CHESTNUT LAKE APARTMENTS & TOWNHOUSES 1450 CHESTNUT DRIVE YPSILANTI, MICHIGAN 48197

Transcription

1 OPERATIONS AND MAINTENANCE PLAN FOR THE MANAGEMENT OF POLYCHLORINATED BIPHENYLS (PCBS) CHESTNUT LAKE APARTMENTS & TOWNHOUSES 1450 CHESTNUT DRIVE YPSILANTI, MICHIGAN PREPARED BY: NOVA CONSULTING GROUP, INC SOUTH 900 EAST SUITE 211 SALT LAKE CITY UT Leaders in Environmental and Engineering Services

2 TABLE OF CONTENTS 1.0 INTRODUCTION General Objectives Benchmarks of an Effective Operations and Maintenance Plan Operations and Maintenance Plan Elements POLYCHLORINATED BIPHENYLS IN TRANSORMERS General Medical Aspects Regulatory Aspects POLYCHLORINATED BIPHENYL MANAGEMENT PLAN General Inspections Notifications MAINTENANCE PLAN General Program Management Training Record-Keeping Awareness Program/Communication Plan REMEDIATION GUIDANCE General... 7 Appendix A Forms Appendix B Site Diagram PCB OPERATIONS AND MAINTENANCE PLAN i CHESTNUT LAKE APARTMENTS & TOWNHOUSES

3 1.0 INTRODUCTION 1.1 General Location: CHESTNUT LAKE APARTMENTS & TOWNHOUSES 1450 WEST CHESTNUT DRIVE YPSILANTI, MI The Property consists of a rectangular-shaped parcel of land totaling approximately acres in size. The Property is currently designed and used for multifamily residential purposes under the name Chestnut Lake Apartments & Townhouses. Current improvements consist of 21 twostory structures that contain a management-reported total of 281 apartment units totaling approximately 245,922 net rentable square feet. The Property also includes a two-story leasing/clubhouse building (3,513 square feet) that is divided into an office area, clubhouse area, restrooms, maintenance shop and storage areas. Additional improvements include asphalt-paved drives and surface parking areas, one in-ground swimming pool, one playground area, laundry rooms (within the apartment buildings). The Property also includes a sewage lift station located within the northeast portion of the Property. A portion of Chestnut Lake is located in the west central portion of the Property. A second unnamed lake is located in the northeast portion of the Property. Available information indicates that the Property buildings were constructed in Nova observed 12 pad-mounted electrical transformers throughout the Property. The units were not labeled as to their PCB status; however, the units were labeled as owned and operated by DTE Energy. Nova contacted DTE Energy in an effort to determine the PCB content (if any) associated with Property transformers, as well as confirm ownership. No response has been received. No indication of staining, leaks or fire damage was observed on or around the bases of these units. DTE did not confirm or deny the presence of PCB in the transformer oil. Until the transformer oil is tested by qualified sampling and analysis and found free of PCB, the oil is considered to contain PCB for the purpose of this O&M Plan. This Operations and Maintenance Plan (O&M Plan) may assist tenants, owners, employees, and occupants of Chestnut Lake Apartments & Townhouses in controlling the potential release of Polychlorinated Biphenyls (PCBs) that could be within the complex. Because it is unknown if the contents of the transformers contain PCBs, safe management of the transformers includes implementing this O&M Plan to reduce the likelihood of a PCB release or exposure event. This O&M Plan is an interim-management approach until such time as it is known that all PCBs have been eliminated or determined not to be on the Property. 1.2 Objectives The primary objectives of an effective PCB Plan are: - To identify the transformers servicing the property; - To minimize the human and environmental exposure; - To provide training to Property maintenance and custodial staff; PCB OPERATIONS AND MAINTENANCE PLAN 1 CHESTNUT LAKE APARTMENTS & TOWNHOUSES

4 - To implement proper and immediate notification to DTE; and, - To monitor the condition of the transformers. 1.3 Benchmarks of an Effective Operations and Maintenance Plan For an O&M Plan to be effective, it must be fully implemented at all levels of management and directed by a single individual who manages the Property. 1.4 Operations and Maintenance Plan Elements This O&M Plan is comprised of the following elements: - Regular visual inspections to observe transformer conditions throughout the Property. - Training in the event of a recognized release of dielectric fluids from a transformer. - Immediate notification to DTE. - Recordkeeping. PCB OPERATIONS AND MAINTENANCE PLAN 2 CHESTNUT LAKE APARTMENTS & TOWNHOUSES

