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

ERRS continued clearing debris and staging and overpacking drums in the west building on 5/21/2016. START continued cataloging containers in the west building as they were restaged. A large pool of spilled liquid which appeared to be waste oil and water was found in the back of the west building. Liquids which could be pumped were transferred into an empty tote. Solid material was shoveled from the shallow sump. Due to the oily water spill and quantity of drums, the maneuvering area for restaging drums was significantly reduced and required clearance of the mercury-contaminated area before staging in the west building could continue. Prior to initiation of decontamination efforts in the mercury-contaminated area, crews segregated totes that were found outside in to three groups: 1) contains liquid/solids; 2) empty and appears to be capable of holding liquids; 3) empty and cracked/breached. 

The mercury vacuum arrived at approximately midday and OSC Huyser worked with ERRS to begin removal of spilled mercury on the floor, drums, and containers. Mercury sources (sphygmomanometers and thermostats), some of which were un-breached and contained mercury in vials, were segregated and bagged separately. After spilled mercury was removed, the floor was sprayed with epsom salt solution (magnesium sulfate) and scraped and shoveled. Mercury-contaminated debris and dirt was bagged and will be segregated for later disposal. Drums which had been in the mercury-contaminated area were removed and placed outside on pallets over a plastic-lined and bermed area where they were sprayed with epsom salt solution and scrubbed. START cataloged and recorded markings on the drums when they were brought outside. The drums will be allowed to sit outside in the sun for several days to dry and vent and will be covered during rain and overnight. 

Cardboard boxes and containers (large tubes designed for florescent lamp tube recycling) were staged on the south side of the building. Some of the boxes or containers are full of florescent lamp tubes but most are empty. These boxes and containers will be evaluated for residual mercury contamination and may be disposed of or left at the Site.

A 5-gallon bucket containing nearly 1/4-inch of mercury in its bottom was discovered in the southeast corner of the west building. The mercury will be transferred to a smaller sealed container and overpacked.

Hazard categorization progressed throughout the day and processed approximately 34 samples. Daily sample processing will likely increase as common waste conditions and groups are recognized.

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
• Continued cataloging containers
• Continued sampling containers for hazard categorization
• Began clearing debris from west building
• Began staging drums in west building
• Began removal of wastewater from secondary containment area
• Began mercury removal
• Began decontaminating mercury-contaminated area
• Began removal and decontamination of mercury-contaminated drums
• Began hazard categorization

2.1.2.1 Current Container Count

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; (ONGOING)
• 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. (ONGOING)

2.2.1.2 Next Steps

Complete removal and decontamination of mercury in the west building. Decontaminate floor in west building including mercury-contaminated areas and areas where waste oil, water, and other fluids have spilled. Complete staging drums in west building.

2.2.2 Issues

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

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  was opened for START contractor, Tetra Tech, in the amount of $10,000 and was verbally raised on $50,000 on 5/21/2016.

* 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

Daily temperatures exceed 90 degrees fahrenheit with high humidity. Arrival time to the Site has been shifted from 0700 to 0630 but excessive heat issues may become a problem and require longer periods of rest to compensate.

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 (9)

START (2)

MDEQ (as available)

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.