Sixth Five-year Review Report for Carolawn Inc. Superfund Site Chester County South Carolina


SIXTH FIVE-YEAR REVIEW REPORT FOR
CAROLAWN, INC. SUPERFUND SITE
CHESTER COUNTY, SOUTH CAROLINA

oEPA

SEPTEMBER 2023

Prepared for

U.S. Environmental Protection Agency
Region 4
Atlanta, Georgia

RANDALL CHAFFINS

Digitally signed by
RANDALL CHAFFINS
Date: 2023.09.27 16:08:52
-04'00'

Caroline Y. Freeman, Director

Superfund & Emergency Management Division

-------
11

-------
Table of Contents

LIST OF ABBREVIATIONS & ACRONYMS	v

I.	INTRODUCTION	1

Site Background	1

FIVE-YEAR REVIEW SUMMARY FORM	3

II.	RESPONSE ACTION SUMMARY	3

Basis for Taking Action	3

Response Actions	4

Status of Implementation	6

III.	PROGRESS SINCE THE LAST REVIEW	9

OTHER FINDINGS	10

IV.	FIVE-YEAR REVIEW PROCESS	 1 1

Community Notification, Involvement & Site Interviews	 1 1

Data Review	 12

V.	TECHNICAL ASSESSMENT	15

QUESTION A: Is the remedy functioning as intended by the decision documents9	15

QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels and RAOs used at the

time of the remedy selection still valid9	15

QUESTION C: Has any other information come to light that could call into question the
protectiveness of the remedy9	 17

VI.	ISSUES/RECOMMENDATIONS	 18

OTHER FINDINGS	19

VII.	PROTECTIVENESS STATEMENT	19

VIII.	NEXT REVIEW	20

APPENDIX A - REFERENCE LIST	A-1

APPENDIX B - CURRENT SITE STATUS	B-l

APPENDIX C - SITE CHRONOLOGY	C-l

APPENDIX D - PRESS NOTICE/INTERVIEW FORMS	D-l

APPENDIX E - GROUNDWATER MONITORING FIGURES	E-l

APPENDIX F - SUMMARY OF DETECTED COCS IN GROUNDWATER MONITORING WELLS

OCTOBER 2004 THROUGH MARCH 2023	F-l

APPENDIX G - SITE INSPECTION CHECKLIST	G-l

APPENDIX H - DETAILED ARARs REVIEW	H-l

APPENDIX I - TOXICITY ASSESSMENT	1-1

APPENDIX J - SITE PHOTOGRAPHS	J-l

iii

-------
Tables

Table 1: COCs by Media	4

Table 2: ROD Established Remediation Goals for OU-1	5

Table 3: Summary of Planned and/or Implemented Institutional Controls	7

Table 4: Protectiveness Determination/Statements from 2018 FYR	9

Table 5: Status of Recommendations from 2018 FYR	10

Table 6: Estimated Surface Water Concentration Evaluation	 14

Table F- 1: Summary of Detected COCs in Groundwater Monitoring Wells October 2004 Through

March 2023	F-2

Table H-1: Chemical Specific ARARs	H-2

Table H-2: Location Specific ARARs	H-3

Table H-3: Action Specific ARARs	H-3

Table H-4: Groundwater ARAR Review	H-4

Table H-5: Surface Water ARAR Review	H-5

Table 1-1: Review of Groundwater Remedial Goal s	1-2

Table 1-2: OU-2 Soil and Sediment COPCs	1-3

Table 1-3: OlJ-2 Soil and Sediment COPC Residential Risk Evaluation	1-4

Table 1-4: Assumptions Used in the IEUBK Model	1-6

Figures

Figure 1: Site Vicinity Map	2

Figure 2: Institutional Controls Map	8

Figure 1-1: OlJ-2 Soil Sample Location Map	1-8

Pictures

Site Photograph J-l: Entrance to Carol awn Inc. Treatment Building Area	J-l

Site Photograph 1-2: Morrison Road Looking West from Site Entrance	J-2

Site Photograph J-3: Entrance to Savannah Spring Farms Hunt Club (located at east end of

Morrison Road)	J-3

Site Photograph J-4: Panoramic View of the Savannah Springs Farm Hunt Club (near monitoring wells

MW-7, MW-13, and MW-17)	J-4

Site Photograph J-5: New Structure Under Construction at Savannah Springs Farms Hunt Club (near

MW-7)	J-5

Site Photograph J-6: Photo Showing New Construction is Elevated Above Ground (near MW-7)	J-6

Site Photograph J-7: Fishing Creek Near Monitoring Wells 1 OA & 10B	J-7

Site Photograph J-8: Hunting Club Building (former cabin location & near MW-8	J-8

iv

-------
LIST OF ABBREVIATIONS & ACRONYMS

AOC

Administrative Order on Consent

ARAR

Applicable or Relevant and Appropriate Requirement

CERCLA

Comprehensive Environmental Response. Compensation, and Liability Act

CFR

Code of Federal Regulations

CIC

Community Involvement Coordinator

coc

Contaminant of Concern

COPC

Chemical of Potential Concern

CSC

Carolawn Steering Committee

DC A

Dichloroethane

DCE

Dichloroethylene

EISB

Enhanced In-Situ Biodegradation

EPA

United States Environmental Protection Agency

FFS

Focused Feasibility Study

FFS-R2

Focused Feasibility Study - Revision 2

FS

Feasibility Study

FYR

Five-Year Review

GWETS

Groundw ater Extraction and Treatment System

HQ

Hazard Quotient

IC

Institutional Control

P-g/L

Micrograms Per Liter

jj.g/m.3

Microgram Per Cubic Meter

MatPb

Maternal Blood Lead Concentration at Childbirth

mg/kg

Milligram per Kilogram

MCL

Maximum Contaminant Level

MNA

Monitored Natural Attenuation

MW

Monitoring Well

NCP

National Contingency Plan

NPL

National Priorities List

O&M

Operation and Maintenance

ou

Operable Unit

PCB

Polychlorinated Biphenyl

PCE

T etrachloroethylene

PRP

Potentially Responsible Party

RAO

Remedial Action Objective

RI

Remedial Investigation

ROD

Record of Decision

RPM

Remedial Project Manager

RSL

Regional Screening Level

RV

Recreational Vehicle

SCDHEC

South Carolina Department of Health and Environmental Control

SVE

Soil Vapor Extraction

TCA

Trichloroethane

TCE

T richloroethylene

UAO

Unilateral Administrative Order

UU/UE

Unlimited Use and Unrestricted Exposure

voc

Volatile Organic Compound

WQC

Water Quality Criteria

v

-------
I. INTRODUCTION

The purpose of a five-year review (FYR) is to evaluate the implementation and performance of a remedy
to determine if the remedy is and will continue to be protective of human health and the environment.
The methods, findings, and conclusions of reviews are documented in FYR reports such as this one. In
addition, FYR reports identify issues found during the review, if any, and document recommendations to
address them.

The U.S. Environmental Protection Agency is preparing this FYR pursuant to the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) Section 121, consistent with the
National Contingency Plan (NCP)(40 Code of Federal Regulations (CFR) Section 300.430(f)(4)(ii)), and
considering EPA policy.

This is the sixth FYR for the Carol awn. Inc. Superfund site (the Site). The triggering action for this
statutory review is the signature date of the previous FYR. The FYR has been prepared because
hazardous substances, pollutants or contaminants remain at the Site above levels that allow for unlimited
use and unrestricted exposure (UU/UE).

The Site consists of two operable units (OUs). OU-1 is a 3-acres area completely enclosed by a chain-
link fence and the areal extent of all groundwater contamination beneath the Site. OU-2 is an
undeveloped wooded area to the north and west of the fenced area of OU-1. OlJ-2 includes the soils,
surface water and sediment in Fishing Creek. This FYR addresses both OUs.

The South Carolina Department of Health and Environmental Control (SCDHEC) conducted the FYR
and prepared this report regarding the remedy implemented at the Site. The EPA is the lead agency for
developing and implementing the remedy for the cleanup at the Site. The relevant entities such as the
potentially responsible parties (PRPs) were notified of the initiation of the FYR. The review began on
September 8, 2022.

Site Background

The 60-acre site is located at 5093 Morrison Road in Fort Lawn, Chester County, South Carolina (Figure 1).
From 1970 to 1979, a waste storage and disposal facility operated at the Site. Operations disposed of
about 4,500 drums of waste, several bulk storage tanks and sludge in the Site's 3-acre fenced area.
Additionally, operations disposed of 660 drums and 1 1 storage tanks outside the fenced area in the
northern portion of the Site.

Current site features include a former groundwater treatment building, monitoring wells, a fence and
signage. Rural and agricultural areas surround much of the Site. The Lancaster & Chester Railroad and
County Road 841 border the Site to the south. Providence Fish & Game (a hunting club) and Fishing
Creek border the Site to the east. The Circle S Ranch borders the Site to the west. There are several
residences southwest of the Site. The fenced OU-1 area is not currently in use; the hunting club hunts on
some areas of OlJ-2. The club also maintains several structures near the Site for storage and hunting-
related purposes and club members temporarily park recreational vehicles (RVs) in this area; they do not
have any drinking water wells on site.

Groundwater beneath the Site occurs along joint/fracture planes in the bedrock, forming a bedrock
aquifer. Groundwater flow is generally northeast and southeast toward Fishing Creek. Fishing Creek

-------
Disclaimer: This map and any boundary lines within the map are approximate and subject to change.

The map is not a survey. The map is for informational purposes only regarding the EPA"S response actions at the Site.

Ti^dhec

Carol awn, Inc. Superfund Site

Town of Fort Lawn, Chester County. South Carolina

Sources:

OqPubiic.rMK Chester County. SC,
2021 Aerial Photography

Carolawn. Inc.
Superfund Silc
Property Boundary

Figure 1: Site Vicinity Map

2

-------
forms a hydraulic boundary to the northeast, east and southeast of the Site and is the discharge location
for site groundwater. The four residences that previously used private wells in the area about 1,000 yards
southwest of the Site were provided an alternative water source in 1985. They were connected to the
Chester Metropolitan Sanitary District.

Appendix A provides a list of references used during this FYR. Appendix B provides detailed site status
information. Appendix C provides a chronology of site events.

There are no immediate plans for the redevelopment of the vacant areas of the Site.

FIVE-YEAR REVIEW SUMMARY FORM

sri i: ii)i:\ i n k \ i ion

Site Name:

Carol awn. Inc.

EPA ID:

SCD980558316

| Region: 4

State: SC

City/County: Fort Lawn, Chester County

Sill; ST All s

NPL Status: Final

Multiple OlJs?
Yes

ri :\ ii :\\ s r \ ri

Lead agency: EPA
Author name: Yvonne Jones (EPA) and Timothy Kadar (SCDHEC)
Author affiliation: EPA and SCDHEC
Review period: 9/8/2022 - 8/30/2023
Date of site inspection: 1 1/17/2022
Type of review: Statutory
Review number: 6
Triggering action date: 9/18/2018

Due date (five years after triggering action date): 9/18/2023

II. RESPONSE ACTION SUMMARY
Basis for Taking Action

The PRP, the Carol awn Steering Committee (CSC), performed a remedial investigation and feasibility
study (Rl/FS) for OU-1 in 1989. It identified volatile organic compounds (VOCs) and lead in
groundwater as the only contaminants of concern (COCs) with the potential to pose unacceptable risk

Has the site achieved construction completion?

Yes

-------
for human consumption (Table 1). Former waste storage drums and tanks were identified as the source
of these COCs.

Based on the results of the 1994 RI and baseline risk assessment for OU-2, the EP A determined
that surface and subsurface soils, surface water, and sediment in Fishing Creek did not pose
unacceptable risks to the public or the environment. Therefore, a FS and a remedial action for OlJ-2
were not warranted.

Table 1: COCs by Media

coc

Media

1,1-Dichloroethane, 1,2-Dichloroethene (cis & trans), 1,1-Dichloroethene,
1,1,1 -Trichloroethane, Trichloroethene, Lead

groundwater

Response Actions

The Carol awn Company abandoned the site property in 1980. SCDHEC and the EPA conducted site
investigations during the early 1980s. Due to the elevated levels of site contamination, the EPA removed
contaminated soils, drums, and liquid waste at the Site from December 1981 to February 1982. The EPA
proposed the Site for listing on the Superfund program's National Priorities List (NPL) in December 1982.
The EPA finalized the Site's listing on the NPL in September 1983. At least one local residential well
showed persistently high levels of VOCs, so the EPA extended the Chester Metropolitan Sanitary
District's water main to four residences near the Site in 1985. In May 1985, the CSC entered an
Administrative Order on Consent ( AOC) to conduct a removal action that included removing storage
tanks, disposing of tank contents, and excavating and disposing of contaminated soils. The CSC
conducted the removal action in 1986.

In September 1989, the EPA issued an OU-1 Record of Decision (ROD), which included the following
remedial action objectives (RAOs):

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

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

Control contaminant migration so contaminant releases from groundwater to Fishing Creek do

not exceed cleanup criteria for human health and the environment.

Monitor groundwater in a manner to verify effectiveness of remedial measures.

Confirm the absence or presence of soil contamination in the storage area north of the fenced

area (OlJ-2).

The OU-1 remedy included the following components:

Migration Control - Remediation of Contaminated Groundwater

o Installation of a groundwater interception and extraction system at the Site.

¦ The remedy provided three water discharge alternatives for the treated

groundwater: 1) the local sewer system; 2) Fishing Creek via a National Pollutant
Discharge Elimination System permit or 3) on-site irrigation,
o Implementation of appropriate institutional controls.

o Plugging and abandonment of the adjacent contaminated private potable wells by
Chester County.

-------
Source Control - Remediation of Contaminated Soils

o Installation of confirmatory soil borings in the disposal area north of the fenced area to
verify the presence or absence of contamination and, if present, address cleanup of this
contamination in another ROD.1
General Site Cleanup Activities

o Inspection, sampling, and disposal of two inactive incinerators and two remaining drums.

ROD Established Remediation Goals for OU-1 (groundwater) are included below in Table 2.

Table 2: ROD Established Remediation Goals for OU-1

Groundwater

COC

Remedial Goal

Basis

(mg/kg)

Acetone

700

Lifetime Health Advisory

1,1-Dichloroethane (DCA)

*

*

1,1-Dichloroethene (DCE)

7

MCL

1,2- Dichloroethene (1,2-DCE)

70-cis
100 - trans

Proposed MCL
Proposed MCL

1,1,1-Trichloroethane (TCA)

200

MCL

Trichloroethene (TCE)

5

MCL

Lead

5

Proposed MCL

Notes:





Source: 1989 ROD. Table 23





Hg/L = micrograms per liter
MCL = maximum contaminant level





* = It is assumed that due to 1,1-DCA's similar chemical/physical characteristics with other contaminants present, the
levels will decrease proportionally along with the other contaminants.

To address the soils located beyond OU-1, the EPA conducted R1 activities for OU-2 and issued a ROD
for OlJ-2 in 1995. The 1995 OU-2 ROD selected a "no action" remedy due to the absence of any
significant source of contamination in soil, surface water and sediment at the Site. The ROD stated that
should future monitoring of the Site indicate the presence of unacceptable risk to the environment, then
the EPA may initiate cleanup actions.

1 No source of contamination remained within the fenced area of the Site due to earlier removal actions.

5

-------
Status of Implementation

From December 1991 to May 1992, CSC contractors closed at least three residential wells (which were
no longer in use). The groundwater extraction and treatment system (GWETS) was installed from
December 1995 to June 1996. GWETS operation began in October 1996 and ended in July 2004 when
CSC shut down the GWETS, removed pumps and decommissioned the system. During operation, the
system extracted about 19.2 million gallons of groundwater and 16 kilograms of VOCs from the bedrock
VOC plume. It was estimated that the GWETS would have had to operate for at least another 62 years to
achieve MCLs, due to the low yield of the bedrock formation. Therefore, the EP A and SCDHEC
recommended a system optimization study to consider other remedial technologies to address
groundwater contamination.

In 2005, the CSC conducted a pilot study to evaluate enhanced in-situ biodegradation (EISB) as a
remedial option, which involved the injection of a soy-oil based product known as Newman Zone to
promote accelerated biodegradation of VOCs. Post-injection monitoring data indicated biodegradation
occurred. However, these conditions were not widespread, and biodegradation slowed at individual
locations due to insufficient transport away from the injection boreholes. In addition, the plume extent
and VOC concentrations did not change significantly in response to the EISB in the bedrock aquifer.
The 2008 FYR Report recommended further evaluation of remedial technologies.

In March 2009, the EPA issued a modified Unilateral Administrative Order (UAO) to the CSC that
required a focused feasibility study (FFS) to identify a groundwater remedy besides the GWETS. In
August 2010, the CSC conducted a soil vapor extraction (SVE) pilot study to evaluate it as a potential
interim remedial measure. The study indicated SVE was a feasible approach to reduce VOC mass in the
subsurface (vadose zone), which could result in reduced VOC concentrations in groundwater. Following
discussions with SCDHEC, the CSC and the Community Advisory Group, the EPA approved
construction of the SVE system, which finished in January 2012. The SVE system was intended to
operate until VOC recovery reached a point of diminishing returns and sufficient data were collected to
complete the FFS. The SVE system operated until June 2014, when it was shut down due to a continued
decrease in VOC mass removal and asymptotic VOC mass removal rates. About 160 pounds of VOC
mass were removed during SVE system operation. SVE system well and piping abandonment activities
took place in July 2016.

The CSC submitted a revised FFS in 2016 and the FFS - Revision 2 (FFS-R2) in 2019, which provided
an update of site conditions based on remedial actions conducted to date and evaluated potential OU-1
remedial technologies. Several technologies were evaluated, including monitored natural attenuation
(MNA) and enhanced permeability with groundwater extraction/treatment or with in-situ biological
treatment, among others.

The EPA, SCDHEC and CSC are currently discussing the remedial options with plans to discuss the
remedial options with members of the community in the coming months. The EP A will consider input
from all parties prior to selecting a new remedy for the Site and amending the 1989 ROD.

Institutional Control (IC) Review

The 1989 OU-1 ROD required institutional controls at the Site, but ICs have not yet been implemented
due to the lack of a viable property owner willing to execute and record institutional controls. The
defunct Carol awn Company is still listed as the property owner. The CSC, SCDHEC and the EPA have
agreed on draft restrictive covenants; they allow no use of OU-1, permit only commercial or industrial

-------
land use in areas outside of OU-1 on the site parcel, require maintenance of site remedial features,
preclude disturbance of soil below the top 12 inches without regulatory approval, and restrict
groundwater use. Figure 2 includes site and nearby parcels that may require institutional controls,
particularly due to contaminated groundwater.

Table 3: Summary of Planned and/or Implemented Institutional Controls

Media,
Engineered
Controls and
Areas that Do
not Support
UIJ/UE Based
on Cu rrent
Conditions

ICs
Needed

ICs Called
for in the
Decision
Documents

Impacted

Parcel(s);!

IC Objective

Instalment in
Place

Groundwater and
Soil

Yes

146-00-00-005-000

The 1989 ROD required
appropriate institutional controls to
be implemented.

Draft institutional controls include

the following restrictions:

• Prevent use of OU-1.

• Permit only commercial or
industrial land use in areas
outside of OU-1.

• Require maintenance of site
remedial features.

• Preclude disturbance of soil
below the top 12 inches
without regulatory approval.

None

Drafted but

not yet
implemented
due to lack of
viable property
owner

Groundwater

Yes

146-00-00-005-000
146-00-00-018-000
146-00-00-019-000
146-00-00-037-000

Restrict groundwater use.

None

Systems Operations/Operation and Maintenance (O&M)

The PRPs" contractor, Geosyntec inspects the Site monthly. Inspection activities include observation of
the general condition of the facility and security of the building and equipment. Additionally, biweekly
lawn maintenance is conducted during the growing season. Groundwater sampling activities occur on a
semi-annual basis, typically in March and September of each year, with reporting on a biennial basis.
The next Biennial Groundwater Monitoring Report is due in early 2024.

-------
Disclaimer: This map and any boundary lines within the map are approximate and subject to change.
The map is not a survey. The map is for informational purposes only regarding the EPA's response actions at the Site.

