Document peGdywYnOKr3ayj2dn478nj2d

I JOE D.TANNER Commissioner J. LEONARD LEDBETTER Division Director ^cpm'imcni of Natural Resources ENVIRONMENTAL PROTECTION DIVISION 270 WASHINGTON STREET, S W ATLANTA. GEORGIA 30334 . Septoriber 10, 1976 TO: FROM: RE: OTIS WOODS HAROID LANFOKD JT /J L" PCB ANALYSIS OF FISH FROM COSTANAUIA AND ETOWAH RIVERS Attached are analysis of fish tissue for PCB. Sanples from the Oostanaula and Etowah Rivers were analyzed on 8/30/76 thru 9/9/76. HL/ghs Attachmnts SS3 DSW 038477 STLCOPCB4022301 Lab fr 1683 1684 1685 1686 1687 1688 PCB FISH OOSTANAULA RIVER HIGW'JAY 156 AUGUST 30, 1976 type Vfeight ' ' (grains) Spotted Bass Large IVouth Bass Channel Catfish Channel Catfish Black Crappie Black Crappie 454 964 332 542 190 200 length (mri) Concentration PCB * 1254 1260 Total PCB 324 . 2.8 ND* 402 0.83 ND* 355 3.9 ND* 405 6.1 2.3 251 0.09 ND* 258 2.1 ND* 2.8 0.83 3.9 8.4 0.09 2.1 PCB FISH OOSTANAULA RIVER 2.5 MUSS ABOVE THE CONFLUENCE WITH THE ETOWAH RIVER AUGUST 30, 1976 lab # 1695 1696 1697 1698 1699 1700 type Vfeight (grams) Large liouth Bass large Mouth Bass Bluegill Black Crappie Channel Catfish Channel Catfish 531 1474 148 266 534 709 length (mm) 334 475 194 276 430 448 Concentration PCB 1254 1260 Total PCB 1.7 1.2 .0.12 1.8 115 15/15 ND* 1.7 1.3 2.5 ND* 0.12 ND* 1.8 ND* 115 3.4/3.4 18.4/18,4 * NOTE: ND signifies None Detected DSW 038478 STLCOPCB4022302 Lab # 1689 1690 1691 1692 1693 1694 PCB FISH LTOffiH RIVER RAILRQ4D TRUSSEL RCME AUGUST 31, 1976 ' TVpe Weight (grams) Channel Catfish Channel Catfish Large Mouth Bass Large Mouth Bass Bluegill Bluegill 544 490 456 161 119 110 Length (nrn) 394 397 331 244 183 179 Concentration PCB 1254 1260 Total : 1.1 ND* 8.6 4.6 0.13 40 ND* 5.6 ND* ND* ND* ND* 1.1 5.6 8.6 4.6 0.13 40 Lab # 1701 1702 1703 1704 1705 1706 PCB FISH ETCMftH RIVER 411 BRIDGE AUGUST 31, 1976 VJeight Length (grams) . (iTTO) Channel Catfish Channel Catfish Large Mouth Bass Bluegill Bluegill Large Mouth Bass 438 502 337 152 116 421 372 392 294 190 172 311 Concentration PCB 1254 1260 Total PCB . ND* 2.5 2.5 3.4 ND* 3.4 4.5 ND* 4.5 3.0/2.8 1.3/2.1 4.3/4.9 3.6 ND* 3.6 0.18 ND* 0.18 * NOTE: ND signifies None Detected DSto 038479 STLCOPCB4022303 JOE D.TANNER Coninni'sjioner J. LEONARD LEDBETTER Drvmoo Director ^cparlmciii of ^fainral ^Rrsourccs environmental protection DIVISION 270 WASHINGTON STREET. S.W. ATLANTA. GEORGIA 3033-3 ' September 1, 1976 memorandum TO: Otis Woods . FROM: Harold Lanford SUBJECT: Analyses of Coosa River Fish Tissue For Polychlorinated Biphenyls (pcb's) - Attached are analyses of fish tissue for PCB,Sample received in the lab. on August 18, 1976. Analyses were conducted on fish filets and are reported in parts per million (mg/kg) of total PCB on a wet weight basis. Aroclor 1254 was only PCB detected in these samples. 58. DSW 038480 STLCOPCB4022304 PCB SURVEY-LOWER COOSA RIVER 7 May 1976 ' Electrofishing-1530 to 1700 Hrs. Fish Collected From Mayo's Lock & Dam Downstream Approx. 1/4 Mile Lab.No. * 1677 *1678 * 1679 . <1680 '1681 t1682 . Specimen No. Species Length (mm) 3 Channel Catfish 286 4 Channel Catfish - 292 .6 Largemouth Bass . 272 7 - Largemouth Bass 264 12 Gizzard Shad 237 13 . Gizzard Shad 267 Weight (grains) ' 176 173 304 259 117 188 Aroclor .1254 mc/kg 127 . 22 5.7 2.1 . 16 115 PCB SURVEY-LOWER COOSA RIVER ' 16 August 1976 .. Electrofishing-1230 to 1430 Hrs. Fish Collected From Stateline Upstream Approx. 1 Mile ' Lab No. , Specimen ' NO. 41665 f 1666 1667 11668 1669 *1670 .1671 *1672 2 '4 5' ,6 o ' 7' s: 13 15 o OJ 16 CD CO . Species Largemouth Bass Largemouth Bass Largemouth Bass Largemouth Bass Bluegill Redear Sunfish Black Crappie Brown Bullhead Length (mm) 556 314 . . 354 279 182 175 178 137 . . Weight (grams) ' 2835 .` . 405 . 680 . ' 310 103 85 65 192 Aroclor 1254 mq/kq - 54 . 7.8 18 3.3 18 . 2.5 3.5 4.1 STLCOPCB4022305 Lab No. 1673 ` 1674 1675 *1676 ' PCB SURVEY-LOWER COOSA RIVER 16 August 1976 _ Electrofishing-1600 to 1730 Hrs* Fish Collected From Mayo's Lock S Dam Downstream Approx. 1/4 Mile Specimen No. . 4 5 14 15 Species Channel Catfish Channel Catfish Redear Sunfish Redear Sunfish Length (mm) 383 349 245 226 Weight (crams) 370 277 ` 182 175 Aroclor . 