Pollution/Situation Report Profile

Bennett Landfill Fire
Chester, SC - EPA Region IV
POLREP #9
Return from holiday break

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U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Bennett Landfill Fire - Removal Polrep

EPA Emergency Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region IV

Subject:

POLREP #9
Return from holiday break
Bennett Landfill Fire
B44Y
Chester, SC
Latitude: 34.7874300 Longitude: -81.4502500

To:

From:

Matthew Huyser, OSC

Date:

7/16/2015

Reporting Period:

7/4/2015-7/17/2015

1. Introduction

1.1 Background

Site Number:	B44Y	Contract Number:	EP-S4-07-02
D.O. Number:	0134	Action Memo Date:	4/30/2015
Response Authority:	CERCLA	Response Type:	Time-Critical
Response Lead:	EPA	Incident Category:	Removal Action
NPL Status:	Non NPL	Operable Unit:
Mobilization Date:	5/26/2015	Start Date:	5/26/2015
Demob Date:		Completion Date:
CERCLIS ID:	SCN000402727	RCRIS ID:
ERNS No.:	1100014	State Notification:	11/2/2014
FPN#:		Reimbursable Account #:

1.1.1 Incident Category
Time-critical removal action.

1.1.2 Site Description
The Bennett Landfill Fire Site is a former construction debris and nonhazardous industrial waste landfill (defined by state regulations as a Class II landfill) that was additionally permitted to accept certain types of asbestos waste.

The landfill ceased accepting waste in 2014. On November 2, 2014, the landfill was found to be on fire and was believed to have been extinguished by November 7th. Due to increasing smoke concentrations in January 2015, SCDHEC requested that the EPA conduct a Removal Site Evaluation (RSE). EPA signed an Action Memorandum on April 30, 2015 to conduct a Time-Critical Removal Evaluation and mobilized to the Site to begin removal activities on May 26.

Additional information for this section is available in POLREP #4 from 6/5/2015.

1.1.2.1 Location
The Site is located at 4399 Pinkney Road, Chester, Chester County, South Carolina. The geographic coordinates of the Site are 34.7874300 degrees north and 81.4502500 degrees west.

Additional information for this section is available in POLREP #4 from 6/5/2015.

1.1.2.2 Description of Threat
The fire at the Bennett Industrial Landfill is actively releasing chemical compounds into the air, including benzene and formaldehyde, which are measured near the fire at concentrations exceeding industrial RMLs for air and concentrations within the surrounding community that are greater than three times the residential RSL. Conditions at the Site, if not addressed, will continue to deteriorate over time and resulting in increasing quantities of exposed asbestos which are susceptible to transport by wind and other weather conditions to the nearby population.

Additional information for this section is available in POLREP #4 from 6/5/2015.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
Additional information for this section is available in POLREP #4 from 6/5/2015.

2. Current Activities

2.1 Operations Section

2.1.1 Narrative
EPA held a community availability session on 7/9/2015 along with DHEC and ATSDR. EPA OSCs Huyser and Gaughan, and CIC Coleman, spoke with residents about ongoing removal work. Representatives from ATSDR spoke with residents about health consultation information developed in review of the EPA's data. South Carolina DHEC representatives spoke with residents about oversight actions, regulatory news and air quality concerns.

Little rain has fallen on the Site since crews demobilized for the July 4th holiday on 7/3/2015. By 7/8/2015, significant cracks in the initial clay layer over the burn area were observed. The clay appears to penetrate most of the way through the clay layer. Most cracks are less than 1/6” in width but several areas contained cracks with widths exceeding 3/4". Additional moisture will be applied during cover installations and topsoil will be applied as soon as possible after clay cover is completed.

EPA ERRS Contractor, CMC, remobilized on 7/12/2015 and resumed Site operations on 7/13/2015. Initial activities began by moving soil from the Old Yard Stockpile at the southern edge of the Site to the top of the landfill, just east of the covered burn area. The soil was moved to provide a smooth road surface over areas where trash was still exposed, increasing operating efficiency and reducing the risk of tire puncture. The installation of the surface was completed on 7/14/2015 and resources from the Old Yard Stockpile were exhausted. However, excavation into the stockpile revealed trash where it was believed that native soil was located. On 7/15, a layer of sandy soil from a staging area elsewhere on the Site was moved to the Old Yard Stockpile to recover the trash that had been found. No additional excavation is anticipated in the area. Silt fencing will be installed around the former Old Yard Stockpile area until a vegetative cover can be installed.
Tree and topsoil removal began at the Western Ridge Borrow Zone on 7/13/2015 and proceeded throughout the week. Felled trees and brush are being staged at the property line. If the trees are not fully removed from the Site, they will be staged along the property line to serve as a barrier in lieu of perimeter fencing.

Additional work on 7/14/2015 included pushing several yards of sandy soil from the north east corner of the Knoll Borrow Zone to the north east corner of the asbestos cell. A portion of this soil was spread as a road surface and the remaining soil was staged for future use.

