East Point Foundry Construction Project

Project

Forging Progress: East Point Foundry Construction Project by Willmer Engineering

Willmer was retained by the owner of East Point Foundry to conduct a thorough investigation and characterization of a spent sand waste pile inherited from the previous facility’s operations and omitted from the lender’s authorized Phase I and II Environmental Site Assessment reports.

After purchase of the property, the Georgia EPD and US EPA conducted a random and unannounced inspection of the facility, finding that the sand waste pile contained hazardous waste exhibiting the characteristics of toxicity for lead.

Willmer responded quickly to expedite and receive approval from the Georgia EPD via a Corrective Action Plan (CAP) to remove the hazardous waste. The CAP included stabilizing the lead impacted soil with a chemical reagent rendering the material as a non-hazardous treated soil. Approximately 46 tons of non-hazardous treated lead impacted soils and 49 tons of non-hazardous soils were transported to an approved Subtitle “D” landfill for disposal. Although the removal eliminated the hazardous condition on the property, US EPA Region IV representatives alleged RCRA and Georgia hazardous waste violations for the storage of hazardous waste without proper interim status or permitting.

After the removal, US EPA conducted an unannounced sampling of a remote corner of the property and discovered lead in the soil sample exceeding the regulatory limit. Willmer, on behalf of the owner, negotiated a Consent Agreement and Final Order with a reduction in penalties to $500.00 with the agreement that a RCRA Closure Plan for the spent sand pile and an additional site wide facility investigation be submitted and executed. Industrial Levels for total lead were accepted based on risk-based standards, significantly decreasing the costs to the owner for implementation of the RCRA Closure Plan and other investigations.

For the additional investigation, Willmer divided the property into grids, sampled the four corners of each grid, and analyses indicated several additional areas that required excavation and proper disposal. Cleanup was expedited.