LCP Chemicals Georgia Inc.

Three Rivers Regional Library System
(formerly Brunswick-Glynn County Library System)
208 Gloucester Street
Brunswick, Georgia 31520

• Site Profile
• Administrative Record Index: Removal (PDF, 30 pp., 3.3M)
• Fact Sheet, June 2002 (PDF, 4 pp., 22K)
• For documents not available on the website, please contact the Region 4 Freedom of Information Office (http://www.epa.gov/region4/foiapgs/submit.htm).

Site Background:
The LCP Chemicals Superfund Site consists of approximately 800 acres, the majority of which is a tidal marsh. An oil refinery, a paint manufacturing company, a power plant, and a chlor-alkali plant have all operated at this site over the last 70 years.  Since 1919 this site has been occupied by at least five major companies: Atlantic Refining Company (ARCO); Georgia Power Company; Dixie Paints and Varnish Company (currently, the O'Brien Company); Allied Chemical Inc. (currently, Allied Signal); and, the Hanlin Group subsidiary, LCP Chemicals-Georgia, Inc.  During various manufacturing activities, the site became contaminated with mercury, polychlorinated biphenyls (PCBs), and semi-volatile contamination in site soils, in groundwater, and in the biota in the marsh.  

Upon the plant's closing in February 1994, the State of Georgia asked EPA to take immediate action at the Site.  EPA needed to address the threat of releases of chlorine gas and the flow of contamination into the adjacent saltwater tidal marsh containing endangered species.  In 1994, EPA issued a Unilateral Administrative Order for Removal (UAO) to several of the former owners/operators of the facility which instructed them to undertake cleanup operations at the Site. In March 1995, the State of Georgia designated the LCP Site as the highest priority release Site in Georgia and requested that it be immediately placed by EPA on the Superfund National Priorities List.  On June 17, 1996, the Site was finalized on the NPL.  Between 1994 and 1997, the removal action was performed on the estimated 70 acres comprising the upland portion of the Site.  The removal action included the excavation of contaminated soils and industrial process waste from 26 discrete areas.  A total of approximately 167,000 cubic yards of soil, sediment, and waste were removed.  The removal areas contained material contaminated with constituents including petroleum hydrocarbons (volatile and semi-volatile organic compounds), mercury, alkaline sludges, polychlorinated biphenyls (PCBs), and lead.  Between 1998 and 1999, the removal response action was extended to approximately 13 acres within the marsh and 2,650 linear feet of tidal channels.  Also, petroleum process buildings and the mercury cell buildings were among the structures that were dismantled. 

Cleanup Progress:

Operable unit 1 (OU1) previously represented the marsh and upland soils and OU2 represented groundwater.  During 2005, EPA redefined the operable units as follows: OU1 represents the marsh, OU2 represents groundwater, and OU3 represents the upland soils.  OU3 was created to allow EPA to separate 2 technically different areas. 

OU1: Marsh
Due to redefining this OU to represent only the marsh, EPA requested that the Potentially Responsible Parties (PRPs) submit an updated RI Report that will focus on OU1 (the current report contains the marsh and upland soils), an updated Human Health Risk Assessment (HHRA), and a Baseline Ecological Risk Assessment (BERA) which will include data that was collected after the previous report.   EPA and Georgia Environmental Protection Division (GaEPD) are working with the PRPs to finalize both reports. 

In order to summarize recent data, the PRPs submitted a data report for the Fall 2007 Estuarine Ecological Monitoring Event.  Since enough data has been collected to characterize the marsh, EPA is moving forward with selecting a cleanup remedy.  It’s projected that the Record of Decision for the marsh will be issued during the Fall of 2009 if outstanding reports are finalized within the next few months.    

OU2: Groundwater
This OU is in the RI/FS Phase.  Annual groundwater monitoring has occurred since 2001.  Leakage of contamination (i.e. Hg) was discovered beneath a sandstone layer.  As a result, horizontal wells were installed in 2002 (approximately 75 feet below ground surface).  In addition, a caustic brine pool (CBP) which has a high pH was discovered beneath the site.  A phytoremediation project was approved by EPA during November 2003. The purpose of this study is to locally suppress the groundwater table to prevent seepage of groundwater and staining of sediments from occurring. This study is a pilot project and is not the Record of Decision (ROD)-specified cleanup remedy for the site.  In order to address the CBP, EPA issued an Action Memorandum dated, March 31, 2006.  Also on March 31, 2006, EPA issued a letter to the PRPs which highlighted EPA’s and GaEPD’s critical issues and requested an updated RI Addendum Report.  EPA negotiated an Administrative Order on Consent (AOC) with the PRPs on April 18, 2007.  The CBP will be extracted to meet the following removal action objectives: 1) reduce the pH of the CBP to less than 10.5, and 2) reduce the density of the CBP.  The removal action began on September 25, 2007.  The PRPs installed 12 extraction wells and a baseline sampling event was performed to establish the groundwater quality characteristics throughout this area of the site, prior to initiation of the CBP removal.  This data is presented in a technical memo which was received during April 2008.  Approximately 20,000 gallons of CBP was extracted from the aquifer as a result of the step-drawdown testing.  This material is stored in on-site holding tanks, and is being used for treatability study testing.  A technical memorandum (TM) titled “Initial Treatability Testing of Caustic Brine, LCP Brunswick Site” for the caustic brine pool (CBP) removal action was submitted in March 2008 to cover the treatability study.  This TM was reviewed and commented on by EPA and GaEPD.  Both agencies reviewed the Conceptual Design for Removal Action on the CBP (August 26, 2008).  A final regulatory comment letter was issued on February 9, 2009 and it was agreed that the removal action could be implemented full scale.  Groundwater will be remediated after a final cleanup remedy is selected.  The removal action should be completed by the end of 2010.  Also, the PRPs prepared a Groundwater Seep Sampling Plan to determine the impact of groundwater seeps on the marsh.  EPA, GaEPD, NOAA, and the PRPs are working together to finalize the sampling plan so this sampling event can be implemented. 

OU3: Upland Soils
This OU is in the RI/FS Phase.  During November 2004, soil samples were collected in the neighborhood adjacent to the site.  A public meeting was held on June 23, 2005.  No contamination from the LCP site was detected.  As a result of creating this new OU, the PRPs were asked to update the RI/FS report to focus on OU3 and write an updated risk assessment to include a new site worker scenario. The Update to the 1999 Human Health Baseline Risk Assessment (HHBRA) for Upland Soils, Operable Unit 3 was approved by EPA on March 13, 2007.  The updated RI/FS report was submitted to EPA during May 2007.  After reviewing this report, It was determined that a complete ecological risk assessment must be done in order to evaluate the site for potential ecological use.  The PRPs began working on this new ecological risk assessment during August 2007.  EPA and GaEPD approved the Work Plan for the ecological risk assessment on August 15, 2008.  EPA and GaEPD commented on the Addendum to the May 2007 OU3 HHRA Report and the Baseline Ecological Risk Assessment for the Upland.  The PRPs have revised the Addendum to the May 2007 HHRA Report which is being reviewed by EPA and GaEPD.  A Record of Decision will document how the site will be cleaned up.  It is scheduled for completion by the Fall of 2009 if outstanding reports are finalized within the next few months.  Also, a technical memo on modeling of the migration of soil constituents to groundwater was submitted by the PRPs.  It was determined that the PRPs should complete a Work Plan for Direct Testing of Soil Leaching Potential.  If direct testing is successful, the need for modeling of the migration of soil constituents to groundwater will no longer be required.  Evaluation of this pathway must be completed as a part of the HHRA.