AMENDED
RECORD OF DECISION
SHURON INC. SUPERFUND SITE
EPA ID: SCD003357589
Barnwell, Barnwell County, South Carolina
Prepared by:
U. S. Environmental Protection Agency
Region 4
Atlanta, Georgia
September 2010
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Table of Contents
Section Section Name Page #
List of Acronyms 4
Part 1 THE DECLARATION 6
1.1 Site Name and Location 6
1.2 Purpose 6
1.3 Assessment of Site 7
1.4 Description of Amended Selected Remedy 7
1.5 Statutory Determinations 10
1.6 Data Certification Checklist 10
1.7 Authorizing Signature 11
Part 2 THE DECISION SUMMARY 12
2.1 Site Name, Location, and Brief Description 12
2.2 Site History and Enforcement Activities 13
2.2.1 Activities that lead to the current problem 13
2.2.2 History of Investigations and Events 13
2.2.3 Enforcement Activities 14
2.3 Community Participation 15
2.3.1 Community Involvement Plan 15
2.3.2 Fact Sheets 15
2.3.3 Newspaper Articles and Ads 15
2.3.4 Community Meetings and Interviews 15
2.3.5 Information Repositories and Administrative Record 16
2.4 Scope and Role of Response Action 17
2.5 Site Characteristics 17
2.5.1 Conceptual Site Model 17
2.5.2 Site Overview 17
2.5.3 Surface and Subsurface Features 18
2.5.4 Sampling Strategy 18
2.5.5 Known and/or Suspected Sources of Contamination 19
2.5.6 Types of Contamination and Affected Media 19
2.5.7 Location of Contamination and Migration 19
2.5.8 Groundwater Description 20
2.6 Current and Potential Future Land and Water Uses 21
2.6.1 Land Uses 21
2.6.2 Groundwater Uses 21
2.6.3 Surface Water Uses 21
2.7 Summary of Site Risks 22
2.7.1 Summary of Human Health Risk Assessment 22
2.7.2 Summary of Ecological Risk Assessment 28
2.7.3 Conclusion 30
2.8 Remedial Action Objectives 31
2.9 Description of Alternatives 31
2.9.1 Description of Remedy Components 32
2.9.2 Common Elements and Distinguishing Features of Alternatives 40
2.9.3 Expected Outcomes of Alternatives 40
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Table of Contents (continued)
Section Section Name Page #
2.10 Comparative Analysis of Alternatives 41
2.10.1 Overall Protection of Human Health and the Environment 41
2.10.2 Compliance with Applicable or Relevant and Appropriate Requirements 43
2.10.3 Long-Term Effectiveness and Permanence 44
2.10.4 Reduction of Toxicity, Mobility, or Volume Through Treatment 45
2.10.5 Short-Term Effectiveness 46
2.10.6 Implementability 47
2.10.7 Cost 48
2.10.8 State/Support Agency Acceptance 48
2.10.9 Community Acceptance 49
2.10.10 Summary of Alternative Evaluation Comparison 50
2.11 Principal Threat Wastes 50
2.12 Amended Selected Remedy 51
- 2.12.1 Summary of the Rationale for the Amended Selected Remedy 51
2.12.2 Description of the Amended Selected Remedy 51
2.12.3 Summary of the Estimated Amended Remedy Costs 54
2.12.4 Expected Outcomes of the Amended Selected Remedy 54
2.13 Statutory Determinations 55
2.13.1 Protection of Human Health and the Environment 55
2.13.2 Compliance with Applicable or Relevant and Appropriate Requirements 56
2.13.3 Cost Effectiveness 56
2.13.4 Utilization of Permanent Solutions and Alternative Treatment (or 57
Resource Recovery) Technologies to the Maximum Extent Practicable (MEP)
2.13.5 Preference for Treatment as a Principal Element 57
2.13.6 Five-Year Review Requirements 57
2.14 Documentation of Significant Changes from Preferred Alternative of Proposed
Plan 57
Part 3 RESPONSIVENESS SUMMARY 59
Part 4 REFERENCES 60
Appendices
A Figures
B Tables
C Photographs
D State Concurrence Letter
E Written Public Comments
F Power Point Slides presented at the August 30, 2010 Public Meeting
G Public Meeting Transcript, August 30, 2010
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Table of Contents (continued)
List of Figures, Tables and Photographs
Appendix A - List of Figures
1 General Location
2 Site Location
6-5 Conceptual Site Model
A-2 Site Diagram indicating areas of excavation
Contaminated Groundwater Plume
Appendix B - List of Tables
1 Chronology of Events
2 Remedial Investigation Maximum Concentrations per Media
3 Summary of Chemicals of Concern (COC) for Groundwater and Medium-Specific Exposure
Point Concentrations
4 Cancer Toxicity Data for Groundwater COCs
5 Non-Cancer Toxicity Data for Groundwater COCs
6 Risk Characterization Summary - Carcinogens for Groundwater COCs - Future Indoor
Worker
7 Risk Characterization Summary - Carcinogens for Groundwater COCs - Future Outdoor
Worker
8 Risk Characterization Summary - Carcinogens for Groundwater COCs - Future On-site
Resident
9 Risk Characterization Summary - Non-Carcinogens for Groundwater COCs - Future Indoor
Worker
10 Risk Characterization Summary - Non-Carcinogens for Groundwater COCs - Future
Outdoor Worker
11 Risk Characterization Summary - Non-Carcinogens for Groundwater COCs - On-Site
Resident
12 Occurrence, Distribution and Selection of Ecological Chemicals of Concern
13 ARARs
14 Groundwater Alternative 1 Estimated Costs (No Action)
15 Groundwater Alternative 2 Estimated Costs (MNA with FYRs)
16 Groundwater Alternative 3 Estimated Costs (P&T with FYRs)
17 Groundwater Alternative 4 Estimated Costs (P&T in source areas with FYRs)
18 Groundwater Alternative 5 Estimated Costs (P&T at border with FYRs)
19 Groundwater Alternative 6 Estimated Costs (EAB)
20 Summary of Groundwater Alternatives Evaluation
21 Groundwater Clean-up Levels
Appendix C - List of Photographs
1 Shuron building and front parking lot in September 2005
2 View facing west at limit of excavation/restoration area in September 2005
3 Monitoring Well MW-274 in September 2005
4 Tracer Study Test Area in September 2005
5 Sump 4 in September 2005
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List of Acronyms and Abbreviations
AOC Administrative Order on Consent
ARARs Applicable or Relevant and Appropriate Requirements
AWQC Ambient Water Quality Criteria
BERA Baseline Ecological Risk Assessment
BRA Baseline Risk Assessment
CDI chronic daily intake
CDM Camp, Dresser & McKee
CERCLA Comprehensive Environmental Response, Compensation and Liability Act
CFR Code of Federal Regulations
cis-1,2-DCE cis-1,2-dichloroethene
COC Chemical of Concern
COPC Chemical of Potential Concern
DHC Dehalococcoides spp. (dechlorinating bacteria)
EAB Enhanced Anaerobic Bioremediation
ENR Engineering News-Record
EPA United States Environmental Protection Agency
EPC Exposure Point Concentration
ERA Ecological Risk Assessment
ESD Explanation of Significant Differences
FS Feasibility Study
FYR Five-Year Review
HEAST Health Effects Assessment Summary Tables
HI Hazard Index
HQ Hazard Quotient
IC Institutional Control
IEUBK Integrated Exposure Uptake Biokinetic Model for Lead in Children
IRIS Integrated Risk Information System
m3 cubic meters
MCLs Maximum Contaminant Levels
mg milligrams
mg/kg milligrams per kilogram
mg/L milligrams per liter
MNA Monitored Natural Attenuation
NCP National Oil and Hazardous Substances Contingency Plan
NPL National Priorities List
O&M Operations and Maintenance
ORNL Oak Ridge National Laboratory
OU Operable Unit
PCE tetrachloroethene or tetrachloroethylene
pH a unit of measurement of acidity or alkalinity
PRP Potentially Responsible Party
RAGS Risk Assessment Guidance for Superfund
FJAO Remedial Action Objectives
RfD Reference Dose
RG Remedial Goal
ROD Record of Decision
Rl Remedial Investigation
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List of Acronyms and Abbreviations (continued)
SCDHEC South Carolina Department of Health and Environmental Control
SDWA Safe Drinking Water Act
SF slope factor
SHRTSC United States Environmental Protection Agency, Superfund Health Risk
Technical Support Center
TCE trichloroethene or trichloroethylene
UAO Unilateral Administrative Order
pg/dL micrograms per deciliter
pg/L micrograms per liter
VC Vinyl Chloride
VOCs Volatile Organic Compounds
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PART 1: 1 ME DECLARATION
Note: Portions of this, document were copied directly from pre-existing Site documents,
including, but not limited to, the 1999 Record of Decision, the 2006 Five-Year Review and
the 2009 Feasibility-Study Amendment,
1.1 SiJc Name and Location
This Amended Record of Decision is for the Shuron Inc. Site, which is located at approximately
1430 Clinton Street1, in Barnwell, Barnwell County, South Carolina. The United Stales
Environmental Protection Agency (EPA) Site Identification Number for the Shuron Inc. Site is
SCD0O3357589, The I998 Record of Decision (ROD) addressed the entire site as one Operable
Unit (OU).
1.2 Purpose
EPA is updating the selected remedy for the Shuron Inc. Site (the Site) by amending certain
aspects of the ROD. EPA is the lead agency for this Site and the South Carolina Department of
Health and Environmental Control (SCDHECl is the support agency. SCDHEC concurs with the
amended selected remedy.
New groundwater data and additional information obtained during the remedial design and
remedial action, led EPA to re-evaluate the remedy, EPA has concluded that specific
fundamental changes are needed to the original clean-up plan for the groundwater component of
the remedy. The original remedy was selected in EPA's September 9. 1998 ROD. EPA is
amending the prior remedy decision in accordance with Section 117 of the Comprehensive
Environmental Response, Compensation and Liability Act of I WO (CERCLA), as amended, and
pursuant to Title 40 of the Code of Federal Regulations (CFR i Section 300.435(eM2MiiM A)
through (II). Federal Register 8666. 8852. dated March 1990. In accordance with 40 CFR
Section 300.825(a)(2), this ROD Amendment will become part of the Administrative Record for
the Site. Please refer to Section 2 3 of this ROD Amendment for the location of die information
repositories.
EPA is updating the selected remedy based on the new information received after the 1998 ROD
was approved. As with many Superfund sites, the problems at the Shuron Site are complex. The
1998 ROD was vague about the treatment technology to be selected for the contaminated
groundwater, indicating that further studies would he needed. The remedial action implemented
in 2001 was successful at reducing the amount of contamination in soils and sediments by
removing approximately 60,300 eubte yards of contaminated media from the Site. During the
remedial action, the Potentially Responsible Party's (PRP) contractor pumped groundwater for a
short duration as prescribed by the ROD. Due to complex geology, pumping of groundwater
1 Historical documents indicate the slieel adefress as MO Cfinlws Street Address numbers have been reassigned on
Clinton Street m watt years. The approximate address of 1430 Clinton Street was selected based en location in 8
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Shuron ic'." Srlfl ROD Amendmenl
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produced less than optimal results with low water yields. As a result, several other treatment
options were evaluated. During 2005 through 2008, a pilot study was conducted to evaluate
Enhanced Anaerobic Biorcmediation (EAB). The conclusion of the pilot study indicated that
EAB is the most viable option that has been evaluated to date for the treatment of contaminated
groundwater at the Site. The technology has limitations, as most groundwater remediation
technologies do, but appears to hold the highest chance for remediation success.
The purpose of this ROD Amendment is to change the treatment method for contaminated
groundwater. Ingestion of water extracted from the aquifer poses a potential future risk to
human health because concentrations of contaminants are greater than the Maximum
Contaminant Levels (MCLs) for drinking water, as specified in the Safe Drinking Water Act
(SDWA). The remedy presented in this ROD Amendment is expected to significantly reduce the
concentrations of Volatile Organic Compounds (VOCs) in the groundwater at the site, and
prohibit installation of wells within the contaminated aquifer until clean-up levels are achieved.
1.3 Assessment of Site
The response action selected in this ROD Amendment is necessary to protect the public health or
welfare and the environment from actual or threatened releases of hazardous substances,
pollutants and contaminants from this Site, which may present an imminent and substantial
endangerment.
1.4 Description of Amended Selected Remedy
EAB Technology Description
EAB is an in situ remediation approach that uses indigenous microorganisms in the subsurface to
degrade chloroethenes to ethene and ethane. During EAB, tctrachloroethene' (PCE) is
completely transformed to innocuous byproducts following the reductive dechlorination
pathway: PCE - trichlorocthene (TCE) " cis-l,2-dichloroethcne (cis-l,2-DCE) • vinyl
chloride (VC) -*¦ ethane. EAB generally occurs through the addition of fermentable carbon
compounds that serve as electron donors for subsurface bacteria that use the chloroethenes as
electron acceptors. The hydrogen produced during fermentation reactions is the primary electron
donor for dechlorinating bacteria and drives EAB. This electron transfer process provides the
bacteria with energy for population growth and metabolic activity.
The two primary requirements for successful implementation of EAB are: 1) adequate spatial
distribution of the electron donor to achieve strongly reducing conditions, and 2) a microbial
community capable of complete reductive dechlorination of chloroethenes.
Electron Donors
Electron donors arc commonly available in two basic types: aqueous and "slow-release".
Aqueous electron donors are generally miscible with water and of a viscosity similar to water,
and are therefore relatively easy to distribute in the subsurface. They have the disadvantage that
they typically last only a few months in the subsurface, and therefore have to be reinjected
" Tetrachiorocthene is also known as tetrachloroethylene.
1 Trichloroethene is also known as trichlorocthylene.
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periodically. Slow-release donors are typically lower solubility liquids or solids that last much
longer than aqueous donors, but can be more difficult to distribute in the subsurface.
Redox Conditions
A critical aspect of groundwater chemistry with respect to the fate of chloroethenes is the
oxidation-reduction, or redox, conditions. Chloroethenes serve as electron acceptors in
microbially-mediated redox reactions during reductive dechlorination (including EAB).
Therefore, they have to compete with naturally occurring electron acceptors in groundwater.
The use of electron acceptors is generally governed by the available free energy from redox
reactions. In order of decreasing energy available, some common, naturally occurring electron
acceptors are oxygen, nitrate, iron-Ill, sulfate, and carbon dioxide. At a minimum, oxygen and
nitrate must be depleted for any reductive dechlorination to occur. Dechlorination of PCE and
TCE to cis-l,2-DCE generally occurs under iron-reducing to sulfate-reducing conditions.
Complete dechlorination to ethane typically occurs under sulfate-reducing to methanogenic
conditions (carbon dioxide is the only remaining electron acceptor.) Thus, understanding redox
conditions (aerobic, nitrate-reducing, iron-reducing, sulfate-reducing, or methanogenic) provides
key insight into the potential for reductive dechlorination to occur. The more electron donor
present, the more reducing the conditions will be.
Dechlorinating Bacteria
The dechlorinating bacteria, Dehctlococcoides spp. (DHC), are very important for achieving
complete dechlorination of PCE to ethane in groundwater. While these bacteria are fairly
common, they are not present at every Site, and their absence can lead to the stall of
dechlorination at cis-l,2-DCE. Where DHC is present, EAB can be accomplished through
biostimulation. Biostimulation involves only the addition of electron donors, and potentially
limiting nutrients such as nitrogen and phosphorous or buffers like sodium bicarbonate, and
relies on the indigenous microorganisms to carry out the desired reactions. Where DHC is not
present, EAB requires bioaugmentation. Bioaugmentation is the introduction of either
commercially available microorganisms or transferring indigenous microorganisms from one
area of the site to another as well as addition of electron donors into groundwater to provide a
metabolic capability that either is not present in the native community or can be significantly
enhanced.
m
The pH4 of the groundwater also plays an important role in DHC survival. pH levels in the range
of 5.0 to 5.5 can impede DHC survival and at a pH below 5.0 survival can be problematic for
dechlorination by DHC and therefore pH needs to be monitored and, if necessary, adjusted
during chemical and, when applicable, microorganism addition.
EAB Pilot Test
An EAB pilot test was performed from 2005 to 2008 by biostimulating the subsurface with whey
in an approximate 100 feet by 200 feet area in the east portion of the Site. A full report of this
pilot test is provided in the Enhanced Anaerobic Bioremediation Pilot Test Final Report (CDM,
September 2008). The results of this pilot test showed that chloroethenes in groundwater can be
4 pH is a unit of measurement of acidity or alkalinity of a solution. pH values range between 0 and 14, in which 7 is
neutral. The lower the value, the more acidic the solution is; the higher the value the more alkaline the solution is.
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biodegraded to ethane following biostimulation, although results were not uniform throughout
the test area due to several factors including low pH and difficulties with electron donor
distribution associated with the low soil permeability. Based on the results from the EAB pilot
test, EAB was recommended as the groundwater remedial alternative for the Site.
EAB Implementation
Implementation of EAB will require the installation of injection wells with an approximate 20- to
25-feet spacing between each. It will also require installation of additional monitoring wells to
evaluate the effectiveness of the remedy. An electron donor will be injected into the
contaminated aquifer approximately three separate times. If needed, a buffering agent may also
be added to the aquifer to bring the groundwater pH within an acceptable range for DHC
survival. If necessary, microorganisms may also be added for areas with no or low volumes of
microorganisms.
Monitoring wells throughout the Site will be sampled on a routine basis to evaluate the
effectiveness of the remedy.
Institutional Controls
Although groundwater is not currently being used at the Site, the implementation of Institutional
Controls (ICs) will be the enforceable instrument which will prevent human consumption of
groundwater until clean-up levels are attained. ICs in the form of a Restrictive Covenant will be
placed on the Site property deeds to prevent the installation of wells, not associated with the
remedial action, or use of groundwater until all clean-up levels have been achieved. The
Restrictive Covenant will also require that a Vapor Intrusion Evaluation be performed prior to
constructing any building above the contaminated groundwater plume, and installation of a vapor
mitigation system for any such future building if determined necessary.
Groundwater contamination has migrated off-site onto the adjacent parcel. The plume was
defined in 2007 and is confined to an undeveloped wetland area. Installation of a permanent
supply well in this area is not feasible without significant access improvements, such as building
a road, and is not likely since a municipal supply well already exists across the street. During the
offsite investigation, CDM was unable to install a monitoring well in this area using specialized
drilling equipment for swampy conditions. Even if a supply well were to be installed in the
offsite area, it would be done so below the confining layer (Unit D) based on the limited
production available from the shallow aquifer. Additionally, all wells drilled in South Carolina
require approval from the SCDHEC prior to installation. SCDHEC- would be unlikely to approve
installation of a supply well in the shallow aquifer of the offsite property. Therefore, the IC to be
utilized for this parcel is annual notification to the property owner as a reminder that
groundwater contamination exists on their property and that drinking water, production, or
irrigation wells should not be installed in the area of contamination or within close enough
distance that would affect the groundwater flow of the contaminated area. The notification would
include a copy of the most recent monitoring results. If clean-up levels are not achieved within
10 years of the initiation of the groundwater remedial action, either a Restrictive Covenant or a
governmental control (local ordinance) may be pursued.
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1.5 Statutory Determinations
The Amended Remedy is protective of human health and the environment, complies with
Federal and State requirements that are applicable or relevant and appropriate to the remedial
action, is cost effective, and utilizes permanent solutions and alternative treatment (or resource
recovery) technologies to the maximum extent practicable. For groundwater, which is the focus
of the ROD Amendment, this remedy satisfies the statutory preference for treatment as a
principal element of the remedy.
The National Oil and Hazardous Substances Contingency Plan (NCP) establishes an expectation
that EPA will use treatment to address the principal threats posed by a Site wherever practicable
(NCP §300.430(a)(l )(iii)(A)). There are no principal threat wastes to be addressed as part of
this amended remedy. The principal threat wastes, contaminated soils, were removed from the
Site under the remedial action associated with the 1998 ROD.
Because the remedy for the Site has resulted in hazardous substances, pollutants, or contaminants
remaining on-site in soils at depth, at concentrations above levels that allow for unlimited use
and unrestricted exposure, reviews are required by statute to occur at least every five years. EPA
approved the first Five-Year Review (FYR) for this Site on June 5, 2006. The next FYR is
required to be completed by June 5, 2011. FYRs will continue until the Site is determined to be
acceptable for unlimited use/unrestricted exposure.
1.6 Data Certification Checklist
The following information is included in the Decision Summary section (Part 2) of this Amended
ROD. Additional information can be found in the Administrative Record file for this Site.
K Chemicals of concern and their respective concentrations
K Baseline risk represented by the chemicals of concern
K Clean-up levels established for chemicals of concern and the basis for these level
K How source materials constituting principal threats are addressed
^ Current and reasonably anticipated future land use assumptions and current and
potential future beneficial uses of groundwater used in the Baseline Risk Assessment
and ROD
K Potential land and groundwater use that will be available at the site as a result of the
Selected Remedy
^ Estimated capital, annual operation and maintenance (O&M), and total present worth
costs, discount rate, and the number of years over which the remedy cost estimates are
projected
Key factor(s) that led to selecting the remedy (i.e. describe how the Selected Remedy
provides the best balance of tradeoffs with respect to the balancing and modifying
criteria, highlighting criteria key to the decision)
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1,7 Aii(horlring Signature
This ROD Amendment documents the amended selected remedy for contaminated groundwater
at the Slnifon Inc. Site. EPA selected this amended remedy with the concurrence of" the
SCDHEC. (Appendix D includes the concurrence letter). The EPA Region 4 Director of the
and sign thus ROD Amendment.
Superfund Division
EPA, Region 4
ShurW Irtt 5*e ROD Affiendntml
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PART 2: THE DECISION SUMMARY
Tins Decision Summary provides a description of the site-specific factor that led to (he
amendment of the selected remedy for the Site, It includes background information. the nature
and extent of (he contamination, the risks posed to human and ecological receptors, and die
identification and evaluation of remedial action alternatives. The Site consists of only one OU
EPA i> the lead agency for the site. EPA's Site Identification Number is SCD003357589.
SCDHEC is the support agency. The PRP will conduct the remedial action,
2.1 Site Name, Location, and Brief Description
The Shuron Inc. Site is an 85-acre parcel of land Located at approximately 14 JO Clinton Street5 in
Barnwell Barnwell County, South Carolina. One building (about 185.000 square feet) exists on
approximately 34 acres of land surrounded by a fence In addition to the building, the 34-acrc
parcel includes pa\ ed parking areas and the former wastewater and solids lagoons. The
remaining 51 aeres is predominantly wetlands, also enclosed by fencing.
Jn 1958. Shuron Continental Optical Company, a former division of Textron Inc.. began
operations at the Site, The facility manufactured single and multi-vision ocular tenses. The
facility received lens blanks thai were then ground and shaped using grinding and polishing
compounds. Operations at the facility ceased in early 1992. Currently, the vacant Site is
bounded by residential properties to the north, Turkey Creek to the east, a railroad right-of-way
lo the south, and Clinton Street to the west Figure I and Figure 2, in Appendix A, arc site
location maps.
The major natural physical features of the 8 5-acre parcel are wetlands to the east and south, a
southern drainage ditch, a northern drainage ditch, and Turkey Creek to the east of the site. The
major man-made physical features of the parcel include the building on the western portion of
the site, an abandoned niitroad embankment to the south, a fill debris area to the south of the
building, and site fencing along the periphery of the parcel.
Approximately one-third of the area surrounding the building ts paved, and storm water runoff
from this area is generally to the south and east. The northern drainage ditch and the southern
drainage ditch collect storm water from the facility and drain to the wetlands east and south of
the facility. The wetlands eventually drain to Turkey Creek, located approximately 1,700 feet
cast of the facility. Turkey Creek flows in the southerly direction.
The land use surrounding the site is a mixture of industrial, commercial, undeveloped, and
residential properties, Residences are located immediately northwest and north-northeast of the
Historical documents indicate the strwl address as 110 C linte»n Street. Address numbers hove been reassigned cm
Offllcm 5tmr« tn recent years. The approximate address nf IJ 30 Ctrnlon Street was selected based on location in ¦
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site. Limited commercial development exists west of the site along Clinton Street, and the
properties to the east and south consist primarily of undeveloped, vaeant property.
The nearest known water supply well is the City of Barnwell Well Number 10. This well is
located on the west side of Clinton Street, approximately 375 feet west of the southwest comer
of the Shuron main building. It is screened approximately 180 feet below land surface.
The city of Barnwell had a population of 4,733 in July 2009, according to information presented
at http: 'www ciiv-dat.i com city. Bamwel 1 -Southj'aro I ina .htm I, which is a decrease by 6.0%
from the 2000 census number.
2.2 Site History and Enforcement Activities
This section of the ROD Amendment provides a brief Site history, including previous
investigations, the listing process, and enforcement activities. A chronological summary of
ev ents can be found in Table 1 of Appendix B
2.2.1 Activities that lead to the current problem
From 1958 to 1992, Shuron manufactured ocular leases at the Site. The manufacturing process
invoh ed grinding and shaping of lenses using materials such as aluminum oxide and garnet,
followed by polishing with oxides containing materials such as iron, cerium, and zirconium.
Wastewater from the process was discharged to a scries of four wastewater settling lagoons
immediately east of the main building. Sediment was periodically transferred from the
wastewater lagoons to two solids ponds located immediately south of the wastewater lagoons.
Facility operations produced approximately 270.000 gallons per day of wastewater. This
wastewater contained the fine-grained grinding and polishing compounds, solvents, and waste
oils. It is believed thai the solvent tetraehloroethene was used to clean the lenses after the
grinding and polishing process.
2.2.2 History of Investigations and Events
Inv estigations began at the Site in 1982. Investigations indicated the presence of heavy metals
and chlorinated VOCs in groundwater, surface soils, and sediments. The Preliminary
Assessment was completed in 1991 and the Silt Assessment was completed in 1993. In 1994,
EPA removed drums of hazardous material from the building. The Remedial Investigation (RJ),
including a Supplemental RI Sampling event, and the installation of a fence around the Site was
completed in 1996.
The EPA proposed the site to the National Priorities List (NPL) on June 17, 19%" through
publication of Proposed Rule #20 in the Federal Register: Volume 61. Number 117, page 30578.
* The IROD erroneously (dcnlifkd the tijue of bo lire NPL as Jure M, I Wis The ciktcci proposal dale
was June 17, 1W6.
Stwm be. Sile ROD AmsttdiTenl
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On December 23, 1996, the site was finalized on the NPL through publication in the Federal
Register: Volume 61, Number 247, page 67658.
After the Feasibility Study (FS) was completed, EPA issued the Proposed Plan in November
1997. EPA signed the ROD on September 9, 1998. The ROD included a remedy for
contaminated groundwater, surface soil, subsurface soil, and sediment at the Site. On June 8,
2001, construction began for the selected remedy. The soil and sediment portion of the remedy
was completed in July 2002.
During May through August 2002, post-remedial action groundwater dewatering was conducted.
Beginning in May 2003, groundwater remediation alternatives evaluation and associated
additional characterization activities were conducted.
Quarterly groundwater monitoring began in January 2001. Monitoring frequency was reduced to
semi-annually in September 2005. EPA approved the first FYR in June 2006. An investigation to
determine the extent of off-site migration of the contaminated groundwater plume was completed
in 2007.
In September 2008, EPA approved the Enhanced Anearobic Bioremediation Pilot Test Final
Report. At this point, it was apparent that the groundwater remedy prescribed in the ROD should
be changed. On August 20, 2010, EPA issued an Amended Proposed Plan to inform the public
of the proposed changes to the groundwater remedy. Those proposed changes are memorialized
in this ROD Amendment.
2.2.3 Enforcement Activities
EPA issued General Notice Letters on December 4, 1992. Negotiations between EPA and the
PRP began on August 4, 1994 and were completed on November 21, 1994, on which date EPA
and Textron entered into an Administrative Order on Consent (AOC), Docket No. 95-5-C, for a
Removal Action, RJ and FS at the Shuron Site.
On June 28, 1999, EPA issued a Unilateral Administrative Order (UAO) to Textron, Inc. to
conduct the Remedial Design and Remedial Action for the Site, for the remedy selected in the
1998 ROD.
On June 11, 2007, EPA and Textron, Inc. entered into an Agreement for Recovery of Past and
Future Response Costs, Docket No. CERCLA-04-2007-3762.
EPA has drafted a UAO Amendment to issue to Textron, Inc., that addresses actions required by
this ROD Amendment, and plans to issue the UAO Amendment on the date that EPA signs this
ROD Amendment. The PRP will implement this amended remedy.
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2.3 Community Participation
This section of the Amended ROD describes EPA's community involvement activities. EPA has
communicated with the public through Fact Sheets, meetings, Internet postings, newspaper ads.
and answering email and phone inquiries. The following website includes current Stic
information: hlto://www .cpa.gov'regions ivasle. npl nplsc s huronsc.htm.
2.3.3 Community Relations Plan
EPA prepared a Community Relations Plan in April 1995. It contains an overview of
Supcrfund, Site background, community background, public issues and concerns,
community relations objectives, community relations techniques, schedule of activities,
list of interested parties, information repository, suggested meeting location, technical
assistance grant program, and lexicological profiles of contaminants of concern.
2.3,2 Fact Sheets
Through (he years, EPA has. published several Fact Sheets for the Site The mosi recent
was, the August 2010, Amended Proposed Plan Fact Sheet.
2.3.3 Newspaper Articles and Ads
Through the years, several newspaper articles have been written and advertisements
placed regarding the Site. In March 2006. an article was published in Tfie People-
Sentinel, Barnwell County. SC. which discussed the plans for an upcoming FYR of the
Site and included an interview with Samanlha Urquhart-Foster, EPA Remedial Project
Manager On Augusi 18, 2010, EPA placed an advertisement in The Peopk-Scnnnei
inviting the community to attend a public meeting and announcing the availability of the
Amended Proposed Plan Fact Sheet. On September 8,2010, the managing editor of The
People-Sentinel published an article about (he Site, proposed revisions to the cleanup
plan, and a summary of the public meeting which was held on August 30, 2010.
2J.4 Community Meetings and Interviews
In March 1995, EPA conducted community interviews to inform the nearby residents of
future activities at the site and to determine their concerns.
In Apri l and May of 1997. prior to issuance of the original Proposed Plan for the ROD,
EPA met with local officials to inform them of the results of the sampling activities and
to discuss various options EPA was evaluating to address the Site contamination and to
solicit (heir input. EPA also conducted an availability session in Barnwell on November
20, 1997, to answer questions from the public concerning the sile. Afterw ards, EPA
issued the Proposed Plan in late November 1997. EPA then held two public meetings,
December 9, 1997 and January 22, 1998, where F.PA representatives answered questions
regarding the Site and the remedial alternatives under consideration.
Shufen Int Site. ROD Amersirnont 15 Sopterfeef 2010
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On April 26, 2006, the EPA Remedial Project Manager for the Site and two
representatives of SCDHEC, interviewed three residents that lived near the Site as part of
the FYR process. Those interviewed had no concerns regarding the Site.
On August 30, 2010, EPA conducted a public meeting to present the Amended Proposed
Plan and answer questions regarding the Site and the remedial alternatives under
consideration.
