SFUND RECORDS CTR

2257972

• T, UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

xI7 REGION IX

75 Hawthorne Street San Francisco, CA 94105

ACTION MEMORANDUM

DATE: V\M ''i ii ^ ^

SUBJECT: Request for a Time-Critical Removal Action at the Guam Power Authority (GPA) Substation PCB Site

FROM: Michelle Roc Federal Oj/sWfeHe Coordinator (SFD-9-2)

TO: Daniel Meer, Assistant Director Superfund Division (SFD-9)

THRU: Harry L Allen, Chief Emergency Response Section (SFD-9-2)

I. PURPOSE

The purpose of this Action Memorandum is to obtain approval to expend up to $600,000 in direct costs to mitigate threats posed to human health and the environment posed by the presence of polychlorinated biphenyl (PCB) wastes located in transformers being stored at the Guam Power Authority (GPA) Apra Heights and Talofofo Substations and at the Dededo Storage facility in Guam ("the Site"). Guam is a territory ofthe United States. The proposed action is being taken pursuant to Section 104 (a)(1) ofthe Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), as amended, by identifying, containing, and disposing ofthe wastes currently being stored in drums.

II. SITE CONDITIONS AND BACKGROUND

Site Status: Non-NPL Category of Removal: Time-Critical CERCLIS ID: to be assigned SITE ID: 09YL

A. Site Description

1. Removal site evaluation

In March 2012, the Guam Environmental Protection Agency (GEPA) approached EPA with a request for assistance from Guam Power Authority (GPA) regarding transformers at their facilities which had been identified as contaminated with polychlorinated biphenyls (PCBs). In April 2012, the EPA Pacific Islands Office contacted the EPA Region 9 Emergency Response Section (ERS) and requested assistance. GPA had conducted sampling ofthe transformers. Analytical results were provided to EPA and reviewed by ERS.

On April 23, 2012, ERS conducted a site walk ofthe substation locations. Two large transformers, which contained approximately 3000 gallons of oil were observed. Both transformers were leaking from different locations. Each transformer contained two compartments, which contained oil and were sampled by GPA. The results ofthe sampling indicated that 3 ofthe compartments contained off-spec used oil, regulated by RCRA, with PCB concentrations that exceeded 2 mg/kg. One of the

compartments contained PCB oil, regulated under TSCA, with a concentration exceeding 50 mg/kg of PCBs. While the large transformers in Apra Heights and Talofofo were located inside of secondary containment, they were leaking from different locations. While drip pans had been placed underneath some of the leaks, others were being disbursed along the sides of the transformer and could not be contained in one location. The secondary containment areas had oil staining and puddles, and each of the secondary containments were free of water, indicating that they had been drained. Each of the drainage valves discharged into surface soils. It is unknown how long the transformers have been leaking, but GPA has plans to repair the transformers once they are drained of the oil.

After EPA's visit, GPA conducted sampling of additional transformers and of surface soils at the two substations. Results are pending. In addition, there are a number of smaller transformers that contain PCBs and are being stored at the Dededo storage facility. The condition of these transformers is unknown but they are being stored outside and subject to the elements.

On April 23, 2012, the United States Environmental Protection Agency, Region 9 (EPA) received a Request for Federal Action from the Guam Environmental Protection Agency (Attachment 1). The request was for assistance to conduct a removal action to abate the hazards posed by the transformers at the Apra Heights and Talofofo Substations. GEPA has requested assistance for proper treatment and/or disposal of the oil and associated PCB wastes.

2. Physical location

The wastes are currently located in two large transformers, with multiple compartments each and a number of smaller transformers with a single compartment. One of the large transformers is located at the Apra Heights Substation facility and the other is located at the Talofofo Substation facility. The smaller transformers are located at a storage location in Dededo. All of the transformers are stored outside, subject to the weather and elements.

3. Site characteristics

The Site is located in a mixed residential and industrial area. The transformers are located in a fenced, secure area of the site, but outdoors. The transformer areas have secondary containment, but the transformers are actively leaking into their containment areas. The transformers are subject to the harsh island climate conditions such as heat and humidity. The climate is tropical and subject to seasonal typhoons of considerable strength. It is likely that soil around the transformer containment areas is contaminated due to releases from the containment area.

The origin of the electrical equipment which originally contained the PCB oil is unknown. The large transformers were manufactured in 1971. This Action Memorandum takes into account that quantities may be greater than reflected in the current inventory of waste material, as some of the most recent sampling data is still pending.

4. Release or threatened release into the environment of a hazardous substance, or pollutant or contaminant

The transformers have been stored in the open environment, in use for a period of over 40 years. In light of the condition of the various transformers, and the potentially hazardous nature of the waste, this

constitutes an actual and/or threatened release into the environment of a hazardous substance, pollutant or contaminant. The transformers continue to leak and are deteriorating within the Site.

5. National Priority List (NPL) status

This site is not on the NPL.

B. Other Actions to Date

GPA has been conducting an assessment of the oil within their transformers to determine PCB concentrations. Any transformer manufactured before 1979 was tested for PCB concentration, which is

how they identified the PCB concentration of the large transformers. Other small transformers were also tested during this assessment. More test results are pending.

