certified mail return receipt requested - us … · certified mail return receipt requested ......

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGlON 4

ATLANTA FEDERAL CENTER 61 FORSY-H-1 STREEr

ATLANTA, GEORGIA 30303-8960

CERTIFIED MAIL RETURN RECEIPT REQUESTED

Ms. Jessica Pennington Director of Safety and Environmental Compliance Florida Transformer, Inc. 4509 State Highway 83 DeFuniak Springs, Florida 32433

RE: Commercial Storage Polychlorinated Biphenyl (PCB) Approval EPA I.D. No. FLR 000 168 203

Dear Ms. Pennington:

Thank you for the June 5, 2017, Flori.da Transformer Inc. (FTI) updated application for renewal ofthe commercial storage PCB Approval (PCB Approval) to store PCB waste within designated areas at the DeFuniak FTI facility. Please find enclosed for your review a copy of the proposed commercial storage PCB Approval. The proposed PCB Approval has been prepared by the U.S. Environmental Protection Agency pursuant to Section 6(e)(l) of the Toxic Substance Control Act (TSCA), 15 U.S.C. § 2605(e) and the federal PCB regulations at 40 CFR Part 76 1. A final decision to issue the PCB Approval will be made following the close of the public comment period.

Also enclosed is a copy of the public notice announcing the proposed issuance of the Approval and the associated public comment period. In accordance with the EPA Region 4's policy, the EPA will provide a forty-five day public comment period on the proposed PCB Approval. The public comment period will be from July 24, 2017 to September 7, 2017. In addition, we have enclosed a copy of the EPA Fact Sheet for your use. On July 24, 20 17, we request the fo llowing:

• Place a copy of the proposed PCB Approval and the TSCA PCB application in the WaltonDeFuniak Library

• Publish the notice in a local newspaper of general circulation; and • Mail a copy of the Public Notice and Fact Sheet to the designated mailing list, including all

residents adjacent to the FTl prope1ty and all local emergency and government offices.

The Walton-DeFuniak Library li sted in the Public Notice will serve as the repository for local citizens wishing to review the proposed PCB Approval and application documents. In order to give area

Internet Address (URL) • http://www.epa.gov Recyc\eo/Recyclab\e • Pr\n\eo will\ Vege1ab\e 0\\ Baseo Inks on Recycled Paper \M1n,mvm 30% PoslcOflsumer\

residents an opportunity to meet and discuss the proposed PCB Approval, the EPA will hold an Availability Meeting (Open House) meeting on August 22 at 6pm at the DeFuniak Springs Civic Center located at 361 North 10th Street, Defuniak Springs, Florida 32433.

If you have any questions or comments concerning the proposed PCB Approval or the public notice, please feel free to contact Terri Crosby~Yega, Environmental Engineer (404) 562-8497 or by e lectronic mail at [email protected].

Enclosures

cc: Shawn Hamilton, FDEP

Sincerely,

~~ Meredith Anderson Acting Branch Chief Materials and Waste Management Branch

Florida Transformer, Inc.

FLR000168203 Rev. 0

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 4

ATLANTA FEDERAL CENTER

61 FORSYTH STREET, SW

ATLANTA, GEORGIA 30303

IN THE MATTER OF:


DeFuniak Springs, Florida

)

) Approval For The Commercial

) Storage Of Polychlorinated Biphenyl

) (PCB) Waste 40 CFR § 761.65

AUTHORITY

This renewal Approval to commercially store polychlorinated biphenyl (PCB) waste (Approval) is

issued to Florida Transformer, Inc. (FTI) pursuant to Section 6(e) of the Toxic Substances Control Act

(TSCA), 15 U.S.C. § 2605(e), and the federal PCB regulations promulgated thereunder at 40 CFR Part

761.

Section 6(e)(1) of the TSCA requires that the U.S. Environmental Protection Agency promulgate rules

for the disposal of PCBs. Rules implementing TSCA Section 6(e) were published in the May 31, 1979,

Federal Register (44 FR 31542) and recodified in the May 6, 1982, Federal Register (47 FR 19527).

