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Site Number: |
A4DD |
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Contract Number: |
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D.O. Number: |
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Action Memo Date: |
9/13/2011 |
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Response Authority: |
CERCLA |
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Response Type: |
Time-Critical |
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Response Lead: |
EPA |
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Incident Category: |
Removal Action |
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NPL Status: |
NPL |
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Operable Unit: |
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Mobilization Date: |
8/9/2011 |
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Start Date: |
8/9/2011 |
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Demob Date: |
4/3/2012 |
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Completion Date: |
4/3/2012 |
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CERCLIS ID: |
SCD003358744 |
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RCRIS ID: |
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ERNS No.: |
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State Notification: |
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FPN#: |
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Reimbursable Account #: |
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1.1.1 Incident Category
Inactive Production Facility (former textile mill).
1.1.2 Site Description
The former US Finishing/Cone Mills site is located at 3555 Old Buncombe Road approximately 3 miles north of downtown Greenville, SC. This facility operated as a textile mill until November 2003 when the main plant was partially destroyed by fire. American Fast Print is the current property owner of a large portion of the 256 acre facility. In July 2004, Piper Properties purchased approximately 19 acres of the 256 acre property along a section of the Reedy River. The property associated with the site is currently in temporary receivership as part of a bankruptcy proceeding.
The US Finishing/Cone Mills site was referred to the Removal Program by the Remedial Program. For a chronological summary of environmental enforcement associated with this site please see the previous POLREPs.
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2.1.1 Narrative
2.1.2 Response Actions to Date
The fire which occurred in 2003 destroyed approximately 130,000 square feet of the 400,000 square foot factory and warehouse. Asbestos insulation was present throughout the debris associated with the damaged portion of the factory. WRSCompass, the ERRS contractor for EPA, was tasked to segregate the debris so that the debris could be managed in a cost effective manner. The debris was segregated into three primary waste streams: asbestos wrapped pipping, steel beams, and miscellaneous debris.
Prior to commencement of removing the building damaged by the fire,
a thorough walk through and evaluation of the building was conducted to confirm
that the area was
ready for commencement of the removal activities. Pre-Demolition Surveys were
completed to identify potential waste streams and the surveys maintained on site.
In general, the tasks included a variety
of procedures. The most important aspect in the development of these procedures
was the safe conduct of the work. The warehouse, whose structural integrity was compromised by the fire, was condemned by the city. WRS' procedures limited the use of labor to
the most controlled and safe conditions and relied upon mechanized means of
removal wherever possible. 80,000 lb. excavators equipped with concrete
breakers/processor, grapples, and other modern hydraulic demolition tools and
attachments were utilized to remove and segregate the debri piles. Wherever possible, large structures were removed to
ground level using mechanized means. Subsequent sizing of scrap materials such
as steel and rebar and other material processing activities took place at grade level.
The steel beams and other ferrous metals were recycled at a local metal scrap yard. The miscellaneous debris which contained Presumed Asbestos Containing Material (PACM) associated with the roofing material and small pieces of asbestos not removed with the asbestos wrapped pipping, was loaded into 20 yard dump trucks and transported to two large waste cells on site. The two waste cells were previously selected for PACM waste disposal and designated as P-1 and P-2. A Closure Plan outlining the construction for the waste cells was generated prior to the work and a copy of the Closure Plan was submitted to the state.
Visible small of pieces asbestos were saturated with a
wetting agent and then double bagged in asbestos labeled bags or wrapped in
plastic and temporarily staged on site. This material was later combined with the asbestos material associated with the Power Plant building (see discussion below) and shipped to an off site landfill for disposal.
The former Power Plant building contained a high concentration of asbestos wrapped pipping. While the fire compromised the warehouse's ability to contain the asbestos, the structural integrity of the Power Plant was not compromised by the fire. Therefore an asbestos abatement was planned for the Power Plant building. An
Asbestos abatement plan was completed by Soil & Material Engineers
(S&ME) and submitted to SCDHEC for review and approval of an asbestos abatement action for the former Power Plant building. S&ME also performed the air
monitoring and clearance monitoring during the abatement process. Following a competitive bidding process, Winter Environmental was hired to perform an asbestos abatement within the Power Plant building. The asbestos material removed during the abatement by Winter Environmental was combined with the asbestos material collected by WRSCompass and sent to a subtitle D regulated landfill for disposal.
Air quality during the removal action was monitored within the work zone (hot zone) and at the perimeter of the property. The perimeter air quality was monitored 24 hours a day for particulates by Ebam units surrounding the periphery of the site. This data was also supplemented through the collection of air samples collected during work hours and the samples submitted to the laboratory for asbestos and lead anaylsis.The results of the perimeter air monitoring indicated that OSHA action levels for particulates, lead and asbestos were not exceeded during the removal activities. Dust control during demolition activities were performed though spraying the work areas with water from fire suppression type spray hoses connected to water trucks. This dust control method was a key factor in keeping airborne dust that potentially contained asbestos below the action levels set for the site.
The qualitative data (particulates data) from the Ebam units was uplinked to the website at http://usfinishing-conemills.com for public viewing. Laboratory data for lead and asbestos analysis was also published on the website to provide qualitative data associated with the quantitative data collected from the Ebam units. This combined information provided the viewers with the volume of airborne particulates and the presence or absence of airborne lead and asbestos. Two web cameras were used to stream video of the removal activities to the website for public viewing.
The investigation derived waste left on site from previous investigations (27 count 55-gallon drums) was characterized for disposal purposes and shipped off site for disposal. Several small (5 through 20 gallon) plastic containers were present in buildings throughout the site. Several of these containers contained unknown liquid substances. These liquids were sampled for characterization and disposal purposes. Seven switches (metal housing units between 2-6 feet in length) containing mercury were discovered in the water treatment building. The mercury was collected from these units and shipped off site for recycling.
The WRSCompass crew pressure washed the concrete slab and the asphalt roadways. The grounds were seeded and covered with straw for erosion control purposes prior to demobilization.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
EPA's cost recovery group is evaluating multiple PRPs associated with this site. They are also evaluating the status of the Cone Mills Corporation following their bankruptcy in addition to evaluating the existence of insurance policies during ownership and operations periods for the respective PRPs.
2.1.4 Progress Metrics
The asbestos associated with the asbestos wrapped pipping and the asbestos abatement was sent to both the Safeguard Landfill Management, 6895 Roosevelt Highway, Fairburn, GA., and the Palmetto Landfill & RC, 251 New Hope Road, Wellford, SC.
| Waste Stream |
Medium |
Quantity |
Manifest # |
Treatment |
Disposal |
| Scrap Iron |
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11,004 tons |
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Recycling |
| PACM debris |
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18,702 cubic yards |
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On-Site Waste Cell |
| Asbestos |
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51.15 tons |
#1-#8 |
Bagged |
Safeguard Landfill and Palmetto Landfill |
| Solids:non-haz
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215 lbs |
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Palmetto Landfill |
| Liquid:non-haz |
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110 gallons |
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Solidified |
Palmetto Landfill |
| Liquid:flamable |
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885 gallons |
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Fuel blend |
EcoFlo, Greensboro, NC |
| Solid:non-haz |
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1840 pounds |
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None |
Uwharrie, Mt.Gilead, NC |
| Liquid:non-haz |
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445 gallons |
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Solidified |
Uwharrie, Mt. Gilead, NC |
| Liquid:Hg |
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20 pounds |
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Recycled |
Ecoflo, Greensboro, NC |
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