The wastes are currently located in two large transformers, with multiple compartments each and a number of smaller transformers with a single compartment.  One of the large transformers is located at the Apra Heights Substation facility and the other is located at the Talofofo Substation facility.  The smaller transformers are located at a storage location in Dededo, all on the island of Guam.  All of the transformers are stored outside, subject to the weather and elements.

The transformers which contain PCBs, and are leaking, have been stored in the open environment, in use for a period of over 40 years.  In light of the condition of the various transformers, and the potentially hazardous nature of the waste, this constitutes an actual and/or threatened release into the environment of a hazardous substance, pollutant or contaminant.  The transformers continue to leak and are deteriorating within the Site.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

In March 2012, the Guam Environmental Protection Agency (GEPA) approached EPA with a request for assistance from Guam Power Authority (GPA) regarding transformers at their facilities which had been identified as contaminated with polychlorinated biphenyls (PCBs).  In April 2012, the EPA Pacific Islands Office contacted the EPA Region 9 Emergency Response Section (ERS) and requested assistance.  GPA had conducted sampling of the transformers.  Analytical results were provided to EPA and reviewed by ERS. 

On April 23, 2012, ERS conducted a site walk of the substation locations.  Two large transformers, which contained approximately 3000 gallons of oil were observed.  Both transformers were leaking from different locations.  Each transformer contained two compartments, which contained oil and were sampled by GPA.  The results of the sampling indicated that 3 of the compartments contained off-spec used oil, regulated by RCRA, with PCB concentrations that exceeded 2 mg/kg.  One of the compartments contained PCB oil, regulated under TSCA, with a concentration exceeding 50 mg/kg of PCBs.  While the large transformers in Apra Heights and Talofofo were located inside of secondary containment, they were leaking from different locations.  While drip pans had been placed underneath some of the leaks, others were being disbursed along the sides of the transformer and could not be contained in one location.  The secondary containment areas had oil staining and puddles, and each of the secondary containments were free of water, indicating that they had been drained.  Each of the drainage valves discharged into surface soils.  It is unknown how long the transformers have been leaking, but GPA has plans to repair the transformers once they are drained of the oil. 

In addition, there are a number of smaller transformers that contain PCBs and are being stored at the Dededo storage facility.  The condition of these transformers is unknown but they are being stored outside and subject to the elements.

5/30/2012 – EPA: 1, START: 1, ERRS: 1, GRESCO: 6, GPA: 4, GEPA: 3 – In the morning, an inbriefing and operational overview was conducted by EPA at the GPA main office in Harmon.  GEPA, and EPA contractors also attended.  Coordination regarding power transfer and removal operations were discussed.  GPA committed to have a team of at least 3 people on site to assist EPA with access to the transformers, provide technical expertise regarding the equipment and other assistance they might be required.  GPA informed EPA that the Apra Heights Substation was already set up with back up power, but that they were still working on getting the Talofofo back up power running.  Discussion also included what material would be used to rinse the transformers.  GPA was concerned with any foreign material (such as diesel) being used and therefore, it was decided that transformer (mineral) oil would be used and that it would be supplied by GPA for the operation, as needed.  GEPA requested information on the generator ID and the action memo.  In the afternoon, work began at Apra Heights Substation, with the draining of the LTC (small) compartment into drums since the concentration was over 50 ppm PCBs.  GPA provided assistance with access to the transformers, protecting the equipment during the transfer operations and re-sealing the transformer access ways.  By the end of the day, approximately 205 gallons were removed from the LTC compartment.  Drums were placed into secondary containment (salvage drums) and operations were wrapped up for the day. 

5/31/2012 -   EPA: 1, START: 1, ERRS: 1, GRESCO: 5, GPA: 4, GEPA: 3 – In the morning, the LTC compartment was opened again to see if any additional material could be drained.  Less than a gallon came out.  The LTC compartment was then filled with new transformer oil (approximately 215 gallons) in preparation for a 24 hour soak.  The isotainer was brought in and large compartment of the transformer was hooked up to pump its contents into the isotainer.  Approximately 2780 gallons of transformer oil was drained from the large compartment.  Operations at Apra Heights were wrapped up for the day, and the crew mobilized to Talofofo to begin work there.  Both the LTC compartment and the main compartment oils were transferred into the isotainer.  Approximately 207 gallons were removed from the Talofofo LTC compartment and 2780 gallons from the main compartment.  Once again, GPA provided support with access to the transformer compartments, assistance during transfer operations and closure of the units when transfers were complete.  START received the supplies for sampling, and conducted soil sampling at Talofofo and Apra Heights along the pathway of drainage from the outlet valve for the secondary containment.

6/1/2012 – EPA: 1, START: 1, ERRS: 1, GRESCO: 5, GPA: 4;  Apra Heights -  In the morning the crew mobilized to Apra Heights and drained the rinse oil from the LTC compartment after the 24 hour soak into drums.  Approximately 215 gallons were drained from LTC compartment.  They also drained an additional 5 gallons out of the main compartment after it had sit empty for 24 hours.  That material was transferred to the isotainer.  GPA was on scene and worked to disconnect the three radiators attached to the main compartment.  The radiators were disconnected, drained and removed with a crane.  Sorbents were placed in the radiator inlets and the outlets to the main compartment were blank flanged.  Rain fell continuously throughout the morning and water from the secondary containment area was pumped into drums for disposal.  GPA wanted to rinse the main compartment, so a drum of new oil provided by GPA was used to rinse down the inside of the main compartment.  No oil came out of the main compartment after it was rinsed.  The secondary containment area was emptied of oil, sludge was removed from the secondary containment sumps and scrub sorbent was used to clean the secondary containment area.   In the afternoon, operations transitioned to Talofofo, where the LTC and main compartments were drained again after sitting empty for 24 hours.  Residual quantities of oil were drained from the main LTC compartments.  The crane provided by GPA was hooked up to the two radiators and they were disconnected, drained and removed.  The outlet and inlet valves were blank flanged.  A drum of new oil, provided by GPA, was used to rinse the inside of the main compartment, but no oil settled to the bottom.  The secondary containment area was cleaned, sumps emptied of sludge and contaminated water and the area was scrubbed. 

6/2/2012 – EPA: 1, START: 1, ERRS: 1, GRESCO: 5, GPA: 4;  The crew started at Talofofo and opened the main container which had been sitting for 24 hours but no oil came out.  Secondary containment was swept out again.  A small crew went back to Apra Heights to check on the compartments, but no additional oil had settled out.  Small crew mobilized to Dededo and emptied the two small transformers, approximately 60 gallons into a drum for transfer to the isotainer.  At Talofofo, the driver showed up to pick up the isotainer and was concerned about the tires, so a repair shop was called for repair.  The EPA Region 9 TSCA program coordinated and consulted with the OSC.  GRESCO filed a notification of TSCA transporter to EPA HQ to move the drums from the Talofofo and Apra Heights facilities to Dededo where the container would be packed and stored until transport off island.  The isotainer and flatbed with the drums were transported to Dededo.  The oil from the small transformers at Dededo was transferred into the isotainer.  Then the isotainer was sampled by START.  The shipping container was packed with the TSCA regulated drums and blocked and braced for shipping.  The containers were placarded and staged for shipment.  The manifests were prepared.  GPA continued to provide support and coordination as activities winded down and provided a safe storage location for the containers awaiting off island transport.