B.01 PWS Enclosure 2C SITE-SPECIFIC GFI_18 FEB 26_clean.docx
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About this file
This is a Site-Specific Government Furnished Information (GFI) enclosure documenting baseline conditions and regulatory considerations for the Shaw Air Force Base Optimized Remediation Contract (ORC). The document provides detailed site-specific information organized by eighteen Installation Restoration Program (IRP) sites and two groundwater treatment plants, identifying current remedial activities, document status, regulatory submissions, and potential issues with South Carolina Department of Environmental Services (SCDES).
Key remedial activities include ozone/peroxone injection systems at multiple Areas of Concern (AOCs O, D, M, and SWMU 87) that have been shut down since 2020-2024 pending effectiveness evaluations, with the most recent injections completed in January 2025 (AOC O) and August 2025 (SWMU 87). Two groundwater treatment plants (GWTP-1 and GWTP-2) provide hydraulic control and cleanup for multiple sites with ongoing sampling and monitoring requirements. Critical regulatory issues include SCDES disputes over naphthalene remedial goals (25 mg/L vs. EPA Regional Screening Levels) at multiple sites (AOC M, SWMU 98, SWMU 99, SWMU 2, and AOC H), dieldrin remedial goal negation concerns at SWMU 78, and approval of reduced sampling analytes and frequencies at treatment plants. The document identifies numerous documents in various review stages by both the Air Force and SCDES, including draft 2025-2026 Corrective Measures Implementation/Progress Reports, feasibility studies, injection completion reports, and vapor intrusion investigations. Off-base sampling activities at Hoover and Levi Farms require annual agreements with property owners and deed notifications. The 2026 planned submittals include quarterly and annual monitoring reports across multiple sites, indicating ongoing operational and compliance activities supporting the objective of achieving site closure for unrestricted residential use.
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Other files
| File | Type | Posted |
|---|---|---|
| B.07 Sign in Roster - Shaw ORC Site Visit.pdf | ||
| B.07 Shaw ORC Site Visit Minutes.pdf | ||
| B.01 Shaw AFB FY26 ORC_PWS_v2.2.6_20260218_redlined.docx | DOCX document | |
| B.01 Attachment 8 Site Visit Information.pdf |
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ENCLOSURE 2C: SITE-SPECIFIC GFI
This summary of site-specific considerations is a result of internal AF discussion and analysis completed while formulating the performance objective (PO) and is provided as Government Furnished Information (GFI). As with all GFI, it is for informational purposes only; the Contractor remains responsible for developing their own independent, professional conclusions/ interpretation of site conditions and requirements to achieve the PO.
The Performance Work Statement (PWS) requires project scoping sessions before work plan development and throughout the planning and execution of the project to meet the PO. The AF review team has identified the following initial items to be considered in project scoping.
SHAW AFB AOC O (CG038)
AOC O/CG038 ozone system - shutdown in October 2020 due to limited effectiveness and to allow for remedial injections, the most recent injections were completed in January 2025, and effectiveness is currently being evaluated Documents not in the Administrative Record being provided as GFI (See spreadsheet titled “ PWS Enclsoure 2B Base Documents List”) Listing current as of 28 January 2026; Draft documents and any review comments (AF or regulator) will be provided if the document is not finalized and entered into the Administrative Record.
Document(s) in SCDES Review:
· Draft Final AOC O COGAC Injection Completion Tech Memo; submitted 7/18/2025
· Draft Final AOC O 2024 CMIPR; submitted 10/31/2025 Documents in Review by Air Force (AF):
· Draft 2025 AOC O CMIPR (Revision 01; redline and AF RTCs)
ORC Contractor Addressing SC DES Comments
· None ORC Contractor Addressing AF Comments
· None Documents in Preparation for AF Submittal
· Draft AOC O 2026 CMIPR Potential issues with SCDES:
None
Shaw AFB SWMU 101 (DP039) Documents not in the Administrative Record being provided as GFI Listing current as of 28 January 2025; Draft documents and any review comments (AF or regulator) will be provided if the document is not finalized and entered into the Administrative Record.