Those rules also regulated the storage of PCB waste prior to disposal under the TSCA Section 6(e)(1)

disposal authority for PCBs. Amendments to these rules were published in the December 21, 1989, and

June 28, 1998, Federal Register (54 FR 52746 and 63 FR 35384). The current rules for PCB storage

facilities are codified at 40 CFR § 761.65, “Storage for disposal.”

BACKGROUND

The operator of the facility is FTI doing business as Emerald Transformer, Florida. “Emerald

Transformer” is a business name coined for marketing purposes. FTI’s facility is located in DeFuniak

Springs, Florida, (“facility”) on approximately twenty-four acres in Walton County. FTI is an electrical

power and distribution equipment service, decommission and repair facility. FTI repairs and rebuilds

oil-filled electrical equipment, primarily electrical regulators and transformers. FTI also scraps obsolete

equipment at its facility. All incoming oil-filled equipment is screened for PCB content. Most of the


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units arriving at FTI’s facility are non-PCB. However, a small percentage of arriving units are classified

as PCB or PCB-contaminated equipment. Equipment classified as PCB equipment contains greater than

or equal to 500 parts per million (ppm) PCBs, while equipment that is PCB contaminated contains

between 50 and 500 ppm. All PCB contaminated equipment received onsite is immediately relocated to

the approved PCB storage area. The PCB oil is removed from the PCB and PCB-contaminated units and

placed in containers for storage. FTI stores the PCB containers along with drained PCB transformers in

a dedicated PCB storage area. Currently, FTI scraps only non-PCB units on-site. All PCB liquids and

drained PCB and PCB-contaminated equipment are disposed offsite at TSCA-approved PCB disposal

facilities or processed in FTI’s chemical dechlorination mobile treatment unit. The PCB-1000 chemical

dechlorination unit (CD Unit) is a non-thermal alternative PCB disposal method which destroys PCBs in

mineral oil dielectric fluid. The CD Unit was issued a PCB Approval on April 22, 2015 by EPA

Headquarters for treatment of PCB waste with PCB concentrations greater than two ppm but less than

2,000 ppm. In the April 22, 2015, PCB Approval for the CD Unit, FTI is limited to 180 cumulative days

within any year of operation onsite at any facility. The CD Unit will remain under the EPA Headquarters

PCB Approval Conditions.

FTI also operates a Scrap Metal Recovery Oven at the facility. Drained PCB-contaminated equipment

(containing 50ppm-499ppm PCB) is processed for disposal at the FTI facility. In 2009, FTI

demonstrated PCB combustion efficiency at required levels of 99.9999% to effectively remove PCBs

from the equipment by thermal destruction. This unit was issued an air operating permit in February

2010 by the State of Florida Department of Environmental Protection Division of Air Resource

Management and is not covered under this Approval.

Under 40 CFR § 761.65(d), FTI must obtain a commercial storage Approval to receive and store PCB

waste onsite. On July 20, 1990, FTI elected to seek EPA approval to operate as a commercial PCB

storage facility, although not required by rule to obtain a written approval for PCB storage. On

November 14, 2002, the EPA issued to the FTI facility a commercial PCB storage Approval authorizing

the maximum storage of 16,435 gallons of PCB waste. The Approval expired on November 14, 2012. A

timely notice of intent to continue PCB operations was submitted by FTI on March 15, 2012 in

accordance with Condition I.E(2) of the Approval; therefore, the Approval has remained in full effect

until a new Approval is issued by the EPA. As requested by the EPA, FTI submitted a new application


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on July 15, 2015 which was updated on June 5, 2017. The new application requested an additional

storage tank to be added to the Approval without increasing the total maximum storage capacity. The

renewal application also requested to include PCB remediation waste and an overall reduction in storage

capacity to 15,000 gallons of PCB waste. After a completeness and technical adequacy review of the

application, EPA has determined that the application meets the regulatory criteria for issuance of an

Approval, identified at 40 CFR § 761.65(d)(2)(i) through (d)(2)(vii).

