining fabrics and plumbing
11 fixtures. And it causes -- it is regarded as gener-
12 ally a secondary standard of the Drinking Water
13 Act.
14 One of the other key findings is that even if you
15 have contamination it is going to -- and this may be
16 a rather complicated notion to follow through, but
17 there are two ways that things can potentially get
18 off the site. That would be surface runoff and
19 infiltration or leachate migration through the
20 soils. There are ways to control these things.
21 The remedy that we selected — (pause).
22 To go back a second. The RPRs have developed a
23 feasibility study that goes through the formulation
24 of some remedial goals, which are numeric numbers
25 that you want to see achieved after a cleanup. They
1 develop a variety of ways of reaching those remedial
2 goals.
3 This slide depicts the eight alternatives that were
4 developed by the PRP's for this Site. It is EPA's
5 responsibility, in conjunction with the State and
6 citizen input to select an alternative that will be
7 most protective of the human health and the environ-
8 ment. We have some other criteria that we have to
9 match also in selecting an alternative.
10 Here are the eight alternatives:
11 Alternative 1, the first one, is "No Action." Which
12 is a reguirement of the law, is that everyone tries
13 to do nothing. We actually reguire them to cost out
14 and show the effects of doing nothing.
15 The other alternatives -- and I won't go into each
16 individual one, but there are combinations of the
17 different -- different components for treating and
18 dealing with the groundwater, and different compo-
19 nents for treating and dealing with the soil contam-
20 ination.
21 The different type of alternatives that we have
22 developed for the groundwater include doing nothing,
23 nothing or no action, to doing monitoring of ground-
24 water for a period of time, and ultimately leading
25 up to Alternative 8, pumping and treating the
-------
1 groundwater. That is a treatment that has been
2 unfortunately required at a number of other sites.
3 It is very costly, very time-consuming. Admittedly,
4 there is some technical debate as to how effective
5 will it turn out to be.
6 The different types of remedies for dealing with the
7 contamination of the soil involve capping the site
8 so that rain water and surface runoff after the rain
9 will not allow contaminants that do exist in the
10 soil to get into the groundwater. That is what you
11 can see in Alternative 3, the soil cap.
12 Then in Alternative 2 -- the excavation of the mate-
13 rial, which is in Alternative 5 and 6.
14 Alternative 7 would be an off-site disposal.
15 Alternatives 5, 6, 7 and 8 would be an off-site
16 disposal of the material.
17 After a number of meetings in which EPA and DHEC
18 reviewed the feasibility study, we decided on Alter-
19 native 3 as meeting all the criteria required for a
20 Superfund remedy.
21 As you can see on the slide, we did make a modifica-
22 tion from the alternative as it was contained in the
23 feasibility study. In the feasibility study what
24 does this alternative consist of? It consists of a
25 couple of different things.
1 For the groundwater, the surface water and the sedi-
2 ment, it proposes monitoring in the future to make
3 sure that what we found today remains to be the
4 case.
5 What was proposed was six groundwater samplings, two
6 per year for the first two years and then annually
7 after that. Three surface water samples and three
8 sediment samples. Samples from these locations will
9 be collected and analyzed semi-annually for the
10 first two years and annually for three years there-
11 after. So it sets up a continuous program of moni-
12 toring the groundwater, the surface water and the
13 sediments.
14 We also proposed capping the site, grading the site
15 and filling in the lagoon, establishing drainage
16 control and capping the site with the necessary
17 materials. This is where the change is, to ensure a
18 ten to minus nine permeability.
19 I, myself, am not an engineer. Ten to the minus
20 five is the permeability that the PRP's proposed for
21 Alternative 3 in the feasibility study.
22 The ten to the minus nine permeability means that
23 you have coverage that is more impervious and it
24 would be more difficult for the contaminants in the
25 soil to reach the groundwater.
-------
1 To do a cap of the site of a ten to the minus five
2 permeability, you could achieve that with a cover
3 over the site that was composed of soil and clay.
4 That is what was proposed in the feasibility study.
5 To achieve a ten to the minus nine impermeability or
6 something that is more impervious would require a
7 use of synthetic material in the covering of the
8 site.
9 A couple of other features of the Alternative is
10 that there is one small area next to the location of
11 the pipeline between the plant and the lagoon, which
12 we call P5, that had some soil contamination. We
13 were proposing excavating that area and putting a
14 soil inside the fenced area and then covering it.
15 As you can see, filling of the lagoon.
16 And future deed restrictions.
17 And institutional controls so that the site is not
18 used for residential development or will allow po-
19 tential exposure to humans.
