Environmental Compliance: DOD Needs to Better Identify and Monitor
Equipment Containing Polychlorinated Biphenyls (Chapter Report, 08/24/94,
GAO/NSIAD-94-243).
From 1929 to 1975, an estimated 1.4 billion pounds of polychlorinated
biphenyls (PCB) were produced in the United States. The military
services have significant amounts of PCBs in equipment, such as
electrical transformers and capacitors, on their installations. However,
because the Defense Department (DOD) has not provided specific guidance
on the identification and replacement of PCB items, each service has
been free to establish its own program. Accordingly, service efforts to
identify and replace PCB items vary considerably. More than 15 years
after enactment of the Toxic Substances Control Act, which cited PCBs as
a threat to human health ad restricted the manufacturer to items
containing this substance, some military installations are still not
meeting Environmental Protection Agency (EPA) regulations on monitoring,
storing, and disposing of PCB items. GAO found (1) improper storage of
PCB items, (2) transformers with previously undetected leaks, (3)
inadequate monitoring of known PCB items, (4) slow responses to PCB
spills, and (5) inadequate or incomplete documentation for PCB
disposals. Although EPA periodically inspects some installations, the
correction of deficiencies was basically left to the individual
installation, and some had been slow to begin and complete corrective
action.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: NSIAD-94-243
TITLE: Environmental Compliance: DOD Needs to Better Identify and
Monitor Equipment Containing Polychlorinated
Biphenyls
DATE: 08/24/94
SUBJECT: Noncompliance
Toxic substances
Hazardous substances
Environmental monitoring
Military facilities
Environmental legislation
Equipment management
Property and supply management
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Cover
================================================================ COVER
Report to the Chairman, Subcommittee on Environment, Energy, and
Natural Resources, Committee on Government Operations, House of
Representatives
August 1994
ENVIRONMENTAL COMPLIANCE - DOD
NEEDS TO BETTER IDENTIFY AND
MONITOR EQUIPMENT CONTAINING
POLYCHLORINATED BIPHENYLS
GAO/NSIAD-94-243
Environmental Compliance
Abbreviations
=============================================================== ABBREV
DLA - Defense Logistics Agency
DOD - Department of Defense
DRMO - Defense Reutilization and Marketing Office
EPA - Environmental Protection Agency
GAO - General Accounting Office
NEESA - Naval Energy and Environmental Support Activity
OSD - Office of the Secretary of Defense
PCB - Polychlorinated Biphenyl
PPM - parts per million
Letter
=============================================================== LETTER
B-257944
August 24, 1994
The Honorable Mike Synar
Chairman, Subcommittee on Environment,
Energy, and Natural Resources
Committee on Government Operations
House of Representatives
Dear Mr. Chairman:
This report was prepared in response to your request that we review
how the Department of Defense manages polychlorinated biphenyl (PCB)
equipment at its installations. The Toxic Substances Control Act
cited PCBs as a threat to human health and restricted the manufacture
and use of equipment containing it.
Unless you publicly announce its contents earlier, we plan no further
distribution of this report until 30 days after its issue date. At
this time, we will send copies to the Secretaries of Defense, the
Army, the Navy, and the Air Force. Copies will also be made
available to other interested parties on request.
If you or your staff have any questions concerning this report,
please call me on (202) 512-8412. Major contributors to this report
are listed in appendix I.
Sincerely yours,
Donna M. Heivilin
Director, Defense Management and
NASA Issues
EXECUTIVE SUMMARY
============================================================ Chapter 0
PURPOSE
---------------------------------------------------------- Chapter 0:1
From 1929 to 1975 an estimated 1.4 billion pounds of polychlorinated
biphenyls (PCB) were produced in the United States. The 1976 Toxic
Substances Control Act specifically cited PCBs as a threat to human
health and restricted the manufacture and use of equipment containing
this substance. The military services have significant quantities of
PCBs in equipment such as electrical transformers and capacitors on
their installations.
At the request of the Chairman of the Subcommittee on Environment,
Energy, and Natural Resources, House Committee on Government
Operations, GAO assessed the Department of Defense's (DOD) efforts to
identify, replace, monitor, store, and dispose of equipment
containing PCBs.
BACKGROUND
---------------------------------------------------------- Chapter 0:2
PCBs are a class of organic chemical compounds that are nonflammable
and can conduct heat without conducting electricity. PCBs are used
primarily in electrical equipment and heat transfer systems. If
released into the environment, PCBs tend to persist and are
considered a chronic toxic hazard since they are readily absorbed and
retained in human and animal tissues. Short-term exposure to PCBs
may cause skin problems and long-term exposure may cause liver damage
or impairment of the nervous system. PCB exposure has also caused
reproductive problems and cancer in animals.
The Environmental Protection Agency (EPA) issued regulations pursuant
to the act that generally allow the continued use of PCB items
already in service, and provide specific storage and disposal
requirements for items removed from service and specific monitoring
requirements for known PCB items still in use. Federal executive
agencies, including DOD, must comply with the act and the EPA
regulations. DOD has not provided specific implementing guidance to
the services, but has provided general guidance on complying with
legal environmental requirements. The services have individually
issued regulations incorporating the EPA requirements.
DOD also has PCB in electrical equipment located on military
installations located outside of the United States. The EPA
regulations do not apply to U.S. military installations overseas,
but in some cases, the services have incorporated standards from the
EPA regulations in overseas directives. DOD guidance states that
overseas bases should comply with the environmental laws of host
countries and, to the extent practicable, U.S. laws. The policy
guidance provides that a designated executive agent in each country
determine appropriate standards by October 1993 and that Unified
Commanders are to coordinate and maintain oversight of the
implementation of specific directives. This goal was not met and DOD
now expects that the standards will be set by December 1994.