2.3.5 Information Repositories and Administrative Record
The Information Repositories were established in February 1995. EPA updated the
Administrative Record file on August 19, 2010 to incorporate files related to this ROD
Amendment. EPA placed the updated Administrative Record in both information
repositories.
Information Repositories
Barnwell County Public Library
40 Burr Street
Barnwell, SC 29812
Phone: 803-259-3612
Hours (as of 8/2/2010):
Monday, Tuesday,
Wednesday, Friday:
Thursday:
Saturday:
Sunday:
10 a.m. - 6 p.m.
10 a.m. - 9 p.m.
10 a.m. - 2 p.m.
closed
EPA Records Center
61 Forsyth Street, SW
Atlanta, GA 30303-8960
Phone: 404-562-8946
Hours:
Monday - Friday: 8 a.m. - 4 p.m.
Saturday, Sunday: closed
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2.4 Scope and Role of Response Action
As with many Superfund Sites, the problems at the Shuron Site are complex. The 1998 ROD
anticipated only one Operable Unit for the Site. The ROD was vague about the treatment
technology to be implemented for the contaminated groundwater, indicating that further studies
would be needed. The overall clean-up strategy for this Site was to reduce the amount of
contamination in soils, sediments, surface water and groundwater to protect both human and
ecological receptors and return the Site to useable property. The remedial action implemented in
2001 was successful at reducing the amount of contamination in soils and sediments by
removing approximately 60.300 cubic yards of contaminated media from the Site. Additional
studies regarding the best method for addressing contaminated groundwater have been
completed.
The purpose of this Amended response action is to specify the treatment method for
contaminated groundwater. Ingestion of water extracted from this aquifer poses a potential
future risk to human health because EPA's acceptable risk range is exceeded and concentrations
of contaminants are greater than the MCLs for drinking water, as specified in the SDWA. This
ROD Amendment presents a remedy which is expected to significantly reduce the concentrations
of volatile organic compounds in the groundwater at the site.
2.5 Site Characteristics
This section of the Amended ROD provides Conceptual Site Models, an overview of Site
contamination, and a description of groundwater. Detailed information can be found in the Rl,
Risk Assessments and Remedial Design for this Site.
2.5.1 Conceptual Site Model
The Conceptual Site Model identifies sources of contamination, release mechanisms,
affected media and exposure routes. The Conceptual Site Model was presented as Figure
6-5 in the Rl. A copy of that figure is included in Appendix A.
2.5.2 Site Overview
In 1958 Shuron Continental Optical Company, a former division of Textron Inc., began
operating on the 85-acre parcel located in Barnwell, South Carolina. The facility
manufactured single and multi-vision ocular lenses. The facility received lens blanks that
were then ground and shaped using grinding and polishing compounds. Operations at the
facility ceased in early 1992.
Currently, the vacant Site is bounded by residential properties to the north, Turkey Creek
to the east, a railroad right-of-way to the south, and Clinton Street to the west. The land
use surrounding the site is a mixture of industrial, commercial, undeveloped, and
residential properties. Residences are located immediately northwest and north-northeast
of the site. Limited commercial development exists west of the site along Clinton Street,
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and the properties to the east and south consist primarily of undeveloped, vacant
property.
2.5.3 Surface and Subsurface Features
The Site comprises approximately 85 acres. It is currently vacant and overgrown with
vegetation. One main building (about 185,000 square feet) exists on approximately 34
acres of land surrounded by a fence. In addition to the main building, the 34-acre parcel
includes paved parking areas and the former wastewater and solids lagoons. The
remaining 51 acres is predominantly wetlands, also partially enclosed by fencing.
The major natural physical features of the 85-acre parcel are wetlands to the east and
south, a southern drainage ditch, a northern drainage ditch, and Turkey Creek to the east
of the site. The major man-made physical features of the parcel are the main building on
the western portion of the site, an abandoned railroad embankment to the south, a
fill/debris area to the south of the main building, and site fencing along the periphery of
the parcel.
Approximately one-third of the area surrounding the main building is paved, and storm
water runoff from this area is generally to the south and east. The northern drainage ditch
and the southern drainage ditch collect storm water from the facility and drain to the
wetlands east and south of the facility. The wetlands eventually drain to Turkey Creek,
located approximately 1,700 feet east of the fenced facility. Turkey Creek then flows
south. Appendix C contains Site photographs.
2.5.4 Sampling Strategy
The Ri investigated the nature and extent of contamination on and near the Site, and
defined the potential risks to human health and the environment posed by the Site. Over
200 surface and subsurface soil samples were collected and analyzed for various
contaminants. Groundwater samples from 25 wells were collected and analyzed for
different compounds. Sediment samples were collected from 25 locations and analyzed
for various contaminants. Surface water samples were collected from 34 locations and
analyzed. The Final RI Report was completed in January 1997, and the Final FS Report
was completed in April 1997.
Additional soil and sediment samples were collected during the Remedial Action (June
2001 - July 2002) to document attainment of clean-up levels for soil and sediment.
Groundwater samples were collected quarterly from January 2001 through March 2005,
and have been collected semi-annually, at a minimum, since then. Samples are analyzed
for VOCs. In addition to the routine monitoring, additional groundwater samples have
been collected over the years to determine the extent of the contaminated groundwater
plume, evaluate MNA as a potential remedy, and a pilot study to evaluate EAB as a
potential remedy.
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2.5.5 Known and/or Suspected Sources of Contamination
The manufacturing process at the former Shuron facility involved grinding and shaping
of lenses using materials such as aluminum oxide and garnet, followed by polishing with
oxides containing materials such as iron, cerium, and zirconium. Wastewater from the
process was discharged to a series of four wastewater settling lagoons immediately east
of the main building. Sediment was periodically transferred from the wastewater lagoons
to two solids ponds located immediately south of the wastewater lagoons. Facility
operations produced approximately 270,000 gallons per day of wastewater. This
wastewater contained the fine-grained grinding and polishing compounds, solvents, and
waste oils. It is believed that a solvent (tetrachloroethene) was used to clean the lenses
after the grinding and polishing process.
2.5.6 Types of Contamination and Affected Media
Investigations at the Site indicated the presence of heavy metals and chlorinated VOCs in
ground water, surface water, sediment and soils. Table 2, in Appendix B includes a
summary of maximum concentrations detected in each media during the RI.
Source control remedial actions, were initiated in June 2001 and were completed by July
2002. During that remedial action, approximately 52,600 tons of soil and sediment were
excavated and disposed of as non-hazardous waste, and approximately 8,700 tons of soil
and sediment were excavated and disposed of as hazardous waste at off-site landfills.
The remedy intended for the removal of all soils with concentrations above clean-up
levels (or Remedial Goals [RGs]). However, this was not realized in some areas. RGs
were achieved in four of the six areas requiring excavation. For the remaining two areas
(Stage 2 - Solids Lagoons and Stage 4 - Southern Wetland Fill/Debris Area), the
majority of the confirmation samples achieved the RGs. However, some subset areas
were closed with above-RG soil concentrations. Excavation in these areas had exceeded
the initial design and proceeded three to four feet below the water table. The softened
sub grade made it virtually impossible to continue construction activities there and these
areas were backfilled with EPA and SCDHEC approval.
2.5.7 Location of Contamination and Migration
This section of the Amended ROD discusses the lateral and vertical extent of
contamination, current and potential future surface and subsurface routes of human or
environmental exposure, and the likelihood for migration of contaminants.
2.5.7.1 Lateral and Vertical Extent of Contamination
Surface soils, subsurface soils, and sediments were contaminated with VOCs
and metals above clean-up levels derived from the human health or ecological risk
assessments, but have since been removed from the Site. Approximately 61,300
tons of contaminated soil and sediment were excavated and disposed at off-site
landfills during 2001-2002. Figure A-2 illustrates the boundaries of the
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excavated areas. Some subsurface contamination remains in two areas of the Site;
those areas were backfilled with clean soil.
Surface water was contaminated with VOCs and metals at concentrations that
exceed clean-up levels. The contaminated surface water was located in wetlands
and lagoons and was treated during the remedial action in 2001-2002.
Groundwater is contaminated with VOCs at concentrations that exceed MCLs at
the Site and extending beyond the property boundary. Appendix A includes a
figure that illustrates the current contaminated groundwater plume.
2.5.7.2 Current and Potential Future Routes of Human or Environmental
Exposure
The property is currently vacant. Because the contaminated surface soil was
removed from the Site and drinking water wells are not located within the
contaminated groundwater plume, there are no current routes of human exposure.
The potential future routes of human exposure would be from potential future
contact with contaminated subsurface soils encountered during potential future
construction activities, and potential future ingestion of contaminated
groundwater.
2.5.7.3 Likelihood for Migration
Contaminated groundwater has migrated beyond the property boundary. The PRP
has installed monitoring wells on this adjacent property to monitor for further
migration.
2.5.8 Groundwater Description
The Shuron Site is located in the Atlantic Coastal Plain Physiographic Province. The
uppermost geologic units consist of interbedded clayey to silty sand, sand, and silty fill
material. Groundwater in the uppermost unit is encountered at land surface in the
wetlands to approximately three feet below land surface in the uplands. At approximately
20 to 30 feet below land surface, geologic units are encountered which consists of a well
sorted, clean to slightly clayey or silty, sand. At about 65 feet below land surface, a
coarsening downward sequence of stiff clay, silty clay, and silt is encountered.
Regional groundwater flow in the coastal plain is controlled primarily by the gentle
seaward dip of the sediments and by the location of principal recharge areas.
Groundwater flow in the upper most units is primarily toward the nearest surface water
drainage, which is the wetlands to the east and south of the facility. Major marine
transgressions and regressions in the geologic past have created a series of relatively
coarse-grained units overlying and/or underlying relatively fine-grained units. It is this
sequence of deposition, coupled with large-scale structural features, which produced the
major aquifers and confining units throughout the coastal plain. On a smaller scale,
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water-bearing units and water-retarding units exist within each aquifer system. In
Barnwell County, the aquifer systems, in order of increasing depth below the surface,
include the unconfined surficial aquifer, the upper and lower Floridan aquifer, the Black
Mingo aquifer, and the Cretaceous aquifers.
The regional surficial aquifer composes the aquifer of concern beneath the site, and this
aquifer has been subdivided on a site-specific basis into several water bearing zones. The
zones are defined as hydraulic units A/B, Upper C, and Lower C. The primary
groundwater flow direction for the water bearing zones beneath the site is towards the
southeast.
2.6 Current and Potential Future Land and Water Uses
2.6.1 Land Uses
The Site is currently vacant and is zoned for industrial use.
2.6.2 Groundwater Uses
Because the Site is vacant, there are currently no groundwater users at the Site. The
portion of the adjacent property onto which contaminated groundwater has migrated is a
wooded wetland. There are currently no groundwater users on that portion of the
contaminated plume either.
The nearest known water supply well is the City of Barnwell Well Number 10. This well
is located on the west side of Clinton Street, approximately 375 feet west of the
southwest corner of the Shuron main building. It is screened approximately 180 feet
below land surface. This well is located upgradient of the contaminated plume. It is
operated on a routine basis and is currently reserved as a backup supply source. Historical
sampling of this well did not show any VOC contamination.
2.6.3 Surface Water Uses
Humans do not currently use surface water at the Site. However, some citizens of
Barnwell fish recreationally in Turkey Creek, which is located downgradient of the Site.
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2.7 Summary of Site Risks
This section of the Amended ROD discusses a summary of Human Health and Ecological Risks.
Because the risk assessments were not revised only a few tables and a brief discussion are
provided in this section to highlight Site risks. Please refer to the 1998 ROD and the Baseline
Risk Assessment (BRA), which is found in the RJ Report, for a more extensive discussion of
these topics.
2.7.1 Summary of Human Health Risk Assessment
The baseline risk assessment estimates what risks the site poses if no action were taken.
It provides the basis for taking action and identifies the contaminants and exposure
pathways that need to be addressed by the remedial action.
2.7.1.1 Identification of Chemicals of Concern
Data collected during the R1 were evaluated in the BRA. Contaminants were
screened for the BRA using stringent risk-based criteria and by comparison to
background levels for naturally occurring constituents. Contaminants in the
following media were evaluated for human health risk: soil (surface and
subsurface), groundwater (shallow, intermediate, deep), surface water (lagoons,
drainage ditches, creek), and sediment (lagoons, drainage ditches, creek). The risk
assessment evaluated 34 different chemicals which failed the risk-based screening
in one or more of these media.
Contaminants were not included in the BRA evaluation if any of the following
criteria applied:
• For an inorganic compound or element:
o it was not detected at or above twice the background concentration,
or
o it was detected at low concentrations, had very low toxicity, and
was judged to be naturally occurring.
• The sampling data included analytical results that were flagged.
The BRA identified the following as COCs for ground water: bis(2-
ethylhexyl)phthalate, 1,2-dichloroethene, ethylbenzene, tetrachloroethene,
toluene, trichloroethene, vinyl chloride, xylenes, arsenic, copper, lead, and zinc.7
Table 3 in Appendix B presents the COCs and exposure point concentration for
each COC detected in groundwater (i.e., the concentration that was used to
estimate the exposure and risk from each COC in the groundwater). The table
includes the range of concentrations detected for each COC in groundwater
during the RJ, as well as the frequency of detection (i.e., the number of times the
7 Because this ROD Amendment only addresses the groundwater component of the original remedy, only
groundwater chemicals of concern will be discussed here. Please refer to the 1998 ROD for more information about
chemicals of concern in other media, which was addressed by the remedial action that was implemented.
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chemical was detected in the samples collected at the site), the exposure point
concentration (EPC), and how the EPC was derived. Information to create this
table was obtained from tables 6-15, 6-16, and 6-17 of the RI. Table 3 in
Appendix B indicates that trichloroethene was the most frequently detected COC
in groundwater at the Site during the RI. The maximum concentration was used as
the EPC for each COC.
2.7.1.2 Exposure Assessment
Because the site was vacant at the time of the BRA, a trespasser was evaluated as
a receptor for the current use scenario. In this scenario, a 7 to 16 year old (9 year
exposure duration) individual was assumed to trespass onto the site up to 26 days
per year. Incidental ingestion and skin contact with contaminated soil, sediment,
and surface water was assumed.
While the site land use may be commercial/industrial in the future, there is also
the potential for part of the Site to become residential in a future use scenario, and
that a future resident potentially could install a private well for potable use. This
is based on the fact that there are nearby residential areas. (However, municipal
water is available to the area.) Therefore, since both a future worker and a future
resident could potentially be exposed to Site contaminants, both populations were
evaluated in the BRA. The assumed exposure pathways consist of: ingestion of
chemicals in contaminated groundwater, inhalation of chemicals volatilized
during showering, and incidental contact (ingestion/dermal contact) with soil
contaminants.
The future Site worker was assumed to incidentally ingest and dermally contact
surface soil and to drink Site groundwater while at work for a duration of 25
years. The construction worker was assumed to contact subsurface as well as
surface soil for a duration of 13 days. It was assumed that the future adult resident
would ingest two liters per day of groundwater for a 24 year period, and that a
child would drink one liter of water per day for six years. The child resident was
assumed to incidentally ingest 200 milligrams (mg) of soil and to breathe 15 cubic
meters (m3) of air per day. The adult resident was assumed to incidentally ingest
100 trig of soil and to breathe 20 m3 of air per day.
2.7.1.3 Toxicity Assessment
Under EPA human risk assessment guidelines, the likelihood of carcinogenic and
noncarcinogenic effects are considered separately. A brief summary of these
separate approaches follows.
Chemicals are classified for carcinogenicity according to EPA's weight-of-
evidence system. This classification scheme is as follows: Group A - Known
human carcinogen; Group B - Probable human carcinogen; Group C - Possible
human carcinogen; Group D - Not classifiable as to Human carcinogenicity.
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Carcinogens
EPA has developed slope factors (SF) to estimate excess lifetime cancer risks
associated with exposure to potentially carcinogenic contaminants of concern
(Groups A, B, C). SFs, which are expressed as risk per milligram per kilogram
(mg/kg) of daily dose, are multiplied by the estimated intake of a potential
carcinogen, in mg/kg per day, to provide an upper-bound estimate of the excess
lifetime cancer risk associated with exposure at that intake level. The term "upper
bound" reflects the conservative estimate of the risks calculated from the SF. Use
of this approach makes underestimation of the actual cancer risk highly unlikely.
SFs are derived from the results of human epidemiological studies or chronic
animal bioassay data to which mathematical extrapolation from high to low dose,
and from animal to human dose, has been applied.
Table 4 in Appendix B provides carcinogenic risk information for groundwater
COC-s. The risk assessment has not been revised; relevant information was
copied from Tables 6-37, 6-38, and 6-39 of the RI.
Vinyl chloride is a known carcinogen to humans. Bis(2-ethylhexyl)phthalate,
1,2-dichloroethane, tetrachloroethene, and trichloroethene are probable human
carcinogens. There is insufficient or no data that would suggest that ethyl
benzene, toluene, or xylenes are human carcinogens.
Noncarcinogens
EPA has developed reference doses (RfDs) to establish the potential for adverse
human health effects from exposure to the contaminants of concern exhibiting
noncarcinogenic effects. RfDs, which are expressed in units of mg/kg-day, are
estimates of daily exposure levels for humans, including sensitive subpopulations,
which are likely to be without appreciable risk of adverse effects. RfDs are
derived from human epidemiological studies or animal studies to which
uncertainty factors have been applied (i.e., to account for the use of animal data to
predict effects on humans).
The risk from exposure to lead is determined by calculating the predicted blood
lead level and comparing it to the EPA acceptable criteria of no greater than 5%
probability of exceeding 10 micrograms per deciliter (|ag/dL) lead in blood. EPA
uses the Integrated Exposure Uptake Biokinetic Model for Lead in Children
(IEUBK) to predict the blood lead level.
Table 5 in Appendix B provides non-carcinogenic risk information which is
relevant to the COCs in groundwater. The information in this table was obtained
from Tables 6-34, 6-35, and 6-36 of the RL Seven of the COCs have toxicity data
indicating their potential for adverse non-carcinogenic health effects in humans.
The chronic toxicity data available for COCs for oral exposures, has been used to
develop oral RfDs. The available toxicity data, indicate that bis(2-
ethylhexyl)phthalate, 1,2-dichloroethene, ethyl benzene, tetrachloroethene and
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toluene primarily affect the liver. Ethyl benzene and toluene also affect the
kidney. Xylene causes hyperactivity, decreased body weight, and increased
mortality. Oral RfDs are not available for 1,2-dichloroethane or vinyl chloride.
As was the case for the carcinogenic data, dermal RfDs can be extrapolated from
the oral RfDs applying an adjustment factor as appropriate.
Inhalation RfDs are not available for bis(2-ethylhexyl)phthalate, 1,2-
dichloroethene, trichloroethene, vinyl chloride or xylene. Inhalation of 1,2-
dichloroethane causes gastrointestinal disturbances, liver and gallbladder disease.
Inhalation of ethylbenzene causes developmental toxicity. Inhalation of
tetrachloroethene affects the liver and kidney. Inhalation of toluene causes
neurological effects.
2.7.1.4 Risk Characterization
Description
The final step of the BRA, the generation of numerical estimates of risk, was
accomplished by integrating the exposure and toxicity information.
For carcinogens, risks are generally expressed as the incremental probability of an
individual's developing cancer over a lifetime as a result of exposure to the
carcinogen. Excess lifetime cancer risk is calculated from the following equation:
Risk = CDI x SF
where: risk = a unitless probability (e.g., 2 x 10~5) of an individual's
developing cancer
CDI = chronic daily intake averaged over 70 years (mg/kg-day)
SF = slope factor, expressed as (mg/kg-day)"1.
These risks are probabilities that usually are expressed in scientific notation (e.g.,
lxl 0~6). An excess lifetime cancer risk of lxl 0"6 indicates that an individual
experiencing the reasonable maximum exposure estimate has a 1 in 1,000,000
chance of developing cancer as a result of site-related exposure. This is referred to
as an "excess lifetime cancer risk" because it would be in addition to the risks of
cancer individuals face from other causes such as smoking or exposure to too
much sun. The chance of an individual's developing cancer from all other causes
has been estimated to be as high as one in three. EPA's generally acceptable risk
range for site-related exposures is 10"4 to 10"6.
The potential for noncarcinogenic effects is evaluated by comparing an exposure
level over a specified time period (e.g., life-time) with a RfD derived for a similar
exposure period. An RfD represents a level that an individual may be exposed to
that is not expected to cause any deleterious effect. The ratio of exposure to
toxicity is called a hazard quotient (HQ). An HQ less than 1 indicates that a
receptor's dose of a single contaminant is less than the RfD, and that toxic
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noncarcinogenic effects from that chemical are unlikely. The Hazard Index (HI) is
generated by adding the HQs for all chemical(s) of concern that affect the same
target organ (e.g., liver) or that act through the same mechanism of action within a
medium or across all media to which a given individual may reasonably be
exposed. An HI less than 1 indicates that, based on the sum of all HQ's from
different contaminants and exposure routes, toxic noncarcinogenic effects from all
contaminants are unlikely. An HI greater than 1 indicates that site-related
exposures may present a risk to human health.
The HQ is calculated as follows:
Non-cancer HQ = CDI/RfD
where:
CDI = Chronic daily intake
RfD = reference dose.
CDI and RfD are expressed in the same units and represent the same exposure
period (i.e., chronic, subchronic, or short-term).
Carcinogenic risk and noncarcinogenic HI values were calculated for both the
current land use scenario, with residents living near the Site, and the reasonably
possible future land uses, which include commercial/industrial, residential, and a
construction worker scenario.
Current Land Use Scenario
The BRA determined that the total cancer risk, using Reasonable Maximum
Exposure for the current scenario (nearby resident who trespasses onto the Site)
was less than lxlO"6; therefore, the Site does not pose an unacceptable cancer risk
under the current exposure scenario. The total HI for the current scenario was less
than 1.0, indicating that the Site does not pose an unacceptable noncarcinogenic
risk under the current exposure scenario evaluated in the BRA. Therefore, in
summary, the Site does not pose any unacceptable current risk to nearby residents.
Future Land Use Scenario
Future Onsite Construction Worker: The BRA determined that both the
cancer and non-cancer risks for the future onsite construction worker scenario
were within acceptable limits (carcinogenic range: lxl 0"4 to lxl 0"6;
noncarcinogenic HI less than one). The BRA assumed exposure to surface and
subsurface soils, but not to site groundwater for this scenario.
Future Onsite Worker: The BRA determined that the total cancer risk for the
future onsite worker ranged from 7xl0"5 to 3x10"", depending on which portion of
the groundwater is assumed to be the source of drinking water for the worker. The
HI for the same receptor ranged from 0.3 to 200. Thus the risks exceed EPA's
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acceptable risk criteria (carcinogenic and noncarcinogenic) for the worker who
drinks water from the contaminated aquifer. The BRA assessed risks posed by
lead in the site soil using the Recommendations of the Technical Review
Workgroup for Lead for an Interim Approach to Assessing Risks Associated with
Adult Exposures to Lead in Soil (EPA, December 1996). The risks from contact
with lead in the soil by this receptor were found to be unacceptable.
Future Onsite Residential Scenario: The BRA determined that the risks
estimated from the future onsite residential scenarios exceeded EPA's acceptable
risk values. The cancer risk for the future onsite resident ranged from 2x10"4 to
2x10"'. The noncarcinogenic HI ranged from 2 to 2,000 for this receptor. These
risks exceed EPA's acceptable risk range regardless of the portion of the affected
groundwater the resident was assumed to have as their drinking water source. For
the future onsite residential scenario, potential exposure of a child to the lead in
the soil and groundwater was assessed using the IEUBK. The risks from soil and
groundwater lead to this receptor were found to be unacceptable.
Risk Characterization Summary Tables
Tables 6 through 8 in Appendix B provide cancer risk estimates for the
significant routes of exposure. These risk estimates are based on a reasonable
maximum exposure and were developed by taking into account various
conservative assumptions about the frequency and duration of a person's exposure
to groundwater, as well as the toxicity of the COCs. Table 6 presents the
carcinogenic risk characterization summary for a future indoor worker. Table 7
presents the carcinogenic risk characterization summary for a future outdoor
worker. Table 8 presents the carcinogenic risk characterization summary for a
future on-site resident.
The highest cancer risk from direct exposure to contaminated groundwater at this
Site is for a future resident being exposed to shallow groundwater. That risk was
estimated to be 2.45 x 10"'. The COCs contributing most to this risk level were
1,2-dichloroethane, tetrachloroethylene, trichloroethylene and vinyl chloride. This
risk level indicates that if no clean-up action is taken, an individual would have an
increased probability of 3 in 10 of developing cancer as a result of site-related
exposure to the COCs.
Tables 9 through 11 in Appendix B provide HQs for each route of exposure and
the HI for all routes of exposure. The Risk Assessment Guidance for Superfund
(RAGS) states that, generally, a HI greater than 1 indicates the potential for
adverse noncancer effects. Table 9 presents the non-cancer risk characterization
summary for a future indoor worker. Table 10 presents the non-cancer risk
characterization summary for a future outdoor worker. Table 11 presents the
non-cancer risk characterization summary for a future on-site resident.
The highest non-cancer risk from direct exposure to contaminated groundwater at
this Site is for a future resident being exposed to shallow groundwater. The
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estimated HI of 2,240 in that scenario indicates that the potential for adverse non-
cancer effects could occur from exposure to contaminated groundwater containing
a variety of metals and VOCs. The contaminants that had the highest three His
were 1,2-diehloroethene, tetraehloroethylene, and trichloroethylene.
Summary
The majority of the on-site risks (both carcinogenic and non-carcinogenic) for the
future worker and residential scenarios are attributable to ingestion of VOCs in
the groundwater, MCLs were exceeded for organic contaminants and the action
level for lead was exceeded in groundwater.
The actual or threatened releases of hazardous substances from this Site, if not
addressed by implementing the response action selected in this ROD Amendment,
may present an imminent and substantial endangerment to public health, welfare,
or the environment.
2.7,2 Summary of Ecological Risk Assessment
An Ecological Risk Assessment (ERA) was conducted and presented in the R1 Report,
Section 7. Because this ROD Amendment only addresses the groundwater medium, only
that aspect of the ERA is summarized in this section.
2.7.2.1 Identification of Chemicals of Concern
Shallow groundwater samples were collected from 31 stations at the Site during
the RI. Maximum concentrations detected in all shallow groundwater samples
were compared to freshwater aquatic life criteria screening values. The purpose of
this comparison was to identify compounds detected in groundwater that have the
potential to pose a hazard to ecological receptors inhabiting surface waters of the
wetlands or nearby creek. If the groundwater concentration did not exceed the
screening value, that compound was excluded from further evaluation. If the
ground water concentration exceeded the ecological screening value, the
compound was retained as a Chemical of Potential Concern (COPC) for further
evaluation. This comparison assumed that groundwater COPC concentrations
were not diluted in the receiving surface waters.
Detected compounds in shallow groundwater samples included 21 metals and 25
organic compounds. Selection of COPCs in shallow groundwater is summarized
in Table 12 in Appendix B. No shallow groundwater data appropriate for use as a
background screen were available. Therefore, no compounds were eliminated
from further analysis through comparison to the background screening data.
Freshwater chronic Ambient Water Quality Criteria (AWQC), EPA Region 4
screening values, or Oak Ridge National Laboratory (ORNL) ecotoxicological
benchmarks were available for all but one of the detected compounds (earbazole).
For the purpose of this evaluation, Region 4 surface water screening values based
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on total recoverable metals were used. Maximum detected groundwater
concentrations were below screening values for 23 compounds. Therefore, these
23 compounds were eliminated from further analysis. An additional nine
compounds were eliminated from further analysis on the basis of low frequencies
of detection (i.e. < 10%). These compounds included cadmium, cobalt, copper,
cyanide, mercury, selenium, bis(2-ethylhexyl)phthalate, carbazole, and 1,2
dichloroethane.
Six organic compounds exceeded screening values and were retained as COPCs
for further analysis. These compounds included 1,2-dichloroethene (total),
ethylbenzene, tetrachloroethene, toluene, trichloroethene, and total xylenes.
Eight inorganic analytes in groundwater exceeded screening values. Further
COPC screening analysis was performed on these eight metals: aluminum,
beryllium, chromium, iron, lead, nickel, vanadium, and zinc. The metal
concentrations presented in Table 7-14 of the RI represent total recoverable
metals concentrations (e.g., unfiltered data); however, the federal acute and
chronic freshwater AWQC are expressed as dissolved metals, and only the
dissolved fraction is likely to migrate and discharge to surface water. Therefore,
an evaluation of the potential to exceed the screening values was conducted using
the limited available dissolved metals groundwater data from the Site.
Table 7-15 of the RI presented total and dissolved aluminum, beryllium,
chromium, iron, lead, nickel, vanadium, and zinc concentrations for seven
groundwater monitoring wells at the site. The metals concentrations from filtered
groundwater samples, as well as unfiltered samples, were compared to the
screening values for total recoverable metals. (South Carolina's water quality
standards are based on total recoverable metals.) Although the total recoverable
concentrations of these metals exceeded screening values, the dissolved fractions
of beryllium, chromium, lead, nickel, vanadium, and zinc in all seven monitoring
wells were less than the appropriate screening value (total recoverable metals).
The maximum total metal concentrations for these compounds were as follows:
beryllium (1.2 micrograms per liter ((ig/L)), chromium (202 |ig/L), lead (124
|ig/L), nickel (118 (ig/L), vanadium (180 (ig/L), and zinc (82.9 (ig/L). The
maximum dissolved metal concentrations for these metals were all undetected,
with the exception of nickel (76.3 (ig/L). These data indicate that many of the
metals measured in ground water are filterable and, therefore, might not be
present in a bioavailable form. Because the dissolved fraction is more likely to
migrate to the soil surface and be discharged, this fraction is compared to surface
water screening values. Because the dissolved concentrations of these metals were
less than appropriate screening values and/or background concentrations, they
were eliminated from further analysis in this risk assessment.
The dissolved metal concentrations of aluminum and iron exceeded the
appropriate screening value concentration in two out of seven monitoring wells.
Maximum total metal concentrations for aluminum and iron were 100,000 |ig/L
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and 61,900 jj.g/L respectively. Maximum dissolved metal concentrations for
aluminum and iron were 1,270 j.ig/L and 6,420 |ig/L respectively. Although the
dissolved fraction was much lower than the total metal concentrations for
aluminum and iron, two of the seven monitoring wells still exceeded screening
value concentrations for each of these compounds. This suggests that a fraction of
the total recoverable aluminum and iron detected in site ground water is present in
the dissolved phase, and may be bioavailable upon discharge to the wetland.
Therefore, aluminum and iron were retained as COPC for further analysis.
In summary, the following contaminants were identified as groundwater COPCs:
aluminum, iron, 1,2-dichloroethene (total), ethylbenzene, tetrachloroethene,
toluene, trichloroethene, and total xylenes.
2.7.2.2 Exposure Assessment
Ecological habitats at or potentially impacted by the Site include wetlands,
drainage ditch and Turkey Creek. There are no State or federally designated
endangered or threatened species at the Site. Contaminants were removed from
wetland sediments in 2001-2002. Surface water sampling in March 2010
indicated no detections of VOCs.