Document(s) in SCDES Review (See spreadsheet titled “PWS Enclsoure 2B Base Documents List …”:
· Draft 2024 Annual Monitoring Report- Submitted 11/14/2025
Document(s) in Air Force (AF) Review:
· Draft 2025 CMIPR
ORC Contractor addressing SCDES Review comments:
· None
ORC Contractor Addressing AF Comments:
· Draft SI Report Rev 02 and RTCs- AF RPM Comments sent to contractor 12/2/2025 (copy of document and any comments to be provided). AF CZT Subject Matter Expect Response to Comments sent to contractor 12/30/2025.
Documents in Preparation for submittal to AF:
· Draft SWMU 101 CMS/CMIWP (Pending resolution of the SI)
· Draft SWMU 101 2026 CMIPR
Shaw AFB SWMU 59 (FT001) SWMU 59/FT001 ozone system - shut down in October 2020 to allow for evaluation of the existing remedy, some injection points were abandoned for GWTP #2 construction; the AF does not plan to restart the system and plans to abandon the remainder of the system under the next ORC contract (Refer to Table 1 in the PWS).
Documents not in the Administrative Record being provided as GFI (See spreadsheet titled “PWS Enclsoure 2B Base Documents List”) Listing current as of 28 January 2026; Draft documents and any review comments (AF or regulator) will be provided if the document is not finalized and entered into the Administrative Record.
Documents in SC DES Review
· SWMU 59 Proposed Revised Monitoring Program; 26-Dec-’25 submittal
· SWMU 59 ’24 CMIPR; submitted 19-Jan-’26
· SWMU 59 Data Gap Investigation Report; submitted 16 Jan 2026; Section 7 Recommendations Change page submitted 27 Jan 2026
ORC Contractor addressing SCDES Review comments:
· None Documents in Review by Air Force (AF):
· None Document(s) in Preparation for submittal to AF:
· SWMU 59 Draft 2025 CMIPR
· SWMU 59 Draft 2026 CMIPR ORC Contractor Addressing AF Comments:
· None 2026 Planned Submittals
· See Sampling Transition Table (PWS Table 3)
Refer to the recommendations that are submitted in the Draft DGI report:
Shaw AFB Landfills
SWMU 58 (LF003)
SWMU 85 (LF008)
SWMU 52 (LF009)
Documents not in the Administrative Record being provided as GFI Listing current as of 28 January 2025; Draft documents and any review comments (AF or regulator) will be provided if the document is not finalized and entered into the Administrative Record.
Document(s) in Air Force (AF) Review (See spreadsheet titled “PWS Enclsoure 2B Base Documents List”:
· SWMU 58/LF003 Draft 2025 CMIPR (copy of document to be provided if available)
Document(s) in SCDES Review:
· Draft Feasibility Study/Corrective Measures Study Report and Proposed Plan Addendum Rev 01 and RTCS -SWMUs 52 and 58- Submitted 8/13/2025
ORC Contractor addressing SCDES Review comments:
· 2024 Annual Land Use Control Inspections- SWMU 52, 58, 85, comments received 1/28/2025. This document is to be removed from the list, this document was submitted to SCDHEC in error and other site documents that follow addresses SCDHEC comments.
ORC Contractor Addressing AF Comments:
· None
Document(s) in Preparation for submittal to AF:
· SWMU 85/LF008 Draft 2025 CMIPR (copy of document to be provided if available)
· SWMU 52/LF009 Draft 2025 CMIPR(copy of document to be provided if available)
Shaw AFB SWMU 78 (OT016A) Documents not in the Administrative Record being provided as GFI (See spreadsheet titled “PWS Enclsoure 2B Base Documents List”) Listing current as of 28 January 2026; Draft documents and any review comments (AF or regulator) will be provided if the document is not finalized and entered into the Administrative Record.
