BACKGROUND
The Wateree Chemical Company is located off an unnamed dirt road that runs 0.75 miles south of the intersection of US Highway 1 and Secondary Road 369 between the towns of Lugoff and Elgin in Kershaw County, South Carolina. The area surrounding the Site is predominantly rural. The Site is encompassed by woodlands. The nearest residence is located approximately 0.5 miles away from the facility. The majority of people within a 4-mile radius of the Site are supplied water by the Lugoff/Elgin Water District who obtains its water from a surface intake located on Lake Wateree, upstream of the Site.
The Site is the location of a former chemical manufacturing facility that operated from 1964 to 1976. Wateree Chemical manufactured a variety of chemicals for sale to schools, industries, and foreign countries. Major products included carboxylic acids, organohalides, organonitrates and organosulfur compounds. Other products included amines, ethers and hydrocarbons. Wateree Chemical ceased operations prior to the inception of RCRA regulations, so the company was never permitted to treat, store, or dispose of hazardous waste on-site. Waste from the chemical manufacturing process and cooling water were discharged into a sand hill and allowed to percolate through the soil at a designated waste pit. Prior to discharge chemicals were either oxidized or diluted using chromic acid, peroxides or sodium cyanide.
The Site was reportedly used as a tire company in the early 1980's. In the mid 1980's a company called Aerospace Technology, Inc. operated on the Site. The company apparently leased the Site for the packaging of oil products. During the late 1980's, Polymer Equipment Cleaning (PEC) used the property to remove oil and paint from equipment used in automobile assembly lines. In 1991 Mr. Leon Goodall of Carolina Continental (current owner), contracted Laidlaw Environmental Services to do a visual cleanup of the Site. Fourteen 55-gallon drums, twenty-seven 5-gallon cans, and 119 other various cans and containers were inventoried and removed from the Site.
The facility consists of five cinder block buildings, one metal building, a pump house, and a cinder block pump house/electrical building. An 18-inch diameter well is located outside one of the large cinder block buildings, which also has a concrete pad outside of it. This building appears to have been used as a garage or maintenance bay. Two of the buildings appear to have been chemistry labs. The buildings drained via a ceramic drainpipe which diverted waste products to a sand pile approximately 20 feet behind one of the other buildings. An additional 8-inch well is located just outside the pump house/electrical building.
REMOVAL SITE EVALUATION
The South Carolina Department of Health and Environmental Control (DHEC) performed an Expanded Site Inspection (ESI) in January and February of 2001. The Inspection consisted of a site reconnaissance including an electromagnetic survey in which a 20' X 40' burial area was discovered at the southeast end of the Site. An unknown number of drums were reportedly located 18" below the surface. Environmental sampling consisted of groundwater, surface water, sediment, surface soil and subsurface soil samples.
Groundwater samples were collected from the 18-inch diameter well adjacent to Building #1 and the 8-inch diameter well located behind the pump house. The samples indicated elevated levels of metals, pesticides, VOCs and SVOCs. Lead and 1,1-dichloroethene were detected above Maximum Contaminant Levels (MCLs)in two samples. One was collected from a spring downgradient of the Site that appears to empty into the unnamed tributary to the northeast of the Site. The second was collected from the 18-inch diameter well adjacent to Building #1, it is important to note that the well was not purged due to depth and lack of appropriate equipment.
Sediment samples were collected from runoff streams located to the southeast and northeast of the Site. Sediment samples indicated high levels of metals and VOCs, as well as an unknown steroid.
Ten surface soil samples (0 to 12") and eleven subsurface soil samples (12 to 18") were collected and compared to a control sample. For this evaluation, the data was reviewed and the maximum detected concentrations were compared to the Removal Action Levels. The Removal Action Levels were determined by converting the Region 9 PRGs to risk-based concentrations appropriate for time-critical removal actions. The derived RALs are based upon a residential human risk of 1x10-4 for carcinogens and a Hazard Index of 3 for non-carcinogens. Although several metals, extractable and pesticides were detected at elevated levels, none of the contaminants exceeded the RALs used to determine the appropriateness of a removal action.
