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EPA Region 5 Records Ctr. 241676 REPORT ON INSPECTION TO DETERMINE COMPLIANCE WITH THE PCB DISPOSAL AND MARKING REGULATIONS SUMMIT EQUIPMENT & SUPPLIES 875 IVOR AVENUE AKRON, OHIO 44314 JULY 31, 1986 PERFORMED BY: OHIO ENVIRONMENTAL PROTECTION AGENCY OFFICE OF EMERGENCY RESPONSE P.O. BOX 1049, 361 E. BROAD STREET COLUMBUS, OHIO 43266-1049 AS AUTHORIZED UNDER THE U.S. EPA PILOT TSCA COOPERATIVE ENFORCEMENT AGREEMENT PROGRAM

REDACTED OH EPA - REPORT ON INSPECTION TO ...P.O. BOX 1049, 361 E. BROAD STREET COLUMBUS, OHIO 43266-1049 AS AUTHORIZED UNDER THE U.S. EPA PILOT TSCA COOPERATIVE ENFORCEMENT AGREEMENT

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Page 1: REDACTED OH EPA - REPORT ON INSPECTION TO ...P.O. BOX 1049, 361 E. BROAD STREET COLUMBUS, OHIO 43266-1049 AS AUTHORIZED UNDER THE U.S. EPA PILOT TSCA COOPERATIVE ENFORCEMENT AGREEMENT

EPA Region 5 Records Ctr.

241676

REPORT ON INSPECTION TO DETERMINE

COMPLIANCE WITH THE PCB DISPOSAL

AND MARKING REGULATIONS

SUMMIT EQUIPMENT & SUPPLIES875 IVOR AVENUE

AKRON, OHIO 44314

JULY 31, 1986

PERFORMED BY:

OHIO ENVIRONMENTAL PROTECTION AGENCYOFFICE OF EMERGENCY RESPONSE

P.O. BOX 1049, 361 E. BROAD STREETCOLUMBUS, OHIO 43266-1049

AS AUTHORIZED UNDER THEU.S. EPA PILOT TSCA COOPERATIVEENFORCEMENT AGREEMENT PROGRAM

Page 2: REDACTED OH EPA - REPORT ON INSPECTION TO ...P.O. BOX 1049, 361 E. BROAD STREET COLUMBUS, OHIO 43266-1049 AS AUTHORIZED UNDER THE U.S. EPA PILOT TSCA COOPERATIVE ENFORCEMENT AGREEMENT

PCB C O M P L I A N C E I N S P E C T I O N REPORT«

I . C O M P A N Y I D E N T I F I C A T I O N

Summit Equipment & Supplies875 Ivor A v e n u eA k r o n , O h i o 44314

(216) 753-6678

g^sponsible O f f i c i a l

v' r. Benny Hursh, Owner

II . DiTE OF INSPECTION

July 31, 1986

III . PARTICIPANTS

C O M P A N Y

Mr. Charles H. Thoman, Foreman

O h i o EPA

Mr. Ken M. Harsh, Asst. Chief, Emergency Response(Author)

IV. OBJECTIVES

The inspection was conducted to document the facility'sh a n d l i n g , storage and disposal practices and to determineits compliance with the PCB Regulations, 40 CFR Part 7fil,as published in the Federal Register of May 31, 1979 andas amended.

V. COMPANY BACKGROUND

Production - Scrap, iron and metal reprocessingSIC Number - 3399Year Established - UnknownPlant Size - Approximately 6 acresB a s i s for Selection - The Akron P o l i c e Department reported

that transformers had been observed during a visit tothe faci l i t y . It was a l l e g e d that the transformerswere being poorly handled.