RESULTS IN BRIEF
---------------------------------------------------------- Chapter 0:3
Because DOD has not provided specific guidance on the identification
and replacement of PCB items, each service has been free to establish
its own program. Accordingly, service efforts to identify and
replace PCB items vary considerably. The Air Force and the Navy
implemented identification and replacement programs, but their
inventory data may not be accurate based on GAO's work at Navy and
Air Force installations. In 1991, the Air Force discontinued
collecting detailed inventory information centrally, leaving it up to
the installations to maintain such data. The Army, like the Air
Force, leaves the responsibility for monitoring PCB identification
and replacement to the installations. As with the other services,
similar problems were noted for the Army. Only one of the four
installations GAO visited had a program to identify PCB items. Goals
to become PCB-free through replacement actions also did not exist at
the Army installations.
More than 15 years after the act was enacted, some installations are
still not meeting the EPA regulations regarding monitoring, storing,
and disposing of PCB items. At 12 installations GAO visited in the
United States, 9 were found not to comply with the EPA regulations.
Examples are (1) improper storage of PCB items, (2) transformers with
previously undetected leaks, (3) inadequate monitoring of known PCB
items, (4) slow responses to PCB spills, and (5) incomplete or
missing documentation for PCB disposals. Although EPA periodically
inspected some installations to see if they were complying with PCB
regulations, the correction of deficiencies was basically left to an
individual installation, and some had been slow in initiating and
completing corrective actions.
PRINCIPAL FINDINGS
---------------------------------------------------------- Chapter 0:4
NEED FOR IDENTIFICATION OF
PCB ITEMS
-------------------------------------------------------- Chapter 0:4.1
In the absence of specific EPA or service requirements to identify
all PCB items, many installations did not know how many PCB items are
in use at their specific bases. DOD only tracked the number of
reported PCB-free installations, and the number of notices of
violation under the act. While the Air Force and the Navy either
maintain or have maintained the PCB inventory in greater detail, GAO
found inaccuracies in their counts. The Army has not accumulated a
complete inventory. Three of the four Army installations GAO visited
did not have a complete inventory. The eight Navy and Air Force
installations GAO visited had inventory data but two of them had not
provided current data to the service level.
Service efforts to replace PCB items, in the absence of guidance to
do so, vary considerably. The Air Force implemented a replacement
program in 1986 with a goal of being PCB free of major items by the
end of 1991. The Air Force did not meet this goal and has not
formally established a new date. The Navy implemented its
replacement program in 1990 with a goal to become PCB free of major
items by the year 2003, replacing larger transformers and capacitors
by 1998 and smaller transformers by the year 2003. The Army does not
have a centrally managed replacement program, but their officials
state that the Army was moving toward elimination of PCBs. None of
the four Army installations GAO visited had established programs to
become PCB free.
MONITORING PCB ITEMS
-------------------------------------------------------- Chapter 0:4.2
Some installations did not meet the EPA requirements regarding
monitoring of PCB items. Monitoring helps to ensure that PCB items
do not present a risk to health or the environment. EPA requires
periodic inspections of certain PCB items, notification to fire
departments as to the location of PCB items, labeling of these items,
and prompt clean-up of spills involving PCB fluids. In GAO's review,
8 of 12 installations visited were not complying with one or more of
the EPA requirements. For example, one installation identified a PCB
spill in June 1991, but the transformer was still leaking at the time
of the GAO survey in September 1992.
EPA periodically inspected some DOD installations to see if they were
complying with the EPA regulations but generally relied on the
assurances of the installations that any deficiencies identified are
corrected. GAO found an instance where, despite installation
assurances to EPA, deficiencies were not corrected 3 years later.
STORAGE AND DISPOSAL
-------------------------------------------------------- Chapter 0:4.3
DOD installations also did not meet the EPA regulations regarding
storage and disposal of PCB items removed from service. GAO found
that 5 of 12 installations visited experienced problems in meeting
storage regulations. For instance, the EPA requires PCB equipment,
stored for disposal for over 30 days, to be stored in a facility that
conforms with EPA specifications. GAO found that one installation
had PCB equipment improperly stored in an abandoned building, a
parking lot, and outside an electrical shop for over 30 days. Also,
three other installations GAO visited had PCB storage facilities that
did not meet EPA storage standards. DOD officials stated that budget
constraints have sometimes caused difficulty in modifying facilities,
especially ones that would not be required once PCBs were eliminated.
In addition, EPA requires that installations prepare and maintain
manifests documenting the shipment of PCB items and a certificate of
disposal from the disposal company certifying proper disposal of the
items. Four installations could not provide these documents to
support disposal of PCB items. DOD officials stated that records
might have been obtainable through DOD offices. In another instance,
an installation disposed of transformers, through sales to salvage
operators, based on chlorine screening tests not recognized by EPA as
an acceptable basis for establishing PCB concentration levels.
Retests, using EPA accepted chemical tests, of other transformers
previously categorized as not PCB contaminated by the chlorine tests,
identified 16 transformers with PCB concentrations above acceptable
limits for sale in this manner.
RECOMMENDATIONS
---------------------------------------------------------- Chapter 0:5
To improve military practices regarding the monitoring, storage, and
disposal of PCBs and to insure identified deficiencies are corrected,
GAO recommends that the Secretary of Defense direct the services to
improve regulatory compliance by
requiring all installations to identify and maintain inventories of
major PCB items and
implementing a follow-up program to ensure that deficiencies
identified by EPA and other monitoring organizations are
corrected.
In addition, GAO recommends that the Administrator of EPA
require installations to report on actions being taken to remedy
instances of noncompliance and
improve on the timeliness of its follow-up inspections conducted at
installations.
AGENCY COMMENTS
---------------------------------------------------------- Chapter 0:6
As requested, GAO did not obtain written agency comments on a draft
of this report. GAO discussed the issues in this report with DOD
officials and incorporated their comments where appropriate.
INTRODUCTION
============================================================ Chapter 1
Polychlorinated biphenyls (PCB), a family of organic chemical
compounds, was commonly used as a coolant or lubricant in various
electrical equipment manufactured from the late 1920s until the
mid-1970s. As health hazards associated with PCBs became known,
Congress regulated its use. The Toxic Substances Control Act of 1976
prohibits the manufacture or use of PCBs, but allows the continued
use of some PCB items under certain restrictions. Since 1976,
overall, the Department of Defense's (DOD) PCB usage has decreased,
but many older PCB items, such as electrical transformers, remain in
use. DOD installations still have a significant number of PCB items
in use and are responsible for complying with the act.
