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PUBLIC HEALTH ASSESSMENT ADDENDUM

CAROLAWN
FORT LAWN, CHESTER COUNTY, SOUTH CAROLINA


SUMMARY

The Carolawn Company site (Carolawn), is an abandoned waste storage and disposal facility on the United States Environmental Protection Agency's (EPA) National Priorities List (NPL). It is located 3 miles west of Fort Lawn, South Carolina. Currently available data identify the presence of chromium, lead, and diethylhexyl phthalate in the soil and chromium, lead, acetone, 1,1-dichloroethylene, trans-1,2-dichloroethylene, and bis- (2-ethylhexyl)phthalate in the groundwater. At least one household within a 1/2-mile radius uses groundwater as a source of potable water; analyses of water from this well have shown the presence of low levels of chlordane-related compounds. Groundwater is believed to discharge to Fishing Creek; however, contaminants have not been found in surface water samples.

Available data is not sufficient to assess the duration or magnitude of past off-site exposures which may have occurred via contaminated groundwater. No currently completed exposure pathway has been identified. However, air monitoring data from within nearby houses and surface soil (0-3") data is not available. Therefore, this site is currently considered to be an indeterminate public health hazard. Should the site become accessible to the public, should contaminated groundwater be used for household uses, should Fishing Creek show evidence of contamination, should sampling within the nearby homes indicate that contaminant vapors are being released from the groundwater, or surface soil samples indicate contaminants at levels able to cause health effects, the site would then be reclassified as a public health hazard. Recommendations include improving site security, periodic sampling of nearby residential wells currently in use, periodic sampling of Fishing Creek, surface soil sampling, and sampling the indoor air of one home.


BACKGROUND

A. Site Description and History

This section presents the history of the Carolawn site. Unless otherwise noted, the information comes from the August 1988 Public Health Assessment for this site prepared by the South Carolina Department of Health and Environmental Control (SCDHEC) and the November 7, 1989 "Final Report, Remedial Investigation, Carolawn Site" by Conestoga-Rovers & Associates.

Carolawn is an abandoned waste storage and disposal facility located in Chester County, South Carolina (see Figures 1 and 2). Aerial photographs show a fenced site of 4 acres and discarded drums in an associated 8-acre area beyond the fenced area. The site is on the southern edge of approximately 82-acres of wooded and undeveloped lands. The closest approach of Fishing Creek lies 740 feet to the northeast of the site. Three residential drinking water wells and the associated homes they supply, lie along the southern border of the site. The closest well is approximately 240 feet from the southeastern border of the site. Another residential well lies 0.6 miles west of the site; the structure at this location burned down in approximately 1988.

In 1970, the Southeastern Pollution Control Company (SEPCO) began operations at this Fort Lawn site as a chemical storage and disposal facility for liquid industrial waste. An estimated 2,500 drums of solvents were stored on the site. SEPCO never obtained storage and disposal permits from the South Carolina Department of Health and Environmental Control (SCDHEC) or from SCDHEC's predecessor, the South Carolina Pollution Control Authority (PCA). PCA initiated compliance proceedings against SEPCO in 1972. In 1974, the company declared bankruptcy.

In January 1975, the bankruptcy administrator contracted with Columbia Organic Chemical Company (COCC) to clean up waste at the SEPCO plant in Clover, South Carolina and at this facility near Fort Lawn facility. The wastes from clean-up were to be brought to the Fort Lawn facility; COCC brought an estimated 2,000 drums to the site. COCC received the Fort Lawn property as payment for services rendered.

South Carolina Recycling and Disposal, Inc. (SCRDI), a subsidiary of COCC, managed the site. SCRDI used the site as a storage and staging area for drummed wastes. In 1978, SCRDI sold the property to the Carolawn Company. In 1978, SCRDI received a permit for a one-time disposal of 300 to 400 drums of inert waste. The location of this disposal site cannot be ascertained from the available information.

