REMOVAL
SITE INSPECTION
WELCH GROUP ENVIRONMENTAL (WGE), Belton Site
ANDERSON, ANDERSON
County, SOUTH Carolina
The
U.S. Environmental Protection Agency (EPA) tasked the Oneida Total Integrated
Enterprises (OTIE) Superfund Technical Assessment and Response Team (START) to
perform field activities in support of the On Scene Coordinator (OSC) for the U.S.
Environmental Protection Agency (EPA) at the Welch Group Environmental (WGE)
Belton Site, located in Anderson, Anderson County, South
Carolina. The
field activities include maintaining the EPA OSC site webpage, compiling site
history and maps and managing field data.
The site activities are conducted under Contract Number (No.)
EP-W-05-053 and Technical Direction Document (TDD) No. TNA-05-001-0127. The general purpose of the RSI is to collect
information to assist in determining whether Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) hazardous substances have
been released into the environment.
Specifically, findings will identify the need for federal intervention
under the CERCLA of 1980 and the Superfund Amendments and Reauthorization Act
(SARA) of 1986. In addition, the EPA OSC expanded the scope of
the above actions by directing the PRP to conduct an emergency response (Pol/SitRep#1). START expanded its role in support of this
additional action.
Specifically, START was
tasked with the following:
·
Preparing
a Health and Safety Plan (HASP);
·
Preparing
a Quality Assurance Project Plan (QAPP)/Site
Sampling Plan (SSP) (Soil
Sampling Plan);
·
Screening
surface and subsurface soil for lead concentrations using a Niton®
X-Ray Fluorescence (XRF) elemental detector;
·
Submitting
a limited number of soil samples to a non-Contract Laboratory Program (non-CLP)
laboratory for total lead analysis (Belton
Site Lab Report);
·
Documenting
site activities with written logbook notes (Field Notes)
and digital photographs (Photolog),
maintain the OSC webpage (OSC Webpage);
and,
·
Preparing
a comprehensive report summarizing the site conditions, field investigation
activities, and analytical results of the RSI.
This RSE Report summarizes the existing conditions at
the site; describes the field investigation activities conducted by START in
February 2011; and, delineates the limits, nature, and extent of soil
contamination at the site. All
activities and procedures described in this report were performed in accordance
with the EPA Region 4 Field Branches
Quality System and Technical Procedures (FBQSTP) (EPA Region 4 Technical Procedures).
This
section discusses the site characteristics, previous investigations, and environmental
setting of the area.
The
site is located in Anderson, Anderson County, South Carolina. The geographic coordinates are 34º 31′ 24.12″
North latitude and 82º 59′ 28.73″ West longitude (Figure
1). The site is comprised of two one-story buildings, and the
property extent is approximately 3 acres.
The site is bordered by Belton
Highway to the north, a cemetery to the east,
agricultural land to the south, and woods to the west (Figure
2). Topographically, the site drains generally to the southwest.
The
property is owned by Mr. David Jones and leased to Glenn
Welch (WGE). WGE
operations are involved in recovering lead from both indoor and outdoor
shooting ranges across the United
States (Access
Approval).
The
South Carolina Department of Health and Environmental Control (SC DHEC)
conducted an initial site inspection on November 3, 2010. Details of the SC DHEC report can be found on
the OSC web page at the following link (SC DHEC Memo).
The
site was referred to the EPA on December 22, 2010 by the South Carolina Bureau
of Land and Waste Management. Details of
the SC DHEC referral letter can be found on the OSC web page at the following
link (SC
DHEC Referral) .
On January 31, 2011, the EPA On-Scene Coordinator (OSC), SC DHEC, START, the
property owner (David Jones), and WGE (Glenn Welch)
conducted a removal site inspection. According
to Mr. Welch, WGE has been operating at this location for approximately 14
months. WGE used this location for material separation of recovered range
materials. After material separation,
the lead material was transported to the Fair Play, South Carolina location for smelting. The second warehouse building was used for
storage of unrecovered bullets that were still embedded into the rubber resin
bullet trap. The photographic log (Photolog)
and field logbook notes (Field Notes)
can be found at the above link.