5 2.0 POLYCHLORINATED BIPHENYLS IN TRANSORMERS 2.1 General Polychlorinated Biphenyl (PCB) PCBs belong to a broad family of man-made organic chemicals known as chlorinated hydrocarbons. PCBs were domestically manufactured from 1929 until their manufacture was banned in They have a range of toxicity and vary in consistency from thin, light-colored liquids to yellow or black waxy solids. Due to their non-flammability, chemical stability, high boiling point, and electrical insulating properties, PCBs were used in hundreds of industrial and commercial applications including electrical, heat transfer, and hydraulic equipment; as plasticizers in paints, plastics, and rubber products; in pigments, dyes, and carbonless copy paper; and many other industrial applications. 2.2 Medical Aspects PCBs have been demonstrated to cause a variety of adverse health effects. PCBs have been shown to cause cancer in animals. PCBs have also been shown to cause a number of serious non-cancer health effects in animals, including effects on the immune system, reproductive system, nervous system, endocrine system and other health effects. Studies in humans provide supportive evidence for potential carcinogenic and non-carcinogenic effects of PCBs. The different health effects of PCBs may be interrelated, as alterations in one system may have significant implications for the other systems of the body. A qualified health professional should be consulted if the user has any questions regarding the health effects of PCB exposure. 2.3 Regulatory Aspects Toxic Substances Control Act (TSCA) The Toxic Substances Control Act (TSCA) became law on October 11, The Act authorized EPA to secure information on all new and existing chemical substances, as well as to control any of the substances that were determined to cause unreasonable risk to public health or the environment. The current PCB regulations were published on July 1, 2007, pursuant to this Act. PCB Regulations: 40 CFR 761 Current PCB regulations can be found in the Code of Federal Regulations (CFR) at 40 CFR 761. The CFR is updated as of July 1 each year. The Government Printing Office maintains the most current version of the CFR. The EPA website contains an Interpretive Guidance page for useful interpretations of the regulations as well as answers to frequently asked questions. PCB OPERATIONS AND MAINTENANCE PLAN 3 CHESTNUT LAKE APARTMENTS & TOWNHOUSES

6 3.0 POLYCHLORINATED BIPHENYL MANAGEMENT PLAN 3.1 General The Property consists of a rectangular-shaped parcel of land totaling approximately acres in size. The Property is currently designed and used for multifamily residential purposes under the name Chestnut Lake Apartments & Townhouses. Current improvements consist of 21 twostory structures that contain a management-reported total of 281 apartment units totaling approximately 245,922 net rentable square feet. The Property also includes a two-story leasing/clubhouse building (3,513 square feet) that is divided into an office area, clubhouse area, restrooms, maintenance shop and storage areas. Additional improvements include asphalt-paved drives and surface parking areas, one in-ground swimming pool, one playground area, laundry rooms (within the apartment buildings). The Property also includes a sewage lift station located within the northeast portion of the Property. A portion of Chestnut Lake is located in the west central portion of the Property. A second unnamed lake is located in the northeast portion of the Property. Available information indicates that the Property buildings were constructed in Nova observed 12 pad-mounted electrical transformers throughout the Property. The units were not labeled as to their PCB status; however, the units were labeled as owned and operated by DTE Energy. Nova contacted DTE Energy in an effort to determine the PCB content (if any) associated with Property transformers, as well as confirm ownership. No response has been received. No indication of staining, leaks or fire damage was observed on or around the bases of these units. 3.2 Inspections Visual inspections should be performed at least every other monthly to observe the condition of the transformers located on the property. The purpose is to determine if there is presence of dielectric fluid beneath the transformers or present on the exterior of the transformer. Each inspection should include photographs of the condition, date and time of the inspection. 3.3 Notifications Guidance has been provided to contact DTE in the event leaks are observed. The contact information is: or PCB OPERATIONS AND MAINTENANCE PLAN 4 CHESTNUT LAKE APARTMENTS & TOWNHOUSES

