Attachment #4
Secretary’s note: referenced attachments are not included in the interest of brevity. Additional
information is available on request.
EPA Multimedia Inspection Summary
June 26-28, 2001
On Tuesday, June 26th, EPA compliance officers arrived unannounced at the Facilities
Engineering Office to conduct a multimedia inspection of Princeton University. A listing of the
EPA inspection team members is attached.
June 26th
Opening conference attendees: Tom Nyquist, Bob Ortego, Garth Walters, Vivian Chin, Jeanette
Dadusc
Attached is a copy of the initial inspection schedule, as proposed by team coordinator Vivian
Chin. During the brief opening conference, we unsuccessfully pressed for rescheduling of the
inspection due to the absence of key people (Robin Izzo and Peter Perkuhn) needed for the PCB
and Underground Injection Control portions of the inspection scheduled for Wednesday. There
also was a discussion of the relationship between Princeton University and the Plasma Physics
Laboratory (PPL) and the areas occupied by PPPL on Forrestal Campus.
Underground Storage Tanks
Following the opening conference, Bob Ortego accompanied Jeanette Dadusc and Vivian Chin
on the Underground Storage Tank portion of the inspection. A review of the existing USEPA
regulated tanks was conducted based on an inaccurate NJDEP inventory. Existing permits were
reviewed and three tank systems were investigated: the MacMillan gasoline tank, the Lewis
Thomas emergency generator tank and the Hoyt Laboratory emergency generator tank.
An inspection of the MacMillan system gasoline delivery system was conducted with input from
Charles Gash of the Garage. Existing files were reviewed and it was determined the interstitial
monitoring system was not being checked every 30 days to determine if it is functioning
properly; however, the systems are continuously monitored.
Note: Following the inspection, the system was determined to be functioning properly.
Historical records show that the interstitial system has not failed during its active life. To
resolve workers from having to manually extract the monitoring equipment, an automatic
statistical inventory reconciliation computer chip was installed and will alleviate the 30
day check. The remainder of the tank system was inspected and found to be in order.
The Lewis Thomas Laboratory tank was visually inspected and determined that the annual
corrosion certification had not been conducted as required by regulation.
Note: Following the inspection, the previous mechanical engineering firm responsible
for the installation was asked to produce historical documentation to show the 15.0 feet
of piping has corrosion protection attached to the system. This piping is believed to be
protected, determined by site observations of a test lead to check the adequacy of the
sacrificial anode system. This will be tested the week of July 30, 2001.
The final discussion involved the Hoyt emergency generator tank, which had been taken out of
service a year and a half ago, thereby exceeding the one-year grace period under current
regulations.
Attachment #4
Note: Following the inspection, Bob Ortego submitted an application to the Borough for
a permit to remove the tank, which is scheduled for removal in August 2001.
Air Emissions
Mr. Raymond Slizys reviewed the current Title V Operating Permit and interviewed Bob Ortego
regarding existing conditions. At the completion, the existing systems of the Co-generation plant
were inspected, including: the continuous emission monitoring data over the past year, log books
of the daily maximum heat input of the boilers and the rolling day average calculations for the
fuel burning on all three equipment. No deficiencies were noted with any of the requirements
under our permit for the plant (over 300 requirements overall for the campus). Annual emission
records for the existing equipment on campus was also inspected and determined to be in order.
Mr. Slizys requested information for the previous year’s CFC repairs and equipment. This
information was not readily available. Bob Ortego compiled these materials and sent them out
on July 6, 2001.
No deficiencies were mentioned at the completion of the inspection.
June 27th
PCBs
Attendees: Leonard Pappalardo, Vivan Chin, Garth Walters, Robin Izzo, Tom Nyquist
The PCB portion of the inspection was conducted by Leonard Pappalardo. Following execution
of confidentiality documents (see attached), Mr. Pappalardo requested general facility
information and uses of PCBs in research. At Mr. Pappalardo’s request, Garth Walters
telephoned George McLendon (Chemistry Department chair) who confirmed our assertion that
there is no PCB research currently taking place in the Chemistry Department. PCB materials
remaining from work performed by Chemistry Professor Jeff Schwartz were disposed of in 2000.
Mr. Pappalardo was informed that all of Princeton University’s oil-filled PCB transformers were
disposed of in 1993. He was provided with copies of the PCB Annual Summary for 1999 and
2000 and advised that the only PCB items known to remain on campus are the 396 capacitors in
the Energy Wing at E-Quad. In response to questions from Mr. Pappalardo, we stated that no
wastes have been rejected for PCB contamination, there is no research in progress on new uses
of PCBs, and that there are no heat transfer devices or high temperature hydraulic systems
containing PCBs.
During the visit to the capacitor facility in G-Wing of the E-Quad, three photographs of the
capacitor area were taken by the inspector.
Additional records requested by Mr. Pappalardo included:
• Copies of all waste disposal manifests and certificates of disposal for PCBs from 1998 to
present (hand delivered by Garth Walters on June 29th)
• Copies of documentation of a small (<1 pound) PCB leak from capacitors earlier this year
during renovation of Chemical Sciences Building at Forrestal. (documentation provided
via e-mail by Garth Walters on June 29th See attached incident narrative)
• A list of PCB transformers disposed of or retrofilled that includes:
o Name, serial number disposal date, electrical ratings, volume of fluid (to be
provided to EPA by P. Perkuhn before August 1st ).
