UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                      WASHINGTON. D.C. 204«0
                                                        OFFICE OP
                                                    THE INSPECTOR GENERAL
                       APR -8  ''-;B3
 oUBJECT;   Late  Report.  Explanation
           '"< v-*-JL«_^ i_>r "V*N >V^v«^,C
 FROM:   ij^ Kenneth  0. Hockman
           Divisional  Inspector  General  for Audit
           Internal Audit  Division  (A- 109)

 rO;        Bert  Anker
           Chief,  Field Operations  Unit  (A-109)


     ATC3  Report  777 showed our report  on  the  PCB Transformer
 Fire Rule  (Report  880780)  as  being 140  days late.   Our
 explanation for a  portion  of  this  delay is presented below.

     1.  During May 1987,  Team  Leader worked full time on
         congressional request  concerning  Superfund cost
         recovery .

     2.  During July 1987, Team Leader  was on  military leave
         for two weeks.

     3.  During July 1987, program officials in Regions 3 and 6
         attended  a national  conference.   Field visits to these
         regions were  delayed two  weeks.

     4.  Unlixke Region 3,  Region 6 did  not have a universe
         of fire departments  for us to  contact.  Therefore,  we
         had to work with  Federal  Emergency Management Agency
         officials and the six  state fire  marshals.  This proces
         took two  weeks  longer  than expected.

     The above  factors resulted in a total delay of about 2-
 1/2 months.  While we  cannot  explain the total delay calculated
 by ATCS , we wish to point  out that the  report was issued per
our commitment  to  Mr.   Bradley.   Ln addition',  we formally briefed
 not only the AIGA  and  the  Inspector General but also the Acting
 Assistant Administrator  for Pesticides  and Toxic Substances.
 The report is scheduled  to appear  in the next semiannual report
as one of the top  internal and  management  audits.  We completed
 this multi-location audit  with  a team of two auditors.


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                       TABLE OF CONTENTS

                                                             Page

SUMMARY OF FINDINGS 	    1

ACTION REQUIRED	    4

SCOPE AND OBJECTIVES 	    4

BACKGROUND	    5

FINDINGS AND RECOMMENDATIONS 	    7

     1.  MANY SMALL AND VOLUNTEER FIRE
         COMPANIES ARE UNAWARE OF THE
         RULE 	    7

     2.  NEED FOR MORE AGGRESSIVE
         OUTREACH EFFORTS TO COMMERCIAL
         BUILDING OWNERS  	    12

     3.  ACTIONS WHICH WILL INCREASE
         THE EFFECTIVENESS OF
         INSPECTIONS 	    19

EXHIBIT A - RESULTS OF OIG TELEPHONE
            SURVEY OF FIRE DEPARTMENTS
            IN REGION 3 	    23

EXHIBIT B - RESULTS OF OIG TELEPHONE
            SURVEY OF FIRE DEPARTMENTS
            IN REGION 6 	    29

APPENDIX 1 - MARCH 3, 1988, RESPONSE TO  DRAFT AUDIT REPORT
             FROM THE ASSISTANT ADMINISTRATOR FOR PESTICIDES
             AND TOXIC SUBSTANCES  	    35

APPENDIX 2 - ADDITIONAL OIG COMMENTS TO  ASSISTANT ADMINI-
             STRATOR'S RESPONSE DATED MARCH 3, 1988 	    39

APPENDIX 3 - DISTRIBUTION OF AUDIT  REPORT 	'	    40

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          UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                      WASH^NGTC^4. D.C, 20460


                       MAR I T 1S88
                                                          E OF
                                                      INSPECTOR GENERAL
  MEMORANDUM

  SUBJECT:  Audit Report E1E57-11-0024-80780
           Review of the EPA Rule Regulating
           Polychlorinated Biphenyl  (PCB)
           Transformer Fires
 FROM:     Ernest E. Bradley  1 1 l
           Assistant Inspector General  for Audit  (A-109)

 TO:       John A. Moore
           Assistant Administrator  for
             Pesticides and Toxic Substances  (TS-788)


 S-BMMAKY OF FINOI-NGS

 The Office of Pesticides and Toxic Substances  (OPTS)  needs
 to conduct an awareness campaign and make other  management
 improvements to better protect the public and  fire  response
 personnel from the significant dangers posed by  PCB trans-
 former fires.  Our review of the implementation  of  the
 Transformer Fires Rule (Rule) by Headquarters  and Regions 3
 and 6 found that:  (1) 62 of 100 small and volunteer fire
 departments we contacted were unaware  of the Rule's require-
 ments; (2) insufficient attention  had  been devoted  to
 commercial buildings where public  exposure to  a  PCB fire
 would likely be the greatest; and  (3)  the effectiveness  of
 inspections to monitor compliance  with the .Rule  was limited
 by the process used to select facilities and a lack of guid-
 ance.  Unless OPTS takes actions to address  these problems,
 fire personnel and the public could be unnecessarily exposed
 to the toxic by-products of  PCB fires.

 Polychlorinated biphenyls (PCBs) are a family  of highly  toxic
 compounds which people absorb through  food,  skin contact, and
 inhalation.   Beginning in the 1930s, PCBs were primarily used
 for insulation purposes in electrical  equipment.  Research has
 shown that exposure to PCBs  can harm reproductive and develop-
 mental processes and cause skin lesions, brain damage, tumors,
 and gastric disorders.

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Until the early 1980s, the Agency believed the major risk
of exposure to PCBs was due to leaks, spills,  and improper
disposal practices.  However, after a PCB transformer caught
fire in Binghamton, New York in 1981, monitoring identified
the presence of dioxins and furans, fire by-products which
are significantly more toxic than the PCB material itself.
PCB fires subsequently occurred at a number of locations.

Because transformer fires were occurring more frequently than
anticipated and presenting a greater health risk than origi-
nally thought, OPTS issued the Rule in July 1985.  The Rule
was designed to limit exposure during fires and the frequency
of PCB-related fires.  To accomplish this, the Rule required
the:  (1) registration of PCB transformers with fire depart-
ments and commercial building owners by December 1, 1985; and
(2) removal of certain transformers or the installation of
"enhanced electrical protection" for other transformers used
in or near commercial buildings by October 1, 1990.  The Rule
defined a commercial building as any non-industrial structure
readily accessible by the general public.

Regions 3 and 6 have conducted activities to inform some
fire response personnel about the Rule's requirements.  Both
regions concentrated their efforts in the larger urban areas
where public exposure in the event of a fire would likely be
the greatest.  However, small and volunteer fire companies
which can also be called to respond to PCB fires were generally
unaware of the Rule approximately two years after the registra-
tion requirement was to have been complied with.  Our contacts
with a total of 100 small and volunteer fire companies in
Regions 3 and 6 during August and September 1987, disclosed
that 62 companies were not aware of the Rule.  Fire personnel
who are unaware of the dangers posed by PCB fires could be
unnecessarily exposed to extremely toxic chemicals unless
appropriate actions, such as the wearing of protective
clothing, are taken.

AlthoughAQFFS was particularly concerned about fires occurring
during peak-use periods in commercial buildings which could
expose hundreds of people to toxic chemicals, Agency outreach
efforts have been limited.  Neither Headquarters nor Regions 3
and 6 have conducted an awareness effort aimed at  commercial
building owners even though fires in or near these structures
have occurred.  Lack of knowledge about the Rule and the danger:
posed by PCB fires may have already resulted in unnecessary
exposure to toxic chemicals.  According to the Deputy Fire  Chie:
in Shreveport, Louisiana, fire personnel were unnecessarily
exposed when they arrived on the scene of a .fire at a power
plant near the Louisiana State University Medical  Center.   The
Deputy Chief said that the facility had not  informed the fire
department that a PCB transformer was on the premises.   Accord-
ingly,  fire personnel did not take precautions when entering
the structure and are now being monitored for adverse health
effects.
                               2

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 Commercial  buildings  as defined in the Rule are varied and
 numerous, making  it difficult  for the Agency to identify a
 complete  universe.  Outreach efforts have essentially been
 limited to  inspections performed by regional personnel and
 State  inspectors  under cooperative agreements.  However, the
 number of facilities  which have been or plan to be inspected
 is  dwarfed  by  the number of buildings which could be inspected.
 Moreover, for  fiscal  1988, OPTS has directed the regions to
 decrease  the number of inspections so that additional resources
 can be devoted to enforcement  cases.  Given the seriousness of
 PCB fires and  the demands placed on limited Agency resources,
 the Agency  needs  to conduct an awareness campaign aimed specif-
 ically at commercial  buildings owners.

 As  the regulated  community is  made aware, the Agency needs an
 effective program to  monitor compliance.  Compliance inspec-
 tions  can be made more effective by obtain-ing and using
 registration information and developing guidance for regional
 inspectors  to  use.  Because the regions are not always certain
 where  PCB equipment,  including transformers, may be found, they
 have targeted  locations for inspection which had no PCB equip-
 ment.  The  PCB coordinators in Regions 3 and 6 estimated that
 no  PCB equipment  is found at approximately half of the loca-
 tions  visited.  They  told us that other high priority work
 had prevented  them from making a concerted effort to obtain
 transformer location  information available at some fire depart-
 ments  and incorporate this information into their inspection
 strategy.   As  a result, these  regions were not able to use a
 valuable  *-r\ai  to  imcrove their inspection program.
    i   '.1                               \
 OPTS also needs to provide guidance on what "enhanced electri-
 cal protection" entails.  The  PCB coordinators in Regions 3
 and 6  said  that their inspectors have little formal training
 in electrical  systems and need guidance to offer advice to
 the regulated  community and determine during their inspections
 whether electrical enhancements are acceptable.

