NCD980602163_19851003_Warren County PCB Landfill_SERB C_Correspondence, 1984 - 1985-OCR

FROM L ibb // ~ .. NOl'JTH CAROLINA ::.-----DEPARTMENT OF HUMAN RESOURCES INTER OFFICE MEMORANDUM DATE 10-3-85 Sorry it took so long to respond. Since Bill Phillips is no longer with CCPS maybe we can get cooperation. I am trying to work through someone over there. If I can't get any action tben we'll talk to Phil about contacting Joe Dean. -OHR Form 2 (8175) L 1k OOT· 7 \985 £1Wa&OUfHiAl. HfM.TH S£CHON ..... OCT 4 'S8S
~ -To: Libby Drury From: Ron Levine~-iv What shall we do about the attached item? SEP 26 1835
TO
FROM NORTH CAROLINA DEPARTMENT OF HUMAN RESOURCES INTER OFFICE MEMORANDUM DATE 7/2/85 Ms. Drury
Dr. Levine ------------------
Here's another fun item to while away
your hours after the General Assembly adjourns .
Should we meet to discuss?
cc : William L. Meyer through James F. Stamey
DHR Form 2 {8/75)
LEACHATE
PONO
LEACHATE
3-STAGE REMOVAL
FILTER
CLEAN EARTH/TOPSOIL
ARTIFICIAL LINER
LEACH A TE COLLECTION SYSTEM
CLAY LINER
GAS
I
WATER TABLE
ORIGINAL
GROUND
/ SURFACE ------
Figure 1. Cross-sectional drawing of controlled PCB landfill in North Carolina.
the Comprehensive Environmental Response, Compensa-o ■HOUSE
A MAIN VENT
B SMALL VENT
E SMALL VENT tion and Liability Act ("Superfund"), all samples were
collected, handled, and transported under standard
chain-of-custody procedures.
Results and Discussion
Controlled Landfill. In 1978, an unprecedented spill
of PCBs along 387 km of roadway occurred in central
North Carolina. Some 40 000-120 000 L of transformer
fluid consisting of Aroclors 1260 and 1242 in chloro-
benzenes were illegally and surreptitiously dumped along
the shoulders of the roads. Over 4 years of litigation were
required before a disposal site for the 30000 m3 of con-
taminated soil could be located in a sparsely populated
area of the state. Because of the great amount of public
concern over the safety of the disposal site, a state-of-
the-art landfill designed to exceed the requirements of
'l'oSCA was constructed in late 1982. The EPA-approved
\Superfun<l) site, located on a 4 ha of land in a rurai area,
measures 75 m X 145 m and has a maximum depth of
about 7 m. The contaminated soil is encapsulated within
0.6-rn (top) to 1.5-m (bottom and sides) thick layers of
highly impervious, compacted clay, augn1ent.ed with 10-mil
(0.25-mm) and 30-mil (0.75-mm) plastic liners on the top
and bottom, respectively. The landfill is properly sloped
and equipped with sump pump!! and a leachate collection
system for monitoring purposes. It is also provided with
a gas vent which protrudes 1.5 m into the landfill for relief
of methane and other gases generated by bacterial decay
of organic matter contained in the soil. A cross-sectioned
drawing of the landfill is shown in Figure 1.
Several months after closure of the landfill, local resi-
dents voiced concerns that gases emanating from the vent
pipe and (as yet uncapped) leachate collection pipes may
have been introducing PCBs into the surrounding atmos-
phere. In response, a study was undertaken in Jan and
Feb 1983 to monitor these emissions and the ambient air
at the site.
Only the LV samplers were used in this study. The
vents and leachate access ports were sampled by placing
the PUF cartridge inlets into the pipes or ports and sealing
the openings with plastic bags to assure maintenance of
positive pressures. Sampling was performed for 8 h at
reduced flow rates of 1.2-1.4 L/min so as not to exceed
the volumetric flow rates of the vent pipes. The sampling
efficiency of the LV sampler employing PUF cartridges
had been previously shown to be essentially quantitative
for collection of Aroclor 1242 in natural gas, which is
97-98% methane (9). Soil temperatures within the landfill
were presumed to be nearly constant at 4-5 °C (thermic
temperature regime); therefore, emission rates were es-
sentially independent of ambient air temperatures.
1 1000m
C UPPER LEACHATE ACCESS PORT
0 LOWER LEACHATE ACCESS POAT
0 SAMPLERS
0--._ ---l -----~o,._-,-_..x_ ________ ,_•s_m--,
------0..... ---• B 75m
----130m 36m 36m -0 36m 160m -o---o-•-o----+---o
0------
_..~i'm
_..o----c~~ -E u.....:::.-----------~ LEACHATE
POMO
WEATHER ST A TION N----Figure 2. Sampling arrangement for monitoring at the controlled landfill
when winds were from the north. Array was rot3ted with wind direction
so as to monitor at the perimeter of the landfill and at half the distance
for the main vent to the perimeter.
Ambient air sampling was performed with an array of
samplers operating at 3.8 L/min and located from 1 to 200
m upwind and downwind of the main vent as shown by
the example presented in Figure 2. Air samples were
collected at 1.2 m aboveground at each of the 18 locations
designated by open circles. Simultaneous samples were
also collected at 4.6 m above ground at the perimeter of
the mounded landfill (72 m downwind of the main vent
in the arrangement shown in Figure 2) so as to be on
line-of-sight with the opening of the main vent. The spatial
arrangement of the samplers was alternated as necessary
at the start of each sampling period to reflect average wind
direction. That is, downwind samplers were placed in a
fanned-out array at half the distance from the main vent
to the perimeter, at the perimeter, and at the tree line
(100-130 m downwind). Upwind samplers were placed
accordingly. One sample was taken at the same location
in the yard of the nearest house (1 km away) during each
sampling period. Sampling was performed from 0900 to
1700 Eastern Standard Time on 3 days and from 2100 to
0500 on the fourth day. Ambient air temperatures ranged
from -1 to +14 °C, wind speed from 0.04 to 6.6 m /s. and
relative humidity from 46 to 95%. No vent sampling was
performed on these days, and all vents were left open.
Analytical results from the gas samples collected from
five vents are presented in Table I. It should be noted
that the lower leachate removal pipe extends below the
landfill. The two small pipes were installed temporarily
to release gas bubbles in the upper plastic liner. PCB
concentrations in the gases (principally methane) ema-
nating from the main vent ranged from 105 to 141 µg/m3
measured as Aroclor 1242 and from 1.8 to 2.1 µg/m3
measured as Aroclor 1260. A typical gas chromatogram
of the PCB mixture found in the main gas vent is shown
Environ. Sci. Technol., Vol. 19, No. 10, 1985 987
' co"lJ;ributing PCBs to the surrounding atmosphere.
' Conclusions
The results of these studies demonstrate that fugitive
em.iasions of PCBs into the atmosphere can occur at un-
controlled landfills. At the three sites, PCB air levels
measured at hot spots on the landfills greatly exceeded
ambient background levels, thus indicating that PCBs
from the leaking capacitors were being emitted into the
air. Concentrations that exceeded background levels were
also observed at sampling locations downwind of the
landfills, even after removal of exJ)08ed capacitors and
obviously contaminated surface soil. By contrast, air
em.iasions of PCB from a well-designed chemical waste
landfill were found to be negligible.
All PCB sampling systems were found to perform well.
The LV samplers offered an advantage over the HV sam-
plers when electrical power was not available (as wu the
case at m08t of the sites monitored). However, limited
battery life would not permit 24-h sampling with the LV
pumps. The experimental passive sampler, which can
readily operate unattended for 24 h. shows much promise
if its sensitivity can be increased by 100-fold through im-
proved extraction and analysis methods.
Acknowledgment8
We than Donald E. Johnson of Southwest Research
Institut.e, San Antonio, TX, for valuable laboratory support
in preparation and analysis of PUF cartridges, Jack C.
Suggs of the U.S. Environmental Protection Agency, Re-
search Triangle Park., NC, for modeling assistance, William
F. Barnard and Jack A. Bowen of the U.S. Environmental
Protection Agency, Research Triangle Park, NC, for per-
forming field audits, James Gray of EPA Region IV,
Athens. GA, for field IIUP) ·.;rt at the controlled landfill, anc!
Ralph Riggin of Battelle for analysis of the p8B8ive sam-
pling devices.
Reci•try No. Aroclor 1242, 53469-21-9; Aroclor 1260, 11096-
82-5.
Literature Cited
(1) MacLeod, K. E.; Lewis, R G. In •Sampling and Analysis
of Toxic Organica in the Atmosphere"; American Society
for Testing and Materials: Philadelphia, PA, 1980; Pub-
lication STP721, pp 56-69.
(2) Weaver, G. Environ. Sci. Technol. 1984, 18, 22A-27A.
(3) Murphy, T. J.; Formanaki, L. J.; Brownawell, B.; Meyer,
J . A. 184th National Meeting of the American Chemical
Society, Kanaaa City, MO, Sept 1982; American Chemical
Society: W uhington, DC, 1982; ENVR 70.
(4) Lewia, R G.; Brown, A. R.; Jackson, M. D. Anal. Chem.
1977, 49, 1668-1672.
(5) Lewia, R G.; Jaclmon, M. D. Anal. Chem. 1982, 54, 592-594.
(6) Lewia, R G.; MacLeod, K. E. Anal. Chem. 1982, 54,
310-315.
(7) Fed. Regut. 1979, 44, 69501-69509.
(8) Webb, R. G.; McCall, A. C. J. Chromatogr. Sci. 1973, 11,
366-373.
(9) Jackaon, M. D.; Hodgson, D. W.; MacLeod, K. E.; Lewi&,
R G. BuU. Environ. Contam. Toxicol. 1981, 27, 226-229.
(10) U.S. Environmental Protection Agency "NTIS Tape of
Uaer'a Network for Applied Modeling of Air Pollution
(UNAMAPt. EPA; 1980, Version 4, NTIS No. PB81-
16"600.
(11) Turner, D. B.; BUSM, A. D. "Uaer'1 Guides to the Interactive
Vemom of Three Point Source Diapenion Programs:
PTMAX, PTDIX, and PTMTP" 1973, U.S. Environmental
Protection Agency Report EPA/DF/OOlf (NTIS No.
PBSl-164667).
(12) Lewi.a, R G.; Mulik, J. D.; Coutant; R. W.; Wooten, G. W.;
McMillin, C. R Anal. Chem. 1985, 57, 214-219.
Received for review December 19, 1984. Accepted April 5, 1985. A.lthouih the research ducribed in thi.& article wcu funded wholly
or in part by the U.S. Environmental Protection Agency through
Contract 68-02-3745, it Juu not necu,arily reflect the view, of
tM Agency, and no oflicial endoraeTMnt ,houl<i : i inferrec.
Mention of trade namu for commercial producu does not con-
. ,titute endoraement or recommendation for u.ae .
.......,_ Sd. Tedv>ol. vm. 19. No. 10, 1985 H1 ~,
l
·~
INBJN
~ of McGraw•Edison and Union Carbide
Mr. T. Karnoski
Department of Human Resources
Division of Health Services
P .O. Box 2091
Raleigh, North Carolina 27602-2091
Dear Mr . Karnoski:
July 24, 1985
UG t 4 198
This memo is intended to bring you up-to-date on the evolution of PCB
regulations and UNISON's initiation of servicing with our RECLASS-5oSM
Technology.
I have included a synopsis of the final Fire Rule published by the E.P.A. on
July 1, 1985. This Rule is a critical document for all of us involved in the
increasingly complex world of PCBs and toxic chemicals in general.
This summary describes the PCB transformer owner's new obligations as they
relate to buildings, both "commercial" and "industrial", and the time frames
within which certain actions must be taken. Most importantly for UNISON is
the comment on Page 3 regarding "cost-effective reclassification of askarel
PCB transformers to non-PCB status may be on the horizon."
I have also included the data released by UNISON on March 28, 1985 in
Washington, D.C., describing the successful reclassifications to non-PCB
of four pure PCB transformers, and the testimony provided by UNISON's
William H. Martin, Director of Technology, to the recent Senate Sub-Committee.
UNISON is at the forefront of PCB transformer technology. We are servicing
our customers' transformers now with our RECLASS-50SM process and feel that
reclassification to non-PCB is the safest, most economical and best alternative
environmentally (no landfilling of any PCB articles or old transformer
carcasses).
We believe you should pursue the reclassification alternative regarding your
transformer. Continuation of our discussions will be in our mutual best
interests.
Please call if we can be of assistance.
Very truly yours,
/?. "I ~l2-ffi_.A_L-_)
R. J. Shearer
Re gional Business Manager
100 E. Campus View Blvd.• P.O. Box 6005 • Columbus, OH 43085 • [phone]
WASHINGTON, WEDNESDAY, JUNE 19, 1985
NEW TECHNOLOGY FOR
PCB REMOVAL AND
DESTRUCTION
WILLIAM H. MARTIN
Director of Technology
UNISON
/JEFORF. Tiff SUBCOMMITTH" ON lo"NVIRONMI.NTA/.
