FIVE YEAR REVIEW REPORT (TYPE 1A) FOR THE CAROLAWN SITE FORT LAWN, CHESTER COUNTY,

August 25, 1998 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 ATLANTA FEDERAL CENTER 61 FORSYTH STREET ATLANTA, GEORGIA 30303-8960

MEMORANDUM

DATE: August 25, 1998

SUBJECT: Five-Year Review Report Carolawn Superfund Site Fort Lawn, Chester County South Carolina

FROM: Alfred L. Cherry Remedial Project Manager

THRU: Jan B. Rogers, Chief South Carolina Section

Robert Jourdan, Chief North Site Management Branch

TO: Richard D. Green, Director Waste Management Division

The Subject report has been prepared in accordance with the May 23, 1991, Office of Solid Waste and Emergency Response (QSWER), directive 9355.7-02 and Supplement Guidance. The directive states that Regions should initiate a Statutory Review within five years of RA on-site construction initiation at a site where hazardous substances will remain above levels that allow unlimited use and unrestricted exposure after completion of the Remedial Action, and the Remedial Action will require five or more years.

Internet Address (URL) • http://www.epa.gov TABLE OF CONTENTS

1.0 INTRODUCTION ...... 1 1.1 Site Location ...... 1 1.2 Site Characteristics ...... 5 1.3 Site History ...... 7 2.0 DISCUSSION OF REMEDIAL OBJECTIVES ...... 11 2.1 ARARs Reviews ...... 11 2.2 Summary of Site Conditions ...... 11 2.3 Areas of Noncompliance ...... 12 2.4 Toxicity Testing Limits ...... 12 3.0 RECOMMENDATIONS ...... 13 4.0 STATEMENT OF PROTECTIVENESS ...... 13 5.0 NEXT FIVE-YEAR REVIEW ...... 13

FIGURES

Figure 1 Site Location Map...... 2 Figure 2 Site Vicinity Map...... 3 Figure 3 Location of Adjacent Residence and Portable Wells ...... 4 Figure 5 Magnetometer Survey Grid and Data ...... 6

APPENDICES

Appendix A - NPDES Permit Modification Revision Appendix B - Effluent Diffuser System Technical Specification Appendix C - Effluent Diffuser Construction Permit 1.0 INTRODUCTION

EPA Region IV conducted this review pursuant to CERCLA Section 121(c), NCP Section 300.400(f)(4)(ii), and OSWER Directives 9355.7-02(dated May 23, 1991), and 9355.7-02A (dated July 26, 1994). It is a policy review. The purpose of a five-year review is to ensure that a remedial action remains protective of human health and the environment and is functioning as designed. This document will become a part of the Site file. This review (Type I) is applicable to a Site at which a response action is ongoing.

1.1 Site Location and Description

The Carolawn Site is an approximate 60-acre abandoned waste storage and disposal facility located in Fort Lawn, Chester County, South Carolina (Figure 1 ). The Site, shown in Figure 2, is situated less than three miles west of Fort Lawn, the closest population center to the Site, and approximately one-half mile south of at an altitude of 34° 41' 10" north and longitude 80° 56' 35" west.

Rural and Agricultural areas surround much of the Site. The Lancaster & Chester Railroad and County Road 841 border the Site to the south and Fishing Creek borders the Site to the east. Fishing Creek is a tributary to the . Wooded areas and cultivated fields lie to the west and north of the Site. Soybeans have been historically planted in these fields. Fort Lawn had a population of 471 according to the 1980 U.S. Census.

Approximately five acres of the Site were affected by the hazardous waste storage and disposal activities, three of which are enclosed in a chain-linked fence (Operable Unit 1 consist of the area beyond the fence ). Disposal activities at the Site began in 1970 and ended in 1980, when the Site was abandoned.

Located within a two mile radius of the Site are approximately thirty (30) permanent, single family residences, most of which are along South Carolina Highway 9 (Figure 2). There are four residences located within 300 yards of the fenced area with a fifth residence located approximately 1,000 yards to the west of the site. One of these dwellings is located between the site and Fishing Creek (Figure 3).

Natural resources in the area of the Site include water, soils, flora, and fauna. The waters of Fishing creek are occasionally used for fishing and other recreational activities, but topography and poor accessibility limit the use of the creek in the vicinity of the Site. Fishing Creek flows southward past the site and eventually empties into the Catawba River, eight miles south of the

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Site and above Great Falls, South Carolina, where approximately 2,500 people receive their water supply from the Catawba River.