On February 2 2011,
START performed a RSE that included soil screening, soil sampling, and analysis
activities at the site to identify the nature and extent of lead contamination
in on-site soils from site operations. START
utilized an XRF instrument to screen on-site soils for lead contamination to a
maximum depth of 6 inches below ground surface (bgs). The EPA OSC indicated that soil samples were
only to be collected from 0 to 6 inches bgs.
Surface soil grab samples (0 to 6 inches bgs) were collected and screened
using the XRF.
START
collected a total of 40 discrete surface soil samples from eight grids using
stainless steel spoons for screening using the XRF. In addition, composite samples of the screened
soils were submitted to Gulf Coast Analytical Laboratories (GCAL) for analysis
of total lead in accordance with SW846 Method 6010C and Target Analyte List (TAL)
Metals in accordance with SW846 Method 6010C/7471B. START collected a total of eight composite samples
and one duplicate composite sample for total lead and five composite samples
and one duplicate composite sample for TAL Metals. The data gathered during the RSE will be used
to determine the release or substantial threat of release of a CERCLA hazardous
substance.
Geographic positioning information was collected for all
sampling locations and was geographically referenced using ArcView and uploaded
to a hand-held Trimble® Global Positioning System (GPS). Table 1 provided in Appendix B
presents the GPS coordinates for each sample location.
On February
2, 2011, START collected surface soil samples for screening purposes. The site was subdivided into 50 foot (ft) x
50 ft sampling grids as shown in Figure 3, Appendix A. Based on the site topography and drainage
pattern, the EPA OSC directed START to grid areas along the drainage
patterns. Five-point discrete surface
soil samples (0 to 6 inches) were collected from each grid location and
screened using the XRF. Each sample was
collected using stainless steel spoons, placed in zip top bags, and screened
using the XRF. The lead results detected
on the XRF were compared to the Region 4 Regional Screening Level (RSL) for
residential soil of 400 parts per million (ppm). Screening results for each sample location
are found on Figure 3 and are summarized in Table 1.
The five
discrete samples from each of the eight grids sampled were homogenized in
stainless steel bowls, containerized, placed on ice, documented, and shipped
under standard chain-of-custody procedures to GCAL in Baton Rouge, Louisiana. The soil samples were compared to the Region 4
RSL for residential soil (400 ppm). A
summary of the laboratory analytical results for each sample collected are
found on Table 2. Figure 4 depicts the areas of lead
impacts to the surface soils.
On February 1, 2011, the EPA discussed with WGE the ER actions required
to the secure the site (WGE
Workplan). The EPA OSC directed WGE to immediately
complete the following site tasks (WGE
Progress Report):
1) Install silt fencing to
limit the further impact of potentially impacted surface water off-site;
2) Determine and secure drums
containing hardened salt;
3) Secure and/or all open
containers with lead related material in the warehouse pending
disposal/recycling;
4) Segregate empty drums, scrap
metal and trash in piles pending disposal/recycling.
On February
2, 2011, the EPA OSC tasked START to screen the floor of the warehouse and the
associated equipment. The lead results
detected on the XRF were compared to the Region 4 RSL for residential soil (400
ppm). The XRF results indicated the warehouse
floor and equipment had elevated lead readings.
A summary of the XRF readings is presented on Table 3. Figure 5 show the sampling location
and XRF readings.
During the
RSE, shell casings and bullet remains were discovered in the natural drainage
patterns at the site. As a result, the
EPA OSC instructed WGE to install silt fencing to limit the further impact of
potentially impacted surface water off-site. The photographic log Photolog shows where silt fencing
was installed around the site.
