|
1. Introduction
|
|
|
1.1 Background
|
|
|
|
|
Site Number: |
B4F6 |
|
Contract Number: |
|
|
D.O. Number: |
|
|
Action Memo Date: |
|
|
Response Authority: |
CERCLA |
|
Response Type: |
PRP Oversight |
|
Response Lead: |
EPA |
|
Incident Category: |
Removal Action |
|
NPL Status: |
Non NPL |
|
Operable Unit: |
|
|
Mobilization Date: |
|
|
Start Date: |
2/7/2011 |
|
Demob Date: |
|
|
Completion Date: |
|
|
CERCLIS ID: |
|
|
RCRIS ID: |
|
|
ERNS No.: |
|
|
State Notification: |
|
|
FPN#: |
|
|
Reimbursable Account #: |
|
1.1.1 Incident Category
PRP Lead Emergency Response with EPA Oversight
1.1.2 Site Description
This site is part of the Welch Group Environmental (WGE) CERCLA response. SCDHEC referred WGE operations to ERRB in late December after informing the operator to cease operations.
WGE is a metals recovery company that recovers lead slugs and shell casings from gun ranges. The WGE Palmetto Hwy site was part of WGE's operations and served as storage. This is a mutli-use warehouse that serves other clients.
As part of a continuing removal site evaluation (RSE), the OSC was notified by SCDHEC on February 4th that additional operations had occurred at Palmetto Hwy. After securing access from the warehouse owner and WGE's operator, the OSC conducted a site walk on February 7th.
WGE no longer stores property at this location. XRF readings for lead ranged from the low hundreds to 35,000 ppm on the floors and walls of the area where WGE stored property.
The OSC had determined that a release or substantial threat of release of a hazardous substance has occurred and presents an imminent and substantial danger to public health.
The OSC has directed the operator to remediate the contaminated section of the warehouse. Workplans will be submitted and become part of the Fair Play and Belton responses. The OSC will continue to consult and coordinate with SCDHEC and EPA R4 RCRA.
The RSE for the WGE properties is expected to be complete by the end of February. Further recommendations will be made at that time.
Currently the OSC is waiting to receive the RAWP from the PRP. Once the RAWP has been approved, remediation and removal efforts can continue at the site. Due to the impending RAWP, there was no work conducted at the site for the week of 3/6/2011. The week of 3/6/2011, the PRP had WGE employees HAZWOPER trained in an effort to reduce PRP cost of hiring a contractor.
The PRP amendment to continue remediation efforts was approved on March 19, 2011 (Approved Workplan Amendments).
1.1.2.1 Location
Belton, SC
1.1.2.2 Description of Threat
A release or substantial threat of release of a hazardous substance to the environment has occurred (lead). The release exists at high concentrations at or near the surface that present an imminent and substantial threat to public or welfare.
1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
This site was discovered during a SCDHEC requested RSE at two other WGE facilities, Fair Play and Belton.
|
|
2. Current Activities
|
|
|
2.1 Operations Section
|
|
|
|
2.1.2 Response Actions to Date
WGE has submitted requested change in contractor. Memo can be found here: Contractor Change Document
From February 28 to March 1, 2011, restricted areas were barricaded in the warehouse. Floors in these areas were covered with paper flooring to prevent dust migration. These restricted areas were decontaminated for lead using Trisodium phosphate (1/2 cup per 1-gallon of water). The floors were scrubbed using wire brushes. XRF screenings were conducted after each area was scrubbed.
At the north end of the warehouse, a sealent prevented decontamination on the flooring. Grinding away two think layers of concrete were necessary to sufficiently decontaminate the area. Additional barricades were constructed to prevent spreading dust generated during grinding. Workers wore level C personal protective equipment and a HEPA vacuum was used to contain the dust from grinding.
During decontamination, ambient air monitoring was performed with GilAir sampling pumps. Filters are being analyzed for lead. In addition, waste waters generated during decontamination are stored in 55-gallon drums and labeled appropriately for future disposal.
XRF screening levels for lead below 400 ppm are considered decontaminated. START and PRP contractors conducted XRF screenings. After completing decontamination, cleaned areas were sealed with poly to prevent future contamination.
Contractor Daily Progress Reports (DPRs) can be found in the documents section. Here is a link for March 4, 2011: DPR 3-4-11
The following environmental actions have been completed:
1. START conducted daily visual inspection of the paper/plastic floor covering and barricades for integrity purposes.
2. START conducted oversight of the decontamination process and conducted confirmation screening of the PRP's contractor data during the screening of the barricaded area.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
An Access Agreement has been secured and NOFI CERCLA Cost Recovery and Legal support have been initiated.
|
|
|
2.2 Planning Section
|
|
|
|
2.2.1.1 Planned Response Activities
PRP submitted additional work plan and Schedule Revision for remainder of the affected warehouse as part of the upcoming time critical removal action Administrative Order on Consent.
2.2.2 Issues
The OSC continues to coordinate and consult with SCDHEC as well as the EPA R4 RCRA Program.
RCRA is being consulted with to assure that WGE's offsite collection operations are compliant with necessary federal requirements.
|
|
|
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
|
|
|
1 EPA
1 START
|
|
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.
|
