UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION 4

ATLANTA FEDERAL CENTER61 FORSYTH STREET

ATLANTA, GEORGIA 30303-8960

2 9 0001.

5EP 1 k 2m.. . -OTHER:

ENFORCEMENT ACTION MEMORANDUM . . .

SUBJECT: Request for a Removal Action at the Virginia Carolina Chemical (VCC)Company Site, Pon Pon, Charleston County, South Carolina.

FROM: l ' Kevin S. Misenheimer, OSC -•Emergency Response and Removal Branch

TO: :,^/.Beverly Banister,'Acting Director^ ^^.^^^y;-^:-;^. / ; . : ) . =Waste Management Division

Site ID#: A4NJ

I PURPOSE

The purpose of this Action Memorandum is to request and document approval of theproposed enforcement-lead removal action described herein for the Virginia Carolina Chemical(VCC)- Pon Pon Site, located in Pon Pon, St. Pauls Parish, Charleston County, South Carolina(the Site). The Site poses a.threat to-public health and the environment that meets the NationalOil and Hazardous Substances Pollution Contingency Plan (NCP) section 300.415(b)(2) criteriafor removal actions. Exxon Mobil Corporation (XOM) is the corporate successor to VCC. Thisremoval action is anticipated to be enforcement lead pursuant to.an Administrative Order onConsent (AOC) with XOM. . , : . / - :

II SITE CONDITIONS AND BACKGROUND

A. Site Description

This section documents the site conditions which require a time-critical removal action tomitigate the effects of a release or threatened release of hazardous substance into theenvironment. The CERCLIS identification number for the VCC-Pon Pon Site is SCS123457002.

1. Removal Site Evaluation

The VCC-Pon Pon Site is the location of a former phosphate fertilizer manufacturingfacility. It is believed that the facility operated during the late 1800's to early 1900's. Historicaldocuments indicate the facility was owned or operated by Georgia Chemical Works", Charleston^Mining and Manufacturing Company and Virginia-Carolina Chemical at some point during itshistory. Figure 1 depicts the location of the Site.

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Internet Address (URL) <> http://www.epa.gov

Recycled/Recyclable "Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Poslconsumar)

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Figure 1Site Location Map

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REFERENCE; BASE MAP US8S ^ M9*. QUAD, JACXSONBORO, SC. 1970

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t/U/U CM-B5-L£I APPROXMA1E GRAPHIC SCALE

EXXONMOBILPON PON, CHARLESTON COUNTY. SOUTH CAROLINA

PROPERTY REPORT

1979 HISTORICALTOPOGRAPHIC MAP

BBL RGURE

B-1

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Investigations conducted thus far have "not confirmed the exact processes employedduring the operation of the Site nor have they identified the location of any lead - acid chamberson the Site. However, based on previously identified processes at other super phosphatefertilizer sites in South Carolina, the facility manufactured sulfuric acid onsite through the leadchamber process. Pyrite (FeS) was-heated or cooked in lead lined chambers yielding hot sulfurdioxide gas,.which-was"*mixed with nitrogen oxides and nitrous vitriol. The vitriol catalyzed the - •-• »••'.-oxidation reaction of sulfur dioxide to sulfur trioxide, which reacted with water to form sulfuricacid (H2SO4). In order to make the super phosphate fertilizer, the locally mined phosphate rockwas crushed and finely-ground into dust of talcum powder consistency. The phosphate rock dustwas then mixed with sulfuric acid (from the lead chamber process) and water. The action of thesulfuric,acid.resulted,in.an_exothennic.-reaction changing ,the,-insqluble,phosphprus.(trircalcium.., , . . . .phosphate) into a:spluble;'form:'(mbh6-calciu'^ ' - ' " 'plants for growth. This form of super phosphate was further processed and sized prior to beingtransported to farmers. These processes resulted in residual metals contamination includingarsemc;,and--lead,-in<environm^ obtained from.. ......,. ,the Pre-CERCLIS Screening Report developed by the South[Carolina Department of Health andEnvironmental Control (SCDHEC). (Ref. 1).

