Five-Year Review Report

Third Five-Year Review Report for

Rock Hill Chemical Co. EPA lD SCD980844005

Rock Hill York County, South Carolina

August 2011

Prepared By: Skeo Solutions

921 Second Street SE Charlottesville, Virginia

22902

For: United States Environmental Protection Agency

Region 4 Atlanta, Georgia

fo:ranklin E. Hill Director, Superfund Division

11111111111111111111111111111111111111111111111111 10749938

Third Five-Year Review Report for

Rock Hill Chemical Co. North Cherry Road

Rock Hill, York County, South Carolina

List of Acronyms .................................................................................................. ; ........................ 4

Executive Summary ....................................................................................................................... 5

Five-Year Review Sumnlary Form .............................................................................................. 7

1.0 Introduction ............................................................................................................................. 9

2.0 Site Chronology ..................................................................................................................... 11

3.0 Background ........................................................................................................................... 12

3.1 PHYSICAL CHARACTERISTICS ........................................................................................ 12

3.2 LAND AND RESOURCE USE ............................................................................................ 16

3.3 HISTORY OF CONTAMINATION ....................................................................................... 16

3.4 INITIAL RESPONSE ......................................................................................................... 17

3.5 BASIS FOR TAKING ACTION ........................................................................................... 17

4.0 Remedial Actions .................................................................................................................. 19

4.1 RErvlEDY SELECTION ...................................................................................................... 19

4.2 RErvlEDY II'vlPLEI\1ENTATION ........................................................................................... 21

4.3 OPERATION AND MAINTENANCE (O&M)....................................................................... 21

5.0 Progress Since the Last Five-Year Review ......................................................................... 23

5.1 UPDATE THE CURRENT DOCUMENT REpOSITORY .......................................................... 24

5.2 IMPLEMENT DELA YED RESTART IN PULSE PUMPING SYSTEM ..................... ; .................... 24

5.3 ABANDON UNUSED WELLS AT THE SiTE ........................................................................ 25

5.4 INSTITUTIONAL CONTROLS NEED TO BE FULLY IMPLEMENTED ....................................... 25

5.5 MONITOR CONTAMINANT TREND IN MW-02SH............................................................. 25

5.6 EVALUATE WHETHER PERFORMANCE STANDARDS ARE EXPECTED TO BE ACHIEVED .. 25

5.7 EVALUATE THE VAPOR INTRUSION PATHWAy ............................................................... 25

6.0 Five-Year Revie\v Process .................................................................................................... 26

6.1 ADMINISTRATIVE COMPONENTS .................................................................................... 26

6.2 COMMUNITY INVOLVEMENT .......................................................................................... 26

6.3 DOCUMENT REVIEW ...................................................................................................... 26

6.4 DATA REVIEW ............................................................................................................... 28

6.5 SITE INSPECTION ............................................................................................................ 32

6.6 INTERVIEWS ................................................................................................................... 35

7.0 Technical Assessment ............................................................................................................ 36

7.1 QUESTION A: Is THE REMEDY FUNCTIONING AS INTENDED BY THE DECISION

DOCUMENTS? ............................................................................................................... 36

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7.2 QUESTION B: ARE THE EXPOSURE ASSUMPTIONS, TOXICITY DATA, CLEANUP LEVELS AND REMEDIAL ACTION OBJECTIVES (RAOS) USED AT THE TIME OF RE~"IEDY SELECTION STILL VALID? ................................................................................................. : ............. 37

7.3 QUESTION C: HAS ANY OTHER IN FORf\1ATION COME TO LIGHT THAT COULD CALL INTO QUESTION THE PROTECTIVENESS OF THE REMEDY'? ...................................................... 38

7.4 TECHNiCAL ASSESSMENT SUMMARy ............................................................................. 38

8.0 Issues.................................................................................................................................... 39

9.0 Recommendations and Follow-up Actions ......................................................................... 40

10.0 Protectiveness Statement .................................................................................................... 41

11.0 Next Reviel\' ......................................................................................................................... 42

Appendix A: List of Documents Reviewed ............................................................................. A-I

Appendix 8: Press Notices ....................................................................................................... 8-1

Appendix C: Interview Forms ................................................................................................. C-l

Appendix D: Site Inspection Checklist ................................................................................... D-l

Appendix E: Photographs from Site Inspection Visit ........................................................... E-l

Appendix F: Ground Water Maps ........................................................................................... F-l

Appendix G: Ground ·Water Data Trends............................................................................:.G-l

Tables Table 1: Chronology of Site Events .............................................................................................. 11 Table 2. Site Property Parcels ....................................................................................................... 12 Table 3: Ground Water Performance Standards ........................................................................... 20 Table 4: Annual O&M Costs ........................................................................................................ 22 Table 5: Progress on Recommendations from the 2006 FYR ...................................................... 23 Table 6: Previous and Current ARARs for Ground Water COCs ................................................ 28 Table 7. Ground Water Monitoring Data for 2006-2010 .............................................................. 29 Table 8: Deed Documents from York County Public Records Office ......................................... 32 Table 9: Institutional Control Summary Table ............................................................................. 33 Table 10: Current Site Issues ............................ ; ........................................................................... 39 Table 11: Recommendations to Address Current Site Issues ....................................................... 40

Figures Figure 1: Site Location Map ......................................................................................................... 14 Figure 2: Detailed Site Map .......................................................................................................... 15 Figure 3: Institutional Control Base Map ..................................................................................... 34

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List of Acronyms

ARAR BRA CERCLA CFR CIC COC DCE EPA FS FYR IC MCL mg/L MTBE NA NCP NPL O&M OU POTW PRP RAO RCRA RHCC RI ROD RPM SARA SC DHEC SDWA TBC TCE VOC

Applicable or Relevant and Appropriate Requirement Baseline Risk Assessment Comprehensive Environmental Response, Compensation and Liability Act Code of Federal Regulations Community Involvement Coordinator Contaminant of Concern cis-I,2-dichloroethene United States Environmental Protection Agency Feasibility Study Five-Year Review Institutional Control Maximum Contaminant Level milligrams per liter Methyl tertiary-butyl ether Not applicable National Oil and Hazardous Substan.ces Pollution Contingency Plan National Priorities List Operation and Maintenance Operable Unit Publicly Owned Treatment Works Potentially Responsible Party Remedial Action Objective Resource Conservation and Recovery Act Rock Hill Chemical Company Remedial Investigation Record of Decision Remedial Project Manager Superfund Amendments and Reauthorization Act South Carolina Department of Health and Environmental Control Safe Drinking Water Act To-Be-Considered Trichloroethene Volatile Organic Compound

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Executive Summary

Introduction

The Rock Hill Chemical Co. site (the Site) is located adjacent to U.S. Highway 211Cherry Road and Farlow Street, just east of Cranford Street in Rock Hill, York County, South Carolina. Most of the 4.S-acre Site is currently vacant and unsecured with the exception of a ground water' extraction well. which is fenced. From 1960 through 1964, the Rock Hill Chemical Company operated at the Site. Operations included distillation of paint solvents, and textile dye products were reportedly recovered. Paint sludges, textile dye products, still bottoms and other wastes generated during the reclamation process were buried or stored in piles that were placed directly onto the ground. The company ceased operations late in 1964. First Federal Savings Bank bought a portion of the prope11y in 1972 and in 1984 began to construct a branch office on the property. During constmction activities, it was discovered that the property was contaminated. Removal actions were conducted to address soil contamination in 1986 and 1987. Follow-up sampling determined that the contaminated soils were successfully removed and no further cleanup action for soils was necessary. The Site's principal threat is ground water contamination. Contaminants of concern in ground water include trichloroethene (TCE), cis-l.2-dichloroethene (DCE), vinyl chloride, and manganese. The Site was proposed to the National Priorities List (NPL) in June 1988 and was listed on the NPL in February 1990. The triggering action for this Five-Year Review (FYR) was the signing of the previous FYR on September 30, 2006 .

• Remedial Action Objectives

The Record of Decision (ROD) that selected the remedy for the Site was signed on June 27, 1994. The principal threat identified in the ROD is ground water contamination. Re'medial action objectives (RAOs) for the site's cleanup include:

• Reduce to acceptable levels the excess risk to humans and environmental receptors associated with the medium and contaminants of concern at the Site. This will be accomplished by reducing the concentrations of contaminants that result in excess risk to human health and the environment.

• Reduce the potential for ingesting contaminants in the ground water or inhalirig volatilized contaminants from the ground water where:

o Carcinogen concentrations are above federal or state standards, or in the absence of standards, are above levels that would exceed an acceptable cancer risk range of 1 x 10-4 to 1 x 10.6; and

o Non-carcinogen concentrations are above federal or state standards, or in the absence of standards, are above levels that would exceed an acceptable Hazard Index of 1.0.

Major components of the selected remedy include:

• Extraction of contaminated ground water. • Direct discharge of extracted ground water to a publicly owned treatment works

(POTW).

5

• Deed restrictions. • Long-term ground water monitoring. • Additional work during the remedial design phase. including: determining the

relationship of the contamination detected in private wells to the contamination detected in on-site monitoring wells; collecting additional background surface soil samples to confirm that the variance in manganese levels is consistent with the environmental setting: and collecting additional surface water and sediment samples to determine if the selected background sample is representative of background conditions.

Technical Assessment

The remedy is functioning as intended. Ground water contamination has been contained and contaminant concentrations have declined since the remedy was implemented. No volatile organic compounds (VOCs) have been detected in downgradient monitoring wells since 1999. Contamination remains in site ground water and additional remedial action (night be needed to attain performance standards. Methyl tertiary-butyl ether (MTBE) contamination from an outside source is present in most wells and concentrations have increased in four wells in the past five years. There are currently no known ground water users in the area. but the institutional controls called for in the ROD have not yet been implemented and the last well survey was conducted in 1992. Institutional controls are needed to ensure that future use of ground water is restricted. Four wells remain on site that should be properly abandoned. All other exposure assumptions . toxicity data. cleanup levels and RAOs used at the time of remedy selection are still valid. In 2008, EPA evaluated the vapor intrusion pathway and determined that contaminant •concentrations in ground water were well below the threshold for concem with vapor intrusion.

Conclusion

The remedy at the Site currently protects human health and the environment in the short-term because contaminated ground water is being pumped and treated and there are no complete exposure pathways for ground water. However, in order for the remedy to be protective in the long-term. the following actions need to be taken: implement institutional controls. including proprietary controls and well permit restrictions; evaluate supplemental remedial technologies to achieve performance standards: and conduct a survey of private wells in the area of the Site to determine if potential receptors are at risk of exposure.

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Five-Year Review Summary Form

SITE IDENTIFICATION

REVIEW STATUS Lead agency: ~ EPA o State 0 Tribe 0 Other Federal Agency Author name: Johnny Zimmerman-Ward and Rxan Burdge (reviewed by EPA) Author title: Associates I Author affiliation: Skeo Solutions Review period**: 01/0112011 to 09/29120 II Date(s) of site inspection: 03/24/20 II Type of review:

~ Post-SARA o Pre-SARA o NPL-Removal only o Non-NPL Remedial Action Site o NPL State/Tribe-lead o Regional Discretion

Review number: o I (first) 02 (second) ~ 3 (third) 0 Other (specify) Triggering action: o Actllal RA On-site ConstnIction at OU# o Actual RA Start at OU#

o ConstnIction Completion ~ Previous Five-Year Review Reporto Other (specify)

Triggering action date (from CERCLlS): 09/29/2006 Due date (fh'e years after triggering action date): 09/29/2011

..* ["OU reters to operable lInI!.]

** [Review period should correspond to the actual start and end dates of the Five-Year Review in CERCLIS.]

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Five-Year Review Summary Form (continued) Issues: I. Removal of ground water contaminants has slowed and may have reached asymptotic levels. 2. A well s'urvey has not been conducted since 1992. 3. MTBE from an off-site source is present in most monitoring wells and concentrations have increased in four wells in the past five years. 4. The three Law Engineering monitoring wells and one private well located on the Site have not been properly abandoned. 5. Institutional controls called for in the ROD have not been implemented.

Recommendations: I. Evaluate contaminant trends and identify and implement supplemental remedial technologies, as needed. 2. Conduct a well survey to determine if potential receptors are at risk of exposure. 3. Work with South Carolina Department of Health and Environmental Control (SC DHEC) to ensure that the off­site source of MTBE contamination is addressed. 4. Properly abandon the unused wells. 5. Implement institutional controls as required in the ROD.

Protectiveness Statement: The remedy at the Site currently protects human health and the environment in the short-term because contaminated ground water is being pumped and treated and there are no complete exposure pathways for ground water. However. in order for the remedy to be protective in the long-term. the following actions need to be taken: implement institutional controls. including proprietary controls and well permit restrictions: evaluate supplemental remedial technologies to achieve performance standards: and conduct a survey of private wells in the area of the Site to determine if potential receptors are at risk of exposure.

Other Comments:

Environmental Indicators - Current human exposures at the Site are under control. - Current ground water migration is under control.

Are Necessary Institutional Controls in Place? D All D Some [gI None

Has the Site Been Designated as Site-Wide Ready for Anticipated Use? DYes [gI No

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IlnunlllFive-Year Revuew Report for

Rodk lHIm CHnemnlCal Co. Superfund! Snte

1.0 nnntIrodudiOIlD

The purpose ofa Five-Year Review (FYR) is to evaluate the implementation and performance of a remedy in order to detennine if the remedy will continue to be protective of human health and the environment. The methods, tindings and conclusions of FYRs are documented in FYR reports. In addition, FYR reports identify issues found during the review, if any, and document recommendations to address them.