Page 3: REDACTED OH EPA - REPORT ON INSPECTION TO ...P.O. BOX 1049, 361 E. BROAD STREET COLUMBUS, OHIO 43266-1049 AS AUTHORIZED UNDER THE U.S. EPA PILOT TSCA COOPERATIVE ENFORCEMENT AGREEMENT

VI . INSP E C T I O N S U M M A R Y

A. Opening Conference

C r e d e n t i a l s were presented to f a c i l i t y r e presentatives. ATSCA Notice of I n s p e c t i o n and TSCA Inspection C o n f i d e n t i -a l i t y Notice were issued to Mr. C h a r l e s Thoman, Foreman.It was e x p l a i n e d that the inspection was in response to ac o m p l a i n t from the Akron Police Department.

3. E l e c t r i c a l Equipment

5 Hi-it e q u i p m e n t & S u p p l i e s (SES) has no in service PCBe Tu ipment.

C . H y d r a u l i c Systems

All in s e r v i c e h y d r a u l i c systems contain PCB free oil

D. Heat Transfer Systems

There are no heat transfer systems on site.

E. Storage/Pi sposal

Mr. Thoman stated that from 1950-1981 SES receivedtransformers and electrical equipment from Ohio andP e n n s y l v a n i a . He stated that they had been received fromu t i l i t i e s , and p r i v a t e corporations and the U.S.Government. There were ten transformers on the northwestside of the facility. All ten were empty, but there wereoil stains on the soil around them. A composite debrissample of the area had 7,500 parts per m i l l i o n (ppm) PCBs.

There were 20-30 large transformers east of that area, withl a r g e oily stains over an area larger than 20 feet by 20feet. A composite of that area had 180 ppm PCBs.

Am area in the m i d d l e part of the facility near the southside had a large number of plates from old transformers. Acomposite of that area had 220 ppm PCB.

Another area over 40 feet by 40 feet had a large stack ofh u n d r e d s of transformer carcasses. There were l a r g en u m b e r of p l a t e s from t r a n s f o r m e r s on the g r o u n d and alarge oily stained area that had 2,900 ppm PCBs. There mayh a v e been approximately one to two thousand transformercarcasses. Most of the transformers were in the westernpart of the f a c i 1 i ty.

Page 4: REDACTED OH EPA - REPORT ON INSPECTION TO ...P.O. BOX 1049, 361 E. BROAD STREET COLUMBUS, OHIO 43266-1049 AS AUTHORIZED UNDER THE U.S. EPA PILOT TSCA COOPERATIVE ENFORCEMENT AGREEMENT

(3)

On the southeast side of the scrap yard, there were lessthan 20 nameplated PCB c a p a c i t o r s . A sample of s o i l aroundthese had 74,000 ppm PCBs. The author could see a l a r g en u m b e r of transformer carcasses on the east s i d e of thef a c i l i t y but could not g a i n access to that area because ofthe p i l e s of scrap.

F. S p i l l s

T n e r e were s p i l l s o f PCBs from t r a n s f o r m e r s , and othere l e c t r i c a l equipment over a large area of the f a c i l i t y .T he s p i l l s were too numerous to d e t a i l without an e x t e n s i v ei n v e s t i g a t i o n .

G. Oi 1 s

Mr. Thoman i n d i c a t e d that oil d r a i n e d from transformers hadbeen sold and used for "road o i l i n g " .

H . C1osi ng Conference

A r e c e i p t for s a m p l e s and d o c u m e n t s were issued to Mr.Thoman. He was told that it appeared that SES had a majorPCB c o n t a m i n a t i o n p r o b l e m . A letter was sent to thef a c i l i t y (Appendix D) i n d i c a t i n g the facility had majorproblems .

VII. PHOTOGRAPHS

Photographs of the f a c i l i t y were taken and are i n c l u d e d inAppend!x B.

