HomeMy WebLinkAboutContract 19808 P
CITY
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ENVIRONMENTAL PROTECTION AGENCY
SE P REGION 6
DALLAS, TEXAS
IN THE Mih k 'T
'fzG b1i TSCA Docket No. VI-4120
CITY OF FORT WORTH
FORT WORTH, TEXAS CONSENT AGREEMENT AND
CONSENT ORDER
AUG
RESPONDENT _A20
I.
PRELIMINARY STATEMENT
1. This proceeding for the assessment of a civil penalty was
instituted pursuant to Section 16 (a) of the Toxic Substances
Control Act (TSCA) , 15 U.S.C. S 2615. This proceeding was
instituted by the issuance of a Complaint and Notice of opportunity
for Hearing ("Complaint") dated March 20, 1989 . The Complaint
charged Respondent with violating TSCA and thf ,,r
Ll 7� 11-14R
L 4
promulgated pursuant to TSCA.
CITY SECRETARY
2 . Respondent admits the jurisdictional alle e
+tfownelp M.
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Complaint; however, Respondent neither admits nor denies the
specific factual allegations contained in the Complaint or the
Findings of Fact and Conclusions of Law contained in this Consent
Agreement and Consent Order (CACO) . The Complaint states a claim
upon which relief can be granted.
3 . Respondent expressly waives its right to request a hearing
on any issue of law or fact set forth herein and waives all
defenses which have been raised or could have been raised to the
claims set out in the Complaint.
4. Respondent consents to the issuance of the CACO hereinafter
recited and consents to the assessment and payment of the stated
civil penalty in the amount and by the method set out in this CACO.
Ii.
FINDINGS OF FACT AND CONCLUSIONS OF LAW
5. Respondent is the City of Fort Worth, a municipality and a
political subdivision of the State of Texas.
6. Respondent is a "person" as that term is defined in 40
C.F.R. S 761. 3 and as such is subject to Part 761 of the
regulations, 40 C.F.R. S 761. 1(b) .
7. On or about September 27, 1988, Respondent was operating
its Landscape and Forestry Department located in the Rolling Hills
Building in Tarrant County at 2525 Tappan Blvd. , Fort Worth Texas.
8. On or about September 27, 1988, Respondent was inspected by
a representative of EPA, Richard P. McLaughlin, pursuant to Section
11(a) of TSCA, 15 U.S.C. § 2610(a) .
9 . On or about September 27, 1988, a written notice of
inspection was issued to a representative of the Respondent, James
Nobles, as required by Section 11(a) of TSCA, 15 U.S.C. S 2610 (a) .
10. At the time of the inspection, the Respondent had three
(3) PCB Transformers and one (1) PCB Contaminated Switch in storage
for reuse. The PCB Transformers were identified by nameplate as
Westinghouse, "Inerteen, " 23 gallons each, Serial Number 2389719,
2389720 and 2389721. The Switch had not been tested for PCB
concentration. Two (2) of the PCB Transformers had leaked and
cleanup of the released PCBs had not been accomplished. No PCBs or
2
PCB Items were in storage for disposal. There were no records of
PCBs or PCB Items having been sent for disposal. All of the
aforementioned PCBs and PCB Items were located on the premises of
the Respondent and in its possession and control.
11. "Inerteen" is the trade name used by Westinghouse to
denote dielectric fluid which contains polychlorinated biphenyls
(PCBs) in concentrations of 500 parts per million (ppm) or greater.
12. 40 C.F.R. S 761. 3 defines "PCB Transformer" as any
transformer that contains 500 ppm or greater.
13 . The three (3) transformers described in paragraph 10 are
"PCB Transformers" as that term is defined in 40 C.F.R. S 761. 3 .
14. "PCB-Contaminated Electrical Equipment" is defined in 40
C.F.R. S 761. 3 as any electrical equipment, including but not
limited to transformers, capacitors, circuit breakers, reclosers,
voltage regulators, switches, electromagnets, and cable that
contain 50 ppm or greater PCB, but less than 500 ppm PCB. oil-
filled electrical equipment other than circuit breakers, reclosers,
and cable whose PCB concentration is unknown must be assumed to be
PCB-Contaminated Electrical Equipment.
15. The one (1) switch described in paragraph 10 is "PCB-
Contaminated Electrical Equipment" as that term is defined in 40
C.F.R. S 761.3 .
16. "PCB Article" is defined in 40 C.F.R. S 761. 3 as any
'manufactured article, other than a PCB Container, that contains
PCBs and whose surface(s) has been in direct contact with PCBs.
