Record of Decision US Finishing/Cone Mills Superfund Site Operable Unit 3 Sitewide Groundwater Greenville Greenville County South Carolina


RECORD OF DECISION

US FINISHING/CONE MILLS
SUPERFUND SITE
OPERABLE UNIT 3

SITE WIDE GROUNDWATER

Greenville, Greenville County, South Carolina
EPA ID: SCD003358744



Prepared By:
U.S. Environmental Protection Agency
Region 4

Superfund & Emergency Management Division
Atlanta, Georgia

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US Finishing/Cone Mills Super&nd Site OU3
Record of Decision
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RECORD OF DECISION

Table of Contents

PART 1: DECLARATION	1

1.0 Site Name and Location	1

2.0 Statement of Basis and Purpose	1

3.0 Assessment of Site	1

4.0 Description of Selected Remedy	1

5.0 Statutory Determinations	2

6.0 Data Certification Checklist	2

7.0 Authorizing Signature	3

PART 2: THE DECISION SUMMARY	4

1.0 Site Name, Location and Brief Description	4

2.0 Site History and Enforcement Activities	9

2.1 Site Activities Leading to Current Problems	9

2.2 History of Investigations and Cleanup Actions	9

2.2.1	History of State of South Carolina Investigations and Cleanup Actions	9

2.2.2	History of EPA Investigations and Cleanup Actions for OU3	 1 1

2.3 History of CERCLA Enforcement Activities	 12

3.0 Community Participation	14

4.0 Scope and Role of the Operable Unit or Response Action	14

5.0 Site Characteristics	15

5.1	Conceptual Site Model	15

5.2	Overview of the Site	 16

5.3	Sampling Strategy	 17

5.4	Known or Suspected Sources of Contamination	 17

5.5	Nature and Extent of Contamination	 17

5.6	Location and Potential Routes of Migration	19

6.0 Current and Potential Future Groundwater and Land Uses	20

7.0 Summary of Site Risks	20

7.1	Human Health Risk Assessment (HHRA)	20

7.2	Basis for Action	22

8.0 Remedial Action Objectives	23

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9.0 Description of Alternatives	24

9.1	Alternative GW 1: No Action	24

9.2	Alternative GW2: In-Situ Chemical Reduction and Institutional Controls	25

9.3	Alternative GW3: In-Situ Enhanced Bioremediation and Institutional Controls. 25

9.4	Alternative GW4: In-Situ Chemical Reduction, In-Situ Enhanced Bioremediation
and Institutional Controls	26

9.5	Common Elements and Distinguishing Features of Each Alternative	26

10.0 Comparative Analysis of Alternatives	26

10.1	Overall Protection of Human Health and the Environment	27

10.2	Compliance with ARARs	27

10.3	Long-Term Effectiveness and Permanence	28

10.4	Reduction of Toxicity, Mobility and Volume	28

10.5	Short-Term Effectiveness	28

10.6	Implementability	29

10.7	Cost	29

10.8	State Acceptance	30

10.9	Community Acceptance	30

11.0 Principal Threat Wastes	30

12.0 Selected Remedy	30

12.1	Summary of the Rationale for the Selected Remedy	3 1

12.2	Detailed Description of the Selected Remedy	31

12.3	Cost Estimate for the Selected Remedy	3 1

12.4	Estimated Outcomes of Selected Remedy	32

13.0 Statutory Determinations	32

13.1	Protection of Human Health and the Environment	33

13.2	Compliance with ARARs	33

13.3	Cost Effectiveness	34

13.4	Use of Permanent Solutions and Alternative Treatment Technologies to the
Maximum Extent Practicable	34

13.5	Preference for Treatment as a Principal Element	34

13.6	Five-Year Review Requirements	34

14.0 Documentation of Significant Changes from Preferred Alternative of Proposed

Plan	35

15.0 References	35

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US Finishing/Cone Mills Superfund Site OU3
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PART 3: RESPONSIV ENESS SUMMARY	36

1.0 Public Review Process	36

1.1	Introduction	36

1.2	Public Review Process	36

1.3	Public Comment Period, Public Meeting, and Availability Sessions	37

1.4	Receipt and Identification of Comments	37

1.5	Locating Responses to Comments in the Comment and Response Index	37

2.0 Technical and Legal Issues	37

3.0 References	37

Tables

Table 1: Maximum Detections of COCs in Groundwater	19

Table 2: OU3 Risks	22

Table 3: Cleanup Levels for Groundwater	23

Table 4: Remedial Alternative Costs	29

Table 5: Estimated Costs for Selected Remedy	32

Table 6: Cleanup Levels for Groundwater	32

Table A-1: Risk Summary of Reasonable Maximum Exposures to Groundwater Contaminants in

the Saprolite Lithology	39

Table A-2: Risk Summary of Reasonable Maximum Exposures to Groundwater Contaminants in

the Bedrock Lithology	40

Table A-3: Location-Specific ARARs/TBC for OU3 at the US Finishing/Cone Mills Superfund

Site	411

Table A-4: Action-Specific ARARs/TBC for OU3 at the US Finishing/Cone Mills Superfund

Site	433

Table A-5 Chemical-Specific ARARs/TBC for OU3 at the US Finishing/Cone Mills Superfund
Site	62

Figures

Figure 1: Site Layout	6

Figure 2: Total Chromium Plume in Alluvium/Saprolite with Proposed Injection Locations (for

remedy review and selection)	7

Figure 3: Total Chromium Plume in Bedrock with Proposed Injection Wells (for remedy review

and selection)	8

Figure 4: Groundwater Monitoring Well Locations	13

Figure 5: CSMforOU3	 16

Appendices

State of South Carolina Concurrence	1

Comment and Response Index	1

in

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US Finishing/Cone Mills Super&nd Site OU3
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Acronyms and Abbreviations

AFP

American Fast Print, Ltd.

AOC

Area of Concern

ARAR

Applicable or Relevant and Appropriate Requirement

BERA

Baseline Ecological Risk Assessment

bgs

Below Ground Surface

BRA

Baseline Risk Assessment

CERCLA

Comprehensive Environmental Response, Compensation, and Liability Act

CFR

Code of Federal Regulations

COC

Chemical of Concern

CO PC

Chemical of Potential Concern

CSM

Conceptual Site Model

Duke Energy

Duke Energy Corporation

EPA

U.S. Environmental Protection Agency

ERA

Ecological Risk Assessment

FEMA

Federal Emergency Management Agency

FS

Feasibility Study

HHRA

Human Health Risk Assessment

HI

Hazard Index

HQ

Hazard Quotient

I SCR

In-Situ Chemical Reduction

ISEB

In-Situ Enhanced Bioremediation

Law

Law Engineering Testing Company

MCL

Maximum Contaminant Level

|ig/L

Micrograms per Liter

mg/L

Milligrams per Liter

MIP

Membrane Interface Probe

NCP

National Contingency Plan

NPL

National Priorities List

O&M

Operation and Maintenance

OSHA

Occupational Safety and Health Administration

OSWER

Office of Solid Waste and Emergency Response

OU

Operable Unit

PCB

Polychlorinated Biphenyl

Piper Properties

Piper Properties of Greenville, LLC

PPb

Parts per Billion

ppm

Parts per Million

PRG

Preliminary Remedial Goal

RAO

Remedial Action Objective

RI

Remedial Investigation

RMT

RMT, Inc.

ROD

Record of Decision

SCDHEC

South Carolina Department of Health and Environmental Control

SESD

Science and Ecosystem Support Division

Site

US Finishing/Cone Mills Superfund Site

svoc

Semi-Volatile Organic Compound

iv

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TBC	To Be Considered

VOC	Volatile Organic Compound

WQS	Water Quality Standard

¥

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US Finishing/Cone Mills Superfund Site OU3
Record of Decision
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PART 1: DECLARATION

1.0 Site Name and Location

US Finishing/Cone Mills Superfund Site
Operable Unit 3 (OU3): Sitewide Groundwater

3335 Old Buncombe Road, Greenville County, Greenville, South Carolina
Superfund Site Identification Number SCD003358744

2.0 Statement of Basis and Purpose

This Record of Decision (ROD) presents the Selected Remedy for operable unit 3 (OU3) at the
US Finishing/Cone Mills Superfund site (the Site) in Greenville, South Carolina (Figure 1). The
U.S. Environmental Protection Agency (EPA) chose the Selected Remedy (Alternative GW4:
In-Situ Chemical Reduction (ISCR), In-Situ Enhanced Bioreniediation (ISEB) and
Institutional Controls) 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 42 U.S.C. Section 9617 of the Superfund, and the
National Oil and Hazardous Substances Pollution Contingency Plan (NCP), as set forth in 40
Code of Federal Regulations (CFR) Section 300.430(f)(2). This decision is based on the
Administrative Record file for the Site. The scope of the final OU3 remedy addresses
groundwater contamination in the alluvium, saprolite and bedrock lithologies of the aquifer
underlying the Site.

The EPA is the lead agency for site activities. The South Carolina Department of Health and
Environmental Control (SCDHEC) is the support agency. In accordance with 40 CFR Section
300.430(f)(2), SCDHEC provided input during the remedial investigation (Rl) and feasibility
study (FS) and the remedy selection process. The State of South Carolina concurs with the
Selected Remedy (see Appendix B).

3.0 Assessment of Site

The response action selected in this ROD is necessary to protect the public health or welfare or
the environment from actual or threatened releases of hazardous substances to the environment.
Groundwater in the alluvium, saprolite and bedrock lithologies of the aquifer underlying the Site
is contaminated with contaminants of concern detected above calculated risk-based drinking
water levels or promulgated federal and SCDHEC Safe Drinking Water Act (SDWA) Primary
Drinking Water Standards maximum contaminant levels (MCLs).

4.0 Description of Selected Remedy

The Selected Remedy is the final action to restore contaminated groundwater to its beneficial use
as potential drinking water source and address potential human exposure to contaminated
groundwater in OU3. The Selected Remedy is Alternative GW4: ISCR, ISEB and
Institutional Controls. The primary components of the Selected Remedy include:

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US Finishing/Cone Mills Super&nd Site OU3
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• In-situ treatment through injection wells of highest groundwater contaminant
concentrations using a combination of I SCR. and ISEB reagents.

• Groundwater monitoring to assess efficacy of treatment, attaining cleanup levels and
inform additional remedial activities such as optimization of injections, as needed.

• Implementation of institutional controls to prohibit groundwater use and to prevent
installation of wells near or in groundwater contamination until cleanup levels are met.

The Selected Remedy will address residual groundwater contamination following cleanup of
source materials under OIJ1. There is no principal threat waste in groundwater at the Site.

5.0 Statutory Determinations

The Selected Remedy meets the requirements for remedial actions set forth in Section 121 of
CERCLA, 42 U.S.C. § 9621, and the NCP at 40 CFR § 300.430(f)(l)(ii) because it: 1) is
protective of human health and the environment; 2) meets a level or standard of control of
hazardous substances, pollutants, and contaminants which at least attains the legally applicable
or relevant and appropriate requirements under federal and more stringent state environmental
laws/regulations or justifies a waiver; 3) is cost effective; 4) utilizes permanent solutions and
alternative treatments (or resource recovery) technologies to the maximum extent practicable;
and (5) satisfies the statutory preference for treatment as a principal element to the extent
practicable. Because this remedy will result in hazardous substances, pollutants, or contaminants
remaining above levels that allow for unlimited use and unrestricted exposure, five-year reviews
under CERCLA Section 121(c) will be required for this remedial action.

6.0 Data Certification Checklist

The following information is included in the Decision Summary Section of this ROD. More
information can be found in the Administrative Record file for the Site.

• Chemicals of concern (COCs) and their respective concentrations (Section 5).

• Baseline risk represented by the COCs (Section 7).

• Cleanup levels established for COCs and the basis for these levels (Section 8).

• How source materials constituting principal threats will be addressed (Section 11).

• Current and reasonably anticipated future land use assumptions (Section 6).

• Potential future land and groundwater uses that will be possible at the Site as a result of
the Selected Remedy (Section 6).

• Estimated capital, annual operation and maintenance (O&M), and total present worth
costs, discount rate, and the number of years over which the remedy cost estimates are
projected (Section 10).

• Key factors that led to selecting the remedy (i.e., describe how the Selected Remedy
provides the best balance of tradeoffs with respect to the balancing and modifying
criteria, highlighting criteria key to the decision) (Section 12).

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US Finishing/Cone Mills Super&nd Site OU3
Record of Decision
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7.0 Authorizing Signature

P A M n A I I	Digitally signed by

r\/"M ML/ALL	RANDALL CHAFFINS

CHAFFINS ^oa2023 09'28 07:01:03

Caroline Y. Freeman, Director

Superfund & Emergency Management Division

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US Finishing/Cone Mills OU3
Record of Decision
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PART 2: THE DECISION SUMMARY

1.0 Site Name, Location and Brief Description

The Site is located at 3335 Old Buncombe Road in Greenville, Greenville County, South Carolina (EPA
ID: SCD003358744). The Site originally included approximately 259 acres. The EPA is the lead agency
for site activities. The SCDHEC is the support agency. Historical textile operations at the Site
contaminated surface water, groundwater, sediment, and soil. Operations at the Site began in 1903 and
stopped in 2003, when a fire partially destroyed the Main Plant.

To manage investigations and cleanup, the EPA divided the Site into three OUs. OIJ1 is the Main
Facility. OU2 is Off Main Facility. OU3 is sitewide groundwater. Figure 1 shows the locations of OIJ 1
and OU2. Figure 2 and Figure 3 show the extent of the total chromium plume (including hexavalent
chromium) in the alluvium, saprolite and bedrock lithologies of the aquifer underlying the Site. The
contamination occurs adjacent to and beneath slab foundations of the former facility. OIJ 1 will address
removal of the slabs to facilitate sampling and treatment, as needed, of any source material located in the
sub slab area. Langston Creek borders the Site to the east. Reedy River borders the Site to the west and
south. Residential properties border the Site to the north. Most of the residential areas that border the
Site are low density. No municipal or private drinking water supply wells are located near the plume or
downgradient of the Site.

The EPA selected the remedy for OIJ 1 in a 2022 Record of Decision (ROD). OIJ 1 includes 11 areas of
concern (AOCs):

AOC02 - Aeration Lagoon.

AOC03 - Reedy River Floodplain.

AOC04 - Basement Sludges.

AOC05 - Former Chromium Tank and Lines.

AOC06 - Former Petroleum Lines.

AOC07 - Caustic Plume Area.

AOC08 - Blue Pond.

AOC 10 - Soils Between Main Plant and Langston Creek.
AOC 1 1 - Alston Street Fuel Oil Storage Tank Area.
AOC 12 - Water Treatment Plant.

AOC 16 - Main Plant.

Remedial actions are planned for AOC 12 and AOC 16; the other nine AOCs require no further action to
support unlimited use unrestricted and unrestricted exposure. The EPA partially deleted the no further
action OIJ 1 AOCs (AOC02, AOC03, AOC04, AOC05, AOC06, AOC07, AOC08, AOC 10, and AOC 1 1
- totaling about 70 acres) from the Superfund program's National Priorities List (NPL) on
February 22, 2023 (88 Federal Register 1085 1).

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US Finishing/Cone Mills OU3
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The EPA issued a No Action ROD for OU2 in 2021. The EPA deleted OU2 (about 150 acres) from the
Superfund program's NPL on September 14, 2021 (86 Federal Register 51010). OU2 includes
six AOCs:

•	AOCO1 - Permitted Sludge Landfill.

•	AOC09 - Langston Creek.

•	AOC13 - Reedy River.

•	AOC14 - Northern Reservoir.

•	AOC 15 - Northwestern Reservoir.

•	AOC 17 - Forested Tract.

This decision document addresses groundwater contamination (OU3) in the alluvium, saprolite and
bedrock lithologies forming the aquifer underlying the Site.1

1 The groundwater beneath the Site is present in four differing lithologies: alluvium, saprolite. partially weathered rock and
bedrock. They each have differing hydraulic properties but arc considered one aquifer with normal varying degrees of
heterogeneity. There are no defined confining layers, and these units acts together as one unconfincd aquifer.

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Figure 1: Site Layout

US Finishing/Cone Mills OU3
Record of Decision
September 2023

Northern
Reservoir

[Northwestern]

WResewoirB

[Aeration]
Igaqoorrl

j Approximate
" Site Boundary
CI! Main Plant
OU1

K-

k«>L



1
11

Sans Souci

¦ fi



!

FIGURE 1:
Site Layout

US Finishing/Cone Mills Superfund Site

City of Greenville, Greenville County, South Carolina

Disclaimer This map and any boundary lines within the map are approximate and
subject to change. The map is not a sun/ey. The map Is for informational purposes
only regarding the EPA's response actions at the Site. Sources: NC CGIA, Maxar,
Estl Community Maps Contributors. City of Greenville. Esrt, HERE. Garmln.
SafeGraph. GeoTechnologies, Inc, METI/NASA, USGS. EPA, NPS. US Census
Bureau, USDA. USGS NHD. the 2020 BERA and the 2021 ROD

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US Finishing/Cone Mills OU3
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Figure 2: Total Chromium Plume in Alluvium/Saprolite with Proposed Injection Locations (for remedy review and selection)

Notes:

1.	Wells screened across multiple zones (alluvial
and saprolite) are included in the saprolite

isocontour model.

2.	Sample points without detectable chromium
modeled as a zero value for contouring purposes.

3.	U - Indicates chromium was analyzed for, but not
detected above the sample quantitation limit.

4.	Apparent discontinuities in chromium (total)
isocontours and individual well concentrations
are the result of a vertical concentration gradient

quifer zone.

Legend

PT Discrete G
ample (Hydro)

® Temporary Wells

Monitoring Well

• Saprolite/Alluvial
® Saprolite

1 AOC16 Main Plant
Site Boundary
Stream/River

eflilHfe Chromium (Total)

Isoconcentration (pg/L)

Saprolite Chromium (Total)
Groundwater Concentration
Isocontour

Saprolite Inferred Chromium (Total)
-——— Groundwater Concentration
Isocontour

Proposed Injection Locations (Alluvial)
15' apart with 3D" row spacing

March 2014 GWEIevation Contour

US Finishing/Cone Mills
Greenville, Greenville County
South Carolina

FIGURE 5-1
Proposed Alluvium/Saprolite
Injection Locations

VERSAR

Greenville County
South Carolina

Source: Sitewide FS Report for US Finishing/Cone Mills, Greenville. Greenville County, South Carolina. Prepared by Versar. July 15, 2020.

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Figure 3: Total Chromium Plume in Bedrock with Proposed Injection Wells (for remedy review and selection)

US Finishing/Cone Mills OU3
Record of Decision
September 2023

Source: Sitewide FS Report for US Finishing/Cone Mills, Greenville, Greenville County, South Carolina. Prepared by Versar. July 15, 2020.

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US Finishing/Cone Mills OU3
Record of Decision
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2.0 Site History and Enforcement Activities

2.1 Site Activities Leading to Current Problems

In 1903, the Arrington family constructed and operated a textile bleaching and finishing facility
under the name of Union Bleachery. Between 1903 and 1947, the plant expanded on several
occasions. In 1947, the Aspinook Corporation purchased the facility. In 1957, Cone Mills
acquired the facility. Cone Mills operated the plant until 1984 under the name Union
Bleachery/Cone Mills. American Fast Print, Ltd. (AFP) purchased the facility in May 1984 and
operated under the name US Finishing until November 2003, when a fire partially destroyed the
Main Plant.

Operational details from 1903 through 1957 are not available. The main production area was on
the first floor of the Main Facility. The second floor contained the dye and chemical mixing
areas and the inspection and grading areas for completed material. The basement consisted of an
eastern and a western side separated by a concrete trench. The basement was used for spare parts
storage, wastewater storage, and wastewater conveyance. Chemicals were stored in the basement
until a flood in 1974 inundated the basement and flooded many of the chemical storage areas.
The western half of the basement contained a wastewater conveyance system that included the
dye range sump (dye sump), piping, and a few smaller trenches leading to the main wastewater
trench running the length of the center of the building. The main trench routed wastewater
through the plant, north to south, toward the underground piping and pumps for ultimate
discharge into the wastewater treatment lagoon.

A brine pit, for the storage of a brine solution used in plant processes, was located on the
southwest side of the facility, near one of the storage warehouses. The brine pit was a concrete
basin measuring 32 feet by 12 feet. It was covered during use. After the 2003 fire, the brine pit
was pumped out and the contents taken off the facility property for use by another manufacturer.
Demolition of the brine pit basin took place in 2005. The water treatment plant was used for the
preparation of process water for use by the facility. The water for the water treatment plant came
from the Northern Reservoir and Northwestern Reservoir. Prior to building the Northern
Reservoir, raw water was pumped during emergencies from a pumping station on the Reedy
River and directed to a raw water lagoon.

