addendum to phase i environmental site assessment, · pdf file ·...

Antea USA, Inc.

Prepared for:

Weyerhaeuser NR Company

33663 Weyerhaeuser Way South

Mail Stop CH1J28

Federal Way, Washington 98063-9777

Addendum to Phase I

Environmental Site

Assessment, July 2011


First Street/Main Street

Wright City, Oklahoma

Antea Group Project No. 5E1104037P

August 2011

Prepared by:

Antea™Group 8008 Corporate Drive, Suite 100

Charlotte, NC 28226 USA

i

Table of Contents

1.0 INTRODUCTION.......................................................................................................................................................... 1

2.0 USER-PROVIDED INFORMATION................................................................................................................................ 1

3.0 RECORDS REVIEW RESULTS........................................................................................................................................ 2

4.0 CONCLUSIONS............................................................................................................................................................ 3

Appendices

Supplemental Appendix A Supplemental User-Provided Information

1

Addendum to July 2011 Phase I Environmental

Site Assessment Weyerhaeuser NR Company


1.0 INTRODUCTION

Antea Group (Antea Group) was retained by Weyerhaeuser NR Company (Weyerhaeuser) to conduct a Phase I

Environmental Site Assessment (ESA) of real property located at First Street and Main Street, in Wright City,

Oklahoma (subject property). Site reconnaissance was completed in May 2011, and Antea Group issued the final

Phase I Environmental Site Assessment (ESA) report in July 2011.

During the site reconnaissance, a total of fifteen pole-mounted transformers were observed on raised platforms.

No labels or other information to indicate the PCB status was observed for any of the pole-mounted transformers.

In addition, numerous unlabeled capacitors and dry-type transformers were observed in various buildings at the

subject property. Several large pad-mounted transformers were noted throughout the facility and all were labeled

as ‘certified PCB free’.

Based on correspondence during the preparation of the Phase I ESA report, Weyerhaeuser representatives

reported that a project was initiated in the early 1990s to remove all PCB containing transformers and capacitors

from Weyerhaeuser facilities. For all facilities owned by Weyerhaeuser (legacy facilities), the PCB-containing

transformers and capacitors were removed and replaced with PCB-free equipment. The Wright City facility is a

legacy Weyerhaeuser operation, leading to the conclusion that any unlabeled transformers and capacitors at

Wright Citydid not contain PCBs.

Subsequent to the issuance of the Phase IESA report, Antea Group received additional information from

Weyerhaeuser pertaining to the PCB status at the Wright City facility. Antea Group is issuing this addendum to

clarify the status of the transformers and capacitors currently located onsite.

2.0 USER-PROVIDED INFORMATION

Subsequent to the site visit and issuance of the July 2011 Phase I ESA report, Weyerhaeuser provided Antea Group

with historical transformer and capacitor records dated from 1978 to 1993. These records include:

• Facility inspection and inventory records;

• Hazardous Waste manifests;

Addendum to July 2011 Phase I Environmental Site Assessment



Antea Group Project 5E1104037P

2

• Analytical oil testing reports;

• Certificates of Disposal; and,

• Correspondence regarding site transformers and capacitors.

3.0 RECORDS REVIEW RESULTS

Pertinent information from the records review is presented in Addendum Appendix A and is discussed below.

• List of Transformers, Internal Weyerhaeuser Communication, August 14, 1981

The letter identifies fourteen transformers containing 50 to 500 ppm PCB; forty-five pole-mounted

transformers that have not been tested; twelve transformers that are PCB free; five transformers that contain

less than 50 ppm PCB; and, six transformers that are out of service and contain 50 to 500 ppm PCB.

In addition, the letter states that there are a total of one-hundred nineteen capacitors that are PCB filled;

Eighty-two capacitors are located inside buildings over concrete dikes; twenty-eight capacitors are located

inside buildings and not diked; four capacitors are located near floor drains and are not diked; and, five

capacitors are located outside without dikes.

• Weyerhaeuser Company PCB Annual Document, 1978 through 1991 (handwritten)

The number of capacitors and transformers including the total weight (kg) of PCBs in the transformers were

recorded by hand on paper.

1978 through 1981; ninety-one PCB capacitors and twenty transformers containing 35,547 kg PCB were in

service.

1982; two PCB transformers were removed from service and shipped to ENSCO. Ninety-one PCB capacitors

and eighteen transformers containing 31,987 kg PCB were in service as of the end of December, 1982.

1983 through 1988; ninety-one PCB capacitors and eighteen PCB transformers containing 35,547 kg PCB were

in service.