APPROVAL

The EPA hereby grants approval to FTI, 4509 State Highway 83 N, DeFuniak Springs, Florida (EPA ID

No. FLR000168203), to commercially store PCB waste for disposal, subject to the Approval Conditions

stated herein, and based on the information described in the approved application.

This Approval shall become effective on the date of signature and shall expire ten (10) years from the

date of signature, unless revoked, suspended, or terminated in accordance with the Approval Conditions

stated herein.

This Approval does not relieve FTI from compliance with all applicable federal, state and local

regulatory requirements, including the federal PCB regulations at 40 CFR Part 761, and any

amendments or revisions thereto.

__________________________ ______________________

Date G. Alan Farmer

Director

Resource Conservation and Restoration Division


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AUTHORITY ............................................................................................................................................ 1

BACKGROUND ....................................................................................................................................... 1

APPROVAL .............................................................................................................................................. 3

I. STANDARD CONDITIONS .............................................................................................................. 5 A. EFFECT OF APPROVAL ........................................................................................................................... 5

B. SEVERABILITY ....................................................................................................................................... 5

C. APPROVAL COMPLIANCE ....................................................................................................................... 5

D. APPROVAL SUSPENSION/REVOCATION .................................................................................................. 6

E. APPROVAL EXPIRATION AND CONTINUATION ....................................................................................... 6

F. APPROVAL RENEWAL ............................................................................................................................ 6

G. APPROVAL MODIFICATION .................................................................................................................... 6

H. ENTRY AND INSPECTION ....................................................................................................................... 7

I. CHANGE IN OWNERSHIP ......................................................................................................................... 7

J. INAPPLICABILITY OF PAPERWORK REDUCTION ACT ............................................................................... 8

II. GENERAL FACILITY CONDITIONS ........................................................................................... 8 A. Operation of Facility ............................................................................................................................ 8

B. Sampling/Analysis ............................................................................................................................... 8

C. Security ................................................................................................................................................. 8

D. Personnel Training ............................................................................................................................... 9

E. Safety .................................................................................................................................................... 9

F. Spills ................................................................................................................................................... 10

G. Emergency Procedures ....................................................................................................................... 10

H. Recordkeeping and Reporting ............................................................................................................ 11

I. Closure and Financial Requirements ................................................................................................... 11

J. Incapacity of Owners or Operator, Guarantors or Financial Institutions ............................................ 12

III. PCB STORAGE MANAGEMENT ................................................................................................ 12 A. Receipt and Processing of Equipment Designated for Disposal ........................................................ 12

B. Approved PCB Storage Areas ............................................................................................................ 13

C. PCB Storage Area Marking ................................................................................................................ 13

D. Design Requirements of Storage Areas ............................................................................................. 14

E. Maximum PCB Storage ...................................................................................................................... 14

F. Containers ........................................................................................................................................... 14

G. Aisle Space Requirement ................................................................................................................... 14

H. Container Stacking and Row Width Limits ....................................................................................... 14

I. Management of PCB Containers in Storage ........................................................................................ 15

J. Inspection Requirements ..................................................................................................................... 15

FIGURE 1- FACILITY SITE MAP................................................................................................................ 16

FIGURE 2- SAMPLE PCB STORAGE AREA STAGING ............................................................................... 17

FIGURE 3- GENERAL PCB BULK STORAGE TANK .................................................................................. 18


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COMMERCIAL STORAGE APPROVAL CONDITIONS FOR

STORAGE OF POLYCHLORINATED BIPHENYL (PCB) WASTES

AT THE FLORIDA TRANSFORMER INC.

DEFUNIAK SPRINGS, FL 40475

EPA ID NO: FLR000168203

I. STANDARD CONDITIONS

A. Effect of Approval

1. FTI may store PCB waste in accordance with these Approval Conditions and the federal PCB

regulations at 40 CFR Part 761. Any storage of PCB waste not authorized in this Approval is

prohibited.

2. Issuance of this Approval does not convey property rights of any part or any exclusive

privilege, nor does it authorize any injury to persons or property, any invasion of other

private rights or any infringement of state or local laws or regulations.