2.7.2.3 Ecological Effects Assessment
Ecological sampling, toxicity testing, and modeling were performed during the
RI. Details can be found in Section 7 of the RJ. In summary,
2.7.2.4 Ecological Risk Characterization
The Baseline Ecological Risk Assessment (BERA) was conducted at the Site to
assess the potential for site related COPCs to pose adverse ecological risks to site
biota and habitats. Because this ROD Amendment only addresses the
groundwater remedy, only aspects of the BERA conclusion that related to water
are included in the following bullet list of findings and conclusions were made in
Section 7 of the RI:
• Turkey Creek had no observable ecological impacts attributable to the site
and the result of the risk characterization of surface water, sediment and
food web exposures indicated no potential ecological risks;
• The Southern Drainage Ditch showed potential ecological risks to
sediment-associated invertebrates which are limited to areas of elevated
metal concentrations while surface water in the Ditch poses minimal
concern to water column species and amphibians.
2.7.3 Conclusion
The response action selected in this Amended Record of Decision is necessary to protect
the public health or welfare or the environment from actual or threatened releases of
hazardous substances, pollutants, and contaminants into the environment.
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2.8 Remedial Action Objectives
Based on the FS, BRA. and Applicable or Relevant and Appropriate Requirements (ARARs), the
remedial action objectives (RAOs) listed below were established for the Site in the 1998 ROD
and are not being changed in this ROD Amendment. The 1998 RAOs were identified as follows:
• Prevent ingestion/direct contact with surface soil, sediment, and hydric soil having:
o Carcinogen concentrations above levels that would exceed an acceptable cancer
risk range of 10"4 to 10"f' and,
o Noncarcinogen concentrations above Federal or State standards, or in the absence
of standards, above levels that would exceed an acceptable HI of 1,0,
• Prevent migration of contaminants from surface and subsurface soils (uplands and
wetlands) that would pose a risk to human health due to leaching of contaminants to
groundwater in excess of Federal/State limits or health-based levels.
• Prevent concentrations of contaminants from exceeding the applicable Federal and South
Carolina Ambient Water Quality Criteria for surface waters.
• Restore the groundwater system to potential productive use. by cleanup to the Clean-up
Levels established in the ROD, and by minimizing the migration of the contaminants
beyond the existing limits of the contaminant plume.
• Prevent direct contact with sediments or hydric soils that would result in an unacceptable
risk to ecological receptors.
• Prevent ingestion of contaminated groundwater from the Site containing:
o Carcinogen concentrations above Federal or State standards, and above levels that
would exceed an acceptable cancer risk range of HP to 10"6 (unless the risk
manager decides that a risk level less than 10-4 (i.e., a risk between IO"4 and 10"6)
is unacceptable due to site-specific conditions), and
o Noncarcinogen concentrations above Federal or State standards, or in the absence
of standards, above levels that would exceed an acceptable HI of 1.0.
2.9 Description of Alternatives
Because the soil, sediment and surface water remedies have already been implemented, only
groundwater alternatives are discussed in this ROD Amendment.
Technologies considered potentially applicable to the various contaminated media were
evaluated based upon their effectiveness and implementability. Listed below are those
alternatives which passed this final screening for groundwater, and were considered for
remediation in the FS Report, Since the time that the 1998 ROD was approved, additional
information has been obtained and the groundwater remedy has been rc-evaluated. A sixth
alternative has been added for consideration of the groundwater remedy. While preparing the
Amended Proposed Plan, it was recognized that some of the components of some of the original
groundwater alternatives were implemented during the soil remedial action and beyond.
Therefore, those alternatives are modified here to remove the components which have already
been implemented in order to better compare them against the new alternative.
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2,9.1 Description of Remedy Components
The 1998 ROD evaluated five alternatives for groundwater. These included:
1. No Action
2. Source Removal with Groundwater Extraction During Excavation Period
3. Source Removal with Temporary Groundwater Extraction for Dewatering, Data
Collection/Aquifer Evaluation, Active Groundwater Treatment of remaining
contaminated groundwater, and if applicable, Monitored Natural Attenuation
4. Groundwater Extraction and Treatment in Source Area
5. Groundwater Extraction and Treatment Near Property Boundary
Details related to these five alternatives can be found in the 1998 ROD. A sixth
alternative is considered in this ROD Amendment. This sixth alternative is:
6. Enhanced Anaerobic Bioremediation (EAB) and Monitored Natural Attenuation
(MXA) with Institutional Controls (ICs).
While preparing the Amended Proposed Plan, it was recognized that some of the
components of some of the original groundwater alternatives were implemented during
the soil remedial action and beyond. In addition, the No Action alternative cost seemed
exorbitant for "no action". Therefore, the original alternatives are modified here in order
to better compare them against the new alternative.
2.9.1.1 Alternative 1
Under the No Action alternative, the Site is left "as is" and no funds are expended
for the control or clean-up of the contaminated groundwater. If no action is taken,
future risks to potential persons living on or working at the Site will remain.
Although no funds would be expended for clean-up, funds would be required for
monitoring groundwater contaminant concentrations in order to conduct Five-
Year Reviews (FYR). Because hazardous substances would remain at the Site
above levels that would allow for unlimited use and unrestricted exposure, FYRs
would be required under CERCLA.
The 1998 ROD estimated a Present Worth Cost of $1.35 million for the No
Action alternative. The Feasibility Study indicated that this alternative would
include;
1. Construction of ten monitoring wells;
2. Quarterly sampling for a period of ten years, semi-annual sampling for
years 11-30; and
3. Conducting FYRs.
The 2009 FS Amendment updated Present Worth Costs to $2.1 million for
January 2009 dollars based on the Engineering News-Record (ENR) Construction
Cost Index, by converting 1997 dollars to 2009 dollars, but did not modify any of
the remedy components.
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While preparing the Proposed Plan Amendment, EPA realized that this cost
seemed exorbitant for "no action". Therefore, the Proposed Plan Amendment
modified the alternative and cost estimate even further. Under the revised
alternative, no additional monitoring wells would be installed since a sufficient
number of monitoring wells currently exist at the Site. This reduced the Capital
Cost to zero. Because this is supposed to be a "No Action" alternative, the
sampling frequency was changed to biennially (every two years), which would
provide the minimal amount of groundwater data necessary to evaluate the
remedy in the FYR. The O&M cost estimate was updated to use a consistent cost
for monitoring for all alternatives ($24,000 per event), rather than simply
converting 1997 costs to 2009 values. The cost estimate was also revised to reflect
current costs for conducting a FYR in EPA Region 4 ($35,000). The revised
Present Worth Cost is $490,000.
2.9.1.2 Alternative 2
Alternative 2 was defined in the 1998 ROD as "Source Removal with
Groundwater Extraction During Excavation Period". The alternative described in
the 1998 ROD included performing groundwater extraction using well points in
the Fill/Debris area during soil excavation activities. Extracted groundwater
would be treated in an on-site, aboveground facility. The treated effluent would be
discharged in to one of three areas: Turkey Creek, the intermediate aquifer
(groundwater reinjection), or the City of Barnwell publicly owned treatment
works (POTW). The 1998 alternative did not include any active technologies for
groundwater remediation following excavation and dewatering. MNA was the
proposed technology for treatment following excavation and dewatering. Because
hazardous substances would remain at the Site above levels that would allow for
unlimited use and unrestricted exposure, FYRs would be required under
CERCLA.
The 1998 ROD estimated a Present Worth Cost of $1.8 million for this
alternative. The FS indicated this alternative would include:
1. Groundwater Monitoring,
2. Modeling and Reporting (i.e. FYRs),
3. Dewatering Fill/Debris Source Area,
4. Dewatering Lagoon Source Area, and
5. Transmission/Discharge of Treated Groundwater
The 2009 FS Amendment updated Present Worth Costs to $2.8 million (based on
2009 dollars), by converting 1997 dollars to 2009 dollars, but did not modify any
of the remedy components.
The Proposed Plan Amendment, however, modified the alternative and cost
estimate even further. Because the groundwater extraction and treatment during
soil excavation activities have been completed, EPA has revised this alternative to
eliminate items 3 through 5 above and add ICs, such as Restrictive Covenants, on
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property deeds of parcels with contaminated groundwater to prevent the
installation of wells, not associated with the remedial action, or use of
groundwater until all clean-up levels have been achieved. The IC would also
require that a Vapor Intrusion Evaluation be performed prior to constructing any
building above the contaminated groundwater plume, and installation of a vapor
mitigation system for any such future building if determined necessary. Under this
revised alternative, additional monitoring wells would not be installed since a
sufficient number of monitoring wells currently exist at the Site. Capital costs
were reduced to only include ICs ($15,000 per affected property parcel).
The O&M cost estimate was updated to $55,000 per year by using a consistent
cost for monitoring for all alternatives ($24,000 per event), rather than converting
1997 costs to 2009 values, and using the same monitoring frequency
(semiannually) for alternatives #2 through #6. The cost estimate was also revised
to reflect current costs for conducting a FYR in EPA Region 4 ($35,000). The
revised Present Worth Cost is $1,447,000.
The cost estimate used the standard 30-year timeframe. However, MNA may take
much longer to achieve clean-up levels at the Site based on the current
concentrations of contaminants.
The new name for Alternative 2 is "Monitored Natural Attenuation and
Institutional Controls".
2.9.1.3 Alternative 3
Alternative 3 was defined in the 1998 ROD as "Source Removal with Temporary
Groundwater Extraction for Dewatering, Data Collection/Aquifer Evaluation,
Active Groundwater Treatment of remaining contaminated groundwater, and if
applicable. Monitored Natural Attenuation". The alternative described in the
1998 ROD included performing groundwater extraction using an appropriate
method (e.g., wellpoints and/or trenches, etc.) during soil, sediment, and sludge
excavation activities and for approximately four to six months following
excavation. Extracted groundwater would be treated in an on-site, aboveground
facility. The treated effluent would be discharged in to one of three areas: Turkey
Creek, the intermediate aquifer (groundwater reinjection), or the City of Barnwell
POTW. Following the extraction system operation, an evaluation would be
performed to evaluate technologies (air sparging, extraction wells and/or trenches,
recirculation wells, or a combination of the three) for an appropriate active
groundwater remediation system to achieve RGs in the remainder of the
groundwater plume, and construct and operate the chosen groundwater system.
The 1998 ROD estimated a Present Worth Cost of $2.4 million to $5 million for
this alternative. The FS indicated this alternative would include:
1. Groundwater Monitoring,
2. Modeling and Reporting (i.e. FYRs),
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3. Dewatering Fill/Debris Source Area,
4. Dewatering Lagoon Source Area,
5. Transmission/Discharge of Treated Groundwater,
6. Evaluation of Excavation Effect,
7. Design of Remedy, and
8. System Implementation
The 2009 FS Amendment updated Present Worth Costs to S3.7 million to $7.7
million (based on 2009 dollars). The low end of this cost estimate assumes that
only MNA would be required while the high end assumes long-term groundwater
extraction and treatment would be required.
The Proposed Plan Amendment, however, modified the alternative and cost
estimate even further. Because the groundwater extraction and treatment during
soil excavation activities have been completed and the effect evaluated, EPA has
revised this alternative to eliminate items 3, 4, 6 and 7 above and add ICs, such as
Restrictive Covenants, on property deeds of parcels with contaminated
groundwater to prevent the installation of wells, not associated with the remedial
action, or use of groundwater until all clean-up levels have been achieved. The IC
would also require that a Vapor Intrusion Evaluation be performed prior to
constructing any building above the contaminated groundwater plume, and
installation of a vapor mitigation system for any such future building if
determined necessary. Under this revised alternative, Capital costs are reduced to
$1.1 million which includes the pump and treat system and ICs.
The O&M cost estimate was updated to $214,000 per year by converting the
pump and treatment system O&M costs from 1997 to 2009 dollars, using a
consistent cost for monitoring for all alternatives ($24,000 per event), and using
the same monitoring frequency (semiannually) for alternatives #2 through #6. The
cost estimate was also revised to reflect current costs for conducting a FYR in
EPA Region 4 ($35,000).
The original alternative had a range of costs with the lower end representing
MNA and the higher end representing long-term pump and treat. Since MNA is
used as alternative #2, this component was eliminated from this alternative and
therefore, a single cost amount was calculated. The revised Present Worth Cost is
$6.6 million.
The new name for Alternative 3 is "Groundwater Extraction and Treatment, and
Institutional Controls".
2.9.1.4 Alternative 4
Alternative 4 was defined in the 1998 ROD as "Groundwater Extraction and
Treatment in Source Area". The alternative described in the 1998 ROD included
performing groundwater extraction using wellpoints during soil, sediment, and
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sludge excavation activities. Additionally, groundwater extraction would be
performed in the Solids Lagoon and Fill/Debris areas using extraction wells
and/or trenches. Extracted groundwater would be treated in an on-site,
aboveground facility. The treated effluent would be discharged in to one of three
areas: Turkey Creek, the intermediate aquifer (groundwater reinjection), or the
City of Barnwell POTW. The additional groundwater extraction activities were
intended to prevent the further migration of COCs, and MNA was the proposed
technology for groundwater treatment outside of the source area.
The 1998 ROD estimated a Present Worth Cost of S3.8 million to $4.7 million,
depending on the Solids Lagoon extraction system that would be used. The FS
indicated this alternative would include:
1. Groundwater Monitoring,
2. Modeling and Reporting (i.e. FYRs),
3. Dewatering Fill/Debris Source Area,
4. Fill/Debris Extraction System,
5. Dewatering Lagoon Source Area,
6. Solids Lagoon Extraction System,
7. Groundwater Treatment System, and
8. Transmission/Discharge of Treated Groundwater.
The 2009 FS Amendment updated Present Worth Costs to $5.8 million to $7.2
million (based on 2009 dollars).
The Proposed Plan Amendment, however, modified the alternative and cost
estimate even further. Because the groundwater extraction and treatment during
soil excavation activities have been completed, EPA has revised this alternative to
eliminate items 3 and 5 above and add ICs, such as Restrictive Covenants, on
property deeds of parcels with contaminated groundwater to prevent the
installation of wells, not associated with the remedial action, or use of
groundwater until all clean-up levels have been achieved. The 1C would also
require that a Vapor Intrusion Evaluation be performed prior to constructing any
building above the contaminated groundwater plume, and installation of a vapor
mitigation system for any such future building if determined necessary. Under this
revised alternative, Capital costs have increased due to cost estimate conversion
of 1997 dollars to 2009 dollars, and the addition of ICs.
The O&M cost estimate was updated to $193,000 per year by converting the
pump and treatment system O&M costs from 1997 to 2009 dollars, using a
consistent cost for monitoring for all alternatives ($24,000 per event), and using
the same monitoring frequency (semiannually) for alternatives #2 through #6. The
cost estimate was also revised to reflect current costs for conducting a FYR in
EPA Region 4 ($35,000).
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The original alternative had a range of costs with the higher end representing a
more extensive extraction system in the Solids Lagoon area. Because the
contaminated groundwater plume is known to be more extensive than what was
known in 1997, the higher end of the cost estimate was used to remove the range
and present a single value. The revised Present Worth Cost is $7.1 million.
The new name for Alternative 4 is ''Groundwater Extraction and Treatment in
Source Area Only, and Institutional Controls".
2.9.1.5 Alternative 5
Alternative 4 was defined in the 1998 ROD as "Groundwater Extraction and
Treatment Near Property Boundary". The alternative described in the 1998 ROD
included performing groundwater extraction using wellpoints during soil,
sediment, and sludge excavation activities. Additionally, a groundwater extraction
system would be installed near the southern property boundary. Extracted
groundwater would be treated in an on-site, aboveground facility. The treated
effluent would be discharged in to one of three areas: Turkey Creek, the
intermediate aquifer (groundwater reinjection), or the City of Barnwell POTW.
The groundwater extraction system was intended to prevent the further migration
of COCs beyond the property boundary, and MNA was the proposed technology
for groundwater treatment in the remainder of the plume.
The 1998 ROD estimated a Present Worth Cost of $4.6 million for this
alternative. The FS indicated this alternative would include:
1.
Groundwater Monitoring,
2.
Modeling and Reporting (i.e. FYRs),
3.
Fill/Debris Dewatering,
4.
Fill/Debris Perimeter Control,
5.
Lagoon Dewatering,
6.
Lagoon Perimeter Control,
7.
Groundwater Treatment System, and
8.
Transmission/Discharge of Treated Groundwater.
The 2009 FS Amendment updated Present Worth Costs to $7 million (based on
2009 dollars).
The Proposed Plan Amendment, however, modified the alternative and cost
estimate even further. Because the groundwater extraction and treatment during
soil excavation activities have been completed, EPA has revised this alternative to
eliminate items 3 and 5 above and add ICs, such as Restrictive Covenants, on
property deeds of parcels with contaminated groundwater to prevent the
installation of wells, not associated with the remedial action, or use of
groundwater until all clean-up levels have been achieved. The IC would also
require that a Vapor Intrusion Evaluation be performed prior to constructing any
building above the contaminated groundwater plume, and installation of a vapor
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mitigation system for any such future building if determined necessary. Under this
revised alternative, Capital costs have increased due to cost estimate conversion
of 1997 dollars to 2009 dollars, and the addition of ICs.
The O&M cost estimate was updated to $211,000 per year by converting the
pump and treatment system O&M costs from 1997 to 2009 dollars, using a
consistent cost for monitoring for all alternatives ($24,000 per event), and using
the same monitoring frequency (semiannually) for alternatives #2 through #6, The
cost estimate was also revised to reflect current costs for conducting a FYR in
EPA Region 4 ($35,000). The revised Present Worth Cost is $7 million,
2,9.1.6 Alternative 6
The new alternative 6 is "Enhanced Anaerobic Bioremcdiation, with Monitoring
and Institutional Controls," The 1998 ROD did not evaluate this alternative. EAB
with MNA was included in the 2009 FS Amendment. The Proposed Plan
Amendment, however, modified the alternative and cost estimate by the
additional requirement of ICs to prevent the installation of wells, not associated
with the remedial action, or use of groundwater until all clean-up levels have been
achieved. The 1C would also require that a Vapor Intrusion Evaluation be
performed prior to constructing any building above the contaminated groundwater
plume, and installation of a vapor mitigation system for any such future building
if determined necessary. During the ROD Amendment review process, EPA
decided to change MNA to "monitoring", with SCDHEC's concurrence. Under
this revised alternative, Capital costs were increased to include ICs, and O&M
costs were increased to reflect current costs for conducting a FYR in EPA Region
4 ($35,000). The revised Present Worth Cost is S2.8 million.
EAB is an in situ remediation approach that uses indigenous microorganisms in
the subsurface to degrade chloroethenes to ethene. During EAB,
tetrachloroethene is completely transformed to innocuous byproducts following
the reductive dechlorination pathway:
tetrachloroethene trichloroethene
cis-1,2-dichloroethene ~ vinyl chloride
ethene
EAB generally occurs through the addition of fermentable carbon compounds that
serve as electron donors for subsurface bacteria that use the chloroethenes as
electron acceptors. The hydrogen produced during fermentation reactions is the
primary electron donor for dechlorinating bacteria and drives EAB. This electron
transfer process provides the bacteria with energy for population growth and
metabolic activity.
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The two primary requirements for successful implementation of EAB are: 1)
adequate spatial distribution of the electron donor to achieve strongly reducing
conditions, and 2) a microbial community capable of complete reductive
dechlorination of the chloroethenes.
This alternative includes installing a series of injection wells, injecting electron
donors, nutrients such as nitrogen and phosphorous or buffers like sodium
bicarbonate, reliance on microorganisms already existing in the ground to carry
out the reaction of converting VOCs to their non-toxic daughter product (ethene).
Where microorganisms are not present, either commercially available
microorganisms will be injected or microorganisms may be transferred from one
area of the Site to another. The pH of groundwater plays an important role in
microorganism survival, therefore pH will be monitored and adjusted as
necessary. A pilot test performed at the Site during 2005 through 2008, showed
successful reduction of chloroethenes to ethene. The reduction is evident by the
decreased concentrations presented in the table on page 5 of this document.
Monitoring will be conducted until clean-up levels are achieved.
Although groundwater is not currently being used at the Site, the implementation
of Institutional Controls (ICs) will be the enforceable instrument which will
prevent human consumption of groundwater until clean-up levels are attained.
ICs in the form of a Restrictive Covenant will be placed on the Site property
deeds to prevent the installation of wells, not associated with the remedial action,
or use of groundwater until all clean-up levels have been achieved. The
Restrictive Covenant will also require that a Vapor Intrusion Evaluation be
performed prior to constructing any building above the contaminated groundwater
plume, and installation of a vapor mitigation system for any such future building
if determined necessary.
Groundwater contamination has migrated off-site onto the adjacent parcel. The
plume was defined in 2007 and is confined to an undeveloped wetland area.
Installation of a permanent supply well in this area is not feasible without
significant access improvements, such as building a road, and is not likely since a
municipal supply well already exists across the street. During the offsite
investigation, CDM was unable to install a monitoring well in this area using
specialized drilling equipment for swampy conditions. Even if a supply well were
to be installed in the offsite area, it would be done so below the confining layer
(Unit D) based on the limited production available from the shallow aquifer.
Additionally, all wells drilled in South Carolina require approval from the
SCDHEC prior to installation. SCDHEC would be unlikely to approve installation
of a supply well in the shallow aquifer of the offsite property. Therefore, the IC to
be utilized for this parcel is annual notification to the property owner as a
reminder that groundwater contamination exists on their property and that
drinking water, production, or irrigation wells should not be installed in the area
of contamination or within close enough distance that would affect the
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groundwater flow of the contaminated area. The notification would include a copy
of the most recent monitoring results. If cleanup levels are not achieved within 10
years of the initiation of the groundwater remedial action, either a Restrictive
Covenant or a governmental control (local ordinance) may be pursued.
2.9.1.7 Other Alternatives Evaluated and Rationale for Exclusion
Barrier Walls: Barrier Walls were discussed in the FS, but were not chosen as a
potential alternative due to the depth required (60 feet), the large expense, and
because it would only contain, not reduce the VOC contamination.
In situ Chemical Oxidation: In situ chemical oxidation was considered at the
request of SCDHEC. It was determined to not be feasible because of the high
natural organic content of the formation that would require very high amounts of
oxidant for effective destruction of VOCs.
Phytoremediation: Phytoremediation was considered because the restored
wetlands include a high quantity of willow trees, which have been demonstrated
to reduce VOC concentrations. It was determined to not be feasible due to the
depth of contamination in most areas of the Site. However, the willow trees would
likely have a positive effect on shallow groundwater.
2.9.2 Common Elements and Distinguishing Features of Alternatives
Alternatives #1 and #2 rely on natural degradation processes. Alternatives #3 through #5
rely on groundwater extraction and treatment at varying locations and to varying extents.
Alternatives #2 through #6 all include the requirement for Institutional Controls.
Alternatives #2 through #5 envisioned the traditional pump and treat type of technology,
whereas Alternative #6 utilizes a more innovative approach.
2.9.3 Expected Outcomes of Alternatives
Alternatives #1 and #2 are not expected to be effective at significantly reducing
contaminant concentrations and would allow the contaminated groundwater plume to
continue to migrate off-site. Alternatives #4 and #5 would reduce the amount of
contamination through treatment, but would only be applied to certain areas of the Site
and therefore, would not completely address the entire contaminated groundwater plume.
Alternatives #3 and #6 are expected to treat the contaminated groundwater. However,
pumping rates are quite low for Alternatives #3, #4, and #5, which implies that they are
not the best alternative for treating contaminated groundwater at the Site. Alternative #6
has been shown to be effective through a Pilot Study at the Site and therefore, is expected
to be the most successful of all of the alternatives evaluated.
Shuron Inc. Site, ROD Amendment
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September 2010
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2 JO Cora par alive Analysis of Alternatives
In this section, each alternative is evaluated using the nine evaluation criteria required in Section
300.43CHf)(5Ki) ^ NCP, The nine criteria include:
1. Overall Protecti veness of Human Health and the Environment
2. Compliance with ARARs
3. Long-Term Effectiveness and Permanence
4. Reduction of Toxicity, Motility or Volume of Contaminants through Treatment
5. Short-term Effectiveness
6. Implemenlability
7. Cost
8. Slate Acceptance
9. Community Acceptance
The nine criteria arc used to evaluate the different remediation alternatives individually and
against each other in order to select a remedy. This section of the ROD Amendment profiles the
relative performance of each alternative against the nine criteria and compares the alternatives
performance against each other.
Under each criteria heading, a table is inserted which gives a visual interpretation of whether or
nut the alternative meets the criteria. Green highlighting in the tables indicates that the
alternative fully meets the criteria. Yellow highlighting indicates thai the alternative partially
meets the criteria Red highlighting indicates that the alternative does not meet the criteria-
Below the tabte is a description of how the alternatives meet, partially meet, or do not meet the
criteria. The descriptions are presented in order of effectiveness at meeting the criteria.
2.10.1 Overall Protection of Human Health and the Environment
Overall protect! veness of human health and the environment determines whether an
alternative eliminates, reduces, or controls threats to public health and the environment
through institutional controls, engineering controls, or treatment.
Overall Protection at Human Health and the
cnYifonnwwTi
t Wo Acton
2 Monitored Natural Attenuation (MNA) and IQs
— - " L-- - - - - - - ~
3 Groun-jwalcr Emr-jctic^ imd Trratmeni and IQs
4, Groundwater Extraction and Treatment in Source Area
Only, and ICs
5. Groundwater Extraction and Treatment Near Property
Boundary and ICs
6 Enhanced Anaerobic R-or«medigrtk>n (EASJ J^th
Monitoring tirtd ICs
Shuron Int Site. ROD Afnwximortt
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Septerrt&er 2010
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Alternative #6 is the alternative that provides the highest level of protection of human
health and the environment. This is accomplished by treating the contaminated
groundwater and preventing access to the aquifer until RGs are attained. It is ranked
higher than Alternative #3 because it is expected to achieve RGs in a shorter time period.
Alternative #3 provides protection of human health and the environment by removing and
treating the contaminated groundwater and preventing access to the aquifer until RGs are
attained.
Alternatives #4 and #5 provide partial protection to human health and the environment by
removing and treating portions of the contaminated groundwater and preventing access to
the aquifer until RGs are attained. However, contaminants outside of the cone of
influence of the extraction system would not be treated.
Alternative #2 provides partial protection of human health through ICs and reliance on
natural degradation processes, but only minimally provides protection to the environment
due to the slow rate at which natural attenuation occurs at sites with such high VOC
concentrations.
Alternative #1 does not provide any increased protection to human health or the
environment.
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2.10.2 Compliance w ith Applicable or Relevant and Appropriate Requirements
Section 121(d) of CERCLA and NCP §300.43G(f)( 1 Ki'KB) require that remedial actions
at CERCLA sites at least attain legally applicable or relevant and appropriate Federal and
Slate requirements, standards, criteria, and limitations, which are collectively referred to
as ARARs, unless such ARARs are waived under CERCLA section 121(d)(4),
Applicable requirements are those clean-up standards, standards of control, and other
substantive requirements, criteria, or limitations promulgated under Federal
environmental or Stale environmental or facility citing laws that specifically address a
hazardous substance, pollutant contaminant, remedial action, location, or other
circumstance found at a CERCLA site. Only those State standards thai arc identified by a
state in a timely manner and that are more stringent than Federal requirements may be
applicable. Relevant and appropriate requirements arc those clean-up standards, standards
of control* and other substantive requirements, criteria, or limitations promulgated under
Federal environmental or Slate environmental or facility citing laws that. while not
"applicable" to a hazardous substance, pollutant, contaminant, remedial action, location,
or other circumstance at a CERCLA site, address problems or situations sufficiently
similar to those encountered at the CERCLA site that iheir use is well-suited to the
particular site. Only those State standards that arc identified in a timely manner and are
more stringent than Federal requirements may be relevant and appropriate
Compliance with ARARs addresses whether a remedy will meet all of the applicable or
relevant and appropriate requirements of other Federal and Stale environmental statutes
or provides a basis for invoking waiver. For additional information on ARARs for this
Site, see section 2.13, ARARs Attainment.
Compliance with ARARs
1. No Action ~~
2 Monitored Natural At1enunl:on (MIMA) and ICs
3. Groundwatar Extraction and Treatment and ICs
4 Groundwirtfif Extraction and Treatment in Sourco Area
Only, and iCe
5. Groundwater Extraction and Treatment Near Property
Boundary nnd ICs
G. Enhanced Anaerobe Bioremedlaticn (EAB j, vritfi
Monitoring and ICs
Alternatives -3 and #6 would meet action-specific, location-specific, and chemical-
specific ARARs. Alternative #6 is expected to achieve chemical-specific ARARs faster
than Alternative #3.
Alternatives #1, -2, #4 and #5 would meet action-specific and location-specific ARARs.
but would not meet chemical-specific ARARs throughout the Site.
ARARs identified for Ibis ROD Amendment arc included in Table 13 in Appendix B.
$huiw» Ine Site. RO£J Arr>«wment
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September 2010
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2.10.3 Long-Term Effectiveness and Permanence
Long-term effectiveness and permanence refers to expected residual risk and the ability
of a remedy to maintain reliable protection of human health and the environment over
time, once clean-up levels have been met. This criterion includes the consideration of
residua] risk that will remain on-site following remediation and the adequacy and
reliability of controls.
Loofl-Tfm Elhctlvinws and Pttmantiitti
1, No Action
2 Monttpred Natural) AttanuaLun (MNA) and ICs
3 Grounrt^rotifr EjaractiOTi OTd T'oatmcnl .-'id Cs
4. GrDufxJwaJ&r Extraction and Tfeatmont in Source Area
Only, and IC»
5, Groundwater Extraction and Treatment Near Property
Boundary amMOs
0. Enhanced Anaorcbic B-aram«fia&on (EABJ .yrth
Mon>!o.-ng ami ICs
Alternatives #3 and would provide long-term effectiveness and permanence through
successful treatment, monitoring and ICs.
Alternatives #4 and #5 would not provide long-term effectiveness or permanence because
they do not actively remediate the entire contaminated groundwater plume. However,
MNA may eventually achieve RGs and is a permanent solution.
Alternatives £1 and #2 provide the lowest level of long-term effectiveness or
performance because they rely solely tin natural degradation processes, which will take
many decades to achieve RGs. if al all.
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2.10,4 Reduction of Toxicity. Mobilit). or Volume Through Treatment
Reduction of toxicity, mobility; or volume of contaminants through treatment evaluates
an alternative's use of treatment to reduee the harmful effects of principal contaminants,
their ability to move in the environment, and the amount of contamination present.
Reduction of Toxicity. Mot ility, or Volume Tbrotign
Treatment
; Morwloree Natural Attenuation »MNA| end IC*
flwataf Extraction and Treafroent ami tC»
4 Groundwater Extraction and Treatmenl in Source Area
Only, and 1C*
5. Groundwater Extraction and Troalm&rit Near Property
Boundary and ICs
6. Enhanced Anaerobic Bioremediation (EAB), wM
MonRon-rQ and ICfe
Alternative #6 would permanently reduce mobility, toxicity and volume-
Alternative #3 would provide a reduction in toxicity, mobility and volume, if
groundwater extraction was successful.
Alternatives #4 and #5 would reduce toxicity, mobility and volume in the areas of
treatment, but may not reduee it for the entire contaminated groundwater plume.
Alternatives I and #2 may reduce toxicity, mobility and volume through natural
attenuation process, but are not expected to be effective throughout the entire
contaminated groundwater plume.