TttgyiTocjToi sTr

0

son ]ooo

2tKMj
F«<

Ncmrvov:

Public .not CkMcr County, SCt
2021 Aerial I'hotograpltv

Lcsemi

furi'i'k Krquirinji;
(.nmiitlwulir K\

t'nrccl Krt{ taring
(itnuntlnjil«r £

Soil K>

Carolawn, Inc. Superfund Site

Town of Fort I awn. Chester Cotttttv. South Carolina

Figure 2: Institutional Controls Map

8

-------
III. PROGRESS SINCE THE LAST REVIEW

This section includes the protectiveness determination and statement from the previous FYR Report
(Table 4) as well as the recommendations from the previous FYR Report and the status of those
recommendations (Table 5).

Table 4: Protectiveness Determination/Statements from 2018 FYR

on #

Protectiveness
Determination

Protectiveness Statement

OU-1

Short-term
Protective

• Select and implement a new groundwater remedy. Record the selected
remedy in a decision document. Include all appropriate COCs and cleanup
goals in the decision document.

• Sample for 1.4-dioxane in groundwater and take additional action if necessary.

• Implement institutional controls for OU-1.

• Evaluate the need for institutional controls restricting groundwater use on
properties where groundwater contamination is present. Record any needed
restriction requirements in a decision document.

OU-2

Short-term
Protective

The remedy at OU-2 is protective in the short term because historical removal actions,
including removal of contaminated soil and drums, addressed contamination in this

area. For the remedy to be protective over the long term, the following action should
occur:

• Evaluate the need for institutional controls for OU-2. as necessary.

Sitewide

Short-term
Protective

The remedy at OU 1 is protective in the short term because there is no complete
exposure pathway to contaminated groundwater, and the GWETS and other pilot
studies have reduced the amount and extent of groundwater contamination. The remedy
at OU-2 is protective in the short term because historical removal actions, including
removal of contaminated soil and drums, addressed contamination in this area. For the
remedy to be protective over the long term, the following actions should occur:

• Select and implement a new groundwater remedy. Record the selected remedy
in a decision document. Include all appropriate COCs and cleanup goals in the
decision document.

• Sample for 1.4-dioxane in groundwater and take additional action if necessary.

• Implement institutional controls forOU 1.

• Evaluate the need for institutional controls for OU-2. as necessary.

-------
Table 5: Status of Recommendations from 2018 FYR

on #

Issue

Recommendations

Current
Status

Current
Implementation
Status Description

Completion

Date (if
applicable)

OU-1

The GWETS is no longer
operating due to its estimated
timeframe required to meet
MCLs, but a new groundwater
remedy is not yet in place. Not
all currently sampled VOCs that
exceed MCLs were selected as
COCs in the original renicdv.

Select and implement a new
groundwater remedy.
Record the selected remedy
in a decision document.
Include all appropriate
COCs and cleanup goals in
the decision document

Ongoing

Data collection is
ongoing to support the
FFS and modifications
to the decision
document

N/A

OU-1

The 1989 ROD identified 1.1.1-
TCA as a COC. and 1.4-dioxane

was historically used as a
stabilizer for 1,1,1-TCA. It is
unknown if 1.4-dioxane is
present in site media.

Sample for 1.4-dioxane in

groundwater and take
additional action if

necessaiy.

Ongoing

1.4-dioxane will be
included in the
Spring 2024 monitoring
event.

N/A

OU-1

The 1989 ROD required
institutional controls, which
have not been implemented due
to the lack of a viable property

owner.

Implement institutional
controls for OU-1.

Ongoing

The PRP. the EPA, and
SCDHEC have agreed
on a restrictive covenant
but there is no viable
property owner to
complete
implementation

N/A

OU-1

Groundwater contamination
extends beyond the site
boundary; no institutional
controls to limit groundwater
use are in place on neighboring
properties where groundwater
contamination is present.

Evaluate the need for
institutional controls
restricting groundwater use
on properties where
groundwater contamination
is present. Record any
needed restriction
requirements in a decision
document.

Ongoing

Data collection is
ongoing to support the
FFS and modifications
to the decision
document

N/A

OU-2

Soil contamination (specifically

chromium and PCB-1254)
concentrations
exceeded residential RSLs
and may not allow for
residential use.

Evaluate the need for
institutional controls for
OU-2. If required, modify
the decision document as
appropriate.

Ongoing

2019 FFS -R2 (Human
Health Risk Assessment

Update) determined
there arc potential risks

to human health if
unrestricted land use is

permitted at OU-
2(soils). Institutional
Controls arc needed to
restrict residential
land use.

N/A

OTHFR FINDINGS

Two additional recommendations were identified during the 2018 FYR. These recommendations did not
affect current and/or future protectiveness.

-------
If additional buildings are built over volatile groundwater contamination, this exposure
pathway should be further evaluated with multiple lines of evidence to determine if
mitigation is needed.

Continue to monitor downgradient monitoring well locations to ensure the current
remedy and the future selected remedy remains protective of Fishing Creek.

IV. FIVE-YEAR REVIEW PROCESS
Community Notification. Involvement & Site Interviews

On October 19, 2022, the EPA issued a press release, which announced that comprehensive reviews will
be conducted of completed cleanup work at NPL Superfund sites in the Southeast, including the
Carol awn Site. Appendix D contains a copy of the EPA News Release. A copy of the FYR report will be
made available on the EPA website: http s: //www.epa. gov/ superfund/carol awn.

The FYR process included interviews with regulatory agencies involved in Site activities or aware of the
Site. The purpose was to document the perceived status of the Site and any perceived problems or
successes with the phases of the remedy implemented to date. All the interviews were conducted in
person, via telephone, or completed by email after the Site inspection. The interviews are summarized
below. Completed interview forms are included in Appendix D.

Jeff Ahrens from PRP contractor Geosyntec stated that the SVE system has been an effective interim
remedial measure. Overall, groundwater monitoring data suggest that concentrations of Site-specific
COCs in groundwater are generally stable or decreasing, and this data supports that MNA following
prior SVE activities, is effectively addressing COCs in groundwater at the Site. Former source area
monitoring wells which historically had the highest concentrations of TCE at the Site (MW-05, MW-06
and MW-12) have shown greater than an order of magnitude reduction in VOC concentrations since the
startup of the SVE system in 201 1. Cis-1,2-DCE concentrations have reduced to concentrations below
the MCL (70 (.ig/L) in each Site monitoring well, except for MW-16. In monitoring wells located near
Fishing Creek, both TCE and cis-l,2-DCE are reported below the MCL at MW-1 OA, MW-11A and
MW-11B in September 2022, with TCE present at a concentration of 39.5 (.ig/L in MW-1 OB, which
represents an approximate 3-fold decrease since 2011.

The SVE system (conducted as an Interim Remedial Measure) proved to be an effective means of VOC
source mass removal at the Site and proved to be a more effective remedial measure than the previously
operated groundwater pump and treat system which was shut down with regulatory approval in 2004.
Approximately 160 pounds (lbs) of VOCs were removed during the period of SVE system operation
(January 2012 through June 2014); for comparison, the groundwater extraction and treatment system
(GWETS) removed approximately 35 lbs of VOCs during its 7.5 years of operation. As is typical, the
mass removal rate of the SVE system decreased with time due to the ongoing reduction of V OC mass
in the vadose zone, and for that reason, SVE system operations were ceased, and the system was
subsequently abandoned in 2016 with concurrence from EPA. The removal of VOCs from the vadose
zone in the former source area by the SVE system has and will continue to result in improvements to
groundwater quality over time as source depletion reduced VOC mass flux into the groundwater.
Following source mass removal, the observed trends over the last five years of groundwater monitoring
indicate that natural attenuation processes also serve an important function in meeting Applicable or

1 1

-------
Relevant and Appropriate Requirements (ARARs) at the Site. Based on the removal of COC source
mass and current groundwater trends observed at the Site, Geosyntec, on behalf of the performing PRPs,
urges EPA to modify the 1989 ROD, and formally select MNA as the remedy for the Site. Geosyntec
stand ready to assist USEPA in preparing the necessary documentation.

Christopher Slocum, the project manager with SCDHEC stated multiple groundwater remedies have
been implemented and attempted throughout the Site's history, including groundwater extraction and
treatment, in-situ bioremediation, and soil vapor extraction. The Site's hydrogeologic setting and the
presence of contaminants in the fractured bedrock have limited the long-term effectiveness of the
groundwater remedies implemented to date. The PRP contractor previously prepared a FFS to MNA as a
potential groundwater remedy at the Site. While MNA may be a viable remedy due to the overall
decreasing VOC concentration trends, SCDHEC has previously expressed concerns about the plume not
being adequately defined to ensure that an MNA remedy will be protective. Based the 2021 groundwater
data, the highest TCE concentrations at the Site were detected in monitoring well MW-1 OB, adjacent to
Fishing Creek, at a concentration of 49.6 |ig/L {decreasing to 40.8 /ig/L in 2023). Additional
characterization of groundwater discharge to the creek may be necessary to ensure that TCE is not
discharging to the creek. Additionally, the northwestern and southern portions of the plume appear to be
undefined, and additional monitoring wells may be needed to fully delineate the plume and support a
potential MNA remedy. SCDHEC plans to continue discussions with the EPA, the PRP group, and the
PRP contractor to select a groundwater remedy. Concurrently, groundwater VOC concentrations across
most of the site demonstrate apparent decreasing trends. Deed restrictions to prohibit groundwater use
were drafted in 2015 but have not been finalized due to the lack of a viable property owner. The
restrictions are necessary to prevent any future human health risk due to exposure to contaminated
groundwater. The Site is currently undeveloped and groundwater at the Site is not being used for
residential purposes, and there is currently minimal risk of human exposure to contaminated
groundwater at the Site. However, institutional controls restricting groundwater use are necessary to
ensure long-term protectiveness of the remedy.

In May 2022, legislation (SC H.4999) was passed regarding the implementation of site-specific cleanup
goals. The SCDHEC is currently working towards determining how best to implement this SC H.4999
on affected sites.

Data Review

Groundwater monitoring conducted during this FYR was intended to verify the effectiveness of
remedial measures. Surface water was not sampled, but estimated surface water concentrations were
calculated based on groundwater concentrations.

Groundwater

As described in multiple groundwater monitoring reports prepared by Geosyntec Consultants
(Geosyntec), groundwater is currently monitored semiannually for VOCs. The well locations are shown
in Appendix E, Figure E-l. Several wells are paired, with B wells having shallower well screens. The
VOCs sampled that have exceeded MCLs from September 2018 to March 2023 include 1,1-DCE, cis-
1,2-DCE, tetrachloroethylene (PCE), TCE and vinyl chloride; several of these VOCs are not official
COCs. Several groundwater COCs are no longer sampled for as they were detected below the MCLs,
including acetone, 1,1-DC A, trans-1,2-DCE, 1,1,1 -TCA and lead. Appendix F, Table F-l, presents a
summary of COCs detected in the groundwater at the site from October 2004 through September 2023.

-------
The two most prevalent contaminants in groundwater at the Site are cis-1,2—DCE and TCE.
Concentrations of these contaminants by well from 201 1 to 2023 are shown in Appendix E, Figure E-2.
Current plumes are shown in Appendix E, Figures E-3 through E-5. Groundwater flow is generally to
the east in the western portion of the Site, and to the northeast and southeast toward Fishing Creek in the
eastern portion of the Site. Therefore, plumes generally extend from the Site east toward the creek. See
Figure E-6 in Appendix E for a potentiometric surface and flow map. The plumes in areas between the
creek and Site are inferred due to a lack of wells. The MCL for TCE is 5 micrograms per liter (|ig/L).
The extent of the 5 |ig/L TCE plume has decreased. All of the wells with TCE concentrations over 100
|ig/L at the time of the 2018 FYR, have decreased in the last five years, including MW-13 (from 107
(ig/L in 2018 to 44.5 |ig/L in 2023) and MW-16 (from 115 |ig/L in 2018 to 44.6 |ig/L in 2023) as well as
MW-12 which has decreased from 108 |ig/L in 2018 to 5.7 |ig/L in 2023. Concentrations in
downgradient wells near the creek have decreased. Concentrations in monitoring well MW-1 1B
decreased from 64.6 |ig/L (in 2018) to 5.7 |ig/L (in 2023). The concentrations in MW-1 OA/10B and
MW-11A have decreased since 2018 but continue to exceed the MCL. During 2023, the concentrations
in MW-10A/10B and MW-11 A ranged from <5.7 |ig/L to 40.8 |ig/L. The TCE plume is available in
Appendix E, Figure E-3.

The MCL for cis-l,2-DCE is 70 |ig/L. The extent of the 70 |ig/L cis-l,2-DCE plume changed slightly as
the concentrations in MW-6 decreased from 142 |ig/L in 2018 to 23.6 |ig/L in 2023. The concentrations
in MW-4 decreased from 44.3 |ig/L in 2018 to 5.0 |ig/L in 2023.The extent of the plume is now centered
around MW-4 and MW-16. However, there was a significant decrease in the concentration at MW-16
which saw a decrease from 212 |ig/L in 2018 to 70 |ig/L in 2023. Concentrations also generally
decreased in MW-5, MW-11 A, and MW-1 IB. cis-l,2-DCE is still present along the northeastern edge of
the creek at MW-1 OA/10B, but both wells showed slight decreases in their concentrations and are below
the MCL. The 2023 cis-1,2- DCE plume is available in Appendix E, Figure E-4.

Vinyl chloride was not detected above the MCL of 2 (.ig/L at the time of this FYR.

Figures depicting the concentration trends of TCE, cis-l,2-DCE and 1,1-DCE in the source area (MW-5
and MW-6) are available in Appendix E, Figures E-7and E-8. As seen in these graphs, concentrations of
these contaminants have decreased overall in the last five years. Generally, groundwater contamination
at the Site has decreased since the GWETS and particularly since the operation of the SVE system from
2012 to 2014. However, contamination remains above MCLs for several VOCs, which is why the EPA,
the PRP and SCDHEC are continuing to discuss additional remedial options.

Surface Water

Groundwater concentrations were above MCLs for several contaminants during the most recent
sampling event in wells next to the creek (MW-1 OA, MW-10B and MW-11 A). Groundwater
concentrations are below levels that would impact surface water in the creek above EPA Water Quality
Criteria (WQC) for human health. To verify this conclusion with current data, the surface water
concentration was predicted by applying a dilution factor (from the 2004 Remedial System Evaluation
and Final Action Plan) to the maximum detected concentrations from wells MW- 1 OA, MW-10B and
MW-11A from September 2018 to March 2023. The dilution factor represents the VOC groundwater

-------
discharge attenuation in the creek. These estimated surface water concentrations were compared to their
WQC (or the MCL if no WQC exists). All estimated surface water concentrations were less than their
regulatory standards. Concentrations for cis-l,2-DCE, TCE and Vinyl Chloride have shown a slightly
decreasing trend over the past five years. The highest concentration of TCE in a well near the creek was
observed in 2019 at 75.8 |ig/L in MW-1 OB; concentrations have declined in that well since then but
have fluctuated and remained between 16.5 |ig/L and 75.8 |ig/L since 2018. Monitoring should continue
to evaluate if increasing groundwater contaminant trends could impact the creek in the future.

Table 6: Estimated Surface Water Concentration Evaluation

coc

Maximum Detections from
2018 thru 2023 Sampling
Events (from MW- 10A, MW-

10B or MW-1 IB) (p.g/L)

Dilution
Factor11

Estimated Surface Water
Concentration (jig/L)h

Current
WQC
(Hg/L)

Cis-1,2-DCE

76.1 (MW-1 1A) - 9/20/2018

0.001

0.0761

70e

TCE

75.8 (MW-10B) - 9-19-2019

0.001

0.0758

0.6

Vinyl chloride

2.2 (MW-1 OA) - 9/19/2019

0.001

0.0022

0.022

Notes:

a. Dilution factor from Section 2.3 of the 2004 Remedial System Evaluation and Final Action Plan.

b. Estimated surface water concentration = maximum detection x dilution factor.

c. WQC (human health for the consumption of water + organism) accessed at https://www.epa.gov/wqc/national-
recoiiiiiiended-water-aualitv-criteria-hiiman-health-criteria-table. Last accessed October 27, 2022.

d. MCL used instead of the WQC because the WQC not available for the contaminant.

Hg/L = micrograms per liter

Site Inspection

The site inspection took place on November 17, 2022. In attendance were Jeff Ahrens (Geosyntec), and
Chris Slocum, Sara MacDonald, Benjamin Bair, Timothy Kadar (SCDHEC). The purpose was to assess
the protectiveness of the remedy. For a full list of site inspection activities, see the Site Inspection
Checklist in Appendix G.

The site inspection began with a tour of OU-1 - the former groundwater treatment building; this system
is no longer used. Access to the area is controlled with a perimeter chain-link fence, locked gate and the
building's doors are also locked. The fence has a "no trespassing" sign and a sign identifying the Site as
a Superfund site. There was no evidence of trespassing in this area. The group also visited Fishing Creek
at the northeastern part of the Site (near MW-1 OA and MW-10B). The monitoring wells in this area are
in good condition.

The adjacent Savannah Springs Farm Hunt Club property is located south of treatment building. The
hunting club cabin burned down approximately 8 to 10 years ago; the club has since rebuilt and
currently has at least three structures on their property with a fourth one under construction. The RVs of
several hunting club members were parked adjacent to the Site, and two of their buildings are in this
area. One is raised about 15 feet off the ground, and one is on the ground behind the raised building. The
third building is northeast of this area and is used for storage and hunting-related purposes. The hunting
club has a no trespassing sign and a gate at Morrison Road that limits access.

-------
SCDHEC visited the Site's information repository at the Lancaster County libraries. The Lancaster
County Library (Library) has changed location within the past 5 years. The Site's Administrative Record
(AR) was lost during the move. The Library requested that the AR be kept online at an EPA website.
The Library can then provide access via the publicly available computers on site and the website link.

SCDHEC visited the Fort Lawn Community Center, and they were receptive to holding the Site's AR at
the Community Center. The closest library to the Site is the Great Falls Library located at 39 Calhoun
Street, Great Falls, Chester County, SC 29055.

V. TECHNICAL ASSESSMENT

QUESTION A: Is the remedy functioning as intended by the decision documents9
Question A Summary:

A review of documents, ARARs, risk assumptions and the site inspection indicate that the Site's remedy
is functioning as intended.

OH-1

The OU-1 remedy is partially functioning as intended. Removal actions addressed contaminated soil for
OU-1. The GWETS operated from 1996 to 2004 and treated millions of gallons of groundwater.
However, the system as operated was predicted to be unable to reach MCLs in a timely manner. The
E1SB and SVE pilot studies both reduced contaminant mass, but VOC contamination in groundwater
persists. The CSC completed the revised FFS in 2016 and an FFS-R2 in 2019. The EPA, SCDHEC and
CSC are currently working together to evaluate a final remedy to address residual groundwater
contamination. After the EPA has an opportunity to solicit input from the community, the EPA will
modify the decision document and formally require the new remedy.

Groundwater data currently indicate that there are no impacts to surface water in Fishing Creek above
WQC. However, monitoring should continue to evaluate if increasing groundwater contaminant trends
could impact the creek in the future. The 1989 ROD required institutional controls, which have not been
implemented due to the lack of a viable property owner. The institutional controls are in draft form and
will be recorded once there is a viable owner. Groundwater contamination also extends beyond the site
boundary, but there are no known uses of this groundwater. The EPA is working with SCDHEC and
CSC to implement institutional controls restricting groundwater use on properties where groundwater
contamination is present.

OU-2

The OlJ-2 no action remedy is functioning as intended. A supplemental Human Health Risk Assessment
(HHRA) conducted as part of the 2019 FFS-R2 indicates there are potential risks to human health if
unrestricted land use is permitted (based on soil exposure). The HHRA supports the use of ICs to restrict
land use to protect human health. See Question B for more detail.

QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels and RAOs used at the time
of the remedy selection still valid9

-------
Question 6 Summary:

The RAOs of preventing human exposure to contaminated groundwater, restoring the contaminated
aquifer, preventing migration of contaminated groundwater to Fishing Creek remain valid. The COCs
used to monitor groundwater to evaluate remedial effectiveness and the absence of soil contamination
posing a risk to human health in OU-2 have changed.

