The Site is bordered to the east by Highway 9 and undeveloped land. To the north, approximately 250 feet from the Site property and 850 feet from the actively burning fire, is a gas station and restaurant. To the west, the Site is bordered by undeveloped land but is only 650 feet from the Broad River, which serves as a recreational waterway and eventually contributes to the drinking water source for the City of Columbia, SC. Two small drainage creeks flow towards the Broad River along the north and south borders of the Site property.

The nearest residence in Lockhart, SC is located 1,650 feet from the Site. The town of Lockhart, with a population of approximately 500, is located on the west side of the Broad River with many residences within the narrow river valley and other residences on the bluff to the west.

On January 27, 2015, OSC Huyser and START mobilized to deploy four particulate monitoring stations to measure respirable particulate matter sized below 2.5 microns (PM2.5) and augment monitoring stations that had been deployed by SCDHEC several days earlier. By February 11, a total of seven monitoring stations had been deployed (four by the EPA and three by SCDHEC). All stations consisted of MetOne EBAM units set to monitor for PM2.5 and record both 15-minute and 1-hour time-weighted averages. Five of the stations were outfitted with metrological sensors that included wind speed and direction. Four of the stations were also outfitted with data transmission systems that allowed both the EPA and SCDHEC to remotely observe live data feeds. Results from these instruments were compared to the EPA’s Air Quality Index (AQI) and National Ambient Air Quality Standards (NAAQS). Six stations yielded no more than 70.7% and as few as 44.6% of their 24-hour average results within a “Good” AQI range and yielded as much as 54.2% of their 24-hour averages in the “Moderate” AQI range. One station yielded 1.2% of its 24-hour averages in the “Unhealthy for Sensitive Groups” range (the last range is consistent with the NAAQS 24-hour average for PM2.5). Twenty-four-hour averages for the seventh station, which was located the furthest away from the Site, were 91.9% “Good” and 8.1% “Moderate”. By comparison, 24-hour averages for the AQI station in Spartanburg, SC were 91.8% “Good” and 8.2% “Moderate”. Elevated particulate concentrations are typically measured overnight and into early morning hours; these measurements are consistent with both anecdotal reports from residents and visual observations from time-lapse photography, and are caused by reduced wind speeds at night as well as morning temperature inversions which trap smoke close to the ground.

On February 11, 2015, OSC Huyser met with SCDHEC and Chester County to examine the Site with the presence of a landfill firefighting specialist with American Engineering Group LLC. Recommendations for addressing the fire from a response standpoint included three primary actions: 1) Cover; 2) Monitor; and 3) Closure. Advanced firefighting techniques involving the injection of various materials such as nitrogen or traditional firefighting techniques involving water application were not recommended and are unlikely to be successful.

On February 17, 2015, OSC Huyser and START mobilized to collect air, soil and surface water samples as well as conduct an asbestos debris survey and collect aerial imagery. Air sampling within the smoke plume directly above the burning area identified 13 compounds with peak concentrations that exceeded their respective long-term exposure Regional Screening Levels (RSL) and Removal Management Levels (RML) : Benzene, 1,3-Butadiene, Chloromethane, Cumene, Ethyl Benzene, Formaldehyde, Naphthalene, Styrene, and Xylene. These values were compared to Acute Exposure Guideline Levels (AEGL), which are published by the EPA Office of Pollution Prevention and Toxics and are used for emergency exposure conditions. None of the 13 chemicals exceeded the lowest AEGL threshold. Hydrogen cyanide (HCN) and carbon monoxide (CO) were also detected within the smoke plume directly above the burning area; neither has a corresponding RSL or RML for ambient air exposure, but both have AEGL criteria. Both HCN and CO peak concentrations in the plume exceeded their respective AEGL-2 (8-hour) time-weighted-average (TWA) value which means that health effects may occur in the general population if exposed to the contaminant at that concentration over that corresponding time period. On April 9, 2015, off-site air samples were collected. Of the 13 compounds identified above risk levels in the plume, benzene and formaldehyde were found to exceed residential RSLs in the community. Benzene was found in the fire at concentrations up to 29,000 µg/m3, more than two orders of magnitude above the Industrial RML of 157 µg/m3. Benzene was found in the surrounding community at concentrations up to 0.91 µg/m3, nearly three times greater than the Residential RSL of 0.36 µg/m3, and also found at the office trailer of the Site at concentrations up to 9.9 µg/m3. Formaldehyde was found in the fire at concentrations up to 197 µg/m3, double the Industrial RML of 94.3 µg/m3. Formaldehyde was found in the community at concentrations up to 1.52 µg/m3, five times greater than the Residential RSL of 0.216 µg/m3, and also found at the office trailer of the Site at 3.24 µg/m3.