3. Compliance with these Approval Conditions does not establish a defense to any other

applicable laws that provide protection from any unreasonable risk to public health and the

environment, including the federal PCB regulations at 40 CFR Part 761.

4. This Approval does not relieve FTI from compliance with all applicable federal, state and

local regulatory requirements, including the federal PCB regulations at 40 CFR Part 761.

B. Severability

The provisions of this Approval are severable, and if any provision of this Approval or if the

application of any provision of this Approval is held invalid, the remainder of this Approval shall

not be affected thereby.

C. Approval Compliance

1. FTI must comply with and operate in accordance with the provisions of the federal PCB

regulations at 40 CFR Part 761 and with the Approval Conditions stated herein.

2. These Approval Conditions are based on the facts, representations, and certifications made

by FTI in its approved application. The “application” or “approved application” means: FTI’s

July 30, 2015, Application for a PCB Commercial Storage Facility as revised on June 6, 2017

(incorporated herein by reference).

3. In the event that these Approval Conditions are inconsistent with the approved application,

FTI must abide by the Approval Conditions stated herein.


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D. Approval Suspension/Revocation

1. Departure from these Approval Conditions, the approved application, approved

modification(s) to this Approval, or the federal PCB regulations without a prior written

approval by EPA may result in the immediate revocation, suspension, and/or modification of

this Approval in addition to any legal or equitable relief or remedy the EPA may choose to

pursue.

2. Any misrepresentation or omission of any material fact in the facility application or in any

records or reports may result in the EPA’s revocation, suspension and/or modification of this

Approval, in addition to any other legal or equitable relief or remedy the EPA may choose to

pursue.

3. This Approval may be suspended or revoked at any time by EPA when it has reason to

believe that the continued operation of this facility presents an unreasonable risk to human

health or the environment.

E. Approval Expiration and Continuation

1. This Approval to commercially store PCBs shall expire ten years from the date of EPA's

issuance of this Approval.

2. This Approval and its conditions herein will remain in effect beyond the Approval expiration

date if FTI has submitted a timely, complete and adequate notice of intent to continue the

Approval and, through no fault of FTI, EPA has not issued an Approval renewal.

F. Approval Renewal

1. To continue the commercial storage of PCB and PCB items granted by this Approval after

the expiration date of this Approval, FTI must notify EPA by written notice of its intention to

continue the Approval at least 180 days, but not more than 270 days prior to the expiration

date of this Approval.

2. EPA may require FTI to submit additional information in connection with the renewal of this

Approval. EPA shall review the submitted information and determine if this Approval is to

be renewed.

G. Approval Modification

1. FTI shall notify EPA in writing of any proposed modification of this Approval or FTI's

approved application.

2. A "major modification" is defined as any change to the storage areas, the maximum PCB


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storage inventory, the closure plan, or any other changes which affect overall performance or

environmental impact of the facility. A major modification to this Approval or the final

application shall be made only upon the written approval of the Resource Conservation and

Restoration Division (RCRD) Director, EPA Region 4.

3. A “minor modification” is defined as administrative or informational change, which may

include: correction to typographical errors; changes to conform to revised Agency guidance

or regulations; or any other change by the Agency or FTI which does not affect overall

performance or environmental impact. A minor modification to this Approval or the

application shall be made upon the written concurrence of the Materials and Waste

Management Branch Chief of EPA, Region 4.

H. Entry and Inspection

FTI shall allow EPA authorized representative(s) to, at reasonable times:

1. Inspect FTI's property to determine compliance with this Approval or the federal PCB

regulations;

2. Inspect any records that must be kept relative to this Approval or the federal PCB

regulations;

3. Take sample(s) for the purpose of assessing this Approval or the federal PCB regulations;

and

4. Inspect FTI's activities relative to this Approval or the federal PCB regulations.

I. Change in Ownership

1. The EPA will recognize the transfer of this Approval to a new owner/operator if all of the

following conditions are met:

a. The transferee demonstrates it has established financial assurance for closure of the

facility pursuant to 40 CFR § 761.65(g);

b. FTI must maintain its financial assurance for closure until EPA transfers this Approval,

so that there will be no lapse in financial assurance for closure of the transferred facility;

c. The transferee submits a new and complete application for final storage Approval

including all of the elements listed in 40 CFR § 761.65(d);

d. The transferee resolves any deficiencies EPA has identified in its application; and

e. The transferee submits a signed and notarized affidavit which states that the transferee


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shall comply with all the terms and conditions of this Approval.