The 2018 FYR Report stated that 1,4-dioxane was historically used as a stabilizer for 1,1,1 -TCA and
recommended including 1,4-dioxane in a future monitoring event. The 2019 supplemental HHRA found
potential human health risks if the potable use of OU-1 (Sitewide) groundwater is permitted and if
unrestricted land use is permitted at OlJ-2. The HHRA conclusions recommended revising the COC list
to include vinyl chloride, 1,2-DC A, and PCE. The results support the use of ICs at the Site to restrict
groundwater and land uses to protect human health.

OU-1

This FYR evaluated the validity of the Site's groundwater cleanup goals; the goals were based on
proposed or established MCLs, except for acetone. MCLs used for groundwater cleanup goals all remain
the same or less stringent than those selected in the 1989 ROD. See Appendix H for the full ARAR
evaluation. The protectiveness of the acetone groundwater cleanup goal was evaluated using a
screening-level risk evaluation conducted by comparing the cleanup goal to the EPA's residential
tapwater regional screening level (RSL). See the full screening-level risk evaluation in Appendix I.
Based on these evaluations, the groundwater cleanup goals set in the 1989 ROD remain valid.

Groundwater contaminants at the Site are considered volatile. A 2018 Vapor Intrusion Risk Evaluation
was conducted as part of the Fifth FYR. The onsite GWETS building is inactive. The adjacent Savannah
Springs Farm hunting club has several buildings near the Site for storage and deer hunting related
purposes. Deer hunting season for Chester County (Game Zone 2) runs 108 days with archery only from
September 15-30, primitive weapons from October 1 -10, and gun hunts from October 1 1 to January 1.
The 2018 Vapor Intrusion Risk Evaluation calculated the potential vapor intrusion risks based on
conservative estimates using the EPA's Vapor Intrusion Screening Level Calculator. Commercial land
use (i.e., 250 days of exposure per year with eight hours of exposure per day) was assumed for a
hunter's exposure for structures near MW-13. The exact use of the storage building near MW-8 was
uncertain at the time of the vapor intrusion evaluation. To be conservative, residential land use (i.e., 350
days per year and 24 hours of exposure per day) was assumed for the storage building. No unacceptable
risk was determined for any structure in the 2018 Vapor Intrusion Risk Evaluation. The COCs
concentrations have continued to decrease in MW-8 and MW-13. Site conditions are unchanged at the
Savannah Springs Farm hunting club. If additional buildings are built over volatile groundwater
contamination, the vapor intrusion exposure pathway should be further evaluated, and risk should be
mitigated as needed.

The 1989 ROD stated that the rate and level of discharge of contaminants with the groundwater into
Fishing Creek would not surpass the AWQC for the COCs. Several AWQC have become more or less
stringent since the 1989 ROD (Appendix I). As part of the original Rl/FS, an endangerment assessment
was conducted to quantify the threat posed to Fishing Creek by Site groundwater. Based on the dilution
factor for groundwater discharging to Fishing Creek, the low groundwater flow velocity and the level of
contaminants detected at the Site, the endangerment assessment conducted during the Rl/FS indicated
that Site groundwater has no adverse effects on Fishing Creek under pre-remedial conditions. Maximum
groundwater VOC concentrations at the Site have decreased substantially since issuance of the ROD.

-------
While reductive dechlorination of chlorinated compounds is occurring, concentrations of daughter
products such as VC have occasionally been detected in wells near Fishing Creek. In October 2014, VC
was detected in MW-11A (a downgradient well adjacent to Fishing Creek) at a concentration of 9 (.ig/L,
which represents the highest detection of VC in a well located adjacent to Fishing Creek. Applying the
dilution factor for estimation of the V OC groundwater discharge attenuation in Fishing Creek as
described in Section 2.3 of the Remedial System Evaluation and Final Action Plan (9.0 (.ig/L x (0.001) =
0.009 (.ig/L) then this calculated theoretical concentration would not exceed the current EPA water
quality criterion for VC (human health-water and organism) of 0.022 (.ig/L. VC concentrations in this
well have since decreased below detection limits. Applying the established dilution factor from the
Action Plan, the maximum detected concentrations of TCE, 1,2-DCE and 1,1-DCE at the Site in
March 2023, are significantly below the concentrations which are estimated to result in an exceedance of
AWQCs in Fishing Creek if the well was located near Fishing Creek. In many cases, the highest
detections of VOCs are located in the vicinity of the former source area (ex. the highest detection of
TCE in March 2023 was 44.5 (.ig/L in MW-13), which is located over 800 ft from Fishing Creek.
Monitoring should continue to evaluate if increasing groundwater contaminant trends could impact the
creek in the future. Long-term monitoring should use current AWQC- when evaluating impacts to
surface water.

OU-2

This FYR also evaluated the validity of the toxicity information used to select the Site's OlJ-2 no action
remedy. The historical maximum contaminant concentrations in soil and sediment were evaluated using
a screening-level risk evaluation conducted by comparing the samples' concentrations to the EPA's
current residential soil RSLs. Except for lead, hexavalent chromium, and polychlorinated biphenyl
(PCB)-1254, the maximum detected concentrations of contaminants in soil are within the EPA's
acceptable risk range for cancer risk and below an HQ of 1 for n on cancer risk. Though the maximum
detection of lead at 430 mg/kg exceeds the residential RSL, the average lead surface soil concentration
was well below the RSL, indicating that unacceptable exposure risk from lead is unlikely. Maximum
concentrations of hexavalent chromium and PCB-1254 exceeded residential RSLs and therefore do not
allow for UU/UE. However, this screening is conservative because use of maximum concentrations and
residential exposure assumptions in the assessment may overestimate risk. There is minimal potential
exposure, as this site area is only used by hunters, and a recreational receptor is assumed to be on site
less frequently and for a shorter duration than is assumed in the residential soil RSLs. However, to
ensure long-term protectiveness, institutional controls are needed for soil in OlJ-2. See the full
screening-level risk evaluation in Appendix J.

QUESTION C : Has any other information come to light that could call into question the protectiveness
of the remedy9

No other information has come to light that could call into question the protectiveness of the remedy.

-------
VI. ISSUES/RECOMMENDATIONS

Table 5 includes the issues and recommendations from the 2018 FYR. As the status of the
recommendations are ongoing, the issues were modified and regrouped to better articulate
the recommendations.

Issiies/Reconimendsilions

OU(s) without Issues/Recommendations Identified in the FYR:

None

Issues and Recommendations Identified in the FYR:

OU(s): OU-1

Issue Category: Remedy Performance

Issue: The GWETS is no longer operating due to its estimated timeframe required to
meet MCLs, but a new groundwater remedy is not yet in place. Not all currently
sampled VOCs that exceed MCLs were selected as COCs in the original remedy.

Recommendation: Select and implement a new groundwater remedy. Record the
selected remedy in a decision document. Include all appropriate COCs and cleanup
goals in the decision document.

Affect Current
Protecti veil ess

Affect Future
Protectiveness

Party
Responsible

Oversight Party

Milestone Date

No

Yes

EPA

EPA

7/3/2028

OU(s): OU-1

Issue Category: Monitoring

Issue: The 1989 ROD identified 1.1.1 -TCA as a COC. and 1.4-dioxane was
historically used as a stabilizer for 1.1.1 -TCA. It is unknown if 1.4-dioxane is present
in site media.

Recommendation: Sample for 1.4-dioxane in groundwater and take additional action
if necessary.

Affect Current
Protecti veil ess

Affect Future
Protectiveness

Party
Responsible

Oversight Party

Milestone Date

No

Yes

PRP

EPA

9/30/2024

OU(s): OU-1

Issue Category: Institutional Controls

Issue: The 1989 ROD required institutional controls which have not been
implemented.

Recommendation: To prevent exposure to contaminated groundwater, restrict
groundwater use on properties where concentrations are above the safe drinking
water levels.

Affect Current
Protecti veil ess

Affect Future
Protectiveness

Party
Responsible

Oversight Party

Milestone Date

No

Yes

EPA/State/PRP

EPA

7/3/2028

18

-------
OU(s): OU-1
and OU-2

Issue Category: Institutional Controls

Issue: Soil contamination, specifically chromium and PCB-1254, concentrations
exceeded residential RSLs and may not allow residential use.

Recommendation: Modify the decision document to require ICs that restrict land
use at the Site and implement ICs.

Affect Current
Protectiveness

Affect Future
Protectiveness

Party
Responsible

Oversight Party

Milestone Date

Yes

EPA/State/PRP

EPA

7/3/2028

OTHFR FINDINGS

No additional recommendation was identified during the FYR. This recommendation does not affect
current or future protectiveness.

VII. PROTECTIVENESS STATEMENT

Prolecliveness Slatciiicnt(s)

Operable Unit: Protectiveness Determination:

OU-1 Short-term Protective

Protectiveness Statement:

• Sample for 1.4-dioxane in groundw ater and take additional action if necessary.

• Modify the decision document to include a new groundwater remedy and identify all appropriate
COCs and cleanup goals.

• Restrict groundwater use on properties where concentrations are above the safe drinking water
levels to prevent exposure to contaminated groundwater.

• Modify the decision document to require ICs that restrict land use at the Site and implement ICs.

-------
Protectiveness M;ilcmcnl(s)

Operable Unit: Protectiveness Determination:

OU-2 Short-term Protective

Protectiveness Statement:

The remedy at OU-2 is protective in the short term because historical removal actions, including
removal of contaminated soil and drums, addressed contamination in this area. For the remedy to be
protective over the long term, the follow ing action should occur:

• Modify the decision document to require ICs that restrict land use at the Site and
implement ICs.

Sitewide Protectiveness Statement

Protectiveness Determination:

Short-term Protective

Protectiveness Statement:

The remedy at OU-1 is protective in the short term because there is no complete exposure pathway to
contaminated groundw ater, and the GWETS and other pilot studies have reduced the amount and extent
of groundwater contamination. The remedy at OU-2 is protective in the short term because historical
removal actions, including removal of contaminated soil and drums, addressed contamination in this
area. For the remedy to be protective over the long term, the follow ing actions should occur:

• Sample for 1,4-dioxane in groundw ater and take additional action if necessary.

• Modify the decision document to include a new groundw ater remedy and identify all
appropriate COCs and cleanup goals.

• Restrict groundwater use on properties where concentrations are above the safe drinking water
levels to prevent exposure to contaminated groundw ater.

• Modify the decision document to require ICs that restrict land use at the Site and
implement ICs.

VIII. NEXT REVIEW

The next FYR for the Site is required five years from the completion date of this review.

-------
APPENDIX A - REFERENCE LIST

Biennial Groundwater Monitoring Report, Carol awn Superfund Site, Fort Lawn, Chester County,
South Carolina. Prepared by Geosyntec Consultants. February 2018.

Carol awn Project Status/Groundwater M odel Overview Meeting, Carol awn Superfund Site.
Prepared by the Carol awn Steering Committee for EPA Region 4 and the South Carolina
Department of Health and Environmental Control. May 2015.

Draft Final Operations and Maintenance Manual, Groundwater Remediation System, Carolawn
Site, Chester County, South Carolina. Conestoga-Rovers & Associates. February 1997.

Fourth Five-Year Review for Carolawn Superfund Site, Fort Lawn, Chester County,

South Carolina. EPA Region 4 and the South Carolina Department of Health and Environmental

Control. September 2013.

Fifth Five-Year Review for Carolawn Superfund Site, Fort Lawn, Chester County,

South Carolina. EPA Region 4 and the South Carolina Department of Health and Environmental

Control. August 2018.

Groundwater Modeling Report, Carolawn Superfund Site, Fort Lawn, Chester County,

South Carolina. Prepared by Geosyntec Consultants. September 2015.

Groundwater Sampling Technique Comparison Study Report, Carolawn Superfund Site, Fort
Lawn, Chester County, South Carolina. Prepared by Geosyntec Consultants. March 2014.

Groundwater Monitoring Report, First Half 2018 - First Half 2020, Carolawn Superfund Site,
Fort Lawn, South Carolina. Prepared by Geosyntec Consultants. June 2020.

Groundwater Monitoring Report, Second Half 2020 - Second Half 2021, Carolawn Superfund
Site, Fort Lawn, South Carolina. Prepared by Geosyntec Consultants. March 2022.

Notification of Completion of SVE System Abandonment Activities, Carolawn Superfund Site,
Fort Lawn, Chester County, South Carolina. Prepared by Geosyntec Consultants.

September 2016.

Record of Decision, Carolawn Superfund Site, Fort Lawn, Chester County, South Carolina.
EPA Region 4. September 1989.

A-l

-------
Record of Decision for the Carol awn (OU-2) Superfund Site, Fort Lawn, Chester County,

South Carolina. EPA Region 4. September 1995.

Remediation System Evaluation and Action Plan, Carol awn Superfund Site, Fort Lawn, Chester
County, South Carolina. Prepared by O'Brien & Gere Engineers, Inc. for the Carol awn Steering
Committee. August 2004.

Results from Injection Well Rehabilitation Activities and Dual Phase Extraction Tests, Carol awn
Superfund Site, Fort Lawn, South Carolina. Prepared by Geosyntec Consultants. May 2010.

Results of Soil V apor Extraction Testing at the Carol awn Superfund Site, Fort Lawn,

South Carolina. Prepared by Geosyntec Consultants. November 2010.

Revised Focused Feasibility Study, Carol awn Superfund Site, Fort Lawn, Chester County,

South Carolina. Prepared by Geosyntec Consultants. November 2016.

Revision 2 - Focused Feasibility Study, Carol awn Superfund Site, Fort Lawn, Chester County,
South Carolina. Prepared by Geosyntec Consultants. February 2019.

Soil V apor Extraction System Construction Completion Report, Carol awn Superfund Site,

Fort Lawn, South Carolina. Prepared by Geosyntec Consultants. March 2012.

SVE System Status Report - 28 March 2014 Through 26 June 2014, Carol awn Superfund Site,
Fort Lawn, South Carolina. Prepared by Geosyntec Consultants. August 2014.

V apor Intrusion Pathway Memorandum for the Carol awn Superfund Site. Prepared by O'Brien
& Gere Engineers, Inc. for the Carol awn Steering Committee. April 2008.

A-2

-------
APPENDIX B - CURRENT SITE STATUS

K11 v i roil in en 1211 I ml iesi 1 ors

Current human exposures at the Site are under control.
Current groundwater migration is under control.

Arc Necessary Inslitnlion;il Controls in Place

I I All O Some ^ None

lliis KI'A Designated (lie Site sis Sitcwidc Ready lor Anticipated I so?

|D Yes El

No

I I Yes ^ No

I his (lie Silo Keen Put into Uense.

B-l

-------
APPENDIX C - SITE CHRONOLOGY

Event

Date

Solvents/waste storage facility first operated on site

1970

Initial operations to dispose of the inert waste from about 2,000 drums

1975

Permit issued by SCDHEC for one-time disposal of 300 to 400 drums

with inert waste

1978

Site abandoned by the Carolawn Company

1980

Site investigation conducted by the EPA and SCDHEC indicated
contamination on the Site and in nearby residential wells

1980

The EPA initiated first removal activitv at the Site

December 1981

The EPA completed first removal action at the Site

February 1982

The EPA proposed the Site for listing on the NPL

December 1982

The EPA listed the Site on the NPL and the PRPs started the OU-1 RI/FS

September 1983

Four nearbv residences connected to an alternative water supplv

1985

PRPs entered an AOC to remove 17 storage tanks from the Site and
dispose of waste content at an incinerator

May 1985

Second and third removal actions began

September 1985

Second and third removal actions completed

February 1986

Fourth removal action began

Mav 1986

Fourth removal action completed

June 1986

PRPs completed the OU-1 RI/FS pursuant to a Consent Decree and the
EPA signed the OU-1 ROD (groundwater remedy)

September 1989

OU-1 remedial action initiated

May 1993

EPA started the OU-2 RI/FS

April 1994

OU-2 RI/FS completed, and the EPA signed the OU-2 ROD (no further action remedy for the
area outside of the fence - soils, surface water and
sediment in Fishing Creek)

September 1995

GVVETS installed

1995-1996

The EPA issued a UAO to PRPs for O&M and monitoring

Julv 1997

Construction completion

May 1998

The EPA issued the Site's first FYR Report

August 1998

OU-1 remedial action completed

May 1999

The EPA issued the Site's second FYR Report

August 2003

With the EPA and SCDHEC approval, the GWETS was shut down as
part of planned EISB pilot study treatment activities

July 2004

Completion of EISB treatment, consisting of injection of soy-oil based

product

May 2005

The EPA issued the Site's third FYR Report

September 2008

The EPA issued a modified U AO that specified the requirement that an

FFS be completed to identify a groundwater remedial action more effective than the GWETS

March 2009

PRP completed construction of the SVE system

January 2012

The EPA issued the Site's fourth FYR Report

September 2013

SVE system shutdown

June 2014

SVE system removed

Julv 2016

CSC submitted revised FFS Report

November 2016

The EPA issued the Site's fifth FYR Report

August 2018

CSC submitted FFS - Revision 2 for OU-1

Februarv 2019

Groundwater Monitoring Report First Half 2018 - First Half 2020

June 2020

C-l

-------
APPENDIX D - PRESS NOTICE/INTERVIEW FORMS

EPA to Review Cleanups at 45 Southeast Superfund Sites

Contact Information: reqion4press@epa.gov. 404-562-8400

ATLANTA (Oct. 19, 2022) - Today, the U.S. Environmental Protection Agency (EPA) announced that
comprehensive reviews will be conducted of completed cleanup work at 45 National Priority List (NPL) Superfund
sites in the Southeast.

The sites, located in Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, and
Tennessee, will undergo a legally required Five-Year Review to ensure that previous remediation efforts at the
sites continue to protect public health and the environment.

"The Southeast Region will benefit tremendously from the full restoration of Superfund sites, which can become
valuable parts of the community landscape," said EPA Region 4 Administrator Daniel Blackmon. "The Five-
Year Review evaluations ensure that remedies put in place to protect public health remain effective overtime."

The Superfund Sites where EPA will conduct Five-Year Reviews in 2022 are listed below. The web links provide
detailed information on site status as well as past assessment and cleanup activity. Once the Five-Year Review is
complete, its findings will be posted in a final report at https://www.epa.gov/superfund/search-superfund-five-vear-
reviews.