GPA has also collected a few soil samples at the Site and is awaiting the analytical data.

C. Federal. State and Local Authorities's Roles

EPA's Emergency Response Section (ERS) will be supported by the EPA's Pacific Islands Office (PIO) and will work in coordination with GPA and Guam Environmental Protection Agency.

Local authorities do not have the financial or technical resources to repackage, transport and dispose the chemicals off-island as there are no permitted facilities on-island to take the materials. The containers holding these materials will continue to deteriorate over time and release into the environment.

III. THREATS TO PUBLIC HEALTH OR WELFARE OR THE ENVIRONMENT, AND STATUTORY AND REGULATORY AUTHORITIES

A. Threats to Public Health, or Welfare or the Environment

Conditions at the Site present a release, and potential threat of release, of a CERCLA hazardous substance threatening to public health, or welfare, or the environment based upon the factors set forth in the National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40 CFR § 300.415(b)(2). These factors include:

1. Actual or potential exposure to hazardous substances or pollutants or contaminants by nearby populations or the food chain

Transformers containing PCBs above health-based benchmarks have been identified at the Site. The transformers are stored in a contained area, but the containments have valves which drain onto the ground. The 2 largest transformers are leaking from at least one or more locations and the containment area has oil staining and oil puddles in it. The transformers are outside and subject to the elements and with the amount of rainfall in Guam, the secondary containment area has obviously been drained through the containment valve. Excessive heat and humidity, and the location of the transformers, pose an imminent risk to the employees of GPA and the environment.

Polychlorinated biphenyls are manufactured chlorinated compounds which have been used as coolants and lubricants in transformers, capacitors and other electrical equipment because of their insulating properties and high flash point. PCBs do not readily break down in the environment and bioaccumulate in the food chain. PCBs have a tendency to bind with soils, but can also dissolve in water and volatilize into air and migrate over long distances. While the most commonly observed health effects in exposed populations are skin conditions such as acne and rashes, other health effects may include liver and digestive system damage. PCBs are also a probable carcinogen.

These transformers have been leaking for an unknown period of time and have resulted in a release to the environment. Persons working at the Site and others nearby could come into contact with this material through direct contact as well as indirect contract due to migration into the aquatic environment and food sources.

2. Actual or potential contamination of drinking water supplies

No specific contamination of a drinking water supply has been identified to date.

3. Hazardous substances or pollutants or contaminants in drums, barrels, tanks, or other bulk storage containers, that may pose a threat of release

This facility has PCB oils and PCB contaminated oils that are in transformers in poor condition. The large transformers each have 2 compartments and one of the compartments contain PCBs over TSCA regulatory limits. It is likely that soils on Site may be contaminated with PCBs.

4. High levels of hazardous substances or pollutants or contaminants in soils largely at or near the surface, that may migrate

Currently, EPA is awaiting analytical data to determine whether contamination is present in surface soils. If the transformers are to remain on Site and continue to degrade, the PCBs could migrate more into surface soils.

5. Weather conditions that may cause hazardous substances or pollutants or contaminants to migrate or be released

This area is subject to extreme weather conditions and typhoons. If the storage area was to be impacted by heavy rains or a typhoon, the contents ofthe transformers could be released and transported into storm drains that lead to Apra Harbor and the Pacific Ocean. Material contained in these transformers could cause harm to the aquatic environment. The material in the transformers could also wash into the surface soils or storm drains.

6. Threat of fire or explosion

The transformers themselves do not appear pose a threat of fire or explosion, but if a fire occurred in the storage area, first responders may suffer impacts from exposure and material could be released to surface soils and the nearby environment.

7. The availability of other appropriate federal or state response mechanisms to respond to the release

Local authorities do not have the financial or technical resources to repackage, transport and dispose the chemicals off-island. GPA requested assistance from Guam Environmental Protection Agency (GEPA) and GEPA has requested assistance from EPA to address the issue.

IV. ENDANGERMENT DETERMINATION

Actual or threatened releases of hazardous substances from this Site, if not addressed by the response action selected in this Action Memorandum, may present an imminent and substantial endangerment to public health, welfare, or the environment.

V. PROPOSED ACTIONS AND ESTIMATED COSTS

A. Proposed Actions

An assessment has been conducted to confirm the status of the transformers and their conditions. Since the oil is in transformers, the material inside will either have to be transferred into DOT shippable drums or intermodal transportation containers for transport and disposal. Liquids and solids will be packaged separately. If necessary for transport, materials will be sampled, segregated and stabilized.

1. Proposed action description

With the approval of this Action Memo, the physical removal of the material will include pumping out the oil from the transformers, cleaning the insides of the transformers for repair and reuse, segregation and packaging of materials, and transport to the U.S. mainland followed by transportation and treatment and/or disposal of the materials at an approved Treatment, Storage or Disposal Facility (TSDF) or recycling facility. Soil sampling will be performed to determine the extent of soil contamination from the leaking transformers. Some soil removal is anticipated to be performed. While it is anticipated that additional hazardous materials, wastes, or situations may be present and contingency costs have been built into the funding ceiling for this eventuality, if extensive soil contamination is identified, additional funds may be necessary to perform those actions. Because these materials will be shipped over the Pacific Ocean, they must be transported in accordance with international shipping regulations.

