Second Five-Year Review Report Brewer Gold Mine …Review period: 12/16/2015 – 07/13/2016 Date of...

Second Five-Year Review Report for

Brewer Gold Mine Superfund Site Operable Unit 01

SCD987577913

Jefferson Chesterfield County, South Carolina

September 2016

United States Environmental Protection Agency Region 4

Atlanta, Georgia

• ' i

/ _ Franklin E. Hill M Director, Superfund Division

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Second Five-Year Review Report

for

Brewer Gold Mine Superfund Site

Operable Unit 01

2965 Hilton Road, Jefferson

Chesterfield County, South Carolina

List of Acronyms .......................................................................................................................... iv

Executive Summary ...................................................................................................................... v

Five-Year Review Summary Form ............................................................................................ vii

1.0 Introduction ............................................................................................................................. 1

2.0 Site Chronology ....................................................................................................................... 2

3.0 Background ............................................................................................................................. 2

3.1 PHYSICAL CHARACTERISTICS .......................................................................................... 2

3.2 LAND AND RESOURCE USE .............................................................................................. 6 3.3 HISTORY OF CONTAMINATION ......................................................................................... 6 3.4 INITIAL RESPONSE ........................................................................................................... 7

3.5 BASIS FOR TAKING ACTION ............................................................................................. 7

4.0 Remedial Actions .................................................................................................................... 8

4.1 REMEDY SELECTION ........................................................................................................ 8 4.2 REMEDY IMPLEMENTATION ........................................................................................... 10

4.3 OPERATION AND MAINTENANCE (O&M) ....................................................................... 10

5.0 Progress Since the Last Five-Year Review ......................................................................... 11

6.0 Five-Year Review Process .................................................................................................... 11

6.1 ADMINISTRATIVE COMPONENTS .................................................................................... 11

6.2 COMMUNITY INVOLVEMENT .......................................................................................... 12 6.3 DOCUMENT REVIEW ...................................................................................................... 12 6.4 DATA REVIEW ............................................................................................................... 15

6.5 SITE INSPECTION ............................................................................................................ 16 6.6 INTERVIEWS ................................................................................................................... 16

7.0 Technical Assessment ........................................................................................................... 18

7.1 QUESTION A: IS THE REMEDY FUNCTIONING AS INTENDED BY THE DECISION DOCUMENTS?

..................................................................................................................................... 18

7.2 QUESTION B: ARE THE EXPOSURE ASSUMPTIONS, TOXICITY DATA, CLEANUP LEVELS AND

REMEDIAL ACTION OBJECTIVES (RAOS) USED AT THE TIME OF REMEDY SELECTION STILL

VALID? ......................................................................................................................... 18

7.3 QUESTION C: HAS ANY OTHER INFORMATION COME TO LIGHT THAT COULD CALL INTO QUESTION

THE PROTECTIVENESS OF THE REMEDY? ....................................................................... 19 7.4 TECHNICAL ASSESSMENT SUMMARY ............................................................................. 19

8.0 Issues, Recommendations and Follow-up Actions ............................................................. 19

9.0 Protectiveness Statement ...................................................................................................... 20

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10.0 Next Review ......................................................................................................................... 20

Appendix A: List of Documents Reviewed ............................................................................. A-1

Appendix B: Press Notice ......................................................................................................... B-1

Appendix C: Interview Forms ................................................................................................. C-1

Appendix D: Site Inspection Checklist ................................................................................... D-1

Appendix E: Photographs from Site Inspection Visit ........................................................... E-1

Appendix F: Effluent Sampling Data Results, 2011 to December 2015................................ F-1

Tables

Table 1: Chronology of Site Events ................................................................................................ 2

Table 2: Interim Remedial Surface Water Discharge Goals ........................................................... 9

Table 3: Progress on Recommendations from the 2011 FYR ...................................................... 11 Table 4: Institutional Control (IC) Summary Table ..................................................................... 14 Table 5: Deed Documents from Chesterfield County Public Records Office .............................. 14 Table 6: Issues and Recommendations Identified in the Five-Year Review ................................ 19

Table 7: Protectiveness Statement ................................................................................................ 20

Figures Figure 1: Site Location Map ........................................................................................................... 4 Figure 2: Detailed Site Map ............................................................................................................ 5

Figure 3: Institutional Control Base Map ..................................................................................... 15

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List of Acronyms

AOC Administrative Order on Consent

ARAR Applicable or Relevant and Appropriate Requirement

CERCLA Comprehensive Environmental Response, Compensation and Liability Act

CFR Code of Federal Regulations

CIC Community Involvement Coordinator

EPA United States Environmental Protection Agency

FS Feasibility Study

FYR Five-Year Review

gpm Gallons per Minute

IC Institutional Control

lbs/MG Pounds per Million Gallons

MCL Maximum Contaminant Level

mg/L Milligrams per Liter

NCP National Oil and Hazardous Substances Pollution Contingency Plan

NPDES National Pollutant Discharge Elimination System

NPL National Priorities List

O&M Operation and Maintenance

OU Operable Unit

PRP Potentially Responsible Party

RAO Remedial Action Objective

RI Remedial Investigation

ROD Record of Decision

RPM Remedial Project Manager

SCDHEC South Carolina Department of Health and Environmental Control

TBC To-Be-Considered

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Executive Summary

The Brewer Gold Mine Superfund site (the Site) is located in a rural area about one mile west of

Jefferson in Chesterfield County, South Carolina. The Site is approximately 1,000 acres in size; about

230 acres were disturbed by gold and topaz mining and processing. These operations occurred

intermittently from 1828 to 1995. From 1987 through 1995, the Brewer Gold Company mined over 12

million tons of ore and waste rock from several open pits. The company crushed ore and placed it in

large heaps on one of several plastic-lined surfaces called pads. A dilute solution of sodium cyanide was

then applied to the surface of the heaps and it dissolved the gold and silver as it trickled through the

heaps. The company collected the solution at the bottom of the heaps and recovered the gold in an on-

site plant. In 1990, following large rainstorms, a dam broke and allowed over 10 million gallons of

stored cyanide solution to flow into Little Fork Creek. The solution resulted in a fish kill in the Creek

and a 50-mile stretch of the Lynches River. The U.S. Environmental Protection Agency and the South

Carolina Department of Health and Environmental Control (SCDHEC) responded to the emergency.

Following the release, SCDHEC conducted an assessment of impacts to aquatic macroinvertebrates in

Little Fork Creek, Fork Creek and the Lynches River, the results of which were compared to an

assessment conducted in 1988. After that time, macroinvertebrate studies were conducted annually

through 2001 to monitor recovery of the insect population in the affected streams. The overflow plastic-

lined pond and dam were redesigned and reconstructed and the mine resumed normal operation in 1991.

In 1995, the most recent owner/operator notified SCDHEC of its intent to close its operations and

SCDHEC issued an Administrative Order on Consent (AOC) that required state-approved closure and

reclamation. Following reclamation, the owner abandoned the Site and a wastewater treatment plant in

1999. The State requested EPA assistance in continuing to operate the wastewater treatment plant, which

treated groundwater and surface water contaminated with acidity and heavy metals. The EPA took

control of the plant under Comprehensive Environmental Response, Compensation, and Liability Act

(CERCLA) removal authority. The Site was placed on the National Priorities List (NPL) in April 2005,

which shifted responsibility for the plant from EPA’s Emergency Response Program to the Remedial

Program. On September 29, 2005, the EPA issued the OU01 Interim Record of Decision (ROD) so the

EPA remedial program could take over operation and maintenance of the Site from the EPA removal

program. The EPA then initiated a sitewide remedial investigation/feasibility study (RI/FS) to identify

and evaluate a permanent remedy. Subsequent to the completion of the sitewide RI/FS, the EPA

designated the surface water capture and treatment system and water treatment sludge handling system

Operable Unit (OU) 01. OU01 includes the capture and treatment of mine pit water, the combined upper

and lower seeps, the Pad 6 sump, and the sediment pond water. Additionally, OU01 includes dewatering

and handling sludge produced during water treatment. Other site features and media will be addressed

under one or more separate OUs in the future. The triggering action for this five-year review (FYR) was

the signing of the previous FYR on September 13, 2011. The first FYR was triggered by the signing of

the September 2005 Interim ROD.

On September 29, 2005, EPA issued the Interim ROD, which included an interim remedy to minimize

the amount of contamination reaching Little Fork Creek through controlling contaminants released to

surface water. The following interim action objectives were established for the Site:

Meet and sustain South Carolina water quality standards for protection of human health in Little

Fork Creek.

Meet and sustain National Water Quality Criteria for human consumption of water and

organisms in Little Fork Creek.

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The review of documents, risk assumptions and the site inspection indicate that the remedy is

functioning as intended by the Interim ROD. The pump-and-treat system, which maintains water within

the backfilled pits at an elevation that prohibits some seeps from discharging and permits others to be

captured and treated, prevents most impacts to Little Fork Creek. Weekly effluent sampling was reduced

to monthly sampling and annual macroinvertebrate sampling was discontinued in 2001 to reduce costs.

Monthly and daily maximum discharge data from June 2011 to December 2015 (available in Appendix

F) showed only two instances of slight exceedances compared to the discharge limits. In August 2011,

the monthly average for the mass-based level of aluminum at 0.7457 pounds per million gallons (lb/MG)

exceeded the discharge limit of 0.726 lb/MG. In June 2013, the monthly average for the concentration-

based level of copper at 0.18 milligrams per liter (mg/L) exceeded the discharge limit of 0.15 mg/L.

There were no other exceedances. The 2010 RI indicated that the pump-and-treat system was

constructed of salvaged and jury-rigged parts in the mid-1990s and was intended to operate for only a

year or two; it has now operated for over 10 years. Operation and Maintenance (O&M) costs have also

risen due to higher electricity costs.

The interim OU01 remedy currently protects human health and the environment because exposure

pathways that could result in unacceptable risks are being controlled. Contaminated seep water and

groundwater are captured, treated and discharged to Little Fork Creek. For the remedy to be protective

over the long term, institutional controls must be implemented.

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Five-Year Review Summary Form

SITE IDENTIFICATION

Site Name: Brewer Gold Mine

EPA ID: SCD987577913

Region: 4 State: SC City/County: Jefferson/Chesterfield

SITE STATUS

NPL Status: Final

Multiple OUs?

Yes

Has the site achieved construction completion?

No

REVIEW STATUS

Lead agency: EPA

Author name: Loften Carr (EPA), Johnny Zimmerman-Ward (Skeo) and Brice Robertson (Skeo)

Author affiliation: EPA and Skeo

Review period: 12/16/2015 – 07/13/2016

Date of site inspection: 01/21/2015

Type of review: Statutory

Review number: 2

Triggering action date: 09/13/2011

Due date (five years after triggering action date): 09/13/2016

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Five-Year Review Summary Form (continued)

Issues/Recommendations

OU(s) without Issues/Recommendations Identified in the Five-Year Review:

None.