In June 2005, SCDHEC completed a Pre- CERCLIS Screening Report for the VCC-PonPon Site (known by SCDHEC as the Georgia Chemical Works Site) (Ref 1). During their March2005 field reconnaissance effort, SCDHEC observed suspected pyrite slag, old structuralremnants, old chemicahbricks, a sulfur pile, an old cistern, and metallic debris in thenorthwestern portion of the property, along the private road that traverses the Site. Using X-rayfluorescence (XRF), SCDHEC analyzed 36 samples of soil and other materials found on theground surface-in this area for a select list of metals (copper, arsenic, mercury, and lead). Leadwas detected at concentrations as high as 22,000 parts per million (ppm) and arsenic as high as62,000 ppm. Approximately eight residences were observed in the immediate vicinity of the. Siteand it appeared that local residents are easily-able to access areas with high concentrations ofarsenic and leadjn soil. A subset of analyticalresults for lead and arsenic is presented in Table1. Figure 2 depicts SCDHEC sampling locations and the approximate location of ori-siteresidences. All of the.residents within the, subdivision use private wells .for drinking watersupply. SCDHEC also reported that the Edisto River, which is a fishery, is adjacent to the Site,and obvious areas of waste disposal are less than 1,000 feet from the river. Based on the Pre-CERCLIS screening, SCDHEC concluded that the VCC-Pon Pon Site required additionalevaluation, and forwarded their findings to EPA Region 4, Superfund Remedial and SiteEvaluation Branch (SRSEB). EPA forwarded the report to Exxon Mobil on September 9,2005.Exxon Mobil consultant Blasland, Blouck and Lee, Inc. (BBL) subsequently visited the Site andcompleted a Property Report, which includes documentation and research into the ownership andoperational history of the Site (Ref. 2). EPA SRSEB also conducted several site visits.

In September 2006, the Property Report and SCDHEC Pre-CERCLIS screening reportwere forwarded to the EPA Region 4 Emergency Response and Removal Branch (ERRB) forconsideration.using CERCLA.rempval authorities. On September 14,2006, ERRB completed areview of the site information and recommended that the site be considered a High Priority forremoval action. (Ref. 3)

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V.A.-J -if.

Table 1Subset of XRF Screening Results

.; (Units = ppm)

Sample ID"'-.f;

...L. .-..::.......2

••••'^ - ' ••*• ' •"-•••*;

5

****&*?** 8&»*

8

9

11

12 " .,

13

.. W.-v*

15 ... . .

. . -4&' - , r -

17.

. . . . 1 8

21

22

25

26

27

31

35 ,

Sample Location

Brick east side of road

Brick east side of road

• :-'r''vfSiag*s6uth6fi6-ad"-i"1'"t '"

Dirt, near ATV trail

^ce^^Slagpile^-'V^^-

Soil runoff near slag pile

West shore of pond

Near bird feeder

Slag pile near pond

Soil

-;-t.,~, ....... l§oil-. and slag

Sulfur pile.

Pile of debris

Pile of debris

- • . Soil sample -

Soil sample - Zokowski

Soil sample - Zokowski

Pile of reddish slag

Pile of reddish slag

Pile of reddish slag

Main facility area

. . Dump area

Arsenic

85

109

•"* •*"-'?*"* : f**~-129

^?^52;9l2.^:i>

66,543

964

219

289

445

- 1,563

478

2,191

. 8 7 8

237 - -

144

265

62,874

42,310

1,511

119

216

Lead

...310

2,202

*:.*--— '.'375- -:r1,035

-;.13,672 .-,,..

5,984

1,773

" 4,227

748

4,198

13,933

.-.,2,638 -

4,040

3,658

189

86 '

101

3,987

4,063

21,918

74

1,875

.*.-3.t-t^:.

