1.1.1 Incident Category

Time-Critical Removal Action

1.1.2 Site Description

The Georgia Department of Natural Resources (GaDNR) requested the assistance of the Environmental Protection Agency (EPA) Region 4 Emergency Response and Removal Branch (ERRB) after an inspection resulting from a citizen’s complaint of abandoned oily and leaky drums.  GC Quality Lubricants (also known as Georgia-Carolina Quality Lubricants,) is a subsidiary of Bay Street Corporation. The property is a former oil processing facility and encompasses three buildings; two are located across the street from each other at 1403 Sixth Street and 1480 Sixth Street), and the third building is located at 195 Bay Street. All of the buildings are unsecure, open to the environment, and surrounded by heavy vegetation.  The property appeared to be abandoned and a tax search revealed that property taxes have not been paid for the past few years. On December 27, 2012, GaDNR performed a site inspection noted numerous violations of the following statutes: 40 CFR Section 262.11, “Hazardous Waste Determination”, 40 CFR Section 279.22(c)(1) “Used Oil Storage Generator Facilities”, and 40 CFR Section 279.22(d)(1-3) “Used Oil Storage” Response to Releases.  The facility is permanently closed, however drums, oil and oily waste material remained at the location.

GC Quality Lubricants is an onshore facility as defined in 40 CFR Section 112 and due to its location, could reasonably be expected to discharge oil into or upon the navigable waters of the United States or adjoining shorelines.  The total storage capacity of the facility exceeds 1,320 gallons of oil and is subject to the preparation and implementation of Spill Prevention Control and Countermeasures (SPCC) Plan.  According to a record of bankruptcy proceedings, in the late 1990’s or early 2000’s, a previous removal action was undertaken by the EPA after a routine SPCC inspection.  This inspection uncovered numerous violations of the Oil Pollution Act (OPA), including oil flowing from the facility into a storm drain which exited into a wetland that flows to the Ocmulgee River.  An EPA time-critical removal activities was undertaken which included installing sheet piling around the contaminated site and placing a clay cap over the surface of the contaminated area.  The total costs of this removal activity was approximately $2.6 million.  

1.1.2.1 Location

GC Quality Lubricants has locations across the street from each other located on Sixth Street and at 195 Bay Street.  It is less than one mile southeast of Mercer University.  It also sits less than ½ mile from a wetland which is in the floodplain of the Ocmulgee River, a navigable water of the United States.  The main channel of the river flows 1.4 miles northeast of the former facility.  There are numerous lakes and creeks that connect the floodplain to the river and it is not uncommon for the wetland to fill with water during heavy rainfall.   The surrounding area is mostly industrial, with a rail yard located to the southeast.

1.1.2.2 Description of Threat

See POLREP #5 dated June 20, 2016.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

See POLREP #5 dated June 20, 2016.

2.1.1 Narrative

Contractors continue to construct a basement entryway though the rear (south) portion of the building.  Safety barriers have been installed and other health and safety activities continue (fire extinguisher installation, eliminating slip hazards from steps, etc.).  Security has been hired.  Approximately 600 containers are located throughout the 4 story building.  Segregation and hazard characterization of the containers will begin this week.

2.1.2 Response Actions to Date

Removal Activities Completed at 195 Bay Street:

Sample results show no evidence of asbestos in the building.

Construction of an access ramp on the south end of the building has been completed. 

• Drum inventory Complete 

Basement

·       47 – 55 gallon drums

·       36 – 20 gallon drums

·       10 – 5 gallon buckets

·       12 – 1 gallon containers

·       1 – 30 gallon cardboard fiber drum with crystals (pH 10-11). 

·       1 – 30 gallon cardboard fiber drum labeled “Koppers DBFC Flakes” about 1/8 full. 

1^st Floor –

·       53 – 55 gallon drums

·       158 – 20 gallon drums

·       53 – 5 gallon buckets

·       2 – 1 gallon containers

·       1 – overpack drum

·       1 – 30 pound cardboard fiber drum

2^nd Floor –

·       73 – 55 gallon drums

3^rd Floor –

·       69 – 55 gallon drums

·       10 – 20 gallon drums

·       2 – 5 gallon buckets

Grand totals (529 total containers)

·       242 – 55 gallon drums

·       204 – 20 gallon drums

·       65 – 5 gallon buckets

·       14 – 1 gallon containers

·       3 – 30 gallon cardboard fiber drums

·       1 – overpack drum

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)

See POLREP #5 dated June 20, 2016.

2.2.1 Anticipated Activities

The building located at 195 Bay St has petroleum that is discharging to the environment and remediation is needed.

2.2.1.1 Planned Response Activities

Actions for 195 Bay Street Location:

1. Install safety controls within building work spaces (ONGOING);
2. Sample and/or monitor working spaces to establish site-specific safe working conditions and practices;
3. Cut or install access pathways for removal of drums and other containers from building (ONGOING);
4. Inventory, sample, and catergorize drums and other waste containers (ONGOING);
5. Remove spilled oil, grease, and petroleum products from the building (ONGOING);
6. Remove drums and other containers from the building; and,
7. Dispose of oil, grease, petroleum products, and oil-contaminated debris.

2.2.1.2 Next Steps

 The floor of the basement will be cleaned of oil and grease.  Contractors will begin to remove containers to the staging area located at the southeast corner of the building.

2.2.2 Issues

The engineer will return to the site to advise on securing the open freight elevator which has seized between floors and is a hazard if it were to shift or fall.