1254 mg/kg 5.9 27 4.5 - 11 j O to s; o OJ CD 4- CD IV STLCOPCB4022306 >* **' UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. ZOlCO JUN 3 1376 ' OFFICE or ENFORCEMENT MEMORANDUM TO: FROM: Regional Enforcement Directors Regional Surveillance fi Analysis Directors NEI.C Director, Denver . EMSL Director, Cincinnati . RTP Research Directors ; NPDES Approved States , ' ,. ` .: * "' ' , '' ' ' Acting Director, Permits Division (EM-336) SUBJECT? PCB Effluent Limitations in UPDES Permits >V1 'Li Y. * , *. uvj ' ^: > ,v. .. CD-;; C. Y;' - ^ In my memorandum of March 19, I indicated that effluent limitations for PCBs in NPDES permits for capacitor and transformer manufacturers having direct discharges should be as follows? (1) zero discharge for : process wastewater and process related effluents; and (2) for ncn-process water (including storm water runoff and non-contact cooling water) , a _ ; .strong presumption of zero discharge with any treatment resulting in a concentration level of PCBs at fS 10 ppb.- / ' . It has developed during a conference call Cn April 28 involving . Regions I,'II, IV, and Headquarters enforcement'personnel (sea attached .;.:Tist) that there exists an inconsistency in the establishment of these '..'limitations for the General Electric plants' in Regions I, II, and IV. - Regions I and IV have proposed a 10 ppb limitation for discharges of . non-process -water. Region II has proposed to modify the NPDES permit '.'for the! General Electric Hudson Falls-Fort. Edward, Now York capacitor* '.'.plants to require 1 ppb (or less) discharge of PCBs by January 1, 1977, .* for`both process water and non-process water. Actually, in this permit, Y-.thc* 30-day average limitation is set at 1 ppb, and the daily maximum is . at 10 ppb (daily 24-hour , composite Stapling for PCBS is required ' also). However, General Electric (GE) v<~,,'id be allowed to request a y'.iurther modification i.f the company is *" ie to Meet those requirements , after'establishing a full-scale act' .red carbon treatment system for .removal of waste PCBs. . *. 1' DSW 038483 STLCOPCB4022307 -2- In meetings concerning the proposed Hegion II limitations, the GE representatives have complained that Region II is being more restrictive in its permits limitations'than are Regions I and IV; i.e., Region II's requirement of 1 ppb in non-process waters versus the other Regions' limitations, . The 10 ppb limitation for non-process wastewater set out in my March 19 memorandum was based mainly on the treatment level recently achieved by Region'VII for a .PCB spill in Clinton, Iowa, wherein activated carbon was used in the final phase of PCB removal. GE has hired Calgon, an activated carbon vendor, to perform a feasibility study on GE's Hudson Falls and Fore Edward effluent wastes and Calgon has demonstrated that treatment to 1 ppb of PCBs is achievable. During the April 28 conference call, Murray Strier of my staff asked to h3ve the opportunity to review the Calgon activated carbon treatment data on the General Electric Hudson Falls-Fort Edward effluents, as well as any other activated carbon treatment data for PCBs removal available to Region II and in support of the Calgon ^ results. Murray has now reviewed that data and it is our conclusion that this report conclusively indicates the feasibility of treatment of FCBs waste streams to 1 ppb under certain conditions. Calgon found that over a three-week period (September 29, 1975, to October 17, 1975), it was possible to treat to <T 1 ppb when the concentration of PCBs in the influent to the activated carbon column was ^"170 ppb. At higher influent concentrations of PCBs, the concentration of PCBs remaining after activated carbon treatment was around.10 ppb.' As a result of the high order of variability of the treatment data and in -the absence of long-term performance data and an evaluation of their reproducibility, I will not at this time~~"\ ^ modify the general guidance contained in my March 19, 1976, randum. Because that memorandum calls for. a non^process water limitation of <C 10 ppb, it appears that Regions