REMOVAL
SITE INSPECTION
WELCH GROUP ENVIRONMENTAL (wge), fAIRPLAY SITE
FAIR PLAY, OCONEE
County, SOUTH carolina
The
U.S. Environmental Protection Agency (EIPA) 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)
Fair Play Site, located in Fair Play, Oconee
County, South Carolina. The field activities include maintaining the
EPA OSC site webpage (Fair Play Site),
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-05-001-0126. 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:
·
Prepare
a Health and Safety Plan (START
HASP);
·
Prepare
a Quality Assurance Project Plan (QAPP)/Site
Sampling Plan (START
Sampling Plan) (SSP);
·
Screen
surface and subsurface soil for lead concentrations using a Niton®
X-Ray Fluorescence (XRF) elemental detector;
·
Submit a
limited number of soil samples to a laboratory for total lead analysis (Laboratory
Report);
·
Document
site activities with written logbook notes (START
Fieldnotes), digital photographs (Photolog)
and maintain the OSC webpage (Fair Play Site);
·
Prepare
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 Fair Play, Oconee
County, South Carolina. The geographic coordinates are 34º 31′ 23.96″
North latitude and 82º 59′ 28.82″ West longitude (Figure
1). The site is comprised of a one story house and a one story partially
enclosed brick building (smelting operation).
The property is located on a hillside that is owned by Mr. James
Feltman. The Feltman property is located
on a 22-acre parcel, and smelting operations were conducted on approximately 6 acres.
Topographically
upgradient of the smelting building there are equipment, scrap metal,
deteriorated cars, trucks, and tractors scattered on the property. Downgradient of the smelting building there
are several box trailers and multiple pallets of concrete blocks.
The site is
bordered by State Road South 37 to the north, to the east by Highway 59, agricultural
land to the west, and a wetland to the south (Figure
2). Topographically, the site drains generally to the northeast.
The
property is owned by Mr. Feltman and leased to Mr. Glenn
Welch of WGE. WGE
operations at this site involved the smelting and molding of lead recovered from
both indoor and outdoor shooting ranges across the United States.
The
South Carolina Department of Health and Environmental Control (SCDHEC)
conducted an initial site inspection on November 3, 2010. Details of the SCDHEC report can be found on
the OSC web page at the following link (SCDHEC
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 SCDHEC referral letter can be found on the OSC web page (SCDHEC
Referral).
On January 31, 2011, the EPA On-Scene Coordinator (OSC), SC DHEC, START, the
property owner (James Feltman), and WGE (Glenn Welch)
conducted a removal site inspection. According
to Mr. Welch, WGE has been operating at this location for approximately 14
months. After material separation at the
WGE Anderson facility, the WGE Fair Play facility was used for smelting and
molding of lead. The photographic log (Photolog)
and field logbook notes (START
Fieldnotes).
On February 1 and 3, 2011,
START performed a preliminary RSE that included surface 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.
START
collected a total of 75 discrete surface soil samples from 15 grids using
stainless steel spoons for screening using the XRF. These discrete soil samples were collected
topographically downgradient from the smelting building. Additionally, START collected a total of 140
discrete surface soil samples from 28 grids using stainless steel spoons for
screening using the XRF. These discrete
soil samples were collected topographically upgradient from the smelting
building. One sample of the surface
material was collected from the concrete floor of the smelting building.
In addition
to the samples collected for XRF screening, composite samples were collected of
the screened soils and submitted for laboratory analysis. These composite samples collected for
laboratory analysis were from the downgradient portion of the site. A total of 11 soil composite samples and one
duplicate were submitted to Gulf Coast Analytical Laboratories (GCAL) for
analysis of total lead in accordance with SW846 Method 6010C, and five soil
composite samples and one duplicate were submitted to GCAL for analysis of Target
Analyte List (TAL) Metals in accordance with SW846 Method 6010C/7471B. The sample of
the surface material that was collected from the concrete floor of the smelting
building was submitted for total lead and TAL metals analysis. The data gathered during the RSI 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) and (Table 1a) presents the GPS
coordinates for each sample location.
On February
1 and 3, 2011, START collected surface soil samples for screening
purposes. The site was subdivided into
50 foot (ft) x 50 ft sampling grids. 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 on (Table 1).
Additionally
on February 8, 2011, the EPA directed START to screen the surface soils
upgradient of the smelter building. START collected a total of 140 discrete
surface soil samples from 28 grids using stainless steel spoons for screening
using the XRF. The samples were only
collected for screening purposes. A
summary of the XRF soil screening results are presented on (Table 1a) and the screening results
for each sample location is found on (Figure 3).
