NPL-U30-2-6-R4 HRS DOCUMENTATION RECORD--REVIEW COVER SHEET Name of Site: Macalloy Corporation Contact Persons U.S. Environmental Protection Agency, Region 4: Craig Zeller, EPA Task Monitor Cynthia Gurley, NPL Coordinator Documentation Record: Sandra J. Harrigan, Project Manager Tetra Tech EM Inc. (404) 562-8827 (404) 562-8817 (770) 717-2324 Pathways, Components, or Threats Not Scored The air migration, ground water migration, and soil exposure pathways were not scored in this documentation record because these pathways are not expected to significantly contribute to the overall site score for the Macalloy Corporation. Air Migration Pathway: Until 1974, air emissions from facility furnaces were allowed to disperse to the atmosphere. These releases resulted in fallout throughout the site and the surrounding areas (Ref. 5, pp. II-5; II-24). From 1974 to 1989, the South Carolina Department of Health and Environmental Control (SCDHEC) allowed the facility to release air emissions from the furnaces under several air permits (Ref. 5, pp. II-24, II-25). During the permitted years, Macalloy violated its air emissions permits on several occasions (Ref. 5, p. II27). However, the air migration pathway was not scored due to a lack of air samples collected within a 4-mile radius of the operations area at Macalloy. Ground Water Migration Pathway: A ground water contamination plume covering about 23 acres exists in the surficial aquifer underlying the electrostatic precipitator (ESP) dust pile (former unlined surface impoundment) (Refs. 5, pp II-43, III-26; 6, p. 2; 7, p. 2). Ground water samples collected from monitoring wells installed in the plume contained concentrations of hexavalent chromium as high as 34 milligrams per liter (mg/L), which exceeds the EPA Drinking Water Act maximum contaminant limit (MCL) of 0.05 mg/L (Ref. 5, p. III-26). However, the ground water migration pathway was not scored due to the limited number of ground water targets within a 4-mile radius of the ESP dust pile (Refs. 8; 9, pp. 15, 16). Soil Exposure Pathway: Extensive surficial contamination exists throughout the facility. ESP dust, slag, and process wastewater have been deposited and spilled onto the ground surface throughout the facility (Refs. 28, pp. 2, 4 - 6; 36). Surficial soil samples have been collected indicating areas of observed contamination; however, background samples were not collected for comparison (Refs. 6, pp. 6 - 9; 7, p. 5). Therefore, the soil exposure pathway was not scored. The facility currently employs 192 people (Ref. 10, p. 2). HRS DOCUMENTATION RECORD Name of Site: EPA Region: Macalloy Corporation CERCLIS ID No.: SCD003360476 4 Date Prepared: September 29, 1999 Street Address of Site: 1800 Pittsburgh Avenue, North Charleston County and State: Charleston County, South Carolina General Location in the State: Southeast coast of South Carolina Topographic Maps: Charleston, South Charleston, 1958, Photorevised (PR) 1979; Fort Moultrie, South Carolina, 1959, PR 1979; North Charleston, South Carolina, 1958, PR 1979 Latitude: 32E50'17" North Longitude: 79E57'4.3" West Site coordinates were determined from a point in the center of the Electrostatic precipitator (ESP) dust pile (Ref. 4). Scores Air Pathway Ground Water Pathway Soil Exposure Pathway Surface Water Pathway Not Scored Not Scored Not Scored 100 HRS SITE SCORE 50.00 1 WORKSHEET FOR COMPUTING HRS SITE SCORE S2 S 1. Ground Water Migration Pathway Score (Sgw) (from Table 3-1, line 13) NS 2a. Surface Water Overland/Flood Migration Component (from Table 4-1, line 30) 100 2b. Ground Water to Surface Water Migration Component (from Table 4-25, line 28) NS 2c. Surface Water Migration Pathway Score (Ssw) 100 Enter the larger of lines 2a and 2b as the pathway score. 10,000 3. Soil Exposure Pathway Score (Ss) (from Table 5-1, line 22) NS NS 4. Air Migration Pathway Score (Sa) (from Table 6-1, line 12) NS NS 5. Total of Sgw2 + Ssw2 + Ss2 + Sa2 6. HRS Site Score Divide the value on line 5 by 4 and take the square root NS S S2 NS 10,000 = Not scored = Site score = Site score squared 2 50 SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT SCORESHEET Factor Categories and Factors Maximum Value Value Assigned 550 550 DRINKING WATER THREAT Likelihood of Release 1. Observed Release 2. Potential to Release by Overland Flow 2a. Containment 2b. Runoff 2c. Distance to Surface Water 2d. Potential to Release by Overland Flow (lines 2a x [2b + 2c]) 3. Potential to Release by Flood 3a. Containment (Flood) 3b. Flood Frequency 3c. Potential to Release by Flood (lines 3a x 3b) 4. Potential to Release (lines 2d + 3c, subject to a maximum of 500) 5. Likelihood of Release (higher of lines 1 and 4) 10 25 25 ---- 500 -- 10 50 --- 500 -- 500 -- 550 550 Waste Characteristics a 6. Toxicity/Persistence 7. Hazardous Waste Quantity 8. Waste Characteristics a 10,000 10,000 100 100 Targets 9. Nearest Intake 50 10. Population b 10a. Level I Concentrations b 10b. Level II Concentrations b 10c. Potential Contamination 10d. Population (lines 10a + 10b + 10c) b 11. Resources 5 b 12. Targets (lines 9 + 10d + 11) 0 0 0 0 0 5 5 Drinking Water Threat Score 13. Drinking Water Threat Score ([lines 5 x 8 x 12]/82,500, subject to a maximum of 100) 100 3 3.33 SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT SCORESHEET, Continued Factor Categories and Factors Maximum Value Value Assigned HUMAN FOOD CHAIN THREAT Likelihood of Release 14. Likelihood of Release (value from line 5) 550 550 Waste Characteristics 15. Toxicity/Persistence/Bioaccumulation 16. Hazardous Waste Quantity 17. Waste Characteristics a a 2 x 108 10,000 1,000 1,000 Targets 18. Food Chain Individual 50 19. Population b 19a. Level I Concentrations b 19b. Level II Concentrations 19c. Potential Human Food b Chain Contamination 19d. Population (lines 19a + 19b + 19c) b b 20. Targets (lines 18 + 19d) 20 0 0 0.0000333 0.0000333 20.0000333 Human Food Chain Threat Score 21. Human Food Chain Threat Score ([lines 14 x 17 x 20]/82,500, subject to a maximum of 100) 100 100 550 550 ENVIRONMENTAL THREAT Likelihood of Release 22. Likelihood of Release (value from line 5) Waste Characteristics 23. Ecosystem Toxicity/Persistence/ Bioaccumulation 24. Hazardous Waste Quantity 25. Waste Characteristics a a 1,000 4 2 x 108 10,000 1,000 SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT SCORESHEET, Concluded Factor Categories and Factors Maximum Value Value Assigned ENVIRONMENTAL THREAT (Concluded) Targets 26. Sensitive Environments 26a. Level I Concentrations 26b. Level II Concentrations 26c. Potential Contamination 26d. Sensitive Environments (lines 26a + 26b + 26c) 27. Targets (value from line 26d) b b b b 250 0 0.08 250.08 b 250.08 60 60 Environmental Threat Score 28. Environmental Threat Score ([lines 22 x 25 x 27]/82,500, subject to a maximum of 60) SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT SCORE FOR A WATERSHED 29. Watershed Scorec (lines 13 + 21 + 28, subject to a maximum of 100) 100 100 SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT SCORE 30. Component Score (Sof)c (highest score from line 29 for all watersheds evaluated, subject to a maximum of 100) 100 1 a b c - Maximum value applies to waste characteristics category. Maximum value not applicable. Do not round to nearest integer. Not evaluated. 5 100 A copy of Figure 1 is available at the EPA Headquarters Superfund Docket: U.S. CERCLA Docket Office Crystal Gateway #1, 1st Floor 1235 Jefferson Davis Highway Arlington, VA 22202 Telephone: (703) 603-8917 E-Mail: [email protected] 6 A copy of Figure 2 is available at the EPA Headquarters Superfund Docket: U.S. CERCLA Docket Office Crystal Gateway #1, 1st Floor 1235 Jefferson Davis Highway Arlington, VA 22202 Telephone: (703) 603-8917 E-Mail: [email protected] 7 A copy of Figure 3 is available at the EPA Headquarters Superfund Docket: U.S. CERCLA Docket Office Crystal Gateway #1, 1st Floor 1235 Jefferson Davis Highway Arlington, VA 22202 Telephone: (703) 603-8917 E-Mail: [email protected] 8 REFERENCES Reference Number Description of the Reference 1. U.S. Environmental Protection Agency (EPA). Hazard Ranking System, 40 CFR Part 300, Appendix A, 55 FR 51533. December 14, 1990. Excerpt 2 pages. 2. U. S. Environmental Protection Agency. Superfund Chemical Data Matrix, Appendix B-1, June 1996. Excerpt, 12 pages. 3. U.S. Geological Survey (USGS). 7.5-minute Series Topographic Quadrangle Maps of South Carolina: Charleston, SC 1959 (Photorevised [PR] 1979); Fort Moultrie 1959 (PR 1979); North Charleston 1958 (PR 1979), scale 1:24,000. 4. U.S. Environmental Protection Agency. Publication 9345.0-01A, Guidance for Performing Preliminary Assessments Under CERCLA, Latitude and Longitude Calculation Worksheet, Appendix E, September 1991. Excerpt, 3 pages. 5. A.T. Kearney, Inc. RCRA Facility Assessment for Macalloy Charleston, South Carolina, December 11, 1995. 228 pages. 6. Arthur L. Collins, Chief, Clean Water Act Enforcement Section, U.S. Environmental Protection Agency. Letter with attachments to Mr. James Frye, President, Macalloy Corporation, February 12, 1998. Subject: Storm Water Inspection, July 21-23, 1997, Macalloy Corporation NPDES Permit No. SC0004014. 60 pages. 7. U.S. Environmental Protection Agency, Region IV, Environmental Services Division (ESD). Case Development Investigation Evaluation (CDIE) for Macalloy Corporation, Charleston, South Carolina, February 1994. 27 pages. 8. Sandra J. Harrigan, Biologist, Tetra Tech EM Inc. Record of telephone conversation with Don Rigger, On-scene Coordinator, EPA Region 4, Emergency Response and Removal Branch, October 9, 1998. Subject: Operational status of Macalloy Corporation. 1 page. 9. Frost Associates. Letter to Peter Lowery (sic), Tetra Tech EM Inc., May 19, 1998. Subject: Macalloy Corporation, Charleston, SC. 16 pages. 10. EPA. RCRA Site Inspection Report, Carolina, May 7, 1997. 9 pages. 11. EPA, Region 4. Administrative Order on Consent in the matter of Macalloy Site, Charleston, Charleston County, South Carolina. CERCLA Docket No. 98-18-C. Ordered and Agreed on June 10, 1998. 25 pages. 12. South Carolina Department of Health and Environmental Control (SCDHEC). Water Pollution Control Permit, Macalloy Corporation, Charleston County, South Carolina, issued September 11, 1995. 29 pages. 13. Barry Mullinax, Environmental Engineer Associate, SCDHEC, Industrial, Agricultural, and Storm Water Permitting Division. Letter with attachment to Ms. Sandra Harrigan, October 12, 1998. Subject: Macalloy Corporation. 241 pages. Macalloy 9 Corporation, Corporation, Charleston, South 14. Sandra J. Harrigan, Staff Scientist, Tetra Tech EM Inc. Record of Telephone Conversation with Miller White, District Fisheries Biologist, South Carolina Marine and Wildlife Resources Department, April 30, 1998. Subject: Fishing in Shipyard Creek and the Cooper River. 