Document(s) in SCDES Review:
· Draft Final 2024 CMIPR (response to SCDES comments); submitted 22 Jan 2026 Documents in Air Force (AF) Review:
· 2025 CMIPR Rev 03 Change Pages and RTCs submitted to AF 1/26/2026 (document with change pages to be provided)- AF reviewed and made note that we must ensure that the ’25 CMIPR recommendations align with our planned response to SCDES’s comments on the ’24 CMIPR ORC Contractor addressing SCDES Review comments:
· None ORC Contractor Addressing AF Comments:
· None Documents in Preparation for submittal to AF:
· Draft SWMU 78 2026 CMIPR Potential issues with SCDES:
Dieldrin remedial goal:
· The Dieldrin Remedial Goal Option (RGO) of 0.185 µg/L was established in the May 2009 Corrective Measures Study (CMS) (AR#2318) and approved by SCDHEC in May 2009 (AR#2325). The groundwater RGOs are site-specific human health risk-based concentrations calculated for the 10-4 residential risk level.
· SCDES May 14, 2019 letter (AR#3926) stating the RGOs are negated because the dieldrin plume has expanded.
· The peroxone (ozone/peroxide) injection altered plume stability, which may reasonably justify revisiting monitoring frequency or requiring additional delineation. However, this does not justify negating an approved RGO.
· Shaw AFB accepts and will implement additional monitoring and delineation measures consistent with the Department’s concerns regarding plume expansion.
Shaw AFB’s position for this SCDES issue is that the CMS is the decision document, approved by SCDES and the Air Force. Cleanup goals shall remain as stipulated in 2009. Cleanup goals are fixed benchmarks for protection of human health and the environment and do not change based on plume behavior, remedial technology performance, or subsequent sampling events. Because of this, Shaw AFB should not concur with the Department’s assertion that the established and approved RGOs are negated. The RGOs for dieldrin (0.185 µg/L) and beta-BHC (2.99 µg/L) should remain valid as approved cleanup goals approved under the 2009 CMS and incorporated into the 2019 RCRA Permit.
SHAW AFB AOC D (OT016C)
AOC D/OT016C peroxone system - shutdown in October 2020 due to limited effectiveness and to allow for remedial injections, the most recent injections were completed in August 2022 and were successful at reducing COCs Documents not in the Administrative Record being provided as GFI (See spreadsheet titled “PWS Enclsoure 2B Base Documents List”) Listing current as of 28 January 2026; Draft documents and any review comments (AF or regulator) will be provided if the document is not finalized and entered into the Administrative Record.
Document(s) in SCDES Review:
· Draft Final AOC D 2024 CMIPR; submitted 10/31/2025 (copy will be provided) Documents in Review by Air Force (AF):
· Draft 2025 AOC D CMIPR (Revision 01; redline and RTCs)
· Vapor Intrusion Investigation Technical Memorandum for sites SWMU 87, AOC M, AOC D, SWMU 96, SWMU 98, SWMU 99; Review comments sent to contractor (5/19/2025). Received 23 Jan 2026 ORC Contractor Addressing SC DES Comments
· None ORC Contractor Addressing AF Comments
· None
Documents in Preparation for AF Submittal
· Draft AOC D 2026 CMIPR
SHAW AFB AOC W (OT016D) aka T-29 Documents not in the Administrative Record being provided as GFI (See spreadsheet titled “PWS Enclsoure 2B Base Documents List”) Listing current as of 28 January 2026; Draft documents and any review comments (AF or regulator) will be provided if the document is not finalized and entered into the Administrative Record.
Document(s) in SCDES Review:
· 2024 AMR Draft Final, Response to SCDES Comments and Change Pages; submitted 7/7/2025
· Draft 2025 AOC W AMR; submitted 1/15/2026 Documents in Review by Air Force (AF):
· Expanded AOC W RFI Report Rev 01 and RTCs (document and any additional AF comments will be provided) ORC Contractor Addressing SC DES Comments
· None ORC Contractor Addressing AF Comments
· None Documents in Preparation for AF Submittal
· AOC W Draft 2026 AMR
The Expanded RFI recommends No Further Action (NFA) for the site. While naphthalene concentrations exceed the EPA Tapwater Regional Screening Level (RSL), the state regulator has indicated that RSL exceedance alone constitutes a basis for remediation. Consistent with EPA Risk Assessment Guidance, a site-specific risk assessment was performed to evaluate actual risk. The results of this assessment demonstrate that naphthalene is not a Chemical of Concern and that the site does not present an unacceptable risk to human health.