2. Contribution to remedial performance

There is no ongoing remedial action at the site.

3. Description of alternative technologies

No alternative technologies are proposed at this time.

4. Applicable or relevant and appropriate requirements (ARARs)

In accordance with 40 C.F.R. § 300.415(1), this removal shall, to the extent practicable considering the exigencies of the situation, attain applicable or relevant and appropriate requirements under federal laws and the environmental laws of Guam.

Federal ARARs: Potential relevant federal ARARs are the provisions of the Resource Conservation and Recovery Act (RCRA), 42 U.S.C. § 6901, et seq., and the corresponding regulations pertaining to the transportation and disposal of hazardous waste, including the land disposal restrictions (LDRs) at 40 CFR Part 268. As some materials being dealt with are likely to be RCRA characteristic and listed wastes, they will be handled accordingly. To the degree materials are sent offsite, wastes will be sent to a RCRA permitted facility and RCRA manifesting requirements will be complied with for all waste streams. Another potentially relevant ARAR is the Toxic Substances Control Act (TSCA), 15 U.S.C. § 2601. et seq. Any TSCA waste will be handled as such and disposed of in accordance with that law and associated regulations.

The materials will be sent to an acceptable RCRA treatment, storage, or disposal facility pursuant to the Off-Site Rule, 40 CFR § 300.440.

If soil excavation is performed, work will be conducted consistent with the Historic Preservation Act.

State ARARs: All state ARARs identified by the appropriate agency in a timely fashion will be complied with to the extent practicable.

6. Project schedule

From the date of an approved Action Memo, approximately six weeks will be required to coordinate this response in Guam, specifically making the logistical arrangements for transportation and staging supplies and equipment. The soil assessment, removal of oil and packaging for transport is expected to last approximately two weeks, and transportation to the US mainland could take up to eight weeks. Soil removal work may take up to four months, if necessary. Therefore the total project schedule could be up to six months.

B. Estimated Costs

Cost estimates are based on existing Emergency and Rapid Remedial Response Services

(ERRS) rates for the EPA Region 9 contracts. Cost estimates may have to be adjusted after potential bids for the removal are received, or if there is a substantial increase in material that requires attention.

Extramural Costs

Regional Removal Allowance Costs

Cleanup Contractor (ERRS) $300,000

Technical Contractor (START) $200,000

Extramural Subtotal $500,000

Extramural Contingency (20%) $100.000

TOTAL, Removal Action Project Ceiling $600,000

VI. EXPECTED CHANGE IN THE SITUATION SHOULD ACTION BE DELAYED OR NOT TAKEN

The "worst-case" scenario should no action be taken would be that the drums will continue to deteriorate and could rupture, causing a release in and around the CNMI CUC PCB Site which would have immediate adverse impacts on human health and the environment.

VII. ENFORCEMENT

Please see the attached Confidential Enforcement Addendum for a discussion regarding PRPs and enforcement. In addition to the extramural costs estimated for the proposed action, a cost recovery enforcement action also may recover the following intramural costs:

Intramural Costs^

U.S. EPA Direct Costs $100,000

U.S. EPA Indirect Costs (36.19% of Spending $600,000 + $100,000) $253.330

TOTAL Intramural Costs $353,330

The total EPA extramural and intramural costs for this removal action, based on full-cost accounting practices that will be eligible for cost recovery, are estimated to be $953,330. Ofthis, an estimated spending of $600,000 comes from the Regional removal allowance.

[Recommendation and signature on following page.)

1 Direct costs include direct extramural costs and direct intramural costs. Indirect costs are calculated based on an estimated indirect cost rate expressed as a percentage of site-specific direct costs, consistent with the full cost accounting methodology effective October 2, 2000. These estimates do not include pre-judgment interest, do not take into account other enforcement costs, including Department of Justice costs, and may be adjusted during the course of a removal action. The estimates are for illustrative purposes only and their use is not intended to create any rights for responsible parties. Neither the lack of a total cost estimate nor deviation of actual costs from this estimate will affect the United States' right to cost recovery.

Vlll. RECOMMENDATION

This decision document represents an appropriate removal action for the GPA Substation PCB Site, Apra Heights and Talofofo, Guam, developed in accordance with CERCLA, as amended, and not inconsistent with the NCP. This decision is based on the Administrative Record for the Site.

Because conditions at the Site meet the NCP criteria for a time-critical removal, I recommend that you concur on the determination of imminent and substantial endangerment and the removal action proposed in this Action Memorandum. The total removal action project ceiling, if approved will be $953,330. Of this, an estimated $600,000 comes from the Regional removal allowance. If you approve of this action, please indicate your decision by signing below.

Approve: Daniel Meei^, Asslsfaht Director Date Superfund Division

Disapprove: Daniel Meer, Assistant Director Date Superfund Division

Attachments 1. Guam EPA Request for Federal Action 2. Analytical Data 3. Enforcement Confidential Addendum

cc: S. Fielding, U.S. EPA, OEM, HQ M. Mann, USEPA Region 9 Administrator, Guam EPA

bcc: Site File Thanne Cox, ORC-3 Michelle Rogow, SFD-9-2 Harry L Allen, SFD-9-2 Peter Guria, SFD-9-4 Celeste Temple, SFD-9-4 Tana Alert, SFD-9-4 Philip Ingram, PMD-1 Ivania Brown, SFD-9-4 Lisa Ouyang, SFD-9-4

TDD No,: TBD ProjectNo,: TBD

' % Dededo •

Y,go.

