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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 #14
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 #14
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: 3/13/2012
Reporting Period: 2/1/12 - 2/29/12

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: 6/21/2011
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 April 30, 2012.

2.1.2 Response Actions to Date

To date the following response activities were completed during this reporting period:

Activities performed during the week of January 30th:    

  • ERRS contractor removed concrete floor from building #1. The Upper office area concrete was deemed cleaned due to site activies and will be staged separate from the stockpile of concrete that came out of the process areas.
  • Once the concrete was removed, START contractor took XRF readings on soil surface area of lower tier of building #1. The lower tier of the building contained the chemical blending area, biodiesel production area, and housed the majority of the chemicals found on site. START located a 3 foot wide section that went along the southeastern perimeter that had arsenic levels in the 100 ppm to 700 ppm range. The soil under the Upper Office area showed non-detect using XRF instrument.
  • OSC directed ERRS contractor to remove a 1 foot deep section that was identified by START.
  • ERRS contractor continued treating stockpile 8T with a FreeFlow mixture of 200/300.

Activties performed the week of  February 6th:

  • ERRS contractor finished stabilizing Stockplile 8T and sent a sample for TCLP analysis.
  • ERRS contractor started and finished treatment of stockpile 9T with a FreeFlow mixture of 200/300, and sent a sample for TCLP analysis.
  • ERRS contractor finished loading out stockpile #1, #2, #18, #12, and started #16. The amount of contaminated soil that was sent for off-site disposal for the week totaled 1,724 tons.
  • ERRS continued moving stockpile #13, #14, and #15 in order to dry them out.
  • ERRS asbestos abatement subcontractor removed tiles that contained asbestos from a 10 foot by 10 foot area. The subcontractor used steam to release the tiles and they where placed in an asbestos labeled plastic bag. The subcontractor performed air sampling during the abatement activities and will dispose of the asbestos waste in an approved Toxic Substances Control Act (TSCA) landfill.
  • START contractor continues working on the stream restoration plan. START is developing a list of plants and determining stream calculations to be used in the final design.

Activities performed the week of February 13th:

  • ERRS contractor finished loading out stockpile  #16, #17, and #6T . The amount of contaminated soil that was sent for off-site disposal for the week totaled 1,243 tons. 
  • ERRS crew starts treating Stockpile 19 with Free Flow 200/300 mix.

Activities conducted week of February 20:           

  • ERRS contractor finished loading out stockpile #6T, #1RT, #13 and #7T for the week total of 1,574 tons.
  • ERRS crew finished treating Stockpile 19 and started treating Stockpile #21 with Free Flow 200/300 mix.
  • OSC tasked ERRS contractor to redesign the truck wheel decontamination station and add a decontamination pad with secondary containment. The previous truck washing station design was capturing water using a french drain system. This new design will caputure water/mud inside the secondary containment decontamination pad and the water will then be put in totes.
  • START contractor took XRF radings along the right of away of Frontage Rd in order to ensure that road has not been contaminated during the transport of contaminated soil. Measurements taken with the XRF indicate non-detect levels on the road and along the side. OSC has determined that contamination is not migrating off-site due to our transportation and disposal operations.
  • START contractor submitted final restoration plan and the OSC sent it to ACE representative for comment.

 Activities conducted week of February 27:

  • ERRS contractor loaded out stockpile #8T, #9T, #14, and #20T for the week total of 1,388 tons.
  • Construction debris and trash was removed from the southern edge of the property. The metal was segregated and will be sent to a recycler.
  • ERRS crew finished treating Stockpile 21, and sent a sample for TCLP analysis for cadmium.

 

Analytical Results of Stockpiled Material that failed the TCLP limit for non-hazardous waste of 1. mg/L for cadmium. Soil above this limit is considered hazardous waste and must be treated before it can be disposed in a Subtitle D Landfill. The treatment standard for cadmium is .11 mg/L or an alternative treatment standard of 90% reduction and be below 1.0 mg/L.

Stockpile # Cadmium Initial TCLP Result (mg/L) Cadmium TCLP Result After Treatment(mg/L)
7 3.43 .019
6 1.84 .011
1 3.61 .036
8 2.44 .017
9 2.64 .026
19 24.9 .091
20 23.2 .071
21 2.87

Waiting for results




2.1.4 Progress Metrics
Waste Stream Medium Quantity Manifest # Treatment Disposal
 Non-Hazardous, Arsenic and Cadmium Contaminated Soil (Total soil)  Soil  7,402 tons    None Upstate  Regional MSW Subtitle D Landfill
 Hazardous, Cadmium Contaminated Soil Treated On-Site  Soil  2,319 tons   Free Flow 300/200
 Magnesium Oxide  Bulk  4 tons    None Upstate Regional MSW Subtitle D Landfill
 Scrap Metal  Scrap Metal  24.9 tons    Cleaned Belton Metals Recycling
 Drums  Metal  3.4 tons    Cleaned Upstate Regional MSM Subtitle D Landfill
 Non-friable Asbestos Vinyl Floor Tiles with Mastic  1 cubic yd    None Enterprise C&D Landfill (TSCA)


  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:
  • Continue off-site disposal of non-hazardous contaminated soil in a Subtitle D Landfill.
  • Excavate the area where the lean to used be attached to the west wall of Building 1.
  • Continue treatment of contaminated soils that failed TCLP for cadmium.
  • START will XRF area under the stockpiles in Zone 6 and 7.
  • 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) - 6
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.