V I I I . SAMPLES

Five composite soil samples were taken. Results are asfol1ows :

Sample Number D e s c r i p t i o n PCBs- (ppm)

1 SS Northwest area 7,500

2 SS Area by large transformers 180

3 SS Area south m i d d l e 220

4 SS Area northside, mid yard 2,900

5 SS Area southeast side by 74,000old capaci tors

Page 5: REDACTED OH EPA - REPORT ON INSPECTION TO ...P.O. BOX 1049, 361 E. BROAD STREET COLUMBUS, OHIO 43266-1049 AS AUTHORIZED UNDER THE U.S. EPA PILOT TSCA COOPERATIVE ENFORCEMENT AGREEMENT

APPENDIX

A. TSCA Notice of InspectionTSCA Receipt for Samples and Documents

B. Photographs

C. Chain of CustodySample Results

D. Other Supporting Documentation

Page 6: REDACTED OH EPA - REPORT ON INSPECTION TO ...P.O. BOX 1049, 361 E. BROAD STREET COLUMBUS, OHIO 43266-1049 AS AUTHORIZED UNDER THE U.S. EPA PILOT TSCA COOPERATIVE ENFORCEMENT AGREEMENT

APPENDIX A

Page 7: REDACTED OH EPA - REPORT ON INSPECTION TO ...P.O. BOX 1049, 361 E. BROAD STREET COLUMBUS, OHIO 43266-1049 AS AUTHORIZED UNDER THE U.S. EPA PILOT TSCA COOPERATIVE ENFORCEMENT AGREEMENT

/4^ V'V^hJl WASHINGTON, DC 20460

PiSKtf fr""2i^aBiL TOXIC SUBSTANCES CONTROL ACT

OjX&Ml * m NOTICE OF INSPECTIONV INVESTIGATION IDENTIFICATION

DATE INSPECTOR NO. DAILY Sg

INSPECTOR ADD7TESS

0 ' ^i~0 FP/} C/l P--O-

Under the authority of Sectic 1

.P3l? For the purpose of inspecting (inment, fsc:!T/, or other premisesessed or rtorad, or held before orfacilities) ar.cl any conveyance bewith their distribution in commeirequirements of the Act applicabconveyance nave been complied ̂

O In addition, this inspection exten

Q A. Financial data

D B. Sales data

DC. Pricing data

The nature and extent of inspect

INSPECTOR SIGNATURE

\—£.A/V^ <3"j s

2. TIME 3. FIRM NAME

Q' NO- / [- l-~-

5. FIRM ADDRESS / '

REASON FOR INSPECTION

1 of the Toxic Substances Control Act :

eluding taking samples, photographs, statements, and other inspectorn which chemical substances or mixtures or articles containing sameafter their distribution in commerce (including records, files, papers,ng used to transport chemical substances, mixtures, or articles contace (including records, files, papers, processes, controls, and facilitiese to the chemical substances, mixtures, or articles within or associatevith.

ds to (Check appropriate blocks):

D D. Personnel data

CI E. Research data

on of such data specified in A through E above is as follows;

RECIPIENT SIGNATURE /-"/"I

NAME ~ ITAWE ^- " — ' / ' ^ ~ / l>

TITLE

EPA Form 7740-3 (12-M

DATE SIGNED TITLE

form ApproiedOMB \o. 2070-0007Approval expirei .9 31 35

^/•/H \>-'f~ft

i activities) an establish-are manufactured, proc-processes, controls, andning same in connectionbearing on whether thed with such premises or

^̂ 1^1 ^

DATE SIGNED

NSPECTI0N FILE

Page 8: REDACTED OH EPA - REPORT ON INSPECTION TO ...P.O. BOX 1049, 361 E. BROAD STREET COLUMBUS, OHIO 43266-1049 AS AUTHORIZED UNDER THE U.S. EPA PILOT TSCA COOPERATIVE ENFORCEMENT AGREEMENT

iXt

WASHINGTON, DC 20460

TOXIC SUBSTANCES CONTROL ACT

RECEIPT FOR SAMPLES AND DOCUMENTS

Form ApprovedOMB ,V0. 2070-0007

1. INVESTIGATION IDENTIFICATION

DATE

7l3//fl"SPICrOR ADDRESS

INSPECTOR NO. DAILY SEQ. NO.

el

2. FIRM NAME

4. FIRM ADDRESS

The documents ard samples of chemical substances and/or mixtures described below were collected in connection with theadministration ard enforcement of the Toxic Substances Control Act.