2.2 History of Investigations and Cleanup Actions

2.2.1 History of State of South Carolina Investigations and Cleanup Actions

Since 1994, there have been multiple remedial and removal actions at the Site. The following
investigations and cleanups took place at the Site prior to 2008:

• 1980: Cone Mills submitted a Hazardous Permit Application, Part A.

• 1981: The SCDHEC issued a memorandum documenting the special survey
conducted by the Greenville Monitoring Section. The survey area consisted of
Langston Creek upstream of the facility to just downstream of the confluence of
Langston Creek and the Reedy River. The impoundment and Langston Creek

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US Finishing/Cone Mills OU3
Record of Decision
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downstream of the pool were tinted yellow-green and chromium concentrations in
surface water and sediment at the pool and downstream were detected at
concentrations above the upstream areas. The SCDHEC officials concluded that
the point of discharge for the chromium was below the Langston Creek
impoundment on the east side of the facility property. Cone Mills retained Law
Engineering Testing Company (Law) to determine the source of chromium
contamination in Langston Creek. Law performed a resistivity study in the
Langston Creek floodplain and installed monitoring wells to identify lateral extent
of chromium in the upper aquifer. The preliminary conclusions indicated that the
source of chromium contamination in the groundwater was a break in the line
between the old chromium storage tank and the dyeing area, with the exact
source unknown.

1982: Cone Mills installed and operated a groundwater recovery and remediation
facility on the property to address chromium contamination adjacent to
Langston Creek.

1984: Cone Mills entered into a Consent Order with the SCDHEC. The Consent
Order documented the groundwater contamination and required that Cone Mills
continue to recover and treat contaminated groundwater after AFP purchased
the plant.

1985: Cone Mills retained Aquatic Analysts to conduct a macroinvertebrate
assessment. The assessment found decreases in the number of both tax a and
specimens and recommended further study.

1985: Cone Mills and AFP conducted chromium analysis on fish tissue and
organs. The SCDHEC completed a Preliminary Assessment for the Cone
Mills Plant.

1987 - 1990: Rogers and Callcott Engineers, Inc., joined by GeoTrans in 1989,
conducted a Preliminary Investigation on behalf of AFP. In 1989, Cone Mills and
AFP conducted a second chromium analysis on fish tissue and organs.
1990 - 1991: GeoTrans completed the RI on behalf of AFP from August 1990 to
June 1991. GeoTrans submitted the Rl/FS Report on July 25, 1991.

1993	- 1999: AFP contractors removed basement sludge. Sludge removal was
achieved through a combination of shoveling, sweeping, and/or washing.

1994	- 1995: Soil removal activities were conducted at the facility from July 1994
through March 1995 by RMT, Inc. (RMT) on behalf of Cone Mills as part of a
1993 Settlement Agreement with the State of South Carolina. Soil removal
activities excavated about 3,636 tons of total petroleum hydrocarbon-affected soil,
6,958 tons of chrom i urn -affected soil, and 3,145 tons of caustic-affected soil from
the facility.

November 2003: A fire destroyed much of the Main Facility.

2004: Due to an impending bankruptcy. Cone Mills removed the groundwater
recovery and treatment system, after 20 years of operation. The SCDHEC
completed an Expanded Site Inspection. Sampling detected metals and
polychlorinated biphenyls (PCBs) in the soils and sediments. Barium, chromium,
iron, lead, magnesium, manganese, and vanadium were detected in groundwater
samples collected downgradient of the Langston Creek floodplain and the sludge
settling basin.

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• 2004: Removal activities took place, under State of South Carolina oversight, at
the facility between October 2004 and December 2004. Removal activities
addressed the area of soil contamination near the southwest corner of the Main
Plant building, sediment from the maintenance shop drain, contaminated soil near
the elevated railroad bed, and contaminated soil near the oil pump house. In
addition, contents from both the brine pit and the former groundwater treatment
plant basin were removed. Then, the brine pit and the groundwater treatment plant
basin were pressure-washed and demolished. Although removal activities were
conducted at the plant, confirmation samples from the areas of soil contamination
near the southwest comer of the Main Plant building, the elevated railroad bed,
and the oil pump house indicated that contamination remained in place.

• 2005: Fletcher Group, Inc. ( AFP contractor) conducted confirmation sampling for
the basement sludge removal conducted between 1993 and 1999. Post-removal,
concentrations of chromium exceeded the cleanup goal of 400 parts per million
(ppm) in four samples; chromium concentrations in two of the four samples
exceeded 1,000 ppm. Subsequently, AFP power-washed those areas to remove the
remaining chromium contamination. The soil beneath the basement was not
removed during the cleanup and removal of the basement sludge, with the
exception of "Area 3", which had soil removed to a maximum depth of 1.5 feet.

• 2006: AFP, Duke Energy Corporation (Duke Energy), and Piper Properties of
Greenville, LLC (Piper Properties), (the Settling Parties), entered into a settlement
agreement with the SCDHEC, as documented by a Consent Decree presented to
the Court in November 2006. The Consent Decree stated that textile operations by
some of the owners/operators significantly contaminated the property and
surrounding areas with hazardous substances, as defined by CERCLA. The
Settling Parties agreed to assume all future obligations for remedial action,
including the completion of the R1 and the FS, and the performance of the remedy
to be selected by the SCDHEC at the property, consistent with the technical intent
of the NCP.

• 2007: Duke Energy led an investigation to delineate the extent of PCB soil
contamination in the vicinity of the substation and near the oil pump house, the
coal storage area, and former and current pole-mounted transformers. Following
the delineation of the extent of PCB contamination in those areas of the facility,
Duke Energy submitted a Soil Removal Plan and removed PCB-contaminated soil
and collected and confirmation samples. Clean fill was brought in to backfill the
removal areas.

2.2.2 History of EPA Investigations and Cleanup Actions for OU3

EPA Region 4's Science and Ecosystem Support Division (SESD) and contractor Versar
performed field activities from August 2012 to November 2016 to inform development of the
Final Remedial Investigation Report for OU3, completed in April 2020, and the Final Feasibility
Study Report for OIJ1, OU2, and OU3, completed in July 2020. Monitoring well surveys,
repairs, and abandonments of the Site's existing monitoring and recovery well network took
place in August 2012, from March 2013 to May 2013, and in July 2013. Figure 4 shows the
current monitoring well network at the Site.

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US Finishing/Cone Mills OU3
Record of Decision
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Temporary monitoring well installations took place:

•	August 2012 for AOCO1.

•	June 2013 for AOC03 and AOC 14.

•	November 2013 for AOC06 and AOC 16.

•	July/August 2014 for AOC05, AOC06, AOC07, AOC11, AOC 12, and AOC 16.

Permanent monitoring well installations took place:

•	October/November 2013 for AOC 16.

•	December 2013 for AOC 16, AOC08, and AOC 1 1.

•	March 2014 for AOC02, AOC03, AOC09, and AOC 16.

Ten groundwater sampling events took place between August 2012 and November 2016.

2.3 History of CERCLA Enforcement Activities

This section provides a brief summary of the Site's regulatory history:

•	In 1981, Cone Mills submitted a Notification of Hazardous Waste Site to EPA Region 4
for the Union Bleachery/Cone Mills plant.

•	In 1984, Cone Mills entered into a Consent Order with the SCDHEC stating that
sampling in nearby Langston Creek in 1980 and 1981 exhibited excessive levels of
chromium and a groundwater study found chromium contamination in groundwater
beneath the Cone Mills facility property at levels exceeding South Carolina Water
Quality Standards (WQS). The Consent Order further outlined that Cone Mills should
continue to recover and treat the contaminated groundwater, despite the sale of the
property to AFP.

•	The Settling Parties entered into a settlement agreement with the SCDHEC, as
documented by a Consent Decree in November 2006. The Settling Parties agreed to
assume all future obligations for remedial action, including the completion of the RI and
the FS, and the performance of the remedy to be selected by the SCDHEC at the property.

•	EPA added the Site to the NPL in 201 1.

12

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Figure 4: Groundwater Monitoring Well Locations

US Finishing/Cone Mills OU3
Record of Decision
September 2023

Source: Sitewlde FS Report for US Finishing/Cone Mills, Greenville, Greenville County, South Carolina. Prepared byVersar. July 15, 2020.

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3.0 Community Participation

The public has been kept informed of the progress on the RI and FS and other Superfund actions
through community notification flyers, presentations, and updates in accordance with the EPA's
Community Involvement Plan for the Site, available at:

https://semspub.epa.gOv/src/document/04/l 1145228. The EPA released the Proposed Plan for
OU3 for public comment on June 21, 2023. The Proposed Plan and other site-related documents
were made available to the public in the Administrative Record file maintained in the Site's
online information repository at https://semspub.epa.gov/src/collections/04/AR/SCD003358744.
The Site's local information repository is Hughes Main Library, located at 25 Heritage Green
Place in Greenville, South Carolina 29601. The library is open and provides computer access for
the community to access the Site's Administrative Record file online. The notice of availability
of these documents was published in the Greenville News on June 21, 2023. A public comment
period was held from June 21, 2023, to August 11, 2023.

To present the OU3 Proposed Plan to the community, the EPA sponsored a public meeting on
July 11, 2023, at Parisview Baptist Church, located at 100 Bud Street in Greenville, South
Carolina. The Site's remedial project manager discussed the OU3 Proposed Plan with
community members in attendance, explained why the EPA prefers this remedy, and responded
to questions and comments. Comments received by the EPA during the public comment period
are summarized and addressed in the Responsiveness Summary (see Part 3 and Appendix C).

Prior community involvement activities that informed the future land use of the site property
include the Greenville County Planning Commission spearheading a consortium of area
stakeholders in development of a Comprehensive Plan for future land use in Greenville County
in 2009. This plan discussed the Priority Investment Act and led to selection of a large land area
including the site, as "Priority Investment Area Three." This designation serves as a supplement
to the county's Future Land Use Map and identifies a priority area where the county can most
effectively accommodate future growth, and where growth is needed to support overall future
land use objectives. The Future Land Use Map and priority investment designation informed
consideration of reasonably anticipated future land uses for the site property.

4.0 Scope and Role of the Operable Unit or Response Action

The EPA divided the Site into three OUs to manage the CERCLA remedy selection process. The
EPA will pursue the partial deletion of the Site from the NPL as required OU cleanups are
completed and OUs become ready for their anticipated future use. The focus of this ROD is OU3
(contaminated sitewide groundwater).

The EPA issued a No Action ROD for OU2 (Off Main Facility) on April 1, 2021, after
determining that no remedial action is necessary to ensure protection of human health and the
environment. The EPA deleted the entirety of OU2, including the six AOCs listed in Section 1.0,
from the NPL on September 14, 2021 (86 Federal Register 5 1010).

The EPA issued the OlJ 1 (Main Facility) ROD on June 27, 2022. The EPA determined that a
CERCLA response action at the following AOCs in OlJ 1 is unnecessary (No Action Decision)

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because, based on the baseline risk assessment (BRA) performed as part of the RI, there is no
unacceptable risk to human health or the environment based on current and reasonably
anticipated future land use (commercial/industrial or recreational for AOC03):

• AOC02 - Aeration Lagoon.

• AOC03 - Reedy River Floodplain.

• AOC04 - Basement Sludges.

• AOC05 - Former Chromium Tank and Lines.2

• AOC06 - Former Petroleum Lines.

• AOC07 - Caustic Plume Area.

• AOC08 - Blue Pond.

• AOC 10 - Soils Between Main Plant and Langston Creek.

• AOC 1 1 - Alston Street Fuel Oil Storage Tank Area.

The EPA partially deleted the no further action OIJ1 AOCs (about 70 acres) from the Superfund
program's NPL on February 22, 2023 (88 Federal Register 10851). Remedial actions are planned
for OIJ 1 AOC 12 and AOC 16, including removal of contaminated soils for off-site disposal,
removal of friable asbestos-containing materials in the Powerhouse Building, maintenance of
disposal cell covers, and institutional controls to prevent potential, future unacceptable exposures
to wastes remaining on site. The OIJ 1 remedy also includes removal of a former building slab to
determine whether a potential source area for groundwater contamination is located beneath the
slab. Remedial design of the OIJ 1 remedy is scheduled to begin in 2023.

This ROD addresses OU3 (contaminated sitewide groundwater). Ingestion of water extracted
from the groundwater contamination plume poses a current and potential future risk to human
health because the EPA's generally acceptable risk range is exceeded, and concentrations of
contaminants are greater than the maximum contaminant levels (MCLs) for drinking water (as
specified in the Safe Drinking Water Act (SDWA) Primary Drinking Water Standards
regulations at 40 CFR 141. 61 and 141.62) which are considered relevant and appropriate
requirements under CERCLA Section 121(d)(2) and the NCP at 40 CFR §300.430(e)(2)(i)(B.
Although there are no water supply wells located near the plume, groundwater at this site is a
potential future source of drinking water per SCDHEC R.61-68 H. Class Descriptions and
Specific Standards for Ground Waters.

5.0 Site Characteristics

5.1 Conceptual Site Model

The Conceptual Site Model (CSM) incorporates information on potential chemical sources,
affected media, release mechanisms, routes of migration, and known or potential human and
ecological receptors. The CSM illustrates the physical, chemical, and biological relationships
between contaminant sources and affected resources. A simplified CSM showing important

2 The remedy selected for AOC 5 is "no further action" based on previous removal actions conducted under SCDHEC
oversight, which removed surface and subsurface chromium-contaminated soil (Soil Removal Report. Former Union
Bleachery. Greenville. SC. May 1995 by RMT, Inc.). Any groundwater contamination and deep residual soil
contamination beneath this area will be addressed as part of OU3.

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features of the groundwater, sources of contamination, and aspects of contaminant degradation
and migration was developed for OU3. Groundwater in the area is not currently used as a
potable water source and there are currently no plans to access the groundwater for potable
uses in the future.

The CSM (Figure 5) showed that there are several potentially complete exposure pathways:

• Ingestion of groundwater.

• Inhalation of vapors released from groundwater.

The following receptor population was evaluated:

• Future lifetime residents.

Exposure assumptions were based on the latest EPA guidance.

Figure 5: CSM for OU3

Complete

5.2 Overview of the Site

The 259-acre site property is bordered by Langston Creek on the east, Reedy River to the west
and south, and residential properties to the north. The OU1 property included about 110 acres of
land; the EPA deleted 70 of these OU1 acres from the NPL in 2023 because no further action
was needed for this land to support unlimited use and unrestricted exposure. OU2 included
approximately 150 acres. The EPA deleted OU2 from the NPL in 2021.

5.2.1 Geologic, Hydrogeologic and Topographic Information

Site topography varies. The Main Facility area is generally flat, with a downhill gradient sloping
toward Langston Creek. Ground surface elevations at the Site range from about 930 feet to 954
feet above mean sea level. Surface water flows into Langston Creek and then to the Reedy River
or directly into the Reedy River. Most of the eastern and southern sides of the property lie within
a 100-year Federal Emergency Management Agency (FEMA) flood zone along the Langston
Creek and Reedy River floodplains. Federally designated wetlands are next to the Reedy River in
the southwest part of the Site.

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The Site is in the Piedmont geologic province, where bedrock is characterized by high-grade
metamorphic and igneous rock. Drilling logs indicate that the gray granite gneiss bedrock is
overlain by weathered bedrock (saprolite) and poorly sorted alluvium.

In the alluvium, the groundwater gradient flows generally southeast near the Main Plant toward
Langston Creek and Middle Creek, south near the Aeration Lagoon and Reedy River Floodplain
toward Reedy River, and west and northwest on the opposite side of Langston Creek. The flow
patterns in the saprolite are similar to those in the alluvium, northwest of Langston Creek. The
flow pattern in the bedrock is also similar based on the limited number of bedrock wells. Unlike
the alluvium lithology, the flow direction continues south and southeast on the opposite side of
Langston Creek and Middle Creek. Depending on topographical location, groundwater is about
3 feet to 30 feet below ground surface. Bedrock fractures are directly connected forming an
integrated groundwater flow system that can act as a reservoir and allows stored water to move
vertically in the fractured rock. Groundwater in bedrock of the Piedmont Aquifer is generally
unconfined. Locally, artesian and confined conditions can exist when wells penetrate deeply
buried fractures that are hydraulically connected to recharge areas at higher altitudes or in places
where the regolith is clayey and forms a confining unit.

5.3 Sampling Strategy

The sampling strategy was developed based on a review of previous investigations. Sampling
completed as part of the OU3 R1 characterized the extent of the groundwater contamination in
the alluvium, saprolite, and bedrock lithologies of the aquifer across the entire Site as compared
to MCLs and risk-based screening levels. From August 2012 to November 2016, EPA Region 4's
Science and Ecosystem Support Division and Versar (an EPA contractor) completed 10
groundwater sampling events. Samples were analyzed for metals, PCBs, pesticides, volatile
organic compounds (VOCs) and semi-volatile organic compounds (SVOCs).

5.4 Known or Suspected Sources of Contamination

Historical textile operations, disposal practices, and chemical storage are the primary sources of
contaminants at the Site. Specifically, chromium was used as the oxidation chemical for the
dyeing process. Facility operations contaminated groundwater with metals, SVOC, and volatile
organic compounds VOC. Chromium is the primary COC in groundwater and the main source of
risk to human health. Soils underneath the remaining Main Facility structure are likely
contaminated with chromium and are a suspected source of groundwater contamination.

5.5 Nature and Extent of Contamination

A summary of the nature and extent of contamination associated with OU3 is in the R1
documents, which are available in the Site's Administrative Record. Sampling completed as part
of the R1 characterized the extent of the contamination within OU3 as compared to the EPA's
and SCDHEC's Primary Drinking Water Standards MCLs and risk-based screening levels based
on drinking water levels. A brief summary of the nature and extent of the groundwater
contamination is below.

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The 2020 RI Report for OU3 found metals, VOCs and SVOCs in groundwater at concentrations
exceeding MCLs, or levels that exceed protection of human health from direct exposure to
contaminated groundwater. Metals contamination consisted primarily of chromium and, more
specifically, hexavalent chromium. With a few exceptions, total chromium and hexavalent
chromium were detected in similar concentrations; if the concentration of one metal exceeded
MCLs, both metals did. In most instances, the remaining metals preliminary remediation goal
(PRG) exceedances were widespread and occurred at different locations than the chromium
exceedances. VOCs and SVOCs were detected in areas both with and without chromium
exceedances. No PCBs were detected. No MCL exceedances were detected for pesticides.

5.5.1 Quantity/Volume of Waste that Needs to Be Addressed

The plumes of hexavalent chromium concentrations exceeding the PRG encompass an area of
about 15 acres (653,400 square feet) in both the alluvium and saprolite. The plume of hexavalent
chromium exceeding the PRG encompasses an area of about 2.1 acres (89,800 square feet) in
the bedrock.

The alluvium and saprolite groundwater contamination extends approximately between 2 feet
below the ground surface (bgs) and 53 feet bgs east of the Main Plant and between 2 feet bgs and
26 feet bgs beneath the Main Plant, for an average contaminant plume thickness of 38 feet
(2 feet bgs to 40 feet bgs). Using an average composite porosity of 0.35 for the alluvium and
saprolite, the plume is expected to contain a volume of about 65.01 million gallons.

5.5.2 Concentrations of COCs

The 2018 Human Health Risk Assessment (HHRA) examined the risk of exposure to children
and adults through the inhalation and ingestion pathways for groundwater contaminants and
selected chemicals of potential concern (COPCs) for the saprolite lithology (Table A-1) and the
bedrock lithology (Table A-2) based on risk to human health. The primary groundwater COC at
the Site is chromium and, more specifically, hexavalent chromium, which poses the greatest risk
to human health. The COCs for site groundwater include 1,2-dichlorobenzene,
2-methylnaphthalene, 4-chloroaniline, arsenic, cobalt, hexavalent chromium, iron, manganese,
molybdenum, and strontium. Table 1 lists maximum concentrations detected for site COCs
during the OU3 RI. The April 2020 RI Report is available in the Administrative Record.