Sfturan inc. See, ROD Aniundmorl
45
2QtO
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2.10.5 Short-Term Effectiveness
Short-term effectiveness considers the length of time needed to implement an alternative
and the risks the alternative poses to workers, residents, and the environment during
implementation.
Short-Term Effectiveness
1 No Action
? MonHonsd NafurBl At1.enuiTf.xjn (MNA| and IPs
3. Groundw3tGf Extraction and Treatmeri! and tCs
4, Groundwater Exiracticm and Tndatmen! in Source Area
CMy. and ICs
5 Groundwater Extraction and Treatment Near Property
Boundary and ICs
6. Enhanced Anaerobic Bioremediation (EABji, with
Monitoring and ICs
Alternative #1 poses the least risk to workers and residents during implementation
because no construction is required and the only action is sampling, which would occur
infrequently (every other year).
Alternative #2 poses the next lowest risk to workers and residents during implementation
because no construction is required and the only action is sampling, which would occur
twice a year.
Alternatives «3 through »*6 pose moderate short-term risks to workers during
construction, pumping, injection, and monitoring. Each of these alternatives arc
anticipated to take approximately one to two years to construct.
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2J0.6 ImplementabilitY
Implementability considers the technical and administrative feasibility of implementing
the alternative, including factors such as the relative availability of goods and services.
r iskj Action
'ural Attonwtton (MNA) and !C*
3. Groundwater Extraction and Treatment and ICs
4 Groundwater Extraction and Treatment in Source Aral
Only, and ICs
5. Groundwater Extraction and Treatment Near Property
Boundary and ICa
6, Enhanced Anaerobic Bioremediartign (EAB). with
Monitoring and ICs
Alternative #1 would be the easiest to implement because the only action required is
sampling, which would occur infrequently t every other year).
Alternative f?2 would be the next easiest to implement becaasc the only action required
would be retarding ICs and sampling twice a year.
Alternatives #3 through p6 pose implementation challenges, particularly regarding
construction in or near wetlands.
Shufon Inc. Site. ROD ftmandpnert
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2.10.7 Cosi
Cost includes estimated capital and annual operations and maintenance costs, as well as
present worth cost, Present worth cost is the total cost of an alternative over time in terms
of today's dollar value. Cost estimates are expected to be accurate within a range of "-50
to -30 percent.
The cost estimates provided in the 2009 FS Amendment converted 1997 dollars to 2009
dollars for Alternatives - I through #5. However, because a portion of mosl of those
remedies have been completed. EPA has revised the cost estimates. A breakdown for
total costs for each alternative are included in an August 2010 letter to Textron, which is
included in the Administrative Record, A summary is provided below. Detailed
breakdowns are included in Tables 14 through 19 in Appendix B
Cost
Alternative
Not
Present
Worth
Cost
1. No Action
5490.000
2. '.'ioriiiic>f»it Ntrtwml Attenusuen (VNA) and fCs
51.447,000
3 GfoumJv»atcif Extraction and Tre-aVrwni and iCf
56,631.000
4. ErtmcWor, artd Trealnrenl tn
Source A/pa Only, and JCi
57.113.000
5. Groundwater ExSroefcon and Trearmorrt Nea«-
Property Boundary and ICs
56.950,000
6. Enhanced Artaofobic E&ofemedlsbon (EABl. with
Monitoring and ICs
52.790,000
2.10.8 State/Support Agency Acceptance
State Support Agency Acceptance considers whether the State agrees with the EPA's
analyses and recommendations, as described in the HI FS, FS Amendment and Proposed
Plan. SCDHEC has been very involved with all activities related to the Sburon Site and
supports the Preferred Alternative.
Shuron
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2.10.9 Community Acceptance
The Public Comment period lasted from August 20, 2010 to September 20, 2010. During
that time period, one set of written comments and one telephone call was received from
the public. The questions/comments were related to the quality of their drinking water
rather than a specific comment on the proposed remedy. Copies of the comments, as well
as the RPM's response to the telephone call are included in Appendix E.
EPA hosted a public meeting for the Amended Proposed Plan at 6:30 p.m. on Monday,
August 30, 2010, at the Barnwell County Public Library. The EPA RPM for this Site
gave a PowerPoint presentation which provided a brief Site history, a summary of actions
completed to date, and a discussion of the different treatment alternatives that have been
evaluated. A copy of the presentation is included in Appendix F. After the presentation,
the RPM requested any comments or questions from the attendees. Questions centered
around future use of the property. No specific comments were made regarding the
proposed remedy. The transcript of the meeting is included in Appendix G.
Please refer to Part 3, the Responsiveness Summary, for more details.
Shuron Inc. Site, ROD Amendment
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September 2010
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2*10.10 Sum man, of Alternath e Evaluation Comparison
In sirnimafj', Alternative 6 has been determined to be the best alternative for groundwater
at the Site Alternatives 1 through 5 ck> not meet at least one of the nine criteria,
Alternative 6 is expected to provide a slightly higher level of overall protectiveness. long-
term effectiveness and permanence, reduction of toxicity, mobility and volume at a lower
cost than Alternative 3. the originally selected remedy. See Table 20 in Appendix B for
a more detailed summary.
Summary of Alternative Evaluation Comparison
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2.12 Amended Selected Remedy
2.12.1 Summary of the Rationale for the Amended Selected Remedy
The 1998 ROD selected Alternative 3, dewatering during excavation, evaluation period,
active groundwater treatment and natural attenuation is applicable. During 2001-2002,
that remedial action was implemented along with the selected soil and sediment remedy.
Active pumping of the groundwater did not yield optimum results. The volume of water
that could be extracted was minimal. Additional groundwater treatment options were
evaluated. An Enhanced Anaerobic Bioremediation (EAB) pilot test was performed in
two phases during May 2006 through March 2008. The results indicated that EAB
successfully biodegraded PCE and TCE to ethane/ethene. Although the pilot test
identified several challenges with implementing EAB, it is believed that EAB is the most
viable technology for reducing groundwater VOCs at the Shuron, Inc. Site.
2.12.2 Description of the Amended Selected Remedy
EAB Technology Description
EAB is an in situ remediation approach that uses indigenous microorganisms in the
subsurface to degrade chloroethenes to ethane and ethane. During EAB, tetrachloroethene
(PCE) is completely transformed to innocuous byproducts following the reductive
dechlorination pathway: PCE -~ trichlorocthcnc (TCE) -~ cis-1,2-dichlorocthene (cis-1,2-
DCE) vinyl chloride (VC) * ethene. EAB generally occurs through the addition of
fermentable carbon compounds that serve as electron donors for subsurface bacteria that
use the chloroethenes as electron acceptors. The hydrogen produced during fermentation
reactions is the primary electron donor for dechlorinating bacteria and drives EAB. This
electron transfer process provides the bacteria with energy for population growth and
metabolic activity.
The primary requirements for successful implementation of EAB are: 1) adequate spatial
distribution of the electron donor to achieve strongly reducing conditions, and 2) a
microbial community capable of complete reductive dechlorination of the chloroethenes.
Electron Donors
Electron donors are commonly available in two basic types: aqueous and "slow-release".
Aqueous electron donors are generally miscible with water and of a viscosity similar to
water, and are therefore relatively easy to distribute in the subsurface. They have the
disadvantage that they typically last only a few months in the subsurface, and therefore
have to be reinjected periodically. Slow-release donors are typically lower solubility
liquids or solids that last much longer than aqueous donors, but can be more difficult to
distribute in the subsurface.
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September 2010
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Redox Conditions
A critical aspect of groundwater chemistry with respect to the fate of chloroethenes is the
oxidation-reduction, or redox, conditions. Chloroethenes serve as electron acceptors in
microbially-mediated redox reactions during reductive dechlorination (including EAB).
Therefore, they have to compete with naturally occurring electron acceptors in
groundwater. The use of electron acceptors is generally governed by the available free
energy from redox reactions. In order of decreasing energy available, some common,
naturally occurring electron acceptors are oxygen, nitrate, iron-Ill, sulfate, and carbon
dioxide. At a minimum, oxygen and nitrate must be depleted for any reductive
dechlorination to occur. Dechlorination of PCE and TCE to cix-l,2-DCE generally
occurs under iron-reducing to sulfate-reducing conditions. Complete dechlorination to
ethane typically occurs under sulfate-reducing to methanogenic conditions (carbon
dioxide is the only remaining electron acceptor.) Thus, understanding redox conditions
(aerobic, nitrate-reducing, iron-reducing, sulfate-reducing, or methanogenic) provides
key insight into the potential for reductive dechlorination to occur at a site. The more
electron donor present, the more reducing the conditions will be.
Dechlorinating Bacteria
The dechlorinating bacteria, Dehcilococcoides spp. (DHC), have been found to be very
important for achieving complete dechlorination of PCE to ethane in groundwater
(Hendrickson et al. 2002). While these bacteria re fairly common, they are not present at
every site, and their absence can lead to the stall of dechlorination at cis-l,2-DCE. Where
DHC is present, EAB can be accomplished through biostimulation. Biostimulation
involves only the addition of electron donors, and potentially limiting nutrients such as
nitrogen and phosphorous or buffers like sodium bicarbonate, and relies on the
indigenous microorganisms to carry out the desired reactions. Where DHC is not present,
EAB requires bioaugmentation. Bioaugmentation is the introduction of either
commercially available microorganisms or transferring indigenous microorganisms from
one area of the site to another as well as addition of electron donors into site groundwater
to provide a metabolic capability that either is not present in the native community, or can
be significantly enhanced.
PH
The pH of the groundwater also plays an important role in DHC survival. pH levels in the
range of 5.0 to 5.5 can impede DHC survival and at pH below 5.0 survival can be
problematic for dechlorination by DHC and therefore pH needs to be monitored and, if
necessary, adjusted during chemical and, when applicable, microorganism addition.
EAB Pilot Test
An EAB pilot test was performed from 2005 to 2008 by biostimulating the subsurface
with whey in an approximate 100 feet by 200 feet area in the east portion of the site. A
full report of this pilot test is provided in the Enhanced Anaerobic Bioremediation Pilot
Shuron Inc. Site, ROD Amendment
52
September 2010
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Test Final Report (CDM, September 2008). The results of this pilot test showed that
chloroethenes in groundwater can be biodegraded to ethane following biostimulation,
although results were not uniform throughout the test area due to several factors
including low pH and difficulties with electron donor distribution associated with the low
soil permeability. Based on the results from the EAB pilot test, EAB was recommended
as the groundwater remedial alternative for this site. This alternative may include MNA
in some areas once EAB reaches a certain end point.
EAB Implementation
Implementation of EAB will require the installation of injection wells with an
approximate 20- to 25-feet spacing between each. It will also require installation of
additional monitoring wells to evaluate the effectiveness of the remedy. An electron
donor will be injected into the contaminated aquifer approximately three separate times.
If needed, a buffering agent may also be added to the aquifer to bring the groundwater pH
within an acceptable range for DHC survival. If necessary, microorganisms may also be
added for areas with no or low volumes of microorganisms.
Monitoring wells throughout the Site will be sampled on a routine basis to evaluate the
effectiveness of the remedy.
Institutional Controls
Although groundwater is not currently being used at the Site, the implementation of
Institutional Controls (ICs) will be the enforceable instrument which will prevent human
consumption of groundwater until clean-up levels are attained. ICs in the form of a
Restrictive Covenant will be placed on the Site property deeds to prevent the installation
of wells, not associated with the remedial action, or use of groundwater until all clean-up
levels have been achieved. The Restrictive Covenant will also require that a Vapor
Intrusion Evaluation be performed prior to constructing any building above the
contaminated groundwater plume, and installation of a vapor mitigation system for any
such future building if determined necessary.
Groundwater contamination has migrated off-site onto the adjacent parcel. The plume
was defined in 2007 and is confined to an undeveloped wetland area. Installation of a
permanent supply well in this area is not feasible without significant access
improvements, such as building a road, and is not likely since a municipal supply well
already exists across the street. During the offsite investigation, CDM was unable to
install a monitoring well in this area using specialized drilling equipment for swampy
conditions. Even if a supply well were to be installed in the offsite area, it would be done
so below the confining layer (Unit D) based on the limited production available from the
shallow aquifer. Additionally, all wells drilled in South Carolina require approval from
the SCDHEC prior to installation. SCDHEC would be unlikely to approve installation of
a supply well in the shallow aquifer of the offsite property. Therefore, the IC to be
utilized for this parcel is annual notification to the property owner as a reminder that
groundwater contamination exists on their property and that drinking water, production,
Shuron Inc. Site, ROD Amendment
53
September 2010
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or irrigation wells should not be installed in the area of contamination or within close
enough distance that would affect the groundwater flow of the contaminated area. The
notification would include a copy of the most recent monitoring results. If cleanup levels
are not achieved within 10 years of the initiation of the groundwater remedial action,
either a Restrictive Covenant or a governmental control (local ordinance) may be
pursued.
2.12.3 Summary of the Estimated Remedy Costs
The selected remedy is expected to cost $2.8 million. Table 19 in Appendix B
represents the combined remedy costs. This value is less than the cost estimate for the
originally selected remedy.
The information in the above cost estimate summary table is based on the best available
information regarding the anticipated scope of the remedial alternative. Changes in the
cost elements are likely to occur as a result of implementation of the remedial alternative.
Major changes may be documented in the form of a memorandum in the Administrative
Record file, an ESD, or a ROD amendment. This is an order-of-magnitude engineering
cost estimate that is expected to be within +50 to -30 percent of the actual project cost.
2.12.4 Expected Outcomes of the Selected Remedy
2.12.4.1 Available Land Use after Clean-up
The available land use after the clean-up for this amended ROD is defined in the
January 18, 2007 Restrictive Covenant. The clean-up levels chosen in the 1998
ROD were based on future industrial use of the property. All of the contaminated
surficial soil and most of the contaminated sub-surface soils and sediments were
removed from the Site during the 2001-2002 Remedial Action.
In 2007, a Restrictive Covenant was filed with the Clerk of Court in Barnwell
County, South Carolina. The Restrictive Covenant states, "The Property shall not
be used for a family or individual residence, family or individual domicile, day
care, school, or agricultural purposes." It also states, "Any owner and/or its
successors and/or its assigns shall not install or otherwise use potable or non-
potable groundwater wells on the property; groundwater wells may only be
installed or used for purposes of investigation or remediation of hazardous
substances." It also prohibits alterations, improvements or disturbances of
"restricted areas" identified as Stage 2 and Stage 4 in a figure attached to the
Restrictive Covenant. These Restricted Areas are where subsurface
contamination remains at the Site.
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September 2010
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2.12.4.2 Final Clean-up Levels
The Clean-up Levels established in the 1998 ROD for ground water were based
on the Safe Drinking Water Act's, National Primary Drinking Water Regulations'
Maximum Contaminant Levels (MCLs). The Final Clean-up Levels in this
amended ROD are the same as the 1998 ROD with the exception of elimination of
bis(2-ethylhexyl) phthalate and lead as contaminants of concern for groundwater.
Groundwater samples collected after the soil/sediment remedial action through
2004, indicated that concentrations for both of these contaminants were well
below the Clean-up Level. Therefore, in 2005, these two contaminants were
removed from the routine monitoring program. The current MCL value for these
two COCs are the same as the 1998 Clean-up Levels. Groundwater Clean-up
Levels for this ROD Amendment can be found in Table 21 of Appendix B.
2.12.4.3 Anticipated Environmental and Ecological Benefits
Removal of the contaminated soil, sediment and surface water above clean-up
levels in 2001-2002 greatly improved the quality of the ecological habitat that
already existed on-site. It is anticipated that this amended remedy for
groundwater will achieve clean-up levels faster than the traditional pump and treat
method, which is better for the underground environment.
2.13 Statutory Determinations
2.13.1 Protection of Human Health and the Environment
The selected remedy will adequately protect human health and the environment through
treatment and institutional controls (1MCP §300.430(f)(5)(ii)). Surface soil, sediment, and
the majority of the sub-surface soil with contaminants concentrations above clean-up
levels specified in the 1998 ROD have been removed from the Site and placed in an off-
site landfill. The areas in which sub-surface soil contamination remains have been
identified as Restricted Areas on a Restrictive Covenant which prevents disturbance of
these areas. Successful implementation of EAB would reduce risks to human health and
the environment and meet RGs by treatment of contaminated groundwater (toxicity and
volume reduction) and institutional controls. Compared with the other groundwater
alternatives, EAB would be more protective because successful EAB would decrease the
toxicity and volume of contaminants in a more aggressive manner than MNA alone, and
pump and treat has been shown to produce very low groundwater recovery yields. A
Restrictive Covenant is currently in place on the Shuron Site property which places
limitation on what the property may be used for, prohibits the use of groundwater, and
prohibits disturbance of the two areas where residual soil contamination is present at
depth. The Restrictive Covenant needs to be amended to include the requirement of a
vapor intrusion evaluation, and possibly mitigation methods before occupancy of a
building located above the contaminated groundwater plume.
Shuron Inc. Site, ROD Amendment
55
September 2010
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Groundwater contamination has migrated off-site onto the adjacent parcel. The plume
was defined in 2007 and is confined to an undeveloped wetland area. Installation of a
permanent supply well in this area is not feasible without significant access
improvements, such as building a road, and is not likely since a municipal supply well
already exists across the street. During the offsite investigation, CDM was unable to
install a monitoring well in this area using specialized drilling equipment for swampy
conditions. Even if a supply well were to be installed in the offsite area, it would be done
so below the confining layer (Unit D) based on the limited production available from the
shallow aquifer. Additionally, all wells drilled in South Carolina require approval from
the SCDHEC prior to installation. SCDHEC would be unlikely to approve installation of
a supply well in the shallow aquifer of the offsite property. Therefore, the IC to be
utilized for this parcel is annual notification to the property owner as a reminder that
groundwater contamination exists on their property and that drinking water, production,
or irrigation wells should not be installed in the area of contamination or within close
enough distance that would affect the groundwater flow of the contaminated area. The
notification would include a copy of the most recent monitoring results. If clean-up
levels are not achieved within 10 years of the initiation of the remediation, either a
Restrictive Covenant or a governmental control (local ordinance) may be pursued.
The groundwater will be monitored until enough data is received that shows that the
groundwater is no longer contaminated above the clean-up levels noted in Table 21 of
Appendix B. The property use restrictions will remain in place until the groundwater is
returned to adequate quality for unlimited use. All of these measures will reduce the risks
to both human and ecological receptors. They are not expected to cause unacceptable
short-term risks or cross-media impacts.
2.13.2 Compliance with Applicable or Relevant and Appropriate Requirements
The Federal and State ARARs, potential ARARs, and requirements which are To Be
Considered that are relevant to the Amended Selected Remedy for groundwater are
presented in Table 13 of Appendix B. The amended selected remedy will comply with
the ARARs.
2.13.3 Cost Effectiveness
This section explains how the Selected Remedy meets the statutory requirement that all
Superfund remedies be cost-effective. A cost-effective remedy in the Superfund program
is one whose "costs are proportional to its overall effectiveness". (NCP
§300.430(f)(l)(ii)(D)). The "overall effectiveness" is determined by evaluating the
following three of the five balancing criteria used in the detailed analysis of alternatives:
(1) Long-term effectiveness and permanence; (2) Reduction in toxicity, mobility and
volume (TMV) through treatment; and, (3) Short-term effectiveness. "Overall
effectiveness is then compared to cost" to determine whether a remedy is cost-effective
(NCP §300.430(f)(l)(ii)(D)).
Shuron Inc. Site, ROD Amendment
56
September 2010
-------
For determination of cost effectiveness, present worth cost estimates were listed for each
alternative (See section 2.10.7). For each alternative, information was presented on long
term effectiveness and permanence, reduction of toxicity, mobility and volume through
treatment, and short term effectiveness. The information in those three categories was
compared to the prior alternative listed and evaluated as to whether it was more effective,
less effective or of equal effectiveness. Alternative #1 is the least expensive alternative,
but does not provide long-term effectiveness nor reduce toxicity, mobility and volume.
Alternative #2 is the second least expensive alternative but does not provide long-term
effectiveness nor reduce toxicity, mobility and volume. Alternative #6 (the selected
remedy) is the third least expensive and is considered cost effective because it is a
permanent solution that reduces human health and ecological risks to acceptable levels at
less expense than the other permanent, risk reducing alternatives evaluated.
2.13.4 Utilization of Permanent Solutions and Alternative Treatment (or Resource
Recovery) Technologies to the Maximum Extent Practicable (MEP)
The selected amended remedy provides permanent solutions for ground water. It also is
considered an alternative treatment to the traditional pump and treat methodology.
2.13.5 Preference for Treatment as a Principal Element
The selected amended remedy for ground water includes treatment as the principal
element. EAB is an active treatment component.
2.13.6 Five-Year Review Requirements
Because the original remedy resulted in hazardous substances remaining on-site in
subsurface soils above levels that allow for unlimited use and unrestricted exposure, five-
year reviews are required as a matter of statute. The first Five-Year Review for this Site
was completed on June 5, 2006. Reviews will continue to be completed every five years
until they are deemed no longer necessary.
2.14 Documentation of Significant Changes from Preferred Alternative of Proposed Plan
The Amended Proposed Plan for the Shuron, Inc. Site was finalized on August 16, 2010, and was
mailed to the community that week. The public comment began on August 20, 2010 and was
concluded on September 20, 2010. The Amended Proposed Plan identified Groundwater
Alternative 6 (Enhanced Anaerobic Biodegradation with Monitored Natural Attenuation and
Institutional Controls) as the Preferred Alternative for remediation. One set of written comments
on the Amended Proposed Plan were received by EPA during the public comment period. A few
questions were asked at the public meeting, but no statements were made by those present about
whether or not they supported the revised remedy.
Written comments were received from the PRP on September 22, 2010. As a result of those
comments, one change was made to the remedy. The PRP's comments were regarding the
Shuron Inc. Site, ROD Amendment
57
September 2010
-------
proposed requirement of placement of a Restrictive Covenant on the adjacent property onto
which contaminated groundwater has migrated. The PRP raised valid points for consideration
and therefore, the IC requirements on that parcel have been modified in this ROD Amendment
over what was presented in the Amended Proposed Plan and draft ROD Amendment. The
modification changes the requirement of a Restrictive Covenant on that parcel to annual
notification to the property owner as a reminder that groundwater contamination exists on their
property and that drinking water, production, or irrigation wells should not be installed in the
area of contamination or within close enough distance that would affect the groundwater flow of
the contaminated area. The notification would include a copy of the most recent monitoring
results. If clean-up levels are not achieved within 10 years of the initiation of the groundwater
remedial action, either a Restrictive Covenant or a governmental control (local ordinance) may
be pursued.
During the ROD Amendment review process, EPA decided to change MNA to "monitoring",
with SCDHEC's concurrence.
Shuron Inc. Site, ROD Amendment
58
September 2010
-------
PART 3: RESPONSIVENESS SUMMARY
The Public Comment period lasted from August 20, 2010 to September 20, 2010. During that
time period, one set of written comments was received from the public. The commenter stated
that the water in the area "has become undrinkable". Her concerns were regarding the quality of
her drinking water rather than a specific comment on the proposed remedy. The RPM will
follow up with her directly regarding her concerns.
One member of the community contacted the RPM by telephone. She wondered whether her
drinking water, received from the City of Barnwell, was contaminated since there is a water
supply well that is located very close to the Shuron Site. The RPM e-mailed a written response to
her, concerns. In summary, wells located between the Shuron Site and the municipal supply well
are not contaminated, groundwater flows in the opposite direction, and therefore, EPA has no
reason to believe that the municipal supply well would be contaminated from the Shuron Site.
The PRP also provided written comments on September 22, 2010. The PRP's comments were
regarding the proposed requirement of placement of a Restrictive Covenant on the adjacent
property onto which contaminated groundwater has migrated. The PRP raised valid points for
consideration and therefore, the IC requirements on that parcel have been modified in this ROD
Amendment over what was presented in the Amended Proposed Plan and draft ROD
Amendment.
Copies of both sets of comments, as well as the RPM's response to the telephone call are
included in Appendix E.
EPA hosted a public meeting for the Amended Proposed Plan at 6:30 p.m. on Monday, August
30, 2010, at the Barnwell County Public Library. The EPA RPM for this Site gave a PowerPoint
presentation which provided a brief Site history, a summary of actions completed to date, and a
discussion of the different treatment alternatives that have been evaluated. A copy of the
presentation is included in Appendix F. After the presentation, the RPM requested any
comments or questions from the attendees. Questions centered around future use of the property.
No specific comments were made regarding the proposed remedy. The transcript of the meeting
is included in Appendix G.
Shuron Inc. Site, ROD Amendment
59
September 2010
-------
PART 4: REFERENCES
Barnwell County Public Library, 2010. Barnwell County Public Library website:
liUp; www. obbe-1 tb.ore barnwel I index asp, viewed in August 2010.
CDM, 2009 Feasibility Study Amendment, Shuron Site. Barnwell. South Carolina, March 2009
CDM, 200S. Enhanced Anaerobic Bioremedjation Pilot Test Final Report for Textron, Inc. at
Shuron Site, Barnwell, South Carolina. September 20QS.
CDM and EPA. 2006. First Five-Year Review Report. Shuron Site, Barnwell. South Carolina,
June 2006.
Cily-Data.com, 20JO. Population Information for Barnwell, South Carolina, website:
http: ww\v .citv-data.com-;citvBarnwcll-South-Carolina html viewed in August 2010.
EN3R, 1997. Final Remedial Investigation Report for Texiron, Inc at Shuron Site. Barnwell,
South Carolina, January 1997.
EPA, 2010. Amended Proposed Plan, Shuron Inc. Superfund Site, Barnwell, South Carolina.
August 2010.
EPA. 2010, Letter to Textron. Inc. regarding Revised Remedial Alternatives and Cost Estimates.
Shuron Site, Barnwell. South Carolina, August 2010.
EPA, 2010. National Primary Drinking Water Regulations, website:
.••walcr.gpa.ffQV'drink contaminants'mtlex.cfm viewed in July 2010.
EPA, 2009. E-mail from David Buxbaum, EPA attorney, regarding ARARs Question -
Shuron Medley Farms Superfund Sites. December 2009.
EPA. 1999. A Guide to Preparing Superfund Proposed Plan*. Records or Decision, and Other
Remedy Selection Decision Documents July 1999.
EPA. 1998. Record of Decision for the Shuron Site, September 1998.
Federal Register. Volume 61, No, 117. page 30578, Monday, June 17. 1996
Federal Register, Volume 61, No. 247, page 67658, Monday, December 23. 1996
SCDHEC, 2010 (erroneously dated 2009) Letter to EPA regarding Request for Identification of
South Carolina Applicable or Relevant and Appropriate Requirements thai Pertain to the Shuron
Superfund Site received July 26, 2010. Shuron NPL Site. Barnwell County. SCD 003 357 589,
July 2010.
Textron, Inc., 2007. Notice of Restrictive Covenants, January 2007.
Shurtrt Inc Silo. ROD Amefldirwfll
Sopswnbor 2010
-------
APPENDIX A
FIGURES
-------
-------
-------
POTENTIAL
PRIMARY
SOURCES
PRMAPY
RELEASE
MECHANISMS
SECONDARY
SOURCE
SECONDARY
RELEASE
MECHANISM
SOUTHERN DISCHARGE
PIPE OUTFALL
BOILER
SPlLL AREA
FUJ./DEBRIS
AREA
UNDERGROUND FUEL
Oil TANK
N. DRAINAGE
01TCH
SOLID
LAGOONS |
SPILLS/LEAKS/
DISCHARGES
1/
WASTEWATER SETTLING
LAGOONS
VAPOR & DL
EMISSION
BI0ACCUMUIAT10N
\
-1
NOTES
Aqua.
Res.
Rec.
Ir-rs.
Terr.
Mr.
TRANSPORT
MEDIUM
EXPOSURE
POINT
EXPOSURE
ROUTE
HUMAN
BIOTA- Tarr.
BOTA-Aaua.
^•|R., |Tr... R~.
Plant jAnlmal
Plant | Animal
CURRENT
FUTURE
H INHALATION
I 1
CURRENT
FUTURE
TERRESTRIAL
PLANTS/ANIMALS
CURRENT
FUTURE
GROUNDWATER
CURRENT
FUTURE
T~*~T
SURFACE WATER/
SEDIMENT
CURRENT
_TURK£_Y_CR_EEK_
FUTURE
Turkey CREEK
'DERMAL CONTACT*.
CURRENT
JWETLANDS
FUTURE
WETLANDS
— {RESPIRATION
AQUATIC
HYPOTHETICAL FUTURE RESIDENT
RECREATIONAL USER
TRESPASSER
TERRESTRIAL
ON-SITE WORKER
POTENTIAL EXPOSURE PATHWAY
DIRECT C0N1AC1 FOR PLANTS
BIOACCUMULATtOH
,
V
eT-
CURRENT
_TURKFY_CREEK
""future
TURKEY CREEK
OTHER BIOTA
(PLANTS/
ANIMALS)
4:
CURRENT AETIANDS/
TURK£y_CREEK
FUTURE WETLANDS/
TURKEY CREEK
XI
! x II
ENSR CONSULTING & ENGINEERING
FIGURE 6-5
CONCEPTUAL SITE MODEL
FOR POTENTIAL EXPOSURE
SHURON SITE
BARNWELL, SOUTH CAROLINA
K.P.B. I 10/4/95 I
DERMAL CONTACT*
X
X
X
DERMAL CONTACT*
X
X
X
X
X
INGESTION
X
X
X
X
INHALATION
|
DERMAL CONTACT*
INGESTION
I
—
INHALATION
X
X
DERMAL CONTACT*
X
X
INGESTION
X
X
DERMAL CONTACT*
X I
! x 1 x
X
INGESTION
X I
i X |
X
RESPIRATION
1
1 1
X
DERMAL CONTACT*
X 1
x 11 ! x x
x
INCESTION
X 1 ..
x 1! 1 x |
X
RESPIRATION
1 |i I 1
*
_JLJ
DERMAL CONTACT*!! X
X
* !
•! X
x
X
X
INGESTION X
X
* 1
1!
X
X
RESPIRATION |j '<
1 II 1 f ; X
6630-055
-------
Properly Line
North
Ditch
Main
Building
r = 22tr
Wetlands
Areas delineated in brown and labeled indicate source control excavation areas
COM
Figure A-2
Current Site Plan
Rve-Year Review Report
Sharon Site
Barnwell, South Carolina
-------
'."rfcT_5
\
Wetlands
\
\
i #
\ *
Approximate area with groundwater
concentrations above remedial goals
r — /
% /
1
I
•» " V
I
I
\
' — 1 % J .
v?
N
I
\ *
x /
v
1" = 220"
lie 0
220f
Contour line represents the approximate limit of the extent of
groundwater wrth concentrations above remedial goats. This line
is conservative as i1 includes all monitored ctepths, tiydrogeologic
layers, and chemicals In many areas, the extent of groundwater
concentrations above remedial goals is limited to a narrow depth
COM range or incfrvidijal chemical
Extent of Groundwater
Above Remedial Goals
Shuron Site
Barnwell, South Carolina
-------
APPENDIX B
TABLES
-------
Table 1: Chronology of Events
Event
Pate
Ocular lens manufacturing
19S8-1992
Investigation - identified presence Of heavy melate and chlorinated VOCs in
groundwater, surface soils, and sediments
1982-1963
Groundwater samples were coJIeeted from four monitoring weJls by Sburon
Inc., Wilbur Smith & Associates, Westmghouse Environmental Services
Inc., and SCDHEG
1984-1987
Waste, sludge, soil, and groundwater samples collected by Westinghouse
Environmental Services. Inc.