Alabama

Alabama Army Ammunition Plant https://www.epa.gov/superfund/alabama-army-ammunition-plant
Alabama Plating Company, Inc. https://www.epa.gov/superfund/alabama-platinq-co
Mowbray Engineering Co. https://www.epa.gov/superfund/mowbrav-enqineerinq
US NASA Marshall Space Flight Center

US Army/NASA Redstone Arsenal https://www.epa.oov/superfund/redstone-aresenal
Florida

ALARIC Area GW Plume https://www.epa.gov/superfund/alaric-area-qroundwater-plume
Beulah Landfill https:/7www.epa.gov/superfund/beulah-landfill

Chevron Chemical Co. (Ortho Division) https://www.epa.gov/superfund/chevron-chemical-companv

Florida Petroleum Reprocessors https://www.epa.gov/superfund/florida-petroleum-reprocessors

Miami Drum Services https://www.epa.gov/supeifund/miami-drum-services

Pensacola Naval Air Station https://www.epa.gov/superfund/naval-air-station-pensacola

Raleigh Street Dump https://www.epa.gov/superfund/raleigh-street-dump

Taylor Road Landfill https://www.epa.gov/superfund/tavlor-road-landfill

Tower Chemical Co. https://www.epa.gov/superfund/tower-chemical-companv

D-l

-------
Georgia

Alternate Energy Resources Inc. https://www.epa.aov/superfund/alternate-enerav-resources

Peach Orchard & Nutrition Co. Rd PCE Groundwater Plume Site https://www.epa.gov/superfund/peach-orchard-

road-pce-plume

Powersville Site https://www.epa.gov/superfund/powersville-site

T.H. Agriculture & Nutrition Co (Albany Plant) https://www.epa.aov/superfund/t-h-agriculture
Kentucky

A.L. Taylor (Valley of the Drums) https://www.epa.gov/superfund/al-tavlor-vallev-of-drums
Brantley Landfill https://www.epa.gov/superfund/brantlev-landfill

Distler Brickyard https://www.epa.gov/superfund/distler-brickvard

Distler Farm https://www.epa.gov/superfun https://www.epa.gov/superfund/lee-lane-landfilld/distler-farm
Lee's Lane Landfill https://www.epa.gov/superfund/lee-lane-landfill

National Electric Coil Co /Cooper Industries https://www.epa.gov/superfund/national-electric-coil-cooper-industries
Tri City Disposal Co. https://www.epa.gov/superfund/tri-citv-disposal

North Carolina

ABC One Hour Cleaners https://www.epa.gov/superfund/abc-one-hour-cleaners

Aberdeen Pesticide Dumps https://www.epa.gov/superfund/aberdeen-contaminated-groundwater

Benfield Industries, Inc. https://www.epa.gov/superfund/benfield-industries

Cherry Point Marine Corps Air Station https://www.epa.gov/superfund/cherrv-point-marine-corps

CTS of Ashville, Inc. https://www.epa.gov/superfund/cts-millsgap

GEIGY Chemical Corp (Aberdeen Plant) https://www.epa.gov/superfund/ciba-geigy-corporation
Gurley Pesticide Burial https://www.epa.gov/superfund/gurlev-pesticide-burial

North Carolina State University (Lot 86, Farm Unit #1) https://www.epa.gov/superfund/north-carolina-state-
universitv

Sigmon's Septic Tank Service https://www.epa.gov/superfund/sigmon-septic-tank

South Carolina

Admiral Home Appliances https://www.epa.gov/superfund/admiral-home-appliances

Beau nit Corp (Circular Knit & Dyeing Plant) https://www.epa.gov/superfund/beaunit

Carolawn Inc. https://www.epa.gov/superfund/carolawn

Elmore Waste Disposal htt ps ://www. e pa. g o v/s u pe rfu n d/e I mo re-waste-d is posa I

International Minerals and Chemicals (IMC) https://www.epa.gov/superfund/imc

Kalama Specialty Chemicals https://www.epa.gov/superfund/kalama-specialtv-chemicals

Koppers Company, Inc. (Charleston Plant) https://www.epa.gov/superfund/koppers-charleston-plant

Savannah River Site (USDOE) htt ps ://www. e pa. g o v/s u pe rfu nd/sa va n n a h- ri ve r-s ite

SCRDI Bluff Road https://www.epa.gov/superfund/scndi-bluff-road

Tennessee

Mallory Capacitor Co. https://www.epa.gov/superfund/mallorv-capacitor

Memphis Defense Depot (DLA) https://www.epa.gov/superfund/memphis-defense-depot

Background

Throughout the process of designing and constructing a cleanup at a hazardous waste site, EPA's primary goal is
to make sure the remedy will be protective of public health and the environment. At many sites, where the remedy
has been constructed, EPA continues to ensure it remains protective by requiring reviews of cleanups every five
years. It is important for EPA to regularly check on these sites to ensure the remedy is working properly. These

D-2

-------
reviews identify issues (if any) that may affect the protectiveness of the completed remedy and, if necessary,
recommend action(s) necessary to address them.

There are many phases of the Superfund cleanup process including considering future use and redevelopment at
sites and conducting post cleanup monitoring of sites. EPA must ensure the remedy is protective of public health
and the environment and any redevelopment will uphold the protectiveness of the remedy into the future.

The Superfund program, a federal program established by Congress in 1980, investigates and cleans up the most
complex, uncontrolled or abandoned hazardous waste sites in the country and endeavors to facilitate activities to
return them to productive use. In total, there are more than 280 Superfund sites across the Southeast.

More information:

EPA's Superfund program: https://www.epa.gov/superfund

D-3

-------
INTERVIEW FORM FOR FIVE-YEAR REVIEW

Site Nam: Carolawn, Inc. Siiperftmi Site

Interviewer's Name: Timothy Kadar	Affiliation: SCDHEC

Interviewee's Nine: Chris Slocum	Affiliation: SCDHEC, Federal Remediation

Project Manager

Contact Info:	SCUH1C

2
-------
activities fivm residents in the past five years.

4.	Has your office cm,ducted any site-related activities or communications in tie past fee- years? If so,
please describe Hie purpose and results of these activities.

DHEC km participated in multiple sits visits, meetings, ami conference cslls with EPA, the PEP
contractor, and the PRP group, DHEC regularly reviews groundwater monitoring reports ami ether
technical documents submitted by the PRP cartrmim" and provides written cmmtmis as appropriate.
The purpose of DHEC'spmticipatkm in site-related activities is ioprovide support to EPA.

In September 2021, DHEC received an inquiry Jhm Lancaster and Chester Railroad Company (L&C)
about a potential purchase of port «f fits site for me as a lay down yard. DHEC" participated in calk
with LAC in September 2021 and October 202J, but no additional discussions between DHEC and LAC
have been had to date.

In November 2021, DHEC received a request from Toeroek Associates, Inc. to complete an interview
form rewording the Site, Toeroek was working with EPA Region 4 to perform interviews with officials
md community members with Mowleigs of the Site. The interviews were intended to evaluate the
remedjy ami work thai was put in place and assess community reaction to the Site. The interview form
was eompktedand returned to Toeroek m November 38, 2021.

5.	Are yon aware of any changes to state laws fiat might iffect tbe pnrtectiveness of the Site's remedy?

Irt Mbj,' 2022, legislation (SCH4999) was passed regarding the implementation of site-specific cleanup
gm,b. The SCDHEC is currently working towards determining bow hesi to implement that on affected
sites,

6.	Are you comfortable with the status of the institutional controls at tfte Site? If not, what axe the
associated outstanding issues?

Deed restrictions is prohibit groundwater use wen drafted: in 2015 but have not been finalized dee to
the lack of a viable property owner. The restrictions am necessary to prevent any future human health
msk Ate to exposure to contaminated groundwater. Tbe Sits is currency undeveloped md groundwater
at the Site is not being used for residential purposes, ami them is currently minimal risk of human
exposure to contaminated gtmmiwaler mi ike Site, However, institutional controls restricting
groundwater me am necessary to ensure lemg-temt protecfiveness of the remedy.

7.	Are you aware of any changes in projected land tise(s} at the Site?

1 em not aware of any changes in projected land use(s) at the Site,

8.	Do yon have any comments, suggestions or recommendations regarcfiiig fie management or operation
of file Site's remedy?

As discussed in responses to previous questions, DHEC, EPA, the PSP group, and the PSP contractor
should continue discussing the proposed change of Ifcf groundwater remedy. Institutional controls Iff dm
form of land use restrictions ft am been drafted but have itot bec*i implemented due to ike lack of a
viable property owner. Institutional controls restricting groundwater is# am necessary to ensure long-
term protectiwness of the remedy.

D-5

-------
ESTIERVIEW FOSM FOE FTVTE-YEAR REVIEW

Site Name: Cafolawn, Inc Superfund Site

Inteniewer's Name: Timothy Kadar	Affiliation: SCDHEC

Interviewee's Name: Jeff Atoms, P.E.jsq	Affiliation: Geosyntec Consultants

Contact Info: 13QQ South. Mint Street, Suite 30(1
Charlotte. NC 28203
(704) 227-0850
j afcrejB@gras5ntec.coo1

Type of Interview: Email

Date; February 2. 2023

1. What is your overall impression of the project, including cleanup,,, maintenance, and tease activities
(as appropriate)?

Overall, groundwater monitoring data suggest that concentrations of Site-specific constituents of
concern (COCs) in groundwater are generally stable or decreasing, and this data supports that monitofed
natiml attenuation (MNA), following prior soil. vapor exlraction (SVE) activities, is effectively addressing
COCs 'in groundwater at the Site, Former soiree area monitoring, wdls which historically had the highest
concentrations of TOE at the Site (MW-05, MW-06 and MW-12) have shown greater than an order of
magnitude reduction in VOC concentrations since the startup of the SVE system in 2011,. TCE
concentrations in MW-05 mi MW-12 have decreased to concentrations below die MCL (5 p.gC) and
af MW-06, TCE lias reduced from 1,230 fig.*!, to 40.4 pg/L from Marcli 2011 to September 2022. Cis-
1,2-DCE concentrations haw reduced to concentrations below the MCL (70 p§fL) in each. Site
inonftctring weBL -except for MW-16. In monitoring wells located near Pishing Creek, both TCE and
eis-O-DCE are reported Mow the MCL at MW-1QA, MW-11A and MW-llB in. Sqrtember 202.2,
with TCE present at a concentration of 39.5 pg/L in MW-lffi, which represents an approximate 3-fold
decrease since 2011.

'The SVE system (conducted as an Interim Remedial Measure) proved to be an effective means of VOC
source mass removal, at tie Site and proved to be a more effective remedial measure thanthe previously
operated groundwater pump and treat system which was .shut down with, regulatory approval in 2004.
Approximately 160 pounds, (lbs) of VOCs were removed daring tie period 01 SVE system operation
(January 2012" through lime 2014); for comparison, the groundwater extraction and treatment system
(GWETS) removed apposnMely 35 lbs of VOCs during its 7.5 years of operation. As is typical, the
mass removal rate of the SVE system decreased with time doe to the ongoing redaction of VOC mass
in the vadose zone, ami for that season, SVE system, operations woe ceased and the system was
subsequently abandoned in 2016 with caD.curreo.ce from EPA.

The removal of VOCs from the vadose zone in the fanner source area by the SVE system has and will
continue to result in improvements to groundwater quality over time as source depletion reduced VOC*
mass flux into the groundwater. Following source mass removal, the observed tends over the last five

D-6

-------
yens of groundwater miMtering indicate that natural attenuation processes also serve an important
function in meeting ARARs at tie Site,

2. What is your assessment of the current performance of the remedy in place at ttie Site'1

The current remedy for flic Site, as stated in. the ROD, is groundwater extortion anil treatment. However,
with Agency approval, the GWETS system was shut down in. 2004, and alter a series of interim remedial
measures (KM), the site lias been in nHmitoied natural attenuation (MNA) since mid-2014. Monitoring
data collected during this five-year review period (2018 through 2CI22) indicate (hat COCs in groundwater
arc attenuating naturally.

The GWETS system was installed in 1996 and operated from. 1996 to 2004 at a cost of $2.1 million. This
system removed approximately 35 lbs ofVOCs over the 7.5 years of operation. The Carolawn PEP Group,
with Agency Oversight, has volratarily ronducted a series of interim remedial measures to forfber reduce
source mass and promote natural attenuation of COCs remaining m groundwater. Enhanced in-situ
biological treatment was convicted in. 'flic former source area from 2004 to 2011 at a cost of $2.2 million.
While successful -in treating groundwater in dose proximity to tie injection points, tfie radius of influence
was 'limited by site specific characteristics. As a final interim remedial measure, the PIP Gimp installed
and operated an. SVE system to treat impacted soils in the former source area. The system was installed
in 2012 .and operated for approximately 30 months at i cost of $750,000. He SVE system removed
approximately 160 lbs ofVOCs Airing the. period of operation. (January 2012 trough Jme 2014). Since
miit-2014, the PIP Group has spent smuttier $850,000 to conduct groundwater monitoring and. reporting,
facility maintenance, conduct Agency-requested fate aid. transport modding. meet with the Agencies, ini.
prepare two revisions of the. Focused Feasibility Study.

In conjunction with the observation that COC concentations in groundwater are generally staMe or
decreasing, the. ETC system appears to have ten an effective Interim Remedial Measure CRM). As
indicated in the Focused Feasibility Study Report (FFS-R2) (completed in February 2019), on-going
groundwater monitoring acfriti.es support that monitored attenuation would provide the most effective
overall protection of human health and environment and provide compliance with ARARs. MNA is
supported by reducing concentrations of VOCs in individual wells, an overall reduction in the plume
footprint with time, and evidence of intrinsic biodegradation of VOCs (mctading 'the presence of
daughter products, as well as methane and ethene production). Additionally,, groundwater flow and
transport modeling; evaluations and first-order decay analysis presented in the March 2022 Biennial
Groundwater Monitoring 'Report showed (hat TCE and DCE present in. groimiwater near Fishing Creek
are expected to attenuate to concentrations below their respective MCL within .an approximate 30-year"
timeframe (and it is noted that some wells have already shown redactions ofVOCs. to Wow MCLs at
rales faster than the model predicted timeframes). Am MNA remedy received the highest ranking amongst
remedial alternatives in tie RFFS (ranking highest amongst comparable alternatives in overall
proteetiveness of human health and tie environment; compliance with regulatory requirements; long-
term effectiveness and performance; reduction in toxicity, mobility and volume; short-term effectiveness;
implenientabflily; cost; and suslainability and is Gcosyitfec*s recoiuiiieiiiei alternative to consider in
modifying the 1989 ROD..

D-7

-------
3. Are you aware of any complaints or inquiries regarding site-related envireimieiiial issues or remedial
activities from, residents in the past five years?

No.

4.	What is tie frequency of Operation and Maintenance activities and site inspections'? To your
knowledge, lias the maintenance been implemented at the site?

The Site is inspected on a, monthly basis "by Geosyntec staff Inspection activities include observation
of the general ctrndition of the facility and security of the building and equipment. Additionally, bi-
weekly lawn maintenance is conducted daring the growing season, Groundwater sampling activities
occur on a semi-annual basis, typically in March and September of each year, witti reporting on a biennial
basis. He next Biennial Groundwater Mouitoiing Report is due in early 2034.

5.	Are yon aware of any changes in projected- land at the Site"1'

No.

6 Do you have any comments, suggestions or recommendations regarding the management or operation
of tie Site's remedy?

As discussed above, significant remedial progress has teen, achieved at the Site during toe past five years,
particularly with respect to tie SVE system's removal of COC source mass from iie vadose zone (Le.,
its fsnsmy objective as a voluntary MM), This COC removal in turn resulted in reducing the COC' flux
to fifae groundwater and lias undoubtedly contributed to tie observed decreasing groundwater COC

concentration tends. Based on the removal of COC source mass and current groundwater treads,
observed at the Site, Geosvntec, on behalf of tie perfonning PRPs, urges USEPA to modify tie WW
ROD, and formally select MNA as tie remedy for the Site. Geosyntec stand ready to assist USEPA in
preparing the necessary documentation.

cc: King & Spalding for the PRP Group
SCDHEC

D-8

-------
APPENDIX E - GROUNDWATER MONITORING FIGURES

E-l

-------
2 IW-5

;o]"W-7

EEJKD —**

srvice Layer Credits: Source. Esri, DigitalGlobe.
|oEye, Earthstar Geographies, CNES,'Airbus DS,
IDA, USGS.'vAeroGRID, IGN, and the GIS User

Legend

Property Line
Fence Line

Wells

Extraction Well
Injection Well
Monitoring Well
Abandoned Well

Notes

1. Former extraction wells EW-3R and EW-5 were converted to
injection wells. Former extraction wells EW-2 and EW-3 were
converted to monitoring wells.

WELL LOCATION MAP

Carolawn Superfund Site

5093 Morrison Road
Fort Lawn. South Carolina

Fenced area and property boundary locations were provided by
O'Brien and Gere.

Monitoring well locations surveyed by Schneider Corp. July 2014,
or provided by O'Brien and Gere from previous survey.

Geosyntec^

consultants

Figure E-1

World Imagery Source: Esri, DigitalGlobe, GeoEye, i-cubed, USDA,
USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS
User Community.

Charlotte, North Carolina

Figure E-1: Well Location Map

E-2

-------


n.'»?ni4

1230.0

1^7014

1100.0

:VSv»l2

9.'iv/2nr2

3129:'2013

»15':0lb

.¦

lOftigftOU



»'w;ais

¦V2SV2011

OT5Q016

' '

9!~26r20P







vsmm*

.vara:!!



X'XSSH'



xX-38--Oil

3.QC01I

srea-'aiii

»'3yam i

3-2K202



"r ¦ ¦;

3-ia^jr-



...¦: ' i

Legend

Property Line
Fence Line

#	Injection Well		... ,

TCE = Trichloroethene (MCL = 5 |jg/L)

Cis-1,2-DCE = Cis-1,2-Dichloroethene (MCL = 70 pg/L)

ND = Non-Detect

Notes

1.	Concentrations above the Maximum Contaminant Level (MCL) are
bold and highlighted.

2.	Where duplicate samples were taken, the higher of the two values is shown.

3.	September 2018 data not shown.

4.	(jg/'L indicates micrograms per liter.

*	IW-14 was mistakenly sampled in place of MW-13 on these dates.

These data were misattributed to MW-13 in some previous reports.

" MW-12 was abandoned in March 2020 due to well damages



~.



jCfr'itll?

Abandoned Well

•jcv;ui6

-rai/211'

jQuO)17

wxm?

:

T". ' "

'

rvnwron

M.'W2J1M

Carolawn Superfund Site
Fort Lawn, South Carolina

¦V18f202f1

¦j/21 '2020

3.-232021

Geosyntec^

consultants

'i 'if •

»lfr3722

Figure E-2

Sb' Hi.'2r22



April 2023

Charlotte, North Carolina

Figure E-2: Concentration of Detected TCE and C,is-1,2-DCE in Groundwater (2011-2023)

E-3

-------
Figure E-3

Figure E-3: TCE Isoconcentration Contour Map (March 2023)



TCE ISOCONCENTRATION CONTOUR MAP
March 2023

Carolawn Superfund Site
Fort Lawn, South Carolina

Geosyntec^

consultants

Charlotte, North Carolina

April 2023

TCE Isoconcentration Contour

(dashed where inferred)

Notes

TCE = Trichloroethene

USEPA Maximum Contaminant Level for TCE is 5 ^g/L.

USEPA = United States Environmental Protection Agency.
Concentration values are presented in micrograms per liter (ug/L).
J indicates an estimated concentration.

Legend

Property Line
Fence Line

® Monitoring Well

-------
mpm
ms

Service Layer Credits: Source: Esri, Maxar, GeoEVe; I
Earthstar Geographies. CNES/Airbus DS, USDA. USGS, f
AeroGRID, IGN, and the GIS User Community	*

Legend

Property Line Monitoring Well
Fence Line

Cis-1,2-DCE Isoconcentration Contour
Notes

DCE = Dichloroethene

USEPA Maximum Contaminant Level for Cis-1,2-DCE is 70 pg/L.
USEPA = United States Environmental Protection Agency.
iConcentratio^valiJ^s^re^resentedjnjTW

CIS-1,2-DCE ISOCONCENTRATION CONTOUR MAP
March 2023

Carolawn Superfund Site
Fort Lawn. South Carolina

Geosyntec^

consultants

Figure E-4

Charlotte, North Carolina

Figure E-4: Cis-/, 2-DCE Isoconcentration Contour Map (March 2023)

E-5

-------
1

¦

f ¦ V

/' , \

\

KtN
I

'



w		 , _

^ WfS.

/oa

CSB5S

	



~*fr

I

GK53 EM

SB. &3	A~-xT

	ap %				

PS»»*"-:ffiK®r!	

1

-•. £ '(MM 7

L IT * ^ / ; *

.. i- L		—a.	/

V #1

mm

''C3QS

geme !

<3®s /

m %.

kU

mm

EEWO© <3®$
¦ildDcD *

Legend

Property Line ® Monitoring Well
Fence Line

1,1-DCE Isoconcentration Contour

Notes

DCE = Dichloroethene

USEPA Maximum Contaminant Level (MCL) for 1,1-DCE is 7 ^g/L.

USEPA= United States Environmental Protection Agency.

Concentration values are presented in micrograms per liter (ug/L).
Isoconcentration contour not shown since concentrations did not exceed MCL.
J indicates an estimated concentration.

