PCB Cleanup Under the Mega Rule

Larry - Sue has done an nice job of providing an outline of what is
required. As you will see do not worry about the 30 day rule for materials
that we are not actively managing. When you see the timetable for the EPA to
respond you will realize that....

this is a big help but a lot of work is required and we will need Donna
Mullins to sign off on what we discussed....
---------------------- Forwarded by Louis Soldano/ET&S/Enron on 01/24/2000
12:18 PM ---------------------------
Susan Fernandez 01/21/2000 11:11 AM

To: Louis Soldano/ET&S/Enron@ENRON
cc: William Kendrick/OTS/Enron@ENRON

Subject: PCB Cleanup Under the Mega Rule

Lou -

Attached is a revised version of the bulleted document I created addressing
characterization and cleanup of PCB contaminated concrete. I revised the
document to include contaminated soils (i.e., bulk remediation waste) and
additional information about cleanup levels.

Generally - My understanding of the rules is that EPA requires cleanup to 100
ppm in low occupancy areas if the contaminated area is capped and deed
recorded. Disposal in place of PCBs at concentrations higher than 100 ppm
requires written EPA approval.

Sue