1988 and 1990
Groundwater samples collected by SCDHEC
1991
EPA Site Discovery
A»ri! 1991
Preliminary Assessment
July 1991
Site Assessment
January 1993
Wastewater and sediment samples collected by EPA
1993 and 1994
EPA removal of drums of hazardous material from the building
March 1994
Admmistratfve Order On Consent For Remedial Investigation I Feasibility
Study and Removal Action
November 1994
Remedial Investigation
August 1995
'",. ''c-a Rer* oval A • .• <«:*: •• :
1995-1996
Supplemental Remed«al Inv.-si qat or Sampling
Ac
&te proposed for inclusion on EPA NPL
June 1995
Final listing on EPA NPL
December 1996
Feasibility Stud^
April 1997
Record of Decision
September 1998
Unilateral Administrative Ordc for Remedial Desion ar.c Remedial Action
June 1999
Baseline groundwater monitoring event
November 1999
Supplemental site characterization
June2000
Quarterly groundwater monitoring began
January 2QC1
Remedial Acton few Soil began
June 2001
Remedial Design for So«l completed
July 2001
Remedial Action foe Soil completed
July 2002
Post Remedial Action Groundwater Sampling and Dewatering
May - August 2005
Groundwater remediation alternatives evaluation and associated additional
characterization acfrvittes
May 2003 - presen
Semi-annual groundwater mentoring
September 2005 - presenl
First Rve-Year Review competed
June 2006
Off-Site groundwater (nvestaijation completed
2007
Enhanced Anearobic Bioremediation Pilot Test FinalRegort
September 2008
Appendix 8. Tables 0-1 Sbufon ROD Amendment
-------
Table 2: Remedial Investigation Maximum Concentrations per Media
Contam loan t
Ground Water
Maximum
Concentration
(M9'U
Surface Water
Maximum
Concentration
(WU
Sediment
Maximum
Concentration
(mgi'kg)
Surface Soli
Maximum
Concentration
{mg/kg>
Subsurface
Soil
Maxsrman
Concentration
(mgAg)
V "vi I"'" ;;r If:
3,700
52
b,i
_
9,1
1.2-dichlonjetlTane
2,600
»
1,2-dichloroetfiene
47,000
1.400
0.41
6
460
T nchloroethene
61.000
10
—
0.85
1.100
T eirachlof oetbane
52,000
15
-
42
2,500
Tcriuer*®
2,400
51
z
0,16
60
Ethylbenzene
20.000
17
16
0.036
1.400
XySenes (lotall
93,000
360
66
0,36
3,700
Bis(2-ethyihexy1)p*uhalale
610
95
11
230
110
Lead
124
343
7470
14.600
17.400
Arsenic
56
57
136
117
Coops'"
—
116
341
741
400
Zinc
-!
1.700
2080
5,170
7.910
Nate* Data ceprtd torn Tabte t of the 199B ROD
—ditaies easa #« flat irelueSed in tte 1996 ROD feurrvrwy tabte 1
Appendix B, TaWes
8-2
Shuron ROD Amendmenl
-------
Table 3: Summary of Chemicals of Concern for Groundwater and Medium-Specific Exposure
Point Concentrations
Seanarto Timeframe:
Medium:
Exposure Medium;
Futon
Ground water
Ground water
Exposure Point
Chemical uf Concern
Concentration
Detected
Unit*
Frequency
of
Petection
Exposure Point
CorvcpniraUon
Unit*
Statistical
Moaturo
Minimum
Maximum
" ShaJtow Ground Water
tKSi2-ft)0ttw>e
37
37
Mg,l
1.!9
37
ug/L
MAXIMUM
T richloroetheofl
&
15
m>Q'1
3/9
ts
wA
MAXIMUM
Deep Ground Water
T hChloro datn tarn trio fin a
COCs fcK girxmd wator in lha 199® ROD ar» ineludod here
[c | Information for ifitewwCiaie ground vrfltof wb» coptod horn TaWe 6-17 of the Ri Exposure Pwrrt Concwn&vSoni far COPts Only the data from Bho ftrval
DOC* ter Bfound wo*Bnn tfwi 199® R00 am irxAfded ham
id) The CU0K modal #nii be u«d to vvaiusto exsosuro to toad
Appendix B„ Tabtes
B-3
Sl>uron ROD
-------
Table 4: Cancer Toxicity Data for Groundwater COGs
Pathways: Ingestion, Der
Chemical til Concern
nal. Inhalati
Weigh! of
Evi-dcnee I
Cancer
Guideline
Description
on
Oral Cancer
Slap® Factor
[fi]ancs
A = Group A - Human Carcinogen evidence of cwcinegwwsfy in human*)
32 * Croup B-2 - sufficient ewdecee of e»ofegen>city in ar*naite witn m«Jequato or tack of OTK&encs «n twimans
D " Group ~ • Not Ciiissfriatio as in Huntn CiifGiy»ei"w3!y i«f»d&«fufltle of no evKJsnca)
MA = Wed Appteafcto
NO « Not D#l*uTmn#d
IRIS = Iraegrubxl Risk jr-ionruiton System, nr> •csrrtna oHTputer daLabaao & toaicnlogical Intoratan (US EPA. 1996)
HEAST = Heaitn Eflects Assessment Summary Tables, published annually try 9m 0,5 EPA (1995)
SHRTSC = U S EPA SuperSunrJ Healfri fts* T#chrncal Suppcfl Center
Append** B, Tables
Stiuron ROD Amendment
-------
Table 5: Non-Cancer Toxicity Data for Groundwater COCs
Pathways: Ingestion, Dermal
Chemical of Concern
Oral
Reference
Dose
timg/kfl/dajrH
Dermal
Reference
Dose
[[rrjo/kgWey))
Target Organ
Source
Date
bis< 2-eEhylhexyS JphEhala! b
2.00E-03
1 0CE-02
Increased1 relative liver weights
IRIS
t996
1„2»0icMq methane
ND
ND
NA
NA
NA
1 ^|"OicWoroi6Bi6o,e | Total >
9-00&03
7 20E^03
Liver
HEAST
1995
Eshyl befttene
ijdo&oi
8.Q0E-C2
Liver end fcdney
IRIS
1996
TetfaditoreclNafw
1 OOE-02
8.00E-C3
Liver
IRIS
1996
Toluene
200E-01
i eoE-oi
Liver and s«dney
IRIS
tsae
Trichlght Increased mortality
IRIS
1996
Pathway: Inhalation
iruijMii'Dn
Raffl trance
Dose
Hmg/kBUiy}J
Target Organ
Source
Date
bisf 2-etftythejeyl tolithatate
ND
NA
NA
NA
1,2-Diehloroethane L"
143E-03
gastrolniestinaJ disturbances: Iwand gallbladder
disease
SHRTSC
1995
V2-DiehiO!-c»tr»ofie r :
ND
NA
NA
NA
Etnyl benzene '
2-90E-01
Developsinentel taioaty
JRIS
1996
Tefrach I(xne1he n ? :
1 14E-01
Liver and Sydney
SHRTSC
1995
Toluene "
1 14E-01
Neurotogical effects
IRIS
1996
Trtchtarootfiefio
ND
NA
NA
NA
¦
ND
NA
NA
NA
X/Vsoes (Tots!)
ND
NA
NA
NA
HQIM
(a) The derma) reietenee dose (WD) was calculated by mut&plyirg tfte oral RfD by the acsyopr«6e EPA Re^jton * d*rm& a&sorp&on
!aetof for converting an admirvsteresf Ocw to an absented dose The abwptajn factors used are 80 percent for voial'ie wganie
BfemwBl*. 60 pw»l for mrmKUstt o 70 ikfl>
!c} Converted from U S EPA H««nM conoanlraOcin of 1E+0 (mg/m4) * 20 (m'.tdajf) / 70 l*fl)
[dj Converted from a provtsonal cftmrac reference corcentra&on o> 4E-1 Img.'mh * 20 (m ",'tfay> J 70 {kg 1
(at Canwwled frartt U 5 EPA rafef«t£» cDf>£Mf>tra£jan o«46>1 (ingAn1)* 20 |mJ!diify) i1 TO (kg)
NtA a Not AjjpJicjfto
MO ¦ Not Deiertwied
IRIS = InlBflraSttf Risk Information SysJo-m an onfew Cpmputor database or IfcociotsQiCal Intanahon (U 5 SPA, 1996J
«£AST = Hearth Effects Assessment Summary Tables, puWisned awiuatty by the U S EPA I t995)
SHRTSC = O S EPA Soperfurw! H&oa-' Tecfintcai Support Cantor
Appendix 8. TaWes
Shurpn ROD Amendment
-------
Table 6: Risk Characterization Summary - Carcinogens for Groundwater
COCs - Future Indoor Worker
Scenario Timeframe: Future
Receptor Population: 1 ndoar Worker
Receptor Ag*: Adult
Exposure Point
Chemical of Concern
Carcinogenic Risk
Inhalation
Ingestion
Dermal
Exposure
Route* Total
ShaJkjw Ground Water
arsenic
NC
435E-05
1 G0E-07
4.36E.Q5
benzene
3.04E-O6
3046-07
3.67E-G9
3 3SE-06
beryllium
NC
1.S0E-0S
4 1SE-08
1 8QE-05
btsfj-ethylhexyl iptithaiate
NC
1 52E-M
4.60E-G7
1.57E-05
NC
3 49E-07
313E-07
B.62E-07
1.2-dchlc*OQttiar>e
6.27603
fl 27E-04
Z52E-0«6
9.10E-03
lefracjilopoeSftyleno
L' 2E-C3
9.45E-Q3
2.61 E-04
t 33E-Q2
indhtonoethytene
1 28E-G2
2 34E-03
2 16E-Q5
1 52E-02
vinyl cMoritSe
3.25E-G2
2.Q6E-Q2
8-64E-05
5 32E-02
Risk. Total«
5.72E-02
3.33E-A2
3-72E.04
9.09E-02
IntBirnediffle Ground Water
&is.|2-otftyheiyl Johthitata
NC
3.G3&06
921607
3 12E-05
tnchtoroetfiytenc
3.156-06
5 771-07
5 30E-09
3736-06
RJsh Total =
3.15E-06
3 09E-Q5
9.26E-G7
3.5QE-05
Deep G«t>ur«j water
beryllium
NC
2.251-05
5.181-08
2.26E-05
trlchtereethytene
1 05E-06
192E-07
1.771-09
1 24E-Q6
Risk Total«
1.0SE-W
2J27E-05
Sv36E-0fi
2.38E-0S
NMer
>*C = Ifc# calculates So Owe rwporiM >iAic twUtite
= Nol Incemnptote (jspasurfl p^ftway
Appendix B, Tables
Shuran ROD Amendment
-------
Table 7; Risk Characterization Summary - Carcinogens for Groundwater
COCs - Future Outdoor Worker
Scenario Timeframe: Future
Receptor Population: Outdoof Worker
Receptof Age: Adult
Exposure Point
Chemical of Concern
Carcinogenic Risk
Inhalation
Ingestion
Dermal
Exposure
Routes T eta 1
Shallow Ground Wose-r
arsenic
NE
4.35E-05
1 OOE-07
4.366-05
benzene
NE
3.04E-Q7
3.B7E-09
3 066-07
baryllrum
NE
1.SQE-05
4 15E-08
1.806-05
&ii{2-«'jfTyW>e*y)iprtt?iaia;&
NE
1 52E-05
4 60S-07
1 57E-05
cartia/o'c
NE
' .:u~ -
313&07
6 62E-07
t.2-dichloro®lftaiie
NE
8.27E-04
2.52E-06
M0&O4
tBtrach'oixwtfhYiene
NE
9.A5E-03
2.61 E-04
9716-03
1 Eriehtoroethyteno
NE
2.34E-03
2-16Ej0S
2.36E-03
Iviriyl chloride
N£
2.Q6E-02
@ 64E*Q5
2.07E-Q2
Risk Total«
NE
3.33E-02
3.72E-04
3,376-02
Intermediate Ground Water
tra<2-e1hylhe*y1i[jh1hala(B
NE
3.03E-Q5
9.21 E-07
312E-05
tri ch lornelhyfen e
NE
5.77E-07
5.30E-09
S 62E-07
Risk Total =
NE
3.09E45
9.26E-Q7
3.18E-0S
Deep Ground Water
beryllium
NE
2.25E-05
5.18E^0S
2 26E-05
tnc^loroeWiyfene
NE
1.92E-07
1.77E-09
V94E-07
Risk Total »
NE
2.2?E4)5
5.36E-08
2.2?E^S
NC = Not talculaSJis} No &M nmpanaa value available
NE - Nh>1 (r.alL,i!c< TCompHjUi yiygjaim pathway
Appendix B. Tables
B-7
Shufon ROD Amendment
-------
Table 8; Risk Characterization Summary - Carcinogens for Groundwater
COCs - Future On-site Resident
Scenario Timeframe: Fulure
Receptor Population; On-site Resident
Rrceptgr Age:
Exposure Point
Chemical of Concern
Carcinogenic Risk
Inhalation
Ingestion
Dermal
E*posure
Routes Total
Shallow Ground Water
arsenic
NC
1.79E-04
1 S7E-0e
1.S1E-Q4
benzene
5.43E-06
V25E-06
L 5.77E-0S
6.74E-QG
beryllium
NC
7 411-05
S.52E-07
7O8E-05
bis(2-flEhylhoxyf)i)htha 'ate
6.23E-05
7.24E-06
6 95E-CS
cartoazole
NC
1 44 E-06
4 53E-06
6 37E-06
1 ^-ditWonoetha™
t.48E^2
3-40E-03
3.96E-05
1 02E-O2
tetraehioroeth jrfene
6 49E-03
3J8&02
4.TOE-03
4 34E-02
tnciitafoemyierve
2.2BE42
963E-03
339E-04
3 2SE-02
vinyl chloride
S.BOE-02
0 4&E-02
1 36E-03
1 E-0
Risk Total s
1.D2E-01
1.37E-01
5.85E43
2 45E-01
Intermediate Ground Water
bts(2-ethylh«*yl tohthaiate
NC
125E-04
1 45E-05
140E-W
tricMoroethylene
5.61E-06
2.37E-06
8.34E-OB
0 06E-06
Risk Total =
5.61 E-06
1.27E-04
1.46E-05
14SE-04
Dees Ground Wale*
beryiiium
NC
9-26E-05
S.t5E-Q7
S34E-05
tnehlnroethylefve
t.87E-Oe
749C-07
278E-O0
3 69E-06
Risk Total ¦
1.87E4M3
9.34E-05
8 43E-07
t.fl1E-05
Mom
\C = No) calcuiefo>3. No dose rsspw-se vaM available
NfE = Not e*st*aied incomplete exposure palhway
Appendix B- Tabies
Shimon BOD Amendment
-------
Table 9: Risk Characterization Summary - Non-Carcinogens for Groundwater
COCs - Future Indoor Worker
Scenario Timeframe; Future
Receptor Population; Indoor Worker
Receptor Age: Adult
Exposure
Point
Chemical of Concern
Primary
Target Organ
Non-Carcinogenic Risk
Inhalation
Inqcsti&n
Dermal
Exposure
Routes Total
Shallow
Ground Water
aluminum
N
NC
9 7&E-01
2.25E-C3
9.80E-01
arsenic
3, V
NC
Z71E-01'
B.23E-Q4
2.72E-01
tJSflUfT!
BP 0
NC
3 93E-02
&.Q3E-Q5
394E-02
tremens
8
1.72E-01
9 78E-G2
1 42E-G3
2.71 E-01
Mfyflnim
NC
2 35E-Q3
S40E-06
2.36E-03
bls(2-athylh&xyl ;$shthaiatB
L
NC
1 52E-01
4 60E-03
1.57E-01
cadmium
K
NC
6 266-02
7 20E-65
6.27E-02
chromium (hexavatertf)
NC
3 956-01
1 18E-Q3
3.©6E*01
1,2-tfecMoiMtharie
GI.L
1 7SE+02
NC
NC
T 78E+02
1,2-dichkjroeChonio (total)
L
NC
495E*0l!
2.84E-G1
4 93E*01
©myib®ra«ne
O.K. L
6.24E*00
1.81E+00
770E-Q2
8.13E-HJ0
manganese
N R
NC
4 066-01
9 35E-04
4 Q7E-01
4-m ethyl phenol
N R
NC
4.7SE-02
4 41E-Q4
4.83E-02
ntckfll
DWG
NC
B66E-02
1 11E-05
8.86E-02
tatrachtarootftylene
K, L
4 46EM31
5.09E+01
1 40E+CC
9.6SE+01
lotuerse
K. L.N
1 97E+O0
1.13E-01
2 91E-Q3
2.WE+00
tnchtoroemylerie
0
NC
9.95E+01
S 1&E-G1
1.O0E+O2
vwacBurn
NC
2 &2E-j0t
5.79E-Q4
2.536-01
syie^e (total]
~L DWG. N
NC
4406-01
203E-02
4 : 01
Total Hazard Index ¦
2.31 E*02
2,05E*Q2
2f1E*00
4.39E+Q2
IruesmedtaM
Ground Water
cs: 2-etn , Ijiilillinliilu
NC
3.03E-01
9211-03
3.12E-D1
1 r2-dich4ort»thane (total)
L
NC
4Q2E-02
2 31E-04
; ~
5richloroettry!ene
0
NC
2 45E-02
2.25E-04
247E-02
Total Hazard Inde* =
NC
3J8E-01
9,871413
3.77E-01
Deep Ground
WbHk
beryllium
NC
2.94E-Q3
&75E-06
295E-03
manganese
N,R
NC
5 42E-Q4
1 2SE-06
5 436-04
tnchtorDertfry'iene
O
NC
8 15E-03
7.50E-05
8.23E-03
Total Hazard Index =
NC
1.16E-02
8 30E-Q5
1.17E4S2
3 * Wooe L ¦ lw«
3P = Wood pressure N • iTfruffltegiCal
0' = rte-.wprner.1a! NC = Not Mlr.!jU>1rvJ Hq (Jew fwsonsff value
Dt *
-------
Table 10: Risk Characterization Summary - Non-Carcinogens for Groundwater
COCs - Future Outdoor Worker
Scenario Timeframe'. Future
Receptor Population: Outdoor Worker
Receptor Ago; Adult
Exposure
Point
Chemical of Concern
Primary
Target Organ
Non-Carcinogenic Risk
Inhalation
Ingeition
Dermal
Exposure
Romas Total
Shallow
Ground Water
aluminum
N
NE
97SE-CT
225E43
9S0E41
arsenic
S,V
NE
2.71E41
623644
272E41
barium
BP, 0
NE
3.93E42
9.03645
3&4E-02
benzene
B
NE
9.78642
1 42E-03
9 92E-Q2
beryllium
NE
2.35E43
54GE4S
2.36E43
t>s| 2-elfiyfhexy 1 )ptrthalatB
L
NE
5 52E-01
460E43
1 57E-01
cadmium
K
NE
6 20E42
7 20E-05
E.27E42
chromium (hexavalent)
rvE
3.95E41
1 18E43
3 96E41
t ,2-dichlortwthene (total)
L
r*E
4 95E+C1
2.84641
4.9ee*oi
BthylbenzenB
D. K, L
NE
1.B1E+00
7.70E42
1.B9E+00
mmaiwse
N, R
NE
4.Q6E41
9.35644
4 07E41
4-methylpbenaJ
N, R
NE
4 79E42
4 41E44
4 B3E42
nkkei
DWG
NE
8.86E42
1.11E-06
0 0€E42
tetrachioroetftytene
KJ.
NE
5 09E+01
1 JOE *00
5.23E+01
toluene
K. LN
NE
113E41
2.91643
1.16E41
tridtiQfMtfiytefMI
0
NE
9 95£*01
9.156-01
1 OOE+Q2
vanadium
NE
2.52E-01
5.79644
2.53E41
xylene (total)
DL. DWG. N
NE
4 40E41
2 036-02
4 60E-01
Total Hazard Index =
NE
2.05E-&2
2.71 E+00
2.08E+Q2
Intermediate
Ground WaJe*
fcns( 2-elhylhPfyfiphlKalaiB
L
NE
3.03E41
, ,, .
3 12E41
1,2-dichlanwthene {lata1)
L
ME
4.02E42
2.31E44
¦i G4E-02
tnchlortwthy'enD
O
NE
2.45E42
2.256-04
2 47E-02
Total H«ard lode* "
NE
3.68E-01
9.67E-03
3.77E-01
Doe© Ground
Water
tofytliuffl
6756-06
2 95E43
mar«ganeso
N. R
NE
5 42E-04
1.25646
S43E-04
trichlofoeShylene
O
WE
8 15E-Q3
7.50E45
0 23E-03
Total Hazard Index =
NE
1.16E42
S.3QE-Q5
1.17E-02
hkslfti'
B = Wood N = neunjiogicai
BP » Wood prelum >iC ¦ Hoi calculated No date response value availabte
D = dowwtoomsritBl ME = Not evaluated Incamptos# »»po*uu ipafrway
DL ¦ decreased longevity O * othw
DWG = dtKfwiMd wcajht gam R - nj*fWna&ty
K. * kidney S = #k*i
L » liver V * vascular
Appendix B, TaWes
B-10
Shuron ROD Amendment
-------
Table 11; Risk Characterization Summary - Non-Carcinogens for Groundwater
COCs - On-Site Resident
Scenario Timeframe:
Receptor Population: On-Site Reskien!
Receptor Age
Exposure
Point
Chtfliiml of Concern
Primary
Target Orsan
U Afl HF»l,nMBIl2p Dir L
ryon^uarcinoyenic kisk
Inhalation
Ingestion
Derrnat
Exposure
Routes Total
Shallow
Ground Water
iBfuminura
H
NC
6 39E+OQ
4 41E-C2
6.43E»O0
arsenic
5, V
NC
1.77E*00
1 22E42
1.7SE+00
twHum
BP, D
NC
2.S7E-G1
1.77E-03
2.59E-01
benzene
B
6.31E-01
S.39E-01
2.78E-02
1.30E+W
beayilium
NC
1 53E-02
1 06E-04
1 54E-G2
bi5(2-ethyihi(}jcyt)phlhj>l«tfi
L
NC
9' 9lE*Q1
9,Q2E*02
1.088+00
cadrnsuiTi
K
NC
1 D9E-01
i 41E-03
4 1OE-01
dhrottnum fhe*iȴOlssnl i
NC
2 5SE-Q0
2 32E-02
2.60E*00
1 „2-dichl«DethenB (total)
L
6.S4E-HJ2
3.23E*02
5 57E+O0
9.83E+02
«thylbenxen«
D, R. L
2.29E*01
1 51.E+O0
3 62E+01
mancjaneae
ISI4 r
NC
2,6ee>oo
1 S3E-02
2.B0E+OO
4-melhy)pha«el
N. ft
NC
3 13-E-Q1
8S5E-Q3
3.22E-01
ntciwl
DWG
NC
5 79E-01
2.T8E-04
5.79E-01
letrad^lnroethyiiane
•Li-
1 S4E+02
3 32E*Q2
2.75E+01
524E*Qi2
toluene
lt, L„ N
7 2SE*00
7.351*01
5.71 E-02
8.04E+00
iriqWorpethyiene
0
NC
6 50E+Q2
1 79E*0l
6.6SE+02
vanadium
NC
i,$4E*ooi
1 13E-02
1.65E+00
xytene (Was)
DL, DWG, N
NC
&me*oo
397E-01
3„2BE*QQ
Total Hazard Index ¦
8.49E+02
1-34E*03
5.32E+01
2.24£*03
iTrtormediatB
Ground Watar
bisf^-ethylhciiyljphshaiate
NC
1.9BE-00
180E-01
2.1fiE*Q0
1 ^HScJitonsethofie (total)
L
NC
2.63E-G1
4.53E-03
2.6aE^J1
frttfiloroelhytene
Q
NC
1 60E-01
4 41E-03
1.64E-01
Total Hazard Inde* ¦
NC
2.40E*00
1.S9E-01
2.59E*0D
Deep Ground
Water
beryl fium
NC
1 &2E-02
1 32E-Q4
1.93E-G2
manganese
N, R
NC
3 54E-03
2.44E-05
3 56E-G3
trictotoroethylene
0
NC
5 3SE-02
1 47E-03
5.4SE-02
Total Hazard Index -
NC
7.60E-02
1.63E-G3
7.77E-02
Motes
9 * btoofl l »lww
BP » Blood pressure N = rwuroiogieat
0 » etevetopfrterrLal NC 3 Not calculated Ho {Jom* i caponse value *vaiiati*9
DL " decreased longevity 0 « ett'«r
DWG = decreased weigH gam R=rtrepifs*jry
< « Money S = *kin
V - vascular
Appends B, Tables
Shurofi ROD Amendment
-------
Table 12: Occurrence, Distribution and Selection of Ecological Chemicals
of Concern
Cxpoaure Medium:
Shadow Ground water
Chemical of Peicntral
Concern
Maximum
Concen-
tration
(Wl)
Mean
Corram-
tnfton
tW^LJ
Background
Concen-
tration (pgrt.J
screening
Toxicity
Value
Imnj
Screening
Tonicity
Value
aource
HQ
Value*
Final
coc?
Aluminum
100000
56377
NA
87
1149 4
No
Iron
15214
NA
TOOQ
b
687
No
1 ^[-dichlofosChcns (total)
45500
4500
NA
1350
b
33.7
Yes
ethyl benzene
18500
1758
NA
453
c
408
Yes
5200Q
4558
NA
84
b
6100
Yes
2300
187
NA
17S
b
131
Yes
!' rhlGrDOfhri^0
€1000
5263
NA
21900
d
28
Yes
jjyWyn© (tertal)
90000
7972
MA
62309
e
1A
Y»
Mobs*
" HQ vftfmss wefe rot presented m Table M4 c! eie Rl However it mas cateuiased #1 thu table by dr.---3>ng Bfie maasiTHaTi
Kxiosnt.-abon by the s-EfeerunG toxioty value
a LD "cr QaaKrua mac'-a. (Varscfueiw 198-31
a Ristpan 4 CfirortK: AWQC or Reg Of IV Sere*
yw>C Value
[baaed on Total Recoverable Metals)
B ¦ 1 a«eit chronic value for dapftnxH, |Sulnr and Mabrey. 1994}
a * PrnpQWKl AWQC Freshwater
(Ovomc (U &. EPA, 1991
e - Lo««5( (Jirpric value for fish
Suler and Mabrey 1994)
SA = Not Available There was Ik
> SirfntMi t^atfow groundwater background statu available for use during ihe Ri
Th« Ptoo guWarfflr TalSe -aEso ind«a»» eolumrji for "Mnimyrn Concentration" and *95% UCL of the M#an Cer«en!.ra{fln*
riato mm not ("Wfnled in Table 7-14 off Che Rl. ard Ehorefwt thaw odunvia m not iflefcajnd In Chm, labia
Appendix B. Tabfes
&-12
Shuiron ROD Amendment
-------
Table 13: ARARs
Action | Requirements
Pro-requisite I Citation
Chem
ical Specific
Classification of
groundwater
All South Carolina ground water fc$ classified Class
GB under SCDHEC R 61-6SH9. which meets the
definition of underground sources of drinking water
Ground waters , except within mixing zones, located
wtilun the State of South Carolina — applicable
SCDHEC R. 61-68H.2
Restoration of
groundwater to its
dessgnaSed use{s)
May no! exceed Maximum Contaminant Levels
(MCLs) for organics as set forth in R 61-58, Primary
Dnnkinq Water Regulations.
Ground water classified as Class GB under
SCDHEC R 61-68H 9, requiring restoration —
relevant and appropriate
SCDHEC R. 61-68H.9 b
Establishes hearth-based enforceable standards for
putoUc water systems (Maximum Contaminants
Levets (MCLs)),
The Site groundwater is not currently a source for
public water system Treatment of groundwater via
enhanced anaerobic btodegradation in conjunction
with monitored natural attenuation is expected to
reduce contaminant concentrations to below MCL
values — relevant and appropriate
40 CFR Part 141
Location Specific ARARs and TBCs
Destruction of
wetlands
Requires consideration of adverse impacts
associated wi1lh destruction or loss of wetlands and
to avoid support of new construction an wetlands if
practical alternative exists.
Actions that involve potential unpacts to, or take
place within. wetlands - potentially a pp I Icable
Protection of Wetlands,
Executive Order 11990.
40 CFR 6 302(a) and
Appendix A
Action Specific ARARs and TBCs
General Construction Standards—Alt Land-disturbing Activities (i.e.. excavation, clearing,, wolt installation
ate.)
Managing storm
water runoff from
land-disturbing
activities
Musi; comply with the substantive requirements for
stormwator management and sediment control of
NPDES General Permit No SCRl 00000
Large and small construction activities (as defined in
R 61-9) of more than 1 acre of land within a half'
rrnle of a surface water body — relevant and
appropriate
SCDHEC R. 61 9.122 41
NPDES General Permit
No SCR 100000
Shan prepare and comply with a stormwater
management and sediment control plan meeting
requirements of R.72-307H
Land disturbing activities involving two (2) acres or
less of actual land disturbance which are not part ol
a larger common development or sale — relevant
and appropriate
SCDHEC R 72-305 A
The stormwater management and sediment control
plan shall contain supporting computations*
drawing®, and sufficient information describing the
manner, location, and type of measures in which
stormwater wits be managed from the entire land
disturt5«fi^artvrt^_
SCDHEC R. 72-305. C.
pag» 1 ot 7
Appendix 0, Tables B-13 Shuron ROD Amendment
-------
Table 13: ARARs (page 2 of T)
Action
Requirements
Prerequisite
Citation
Managing fugitive
dust emissions
from land
disturbing
activities
Emissions of fugitive particulate matter shall be
controlled in such a manner and to the degree that it
does not create an undesirable level of air pollution
Activities that will generate fugitive particulate matter
(Statewide) — applicable
SCDHECR 61-62 6
Section 111(a)- Control of
Fugitive Particulate
Matter Statewide
Volatile organic compounds shall not t>e used for
dust control purposes. Oil treatment is also
prohibited
SCDHEC R 61-62.6
Section (11(d)
Mor
Operation, and Abandonrmtnl
Installation or
Abandonment of
Permanent and
Temporary
Monitoring Wells
All monitoring wells shall be drilled, constructed,
maintained, operated, and/or abandoned to ensure
that underground sources of drinking water are not
contaminated
Construction of permanent and temporary
monitoring wells (including non-standard installation,
as defined in R 01-71S(2')) — applicable
SCDHECR 61-71H 1b
Casing shall be of sufficient strength to withstand
normal forces encountered during and after well
installation and be composed of material so as to
minimally affect water quality analyses
Construction of Temporary Monitoring Wells
(including Direct Push, as defined in R. 61-MB. 12)
— applicable
SCDHEC R 61-
71H.4,a.(1)
Casing shall have a sufficient diameter to provide
access for sampling equipment.