During the
RSE drums, steel containers, scrap metal, and trash were observed on site. The inventory of items at the back of the property
was as follows (WGE Progress Report):
1) Approximately 941 55-gallon steel drums of a
hardened salt (NuSal);
2) Approximately 66 drums of lead derived
material;
3) 21 metal
square containers (lead material);
4) One cardboard box (lead
material);
5)
23 blue drums with material;
6) 24 empty drums.
On November 3, 2010, SCDHEC submitted samples of the NuSal for
analysis. The samples were varying
shades of white, gray, or brown in color.
A summary of the laboratory data indicated the white/gray portion of
the sample was composed of potassium chloride and sodium chloride. The brown portion of the sample was a mixture
of five salts which included potassium chloride, sodium chloride, potassium
nitrate, sodium nitrate, and sodium nitrite. The complete laboratory analysis and the SCDHEC
report is located on the EPA OSC webpage at (SC DHEC Site Sampling
Report). This material
does not qualify as a CERCLA hazardous substance or pollutant/contaminant and
is not part of this enforcement action.
Nevertheless, SCDHEC expressed an interest in the PRP properly managing
this material and the issue was deferred to SCDHEC oversight.
QA/QC
data are necessary to determine precision and accuracy and to demonstrate the
absence of interferences and/or contamination of sampling equipment, glassware,
and reagents. This section describes the
QA/QC measures taken and provides an evaluation of the usability of data
presented in this report.
A
total of two duplicates (D5-100 and F3-101) for total lead were submitted to GCAL
for analysis. The native sample (A05-F3)
and its duplicate (F3-101) were within permissible limits of each other as
allowed by the National Functional Guidelines (NFG) for lead. However, the native sample (A02-D5) and its
duplicate (D5-100) had a high percent difference between the two samples (90%)
for lead. This difference can be
attributed to the heterogeneity of the soil.
5.0
SITE INVESTIGATION RESULTS
The
following sections summarize the XRF and laboratory results for soil samples
collected during the RSI field sampling activities. As discussed, 40 discrete surface soil
samples were collected from 8 grids. XRF
screening results indicate concentrations of lead above the Region 4 RSL were detected
in Grids D3, D4, D5, E3, E4, F3, and G3. The screening results for each sample location
are summarized in Table
1 and are shown on Figure
3.
Soil
samples from the 8 grids were homogenized and submitted for laboratory
analysis. The analytical data indicates soil
concentrations of lead were above the residential RSL of 400 mg/kg in the
samples collected from all 8 grids. Soil
concentrations ranged from 680 mg/kg in Grid G3 to 45,600 mg/kg in Grid
E3. A summary of the laboratory
analytical results for each sample collected are found on Table
2. Figure
4 depicts the areas of lead impacts to the surface soils. The laboratory analytical report can be
viewed at the following link (Laboratory
Report).
6.0
SUMMARY AND CONCLUSIONS
WGE
leases the property from Mr. David Jones and has been operating a business that recovers lead and other metals from spent
munitions at firing ranges gathered from around the Southeast. The WGE Anderson site conducted material
separation as well as distribution of recycled material.
WGE
was directed by the EPA OSC to submit workplans that were approved for securing
the facility. WGE
installed silt fencing to limit the amount of potentially impacted surface
water leaving the site. Based on the XRF
data collected by START during the RSE, the warehouse was limited to
activity. Drums and metal containers of exposed
lead material that existed on-site were moved and secured in the warehouse
for further disposal. The remaining drums in various conditions of deterioration were
secured on-site until further determination by the EPA OSC.
On February 17th, the EPA OSC requested that
WGE prepare the following plans for the WGE Anderson facility:
- Waste Characterization Plan (re. sampling) in order to gather the
necessary information for an eventual Disposal/Recycling Options
Analysis.
- Decontamination/Demolition Plan for
remaining debris and structures exceeding the lead cleanup criteria.
- Soils Removal and Disposal Plan for
soils exceeding the cleanup criteria.
Further activities associated with this site
will be determined by the EPA OSC. The
EPA OSC anticipates that the management of the site will transition into a time
critical removal action under an EPA Administrative Order on Consent.