Pollution/Situation Report Profile

Welch Group Environmental (WGE) Fairplay
Fair Play, SC - EPA Region IV
POLREP #25
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 #25
Progress
Welch Group Environmental (WGE) Fairplay
B4F1
Fair Play, SC
Latitude: 34.5233220 Longitude: -82.9913550

To:

From:

Greg Harper, OSC

Date:

6/8/2016

Reporting Period:

July 11, 2015 through April 18, 2016

1. Introduction

1.1 Background

Site Number:	B4F1	Contract Number:
D.O. Number:		Action Memo Date:	3/23/2011
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 the distribution of recycled material. In addition, several hundred drums of 'salt formations' were present in drums which are in various deteriorated 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 curtains and hay bales where appropriate.

The PRPs hired a qualified contractor. The qualified contractor's Health and Safety as well as Removal Action Workplans (RAWPs) have been submitted and approved by the OSC in consultation 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 commenced at the site. The PRP requested an amendment to the planned work, 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 and the WGE Fair Play Site.

On March 16, 2016, the EPA met on site with WGE. The meeting was scheduled in order to transfer OSC duties from OSC (Greg Harper) to OSC (Jordan Garrard). WGE was informed of the change and any further site approvals will be reviewed by OSC Jordan Garrard.

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. Current Activities

2.1 Operations Section

2.1.2 Response Actions to Date

In October 2012, twenty 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 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.

After WGE completed the decontamination process of the block building and performed XRF screening of a specified grid (2 foot by 2 foot) overlay of the floor and walls. On September 18, 2014, START accompanied the EPA OSC to the site. START screened the on-site block building, floor and walls, using pre-determined grid. START screened selective sections from the floor and each of the walls following WGE previously established grid. The screening was to verify WGE screening data of all established grids.
On February, 18, 2015, a total of 8, 55-gallon drums of lead waste were transported off site and were received by Chemical Waste Management at Emelle, AL for disposal on February 19, 2015.
June 4 through June 8, 2015 a total of 13 dump truck loads of non-hazardous soils were transported off site. A total of 259.79 tons of non-hazardous soils were disposed at the Republic Services, Upstate Regional MSW Landfill in Enoree, SC.
Since the disposal of the non-hazardous soil On June 8, 2016, WEG has excavated the remainder of the soil contamination on site. Two stock piles were created one hazardous soil and the other non-hazardous.
On October 22, 2015 WEG informed the EPA their sister company declared bankruptcy, this company employed the removal staff conducting the clean-up activities at Fair Play. The owner assured EPA the clean-up would be completed. He requested time to reorganize and work with the property owner to complete the clean-up. The owner was given until February 28, 2016 to complete the site clean-up.
March 16, 2106 EPA changed the OSC for the site. On March 16, 2016, the EPA met on site with the owner of WGE. The meeting was scheduled in order to transfer OSC duties from OSC (Greg Harper) to OSC (Jordan Garrard). WGE was informed of the change and any further site approvals will be reviewed by OSC Jordan Garrard.

2.2 Planning Section

2.2.1 Anticipated Activities

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

Complete the disposal of the excavation of lead contaminated soils from the site;
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 and;
Sample the 30 yard roll-off box before a disposal and dispose the 30yard roll-off box

2.2.2 Issues

WGE is currently conducting the removal action at Fair Play location. In accordance with the AOC WGE can complete the work at the three site in sequence: the Palmetto, SC site, Fair Play site and then the Belton site.

According to the owner of Welch Group Environmental (WGE), its sister company which has generated the money to pay for the removal operations and employed the removal manager and crew declared bankruptcy. The owner said he would continue to pay for removal action. The EPA attorney is involved with the lastest issue.

In a meeting with WEG on March 16, 2016, WGE was informed of an OSC change to OSC Jordan Garrard change and any further site approvals will be reviewed by OSC Jordan Garrard.

2.3 Logistics Section