REMOVAL SITE INSPECTION

WELCH GROUP ENVIRONMENTAL (WGE), Belton Site

ANDERSON, ANDERSON County, SOUTH Carolina

1.0     INTRODUCTION

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).

2.0     SITE BACKGROUND

This section discusses the site characteristics, previous investigations, and environmental setting of the area.

2.1         SITE DESCRIPTION

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).

2.2         PREVIOUS INVESTIGATIONS

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.

3.0     FIELD INVESTIGATION ACTIVITIES

 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.

3.1         SURFACE SOIL SCREENING AND SAMPLING

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.

3.2         OSC REQUIRED EMERGENCY RESPONSE (ER) ACTIONS

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.

3.3         XRF SCREENING OF THE WAREHOUSE AREA

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.     

3.4         SITE SECURITY AND MISCELLANEOUS ITEMS

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.

4.0      QUALITY ASSURANCE/QUALITY CONTROL

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.