After purchasing the property from SCRDI, Carolawn constructed two incinerators on-site in 1978. As documented in the 1987 Remedial Investigation/Feasibility Study (RI/FS), a test burn of one incinerator was conducted with conditional SCDHEC approval but full-scale incineration was never implemented. As stated in the NUS Corporation's sampling investigation report, two incinerators were operated at the facility for waste disposal. As documented in a 1979 Consent Order between SCRDI, Carolawn Company, and SCDHEC, SCRDI was granted a permit on October 13, 1978, allowing them to "dispose of the waste in accordance with stipulations described therein." SCDHEC inspections of November 21, 1978; March 22, 1979; April 9, 1979; and April 12, 1979, revealed improperly stored wastes and a lack of progress towards the disposal of waste materials. After the investigative conference of May 21, 1979, between SCDHEC, Carolawn, and SCRDI, a Department Consent Order was issued. The Carolawn Company was not able to obtain a permit for incineration. They declared bankruptcy in 1980.

The March 12, 1980, EPA Tentative Disposition Form stated, "Site contains fire damaged, corroded, and leaking drums of flammable solvents, paints, inks, dyes, oil, and a mixture of caustic/antimony. Site had fire in 8/79 involving materials. Drums are piled together in a disordered heap adjacent to a wet weather spring. A small dike is not retaining obvious leakage. Rains are apparently carrying materials into the spring. Site also has 4 (four) 2000 gal. bulk tanks of solvents. Site has no security." EPA conducted a Hazardous Waste Investigation in August 1981.

In December 1981, EPA contracted four companies to undertake cleanup activities. Completed in 1982, this cleanup consisted of removing drums, waste, and contaminated soil. Waste water contained in on-site surface impoundments was pretreated and released to the Great Falls, South Carolina, waste water treatment plant. Approximately 200,000 gallons of liquids, 50,000 gallons of organic solvents, 1,250 cubic yards of contaminated soil, 85,000 gallons of contaminated water, and an unspecified amount of sludge were removed from this site.

The Carolawn site was proposed for addition to the EPA National Priority List (NPL) on December 1, 1982. The site was finalized on the NPL on September 1, 1983.

Since this listing on the NPL, continued sampling of local residential wells showed persistently high levels of trichloroethylene. The 1987 RI/FS states that three private wells were sampled in November 1980. SCDHEC files document a series of subsequent samplings. Of the surrounding private wells, the well southeast of the site, RW-1, consistently showed contamination with Volatile Organic Compounds (VOCs) and the highest levels of contamination. A November 23, 1981, letter to the owner stated the persistence of low levels of various VOCs in the well water.

SCDHEC letters dated December 6, 1982, and September 20, 1983, recommended that residents obtain their drinking water from another source. An April 18, 1985, memorandum from the Department of Health and Human Services (DHHS) - EPA Liaison recommended "that bottled water be used for drinking and domestic purposes until a permanent, safe water supply can be provided."

In an August 1984, SCDHEC memorandum, the owner stated that he no longer used RW-1 for drinking water. In 1985, EPA arranged for an extension of a two-inch diameter water main from the Chester Municipal Sewer District to the homes near the site. A resident stated that the homes served by the second well, RW-2, tied-on to the municipal water supply in 1985. This resident also stated that the well southwest of the site, RW-3, continues to serve the associated home.

In May and June 1986, storage tanks were removed on behalf of the Carolawn Generator Steering Committee. The committee commissioned a Remedial Investigation and Feasibility Study (RI/FS). HAZTECH and Soil & Material Engineers, Inc. (S&ME) submitted an RI/FS on March 13, 1987.

Under a cooperative agreement with the Agency for Toxic Substances and Disease Registry (ATSDR), SCDHEC prepared a Health Assessment for this site in August of 1988. This Health Assessment was released in final form on April 12, 1989.

According to the EPA Fact Sheet, insufficient data was collected during the first phase of the Remedial investigation. Therefore a second round of sampling was performed in 1989.

EPA entered a Record of Decision (ROD) on September 27, 1989. This ROD calls for a ground-water interception and extraction system. In a July 31, 1990 letter from Hartsill W. Truesdale, Chief of the SCDHEC Bureau of Solid and Hazardous Waste, the State of South Carolina did not concur with the EPA Record of Decision because of certain unresolved issues. In a September 26, 1989, memorandum, ATSDR concurred with the selected remedies. It stated, "However, until the groundwater extraction and treatment systems have been proven to reduce the levels of identified organic and inorganic compounds to specified ARAR's and other relevant Federal/state criteria, we suggest institutional controls be considered to prevent the drilling of down gradient wells for potable use within approximately 1/4 to 1/2 mile from the site boundary."