 To correct  the problems described above, we are recommending
 that the Agency:  (1) conduct  an awareness program for  small
 and volunteer  fire departments and commercial building  owners;
 and  (2) use available information and develop guidance  to
 improve the inspection program.

     OPTS COMMENTS AND PIG EVALUATION

The Assistant  Administrator (AA) for Pesticides and Toxic
 Substances provided formal written comments on our draft
 audit  report in a memorandum dated March 3, 1988.  The  AA
generally agreed with our findings and recommendations  and
 indicated that OPTS will be taking actions to implement our
 report recommendations.  We have summarized the AA's position
after each  finding and included the complete response as
appendix 1.   Appendix 2 provides additional comments on the

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 AA's response.   We  discussed  the  results of our audit with
 senior OPTS  officials  on  February 25,  1988.  The Director,
 Exposure Evaluation Division,  said that an exit conference
 was not necessary because the Office of Inspector General
 agreed with  the  corrective actions planned by OPTS.

 ACTION REQUIRED

 In accordance  with  EPA Directive  2750, the action official
 is retired  to provide this office a written response to the
 audit report within 90 days of the audit report date.  For
 corrective actions  planned but not completed, reference to
 specific milestone  dates  will assist this office in closing
 this report.

 SCOPS-. AMD— QBJECTI-VES-

 The overall  purpose of this audit was  to assess the effective-
 ness of Headquarters and  regional controls for implementing
 portions of  the  Rule.   Specifically, we evaluated Agency actions
 to:   (1)  monitor compliance with  the Rule's registration require
 ment;  and (2) ensure compliance with future milestone dates.

 cfe conducted ou-r work  within  OPTS in EPA Headquarters and the
 Hazardous Waste  Management divisions of Regions 3 and 6.  We
 also visited two locations — Binghamton, New York and Santa Fe,
 New Mexico — which experienced major PCB transformer fires.  For
 our purposes, a  major  fire incident involved:   (1) total cleanup
 costs  in excess  of  $1  million;  (2) the evacuation of several
 hundred people;  and (3) several gallons of PCB material being
 released.  During our  visits,  we  obtained information from
 State,  local, and fire response officials concerning the  extent
 and  cost of  cleanup measures  taken as  well as. health studies
 done on those exposed  to  the  fires.
To accomplish, o**.!.- audit  objectives,  we- also  interviewed
regional and  Headquarters  officials  about  actions taken to:
(1) inform the regulated community and  affected parties of
the Rule's intent and  requirements;  and (2)  monitor compliance
We also reviewed the Toxic Substances Control  Act,  the Rule,.
and regional  and Headquarters  internal  controls,  including
policies and  procedures, relating to our areas of concern.

To assess the effectiveness of EPA outreach  efforts,  we tele-
phonically contacted,  during August  and September 1987, 50 fire
departments each in Regions 3  and 6  to  question them on +**eir
knowledge of  the Rule  and  Agency outreach  activities.   We^ judg-
mentally selected the  fire departments  contacted and avoided
ones included in regional  analyses.  We chose  a sample of depart
ments from each State  in each  region.   The departments contacted
represented a mix of volunteer groups or departments -located in

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 cities other than major population centers.  In each case,
 we attempted to interview the top official' within each depart-
 ment.  If this person was not available, we contacted the next
 highest official available at the time we called.  Because
 Region 6 did not have a universe of fire departments, .we....
 judgmentally selected the departments we contacted.  For this
 reason, we- make no projections to the universe.

 We conducted our field work from February to October 1987.
 The scope of our review generally covered Headquart'?''"' ind
 regional activities during fiscal 1986 and 1987.  We aj?e not
 aware of any prior audit reports addressing our audit objec-
 tives.

 We performed this audit in accordance with the Standards For
 Audit of Governmental Organizations. Programs. Activities, and
 Functions (1981 Revision) issued by the Comptroller Genera-1 of
 the United States.  Significant weaknesses in internal administra-
 tive controls are disclosed in the Findings and Recommendations
 section of this report.  No other issues came to our attention
 which we believed warranted detailed audit work.

 BACKGROUND

 Beginning in the 1930s, PCBs were primarily used for insula-
 tion purposes in electrical equipment.  Thay are a  family of
 highly toxic industrial compounds which people absorb through
 food, skin contact, and inhalation.  PCBs gather in  fatty  -
 tissues and body organs, where they remain even after direct
 exposure ceases.  Research has shown that PCBs can harm  repro-
 ductive and developmental processes and cause skin  lesions,
 brain damage, tumors, and gastric disorders.

 Based on the mounting health evidence, the Congress, through
 section 6(e) of the Toxic Substances Control Act of  1977  (TSCA),
 required EPA to implement a regulatory program  for  PCBs.  At
 the same time, TSCA prohibited the manufacture, processing,
distribution and use of PCBs unless they were used  in a  "totally
enclosed manner" or in a way that did not present unreasonable
risk of injury to health and the environment.

Until recently, the major risk of exposure to PCBs  was believed
to be from:  (1} leaks and spills; and  (2) disposal  of PCBs  and
used PCB equipment.  However, fires in Binghamton,  New York;
Tulsa, Oklahoma; San Francisco, California; Miami,  Florida;
Santa Fe,  New Mexico and other locations have shown that fires
involving PCB transformers may pose an even greater risk for
humans.   For example, monitoring conducted after the Binghamton
fire identified the presence of dioxins and furans.  Dioxins
are acutely toxic and carcinogenic.  Presently,  there are no
approved disposal facilities for dioxins in the United States.
Furans,  whose chemical properties are similar to dioxins,.are

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also assumed to b& extremely toxic.  These fire by-products
are significantly more toxic than the PCB material itself.
The health dangers posed by PCB fires have often resulted in
multi-year, multimillion dollar cleanup efforts before the
buildings can be reopened for use.

Because fires were occurring at a greater rate than EPA
anticipated and releasing byproducts more toxic than the PCB
material itself, the Agency issued the Rule on July 17, 1985.
The Rule, which is designed to limit exposure during fires
and the frequency of PCB-related fires, retires that:

     — PCB transformers be registered with fire departments
        by December 1, 1985;

     — PCB transformers located in or near commercial
        buildings be registered with the building owner by.
        December 1, 1985;

     — network PCB transformers of 480 volts or greater in
        or near commercial buildings be removed from service
        by October 1, 1990;

     — network transformers of less than 480 volts and radial
        transformers of 480 volts or greater used in or near
        commercial buildings should have enhanced electrical
        protection installed by October 1, 1990; and

     — the National Response Center be immediately notified
        in the event of a PCB transformer fire-related incident.

Within OPTS, the Office of Toxic Substances  (OTS) and the
Office of Compliance Monitoring (OCM) are responsible  for
implementing the corrective actions recommended in this report.
OTS is responsible for providing operational guidance on the
Rule to regional offices and for evaluating  the activities  of
EPA's ten regional offices as they implement the rule.  Within
OTS, the Toxic Substances Control Act Assistance Office  is
responsible for disseminating information on regulations address-
ing toxic substances, including the Rule.  OCM establishes
compliance priorities and provides program policy direction
to regional offices.

Regional personnel can also conduct additional awareness  efforts
The regional offices are responsible for monitoring compliance
with the Rule's requirements.

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 FINDINGS AND RECOMMENDATIONS

 1.  MANY SMALL AND VOLUNTEER FIRE COMPANIES
    ARE UNAWARE OF THE RULE

 Despite efforts to inform fire response personnel about the
 Rule, many small and volunteer fire companies were unaware of
 the Rule's intent and requirements approximately two years
 after the Rule became effective.  Of the 100 small and volun-
 teer companies we contacted in Regions 3 and 6, 62 said they
 were not aware of the Rule.  Fire personnel unfamiliar with the
 dangers posed by PCS transformer fires could be unnecessarily.
 exposed to toxic chemicals during fires unless appropriate
 precautions are taken.  OPTS needs to conduct an awareness
 effort directed specifically at small and volunteer departments

 Issued in .July 1985, the Rule required the owners of PCB
 transformers' to register this equipment with the local fire
 department having primary response duties.  Registration of
 all PCB transformers was to be completed by December 1, 1985.
 In registering, the owner was to indicate the:   (l) physical
 location of the transformer; (2) type of dielectric fluid in
 the transformer; and (3) name and phone number of a person
 the fire department should contact in the event of a fire
 involving the equipment.  The registration requirement was
 designed to help prepare fire response personnel for the
 unique conditions (i.e., the release of highly toxic by-
 products such as dioxins and furans) presented by PCB  fires.
 When called to respond to a fire involving a PCB transformer,
 fire departments could take appropriate measures to protect
 fire fighters, select the appropriate means for extinguishing
 the fire, and where possible, de-energize the equipment.

 In issuing the Rule, OPTS concluded that  fire departments were
 too numerous and geographically dispersed to permit a  national
 notification program.  Accordingly, OPTS decided that  regional
 offices would be responsible for notifying fire personnel and
 monitoring implementation of the Rule.  Since OPTS viewed the
 Rule as essentially a regional responsibility, it did  not
provide the regions any guidance on notifying  fire personnel
 and it did not establish a national monitoring program.