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Table 1: Maximum Detections of COCs in Groundwater

Maximum

COC

MCL

Concentration

Monitoring Well

Sou rce"

(M«/L)

Detected
(MJl/L)

1,4-Dichlorobenzene

AOC1629

Table 6-5

2-Methylnaphthalene

not established

4.7 U

MIP02 b

Table 6-4

4-Chloroanilinc

not established

11 U. J. QL-1

RMT-2

Table 6-4

Arsenic

AOC0502

Table 6-1

Cobalt

not established

31 c

AOC0726

Table 6-1

Hcxavalcnt chromium

100 d

22,000

W-9

Table 6-1

Iron

300 e

130,000

AOC0502

Table 6-1

Manganese

50e

13,000

MW-16R

Table 6-1

Molybdenum

not established

VV-2

Table 6-1

Strontium

not established

15,000

MW-113D

Table 6-1

Notes:

a. References table used as source in the 2020 OU3 Rl Report.

b. Discrete groundwater sample collected using Membrane Interface Probe (MIP) technology; probe locations
were abandoned after sample collection.

c. Several 50 p,g/L results were marked with a "U" qualifier, indicating the anal vie was not detected at or above

the reporting limit.

d. The MCL value at 40 CFR 141.62 is for total chromium.

e. The MCL value is the secondary MCL from the EPA's National Primary Drinking Water Regulations which
are based on organoleptic factors as opposed to health based considerations.

|ig/L = micrograms per liter
J = reported value is an estimate.

QL-1 = laboratory control spike recovery less than method control limits.

U = analyte not detected at or above reporting limit.

5.6 Location and Potential Routes of Migration

Metal, VOC, and SVOC contamination was present in groundwater beneath the Site. In the
aquifer, the chromium exceedance plume occurs mostly east of the Main Plant and west of the
facility property boundary at Blue Ridge Drive. The highest concentrations occurred along
Langston Creek, near the Langston Creek Impoundment. A separate shallow plume occurs in the
alluvial sediments southwest of the Main Plant near the Main Plant gray warehouse. The plume
in saprolite lithology extends west under the Main Plant and southwest to Main Plant gray
warehouse (See Figure 2 and Figure 3). Vertical contaminant migration is evident due to
exceedances being present in both saprolite and bedrock lithologies. Current and future potential
routes of exposure are through the ingestion and inhalation pathways. Based on detected COC
concentrations in groundwater, as compared with respective screening levels, it is likely that
contamination could pose an unacceptable risk to human populations.

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6.0 Current and Potential Future Groundwater and Land Uses

Currently, there are no municipal or private water supply wells located near the plume. However,
according to SCDHEC R.61-68 H. Class Descriptions and Specific Standards for Ground
Waters, the groundwater located underneath the Site is considered Class GB. This includes all
state groundwater that meets the definition of underground sources of drinking water. Therefore,
while no current plans are in place to use groundwater as a drinking water source, groundwater is
considered a potential future source of drinking water. Cleanup will necessitate groundwater
remediation to attain Safe Drinking Water Act primary drinking water standards maximum
contaminant levels (MCLs) or human-health risk drinking water levels in the absence of an MCL
throughout the plume. The site property is vacant and not in use. Future anticipated use includes
mixed use and commercial.

7.0 Summary of Site Risks

This section summarizes the results of the 2018 HHRA for OU3. In addition, per the NCP, the
EPA conducted a baseline risk assessment as part of the 2020 OU3 R1 to estimate the current and
future effects of site contaminants on human health and the environment. A baseline risk
assessment is an analysis of the potential adverse human health and ecological effects of releases
of hazardous substances from a site in the absence of any actions or control s to mitigate such
releases, under current and reasonably anticipated future land uses. The baseline risk assessment
typically includes an HHRA and an ecological risk assessment (ERA) It provides the basis for
taking action and identifies the contaminants and exposure pathways that need to be addressed
by the remedial action. Groundwater at the Site is in the subsurface and does not have any
ecological receptors. For this reason, an ERA was not performed for OU3.

7.1 Human Health Risk Assessment (HHRA)

A four-step process assesses site-related human health risks for a reasonable maximum
exposure scenario:

• Hazard Identification - uses the analytical data collected to identify the CO PCs at the Site
for each medium, with consideration of several factors explained below.

• Exposure Assessment - estimates the magnitude of actual and/or potential human
exposures, the frequency and duration of these exposures, and the pathways by which
humans are potentially exposed.

• Toxicity Assessment - determines the types of adverse health effects associated with
chemical exposures, and the relationship between magnitude of exposure (dose) and
severity of adverse effects (response).

• Risk Characterization - summarizes and combines outputs of the exposure and toxicity
assessments to provide a quantitative assessment of site-related risks. The risk
characterization also identifies contamination with concentrations which exceed
acceptable levels, defined by the NCP as an excess lifetime cancer risk greater than

1 x 10"6 to 1 x 10"4, or a hazard index (HI) greater than 1.0. Contaminants at these
concentrations are considered COCs and will typically require remediation. This section
also includes a discussion of the uncertainties associated with these risks.

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The HHRA estimates the risks the Site poses if no action was taken. It provides the basis for
taking action and identifies the contaminants and exposure pathways that need to be addressed by
the remedial action. This section of the ROD summarizes the results of the HHRA for the Site.

7.1.1 Hazard Identification

The 2018 HHRA considered data collected during the OU3 R1 (August 2012 to November 2016)
to evaluate groundwater. Constituents detected in groundwater data were compared to EPA
regional screening levels for tap water. The HHRA retained groundwater COPCs following EPA
Region 4 guidance.

7.1.2 Exposure Assessment

The exposure assessment calculates potential chemical intake, or exposure concentration, for the
exposure pathways evaluated in the HHRA. Exposure is a function of the chemical concentration
at the point of contact (i.e., exposure point concentrations) and parameters that characterize the
activity patterns of the potentially exposed receptors. The assessment of pathways by which
human receptors may be exposed to chemicals of potential concern includes an examination of
existing migration pathways (i.e., soil) and exposure routes (i.e., ingestion, dermal absorption),
as well as those pathways that may be reasonably expected in the future.

Potentially complete exposure pathways examined in the 2018 Final HHRA for OU3 are:

• Ingestion of groundwater.

• Inhalation of vapors released from groundwater while showering.

Potential receptor populations include child and adult future residents. Groundwater in the area is
not currently used as a potable water source and there are no plans to access the groundwater for
potable uses in the future.

7.1.3 Toxicity Assessment

The toxicity assessment summarizes the health effects that may be associated with exposure to
the COPCs selected for the risk assessment and identifies doses that may be associated with
those effects. It involves evaluating the potential for a constituent to cause an increase in the
incidence of adverse effects in exposed individuals and quantitatively characterizing the
chemical dose and the incidence of adverse health effects in the exposed receptor. The potential
toxicological effects induced by a given dose of a chemical are classified as either noncancer
effects or cancer effects. Toxicity values typically employed to calculate baseline non-
carcinogenic hazards include reference doses for oral and dermal exposures, and reference
concentrations for inhalation exposures. Oral and dermal cancer slope factors and inhalation unit
risks are typically used to estimate carcinogenic risks. Constituent-specific toxicity values were
used to calculate potential effects for these two types of effects. Toxicological criteria were
selected following the EPA's 2003 hierarchy, as follows for the HHRA:

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• Tier 1 - the EPA's Integrated Risk Information System.

• Tier 2 - the EPA's 2018 Provisional Peer Reviewed Toxicity Values.

• Tier 3 - Other toxicity values, including EPA and non-EPA sources of toxicity
information, including:

o Agency for Toxic Substances and Disease Registry Minimal Risk Levels,
o EPA Health Effects Assessment Summary Table values.

7.1.4 Risk Characterization

EPA considers two types of risk: cancer risk and noncancer risk. The likelihood of any kind of
cancer resulting from a Superfund site is generally expressed as an upper bound probability, for
example, a " 1 in 10,000 chance". In other words, for every 10,000 people that could be exposed,
one extra cancer may occur because of exposure to site contaminants. An extra cancer case
means that one more person could get cancer than would normally be expected to from all other
causes. For noncancer health effects, the EPA calculates a "hazard index" or HI. The key concept
is that a "threshold level" (measured as an HI of less than 1) exists below which noncancer
health effects are no longer predicted. A CERCLA response action is generally warranted when
cancer risk is greater than 1 x 10"4 or when noncancer health effects are greater than an HI of 1.

Cancer and noncancer risks were calculated for each exposure pathway and scenario by
integrating the exposure doses calculated in the exposure assessment with the toxicity criteria
determined in the toxicity assessment.

Excess cancer risk exceeded the EPA's generally accepted risk range for a future lifetime resident
(1 x 10"1) in the saprolite lithology (Figure A-1) and (4 x 10"2) in the bedrock lithology (Figure
A-2). Noncancer hazards exceeded the EPA's generally accepted HI of 1 for a future lifetime
resident (HI = 206) in the saprolite aquifer and (HI = 66) in the bedrock aquifer. Hexavalent
chromium is the primary risk driver for both carcinogenic and non-cancer risk in both
lithologies.

Table 2: OIJ3 Risks

Groundwater Lithology

Exposure Seenario

Excess Cancer Risk

NoncancerHI

Saprolite

lifetime resident

1 x 10"1

206

Bedrock

4 x 10"2

Notes:

Source: Table on page 2-17 of the Final Feasibility Study Report for OU1. OU2. and OU3, US Finishing/Cone
Mills, Greenville. Greenville Count v. South Carolina. Versar. My 15, 2020.

7.2 Basis for Action

The response action selected in this ROD is necessary to protect the public health or welfare or the
environment from actual or threatened releases of hazardous substances into the environment. The
presence of COCs in the groundwater exceeding MCLs, and protective human health risk-based
levels in the absence of an MCL for a particular COC, present an unacceptable risk of exposure
to future residents. The primary risk is attributable to exposure to hexavalent chromium.

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8.0 Remedial Action Objectives (RAOs)

Before developing cleanup alternatives for a Superfund site, the EPA establishes RAOs -
specific goals and objectives to protect human health and the environment. RAOs address
contaminated media, exposure pathways and risks posed by the Site. RAOs may also include
reference to PRCs, which are based on applicable or relevant and appropriate requirements
(ARARs) such as promulgated chemical-specific standards, where available or other information
and standards, such as to-be-considered (TBC) guidance, and site-specific risk-based levels.

PRGs may be refined throughout the Rl/FS as more information becomes available and are
identified as final remediation goals or cleanup levels in the ROD.

The following RAOs have been identified for OU3:

• Prevent exposure of humans to groundwater contaminated with COC concentrations
above federal or more stringent state primary drinking water standards (i.e., MCLs) and
health-based cleanup levels in the absence of a MCL for a particular COC.

• Restore groundwater to its beneficial use as a potential drinking water source by reducing
groundwater COC concentrations to meet federal or more stringent state primary drinking
water standards (i .e., MCLs) or health-based cleanup levels in the absence of a MCL for a
particular COC.

Table 3: Cleanup Levels for Groundwater

Groundwater COC

Cleanup Levels (jig/L)

Basis

Cobalt

hazard quotient level, residential,
hazard quotient = 1

Iron

20,256

Manganese

4,051

Molybdenum

145

Strontium

17,362

2-Methylnaphthalene

116

4-Chloroanilinc

0.4

cancer risk level, residential. 1 x 10~6

Chromium (including Cr+6)

100*

MCLs

Arsenic

1,4-Dichlorobenzene

Notes:

* = The federal primary drinking water standard (MCL) at 40 CFR 141.62 for total chromium is 0.1 mg/L or 100
ppb. This regulation assumes that a measurement of total chromium is 100% hcxavalent chromium, the more
toxic form. See httos://www.eDa.gov/sdwa/chromium~drinking-water.

Source: Final Feasibility Study Report for OU1. OU2. and OU3, US Finishing/Cone Mills, Greenville. Greenville
County. South Carolina. Versar. July 15, 2020.

mg/L = milligrams per liter
ppb = parts per billion

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9.0 Description of Alternatives

Section 12 l(b)( 1) of CERCLA, 42 U.S.C. § 9621 (b)( 1), mandates that remedial actions must be
protective of human health and the environment, be cost effective, comply with ARARs, and
utilize permanent solutions and alternative treatment technologies and resource recovery
alternatives to the maximum extent practicable. Section 12 l(b)( 1) of CERCLA also establishes a
preference for remedial actions that employ, as a principal element, treatment to reduce
permanently and significantly the volume, toxicity or mobility of the hazardous substances,
pollutants and contaminants at a site. Section 121(d)(2) of CERCLA, 42 U.S.C. § 9621(d),
further specifies that a remedial action must attain a level or standard of control of the hazardous
substances, pollutants and contaminants that at least attains ARARs under federal and more
stringent environmental state laws, unless a waiver can be justified pursuant to Section 121(d)(4)
of CERCLA, 42 U.S.C. § 9621(d)(4).

The 2020 Sitewide FS Report evaluated four remedial action alternatives for groundwater:

• Alternative GW1: No Action.

• Alternative GW2: In-Situ Chemical Reduction (1SCR) and Institutional Controls

• Alternative GW3: In-Situ Enhanced Bioremediation (1SEB) and Institutional Controls

• Alternative GW4: In-Situ Chemical Reduction, In-Situ Enhanced Bioremediation and
Institutional Controls

Detailed descriptions of the remedial alternatives presented in the Sitewide FS Report
(July 2020) are summarized below.

• Capital costs - expenditures required to construct a remedial alternative.

• O&M costs - the post-remedy construction costs necessary to ensure or verify the
continued effectiveness of a remedial alternative. They are estimated on an annual basis.

• Indirect costs - these project and construction management costs are for the management
of the remedial action as well as costs associated with institutional controls.

• Present value - this value represents the amount of money that, if invested in the current
year, would be sufficient to cover all costs associated with a project over time, calculated
using a discount rate of 7% and a 30-year time interval.

• Construction time - the time required to construct and implement the remedial
alternative. It does not include the time required to design the remedy, negotiate the
performance of the remedy with responsible parties, or procure contracts for design
and construction.

9.1 Alternative GW1: No Action

Estimated Capital Cost: $0

30-Year Net Present Worth of Annual O&M Costs: $94,000

Indirect Costs: $0

Net Present Value: $0

Estimated Construction Timeframe: 0 years

Estimated Time to Achieve RAOs: RAOs would not be met

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The "no action" alternative must be evaluated under the NCP as a baseline against which all
other alternatives are compared. Under this alternative, no remedial actions would take place.
There are no capital costs associated with Alternative 1, though the comparative analysis
includes a cost estimate for five-year reviews.

9.2 Alternative GW2: In-Situ Chemical Reduction and Institutional Controls

Estimated Capital Cost: $7,483,750

30-Year Net Present Worth of Annual O&M Costs: $844,000
Net Present Value: $8,282,750
Estimated Construction Timeframe: 4 months
Estimated Time to Achieve RAOs: 2 years

Alternative GW2 consists of in-situ treatment using I SCR. and institutional controls. A chemical
reductant solution would be used to remediate the areas with the highest hexavalent chromium
concentrations. The reductant solution, injected into the groundwater via underground injection
wells, would reduce and immobilize hexavalent chromium to the less-toxic trivalent chromium.
Proposed injection locations for the saprolite aquifer (Figure 2) and the bedrock aquifer (Figure 3)
were developed to inform remedial technology review and selection. Groundwater monitoring
would assess the effectiveness of reagent injections and the reduction of hexavalent chromium
and other COCs that would not be directly treated. Institutional controls would be implemented
to prohibit use of groundwater and to prohibit installation of new water supply wells within the
plume area until cleanup goals are achieved.

9.3 Alternative GW3: In-Situ Enhanced Bioreniediation and Institutional Controls

Estimated Capital Cost: $4,262,500

30-Year Net Present Worth of Annual O&M Costs: $844,000
Net Present Value: $5,106,500
Estimated Construction Timeframe: 3 months
Estimated Time to Achieve RAOs: 2 years

Alternative GW3 consists of treating the plume using ISEB and institutional controls. An
electron donor solution would be injected via underground injection wells into the groundwater
in the areas with the highest hexavalent chromium concentrations. The proper application of
ISEB would reduce and immobilize hexavalent chromium to the less-toxic trivalent chromium.
Proposed injection locations for the saprolite aquifer (Figure 2) and the bedrock aquifer (Figure 3)
were developed to inform remedial technology review and selection. Groundwater monitoring
would be implemented to assess the effectiveness of reagent injections and the reduction of
hexavalent chromium and other COCs that would not be directly treated. Institutional controls
would be implemented to prohibit use of groundwater and to prohibit installation of new water
supply wells within the plume area until cleanup goals are achieved.

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9.4	Alternative GW4: In-Situ Chemical Reduction, In-Situ Enhanced
Bioreniediation and Institutional Controls

Estimated Capital Cost: $9,535,000

30-Year Net Present Worth of Annual O&M Costs: $844,000
Net Present Value: $10,379,000
Estimated Construction Timeframe: 3 months
Estimated Time to Achieve RAOs: 2 years

Alternative GW4 consists of treating the plume using a combination of I SCR, ISEB and
institutional controls. A chemical reductant solution along with an electron donor solution would
be injected into the groundwater via underground injection wells in the areas with the highest
hexavalent chromium concentrations. The use of the two technologies, combined with the use of
the latest advancements in I SCR. and ISEB reagents, would simplify implementation by reducing
the overall injection volume. This alternative could also use a reagent to reduce arsenic
concentrations by co-precipitation. The proper application of I SCR and ISEB would reduce and
immobilize hexavalent chromium to the less-toxic trivalent chromium. The details of these
complex geochemical processes will be resolved in the Pre-Design Investigation and Remedial
Design. Proposed injection locations for the saprolite zone of the aquifer (Figure 2) and the
bedrock portion of the aquifer (Figure 3) were developed to inform remedial technology review
and selection but will be finalized as part of the remedial design. Groundwater monitoring would
be implemented to assess the effectiveness of reagent injections and the reduction of hexavalent
chromium and other COCs that would not be treated and to determine whether to optimize the
remedy such as modifying injection locations and frequency. Institutional controls, to include
proprietary controls in the form of restrictive covenants, would be implemented to prohibit use of
groundwater and to prohibit installation of new water supply wells within the plume area until
cleanup goals are achieved.

9.5	Common Elements and Distinguishing Features of Each Alternative

Alternatives GW2, GW3 and GW4 all involve injections into the saprolite and bedrock aquifers
to administer reagents to treat groundwater contamination and implementation of institutional
controls to restrict groundwater use and to prevent well installation in the groundwater plume.
The alternatives differ regarding the reagents to be injected. Alternatives GW2, GW3, and GW4
would all require long-term monitoring and maintenance, as well as five-year reviews, until OU3
groundwater is restored to beneficial use. For all three alternatives, groundwater monitoring
would inform progress towards achieving cleanup goals, whether optimization of injections is
needed, as well as any changes to institutional controls resulting from groundwater cleanup and
restoration of groundwater quality.

10.0 Comparative Analysis of Alternatives

In selecting a remedy, the EPA considered the factors set out in Section 121 of CERCLA, 42
U.S.C.§ 9621, by conducting a detailed analysis of the viable remedial response measures
pursuant to the NCP, 40 CFR §300.430(e)(9), and EPA Office of Solid Waste and Emergency
Response (OSWER) Directive 9355.3-01. The detailed analysis consisted of an assessment of
each of the individual response measures per remedy component against each of nine evaluation
criteria and a comparative analysis focusing on the relative performance of each response

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measure against the criteria. This section of the ROD compares the relative performance of
Alternatives GW1, GW2, GW3, and GW4 against the nine criteria, noting how each compare to
the other options under consideration.

THRESHOLD CRITERIA - The first two criteria are known as "threshold criteria" because
they are the minimum requirements that each response measure must meet in order to be eligible
for selection as a remedy.

10.1 Overall Protection of Human Health and the Environment

Overall protection of human health and the environment addresses whether each alternative
provides adequate protection of human health and the environment and describes how risks
posed through exposure pathway are eliminated, reduced, or controlled through treatment,
engineering controls, and/or institutional controls.

During every FS, a "no action" alternative is developed as a baseline for comparative analysis
purposes. The current condition of OU3 groundwater represents a potentially unacceptable risk
and does not meet the RAOs. Without engineering controls and/or institutional controls, there is
a potential for exposure to hexavalent chromium and other COCs for current and future site
users. Therefore, Alternative GW1 ('No Action) does not meet the threshold criteria and will not
be assessed further in these comparative analyses.

Alternatives GW2, GW3 and GW4 would be protective of human health and the environment.
Restricting the use of groundwater would eliminate potential risks to human health from
exposure to contaminated groundwater. I SCR. under Alternatives GW2 and GW4 and ISEB by
carbon substrate injection under Alternatives GW3 and GW4 would eliminate the highest
concentrations of hexavalent chromium in groundwater, facilitating attenuation in the remainder
of the groundwater plume. The use of monitoring would protect human health and the
environment by assisting in predicting when remediation will reach cleanup levels and whether
optimization of the injections is needed. This will be further quantified by the development of a
Remedial Management Plan as part of the remedial design. That document will identify and
approximately quantify the expected timeframe for successful remedial action and identify
criteria that would trigger the need for additional treatments.

