Pollution/Situation Report Profile

Welch Group Environmental (WGE) Palmetto Hwy
Belton, SC - EPA Region IV
POLREP #5
Remediation Progress

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U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Welch Group Environmental (WGE) Palmetto Hwy - Removal Polrep

EPA Emergency Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region IV

Subject:

POLREP #5
Remediation Progress
Welch Group Environmental (WGE) Palmetto Hwy
B4F6
Belton, SC
Latitude: 34.5228881 Longitude: -82.4942948

To:

From:

Leo Francendese, OSC

Date:

4/11/2011

Reporting Period:

3/21 through 4/11

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 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.

On March 28, 2011, WGE began decontamination of the area between the restroom and the shared pathway designated Area A (Warehouse Decontamination Map). Built containment to contain dust, water and conduct air monitoring activities.

Started decontamination of area between bathroom and shared pathway, washed with vinegar, and scrubbed with wire brush, vacuumed all water and contained in a 55 gallon drum with lead hazard stickers. A tavasco grinder was used on the floor, all dust vacuumed and contained in a contractor bag with lead hazard stickers, and placed into a 55 gallon drum. The floor was washed with vinegar to complete decontamination procedures.
Workers wore level C personal protective equipment and a HEPA vacuum was used to contain the dust from grinding.

On March 31, 2011 through April 1, 2011, WGE marked 2 ft by 2 ft grids and conducted XRF readings. START collected confirmation XRF readings. Any readings above 400 ppm were additionally decontaminated and re-screened. All areas in Area A were decontaminated to below 400 ppm (Warehouse Decontamination Map).

On April 4, 2011, WGE began decontamination of designated Area B (Warehouse Decontamination Map). WGE began decontamination of the walls, steel beams and ceiling. START collected confirmation XRF readings. Readings were above 400 ppm. As such START conducted wipe sampling at several locations. The locations were below 400 ppm. Contractor Daily Progress Reports (DPRs) can be found in the documents section. Here is a link for April 1, 2011: DPR 4-8-11. WGE will continue with decontamination activities.

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 floor path area (loading docks and walk paths).
3. START conducted oversight of the decontamination process and conducted confirmation screening of the PRP's contractor data in the area designated Area A (Warehouse Decontamination Map).

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