United States
                     Environmental Protection
                     Agency
                  Solid Waste and
                  Emergency Response
                  (5502G)
EPA520-F-94-015
      Fall 1994
                     Superfund At  Work
                     Hazardous Waste Cleanup Efforts Nationwide
     Northwest Transformer
     Mission/Pole Site Profile
      Site Description:
      Former electrical transformer
      salvage yard
      Site Size: 1.2 acres
      Primary Contaminants:
      Polychlorinated biphenyls (PCBs)
      Potential Range of Health Risks:
      Chloracne, topical irritations,
      central nervous system disorders,
      and increased risk of cancer
      Nearby Population:
      200 people within a one-mile radius
      Ecological Concerns:
      Local agriculture and wildlife
      Year Listed on the NPL: 1986
      EPA Region: 10
      State: Washington
      Congressional District: 2
U.S. Environmental Protection Agen
?|S.jon 5, Library (PL-12J)
// West Jackson Boulevard, 12th
Chicago, JL 60604-3'
     Hundreds of leaking transformers surrounded the wooden salvage barn.
Success in Brief

Electrical Transformers Removed

From Farming Community

  A high degree of cooperation among federal, state, and private
parries characterized the cleanup of the Northwest Transformer
Mission/Pole (NWTMP) site in Whatcom County, Washington.
Almost 30 years in the making, this old salvage yard had been
thoroughly contaminated with polychlorinated biphenyls (PCBs).
Hundreds of electrical transformers and capacitors littered the site,
some with dangerously high PCB concentrations. Adhering to the
stricter standards of the state, the U.S. Environmental Protection
Agency (EPA) developed a Superfund cleanup strategy that included:
  • An emergency removal of PCB-contaminated soil, liquids
    and transformers;
  • An amended soil cleanup plan that met requirements of the
    state's Model Toxics Control Act;
  • Negotiated settlements with site operators, utility companies, and
    small-volume generators to conduct a $3.7 million cleanup; and
  • Cost recovery of 90% of past cleanup and future monitoring costs.
                              Joint efforts succeeded in restor-
                              ing soil and protecting drinking
                              water for future generations.  This
                              site will be available for future
                              redevelopment without restric-
                              tions once ground water monitor-
                              ing is completed.
                              The Site Today

                                All the transformers and
                              hazardous liquids are gone.
                              Disturbed portions of the site
                              have been backfilled and covered
                              with six inches of topsoil and
                              grass. Ground water monitoring
                              will continue through the spring
                              of 1995 to ensure that off-site and
                              perimeter wells remain uncon-
                              taminated.

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                   Superfund At Work  •  Northwest Transformer Site, Everson, WA
                                           Summer 1994
  This 1.2 acre site is at the
intersection of Mission and Pole
Roads, two miles southwest of
Everson, Washington.  One of
two properties operated by the
Northwest Transformer Service
Company, the NWTMP site
served as a former salvage and
storage area for electrical trans-
formers. The site is less than 10
miles from the Canadian border
and adjoins prime agricultural
land, dairies, and commercial
and family farms to the south.
The rest of the area is residential
with approximately 200 people
living within one mile of the
site.  Ground water is used for
agricultural irrigation and is a
source of residential drinking
water. Some 27 private wells
           A Site  Snapshot

