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Aluminum Finishing of South Carolina

All POLREP's for this site Aluminum Finishing of South Carolina
Barnwell, SC - EPA Region IV
POLREP #2 - Initiation of Removal Phase
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On-Scene Coordinator - Alyssa Hughes 2/11/2008
Time-Critical - Removal Action Pollution Report (POLREP) #2
Start Date: 2/4/2008
Pollution Report (POLREP) #2
Site Description
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 aluminum 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.

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 against 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 labeled as new/spent acids, caustics and additives.

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 categorization 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 addition, 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.


Current Activities
On February 5, 2008 the On-Scene Coordinator met on-Site with personnel from the Superfund Technical Assessment and Response Team (START) and Emergency and Rapid Response Services (ERRS) in order to fully characterize all containers on-Site.  Upon entry into the building ERRS personnel worked on lifting the bay doors in order to provide lighting while START personnel conducted air monitoring.  No levels above background were encountered while walking through the building.  All trip hazards were indicated with fluorescent orange spray paint.

James Burckhalter with South Carolina Department of Health  and Environmental Control (DHEC) met with OSC Hughes on-Site in order to review the plans for removal action and to observe ongoing sampling activities.

START members began by photographing and labeling every container with a unique identification number.  The team then collected samples from all of the vats and containment areas while dressed in Level C personal protective equipment (PPE).  Two members of the team then continued sampling of the drums and totes after upgrading to Level B PPE.  The third team member performed hazardous categorization of the samples collected.  A total of 12 vats, 60 drums and totes, 4 sumps (containment areas), and 2 tank hazcat analyses were performed.

Some of the materials identified on-Site through hazard categorization include sulfuric acid, hydrochloric acid and aqua ammonia.

The results of the hazcatting were compiled in an excel spreadsheet and submitted to the Transportation and Disposal (T & D) Coordinator for the ERRS contractor.  Upon review of the results, the T & D Coordinator composited like samples from the vats and shipped a representative sample per waste stream in order to obtain a laboratory analysis.  A total of eight samples were shipped for analytical sampling.  

During this reporting period the OSC met with representatives from the Barnwell City Sewage Treatment Plant in order to discuss the possibility of disposing of non hazardous waste via batch drop off at the Plant.  The director was amenable with the proposal as long as all discharged waste meets the discharge parameters.  The T & D Coordinator will evaluate alternatives for treating waste and disposing via the Sewage Treatment Plant in order to control disposal costs.


Planned Removal Actions
Once the analytical results are completed and waste streams are established, the OSC, START member and ERRS crew will mobilize to the Site.  An electrician will visit the Site in order to energize the appropriate fuses for overhead lighting.  An on-Site office will be established within the facility. The following activities will take place upon return to the Site:
- Debris, trash, piping and small empty containers will be compiled and stored in roll-off containers in order to diminish the trip hazards within the facility
- All empty containers will be staged in an area secluded from day to day operations
- All containers with contents will be color coded depending on waste stream
- Bulk all drum and tote liquids according to waste stream
- Rinse all containers and containerize rinse water for disposal
- Treat all material that is able to be treated for compliance with the Barnwell Country Sewage Treatment Plant Discharge Parameters
- Batch disposal of this material to the Sewage Treatment Plant
- Disposal of hazardous waste in drums, totes, tanks, vats and containment areas to be in compliance with the CERCLA off-Site Rule
- Disposal of non hazardous solid waste at subtitle D landfill
- Decontamination of containment areas and facility floor


Next Steps
An inventory of all containers including ID, photograph, hazardous categorization results and waste stream will be generated and posted in the documents section of this website.

Upon arrival of analytical results waste streams will be established and disposal facilities will be identified.


Key Issues
Since the initiation of the Emergency Response in May of 2007 REOCO, LLC has relinquished ownership of the title for this property.  As a result of this action, the removal phase has commenced.