1.1.1 Incident Category

Time-Critical Removal Action

1.1.2 Site Description

The Georgia Environmental Protection Division (GAEPD) requested the assistance of the Environmental Protection Agency (EPA) Region 4 Emergency Response, Removal and Prevention Branch (ERRPB) after an inspection resulting from a citizen’s complaint of abandoned oily and leaky drums.  GC Quality Lubricants, also known as Georgia-Carolina Quality Lubricants, is a subsidiary of Bay Street Corporation. The property is a former oil processing facility and encompasses three buildings; two are located across the street from each other at 1403 Sixth Street and 1480 Sixth Street, the third building is located at 195 Bay Street in Macon, Bibb County, Georgia. All of the buildings are unsecure, open to the environment, surrounded by heavy vegetation, and with evidence of trespassing/vandalism.  The property appeared to be abandoned. A tax search revealed that taxes have not been paid for the past few years. On December 27, 2012, GAEPD performed a site inspection and documented numerous violations of the following statutes: 40 CFR Section 262.11, “Hazardous Waste Determination”, 40 CFR Section 279.22(c)(1) “Used Oil Storage Generator Facilities”, and 40 CFR Section 279.22(d)(1-3) “Used Oil Storage” Response to Releases.  The facility is permanently closed, however drums, oil and oily waste material remained at the location(s).

GC Quality Lubricants is an onshore facility as defined in 40 CFR Section 112 and, due to its location, could reasonably be expected to discharge oil into or upon the navigable waters of the United States or adjoining shorelines.  The total storage capacity of the facility exceeds 1,320 gallons of oil and is subject to the preparation and implementation of Spill Prevention Control and Countermeasures (SPCC) Plan.  According to a record of bankruptcy proceedings, in the late 1990’s or early 2000’s, a previous removal action was undertaken by the EPA after a routine SPCC inspection.  The inspection uncovered numerous violations of the Oil Pollution Act (OPA) including oil flowing from the facility into a storm drain which exited into a wetland that flows to the Ocmulgee River.  An EPA time-critical removal action at the facility included installing sheet piling around the contaminated site and placing a clay cap over the surface of the contaminated area. The total costs of this removal activity was approximately $2.6 million. 

1.1.2.1 Location

GC Quality Lubricants has locations across the street from each other located on Sixth Street and at 195 Bay Street.  It is less than one mile southeast of Mercer University.  It also sits less than ½ mile from a wetland which is in the floodplain of the Ocmulgee River, a navigable water of the United States.  The main channel of the river flows 1.4 miles northeast of the former facility.  There are numerous lakes and creeks that connect the floodplain to the river and it is not uncommon for the wetland to fill with water during heavy rainfall.   The surrounding area is mostly industrial, with a rail yard located to the southeast.

1.1.2.2 Description of Threat

See POLREP #5 dated June 20, 2016.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

See POLREP #5 dated June 20, 2016.

2.1.1 Narrative

Emergency Rapid Response Service (ERRS) has initiated operations to remove containers of oil & lubricants from the facility at 195 Bay Street and is staging the containers within a lined containment area. Due to the concerns of the floor stability within the building, ERRS subcontracted a structural engineer to advise on measures required to assure structural safety during the removal action. ERRS is constructing and installing shoring structures to augment floor support as operations moves from the basement and upward to the top (third) floor.  The Superfund Technical Assessment and Response Team (START) continues to refine the container inventory and waste into disposal streams utilizing field compatibility testing and portable instrumentation. 83 drummed containers ranging from 5-gallons to 55-gallons, of product have been removed from the basement floor of the building and into containment outside of the building. Numerous small containers continue to be inventoried, segregated and staged for disposal. 10-cubic yards of oil stained debris and sorbent materials have been consolidated into a roll-off box in this reporting period.  A power line was installed and permanent electrical service established to the site trailers and building operations. 

 
2.1.2 Response Actions to Date

Week of October 10, 2016: 

Reconnaissance/ expanded assessment of 195 Bay Street completed.

Ceiling tiles and associated structural materials sampled for asbestos analysis.

*** Sample results show no evidence of asbestos in sampled materials ***

Construction of an access ramp into the south end of the building (basement) has been completed. 

• Drum inventory Complete 

Basement

·       47 – 55 gallon drums

·       36 – 20 gallon drums

·       10 – 5 gallon buckets

·       12 – 1 gallon containers

·       1 – 30 gallon cardboard fiber drum with crystals (pH 10-11). 

·       1 – 30 gallon cardboard fiber drum labeled “Koppers DBFC Flakes” about 1/8 full. 

1^st Floor –

·       53 – 55 gallon drums

·       158 – 20 gallon drums

·       53 – 5 gallon buckets

·       2 – 1 gallon containers

·       1 – overpack drum

·       1 – 30 pound cardboard fiber drum

2^nd Floor –

·       73 – 55 gallon drums

3^rd Floor –

·       69 – 55 gallon drums

·       10 – 20 gallon drums

·       2 – 5 gallon buckets

Grand totals (529 total containers)

·       242 – 55 gallon drums

·       204 – 20 gallon drums

·       65 – 5 gallon buckets

·       14 – 1 gallon containers

·       3 – 30 gallon cardboard fiber drums

·       1 – overpack drum

Week of October 24, 2016:

•  83 drummed containers of product have been removed from the building.
• 24-cubic yards of oil stained debris and sorbent materials have been consolidated into a roll-off box in this reporting period.
•  Two shoring platforms were installed on the basement level to support designated areas of the first floor. 
•  29 samples field tested for materials compatibility and disposal coordination.
• Power line installed on site and in-service.

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)

See POLREP #5 dated June 20, 2016.

2.2.1 Anticipated Activities

The building located at 195 Bay St has petroleum that is discharging to the environment and remediation is indicated.

2.2.1.1 Planned Response Activities

Actions for 195 Bay Street Location:

1. Install safety controls within building work spaces (ONGOING);
2. Sample and/or monitor working spaces to establish site-specific safe working conditions and practices;
3. Cut or install access pathways for removal of drums and other containers from building (ONGOING);
4. Inventory, sample, and catergorize drums and other waste containers (ONGOING);
5. Remove spilled oil, grease, and petroleum products from the building (ONGOING);
6. Remove drums and other containers from the building; and,
7. Dispose of oil, grease, petroleum products, and oil-contaminated debris.

2.2.1.2 Next Steps

The floor of the basement will be cleaned of oil and grease.  Contractors will begin to remove containers to the staging area located at the southeast corner of the building.

2.2.2 Issues

The engineer will return to the site to advise on shoring operations between the floors and other structural issues that may effect removal operations and safety.

2.5.1 Safety Officer
This position is served by the FOSC

2.5.2 Liaison Officer
This position is served by the FOSC

2.5.3 Information Officer

 This position is served by the FOSC 

3.1 Unified Command
N/A

3.2 Cooperating Agencies

 GAEPD

EPA (1 FOSC)

ERRS Kemron; (8 personnel) 1-Response Manager,1-Field Clerk, 1-Foreman, 1-Equip Operator , 4 Laborers

START OTIE (1 Environmental Scientist)