1.1.1 Incident Category

 Emergency Response.

1.1.2 Site Description

Former used oil and waste recycling facility.

1.1.2.1 Location

137 J J Holcomb Rd, Picayune (Nicholson), Pearl River County, Mississippi

1.1.2.2 Description of Threat

Site is comprised of used oil and other oil materials stored in totes and drums which are leaking in an unsecured building and migrating to the ground outside. Spilled elemental mercury has been found scattered in an open and unsecured area. Abandoned aboveground storage tanks containing waste oil are located in a secondary containment area which has filled with rainwater, the freeboard is undetermined. The secondary containment areas contain oil saturated sorbents and there is a sheen on the trapped water. There are residences within 50-100 feet outside the fence line on three sides of the facility. A small creek flows on the southern border of the facility and a stream on the northern border.  Access to the property, its buildings, and their contents is unsecured. 

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

Mississippi Department of Environmental Quality (MDEQ) requested that EPA Emergency Response, Removal and Prevention Branch (ERRPB) conduct a removal site evaluation (RSE) at the JCC Environmental Site. The business filed bankruptcy in 2013 and was subsequently abandoned. EPA OSC Huyser met with MDEQ and one of the former JCC Environmental partners on May 17, 2016, to walk through and inspect the facility. Approximately 150 drums and 100 totes were found, most of which were full or at least partially filled and some of which were leaking. Contents of the full containers mostly appeared to be oil. Buckets marked corrosive and universal waste were found, some of which reportedly contained liquid elemental mercury waste. The former partner indicated that vandals may have broken instruments containing mercury on the floor of one building. 

There are three buildings located at the Site. The north building is closed and contains only a few drums, totes, and buckets. The west building is open and contains a majority of the drums and totes. The south building is office space. There are two above-ground storage tanks (ASTs) at the site with capacities in excess of 10,000-gallons each. Thermal imaging suggests that one tank is approximately 20% full while the other has a liquid level of only 12 inches. The tanks are within a shallow secondary containment area that is filled with rainwater and has a sheen on the surface. There are drums and totes within the secondary containment area as well.

2.1.1 Narrative

Emergency Rapid Response Services (ERRS) and Superfund Technical Assessment and Response Team (START) crews began Site response activities on 5/19/2016.

ERRS crews cleared debris from the north building. E-waste and fluorescent bulbs were moved to the east wall. Trash and uncontaminated debris was bagged and moved to the exterior of the building. Contaminated materials were solidified with sorbent and containerized. Waste oil in two sumps within the building were pumped into available totes. Debris in the sumps was solidified and shoveled into another container. Small containers such as 5-gal buckets were staged on the south wall. ERRS then began to stage drums in the building that had been found in the north building and around the outside. Drums are staged on pallets and arranged in rows for easy and safe access. Prior to moving drums, ERRS collected samples (where possible) from each drum and tote for hazard categorization.

START and EPA OSC Huyser entered the west building with a Lumex Mercury Vapor Analyzer (MVA) and a Jerome MVA to identify mercury contamination in the building. Immediately mercury beads were identified in at least four distinct locations where medical devices (sphygmomanometers) and thermostats lay broken open. Glass tubes which previously contained mercury were found nearby. Mercury beads were found on the concrete floor within and alongside dirt, debris, rocks, trash, and oil residue. Mercury beads were found on drums, many of which were also covered in dust and oil residue. Amd mercury beads were found on stacks of cardboard boxes, which contained fluorescent bulbs. Mercury contamination appeared to be limited to the southern portion of the building and was well ventilated due to two large garage bay doors which were left open. The long building has four garage bay doors, one of which is missing and two of which were open upon initial inspection. Mercury vapor concentrations remained below 5,000-7,000 ng/m3 even around the spilled mercury although concentrations spiked beyond 30,000 ng/m3 near the floor in areas where mercury had been spilled. Mercury vapor levels fell to outdoor background concentrations through the rest of the building (when garage doors remained open).

 START and EPA OSC Huyser continued mercury screening in the north building and did not find any indication of contamination. Three 5-gallon buckets sealed with red duct tape were identified with labels that identified the contents as mercury waste; one bucket contained a closed 1-gallon can and no elevated mercury readings were detected around the containers.

 START began cataloging all containers using an electronic iForms system which includes notes and photographs of each object. The database will be used to assist in hazard categorization and bulking for disposal as well as provide a sufficient record of all wastes found at the Site. ERRS has mobilized a chemist to begin hazard categorization of samples.

2.1.2 Response Actions to Date

• Cleared debris from north building
• Began cleaning sumps in north building
• Began staging drums in north building
• Delineated extent of spilled mercury contamination
• Began cataloging containers
• Began sampling containers for hazard categorization

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
The former partner declared that there were no available funds associated with the business to conduct the response and there were no other fund sources to undertake the action. Written access to conduct the response was not granted until May 18.

2.1.4 Progress Metrics

2.2.1 Anticipated Activities

Primary objectives will be evaluating safe working and operating conditions at the site, initial cleaning of spilled waste materials, securing containers and assessing the contents of each, then segregating by waste streams for later disposal.

2.2.1.1 Planned Response Activities

• Screen working areas to delineate potential mercury contamination; (COMPLETE)
• Catalog and document all containers throughout the Site and stage in a secure location to await disposal; (ONGOING)
• Overpack or repackage materials from leaking containers; (ONGOING)
• Sample waste materials for hazard categorization and profiling for treatment and/or disposal; (ONGOING)
• Remove free liquids and wastes from secondary containment area;
• Remove liquids and sludges from above-ground storage tanks and decontaminate, if necessary;
• Excavate stained soils resulting from previous on-site spills;
• Perform additional surface and soil screening for additional contaminant hazards, if necessary;
• Perform air monitoring for on-site health and safety; (ONGOING)
• Treat and/or dispose of waste materials from the Site.

2.2.1.2 Next Steps

 Removal and decontamination of mercury in the west building will begin on 5/20/2016. Also on 5/20, the Kemron's chemist will arrive to begin hazard categorization and a vacuum truck will arrive to begin removing water from the secondary containment area. The water will be disposed of as oily wastewater and treated at a facility in Mobile, AL.

2.2.2 Issues

 Small jars of low level radioactive materials (Thorium Oxide and Thorium Nitrate) were found in the former lab of the north building. The small containers appear to be properly labeled and have not spilled but do register on radiological meters as radioactive.

2.4.1 Narrative

The initial ceiling for this emergency response action memorandum will be $250,000. An initial Task Order has been opened for ERRS contractor, Kemron, in the amount of $100,000. An initial TDD has been opened for START contractor, Tetra Tech, in the amount of $10,000.

* The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written. The OSC does not necessarily receive specific figures on final payments made to any contractor(s). Other financial data which the OSC must rely upon may not be entirely up-to-date. The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery.

2.5.1 Safety Officer

No information to report in this section at this time.

2.5.2 Liaison Officer

No additional information to report in this section at this time.

2.5.3 Information Officer

No information to report in this section at this time.

3.1 Unified Command

 No information to report in this section at this time.

3.2 Cooperating Agencies

EPA (1)

ERRS (7)

START (2)

MSDEQ (1)

6.1 Internet location of additional information/report

 No information to report in this section at this time.

6.2 Reporting Schedule

 No information to report in this section at this time.