1.1.1 Incident Category

 Emergency Response.

1.1.2 Site Description

Former used oil and waste recycling facility.

1.1.2.1 Location

137 J J Holcomb Rd, Picayune (Nicholson), Pearl River County, Mississippi

1.1.2.2 Description of Threat

Site is comprised of used oil and other oil materials stored in totes and drums which are leaking in an unsecured building and migrating to the ground outside. Spilled elemental mercury has been found scattered in an open and unsecured area. Abandoned aboveground storage tanks containing waste oil are located in a secondary containment area which has filled with rainwater, the freeboard is undetermined. The secondary containment areas contain oil saturated sorbents and there is a sheen on the trapped water. There are residences within 50-100 feet outside the fence line on three sides of the facility. A small creek flows on the southern border of the facility and a stream on the northern border.  Access to the property, its buildings, and their contents is unsecured. 

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

Mississippi Department of Environmental Quality (MDEQ) requested that EPA Emergency Response, Removal and Prevention Branch (ERRPB) conduct a removal site evaluation (RSE) at the JCC Environmental Site. The business filed bankruptcy in 2013 and was subsequently abandoned. EPA OSC Huyser met with MDEQ and one of the former JCC Environmental partners on May 17, 2016, to walk through and inspect the facility. Approximately 150 drums and 100 totes were found, most of which were full or at least partially filled and some of which were leaking. Contents of the full containers mostly appeared to be oil. Buckets marked corrosive and universal waste were found, some of which reportedly contained liquid elemental mercury waste. The former partner indicated that vandals may have broken instruments containing mercury on the floor of one building. 

There are three buildings located at the Site. The north building is closed and contains only a few drums, totes, and buckets. The west building is open and contains a majority of the drums and totes. The south building is office space. There are two above-ground storage tanks (ASTs) at the site with capacities in excess of 10,000-gallons each. Thermal imaging suggests that one tank is approximately 20% full while the other has a liquid level of only 12 inches. The tanks are within a shallow secondary containment area that is filled with rainwater and has a sheen on the surface. There are drums and totes within the secondary containment area as well.

2.1.1 Narrative

ERRS crews simultaneously cleared debris and staged and overpacked drums in the west building on 5/20/2016. START cataloged containers in the west building as they were restaged. There were several areas where waste oil and wastewaters had breeched and leaked across the floor, creating residue and pools of liquid that required pumping, solidification, and manual removal. Drums were staged on pallets and sampled for hazard categorization.

By the end of 5/20/2016, 165 containers had been cataloged in the west building; this is representative of approximately half of the containers throughout the building, several of which cannot be accessed until the mercury contaminated area is decontaminated.

In addition, 66 containers were cataloged in the north building and 138 were cataloged outside. The total container count is 369. Less than 40 of these are small containers (5 gallons or less).

A vacuum tanker was brought on-site to remove the oily water from the secondary containment area. Two loads were removed on 5/20/2016, one of 5,025-gal and a second of 4,735-gal (total 9,760-gal). Both were transported offsite to Liquid Environmental Solutions in Mobile, AL for treatment.

2.1.2 Response Actions to Date

• Cleared debris from north building
• Began cleaning sumps in north building
• Began staging drums in north building
• Delineated extent of spilled mercury contamination
• Continued cataloging containers
• Continued sampling containers for hazard categorization
• Began clearing debris from west building
• Began staging drums in west building
• Began removal of wastewater from secondary containment area

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
The former partner declared that there were no available funds associated with the business to conduct the response and there were no other fund sources to undertake the action. Written access to conduct the response was not granted until May 18.

2.1.4 Progress Metrics

2.2.1 Anticipated Activities

Primary objectives will be evaluating safe working and operating conditions at the site, initial cleaning of spilled waste materials, securing containers and assessing the contents of each, then segregating by waste streams for later disposal.

2.2.1.1 Planned Response Activities

• Screen working areas to delineate potential mercury contamination; (COMPLETE)
• Catalog and document all containers throughout the Site and stage in a secure location to await disposal; (ONGOING)
• Overpack or repackage materials from leaking containers; (ONGOING)
• Sample waste materials for hazard categorization and profiling for treatment and/or disposal; (ONGOING)
• Remove free liquids and wastes from secondary containment area; (ONGOING)
• Remove liquids and sludges from above-ground storage tanks and decontaminate, if necessary;
• Excavate stained soils resulting from previous on-site spills;
• Perform additional surface and soil screening for additional contaminant hazards, if necessary;
• Perform air monitoring for on-site health and safety; (ONGOING)
• Treat and/or dispose of waste materials from the Site. (ONGOING)

2.2.1.2 Next Steps

 Removal and decontamination of mercury in the west building has been delayed until 5/21/2016 (see 2.2.2 below). Kemron's chemist was delayed and did not arrive until the end of the day on 5/20 so will begin hazard categorization on 5/21. The treatment facility that received the wastewater from the secondary containment area will not reopen until Monday (5/23), so the vacuum truck will not return to collect wastewater until 5/23 to avoid sitting unattended with a full tank.

2.2.2 Issues

Due to a shipping error, the mercury vacuum did not arrive on 5/20 and will not arrive until midday on 5/21. This delay will cause significant issues if crews working in the west building are able to complete consolidation activities in the unimpacted areas before mercury decontamination can begin. Crews may shift to moving and staging totes on the exterior of the building while the mercury decontamination occurs.

Kemron's chemist was delayed and can only begin hazard categorization on 5/21. Due to the significant volume of samples, the time to conduct hazard categorization is likely to exceed the time that will be required for staging and decontamination activities.

2.5.1 Safety Officer

No information to report in this section at this time.

2.5.2 Liaison Officer

No additional information to report in this section at this time.

2.5.3 Information Officer

No information to report in this section at this time.

3.1 Unified Command

 No information to report in this section at this time.

3.2 Cooperating Agencies

EPA (1)

ERRS (8)

START (2)

MSDEQ (as available)

6.1 Internet location of additional information/report

 No information to report in this section at this time.

6.2 Reporting Schedule

 No information to report in this section at this time.