Overview

The CSXT Bramlett Road Site (Site) is in Greenville, South Carolina, and is defined by five parcels and a portion of the Legacy Early College Elementary School (LECE) property that total approximately 35 acres. The Site consists of a former Duke Power Manufactured Gas Plant (MGP) and a 7-acre unpermitted construction and debris landfill (a/k/a Vaughn Landfill) downgradient of the former MGP site. The current owner of all but the LECE property is CSX Transportation, Inc (CSXT).  

Site History

Southern Public Utilities built the MGP on East Bramlett Road in 1917. Duke Energy assumed ownership of the MGP in 1939 but then sold it to Piedmont Natural Gas in 1951. Between 1963 and 1967, ownership of Parcels 1-5 were transferred to Seaboard Coast Line Railroad, a predecessor of CSXT.  

Gas was manufactured at the Bramlett MGP from 1917 to 1952 and produced a total of 5.5 billion cubic feet of gas. Coal tar was a byproduct waste stream of the MGP process. Coal tar moved through historic ditch channels from the MGP to a wetland area across Bramlett Road. Volatile organic compounds (VOCs) and semi-volatile organic compounds (SVOCs) associated with coal tar are the main constituents of concern (COCs).  

Beginning in 1988, Vaughn Construction created an unpermitted construction and demolition (C&D) landfill and spread waste (including concrete, brick, wood, plastic, roofing materials, insulation, and glass) up to 10 feet deep over 6.3 acres on Parcel 3. It is estimated that around 84,000 cubic yards of C&D debris exist within the Vaughn Landfill. In 1993, the South Carolina Department of Health and Environmental Control (DHEC) advised Vaughn Construction that landfilling activities were improper. In 1994, the US Army Corps of Engineers (USACE) notified CSXT that the landfill was located on a wetlands area and CSXT ordered Vaughn Construction to cease operation and close the unpermitted landfill. Vaughn Construction did not remove the C&D debris or remediate any environmental impacts.

Remedial Investigation Timeline

Duke implemented an interim removal action in 2001, focusing on the 3.8 acres where the MGP plant operated (Parcel 1). 61,000 tons of contaminated soil and debris were excavated, screened, and shipped off-site for treatment and/or disposal. 34,000 tons of this contaminated soil was sent for thermal treatment and returned to the site to use as clean backfill.  

Duke Energy entered into a Voluntary Cleanup Contract with DHEC in 2016 to determine the extent of coal tar impact remaining and evaluate remedial alternatives. The 2020 Remedial Investigation Report (RIR) and the 2021 Remedial Investigation Report Addendum (RIR-A) provided data which expanded the site characterization and focused on several important elements, including the location of the historic drainage ditch system and the extent and distribution of non-aqueous phase liquid (NAPL) impacts. NAPLs are organic liquid contaminants like coal tar and chlorinated solvents that do not mix with water. The extent of MGP-related residual contamination in sediment, soil, and groundwater was not known at the time of the original removal action. 

Data collected as part of the RIR-A included polycyclic aromatic hydrocarbon (PAH) forensics analysis.  The forensic analysis found that MGP-related impacts were observed in some on-site sediments in ditch assessment samples from Parcels 3, 4, and 5; concentrations in ditches upgradient of the site were consistent with background concentrations attributable to urban runoff; and PAHs detected in the Reedy River and off-site sediment samples can be attributed to urban runoff unrelated to the former MGP.  

In 2021, DHEC addressed concerns about possible MGP-related contamination in the community near Mountain View Baptist Church by sampling various properties in that area. The results indicated there had not been any impact from the MGP on surface soils.

In 2021, Best Management Practices (BMP) were implemented to reduce the potential migration of coal tar residuals, biofilm, and sediment. A turbidity curtain was installed along the bank of the Parcel 3 incised ditch. Two rock check dams were installed within the primary ditch on Parcel 5. This work involved the removal of approximately 62 tons of impacted sediment material which was properly disposed of at an offsite facility.  

Additionally, concrete cloth was used to replace rip rap in the ditch south of the Transflo property and north of Willard Street.  Approximately 257 tons of existing rip rap within the ditch and an approximate 1-foot lift of sediment from the base were removed and properly disposed of.  The existing culvert pipe was extended approximately 8 feet with an additional 30-inch diameter reinforced concrete pipe to prepare the slope face.  Concrete cloth was installed across an approximately 35’ by 85’ area.

Duke Energy submitted a Feasibility Study Work Plan in August 2022. The Feasibility Study Work Plan was approved in November 2022.  A Focused Feasibility Study (Rev. 1) was submitted to DHEC in October 2023. The Focused Feasibility Study was approved in February 2024. DHEC presented the Proposed Plan in May 2024. The Proposed Plan split the Site up into Operable Units 1, 2, and 3. Operable Unit 1 consisted of soil and sediment. Operable Unit 2 consisted of surface water and shallow zone groundwater. Operable Unit 3 consisted of transition zone groundwater and the deeper, fractured bedrock groundwater. The Proposed Plan presented the preferred alternative for Operable Units 1 and 2. An additional Proposed Plan will look at alternatives for Operable Unit 3 after the completion of the Operable Units 1 and 2 Remedy and a sufficient amount of time to monitor changes to the Site.

