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 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. WGE remediation and removal efforts have 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 which was approved by the OSC.

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. This removal action time line was delayed due to the clean-up activities at the WGE Palmetto Site.  

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 soils, 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.

2.1.2 Response Actions to Date

WGE continues screening, decontaminating and removing the masonry block from the contaminated area of the site. The decontaminated masonry block has been placed in a designated lay-down area in a clean portion of the property. They have moved three of the six box trailers from the contaminated area. Also, WGE has cleared the other debris, broken block, wood and plastic from the contaminated area and placed it in a 30 yard roll-off.

On June 18, 2012 WGE began to clean the content of the trailer open to the building where the lead melting operation was located. The trailer contains approximately 500 boxes of plastic “super screws.” WGE’s industrial hygienist was on-site and collected a total of seven air samples; three perimeter air samples, three worker air samples and one air sample outside the building. Results are anticipated the week of July 2.

2.2.1 Anticipated Activities

WGE will continue to identify and segregate on-site waste into the different waste streams identified in the Waste Characterization Plan. They will collect a waste sample from the 30 yard roll-off box and complete a waste profile for disposal.

WGE will identify a facility to receive hazardous waste from the site. EPA will approve all facilities before waste in transported from the site.

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

• Decontamination/Demolition Plan for remaining debris and structures exceeding the lead cleanup criteria.
• Soils Removal and Disposal Plan for soils exceeding the cleanup criteria.