20 Now, the feasibility study, as you saw from the
21 previous slide had a range of costs, both a high and
22 a low cost for each of the alternatives. We made
23 the decision that, just to give the public the basis
24 of comparison, we would choose the midpoint within
25 each range. Because I was concerned that somebody
1 might pick up the document and say, 'Well, the high
2 cost for Alternative 4 was less than the low cost
3 for Alternative' -- so we just wanted to simplify
4 the numbers so that we could compare the costs of
5 the various alternatives.
6 Similarly, when I estimated the costs for the modi-
7 fications to Alternative 3, I utilized two other
8 things to help me determine the midpoint. Those
9 were some recent cost information for other caps
10 that were proposed in South Carolina at other loca-
11 tions. And, number two, a computer software package
12 that estimated the cost of doing different types of
13 remedies. It was not just generic software but a
14 very specific package that has specific costs for
15 numerous locations in South Carolina. In other
16 words, different costs for doing work in Greenville
17 than other places. And the costs have been updated
18 several times during the year, so our cost estimate
19 is probably as good as you can get.
20 Ultimately whenever any of these design costs are
21 decided after they are built, after they are drawn
22 up and after they are -- after plans and specs are
23 let out and they are bid upon and the things are
24 fully finished. It reflects any construction activ-
25 ity, all those costs.
-------
1 So the Agency has proposed modification of Alterna-
2 tive 3 for the cleanup of the Beaunit Knitting &
3 Dyeing Site, which is a monitoring program for the
4 groundwater, the sediments and the surface waters
5 and the capping of the Site.
6 One of the things that I mentioned a few moments ago
7 is how do we decide which one to pick. Obviously
8 the key factor in all of our decision making is the
9 overall protection of human health and the environ-
10 ment.
11 The second thing which is most important is that we
12 have nine criteria. They are all contained in the
13 Proposed Plan. They are located in a block that
14 goes through them all, which is located on page
15 eleven in the left-hand column.
16 The nine criteria are divided into three groupings.
17 The two most important things which are on this are
18 the overall protection of human health and environ-
19 ment and the second thing is called compliance with
20 what we call ARARs, applicable and appropriate
21 reguirements.
22 When you are talking about drinking water, the Fed-
23 eral Government and the State Government have numer-
24 ical numbers for various contaminants which they
25 cannot exceed. They are the MCLs. It is easy to
1 see if something does meet those reguirements.
2 There are no numeric numbers in any regulation that
3 would tell you how clean the soil would be. One
4 thing is that in typical soil contamination, you
5 have to -- we use two different ideals.
6 One is that some things that we are trying to regu-
7 late have applicable regulations. We have a num-
8 bet — and some things have what we call "relevant
9 and appropriate" of a State law. There are some
10 things that you can see if it is cleaned up, to a
11 certain point that it would reduce the risk level to
12 an acceptable level. That is the appropriate and
13 relevant reguirement.
14 The second criteria that we have to use to select
15 alternatives is compliance with ARARs, as we call
16 them.
17 There is another five criteria and, as you can see,
18 they are all written there (page eleven of Proposed
19 Plan).
20 The effects long-term? Is it permanent?
21 Does it reduce the toxicity, mobility or volume
22 through treatment?
23 Does it have a short-term effectiveness?
24 And whether it meets State acceptance.
25 And what is the risk to the individuals doing the
-------
1 remedy? You don't want to harm the people who are
2 out in the field at the Site working.
3 And is it implementable?
4 And what does it cost?
5 Is it innovative?
6 Does it have a proven track record?
7 Last, and certainly not least, does a modified cri-
8 teria have State acceptance and community accep-
9 tance?
10 All of these factors come into our decision making
11 process when choosing an alternative.
12 The question that remains now is where do we go from
13 there, or what happens next?
14 At Region IV, we like to issue a Proposed Plan of
15 Action for the public, so that the public can under-
16 stand. And we did that several weeks ago. We gen-
17 erally try to have a public meeting after people
18 have had an opportunity to look at the document for
19 a period of time. Such a meeting as we are at to-
20 night.
21 We have a comment period on this which will run
22 until December 7th.
23 It is also a practice of Region IV that if anyone
24 wants a longer period of time that we will automati-
25 cally grant an extension to the comment period.
1 You might ask what happens to your comments? Do
2 they go into a file? All comments and any guestions
3 that you might ask -- that's why we have a stenogra-
4 pher here -- have to be responded to, in writing.
