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APPENDIX C PCB MANAGEMENT PLAN • Henderson Mill has a significant amount of PCB contaminated oil contained in transformers and large capacitors in use at the site. Storage of small quantities of PCBs takes place in the Flammable Materials /Hazardous Waste Storage Building (Figure 2) within an epoxy-coated concrete containment area (capable of holding 1700 gallons of liquid) and on containment pallets. With the current environmental concerns being expressed by go/ernment agencies and regulations from the Environmental Protection Agenc~~ (EPA) a management plan for the control of PCB materials is a necessity. This PCB Management Plan is intended to cover the identification, storage locations, control, decontamination, and disposal of PCB fluids. I. INVENTORY All PCB articles in equipment or in storage at the Henderson project have been inventoried and the inventory is maintained current. The records show all transfers or disposal of PCBs. All areas whr~re PCBs are used are diked and inspected on a quarterly basis. All storage areas are diked and inspected at least once every 30 days. PCES Annual Reports are available from 1978 to the present time. • II. NOTIFICATION OF LEAKAGE OR SPILL Any person observing a transformer or capacitor leaking or rr spill of suspected PCB from any source shall immediately notify tfie boiler operator at the mill site. The on-duty boiler operator shall them notify the Maintenance Superintendent or one of the Maintenance Supervisors. Upon assessment of the leakage or shill, the Maintenance Department representative shall institute the proper decontamination and disposal activities. He shall notify all other parties as necessary. III. MARKING All transformers and capacitors currently in use identify the insulating fluid on the nameplate; in addition, marking labels in accordance with EPA regulations are applied to all equipment containing PCB articles; including Pyranol, Askerel, Inerteen and Insuldor. IV. CONTAINMENT All PCB transformers are enclosed in dikes of either concrete or steel. The capacity of these dikes is such that they will contain 100 percent of the liquid of the transformers inside that dike in accordance with EPA regulations.