Issues and Recommendations Identified in the Five-Year Review:

OU(s): 01 Issue Category: Institutional Controls

Issue: Institutional controls are not yet in place to ensure long-term protectiveness. The property is abandoned and they cannot be put in place in the traditional manner.

Recommendation: Implement the necessary institutional controls to prevent exposure to contaminated media. The EPA and SCDHEC are investigating putting the property into a receivership and the receivership may be able to address the institutional control issue. Institutional controls will be included in a future sitewide OU decision document.

Affect Current Protectiveness

Affect Future Protectiveness

Implementing Party

Oversight Party

Milestone Date

No Yes EPA EPA 09/30/2017

Protectiveness Statement

Operable Unit: OU01

Protectiveness Determination: Short-term Protective

Protectiveness Statement: The interim OU01 remedy currently protects human health and the environment because exposure pathways that could result in unacceptable risks are being controlled. Contaminated seep water and groundwater are captured, treated and discharged to Little Fork Creek. For the remedy to be protective over the long term, institutional controls must be implemented.

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Five-Year Review Summary Form (continued)

Environmental Indicators

- Current human exposures at the Site are under control. - There are insufficient data to determine migration control status.

Has the EPA Designated the Site as Sitewide Ready for Anticipated Use?

Yes No

Are Necessary Institutional Controls in Place?

All Some None

Has the Site Been Put into Reuse?

Yes No

1

Second Five-Year Review Report

for

Brewer Gold Mine Superfund Site

Operable Unit 01

1.0 Introduction

The purpose of a five-year review (FYR) is to evaluate the implementation and performance of a remedy

in order to determine if the remedy will continue to be protective of human health and the environment.

FYR reports document FYR methods, findings and conclusions. In addition, FYR reports identify issues

found during the review, if any, and document recommendations to address them.

The U.S. Environmental Protection Agency prepares FYRs pursuant to the Comprehensive

Environmental Response, Compensation and Liability Act (CERCLA) Section 121 and the National Oil

and Hazardous Substances Pollution Contingency Plan (NCP). CERCLA Section 121 states:

If the President selects a remedial action that results in any hazardous substances, pollutants, or

contaminants remaining at the site, the President shall review such remedial action no less often

than each 5 years after the initiation of such remedial action to assure that human health and the

environment are being protected by the remedial action being implemented. In addition, if upon

such review it is the judgment of the President that action is appropriate at such site in

accordance with section [104] or [106], the President shall take or require such action. The

President shall report to the Congress a list of facilities for which such review is required, the

results of all such reviews, and any actions taken as a result of such reviews.

The EPA interpreted this requirement further in the NCP, 40 Code of Federal Regulations (CFR) Section

300.430(f)(4)(ii), which states:

If a remedial action is selected that results in hazardous substances, pollutants, or contaminants

remaining at the site above levels that allow for unlimited use and unrestricted exposure, the lead

agency shall review such action no less often than every five years after initiation of the selected

remedial action.

Skeo Solutions, an EPA Region 4 contractor, conducted the FYR and prepared this report regarding the

interim remedy implemented at the Brewer Gold Mine Superfund site (the Site) in Jefferson,

Chesterfield County, South Carolina. The EPA’s contractor conducted this FYR from December 2015 to

July 2016. The EPA is the lead agency for developing and implementing the remedy for the Superfund-

financed cleanup at the Site. The South Carolina Department of Health and Environmental Control

(SCDHEC), as the support agency representing the State of South Carolina, has reviewed all supporting

documentation and provided input to the EPA during the FYR process.

This is the second FYR for Operable Unit 1 (OU01). The triggering action for this statutory review is

the previous FYR. The FYR is required due to the fact that hazardous substances, pollutants or

contaminants remain at the Site above levels that allow for unlimited use and unrestricted exposure. This

FYR Report addresses the interim remedy at OU01.

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2.0 Site Chronology

Table 1 lists the dates of important events for the Site.

Table 1: Chronology of Site Events

Event Date

Brewer Gold Company caused release of hazardous substances via on-site dam failure

and triggered EPA emergency response action

October 28, 1990

The EPA issued Unilateral Administrative Order November 11, 1990

Removal action completed by Brewer Gold November 30, 1991

SCDHEC conducted preliminary investigation April 19, 1994

Administrative/voluntary cost recovery conducted by the EPA September 9, 1994

SCDHEC issued Administrative Order on Consent (AOC) 1995

Second emergency response initiated by the EPA December 2, 1999

The EPA initiated removal action December 12, 1999

Expanded site inspection initiated by SCDHEC February 8, 2000

SCHEC completed expanded site inspection September 25. 2001

First remedial investigation/feasibility study (RI/FS) for OU01 initiated by the EPA July 30, 2002

The EPA initiated second RI/FS for OU01 September 29, 2003

Site proposed for listing on Superfund program’s National Priorities List (NPL) September 23, 2004

Site finalized on NPL April 27, 2005

The EPA initiated remedial design for OU01 September 20, 2005

Focused RI/FS for OU01 completed

The EPA issued Interim Record of Decision (ROD) for OU01

September 29, 2005

Remedial design for OU01 completed by the EPA June 16, 2006

The EPA initiated OU01 interim remedial action September 14, 2006

Removal action completed by the EPA November 30, 2006

The EPA issued baseline human health risk assessment 2010

First FYR completed by the EPA September 13, 2011

The EPA completed second sitewide RI Report December 2011

Revised final FS for OU01 completed by the EPA January 2013

The EPA released proposed plan for OU01 for public comment February 18, 2013

Public meeting at Jefferson Elementary School hosted by the EPA to allow residents

and interested parties to comment on documents and proposed plan

February 28, 2013

The EPA received written comments from SCDHEC concerning the proposed plan 2013

The EPA initiated the OU01 remedial design August 8, 2014

Final ROD for OU01 issued by the EPA September 30, 2014

3.0 Background

3.1 Physical Characteristics

The approximately 1,000-acre Site is located off Hilton Road in a rural area of Chesterfield County,

about four miles west of Jefferson, one half-mile mile north of the intersection of SR 265 and CR 110, in

north-central South Carolina (Figure 1). About 230 acres were disturbed by gold and topaz mining and

processing. The Site includes two property parcels: Chesterfield County parcel #026 000 000 013 and

Chesterfield County parcel #026 000 000 014.

The Site is bounded to the east by Little Fork Creek, a tributary to Lynches River, to the north and west

by private land, and to the south by State Highway 265. The Site is located in a rural residential area that

is mostly wooded and undeveloped. Little Fork Creek enters Lynches River approximately two miles

3

downstream of the Site. About 25 miles downstream of the Site, an extended reach of Lynches River has

been designated as a State Scenic River.

The Site is located in the Piedmont Province of South Carolina, an area characterized by rolling hills and

incised rivers and streams. The boundary between the Piedmont and Coastal Plain provinces lies about

one mile east of the Site. The former mine is situated atop a broadly rounded hill with an elevation of

about 600 feet above mean sea level. The hilltop stands 150 to 200 feet above the surrounding terrain.

Relief in the area surrounding the mine is steep, with slopes of 20 to 30 percent occurring on the

northwest and east sides of the hill. Little Fork Creek is deeply incised along the eastern margin of the

hill and two deeply incised, unnamed streams drain the northeast and western slopes of the mine. On-site

buildings include an office building, truck shop and sheds.

Most runoff from the Site drains east and south through unnamed gullies to Little Fork Creek, which

flows into Fork Creek, a tributary of the Lynches River. The northwestern portion of the Site drains

directly to Lynches River through unnamed ephemeral gullies; this part of the Site has not been mined.

From the point where it receives inflow from the sediment pond tributary, Little Fork Creek flows an

additional 0.65 mile to its confluence with Fork Creek. Fork Creek then flows 0.94 mile to its

confluence with the Lynches River. Informal names have been given to three gullies along the eastern

side of the Site: the pad 6 drainage, which flows from below the earthen dam that impounds the pad 6

overflow pond to Little Fork Creek on the northeast side of the Site; Roger’s River, which flows south to

Little Fork Creek along the east-central part of the Site; and the sediment pond tributary, which flows

southward to Little Fork Creek from below the earthen dam that impounds the sediment pond (Figure 2).

Groundwater on the Site occurs in surficial soil and saprolite (intact but decomposed bedrock) and in

deeper crystalline bedrock. Groundwater flow and storage at the Site have been modified by mining

activities, including excavation of historic workings, construction of a drainage tunnel and recent open-

pit mining and reclamation.

The shape of the water table implies that the groundwater gradient is oriented radially away from

Brewer hill and toward Little Fork Creek and other bounding gullies and streams. Seeps that occur on

hill slopes surrounding the Site indicate that the water table locally intersects the ground surface; in

many locations, these seeps are spatially associated with a resistant ledge of rock.

A seep appeared at the east end of the B-6 pit during reclamation and discharged poor quality water

from the pit area. This seep, termed the “B-6 seep,” discharged water at a three-year average rate of

118.8 gallons per minute (gpm). Two other seeps also drained water of poor quality from the pit area.

The “upper seep” (also known as the “tunnel seep”) flowed at approximately 10 gpm and originated in

the area of the Brewer drainage tunnel outlet; this seep began to flow after the drainage tunnel portal was

plugged during backfilling of the Brewer pit. The “lower seep” flowed at 1 to 2 gpm and was apparently

active prior to reclamation activities. Consequently, groundwater discharge from the Brewer and B-6 pit

areas totaled approximately 130 gpm, similar to the pumping rate of the Brewer pit during mining.

4

Figure 1: Site Location Map

Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informational

purposes only regarding the EPA’s response actions at the Site.

5

Figure 2: Detailed Site Map



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3.2 Land and Resource Use

Major gold and topaz mining operations took place on site for over a century, from about the 1850s until

1995. The Site is not currently in use, with cleanup systems and equipment covering much of the land

area. Other parts of the Site consist of undeveloped forestland. The Site’s Interim Record of Decision

(ROD) and final ROD anticipated that the property would be used for recreation in the future.

Chesterfield County is primarily rural, with a mix of forest and agricultural lands. Most people living

within a 4-mile radius of the Site obtain their drinking water from the Jefferson Town Water System.

The closest drinking water intake is upstream on the Lynches River, about 1.2 miles from the Site, and

therefore is unaffected by discharges from the Site. Residents do not use Little Fork Creek and

downstream waters for drinking water. However, there are an estimated 339 homes within 4 miles of the

Site that obtain drinking water from private wells. The EPA sampled private wells in 2003 and detected

no metals in the water. Groundwater within the mine area is not used for drinking water and on-site

personnel drink bottled water. Close to the Site, Oceana Gold plans to reopen the Haile Gold Mine in the

near future.

About 25 miles downstream of the Site, the Lynches River is an important fishery. It is a state-

designated Scenic River. There are also some wetlands (approximately 1 mile of frontage) downstream

along the Lynches River.

