Shakespeare Composite Strtuctures Site Proposed Plan & Public Meeting The South Carolina Department of Environmental Services (SCDES) has completed an evaluation of cleanup alternatives to address contamination at the Shakespeare Composite Structures Site (the Site). The Proposed Plan identifies SCDES’s Preferred Alternative for cleanup and provides the reasoning for this preference. SCDES will hold an in person public meeting to further explain the Proposed Plan and all the alternatives presented in the Remedial Alternatives Evaluation and answer questions.
A public meeting will be held on March 11, 2025 at 6pm at the Newberry Firehouse Conference Center located at 1227 McKibben Street, Newberry, SC at 6:00 PM. SCDES will accept written comments on the Proposed Plan from March 11, 2025 until April 14, 2025. Please submit your written comments to: |
Site History
The Shakespeare Composite Structure Site (the Site) is located at 19845 US Highway 76, approximately 1 mile northwest of Newberry, Newberry County, South Carolina. The Site includes approximately 24 acres. The land surrounding the Site includes agricultural, residential, undeveloped, and commercial/light industrial properties.
Prior to purchase by Shakespeare Composite Structures, LLC (Shakespeare) in 1965, the property was an undeveloped wooded land. The facility has operated for fiberglass product production that continues to this day. The facility has two main structures, the Main production building (Main Building) built in 1966, and the Pole Winder building constructed in the late 1970s. These two buildings total approximately 250,000 square feet. Several smaller outlying structures located on the west end of the property, includes a hazardous waste storage building, a residual resin curing building, and other smaller storage buildings have been built over the years. Operations at the facility include the design and manufacture of large fiberglass utility poles and cross arms, and a variety of other products such as posts, signs, and sheet piling. The manufacturing processes include the following categories: materials received, formulation of resin mixes, pultrusion of fiberglass products, extrusion of plastic products, winding of fiberglass poles, painting, heat curing of poles, testing of materials, warehouse/storage of finished goods, and packaging/shipping. The finishing process for the products are completed on site.
In December 2013, Shakespeare Composite Structures, LLC (Shakespeare), a division of Philips Electronics North America Corporation (PENAC), initiated a series of environmental assessments to investigate the Site. The results showed elevated concentrations of chlorinated volatile organic compounds (CVOCs) in soil and groundwater. PENAC entered into a responsible party voluntary cleanup contract (VCC-14-6271-RP) with the DHEC to further assess and evaluate cleanup alternatives at the Site. PENAC has since been reorganized to the larger Signify North America Corporation (Signify). The facility has since been purchased by Valmont Composite Structures and continues with the fiberglass production.
Areas of Concern
Since construction, the facility has been used to produce fiberglass products. During initial assessments at the Site, chlorinated volatile organic compounds were detected in the groundwater, soil, and sub-slab vapors. The chemicals of concern (CoCs) at the Site that have exceeded their United States Environmental Protection Agency (EPA) Maximum Contaminant Levels (MCLs) in the groundwater are tetrachloroethene (PCE), trichloroethene (TCE), cis-1,2-dichloroethene (cis-1,2 DCE), and vinyl chloride (VC). MCLs for these compounds are 5 µg/L (PCE, TCE), 70 µg/L (cis-1,2 DCE) and 2 µg/L (VC). Based on relative concentrations and abundance, TCE is considered the primary driver for groundwater contamination. Soil concentrations only exceeded MCL-based soil screening levels (SSLs) for methylene chloride, styrene and TCE. The first two compounds are currently in use on site, and none on of the soil CoCs exceed the industrial regional screening levels (RSLs). The only sub-slab vapors that exceed their RSLs are TCE and cis-1,2 DCE.
During the Remedial Investigation, it was determined that the source areas for the CVOCs originated from historical operation practices that impacted groundwater beneath the western portions of the Main and Pole Winder Buildings. Groundwater contamination has migrated off-site to adjacent properties in the shallow, intermediate, and bedrock zones of the aquifer, and water supply wells have been impacted. The impacted water supply wells have been removed from service and water is being supplied through municipal sources. There are numerous surface water bodies and intermittent creeks in the area that have historically shown low level impacts below the MCLs.
SCDES’s Preferred Cleanup Alternative
SCDES has identified Alternative 5 from the Feasibility Study as the preferred alternative to address the contamination at the Shakespeare Site. Alternative 5, combines the use of in situ chemical oxidation (ISCO), in situ chemical reduction (ISCR), in situ adsorption (ISA), monitored natural attenuation (MNA), institutional controls (ICs), and containment via cover (CvC).