I, II, and IV have all proposed permit terms consistent with that guidance. However, where permit issuing authorities determine that a dis- cllarger is capable of achieving a limitation which is more Stringent than 10 ppb, the more stringent limitation should be used (consistent with BPT-based "best judgment" of the permit issuers). Furthermore, strong consideration should be given to treatment data (such as that contained in the Calgon report) which 'indicate a technology capable of achieving a more stringent limitation. In this regard, I am enclosing a copy of the Calgon . .feasibility report for your consideration and use as a possible ' /basis, for -requiring more stringent limits for non-process water . effluent for direct dischargers if you wish to do so. ' 1; ;! . -i DStt 038484 / - <; r. STLCOPCB4022308 3- Consistent with this consideration, a decision was made during . a meeting among Regions I, II and Headquarters personnel on May 13, 1976, regarding the NPDES permit for the GR transformer plant in Pittsfield, Massachusetts. The permit will contain a special condition that would require the company to treat their non-process wastewater for PCBs to less that\ 10 ppb if it is found that the GE plants in Hudson FallsFort Edward, New York are able to do so. As a related matter, during the April 28 conference call, Ed Conley ' of Region I mentioned the issue of limitations for PCBs contained in contaminated ground waters which are being pumped. For such waters, the limitation under such conditions should be the same as that pre- scribed for other non-process waters, i.e., ppb, provided the area is not being used deliberately as a disposal site for process waters. . Finally, it has come to my attention that at least one major manufacturer of small capacitors impregnates these capacitors with PCBs under heat and vacuum by an immersion technique. After .the filling operation is completed, the capacitors, are removed from the filling chamber and the excess filling liquid is allowed to drain away from the outside of the miscellaneous plant wastewater. For purposes of establishing NFDES limitations, wastewater containing such PCBs should be considered process water subject to the zero discharge limitation ' in this specific situation. ., , Scnafer ^ DSW 038485 STLCOPCB4022309 Conference Call . April 28, 1976 : . ; , ' . . E, Conley ~ . ` Region I 1 W, Thompson R. Flye ./ ' . "' ` Region I Region II R. Spear < ' " . Region ,11 G. Harlov; i Region IV C. Schafer ~ .. Headquarters B, Biles -- Headquarters M. Strier .# ' * , Headquarters * 1, < . ' DSW 038486 i i 1 . 4 ' * ' ' ` , " , r , ' `; ' : 1 ' : {*>. : ` ---- ..... .:..Sf ..... .... '. . . . - , ' ;i * ` . .` ' '- S, STLCOPCB4022310 o. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IV 1421 PEACHTREE ST., N. E. ATLANTA, GEORG! A 30309 4AEW:RWJ MAR 19 iffl Mr. Gene Welsh Director, Environmental Protection Division Department of Natural Resources 270 Washington Street, S.W. Atlanta, Georgia 30334 Dear Mr. welsh: . The results of the recent PCB survey are coming in. Positive contamination is determined with few exceptions. Georgia findings are contained on the enclosed abstract of the Surveillance and Analysis (S & A) report to the EPA Region IV office. Sampling point location and identification should be coordinated through S 6 A, Athens, Georgia. Please contact those facilities inspected for PCB contaminants and found to have some. PCB contamination and inform those which have no NPDES applications that PL 92-500 requires permitting contaminated storm water run-off and provide necessary applications for them. Inform those facilities with permits which do not include PCB limits and found to have PCB contamination that application for contaminated storm v;atsr run-off modifications to those existing permits are in order and supply them with application forms. Region IV appreciates the cooperation you have rendered in this crash program and we wish to convey that the level of success of this effort could not have been achieved without your assistance. Thank you again for your cooperatic (, Director Enforcement Division Enclosure(s): Abstract of S & A Report h G. E., Rome DSW 038487 STLCOPCB4022311 PROJECT:' C.E. Ron>e) GA COLLECTED BY: F.PA and GA EPD (1,'cter) RECEIVED: 2/A/76 COMPLETED: 2/25/76 SAD NO. -STATION NO. DATE OF SAISFLE AROCLOR 1016* uc/1 AROCLOR . 