 During our field work, we visited Regions 3 and  6 to assess
the effectiveness of their outreach efforts.   Both regions had
undertaken certain activities designed to inform fire  response
personnel about the Rule.  In both regions the efforts were
primarily directed at fire departments in the  larger urban
areas where public exposure in the event  of a  fire would
 likely be the greatest.  The following sections  contain our
analyses of actions taken by Regions 3 and 6.

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    Region  3

 In  1986, the Toxics and Pesticides Branch, Hazardous Waste
 Management  Division, purchased a list of known fire depart-
 ments  in the region from a trade association.  Using this
 list,  the branch contacted approximately 70 departments by
 telephone.  Many of the departments served large cities such
 as  Philadelphia and Baltimore.  The departments were asked:
 (1) if they were aware of the Rule; (2) how they became aware
 of  it; (3)  how many registrations they had received; and (4)
 whether they were using the registrations in their fire pro-
 grams-.  After analyzing the responses received, the branch
 concluded that the small and volunteer departments were
 generally unaware of the Rule and additional measures were
 needed to notify them.

 The branch  then prepared a notice which explained.the Rule's
 intent, the registration requirement, and the dangers involved
 with PCB fires.  From February to June 1987, the branch sent
 the notice  to all 3,800 fire departments located within the
 region.  However, because the Branch was devoting significant
 resources to enforcement cases, it was not able to followup
 to determine whether the notice had been received and its
 contents understood.

 Since  no followup effort had been done, we telephonically
 contacted,  during August and September 1987, 50 small and
 volunteer departments which Ware not included in the branch's
 phone  survey.  Of the 50 departments contacted, 26 told us
 that they were not aware of the Rule.  In addition, of the  24
 departments who indicated they were aware of the Rule, only
 11 recalled having seen the notice.  Those who knew of the
 Rule had gained their knowledge by reading various documents,
 word of mouth, and miscellaneous other sources.  Exhibit A
 provides the results of our phone survey  for Region 3.  During
 our field work, we provided branch officials with the results
 of our survey.  The PCB coordinator told us  that they would
 use the results to improve their program.

     Region 6

 In September 1985, Region 6 officials conducted six seminars
 for State and local government personnel,  fire officials  and
 private industry.  The seminars discussed  PCB regulations,
 including the recently published Rule.  Beginning  in February
 1986,  the Pesticides and Toxics Branch; Air, Pesticides and
Toxics Division, began to address the Rule directly.  The
 branch sent a package on the Rule to State  fire marshals  and
 fire training schools, 67 fire departments and 25 utilities.
The fire departments chosen were those from  the larger cities
 in each State.  The package included a copy  of the  Rule and
 its summary.  The package also asked the  addressee  to provide
                               8

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 the branch with registration information including the number
 of registrations received, who the owners were, and how the
 fire departments were using the registration information.

 Also, beginning in February 1986, the region began a proce-
 dure designed to increase the coverage of its outreach efforts.
 Inspectors conducting asbestos inspections would also visit
 local fire response personnel to discuss the Rule and safety
 issues  involving PCS fires.  Approximately one week prior to
 a visit, a regional inspector contacts the fire department to
 briefly discuss the Rule and inform fire officials that infor^
 mation  on the Rule is being sent to them.  We inguired about
 the degree of awareness existing at the time Region 6 made
 its initial contacts,  while awareness statistics were never
 formally recorded, the branch estimated that of the 51 depart-
 ments visited through July 27, 1986, 75 percent were unaware
 when initially contacted.

 As we had done in Region 3, we contacted by telephone 50 fire
 departments during August and September 1987, to assess the
 effectiveness of the region's outreach efforts.  The depart-
 ments contacted were obtained from a list provided by the
 fire marshal in each State.  Of the 50 departments contacted,
 3.6 told us they were not aware of the Rule.  Exhibit B provides
 the results of our phone survey for Region 6.  Thus, despite
 awareness efforts, including the 223 asbestos  inspector visits
 made through August 1987, 72 percent of the fire companies we
 contacted were unaware of the Rule approximately two years
 after it was issued.

 During our field work, we sent the results to  branch officials.
 The PCB Coordinator stated that they would use the results in
 their program.

 CONCLUSION

 Regions 3 and 6 have taken certain actions to  inform fire
 response personnel about the Rule.  These regions concentrated
 their efforts on the larger urban areas where  significant public
 exposure to PCB fires is more likely to occur.  Despite  the  pro-
 gress made, small and volunteer fire departments were generally
 unaware of the Rule's intent and requirements  approximately  two
 years after the Rule was issued.  Of the 100 small and volunteer
 fire departments we contacted, 62 told us they were unaware  of
 the Rule.

 Small and volunteer fire departments can be called to  respond
 to fires involving. PCB transformers.  A lack of awareness  to
 the dangers posed by the highly toxic by-products of PCB fires
 could unnecessarily expose fire personnel and  seriously  damage
 their health.  Because of the significant lack of awareness  our
phone survey identified, OPTS needs to conduct a special aware-
 ness effort directed at small and volunteer  fire departments.

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 The awareness  effort should  involve  the distribution of
 written materials  concerning the Rule  and the need to take
 special precautions  in fighting PCB  fires,   in addition,
 regional seminars  for fire personnel would  increase awareness
 of the Rule.   Conducting an  effective  awareness program will
 provide fire personnel with  knowledge  about the dangers posed
 by PCB transformer fires and the Rule's requirements.  Armed
 with this knowledge,  fire personnel  could develop plans for
 responding to  transformer fires, even  if they are not sure a
 PCB transformer is involved.

 To monitor whether the awareness program has been successful
 in informing fire  personnel  about  the  Rule,  the regions should
 selectively followup with fire departments  to determine
 whether the -Rule and the reasons for its issuance are clearly
 understood.  Priority attention should be given to contacting
 departments who would respond to fires at locations known to
 have PCB transformers.   Had  Region 3 done this after distri-
 buting its notice  on the Rule, the lack of  awareness we
 identified would have been found and corrective action could
 have been taken.   In addition, the outreach program will be
 enhanced if other  regions adopt practices such as Region 6's
 use of abestos inspectors to inform  fire personnel about the
 Rule.   Similar innovative activities,  which require a minor
 investment of  resources,  should be made part of the Agency's
 awareness program.

      OPTS—€OMM£NTS AND-QIC EVALUATION

 In his March 3,  1988,  memorandum,  the  Assistant Administrator
 for Pesticides and Toxic Substances  stated  that it  is  important
 for all fire response personnel, including  small  and volunteer
 departments, to be aware of  the Rule.  To promote awareness  for
 fire departments,  the Assistant Administrator  said  that  OPTS
 would place articles in pertinent  trade journals  and magazines.
 In addition, OPTS  will use asbestn=  ; -.*-•??+?r:p. to inform fire
 personnel *wout the  Rule. While we  agree-, wVcu'Vhs  iiwtions
 planned,  we believe  that the regions and Headquarters  need  to
 selectively followup with fire response personnel to ensure
 that the Rule's reouirements and reasons for issuance  ^^n
 understood.                          - > -               ' : -

 RECOMMENDATIONS•

•we recommend: that  the Assistant Administrator  for Pesticides
 and Toxic Substances^'

      i%   Conduct,  in conjunction with  the  regions,  an  aware-
          ness  program specifically directed at small  and
          volunteer fire departments.  To accomplish this,  the
          Assistant Administrator should develop  a plan which:
                                10

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    — assigns specific duties and responsibilities to
       regional and Headquarters personnel;

    — contains milestone dates for accomplishing major
       tasks;

    — includes activities requiring a minor investment
       of resources, such as using asbestos inspectors to
       inform fire personnel about the Rule; and

    -- requires the regions to followup with fire person?-
       nel, particularly with those who- would respond to
       fires at known PCB transformer locations.
2.   Monitor progress against— the
                           11

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2.  NEED FOR MORE AGGRESSIVE OUTREACH EFFORTS
    TO COMMERCIAL BUILDING OWNERS
Since OPTS first distributed the Rule in July 1985,  neither
OPTS nor Regions 3 and 6 have conducted additional awareness
efforts or directed monitoring activities specifically aimed
at commercial building owners.  During 1987, two fires occurred
in Region 6 near commercial buildings.  According to fire
officials or EPA records, the registration requirement was
not followed in either incident.  For one of the incidents, a
fire department official told us that the failure to register
resulted in fire personnel being unnecessarily exposed to toxic
chemicals.  Also, the PCB coordinator•in Region 3 estimated
that violations of the Rule, primarily involving the registra-
tion requirement, are found in half of the commercial building
inspections.  The seriousness of the health risks posed by
PCB fires in commercial buildings warrants a more aggressive
awareness campaign for commercial building owners.

In enacting the Rule, OPTS cited numerous incidents across the
country that prompted the office to reassess its early thinking
about the frequency of PCB fires.  When the Rule was published,
EPA estimated that 50 structure-related transformer fires would
occur over the remaining useful life of PCB transformers.  Of
these, 44 would happen in or near commercial buildings.  OPTS
was particularly concerned about fires occurring during peak-
use periods in commercial buildings because hundreds of building
occupants could be exposed to smoke and soot from the fire during
evacuation of the buildings.  If the transformer involved  in
the fire is located near the building's ventilation system and
duct work, the chance for exposure is increased.