The residential, commercial, and industrial establishments within the City of Fort Lawn receive their water supply from the Chester Metropolitan Sanitary District (MSD), whose water intake on the Catawba River is approximately four miles east of the Site and above the confluence of Fishing Creek and Catawba River. Three of the four residents adjacent to the Site who used private wells were provided an alternative water source in 1985 and connected to the Chester MSD. The fourth resident declined the opportunity to be connected to Chester MSD system and elected to continue to use their private well. To date, no contaminants have been found in this private well.

1.2 Site Characteristics

The Carolawn Site is located in the eastern Charlotte Belt of the Piedmont Physiographic Province of South Carolina. This belt is characterized by granitoid gneisses with strong compositional layering, probably derived from sediments. The bedrock in the vicinity of the Site consists of Lower Metadiorite and Metagabbros. The complex is cut by pegmatite granite and mafic dikes.

The upper regions of the bedrock have been altered by in-Site weathering. This weathering has produced a partially to highly decomposed mixture of rock and soil, which is referred to as saprolite. Saprolite retains the vestigial mineralogy and structure of the original rock.

The bedrock beneath the Site has undergone several episodes of deformation. These events created joints and fractures. These structural features influence groundwater flow within the crystalline bedrock. The major structural features noted at the Carolawn Site were joints and dikes. Joint measurements revealed the presence of three joint sets with primary sets striking N45° W and N5° W and a minor set striking at N35° W. All joint sets had vertical to subvertical dips. The mafic dike identified strikes at approximately 45° W and is moderately well fractured. Figure 5 provides the orientation and profile lines as well as the data generated in the magnetometer survey of the Site and the orientation of the mafic dike that runs through the Site.

The major hydrostratigraphic unit beneath the Site is the granodiorite bedrock. Saturated conditions were not encountered in the Residuum /Saprolite unit. Conditions may usually be saturated, but the RI was conducted during an extended drought and only unsaturated conditions were encountered in this unit. The groundwater in the bedrock is associated with the joints and fractures.

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All groundwater in South Carolina is classified as Class GB Waters (South Carolina Regulation 61-68). This classification means that all groundwater meeting the definition of underground sources of drinking water (USDW) meet quality standards set forth in the State Primary Drinking Water Regulations (R.61-58.5). An USDW is defined as an aquifer or portion of an aquifer which supplies or contains sufficient quantity of water to supply a public supply system.

1.3 Site History

The Carolawn Site was originally owned by the Southeastern Pollution Control Company (SEPCO) of Charlotte, . Beginning in 1970, SEPCO used the Site as a storage facility for a solvent recovery plant located in Clover, South Carolina. SEPCO went bankrupt in 1974 and abandoned the Site, leaving approximately 2,500 drums of solvent on Site. SEPCO had been storing the drummed solvents in anticipation of incinerating the waste. However, neither an incineration permit nor a storage\disposal permit was issued to SEPCO by SCDHEC. In January 1975, Columbia Organic Chemical (COCC) was contracted to clean up the SEPOC Plant in Clover, South Carolina. As part of this clean up effort, COCC transported and stored the waste of approximately 2,000 drums at the Carolawn Site. As payment for services rendered during the cleanup of the plant in Clover, South Carolina, COCC received the Carolawn property. After 1975, South Carolina Recycling and Disposal, Inc.(SCRDI), a subsidiary of COCC, controlled the Site. During 1978, SCRDI obtained a permit from SCDHEC for a one-time disposal of 300-400 drums containing inert waste. In October 1978, SCRDI was given approval to dispose of empty drums on the 3-acre fenced portion of the property. After the disposal, SCRDI sold the 3-acre fenced area of the Site to the Carolawn Company. Between 1978 and 1980, the Carolawn Company conducted waste storage and disposal operations within the sixty-acre Site that was enclosed by a chain linked fence. When the Site was subsequently abandoned in 1980 by the Carolawn Company, the fenced area contained a diked area for storage of tanks and drums, two incinerators, two storage trailers, 14 storage tanks, and over 400 drums containing liquid and solid wastes. Over 600 drums and 11 tanks were also located outside the fenced area to the west and north of the Site.’