PCB USES AND HEALTH HAZARDS
---------------------------------------------------------- Chapter 1:1
PCBs are any of various compounds produced by substituting atoms of
chlorine for atoms of hydrogen in a hydrocarbon called biphenyl.
PCBs are used in a variety of electrical equipment and other
industrial applications because they are nonflammable and can conduct
heat without conducting electricity. They have been produced
industrially since 1929 and have been mainly used as insulators or
heat transfer liquids in electrical equipment such as transformers
and capacitors. PCBs have also been used in paints, adhesives,
caulking compounds, and certain plastics. From 1929 to 1975, an
estimated 1.4 billion pounds of PCBs were produced in the United
States.
Researchers have found that exposure to PCBs can cause serious health
problems. They do not break down quickly in the body or in the
environment. Rather, PCBs accumulate in body tissues and can reach
harmful levels. Short-term exposure to PCBs may cause the
development of skin problems such as chloracne, a skin ailment
similar to acne. Long-term exposure may cause liver damage or
impairment of the nervous system. Where the liver damage has been
severe the exposed person may pass into a coma and die. PCB exposure
has also caused reproductive problems and cancer in animals.
PCB fumes can also be dangerous. Although PCBs are used as a fire
retardant, when heated to decomposition in uncontrolled environments
they emit highly toxic fumes. Thus, transformer fires potentially
can be very hazardous.
TOXIC SUBSTANCES CONTROL ACT OF
1976
---------------------------------------------------------- Chapter 1:2
The act (15 U.S.C. 2601-2692), passed in 1976, directs the
Administrator of the Environmental Protection Agency (EPA) to
regulate chemicals that "pose an unreasonable risk of injury to
health and the environment." The act specifically bans the use,
manufacture, processing, and distribution in commerce of PCBs and PCB
items, except in certain limited circumstances. PCBs are the only
chemicals specifically cited in the act.
The act charges EPA with the enforcement of PCB regulations
promulgated under the act. These regulations (40 C.F.R. 761)
generally prohibit the manufacturing of PCBs and the use of PCBs
unless they are totally enclosed. Some PCB items such as
transformers and capacitors were permitted to remain in use for the
remainder of their useful lives, subject to servicing, record
keeping, and inspection conditions. The regulations also require
proper disposal, labeling to indicate PCB content, and spill
containment procedures. Executive Order 12088 of October 13, 1978,
requires federal executive agencies to comply with the act and
implement the EPA regulations.
EPA periodically selects military facilities to check for compliance
with
40 C.F.R. 761 and cites deficiencies. EPA officials said EPA issues
letters of noncompliance for violations, but no fines are levied as
is the practice when violations are found at non-federal facilities.
They further stated that EPA does not follow-up immediately to ensure
violations are corrected but requires a written response describing
corrective actions taken or planned to be taken at federal
facilities.
REQUIREMENTS FOR PCB ITEMS
---------------------------------------------------------- Chapter 1:3
The EPA regulations do not specifically require activities to test to
determine the PCB concentration of fluid in equipment in use. Once
PCB concentrations are identified, EPA requirements for monitoring,
inspecting, storing, and disposing of PCBs vary depending on the PCB
concentration in fluid, which is expressed in parts per million
(ppm). EPA considers fluid or items containing fluid with PCB
concentrations of
500 ppm or more to be PCB,
50 ppm but less than 500 ppm to be PCB contaminated, and
under 50 ppm to be non-PCB.
PCB items (500 ppm or greater) must be monitored when in use. For
example, PCB items must be labeled and listed on an annual log.
Their locations must be reported to local fire departments, and PCB
transformers must be periodically inspected for leaks. PCB items
that are no longer in use must be labeled and may be stored up to l
year in a building that meets certain standards. The items must be
disposed of in an incinerator or, in certain circumstances, chemical
waste landfill.
The use of PCB-contaminated items (50 ppm but less than 500 ppm) is
not as stringently regulated. Once taken out of use, however,
PCB-contaminated items are subject to storage and disposal
requirements.
Laboratory tests may be used to determine PCB concentrations. For
items not tested, users must assume they are PCB items if the
nameplate indicates the equipment contains PCB fluid, there is any
reason to believe the equipment contained PCB fluid at one time, or
there is no nameplate on the equipment. Generally, untested items
that do not meet the above conditions must be assumed to be PCB
contaminated.
PCB spills must be contained and cleaned up according to approved
disposal methods. The cleanup must begin within 48 hours after a
spill is discovered. In addition to the environmental hazard they
create, PCB spills are expensive to clean up because of training and
labor costs, testing requirements, and disposal expenses.
Currently, the EPA regulations only specifically address those PCBs
found in electrical equipment. An EPA official said EPA is
considering rules to address other PCB uses, such as in adhesives,
insulation, and paint. However, this official said the uses of PCBs
in manners other than in electrical equipment generally present less
of a risk to health and the environment than those PCBs found in
dielectric fluid.
USE OF PCBS IN DOD
---------------------------------------------------------- Chapter 1:4
Military installations have thousands of electrical transformers and
other electrical equipment that either contain or are suspected to
contain PCBs. The Secretary of Defense has not issued any PCB
guidance to the military services and does not maintain DOD-wide
statistics. The Air Force fiscal year 1990 inventory indicates 4,904
PCB and PCB-contaminated transformers were in service at Air Force
installations.\1
Calendar year 1993 Navy inventory shows a total of 6,461 PCB items
were in use or in storage, including 4,600 transformers. This total
is a reduction from the 1992 data showing 6,984, including 4,891
transformers. The Army does not collect service-wide inventory data.
--------------------
\1 Air Force headquarters no longer has reporting requirements for
such information.
