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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
Oneida Total Integrated Enterprises (OTIE) completed sampling of a bone yard on the northern most portion of the Site, confirming PCB levels were below Residential Removal Management Levels (RMLs). Five five-point composite and one grab sample were collected. Detectable results for PCB Aroclor 1260 ranged from 0.13 to 4.1 mg/kg and were below EPAs RML for residential soil (22 mg/kg).
Environmental Restoration LLC continued transportation and disposal of TSCA and non-TSCA solids and oily water previously in contact with PCBs. Oily water from ASTs 202, 229, 501, 502, 504 were pumped into frac tanks and sampled prior to transportation and disposal.
Demolition of ASTs 201, 202, 203, and 229 were completed so that non-pumpable sludge and water containing high levels of chromium in AST 501 could be accessed. This material was disposed of.
TSCA solids from AST 205 was staged with TSCA solids in a drained pit previously used as an oil water separator. ASTs 204, 206 and 207 previously operated by another waste oil business were accessed and found to contain several thousand gallons of tank bottoms and oily water. Analytical testing revealed that tank bottoms from tanks 204 and 212 contain PCB Aroclor 1260. Because the original source of PCBs was >500 ppm, materials in these tanks were removed under the ongoing CERCLA response.
ASTs 201, 202, 203, 216, 229 and 501 were completely dismantled, cleaned and salvaged. The PRP had previously refused to sign a salvage agreement for a number of ASTs onsite including tank 212. AST 212 was secured inside secondary containment.
2.1.2 Response Actions to Date
EPA and ERRS Contractors performed the following tasks during this reporting period:
Continued transportation and disposal of TSCA solids, non-TSCA solids and non-TSCA oily water
Conducted decontamination of equipment used during removal of TSCA material
Completed demolition of tanks surrounding AST 501 and AST 501
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 |
Estimated 213,738 Gal |
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Incineration |
| >50 ppm PCB |
Solids |
Estimated 566.77 Tons |
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Internment
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non-haz
non-TSCA Soilds |
Oily Water
Sludge |
Estimated 389,064 Gal
Estimated 245.39 Tons |
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Treatment
Internment
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