10.2 Compliance with ARARs

Section 121(d) of CERCLA and NCP §300.430(f)(l)(ii)(B) require that remedial actions at
CERCLA sites attain legally applicable or relevant and appropriate federal and more stringent
state environmental requirements, standards, criteria, and limitations that are collectively referred
to as "ARARs", unless such ARARs are waived under CERCLA section 121(d)(4). ARARs do
not include occupational safety or worker protection requirements. Compliance with
Occupational Safety and Health Administration (OSHA) standards is required separately by
40 CFR §300.150.

Alternatives GW2, GW3 and GW4 would comply with the potential location-specific and action-
specific ARARs identified in the 2020 Sitewide FS Report and summarized in preceding sections
of this Proposed Plan. While outer portions of the plume would not be treated in the proposed
injection strategies, the reduction in the higher concentration areas of the plume would allow

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natural attenuation to treat the remaining plume more effectively. Chemical-specific ARARs,
specifically MCLs, would eventually be achieved in the groundwater plume with any of these
three alternatives, although restoration timeframes will vary.

BALANCING CRITERIA - The next five criteria, criteria 3 through 7, are known as "primary
balancing criteria". These criteria are factors by which tradeoffs between response measures are
assessed so that the best options will be chosen, given site-specific data and conditions.

10.3 Long-Term Effectiveness and Permanence

Long-term effectiveness and permanence refer to expected residual risk and the ability of a
remedy to maintain reliable protection of human health and the environment over time, once
cleanup levels have been met. This criterion includes the consideration of residual risk that will
remain on site after remediation and the adequacy and reliability of controls.

Alternatives GW2, GW3 and GW4 would provide long-term effectiveness and permanence.
Elimination of the highest hexavalent chromium concentrations by I SCR, ISEB or both should
enhance the attenuation processes and shorten the time to achieve cleanup goals. Institutional
controls would effectively address the human health risk until treatment and chemical processes
reduce the remaining hexavalent chromium and other COC concentrations to cleanup levels.
Hexavalent chromium reduction to trivalent chromium forms an immobile precipitate. The
reversal reaction will not occur at the natural pH of the groundwater, thereby providing long-
term effectiveness and permanence. Reduction of hexavalent chromium should enhance the
natural attenuation processes for all COCs and shorten the time to cleanup goals.

10.4 Reduction of Toxicity, Mobility and Volume

Reduction of toxicity, mobility, or volume through treatment refers to the anticipated
performance of the treatment technologies that may be included as part of a remedy and which
permanently and significantly reduces the toxicity, mobility, or volume of the hazardous
substances, pollutants, or contaminants as a principal element.

There are no principal threat wastes in OU3. However, Alternative GW2, Alternative GW3 and
Alternative GW4 will all reduce the toxicity, mobility and volume of hexavalent chromium, as
well as other COCs, in groundwater through in-situ treatment and reduce the total plume area
until cleanup goals are achieved. While outer portions of the plume would not be treated, the
reduction in the higher concentration areas of the plume would allow attenuation processes to
reduce levels in the remaining plume more effectively.

In addition. Alternative GW4 could also reduce dissolved arsenic concentrations with the
injection of the reagent AquaZVI. Arsenic is co-precipitated by ZVI by forming complexes with
ZVI corrosion products.

10.5 Short-Term Effectiveness

Short-term effectiveness addresses the period of time needed to implement the remedy and any
adverse impacts that may be posed to workers, the community, and the environment during
construction, and operation of the remedy until cleanup levels are achieved.

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Exposure to contaminated groundwater during on-site injection or sampling activities could
present a short-term risk to workers for Alternative GW2, Alternative GW3 and Alternative
GW4. Exposure to calcium poly sulfide could be a short-term risk for Alternative GW2.

Exposure to pH buffer could be a short-term risk for Alternative GW3 and Alternative GW4.
However, the potential for exposure would be minimized by wearing appropriate personal
protective equipment and compliance with the Occupational Safety and Hazard Administration
regulations and site-specific health and safety procedures.

Implementation of Alternative GW2, Alternative GW3 and Alternative GW4 would not result in
short-term adverse impact on the community. The short-term risk of mobilization of redox-
sensitive and exchangeable sorbed metals would be monitored under Alternative GW2 and
Alternative GW4, as arsenic and manganese are more soluble when reduced. In addition,
institutional controls will be implemented to prohibit groundwater use until cleanup levels
are achieved.

10.6 Iinplementability

Implementability addresses the technical and administrative feasibility of a remedy from design
through construction and operation. Factors such as availability of services and materials,
administrative feasibility, and coordination with other governmental entities are also considered.

Alternative GW2, Alternative GW3, and Alternative GW4 are all implementable at the Site
using proven in-situ treatment technologies with readily available equipment and injection
reagents. Alternative GW3 and Alternative GW4 are both easier to implement due to reduced
injection volumes compared to Alternative GW2. If property ownership changed, appropriate
provisions would be incorporated into the property transfer documents to ensure continued
implementation of institutional controls.

10.7 Cost

Cost estimates, including capital costs and long-term operating costs, were prepared for each
remedial alternative. They are summarized below.

Table 4: Remedial Alternative Costs

Alternative GWl

Alternative GW2

Alternative GW3

Alternative GW4

Construction cost (capital):

$8,282,750

$4,262,500

$9,535,000

30-year net present worth
of O&M activities:

$94,000

$844,000

Construction time:

0 months

4 months

3 months

Time to achieve RAOs:

not applicable

2 vcars

MODIFYING CRITERIA - The final two evaluation criteria, criteria 8 and 9, are called
"modifying criteria" because new information or comments from the state or the community on
the Proposed Plan may modify the preferred response measure or cause another response
measure to be considered.

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10.8 State Acceptance

This criterion indicates whether, based on its review of the RI/FS reports and the Proposed Plan,
the state supports, opposes, and/or has identified any reservations with the selected response
measure.

The state has reviewed the public comments received and submitted a letter of concurrence on
September 21, 2023.(Appendix B).

10.9 Community Acceptance

This criterion summarizes the public's general response to the response measures described in
the Site's Proposed Plan and the RI/FS reports. This assessment includes determining which of
the response measures the community supports, opposes, and/or has reservations about.

The public comments received during the comment period were generally supportive of the
Preferred Alternative. A letter of support was submitted by the Friends of the Reedy River.

11.0 Principal Threat Wastes

The NCP establishes an expectation that the EPA will use treatment to address the principal
threats posed by a site wherever practicable (NCP Section 300.430(a)(l)(iii)(A)). The "principal
threat" concept is applied to the characterization of "source materials" at a Superfund site. A
source material is material that includes or contains hazardous substances, pollutants, or
contaminants that act as a reservoir for migration of contamination to groundwater, surface water
or air, or acts as a source for direct exposure. Contaminated groundwater generally is not
considered to be a source material. There are no principal threat wastes known to be present in
OU3 groundwater.

12.0 Selected Remedy

Based on the above information in the Site's Administrative Record file, the EPA's Selected
Remedy for OU3 at the Site is Alternative GW4: I SCR, ISEB, and Institutional Controls.

The estimated capital cost is $9,535,000.

The estimated cost for the remedy is $10,379,000.

Based on currently available information, the EPA believes Alternative GW4 meets the threshold
criteria and provides the best balance of tradeoffs among the other alternatives with respect to the
balancing criteria and modifying criteria. The EPA expects the Selected Remedy to satisfy the
following statutory requirements of CERCLA Section 121(b), 42 U.S.C. §9621(b): 1) be
protective of human health and the environment; 2) comply with ARARs (or justify a waiver);
(3) be cost effective; (4) utilize permanent solutions and alternative treatment technologies or
resource recovery technologies to the maximum extent practicable; and (5) satisfy the statutory
preference for treatment as a principal element to the extent practicable.

The EPA recommends this alternative because it provides the highest-level reduction of toxicity,
mobility and volume of contamination in the shortest timeframe to achieve RAOs. Alternative

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GW4 would be easier to implement than Alternative GW2 due to reduced injection volumes.
Alternative GW4 would also reduce dissolved arsenic concentrations by incorporating the
injection of a reagent and provides maximum flexibility regarding choosing the most effective
reagent and technologies to optimize groundwater cleanup. The EPA believes the Selected
Remedy will be protective of human health and the environment.

12.1 Summary of the Rationale for the Selected Remedy

Based on consideration of the results of site investigations, CERCLA requirements, the detailed
analysis of the response measures, and public comments, the EPA has determined that
Alternative GW4: I SCR, ISEB and Institutional Controls is the appropriate remedy for OU3
contamination because it best satisfies the requirements of Section 121 of CERCL A, 42 U.S.C. §
9621, and the NCP's nine evaluation criteria for remedial alternatives, 40 CFR § 300.430(e)(9).
Of those alternatives that are protective of human health and the environment and comply with
ARARs, the EPA has determined that the Selected Remedy provides the best balance of
tradeoffs in terms of the five balancing criteria, while also considering the statutory preference
for treatment as a principal element, bias against off-site treatment and disposal, and considering
state and community acceptance.

The EPA and the SCDHEC concur that the selected remedy will satisfy the following statutory
requirements of CERCLA Section 121(b), 42 U.S.C. § 9621(b): 1).

12.2 Detailed Description of the Selected Remedy

Alternative GW4 consists of the following remedial activities:

• In-situ treatment of highest hexavalent chromium groundwater concentrations using a
combination of I SCR and ISEB reagents via underground injection wells.

• Groundwater monitoring to assess efficacy of treatment and inform additional remedial
activities such as optimization of the injections, as needed.

• Implementation of institutional controls to prohibit groundwater use and to prevent
installation of wells near or in groundwater contamination until cleanup levels are met.

12.3 Cost Estimate for the Selected Remedy

The information in the cost estimate summary table below is based on the best available
information regarding the anticipated scope of the remedial alternative. Changes in the cost
elements are likely to occur as a result of new information and data collected during the
engineering design of the remedial alternative. Major changes may be documented in the form of
a memorandum, in the Site's Administrative Record, an Explanation of Significant Differences,
or a ROD Amendment.

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Table 5: Estimated Costs for Selected Remedy

Activity

Alternative GW4

Estimated capital cost:

$9,535,000

Estimated O&M costs (30-year
net present worth):

$844,000

Estimated time to achieve RAOs:

2 years

12.4 Estimated Outcomes of Selected Remedy

The Selected Remedy will protect human health and the environment by restoring contaminated
groundwater to achieve drinking water levels and by eliminating, reducing, or controlling risks at
OU3 through in-situ injection of reagents and institutional controls. While not currently used as a
drinking water source, the aquifer underlying the Site is designated as a potential drinking water
source and may be used as such in the future.

Implementation of the Selected Remedy and achievement of the final cleanup levels will
accomplish the RAOs for OU3. The table below identifies the final cleanup levels.

Table 6: Cleanup Levels for Groundwater

Groundwater COC

Concentration (jxg/L)

Basis

Cobalt

hazard quotient level, residential,
hazard quotient = 1

Iron

20,256

Manganese

4,051

Molybdenum

145

Strontium

17,362

2-Methylnaphthalene

116

4-Chloroanilinc

0.4

cancer risk level, residential. 1 x 10~6

Chromium (including Cr+6)

100*

MCLs

Arsenic

1,4-Dichlorobenzene

Notes:

* = The federal primary drinking water standard maximum contaminant levels (MCL) at 40 CFR 141.62 for total
chromium is 0.1 mg/L or 100 ppb. This regulation assumes that a measurement of total chromium is 100%
hexavalent chromium, the more toxic form. See httds://www.eDa. eov/sdwa/chromium-drinking-water.

Source: Final Feasibility Study Report for OU1. OU2. and OU3, US Finishing/Cone Mills, Greenville. Greenville
County, South Carolina. Versar. My 15, 2020.

13.0 Statutory Determinations

As noted previously. Section 12 l(b)( 1) of CERCLA, 42 U.S.C. § 9621 (b)( 1) mandates that
remedial actions must be protective of human health and the environment, cost effective, and
utilize permanent solutions and alternative treatment technologies or resource recovery
technologies to the maximum extent practicable. Section 12 l(b)( 1) of CERCLA, 42 U.S.C. §

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9621 (b)( 1) also establishes a preference for remedial actions that employ treatment to
permanently and significantly reduce the volume, toxicity, or mobility of the hazardous
substances, pollutants, or contaminants at a site. Section 121(d) of CERCLA, 42 U.S.C. §
9621(d) further specifies that a remedial action must attain a degree of cleanup that satisfies
ARARs under federal and more stringent state environmental laws, unless a waiver can be
justified pursuant to Section 121(d)(4) of CERCLA, 42 U.S.C. § 9621(d)(4).

13.1	Protection of Human Health and the Environment

The EPA believes the Selected Remedy meets the threshold criteria and provides the best
balance of tradeoffs among the other alternatives with respect to the balancing and modifying
criteria. The EPA expects the Preferred Alternative to satisfy the following statutory
requirements of CERCLA 121(b) and (d): (1) be protective of human health and the
environment; (2) comply with ARARs (or justify a waiver); (3) be cost effective; (4) utilize
permanent solutions and alternative treatment technologies or resource recovery technologies to
the maximum extent practicable; and (5) satisfy the statutory preference for treatment as a
principal element to the extent practicable.

The EP A selected the Selected Remedy over the other alternatives because of its overall potential
effectiveness and efficiency in addressing site contamination. The proposed remedy will provide
for permanent long-term risk reduction through in-situ treatment of groundwater contamination
that could present unacceptable risk to human health from direct exposure and to restore
groundwater to its beneficial use as a potential drinking water source. The EPA believes the
Selected Remedy will be protective of human health and the environment.

13.2	Compliance with ARARs

Section 121(d) of CERCLA, as amended, specifies, in part, that remedial actions for cleanup of
hazardous substances must comply with requirements and standards under federal or more
stringent state environmental laws and regulations that are applicable or relevant and appropriate
(i.e., ARARs) to the hazardous substances or particular circumstances at a site or justify invoking
a waiver under Section 121(d)(4) (see also 40 C.F.R. §§ 300.430(f)(l)(ii)(B) and (C), and 40
C.F.R. §§ 300.430(f)(5)(ii)(B) and (C)). ARARs include only promulgated federal and state
environmental or facility siting laws/regulations. They do not include occupational safety or
worker protection requirements. Compliance with OSHA standards is required by 40 C.F.R. §
300.150. Therefore, the CERCLA requirement for compliance with or waiver of ARARs does
not apply to OSHA standards.

Under CERCLA Section 12 l(e)( 1), federal, state, or local permits are not required for the portion
of any removal or remedial action conducted entirely on site, as defined in 40 C.F.R. § 300.5 (see
also 40 C.F.R. §§ 300.400(e)(1) & (2)). Also, CERCLA actions must only comply with the
"substantive requirements," not the administrative requirements of a regulation or law.
Administrative requirements include permit applications, reporting, recordkeeping, and
consultation with administrative bodies. Although consultation with state and federal agencies
responsible for issuing permits is not required, it is recommended for determining compliance with
certain requirements such as those requirements typically identified as location-specific ARARs.

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In accordance with 40 C.F.R. § 300.430(f)(5)(ii)(B), this ROD includes ARARs that the remedy
is expected to attain that were identified by the EPA and the State of South Carolina. Tables A-3,
A-4, and A-5 list, respectively, the location-specific, action-specific and chemical-specific
ARARs/TBCs for the selected remedial action. A waiver is not being invoked for any of the
identified ARARs.

13.3 Cost Effectiveness

The EPA has determined that the Selected Remedy is cost effective, and that the overall
protectiveness of the remedy is proportional to the overall cost. As specified in 40 CFR §
300.430(f)(l)(ii)(D), the cost effectiveness of the Selected Remedy was assessed by comparing
the protectiveness of human health and the environment in relation to three balancing criteria
(long-term effectiveness and permanence, reduction in toxicity, mobility, or volume, and short-
term effectiveness), with the other alternatives considered.

While more than one remedial alternative can be considered cost effective, CERCLA does not
mandate the selection of the most cost-effective or least-expensive remedy.

13.4 Use of Permanent Solutions and Alternative Treatment Technologies to the

Maximum Extent Practicable

The EPA has determined that the Selected Remedy represents the maximum extent to which
permanent solutions can be used in a practicable manner at the Site. As described earlier, in-situ
treatment of contaminated groundwater will achieve the RAOs and thereby permanently prevent
any unacceptable risk to human health. A combination of 1SEB and I SCR will treat contaminants
in groundwater on site. No resource recovery technologies are used.

The Selected Remedy does not present short-term risks different from the other treatment
alternatives. There are no special implementability issues that set the Selected Remedy apart
from any of the other alternatives evaluated.

13.5 Preference for Treatment as a Principal Element

No principal threat wastes are present in OU3 groundwater. Injection of reagents will address
contaminant concentrations exceeding MCLs or respective health risk-based drinking water
levels through ISEB and I SCR. The use of these treatment technologies will reduce the toxicity,
mobility and volume of hexavalent chromium in site groundwater. The reduction of areas of
groundwater exhibiting higher concentrations of contamination will facilitate natural attenuation
processes in effectively reducing the residual contamination in remaining areas of the plume in
view of attaining cleanup levels throughout the plume.

13.6 Five-Year Review Requirements

Because hazardous substances will remain at the Site above levels that allow for unlimited
exposure and unrestricted use, the EPA will review the remedial action no less than every five
years, per CERCLA Section 121(c) and the NCP at 40 CFR 300.430(f)(4)(ii) until the levels of
COCs allow for unrestricted use of soil and groundwater with unlimited exposure to these media.
If results of the five-year reviews show that remedy integrity is compromised and protection of

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human health and the environment is insufficient, then the EPA and the SCDHEC will evaluate
more remedial actions.

14.0 Documentation of Significant Changes from Preferred
Alternative of Proposed Plan

Pursuant to CERCLA Section 1 17(b) and NCP §300.430(f)(3)(ii), the ROD must document any
significant changes made to the Preferred Alternative discussed in the Proposed Plan.

The EPA reviewed all written and verbal comments submitted during the public comment
period. There are no other significant changes to the remedy, as originally identified in the
Proposed Plan.

15.0 References

EPA, 2022. Proposed Plan. US Finishing/Cone Mills Superfund Site, Operable Unit 3 (OU3),
Greenville County, Greenville County, Greenville, South Carolina.

Versar. 2020. Final Feasibility Study Report OU1, OU2, OU3. US Finishing/Cone Mills,
Greenville, Greenville County, South Carolina, dated July 15, 2020. Prepared for
U.S. Environmental Protection Agency, Remedial Action Contract II Lite, EPA Region 4.

Versar. 2018. Final Human Health Risk Assessment, OU3, US Finishing/Cone Mills, Greenville,
Greenville County, South Carolina. Prepared for U.S. Environmental Protection Agency,
Remedial Action Contract II Lite, EPA Region 4.

Versar. 2020. Final Remedial Investigation Report, OU3. US Finishing/Cone Mills, Greenville,
Greenville County, South Carolina. Prepared for U.S. Environmental Protection Agency,
Remedial Action Contract II Lite, EPA Region 4.

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PART 3: RESPONSIVENESS SUMMARY

1.0	Public Review Process

1.1	Introduction

This Responsiveness Summary provides a summary of comments and concerns received during
the public comment period related to the Proposed Plan for OU3 at the Site. It also provides the
EPA's responses to those comments and concerns.

A Responsiveness Summary serves two functions. First, it provides the deci si on maker with
information about the views of the public, government agencies, and potentially responsible
parties regarding the proposed remedial action and other alternatives. Second, it documents the
way in which public comments have been considered during the decision-making process and
provides answers to significant comments.

Public involvement in the review of Proposed Plans is stipulated in CERCLA Section 1 17(a) and
Sections 300.430(f)(3)(i)(F) and 300.430(f)(5)(iii)(B) of the NCP. These regulations provide for
active solicitation of public comment.

This Responsiveness Summary addresses all public comments received. The Responsiveness
Summary was prepared following guidance provided by the EPA in the EPA's 1992 Community
Relations in Superfund: A Handbook and the EPA's 1988 Community Relations during
Enforcement Activities and Development of the Administrative Record. The comments
presented in this document have been considered in the EPA's decision in the selection of a
remedy for OU3 at the Site.

The text of this Responsiveness Summary explains the public review process and how the EPA
responded to public comments. Appendix C provides the Comment and Response Index, which
contains summaries of every comment received during the public comment period and the
EPA's responses.

1.2	Public Review Process

The EPA relies on public input to make sure community concerns are considered when selecting
an effective remedy for each Superfund site. The EPA released the Proposed Plan for OU3 for
public comment on June 21, 2023.