          are located within a half mile of
          the site.
             The NWT Service Company
          operated from 1958 to 1985 at a
          one-acre site in downtown
          Everson (South Harkness Street).
          The company repaired, stored, and
          rebuilt electrical transformers and
          capacitors containing polychlori-
          nated biphenyls (PCBs). The
          Mission/Pole Road salvage yard
          was leased for disassembling the
          transformers and capacitors,
          draining fluids, and reusing parts.
          When the plant downtown closed
          in 1987, the company employed a
          dozen people and was receiving
          transformers from more than 80
          different utility companies.
             When first investigating the
          salvage yard, EPA discovered
                                             Northwest
                                             Transformer Site
                                             Everson, WA
                                about 500 transformers aban-
                                doned in an open field. Waste
                                oil and PCBs were found in a
                                seepage pit and a wooden barn;
                                much of the soil was thoroughly
                                saturated.  With both agricul-
                                tural and residential properties
                                nearby, the potential for expo-
                                sure to contaminants was high.
                                PCBs can be highly toxic and are
                                associated with a wide range of
                                topical irritations, central ner-
                                vous system disorders, and a
                                variety of cancers.
    Northwest Transformer
    Mission/Pole
    Timeline
                                   • NWT owner-operators fail to cooperate
                                   • EPA conducts emergency removal

                           • EPA proposes salvage yard site to NPL
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                     Superfund At Work  •  Northwest Transformer Site, Everson, WA  •   Summer 1994
 Cooperative Efforts Transform Hazardous Waste Site
Public Awareness Triggers
Response
   Starting in the early 1960s,
workers at the salvage yard
drained contaminated fluids from
spent transformers into a wood-
frame, gravel-filled seepage pit
about six to eight feet deep.
Workers also used some PCB oils
to heat a wooden barn that served
as a work area, salvaging scrap
copper and steel for sale to local
firms. Some PCB wastes and
casings from transformers were
burned in an open concrete pit
called an air curtain incinerator.
The incinerator only operated
about twice a year, reaching
temperatures up to 1,200° F.
   During the 1970s, Everson
residents complained to state and
local officials about the unre-
                       stricted site, noting that children
                       may have come into direct con-
                       tact with tainted soil. State offi-
                       cials were unaware of any health
                       effects related to the bi-annual
                       incinerations.

                        Hundreds of transformers
                              littered the site


                          In 1976, Congress enacted the
                       Toxic Substances Control Act
                       (TSCA) which outlawed PCB
                       production and distibution.
                       Beginning in 1977, new EPA
                       regulations required the Wash-
                       ington State Department of
                       Ecology and Whatcom County
                       officials to regularly inspect the
                       NWTMP site.
                          Finding the site "in a condition
                                 of disarray", EPA fined NWT's
                                 owners and operators under
                                 TSCA for improper storage and
                                 disposal of PCBs and for inad-
                                 equate record keeping, marking,
                                 and dating. Six months earlier in
                                 December 1980, Congress had
                                 enacted the Comprehensive
                                 Environmental Response, Com-
                                 pensation, and Liability Act
                                 (CERCLA). This law established
                                 the "Superfund" program to
                                 clean up the multitude of prob-
                                 lems associated with improper
                                 hazardous waste disposal.

                                 Dangerously High PCB
                                 Levels Revealed
                                    At this time, ground water
                                 samples from nearby domestic
                                 wells indicated no elevated levels
                                 of PCBs in local drinking water.
     1 Site placed on NPL
           m • EPA and USAGE begin detailed studies

                  ^ * Site investigation completed

                           • EPA issues cleanup plan
                r
                                   • Several parties perform treatability study
                                   1 State enacts Model Toxics Control Act
                                           1 EPA issues revised cleanup plan
                                           1 Landowners agree to pay past costs
                                           • 85 parties agree to conduct cleanup
                                                    EPA approves cleanup design
                                                            • Excavation,
                                                             incineration begins
                                                                  ^•Construction  [/*Ground
                                                                    completed    i   wa*er
                                                                                  monitoring
 1986
1987   1988    1989
1990
1991
1992
1993    1994
Ongoing

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                     Superfund At Work  •  Northwest Transformer Site, Everson, WA
                                 Summer 1994
But 200 parts per million (ppm)
were recorded in on-site soil, 20
times higher than federal safety
standards. EPA proposed the site
to the National Priorities List, the
agency's roster of serious hazard-
ous waste sites requiring cleanup
under the Superfund program.
In March 1985, EPA again
sampled soil and liquids at the
site and recorded PCB levels as
high as 38,000 ppm. This severe
contamination prompted EPA to
order the company to restrict
access to the site, start cleaning up
the soil, and take samples.

