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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 |
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D.O. Number: |
0134 |
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Action Memo Date: |
4/30/2015 |
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Response Authority: |
CERCLA |
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Response Type: |
Time-Critical |
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Response Lead: |
EPA |
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Incident Category: |
Removal Action |
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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 |
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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 |
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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
Installation of topsoil on the landfill face (former burn area) was completed on October 19. Seed and fertilization spreading was completed by October 20. Installation of straw matting and erosion control devices were completed on October 22; the erosion control devices consist of 12-inch-diameter logs of bound coconut fibers (i.e. "coir logs") each 10-feet long and staked to the ground in long lines perpendicular to the slope at approximately a 50-foot spacing for each line.
A 3-foot berm at the top of the landfill face was completed to redirect storm water from the top of the landfill to areas which already contain heavy vegetation and prevent excessive water flow over the newly installed landfill face. Installation of clay on top of the landfill has resumed and will be completed with a 2-foot depth in the uppermost areas then at least 1-foot in areas which already contain a sandy cover material.
One of the air monitoring wells was closed and removed on October 17. The remaining three wells were closed and removed on October 19. Closure consisted of filling the well with 1.5 bags of bentonite clay. The soil surrounding the well was then dug out and the well was cut off below the ground surface and backfilled. Coordinates for each well have been recorded in the event that they need to be relocated.
At OSC Huyser's request, South Carolina DHEC removed the last remaining offsite particulate air monitoring station on October 21.
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 29 Final cover of Asbestos Cell completed
- Aug 25 Begin installation of topsoil on former burn area
- Aug 29 Begin installation of vegetative cover on former burn area
- Aug 29 Complete stormwater protection measures on detention pond.
- Aug 31 Begin grading northeast debris cell
- Sep 17 Complete initial 12-inch soil layer on northeast debris cell
- Sep 18 Complete construction of dams above retention pond and in west stormwater channel
- Sep 25 Clay capping of North Debris Cell 50% complete
- Sep 28 Temporary demobilization due to weather and ground conditions
- Oct 07 ERRS contractors remobed after significant rain event and flooding in South Carolina
- Oct 17 60 percent of landfill face covered with topsoil, seeded and fertilized.
- Oct 19 Landfill face covered with topsoil
- Oct 22 Landfill face covered with seed, fertilizer, straw matting, and erosion control devices
- Oct 21 Berm at top of landfill face completed to redirect storm water from top
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 completed 10/19. Erosion Control completed 10/22 |
| Asbestos Cell |
Debris |
Approx 19,500 CY |
n/a |
Regrade & Cover |
Initial cover completed 8/17/15. Final clay cap completed 8/29/2015. Vegetation installed 9/23 |
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2.2 Planning Section
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2.2.1 Anticipated Activities
The first priority of the removal action has been 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 has been to address the eroding asbestos disposal cell by re-grading and covering the area.
Air sampling and monitoring activities have been completed.
The disturbed areas of the Site will be secured with vegetation to provide a stable erosion-resistant surface. Total project time has been updated to approximately 5 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; (COMPLETE)
- Re-grading waste materials and native soils for purpose of cover installation; (COMPLETE)
- 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. (COMPLETE)
2.2.1.2 Next Steps
- Complete initial and final clay cover on landfill top, then vegetate
- Repair channel dams with riprap
- Vegetate all remaining exposed areas
- Water until vegetation established
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2.3 Logistics Section
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Any equipment or personnel will be demobilized when no longer needed.
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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 inspected the Site and confirmed that no unacceptable forest fire hazard is present.
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 (11)
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
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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