Shaw AFB SWMU 96 (SD33) Documents not in the Administrative Record being provided as GFI Listing current as of 28 January 2025; Draft documents and any review comments (AF or regulator) will be provided if the document is not finalized and entered into the Administrative Record.
Document(s) in SCDES Review (See spreadsheet titled “PWS Enclsoure 2B Base Documents List”:
· Draft Final 2024 CMIPR; submitted to SC DES 12-Mar-’25 Documents in Review by Air Force (AF):
· 2025 CMIPR (Rev 01 SAFB RTCs); RTCs provided 08-Jan-’26
· Vapor Intrusion Investigation Technical Memorandum for sites SWMU 87, AOC M, AOC D, SWMU 96, SWMU 98, SWMU 99; Review comments sent to contractor (5/19/2025). Received 23 Jan 2026 ORC Contractor Addressing SC DES Comments
· None ORC Contractor Addressing AF Review Comments
· None Documents in Preparation for AF Submittal
· Remedy Completion Report (RCR); draft from ORC contractor estimated 15-Jan-’26
· 2026 SWMU 96 CMIPR
Potential issues with SCDES:
SC DES acceptance of SAFB recommendations:
· No more active remediation (’24 CMIPR)
· Non-COC metals mobilization due to ISCO injections
· Preparation of a RCR
· Resolution of LTM parameters (analytes & frequency)
Please refer to the 2024 CMIPR
Please refer to the 2025 CMIPR and TABLE 7-1
Shaw AFB AOC F, AOC H, AOC N & SWMU 2 Majority of reports include AOCs F, H, N and SWMU 2 together Please Note:
· AR#4368; Long Term and Performance Monitoring Program at AOC F/OT-16B, AOC H/SS-35, AOC N/SS-36 and SWMU 2/OU-1; this document will be revised if proposed sampling changes are approved by the regulator.
· Hoover and Levi Farms- Off-Base sampling and ROEs; current ROE agreement in route for Wing Commander signature; annual payment to property owner is necessary for monitoring area/well maintenance, Refer to Shaw ORC SubCLIN 0020.
· Conduct quarterly review of property cards for changes in ownership
· Annual bi-lateral agreement offer letters are sent to property owners to determine whether they want the AF to place a deed notification on the property for underlying groundwater contamination (This is done three times (annually) for the current property owner, before the offer letter is no longer sent)
· Off-base sampling annual results reporting to homeowners from the water samples collected from the monitoring wells on owners’ property.
· Annual notice letters informing property owners of groundwater contamination in the area.
Documents not in the Administrative Record being provided as GFI (See spreadsheet titled “PWS Enclsoure 2B Base Documents List) Listing current as of 28 January 2026; Draft documents and any review comments (AF or regulator) will be provided if the document is not finalized and entered into the Administrative Record.
