The thread below about the issue of the EPA acting against the owners of GG-1's for PCB's led me to do a little research. I'm not a lawyer, so if you think you have a problem-pay the piper. Speak to your atty and disposal experts.In the long run, doing it the right way lets you and your conscience sleep better at night.

There are two main federal laws that could impact the hazardous waste issues related to older RR equipment. There are others and state laws as well. These laws would not only cover PCB's, but such things as asbestos and lead paint.

The first is the Comprehensive Environmental Response Compensation and Liability Act. Commonly referred to as CERCLA (1980), it's also known as the "superfund law" because the creation of the superfund was a major part of the law.

It allows the EPA to order responsible parties-e.g, generators, transporters, owners at time of disposal or current owners/operators of the site to pay the entire cost of clean-up regardless of responsibility. Defenses are difficult to assert and a partially responsible party must sue other entities to recover costs from others that might bear some responsibility.

the RCRA (1976) allows the EPA to identify and list hazardous waste sites and to develop standards for the management of hazardous wastes by generators/transporters and to establish standards for the construction/operation of hazardous waste treatment storage and disposal facilities.

Does the EPA always find those who handle hazardous waste irresponsibly? No. A few weeks the coaches at the former market street square in Wilkes Barre, Pa were destroyed with backhoes-open air and put in dumpsters. Presumably, these coaches like a great many-had asbestos and lead paint. If so, this would be a clear violation of the standards promulgated for the handling of asbestos. (of course the owner needed to spend a significant amount of money for media ads to advocate a gunernatorial candidacy-hint-the winner). We all know of stories of locomotives that had midnight asbestos abatement as well.

Is it likely that the EPA snooping around old locomotives? Not really, just because in the grand scheme of things-there are bigger sources of wastes than GG-1's. Would they come if somebody let them know about a situation. That's more likely.

Could they? Certainly. Could you get nailed with a bill-definitely. The easiest way to limit risk is to contract with an approved waste disposal firm and keep the waste manifest (the document that specifies the proper disposition of the offensive material).

As I said, I'm not an expert, others may have had more hands on experience- I investigated and contracted for residential asbestos abatement only.



superheater@beer.com

I was utilities supervisor at a very large chemical plant that had everything. We had it all lead, asbestos, PCB, chrome, nickel, and all of the rest. We could not dig a hole in the ground without a suit and full respirator. Everything was contaminated and we had hundreds of tons of asbestos and thousands of gallons of PCB and other wonderful liquids. Here are a few things I know from first had experience.

Large facilities have their own transformers because it is cheaper to buy power at higher voltages. Many old plants have old transformers and many still have old oils. You donÂ’t get fined for having them; you get fined for mishandling them or getting rid of them in an unapproved fashion. The same goes for asbestos; it is still in many places including pipe insulation, boiler refractory, and floor tiles. You donÂ’t get into trouble for still having it, it is when you handle it improperly that the law comes down on you.

Next, the EPA only handles the really big stuff; something like an old electric locomotive would be in the hands of a state or local jurisdiction. My former company had under-reported VOC emissions for something in excess of 10 years. They were the largest polluter in the state at the time and the fine was only $300,000 for millions of pounds of pollution. The state handled it, not the EPA as it was still considered small stuff.

Now look at this rumor that Mitch is passing around. He claims fines of hundreds of thousands of dollars for something to do with an unnamed historic locomotive at a museum. If the locomotive was a 246-ton GG-1 made of solid asbestos soaked PCB it would maybe rate a fine in that range.

This guy doesnÂ’t know what he is talking about and these types of rumors should be wiped off of this board. I donÂ’t believe anything when someone who does not use his full name or email posts something so vague with such big claims. Like I said before the BS detector is going beep beep beep.

Tom Gears
My real name

Forgotten Delaware
tom@forgottendelaware.com

I would defer to your real world experience on the plausibility of Mitch's post.

I'll confess a certain bias on the topic, especially the white stuff. I had an uncle pass away from lung cancer in 1997. He made the mistake of working at Johns-Manville for a couple of months in the early 60's. Its a hell of a thing to see a healthy 180-something pound guy go to 122 in 14 months. Not worth exposing yourself.

superheater@beer.com

Superheater,

I am sorry to hear about your uncle. I was by no means saying that any of this stuff is okay or good. I am a former plant supervisor due to the fact that I switched to teaching to get away from all of the bad stuff. We know how to deal with it safely now when it comes time to remove it, it is when we ignore these procedures that we put people at risk and fines are in order.

Tom

Forgotten Delaware
tom@forgottendelaware.com

> I'll confess a certain bias on the topic,
> especially the white stuff. I had an uncle
> pass away from lung cancer in 1997. He made
> the mistake of working at Johns-Manville for
> a couple of months in the early 60's. Its a
> hell of a thing to see a healthy
> 180-something pound guy go to 122 in 14
> months. Not worth exposing yourself.