Respirable (PM2.5) particulates measured in samples from the smoke plume directly above the burning area peaked at 4,500 µg/m3. For comparison, the EPA AQI classifies a 24-hour average of PM2.5 above 250.5 µg/m3 as “Hazardous”. Measurements from monitoring stations near the Site and throughout the town of Lockhart recorded 4-min-average readings in excess of 250.5 ug/m3 at a frequency of 0.1% and recorded one 1-hour average reading in excess of this level. Ninety percent of all 4-min-average particulate monitor readings and 97.8% of all 1-hour average particulate monitor readings are below 45µg/m3 which are two orders of magnitude below the peak PM2.5 measurement sampled from the burning area. On April 9, 2015, off-site air samples were collected and yielded a 24-hour reading for PM2.5 of 78 µg/m3 in downtown Lockhart, which exceeds the EPA 24-hour NAAQS for PM2.5 and is within the EPA AQI range of “Unhealthy” for the general public. However, no PM2.5 detections were found above reporting limits on concurrent samples collected at the gas station close to the Landfill or at the office trailer of the Landfill during the same time period, so it is uncertain whether the value measured in downtown Lockhart is directly related to the smoke plume from the fire.

A survey was conducted on the Site to identify asbestos materials in areas outside of the designated asbestos disposal cell. The survey encompassed 125 grids sized 40 by 40 feet (total survey size of more than 4.5 acres) and identified, described, and counted suspected ACM in 42 of the grids (an area of more than 1.5 acres). Samples of suspected ACM were collected in 22 of the grids and PLM analysis showed that 10 of those grid samples contained Crysotile asbestos at concentrations ranging from 5% to 50%. The designated asbestos disposal cell, which covers approximately 1.6 acres, was not included in the survey since it is known and recognized that the cell area contains exposed ACM. These materials were sampled following the emergency response in November 2014 and identified Chrysotile and Crocidolite Asbestos at varying concentrations of up to 18% and 7%, respectively.

An aerial survey was conducted on February 19, 2015, to conduct volumetric measurements of waste material at the Site. A digital topographic surface was built using photogrammetry from the aerial survey and high accuracy ground control points of known location and elevation. This surface was measured against: 1) the original grade based on the U.S. Geological Service (USGS) 1972 Lockhart, SC quadrangale; and 2) the August 31, 1999, Bennett Industrial Landfill design plans which were digitized and geo-rectified. The survey estimates that there is approximately 19,500 cubic yards of waste in the designated asbestos disposal cell. The remaining landfill waste volume is estimated at 381,000 cubic yards of waste in the last active disposal area, as well as an additional 333,000 cubic yards of waste in the cell on the south side of the Site where operations ceased sometime between 2005 and 2008. The fire is occurring in the last active disposal cell but there is no visible barrier separating the active cell from the previously used cell. As a result, there are approximately 714,000 cubic yards of waste that is at risk of burning. Disposal records that were submitted by Bennett Industrial Landfill, Inc. to SCDHEC for annual reporting, which are incomplete and have not been verified, report that a known minimum of 423,713 tons of waste was received, at least 3,252 tons of which is known to be asbestos. This number includes only reports from 1999 to 2006, after which regulatory requirements changed and asbestos waste was not stated as a separate line item in annual reports. A common density for waste materials received by the landfill is within the range of 0.6 – 0.5 tons per cubic yard. For the known minimum waste received that was reported to SCDHEC, this density provides a volume range of 706,000 cubic yards to 847,000 cubic yards. The volume range is consistent with the calculated measurements from the aerial survey of 714,000 cubic yards. Therefore, the estimated volume of waste in the designated asbestos disposal cell of approximately 19,500 cubic yards is considered reliable.