Hagatna oMangilao

Guam

T-70 Transfomier „ • O Y o f i a

Santa Rita

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Guam Power Authority Substation PCB Site Sampling Locations

Guam

2012 ecology and environment, Inc,

ATTACHMENT 1

Guam EPA Request for Federal Action

GUAM ENVIRONMENTAL PROTECTION AGENCY

AHENSIAN PRUTEKSION LINA'LA GUAHAN

EDDIE BAZA CALVO P.O. Box 22439 GMF • BARRIGADA, GUAM 96921 RAYTENORIO GOVERNOR OF GuAM TEL: 475-1658/9 • FAX: 475-8007 LT. GOVERNOR OF GUAM

REOUEST FOR FEDERAL ACTION

The Guam Environmental Protection Agency requests assistance from the United States Environmental Protection Agency, Region 9 to conduct a removal action at the Guam Power Authority facilities located at:

Apra Substation, Lot No. 402-1, Apra Heights, Guam

Talofofo CT/Substation, Route 4A, Talofofo, Guam

By making this Request, the Requesting Agency recognizes that with respect to this removal action EPA, or any other federal agency acting in conjunction with or on behalf of EPA, may use its authority under the Comprehensive Environmental Response Compensation and Liability Act (CERCLA), 42 U.S.C.A. §§9601, et seg., the National Contingency Plan (NCP), 40 C.F.R. Part 300, or any other federal statute, regulation or response program, to respond to and recover costs incurred in response to releases or threats of releases of pollutants and contaminants as deemed necessary in EPA=s sole discretion to abate an imminent and substantial endangerment to public health or welfare or the environment at the location stated above. By making this Request, the Requesting Agency acknowledges that notice pursuant to Section 128(b)(1)(D) of CERCLA, 42 U.S.C. ' 9628(b)(1)(D), is not applicable with respect to this removal action. The signatory of this request is authorized to make this request on behalf of the State.

Executed on this die 23"* day of April, 2012.

^RIC M . PALACIOS Administrator

"ALL UVING THINGS OF THE EARTH ARE ONE'

ATTACHMENT 2

Analytical Data

; N \ / I R a IM IVI E N X A L

September29,2011

Ms. Sylvia Ipanag Guam Power Authority P.O. Box 2977 Hagatna, Guam 96932

Subject: ANALYTICAL TEST RESULTS AND REPORT OF THE PCB SAMPLING AT THE GPA APRA HEIGHTS AND TALOFOFO SUBSTATIONS

Dear Ms. Ipanag:

This report outlines the services and the analytical testing results performed on September 12, 2011 at the Apra Heights and Talofofo Substations. Guam Refinery and Environmental Services Company (GRESCO) was contracted by Guam Power Authority (GPA) to collect samples from two in-service transformers and have the samples analyzed for Poly-chlorinated Biphenyls (PCBs).

OVERVIEW GPA operations include the disposal of transformer oil when transformers are taken out of service. However, older transformers were known to use fluids that may have contained PCBs which are considered hazardous in high concentrations. Two (2) such transformers were identified in the Apra Heights Substation and the Talofofo Substation. Each transformer contains two separate chambers with transformer oil with a combined capacity of about 2500 gallons. As per GPA personnel, the lower chamber is known as the "Main" chamber, while the upper chamber was known as the "LTC" chamber.

SAMPLING AND ANALYHCAL SERVICES On September 12, 2011, GRESCO had collected samples from each chamber of each transformer located in the Apra Heights and Talofofo Substations. Each transformer was situated within its site's secondary containment berm. A discrete sample from each chamber was collected into an 8-ounce, pre-cleaned certified sampling jar with a Teflon-lined cap via the drainage valve. Each sample was then labeled with a unique sample ID.

GRESCO sampling personnel had utilized a new pair of nitrile gloves prior to each collection. In addition, the sampling personnel were also outfitted with Level .C Personal Protection Equipment (PPE) which included a full chemical suit, nitrile gloves, and a full-face air-purifying respirator during the sampling. Once collected, the samples were then immediately placed in a cooler with sufficient ice to maintain a temperature of four (4) degrees centigrade for transportation to the GRESCO Environmental Laboratory. Once at the GRESCO Environmental Laboratory, the samples were repackaged and sent to Calscience Environmental and Marine Chemistry Laboratories via DHL Express on the same day.