3.3 History of Contamination

Development of the Brewer Gold Mine began in 1828. Various gold mining operations took place on

site until about 1940. These operations included gold panning, mercury amalgamation, gravity methods,

chlorination and cyanidation.

Following World War II, miners mined the Site for topaz, which had been earlier identified as a mineral

in the deposit. They excavated the topaz from one and possibly two small pit(s) north of the Brewer pit

in the 1940s and 1950s (referred to as the Hilford and Topaz pits). Following this topaz mining, the Site

was largely undisturbed until Gold Resources, Inc. acquired an option on the site property and the firm

entered into a joint venture with Nicor Mineral Ventures in 1983 to explore and develop the gold

deposit. The companies completed a feasibility study in 1986.

Later in 1986, Costain Holdings acquired Nicor Mineral Ventures and established Westmont Mining,

which broke ground for new facilities in March 1987. They established Brewer Gold Company (Brewer)

in June 1987 to operate the new facilities. The company poured its first gold in August 1987. Brewer

operated an open pit-heap leach operation on the property. They expanded the pit to include the pre-

existing Brewer, Hartman, Hilford and Topaz pits, as well as many of the shafts, adits and underground

workings. Brewer mined an estimated 12 million tons of ore and waste rock that yielded 192,000 ounces

of gold.

Following heavy rains associated with a tropical storm, a dam impounding an overflow pond at heap

leach pad 6 failed on October 28, 1990. This event released an estimated 10 to 12 million gallons of

pregnant (gold-laden) cyanide leach solution that flowed down a small unnamed tributary to Little Fork

Creek, eventually reaching the Lynches River. The EPA reported fish kills for at least 49 miles

downstream.

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3.4 Initial Response

In 1991, Brewer redesigned and reconstructed the overflow pond and dam and resumed mining

operations later that year. SCDHEC completed a preliminary assessment of the Site in 1993. The

assessment evaluated the potential threat to human health and the environment posed by the Site to

support a decision for further investigations under CERCLA. The Assessment Report included a review

of impacts from the 1990 dam failure. It concluded that aquatic life was recovering from the event. The

report recommended continued monitoring and low prioritization of the Site for further CERCLA action.

Mining and gold production continued until 1995 when Brewer notified SCDHEC that it intended to

close the mine. Following this announcement, SCDHEC issued an Administrative Order on Consent

(AOC) requiring Brewer to submit a design for closing and reclaiming the facility. SCDHEC approved

Brewer’s design; in August 1995, Brewer commenced reclamation activities. These actions included

dewatering the Brewer and B-6 pits, rinsing leach heaps, dismantling unnecessary facilities, backfilling

the Brewer and B-6 pits, installing a geosynthetic clay liner across the pit area, and continuing to operate

an on-site water treatment plant.

In November 1999, Costain Holdings, the British parent company of Brewer, abandoned the Site in

violation of the AOC. As a result, SCDHEC requested emergency response assistance from EPA Region

4 in December 1999. The EPA initiated an emergency response on December 2, 1999, and authorized

actions to continue operating the seepage collection and treatment system. In January 2000, the EPA

performed an impact study of site waters. This study concluded that failure to treat wastewater would

result in releases of acidic, metals-laden water that would severely degrade water quality in Little Fork

Creek. In 2001, SCDHEC prepared an Expanded Site Investigation Report. It recommended listing the

Site on the Superfund program’s National Priorities List (NPL).

The EPA placed the Site on the NPL on April 27, 2005, shifting responsibility for the Site from EPA’s

Emergency Response Program to the Remedial Program. The EPA took several steps to conclude the

emergency removal action. These steps included preparation of a focused remedial

investigation/feasibility study (RI/FS). The study recommended continued treatment of contaminated

water as an interim action to reduce risks from the Site pending implementation of the final remedy.

3.5 Basis for Taking Action

From 2002 until 2004, SCDHEC collected quarterly water samples from Little Fork Creek near the State

Highway 265 bridge. Sampling identified potential contaminants of concern, including aluminum,

barium, cadmium, cobalt, copper, iron, manganese, mercury, silver, zinc and cyanide. These

contaminants showed mean concentrations above water quality standards.

Because the focus of the interim action was to prevent the release of acidic water contaminated with

high concentrations of metals to Little Fork Creek until identification and selection of a permanent

remedy, the only human exposure route examined in the focused RI (2005) was via surface water. The

RI found that people wading, swimming or fishing in Little Fork Creek, Fork Creek or the Lynches

River would be the most likely human receptors. Human receptors could be exposed to contaminants in

the surface water through incidental ingestion of the water, dermal contact with the water or

consumption of fish.

8

Aquatic life, particularly macroinvertebrates and fish, are the biggest concern in Little Fork Creek. The

uptake of metals through the water column is the major route of exposure for aquatic invertebrates, algae

and fish. Routes of benthic organism exposure include uptake from porewater in the sediments of Little

Fork Creek or water at the sediment/water interface, and direct contact with or ingestion of contaminated

sediments. Because mercury and selenium were contaminants of potential concern in the three

waterways, these chemicals could follow an indirect pathway of contamination through the food chain.

The RI identified small mammals, deer and birds as the most likely terrestrial receptors on site.

Waterfowl are not particularly attracted to the Site, although there might be occasional visits of

migratory waterfowl to the Northwest Trend pit, the pad 6 pond or the sediment pond. Ingestion and

contact with surface water and sediments are the pathways of concern.

4.0 Remedial Actions

In accordance with CERCLA and the NCP, the overriding goals for any remedial action are protection

of human health and the environment and compliance with applicable or relevant and appropriate

requirements (ARARs). A number of remedial alternatives were considered for the

Site, and final selection was made based on an evaluation of each alternative against nine evaluation

criteria that are specified in Section 300.430(e)(9)(iii) of the NCP. The nine criteria are:

1. Overall Protection of Human Health and the Environment

2. Compliance with ARARs

3. Long-Term Effectiveness and Permanence

4. Reduction of Toxicity, Mobility or Volume through Treatment

5. Short-Term Effectiveness

6. Implementability

7. Cost

8. State Acceptance

9. Community Acceptance

4.1 Remedy Selection

On September 29, 2005, the EPA issued the OU01 Interim ROD so the EPA remedial program could

take over operation and maintenance of the Site from the EPA removal program. The OU01 Interim

ROD included an interim remedy to minimize the amount of contamination reaching Little Fork Creek

by controlling contaminants released to surface water, which was mostly contaminated groundwater

coming from the metal and acid-contaminated seeps. The document established the following interim

action objectives for the Site:

Meet and sustain South Carolina water quality standards for protection of human health in Little

Fork Creek.

Meet and sustain National Water Quality Criteria for human consumption of water and

organisms in Little Fork Creek.

The EPA chose these objectives to be consistent with future remedial actions. The interim remedy

designed the chosen actions to prevent discharges of contaminated groundwater to surface waters at the

Site. The major components of the interim remedy included:

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Collecting contaminated seepage from several springs downgradient of the backfilled pits and

injecting it into the B-6 pit.

Pumping contaminated water out of the B-6 pit and from the sediment pond and storing it in a

lined storage pond.

Treating all contaminated water with lime in an on-site wastewater treatment plant and

discharging the treated water into the Northwest Trend pit.

Decanting water from the Northwest Trend pit and storing it in one of two lined storage ponds or

discharging it directly to Little Fork Creek.

Periodically removing sludge from the Northwest Trend pit, drying the sludge and storing it in

on-site piles.

Evaluating the potential for contaminants to be released from sludge while it is stored. If it is

determined that contaminants could be released, a sludge management plan would be developed

and implemented, pending development of a final remedy.

Monitoring water quality of the effluent discharge and surface water in Little Fork Creek.

Maintaining the site property and equipment as necessary to accomplish all of the foregoing

activities.

The preliminary interim action goal for Little Fork Creek was for treated water discharged to the creek

to meet discharge limits equivalent to the formerly applicable National Pollutant Discharge Elimination

System (NPDES) permit (permit SC0040657, originally effective February 1, 1998, and modified on

October 12, 1998), as shown in Table 2. SCDHEC based these limits in part on mass-based criteria in

pounds-per-million-gallons (lbs/MG) in Little Fork Creek and in part on Ambient Water Quality Criteria

promulgated by the EPA, as well as state water quality standards.

Table 2: Interim Remedial Surface Water Discharge Goals

Contaminant Mass-Based Limit (lbs/MG) Concentration-Based Limit (mg/L)

Monthly Average Daily Maximum Monthly Average Daily Maximum

Total suspended solids - - 20 30

Oil and grease - - 10 15

Cyanide 0.0835 0.167 - -

Aluminum 0.726 6.26 - -

Arsenic 0.0417 0.0835 - -

Cadmium 0.0835 0.167 0.05 0.10

Copper 0.0835 0.167 0.15 0.30

Lead 0.417 0.835 0.3 0.6

Mercury 0.00167 0.00334 0.001 0.002

Selenium 0.0417 0.167 - -

Silver 0.250 0.500 - -

Zinc 0.492 0.542 0.75 1.5

Ammonia (as nitrogen,

April - October) 30.5 61.0 - -

10

Contaminant Mass-Based Limit (lbs/MG) Concentration-Based Limit (mg/L)

Monthly Average Daily Maximum Monthly Average Daily Maximum

Ammonia (as nitrogen,

November - March) 32.1 167 - -

Sulfate monitor only

Notes:

lbs/MG = pounds-per-million-gallons

mg/L = milligrams per liter

- = no goal defined

On September 30, 2014, the EPA issued the final ROD for OU01. The 2014 ROD addressed surface

water remediation through capture and treatment of mine-impacted groundwater. The 2014 ROD is not

the focus of this FYR, as it was issued in the fourth year of the FYR period and remedy design is

currently underway. The remedy chosen in the final ROD is largely based on the findings of the Site’s

2010 RI and 2013 FS.

4.2 Remedy Implementation

The Site’s interim remedial design started in September 2005 and finished in June 2006. The interim

remedial action started in September 2006. The wastewater treatment system is presently operated as

described in the 2005 Interim ROD under contract to EPA contractor Black & Veatch. In a typical

month, the system treats two 3-million-gallon batches of mine-impacted groundwater, at a treatment rate

of 1,400 to 1,600 gpm. The treatment train process is briefly described below, followed by slight

variances of the remedial components of the 2005 Interim ROD.

Water treatment starts when contaminated water is pumped from the wastewater sources to the pad 6

pond, which serves as a holding pond. The untreated water is then pumped from the pad 6 pond to the

treatment plant, where it is mixed with lime slurry to raise the pH. This mixture is retained for short time

in the retention tanks. The neutralized wastewater is then discharged to the Northwest Trend pit.