The surface of the designated asbestos disposal cell is entirely covered with evidence of erosion including rills in excess of 24 inches deep and 36 inches wide. Exposed ACM is observed throughout the floor of the eroded areas. Erosion features on the cell are less than 30 months old since they were last repaired on August 28, 2012, which was confirmed during a SCDHEC inspection on September 26, 2012. Large asbestos disposal bags and ACM objects are observed in the drainage path up to 350 feet from the disposal cell surrounded in sediment which indicates that washout of the cell is transporting waste downstream. The sedimentation pond, originally designed to a depth of five feet below the drainage riser surface, has filled with sediment to the riser inlet and within 2.5 feet of the riser overflow surface. The sedimentation pond was reportedly last cleaned out on August 27, 2012, but the SCDHEC inspection on September 26, 2012, reported that the claims of a cleanout action were either inadequate or false.

On Monday and Tuesday, June 1^st and 2^nd, ERRS contractors began grading and excavating operations on the landfill fire area in an effort to extinguish smoldering subsurface zones. The active fire area was approximately 0.5 acres with a 35 foot drop at the face along the southern edge. ERRS began grading the western edge of the fire area with a D-8 bulldozer to a manageable slope for soil and clay cover, approximately a 4:1 slope. Water was used intermittently to address hot zones which were uncovered during grading operations and dust which was lifted by equipment due to the dry material conditions. Once the western edge was sloped successfully the remainder of the 35 foot face was gradually sloped.

This operation proved to be successful over the first few days of grading and no smoldering or smoke was noted by Wednesday morning (June 3^rd).  Grading operations continued while incorporating some debris into the final desired slope of the landfill area. On Wednesday ERRS began moving cover soils from a borrow area to the work zone and continued grading and sloping operations. By Thursday (June 4^th) no smoldering, smoke or burning odor was noted near the burn area. Large amounts of rain through the week (2.5 inches on Tuesday, June 2^nd) most likely assisted in quenching the hot zones within the landfill. No significant smoke or volatile organic compounds (VOCs) were noted in ambient air during the first week of operations. During the remainder of the week, grading and sloping ops continued essentially expanding the working area to approximately 2.5 acres.

Media interest remained high through the first week. On Monday and Tuesday (June 1^st and 2^nd) four local news stations from Greenville SC, Columbia SC  Spartanburg SC and Charlotte NC interviewed OSC Huyser. Lockhart Mayor Eileen Ashe was also interviewed and EPA Region 4 Community Involvement Coordinator (CIC) Kerisa Coleman was on site to assist the mayor as needed by addressing site related questions. On Wednesday, June 3^rd, EPA CIC Coleman planned to distribute site fact sheets door to door with South Carolina Dept Health and Environmental Control (SC DHEC) community representatives.

START contractors continue air monitoring, drafting final capping and runoff plans and providing technical assistance. No significant smoke, air or technical issues have been encountered to date. .

During the emergency response in November of 2014, EPA's responding OSC informed the owner of the landfill that an emergency action would be necessary to address the on-going fire and potential hazardous substance as well as pollutant and contaminant releases at the Site. The landfill owner declined to undertake an action. 

• Isolation of burning material by removal and relocation of available fuel path and installation of earthen cover; (ONGOING)
• Isolation of designated asbestos disposal cell through the installation of earthen cover;
• Re-grading waste materials and native soils for purpose of cover installation; (ONGOING)
• Installation of temporary measures to prevent off-site migration of dust or contaminants as removal operations are conducted; and, (ONGOING)
• Continue sampling and monitoring, as needed, for site safety purposes and to further delineate or identify contaminants. (ONGOING)