During the early 1980’s, SCDHEC and EPA conducted Site investigations at the Carolawn Site. These investigations included collecting environmental and private residential well samples for analysis. The result of these investigations showed the presence of trichloroethane (TCE) and other solvents in nearby residential wells. The results also indicated that the Site was contaminated with high levels of metals and organic compounds. Due to the elevated levels of contamination found and the potential threat for imminent damage to public health and/or the environment, EPA initiated cleanup activities at the Site on December 1, 1981. The cleanup activities continued through February 1982 and included removal of contaminated soils, drums, and liquid waste from

7 the Site. Subsequently, in December 1982, the Site was proposed for inclusion on the National Priorities List (NPL). The Carolawn Site was finalized on the NPL in September 8, 1983. Since continued sampling of local residential wells showed persistently high levels of TCE, the Chester Municipal Sewer District's water main from Highway 9 was extended to four of the five residences living near the Site. These four residents were connected to this alternative water supply in 1985.

In May 1985, a group of Potentially Responsible Parties (PRPs- the Carolawn Generators Steering Committee) entered into an Administrative Order on Consent to remove 17 storage tanks off-Site and dispose of the waste contents at an incinerator. In addition, the PRPs treated the water from decontamination activities and excavated and disposed of contaminated soils. Pursuant to a Partial Consent Decree, the PRPs conducted a Remedial Investigation and Feasibility Study (RI/FS) for OU1 between 1985 and 1989. The RI/FS confirmed the presence of volatile organic compounds (VOCs) in the groundwater exceeding Maximum Contaminant Level (MCLs). It was also determined that due to the effectiveness of the removal actions, no source of contamination remained within the fenced area of the Site. However, the findings documented in the RI for OU1 indicated that limited soil data was collected from the west and north drum areas located outside the fenced area (OU2), requiring collection of additional samples to confirm the presence or absence of residual soil contamination in these areas.

On September 27, 1989, EPA issued a Record of Decision (ROD) for OU1 which selected the following remedy:

Recovery of contaminated groundwater using extraction well technology;

On-Site treatment of groundwater by equalization, filtration, and removal of VOCs by air- stripping;

The following are alternatives for discharge of treated groundwater: (1) the local sewer system: (2) Fishing Creek via a National Pollution Discharge Elimination System permit (NPDES): (3) on-Site irrigation or : (4) possible groundwater injection. The most cost effective combination for the point of discharge and the degree of treatment will be determined in the Remedial Design stage. In addition, concurrence on the final Remedial Design will be required from SCDHEC and the public.

Upon the condemnation of the adjacent contaminated private potable wells by the County of Chester, these wells will be plugged in accordance to SCDHEC regulations. Additional field work will be required in the disposal area north of the fenced area consisting of the installation of soil borings to verify the presence on absence of contamination in this area.

8 The selected remedy established clean-up for contaminants in the groundwater based upon 1 x 10-6 carcinogenic risk factors and proposed MCLs. The selected remedy eliminates the principal threat posed to human health and the environment by preventing further migration of VOCs in the groundwater and by treating groundwater to health-based clean-up levels.

In accordance with the Remedial Design/Remedial Action Work Plan, from December 1991 through May 1992, Conestoga-Rovers & Associates (CRA), representatives of the Carolawn Steering Committee, implemented several components of the Remedial Action, which included the closure of residential wells, appropriate closure of the RI Decontamination area and installation of a water service to a resident. In an effort to address components of the ROD for OU1, EPA conducted a RI/FS on OU2, focusing mainly on soil (surface/sub surface), surface water, and the sediment in Fishing Creek. On September 21, 1995, EPA issued an ROD for OU2, which selected a “no further action” remedy for land located immediately around the fenced area. This consisted of land located north and west of the fenced area. Furthermore, based on several comments and concerns received during a public comment period for the Remedial Design for OU1, EPA, in consultation with SCDHEC, selected discharge to Fishing Creek via NPDES permit (SC00447538).

The Remedial Action was formally initiated on May 12, 1993, upon EPA's approval of the Remedial Design. The groundwater extraction system was constructed by CRA and ENSR under the direction of EPA and SCDHEC. The complete groundwater recovery and treatment system was installed during the period of December 1995 through June 8, 1996. The groundwater recovery system consists of five groundwater extraction wells, all requiring hoses and piping to transmit recovered fluids from the wells to the treatment building. Each extraction well is equipped with a pneumatic submersible pump and associated level sensors/ controls. The treatment system consists of two processes, which may be operated separately or in series configuration. The treatment processes are identified as the Air Stripping/Clarification process and the Bag Filter/Granular Activated Carbon (GAC) Adsorption process. It is intended that the Air Stripping/Clarification process be utilized as the primary treatment process. The Bag Filter GAC Adsorption process may provide treatment while the Air Stripper is being maintained.