Because of these concerns, the Rule required owners of PCB
transformers located in or near commercial  buildings to regis-
ter the equipment with the primary fire response group and
the building owner.  For purposes of  this Rule, EPA defined
commercial buildings as non-industrial buildings typically
accessible to members of the general  public.  Commercial build-
ings would include apartments, office buildings, schools,  meeting
halls, and stores.  EPA determined that PCB transformer fires,
particularly those occurring in or near commercial buildings,
presented risks to human health and to the  environment.

Aaencv Outreach Efforts Have Been Limited

After the final Rule was approved, OPTS contracted to mail the
Rule to entities including environmental groups,  industries,
insurance associations, insurance companies, buildings associa-
tions, and State governments.  OPTS hoped that  these  entities
would "spread the word" through their various publications.
                                12

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Shortly thereafter, OPTS held a one-day seminar to explain
the Rule.  Various groups including industry and trade associ-
ations, Stst» governments, universities and fire officials
were invited.  However, the session was not well attended.

OPTS did not conduct any additional awareness efforts for
commercial building owners until April 1986, when it deve-
loped a pamphlet explaining the intent and requirements of
the Rule.  In emphasizing the seriousness of PCB fires in
commercial buildings, the pamphlet stated that:

          It is critically important (underscoring
          added) that commercial building owners
          register PCB transformers with local fire
          departments or brigades.  PCB fires pose
          serious risks to building occupants and
          fire fighters.  If fire fighters and
          other personnel know they may be dealing
          with PCBs, they can be prepared and
          equipped to deal with the fire.  Both
          fire fighters and building owners also
          should be aware of the need to quickly
          evacuate occupants in an emergency
          situation, and of the need to ensure that
          proper and adequate cleanup occurs prior
          to recccupation of the building.

While OPTS sent copies of the pamphlet to the regional
offices, it did not.provide any guidance for distribution of
the pamphlets.  The PCB Coordinators in Regions 3 and 6 told
us that they only mailed the pamphlet to parties who requested
information on the Rule.  These regions did not do a mass
distribution because they were:   (1) uncertain where the
information should be sent; and (2) involved in other priority
work.

PCB Transformer Fires Continue to Occur

While the health effects of those exposed during  actual
incidents are still being studied, the seriousness of PCB
transformer fires can be demonstrated by the cost and time
involved in cleanup prior to reoccupancy.   The  Binghamton,
New York incident contributed to the Rule's development.  On
February 5, 1981, an electrical fire occurred  in  the basement
of the 18-floor State Office Building.  Oil containing  PCBs
spilled into the fire and was changed by the heat into  dioxin.
The dioxin was drawn into the soot and dispensed  through the
ventilation system to virtually every part  of  the building.
Pictured on the next page is the toxic material covering an
office after the fire.
                                13

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The contamination resulting from the Binghamton fire was so
severe that the cleanup efforts are still underway.  In
February 1987, State officials estimated that about $37 million
in cleanup costs had been expended.  The building cost $13
million to construct.  Current plans call for reoccupancy in
early 1989, over eight years after the fire occurred.

The Binghamton fire was not an isolated incident.  More
recently, transformer fire incidents have occurred in the
following locations within the Regions 3 and 6—Santa Fe, New
Mexico; Norfolk, Virginia; Shreveport, Louisiana; and Garland,
Texas.
                              14

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In Santa Fe, an overheated PCS transformer developed smoke  at
the New Mexico State Highway Building on June 17,  1985.   While
there were no flames, the extreme heat caused the  PCS oil to
vaporize producing dioxins and furans.  Smoke entered the air
intake duct and was distributed throughout the building.  The
picture on the bottom of the previous page shows the cleanup
activities undertaken.  Workers are wearing protective clothing
worn during PCS fire cleanups.

Reoccupancy of the State Highway Building began in December 1986,
and was completed in January 1987, or approximately a year  and
a half after the incident occurred.  State officials estimated
that they spent about $16 million in cleanup costs.

In another incident, a PC3 transformer was struck by lightning
at the U.S. Navy Rework Facility in Norfolk, Virginia on April  29,
1986.  The resultant fire occurred on the ground floor of a build-
ing used as a combination workshop, packaging and engineering
office building.  Smoke and soot spread through the building and
adjacent areas.  The Navy is now deciding whether to perform the
necessary cleanup activities to. permit reoccupancy or replace
the building.  Regardless of the option chosen, estimated costs
are likely to be at least 520 million.

Still another incident occurred on April 4,  1987, at the
Louisiana State University Medical Center in Shreveport,
Louisiana.  An estimated 470 gallons  of PCB  oil was released
from a power plant transformer when it overheated and ruptured.
PCB oil was sprayed over the entire second floor of the power
plant building and spread into the majority  of the  first floor
generator room.  Air sample results indicated that  the fire
was contained within the plant building because no  airborne
PCBs were detected outside the power  plant.  The Shreveport
Fire Department responded to the  incident.   According to the
Deputy Fire Chief, the department had not received  a registra-
tion for the PCB transformer at the facility.  Firemen who
entered the building initially did so without protective gear
worn when responding to PCB fires.  Eight firemen were admitted
to the hospital.  Three plant workers were also exposed.  The
Deputy Chief told us that, while  all  persons exposed were
released from the hospital after  a short stay, all  will  undergo
longterm medical monitoring.

Finally, the most recent incident we  are aware of  occurred
on July 30, 1987, in Garland, Texas.  A  PCB  transformer  in  an
outside vault near Memorial Hospital  overheated.   Apparently
the smoke was confined to the vault area.   In this  case, the
fire department knew a PCB transformer was  on the  premises.
However, registration occurred only after an EPA  inspection.
                                15

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 In January  1987, Region 6 cited the owner for failing to
 register the transformer with the fire department and the
 building owner, which should have been done by December 1,
 1985.  As a result of the inspection and the subsequent Notice
 of Violation,  the owner registered the equipment.

 An Awareness Program Is Needed

 After  initial  outreach efforts, the Agency has primarily
 relied on inspections to inform commercial building owners
 about  the Rule.  Considering the number of buildings which
 could  be inspected and the competing demands for Agency
 resources,  this approach is not sufficient to achieve the
 level  of awareness necessary to protect against the dangers
 posed  by PCS fires.

 The number  of  commercial buildings which could be inspected
 greatly exceeds the number of inspections that can be done
 with limited Agency resources.  Annually, the regions allocate
 the total number of inspections they will do among various
 categories.  Commercial buildings, one of the categories,
 will represent from 15 to 25 percent of the total regional
 inspections during fiscal 1988.  For fiscal 1988, OPTS directed
 the regions to decrease the number of inspections so that
 additional  resources could be devoted to enforcement cases.
 For example. Regions 3 and 6 will reduce the total number of
 compliance  inspections during fiscal 1988 as shown below:
                          Number of Inspections
     Region
FY 87
                          185
                          175
FY 88
                   150
                   130
Competing priorities have also slowed regional efforts to
use transformer location information in selecting which  facili-
ties to inspect.  For example, during 1986 and 1987, Region  3
asked utility companies to provide location  information  on
their customers.  Also, during this period,  Region  6 obtained
transformer location information from certain fire  departments
who had received registrations.  However, a  major effort
directed at developing enforcement cases had prevented both
regions from using the information obtained  by the  time  we
completed our field visits.  Similar priority projects are
likely to occur in the future.

In our opinion, the demands placed on the Agency's  limited
resources to regulate a large universe necessitates the  need
for additional awareness efforts.  From the  records reviewed
or discussions held, PCS transformers involved in'the Garland,
                                16

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Texas and Shreveport, Louisiana incidents had not been registered
by the Rule's December 1, 1985, deadline.  The PCB Coordinator
in Region 3 estimated that inspectors fir.d violations of the
Rule, primarily involving the registration requirement,  in 50
percent of the commercial buildings inspected.  A program is
needed to increase awareness and promote compliance with the
Rule's requirements, particularly concerning registration.

CONCLUSIONS

Both in establishing the registration requirement for commer--
cial buildings-and in the April 1986, pamphlet, OPTS expressed
concern about public exposure to PCB fires in commercial
buildings.  To help building owners and fire fighters prepare
for fire-related incidents, owners of PCB transformers located
in or near commercial buildings were required to register the
equipment by December 1, 1985.  Actual fire incidents have-
occurred at or near locations which have not complied with
the registration requirement.  For one incident, a fire
official told us that the failure to register resulted in
fire fighters being unnecessarily exposed to toxic chemicals.
The PCB Coordinator in Region 3 estimated a 50 percent
noncompliance rate with the Rule, primarily involving the
registration requirement.  To increase awareness and promote
compliance with the Rule's requirements, the Agency needs to
conduct an outreach effort aimed at commercial building owners.
The increased demands placed on Agency resources which could
be used for awareness further supports the need for outreach
activities.

Identifying a complete universe of commercial buildings,  as
defined in the Rule, is a difficult task.  Commercial buildings
are numerous and geographically dispersed.  However, some
information is already available.  For example, Regions 3 and
6 obtained information on transformer locations from certain
utilities and fire departments.  In addition, the  regions could
use inspection reports for commercial buildings to identify
types of entities most likely to have PCB transformers.   This
information could be supplemented by data gathered from building
associations, chambers of commerce, and  school districts.