RECEIPT OF THE DOCUMENT(S) AND/OR SAMPLE(S) DESCRIBED IS HEREBY ACKNOWLEDGED:

NO. DESCRIPTION

/"

2*'

OPTIONAL:

DUPLICATE OR SPLIT SAMPLES: REQUESTED AND PROVIDED D NOT

Page 9: REDACTED OH EPA - REPORT ON INSPECTION TO ...P.O. BOX 1049, 361 E. BROAD STREET COLUMBUS, OHIO 43266-1049 AS AUTHORIZED UNDER THE U.S. EPA PILOT TSCA COOPERATIVE ENFORCEMENT AGREEMENT

APPENDIX B

Page 10: REDACTED OH EPA - REPORT ON INSPECTION TO ...P.O. BOX 1049, 361 E. BROAD STREET COLUMBUS, OHIO 43266-1049 AS AUTHORIZED UNDER THE U.S. EPA PILOT TSCA COOPERATIVE ENFORCEMENT AGREEMENT

Pictures could not be located, they are believedDisplaced , or lost, the pictures will be retaken after anothervisit is made to the facility, to take further samples to betterdefine levels of PCB contamination that exist at the facility

Page 11: REDACTED OH EPA - REPORT ON INSPECTION TO ...P.O. BOX 1049, 361 E. BROAD STREET COLUMBUS, OHIO 43266-1049 AS AUTHORIZED UNDER THE U.S. EPA PILOT TSCA COOPERATIVE ENFORCEMENT AGREEMENT

APPENDIX C

Page 12: REDACTED OH EPA - REPORT ON INSPECTION TO ...P.O. BOX 1049, 361 E. BROAD STREET COLUMBUS, OHIO 43266-1049 AS AUTHORIZED UNDER THE U.S. EPA PILOT TSCA COOPERATIVE ENFORCEMENT AGREEMENT

P. 0. Be 208CANTON, OH 44701(216) 454-8304

CHAIN-OF- USTODY RECORD

t o

NAMt Of CLIENT I'HO.Il CI Tf.l rniONl NU

jNIIMllEU SAMPI.F NUMDCII Of CONIAINI.I1S

6Utrr/>

If'

<» P

niANiji in NUMIII.H A ( "i I'I ? .1 * ', I

"'uiposc ol nn.Tlysu (use bjck ol Iroril sheet il

THAN:,' I HNltMllf II

111. M

N l ) M l > C H

ui*N;;rf us

Page 13: REDACTED OH EPA - REPORT ON INSPECTION TO ...P.O. BOX 1049, 361 E. BROAD STREET COLUMBUS, OHIO 43266-1049 AS AUTHORIZED UNDER THE U.S. EPA PILOT TSCA COOPERATIVE ENFORCEMENT AGREEMENT

WADSWORTH;' ALERTLABORATORIES, INC.

COMPANY : .:.SAMPLE ID :LABORATORYSAMPLE M̂ TR

::o EPA-DIV o? r". £5, AP-EA A NX

U : 3S25-1£630

PCB ANALYTICAL REPORT

RGENCY RESPONSE RECEIVING DATE : 8/ 1/cSEXTRACTION DATE : S/ 5/8'JANALYSIS DATE : 8/ G/S6

SITE : SL:-?::T E '̂I?:-:E

PC3-1015PCB-1221PCB-1232PCB-1242PCB-1243PC3-1254PCB-1260

RESL1.T (mg/kg )

NT)NDNDNT)NDND

7,500

DETECTION LIMIT

3,5003,5003,5003,5003,5003,5003,500

NT) - NONE DETECTED

Page 14: REDACTED OH EPA - REPORT ON INSPECTION TO ...P.O. BOX 1049, 361 E. BROAD STREET COLUMBUS, OHIO 43266-1049 AS AUTHORIZED UNDER THE U.S. EPA PILOT TSCA COOPERATIVE ENFORCEMENT AGREEMENT

WADSWORTH; ALERTLABORATORIES. INC.

