The WGE Belton site conducted material separation as well as distribution of recycled material. In addition, several hundred drums of 'salt formations' are present in drums which are in various conditions. 

The WGE Fair Play site conducted material separation as well as melting activities and also has up to 50 drums of uncontained process material.

Both site operations were conducted without South Carolina Department of Health and Environmental Control (SCDHEC) permits. SCDHEC documents that up to 10 WGE employees had significantly high lead levels.  SCDHEC ordered the cessation of operations on December 2, 2010.  SCDHEC referred the sites to EPA R4 ERRB for removal site evaluation (RSE) on December 22, 2010.

The EPA On Scene Coordinator (OSC) began the removal site inspection during the week of January 31st, 2011 and is coordinating enforcement efforts with SCDHEC using CERCLA response authority.  In coordination with Air, Waste and Land Management, Site Evaluation, and Region 1 programs at SCDHEC, the OSC has directed the potentially responsible parties (PRPs) to secure the locations, contain and secure open vessels/drums and construct a sediment/soil containment measure such as silt curtain and hay bales where appropriate.

The PRPs have hired a qualified contractor.  Both Health and Safety as well as Removal Action Workplans have been submitted and approved by the OSC in consult with SCDHEC.  Work will commence on February 8th.  Other removal action may be directed by the OSC as appropriate.

The RSE Report is expected to be complete by the end of February with a subsequent recommendation for further action.  The OSC will continue to coordinate enforcement activities with SCDHEC.  In addition, the OSC is coordinating with EPA R4 RCRA to assure that WGE proposed gun range recovery activities meet with applicable federal RCRA standards. 

On Friday, March 4th, the clean up crew, oversight contractor and START traveled to the site for the clean up crew to conduct a test decon on a piece of equipment. The test was done utilizing vinegar as a decontaminating agent to aid in dissolving the lead. The test showed to be effective and the PRP authored documentation for submittal to the OSC to implement the method on other WGE equipment.

The PRP's contractor submitted the site RAWP on March 5, 2011, and after the OSC's review, the RAWP was approved on March 8th. Due to impending approval of the RAWP, there was no work conducted at the site for the week.

The week of March 6th, the PRP had WGE employees HAZWOPER trained in an effort to reduce PRP cost of hiring a contractor.

On the morning of March 14th, work began at the site with WGE employees decontaminating a piece of equipment primarily used to separate bullets from lead dust and range debris. XRF readings were collected from several locations on the piece of equipment. In areas where the paint had been removed and decontaminated, the reading was under 2,000 ppm. In other areas, the readings were approximately 4,000 ppm. WGE purchased a solvent to dissolve the paint on the piece of equipment and completed removal from half of the equipment. XRF readings were also collected from an additional piece of equipment decontaminated by WGE employees. With exception to a small piece of insulation material on the item, the equipment had lead readings under 1,000 ppm. 

Equipment decontamination continued on 3/15/11 and 3/16, WGE removed the paint from the vibratory screen. Personnel used paint-removing solvent to remove the paint from the screen. The screen was broken down into three pieces. START collected lead readings from the equipment; however the readings were not below 2,000 ppm. WGE personnel purchased Nansulate®, a clear sealant to apply to the pieces of the vibratory screen.

On March 17, 2011, START collected wipe samples of the pieces of the vibratory screen. Sampling was conducted by SESD Wipe (Contaminated Surface) Sampling method 304-R1. Wipe samples were screened with an XRF to determine lead content present on the sample. Locations of the equipment that were screened that were above 400 ppm received an additional coat of sealant, left to dry and wipe sampled again. The equipment received clearance at the end of the day. WGE submitted a vibratory screen cross contamination plan detailing decontamination procedures after future use. The latest daily progress report can be viewed at the following link (DPR 3-17-11).

During this reporting period no site activities were conducted.  The site is awaiting the final RAWP documents form WGE while the AOC is being negotiated.

1.1.2.1 Location

Anderson, SC

1.1.2.2 Description of Threat

Lead is present at high levels in either soils, sediments, uncontained vessels/drums (approx 12), various equipment and facility floors.  These high levels exist at concentrations that are an imminent and substantial threat to public health or welfare.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

RSE has been completed (RSI Report). See SCDHEC referral package at the documents section of for this site.

• Waste Characterization Plan (re. sampling) in order to gather the necessary information for an eventual Disposal/Recycling Options Analysis.
• Decontamination/Demolition Plan for remaining debris and structures exceeding the lead cleanup criteria.
• Soils Removal and Disposal Plan for soils exceeding the cleanup criteria.

The OSC is currently reviewing the RAWP with the PRP while the negotiations for the AOC continue.

2.2.2 Issues

The OSC is coordinating with both SCDHEC and EPA R4 RCRA concerning the proposed continued gun range metals recovery operations of WGE.  The current WGE proposal is to conduct all materials separation at the gun ranges.  The intent is to assure Federal RCRA compliance before WGE continues with its current business model.

WGE is currently under an OSHA investigation for past melting and recovery operations.