OPTS should also explore ways to supplement Agency resources
by requesting the assistance of other groups  concerned  with
health and safety issues.  For example,  the Agency could
request that State and local health and  safety  inspectors and
fire safety inspectors expand their  inspections to emphasize
the Rule's importance and determine whether the registration
requirement has been complied with.  A procedure  could  then
be established to inform the local fire  department about
facilities which have not registered.  In addition,  the Agency
could contact insurance companies, expressing the seriousness
of PCB fires, in the hope that the companies  will pressure
those they insure to comply with the Rule's requirements.

                               17

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     OPTS CnMMTTjjTS_AND PIG EVALUATION

In his, memorandum of Marca j, 1988, tne Assistant Administra-
tor stated that risks to health and the environment, as well
as cleanup costs, in the event of a fire involving a PCS
transformer in a commercial building are well documented.
Accordingly, OPTS believes that is is important for owners of
PCB transformers located in or near commercial buildings to
register the equipment with building owners and fire departments,

To promote awareness and compliance, OPTS plans to place arti-
cles in pertinent trade journals and magazines whose audience
is affected by the Rule, e.g., building owners and insurance
companies.  Also, OPTS will work with the regions to conduct
an awareness program directed at commerical building owners.
Lastly,  OPTS plans to publish an amendment to the Rule in
July 1988.  OPTS plans an extensive distribution which will
include information on commerc^i buildings.  We agree with
the actions planned by OPTS.

RECOMMENDATIONS

We- recommend-: that the Assistant Administrator for Pesticides
and Toxic Substances:

     L.   Conduct, in conjunction with the regions, an aware-
         ness program for commercial building owners.  To
         accomplish this, the Assistant Administrator should
         develop a plan which:

         — assigns specific duties and responsibilities to
            regional and Headquarters personnel; and

         — considers ways of supplementing Agency  resources
            through the use of groups such as health and
            safety inspectors and  fire inspectors.

     2..   Monitor progress against—the—pian-.-

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 3.   ACTIONS WHICHWILL INCREASE THE
     EFFECTIVENESS OF  INSPECTIONS

 To  increase the effectiveness of its inspections, the Agency
 needs  to" improve its  process for selecting which facilities to
 inspect  and provide guidance which regional inspectors can use
 to  perform inspections.  Regions 3 and 6:  (1) had not always
 contacted fire departments to obtain registration information;
 (2)  did  not record key inspection information in an automated
 management information system; and (3) lacked guidance con-
 cerning  enhanced electrical protection.  Unless these actions.
 are taken, the Agency will continue to allocate a portion of
 its limited inspection resources to facilities which have no
 PCB equipment and be  unable to determine compliance with the
 electrical protection requirement.

 The Rule  requires that network PCB transformers of 480 volts
 or  greater located in or near commercial buildings must be
 removed  from service  by October 1, 1990.  In addition, network
 transformers of a lesser voltage and radial transformers of
 480 volts or more used in or near commercial buildings should
 have enhanced electrical protection installed by the same
 date.  EPA believed these actions would significantly reduce
 the fire-related risks posed by the use of PCB transformers.

 Since  the Toxic Substances Control Act did not require owners
 of  PCB equipment to submit location information to EPA, the
 Agency has had to rely on other means -to develop a universe
 of  regulated entities.  For example, a list of purchasers of
 PCB material was obtained from the major manufacturer.  Based
 on  this  information and working knowledge developed over time,
 the Agency identified types of industries most likely to have
 PCB equipment, including transformers.  OPTS' annual inspec-
 tion guidance directs the regions to allocate- their inspections
 among these major industry categories.  The regions then decide
 which  facilities within these categories to inspect.  Inspec-
 tions have been one of the Agency's means for:   (1) developing
 a universe of entities with PCB transformers;  (2) conducting
 outreach efforts; and (3) monitoring compliance.  PCB inspec-
 tions are comprehensive; not only does the inspector check
 for  compliance concerning marking, storage, and disposal but
 also for adherence to the Rule's requirements.  As discussed
 in  Finding Number 2,  the Agency has used inspections to  inform
 those who are unaware about the Rule's requirements.

Available Information Not Used
To  Select Facilities  For Inspection

 Because the Agency is not always certain where PCB equipment,
 including transformers, may be found,  it has  targeted loca-
 tions for inspection  which had no PCB  equipment.  The PCB
Coordinators in Regions 3 and 6 estimated that,  for approxi-
                                19

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mately half of the locations visited,  no PCS equipment has
been found.  Concern over the low rate for finding PCS equip-
ment caused OPTS to contract with a consultant to obtain
advice on how limited inspection resources could be better
utilized.  The consultant's study,  dated August 1985,  con-
cluded that in light of resource constraints "... narrowing
the size of the regulated community to a manageable number  of
priority sources and inspecting those most likely to be in
violation of Federal requirements are central to achieving
EPA's mandate concerning these hazardous substances."

In June 1986, OPTS amended the PCS Compliance Monitoring Stra-
tegy to urge the regions to obtain registration information
from fire departments in urban areas within their jurisdiction.
Primary attention was to be directed at information for trans-
formers located in or near commercial buildings,  obtaining
this information would assist the regions in estimating the
resources needed to inspect commercial buildings and in desig-
ning a strategy to inspect for compliance with future Rule
requirements.

The PCS Coordinators in Regions 3 and 6 told us that other
high priority work, primarily involving enforcement cases,
had prevented them from conducting a concerted effort to
obtain information from fire departments who received registra-
tions and incorporate this information into their selection
process for inspections.  As a result, these regions had not
been able to use a valuable resource in developing  an inspec-
tion strategy.  As the number of inspections decreases  (see
page 16 of this report), it becomes even more  important to
target inspection resources to facilities having PCB equipment,
including transformers.

Selection Process Can
Be More Efficent

When inspections are performed, key data  including  whether a
PCB transformer was found, its type, and  location are not
recorded in an automated management information  system  in
Regions 3 and 6.  Therefore, at the point when the  Agency
begins to check for compliance with the 1990 milestone  dates,
regional personnel will have to manually  review  hundreds of
inspection files to determine which facilities should be
included in the inspection scheme.  Automating inspection
results would provide for a quick  review  with  a  small  invest-
ment of resources.

In discussing this issue, the regions believed a master,
automated inventory of locations with PCB equipment would  be
of limited value.  The PCB Coordinators in  Regions  3  and 6
told us that an inventory would only  list locations that had
PCB equipment as of the date of the inspection.   The owner
                               20

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could subsequently dispose of the equipment.   Moreover,  they
told us that obtaining information from fire departments
would only identify locations that complied with the registra-
tion requirement; it would not identify those that did not
comply.  We continue to believe that automating inspection
information will assist the regions in targeting a portion of
their limited inspection resources to those locations having
PCB equipment which must be modified or replaced by October 1,
1990.

Guidance Needed For
Enhanced Electrical Protection

OPTS has not provided guidance describing safety enhancements
that would represent acceptable "enhanced electrical protec-
tion".  An OPTS official stated that guidance has not been
developed because of other priorities, limited resources and
the absence of immediate need, since compliance is not
required until 1990.

The PCB coordinators in Regions 3 and 6 said that they and
their inspectors were not sure what "enhanced electrical
protection" would entail.  Both officials said that, as the
milestone date approaches, they expect to receive inquiries
from transformer owners about the protection requirement.
Unless specific guidance is developed, the regions will not
be able to adequately respond to inquiries or determine whether
enhancements are acceptable.  The officials added that guidance,
supplemented by training, is essential because inspectors
have little formal training in electrical systems.

CONCLUSION

Collecting and automating inspection and registration
information wiir provide for a more effective and efficient
identification of those locations subject to the  1990 date
and other PCB regulations.  In addition, OPTS needs  to  explain
what "enhanced electrical protection" entails so  that regional
inspectors will be able to assist the regulated community and
determine compliance.