SCDHEC R 61-
71H.4.a.(2)
The monitonng well mlake or screen design shall
minimize forrnatlonal materials from entenmg the
well The filter pack or intake shall be utilized
opposite the well screen as appropriate so thai
parameter analyses will be minimally affected
SCDHEC R 61-
71H4a,(3)
Operation and
Maintenance
Temporary
Monitoring Wells
Al 1 temporary monitoring wells shall be sealed with a
watertight cap or seal until abandoned Temporary
monitoring wefls ShgJI be maintained such that they
are not a source or channel erf contamination before
they are abandoned
Construction of Temporary Monitoring Wells
(including Direct Push, as defined in R. 61-71B.12}
— applicable
SCDHEC R. 61-71H.4. b
Appendix B, Tables
B-13
Shuron ROD Amendment
-------
Table 13; ARARs (page 3 of 7)
Ad ton | Requirements
Pro-requisite
Citation
Abandonment of
Temporary
Monitoring Welts
All temporary monitoring wells shall be abandoned
within 5 days of borehole completion.
Construction of Temporary Monitoring Wells
(including Direct Push, as defined in R. 61-710 12)
SCOHEC R 61-71H 4
c, (1)
A conventionally drilled temporary well shall
abandoned by forced injection of neat cement,
bentocirte-camarct, or 20% high solids sodium
beritonite grout through a tremie pipe starting at the
bottom of the well and proceeding to the surface in
one continuous operation
SCDHEC R. 61-71H.4.
c- (21
A Temporary Direct Push Weil that does not
penetrate a confining layer shall be abandoned by
forced injection of neat cement bentonite-eemenl. or
20% high solids sodium bentomite grout through a
tremie pipe after the sampling device has been
removed.
uppllQiSDw
SCDHEC R. 6I-71H.4.
e(3)
Protection of
Underground
Sources of
Drinking Water
The movement of Hu»ds containing wastes or
contaminants into underground souices of dnnking
water as a result of injection is prohibited if the
presence of the waste of contaminant
(A) Mary cause a violation of any drinking water
standard under R61-S8.5; or,
(0) May otherwise adversely affect the health of
persons.
Persons ownmg, using, or proposing to use any well
for underground injection — applicable
SCDHECR 61-07 5
Information on
Injection Well foe
Permit
Shall provide information related to nature and
characteristics of the injection activity and fluids as
provided in subsections (a) through If).
Class VA corrective action wells used to inject
groundwater associated with aquifer remediation as
speeded in SCDHEC R.61-e7.l 1 (EK1 HO —
applicable
SCDHEC R.61-
S7.13.(GW2)
Operation and
Maintenance of
Class VA
Injection Well
Shall at aN times properly operate and maintain all
faoJitKss and systems of treatment arvd control which
are installed or u&ed.
SCDHEC R.61-A7 13,(X)
Shall immedialefy stop injection and shall not restart
the injection system until malfunction has been
corrected
Malfunction of the Class VA well Injection system
which may cause fluid migration into or between
underground sources of dnnking water —
applicable
SCDHEC R 61-
87.13.(EE)
Construction and
Abandonment of
Class V.A
srejection well
Minimum standards for construction and
abandonment of injection wells are those stated for
all wells In the SC Wet) Standards and Regulabons
RJ61-71
Corrective action wells used to inject groundwater
associated with aquifer remediation as specified in
SCDHEC RJ3l-fl7.1 t.(E)(1X<) Class VA —
applicable
SCDHEC R 61-67 3
Appendix 6, TebJes
B-13
Shuron RQQ Amendment
-------
Table 13: ARARs (page 4 of 7)
Action
Requirements
Pro-requisite
Citation
Waste Characterization and Storage — Primary Wastes (i.e . well cutting softs) and Secondary Wastes
Must determine it solid waste is hazardous waste or
if waste is excluded under 40 CFR 261 4(b): and
40 CFR 262 11(a)
Must determine it waste is listed under 40 CFR Part
261, or
Generation of sotid waste as defined m 40 CFR
261.2 and which is not excluded under 40 CFR
40 CFR 262 11(b)
Characterization of
solid waste
Must characterize waste by using prescribed testing
methods or applying generator knowtedge based on
information regarding materia) or processes used
261.4(a) applicable
40 CFR 262.11(c)
Must refer to Parts 261. 262, 264, 265, 266, 268.
and 273 of Chafer 40 for possibto exclusions or
reslrictioos pertairartg to management of the specific
waste.
Generation of solid waste which «s determined to be
hazardous — applicable
40 CFR 262 11(d)
Must obtain a detailed chemical and physical
analysis on a representative sample of the wasters),
which at a minimum contains aB the information that
must be known to treat, store., or dispose of the
waste in accordance with pertinent sections of 40
CFR 264 and 268
Generation of RCRA-hazardous waste for storage,
treatment or disposal — applicable
40 CFR 264 13(a)(1)
Characterization of
hazardous waste
Must determine the underlying hazardous
constituents [as defined in 40 CFR 268,2(1)] in the
waste.
40 CFR 268.9(a)
Must determine rf the waste is restricted from land
disposal under 40 CFR 263 et seq. by testing in
accordance with prescribed methods or use of
generator knowledge of waste
Generation ol RCRA characteristic hazardous
waste (and Is not 0001 non-wastewaters treated by
CMBST, RGRGS. or POLYM of Section 268 42
Table 1) for storage, treatment or disposal —
40 CFR 268 7
Must determine each EPA Hazardous Waste
Number (Waste Code) lo determine the appticabte
treatment standards under 40 CFR 266.40 eL seq.
applicable
40 CFR 268.9(a)
Appendw 0. Tables
B-13
Shuron ROD Amendment
-------
Tabte 13: ARARs {page 5 of 7]
Action
Reflulrefnents
Pre-reauisltfi
Citation
Temporary
storage of
hazardous waste
in containers
A generator may accumulate hazardous waste at the
facility provided (hat
« waste is placed in containers that comply with 40
CFR 265.171-173: and
40 CFR 262 34(a)
40 CFR 262.34(aM1Ki)
• Hie date upon which accumulation begins Is dearly
marked and visiWe for inspection on each container
AuLurnuiaiian or kuiv\ n-dzaruuub waste on sue &S
defined in 40 GFR 260 10 - applicable
40 CFR 262.34(aM2J
* container 15 marked with (he words "hazardous
waslB*|_pr
40 CFR 264 34(a)(3)
¦ container may be marked with other words that
identify the contents
Accumulation of 55 gal or less of RCRA hazardous
waste at or near any point of generation —
applicable
40 CFR262.34(cX1}
Use and
management of
hazardous waste
in corvtaumers
If container is no* in good condition (e g severe
a/sting. structural defects) or if it begins to leak,
must transfer waste into container in good condition.
Storage of RCRA hazardous waste in containers —
applicable
40 CFR 265 171
Use container made or lined with materials
compatible with waste to bo stored so that the ability
of the container a not impaired-
40 CFR 265.172
Keep containers closed during storage, except to
add/remove waste
40 CFR 265.173(a)
Open, handle and store containers in a manner that
will not cause containers to rupture or leak
40 CFR 265 173(b)
Appendix B, Tabtes
0-13
Shuron ROD Amendmenl
-------
Table 13: ARARs (page 6 of 7}
Action
Requirements
Prerequisite
Citation
Temporary
storage of sohO
waste
Shall be conducted in a manner la
a. Inhibit the harborage of flies, rodents. ar>d other
vectors;
b. Prevent conditions for transmission of diseases to
man or animals;
c. Prevent blowing debris and particulates so as not
to be injurious to human health and trie environment;
d Prevent water pollution and prevent the escape of
solid waste or leachate to waters of the State; and,
e. Minimize objectionable odors, dust, unsightliness.
and aesthetically objectionable conditions, and
prevent trie accumulation of materials in an untidy
and unsate manner so as to become a fire and
safety hazard
Generation of solid waste for temporary storage
prior to processing, disposal of that waste —
relevant and appropriate
SCDHEC R. 61-
iors(CKi)
j,.f:f 11)' 1/1 f- fi3I --'-ftf.ll-.'IH
l r~7T
Disposa' gf solid
waste
Shall ultimately dispose of solid waste at facilities
and/or sites permitted or registered by trie
Department for processing or disposal of that waste
stream
Generation of solid waste intended for off-site
disposal — relevant and appropriate
SCDHEC R. 61-
107,S(OK3)
Disposal of RCRA-
hazardous waste
in an off-site land-
based unit
May be land disposed if r! meets the requirements m
trie table Treatment Standards for Hazardous
Waste' at 40 CFR 265 40 before land disposal
Land disposal, as defined in 40 CFR 268 2. of
restricted RCRA waste — applicable
40 CFR 268.40(a)
Must be treated according to the alternative
treatment standards of 40 CFR 268.49(c) or
Must be treated according to trie UTSs [specified in
40 CFR 268,48 Table UTS] applicabte to the listed
and/or characteristic waste contaminating the soil
pries' to land disposal
Land disposal, as defined in 40 CFR 268 2. of
restricted hazardous soils — applicable
40 CFR 268.49(b)
Appendix B„ Tables
B-13
Shoron ROD Amendment
-------
Tabic 13: ARARs (page 7 of 7)
Action | Requirement's
Pro-requisite | Citation
Trapper
^ of Wastes
T ransportatwn of
hazardous waste
on-site
The generator manifesting requirements of 40 CFR
262 20262.32(b) do no! apply Generator or
transporter must comply with the requirements set
forth in 40 CFR 263.30 and 263.31 m 1he event of a
discharge of hazardous waste on a private or public
ngM-of-way
Transportation of hazardous wastes on a public or
private right-of-way wtlun or atong the border of
contiguous property under the control of the same
person, even if such contiguous property is divided
by a puOfoc or pnvate right-of-way applicable
40 CFR 262.20(0
Transportation of
hazardous waste
off-site
Must comply with the generator requirements of 40
CFR 262.2023 for manifesting. Sod. 262.30 for
packaging. Sect, 262-31 for labeling, Sect. 262.32
for marking. Sect 262 33 for placarding. Sect..
262.40. 262.41(a) for record keeping requirements.
and Sad. 262.12 to obtain EPA ID number.
Off-site transportation of RCRA-hazarttous waste —
applicable
40 CFR 262.10(h)
Must comply with the requirements of 40 CFR
26311263 31
Transportation o( hazardous waste within ihe United
Slates requiring a manifest - applicable
40 CFR 263.10(a)
A transporter who meets all applicable requirements
of 49 CFR 171179 and the requirements of 40 CFR
263 11 and 263 31 will be deemed an compliance
with 40 CFR 263.
Transportation of
hazardous
materials
Shalt be subject to and must comply with all
applicable provisions of the HMTA and DOT HMR at
49 CFR 171-160.
Any person who. under contract with a department
or agency of ihe federal government, transports "in
commerce." or causes to be transported or shipped,
a hazardous material — applicable
49 CFR 171 1(c)
Appendix B, Tables
B-13
Shuron ROD Amendment
-------
Table 14: Groundwater Alternative 1 Estimated Costs (No Action with minimal monitoring and FYRs)
Units
Quantity
Unit Price
Total
Annual
Cost
Operation
Time
(years)
Present
Worth
CAPITAL COST
1
Instaltaton of Monitoring welts
eacb
0
SO
WA
NA
SC
2
Total Capital Cost
St
3
OPERATION AND MAINTENANCE (O&M) COST
30
Bienntaf Groundwater Monitoring & Reporting
lump sum
30
324,000
$12,000
5269,000
4
Fwe-Year Reviews (FYR)
lump sum
6
535,000
S7.000
30
5157,000
5
Subtotal! 0AM Cost
$19, DOG
5428,000
6
Contractor Fee (10% of Q&M Cost)
542,600
7
Legal Fees., Licenses & Permits (5% of OSM Cost)
$21,300
8
Tolal O&M Cost
5489,900
9
TOTAL PRESENT WORTH COST (ROUNDED TO NEAREST THOUSAND)
$490,000
Motes
the tottowir-fl Notes «3tnBspc«ncJ Jo Bis tornranker
1 The 19§7 FS esiimjiiiKl captai costoJ SIl.TOOfw tnitaflafeon of 10 monitoring wirfs Hqwwww, a suffipont rsurnt* of #«Bs tutve been installed althe S4© *o lh»reteo! no
gijcjijionjlt fiwnfai costs IWD nr'boc-^ltKj
3 The 599 7 FS eSJMhiMed aetrB-ainiufli jrourvJwAtH; uidi^flmg la ceh.1 $36,000 pM yfett (*l S99T dofclrft! The 2DQ9 FS Afftendmanl rKSs-aBwJ a cpst cElirt.iiSB tit $24,000 per
tiwenl lor monrtonng For corurttwrt companioo ai BitemAiwes, $24,000 it uwd r tb«s revised eslnnate The Mrfsfrfimj frequerwy is reduced id btemidd (every hw yean)
tor toe No Action aBefnatwe a# « Gost-ssvwgi measure Thti would provide enough data to use *1 conducting tte FYR
* the 5987 FS eslwnaS«f FYfo (cafted modeing and reisorung in 5907 FS) to cost 566,000 each T>e average cost to eoodud a FYR in 2010 a $30,000 - $35,000
T>«ra*ora. S35.000 « used m ail oi>« revised cosi estimates
6 7 These item® *tm not e-j-tudod m ihc oogmjiJ FS. bul tnrv included m the MG9 FS Arrwndmimj tar Altomalfv* S Therotore. Burp1 were added to this ww4 osiimaie tor
conwutwicy domparaon
9 Pr«r;«!nt Wqtlh Goto were rairi ritrtmt fay an Ejccnt spreadshflflt tuncfton uwng 5% Bfloban ntfo and 7> damiri rabo ovw a 30 ytwr penwt The cwrjwtod valww tmw Ihw
rcundecs to me nearest thousand
Append® 0. Tabtes
B-14
StiurDrt ROD Amendment
-------
Table 15: Groundwater Alternative 2 Estimated Costs (MNA with FYRs)
I t . m,. W. — —¦ — — f — *1 — —
Ufrm UreSCripflOri
Units
Quantity
Unit
Price
Total
Annual
Cost
Operation
Time
(years)
Present
Worth
CAPITAL COST
1
Installation of Momtonng wells
each
a
SO
NA
NA
$£
2
Institutional Controls (IGs) on two parcels
each
2
$15,000
NA
NA
$3Q,DQ(
3
Total Capital Cost
530,CM
OPERATION AND MAINTENANCE COST
4
Semiannual Groundwater Monilcinng & Reporting
lump sum
60
$24,000
$48,000
30
$1 075,000
5
Five-Year Reviews (FYR)
lump sum
6
$35,000
S7.000
30
$157,000
6
Subtotal
$55,000
Si. 232.000
7
Contractor Foe (10% of O&M Cos!)
S123.200
8
Legal Fees, Licenses 4 Permits (5% of O&M Cost)
$61,600
9
Total O&M Cost
$1,416,800
10
TOTAL PRESENT WORTH COST {ROUNDED TO NEAREST THOUSAND)
51,447,000
Molw
Tho toitowirq Moles ooTsspoiKi to Bm Aon numtw
t
The 1997 FS estimated capital COM at S495.000 fey installation of 10 monitoring wefa devratenrg during excavation and (nstaBatnan of a «**• ops 9orvi'««»rtup>s.^x)itcy?tci'pdffc'bo*DC_cosl pclt Page ? ftml document irckidmt cosi vsfrnelK icr
Covenants Tim unit puce pnB5»nt»d ri Bus table is a H«m of Ptanmng. Owlpi Imptanwr^ataxi E«*totwn#tx and Temwnation Morfonnq and Reporting amr assumed in Shi
co*ts Of conducting FVRs
*
Tho 1997 FS estimate) semranmjal groundwater monitoring to nasi $36000 per year fit 1997 dollar*) The 2009 FS Amendment indicated a Ccat eslWHale of $40,000 pfr-
yam tor sornt-annual moinlorrfvg For CQfiSrSSiKtey COrnpaftSOfi of atlefnaSivea. 5X0.000 is used in Bis revised estimate
S
TNi 1997 FS estimated Frvfr Year Ftoviews la cost $66,000 The average cost id cordueJ u FYR u-. 2010 a 5% GOG • $35,000 Tnerelore. S3&.000 is itsed m all el tfsa
fSMwed cost estimate*
7,«
Theie items whi rtot incJuJed m
-------
Table 16: Groundwater Alternative13 Estimated Costs (P&T with FYRs)
Hem Description
Unils
Quantity
Unit Price
Total
Annual
Cost
Operation
Time
(years)
Present
Worth
1
CAPITAL, COST
2
Pump and Treat system
lump sum
1
5835,360
NA
NA
5835,3S<
3
Institutional Gonlrols (ICs) on two parcels
eadt
2
SI 5,000
NA
NA
530,00£
4
Subtotal Capital Cost
5865.3&C
5
Contractor Fee (10% of Item #2)
$83,538
6
Legal Fees. Licenses & Permits {5% of Hem S2J
r.r m
7
Engineering & Administrative (15% of Item #2)
S 125.307
8
Total Capital Cost
*1,115,99-
OPERATION AND MAINTENANCE COST
9
Pump and Treat system Q&M
lump sum
30
5159,120
5159.120
30
53.564,00C
to
Semiannual Groundwater Monitoring and Reporting
lump sum
60
524,000
548,000
30
51.075.00C
11
Five-Year Reviews (FYR)
lump sum
6
535,000
57,000
30
5157,000
12
Subtotal O&M Costs
5214,120
$4,796,000
13
Coniraetor Fee (10% of O&M Cost)
S479,600
14
Legal Fees. Licenses & Permits (5% of OS.M CpslJ
5239.800
15
Total O&M Costs
55,515,400
16
TOTAL PRESENT WORTH COST (ROUNDED TO NEAREST THOUSANO)
$6,631,000
Motes
The £**3ina» ASer-nalrrt »3 iiiclucSeo a range of coals mm the lew rac»3« correspordtng id monitored crural aBMiuatof- (MNA) and the high erd associated with tang.&wrv
fKH-T® arid treat Because MMA is Alternative «2, only the casts tor long-term pump and treat were used in etis revrwd Alternative #3 cast
!The toftwwog tfotas correspond to the item ^urn&w
1 The 199? FS cstiTvltod p^ol up toSM70,OOO Tot fnELTSabon pf IQmiyitti^rig wofls. d»WS»rtng dMnr^iinrjirat-.cin. evaluation of 9«M«.Jl»C*s.
nemetty, system infiptementaixjn and installation of a discharge outfniL"pip&-iwnll Tho davratorng activities wi«r* ccmpletod m) J003 and rwnwf^ "valuation was
ecmpfeled as wen A BulTtdent number of waits Have teeii iftfttaltel at the Site for mondCBitfg Thomfgro csnty additohisi capital co*3a sribcipafed are Tor
installation of the puff® and tnhat system.
' Tt« eovt cs;tmate tor tw Purr-p and Treat sytem was calculated by adding the costs o(the system jAis tMwse line from tt-® 1997 FS fines 5 and B from the
FS | and than conwwtwg this amount to 20SW dotes (muttiptyino 4^ 1 53j|
3 The cost estimate tor ICs arid then ccmvwljng tas amount to 200B deters *mutt*>tylng by t S3}.
Appendix B, Tables
B-16
Shuron ROD Amendmenl
-------
10
The 1997 FS estimated semi-annual groundwater monitoring to cost $36,000 per year (in 1997 dollars). The 2009 FS Amendment indicated a cost estimate of
$48,000 per year for semi-annual monitoring. For consistency comparison of alternatives, $48,000 is used in this revised estimate.
11
The 1997 FS estimated Five-Year Reviews to cost $66,000. The average cost to conduct a FYR in 2010 is $30,000 - $35,000. Therefore, $35,000 is used in all of
the revised cost estimates.
13, 14
These items were not included in the original FS, but were included in the 2009 FS Amendment for Alternative 6. Therefore, they were added to this revised
estimate for consistency comparison.
16
Present Worth Costs were calculated by an Excel spreadsheet function using 5% inflation rate and 7% discount rate over a 30 year period. The computed values
were then rounded to the nearest thousand.
Appendix B, Tables
B-16
Shuron ROD Amendment
-------
Table 17: Groundwater Alternative 4 Estimated Costs (P&T in source areas with FYRs)
Hem Description
Units
Quantity
Unit Price
Total
Annual
Cost
Operation
Time
tyeare)
Present
Worth
1
CAPITAL COST
2
Fill Debris Extraction System
lump sum
1
5260,100
NA
NA
5260,1 QC
3
Solids Lagoon Extraction System
lump sum
1
51.132.200
NA
NA
S1.132.20C
4
Ground water Treatment System
lump sum
1
5153,000
NA
NA
5153.00C
5
TrarvsrnissiorL'Dtsrtiarqe of Treated Water
lump sum
1
$70,380
NA
NA
5?0,36C
6
Institutional Controls (ICs) cm two parcels
each
Z
SIS,000
NA
NA
SM.OM
7
Cap:.i:a; Ccjs:s
S1.645.68C
8
Contractor Fee {10% of Capital Cost (minus ICs))
5161,568
9
Legal Fees. Licenses & Permits (5% of Capital Cost (minus (Cs))
560,7841
10
Engineering & Administrative (15% of Capital Cost {minus ICs))
5242,352
11
Total Capital Cost
52,130,38'
OPERATION AND MAINTENANCE COST
12
Pump and Treat system OA.M
lump sum
30
5138.465
5138,465
30
53.101.00C
13
Semiannual Groundwater Monitpnng and Reporting
lump sum
60
S24.0O0
548,000
30
51,075,0QC
14
Five-Year Reviews (FYR)
lump sum
6
535.000
57.000
30
$157,000
15
Subtotal OSM Costs
S 193.465
S4.333.000
16
Contractor Fee {10% of Q&M Cost)
5433,300
17
Legal Fees, Licenses & Pemrnts (5% of Q&M Cost)
5216,650
16
Total O&M Costs
54,982,950
19
TOTAL PRESENT WORTH COST (ROUNDED TO NEAREST THOUSAND)
S7,113t000
Notes
Tre fbflOMtQ Nats eorfGlpend fcb the i twn run®**
1
t he 1997 FS eafcmateeJ capital coal Of up 10 S1,506,000 Jcr msUAtaMn Of 10 monitoring wails, dewaHertog during Bjeavatior. system Bretoftientabofi Arid msta/Ubon
of a discharge iXjriali'pijse.'waii The dewAteraig .i«/vtlies wew eompietod in 2002 A suificxwn number od wefli have Been «*r4iari(M at the Site tor morwmwig
Therefore. it* only odditonat eyptnl costs anhcgial«i at« tor installation ol the pump and Icaal system
2-6
The cost estimate for me Purrv ana Treat sylem *es calculated by adding (he eosis of Uhe system plus iJscftarsie hne tnom the 1$07 FS (tines 4 6,] and 6 from ihe
FS) and then eonverfcng Hit* amount to 2009 datarg (muftpffiig by i S3}
6
TN cost estimate for ICs is tssed on data found at http •'www «pn gcrv.i*Mpe^u»^porcyii«,rpdfs,'b«iot cost pdf Pag# 7 of that document includes wsJ estimate? for
Otwrt The unil price present in tNs latin a a sym of Planning. De*gn lmplemi|irt.itcn Er,1pfanTWTt ard Ternwmtajn Mentoring *>d Ritportins arc
nasi*ne<} Hi ftw ccstj of conctiySmg FYRs
6-10
Than ifcffll were not rdiuded in the oogmal FS bul were mduded m the 2009 FS Amerdmpnt fof AJtefrsai/ve 6 Thertlbfn, they were added to this nmnsed estmUSe
for consistency companion
<2
"ft* aal estimate lor the Pt*r«> af*l Tieatsytom O&M ww crtcutatod b* adding the costs at the system j*is Oucharge »ne ham the 1997 FS tunes 4. 6, 7, and 8
from the FS) and Bwtn converting this amount to 2099 dollars
-------
13
The 1997 FS estimated semi-annual groundwater monitoring to cost $36,000 per year (in 1997 dollars). The 2009 FS Amendment indicated a cost estimate of
$48,000 per year for semi-annual monitoring. For consistency comparison of alternatives, $48,000 is used in this revised estimate.
14
The 1997 FS estimated Five-Year Reviews to cost $66,000. The average cost to conduct a FYR in 2010 is $30,000 - $35,000. Therefore, $35,000 is used in all of
the revised cost estimates.
16,
17
These items were not included in the original FS, but were included in the 2009 FS Amendment for Alternative 6. Therefore, they were added to this revised estimate
for consistency comparison.
19
Present Worth Costs were calculated by an Excel spreadsheet function using 5% inflation rate and 7% discount rate over a 30 year period. The computed values
were then rounded to the nearest thousand. The original Alternative #4 included a range of costs associated with the Solids Lagoon Extraction System. To simplify,
the high end values were used in this revised cost estimate. Plugging the low end values into the calculations results in a low cost of $5.2 million.
Appendix B, Tables
B-17
Shuron ROD Amendment
-------
Table 18: Groundwater Alternative 5 Estimated Costs (P&T at border with FYRs)
Item Description
Units
Quantity
Unit Price
Total
Annual
Cost
Operation
Time
(years)
Present
Worth
1
CAPITAL COST
2
Ftll/Debrts Penrnetsr Control Extraction System
lump sum
1
5244,800
NA
NA
5244, aoc
3
Lagoon Penmefer Control Exfracton System
lump sum
1
$673,200
NA
NA
S673.20C
4
Groundwater Treatment System
lump sum
t
$153,000
NA
NA
$153,0QC
5
Transmission/Discharge of Treated Water
lump sum
1
570,380
NA
NA
570,381:
S
Institutional Controls ( ICs) on two parcels
each
1
2
515,000
NA
NA
S30.00C
7
Subtotal Capital Costs
SU 71.38C
6
Contractor Fee (10% of Capital Cost (mtrtus ICs))
5114,138
9
Legal Fees, Licenses & Permits (5% of Capital Cost (minus ICs))
557,069
10
Engineering & Administrative {15% Of Capital Cost [minus ICs))
$171,207
11
Total Capital Cost
51.513,7M
OPERATION AND MAINTENANCE COST
12
Pump arid Treat system O&M
lump sum
30
$156,060
$156,060
30
$3,495,OOC
13
Semiannual Groundwater Monitoring and Reporting
lump sum
60
524,000
548,000
30
51.075.00C
14
Five-Year Reviews (FYR)
lump sum
6
535,000
57.000
30
$157,000
15
Subtotal G£M Costs
5211,060
$4,727,000
16
Contractor Fee (10% of OSM Cost)
$472,700
17
Legal Fees. Ucenses & Permits (5% of O&M Cost)
$236,350
16
Tom I Q&M Costs
55,436.050
19
TOTAL PRESENT WORTH COST (ROUNDED TO NEAREST THOUSAND)
$6,950,000
The (oiowinQ Notes correspond to the Hem number
1
The 1&9/ FS estimated capita* cost erf up to S1.195.OCO for instiMlitlwn ol 10 mornteinng woii dmaMnp Sunno siMvalion. system impterronlateGn ¦ml irstattaton
of a w? net induflad n Btb orqir.al FS but wm wteJudSiJ tfl the 2009 FS Amendment tar Ancfnalive 6 Thorotoro tfiBy were added to tttli missed «Umale
for ransaliftey comparison
1?
The can ssbmato Dew (hePump and Treat »ytemO&M was calculated by addrg 9m easts at Ito sys»«n plus disflharpa tine tram Bw 199? FS (kiwi. 6, 7, and B
from Ihe FS) and then converting this amount to 2009 dollars [enutfcplying by 1 531
Appendix B. Tables
B-18
Stiuron ROD Amendment
-------
13
The 1997 FS estimated semi-annual groundwater monitoring to cost $36,000 per year (in 1997 dollars). The 2009 FS Amendment indicated a cost estimate of
$48,000 per year for semi-annual monitoring. For consistency comparison of alternatives, $48,000 is used in this revised estimate.
14
The 1997 FS estimated Five-Year Reviews to cost $66,000. The average cost to conduct a FYR in 2010 is $30,000 - $35,000. Therefore, $35,000 is used in all of
the revised cost estimates.
16,
17
These items were not included in the original FS, but were included in the 2009 FS Amendment for Alternative 6. Therefore, they were added to this revised estimate
for consistency comparison.
19
Present Worth Costs were calculated by an Excel spreadsheet function using 5% inflation rate and 7% discount rate over a 30 year period. The computed values
were then rounded to the nearest thousand.
Appendix B, Tables
B-18
Shuron ROD Amendment
-------
Table 19: Groundwater Alternative 6 Estimated Costs (EAB)
Item Description
Units
Quantity
Unit Price
Total
Annual
Cost
Operation
Time
(years)
Present
Worth
CAPITAL COST
IN SITU TREATMENT SYSTEM (EAB)
1
Unit A'B Injection Wefts, 25-foot Depth {20-fl x 25-ft spacing)
each
188
$750
NA
NA
5141,000
2
Unit C Injection Wells. 40-fool depth (20-ft x 25-ft spacing]
each
125
St.200
NA
NA
$150,000
3
Injection System Infrastructure Construction
lump sum
1
550,000
NA
NA
$60,000
IUNIT MB ELECTRON DONOR INJECTION - 3 EVENTS
4
Injectwn Labor & Equipment. 1B-8 Injection Welts
event
3
$65,000
NA
NA
$195000
5
Fast Release Electron Donor - 2 events
pound
132 ftO"
$2
NA
NA
$265,600
6
Slow Release Electron Donor -1 eveni
pound
66.400
$4.25
NA
NA
5282,200
UNIT C ELECTRON DONOR INJECTION - 3 EVENTS
7
Injection Labor & Equipment 125 Injection Wells
event
3
$45,000
NA
NA
$135,000
&
Fast Release Electron Donor • 2 events
pound
109.560
$2
NA
NA
$219,120
S
Slow Release Electron Donor -1 evenl
pound
54.780
$4.25
NA
NA
$232,815
10
Verification Monitoring Well Installation
eadh
6
$2,500
NA
NA
S 15.000
Institutional Controls (iCs) on two parcels
each
2
$15,000
NA
NA
$30,000
11
Subtotal Capital Cost
51.715,735
12
Contractor Fee (10% of Capital Cost)
S16S.574
13
Legal Foes, Licenses & Permits (5% of Capital Cost)
$84,287
14
Engineering & Administrate (15% of Capital Cost)
$252,860
IS
TOTAL CAPITAL COST
$2,221,456
OPERATION AND MAINTENANCE COST
16
Semiannual Groundwater Monitoring & Reporting 1 lump sum
20 S24.000
$48,000
10
$431,000
17
Five-Year Reviews | lump sum
21 $35,000
$7,000
10
563,000
18
Subtotal Q&M Cost
$65,000
5494,000
19
Contractor Fee (10% of OS M Cost)
$49,400
20
Legal Fees, Licenses & Permits (5% of Q&M Cost)
$24,700
21
TOTAL Present Worth O&M Cost
$568,100
TOTAL PRESENT WORTH COST (ROUNDED TO NEAREST THOUSAND)
52,790,000
Motto.
IT* Mowing Not** eorrMpciftd to Ifin item nuitar
1 f Th* 2009 FS Arnnndmom r«jd a total o?»l Sgr ITiw «nm ni S140,625 Hcwwivor. mutttptyng the Quantity (186) By tho Out Pnoc
-------
17
The 2009 FS Amendment calculated a Present Worth Cost as $433,320 using a 5% inflation rate and a 7% discount rate. These same values were used in the Excel
spreadsheet function to calculate Present Worth and a slightly different value resulted. In order to consistently compare alternatives, the spreadsheet function value, rounded
to the nearest thousand, is presented in this table.