POI.UT/ON Of-TIii, U.S. Slo"NA U: COMMITTH.
ON ENVIRONMl'NT AN/J PUBI.IC WORl<:S
Jww /Ii, /9X5
I am pleased to appear here today to
summarize the technology developed by
Union Carbide Corporation and offered
through UNISON to remove PCBs from
electrical transformers. I am submitting
written materials for the record describing
our R ECLASS-50 SM Transformer
Service; in my oral comments, I would like
to highlight briefly those aspects of the
process most pertinent to this
Subcommittee's exploration of alternative
waste destruction methods.
The legacy of landfills throughout this
nation and the hazards they pose has led
congress, EPA and numerous scientific
groups to urge that alternative disposal
methods be developed and implemented as
rapidly as possible. The RCRA 1984
Amendments, for example, call for an end to
all landfilling of PCBs by July I 988 unless
EPA rules to the contrary.
Less attention, however, has been focused
to date on the disposal problem specifically
addressed by the UNISON PCB
transformer retrofill method, namely the
collection of hazardous materials such as
PCBs in a manner that makes them available
for disposal by other more permanent
means. As I shall describe, the UNISON
RECLASS-50 SM retrofill method is
designed to remove and destroy PCBs from
electrical transformers. The result is a safer,
non-PCB classified operating transformer --
which when much later at the end of its
useful life is removed from service for
disposal --contains virtually no PCBs in the
transformer carcass. Without such
technologies, considerable quantities of
hazardous materials my still find their way
to landfills via transformer carcasses and
thus lead to continuing long-term PCB
releases to the environment.
We should not let PCBs leaching from
landfilled transformers become the
environmental crisis of the next decade.
Union Carbide's technology solves the dual
issues of asset rejuvenation and permanent
toxic chemical disposition.
The PCB Transformer Problem
In 1976, as part of the Toxic Substances
and Control Act, Congress banned not only
future manufacture, but also continued use
of PCBs. Among the types of electrical
equipment containing and using PCBs are
electrical transformers. EPA estimates that
about 140,000 such transformers --each
containing several hundred gallons of fluid
with 40 to I 00% PCBs --are still in use
throughout the country. The average
transformer is a 2,000 pound ( one ton) PCB
risk.
EPA has authorized continued use of
PCBs in electrical transformers as long as
numerous regulatory controls are met.
These many regulatory controls have
created a strong incentive for transformer
owners to eliminate their PCB problems
altogether.
PCB trnasformer owners have two basic
alternatives if they wish to eliminate their
PCB problems: (I) replacing the PCB
transformer with a new, non-PCB unit, or
(2) draining liquid PCBs from the
transformer, servicing to remove absorbed
PCBs and refilling with a non-PCB coolant.
Retrofill servicing of PCB transformers to
reduce PCB concentrations, thus
reclassifying to non-PCB status (i.e., less
than 50 parts per million PCBs, which is less
than five one thousandths of I percent), is
specifically authorized by EPA.
Replacing a transformer provides the
owner with new non-PCB equipment, but
does not lead to destruction and elimination
of all PCBs. After the old transformer is
drained and its surfaces flushed, the carcass
is typically landfilled intact in accordance
with EPA regulations. Such carcasses still
contain 20 to 100 pounds of PCBs in their
internal workings. Therefore, while PCB
transformers are being phased out,
substantial quantities of hazardous liquid
waste are being put into landfills with
consequent potential for migration of the
PCBs. Thus, after all the effort and expense
to replace, the PCB problem is not
eliminated --just moved from above ground
to below ground where it is much more
difficult and expensive to monitor and
ultimately correct.
The experience of the past decade suggests
that know how for dealing with toxic wastes
in landfill is in short supply. Regardless of
the liners or leachate collection system, no
landfill can be considered secure forever.
Even new state-of-the-art landfills legislated
by Superfund are far from secure. Of the
sites looked at carefully, all are leaking or
appear to be leaking in the opinion of the
EPA hydrogist who conducted the first site
inspections. Society is virtually assured of
PCBs migrating from landfills and thus
reinitiating new cycles of exposures.
UNISON's RECLASS-50 SM servicing
technology, on the other hand, has as its
primary purpose the removal and
destruction of PCBs from the transformer
carcass. The method is designed to remove
safely and economically those last 20 to 100
pounds of PCBs that would otherwise be
sent, along with the carcass, to a landfill.
Removal and destruction are accomplished
in such a manner that only a few grams of
PCBs remain in the internals of the
transformer and less than 50 parts per
million remain in the coolant.
The Need To Remove PCBs
From Transformer Cores
Prior to Union Carbide's development of
RECLASS-50 SM, retrofilling and
reclassification of PCB transformers to non-
PCB status was limited to lightly
contaminated oil transformers (less than
5,000 parts per million PCBs or one-half
percent). Previous attempts to achieve non-
PCB classification with Askarel or pure
PCB transformers (containing up to l00%
PCBs) had been notably unsuccessful.
Draining and rinsing a transformer still
leaves from 1% to 3% of the original PCBs
trapped within the transformer windings.
Surface flushing does not remove the
residual PCBs held within these porous
constituents of a transformer.
When silicones or other commonly used
replacement coolants are placed into freshly
drained and rinsed transformers, they block
the PCBs in the porous materials and thus
impede or prevent removal of PCBs.
Reclassification in the past has occasionally
been achieved not because all PCBs were
removed by the retrofill servicing, but
because the leaching rate had been slowed
down. Actually, about 30% of the original
PCBs held within the windings still
remained after reclassification by most other
methods.
What was needed to solve the
reclassification problem was to concentrate
on technology that removes PCB from the
windings and other porous constituents of
the transformer.Union Carbide launched an
extensive research and development effort in
1982 to determine the mechanisms by which
PCBs were held within transformer internals
and by what means they could most
efficiently be removed. The secrets of how
and where PCBs are held within the
transformer began to unfold, and by late
1983 effective removal techniques had been
demonstrated in our laboratories.
In light of earlier failures in retro fill
technology, Union <;:arbide recognized the
need to demonstrate its method in the field
at full scale. The demonstration has, to date,
successfully reclassified four on-line
transformers to non-PCB status. The final
PCB levels in the fluid of the reclassified
transformers ranged from a low of 5.7 to a
high of 35.7 parts per million. The final PCB
concentrations all approached asymptotes
(a leveling oft) below 50 ppm. Complete
removal also is confirmed by measurements
of PCB material balances. We, therefore,
expect the PCB concentrations in the fluid
of these transformers to remain below 50
parts per million for a long, long time. This
break -through technology accomplishes
what others have not and does so in
consonance with EPA regulations.
Conclusion
The RECLASS-50 SM process is now
being offered throughout the United States
by UNISON. Achievement of non-PCB
classification is accomplished at the
transformer site in a timely, cost-effective
manner, thereby permitting continued use of
the transformers. Most importantly from
the standpoint of hazardous waste disposal,
RECLASS-50 SM removes nearly all PCBs
from the transformers so that they can be
destroyed. Unlike transformer carcasses
that have been merely drained and rinsed
before burial in an underground cell, these
retrofilled transformers will contain no
more than trace quantities of PCBs and thus
will not pose the long-term potential for
PCB migration into the environment.
EPA
FINAL FIRE RULE FOR TRANSFORMERS
A SUMMARY OF FINAL ACTIONS AND
AMMENDMENTS TO-THE AUGUST 1982
"ELECTRIC RULE"
JULY 9, 1985
PROVIDED BY: ......__
INBJN
~ II""':, Jc-::':!-1:!':,': and Union Carbide
100 E. Campus View Blvd.• P.O. Box 6005 • Columbus, OH 43085 • [phone]
ENVIRONMENT AL PROTECTION
AGENCY OFFICE OF
PESTICIDES AND TOXIC
SUBSTANCES
40 CFR PART 761
(OPTS 62035D; TSH FRL)
POLYCHLORINATED BIPHENYLS IN
ELECTRICAL TRA NSFORMERS
AGENCY: Environmental Protection
Agency (EPA)
ACTION: Final Rule.
SUMMARY: This final rule amends
portions of an existing EPA rule concerning
the use of polychlorinated biphenyls (PCBs)
by placing additional restrictions and
conditions on the use of PCB Transformers
(electrical transformers containing 500 parts
per million or greater PCBs.
This rule: 1) prohibits the use of higher
secondary voltage (480 volts and above)
network PCB Transformers in or near
commercial buildings after October 1, 1990,
2) requires, by October 1, 1990, the
installation of enhanced electrical
protection on lower secondary voltage
network PCB Transformers and higher
secondary voltage radial PCB Transformers
in use in or near commercial buildings, 3)
prohibits further installation of PCB
Transformers in or near commercial
buildings after October 1, 1985, 4) requires
the registration, by December 1, 1985, of all
PCB Transformers with fire response
personnel and building owners, 5) requires
the marking, by December 1, 1985, of the
exterior of all PCB Transformer locations,
and 6) requires the removal, by December 1,
1985, of stored combustibles located near
PCB Transformers.
EPA is also requiring that owners of PCB
Transformers involved in fire-related
incidents immediatley notify the National
Response Center, and, take measures as
soon as practically and safely possible to
contain any potential releases of PCBs or
incomplete combustion products to water.
FOR FURTHER
INFORMATION CONTACT:
Edward A. Klein,
Director, TSCA Assistance Office
(TS-799),
Office of Toxic Substances,
Environmental Protection Agency,
Room: E-543,
401 M ST., SW.,
Washington, D.C. 20460,
Toll free: (800-424-9065),
In Washington, D.C.: (554-1404)
Outside the USA:
(202-554-1404),
►
SUMMARY OF THE
FINAL RULE
Under section 6 ( e) (2) (B) of TSCA, EPA
can authorize a use of PCBs provided that
the use "will not present an unreasonable
risk of injury to health or the environment."
EPA's August 1982 decision to allow the
continued use of electrical transformers
containing PCBs was based on the reported
low frequency of leaks and spills of PCBs
from this equipment compared to the high
costs associated with replacing this
equipment with substitute transformers or
requiring secondary containment to limit
the spread of spilled materials.
EPA subsequently undertook an
evaluation of the fire-related risks posed by
the continued use of PCB Transformers, and
the costs and benefits of measures designed
to reduce those risks. On October II, 1984,
EPA issued a Proposed Rule which
contained EPA's determination that PCB
Transformer fire s (fires involving
transformers containing greater than 500
ppm PCBs), particularly fires which occur in
or near buildings, do present risks to human
health and the environment. EPA reached
this determination after considering the
extreme toxicity of materials which can be
formed and released during fires involving
this equipment, as well as the potential for
human and environmental exposures to
these compounds from a single incident, and
the expected frequency of incidents over the
remaining useful life of this equipment.
EPA further determined that the
continued use of PCB Transformers without
additional restrictions does present an
unreasonable risk of injury to health and the
environment. EPA reached this
determination after considering the risks
posed, the costs of cleanup following these
incidents, the availability of adequate
substitute materials, and the costs and
benefits associated with risk reduction
measures. EPA did, therefore, propose
additional regulatory controls on the use of
this equipment.
EPA proposed to require: I) the
immediate registration of all PCB
Transformers with appropriate fire
department jurisdictions, and the immediate
registration with building owners of all PCB
Transformers located in or near buildings, 2)
the immediate marking of the exterior of the
vault door, machinery room door, means of
egress, or grate(s) accessing a PCB
Transformer with PCB identification labels
3) the immediate removal of stored
combustibles from PCB Transformer
locations, 4) the installation, by July I, 1988,
of additional electrical protective devices on
PCB Transformers in or near buildings in
high secondary voltage system ( 480 / 277 volt
systems), and 5) the isolation, by July I,
I 988, of all PCB Transformers in or near
buildings from building ventilation systems,
page 1
building ductwork, and openings in
con~truction to reduce the widespread
contamination of structures and the
environment by smoke and soot in the event
of a PCB Transformer fire. In addition, to
facilitate monitoring compliance with the
isolation requirements, EPA proposed that
PCB Transformer owners maintain records
of their efforts in isolating transformers
through the completion of PCB Smoke
Spread Reduction Plans (PCB-SSRPs).
Finally, in the event of a PCB
Transformer fire, EPA proposed to require
PCB Transformer owners to take immediate
measures to contain potential water
discharges, and to report all PCB
Transformer fire-related incidents to the
National Reponse Center (NRC) prior to
the initiation of cleanup efforts.