12 54 ___ 76C0228 001 2/3/76 1405 25 330 ` 76C0229 002 2/3/76 1430 ND 2.8 76C0230 76C0231 76C0232 003 004 , S 2/3/76 1415 ` 2/3/76 1305 2/3/76 1320 *' 14 0.90 l ND . 70 ( 6.1 310 ND - None Detected ^Calculated as Aroclor 1016. It could be Aroclor 1242. COLLECTED BY: FPA and GA EPD (Soil). . AKOCf 12CC u g/3 110 ND 44 4 nd SAT.) NO. 76C0233 STATION NO. 001A . DATE OP SAMPLE 2/3/76 , . 1410 AROCLOR 1016* cift/kfc 26 * AROCLOR 1254 cig/kg_ ND 76C0234 6 ND - None Detected ' *Calculaled as Aroclor 1016. 2/3/76 1345 3300 Could be Aroclor 1242. . . 54,000 AROC 12c T.\ 9; / 21c 16,00 i DSW 038488 STLCOPCB4022312 J- Idtmtiflection arid Control of Environmental' Sources of PCBa George h. Knrlov, Chief Rater Enforcement Branch Region XV, U.S. E.F.A. Blake Biles ' Enforcement Division -Eli 330 Enclosed are nonitoring reports, responses by industries to the MCapccitor/TransfornerM check Hot, and Ruueral ccrxiontu on the facility inspections of industries named oa the Region IV identification list. Based-on the content of analytical data cubraitted by the Surveillnnc mul Analysis Division, those facilities vith no application for RIDES per salts on. hand are being requested to submit came, puroueat to F.L. 92-500 requirements that contaminated atom voter run-off be Remitted. Ail In spected facilities arc being advised of methods of developing control over levels of environmental contamination and tha rates of that conta:oination. .Included vith the Region IV Report ate tho reports submitted by the States which have been awarded .authority under the RIDES program. Cancral comments by tho Rater Enforcement Branch, Region IV, will not include special Instructions to those industries in KPDES states. live Stato of fices nro being advised to pursue informing industrial rCB users vithin their boundaries of methods of reducing environmental PCD loads. Several sources of possible FC3 contamination have bc-an identified by Rollins Environmental Services Incorporated'o FOB cource list: General Electric, Kobilc, Alabama General Electric, Knoxville, Tennessee Tcicdya#, Ratchung, Alabama General Electric, Jackconville, Florida Reycrhausor* Plymouth, Forth Carolina R.' F. Goodrich, Xuacaloocn, Alabama J if. . Carbo^fnd^ru, Knoxville, Tcruicssoe PCS found by DSGS in tha SoetlvFurther iuCorrvrition dcvclopc-nnt area i3 tentatively planned pondy.^ DSW 038489 STLCOPCB4022313 Mobray Eogiaocrlnj' Company, Inc., Greenville, Alabama vac identified by the State of Alabama nnd \;no sampled on January 29, 1976, In the tb~ ecasa of Ralph VJ. Jennings. The company ailcdgco that no PC3 has ever been uned. .. Helena Corporation end Mallory Capacitor Company vero. inspected by Staff Engineers from the Solid Waste Mcnagc-ncnt, Land 1'x'otecticn Section at U.S. IMP.A., Region IV. S maple c were token at the Mallory Capacitor Company landfill cito3. Tho enclosed "off-vcite'' disposal check Hats vera abstracted freo c.onprohensivo reports Guhrdttod by Either C. Clcvo- laud and Henry T. Hudson of the. Solid V.'actc Management, ..Land Protection Section. . `' . . . . The data on llevi-IXiUy Electric Cornany at Goldsboro, Worth Carolina is enclosed bjit the chock list -responses submitted by tho State of North . Carolina did not reach tho Region XV offices in ti;ao to be Included in ' this report. The check list will bo Identified and forwarded upon receipt. . 'Region'T.V is proceeding to schedule inspections on facilities identified in GC-dorsnda of January 13 and 1`cbruary 6, 1976. ' . . . .