2. Failure by FTI or the transferee to comply with any of the provisions of this condition shall

render this Approval null and void.

J. Inapplicability of Paperwork Reduction Act

Any and all information required to be maintained or submitted pursuant to this Approval is not

subject to the Paperwork Reduction Act of 1980, 44 U.S.C. § 3501 et seq., because it is

information collected by EPA from a specific individual or entity for the purpose of assuring

compliance with this Approval.

II. GENERAL FACILITY CONDITIONS

A. Operation of Facility

1. FTI must maintain and operate the facility to prevent fire, explosion, or releases of PCBs to

air, soil, ground water or surface water.

2. FTI shall not use a cutting torch or other thermal methods to cut PCB painted metal unless

the cutting zone is first mechanically or chemically decontaminated to meet 40 CFR §

761.79(b)(3)(i)(A).

B. Sampling/Analysis

1. FTI shall use gas chromatography for chemical analysis of PCBs when testing samples

collected during PCB spill cleanups and facility closure and for demonstrating compliance

with the terms of this Approval and the PCB regulations at 40 CFR Part 761. This

requirement is not intended to restrict FTI’s use of other test methods for purposes of PCB

screening of oil-filled transformers and regulators received at the Inprocessing Facility.

2. PCB concentrations for liquid, non-liquid, multi-phasic wastes shall be determined and

reported as specified in 40 CFR § 761.1(b).

3. When determining PCB surface concentrations for purposes of verifying decontamination of

non-porous surfaces and conducting PCB spill clean-up in accordance with the PCB Spill

Cleanup Policy, FTI shall use a standard wipe test as defined in 40 CFR § 761.123, unless the

Visual Standard No. 2 is applicable.

C. Security

The facility must be secured to restrict public access to PCB waste stored on the premises. The


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storage area shall be secured at all times (e.g. gates closed).

D. Personnel Training

1. FTI shall ensure through documented training, that personnel, who are directly involved with

handling or disposal of PCBs are familiar with the requirements of this Approval, and

regulatory requirements under 40 CFR Part 761 as they relate to specific job tasks. Training

for personnel directly involved in the operation and maintenance of the PCB storage areas

must include, at a minimum:

a. The types of PCB waste that may be stored;

b. Safe PCB sampling and handling procedures;

c. The location of spill response equipment and proper usage techniques;

d. The health and environmental hazards that PCBs pose to the individuals/employees and

the environment;

e. Basic recordkeeping requirements under this Approval and the location of records;

f. Inspection requirements, including use of facility specific inspection forms;

g. Notification requirements;

h. Disposal requirements for regulated PCB wastes generated during the operation of the

PCB storage area; and

i. Reporting requirements.

2. Training for new employees involved with managing PCBs shall be completed within 30

days of employment.

E. Safety

1. FTI shall comply with all applicable safety and health standards, as required by federal, state

and local regulations and ordinances. The Federal OSHA requirements can be found at

www.osha.gov.

2. Injuries or illnesses directly related to PCB exposure, or resulting from spills or handling of

PCBs during the approval period, must be reported to the EPA Region 4 in writing. The

report must include a description of the incident and the corrective measures or treatment

provided. Within five days of completing the corrective measures and/or treatment, FTI must

submit the report to:


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U. S. Environmental Protection Agency

Resource Conservation and Recovery Division

Attention: Terri Crosby-Vega

Atlanta Federal Center

61 Forsyth Street, S.W.

Atlanta, GA 30303-8960

F. Spills

1. If in the course of operation, there is a spill or release of one pound or more of pure PCBs (a

reportable quantity [RQ] into the environment as defined under the Comprehensive

Environmental Response Compensation and Liability Act, 40 CFR Part 302, “Designation,