Clarified wastewater from the Northwest Trend pit is decanted and pumped either to the emergency

pond or freshwater pond (lined treated water holding ponds), or directly discharged to the Little Fork

Creek. The plant operator determines where the wastewater will be pumped based upon the current

wastewater levels in the ponds, current creek flow conditions, and the overall water balance of the

treatment system. Flow of wastewater discharged to the creek is regulated by a treated wastewater

discharge valve station.

The 2005 Interim ROD required weekly monitoring of 15 effluent contaminants. However, since 2001,

the EPA continues to monitor only effluent discharge, pH, aluminum, copper, mercury and selenium

monthly in order to reduce monitoring expenses. The EPA also discontinued annual macroinvertebrate

studies as called for in the Interim ROD in 2001, due to results of previous sampling, which indicated a

near full recovery of macroinvertebrate communities, and to reduce operation and maintenance (O&M)

costs. The Interim ROD did not take into account cost-cutting measures and changes in operational

procedures at the Site under the Emergency Response Program during its six-year operation at the Site.

4.3 Operation and Maintenance (O&M)

The Site’s June 2006 O&M Manual described the water treatment system as well as site O&M

requirements. These requirements included daily measurements of total effluent and stream flow,

11

weekly measurements of total contaminants discharged to Little Fork Creek and bimonthly

measurements of stream pH. The 2006 O&M Manual also detailed responsibilities associated with site

management, environmental quality, equipment operation, the electrical system and other miscellaneous

responsibilities for site upkeep.

Many improvements have been made to the Site since the Interim ROD. The EPA reroofed and resided

the office in 2011 and installed backup generators at the B-6 seep collection area, the upper seep

collection area and below the pad 6 pond. O&M contractors repair old equipment as needed.

Estimated annual O&M costs in the Interim ROD were approximately $695,684. From 2011 to 2015, the

EPA and O&M staff estimated O&M costs to be $1 million annually. The significant increase can be

attributed to increases in electricity prices. The original mine operation used substantially more

electricity than the current remediation operations and therefore received a discount rate from the local

electrical cooperative. The Site no longer receives the previous discount rate therefore costs have

increased. Water treatment system operations require large amounts of electricity.

5.0 Progress Since the Last Five-Year Review

The protectiveness statement from the 2011 FYR for the Site stated:

The remedy at the Site is expected to be protective of human health and the environment upon

completion. In the interim, exposure pathways that could result in unacceptable risks are being

controlled. Contaminated seep water and groundwater are captured, treated and discharged to Little

Fork Creek.

The 2011 FYR included one issue and recommendation. This report summarizes each recommendation

and its current status below.

Table 3: Progress on Recommendations from the 2011 FYR

Recommendations Party

Responsible

Milestone

Date

Action Taken and

Outcome

Date of

Action

As part of the selection of the final remedy,

identify the institutional controls necessary to

prevent exposure to contaminated media and to

protect the integrity of the remedy in the long

term; measures to restrict access to the Site have

been taken to ensure short-term protectiveness

until the final remedy is selected and

institutional controls can be implemented by a

future owner.

EPA 11/30/2011 Ongoing N/A

6.0 Five-Year Review Process

6.1 Administrative Components

EPA Region 4 initiated the FYR in December 2015 and scheduled its completion for July 2016. EPA

remedial project manager (RPM) Loften Carr led the EPA site review team, which also included EPA

site attorney Rhelyn Finch, EPA community involvement coordinator (CIC) Angela Miller and

contractor support provided to the EPA by Skeo Solutions. In December 2015, the EPA held a scoping

12

call with the review team to discuss the Site and items of interest as they related to the protectiveness of

the remedy currently in place. The review schedule established consisted of the following activities:

Community notification.

Document review.

Data collection and review.

Site inspection.

Local interviews.

FYR Report development and review.

6.2 Community Involvement

In March 2016, the EPA published a public notice in the Pageland Progressive newspaper announcing

the commencement of the FYR process for the Site, providing contact information for Loften Carr, RPM

and Angela Miller, CIC and inviting community participation. The press notice is available in Appendix

B. No one contacted the EPA as a result of the advertisement.

The EPA will make the final FYR Report available to the public. Upon completion of the FYR, the EPA

will place copies of the document in the designated site repository: Fannie D. Lowry Library, 500 North

Main Street, Jefferson, South Carolina 29718.

6.3 Document Review

This FYR included a review of relevant site-related documents, including the 2005 Interim ROD,

remedial action reports and recent monitoring data. Appendix A provides a complete list of the

documents reviewed.

ARARs Review

CERCLA Section 121(d)(1) requires that Superfund remedial actions attain “a degree of cleanup of

hazardous substances, pollutants, and contaminants released into the environment and of control of

further release at a minimum which assures protection of human health and the environment.” The

remedial action must achieve a level of cleanup that at least attains those requirements that are legally

applicable or relevant and appropriate.

Applicable requirements are those cleanup standards, standards of control and other substantive

requirements, criteria or limitations promulgated under federal environmental or state

environmental or facility siting laws that specifically address a hazardous substance, remedial

action, location or other circumstance found at a CERCLA site.

Relevant and appropriate requirements are those standards that, while not “applicable,” address

problems or situations sufficiently similar to those encountered at the CERCLA site that their use

is well suited to the particular site. Only those state standards more stringent than federal

requirements may be applicable or relevant and appropriate.

To-Be-Considered (TBC) criteria are non-promulgated advisories and guidance that are not

legally binding, but should be considered in determining the necessary remedial action. For

example, To-Be-Considered criteria may be particularly useful in determining health-based

13

levels where no ARARs exist or in developing the appropriate method for conducting a remedial

action.

Chemical-specific ARARs are health- or risk-based numerical values or methodologies which, when

applied to site-specific conditions, result in the establishment of numerical values. These values

establish an acceptable amount or concentration of a chemical that may remain in, or be discharged to,

the ambient environment. Examples of chemical-specific ARARs include maximum contaminant levels

(MCLs) under the federal Safe Drinking Water Act and ambient water quality criteria enumerated under

the federal Clean Water Act.

Action-specific ARARs are technology- or activity-based requirements or limits on actions taken with

respect to a particular hazardous substance. These requirements are triggered by a particular remedial

activity, such as discharge of contaminated groundwater or in-situ remediation.

Location-specific ARARs are restrictions on hazardous substances or the conduct of the response

activities solely based on their location in a special geographic area. Examples include restrictions on

activities in wetlands, sensitive habitats and historic places.

Remedial actions are required to comply with the chemical-specific ARARs identified in the ROD. In

performing the FYR for compliance with ARARs, only those ARARs that address the protectiveness of

the remedy are reviewed.

The 2005 Interim ROD identified the former 1998 NPDES permit discharge limits in Table 2 as ARARs

for the Site because they are based on state water quality standards and national effluent limitations. The

NPDES limits were developed using mass-based criteria in lbs/MG and also concentration-based criteria

in milligrams per liter (mg/L). The ARARs identified in the Site’s 2014 ROD will apply to the final

remedy.

Institutional Control Review

The 2005 Interim ROD did not call for institutional controls to be put in place at the Site. However,

institutional controls will be necessary for the long-term protectiveness of the Site’s remedy (Table 4;

Figure 3). They will not be put in place until a viable landowner purchases the site property. The EPA

and SCDHEC are investigating putting the property into a receivership and the receivership may be able

to address the institutional control issue. The 2014 final ROD for OU01 does call for implementation of

institutional controls in a future separate sitewide OU decision document in order to restrict land and

groundwater use, and prevent degradation of on-site engineering controls (e.g., capped areas). These

include, but are not limited to, instruments such as deed notices, negative easements, restrictive

covenants or governmental controls such as local ordinances or zoning restrictions.

On February 8, 2016, Skeo Solutions conducted research at the Chesterfield County Public Records

Office and found the deed information pertaining to the Site listed in Table 5.

14

Table 4: Institutional Control (IC) Summary Table

Media ICs Needed

ICs Called for in

the Decision

Documents

Impacted Parcels IC

Objective

Instrument in

Place

Soil,

groundwater,

sediments,

surface water,

fish

To be

determined in a

future remedy.

To be determined

in a future

remedy.

Chesterfield County

parcels: #026 000 000

013 and #026 000 000

014

To be

determined in a

future remedy.

To be

determined in a

future remedy.

Table 5: Deed Documents from Chesterfield County Public Records Office

Date Type of

Document Description Book # Page #

12/18/1996 Quit Claim Transfer tract from Westmont Mining Inc. to Gold

Resources Inc. 356 828

12/18/1996 Quit Claim Transfer tract from Westmont Mining Inc. to Gold

Resources Inc. 355 1393

01/01/1995 Deed Surrender of exploration right with option to lease agreement

between Brewer Gold Company and Carl M. Tucker 359 1174

07/01/1987 Deed Transferred property to Westmont Mining Inc. 303 1250

15

Figure 3: Institutional Control Base Map



16

6.4 Data Review

During the past five years, the O&M contractor collected weekly water samples of effluent discharged

into Little Fork Creek and analyzed the data monthly for mass-based levels (lb/MG) of aluminum,

copper, selenium and mercury. The contractor recorded monthly averages as well as daily maximums

within each month. The contractor also analyzed the composite samples and compiled monthly averages

for concentration-based levels (mg/L) of effluent discharged to Little Fork Creek.

For this data review, monthly averages and daily maximums of mass-based levels of the four

contaminants were compared to the effluent discharge limits set forth in the 2005 Interim ROD

(Appendix F). Monthly averages of concentration-based limits for copper and mercury were also

compared to the effluent discharge limits set forth in the Interim ROD. Aluminum and selenium were

not compared for concentration-based limits because no concentration-based limits were established in

the Interim ROD for the two contaminants. Monthly and daily maximum discharge data from June 2011

to December 2015 showed only two instances of exceedances compared to the discharge limits. In

August 2011, the monthly average for the mass-based level of aluminum at 0.7457 lb/MG exceeded the

discharge limit of 0.726 lb/MG. In June 2013, the monthly average for the concentration-based level of

copper at 0.18 mg/L exceeded the discharge limit of 0.15 mg/L. However, these two instances do not

compromise likelihood of future compliance; they barely exceeded the discharge limits and were two

isolated instances over the review period. There were no exceedances of selenium and mercury

compared to mass-based and concentration-based limits during this FYR period. Daily maximum

concentration-based data were not available for review and the Interim ROD did not specify

concentration-based limits for aluminum or selenium.

6.5 Site Inspection

On January 21, 2016, EPA RPM Loften Carr, Jim McLain of Gemini Services (O&M contractor to

Black & Veatch), and Johnny Zimmerman-Ward and Brice Robertson of Skeo Solutions met at the Site.

Following a brief meeting in the office building, Jim McClain and Loften Carr led a tour of the Site. The

completed site inspection checklist is available in Appendix D. Photographs taken to record site

conditions are available in Appendix E.