The complete Administrative Record file, which contains the Rl/FS reports and risk assessments
on which the Selected Remedy is based, is available at the locations listed below.

Online at https://semspub.epa.gov/src/collections/04/AR/SCD003358744.

The Site's local information repository is Hughes Main Library, located at 25 Heritage Green
Place in Greenville, South Carolina. It is open and provides computer access for the community
to access the Site's Administrative Record file online.

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1.3	Public Comment Period, Public Meeting, and Availability Sessions

The goal of the public comment period is to gather information about the views of the public
regarding both the remedial alternatives and general concerns about the Site. A notice of the start
of the public comment period, the public meeting date, the preferred remedy, contact
information, and the availability of above-referenced documents was provided in a fact sheet
distributed to the public on June 21, 2023, and published in the Greenville News on the
same day.

The public comment period for the OU3 Proposed Plan started on June 21, 2023. It continued
until August 11, 2023, for a total of 51 days.

1.4	Receipt and Identification of Comments

Public comments on the Proposed Plan and EPA Region 4 responses were received as written
comments submitted to EPA Region 4 via email and verbally during the Q& A session at the
public meeting presenting the Proposed Plan. The comments from the July 11, 2023 public
meeting are summarized in Appendix B.

EPA received a letter of support for the preferred alternative from The Friends of The Reedy River dated

August 10, 2023.

1.5	Locating Responses to Comments in the Comment and Response Index

The Comment and Response Index (Appendix B) contains a complete listing of all comments
and responses from the EPA.

2.0 Technical and Legal Issues

No technical or legal issues were raised.

3.0 References

EPA, 1988. Community Relations During Enforcement Activities and Development of the
Administrative Record. Office of Solid Waste and Emergency Response, U.S. Environmental
Protection Agency, Washington, D C. OSWER Directive 9836.0-01 A. November 1988.
EPA, 1992. Community Relations in Superfund: A Handbook. Office of Emergency and
Remedial Response, U.S. Environmental Protection Agency, Washington, D C. OSWER
Directive 9230.0-03C. EPA 540-R-92-009. January 1992.

37

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September 2023

TABLES

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September 2023

Table A-l: Risk Summary of Reasonable Maximum Exposures to Groundwater Contaminants in the Saprolite Lithologv3

Table 10.1 RME
Risk Summary

Reasonable Maximum Exposure: Saprolite Groundwater
US Finishing/Cone Mills
Greenville, Greenville County, South Carolina

Scenario Timeframe:

Futu re

Receptor Population:

Resident

Receptor:

Child - Adult

Receptor Location:

Saprolite Groundwater



Exposure
Medium

Exposure
Point



Carcinogenic Risk

Non-Ca reinogen ic-Haza rd Quotient

Med iu m

Chemical of Concern

Ingestion

Dermal

Inhalation

Exposure
Routes Total

Primary Target
Organ(s)

Ingestion

Dermal

Inhalation

Exposure
Routes Total

Groundwater

Saprolite

Tap

Arsenic

6E-05

NA

NA

6E-05

Vascular

0.4

NA

NA

0.4



Groundwater



Chromium, Hexavalent

1E-01

NA

NA

1E-01

None reported

204

NA

NA

204







Coba It

NA

NA

NA

NA

Thyroid

0.7

NA

NA

0.7







Iron

NA

NA

NA

NA

Gl Tract

0.1

NA

NA

0.1







Manganese

NA

NA

NA

NA

CNS

0.16

NA

NA

0.2







Molybdenum

NA

NA

NA

NA

Incr uric acid

0.2

NA

NA

0.2







2-Methyl naphthalene

NA

NA

NA

NA

Lung

0.1

NA

NA

0.1







4-Chloroaniline

6E-06

NA

NA

6E-06

Spleen

0.02

NA

NA

0.02







1,4- Dich lo ro be n ze n e

9E-07

NA

2E-07

1E-06

Liver

0.006

NA

0.00006

0.006







Chemical Total

1E-01

NA

5E-07

1E-01



206

NA

0.06

206





Exposure Point Total

1E-01



206



Exposure Medium Total

1E-01



206

Receptor Total

1E-01



206

Total Risk Across All Media = | 1E-Q1

Total Hazard Across All Media = | 206

Total Kidney HI Across All Media =
TotalThyroid HIAcross All Media =
Total Decreased Body Weigt HIAcross All Media =

0.1

0.7

0.06

3 Source: Versar. 2018. Final Human Health Risk Assessment, OU3, US Finishing/Cone Mills, Greenville, Greenville County, South Carolina. Prepared for U.S. Environmental
Protection Agency, Remedial Action Contract II Lite, EPA Region 4.

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September 2023

Table A-2: Risk Summary of Reasonable Maximum Exposures to Groundwater Contaminants in the Bedrock Lithology4

Table 10.2 RME
Risk Summary
Reasonable Maximum Exposure: Bedrock Groundwater
US Finishing/Cone Mills

		Greenville, Greenville County, South Carolina

See n a r io Timefra me:

Future

Receptor Population:

Resident

Receptor:

Child - Adult

Receptor Location:

Bedrock Groundwater

Medium

Exposure
Med iu m

Exposure
Point

Chemical of Concern

Carcinogenic Risk

Non-Carcinogenic-Hazard Quotient

Ingestion

Dermal

Inhalation

Exposure
Routes Total

Primary Target
Organ(s)

Ingestion

Dermal

Inhalation

Exposure
Routes Total

Groundwater

Bedrock
Groundwater

Tap

Chromium, Hexavalent

4E-02

NA

NA

4E-02

None reported

64

NA

NA

64

Molybdenum

NA

NA

NA

NA

Incr uric acid

0.8

NA

NA

0.8

Strontium

NA

NA

NA

NA

Bone

0.5

NA

NA

0.5

Chemical Total

4E-02

NA

NA

4E-02



66

NA

0.00001

66

Exposure Point Total

4E-02



66

Exposure Medium Total

4E-02



66

Receptor Total

4E-02



66

Total Risk Across All Media = | 4E-02 |	Total Hazard Across All Media = | 66~

Total Increased Uric Acid HI Across All Media =	0.8

Total Bone HI Across All Media =	0.5

4 Source: Versar. 2018. Final Human Health Risk Assessment, OU3, US Finishing/Cone Mills, Greenville, Greenville County, South Carolina. Prepared for U.S. Environmental
Protection Agency, Remedial Action Contract II Lite, EPA Region 4.

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Table A-3: Location-Specific ARARs/TBC for OU3 at the US Finishing/Cone Mills Superfund Site

Location
Characteristic(s)

Requirements

Prerequisite

Citation(s)

Presence of
Floodplain(s)
designated as such on a

map5

Shall take action to reduce the risk of flood loss, to
minimize the impact of floods on human safety, health
and welfare, and to restore and preserve the natural and
beneficial values served by fkxxiplains.

Federal actions that involve potential
impacts to. or take place within,
floodplain - To Be Considered

NOTE: Federal agencies required to
comply with E.O. 11988 requirements.

Executive Order 11988
Section 1. Floodplain

Management

Shall consider alternatives to avoid, to the extent possible,
adverse effects and incompatible development in the
floodplain. Design or modify its action in order to
minimize potential harm to or within the floodplain

Executive Order 11988

Section 2.(a)(2)
Floodplain Management

Where possible, an agency shall use natural systems,
ecosystem processes, and nature-based approaches when
developing alternatives for consideration.

Federal actions that involve potential
impacts to. or take place within,
floodplain - To Be Considered

NOTE: Federal agencies required to
comply with E.O. 13690 requirements.

Executive Order 13690
Section 2. (c)

Presence of
Floodplain(s)
designated as such on a

map2

The Agency shall design or modify its actions so as to
minimize'' harm to or within the floodplain

Federal actions affecting or affected by
Floodplain as defined in 44 C.F.R. § 9.4
- relevant and appropriate

44 C.F.R. § 9.11(b)(1)
Mitigation

The Agency shall restore and preserve natural and
beneficial floodplain values.

44 C.F.R. § 9.11(b)(3)
Mitigation

The Agency shall minimize:

• Potential harm to lives and the investment at risk
from base flood, or in the case of critical actions .
from the 500-year flood;

44 C.F.R. §9.11(c)(1) and
(3)

Minimization provisions

5 Under 44 CFR § 9.7 Determination of remedial action's location, Paragraph (c) Floodplain determination. One should consult the FEMA Flood Insurance Rate Map (FIRM), the
Flood Boundary Floodway Map (FBFM) and the Flood Insurance Study (FIS) to determine if the Agency's remedial action is within the base floodplain.

6Minimize means to reduce to smallest amount or degree possible. 44 C.F.R. § 9.4 Definitions.

7 See 44 C.F.R. § 9.4 Definitions. Critical action. Critical actions include, but arc not limited to. those which create or extend the useful life of structures or facilities such as those
that produce, use or store highly volatile, flammable, explosive, toxic or water-reactive materials.

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Location
Characteristic(s)

Requirements

Prerequisite

Citation(s)



• Potential adverse impacts that action may have on
floodplain values





ARAR = applicable or relevant and appropriate requirement	CWA = Clean Water Act

CFR = Code of Federal Regulations

EPA = U.S. Environmental Protection Agency

SCDHEC = South Carolina Department of Health and Environmental Control
TBC = to be considered

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Table A-4: Action-Specific ARARs/TBC for OU3 at the US Finishing/Cone Mills Superfund Site

US Finishing/Cone Mills OU3
Record of Decision
September 2023

Action

Requirements

Prerequisite

Citation

General Construction Standards—AH Land-disturbing Activities (i.e., excavation, clearing, grading, etc.)

Managing storm water
runoff from land-
disturbing activities

All erosion and sediment control plans shall include details and
descriptions of temporary and permanent erosion and sediment
control measures and other protective measures shown on the
stormwater and sediment management plan. Procedures in a
stormwater and sediment management plan shall provide that
all sediment and erosion controls arc inspected at least once
every seven calendar days and after any storm even of greater
than 0.5 inches of precipitation during any 24-hour period.

Land disturbing activities related to
residential, commercial, industrial or
institutional land use which are not
specifically exempted or waived by
these regulations - applicable

SCDHEC R. 72-307B.1 -
South Carolina Storm
Water Management and
Sediment Reduction

Regulations



The stormwater management and sediment control plan shall
contain at a minimum the information provided in the following
subsections:

A narrative description of the stormwater management
and sediment control plan to be used during land disturbing
activities.

The location of temporary and permanent vegetative and

structural stormwater management and sediment control
measures.

Activities involving two (2) acres or
less of actual land disturbance which arc
not part of a larger common plan of
development or sale - applicable

SCDHEC R. 72-307H(2)
and (5)(d)



The stormwater management and sediment control plan shall
contain at a minimum the information provided in the following
subsections:

•	A plan for temporary and permanent vegetative and
structural erosion and sediment control measures which
specify the erosion and sediment control measures to be
used during all phases of the land disturbing activity and a
description of their proposed operation;

•	Provisions for stormwater runoff control during the land
disturbing activity and during the life of the facility

meeting the peak discharge rate and velocities
requirements in subsections (e)l. and (e)2. of this section.

Activities involving more than two (2)
acres and less than five (5) acres of
actual land disturbance which arc not
part of a larger common plan of
development or sale - applicable

SCDHEC R. 72-
307I(3)(d) and (e)

Managing fugitive dust
emissions from land
disturbing activities

Emissions of fugitive particulate matter shall be controlled in
such a manner and to the degree that it docs not create an
undesirable level of air pollution.

Activities that will generate fugitive
particulate matter (Statewide) -
applicable

SCDHEC R. 61-62.6
Section 111(A)- Control of
Fugitive Particulate
Matter Statewide

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Action

Requirements

Prerequisite

Citation



Volatile organic compounds shall not be used for dust control
purposes. Oil treatment is also prohibited.



SCDHEC R. 61-62.6
Section lll(D)

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Action

Requirements

Prerequisite

Citation

Monitoring Weil Installation, Operation, and Abandonment

Installation of

Permanent and
Temporary Monitoring
Wells

All monitoring wells shall be drilled, constructed, maintained,
operated, and/or abandoned to ensure that underground
sources of drinking water arc not contaminated.

Construction of permanent and
temporary monitoring wells, as
defined in R. 61 -71B - applicable

SCDHEC R. 61-
71H. lb.

Installation of
Permanent
Conventionally
Installed or Direct Push
Monitoring Wells

Wells shall be grouted from the top of the bentonite seal to
the land surface.

Grout is to be composed of neat cement, a bentonite cement
mixture, or high solids sodium bentonite grout.

Construction of permanent
conventionally installed or direct push
monitoring wells, as defined in R. 61-
71B - applicable

SCDHEC R. 61-

71H.2.a.(l),(2)
[conventionally installed

wells]

SCDHEC R. 61-
71H.3.b.(l),(2) [direct

push wells]



The diameter of the annular space shall be large enough to
allow for forced injection of grout through a trcmic pipe.

All grouting shall be accomplished using forced injection to
emplace the grout. When emplacing the grouting material, the
trcmic pipe shall be lowered to the bottom of the zone to be
grouted. The trcmic pipe shall be kept full continuously from
start to finish of the grouting procedure, with the discharge
end of the trcmic pipe being continuously submerged in the
grout until the zone to be grouted is completely filled.



SCDHEC R. 61-

71H.2.a.(3),(4)
[conventionally installed

wells]

SCDHEC R. 61-
71H.3.b.(3),(4) [direct
push wells]



A cement or aggregate reinforced concrete pad at the ground
surface of appropriate durability and strength, considering the
setting and location of each well, that extends six inches
beyond the borehole diameter and six inches below ground
surface is required. The pad shall be capable of preventing
infiltration between the surface casing and the borehole to the
subsurface.



SCDHEC R. 61-

71H.2.a.(5)

[conventionally installed

wells]

SCDHEC R. 61-

71H.3.b.(5) [directpush

wells]

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Action

Requirements

Prerequisite

Citation

istallation of
Permanent
Conventionally
Installed or Direct Push
Monitoring Wells
(cont'd)

Well Construction and Materials Standards -

(1)	Casing shall be of sufficient strength to withstand normal
forces encountered during and after well installation and be
composed of material so as to minimally affect water quality
analyses.

(2)	Casing shall have a sufficient diameter to provide access for

sampling equipment.

(3)	A properly hydrated bentonite seal with a minimum
thickness of twelve inches directly above the filter pack shall be
used, if the well has a filter pack.

(4)	The monitoring well intake or screen design shall minimize
formational materials from entering the well. The filter pack 17
shall be utilized opposite the well screen as appropriate in so
that parameter analyses will be minimally affected.

(5)	A locking cap or other security devices to prevent damage
and/or vandalism shall be used.

(6)	Monitoring wells completed below grade shall be in a
watertight vault with a well cap to prevent infiltration of
surface water into the well.

Construction of permanent
conventionally installed or direct push
monitoring wells, as defined in R. 61-
71B - applicable

SCDHEC R. 61-

71 H.2.b. [conventionally
installed wells]

SCDHEC R. 61-71H.3.c
[directpush wells]



All monitoring wells shall be properly labeled with an
identification plate immediately upon well completion. The
identification plate shall be constructed of a durable,
weatherproof, rustproof, material. The identification plate
shall be permanently secured to the well casing or enclosure
floor around the casing where it is readily visible and shall
identify: (1) company name and certification number of the
driller who installed the well; (2) date well was completed;
(3) total depth (feet); (4) casing depth (feet); (5) screened
Interval; (6) designator and/or identification number.



R. 61-71H.2.C.

[conventionally installed

wells]

SCDHEC R. 61-71H 3 d

[directpush wells]

Additional
Requirements for
Installation of Direct
Push Monitoring Wells

Direct push wells cannot be installed below a confining layer
unless it can be demonstrated to the satisfaction of the
Department that cross-contamination of the aquifer systems
can be prevented.

Construction of direct push
monitoring wells, as defined in R. 61-
71B - applicable

R. 61-71H.3.a.

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Action

Requirements

Prerequisite

Citation

istallation of

Temporary Monitoring
Wells

Construction and Materials -

(1)	Casing shall be of sufficient strength to withstand normal
forces encountered during and after well installation and be 20
composed of material so as to minimally affect water quality
analyses.

(2)	Casing shall have a sufficient diameter to provide access for
sampling equipment.

(3)	The monitoring well intake or screen design shall minimize
forinational materials from entering the well. The filter pack or
intake shall be utilized opposite the well screen as appropriate
so that parameter analvses will be minimally affected.

Construction of temporary monitoring
wells, as defined in R. 61 -71B -
applicable

SCDHEC R. 61-71H.4.a.



All temporary monitoring wells shall be sealed with a
watertight cap or seal until abandoned. Temporary monitoring
wells shall be maintained such that they arc not a source or
channel of contamination before they arc abandoned.

Operation and maintenance of
temporary monitoring wells, as
defined in R. 61 -71B - applicable

SCDHEC R. 61-

71H.4.b.

Abandonment of
Permanent
Conventionally
Installed Monitoring
Wells

Abandonment shall be by forced injection of grout or pouring
through a treinie pipe starting at the bottom of the well and
proceeding to the surface in one continuous operation. The
well shall be filled with either with neat cement, bentonite-
cement. or 20% high solids sodium bentonite grout, from the
bottom of the well to the land surface.

Abandonment of permanent
conventionally installed monitoring
wells - applicable

SCDHEC R. 61-71H.2.C.

Abandonment of
Permanent Direct Push
Monitoring Wells

(1)	Permanent direct push wells that do not penetrate a
confining layer shall be abandoned by removing all casing from
the subsurface and be grouted by forced injection through a
treinie pipe from the total depth to the land surface, or by forced
injection or pouring of neat cement, bentonitc-ccincnt. or 20%
high solids sodium bentonite grout through a treinie pipe
starting at the bottom of the well and proceeding to the surface.

(2)	Direct push wells that penetrate a confining layer shall be
abandoned by forced injection or pouring of neat cement,
bentonitc-ccincnt. or 20% high solids sodium bentonite grout
through a treinie pipe starting at the bottom of the well and
proceeding to the surface in one continuous operation.

Abandonment of permanent direct
push monitoring wells, as defined in
R.61-71B - applicable

SCDHEC R. 61-71H.2J.

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Action

Requirements

Prerequisite

Citation

Abandonment of
Temporary
Conventionally
Installed or Direct Push
Monitoring Wells

(1)	All temporary monitoring wells shall be abandoned within 5
days of borehole completion.

(2)	A conventionally drilled temporary well shall be abandoned
by forced injection of neat cement, bcntonitc-ccnicnt. or 20%
high solids sodium bentonite grout through a trcmic pipe
starting at the bottom of the well and proceeding to the surface
in one continuous operation.

(3)	A temporary direct push well that docs not penetrate a
confining layer shall be abandoned by forced injection of neat
cement, bentonitc-ccmcnt. or 20% high solids sodium bentonite
grout through a trcmic pipe after the sampling device has been

removed.

(4)	A temporary direct push well that penetrates a confining
layer shall be abandoned by forced injection of neat cement,
bentonitc-ccmcnt. or 20% high solids sodium bentonite grout
through the sampling device as the sampling device is removed
from the sub-surface. Abandonment shall occur during the
initial withdrawal from the original push borehole and not by a
separate trcmic tool after the sampling device has been removed
to ensure the breech in the confining layer is permanently
scaled.

Abandonment of temporary
conventionally installed or direct push
monitoring wells, as defined in R.61-
71B - applicable

SCDHEC R. 61-71H.4.C.

Underground Injection Control Requirements
(e.g., injection of reagents or bio-amendments)

Injection of fluids, solids,
or mixtures into

subsurface

No owner or operator shall construct, operate, maintain,
convert, plug, abandon, or conduct any other injection activity
in a manner that allows the movement of fluid containing any
contaminant into underground sources of drinking water, if
the presence of that contaminant may cause a violation of any
primary drinking water regulation under 40 CFR Part 142 or
may otherwise adversely affect the health of persons.

Underground injection into an
underground source of drinking water -
applicable.

40 CFR 144.12(a)



The movement of fluids containing wastes or contaminants
into underground sources of drinking water as a result of
injection is prohibited if the presence of the waste or

•	May cause a violation of any drinking water standard
under R61-58.5; or.

•	May otherwise adversely affect the health of persons.
As defined in R.61-87.2:

Underground injection of any fluids
into the subsurface or ground waters
of the State of South Carolina -
applicable.

SCDHEC R.61-87.5(A)
and (B)

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Action

Requirements

Prerequisite

Citation



' 'Fluid'' means material or substance which flows or moves
whether in a semisolid, liquid, sludge, gas, or any other form
or state.

"Well" means any excavation which is cored, bored, drilled,
jetted, dug, or otherwise constructed the depth of which is
greater than its largest surface dimension; or. a dug hole
whose depth is greater than the largest surface dimension; or.
an improved sinkhole; or. a subsurface fluid distribution
system.