On June 6, 2024, a Proposed Plan public meeting was held at the Mountain View Baptist Church. DHEC representatives presented the results of recent investigation work, explained the remedial alternatives evaluated in the Focused Feasibility Study, and presented DHEC’s preferred alternative for the Site. The meeting initiated the official public comment period, which concluded on August 6, 2024. The public submitted extensive comments during the comment period and posed numerous questions during the public meeting.

DHEC became the South Carolina Department of Environmental Services (SCDES) on July 1, 2024.  SCDES reviewed and responded to each comment received and made significant changes to the preferred alternative based on feedback from the public. One of those changes was to move shallow zone groundwater into Operable Unit 3. On May 1, 2025, the Record of Decision (ROD) was executed by SCDES.  

Description of the Selected Remedy

SCDES has selected Excavation and Removal of the Vaughn Landfill, Monitoring, and Land Use Controls (LUCs) as the remedy for Operable Units 1 and 2. 

This remedy includes the excavation of the entire Vaughn Landfill; excavation of the impacted sediments on Parcels 3, 4, 5, and the LECE School property; monitoring of groundwater; and implementation of LUCs for long-term effectiveness. Additionally, a small area of impacted soil on Parcel 2 will be removed.

On Parcel 3, the remedy will include the excavation of the non-aqueous phase liquid (NAPL) and the entire Vaughn Construction and Demolition (C&D) Landfill (Vaughn Landfill). The areal extent of excavation includes the impacted wetlands areas, the areas underlain by NAPL, and the Vaughn Landfill.  The excavations will be backfilled with clean soil and sediment and wetland vegetation will be restored. During restoration, the Vaughn Landfill footprint will be backfilled to match the existing contours of the surrounding wetlands. Best Management Practices (e.g. silt fences, sediment tubes, rock ditch check dams, and turbidity curtains) will be utilized to prevent sediment from migrating off-Site during construction.  

The total areal extent of the excavation for Parcels 4 and 5 encompasses 0.44 acres. The depth of sediment excavation will be based on the results of sampling collected during the Remedial Investigation and by visual observation. Best Management Practices (e.g., silt fences, sediment tubes, rock ditch check dams, and turbidity curtains) will be placed to prevent sediment from migrating off-Site during construction.  

On the LECE School Property, the excavation will remove sediments within the wetlands and uplands that are visibly stained with NAPL. This will include a portion of the turnaround and parking area to a depth of up to 16 feet. To excavate to this depth, it is expected that a 1000-foot long temporary, sheet pile wall will be installed to an estimated depth of 25 feet. The total excavation is approximately 1.02 acres with an estimated volume of 26,400 cubic yards. Excavation will require the implementation of an Air, Noise, and Fugitive Emissions Monitoring and Mitigation Plan. Additionally, the use of a temporary sprung structure, if needed, will be used over the excavation area to further reduce potential impacts during the excavation. Dewatering and surface water management will likely be required during the excavation. The excavation will be backfilled with clean soil to match the existing elevations and restored to its preconstruction condition.  

With the footprint of the Vaughn Landfill being returned to wetlands, the monitoring well network will need to be focused on the Site periphery. Following the removal of NAPL-impacted soil and sediments, shallow and transition zone groundwater quality will be monitored. LUCs will be required to prevent or limit the use of groundwater until the groundwater reaches remedial goals and to maintain current property zoning.  

The estimated volume of excavated material for the remedy is 183,800 cubic yards. Excavation, transportation, and disposal have been successfully implemented to remediate other manufactured gas plant (MGP) sites. There are many qualified contractors capable of performing the work. Some specialized equipment for working in the wetlands, the installation of sheet piling, dewatering operations, and treatment systems will be required.  

The schedule assumes that approximately 8 months of each year will be available for remedy implementation due to seasonal weather and flooding conditions. The full implementation timeframe is estimated at 6 to 7 years. The estimated cost to implement the remedy, including 30 years of operation and maintenance, is $39,500,000.

Consent Agreements

SCDES began negotiating with responsible parties to conduct the remedial alternative shortly after the Record of Decision was executed. Through negotiations it became apparent that working on completing the remedial alternative through a series of consent agreements between SCDES and Duke Energy Carolinas, LLC would be the best approach. The first consent agreement would cover the small excavation on Parcel 2 which will allow Parcels 1 and 2 to be available for residential development with restrictions on groundwater. Consent Agreement 26-09-HW was signed by Duke Energy Carolinas, LLC on May 5, 2026. The consent agreement went through a public comment period through June 22, 2026, and was executed on July 7, 2026.  

Historical Documents

Below are historical documents relating to the previous investigations of the Site. These documents include work plans, investigation activities, remedial action plans, and other key documents. If you are interested in documents that appear on the Index but are not listed below, please contact the Department.

Mailing List

Anyone interested in receiving updates may contact Elisa Vincent at 803-898-0840 or via email Elisa.Vincent@des.sc.gov . If you have received information directly from DHEC, you are already on the Site's mailing list.