The group toured the Site to observe the condition of interim action remedial components and followed

the complete water treatment process. Participants found components of the Site’s remedy to be mostly

well-maintained and functioning as intended. Near the end of the inspection, participants observed that

the piping used to discharge treated water to Little Fork Creek was severely corroded but still

functioning. Mr. Carr and Mr. McLain noted that the piping was scheduled for replacement in the near

future.

Due to the Fannie D. Lowry Memorial Branch Library (site information repository) being closed on the

day of the site inspection, Skeo Solutions called the library on an earlier date to confirm the public

availability of relevant site documents. The librarian stated that multiple binders of administrative

records and other site documents were present.

6.6 Interviews

The FYR process included interviews with parties affected by the Site and regulatory agencies involved

in site activities or aware of the Site. The purpose was to document the perceived status of the Site and

17

any perceived problems or successes with the phases of the remedy implemented to date. The interviews

took place during the site inspection on January 21, 2016, or at a later date through email. The

interviews are summarized below. Appendix C provides the complete interviews.

Charles Williams: Charles Williams represents the State of South Carolina and is the current state

project manager for the Site. Mr. Williams noted that the extraction well and water treatment plant are

working well and he believes the system is working as intended. He is not aware of any complaints from

nearby residents and his office has not conducted any site-related activities or communications in the

past five years. He is not aware of any changes to state laws that might affect the protectiveness of the

Site’s remedy and is also not aware of any changes in projected land uses at the Site. He noted that for

now, the institutional controls are appropriate. If the Site ever has a viable landowner, groundwater use

restrictions will need to be put in place.

Jim McLain: Jim McLain represents O&M contractor Black & Veatch and is the current O&M site

manager. Mr. McLain believes that the ongoing project at the Site has been essential for the health of the

area and believes that the remedy has continued to be successful in its mission to protect the

environment at a reasonable cost. He indicated that monitoring data show that the conditions that

produce the contamination of the groundwater will continue. While improved efficiency in the

containment and treatment of impacted water may be possible, discontinuing of the remedy will not be

possible. He mentioned that there is a continuous on-site O&M presence, with three full-time employees

responsible for treating and discharging contaminated groundwater and maintaining the integrity and

security of the Site. The O&M personnel are also responsible for recordkeeping, community relations

and emergency responses.

Mr. McLain mentioned that there have been very few changes to O&M procedures in the last five years

and that there have not been any major O&M difficulties in that same period. He believes that while

there is always room for improvement and optimization at the Site, most advances in efficiencies were

made many years ago. He noted that personnel need to continue to maintain a safe and productive

workplace, while stretching materials and money as far as possible until the new improvements have

been completed.

Resident 1: Resident 1 is the owner of a local business near the Site. He commented that he is aware of

the former environmental issues and cleanup of the Site and believes the cleanup and maintenance of the

Site are very good. He mentioned that he has seen no negative effects on the community and that the

EPA has kept nearby residents relatively informed of site activities and does not see a better way to keep

residents more informed. Lastly, he commented that he believes Jim McLain has done a good job with

the Site and runs a very tight ship.

Resident 2: Resident 2 runs a local business near the Site. She commented that she is aware of the

former environmental issues and cleanup of the Site and believes the cleanup and maintenance of the

Site is going fine and that they are doing what they need to do. She said that the only effect on the

community was a shortage of jobs for the community when the mine first closed. She mentioned that the

EPA has not kept her informed of activities and that she only knows of site activities because of talking

with Jim McLain. She prefers to receive mail for information on site activities. She noted that the

cleanup process is a long-term project and that nobody thought of the effects during mining operations.

Resident 3: Resident 3 is the owner of a local business near the Site. He commented that he is aware of

the former environmental issues and cleanup of the Site and believes that the people associated with it

18

are doing a good job and have kept it up. He mentioned that his business has done some work on site

equipment. He said that the cleanup and maintenance of the Site has created some income for the

community and that the effect of the Site on the community has mostly been positive. He commented

that the EPA has not informed him of any site activities and that the best way to do so would be by

emailing him and by informing the town council.

7.0 Technical Assessment

7.1 Question A: Is the remedy functioning as intended by the decision documents?

The review of documents, risk assumptions and the site inspection indicate that the interim remedy is

fully functioning as intended by the 2005 Interim ROD. The pump-and-treat system, which maintains

water within the backfilled pits at an elevation that prohibits some seeps from discharging and permits

others to be captured and treated, prevents negative impacts to Little Fork Creek. There were only two

instances of monthly average exceedances of discharge limits to Little Fork Creek, occurring for

aluminum in August 2011 and for copper in June 2013. These exceedances were barely above discharge

limits and therefore do not compromise the protectiveness of the Site’s remedy. There were no

exceedances of selenium and mercury compared to mass-based and concentration-based limits during

this FYR period. The EPA discontinued annual macroinvertebrate studies as called for in the Interim

ROD in 2001. This was done as a result of previous sampling, which indicated a near full recovery of

macroinvertebrate communities, and to reduce O&M costs. All components of the Site’s remedy and

treatment train are well-maintained and contain backup systems in case of emergencies.

Current O&M procedures are performed as intended by the 2005 Interim ROD and ensure the

protectiveness of the Site’s remedy. O&M costs have risen since the 2011 FYR due to increases in

electricity costs. The EPA explored the option of installing solar panels to reduce these costs in a report

on renewable energy development opportunities. The State of South Carolina determined that they did

not want to be responsible for the additional operation and maintenance costs associated with a solar

power system. The EPA is also considering possible solutions for metal-laden, on-site sludge piles. This

includes potential recycling of heavy and light metals.

There are no institutional controls in place at the Site. They will not be put in place until a viable

landowner purchases the site property. The EPA and SCDHEC are investigating putting the property

into a receivership and the receivership may be able to address the institutional control issue. The 2014

final ROD for OU01 states that institutional controls will be implemented under a future sitewide OU

decision document in order to restrict land and groundwater use, and prevent degradation of on-site

engineering controls (e.g., capped areas). These include, but are not limited to, instruments such as deed

notices, negative easements, restrictive covenants or governmental controls such as local ordinances or

zoning restrictions. Institutional controls are necessary to ensure long-term protectiveness of the remedy.

However, there are access controls in place that continue to ensure short-term protectiveness of the

Site’s remedy. These access controls include a daily presence of on-site personnel and appropriate

signage designating no trespassing on the Site.

7.2 Question B: Are the exposure assumptions, toxicity data, cleanup levels and remedial

action objectives (RAOs) used at the time of remedy selection still valid?

The exposure assumptions, toxicity data, cleanup levels and RAOs used at the time of remedy selection

are still valid. The exposure assumptions are still valid because land uses on the Site have not changed,

19

there are no new ecological routes of exposure, there are no newly identified contaminants and there

have been no changes in physical site conditions. The toxicity data are still valid because there have

been no changes in toxicity factors or other contaminant characteristics for contaminants of concern at

the Site. The cleanup levels are still valid because they were based on the former NPDES permit at the

Site and those values have not changed. The 2014 final ROD for OU01 identified the same cleanup

levels as the final cleanup goals in the Interim ROD. The RAOs are still valid because effluent is still

being discharged to Little Fork Creek, so water quality for effluent discharge must meet state and

national water quality standards in order to be protective of human health and protective of human

consumption of water and organisms from the creek.

7.3 Question C: Has any other information come to light that could call into question the

protectiveness of the remedy?

No other information has come to light that could call into question the protectiveness of the remedy.

7.4 Technical Assessment Summary

The remedy is fully functioning as intended by the 2005 Interim ROD. The pump-and-treat system

prevents negative impacts to Little Fork Creek. There were only two instances of monthly average

exceedances of discharge limits to Little Fork Creek and these exceedances do not compromise the

protectiveness of the remedy. All components of the Site’s remedy and treatment train are well-

maintained and contain backup systems in case of emergencies. Current O&M procedures are performed

as intended by the 2005 Interim ROD and ensure the protectiveness of the Site’s remedy. O&M costs

have risen since the last FYR due to increases in electricity costs. The EPA continues to explore various

ways to offset these costs. Currently, there are no institutional controls in place at the Site. Institutional

controls cannot be put in place until a potential buyer purchases the site property. Institutional controls

will be included in a final sitewide remedy.

8.0 Issues, Recommendations and Follow-up Actions

Table 6: Issues and Recommendations Identified in the Five-Year Review

Issues and Recommendations Identified in the Five-Year Review:

OU(s): 01 Issue Category: Institutional Controls

Issue: Institutional controls are not yet in place to ensure long-term protectiveness. The property is abandoned and they cannot be put in place in the traditional manner.

Recommendation: Implement the necessary institutional controls to prevent exposure to contaminated media. The EPA and SCDHEC are investigating putting the property into a receivership and the receivership may be able to address the institutional control issue. Institutional controls will be included in a future sitewide OU decision document.

Affect Current Protectiveness

Affect Future Protectiveness

Implementing Party

Oversight Party

Milestone Date

No Yes EPA EPA 09/30/2017

20

9.0 Protectiveness Statement

Table 7: Protectiveness Statement

Protectiveness Statement

10.0 Next Review

The next FYR will be due within five years of the signature/approval date of this FYR.

Operable Unit: OU01

Protectiveness Determination: Short-term Protective

Protectiveness Statement: The interim OU01 remedy currently protects human health and the environment because exposure pathways that could result in unacceptable risks are being controlled. Contaminated seep water and groundwater are captured, treated and discharged to Little Fork Creek. For the remedy to be protective over the long term, institutional controls must be implemented.

A-1

Appendix A: List of Documents Reviewed

EPA Superfund Final Record of Decision, Brewer Gold Mine Superfund Site, EPA ID: SCD987577913,

OU 1. Jefferson, South Carolina. Prepared by U.S. EPA. September 30, 2014.

EPA Superfund Interim Record of Decision, Brewer Gold Mine Superfund Site, EPA ID:

SCD987577913, OU 1. Jefferson, South Carolina. Prepared by U.S. EPA. September 29, 2005.

First Five-Year Review Report, Brewer Gold Mine Superfund Site. Prepared by Skeo Solutions for U.S.

EPA Region 4. September 2011.

Focused Feasibility Study of Continuing Water Treatment, Brewer Gold Mine Superfund Site. Prepared

by Black & Veatch for U.S. EPA Region 4. August 1, 2005.

Monthly Effluent Discharge Reports, Brewer Gold Mine Superfund Site. Prepared by Black & Veatch

for U.S. EPA Region 4. June 2011-December 2015.

Operations and Maintenance Manual, Brewer Gold Mine Superfund Site, Interim Action Remedial

Design. Prepared by Black & Veatch for U.S. EPA Region 4. June 16, 2006.

Remedial Investigation Report, Brewer Gold Mine Superfund Site. Prepared by Black & Veatch for U.S.

EPA Region 4. December 2010.

Renewable Energy Development Opportunities, Brewer Gold Mine Superfund Site. Prepared by U.S.