The United States Environmental Protection Agency (EPA) prepares FYRs pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section 121 and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). CERCLA Section 121 states:

"If the President selects a remedial action that results in any hazardous substances, pollutants, or contaminants remaining at the site, the President shall review such remedial action no less often than each five years after the initiation of such remedial action to assure that human health and the environment are being protected by the remedial action being implemented. In addition, if upon such review it is the judgment of the President that action is appropriate at such site in accordance with section [104] or [106], the President shall take or require such action. The President shall report to the Congress a list of facilities for which such r~view is required, the results of all such reviews, and any actions taken as a result of such reviews."

EPA interpreted this requirement further in the NCP; 40 Code of Federal Regulations (CFR) Section 300.430(t)(4)(ii), which states:

"If a remedial action is selected that results in hazardous substances, pollutants, or contaminants remaining at the site above levels that allow for unlimited use and unrestricted exposure, the lead agency shall review such actions no less often than every five years after the initiation of the selected remedial action."

Skeo Solutions, an EPA Region 4 contractor, conducted the FYR and prepared this report regarding the remedy implemented at the Rock Hill Chemical Co. site (the Site) in Rock Hill, York County, South Carolina. This-FYR was conducted from February to September 2011. EPA is the lead agency for developing and implementing the remedy for the potentially responsible party (PRp)-tinanced cleanup at the Site. The South Carolina Department of Health and Environmental Control (SC DHEC), as the support agency representing the State of South Carolina, has reviewed all supporting documentation and provided input to EPA during the FYR process.

This is the third FYR for the Site. The triggering action for this policy review is the previous FYR. The FYR is required due to the fact that hazardous substances, pollutants or contaminants

9

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remain at the Site above levels that allow for unlimited use and unrestricted exposure. The Site consists of one operable unit (OU), which is addressed in this FYR.

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2.0 Site Chronology

Table 1 lists the dates of important events for the Site.

Table 1: Chronology of Site Events

Event Date Initial discovery January I, 1985 EPA proposed the Site for listing on the National Priorities List (NPL) June 24, 1988 EPA listed the Site on the NPL February 21, 1990 Removal action completed May 3,1990 Remedial investigation/feasibility study (RJ/FS) started September 25, 1991 RifFS completed; Record of Decision (ROD) signed

June 27, 1994

Unilateral Administrative Order signed requiring the PRPs to complete the remedial design and remedial action

February 14, 1995

Remedial design started March 23, 1995 Remedial design completed; Remedial action started

September 19, 1996

Administrative Order on Consent signed November 6, 1996 Construction completed December 18, 1996 Preliminary Close-out Report prepared December 31, 1996 First Five-Year Review (FYR) signed December 14, -2000 Ground water sampled June 1995 - June 2006 Second FYR signed September 29, 2006 Ground water sampled June 2007 Ground water sampled June 2008 Second FYR Addendum Signed September 28, 2008 Ground water sampled June 2009 Ground water sampled June2010

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3.0 Baclkgrm.mdl

3.1 !Physical Chancteristics

The Site is located adjacent to U.S. Highway 211Cherry Road and Farlow Street, just east of Cranford Street in Rock Hill, York County, South Carolina (Figure 1). Rock Hill has a population of71,154 and is part of the Charlotte, North Carolina metropolitan area. The Site lies within a residential and commercial area and covers approximately 4.5 acres. The Site is bounded by Cherry Road and the former Rock Hill Mall to the south; commercial areas to the west; residences and an unnamed stream to the north; and a shopping plaza to the east (Figure 2). Most of the Site is currently vacant and unsecured with the exceptio!). of a ground water extraction well, which is fenced. The foundation of the former chemical company building remains on site. The southern portion of the Site includes a parking lot and check-cashing business. The northern portion of the Site is vegetated, including a woodland with a network of foot paths. Site property parcels are listed in Table 2.

Table 2. Site Property Parcels

Site Parcels 6340000003 6340000107 6340000108 6340000109 6340701044 6340701047 6340701058

Soils at the Site generally consist of sandy, clayey silt, fine sand and silt. The contact between the saprolite and bedrock typically is gradational and is often characterized by a zone of fractured rock material. Geologic mapping of the Rock Hill area indicates that the Site is underlain by unconsolidated soils that consist of a surficial layer of alluvium underlain by saprolite, followed by gabbro. The alluvium ranges in thickness from 5.5 to 9.0 feet and the saprolite ranges in thickness from 3.4 to 22 feet at the Site.

On-site drainage is controlled by topography and man-made drainage features. The Site is drained by an unnamed stream, which originates on the northern portion of the Site. There is another, smaller drainage ditch that intersects the larger unnamed stream. The U1mamed stream receives the majority of surface water from the n-inch storm drain. The origin of surface water that tlows through the 72-inch storm drain includes open land south of the Rock Hill Mall and surface water runoff from the Rock Hill Mall property and Cherry Road. Another 40-inch storm drain also intersects the unnamed stream, in the same area as the 72-inch drain. Water from this smaller drain originates west of the Site. Site runoff and surface water from the drainage ditch also tlow into the unnamed stream. Presently, all surface water that reaches the U1mamed stream flows along its course in a northeasterly direction for 1.9 miles and discharges into the Catawba River. Elevations across the Site vary from 606 feet above mean sea level in the southern and western parts

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of the Site, to 590 feet above mean sea level in the northern portion of the Site. Ground water flow is shown in Appendix F.

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Figure 1: Site Location Map

ock Hill, SC

o 0.25 0.5 1 ...===-___ Miles

n Rock Hill Chem.cal Co. Superfund Site Rock Hill, York County, South Carolina

NORTH

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

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Figure 2: Detailed Site Map

..

THE~KETON ~STREeT

(YORK SHOPPING PlAlA)

o 50 100 200 S Monitoring well - Site boundary....===-......F~ • Pumping well Parcel boundary o Production well Creek A Law engineering well B Abandoned monitoring well

o NORTH

Rock Hill Chemical Co. Superfund Site Rock Hill, York County, South Carolina

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

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3.2 Land and Resource Use

The Site is located in a light commercial and residential area within the City of Rock Hill. Land use in the vicinity of the Site when the ROD was finalized in 1994 was light commercial and residential. Land use has not changed since the ROD was finalized. No projected land use changes were identitied during this FYR.

Ground water at the Site is not used as a source of potable water. Ho\vever, all ground water in South Carolina is considered an underground source of drinking water. The area around the Site is served by the City of Rock Hill's municipal water supply and there are no known ground water users on or near the Site. The last known well survey related to the Site occurred in March 1992. A Speedee Cash check-cashing business operates in the southern portion of the Site. People live on site in a campsite within the wooded area to the north.

3.3 History of Contamination

From 1960 through 1964, the Site was the location of the Rock Hill Chemical Company (RHCC), a facility that distilled paint solvents. Textile dye products were also reportedly recovered from the facility. During its operation, RHCC accepted waste oils and solvents from generators, separated them, and sold the extracted solvents and oils back to the generators. In this operation, waste fluids were reprocessed by separating solvents from the oil phase, filtering the oil through a charcoal filter press, and repackaging the reclaimed oil for distribution to clients. The waste fluids initially were contained in drums. As the process expanded, aboveground storage tanks were added as needed.

Paint sludges, textile dye products, still bottoms, and other wastes generated during the reclamation process were stored in piles that were placed directly onto the ground. In some cases, waste products were buried at the Site. Still bottoms generated from the reclamation process were incorporated into various layers of till dirt and construction debris was used to till low areas of the property to help support heavy machinery. Tanks that were used to hold liquid wastes before reclamation had, on occasion, leaked onto the ground, creating a potential source of contamination. One such leak was caused by a faulty tank valve. Another release occurred when a valve on one of the tanks was deliberately opened by a trespasser, which caused chemicals to spill onto the ground.

By late 1961, the demand by RHCC clients for reclaimed oil diminished and a surplus remained in inventory. Much of this residual inventory was either reprocessed and sold to various customers or consumed by RHCC as fuel for its steam generator until the company ceased operations in 1964. In October 1964, a tire at the facility caused oil and chemical drums to explode, releasing their contents into the environment. After the tire, the RHCC was dissolved. Since that time, no other industrial activity has taken place at the Site.

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3.4 Initial Response

Solid and liquid wastes were disposed of at the Site during RHCC facility operations between 1960 and 1964. In 1984, First Federal Savings Bank began to construct a branch office on the western portion of the Site, on lots that it had purchased in 1972. The bank had not used the property between 1972 and 1984. During construction activities, it was discovered that the property was contaminated. At the time of the 1984 discovery, First Federal Savings Bank promptly notitied SC DHEC and employed consultants to analyze the property and determine the extent of the contamination. Distillation still bottoms, metal drums, and other hazardous substances were found buried beneath the surface of the property. Under the supervision of SC DHEC, First Federal Savings Bank conducted a removal action on its property, which was completed in November 1986. During the 1986 removal action, the previously-contaminated portion of the property was excavated, contaminated soil was deposited in an approved landfill, and the affected portion of First Federal Savings Bank's property was covered by a clay cap. A total of 820 cubic yards of material was excavated during the removal action. In late 1987, EPA's Emergency Response Team used CERCLA funds to remove approximately 46,000 gallons of waste from aboveground tanks, along with an unknown amount of contaminated soil from the eastern portion of the Site. This material was transferred to a Resource Conservation and Recovery Act (RCRA)-regulated facility.

Based upon sampling investigations conducted'before and after these removal actions, EPA proposed the Sit~ for inclusion on the NationalPriorities List (NPL) on June 24, 1988, and EPA finalized the Site on the NPL on February 21, 1990.

3.5 Basis for Taking Action

As part of the Site's 1993 remedial investigation/feasibility study (RIfFS) completed by EPA, a baseline risk assessment (BRA) was conducted to determine the current and future effects of site contaminants on human health. The BRA concluded that the soil removal actions were effective in both eliminating the risk to human health due to exposure from contaminated soils and eliminating contaminated soils as a source of continued ground water contamination. Trichloroethene (TCE), cis- 1 ,2-dichloroethene (DCE), vinyl chloride and manganese were identified as the contaminants of concern (COCs) at the Site. Future ingestion of ground water under a residential land use scenario was the only medi urn posing an unacceptable level of risk to human health or the environment.

The BRA calculated carcinogenic risk and non-carcinogenic Hazard Index ratios for both a current land use scenario, with residents near the Site (site visitor), as well as on-site workers, and a potential future land use scenario (residential). The BRA determined that the total cancer risk for the future site residential scenario was 2.63 x 10-2

, which exceeds EPA's acceptable risk range of 1 x 10-4 to 1 X 10-6

. The non-carcinogenic Hazard Index for the future site residential scenario was 400 for an adult and 950 for a child, both of which exceed the acceptable Hazard Index of 1.0. These carcinogenic and nOll­

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carcinogenic risks are attributable to the ingestion of ground water. The BRA concluded that surface soils, surface water and sediments at the Site are not media of concern.

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4.0 Remedial Actions

In accordance with CERCLA and the NCP, the overriding goals for any remedial action are protection of human health and the environment and compliance with applicable or relevant and appropriate requirements (ARARs). A number of remedial alternatives were considered for the Site, and final selection was made based on an evaluation of each alternative against nine evaluation criteria that are specified in Section 300.430(e)(9)(iii) of the NCP. The nine criteria include:

1. Overall Protectiveness of Human Health and the Environment. 2. Compliance with ARARs. 3. Long-Term Effectiveness and Permanence. 4. Reduction of Toxicity, Mobility or Volume of Contaminants through Treatment. 5. Short-term Effectiveness. 6. Implementability. 7. Cost. 8. State Acceptance. 9. Community Acceptance.

4.1 Remedy Selection

EPA signed the Record of Decision (ROD) for the Site on June 27, 1994. The principal threat identified in the ROD is ground water contamination. The ROD concluded that the actual or threatened releases of hazardous substances from the Site, if not addressed by implementing the selected response action, could present an imminent and substantial endangerment to public welfare or the environment. Remedial action objectives (RAOs) for the Site's cleanup include:

• Reduce to acceptable levels the excess risk to humans and environmental receptors associated with the medium and contaminants of concern at the Site. This will be accomplished by reducing the concentrations of contaminants that result in excess risk to human health and the environment.

• Reduce the potential for ingesting contaminants in the ground water or inhaling volatilized contaminants from the ground water where:

o Carcinogen concentrations are above federal or state standards~ or in the absence of standards, are above levels that would exceed an acceptable cancer risk range of 1 x 10-4 to 1 x 10-6

; and , o Non-carcinogen concentrations are above federal or state standards, or in the

absence of standards, are above levels that would exceed an acceptable Hazard Index of 1.0.

Major components of the selected remedy include:

• Extraction of contaminated ground water. • Direct discharge of extracted ground water to a publicly owned treatment works

(POTW).

19

8

• Deed restrictions. • Long-term ground water monitoring.

Additional work during the remedial design phase, including: determining the relationship of the contamination detected in private wells to the contamination detected in on-site monitoring wells; collecting additional background surface soil samples to contirm that the variance in manganese levels is consistent with the environmental setting; and collecting additional surface water and sediment samples to determine if the selected background sample is representative of background conditions.