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17. "PCB Item" is defined in 40 C.F.R. S 761.3 as any PCB
Article, PCB Article Container, PCB Container, or PCB Equipment
that deliberately or unintentionally contains or has a part of it
any PCB or PCBs.
18. The three (3) PCB Transformers and the one (1) PCB-
Contaminated Switch described in Paragraph 10 are "PCB Articles"
and "PCB Items" as those terms are defined in 40 C.F.R. S 761. 3 .
19. 40 C.F.R. S 761. 30 authorizes the use of PCBs in
transformers subject to certain conditions.
20. 40 C.F.R. S 761.30 (a) (1) (vi) requires that as of December
1, 1985, all PCB Transformers must be registered with fire response
personnel with primary jurisdiction over Respondent's premises.
21. At the time of the inspection, Respondent had failed to
register by December 1, 1985, with the fire response personnel with
primary jurisdiction over Respondent's premises its three (3) PCB
Transformers.
22 . 40 C.F.R. 761. 30 (a) (1) (viii) requires that as of
December 1, 1985, combustible materials, including, but not limited
to paints, solvents, plastics, paper, and sawn wood must not be
stored within a PCB Transformer enclosure (i.e. , in a transformer
vault or in a partitioned area housing a transformer) : within five
(5) meters of a transformer enclosure, or, if unenclosed
(unpartitioned) , within five (5) meters of a PCB Transformer.
23 . At the time of the inspection, combustible materials
(i.e. , plastics and paper boxes both empty and containing various
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liquids) were being stored within five (5) meters of Respondent's
three (3) PCB Transformers.
24. 40 C.F.R. $ 761. 30(a) (1) (x) requires that if a PCB
Transformer is found to have a leak which results in any quantity
of PCBs running off or about to run off the external surface of the
transformer, then the transformer must be repaired or replaced to
eliminate the source of the leak, and cleanup of the released PCBs
must be initiated within 48 hours of discovery.
25. At the time of the inspection, Richard McLaughlin observed
that two (2) of Respondent's PCB Transformers had leaked
approximately three (3) quarts of oil. The appearance of the areas
plus the previous report of leaking transformers in the building,
indicates that cleanup of released PCBs was not initiated within 48
hours of discovery.
26. 40 C.F.R. § 761.30 (a(1) (ix) requires that a visual
inspection of each PCB Transformer in use or stored for reuse shall
be performed at least once every 3 months.
27. 40 C.F.R. S 761.30(a) (1) (xii) requires that records of
inspection and maintenance history for PCB Transformers shall be
prepared and maintained at least three (3) years after disposing of
PCB Transformers and shall be made available for inspection upon
request by EPA.
28. At the time of the inspection, Respondent had failed to
prepare and maintain and make available during inspection the
records of inspection and maintenance history for its three (3) PCB
Transformers.
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29. 40 C.F.R. S 761.40(c) (1) requires that PCB Transformers in
use or stored for reuse shall be marked with the PCB ML label.
30. At the time of the inspection, Respondent had failed to
mark its three (3) PCB Transformers with the PCB ML label.
31. 40 C.F.R. S 761.40(j) requires that as of December 1,
1985, the vault door, machinery room door, fence, hallway, or means
of access to a PCB Transformer must be marked with the PCB ML
label.
32. At the time of the inspection, Respondent had failed to
mark the means of access to its three (3) PCB Transformers with the
PCB ML label.
33 . 40 C.F.R. S 761.3 defines "Leak" or "Leaking" as an
instance in which a PCB Article, PCB Container, or PCB Equipment
has any PCBs on any portion of its external surface.
34. 40 C.F.R. S 761.3 defines "Disposal" as intentionally or
accidentally discarding, throwing away, or otherwise completing or
terminating the useful life of PCBs and PCB Items. Disposal
includes spills, leaks, and other uncontrolled discharges of PCBs
as well as actions related to containing, transporting, destroying,
degrading, decontamination, or confining PCBs and PCB Items.
35. 40 C.F.R. S 761. 60 (d) (1) states that spills and other
uncontrolled discharges of PCBs at concentrations of 50 ppm or
greater constitute the disposal of PCBs.
36. During the inspection, Richard McLaughlin observed that
two (2) of Respondent's PCB Transformers had leaked. The PCBs
6
leaked from these transformers constitute disposal as that term is
defined in 40 C.F.R. S 761. 3 and 40 C.F.R. S 761. 60 (d) (1) .