EPA Abandoned Minelands Team for U.S. EPA Region 4.

Revised Final Feasibility Study, Brewer Gold Mine Superfund Site, Surface Water Protection, OU 1.

Prepared by Black & Veatch for U.S. EPA Region 4. January 2013.

B-1

Appendix B: Press Notice

The U.S. Environmental Protection Agency, Region 4

Announces the Second Five-Year Review for

The Brewer Gold Mine Superfund Site

Jefferson, Chesterfield County, South Carolina

Purpose/Objective: The EPA is conducting the second Five-Year Review of the remedy for the Brewer Gold Mine

Superfund site (the Site) in Jefferson, South Carolina. The purpose of the Five-Year Review is to make sure the selected

cleanup actions effectively protect human health and the environment.

Site Background: The Site covers about 1,000 acres; gold and topaz mining and processing disturbed about 230 acres. The

mine operated intermittently from 1828 to 1995. From 1987 to 1995, the Brewer Gold Company mined over 12 million tons

of ore and waste rock from several open pits. In 1990, following large rainstorms, a dam broke, allowing over 10 million

gallons of stored cyanide solution to flow into Little Fork Creek. The solution resulted in a fish kill in the creek and a 50-mile

stretch of the Lynches River. The EPA and the South Carolina Department of Health and Environmental Control (SCDHEC)

responded to the emergency. Following the release, SCDHEC assessed impacts to aquatic macroinvertebrates in Little Fork

Creek, Fork Creek and the Lynches River. When the company abandoned the Site in 1999, the EPA took over water

treatment operations to contain acid rock drainage that could harm Little Fork Creek and the Lynches River. An expanded

site investigation report, prepared by SCDHEC in 2001, recommended listing the Site on the Superfund program’s National

Priorities List (NPL). The EPA placed the Site on the NPL in 2005.

Cleanup Actions: EPA selected an operable unit (OU) 1 interim remedy to treat contamination at the Site in the Site’s 2005

Interim Record of Decision (ROD). Its major components included pumping and treatment of contaminated groundwater and

discharge of treated water to Little Fork Creek; monitoring to make sure effluent meets water quality standards; and sludge

management by dredging the Northwest Trend Pit and drying materials for storage. Remedial actions began in September

2006 and are ongoing. The EPA signed the OU1 ROD in September 2014. The remedial design is underway and is scheduled

for completion in 2017.

Five-Year Review Schedule: The National Contingency Plan requires review of remedial actions that result in any

hazardous substances, pollutants or contaminants remaining at the Site above levels that allow for unlimited use and

unrestricted exposure every five years to ensure the protection of human health and the environment. The second of the Five-

Year Reviews for the Site will be completed by September 2016.

EPA Invites Community Participation in the Five-Year Review Process: The EPA is conducting this Five-Year Review

to evaluate the effectiveness of the Site’s remedy and to ensure that the remedy remains protective of human health and the

environment. As part of the Five-Year Review process, the EPA staff members are available to answer any questions about

the Site. Community members who have questions about the Site or the Five-Year Review process, or who would like to

participate in a community interview, are asked to contact:

Loften Carr, EPA Remedial Project Manager Angela Miller, EPA Community Involvement Coordinator

Phone: (404) 562-8804 Phone: (404) 562-8561

Email: [email protected] Email: [email protected]

Mailing Address: U.S. EPA Region 4, 61 Forsyth Street, S.W., 11th Floor, Atlanta, GA 30303-8960

Additional information is available at the Site’s local document repository, located at Fannie D. Lowry Memorial Branch

Library, 500 North Main Street, Jefferson, SC 29718, and online at

http://cumulis.epa.gov/supercpad/cursites/csitinfo.cfm?id=0405550&msspp=med.

mailto:[email protected]

mailto:[email protected]

http://cumulis.epa.gov/supercpad/cursites/csitinfo.cfm?id=0405550&msspp=med

C-1

Appendix C: Interview Forms

Brewer Gold Mine Superfund Site Five-Year Review Interview Form Site Name: Brewer Gold Mine EPA ID No.: SCD987577913

Interviewer Name: Johnny Zimmerman-

Ward

Affiliation: Skeo Solutions

Subject Name: Charles Williams Affiliation: SCDHEC

Subject Contact Information: Project Manager

Time: 9:52 a.m. Date: 1/26/16

Interview

Location:

Interview Format (circle one): In Person Phone Mail Other: e-mail

Interview Category: State Agency

1. What is your overall impression of the project, including cleanup, maintenance and reuse

activities (as appropriate)?

The extraction well and the water treatment plant are working well.

2. What is your assessment of the current performance of the remedy in place at the Site?

The system is working as intended.

3. Are you aware of any complaints or inquiries regarding site-related environmental issues or

remedial activities from residents in the past five years?

No.

4. Has your office conducted any site-related activities or communications in the past five years? If

so, please describe the purpose and results of these activities.

No.

5. Are you aware of any changes to state laws that might affect the protectiveness of the Site’s

remedy?

No.

6. Are you comfortable with the status of the institutional controls at the Site? If not, what are the

associated outstanding issues?

For now the institutional controls are appropriate. If the site ever has a viable land owner,

groundwater use restrictions will need to be put in place.

7. Are you aware of any changes in projected land use(s) at the Site?

No.

8. Do you have any comments, suggestions or recommendations regarding the management or

operation of the Site’s remedy?

No.

C-2


Interviewer Name: Johnny

Zimmerman-Ward


Subject Name: Jim McLain Affiliation: Black & Veatch

Subject Contact Information:

Time: NA Date: 2/2/2016

Interview Location: NA

Interview Format (circle one): In Person Phone Mail Other: email

Interview Category: O&M Contractor

1. What is your overall impression of the project, including cleanup, maintenance and reuse

activities (as appropriate)?

I feel the ongoing project at the Site has been essential for the health of the area.

2. What is your assessment of the current performance of the remedy in place at the Site?

In spite of some serious water problems, the Brewer plan has continued to be very successful in

its mission to protect the local environment at a reasonable cost.

3. What are the findings from the monitoring data? What are the key trends in contaminant levels

that are being documented over time at the Site?

Our monitoring data indicated that the conditions that produce the contamination of the

groundwater will continue. Containment and treatment of the impacted water can be made to be

more efficient, but cannot be eliminated.

4. Is there a continuous on-site O&M presence? If so, please describe staff responsibilities and

activities. Alternatively, please describe staff responsibilities and the frequency of site

inspections and activities if there is not a continuous on-site O&M presence.

We have three employees who are responsible for treating and discharging all of the

contaminated groundwater and maintaining the integrity and security of the 1,000-acre site. We

are also charged with all recordkeeping, community relations and emergency responses to

potentially dangerous situations.

5. Have there been any significant changes in site O&M requirements, maintenance schedules or

sampling routines since start-up or in the last five years? If so, do they affect the protectiveness

or effectiveness of the remedy? Please describe changes and impacts.

Very few changes have occurred in the O&M procedures over the last five years.

6. Have there been unexpected O&M difficulties or costs at the Site since start-up or in the last five

years? If so, please provide details.

There has not been any major O&M difficulties within the last five years. Normal wear-and-tear

problems with the equipment have been low, considering the age of much of this equipment.

7. Have there been opportunities to optimize O&M activities or sampling efforts? Please describe

changes and any resulting or desired cost savings or improved efficiencies.

While there is always room for improvement, most advances in efficiencies have been made

many years ago.

C-3

8. Do you have any comments, suggestions or recommendations regarding O&M activities and

schedules at the Site?

We need to continue maintaining a safe and productive workplace while stretching materials and

money as far as we can until the new improvements have been completed.

C-4



Ward


Subject Name: Nearby Resident Affiliation: Nearby Resident

Subject Contact Information: NA

Time: 11:15 a.m. Date: 01/21/2016

Interview Location: Jefferson, SC

Interview Format (circle one): In Person Phone Mail Other:

Interview Category: Residents

1. Are you aware of the former environmental issues at the Site and the cleanup activities that have

taken place to date?

Yes.

2. What is your overall impression of the project, including cleanup, maintenance and reuse activities

(as appropriate)?

They have done a good job and kept it up. I have done some work on their equipment.

3. What have been the effects of the Site on the surrounding community, if any?

It has created some income for the community. It has mostly been positive and nobody has really

said anything.

4. Have there been any problems with unusual or unexpected activities at the Site, such as emergency

response, vandalism or trespassing?

No.

5. Has EPA kept involved parties and surrounding neighbors informed of activities at the Site? How

can EPA best provide site-related information in the future?

I have not heard the EPA say anything. I would like them to inform the town council as well as

inform residents through email.

6. Do you own a private well in addition to or instead of accessing city/municipal water supplies? If so,

for what purpose(s) is your private well used?

No.

7. Do you have any comments, suggestions or recommendations regarding any aspects of the project?

No.

C-5



Ward




Time: 11:25 a.m. Date: 01/21/2016






Yes.


(as appropriate)?

It is going fine and they’re doing what they need to.


When the mine closed down, there was a lack of jobs in the community.



No.



No, I have kept informed through Jim McLain. I prefer mailing.



No.


It’s been a long-term thing. Nobody thought of the effects when the mine was open.

C-6



Ward




Time: 11:30 a.m. Date: 01/21/2016






Yes.


(as appropriate)?

My overall impression is very good and I do not see anything bad.


There has not been a negative effect.



No.



Yes, they’ve been pretty informative. It is fine the way they provide information now.



No.


No, I think it’s great. Jim McLain runs a tight ship.

D-1

Appendix D: Site Inspection Checklist

FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST

I. SITE INFORMATION

Site Name: Brewer Gold Mine Date of Inspection: 01/21/2016

Location and Region: Jefferson, SC / Region 4 EPA ID: SCD987577913

Agency, Office or Company Leading the Five-Year

Review: EPA

Weather/Temperature: 35 degrees Fº/ clear and

sunny

Remedy Includes: (Check all that apply)

Landfill cover/containment Monitored natural attenuation

Access controls Groundwater containment

Institutional controls Vertical barrier walls

Groundwater pump and treatment

Surface water collection and treatment

Other:

Attachments: Inspection team roster attached Site map attached

II. INTERVIEWS (check all that apply)

1. O&M Site Manager Jim McClain

Name

O&M Site Manager

Title

2/2/2016

Date

Interviewed at site at office by phone Phone:

Problems, suggestions Report attached:

2. O&M Staff

Name

Title

Date

Interviewed at site at office by phone Phone:

Problems/suggestions Report attached:

3. Local Regulatory Authorities and Response Agencies (i.e., state and tribal offices, emergency

response office, police department, office of public health or environmental health, zoning office, recorder of

deeds, or other city and county offices). Fill in all that apply.

Agency SCDHEC

Contact Charles Williams

Name

Project

Manager

Title

1/26/2016

Date

Phone No.