The Site's ROD selected a remedy that included extraction of contaminated ground water with direct discharge to a wastewater treatment plant and long-term ground water monitoring. No pretreatment is required prior to discharge to the sewer line. The performance standards selected in the ROD for volatile organic compounds (VOCs) in site ground water were set at the respective maximum contaminant levels (MCLs). For manganese, EPA set a cleanup goal of 0.200 milligrams per liter (mg/L) based on an average background concentration of 0.185 mg/L. The performance standards are shown in Table 3.

Table 3: Ground Water Perfonnance Standards

COC ROD Performance Standard (mg/L)

Basis

TCE 0.005 MCL DCE 0.070 MCL Vinyl chloride 0.002 . MeL Manganese 0.2 Background levels

The ROD also required implementation of institutional controls to prevent the future use of contaminated ground water for purposes such as a potable water supply or irrigation of garden vegetables. Proprietary restrictions were to be written into site property deeds to inform future property owners of the possibility of contaminated ground water beneath their property. Permit restrictions issued by the State of South Carolina would restrict all well drilling pem1its for new wells on the site property that could draw contaminated ground water for potable water use or irrigation of garden vegetabfes.

The ROD required that the following additional fieldwork be conducted during. the remedial design: (1) sampling and analysis of additional background soil samples to confirm that the variance in the previous background manganese concentrations are representative of actual site conditions; (2) sampling and analysis of additional background sediment and surface water samples to confirm that the previous background tetrachloroethene concentrations are representative of actual site conditions; and (3) evaluation of several private wells near the Site. Evaluation of the private wells included additional well sampling and analysis and investigation of the wells' construction characteristics. This evaluation was required to determine if low levels of contamination previously detected in the wells was site-related.

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4.2 Remedy Implementation

In 1995, EPA issued a Unilateral Administrative Order requiring the PRPs to develop and implement the remedial design for the cleanup approach specified in the ROD. Remedial design began in March 1995 and was completed in September 1996. The Site's ground water remedial system began operation in December 1996. Contaminant levels in ground water have been monitored annually since 1995. The institutional controls required by the ROD have not been implemented.

Other construction activities related to the Site's remedial system included: (I) installation of a new manhole to allow discharge of recovered ground water into the City of Rock Hill's sanitary sewer system, through which it would travel to the POTW; (2) installation of a submersible pump into the recovery well; (3) installation of piping, fittings, meters and valves between the recovery well and the new manhole; and (4) installation of instrumentation to allow continuous operation of the system.

The results of the additional fieldwork required by the ROD were as follows:

• The analysis of the additional background soil samples contirmed that the manganese concentrations detected in previous background soil samples are representative of site conditions.

• The analysis of the additional background sedimentand surface water samples confirmed that the tetrachloroethene concentrations detect~d in previous background sediment and surface water samples are not site-related.

" The evaluation of the private wells revealed that there were no site-related contaminants in the private wells.

Ground water at the Site has also been impacted by a former ofT-site gasoline service station covered under the state's underground storage tank trust fund program. In 1996, methyl-tertiary-butyl ether (MTBE), a gasoline constituent, was detected in the sewer discharge analyses. It was concluded that the source of MTBE in the monitoring wells and the recovery well is contaminant migration from the gas station and is not connected with the operations at the RHCC. The annual" ground water samples from the site monitoring wells are analyzed for benzene, ethyl benzene, toluene, xylene and MTBE in

. addition to the site COCs.

During February 2010, the now rate· of the recovery well was reduced to the approximate yield of the aquifer, approximately two-to-four gallons per minute. The lower, nearly continuous flow allows for slow mass desorption, nearly continuous run-time, and increased removal volume.

4.3 Operation and Maintenance (O&M)

O&M activities conducted by the PRP consist primarily of annual ground water sampling. The first sampling event occurred in June 1995 and sampling has taken place in June of every following year until the present. In addition to the annual sampling

21

----~---- ---

events, the discharge from the recovery well into the sanitary sewer system was sampled on a quarterly basis from 1995 until 1999 and on a semi-annual basis from 2000 until the present. Other O&M activities include periodic mowing and routine equipment maintenance and repair.

The ROD estimated that the average annual O&M costs of a one and two extraction well system would be $225,000. Actual annual O&M costs for the single extraction well system from September 2006 through August 2010 averaged approximately $34,000 (Table 4).

Table 4: Annual O&M Costs

Date Range Total Cost (rounded to the nearest $1,000)

912006 ­ 812007 $38,000 9/2007 - 8/2008 $31,000 912008 ­ 8/2009 $34,000 912009 ­ 812010 $31,000 9/2010 - 21201 1 $13,000

22

5.0 Progress Since the Last Five-Year Review

The protectiveness statement from the 2006 FYR for the Site stated:

"A protectiveness determination ofthe remedy at the Rock Hill Chemical Company Site cannot be made at this time untiUzirther iI~formation about the vapor intrusioi1 patlnvay is obtained. The vapor intrusion pathway for both the currently occupied building at the site and the jliture on-site building scenario must be evaluated before a protectiveness determination can be rnade. It is expected that these actions will take approximately 12 months to complete. at 'which time a protectiveness determination will be made.

In addition to evaluating the vapor intrusion pathway for current andfiilure on-site buildings. in order for the remeczv to be protective in the long-term. the following actions need to be taken:

• pel/ormance standards spec(fied in the ROD must be rnet • ICs. as ident(/ied in the RODfor the selected remedy. need to be implemented • on-going ground water monitoring should be continued"

The protectiveness statement from the 2008 FYR Addendum for the Site stated:

. "The remedy at the Rock Hill Chemical Company site protects human health and the environment in the short-term because contaminated ground '\ovateI' is being pumped and treated. I However. in order for the remeczv to be protective in the long-term. the following actions need 10 be taken: institutional controls. deed restrictions and well permit ;·estrictions. need to be implemented, on-going ground water monitoring should continue. and pel:formance standards idenl?fied in EPA's 1994 Record ofDecision (ROD) must be met . ..

The 2006 FYR included nine issues and recommendations. Each recommendation and its current status are discussed below.

Table 5: Progress on Recommendations from the 2006 FYR

Section Recommendations Party

Responsible Milestone

Date Action Taken and Outcome

Date of Action

5.1

The local info~mation repository at the York County Library needs to be updated to include all appropriate site related documents.

EPA 9/30/2007 Completed 9/3012008

5.2

Consideration should be given to incorporating a delay re-start into the operation of the system after the ground water recovers in MW-03 SH.

EPA/PRP 9/3012009 Ongoing 5/30/2009

I The ground water is being extracted and discharged, but treatment is not part of the remedy.

23

Section Recom mendations Part)'

Responsible Milestone

Date Action Taken and Outcome

Date of Action

5.3

The three Law Engineering monitoring wells and one private well located on the Site should be properly abandoned.

EPA/PRP 9/3012009 Not completed NA

5.4

In order to ensure future protectiveness of the Site. the formal implementation of institutional controls should be completed and an institutional controls monitoring plan should be developed that identities the type and frequency of monitoring necessary to ensure the continued effectiveness of the implemented institutional controls.

EPA/SC DHEC

9/3012010 Not completed NA

5.5

The recent trend of the contamination levels in MW-02SH has been increasing. If these contamination levels remain elevated after the annual ground water monitoring in 20 I 0, consideration should be given to investigating the cause of these increased contamination levels.

EPA 9/3012011 Completed 9/30120 II

5.6

Current trends of contaminant removal are beginning to show that performance standards might not be achieved within the 30-year project duration estimated in the ROD. This issue should be evaluated in the next FYR.

EPA/SC DHEC

9/3012013 Not completed NA

5.7 Evaluate the vapor intrusion pathway.

EPA/SC DHEC

9/3012008 Completed 9/2612008

5.1 Update the Information Repository

EPA Region 4 sent relevant site documents to the information repository to be made available to the public.

5.2 Implement Delayed Restart in Pumping System

Additional sampling was performed in May 2009 to determine how quickly, if at all, the organic COCs would rebound if pumping of the aquifer was stopped for an extended period of time. Samples were collected from MW-02SH, MW-03SH, MW-03RKand RW-Ol. Five rounds of samples were collected from each well. The results of the sampling indicated that COC concentrations did not rebound in the monitoring wells. The recovery well coe contaminations exhibited a small, gradually increasing trend.

24

5.3 Abandon Unused Wells atthe Site

The three Law Engineering wells (LW-I, LW-2 and LW-3) have not been properly abandoned. The unused private well has also not been properly abandoned.

5.4 Implement Institutional Controls

No institutional controls have been impleinented at the Site.

5.5 Monitor Contamination Levels in MW-02SH

Ground water is sampled annually from all monitoring wells, included MW-02SH. The annual monitoring reports submitted by the PRP to EPA discuss contaminant trends. The rise in concentrations centered arou~d 2001-2002 was followed by a decrease in contaminant concentrations at MW-02SH.

5.6 Evaluate Whether Performance Standards are Expected to Be Achieved

The likelihood of the current remedy achieving performance standards within the ROD­specified timeframe of 30 .years has not been evaluated since the 2006 FYR.

5.7 Evaluate the Vapor Intrusion Pathway

The vapor intrusion pathway for both the currently occupied building and the future on­site building scenarios were evaluated and described in the 2008 FYR Addendum. Based upon reviews conducted by Region 4 EPA's Technical Services Section, EPA concluded that current levels of TeE in site ground water were well below the threshold for concern regarding vapor intrusion.

25

6.0 Five-Year Review Process

6.1 Administrative Components

EPA Region 4 initiated the FYR in February 2011 and scheduled its completion for 5.eptember 2011. The EPA site review team was led by EPA Remedial Project.Manager (RPM) Robert West and also included EPA site attorney Kim Jones, EPA Community Involvement Coordinator (CIC) Linda Starks, and contractor support provided to EPA by Skeo Solutions. In February 2011, EPA held a scoping call with the review'team to discuss the Site and items of interest as they related to the protectiveness of the remedy currently in place. A review schedule was established that consisted of the following activities:

• Community notification. • Document review. • Data collection and review. • Site inspection. • Local interviews. • FYR Report development and review.

6.2 Community Involvement

In June 2001, a public notice was published in the Herald newspaper aJUlouncing the commencement of the FYR process for the Site, providing contact infonnation for EPA RPM Robert West and crc Linda Starks, and inviting community participation. The press notice is available in Appendix B. No one contacted EPA as a result of this advertisement.

The FYR Report will be made available to the public once it has been finalized. Copies of this document will be placed in the designated site repository: York County Public Library. Upon completion of the FYR, a public notice will be placed in the Herald newspaper to announce the availability of the tinal FYR Report in the Site's document repository.

6.3 Document Review

This FYR included a review of relevant, site-related documents including the ROD, relnedial action reports and recent monitoring data. A complete list of the documents reviewed can be found in Appendix A.

ARARs Review

CERCLA Section 121 (d)(1) requires that Superfund remedial actions attain "a degree of cleanup of hazardous substance, pollutants, and contaminants released into the environment and of control of further release at a minimum which assures protection of human health and the environment." The remedial action must achieve a level of cleanup

26

that at least attains those requirements that are legally applicable or relevant and appropriate. Applicable requirements are those cleanup standards, standards of control, and other substantive requirements, criteria, or limitations promulgated under federal environmental or state environmental or facility siting laws that specifically address a hazardous substance, remedial action, location, or other circumstance found at a CERCLA site. Relevant and appropriate requirements are those standards that, while not "applicable," address problems or situations sufficiently similar to those encountered at the CERCLA site that their use is well suited to the particular site. Only those state standards that are more stringent than federal requirements may be applicable or relevant and appropriate. To-be-considered (TBC) criteria are non-promulgated advisories and guidance that are not legally binding, but should be considered in determining the necessary remedial action. For example, TBC criteria may be particularly useful in determining health-based levels where no ARARs exist or in developing the appropriate method for conducting a remedial action ..

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

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

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

Remedial actions are required to comply with the chemical-specitic ARARs identified in the Site's ROD. In performing the FYR for compliance with ARARs, only those ARARs that address the protectiveness of the Site's remedy are reviewed.

Ground Water ARARs

According to the Site's 1994 ROD, cleanup goals for the four ground water COCs were based on federal SDWA National and Primary and Secondary Drinking Water Standards, South Carolina Water Classifications and Standards, South Carolina Well Standards and Regulations, and South Carolina Primary Drinking Water Regulations. ARARs from the 1994 ROD were compared to current SDWA and South Carolina standards (Table 6). ARARs for TCE, DCE and vinyl chloride have not changed. No chemical-specific ARAR was identified in the ROD for manganese and no primary MCL has been promulgated. .

27

Table 6: Previous and Current ARARs for Ground Water COCs

COC 1994 ROD

ARARs (mg/L) Current"b

ARARs (mg/L) ARARs Change

TCE 0.005 0.005 None DCEc 0.070 0.070 None Vinyl Chloride 0.002 0.002 None Manganese NAd NAe NA

a. South Carolina Primary Drinking Water Regulation are available at: httpJ/www.SC CI:l:ECIIl!ll!~GDlr!itllDDl'DIimII;[~[n~~[,61-~a~~ 1-~8,l:!slC (last accessed 411 / 11 ).

b. National Primary Drinking Water Regulations and National Secondary Drinking Water Regulations are available at: bl112;llww:n:,;lIl1ll1glr!l.slf~:n:It;rLligDllIIDiDBDt!iliDsl~lIlb!J:D( (last accessed 411/11).

c. Ground water samples wcre analyzed for 1,2 dichloroethene (total). The MCL for cis- I,2 dichlorocthene was used because it i more conservative than the trans- I.2 dichloroethene MCL. Dichloroethene i also known as dichloroethylene.

d. The ROD did not identify a chemical-specific ARAR for manganesc. EPA set a cleanup goal of 0.200 mg/L based on an average background concentration of 0.185 mgIL.

e. There is no primary MCL for manoanese.