On May 30, 2007 OSC Hughes visited the Site in order to conduct a site reconnaissance and determine the need for additional investigatory actions. There was no visible evidence indicating the suspected location of the buried drums. It was determined that further investigatory activities would take place at the Site.
On July 31, 2007 OSC Hughes met with START personnel on-site in order to conduct a geophysical survey using ground penetrating radar (GPR). ARM Environmental was contracted by START to perform the geophysical survey using a GPR to evaluate the property for potentially buried drums. The survey identified two areas defined as a grouping of large hyperbolic anomalies that may represent drums, pipes, or other buried materials. In addition to these areas, smaller anomalies were also encountered, as well as a contiguous area of probable disturbed ground. This final anomaly is coincident with a small, gentle swale on the ground surface over most of its length, and the trees within the footprint of the anomaly are consistently small. The conclusions of the geophysical survey in conjunction with selective hand augering indicate the presence of some metallic objects in the subsurface of the southeast portion of the Site. Visible observations of the hand augered locations indicated that the metal objects appeared to be in a severely deteriorated condition. In order to determine whether or not the metal objects contain and/or have led to the release of hazardous substances, pollutants, or contaminants; additional sampling was conducted.
On September 5, 2007 EPA and START personnel returned to the Site to conduct sampling activities in an attempt to identify a release of any hazardous substances at the Site. Upon arrival at the Site, START conducted a radiation survey with a Ludlum radiation meter. None of the values exceeding background readings for the Site. Additionally, a Toxic Vapor Analyzer (TVA)- 1000 equipped with a combination photoionization (PID) flame ionization (FID) detector was used to screen the Site for organic vapor concentrations. None of the readings exceeded background levels. Soil and groundwater samples were collected from the Site in order to quantify and document releases to the environment and to collect any evidence indicating the potential contents of the buried drums.
The two permanent wells were original targeted for sampling, but the water level indicator showed that the well adjacent to Building #1 had approximately 1 foot of muddy water in it, an insufficient volume to perform the necessary purging. Two subsurface soil samples and one duplicate were collected in the vicinity of the buried drums based on the results of the geophysical survey, visible staining and PID/FID readings.
Analytical results from the groundwater sample indicate that aluminum, chromium, nickel, iron and potassium were detected above the Method Detection Limit. However, none of the results were above the Region 9 PRGs for direct contact exposure with tap water. Analytical results for the subsurface soil samples indicate that 15 metals, 7 pesticides, 3 SVOCs, and 7 VOCs were detected in one or more of the soil samples. Arsenic concentrations ranged from 2.3 mg/kg to 3.3 mg/kg.
RECOMMENDATION
Based on the removal site evaluation, the Wateree Chemical Site should be assigned a no further action for conducting a time-critical removal action. Site conditions do not meet the requirements for initiating a time-critical removal action according to criteria listed in Section 300.415 (b)(2) of the NCP. The site does not pose an immediate threat to the public health or welfare or the environment because of the following:
Soil exposure pathway: There are no occurrences of soil contamination on the surface or in the subsurface, in excess of the Removal Action Levels.
Surface water migration pathway: One surface water and three sediment samples were collected from the unnamed tributary east of the Site. Two sediment samples contained heavy metals and volatile organic compounds at concentrations more than three times background, but none exceeding EPA Region 9 PRGs.
Groundwater migration pathway: Although two groundwater samples did exceed MCLs for lead, the site is located in an area where the nearby population utilizes drinking water from the municipal water supply. Additional sampling conducted at a later date using the proper purging techniques did not indicate any contaminants above MCLs.
Air migration pathway: The air migration pathway does not pose a threat at the Site due to its remote location and limited number of residents within 0.5 miles of the facility.
The investigations conducted as part of this RSE attempted to evaluate the conditions at the Site in order to identify the applicability of the criteria stated in Section 300.415(b)(2) of the NCP. Although trace levels of contaminants were identified in the vicinity of the unidentified metal objects in the subsurface, none of the values are above Removal Action Levels. This evidence, in addition to the lack of exposure pathways, leads to the conclusion that the Site should be assigned a no further action for removal activities.
In the event that the property encompassing the Site transitions into residential use, the need for CERCLA activity may want to be reevaluated.
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