1 page. 15. Sandra J. Harrigan, Staff Scientist, Tetra Tech EM Inc. Record of Telephone Conversation with Vicki Benfield, Biologist, Tetra Tech EM, Inc., May 18, 1998. Subject: Fishing in Shipyard Creek. 1 page. 16. Dr. Jeffrey L. Hyland, Manager, Carolinian Province Office, NOAA. Letter with attachments to Ms. Lisa Gordon, EPA-Region 4, April 20, 1998. Subject: Data on chromium in edible tissues of oysters, penaeid shrimp, blue crabs, and fish collected in Shipyard Creek during the Summer of 1997. 41 pages. 17. U.S. Department of the Interior, Fish and Wildlife Service. National Wetlands Inventory Map, Charleston, South Carolina 1989, scale 1:40,000. 18. EPA, Target Compounds and Analytes, with attachment. 19. Lionel, C. Arnold, Jr., Waste Assessment Section, Division of Waste Assessment and Emergency Response, Bureau of Solid and Hazardous Waste Management, SCDHEC. Memorandum to Ken Johnson, Hazardous Waste Permitting Section, Division of Hazardous and Infectious Waste Management, SCDHEC, June 28, 1997. Subject: Macalloy Sampling Trip - March 28, 1995. 23 pages. 20. Sandra J. Harrigan, Biologist, Tetra Tech EM Inc. Project note with attachment to file for Macalloy Corporation (9804-0002), May 28, 1998. Subject: Calculation of Area of Contaminated Soil. 7 pages. 21. Harold Seabrook, Manager, Waste Assessment Section, Division of Waste Assessment and Emergency Response, Bureau of Solid and Hazardous Waste Management, SCDHEC. Memorandum to Kim Hagan, Enforcement Section, Bureau of Solid and Hazardous Waste Management, SCDHEC, April 9, 1993. Subject: Macalloy Corporation Sampling Results, Charleston County. 53 pages. 22. Lionel, C. Arnold, Jr. et al., Waste Assessment Section, Division of Waste Assessment and Emergency Response, Bureau of Solid and Hazardous Waste Management, SCDHEC. Memorandum to File February 16, 1993. Subject: Macalloy Sampling - January 20, 1993. 22 pages. 23. SCDHEC. News Conference with attached News Release and Emergency Order. Subject: Shipyard Creek closed to shrimping and crabbing. April 30, 1998. Excerpt, 5 pages. 24. Tim Nelson, Senior Project Engineer, Macalloy Corporation. Letter with attachment to Ms. Kim Hagan, Enforcement Section, Bureau of Solid & Hazardous Waste Management, SCDHEC, February, 1994. Subject: Analysis of waste samples. 4 pages. 25. Andy Fairey, Director of Water Resources, Charleston Commissioners of Public Works (CPW). Letter to Sandra Harrigan, Tetra Tech EMI, May 6, 1998. Subject: Water Use and Distribution of the Charleston Commissioners of Public Works. 3 pages. 10 July 22, 1998. 9 pages. 26. David E. Bower et al., U.S. Geological Survey (USGS) in cooperation with the Charleston Commissioners of Public Works. Retention Time Simulation for Bushy Park Reservoir Near Charleston, South Carolina, Water-Resources Investigations Report 93-4079, 1993. Excerpt, 19 pages. 27. William R. Schneider, Vice President, Engineering, Macalloy Corporation. Letter to John Litton, SCDHEC, June 25, 1993. Subject: Revised Hazardous Waste Permit Application, Part A, form for facility in North Charleston, SC. Excerpt, 10 pages. 28. Sandra J. Harrigan, Staff Scientist, Tetra Tech EM, Inc. Record of telephone conversation, with attachment, with Lisa Gordon, Remedial Project Manager, Waste Management Division, U.S. Environmental Protection Agency, May 18, 1998. Subject: Storm Water Inspection at Macalloy Corporation. 11 pages. 29. U.S. Fish and Wildlife Service. Endangered and Threatened Species of the Southeastern United States (Atlanta, Georgia, 1992). Excerpt, 5 pages. 30. Sandra J. Harrigan, Biologist, Tetra Tech EM Inc. Project note with attachment to file for Macalloy Corporation (4-9804-0002), May 28, 1998. Subject: Rare, Threatened, and Endangered Species of Charleston County, South Carolina. 4 pages. 31. Walter A. Moore, III, P.E. Letter to Mr. W.R. Schneider, Vice President, Engineering, Macalloy Corporation, January 16, 1991. Subject: Subsurface Water Flow at the Charleston Plant. 1 page. 32. Sandra J. Harrigan, Biologist, Tetra Tech EM Inc. Project note to file for Macalloy Corporation, November 19, 1998. Subject: Discussions on sampling procedures during the START Sampling Investigation. 2 pages. 33. Sandra J. Harrigan, Biologist, Tetra Tech EM Inc. Record of telephone conversation with Barry Mullinax, Environmental Engineer Associate, SCDHEC, Industrial, Agricultural, and Storm Water Permitting Division, October 19, 1998. Subject: National Pollutant Discharge Elimination System (NPDES) discharge monitoring reports (DMR) for Macalloy Corporation. 1 page. 34. Sandra J. Harrigan, Biologist, Tetra Tech EM Inc. Record of telephone conversation with Craig Zeller, Remedial Project Manager, EPA Region 4, September 18, 1998. Subject: Status of Removal action at Macalloy Corporation. 1 page. 35. Sandra J. Harrigan, Biologist, Tetra Tech EM Inc. Record of telephone conversation with Nancy Robertson, Project Manager, Quanterra Environmental Services, Inc., October 14, 1998. Subject: Explanation of “Reporting Limits” provided in the analytical data for Macalloy Corporation. 1 page. 36. Sandra J. Harrigan, Biologist, Tetra Tech EM Inc. Record of telephone conversation with Mike Neill, Life Scientist, EPA, Region 4, Science and Ecosystem Support Division (SESD), October 8, 1998. Subject: Location of sediment sample SED-05 from the CDIE. 1 page. 11 37. Roger E. Brewer, Manager, SCDHEC, Sample and Data Management, Analytical Services Division. Letter with attachments to Sandra Harrigan, Tetra Tech EM Inc., November 5, 1998. Subject: Laboratory quality assurance and quality control information. 600 pages. 38. Sandra J. Harrigan, Biologist, Tetra Tech EM Inc. Project note with attachment to file for Macalloy Corporation, October 16, 1998. Subject: Meeting with EPA personnel at the SESD Office in Athens, Georgia. 8 pages. 39. Sandra J. Harrigan, Biologist, Tetra Tech EM Inc. Record of telephone conversation with Garry Bennett, Chief, Office of Quality Assurance, EPA, Region 4, SESD, November 24, 1998. Subject: General information about the analytical services that SESD provides. 2 page. 40. Tetra Tech EM Inc. Field Logbook No. 04-S-0289, for Macalloy Corporation, Charleston Corporation, Site Investigation, August 4 - 13, 1998. 12 pages. 41. Tetra Tech EM Inc. Field Logbook No. 04-S-0290, for Macalloy Corporation, Charleston Corporation, Site Investigation, August 4 - 13, 1998. 11 pages. 42. EPA Region 4, ESD. Field Logbook for Macalloy Corporation, 1800 Pittsburgh Avenue, North Charleston, South Carolina, ESD Project No. 940132. December 6 and 7, 1993. 6 pages. 43. EPA Region 4, SESD. Field Logbook No. Corporation, July 21 - 24, 1997. 15 pages. 44. Office of the Federal Register, National Archives and Records Administration, 40 Code of Federal Regulations, Parts 260 to 265. U.S. Government Printing Office, Washington: Revised July 1, 1997. Excerpt, 6 pages. 45. Sandra J. Harrigan, Biologist, Tetra Tech EM Inc. Project note with attachment to file for Macalloy Corporation, November 23, 1998. Subject: Analytical data sheets and Quality Assurance/Quality Control (QA/QC) information for samples analyzed by Quanterra Environmental Services, Inc. 280 pages. 46. R. Steve Pierce, START Leader, Tetra Tech EM Inc. Letter with attachment to Leo Francendese, On-Scene Coordinator, EPA Region 4, September 4, 1998. Subject: Macalloy Site Analytical Data, Charleston, South Carolina, Technical Direction Document No. 04-9806-0010. 30 pages. 47. Sandra J. Harrigan, Biologist, Tetra Tech EM Inc. Project note with attachment to file for Macalloy Corporation, November 23, 1998. Subject: Aerial photograph of vicinity of Macalloy Corporation obtained from the Charleston County, South Carolina Tax Assessor’s Office. 1 page. 48. USGS. 1998. “Water Resources Data, South Carolina Water Year 1997.” Data Report SC-97-1. Excerpt, 5 pages. 49. U. S. Department of Agriculture. 1971. Soil Survey of Charleston County, South Carolina. Soil Conservation Service. Excerpt, 5 pages. 12 7530-00-274-5494 for Macalloy Water 50. Sandra J. Harrigan, Biologist, Tetra Tech EM Inc. Project note with attachment to file for Macalloy Corporation, October 13, 1999. Subject: Explanation of how scale was calculated for the 1998 Aerial Photograph of Macalloy Corporation. 2 pages. 51. Sandra J. Harrigan, Biologist Tetra Tech EM Inc. Telephone conversation with Elizabeth Vonkolnitz, Assistant Director, Office of Public Affairs, South Carolina Department of Natural Resources, October 8, 1999. Subject: Fishing in Charleston Harbor. 1 Page. 13 SD-General Site Description SOURCE DESCRIPTION General Site Description The Macalloy Corporation (Macalloy), EPA ID No. SCD003360476, is located at 1800 Pittsburgh Avenue in North Charleston, Charleston County, South Carolina. The facility comprises about 125 acres, and is bound on the west by the CSX railroad, on the east by Shipyard Creek, a tributary of the Cooper River, on the south by Pittsburgh Avenue, and on the north by a waste-to-energy plant operated by Foster Wheeler, Inc. The area surrounding the facility is primarily industrial, with some commercial and residential areas. The nearest residential area, Union Heights, is located approximately 600 feet northwest of the facility (Refs. 3; 5, p. A-4; 6, p. 1; 7, p. 2; 10, p. 3; 11, p. 3). Since 1979, Macalloy has owned and operated the facility for the production of ferrochromium alloy. From 1966 to 1979, the facility was owned and operated by AIRCO Corporation. From 1941 to 1966, the facility was owned and operated by the Pittsburgh Metallurgical Corporation. Prior to 1941, the facility property was used as a lumbermill and a rice plantation. At various times from 1942 to the present, the United States owned, operated, or otherwise used portions of the facility for the production of ferrochromium alloy. Market pressure from cheaper ferrochromium produced abroad has forced Macalloy to consider several options for future operations, including shutting down the plant (Refs. 5, pp. A-3, A-22; 6, p. 1; 7, p. 2; 10, p. 3; 11, p. 3). In July 1998, facility personnel shut down the last operating furnace (Ref. 8). Macalloy produces ferrochromium alloy by smelting iron and chromium ore in submerged electric arc furnaces. Ferrochromium alloy is used in the production of high quality stainless steel. Ferrochromium alloy manufacturing activities have been conducted at the facility from 1941 to the present. Historically, as many as twelve furnaces were used to produce the alloy. Presently, Macalloy operates only one furnace. Alloy manufacturing activities have resulted in the generation of slag, fine particulate matter, ashes and dust (PMAD), gas conditioning tower (GCT) sludge