200 100 o

1,1-DCE ISOCONCENTRATION CONTOUR MAP
March 2023

Carolawn Superfund Site
Fort Lawn, South Carolina

Service Layer Credits: Source: Esri. Maxar. GeoEye.
•UEarthstar Geographies, CNES/AirbUs DS. USDA. USGS,
\aroGRiD, IGN, and the GIS User Community

Figure E-5

Figure E-5: 1,1 -DCE Isoconcentration Contour Map (March 2023)

E-6

-------
mm

mmn

S0OJ3®

Service Layer Credits Source' E$ri.	GeoEye

E&rthstai Geographies. CNESrAfrbus DS. USOA. USGS,
AeroGftID, IGN. and the GlS User CcJnrmmity

Legend

Property Line	<§> Injection Well

Fence Line	^ Monitoring Well

Groundwater Potenbometnc Surface Contour $$ Abandoned Well
(dashed where inferred)

Interpreted Groundwater Flow Direction

GROUNDWATER POTENTIOMETRIC
SURFACE AND FLOW MAP
1 March 2023

Carofawn Superfund Site
Fort Lawn. South Carolina

Notes

1	Groundwater etevations in feet above sea level North AmencanVertical Datum 1988

2	IW-3 has not been located since March 2017 and was not measured.

3. MW-17 water level does not represent static conditions and was excluded from the contours

syntec

nnsultants

Figure E-6

Figure E-6: Groundwater Potentiometric Surface and Flow Map (March 2023)

E-7

-------
<1)
O
c
o
o

MW-6 Primary COC Concentrations after GWETS Shutdown

10000

1000

— 100

E

o
15

10

0.1





SVE
/~ Shutdown





VH~»^

- V W Vv.





Vo^

Vvo-o^^

GWETS SVE
j Shutdown Startup \





^	J# (# ^	cf^ jrv^ ^ ^ ^	<&

Jy Jy jy K# K# ^ K# Jp Jp Jp J? J? ,#	K# ~# K#

^ # <
-------
MW-5 Primary COC Concentrations after GWETS Shutdown

1000

100

-J

13 10

o
o

0.1

^ ^ ^ ^ ^ ^	„v> ^ _»£> „»$> . _>? j® j{y j$>

///kVK
-------
APPENDIX F - SUMMARY OF DETECTED COCS IN GROUNDWATER
MONITORING WELLS OCTOBER 2004 THROUGH MARCH 2023

F-l

-------
Tabic F- 1: Summary of Detected COCs in Groundwater Monitoring Wells October 2004 Through

March 2023

XVfQ IB

'"¦ * iZ p ! r "1



¦£

¦£

¦£

-

¦£-

-

. T ~ . *. . •













1

3, '







i ;

0,4 J

I 0

.. .



. . » . .







: ;

«= I JO

L 0



: :

- . .







¦ ,i".

I J.

1 L

4.1

^ ;

. .







i *

:

I 0

1J

: ;









!. !

< 1.0

¦ I 0

li

L '

- . ¦ : :

¦





0 S

t.s.i

: '

3.1



¦ .. .

¦





;

< 1,0

i j

lo











: :

< IJ

l V

1 :'*s

!: ?









¦ ^

1J

""¦¦¦ il,

l ;

: :









• •

* IjO

!,

1.3

:;



« 0 A

o -

^ 0.2

C I

o.; i

L".~

: _: _ . .

c 0.4

o* -

* ft;2

::

o;> I

V m





0.1

0.4 J

C I

.13

^ _

	







: .

0? '

; i

0 S 7

A

. ¦ !









OJJ

L 0

y ¦»



: ." !.







¦¦¦¦ M



- 1 0

L ~

:.a

.....







IX 11

L.2

i.rjj

2...4

1.3

; ., ...







CO

-= 0,2

C !

v 3

;> «

- ¦



< 0.2

- -

J z

C 5

0,3

•i',-







0.3

3

e i

"J-Z

0.3

:





"

j ?

C 3

0.3

5,1

: .._..





0 3

J 1

C

A "*•

»,







- f !i 3

¦ V 2

... 2

¦Ti

0,5









0?

c.»

r- ¦

" ^









us 3

: ?

...»^

0,»>

	





0.3

. 2

::



0-

. ¦ ¦¦ ¦ ¦





0--*

0 ?

c;



tJ-









" 1

.. ¦¦ f

- w.-!

0.-







0.3

3

::

•*0.4

0,""

	





0 3

:

! I

0,-

0 -







rJ, j

o J

: L

•:•>

,]l i









r<

«" 3

c:

V.-

0,-









- i

¦ 0 3

c:

-

»} i









"» \

• 0 ?

C 1

V.-

0.-













::

V.-

0>









¦¦¦¦ -w» ..«»

3

¦¦ v:

0.-

0.-





»c 0.



l" «>



c l

•:•.-

0.-

.- .



.. ¦¦ »•• 3 ft j/t

c ?;

. j ;

K . . .

• C.4; c 4;

5 4;' 5 4'







¦j 3



: :

0.-

0.-

F-2

-------
Table F-l (Continue)
SUMMARY OF DETECTED COCS
IN GROUNDWATER MONITORING WELLS
OCTOBER 2004 THROUGH MARCH 2023

ri. .

Uai* C- ucpUd

Yjlaaie Orjsssic Cotcp^usd: *V€*C

a

"33

-

-

¦£

-

t'vEFA MCLn



T

w.





1









41

11,®

120u§

S3

140 C'

« 4 J





lHI



5-1

15-9

15iJ

12.®

l«u

1.0



¦

. -:



5 JI

i 7



M

Sl'J





H31

<• .



l 7

1 1 A

HCLd

ll.f

IOOjI

)







:







3 T O, T"i

I'M (li)

ifi,i fit J§

%

.«::s 4;.

S(.tp?.5J



1.4 ^

14]









2 0 {32]i

3.6 Q_§)

IflCtlliTJ!



j tti.71

1(5 (44J)



YA f-

Ml

s.



5.4 p,»7|

13 H3)

113.0 PIS J|

v

.3 -;2l s;.

US.» fMS.i)



-

-»„



::.

'S3 {Sj§)

ItSftlf



i



llf.t pjtf.B'j



a •

\ a»



¦ •



53 {4.2)

7 J (12)

imiiptfjj

1

J t»J>

15M (U5.9)









. .



4 J (43)

T 1 f7 Qv

P5.4 ;94 ft

2

.5 (13.J)

lllif (ilS.i)









. .



4.0 (43)

§J (?„#&

§§J (BSL1)



t,7121^21

Sf.i (IM.fi)









_



3 3

5.4

PfU

21 4

US .

»



* 2'. 1-

= ^

2 9 fSJOt)

4.5 (4 J)

SO.S r'SS 0r«

:f.s r r

»J illOJj



i £





- t



2 J|2.,S)i

SJJ (13)

Q1

IS J jl? 5;.

14.1 pl.t)



4

-



. .



*K A ¦*""& T-k

U .• < 'T».

$14 |1KL4I|

11J fll ,T»

7§v2 (fIS'.S)



, 4 "

* 4'





2,7 (•- 0.3)

-: ¦*: r

873 {2431

ii 7 #;c g 5%

87.4 (1M)



, 4 "





23 {23)

-:

7§3 (7<§.l)

ll.f |1I.7>

fii.i pl3)



-

-





2 M

49

JPSvr?

10?

833

A_

r v !r _ -





4..!

Ii,S

110

"











13 (L§)

- T J : i Tj

fl.0 (€2j0)



m.zmri



, 4 '

-











13 f 1,1)

'"i "*? ?"<»

#IJ (51.:2)

5.3 *9,I]

51.4:54.0^



: j. ,¦

J.







5-1 fS-S)

SI § i'IT i""i

M;S.2i

533 \f4Ji



J. ;

-





1 1 {13)

3" : "

713 (mi)

S.l .J3.4I

483 ;4S.Si

(4 (4;





j*i m t m "** T|.

233::

46 .1 (43 T)



*53 'AlAj

; - ; -

r 1 *: -



¦c §3

L S



s.s

35 S



: » £ Z '.C$

§ 3 ft.## J)

2, L •' 2 ?*¦

M3 Cltl)

j" -:

32. Z :34."i



F-3

-------
Table F-l (Continue)
SUMMARY OF DETECTED COCS
IN GROUNDWATER MONITORING WELLS
OCTOBER 2004 THROUGH MARCH 2023

"• "~l

Z>%:*

Y-iUiilf Orgsss« C ompseai: (VOC

S





i.



-















• ¦ n :



53

III®



"1,4



'<:¦ 2,0

. .. ...



:5j.:

HJflMl

4S0.0 [4 5: 05

i,41 (3. Jf)

f1t.»C»8.»l

Tf-

.....



2 4

141 (14.9)

4J8J«C4mf}

-: «,-f

BUJfSTAJ}

c L0{*U&

ISti



1 1

14 J®

510.t

41

5Tt.i

I '

11 3v - v''

3:

U'J

MM

3,5

IlI'V

1:







1-3

9.5

5DM

5.3

5MJ





i





.

i:s

57M

-:

sf :

1 d

- :









lJ.v

550.0 (5~tM13

- 5 ,-i y*

f 30.0 ;«•:•».0 Ji

¦ ¦

- 2

S





4. •&»

0.4

5h>;

5.3

45M

*¦¦'¦ -'4

- ~:





r t

" 0

ro •:•

^ r

0

: o







4 »

11 0

520 '3

-:

f*. .



lassos



Sf 2

n.

m ;•



J51 0

¦"

M/JtBI



~ s.

'¦

a«i ¦:

I 1

*£:•:

j 2



' Jr



SS

1 -

mi

34

53i







1®





"¦ ..k:

€ J

¦ii;.

3,4

ii" :>

r "i





.







- -

>:s:

5.3

HI G



§£l

_





~ 7

j.T

292 ¦:>

: i

3S2 v

1 )









T v {€ J>

i - : 1

253.0 •::; !.#)



W.OlSBJi

10 l



W2?





S :

3;

M3.»

IS

*•%' r\

: -)









s s

i' .*

list

1J p

2i% :











liJ

> r

•:•

11.?

115 0

: 1



V-

9 9

: ^ ]

n~ 0

5.4

143-:*

1

:s iu*

? t-

L £

u: ¦:«

-i

13S •!'

I 3>

3

IiS



S 2

:: j

1:15



139 •!•

j*



JfJT



7 0

"7

56.3

:; :

5f S

0 "7





;:.r

7 0

I'tf J

S~ '

1 ^

se«

C\]

£ iv



3 *

• _ -

Si "

; 1

61S

0 3

3 1C 2



; :





: : r

:: :





•1~

¦- :

i'»

•

C5 J

3" »







3

. i

— i

C 4 J

35 C*

c -

1* 1^R i"

3;

" ?

3T C

i 3 1

31 1

J -







i :

..

3CS

J -4

y :

Cl -



. - -





: '

c»

'~

C J- J

10 "

; -









». «r





: : :

13 4

0»











:• ?

14 5

•::

13 •

















1 '?



JC €

;:

10 5

V-









' "

¦ :

ic c

t:

113











L 4



sj:

¦ c z

10 3

z* -









l]

~, •

™ £

C 2

$:

v-



* u ;o:



C* 6 J

c ?

I* S

; ;



j -



" .



0 3



f"

; :

: 5

0 -

F-4

-------
Table F-l (Continue)
SUMMARY OF DETECTED COCS
IN GROUNDWATER MONITORING WELLS
OCTOBER 2004 THROUGH MARCH 2023

-l

Umplrd

VslaJiitOrfssM Comp««d: >TOC-.





¦s

-

¦£

r

t'vEFA MCL £m s 1.;-



-

¦¦





1



I

_



< ims{< mm

ffJl JfTTJ U

iM.a<79M)

iX'O.si.o:;

1,10®

« V't 0 i'Cv1^

i lx





IM I

§23

?*§

li 0

I,S«

1 1

- ¦





itf- iyl

®0j§

i,m

:d.o

2,5w

• ;

H- 1



J.J5 Lj5|

'?#.§ fit J)

: ooo -ii

;»o (2i

J, 'Pfl1!® O»$0(h

: 5 T 0>

11







«t"3 ft

fjrnui

ii.O

1»JK











MJPIJI

56D.0 tffC'.Oi

:io a"*

l,M«CW«i|

111.







<: 1.0 (*•¦' t V «

?fj fT5.fl

:ooo

*0.0 V"

:.20ooj-iai

3 S 13 ^

-r







5I.&J

fiiJ

:so j



" 3 *k





v~



4.5.0 :S2 0)

m»f«sn.«j

19M ;m :•>

l,7l#Cl»5iO}

1 2 |7 S:

^:

_







!<),•*• ;2C\0"»

C2D ,# (TIM)

•5.7 J ;1" 0;.

13Qvvl.5fiO,i

, " , 1 " .

? -! 1









?5#J

mo

1.7M

3;









:5 3

71SJJ

16.1

].jr:

' ^ s

- : iy*r



3* -

«1,J

16.7

l,:"v

n %







-

13 2

55>5 0

fx

SIS

$4







i' i

3-9.2 J



:: e

l.os: i

• '









0 6

19 I

SIM

id.:

1,230

:.?}









::

13 •:>

#BJt



1.1X-

-









0 a J

- *



4.3

i.o >:¦

¦ •









0 - I

n -

SIM

2,4

?fl"5

15









- -

: :

717.#

< s.a

S: SO

4- -









¦ -

2 t{

SJ4 I>

: 1

53? v

11 J

t:

1

:. -

: -

1

547.*

2 i

5:3 I-

1 ¦:



i.

1 3

-J: :

1 :

JS4 :•







• •

: ~

-15 fJ

: t

roo

-^u





:)

: -



' .£

J01 c-

^13







: i

!*,§

" ?

131 0

I 5





: -

: i

151.3

I K

219 j





¦- \ •

C 3

o ^ i

raj

f '

144 I'

0,-



' -

v i

\f 5

127.0'I

C 4

io«:

0,5

1 .





C e"

0 6

MM

€4

93 i

ii '

Y -C -





- ;

¦¦ v 3

M4J

! 1

"s:

0.-

i- - .1 „ ,



¦

C .3

SI.2

c:

S
-------
Table F-l (Continue)
SUMMARY OF DETECTED COCS
IN GROUNDWATER MONITORING WELLS
OCTOBER 2004 THROUGH MARCH 2023

YC?L "D

Iv«:< 'izpj-:

7 I- :.- C: ¦ ¦ :-i= F: J" "¦ ¦: ¦

¦sa

¦»

=

z

TS

-

Z F.J. i I. ¦. ¦ j1 1











1

• ii -



-:



_. .*



110 ~

-





L.*

19

DO 0

13

«:

I





13

L >

130 £

2.3

i:«:







13

::

110 *

.

94 :•

1 i





: 0

t *

wo

2 i

120 C-

1 ,





*

2 y

140

3 &

14'jC>

-



¦

:

J,6

ro o



ie j

I





• -*

3 ,f.

140 :•

12

»•:»:•

. -

i i* - X

¦.I,1

•» r

x.

"J

101' i"

- .

-

* ^

19



6.0

"3 C'

- -



* w

3 ?

$7 0

6.1

""4 v



? 2-. :

- 3

2 T

TT S

S.S

Sf S

- .

: -.::

C\-

¦> "

alt

5 "

S" "





:



0.™

24

¦i:

--

S3 r











:> i

14

- ** i.



r i











3.: j

L -

j















" ^

i;

33 4

6.0

42 S

1 .









03 J

I 9

iiji

5_T

44 €

1









:c j

"Tt

: "¦



4SJ

.









C* 2

¦* 1



14.3

S2S











DJ J

> -

-4:

13.0

4







•1-;

3" J

4:

-(i



«-¦:>

:\3

. ::

0 i 1

3 C

JJ :

4

5? f"

0,3





]3 J

i '

i ^

<>.:

¦j i

0,3

"r* _'-v -



03 J

: +

;s:

'.4

51 r

"





K!

24

i;™ s

I S

4: I

03

i"' ; ? .



0 o J

L "

nv.i: ,"i

- ?

43 :

0 3



¦ ¦

0 " J

E I

;s o

« T

4" 5

C".~



: s -

j

[ *

22 -

::

3c:

0 -





0 ' X

t'

:i-

] s

34 "



r I' - « v " *



Ji.

2

c:

52 "

0 -



r a

! 0

iS ?'

¦% n

30 S

0 -

-.2 .





0-- J

t:

:»'

m

30 €

0,-

SEISMS





0 - J

i <;•

IF 4

1 S

2" S

I'-

: .





0 - J

0??

IS c

1 c

2T I

04

. ! .





;

r, j'

:: "

.

30 5



^ 22 I





0 2

Q'l

16 4

]:

22 ?

04

> - r 1

i..



. .*



14:

i:

« 1

04







C" 3

14 I

i 4

20 y





;-.~

j

: p:

12;

. ;

r

0-





M "i

C ~-J

j r 4

.:

21 :•

0»

F-6

-------
Table F-l (Continue)
SUMMARY OF DETECTED COCS
IN GROUNDWATER MONITORING WELLS
OCTOBER 2004 THROUGH MARCH 2023

v-. -l





¦a

-

-=



¦sE

-

Idsepaiitl



s

7

?»

5

j









<• LD

C -?

1.0

1J

2.1

1.3

. * _



::

i:

1.5





5.S

:,'j

....



; :

... f A
« .

„v





0,- J

: :

2:



• ¦

ff r

- C r





C\-

.... A I

" *

-



: 5

• -





1.3

1.3

- - .





:;

: :

L C'





1 !

1.3







: 3

" ^

L 0





« .. V









1.3

' ¦

• • i <:•





1 !

:.3

; - _::

-

0~

c;



_

0-1

<*»



. .





o

I'-

: :



« ¦«



'J.-









r, i

I' 1

: r:



_







SlpJl





o:i

01

C 4 J



1



¦ -



. -





::

: :

C4J





0.21

:.o









::

..- ^ ^

" i. "





0.J J

:









:.3



£ 6 J



*

0 3 J

1.0













t w- J





0.' J

•X-



•





"V

r~A

1.8





Li

•:>-



:



A

3

1,7





o i

'J .j





r. a

. :





;



. .





3

: ;





. . _

'J 2

j-v -



"i

. 3

;:





_...

0 3





•I" J"

r, 3 i

; a





o ¦ j

x"> «

SV15.5I



0.1

0 2

-





M 3 J

v -•



¦

1 :

A 3

2 S





j

-

h mV -

¦

- ¦

0«

: i



1

OBJ

0 -







3 3

0 5 3

1.3



_



j ~





0 3





100.0



_

S3 S

0 -



0 3





- £



>„.._.

::

0 -





0 5

04



-i





1 3

0 4*

.?• I r _ . »v



, ;





5,2



_

1 c

j 4

: ... .



, j





5.1



I

::i

, .j 4





	./





: l





: ;

- 0 4



Ifrl.



- .*





tf.L



1

l.L

0 4







«} 3





:





. :

- 0 4



¦ «. -01.-



A 3

- c ?

J V



-

: :

- 0 4







0!

C 5

¦ L





' v 4

• 0 4







3

C j s 3

SLS.



-

] 2

- 0 4

F-7

-------
Table F-l (Continue)
SUMMARY OF DETECTED COCS
IN GROUNDWATER MONITORING WELLS
OCTOBER 2004 THROUGH MARCH 2023

Well ID

VlE&pkfl

Vojuik Orzrauc O* sap-: mid: :YOC

E
¦¦

-£
¦_

JZ

¦=

r_-
E

_

¦r

fi
>

w
..

¦r

*2

-

¦E
0-

-

U
1

t**

USE? A MCI. Cfttflil



¦¦

"l"-



r

..

MTV-10A

iC 55 20C4





i'"



9 >





5 ij : ?¦: 5







i

:i o





0 26 2 .•; ;•

: :

3.5

34 C

1.0

J J 0



j"1.

5 20 1 OOd

1 0

17

25 C

1.0

14 0



0

<3 : '¦ -r

1 0

5.6

4.' C

1.0

?: o



0



5,5

4.1

28 C

0.5

34,0





9i~ 2 jo~

I 0

6.9

5: C

1.0

n.o



u

- '.4 :xs

:;

2.1

20.C

1.0

38,0



0

:• JJ.'S

1 c

5.3

4SC

1.0

7_ 0



L

_J!.y

I 0

2.2

25 5

1.0

3" 2





s.* i: ,-;:

0 4

3.4

' __

¦:: :

SI,«5

C.2

5201 c

0 4

3.2

31 4

< i.2

si-

0.2

9:: 201c

o:

2.3

51 5

(' 2

-s 0

C.2

;'s

o:

4:3

50 C

C',2:

7" (J

C.S J

si.;:

1 c

2.7

-0 8

1 0

114 0

l.C

: i ~ i ¦ i

1 0

4,2

44 "

0.1

"14

1.0

3 is j.'i:

: o

4.9

60S

f .4;

11<),0

C.2 J

5

0 2

*.0

449



r

"6 I

0.4

lo 20li-

0 2

5 2

62 5

C,

-

86 6

C.4

ft 24 2 01-

0 2

1 -

34 C



( 3.