Reportable Quantities, and Notification”), FTI must immediately notify the National

Response Center at (800) 424-8802. Releases or spills of ten (10) pounds or more of pure

PCBs and PCB releases or spills in any amount which pose a potential for significant

exposure to humans, animals, or the environment, shall be immediately reported to the NRC

and to the EPA, Region 4 at (404) 562-8440, or (404)-562-8705. Further, for any spills or

releases of an RQ of PCBs that leave the facility and enter the environment through any

conveyance or means, FTI may be required to notify not only the NRC, but also the Local

Emergency Planning Committee and the State Emergency Response Commission as required

by Section 304 of the Emergency Planning and Community Right to Know Act (EPCRA), 42

U.S.C. §11004.

2. A written summary report about a reportable spill incident, as identified in the preceding

paragraph, must be submitted to EPA within five business days following the incident.

When EPA requests a detailed report on the incident, this report shall be submitted to EPA

within 15 business days following the request. The detailed report shall include, but not be

limited to, a description of the spill, cleanup activities, and changes in the FTI operations to

prevent such spills in the future.

3. Cleanup of PCB spills shall begin immediately pursuant to 40 CFR Part 761, Subpart G,

“PCB Spill Cleanup Policy.”

4. Any debris or solid wastes generated as a result of clean up or decontamination of a PCB

spill or release shall be disposed of in a facility approved to dispose of PCBs as required by

40 CFR § 761.60.

G. Emergency Procedures

FTI must, without delay, implement appropriate measures whenever there is a fire or any PCB

related emergency which could threaten human health or the environment. In such an

emergency, FTI must notify the EPA, Region 4’s Emergency Planning and Response Center at

(404) 562-8705 and the EPA Region 4 RCRD at 404-562-8440 and any other appropriate


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authority, as applicable.

H. Recordkeeping and Reporting

1. FTI must maintain at the facility: a copy of this Approval; all employees training records, the

Spill Prevention Control and Countermeasure Plan; inspection records, inventory records,

and records documenting sampling and analytical procedures used to determine PCB

concentrations. All reports and other information requested by EPA shall be signed by the

facility manager and shall contain the certification as defined in 40 CFR § 761.3.

2. FTI must record the facility specific inspections required by Approval Conditions III.J.1 and

3 of this Approval, in a facility specific inspection log or summary. Records of inspections,

training, maintenance, cleanup and disposal must be maintained at the facility in accordance

with this Approval and 40 CFR § 761.180(a) and (b).

3. All records required by this Approval and/or supporting documentation must be made

available to the EPA upon request during regular business hours. Inspection records must be

kept three years from the date of the inspection.

4. FTI shall prepare and maintain all other records and documents, including annual records,

annual document logs and annual reports as required by 40 CFR § 761.180(b). The annual

report shall include a certification statement as defined in 40 CFR §761.3.

5. FTI shall retain all records required by this Approval or the federal PCB regulations at 40

CFR Part 761 during the course of any unresolved enforcement action regarding the facility

or upon request by EPA, notwithstanding any other provision of this Approval or the federal

PCB regulations at 40 CFR Part 761.

6. FTI shall only send out “Certificates of Disposal” if the disposal/destruction/treatment has

been performed onsite.

I. Closure and Financial Requirements

1. FTI must maintain a facility specific closure plan, a facility specific closure cost estimate,

and corresponding financial assurance for closure, in accordance with 40 CFR §§ 761.65(e),

(f) and (g), respectively. Financial assurance for closure shall be at least in the amount of the

cost estimates in the closure plan estimating that the maximum PCB waste inventory be

removed and treated by a third-party.

2. FTI shall submit to the EPA a written request to modify the approved closure plan whenever

any of the conditions listed in 40 CFR § 761.65(e)(4) arise.

3. When EPA approves a modification to the facility's closure plan and that modification

increases the cost of closure, FTI shall revise the closure cost estimate and the financial


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assurance mechanism, if applicable, no later than thirty (30) days after the modification is

approved.