On 7/15/2015, crews began installation of a second 6” lift of clay on the burn area. Clay was both pushed form the Knoll Borrow Zone surface and relocated from the Knoll Stockpile. By the end of 7/16/2015, approximately 40% of the burn area was covered with the second clay layer.

EPA START Contractor, Tetra Tech, remobilized on 7/12/2015 and resumed Site activities on 7/13/2015. START measured grade stake elevations with a high accuracy GPS unit and confirmed that grade elevations were on-target with projected goals. The initial cover of sandy soil ranges in depths of 0.7-1.9ft. The initial clay layer is generally 0.5ft. A minimum of three clay layers are planned.

EPA and START continued monitoring the test Air Wells. Initial monitoring began 7/2/2015. Daily monitoring began 7/13/2015 with two readings per day collected during the week. Frequency may be reduced to 1/day or may be further reduced to 1/week, if appropriate. Initial well procedures involved opening a cap at the top and inserting a tube attached to each instrument then waiting for stabilization prior to recording results. On 7/14/2015, procedures were improved by installing plugged fittings attached to the well cap with the tube attached underneath. On the second measurement of 7/15/2015, procedures were further improved by purging the wells with a Gillian pump which ran for 30-60 minutes (pulling through the fittings and hose from the bottom of the well). Water caused by accumulation in the well or condensation inundated the pump on 7/16/2015 and the tube length was reduced to compensate.

General characteristics of the air monitoring wells show that the subterranean space contains low levels of oxygen (≈1%) and high levels methane (>20%). Hydrogen Sulfide concentrations increase from Well #1 consistent ranges of 1-5 ppm to Well #4 consistent ranges of 90-120 ppm. This increase in H2S concentrations coincides with temperature increase from Well #1 average temp of 85°F to Well #5 average temp of 104°F. Carbon Monoxide concentrations are generally from 5-10 ppm and may show mild increases from Well #1 to Well #4 but more data will be needed to establish trends.

START utilized data from the unmanned aerial flight to calculate volumes of the uncovered waste at the norheast corner of the Site and the available top soil staged near the center of the Site. Calculations show that approximately 2300 CY of uncovered waste is accumulated in unorganized piles at the northeast corner of the Site near the scale house. An additional volume of approximately 400 CY of waste is located down the slope of the hill between the larger pile and Highway 92. These volumes account for only the waste above the general ground level and do not include potential waste volumes below ground surface.

The volume of topsoil staged near the center of the Site was measured at approximately 1200 CY. This volume would provide sufficient soil for an immediate cover over the burn area with a depth of approximately 3-4in.

2.1.2 Response Actions to Date

May 25-29: ERRS mobilization, site preparation (access roads, entrance, trailer, work zones)
June 1-2: Grading and wetting burned area
June 3: First record of no morning smoke observed
June 3-5: Continue grading and wetting burned area. Moved cover soils from borrow area to burned area
June 5-26: Continue grading and covering operations.
June 16: Exhausted stockpile of cover soil at top center of Site
June 26 Initial cover soil installation completed.
June 29 Initial six inches of clay cap begun. Completed on July 3rd.
July 2nd Three additional gas monitoring wells installed to monitor landfill carbon monoxide and temperatures near former burn area.
July 13-17: Began removal of trees and topsoil from West Ridge Borrow Zone
July 14: Exhausted Old Yard Stockpile at the south side of the Site
July 14-17: Begin installation of second 6" clay layer on burn area

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
Information for this section is available in POLREP #4 from 6/5/2015.

2.1.4 Progress Metrics

*Waste Stream*	*Medium*	*Quantity*	*Start Date*	*Treatment*	*Est. % Complete*
Burning Area	Debris	Approx 3.0 acres	6/1/2015	Cover	18" of cover soils completed on 6/26. Initial clay cap completed 7/3. 40% of Second clay layer completed by 7/16
Asbestos Cell	Debris	Approx 19,500 CY	n/a	Regrade & Cover	n/a

2.2 Planning Section

2.2.1 Anticipated Activities
The first priority of the removal action will be to address the burning debris pile by installing a soil cover. Isolation of the burning material and reduction of oxygen supply will significantly reduce emissions from the smoldering fire. The second priority of the removal action will be to address the eroding asbestos disposal cell by re-grading and covering the area.

Air sampling and monitoring activities will be conducted on-site for worker health and safety and continued site investigation purposes. Air monitoring for respirable particulate matter (PM2.5) will continue off-site outside the fenceline and in downtown Lockhart, SC for the duration of the action.

Soil for cover and encapsulation will be obtained from on-site sources to the greatest extent possible. The disturbed areas of the Site will be secured with vegetation to provide a stable erosion-resistant surface. Total project time is estimated at approximately 3 months.