No person shall construct, use or operate a Class V.A. well for
injection in violation of R61-87.5.

R.61-87.11(E)(1) - Class V.A. injection wells include:
(g) Injection wells used in experimental technologies

Class V.A injection wells [as
classified in R.61-87.11(E)(1)(g)-
relevant and appropriate

SCDHEC R.61-
87.11(E)(2)(b)

Operation of
underground injection
wells

At a minimum, the following information concerning the
injection formation shall be determined or calculated:

(1)	Fluid pressure;

(2)	Estimated fracture pressure;

(3)	Physical and chemical characteristics of the injection zone.

Operation of Class V.A. wells, [as
classified in R61-87.11(E)( 1 )(g)| for
underground injection into the
subsurface or ground waters of the
State of South Carolina - relevant
and appropriate

SCDHEC R.61-87.14(D)



Shall at all times properly operate and maintain all facilities

and systems of treatment and controls which arc installed or
used.



SCDHEC R.61-87.13(X)



Shall report malfunction of injection system which may cause
fluid migration into or between underground sources of
drinking water; shall immediately stop injection upon
determination that the injection system has malfunctioned and
could cause fluid migration into or between underground
sources of drinking water; shall not restart the injection
system until the malfunction has been corrected.



SCDHEC R.61-

87.13 (EE)

Monitoring of
underground injection
wells

An appropriate number of monitoring wells shall be
completed into the injection zone and into any underground
sources of drinking water which could be affected by the
injection operation. These wells shall be located in such a
fashion as to detect any excursion of injection fluids, process
by-products, or formation fluids outside the injection area or
zone. If the operation may be affected by subsidence or

Monitoring of Class V.A. wells, [as
classified in R.61-87.ll(E)(g)], used
for underground injections into the
subsurface or ground waters of the
State of South Carolina - relevant
and appropriate

SCDHEC R.61-
87.14(G)(1)

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Action

Requirements

Prerequisite

Citation



catastrophic collapse the monitoring wells shall be located so
that they will not be physically affected.





Waste Ch aracterization
(e.g., excavated soils, soil cuttings from well installation, wastewater)

Characterization of
solid waste (all primary
and secondary wastes)
and listed hazardous
waste determination

Must make an accurate determination as to whether that waste
is a hazardous waste in order to ensure wastes arc properly
managed according to applicable RCRA regulations. A

hazardous waste determination is made using the following
steps:

(a)	Must be made at the point of waste generation, before
any dilution, mixing, or other alteration of the waste occurs,
and at any time in the course of its management that it has. or
may have, changed its properties as a result of exposure to the
environment or other factors that may change the properties
of the waste such that the RCRA classification of the waste
may change

(b)	Must determine whether the waste is excluded from
regulation under 40 CFR § 261.4

(c)	Must use the knowledge of the waste to determine
whether waste meets any of the listing descriptions under
subpart D of 40 CFR Part 261. Acceptable knowledge that
may be used in making an accurate determination as to
whether the waste is listed may include waste origin,
composition, the process producing the waste, feedstock, and
other reliable and relevant information

Generation of solid waste as defined

in40 CFR § 261.2 / R.61-79.26In-
applicable

40 CFR § 262.11(a), (b)
and (c)

SCDHEC R. 61-79.
262.11(a),(b), and (c)

Determination of
characteristic

hazardous waste

The person then must also determine whether the waste
exhibits one or more hazardous characteristics as identified in
subpart C of 40 CFR part 261 by following the procedures in
paragraph (d)(1) or (2) of this section, or a combination of
both.

Generation of solid waste which is not
excluded under 40 CFR § 261.4(a) -
applicable

40 CFR § 262.11(d)

SCDHEC R. 61-79.
262.11(d)

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Action

Requirements

Prerequisite

Citation

determination of
characteristic

hazardous waste
through knowledge

The person must apply knowledge of the hazard characteristic
of the waste in light of the materials or the processes used to
generate the waste. Acceptable knowledge may include
process knowledge (e.g., information about chemical
feedstocks and other inputs to the production process);
knowledge of products, by-products, and intermediates
produced by the manufacturing process; chemical or physical
characterization of wastes; information on the chemical and
physical properties of the chemicals used or produced by the
process or otherwise contained in the waste; testing that
illustrates the properties of the waste; or other reliable and
relevant information about the properties of the waste or its
constituents.

A test other than a test method set forth in subpart C of 40
CFR part 261. or an equivalent test method approved by the
Administrator under 40 CFR 260.21, may be used as part of a
person's knowledge to determine whether a solid waste
exhibits a characteristic of hazardous waste. However, such
tests do not. by themselves, provide definitive results. Persons
testing their waste must obtain a representative sample of the
waste for the testing, as defined at 40 CFR 260.10.



40 CFR § 262.11(d)(1)

SCDHEC R. 61-79.
262.11(d)

Determination of
characteristic

hazardous waste
through testing

When available knowledge is inadequate to make an accurate
determination, the person must test the waste according to the
applicable methods set forth in subpart C of 40 CFR part 261
or according to an equivalent method approved by the
Administrator under 40 CFR § 260.21; or and in accordance
with the following:

(i)	Persons testing their waste must obtain a

representative sample of the waste for the testing, as defined
at 40 CFR §260.10.

(ii)	Where a test method is specified in subpart C of 40
CFR part 261. the results of the regulatory test, when properly
performed, arc definitive for determining the regulatory status

of the waste.

Generation of solid waste which is not
excluded under 40 CFR § 261.4(a) -
applicable

40 CFR § 262.11(d)(2)

SCDHEC R. 61-79.
262.11(d)



Must refer to Parts 261, 262, 264, 265, 266, 268, and 273 of
Chapter 40 for possible exclusions or restrictions pertaining to

management of the specific waste.

Generation of solid waste which is
determined to be hazardous -
applicable

40 CFR 262.11(e)
SCDHEC R. 61-79.
262.11(e)

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Special rules for
characteristic

hazardous waste

Must determine each EPA Hazardous Waste Number (waste
code) applicable to the waste in order to determine the
applicable treatment standards under subpart D of this part.
This determination may be made concurrently with the
hazardous waste determination required in § 262.11 of this
chapter. For purposes of part 268, the waste will carry the
waste code for any applicable listed waste (40 CFR part 261,
subpart D). In addition, where the waste exhibits a
characteristic, the waste will carry one or more of the
characteristic waste codes (40 CFR part 261, subpart C),
except when the treatment standard for the listed waste
operates in lieu of the treatment standard for the characteristic
waste, as specified in paragraph (b) of this section.

Generation of characteristic hazardous
waste for storage, treatment, or
disposal - applicable

40 CFR § 268.9(a)

SCDHEC R. 61-79.
268.9(a)



Must determine the underlying hazardous constituents [as
defined in 40 CFR § 268.2(i)] in the characteristic waste.

Generation of RCR A characteristic

hazardous waste (and is not D001
nonwastewaters treated by CMBST,
RORGS. or POLYM of § 268.42
Table 1) for storage, treatment, or
disposal - applicable

40 CFR § 268.9(a)

SCDHEC R. 61-79.
268.9(a)

Determinations for land
disposal of hazardous
waste

Must determine if the waste has to be treated before it can be
land disposed. This is done by determining if the hazardous
waste meets the treatment standards in §268.40, 268.45, or
§268.49. This determination can be made concurrently with
the hazardous waste determination required in §262.11 of this
chapter, in either of two ways: testing the waste or using
knowledge of the waste. If the generator tests the waste,
testing would normally determine the total concentration of
hazardous constituents, or the concentration of hazardous
constituents in an extract of the waste obtained using test
method 1311 in "Test Methods of Evaluating Solid Waste,
Physical/Chemical Methods," EPA Publication SW-846,
(incorporated by reference, see §260.11 of this chapter),
depending on whether the treatment standard for the waste is
expressed as a total concentration or concentration of
hazardous constituent in the waste's extract. ( Alternatively,
the generator must send the waste to a RCRA-pcrinitted
hazardous waste treatment facility, where the waste treatment
facility must comply with the requirements of §264.13 of this
chapter and paragraph (b) of this section.)

Generation of hazardous waste for
storage, treatment, or disposal -
applicable

40 CFR § 268.7(a)

SCDHEC R. 61-79.
268.7(a) (1)

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General Requirements for Remediation Wastes



Characterization of
remediation wastes

Obtain a detailed chemical and physical analysis of a
representative sample of the hazardous remediation wastes to
be managed at the site. At a minimum, the analysis must
contain all of the information which must be known to treat,
store or dispose of the waste according to this part and part
268 of this chapter and must be kept up to date.

Management of remediation wastes at
facility that docs not have a RCRA
permit - applicable

40 (l-'R % 264.10X2)

Waste Storage - Primary Wastes (contaminated media) and Secondary Wastes (spent treatment media, PPE, etc.)

emporary on-site
accumulation of
hazardous waste in
containers

A small quantity 8 generator may accumulate hazardous waste
on site without a permit or interim status, and without
complying with the requirements of parts 124, 264 through
267, and 270 of this chapter, or the notification requirements
of section 3010 of RCRA. provided that all the substantive
conditions for exemption listed in this section arc met.

Accumulation of RCRA hazardous waste
in containers on-site as defined in 40 CFR
§ 260.10 - applicable

40 CFR § 262.16(a)
SCDHEC R. 61-79. 262.16

Condition of containers

If a container holding hazardous waste is not in good
condition, or if it begins to leak, the small quantity generator
must immediately transfer the hazardous waste from this
container to a container that is in good condition, or

immediately manage the waste in some other way that
complies with the conditions for exemption of this section.



40 CFR § 262.16(b)(2)(i)
SCDHEC R. 61-79.
262.16(b)

Compatibility of waste
with container

Must use a container made of or lined with materials that will
not react with, and arc otherwise compatible with, the
hazardous waste to be accumulated, so that the ability of the
container to contain the waste is not impaired.

Accumulation of RCRA hazardous waste
in containers on-site as defined in 40 CFR
§ 260.10 - applicable

40 CFR § 262.16(b)(2)(ii)
SCDHEC R. 61-79.
262.16(b)

Management of
containers

(A) A container holding hazardous waste must always be closed
during accumulation, except when it is necessary to add or

remove waste.

(B) A container holding hazardous waste must not be opened,
handled, or accumulated in a manner that may rupture the
container or cause it to leak.



40 CFR § 262.16(b)(2)(iii)
SCDHEC R. 61-79.
262.16(b)

Inspections

At least weekly, the small quantity generator must inspect
central accumulation areas. The small quantity generator must
look for leaking containers and for deterioration of containers



40 CFR § 262.16(b)(2)(iv)
SCDHEC R. 61-79.
262.16(b)

8 The quantity of hazardous waste accumulated on site never exceeds 6,000 kilograms (13,200 pounds).

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caused by corrosion or other factors. See paragraph (b)(2)(i) of
this section for remedial action required if deterioration or leaks
are detected.





Labeling and marking of
containers

A small quantity generator must mark or label its containers with
the following:

(A)	The words "Hazardous Waste";

(B)	An indication of the hazards of the contents (examples
include, but arc not limited to. the applicable hazardous
waste characteristic(s) (i.e., ignitable. corrosive, reactive,
toxic); hazard communication consistent with the
Department of Transportation requirements at 49 CFR part
172 subpart E (labeling) or subpart F (placarding); a hazard
statement or pictograin consistent with the Occupational
Safety and Health Administration Hazard Communication
Standard at 29 CFR § 1910.1200; or a chemical hazard label
consistent with the National Fire Protection Association code
704); and

(C) The date upon which each period of accumulation begins
clearlv visible for inspection on each container.

Accumulation of RCRA hazardous waste
in containers on site as defined in 40 CFR
§260.10 - applicable

40 CFR § 262.16(b)(6)(i)
SCDHEC R. 61-79.
262.16(b)

Storage of hazardous
waste in container area

Area must have a containment system designed and operated in
accordance with 40 CFR 265.175(b).

Storage of RCRA hazardous waste in
containers with free liquids -
applicable

40 CFR 264.175(a)
SCDHEC R. 61-79.
264.175(a)



Area must be sloped or otherwise designed and operated to
drain liquid from precipitation, or

Containers must be elevated or otherwise protected from contact
with accumulated liquid.

Storage of RCRA-hazardous waste in
containers that do not contain free
liquids (other than F020, F021, F022,
F023, F026 and F027) - applicable

40 CFR 265.175(c)(l)-(2)
SCDHEC R. 61-79.
265.175(c) (l)-(2)

Closure of RCRA
container storage unit

At closure, all hazardous waste and hazardous waste residues
must be removed from the containment system. Remaining
containers, liners, bases, and soils containing or contaminated
with hazardous waste and hazardous waste residues must be
decontaminated or removed.

| Co in me nt: At closure, as throughout the operating period,
unless the owner or operator can demonstrate in accordance
with 40 CFR 261.3(d) of this cliapter that the solid waste
removed from the containment system is not a hazardous waste,
the owner or operator becomes a generator of hazardous waste
and must manage it in accordance with all applicable
requirements of parts 262 through 266 of this chapter].

Storage of RCRA hazardous waste in
containers in a unit with a containment
system - applicable

40 CFR 264.178

SCDHEC R. 61-79.
264.178

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Temporary on-site
storage of rcmediation

waste in staging piles
(e.g., excavated soils)

Must be located within the contiguous property under the

control of the owner/operator where the wastes arc to be

managed in the staging pile originated.

For purposes of this section, storage includes mixing, sizing,

blending or other similar physical operations so long as

intended to prepare the wastes for subsequent management or

treatment.

Accumulation of non-flowing hazardous
remediation waste (or remediation waste
otherwise subject to land disposal
restrictions) as defined in 40 C.F.R. §
260.10 -applicable

40 C.F.R. § 264.554(a)

SCDHEC R. 61-
79.264.554(a)



Staging piles may be used to store hazardous remediation
waste (or remediation waste otherwise subject to land disposal
restrictions) based on approved standards and design criteria
designated for that staging pile.

Note: Design and standards of the staging pile should be
included in CERCLA Remedial Design document approved or

issued by EPA.



40 CFR § 264.554(b)

SCDHEC R. 61-
79.264.554(b)

Performance criteria for

staging piles

Staging Pile must be designed to:

•	facilitate a reliable, effective and protective remedy;

•	prevent or minimize releases of hazardous wastes and
constituents into the environment, and minimize or
adequately control cross-media transfer as necessary to
protect human health and the environment (e.g., use of
liners, covers, run-off/run-on controls);



40 C.F.R. §

264.554(d)(l)(i) and (ii)

SCDHEC R. 61-

79.264.554(d)(l)(i) and (ii)

Operation of a staging
pile

Must not operate for more than 2 years, except when an
operating term extension under 40 CFR 264.554(i) is granted.
Note: Must measure the 2-year limit (or other operating term
specified) from first time remediation waste placed in staging
pile.



40 C.F.R.

§ 264.554(d)(l)(iii)
SCDHEC R. 61-
79.264.554(d)(l)(iii)



Must not use staging pile longer than the length of time
designated by EPA in appropriate decision document



40 CFR § 264.554(h)



Extension of up to an additional 180 days beyond the
operating term limit may be granted provided the continued
operation of the staging pile:

•	Will not pose a threat to human health and the
environment; and

•	Is necessary to ensure timely and efficient implementation
of remedial actions at the facility.



40 CFR 264.554(i)(l)(i)
and (ii)

SCDHEC R. 61-

79.264.554(i)( 1 )(i) and (ii)

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Design criteria for staging
pile

In setting standards and design criteria, must consider the

following factors:

•	Length of time pile will be in operation;

•	Volumes of waste you intend to store in the pile;

•	Physical and chemical characteristics of the wastes to be
stored in the unit;

•	Potential for releases from the unit;

•	Hydrogeological and other relevant environmental
conditions at the facility that may influence the migration
of any potential releases; and

•	Potential for human and environmental exposure to
potential releases from the unit.



40 CFR §

264.554(d)(2)(i)-(vi)
SCDHEC R. 61-
79.264.554(d) (2) (i) - (vi)

Operation of staging pile

Must not place ignitable or reactive remediation waste in a
staging pile unless the remediation waste has been treated.

rendered, or mixed before placed in the staging pile so that:

•	The remediation waste no longer meets the definition
of ignitable or reactive under 40 CFR 261.21 or 40
CFR 261.23; and

•	You have complied with 40 CFR §264.17(b); or

Must manage the remediation waste to protect it from exposure
to anv material or condition that may cause it to ignite or react.

Storage of ignitable or reactive
remediation waste in staging pile—
applicable.

40 CFR §264.554(e)(l)-(2)

SCDHEC R. 61-
79.264.554(e)(l)-(2)



Must not place in the same staging pile unless you have
complied with 40 CFR § 264.17(b)

Storage of "incompatible" remediation
waste (as defined in 40 CFR §260.10) in
staging pile in - applicable

40 CFR § 264.554(f)(1)

SCDHEC R. 61-
79.264.554(f)(1)



Must separate the incompatible waste or materials, or protect
them from on another by using a dike. bcrm. wall, or other
device.

Staging pile of remediation waste stored
nearby to incompatible wastes or
materials in containers, other piles, open
tanks or land disposal units—
applicable.

40 CFR § 264.554(f)(2)
SCDHEC R. 61-
79.264.554(f)(2)



Must not pile remediation waste on same base where
incompatible wastes or materials were previously piled unless
you have sufficiently decontaminated the base to comply with
40 CFR § 264.17(b).



40 CFR §264.554(f)(3)
SCDHEC R. 61-
79.264.554(f)(3)

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Closure of staging piles
of remediation waste

Must be closed within 180 days after the operating term by
removing or decontaminating all remediation waste,
contaminated containment system components, and structures
and equipment contaminated with waste and leachatc.

Storage of remediation waste in staging
pile in previously contaminated area -
applicable

40 CFR §264.554(j)(l)

SCDHEC R. 61-

79.264.554®(1)



Must decontaminate contaminated sub-soils in a manner that
EPA determines will protect human and the environment.



40 CFR §264.554(j)(2)

SCDHEC R. 61-
79.264.554(j)(2)



Must be closed within 180 days after the operating term
according to 40 CFR §§ 264.258(a) and 264. 111. or 265.258(a)
and 265. 111.

Storage of remediation waste in staging
pile in uncontaminated area -
applicable

40 CFR §264.554(k)
SCDHEC R. 61-
79.264.554(k)

Waste Treatment / Off-Site Disposal —Primary Wastes (e.g., contaminated media)
and Secondary Wastes (e.g., contaminated equipment and PPE)

Disposal of solid waste

Shall ultimately dispose of solid w aste at facilities and/or sites
permitted or registered by the Department for processing or
disposal of that waste stream.

Generation of solid w aste intended for
off-site disposal - relevant and
appropriate

SCDHEC R. 61-
107.5(D)(3)

Disposal of RCRA-
hazardous waste in an
off-site land-based unit

May be land disposed if it meets the requirements in the table
"Treatment Standards for Hazardous Waste" at
§ 268.40 before land disposal.

Land disposal, as defined in 40 CFR
268.2, of restricted RCRA waste -
applicable

40 CFR 268.40(a)
SCDHEC R. 61-79
§268.40(a)



All underlying hazardous constituents (as defined in 268.2(i))
must meet the Universal Treatment Standards, found in §
268.48, Table Universal Treatment Standards, prior to land
disposal as defined in § 268.2(c).

Land disposal of restricted RCRA
characteristic wastes (D001-D043)
that are not managed in a wastewater
treatment system that is regulated
under the CWA, that is CWA
equivalent, or that is injected into a
Class 1 nonhazardous injection well -
applicable

40 CFR 268.40(e)
SCDHEC R. 61-79
§26SA0(e)



Must be treated according to the alternative treatment
standards in 268.49(c) or must be treated according to the
Universal Treatment Standards (UTS) [specified in 268.48
Table UTS] applicable to the listed and/or characteristic waste
contaminating the soil prior to land disposal.

Land disposal, as defined in 40 CFR
268.2, of restricted hazardous soils -
applicable

40 CFR 268.49(b)
SCDHEC R. 61-79

268.49f&;



To determine whether a hazardous waste identified in this
section exceeds the applicable treatment standards of 40 CFR
268.40, the initial generator must test a sample of the waste
extract or the entire waste, depending on whether the
treatment standards arc expressed as concentration in the
waste extract or waste, or the generator may use knowledge of

Land disposal of RCRA toxicity
characteristic wastes (D004-D011)
that arc newly identified (i.e., wastes
or soil identified by the TCLP but not
the Extraction Procedure) -
applicable

40 CFR 268.34(f)
SCDHEC R. 61-79

268.34(f)

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the waste.