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Figure 2SCDHEC Sampling Locations

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2. Physical Location

The Site is located at the western edge of Charleston County, South Carolina,approximately 35 miles west of Charleston, South Carolina along United States Highway 17 (US17). The Edisto River forms the western boundary of the Site, and serves as the boundary linebetween Charleston County, South Carolina and neighboring Colleton County, South Carolina.As currently mapped, the boundaries of the former Georgia Chemical Works propertyencompass 221 acres of land. Although the exact location of the plant within the formerproperty is uncertain, available historical documents suggest that it was located in the north-central portion of the former-property. The geographic location of the center of the Site is atapproximately 32.7862° north .latitude and 80.4342° west longitude., • . ; . . . _ . ,

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2 9 0 0 0 63. Site Characteristics ,

The Site lies in a predominantly rural area that was historically used for phosphate 'v "*. -j

mining until the 1930s, and for quarrying of sand and gravel until the middle of the 20th Century.The old sand and gravel pits, now abandoned and filled with water; remain as significant featuresboth on and near the Site/..There are currently 17 tax parcels within the boundaries of the formerGeorgia Chemical Works;'Charleston Mining and Manufacturing Company and Virginia-Carolina Chemical facilities (herein known as VCC-Pon Pon). Most of the former VCC-PonPon property is currently undeveloped. The west-central portion of the property, along the . ' . : : ;Edisto River, contains several residences. According to SCDHEC, there are approximately eightresidences within or near the former VCC-Ppn.Pon Site (Ref.l). As stated.above, the Site is . . . .traversed from'east to west by US 17 and a parallel railroad owned by CSX. Several unimprovedprivate access roads also traverse the Site, with one primary north-south road providing access tothe interior of the property, both north and south of US 17. The Site can be readily accessedfrom US 17, but access to the.interior of:the;Site-is5Controlled'by locked;gates.and."no. ;..--•• < ••• •.:•,,.. ,_•trespassing" signs at the points of entry along the primary road. SCDHEC reported that manyportions of the Site are crossed by ATV trails.

The nearest notable community is Jacksonboro, which is located approximately 0.5 mileswest of the Site along US 17 in Colleton County. Along US 17 in the vicinity of the Site, there isa mix of residential, commercial, and undeveloped properties. The "Edisto Motel" and "EdistoDelicacies" are located west of the Site across the Edisto River at the eastern edge ofJacksonboro. Several single family dwellings lie along US 17 in the vicinity of the Edisto Motel.The Edisto Nature Trail is located west of the Site along US 17, across the Edisto River in

-Colleton County.- A large'tract <bf land, located east of the Site, is owned by MeadWestvacoForestry LLC, and appears to be used for the cultivation and harvesting of timber.

4. Release or Threatened Release into the Environment of a HazardousSubstance, or Pollutant or Contaminant

Screening results conducted-by SCDHEC using- XRF technology have demonstrated .. .elevated levels of arsenic and lead in Site soils and debris piles above the removal action levels(RAL) of 40 ppm and 400 ppm, respectively. Lead was detected at concentrations as high as22,000 ppm and arsenic as high as 62,000 ppm. A summary of XRF results is presented in Table1. The source of the contamination is believed to be the result of the phosphate fertilizerproduction activities which have historically taken place on the VCC-Pon Pon Site.

Arsenic and lead are both hazardous substances, listed in the Title 40 of the Code ofFederal Regulations (CFR) Section 302.4, as referred to in Section 101 (14) of theComprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA),as amended. Hazardous substances from the Site .will continue to be a threat to public health,welfare and the environment, if not mitigated.

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Most of the former VCC-Pon Pon property is currently undeveloped. The west-centralportion of the property, along the Edisto River, contains several residences. According toSCDHEC, there are approximately eight residences within or near the former Georgia ChemicalWorks Site (Ref.l).

'•TV.;;. ._*:.. . . ^ •»-• - . . .

5. NPL Status - - - >

The Site is not on the.National Priorities List (NPL). The arsenic and lead contaminatedsoils at the site above the RALs, where feasible, will be removed during this removal action,thereby eliminating potential exposure, and reducing the potential for future off-site migration.

6. Maps, Pictures, and Other Graphic Representations ..:

Figure 1 and 2 provide a depiction of the site location and SCDHEC sampling locations.Additional maps and figures;(-including:histoncaK-Sanbornrmaps)«are included in the Property.-<_Report compiled by BBL, Inc. (Ref. 2). Photographs are included in Attachment C.

B. Other Actions To Date

1. Previous Actions

Other than the activities mentioned above, no other government or private actions havebeen taken to investigate or mitigate the threats posed by the Site.