OBJECTIVES, SCOPE, AND
METHODOLOGY
---------------------------------------------------------- Chapter 1:5
The Chairman of the Subcommittee on Environment, Energy, and Natural
Resources, House Committee on Government Operations, asked that we
review DOD's efforts to identify, replace, monitor, store, and
dispose of equipment containing PCBs.
To meet these objectives, we interviewed the Office of the Secretary
of Defense (OSD), Army, Navy, and Air Force officials responsible for
environmental matters, and discussed policy, guidance, and programs
concerning PCBs that they have given to their installations.
We reviewed 40 CFR 761 of the EPA regulations and discussed EPA
interpretation of the act with EPA headquarters and the Southeast and
Southwest Regional EPA offices.
To determine how military installations had implemented relevant
policy and guidance, we visited sites in all three services that have
a variety of missions. At the following sites, we reviewed
installation records on tests, inventory, monitoring, and disposals;
inspected transformers in use; and examined storage facilities:
Redstone Arsenal, Alabama;
Anniston Depot, Alabama;
Fort Ord, California;
Fort Belvoir, Virginia;
Robins Air Force Base, Georgia;
Eglin Air Force Base, Florida;
Andrews Air Force Base, Maryland;
George Air Force Base, California;
Long Beach Naval Shipyard, California;
Charleston Naval Weapons Station, South Carolina;
Philadelphia Naval Shipyard, Pennsylvania; and
Camp Pendleton, California.
We supplemented our review with information gathered during a similar
review conducted earlier at the following DOD locations in Hawaii:
Bellows Air Force Base,
Fort Shafter,
Hickam Air Force Station, and
Pearl Harbor Naval Shipyard.
These installations are included as case examples in our report but
are not included in the 12 installations cited as meeting or failing
to meet the EPA regulations.
We conducted our review from August 1992 to February 1993 and updated
selected data in May 1993 and July 1994 in accordance with generally
accepted government auditing standards. As requested, we did not
obtain written comments on a draft of this report. However, we
discussed our preliminary work with responsible military officials
and incorporated their comments where appropriate.
LIMITED DATA ON MAJOR PCB ITEMS AT
DOD INSTALLATIONS
============================================================ Chapter 2
In the absence of specific EPA requirements, OSD has not implemented
a Defense-wide program to identify and replace PCB items. OSD leaves
the implementation of the Toxic Substances Control Act to the
individual services and identifies only the number of reported
PCB-free installations. Although the Air Force and the Navy, on
their own initiative, have instituted programs to identify and/or
replace major PCB items, their inventory data were not always
accurate. Air Force headquarters no longer maintains a centralized
inventory of PCB items. The Army headquarters does not collect
servicewide PCB inventory data.
NO SPECIFIC EPA REQUIREMENTS TO
IDENTIFY AND REPLACE PCB ITEMS
---------------------------------------------------------- Chapter 2:1
Although the EPA regulations established in response to the act set
standards for monitoring, storing, and disposing of PCB items, these
regulations do not specifically require organizations to identify and
replace PCB items. An EPA official said the regulations "indirectly"
require the identification of PCB items since they set standards for
monitoring PCB items and items cannot be monitored unless they are
identified. The official also said that not inspecting all equipment
to identify PCB items is not a violation of the act, but if an EPA
inspector found a PCB item that had not been identified, and thus,
not properly monitored, this would constitute a violation.
The act allows the continued use of PCB items in service. The act
provides specific monitoring requirements for these items while in
service and storage and disposal requirements after such items are
removed from service.
NO DOD PROGRAM TO IDENTIFY AND
REPLACE PCB ITEMS
---------------------------------------------------------- Chapter 2:2
In the absence of specific EPA requirements, OSD does not require
inspection or testing of in-use equipment to identify PCB items, nor
did it require reporting or replacement of PCB items identified.
Currently, DOD has no regulations nor directives concerning PCBs
although an environmental official said that DOD will be issuing a
general environmental directive, which will include PCBs, on
protection and enhancement of environmental quality by the end of
1994.
Although DOD maintains no data on the number and type of PCB items at
its installations, a DOD official said DOD does track the number of
installations that are free of major PCB items. This official said
that DOD stopped collecting other quantified data in 1988 due to
questions as to the accuracy of the information supplied by the
installations.
IDENTIFICATION AND REPLACEMENT
OF PCB ITEMS VARIED AMONG
SERVICES
---------------------------------------------------------- Chapter 2:3
The Air Force and the Navy, on their own initiative, maintained and
regularly updated PCB inventory databases of individual
installations. The Air Force stopped maintaining a centralized
inventory database after fiscal year 1990. The Army, like the Air
Force, only maintains PCB inventory information at the installation
level.
NAVY TESTING AND TRACKING OF
PCB ITEMS
-------------------------------------------------------- Chapter 2:3.1
The Navy instituted a policy in 1990 to be free of all PCB
transformers and PCB large capacitors by October 1998 and free of all
PCB-contaminated transformers by October 2003. As a part of this
initiative, the Navy directed all Navy and Marine Corps installations
to test and record the PCB concentration for all pad and pole mounted
transformers. As part of this program, the Navy attempts to track
PCB, PCB contaminated, and unknown transformers, capacitors, and
dielectric fluid for each installation for each calendar year. This
tracking system includes PCB items in use, stored, or disposed of.
Navy and Marine installations annually report PCB information to the
Naval Facilities Engineering Service Center, which compiles an annual
servicewide inventory. The Center tasks each installation to update
its prior year PCB inventory by annotating known changes and
forwarding the revised inventory. It relies primarily on the data
submitted by the facilities without much verification, according to
Navy officials.