This final rule modifies and clarifies some
of the requirements presented in the
Proposed Rule as a result of information
and comments provided to the Agency
during public comment periods and at the
public hearing. In developing the Proposed
Rule, EPA evaluated the risks posed by PCB
Transformer fires in or near buildings by
using an office building setting to evaluate
generically the nature of and potential for
human and environmental exposures to
PCBs and incomplete combustion products.
EPA determined that additional control
measures, principally the isolation of PCB
Transformers from building ventilation
equipment and ductwork, were necessary to
reduce the risks posed by the continued use
of this equipment.
During the public comment period for the
Proposed Rule, EPA received extensive
comments in three specific areas, and has
modified the final rule accordingly. First,
many comments received in response to the
Proposed rule suggested that EPA consider
evaluating separately the fire-related risks
posed by the continued use of PCB
Transformers in industrial locations versus
the fire-related risks posed by the use of PCB
Transformers in or near buildings, such as
office buildings,stores, hospitals and schools
(hereafter, all non-industrial, non-
substation buildings will be referred at as
"commercial buildings"). This final rule
adopts this suggestion and addresses the use
of PCB Transformers in or near industrial
buildings separately from the use of PCB
Transformers in or near commercial
buildings.
Second, many comments on the Proposed
Rule discussed the probability of PCB
Transformer failures and fires, and
suggested that certain types of PCB
Transformers installations, network
installations with higher secondary voltages
(secondary voltages of 480 volts and above,
including 480/277 volt secondaries), may be
particularly likely to be involved in fire-
related incidents. These comments suggest
that if EPA were to pursue additional
restrictions on the use of PCB Transformers,
INBJN 100 E. Campus View Blvd.• P.O. Box 6005 • Columbus, OH 43085 • [phone] p
these installations should be the subject of
more stringent control measures. In
response to these comments, this final rule
considers factors such as the relative
probabilities of failures and fires in different
types of PCB Transformers installations and
places more stringent controls on those
transformers which EPA believes pose
higher risks of failures and fires.
Finally in response to comments on the
Proposed Rule, in this final rule, EPA has
increased its emphasis on the prevention of
PCB Transformer fires through increased
electrical protection, and, decreased its
emphasis on the use of isolation measures to
minimize the spread of already formed
and/ or released contaminants.
This final rule prohibits:
1. The continued use of higher secondary
voltage network PCB Transformers
(network PCB Transformers with secondary
voltages at or above 480 volts, including
480/ 277 volt systems) in or near commercial
buildings beyond October I, 1990.
2. The further installation of PCB
Transformers (which have been placed into
storage for reuse) in or near commercial
buildings.
This final rule also requires:
1. The installation, by October I, I 990, of
enhanced electrical protection on lower
secondary voltage network PCB
Transformers and on higher secondary
voltage radial PCB Transformers (radial
PCB Transformers with secondary voltages
at or above 480 volts, including 480 / 277
volts systems) used in or near commercial
buildings.
2. The registration by December I, 1985 of
all PCB Transformers with fire departments
or fire brigades with primary response
function, and, the registration, by December
I, 1985, of all PCB Transformers located in
or near buildings with building owners.
3. The marking, by December I, 1985, of
the exterior of all PCB Transformer
locations ( excluding grates and manhole
covers).
4. The removal, by December I, 1985, of
combustible materials stored within a PCB
Transformer enclosure, within 5 meters of a
PCB Transformer enclosure, or within 5
meters of an unenclosed PCB Transformer.
This rule also requires the immediate
notification of the National Response
Center in the event of a PCB Transformer
fire-related incident; and, that PCB
Transformer owners take measures as soon
as practically and safely possible to contain
any potential water releases associated with
a PCB Transformer fire-related incident.
associated with a PCB Transformer fire-
related incident. These measures include,
but are not limited to, the blocking of floor
drains, the containment of water runoff, and
the control and treatment of cleanup water
prior to discharge.
Fire events involving the rupture of PCB
Transformers can lead to contamination of
►
sewers, sewage treatment systems, sewage
sludges and bodies of water. Liquid PCBs
and incomplete combustion products such
as dioxins or furans may be conveyed
through drains into storm or sanitary sewer
sytems. This process is facilitated when
water is used in firefighting operations or is
present as a result of the rupture of water
pipes. Disruption of sewage treatment
processes can also be caused, and eventually
contaminants may be discharged into
receiving waters poorly treated or not
treated at all.
Contamination of receiving waters
presents a risk of long lasting adverse effects
on aquatic life and bottom sediment, as well
as threats to public health through
contamination of drinking water supplies
and direct public contact with contaminated
water.
The cost of cleaning up contaminated
sewer systems and associated treatment
facilities may be very high. Sludge
contaminated with PCBs, dioxins and
furans may be required to be handled and
disposed of as hazardous waste under the
Resource Conservation and Recovery Act
(RCRA) and pursuant to the PCB
regulations under the Toxic Substances
Control Act (TSCA). Clean up of water
bodies and bottom sediments, if possible,
would also be very expensive. Data
indicating water and sewer treatment system
contamination following the Binghamton
fire confirm that water treatment facility
sludge can become contaminated with PCBs
as result of releases during PCB
Transformer fires.
For these reasons, it is important that
sewer systems and treatment plant operators
have as much notice as possible of a PCB
Transformer fire event. The sooner this
information is available, the sooner action
can be taken to isolate or contain
contaminants (if possible), to limit their
spread and to assure proper handling.
Fire departments are required to be
notified pursuant to §761.30 (a) (I) ( vi) of
this regulation as to the location of PCB
Transformers. Fire departments generally
maintain good information for response to
emergencies and have plans and a
coordinating capacity for dealing with fires
involving hazardous materials. EPA,
therefore, strongly urges fire departments,
on a voluntary basis, to contact storm and
sanitary sewer system and treatment plant
operators in the areas served by the fire
department, once the information required
to be submitted to the fire departments
under §761.30 (a) (I) (vi) is available. EPA
also urges the fire department to work with
sewer system and treatment plant operators
to develop contingency plans for handling
contamination entering the sewers as a result
of PCB Transformer fire events.
· EPA also urges owners of PCB
Transformers and owners of buildings in
which those transformers are located to plan
ahead for a fire event. Building owners,
page 2
working with other parties, should plan their
best course of action to prevent or limit
release of PCBs and other contaminants in
the event of a fire. These plans should give
special consideration to the location of
individual PCB Transformers, the location
of drains near these transformers, and
methods for closing the drains in the event of
a PCB Transformer fire.
To support this voluntary cooperative
effort, EPA will develop guidance for use by
owners and operators of sanitary sewer
systems and treatment facilities, pointing
out the availability at local fire departments
of information on the location of
transformers and the potential impact of the
release of PCBs and other contaminants into
the sewer system in the event of a fire. EPA
will also evaluate the possible roles of
organizations such as the Water Pollution
Control Federation, the Association of
State and Interstate Water Pollution
Control Authorities, the American Public
Works Association, and the National Fire
Protection Association in distributing
information, and may request their
cooperation in this effort.
For purposes of this rule, commercial
building is defined as a non-industrial (non-
substation) building which is typically
accessible to both members of the general
public and employees. Commercial buldings
include: 1) public assembly properti~s, 2)
educational properties, 3) institutional
properties, 4) residential properties, 5)
stores, 6) office buildings, and 7)
transportation centers (i.e., airport terminal
buildings, subway stations, bus stations, and
train stations.). For purposes of this rule, "in
or near" a commercial building is defined as:
I) within the interior of a commercial
building, 2) on the roof of a commercial
building or attached to the exterior wall of a
commercial building, 3) in the parking area
of a commercial building, or 4) located
within 30 meters of a commercial building.
An industrial building is defined as a
building directly used in manufacturing or
technically productive enterprises.
Industrial buildings are not generally or
typically accessible to other then workers.
Industrial buildings include buildings used
directly in the production of power, the
manufacture of products, the mining of raw
materials, and the storage of textiles,
petroleum products, wood and paper
products, chemicals or plastics, and metals.
EPA has m:rermined that requiring the
removal of particularly high risk PCB
Transformers from use and adding
conditions and restrictions on the use of the
remaining PCB Transformers (including
enhanced electrical protection, registration,
and labeling) will significantly reduce the
fire-related risks posed by the use of PCB
Transformers. EPA has determined that the
continued use of PCBs in PCB
Transformers which comply with the
conditions and requirements described
above do not present unreasonable risks to
(NBJN 100 E. Campus View Blvd.• P.O. Box 6005 • Columbus, OH 43085 • [phone] p
requirements of §761 .60. Cleanup of the
released PCBs must be initiated as soon as
possible, but in no case later than 48 hours of
its discovery. Until appropriate action is
completed, any acrive leak of PCBs must be
contained ro prevent exposure of humans or
the environment and inspected daily to
verify containment of the leak. Trenches,
dikes, buckets, and pans are examples of
proper containment measures.
(xi) If a PCB Transf ormer is involved in a
.fire-related incident, the owner of the
transformer must immediately report rhe
incident to the National Response Center
(toll-free /-800-424-8802; in Washington,
D. C. 202-426-2675). A fire-related incident
is defined as any incident involving a PCB
Transformer which involves the generation
of sufficient heat and/ or pressure (by any
source) to result in the violent or non-violent
rupture of a PCB Transf ormer and the
release of PCBs. Information must be
provided regarding the type of PCB
Transformer installation involved in the
fire-related incident (e.g., high or low
secondar.11 voltage network transf ormer,
high or low secondary voltage simple radial
system, expanded radial system, primary
selected system, primary loop system, or
secondary selective system or other systems)
and the readily ascertainable cause of the
fire-related incident (e.g., high current fault
in the primary or secondary or low current
fault in secondary). This information
collection requirement was approved by the
Office of Management and Budget under
Control Number: 2070-. The owner of the
PCB Transformer must also take measures
as soon as practically and safely possible to
contain and control any potential releases of
PCBs and incomplete combustion products
►
into water. These measures include, but are
not limited to:
( A) The blocking of al/floor drains in the
vicinity of the transformer.
( B) The containment of water runoff
(CJ The control and treatment (prior to
release) of any water used in subsequent
cleanup operations.
(xii) Records of inspectio n and
maintenance history shall be maintained at
least 3 years after disposing of the
trans/ armer and shall be made available f or
inspection, upon request by EPA (OM B
Control Number: 2070-0003 ). such records
shall contain the follo wing information for
each PCB Transformer:
(A) /fs location.
(B) The date of each visual inspection and
the date that leak was discovered. if different
from the inspection date.
(C) The person performing the inspection.
( D) The lo cat ion of any leak(s).
(£) An estimate of the amount of
dielectric fluid released.from any leak.
( F) The date of any cleanup, containment,
repair, or replacem ent.
(G) A description of any cleanup,
containment, or repair performed.
(H) The results of any containment and
daily inspection required f or uncorrected
active leaks.
(xiii) A reduced visual inspection
frequency of at least once every 12 months
applies to PCB Transformers that utilize
either of the following risk reduction
measures. These inspections may rake place
any time during the calendar year as long as
page 5
there is a minumum of /80 days between
inspect ions.
(A) A PCB Transformer which has
imper v ious, undrained, secondary
containment capacity of at least 100 percent
of the total dielectric fluid volume of all
transformers so contained or
(BJ A PCB Trans.former which has been
tested and found to contain less than 60,000
ppm PCBs (afr er 3 months ofin service use if
the transformer has been serviced for
p u r p o s e s of red u c in g t h e P C B
concenrrarion).
(xiv) An increased visual inspecrion
frequency of at leasr once every week applies
ro any PCB Transformer in use or stored f or
reuse which poses an exposure risk to food
or f eed. The user of a PCB Tran sf armer
posing an exposure risk ro f ood is
r esp o n sible fo r rh e ins p ecri o n
r ecordkeeping, and mainre nance
requirem ents under rhis section until the
user notifies the owner that the transformer
may pose an exposure risk to f ood or feed.
Following such norificarion, iris rhe owner's
ulrimar e responsibiliry ro derermine wherher
the PCB Trans.former poses an exposure
risk w f ood or f eed.
4) In §76/.40, paragraph (j) is added ro
read as .follows:
§761.40 Marketing requirements.
* * * * * * * * * * * * *
9()) As of December I. /985, rhe vaulr
door, machinery room door.f ence, hallway,
or means of access (orher rhan grates and
manhole covers) ro a PCB Transformer
musr be marked with rhe mark ML, The
mark mus1 be placed so rhar ir can be easily
read b.v .firemen fighting a.fire involving rhis
equipmenr.
INBJN 100 E. Campus View Blvd. • P.O. Box 6005 • Columbus, OH 43085 • [phone] p
public health or the environment. Further,
after considering the risks posed by fires
involving transformers containing less than
500 ppm PCBs, and the costs of regulatory
control measures, EPA is reaffirming its
August I 982 determination that the
continued use of PCB-Contaminated
transformers and non-PCB transformers
(transformers containing 50-500 ppm PCBs,
and less than 50 ppm PCBs, respectively) do
not present unreasonable risks to public
health and the environment.
