The Aluminum Finishing of SC Site (Site) is the location of a former aluminum anodizing and coloring facility. The site was owned and operated from approximately 1999-2004 by the Aluminum Finishing of South Carolina Corporation. The Site is no longer in operation. Based on a review of Barnwell County records, the site was sold in a tax sale on November 7, 2005. At that time, the property was titled to REOCO, LLC of Jupiter Lakes, Florida. (Ref 1)
The Site is located at 566 Fuldner Road, Barnwell, South Carolina. Recent inquiries have indicated that Fuldner Road has been renamed as Joey Zorn Boulevard, however, Barnwell County documents continue to list the address as Fuldner Road. The property is approximately thirteen acres and is located in an industrial park adjacent to the Barnwell County airport. There is one-story steel frame structure on the Site, which housed the aluminium finishing operation. There is a stormwater retention pond on the southeast side of the property and a small paved parking lot located on the northeast corner. Water supply to the Site is provided by the Barnwell County public water system. The Barnwell County Sheriff's office is located directly across from the Site.
On June 28, 2006, representatives of the South Carolina Department of Health and Environmental Control (DHEC) conducted an inspection of the Site to determine compliance with the South Carolina Hazardous Waste Management Regulations (SCHWMR), 25 S.C. Code Ann. Regs. 61-79 (Supp. 2005), promulgated pusuant to the South Carolina Hazardous Waste Management Act, S.C. Code Ann. Section 44-56-30 (Rev. 2002). During the inspection, DHEC documented violations of the SCHWMR. DHEC noted that Aluminum Finishing of SC failed to submit a form DHEC-2701, First Notification of regulated waste facility activity and failed to obtain an EPA ID number. DHEC noted the following containers located outside the vacant building: two abandoned tanks, several empty totes and some containing chemicals, several 55-gallon drums of dye, several 55-gallon drums of various chemicals and one poly tank containing an unknown liquid. DHEC also noted spillage on the ground from one of the totes, which was labeled as containing Sodium Nitrate / Potassium Floride.
On August 9, 2006, DHEC conducted a follow up visit to the Site. The inspection noted the following within the unsecured vacant building: two acid tanks containing various chemicals, several totes containing various acids and solutions, several baths containing anodizing solutions, one caustic tank and one unknown tank. DHEC futher concluded that Aluminum Finishing of SC had stored hazardous waste for greater than 90 days. On October 10, 2006 DHEC issued a Notice of Alleged Violation / Notice of Enforcement Conference to Aluminum Finishing of South Carolina. (Ref 2).
In January 2007, REOCO, LLC initiated a Phase I Environmental Site Assessment (ESA) at the Site. The Phase I ESA was completed between February 15 and April 10, 2007. The Phase I included a review of historical records, a site inspection and sampling and analysis of some of the waste streams at the Site. The Phase I report identified numerous tanks and containers both inside and outside the building on the Site. (Ref 3). The following were documented in the Phase I ESA report:
- Fifteen fiberglass vats, ranging in size from 5,000 to 6,000 gallons located inside the building. Vats contain liquid, sludge and/or precipitate;
- At least three isolated containment units beneath the open vats, which contain liquid, sludge and/or precipitate;
- Two above ground tanks inside the building which contain a slightly caustic solution;
- One above ground stainless steel tank which has a corroded foundation and is leaning agains the east wall of the building;
- Several plastic totes and 55-gallon drums of new and spent acids, caustics and additives inside the building;
- Numerous containers of laboratory chemicals, paints and other hazardous materials near the electrical room;
- Several plastic totes, drums and containers located outside on the west side of the building. At least three fiberglass above ground storage tanks located outside. Containers are labled as new/spent acids, caustics and additives.
During the Phase I ESA, several samples were collected from the vats inside the building at the Site. The samples were submitted to a laboratory for analysis (Ref. 4). All of the samples collected showed evidence of low and high pH materials. Two samples had pH levels which demonstrated the characteristics of a hazardous waste (pH of 1.86 std. Units and 12.74 std. Units)
On May 30, 2007 OSCs Misenheimer and Hughes visited the Aluminum Finishing of South Carolina Site. The purpose of the site visit was to conduct a Removal Site Evaluation (RSE). The OSCs arrived on site at approximately 1145 hours and met with representatives of the South Carolina Department of Health and Environmental Control (DHEC). EPA and DHEC conducted a site assessment and noted the presence of numerous 55-gallon polyethylene drums as well as several plastic tote containers located along the west side of the building. The drums were located outside in an unsecured area. The OSC observed 25 drums which appeared to be full, 12 drums that were partially full and ten tote containers which contained some material. Some of the drums were stacked on wooden pallets which were rotting. In addition, at least two drums had fallen from the pallets, ruptured and were spilling there contents onto the ground. Two of the drums were observed to be leaking a liquid. Field hazard categorization tests on the spilled material indicated a pH of one (1), which classifies the material as a hazardous waste. In addition, there were labels on some of the containers (“sulfuric acid”, “oxidizer”, and “ammonium hydroxide”). Material had been released from several of the containers, and other containers posed a serious threat of release. EPA and DHEC also inspected the interior of the on site building and confirmed the previous findings of the Phase I ESA. Based on these observations the OSC determined that the Site posed an immediate threat to human health and the environment. The OSC initiated an emergency removal action to mitigate the leaking drums and to stabilize the potential releases from the Site.
At approximately 1230, OSC Misenheimer contacted the site owner (Mr. Matt Marini, REOCO, LLC) to brief him on the need to conduct an immediate removal action at the Site. Mr. Marini provided verbal concurrence with EPA's decision to conduct the emergency response. The OSC then contacted WRS Infrastructure and Environment, Inc., one of the Region 4 Emergency and Rapid Response Services (ERRS) contractors, and requested that personnel and equipment be mobilized to the Aluminum Finishing of SC Site. A National Response Center (NRC) report was filed to document the site conditions (NRC 836997).
At 0730 on May 31, 2007, EPA and ERRS contractor WRS arrived at the Site. A representative from DHEC was also on site. EPA and ERRS discussed health and safety issues at the Site. ERRS worked throughout the day to accomplish the following tasks to stabilize the Site:
- Overpacked two leaking drums with pH 1;
- Moved and secured 25 full drums into the building;
- Moved and secured 13 partially full drums into the building;
- Moved and secured 10 partially full 250 gallon totes into the building;
- Moved 29 empty drums into the building;
- Collected samples from three drums and one above ground storage tank;
- Performed hazard catagorization field screening on the four samples. Results indicated three drum samples with pH < 2 and one tank sample with pH 12;
- Shipped four samples off site for laboratory analysis.
EPA OSCs conducted air monitoring around the containers and throughout the Site during the emergency response action. No elevated readings were detected on the PID, FID and 4-gas meter. In additon, a radiation survey was conducted and no readings were detected above background (12 uR/hr).
EPA and ERRS completed all emergency response actions and demobilized from the Site on the morning of June 1, 2007.
Additional removal activities are required at the Aluminum Finishing of SC Site to address concerns inside the building.
EPA and DHEC will discuss the required future actions at the Site and determine if Fund lead removal activities will be resumed.
References:
1. Tax Sale Deed, County of Barnwell, South Carolina. Book 765, Page 13. November 30, 2006
2. Notice of Alleged Violation / Notice of Enforcement Conference, SC DHEC. October 10, 2006
3. Phase I Environmental Assessment & All Appropriate Inquiries Report. Compliance Centre, April 10, 2007.
4. Analysis Report, Aluminum Finishing, Access Analytical Inc., March 23, 2007.
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