If the waste contains constituents (including UHCs in the
characteristic wastes) in excess of the applicable UTS levels
in 40 CFR 268.48, the waste is prohibited from land disposal,
and all requirements of part 268 arc applicable, except as
otherwise specified.





Disposal of RCRA-
hazardous waste soil in
a land-based unit

You must comply with LDRs prior to placing soil that

exhibits a characteristic of hazardous waste, or exhibited a
characteristic of hazardous waste at the time it was generated,
into a land disposal unit.

Land disposal, as defined in 40 CFR
268.2, of restricted hazardous soils -
applicable

40 CFR 268.49(a)
SCDHEC R. 61-79.
268.49(a)

Treatment of RCRA

hazardous waste soil

Prior to land disposal, all "constituents subject to treatment." as
defined in 268.49(d), must be treated as follows:

Treatment of restricted hazardous waste
soils - applicable

40 CFR 268.49(c)(1)
SCDHEC R. 61-79

268.49(c)(1)



For non-metals, except carbon disulfide, cvclohexanone. and
methanol, treatment must achieve a 90 percent reduction in
total constituent concentrations, except as provided in
268.49(c)(1)(C).



40 CFR 268.49(c)(1)(A)
SCDHEC R. 61-79
268.49(c)(1)(A)



For metals and carbon disulfide, cvclohexanone. and methanol,
treatment must achieve a 90 percent reduction in total
constituent concentrations as measure in leachatc from the
treated media (tested according to TCLP) or 90 percent
reduction in total constituent concentrations (when a metal
removal technology is used), except as provided in 268.49
(c)(1)(C).



40 CFR 268.49(c)(1)(B)
SCDHEC R. 61-79
268.49(c)(1)(B)



When treatment of any constituent subject to treatment to a 90
percent reduction standard would result in a concentration less
than 10 times the Universal Treatment Standard (UTS) for that
constituent, treatment to achieve constituent concentrations less
than 10 times the UTS is not required. UTS arc identified in
268.48 Table UTS.



40 CFR 268.49(c)(1)(C)
SCDHEC R. 61-79
268.49(c)(1)(C)



In addition to the treatment requirement required by paragraph

(c)(1) of 268.49, soils must be treated to eliminate these
characteristics.

Soils that exhibit the characteristic of
ignitability. corrosivity. or reactivity
intended for land disposal - applicable

40 CFR 268.49(c)(2)
SCDHEC R. 61-79
268.49(c)(2)



Provides methods on how to demonstrate compliance with the
alternative treatment standards for contaminated soils that will
be land disposed.

Treatment of restricted hazardous waste
soils - TBC

Guidance on
Demonstrating
Compliance with LDR
Alternative Soil Treatment

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Standards, U.S. EPA 530-
R-02-003 (Julv 2002)

Disposal of RCRA
wastewaters into CWA
wastewater treatment
unit

Wastes that are hazardous only because they exhibit a
hazardous characteristic, and which are otherwise prohibited
under this part, arc not prohibited | fro in land disposal] if the
waste meet any of the following criteria, unless the wastes arc
subject to a specified method of treatment other than DEACT
in §268.40, or arc D003 reactive cyanide:

(i)	The wastes arc managed in a treatment system which
subsequently discharges to waters of the U.S. pursuant to a
permit issued under section 402 of the Clean Water Act [SC

R.61-9 and R. 61-68]; or

(ii)	The wastes arc treated for purposes of the prctrcatmcnt
requirements of section 307 of the Clean Water Act [SC R.

61-9 and R.61-68]; or

(iii)	The wastes arc managed in a zero discharge system
engaged in Clean Water Act-cquivalcnt treatment as defined
in 268.37(a); and

(iv) The wastes no longer exhibit a prohibited
characteristic at the point of land disposal (i.e., placement in a
surface impoundment).

Restricted RCR A characteristic

hazardous wastewaters managed in a
wastewater treatment system
—applicable

40 CFR §268.1(c)(4)
SCDHEC R. 61-79
§268.1(c)(4)

Prctrcatnicnt standards
for discharges into
POTW

A user may not introduce into a POTW any pollutants which
cause pass through or interference (as defined in 403.3).

Introducing pollutants into POTW
(defined in 40 CFR 403.3) by a user
whether or not user is subject to other
National Prctrcatnicnt Standards or
national. State, or local prctrcatnicnt
requirements - applicable

40 CFR §403.5(a)(1)
SCDHEC R.61-9
§403.5(a)(1)



The following pollutants shall not be introduced into a

POTW:

(1)	pollutants which create a fire or explosion hazard,
including waste streams with a closed cup flashpoint of < 140

°F or 60 °C, using test methods specified in 40 CFR 261.21;

(2)	pollutants which will cause corrosive structural damage,
but in no case discharges with pH < 5.0, unless POTW is
designed to accommodate such discharges;

(3)	solid or viscous pollutants in amounts which will cause
obstruction to flow resulting in interference;



40 CFR §403.5(b)(l)-(8)
SCDHEC R.61-9
§403.5(b)(l)-(8)

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(4)	any pollutant, including oxygen demanding pollutants
(BOD) released in a discharge at flow rate and/or pollutant
concentration which will cause interference;

(5)	heat in amounts which will inhibit biological activity
resulting in interference, but in no case heat in quantities
causing temperature at POTW to exceed 40°C (104°F) unless
alternate temperature limits approved by POTW;

(6)	petroleum oil. nonbiodegradable cutting oil. or products
of mineral oil origin in amounts that will cause interference or
pass through;

(7)	pollutants which result in presence of toxic gases,
vapors, or fumes within POTW in quantity that may cause
acute worker health and safety problems; and

(8)	any trucked or hauled pollutants, except at discharge
points designated by the POTW.







Where specific prohibitions or limits on pollutants or
pollutant parameters arc developed by a POTW in accordance
with paragraph (c) above, such limits shall be deemed
Prctrcatment Standards for the purposes of section 307(d) of

CWA.



40 CFR §403.5(d)
SCDHEC R.61-9
§403.5(d)

Transportation of Wastes

Transportation of
hazardous waste on-site

The generator manifesting requirements of §262.20 and
§262.32(b) do not apply. Generator or transporter must comply
with the requirements set forth in §§263.30 and 263.31 in the
event of a discharge of hazardous waste on a private or public

right-of-way.

Transportation of hazardous wastes on a
public or private right-of-way within or
along the border of contiguous property
under the control of the same person,
even if such contiguous property is
divided by a public or private right-of-
way - applicable

40 CFR §262.20(0

SCDHEC R. 61-79
§262.200

Transportation of

hazardous waste off-site

Must comply with the generator requirements of
§§ 262.20-23 for manifesting. §262.30 for packaging. §262.31
for labeling. § 262.32 for marking. §262.33 for placarding.
§§262.40, 262.41(a) for record keeping requirements, and
§262.12 to obtain EPA ID number.

Generator who initiates the off-site
shipment of RCRA-hazardous waste -
applicable

40 CFR §262.10(h)
SCDHEC R. 61-79
§262.10(h)



Must comply with the requirements of 40 CFR 263.11-263.31.

A transporter who meets all applicable requirements of 49 CFR
171-179 and the requirements of 40 CFR 263.11 and 263.31

Transportation of hazardous waste
within the United States requiring a
manifest - applicable

40 CFR § 263.10(a)

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will be deemed in compliance with 40 CFR 263.





Transportation of
hazardous materials

Shall be subject to and must comply with all applicable
provisions of the HMTA and DOT HMR at 49 CFR 171-180.

Any person who, under contract with a
department or agency of the federal
government, transports "in commerce,"
or causes to be transported or shipped, a
hazardous material - applicable

49 CFR §171.1(c)

Transportation of
samples (i.e., solid
waste, soils and
wastewaters)

Are not subject to any requirements of 40 CFR Parts 261
through 268 or 270 when:

•	the sample is being transported to a laboratory for the

purpose of testing; or

•	the sample is being transported back to the sample

collector after testing.

•	the sample is being stored by sample collector before

transport to a lab for testing.

Samples of solid waste or a sample of
water, soil for purpose of conducting
testing to determine its characteristics
or composition - applicable

40 CFR §261.4(d)(l)(i)-

(iii)

SCDHEC R. 61-79
§26\A(d) (1)



In order to qualify for the exemption in 40 CFR 261.4 (d)(l)(i)
and (ii), a sample collector shipping samples to a laboratory
must:

•	Comply with U.S. DOT. U.S. Postal Service, or any

other applicable shipping requirements.

•	Assure that the information provided in (1) thru (5) of

this section accompanies the sample.

•	Package the sample so that it docs not leak, spill, or

vaporize from its packaging.



40 CFR 261.4(d)(2)

40 CFR 261.4(d)(2) (ii)(A)
and (B)

SCDHEC R. 61-79
261 A(d) (2)(ii)(A) and (B)

ARAR = applicable or relevant and appropriate requirement

CFR = Code of Federal Regulations

CVVA = Clean Water Act of 1972

DEACT = deactivation

DOT = U.S. Department of Transportation

EPA = U.S. Environmental Protection Agency

HMR = Hazardous Materials Regulations

HMTA = Hazardous Materials Transportation Act

LDR = Land Disposal Restrictions

NPDES = National Pollutant Discharge Elimination System
RCR A = Resource Conservation and Recovery Act of 1976
SCDHEC = South Carolina Department of Health and

Environmental Control
TBC = to be considered

TCLP = Toxicity Characteristic Leaching Procedure
UHC = underlying hazardous constituents
UTS = Universal Treatment Standard
WVVTU = Wastewater Treatment Unit

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Table A-5: Chemical-Specific ARARs/TBC for OU3 at the US Finishing/Cone Mills Superfund Site

Chemical-Specific ARARs

A ction/Media

Requirements

Prerequisite

Citation

Classification of ground
water

All South Carolina groundwater that is a potential underground
source of drinking water is classified Class GB under SCDHEC

R. 61-68H.9.

Groundwater, except within mixing
zones, within the state of South
Carolina - applicable

SCDHEC R. 61-68H.2

Restoration of ground
water as a potential
drinking water source

All inorganic and organic contaminants in underground sources

of drinking water may not exceed Maximum Contaminant
levels (MCLs) as set forth in SCDHEC R.61-58, State Primary
Drinking Water Regulations.

Shall not exceed the Safe Drinking Water Act National Revised
Primary Drinking Water Regulations: MCLs for organic
contaminants specified in 40 CFR § 141.61 and inorganic
contaminants specified in 40 CFR § 141.62.

Groundwater classified as
underground source of drinking water
(USDW) as (defined in SCDHEC
Reg. 61-68B.62) - relevant and
appropriate

SCDHEC R. 61-68H.9.b
(Groundwater Quality
Standards for Class GB
Ground Waters)

40 CFR Part 141 Subpart

G {National Primary
Drinking Water

Regulations)

Shall not exceed concentrations or amounts such as to interfere
with use. actual or intended, as determined by SCDHEC.

Presence of waste, pesticides, other
synthetic organic compounds,
deleterious substances, or constituents
thereof not specified in SCDHEC R.
61-68H.9aorb. in Class GB
groundwater - relevant and
appropriate

SCDHEC R. 61-68H.9.C

Discharge to surface

water

Any discharge into waters of the State must be permitted by
the Department and receive a degree of treatment and/or
control which shall produce an effluent which is consistent
with the Act, the Clean Water Act (P L. 92-500, 95-217, 97-
117, 100-4), this regulation, and related regulations.

NOTE: Under CERCL A Section 121(e) permits arc not
required for on-site response actions. Instead, discharges must
meet any applicable effluent limits or other substantive
requirements in order to protect the water quality of the
receiving water.

Discharge of pollutants (including
toxic substances) into waters of the
State of South Carolina - applicable

SCDHEC R. 61-68E.4.a

All ground and surface

waters

All ground waters and surface waters of the State shall at all
times, regardless of flow, be free from:

a. Sewage, industrial waste, or other waste that will settle to
form sludge deposits that arc unsightly, putrescent, or odorous
to such degree as to create a nuisance, or interfere with
classified water uses or existing water uses;

b. Floating debris, oil. grease, scum, and other floating
material attributable to sewage, industrial waste, or other

Standards applicable to all waters of
the State - applicable

SCDHEC R. 61-68E.5

GENERAL RULES
AND STANDARDS
APPLICABLE TO ALL
WATERS

-------
US Finishing/Cone Mills OU3
Record of Decision
	September 2023

waste in amounts sufficient to be unsightly to such a degree as
to create a nuisance or interfere with classified water uses or
existing water uses;

c.	Sewage, industrial, or other waste which produce taste or
odor or change the existing color or physical, chemical, or
biological conditions in the receiving waters or aquifers to
such a degree as to create a nuisance, or interfere with
classified water uses (except classified uses within mixing
zones as described in this regulation) or existing water uses;
and.

d.	High temperature, toxic, corrosive, or deleterious
substances attributable to sewage, industrial waste, or other
waste in concentrations or combinations which interfere with
classified water uses (except classified uses within mixing
zones as described in this regulation), existing water uses, or
which are harmful to human, animal, plant or aquatic life.

ARAR = applicable or relevant and appropriate requirement
CVVA = Clean Water Act of 1972

CFR = Code of Federal Regulations

EPA = U.S. Environmental Protection Agency

SCDHEC = South Carolina Department of Health and
Environmental Control

63

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APPENDIX A

State of South Carolina Concurrence

A-l

-------
T^dhec

Healthy People. Healthy Communities.

September 21, 2023

Caroline Y. Freeman, Director

Superfurid & Emergency Management Division

US EPA, Region IV

Atlanta Federal Center

61 Forsyth Street, SW

Atlanta, Georgia 30303

Re: State Concurrence for Record of Decision of OU3: Sitewide Groundwater
U.S. Finishing/Cone Mills Superfund Site
Greenville, South Carolina
SCD003358744

Dear Ms. Freeman:

The South Carolina Department of Health and Environmental Control {SCDHEC or Department) has
received the request for written concurrence on the Environmental Protection Agency {EPA) decision
to proceed with the Record of Decision (ROD) of OU3: Sitewide Groundwater for the U.S.
Finishing/Cone Mills Superfund Site located in Greenville, South Carolina. The Department has
reviewed and concurs with all parts of the ROD for OU3 dated September 2023. In concurring with
this ROD, the Department agrees that the Remedy was selected in accordance with the
Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA), 42
United States Code (USC) §9601 et seq., as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), and, to the extent practicable, the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP), 40 CFR Part 300, as amended.

The Selected Remedy, Alternative GW4, includes In-Situ Chemical Reduction (ISCR), In-Situ Enhanced
Bioremediation (ISEB), and Institutional Controls. This remedy involves the injection of reagents (a
chemical reductant for ISCR and an electron donor for ISEB to immobilize hexavalent chromium by
conversion to trivalent chromium) into the saprolite and bedrock aquifers to treat groundwater
contamination and the implementation of institutional controls to restrict groundwater use and to
prevent well installation in the groundwater plume.

The selected remedy meets the Threshold Criteria and provides the best balance of tradeoffs among
the other alternatives with respect to balancing and modifying criteria. It addresses chromium
impacted groundwater and is expected to meet the statutory requirements under CERCLA Section
121(b).

S.C. Department of Health and Environmental Control

2600 Bull Street. Columbia. SC 29201 (803)898-3432 www.scdhec.gov

-------
Ms. Freeman

Page 2

The Selected Remedy for the U.S. Finishing/Cone Mills Superfund Sitewide groundwater is estimated
to cost $9,500,000 for OU3. The cost estimate is based on a 30-year timeframe and all available
information regarding the scope of the response actions. The estimate may change as a result of
new information and data collected during the Remedial Design phase.

SCDHEC agrees that the Selected Remedy presented in the ROD is protective of human health and
the environment, complies with Federal and State requirements that are applicable or relevant and
appropriate to the remedial action, are cost-effective, and utilize permanent solutions and
alternative treatment technologies to the maximum extent practicable.

Thank you for the opportunity to provide input on the ROD. if you have any questions concerning the
Department's concurrence, please feel free to contact Susan Fulmer at (803) 898-4331.

Henry J. Porter, Chief

Bureau of Land and Waste Management

cc: Glenn Adams, EPA Region 4
Scott Martin, EPA Region 4
Scott Miller, EPA Region 4
G. Ken Taylor, BLWM
R. Gary Stewart, BLWM
Susan Fulmer, BLWM
Sara MacDonald, BLWM

Natalie Kirkpatrick, EA Update Greenville Region
File # 50936

Sincerely,

-------
APPENDIX B

Comment and Response Index

B-l

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U.S. Finishing/Cone Mills Superfund Site, Operable Unit 3 (OU3)

Public Meeting July 11, 2023
Question &Answer Session/Responsiveness Summary

The following questions were asked by attendees during the public meeting held on July 11,
2023, at Parisview Baptist Church, Greenville, South Carolina, during the Q&A session
following EPA's presentation of the proposed plan for OU3 - Site-wide Groundwater. The
EPA's responses are provided below.

How long/how many injections will there be?

The number of injections needed will be determined during the remedial design process. A round
of injections may take 4 to 6 months to implement. It is anticipated that multiple rounds of
injections may be needed over a period of years. The estimated time frame to achieve remedial
action objectives is 2 to 15 years depending on the response of contamination to treatment.

Was Langston Creek tested?

Yes. Surface water and sediment samples were collected in Langston Creek as part of the
remedial investigation in 201 1, 2012, 2013, and 2016. The results of the sampling indicated that
no remedial action was necessary. Langston Creek was deleted from the National Priorities List
in September 2021.

Can anything be built during this time?

Yes. Construction on the Main Facility area can begin during the time of groundwater
remediation. Limitations on construction in the area of groundwater remediation may be needed
until cleanup goals are achieved.

Is this federally funded? Where will the funds come from?

The US Finishing/Cone Mills Superfund Site is a fund lead remedial action. The federal
government will fund the remedial action for OU3: Sitewide Groundwater.

W ho purchased the Site?

Approximately 150 acres of the OU2: Off Main Facility area have been purchased by the Cone
Mills Acquisition Group (CMAG). EPA determined No Action was warranted for OU2 and thus
OU2 was deleted from the National Priorities List in September 2021.

How deep is the plume?

The depth of the contaminated groundwater plume varies across the Site and can be found as
deep as 50 feet below ground surface.

B-2

-------
Could there be concerns regarding community gardens?

The groundwater contamination is located on Site and, based on information currently available
to the EPA, there are no community gardens within the extent of the plume.

Who is responsible for removing the old bleachery and what is the time frame to make it
visibly attractive?

The Record of Decision for OIJ1: Main Facility was approved in June of 2022. The selected
remedy calls for the demolition of the remaining Main Facility slab, removal of contaminated
soils under the main slab area, and institutional controls to protect to areas used to contain
demolition material and Asbestos Containing Material (ACM). The OIJ 1 remedy will be
implemented by the EPA fund lead or under EPA's oversight pursuant to a voluntary cleanup
agreement with a prospective developer.

Are the new water/sewer lines being installed by Greenville County impacting the plumes?

EPA does not anticipate that the installation of new water and sewer lines would impact the
groundwater plume.

The pond lake view, when was it sampled and what action was taken?

The Northern Reservoir, across from Lakeview Middle School, had soil and groundwater
samples taken during the remedial investigation. The results of the sampling indicated that no
remedial action was necessary. The area was deleted from the National Priorities List in
September 2021.

The areas that EPA states does not require action, will the eventually require cleanup
action?

Areas that were designated as No Action by the EPA will not receive remedial action from the
EPA.

What about the water treatment area that is full of water near brooks, a pond? Will they
rehome the turtles?

The aeration lagoon located near Brooks Avenue was designated as a No Action area by the EPA
and removed from the National Priorities List in February 2023. Future use of this area has yet to
be determined.

B-3

-------
Can you explain the nuances of the Brownfield cleanup versus EPA cleanup?

Superfund sites are uncontrolled or abandoned sites or properties where hazardous waste or other
contamination is located. A contaminated site is generally considered a "Superfund site" if the
federal government is or plans to be involved in cleanup efforts. Many of these sites are listed on
the National Priorities List (NPL). The federal government may provide funding for the cleanup
efforts or direct a Potentially Responsible Party (PRP) to conduct the cleanup.

Brownfield sites are real properties, the expansion, development, or reuse of which may be
complicated by the presence or potential presence of a hazardous substance, pollutant, or
contaminant. Generally, the federal government is not involved at brownfields. Rather, state and
tribal response programs play a significant role in cleaning up and helping to revitalize these
sites, frequently through state voluntary cleanup programs.

What is a VCC?

A VCC is a voluntary cleanup contract conducted under the state Brownfields program.

What are the extra requirements of state/brownfields that EPA does not do?