Documents in Air Force (AF) Review:
· Draft 2025 CMIPR for AOC F, AOC H, AOC N, and SWMU 2, Rev 00
· Draft Q4 2025 Quarterly GWTP-1 PM Report at AOC F H N Rev 00
Document(s) in SCDES Review:
· 2023 5-Year Review Report -AOC F, H, N; submitted 3/5/2025
· Draft 2023 CMIPR for AOC F, AOC H, AOC N, and SWMU 2, Rev 00; submitted 5/29/2025
· Draft Remedial Evaluation and Recommendations Report Rev 00 (HRSC Report; 3D CSM snapshots included in the RERR as an attachment) Rev 01 and RTCs - AOC F, H, N, SWMU 2; submitted 9/18/2025 (Copy will be provided)
· Draft 2024 CMIPR for AOC F, AOC H, AOC N, and SWMU 2, Rev 00; submitted 9/22/2025 (Copy will be provided)
· Draft Q4 2025 Quarterly PM Report at AOC H; submitted 7 Jan 2026 (
ORC Contractor addressing SCDES Review comments:
· Vapor Intrusion Investigation Report Rev 02- AOC F, H, SWMU 2
Document(s) in Preparation for submittal to AF:
2026 Planned Submittals
· Draft Q4 2025 RA-O (Base Supply Well Report) at AOC H and N Rev 00
· Draft Q1 2025 Quarterly PM Report at AOC H
· Draft Q1 2025 Quarterly GWTP-1 PM Report at AOC F H N Rev 00
· Draft Q1 2026 RA-O (Base Supply Well Report) at AOC H and N Rev 00
· Draft Q2 2026 RA-O (Base Supply Well Report) at AOC H and N Rev 00
· Draft Q2 2025 Quarterly LTM and PM Report at AOC H
· Draft Q2 2025 Quarterly GWTP-1 LTM and PM Report at AOC F H N Rev 00
· Draft Q3 2025 Quarterly PM Report at AOC H
· Draft Q3 2025 Quarterly GWTP-1 PM Report at AOC F H N Rev 00
· Draft Q3 2026 RA-O (Base Supply Well Report) at AOC H and N Rev 00
· Draft 2026 CMIPR for AOC F, AOC H, AOC N, and SWMU 2, Rev 00
Potential issues with SCDES:
Naphthalene cleanup Goal
· SWMU 2:
· Final CMS 3/7/2013; proposes cleanup goal of HAL 100 µg/L (ppb), this level was an EPA health advisory level for Naphthalene at the time (AR#2931)
· CMS approval 4/26/2013 (AR# 2957)
· SOB 5/29/2013 (AR #2970); Naphthalene’s cleanup goal is listed as the RBSL (25 ppb)
· RCRA Permit (AR#3942) Table A-7 reflects CMS ( 4/26/2013) as approved corrective action document
· AOC H:
· AOC L was merged into AOC H in the 2019 RCRA Permit Renewal (AR#3942); AOC H now includes requirements of the fuel contaminated areas of AOC L.
· Final AOC L Corrective Measures Implementation (CMI) Workplan 11/13/2013 (AR#3097); Identified Naphthalene as a COC with 25 ppb as cleanup goal
· CMI approval 11/26/2013 (AR # 3115)
· SOB 6/18/2014 for AOC L (AR#3185); Bureau of Water Consent Agreement CA08-084-W was terminated (~May 2014) to pursue RCRA corrective action per the CMI workplan. RCRA permit requirement is to submit a SOB incorporating cleanup goals and approved corrective action.
Current RCRA Permit Table A-7 mentions that AOC H includes areas and contamination associated with AOC L, but doesn't specifically mention the CMI workplan or the SOB as a corrective action document. The 11/26/2014 RCRA Permit mod (AR #3248) mentions the 6/18/2014 SOB as the corrective action document for AOC L.
Shaw AFB SWMU 87 (ST018) SWMU 87/ST018 ozone system - shutdown in October 2022 due to limited effectiveness and to allow for remedial injections, the most recent injections took place in August 2025, and effectiveness is currently being evaluated Documents not in the Administrative Record being provided as GFI Listing current as of 28 January 2025; Draft documents and any review comments (AF or regulator) will be provided if the document is not finalized and entered into the Administrative Record.
Document(s) in SCDES Review (See spreadsheet titled “PWS Enclsoure 2B Base Documents List”:
· 3rd Qtr ’25 Site Rehabilitation Monitoring Report; submitted to SC DES UST 31-Dec-‘25 Documents in Review by Air Force (AF):
· Injection Completion Report review completed 06-Jan-’26 (potential 1903 documentation issue)
· Vapor Intrusion Investigation Technical Memorandum for sites SWMU 87, AOC M, AOC D, SWMU 96, SWMU 98, SWMU 99; Review comments sent to contractor (5/19/2025).