39 4

£

ic::j14

0 4 J

5.1

60 4



1 .

3L9

3.8

5 16 1 Jil"

05 J



54 9



»:

If 1

6,3

9 i: :

5 5 J

5,7

6 -S



) "j

41 S

C.4 J

:¦

0 5

1.4

30 :



':

9.9



5 I'' 2j 16

04 J

23

94,0



f '

Si

C.5 I



04 J

2.5

810

. 2

10 3

3.6



0 5

*» w

35 S

0,2

"9

C.5 J

' "I J 1 C

0 5

2.5

9

0 2

-.1

3,1



0 5 J

1.4

25 1

2 C

35 S

C.4



0 5

0.5

4 5

< 0.2

6,1

C.4

22 2019

0 5

2.1

55 6

- 0:2

50 3

C.S I

'• 2? 13

0 5

2.1

.- : •-

0.2

16 6

•~i. -T>

; 22 202C

0,5

0.5

74

0.2

-*

C.4

9 21 2022'

0 5

1.1

45 2

- 0.2

? ?

2.C

- "% "I -| "! *

0 5

0 7 J

JSC

; :

-i T

1,"

9 21 2021

0 5

09 J

41 9

0.2

5 5

2 .«;• i

5 2': 2022

0 5

'0 7 J

31 T

0.2

101

l.C

9 16 2022

0 5

0 6 J

35 5

::

i 9

C.4

- *-•'=~

0 5

0 5

16 C

0.2

6,"

0.61 J

F-8

-------
Table F-l (Continue)
SUMMARY OF DETECTED COCS
IN GROUNDWATER MONITORING WELLS
OCTOBER 2004 THROUGH MARCH 2023









"Oohriis Organic

C osr-pt-uud: tTOC" i





1

Date i.impkd

u.
=

€
¦_

f-1

_

E
.

r

C

|
f t

v

§
1

_z

Z.

¦-

T/SEFA MCL



"

~



-

~









i c

2.1

18 0

1.3

ISO



.0



5 14

I c

2.6

19.0

1.0

1?0



.0



C VI

1 c

2.4

27.0

3.3

:4 0







5 l v 2'»t:

I c

13

11J

1.3

:oo



.0







3.0

30.0

1.3

34 0



H



- ~~

3 5

3.3

24.0



'

32,0

0.7



y 1 'JC'V

I G

4.4

45.0

1 0

f4,0



.0



- 14 ::X S

1 C

1.3

13.0

1.0

23 0



,0



*.J- _5 2-.;i '. S

I c

6.1

48.0

1.0

"*"0



.0



5:3 2x?

I c

• T

I7 -

1.0



2,0



S : .009

;¦ -

5.4

2

o.2 r

*>'?

... 2



r w/

3 -i

2.4

24 5

0.2

4*4

0.2



' s

D :

•1."

50.S 5

0,5:

93*11

0.2



- "i

0 :

2 ¦"

33 5

0,2

fl S

0.2



C ' C, "•V! '

t C

2.4

2

OA J

133.0

1.0



;

1 C

:;

3«

0,21

62.6



f:



9;" i :

I c

4.3

5-6,5

0,3 I

96 9

l:.6J



;

02

5.4

36.1

;

61,9

0.4



? if

0 2

6.5

7«J'

04 7

io:,o

0.4

L 5

•; i-i;:: -

3 5

4.7

54J





io:,o

0.7



ic :j ::=i4

3 5

4.1

59 7



,7

11^.0

0.7



5 25 J j'.~

3 2

5

5£ 0



, J.>

"1

C.3





3 2



58 4





88,8

C 3



5 50 251c

0 5

5,6

42.6



.

86.8

C.3



: -

3 5



61.3



7

90 9





.

: :

: :¦

445

c

~

91'

•3.4



s if

3;

5 T

54 3



_

95 3

0.4



: 22 101 ^

3 5

Ti -"3

37.1



I

m,7

0.4



S 2i 2C L-;""

- 0,5

3 5

4,2



_

1.0 J

0.4



\

3 5

C.3

99





16?

0.4



_ ~1 1 i .**

3 5

• 7

32,4



_

?9 5

0.4



s !':¦;:;

3 5

1 7

«,1



_

"? 8

0.4



s is ":oc

3 5

: -'

26,5





46 1

4



;2':o

3 5

1.7

34.3



2

<~0.:

0 4



; •• i -i •• ^ '

3 5



2S9





4# g

0.4



? :.i:3::

3 5

1.3

33 -



_

¦»«"

0.4



i- :i

3 5

3 S J

19-1



2

3J f

0.4



Cj : !C. "•

3 5

:.i

25 9



..2

59 r

0.4



"= ' * ^ :

3 5

• i

25,2





40 8

0.4

F-9

-------
Table F-l (Continue)
SUMMARY OF DETECTED COCS
IN GROUNDWATER MONITORING WELLS
OCTOBER 2004 THROUGH MARCH 2023









t ci-ifiU Ovramc

Comp-jwniz XQC



Tun ID

Due i.nsp;*K(

_
-

•:r
%

f-l

3

€

b-
_z

z

1

l
—

4

i
.=

¦i
.-

=

i



U^EF'AMCI

iiif Li



T



_*

*





ic:: :c-C4

< 13

I 0

031

l.D







; U231?

< 13

1 0

2.1

l.D

2 T

i.O



v ' -

< 1.0

I c

5.7

1.3

4 7

1 0



3 - -lOo

< I 0

3.4

19 C

1.3

21 0

1.0





< 1.0

1.6

33 C

1.3

1 6

1.0



-1} iy. ~

< 0.3

' -

9.2

0.5

9 .<

G.T





< L§

I 0

f.3

1.3

t 3

1.0



- L4 23CS





; i.v:

1.3

- 6

<»'¦

4 i

10.6

i.Z



s;: '

< 0.2

OS J

16 3

C..'

o.:

"» ¦>



;¦;: 2? is

< 0.3

'.*.2

0 :

3.3

0.5

C.3



? .•:: .•„•

<03

	

¦; ;

C.3

0.3

0.3



3 :o

0.5 J

1.9

33 9

0.3 3

16 4

0 "J



? ;c

0.7 J

¦ -N

:

f',2

0.4

5 1



:> j3io

0.7 J

2.6

4A.S

0.71

::.9

C 4



v .23 23 is-5

« 0.3

i

"61

C.2

"3

C 4



i: :c:s

<03

0.:

5 C

0.2

1 I

C 4





<03

0 4 r

• s

C.2

(.'A

1.4



V L >' j . '?

< 0.3

o.4:

6 0

0.2

0.4

0 7 J



;* . t 1 0

<03

r 3

0 5

0.2

0.4

C 4



•• i; :

< 0,5

0,;

-

0.2

C.4

0 4



3 12 232!

0.51

; u

2S0

C.2

5.8

1.4



s :::.

< 0.3

C\:

04."

0.2

0.4

C 4



y_ i j'p *

< 0.3

0.3

2 S

0.2

2 5

C 4



5 ::o:

<0.3

:

-¦:

0.2

0.4

3 91



z.' < "• 

< 0.3



; ;

< §.2

0.4

C 4

F-10

-------
Table F-l (Continue)
SUMMARY OF DETECTED COCS
IN GROUNDWATER MONITORING WELLS
OCTOBER 2004 THROUGH MARCH 2023

ID

Due ]

Yol.nite Orsraisic C Mrjpeuiid: -.YOC ; =

£
*E

-r.

t-1

|

r

JZ

It

z

•3

i

-3
—

£
_
—
•_

~

Z

_z

V
JZ

-.
-T

-*

USEPA M£ L : :•= Li





'





-

MTV-11B

": • ¦" '' -i

ic

1 >

lOJ

1 0

21.0





1 c

1.3

7.6

1.0

11.0



.0

916

1 c

1.1

11.0

1.0





,0

5 10

i e

t *1r

7.7

1.0

12-0



.0

s i;

1 c

3 S J

9.3

1.0

5 1





--Z5 130"

0 5

0 8

S3

0,5

4.5

C.7

; l~i': ~

1 c

I C J

6.8

1.0

4.9



.0

- u ::>:¦£

1 c

1 CI

9.5

1.0

11 0



.0

s :4

i e

I C

11J

1.0

"f



.0

5 54 200 s

i e

04 J

2.9

1.0

1 6



s :

0 4

3 4 J

8,2

0.2

- -

•i.**

0.2

5 15 no c

34

3.4

17

0.1

5J

C.2

S 1:-231C

0 1

04 J



1 5

'A-

SJ

C.2

5 11 11:11

o;

0.? 1





0.1

7.6

C.2

.' i .

i c

O.S J



? ~

1.0

SJ

1.0

.': .

32 J

1 2



S 1

1.0

11.1

1

¦ ."i.i

1 0

or J



68

1.3

3 0

1.0

. I.U.-

02

2.1



6 1

(a;

19.4

C.4

& lv i.

32

1,0



I 2

0.5

9,5

C,4

-* 14 i:: 4

0 5 J

l.C J



i 6

0.5

t 4

C.3

: c is ii-14

0 fc" J

2.9



- -i

0.5

" 0

C.3

5 16 111 5

0 6 J

5.0



82

0.5

10.4

0.41

50

02

2.;



6 1

C.5

0,1

0 7 J

; ::as

a-j

5.1



6.1

C.3

4.3

2.0

? ;• ins

0 5

i : i



0 5

G.3

1 ¦' 5

4,1

: 1:1 Jl'i"

05 J

1.4



5 5

C.2

6?

1.4

1 ¦

0-J

! i



9 C

C.2

1 C

1.1

j ii i:.i

35 J

1."



4 5

C.2

4 S

2.0

911 j C1 S"=

0 3

2.3



4 1

C.2

64,0

04

__ :	v . c

C.J

1.4

25 1

C.2

14."

C 4

- -

0 5

(>.4 :

6 7

C.2

p 9

C 4

9

0 5

O.S

21 "

C.2

0 4

C 4

:¦ ii ' r:.>

34 J

i.o:

21 9

C.2

j ¦¦

0 51

9 :i ::co

0 5

0.5

21 1

C.2

2.7

C 4

:• 22

0 5 J

1.3

51 5

C.2

7.6

04

? :i ::ci

05 J

1.0

21J

C.2

LI

C.4

: ¦ •< "

0 5

O.S J

19.4

0.2

SJ

C 4



3 5

0.4:

13.5

C.2

LI

C 4

3 i 120:

05

0 95 1

20.&

¦.. 1

5,7

C.4

F-l I

-------
Table F-l (Continue)
SUMMARY OF DETECTED COCS
IN GROUNDWATER MONITORING WELLS
OCTOBER 2004 THROUGH MARCH 2023

\\>!l ID

Ds«e vris&pkd

YohriSe Orramc .'VOC :s

.1
£

r
t- i

E
_

HI

_

-i?
_

—

"ir

¦m
-

—
¦_

¦
-

jr

ii

Z
_

=

3

z

_

-

_Z
*.

A- .

OEFAMCL

i us L:>

>

~

'.I'



*¦

-

Mvr-i:-

;; i 200-

:c

«®j

i-i J.-.

5.1

130*i.O

	

:• 2005

l 0

67.1

"F"



130y.0

- 2.0

" Li

;oo

81.0

r o

10.0

13040

• IOC



1 c

Si.-)

:"S C

? 7

1101,0

; n

i

t 0

110,0

66 U

49

1600.0

1.0



I 0

"9,f}

55 C

^ i

lOO'J.O

1.0

•' ~ i ' -

I c

0,0

'4 0

* 2

1-100,0

i.o

- 1: j Oi '

3 5

S8.0

48 C

4"

M«,0

C.7

¦¦¦ "

I 0

94.#

5! C

45

S49.0

.

- i"205S

1 c

?!.'>

52 C

10.0

1000.0

1.0

a ' " "'ii' K

1 0

9>4/i

54 C

??

98(3.0

1.0

;¦ : .¦: •••

0 j J

40.1

3? 6,0

0." 5

8M

19.V

s ?::.

3 ~

4".4

66 :

5 S

T3?,0

0.2

.. .

i :• i o

3-5

4:.:

44J

4 6

69-0

C.2

9 :>

.:i;

0 5

63.4

45 5

5 4

9>},0

0.5

. _



o:



s-,o

11,3

139W

0.2

9 Is

i:::

i :

46"

— 9

6,7

'tW.O





05 J

42.2

SUM

26

:o:.o

1.6

:? :>¦

I C

-J

91,4

1 5

19?,0

.0



0 2



SI -

1 -

153,0

0.4

iMf

i;

i "J

r:.o

1.6

4-5,0

2 2

25 :>i-

1 2

2 ; J

144.0

1.5

354,0

1.6

:.:: ':-i4

0 6

09 J

54 8

¦ O.S

:i6 0

O.S

:20 i 5

0 5

0" J

68 9

• O.S

201.0

0.6



0 -

0 5

mi

; ~

1*1.0

C.5

r

3 6

0-

571

0.6

130.0

0.6

$ 201?

0 6"

0-;

51.2

0.6

ir.o

C.6

: 2\ 2)1"

0 6

0 6

57.7

0.4

13? .0

O.S

; i f: v."

0 c

0 6

4" 5

0.4

96?

0,-5

;:: 201s

-------
Table F-l (Continue)
SUMMARY OF DETECTED COCS
IN GROUNDWATER MONITORING WELLS
OCTOBER 2004 THROUGH MARCH 2023





Voh?!h Orft' .>aif >uutt: 

:ie,o

< 10.0

3Jf,0

100



3 1 V, >

1 c

9,4

l-SO 0

1.J

1?0,0

1,0



~ 11

:e

1?,-)

:jo o

3.7

:»,o

;



9

i c

lf.O

::o.o

3.1

:mx>

C.7J



v V;,^'

1 c

14,*}

:-io.o

2,5

zm.o



.0



;•: ¦ ix-6

1 c

11,')

140,0

2.7

16ty.ii



.0



srx-c

i c

1J.0

150,0

2.3

ro.o



.0



_ v.

0 5

i:.o

?:.o

t S

i:«),o

0 7



o :v -

¦ 1.0 ( I C)

c.i

61.0 '3~- 0)

i 2(i.3i

*".0 (S4 01

LC'

: 01



j;, ' £

1,3 f . LIT)

" ' ' 7 5 'i

42.0 s.45 CO

I 4i.l.<5:

99 \> (93,0.1

i.e

: Cm



v ;4 \»:

i C

14,0

-1 0

2 1

i:o,o

1.0



:• :-i :>:p

1 C

10*

•: s

1.8

104,0



:.0



S 4 -009

0 4

7.3

*

IS

83,1

0.2



5 21 -ViO

0 4

6.0

45 4

LS

"3 S

0.2



?::>iC

D 1



r 2

1,7

6-:

C.3



5 : ji:

[i I

8,1

642

28

93 "

C.2



_ J i -

I C

^ *

50 S

23





fj



:::ca:

3 2 J



66 8

3.6

94 "



$



LS JJi:

0 5 J

6.5

61 9

4.1

88.6



0



:¦ 1" 2 C L^

..

_

_

_

_







" . v' _ v j. 2'

__

..

_

_

_









-

_

-

...

..







JJ.4

0.2

¦

32 2

2.9

ssJ

<: 0,3



5

OS J

H 1

?

3,7

117,0

0.5



9 :0 -ji'~

0-

S.6

50 5

4.0

115,0

C.5



5-:(::«i*

0SJ

S,t

SPO

3 6

94,1

C.3



? i":oic

OSJ

c 5

S,2J

4.5

11?,C

0.6



5 :jl"

39 J



88,0

3,5

i:4.0

Ci



9 :f- ~

3 6

e"

"SI

f 1

10"0

Ci



5.2 J MS

OSJ

s?

104,0

: C

lr.o

0.5



-¦ \s 'iV ?>¦

0 5



3" C

0.2

o.s:

1.5



i: l: :o:$

1.0

S.l

9" 9

6 4

1C.-.0

0.4



-- ---= - "tig

0.7

3 £

55 (

3,9

31.9

0.4



9 -s ::a?

1 C J

5 9

'if

4.2

94 3

0.4



•a «

06 J

-

62 6

3.5

3:0

0.4



? :i :o:o

0 3



3PS

3,2

*y f

0.4



;( * j ^ '

0 5

2 5

3.' 3

29

48 f

0,4



11

3 5 J

.

23 2

1,9

34,3

0,4



• ¦ ;

0 5



38 6

1 8

f:;

0.4



C 'A "-V

0 3



30,2

1.8

3- 4

0.4



. . ....

0 5

24

33

2.1

44?

0.4

F-l 3

-------
Table F-l (Continue)
SUMMARY OF DETECTED COCS
IN GROUNDWATER MONITORING WELLS
OCTOBER 2004 THROUGH MARCH 2023

tv*ji ijd



Y-ihriifc Oi frunc Cc«i3|:->ua(i- ;YOC*:

i

r:

i

f-1



£
4

j

-T

<*•»

;

sz

£
_

¦:

£

%
a

£

£
it.

ST

ZT

l^EPAMCLins-U



~











MW-14

ic 24 :oc4





i.o:



.'j

5 1

i: c

S/1SSC1CIS









.0



" T

P jS O'X1;"









.0

;¦ -.

15 0

..

:







.



: .= (¦

J... J-Jvc

:

: ¦;

'% c

1.0

5 7

1.0

. .

t c

65

210,0

1 0

53 0

?.?

- 14 200"

t 5 i. :< ji

2.9 :2.Si

50.0 i4G 0)

0 5.' C.5:

44,<) 141 0i

€? (6.4.1

m Y- "5V~

1 c

-.6

160.0

1.3

24 0

6.0

- [ " I "

I 0

I C

4,2

1.0

2 9

1.0

Lv :?•200s

l c

1 c

i:c

1.3

S-)

;.s

" '"

l c

1 c

s.o

1.0

5 1

2.0

s 4 :eor-

0 4

i.O

45.7

o.;

»Q

C.2

¦ : -

3 4

1.3

25.1

0.2

5? 4

1.0 J

; _ ...

3 1

3 i

q.O

l .2

9 -1

C.51

-> jOl,

3:

35 J

S 3

0.2

SJ

C.2

9 :oi:

i G

OS J

34 5

1.0

68

i.O I

. j i«

I 0

02 J



1.3

3.5

1.0

9 \9 20s j

I c

3 5 J

43

1.0

4.7

I f<

2 22 2

!Ii

32

3.2

I 4

0.3

1 C

0.4

9 1



0 2

4.4

102.0

C.3

154.0

i.:

. "



0 5

2.3

55 2

0.5

16'),0

C."

IC 15 .



3 5

1 'T

69."?

0.5

i:?j

0.7

51" 201;'

d:

3.5

7 8

0.}

0 SO J

C.61

¦? :v

02

1 7

St 1

0.2

96.4

C.5 J

3/3C1G



0 5

*i 2

86 4

¦;

8"9

¦: 4 j

. " L

| =



i.3

"14

¦; j

69.'

C.3



Pi /

0 5

:.i

53 9

0.2

49 4

1.4

:5261



0 5

0 9 J

5SS

o.:

::;

6.5

3f22Q

i v

0 5

0.5

1 ?