18
The 2009 FS Amendment estimated FYRs to cost $25,000. The average cost to conduct a FYR in 2010 is $30,000 - $35,000. Therefore, $35,000 is used in all of the revised
cost estimates.
23
Present Worth Costs were calculated by an Excel spreadsheet function using 5% inflation rate and 7% discount rate over a 10 year period. The computed values were then
rounded to the nearest thousand.
Appendix B, Tables
B-19
Shuron ROD Amendment
-------
Table 20: Summary of Groundwater Alternative's Evaluation
Rnm»dlal
All»rna»lva
Thmhokl Crif aria
Botancing Cntaria
MocKiy/nc
Criteria
Overall Prelect wsn of
Human Health and ttw»
Environment
Compilanefl
with ARAfig
Lono-Tflrm
OfMSttapnon
and
PttmnMCt
Reduction of
Mobility.
Tonicity or
Volwma
(WW)
Through
Trnatrrwril
Short-Torm
6ffcctiv«n»»*
Implamant*
abllilty
C0*t
ilApproxImvl*
Tot«4 Prt»frirt
Worth]
8lat»
Acc*ot»ne4
Oomrnuoity
AeevotBiwEc
1 No Ar.iar
Anemaliw«1dowrat
p»owd« any ncaasco
protection tahixnnr.
boattity the
itf i n m
nteoi
and Into*
ARARs. tKji
«**t not
AHAfe
~"
BraJ ri prsvKte
thu knwrci
towstoltong
or
boiLiTJItB they
Wy &o*ety or
«vtnch«*U4t.
unary d«*s»
l3
RGs if at all
\Mj\nr-. ran • -
at*) K "Wf
nxKlCV wxstf'r
moiety and
vott^rw
through nwture
process but
•wool
0Xp£Cte<3 lo be
•ff«ctiv»
thtaughouH »>•
errt.ro
prfkjnw
Nttmm» «i
pnaaaifw
inmm*
*ofusmaf&
imdetente
nfeacauwno
ca^trudvjn.
Ihowliy ii*>n
a wmoHng
-f ^ »•>"«
irrtroqu*oMy
i inmy rttK?
JW*»
Aitwnatu«£l
HMtlc
action return! n
wirap4wj.-a*Sd»
MmAJOWT
Wrinuerrtty
l#r«y athe»
roori
^90,000
No
?
¦ J
N *bt> iml
(MNA) aixj ICS
Aflwnairrft! tf2 provides
portal (xa««rcik*i of
human NwiHTi frtrougft
Cs and refaance on
natural dcgr*iahpn
proc»ses bulorty
rrenHno»(f pro«>«a
proteclrar to Iho
am-ironrrwnt thja to tf»
ruuuiaJ asieriujijon
occore st s4es wHh< such
iwjh VOC
#i #2. «4*ret
*5 Mufcj n«l
BG&cr-spac/e
andtocafcon-
apeorfic
AHAKp tnji
•WJuWflot
thrtJUghM* Ifus
%«m
Afcw-aevwirt
am} *7 pro.-h
the lowmi
*.¦* 0< feas-
or
r^rfermantM
boeaufro Ihey
retyadMyitt
wtwi <»« Uw
In ocfitav*
RGs. 1h» €rtf
[fc-tion roi(utf«d
Wffl t*
rtcr^ding IC« »rv9
s»-np*f^ tunc# a
Sl.447.«W
7
t
Append* a Tables
8-20
Shtron ROD Am»ndnw*l
-------
Rsmndiil
AJtWTIKtlVl
r. r. ....
OvtM»il Ptsrftcljon of
Human Health and Ut*
CtWOfHi
wiUt ARARs
Lp-ng-Tunn
and
Permansa
ipOM inc. '^inj!/'
impttimefftabon
ShwMetm
chaBargoS,
ISMtSto
pareculnrlY
wpsfcj&^s Qunrtg
njgjrdifg
coMifucuan.
eamlfuaiofi In or
pynx*nB
ngar wotUsnds
¦ijectidft, and
Lew pGrmoabMy
monnoftno
CODtiftOttS WtH
Eiicti of th«H
puraent
S6,631.000
7
9
^3flg
-------
Rsmcdri
Allanlfllil-UB
Thrmtftoia Cb
twrfa
Si.tenctag Criteria
j« , r iT1 -ii»^,r-i *
\tqcjiT| irrg "unr&na
Ow»ll Protaetnon of
Human M»aith and th»
Compliance
*de partus* prelection
to human health and tNt
wonn^r^ by
rarwng trpatififl
pOftlOflS &> BSC
car*#iT\trjtoii3
gfaundlwalar and
pwwnli^g jc«ii ® IPS
aquifer unH ftfis *r»
attained However
cortammants outsets of
Ifw cane nf arifusnca at
the ewaesicm sysjam
wpiitd rat bo treated
•1. 02. ** and
ts woukt rtm*
ftJKj teaatan
AHAft*. ClUt
0OUtC nQt
r-ieirt cr<
SEE ,n
(MemabveS *4
and *5 would
not prmtSo
tepg-term
•'tocivorfliH
ot
pa#manemee
bocuuw thfly
do not acitvaty
rarrxKMtfl th»
UltiTD
cantaminatad
groundwater
(Aal*
Howavw, I4NA
may ewrhjaiUy
achieve RGi
and a a
pwmnrwi
iohibor
Wletralrvtra IM
and <3 Mould
rmtuw lowctty.
mob^ty and
volume r the
anb-is of
In-,.truer! but
may not
rosuoB a tor
tfws entire
contamiruiAod
groundwater
pk*rm
Aawrjilivws Si
through #6
pose moderate
short-tarfn
Tiahs Id
WOi&are during
COnstrucftan
pejmjsno.
in^scitarv. and
mortrtotwig
Each of
alwnafrwM
#r«r ^IbdJMtwKt
ta lata
approximately
on* to tw
years BO
construct
AHamativttt #3
trough as pose
imp*emental»txi
ehaHenge»,
partaJarty
regafljfg
constructs in or
rscar nwfiandi
L ctw pwmeoGxIity
COrtMiOfis WJ|
present
aivgineeririg
StaaengH
t? 113 000
?
f
AppotKfa B Tnfcte*
B-20
Shuoo HOC Amendment
-------
Tftrmzhatd Criteria
Ottancittg Criteria
wocjryjngr u/iffona
Reduction of
Mobility,
Tonicity or
iaofl-TmJU
Votunw
Ce#t
Ovorall Protection of
Effscllvenoiii
[MOW)
(Approximate
Ro-modlal
Aiternatly*
Human Health and lha
Ccrmplunc#
with ARARa
and
Through
Trmikl-miiinit
Short *Tarm
Ejffpctivenee*
jrnplartwnrt-
abalilrv
Total Pro-Mint
W«thj
State
Community
AcccplJncc
Alternative* S4 and #5
Mmmsltbtm
Alternative* »4
Afts»C ElWT#*3
vdunw «i lh»
ratfw 6S
fMuticutarty
Boundary and
portions o< toe
at
areas of
workers dunng
«egaid'2 :
•iirovanting a«#is to tti#
fflNtdwniG^
do not actively
reduce it far
•"lecton and
Low jwmwia&fity
aquifer until RGs are
stwoftd
remcdials toe
to® pntro
mcnitanng
;ordrtKjna wi
uE^u-hm! HcrwevCf
ARARs
entire
Each Of Iheae
prewi-t
Cf»n!iMniniini» OilUidO Of
throughout the
contaminated
pound ¦•¦ A*
s«ornatrv*i
imgineering
HkWS.QOG
?
?
ton cone Of liltuefof Of
56m
groundwater
plume
are anticipated
ihattengea
11-e a
-------
R»HMdLBl
AJteruailife
¦ Ecihaitc^d
AriiMfOtHC
BtcwmeduIiGf
(EAB | wTi
Mciitomg atic
ThrtxhoM CrjtmU
Overall Protection ol
Human Hwiitti and the
Enviftxufunt
Mfffttftv* -ffi it: 1Ni
, IkMIM'-vtS I' .l' [VJU'-Sds
the Wobnt vswrt rf
-innieh 3fi cf Nirwm
r>»,4Wi .wbttv
amilOmMl, T»m "J
ampuarrt fry
conlprnirjiSid
jfouniJ^ulra ani
-icce-iu to tr»i?
aqU'W ir'U RCt; «n»
Jit j* <_J ! 'i. ar.ltgiA
ttijrfir Mian Mnnrwttvp
19 Dorii-.rw il it
d*».«ted to ach«o*e
R of
c-$ar vwltflrKH
SuDiui'-Aie
riBlerog«n&!fM
¦M , PH.
pontxtoiiililj )¦ /rury
•TsftkC effect^*
dispersion o(
¦UtMMi difficult
n sit areas
Com
(Approximate
Tottl Prewnl
WgirW
f?;r!W,ceo
ItodB^vno Crttc n_j
Stilt
A«»gj|jnc^
Yin
Commtmiiy
Acc+ptaum
Append* B. Tadifas
8-20
Shuron ROD Am*rH£nq*i|
-------
Table 21: Groundwater Clean-up Levefs
-smraw
1998 ROD
MCL as of
Amcfidrnenf
CONTAMINANTS OF
Qeans-up
August 2010
ARAR
CJean-up
CONCERN
Levels (ug.'L)
Change?
Levels fyg/L)
9i5'2-ethylhexyl phtbalate
6
6
No
*
1,2-Dichloraethan©
5
5
No
5
1,2-Dbchloroeiriene (Total}
70
70
No
70
ElFiyi benzene
700
700
No
700
Lead
IS
15
No
"
rretr0chlofoett>&ne
5
5
No
5
ToSuene
1.000
1,000
No
1,000
TruchloroeUhene
5
5
No
5
Vinyl Gfitoftde
2
2
No
2
Xylerws (Total)
10.000
10,000
No
10,000
Mates
" In JW5 ptrit-jilalo ana Iwsl *m njmcnr»el the gncwrwJwTtrr rnqMnnng plan bocawM
lhw
compWod Thoftftaf* lfi»w fw
txiing remOviK! ftwf! Btfr C
ApperwJw B, Tatries
B-21
Shuron ROD AmendtnerU
-------
APPENDIX C
PHOTOGRAPHS
-------
Photo #1 Shwon building and front parking lot in September 2005
Photo #2: View facing west al limit of excavation/restoration area In September 2005
Appendix C, Photographs
C-1
Shurofi ROD Amendment
-------
Appendix C, Photographs
C-2
Shufon ROD Amendment
-------
Appendix C, Photographs
03
Slwon ROD Amendment
-------
APPENDIX D
STATE CONCURRENCE LETTER
-------
D H E C
mm ¦
rfnTtTf RTTrTS
/'u-emri* Ik* ([P1»W« » iM'l'Wj, iMWri
September 30,2010
Franklin E, Hill, Director
Superfirod Division
US EPA, Region IV
Atlanta Federal Caller
61 Forsyth Street. SW
Atlanta, Georgia 30303
Re; Shuron, Inc.
EPA ID# SCDQ03357589
Barnwell County, South Carolina
Record of Decision Amendment and Amended Unilateral Administrative Order
Dear Mr. Hill:
The Department has reviewed and concurs with all parts of the Record of Decision
(ROD) Amendment data! September 2010 and Amended Unilateral Adimmstrativc
Drder (UAO) for the Shuran, Inc. Coniarnination Site located in Barnwell County. South
Carolina. In concurring with this ROD and UAO Amendment, the South Carolina
Department of Health and Environmental Control (SCDHEC) does not waive any right ot
authority it may have under tedcrul or state law. SCDHEC reserves any right or authority
it may liave to require corrective action in accordance with the South Carolina Pollution
Contrul Act, These rights include, but are not limited lo, the right to insure that all
necessary permits are obtained, all clean-up goals and remedial criteria are met, and to
take separate action in the event clean-up goals and remedial criteria are not met.
Nothing in the concurrence shall preclude SCDHEC from exercising any additional
administrative, legal and equitable remedies available to require additional response
actions in the event that; (1 Ka) previously unknown or undetected conditions arise at the
site or (b) SCDHEC receives information not previously available concerning the
premises upon which SCDHEC relied in concurring with the selected alternative, and (2)
the implementation of the remedial alternative selected in the ROD is no longer
protective of human health or the cnvironmenL
SCDHEC concurs with amending the Selected Remedy in the September 1W8 ROD for
Operable Unit 1 (OlJ-1> of the Shuran Site, Over the past several year*, new groundwater
data and additional information obtained during the remedial design and remedial action,
led to a re-evaluation of the remedy. It has been concluded that specific fundamental
changes arc needed to the original clean-up plan for the groundwater component of the
remedy.
SOUTII CAROLINA DEPART MJ..N 1 OFJhUALTl' A NJJ^EN V 1 RON' MEN 1 A I. t ON I ROL
-------
The major modified remedial components of the ROD Amendment for the Shuron Site
are as.follows:
D Use of Enhanced Anaerobic BiuremediciHon (EAB.) EAJB generally occurs through the
addition of fermentable carbon compounds that serve as electron donors for subsurface
bacteria that use the chloioethenes as electron acceptors. The hydrogen produced during
fermentation reactions is the prima 17 election donor for dechlorinating bacteria and
drives £AB. This electron transfer process provides the bacteria with energy for
population growth and metabolic activity to reduce the concentrations of
tctrachlbroethenc (PCE) and trichloroethene (TCE) to levels that would be protective of
Turkey (heck and achieve the clean-up goals to be protective of human health and the
environment.
0 Institutional controls for land use and groundwater use restrictions.
° Implementation and maintenance of a-groundwater monitoring system.
If you should have any questions regarding the Department's concurrence with the ROD
or CTAO Amendment, please contact Chuck Williams at (803) 896-4162.
CC: Stan Clark, BLWM
Ken Taylor, BLWM
Van Keisler, BLWM
EQC Region 5
File #50926
Sincerely,
Daphne G. Neel, Bureau Chie:f
Bureau of Land and Waste Management
-------
Page 1 of2
Re: draft SOW attached... Re: Shuron Superfund Site - Amended UAO and AOC attached
Charles J Williams
to:
Samantha Urquhart-Foster
09/27/2010 08:39 AM
Show Details
Samantha,
We will send an official letter with the Final versions once tliey are sent out, if that's ok.
Thanks,
Chuck
»> Or) 9/21/2010 at 11:17 AM, wrote:
Thanks Chuck! Could you send me a "concurrence letter", (if you haven't already)"?
Samantha Urquhart-Foster
Remedial Project Manager / Region 4 Five-Year Review Coordinator
US EPA , Region 4
61 Forsyth Street, SW
Atlanta, GA 30303-8960
Phone: (404J 562-8760
Cell: (404) 909-0839
"Charles J. Williams" wrote:
To:
From: "Charles J. Williams"
Date: 09/20/2010 07:50AM
Subject: draft SOW attached... Re: Shuron Superfund Site - Amended UAOand AOC attached
Samantha,
Greg and I are good with the Draft ROD, UAO and SOW.
Thanks,
Chuck
»> On 9/13/2010 at 11:58 AM, wrote:
Hello all. Attached is the draft Amended SOW that goes with the draft Amended UAO that Gwen sent earlier today.
Samantha Urquhart-Foster
Remedial Project Manager / Region 4 Five-Year Review Coordinator
US EPA , Region 4
61 Forsyth Street, SW
Atlanta, GA 30303-8960
Phone: (404)562-8760
Cell: (404) 909-0839
-—Gwen Bivins/R4/USEPA/US wrote: -----
filc://C:\Documcnts and Settings\surquhar\Local Settings\Temp\notcsC98l2B\~web8575.h... 9/28/2010
-------
Page 2 of 2
To: JSchiff@textron.com, williacj@dhec.sc.gov, CASSIDGA@dhec.sc.gov
From: Gvven Bivins/R4/USEPA/US
Date: 09/13/2010 07:25AM
Cc: Felicia Jackson/R4/USEPA/US@EPA, Samantha Urquhart-Foster/R4/USEPA/US@EPA
Subject: Shuron Superfimd Site - Amended UAO and AOC attached
(See attached file: Shuron Draft uao amend april 122010abf.doc)
Hello, gentlemen:
Please find attached the Amended UAO for the above-referenced site which will be issued as soon as the Amended
ROD is final. Please let me know if you have any significant comments to the attached by COB September 17. I will
be sending you the draft Administrative Settlement for this matter after 1 receive final comments from my program,
NLT next week. Mr. Schiff, would you please advise which form of financial assurance Textron plans to use for the
Administraive Order? Thanks in advance!
Gwendolen Bivins
Attorney-Adviser
U.S. EPA Region 4
61 Forsyth Street
Atlanta, GA 30303
(404) 562-9675 or (404) 329-7159
bivins.gwen@epa.gov
CONFIDENTIAL: For federal recipients: This transmission may contain deliberative, attorney-client, attorney work
product or otherwise privileged material. Do not release without appropriate review. For all recipients: If this
message was sent to you in error, delete this message from your machine and all storage media whether electronic or
hard copy.
fi!e://C:\Documents and Settings\surquhar\Local Settings\Temp\notesC9812B\~web8575.h.
9/28/2010
-------
APPENDIX E
WRITTEN PUBLIC COMMENTS
-------
SEND US YOUR COMMENTS
Your input on the Proposed Plan for the Record of Decision Amendment for the Shuron Superfund Site is
important to EPA. Comments provided by the public are valuable in helping EPA select the clean-up remedy
for a Site. You may use the space below to write your comments, you may submit comments via e-mail, or
provide oral comments during the Public Meeting (see page 1 for time and location). Comments must be
postmarked by September 20, 2010. If you have any questions about the comment period, contact the
Remedial Project Manager listed below. Written comments should be submitted to:
Samantha Urquhart-Foster
Remedial Project Manager
USEPA- Superfund Division
61 Forsyth Street, SW
Atlanta, GA 30303-8960
Phone: (404) 562-8760
Email: URQUHART-FCSTER.SAMANTHA@EPA.GOV
Comments: Thp f irx i s Qye^nePo\ I cx fgoi
hO.S. rnnr> p. \A A 0 \ W, \ e p. r- Yh< c.
The r-c r\ Plunt.Af f i rrv s* +U*. Q
J I I ¦ 1 . >. f I wi I—~ i ^ i - II I i r i
1 . J
KVU, . ,, /-v .
c ir t)nr\ /Xr\A (Jr~i
k)^/V7q k> n jkc/, T h ^ ^ r> 9r r rlr.n^-r
r r* r\cL ^ c /Vy?<3 Jn ^ r,
-Lkuf. f> mc)la/e*r> _
Comments Submitted by (name H/Jlr
Address:, \ifOb fAiriVgw
City, State, Zip code:
PROPOSED PLAN FACT SHEET, Shuron Site: August 16, 2010 Page 27
-------
0ft'0t>2010 04:06 PM
Hello Sharon,
Thank you for your call and questions about the safety of your drinking water. The annual
Water Quality Report for Barnwell, SC, can be found at the following website:
http^/www.citYOfbarnwell.com/Departments/PublicWorks/WaterSewer.aspx
I did a little more research. The water supply well that is located closest to the 5huron Site
obtains water from a depth of 180 to 295 feet below ground and is located on the west side of
Clinton Street, approximately 175 feet west of the Shuron main building. At the Shuron Site,
the contaminated groundwater is in the first 60 feet below ground. There is a deep monitoring
well, located on the east side of Clinton Street that was last sampled in March 2010 and did not
detect any volatile organic compounds. Groundwater at the Site does not flow towards the
water supply well, but rather flows away from it. There are several monitoring wells between
the known contaminated groundwater area and Clinton Street which are not contaminated.
Therefore, we have no reason to suspect that the Barnwell drinking water supply system is
contaminated by the Shuron Site.
Because a picture is better than a thousand words... I edrted the figure that you received in the
mail to show the approximate location of the Barnwell water supply well, locations of a few of
the clean monitoring wells that are located between the Barnwell weft and the contaminated
groundwater, and an arrow that shows the direction of groundwater flow. See attached.
EV-
Shurtm
Hope this helps,
Samantha Urquhart-Foster
Remedial Project Manager / Region 4
Superfund Division
US Environmental Protection Agency,
61 Forsyth St, SW
Atlanta, GA 30303 3960
Office: 404 S62-8760
Mobile: 404-909-0839
e-mail: URQUHAKT-FOSTER.SAMANTHA£> EPA.GOV
Five-Year Review Coordinator
Region 4
-------
FIGURE 1 - EXTENT OF GROUNDWATER ABOVE REMEDIAL GOALS
Monitoring well
•W IMHI irf ft
*?*! ,*??*** Extent ot Groundwater
M^issrssirjssr *»« ««»•
. . wiwfiplooiN « &vim4 to * rwwd*rth _ _ ?ufor ^
&r fcfuAvdkaal dhoncat . South Cw&tl
-------
CDM
Memorandum
To:
Samantha Urquhart-Foster, EPA
From:
Andrew Romanek, CDM
Date:
September 22, 2010
Subject:
CDM and Textron Comments on Draft Amended Record of Decision
Shuron Site - Barnwell, South Carolina
Camp Dresser & McKee Inc. (CDM) and Textron Inc. have reviewed the draft Amended
Record of Decision e-mailed to our attention on September 8, 2010. In addition to the minor
text changes noted in the attached file, we offer the following comments for your
consideration:
• The wording related to institutional controls is inconsistent in the document. In some
instances, the text correctly indicates that restrictive covenants have already been
placed on the Shuron property. However, in other instances, such as the description of
alternatives, the text seems to indicate that institutional controls have yet to be
implemented.
• The requirement for a restrictive covenant on the offsite property seems unwarranted
for the following reasons:
o The portion of the offsite property with compounds in groundwater above
remedial goals is located within wetlands. This part of the property is unused
and undevelopable. Installation of a permanent supply well in this area is not
feasible without significant access improvements, such as building a road.
During the offsite investigation, CDM was unable to install a monitoring well
in this area using specialized drilling equipment for swampy conditions.
o Even if a supply well were to be installed in the offsite area, it would be done
so below the confining layer (Unit D) based on the limited production available
from the shallow aquifer. Additionally, all wells drilled in South Carolina
require approval from the South Carolina Department of Environmental
Control (SCDHEC) prior to installation. SCDHEC would be unlikely to
approve installation of a supply well in the shallow aquifer of the offsite
property.
CDM and Textron Comments on Draft Amended ROD - 9-22-10.docx
-------
Ms. Samaritha Urquhart-Foster
September 22, 2010
Page 2
o Only a small portion of the offsite property has compounds in groundwater
above remedial goals, and these compounds appear limited to Upper Unit C. A
long-term goal of groundwater remedial action is to eliminate compounds in
offsite groundwater above remedial goals.
o Based on prior experience with similar situations, working on a restrictive
covenant with an offsite property owner can be a difficult process. It may be
prudent to first evaluate whether groundwater remedial action is reducing
offsite migration of contaminants. If not, then the need for an offsite property
restrictive covenant could be revisited.
If you have any questions regarding these comments, please let us know.
cc: Jamie Schiff, Textron
Mike Colvin, Fishbeck, Thompson, Carr & Huber
Gwen Bivins, EPA
File: 1727-75943
CDM and Textron Comments on Draft Amended ROD - 9-22-10.docx
-------
APPENDIX F
POWER POINT SLIDES FROM
PUBLIC MEETING
AUGUST 30, 2010
-------
Shuron Inc. Site
Proposed Plan Public Meeting
August 30, 2010
Samantha Urquhart-Foster
-------
Averts Si
Canton
RVdi*t&$2L
©2D06 Google - Imagery*
be, GeoEye, Map data
-------
-------
¦ 1994-1998: RI/FS
¦ 1996: Proposed/Finalized on NPL
¦ 1998: ROD
¦ 1999: UAO to Textron, Inc.
¦ 1999-2001: Remedial Design
¦ 2001-2002: Soil Remedial Action
¦ 2006: First FYR
¦ 2006-2008: Groundwater Treatability
Study
-------
Soil/Sediment Remedial Action
r v $
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- ' '
June 2001 - July 2002
Main contaminants:
metals and volatile
organic compounds
60,000 tons of soil &
sediment removed
Little contamination
remains at depth in two
locations & a wetland
Locked fences
-------
ROD: GW Remedy Part 1
¦ Temporary groundwater recovery and
treatment system for dewatering
purposes during source removal and
for an additional four to six months
afterwards
-------
ROD: GW Remedy Part 2
¦ Data collection / evaluation
¦ Active groundwater treatment options:
o Pump and treat
o Air sparging
o Recirculation wells
¦ Monitored Natural Attenuation (MNA)
may be applied to some portions of the
plume (if determined applicable)
-------
Implementation of Part 1
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After soil removal, 4 sumps
were installed in the areas of
deep soil excavation where
VOCs were at high
concentrations.
The sumps were only able to
pump less than 1/10"1 of a
gallon per minute.
Therefore, it was determined
that the groundwater capture
zone was too small to be
effective and that continued
sump operation would not
significantly reduce the VOC
mass.
-------
Other Alternatives Evaluated
¦ Based on this conclusion, potential
groundwater alternatives were
reevaluated, including alternatives not
evaluated by the Feasibility Study.
These alternatives included
o barrier walls
o in situ chemical oxidation
o phytoremediation
c monitored natural attenuation
o in situ bioremediation
-------
Barrier Walls
treated
Groundwater
¦ Discussed in the FS but
were not chosen as a
potential remedial
alternative.
¦ Would have to be installed
50-60 feet below ground
surface in most areas.
¦ Cost would be much
higher than other
alternatives.
¦ Would require destruction
of wetlands.
-------
In situ Chemical Oxidation
Injecting permanganate
solution into groundwater
that reacts with VOCs
high natural organic
content at the Site would
require very high amounts
of oxidant for effective
destruction of VOCs
-------
Phytoremediation
Trees drink the groundwater,
removing the contaminants
Site wetlands include many
willow trees, which have been
shown to reduce VOC
concentrations
Would help with shallow
contamination
But wouldn't affect deep
contamination
-------
MNA Evaluation
¦ Natural processes:
o Biodegradation
o Sorption
o Volatilization
o Transformation
o Dilution
¦ Data shows natural attenuation
is occurring at Site.
¦ prompted Enhanced Anaerobic
Bioremediation Pilot Study
-------
In situ bioremediation
¦ Enhanced Anaerobic Bioremediation
(EAB) Pilot Study
o Phase 1
o Phase 2
-------
EA
¦
EAB Pilot Study: Phase 1
s
k
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*¦ ANVl -Jr
w ' - .¦* -
May 2006 - April 2007
Injected whey into 30
wells in an 100 feet by
200 feet area
Groundwater monitoring
o Before
o 2 weeks after
o 1 month
o 3 months
o 5 months
o 8 months
-------
Phase 1 Results
PCE/TCE decreased in
all 5 wells used in study
Ethene/ethane increased
in 4 of the 5 wells
Naturally occurring
dechlorinating bacteria,
was present in all wells
Recommended Phase 2
-------
EAB Study: Phase 2
¦ Reinjected whey
¦ Evaluated effects of pH adjustment
¦ Added dechlorinating bacteria in areas
where full dechlorination was not
occurring
-------
I Phase 2 Results J
¦ Full dechlorination was achieved in parts of the
pilot cell
¦ pH drop after whey injection is likely causing
some resistance to dechlorination
¦ injection rates reduced during Phase II
¦ VOC concentration rebound may be occurring
¦ DHC bacteria were not present in some areas
but could be transferred through groundwater
recirculation
-------
Pilot Study Recommendation
¦ Of all of the alternatives mentioned in
prior slides (pump and treat, in situ
chemical oxidation, barrier walls,
phytoremediation, MNA), EPA and
SCDHEC believe that EAB offers the
most promising outcome, and
therefore recommends...
¦ Implement EAB Site-wide
-------
Progress
CONTAMINANTS OF CONCERN IN
GROUNDWATER
1,2-Dichloroethane
1,2-Dichloroethene (Total)
Ethyl benzene
Tetrachloroethene (PCE)
Toluene
Trichloroethene (TCE)
Vinyl chloride
Xylenes (Total)
1998 ROD
Remedial
Goals*
(MQ/L )"
1998 ROD
Maximum
Concentra-
tion (pg/L)
2010
Maximum
Concentra-
tion (|jg/L)
5
2,600
<5
70
47,000
38,000
700
20,000
2,300
52,000
930
1,000
2,400
<5
5
61,000
mT J 4
94,000
2
3,700
350
10,000
93,000
15,000
• The 1990 ROD RWWjial Gnats ate -Mill valid and am kteinticnl to 2010 Fotioral EWinkmg W.H* Sluradards
** iuo L = nrcrograms. p*r liter
-------
Breakdown Process
PCE „
52000 -> 930
TCE ®
61,000-> 94.000
Cis-1,2-DCE
47.000 -> 38.000
Vinyl chloride
3,700 350
-------
Feasibility Study Amendment
March 2009, CDM submitted a
Feasibility Study Amendment
Described EAB and compared
against original alternatives from
the 1998 ROD
Cost estimate of EAB was $2.8
million. Original alternatives
updated cost ranged $2.1 - $7.7
million
-------
]
Revised alternatives:
o No Action
o MNA
o Pump& Treat
o P&T in source area only
o P&T at border only
o EAB with MNA
-------
Revised Alternatives (1)
¦ No Action
o Sample every 2 years
o Five-Year Reviews
o Property use restrictions on deeds
o Cost: $490,000
-------
Revised Alternatives (2)
¦ MNA
o Sampling every 6 months
o Five-Year Reviews
c Property use restrictions on deeds
o Cost: $1.5 million
-------
Revised Alternatives (3-5)
¦ Pump and Treat
o Install and operate extraction wells and
treatment system
o Sample every six months
o Five-Year Reviews
o Property use restrictions on deeds
o Cost:
¦ $6.6 million - $7.1 million
-------
[Revised Alternatives (6)
¦ Enhanced Anaerobic Bioremediation
o Install injection wells 25 feet apart
o Perform 3 separate injection events
o Sample every six months
o Five-Year Reviews
o Property use restrictions on deeds
o Cost: 2.8 million
-------
Next steps
¦ After considering public comments,
EPA will issue a Record of Decision
Amendment
¦ Remedial Design will be completed
¦ Groundwater treatment will begin after
Remedial Design is approved
-------
Public comments
¦ EPA and SCDHEC believe EAB is best
treatment option for the Shuron Site
¦ We'd like to hear from you
¦ EPA will consider any comments that are
submitted by September 20, 2010
-------
Questions or comments?
-------
APPENDIX G
PUBLIC MEETING TRANSCRIPT
AUGUST 30, 2010
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0001
1
2
Public Meeting Regarding Shuron Inc. Site
3
Date of Meeting: August 30. 2010, 6:30 p.m.