and associated wastewater, electrostatic precipitator (ESP) dust, and baghouse dust (Refs. 5, pp. II-5, A-3; 11, p. 3). Slag, which contains chromium and cadmium, has been deposited as fill material throughout the facility and has been used to construct a portion of an on-site unlined surface impoundment. From 1941 to 1970, PMAD generated during the manufacturing process was discharged directly into the atmosphere. PMAD containing chromium, lead, zinc, and manganese, was deposited throughout the facility through fallout from the atmosphere. Air pollution control (APC) equipment, including gas conditioning towers and electrostatic precipitators, was installed in approximately 1970 to remove contaminants from plant air emissions prior to their discharge to the atmosphere (Refs. 5, pp. II-13, A-7; 10, pp. 3 4; 11, p. 3, 4). ESP dust, containing cadmium, chromium, lead, zinc, mercury, and manganese, has been generated as part of the operation of the APC at a rate of about 7 14 SD-General Site Description tons per day (Ref. 11, pp. 3, 4). From 1970 to about 1981, ESP dust was stockpiled in numerous areas on the facility, and was used to fill in low areas onsite. From 1988 to 1997, Macalloy placed treated ESP dust on site, primarily in the ESP dust pile (formerly the unlined surface impoundment) (Refs. 6, p. 2; 10, p. 4; 11, p 4). In January 1997, pursuant to the terms of a consent order with the South Carolina Department of Health and Environmental Control (SCDHEC), Macalloy discontinued disposal of ESP dust in the unlined surface impoundment and initiated off-site disposal of the material. On June 10, 1998, pursuant to the terms of an administrative order on consent with the U.S. Environmental Protection Agency (EPA) Region 4, Macalloy agreed to conduct work to abate an imminent and substantial threat to human health and the environment (Ref. 11, pp. 1, 4, 5). As of September 18, 1998, a removal action to remove the ESP dust pile from the facility had not occurred (Ref. 34). The facility has implemented some aspects of a Storm Water Management Plan; however, major modifications are being made in the plan (Ref. 8). GCT sludge, and associated wastewater, containing cadmium, chromium, lead, mercury, nickel, and zinc have also been generated as part of the operation of the APC equipment. GCT sludge has been disposed of as fill material at numerous locations at the facility. Approximately 40,000 tons of GCT sludge were used in the construction of the unlined surface impoundment. Currently, Macalloy generates approximately 6 tons of GCT sludge per day and returns this material from the settling basins to the furnace as a substitute for low-grade chromite ore. From 1970 to 1998, the GCT wastewater has been discharged to a settling basin (001 Settling Pond) (Refs. 5, pp. II-13 to II-17; 10, pp. 3, 4, 5; 11, p. 4). Macalloy operates four surface water discharge points under a National Pollutant Discharge Elimination System (NPDES) permit that SCDHEC issued. These outfalls discharge directly into Shipyard Creek and in the wetland area adjacent to Shipyard Creek (Ref. 12). Water samples collected pursuant to the requirements of the NPDES permit, have repeatedly exceeded permit limits for total chromium and hexavalent chromium (Ref. 13). In 1997, EPA and SCDHEC conducted a storm water inspection at the facility and collected soil, sediment, and surface water samples from various locations at the facility. At the end of the inspection, EPA concluded that storm water discharge into Shipyard Creek and the adjacent wetlands at locations other than permitted outfalls occurred (Refs. 6, pp. 3 to 18; 11, p. 4). Facility personnel and local residents use Shipyard Creek for recreational fishing (Refs. 14; 28, p. 4). On April 30, 1998, SCDHEC issued an Emergency Order closing Shipyard Creek to the harvesting of all shellfish due to high levels of chromium detected in edible fish tissue (Refs. 16, pp. 1, 3, Table 1; 23). The Cooper River, located approximately 0.75 mile downstream from the facility, is used for fishing, boating, and water skiing (Refs. 3; 14). 15 SD-Characterization and Containment Source No. 1 SOURCE DESCRIPTION 2.2 Source Characterization Number of the source: 1 Name and description of the source: ESP Dust Pile HRS Source Type: Pile Source No. 1 is an ESP dust pile. The pile was formerly an unlined surface impoundment constructed in 1988 to collect and store ESP dust and slurry. Over the years, ESP containing slurry was pumped into the unlined surface impoundment. The slurry was dewatered resulting in the ESP dust pile. Source No. 1 was in operation from 1988 to 1997. In November 1994, EPA conducted a Visual Site Inspection (VSI) at the facility. During the VSI, facility representatives indicated that the walls and floor of the unlined surface impoundment are above grade. The unlined surface impoundment, more recently referred to as a pile or dust impoundment, may be as large as 200 by 350 feet (ft) by 40 ft high, and was constructed in an area that was once a lake (Ref. 6, p. 7). The former lake and the unlined surface impoundment were filled with dust slurry generated as byproducts of the facility’s ferrochromium ore processing operations. When the unlined surface impoundment was filled, sludge and slurry were added to the walls, forming the dust pile now referred to as Source No. 1 (Refs 5, pp. III-25, A-22, A-23, A-57; 6, pp. 2, 7; 31). Information regarding the dimensions of the ESP dust pile is not consistent. These discrepancies may be due to the change in physical appearance, and disposal practices historically associated with Source No. 1. According to the Resource Conservation and Recovery Act (RCRA) Facility Assessment (RFA) prepared by EPA, several samples have been collected from the unlined surface impoundment. Analytical results of samples collected from the unlined surface impoundment revealed the presence of chromium, hexavalent chromium, cadmium, barium, and lead (Refs. 5, pp. III-25, III-26; 6, p. 8). Furthermore, Toxicity Characteristic Leaching Procedure (TCLP) samples for chromium indicated that waste stored in Source No. 1 failed TCLP tests for chromium (Ref. 5, p. III-25). According to the Case Development Investigation Evaluation (CDIE) that EPA prepared, ESP dust is a RCRA hazardous waste (Ref. 7, p. 2). Location of the source, with reference to a map of the site: Source No. 1, ESP approximately 300 25). Source No. 1 approximately 150 dust pile, is located in the central portion of the facility, feet north of the ferrochromium process area (Ref. 5, p. IIIis also located along the facility’s eastern property boundary feet west of Shipyard Creek (see Figure 2). 16 SD-Source Characterization and Containment Source No. 1 Containment Release by overland migration and/or flood: Source No. 1 has no surface water runoff control or management system. During the week of July 24, 1997, EPA and SCDHEC conducted a storm water inspection at the facility. During the inspection, EPA and SCDHEC personnel observed runoff from the surface impoundment (dust pile) entering Shipyard Creek (Refs. 5, pp. II-36, II-39; 6, pp. 7, 8) Containment value: 10 Reference: 1, Section 4.1.2.1.2.1.1 17 SD-Hazardous Substances Source No. 1 2.4.1 Hazardous Substances Hazardous Substance Evidence Contract Required Detection Limit Reference(s) Cadmium SW-03 (720 Fg/L) DST-08 (9.7 mg/kg) DST-09 (2.7 mg/kg) 5 Fg/L (water) 1 mg/kg (soil) 7, Appendix A, pp. 3, 8, 9; 18, p. 9; 42, pp. 2, 4 Chromium SW-03 (530,000 Fg/L) SW-04 (32,000 Fg/L) DST-08 (5,600 mg/kg) DST-09 (3,400 mg/kg) 10 Fg/L (water) 2 mg/kg (soil) 7, Appendix A, pp. 3, 4, 8, 9; 18, p. 9; 42, pp. 2, 4 Cobalt DST-09 (16 mg/kg) 50 Fg/L (water) 10 mg/kg (soil) 7, Appendix A, p. 9; 18, p. 9; 42, p 4 Copper SW-03 (3,500 Fg/L) DST-08 (41 mg/kg) DST-09 (73 mg/kg) 25 Fg/L (water) 5 mg/kg (soil) 7, Appendix A, pp. 3, 8, 9; 18, p. 9; 42, pp. 2, 4 Lead SW-03 (100,000 Fg/L) DST-08 (1,700 mg/kg) DST-09 (670 mg/kg) 3 Fg/L (water) 0.60 mg/kg (soil) 7, Appendix A, pp. 3, 8, 9; 18, p. 9; 42, pp. 2, 4 Mercury SW-03 (31 Fg/L) SW-04 (0.30 Fg/L) DST-08 (0.46 mg/kg) DST-09 (0.28 mg/kg) 0.20 Fg/L (water) 7, Appendix A, pp. 3, 4, 8, 9; 18, p. 9; 42, pp. 2, 4 0.10 mg/kg (soil) Nickel SW-03 (14,000 Fg/L) DST-08 (150 mg/kg) DST-09 (580 mg/kg) 40 Fg/L (water) 8 mg/kg (soil) 7, Appendix A, pp. 3, 8, 9; 18, p. 9; 42, pp. 2, 4 Zinc SW-03 (940,000 Fg/L) SW-04 (2,000 Fg/L) DST-08 (10,000 mg/kg) DST-09 (3,400 mg/kg) 20 Fg/L (water) 4 mg/mg (soil) 7, Appendix A, pp. 3, 4, 8, 9; 18, p. 9; 42, pp. 2, 4 Notes: SW = DST = Fg/L = mg/kg = Surface water Dust Micrograms per liter Milligrams per kilogram The hazardous substances listed in the table above were detected in surface water and ESP dust samples collected from Source No.1 during the CDIE EPA conducted in 1993. All samples listed were collected from waste material; therefore, the concentrations of hazardous substances detected were not compared to background levels (Ref. 7, pp. 5, 6, 7, 8, 9, Appendix A, pp. 3,4,8, 9). Hexavalent chromium and strontium were also detected in Source No. 1; however, they are not listed in the table on the previous page because Contract Required Detection Limits are not 18 SD-Hazardous Substances Source No. 1 available for comparison (Ref. 18, p. 9). Sample quantitation limits for the hazardous substances detected in the samples listed in the table on the previous page were not available from the EPA Region 4, Science and Ecosystem Support Division (SESD) (Ref. 39). The EPA Region 4 SESD oversees the Contract Laboratory Program (CLP). Therefore, contract required detection limits for CLP laboratories were provided for comparison (Ref. 18, p. 9). Hazardous Substance Evidence Detection Limit Reference(s) Arsenic MC-06 (180 Fg/L) 5 Fg/L 19. pp. 2, 12; 37, pp. A-6, A-7 Cadmium MC-06 (490 Fg/L) 10 Fg/L 19, pp. 2, 12; 37, pp. A-6, A-7 Chromium MC-06 (12,000 Fg/L) 10 Fg/L 19, pp. 2, 12; 37, pp. A-6, A-7 Lead MC-06 (81,000 Fg/L) 50 Fg/L 19. pp. 2, 12; 37, pp. A-6, A-7 Mercury MC-06 (40 Fg/L) 0.2 Fg/L 19, pp. 2, 12; 37, pp. A-6, A-7 Selenium MC-06 (150 Fg/L) 5 Fg/L 19, pp. 2, 12; 37, pp. A-6, A-7 Silver MC-06 (280 Fg/L) 30 Fg/L 19, pp. 2, 12; 37, pp. A-6, A-7 Notes: MC = Macalloy Corporation Fg/L = Micrograms per liter On March 28, 1995, SCDHEC conducted a RCRA inspection at the facility. The table above lists analytical results for samples collected during the inspection. Sample MC-06 was a liquid sample collected from the discharge pipe to the unlined surface impoundment. The sample represents a source sample; therefore, it was not compared to a background sample. Waste from the discharge pipe is pumped from the furnaces and ESP precipitators (Ref. 38). Method Detection Limits were obtained from the SCDHEC Analytical Services Laboratory (Refs. 19, pp. 2, 12; 37, pp, A-6, A-7). Quality assurance/quality control (QA/QC) information for sample MC-06 is contained in Reference 37, pp. A-191 through A-401. 