1989; thirteen PCB capacitors and one PCB transformer were removed from service and shipped to Aptus,

along with 347 gallons of PCB fluids from transformer retrofill. Seventy-eight PCB capacitors and seventeen

transformers containing 30,877 kg PCB were in service as of the end of December, 1989.

1990; thirty-eight PCB capacitors and three PCB transformers were removed from service and shipped to

Aptus, along with 347 gallons of PCB fluids from transformer retrofill. Forty PCB capacitors and fourteen

transformers containing 25,537 kg PCB were in service as of the end of December, 1990.

1991; twenty-eight PCB capacitors and fourteen PCB transformers were removed from service and shipped to

Aptus. Twelve PCB capacitors and no PCB transformers were in service as of the end of December, 1991.

1992; twelve PCB capacitors were removed from service and shipped to Aptus. No PCB capacitors or





3

transformers were located onsite as of the end of December, 1992.

• Weyerhaeuser correspondence to area fire departments, April 11, 1989.

Letter to the Wright City Fire Department, Broken Bow Fire Department, Idabel Fire Department, Valliant Fire

Department, and Lawrence Hall with an attached site layout denoting the approximate locations of PCB

transformers and capacitors. The letter also states that “each outside door has a warning sign in addition to

the warning sign on each contaminated capacitor and transformer”.

• Weyerhaeuser correspondence to area fire departments, July 29, 1993.

Letter to the Wright City Fire Department, Broken Bow Fire Department, Idabel Fire Department, and Phil

Allen stating that the Wright City Wood Products Complex has obtained “PCB free” status as of January 1993.

• Public Service Company of Oklahoma letter to John Turner – WEYCO, June 25, 1999

Letter provides PCB information and concentrations for oil-filled equipment, owned by PSO (Public Service

Company of Oklahoma), and located in the electrical substation at the Wright City facility.

Transformer #1 contained 2.9 ppm Arochlor 1262; Transformer #1 LTC contained 9.5 ppm Arochlor 1242-

1260; Transformer #2 contained 14.7 ppm Arochlor 1260;and, Transformer #2 LTC contained 5.7 ppm Arochlor

1262. Two transformers installed in 1991 and 1992, respectively, were not tested.

The letter also listed “Equipment CCVT” was not tested, but was listed as “compound filled. Has PCB sticker”.

4.0 CONCLUSIONS

Based on a review of the supplemental records, the Wright City facility historically used transformers and

capacitors that contained PCBs. Weyerhaeuser implemented a program to phase-out PCB transformers and

capacitors. From 1982 to 1992, the Wright City facility removed ninety-one PCB capacitors from service for

disposal by Aptus; and removed twenty PCB transformers from service for disposal by Aptus. In addition, four PCB

transformers were retrofilled with non-PCB fluids and the PCB fluid was transported off-site for disposal by Aptus.

Inspection records, maintained by the facility, did not indicate any releases from the PCB transformers or

capacitors. Based on the records reviewed, the capacitors and transformers currently located at the Wright City

facility, and owned by Weyerhaeuser do not contain PCBs.

The letter dated June 25, 1999 from the Public Service Company of Oklahoma (PSO) indicates that four

transformers located in the substation owned by PSO contains <15 ppm PCBs. PCB concentrations less than 50

ppm in transformers are classified per 40 CFR 761.3 as non-PCB transformers; therefore, the PSO substation

transformers are non-PCB and are not an environmental concern to the subject property.





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The June 1999 PSO letter also denoted that equipment identified as CCVT (Coupling Capacitor Voltage

Transformer) with serial # 4K2711 was filled with a ‘compound’ and was labeled with a “PCB sticker”. Access to the

substation was limited during the site reconnaissance and observations were made through the chain-link fence.

However, no labeling was observed in the electrical substation.

Antea Group contacted the Public Service Company of Oklahoma to obtain further information on the status of the

CCVT. Antea Group received a copy of an ‘Equipment Change Order”, dated September 21, 2008, from American

Electric Power (parent company of PSO). The CCVT, serial # 4K2711, containing a PCB compound was replaced by a

mineral oil CCVT on September 21, 2008. The mineral oil CCVT is not an environmental concern to the subject

property.

I declare that, to the best of my professional knowledge and belief, I meet the definition of Environmental

Professional as defined in section 312.10 of 40 Code of Federal Regulations (CFR) 312. I have the specific

qualifications based on education, training and experience to assess a property of the nature, history, and setting

of the subject property. I have developed and performed the all appropriate inquires in conformance with the

standards and practices set forth in 40 CFR Part 312.

Date: 8/23/2011

Katie Theaux

Staff Professional

Reviewed by:

Date: 8/23/2011

Tony Rossano

Project Manager





www.anteagroup.com

Addendum Appendix A

Supplemental User-Provided Information

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