7 4.0 MAINTENANCE PLAN 4.1 General It will not be the responsibility of Chestnut Lake Apartments & Townhouses to maintain the transformers. No direct action by Property personnel should ever be conducted with either the leaking dielectric fluids or the transformers. Immediate calls to DTE to respond to events such as leaks, fires or other destructive events are to be followed as defined in Section Program Management Key Personnel For the purposes of this O&M Plan the Program Manager will be: Facility Transformer Inspection Coordinator: Name: Phone Number Cell Phone: Facility Transformer Inspection Coordinator The Facility Transformer Inspection Coordinator is the individual responsible for managing the overall O&M Plan and acts as the decision-maker on all inspections or emergency calls. This person should be on site during most working hours at the facility. 4.3 Training The Facility Transformer Inspection Coordinator should have knowledge of the locations, operations, phone numbers and observation techniques to recognize damaged transformers. There are no specific training requirements, but the following information is important for management of the O&M Plan. The topics include the following: - Introduction to PCBs - Periodic Inspections - Notification Procedures - Record keeping 4.4 Record-Keeping The record keeping system must accurately track data on the location of the transformers and visual inspection results. The Facility Transformer Inspection Coordinator is to maintain the record keeping system in a central location and in a condition suitable for audit. The essential records are described below. PCB OPERATIONS AND MAINTENANCE PLAN 5 CHESTNUT LAKE APARTMENTS & TOWNHOUSES

8 4.5 Awareness Program/Communication Plan The owner of the Subject Building will provide information as is necessary to protect human life and the environment. Employee and Occupant Notification Letter If necessary, a notification letter will be issued to all occupants in the event there is a release that could expose or impact occupants or guests. PCB OPERATIONS AND MAINTENANCE PLAN 6 CHESTNUT LAKE APARTMENTS & TOWNHOUSES

9 5.0 REMEDIATION GUIDANCE 5.1 General No employees will engage in any remediation activity that involves a response action dealing with damaged or leaking transformers. All response actions will be reserved for DTE. PCB OPERATIONS AND MAINTENANCE PLAN 7 CHESTNUT LAKE APARTMENTS & TOWNHOUSES

10 APPENDIX A OCCUPANT NOTIFICATION LETTER TRANSFORMER INSPECTION FORM OBSERVATION OF WORK TO REPAIR, REPLACE AND CLEAN DAMAGED TRANSFORMERS

11 OCCUPANT NOTIFICATION FORM DATE: LOCATION: RE: Notification of A Damaged Electrical Transformer Within the complex, we have observed a damaged electrical transformer. We are providing this notification asking all residents to refrain from the area as identified above. We have placed barriers around the area and ask that you stay out of this area to protect yourself and others from potential contact with potentially hazardous materials and hazardous electric energy. We have notified the electrical utility company and once the condition has been repaired, we will remove the barriers. If you have any concerns or questions, please direct them to the facility management. Thank you for your cooperation as we remedy this situation.

12 TRANSFORMER INSPECTION FORM DATE: BUILDING: ID or S/N: INSPECTION LOCATIONS: REASON FOR INSPECTION: DAMAGED MATERIAL: PERIODIC SURVEY: IF DAMAGED IS REASON FOR INSPECTION, PLEASE COMPLETE 1 THROUGH 5 1 TYPE OF DAMAGE: 2. CAUSE OF DAMAGE: 3. APPROXIMATE SIZE OF DAMAGED OR IMPACTED AREA: 4. HAS PERSONAL PROPERTY BEEN IMPACTED? 5. ARE EMPLOYEES/TENANTS/SUBCONTRACTORS LIKELY TO BE IMPACTED? 6. HAS MATERIAL CONDITION CHANGED SINCE LAST INSPECTION? COMMENTS: NEXT SCHEDULED INSPECTION DATE: INSPECTOR'S SIGNATURE(S):

13 OBSERVATION OF WORK TO REPAIR, REPLACE AND CLEAN DAMAGED TRANSFORMERS NAME: DATE: LOCTATION: Transformer ID or S/N 1. Address, building, and room number(s) (or description of area) where transformer work is to be performed: 2. Starting date: Finish date: 3. Description of work: 4. Name and telephone number of responders 6. Name and telephone number of responder: Save this form with the inspection documents.

14 APPENDIX B SITE DIAGRAM

15 Undeveloped Land Huron Ophthalmology (5477 W. Clark Rd.) Chase Bank (5485 McAuley Dr.) Lift Station Residential (2921 W. Clark Rd./ W. Chateau Vert) Leasing Office Villas Apartments (2911 Bynan Dr.) Chestnut Lake Apartments & Townhouse s Surface Parking Lots/ Undeveloped Land (1 Huron River Dr.) Undeveloped Land Chippewa Racquet Club (2525 Golfside Rd.) N W E Chippewa Racquet Club (2505 Golfside Rd.) LEGEND = Property Boundary = Transformer S (Not to Scale) = Dumpster = In-Ground Poo = Playgroundl PROPERTY DIAGRAM Chestnut Lake Apartments & Townhouses 1450 West Chestnut Drive Ypsilanti, Michigan Nova Project No.: B