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 continued clearing debris and staging and overpacking drums in the west building. START completed cataloging and sampling containers in the west building and transferred contents of compromised totes to new containers.

Decontamination of the west building continued with removal of dried oil patches impacted with mercury. Mercury-contaminated waste that had been bagged and final small containers previously moved outside for ventilation remain outside the building. The bags were set aside and opened to allow greater ventilation in an attempt to allow at least some of the bags to sufficiently reduce mercury vapor concentrations so that they no longer need to be considered mercury-contaminated waste.

The vacuum tanker truck remains onsite to remove liquids from the secondary containment area. Pumping, removal and staging of wastes from the tank farm have been completed. Oily debris have been collected and staged on the driveway on the south side of the tank farm. This pile has been covered and bermed to prevent oily runoff.

Tank levels were assessed and liquid volumes that had been determined through use of the thermal imaging camera were confirmed. All oil has been removed from the tanks in the tank farm and placed in totes. Only oily sludge remains in the tanks at this time and the tanks have been resealed. The larger tank (marked Tank #2) was left at approximately 20% full and the smaller tank (marked Tank #4) was left at approximately 12-inches full.

Several sections of above-ground piping were removed on 5/23 and 5/24. Most of the piping contained only residual quantities of waste materials including liquids and sludge.

Hazard categorization progressed throughout the day and approximately 50 samples were completed during this reporting periods.

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 & sampling containers onsite
• Completed cataloging containers & sampling containers in west building
• Cleared debris from west building
• continued staging catalogued and sampled drums and totes in west building
• Completed removal of wastewater from secondary containment area
• Completed pumping, removal and staging of wastes in the tank farm
• Completed decontaminating mercury-contaminated area
• Completed removal and decontamination of mercury-contaminated drums
• Continued hazard categorization
• Completed sludge removal from secondary containment area
• Completed removing piping from tank farm

Completed work in the tank farm

2.1.2.1 Current Container Count

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; (COMPLETE)
• Remove liquids and sludges from above-ground storage tanks and decontaminate, if necessary; (COMPLETE)
• 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

Complete staging drums in west and north buildings.

Transfer liquids from broken/leaking totes to stable containers and stage. Complete excavation and staging of stained soils.

2.2.2 Issues

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

2.4.1 Narrative

The initial ceiling for this emergency response action memorandum will be $250,000. An initial Task Order for ERRS contractor, Kemron, has been verbally raised to $200,000 following submission of an Independent Government Cost Estimate (IGCE) to the Contracting Officer. An initial TDD  was opened for START contractor, Tetra Tech, in the amount of $10,000 and was verbally raised on $50,000 on 5/21/2016.

* The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written. The OSC does not necessarily receive specific figures on final payments made to any contractor(s). Other financial data which the OSC must rely upon may not be entirely up-to-date. The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery.

2.5.1 Safety Officer

EPA OSCs, START and ERRS are providing safety support 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 (2)

ERRS (10)

START (2)

MDEQ (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.