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 completed clearing debris and staging and overpacking drums from the west building on 5/24/2016. START continued cataloging and sampling containers in the west building as they were  removed from being stacked. Mercury vapor levels in the west building were found to be consistently below 5,000 ng/m3 and ERRS began returning staged drums to the previously mercury-contaminated side of the west building on 5/24.

Totes which had been stacked outside the south side of the west building were sampled. Several totes with quantities of liquid were extracted and staged at ground level. Totes with liquid in this area are mostly cracked or otherwise damaged and their liquid will have to be transferred to a different container prior to staging in the west building.

The vacuum tanker truck returned on 5/24 to remove liquids and sludge from the secondary containment area. Additional piping was cut to allow sludge to flow into the central sump. Sludge that had been shoveled onto the sloped driveway was also vacuumed into the tanker. Wastewater found in Tank #4 was transferred to the tanker by opening the manway in the side of the tank; less than 6 inches of sludge was left in the tank and it was resealed. Wastewater found in Tank #2 was transferred to the tanker first by opening a 3" valve and transferring through the central sump, then by opening the manway in the side of the tank; less than 10 inches of sludge was left in Tank #2 and it was resealed.

The sludge and water was transferred to totes which were staged in the north building after being filled. Decontamination of the tank farm was initiated with a general purpose degreasing cleaner and a pressure washer. The tanker continued to remove liquids as cleaning progressed in order to improve sludge removal from the tank. By the end of the day, less than 1000 gallons of sludge remained in the tank which would have to be removed on-site with the addition or water or would have to be cleaned at the transportation facility on Mobile, AL. The tanker was allowed to sit overnight at the Site by parking the rear of the tanker on the sloped parking area (the rear of the tanker contained the only outlet and would discharge into the secondary containment if leaking or open).

Hazard categorization progressed throughout the day and processed approximately 50 samples which matches the 50 samples from the previous two days.

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
• Cleared debris from west building
• Began staging drums in west building
• Removed wastewater from secondary containment area
• Completed mercury removal
• Completed decontaminating mercury-contaminated area
• Completed removal and decontamination of mercury-contaminated drums
• Began hazard categorization
• Completed sludge removal from secondary containment area
• Began removing piping from tank farm

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; (ONGOING)
• 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 staging drums in west building. Complete decontamination of tank farm.

Transfer liquids from broken/leaking totes to stable containers and stage. Begin excavation of stained soils.

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 for ERRS contractor, Kemron, has been verbally raised to $200,000 following submission of an Independent Government Cost Estimate (IGCE) to the Contracting Officer. 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

No additional 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 (10)

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.