The enhanced electrical protection
requirements for higher secondary voltage
radial PCB Transformers consist of the
installation of protection against
transformer failures from sustained low
current faults. EPA has determined that the
enhanced protection of these PCB
Transformers is necessary to reduce the fire-
related risks posed by the continued use of
these transformers in commercial locations.
This protection will reduce the frequency of
PCB Transformer fires in these types of
transformers by allowing for rapid
deenergization in the event of a sustained
low current fault.
While EPA is a ware of at least five basic
types of radial installations (simple radial
systems, expanded radial systems, primary
selective systems, primary loop systems, and
secondary selective systems), existing data
do not indicate that the probability of low
current fault-related failures would be
significantly different among these five types
of radial installations. Thus, EPA has
required enhanced electrical protection on
all commercial higher secondary voltage
radial PCB Transformers.
EPA recognizes, however, that additional
experience and further research into the
causes of PCB Transformer failures and
fires may result in the development of data
by industry which would indicate that there
are significant differences in the
probabilities of fault-related failures among
the different types of radial systems. If these
data are developed, they should be
submitted to EPA for consideration. Based
on the timely submission of new
information, that is, within 2 years of the
date of promulgation of this final rule, EPA
may chose to revisit this particular
requirement.
The remainder of this preamble describes
the basis for the determinations reached in
this final rule.
RETROFILLING OF
PCB TRANSFORMERS
I). Introduction. Two general types of
substitutes for PCBs in transformers stand
out as the best retrofill candidates. These
fluids are silicones and high temperature
hydrocarbons (HTH). The principal
questions to be considered are the cost of
retro fill versus the value of the remaining life
of the transformer and the qualification of
the fluid as "less flammable" for insurance
purposes. A related question is the potential
for the formation of toxic products of
►
incomplete combustion from the retrofill
fluid and remaining residual concentrations
of PCBs. Other fluids, such as chlorinated
hydrocarbons, fluorocarbon, and mineral
oil, are used in new transformers but are
inappropriate for retrofilling because the
design of the PCB Transformers does not fit
the properties of the fluids.
Experience with retrofilling to date
indicates that reclassification of askarel
PCB Transformers to non PCB status is
often not cost-effective. Reclassification to
PCB Contaminated status, however, has
been accomplished in a cost-effective
manner for a number of askarel PCB
Transformer units. Testimony at the public
hearing, however, indicates that retrofill
technology continues to evolve, and, that
cost-effective reclassification of askarel PCB
Transformers to non PCB status may be on
the horizon.
2). Silicones. There are six silicone fluids
sold by six different companies for use as
dielectric fluid . Four of the six fluids have
been approved by Factory Mutual Research
Corporation (FM RC) as "less flammable"
fluids. Silicones have a higher viscosity than
PCBs and are therefore not quite
comparable to PCBs as a coolant. For this
reason, it is possible that transformers
retrofilled with silicone would have to be
derated. According to one silicone fluid
manufacturer, if the transformer were fully
loaded, a derating not exceeding 5 percent
could be necessary. (Derating means
lowering the maximum level of electrical
load that the transformer can handle.)
It has been mentioned in the literature
that a leaking problem could be created
because silicone fluids are not compatible
with silicone rubber gaskets and the
coefficient of expansion of silicone fluids is
50 percent greater than that of PCBs. In
actual practice, however, the silicone gaskets
are replaced during retrofilling. (Further,
even though the coefficient of expansion is
greater than that for PCBs, the greater
solubility of the filler gas (nitrogen) in
silicone eliminates the expected increase in
pressure.)
3). HTHs. There are six HTH fluids sold
by five companies that may be used as
transformer dielectric fluids. There are also
two products sold by two other companies
that when mixed with other products may be
used as HTH transformer fluids. Three of
the six fluids are paraffinic based oils and
three are esters. As mentioned earlier, the
three esters are more specialized for use in
railroad transformers.
The other three fluids are more viscous
than the silicones at lower temperatures, but
thin more rapidly at higher temperatures.
According to an HTH manufacturer, this
property allows the transformers to be
retrofilled with HTH without any derating.
At lower normal load temperatures,
however, the transformers do run hotter.
page 3
These fluids are completely compatible with
the materials that make up PCB
Transformers, and they are soluble in PCBs.
Two of these fluids are approved by FM RC
as "less flammable transformer fluids," and
the fire point of the third is over 300°C.
Because the paraffinic HTHs have high
convective and radiant heat release rates, the
owner's in surance company may
recommend more stringent installation
requirements.
THEREFORE, 40 CFR PART
761 IS AMENDED AS FOLLOWS:
1 ). The authority citation for Part 761 is
revised to read as follows:
AUTHORITY: 15 U.S.C. 2605, 2607, and
2611.
2). In §761 .3, the following paragraphs are
alphabetically added to read as follows:
§761.3 Definitions.
* * * * * * * * * * * * *
"In or Near Commercial Buildings"
means within the interior of. on the roof of.
al/ached to the exterior wall of. in the
parking area serving, or within 30 meters of
a non-industrial non-substation building.
Commercial buildings are typically
accessible to both members of the general
public and employees, and include: (I)
public assembly properties, (2) educational
properties, (3) institutional properties, (4)
residential properties, (5) stores, (6) office
buildings, and (7) transportation centers
(e.g., airport terminal buildings, subway
stations, bus stations, or train stations).
* * * * * * * * * * * * *
"Industrial building" means a building
directly used in manufacturing or
technically productive enterprises.
Industrial buildings are not generally or
typically accessible to other than workers.
Industrial buildings include buildings used
directly in the production of power, the
manufacture of products, the mining of raw
materials, and the storage of textiles,
petroleum products, wood and paper
products, chemicals, plastics, and metals.
* * * * * * * * * * * * *
"Manned Control Center" means an
electrical power distribution control room
where the operating conditions of a PCB
Transformers are continuously monitored
during the normal hours of operation (of the
facility), and, where the duty engineers,
electricians, or other trained personnel have
the capability to deenergize a PCB
Transformer completely within I minute of
the receipt of a signal indicating abnormal
operating conditions such as an
overtemperature condition or overpressure
condition in a PCB Transformer.
* * * * * * * * * * * * *
"On site" means within the boundaries of
a contiguous property unit.
CNISJN 100 E. Campus View Blvd.• P.O. Box 6005 • Columbus, OH 43085 • [phone] p
"Rupture of a PCB Transformer" means a
violent or non-violent hreak in the integrity
of a PCB Transformer caused by an
overtemperature and/ or overpressure
condition 1ha1 results in 1he release of PCBs.
3 ). In §761.30, paragraph (a) (I) is revised
to read as fallows:
§761.30 Authorizations.
(a) Use in and servicing of transformers
(other than railroad transformers). PCBs at
any concentration may be used in
transformers (other than in railroad
locomo1 ives and self-propelled railroad
cars) and may be used for purposes of
servicing including rebuilding these
transformers for the remainder of their
useful lives, subject to the following
conditions:
/). Use conditions. (i) As of October I,
1985, the use and storage for reuse of PCB
Transformers that pose an exposure risk to
food or feed is prohibited.
(ii) As of October 1, /990, the use of
network PCB Transformers with higher
secondary voltages (secondary voltages
equal to or greater than 480 volts, including
480/ 277 volt systems) in or near commercial
buildings is prohibited. Network PCB
Tran sf armers with higher secondary
voltages which are removed from service in
accordance with this requirement must
either be reclassified to PCB Contaminated
or non PCB status, placed into storage for
disposal, or disposed.
(iii) As of October I, /985, the installation
of PCB Transformers (which have been
placed into storage for reuse or which have
been removedfrom another location) in or
near commercial buildings is prohibited.
(iv) As of October I, 1990, all radial PCB
Transformers and lower secondary voltage
network PCB Transformers (network
transformers with secondary voltages below
480 volts) in use in or near commercial
buildings must be equipped with electrical
protection to avoid transformer failures
caused by high current faults. Current-
limitingf uses or other equivalent technology
must be used to detect sustained high current
faul!s and provide fo r complete
deenergization of the transformer within
several tenths of a second of detection,
before transformer failure occurs. The
installation, selling, and maintenance of
current-limiting fuses or other equivalent
technology to avoid PCB Transformer
failures from sustained high current faults
must be co mpleted in accordance with good
engineering practices.
(v) As of October 1, 1990, all radial PCB
Transformers with higher secondary
voltages (480 volts and above, including
►
480/ 277 volt systems) in use in or near
commercial buildings must (in addition to
the requirements o_fparagraph (a)(J)(iv)of
this section) be equipped with protection to
avoid transformer failures caused by
sus1ained low current faults.
( A) Pressure and temperature sensors (or
other equivalent technology which has been
demonstrated to be effective in the early
detection of sustained low current faults)
must be used in these transformers 10 detect
sustained low current faults.
(B) Disconnec1 equipment must be
provided to insure complete deenergization
of the transformer in the event of a sensed
abnormal condition ( e.g., an overpressure or
overtemperature condition in the
transformer), caused by a sustained low
current fault. The disconnect equipment
must be configured to operate automatically
within 30 seconds to I minute of the receipt
of a signal indicating an abnormal condition
from a sustained low current fault, or can be
configured to allow for manual
deenergization from a manned on-site
control center upon the receipt of an audio
or visual signal indicating an abnormal
condition caused by a sustained low current
fault. Manual deenergization from a
manned on-sire control center must occur
within I minute of the receipt of the audio or
visual signal indicating a~ abnormal
condition caused by a sustained low current
fault. If automatic operation is selected and
a circuit breaker is utilized for
disconneclion, it must also have the
capability to be manually opened if
necessary.
(C) The enhanced electrical protective
system required for the detection of
sustained lo w current faults and the
complete and rapid deenergization of
transformers must be properly installed,
maintained sensitive enough (in accordance
with good engineering practices) to detect
sustained lo11· current faults and allo w for
rapid and total deenergization prior to PCB
Transformer rupture (either violent or non
violent rupture) and release of PCBs.
(vi) As of December 1, 1985, all PCB
Transformers (including PCB Transformers
in storage f or reuse) must be registered with
fire response personnel with primary
jurisdiction (that is, the fire department or
fire brigade which would normally be called
upon ini1ial response to afire involving the
equipment). Information required to be
provided to fire response personnel includes:
(A) The location of the PCB
Transformer(s) (the address(es) of the
building(s) and the physical location of the
PCB Transformer(s) on the building site(s)
and for outdoor PCB Transformers, the
loca1ion of the outdoor substation).
( B) The principal constituent of the
dieleC!ric fluid in the transformer(s) (e.g.,
PCBs, mineral oil, or silicone oil).
(C). The name and telephone number of
the person 10 contacl in the event of a fire
page 4
involving the equipment.
This informa1ion collection requirement
was approved by the office o_f Management
and Budget under Control Number: 2070-
(vil) As of December I, I985, PCB
Transformers in use in or near commercial
buildings must be registered with building
owners. For PCB Transformers localed in
commercial buildings, PCB Transformer
owners must regis1er !he 1ransformers with
the building owner of record. For PCB
Transformers located near commercial
buildings, PCB Transformer owners must
register 1he 1ra11sformers wi1h all owners of
buildings located within 30 meters of the
PCB Tran~former(s). Information required
to be provided to building owners by PCB
Tran~former owners included but is not
limited to:
(A) The specific /oca1ion of the PCB
Transformer(s).
(B) The principal co nstituent of the
dielectric fluid in the 1ransformer(s) (e.g.,
PCBs, mineral oil, or silicone oil).
(C) The type of transformer installation
(e.g., 208/ 120 volt net work, 208 / 120 volt
radial, 208 volt radial, 480 volt network,
480 / 277 volt network, 480 volt radial
480 / 2 77 vol! radial).
This informa1ion collec1ion requirement
was approved by the Office of Management
and Budget under Control Number; 2070-
(viii) As of December I. I 985.
co mbustible ma1erials, including, but not
limited to paints, solvents, plastics, paper,
and sawn wood must not be s/Ored wi1hin a
PCB Transformer enclosure (i.e .. in a
tran~/ormer vault or in a partitioned area
housing a transformer); wi1hin 5 meters of a
transformer enclosure, or, if unenclosed
(unpartilioned), within 5 meters of a PCB
Tran~former.
(ix) A visual inspection of each PCB
Transformer (as defined in the definition o_f
"PCB" Transformer" under §761.3) in use or
sroredfor reuse shall be performed at least
once every 3 m onths. These inspections may
take place any time during the 3-month
periods: January-March, April-June, July-
Seplember, and October-December as long
as there is a minimum of 30 days between
inspections. The visual inspection must
include investigation .for any leak of
dielectric fluid on or around the
tran~former. The extent of the visual
inspections will depend on the physical
constraints of each tran~former ins1alla1ion
and should not require an electrical
shu1down of the transformer being
inspected.