PCB ANALYTICAL RELXTRT

COMPANY ; c:-::o EPA-DIV OF E>-ERGENCY RESPONSESAMPLE ID : 2-5, A?. FA 3 DIG TRANSFORM-SILABORATORY ID : 3926-18531SAMPLE MATRIX : SOIL

RECEIVTNG DATE : P./ 1/cGEXTRACTION! DATE : c/ 5/cGANALYSIS DATE : 8/11/86

SITE .- su:-:-::7 EGUI?>S.\T .

PCB-1016PCB-1221PCB-1232PCB-1242PCB-1248PC'S-1254PCB-1260

RESULT (ng/kg )

NDNDNT)NT)NTJND180

DETECTION LIMIT

100100ICO100100ICO100

ND - NONE DETECTED

Page 15: REDACTED OH EPA - REPORT ON INSPECTION TO ...P.O. BOX 1049, 361 E. BROAD STREET COLUMBUS, OHIO 43266-1049 AS AUTHORIZED UNDER THE U.S. EPA PILOT TSCA COOPERATIVE ENFORCEMENT AGREEMENT

WADSWORTH 'ALERTLABORATORIES. INC.

PCS ANALYTICAL REPORT

COMPANY : OHIO EPA-DIV OF EMERGENCY RESPONSESAMPLE ID : ̂ S, AREA CLABORATORY ID : 2326-18632SAMPLE MATRIX : SOIL

RECEIVING DATE :EXTRACTION DATEANALYSIS DATE :

B/ 1/353/ 5/8G

3/

^ i TV-\V*AKRON

(mg/kg )

PCE-1016PCE-1221PCB-1232PCB-1242PCB-1248PCB-1254PCE-1260

NT)NT)NT)NDNT)ND220

DETECTION LIMIT

100100100100100100100

NT) - NONE DETECTED

Page 16: REDACTED OH EPA - REPORT ON INSPECTION TO ...P.O. BOX 1049, 361 E. BROAD STREET COLUMBUS, OHIO 43266-1049 AS AUTHORIZED UNDER THE U.S. EPA PILOT TSCA COOPERATIVE ENFORCEMENT AGREEMENT

WADSWORTH. ALERTLABORATORIES. INC.

COMPANY : c:::o LTA-DIV OF E-:I:HGH:;CY RESF-SAMPLE ED : 4;S, AREA DLABORATORY LD : 2925-1S523S.AMPLE MATRIX : SOIL

RECEIVING DATE :EXTR\CTION DATEANALYSIS DATE :

8/: 8/3/ «,

SITE :

PC3-1232PCS-I242PC3-124SPCE-1254PCE-1250

N'DNT)NDNT)NT)NT)

2,900

DETECTION LIMIT

1,0001,0001,0001,0001,0001,000l .OCO

ND - NONE DETECTED

Page 17: REDACTED OH EPA - REPORT ON INSPECTION TO ...P.O. BOX 1049, 361 E. BROAD STREET COLUMBUS, OHIO 43266-1049 AS AUTHORIZED UNDER THE U.S. EPA PILOT TSCA COOPERATIVE ENFORCEMENT AGREEMENT

WADSWORTH/ ALERTLABORATORIES, INC.

COMPANY : c :-::••:SAMPLE ID : 5:LABORATORY IDSAMPLE MATRIX

PCB ANALYTICAL REPORT

•T!