On December 7, 1995, ENSR, a substractor of Conestoga-Rover & Associates was issued the Notice to Proceed for construction activities. ENSR proceeded with submittals and placing material orders, but did not begin Site work activities until January 10, 1996. Mobilization of trailers and setup of the Site support area were completed during the week of January 15, 1996. Clearing, grubbing, and pregrading of the access road and discharge line alignment were completed by January 31, 1996. Trees were cleared for railroad boring and jacking on March 12, 1996 and March 13, 1996. The casing was backfilled on May 8, 1996. This schedule was extended due to negotiations with the Lancaster & Chester Railway for the boring and jacking lease agreement.

9 The discharge line was installed between February 20, 1996 and March 14, 1996. The discharge line and manholes were leak tested from April 18, 1996 to April 24, 1996. This schedule was delayed due to wet weather conditions during installation of the discharge line. Completion of the access road was executed from April 10, 1996 to April 16, 1996.

The treatment building excavation was completed on March 5, 1996, and the dewatering bed and sump chamber were installed on March 9, 1996. The underbuilding plumbing, electrical, and foundation bases were installed and tested between March 11, 1996 and March 25, 1996. The concrete foundation was poured on April 2, 1996. The treatment building enclosure was completed over a course of nine days, from April 10, 1996 to April 18, 1996. Installation of the force mains was performed concurrently with construction of the treatment building.

Trenching, installation, and backfilling of the force mains and electrical conduits were completed from April 2, 1996 to April 18, 1996. Hydrostatic testing of the force mains was completed from April 24, 1996 to April 27, 1996. The railroad boring and jacking was completed on April 12, 1996 and the force main spares were tested on May 1, 1996.

The groundwater extraction well pumps were installed on April 23, 1996 and April 24, 1996. Completion of the wellhead piping occurred from April 23, 1996 to April 30, 1996. The pressure transducers were installed on May 30, 1996.

Electrical components were installed during the period of April 22, 1996 to April 24, 1996. Installation of mechanical components occurred from May 11, 1996 to June 5, 1996. This schedule component was extended because of equalization tank fabrication problems.

Construction of the groundwater remediation system was essentially completed June 8, 1996. SCDHEC completed a Pre-Final Inspection of the groundwater remediation system on June 11, 1996, while the EPA conducted this same inspection on June 12, 1996. Minor construction items were identified during the week of June 10, 1996, however, all items were completed by July 5, 1996. The Permit to Operate the groundwater remediation system was issued on June 14, 1996. Commissioning of the groundwater remediation system began on June 15, 1996. However, the commissioning period was reduced to two weeks as negotiated with SCDHEC, due to the fact that the NPDES permit had not been finalized. Operation and maintenance of the groundwater remediation system began on October 9, 1996. The EPA in conjunction with the Carolawn Community Advisory Group, conducted a Final Inspection on October 10, 1996 and is satisfied with the construction of the treatment system. Between October 10, 1996, and August 1997, the PRP’s operated the groundwater recovery and treatment system during Consent Decree (Amendment) negotiations. However, the PRP’s are currently operating the groundwater recovery and treatment system pursuant to a Unilateral Administrative Order issued by EPA on

10 July 28, 1997. Concurrent with operation of the groundwater recovery and treatment system, the Carolawn NPDES Permit was modified on April 2, 1998, which allowed the use of a diffuser requiring only effluent chronic testing at the instream waste concentration of 1.02%, in lieu of the current acute test at 100% effluent. The Preliminary Close Out Report was delayed until May 18, 1998, after the permit modification was approved by the State of South Carolina.

2.0 DISCUSSION OF REMEDIAL OBJECTIVES

The remedial action objectives, as defined in the ROD ( September 27, 1989 ) and the EPA issued ROD for OU2, which selected a “no further action” remedy for land located north and west of the fenced area, include the following: (1) eliminate or minimize the threat posed to public health and the environment from current and/or future migration of hazardous substances in the groundwater; (2) reduce hazardous-substance concentration levels and; (3) reduce the mobility, toxicity and/or volume of hazardous substances at the Site.

2.1 ARAR Review

A review of current Federal and South Carolina drinking water regulations reveals that most of remedial goals established in the ROD are the same as the current drinking water standards. These apply to the remedial goals for the following contaminants: Acetone, 1,1-Dichloroethane, 1,2-Dichloroethene, 1,1-Dichloroethene, 1,1,1-Trichloroethane, Trichloroethene, and Lead. Cleanup goals established in the ROD for all the aforementioned contaminants were calculated from the carcinogenic potency factor for a 1 x 10-6 risk level and based on a 70 kg person consuming 2 liters of water per day.

