Document 0Lq6neLLw4EmE4yO9607oDw3k

mATUHAI B tO U A C f COMMISSION CARL T JOHNSON C M tAlTAlA DEAN '.iir'CEON HILARY t S l.c L l HARRY M WHITEl EV JOAN L W GLfC C H A R LE S C. YOON GLOVE STATE OF MICHIGAN ) WILLIAM ft. MILUKCN. Governor ' DEPARTMENT OF NATURAL RESOURCES STCVfcNS t MASON DUL3NG. LANSING. MICHIGAN 4CD?C . HlAYAKO A. TANNER. D.roclt'f Pointe MoullLce State Came Aren RFD tf2 Rockwood, Michigan 4SI 73 * March 19, 1976 b tf W A te n HEfcOl/liCFS COWMI55 C W ill 1AM C O U H T iH JO H N G l AU CH AH l.ES O HAH ..: JO H N H Al H M l : . I.' O CLCAM O N E I AT STAN LEY OUACk CN UUS'i JOHN E VOGT Robert Pc-creon Howard Zar Enforcement Division U.S. E.P.A. - Region 5 Chicago, Illinois Gentlcnen: In response to a request fro:?. U.S. EPA a Facilities Inspection was made by the writer, Mr. Brian Keicks r.r.d Mr. Richard Powers, all of the Michigan Department of Natural Resources, .Bureau of Water Management, of facilities named: WccLJ. i`:hou3:* Apparatus Repair 19050 Allen Road Trenton, Michigan 48183 The inspection was done on February 25, 1976. Our V.'es ting house contact was Mr. Robert Wilson, Plant Superintendent, Trenton. Physically the plant is a single story building with high bays suitable for movement of large transformers or power generating equipment. Offices occupy the front of the building. Delivery of bulk materials occur at the rear of the plant as does delivery of tankers of non-PCB dielectric fluids. Trade name of the PCB used at this plant is "Inerteen". In reply to the 308 letter the following usages were noted: Inerteen 100-42 " 54201 cm 1973 2400# 1974 2400# 1975 2400# Mr. Wilson stated that his facility does little work on PCB type equipment. Recalling only one job done within the past year. One PCB type of trans- former was in the repair area although not being worked on. There was no evidence of leakage from this transformer. Five 55 gallon drums of unused Inerteen were stored in the oil storage room. Used Inerteen is shipped back to Monsanto In St. Louis, Missouri. No used Inerteen was bciog stored at the time of our inspection. MICtilf'rH -- i u AtOM ?0775 d e c e iv e d 1976 PE!?MiT PTANCTI . iii'A, Kiji.io;; v NPC00026544 753881 Robert Pearson llovnrd Zor Enforcement Division U.C. El'A - Region 5 March 18, 1976 Inertecn Is shipped to the Trenton plant by common carrier. Shipment is in 55 gallon drurs. Handling of there materials is similar to other druwncd fluids, namely, on pallets by hand or fork lift truck. Drum storage is in an oil storage room in which non-PCB fluids arc also stored. Inertecn is moved to a use area as needed. Normal storage is in scaled 55 gallon drums. Inertecn is transferred by use of manually operated barrel pumps or -upsetting the drum and using a drum tap or spigot. No separate transfer equipment for Inerteen was observed. Solids contaminated by Inertecn, such as gloves, rags, and oil absorbent are thrown away with normal trash. Used Inerteen is stored in drums and returned to Monsanto Company by common carrier. The general appearance of the shop area was very good. Drip pans arc used under all equipment being repaired. No oil was seen on the floor or walls with the exception of the oil storage room which has some oil on the floor. Safety equipment is, available to employees and company has a positive attitude regarding handling of hazardous materials. The company is willing to implement any necessary l'CB program, however, nothing extensive hes been done since only a very few Jobs accepted at the facility have been with Inertcen dielectric. Sanitary sewage from the plant is discharged to Wayne County - Trenton WWTP. With the exception of an open floor drain near a drinking fountain no floor drains were seen in the work r.rer.s, A stagnant drainage ditch runs along the back of the plant, within the plant's fence, however it does not flow off their property. Blueprints of the sewers serving the plcnt are available. PCB's used in the plnnt were in repair work of transformers, although the repair of capacitors or other PCS containing equipment is within the technical capability of the plant. Capacitor impregnation or flood filling processes are not done with Inertecn. Should a vacuum test be required on an Inertecn transformer the standard vacuum pumps would be used. These pumps do not have a vapor condenser. Cooling water and pump oil from them is not monitored, and is disposed of in normal manner, l.e., sanitary sewer and waste hauler, respectively. Filtering equipmencand filter aid have not been used for Inertecn. The company does not operate an oil separator or oil skimmer. In bidding on Jobs, including PCB's filled equipment, the company has three alternatives when dealing with customers (1) the Job was not accepted because it is out of date, repair facility is at capacity, or other monetary reason (2) after inspection of equipment in the repair shop it may be deemed "not repairable" and returned to customer intact or (3) deemed not 'Repairable and sold to a scrap dealer. PCB fluids would be removed prior to sale to scrap dealer. The defective equipment would be stored in a drip pan until disposed of. The facility apparently does not have a SPCC plan. A Michigan Pollution Incident Prevention Plan aimed at Inertecn has been requested from the plant. J 'r : S"; N P C 0 0 0 2 6 5 4 5 753882 J" obcrt Pearson Howard Zar Enforcement Division U.S. LPA - Region 5 March IH, 1976 6V 3 Three samples to be analyzed for PCD were taken as follows, (1) large outside, non-PCB, bulk tank containing dielectric fluid (2) oil saturated "oil absorbent granules" from the floor of the oil storage room (3) water sample from stagnant ditch at the rear of plant. The results of the analyses were available on March 17, 1976, and as follows: (1) Bulk Storage Tank (non-PCB transformer oil) 1 . 0 ing/1 m 1742 1.9 mg/1 - 1254 L 1.0 ng/1 - 1260 (2) Granular Oil Absorbent 88,000 ng/1 . 1242 55,000 ug/1 - 1254 a ^1.0 mg/1 - 1260 1j <3) Stagnant Ditch behind plant 165,000 ug/l . 1242 (water sample) 190,000 ug/l - 1254 1 . 0 *s/i - 1260 The company has been notified of the results and necessity for a cleanup of the area. I A letter was sent to this facility on March 12, 1976, outlining our reconzK adetions and requirements for a PCS program. The letter was a formal request that a PIPP plan be filed. The company will cooperate with us regarding PCB's, however, since the dollar volume of PC3 repair work is low, it would be wore likely that they refuse the business and eliminate PCB's from their inventory. Very truly yours, WATER RESOURCES COMMISSION Stan Novak SN:gm Sanitary Engineer cc: John Bohunsky Robert Buckley t EPA - Ohio District Office Richard Powers ;NPC00026546 753883