5 They are responded to and then attached to the docu-
6 ment that EPA will produce. Everyone's comments
7 have an egual value. We have some PRP's in the
8 audience tonight and they tend to comment guite a
9 bit on what we propose. So — and obviously they
10 have a financial interest in it. We take their
11 comments, we take your comments and attach them to
12 the record of decision. We attach your guestions
13 and comments, and we attach our respond. That an
14 attachment to the decision.
15 EPA proposes something, we take comments on it and
16 now 'this is what we think should happen.' Quite
17 often there may be further modification on the Pro-
18 posed Plan after public input.
19 The record of decision will be probably a sixty to a
20 hundred and ten page document wherein we will go
21 through this entire process in greater detail, a
22 summarization of all alternatives. More detailed
23 information on the risk assessment, the selection of
24 an alternative and the responsiveness summary. That
25 will also include a transcript of tonight's meeting.
-------
1 Then there will a recommendation with the Agency
2 publicly saying 'this is how we feel that the Site
3 should be cleaned up.' And if anybody is going to
4 clean up the Site -- well, let me correct that.
5 Not "if" but when the Site is cleaned up, that's how
6 it is going to be done. So the guestion becomes,
7 'Well, who is going to do it?' Hopefully we will
8 get an agreement with the PRP's for cleaning up the
9 Site and they will negotiate with EPA and sign a
10 Consent Agreement, which is the contractual obliga-
11 tion to remediate the Site. We used a different --
12 the Administration Order Under Consent, which I
13 talked about earlier. We use a Consent Agreement,
14 which is a very lengthy document which is entered
15 into by the parties, given to a Judge and the Judge
16 asks for comments and then it becomes final. If
17 somebody doesn't live up to it -- everyone knows how
18 lengthy legal processes can be. You don't have to
19 go through all that with a Consent Order or Consent
20 Agreement. There are penalties in there, onerous
21 penalties, sometimes very severe penalties of sever-
22 al thousand dollars a day for not doing things that
23 were agreed to be done.
24 So the Consent Agreement is the agreement where the
25 PRP's indicate to perform a remedy.
1 There will be a design hearing with a design speci-
2 fication of the cap to meet the performance stan-
3 dards of the ten to the minus nine permeability.
4 They will -- or EPA, if we cannot reach agreement
5 with the PRP's, we will use Superfund money to pur-
6 sue the remedy and seek costs from the PRP's for the
7 remedy.
8 Then once the remediation is successful, at some
9 point in the future the Site can be delisted.
10 with that, I will ask if there are any guestions?
11 (No response from attendees)
12 BY MR. SANDLER:
13 No guestions?
14 (No response from attendees)
15 BY MR. SANDLER:
16 Well, you may be thinking of something -- (pause).
17 I invite you'all to look at these photographs (indi-
18 caring photographs put on public table). Some of
19 you probably don't know what the Site looks like,
20 unless you've been trespassing.
21 No guestions?
22 (No response from attendees)
23 BY MR. SANDLER:
24 Well, if you think of anything our 800-Number is on
25 the Proposed plan, and our address. If you're not
-------
1 on our mailing list, there is a mailing list coupon
2 on the back page, the last page. We will continue
3 to give you information on the Site as the process
4 continues.
5 I want to thank everyone for coming tonight.
6 If you have any guestions, we will certainly be here
7 for a period to talk with you.
8 Thank you.
9 Hearing no guestions, we are adjourned.
10 (CONCLUDED)
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
1 State of South Carolina
2 County of Greenville
3
4 This is to certify that the within Public Hear-
5 ing was conducted before duly authorized agents of the
6 U.S. Environmental Protection Agency, Region IV, out of
7 Atlanta, Georgia on the 14th day of November, 1994, com-
8 mencing at 7:10 p.m. in the Fountain Inn Activity Center,
9 Fairview Road, Fountain Inn, South Carolina;
10 That the within presentation was duly presented
11 to a public body and that the foregoing is an accurate
12 transcription of the said presentation;
13 That no exhibits were entered herein or made a
14 part of this record;
15 That the undersigned court reporter, a Notary
16 Public for the State of South Carolina, is not an employ-
17 ee or relative of any of the parties, counsel or witness
18 and is not in any manner interested in the outcome of
19 this action;
20 IN WITNESS WHEREOF, I have hereunto set my Hand
21 and Seal at Greenville, South Carolina this 15th day of
22 November, 1994.
23
24 Commission expires: 1-10-2001
25
-------