U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
P & W Waste Oil Site - Removal Polrep
Final Removal Polrep

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region IV
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Subject:
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POLREP #9
Final POLREP
P & W Waste Oil Site
B4Y3
Leland, NC
Latitude: 34.2710740 Longitude: -78.0041630
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To:
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From:
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Brian Englert, OSC
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Date:
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6/30/2014
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Reporting Period:
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5/20/2014 to 6/27/2014
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1. Introduction
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1.1 Background
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Site Number: |
B4Y3 |
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Contract Number: |
EP-SF-07-04 |
D.O. Number: |
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Action Memo Date: |
8/27/2013 |
Response Authority: |
CERCLA |
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Response Type: |
Time-Critical |
Response Lead: |
EPA |
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Incident Category: |
Removal Action |
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 |
Demob Date: |
5/15/2014 |
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Completion Date: |
5/15/2014 |
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. Current Activities
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2.1 Operations Section
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2.1.1 Narrative
NCDENR’s Wilmington Regional Office noticed OSC Englert that residential well sampling revealed no detectable levels of PCBs and oil related constituents. NCDENR is in the process of notifying the resident by mail.
SITE STATUS AS OF 5/15/2014:
An administrative order on consent (AOC) has been issued by NCDENR for the PRP to conduct further cleanup to bring the Site in compliance with all soil and groundwater remediation requirements.
It should be noted that, none of the remaining ASTs and piping at P&W, that have been in contact with PCBs, 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 any use. These tanks have been PCB placarded and marked accordingly. 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.
Following the requirements of 40 CFR Part 112 and because the facility has no SPCC plan, liquids and sludge have been removed from these tanks and their connecting lines and they have been permanently closed according to the regulations found in 40 CFR Part 112.
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 ASTs and 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 ASTs and valves had previously been in contact with PCB material and were stenciled “PCBs” and secured. Valves were secured in AST 12. All ASTs which had been in confirmed contact with high concentrations of PCBs material were placarded and 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 have been 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.
2.1.2 Response Actions to Date
EPA and ERRS Contractors performed the following tasks during this reporting period:
Completed removal and Site restoration activities and demobilized from the Site
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 918.77 Tons |
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Internment
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non-haz oily water
Non-TSCA Soilds
Non-haz Oily Water
Scrap Metal |
Oily Water
Sludge
Oily Water
Metal |
Estimated 389,064 Gal
Estimated 1993.39 Tons
229,500 Gal
154,420 lbs |
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Solidification
PCB Decon where applicable |
Treatment
Internment
Internment
Reuse |
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2.2 Planning Section
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2.2.1 Anticipated Activities
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
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2.3 Logistics Section
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No information available at this time.
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2.4 Finance Section
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No information available at this time.
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2.5 Other Command Staff
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No information available at this time.
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3. Participating Entities
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3.1 Unified Command
3.2 Cooperating Agencies
North Carolina Department of Environment and Natural Resources (NCDENR)
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4. Personnel On Site
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The following personnel demobilized during the previous reporting period
One Senior OSC remote with period site visits, one junior OSC, USCG Strike Team Member, one START Contractor (intermittent) and five ERRS crew members
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5. Definition of Terms
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No information available at this time.
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6. Additional sources of information
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No information available at this time.
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7. Situational Reference Materials
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No information available at this time.
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