6.4 Data Review

Ground Water

This FYR reviewed results from the annual ground water monitoring that was conducted at the Site during June from 2006 through 2010. Six monitoring well pairs, each of which has a saprolite monitoring well (MW-SH designations) and a shallow bedrock monitoring well (MW-RK designations), are annually monitored. The recovery well (RW-01) was turned off for one week prior to each sampling event. Three wells were sampled multiple times in May and June 2009 as part of the desorption study. Ground water maps are included in Appendix F and contaminant trends are included in Appendix G.

Ground water samples were analyzed for site COCs: TCE, DCE, vinyl chloride, and total manganese, as well as the gasoline components benzene, toluene, ethylbenzene, total xylenes and MTBE. The gasoline components are not site COCs, but are included in the annual monitoring. Ground water at the Site has also been impacted by a former off-site gasoline service station covered under the state's underground storage tank trust fund program.

VOCs

In the past five years, VOC concentrations have exceeded performance standards in MW-2SH, MW-03SH and MW-03RK (Table 7). MW-2SH is located upgradient of the recovery well and MW-03SH and MW-03RK are located adjacent to the recovery well. VOC concentrations did not exceed performance standards in any ofthe other seven monitoring wells. No VOCs have beeD: detected in the nearest downgradient monitoring well, MW-04SH, since 1999.

TCE and vinyl chloride concentrations in MW-2SH declined in the past five years, but were above the performance standard in all sampling events. DCE in MW-2SH has not exceeded the performance standard since 2009. VOC concentrations in MW-3SH have

28

significantly decreased since 1995. TCE concentrations in MW-3SH fluctuated in the past five years and remain above the perfom1ance standard. DCE and vinyl chloride in MW-3SH were below the performance standard in each of the past five annual sampling events. Concentrations ofYOCs in MW-3RK were generally above the performance standards in each of the past five years and increased slightly during the most recent sampling event.

i\,fanganese

Manganese was detected above the performance standard in MW-2SH, MW-3SH, MW­4SH, MW-6SH and MW-8SH (Table 7). Manganese concentrations were consistently above the performance standard in MW-2SH, MW-4SH and MW-6SH. Concentrations in MW-2SH and MW-6SH have been stable and concentrations in MW-4SH have declined in the past tive years. Elevated manganese concentrations in ground water might be attributable to natural conditions.

Gasoline Constitllents

The gasoline constituents benzene, toluene, ethyl benzene, total xylenes and MTBE are not site COCs but are included in annual ground water monitoring at the Site. The source of gasoline contamination was determined to be a gasoline station located across Cherry Road. In recognition of this additional source of ground water contamination,the annual

. ground water samples from the site monitoring wells are analyzed for benzene, ethyl benzene, toluene, xylene and MTBE, in addition to the site COCs. There are no perfonnance standards for the gasoline constituents associated with the Site. Of the gasoline constituents, only MTBE is consistently detected on site, in MW-J RW, MW­2RK, MW-3RK, MW-4SH, MW-6SH, MW-6RK, MW-8SH·and MW-8RK (Table 7). Concentrations in MW-2RK, MW-4SH, MW-6SH and MW-8SH have increased in the past tive years.

Table 7. Ground Water Monitoring Data for 2006-2010

TCE (mg/L)

cis-I,2-DCE (mg/L)

Vinyl Chloride (mg/L)

Total Manganese

(mg/L)

MTBE (mg/L)

Performance Standards 0.005 0.070 0.002 0.2 NA Sample

Location Sample Date

MW-02SH Jun-06 0.065 0.120 0.0087 0.770 <0.001 Jun-07 0.066 0.160 0.0094 0.600 <0.0023 Jun-08 0.032 0.081 0.0047 0.752 <0.0023

May-09a 0.0198 0.073 0.0050 0.740 <0.001 May-09" 0.0169 0.0592 0.0040 0.736 <0.001 May-09' 0.0171 0.0595 0.0039 0.728 <0.001 Jun-09" 0.0140 0.0555 0.0035 0.581 <0.001

Jun-09a (D) 0.0145 0.0565 0.0038 0.630 <0.001 , Jun-09" 0.0166 0.0674 0.0041 0.657 <0.001

Jun-IO 0.0101 0.0583 0.0037 0.767 <0.001 MW-02RK Jun-06 <0.001 <0.001 <0.001 0.15 0.0021

29

TCE cis-I,2-DCE Vinyl Chloride Total

MTBEManganese

(mg/L) (mg/L) (mg/L) (mg/L)

(mg/L)

Performance Standards 0.005 0.070 0.002 0.2 NA Sample

Sample Date Location

Jun-07 <0.0026 <0.0017 <0.0012 0.12 0.0026J Jun-08 <0.001 <0.001 <0.001 . 0.132 0.0043 Jun-09 <0.001 <0.001 <0.001 0.117 0.0041 Jun-IO <0.001 <0.001 <0.001 0.126 0.0041 Jun-06 0.0089 0.0076 <0.001 0.059 0.0010

MW-03SH Jun-07 0.022 0.0097 <0.0012 0.0021 J <0.0023

Jun-08 0.0594 0.0355 <0.0012 0.0094 0.0015

Jun-08 (0) 0.0543 0.0321 <0.0012 <0.005 0.0014

May-09" 0.0013 <0.001 <0.001 0.131 <0.001

May-09" 0.0027 0.0016 <0.001 0.034 <0.001

May-09" 0.0042 0.0030 <0.001 0.0282 <0.001

Jun-09" 0.0184 0.0139 <0.001 0.0081 <0.001 Jun-09:I 0.0032 <0.001 <0.001 0.365 <0.001

Jun-IO 0.0067 0.0035 <0.001 0.0436 <o.ooi

Jun-06 0.170 0.290 0.0029 0.11 0.016 MW-03RK Jun-06 (0) 0.170 0.380 0.0031 0.12 0.016

Jun-07 0.270 0.360 0.002J 0.13 0.016

Jun-08 0.147 0.390 0.0013 0.100 0.0132

May-09" 0.191 0.219 0.002 0.090 0.0089

May-09a 0.355 0.226 0.0028 0.089 0.0092

May-09" 0.492 0.246 0.0035 0.091 0.0103

Jun-09" 0.173 0.204 0.0021 0.085 0.0127

Jun-09" 0.199 0.386 0.0026 0.089 0.0128

Jun-IO 0.324 0.358 0.0025 0.085 0.0094

MW-04SH Jun-06 <0.001 <0.001 <0.001 1.80 0.0056

Jun-06 <0.001 <0.001 <0.001 1.90 0.0058

Jun-07 <0.0026 <0.0017 <0.0012 1.50 0.0073

Jun-08 0.0014 <0.001 <0.001 1.53 0.012

Jun-08 (0) <0.001 <0.001 <0.001 NA NA Jun-09 <0.001 <0.001 <0.001 1.32 0.013

Jun-IO <0.001 <0.001 <0.001 1.34 0.013

MW-04RK Jun-06 <0.001 <0.001 <0.001 0.024 <0.001

Jun-07 <0.0026 <0.0017 <0.0012 0.022 <0.0012

Jun-08 0.0013 <0.001 <0.001 0.021 <0.001

Jun-08 (0) <0.001 <0.001 <0.001 NA NA.

Jun-09 <0.001 <0.001 <0.001 0.018 <0.001

Jun-IO <0.001 <0.001 <0.001 0.018 <0.001

MW-06SH Jun-06 <0.001 <0.001 <0.001 0.40 0.0039

Jun-07 <0.0026 <0.0017 <0.0012 0.46 0.00411

Jun-08 <0.001 <0.001 <0.001 0.43 0.0059

Jun-09 <0.001 <0.001 <0.001 0.55 0.0078

Jun-IO <0.001 <0.001 <0.001 0.38 0.0084

MW-06RK ·Jun-06 <0.001 <0.001 <0.001 0.18 0.024

30

TCE cis-],2-DCE Vinyl Chloride Total

MTBEManganese

(mg/L) (mg/L) (mg/L) (mg/L) (mg/L)

Performance Standards 0.005 0.070 0.002 0.2 NA Sample

Sample DateLocation

Jun-07 <0.0026 <0.0017 <0.0012 0.094 0.021 Jun-OS <0.001 <0.001 <0.001 0.0976 0.024 Jun-09 <0.001 <0.001 <0.001 0.102 0.022 Jun-IO <0.001 <0.001 <0.001 0.126 0.021

MW-08SH Jun-06 <0.001 <0.001 <0.001 0.24 0.017 Jun-07 <0.0026 <0.0017 <0.0012 0.OS4 0.024 Jun-OS <0.001 <0.001 <0.001 0.173 0.029 Jun-09 <0.001 <0.001 <0.001 0.09S 0.032 Jun-l0 <0.001 <0.001 <0.001 0.OS2 0.033

MW-08RK Jun-06 <0.001 <0.001 <0.001 0.05S 0.033 lun-07 <0.0026 <0.00l7 <0.0012 0.020 0.041 Jun-OS <0.001 <0.001 <0.001 0.023 0.039 Jun-09 <0.001 <0.001 <0.001 0.029 0.04S Jun-IO <0.001 <0.001 <0.001 0.025 0.040

Dec-05b 0.062 0.041 <0.005 0.32 0.016 RW-Ol lun-06 0.065 0.055 <0.001 O.IS 0.015

Jun-06c 0.077 0.069 0.0019 0.79 0.015 Dec-06b 0.048 0.037 <0.005 0.19 0.014

Jun-07b b 0.067 0.036 <0.001 0.23 0.015 Jun-07c 0.058 0.056 O.OO13J 0.23 0.013 Dec-07b 0.104 0.092 <0.001 0.192 0.0149 Jun-OSb 0.0561 0.0427 <0.001 0.173 0.0062 Jun-OSc 0.0852 0.0727 0.0011 0.222 0.0099 May-09' 0.047 0.0347 <0.001 0.286 0.00S8 May-09a 0.0524 0.0376 <0.001 0.352 0.00S7 May-09a 0.0547 0.0427 <0.001 0.209 0.0064 Jun-09" 0.0733 0.0719 0.0015 0.294 0.00S6 Jun-09a 0.151 0.151 0.0029 0.360 0.0070 Jun-10b 0.0937 0.0463 <0.001 0.430 0.0093 Jun-lOc 0.]46 0.12 0.0019 0.445 0.0061

Concentrations that exceed the performance standard are shaded and in bold . "J" indicates an estimated value. Result is below the laboratory reporting limit, but above the method detection limit. ".0,. indicates a duplicate sample. a. Samples collected with pump on, a few hours after pumping stopped, one day after pumping stopped, one week after pumping stopped, and one month after pumping stopped. b. Results of analyses for the Rock Hill Se~er Authority. Samples were collected on discharge of pump at sample port inside the well housing. Samples were collected during operation of the recovery system. The system was not shut off to stabilize before sampling. c. Recovery well sample collected at the time of the annual sample. Pump had been on for a period before sample collection.

31

6.5 Site Inspection

The site inspection was conducted on March 24, 2011. Attendees included EPA RPM Robert West; EPA CIC Linda Starks; Greg Cassidy ofSC DHEC; Kathryn Webb and Richard Jacobs, O&M contractor staff for the PRP; and Johnny Zimmerman-Ward and Ryan Burdge of Skeo Solutions.

The pump system is fenced and secured and all monitoring wells were secured and labeled. The Law Engineering wells were still present and not yet abandoned. The former pumping well could not be located. Litter was found throughout the Site, including several areas with larger dump piles. Several footpaths are used by local citizens and homeless persons are living in tents on site. These activities have not caused any visible disturbances. No significant issues were noted.

On March 24, 2011, Skeo Solutions staff visited the designated site repository, York County Public Library, to review site-related documents available to the public. Library staff stated that site-related documents had been received, but no documents could be located by library staff. Site documents will be sent to the library.

Skeo Solutions staff conducted research at the York County Public Records Office and found the property deed information pertaining to the Site listed in Table 8.

Table 8: Deed Documents from York County Public Records Office

Date Type of

Document Description Book # Page #

9/13/2004 Property Deed Property Deed for parcel number 6340701058.

6545 42

8/12/1997 Property Deed Property deed for parcel number 6340701047.

1949 45

The ROD required implementation of institutional controls to prevent the future use of contaminated ground water fOr"purposes such as a potable water supply or irrigation of garden vegetables, but institutional controls have not yet been implemented. Proprietary restrictions were to be written into site property deeds to inform future property owners of the possibility of contaminated ground water beneath their property. Permit restrictions issued by the State of South Carolina would restrict all well drilling permits for new wells on the site property that could draw contaminated ground water for potable water use or irrigation of garden vegetables. Table 9 lists the status of institutional controls associated with areas of interest at the Site. Figure 3 displays the area parcels.

32

Table 9: Institutional Control Summary Table

Media lCs

Needed

ICs CaUed for in the Decision

Documents

Impacted Parcel(s)

IC Objective

Instrument in Place

Ground Water

Yes Yes

6340000107 6340000108 6340000109 6340701047 6340701058

Proprietary restrictions were to be written into site property deeds to inform future property owners of the possibility of contaminated ground water beneath their property.

