First Five Year Review Report Macalloy Corporation
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First Five-Year Review Report Macalloy Corporation National Priorities List Site Cfiarfeston, Charleston County, South Carolina Prepared By: U.S. EPA Region 4 Superfund Division 61 Forsyth Street, SW Atlanta, GA 30303 June 24, 2010 10760299 First Five-Year Review Report Macalloy Corporation National Priorities List Site Charleston, Charleston County, South Carolina Prepared By: U.S. EPA Region 4 Superfund Division 61 Forsyth Street, SW Atlanta, GA 30303 June 24, 2010 Approved by: Date: (jli M mklin E. Hill, Director Superfund Division US EPA Region 4 Table of Contents EXECUTIVE SUMMARY viii 1. INTRODUCTION XI 2. SITE CHRONOLOGY 2 3.0 BACKGROUND 4 3.1 Physical Characteristic 4 3.2 Land and Resource Use 4 3.3 History of Contamination 5 3.4 Initial Response 5 3.5. Basis for Taking Action 7 3.5.1 Summary of RI Conclusions by Media 7 3.5.2 Summary of Site Risks 8 3.5.2.1 Human Health Risks 8 3.5.2.2 Ecological Risks 9 3.5.2.3 Fate and Transport Summary 10 4.0 REMEDIAL ACTIONS ; 12 4.1 Radiological Material: Excavation and Offsite Disposal 13 4.1.1 Remedy Selection 13 4.1.2 Remedy Implementation 13 4.1.3 Operation and Maintenance 14 4.2 Zone A Sediment Removal 14 4.2.1 Remedy Selection 14 4.2.2 Remedy Implementation 15 4.2.3 O&M 16 4.2.3.1 001 Tidal Creek Cap Monitoring 16 4.2.3.2 Tidal Marsh Plant Surveys 17 4.2.4 Five-Year Costs 18 4.3 Zone C Sediment 18 4.3.1 Remedy Selection 18 4.3.2 Operationa & Maintenance (O&M) 18 4.3.3 Five-Year Costs 19 4.4 Groundwater: Enhanced In Situ Chemical Reduction 19 4.4.1 Remedy Selection 19 4.4.2 Remedy Implementation (2004-2005) 20 4.4.3 Supplemental Remedy Implementation (2008) 22 4.4.4 O&M 24 4.4.5 Five-Year Costs 26 4.5 Soil: Onsite Chemical Reduction 26 4.5.1 Remedy Selection 27 4.5.2 Remedy Implementation 27 4.5.3 O&M 31 4.6 Surface and Storm Water: Comprehensive Storm Water Management 31 4.6.1 Remedy Selection 31 4.6.2 Remedy Implementation 31 4.6.3 O&M 33 /// 4.6.4 Five-Year Costs 33 4.7 Institutional Controls 33 5.0 PROGRESS SINCE THE LAST REVIEW 34 6.0 FIVE-YEAR REVIEW PROCESS 35 6.1 Administrative Components 35 6.2 Community Notification & Involvement 35 6.3 Document Review 36 6.4 Data Review 36 6.4.1 Review of Groundwater Monitoring Data 36 6.4.2 Review of 001 Tidal Creek Cap Measurements 38 6.4.3 Review of Tidal Marsh Plant Survey Data 38 6.4.4 Review of Zone C Sediment Monitoring Data 39 6.5 Site Inspection 39 6.6 Interviews 40 7.0 TECHNICAL ASSESSMENT 41 7.1 Question A: Is the remedy functioning as intended by the decision documents?... 41 7.1.1 Radiological Material 41 7.1.2 Zone A Sediment Removal 42 7.1.3 Zone C Sediment 43 7.1.4 Groundwater 43 7.1.5 Soil 45 7.1.6 Surface Water/Storm Water 46 7.2 Question B: Are the exposure assumptions, toxicity data, cleanup levels, and RAOs used at the time of the remedy selection still valid? 46 7.2.1 Changes in Standards and To Be Considered (TBCs): 47 7.2.2 Changes in Exposure Pathways: 47 7.2.3 Changes in Toxicity and other Contaminant Characteristics: 48 7.2.4 Changes in Risk Assessment Methods: 48 7.2.5 Expected Progress towards Meeting RAOs: 48 7.3 Question C: Has any other information come to light that could call into question the protectiveness of the remedy? 50 7.4 Technical Assessment Summary 50 8.0 ISSUES 51 9.0 RECOMMENDATIONS AND FOLLOW-UP ACTIONS 53 10.0 PROTECTIVENESS STATEMENT 55 11.0 NEXT REVIEW 54 /I/ Tables Table 2-1 Chronology of Events Table 4-1 Zone A Tidal Creek O&M Costs Table 4-2 Zone C Sediment Monitoring Costs Table 4-3 Supplemental Permeable Reactive Barriers Dimensions and Components Table 4-4 Chronology of Post-Construction Groundwater Events Table 4-5 Groundwater Monitoring and Remedial Costs during the First Five-Year Review Period Table 6-1 Groundwater Monitoring Results during the First Five-Year Review Period Table 6-2 Tidal Creek Cap Thickness Measurements during the First Five-Year Review Period Table 6-3 Zone C Sediment Monitoring Results during the First Five-Year Review Period Table 8-1 Issues Table 9-1 Recommendations and Follow-up Actions Figures Figure 3-1 Site Map Figure 3-2 Site Condition Before Remedial Action Figure 4-1 Site Remedies Figure 4-2 Monitoring Locations Figure 4-3 Zone C Sediment Sample Locations Figure 4-4 Rathall Creek Sediment Sample Location Figure 4-5 Storm Water Management Plan Figure 6-1 Total Chromium in Groundwater during First Five-Year Review Period Figure 6-2 Event 9 Shallow Groundwater Elevation Contours Figure 6-3 Year 4 Tidal Creek Cap Thickness Measurements Figure 7-1 Total Chromium Isoconcentration Lines Above Cleanup Goal From October 2009 Groundwater Sampling Appendices Appendix A Termination of Storm Water Monitoring Letter from South Carolina Department of Health and Environmental Control Appendix B Restrictive Covenant Appendix C Community Notification Appendix D Five-year review Document List Appendix E Photographs of Tidal Marsh Before and After Full Restoration Appendix F Five-year