2. Current Actions «/

EPA and XOM are currently negotiating an Administrative Order on Consent which willprovide for the continued investigation, site characterization and removal actions at the Site.

C. State and Local Authorities* Roles

1. State and Local Actions to Date .- - ,

The South Carolina Department of Health and Environmental Control has completed aPre-CERCLIS screening investigation of the VCC-Pon Pon Site. In June 2005, SCDHECconcluded that conditions at the Site warranted further evaluation, and referred the Site to EPARegion 4. SCDHEC personnel continue to assist EPA and XOM with the ongoing investigationof the Site.

2. Potential for Continued State and Local Response

It is not anticipated that SCDHEC will perform any response activities at the Site. ERRBwill continue to coordinate with ATSDR, state, and local agencies during the removal activities.

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III. THREATS TO PUBLIC HEALTH OR WELFARE OR THE ENVIRONMENT,AND STATUTORY AND REGULATORY AUTHORITIES *

A. > Threats to Public Health or Welfare .~ ' - • . . . , , '" .' , i•;•»]!-

Arsenic'and lead present in on-site surface and subsurface soils pose the following threatsto public health or welfare as listed in Section 300.415 (b)(2) of the NCP:

Section 300.415 (b)(2)(i) Actual or potential exposure to nearby human-,v. populations, or the, food, chain from hazardous substances pollutants or

contaminants. ' : - - • • • • • -

The Pre-CERCLIS screening investigation disclosed that there is significant lead andarsenic contarmnation4hatis-closelyiassociated. with the pyrite and slag material and other wastedeposition piles, throughout the sampled areas of the Site. Lead and arsenic concentrationsexceeding the RALs of 400 ppm and 40 ppm, respectively, were confirmed through on-site XRFanalysis. The maximum lead concentration detected in surface soils was 22,000 ppm, and themaximum arsenic concentration in surface soils was 62,000 ppm. At least 25 of the 36 XRFsamples analyzed by SCDHEC exceeded the RALs. A summary of the XRF data is presented inTable 1. ~. ,, r.-i. ...._;.

There are residences currently located within the footprint of the former phosphatefertilizer production facility, now known as the VCC-Pon Pon Site. iThere is also evidence thatATVs are used on the Site which could indicate a potential exposure.to recreational users as wellas trespassers. Potential human exposure to site related contaminants may occur via inhalationof windbome dust, inadvertent ingestion of contaminated soil, and direct contact with thecontaminated surface soils.

Section 300.415 (b)(2)(iv) High levels of hazardous substances or pollutants or.,contaminants in soils largely at or near.the surface that may migrate.

Analytical results reveal that high lead and arsenic levels are present at or near thesurface creating a potential for migration to off-site locations. Lead and arsenic concentrationsexceeding the RALs of 400 ppm and 40 ppm, respectively, were confirmed through on-site XRFanalysis. The maximum lead concentration detected in surface soils in was 22,000 ppm, and themaximum arsenic concentration in surface soils was 62,000 ppm. At least 25 of the 36 XRFsamples analyzed by SCDHEC exceeded the RALs. A summary of the XRF data is presented inTable 1.

The Site is adjacent to the Edisto River, which is used as a public water supply in downstream areas. There is a potential for site contaminants to migrate to the Edisto River throughdrainage pathways.

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Section 300.415 (b)(2)(v) Weather conditions that may cause hazardoussubstances or pollutants or contaminants to migrate or be released,

Several areas throughout the Site are void of vegetation making them susceptible to windand Surface water runoff during heavy rain events which are common in this geographical area.Such events may contribute to the migration of lead and arsenic into nearby water bodies,including the Edisto River.

/

x

B Threats to the Environment . . , - . - . . . . . . . . .

The elevated levels of arsenic and lead in surface and subsurface soils pose the followingthreats to the environment as listed in Section 300.415 (b)(2) of the National Oil and HazardousSubstances Eollution^Gontingency.Plan: -r-- i ^ - - - , . - - - , ,

- -Section 300.415 (b)(2)(i) Actual or potential exposure to nearby animals, or thefood chain from hazardous substances pollutants or contaminants.