Superheater,

I also offer my condolences. However, I was at one point in my career in the unique position of working in a WAREHOUSE full of records pertaining to the Manville lawsuits (now, this was ONE asbestos company's plaintiffs, and the individual case folders filled five floors of a two-football-fields-large records warehouse). I probably shouldn't even be blabbing about the stuff I read in folders out of boredom, but:

There was, and still is, a big difference between a one-off exposure to stuff like asbestos, PCBs, etc. and working with the stuff day in and day out for years. I handled records on pipefitters with the Navy, and boilermakers with the PRR and B&O, and have heard personal anecdotes of such things as men going off to work in clean clothes and coming home looking like snowmen. I will never doubt for one minute the hazards these men were exposed to.
On the other hand, when one sees a folder on a guy who worked for six months for a plumber, and smoked three packs a day for a decade, and he's trying to say the lung cancer was due to asbestos exposure, well.........

But when someone sees flaking asbestos on an old locomotive and immediately reacts like a chunk of the Chernobyl reactor has just banded before them, that's when I'm forced to roll my eyes.


lner4472@bcpl.net

> Superheater,

> I was > by no means saying that any of this stuff is okay or good.

No problem. Didn't think you were, just admitting my bias. I was very devil-may-care about this stuff until then, assumed that the alarms were all hype. If somebody else thinks twice about being cavalier, profits from anothers misfortune... I've done some good.



superheater@beer.com

> Thanks for kind thought.(Tom as well) Correct about smoking. Oncologist indicated that smoking while being exposed does greatly increase likelihood of getting the cancer, but did say tumor was "almost certainly" caused by asbestos exposure. I was shocked such accute exposure could lay dormant for 30-35 years and pow.



superheater@beer.com

I have no doubt that asbestos is harmful to the lungs, however the whole PCB thing baffles me. I live in a town where at one time one of the largest employers was making transformers (plant is now ABB owned). If recollection serves me correct they did a study of past employees who were exposed daily to PCBs for years (basically bathed in the stuff) and their conclusions were that the workers had no higher incidence of cancer or any other health issues than the general population. So where did the almighty PCB scare come from anyway? Some lab rat who got cancer after ingesting high concentrations for an extended period of time?

b.hume@rogers.com

Let me add my condolences. The people damage from the "industrial revolution" is truly staggering and will be with us for quite awhile. Follow the link below for PCB info.

http://www.easternenvironmental.com/faq.shtml
lamontdc@adelphia.net

> If
> recollection serves me correct they did a
> study of past employees who were exposed
> daily to PCBs for years (basically bathed in
> the stuff) and their conclusions were that
> the workers had no higher incidence of
> cancer or any other health issues than the
> general population. So where did the
> almighty PCB scare come from anyway? Some
> lab rat who got cancer after ingesting high
> concentrations for an extended period of
> time?

PCBs are the only compound that is listed in federal environmental legislations. TSCA regulates compounds which are found to be carcinogens, mutagens or teratogens.

There were two main reasons why PCBs were listed. These are: 1) Prolonged skin exposure did cause chloracne; and, 2) PCBs persist in the environment.

At the time, chloracne was thought to be an indicator of a carcinogenic compound.

Environmental persistence was and still is considered to be potentially harmful to the environment. This was based upon the data gathered about DDT. As DDT accumulated in the food chain, it was found to cause shell thinning in birds. The bald eagle almost disappeared in the 60's as a result of bioaccumulation of DDT.
Hope this helps.

> You donÂ’t get fined for having them; you get
> fined for mishandling them or getting rid of
> them in an unapproved fashion. The same goes
> for asbestos; it is still in many places
> including pipe insulation, boiler
> refractory, and floor tiles. You donÂ’t get
> into trouble for still having it, it is when
> you handle it improperly that the law comes
> down on you.

> Next, the EPA only handles the really big
> stuff; something like an old electric
> locomotive would be in the hands of a state
> or local jurisdiction.

On the issue of PCBs (polychlorinated biphenyls), Tom is correct. It is the issue of media contamination (soil and groundwater) and disposal of the material that cause problems. A release or threat of a release greater than one pound of PCBs into the environment triggers a reporting and cleanup requirement.

Most production and use of PCBs was banned in 1979 by EPA, due to health impacts. It is still around in transformers and other electrical equipment because it will last anywhere from 15 to 25 years before needing replacement. Replacement is usually necessary because of eventual leaks. Any equipment containing PCBs is required to be properly labled or marked, and records maintained. How this may specifically be applied to an electric locomotive in a museum, I am not sure, but it is certainly worth investigating if you have one of these beasties in your collection. I would try an anonymous call to your state environmental protection section to ask some basic questions. If nothing else, I would mark any transformers known or suspected of containing PCBs in such a manner that future work on the equipment did not result in a release.

