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 has placed decontaminated materials in designated lay-down area in a clean portion of the property. Three of the six box trailers have been moved from the contaminated area. WGE prepared 48 drums of lead waste, placed them onto pallets and collected a waste sample for off-site disposal. The analytical results were lead of 2,720 mg/L and copper of 0.04 mg/L. WGE has shipped most of the drummed waste off-site for disposal. WGE has decontaminated or removed most of the miscellaneous items from the contaminated area of the site. WGE continues to decontaminate the on-site block building. First by using a pneumatic nettle chisel to remove lead splatter from the concrete block caused by the lead melting operation. The lead waste generated the building decontamination process was drummed with the lead other waste. The remaining drums of lead waste have been prepared for shipment off-site for disposal. Once the gross lead contamination was removed from the block walls, WGE used a dilute muriatic acid rinse to remove the remaining lead dust from the concrete block walls and concrete floor inside the building. The dilute muriatic acid was collected and reused or stored for sampling and disposal.   

• In October 2012, 20-55 gallon drums of lead contaminated waste were transported off site and received by Chemical Waste Management in Emelle, AL.
• January 17, 2013, 11 cubic yard boxes of lead contaminated waste were transported off site and received by Chemical Waste Management in Emelle, AL on January 18, 2013.
• During the week of April 15, 2013, WGE collected XRF soil samples from grid AF-7, an area south of the block building outside the previously sampled areas. WGE identified an area approximately 20 feet by 30 feet with lead contaminated soils. The area was excavated and the contaminated soil was stockpiled near the block building and will be addressed during the soil clean-up phase of the project.
• April 22, 2013, 24 -55 gallon drums of lead waste and 10 cubic yard boxes of lead contaminated items were transported off site and were received by Chemical Waste Management at Emelle, AL for disposal on April 23, 2013.
• WGE has transferred the lead waste from drums that were in poor condition into new drums that can be shipped off site for disposal.  
• On September 30, 2013, 26 cubic yard boxes of cubic yard boxes of lead contaminated waste were transported off site and received by Chemical Waste Management in Emelle, AL on October 1, 2013.
• On March 11, 2014, a 30 yard roll-off box that had been filled, during earlier onsite clean-up operations, with miscellaneous contaminated site waste (wood, plastic, block, metals, glass and other items) and used personal protective equipment (PPE). The 30 yard roll-off was received by Chemical Waste Management in Emelle, AL on March 12, 2014.

2.2.1 Anticipated Activities

The remaining items and activities WGE has to complete at the Fair Play site are as follows:

• Complete the decontamination of the block building
• Move two box trailers and container box from the contaminated soil area
• Ship the remaining drums of lead waste off site for disposal
• Identify a disposal facility for the oily water and oily waste drums
• Continue to identify and segregate on-site waste according to the waste streams identified in the Waste Characterization Plan and place the miscellaneous waste (wood, plastic, block, metals and glass) into the on-site thirty yard roll-off
• Sample the 30 yard roll-off box before a disposal