Extra requirements required by the state Brownfield program are varied. Additional requirements
may be needed depending on the future use of an area under the Brownfield program. For
example, if the EPA determined an area required remediation to levels acceptable for
industrial/commercial uses based on the existing or reasonably anticipated land use for the Site,
but a new owner/developer later wants to use the area for residential use, additional cleanup may
be required by the state and could be conducted by the new owner under the state Brownfield
program through a voluntary cleanup contract.

How is the groundwater different form the drinking water being used by the city?

While the groundwater at the Site is designated as a potential source of drinking water the City
of Greenville does not use groundwater as a source of drinking water. Greenville utilizes Table
Rock Reservoir, North Saluda Reservoir, and Lake Keowee to obtain drinking water.

When you dig for water/development does the evaporated water then create air
contamination from the contamination in the water?

No. Any vapors from excavation of soil or treatment of groundwater are not a risk as a source of
air contamination.

If water does become contaminated, what are the chances of health risks for the
neighborhood due to the groundwater injections?

The groundwater on the main facility is currently contaminated with the main contaminant of
concern being chromium. The purpose of the injections is to treat the contaminated groundwater.
Treatment will decrease the chances of health risks to the neighborhood. The surrounding
neighborhoods utilize City water so residents are not exposed to the groundwater.

B-4

-------
What kind of chemical is leaking/exists in the groundwater? How much has been cleaned
up?

The main contaminant of concern in the groundwater is chromium. Prior to facility closure in
2003 due to fire, a pump and treat system was operated by the facility under state oversight to
treat groundwater. The EP A does not know the exact detail of how much groundwater was
treated, but the system operated for over 20 years. The EPA's selected OU3 groundwater remedy
will utilize additional active treatment measures to address remaining contamination in the
plume.

Are there any effects on the ecosystem from the injections?

No. Negative impacts to the ecosystem are not anticipated from treating the groundwater
contamination.

Did you retest after destroying the structures/trees?

No. The EPA did not sample after the structures/trees located in portions of OU2: Off Main
Facility were cleared by the new owner of the [northern] portion of the former Cone Mills
property. Approximately 150 acres of OU2 qualified as No Action in the Superfund program.
These areas were deleted from the federal Superfund Program's National Priorities List in
September 2021 and require no further action by the EPA.

Will you test to see if there is any runoff in the creeks/ponds after cleanup?

Groundwater monitoring will be conducted as part of the remedial action for OU3: Sitewide
Groundwater. Surface water sampling of Langston Creek and the Reedy River may be conducted
as part of the post remedial action for OU3, but that has not been determined at this time.

B-5

-------
Frcends

August 10, 2023

To Whom This May Concern,

Friends of the Reedy River (FoRR) is a 501(c)(3) nonprofit organization based in Greenville,
South Carolina dedicated to promoting, preserving, and restoring the Reedy River. We
accomplish this through education, advocacy, and action to fulfill our vision of a safe, clean, and
accessible river corridor that enhances the quality of life for all residents, businesses, and
visitors. Founded in 1993, Friends of the Reedy River is the only nonprofit organization
dedicated solely to the restoration and preservation of tributaries and wetlands within the Reedy
River watershed. We advocate for improved watershed management to minimize stormwater
impacts and sedimentation, community activation and volunteerism, water quality monitoring,
and public education initiatives.

FoRR has a vested interest in the US Finishing/Cone Mills Superfund Site (the Site) due to its
abundant riparian lands adjacent to the Reedy River and Langston Creek. As advocates for the
restoration of these waterways, we recognize the contamination and degradation of the
groundwater at the Site could have significant ramifications on downstream water quality,
adversely increasing health risk to local communities and decreasing the viability of the Reedy
River as a drinking water source.

Moreover, the Site is surrounded by communities that have a legacy of bearing the impacts of
pollution. The residents of these areas, many of whom belong to economically disadvantaged
groups, already face numerous environmental challenges, with the surrounding neighborhood
exceeding national and state averages for all thirteen Environmental Justice indices provided in
EPA's EJScreen Environmental Justice Mapping Tool (see attachment). The potential exposure
to hazardous substances from the Site poses severe health and economic risks to these
communities, making the remediation efforts even more crucial to ensuring environmental
justice and equitable access to clean water.

Furthermore, the area surrounding the Site is experiencing rapid development and growth. As
this region of the watershed undergoes significant urbanization, there is an increased risk of
exacerbating existing environmental issues and contaminant spread. By addressing the
contamination promptly and comprehensively, the EPA's cleanup efforts will not only protect the
environment but also support sustainable and responsible development in the long term.

After reviewing the Proposed Plan for the Operable Unit 3 (OU3) at the Site, FoRR fully
supports the preferred remedial alternative of GW-4, combining in-situ chemical reduction,

Post Office Box 9351 • Greenville, South Carolina 29604

-------
enhanced bioremediation, and institutional controls. We support this alternative as it provides a
portfolio of interventions and will achieve the highest level of reduction in contamination within
the shortest time frame.

FoRR, a now 30-year-old organization, has a deep history and connection with the communities
of Greenville. As such, we would like to offer our resources and capacity to assist the EPA with
the solicitation of community engagement and feedback in this process to the best of our ability.
While we understand that this process is well under way as OIJ1 and 2 have already been
delisted as NPL sites, we appreciate the significance of completing contamination clean up of
this site. Additionally, we want to highlight the significance of preparing the community that has
been historically impacted by this pollution as they will see new pressures, namely development
of these sites. We also welcome collaboration with those involved in the redevelopment
following the delisting of the Site.

Sincerely,

Friends of the Reedy River
P.O. Box 9351
Greenville, SC 29604
i nfo@fri endsofthereedy ri ver.org
j osi e@fri endsofthereedy ri ver.org

Attachment:

EJ Screen Environmental Justice Mapping Tool Sans Souci.pdf

Post Office Box 9351 • Greenville, South Carolina 29604

-------
The United States Environmental Protection Agency

Memorandum of Public Meeting Minutes
for the US Finishing/Cone Mills Site
Greenville, South Carolina

I am Zariah Lewis the EPA Community Involvement Coordinator for the U.S. Finishing/Cone Mills
Site. There was a proposed plan public meeting held on July 11, 2023 in Greenville. South Carolina
at the Parisview Baptist Church. The meeting was called to order by Zariah Lewis at 6:35 pm and
the agenda/presentation (attached) was presented by Scott Martin, the Remedial Project Manager.
The presentation covered the Site's Proposed Plan for the alternative cleanup remedy for Operable
Unit 3: Groundwater and notified the community of their options to comment on the proposed plan
during the comment period. The presentation ended around 7: 00 p.m. and transitioned to a Q and

The meeting was attended by a total of 55 community members. 3 South Carolina Department of
Health and Environmental Control representatives, and 2 representatives from the Prospective
Purchasers. Cone Mills Acquisition Group. LLC. The meeting concluded around 7:30 p.m. A court
reporter was not hired for the meeting, thus, there is no formal transcription of the meeting. Though
there is no formal transcription, Zariah Lewis took note of the questions asked and answ ered during
the meeting. Those questions are bulleted below and will also be responded to in writing by EPA in
the Record of Decision responsiveness summary.

•	How long/how many injections will there be?

•	Langston Creek was blue, was the creek tested'.'

•	Can anything be built during this time'.'

•	Going back my first question, after 15 years, will the construction begin or will there be any
construction at all?

•	Is this federally funded'.' Where will the funds come from'.'

•	Who purchased the Site'.'

•	How deep is the plume'.'

•	Could there be concerns regarding community gardens'.'

•	Who is responsible for removing the old bleachery and what is the time frame to make it
visibly attractive'.'

•	Are the new water/sewer lines being installed by Greenville County impacting the plumes'.'

•	The pond lake view , when was it sampled and what action was taken'.'

•	The areas that EPA states does not require action, will the eventually require cleanup
action'.' What about the water treatment area that is full of water near the pond'.' Will they
rehome the turtles'.'

•	Can you explain the nuances of the Brow nfield cleanup versus EP A cleanup?

•	What is a VCC

•	What are the extra requirements of state/brow nfields that EPA does not do'.'

•	How is the groundwater different form the drinking water being used by the city?

•	When you dig for water/development docs the evaporated water then create air
contamination from the contamination in the water?

•	If water does become contaminated, what are the chances of health risks for the
neighborhood due to the groundwater injections'.'

•	What kind of chemical is leaking/exists in the groundw ater'.' How much has been cleaned
up'.'

•	Is there any effects on the ecosystem from the injections'.'

•	Did you retest after destroying the structures/trees'.'

•	Will you test to see if there is any runoff in the creeks/ponds after cleanup'.'

A.

-------
This memo was prepared by Zariah Lewis, the Community Involvement Coordinator, from notes
taken during the meeting using the notes function on her cellphone on July 11, 2023 at
approximately 7:00 pm.

Zariah Lewis

EPA Community Involvement Coordinator

61 Forsyth Street
Atlanta, Ga 30303
(404) 562-8342

Sincerely.

Attachments: OU1 Proposed Plan PowerPoint Presentation

-------
United States
Environmental Protection
Agency

OU3 Proposed Plan Summary Presentation

2023 Proposed Plan for OU3
and Administrative Record

httDs://www.eDa.aov/suDerfund/us-finishinq-cone-mills

The public may review the online Administrative Record at:

Hughes Main Library

25 Heritage Green Place
Greenville, SC, 29601
(864) 242-5000

Hours:

Monday-Thursday 10:00 am - 8:00 pm
Friday-Saturday 10:00 am - 5:00 pm

-------
United States
Environmental Protection
Agency

Public Comment Period

Comments must be submitted by August 11, 2023,

Mail

U.S. EPA Region 4
Attention: Scott Martin
61 Forsyth Street, S.W.
Atlanta, Georgia 30303

Email

Scott Martin, Remedial Project Manager
Martin.Scott@epa.gov

Zariah Lewis, Community Involvement Coordinator
Lewis.Zariah(S)eDa.aov

Phone

Scott Martin (404) 562-8916
Zariah Lewis (404) 562-8342

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United States
Environmental Protection
Agency

Superfund Process

THE SUPERFUND REMEDIAL PROCESS

/Issessmenf

t

i=

os ;i

Discovery of Preliminary
Contamination Assessment

Site
Inspection

National
Priorities List
(NPL) Site Listing

Characterization

rf ~

Remedial investigation/
Feasibility Study
& Proposed Plan



CURRENT STAGE

Selection of
Remedy

Record of
Decision

Cleanup

Remedial
in

Remedial
Action

Post-Construction





Operation and
Maintenance

NPL
Deletion

Five-Year Reviews

Community in vofvement and planning for a site's redevelopment are integral fo the entire process

-------
United States
Environmental Protection
Agency

SiteC

•	Located approximately 2.5 miles north of
downtown Greenville, SC.

•	Approximately 260 acres; multiple parcels

•	Three Operable Units

-	OU1: Main Facility

-	OU2: Off Main Facility

-	OU3: Sitewide Groundwater

•	The site is currently not in use.

-------
United States
Environmental Protection
Agency

•	Facility operated as a textile mill,
under various owners, for -100 years.

•	2003 - American Fast Print closed due
to fire destroying main plant. No
viable responsible party.

•	2011 - EPA listed Site on the
National Priority List (NPL)

•	2011 - EPA initiated a Time Critical
Removal Action at the main facility to
remove and contain exposed asbestos
resulting from main plant fire.

•	2011 - EPA initiated sitewide remedial
investigation to assess nature and
extent of site contamination.

[granbrcokiCti

IPJniteyT&rji

!NiHaven*Dr-







Site History

-------
United States
Environmental Protection
Agency

Approximately 220-acres Removed From NPL

In Sept. 2021 approximately 150-acres
were removed from NPL for OU2 after
EPA issued No Action ROD for OU2.







h



fl' w -

*.A* SL ¦ -*• '

llx ifcP



/¦



i ''

^a!



In Feb. 2023, approximately 70-acres
were removed from NPL for OU1 main
plant areas requiring no action.

lA. iiSfe*





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w





HW .

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Bar¦# '; n • „4rV - •¦ ¦

H - |i

-------
United States
Environmental Protection
Agency

Remedial Investigation (Rl)

A sitewide Remedial Investigation was conducted to determine the nature
and extent of contamination at the site. This included the analysis of soil,
sediment, surface water, and groundwater.

• This Proposed Plan will focus on the RI that was conducted on the
sitewide groundwater.

Additional details regarding the sitewide RI can be found in the
Administrative Record.

-------
United States
Environmental Protection

Anpn r»\/

Remedial Investigation (Rl)

The W-17 screened interval extends
through alluvial, saprolhic. and bedrock
aquifer materials.

Legend

Monitor Wells

~	Alluvial

~	Saprolite/Alluvium

~	SapnoJrte

~	Bedrock
Recovery

~	Staff Gauge
** Piezometer

Abandoned

~	Temporary Wells

DPT Discrete Groundwater
Sample (Hyrdropuncti)

i i Main Plant (AOC 16)

I I Gray Warehouse

. Site Boundary

H—I- Former Railroad

Stream/River

i	'	"	«	r

«	1	1

125	250	500

WGSS4

US Finsshin-gj'Cone Mills
Green vrtle, Greenville County
South Carolina

Figure 3-1
Monitor WeJI Locations
Operable Unit 3

^VERSAR

-------
United States
Environmental Protection
Agency

Remedial Action Objectives

• Prevent exposure of humans to groundwater contaminated with contaminants
of concern (COC) concentrations above federal or state primary drinking
water standards (i.e., Maximum Contaminant Level, MCL) and health-based
cleanup goals in the absence of a MCL for a particular COC.

• Restore groundwater to its beneficial use as a potential drinking water source
by reducing groundwater COC concentrations to meet federal and state
primary drinking water standards (i.e., MCLs) or health-based cleanup goals
in the absence of a MCL for a particular COC.

-------
Preliminary Remediation Goals for Soils

United States
Environmental Protection
Agency

Prelim nary Remedial Goals

Groundwater COC

PRO (jig/L)

Basis

Cobalt

9

Hazard Quotient Tevel, Residential, Hazard

Quotient = 1

Iron

20.256

Manganese

4.051

Molybdenum

145

Strontium

17,362

2 -Methylnaphthalene

116

4-Chloroaniline

0.4

Cancer Risk Tevel, Residential, 1 x 10"6

Chromium (including Cr+6)

100*

MCTs

Arsenic

10

1,4-Dichlorobenzene

75

Notes:

* = The federal primary drinking water standard (MCL) for total chromium is 0.1 mg/L or 100 ppb. This regulation
assumes that a measurement of total chromium is 100 percent chromium-6 (Hexavalent Chromium), the more toxic form.
See https://www. ep a.gov/sdwa/chromium-drinking-water

Source: Final Feasibility Study Report for OUT, OU2, and OU3, US Finishing/Cone Mills, Greenville, Greenville County,
South Carolina. Versar. July 15, 2020.

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United States
Environmental Protection
Agency

Remedial Alternatives

• The 2020 Sitewide Feasibility Study Report evaluated four remedial action alternatives for
groundwater:

Alternative GW1: No Action.

Alternative GW2: In-Situ Chemical Reduction and Institutional Controls
Alternative GW3: In-Situ Enhanced Bioremediation and Institutional Controls
Alternative GW4: In-Situ Chemical Reduction, In-Situ Enhanced Bioremediation and
Institutional Controls

• Alternatives GW2, GW3 and GW4 all involve injections into the aquifers to administer
reagents to treat groundwater contamination and implementation of institutional controls to
restrict groundwater use and to prevent well installation in the groundwater plume.

The alternatives differ regarding the cost and the reagents to be injected.

-------
United States
Environmental Protection
Agency

Evaluation of Alternatives

Threshold Criteria

—	Overall Protection of Human Health and the Environment

—	Compliance with Applicable or Relevant & Appropriate Requirements (ARARs)

Balancing Criteria

—	Long-term Effectiveness and Performance

—	Short-term Effectiveness

—	Reducing Toxicity/Mobility/Volume Through Treatment

—	Implementability

—	Cost

Modifying Criteria

— State Acceptance
mmunitv A

mmrn

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United States
Environmental Protection
Agency

Evaluation of Alternatives

Effectiveness

Implementability

Cost

In-Situ Chemical in-situ Enhanced
No Action Reduction ISCR Bioremediation ISEB

and ICs	and ICs

Protective of Human Health & the Env.

Achieves Removal Objectives
Reduction of Contamination
Short-Term
Long-Term
Technical Feasibility
Availability

Capital Cost (conventional injections)
Capital Cost (hydro-fracture injections)

RESULT

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United States
Environmental Protection
Agency

Preferred Alternative

•	EPA's Preferred Alternative for 0U3 is Alternative GW4: ISCR, ISEB and
Institutional Controls. Alternative GW4 consists of the following remedial activities:

•	In-situ treatment of highest hexavalent chromium groundwater concentrations using a
combination of ISCR and ISEB reagents.

•	Groundwater monitoring to assess efficacy of treatment and inform additional
remedial activities, as needed.

Implementation of institutional controls to prohibit groundwater use and to prevent
installation of wells near or in groundwater contamination until cleanup levels are
met.

Cost approximately $ 9,500,000.

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20OFeei

NADB3 Sate Plane South Caioli

assays

oEPA Example Injection Points Shallow Aquifer

Environmental Protection	®	®

Agency

Notes

1 i/VpIH; cj-rp»pnori arrncs mnlfiplfl rnrps | alluvial

and saprohte) are mended m the saprone
(socontour madei

2. &arrf3le points without decectabte chromium
mode ted as a zero value ror contouring purposes

3	U - Indicates ctn-omium was analysed far. but not
de tccte d -3b ove the sarru le qua nbtabon I mt

4	Apparent discontinuities n chromium (total)
isocontours and individual well concmtnjlions
are the resiit of a vertical concentration gradient
vwthin the saprolite aquifer zone

5	The 1.000 ut/L alluvial isoconloir east of 1he Man
Plant is -within the same area as the sa pi elite 1.000
ugfl. saprditc isocartour	

Legoitd

DP T Discrete Groundwater
® Sam pie (H ydiopunch)

~	Tern poraiywalls
Monitor ing W*B

~	SsprolteW luvi d

~	saproite

ADC 16 Main Ptant

1 Stte Bounttary

Stream/River

Chromium (Total)
l soconcanlraticn (pg/L,i
Sapiolila ChiotnuJiri |To1aQ
. Grou ndwater C o nee r.ii ato n
laoconteur

Seproiile Interred Chromium (ToteO
¦ &rou ndwaier C o nee rnrato n
Isaconlou r

Alkjv ial G id undwaler

Concentration laocoirtour

Gray Waraho use

Proposed Injection Locations (SSftfCitd]
15* aparl with 30' raw spacing

Proposed Injection Locations {AjiuviaD
15' apart with 30' row spaetn g

March 201* GWEIevaticn Concur

US Finishing/Gone Mi#s
Greenville. Greenville County
South Carolina

FIGURE 5-1
Proposed Alluvium/Sapiolite
Injection Locations

fVERSAR

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9

MADB3 Slabs Plana South Carolina

torn

Wore s.

1	On V ma ritor vw I s screen ed v-ith in
die bedrock aie included m the bedrock
potenbornetric surface mode!

2	Groundwater elevations were measured
Auflust 2,2014.

3. Bedrock wells not shown rrere not gauged
on August 2. 2D 14

United States
Environmental Prot

EW 4'

V V * ¦>

Legend

Monlteitog w«»

• BeflrocK

AOC16 Main Plant

— Site Boundary

StrearruRi'/er

Chromium (Total)
Iscconcentration [ugrt-l
Chromium (Toiall
ticjndrtattr Concentration
bDcorilour

In I or rod Chromium (Total)

-	Groundwater Concentration

bocontour

Gray "Warehouse

P reposed In_£cl5 cn Wei is (H ednxk)
45' apart with 90* row spacing

August 20lit GWEIevatlon Contour

GreeovtUe County	f

So uih Carolina

US Finishing/Cone Mills
Greenville, Greenville County
Soutti Carolina

FIGURE 5-2
Proposed Bedrock
Injection Wells

^ VERSAR

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United States
Environmental Protection
Agency

Questions?

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United States
Environmental Protection
Agency

Public Comment Period

Comments must be submitted by August 11,2023.

Mail

U.S. EPA Region 4
Attention: Scott Martin 11th Floor
61 Forsyth Street, S.W.

Atlanta, Georgia 30303



Scott Martin, Remedial Project Manager



Martin.Scott@epa.gov

Email

Zariah Lewis, Community Involvement Coordinator



Lewis.Zariah@epa.gov

Phone

Scott Martin (404) 562-8916
Zariah Lewis (404) 562-8342

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