EPA Stabilizes Site
  When NWT Service Company
failed to comply with the cleanup
order, EPA enclosed the salvage
yard with an eight-foot cyclone
fence. All the transformers were
centralized and rinsed of their
PCB fluids and about 6,000 gal-
lons of tainted liquids were
incinerated or recycled.  A techni-
cal assistance team excavated and
disposed of 1,400 cubic yards of
contaminated soil and debris at
approved facilities. Workers also
installed five ground water
monitoring wells and tested 21
residential wells; no private well
had elevated PCB levels.

EPA Selects Comprehensive
Cleanup Plan
  While the 1985 emergency
action reduced some dangers, the
site required a comprehensive
remediation. In 1986, EPA placed
the site on the NPL, and together
with the U.S. Army Corps of
Engineers, conducted in-depth
studies between 1987 and 1988.
  These studies found certain
areas to be contaminated with
PCBs at markedly elevated levels.
In addition, the wooden barn was
a source of residual contamina-
tion and low levels of PCBs in
ground water warranted contin-
ued monitoring.
  EPA's final cleanup plan,
announced in 1989, featured an
innovative technology known as
in situ vitrification (ISV). ISV is a
thermochemical treatment pro-
cess that electrically melts the
contaminants in soil. Upon
cooling, a stable, glass-like solid
remains. EPA's recommendation
was to cap the treated soil with a
two-foot soil cover and to con-
tinue studies of area ground
water and the barn to determine if
additional cleanup actions were
necessary. The State of Washing-
ton concurred with the plan to
use ISV for the soil cleanup.

Cleanup Plan Adjusted to
Reflect New Findings
  After issuing the cleanup plan,
EPA negotiated with some utility
companies that did business with
NWT Service Company to per-
form pre-cleanup treatability
studies. These studies included
testing the effectiveness of the ISV
technology, continuing ground
water monitoring, and evaluating
the extent of the old wooden
barn's contamination.
  The utilities' ISV study con-
cluded that, while ISV would
treat the soil satisfactorily, the
technology was not economical
and could cost as much as five
times the original estimate. EPA
was persuaded to amend the
plan, taking into consideration the
State of Washington's new haz-
ardous waste cleanup law, the
Model Toxics Control Act. Provi-
sions of that law allow the state to
impose a more stringent cleanup
standard for PCBs than does
federal law. Incineration would
quickly and effectively destroy all
contaminants to satisfy state
standards but wouldn't finan-
cially jeopardize any of the waste
contributors.
  Fair, flexible settlements
       achieve results


  The amended cleanup plan
required off-site removal and
incineration of site soil having
PCB concentrations of 50 ppm or
more and removal of 1,500 cubic
yards of less contaminated soil
and barn materials to an ap-
proved hazardous waste landfill.

Flexibility Results in Negotiated
Settlements
  Viewed as a partner instead of
an adversary, EPA was able to
secure two major cost settlements,
the first in August 1991 with
seven owners and operators who
agreed to pay $460,000 in past
cleanup costs. In November 1991,
85 utility companies — 70 of them


