EPD Slaps Knuckles of Dade Chromium-6 User But Clears It of More Serious Allegations. Sort of.

July 1, 2019

A Trenton electroplating company that uses the carcinogen chromium-6 was written up for  "secondary violations" after the Georgia Environmental Protective Division (EPD) inspected it on May 23, but it was given a pass on the primary offense it was accused of--leaking contaminants into the local groundwater.


At least, it was not cited for leaking contaminants into the local groundwater. But an addendum to the official report made it clear that EPD did not and will not investigate the most serious allegation against the company--that its mostly subterranean electroplating tank is, well, leaking contaminants into the local groundwater--though the addendum did note there was no evidence of such a leak.  


C&S Plating & Machine, located behind Reeves Heating and Air between Trenton and Rising Fawn, uses in its industrial-parts-coating operation hexavalent chromium, the carcinogen that poisoned a whole community in the real-life illegal dumping scandal that inspired the movie Erin Brockovich. In May, an anonymous tipster told The Dade Planet that C&S Plating was leaking the same toxin into the local groundwater via a huge tank of chromium-6-laced water whose underlying catchment basin had rotted away, and also through employees leaving the tank to overflow while refilling it with water.


The Planet duly passed the complaint on to the EPD and on May 22 published an article announcing the company's existence--though C&S had been in constant operation since 1995, both the county government and the local water company professed deepest ignorance that Dade contained any such industry. C&S Plating owner James Conkle, interviewed by The Planet, responded that his company hadn't been trying to hide, denied the tipster's allegations, and maintained that C&S followed all required environmental guidelines and was closely regulated by the EPD.


The EPD's inspection of C&S came the very next day after The Planet's article, but EPD did not release its report of the visit until today. This followup comes from that report, dated June 27. 


EPD inspectors found, says the document, that C&S's chromium-6 tank did in fact have an adequate under-basin and that the tank's liner was reportedly replaced as necessary. The only reference the report made of the second allegation--that of spillage from refiling the tank seeping out to the ground--was as follows:


 (Photo from EPD report)


"The water used to constantly replenish the tank accumulates on the floor of the containment area and is then pumped into a holding tank where the solution is reblanced and then pumped into the electroplating tank to replenish the water content."


The report refers consistently to all operations--and all spills--taking place in an indoor area with a concrete floor, not outside where spillage might seep into the earth as alleged by the anonymous tipster.


EPD did issue C&S a "notice of violation" on three counts, two of them minor mishandlings of hazardous waste--leaving a container of discarded contaminated rags open and failing to label another one. But no. 1 on the list of violations cited by EPD appears related to the C&S's habit of operating under Dade's radar: EPD cited the company for failing to make arrangements with the local government for emergency preparedness, a charge that would seem in keeping with the local government's professed astonishment that C&S was doing business in Dade County at all.


A June 11 letter from C&S CEO James Conkle said he had contacted the Dade County government and was arranging to have the facility inspected for safety by one of the local fire departments. The Planet was unable to reach Dade Emergency Management Services Director Alex Case to confirm whether this had yet been accomplished.


  (Photo from EPD report)


Besides the citable offenses, the EPD report went on to identify several other "areas of concern" at C&S. One such was related to an outside area affected by an air scrubber at the facility. "While the scrubber is permitted and the facility is up to date with their required submissions at the time of inspection, there appears to be dead vegetation and stained soils at the immediate area at the base of the down drain gutter off of the roof near the out fall of the permitted air scrubber," reads the report. "A soil sample of this area will be required to identify any potential releases of hazardous waste constituents, from the scrubber to the environment."


Kevin Chambers, an EPD media spokesman, said he'd check on the soil sample and pass on any findings from it.


EPD also noticed that particulates from the final polishing process for electroplated parts were funneled out of the building and released directly into the environment. It recommended that they instead be contained and disposed of as nonhazardous waste. Conkle's letter also reported this had been done, and provided a photo (left).


"There is no method for determining, or measuring, or monitoring a leak..."

All of this is from the official report, sent with the citation to the company, and duly released to The Planet. But accompanying the longer document was a "trip report" generated by environmental engineer Brian Koehler, who had accompanied EPD inspector Nancy Parast on the May 23 site visit.  And from the first page, the trip report makes clear that The Planet's nameless caller's most serious allegation against C&S will remain unexamined. Here's an excerpt:


"During the course of the investigation, Brian Koehler observed that the plating tank is about 7 feet deep," reads the report. "About 3 feet of the freeboard is above the grade or slab of the building, and about 4 feet of the freeboard is below the grade or slab of the building. There is no method for determining, or measuring, or monitoring a leak from the plating tank. There are no Georgia or Federal rules requiring that C&S Plating and Machine, Inc., determine, measure or monitor a leak from the plating tank."


But it does add: "There was no evidence of a leak from the plating tank." And, in the next paragraph: "There was no evidence of any discharge from the plating tank onto the ground outside of the building." 


Concern about chromium-6 in Dade drinking water began in 2016 when an environmental group posted an online map showing levels of the carcinogen in communities across the United States. Clicking on Dade reaped a concentration of 1.17 ppb, or parts per billion, comfortably within state safety limits but exponentially higher than that of surrounding counties. (No more current numbers are as yet available.)


Why should Dade's level be so much higher? The Planet's unnamed caller postulated it was because of leakage from the C&S tank--a theory that, extrapolating from the trip report, must remain neither confirmed nor refuted. 


Another loose end before we conclude this summary: The EPD report describes the C&S facility as located in a nonresidential area. In fact, it is on Highway 11 between Rising Fawn and Trenton, a stretch of road girded on both sides by private residences at varying distances apart. Right next door to the facility is a home whose residents confirmed that they stopped using their well in 2012 because of water problems they blamed on their industrial neighbor, though they declined to be interviewed further.


The Planet will continue reporting on this issue if and when there are further developments.

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