The Navy's inventory showed 6,067 PCB items in use at the end of
1993, down from 6,572 in 1992 and 8,749 in 1991. The above totals
included
4,256 transformers and 603 capacitors in 1993, 4,555 transformers and
745 capacitors in 1992, and 6,163 transformers and 1,672 capacitors
in 1991. The Navy disposed of 375 transformers and 102 capacitors in
1993,
834 transformers and 499 capacitors in 1992, and 2,174 transformers
and
2,787 capacitors in 1991. The Navy had an additional 394 items in
storage for disposal or reuse in 1993, 412 items in storage for
disposal or reuse in 1992, and 1,361 items in storage for disposal or
reuse in 1991. The Navy estimated in 1993 that 37 percent of its
transformers were yet to be tested to determine PCB status. The
estimate in 1992 was 32 percent and 66 percent in 1991.
All four Navy and Marine Corps sites we visited had completed testing
of their transformers. However, one installation, Charleston Naval
Weapons Station, had not reported PCB items identified as needed by
the Center, known then as the Naval Energy and Environmental Support
Activity (NEESA), for accurate inventory update data. Contracted
laboratory test results showed the installation had 35 PCB
transformers and 76 PCB- contaminated transformers in use at the end
of 1991. However, the Navy inventory data showed that the Charleston
Naval Weapons Station had 23 PCB transformers and no PCB-contaminated
transformers in use. An installation official recently stated that
for fiscal year 1993, the number of PCB transformers was 35 and the
number of PCB-contaminated transformers in use was 25.
In 1991, the Center, known then as NEESA, noted discrepancies in
their 1991 inventory compilation. According to information provided
to them by Navy and Marine Corps installations, 670 items were stored
for disposal at the end of 1990, but only 388 items were accounted
for by disposal or storage at the end of 1991. In comparison to
1991, the number was 293 items in 1992 and 392 items in 1993. Our
analysis of the inventory data over the last 5 years revealed similar
discrepancies. An official at the Center indicated that recent
inventory reports reflect the Navy's continued efforts to improve the
accuracy of the data.
AIR FORCE IS IDENTIFYING AND
REPLACING PCB ITEMS
-------------------------------------------------------- Chapter 2:3.2
Before fiscal year 1991, the Air Force required its installations to
test for PCBs and provide an updated status of PCB and
PCB-contaminated equipment each year. Each Air Force installation
provided information about PCB equipment in use that contains less
than 49 ppm, between
49 ppm and 499 ppm, and those 500 ppm and over as well as an
estimated date to be PCB free at each installation. Air Force
headquarters also asked installations to report the number of other
PCB equipment in use as well as the number of PCB suspected items yet
to be tested. Currently, item management is the responsibility of
the installations.
The Air Force originally established a goal to be PCB free of all
major PCB items by fiscal year 1991. They did not meet this goal,
but have continued their identification program. Air Force
environmental officials say being PCB free is still their objective,
although no new deadline has been set. The four Air Force
installations we visited had tested all their transformers, but only
one installation had removed all its PCB equipment in accordance with
the Air Force's objective.
According to their fiscal year 1990 inventory, the Air Force had
1,042 PCB transformers over 500 ppm, an additional 3,862
PCB-contaminated transformers over 50 ppm, and 2,599 other PCB items.
Additionally, the Air Force identified 2,780 items suspected to
contain PCBs that require testing.
The Air Force relied on information provided by its individual
installations to update its PCB inventory databases. However, we
noted that the Air Force compilation had inaccurate information for
one of the four Air Force installations we visited. This inventory
showed Eglin Air Force Base with no PCB equipment in use in 1990, but
we found Eglin had 14 PCB items and 16 PCB-contaminated transformers
in use during our visit in September 1992.
In 1991, Air Force headquarters changed from collecting detailed PCB
item information to tracking only the number of PCB items rendered
PCB free or removed. As of calendar year 1992, the Air Force
reported that 70 percent of PCB items had been rendered PCB free or
were removed. In 1994, the Air Force again changed the way PCB data
was tracked. The Air Force now requires its major commands to report
only on how many installations are and are not PCB free and when all
installations assigned to each command will be PCB free. Air Force
statistics show that 142 out of 226 installations were PCB free at
the end of calendar year 1993, or 63 percent. As of the most recent
report, Air Force records indicate that all installations should be
PCB free by the end of 1998. According to Air Force headquarters
officials, the collection of item data was discontinued because the
inventory was constantly going up and down and was hard to track.
Also, officials stated that OSD does not require the services to
report such data. Subsequently, item monitoring and managing has
solely become the responsibility of the installation.
ARMY IDENTIFICATION AND
REPLACEMENT OF PCB ITEMS
-------------------------------------------------------- Chapter 2:3.3
The Army does not require testing of equipment to determine PCB
status, nor has it set a goal to remove PCBs from its installations.
The Army directs its installations to comply with EPA regulations and
to manage their own replacement programs. The Army does not
centrally track detailed PCB data.
In 1991, the Army implemented a tracking system used by the Army
Environmental Center to monitor hazardous waste. Among many types of
hazardous material, the system tracks whether an installation has PCB
equipment in service or in storage, PCB containers, and
PCB-contaminated electrical equipment. However, the system does not
track how many PCB items are at an installation or the number of PCB
ppm are contained in each item. According to the system, the Army
had 17 out of 100 installations that were PCB free in fiscal year
1993. An Army official stated that some installations, predominantly
National Guard and Reserve, did not report. When these installations
are added, the total number of installations would grow to over 200.
In fiscal year 1992, there were 14 out of 91 installations reporting
to be PCB free.
None of the four Army installations we visited had established
programs to become PCB free and three of the four had not tested all
their electrical equipment for PCBs. For example, several hundred
older pole-mounted transformers still in use at the Anniston Army
Depot have not been tested. Similarly, officials at Fort Belvoir and
the Army Missile Command said they have hundreds of transformers that
they have not tested. These officials said that they do not plan to
test the transformers until they are scheduled for replacement.
Only Fort Ord has tested for PCBs and inventoried their transformers,
but questions exist as to the accuracy of the Fort's inventory.
Subsequent laboratory tests found a transformer, thought to contain
less than 1 ppm PCB, to be PCB contaminated. It actually contained
86 ppm. Fort Ord officials agreed that the remaining transformers
need to be accurately inventoried.