OFFS COMMENTS-AND PIG EVALUATION

In his memorandum of March 3, 1988, the Assistant Administra-
tor for Pesticides and Toxic Substances concurred vicn. o«*
recommendations.  The Office of Compliance Monitoring within
OPTS -has prepared a draft Compliance Strategy amendment which
recommends that the regions:  (1) obtain registration informa-
tion; and (2) record key inspection information on  their
computers.  In addition, OPTS will work with the  regions to
develop guidance explaining what enhanced  electrical protection
entails.  While we agree, with the  intent of  the actions planned,
we ace concerned that the draft amendment  only  recommends and
does not require the regions to take these  actions.
                               21

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RECOMMENDATIONS  •

We recommend that the Assistant Administrator for Pesticides and
Toxic Substances:

     1.  Require the regions to use transformer registration
         information in selecting which facilities to inspect.

     J.  Direct the regions to record inspection results in an
         automated management information system.

     j.  Issuo guidance explaining what enhanced electrical
         protection entails.
                                22

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                                                  EXHIBIT A
                    RESULTS OF PIG TELEPHONE
                 SURVEY OF FIRE DEPARTMENTS IN
                            REGION 3
NAME/ADDRESS OF                    AWARE OF EPA        SAW EPA
DEPARTMENT CONTACTED                FIRES RULE

  DELAWARE

Bethany Beach Vol. Fire Co.             Yes               No
P.O. Box 142
Bethany Beach, De. 19930
Contacted Member

Carlisle Vol. Fire Dept.                 No               No
P.O. Box 292
Milford, De.  19963
Contacted Engineer

Georgetown Fire Co.                     Yes              Yes
P.O. Box 132
Georgetown, De.   19947
Contacted 2nd Asst. Fire Chief

Robbins Hose Fire Co. #1                Yes               No
103 South Governors Avenue
Dover, De.  19901
Contacted Fire Chief

Roxana Vol. Fire Co.                     No               No
Box 420
Frankford, De. 19945
Contacted Member

Talleyville Fire Co.                     No               No
3919 Concord Pike
Wilmington, De.   19803
Contacted. Member

 DISTRICT OF COLUMBIA

Washington Airport Fire Dept.           Yes               Yes
West Lab Bldg., Room 175
Washington, D.C.  20001
Contacted Fire Chief

Dist. of Columbia Fire Dept.            Yes               No
1923 Vermont Avenue, N.W.
Washington, D.C.  20001
Contacted Fire Chief
                                23

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                                                    EXHIBIT A
 NAME/ADDRESS OF                    AWARE OF EPA         SAW  EPA
 DEPARTMENT CONTACTED               FIRES RULE           FLYER

    MARYLAND

 Brandywine Vol. Fire Dept.               No               No
 P.O. Box 216
 Brandywine, Md.  20613
 Contacted Actg. Lieutenant

 Greenbelt Vol.  Fire Dept.               Yes               Yes
 125 Crescent Road
 Greenbelt,  Md.   20770
 Contacted Firefighter

 Hereford Vol.  Fire Co.                  No               No
 510 Monkton Road
 Monkton, Md."  21111"
 Contacted Engineer

 Ocean City  Vol. Fire Co.                 No               No
 P.O.  Box 27
 Ocean City,  Md.  21842
 Contacted Member

 Odenton  Vol.  Fire Co.                   Yes               Yes
 1425  Annapolis  Road
 Odenton,  Md.   21113
 Contacted Asst. Fire Chief

 Rescue Fire Co.                         No               No
 P.O.  Box 364
 Cambridge,  Md.   21613
 Contacted Member

 Sharptown Vol.  Fire Dept.                No               No
 P.O.  Box  307
 Sharptown, Md.   21861
 Contacted Fire  Chief

 West  Lanham Hills Vol.  Fire              No               No
 7609  Annapolis  Road
 Hyattsville, Md.   20784
 Contacted Lieutenant

  PENNSYLVANIA

American  Hose Co.  #1                    No               No
 39 Mauch  Chunk  Street
Tamaqua,   Pa.  18252
Contacted Fire  Chief
                               24

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                                                  EXHIBIT A
 NAME/ADDRESS OF                   AWARE OF EPA           SAW EPA
 DEPARTMENT CONTACTED                FIRES RULE             FLYER"

 Eastvale Vol.  Fire Dept.               No                    No
 321 3rd 'Avenue
 Eastvale Beaver Falls,  Pa.   15010
 Contacted Fire Chief

 Highland Firemens Assn.                No                    No
 8705 Harold Place
 Pittsburgh,  Pa.   15237
 Contacted Asst.  Fire Chief

 Lock Four Vol.  Fire Co.                No                    No
 560 Isabella Avenue
 North Charleroi,  Pa.  15022
 Contacted Fire Chief

 McDonald Vol.  Fire Dept.               No                    No
 150 North McDonald Street
 McDonald,  Pa.   15057
 Contacted 2nd  Lieutenant

 North Bessemer Vol.  Fire Co.          Yes                    No
 1917  Leechburg Road-
 Pittsburgh,  Pa.   15235
 Contacted Asst.  Fire  Chief

    VIRGINIA

 Amelia County  Vol.  Fire Dept.          No                    No
 P.O.  Box  307
 Amelia, Va.  23002
 Contacted  Fire  Serv.  Coord.

 Arlington  County  Fire Dept.           Yes                    No
 1020  N. Hudson Street
Arlington, Va.  22201
 Contacted  Captain

Central King & Queen  Fire             Yes                    No
King  & Queen Courthouse, Va.
  23085
Contacted  Fire Chief

Falls Church Fire Dept.               Yes                    No
555 N. Washington Street
Falls church, Va.   22046
Contacted  Fire Marshal
                               25

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                                                   EXHIBIT A
 NAME/ADDRESS OF                    AWARE OF EPA           SAW EPA
 DEPARTMENT CONTACTED                FIRES RULE              FLYER

 Franconia Vol. Fire Dept.               Yes                  No
 6300 Beulah Street
 Alexandria, Va.  22310
 Contacted Lieutenant

 King George Vol.  Fire Dept.              No                  No
 P.O. Box 466
 King George, Va.   22485
 Contacted Fire Chief

 London Bridge Vol.  Fire                Yes                  Yes
 2310 Va.  Beach Blvd.
 Virginia Beach, Va.   23454
 Contacted Captain

 London County Fire  Dept.                 No                  No
 209  Gibson Street,  N.W.
 Leesburg,  Va.   22075
 Contacted Asst. Fire  Chief

 Mt.  Vernon Vol. Fire  Dept.              Yes                  No
 2675 Sherwood Hall  Lane
 Alexandria,  Va.  22306
 Contacted Lieutenant

 Shenandoah Vol. Fire  Co.                 No                  No
 201  Pennsylvania  Avenue
 Shenandoah,  Va.  22849
 Contacted  Member

 Sperryville  Vol.  Fire Dept.              No                  No
 Route  522
 Sperryville,  Va.  22740
 Contacted  Fire  chief

 USA  Vint Hills  Farm station             Yes            '      No
 US Army Garrison
 Warrenton, Va.  22186
 Contacted  Member

USAF Langley  Base Fire Dept.            Yes                  Yes
 Langley AFB, Va.  23365
Contacted  Fire  Chief

USMC Quantico Fire Dept.                Yes                  No
Security BN Fire Protection
  Prevention Division
Quantico, Va.   22134
Contacted  Fire  Chief
                               26

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                                                   EXHIBIT A
  NAME/ADDRESS  OF             '       AWARE OF EPA           SAW EPA
  rEPARTMENT  CONTACTED                FIRES RULE    '         FLYER

  USN Amphibious Base Fire Dept.          Yes                 Yes-
  Bldg.  3029  Little Creek
  Norfolk, Va.  23521
  Contacted Fire Chief

  Vienna Fire Dept.                       Yes                 Yes
  P.O. Box 1115
  Vienna, Va.  22180
  Contacted Lieutenant

  Williamsburg Fire Dept.                 Yes                 Yes
  440 North Boundary Street
 Williamsburg,  Va.  28185
  Contacted Batallion Chief

    WEST VIRGINIA

 Gary Fire Dept.                          Yes                  No
 P.O.  Box 310
 Gary,  WV.   24830
 Contacted Training Officer

 Harrisville Fire  Dept.                    No                  No
 612  East Main  Street
 Harrisville, WV.   26362
 Contacted  Asst. Fire Chief

 Hinton  Fire  Dept.                         No                  No
 Park Avenue
 Hinton,  WV.  25951
 Contacted  Engineer

 Jefferson Vol. Fire  Dept.                 No                  No
 6313 MacCorkel Avenue
 Saint Albans,  WV.  25177
 Contacted Firefighter

 Kenova Fire  Dept.                        Yes                 Yes
 615 15th Street
 Kenova, WV.  25530
 Contacted Firefighter

 Logan Fire Dept.                          No                  No
 219 Dingess Street
 Logan,  WV.  25601
Contacted Fire Chief
                               27

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                                                  EXHIBIT A
 NAME/ADDRESS  OF
 DEPARTMENT  CONTACTED

 Marlinton Fire  Dept.
 709  2nd  Avenue
 Marlinton^  WV.   24954
 Contacted Captain

 Meadow Bridge Fire  Dept.
 P.O.  Box 32
 Meadow Bridge,  WV.   25976
 Contacted Lieutenant

 Pineville Fire  Dept.
 P.O.  Box 200
 Pineville,  WV.   24874
 Contacted Fire  Chief
 Stonewood Fire  Dept.
 112  Southern  Avenue
 Stonewood,  WV.   26301
 Contacted Fire  Chief

 Summerville Fire Dept.
 400  Broad Street
 Summerville,  WV.  26651
 Contacted Fire  Chief
   AWARE OF  EPA
    FIRES  RULE

       No
SAW EPA
 FLYER

   No
       Yes
  Yes
       Yes
        No
   No
   NO
        No
   No
RESULTS

AWARE OF EPA
 FIRES RULE

 No  =  26  (52%)
Yes  -  24  (48%)
   SAW  EPA
    FLYER

  No = 39  (78%)
.Yes = 11  (22%)
                               28

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                                                   EXHIBIT B  '


                     RESULTSOF PIG TELEPHONE
                    SURVEY OF FIRE DEPARTMENTS
                           IN REGION 6


 NAME/ADDRESS OF                                    AWARE OF EPA
 DEPARTMENT CONTACTED  '                              FIRES RULE

    ARKANSAS

 Earle Vol. Fire Dept.                                  Yes
 1121 2nd Street
 Earle, Ar.  72331
 Contacted Fire Chief