(x) If a PCB Transformer is found to have
a leak which results in any quantity of PCBs
running off or about to run off the external
surface of the transformer, then the
transformer must be repaired or replaced to
elimina1e the source of 1he leak. In all cases
any leaking material must be cleaned up and
properly disposed of according to disposal
INBJII 100 E. Campus View Blvd.• P.O. Box 6005 • Columbus, OH 43085 • [phone] p
.. "'M~-, . . It ILL--"' -L_ .. NORTH CAROLINA · 11t·eJI DEPARTMENt oF~HuMAN REsouRcEs . TO . INTER OFFICE MEMORANDUM · DATE 7/2/85 TO Ms. Drury -------------------FROM _____ Dr_._L_e_v_in_e _________ _ Her~•s another fun item to while away your hours after the General Assembly adjourns. Sho~ld we meet to discuss? cc, ~;am L. Meyer through Jam~amey <----'. DHR Form 2 (8/75)
.. ~'-· .•. ~-·~~~
North Carolina Department of Human Resources
Division of Health Services
P.O. Box 2091 • Raleigh, North Carolina 27602-2091
James G. Martin, Governor
Phillip J. Kirk, Jr., Secretary
Ronald H. Levine, M.D., M.P.H.
July 1, 1985
MEMORANDUM
TO: Ronald H. Levine, M.D., M.P.H.
State Health Director
FROM: James F. Stamey, Chief-J./t--7..--
Environmental Health s?c't~on ,
SUBJECT: PCB Landfill, Warren County
State Health Director
733-2870
The PCB landfill has two environmental permits in force -a TSCA permit
issued by EPA and a non-discharge wastewater permit issued by DEM. Both permits
were applied for and issued to the Department of Crime Control and Public Safety.
The Secretary of CCPS is responsible for complying with all permit conditions.
We were assigned the task of performing required inspections and monitoring. The
Secretary of CCPS is still responsible for ensuring availability of resources for
post-closure maintenance activities that may be identified by future inspections.
In accordance with the federal permit, monthly and semi-annual inspections
are performed by our Agency. The reports have been prepared and given to
Mr . Bill Phillips, Assistant Secretary, for formal distribution. Bill Phillips
has decided that he no longer wishes to be included in the reporting process and
has so advised EPA and Bill Meyer. Reports are to be sent to EPA, Division of
Environmental Management, Attorney General, and Warren County Health Department.
Distributing the reports seems a small task since we have to do the investiga-
tions. Nevertheless, we are concerned that since no other person in CCPS has been
identified even to receive reports this is a significant turn of events.
I do not think we should let CCPS walk off and dump this whole future landfill
burden and responsibility in our lap. I believe that the Secretary of CCPS should
be advised by Secretary Kirk of his responsibilities regarding these permits. We
should refuse to accept the landfill_ and all its joys as "ours".
cc: Mr. W. L. Meyer
An Equal Opportunity / Affirmative Action Employer
---·
July 1, 1935
MEMORANDUM
TO: Ronald H. Levine, H.D., H.r.H.
State Health Director
FROM: James F. Stamey, Chief ,~·
Environmental Health Section
SUBJECT: PCB Landfill, Warren County
The PCB landfill has two environmental permits in force -a TSCA permit
issued by EPA and a non-discharr,e wastewater permit issued by DF.M. Jloth permits
were applied for and issued to the Department of Crime Control nnd Public Safety.
The Secretary of CCPS is responsible f or complying with all permit conditions.
He were assigned the task of performinp; required inspections and monitorin~. The
Secretary of CCPS is still responsible for ensuring avail ability of res ources for~
poat-closure maintenance a ctivities that may be identified hy future ins pections.
In accordance with the fede ral permit, monthly and semi -annu;il ins pections
are performed by our Agency. The reports have been prepar ed and given to
Hr. Bill Phillips, Assistant Secretary, for formal distribution. Rill Phillips
has decided that he no longer wishes to be included in the r eportin?, process and
has ao advised EPA and Bill Mey er. Reports are to be s ent to EPA, Division of
Environmental Management, Attorney General, and Warren County Health Department.
Distributing the reports seems a small task since we have to do the investiga-
tions. Nevertheless:, :we are concerned that since no other person in CCPS has been
identified even to receive reports this is a significant turn of events.
I do not think we should let CCPS walk off and dump this whole future landfill
burden and responsibility in our lap. I believe that the Secretary of CCPS should
be advised by Sectetary Kirk of his responsibilities regarding these permits. We
should refuse to accept the landfill and all its joys as 11 ours".
cc: Mr. W. L. Meyer
_f]~ ;-; r p~~ ~~ To {L ,
North Carolina Department of Human Resources
Division of Health Services
P.O. Box 2091 • Raleigh, North Carolina 27602-2091
James G. Martin, Governor
Phillip J. Kirk, Jr., Secretary Ronald H. Levine, M.D., M.P.H.
June 27, 1985
TO:
THROCill:
FROM:
SUBJECT:
Ronald H. Levine, M.D., M.P .H.
James F. Stamey, Olief
Environmental Health Section
William L. Meyer, '&ad
Solid and Hazardous Waste Management Branch
Environmental Health Section
PCB Landfil 1, Warren C.ounty
State Health Director
919/733-3446
In accordance with 1=ae conditions of/1~ federaUy issued pennit, monthly and
semi-ann~ inspections are perfonned:il1~~'r post-closure maintenance.
The ~ of these inspections have, in the past, been forwarded to William
Phillips, (Assistant to the Secretary, Department of Crime C.ontrol and Public
Safety) for fonnal distribution. Mr. Phillips has indicated that ~ wishes to . t
be left out of the reportino process.4,w) ND pWiso ~,._,,, h/l.~ 6,ep,,., l\'.:IJ1-i-,J-~ ·to (l,.Q..(q·,ut,., 1~~rri;,•'-~1<; ' --o ' • I >' ~ [V.. l p</i ~ 11.)'S iJ,;-, I
\,'f'\l)t 6•h·«-1·\\t~\sLc...V1.v 1~'+-t'..c.-1 /Vo-J,j, •\ 'l
I \,D11]d like-t-e--·eake responsibility for keeping interested individuals
irfiu11ud of all inspection results. These would include Paul Wi Ji\ls' (Director,
Division of Environmental Management), Jee:::i:eoggn (.AetiJ;ig Director, Warren
C.otmty Health Department), Ai.a, l lt~s (Assistant Attorney General, Department
of Justice), and Jarn a 9 11tfs8igh (Chief, Residuals Management Branch,
EPA-Region IV). Tan Kamoski of my staff will be the lead individual for
these activities.
The landfill requires two environmental pennits--a TSCA pennit issued by EPA
for overall landfill operation and a non-discharge pennit issued by DEM for
the leachate treatment system. Both penni~ ai issu,eq to the 1lartment of
Crime Control and Public Safety. A.. i!!ih, :rt ~~a ~ecretary ~' a CC P S ~
responsibility to comply with all pennit conditions. I am requesting that you
inform him that while the Solid and Hazardous Waste Management Branch will
perform required inspections and monitoring, it is still his responsibility to
ensure the availability of resources for post-closure maintenance activities&f"
')\ f IIO (,u__ I ,1,..... rf" ,-~ 4--~ s 1.,L+\.I IV--I/ J: ( ,_.,. f-,-.. c\,o: ~ 1
TCl<:ct/2900A
w NORTH CAROLINA DEPARTIIENT OF HUIIAN RESOURCES ' , TO ____________ DA TE _____ _ FROll ____ _._{p-+---'-("3+-'/tb"-----"-S __ D For your information D KHp D Return D File D For your signature D For your approval 0 Note and see me about thla , Pl ease D Prepare a reply D Your signature O My signature 0 Send me a copy of reply 0 Your comments D Take charge of this , Please D Attach requested information 0 lnltl
.... NORTH CAROLINA DEPARTMENT OF HUMAN RESOURCES INTER OFFICE MEMORANDUM DATE 7 U ~ / f'>-# ' . TO Id« FROM I * e,,c_ <t P> /4.t..-z.-~ ~ fe.,f!, LA:::-~ ~ (se..c.. ~ ~ s ~~ -to t-e.v~ -:1~ I/ iq'2c; I ~ ~ fel> ~ J 'i'&S-~~ 1y-L--) .. -r~ c.Q_ o.--s~ ~ "1-~ . . ~/~~~~ ~~-/:;-cLr-A--tr~ ~ ~~~~ LAM~ ~~ ~ ~ ~ UIH v-) M.B) . OHR Form 2 (8/75) !G-~~
., \ NORTH CAROLINA DEP~RT~ENT OF HUMAN RESOURCES -.,__ I \ J,,,.,/'J'r \ TO ___ -=-----~----DATE --FROM _____ J~O~"'---------------0 For your information D KHp O Return &File D For your signature D For your approval D Note end see me about this, Please D Prepare a reply D Your aigneture D My signature D Send me • copy of reply D Your comments D Take charge of this , Please D Attach requeated information D Initial end route to ,o tt/lfM,i c>v/l., i) 1jT/2 I B0110 A/ o ~ /10-v 1"61 t 1v ilir'oJl.'3 DH R 8 6 3/78
UN 10
State of North Carolina
Department of Natural Resources and Community Development
512 North Salisbury Street• Raleigh, North Carolina 27611
James C. Martin, Governor
Mr. William W. Phillips, Jr.
Assistant to Secretary
N. C. Department of Crime Control
and Public Safety
P.O. Box 27687
Raleigh, North Carolina 27611
S. Thomas Rhodes, Secretary
May 30, 1985
SUBJECT: Permit No. 7634R3
Dear Mr. Phillips:
North Carolina Department of Crime
Control and Public Safety
Warren County PCB Landfill
Wastewater Treatment and Disposal Facility
Warren County
In accordance with your application received March 30, 1985, we are forwarding
herwith Permit No. 7634R3, dated May 30, 1985, to the North Carolina Department
of Crime Control and Public Safety for the continued operation of the subject
existing nondischarge type wastewater treatment and disposal facilities.
This permit shall be effecti~e from the date of issuance until June 1, 1990,
shall be subject to the conditions and limitations as specified therein, and
shall void Permit No. 7634R2, issued June 15, 1983.
If any parts, requirements or limitations contained in this permit are
unacceptable to you, you have the right to an adjudicatory hearing before a hearing
officer upon written demand to the Director within thirty (30) days following
recipt of this permit, identifying the specific issues to be contended. Unless
such demand is made, this permit shall be final and binding.
One (1) set of approved plans and specifications is being forwarded to you.
If you have any questions or need additional information concerning this matter,
please contact Mr. Robert Teulings, telephone No. 919/733-5083, ext. 120.
Sincerely y&urs •
()figtna\ Si.gned Y
ART~UI' MOUB£RR't
for.
R. Paul Wilms
Director
cc: Warren County Health Department
PO. Box 276ffl. Ralcigh, North Carolina 27611-7687 Tdcp~ 919-733-4984 Mr. William L. Meyer
Mr. Dennis R. Ramsey An Equal-Opportunity/ Affirmative Action Employer
Raleigh Regional Supervisor
RPT/cgc
NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF NATURAL RESOURCES AND COMMUNITY DEVELOPMENT
RALEIGH
P E R M I T
For the Discharge of Sewage. Industrial Wastes, or Other Wastes
In accordance with the provisions of Article 21 of Chapter 143. General
Statutes of North Carolina as amended. and other applicable Laws, Rules and
Regulations
7.
r.J·,;:
PERMISSION IS HEREBY GRANTED TO
N. C. Department of Crime Control and Public Safety
Warren County
FOR THE
operation of 0.80 MGal. nondischarge type wastewater treatment facility consisting
of a 10 GPM influent pump with leachate collection system and sump, a 52-square
feet sand filter, a 26-square feet activated carbon filter, a 0.80 MGal. holding
pond with rainwater diversion pipe and valve, a 500 GPM portable effluent irrigation
pump, and approximately 4.5 acres of irrigation area to serve the Warren County
PCB Landfill with no discharge of wastewater to the surface waters of the State,
pursuant to the letter of request received March 20, 1985, and in conformity with
the project plans, specifications, and other supporting data. subsequently filed
and approved by the Department of Natural Resources and Community Development and
considered a part of this permit.
This permit shall be effective from the date of issuance until June 1. 1990,
shall void Permit No. 7634R2 issued June i6. 1983, and shall be subject to the following
specified conditions and limitations:
1. This permit shall become voidable unless the facilities are constructed in
accordance with the approved plans, specifications and other supporting data.
2. This permit is effective only with respect to the nature and volume of wastes
described in the application .and other supporting data.
