2.1.1 Narrative

ERRS crews worked through December 5 and December 6 to finish final grading on the silt slope at the south west corner of the Site. Seed and fertilizer was installed on the soil. Straw matting was installed on the slope from the toe of the landfill face down to the detention pond. Three lines of coir logs were installed perpendicular to the slope at a spacing of approximately 50-feet between each line. From December 7 to December 9, 8-10" rip-rap was placed on the slope between the lower coir log and the detention pond. A run of stone approximately 10-feet wide was also placed in the shallow channel between the slope and the access road.

Approximately 10 or more tons of sediment which had built up in front of the pre-detention dam was excavated and moved to an area where it could dry and would not impact any structures. Additional stone was placed in front of the inlets to pipes within the dam and eroded soil near the outlet of the pipes was repaired.

Sediment was excavated from west channel between the asbestos disposal cell and the border of the site; that sediment was placed and packed at the top of the channel where it will be able to dry without eroding. The channel was re-lined with rip-rap covering an area approximately 25 feet wide and 40 feet long.

The access road on the north side of the disposal cell was sloped to divert storm water away from areas containing wastes and prevent channeling between the road and the cell. The access road between the main waste disposal cell and the asbetos cell was also graded to divert storm water away from the steeper slope leading to the toe of the landfill face and towards the shallower slope of the asbestos cell.

Two diversion berms were completed on the north side of the site. The area was seeded, the berms were covered with straw matting, the north side of the Site was covered with straw, and several tons of 2" stone were placed in front of the berms.

Boulders were staged near the front entrance to be used as vehicle barriers at the end of the project. OSC Huyser spoke with the regional SC DHEC representatives to confirm that this level of restricted access was acceptable. DHEC provided positive feedback and were confident that they would be able to continue to conduct inspections without driving onto the Site but would walk around the barriers.

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
• Nov 2-12 Temporary demobilization due to weather and ground conditions
• Nov 18 Landfill top soil cap completed
• Nov 18 Landfill top covered with seed, fertilizer, and straw
• Dec 4 Complete diversion berm on silt slope under southwest toe of Landfill face
• Dec 9 Complete vegetation and erosion controls on silt slope
• Dec 9 Complete diversion berms and vegetation on north side of asbestos cell
• Dec 9 Complete erosion controls and vegetation on west channel

• Isolation of burning material by removal and relocation of available fuel path and installation of earthen cover; (COMPLETE)
• 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

1. Repair channel dams with riprap
2. Vegetate all remaining exposed areas

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

3.1 Participating Entity Activities

During the course of the removal action, three steel 55-gal drums containing oil materials were found and staged on-Site. Two were closed-top steel drums containing used hydraulic oil (one was 100% full and the second was approximately 30% full); the third drum was an open-top steel drum containing diesel fuel (approximately 30% full). Each of the drums appeared to also contain some amount of water and grit or dirt.

Limits in the scope of the action memorandum for this removal action prevented off-site disposal of the drums. SCDHEC contacted the Chester County waste oil recycling program and the drums were retrieved by a Chester County crew on December 10. Much of the oil collected through these programs is processed for fuels blending. The oil will likely be "recycled" as a supplemental fuel source to the Santee Cooper Winyah Generating Station.

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.