None

33

Figure 3: Institutional Control Base Map

"

63040000111 6340000003

6340000108

6340000107

- Site boundary _ •• Parcel boundary

o 50 100 200 ....===-......F_

NORTH

Rock HI! Chemical Co. Superfund Site Rock Hili, York County, South Carolina

Disclaimer: This map and any boundary lines within the map are approximate and subject lo change. The map is not a survey. The map is for informational purposes only regarding EPA's response aClions al the Site. and is not intended for any other purpose.

34

6.6 Interviews

During the FYR process, interviews were conducted with parties impacted by the Site, including the current landowners, and regulatory agencies involved in site activities or aware of the Site. The purpose of the interviews was to document the perceived status of the Site and any perceived problems or successes with the phases of the remedy that have been implemented to date. All of the interviews were conducted during the site inspection on March 24, 2001. Interviews are summarized below and complete interview summaries are included in Appendix C.

Mr. Greg Cassidy: Mr. Greg Cassidy is an Environmental Engineer with SC DHEC. Mr. Cassidy believes that the remedy is functioning as intended and that everything is going as expected. He noted that although there are trespassers living on site, they have not harmed the treatment system or monitoring wells.

Ms. Kathy Webb and Mr. Richard Jacobs: Ms. Webb, Principal, and Mr. Jacobs, Project Manager, are with Synterra Corporation, the O&M contractor for site PRPs. They believe that the remedy is functioning well and that the current elevated contaminant levels are close to the performance standards. They reported that there have not been any issues with O&M activities at the Site.

Mr. Steve Turner: Mr. Turner works for the City of Rock Hill . He is very knowledgeable about the Site and knows its history. He stated the City has not received any complaints about the Site. As far as he knows, the remedy remains protect of human health and environment.

Resident 1: Resident 1 knows nothing about the site. He is currently renting the property.

Resident 2: Resident 2 have lived near the Site for four years and knows nothing about the Site.

35

7.0 Technical Assessment

7.1 Question A: Is the remedy functioning as intended by the decision documents?

The pump and discharge remedy is functioning as intended by the Site's ROD. Ground water contamination has been contained and contaminant concentrations have declined. No VOCs have been detected in the downgradient monitoring wells since 1999. Ground water is pumped and discharged to a POTW for treatment.

TCE, DCE and vinyl chloride concentrations have declined but remain above performance standards in three monitoring wells and the recovery well. Manganese concentrations remain elevated above the performance standard in five monitoring wells. Typically, ground water concentrations in a pump-and-treat system approach a steady­state condition due to the rate of desorption of contaminants approaching the mass removal rate. Statistical analyses conducted in prior years by the PRP and included in annual monitoring reports indicate that organic COC concentrations may have reached steady-state or asymptotic conditions.

Additional measures to improve removal efficiency are being considered. Alternatives such as extending the pump-off cycle for longer durations to allow for mass desorption and monitored natural attenuation were discussed with EPA during 2008 and 2009. In June 2009, a desorption study in the vicinity ofRW-l was conducted. During the study, RW-l showed a concentration rebound after pumping stopped and MW-03RK also showed some concentration responses to stopping pumping at R W -1 . Rebound was not apparent at other wells. Implementation of supplemental technologies is anticipated to attain performance standards. The PRPs have proposed a work plan, which is currently under review by EPA.

The institutional controls called for in the Site's ROD have not yet been implemented. The ROD called for institutional controls to prevent future use of contaminated ground water. Proprietary restrictions were to be written into site property deeds to inform future property owners of the possibility of contaminated ground water beneath their property. Permit restrictions issued by the State of South Carolina would restrict all well drilling permits for new wells on the site property that could draw contaminated ground water for potable water use or irrigation of garden vegetables. There are currently no known ground water users at the Site, but a private well survey has not been conducted since 1992. Institutional controls were called for in the ROD and are needed to ensure the long­term protectiveness of the Site's remedy. Four wells remain on site that were to be properly abandoned.

36

7.2 Question B: Are the exposure assumptions, toxicity data, cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid?

The exposure assumptions used at the time of remedy selection are still valid. The results of the BRA concluded that the only medium of concern was the ground water, and that the contaminants of concern were TCE, 1,2-dichloroethene, vinyl chloride and manganese. The following future use scenario exposure assumptions were used in the BRA: for exposure to the non-carcinogens by an adult resident, it was assumed that the adult resident would ingest two liters per day of ground water for a 24 year period. It was assumed that a child would be exposed for six years and would only consume 1 liter per day of water. For carcinogens, the time period used was seventy (70) years. An inhalation rate of 0.83 cubic meters per hour was assumed for al5-rninute shower duration.

Contaminated ground water is confined on site and is not used as a potable water source . . As at the time of the BRA, the land use is currently commercial and there remains 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 future use was considered in the BRA.

The toxicity data for all four COCs have been updated since the BRA. The changes to TCE, 1,2-DCE and vinyl chloride would not call into question the protectiveness of the remedy since the RAOs for ground water were based on the MCLs, which have not changed. The cleanup goal of 200 IlgIL for manganese was based on the average background concentration. Toxicity data for manganese was updated in 1996 and the current regional screening level for manganese is 880 ~ A review of the manganese cleanup goal is needed to determine if the cleanup goal remains valid. The RAOs (see section 4.1) used at the time of the ROD are still valid.

Gasoline constituents are present on site, notably MTBE. The source of contamination is a gas station across Cherry Avenue and is being addressed under the SC DHEC leaking underground storage tank program. No cleanup levels have been set for these contaminants and they have not been evaluated for risk to human health. MTBE contamination from a nearby gas station is present in most wells and concentrations have increased in four wells in the past five years. However, there are no ground water users in the area and institutional controls restricting ground water use are to be added to property deeds.

The vapor intrusion pathway was evaluated by EPA and SC DHEC in 2008. SC DHEC' s risk analysis determined that a concentration of 6.86 mgIL ofTCE in ground water equates to 1 x 10-5 excess cancer risk. From the Site's 2007 Annual Monitoring Report, the highest level ofTCE in ground water at the Site is 0.270 mg/L. Based on these calculations, the level of TCE at the Site is well below the health-based level of concern for the vapor intrusion exposure pathway. Although a higher concentration was detected in 2009 (0.492 mg/L), it was still significantly lower than the concentration (6.86 mg/L) that would equate to a 1 x 10-5 excess cancer risk.

37

L--______________________________________________________________. ___________________________ _

7.3 Question C: Has any other information come to light that could call into question the protectiveness of the remedy?

No

7.4 Technical Assessment Summary

The remedy is functioning as intended. Ground water contamination has been contained and contaminant concentrations have declined since the remedy was implemented. No VOCs have been detected in downgradient monitoring wells since 1999. Contamination remains in site ground water and additional remedial action might be needed to attain performance standards. MTBE contamination from an outside source is present in most wells and concentrations have increased in four wells in the past five years. There are currently no known ground water users in the area, but the institutional controls called for in the ROD have not yet been implemented and the last well survey was conducted in 1992. Institutional controls are needed to ensure that future use of ground water is restricted. Four wells remain on site that should be properly abandoned. The toxicity data for manganese has changed and the cleanup level for manganese, based on the average background concentration may no longer be valid. All other exposure assumptions, toxicity data, cleanup levels and RAOs used at the time of remedy selection are still valid. In 2008, EPA evaluated the vapor intrusion pathway and determined that contaminant concentrations in ground water were well below the threshold for concern with vapor intrusion.

38

8.0 issues

Table 10 summarizes current site issues.

'fable 10: Current Site llssues

Issue Affects Current Protectiveness

(Yes or No)

Affects Future Protectiveness

(Yes or No) Removal of ground water contaminants has slowed and may have reached asymptotic levels.

No Yes

A well survey has not been conducted since 1992. No Yes MTBE from an off-site source is present in most monitoring wells and concentrations have increased in four wells in the past five years.

No No

The three Law Engineering monitoring wells and one private well located on site have not been properly abandoned.

No No

Institutional controls called for in the ROD have not been implemented.

No Yes

39

9.0 Recommendations and Fonow~u.p Actions

Table 11 provides recommendations to address the CUlTent site issues.

Table 11: Recommendations to Address Current Site issues

Issue Recommendations I Follow-Up Actions

Party Responsible

Oversight Agency

Milestone Date

Affects Protectiveness?

(Yes or No) Current Future

Removal of ground water contaminants has slowed and may have reached asymptotic levels.

Evaluate contaminant trends and identify and implement supplemental remedial technologies, as needed.

PRP EPA 09/3012012 No Yes

A well survey has not been conducted since 1992.

Conduct a well survey to determine if potential receptors are at risk of exposure.

PRP EPA 09/3012012 No Yes

MTBE from an (lff­site source is present in most monitoring wells and concentratio ns ha ve increased in four wells in the past five years.

Notify SC DHEC of the MTBE contamination in on site monitoring wells.

SCDHEC SC DHEC 09/3012012 No No

The three Law Engineering monitoring wells and one private well located on the Site have not been properly abandoned.

Properly abandon the unused wells.

PRP EPA 09/3012012 No No

Institutional controls called for in the ROD have not been implemented.

Implement institutional controls as required in the ROD.

PRP EPA 09/3012012 No Yes

40

10.0 Protectiveness Statement

The remedy at the Site currently protects human health and the environment in the short-term because contaminated ground water is beiJlg pumped and treated and there are no complete exposure pathways for ground water. However, in order for the remedy to be protective in the long-term, the following actions need to be taken: implement institutional controls, including proprietary controls and well permit restrictions; evaluate supplemental remedial technologies to achieve performance standards; and conduct a survey of private wells in the area of the Site to determine if potential receptors are at risk of exposure.

41

11.0 Next Review

The Site is a policy site that requires ongoing FYRs as long as waste is left on site that does not allow for unrestricted use and unlimited exposure. The next FYR will be due within five years of the signature/approval date of this FYR.

42

Appendix A: List of Documents Reviewed

Record of Decision, Summary of Remedial Alternative Selection, Rutledge Property Superfund Site; Rock Hill, York County, South Carolina, 1994.

2006 Annual Monitoring Report, The Rutledge Property Superfund Site, North Cherry Road, Rock Hill, South Carolina, September 2006.

2007 Annual Monitoring Report, The Rutledge Property Superfund Site, North Cherry Road, Rock Hill, South Carolina, September 2007.

2008 Annual Monitoring Report, The Rutledge Property Superfund Site, North Cherry Road, Rock Hill, South Carolina, September 2008.

2009 Annual Monitoring Report, The Rutledge Property Superfund Site, North Cherry Road, Rock Hill, South Carolina, September 2009.

2010 Annual Monitoring Report, The Rutledge Property Superfund Site, North Cherry Road, Rock Hill, South Carolina, September 2010.

First Five-Year Review Report (Type 1) Rock Hill Chemical Co. Site, Rock Hill, South Carolina; EPA ID#SCD980844005, December 2000.

Second Five-Year Review Report (Type 1) Rock Hill Chemical Co. Site, Rock Hill, South Carolina; EPA ID#SCD980844005, September 2006.

Addendum to the Second Five-Year Review Report (Type 1) Rock Hill Chemical Co. Site, Rock Hill, South Carolina; EPA ID#SCD980844005, September 2008.

A-I

Appendix B: Press Notice

U. S. Environmental Protection Agency, Region 4 Announces a Five-Year Review for

The Rock Hill Chemical Co. Superfund Site, Rock Hill, York County, South Carolina

Purpose/Objective: The U.S. Environmental Protection Agency (EPA) is conducting a Five­Year Review of the remedy for the Rock Hill Chemical Co. Superfund site (the Site) in Rock Hill, South' Carolina. The purpose of the Five-Year Review is to ensure that the selected cleanup action effectively protects human health and the environment.

Site Background: The 4.5-acre Site is located within the City of Rock Hill in York County, South Carolina. From 1960 through 1964, the Rock Hill Chemical Company operated at the Site. Operations included distillation of paint solvents and textile dye products were reportedly recovered. Paint sludges, textile dye products, still bottoms, and other wastes generated during the reclamation process were stored in piles placed directly onto the ground and buried at the Site. The company ceased operations late in 1964.

First Federal Savings Bank bought a portion of the property in 1972 and in 1984 began to construct a branch office on the property. During construction activities, it was discovered that the property was contaminated. Removal actions were conducted to address soil contamination in 1986 and 1987. Follow-up sampling determined that the contaminated soils were successfully removed and no further cleanup action for soils was necessary. The Site' s principal threat is ground water contamination. Contaminants of concern in ground water include trichloroethene, 1 ,2-dichloroethene, vinyl chloride, and manganese. The Site was proposed to the National Priorities List (NPL) in June 1988 and listed in February 1990.

Cleanup Actions: A Record of Decision (ROD) for the Site was signed in June 1994 and included the cleanup plan for ground water. Major components of the cleanup approach included extraction of contaminated ground water, direct discharge of extracted ground water to a city-owned wastewater treatment facility, deed restrictions, long-term ground water monitoring, and additional field work during the cleanup design phase, including analysis of private wells and monitoring wells and sampling of surface water, sediments, and soil. The ground water treatment system began operation in December 1995.

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Five-Year Review Schedule: The National Contingency Plan requires that remedial actions that result in any hazardous substances, pollutants, or contaminants remaining at the Site above levels that allow for unlimited use and unrestricted exposure be reviewed every five years to ensure the protection of human health and the environment. The third of these Five-Year Reviews for the Site will be completed by August 2011.

