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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 #14
Progress
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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 #14
Progress
Welch Group Environmental (WGE) Fairplay
B4F1
Fair Play, SC
Latitude: 34.5233220 Longitude: -82.9913550


To:
From: Greg Harper, OSC
Date: 2/16/2012
Reporting Period: 1/01/2012 through 2/15/2012

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. The recovered materials were gathered from around the Southeast. WGE 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. The WGE Fair Play site 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 documented that up to 10 WGE employees had significantly high lead levels. SCDHEC ordered the cessation of operations on December 12, 2010. SCDHEC referred the sites to EPA R4 Emergency Response and Removal Branch (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 31, 2011 and coordinated 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 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. The qualified contractor Health and Safety as well as Removal Action Workplans (RAWPs) have been submitted and approved by the OSC in consult with SCDHEC. The initial stabilization work commenced on February 8, 2011.

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 Resource Conservation and Recovery Act (RCRA) standards.

WGE has decided to conduct removal operation without the assistance of a contractor. The OSC has received the RAWP from the PRP. Once the WGE site Health and Safety Plan is 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(Work Plan Amendments), however no other work is to be implemented at the site

The Administrative Order on Consent (AOC) was finalized and transmitted on May 12, 2011 (AOC).

On June 27, 2011, EPA sent a memorandum to WGE, the subject was “Schedule Milestones for the Time Critical Removal Action at the Welch Group Environmental (WGE) Fairplay Site, Anderson County, South Carolina” establishing a removal action timeline.

1.1.2.1 Location

The site is located at 170 Feltmen Farm Road in Fair Play, Oconee County, South Carolina.

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.


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

The site is stabilized. PRP has been given approval to begin the removal actions.  Operation is to be conducted in accordance with Health and Safety Plan (HASP) and work is followed up with weekly progress reports.

WGE requested permission to remove a semi-truck located on site. Wipe samples were collected by WGE from the truck and sampled using the XRF. The samples were verified by OTIE START. Approval to remove the semi-truck from the site was given on January 16, 2012.

On January 31, 2012, WGE and the OSC met to review the final comments on the site HASP. The site HASP was approved on February 7, 2012. Following the approval of the HASP, WGE began to screen and segregate bulk waste material on site to determine need for off-site disposal in accordance with the site Waste Management Plan.

On February 14, 2012, the EPA OSC and WGE met to determine next steps and plan for the upcoming removal and excavation of contaminated soil.

  2.2 Planning Section
    2.2.1 Anticipated Activities

As part of the Administrative Order on Consent (AOC), the OSC requested the PRP prepare the following plans for WGE Fair Play 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.

WGE will identify and segregate on-site waste into the different waste streams identified in the Waste Characterization Plan.

EPA, OTIE START, and WGE will conduct an extent of soil contamination the week of February 21, 2012.


  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
  Welch Environmental Group - 1

EPA - 1

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.