The Pre-CERCLIS screening investigation disclosed that there is significant lead andarsenic contamination that is closely associated with the pyrite and slag material and other wastedeposition piles, throughout the sampled areas of the Site. Lead and arsenic concentrationsexceeding the RALs of 400 ppm and 40 ppm, respectively, were confirmed through on-site XRFanalysis. The maximum lead concentration detected in surface soils in was 22,000 ppm, and themaximum arsenic concentration in surface soils was 62,000 ppm. At least 25 or the 36 XRFsamples analyzed by SCDHEC exceeded the RALs. A summary of the XRF data is presented inTable 1.

Much" of the Site is undeveloped and therefore the potential exists for wildlife to inhabitthe area. Animals could be exposed to the high concentrations of lead and arsenic in the soilthrough dermal contact.and ingestion. In addition, the proximity of the contamination to theEdisto River and other Federally designated wetlands which border the Site, presents a threat tospecies that traverse the Site and live in the wetland areas.

Section 300.415 (b)(2)(ii) Actual or potential contamination of sensitiveecosystems.

SCDHEC considers the Edisto River, which borders the Site, to be a fishery.In addition, there are surface water features located on the Site and Federally designatedwetlands in close proximity. Lead and arsenic contamination in the soils at the Site pose a threatto these sensitive ecosystems.

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IV ENDANGERMENT DETERMINATION

Actual or threatened releases of hazardous substances from this site, if not addressed byimplementing the response action selected in this Action Memorandum, may present animminent and substantial endangerment to public health;1 or welfare, or the environment • .

V PROPOSED-ACTION AND ESTIMATED COSTS:

A. Proposed Actions,. . . . . . .

1. -Proposed Action Description . . . . . _ . . . . . . . . . , . . . , . . . . , , : . 7 . . . . . . ..• .-.', "-. '. ,,.,..:•! -,,-..M..- ii .» Vij .... . . - . - . . _ :';*>.- :,.,;., „;>;,...,-.. j \ * f - \ , ' • . . ' . • . : - . ••" . . . . . • .... •. . .-.J.'v.,. i^v. . --

The removal action will involve, but is not limited to, the following steps:

- : • . . . . . . . XOM will developed ;implement_a. Site Characterization Plan, to further ,. : J . . - .investigate and determine the nature and extent of lead and arsenic contamination.

• XOM will implement the OSC approved removal action in accordance with theschedule and requirements of a Removal Action Work Plan. The Removal ActionWork Plan shall include as a minimum: a health and safety plan, contaminatedsoil excavation plan, confirmatory soil sampling-plan, contaminated soil treatmentand disposal plan, and a site restoration plan.

• XOM will excavate contaminated soils at the Site which exceed EPA's RemovalAction Levels (400 ppm lead and 40 ppm arsenic) and treat and / or dispose of thematerial according to appropriate industry and regulatory standards.

• XOM will restore areas which are disturbed by the removal action to their pre-removal state to the maximum extent practicable.

2. . Contribution to Remedial Performance

The proposed removal action will address the threats discussed in Section HI which meetthe NCP Section 300.415 (b) (2) removal criteria. Although future action under the RemedialProgram is unlikely, the removal action contemplated in this Action Memorandum would beconsistent with any future remedial action.

3. Description of Alternative Technologies

At this time it is difficult to anticipate what disposal and/or treatment alternatives will beapplicable to the waste. Contaminated soil from the Site may be excavated and treated and/or =disposed off-site. Alternatively, contaminated soils in some areas may be capped to eliminatethe direct exposure pathway.

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Because the waste materials at the Site have not been fully characterized, no formalevaluation of alternative technologies has been made. Such an evaluation will take place beforethe disposal phase of the response action and will be documented at that time.

4. EE/CA - -*..;:..-".. . . ? .::•.;- • . - . . ...-,.' .

This proposed action is a time-critical removal and does not require an EE/CA.

5. ARARs . . - - • - . . . . . • : • • • ' . ..-.-.

On-site removal activities conducted under CERCLA are required to attain ARARs toextent practical considering the exigencies of the' situation1. Off-site-removal activities-need.onlycomply with all applicable Federal and State laws, unless there is an emergency. All wastetransferred off-site will follow the CERCLA Off-Site Rule. A letter to SCDHEC requestingARARs was sent on 5ep.tember44vr2pO&..:.vj.r./:;v/^'r5;^--':->4:

s-ic--ei.^.......-..-••• .•; /, ..-

6. Project Schedule

The EPA is currently negotiating with XOM to undertake the removal actions outlined inthis memorandum. The project schedule will be incorporated in the work plan submitted to EPAfor approval under the Administrative Order on Consent (AOC).