EPA invites community participation in the Five-Year Review process: EPA is conducting the Five-Year Reviews to evaluate the effectiveness of the Site remedy and to ensure that the remedy remains protective of human health and the environment. As part of the Five-Year Review process, EPA staff are available to answer any questions about the Site. Community members who have questions about the Site or the Five-Year Review process, or who would like to participate in a community interview, are asked to contact:

Robert West, Remedial Project Manager Linda Starks, Community Involvement Coordinator Phone: 404-562-8921 Phone: 1-800-564-7577 (Toll Free) E-mail: west.robert@epa.gov E-mail: starks.linda@epa.gov

Mailing Address: EPA Region 4 61 Forsyth St. S.W. Atlanta, GA 30303-8960

Site information is also available at the local document repository, located at the York County Library, 138 East Black Street, Rock Hill, South Carolina 29730, and online at http://www.epa.gov/region4/waste/npl/nplsc/rockhisc.htm.

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

Appendix C: Interview Forms

Rock Hill Chemical Co. Superfund Site Five-Year Review Interview Form Site Name: Rock Hill Chemical Co. EPA ID No.: SCD98084400S Interviewer Name: Johnny Zimmerman- Affiliation: Skeo Solutions

Ward SUbject Name: Greg Cassidy Affiliation: SCDHEC Subject Contact Information: cassidgara>dhec.sc.gov Time: 10:30AM Date: March 24,2011 Interview Location:· Site

Interview Format (circle one): In Person Phone Mail Other:

Interview Category: State Agency

1. What is your overall impression of the project; including cleanup, maintenance, and reuse activities (as appropriate)? I think we are in a good position, the Site appears to be running well and we're into long­term O&M.

2. What is your assessment of the current performance of the remedy in place at the Site? The Site seems to be hanging steady, but overall is performing well.

3. Are you aware of any complaints or inquiries regarding site-related environmental issues or remedial activities from residents in the past five years? We do not hear anything about the Site.

4. Has your oftice conducted any site-related activities or communications in the past five years? If so, please describe the purpose and results of these activities. None other than O&M activities.

5. Are you aware of any changes to state laws that might affect the protectiveness of the Site's remedy? None.

6. Are you comfortable with the status of the institutional controls at the Site? If not, what are the associated outstanding issues? The wells are in good shape and locked. There are people living on the Site, but they don't harm the treatment system or wells. ICs may not be necessary.

7. Are you aware of any changes in projected land use(s) at the Site? Currently I don't know of any planned use, but the Site is located in an area of potential redevelopment.

8. Do you have any comments, suggestions or recommendations regarding the management or operation of the Site's remedy? Overall I have been happy with the Site's operation.

C-I

Rock Hill Chemical Co. Superfund Site Five-Year Review Interview Form Site Name: Rock Hill Chemical Co. EPA ID No.: SCD98084400S Interviewer Name: Ryan Burdge AffIliation: Skeo Solutions Subject Name: Kathv Webb and Affiliation: Synterra

Richard Jacobs Subject Contact Information: Time: 10:30 am Date: 3/2412011 Interview Location: Site

Interview Format (circle one): In Person Phone Mail Other:

Interview Category: O&M Contractor

1. What is your overall impression of the proj ect; including cleanup, maintenance, and reuse acti vities (as appropriate)? Implementation has been straightforward and there is not much maintenance. The system is monitored remotely from the office. Contaminant concentrations are near the cleanup goals.

2. What is your assessment of the current performance of the remedy in place at the Site? It is doing what it was designed to do. The plume is contained and there have been substantial decreases.

3. What are the findings from the monitoring data? What are the key trends in contaminant levels that are being documented over time at the Site? There have been substantial decreases over time, but concentrations are approaching asymptotic levels. A proposed work plan is underway.

4. Is there a continuous on-site O&M presence? If so, please describe staff responsibilities and activities. Alternatively, please describe staff responsibilities and the frequency of site inspections and activities if there is not a continuous on-site O&M presence. The data are downloaded daily. The Site is visited monthly and also if a problem is detected. The property is mowed to allow access to monitoring wells.

5. Have there been any significant changes in site O&M requirements, maintenance schedules or sampling routines since start-up or in the last five years? If so, do they affect the protectiveness or effectiveness of the remedy? Please describe changes and impacts. No.

6. Have there been unexpected O&M difficulties or costs at the Site since start-up or in the last five years? If so, please provide details. The flow meters were serviced.

7. Have there been opportunities to optimize O&M activities or sampling efforts? Please describe changes and any resulting or desired cost savings or improved efficiencies. A delayed restart to allow saturation of the saprolite aquifer has been effective at reducing

C-2

the contaminant concentrations.

8. Do you have any comments, suggestions or recommendations regarding O&M activities and schedules at the Site? No.

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

Rock Hill Chemical Co. Superfund Site Five-Year Review Interview Form Site Name: Rock Hill Chemical Co. Interviewer Name: Linda Starks Subject Name: Resident 1 Subject Contact Information: Time: 10:30 am Interview Location: Resident Home

Interview Format (circle one): In Person

EPA ID No.: SCD980844005 AffIliation: EPA Region 4 AffIliation: Resident

Date: 3/24/2011

Phone Mail Other:

Interview Category: Resident

1. What is your overall impression of the remedial activities at the Site? Has only lived there for 4 years.

2. What effect has this site had on the surrounding community, if any? None.

3. How well do you believe the remedy currently in place is performing? None.

4. Are you aware of any complaints or inquiries regarding environmental issues or the remedial action from residents since implementation of the cleanup? Not applicable (N/A).

5. Are you comfortable with the status of the institutional controls at the Site? If no, what do you see as the outstanding issues? N/A

6. Do you feel well informed about the Site's activities and progress? If not, what other methods ofconveying information should EPA use? N/A

7. Do you have any comments, suggestions, or recommendations regarding the Site's management or operation? None.

'-----------------------­

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Rock Hill Chemical Co. Superfund Site Site Name: Rock Hill Chemical Co.

Five-Year Review Interview Form EPA ID No.: SCD980844005

Interviewer Name: Linda Starks Subject Name: Resident 2 Subject Contact Information: Time: 10:45 am Interview Location: Resident Home

AffIliation: AffIliation:

EPA Region 4 Resident

Date: 3/24/2011

Interview Format (circle one): In Person Phone Mail Other:

Interview Category: Resident

1. What is your overall impression of the remedial activities at the Site? Has lived there for two years but is renting.

2. What effe.ct has this site had on the surrounding community, if any? None.

3. How well do you believe the remedy currently in place is performing? None.

4. Are you aware of any complaints or inquiries regarding environmental issues or the remedial action from residents since implementation of the cleanup? N/A.

5. Are you comfortable with the status of the institutional controls at the Site? lfno, what do you see as the outstanding issues? N/A.

6. Do you feel well informed about the Site s activities and progress? If not, what other methods of conveying information should EPA use? N/A.

7. Do you have any comments, suggestions, or recommendations regarding the Site's management or operation? None.

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Appendix D: Site Inspection Checklist

FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST

l. SHE INFORMATION

Site name: Rock HiJJ Chemical Co. Date of inspection: 3/24/20]]

Location and Region: Region 4 EPA ID: SCD98084400S

Agency, office or company leading the Five-Year Review: EPA Region 4

Weather/temperature: 6S degrees, Sunny

Remedy Includes : (Check all that apply) D Landfill cover/containment o Monitored natural attenuation o Access controls o Ground water containment ~ Institutional controls o Vertical barrier walls ~ Ground water pump and treatment o Surface water collection and treatment o Other

Attachments: o Inspection team roster attached o Site map attached

II. INTERVIEWS (Check all that apply)

l. O&M site manager Kathy Webb Geologist 03 /24/2011 Name Title Date

Interviewed ~ at site 0 at office 0 by phone Phone no. --Problems, suggestions; ~ Report attached see Almendix. C

2. O&M staff mm/dd/yvyv - ­ --Name Title Date

Interviewed 0 at site 0 at office 0 by phone Phone no. --Problems, suggestions; D Report attached

D-l

--

-- -- --

-- -- - - --

-- - - -- --

-- -- -- --

--

--

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

Agency SC DHEC Contact Greg Cassidy Environmental

Name Engineer Date Phone No. Title

Problems; suggestions; ~ Report attached see Appendix C

Agency __ Contact __Name

Title Date Phone No. Problems; suggestions; 0 Report attached

Agency __ Contact

Name Title Date Phone No. Problems; suggestions; 0 Report attached

Agency __ Contact

Name Title Date Phone No. Problems; suggestions; 0 Report attached

Agency __ Contact

Name Title Date Phone No. Problems; suggestions; 0 Report attached

4. Other interviews (optional) 0 Report attached

III. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply)

1. O&M Documents

o O&M manual ~ Readily available o Up to date DN/A

o As-built drawings ~ Readily available o Up to date DN/A

o Maintenance logs ~ Readily available o Up to date DN/A

Remarks: - ­2. Site-Specific Health and Safety Plan o Readily available o Up to date [8J N/A

o Contingency plan/emergency response plan o Readily available o Up to date [8J N/A

Remarks:

3. O&M and OSHA Training Records o Readily available o Up to date [8J N/A

Remarks:

D-2

4. Permits and Service Agreements

o Air discharge permit o Readily available o Up to date [gI N/A

o Effluent discharge o Readily available o Up to date IX! N/A

[gJ Waste disposal, POTW [gJ Readily available o Up to date DN/A

o Other permits __ o Readily available o Up to date IX! N/A

Remarks: -­5. Gas Generation Records o Readily available o Up to date IX! N/A

Remarks: -­

6. Settlement Monument Records o Readily available o Up to date [gI N/A

Remarks: -­7. Ground Water Monitoring Records [gJ Readily available [gJ Up to date DN/A

Remarks: -­8. Leachate Extraction Records o Readily available o Up to date IX! N/A

Remarks: -­9. Discharge Compliance Records

o Air o Readily available o Up to date [gI N/A

o Water (effluent) o Readily available o Up to date IX! N/A

Remarks: -­

10. Daily Access/Security Logs o Readily available o Up to date [gI N/A

Remarks: ­ -IV. O&M COSTS

I. O&M Organization

o State in-house o Contractor for State

o PRP in-house [gI Contractor for PRP

o Federal Facility in-house o Contractor for Federal Facility

0_

D-3

2. O&M Cost Records

[gl Readily available [gl Up to date

D Funding mechanism/agreement in place D Unavailable

Original O&M cost estimate $225,000 D Breakdown attached

Total annual cost by year for review period jf available

From 09/30/2006 To 08/01 /2007 ~38,000 D Breakdown attached

Date Date Total cost

From 09/30/2007 To 08/01/2008 $31,000 D Breakdown attached

Date Date Total cost

From 09/30/2008 To 08/01 /2009 $34,000 D Breakdown attached

Date Date Total cost

From 09/30/2009 To 08/0112010 $31,000 D Breakdown attached

Date Date Total cost

From 09/30/2010 To 02/0112011 $13,000 D Breakdown attached

Date Date Total cost

.., Unanticipated or Unusually High O&M Costs During Review Period .).

Describe costs and reasons: None noted.

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

A. FenCing

l. Fencing da maged o Location shown on site map I:8J Gates secured D N/A

Remarks: --

B. Other Access Restrictions

I. Signs and other security measures D Location shown on site map I:8J N/A

Remarks: --

C. Institutional Controls (ICs)

D-4

-- -- --

--

--

--

l. Implementation and enforcement

Site conditions imply institutional controls not properly implemented ~Yes D No DN/A

Site conditions imply institutional controls not being fully enforced DYes D No (gI N/A

Type of monitoring (e.g. , self-reporting, drive by) __

Frequency __

Responsible party/agency __

Contact mm/ddlvvvv

Name Title Date Phone no.

Reporting is up-to-date DYes DNo DN/A

Reports are verified by the lead agency DYes DNo DN/A

Specific requirements in deed or decision documents have been met DYes DNo DN/A

Violations have been reported DYes DNo DN/A

Other problems or suggestions: D Report attached

2. Adequacy D ICs are adequate ~ lCs are inadequate DN/A

Remarks: Institutional controls have not been imI1lemented.

D. General

I. Vandalism/trespassing D Location shown on site map ~ No vandalism evident

Remarks: PeoI1le are Living on site in tents but have not caused any I1roblems.

2. Land use changes on site ~N/A

Remarks:

..,

.) . Land use changes off site ~N/A

Remarks: --VI. GENERAL SITE CONDITIONS

A. Roads D Applicable ~N/A

1. Roads damaged D Location shown on site map o Roads adequate ~N/A

Remarks:

B. Other Site Conditions

Remarks: Litter was found throughout, including dumI1 I1iles .

VII. LANDFILL COVERS o Applicable ~N/A

A. Landfill Surface

1. Settlement (Low spots) o Location shown on site map o Settlement not evident

Arial extent -- Depth __

Remarks:

0-5

2. Cracks o Location shown on site map o Cracking not evident

Lengths __ Widths -- Depths __

Remarks: -­3. Erosion o Location shown on site map o Erosion not evident

Arial extent -- Depth __

Remarks: - ­4. Holes o Location shown on site map D Holes not evident

Arial extent -- Depth __

Remarks: -­

5. Vegetative Cover o Grass o Cover properly established

o No signs of stress o Trees/Shrubs (indicate size and locations on a diagram)

Remarks: -­

6. Alternative Cover (armored rock, concrete, etc.) DN/A

Remarks: - ­7. BuLges o Location shown on site map D Bulges not evident

Arial extent -- Height __

Remarks: - ­8. Wet AreaslWater Damage D Wet areas/water damage not evident

o Wet areas o Location shown on site map Arial extent --D Ponding o Location shown on site map Aria! extent -­o Seeps D Location shown on site map Aria! extent --D Soft subgrade o Location shown on site map Arial extent --Remarks: - ­

9. Slope Instability o Slides D Location shown on site map

D No evidence of slope instability

Arial extent --

Remarks: --

B. Benches D Applicable DN/A

(Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined channel.)

l. Flows Bypass Bench o Location shown on site mal? o N/A or okay

Remarks: -­

2. Bench Breached o Location shown on site map D N/A or okay

Remarks: - ­

D-6

.., Bench Overtopped o Location shown on site map o N/A or okay.J.

