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.

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. 

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.

Remaining transportation and disposal, site restoration and demobilization activities took place during this reporting period. A number of drums were screened using hazard categorization and determined to contain oily waste, chemicals and oily waste water similar to material found in AST 504. These drums and the remaining contents of the oil water separator were disposed of. Drums containing usable chemical products, chemical storage containers and a number of gas cylinders were secured Onsite.

Surface soils in the bone yard at the northern end of the Site and the soils inside secondary containment were excavated and an eight point composite samples was collected from each area. The excavated area in the bone yard contained PCB Aroclor 1260 at a concentration of 474 ug/kg and the excavated area inside secondary containment contained PCB Aroclor 1260 at a concentration of 393 ug/kg. Both of these results are well below EPAs Removal Management Levels (RMLs) for industrial and residential soil (74 and 22 mg/kg respectively).

Clean soil to be used as backfill was tested to confirm the absence of PCBs and other hazardous substances and mobilized to the Site. The excavated area in the bone yard and secondary containment were backfilled. Exposed soil previously underneath tank 501 (now dismantled) was sampled and PCB Aroclor 1254 was detected at a concentration of 174 ug/kg, well below EPAs RMLs for industrial and residential soil (32 and 3.4 mg/kg respectively). This area was capped with concrete as part of Site restoration activities.

An open pit previously used as an oil water separator which contained TSCA solids was emptied and three core samples were collected. Detectable concentrations of PCB Aroclor 1260 ranged from 780 to 1110 ug/kg with one non-detect. A sample of a small amount of water in the oil water separator was also non-detect. The oil water separator and several other pits which had created previous runoff issues were backfilled and capped with concrete so that they would not create future problems with oily water runoff from the Site.

Following the requirements of 40 CFR Part 112 and because the facility has no SPCC plan, liquids and sludge have been removed from all tanks and connecting lines. Only residual amounts of oil and rinse water remain. Connecting lines and piping have been disconnected and were possible and blanked flanged. ASTs 210, 211, 213, 214 and 215 could not be blank flanged so lines were blanked off using 2-3 inches of concrete which could later be removed by mechanical means. All tanks were labeled “permanently closed” with the date of closure.

The PRP previously refused to sign a salvage agreement for a number of valves which were disconnected in the decommissioning of ASTs and informed the OSC of his intent to go back into operation in the future. These valves had previously been in contact with PCB material and were stenciled “PCBs” and secured in AST 12. All ASTs which had been in confirmed contact with high concentrations of PCBs material were stenciled with “PCBs.” 

A number of small miscellaneous containers, drums and cylinders containing paint, house hold hazardous waste, acetylene and possibly Freon were secured onsite.

Site walkthroughs were conducted with US Coast Guard (USCG) Sector North Carolina, NCDENR personnel and the Cape Fear River Keeper. Local officials were contacted and informed that the removal had been completed. USCG Strike Team (May 8), ERRS Contractors (May 15) and the EPA OSC (May 14) completed Site activities and demobilized from the Site by 5/15/2014.

It should be noted that to date, none of the remaining ASTs and piping at P&W have been wipe sampled or decontaminated in accordance with the regulations set forth in Title 40 CFR Part 761. Specifically ASTs 12, 204, 205, 206, 207, 214, 215, 220, 502, 503, and 504 have previously been in contact with PCBs and should be decontaminated following the procedures found at Title 40 CFR Part 761 prior to use. Tanks 210, 211 and 213 should be wipe sampled following the procedures found at Title 40 CFR Part 761 to confirm they are suitable for use. These tanks have been permanently closed according to the regulations found in 40 CFR Part 112.

During removal operations it was determined that there were a number of discrepancies between the amount of oil, sludge and water determined to be onsite during previous RSEs. During Removal Site Assessments the amounts of sludge and oil being stored in AST’s was estimated using a weighted measuring tape. This approach was used to measure the exterior height of the tank, the interior headspace, and oil and sludge layers, based on viscosity and resistance of the weighted tape. This approach is subject to a large percentage of judgmental error and is useful primarily for determination of the amount of bulk material being stored for purposes of cost estimates.

Interviews with the Site owner revealed that he had continued to operate several tanks after the February 2013 RSE was conducted and the contents of those tanks had changed. Additional interviews with workers at the Site revealed that a number of tanks in the boneyard and tank farm had largely been used to store water and sludge. These tanks were previously believed to contain primarily oil.

It was noted that tanks, 503 and 504 had extensive internal heating coils and piping so the volume of material in both of these tanks was determined to be less than noted in previous RSEs. Additionally, tank 504 which was previously reported to contain oil, was determined to contain large amounts of water and sludge with a thin oil layer on top.

Tank 501, an 85,000 gallon tank, which was previously believed to contain oil, was determined to contain primarily water and sludge with a thin layer of oil on the top. Tank 229, a 20,000 gallon tank previously thought to contain oil was determined to contain primarily water and sludge. Tank 219, previously believed to contain only oil was determined to contain primarily sludge.

Anticipated Activities

The following response actions are anticipated during the next reporting period:
Any remaining coordination with state and local officials, PRPs and residents.

2.2.1.1 Planned Response Activities

Coordination with state and local officials, PRPs and residents are the only planned activities.

2.2.1.2 Next Steps

2.2.2 Issues

Coordination with NCDENR RCRA Personnel

One Senior OSC remote with period site visits, one junior OSC, USCG Strike Team Member, one START Contractor (intermittent) and five ERRS crew members