37 . 40 C.F.R. S 761. 180(a) requires that each owner or
operator of a facility using or storing at one time at least 45
kilograms of PCBs contained in PCB Container(s) or one or more PCB
Transformers! or 50 or more PCB Large High and Low Voltage
Capacitors shall develop and maintain records on the disposition of
PCBs and PCB Items. These records shall form the basis of an
Annual Document prepared by each facility by July 1, covering the
previous calendar year. The records and documents shall be
maintained for at least five (5) years after the facility ceases
using or storing PCBs or PCB Items in the prescribed quantities.
The information required to be included in the Annual Documents
includes, inter alia: (1) the total number of PCB Transformers and
total weight in kilograms of any PCBs contained in the PCB
Transformers which remain in service at the end of the calendar
year (40 C.F.R. S 761. 180(a) (3) (ii) ] .
38. At the time of the inspection, Respondent had failed to
prepare an Annual Document for the latter half of 1978 and calendar
years 1979 through 1987.
39. At the time of the inspection, the Respondent had failed
to record in Annual Documents the total number of PCB Transformers
and total weight in kilograms of any PCBs contained it its three
(3) PCB Transformers.
40. Failure or refusal to comply with any rule promulgated, or
order issued, under Section 6 of TSCA, 15 U.S.C. 2605,
7
constitutes an unlawful act under Section 15 (1) (C) of TSCA,
15 U. S. C. S 2614 (1) (C) .
41. Therefore, Respondent has violated Section 15 (1) (C) of
TSCA, 15 U.S.C. S 2614 (1) (C) , by [1] failing to register by
December 1, 1985 its three (3) PCB Transformers with fire response
personnel with primary jurisdiction over Respondent's premises, as
required by 40 C.F.R. S 761. 30(a) (1) (vi) ; [2] storing combustible
material within five (5) meters of its three (3) PCB Transformers,
as prohibited by 40 C.F.R. S 761. 30(a) (1) (viii) ; [3] failing to
initiate cleanup of released PCBs within 48 hours of discovery, as
required by 40 C.F.R. S 761. 30 (a) (1) (x) ; [4] failing to prepare and
maintain and make available during inspection, the records of
inspection and maintenance history for its three (3) PCB
Transformers, as required by 40 C.F.R. S 761. 30(a) (1) (xii) ; [5]
failing to mark its three (3) PCB Transformers with the PCB ML
label, as required by 40 C.F.R. S 761.40(c) (1) ; [6] failing to mark
the means of access to its three (3) PCB Transformers with the PCB
ML label, as required by 40 C.F.R. S 761.40(j) ; [7] failing to
properly dispose of PCBs, as required by 40 C.F.R. S 761. 60; [8]
failing to prepare and maintain Annual Documents, as required by 40
C.F.R. S 761. 180 (a) ; and [9] failing to record in Annual Documents
the total number of PCB Transformers and the total weight in
kilograms of any PCBs contained in its three (3) PCB Transformers,
as required by 40 C.F.R. S 761.180(a) (3) (ii) , rules promulgated
pursuant to Section 6 of TSCA, 15 U.S.C. S 2605.
8
COSTS
Each party shall bear its own costs and attorney fees.
IV.
TERMINATION OF CACO
All obligations under this CACO shall terminate upon payment
of the penalty by the Respondent.
V.
CIVIL PENALTY
Pursuant to TSCA S 15 (a) (1) (B) , and the PCB Civil Penalty
Policy, EPA proposed a civil penalty of $9, 500.00 in this matter.
The City of Fort Worth, Fort Worth, Texas, undertook the following
environmentally beneficial project:
1. Removal, disposal and replacement of one (1) PCB Transformer
and two (2) PCB-Contaminated Transformers from the Will Rogers
Memorial Coliseum, at an approximate cost of $61, 379. 00
In addition, the City of Fort Worth has reconstructed Annual
Documents for all of the City's facilities. The City has agreed to
maintain the Annual Documents and Annual Document Logs at each
facility location for three years after disposal of their PCB
Equipment.
COSEZT ORDER.
Pursuant to the authority granted in Section 16 of TSCA,
15 U.S.C. S 2615, and upon consideration of the entire record
herein, including the above Findings of Fact and Conclusions of
9
Law, which are hereby adopted and made a part hereof, and upon
consideration of the nature, circumstances, extent and gravity of
the alleged violations, and with respect to the Respondent, its
ability to pay, effect on its ability to continue to do business,
any history of prior PCB violations, the degree of culpability, and
other factors as justice may require, it is ORDERED that Respondent
be assessed a civil penalty of NINE THOUSAND, AND FIVE HUNDRED
DOLLARS ($9, 500. 00) .