review Site Inspection Checklist Appendix G Photographs of Site during Site Inspection List of Acronyms Mg/L Micrograms per liter Ashley II Ashley II of Charleston, LLC bgs Below ground surface CaS4 Calcium Polysulfide CERCLA Comprehensive Environmental Response Compensation and Liability Act CY Cubic yard DPT Direct Push Technology EPA United States Environmental Protection Agency ERA Ecological Risk Assessment FRAR Final Removal Action Report FS Feasibility Study lbs Pounds LFA Lake fill area M Molar MCL Maximum contaminant level mg/kg Milligrams per kilograms NPDES National Pollutant Discharge Elimination System NPL National Priorities List O&M Operation and Maintenance OCRM Ocean and Coastal Resource Management PCOR Preliminary Closeout Report PRB Permeable Reactive Barriers PRP Potential Responsible Party PSI Per square inch QAPP Quality Assurance Project Plan RAO Remedial Action Objective RCRA Resource Consen/ation and Recovery Act RD Remedial Design redox reduction/oxidation RFI RCRA Facility Investigation RI Remedial Investigation ROD Record of Decision w Acronyms (cont'd) SCDHEC South Carolina Department of Health and Environmental Control Site Macalloy Corporation National Priorities List Site SPLP Synthetic Precipitation Leaching Procedure TBCs To be considered USI Unlined surface impoundment VII Executive Summary The United States Environmental Protection Agency (EPA), Region 4 Office, has prepared this First Five-Year Review Report for the Macalloy Corporation National Priorities List Site (NPL), ID #SCD003360476, located at 1800 Pittsburgh Avenue in Charleston, South Carolina. The site was used to manufacture ferrochromium alloy from 1941 to 1998 by several companies and, at various times the Department of Defense, with submerged or open arc furnaces. Waste materials generated during furnace operations included slag, wastewater, airborne waste gases, and particulate matter that were stored in unlined and lined impoundments throughout the site. The site is approximately 140 acres fronting Shipyard Creek in an industrial and commercial section of the Charleston Peninsula, which is formed by the confluence of the Ashley and Cooper Rivers. Currently, several industrial businesses occupy the southern portion of the site, and an inter-modal shipping facility is planned for the northern portion with Shipyard Creek access. During its final years of operation the plant was regulated by several federal environmental statues, primarily the Clean Water Act, the Clean Air Act, and the Resource Conservation and Recovery Act. After production at the plant ceased in July 1998 Macalloy, the EPA, and South Carolina Department of Health and Environmental Control (SCDHEC) decided the Comprehensive Environmental Response Compensation and Liability Act would be a more appropriate mechanism for the site. Subsequently, it was listed on the NPL in February 2000. Upon completion of a Phase I and II Remedial Investigation and Feasibility Study, the EPA published the Record of Decision (ROD) on August 21, 2002, for the cleanup of contaminated soil, groundwater, storm water, and sediment at the site. The following remedial action objectives (RAOs) were established by the Final ROD: • Prevent future site worker exposure to unacceptable hazard levels in groundwater. • Remediate shallow groundwater zones with the highest concentrations of hexavalent chromium to minimize long-term threats and limit hexavalent chromium migration into Shipyard Creek. • Remediate soil that leaches hexavalent chromium to groundwater and surface water at concentrations hazardous to human health and the environment. • Mitigate offsite hexavalent chromium discharges in storm water to Shipyard Creek through a combination of the aforementioned remediation measures and a comprehensive site-wide storm water management plan. • Manage storm water discharges of toxic inorganic compounds in accordance with the comprehensive storm water management plan to protect ambient saltwater quality in Shipyard Creek. • Remediate soil and debris that produce elevated levels of gamma radiation to mitigate current exposure pathways. • Mitigate exposure of benthic organisms to contaminated sediments in the Outfall 001 Tidal Creek. VIII To accomplish these RAOs, the following comprehensive, site-wide remedy was specified in the ROD and is summarized below. Environmental Media Remedy Component Description Radiological Material Excavation with Offsite Disposal 001 Tidal Creek: Removal, Upland Disposal, Capping Sediment & Restoration Zone C Shipyard Creek: Monitoring up to Five-Year Review Groundwater Enhanced In Situ Chemical Reduction Soil Onsite Chemical Reduction Surface Water/Storm Water Comprehensive Storm Water Management System Institutional controls and restrictive covenants to limit land use to commercial/industrial purposes, and Multi-media prohibit the use of groundwater underlying the property Remedial action design documents and work plans were completed and approved between January 2003 and September 2004.