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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 #15
End of Excavation Activities
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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 #15
End of Excavation Activities
Flex-A-Form Drum Site
B4K2
Anderson, SC
Latitude: 34.5901430 Longitude: -82.6698200


To:
From: Benjamin Franco, On Scene Coordinator
Date: 3/22/2012
Reporting Period: 3/5/2012-3/23/2012

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: 6/21/2011
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 March 5th:    

  • ERRS contracter transported off-site Stockpiles 19T, 15 and 21T for a weekly total of 1,391 tons of contaminated soil removed.
  • START contractor conducted XRF screening the surface of Zone 6 and 7 where the stockpiles have been located to ensure that there were no residual contamination left behind.  XRF readings in the area indicated levels in the range of 50 ppm to 122 ppm. The contamination was contained to the first 6 inches of soil. OSC tasked ERRS contractor to scrape the surface to that level in both Zone 6 and 7.

Activties performed the week of  March 12th:

  • ERRS contractor finished removing first six inches of Zone 6 and 7. The material from these areas became stockpile 22 and 23.
  • ERRS contractor also finished excavating the pit that was located in the lean to area next to Building 1. The material from this area was placed in Stockpile #24.  
  • All zones that were initially sampled are clear of contamination and excavation operations have finished.
  • ERRS sent waste samples from the three stockpiles for TCLP analysis.
  • ERRS received the plants and trees that were outlined in the stream restoration plan.
  • OSC and ERRS project manager (PM) met with a representative with SCDOT to discuss the conditions of Frontage Rd that leads to the Site. The SCDOT representative surveyed the road and came to the conclusion that the road did not require resurfacing but just minor patch work. He stated that his District Office will do the work for free.

Activities performed the week of March 19th:

  • ERRS contractor received waste results and Stockpile #23 failed TCLP analysis for cadmium at 1.07 mg/L. This will require treatment of the stockpile with Free Flow. Because the value was so close to 1.0 mg/L requirement, ERRS ordered and received 20 tons of Free Flow 200 stabilizing agent instead of 200/300 mix.
  • ERRS contractor disposed off-site 401 tons of contaminated concrete to a Subtitle D landfill. The concrete came from the chemical blending and biodiesel rooms in Building 1 and from Building 2.
  • ERRS contractor started off-site disposal of Stockpile #22 and #24.
  • ERRS contractor continues with grading western side of the property.
  • ERRS contractor received erosion control mats and hyrdoseeding supplies.
  • The OSC, ERRS PM and START personnel met on Site with USACE personnel to discuss the stream restoration plan.
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 of the initial TCLP value and below 1.0 mg/L, in order to meet the Land Disposal Reguirements for Subtitle D Landfills.

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 .119
23 1.07  Requires Treatment



2.1.4 Progress Metrics
Waste Stream Medium Quantity Manifest # Treatment Disposal
 Non-Hazardous, Arsenic and Cadmium Contaminated Soil (Total soil)  Soil  8,793 tons    None Upstate  Regional MSW Subtitle D Landfill
 Hazardous, Cadmium Contaminated Soil Treated On-Site  Soil  3,003 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)
 Cement Pad  Cement  401 tons      Upstate Regional MSM Subtitle D Landfill


  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:
  • ERRS contractor will Treat Stockpile #23 with Free Flow 200.
  • ERRS will continue with site restoration activies.
  • START contractor will assist with the placement of plants and trees and the shaping of the stream bank.

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.