19 SD-Hazardous Constituent Quantity Source No. 1 2.4.2. Hazardous Waste Quantity 2.4.2.1.1. Hazardous Constituent Quantity Insufficient information is available to evaluate hazardous constituent quantity. Hazardous Constituent Quantity Value (c): Not scored 2.4.2.1.2. Hazardous Wastestream Quantity Insufficient information is available to evaluate hazardous wastestream quantity. Hazardous Wastestream Quantity Value (W): Not scored 2.4.2.1.3. Volume The available information is not consistent regarding the dimensions of Source No. 1. The discrepancies may be due to the change in appearance and disposal practices associated with Source No. 1. During the week of July 21, 1997, EPA and SCDHEC personnel conducted a storm water inspection at the facility. During the inspection, the dimensions of the ESP dust pile were visually estimated to be 200 by 350 ft by 40 ft high (Ref. 6, p. 7). The ESP dust pile was not measured with a measuring instrument; the dimensions are based on visual observations (Ref. 38). A visual representation of the ESP dust pile is presented in Photograph No. 1 of Reference 38. The estimated volume of the ESP dust pile was obtained by multiplying the length, width, and height: 200 ft x 350 ft x 40 ft = 2,800,000 ft3. Then the volume in cubic feet (ft3) was converted to cubic yards (yd3): 2,800,000 ft3 ÷ 27 ft3/yd3 =103,703.7 yd3. Dimension of source (yd3 or gallons): 103,703.7 yd3 References(s):1, Section 2.4.2.1.4, Table 2-5 Volume Assigned Value (V): 103,703.7 yd3 ÷ 2.5 = 41,481.48 2.4.2.1.5. Source Hazardous Waste Quantity Value Source Hazardous Waste Quantity Value: 41,481.48 20 SD-Characterization and Containment Source No. 2 SOURCE DESCRIPTION 2.2 Source Characterization Number of the source: 2 Name and description of the source: Secondary Settling Pond HRS Source Type: Surface Impoundment Source No. 2, the secondary settling pond, is a surface impoundment that was excavated into native soils. Based on the description of past waste management practices at the facility, Source No. 2 was excavated in a previously marshy area that was later filled with slag and ESP dust from the ferrochromium process. According to Macalloy personnel, Source No. 2 is 100 by 75 ft by 6 ft deep. The secondary settling pond receives storm water runoff and process wastewater from concrete settling basins at the gas conditioning tower (GCT) via an underground pipeline system. Suspended solids in the wastewater are allowed to settle in the pond; the resulting sludge is dredged and deposited in piles called dredge spoil piles in the immediate vicinity of Source No. 2. Wastewater in Source No. 2 ranges in color from emerald green to pea-soup green in the eastern half of the settling pond and from muddy green to gray in the western and southwestern half of the pond. Erosion of the impoundment walls is most prevalent in the western and southwestern portion of the impoundment. Wastewater from Source No. 2 is discharged into Shipyard Creek under NPDES Permit No. SC0004014 via Outfall No. 001 (Refs. 5, pp. III-17, III-18; 6, p. 8). Wastewater from the GCT concrete settling basins discharged into Source No. 2 via an underground pipeline system (Ref. 5, p. III-22). Source No. 2 is also affected by groundwater recharge contaminated with hexavalent chromium, possibly originating from the groundwater contamination plume located beneath Source No. 1 (Refs. 5, p. III-18; 31). Analyses of samples collected from Outfall No. 1 indicate the presence of hexavalent chromium and chromium concentrations that exceed NPDES requirements. During the 1993 CDIE that EPA conducted, sediment sample SED-05 was collected below Outfall No. 001 in the ditch that leads into the wetland area adjacent to Shipyard Creek. Analysis of sediment sample SED-05 indicated the presence of cadmium, chromium, cobalt, copper, lead, mercury, nickel, and zinc (Ref. 7, Appendix A, p. 5). Location of the source, with reference to a map of the site: Source No. 2 is located on the eastern side of the facility, adjacent to the eastern wall of Source No. 1 (Ref. 5, p. III-17). Source No. 2 is situated approximately 20 feet west of the western bank of Shipyard Creek (Refs. 3; 6, p. 4)(see Figure 2). 21 SD-Characterization and Containment Source No. 2 Containment Release by overland migration and/or flood: Source No. 2 has no surface water run-on control or runoff management system (Ref. 6, p. 8). During the storm water inspection EPA conducted in 1997, facility personnel indicated that washout occurs in the area where Source No. 2 is located (Ref. 6, p. 8). According to facility personnel, storm water runoff carries material from the dredge spoil piles into Shipyard Creek (Ref. 6, p. 8). Containment value: 10 Reference: 1, Section 4.1.2.1.2.1.1 22 SD-Hazardous Substances Source No. 2 2.4.1 Hazardous Substances Hazardous Substance Evidence Method Detection Limit Reference(s) Arsenic MC-04 (6 Fg/L) 5 Fg/L 19, pp. 2, 11; 37, pp. A-6, A-7 Chromium MC-04 (2,800 Fg/L) 10 Fg/L 19, pp. 2, 11; 37, pp. A-6, A-7 Selenium MC-04 (21 Fg/L) 5 Fg/L 19, pp. 2, 11; 37, pp. A-6, A-7 Note: Fg/L = Micrograms per liter Surface water sample MC-04 was collected during an SCDHEC investigation on March 28, 1995. The sample from Source No. 2 was a green liquid (Ref. 19, pp. 2, 10). Sample MC-04 represents a source sample; therefore, it was not compared to a background sample. Sample MC-04 was collected and analyzed by SCDHEC. Method Detection Limits were obtained from the SCDHEC Analytical Services Laboratory (Ref. 37, pp. A-6, A-7). QA/QC information for sample MC-04 is contained in Reference 37, pp. A-191 through A-401. 23 SD-Hazardous Constituent Quantity Source No. 2 2.4.2. Hazardous Waste Quantity 2.4.2.1.1. Hazardous Constituent Quantity Insufficient information is available to evaluate hazardous constituent quantity. Hazardous Constituent Quantity Value (C): Not Scored 2.4.2.1.2. Hazardous Wastestream Quantity Insufficient information is available to evaluate hazardous wastestream quantity. Hazardous Wastestream Quantity Value (W): Not Scored 2.4.2.1.3. Volume The secondary settling pond, Source No. 2, is approximately 100 ft x 75 ft x 6 ft deep (Ref. 5, p. III-176, p. 4). Based on a map obtained from the facility, the length and width of Source No. 2 mentioned in the RFA are accurate (Ref. 6, p. 4). Therefore, the depth indicated in the RFA was used to calculate volume. The estimated volume of Source No. 2 was obtained by multiplying the length, width, and height: 100 ft x 75 ft x 6 ft = 45,000 ft3. Then the volume in cubic feet (ft3) was converted to cubic yards (yd3): 45,000 ft3 ÷ 27 ft3/yd3 = 1,666.67 yd3. Dimension of source (yd3 or gallons): 1,666.67 yd3 References(s): 1, Section 2.4.2.1.4, Table 2-5 Volume Assigned Value (V): 1,666.67 yd3 ÷ 2.5 = 666.67 2.4.2.1.5. Source Hazardous Waste Quantity Value Source Hazardous Waste Quantity Value: 666.67 24 SD-Characterization and Containment Source No. 3 SOURCE DESCRIPTION 2.2 Source Characterization Number of the source: 3 Name and description of the source: Gas Conditioning Tower (GCT) Concrete Settling Basins HRS Source Type: Surface Impoundment Source No. 3, the GCT Concrete Settling Basins, includes two concrete settling basins constructed to manage the GCT sludge and process wastewater. The eastern basin was constructed in 1969 and the western basin was constructed in 1970. Both basins are currently being used to store processed wastewater and baghouse dust from the gas conditioning towers. Baghouse dust is dust generated from the furnaces during tapping operations. Each basin is 18.4 feet by 33.9 feet. The basins gradually slope to a depth of approximately 5 feet, and the exterior walls of both basins are below grade. The western basin has a ramp on the northern side, and the eastern basin has a ramp on the eastern side. The ramp on the western basin is used to allow front-end loaders to deposit baghouse dust into the unit and remove sludge from the unit (Ref. 5, pp. II-16, III-22). During the VSI in November 1994, EPA personnel observed wastewater being spilled onto the ground in the vicinity of the settling basins. The spills resulted from wastewater flowing over the edges of the settling basins and from the daily operations of front-end loaders removing sludge from the settling basins. Wastewater from the settling basins drains by an underground pipeline system to the Secondary Settling Pond, Source No. 2 (Ref. 5, p. III-23). Location of the source, with reference to a map of the site: Source No. 3, the GCT Concrete Settling Basins, is located in the southern portion of the facility, approximately 50 feet north of the current furnace building and east of the GCT (Ref. 5, p. III-22) (see Figure 2). 25 SD-Characterization and Containment Source No. 3 Containment Release by overland migration and/or flood: Source No. 3 has no surface water run-on control or runoff management system. During the VSI EPA conducted in November 1994, process wastewater was observed spilling onto the ground in the immediate vicinity of Source No. 3 (Ref. 5, p. III-23). During the storm water inspection EPA conducted in 1997, EPA personnel observed surface water runoff in the vicinity of Source No. 3 flowing toward Shipyard Creek (Ref. 6, pp. 6, 7). Containment value: 10 Reference: 1, Section 4.1.2.1.2.1.1 26 SD-Hazardous Substances Source No. 3 2.4.1 Hazardous Substances Hazardous Substance Hexavalent Chromium Evidence Reference(s) GCT wastewater (9.6 mg/L) Refs. 5, p. III-23 Notes: GCT = Gas conditioning tower mg/L = Milligrams per liter The sample listed in the table above was analyzed for TCLP. According to the RFA, on November 8, 1990, a sample was collected from the GCT wastewater that contained hexavalent chromium at 9.6 mg/L (Ref. 5, p. III-23). Hazardous Substance Evidence Reference(s) Cadmium EPA-06 (0.002 mg/L) 24, pp. 1, 2 Chromium EPA-06 (0.79 mg/L) 24, pp. 1, 2 Lead EPA-06 (0.24 mg/L) 24, pp. 1, 2 Mercury EPA-06 (0.01 mg/L) 24, pp. 1, 2 Notes: mg/L = Milligrams per liter Sample EPA-06 was collected from a pile of sludge that was dredged from Source No. 3. This sample was analyzed for TCLP metals. This sample was collected as a split sample during an EPA investigation. The Macalloy split sample was analyzed by General Engineering Laboratories (Ref. 24, pp. 1,2). 