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.
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.
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
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
form of doing nothing, essentially doing nothing with testing every couple
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;
stabilization-- using cement or drying agents to immobilize toxins in-place;
- Capping and/or soil covers over the bad
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
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.
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.
by R. Kevin Pegg, Ph.D. Copies of the newsletter are available from the GEC,
at the Glynn County library, or at
on the Internet.
Volume 12, Number 1,