4
Location: Barnwell County Library, Barnwell, SC
5
6
7
8
9 THE WITHIN PUBLIC MEETING WAS TAKEN BEFORE
SUESAN L. RICHARDSON, A NOTARY PUBLIC IN AND FOR THE STATE
10 OF SOUTH CAROLINA, COMMENCING AT THE HOUR OF 6:30 P.M.,
AUGUST 30. 2010, AT THE BARNWELL COUNTY LIBRARY, 617 HAGOOD
11 AVENUE, BARNWELL, SOUTH CAROLINA.
12
13
14
15
REPORTED BY
16 SUESAN L. RICHARDSON
17
18
19
20
21
22
23
24
25
0002
1 APPEARANCES
2 PRESENTERS:
J. Kyle Bryant, Environmental Specialist
3 Office of Superfund Public Affairs and Outreach
Environmental Protection Agency
4 61 Forsyth Street, SW
11th Floor
5 Atlanta, Georgia 30303
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6 Samantha Urquhart-Foster
Remedial Project Manager
7 Superfund Remedial & Site Evaluation Branch
Environmental Protection Agency
8 61 Forsyth Street, SW
11th Floor
9 Atlanta, Georgia 30303
10 ALSO PRESENT:
Mr. Michael Meyer
11 Ms. Jennifer Hughes
Mr. Jeff Weeber
12 Mr. Benjamin Duncan
Ms. Susan C. Delk
13 Mr. Greg Cassidy
Mr. V. Keisler
14 Mr. William Gouthro
Mr. Chuck Williams
15
INDEX
16
OPENING STATEMENT BY MR. BRYANT 3
17 PRESENTATION BY MS. URQUHART-FOSTER 3
OPEN FLOOR FOR QUESTIONS AND COMMENTS 19
18 CLOSING STATEMENT BY MR. BRYANT 24
CERTIFICATE 30
19
20 EXHIBITS
21 NO EXHIBITS WERE MARKED FOR THIS HEARING.
oo
*DIGITALLY RECORDED AUDIO RETAINED FOR TWELVE (12) MONTHS
23 FROM DATE OF CERTIFICATION.
24
25
0003
1 OPENING STATEMENT BY MR. BRYANT
2 First of all, good evening to everyone. My name
3 is Kyle Bryant and I am the Environmental
4 Scientist/Community Involvement Coordinator assigned to
5 the Shuron Inc. Site, and I'd like to welcome you to
6 this evening's meeting to discuss the amended proposed
7 plan.
8 First, a little housekeeping rules for those who
9 aren't familiar with this facility: the restrooms are
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10 just outside of the — these doors to the left and we
11 have bottled water and some mints and two chocolates in
12 the back just for your pleasure.
13 But, anyway, I'd like to introduce at this time
14 Samantha Urquhart-Foster who is the Remedial Project
15 Manager at this site.
16 And, just rules of engagement, you can, I guess,
17 ask questions as the presentation is going forward, but
18 there is going to be ample time for your specific
19 questions at the end of the presentation, and so, we'll
20 proceed. Samantha?
21 PRESENTATION BY MS. URQUHART-FOSTER
22 All right, thanks for coming tonight. Let my
23 computer unlocked again. As Kyle said, I'm Samantha
24 Urquhart-Foster; I'm the Remedial Project for the
25 Shuron Site. I've been involved with the site probably
0004
1 about five years now. There was a previous Remedial
2 Project Manager involved with before and — before
3 then. So, if you've got questions going way back in
4 time, I may not be able to -- to answer it, but I'll
5 definitely take it back and find the answer for you.
6 And tonight we're here to talk about the amended
7 proposed plan. The Ken — oh, sorry — the Shuron Site
8 is located on Clinton Street. It may be hard to see.
9 Kyle, can you adjust the lights.
10 MR. BRYANT: Sure. I'll just turn them off
11 there.
12 MS. URQUHART-FOSTER: Uh-huh (affirmative).
13 MR. BRYANT: Is that better?
14 MS. URQUHART-FOSTER: Uh-huh (affirmative).
15 PRESENTATION BY MS. URQUHART-FOSTER CONTINUES
16 All right, the facility itself sits right here
17 (indicates), the old Shuron building; it's right off
18 Clinton Street, which you can see it's not too far from
19 Jackson. The Shuron, when they were in operation, they
20 made eye glasses for — lenses for eye glasses. And
21 they used different chemicals in the process. They
22 used some metals for polishing and some volatile
23 organic compounds for cleaning them. They went out of
24 business, I believe, in 1992 and EPA got involved and -
25 - and evaluated the site.
0005
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1 From 1994 to 1998 the Remedial Investigation and
2 Feasibility Study was conducted and that's when they
3 went out and collected hundreds of samples of soil,
4 ground water, surface water and sediment. Found out
5 where the contamination was located, what the
6 concentrations were and then they developed — went
7 through a feasibility study to come up with looking at
8 different treatment options for it.
9 In 1996 it was proposed to the National Priorities
10 List, which is a - making it eligible to be a
11 Superfund site.
12 In 1998 EPA wrote the Record of Decision, which is
13 basically taking all the information for all the
14 sampling events and the feasibility study and
15 determined what the final cleanup — or what the
16 cleanup action would be for the soil, sediment, gravel.
17 The next year EPA issued what's called a
18 Unilateral Administrative Order to Textron. Textron's
19 a parent company for the Shuron Site and they were --
20 they've been involved since the beginning of time with
21 this project. They've done — they've done the work
22 involved with it. It — this is just kind of a — a
23 binding agreement, which — between EPA and Shuron, or
24 sorry, Textron, for them to do the work.
25 In 1999 to 2001 they did the Remedial Design for
0006
1 the cleanup plan. And the cleanup plan then was to
2 excavate all of the contaminated soil that was on site
3 and the sediment and take it off site for disposal.
4 And, the groundwater remedy at that time was to do
5 groundwater extraction while they were digging out the
6 soil, do four to six months of pump and treat and
7 evaluate it. And then after that they were going to
8 determine what would be the best treatment method for
9 groundwater. And, I'll go into that a little more in
10 the future slides.
11 The Soil Remedial Action began in -- in middle of
12 2001 and it took about a year to complete.
13 And, then in 2006 the first five-year review was
14 done. For Superfund sites where any contamination is
15 left on the site after the cleanup has been done, if
16 there's any contamination left on the site, they're
17 required to do what's called a five-year review or EPA
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18 is required to do a five-year review. So, every five
19 years, we relook at the site; make sure that the remedy
20 is still protective of human health and the
21 environment. So the first five-year review was done
22 five years after the start of the remedial action. The
23 next five-year review is going to be due next year, so
24 we'll be starting that process soon.
25 From 2006 to 2008 they did a Groundwater
0007
1 Treatability Study.
2 The Soil and Sediment Remedial Action, like I
3 said, was from middle of 2001 to 2002. The main
4 contaminants at the site are metals and volatile
5 organic compounds. They removed approximately sixty
6 thousand tons of contaminated soil and sediment.
7 There's a little bit of contamination that was left
8 behind when they were excavating some of the areas.
9 They dug down as far as they could go, three — three
10 feet below the groundwater table and still sampling
11 showed there were still some limited concentrations at
12 - at - at a good depth. But it was to the point
13 where the soil was so soft they couldn't — they
14 weren't able to — to get that out. So, EPA in South
15 Carolina agreed to just leave that little bit of
16 remaining contamination there and — and then they
17 backfilled it. They brought in clean dirt and filled
18 in the holes that they had excavated. The site's
19 surrounded by a fence with locked gates, so, you know,
20 you'd have to cut the fence to get inside it.
21 The Groundwater Remedy in the — in the original
22 Record of Decision was temporary groundwater recovery
23 while they were doing the excavation. And then try —
24 try pumping it and treating it for a period of four to
25 six months and to evaluate how that was going. And
0008
1 also to look at Monitor Natural Attenuation to see if
2 that would be a feasible treatment method.
3 After the soil removal, they installed four sumps,
4 which they — they used to pump water out of. They
5 were only able to pump less than a — a tenth of a
6 gallon per minute, which is very slow. So, they
7 realized after doing that for three or four months that
8 — that maybe pump and treat isn't - isn't the best
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9 option for the site.
10 After they did that realized pump and treat wasn't
11 the best option for the site, they looked at a couple
12 different alternatives. Barrier walls, in situ
13 chemical oxidation, phytoremediation. monitored natural
14 attenuation and in situ bioremediation.
15 Barrier walls were discussed in the feasibility
16 study, but weren't chosen as a — as a potential
17 remedial option, because the depth of the groundwater
18 is — the contamination is down to sixty feet deep, so
19 they would have to dig a trench down sixty feet deep,
20 quite — quite a long ways and install a barrier wall.
21 It'd be very expensive and in addition it would destroy
22 some of the wetlands that were on site.
23 They also looked at in situ chemical oxidation.
24 which is injecting a permanganate solution or some
25 other oxidant into the groundwater, which will react
0009
1 with volatile — the volatile organic compounds and
2 break them down. But there's high natural organic
3 contaminant — or content in the site already, which
4 would require a high volume of — of solution to be
5 injected into the groundwater, so, that didn't seem
6 like a very viable option either.
7 Another thing they looked at was phytoremediation,
8 which is using trees, planting trees or using existing
9 trees at the site. You know, trees have deeps roots
10 and they soak — soak up water from the ground. And,
11 that would be helpful with the shallow groundwater
12 contamination, but the contamination at this site goes
13 down to, like I said, sixty feet deep, and so, using
14 phytoremediation or trees to soak up the contaminants
15 at depth, that - that wouldn't work.
16 The next thing looked at was monitor natural
17 attenuation. Natural attenuation is — it — it
18 includes breaking down of the contaminants through
19 natural processes, such as biodegradation, or sorption
20 in the soil, volatilization, transformation or
21 dilution. The data shows that natural attenuation is
22 occurring at the site, but the concentrations of
23 contaminants in the groundwater are so high that it
24 would - it would take forever for -- for that to
25 completely occur. It was not even possible that it
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0010
1 would completely break it down in some of the areas of
2 the highest contamination.
3 So, that prompted an Enhanced Anaerobic
4 Bioremediation Treatability Study. Enhanced Anaerobic
5 Bioremediation Pilot Study was done in two phases. In
6 May 2006 to April 2007 was the first phase. What they
7 did, they went in and installed injection wells
8 throughout the site and injected whey into wells that
9 were a hundred feet by two hundred feet separated.
10 They did groundwater sampling before the injection, at
11 two weeks after, one month after, three months, five
12 months and then eight month. They collected data at
13 all those times to evaluate to see if - if this
14 process was effective. And when you inject whey into -
15 - or other -- other places, they used molasses or
16 different — they used more of an organic food grade
17 product where it stimulates the natural biological
18 bacteria that's in groundwater and that bacteria eats
19 away at the volatile compounds and breaks them down.
20 So, just injecting the — the food sources helps
21 stimulate that bacteria to not -- in addition to eat
22 the food source, but also break down the volatile
23 compounds as well.
24 The results of that phase I showed that PCE or
25 which is tetrachloroethene and trichloroethene
0011
1 decreased in all five of the wells used in the study.
2 Ethene - I'm going to go through in a minute the
3 breakdown process of it, but the — the goal is to
4 break down tetrachloroethene, goes to trichloroethene
5 and it eventually gets down to ethene/ethane which is -
6 - which is not hazardous.
7 So they showed increases of ethene and ethane,
8 which showed that it was the bio — the breaking down
9 was working. We were getting lower concentrations of
10 the really bad stuff and higher concentrations of the
11 good stuff.
12 In the sampling, they also took samples and
13 analyzed it for naturally occurring bacteria that's in
14 groundwater that breaks down the volatile organic
15 compounds and it was present in all wells; and
16 recommended at Phase 2 of the investigation.
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17 And in Phase 2 they re-injected whey, they
18 evaluated the effects of pH adjustment because during
19 Phase I they found that — that pH of groundwater
20 dropped during the process and — and you have to
21 maintain the groundwater pH at a certain level for the
22 bacteria to be effective.
23 There was an area where full dechlorination wasn't
24 occurring and so they added -- added bacteria in those
25 wells to see, you know, can we transfer the bacteria
0012
1 from one part of the site to another part to make it
2 effective.
3 The results of the Phase 2 study showed that full
4 dechlorination was achieved in parts of the pilot cell.
5 The pH dropped after the whey injection maybe causing
6 some of the — some resistance to the dechlorination.
7 The — they noticed that the injection wells were kind
8 of clogging up and they — they weren't able to force
9 as much — as much whey into the wells on the second
10 round. And they found that — what — in the wells
11 where the bacteria wasn't naturally — naturally there
12 they were able to pump groundwater out of one area that
13 did have high concentrations of bacteria and then re-
14 injected in the other area that was missing, the — the
15 bacteria. And then the bacteria started working over
16 there.
17 The pilot study recommendation was that out of all
18 the alternatives they looked at, pump and treat, in
19 situ chemical oxidation, barrier walls,
20 phytoremediation and MNA that the one that seemed to be
21 the most promising is Enhanced Anaerobic
22 Bioremediation.
23 These are the contaminants of concern in
24 groundwater at the site: 1,2-Dichloroethane and
25 ethene, Ethyl benzene, tetrachloroethene, toluene,
0013
1 trichloroethene, vinyl chloride and xylenes. The
2 second column is what the concentrations were back in
3 the - during the remedial investigation. I'm sorry,
4 the second column is the remediation goals that was —
5 that were established in the Record of Decision. The
6 third column is the concentrations that were present
7 during the remedial investigation and feasibility
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8 study. And then the last column are the maximum
9 concentrations that were found in the latest
10 groundwater sampling. And, for the most part there
11 have been — for most of them there have been
J2 significant decreases,
13 And the breakdown process that I mentioned is the
14 — the most chlorinated compound is tri — or
15 tetrachloroethene or PCE. And back during the remedial
16 investigation the highest concentration was 52,000.
17 The latest sampling is down to 930. TCE concentration
18 or trichloroethene, which is PCE breaks down — the
19 first step is to go to TCE. The concentrations have
20 increased slightly, but you would expect that if the
21 breakdown process was working. Since the concentration
22 of PCE dropped so much it was broken down and converted
23 into Trichloroethene. So there was a slight increase
24 there. The next step in the breakdown process is Cis-
25 1,2-DCE. There's slight decrease in that
0014
1 concentration. Then it's broken down to vinyl
2 chloride. We see a — a decrease in that
3 concentration. And then it's broken down to etliene and
4 I didn't have sampling data for ethene, so I don't have
5 any concentrations up here right now.
6 Vinyl chloride is the most ease — is the easiest
7 one to breakdown. There's only one chloride bond to
8 the chemical so it's the easiest for the bacteria to
9 break it down.
10 So, after the pilot study was done. Tex Iron's
11 contractor. CDM submitted a feasibility study
12 amendment, and it described the enhanced anaerobic
13 bioremediation process and compared it against the
14 original treatment options that were evaluated in the
15 Record of Decision. The cost estimate of enhanced
16 anaerobic bioremediation was $2.8 million. In the
17 original alternatives they updated the cost for those
18 by basically converting the 1998 dollars to 2009
19 dollars. And that cost range ended up being between
20 $2.1 and $7.7 million dollars.
21 When I was in the process of preparing the amended
22 proposed plan I realized that quite a few of the
23 alternatives in the original Record of Decision
24 included activities that had already been conducted,
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25 like the pumping of groundwater and the four to six
0015
1 month treatment of it and evaluation of it. So, part
2 of — part of the original alternatives had already
3 been conducted so we're — we --1 realized it's kind
4 of comparing apples to oranges, which isn't quite
5 right.
6 So, I went back and looked at the alternatives and
7 the cost estimates and took out the portions that had
8 already been completed. And, came down to the No
9 Action Alternative, which is required to be evaluated
10 for all Superfund sites. Monitor natural attenuation,
11 pump and treat for the whole site, pump and treat in
12 source area only and pump and treat at the border, and
13 enhanced anaerobic bioremediation with monitor natural
14 attenuation. Because, like I said, there - there
15 really wasn't much point in - in comparing the other
16 options I mentioned, in situ chemical oxidation,
17 phytoremediation, because we knew those just weren't
18 going to work.
19 So when 1 — when 1 revised - when I prepared the
20 proposed plan, I revised the -- the alternatives and
21 cost estimates. The original No Action Recommended
22 Alternative in the original ROD included sampling every
23 six months and conducting five-year reviews. Well,
24 that's just ~ that's — it — it ended up at a cost
25 estimate of, I think, $2.-something million dollars,
0016
1 which doesn't really make sense for no action.
2 So when I updated it, because waste was left in
3 place, five-year reviews have to be done. And then
4 minimum amount of data we would want to see to evaluate
5 a remedy is — is at least one sampling event every
6 five years, but preferably more than that. So, I threw
7 in two sampling events.
8 Conducting five-year reviews and putting -
9 putting property use restrictions on the property,
10 recording a restrictive covenant on the property deeds,
11 so people couldn't go in and install wells to use for
12 drinking purposes.
13 The second alternative was monitor natural
14 attenuation and for that we would conduct sampling
15 every six months and do five-year reviews, property use
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16 restrictions and that cost estimate came to $1.5
17 million. Like I said. Monitor Natural Attenuation is -
18 - is shown to be effective, but it's — it's not the
19 best fit because of the high contamination in some of
20 the areas.
21 The revised alternatives three through five, which
22 were pump and treat at different areas, would install
23 and operate extraction wells and a treatment system,
24 sample every five year — or every six months, conduct
25 five-year reviews, property use restrictions and it
0017
1 would cost between $6.6 and $7.1 million. And the big
2 disadvantage of this is because earlier when they tried
3 to do the extraction, they were just getting such low
4 yields that I don't think this would be the best —
5 best option for this site.
6 And then the last one is enhanced anaerobic
7 bioremediation, which is what — what we're proposing
8 to move forward with for the cleanup of groundwater on
9 the site.
10 For this remedy they would install injection wells
11 twenty-five feet apart. During the pilot study they
12 did it at one hundred by two hundred foot distance.
13 But during that study realized we — we need the closer
14 spacing between the wells. So they would install
15 injection wells twenty-five feet apart. They would do
16 three separate injection events; they would inject and
17 monitor for several months and then do a successive
18 injection and if takes more than — more than three
19 times they would do it again. But, think it can be
20 accomplished with three injections. Sample every six
21 months; they've been sampling groundwater every six
22 months since the, I believe, 2001; so this is really
23 nothing new for them. Five-year reviews, property use
24 restrictions and the cost was $2.8 million.
25 So the next steps are, after we consider any
0018
1 public comments, EPA will issue a Record of Decision
2 Amendment, which we'll select the — the final remedy
3 for the site. If any of you have any great ideas for
4 something I haven't already discussed, some innovative
5 treatment technology, you know, we — we'd love to hear
6 about it. But we think at this point this is the best
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7 treatment option for the site.
8 After the Record of Decision Amendment is issued,
9 the remedial design will continue and be completed.
10 And after the remedial design is completed, the
11 groundwater treatment would begin.
12 The public comment period extends through
13 September 20th where tonight we have a court reporter
14 here who will be - who's recording this meeting and
15 shell — any comments or questions, or comments you
16 have here tonight will be recorded and be considered as
17 part of the — part of the public comment process. But
18 if you leave here and think of something else, you
19 know, you go home and you Google search and you find
20 some grand technology that you think might work, feel
21 free to mail or email me any comments. And anyone —
22 any comments received by September 20th will be
23 considered for the Record of Decision Amendment.
24 So, at this point, I'm going to open it up to any
25 comments or questions. If you would please state your
0019
1 — your first and last name before you make your
2 comment or question so it can be recorded.
3 OPEN FLOOR FOR QUESTIONS AND COMMENTS
4 MR. BENJAMIN DUNCAN: Benjamin Duncan. The
5 building — the building out there, you think
w w -• J
6 there's contamination — contamination is under
7 that building?
8 MS. URQUHART-FOSTER: No, sir, we don't - we
9 don't think there's contamination under the
10 building. They — they've collected a lot of —
11 lot of samples around the area.
12 MR. BENJAMIN DUNCAN: Okay. And there wasn't
13 nothing under - under the floor? The building
14 have a concrete floor, right?
15 MS. URQUHART-FOSTER: I haven't been in the
16 building, I — I believe sampling has been done
17 near the edge, but I'm not positive. I can — I
18 can certainly get back to you on that.
19 MR. BENJ AMIN DUNCAN: Okay.
20 MS. URQUHART-FOSTER: But they did do - the
21 Removal Program of EPA went in and evaluated the
22 site and 1 believe they removed some drums of
23 chemicals that were in the building, but the
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24 building itself is not contaminated.
25 MR. BENJAMIN DUNCAN: Okay,
0020
1 MS. URQ UHART-FOSTER: Thank you. (Awaits
2 more questions.) Yes?
3 MS. SUSAN DELK: Hi, I'm Susan Delk with
4 People-Sentinel Newspaper. The cost that you have
5 in — in these different proposals here, who
6 actually pays for that cost? Where does that
7 money come from?
8 MS. URQUHART-FOSTER: Textron will be paying
9 for the cleanup as -- as they have been since the
10 remedial investigation. They - they have funded
11 all of the work from the remedial investigation on
12 forward. And, expenses that EPA and South
13 Carolina Department of Health and Environmental
14 Control, you know, they — they charge the time
15 that they work on this project, and - and all of
16 those costs are - we send an, what's called an
17 oversight bill to Textron once a year with EPA and
18 South Carolina DHEC cost and then they reimburse
19 EPA as well. So. not only will they being for the
20 cleanup, but they reimburse us for our costs as
21 well. (Awaits more questions.) Any other
22 questions or comments? Are you deep in thought;
23 contemplating?
24 MS. SUSAN DELK: One more question?
25 MS. URQUHART-FOSTER: Sure.
0021
1 MS. SUSAN DELK: How long - I saw the
2 restrictions on the deeds, how long before this
3 property can actually be sold by Textron?
4 MS. URQUHART-FOSTER: I believe they - they
5 could sell it now. The — the restrictions on the
6 deed would just ~ if ~ if someone bought it now,
7 the restriction would be not to dig in those areas
8 where the soil contamination was left behind and
9 not to install wells for potable purposes. But
10 they could still use the property for other —
11 other uses. But, they're aoing to be going in and
12 installing these injection wells twenty-five feet
13 apart over a large portion of the property. So,
14 it would, you know, kind of depend on what the
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15 person who was buying the property, what they were
16 going to use it for. They think — think — I
17 think the estimate was ten years for the — the
18 bioremediation to — to break — break it down
19 completely. And also they — they have, looking
20 at monitor natural attenuation is kind of a
21 backup. Because that is occurring, but mainly in
22 the areas where the contamination is lower
23 concentrations, and - and it's — we found it
24 monitor natural attenuation works best for areas
25 with low — lower concentrations, so, that'd be
0022
1 kind of a polishing step.
2 MR. WILLIAM GOUTHRO: Who owns the property
3 now?
4 MS. URQUHART-FOSTER: I'm not sure if Textron
5 owns it or if someone else, but I can find out.
6 MR. WILLIAM GOUTHRO: (Inaudible response)
7 took over from Textron, he owned the - he owned
8 the business. I don't know about the property.
9 And then when he — he pulled out, he just pulled
10 out and left it. Now, I — then I thought the
11 Superfund took over after that.
12 MS. URQUHART-FOSTER: Well, Superfund -- EPA
13 can't — we don't purchase property. We took over
14 the cleanup and stuff like that, but we don't own
15 the - own property. And I'm not — I'm not sure
16 if Textron bought it or not, but I can find out
17 and get back to you.
18 MR. WILLIAM GOUTHRO: I was just wondering -
19 wondering why Textron's involved again.
20 MS. URQUHART-FOSTER: Well, because they were
21 a responsible party.
22 MR. WILLIAM GOUTHRO: The original owners?
23 MS. URQUHART-FOSTER: Yes. Sir, what was
24 your name?
25 MR. WILLIAM GOUTHRO: Huh?
0023
1 MS. URQUHART-FOSTER: What was your name,
2 please?
3 MR. WILLIAM GOUTHRO: Mine?
4 MS. URQUHART-FOSTER: Yes.
5 MR. WILLIAM GOUTHRO: Bill Gouthro.
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6 MS. URQUHART-FOSTER: Okay.
7 MR. WILLIAM GOUTHRO: I had worked there
8 awhile.
9 MS. URQUHART-FOSTER: Okay.
10 MR. WILLIAM GOUTHRO: That's why I --
11 MS. URQUHART-FOSTER: So you're familiar with
12 it. (Awaits more questions.) Any other questions
13 or comments?
14 Well, if you leave here and happen to think
15 of something else that you think is important for
16 us to — to hear about, please let us know. We
17 definitely like to consider your input. I've -
18 I've learned a lot from the community in each time
19 I've done a Record of Decision; have learned
20 valuable things that have really helped improve
21 the remedy. I mean it may be something small, but
22 we definitely value community input. (Awaits more
23 questions.)
24 MR. BENJAMIN DUNCAN: Turkey Creek right
25 behind that, isn't it?
0024
1 MS. URQUHART-FOSTER: Turkey Creek?
2 MR. BENJAMIN DUNCAN: Right.
3 MS. URQUHART-FOSTER: Yes.
4 MR. BENJAMIN DUNCAN: It didn't get that far
5 back, did it?
6 MS. URQUHART-FOSTER: No, it's not in Turkey
7 Creek. And I — I — I believe they sample it
8 once, or at least they used to sample the Turkey
9 Creek. I don't - I don't remember if they -
10 they're still doing it or not. But it - it
11 wasn't — it didn't get that far. It wasn't
12 contaminated.
13 MR. BENJAMIN DUNCAN: The reason I ask is
14 there's fish back there.
15 MS. URQUHART-FOSTER: Okay. Well, if nobody
16 has anything else, thank you for coming tonight.
17 Kyle, did you have anything else?
18 CLOSING STATEMENT BY KYLE BRYANT
19 Not as far — I guess I will add just from a
20 community's perspective for whoever's the potential —
21 who is the potential future owner, if there's a
22 purchaser in the community interested in the site, our
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23 agency does have several competitive grant resources
24 that are available so community stakeholders can look
25 at Superfund types not just as an eye sore, but as an
0025
1 opportunity for revitalization and redevelopment. And
2 that — we have Superfund redevelopment funds that are
3 available. There are competitive grants. So, city
4 governments, county governments, downtown development
5 authorities, those types of entities, main street
6 organizations, can identify the stakeholders in a given
7 community. It could be a local community group. It
8 could be any non-profit organization that has interests
9 in redevelopment and look at the Superfund site as for
10 what do we want this to become. You know, whether it's
11 an industrial park based on the limitations that are
12 set forth in the — the institutional controls.
13 Now is the time at the public comment period stage
14 where you start to interface with the agency and let us
15 know what -- hey, we're kind of interested in doing
16 something with this, so if you have to leave some
17 contamination in place, let's see where we can work
18 with the agency to re-identify those places and say,
19 okay, well, if they're all on, say, the western part of
20 the property, maybe that can be the parking area and we
21 can just pave that over and then — then that can go
22 into the remedial design. But, also, just think of it
23 in terms of the Superfund site being the hole of a
24 donut and then you can think about what goes around the
25 peripheral of that in terms of other resources that we
0026
1 have available to us, like a ground (inaudible
2 response) development, which looks at commercial or
3 industrial property where there is no or perceived
4 contamination. These are opportunities that a township
5 can look at this site as an opportunity to spur up
6 revitalization and -- and may be an area that might be
7 perceived as vital. And so, we have several resources
8 for that and even resources that help communities build
9 their capacity like our CARE Grant, which is
10 Communities Aligned for Renew Environment - Renewed
11 Environment. Those grants help communities identify
12 the stakeholders and bring them together in forums like
13 this to discuss, "What are we going to do about Shuron
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14 Site?"
15 Most of you, I'm sure in this area are familiar
16 with SRS. We just completed another successful
17 Superfund's job training initiative at the site where
18 we focused on Allendale and Barnwell communities and
19 got jobs, career opportunities for thirty-nine
20 additional people. And, this general area, well,
21 Superfund job training initiative is not just for SRS
22 jobs. And these super fund sites around the country
23 we're using that as a vehicle to have a character
24 dangle for community citizens if they're going to be
25 like a couple of years of moving earth around and doing
0027
1 cleanup work and EPA contractors is coming to do that
2 work, we can also look at structuring opportunities
3 where we have locals apply for jobs and things like
4 that. And then we can train them with these funds we
5 have to be, say, a forty hour certified and (inaudible
6 response) and things like that. Whether they are just
7 flag men or shoveling dirt, simple things, but giving
8 these people meaningful skills that can transition to
9 other jobs once the contractors are out of town. And
10 in some cases the contractors that like the work of the
11 locals and ask them to follow them onto the next, you
12 know, cleanup. So there are opportunities that our
13 agency can make available, that are competitive and
14 also through some of our other federal partners looking
15 at other grants that tie into redevelopment and
16 revitalization. from USD A, Department of
17 Transportation, HUD, things like that, that all work as
18 pieces of the puzzle to help a city, you know, regroup
19 and redevelop a vital piece of property. That's all I
20 have to say.
21 MS. URQUHART-FOSTER: And--that just reminded
22 me. We also have, what's called a bonafide — I forget
23 what the "S" stands for. Well, maybe it's Bonafide
24 Perspective Purchaser Program. And so if someone's
25 interested in purchasing the property, what we would do
0028
1 is have a — a conference call between EPA and them and
2 explain to the person who's interested, what the
3 contamination is at the site, what the limitations
4 would be of their use, find out from them what they
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5 intend to use the property for and see if it's a good
6 fit.
7 If it's a good fit, then we would send them what's
8 called a Status Letter or Comfort Letter, which would
9 basically go document that conversation, what they plan
10 to use the property for, what — what we see future
11 work on the property being, what the restrictions would
12 be. And as long as they don't cause anymore
13 contamination to the property and as they don't
14 interfere with the cleanup going on, then they will not
15 be held liable as a liable party to do the — to be
16 required to do any part of the cleanup. Of course, if
17 they spill something during their operations then —
18 then they would be liable, but...
19 MR. BRYANT: So these bring some good
20 opportunities to think strategically about what else is
21 going on in your region, what types of industries
22 you're trying to attract and what is going where and
23 what might be a good puzzle piece for that particular
24 site.
25 All right. If there aren't any more questions or
0029
1 comments, thanks for coming and comment period is over
2 on the 20th of September, so. spread the word to your
3 neighbors and if they have any questions they need to
4 contact Ms. Urquhart or myself; especially, about the
5 grants or anything like that. Thank you.
6 MS. URQUHART-FOSTER: Thanks.
7
8 (WHEREUPON, AT 7:10 P.M., THE PROCEEDING OF THE
9 ABOVE-ENTITLED MATTER WAS CONCLUDED.)
10
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22
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24
25
0030
1
2
Public Meeting Regarding Shuron Inc. Site
3
Date of Meeting: August 30, 2010, 6:30 p.m.
4
Location: Barnwell County Library, Barnwell, SC
5
6
7 Be it known that I took the foregoing hearing; and
for the State of South-Carolina-at-large;
8 The foregoing transcription of represents a true,
accurate and complete transcription of the public
9 meeting so given at the time and place aforesaid to the
best of my skill and ability;
10 That I am not related to nor an employee of any of
11 the parties hereto, nor a relative or employee of any
12 attorney or counsel employed by the parties hereto, nor
13 interested in the outcome of this action.
14
15 Witness my hand and seal this 13th day of
16 September, 2010.
17
18
19 Suesan L. Richardson, Notary Public for SC
20
21
22 Notary in and for the State of South Carolina
23
24 My Commission Expires: August 3, 2010
25
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