0.2

C.S5

C.4

v 2'j 2C

;

3 5

3.5

'31

o.5 r

" 6

C.4

i::: :-:;s

0 5

0.6

q

0.2

4" 8

C.4

;* * 2 201^

0 5

3.5 I

9.1

o.:

34.3

C.4



3 5

3.5

1,3

0,2

-

C 9 J

s^isscp©

0 5

3.4 J

8.4

0.2

:s:

C.4

¦

0 5

3.5

7,0

C.2



C.4



3 5

3.5

6.5

0.2

:l 3

C.4



0 5

3.5

5.4

¦ ¦ 'j 2

r.s

C.4

5 ;i 20:2

0 5



4.5

C.2

. &

C.4

y 6 '' P '

D 5

3 5

23

0.2

li.i

C.4

:• 202-

<03

< 0 J

23

< 0.2

10.7

C.4

F-14

-------
Table F-l (Continue)
SUMMARY OF DETECTED COCS
IN GROUNDWATER MONITORING WELLS
OCTOBER 2004 THROUGH MARCH 2023









s'thrut Organic

C iVOC : ^



Tun id



¦¦

w

1:
~

¦}

.

_







_¦





T









_z

JZ



jE

;







m



i



E

--

VSEFA >K L

!iii L«



T







-



x 12x-

2.6

6.9

34 0

4 2

S9.fi

1



, •



11,0

1-0,0

6 ?

14'U>

:.C«



SSf!'20©5

43

- -

2? 0,0

23

4?,0

i ;



x i :x-;

5.1

5.2

190,0

2 9

42 0

1 0



;¦ 11

C?

1 T

160,0

4

69 0

i .0



? 2" 2X(i

?, 6

6.3

190.0

< **

"0

1.0



- 2;: 22'X

6.1

12,0

1*0,0

12.0

13#,0

0."



9 x: >: -

6.9

12,0

250,0

42

4?,0

C.SJ



_ jV-§

I C

-5

180.0

~ 4

38,0

I '¦



9 .4 2 X $

T i

9, J

2200

- 1

?0 0

1 9



24 2X1?

",6

8,6

:6* 0

8.9

88,?

3J







9,5

501 0

9.6

89 1

16,1



. 	

s,i

¦i.6

211 0

8,1

"9 2

1.6



¦2 2":= xxc

T.o

11.:

is-.o

20,0

134,0

T.8



5 _2X

5,6

13,4

229 0

2? 3

16'), 0

7,1



>¦ 2v 201

S."

10,5

226,0

19 0

104,0

7.8



.XI . _



3,1

211,0

14 9

96 9

.



>¦ . 2 21'12

'.J

5."

200 0

12 "

"6,?

3 "



3 22 _'jI :¦

5,6

1?,1

264 0

24,6

114,0



MW-16

9. X2 2X2

T,4

11,4

236 0

18 8

ltP.O

6?

6 2:: 201-

10.?

10,9

If 1 0

14.?

18?,0

0."



j!j 22 2014

T 1

10,s

;no n

IS 6

104,0

0 $



i 2 2/i„s

7

11,1

233,0

1*8

109,0

::





<~,?

11,9

205.0

1?,-

31 0

; :



3 5\ 2Xt

6,4

10,?

1S2 0

14.?

101,0

; :



c. - - -

.2 ?

9,0

18" 0

14 2

MS

v:



3 2? 221"



Q ¦

o.S"

183 0

11,1

931

o.s



•; v-i -• " -

4J

7,7

163 0

11,5

?

OS



-i ! ' '' £¦

4.?

8,'

211.0

6,4

27 I

1.0



^ v, 2v* X"*

0.9 I

9,1

S6.fi

?,?

11?,0

0.4



12 2: 2XS

4.5

5.:

16" 0

39

63 "

1 0



: 2: _ L' X-

3.4(3 5)

5 j ; f i 1

132.0 1.125,0:.

" 6 (",31

f 3 1 1*1.1)

0 S i C.5';



' C- "¦ Ci

34

~ 5

99 0

5 9

69 2

0.4



3/l®sC2®2tf

14

5 5 J

93,3

7 7

?4 6

C.4J



X ' .

¦1 -

«•;

93.3

8.6

62 4

0.4



" " "

1.4

-.3

11,1

S3

tf> S

0.4



X . X

: -

4.6

fSJ

6.6

4" 9

: ¦ ;



¦ ¦

: s

- ¦"

SI.8

6.3

?; "

-.-1



? X- 2;X2

1.6

5.7

81.3

5.0

3S3

C.6J



:• X;- 2222

i.«

-i.4

70.0

€t

44,6

C.61

F-l 5

-------
Table F-l (Continue)
SUMMARY OF DETECTED COCS
IN GROUNDWATER MONITORING WELLS
OCTOBER 2004 THROUGH MARCH 2023







Voliriie Organic

Cvur.pouud" -.VOC::









r

_







Will ID

DjH

::
_

r

I

1

0
;

~~.
.

—









—

' i

i

r









:

i





U-'EPA MCL rusLi

•



¦



f.





.. ;• :k4

f-

: o





f.>:»





3 :"'



io,>

'6 0



ir -

.



? 2? 2 • '



13.0

l-i 0

2.S

ltv-0





3 :i;: f



i;:

0

_ •

14;. 0





yi _ A J ' K p.



""6,0

42

130,0

1 u



- 16 2jv8

<1.0

11.0

-SO

: ~

110,0

: ¦:



& 14 --j'/S

< 1.0

19.0

-so

42

134.0

:.c<



:¦ 14 jV.:»

< 1J

8.4

-so

2.8

«

C 6 J



4 2 U v V

< 0 4

io.:

"3 I

3.5

9?.0

::



5 _-i- J'jio

< 0.4

9.6

80 6

5 0

141 0

0.2



9 l-r J Jli=

0.4 J

18.1

94 8

5,4

164.0

0.2



;•

0 4 J

i:4

ij -

fe-

i:«,o

C.2



Q V.

0.7 J

:c>-

10:,0

ll.:

ISj.O

1.0



;¦j ji:

0.5 J

1S 3

94 9

Sf

14?, 0

SSI





0.7 J

:o s

105.0

11,3

1S0.0

;.o



; :: ::.:

0.6 J

14,6

so:

9?

111,0

04



' ''

0.4 J

M'.r

69 S

6 5

91,6

04

M",V-r

6 14 Jj14

< 0.2

1.6

14.2

1 6

::.4

0 3



:s :o:4

<0,2

3.3

26 -

2 ?

44,?

0 3



; V •'•;'=• •-

<02



0 2

C.4I

1 -

0 3



:? ; 0 2 V S

0 6 J

1 •1.

"i;

C.3

43

:,4



;• ."V J j.6

< 0,3

2.1

::;

0.51

IS,?

4 0



9 f JC*I S

1.0 <1.0 J)

2? >3 0;

?S C (.56 31

0.4 J., 0 4 J:

4",0 C4? (f)

3 S i,3 "j



	

l.l

-:

"6-3

2 5

90,0

04



i v, ---v 7

0 8 J

3.6

¦? 'i

5 0

m 0

04



;• _ 2 2 J. S

1JJ

-.3

—,o

1,9

-s?

C.51





<: 03

as j

19 8

< 0.2

S#.l

0.4



i: i: :;=;s

< 0.3

: ;

i.y

< 0.1

5.4

C.4



:oi9

< 0.3

0.4

e.6

0.2

6.1

0.4



9 •:> 2019

< 03 (< 0.3)

C ! J :0.5 .1

::."-2C9i

0 2 ( C.2:

^ * ,4 7.

0.4 1; 0 4)



' ' K ~s i'p/il:

< 0.3

0 3

( i

0.2

04

0,4



3 :i :;c::

< 0 J

0 3



¦ 0.2

2 1

C.4



: •••VM

< 0.3

'D 3

( ;

0.:

0 4

0.4



s :i

< 0.3

0 3

-» «;

K\ 2

1 "

« n



; _i JJ__

< 0.3

3 3

0.2

0.2

(.4

13





0.3

3 3

s

0.2

1 6

16



:• it jcc;

< 0.3

< 0.3

o.i

< 0.2

< 0.4

« 0.4

F-l 6

-------
APPENDIX G - SITE INSPECTION CHECKLIST

Site Name: Carolawn, Inc.

Date of Inspection: 11/17/2022

Location and Region: Fort Lawn, South Carolina,
Region 4

EPA ID: SCD908558316

Agency, Office or Company Leading the Five-Year
Review: EPA Region 4	

Weather/Tcnipcratu re: 50's and mostly sunny

~	Monitored natural attenuation

~	Groundwater containment

~	Vertical barrier walls

Remedy Includes: (Check all that apply)

~	Landfill cover/containment

~	Access controls
Institutional controls
Groundwater pump and treatment

~	Surface water collection and treatment

Other: Final remedy to address remaining groundwater contamination will be determined at a future date.

Inspection team roster attached	~ Site map attached

Attachments:

II. INTERVIEWS (check all that apply)

1. (MM Site Manager Jeff A lire as

Name

Interviewed ~ at site ~ at office ~ by phone Phone: _
Problems, suggestions ^ Report attached: Appendix E

Principal Engineer
Title

12/30/2022
Date

2. O&M Staff				

Name	Title

Interviewed ~ at site ~ at office ~ by phone Phone:	

Problems/suggestions ~ Report attached: 	

Date

3. Local Regulatory Authorities and Response Agencies (i.e., state and tribal offices, emergency
response office, police department, office of public health or environmental health, zoning office, recorder of
deeds, or other city and county offices). Fill in all that apply.

Agency Sj.J HJJ X..

Contact

Name

Prob le ins/suggestioas ~ Report attached:.

Project

Manager
Title

12/30/2022 	

Date	Phone No.

Agency.
Contact

Name

Title

Date

Phone No.

Prob le ins/suggest io as ~ Report attached:.

4. Other Interviews (optional) ~ Report attached:.

III. ON-SITE DOCUMENTS AND RECORDS VERIFIED (check all that apply)

1. O&M Documents

~	O&M manual	[3 Readily available	~ Up to date

~	As-built drawings	Readily available	~ Up to date

~	Maintenance logs	~ Readily available	~ Up to date
Remarks: Treatment system is no longer operating

§N/A
§N/A
§N/A

G-l

-------
2. Site-Specific Health and Safety Plan

^1 Readily available

~ Up to date

~ n/a

~ Contingency plan/emergency response plan

~ Readily available

~ Up to date

Sn/a

Remarks: Treatment svstem is no longer odcratine







3. O&M and OS HA Training Records

~ Readily available

~ Up to date

Sn/a

Remarks: Treatment svstem is no longer operating







4. Permits and Service Agreements







~ Air discharge permit

~ Readily available

~ Up to date

|n/a

~ Effluent discharge

~ Readily available

~ Up to date

Kl N/a

~ Waste disposal, POTW

~ Readily available

~ Up to date

Kl N/a

n Other ocrinits:

~ Readily available

~ Up to date

|n/a

Remarks: Treatment svstem is no longer odcrating







5. Gas Generation Records

~ Readily available

~ Up to date

Sn/a

Remarks:







6. Settlement Monument Records

~ Readily available

~ Up to date

|n/a

Remarks:







7. Groundwater Monitoring Records

13 Readily available

~ Up to date

~ n/a

Remarks:







8. Leachate Extraction Records

~ Readily available

~ Up to date

|n/a

Remarks:







9. Discharge Compliance Records







~ Air ~ Readily available ~ Up to date

0N/A

~ Water (effluent) ~ Readily available ~ Up to date

Sn/a

Remarks: Treatment svstem is no longer operating







10. Daily Access/Security Logs

~ Readily available

~ Up to date

Sn/a

Remarks:







IV. O&M COSTS

1. O&M Organization







[~l State in-housc

~ Contractor for state





1 1 PRP in-housc

1X1 Contractor for PRP





l~l Federal facility in-house

O Contractor for Federal facility



n O&M Costs arc suininari/ed in the FYR Reoort







2. O&M Cost Records







[~l Readily available

~ Up to date





[~l Funding mechanism/agreement in place ~ Unavailable





Original O&M cost estimate: HI Breakdown attached





G-2

-------
From:

Total annual cost by year for review period if available
To:			

Date

From:

Date

To:

Total cost

Date

From:

Date

To:

Total cost

Date

From:

Date

To:

Total cost

Date

From:

Date

To:

Total cost

O Breakdown attached
O Breakdown attached
O Breakdown attached
O Breakdown attached
O Breakdown attached

Date

Date

Total cost

3. Unanticipated or Unusually High (MM Costs during Review Period
Describe costs and reasons:	

V. ACCESS AND INSTITUTIONAL CONTROLS ^ Applicable ~ N/A

A. Fencing

1. Fencing Damaged

Remarks:	

~ Location shown on site map ^ Gates secured ~ N/A

B. Other Access Restrictions

1. Signs and Other Secu rity Measu res

Remarks

~ Location shown on site map ~ N/A

C. Institutional Controls (ICs)

Implementation and Enforcement

Site conditions imply ICs not properly implemented
Site conditions imply ICs not being fully enforced
Type of monitoring (e.g., self-reporting, drive by): __

Frequency:	

Responsible party/agency:	

Contact 	

~	Yes ~ No IK1 N/A

~	Yes ~ No [XJN/A

Title

Name
Reporting is up to date
Reports arc verified by the lead agency

Specific requirements in deed or decision documents have been met
Violations have been reported

Other problems or suggestions: [~~| Report attached

Date



Phone no.

l~l Yes

~

No

IXlN/A

l~l Yes

~

No

0N/A

[~l Yes



No

~ n/a

[~l Yes

~

No

Sn/a

2.

~ ICs arc adequate

ICs arc inadequate

~ N/A

Adequacy

Remarks: Institutional controls are in draft form and will be implemented when a viable owner aquires the site
property. Institutional controls are needed for areas of off-site groundwater contamination and on-site soils..

G-3

-------
D. General

1.	Vandalism/Trespassing ~ Location shown on site map	No vandalism evident
Remarks:	

2.	Land Use Changes On Site	N/A

Remarks:	

3.	Land Use Changes Off Site	N/A

Remarks:	

VI. GENERAL SITE CONDITIONS

A.	Roads	^ Applicable ~ N/A

1. Roads Damaged	~ Location shown on site map Roads adequate ~ N/A

Remarks:	

B.	Other Site Conditions
Remarks:	

VII. LANDFILL COVERS ~ Applicable ^ N/A

VIII.	VERTICAL BARRIER WALLS ~ Applicable g] N/A

IX.	GROUNDWATER/SURFACE WATER REMEDIES E3 Applicable ~ N/A

A. Groundwater Extraction Wells, Pumps and Pipelines	[3 Applicable ~ N/A

1.	Pumps, Wellhead Plumbing and Electrical

~	Good condition	~ All required wells properly operating ~ Needs maintenance ~ N/A

Remarks: The groundwater extraction and treatment system is no longer in use and will be removed from the
Site when a new remedy is implemented.

2.	Extraction System Pipelines, Valves, Valve Boxes and Other Appurtenances

~	Good condition	~ Needs maintenance
Remarks: Treatment system is no longer operating.

3. Spare Parts and Equipment
~ Readily available	~ Good condition

Remarks: Treatment system is no longer operating.

1. Collection Structures, Pumps and Electrical

~ Good condition	~ Needs maintenance

~ Requires upgrade ~ Needs to be provided

~ Applicable N/A

B. Surface Water Collection Structures, Pumps and Pipelines

2.	Surface Water Collection System Pipelines, Valves, Valve Boxes and Other Appurtenances
[~l Good condition	~ Needs maintenance

Remarks:	

3.	Spare Parts and Equipment

~ Readily available	~ Good condition ~ Requires upgrade ~ Needs to be provided

Remarks:	

G-4

-------
C. Treatment System ~ Applicable N/A

1. Treatment Train (check components that apply)



[~l Metals removal O Oil/water separation ~ Biore mediation

~ Air stripping ~ Carbon adsorbers



1 1 Filters:



n Additive (e.g.. chelation agent, flocculent):



1 1 Others:



l~l Good condition ~ Needs maintenance



l~l Sampling ports properly marked and functional



[~l Sampling/maintenance log displayed and up to date



[~l Equipment properly identified



n Ouantitv of groundwater treated annually:



n Ouantitv of surface water treated annuallv:



Remarks: Treatment svstem is no longer operating.



2. Electrical Enclosures and Panels (properly rated and functional)



E3 N/A O Good condition ~ Needs maintenance



Remarks:



3. Tanks, Vaults, Storage Vessels



E3 N/A O Good condition O Proper secondary containment

[~l Needs maintenance

Remarks:



4. Discharge Structure and Appurtenances



E3 N/A O Good condition O Needs maintenance



Remarks:



5. Treatment Building(s)



E3 N/A ~ Good condition (esp. roof and doorways)

O Needs repair

l~l Chemicals and equipment properly stored



Remarks:



6. Monitoring Wells (pump and treatment remedy)



E3 Properly secured/locked ^ Functioning ^ Routinely sampled

E3 Good condition

E3 All required wells located Q Needs maintenance

~ N/A

Remarks:



D. Monitoring Data

1. Monitoring Data



E3 Is routinely submitted on time [3 Is of acceptable quality

2. Monitoring Data Suggests:



E3 Groundwater plume is effectively contained ^ Contaminant concentrations arc declining

G-5

-------
E. Monitored Natural Attenuation	

1. Monitoring Wells (natural attenuation remedy)

~	Properly secured/locked	~ Functioning ~ Routinely sampled ~ Good condition

~	All required wells located	~ Needs maintenance	N/A
Remarks:	

X. OTHER REMEDIES

If there are remedies applied at the site and not covered above, attach an inspection sheet describing the physical
nature and condition of any facility associated with the remedy. An example would be soil vapor extraction.
	XI. OVERALL OBSERVATIONS	

A	.	Implementation of the Remedy	

Describe issues and observations relating to whether the remedy is effective and functioning as designed. Begin
with a brief statement of what the remedy is designed to accomplish (e.g., to contain contaminant plume,
minimize infiltration and gas emissions).

The groundwater extraction and treatment system removed approximately 35 pounds of VOCs between 1998 and
2004. The PRP contractor performed pilot studies and drafted an FFS to adjust the remedy. EISB performed in
2005 did not affect the overall plume extent. The SVE system removed approximately 160 pounds of VOCs

	

B	.	Adequacy of O&M	

Describe issues and observations related to the implementation and scope of O&M procedures. In particular,
discuss their relationship to the current and long-term protcctivcness of the remedy.

The PRP contractor maintains the Site, associated structures, grounds, fencing, and monitoring wells in good and

C.	Early Indicators of Potential Remedy Problems	

Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high frequency of
unscheduled repairs that suggest that the protcctivcness of the remedy may be compromised in the future.

A final remedy for groundwater treatment is forthcoming in a future decision document.

P.	Opportunities for Optimization	

Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.

None.

Site Inspection Participants:

Jeff Ahrens, Geosyntec

Chris Slocum, Project Manager, SCDHEC

Sara MacDonald, SCDHEC

Evan Etheridge, SCDHEC

Benjamin Bair, SCDHEC

Timothy Kadar, SCDHEC

G-6

-------
APPENDIX H - DETAILED ARARs REVIEW

Appendix H includes a review of relevant, site-related documents including the RODs, A ROD, remedial
action reports and recent monitoring data. CERCLA Section 12 l(d)( 1) requires that Superfund remedial
actions attain "a degree of cleanup of hazardous substance, pollutants, and contaminants released into
the environment and of control of further release at a minimum which assures protection of human
health and the environment." The remedial action must achieve a level of cleanup that at least attains
those requirements that are legally applicable or relevant and appropriate. In performing the FYR for
compliance with AR ARs, only those AR ARs that address the protectiveness of the remedy are reviewed.

•	Applicable requirements are those cleanup standards, standards of control, and other substantive
requirements, criteria or limitations promulgated under federal environmental or state
environmental or facility siting laws that specifically address a hazardous substance, remedial
action, location, or other circumstance found at a CERCLA site.

•	Relevant and appropriate requirements are those standards that, while not "applicable," address
problems or situations sufficiently similar to those encountered at the CERCLA site that their use
is well suited to the particular site. Only those state standards that are more stringent than federal
requirements may be applicable or relevant and appropriate.

•	To-Be-Considered (TBC) criteria are non-promulgated advisories and guidance that are not
legally binding but should be considered in determining the necessary remedial action. For
example, TBCs may be particularly useful in determining health-based levels where no ARARs
exist or in developing the appropriate method for conducting a remedial action.