REFINERY / ENVIRONMENTAL LP GAS DIVISlOW WASTEWATER SOLUTIONS CNMI OFFiCE 320 South East Santa Rita Industrial Dr. 330 Cbalan Pale Ramon Ugu 213 Dulce De Maria Drive PMB 327, Box 10000

Santa Rita, GU 96915 Ylgo, 6 0 96913 Anigua, GU 96910 Saipan, MP 96950 Tel: (671) 565-7474 Fax: (671) 565-7575 Tel: (671) 653-4888 Fax:(671)653-4889 Tel: (671) 472-8280/81 Fax:(671)888-1116 Tel/Fax: (670) 234-2000

ANALYTICAL TEST RESULTS AND REPORT OF THE PCB SAMPUNG AT THE GPA APRA HEIGHTS AND TALOFOFO SUBSTATIONS

September 29, 2011; Page 2 of 3 SUMMARY OF ANALYTICAL RESULTS On September 22, 2011, the results were made available by the laboratory via e-mail. The table below enumerates the test results for each sample:

Sample ID Sample Location

Chamber Results Units PCB Pattem*

GPA-AH-M- 91211 Apra Heights Main 11 mg/kg (PPM) Aroclor 1242

GPA-TAL-M-91211 Talofofo Main 12 mg/kg (PPM) Aroclor 1242

GPA-TAL-LTC-91211 Talofofo LTC 24 mg/kg (PPM) Aroclor 1242

•^Considered as "PCB-Contamlnated" as perthe Toxic Substance Control Act or TSCA (40 CFR 761.40(a)) •=Considered as "Quantifiable Level of PCBs" as per the Toxic Substance Control Act or TSCA (40 CFR 761.20(e)(1)) *For a full list of PCB Patterns analyzed and their respective results, please see Laboratory Report (attached)

FINDINGS AND RECOMMENDATIONS Results show that the Main chambers of the Apra Heights and Talofofo Substations as well as the LTC chamber of the Talofofo Substation contain transformer oil with quantifiable (between 2 ppm and 49 ppm) levels of PCBs, where as the LTC chamber of the Apra Heights Substation contains transformer oil that is considered PCB-contaminated (between 50 ppm and 499 ppm). As per 40 CFR 761, oil containing levels of PCB greater than 2 ppm cannot be readily burned for energy recovery. As such, GRESCO recommends that the transformer oil from the two sampled transformers be disposed of at a permitted facility.

A full copy of the laboratory report, along with the Chain of Custody form, is attached for your reference.

Should you need additional information, please contact our office at 565-7473.

Best regards,

Franco L. Quintans

Environmental Project Coordinator

E N V I R O W M F W T A L 320 South East Santa Rita Industrial Dr.

SanU Rita, GU 9691S Tel: (671) 565-7474 Fax: (671) S6S-7575

L.P. GAS DIVISION 330 Chalan Pale Ramon Lagu

Vigo GU 96913 Tel: (671) 653-4888 Fax:(671)653-4889

WASTEWATER SOUJTIONS 213 Duke De Maria Dthie

Anigua, GU 96910 Tel: (671) 472-8280/81 Fax: (671) 888-1116

CNMI OFFICE PMB 327, Box 10000

Saipan, MP969S0 Tel/Fax: (670) 234-2000

CALSCIENCE WORK ORDER NUMBER: 11-09-0731

The difference is service

AIR : SOIL : WATER • ftMRINE CHEMISTRY

Analytical Report For Client: GRESCO

Client Project Name: GPA PCBs Attention: Robert Borden

P.O. Box 6307 Tamuning, Guam 96931-6307

Approved for release on 09/21/2011 by: Ranjit Clarke Project Manager

Calsdence Environmental Laboratories certifies that the test rasutts provided in Oils report meet all NELAC requirements for paiameterB tor which accreditation is requirad or availal](e. Any wceptions to NELAC requiranwnts are noted in the case nanativa. Theoriginal report of 8ut>contfBcted analyses, if any, is provided herein, and follows the standard Calscience data package. The rasults in this analyfical report are limited to the samples tested and any reproduction thereof must be made in its entirety. Note that the Chain-of-Custody Record and Sample Receipt Form are integral parts ofthis report

IIIIIIIII 71'?0LincolnWay,GardenGrove,CA92841-1432 • TEL:(711)895-5494 • FAX:(/'14)894-7501 • www,calscience,conn

^ Page 2 of 10

Gaiscience Environmental & Marine Chemistry Laboratories COBltGTBtS Client Project Name: GPA PCBs

Work Order Number 11-09-0731

1 Client Sample Data 3 1.1 EPA 8082 PCB Aroclors (Solid) 3

2 Quality Control Sample Data 5 2.1 MS/MSD and/or Duplicate 5 2.2 LCS/LCSD 6

3 Glossary of Terms and Qualifiers 7

4 Chain of Custody/Sample Receipt Fonn 8

alscience

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Page 3 of 10

GRESCO Date Received: 09/13/11 P.O. Box 6307 Work Order No: 11-09-0731 Tamuning, Guam 96931-6307 Preparation: EPA 3580A

Method: EPA 8082 Units: ug/kg

Project: GPA PCBs Page 1 of 2

Client Sample Number Lab Sample

Number Datemme , _^ Collected Matrix instrument

Date Prepared

[3ate/Tim8 Analyzed QC Batch ID

GPA-AH-M-01211 11-09-0731-1-A 09/12/11 Oil GC 58 10:08

09/16/11 00/19/11 19:26

110916L03

Parameter Result BL BE Qual Parameter Result BL EE Qua!

