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Manufacturing Facility

Florence, South Carolina

Roux Associates conducted Resource Conservation and Recovery Act (RCRA) corrective action and post-closure care activities at a 40-acre metal finishing and manufacturing facility located in Florence, South Carolina. Constituents of concern at the site include chlorinated volatile organic compounds and metals. The primary media of concern were soils and groundwater. The ICM involves operation and monitoring of a groundwater extraction system near the SWMUs at the facility. Based on the results of the RFI, Roux Associates successfully negotiated approval of no further soil or groundwater delineation activities for the site. The facility Solid Waste Management Units (SWMUs) include two Waste Management Areas (WMAs) that are regulated as RCRA land disposal units and two SWMUs that are regulated under RCRA as areas that are not linked to WMAs. Both the USEPA Region IV and the South Carolina Department of Health and Environmental Control (SCDHEC) direct the RCRA program, and the two programs have overlapping jurisdictions. Roux Associates has worked with the client and both agencies to develop a strategy for regulatory compliance without unnecessary duplication of effort.

Project activities included:

  • groundwater delineation and source area investigation
  • preparation of the RCRA Facility Investigation (RFI) report
  • corrective action monitoring
  • development and implementation of Interim Corrective Measures (ICMs)
  • preparation of the Post-Closure Care permit renewal application
  • operation and monitoring of the facility groundwater extraction system as an ICM
  • groundwater extraction system optimization
  • preparation of the facility deed restriction and land use management control management plan.

    • Through an evaluation of historic practices, RFI sampling results and groundwater quality to date, Roux Associates was able to limit the analytical requirements for the RFI and groundwater monitoring programs resulting in substantial cost savings. Based on the proven effectiveness of the ICMs, the USEPA and SCDHEC waived the requirement for a Corrective Measures Study (CMS) for the site, requiring instead a limited evaluation of the effectiveness of the existing groundwater treatment program. Roux Associates successfully petitioned for a Class III Permit modification for optimizing recovery using pulsed pumping from existing groundwater extraction wells, which resulted in the permanent shut down of two extraction wells. Roux Associates continues to advocate for our client to ensure that the project continues to move toward closure within the regulatory framework.