27 SD-Hazardous Constituent Quantity Source No. 3 2.4.2. Hazardous Waste Quantity 2.4.2.1.1. Hazardous Constituent Quantity Insufficient information is available to evaluate hazardous constituent quantity. Hazardous Constituent Quantity Value (C): Not Scored 2.4.2.1.2. Hazardous Wastestream Quantity Insufficient information is available to evaluate hazardous wastestream quantity. Hazardous Wastestream Quantity Value (W): Not Scored 2.4.2.1.3. Volume Insufficient information is available for evaluating volume hazardous waste quantity. Volume Assigned Value (V): Not Scored 2.4.2.4 Area Each settling basin is approximately 18.4 x 33.9 ft. (Ref. 5, p. III-22). Based on the Resource Conservation and Recovery Act Part A permit application submitted by the facility, the dimensions in the RFA are conservative (Ref. 27, p. 10). The estimated area of Source No. 3 was obtained by multiplying the length, and the width: 2(18.4 ft x 33.9 ft) = 1,247.52 ft2 (Ref. 5, p. III-22). Dimension of source (ft2 or gallons): 1,247.52 ft2 References(s): 1, Section 2.4.2.1.4, Table 2-5 Area Assigned Value (A): 1,247.52 ft2 ÷ 13 = 95.96 2.4.2.1.5. Source Hazardous Waste Quantity Value Source Hazardous Waste Quantity Value: 95.96 28 SD-Characterization and Containment Source No. 4 SOURCE DESCRIPTION 2.2 Source Characterization Number of the source: 4 Name and description of the source: Gas Conditioning Tower Sludge Pile HRS Source Type: Pile Source No. 4 is a waste pile that contains GCT sludge (Ref. 7, p. 5). Based on the storm water inspection report, this pile may contain sludge dredged from the bottom of the secondary settling pond (Ref. 6, p. 8). Further, this pile is referred to as a “dredge spoil pile” in the storm water inspection report (Ref. 6, p. 8). Location of the source, with reference to a map of the site: Source No. 4 is located south of the secondary settling pond (Source No. 2) along the eastern boundary of the facility property (Ref. 7, pp. 4, 5). Containment Release via overland migration and/or flood: Source No. 4 has no surface water run-on control or runoff management system. The area where Source No. 4 is located is known to flood during heavy rain periods, and washout to Shipyard Creek occurs (Ref. 6, p. 8). Containment value: 10 Reference: 1, Section 4.1.2.1.2.1.1 29 SD-Hazardous Substances Source No. 4 2.4.1 Hazardous Substances Hazardous Substance Evidence Contract Required Detection Limit Reference(s) Chromium SL-06 (2,300 mg/kg) 2 mg/kg 7, Appendix A, p. 6; 18, p. 9; 42, p. 3 Cobalt SL-06 (12 mg/kg) 10 mg/kg 7, Appendix A, p. 6; 18, p. 9; 42, p. 3 Copper SL-06 (34 mg/kg) 5 mg/kg 7, Appendix A, p. 6; 18, p. 9; 42, p. 3 Lead SL-06 (360 mg/kg) 0.60 mg/kg 7, Appendix A, p. 6; 18, p. 9; 42, p. 3 Mercury SL-06 (0.13 mg/kg) 0.10 mg/kg 7, Appendix A, p. 6; 18, p. 9; 42, p. 3 Nickel SL-06 (470 mg/kg) 8 mg/kg 7, Appendix A, p. 6; 18, p. 9; 42, p. 3 Zinc SL-06 (1,600 mg/kg) 4 mg/kg 7, Appendix A, p. 6; 18, p. 9; 42, p. 3 Notes: SL = Sludge mg/kg = Milligrams per kilogram The constituents listed in the table above were detected in sample SL-06, collected from Source No. 4. During the CDIE EPA conducted in 1993, the sample was collected to characterize the waste pile (Ref. 7, pp. 4, 5; 42, p. 3). Sample SL-06 represents a waste sample; therefore, it was not compared to background conditions. Sample quantitation limits for the hazardous substances detected in the samples listed in the table above were not available from the EPA Region 4 SESD (Ref. 39). The EPA Region 4 SESD oversees the CLP. Therefore, Contract Required Detection Limits for CLP laboratories were provided for comparison (Ref. 18, p. 9; 39). 30 SD-Hazardous Constituent Quantity Source No. 4 2.4.2. Hazardous Waste Quantity 2.4.2.1.1. Hazardous Constituent Quantity Insufficient information is available to evaluate hazardous constituent quantity. Hazardous Constituent Quantity Value (C): Not Scored 2.4.2.1.2. Hazardous Wastestream Quantity Insufficient information is available to evaluate hazardous wastestream quantity. Hazardous Wastestream Quantity Value (W): Not Scored 2.4.2.1.3. Volume During the CDIE that EPA conducted in 1993, one sample was collected from Source No. 4. The volume of the pile could not be determined. Insufficient information is available for evaluating volume hazardous waste quantity. Volume Assigned Value (V): Not Scored 2.4.2.4 Area During the CDIE that EPA conducted in 1993, one sample was collected from Source No. 4. The area of the pile could not be determined. Insufficient information is available for evaluating area hazardous waste quantity. Dimension of source (ft2 or gallons): >0 References(s): 1, Section 2.4.2.1.4, Table 2-5; 6, p. 8; 7, pp. 4, 5 Area Assigned Value (A): >0 2.4.2.1.5. Source Hazardous Waste Quantity Value Source Hazardous Waste Quantity Value: >0 31 SD-Summary SITE SUMMARY OF SOURCE DESCRIPTIONS Source No. Source Hazardous Waste Quantity Value Containment Ground Water Surface Water Gas Air Particulate 1 41,481.48 NS 10 NS NS 2 666.67 NS 10 NS NS 3 95.96 NS 10 NS NS 4 >0 NS 10 NS NS Areas of Concern Several areas of concern are present at the facility. However, sufficient information is not available to score the areas of concern as sources. Some of these areas of concern include, but are not limited to the following: • Area of contaminated soil along bank of Shipyard Creek. An adequate background surface soil sample is not available to evaluate this area as a source (Refs. 20; 21; 22). • Marsh slough/lake fill area (Refs. 5, pp. II-10, II-13; 10, p. 3). • Strip fill area (Ref. 5, p. II-13). • Landfill (Ref. 5, p. II-17). • Areas of contaminated soil throughout the facility (Ref. 6, pp, 6 - 9). 32 SWOF-Surface Water Overland Flow/Flood Migration Pathway 4.1 OVERLAND/FLOOD MIGRATION COMPONENT 4.1.1.1 DEFINITION OF HAZARDOUS SUBSTANCE MIGRATION PATH FOR OVERLAND/FLOOD COMPONENT The surface water overland flow path includes surface water runoff from the ESP dust pile, drainage areas along the eastern portion of the facility, and effluent discharge from four NPDES outfalls into Shipyard Creek (Refs. 3; 5, pp. II-26, II-27; 6, p. 6; 28, pp. 2, 4 - 7). The ESP dust pile is located approximately 150 feet from the bank of Shipyard Creek. During the Storm Water Inspection EPA conducted in July 1997, gullies were observed from the top of the ESP dust pile to Shipyard Creek. The gullies were the result of runoff after a recent rain event. Facility personnel also indicated that runoff from the eastern property flows into Shipyard Creek unimpeded after rain events (Ref. 6, p. 8; 28, p. 5 7; 38). Macalloy has an NPDES permit (No. SC0004014) which allows discharge from four outfalls to Shipyard Creek. Outfall No. 001 is permitted release to furnace cooling/gas conditioning effluent and storm water into Shipyard Creek. Effluent is allowed to settle in Source No. 2 and then discharges into Shipyard Creek (Ref. 6, p. 8). Outfall No. 2 is permitted to release slag concentration effluent, fuel/steam cleaning station and storm water; and Outfall Nos. 003 and 004 are permitted to release sanitary wastewater and storm water, respectively (Ref. 12, pp. 2, 6, 10, 11). The storm water discharge often contains elevated levels of inorganic contamination as a result of runoff from contaminated surficial soils at the facility (Refs. 7, pp. 5, appendix A pp. 1, 2; 13 pp. 64, 72, 95, 108, 120, 136, 238). From 1993 to the present, numerous permit violations have been recorded, including violations for Outfalls 001, 002, and 004 listed in the NPDES permit (Refs. 12 pp. 2, 3, 6, 7, 10, 11, 12; 13 pp. 64, 72, 95, 108, 120, 136, 238). Surface water runoff from the Macalloy facility enters Shipyard Creek (1) in a wetland area at Outfalls No. 001 and 002 and (2) just downstream of the wetland area from Outfalls No. 003 and 004. Shipyard Creek flows south-southeast for approximately 0.75 mile then enters the Cooper River. The Cooper River flows south-southeast for 4 miles then converges with Charleston Harbor (Ref. 3). Charleston Harbor flows south for 4 miles then empties into the Atlantic Ocean ending the 15-mile surface water migration pathway (Ref. 3). Shipyard Creek, the Cooper River, and Charleston Harbor are influenced by the tidal effects of the Atlantic Ocean (Ref. 14). Therefore, reverse flow for the 15-mile surface water migration pathway was evaluated upstream of the facility along the Cooper River to about 1 mile upstream of where the Back River converges with the Cooper River (Ref. 3). Shipyard Creek, the Cooper River, and Charleston Harbor are fished. During a 1997 inspection that EPA conducted, Macalloy personnel indicated that fishing occurs from the facility dock (Ref. 6, p.7). NPDES Outfall 004 is located in this area (Refs. 6, p. 4; 12). In April 1998, SCDHEC issued an Emergency Order closing Shipyard Creek to shrimping and crabbing and continuing the closure of harvesting oysters and clams in Shipyard Creek. The closings were prompted after chromium was detected at high levels in shrimp, crabs, oysters, and clams. However, Shipyard Creek is still open to other forms of fishing (Refs. 15; 16, pp. 1, 2, Table 1; 23). 33 SWOF-Observed Release 4.1.2.1 4.1.2.1.1 LIKELIHOOD OF RELEASE Observed Release Direct Observation - Basis for Direct Observation An observed release by direct observation has been documented in three forms at the Macalloy facility including (1) a lake and marsh area along the facility’s eastern border was filled with wastes containing hazardous substances (Ref. 31), (2) storm water contaminated with ESP dust was observed entering Shipyard Creek near Outfall No. 4 (Ref. 38), and (3) Macalloy Corporation has violated its NPDES permit on several occasions (Ref 13). During the VSI, aerial photographs provided by the facility indicated that a lake was located in the area of Source No. 2. In the 1954 aerial photograph, the lake was large with some evidence of fill material being placed in the lake. In 1963 the lake was still intact, but evidence of fill material in the lake was evident (5, pp. A-22, A-23). A 1967 aerial photograph obtained from the Charleston County, South Carolina, Tax Assessor’s office depicts a lake in the mid-eastern portion of the facility in the areas now occupied by Source Nos. 1 and 2 (Ref. 47). In 1991, a former Macalloy plant engineer indicated that the marsh slough was filled; some of the fill material included ashes, sludge, and slag from furnace operations (Ref. 31). Hazardous substances contained in the fill material include arsenic, cadmium, chromium, cobalt, copper, hexavalent chromium, lead, mercury, nickel, strontium, and zinc (Refs. 7, pp. 5, 7, Appendix A, pp. 3, 4, 8, 9; 24, pp. 2, 3). Furthermore, Source No. 2 was excavated into a marsh area believed to be the marsh slough referred to by the former plant engineer (Refs. 5, pp. A-22, A-23). During the 1997 storm water inspection, EPA personnel observed the unpermitted release of storm water runoff into Shipyard Creek. Migration of ESP dust and slag entering the wetland area along Shipyard Creek near Outfall No. 001, and Shipyard Creek near Outfall No. 004 was observed (Refs. 6, pp. 8, 9; 38). The contamination was migrating from storm water washout after a heavy rain period. EPA personnel noted that some areas in the wetland contained stressed vegetation and other areas were completely devoid of vegetation (Ref. 6, pp. 8, 9; 28, pp. 2 - 6). During this investigation, ESP dust and slag were observed on the ground in the drainage areas along the facility’s eastern border, near Shipyard Creek (Refs. 6, pp. 3 through 10; 28, p. 2 - 7). Macalloy Corporation operates under NPDES Permit No. SC0004014, which allows the facility to discharge process wastewater and storm water into Shipyard Creek (Ref. 12, p. 1). During the last several years, the facility has violated its NPDES permit on several occasions and at Outfall Nos. 001, 002, and 004. Outfall 001 receives discharge from Source Nos. 2 and 3, and Outfall 004 is affected by surface water runoff in the area northeast of the old furnace and the immediate vicinity of the sewage treatment plant (Ref. 6, pp. 4, 6). Chromium, cyanide, hexavalent chromium, and lead were discharged into Shipyard Creek at levels that exceeded the daily maximum and monthly averages outlined in the facility’s NPDES permit (Ref. 13). The following table lists the highest exceedances for chromium, cyanide, hexavalent chromium, and lead at Outfall Nos. 001, 002 and 004. Additional violations from January 1995 to July 1998 are contained in Reference 13. 