An Army official stated that Army guidance on hazardous waste is
under revision and should be issued by the end of 1994. Guidance
changes, regarding PCB items, will address small capacitor
requirements, inventory requirements, and requiring the installation
commander to sign the PCB annual report. According to the official,
one of the most significant changes will be that equipment containing
PCBs must be labeled, and that oil filled equipment without records
or manufacturers label stating "No PCBs" will be treated as
containing PCBs above 500 ppm until analyzed. The official said such
a change should increase testing of equipment and enhance program
management.
WEAKNESSES IN MONITORING AND
CORRECTIVE ACTIONS
============================================================ Chapter 3
Over half of the installations we visited did not comply with one or
more of the EPA requirements for monitoring PCB items and correcting
PCB spills discovered through this monitoring. This lack of
attention to regulations, designed to minimize risk to health and the
environment, unduly increases the risks of PCB contamination and the
potential harmful health effects.
PERIODIC INSPECTIONS NOT
PERFORMED
---------------------------------------------------------- Chapter 3:1
Military installations were not consistently performing or
documenting periodic inspections of PCB items as required by EPA.
The EPA regulations allow the continued use of PCB items, but require
periodic inspections of such items so that leaks or ruptures may be
discovered and repaired on a timely basis. These inspections must be
documented. However, at five installations, such inspections were
either not being done or were not documented.
Not properly monitoring known PCB items increases the health risks
since PCB leaks may go undetected for long periods. EPA cited two
installations in 1988 for not keeping required inspection records.
These installations still lacked the records at the time of our
visits in 1992. For example, Fort Ord was cited in 1988 by EPA for
failure to prepare required inspection reports. Despite assurances
to EPA that the problem was corrected, the installation still did not
have inspection reports for any year when we visited the site in
October 1992.
In addition, George Air Force Base was not performing PCB inspections
when we visited in September 1992. Officials said that quarterly
inspections had been done up until the installation began support of
Operations Desert Shield and Storm. As demonstrated in the following
section, some military installations had ruptured equipment leaking
PCB fluids for extended periods of time.
LACK OF TIMELY CORRECTIVE
ACTIONS TO REMEDY PCB LEAKS
---------------------------------------------------------- Chapter 3:2
At four sites we visited, we found leaking PCB transformers that had
not been properly repaired or replaced as the EPA regulations
require. At three of the installations, officials had attempted to
contain the leak, but then did not repair or replace the transformer
and failed to monitor it for further seepage. At one installation,
officials had not taken corrective actions to abate a leak reported
months earlier by a contractor testing for PCB contamination.
If a PCB transformer is found to have a leak, EPA requires that the
transformer be repaired or replaced to eliminate the source of the
leak. Cleanup of the released PCBs must be initiated no later than
48 hours after its discovery, and any leaking material must be
cleaned up and properly disposed of in accordance with the EPA
regulations. Once a leak is discovered, the transformer must be
inspected daily to verify that the leak has been contained until the
transformer is repaired or removed.
At Eglin Air Force Base we found a PCB transformer leaking PCB fluid.
According to installation officials, the pad-mounted transformer,
located in the occupied section of a radar site behind an occupied
building, was identified as leaking about June 1991. The transformer
was still in service and still leaking PCBs at the time of our
initial visit in September 1992 even though at least one cleanup had
already been performed. The containment booms were saturated, and
fluid was running off the cement transformer pad onto the surrounding
gravel. According to the inventory list, the transformer originally
contained 830 gallons of 355,000 ppm PCB fluid. Eglin officials
awarded a contract to replace the transformer in May 1992 but,
according to the officials, the contractor refused to begin work
because of the PCB contamination in the soil surrounding the
transformer. At the time of our follow-up visit in February 1993,
the transformer had not been replaced. The contract for replacement
was still being negotiated. Eglin officials said that, after the
transformer is replaced, another contract would be awarded to assess
and clean up the site. According to an installation official, the
transformer was removed and replaced; however, substantiating
paperwork was unavailable.
Eglin Air Force Base also identified a PCB spill in 1984, but did not
take soil samples until 1986 and did not excavate the site until
1988. The last soil samples were taken from the site in 1990, and it
was still an open case when we visited in September 1992. Eglin has
submitted data to EPA requesting, based on clean-up work and tests
done to date, that the site be declared safe and the case closed.
The current EPA clean-up requirements do not apply to this spill
because it occurred before May 1987. However,
8 years would seem to be an unacceptable response time.
At the Charleston Naval Weapons Station, our installation inspection
revealed one leaking PCB transformer in the officer housing area.
Even though the EPA regulations require periodic inspections of PCB
transformers, this transformer was not on the station's list of
transformers to be inspected. It was identified by a contractor,
hired to test transformers for PCBs, approximately 6 months before
our visit. The pad-mounted PCB transformer was leaking at its posts,
and fluid ran down the front of the transformer and into the gravel
base. It originally contained 88.6 gallons of 1,210 ppm PCB fluid.
The station replaced the transformer and, according to descriptions
provided by an environmental official, cleaned up the spill site in
accordance with the EPA regulations.
At Fort Shafter, two of the five transformers we inspected were
leaking. Both had drip pans to contain the seepage, but one had an
additional leak that was dripping directly onto the concrete floor of
an electrical vault. The transformer, which contained a highly
concentrated PCB fluid, was located in the headquarters building of
the U.S. Army, Pacific Command. Similarly, we found two leaking PCB
transformers at Andrews Air Force Base. These leaks were being
contained by drip pans filled with absorbent material.
FAILURE TO NOTIFY FIRE
DEPARTMENTS OF PCB SITES
---------------------------------------------------------- Chapter 3:3
Although the EPA regulations require installations to notify fire
departments of PCB locations, four installations we surveyed had not
done so. Not notifying fire department personnel of potential PCB
locations unnecessarily increases the health risks to both emergency
personnel and the environment.