Arodor-1016 ND 5000 5 Arodor-1248 ND 5000 5 Arodor-1221 ND 5000 5 Arodor-1254 ND 5000 5 Arocior-1232 ND 5000 5 Arodor-1260 ND 5000 5 Aroclor-1242 11000 5000 5 Aroclor-1262 ND 5000 5 Surrooates: Control

Umits Qual Svvrogatos; RECf%^ Corrtrd

Umlts Jual

[}ecachlorobiphenyl 106 50-130 2,4,5,6-Tetrachloro-m-Xylene 83 50-130

GPA-AH4.TC-91211 11-094731-2-A 09/12/11 Oil GC58 i f t ie

09/16/11 09/10/11 19:44

110916L03

Parameter Result BL i2E QusI Parameter Result BL CE Qual

Arodor-1016 ND 20000 20 Arodor-1248 ND 20000 20 Arodor-1221 ND 20000 20 Arodor-1254 ND 20000 20 Arodor-1232 ND 20000 20 Arodor-1260 ND 20000 20 Arodor-1242 71000 20000 20 Arodor-1262 ND 20000 20 Surroaates: REQ(%) Control

Limits 50-130

Qual Surropates: REC/%^ Contral Qual Limita

Decachlorabiphenyl 118

Control Limits 50-130 2,4,5,6-Tetrachloro-m-Xylene 92 50-130

OPA-TAL-M-41211 11-09-0731-3-A 09/12M1 Oil GC 58 10:50

09/18/11 09/19/11 20:02

110916L03

Paramter Result BL DE jaual Parameter Result BL i2E Qua!

Arodor-1016 ND 5000 5 Arodor-1248 ND 5000 5 Arodor-1221 ND 5000 5 Arodor-1254 ND 5000 5 Arodor-1232 ND 5000 5 Arodor-1260 ND 5000 5 Arodor-1242 12000 5000 5 Arodor-1262 ND 5000 5 Surrogates: REC (%) Control

Limits Quai Surrogates: REC<%^ Control (

Limits 3ual

Decachlorobiphenyl 104 50-130 2,4,5,6-TetrachloRwn-Xylene 81 50-130

GPA-TAL-LTC-ei211 11-09-0731-4-A 09/12/11 011 GC58 10:55

09/16/11 00/19/11 20:20

110916L03

Parameter Result BL DE Qud Paramrter Result BL EE Arodor-1016 ND 10000 10 Arodor-1246 ND 10000 10 Arodor-1221 ND 10000 10 Arodor-1254 ND 10000 10 /Vodor-1232 ND 10000 10 Arodor-1260 ND 10000 10 Arodor-1242 24000 10000 10 Aroclor-1262 ND 10000 10

§«rrKieite9; RECf%l Control Limits

Qual Surrooates: RECf% l Centrol i Limits

aual

Decachlorobiphenyl 117 50-130 2,4,5,6-TetrBchtoro-m-Xylene 92 50-130

1

I KU-W RL - Reporting Umit , DF - Dilution Factor Quai - Qualifiers

7440 Lincoln Way, Garden Grove, CA 92841-1427 • TEL:(714) 895-5494 • FAX: (714) 894-7501

Page 4 of 10 alscience

L nvironmental

^ aboratories, Inc. Analytical Report

GRESCO Date Received: 09/13/11 P.O. Box 6307 Wori< Order No: 11-09-0731 Tamuning, Guam 96931-6307 Preparation: EPA 3580A

Method: EPA 8082 Units: ug/kg

Project: GPA PCBs Page 2 of 2

Client Sample Number Lab Sample

Numt>er Date/Time Colleded Matrix Instrument

Date Prepared

Date/Time Analyzed QC Batch ID

Method Blank 09e-O1-O13410 N/A Solid GCS8 09/16/11 00/17/11 110016L03 08:10

Parameter Resgit BL DE OiM Parameter Result BL DE Arodor-1016 ND 1000 1 Arodor-1248 ND 1000 1 Arodor-1221 ND 1000 1 Arodor-1254 ND 1000 1 Arodor-1232 ND 1000 1 Arodor-1260 ND 1000 1 Arodor-1242 ND 1000 1 Arodor-1262 ND 1000 1 Surroaates: Control

Umits Qual Sumxjates: REC (%) Control Qual

Umits Decachlorobiphenyl 109 50-130 2,4,5,6-Tetrachloro-fTi-Xylene 104 50-130

1

I K L - K I RL - Reporting Umit , DF - Dilution Factor , Qual - Qualifiers

7440 Lincoln Way, Garden Grove. CA 92841-1427 • TEL:(714) 895-5494 • F/VX: (714) 894-7501

Page 5 of 10

alscience

nvironmental Quality Control - Spike/Spike Duplicate

aboratories, inc.

GRESCO P.O. Box 6307 Tamuning, Guam 96931-6307

Date Received: Work Order No: Preparation:

09/13/11 11-09-0731 EPA 3580A

Method: EPA 8082

Proiect GPA PCBs

Quality Control Sample ID Matrix Instrument Date

Prepared Date

Anal^ed MS/MSD Batch

Number

GPA^AH-M-01211 on GCS8 00/16/11 09/17/11 110916803

Parameter SPIKE ADDED MS %REC MSD % R E C %REC CL RPD RPD CL Qualifiers

Arodor-1016 2000 698 654 50-135 6 0-25 3

Arodor-1260 2000 192 176 50-135 9 0-25 3

1

» t \ r u - n RPD - Relative Percent Difference , CL - Control Umit

7440 Lincoln Way. Garden Grove. CA 92841-1427 . TEL:(714) 895-5494 . FAX: (714) 894-7501

alscience

_ nvironmental Quality Control • LCS/LCS Duplicate

im aboratories. Inc.

