In its report to the federal court, EPA noted that CUC’s typhoon response plan is more focused on protecting personnel.
The plan did not provide a framework for response at the facility, EPA said.
Based on the second joint stipulation, CUC was required to submit an interim facility response plan by April 25.
But CUC failed to meet the deadline and is months behind schedule for tank cleaning and repair operations, EPA said.
CUC general counsel Deborah Fisher told the court that the utilities agency is hoping that once a facility response plan is approved, the typhoon preparedness plan will either be replaced or it may become an integral part of the facility response plan.
Secondary containment
CUC also reported to the court the completion of the secondary containment system of Power Plants 1 and 2.
Except for the roofing, most of the metal structure has been installed, CUC said.
At Power Plant 4, the secondary containment construction is complete but there are technical issues.
EPA expressed concern regarding the generator and pipeline areas which it said were not constructed effectively.
However, according to CUC, Pacific Marine and Industrial Company, the power independent producer that administers Power Plant 4, is currently developing a plan which will be submitted to EPA regarding the additional work.
In its assessment of the Rota power plant, EPA noted that its transformers were being stored with no secondary containment and certain secondary containment areas had holes drilled in the bottoms.
CUC said it already transferred the transformers, sealed the secondary containments that had holes and replaced the open valve that could be padlocked in the closed position.
“They will not be opened without supervision from appropriate staff to drain storm water,” CUC said.
Tank cleaning work plan
CUC said Tank 104 is now fully cleaned and empty and will no longer pose a major environmental or safety risk.
The CNMI Division of Environmental Quality is in the process of permitting Tank 106 for service.
Tank 105, CUC said, is undergoing repair. The bad weather in the past weeks, it added, has contributed to delays.
Tank 101, 102 and 107 have been cleaned and removed, CUC added.
CUC said the cleanup for Tanks 107 B and 108 has been postponed while new Tank 101 has been purchased although funding for the installation has not been obtained.
EPA has identified funding from the previous Department of the Interior grant for installing the tank and performing quality assurance and quality control work.
CUC said it received approval on Aug. 25 from EPA on the sampling and disposal plan for the oil contaminated soil found underneath the original Tank 101 which has been demolished.
The tank cleanout plan for Power Plant 4 is now in the final stages of completion, CUC said, adding that PMIC has requested an extension until Sept. 17 to submit its plan.
The tanks at Rota power plant have been cleaned and inspected and repair has been ongoing.
But EPA, citing its inspection, identified some issues with the pipelines on Rota. Repair has been postponed until Tank R-1 inspection and repair occurs.