34 SWOF-Observed Release Date Outfall Parameter Permit Requirement Sample Measurement MA/DM Reference Jan 95 1 Hexavalent chromium 0.50 mg/L 5.23 mg/L MA 13, p. 238 Sep 97 1 Chromium 0.82 lbs/day 40.98 lbs/day MA 13, p. 120 Oct 97 1 Chromium 1.6 lbs/day 42.84 lbs/day DM 13, p. 108 Jan 98 1 Cyanide 0.033 mg/L 0.0746 mg/L DM 13, p. 72 Aug 97 2 Lead 8 Fg/L 34.303 Fg/L MA 13, p. 136 Feb 98 2 Hexavalent chromium 0.05 mg/L 0.23 mg/L MA 13, p. 64 Feb 98 2 Hexavalent chromium 0.10 mg/L 0.50 mg/L DM 13, p. 64 Dec 97 4 Lead 0.80 mg/L 2.99 mg/L MA 13, p. 95 Notes: MA DM mg/L lbs/day Fg/L - = = = = = Monthly average Daily maximum Milligrams per liter Pounds per day Micrograms per liter Hazardous Substances in the Release via Direct Observation Chromium Cyanide Hexavalent chromium Lead 35 SWOF-Observed Release Chemical Analysis - Background Samples Sample ID Sample Location Depth (inches) Date Reference(s) MAC-SD-02A Collected from Shipyard Creek upstream Outfall No. 002. 0 - 4 08/10/98 3; 40, p. 6 MAC-SW-01L Collected from Shipyard Creek upstream of Outfall No. 002. 0 - 3 08/07/98 3; 32; 40, p. 5 Notes: MAC SD SW A L - Macalloy Sediment sample Surface water sample Sample collected from 0 to 1 foot Sample collected at low tide In August 1998, the EPA Region 4, Superfund Technical Assessment and Response Team (START 4) conducted a sampling investigation at Macalloy. The investigation was conducted on behalf of the EPA Region 4, Emergency Response and Removal Branch (ERRB). The investigation focused on the impact of Macalloy Corporation on Shipyard Creek and its associated wetlands. Surface water and sediment samples were collected at high and low tide at varying depths. All samples discussed in the table above and the tables that follow were collected at low tide and at depths ranging from 0 to 1 foot for sediment samples and at the surface of the water at about 0 to 3 inches deep (Refs. 32; 40, pp. 1- 11; 41, pp. 1- 10). 36 SWOF-Observed Release - Background Concentrations Sample ID MAC-SD-02A MAC-SW-01L Hazardous Substance Concentration Reporting Limit Reference(s) Chromium 370 mg/kg 3.2 mg/kg 45, pp. 282, 287 Cobalt ND 8.0 mg/kg 45, pp. 282, 287 Nickel 33.6 mg/kg 8.0 mg/kg 45, pp. 282, 288 Chromium 25 Fg/L 10 Fg/L 45, pp. 322, 326 Lead 15 Fg/L 3 Fg/L 45, pp. 322, 326 Nickel ND 40 Fg/L 45, pp. 322, 327 Zinc 83 Fg/L 20 Fg/L 45, pp. 322, 327 Notes: MAC SD SW mg/kg Fg/L ND A L - Macalloy Corporation Sediment sample Surface water sample Milligrams per kilogram Micrograms per liter Not detected Sample collected from 0 to 1 foot Sample collected at low tide Background sediment sample MAC-SD-02 and background surface water sample MAC-SW-01 were collected from Shipyard Creek, upstream of the Macalloy’s Outfall No. 002 (Ref. 40, pp. 5, 6). Concentrations for hazardous substances listed in the table above are presented in Fg/L; however, the concentrations are presented in milligrams per liter (mg/L) in Reference 45. Laboratory QA/QC information for samples MAC-SD-02, and MAC-SW-01 was furnished by Quanterra Environmental Services, Inc., and is in Reference 45, pp. 290 - 318; and 329 -377, respectively. Data validation was performed by START 4 and is in Reference 46. 37 SWOF-Observed Release - Contaminated Samples Sample ID Sample Location Depth (feet) Date Reference(s) MAC-SD-19A Collected from the wetland area adjacent to Shipyard Creek, downstream of Outfall No. 001. 0 - 1 08/10/98 41, p. 7 MAC-SD-25A Collected from channel downstream of Outfall No. 001. 0 - 1 08/11/98 41, p. 9 MAC-SD-31A Collected from the marsh/channel interface along the main waterway of Shipyard Creek. 0 - 1 08/11/98 41, p. 8 MAC-SW-03L Collected from wetland area adjacent to Shipyard Creek about 300 feet downstream of Outfall No. 001. 0 - 3 inches 08/04/98 32; 41, p. 1 MAC-SW-04L Collected from wetland area adjacent to Shipyard Creek about 800 feet downstream of Outfall No. 001. 0 - 3 inches 08/04/98 32; 41, p. 1 Notes: MAC SW SD A L - Macalloy Corporation Surface water sample Sediment sample Sample collected from 0 to 1 foot Sample collected at low tide Surface water and sediment samples presented in the table above and on the previous page were collected in Shipyard Creek. The sample locations were recorded using Global Positioning System (GPS) coordinates (Refs. 32; 41, pp. 1, 7, 8, 9). The GPS coordinates were plotted on a 1998 aerial photograph of the Macalloy area. The scale of the aerial photograph was not provided; therefore, an estimated scale was calculated using the USGS topographic quadrangle map of Charleston, South Carolina 1955 (PR 1979). The large furnace building was measured on the topographic map and a relative scale was determined for the aerial photograph. Based on the aerial photograph, the sample locations were recorded on Figure 3 of this documentation record. The distances of the samples presented in the table above were then determined using the estimated scale calculated for the aerial photograph, GPS coordinates, the topographic map, and Figure 3 (Refs. 3; 40, pp. 1 - 11; 41, pp. 1 - 10; 47; 50). 38 SWOF-Observed Release - Contaminated Concentrations Sample ID MAC-SD-19A MAC-SD-25A MAC-SD-31A MAC-SW-03L MAC-SW-04L Hazardous Substance Concentration Reporting Limit Reference(s) Chromium 1,670 mg/kg 2.5 mg/kg 45, pp. 96, 103, Cobalt 12.5 mg/kg 6.3 mg/mg 45, pp. 96, 103 Nickel 202 mg/kg 6.3 mg/kg 45, pp. 96, 104 Chromium 3,430 mg/kg 1.3 mg/kg 45, pp. 38, 48 Cobalt 23.7 mg/kg 3.4 mg/kg 45, pp. 38, 48 Nickel 715 mg/kg 3.4 mg/kg 45, pp. 38, 49 Chromium 1,830 mg/kg 2.1 mg/kg 45, pp. 36, 42 Cobalt 11.8 mg/kg 5.3 mg/kg 45, pp. 36, 42 Nickel 333 mg/kg 5.3 mg/kg 45, pp. 36, 43 Chromium 2,600 Fg/L 10 Fg/L 45, pp. 236, 246 Lead 60 Fg/L 3 Fg/L 45, pp. 236, 246 Nickel 56 Fg/L 40 Fg/L 45, pp. 236, 247 Zinc 320 Fg/L 20 Fg/L 45, pp. 237, 247 Chromium 630 Fg/L 10 Fg/L 45, pp. 235, 240 Notes: MAC SD SW mg/kg Fg/L A L - Macalloy Corporation Sediment sample Surface water sample Milligrams per kilogram Micrograms per liter Sample collected from 0 to 1 foot Sample collected at low tide Concentrations for hazardous substances listed in the table above are presented in Fg/L; however, the concentrations are presented in milligrams per liter (mg/L) in Reference 45. Laboratory QA/QC information for the surface water and sediment samples listed in the table above was furnished by Quanterra Environmental Services, Inc., and is contained in Reference 45. Data validation was performed by START 4 and is contained in Reference 46. 39 SWOF-Observed Release Attribution: Macalloy produces a ferrochromium alloy and generates ESP dust and slag as byproducts (Refs. 5, p. II-3; 6, pp. 1, 2; 7, p. 2). GCT sludge is generated from wastewater settling in lined and unlined surface impoundments. Analyses of waste samples collected from the GCT sludge and ESP dust and slag indicate the presence of arsenic, cadmium, chromium, cobalt, copper, hexavalent chromium, lead, mercury, nickel, strontium, and zinc (Refs. 7, pp. 5, 7, Appendix A, pp. 3, 4, 8, 9; 24, pp. 2, 3). Over the years, the facility stored and disposed of the GCT sludge and ESP dust and slag in various locations on site (Refs. 5, p. I-2; 6, pp. 2, 3, 6). Facility personnel also indicated that the ESP dust and slag were used as fill material in several marshy areas at the facility (Refs. 5, p. II-10; 6, p. 2; 31). Hazardous substances detected in the GCT sludge and ESP dust slag include arsenic, cadmium, chromium, cobalt, copper, hexavalent chromium, lead, mercury, nickel, strontium, and zinc (Refs. 7, pp. 5, 7, Appendix A, pp. 3, 4, 8, 9; 24, pp. 2, 3). A 1967 aerial photograph obtained from the Charleston County, South Carolina, Tax Assessor’s office depicts a lake in the mid-eastern portion of the facility in the area that is now occupied by Sources 1 and 2 (Ref. 47). In December 1993, EPA collected a sediment sample (SED-05) from the ditch below Outfall No. 001. This ditch leads to the wetland area adjacent to Shipyard Creek (Refs. 7, p. 4; 36; 38, p. 2). Analysis of sediment sample SED-05 indicated the presence of hazardous substances including arsenic, cadmium, chromium, cobalt, copper, lead, mercury, nickel, and zinc (Ref. 7, Appendix A, p. 5). During the 1997 storm water inspection, EPA personnel observed runoff from spoil piles dredged from Source No. 2 towards Shipyard Creek. Facility personnel indicated that the runoff from the spoil piles covered the road area and ground between the piles and the creek and discharged to Shipyard Creek (Ref. 6, p. 8). In July 1997, the EPA Region 4 SESD collected surface soil samples (MSS-03 through MSS10) along the eastern perimeter of the facility property. Analyses of the samples indicated that an area of surficial contamination exists in the drainage areas of Sources 1, 3, and 4 and along the western bank of Shipyard Creek (Refs. 6, pp. 4, 7, 8, 9; 20; 43, pp. 1- 14). Constituents detected in samples collected from this area of surficial contamination include arsenic, chromium, copper, cadmium, mercury, and lead (Ref. 6, pp. T-3a, 3b, Appendix B, pp. 3 through 10). These samples were collected from areas where evidence of unpermitted runoff was observed flowing into the wetland area adjacent to Shipyard Creek (Refs. 28, pp. 4 - 7; 38). Hazardous substances detected