Site Number: |
B4F1 |
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Contract Number: |
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D.O. Number: |
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Action Memo Date: |
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Response Authority: |
CERCLA |
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Response Type: |
PRP Oversight |
Response Lead: |
PRP |
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Incident Category: |
Removal Action |
NPL Status: |
Non NPL |
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Operable Unit: |
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Mobilization Date: |
1/31/2011 |
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Start Date: |
1/31/2011 |
Demob Date: |
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Completion Date: |
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CERCLIS ID: |
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RCRIS ID: |
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ERNS No.: |
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State Notification: |
1/31/2011 |
FPN#: |
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Reimbursable Account #: |
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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 on 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.
The AOC was finalized and transmitted on May 12, 2011 (AOC).
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
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