Chemical-specific ARARs are health- or risk-based numerical values or methodologies which, when
applied to site-specific conditions, result in the establishment of numerical values. These values
establish an acceptable amount or concentration of a chemical that may remain in, or be discharged to,
the ambient environment. Examples of chemical specific ARARs include Maximum Contaminant
Levels (MCLs) under the federal Safe Drinking Water Act and ambient water quality criteria
enumerated under the federal Clean Water Act (CWA).

Action-specific ARARs are technology- or activity-based requirements or limits on actions taken with
respect to a particular hazardous substance. These requirements are triggered by a remedial activity,
such as discharge of contaminated groundwater or in-situ remediation.

Location-specific ARARs are restrictions on hazardous substances, or the conduct of the response
activities solely based on their location in a special geographic area. Examples include restrictions on
activities in wetlands, sensitive habitats, and historic places.

Remedial actions are required to comply with the chemical specific ARARs identified in the ROD. In
performing the five-year review for compliance with ARARs, only those ARARs that address the
protectiveness of the remedy are reviewed (Tables H-l through H-5).

H-l

-------
Table H-l: Chemical Specific ARARs

Standard, Requirement, or Criterion

Description

Citation

WATER REGULATIONS (Safe Drinking Water Act - 40 USC ' 300; Clean Water Act - 33 USC Section 1251-1376)

Federal Groundwater Classification

Federal classification system to establish groundwater
usage categories for aquifers as part of a groundwater
protection strategy.

55 FR Part 8733

National Primary Drinking Water Regulations

Establishes maximum contaminant levels (MCLs) for
specific chemicals to protect drinking water quality.

40 CFR 141.61

Ambient Water Quality Criteria

Establishes recommended highest concentration of
specific pollutants or parameters in water to protect
ambient water quality.

40 CFR 131.5

National Pollutant Discharge Elimination System

Discharges of extracted/treated Groundwater will be
subject to Substantive requirements of the NPDES
process if discharged to Local stream. NPDES is
administrated by the State.

40 CFR 122, 125

Effluent Guidelines and Standards:
Pre treatment Standards

Discharges of extracted/treated Groundwater will be
subject to Pretreatment requirements if discharged to the
publicly owned treatment works.

40 CFR 403

South Carolina MCLs in Drinking Water

Establishes maximum contaminant levels (MCLs) for
specific chemicals to protect drinking water quality.

SCDHEC R 61- 58.5

H-2

-------
Table H-2: Location Specific ARARs

Standard, Requirement, or Criterion

Description

Citation

Fish and Wildlife Coordination Act

The Act allows the Department of
Agriculture and Commerce to assist Federal
and State agencies to study the effects of
domestic sewage, trade wastes, and other
polluting substances on wildlife.

16 USC Sections 661 to 667e

Protection of Wetlands

Requires federal agencies to take action to
avoid adversely affecting wetlands, to
minimize wetlands destruction, and to
preserve the value of wetlands.

(Executive Order 11990; 40 CFR 6.302
(a); 40 CFR Part 6, Appendix A)

Standard, Requirement, or Criterion

Description

Citation

Installation of Monitoring Wells

Requirements for installation of wells

SC Well Standards
(R.61-71)

Groundwater ARARs

The 1989 ROD identified multiple potential chemical specific ARARs for groundwater. However, only the following ARAR was used as
basis for selection of groundwater cleanup goals:

• National Primary Drinking Water Standards (MCLs) (40 CFR Part 141, Subpart B and G)

This FYR compared groundwater ARARs in the 1989 ROD against the current values of these ARARs (see Table 1-4). None of the ARARs
have changed since 1989. In addition, no new MCLs have been established for those remedial goals originally based on risk.

H-3

-------
Table H-4: Groundwater ARAR Review

Contaminant

1989 ROD
Cleanup Levels
(Pg/L)1'

Current ARAR (MCL)
(jig/L)c

ARARs More or
Less Stringent than
Cleanup Levels?

1,1 -Dichloroethene

7

7

None

1,2-Dichloroethene

70-cis
100-trans

70
100

None

1,1,1 -Trichloroethane

200

200

None

Trichloroethene

5

5

None

Lead

5

15c

Less stringent

Notes:

a)	Cleanup goals from 1989 ROD. Tabic 23.

b)	Listed values arc MCLs from httDs://www.eDa.eov/eroimd-water-and-dririking-water/table-reeulated-drinkirig-

water-coritarniriants. accessed 12/02/22.

c) Lead is regulated by a treatment technique that requires systems to control the corrosivcncss of their water. If
more than 10 percent of tap water samples exceed the action level, water systems must take additional steps. For
lead, the action level is 15 ng/L.

Hg/L = micrograms per liter

Surface Water ARARs

The 1989 ROD identified the ambient water quality conditions in the Water Quality Criteria (WQC) as a chemical specific ARARs for
surface water. The 1989 ROD stated that the rate and level of groundwater discharge of contaminants into Fishing Creek would not surpass
the ambient WQC for the COCs. This FYR compared surface water ARARs in the 1989 ROD against the current values of these ARARs (see
Table 1-5). Several ambient WQC have changed becoming more or less stringent. Due to these changes, long-term monitoring should use
current WQC when evaluating impacts to surface water.

H-4

-------
Table H-5: Surface Water ARAR Review

Contaminant

1989 ROD WQC
(*ig/L)a

Current ARAR
(fig/Lf

ARARs More or Less
Stringent than Cleanup
Levels?

Acetone

-

Criteria currently
not established

N/A

1,1 -Dichloroethane

-

Criteria currently
not established

N/A

1,1 -Dichloroethene

0.033

300

Less Stringent

Trans 1,2-Dichloroethene

-

100

More Stringent

Cis 1,2-Dichloroethene

-

Criteria currently
not established

N/A

1,1,1 -Trichloroethane

19,000

10,000

Less Stringent

Trichloroethene

2.7

0.6

More Stringent

Lead

-

Criteria currently
not established

N/A

Notes:

a)	Cleanup goals from 1989 ROD. Tabic 23.

b)	WQC for human health (human health for the consumption of water + organism) accessed at
- = WQC not available at the time of the 1989 ROD.

N/A = cleanup goal was not based on an ARAR; therefore, no ARAR change was included.
p,g/L = micrograms per liter

Soil ARARs

The 1989 ROD did not identify chemical specific ARARs for soil. The multi-phase Remedial Investigation/Feasibility Study (Rl/FS) between
1987 and 1989 determined the removal activities at the Site were effective in remediating/removing any chemicals of potential concerns
(COPC). The remedy for OU-1 required additional investigation of the disposal area north of OU-1. This area was identified as OU-2. In
1995 the EPA issued a ROD of no further action as the final remedy for OlJ-2.

H-5

-------
APPENDIX I - TOXICITY ASSESSMENT

A baseline risk assessment (BRA) was completed for OU-1 at the Carol awn. Inc. site as part of the 1989
ROD.

OH-1

The BRA for OU-1 evaluated the risks to human health and the environment under present day and
assumed future use conditions. The BRA considered the potential release mechanisms to the five
primary environmental media of concern: air, soil, surface water, sediment, and groundwater.

The BRA identified the following potential human exposure pathways associated with the Site:

•	inhalation, consumption, and dermal contact of contaminated groundwater;

•	inhalation, consumption, and dermal contact of contaminated surface water; and

•	consumption of contaminated fish from Fishing Creek.

The COCs identified for the Site are VOCs and one heavy metal. More specifically: acetone, 1,1-
dichloroethane (1,1 -DCA), 1,1 -dichloroethene (1,1 -DCE), 1,2-dichloroethene (1,2-DCE), 1,1,1-
trichloroethane (1,1,1-TCA), trichloroethene (TCE) and lead.

No new exposure pathways were identified. No new methodologies to determine risk more accurately
were identified during this Five-Year Review. Groundwater cleanup levels, apart from acetone, are
based the National Primary Drinking Water Regulations Maximum Contaminant Levels and are not
addressed further. Acetone was based on a lifetime health advisory rather than an ARAR.

The RSLs for cancer are chemical-specific concentrations for individual contaminants that correspond to
an excess cancer risk level of 1 x 10"6 (or a hazard quotient of 1 for non-carcinogens), and they have
been developed for a variety of exposure scenarios (e.g., residential, commercial/industrial). RSLs are
not de facto cleanup standards for a Superfund site, but they do provide a good indication of whether
actions may be needed to address potential human health exposures. The EPA acceptable risk range is
between 1 x 10"6 and 1 x 10"4 RSL values that are within this range are determined from a risk
standpoint to be acceptable.

To evaluate the protectiveness of the acetone groundwater cleanup goal, a screening-level risk
evaluation was conducted by comparing the acetone groundwater cleanup goal to the EPA's residential
tap water RSL and calculating a corresponding risk value (Table 1-1). The cleanup goal corresponds to a
noncarcinogenic HQ of 0.038 (below EPA's threshold value of 1), indicating that this cleanup goal
remains valid.

1-1

-------
Table 1-1: Review of Groundwater Remedial Goals

Contaminant

Groundwater
Remedial Goal

Tapwafer RSLb

Risk

HQ*

10"6 Risk

HQ= 1

Acetone

700

-

18,000

-

0.038

Notes:

a)	Cleanup goal from 1989 ROD

b)	Current EPA RSLs, dated Mav 2022, are available at http://www2.e0a.eov/risk/risk~tosed-screenine-table-eeneric-tables (accessed
12/01/22).

c)	The noncancer HQ was calculated using the following equation: HQ = (cleanup goal noncancer RSL).

- = no RSL available/unable to calculate risk

Hg/L = micrograms per liter

OU-2

To address an uncertainty stemming from insufficient confirmatory data of the 1982 and 1986 removal
action of soil in the storage area north of OU-1, a RI and BRA were conducted on OlJ-2 in 1994. The
BRA for OlJ-2 considered the potential release mechanisms of CO PCs from the Site to two primary,
environmental media of concern: soils, surface water and sediment. There were no COPCs identified for
surface water. Therefore, exposure to surface water was not considered a potentially significant risk to
human health or the environment and the surface water pathway was eliminated as an exposure pathway
of concern. Furthermore, the EPA determined a remedial action was not warranted for the surface water
in Fishing Creek.

Potential human exposure routes (for adults and children) evaluated in the BRA for OlJ-2
included the following:

•	Incidental ingestion of surficial soil,

•	Dermal contact with surficial soil,

•	Incidental ingestion of sediment from Fishing Creek, and

•	Dermal contact with sediment in Fishing Creek.

Future potential exposure routes for adults and children associated with Site development that were
evaluated included the scenarios listed above in addition to the following:

•	Incidental ingestion of subsurface soil, and

•	Dermal contact with subsurface soil.

The BRA for OlJ-2 concluded the carcinogenic risk estimates for current and future conditions are either
below the lower limit 1 x 10"6 or within the EPA's acceptable range of 1 x 10"4 to 1 x 10"6. Furthermore,
no noncarcinogenic hazard indices exceeded the EPA's acceptable level of 1.0. Therefore, the EPA
determined that risks to human health from contaminants in the soil and sediment are within the EPA's
acceptable risk range and that remediation of the soil and sediment would not be required for the
protection of human health.

As part of the 1994 RI, forty-one surface and nine subsurface soil samples were collected from 41 grids
within OlJ-2 (Figure 1-1). Four sediment samples were collected from Fishing Creek. The OlJ-2
chemicals of potential concern (COPC) are shown in Table 1-2.

1-2

-------
Table 1-2: OU-2 Soil and Sediment COPCs

COPC

Surface Soil

Subsurface Soil

Sediment

Aluminum



X



Arsenic

X

X

X

Barium

X





Beryllium

X

X



Calcium

X

X



Chromium

X

X



Copper

X





Iron



X



Lead

X

X



Magnesium

X

X



Manganese

X

X



Potassium



X



Sodium

X





Vanadium



X



PCBs

X





Notes:





Source: Table 1, 1995 OlJ-2 ROD

The maximum concentrations for each CO PC from surface soil, subsurface soil and sediment are listed
in Table 1-3 and compared to the current EPA RSL for residential use to estimate corresponding
carcinogenic and noncarcinogenic risk values.

1-3

-------
Table 1-3: OU-2 Soil and Sediment COPC Residential Risk Evaluation

COPC

Maximum
Concentration
(mg/kg)

Residential RSLa (mg/kg)

Residential Risk Evaluation1'

1 x I0"6 Risk

HQ = 1.0

Carcinogenic
Risk

Noncarcinogenic HQ

Aluminum

31,000

NA

77,000

NA

0.4

Arsenic

23

0.68

35

3.4 x 10"5

0.7

Barium

1,200

NA

15,000

NA

0.08

Beryllium

4.1

1,600

160

2.6 x 10"9

0.03

Calcium

49,000

NA

NA

NA

NA

Trivalent

chromium

380

NA

120,000

NA

0.003

Hexavalent

chromium

380

0.3

230

1.27 x 10 3

1.7

Copper

410

NA

3,100

NA

0.1

Iron

50,000

NA

55,000

NA

0.9

Lead

430

400°

NA

NA

Magnesium

26,000

NA

NA

NA

NA

Manganese

1,100

NA

1,800

NA

0.6

Potassium

6,000

NA

NA

NA

NA

Sodium

160

NA

NA

NA

NA

Vanadium

140

NA

390

NA

0.4

PCBs

5.4 (PCB-
1254)

0.24

1.2

2.3 x 10"5

4.5

0.440 (PCB-
1248)

0.23

NA

2.0 x 10-6

NA

0.700 (PCB-
1260)

0.24

NA

3.0 x 10-6

NA

Notes:

Source: Appendix A of 1995 OU-2 ROD

a.	The current EPA RSLs. dated May 2022, arc available at https://www.epa.gov/risk/regional-screening-levels-rsls-
generic-tables (accessed 12/19/2022).

b.	Screening level risk calculations were performed as follows: cancer risk = (maximum concentration/risk-based RSL) x
1 x 10-6

noncancer hazard index = (maximum concent rat ion/HQ-bascd RSL)

c.	The EPA has no consensus reference dose or cancer slope factor for inorganic lead, so it is not possible to calculate
RSLs as it is for other chemicals. The EPA considers lead to be a special case because of the difficulty in identifying
the classic "threshold" needed to develop a reference dose. The EPA evaluates lead exposure by using blood-lead
modeling, such as the Integrated Exposure-Uptake Biokinetic Model. The EPA Office of Solid Waste has also released
a detailed directive on risk assessment and cleanup of residential soil lead. The directive recommends that soil lead
levels less than 400 mg/kg arc generally safe for residential use. Above that level, the document suggests collecting data
and modeling blood-lead levels with the Integrated Exposure-Uptake Biokinetic Model. For the purposes of screening,
therefore. 400 mg/kg is recommended for residential soil.

NA = no RSL available or unable to calculate risk

Bold = exceeds EPA's acceptable risk values

mg/kg = milligrams per kilogram

1-4

-------
Except for lead, hexavalent chromium and PCB-1254, the maximum detected concentrations of CO PCs
in soil and sediment are within the EPA's acceptable risk range for cancer risk and below an HQ of 1 for
noncancer risk.

Lead

The 1995 OU-2 ROD selected a "no action" remedy due to the absence of any significant source of
contamination in soil, surface water, and sediment at the Site. The maximum concentration of lead from
the 1995 ROD was 430 mg/kg (see Table 1-4) and slightly exceeds the residential RSL. Generally, the
EPA recommends utilizing the average lead concentration across the Site to assess lead exposure risk.
The average lead concentration was 66 mg/kg in surface soil, 55 mg/kg in surface and subsurface soil
combined, and 2 mg/kg in sediment (as calculated from concentrations provided in Appendix A of the
1995 OlJ-2 ROD). These values are all below the RSL of 400 mg/kg.

Using the maximum lead concentration of 430 mg/kg, a site-specific risk model was developed using the
IEUBK Model for Lead in Children. Until recently, children were identified as having a blood lead level
of concern if the test result is 10 or more micrograms per deciliter ((.ig/dL) of lead in blood. The CDCs
now use a new level based on the U.S. population of children ages 1-5 years who are in the top 2.5% of
children when tested for lead in their blood. Currently that is 3.5 (.ig/dL of lead in blood. However, the
EPA has not yet issued additional guidance updating the target blood lead level for use in the IEUBK
Model. Therefore, this FYR evaluates the residential lead-in-soil risk using other updated guidance
(such as the maternal blood lead concentration at childbirth (MatPb) in the IEUBK model). Using the
2017 updated MatPb in the IEUBK model, blood lead levels are calculated to be below 10 (.ig/dL using
the maximum lead concentration in soil of 430 mg/kg.

If EPA lowers the acceptable target blood lead level below 10 jug/dl, the EPA will need to reassess the
risk lead poses at the Site. Until such guidance is updated, the OlJ-2 "no action" remedy is currently
protective.

1-5

-------
Table 1-4: Assumptions Used in the IE LIBK Model

Description

Units

Model Input Values

Maternal blood lead
concentrations

(J-g/dL

0.60

Contribution of soil
lead to indoor dust

Percent

30

Concentration in air

micrograms per
cubic meter

0.10

Dietary lead intake





6-12 months



2.66

12-24 months



5.03

24-36 months

(.tg/day

5.21

36-48 months

5.38

48-60 months



5.64

60-72 months



6.04

72-84 months



5.95

Risk-based
concentration

mg/kg

43 0a

Notes:

Values in tabic generated from IEUBK Lead Model Version 2.0 Build 1 for Windows. These IEUBK Model results arc
valid as they were produced with an official, unmodified version of the IEUBK Model with a software certificate.

While IEUBK Model output is generally written with three digits to the right of the decimal point, the true precision of
the output is strongly influenced by least precise input values.

a) Value obtained from 1995 ROD for OU-2 (see Table J-3).

1-6

-------
PCB-1254

The maximum concentration of PCB-1254 exceeded the non-cancer RSL of 1.2 mg/kg with a resulting
HQ of 4.5. PCB-1254 was detected in nine soil samples ranging in concentration from 0.028 to 5.4
mg/kg. Two of the nine samples (1-SLA and 4-SLA) contained PCB-1254 concentrations above the
non-cancer RSL. The highest concentration was detected in surface soil sample 1-SLA, which also
contained PCB-1248 and PCB-1260. Soil sampling location 4-SLA (with a concentration of 2.9 mg/kg
PCB-1254) was a surface soil sampling location located in the West Drum Area. See sample locations
below in Figure 1-1.

Chromium

It is unknown whether concentrations of chromium are in the trivalent or hexavalent form, so this
screening level risk evaluation analyzed the maximum chromium concentration against both RSLs.
When compared to the less toxic trivalent chromium, the concentration was below EPA's target HQ of
1. However, when compared to the hexavalent chromium RSLs, the concentration corresponded to
cancer risk above EPA's acceptable risk range and noncancer risk above an HQ of 1. This sample was
from a surface soil sampling location located in the West Drum Area (4-SLA).

Though maximum concentrations of hexavalent chromium and PCB-1254 exceed residential RSLs, this
screening is conservative because use of maximum concentrations in the assessment may overestimate
risk. In addition, residential RSLs were used, and this area is not currently used residentially. There is
minimal potential exposure, as this site area is only used by hunters, and a recreational receptor is
assumed to be on site less frequently and for a shorter duration than is assumed in the residential soil
RSLs. However, to ensure long-term protectiveness institutional controls restricting land use need to be
implemented.

1-7

-------
SOIL SAMPLE LOCATION MAP

CAJROLAWN SITE
FT. LAWN, SOOTH CAROLINA

Figure 1-1: OU-2 Soil Sample Location Map

sizEPA

< IN f££T >
t Inch • 130 ft.

1-8

-------
APPENDIX J - SITE PHOTOGRAPHS

W

SUPEBfUNDCLFAISUP
Environmental Protection Agency

(NO TRESPASSING)

¦¦B

Site Photograph J-l: Entrance to Carolawn Inc. Treatment Building Area

J-l

-------
-------
-------


Site Photograph J-4: Panoramic View of the Savannah Springs Farm Hunt Club (near monitoring wells MW-7, MW-13, and MW-17)

J-4

-------
Site Photograph J-5: New Structure Under Construction at Savannah Springs Farms Hunt Club (near MW-7)

J-5

-------
-------
Site Photograph J-7: Fishing Creek Near Monitoring Wells 10A & JOB

J-7

-------
-------