3. The facilities shall be properly maintained and operated at all times.
41 The wastewater collected by this system shall be adequately treated in the Warren
County PCB Landfill Wastewater Treatment Facility and analyzed for PCB concentration
prior to being discharged onto the receiving landfill surface irrigation area.
5. This permit is not transferable.
~ermit No. lb43R3
Page Two
6. This permit shall become voidable in the event of failure of the landfill surface soil
to adequately absorb the wastes. and may be rescinded unless the facilities
were installed, maintained and operated in a manner which will protect the
assigned water quality standards or the surface waters and ground waters.
7. In event the facilities fail to perform satisfactorily, the Permittee shall
take such immediate corrective action as may br required by this Department.
8. Solids, sludges, or other pollutants removed or resulting from the wastewater
storage facilities shall be contained and disposed of in such a manner as to
prevent any contamination of the surface or groundwaters of the State.
9. The Permittee shall employ a certified wastewater treatment plant operator in
responsbile charge of the wastewater treatment facilities. Such operator must
hold a certificate of the grade at least equivalent to the classification
assigned to the wastewater treatment facilities by the Certification Commission.
10. Diversion or bypassing of the untreated wastewater from the treatment facilities
is prohibited.
7
11. All of the effluent wastewater from the treatment facilities shall be discharged
onto tne'Warren County PCB Landfill surface irrigation area and no wastewater
shall be discharged to the surface waters of the State.
12. The sand and carbon filter media shall be disposed of at a suitable and approved
hazardous waste disposal site. All soil in the effluent wastewater detention
pond containing PCB's at concentrations greater than or equal to 1.0 ppm (by
weight) shall also be disposed of in an approved hazardous waste disposal ··site.
13. Any monitoring deemed necessary by the Division of Environmental Management
to insure surface and ground water protection will be established and an
acceptable sampling reporting schedule shall be followed.
14. The issuance of this permit shall not relieve the N. C. Department of Crime
Control and Public Safety of the responsibility for damages to surface or ground
waters resulting from the operation of this facility.
15. The facilities shall be effectively maintained and operated as a non-discharge
system to prevent the discharge of any wastewater into the surface waters of
the State.
16. The concentration of PCB in the effluent wastewater to be land applied by these
spray irrigation facilities shall not exceed 1.0 PPB.
17. A suitable year round vegetative cover shall be maintained and sown prior to
spraying.
18. Irrigation shall not be performed during inclement weather or when the ground
is in a condition that will cause runoff such_ as within a 24-hour period after
a total rainfall event of 0.5 inches or greater within the previou~ 24-hour
period or when the wind velocity exceeds 15 mph.
19. The application rates shall not exceed 0.25 inches per acre per week.
20. Freeboard in the storage lagoon shall not be less than two (2) feet at any time.
Permit No. 7643R3.
Page ~o,
21. No type of wastewater other than that from the Warren County PCB Landfill
shall be treated by this facilities and spray irrigated onto the irrigation
area.
22. No root or leaf crops for public consumption shall be raised on these sites.
23. The spray irrigation will only be conducted on the designated site owned by
the North Carolina Department of Crime Control and Public Safety and shall
not be conducted within 25-feet of the property lines.
24. The spray irrigation area shall not be grazed nor shall. the cover crop be
harvested or removed from the site.
25. Adequate records and an operational log shall be maintained at these facilites
detailing the following information:
a. date of irrigation and date wastewater analyzed last,
b. amount of wastewater irrigated,
c. le>cation and amount of area irrigated, and
d. general weather conditions.
r.J-,;
26. The Permittee, at least six (6) months prior to the expiration of this Permit,
shall request its extension. Upon receipt of the request, the Conunission
will review the adequacy of the facilities described therein, and if indicated,
will extend the Permit for such period of time and under such conditions and
limitations as it may deem appropriate.
27. A report summarizing the total amount of wastewater spray irrigated, analysis
of the wastewater, analysis of the :irrigation site soil, analysis of the irrigation
site cover crop, and groundwater monitoring wells sample analysis shall be
submitted for review by the Division with the permit renewal request or within
thirty (30) days after termination of facilities operation.
Permit issued this the 30th day of May, 1985.
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
Original Sign,ed By
ARTHUR MOUBERRY
For:
R. Paul Wilms, Director
Division of Environmental Management
By Authority of the Environmental Management Conunission
Permit No. 7643R3
AY 24
North Carolina Department of Crime Control and Pu
James G. Martin, Governor May 22, 1985 Joseph W. Dean, Secretary
Mr. Al Hanke ,
Environmental Scientist
EPA, Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
Re: Warren County PCB Landfill Monitoring
Dear Al:
Since the responsibility under the cooperative agreement for
monitoring the landfill is with the North Carolina Department of
Human Resources, I have requested that Mr. Bill Myer, head of the
Solid and Hazardous Waste Branch of that department be responsible
for providing information as to the results of all future moni-
toring.
If you have any questions, please let me know.
WWP/ls
Sincer:-ely yours,
w~~f)
Wi 11 i am W. Phi 11 i ps, Jr.
Special Assistant to the
Secretary
cc Joe Lennon -Director, Warren County Health Services
Jim Scarbrough
~l Meyer -HR
Paul Wilms -NRCD
512 N. Salisbury Street• P . 0 . Box 27687 • Raleigh, North Carolina 27611-7687
An Equal Opportunity / Affirmative Action Employer
---(o -low-.
fy 01,1., -T, ""V\,t.'1
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he t2tJ-d' t'ot;id~
do( ( ci-...-s
April 23, 1985
Mr. Keith Lawson
North Carolina Department
of Human Resources
Division of Health Services
P. 0. Box 2091
Raleigh, North Carolina 27602-2091
Dear Mr. Lawson:
()Battelle
Pacific Northwest Laboratories
P.O. Box 999
Richland, Washington U.S.A. 99352
Telephone [phone]
Telex 15-2874
Per your request for additional information on the In Situ Vitrification
process, enclosed is a recent publication describing the potential and tech-
nique for hazardous waste. Also enclosed is a specimen of the vitrified soil
or glass.
If there are further questions, p 1 ease don I t hes it ate to contact me at the
above address.
Sincerely, ~-v. F. FitzPatrick
Program Manager, In Situ Vitrification
Chemical Process Engineering Section
VFF: 1 m
Enclosures
\~
~~ (JJt·:::~ ·~:~-./~ ~~_...r
North Carolina Department of Human Resources
Division of Health Services
P.O. Box 2091 • Raleigh, North Carolina 27602-2091
I James G. Martin, Governor
Phillip J . Kirk, Jr., Secretary
Ronald H. Levine, M.D., M.P.H.
April 4, 1985
Mr. Vincent F. FitzPatrick
Pacific Northwest Laboratory
Battelle Corporation
PO Box 999
Richland, Washington 99352
Dear Mr. FitzPatrick:
State Health Director
919/733-3446
Our office has recently been advised of the technology for situ soil
vitrification which Battelle has been developing, and we have been given
a copy of a technology transfer bulletin about it. Our initial impression
is that such treatment might well be used to advantage in some sites in
North Carolina.
We would appreciate rece1v1ng any additional descriptive material which
you may have. We would also be interested in seeing a specimen of the
vitrified soil. It would not have to be very large.
Any further information at all will be welcome. v;;;;;Y~~
Keith Lawson
cc: Bill Meyer
Mr. Charles Oldham
KL/pcs
An Equal Opportunity / Affirmative Action Employer
J
\
,_,
.
.
North Carolina Department of Human Resources
Division of Health Services
P.O. Box 2091 • Raleigh, North Carolina 27602-2091
James G. Martin, Governor
Phillip J. Kirk, Jr., Secretary
I Ronald H. Levine, M.D., M.P.H.
April 4, 1985
Mr. Charles Oldham
2205 Southern Road
Sanford, NC 27330
Dear Mr. Oldham:
State Health Director
919/ 733-3446
Thank you for calling to our attention Battelle's process for in situ soil
vitrification. We feel it has definite interest, but would like more
information.
I am enclosing a copy of our letter to Battelle asking for more descriptive
material and a sample of treated soil.
Keith Lawson
for Bill Meyer
KL/pcs
Enclosure
An Equal Opportunity / Affirmative Action Employer
Mr. Bill Meyer
Solid/Hazardous Waste Branch
P.O. Box 2091
Raleigh, NC 27602
Dear Bill: I
Mr. Charles Oldham
2205 Southern Road
Sanford, NC 27330
April 2, 1985
Hope t hings are well with you and your family.
Bill, wi ll you please read the enclosed bulletin and possibly
call the contacts mentioned to get the technical details of the
process. I am very much interested in your ideas as to whether
this technoloqy can be applied to the Southern Wood Piedmont
landfill at Gulf, NC. At a cost of 3-6 dollars per cubic foot
of vitrified mass it would cost SWP 21,600-43,200 dollars to
vitrify the 7200 cubic feet of sludge they reported as land-
filled on their superfund report. This landfill is located on
42 acres of land served by two railroads , city water, and
includes 60-80 thousand dollars worth of office buildings. The
economics of this process miqht begin to work in their favor on
this tract of land.
I know you are working with some hazards more imminent than the
l andfill at Gul f, but I would sincerely appreciate hearing from
you as soon as possible.
Thank you,
C4L~
Charles Oldham
aam
Enclosure
PS I sent a copy of this bulletin to Ed Gibbs, Environmental Manager,
Sou thern Wood Piedmont, Inc., and to Charles Case a Raleigh Attorney.
Mr. Charles Case
More, Van Allen,and Allen
P.O. Box 26507
Raleigh, NC 27611
Dear Charles:
Mr. Charles Oldahm
2205 Southern Raad
Sanford, NC 27330
April 2, 1985
Hope things are well with you and yours.
I thought you might like to see the enclosed bulletin.
I am going to get your people some money soon. ---
c.Zl ~
Charles Oldham
earn
Enclosure
The Technology
UNISON PRESENTATION
March 27, 1985
Vista International Hotel -Washington, D. C.
Summary
Four PCB-laden transformers located at a Union Carbide facility were reclassified during March
1985 to non-PCB status in accordance with EPA regulations. These full scale, production unit
transformers were part of extensive research and development efforts over the past five years leading
to the development of a proprietary technology to safely and effectively achieve such reclassifications ...
~eclassification to non-PCB status under EPA -TSCA regulations requires that the PCB level in
the transformer be less than 50 parts per million (ppm) after three months of in-service use. All
such criteria have been met, and applicable conditions have been satisfied. The PCB concentrations
of these four Union Carbide transformers are: 35.7, 23.5, 11.0, and 5.7 ppm respectively.
This technology has been commercialized into a full service capability designated RECLASS 505M
Transformer Service, and is being offered throughout the United States by UNISON. The service
includes a transformer assessment followed by management of the entire process, including provision
of all raw materials, labor, distribution, analysis and destruction of the PCB. All activities are
performed in accordance with EPA regulations. There will be no landfilling of any equipment,
raw materials, or any other articles associated with RECLASS 5U5M:Transformer Service.
The Company
UNISON is a joint venture formed by Union Carbide Corporation and McGraw-Edison Company
in mid-1984 to market a new technology for retrofilling PCB and PCB-Contaminated transformers.
The technology was developed by Union Carbide Corporation. We believe the RECLASS 5QSM
Tran"sformer Service is the only retrofill technology marketed with the guarantee of satisfying the
EPA designated non-PCB transformer status for transformers containing PCB's. Achievement of the
non-PCB classification is accomplished by UN ISON at the transformer site in a timely, cost-effective
manner, thereby permitting continued use of these long-life assets.
UNISON brings together Union Carbide technology and McGraw-Edison service and sales capabilities
under management from both companies. The extensive technical skill centers and particular
experiences in the electrical, chemical and regulatory arenas which both companies have provided
to UN ISON are necessary to solve the complex PCB transformer problem in a safe, dependable and
environmentally acceptable fashion.
UNISON operates a fleet of vans which have been specially equipped to provide the RECLASS 5QSM
Transformer Service. Vans are located throu~hout the country at McGraw-Edison service shops.
Service crews have been fully trained and are based at the van location sites.
The UNISON joint venture is a partnership with the resources and assets of both partners supporting
the venture. The UNISON management staff mailing address is 100 E. Campus View Blvd.,
Columbus, OH 43085. The UNISON phone number is [phone].