* George L. Karlov ' Chief - ' .' Mater Enforcement branch Enforcement Division . . Enclosure: Cos:prchencivo Report on Region IV Inspsctiono osn 88<,9 STLCOPCB4022314 JOE O. TANNER Commissioner J. LEONARD LEDDETTER Division Director ^rpa-inmit nf ^Natural ^{esonrcrs ENVIRONMENTAL PROTECTION DIVISION ?70 WASHINGTON STREET. S W ATLANTA. GEORGIA 30334 November 5, 1975 Mr. Paul J. Trains,.Director Enforcement Division U.S. Environmental Protection Agency 142! Peachtree Street, N.E. Atlanta, Georgia 30309 . Dear Mr. Traina: Ret General Electric Company Rome, Georgia NPDES Permit No. GA 0024155 This will acknowledge receipt of your letter dated October 22, 1975. In regard to the lack of limitations lor oil and grease on the above referenced permit for discharges 001 arid 003, this was omitted since construction of oil-water separators for these discharges is just being completed. Therefore, no background data has been collected to demonstrate whether the treatment will meet any proposed limitations or if additional treatment will be required. Y7hen the permit is reissued an oil and grease limitation will be included. In the case of discharges 002 and 004, the limitation v/as omitted since there should not be any oil and grease present due to the nature of their origin. To confirm that there ere no housekeeping or other problems which will need to be corrected, oil and grease monitoring lor discharges 002 and 004 is being required. According to General Electric, ail process wastewater produced in the metal finishing area has been diverted to the sanitary sewer. The rnetai monitoring is to confirm the above, If the monitoring results demonstrate that there is an appreciable concentration of metals, limitations will be developed for the next permit along with a compliance schedule. Monitoring of the Coosa River by the Georgia Environmental Protection Division has already established that polychlorinated byphenyls (PCBs) exist in the Coosa River, In the future we plan to initiate further studies to pinpoint any additional PCS sources. Any assistance that the S (x. A would be able to provide in this area would be appreciated. . When these studies are undertaken, one of our staff wiJJ contact the 5 & A to coordinate any possible assistance. If possible, we would appreciate being informed of the results of General Electric's adjudicatory proceedings on their New York State plant since this v/ill probably set a precedent concerning PCD limitations. Sincerely, (^1376 GD\V:mg Gene B, Welsh, Chief v'*:nr Pro-,branch qS* STLCOPCB4022315 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IV 121 F'CACHTNCe ST.. N. C. ATLANTA. GCONGIA 30309 4AEW:RGW OCT 22 1975 T1 '( RECEIVED Hr. Gene B. Welsh, Chief Water Protection Branch Department of Natural Resources Environmental Protection Division 270 Washington Street, S.W. Atlanta, Georgia 30334 >f.T '23 1975 LNVJRO.N'MENi/.L rYGUCEON Qj'.r.s* jj* VC/JlF t'OR' LPT T >A u P-X Dear Mr. Welsh: In accordance with the Memorandum of Agreement we have reviewed the effluent limits for the following dra t NPDES permits and have no comments: NPPES No. . Facility . GA0030937 Sweetwater Carpet Co, Ringgold, Georgia GA0023779 Soundlock Corp. llazelhurst, Georgia GA0001261 Georgia Marble Co. Tate, Georgia GA0000485 " Georgia Marble Co. Nelson, Georgia GA0000477 ' '. . Georgia Marble Co. Marble Hill, Georgia QA0002283 Emerson Electric Co. Statesboro, Georgia GA0030988 Salem Carpet Mills, Inc. ' Ringgold, Georgia In the case of the following facility there are comments. GA0024135 General Electric Co. Rome, Georgia 038492 STLCOPCB4022316 2 This short-terio permit contains essentially no discharge limitations, hut does specify monitoring requirements. V.'e concur with this approach for obtaining data from the company where neither guidelines nor adequate data base are available. This is the case with polychlorinated biphenyls. However, we would suggest that concentration limits be specified in this permit for oil and grease and the metals. We recommend that in addition to the company's self-monitoring data, Independent analytical data for the effluent and the stream be obtained. If you contact Billy Adams directly, it is possible that an S&A study could be carried out during the duration of this permit. General Electric Company has adjudicatory proceedings against the Environmental Protection Agency and the state of New York concerning PCB limits for a similar transformer facility. This case should also be resolved during the same period. CSW 038493 II STLCOPCB4022317