DATE : 8/ l / £ 6EXTRACTION DATE : 2/ 5/;-lGAt^iALYSIS DATE : 3/11/36

SITE : E^: I?N;ENT -JZRO\'

PCB-1016PCB-1221PCB-1232PCB-1242PCB-1243PC3-1254PCB-1260

RESL1,T (rug/kg )

NT)NT)NT)NT)NT)

74,000NT)

DETECTION LIMIT

25,00025,00025,00025,00025,00025,00025,000

NT) - NONE DETECTED

Page 18: REDACTED OH EPA - REPORT ON INSPECTION TO ...P.O. BOX 1049, 361 E. BROAD STREET COLUMBUS, OHIO 43266-1049 AS AUTHORIZED UNDER THE U.S. EPA PILOT TSCA COOPERATIVE ENFORCEMENT AGREEMENT

APPQOIX D

Page 19: REDACTED OH EPA - REPORT ON INSPECTION TO ...P.O. BOX 1049, 361 E. BROAD STREET COLUMBUS, OHIO 43266-1049 AS AUTHORIZED UNDER THE U.S. EPA PILOT TSCA COOPERATIVE ENFORCEMENT AGREEMENT

State Of Ohio Environmental Protection Agency

PO. Box 1049, 361 East Broad St..Columbus, Ohio 43216-1049' I) 466 -8565

Richard F. Celeste,Governor

O c t o b e r 6 , 1986

Sunmit Equipment Supplies875 IvorAkron, OH 44314

Dear Sir:

On July 31, 1986 an Ohio Environmental Protection Agencyrepresentative conducted a PCS compliance inspection forthe U.S. Environmental Protection Agency under the au-thority of the Toxic Substance Control Act (40 CFR, Part761) at Summit Equipment in Akron. During the inspec-tion five samples were taken. The results are asfollows:

PCBs (partsNUMBER DESCRIPTION per million)

1SS NW area next to transformers 7,500

2SS Area soil by large transformers 180

3SS Area further south middle pile 220

4SS Area midyard, north side neartransformer pile 2,900

5SS Area southeast side by oldcapacitor 74,000

These samples Indicate that your facility has a majorPCB contamination problem. Additional samples shouldbe taken, and I suggest that you may want to have aconsultant assist you with site contamination deter-mination and remediation. There are a large numberof transformer carcases and other debris on your sitewhich will require disposal in accordance with TSCAregulations. There are also PCB capacitors which willrequire proper disposal. Considerable quantities ofPCB contaminated debris will need to be removed fromyour site to an approved disposal facility.

i-

V

Page 20: REDACTED OH EPA - REPORT ON INSPECTION TO ...P.O. BOX 1049, 361 E. BROAD STREET COLUMBUS, OHIO 43266-1049 AS AUTHORIZED UNDER THE U.S. EPA PILOT TSCA COOPERATIVE ENFORCEMENT AGREEMENT

Summit Equipment SuppliesPage TwoOctober 6, 1986

I suggest that we meet in the near future to discuss thisproblem further so that you may begin remedial activities.

I can be reached at (614) 466-6542 if you have any questions

Sincerely,

Ken H. HarshAssistant Chief,Emergency Response

KMH:gc

Page 21: REDACTED OH EPA - REPORT ON INSPECTION TO ...P.O. BOX 1049, 361 E. BROAD STREET COLUMBUS, OHIO 43266-1049 AS AUTHORIZED UNDER THE U.S. EPA PILOT TSCA COOPERATIVE ENFORCEMENT AGREEMENT

1

,,. ........ 1-77-3 $INITIAL POLLUTION INCIDENT REPORT 19^6

Discovered

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. Occurred

Complaint

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(Street Lccat ic- ) _ 2 \,'id Ycu 7&n SpiT.e- To Call The N.R.C.? __ yes

..."•IENTS AND POLL: «-'.•? INFOho (1-800-424-8802, Washington D.C.)

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District Engineer

CO:iR (night: 265-7005)

DSH'.JM

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OOH (5190)

PIC (8503) Al Franks 263-0220: Home

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