ORC Contractor Addressing SC DES Comments
· None ORC Contractor Addressing AF Review Comments
· None Documents in Preparation for AF Submittal
· 4th Qtr ’25 Site Rehabilitation Monitoring Report (UST, not a “courtesy” submittal
· Q1 2026 Site Rehabilitation Monitoring Report
· Q2 2026 Site Rehabilitation Monitoring Report
· Q3 2026 Site Rehabilitation Monitoring Report
Shaw AFB AOC M (ST030) AOC M/ST030 ozone system- shutdown in October 2020 due to limited effectiveness and to allow for remedial injections, the most recent injections were completed in August 2022 and were successful at reducing COCs at targeted wells, additional injections are being planned for the remaining well with COCs greater than the RGs Documents not in the Administrative Record being provided as GFI Listing current as of 28 January 2025; Draft documents and any review comments (AF or regulator) will be provided if the document is not finalized and entered into the Administrative Record.
Document(s) in Air Force (AF) Review (See spreadsheet titled “PWS Enclsoure 2B Base Documents List”:
· Draft 2025 CMIPR Rev 01 and RTCs- AF reviewed and confirmed RTCs acceptable (1/5/2026).
· Vapor Intrusion Investigation Technical Memorandum for sites SWMU 87, AOC M, AOC D, SWMU 96, SWMU 98, SWMU 99; Review comments sent to contractor (5/19/2025). Received 23 Jan 2026
Document(s) in SCDES Review:
· None ORC Contractor addressing SCDES Review comments:
· Draft Final 2024 CMIPR Replacement Pages and SCDES RTCs – Updates- SCDES review comments sent to contractor 12/19/2025 (copy of document and any comments to be provided); currently drafting response comments to regulator (will be provided)
· UIC Permit Application Rev 01 and RTCs- SCDES review comments sent to contractor 12/30/2025 (copy of document and any comments to be provided); currently drafting response comments to regulator (will be provided); Please note: AF received UIC Permits to Construct and Operate on 20 Jan 2026
Documents in Preparation for submittal to AF:
· Draft AOC M 2026 CMIPR
Potential issues with SCDES:
AOC M established Naphthalene remedial goal:
· SCDES current position is that the 25 μg/L is not an appropriate cleanup value.
Documentation demonstrating SCDHEC’s prior approval of the 25 μg/L Risk-Based Screening Level (RBSL) for Naphthalene as a cleanup goal for AOC M:
· The Corrective Measures Study (CMS) dated August 14, 2013 (AR# 3032) explicitly identifies 25 μg/L as the RBSL for Naphthalene and incorporates it as a cleanup goal. The CMS also establishes Corrective Action Objectives (CAOs) which specifically include reducing Naphthalene concentrations in groundwater to below the RBSL.
· SCDHEC formally approved the CMS on August 2, 2013 (AR# 3037), as noted in the RCRA Permit. This approval demonstrates regulatory acceptance of the proposed remedial goals, including the RBSL for Naphthalene.
· The Statement of Basis for AOC M (AR# 3033) submitted to SCDHEC reiterates the cleanup objective to “reduce concentrations of Naphthalene in groundwater to less than the RBSL of 25 μg/L”.
· At the time the cleanup goals were established, the UST RBSL was the only available cleanup value for Naphthalene across all SCDHEC programs and thus was adopted as an Applicable or Relevant and Appropriate Requirement (ARAR). Given these documents and the fact that the RCRA Permit reflects the CMS as the basis for corrective action, we believe this provides clear evidence of the previously approved use of the 25 μg/L RBSL for Naphthalene.
· SCDES’s position - that “RBSLs are not appropriate to use as cleanup values” - is difficult to reconcile with the continued acceptance and application of the same RBSLs by the SCDES UST Program. The UST Program still utilizes the Naphthalene RBSL of 25 μg/L as a valid and protective cleanup goal, which strongly supports its appropriateness and protectiveness under other regulatory programs. This inconsistency raises concern regarding the equitable and technically consistent application of cleanup standards across SCDES programs.
Shaw AFB Groundwater Treatment Plant 1 (GWTP1) - AOC F, H, N & SWMU 2 Note: GWTP-1 provides hydraulic control for AOC F, H, N & SWMU 2. This information only covers the operation, monitoring and maintenance of GWTP-1. Specific Site information is provided on their respective GFI.
