HomeMy WebLinkAbout1910_Brickhaven_EmailThread_EPACharahDEQ_DIN27756_201703151
Mussler, Ed
From:Mussler, Ed
Sent:Wednesday, March 15, 2017 1:47 PM
To:Scott, Michael (michael.scott@ncdenr.gov); Norman Divers (ndivers@charah.com)
Cc:Ellen Lorscheider
Subject:EPA RE:FW: Charah Environmental Incident Form_CCP - PCB Presence.03142017.docx
Norman,
On March 14th I spoke with Ken Feely of EPA Region IV in Atlanta. He is the in‐house PCB expert. I was seeking
clarification to some of the TSCA issues. He confirmed the unrestricted use level of <1ppm. Should levels exceed the
threshold, we will then
have to determine what we are dealing with, a particular waste, an unregulated waste, or a remediation waste.
Today I sent him the report I received from Charah this morning and this is the return email.
As you can see we will need additional discussion concerning what it is, the test methods being employed by Duke as
well as seeking additional clarification on where the source may have originated.
We will be in touch
Ed Mussler
From: Feely, Ken [mailto:Feely.Ken@epa.gov]
Sent: Wednesday, March 15, 2017 12:57 PM
To: Mussler, Ed <ed.mussler@ncdenr.gov>
Cc: Johnston, Jon <Johnston.Jon@epa.gov>
Subject: RE: Charah Environmental Incident Form_CCP ‐ PCB Presence.03142017.docx
Ed,
Looks like the samples were prepared using method 3546 (microwave extraction), which under the PCB regulations is
not definitive. As we discussed yesterday, 3540C and 3550C are the required extraction methods, 3540C being
preferred.
The detected Aroclor (1260) is an indication that the source of the PCBs was transformer dielectric fluid. I’d recommend
we get on the phone with the appropriate parties to nail down the likely source of the PCBs. If it’s thought that they are
from the burning of 50 – 500 ppm PCB transformer oil in the high efficiency boiler, then we need to discuss some sort of
sampling plan for the rest of the material, using an appropriate extraction method.
_____________________________________________________________
Ken Feely | EPA Region 4 | Resource Conservation & Restoration Division
Regional PCB Program Coordinator | Team Lead
USEPA Region 4 | Atlanta Federal Center 9T25 | 61 Forsyth Street SW | Atlanta GA 30303-8960
O: 404.562.8512 | F: 404.562.9964 | M: 470.725.7929 | Email: feely.ken@epa.gov
From: Mussler, Ed [mailto:ed.mussler@ncdenr.gov]
Sent: Wednesday, March 15, 2017 11:20 AM
To: Feely, Ken <Feely.Ken@epa.gov>
Subject: FW: Charah Environmental Incident Form_CCP ‐ PCB Presence.03142017.docx
Ken, this is what we received. We have not yet acted on it, but based on the information I am going to recommend that
we let them continue the excavation.
Ed
2
From: Norman Divers [mailto:ndivers@charah.com]
Sent: Wednesday, March 15, 2017 8:15 AM
To: Mussler, Ed <ed.mussler@ncdenr.gov>
Cc: Rob Reynolds <rreynolds@charah.com>; Scott Sewell <ssewell@charah.com>
Subject: Charah Environmental Incident Form_CCP ‐ PCB Presence.03142017.docx
Ed:
Attached please find a copy of the PCB incident report as requested.
Don’t hesitate to contact us with any questions you may have.
Best regards,
Norman
Norman Divers
Engineering & Environmental Director |Charah, LLC
Mobile: 704‐472‐3919 | Office: 704‐731‐2300 | Direct: 704‐731‐2203 | Fax: 866‐728‐2444 |
ndivers@charah.com | http://www.charah.com