RESPONDENT WAS USING A PCB HEAT TRANSFER SYSTEM AND FAILED TO LABEL THE SYSTEM WITH THE PCB ML LABEL.
CCDS: respondent used a PCB Heat Transfer System to heat a chemical reactor. The Heat Transfer Oil contained PCBs greater than 50 ppm in violation of 40 CFR Part 761.30(d). The system was not Labeled with the PCB ML Label as required by 40 CFR Part 761.40. Respondent will dismantle and dispose of the Heat Transfer System as PCBs and Purge the Jacket to the Chemical Reactor to >2.00 ppm PCBs.