in these samples were also detected in on-site sources (See pages 18, 19,23, 27, and 30 of this HRS documentation record). Discharge monitoring reports for Macalloy’s NPDES permit indicated that the facility has exceeded its permit requirements on several occasions. Hazardous substances including hexavalent chromium, chromium, cyanide, and lead have been released at concentrations above the facility’s permit limits (Ref. 13, pp. 64, 72, 95, 108, 120, 136, 238). In 1998, START 4 collected surface water and sediment samples from Shipyard Creek to determine the impacts of the Macalloy Corporation facility on Shipyard Creek and its associated wetlands (Refs. 40, pp. 1 - 11; 41, pp. 1 - 10). Analyses of SWOF-Observed Release 40 samples collected from Shipyard Creek indicate the presence of several hazardous substances including chromium, cobalt, nickel, and zinc at elevated concentrations (Ref. 45, pp. 42, 43, 48, 49, 103, 104, 240, 246, 247). During the START 4 sampling event, analytical results for background samples collected from Shipyard Creek were compared to the samples collected downstream of the outfalls at the Macalloy facility. During the START 4 sampling event, background surface water and sediment samples were collected from Rathall Creek, a tidally influenced tributary of the Wando River (Refs. 3; 40, p. 10; 41, p. 10; 49, pp. 3, 4). The Wando River is part of the Cooper River Basin (Ref. 48, pp. viii). The immediate vicinity of Rathall Creek is not affected by industry (Ref. 3). It appears that Shipyard Creek is significantly impacted by industry based on hazardous substances detected in sediment and surface water samples. Hazardous Substances Released: Chromium Cobalt Lead Nickel Zinc ========================================================================== Observed Release Factor Value: 550 41 SWOF-Potential to Release 4.1.2.1.2 POTENTIAL TO RELEASE 4.1.2.1.2.1 Potential to Release by Overland Flow Potential to release was not scored because an observed release to surface water was established by direct observation chemical analysis (see Section 4.1.2.1.1 of this documentation record). 42 SWOF/Drinking-Toxicity/Persistence 4.1.2.2 WASTE CHARACTERISTICS 4.1.2.2.1 Toxicity/Persistence Hazardous Substance Source Number Toxicity Factor Value Persistence* Toxicity/ Persistence Factor Value** Arsenic 1,2 10,000 1 10,000 1, Section 4.1.2.2.1; 2, p. B-2 Cadmium 1,3 10,000 1 10,000 1, Section 4.1.2.2.1; 2, p. B-4 Chromium 1,2,3, 4 10,000 1 10,000 1, Section 4.1.2.2.1; 2, p. B-5 Cobalt 1,4 1 1 1 1, Section 4.1.2.2.1; 2, p. B-6 Copper 1,3,4 *** 1 ** 1, Section 4.1.2.2.1; 2, p. B-6 Lead 1,3,4 10,000 1 10,000 1, Section 4.1.2.2.1; 2, p. B13 Mercury 1,3,4 10,000 0.40 4,000 1, Section 4.1.2.2.1; 2, p. B13 Nickel 1,3,4 10,000 1 10,000 1, Section 4.1.2.2.1; 2, p. B14 Selenium 1 100 1 100 1, Section 4.1.2.2.1; 2, p. B17 Silver 1 100 1 100 1, Section 4.1.2.2.1; 2, p. B18 Zinc 1,3,4 10 1 10 1, Section 4.1.2.2.1; 2, p. B20 Ref(s) * ** = Persistence value for rivers = Toxicity/persistence factor values can be found in Table 4-12 of Reference 1. *** = A toxicity value is not available for copper in the SCDM database. ========================================================================== Toxicity/Persistence Factor Value: 10,000 43 SWOF/Drinking-Hazardous Waste Quantity 4.1.2.2.2 Hazardous Waste Quantity Source Number Source Hazardous Waste Quantity Value (Section 2.4.2.1.5) Is source hazardous constituent quantity data complete? (Yes/No) 1 41,481.48 No 2 666.67 No 3 95.96 No 4 >0 No Sum of Values: 42,244.11 4.1.2.2.3 Waste Characteristics Factor Category Value Toxicity/persistence factor value (10,000) X hazardous waste quantity factor value (10,000): 1 x 108 ========================================================================== Hazardous Waste Quantity Factor Value: 10,000 Waste Characteristics Factor Category Value: 100 44 SWOF/Drinking-Targets 4.1.2.3 DRINKING WATER TARGETS No potable surface drinking water intakes have been identified within the 15-mile surface water target distance limit (Refs. 3; 25, p. 1). Shipyard Creek and the Cooper River are affected by tidal influences from the Atlantic Ocean (Ref. 14). The surface water intake for the City of Charleston Commissioners of Public Works (CPW) is located on the Bushy Park Reservoir which is located on the Back River about 0.25 mile upstream of the Back River’s confluence with the Cooper River. The CPW intake is not located along the 15-mile surface water target distance limit. Further, the CPW intake is not affected by reverse flow caused by tidal influence because CPW pumps water into the Bushy Park Reservoir via Durham Canal, and water exiting the reservoir is released from the Bushy Park Dam. The Bushy Park Dam prevents tidal flow from entering the Bushy Park Reservoir (Refs. 3; 26, pp.3, 4). ========================================================================== Nearest Intake Factor Value: 0 45 SWOF/Drinking-Resources 4.1.2.3.3 Resources The Cooper River is used for recreational purposes, including fishing, boating, and water skiing (Ref. 14). ========================================================================== Resources Factor Value: 5 46 SWOF/Food Chain-Toxicity/Persistence/Bioaccumulation 4.2.3.2 4.1.3.2.1 WASTE CHARACTERISTICS Toxicity/Persistence/Bioaccumulation Persistence* Bioaccumulation Toxicity/ Persistence/ Bioaccumulation Factor Value** Hazardous Substance Source No. Toxicity Factor Value Arsenic 1,2 10,000 1 500*** 5 x 106 1, Section 4.1.3.2.1; 2, p. B-2 Cadmium 1,3 10,000 1 5,000 5 x 107 1, Section 4.1.3.2.1; 2, p. B-4 Chromium 1,2,3, 4 10,000 1 500*** 5 x 106 1, Section 4.1.3.2.1; 2, p. B-5 Cobalt 1,4 1 1 0.50 0.50 1, Section 4.1.3.2.1; 2, p. B-6 Copper 1,3,4 **** 1 50,000 **** 1, Section 4.1.3.2.1; 2, p. B-6 Lead 1,3,4 10,000 1 5,000*** 5 x 107 1, Section 4.1.3.2.1; 2, p. B-13 Mercury 1,3,4 10,000 0.40 50,000 2 x 108 1, Section 4.1.3.2.1; 2, p. B-13 Nickel 1,3,4 10,000 1 500*** 5 x 106 1, Section 4.1.3.2.1; 2, p. B-14 Selenium 1 100 1 5,000 5 Silver 1 100 1 50 5,000 1, Section 4.1.3.2.1; 2, p. B-18 Zinc 1,3,4 10 1 50,000*** 5 X 105 1, Section 4.1.3.2.1; 2, p. B-20 47 x 105 Ref(s) 1, Section 4.1.3.2.1; 2, p. B-17 SWOF-Food Chain-Toxicity/Persistence/Bioaccumulation Notes: * ** = Persistence value for rivers = Toxicity/persistence/bioaccumulation factor values can be found in Table 4-16 of Reference 1. *** = Salt water values were used for arsenic, chromium, lead, nickel, and zinc **** = A toxicity value is not available for copper in the SCDM database. ========================================================================== Toxicity/Persistence/Bioaccumulation Factor Value: 2 x 108 48 SWOF/Food Chain-Hazardous Waste Quantity 4.1.3.2.2 Hazardous Waste Quantity Source Number Source Hazardous Waste Quantity Value (Section 2.4.2.1.5) Is source hazardous constituent quantity data complete? (Yes/No) 1 41,481.48 No 2 666.67 No 3 95.96 No 4 >0 No Sum of Values: 42,244.11 4.1.3.2.3 Waste Characteristics Factor Category Value Toxicity/persistence factor value (4,000) X hazardous waste quantity factor value (10,000): 4 x 107 (Toxicity/persistence (4,000) x hazardous waste quantity [10,000] X bioaccumulation potential factor value [50,000]): 2 x 1012 ========================================================================== Hazardous Waste Quantity Assigned Value: 10,000 Waste Characteristics Factor Category Value: 1,000 49 SWOF/Food Chain-Targets 4.1.3.3 HUMAN FOOD CHAIN THREAT-TARGETS Actual Human Food Chain Contamination Actual contamination of a fishery has not been documented. Shipyard Creek is fished; however, it is not known whether the exact locations where the samples were collected are fished (Refs. 14, 23). Closed Fisheries No known fisheries have been closed due to contamination within the 15-mile surface water target distance limit. However, on April 30, 1998, SCDHEC issued an order prohibiting the harvesting and collecting of shrimp and crabs in Shipyard Creek due to high concentrations of chromium (Ref. 23). Other types of fishing are still permitted in the creek (Refs. 14; 15; 23). The alloy produced at Macalloy contains about 65 percent chromium (Ref. 27, p. 5). Emission control dust or sludge from ferrochromium production is an EPA listed hazardous waste (Ref. 44, p. 62). Furthermore, the facility has exceeded the daily maximum and monthly average concentrations of hazardous substances including chromium, hexavalent chromium, lead, and cyanide allowed to be discharged into Shipyard Creek under its NPDES permit. (Also see pages 34, 35 of this documentation record and Reference Ref. 13, pp. 64, 72, 95, 108, 120, 136, and 238). In addition, during a storm water inspection, EPA personnel observed ESP dust and slag migrating to Shipyard Creek and adjacent wetland area (Ref. 6, pp. 6, 7, 8; 38, pp. 1 - 8). Benthic Tissue In the summer of 1997, National Oceanic and Atmospheric Administration (NOAA) conducted an Environmental Monitoring and Assessment Program (EMAP) study in the Carolinian Province. During this study, NOAA collected and analyzed benthic tissue samples for chromium; however, the control sites for the benthic tissue samples could not be determined. Analytical data from the NOAA study indicated that elevated levels of chromium in the benthic (oyster) tissue samples collected from Shipyard Creek than found in other EMAP-Carolinian Province sites (Ref. 16, pp. 1, 2, Attachment 1, p. 1, Attachment 3, Table 1). As a result, SCDHEC continued the existing closure of Shipyard Creek for clam and oyster harvesting (Ref. 23). 