4. During the active life of the PCB storage operations, FTI must annually adjust the facility’s

closure cost estimate for inflation and for changes beyond control of FTI which may affect

PCB disposal costs.

5. All financial assurance documentation and/or request for modifications shall be submitted to

the EPA.

6. The type of financial assurance mechanism used by FTI may be modified with prior written

approval from the EPA.

7. FTI shall keep a copy of the current closure plan, closure cost estimate financial assurance

document(s) at the DeFuniak Springs facility and make such documents available to EPA

inspectors for review, upon request.

J. Incapacity of Owners or Operator, Guarantors or Financial Institutions

1. FTI shall notify the EPA by certified mail of the commencement of a voluntary or

involuntary proceeding under Title 11 (Bankruptcy), U.S. Code, naming the FTI as a debtor,

within ten days of commencement of the proceeding.

2. If FTI uses any of the mechanisms listed in 40 CFR § 264.148(b) to establish financial

assurance required by this Approval and an event identified in § 264.148(b) arises, FTI will

be deemed to be without the required financial assurance and must establish other financial

assurance within 60 days after such an event.

III. PCB STORAGE MANAGEMENT

A. Receipt and Processing of Equipment Designated for Disposal

1. PCB and PCB-contaminated equipment may be stored within FTI’s Inprocessing Facility

outside of the approved PCB storage areas for up to 30 days from the date of their removal

from service in accordance with 40 CFR § 761.65(c)(1). The removed from service date is

the day on which FTI receives gas chromatographic analytical results confirming the oil in

the equipment contains > 50 ppm PCB and FTI determines the equipment will be scrapped

rather than repaired.

2. For PCB-contaminated electrical equipment designated for disposal, all free-flowing liquid

shall be removed from the equipment and the removed PCB liquid shall be transferred to

containers in the approved PCB Storage Unit, within 30 days of the removed from service

date as specified in Approval Condition III.A.1. Alternatively, non-leaking and structurally


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undamaged PCB-contaminated electrical equipment, including bushings, may be stored on

pallets next to the approved PCB Storage Unit in accordance with 40 CFR § 761.65(c)(2).

Storage for disposal of PCB-contaminated articles from which all free-flowing liquid has

been removed is not regulated under 40 CFR § 761.65.

3. PCB equipment, whether drained or undrained shall be transferred to an approved PCB

storage area, within 30 days of the removed from service date as specified in Approval

Condition III.A.1.

4. Plastic bags and oil pads shipped to FTI with leaking electrical equipment are managed as

PCB waste by FTI regardless of the PCB content of the incoming equipment. FTI may

temporarily store these wastes in a suitable container for up to 30 days from the container fill

start date in accordance with 40 CFR § 761.65(c)(1). After 30 days from the container fill

date the container shall be transferred to the approved PCB storage unit or the container may

be placed into a PCB marked, secondary containment area next to the approved PCB storage

unit.

5. PCB remediation waste shipped to FTI shall be stored in the PCB storage unit. FTI shall

ensure that all PCB remediation waste is disposed of within one year from the date it was

determined to be PCB waste and the decision was made to dispose of it.

B. Approved PCB Storage Areas

Except as allowed under Approval Conditions III.A.1- 4, PCB waste, including but not limited to

containers of PCB liquid, drained PCB transformers, and drained and undrained PCB bushings,

shall be stored in the approved PCB storage areas located within the Inprocessing Facility. The

approved PCB storage areas are the PCB Storage Units and the Secondary Containment Area as

depicted in Figure 1. Figure 2 provides an example of the PCB staging within the PCB storage

area. Figure 3 depicts an example of the general bulk PCB oil storage tank design.

C. PCB Storage Area Marking

1. The approved PCB storage areas, as well as any temporary PCB storage area or ancillary

pallet storage area authorized under Approval Conditions III.A.1 - 4, shall be marked as

required in 40 CFR §761.40(a)(10).

2. PCB Items in storage shall be marked in accordance with applicable requirements in 40 CFR

§761.40. PCB Items shall be dated in accordance with 40 CFR §761.65(c)(8).

