EPA has received and reviewed 2 One-Year Exception Reports submitted by Philip Services Corportion (PSC) on April 21, 2005 and April 17, 2006. As a disposal facility, PSC submitted these reports as required by 40 CFR Secs 761.215(c) and (d).
On March 14, 2005, CEA shiped 6 gallons of liquid PCBs and 196 pounds of PCB-contaminated debris to PSC. This PCB waste was received by PSC on April 19, 2005. The out of service date for the liquid PBCs and PBC-contaminated debris was 3/1/2004. These PCB items were removed from service and designated for disposal more than one year prior to the actual disposal of the items at PSC. On 2/15/2006, CEA shipped 206 pounds of PCB contaminated debris to PCS. This PCB waste was received by PSC on 3/21/2006. The out of service date for the PCB debris was 3/15/20065. These PCB items were removed from service and designated for disposal more than one year prior to the actual disposal of the items at PCS.
According to 40 CVR Sect 761.65(a)(1) a generator has one year from the out of service date of PDBs and PBC items to dispose of this material as PCB waste. On two occasions, CEA failed to dispose of PCBs and/or PCB items within one year of the out of service dates for this PCB waste, resulting in 2 violations of 40 CFR Section 761.65(a)(1).