2.2.1.1 Planned Response Activities

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)

2.2.1.2 Next Steps

Continue landfill slope grading and cover operations
Finalize landfill design plans
Begin evaluating extent of asbestos cell for covering operations
Continue clay capping of 3 acre face area
Continue monitoring carbon monoxide and temperature at 4 monitoring well locations

EPA and DHEC are evaluating soil gas data to determine whether the current subterranean conditions around the north and south perimeter of the burn area. A list of parameters for acceptable gas concentrations and procedures for ongoing measurement will continue to be developed for the project.

A geotechincal assessment is scheduled for the week of 7/20/2015. Soil density and moisture conditions will be measured to determine if current compaction procedures are sufficient. Target conditions for the soil dry density is within 95% of 88 lbf/ft3 and target conditions for the soil moisture content is within +/-3% of 24.7%. Compaction procedures will be adjusted if conditions are outside of these ranges.

2.3 Logistics Section

An additional ERRS crew is being mobilized. A second water truck may need to be mobilized due to significantly dry conditions.

2.4 Finance Section

No information available at this time.

2.5 Other Command Staff

OSC Matthew Huyser
OSC Perry Gaughan

3. Participating Entities

SCDHEC continues to provide technical assistance and information regularly

South Carolina Forestry Commission has offered to provide assistance with tree removal, if necessary

Chester County EMA and Union County EMA will provide technical assistance and information, as needed

Clemson Chester County Extension Office will provide technical assistance for soil amendment and seeding needs regarding final cover and vegetation

4. Personnel On Site

EPA (1)
SCDHEC (varies)
County EMA (varies)
ERRS (10)
START (1)

5. Definition of Terms

µg/m3	Micrograms per cubic meter (= 0.001 mg/m3)
AEGL	Acute Exposure Guideline Levels
AQI	Air Quality Index
C	Celsius
CERCLA	Comprehensive Environmental Response, Compensation, and Liability Act
CFR	Code of Federal Regulations
Conc	Concentration
ConcHR	Hourly (HR) average value recorded by an EBAM instrument
ConcRT	Real time (RT) concentration recorded by an EBAM instrument based on a rolling four-minute average
DHEC	South Carolina Department of Health and Environmental Control
EMA	Emergency Management Agency
EPA	U.S. Environmental Protection Agency
ERRS	Emergency and Rapid Response Services
mg/kg	Milligram per kilogram (= 1 ppm)
mg/L	Milligram per liter
mg/m3	Milligram per cubic meter (= 1000 µg/m3)
NAAQS	National Ambient Air Quality Standard (primary and secondary NAAQS for PM2.5 24-hour average is 35 µg/m3)
NPL	National Priorities List
OAQPS	EPA Office of Air Quality Planning and Standards
OSC	On-Scene Coordinator
PM2.5	Airborne particulate matter with particle diameters below 2.5 microns
ppb	Part per billion (cannot be used to describe a mass per volume unit such as µg/m3)
ppm	Part per million (cannot be used to describe a mass per volume unit such as mg/m3)
RML	Removal Management Level
RSL	Regional Screening Level
SCDHEC	South Carolina Department of Health and Environmental Control
START	Superfund Technical Assessment and Response Team
TWA	Time-weighted average

5.1 Regional Screening Levels (RSL) and Removal Management Levels (RML)
Regional Screening Levels (RSL) are conservative risk-based screening values developed by the U.S. EPA to help identify contaminants of potential concern. Contaminants that exceeded a RSL in at least one sample are then screened against industrial air Removal Management Levels (RML) that were calculated for this evaluation. RMLs are risk-based screening values developed by the U.S. EPA to determine whether sample concentrations are sufficiently elevated that they may warrant a removal action. Exceedance of a RML by itself does not require a removal action, nor does it imply that adverse health effects will occur.

6. Additional sources of information

6.1 Internet location of additional information/report
Site updates will be provided to the "Bulletins" section of epaosc.org/bennettlandfill

Documents, reports, and videos for public release will be posted to the "Documents" section of epaosc.org/bennettlandfill

The Agency for Toxic Substances and Disease Registry (ATSDR) has reviewed chemical constituent and other sampling and monitoring data collected at the Bennett Landfill Fire Site as part of EPA's Removal Site Evaluation. A final version of at Health Consultation Letter and Fact Sheet were released on June 19, 2015. These materials are posted to the documents section of the epaosc.org/bennettlandfill webpage. ATSDR is currently in the finalization process of a Health Consultation Letter and Fact Sheet for particulate monitoring results. The data for the particulate monitors was released on June 11, 2015 and is also posted to the documents section of the epaosc.org/bennettlandfill webpage.

6.2 Reporting Schedule
New POLREPS will be issued weekly on Fridays for the duration of on-site activities.

Daily photos of site conditions and progress are being posted to the "Images" section of epaosc.org/bennettlandfill. These photos are collected from the same general locations each day.

7. Situational Reference Materials

No pertinent information to report at this time.