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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 #3 - Continuation of Action - Contractor Mobilization
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On-Scene Coordinator - Alyssa Hughes 4/22/2008
Time-Critical - Removal Action Pollution Report (POLREP) #3
Start Date: 2/4/2008
Pollution Report (POLREP) #3
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 March 24, 2008 members of Environmental Restoration LLC, one of the Region 4 Emergency and Rapid Response Services Contractors mobilized to the Aluminum Finishing Site of South Carolina.  Personnel include a response manager, a chemist serving as the transportation and disposal coordinator, a field clerk accountant, an equipment operator and two technicians.  Results from sampling and volume estimations conducted during the week of February 21 were compiled by the T and D Coordinator during the early weeks of March.  These results enabled the establishment of various waste streams and the procurement of disposal facilities.

Upon arrival at the Site, the first order of business was to eliminate slip, trip and fall hazards.  A 20 cubic yard roll-off box was delivered on March 25, 2008.  Numerous sections of PVC piping and other debris were placed in the roll-off box.  In addition 47 empty drums were cut and placed in the roll-off for disposal.  The roll-off box was filled with non-hazardous solid debris on March 27 and transported for disposal at the Subtitle D Three Rivers Landfill located in Aiken, South Carolina.

An air spurge system was initiated in vats 13, 14 and 15 using air lines that were already in place from plant operations.  This system will be used to mix liquids placed in these vats for neutralization processing.  These liquids, upon meeting established parameters set forth by the City of Barnwell Sewage Treatment Plant, will be discharged to the sewer system on-site.

Approximately 720 gallons from vat 3, 2160 gallons from vat 4 and 1035 gallons from tank 6 were loaded into a tanker truck and transported to Vickery Environmental located in Vickery, Ohio for hazardous waste disposal.  The waste, totaling 3917 gallons, was analyzed and identified as characteristic hazardous waste for exceeding the Toxic Characteristic Leaching Procedure (TCLP) for chromium and having a pH grater than 12.5.  This labels the wastewaters as high pH chromium liquids with waste codes D002 and D007.

The remaining sludges in tank 6 were solidified using oil dri and placed in the roll-off container for non-hazardous solids disposal.  

Liquids were pumped into the neutralization system beginning on Thursday, March 27.  The Chemist performed several bench scale studies with samples from the vats in order to determine the appropriate mix quantities.  These studies revealed which acids and caustics could be combined without generating an exceedance of total suspended solids.  An agreement between the City of Barnwell Sewage Treatment Plant and the United States Environmental Protection Agency was established in order to discharge liquids within the Effluent Discharge Limits (see documents list) directly to the sewer on-site.  Prior to discharge a sample will be collected and analyzed for pH and metals content.  A copy of the laboratory report and a letter stating the time of discharge and approximate volume will be generated and submitted to the Sewage Treatment Plant for their records.  Liquids from vat-1 (pH 11) were pumped into vats 13, 14 and 15 for neutralization treatment.  Approximately 18,000 gallons were successfully neutralized to a pH of 7.  A sample was collected and submitted to the laboratory for pH and metals analysis.  Once it is cleared to within the POTW parameters, it will be discharged to the sewer.

Three of the four tanks in the waste water treatment system area were cut opened on Friday March 28.  Tank 1 was approximately 1/3 full of sludges with a pH 12.  Tank 2 was approximately 1/3 full of pH 7 liquid.  Materials, including liquids and sludges, were pumped from the tanks into vat 4 for further treatment and disposal.  It is assumed to be water.  Remaining sludges in the bottom of the tanks were solidified and placed in a roll-off container for subtitle D landfill disposal.  PVC piping was also removed from this area and placed in the roll-off for disposal.  The tanks were then pressure washed and decontaminated.


Planned Removal Actions
All materials on-site will be transported and disposed of at various facilities meeting the CERCLA Off-Site Rule Requirement.  The following waste streams have been identified:

WASTE STREAM         QUANTITY DISPOSAL OPTION/TSDF
High pH, D002 and D007 1500 galls CWM- Vickery, OH
Low pH, D002 and D007 7800 galls CWM- Vickery, OH
Non-Haz Vat Liquids
  (pH 6-8.5)         20000 galls POTW- Barnwell, SC
Non-Haz Vat Liquids
  (untreatable)         25000 galls   Clean Management-Walterboro, SC
Non-Haz Solids         10 roll-offs  Three Rivers Landfill-Aiken, SC
Containerized Waste 2750 galls    Clean Management-Walterboro, SC

Once the disposal of all materials is complete, the facility will be decontaminated to the best possible state without removing any of the vats.  The vats and most of the air and water lines will be left in place.



Next Steps
The next steps are to continue with plans to dispose of materials left on-site.  The first batch discharge to the POTW will take place next week.  The second load of hazardous waste is scheduled for transportation on Tuesday, April 1.  The second roll-off pick-up for non-hazardous solids will take place next week.

Key Issues
OSC Hughes must confer with the State regarding the “clean closure” of the facility.  The time and effort that would be expended cutting and disposing of the vats may not be necessary due to the time that this facility was operational.  The containment areas below the vats will be pressure washed clean and the vats will be cut at the bottom to ensure no future use, but the material will remain on-site.

 
Disposition Of Wastes


Waste Stream Quantity Manifest # Disposal Facility
High pH Chromium Hazardous Waste Liquids 3917 gallons 002774793 Vickery Environmental Inc.
Vickery, Ohio
Non-Hazardous Solids Three Rivers Sub-title D Landfill
Aiken, SC