Pollution/Situation Report Profile

CNMI CUC Isley
Dan Dan, Saipan, MP - EPA Region IX
POLREP #2
CUC Power Plant 3 Polrep #2 and Final

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U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
CNMI CUC Isley - Removal Polrep
Final Removal Polrep

EPA Emergency Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region IX

Subject:

POLREP #2
CUC Power Plant 3 Polrep #2 and Final
CNMI CUC Isley
09TH
Dan Dan, Saipan, MP
Latitude: 16.0000000 Longitude: 145.5003000

To:

From:

Chris Reiner, OSC

Date:

3/26/2012

Reporting Period:

10/13/11-11/1/11

1. Introduction

1.1 Background

Site Number:	09TH	Contract Number:
D.O. Number:		Action Memo Date:
Response Authority:	CERCLA	Response Type:	Time-Critical
Response Lead:	EPA	Incident Category:	Removal Action
NPL Status:	Non NPL	Operable Unit:	01
Mobilization Date:	2/11/2010	Start Date:
Demob Date:	11/1/2011	Completion Date:	11/1/2011
CERCLIS ID:	MPN000908795	RCRIS ID:
ERNS No.:		State Notification:	Yes
FPN#:		Reimbursable Account #:

1.1.1 Incident Category

TIme critical removal action.

1.1.2 Site Description

EPA has conducted multiple removal assessments/actions relating to the Commonwealth Utilities Commission (CUC) Power Plants in Saipan, CNMI. The first phase of this removal action focused on removal of drums containing polychlorinated biphenyl (PCB) wastes located in drums being stored the CUC Power Plant 3 facility at Isley Field in Dan Dan, Saipan, CNMI ("the Site"). The current phase is focused on removal of asphalt and soil contaminated with PCBs and removal of sludges in drains on the site, which are contaminated with heavy metals.

1.1.2.1 Location

The Site is located at Isley Field, adjacent to the Saipan airport, in Dan Dan, CNMI.

1.1.2.2 Description of Threat

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.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

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.

2. Current Activities

2.1 Operations Section

2.1.1 Narrative

OSC Reiner and personnel from ERRS and START were on Saipan as part of a multi-site removal action related to the CUC power plants on the island, primarily at Power Plant 1&2. During this time, EPA completed the removal action at Power Plant 3 (PP3). This work consisted of removing asphalt and soil contaminated with PCBs, and sludges present in drains and the oil/water separator, which are contaminated with heavy metals.

2.1.2 Response Actions to Date

10/13/11 - EPA OSC (2), ERRS (1), START (1): OSCs Reiner and Rogow do site walk with START and ERRS to plan removal of PCB-contaminated asphalt and soil and metals-contaminated sludges.

10/15/11 - EPA OSC (1), START (1): START delineates area of PCB-contaminated asphalt to be removed.

10/19/11 - EPA OSC (1), ERRS (3), START (1), small wheeled excavator: ERRS begins removal of asphalt, placing it in cubic-yard transport boxes. ERRS clears vegetation and shovels out sludge from east and west trench drains at entrance gates. Sludges are placed in drums. START takes 4 confirmation soil samples in area where asphalt has been removed.

10/20/11 - EPA OSC (1), ERRS (3), START (1) , small wheeled excavator: ERRS completes removal of asphalt and any soil showing apparent staining, placing it in cubic-yard transport boxes. A total of 7 cubic-yard boxes were filled with asphalt and excavated soil. ERRS begins removing sludge from oil/water separator, placing it in drums. START takes 2 confirmation soil samples in area where asphalt has been removed.

10/21/11 - EPA OSC (1), ERRS (3), START (1): ERRS completes removal of sludge from oil/water separator. A total of 18 drums were filled with sludge removed from the trench drains and OWS.

10/29/11 - EPA OSC (1), ERRS (3), forklift: ERRS prepared shipping container and loaded drums and boxes into container for shipping.

11/1/11 - EPA OSC (1), ERRS (3): Container picked up from PP3 by transporter. Demobilized from Site.

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)

This removal action took place in the context of a stipulated order against CUC, which required this removal action to take place. As described above, CUC indicated that they did not have the expertise or resources to undertake the removal and requested that EPA do so.

2.1.4 Progress Metrics

Waste Stream Medium Quantity Manifest # Treatment Disposal

PCB debris and soil soil, asphalt 7 cubic yards
18,000 lbs 9066-1 Landfill
Waste Management
Arlington, OR

Lead and chrome
sludge sediment 18 drums
9,000 lbs 000018782 DAT Landfill
Burlington Environmental
Kent, WA

2.2 Planning Section

2.2.1 Anticipated Activities

All anticipated and planned removal activities to be performed under this removal action have been completed.

2.2.1.1 Planned Response Activities

2.2.1.2 Next Steps

Waste materials will be shipped back to the U.S. Mainland for proper disposal.

2.2.2 Issues

None

2.3 Logistics Section