Background Current Sampling Requirements (Refer to Table 1 in the PWS): Bi-Monthly (2X/month): four (4) sampling locations for PFAS; Two (2) sampling locations for VOCs; one (1) sampling location for NPDES Discharge 02A1
Current reporting requirements (Refer to Table 1 in the PWS): Monthly for UIC (PFAS & VOCs), DMR for 02A1 Quarterly for AOC F, H, N & SWMU 2, GWTP-1 Hydraulic Control
Documents not in the Administrative Record being provided as GFI (See spreadsheet titled PWS Enclsoure 2B Base Documents List) Listing current as of 28 January 2025; Draft documents and any review comments (AF or regulator) will be provided if the document is not finalized and entered into the Administrative Record.
Document(s) in SCDES Review:
· Notice of Proper Storage of Resin Material - 3rd Quarter 2025; submitted 11/20/2025; should be resolved ASAP Documents in Review by Air Force (AF):
· None ORC Contractor Addressing SC DES Comments
· None ORC Contractor Addressing AF Review Comments
· None Documents in Preparation for AF Submittal
· Quarterly & Monthly submittals Potential issues with SCDES:
· Sampling and reporting for the new NPDES Discharge permit
· Reduction of sampling frequencies
Shaw AFB GWTP2 - SWMU 54, 55 & 59 Note: GWTP-2 provides hydraulic control and cleanup for the three (3) former fire training areas: SWMU 54 (FT-003), SWMU 55 (FT-002), and SWMU 59 (FT-001). This GFI information only covers the operation, monitoring and maintenance of GWTP-2. Specific Site information is provided on their respective GFI.
Background Current Sampling Requirements: Bi-Monthly (2X/month): Six (6) sampling locations for PFAS & VOCs
Current reporting requirements: Monthly
Documents not in the Administrative Record being provided as GFI Listing current as of 28 January 2025; Draft documents and any review comments (AF or regulator) will be provided if the document is not finalized and entered into the Administrative Record.
Document(s) in SCDES Review (See spreadsheet titled “PWS Enclsoure 2B Base Documents List”:
· GWTP-2 UFP-QAPP; submitted 8/14/2025
· GWTP-2 Analytical Program Recommendations; submitted 12/19/2025 Documents in Review by Air Force (AF):
· November ’25 Monthly Status Report ORC Contractor Addressing SC DES Comments
· None ORC Contractor Addressing AF Review Comments
· None 2026 Planned Submittals
· Monthly submittals
· SCDES RTCs to UFP-QAPP
· SCDES RTCs to Analytical Program Recommendations Documents in Preparation for AF Submittal
· None Potential issues with SCDES:
SCDES acceptance of reduced sampling analytes (Analytical Program Recommendations)
Shaw AFB Miscellaneous GFI: Please note the new Well Installation and Abandonment Plan Well Installation and Abandonment Compliance Plan Dec 2025 – AR#4390; The plan is to be used by Shaw contractors to ensure well installation and abandonment is completed in accordance with the project Work Plan, Well Application Document, Well Application Approval Letter, R.61-71 of the S.C. Well Standards, and Title 40-Professions and Occupations, Chapter 23 Labor, Licensing and Regulation (LLR). The fields in this document should be completed and maintained at the site throughout drilling and the completed form should be included with the 1903 submittal.
Documents not in the Administrative Record being provided as GFI Listing current as of 28 January 2026; Draft documents and any review comments (AF or regulator) will be provided if the document is not finalized and entered into the Administrative Record.
Other Document(s) in SCDES Review (See spreadsheet titled “PWS Enclsoure 2B Base Documents List”:
· 2024 Groundwater Monitoring Well Repair Technical Memorandum SCDES RTCs and Change Pages; submitted 7/14/2025; should be resolved ASAP
· NPDES Application HQ2-2JPY-A4XV6 requesting the discharge treated water under two different flow scenarios from the GWTP#1 that contains IDW to the NPDES outfall. Currently only allowed to send treated water containing IDW to the injection wells; submitted to SC DES Bureau of Water March 2024; All required calculations and forms have been submitted via SCDES E-Permitting Online Platform, currently waiting on new SCDES PM to review package and provide approval.
