Document 5kzNRLXvqZwo248NaB517kvyz

August 26, 1976 MEMORANDUM TO: FROMi RE: G. B. Welsh W. M. Jernigan Polychlorinated Biphenyls General Electric Company Rome - Floyd County General Electric Company, which began operation In 1959, at Rome, Fioyd County, Georgia, manufactures transformers. Polychlorinated biphenyls (PC3's) have and are being used at the General Electric plant. PCB's are used in some transformers in a closed system for cooling. PCB's are used for this purpose since it is a non-conouctor, good heat transferring media and non-flammable, PCB containing transformer oils are called askarels. General Electric's askarels arc called Pyranol. PCB's are considered almost totally nonbiodegraoable and toxic to aquatic life. PCB's are bioaccurnulative particularly in fatty tissues. The Food and Drug Administration lias, a limitation of no more than 5 ppm in tne edible portion of fish. Contamination by PCB's in humans can cause Yusho disease. The first inspection by a member of the staff of the Industrial Wastewater Program of General Electric's wastewater discharges was on dune 12, 1979, in regard to a telephoned complaint concerning oil on a stream in a residential area. General Electric has four discharges to surface waters in addition to their discharge to ths City of Rome's sanitary sewer. The discharges to surface waters arc from storm water runoff, cooling water, one floor drain, which is not In a PCB containing area and normally does not have a dischaVge, hydrostatic test water, overflow from n cooling water spray pond, and steam condensate. Two of the discharges flow by different routes to Dry Creel; whicn is a tributary to the Oosatanaula River. The other two discharges flow via on unnamed trihutary into Horselog Creek which flows into the Coosa River alter its formation by me Etowaii and the Custannula Rivers. Attached is a map showing the discharges and receiving streams. Pour housekeeping practices in the p.-.st have caused significant c-.-r lamination of the soil on the plant property. Housekeeping problems have been and will ho corrected along with elimination o', leaching of contain) ru.ted soi,. . Analytical remits lor sample;, collected .:t ti poirils have been err otic but 'cneraliy reflect the fact that certain plaint areas have been more contuninat-.-d by past abuse- than others. The samples are composites collected over 29 hours or a lesser period if due solely to r'-neff. the HONS 030552 Weiural i-'otinc - Uo' August 26, 19/6 Page 2 period covered and range ol results is as follows: PCD 001 10/3/75-6/30/76 002 6/30/75-6/17/76 003 10/S/75-6/30/76 006 6/17/75-6/17/76 MINIMUM 66 <1 1 <1 MAXIMUM 7S6 Aig/1 19 jug/l 106 /Jg/l 11 yug/l The following is a list of Items that have already been undertaken to eliminate PCB's and oil contamination in the wastewater discharges: 1. A waste oil tank and a waste Pyrenol tank were installed. The waste pyranol tank is within a concrete dike which has sufficient capacity to hold its contents. The area is provided with a roof to prevent precipitation from entering the dike. Any spillage within the dike is collected in a sump and pumped back into the tank. The waste Pyranol is shipped to Monsanto, the only manufacturer of PCB's in the United States, for incineration. 2. A catch basin was installed to receive oil from lire radiator flushing and return it to the waste oil tank. 3. An oil house unloading station was installed. The unloading station consists of a covered concrete pad with separate unloading points for various oils. Any spilled Pyranoi is collected in a sump and pumped to the Pyranol waste storage tank. 4. All supply piping between the utility buildings and the factory is located in overhead pipe trusses. To prevent rupture of the lines by in-plant vehicles clearance signs and overheight cables were installed adjacent to the pipe br idges. 5. Oil-water separators have beer: installed at two ol the discharges which receive most ol the oil and Pyranoi contamination. 6. Eight oil storage dike valves have boon plugged. Accumulated water in the . diked areas is pumped out througn an oil-waver separator. 7. Since soil samples taken from the Pyranol storage dike showed significant quantities of PCB's and visual observations indicated some leaching in tire corner of the dike, a concrete basin was constructed on the inside lace and bottom of the 'existing earth diked area. All contaminated soil lit.'