During the week of December 10, 1990, EPA sampled on-site soil from locations north and west of the fenced area. Soil samples came from areas which previous aerial photographs showed the presence of drums.

B. Site Visit

Doug Blansit, Gail Godfrey, and Ed Gregory, SCDHEC project staff, conducted a site visit on June 2, 1988 as part of the August 1988 Health Assessment of this site. Subsequent site visits have yielded similar results.

Outside of the site, water meter boxes lie in the yards across the road from the site's south boundary. The bent front gate (southwestern corner) allowed easy access to the site. The back gate (northwestern corner) was open. Staff saw a sardine can and beverage cans on-site. They did not know whether these items were left by workers or trespassers.

The fence surrounded a plateau with a gully in the northeastern corner and a gulch on the western border. Remnants of underground pipes, some marked with flags, and discarded rubber hoses and polymeric pipe were scattered throughout the site.

The soil appeared to be a gray clay loam or silty clay. Erosion was evident in the northeastern section. Vegetation ranged from scrubs and grasses to some young deciduous trees. Barren areas were present in the north central section where old vertical tanks once stood, according to 1982 aerial photographs. Signs of small animal habitation were seen inside the fence.

Near the southern fence, a rusted drum rested in a pool of standing liquid. The pool lining was in disrepair. A frog was observed in the pool.

The eastern section of the site contained the remains of two incinerators. The incinerators consisted of a connected open horizontal cylindrical chamber and vertical cylinder. The staff did not see evidence of any pollution abatement equipment. The staff detected a subtle, pleasantly sweet odor in the vicinity of the incinerators (Staff did not note this odor on subsequent visits.)

A dirt trail led from the back gate toward the northeast. Another trail branched to the east. These trails led to the old drum storage sites, as seen on old aerial photographs. The soil was composed of red clay (in contrast to the gray clay on-site). Normal botanical succession was apparent.

On August 8, 1988, staff met representatives of Conestoga-Rovers and Associates, Inc. and Geo/Resource Consultants, Inc. on-site. They stated they were drilling on- and off-site monitoring wells and were sampling Fishing Creek.

On May 7, 1991, Doug Blansit and YanQing Mo of SCDHEC met with Environmental Quality Control District personnel to make a site visit. The site appeared unchanged from earlier visits. The bent front gate allowed convenient access to the site as did the space between the back gate and the ground. Foot-high weeds covered most of the site. A thick mixture of honeysuckle and blackberry plants covered the remainder of the site. In the western portion of the site, three rectangular areas of standing water contained rows of cattails. Staff also observed frogs, lizards, and a snake. The remains of the "incinerators" were still present.

C. Demographics, Land Use, and Natural Resource Use

Demographics and Land Use

Demographic data are based on the 1980 Census Data and field observations. The Carolawn site is located in a predominantly rural area. The area surrounding the site is predominantly forested but includes several small fields approximately 3 acres in size.

Four households are located along the southern border of the site. Residential well RW-1 lies southeast of the site. Residential well RW-2 is located south of the site and supplies potable water to two residences also located south of the site. Residential well RW-3 lies southwest of the site and continues to supply water to a home southwest of the site. SCDHEC staff did not see children nor notice children's playthings (such as toys, swingsets, etc.) in the yards of any of these residences.

Residential well RW-4 lies west of the site; according to a local resident, the home at this location burned down around 1988. Neither visual recognizance nor topographic maps show any other structures between the site and Fishing Creek or its tributaries to the north, east, or south.

In 1980, approximately 2,000 people lived within a 4-mile radius of the site; an estimated 100 people lived within a 1-mile radius. Fort Lawn, South Carolina (population 471), lies 2.5 miles east of the site. Eight miles south of the site, Fishing Creek joins the Catawba River from which approximately 2,500 people of Great Falls, South Carolina, receive their water supply. No day care or nursing home facilities were identified within a 1-mile radius. No extensive commercial agriculture was identified in the area, although gardens and small pastures with livestock were common.