2.2 Summary of Site Conditions

During this phase of the project, routine Groundwater Treatment System Operations Maintenance and Monitoring activities are performed by O’Brien & Gere Operations, Inc. This includes weekly Site inspections of the treatment facility and well head locations for damage, theft, or breach of security. Equipment and control systems are functioning within operational limits. Discharge sampling is conducted two times per month, in accordance with the SCDHEC permit for the site. Volatile Organic Compounds (VOCs) samples are collected on the second and fourth Tuesday of each month. In addition, one Acute Toxicity sample is collected on the second Tuesday of each month. While the Acute Toxicity sample collected on May 12, 1998, did not meet the SCDHEC NPDES permit requirement, the Carolawn Steering Committee obtained an easement on May 12, 1998 from the State of South Carolina Budget and Control Board to install the proposed effluent

11 diffuser in the stream bed of the Fishing Creek. The Committee recorded the easement with Chester County on May 22, 1998.

2.3 Areas of Non-compliance

During the Groundwater Treatment System Operations Maintenance and Monitoring activities, all effluent limitations were met, with the exception of one exceedence, outlined by the SCDHEC permit. On May 2, 1997, the South Carolina Department issued a Notice of Violation to the Carolawn Steering Committee for failing Acute Toxicity tests during the months of October, November, and December 1996 and the January 1997 monitoring periods. In October 1997, the Carolawn Steering Committee’s Macro invertebrate study of Fishing Creek near the Carolawn Site, conducted by Shealy Environmental Services, Inc., determined that the Carolawn Site NPDES discharge had not had any impact on macro invertebrates in Fishing Creek, and the test demonstrated that the Carolawn discharge was not toxic.

The Carolawn Steering Committee plans to install an effluent diffuser at the Carolawn Site, consisting of a 6-inch ductile iron pipe attached to the end of the existing outfall pipe. Three 2- inch nozzles will be attached to the pipe, and the assembly will be buried in the streambed to assure that only the nozzles will protrude from the streambed. The 6-inch pipe will be anchored in the streambed with concrete blocks to prevent it from moving. A Red Valve Tideflex check valve will be attached to the end of each nozzle to provide maximum effluent velocity and rapid mixing in the stream. The nozzles will be directed so they discharge parallel to the flow of the stream.

In addition to the installation of a diffuser, one 4-foot section of wall will be added to the height of the last manhole to raise it above flood level. This will ensure sufficient head for proper operation of the diffuser.

The effluent diffuser will be installed no later than December 31, 1998 according to the following schedule:

Obtain all necessary permits and approvals June 1, 1998 Begin Construction August 1, 1998 Complete Construction November 1, 1998

2.4 Toxicity Testing and Limits

The South Carolina Department’s Toxic Control Strategy for Wastewater Discharges requires Acute Toxicity testing for IWC’s between 0.0% and 1.0%. The permittee proposes to construct an

12 outfall diffuser. Once the diffuser has been constructed and approved for operation by the Department, the toxicity requirement will change. The Toxic Control Strategy for Wastewater Discharges requires chronic toxicity testing for IWC’s between 0.0% and 1.0% when an instream diffuser is in place.

3.0 RECOMMENDATIONS

The effluent diffuser will be completed in November 1998. Once the wastewater treatment plant has successfully operated and consistently met permit limits for a period of six (6) consecutive months, the Carolawn Steering Committee will make application to reduce the monitoring frequency. Upon written approval by SCDHEC, the monitoring frequency will be reduced and toxicity testing will change from acute to chronic.

EPA will consult and oversee the PRP’s during the effluent diffuser construction. Based on this schedule, all construction activities shall be completed by November 1, 1998.

4.0 STATEMENT OF PROTECTIVENESS

As discussed above, the Remedial Action at the Carolawn Site has proceeded as recommended in the ROD. However, concentrations of most of the groundwater contaminants remain above the remedial goals, but are decreasing. Therefore, the Remedial Action at this Site is believed to be protective of human health and the environment. While the system is performing as designed, additional modifications discussed previously, should improve the overall effectiveness of the treatment system and hydraulically control off-Site migration of the plume.

5.0 NEXT FIVE-YEAR REVIEW

Since ongoing remedial action has not achieved the cleanup standards set forth in the ROD, EPA guidance mandates that another five-year review will be conducted to evaluate the Site’s status. Therefore, it will be necessary to re-evaluate the effectiveness of the remedy by August 2004.

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