 Fordyce Vol.  Fire Dept.                                 Yes
 201 S. Moseley
 Fordyce,  Ar.   71742
 Contacted Fire Chief-

 Grady Vol.  Fire Dept.                                    No
 P.O.  Box  181
 Grady,  Ar.   71644
 Contacted Fire Chief

 Junction  City Vol.  Fire  Dept.                            No
 P.O.  Box  41
 Junction  City,  Ar.   71749
 Contacted Fire  Chief

 Mansfield Fire  Dept.                                     No
 P.O.  Box  476
 Mansfield, Ar.  72944
 Contacted Fire  Chief

 Siloam Springs  Fire Dept.                               Yes
 100 Mount Olive
 Siloam Springs, Ar.  72761
 Contacted Fire  Chief

 Texarkana Fire  Dept.     -                                No
 P.O. Box  2711
Texarkana, Ar.  75504
Contacted Fire  Chief

Van Buren .Fire  Dept.                                     No
408 Mt. Vista
Van Buren, Ar.  72956
Contacted Captain
                               29

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                                                   EXHIBIT  B
 NAME/ADDEESS OF                                    AWARE  OF  EPA
 DEPARTMENT CONTACTED                                FIRES RULJT

 Hominy Fire Dept.                                 "•    No
 111 S. Regan
 Hominy, Ok. 74035
 Contacted Firefighter

 Mannford Vol.  Fire Dept.                                Yes
 P.O.  Box 327
 Mannford, Ok.  74044
 Contacted Fire Chief

 Mustang Fire Dept.                                     No
 470 W.  Highway #152
 Mustang,  Ok. 73064
 Contacted Asst.  Fire Chief

 Ringling Fire  Dept.                                    No
 P.O.  Box 900
 Ringling,  Ok.  73456
 Contacted Asst.  Fire Chief

 The Village Fire Dept.                                  No
 2201  W.  Britton  Road
 The Village, Ok.   73120
 Contacted Deputy Fire Chief

        TEXAS

 Greenville Fire  Dept.                                   Yes
 P.O.  Box  1049
 Greenville,  Tx.   75401
 Contacted  Asst.  Fire Chief

 Kenedy  Fire Dept.                                       No
 P.O.  Box  720
 Kenedy, Tx.  78119
 Contacted  Fire Chief

 Lewisville Fire  Dept.                                   No
 151 West Church  Street
 Lewisville, Tx.   75067
 Contacted  Fire Chief

Mabank Fire Dept.                                       No
P.O. Box 545
Mabank, Tx. 75147
Contacted  Fire Chief
                                33

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                                                  EXHIBIT B
NAME/ADDRESS OF
DEPARTMENT CONTACTED

Marshall  Fire  Dept.
P.O.  Box  698
Marshall, Tx.  75671
Contacted Fire Chief

Midlothian Fire  Dept.
235 North 8th
Midlothian, Tx.  76065
Contacted Firefighter

Palmer Volunteer Fire Dept.
P.O.  Box  430
Palmer, Tx.  75152
Contacted Lieutenant

Venus Vol. Fire  Dept.
P.O.  Box  183
Venus, Tx.  76084
Contacted Asst.  Fire Chief

Victoria  Vol.  Fire Dept.
P.O.  Box  1758
Victoria, Tx.  77901
Contacted Asst.  Fire Chief

White Settlement Fire Dept.
214 Meadowpark
White Settlement, Tx.  76108
Contacted Fire Chief
AWARE OF EPA
 FIRES RULE

    Yes
     Yes
      No
      NO
      No
      NO
RESULTS

AWARE OF EPA
 FIRES
No = 36 (72%)
Yes » 14 (28%)
                                34

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                                            APPENDIX 1 -
            UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                       WASHINGTON. O.C. 20460            C


                             MAR   3 1388
                                                            tee. OF
                                                  PESTICIDES AND TOXIC SUBSTANCE
MEMORANDUM
SUBJECT:
FROM:
TO:
OPTS Response on Draft Audit Report E1E57-11-0024,
Review of the EPA Rule Regulating Polychlorinated
Biphenyl  (PCB) Transformer Fires

John A. Moore
Assistant Administrator
  for Pesticides
  and Toxic Substances (TS-788)

Ernest E. Bradley III
Assistant Inspector General for Audit  (A-1Q9)

     The Office of Pesticides  and  Toxic  Substances (OPTS)
welcomes the opportunity  to provide  comments  on the Inspector
General's February 2,  1988 Draft Audit Report,  which indicated a
need for improving the existing awareness  campaign for the PCS
Transformer Fires Rule.   OPTS  is well aware of  the potential
risks associated with  PCB transformer fires and the need to
ensure compliance with the provisions of the  rule in order to
minimize these risks.   We will first summarize  our outreach
efforts to date and  then  address the areas of concern
specifically identified in the draft report,  followed by our
plans to upgrade future outreach efforts.

     As you know, the  PCB Transformer Fires Rule was published in
the Federal Register on July 17, 1985, and became effective on
August 16, 1985.  Outreach efforts began,  however, shortly after
publication of the proposed PCB Transformer Fires Rule in October
1984; copies of the proposed rule  were sent for comment to all
members listed on the  International  Association of Fire Fighters
mailing list.  In the  Spring of 1985 the Chief  of the Chemical See Appendi
Regulation Branch (CRB) held a conference call  with the Regional'Note l
PCB Coordinators indicating they should  implement an outreach
effort by identifying  fire departments as a source of
information.  Also at  that time, CRB made presentations to the
Apartment Owners and Builders  Association, Building Owners and
Managers Association,  and the  Apartment  Owners  and Managers
Association, in an attempt to  inform this segment of the
regulated community about the  PCB  Transformer Fires Rule.
                                 35

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                                                  EXHIBIT B
 NAME/ADDRESS OF
 DEPARTMENT CONTACTED

 Viola Volunteer Fire Dept.
 P.O.  Box 75-
 Viola,  Ar.   72583
 Contacted Fire  Chief

 Y-City Volunteer Fire Dept.
 HCR  69,  Box 328
 Boles,  Ar.   72926
 Contacted Fire  Chief

       LOUISIANA

 Bastrop Fire Dept.
 City  Hall Complex
 P.O.  Box 431
 Bastrop,  La.  71220
 Contacted Acting Fire Chief

 Bogalusa Fire Dept.
 200 Arkansas Avenue
 Bogalusa,  La.   70427
 Contacted Asst.  Fire Chief

 Hammond  Fire Dept.
 P.O.  Box 1595
 Hammond,  La.  70404
 Contacted Hazardous  Mat.
  Team  Leader

 Iota  Volunteer  Fire  Dept.
 P.O.  Box 890
 Iota,. La.   70543
 Contacted Fire  Chief

 Kenner Fire  Dept.
 1801  Williams Blvd.
 Kenner,  La.   70062
 Contacted Asst.  Fire Chief

Morgan City  Fire Dept.
 P.O.  Box  2622
Morgan City,  La.  70381
Contacted Fire  Chief

Sicily Island Vol. Fire Dept,
 P.O.  Box  45
Sicily Island,  La.   71368
Contacted Actg. Fire Chief
AWARE OF EPA
 FIRES RULE

    Yes
     No
     NO-
    Yes
    Yes
    Yes
    Yes
     NO
                                30

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                                                  EXHIBIT B
 NAME/ADDRESS  OF
 DEPARTMENT CONTACTED

 Turkey Creek  Vol.  Fire  Dept,
 P.O.  Box 98
 Turkey Creek,  La.   70585
 Contacted Fire Chief

 Winnfield Fire Dept.
 306 South Abel Street
 Winnfield,  La.   71483
 Contacted Fire Chief

 Winnsboro Fire Dept.
 905 Harvard Street
 Winnsboro,  La.   71295
 Contacted Fire Chief

       NEW MEXICO

 Central  Vol.  Fire  Dept.
 P.O.  Box 316
 Central,  NM.   88026
 Contacted Fire Chief

 Columbus Vol.  Fire Dept.
 P.O.  Box 412
 Columbus,  NM.   88029
 Contacted Captain

 Espanola Fire  Dept.
 P.O.  Drawer 37
 Espanola,  NM.   87532
 Contacted Firefighter

 Glenco-Palo Verde  Fire  Dept.
 Star  Route/Coe Ranch
 Glenco,  NM.  88324
 Contacted Fire  Chief

 Loco  Hills  Fire Dept.
 P.O.  Box 56
 Loco  Hills, NM.  88255
 Contacted Fire  Chief

Milan Vol.  Fire Dept.
 P.O.  Box 2727
Milan, NM.  87021
 Contacted Fire  Chief
AWARE OF EPA
 FIRES RULE

     No
    Yes
    Yes
     No
     No
     No
     No
     NO
     No
                                31

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                                                   EXHIBIT B
 NAME/ADDRESS OF                                    AWARE OF EPA
 DEPARTMENT CONTACTED                                FIRES RULE

 San Jon Vol. Fire Dept.                                  No
 P.O. BOX 222
 San Jon, NM.  88434
 Contacted Fire Chief

 Socorro Fire Dept.                                       No
 P.O. Box K
 Socorro, NM.  87801
 Contacted Fire Chief

 Turquoise Trial Vol. Fire                                NO
 Rt. 2,  Box 150M
 Santa Fe, NM. 87505
 Contacted Fire Chief

