March 9, 2011
Mr. Leo Francendese
On-Scene Coordinator (OSC)
U.S. Environmental Protection Agency
61 Forsyth Street, SW 11th Floor
Atlanta, Georgia 30303
Subject: Removal Site Inspection, Revision 0
Welch Group Environmental (WGE) Palmetto Parkway
Site
110
Palmetto Parkway, Belton, South Carolina
EPA Contract No. EP-W-05-053
Technical Direction Document (TDD) No. TNA-05-001-0129
Dear Mr. Francendese:
The
Oneida
Total Integrated Enterprises (OTIE) Superfund Technical Assessment and Response
Team (START) have prepared this Incident Response Letter Report detailing activities
conducted in support of the On Scene Coordinator (OSC) for the U.S.
Environmental Protection Agency (EPA).
The initial scope of this activity was to conduct field investigation activities
at the Welch Group Environmental (WGE) Palmetto Parkway site
(site) in support of a removal site inspection that was part of a Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) removal site evaluation (RSE). The OSC directed WGE to conduct an emergency
response action at the site thus expanding START’s support role. WGE is a metal recovery company that recovered
lead slugs and shell casings from gun/rifle ranges until it ceased operations
in December 2010 at the request of the South Carolina Department of Health and
Environmental Control (SCDHEC). The
site is part of WGE's operations and was serving as storage.
START was specifically
tasked to prepare a Health and Safety Plan; provide equipment including an
X-Ray Fluorescence (XRF) instrument, and personnel to conduct inspection and
support activities; document START and Responsible Party (RP)-lead response
action site activities with photographs and written logbook notes; maintain the
OSC webpage (EPAOSC Webpage) and prepare an Incident Response Letter Report summarizing the
inspection and emergency response action activities. Attachment A of this Letter Report includes a
topographical map (Figure
1), a site aerial photograph (Figure
2) and XRF screening location maps (Figure
3) and (Figure
4), respectively. The XRF decontamination test results are
presented in Table 1 provided in Attachment B (Pilot
Test Data). A photographic log of
site activities is provided as Attachment C (Photolog)
and a copy of the logbook notes are provided as Attachment D (EPA Field
Notes).
Physical Location
The
site is located at 110 Palmetto
Parkway in Belton, Anderson County, South Carolina. The geographic coordinates for the center of
the property are Latitude 34.5228881°
North and Longitude -82.4942948° West (Figure
1). The site is comprised of a one-story
warehouse building where WGE stored recovered lead slugs
and shell casings from gun/rifle ranges.
Several different clients lease space within the multi-use warehouse,
but the building is not partitioned into individual units. Residential properties are located to the
east, west, and south of the warehouse building. A large one-story warehouse building bounds the
site to the north. (Figure
2) located in Attachment A show the location of the site and the
surrounding areas.
Site Background
This site is part of the WGE
CERCLA response. SCDHEC notified EPA of
the site while EPA was conducting Removal Site Evaluations (RSE) at two other
WGE facilities located in Fair Play (Fair Play
Facility) and Belton (Belton Facility
Webpage), South Carolina. The WGE Palmetto Parkway
site was part of WGE's operations and served as warehouse storage.
On
February 7, 2011, EPA, START, property owner Cummings Gary, and site operator WGE
conducted a site walk. During the site walk, WGE
indicated that a box of range recovered material had overturned during cleanup
and a metal shovel was used to recover the spilled material (AccessAgreement). During recovery, the
metal shovel scraped against the residual gun powder (green powder) covered concrete
floor creating a spark. The ensuing fire partially damaged the building leaving
burnt insulation and roofing material.
Field Investigation Activities
and Results
During the February 7, 2011 site walk, the EPA OSC tasked START to
use an XRF to conduct in situ screening for metal concentrations at select
locations of the building. START screened
the floor and walls of areas where most site operation activities took place. WGE operations occupied approximately 4,000
square feet (ft2) of warehouse space. XRF readings for lead ranged from 408 parts
per million (ppm) on the warehouse floor to 35,000 ppm along the building walls. Figure 3, provided in Attachment A, shows the
building layout and the XRF lead readings (Figure
3).
Based on the XRF lead screening
results, the EPA OSC determined that a release or substantial threat of release
of a hazardous substance to the environment had occurred. The release exists at high concentrations at
or near the surface that present an imminent and substantial threat to
public or welfare (Pol/Sitrep
#1).
On February 10, 2011, a
Notice of Federal Interest (NOFI) was issued to the site owner, Mr. Cummings
Gary (NOFI). The OSC directed the site operator, WGE, to
remediate the contaminated section of the warehouse. WGE’s immediate goal was securing the
facility from other facility personnel.
RP-Lead RA Actions
On February 17, 2011, WGE
contractor was on site to cover the concrete flooring in designated areas with
an industrial paper until remediation activities could occur. Safety barricades were used to delineate the
exclusion zone (area where WGE stored the range recovered material) to prevent
non response-related personnel from entering.
WGE contractor submitted a Pilot Test Work Plan proposing
decontamination of approximately 1,400 ft2 of the warehouse floor to
determine contaminant reduction concentrations below the EPA regional screening
levels (RSL) of 400 ppm (Approved
Work Plan).
On February 21 and 22, 2011,
Phillips was on site to conduct the decontamination Pilot Test. Pilot testing was performed in a small area of
the warehouse floor near the loading docks.
Initial XRF readings for lead near the loading docks ranged from 1,399
to 1,570 ppm (Figure 3). The concrete
near the loading docks was smooth in some areas and pitted and showing signs of
deterioration in others. A detergent
solution and water was used to clean the small area. The area was then rinsed with minimal water, vacuumed,
and allowed to dry before confirmation screening using the XRF. A steel wire brush was used by WGE
contractors in several areas to determine its effectiveness. Table 1, provided in Attachment B, presents the
results of the February 21 and 22, 2011 Pilot Test XRF readings (Pilot
Test Data). Figure 4, provided in Attachment A, shows the
locations of the decontaminated areas (XRF
Readings).
On February 28, 2011 through
March 2, 2011, START observed WGE contractors continue with the decontamination
Pilot testing activities (Revised
RAWP). WGE contractors monitored air
particulates while cleaning activities were being conducted (Air
Monitoring Data). There were
sections of the warehouse pathway where concentrations were still above 400
ppm. WGE contractors used a tavasco
grinder on the floor and vacuumed dust with a high efficiency particulate air
vacuum. The areas of the previously
covered pathway were screened and readings were below 400 ppm.
Planned RP-Lead RA Activities
EPA tasked WGE with developing
a Work Plan for remediating the remaining surface areas of concern in the
warehouse while maintaining security to unqualified personnel for the area. WGE will submit the Work Plan to the EPA OSC
for approval and it will be incorporated into an upcoming time critical removal
action under an Administrative Order on Consent (AOC). Any further activities will be at the
direction of the EPA OSC.
If you have any questions or
comments regarding this letter report or require any additional information,
please contact myself or Mr. Russell Henderson,
START Assistant Program Manager, at 678-355-5550.
Sincerely,
Jerry Partap
START Project Manager
