Pollution/Situation Report Profile

Bennett Landfill Fire
Chester, SC - EPA Region IV
POLREP #12
Installation of Final Clay Layer Continues

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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 #12
Installation of Final Clay Layer Continues
Bennett Landfill Fire
B44Y
Chester, SC
Latitude: 34.7874300 Longitude: -81.4502500

To:

From:

Perry Gaughan, OSC

Date:

8/7/2015

Reporting Period:

8/03/2015 through 8/07/2015

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

During the week of August 3rd, 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. The final six inch lift of clay began on July 31^st and is currently 75% completed. Heavy showers on Thursday, August 6^th delayed completion of clay capping on the landfill face area.

On Thursday morning August 6th, a second round of compaction testing was conducted by PSI Inc., Columbia, South Carolina. The pre-existing 50-foot grid was used on the landfill face area and 28 grid locations were tested. Only one grid was found to be outside the desired landfill capping specifications of 95% compaction and 21.6-27.6 % moisture content. The one grid location along the eastern boundary of the landfill face near Monitoring Well No. 4 will be re-tilled with the D-6 bulldozer and allowed to dry out prior to compaction.

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. An increase in carbon monoxide was noted (to 35-50 ppm) at Monitoring Wells 1 and 2 this week near the crest of the landfill face. No corresponding temperature increase was noted however. The instrument was bumped with calibration gas for carbon monoxide at 50 ppm and registered 52 ppm CO, suggesting that the values observed are real. The OSC's and START will continue to monitor CO levels to determine if additional measures at the crest of the landfill are required. A more thorough discussion of the observed CO levels will be discussed in a conference call next week with all parties.

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 Begin installation of third clay layer on landfill face area
July 28 Complete excavation of 3 vertical feet of sediment from detention pond
July 29 Consultation with Clemson University Extension Office for Soil quality and vegetation
July 27-31 Continue installation of third clay layer on landfilled face area reaching 90% completion
Aug 6 - Conducted round 2 of compaction testing, 27 of 28 grids passed.
Aug 3-7 75% completion of final clay layer on the 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. 75 % completion of final clay layer (24 inches) completed.
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 4 well locations
Continue close scrutiny of CO and temperature levels particularly at MW 1 and MW 2

Planning Notes and Possible Steps for August 10th.

Based on observations during the week of August 3rd, an increase in CO levels at MW 1 and 2 was noted and appears to be real. No temperature increase in either well was noted however. This may be an increase in microbial activity considering that the measured O2 infiltration remains at 0.1% ( or the equivalent of 1000 ppm O2). Microbes given the chance to degrade wood and construction debris in an atmosphere of 1000 ppm O2 may generate additional CO and CO2.

With our operational emphasis on placement of a two foot clay cap on the landfill face, we my have inadvertently ignored the rest of the landfill north of the crest. Some consideration as to placement of one foot of compacted clay along the crest and 100 feet north of the crest may be warranted if CO readings continue to be observed at MW 1 and MW 2.

Previous Planning Considerations:

Consultations on air monitoring results in the wells were received from EPA and SCDHEC officials with experience with air quality monitoring for landfills. Several recommendations were included and are addressed below:

Add shallow gas wells:
Shallower wells could monitor for O2 infiltration. Locations could be targeted at cracks in the clay liner or anywhere H2S or CH4 are detected at the surface. However, this recommendation is outside the current scope of the response and may be implemented at a later time depending on the duration of the removal project and SCDHEC’s ability to conduct future monitoring.

Measure wells twice per day:
Wells were measured twice per day from 7/13 to 7/14. Only small variations were observed from morning to afternoon measurements. The most notable was H2S readings in Well3 which increased by 5-10ppm from morning to afternoon but decreased by 3-7ppm for the next morning with fair regularity. In the interest of time for personnel responsible for collecting readings, the measurements were reduced to 1/day on 7/27/2015. Twice per day measurements could resume at any time to determine whether the low degree patterns are still persistent.

Conduct a Bar Hole Survey to map the Methane Plume:
The scale of the landfill does not suggest that there would be significant variation across the Site and information gained from the survey is unlikely to alter decisions on the removal action design at this point. The burn area that is of primary concern covers less than 3 acres and the location of smoldering material is sufficiently documented.

For ideal and stable conditions, O2 and CO concentrations should be near zero and remaining “Balance Gas” (anything other than CH4, CO2, or O2) should be less than 20% by volume. Temperature should be stable:
The presence or increase in CO, O2 (>2%) and/or BALANCE (>40-50%) may indicate ambient air intrusion into the landfill. With BALANCE<20%, then the remaining 80% should ideally be composed of Methane and Carbon Dioxide. These goals are met, so far, in Wells 2, 3, and 4. Well 1 shows signs of possible ambient air intrusion (BALANCE concentrations in Well 1 are greater than 30%) which is likely from the uncovered and usealed top of the landfill.

Carbon Monoxide concentrations are generally below 30ppm (0.003%) and more often below 15ppm (0.0015%) with lowest consistent readings in Well1. CO measurements made by the RAE Systems MultiRAEpro instrument are generally higher than the Landtec GEM2000 instrument and both are lower than the RAE Systems MultiRAE+ instrument. It is believed that the true value is likely near or between the MultiRAEpro and the GEM2000 values. Increases in CO concentrations may indicate continued smoldering but this trend has not yet been observed.

Temperatures are generally stable but migration of smoldering, if it were to occur, will likely take several weeks or months.

Monitor CH4 and H2S for short term and long term exposure concerns:
Hydrogen Sulfide will be monitored for in low lying areas. The SC air standard for H2S at property line would be 100ppb. Methane and Hydrogen Sulfide concentrations in the well are high and would present a Health & Safety issue if a trench or pit were dug into the ground. Hydrogen Sulfide generation is indicative of anaerobic digestion with high moisture content; these conditions are confirmed in the field in Wells 3 and 4 where high H2S readings are accompanied by excessive condensation found in those wells.

Seasonal variation in gas generation can be expected and settling over time may create pathways for gas and moisture infiltration:
The removal project will likely terminate by the fall of 2015. Any further monitoring would be conducted by the property owner or state or county agencies. EPA assistance could be requested in the future if necessary.

2.3 Logistics Section

No information available at this time.

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 (11)
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.