VI. EXPECTED CHANGE IN THE SITUATION SHOULD ACTION BE DELAYEDOR NOT TAKEN

If this response action is significantly delayed or not taken, the residents living on the Sitemay be at risk to prolonged exposure to lead and arsenic.

VII. OUTSTANDING POLICY ISSUES:

No outstanding policy issues have been identified at this .time.

VHI. ENFORCEMENT

EPA anticipates that the XOM Corporation will both fund and conduct the removalaction. XOM is the corporate successor to the Virginia Carolina Chemical Company (VCC), thepast owner and operator of the Site. EPA has not identified any other PRPs and it is expectedthat XOM will be the sole PRP for this Site. EPA and XOM are currently negotiating the termsof the AOC for conducting the removal. XOM has signed AOCs to clean up other VCC sites inRegion 4, and it is expected that it will do so in this instance. Should negotiations with XOMfail to result in an AOC, EPA may decide to issue a Unilateral Order or take a fund-lead removalaction.

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IX. RECOMMENDATION

This decision document represents the proposed removal action for the Virginia CarolinaChemical - Pon Pon Site;located in Pon Pori, St. Pauls Parish, Charleston County, SouthCarolina. This document was developed in accordance with CERCLA, as amended, and notinconsistent with the NCP criteria. This decision is based upon the administrative recordestablished for the site. Conditions at the Site meet the NCP Section 300.415 (b)(2) criteria for a.removal action, and I recommend your approval of this proposed enforcement removal action.

(Approval) ^JJJA^/ ^\ ^R- §1^ ...... Date: /| <)-•• •- - ^^ -~ - . • . - . • .r^.' rr —; • - •...,. «

(Disapproval) 11_\___ Date:

Beverly Banister, Acting DirectorWaste Management Division

Attachments

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ATTACHMENT A

REFERENCES

1. Pre-CERCLIS Screening Report, Georgia Chemical Works, South Carolina Departmentof Health and Environmental Control, June 15, 2006.

2. Property Report, Former Georgia Chemical Works Site, BBL, Inc., June 2006.

3. Memorandum from 'Kevini Misenheimer to'JiriiMcGuire regarding the RAT Notification/ Priority Recommendation for the VCC-Pon Pon Site, September 14, 2006.

- - ^ - - ' , - ' - _>_;. '-"^f^r'~ ..'1*".T-' '"-T.:.1;; • .T'1""1",'-/ *~" ' • . ' - ' - - : ' . • • _ _".-_-' . • •- -• •

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ATTACHMENT B

SITE PHOTGRAPHS

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Site Photographs2 9 0 0 1 5

Page 11

GRAPHIC SCALE 1* = ISO'(INSET ONLY)

9 I

LEGEND:i c. o> APPROXIMATE LOCATION OF FORMER

GEORGIA CHEMICAL WORKS PROPERTYBOUNDARY

» APPROXIMATE LOCATION OF SITE VISITPHOTOGRAPH; SEE APPENDIX F

APPROXIMATE LOCATION OF CURRENTPROPERTY LINES

NOTES: :;• 1. FORMER PROPERTY BOUNDARY BASED ON ..

HISTORICAL DEEDS AND ON PLAT MAP DATED APRIL1902 BY SIMMONS AND UYRANT CIVIL ENGINEERS.

2. 2001 DIGITAL AERIAL PHOTOGRAPH OBTAINED FROMCHARLESTON COUNTY GEOGRAPHIC INFORMATIONSYSTEM DEPARTMENT. '

EXXONUOBILPON PON. CHARLESTON COUNTY. SOUTH CAROUNA

PROPERTY REPORT

2004 CHARLESTON COUNTY TAXMAP AND 2001 AERIAL WITH SITE

VISIT PHOTOGRAPH LOCATIONS

&..ARCADIS.1 /-,

HGURE

2