• Copies of disposal manifests and certificates of disposal of the above referenced
transformers (to be provided to EPA by P. Perkuhn before August 1st ).
Attachment #4
•
A current list of all oil-filled transformers on campus that includes:
o Name serial number, electrical ratings, volume of fluid (to be provided to EPA by
P. Perkuhn before August 1st ).
Underground Injection Control
Attendees: John Struble, Vivan Chin, Tom Nyquist, Bob Ortego, Bernie Seighman, Scott Sepsy,
Robin Izzo, Garth Walters
The UIC portion of the inspection was conducted by John Struble. Mr. Struble requested the
following documents:
• Blueprints of building drainage systems (to be provided by August 1)
• A copy of our Stony Brook Regional Sewer Authority Permit (provided at the inspection)
• A copy of the most recent Right to Know Survey for Main Campus (provided at the
inspection)
• A copy of our RTK Research and Development exemption (provided at the inspection)
• Copies of sample invoices from Clean Harbors and Safety Kleen for chemical waste
disposal services (provided at the inspection)
• A copy of the University’s drain disposal policy (to be provided by August 1, see
attached memo by Robin Izzo)
• A summary of the types of chemicals used in University research (to be provided by
August 1, see attached memo by Robin Izzo)
• The results of our drain discharge inventory (to be provided by August 1)
• The names of the NJDEP case officers or other contacts for:
o the Forrestal ground water case (provided at the inspection)
o Boiler House tank removals (to be provided by August 1)
o Art Museum elevator leak (to be provided by August 1)
o Friend Center oil intrusion (to be provided by August 1)
The following areas were visited by all of the above attendees except Bob Ortego:
The book conservation area in Firestone Library
Frick Lab basement mechanical room
Chemistry Professor Dan Kahne’s laboratory in New Frick
Athletics pesticide storage area at the Armory
McCarter Scene Shop at the Armory
Vehicle maintenance garage & car wash area in MacMillan
MacMillan paint shop
Princeton Energy Plant
MR Struble stated that his preliminary determination is that we do not have underground
injection wells
June 28th
EPCRA/Risk Management Plan
Attendees: Vivian Chin, Angelo Diana, Chris Jimenez, Kelly States, Garth Walters, Tom
Nyquist, Bob Ortego
The Right-To-Know portion of the inspection was conducted by Mr. Angelo Diana.
The following documents were provided at the time of the inspection:
Copies of the Community Right To Know Survey for 20000 for Main Campus, West
Windsor, Forrestal Campus, Blairstown and Dunwalke
No other documents were requested (see attached EPA Inspection Summary).
Attachment #4
Mr. Diana asked whether there is ammonia or chlorine use outside of research labs. Mr. Diana
confirmed that because there is no other use, a Risk Management Plan is not required. There
were no site visits related to EPCRA (RTK) compliance.
Spill Prevention, Control, and Countermeasures(SPCC) Plan
Attendees: all of the above except Kelly States
The SPCC portion of the inspection was conducted by Chris Jimenez. Mr. Jimenez requested a
copy of the current SPCC Plan which was provided by Bob Ortego. According to Mr. Jimenez, a
formal inspection report should arrive approximately three weeks following the inspection. We
will be given 60 days to respond to any problems identified in that report. Based on a quick
review of the plan, the inspector identified several areas to visit:
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Princeton Energy Plant – substation, underground storage tanks, and surrounding area
Cathedral of the Air
Lewis Thomas Lab generator diesel fuel filling point
Storm drain at point where it discharges into the stream below Jadwin Hall
Hoyt Lab generator diesel fuel filling point
Charlton Street substation
Broadmead detention basin
Faculty Road (Hibben-Magie) detention basin
Mr. Jimenez noted the following:
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Visual inspection of fuel storage tanks should be documented during weekly cycling of
generators
During fuel unloading, vehicle wheels must be chocked or warning signs posted
There is a lack of secondary containment at the PEP storage tanks due to the lack of a
valve in the storm drain at the Southeast corner of Lot 28
The storage tanks at the Cathedral of the Air do not have fail-safe overfill protection or
secondary containment for loading by fuel providers.
There is no secondary containment at the loading areas for each of the emergency
generators
There is no secondary containment at the Charlton Street substation
Documentation on testing of overfill alarms should be incorporated into the SPCC plan.
Mr. Jimenez indicated that in his opinion we were overall in good shape, but that we
should expect substantial comment during his complete review of the SPCC Plan
document. While deficiencies will be noted in the inspection report, he does not
anticipate that any notices of violation will result.
Closeout Conference
Attendees: Vivian Chin, Angelo Diana, Chris Jimenez, Tom Nyquist, Bob Ortego, Garth Walters
According to Vivian Chin, we can expect a letter of findings in approximately three weeks,
however the status of all issues may not be clear at that point. If open issues remain, they will be
negotiated with individual program areas from that point forward.
Garth G. Walters
October 10, 2001