Page 6 of 10

GRESCO P.O. Box 6307 Tamuning, Guam 96931-6307

Project: GPA PCBs

Date Received: Work Order No: Preparation: Method:

N/A 11-09-0731 EPA 3580A

EPA 8082

Date Date LCS/LCSD Batch Quality Control Sample ID Matiix Instrument Prepared Analyzed Number

09641-013-510 Solid GC 58 09/16/11 09/17/11 110916L03

Parameter SPIKE ADDED L C S % R E C LCSD %REC %REC CL RPD RPD CL Qtffllifiers

Arodor-1016 2000 120 114 50-135 6 0-25

Arodor-1260 2000 119 116 50-135 3 0-25

1

RPD - Relative Percent Drffetence , CL - Control Umit

7440 Lincoln Way. Garden Grove. CA 92841-1427 . TEL(714) 895-5494 . FAX: (714) 894-7501

Page 7 of 10

alscience

nvironmental Glossary of Terms and Qualifiers ; - i i i aboratories. Inc. - ^ L

Work Order Number 11 -09-0731

Qualifier Definition * See applicable analysis comment. < Less than the indicated value. > Greater than the indicated value. 1 Surrogate compound recovery was out of control due to a required sample dilution,

therefore, the sample data was reported without further clarification. 2 Surrogate compound recovery was out of control due to matrix interference. The

associated method blank surrogate spike compound was in control and, therefore, the sample data was reported without further clarification.

3 Recovery of the Matrix Spike (MS) or Matrix Spike Duplicate (MSD) compound was out of control due to matrix interference. The associated LCS and/or LCSD was in control and, therefore, the sample data was reported without further clarification.

4 The MS/MSD RPD was out of continol due to matrix interference. The LCS/LCSD RPD was in control and, therefore, the sample data was reported without further clarification.

5 The PDS/PDSD or PES/PESD associated with this batch of samples was out of control due to a matiix interference effect. The associated batch LCS/LCSD was in control and, hence, the associated sample data was reported without further clarification.

6 Surrogate recovery below the acceptance limit. 7 Surrogate recovery above the acceptance limit. B Analyte was present in the associated method blank.

BU Sample analyzed after holding time expired. E Concentration exceeds the calibration range. A

ET Sample was extracted past end of recommended max. holding time. 1 HD The chromatographic pattem was inconsistent with the profile of tiie reference fuel

standard. HDH The sample chromatographic pattem for TPH matches the chromatographic pattern of

the specified standard but heavier hydrocarbons were also present (or detected). HDL The sample chromatographic pattem for TPH matches the chromatographic pattem of

the specified standard but lighter hydrocartx}ns were also present (or detected). J /Vnalyte was detected at a concentration below the reporting limit and above the

laboratory method detection limit. Reported value is estimated. ME LCS/LCSD Recovery Percentage is within Marginal Exceedance (ME) Control Limit

range. ND Parameter not detected at the indicated reporting limit. Q Spike recovery and RPD control limits do not apply resulting from the parameter

concentration in the sample exceeding the spike concentration by a factor of four or greater.

SG The sample extract was subjected to Silica Gel treatment prior to analysis. X % Recovery and/or RPD out-of-range. Z Analyte presence was not confirmed by second column or GC/MS analysis.

Solid - Unless otherwise indicated, solid sample data is reported on a wet weight basis, not corrected for % moistajre. All QC results are reported on a wet weight basis.

7440 Lincoln Way, Garden Grove. CA 92841-1427 • TEL(714) 895-5494 • F/\X: (714) 894-7501

7440 LINCOLN WAY GARDEN GROVE, CA 92841-1432 TEL: (714) 895-5494 FAX: (714) 894-7501

CHAIN OF CUSTODY RECORD DATE: September 12,2011

PAGE: 1 OF 1

LABORATORY CUENT;

Guam Refinery & Environmental Services Company (GRESCO) GPA PCBs ADDRESS:

P. O.Box 6307

TEL

(671) 565-7473 TURNAROUND TIME

Tamuning. Guam 96931 FAX

(671) 565-7575 E-MAU.

fquintans@teleguam .net

• S A M E DAY n 2 4 H R • 48HR • 72 HR 5 DAYS [ I^DAYS

PROJECT CONTACT:

Robert Borden S A M P I ^ S ) : (SIGNA1

P.O. NO.:

QUOTE NO.:

REQUESTED ANALYSIS SPECML REQUIREMENTS (AOOmONAL COSTS MAY APPLY)

n RWQCB REPORTtNG f " ! ARCHIVE SAMPLES UNTIL / /

PC

Bs

SPECIAL INSlRUCnONS

P L E A S E E-MIAIL RESULTS TO dennlsp@tel«guam.net or

robert.borden(SarescoDacifk;.com

or fax to 671.565.7575 attn Dave or Dennis

PC

Bs

:U9I Q«.V

SAMPLEID LOtMTlOW

DESCRIPTION

SAMPUNG MATRIX Na OF CONT.

