NCD980602163_19840920_Warren County PCB Landfill_SERB C_Re State PCB Task Force-OCR

THE UNIVERSITY OF NORTH CAROLINA
AT
CHAPEL HILL
UTILITIES DIVISION
Electric Diatribution
The University of North Carolina at Chapel Hill
Electric Distribution Operations Center 463-A
Chapel Hill, N.C. 27514 September 20, 1984
Mr. George P. Johnson
State Building Division -Construction
Legislative Office Building
300 N. Salisbury Street
Raleigh, N.C. 27603-1360
Dear Mr. Johnson:
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I wish to thank you and the State PCB Task Force or your efforts in preparing the
PCB Guidelines and in organizing the PCB Management Seminar. I found the guidelines
and the seminar to be most helpful in understanding the EPA Federal Register on PCB.
I hope this effort in Raleigh is an indication of future assistance we can expect from
State Construction.
Per your request at the seminar on September 6, 1984, I have prepared the following
comments and questions.
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1. TESTING FACILITY - A State owned or approved PCB testing facility available
to all state agencies which would furnish test kits upon request would be a
great advantage. Presently we are using Environmetrics, St. Louis, Missouri,
to perform an X-ray, PCB detection only test for $1 O. 00.
<[/c ~ \C~ · 2 STORAGE AND DISPOSAL SERVICE - A State owned Annex 111 central storage
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,.,. • facility could contract annually with a waste chemical disposal company for
~ disposal of PCB transformers and other PCB waste. This service to individual
v-r-state agencies would encourage the phase out of PCB transformers. The
:; ): ,,, problems involved with storage and disposal may discourage many of us from
CP" ,!'~ ,.... ~ phasing out the PCB transformers. The ultimate result will be transformer Y:r. \.V} ~(---failure, spills, added cost of clean up and adverse publicity associated with v~ ): }·,J·· the PCB spills. ~ P~ ~~ ,, ~~ 9nr . 't'-0 L , r..(~' ,JI;,, 3. SMALL LOW VOLTAGE CAPACITOR DISPOSAL -We learned at the seminar that
Jt/' f Jt Federal law allows dumping of small non-leaking PCB capacitors in an approved
(L ,, '';i·· landfill. Then we were told there are no North Carolina approved landfills. P What should we do with these capacitors? It would be helpful if we could
accumulate these until we have a container full and then trRn~P,,p,rt/hem to a
central facility for storage ;m_p,....disposal. filf'~--· L---;1)-~ . s:--)). {~ s_ .. 1
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4. "NO PCBs" -Are transformer manufacturers required to label non-PCB trans-·
formers with a "No PCBs" label? If not, can we label transformers manufac-
tured after a certain date with a "No PCBs" fabel ?l What is the date of
manufacture of NON-PCB transformers? f-Jo ~ 1,_)..J
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R TROFIT vs. REPLACEMENJ -Has anyone_ on the PCB Task Force don~ a c!t analy.sis of PCB dispo3a-f through retrofit vs. replacement? ls retrofit
economically feasible for small distribution transformers?
ANNUAL INSPECTION -Federal Register, Vol. 47, No. 165, page 37357
permits an annual inspection (instead of quarterly) for PCB transformers
which have "impervious, undrained, secondary containment capacity of at
least 100 percent of the total dielectric fluid volume of all transformers so
contained." Please recommend an acceptable material for painting concrete, (l ,
brick or block to form an impervious (to PCB) containment. r1o ~></VJ-'U.-{..-r~./1,.,i ·.,
PCB CONT AMI NA TED SPILLS -In view of the requirement that all transformers
manufactured before 1978 must be assumed to be PCB contaminated ( 50-500 PPM)
and that all spills from these transformers must be cleaned up and disposed
of in the same manner as PCB transformers (unless tested and proven to be
non-PCB); we plan to eventually test all transformers located in vaults and
label them as non-PCB. This would save a lot of extra work, confusion and
adverse publicity in the event of a spill. I think it's worth the cost of an
oil test. /-.,o
8. PCB RISK ASSESSMENT -We found the PCB Risk Assessment in Appendix H
of the PCB Guidelines to be most helpful in making a risk evaluation of our
in-service PCB transformers and in preparing a priority list for phase out of
some of our PCB transformers.
9. ANNUAL PCB SUMMARY REPORT -I have enclosed copies of our Annual PCB
Summary Report_s for 1978 through 1983. All of these were prepar ed and
dated September 17, 1984. Based on our experience with EPA I recommend
that where information is available these past reports be prepared accordingly.
10. CALCULATIONS -When preparing the Annual PCB Summary Report for PCB
transformers we use the conversion factors of 1 0 lbs . per gallon and . 45 Kg
per lb. These factors agree with the EPA's PCB Penalty Policy, Federal
Register, Vol. 45, No. 177, September 10, 1980, page 59779 which says you
may base figures on the assumption that the density of PCB fluids is 10 lbs.
per gallon where the actual density of the fluid involved is unknown. When
the actual quantity (gallons) or weight (lbs.) of fluid in a PCB transformer.
is not listed on the nameplate, we measure the height and diameter of the
tank, calculate the total volume in cubic inches and convert to gallons ( 231
cubic inches per gallon). We then use 50% of the total volume as fluid volume
allowing 50% for core and coil. The 50% figure was recommended to us by
Charlie Brown of General Electric, Raleigh. The figure applies to distribution
transformers only; it does not apply to substation type transformers.
11. FUTURE PLANS -At UNC we feel we have met all EPA rules and regulations
for marking, storage, inspection and record keeping of all PCB transformers.
Future plans include a major oil testing program, modifications to PCB