Remarks: --

C. Letdown Channels o Applicable DN/A

(Channel lined with erosion control mats, riprap, grout bags, or gab ions that descend down the steep side slope oftbe cover and will allow the runoff water collected by the benches to move off of the landfill cover without creating erosion gullies.)

l. Settlement (Low spots) o Location shown on site map o No evidence ofsettlement

Arial extent -- Depth __

Remarks: -­2. Material Degradation o Location shown on site map o No evidence of degradation

Material type __ Arial extent --

Remarks: -­3. Erosion o Location shown on site map o No evidence of erosion

Arial extent -- Depth __

Remarks: -­4. Undercutting D Location shown on site map D No evidence of undercutting

Arial extent -- Depth __

Remarks: -­5. Obstructions Type __ D No obstructions

o Location shown on site map Arial extent --Size --

Remarks: -­6. Excessive Vegetative Growth Type __

D No evidence of excessive growth

D Vegetation in channels does not obstruct flow

D Location shown on site map Aria] extent --Remarks: --

D. Cover Penetrations D Applicable D N/A

l. Gas Vents o Active o Passive

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

D Evidence of leakage at penetration o Needs Maintenance DN/A

Remarks: -­

D-7

2. Gas Monitoring Probes

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

o Evidence of leakage at penetration o Needs maintenance ON/A

Remarks: -­3. Monitoring Wells (within surface area of landfill)

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

o Evidence of leakage at penetration o Needs maintenance ON/A

Remarks: -­4. Extraction Well Leachate

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

o Evidence of leakage at penetration o Needs maintenance ON/A

Remarks: -­5. Settlement Monuments o Located o Routinely surveyed ON/A

Remarks: --

E. Gas Collection and Treatment o Applicable ON/A

l. Gas Treatment Facilities

o Flaring o Thermal destruction o Collection for reuse

o Good condition o Needs maintenance

Remarks: -­

2. Gas Collection Wells, Manifolds and Piping

o Good condition o Needs maintenance

Remarks: -­..,

Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)-' .

o Good condition o Needs maintenance ON/A

Remarks: --

F. Cover Drainage Layer o Applicable ON/A

l. Outlet Pipes Inspected o Functioning ON/A

Remarks: -­2. Outlet Rock Inspected OFu ctioning ON/A

Remarks: --

G. Detention/Sedimentation Ponds o Applicable ON/A

1. Siltation Area extent -- Depth __ ON/A

o Siltation not evident

Remarks: -­

D-8

2. Erosion Area extent -- Depth __

o Erosion not evident

Remarks: -­

3. Outlet Works o Functioning DN/A

Remarks: -­

4. Dam o Functioning DN/A

Remarks: --

H. Retaining Walls o Applicable DN/A

I. Deformations o LocationOshown on site map o Deformation not evident }

Horizontal displacement __ Vertical displacement __

Rotational displacement __

Remarks: -­2. Degradation o Location shown on site map o Degradation not evident,

Remarks: --

I. Perimeter Ditches/Off-Site Discharge o Applicable DN/A

I. Siltation o Location shown on site map o Siltation not evident

Area extent -- Depth __

Remarks: -­

2. Vegetative Growth o Location shown on site map DN/o

o Vegetation does Dot impede tlow

Area extent -- Type __

Remarks: -­3. Erosion o Location shown on site map o Erosion not evident

Area extent -- Depth __

Remarks: -­

4. Discharge Structure o Functioning ON/A

Remarks: --

VIII. VERTICAL BARRIER WALLS o Applicable ~N/A

I. Settlement o Location shown on site map o Settlement not evident

Area extent -- Depth __

Remarks: -­

. 0-9

2. Performance Monitoring Type of monitoring __

o -,Performance not monitored

Frequency __ o Evidence of breaching

Head differential --Remarks: --

IX. GROUND WATER/SURFACE WATER REMEDIES ~ Applicable o N/A

A. Ground Water Extraction Wells, Pumps and Pipelines ~ Applicable DN/A

l. Pumps, Wellhead Plumbing and Electrical

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

Remarks: -­

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

~ Good condition o Needs maintenance

Remarks: -­

3. Spare Parts and Equipment

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

Remarks: --

B. Surface Water Collection Structures, Pumps and Pipelines o Applicable ~N/A

1. Collection Structures, Pumps, and Electrical

o Good condition o Needs maintenance

Remarks: -­

2. Surface Water Collection System Pipelines, Valves, Valve Boxes and Other Appurtenances

o Good condition o Needs Maintenance

Remarks: -­3. Spare Parts and Equipment

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

Remarks: --C. Treatment System ~ Applicable DN/A

D-IO

I. Treatment Train(Check components that apply)

o Metals removal o Oil/water separation o Bioremediation

o Air stripping o Carbon adsorbers

o Filters __

o Additive (e.g., chelation agent, flocculent) __

o Others __

o Good condition o Needs maintenance

o Sampling ports properly marked and functional

o Sampling/maintenance log displayed and up to date

o Equipment properly identified

o Quantity of ground water treated annually __

o Quantity of surface water treated annually __

Remarks: __

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

o N/A IZl Good condition 0 Needs maintenance

Remarks: __

3. Tanks, Vaults, Storage Vessels

[g] NIA o Good condition o Proper secondary containment

Remarks: __

o Needs maintenance

4. Discharge Structure and Appurtenances

o N/A [g] Good condition

Remarks: __

o Needs maintenance

5. Treatment Building(s)

[g] N/ A 0 Good condition (esp. roof and doorways)

o Chemicals and equipment properly stored

Remarks: __

o Needs repair

6. Monitoring Wells (pump and treatment remedy)

IZl Properly secured/locked IZl Functioning IZl Routinely sampled

IZl All required wells located 0 Needs maintenance

Remarks: __

IZl Good condition

DN/A

D. Monitoring Data

I. Monitoring Data

IZlls routinely submitted on time [g] Is of acceptable quality

2. Monitoring data suggests:

[g] Ground water plume is effectively contained o Contaminant concentrations are declining

0-11

E. Monitored Natural Attenuation 1. Monitoring Wells (natural attenuation remedy)

o Properly securedllocked o Functioning o Routinely sampled o Good condition

o All required wells located o Needs Maintenance ~N/A

Remarks: - -X. OTHER REMEDIES

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

XI. OVERALL OBSERVATIONS A. Implementation of the Remedy

Describe issues and observations relating to whether the remedy is effective and functioning as designed. Begin with a brief statement of what the remedy is to accomplish (i.e. , to contain contaminant plume, minimize infiltration and gas emission). The remedy is functioning as intended. The I1lume is contained on site and no contaminants have been detected in downQTadient wells.

B. Adequacy of O&M Describe issues and observations related to the implementation and scope ofO&M procedures. Ln particular, discuss their relationship to the current and long-term protectiveness of the remedy. No issues noted.

C. Early Indicato rs of Potential Remedy Problems Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high frequency of unscheduled repairs that suggest that the protectiveness of the remedy may be compromised in the future. None noted.

D. Opportunities for Optim ization Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy. None identified.

D-12

Appendix E: Photographs from Site Inspection Visit

View of Site from the Speedee Cash parking lot, looking north. Cherry Street located to the east.

Monitoring wells MW-OISH and MW-OIRK.

E-l

Trash dumped near the northern edge of the Site. Shopping center in background.

Monitoring wells MW-06SH and MW-06RK.

E-2

Pumping well system.

E-3

Appendix F: Ground Water Maps

\ \ \, \ , \

\ \ \ \ 11 I I MW-04SH/ I

.; .; / \,\.38 M'~

\\ . 586.34 ,_"""" JI ./ \', . 1oIW.(JSIK, , &

LEGEND BEDROCK IotONITCIUNG W8..l. SN'fQlTE fll<:NlaijteQ W&.l. WATER lEVB. (FT 10IIII.) R£C()IJI;RYWBJ. r>!I:lOUCiklN WEU. (NOT"lJSE) IJ..W ~GlNEERKlweu. AMNOONED M~ITORING 'Mll

--- WATER bEVEl. OONltlUR (FT U!iJ -_

• -. _ . -

RlmEDGE PRa'ER'YlJIEPROPERlY UIE 01'l-ERS

_ •• - CREBC _ EXISTING IlUII.DlNGS (APPRQlQ1oIAn;)

, fOIW!RSmUCT\JRES~lE) _011 ~_a;1IIIQ, ,1II1H)1II!

FIGURE 3.1 SAPROLITE PUMPING WATER LEVEL MAP

JUNE 22. 2010 RUTLEDGE PROPERTY SUPERFUND SITE

ROCKHILL. SOUTH CAROLINAsynTerra

F- l

LE,Q ND IIB)OOQ( MOIIllJUNQ WEU. W",l£IU!Vli~ (r'f II!l.) SN'ROlllE UONIfORING WELL RECOYERY WElL PftOOUCTlOH WEI.L (NOT IN ~ LAW PlGlNiiRtIBWil.L AIWIOONEII MONITO!II~YaI.

--- W",TER LEVEL O(JH~ (FT IIS.) - - - RUTlEDGE IIRClIER'I' UNE -'-'- PROPeR1YUNlO'l'lW

CRE!l(

ElCl5n'IG BUlLDIMGS~TE) FORMER tTRucmJRE$IfI'I'I\OIGMAn;)

FIGURE 3.2 BEDROCK PUMPING WATER LEVEL MAP

JUNE 22.2010 RUTLEDGE PROPERTY SUPERFUND SITE

MWlNr. .....,.,JECt",,,,_IlJilQl_.-nI_..

ROCKHILL. SOUTH CAROLINA

F-2

= . /'

,/ ;

LEGEND I!alROOk I.IOHI1tJMING WiLL 8N'If)Ul! IoIONflURlNQ WElL WAT lML,r~ RI!CKMRY W!l.l PRODUCTION ww. (NOTIN U$Cj l.NN !.NClIHURfIOwat. AIIAHOONED MONITOIlJNO v.w.

--- WATERL COHTOUR(FTMSl) - • - RUTI.iOOIi PRCftRY UNIi - ---- 1'II000RlYUNEOTHaIS

CREEK ElOsnNGIIIJIL.D~~~ FOIWER 8TRUC1\JRES(N)I'ROlaMATE)

FIGURE 3.3 SAPROLITE STATIC WATER LEVEL MAP

JUNE 15,2010 RUTLEDGE PROPERTY SUPERFUND SITE

ROCKHILL, SOUTH CAROUNAsynTerra

F-3

(fTUSL) aNWlI.l11: MONITORING WELl. llEOC:M:RV WEll fWlOUCTlON '/IiU. (NOT IN USil V,W ENOlN WEU. AMNQCl\IED IiIONITORINO WEll

--- WA~L~eC»l~(I9'~ - • - I\Ul\.eOGe I"RQl'CRYUN= - . - . - 1'R000000IJNEOTHSRS

CREEK EXlS11NG NUll ~Ti) FORMIiR $TRUC1\JRe$~IAA~

FIGURE 3.4 BEDROCK STATIC WATER LEVEL MAP

JUNE is. 2010 RUTLEDGE PROPERTY SUPERFUND SITE

ROCKHILL, SOUTH CAROUNA.....­

F-4

Appendix G: Ground Water Data Trends

CONCENTRAT1ON.VS.T1M~

TRICH OROTHYLENE ,... -' ..... 0.4 .§I:Il

0 .35 03z

00.25

()0

IIIV q'

.., c

'"

"c. 0 .12

...,E 0 .1

~ 0.08

I:! 0,06

~ 0 ,04

~ 0 ,02 v Z 0

IIIv ° q' c IV....

,.... 0 .... N M III

~ q' ~ ~ <;> <;> <;> 9 9• 9 c: c c c c: c: c:: c: c.,. .. .. .. .,. .. ij.., ~ ., .., .... .... ...ro .., .., ..,'"

SAMPLDlG DATE

FIGURE 3.10 CONCENTRATION TREND

MW-02SH 2010 Annuill Monitoring Report

Rutledge Property Superfund Site.

CONC£lIfrRATlON .W. TIME l.~-OJICHLOROEntENf

,... -'

§03S 02 DC 0 ,15 I- ELlI­ 0,1 z

• ~ ()l......t1 0 ,05 v zz

CONCENTRATION .VS. TIME CONCENTRATION .VS. TIME VDlYL CHLORIDE TOTAL MIUIGANESE

....."-' -'

(I) .... .., In

~ " ~ ~ .,.'" 9 <;> '"<;> 9 3

C 0

c c c Co c: c c c C II II OJ OJ.., ..., ..., ..., ..,... .. .. .., ...,... ... ~'" '"

SAMPLING DATE

"Ca 0 ,6

50.5

~ 0,4

..00,.... II\.

~ "0.. V q' q'~ 9 ~ ~ c c c: c ~.. ro ro..OJ OJ ro ro.., .., ., ... ..., ... c .... c ... c

... N ~ ~ ~ 9 <;> "" 9 9 '"<;> c: c c c c. c c c:

to to..,.. ..,.. .., .., ...... ..., ..,.. .....,.'"