PC

Bs

:U9I Q«.V

SAMPLEID LOtMTlOW

DESCRIPTION DATE TIME MATRIX Na OF CONT.

PC

Bs

1 GPArAH-M-91211 GPA APRA HEIGHTS 9/12/11 1008 OIL 1 X

i'a" GPAnAH-LTC-91211 GPA APRA HEIGHTS 9/12/11 1016 OIL 1 X

3 GPArTAL-M-91211 GPA TALOFOFO 9/12/11 1050 OIL 1 X

4 GPArTAL-LTC-91211 GPA TALOFOFO 9/12/11 1055 OIL 1 x 5

mm

8 9 10; 11 12 Rellnqu»hed by. (Signature) " ! . ' X r — * . ^ J ^

RellnquMMd by. (Signature)

Received by: (Signature) Date:

9/12/2011 Time:

Received by: (Signature) Date: Time:

ReOnquMiad by: (Signature) Received by: (Signature) Time: '

•age 9 of 10

; IVI\/IR a IVIIVIEIVITAL

SAMPLE INFORMATION SHEET AWB REFERENCE NUMBER: DHL 24 3039 6522

1. SAMPLE DESCRIPTION

Sample Matrix: Uquid (Oil)

Volume: Eight (8)-ou nee - 4X

Origin: GPA Apra Heights and Talofofo Transformers

Purpose:

2. SAMPLE CLASSIFICATION

3. NOTATIONS

PCB Analysis

Synthetic • Animal • Plant • Soil

Samples were pulled from transformers located in the Apra Heights and the Talofofo sub stations

1

4. CERTIFICATION

Signa rjked€RESCO Representative Date

ENVIRONMENTAL 320 SoDth East Santa Rita Indnstrial Dr.

Santa Rita, GU 96915 Tel: (671) 565-7474 Fas: (671) S6S-7575

LJP. GAS DIVISION 330 Ciialan FBle Ramon Lagn

Yigo GU 96913 Td: (671) 653-4888 Fax: (671) 653-4889

CNMI OFFICE FMB 327, Box 10000 Saipan, MP 96950

Tel/Fax: (670) 234-2000

mmtihtaafnilnift, Aw-

CLIENT: Q(^C6>

Page 10 of 10

WORK ORDER #: 11 -09-0 S 0 H

Cooler / of

09//3 /11 SAMPLE RECEIPT FORM

DATE.

T E M P E R A T U R E : Thermometer ID: SCI (Criteria: 0.0°C - 6.0 °C, not frozen)

Temperature _ v J _ _ . _ 0 _ * * C + 0 .5 °C (CF) = >S" . vT °C • Blank H^ample

• Sample(s) outside temperature criteria (PM/APM contacted by: ).

• Sample(s) outside temperature criteria but received on ice/chilled on same day of sampling.

• Received at ambient temperature, placed on Ice for transport by Courier.

Ambient Temperature: • Air • Filter Initial: 1. CUSTODY SEALS INTACT:

• Cooler • • Sample •

• No (Not Intact)

• No (Not Intact)

el Not Present

Ef^ot Present

• N/A initial:

Initial:

Y e s ^

. CT

SAMPLE CONDITION:

Chain-Of-Custody (COC) document(s) received with samples

COC document(s) received complete •

• Collection date/time, matrix, and/or # of containers logged In based on sample labels.

• No analysis requested. • Not relinquished. date/time relinquished.

Sampler's name indicated on COC .,S3r—

Sampie container label(s) consistent with COC B —

Sample container(s) intact and good condition

Proper containers and sufficient volume for analyses requested ^

Analyses received within holding time .S"

pH / Res. Chlorine / Diss. Sulfide / Diss. Oxygen received within 24 hours... •

Proper preservation noted on COC or sample container •

• Unpreserved vials received for Volatiles analysis

Volatile analysis c»ntainer(s) free of headspace •

Tedlar bag(s) free of condensation • CONTAINER TYPE:

Solid: 040200J DSozCGJ DieozCGJ • Sleeve (_

No

•

0 ^

•

•

•

•

•

•

•

•

•

N/A

•

•

•

•

•

f^

J DEnCores® DTerraCores* •_

Water: DVOA DVOAh DVOAnaa •125AGB DIZSAGBh •125AGBp DIAGB DIAGBnaj DIAGBs

D500AGB D500AGJ DSOOAGJs D250AGB D250CGB D250CGBS D1PB D500PB DSOOPBna

D250PB D250PBn D125PB ;;?125PBznna D100PJ DIOOPJnaj D_

Air: DTedlar® DSumma® Other: 0^^^Jfii^Gi\Trlp Blank Lot#:. Labeled/Checked by: POL^ Container: C: Clear A: Amber P: Plastic G: Glass J : Jar B: Bottle Z: Ziploc/ResealableBag E: Envelope R e v i e w e d by :

Preservative: h: HCL n: HNO3 nairNajSiOi na: NaOH p: HjPCU s: H]S04 znna: ZnAcj^-NaOH f: Field-filtered S c a n n e d by :

SOPTIOO 090(0304/11)