United States Department of the Interior
FISH AND WILDLIFE SERVICE
Division of Ecological Services
P.O. Box 25039
Raleigh, North Carolina 27611-5039
F 7
Mr. Tom Karnoski
Department of Human Resources
Solid and Hazardous Waste Management Branch
P. O. Box 2091
Raleigh, NC 27602
Dear Mr. Karnoski:
MAR 2 2 1985
Enclosed is a report on the results of the Raleigh Field Office's study of
polychlorinated biphenyl (PCB) levels in aquatic indicator species from the
PCB Highway Spill Site in North Carolina. This study was conducted during
1984, three years after the site cleanup, to determine the possible extent
of residual contamination of the aquatic food chain. This is a preliminary
report for limited distribution, pending publication of the final manuscript
currently in preparation. If you have any questions, please contact Kate
Benkert of my staff at 919-755-4520.
cc:
Waynon Johnson -HR/RCA, Atlanta
Don Steffeck -ES, Bloomington FO
ll'~Y~~~~
L. K. ('Mike) Gantt
Field Supervisor
North Carolina Department of Human Resources
Division of Health Services
James G. Martin, Governor
Phillip J. Kirk, Jr., Secretary
Patrick T. Brady
68 Eddington Street
P.O. Box 2091 • Raleigh, North Carolina 27602-2091
Ronald H. Levine, M.D., M.P.H.
March 19, 1985
State Health Director
919/733-3446
Pawtucket, Rhode Island 02861
Dear Mr. Brady:
Your letter of March 12 requested information on a PCB disposal
operation in North Carolina. I am more than happy to provide background on
that problem. However, I do not think our situation is relevant to the
situation in Pawtucket.
In July,1978, North Carolina government officials were informed of
possible PCB contamination along roadsides in Warrerl County. After three
days of investigation, we identified more than 240 miles of roadsides in 14
counties where PCB-laced transformer oil had been deliberately and
illegally dumped. ·' ··
The clean-up and disposal of the contaminated soil took several years
and more than $2.75 million of federal and state funds. The men
responsible for the illegal and improper disposal of the PCB-laced oil· were
convicted of criminal charges. They are currently facing civil suits by
federal and state authorities in an attempt to recover the cost of the
clean-up.
Bear in mind that we consider this incident to have been one of
illegal and improper disposal of a toxic waste. We have had no other
problems of this nature in North Carolina. Our local power companies, like
yours, are replacing PCB as a transformer coolant. To date, all of this
activity has been carried out safely and legally without incident.
If you would like more information about PCB disposal and regulation,
I suggest you contact the appropriate state environmental management agency
in Rhode Island. You might also contact Brooke C. Cook, Director, Office
of Public Affairs, U.S. EPA Region 1, _JFK Federal Building, Boston .MA 0·2203.
WLM:HLM
Sincerely,
·7J4~~ -j71J.;i'~
William L. Meyer, Head
Solid and Hazardous Waste
Management Branch
An Equal Opportunity / Affirmatiw Action Employer
North Carolina Department of Crime Control and Public Safety
512 North Salisbury Street" Raleigh, North Carolina 27611
James G. Martin, Governor March 15, 1985
Mr. Paul Wilms, Director
Division of Environmental Management
N. C. Department of Natural Resources
and Community Development
Archdale Building
P.O. Box 276 87
Raleigh, NC 27611-7687
RE: Permit No. 7634-R 2
Warren County PCB Landfill
Dear Mr. \./ilms:
Joseph W. Dean, Secretary
Permit No. 7634 for the operation of a facility in Warren County to
treat potentially PCB contaminated water expired on December 31, 1984.
By this letter I am requesting a renewal of that permit.
\./P/es
If you have any question, please let me know.
_;;cyely, /1./~~
1
~, ~ k!!~:l{/,~-r W1ll1am W. Philli:s, Jr. •
Special Assistant to the Secretary
cc: Bill Meyer-Department of Human Resources
An Equal O pportunity / Afiirmr.tive Action Employer
Mr. William L. Myer
Solid and Hazardous Waste Management Branch
Division of Health Services
P.O. 2091
Raleigh, NC 27602
Mr. Myer:
My city is currently in the midst of a controversy
concerning the local power company's decision to store
substantial amounts of the toxic chemical PCB in the
heart o:f a densly populated,neighborhood. The PCB in
question is being replaced as transformer coolant :·
in the electric company:s system, and prior to its
being transferred to a toxic waste facility at some
undetermined time in the future, it needs to be stored
locally.
I have recently read an article written in 1980 which
made a passing reference to the fact that improper dis-
posal methods of PCBs in Raleigh changed what would have
been a $100,000 cost into a multi-million dollar clean-
up cost. This article said just this and went no further
in describing the situation that you people were con-
fronted with and how it was handled.
We in Pawtucket have found that there is a paucity of
information concerning the hazards of contact with and·
disposal of PCBs. I am hoping that your situation may
enlighten us somehow, and help us choose the proper path
in settling our current dispute. For this reason I am
asking you if you would be kind enough to forward to me
any data from your past experience in dealing with the PCB disposal problem in Raleigh which might shed some
light on our problem here.
I thank you in advance for any help you may give.
Sincerely,
~:fo/
North Carolina Department of Crime Control and Public Safety
512 North Salisbury Street• Raleigh, North Carolina 27611
James G. Martin, Governor March 4, 1985 Joseph W. Dean, Secretary
MEMORANDUM
TO: M. C. (Bob) Adams
Division of Highways
Department of Transportation
FROM: Bi 11 Phillips~
RE: Warren County PCB Landfill
Per our phone conversation of today, attached is a letter from Jim
Scarbrough of EPA in Atlanta requesting that the irrigation system at the
landfill be repaired. I have talked with Tom Karnoski of the Department of
Human Resources and he has agreed to assist your maintenance people with the
repair work.
Thank you.
es
Enclosure
~c Tom Karnoski
An Equal· Opportunity / Affirm;.tive Action Employer
.NORTH CAROLINA DEPARTMENT OF HUMAN RESOURCFS INTER OFFICE MEMORAND4M/ DATE J[( ~S TO A N.D, 0tL£S /)770 /?.>Jt:; '( 0t/V(~l?:-4Ll
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OHR Form 2 (8/75) •
North Carolina Department of Crime Control and Public Safety
512 North Salisbury Street• Raleigh , North Carolina 27611
James G. Martin, Governor January 30, 1985
MEMORANDUM
TO: Tom Karnoski
Solid and Hazardous Waste Branch
Department of Human Resources
FROM: Bi 11 Phi 11 i ps (Op
Assistant to t'i;; Secretary
RE: PCB Landfill
Joseph W Dean, Secretary
~ 1/~ rt
l ::C: FEB 1 lQA
As a follow-up to our ohone conversation of January 17, I
have checked the 20-day Taq 647760 (ID IN6ND06YOFC320849) which
was found at the landfill recently. It belongs to a 1985 Nissan
truck registered to:
Charles Crawford Edmonds
Route 2, Box 57-A
Warrenton, N. C.
Please advise if you have any questions.
BP:jj
cc: Charles Worth
Warren County Manager
Joe Lennon
Warren County Health Director
An Equal Opportunity / Affirmative Action Employer
North Carolina Department of Crime Control and Public Safety
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor January 17, 1985
MEMORANDUM
TO: Tom Karnoski
Solid and Hazardous Waste Branch
Department of Human Resources
FROM: Bi 11 Phi 11 i ps~
Assistant to the Secretary
RE: PCB Landfi 11
Joseph W Dean, Secretary
Confirmin0 our phone conversation of today, I have talked
with the Warren County Manager concerning the trespassing of deer
hunters on the county and state property at the landfill site.
He concurs with the Department of Transportation erecting a sign
at the gate where the county owned buffer zone beqins which
prohibits any hunting or trespassing.
If you have any questions, please advise.
BP:jj
cc: Charles Worth
Warren County Mana~er
An Equal O pportunity / Affirmative Action Employer
l
.... ~
a year-long monitoring system to collect data on the visibility of the integral vistas at the 164 national parks
and wilderness areas. With this data, the second phase will determine whether there is significant visibility
degradation already occurring from existing sources, probably from nitrogen oxides. If so, tighter emission
controls will be ordered on those sources to remove the degradation.
The order allows states 34 months from April 19, 1984, to adopt implementing plans for the visibility
regulations. Failure of a state to establish a program will result in EPA assuming control in the state. Of the
affected states, only Alaska and Washington have adopted plans implementing the visibility rules. Oregon
currently is developing a plan. Colorado and California air-quality regulators have indicated they will volun-
tarily develop a state program. Although the visibility rules mostly affect the West where most of the Oass-1
areas are located, the Great Smoky Mountains National Park in Tennessee and North Carolina will be affected
as will Florida because of the Everglades.
During hearings on the regulations, the Western Energy Supply and Transmission (WEST) Associates,
representing utilities, said the proposals could lock up as much as 89% of the West from energy and other
forms of development. Russell Hulse, a vice president of Arizona Public Service, said the proposal "could
jeopardize the construction of 46% of the additional generating capacity required to meet westerners' elec-
trical needs in 1989 ."
Some industry leaders have warned that the visibility rules will require retrofitting of many power plants
at a cost of billions of dollars to remove nitrous ox.ides; However, EPA officials and environmentalists have
claimed that only a few plants may be required to install more pollution controls. ED F's Yuhnke said only
. two major power plants, the Navajo generating station at Page, Ariz., and the Mohave generating station at
Laughlin, Nev., may be required to install additional controls. The 2,410-MW Navajo station is operated by
Salt River Project for a consortium of Southwest utilities and the 1,580-MW Mohave station is managed by
Southern California Edison for a similar consortium. The plumes from these stations are believed to affect the
visibility around the Grand Canyon, although this is disputed by the operators. . · .
t/41LITIES, EPA REACH SETTLEMENT ACCORD ON DISPUTED 1982 PCB REGULATIONS
Electric utility representatives and the federal Environmental Protection Agency have reached a settle-
ment agreement that could resolve the last piece of industry litigation pending against EP A's major 1982 rule-
making on polychlorinated biphenyls (PCBs). In return for assent by the utilities and other groups to drop their
challenge to parts of the rules now before the U.S. Court of Appeals for the District of Columbia Circuit, EPA
has agreed to conduct a rulemaking that would amend several key definitions regarding PCBs.
The main change would be deletion of the term "significant exposure," which is defined in the rules as
meaning "any exposure of human beings or the environment to PCBs as measured or detected by any scientifi-
cally acceptable analytical method."
Industry experts have argued that such a strict standard overplays the actual risks involved. They also say
the definition is being misapplied in connection with spill cleanups where an inclination to return a PCB spill
site to non-detectable levels is seen as an extreme. Moreover, say industry sources, the definition tends to cause
unwarranted concern among worker groups·handling PCBs. Some incidental contact with the chemicals is
typical in storage and cleanup operations.
Language proposed in the settlement agreement that would substitute in part for the deleted definition
of "significant exposure" says that "any exposure of human beings or the environment to PCBs, as measured or
detected by any scientifically acceptable analytical method, may be significant, depending on such factors as
the quantity of PCBs involved in the exposure, the likelihood of exposure to humans and the environment, and
the effect of exposure."
"It's an important clarification," said Harry Onishi, chairman of the Utility Solid Waste Activities Group's
PCB committee and manager of transmission and distribution engineering at Commonwealth Edison. "It puts
the meaning of the term [significant exposure) back in proper perspective. We don't think the agency meant
for every exposure to be considered significant." An attorney representing the utility industry on the PCB issue
said the proposed clarification would "more appropriately reflect the evidence on what the risks are."
Last fall, two environmental groups offered to drop their challenge to the 1982 PCB rules in exchange for
EPA 's agreement to initiate a rulemaking focusing on the risks posed by PCB transformers involved in fues
(EUW, 7 Nov '83, 1). The groups, the Environmental Defense Fund and the Natural Resources Defense Coun-
cil, so far have voiced no objection to the recent motion by the utility industry and EPA to set a rulemaking
proceeding and avoid further litigation over the disputed definitions.
Under the latest settlement agreement -which also includes the National Electrical Manufacturers Assn.
and the American Paper Institute on the side of the utilities -EPA says it will issue a final rule on the pro•
posed change by November 1.
ELECTRIC UTILITY WEEK -April 30, 1984
,
276
posed by the pesticide use under review." If the notice
proposed the agency's intent to cancel or deny registration
to a product, EPA would seek comment from its Scientific
Advisory Panel and the Secretary of Agriculture.
► Finally, the agency would publish another notice, an-
nouncing its final determination on the reviewed use or uses
of the chemical, and a response to public and scientific
comments.
Polychlorinated Biphenyls
CLEAN-UP POLICY BASED ON LEGAL DECISION
TO SET BACKGROUND LEVEL AS REMOVAL TARGET
Spilled and improperly disposed polychlorinated biphenyls
would have to be cleaned up to background levels or the
lowest level below 50 parts per million that can be obtained
using normal clean-up methods, according to a May 23 draft
compliance policy developed by the Environmental Protec-
tion Agency.
The draft document, obtained by BNA, is an effort by
EP A's Office of Pesticides and Toxic Substances to establish
a uniform clean-up standard for PCBs. Currently, each EPA
regional office has its own PCB clean-up standard, meaning
there are nearly as many different· policies as there are
regions.
