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GIVING DAYS 2024
Double your impact
by making a gift during
Giving Days May 7 & 8
Double your impact
by making a gift during
Giving Days May 7 & 8
Thirty years ago, coal tar contamination was discovered on the site of a former Manufactured Gas Plant (MGP) on Bramlett Road in the Southernside Community of Greenville. Coal tar was first encountered in a large tract of wetlands south of Bramlett Road and adjacent to the Reedy River.
The coal tar was discovered because an illegal landfill had been operating in these wetlands, and inspectors were onsite to evaluate the landfill. The source of the coal tar was quickly traced to the former MGP site northeast of these wetlands, at the corner of E. Bramlett Road and W. Washington Street.
Testing for the location and extent of contamination began in 1994, and it has continued ever since with no actual remedial and restorative actions in sight. Over the years, Duke Energy has employed many different environmental consultants who have proposed and undertaken various testing and have prepared dozens of lengthy reports. Most recently, building upon all the testing and reports from the last decade, Duke and their consultants finally completed a study developing and evaluating options for the remedial cleanup of the Bramlett site. Duke’s findings, which included five remedial options, were published in a Focused Feasibility Study in October of 2023 and submitted to the South Carolina Department of Health and Environmental Control (DHEC).
Now that Duke has submitted the Focused Feasibility Study, the path for selecting a cleanup alternative begins. In this process, DHEC considers the alternatives presented, selects a preferred alternative, publishes their preferred alternative in a Proposed Plan, receives public comment on the Proposed Plan, considers those public comments, revises their preferred alternative in light of the public comments received, and then issues a Record of Decision that details the chosen cleanup remedy for the site.
Because the cleanup alternatives proposed by Duke are forming the basis of DHEC’s decision, we commissioned an expert report from an environmental consulting firm to objectively evaluate the remedial alternatives and independently review the results of Duke’s own testing. That report was finalized in May of 2024, and it reached the emphatic conclusion that a more comprehensive cleanup than those listed in the Focused Feasibility Study is needed to fully remediate and restore the Bramlett site. View the report.
The team at Aquilogic, Inc. has extensive experience evaluating contamination specifically at former MGP sites. Based on their review of all available data on this site, Aquilogic concluded that a fully comprehensive cleanup should be selected and adopted. In particular, Aquilogic recommended immediate removal of the old landfill and excavation of the ponds and various other deposits of coal tar on which it sits. In addition, excavation should occur along the length of the discharge ditch, including all contaminated soil in and around this historic conduit for coal tar, to the confluence of the ditch with the Reedy River. After these excavations, all of the wetlands on these parcels should be restored to natural and/or improved wetlands. Further, a long-term groundwater remedy including pump and treat should be implemented to prevent the discharge of contaminated water to surrounding parcels and the Reedy River. Finally, Aquilogic made specific recommendations for testing that should take place immediately in order to fully delineate the extent of contamination and finally answer the question of whether the contaminated groundwater is discharging into the Reedy River.
On June 6, 2024, DHEC will host a public meeting at Mountain View Baptist Church at 6:00 PM to present their Proposed Plan to the community. After that, the public will be able to submit formal comments on DHEC’s Proposed Plan in a public comment period running from June 6, 2024 until August 6, 2024. We are representing Mountain View Baptist Church in advocating for a fully restorative cleanup of the Bramlett site and all coal tar contamination, and we will continue to urge DHEC to stand for environmental justice, comprehensively clean-up the site, and center the community’s needs throughout the cleanup process.
The Historical and Significant Importance of the Southernside Community
The Southernside Neighborhood, located in Greenville, South Carolina, is a historically significant, predominantly African American community. Notably, it was included in the Green Book as a safe destination for African American travelers during segregation. In fact, the Southernside community hosted prominent African American figures like Duke Ellington, Sarah Vaughan, Ella Fitzgerald, Della Reese, and Ethel Waters. Given the cultural importance of this community, it is paramount to protect and preserve the land, which includes thoroughly cleaning up the Bramlett site. The contamination in the project area, along with the vacant, unusable land it produces, places a tremendous burden on the overall well-being of surrounding Southernside.
The Tale of Two Sites
Greenville had a second MGP operation in the early 1900s on Broad Street, across from what is now Northampton Wine. The condition of the Broad Street and Bramlett sites today tells a story of environmental inequity and of how the natural environment of all Greenvillians is not created equal.
Duke Power's clean-up of the Broad Street MGP started in 1995. Workers dug to the bedrock during multiple excavations of the property and utilized sophisticated aeration and injection systems to restore the property for residential development. Today on the old Broad Street site, one can experience “luxury living in Greenville” at the Ellison on Broad apartment complex.
In Southernside, by contrast, the only “redevelopment” of the Bramlett MGP site is a failing barbed wire fence designed to keep residents out. Other than limited removal of structures and surface coal tar in 2000, contamination from the Bramlett MGP operation remains in the ground and water of Southernside, spreading toward and into the Reedy River.
As Attorney Michael Corley wrote in the Greenville News:
How did two sites within the same city, contaminated by the same toxins, from the same operation during the same time period, by the same company, end up with such divergent outcomes? The answer most certainly has to do with the identity of the residents in the communities surrounding those sites.
The concept of environmental justice emerged from recognition that certain communities—typically low-income, minority, rural, or those otherwise lacking in political or capital influence — are often forced to bear a disproportionate burden of environmental harm. Indeed, in my career as a public interest environmental lawyer, I’ve observed that new landfills don’t tend to get sited near second homes; that highway expansions don’t disrupt wealthy neighborhoods; and that complaints from certain zip codes tend to get an inspector onsite more quickly.
