On November 25, 2013, outside counsel for GD-OTS contacted Region 1 via telephone regarding 14 electrical transformers and 56 associated capacitors in use at its manufacturing facility in Saco, Maine. All of the transformers and capacitors contained PCBs. GD-OTS was in the process of developing a repowering plan for the facility that included the decommissioning and disposal of all the PCB transformers and capacitors. In reviewing its records regarding the transformers and capacitors, GD-OTS identified potential violations of certain requirements of the PCB regulations. Among other things, GD-OTS found (1) no documentation that its transformers had been registered with EPA by December 28, 1998 (as required by 40 C.F.R. section 761.30(a)(1)(vi)(A); and (2) no annual records or written annual documents logs (as required by 40. C.F.R. 761.180(a). GD-OTS documented these violations in two letters to Region 1, dated November 25, 2013, and January 28, 2014.
As a result of the self-disclosure letter, Region 1 has determined that (1) GD-OTS was not authorized to use the 14 PCB transformers since it had acquired the facility in 2000; and (2) GD-TS had failed to keep annual records or written annual document logs for the transformers.
GD-OTS has agreed to pay a $8,500 penalty to settle the alleged violations.