When PCBs are burned in an uncontrolled situation they emit highly
toxic fumes. This factor, along with the other potential health
hazards associated with PCBs, resulted in the EPA requirement that
PCB transformers must be registered with fire response personnel in
writing within 30 days of discovery. This registration includes the
location of the PCB transformers, the principal PCB fluid in the
transformer, and the name and telephone number of the person to
contact in the event of a fire. If a PCB transformer is involved in
a fire-related incident, the incident must be immediately reported to
the National Response Center in Washington, D.C.
We found four installations that had identified PCB transformers but
had not notified the fire department within the allotted time frame.
Fort Belvoir's fire station received its first inventory of the
Fort's known PCB equipment the day prior to our visit. The
Charleston Naval Weapons Station identified 13 PCB transformers in
February 1992, but did not notify the fire department until our visit
in September 1992. We found similar situations at Andrews Air Force
Base and the Long Beach Naval Shipyard.
INSTALLATIONS GENERALLY HAD
ADEQUATE LABELING
---------------------------------------------------------- Chapter 3:4
Installations generally complied with the EPA requirements for PCB
warning labels on all identified PCB containers, PCB transformers,
other PCB equipment, and access areas. However, four of the
installations had not labeled PCB storage areas and doors, fences,
hallways, or other means of access to PCB transformers.
The Long Beach Naval Shipyard did not mark a PCB storage facility and
means of access to five PCB transformers. Andrews Air Force Base,
Fort Shafter, and Fort Belvoir also did not have all accesses to PCB
transformers marked.
ACCURATE ANNUAL REPORTS NOT
ALWAYS PREPARED
---------------------------------------------------------- Chapter 3:5
EPA requires maintenance of an annual report that lists all
identified PCB equipment in use, stored for disposal, and disposed of
during the year. Our tests of PCB inventory data showed that 6 of
the 12 installations had incomplete or inaccurate annual reports of
major PCB items in use or storage. Furthermore, EPA had cited two of
our sample sites for not preparing the report at all.
Both George Air Force Base and Fort Belvoir were cited by EPA
previously for not maintaining an annual report. George Air Force
Base was first cited by EPA in 1988 for not having the required
report, then was subsequently cited in 1991 by the Environmental
Compliance and Management Program, a DOD environmental audit team.
In addition, during our visit, Air Force officials could not locate a
copy of the 1990 annual PCB report. EPA cited Fort Belvoir in 1986
for not having annual PCB document reports for 1978 through 1984.
When we visited the base 6 years later, Fort Belvoir officials still
did not have any annual documents.
DOD EXPERIENCING PROBLEMS IN
STORING AND DISPOSING OF PCB ITEMS
============================================================ Chapter 4
Service installations were not complying with EPA established storage
facility requirements, time limits for storage, and documentation
standards for PCB disposal. Not meeting storage standards increases
the risk of harmful spills of PCB fluids and consequently increases
the chances of contaminating water levels. The lack of adequate
documentation for PCB disposals disrupts the accountability trail and
could result in compliance or liability problems if disposals are not
properly accomplished. In addition, one installation sold
transformers without adequate laboratory testing to demonstrate the
absence of PCBs, thereby putting themselves at risk of improper
disposal.
STORAGE FACILITY REQUIREMENTS
NOT ALWAYS MET
---------------------------------------------------------- Chapter 4:1
Three installations we visited were using storage facilities that did
not conform to the EPA requirements. Facilities used to store PCB
items must have adequate roof and walls to prevent rain water from
reaching the stored PCBs and PCB items. The facility floor must be
constructed of continuous smooth and impervious materials and have
continuous curbing for containment with no drains or other openings
that would permit liquids to flow from the curbed area. The facility
and access to the facility must be marked with PCB warnings.
For example, the Anniston Army Depot's facility was properly marked
and had the adequate walls, roof, and the containment curb. However,
the floor of the facility was made of porus concrete with cracks and
holes. According to a depot official, the depot intends to build a
new PCB storage facility that conforms to the EPA requirements.
PCBS REMOVED FROM SERVICE NOT
DISPOSED OF WITHIN REQUIRED
TIME FRAMES
---------------------------------------------------------- Chapter 4:2
Three of the sites we visited had PCB items in storage longer than
the EPA regulations allow. EPA requires that any PCB article or PCB
container that is stored for disposal must be removed from storage
and disposed of within
1 year from when it was first placed into storage. EPA also
specifies that certain PCB items may be stored temporarily, for up to
30 days, in an area that does not comply with the PCB facility
requirements.
At the Charleston storage area, two PCB transformers were stored
outside their hazardous waste building in a nonconforming area for
more than the allowed 30 days. Each of the transformers contained
178 gallons of PCB fluid. These transformers were shipped out for
disposal after our visit.
Camp Pendleton had a PCB transformer with 230 gallons of PCB fluid
stored for over 120 days outside of its PCB storage facility.
Officials stated that the transformer was too large to fit into the
facility.
Eglin Air Force Base had a number of storage violations when we
visited. Although the Eglin site has a complying PCB storage area,
officials said it is too small to accommodate larger capacitors or
transformers. As a result, the base stores its PCB and
PCB-contaminated items on an asphalt surface outside of their
electrical shop where there is no spill containment, no walls or roof
to keep off the rain, and no limited access. The EPA regulations
require removal of material from this area within 30 days of its
removal from service. However, when we visited the installation in
September 1992, 6 of the 13 items stored in the area had been removed
from service for over 30 days. These items were shipped out in
October 1992.
Also at Eglin, we found 2 rectifiers containing 278 gallons of highly
concentrated PCB fluid stored in an abandoned building with porous
floors, no spill containment, and unlocked doors. Officials could
not tell us how long the equipment had been there, but one official
said that it could have been in storage for over 10 years. At the
time of our follow-up visit in February 1993, about 5 months after
our initial visit, the rectifiers were still stored in the same place
and had not been added to the list of items to be periodically
inspected. An installation official stated that the rectifiers were
removed in December 1993.
