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Welch Group Environmental (WGE) Fairplay

All POL/SITREP's for this site Welch Group Environmental (WGE) Fairplay
Fair Play, SC - EPA Region IV
POLREP #7
Site Stabilized, PRP Lead Time Critical Removal Action Pending
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U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Welch Group Environmental (WGE) Fairplay - Removal Polrep

EPA Emergency Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region IV

Subject: POLREP #7
Site Stabilized, PRP Lead Time Critical Removal Action Pending
Welch Group Environmental (WGE) Fairplay
B4F1
Fair Play, SC
Latitude: 34.5233220 Longitude: -82.9913550


To:
From: Leo Francendese, OSC
Date: 4/25/2011
Reporting Period: 4/11 through 4/25

1. Introduction
  1.1 Background
   
Site Number: B4F1    Contract Number:  
D.O. Number:      Action Memo Date:  
Response Authority: CERCLA    Response Type: PRP Oversight
Response Lead: PRP    Incident Category: Removal Action
NPL Status: Non NPL    Operable Unit:
Mobilization Date: 1/31/2011    Start Date: 1/31/2011
Demob Date:      Completion Date:  
CERCLIS ID:    RCRIS ID:
ERNS No.:    State Notification: 1/31/2011
FPN#:    Reimbursable Account #:

1.1.1 Incident Category

Site Description

Welch Group Environmental (WGE) operated a business that recovered lead and other metals (i.e copper) from spent munitions at firing ranges gathered from around the Southeast. They then melted the lead into ingots. 

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 and liquids.

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 commenced n February 8th.  Other removal action may be directed by the OSC as appropriate.

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.

The OSC is waiting to receive the RAWP from the PRP. Once the RAWP has been approved, remediation and removal efforts will commence at the site. The PRP requested an amendment to work at the property on March 15, 2011 to include decontamination of on-site equipment. The OSC approved decontamination of the equipment, however no other work is to be implemented at the site (Work Plan Amendments).

On March 16, 2011, WGE personnel was onsite to decon the bobcat and track-hoe.  The equipment was deconned on top of a poly sheet, as to avoid water runoff from the decontamination area during cleaning. WGE used vinegar, soap and water during the decon procedure. START took preliminary lead readings and screened the bobcat periodically to determine if the decontamination process was successful. Some areas of the bobcat had lower lead levels, whereas other locations were still above 2,000 ppm. The bobcat was moved from the decontamination area so WGE personnel could determine another decontamination method.  Waste generated during the decontamination was bagged, tagged and later placed in a 55-gallon drum.

On March 18, 2011, WGE personnel continued with decontamination of the track-hoe.  START took preliminary lead readings and screened the track-hoe periodically to determine if the decontamination process was successful. Some areas on the equipment were below 2,000 ppm, whereas other areas were above 2,000 ppm, primarily the tracks on the equipment. Waste generated during the decontamination was bagged, tagged and placed in a 55-gallon drum. 

WGE continued with decontamination activities on 3-21-11; however WGE was unable to completely decon the track-hoe.  WGE indicated they would require a professional contractor to complete the remaining decontamination activities.  The latest daily progress report can be viewed at the following link DPR 3-23-11.

No field activities were conducted during this reporting period.

1.1.2.1 Location

Fair Play, SC

1.1.2.2 Description of Threat

Lead is present at high levels in either soils, sediments, uncontained vessels/drums, lead melting process shed, several onsite dump sites, various equipment and brick supplies.  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

The RSE Report has been completed and submitted to the EPA (RSI Report).  See SCDHEC referral package at the documents section of for this site: SC DHEC Referral Letter



2. Current Activities
  2.1 Operations Section
    2.1.2 Response Actions to Date

The site is stabilized. PRP has been given approval to decontaminate certain onsite equipment.  Operation is to be conducted in accordance with HASP and work is followed up with daily DPRs.

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)

Owners and operators have been identified by SCDHEC.  OSC is conducting enforcement in coordination with SCDHEC.  Access agreements (Access Agreement) and Notice of Federal Interest (NOFI) are available on this webpage.  The Agency is currently in negotiations with the PRPs.

CERCLA Cost Recovery and Legal support have been initiated.

  2.2 Planning Section
    2.2.1 Anticipated Activities

High concentrations of either lead dust, waste material, contaminated debris and soils will result in further recommended removal actions as part of the RSE Report due to be complete by 3-4-2011  These actions will be conducted as time critical removal actions under an Administrative Order on Consent.

On 2-17-2011, the OSC requested that the PRP prepare the following plans for WGE Fairplay.
  • 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 in dicussions with the PRP to resolve issues pertaining to the RAWP.  This is being done simultaneously with negotiations for the AOC.

The PRP had requested to decontaminate on-site equipment on March 15, 2011. Only decontamination of the equipment was approved. No other work has been approved on the site (Approved RAWP limited activities).

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.



  2.3 Logistics Section
    No information available at this time.

  2.4 Finance Section
    No information available at this time.

  2.5 Other Command Staff
    No information available at this time.

3. Participating Entities
  No information available at this time.

4. Personnel On Site
  No information available at this time.

5. Definition of Terms
  No information available at this time.

6. Additional sources of information
  No information available at this time.

7. Situational Reference Materials
  No information available at this time.