Agency

Contact Name

Title

Date

Phone No.


Agency

Contact

Name

Title

Date

Phone No.


Agency

Contact

Name

Title

Date

Phone No.


D-2

Agency

Contact

Name

Title

Date

Phone No.


4. Other Interviews (optional) Report attached:

III. ON-SITE DOCUMENTS AND RECORDS VERIFIED (check all that apply)

1. O&M Documents

O&M manual Readily available Up to date N/A

As-built drawings Readily available Up to date N/A

Maintenance logs Readily available Up to date N/A

Remarks:

2. Site-Specific Health and Safety Plan Readily available Up to date N/A

Contingency plan/emergency response plan Readily available Up to date N/A

Remarks:

3. O&M and OSHA Training Records Readily available Up to date N/A

Remarks:

4. Permits and Service Agreements

Air discharge permit Readily available Up to date N/A

Effluent discharge Readily available Up to date N/A

Waste disposal, POTW Readily available Up to date N/A

Other permits: Readily available Up to date N/A

Remarks: No NPDES Permit but does meet substantive requirements

5. Gas Generation Records Readily available Up to date N/A

Remarks:

6. Settlement Monument Records Readily available Up to date N/A

Remarks:

7. Groundwater Monitoring Records Readily available Up to date N/A

Remarks: No longer monitoring groundwater but past records are available

8. Leachate Extraction Records Readily available Up to date N/A

Remarks:

9. Discharge Compliance Records

Air Readily available Up to date N/A

Water (effluent) Readily available Up to date N/A

Remarks:

10. Daily Access/Security Logs Readily available Up to date N/A

D-3

Remarks:

IV. O&M COSTS

1. O&M Organization

State in-house Contractor for state

PRP in-house Contractor for PRP

Federal facility in-house Contractor for Federal facility

EPA Contractor

2. O&M Cost Records

Readily available Up to date

Funding mechanism/agreement in place Unavailable

Original O&M cost estimate: $695,684 Breakdown attached

Total annual cost by year for review period if available: Approximately $1,000,000 annually

3. Unanticipated or Unusually High O&M Costs during Review Period

Describe costs and reasons: Price increase in electricity increased water treatment costs.

V. ACCESS AND INSTITUTIONAL CONTROLS Applicable N/A

A. Fencing

1. Fencing Damaged Location shown on site map Gates secured N/A

Remarks:

B. Other Access Restrictions

1. Signs and Other Security Measures Location shown on site map N/A

Remarks:

C. Institutional Controls (ICs)

1. Implementation and Enforcement

Site conditions imply ICs not properly implemented Yes No N/A

Site conditions imply ICs not being fully enforced Yes No N/A

Type of monitoring (e.g., self-reporting, drive by):

Frequency:

Responsible party/agency:

Contact

Name Title Date Phone no.

Reporting is up to date Yes No N/A

Reports are verified by the lead agency Yes No N/A

Specific requirements in deed or decision documents have been met Yes No N/A

Violations have been reported Yes No N/A

Other problems or suggestions: Report attached

2. Adequacy ICs are adequate ICs are inadequate N/A

D-4

Remarks: Institutional controls are not yet in place. Currently, there is no viable landowner to file institutional

controls.

D. General

1. Vandalism/Trespassing Location shown on site map No vandalism evident

Remarks:

2. Land Use Changes On Site N/A

Remarks:

3. Land Use Changes Off Site N/A

Remarks: Oceana Mining Company is reopening the Haile Gold Mine nearby.

VI. GENERAL SITE CONDITIONS

A. Roads Applicable N/A

1. Roads Damaged Location shown on site map Roads adequate N/A

Remarks:

B. Other Site Conditions

Remarks: Office building, treatment system, piping, various ponds all used but still functioning normally.

VII. LANDFILL COVERS Applicable N/A

A. Landfill Surface

1. Settlement (low spots) Location shown on site map Settlement not evident

Arial extent: Depth:

Remarks:

2. Cracks Location shown on site map Cracking not evident

Lengths: Widths: Depths:

Remarks:

3. Erosion Location shown on site map Erosion not evident


Remarks:

4. Holes Location shown on site map Holes not evident


Remarks:

5. Vegetative Cover Grass Cover properly established

No signs of stress Trees/shrubs (indicate size and locations on a diagram)

Remarks: In addition to grass, brambles and bushes also cover the landfill.

6. Alternative Cover (e.g., armored rock, concrete) N/A

Remarks:

7. Bulges Location shown on site map Bulges not evident

Arial extent: Height:

D-5

Remarks:

8. Wet Areas/Water

Damage

Wet areas/water damage not evident

Wet areas Location shown on site map Arial extent:

Ponding Location shown on site map Arial extent:

Seeps Location shown on site map Arial extent:

Soft subgrade Location shown on site map Arial extent:

Remarks:

9. Slope Instability Slides Location shown on site map

No evidence of slope instability

Arial extent:

Remarks:

B. Benches Applicable N/A

(Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in order

to slow down the velocity of surface runoff and intercept and convey the runoff to a lined channel.)

C. Letdown Channels Applicable N/A

(Channel lined with erosion control mats, riprap, grout bags or gabions that descend down the steep side slope of

the cover and will allow the runoff water collected by the benches to move off of the landfill cover without

creating erosion gullies.)

D. Cover Penetrations Applicable N/A

1. Gas Vents Active Passive

Properly secured/locked Functioning Routinely sampled Good condition

Evidence of leakage at penetration Needs maintenance N/A

Remarks:

2. Gas Monitoring Probes



Remarks:

3. Monitoring Wells (within surface area of landfill)



Remarks: Monitoring wells are only used to monitor water table depth.

4. Extraction Wells Leachate



Remarks:

5. Settlement Monuments Located Routinely surveyed N/A

Remarks:

D-6

E. Gas Collection and Treatment Applicable N/A

F. Cover Drainage Layer Applicable N/A

G. Detention/Sedimentation Ponds Applicable N/A

1. Siltation Area extent: Depth: N/A

Siltation not evident

Remarks:

2. Erosion Area extent: Depth:

Erosion not evident

Remarks:

3. Outlet Works Functioning N/A

Remarks:

4. Dam Functioning N/A

Remarks:

H. Retaining Walls Applicable N/A

I. Perimeter Ditches/Off-Site Discharge Applicable N/A

1. Siltation Location shown on site map Siltation not evident

Area extent: Depth:

Remarks:

2. Vegetative Growth Location shown on site map N/A

Vegetation does not impede flow

Area extent: Type:

Remarks:

3. Erosion Location shown on site map Erosion not evident

Area extent: Depth:

Remarks:

4. Discharge Structure Functioning N/A

Remarks:

VIII. VERTICAL BARRIER WALLS Applicable N/A

IX. GROUNDWATER/SURFACE WATER REMEDIES Applicable N/A

A. Groundwater Extraction Wells, Pumps and Pipelines Applicable N/A

1. Pumps, Wellhead Plumbing and Electrical

Good condition All required wells properly operating Needs maintenance N/A

Remarks: Redundancies and backup generators are in place to ensure the treatment system keeps running in an

emergency.

2. Extraction System Pipelines, Valves, Valve Boxes and Other Appurtenances

Good condition Needs maintenance

D-7

Remarks:

3. Spare Parts and Equipment

Readily available Good condition Requires upgrade Needs to be provided

Remarks:

B. Surface Water Collection Structures, Pumps and Pipelines Applicable N/A

1. Collection Structures, Pumps and Electrical


Remarks:

2. Surface Water Collection System Pipelines, Valves, Valve Boxes and Other Appurtenances


Remarks:

3. Spare Parts and Equipment

Readily available Good condition Requires upgrade Needs to be provided

Remarks:

C. Treatment System Applicable N/A

1. Treatment Train (check components that apply)

Metals removal Oil/water separation Bioremediation

Air stripping Carbon adsorbers

Filters:

Additive (e.g., chelation agent, flocculent): lime

Others:


Sampling ports properly marked and functional

Sampling/maintenance log displayed and up to date

Equipment properly identified

Quantity of groundwater treated annually: 90 million gallons

Quantity of surface water treated annually:

Remarks:

2. Electrical Enclosures and Panels (properly rated and functional)

N/A Good condition Needs maintenance

Remarks:

3. Tanks, Vaults, Storage Vessels

N/A Good condition Proper secondary containment Needs maintenance

Remarks:

4. Discharge Structure and Appurtenances

N/A Good condition Needs maintenance

D-8

Remarks: Discharge structure is functional but needs to be updated.

5. Treatment Building(s)

N/A Good condition (esp. roof and doorways) Needs repair

Chemicals and equipment properly stored

Remarks:

6. Monitoring Wells (pump and treatment remedy)


All required wells

located

Needs maintenance N/A

Remarks:

D. Monitoring Data

1. Monitoring Data

Is routinely submitted on time Is of acceptable quality

2. Monitoring Data Suggests:

Groundwater plume is effectively contained Contaminant concentrations are declining

E. Monitored Natural Attenuation

1. Monitoring Wells (natural attenuation remedy)


All required wells located Needs maintenance N/A

Remarks:

X. OTHER REMEDIES

If there are remedies applied at the site and not covered above, attach an inspection sheet describing the physical

nature and condition of any facility associated with the remedy. An example would be soil vapor extraction.

XI. OVERALL OBSERVATIONS

A. Implementation of the Remedy

Describe issues and observations relating to whether the remedy is effective and functioning as designed. Begin

with a brief statement of what the remedy is designed to accomplish (e.g., to contain contaminant plume,

minimize infiltration and gas emissions).

The remedy is designed to contain the containment plume and treat contaminated surface and groundwater. The

remedy is effective and functioning as designed.

B. Adequacy of O&M

Describe issues and observations related to the implementation and scope of O&M procedures. In particular,

discuss their relationship to the current and long-term protectiveness of the remedy.

O&M activities are performed in a timely and quality manner and currently protect the remedy and its long-term

protectiveness.

C. Early Indicators of Potential Remedy Problems

Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high frequency of

unscheduled repairs that suggest that the protectiveness of the remedy may be compromised in the future.

There is nothing that currently compromises the remedy. O&M costs have increased due to increased electricity

prices in the area.

D. Opportunities for Optimization

Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.

A possible avenue to optimize the remedy was to implement solar and wind turbines to generate electricity. A

plan was developed but never implemented due State of South Carolina concerns..

