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Bennett Landfill Fire

All POL/SITREP's for this site Bennett Landfill Fire
Chester, SC - EPA Region IV
POLREP #15
Near Completion of Clay Cap on Asbestos Cell 		Printer Friendly  |   PDF
 
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 #15
Near Completion of Clay Cap on Asbestos Cell
Bennett Landfill Fire
B44Y
Chester, SC
Latitude: 34.7874300 Longitude: -81.4502500

To:
From: Matthew Huyser, OSC
Date: 8/28/2015
Reporting Period: 8/21/2015 8/28/2015

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

From August 25-28, ERRS contractors removed trees and vegetation from the remaining section of the "West Ridge Borrow Zone". Clay soil from the West Ridge Borrow Zone continues to be excavated for cover material which is being placed on the asbestos cell. By August 28, the 1-foot-deep cover of clay was 90% complete and total completion of the clay cap is anticipated by August 29. 

Beginning August 24, grass seed, fertilizer, and erosion control matting were installed on the north end of the former burn area slope and along the west bank of the ditch which serves as a stormwater conduit between the landfill slope and the asbestos cell. Installation of ground cover materials is less than 10% complete and will be suspended until September 9 so that daily watering activities on the remaining installation can be conducted without interruption. ERRS contractors will demobilize for the labor day weekend from September 4-8.

Excavation of sediment was resumed in the retention pond during the week. The excavation is estimated at approximately 80% completion.

START contractors continued daily collection of subsurface air well measurements from August 24-28. On August 25, samples of subsurface air was collected with vacuum cannisters and shipped to a laboratory for analysis. The analysis will provide insight on the components of unspecified "balance" gas. The relative levels of nitrogen and nitrogen oxides as well as other unidentified chemical constituents will help to evaluate whether ambient air is flowing through the subsurface and/or whether air from the smoldering waste is reaching the well.

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
  • Aug 17  Initial cover of Asbestos Cell completed
  • Aug 28  90% of the Asbestos Cell covered with 1 foot of clay
  • Aug 25  Begin installation of vegetative cover on former 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. Final clay cap completed 8/14. (topsoil remains)
 Asbestos Cell  Debris  Approx 19,500 CY  n/a  Regrade & Cover  Initial cover completed 8/17/15. 90% of clay cap completed. 8/28/2015.
           


  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; (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)
2.2.1.2 Next Steps
  • 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 



  2.3 Logistics Section
    Installation of straw matting on landfill face may require mobilization of additional labor personnel to complete.
  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.