Alternative 5 initially begins treatment using ISCO in Area 1 and ISCR and ISA in Areas 2A thru 2 H, 3A, 3B, 4 and 5. ISCO in Area 1 would consist of a series of injection points through the concrete floors to come into direct contact with contamination in the soil and groundwater. ISCR and ISA would also use a series of injection points throughout the targeted areas. A chemical reductant, such as ZVI, would be injected into shallow groundwater zone hot spot areas using a geoprobe rig or rotosonic drilling. Activated carbon (either colloidal or powdered) would be injected into shallow groundwater zone hot spots in order to provide both a media to adsorb the targeted CoCs as well as provide a matrix for intrinsic microorganisms to attach to while reductively dechlorinating the target CVOCs. Only two events are planned for ISCR/ISA. Both the shallow and intermediate groundwater zones are being targeted for this treatment; deep groundwater zones and downgradient contamination are expected to reduce once the initial source area is addressed. A Pilot Study (AECOM, May 2023) was completed in 2023 in which ISCO and to some extent ISCR (included as part of ISERD) saw initial reductions in concentrations.
Groundwater monitoring would be conducted throughout the treatment process and to monitoring post-remediation levels at the Site to ensure the progress of the treatment. A transition to MNA would occur after the volume of course area contamination has been reduced. Institutional controls such as land and groundwater use restrictions would be implemented both onsite and offsite as part of the plan. The floor of the Main Building will be maintained as part of the containment via cover operations. This alternative would have a five-year review post treatment to demonstrate that cleanup goals are being achieved. The total estimated net present worth of this alternative combination is approximately $2,393,000 over a 30-year period.
Administrative Record
The Administrative Record includes historic and recent documents used by SCDES in its oversight role. The Administrative Record documents are provided below for convenient access by those who are interested in learning more about the site:
- Work Plan for Geoprobe Feasibility & ROI Field Injection Testing MW Installation Permit Request for Temporary Wells (1-15-25)
- Review of Feasibility Study Report (6-13-24)
- Feasibility Study Report, Attachment D (4-12-24)
- Feasibility Study Report (4-12-24)
- Feasibility Study Technical Memorandum (3-1-24)
- Sitewide GW Monitoring Report (5-31-23)
- Pilot Study Report (5-15-23)
- MW Installation Permit Request (7-8-21)
- Review of Pilot Study Work Plan (10-16-20)
- Pilot Study Work Plan (10-1-20)
- Review of Bench Scale Treatability Study Report (6-15-20)
- Bench Scale Treatability Study (5-28-20)
- Review of Bench Scale Treatability Study Work Plan & Summary of June 2019 Water Supply Well Sampling (8-23-19)
- Bench Scale Treatability Study Work Plan (7-30-19)
- Review of Feasibility Study Work Plan (6-4-19)
- Feasibility Study Work Plan (5-15-19)
- Review of RI Report (2-4-19)
- RI Report & Baseline Risk Assessment, App I-Baseline Risk Assessment (11-20-18)
- RI Report & Baseline Risk Assessment, App G, App H (11-20-18)
- RI Report & Baseline Risk Assessment, App F (11-20-18)
- RI Report & Baseline Risk Assessment, App C, App D, App E (11-20-18)
- RI Report & Baseline Risk Assessment, App A, App B (11-20-18)
- RI Report & Baseline Risk Assessment, Text, Figures, Tables (11-20-18)
- Review of Work Plan for Well Installation & Soil Vapor Sampling (11-21-17)
- Work Plan for Well Installation & Soil Vapor Sampling (11-15-17)
- Review of Phase II RI Work Plan (5-9-17)
- Phase II RI Work Plan (4-18-17)
- 3-D Model Delivery (11-10-16)
- Review of Summary of Well Installation & Sampling Efforts (5-25-16)
- Summary of Well Installation & Sampling Efforts (5-18-16)
- Review of Site Investigation Work Plan Addendum (9-3-15)
- Revised Site Investigation Work Plan Addendum (8-20-15)
- Review of Site Investigation Work Plan Addendum, MW Approval (7-30-15)
- Review of Summary of Investigation Efforts, Additional Well Summary Table (7-29-15)
- Summary of Investigation Efforts (9-16-14)
- Executed VCC 14-6271-RP (9-8-14)
- Review of Work Plan & Request for Well Installation Permit, MW Approval (9-4-14)
- Well Permit Addendum (9-3-14)
- Review of Work Plan & Request for Well Installation Permit, MW Approval (8-7-14)
- Work Plan for Additional GW Sampling (8-6-14)
- Review of Work Plan & Request for Well Installation Permit, MW Approval (7-10-14)
- Work Plan & Request for Well Installation Permit (7-8-14)