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Flex-A-Form Drum Site

All POL/SITREP's for this site Flex-A-Form Drum Site
Anderson, SC - EPA Region IV
POLREP #3
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U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Flex-A-Form Drum Site - Removal Polrep

EPA Emergency Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region IV

Subject: POLREP #3
Flex-A-Form Drum Site
B4K2
Anderson, SC
Latitude: 34.5901430 Longitude: -82.6698200


To:
From: Jeffery Crowley, On Scene Coordinator
Date: 7/11/2011
Reporting Period: 6/25/11 - 7/1/11

1. Introduction
  1.1 Background
   
Site Number: B4K2    Contract Number: EP-S4-07-04
D.O. Number: 130    Action Memo Date: 6/30/2011
Response Authority: CERCLA    Response Type: Time-Critical
Response Lead: EPA    Incident Category: Removal Action
NPL Status: Non NPL    Operable Unit:
Mobilization Date: 6/22/2011    Start Date: 6/22/2011
Demob Date:      Completion Date:  
CERCLIS ID: SCD987673458    RCRIS ID:
ERNS No.:    State Notification: 6/21/11
FPN#:    Reimbursable Account #:


1.1.1 Incident Category

Inactive Production Facility

1.1.2 Site Description

1.1.2.1 Location

Site is located at 2060 Frontage Road in Anderson, SC. It is highly visible from Interstate 85 as it is located only 30-40 feet from it. The Site is bordered to the West by I-85, to the north and south by two unnamed creeks and to the East by Lake Hartwell. Approximate Site acreage is 4 acres. There is a resident who lives just to the north of the facility and their driveway comes out right at the Site. The Site consists of three buildings and one transport trailer. The main warehouse building has many holes in the roof and in the foundation. The main lab chemical storage building has no doors and is open to the elements.

1.1.2.2 Description of Threat

The Site poses a threat from the improper storage of high levels of hazardous materials and oils. Upon initial recon the OSC observed approximately 100 - 200 drums, totes, buckets, and other containers of materials with labels ranging from acids to cyanides. Also located on Site is what appears to be a former laboratory area where there are hundreds of lab chemicals including picric acid and isopropyl ether.

In addition to the drums and lab chemicals, there is also several runoff pathways of dead vegetation leading to the creeks. Two of the pathways appear to be stained with oil and animal fats (the owner was making biodiesel) and several others give off a strong chemical odor.

Some of the chemicals identified upon initial recon include: Picric acid, isopropyl ether, ammonium hydroxide, sodium cyanide, arsenic acid, formaldehyde, hydrochloric acid, hydrobromic acid and phosphoric acid.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

On June 21, 2011 OSC Crowley stopped by the facility to speak with the owner who stated that he was running a biodiesel operation at the facility. The facility was not permitted nor was is actually an operating business. The OSC walked through the perimeter of the Site and saw enough to notify South Carolina Department of Health and Environmental Control (DHEC) who visited the Site the same day. Based on the observations of DHEC and the OSC the Site was referred to ERRB and OSC Crowley who was conducting work on the American Screw and Rivet Site (which is .5 miles away) initiated an Emergency Response at the Site on June 22, 2011 after obtaining written access from the owner.


2. Current Activities
  2.1 Operations Section
    2.1.1 Narrative

EPA has transitioned from the Emergency Response Phase of the project into the Time-Critical Removal Phase. However, the dangers at the Site continue to pose an immediate threat to human health and the environment. The current focus at the Site is to mitigate the immediate threats of release from the Site to off-site migration pathways. EPA's estimated time to complete the removal is roughly 4-5 months.

Also during this reporting period it was discovered that the US Army Corps of Engineers manages all of the property surrounding the Site. This includes the two creeks. They were onsite on July 8 to discuss cleanup options and future activities on their land.