EIGHT THOUSAND FIVE HUNDRED AND FIFTY DOLLARS ($8,550. 00) ARE
HEREBY REMITTED, as Respondent has expended in excess of $28,
500.00 to complete the environmentally beneficial project discussed
in "Civil Penalty" above.
The payment shall be made by mailing a money order, cashier's
check, or certified check payable to Treasurer of the United
States, within thirty (30) days of the effective date of this
Agreement to the following address:
Regional Hearing Clerk (6C)
U.S. EPA, Region 6
P. 0. Box 360582M
Pittsburgh, Pennsylvania 15251
TSCA Docket No. VI-412C shall be clearly typed on the check to
ensure proper credit.
Respondent shall send simultaneous notice of such payments,
including copies of the money order, cashier's check, or certified
check to the following:
10
(1) Ms. Donna Mullins (6T-PT)
Environmental Scientist
Toxics Section
Air, Pesticides and Toxics Division
U.S. EPA, Region 6
1445 Ross Avenue
Dallas, Texas 75202-2733
Adherence to this request will ensure proper credit is given
when penalties are received.
If EPA does not receive payment within thirty (30) days of the
due date, interest will accrue on the amount due from the due date
at the current annual rate prescribed and published by the
Secretary of the Treasury in the Federal Register and the Treasury
Fiscal Requirements Manual Bulletin per annum through the date of
payment.
If the payment is overdue, EPA will also impose a late payment
handling charge of $15, with an additional delinquent notice charge
of $15 for each subsequent thirty (30) day period. Finally, EPA
will apply a six (6) percent per annum penalty on any principal
amount not paid within ninety (90) days of the due date.
Other penalties for failure to make a timely payment may also
apply.
Payment of NINE HUNDRED FIFTY DOLLARS ($950.00) shall be made
within thirty (30) days of the effective date of this Consent
Agreement and Consent Order.
Date:
Bob Terrell, ity Manager
City of Fort Worth
1000 Throckmorton Street
Fort Worth, Texas 76102
Date: c� - .. C��= .-� .�4 ..r
Alice Church, City Secretary
City of Fort Worth
1000 Throckmorton Street
Fort Worth, Texas 76102
Approved as to form and legality
Date:
Marcia Wise, Assistant City Attorney
City of Fort Worth
1000 Throckmorton Street
Fort Worth, Texas 76102
Date
A. tan ey eiburg
Director
Air, Pesticides and Toxics Division
Region 6
Coctract kathorization
Date
12
This Consent Agreement and Consent Order is hereby adopted and
issued pursuant to Section 16 of TSCA, 15 U.S.C. § 2615, and the
Consolidated Rules of Practice Governing the administrative
Assessment of Civil Penalties, 40 C. F. R. Part 22 .
It is so ORDERED. This Order shall become effective immediately.
Date: q'5
4Joe D. Winkle
Acting Regional Administrator
,,,,i EPA Region 6
13
CERTIFICATE OF SERVICE
I hereby certify that on the 1_4_;7
(lay of Z&V1993 ,
the original of the foregoing consent Agreement and Consent Order
was hand delivered to the Regional Hearing Clerk, U. S. EPA, Region
6, 1445 Ross Avenue, First Interstate Bank Tower, Dallas, Texas
75202-2733, and a true and correct copy was placed in the United
States Mail, certified mail, return receipt requested, addressed to
the following:
Kay Granger
Mayor
City of Fort Worth
1000 Throckmorton Street
Fort Worth, Texas 76102
Certified No. P 923
Carolyn ,yi'lliams' on (6T-PT)
Paraleg<11
14
CERTIFICATE OF SERVICE
I hereby certify that on the day 1993,
the original of the foregoing Consent Agreement and Consent Order
was hand delivered to the Regional Hearing Clerk, U. S. EPA, Region
6, 1445 Ross Avenue, First Interstate Bank Tower, Dallas, Texas
75202-2733 , and that on the day of 1993
LLI
a true and correct copy of the original was placed in the United
States Mail, certified mail, return receipt requested, addressed to
the following:
Ms. Catherine Musser
City of Fort Worth
1000 Throckmorton Street
Fort Worth, Texas 76102-6311
Certified No. 3 7,
Caroly"illiamson (6T-PT)
Paralegal