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Site Number: |
B4Y3 |
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Contract Number: |
EP-SF-07-04 |
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D.O. Number: |
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Action Memo Date: |
8/27/2013 |
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Response Authority: |
CERCLA |
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Response Type: |
Time-Critical |
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Response Lead: |
EPA |
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Incident Category: |
Removal Action |
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NPL Status: |
Non NPL |
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Operable Unit: |
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Mobilization Date: |
11/4/2013 |
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Start Date: |
11/5/2013 |
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Demob Date: |
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Completion Date: |
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CERCLIS ID: |
NCD986215242 |
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RCRIS ID: |
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ERNS No.: |
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State Notification: |
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FPN#: |
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Reimbursable Account #: |
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1.1.1 Incident Category
Time Critical Removal Action
1.1.2 Site Description
The P & W Waste Oil Site (the Site) is a former waste oil recycling facility located in Navassa NC. P&W Waste Oil (the business) began operation in 1993 and continued operation until March 2012 when the facility owner ceased operations. From April 2012 to March 2013, several tanks on the Site were leased to another waste oil recycling business.
While the facility was in operation, waste oil, waste oil containing antifreeze and oily water were transported to the facility and pumped into aboveground storage tanks (ASTs). After on-site treatment, the waste oil was sold to third parties for energy production. The facility owner has ceased operations, abandoning approximately thirty ASTs of used oil, sludges and oily water contaminated with polychlorinated biphenyl PCBs.
In 2009, the EPA and North Carolina’s Department of Environment and Natural Resources (NCDENR) responded to a waste oil spill at the Site. The owner of P&W Waste Oil contained the spill and excavated several inches of surface soil. This waste oil spill was estimated to be less than 20,000 gallons.
In June 2013, another release occurred at the Site when the contents of a full open top tank were being transferred to another AST. This spill was estimated to be less than 20,000 gallons of waste oil and oily water and was confined in secondary containment. The Potentially Responsible Parties (PRP) cleaned up the spill.
1.1.2.1 Location
The Site is located at 10518 Royster Road, Leland, Brunswick County, NC 28451 which is in Navassa city limits. The latitude and longitude of the Site are 34.271074 and -78.004163 respectively. P&W Waste Oil (the business) is bordered by a residential property immediately to the north on which several ASTs belonging to P&W Waste Oil (the business) are stored. This adjacent property is part of the Site.
The Site is bordered by an open field immediately to the north, a waste water treatment plant immediately to the west, a distillery and waste oil facility to the south and an a federally recognized wetland and Cape Fear River immediately to the east. The federally recognized wetland is 130 feet due east of the Site. The Cape Fear River is located approximately 450 feet due east and slightly down gradient of the Site.
1.1.2.2 Description of Threat
The threat of release of a hazardous substance at the Site poses a threat to public health and the environment pursuant to Section 104 of the Comprehensive Environmental Response, Compensations and Liability Act (CERCLA) that meets the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) section 300.415(b)(2) criteria for removal actions. The Site is an inactive waste oil facility with large amounts of polychlorinated biphenyls (PCBs) contaminated waste oil stored in deteriorating tanks in close proximity to navigable water. The Site is currently nonoperational.
1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
Phase II sampling activities conducted in August 2008, by a prospective purchaser of the Site, revealed PCB contamination in the soil at the Site. Additionally, in 2009 the owner of the Site came under criminal indictment for alleged unlawful transportation, storage and disposal of used oil contaminated with PCBs in violation of the Toxic Substances Control Act (TSCA). In March 2012 the PRP ceased operations at the Site.
The U.S. Environmental Protection Agency’s Resource Conservation and Recovery Act (RCRA) Program referred the Site to Superfund’s Emergency Response and Removal Branch (ERRB) for consideration of a time-critical removal action in November 2012 because the owner of the Site came under criminal indictment for alleged unlawful transportation, storage and disposal of used oil contaminated with PCBs in violation of the Toxic Substances Control Act (TSCA).
On February 12 and 13, 2013, EPA OSCs Terry Stilman and Brian Englert and Superfund Technical Assessment and Response Team (START) contractors arrived on-site to evaluate the Site conditions and to collect waste oil samples and surface soil samples for a Removal Site Evaluation (RSE) under CERCLA authority. Upon arrival, visual assessment confirmed that there were a number of tanks in deteriorating condition and without secondary containment. Waste oil samples were collected from 15 above ground storage tanks (ASTs) and one consolidation pit located on the Site. Eight of the tanks sampled contained Aroclor-1260 and seven of the tanks were non-detect.
This prompted OSC’s Terry Stilman, Kenneth Rhame and Brian Englert to coordinator and oversee a separate RSE under to CWA authority to further assess the amount of used oil not containing hazardous substances. Additional sampling was conducted at the Site on July 11-12th 2013 to determine if the waste oil not contaminated with PCBs would meet the specifications for used oil at 40 Code of Federal Regulations (CFR) Part 279.11 and could be recycled. This sampling indicated that additional volumes of oil, oily water and sludge at the Site either contained PCBs or did not meet the specifications for used oil because it contained cadmium, chromium or lead above the specifications in 40 C.F.R. Part 279.11.
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2.1.1 Narrative
During the week of 11/04/2013 EPA Emergency Rapid Response Contractor (ERRS) mobilized personnel and equipment to the Site in preparation of removal activities. The Site was staged for removal activities and waste profile samples were collected. From to 11/04/2013 to 12/26/2013 ERRS contractors loaded trucks with waste oil containing >50 ppm PCBs and nonhazardous oily water destined for disposal facilities.
EPA and ERRS contractors demobilized from the Site on 11/27/13 and mobilized back to the Site on 12/02/13 to continue removal operations. From 12/02/13 to 12/20/2013 ERRS contractors continued to load trucks with waste oil containing >50 ppm PCBs, >50 ppm PCB solids and nonhazardous oily water destined for disposal facilities. Additional profile samples were collected as needed.
An AST outside of secondary containment and containing PCB sludge which could not be pumped were sheared open and the contents removed and disposed of. These tanks were relocated within secondary containment. A large open top storage tank which had been the location of two former releases was sheared and its liquid contents removed. Solids remain in the tank awaiting disposal at a later time. ERRS contractors pumped out an open pit onsite and constructed a cover that would prevent accumulation of storm water and generation of more waste. The Site was staged for further removal activities and secured for the holidays.
2.1.2 Response Actions to Date
EPA and ERRS Contractors performed the following tasks during this reporting period:
Staged the Site for removal activities
Collected waste profile samples
Conducted transportation and disposal of waste oil containing >50 ppm PCBs, solids containing > 50 ppm PCBs and nonhazardous oily water
Several tanks were sheared, the contents removed and the tanks relocated.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
Enforcement activities continue with the identification and Noticing of PRPs.
2.1.4 Progress Metrics
| Waste Stream |
Medium |
Quantity |
Manifest # |
Treatment |
Disposal |
| >50 ppm PCB |
Oil |
220,000 Gal |
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Incineration |
| >50 ppm PCB |
Solids |
88 Tons |
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Internment
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| non-haz |
Oily Water |
108,000 Gal |
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Treatment |
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