 Vaughn Vol. Fire Dept.                                   No.
 P.O. Box 278
 Vaughn, NM.  88353
 Contacted Fire Chief

      OKLAHOMA

 Agra Volunteer Fire Dept.                                No
 P.O. Box 222
 Agra,  Ok.  74824
 Contacted-Fire Chief

 Bixby Fire Dept.                                         No
 116 W.  Needles
 Bixby,  Ok.  74008
 Contacted Fire Marshal

 Bluejacket Vol.  Fire Dept.                                No
 P.O.  Box 124
 Bluejacket,  Ok.  74333
 Contacted Member

 Canute  Volunteer Fire Dept.                              No
 P.O.  Box 184
 Canute,  Ok.   73626
 Contacted Firefighter

 Cheyenne Fire Dept.                                       No
.P.O.  Box 532
 Cheyenne,  Ok.  73628
 Contacted Fire Chief
                                32

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     On July 19,  1985, TAO mailed copies of the Final Rule, a
 fact sheet on  the Final Rule, and the Press Release to nearly
 1,000 contacts  including  trade associations,  industry groups,
 utilities, and  national fire  fighter and building associations.
 In  addition, TAO  set  up an informal informational meeting  in the
 early Fall of  1985  to explain the rule.  While this was an
 opportunity for various trade associations, state governments,
 universities,  and fire officials to obtain  information on  the See Append
 rule, the session was not well attended.  In  April of 1986 thejfote 2
 pamphlet "PCS  Transformers and the Risk of Fire - A Guide  for
 Building Owners"  was  sent in  bulk to the EPA  Regional Offices  to
 help facilitate awareness and outreach to commercial building
 owners.  In December of 1986, prior to the publication of  the
 Notice of Interpretation  of Transformer Fire  Regulation  (FR
 December 31, 1986), TAO mailed over. 350 copies to those listed on
 their PCS Comprehensive mailing list a copy of -a pamphlet
 announcing the availability of a videotape explaining the  PCS
 regulations.  This  video  includes the provisions on the PCS
 Transformer Fires Rule.

     Lastly, during the summer and fall of  1985, the peak
 interest time,  the  TSCA Hotline provided guidance to thousands of
 callers concerning  the provisions of the PCS  Transformer Fires
 Rule, and thousands more  have received guidance to date.   While
 this is not outreach per  se,  it is a means  by which  information
 on the rule was and is obtained.

     Your office  found that many small and  volunteer fire
 departments are unaware of the rule, despite  Regional efforts  to
 inform fire response personnel about the rule.  OPTS agrees  it is
 important that all  fire response personnel  including small and
 volunteer departments be  aware of the rule.   It must be  noted,
 however, that  these small and volunteer fire  departments are
 primarily located within  rural areas where  mineral oil
 transformers are  generally in use.  Mineral oil transformers
 generally contain relatively  low concentrations of PCBs, compared
with askarel transformers, therefore, the danger of  high
exposures to PCBs is minimal.  This is one  reason mineral  oil
 transformers, which can be assumed to contain 50-499 ppra PCBs,
are not subject to  the marking requirements or other provisions
of the PCS Transformer Fires  Rule.

     Secondly, the  rule calls for registration  "with fire
 response personnel with primary jurisdiction  {that  is,  the fire
department or brigade which would normally  be called  upon  for  the
 initial response  (emphasis added) to a fire involving  the
equipment."  Reference cited  in 40 CFR 761. 30 (a) (1) (vi) .   If a
 small or volunteer  fire department  is called  to  respond to a fire
where an askarel  transformer  was involved  they would,  in most
cases,  not be the initial response  team.  They would,  most
likely, be assisting  the  initial response  team who  are generally
aware of the PCB  Transformer  Fires Rule and would  take the
necessary precautions when fighting the fire.


                               36      - ---
.
 PPen •

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     OPTS agrees that it is important for owners of PCB
Transformers located in or near a commercial building to register
these units with building owners and fire departments.  The risks
to health and the environment, as well as cleanup costs, in the
event of a fire involving a PCB Transformer are well documented.

     We concur with your suggestion that an automated information
system to record inspection results will assist in determining
whether the registration requirements, as well as phase-out   Sge
requirements of the rule are adhered to.  The function of OTS is #oce 4
to provide technical program guidance.  It is the function of the
Office of Compliance Monitoring  (OCM) to provide compliance
monitoring guidance and their amended Compliance Monitoring
Strategy urges the Regions to obtain registration information
from fire departments in urban areas within their jurisdiction.
The Office of Enforcement and Compliance Monitoring  (OECM) is in
the process of developing an automated system to record  this
registration and inspection information.

     It must be noted that there has been a shift in  focus for Sse APP«nd:l
inspections due to the Administrator's request for a  risk-based Note 5
enforcement strategy.  Inspection resources are being more
closely focused on the disposal process where there  is  an overall
greater risk to health and the environment due to releases of
PCBs from illegal disposal than from violations of the
requirements of the PCB Transformer Fires Rule.

             Plans  to Upgrade OPTS*  Awareness Program

     OPTS is cognizant that public awareness/notification  is  an
agency-wide pjoblem and not unique to  the PCB Transformer  Fires
Rule.  Further, the Agency, because of budget constraints  has
difficulty budgeting follow-up procedures on a continuing
basis.  However, there are some  things  that we could do better
within these budget constraints.  They  include:

          (1)  CRB staff is coordinating with TAO  to place
          articles in pertinent  trade  journals  and magazines
          whose audience is affected  by  the rule,  i.e.  volunteer
          fire departments, building  owners,  insurance companies,
          etc.  In addition, we  hope  to  upgrade  our  current
          mailing lists by adding additional groups  who may be
          affected by the rule.  Meetings  have  been  held with the
          Office of External Affairs'  Community and
          Intergovernmental Relations  Branch  to  meet this end;

          (2)  In the past, civil actions  have  been used as a  See. Append]
          vehicle to initiate  educational  programs.   We would  l
          like to expand the  use of  this mechanism in the future;
                               37

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                                            APPENDIX 1
           (3)  Inspection data compiled by the Regions on an
          automated data  system; as indicated in OCM's draft
          compliance monitoring strategy amendment will help to
          target Fires Rule compliance inspections after October
          of 1990;  .

           (4)  Use asbestos inspectors to inform fire personnel
          about the Transformer Fires Rule;

           (5)  OCM will work with OTS and the Regions to conduct
          an awareness program for commercial building owners as
          well as developing inspector guidance explaining what
          enhanced electrical protection entails; and

           (6)  OPTS plans to use the publication of  the PCS .
          Transformer Fires Rule Amendment  (July 1988) to
          initiate some of the new notification steps mentioned
          above.  We could supplement the planned notification
          package with additional information on other aspects of
          the rule/ i.e. the guide for building owners pamphlet.

     If you have any questions or further suggestions as  to  how
we may improve or implement this plan, please feel  free  to
contact Thomas Simons of my staff at 382-3788.
                                 38

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                                                 APPENDIX 2
           ADDITIONAL PIG COMMENTS TO OPTS' RESPONSE
                      DATED MARCH  3.  1988
The following notes present the  OIG's  response  to  OPTS1
comments which were not addressed in the  body of the  report:
         As pointed out on pages  8  and  9,  each  region
         implemented its own awareness  program  without
         Headquarters guidance on the minimum elements
         necessary for an acceptable program.

         As pointed out on page 13,  neither Region 3
         nor Region 6 distributed the pamphlet  because
         they were- (1)  not sure who it  should be distri-
         buted to and (2) involved in other work.

         Some of the fire departments who indicated that
         they were unaware of the Rule  are not  located  in
         rural areas.  For example,  fire departments in
         Pittsburgh,  Pennsylvania;  Ocean City,  Maryland, and
         Santa Fe, New Mexico were among those  who told us
         that they were net aware of the Rule.

         We were concerned that OCM's 1986 strategy only urged
         the regions to obtain the information.  As discussed
         on page 20,  we believe that using registration informa-
         tion to select facilities to inspect will improve the
         Agency's inspection program.

         Reference to the "Office of Enforcement and Compliance
         Monitoring" should read the "Office of Compliance
         Monitoring."

         As discussed in the note above, we believe that
         registration information will  assist the Agency in
         inspecting other than disposal facilities.  If
         inspection resources continue to be directed to
         disposal facilities, it becomes even more important
         to conduct an effective awareness program to promote
         compliance with the Rule's requirements.

         The Assistant Administrator is describing a situation
         that allows an inspected company to either eliminate
         or reduce a fine from a PCB related inspection.  In
         turn, the company promises to conduct an education
         program in the community; for example, on the  risks
         posed by PCBs to health and the environment.
                               39

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                                                  APPENDIX 3
                          DISTRIBUTION


Associate Administrator  for Regional
  Operations  (A-101)

Comptroller  (PM-225)

Agency Followup Official
  Attn:  Resource Management Staff  (PM-208)

Regional Administrators

Director, Office of Public Affairs  (A-107)

Director, Office of Compliance Monitoring
  OPTS (EN-342)

Director, Office of Toxic Substances  (TS-792)

Director, TSCA Assistance Office  (TS-798)

Director, Exposure Evaluation Division  (TS-798)

Chief, Chemical Regulation Branch  (TS-798)
                               40

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