PCBs were used as an additive in dielectric fluids because they are stable at high temperatures. You may have fluorescent light fixtures in your building that have PCBs in the ballast. Ballasts manufactured before 1979 may contain them. Most manufactured since then will have the notation "NON-PCB". As mentioned further down this thread, it is also long-lived in the environment. It does not degrade easily, and don't try burning PCB-containing oil to dispose of it. Low temperature combustion of PCBs generates compounds even more nasty than the PCBs.

I don't know much about electric locomotives, but if someone were to get a GG1 operating now, the oil in the transformers would, in all likelihood, need to be replaced. The removal of the oil, cleaning the transformer and disposal of the wastes would need to be handled by an experienced and qualified company. If not properly handled, the possibility of fines is real, assuming of course that you are caught. And just because you don't get caught in the next 90 days doesn't mean you will never be caught.

Most commercial property sales are accompanied by a Phase I Environmental Site Assessment (ESA). A properly conducted ESA will identify all manner of real and potential problems associated with use of hazardous material and disposal of hazardous waste. Any reliable waste disposal company dealing with petroleum will need to know if the oil is possibly contaminated with PCBs. If you don't know, they will not likely accept it. If they do, and their tests later show the contamination, you could be liable for any disposal/cleanup costs related to the entire batch of waste oil yours was introduced into. So, best advice, handle the stuff properly. Yes, it will cost more up front, but you will not have to worry about it again. Just keep your disposal documentation!

Same thing for asbestos.

Stephen

syfrettinc@bellsouth.net

On the other hand. Could the posts be the result of a museum or railfan organization who was caught illegally and/or improperly disposing of hazardous material? Anyone who practices the old saying "I didn't see that, therefore it did not happen" deserves whatever happens to them. The downside being that the rest of us get tarred and feathered with more government regulation and higher insurance costs.

Just a thought.

jimhollis@ev1.net

All of your credentials may be impressive, but guys get off the soapbox. The feds are coming and I'm afraid it will not be pretty. I'm hiding behind my name so that others will benefit from my "heads up".

Take it or leave it, that's the way it is.

> I was utilities supervisor at a very large
> chemical plant that had everything. We had
> it all lead, asbestos, PCB, chrome, nickel,
> and all of the rest. We could not dig a hole
> in the ground without a suit and full
> respirator. Everything was contaminated and
> we had hundreds of tons of asbestos and
> thousands of gallons of PCB and other
> wonderful liquids. Here are a few things I
> know from first had experience.

> Large facilities have their own transformers
> because it is cheaper to buy power at higher
> voltages. Many old plants have old
> transformers and many still have old oils.
> You donÂ’t get fined for having them; you get
> fined for mishandling them or getting rid of
> them in an unapproved fashion. The same goes
> for asbestos; it is still in many places
> including pipe insulation, boiler
> refractory, and floor tiles. You donÂ’t get
> into trouble for still having it, it is when
> you handle it improperly that the law comes
> down on you.

> Next, the EPA only handles the really big
> stuff; something like an old electric
> locomotive would be in the hands of a state
> or local jurisdiction. My former company had
> under-reported VOC emissions for something
> in excess of 10 years. They were the largest
> polluter in the state at the time and the
> fine was only $300,000 for millions of
> pounds of pollution. The state handled it,
> not the EPA as it was still considered small
> stuff.

> Now look at this rumor that Mitch is passing
> around. He claims fines of hundreds of
> thousands of dollars for something to do
> with an unnamed historic locomotive at a
> museum. If the locomotive was a 246-ton GG-1
> made of solid asbestos soaked PCB it would
> maybe rate a fine in that range.

> This guy doesnÂ’t know what he is talking
> about and these types of rumors should be
> wiped off of this board. I donÂ’t believe
> anything when someone who does not use his
> full name or email posts something so vague
> with such big claims. Like I said before the
> BS detector is going beep beep beep.

> Tom Gears
> My real name

> All of your credentials may be impressive,
> but guys get off the soapbox. The feds are
> coming and I'm afraid it will not be pretty.
> I'm hiding behind my name so that others
> will benefit from my "heads up".

> Take it or leave it, that's the way it is.

I think it might be useful if you provided a link to a public news source or governmental website detailing this initiative.

My mind is open. I worked in a capacity where I was involved with the geds (IRS & DOL) and I am aware that on occasion, small but showy "initiatives" are done for the value of visibility or because a bureacrat gets a wild hair.

If you can provide some independent corroboration-most of the folks here will give you an ear.



superheater@beer.com

Mitch, we trade in verifiable hard information here, not rumor. It's the general practice on the Interchange to back up assertions with public records, hyperlinks, contact phone numbers, or at least a full name and/or an email address so people can contact you back channel for more information.

In the absence of any of these, we have no choice but to discount your (or any other equally unsupported) message as noise, not signal. Nothing personal, that's just the way we filter what's reliable from what's not here.