Residential housing consisted of predominantly single-family units. The average number of persons per household was 3.2 (4.1 persons per black household, 2.7 persons per white household). Of owner-occupied housing, 42.9% had a value of less than $25,000; 83.3% of renter-occupied housing rented for less than $120 per month. These figures suggest that this is primarily of a low-income area with older housing units.

In 1980, approximately 57.4% of the population within a 4-mile radius of the site were white, 41.9% were black, and 0.7% were recorded as other (State averages are 68.8%, 30.4%, and 0.8%, respectively). The population was 49.6% male and 50.4% female. Persons under age ten made up 16.1% of the population and persons 65 years and over made up 9.5% of the population (State percentages were 15.8% and 9.2%, respectively).

Of the total population within a 4-mile radius, 10.3% were under age seven; 28.0% were under age 14; and 33.3% were under age 18 (State averages were 10.7%, 22.5%, and 30.2%). The Public Health Implications Section will discuss the significance of both age and race.

Natural Resource Use

Available evidence indicates that groundwater discharges into Fishing Creek. According to the November 1989 Remedial Investigation, Fishing Creek also drains the Site area. Portions of the 82-acre site lie within the 100-year flood area as established by the United states Geological Survey (USGS). South Carolina classified Fishing Creek in the area of the site as Class SB water (South Carolina R.61-69); that is, the water quality is suitable for secondary contact, recreation and as a source of drinking water after it undergoes conventional treatment. Class SB water is also suitable for fishing, industrial and agricultural uses.

Approximately 8 miles south of the site, Fishing Creek joins the Catawba River at Fishing Creek Reservoir. Fishing Creek Reservoir is used for fishing, boating, and bathing. According to a January 1984 letter from the United States Department of the Interior, Fishing Creek is used by "a number of migratory waterfowl species," and "there are several sightings each year on the Catawba River of the endangered bald eagle."

Use of this area for hunting is unknown; however, since this is a large, forested area, we believe that hunting may occur. Local residents may fish in Fishing Creek.

The climate of this area includes long hot summers and short mild winters. According to the 1989 Remedial Investigation report, data from the Chester, SC meteorologic station shows a mean annual temperature of 61º F with near monthly temperatures ranging from 42º F in January to 79º F in July. The mean annual precipitation is 47.11 inches.

D. Health Outcome Data

Site-specific health outcome data are not available for this site. Additionally, the demographic section suggests that the population which may possibly be exposed to contaminants from this site consists, at most, of four households. Therefore, this population is too small to allow the use of established registries or other health outcome data.


COMMUNITY HEALTH CONCERNS

Citizens complained about the Carolawn Company while it was in operation. In a December 1979 letter addressed to SCDHEC, residents complained of smoke and debris settling on laundry and vegetable gardens "a couple of weeks ago." It states, "we feel that our right to live without undue pollution is being ignored and that our health and possibly our lives are being endangered."

In a public meeting on August 30, 1989, a resident living adjacent to the site publicly stated that they had not connected to municipal water because the government told them that their well was "clean." They expressed concern that the contaminants found in the groundwater could harm their health. EPA subsequently tested this well for inorganic elements, purgeable organic compounds, extractable organic compounds, and pesticides. This revealed the presence of chlordane-related compounds. Therefore, a second sample was collected on December 15, 1989 and analyzed for pesticides.

In a June 5, 1991 telephone interview, an adjacent landowner expressed three health concerns: Could drinking their current groundwater result in health effects?; Could this water become polluted in the future?; Could their neighbors be exposed to any contaminants if they use Fishing Creek for fishing or swimming?

The Carolawn Public Health Assessment was avaliable for review and public comment from September 4, 1992 until October 10, 1992. Copies of the Public Health Assessment were available to the community/interested parties at the Lancaster Public Library, the Catawba Health District Office, and the South Carolina Department of Health and Environmental Control, Division of Health Hazard Evaluation. Additionally, news releases were sent to all the weekly and daily newspapers in the state, all television networks in the state, the Associated Press, and the South Carolina Radio network. This comment period was intended to give the public and/or interested parties an opportunity to voice additional concerns or make comments pertaining to the Carolawn Public Health Assessment. The office of Health Hazard Evaluation of the South Carolina Department of Health and Environmental Control did not receive comments during this period.



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