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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 #13
Continuation of Removal Action
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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 #13
Continuation of Removal Action
Flex-A-Form Drum Site
B4K2
Anderson, SC
Latitude: 34.5901430 Longitude: -82.6698200


To:
From: Benjamin Franco, On Scene Coordinator
Date: 2/3/2012
Reporting Period: 1/2/2012-1/31/2012

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 #:

For background information including Site Description, Location, and Description of Threat please refer to previous POLREPs.



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 approximately March 1, 2012.

2.1.2 Response Actions to Date

To date the following response activities were completed during this reporting period:
  • On January 2, 2012, EPA's contractors mobilized to the Site from the Holdiay break. Site activities were resumed on January 3, 2012.  

Activities performed during the week of January 4-7

  • The Toxicity Characterists Leaching Procedure (TCLP) test results for cadmium of stockplie #1 that was treated before the holiday period did not meet the treatment standards of .11 mg/L for cadmium.  ERRS contractor consulted with a Free Flow representative to determine possible solutions. Based on the mixing calculations, the Free Flow representaive determined that the mix rate was below the 5% recommended rate. He also recommended a different Free Flow mix that is composed of 80% Free Flow 300 and 20% Free Flow 200. ERRS adjusted the treatment mixing procedures and applied it at the 5% rate on stockpile #7.  Stockplie #7 and #1 have similar TCLP values, 3.43 mg/L and 3.61 mg/L, respectively.  Results from the treatment of stockpile #7 were .019 mg/L and were below the treatment standards.  Based on these results, ERRS will repeat these procedures with the rest of the contaminated material that failed TCLP for cadmium and retreat stockplie #1. 
  • Disposed off-site 496 tons of non-hazardous contaminated soil at Subtitle D Landfill. 
  • Removed used batteries, tires and fire extinguishers that were found on Site and were sent for recycling.  
  • Rinsed steel drums and prepared them for disposal.  
  • Final preparation of Buildng 1 for demolition. 

Activties performed the week of January 9th

  • ERRS contractor demolished Building 1 on January 12 and 13th and the metal was segregated for recycling.
  • START contractor has an asbestos inspector certificate and was assessing the demolition debris for asbestos suspect material that was not visible during the initial asbestos inspection.
  • ERRS subcontracted with a crane company in order to move a large piece of equipment from inside Building 1. The equipment weighed approximately 30,000 lbs and was in area that the concrete floor had to be removed. The owner/operator took the piece of equipment and sent it to a metal recycler. 
  • ERRS contractor fixed silt fencing in order to maintain effective erosion control. 

Activities performed the week of January 16th

  • ERRS contractor started with the removal of concrete floor in Building 1. START contractor is obtaining XRF measurements from the soil under the concrete area as it gets exposed.
  • The soil in soutwestern corner of Building 1 had arsenic and cadmium levels of 2,311 ppm and 5,426 ppm respectively. This area was associated with a nearby septic tank and was under the chemical blending room of the building. 
  • On January 18th, a drum with a blue substance and solid material was found buried in the soil under the area of the building that was under a lean to shed that was attached to Building1.  START took a XRF readings of the solid material inside the drum and found arsenic readings at 1,688 ppm.  START took a sample of the blue substance and applied pH paper to it and it indicated that material was an acid.  OSC Franco and START obtained photo documentation of the drum. ERRS overpacked the drum, moved it to a secure location within the Site and took a sample for disposal purposes. 
  • ERRS continued excavating in the area where the lean to shed was attached to Building 1. This area of Building 1 was a migration pathway from inside the building all the way to the nearby stream. The roof had holes and rainwater was entering the building and existing through the compromised floor and outside the building. The soil in the area under the caved in floor had arsenic values up to 4,060 ppm, and cadmium values of up to 1,068 ppm.  The cement slab had arsenic and cadmium readings of 9,414 ppm and 1,996 ppm, respectively. 

Activities conducted week of January 23           

  • ERRS continued removing the concrete and START continued taking direct reading measurements of the soil.  
  • ERRS disposed of 564 tons of non-hazardous contaminated soil at a Subitle D Landfill. 
  • OSC Franco received approval for a Action Memo ceiling increase of $800,000.  The new ERRS contractor ceiling is $2.4 million dollars. The ceiling increase request was due to a larger amount of contaminated soil found on Site that resulted in higher disposal costs.  

2.1.4 Progress Metrics

Waste Stream Medium Quantity Manifest # Treatment Disposal
 Non-Hazardous, Arsenic and Cadmium (Total)  Soil  1,473 tons    None  Subtitle D
 Hazardous, Cadmium Total Treated  Soil      Free Flow 300/200
 Magnesium Oxide  Bulk  4 tons    None  Subtitle D
 Scrap Metal  Scrap Metal  24.9 tons    Cleaned  Recycler
 Drums  Metal  3.4 tons    Cleaned  Subtitle D


  2.2 Planning Section
   

2.2.1 Anticipated Activities

2.2.1.1 Planned Response Activities

The following activities are planned during the next reporting period:
  • Finish removing concrete and characterize soil under building 1.
  • Continue treatment of contaminated soils that failed TCLP for cadmium.
  • Prepare stream and property restoration plan for area disturbed on Army Corp of Engineer property.
  • Continue off-site disposal of non-hazardous contaminated soil in a Subtitle D Landfill.
  • Continue to maintain silt fencing.

2.2.2 Issues

Now that all of the dangerous chemicals have been removed from the Site, EPA will focus on removing contaminated soils that contain arsenic.  EPA will continue 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 - 1
ERRS (ER) - 5
START (OTIE) - 1
DHEC -0
US Army Corps of Engineers - 1



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
PCB - Polychlorinated biphenal
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
TCLP - Toxicity Characteristic Leachate Procedure 
USACE - United Stated Army Corps of Engineers
XRF - X-Ray Fluorescence 


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

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