There are approximately thirty 55 gallon drums and two hundred cut open drums at the CNMI CUC Power Plant 3 facility at Isley Field, Saipan, CNMI.  In addition, 10 drums are located at the main CUC Power Plant in Garapan, Saipan, CNMI.  The drums are stored outside, subject to the weather and elements.

In March 2008, the CNMI CUC informed EPA of the presence of drums of transformer oil being stored at their Isley Field, Power Plant 3 facility.  CUC claimed that some sampling of the drums had occurred, but that there were no results could be provided by CUC.  On March 10, 2008, EPA, with the assistance of CNMI Division of Environmental Quality (DEQ), conducted sampling of a random subset of drums in order to determine whether some of the drums contained polychlorinated biphenyls (PCBs).  At that time, there were less than 300 drums stored at the Isley Field location and approximately 10% of the drums were collected into composite samples.  Analytical results indicated that at least one of the drums contained PCBs above RCRA regulatory level of 2 mg/kg.  Some heavy metals, including silver and zinc, were also present.

On November 20, 2008, EPA and DEQ conducted an additional sampling of the drums to determine which of the drums contained PCBs.  During this sampling event, the individual drums that were part of the composite sample which had a detection for PCBs were sampled as aliquots and all the remaining drums were sampled as composites.  All samples were analyzed at EPA Region 9’s Richmond Laboratory.  Results of the sampling revealed that one of the original drums contained PCBs and 11 of the composite sampling results indicated that there were PCBs present in at least one of the drums in the composite set.

On April 16, 2009, EPA and DEQ conducted additional sampling of the drums to determine which of the drums contained PCBs and at what concentrations.  Analytical results indicated that 18 additional drums contained PCB concentrations at above RCRA regulatory levels, and that 7 of the drums had concentrations above TSCA regulatory levels.  The highest concentration reported was 300 mg/kg PCBs.

After many attempts to get CNMI CUC to address the PCB and PCB contaminated oils being stored at the Power Plant 3 facility, EPA and DEQ conducted an inspection of the facility on November 17, 2009 and found that at least one of the PCB contaminated drums had failed and was spilling its contents onto the concrete slab at the facility.  EPA and DEQ also conducted additional sampling of soils and waste water at the facility to determine whether PCB contamination had impacted soils and other media at the Site.  EPA provided technical assistance to CUC to contain the control the source of the PCB spill. 

On December 11, 2009, The United States Environmental Protection Agency, Region 9 (EPA) received a Request for Federal Action from the CNMI Division of Environmental Quality (DEQ) (Attachment 1).  The request was for assistance to conduct a removal action to abate the hazards posed by the drums stored at the CUC Isley Field Power Plant.  DEQ has requested assistance for proper treatment and/or disposal of the drums and associated PCB wastes. 

- Overpack oil drums containing liquid PCBs 50-500 ppm (8 overpack drums)

- Consolidate oil drums containing liquid PCBs less than 50 ppm (12 overpacked 9 placed in new 55 gallon drums)

- Consolidate soil drums containing PCBs less than 50 ppm (consolidated into 6 cubic yard boxes)

- Load above overpacks drums, 55-gallon drums and cubic yard boxes into container for transport to mainland for disposal
- Tranport the loaded container to the port for shipment

- Consolidate non-PCB containing soil into  dump trucks for disposal at Marpi Landfill (Saipan).  Two truckloads (approximately twenty cubic yards) placed in the landfill and half truckload (approximately 6 yards of cleaner material) used as landfill cover.

- Crush empty used drums and send to on-island metal recycler

-  Demobilize personnel from site
 
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)

During the performance of the removal action, CUC, the PRP, provided logistical support to EPA; including providing security guards, a forklift, boomtruck, backhoe, dump truck and other support.

2.1.4 Progress Metrics