50 SWOF/Food Chain-Food Chain Individual 4.1.3.3.1 Food Chain Individual Sample ID: MAC-SD-19A, MAC-SD-25A, MAC-SD-31A, MAC-SW-03L, MAC-SW-04L Hazardous Substance: Chromium, lead, nickel, and zinc Bioaccumulation Potential: 500, 5,000, 500, 50,000, respectively Identity of Fishery Type of Surface Water Body Shipyard Creek Dilution Weight Reference Moderate to large stream 0.01 1, Table 4-13; 3 Cooper River River 0.001 1, Table 4-13; 3; 14 Charleston Harbor Coastal tidal waters 0.0001 1, Table 4-13; 3 A food chain individual value of 20 was assigned because an observed release to Shipyard Creek was documented by chemical analysis. The release contained several hazardous substances with bioaccumulation potential factor values greater than or equal to 500 which include chromium (500), lead (5,000), nickel (500), and zinc (50,000). Sediment and surface water samples MAC-SD-19A, MAC-SD-25A, MAC-SD-31A, MAC-SW-03L, MAC-SW-04L were collected from Shipyard Creek. It is not known whether the exact location where the samples were collected are fished; however, Shipyard Creek is fished downstream of the sample locations (Refs. 3; 14; 23; 41, pp. 1, 7, 8). Charleston Harbor is fished recreationally. Fish caught in Charleston Harbor include red drum, black drum, spotted sea trout, and sheep’s head. Commercial crabbing and shrimping also occur in Charleston Harbor (Ref. 51). During the storm water inspection, a facility representative stated that fishing occurs from the facility dock located near NPDES Outfall No. 004 (Ref. 28, pp. 4). Therefore, an observed release to surface water is documented with a fishery downstream. The surface water and sediment samples listed above were compared to background samples collected from Shipyard Creek, MAC-SW-01L for surface water samples and MAC-SD-02A, for sediment samples (Ref. 40, pp, 5, 6). ========================================================================== Food Chain Individual Factor Value: 20 51 SWOF/Food Chain-Level I Concentrations 4.1.3.3.2 Population 4.1.3.3.2.1 Level I Concentrations No Level I concentrations were documented. Samples were collected from sessile benthic organisms; however, the locations where the control samples were collected could not be determined. During the investigation that NOAA conducted in 1997, tissue samples were collected from oysters; however, the exact sampling locations are not known (Ref. 16, p. 1, 2). ========================================================================== Level I Concentrations Factor Value: 0 52 SWOF/Food Chain-Level II Concentrations 4.1.3.3.2.2 Level II Concentrations No Level II concentrations have been documented. During the START 4 sampling event, surface water and sediment samples were collected from Shipyard Creek. Shipyard Creek is fished; however, it is not known whether the exact locations where the samples were collected are fished (Refs. 14; 23; 41, pp. 1, 7 - 9). ========================================================================== Level II Concentrations Factor Value: 0 53 SWOF/Food Potential Human Food Chain Contamination 4.1.3.3.2.3 Potential Human Food Chain Contamination Identity of Fishery Annual Production in Pounds Type of Surface Water Body Average Annual Flow Rate Population Value (Pi) Dilution Weight (Di) Population Value x Dilution Weight (Pi x Di) Reference Shipyard Creek >0 Moderate to large stream <1,000 cfs 0.03 0.01 0.0003 1, Tables 4-13, 418; 3 Cooper River >0 Large stream to river 4,500 cfs 0.03 0.001 0.00003 1, Tables 4-13, 418; 3; 14 Charleston Harbor >0 Coastal tidal waters NA 0.03 0.0001 0.000003 1, Tables 4-13, 418; 3 Sum of Human Food Chain Population Values x Dilution Weights (Pi x Di) =0.000333 Population Values x Dilution Weights (Pi x Di) ÷ 10 = 0.0000333 Notes: cfs = Cubic feet per second NA = Not Applicable (for coastal tidal waters) The flow rate for Shipyard Creek is not known. For scoring purposes, the flow rate was estimated to be between 100 and 1,000 cubic feet per second (cfs) based on the U.S. Geological Survey 7.5-minute series topographic quadrangle map of Charleston, South Carolina (Ref. 3). Information was not available on the annual production of fish from the surface water bodies listed in the table above. However, because Shipyard Creek, the Cooper River, and Charleston Harbor are fisheries, for scoring purposes, the annual production was assumed to be greater than zero (Refs. 14; 15; 51). ========================================================================== Potential Human Food Chain Contamination Factor Value: 0.0000333 54 SWOF-Environment-Ecosystem Toxicity\Persistence\Bioaccumulation 4.1.4.2 WASTE CHARACTERISTICS 4.1.4.2.1 Ecosystem Toxicity/Persistence/Bioaccumulation Hazardous Substance Source No. Ecosystem Toxicity Persistence* Ecosystem Toxicity/ Persistence Factor Value (Table 4-20) Arsenic 1,2 100** 1 100 1, Section 4.1.4.2.1; 2, p. B-2 Cadmium 1,3 1,000 1 1,000 1, Section 4.1.4.2.1; 2, p. B-4 Chromium 1,2,3, 4 100 1 100 1, Section 4.1.4.2.1; 2, p. B-5 Cobalt 1,4 *** 1 *** 1, Section 4.1.4.2.1; 2, p. B-6 Copper 1,3,4 100 1 100 1, Section 4.1.4.2.1; 2, p. B-6 Lead 1,3,4 1,000 1 1,000 1, Section 4.1.4.2.1; 2, p. B-13 Mercury 1,3,4 10,000 0.40 4,000 1, Section 4.1.4.2.1; 2, p. B-13 Nickel 1,3,4 1,000** 1 1,000 1, Section 4.1.4.2.1; 2, p. B-14 Selenium 1 1,000 1 1,000 1, Section 4.1.4.2.1; 2, p. B-17 Silver 1 10,000 1 10,000 1, Section 4.1.4.2.1; 2, p. B-18 Zinc 1,3,4 100** 1 100 1, Section 4.1.4.2.1; 2, p. B-20 Reference Notes: * = Persistence value for rivers ** = Salt water values were used for arsenic, nickel, and zinc. *** = No ecosystem toxicity value is available for cobalt. 55 SWOF-Environment-Ecosystem Toxicity\Persistence\Bioaccumulation Hazardous Substance Ecosystem Toxicity/ Persistence Factor Value Bioaccumulation Factor Value (Section 4.1.3.2.1.2) Ecosystem Toxicity/ Persistence/ Bioaccumulation Factor Value (Table 4-21) Arsenic 100** 500 5 x 104 1, Section 4.1.4.2.1; 2, p. B-2 Cadmium 1,000 5,000 5 x 106 1, Section 4.1.4.2.1; 2, p. B-4 Chromium 100 500** 5 x 104 1, Section 4.1.4.2.1; 2, p. B-5 Cobalt ** 5,000 *** 1, Section 4.1.4.2.1; 2, p. B-6 Copper 100 50,000 5 x 106 1, Section 4.1.4.2.1; 2, p. B-6 Lead 1,000 5,000 5 x 106 1, Section 4.1.4.2.1; 2, p. B-13 Mercury 4,000 50,000 2 x 108 1, Section 4.1.4.2.1; 2, p. B-13 Nickel 1,000** 500 5 x 105 1, Section 4.1.4.2.1; 2, p. B-14 Selenium 1,000 5,000 5 x 106 Silver 10,000 50 5 x 105 Zinc 100** 50,000** 5 X 106 Notes: Reference 1, Section 4.1.4.2.1; 2, p. B-20 * ** = Persistence values for rivers = Salt water values were used for arsenic, chromium, cobalt, nickel, and zinc. *** = No ecosystem toxicity value is available for cobalt. ========================================================================== Ecosystem Toxicity/Persistence/Bioaccumulation Factor Value: 2 x 108 56 SWOF/Environment-Hazardous Waste Quantity 4.1.4.2.2. Hazardous Waste Quantity Source Number Source Hazardous Waste Quantity Value (Section 2.4.2.1.5) Is source hazardous constituent quantity data complete? (Yes/No) 1 41,481.48 No 2 666.67 No 3 95.96 No 4 >0 No Sum of Values: 42,244.11 4.1.4.2.3. Waste Characteristics Factor Category Value Ecosystem toxicity/persistence factor value (4,000) X hazardous waste quantity factor value (10,000): 4 x 107 (Ecosystem toxicity/persistence [4,000] X hazardous waste quantity [10,00] x bioaccumulation potential factor value [50,000]): 2 x 1012 ========================================================================== Hazardous Waste Quantity Factor Value: 10,000 Waste Characteristics Factor Category Value: 1,000 57 SWOF/Environment-Targets 4.1.4.3 ENVIRONMENTAL THREAT - TARGETS Level I Concentrations Sample ID: MAC-SW-04L Hazardous Substance Hazardous Substance Concentration Fg/L Benchmark Concentration Fg/L Benchmark References Chromium 630 Fg/L 11 Fg/L AWQC/AALAC 2, p., B-47; 45, pp. 235, 240 Notes: Fg/L = Micrograms per liter AWQC = Ambient Water Quality Criteria AALAC = Ambient Aquatic Life Advisory Concentrations Most Distant Level I Sample Sample ID: MAC-SW-04L Distance from Probable point of entry: about 800 feet (0.15 mile) References: 41, p. 1; 45, pp. 235, 240; 50 Surface water downstream of water sample, 002 (Refs. 3; sample MAC-SD-04L was collected from Shipyard Creek about 800 feet Outfall No. 001 (Refs. 3; 41, p. 1; 50). The background surface MAC-SW-01L was collected from Shipyard Creek upstream of Outfall 40, p. 5; 50) Most Distant Level II Sample The most distant Level II sample is MAC-SD-31A. Sediment sample MAC-SD-31A is located within the area scored as Level I concentrations (Refs. 3; 41, pp. 1, 8; 50). Also see Figure 3. 58 SWOF/Environment-Level I Concentrations 4.1.4.3.1 Sensitive Environments 4.1.4.3.1.1. Level I Concentrations Sensitive Environments Several Federally designated and state-designated endangered or threatened species are located in Charleston County and coastal waters within the 15-mile surface water migration pathway target distance limit; however, the exact locations of these species are not known and were not scored in this documentation record (Refs. 14; 29, pp. 3, 4; 30, pp. 2 - 4). Wetlands Based on the Wetlands Inventory Map for Charleston, South Carolina, the wetland area adjacent to Shipyard Creek affected by Level I concentrations is classified as estuarine intertidal emergent persistent regularly flooded (E2EM1N) (Ref. 17) (see Figure 3). About 800 feet of wetland frontage were determined to be affected by Level I concentrations. The wetland frontage was calculated from the PPE at Outfall No. 001, to surface water sample MAC-SW-04L, along the in-water segment of Shipyard Creek (Refs. 3; Figure 3). In times of reverse flow caused by tidal influence, the distance from the PPE at Outfall No. 004, along the inwater segment of Shipyard Creek, to surface water sample MAC-SW-03L is 2,000 feet (0.38 mile)(Ref. 3; Figure 3). Wetland Wetland Frontage References Wetland area contiguous with Shipyard Creek 0.15 mile 3; 17; 41, p. 1 Total wetland frontage: 0.15 mile Wetland value: 25 Sum of sensitive environments and wetlands: 25 25 x 10 = 250 ========================================================================== Level I Concentrations Factor Value: 250 59 SWOF/Environment-Level II Concentrations 4.1.4.3.1.2. Level II Concentrations Sensitive Environments No Level II sensitive environments were scored. Wetlands No Level II sensitive wetlands were scored. All wetlands identified were scored using Level I or potential contamination criteria (see pages 59, 61, and 62 of this documentation record). Sum of Sensitive Environments Value + Wetland Value: 0 ========================================================================== Level II Concentrations Factor Value: 0 60 SWOF/Environment-Potential Contamination 4.1.4.3.1.3 Potential Contamination Sensitive Environments Type of Surface Water Body River Sensitive Environment Value(s) Sensitive Environment The Cooper River is a habitat for the Federally designated endangered Shortnose sturgeon, Acipenser Brevirostrum. 75 Reference 1, Table 423; 14; 29; 30 Sum of Environment Value: 75 Wetlands Type of Surface Water Body Wetlands Frontage Wetlands Value Reference Shipyard Creek 1 mile 25 1, Table 4-24; 3; 17 Cooper River 17 miles 450 1, Table 4-24; 3; 17 Charleston Harbor 2 miles 50 1, Table 4-24; 3; 17 Total Wetland Frontage: 20 miles 61 SWOF/Environment-Potential Contamination Name of Surface Water Body Sum of Sensitive Environment Values (Si) Shipyard Creek Wetland Frontage Value (Wi) Dilution Weight (Di) Di(Wi + Si) References None identified 25 0.01 0.25 1, Tables 413, 4-24; 3 Cooper River 75 450 0.001 0.525 1, Tables 413, 4-24; 3; 14 Charleston Harbor None identified 50 0.0001 0.005 1, Tables 413, 4-24; 3 Sum of Sum of Dj(Wj + Sj): 0.78 (Sum of Dj[Wj + Sj])/10: 0.078 ========================================================================== Potential Contamination Factor Value: 0.08 62
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