On January 31, 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) Secure and/or overpack all
open containers with lead related material in the smelting building pending
disposal/recycling;
3) Secure site with security
tape until removal activities.
On February
1, 3, 8, and 9, 2011, the EPA OSC tasked START to screen the pallets of
concrete blocks, equipment, and used vehicles located at the site. On February 1 and 3, 2011, START screened the
pallets of concrete blocks that were located downgradient of the smelting
building. The results from the XRF
screening indicated approximately 45% of the items screened were impacted with
lead concentrations greater than the Region 4 RSL for residential soil of 400
ppm.
On February
3, 8, and 9, 2011, START screened the equipment and used vehicles upgradient of
the smelting building. The XRF results
indicated lead impacts, possibly from site operations, above the Region 4 RSL
for residential soil of 400 ppm. A summary
of the XRF readings and grid locations is presented in (Table 2). (Figure 4) shows the grid location and
associated XRF readings.
On February
17, 2011, the EPA OSC directed START to collect representative paint samples
from two old vehicles staged on the upgradient portion of the property in order
to gain a representation of the vehicles upgradient of the smelting
building. The samples were submitted to
GCAL for laboratory analysis of lead. A
summary of the analytical results is included on (Table 3). The laboratory report (Laboratory Report) can be viewed at the
following link.
A composite
sample from each of the 15 grids was submitted for laboratory analysis. The five discrete samples that were collected
and screened using the XRF from each of the 15 grids 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 Regional Screening Level (RSL) for residential soil of 400 milligrams per
kilogram (mg/kg). A summary of the
laboratory analytical results for each sample collected are found in (Table 3). (Figure 5) depicts the areas of lead
impacts to the surface soils.
During the
site inspection, 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) can be viewed at the following
link.
During the RSE,
drums of varying contents were observed on site. The EPA OSC instructed WGE to overpack
deteriorated drums. WGE was also told by
the EPA OSC that all drums shall be stored and secured in the former smelting
building for characterization and future disposal/recycling. There were a total
of 41 drums of contaminated material, and an additional 11 drums and 10 buckets
of unknown material for hazardous categorization, 2 steel boxes of lead material,
and 1 drum of trash (WGE
Progress Report).
On February 9, 2011, WGE obtained samples of
material from each of the 11 drums and 10 buckets for hazardous
characterization (HazCat) testing to determine material classification. The results of the HazCat performed by WGE
can be found at the following link (Fair
Play Site).
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 one duplicate (AA10-100) for total lead and one duplicate (AA9-101) for
TAL metals were submitted to GCAL for analysis.
The native sample (FP01-AA10) and its duplicate (AA10-100) had a high
percent difference between the two samples (67%) for lead. This difference can be attributed to the
heterogeneity of the soil. The native
sample (FP06-AA9) and its duplicate (AA9-101) had a high percent difference
between the two samples (90%) for copper (111%) and zinc (118%). This difference can be attributed to the
heterogeneity of the soil (Soil
Laboratory Report).
5.0
SITE INVESTIGATION RESULTS
The
following sections summarize the XRF and laboratory results for soil samples
collected during the RSE field sampling activities.
As
discussed, above START collected a total of 75 discrete surface soil samples
from 15 grids. XRF screening results
indicate concentrations of lead were detected in all 15 Grids located
downgradient of the smelting building. Additionally,
START collected a total of 140 discrete surface soil samples from 28 grids topographically
upgradient from the smelting building. The
screening results for each sample location are summarized in (Table
1) and (Table
1a) and are shown on (Figure
3).
11
composite samples from 11 grids were submitted for laboratory analysis. The laboratory data indicated that 10 grids
indicated soil lead concentrations results above the residential RSL of 400
mg/kg. Only one sample, Grid AE10,
indicated soil concentrations below the RSL (Soil
Laboratory Report).
Additionally,
START screened pallets of concrete blocks, equipment, and used vehicles located
at the site. Initial indications are that
items on site were impacted with lead, possibly from smelting operations. Results of the screening are presented on (Table
2). (Figure
4) shows the grid locations and associated XRF readings.
6.0
SUMMARY AND CONCLUSIONS
The
WGE Fair Play facility was used for smelting and molding of lead and other metals from spent munitions at firing ranges
gathered from around the Southeast. WGE
leases the property from Mr. James Feltman.
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
results, the warehouse was limited to activity.
Drums and over packed containers of exposed lead and materials that exists
on site were moved and secured in the former smelting building for further
disposal/recycling.
On February 17th, the EPA OSC requested that WGE prepare the
following plans for the WGE Fair Play 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 be based on the
approval of the workplans listed above 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.
