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

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region IV
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Subject:
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POLREP #10
Clay Cappping Installation Continues
Bennett Landfill Fire
B44Y
Chester, SC
Latitude: 34.7874300 Longitude: -81.4502500
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To:
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From:
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Perry Gaughan, OSC
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Date:
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7/24/2015
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Reporting Period:
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7/20/2015 to 7/25/2015
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1. Introduction
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1.1 Background
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Site Number: |
B44Y |
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Contract Number: |
EP-S4-07-02 |
D.O. Number: |
0134 |
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Action Memo Date: |
4/30/2015 |
Response Authority: |
CERCLA |
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Response Type: |
Time-Critical |
Response Lead: |
EPA |
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Incident Category: |
Removal Action |
NPL Status: |
Non NPL |
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Operable Unit: |
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Mobilization Date: |
5/26/2015 |
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Start Date: |
5/26/2015 |
Demob Date: |
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Completion Date: |
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CERCLIS ID: |
SCN000402727 |
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RCRIS ID: |
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ERNS No.: |
1100014 |
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State Notification: |
11/2/2014 |
FPN#: |
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Reimbursable Account #: |
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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.
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2. Current Activities
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2.1 Operations Section
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2.1.1 Narrative
During the week of July 20th, ERRS contractors continued clay covering operations of the three-acre landfill face area. As previously noted, no smoke or fire has been observed since the first week of June. Capping operations are being conducted in six inch lifts to insure proper compaction.
On Wednesday, July 22nd, compaction testing was conducted by PSI Inc, Columbia, South Carolina. The pre-existing 50-foot grid was used on the landfill face area and 34 grid locations were tested. Only four grids were found to be outside the desired landfill capping specifications of 95% compaction and 21-27 % moisture content. Those four grid locations along the eastern boundary of the landfill face near Air Monitoring Well No. 4 were re-tilled with the D-6 bulldozer and allowed to dry out overnight to lower the moisture content. On Thursday, July 23rd, ERRS contractors continued with the third six-inch lift of clay, borrowing clay from the southern perimeter of the site and the former sedimentation pond area.
START contractors continued to collect data from the subsurface air monitoring wells along the northern and eastern edge of the landfill face. Oxygen, carbon monoxide, carbon dioxide, hydrogen sulfide and temperature are being closely monitored for any changes which would necessitate the placement of a fire trench around the previous burn area. All gas levels have remained low thus far and subsurface temperatures remain consistently low. A conference call is scheduled during the week of July 27th to discuss the air monitoring well results with landfill engineers. at which time a decision on the need for a fire trench is anticipated.
Again no rain was observed during the week of July 20th at the Site, and cracks in the clay capping are prominent. As OSC Huyser noted the previous week, most cracks are less than 1/6” in width but several areas contained cracks with widths exceeding 3/4". Additional moisture may be required daily to insure the integrity of the cap.
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
- July 20-22 Complete second 6" clay lift on burn area
- July 22 Conducted compaction testing by PSI Inc - 30 of 34 grids passed
- July 23-25 Begin installation of third clay layer on landfill face 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. Second clay layer completed by 7/22. Third layer started. |
Asbestos Cell |
Debris |
Approx 19,500 CY |
n/a |
Regrade & Cover |
n/a |
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2.2 Planning Section
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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.
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2.3 Logistics Section
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An additional ERRS crew is being mobilized. A second water truck may need to be mobilized due to significantly dry conditions.
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2.4 Finance Section
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No information available at this time.
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2.5 Other Command Staff
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OSC Matthew Huyser
OSC Perry Gaughan
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3. Participating Entities
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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
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4. Personnel On Site
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EPA (1)
SCDHEC (varies)
County EMA (varies)
ERRS (10)
START (1)
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5. Definition of Terms
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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.
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6. Additional sources of information
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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.
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7. Situational Reference Materials
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No pertinent information to report at this time.
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