5.lIi...UHGDATE

,.....0 9 9 ~ 9 s c c: c c c:

OJ..,.. ..,.. ..,'" ..,.. ....

.­~1.2

15

~ 4) 8

506

~ 0 ,4

~ 02 v Z Q0.... 0 III .....v... ~9 9 ~ ~ . '!' f("

c c c c c c .: c.. ..,... .. ~ ~ ... .!!l ~ ~ ... ..,0 .... ...

0 0 0~ ~ 9 9 3 '" c c c c c c c c ..,III ..,.• .. ..., ..... til ...,.. ...OJOJ

"'" "'" SAMPUNG DATE

9 .... 0~ ....9 ~ . c c c Co c: ...,II ..,... .. ...,.. ..,... ....

FIGURE 3.11 CONCENTRAnON TREND

MW-03SH 2010 Annual Monitoring Report

Rutledge Property Superfund S-te

CONCfHTRATlON. S. TDLE CONCENTRATION_VS.~E

TRICHl.O~OTHYlEJIE 1,2-DXHlORO.ETHENE ,..

:J-' "Q 0 .6 ~ 14

! 12 ! 0.5 z 10 1

~ 0.40 s .1 \ ....... 5 6

4~ III 2 u Z 0 0 U

~

ti 0.3 f-\\ Performance I\ ~ 0.2+-~-------~~~~'-------------------;I Standard ~.. ...~~~~__~~S~ndaro~_________________________--;~ ~ 0.1

u·..... IL .'. --'. .':'::'\ Z 0 on .., ... o II') OJ) ... 'II) ..... -LI') \D r-. .co cr. <D cr. .0 N I"l .... <Du cr. '" cr. .0 .0 '" '" 80<:>.0 9 .0~ 9 ~ ~ 9 9 ':' ':' '9 '9 9 9 c '" r. C: '"r. c c r. r. c: r. c c: c c c c c r.= ;: c C:r::

::> ::> :; :::0 :> :J::> ::> ..., g g ..., ..., ..., ..., ..., g.::c

~ ~ ~ ~ ..,..... ..... '" ..... '" .:: .:: '" "" ~ ..... ..... " ..... SANPUNG DAlE SA UNGDATE

COffCENTRATION .ys'TIHE CONCENTRATIO .IIS. TDIIE VlJCYL 1:HLORlDE TOTAL fllAliGANESE

~ "Q 0.03 "Q 0.4 ,....-------~-----~-------....,

E 0.35 tr--------;:= ;-----------'lf---I!0.025 i 0 .3 ~ 0.02 E 0.25 +-------­

01550 . ~ 0 .2 t------------------~------------------~~ 'lie 0.15O>r-- P5fcrmaoce1~ 0.01 f---o­ ~ 0 .1 +--+---------(t-------------;ft-~Sta:nclard -l.

-E 0 .005 ~ 0.05 +---1,--------­u Z 0 ~ 0 "'~~~~~~~~-,-~~~~~~~~~~~~8 In oD "'- U) 0> 0 ... -r<I ... 11') .., .... trJ 0 oD ..... <D 01 .0

C1> '1' ." 'r '1' '? 9 9 '9'" 0 '? 9 0 9 '"9 ..., u '1' '1' ~ <r <!' '? 9<: c <: c: c: c c: c c: r. <: c c c: c: c c: c: c: c: c :c c ::> ::> ::> ::0 :> ::0 ::J ::> ::> :> ::> :> ::J :> :> ::J :> .:;J :::0 :>..,"" ..., ..... ..., .., ,..., .., ..., ..,'" ..... ...,'" ..., ... ..., ... ..... ..., ..., ..,..... ..... ..... ....

SAMPlING DATE SAM DAn

G-2

FIGURE 3.12 CONCENTRATION TREND

MW-Q31lK 2010 Annual Monitoring Report

Rutledge Property Superfund Site

COfIKEKTllATlON .Vs. TIME COHCENTRATIO .VS. TIME TRICHlORODfYL£NE l,.2-DICHlOROETHENE

.... .... :::J '"D 12 'ii 1.6

E 1.4! 10 '"' z 1.:1.z 80 0 1 H ...

6 ~ 0.8~ Ck 0 .6 Ill! 4... !E 0.4..,z

2 ~ 0.2u z 0 0 LIl .0 .... «> ex- 0 ..... N t'T ... LIl .0 ... <U ao 0 0 01) <U 0 ~ ..... M ... 01) ... CD

Z a <t)u ..... u ~ " ! ! t t 't '[ '[ '[ '[ '[ '[ '[ '[ 'f 'f ... cr '" cr cr cr cr '" '[ 'f '[ ~ '[ ~ 'f '[ <;> '['" '­a. a. n. Q Q a 0. a. 0. a. Q. a. 0- c. c. 0. a. c. a. a. c. a a a. a a. Q c. D. a D. Do « « « « ..: <{ <t <C <C « « « « <l <C « ..: « « <l <C <l <t ..: <l ..: ..: <l « « « «

SAMPlING DATE SA.MPUNG DATE

CO ENTRATlON .VS. TIME CONCENTRATION.vs. TIME VINYL CHlOIUM 'faTAL MANGAJIIESE

,... .... oJ oJ

~ 0.25Ii 0 .12 E.... 0 .1 ! 0 .2

z~ 0.08 S 0.1S

§0 .06 ~ 0 .1

... O .O~ ... ~ 0.05l5 002

u U Z 0 z a 0 11'1

P'erforman c:e 5alrrdard

-..0 at (II 0 N ... .... ..0 r- ... (II II> .0 <XI a- 0 ..... N ... .... IX) 0u "- :; u 0

(II 0 a 0 0 0 0 0 0 0 0 0 "" " '" '" "" .:. ~ t ! ! L '[ CZ '[ 9' 9 L 9' '[ .:. L '1' t '" .:. ~ t CZ .:. .:. L CZ '" L L L L L c. a. a. a. a. a. D. ... a. a; li. a. 5. a. a. a. a; n. a. '0. a. a. a. a. Q. a. ~ a. 0.. a. a. a. <C « <C <C <C <l < « « « « « <C « « « « « « <C ..: « <C <C « « « « « <C « «

SAMPLING DAn SAMPLING DATE

- ~=-£...... .

Performance Standard

..... \I)

'" '" ~ ~ a 0

CONCENTRATION .VS. TINE VDO'l. t:HLORIOE

..... ~j 0.012

..... 0.01

~ 0 .008

S0 .006

~ 0 .004 .... 0 .002 u

Performa nee Standard

z 0 ....8 a­ld 0

CONCENTRAT.ION .VS. Tnu TRICHLOROTHY

----- ­ - - ----

Performance I

~ 7 Standard

-

'~.-. ...... ..... ..... ..... ~ ..... <1>

~ <D

'" ~ '" '" ~

<:> <:>

~

.... <:>

tJ '" <:>

~ '".0

~ ... Q

¥ II)

0

~ 0 0 0 a a a C) C) 0

SAMPlING DAIrE

.n ,... m 0- -0 - ..... rt In a- a- a- 0- -0 0 .0 .Q .0'" .0

~ ~ ~ ld ~ ~ ~ ~ ~ li! 0 0 0 Cl Cl 0 0 Cl 0 Cl

SAMPLING DAlE

FIGURE 3.13 CONCENTRATION TREND

RW-01 2010 Annual Monitoring Report

Rutledge Property Superfund Site

CONCElfTRATlO .VS. TIME 1,2-DICHlOROHIfENE

20.6T-------------------------------------------~ .,. .§. 0.5

r5 0.4 +----------------------~

~ 0.3 ~ 0 .2 il--------- ­

lj 0.1 z8 °ll)+-~~---ID "'-~O-~-r--N~-Mr----\I)r--'Dr--r--<D~~"'~..... ~~ ... .....

'D ..... III 0 0 0 0 ~ ~ ~ ~ ~ q 0 000 9 0 090 '" ~ ~ ~ ~ 0 C) 0 0 ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

S"f'1PLlNG DATE

CONCENTRATION.VS.T~E

TOTAL MANGA E

..J"rO.0.8 9

i 0.7 C 0.6 f:! 0.5=0.4 .. 0.3 Z 0.2 ~ 0.1 z 0

..... to \I) ..... CD <1> 0 '" 0 0 0 '" 8 '" <1> 0- 8 0 ~ ~ ~ ~ ~ S 8 ~'" '" '" ¥ ~ ~ ¥ ~ ~ li! ~ li! ~li!~li!~~~~ld~ 0 0 0 0 0 0 0 0 Cl 000 0 000 000

SAMPLING DATE

0-4

--

---

FIGURE 3.14 CONCENTRATION TREND

MW-04SH 2010 Annual Monitoring Report

Rutledge Property superfund Site

(X)I(CEft'fRATlO .VS. TIME TRlCHlOROTHTLfNE

CONCENTllATlON .VS. TXKE 1,2-DlClllOROETHfNE

..... .....

...J ...J

Ii. 0.08 E 0.07....-Z 0.06 g 0 .05 ~ 0 .04 ~ 0.03 ~ 0.02 ::: 0.01 Z 0

......... " Performance

Standard

r-- - ---- -- -­

'" --I.. --6 - A-. -A- A- -.A 1\

o ...,to .... 0:> (J\ 0 -' "- 0:> (J\ 0 o lf1 oD .... (I) (J\ 0 ... N M .... lf1 'iJ r- ID (J\ 0u '" '" • '" '" .... u 0 ...! ! 'f ! 't 'l <r ~ 'l <r ~ 'l <r 'Z: <r ... ! 'f ! ! ! 't 'l 'l 't '!: 'l 't L 'l 't ....a 0- n. cr n a. c. n n. c. 0. Q. Q. cr a. a. a. tt a. co n a. c. D. a. 0. D."'- "'- "'- "'­<{ <{ c( c( c( c( <{ c( c( <{ c( <{ c( c(..« « ~ « « « ~ «« « « « ~ « « ~ «

SA,. PLIIIlG OATE SAMPLING DATE

(X)I(CENTTRATIO .VS. nME VINYL CHLORIDE

CONCENTRATION .VS. TIME TOTAL ""NGArtHE

..... .....

...J ...

Ii. 0 .06

SO.OS

~ 0.04.. ~ 0.03

E0.02 III 0.01 u Z 0

I ~

,-...., / \

\ ... -\.,., Performance .1

Standar€l ~.

"Q 0 .012 ....-------------------~..,.s 0.01

~ 0 .000 -f--+--------'------------I§0 .006

fi 0.004 III 0 .002 ijJo--------...;---!"-o".......----=-----! U Z 0 8 a -' .... .... ... ...

9 9 9 9 a 9 a. a. a. a. ~ a. « c( « c( c( c(

~E 4.5 "-' Z o

..

~ 2!i 1.5 IU 1

Z 0 I:

8 '" 1 «

5 ~------------------------------------~------, 3.5 ¥--<~------_..!,---=------ - ­ ---I

3 +----1~------+-~4--------------__1 ~ 2.5 +--------'-'_-«>-~----.r;I----..,__-------1

U 0 .5 t::;:::=:;::::;:::~s=:;:=:;:=:;:=:;:=:;::::;::::;::::;::::1

SAMPLING DAn

P;\ROCKIUI.L.233\ 19. 0&''1"09\ 04 5&11 Mu.2"'<>- AIt& 2OlIl\ T1mo n ConcGrapbuls\ MW-<>4l!H

FIGURE 3.1.5 TeE CONCENTRAnON lRENDS 2005 TO 2010

2010 Annual Monitoring Repo Rutledge Property Superfund SUe

COfi~£NTRATlON .VS. TINE CONCENTRATION .V5.TlME NW-02SH MW-03SH

:; ~ () 12 ,.....--~--------------------.III ~ 0.1 +-~~----------------------------------------~

Z OOBa ~ 006 ~ ().04

~ 0 .02

~ 0 ~~~~~;=~~~==~~~~~~~~ u

SAMPUNG DATE

~ 0_06 .....----------------------,

! 0.05 t-------­--+\--­-------­ -I z 0.04 ~.~~------------~--~~-------~ 0-03: ~ ... u z 8

0.02

().Ol

0 \I) '" <XI 01 9 c;> 9 '? c c c >­

" ~ ~ .. .....

0- Cl '? -;' C c ~ ~

II> 9 c ~ ~

SAMPUIliG DATE

,...

CONCENTRATION .VS. nNE NW-03RK

:::! 0 6 ..... -------------~-------------__...s ()5 ~ ().4

a= ()3e02

III 0.1 +---..-" U

~ ol-----~~~~~~~--~----~----~--~ u lfl

o ;; ::::l...,

" <XI 01999 c c: :>­

~ ~ ~ SA.MPUNG DATE

.,.. 0 0 .... C .

C ::J ::J., ....

..... ~ 0 .16 110

! 0..l4

Z 0 .12­

o O. ~

~ 0.08 ~ o of>

~ I)° t... 0.02U

Z 00 U In

9 C ::J..,

CONCOITRATION .YS. TIME RW-01

~ ,... eX) a'o 9 9 9 0

I C C c :>­::J ::J ::J ., ..... ..... .., ~

SANPUNG DAn:

Performante St;lnOilfd

0> 0 0 "7I c c ::J ::J.., ..,

P. \ROCKH(l.L.~13\19 . O&M09 D4. S8iR Mar."2nlo- Aug . 2010\Tlme YS Cone ~ph5_RB.J(Is\n:t: C.",oe~tl'lltlan. ilt.ew

G-6