D-9

Site Inspection Roster:

Loften Carr, EPA

Jim McClain, Gemini Services

Johnny Zimmerman-Ward, Skeo Solutions

Brice Robertson, Skeo Solutions

E-1

Appendix E: Photographs from Site Inspection Visit

Front entrance sign

Extraction well EW-1

E-2

The B-6 seep

Monitoring well MW-24

E-3

Capped landfill

Pad 6 overflow pond

E-4

Wastewater treatment plant

Northwest Trend pit

E-5

Heap Leach Pad 5 (sludge drying cells and sludge storage pile)

Emergency pond

E-6

Sediment pond

Effluent discharge piping to Little Fork Creek

F-1

Appendix F: Effluent Sampling Data Results, 2011 to December 2015

NA = Not Available

Red = exceedance of Interim ROD goal

Monthly Average Daily Max Monthly Average Daily Max Monthly Average Daily Max Monthly Average Daily Max Monthly Average Daily Max Monthly Average Daily Max Monthly Average Daily Max Monthly Average Daily Max

Interim ROD Limits 0.726 6.26 NA NA 0.0835 0.167 0.15 0.3 0.0417 0.167 NA NA 0.00167 0.00334 0.001 0.002

Jun-11 0.3155 0.3875 0.7 NA 0.0045 0.0055 0.01 NA 0.0176 0.0216 0.039 NA 0.00009 0.0001 0.0002 NA

Jul-11 0.1125 0.3072 1.3 NA 0.0006 0.0031 0.013 NA 0.004 0.0109 0.046 NA 0.000017 0.00 0.0002 NA

Aug-11 0.7457 1.5563 1.4 NA 0.0107 0.0222 0.02 NA 0.0181 0.0378 0.034 NA 0.000107 0.0002 0.0002 NA

Sep-11 0.1302 0.2713 0.35 NA 0.0074 0.0155 0.02 NA 0.0108 0.0225 0.029 NA 0.000074 0.0002 0.0002 NA

Oct-11 0.0447 0.0643 0.24 NA 0.0037 0.0054 0.02 NA 0.0076 0.011 0.041 NA 0.000037 0.0001 0.0002 NA

Nov-11 0.0453 0.0878 0.31 NA 0.0039 0.0076 0.027 NA 0.0056 0.0108 0.038 NA 0.000029 0.0001 0.0002 NA

Dec-11 0.0037 0.0092 0.14 NA 0.0004 0.001 0.015 NA 0.0012 0.003 0.046 NA 0.000005 0.00 0.0002 NA

Jan-12 0.0119 0.0251 0.28 NA 0.0008 0.0016 0.018 NA 0.0021 0.0045 0.05 NA 0.000008 0.00 0.0002 NA

Feb-12 0.0012 0.0045 0.01 NA 0.0014 0.0054 0.012 NA 0.0053 0.0197 0.044 NA 0.000024 0.0001 0.0002 NA

Mar-12 0.0419 0.0736 0.48 NA 0.001 0.0018 0.012 NA 0.004 0.0071 0.046 NA 0.000017 0.00 0.0002 NA

Apr-12 0.0171 0.0471 0.4 NA 0.0004 0.0012 0.01 NA 0.0019 0.0053 0.045 NA 0.000009 0.00 0.0002 NA

May-12 0.1077 1.5135 0.78 NA 0.0017 0.0233 0.012 NA 0.0047 0.066 0.034 NA 0.000028 0.0004 0.0002 NA

Jun-12 0.2603 0.66 0.65 NA 0.004 0.0102 0.01 NA 0.0092 0.0234 0.023 NA 0.00008 0.0002 0.0002 NA

Jul-12 0.3381 0.7471 0.65 NA 0.0052 0.0115 0.01 NA 0.013 0.0287 0.025 NA 0.000104 0.0002 0.0002 NA

Aug-12 0.213 0.517 0.49 NA 0.0052 0.0127 0.012 NA 0.0083 0.02 0.019 NA 0.000087 0.0002 0.0002 NA

Sep-12 0.1734 0.6349 0.5 NA 0.0066 0.0241 0.019 NA 0.0066 0.0241 0.019 NA 0.000069 0.0003 0.0002 NA

Oct-12 0.0962 0.6919 0.44 NA 0.0042 0.0299 0.019 NA 0.0066 0.0472 0.03 NA 0.000044 0.0003 0.0002 NA

Nov-12 0.0057 0.0095 0.25 NA 0.0004 0.0007 0.018 NA 0.0011 0.0018 0.048 NA 0.000005 0.00 0.0002 NA

Dec-12 0.012 0.0367 0.21 NA 0.0007 0.0023 0.013 NA 0.0021 0.0065 0.037 NA 0.000011 0.00003 0.0002 NA

Jan-13 0.0721 0.1738 0.67 NA 0.0011 0.0026 0.01 NA 0.0032 0.0078 0.03 NA 0.000022 0.0001 0.0002 NA

Feb-13 0.00 0.00 0.00 NA 0.00 0.00 0.00 NA 0.00 0.00 0.00 NA 0.00 0.00 0.00 NA

Mar-13 0.0212 0.0484 0.2 NA 0.0021 0.0048 0.02 NA 0.0022 0.0051 0.021 NA 0.000021 0.00 0.0002 NA

Apr-13 0.0534 0.1119 0.62 NA 0.0017 0.0036 0.02 NA 0.0028 0.0058 0.032 NA 0.000017 0.00 0.0002 NA

May-13 0.1239 0.5329 1.4 NA 0.0009 0.0038 0.01 NA 0.0022 0.0095 0.025 NA 0.000018 0.0001 0.0002 NA

Jun-13 0.3005 1.2675 2 NA 0.027 0.1141 0.18 NA 0.0033 0.0139 0.022 NA 0.00003 0.0001 0.0002 NA

Jul-13 0.239 0.725 1.5 NA 0.0016 0.0048 0.01 NA 0.0035 0.0106 0.022 NA 0.000032 0.0001 0.0002 NA

Aug-13 0.0678 0.1472 0.22 NA 0.0062 0.0134 0.02 NA 0.008 0.0174 0.026 NA 0.000062 0.0001 0.0002 NA

Sep-13 0.088 0.1506 0.38 NA 0.0028 0.0048 0.012 NA 0.0081 0.0139 0.035 NA 0.000046 0.0001 0.0002 NA

Oct-13 0.114 0.1853 0.44 NA 0.0044 0.0072 0.017 NA 0.0101 0.0164 0.039 NA 0.000052 0.0001 0.0002 NA

Nov-13 0.0232 0.0511 0.12 NA 0.0019 0.0043 0.01 NA 0.0077 0.017 0.04 NA 0.000039 0.0001 0.0002 NA

Dec-13 0.0199 0.0357 0.36 NA 0.0013 0.0023 0.023 NA 0.0025 0.0045 0.045 NA 0.000011 0.00 0.0002 NA

Jan-14 0.0141 0.0528 0.1 NA 0.0014 0.0053 0.01 NA 0.0056 0.0211 0.04 NA 0.000028 0.0001 0.0002 NA

Feb-14 0.0244 0.0726 0.1 NA 0.0024 0.0073 0.01 NA 0.0063 0.0189 0.026 NA 0.000049 0.0001 0.0002 NA

Mar-14 0.1292 0.6029 0.58 NA 0.0022 0.0104 0.01 NA 0.0062 0.0291 0.028 NA 0.000045 0.0002 0.0002 NA

Apr-14 0.2008 0.4551 0.72 NA 0.0028 0.0063 0.01 NA 0.0089 0.0202 0.032 NA 0.000056 0.0001 0.0002 NA

May-14 0.2183 0.5325 0.56 NA 0.0078 0.019 0.02 NA 0.0078 0.019 0.02 NA 0.000078 0.0002 0.0002 NA

Jun-14 0.187 0.4268 0.38 NA 0.0098 0.0225 0.02 NA 0.0153 0.0348 0.031 NA 0.000098 0.0002 0.0002 NA

Jul-14 0.178 0.2941 0.22 NA 0.0081 0.0134 0.01 NA 0.0259 0.0428 0.032 NA 0.000162 0.0003 0.0002 NA

Aug-14 0.523 0.9093 0.72 NA 0.0145 0.0253 0.02 NA 0.0167 0.029 0.023 NA 0.000145 0.0003 0.0002 NA

Sep-14 0.5006 0.7584 0.81 NA 0.0093 0.014 0.015 NA 0.0117 0.0178 0.019 NA 0.000124 0.0002 0.0002 NA

Oct-14 0.2935 0.5886 0.47 NA 0.0062 0.0125 0.01 NA 0.0231 0.0463 0.037 NA 0.000125 0.0003 0.0002 NA

Nov-14 0.0402 0.1226 0.2 NA 0.002 0.0061 0.01 NA 0.0074 0.0227 0.037 NA 0.00004 0.0001 0.0002 NA

Dec-14 0.0107 0.0286 0.1 NA 0.0011 0.0029 0.01 NA 0.0037 0.0097 0.034 NA 0.000021 0.0001 0.0002 NA

Jan-15 0.068 0.1151 0.3 NA 0.0045 0.0077 0.02 NA 0.0057 0.0096 0.025 NA 0.000045 0.0001 0.0002 NA

Feb-15 0.0253 0.0684 0.23 NA 0.0022 0.0059 0.02 NA 0.0023 0.0062 0.021 NA 0.000022 0.0001 0.0002 NA

Mar-15 0.0293 0.0502 0.2 NA 0.0029 0.005 0.02 NA 0.0041 0.007 0.028 NA 0.000029 0.0001 0.0002 NA

Apr-15 0.0733 0.3426 0.6 NA 0.0055 0.0257 0.045 NA 0.0034 0.016 0.028 NA 0.000024 0.0001 0.0002 NA

May-15 0.0999 0.2644 0.2 NA 0.005 0.0132 0.01 NA 0.014 0.037 0.028 NA 0.0001 0.0003 0.0002 NA

Jun-15 0.1666 0.299 0.37 NA 0.009 0.0162 0.02 NA 0.009 0.0162 0.02 NA 0.00009 0.0002 0.0002 NA

Jul-15 0.1393 0.1665 0.32 NA 0.0087 0.0104 0.02 NA 0.0157 0.0187 0.036 NA 0.000087 0.0001 0.0002 NA

Aug-15 0.1807 0.2947 0.4 NA 0.009 0.0147 0.02 NA 0.0117 0.0192 0.026 NA 0.00009 0.0001 0.0002 NA

Sep-15 0.095 0.1373 0.19 NA 0.005 0.0072 0.01 NA 0.019 0.0275 0.038 NA 0.0001 0.0001 0.0002 NA

Oct-15 0.0623 0.1735 0.17 NA 0.0037 0.0102 0.01 NA 0.0099 0.0276 0.027 NA 0.000073 0.0002 0.0002 NA

Nov-15 0.0236 0.0816 0.39 NA 0.0012 0.0042 0.02 NA 0.0013 0.0046 0.022 NA 0.000012 0.00 0.0002 NA

Dec-15 0.0187 0.0538 0.1 NA 0.0019 0.0054 0.01 NA 0.003 0.0086 0.016 NA 0.000037 0.0001 0.0002 NA

Mercury (lbs/MG) Mercury (mg/L)Aluminum (lbs/MG) Aluminum (mg/L) Copper (lbs/MG) Copper (mg/L) Selenium (lbs/MG) Selenium (mg/L)

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