                continued on page 6

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                    Superfund At Work  •  Northwest Transformer Site, Everson, WA  •  Summer 1994
                         The Trouble With PCBs
   From the 1930s until 1977,
polychlorinated biphenyls
(PCBs) were widely used as
coolants in electrical equip-
ment, in brake and hydraulic
fluids, and in the manufacture
of plastics, adhesives, paints,
and other industrial products.
   Because of their universal
acceptance, PCBs were not
recognized as potentially
dangerous until the late 1960s.
Scientific studies have shown
that PCBs are unusually persis-
tent in the environment, and
background levels have been
measured in outdoor air, on
soil surfaces, and in water.
Nearly everyone has some
internal level of PCBs, includ-
ing infants who drink breast
milk from exposed mothers.
   PCBs bioaccumulate in fatty
tissue and are suspected car-
cinogens. For these reasons,
the Toxic Substances Control
Act of 1976 (TSCA) banned the
manufacture, distribution, and
use of PCBs.
   Over the years, research on
PCBs has reached some differ-
ent conclusions. An industry-
financed assessment concluded
that the carcinogenicity of
PCBs was related to the
amount of chlorine used in the
synthesis process, therefore
EPA should adopt standards
for PCBs based on chlorination.
   On the other hand, studies at
the State University of New
York and Wayne State Univer-
sity link PCBs — even those
that are lightly chlorinated —
to neurological damage and
loss of motor control, particu-
larly in children, causing
learning disabilities similar to
those associated with lead
poisoning. Other research at
the University of Michigan
found malignant breast tumors
in women with higher traces of
PCBs than benign tumors.
Further studies of marine
mammals (dolphins, seals, and
whales) implicate PCBs as a
cause of low birth rate and
even death.
  Because so many studies
associate PCBs with toxicity,
the EPA cleanup standard is
10 parts per million (ppm).
One ppm is comparable to
one drop of gasoline in the
tank of a full-size car. At the
Northwest Transformer site,
the state standard of one
ppm was applied to the
cleanup of PCBs in soil.
   Octachlorobiphenyl
    Two hexagon-shaped molecules of carbon linked together constitute
  the basic biphenyl. As many as 10 chlorine atoms can be attached to
  the biphenyl structure, hence the name, poly (many) chlorinated
  bi (two) phenyl. Shown here is Octachlorobiphenyl with eight chlorine
  atoms; there are more than 400 known compounds.
    Each additional attachment of the basic biphenyl and its associated
  chlorines increases the molecular weight, providing greater stability.  But
  greater stability translates into persistence in the environment and
  increased toxicity. Even with a manufacturing and distribution ban in
  effect since 1976, PCBs have bioaccumulated in species all the way up
  the food chain to man.
                                                     U.S. Environmental Protection Agency
                                                     Region 5, library (PL-12J)	
                                                     77 West Jacksqn_Boujevard,  12th Floor
                                                     uniCiigu,  IL  60604-3590

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                     Superfund At Work •  Northwest Transformer Site, Everson, WA
                                Summer 1994
  Cooperative
  Efforts
continued from page 4

de minimis (minor) generators —
agreed to pay for the revised
cleanup, valued at approximately
$4 million. This same group
agreed to reimburse $1.2 million
of EPA's past costs.
  Between February 1990 and
November 1991, EPA and other
parties signed three additional
agreements for a treatability
study and ground water
monitoring, each valued at
$500,000. Altogether, EPA recov-
ered more than 90% of past  costs
and all cleanup and future moni-
toring costs associated with  the
site, a sum totalling approxi-
mately $3.7 million. Excavation
and incineration began in the
                      Success at
          Northwest Transformer
    EPA's emergency removal
  stabilized the NWTMP site
  and reduced the greatest
  environmental risks. When
  treatability studies showed the
  selected remedy to be expen-
  sive, EPA amended the origi-
  nal cleanup plan to reflect the
  new evidence. In the process,
  EPA worked closely with the
  State of Washington to require
  a stricter cleanup level for
  PCBs than current federal
  standards.
spring of 1993 and took one year
to complete. The site now meets
state and federal standards for
unrestricted use.
  Nearly 100 responsible
parties performed a long-term
remediation and reimbursed
EPA for past costs. Balancing
different scientific and partisan
perspectives resulted in a job
well done that was acceptable
to waste contributors and the
residents of the local commu-
nity. Although construction
was completed in the spring of
1994, EPA will oversee moni-
toring of ground water at the
site for at least a year.
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