.; was removed during construction was placed in 55 gallon steel arums and shipped to the cliomic.'.l landfill in Texas. The basin wax also covered with a .roof to prevent precipitation from entering the basin end possibly becoming contaminated. MONS 030553 Llt.'Clnc - Koi August 26, 19/6 Pago 3 8. To minimize the oil and Pyranol contamination of the storm water runoff in' the drainage ditches for two of the discharges, a conccrctc lining has been poured from the end of the drainage pipes to the oil-water separators. 9. A quick drainage system which is a holding pond with an underflow baffle for containing fuel oil spills was constructed since the fuel oil tank farm area does not drain to an oii-v/ater separator. 1C. The discharge of paint booth spray wastewater was eliminated by filtering and recirculating the wastewater. 11. Drum storage building used for storage of paints, solvents, etc.,.has been curbed to contain spills from leaky or ruptured containers. .Spills within the curbed area are cleaned up with absorbant material. 12. Solid waste consisting of wood, rags, Fullers earth, filter paper, etc., which has been contaminated with PCB's is placed in 55-gallon drums and shipped to Texas for disposal in a chemical landfill. This has been the practice since about mid-137Q to early 1971 according to the company officials with which we deal. Prior to that time all waste material was disposed of in G.E.'s landfill on their property and that practice was followed for solid waste materials that had not been in contact with PCfi's until recently. This was discontinued about one year ago and non-PCB contaminated materials arc now disposed of at the Floyd County landfill. A National Pollutant Discharge Elimination System (NPDES) permit was issued for Genera] Electric on December 31, 1975, and will expire on September 30, 1976. Limitations were not placed on PCB's, but monitoring was required so that limitations on PCB's and other parameters and a schedule of compliance could be established. General Electric has proposed to do the following tilings to' further reduce the contamination of their wastewater discharges: 1. General Electric has verbally committed to this office to phase out the manufacture of PCB containing transformers and the use of PCB's by June 30, 1977. It was requested that this information bo kept confidential until General Electric makes its own public announcement within the next month. 2. After termination of the use of PCB's the wooden floor in the filling area where drips could have, occurred will be removed and the tanks at the unloading station will bo drained, capped, and left in place. All materials which will no longer be used will be disposed of at tiie special chemical landfill, incinerated or smelted as appropriate. 3. The diatomaccous earth filters used in purification of Pyrano) must be renewed periodically. To achieve tips the filter press is opened and the spent material is removed from the filter plates. To prevent loss of this contaminated material, drip pons will .bo fabricated and installed under each filter press. The house in which there ore located has olv/ayr. I "tn I. .., I, ct. ; it . c a . . .... .a ,. .c. HONS 030554 Polychlorinated Biphc.'i*'s General Electric Ro August 26, 1976 Page 6 4. The sediment which contains some PCB's in the two oil-water separators will be removed. The sediment will bo drummed and sent to the special chemical landfill in Texas. This will be undertaken alter the unvogetated areas surrounding the drainage ditches leading to the separators has been replanted. 5. The outside lace oi the dikes around the Pyranol storage area will be concreted to prevent leaching. 6. An apron will be poured along part of the already concreted .ditch for discharge 001 which runs adjacent to the Pyranol storage'area to prevent leaching. 7. The retention basin next to the oil-water separator for discharge 003 will be concreted., 8. Part of the area adjacent to discharge 004 where reportedly non-PCB transformer and crankcase oils have been previously spilled and/or dumped in the lifties will'be concreted to prevent leaching. The area has already been cleaned up, regraded and vegetated. 9. Additional soil samples will be collected and analyzed for PCB's to identify any further problems. A new NPDES permit will be issued as soon as we receive a schedule for the above items, except for item //3 on which we heive already received a schedule. V/idOirng MONS 030555