Meanwhile, officials: 1it the office of solid waste and
emergency response are working on their own PCB clean-up
policy for Resource Conservation and Recovery Act facili-
ties and superfund sites. EPA sources told BNA May 29 that
the two policies will likely be combined so that both pro-
grams are using the same clean-up standard for PCBs. The
RCRA and superfund clean-up policy is in very preliminary
form, agency sources said.
'Normal Clean-up Methods'
According to the draft policy, "All improperly disposed
PCBs shall be cleaned up to background levels, as verified
by analysis of spill site samples, except that where back-
ground levels are not practicably attainable using normal
clean-up methods, the regional administrator shall have the
authority to allow alternative clean-up levels below 50
ppm."
Any such alternative clean-up level, according to the draft
policy, must be justified in writing and made a part of the
ca·se file. In making determinations on alternative clean-up
levels, the regional administrator may consider such factors
as:
► The location of the spill;
► Difficulty of cleanup;
► Risk of exposure to humans;
► Potential contamination of food/feed or water;
► Possible environmental damage caused by further
cleanup versus no further cleanup; and
► Whether steps can be taken to contain any remaining
contamination.
The draft compliance policy is based on a decision by
Administrative Law Judge Gerald Harwood in a case involv-
ing a General Electric plant in Cincinnati, Ohio (Current
Report, Feb. 17, p. 1663). Harwood held that improperly
disposed PCBs must be cleaned up to the lowest level below
50 ppm practicably attainable through the use of normal
clean-up methods. He assessed a penalty against GE for
cleaning up a PCB spill to a level of 13 ppm because,
according to the decision, the spill could have been cleaned
CHEMICAL REGULATION REPORTER 1':
up to much lower levels by the application of so-called
normal clean-up methods. </
Site-Specific, Background Level
The policy says the GE case "essentially requires site-
specific determinations of 'practicably attainable' clean-up
levels." The policy does not define the term "normal clean-
up methods."
In most cases, the policy explains, the application of
normal clean-up methods by properly trained and super-
vised personnel will bring PCBs close to background levels,
and will not impose an undue burden on industry. "EPA's
experience indicates that the primary difficulty in achieving
background levels is the failure to adhere to proper clean-up
procedures," according to the draft policy.
"Background level" is defined by the policy as O ppm
PCBs, unless determined otherwise by calculating the aver-
age of samples from four equidistant points on the circum-
ference of a circle having a diameter twice the diameter of
the soill area and whose center is the center of the spill
area." This definition, according to EPA, allows PCBs to
remain in the parts per billion range "since even the most
diligent application of normal clean-up methods may not
remove every molecule of PCB from the site."
The draft policy says the burden of proving that spilled
PCBs have been adequately cleaned up rests with the person
responsible for the spill. EPA's regional offices will require
post-cleanup sampling to ensure adequate decontamination,
according to the policy.
According to agency sources, an effective date for the
policy has not yet been set. The document is currently under
review within EPA.
Copies of the draft policy can be obtained for a charge
from BNA's Research and Special Projects Division at (800)
452-RSPD or [phone] in the Washington, D.C., area.
General Policy
TSCA'S USE FOR OCCUPATIONAL HAZARDS
ENDORSED BY SENATORS IN LETTER TO EPA
Use of the Toxic Substances Control Act to regulate
occupational exposures to hazardous substances - a prac-
tice challenged by industry groups and the Office of Man-
agement and Budget -was endorsed by the Senate Envi-
ronment and Public Works Committee in a letter to the
Environmental Protection Agency.
Committee Chairman Robert T. Stafford (R-Vt) and three
other committee members said the law requires EPA to
review chemical hazards before manufacture, instead of
before marketing, "to assure protection of workers."
The letter added that it would be "poor public policy to
forgo regulation of a recognized unreasonable risk using
TSCA merely because another statute could be used, without
regard to whether it actually will be used immediately to
regulate the risk."
The May 4 letter to EPA Administrator William D. Ruck-
elshaus was signed by Stafford; and by Sens. Jennings Ran-
dolph (D-WVa), ranking minority member of the Senate
committee; Dave Durenberger (R-Minn), chairman of the
Environment and Public Works Subcommittee on Toxic
Substances and Environmental Oversight; and Max Baucus
(D-Mont), subcommittee ranking minority member.
TSCA Versus Other Laws
Several industry groups and 0MB have argued that Sec-
tion 9(a) of TSCA preclude use of the act to regulate
6-1-84 Copyright 0 1984 by The Bureau of National Affairs. Inc.
0148-7973/84/SO+ .50
\_
CURRENT REPORT
Ethyl Corporation Defends Studies
J. Roger Mangham, senior environmental health associate
with Ethyl Corp., the largest manufacturer of EDB world-
wide, claimed that 50 years of workplace analysis have
shown there are "no salient adverse health effects from
exposure to the chemical when proper industrial hygiene is
practiced." He stressed that Ethyl has been "particularly
concerned" with the possibility that workers exposed to
EDB might experience "adverse reproductive effects."
Ethyl Assistant Director of Toxicology and Industrial
Hygiene Donald E. Johnson called for a concentration
threshold for mixtures containing EDB so that processes and
products experiencing minute traces of EDB, "perhaps due
to a side reaction or trace impurity," would not be required
to go through the initial monitoring, training program, and
emergency procedures required under the proposed stan-
dard. Johnson claimed that a threshold of 0.1 percent EDB
in a mixture would be consistent with previous OSHA
standards.
Polychlorinated Biphenyls
JUDGE RULES SPILLS MUST BE CLEANED UP
TO LOWEST LEVEL PRACTICABLY A TT Al NAB LE
In a precedent-setting decision, an administrative law
judge with the Environmental Protection Agency ruled Jan.
27 that spills of polychlorinated biphenyls must be cleaned
up to the lowest level below 50 parts per million practicably
attainable through the use of normal clean-up methods.
The case, involving a PCB spill at a General Electric
plant in Cincinnati, is the first case to cc:·1sider whether
spilled PCBs must be cleaned up if the residue is below 50
ppm. Administrative Law Judge Gerald Harwood rejected
aguments by General Electric that cleanup of PCB spills to
50 ppm is consistent with EPA's policy as expressed in the
preamble to the PCB ban (Chemical Regulation Reporter
Reference File 1, 35:0101).
The company contended that EPA's general policy ex-
pressed in the PCB rule to regulate only concentrations of 50
ppm or more also was intended to apply to the level of
cleanup required for spilled PCBs. Harwood, however, con-
cluded that the 50 ppm cutoff should not be construed as
applying to situations that result in adding PCBs to the
environment unless it is clear that EPA intended to do so.
"Here it is neither clear from the spill provisions [of the
rules] nor from their history that the EPA intended this
result," he wrote.
Level of Cleanup
Harwood also rejected General Electric's argument that
EPA's apparent refusal to fix a level of cleanup in the
regulations shows an intention to require that PCB contami-
nation caused by a spill need only be reduced to a concentra-
tion below 50 ppm.
"Nothing in the agency's action or in the language of [the
reglations], as amended, suggests that the agency intended
to limit the cleanup of spills to only where the concentration
is below 50 ppm," Harwood concluded.
General Electric also argued that, without some objective
criterion in the regulation fixing a level of cleanup, the rule
would be void for vagueness. But Harwood disagreed. "The
regulation ... in making a spill illegal per se can hardly be
called vague," he said.
The question of setting a clean-up level for PCB spills has
been a troubling one for EPA. In an attempt to avoid the
situation, EPA sources told BNA, the agency opted not to set
1663
a national spill clean-up policy for PCBs, but rather to allow
the EPA regional offices to set their own clean-up policy.
The result has been fractured enforcement of the PCB rules,
with some regions requiring spills to be cleaned up to
background levels while others require cleanup only to the
50 ppm level.
Enforcement Action Taken
The case is the result of an enforcement action taken
against General Electric by EP A's Region V office. EPA
inspectors visiting the GE plant in Cincinnati discovered
that a ruptured compressor air line had spattered oil con-
taminated with up to 84,000 ppm PCBs on the wall and
ceiling of the plant.
Although the company had attempted to clean up the spill,
residues containing 2.5 to 13 ppm PCBs were found on the
plant walls by EPA inspectors. The agency charged that GE
failed to sufficiently clean up the PCB spill and levied a fine
of $20,000. The judge, however, reduced the penalty to
$6,750.
GE has not yet decided whether it will appeal the deci-
sion, according to attorneys for the company.
Hazardous Waste
FIRST GENERIC CLASS OF INDUSTRIAL WASTES
LISTED BY EPA AS HAZARDOUS UNDER RCRA RULES
Several wastes generated from one manufacturing pro-
cess were listed by the Environmental Protection Agency as
hazardous wastes to be controlled under the Resource Con-
servation and Recovery Act, in a Feb. 10 action that for the
first time listed wastes as a group rather than individually.
In an interim final rule, EPA said it used the group listing
process to speed control over the wastes, which are generat-
ed when chlorinated aliphatic hydrocarbons are manufac-
tured using free radical catalyzed processes (49 FR 5308).
By using the group listing process, EPA is "cutting the
time and effort to deal with these hazardous wastes without
cutting corners," according to Lee M. Thomas, EP A's assis-
tant administrator for solid waste and emergency response.
"One regulation rather than 25 individual regulations will
cover the wastes of 25 major commercial products," Thom-
as explained.
The substances covered by the rule are distillation resi-
dues, heavy ends, tars, and reactor cleanout wastes, all of
which have a carbon content ranging from one to five, with
varying amounts and positions of chlorine substitution, ac-
cording to EPA.
The interim final rule, which takes effect Aug. 10, 1984,
will subject these wastes to the hazardous waste manage-
ment standards and permitting requirements of RCRA
rules.
Proposal To List Other Wastes
In another Feb. 10 action, EPA proposed to list as hazard-
ous several additional wastes generated in the manufacture
of aliphatic hydrocarbons -light ends, spent filters, filter
aids, and spent dessicants. Once listed under RCRA, the
wastes will be subject to storage, treatment, shipment, and
disposal rules.
Approximately 75,000 metric tons per year of new wastes
are covered by the interim final regulation, and approxi-
mately 29,000 metric tons of new wastes would be con-
trolled under the proposed regulation, EPA said. An addi-
tional 1.5 million tons of chlorinated hydrocarbon-
2-17-84 Chemical Regulation Reporter
0148-7973/84/$00.50
(
PCB LANDFILL MONITORING CODE
RC -Richneck Creek
UT -Unnamed Tributary
DS -Downstream
US -Upstream
SW-CON -Spring Discharge 30 feet above UT
SW-HEAD -Spring Discharge 500 feet above UT
Wl -Groundwater Monitoring Well Ill
W2 -Groundwater Monitoring Well 112
W3 -Groundwater Monitoring Well 113
W4 -Groundwater Monitoring Well 114
A -Replicate A
B -Replicate B
'
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DEPARTMENT PCB MANAGER SEMINAR
DECEMBER 12, 1984
9:00 a.m. Introduction to N. ·c. State PCB Management Program -George Johnson
a. Background -significance of PCB to environment.
b. Brief history of the development of the State PCB Management Guidelines
c. Overview of PCB Management Program
d. Philosophy adopted for Management Program
e. Organization of Management Program
9:45 a.m. Function of PCB Advisory Committee-Bill Meyer
a. Makeup and balance of committee
b. Responsibility of Advisory Committee to Program
c. Responsibility of facility personnel to Program
d. Alternative to following EPA regulations
e. Responsibility of department managers to Program
10:15 a.m. Coffee Break
10:30 a.m. EPA PCB Regulation Enforcement Philosophy-Robert Stryker
a. Procedure used in investigative action
b. Citation reasons and forms
c. Recourse
11:00 a.m. Program Developed by ~artment of Correction,.to Identity PCB
Items and Comply with Regulations -Tom Wilson & Ernest Dement
a. Organization of testing procedure
b. Method used in selection of testing laboratory
c. Summary of test results
d. Results of department program
12:15 p.m. Luncheon
1:15 p.m. Review of State PCB Management Guidelines
a. Identification of PCB items and determination
of appropriate transformer categories, trans-
former servicing. •.,:;\
b. MarCY g Requirements.<equired P&</~uipment
Phase-Out; Recordkeep~ng ✓,(i.J_:;
c. Handling PCB Items for Disposal; Spill Reporting,
Spill Cleanup
d. Personnel Protection, Sampling, Analytical Testing
George Johnson
Bill Meyer
Page Benton
Pat Currin
3:15 p.m. Direction of PCB Regulation Development
a. Need for support from department PCB managers
b. Schedule of phaseout development
c. Responsibility of departments to facilities' efforts to comply with EPA
PCB regulations
d. Responsibility of facilities to comply with EPA PCB regulations
3:30 p.m. Panel Discussion--Questions and Answers
Representatives of the Advisory Committee
4:30 p.m. Adjourn
2
1597A