ERRS contractors temporarily demobilized from the Site on 8/7/2015 for a brief period and remobilized to the Site on 8/11/2015. A rainfall event of 0.4” on 8/11/2015 caused minor rill erosion on some working surfaces of the Site and re-filled the detention pond with water but did not cause damage to the landfill face. On 8/12/2015, ERRS crews resumed work which included installation of the fourth and final 6” clay layer on the landfill face. Other work included repairs to access roads which were impacted with water and construction of a small diversion berm to prevent runoff from the undisturbed north slope of the site from discharging to active working areas. By the morning of 8/14/2015, the final clay layer on the landfill face was complete.

START’s engineer developed a design for the proposed slope of the designated asbestos cell cover and a drainage path between the asbestos cell and the landfill face. START and ERRS crews arrived the afternoon of 8/11/2015 to install grade stakes around the KNOLL BORROW ZONE in order to delineate the shape of the drainage path. A discrepancy of 5-8 ft between the true existing grade and the marked existing grade developed from the June aerial overflight was discovered in this area. START subsequently identified discrepancies between two ground control point elevations and the drawn elevations from aerial overflight data. START will pursue modification to the grade elevation data.

On 8/12/2015, ERRS crews began removing soil from the KNOLL BORROW ZONE and relocating the soil to the immediately adjacent top surface of the designated asbestos disposal cell. At the south end of the KNOLL BORROW ZONE where the access road begins to reach the toe of the landfill face, ERRS crews uncovered roofing materials below the roadway and other materials which were suspected to contain asbestos waste. Excavation in this area at the south end of the zone ceased and a bulk sample of suspected asbestos containing material was collected for laboratory analysis.

A work plan for asbestos activities was developed and distributed to ERRS and START for finalization. The work plan includes procedures that mostly restrict asbestos waste disturbance and define methodology by which fill and cover material will be installed from the perimeter, ensuring that equipment does not have to come in contact with asbestos waste. Materials will be wetted throughout all operations and daily air samples will be collected. Work will proceed with Level D PPE unless asbestos fibers above 0.01 f/cc are detected in a daily air sample; if this occurs, PPE will be upgraded to Level C and a personnel decontamination system will be installed.

START contractors continued to collect data from the subsurface air monitoring wells along the northern and eastern edge of the landfill face. Oxygen concentrations remain at or near zero in all four monitoring wells. Methane and Temperature readings also remain constant.  A slight increase in Hydrogen Sulfide was observed in all four wells from the previous week. The Balance gas in wells 1, 3, and 4 remain constant from previous readings, but the Balance gas in well 2 has increased from 20% in previous weeks to above 30% beginning 8/12/2015; the goal for Balance gas is below 20%. The increase in Carbon Monoxide that was observed in the previous week was confirmed from 8/12/2015-8/14/2015 and the discrepancy between the Landtec and MultiRAEpro devices may have been corrected (this issue is discussed in Section 2.2.1.2).

On 8/13/2015, a Site visit was held with the EPA R4 ERRP Branch Chief, the City of Lockhart Mayor, and several managers and directors from SCDHEC. The meeting included a tour of the Site and discussions regarding the completion conditions of the Site at the end of the removal action. The removal action will continue to focus on completion of encapsulating the former burn area and the designated asbestos disposal cell. Air monitoring wells will be closed at the end of the removal action. Additional cover on the top of the landfill, including reduction of waste piles at the northeast corner, will be addressed based on available time and resources following the completion of these objectives.

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 14: Completed fourth and final clay layer on the face area
• Aug 12: Begin removal of Knoll Borrow Zone
• Aug 12: Begin initial cover installation on Asbestos Cell

• 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; (ONGOING)
• 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)

• Complete landfill cover operations with installation of topsoil, seed, fertilization, and matting
• Finalize landfill design plans
• Continue asbestos cell covering operations
• Continue monitoring 4 well locations 
• Continue close scrutiny of CO and temperature levels particularly at MW 1 and MW 2 

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.