Documents in Review by Air Force (AF):
· None ORC Contractor Addressing SC DES Comments
· None ORC Contractor Addressing AF Review Comments
· None Documents in Preparation for AF Submittal
· None
· None
Shaw AFB SWMU 98 (Bldg 1200) – DLA Funded Site Air Injection System - shut down in October 2024 due to limited effectiveness, post-shutdown monitoring in progress Documents not in the Administrative Record being provided as GFI (See spreadsheet titled “PWS Enclsoure 2B Base Documents List”) Listing current as of 28 January 2025; Draft documents and any review comments (AF or regulator) will be provided if the document is not finalized and entered into the Administrative Record.
Document(s) in SCDES Review:
· Draft Final SWMU 98 2024 CMIPR; submitted 3/24/2025
· Draft Final SWMU 98 2024 Semi-Annual PM Report; 7/11/2025 (copy of document to be provided) Documents in Review by Air Force (AF):
· Draft SWMU 98 2025 CMIPR; AF provided comments 1/12/2026
· Vapor Intrusion Investigation Technical Memorandum for sites SWMU 87, AOC M, AOC D, SWMU 96, SWMU 98, SWMU 99; Review comments sent to contractor (5/19/2025). Received 23 Jan 2026 ORC Contractor addressing SCDES Review comments:
· None ORC Contractor Addressing AF Comments:
· None Document(s) in Preparation for submittal to AF:
· Draft SWMU 98 2026 CMIPR Potential issues with SCDES:
Naphthalene Remedial Goal-
· SCDES does not agree with 25 μg/L as the remedial goal even though it was approved in the decision document for the site
· CMS (12/21/2016) identifies 25 μg/L as remedial goal for naphthalene (AR #3631)
· Regulatory approval of CMS- Jan 10, 2017 (AR#3642)
· SOB submitted with 25 μg/L as remedial goal 2/7/2017 (AR #3657)
· SOB approval 3/24/2017 (AR#3698)
· RCRA Permit (AR# 3942) Table A-7 reflects CMS (12/21/2016) as approved corrective action document
Shaw AFB SWMU 99 (Bldg 1610/1612) – DLA Funded Site Air Injection System - shut down in October 2024 due to limited effectiveness, post-shutdown monitoring in progress Documents not in the Administrative Record being provided as GFI Listing current as of 28 January 2025; Draft documents and any review comments (AF or regulator) will be provided if the document is not finalized and entered into the Administrative Record.
Document(s) in SCDES Review (See spreadsheet titled “PWS Enclsoure 2B Base Documents List”:
· Draft Final SWMU 99 2023 CMIPR; submitted 3/24/2025
· Draft Final SWMU 99 2024 Semi-Annual PM Report; 7/11/2025
Documents in Air Force (AF) Review:
· Draft SWMU 99 2024 CMIPR; received 14 Jan 2026
· Vapor Intrusion Investigation Technical Memorandum for sites SWMU 87, AOC M, AOC D, SWMU 96, SWMU 98, SWMU 99; Review comments sent to contractor (5/19/2025). Received 23 Jan 2026
ORC Contractor addressing SCDES Review comments:
· None ORC Contractor Addressing AF Comments:
· None Documents in Preparation for submittal to AF:
· Draft SWMU 99 2025 CMIPR Potential issues with SCDES:
Naphthalene Remedial Goal-
· SCDES does not agree with 25 μg/L as the remedial goal even though it was approved in the decision document for the site
· CMS (12/21/2016) identifies 25 μg/L as remedial goal for naphthalene (AR #3630)
· Regulatory approval of CMS- Jan 10, 2017 (AR#3641)
· SOB submitted with 25 μg/L as remedial goal 2/7/2017 (AR #3658)
· SOB approval 3/24/2017 (AR#3698) RCRA Permit (AR# 3942) Table A-7 reflects CMS (12/21/2016) as approved corrective action document.
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