LCP Chemicals Upland Feasibility Plan

Overview 

   We received for review the LCP Upland Feasibility Study dated May 2007. This Feasibility Study (FS) is the culmination of many previous studies and plans conducted at the LCP site over the last decade. Feasibility Studies are required by law to list the options for site cleanup, indicate which remedy was chosen by the site owners with the EPA, and discuss how that decision was reached. The Feasibility Study is meant to ensure that the legal criteria required for all Superfund sites can be met by a selected cleanup. The criteria established by Congress for EPA regulated cleanups are: meets all laws; reduction in toxicity, mobility, or volume; implementable; effective; safe for humans and the environment; state acceptance; and, community acceptance. It is fair to say that the Feasibility Study provided for our review does not allow determining if the criteria are fully met.

Background 

   The LCP Chemicals Superfund site is a 550-acre area along the Turtle River in Glynn County, Georgia. At the time the site was closed, and EPA oversight initiated, the site was a bleach production facility; earlier industries include petroleum products and paint. These operations left the area heavily contaminated with known chemical toxins. Ground, water and air pollution occurs at LCP. The site has several different “Operable Units” for the marsh areas, the groundwater, a Caustic Brine Pool, and the focus of this study, the Uplands Soils.

   The “uplands” refers to dry areas above the tidal zones of the marsh that includes several types of wildlife habitat, areas where toxins were removed or treated in place, and areas with existing structures or former foundations. Chemical contaminants include elements such as Mercury and Lead; and organic materials such as polychlorinated biphenyl’s (PCBs) and carcinogenic hydrocarbons. The elemental toxins cannot be broken down in nature to less complicated materials, although they can be diluted below toxicity thresholds. Organic materials can be mineralized—broken down to carbon, hydrogen or oxygen. However, in the process organics may release Chlorine or chlorinated compounds that are as bad as or worse than the parent chemical. How fast and what types of breakdown and dilution are occurring is determined by environmental factors.  In other words, the uplands are very complex areas.

Feasibility Study 

   An emergency removal action at this site removed much of the acute threat—the most dangerous materials that can cause immediate harm. Earlier, a Remedial Investigation (RI) looked at soils in the uplands for long-term threats.  The RI was the data-collection phase where sampling took place. In the RI study sampling included surface soil samples, bores for subsurface sampling, and long trenches that were dug for sampling along the walls of the trench.

   Previously, several toxicity models were attempted that essentially treated the uplands as one large site. These models ignored the complexity of the site, and had the effect of statistically diluting dangerous toxin levels by averaging those samples with samples from clean areas. This current model uses two zones. However, while we agree with the use of subsets of the site, the criteria for choosing areas was not well-described. The inclusion of samples within zones appears artificial and capricious, rather than based on ecology or technology.

   Several use-scenarios were examined ranging from daytime workers to residential dwellers. These are fairly standard models in risk assessment. However, there was a lack of ecological modeling—use as habitat with no human activity. Since it is likely that the large and complex uplands may eventually have multiple uses, a Feasibility Study should take all potential uses into consideration. Besides, it is the law that environmental benefit should be considered.

   Several site remedies were proposed for the uplands. These remedies (soil cleanups) include: 

“No action”—doing nothing;

Natural attenuation—another form of doing nothing, essentially doing nothing with testing every couple of years;

Containment, this option has several categories:

- Chemical extraction and treatment of soils followed by return of the cleaned soils to the upland;

- Bioremediation/phytoremediation-- mostly adding nutrients to soil or planting vegetation with a goal of accelerating the absorption of chemicals;

- In situ stabilization-- using cement or drying agents to immobilize toxins in-place;

- Capping and/or soil covers over the bad areas; and,

Removal of the most contaminated areas, with some backfilling with clean or cleaner materials.  

   The “No action” remedy is provided as an inexpensive alternative for baseline cost versus benefit calculations. This site is too dangerous to leave in its current state without treatment.

   There are problems with this Feasibility Study report. One problem is that the manner in which the site was divided into zones minimizes risk. Areas that might be used for commercial development are lumped in with areas that are likely to be set aside and left natural. This changes the exposure dynamics and has the effect of making the site seem safer for redevelopment than it actually would be. Secondly, some needed information was omitted, or obscured, making it difficult to verify the soil volume estimates. For each exposure scenario the amount of soil area that needs to be treated to make the site safe is calculated. Then each potential treatment is assigned a dollar amount per treatment volume. Since some of the potential remedies were rejected based on costs it is important to understand the calculations for treatments with nearly the same costs, and it was not possible to check the math in this report.

   That said, the proposed bioremediation options were no better than doing nothing, and both options are properly declined for further consideration. Also, techniques that only remove organics will have little effect on elemental toxins; for example, Mercury is an element and cannot be broken down further or easily separated from soil. Chemical extraction methods that only dealt with organic removal were properly declined for consideration.  Further, some of the capping options that used materials inappropriate for this site were rejected based on technical grounds, and we concur with those decisions.

   It does become difficult to understand the efficacy of some capping options versus removal options without better data on the volumes and areas affected. It also seems highly improbable that a single best treatment method could be applied to the entire uplands site.

   This plan would greatly benefit from a final use plan. If there were some direction for the site, either leaving it as habitat or building facilities, it would be much easier to understand and relate the treatment with the future use of the land. Without references to long-term use, only the removal options can be supported.

   Specifically: Tables, pages 64 and 65, East and West Parcel Remediation Areas. These two tables provide the calculations for the area and cubic yard estimations used elsewhere in the report. The tables relate to the “Modeled Remediation Areas” insert on Figures 8-1 and 8-2. It is not possible with the information provided to understand how the borders of remediation areas were derived. For example, there is a prominent diagonal band of positive PCB and Mercury samples running from the “Scrap Yard Area” to the “Cell Bldg Perimeter Areas” that are apparently not treated by any method in the FS. These clearly exceed safety guidelines, but are outside of proposed treatment areas. Further, the “Raw Brine Tank Area” shown on the Figures is presumed to be the same as “Brine Tank” shown in the tables. This spot is designated for removal based, apparently, on Mercury and PCB exceeding standards; however, there is excessive Lead indicated nearby (to the west) with no sampling in the intervening areas. How are the borders actually determined in this area when positive “hits” have not been bracketed with sampling to determine the range of contamination? These are just two examples. There are other instances where areas with samples exceeding toxicity limits are left untreated.

Conclusions 

   Only a small percentage of areas with pollutants are treated by this plan. This Feasibility Study seems to be another in the long series of “trial balloons” at this site. Just as the caustic brine pool treatment was held up for years while the site managers played semantic games with data showing CBP movement, this “study” is likely more wishful thinking by the authors, rather than a bona fide attempt to move the cleanup closer to reality.

   The study should be rewritten and resubmitted for review. Spreadsheets used for the calculations should be provided, and a complete rationale for the exclusion of positive toxins from cleanup should be given to the community.

  Written by R. Kevin Pegg, Ph.D. Copies of the newsletter are available from the GEC, at the Glynn County library, or at www.Enviro-Issues.com  on the Internet.

TECHNICAL ASSISTANCE REPORT

"This project has been funded wholly or partly by the U.S. Environmental Protection Agency under Assistance Agreement Number 1-994850-01-0  to The Glynn Environmental Coalition, Inc. The contents of this document do not necessarily reflect the views and policies of the U.S. Environmental Protection agency, nor does mention of trade names or commercial products constitute endorsement or recommendation for use."

Volume 12,  Number 1,  August, 2007