2.1.2 Response Actions to Date

To date the following response activities were completed during this reporting period:
  • START continues to air monitoring inside the buildings of the Site and is also started collecting particulate samples using a Data Ram. Levels for particulates fell below action levels.
  • Additional soil screening was conducted at the Site and levels of arsenic in the soil ranged as high as 2,000 ppm. Additionally, the analytical sample for the sediment in the southern creek was found to be 78 ppm. Both of these levels are above EPA RALs for arsenic, which is 40 ppm. A plan will be developed to cleanup the contaminated soils.
  • ERRS installed silt fencing to prevent further runoff of soils from the slope to the creek. The fencing surrounds the site. 
  • Samples collected from the onsite well and the well located to the north of the Site were found to contain no contaminant levels above EPA Maximum Contaminant Levels (MCLs).
  • START has hazard categorized 321 containers of materials onsite.  This information will be used to develop bulking schemes to transfer materials from unsecured containers into totes. 
  • To date, approximately 900 gallons of acids, 900 gallons of acids with chlorides, and 650 gallons of caustic material have been bulked at the Site.
  • Approximately 250 cubic yards of soils have been excavated.
  • START collected a few samples of potential Asbestos Containing Material (ACM) for analysis and all samples were non-detect.
  • Security at the Site continues to be conducted by the Anderson County Sheriff's Department.
Other Activities Involving the Site:
  • EPA OSC attended a meeting with local emergency services officials to discuss the Site as it relates to worst-case scenarios involving the Site (i.e. fire, chemical release, etc...).
  • EPA ERT also visited the Site on July 5 to consult the OSC on the nature and proper handling of certain chemicals onsite.

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)

The owner of the Site has been identified and stated to the OSC that he does not have the financial means to cleanup the Site. Further enforcement activities have begun. Should a viable PRP be identified they will be given the opportunity to assume the cleanup efforts from EPA.

2.1.4 Progress Metrics

Waste Stream Medium Quantity Manifest # Treatment Disposal
           
           
           



  2.2 Planning Section
   

2.2.1 Anticipated Activities

2.2.1.1 Planned Response Activities

The Site is very complex and will require several phases. The primary phase of the initial response is to stop releases from the Site to the creeks and into Lake Hartwell and to secure any containers that are posing a threat of release. During the next reporting period it it expected that excavation and stockpiling of contaminated soils, bulking of materials from unsecured containers into secure containers, and hazard categorization of containers onsite will continue.

2.2.1.2 Next Steps

  • Excavation and stockpiling of contaminated soils
  • Bulking of materials into secured containers
  • Transfering contents of unsecured containers into secured containers
  • Continue hazard categorization of containers onsite

2.2.2 Issues

The main concern at the Site is the nature of the containers. Many of the are mislabeled and in poor condition. In addition, there is a high presence by the local emergency services community due to the presence of explosive materials and other high hazard items. EPA will need to work closely with local, state, and county officials throughout the cleanup process.



  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
  3.1 Unified Command


3.2 Cooperating Agencies
The following Agencies are Cooperating in the cleanup:

South Carolina Department of Health and Environmental Control
Anderson County Fire Department
Anderson County Sheriff's Office
Anderson County Emergency Services Department
United States Army Corps of Engineers

4. Personnel On Site
  Maximum on-site personnel for reporting period:

USEPA OSC - 2
ERRS (ER) - 7
START (Otie) - 3
DHEC - 2
US Army Corps of Engineers - 4



5. Definition of Terms
  ACM - Asbestos Containing Material
EPA - Environmental Protection Agency
EPM - Enforcement Project Manager
ERRB - Emergency Response and Removal Branch
ERRS - Emergency and Rapid Response Services
ERT - Environmental Response Team
MCL - Maximum Contaminant Level
OSC - On Scene Coordinator
PPE - Personal Protective Equipment
PRP - Potentially Responsible Party
RAL - Removal Action Level
RSE - Removal Site Evaluation
RSL - Removal Screening Level
RFQ - Request For Quote
SCDHEC - South Carolina Department of Health and Environmental Control
START - Superfund Technical Assessment and Response Team
USACE - United Stated Army Corps of Engineers


6. Additional sources of information
  No information available at this time.

7. Situational Reference Materials
  No information available at this time.