3. PCB waste storage shall be managed so that the PCB item can be located by the removal

from service date or by the item’s unique tracking number.

4. Any vacuum equipment or other equipment used to collect PCB decontamination residues

must be labeled with the ML mark while in service and while in standby mode between uses


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and until properly decontaminated.

D. Design Requirements of Storage Areas

The approved PCB storage areas identified in Approval Condition III.B shall be maintained in

accordance with the requirements at 40 CFR § 761.65(b) and as specified in the approved

application.

E. Maximum PCB Storage

1. FTI is authorized to store no more than the amounts of PCB materials specified herein:

a. 100 55-gallon PCB containers or 8,500 gallon-equivalent PCB containers;

b. 6,475 gallons of >50 ppm containing oil in five 1,295 gallon tanks;

c. 50 drained or undrained PCB and PCB-contaminated transformers;

d. 40,000 pounds of PCB bushings, PCB-contaminated bushings, and/or PCB remediation

waste.

2. The total volume of PCB waste that may be stored for disposal at FTI in PCB containers and

articles shall not exceed 15,000 gallons.

F. Containers

1. PCB containers used for storage of PCB waste shall be limited to those container types

authorized for PCB storage under 40 CFR § 761.65(c)(6).

2. Stationary PCB storage containers used for storage of PCB liquids shall be as specified in the

FTI PCB Tank specifications section of the application and comply with the requirements of

40 CFR § 761.65(c)(7)(i).

G. Aisle Space Requirement

Aisle space within the storage area must be maintained at all times to allow the unobstructed

movement of personnel, fire protection equipment, spill control equipment and decontamination

equipment.

H. Container Stacking and Row Width Limits

1. Containers may be stacked subject to the following limitations:

a. Larger containers shall not be stacked on top of smaller ones unless the weight of the

upper container tier can be safely supported;

b. Containers having a capacity greater than 5 gallons shall not be stacked more than two

containers high; and


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c. Pallets (or plywood sheets) shall be used between container tiers when the stack height

exceeds one container, except that 5-gallon capacity containers may be stacked up to

three containers high, without pallets (or plywood sheets) between tiers.

2. Generally, containers shall be stored in rows no more than two containers wide. However,

FTI may store PCB containers in rows three containers wide provided that the containers are

stored in a manner does not endanger employees or impede routine inspections, as required

by this Approval. During compliance inspections conducted by EPA, FTI will move items as

requested by the inspector(s) to allow the inspector(s) full access to the facility and stored

PCB items. All PCB marks shall be visible from the aisle.

I. Management of PCB Containers in Storage

1. PCB containers shall always be closed during storage, except when adding and removing

their contents, and they must not be opened, handled or stored in a manner which may

damage them or cause them to leak.

2. PCB containers and PCB articles shall be stored so that required PCB marks, storage dates

and other identification information can be easily read by any inspector.

J. Inspection Requirements

1. All PCB items stored within the approved PCB storage areas shall be checked for leaks at

least once every 30 days. PCB items stored in temporary or ancillary storage areas in

accordance with paragraphs (c)(1) and (c)(2) of 40 CFR § 761.65 and Approval Conditions

III.A.1 - 4, shall be checked for leaks, weekly.

2. Any leaking PCB item and its contents shall be transferred immediately to properly marked

non-leaking containers. Any spilled or leaked materials shall be immediately cleaned up and

the materials and residues containing PCBs shall be disposed of in accordance with 40 CFR

§ 761.61.

3. The condition of floor, joints and curbing in the approved PCB Storage Unit and the integrity

of the Secondary Containment Area metal drip pans shall be inspected at least semi-

annually. Any needed repairs noted during such inspections shall be made within 30 days of

the inspection date unless a longer repair period is authorized by EPA.

4. Records of inspections, maintenance, cleanup and disposal must be maintained in accordance

with 40 CFR § 761.180(a) and (b).


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Figure 1- Facility Site Map


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Figure 2- Sample PCB Storage Area Staging


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Figure 3- General PCB Bulk Storage Tank

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