On 14 March 2019 EPA, at the request of the Fresno County Department of Public Health, Environmental Health Division (the CUPA) responded to the property. The CUPA sought EPA assistance in the removal of the abandoned drums at the Site as the owner had not complied with orders previously-issued by the CUPA to remove the drums. The owner consented to EPA’s access to the Site to conduct an assessment. EPA was accompanied by representatives of the CUPA and the CA Dept. of Toxic Substances Control (DTSC). During the Site assessment, a count indicated a total of approximately 600 drums and barrels (later confirmed at 563). Some of the drums were uncovered and exposed to the elements. Some evidence of drum deterioration and leakage or spillage was observed. Select drums were opened and sampled for hazard categorization in the field, all of the opened drums appeared to contain used oils and greases. A subset of the samples were sent to a laboratory for analysis in order to determine if the wastes contained hazardous substances. The laboratory’s analytical results indicated the presence of lead as a contaminant in some of the samples. The decision was made to conduct a Time Critical Removal Action.
The removal action proceeded in two phases. The first phase consisted of drum staging, field hazcatting, and sampling. Once the laboratory analytical results were received, operations resumed for the second phase, which consisted on drum overpacking, transportation and disposal.