Early Efforts
Our team began studying the Bramlett site around 2018. That same year, Duke issued a proposal that set the stage for years of more testing, but that proposal still sidestepped the most critical locations and questions on the site.
Frustrated by the lack of progress toward a remedial action, we commissioned our own testing at critical locations on the site and retained expert consultants to generate an independent review of Duke’s results over 25 years and our own testing. That report was finalized in 2019, with concrete recommendations for immediate cleanup.
The objective of our testing was to determine whether toxins continue to discharge into the Reedy from the ditch that was used to carry coal tar laden wastewater from the facility during its operation. This ditch originated from the facility, went south under Bramlett Road and continued approximately 800 yards through the wetlands to a discharge point on the Reedy River at Willard Road. This discharge point is at the very southern end of the affected property, much further south than what Duke had portrayed as the limit of contamination. Today, the final piece of this discharge ditch runs under the Swamp Rabbit Trail, adjacent to the boundary of Unity Park.
Five samples were collected from the discharge ditch near the point where it enters the River. The total carcinogenic polyaromatic hydrocarbons (carcinogenic PAHs) in those samples ranged from 6,600 to 22,800 ug/kg, with an average around 16,500 ug/kg. The standard for cleanup that Duke has previously used on this site is 319 ug/kg. Testing in the Reedy River around the discharge point confirmed that these toxins are entering the River. Just upstream of the discharge point, all samples have come back negative for carcinogenic PAHs. Just downstream of the discharge point, carcinogenic PAHs registered at 2,412 ug/kg.
Our Response to the Focused Feasibility Study Work Plan in 2022
A few years later, on August 19, 2022, Duke Energy submitted its Focused Feasibility Study Work Plan, which set forth several different remedial alternatives for the site. DHEC approved the Feasibility Study Work Plan, and Duke Energy started conducting the Feasibility Study. Recognizing the critical opportunity to advocate for the complete and thorough remediation of the entire Bramlett site, SCELP submitted a letter urging DHEC to adopt the remedial alternative Aquilogic recommended in its report in 2019.
SCELP's close scrutiny of the reports and data created over the last thirty years has led it one conclusion: The only alternative capable of accomplishing the goals stated in the work plan—to restore soils and sediments to residential standards and restore groundwater to the appropriate maximum contaminant level—is excavation of all contaminated soils and sediments, including the Vaughn Landfill, and a pump and treat system to restore the groundwater. Our letter noted several key findings that demonstrate the necessity for DHEC to adopt this alternative. Specifically, soil samples located alarmingly close to the Legacy Charter School contained levels of carcinogens far beyond residential screening levels.
In addition to these highly contaminated samples near an elementary school, we pointed out how DHEC's conclusion regarding its soil sampling near Mountain View Baptist Church and the surrounding community is extraordinarily flawed. DHEC concluded and informed the community that the soil was unaffected by the contamination from the Bramlett site and the former operations of the MGP. However, this conclusion is significantly flawed because it ignored the fact that the background sample it relied on contains elevated levels because of its close proximity to the Bramlett site and is itself tainted.
Contrary to DHEC's conclusion, the differing results for the Southernside Sample and the North Main Sample demonstrate that the Bramlett MGP has affected soils surrounding Mountain View Baptist Church, which should be included as part of any remediation efforts.
Our Advocacy Efforts in 2024
Now that the Focused Feasibility Study has been published, the tables now turn to DHEC to make a critical decision about how the Bramlett site will be cleaned up. In their Proposed Plan, DHEC states that Alternative 5 is the preferred alternative, which includes: excavation of the Vaughn landfill, excavation of impacted sediments, monitored natural attenuation of groundwater, and land use controls to restrict development and groundwater use. While Alternative 5 is the most comprehensive cleanup option presented in Duke Energy’s Focused Feasibility Study, the Aquilogic report points out several deficiencies that must be considered in order to address significant community and environmental harm originating from this site.
To make certain that these harms are properly addressed by DHEC, we are advocating for a cleanup solution we’ve coined “Alternative 5+”. The Alternative 5+ remedial approach includes: (1) full excavation of the Vaughn landfill; (2) excavation of all contaminated sediment, including along the course of the drainage ditch to the confluence of the drainage ditch with the Reedy River; (3) restoration of all excavated portions to a natural wetland and/or an improved wetland; (4) a long-term groundwater remedy including pump and treat that extends to the bedrock zone to prevent the continued discharge of contaminated water; and (5) heightened monitoring, sampling, and studying of the site and surrounding areas for the future.
CSXT has claimed in a letter to DHEC that it bears no liability for the removing the landfilled material because it never allowed the dumping of a massive amount of debris onto its property. CSXT makes this claim even though Vaughn Construction and Demolition attempted to purchase property onsite from CSXT for the express purpose of constructing a solid waste landfill. Further, Vaughn engaged in illegal landfilling activities for at least five years next to a CSXT office despite never completing the property transfer.
CSXT cannot stand behind such willful blindness to avoid liability, and SCELP will push for CSXT to participate in the cleanup for its share of the contamination on the Bramlett site as the remedial action process moves forward. As the time for implementing a cleanup alternative grows closer, SCELP also urges DHEC to use every tool at its disposal to ensure that CSXT answers for its portion of the contamination and cleanup cost.