In addition, at Eglin Air Force Base, we found seven barrels marked
with the PCB warning labels stored in a parking lot behind an
occupied building. Officials said that these barrels contain soil
that had been excavated from a spill and although they could not
provide us with the exact date, they said that the barrels were
placed in the parking lot anywhere from
3 months to 12 months prior to our visit. These barrels were shipped
out for disposal in October 1992.
LACK OF REQUIRED DOCUMENTATION
FOR PCB DISPOSALS
---------------------------------------------------------- Chapter 4:3
In an effort to maintain accountability for PCB items, EPA requires
documentation for all PCB items disposed of by an installation. This
documentation includes a manifest that describes the PCB waste, an
identification number, and the designated disposal facility. The
installation should then receive a certification from the disposal
facility certifying proper disposition of the PCB waste. Fort Ord,
Fort Shafter, Long Beach Naval Shipyard, and Marine Camp Pendleton
did not maintain this PCB disposal documentation. However, DOD
officials stated that the documentation may have been maintained by
the Defense Logistics Agency (DLA).
Fort Ord officials told us that delivery orders, manifests, tests,
and certificates of disposal go to the west regional Defense
Reutilization and Marketing Office (DRMO). EPA requires
installations that generate PCB waste to maintain records on site
documenting disposal of such items. However, DOD officials stated
that in PCB removed under DLA contracts, records would be available
through DLA.
Long Beach Naval Shipyard officials said that their facility was in
the process of streamlining its record keeping process. Similarly,
officials at Camp Pendleton, California, could provide complete
disposal documentation for only one PCB transformer. No other
information was available, according to representatives, because of
inaccurate data in their automated system that made it impossible to
trace all other PCB items to disposal documentation.
ITEMS DISPOSED OF WITHOUT
LABORATORY TESTS
---------------------------------------------------------- Chapter 4:4
The Missile Command at Redstone Arsenal was not using the testing
method DRMO now requires--a gas chromatography test, which is the
minimum acceptable method EPA has approved for determining the
concentration and nature of PCBs in oil. Instead, Redstone was using
a total chlorine field test that the local DRMO had previously
accepted. EPA has found such chlorine field tests to yield an
unacceptable number of false negatives, thus, not detecting some
items that actually contain PCBs.
In 1991, the Missile Command, as part of a total electric grid
changeout, removed over 300 transformers from service. They tested
these transformers using the chlorine test and turned them into the
local DRMO for disposal. DRMO sold about 290 of these transformers,
certified non-PCB by the chlorine test, to the general public.
Subsequently, DRMO learned that the chlorine test is not acceptable
because it sometimes yields false negatives. An EPA official said
the Missile Command could be held legally liable if any of the
transformers sold actually contained PCB fluid.
During our initial visit to Redstone Arsenal in July 1992, the
Missile Command had a second batch of 281 transformers awaiting
disposal. The transformers had been tested by a chlorine screening
method, as standard practice at the Arsenal at that time, and labeled
either non-PCB or PCB as the screening results indicated. However,
when these transformers were retested using the gas chromatography
method, 16 of the transformers identified as non-PCB were actually
PCB and PCB contaminated.
Missile Command environmental officials contend that the errors in
mislabeling this batch of transformers were the result of poor
quality control in the documentation by the testing subcontractor and
not in the testing method. Missile Command officials found errors in
the paperwork, such as incorrect manufacturer and incorrect serial
numbers, that lead them to believe that this particular batch of
transformers was incorrectly labeled.
Missile Command officials believe that transformers disposed of prior
to this batch were accurately tested because the installation's
chemist performed the screening. According to these officials, the
chemist has been doing these analyses for 35 years. The chemist
believes that the government screening of PCBs at Redstone Arsenal
has been accurate and correct. However, Missile Command officials
stated that all future disposals will be certified using the gas
chromatography method.
CONCLUSIONS AND RECOMMENDATIONS
============================================================ Chapter 5
CONCLUSIONS
---------------------------------------------------------- Chapter 5:1
Neither EPA nor DOD specifically require that services identify PCB
items still in use, but we believe such identification is essential
to ensure protection of health and environment. All of the services
identify their items containing PCBs, either at the headquarters or
installation level. While their identification efforts have been
marred by some discrepancies in reporting inventories to the
headquarters, each individual installation has a listing of PCB items
that require monitoring and other special treatment to comply with
the EPA regulations.
Although the Toxic Substances Control Act has been in existence for
more than 15 years, DOD installations are still not meeting the EPA
requirements regarding monitoring, storing, labeling, and disposing
of PCB items. In some cases, installations have not corrected
problems even when cited by EPA or other monitoring agencies for
violations, such as not performing periodic inspections or not
cleaning up spilled PCB material. Although EPA does require
installations to report what actions are being taken to remedy any
instances of noncompliance, some of these problems have not been
corrected years after the fact, in part, because neither EPA nor DOD
conduct timely follow-up inspections.
RECOMMENDATIONS
---------------------------------------------------------- Chapter 5:2
In view of the frequent lapses in identification, labeling,
monitoring, storage, and disposal of PCBs, and the instances where
identified problems had not been corrected even years after the fact,
we recommend that the Secretary of Defense direct the military
services to fully comply with the Toxic Substances Control Act and
the EPA regulations by
requiring all installations to identify and maintain inventories of
major PCB items and
implementing a follow-up program to ensure that deficiencies
identified by EPA and other monitoring organizations are
corrected.
In addition, we recommend that the Administrator of EPA
require installations to report on actions being taken to remedy
instances of noncompliance and
improve on the timeliness of its follow-up inspections conducted at
installations.
MAJOR CONTRIBUTORS TO THIS REPORT
=========================================================== Appendix I
NATIONAL SECURITY AND
INTERNATIONAL AFFAIRS DIVISION,
WASHINGTON, D.C.
David Warren
Uldis Adamsons
ATLANTA REGIONAL OFFICE
Bob Crowl
Don Howard
David Schechter
LOS ANGELES REGIONAL OFFICE
Sam Van Wagner
James Bancroft
DALLAS REGIONAL OFFICE
C. F. Harlow
Jim Viola