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Commissioner Peder A. Larson <br />April 15, 1997 <br />Page 5 <br />and batteries. The amount of off -site shipments far exceeds the amount used by the MPCA to <br />establish liability in its PRP identification effort. <br />3. MPCA staff speculated that Schnitzer broke or cracked batteries and that releases <br />from those operations contributed to the contamination at the site. The Schnitzer site history <br />indicates that battery breaking only occurred on a one time experimental basis inside the building <br />on the site at a time long before the current business records utilized to establish liability in this <br />matter. A review of the business records reveals that although Schnitzer owned a piece of <br />battery breaking equipment, it was sold in May 1972. The documents related to that transaction <br />confirm the statement made by Schnitzer representatives that any breaking of batteries was done <br />only on an experimental basis and inside the building. <br />4. The only batteries handled in the yard were those in automobiles that arrived at <br />the Schnitzer facility. Automobile scrapping operations at the Schnitzer yard date back to at <br />least the 1950s. Although it is possible that some of the batteries from these cars were crushed <br />or burned with these vehicles, the Schnitzer employees we interviewed indicated that car <br />batteries were removed from cars, stored temporarily on pallets in the yard and routinely added <br />to stockpiles in the metals room. We are not aware of any documentation indicating that any <br />of the members of the Schnitzer Group sent automobiles to the Schnitzer site. One of the <br />employees we spoke with told us that the City of Minneapolis had a contract with Schnitzer to <br />handle all abandoned vehicles. That may mean that the City of Minneapolis could be one of the <br />largest responsible parties. Presumably that is why it has joined with the University as a <br />remediating party. <br />5. During the period 1950 to 1970 an undetermined number of transformers were <br />accepted at the Schnitzer site. Based on interviews with former employees, a limited number <br />of transformers were accepted on an irregular basis and only during certain years of operation. <br />Transformers themselves are not 'a source of PCBs. Rather, the alleged source of PCBs is <br />contaminated transformer oil. How the transformers were handled and whether they contained <br />contaminated transformer oil with PCBs is unclear and the basis for liability on the part of PRPs <br />is questionable. In fact, the available data revealed that the PCBs that are prevalent at the site <br />are predominantly Aroclor 1248, a specific form of PCBs not associated with transformer oil <br />(Aroclor 1260). Although the MPCA identified the University as a source for transformers, the <br />MPCA's de minimis process attributes no liability to suppliers of transformers. <br />6. Other activities associated with the handling of scrap metal, particularly, the <br />burning, dismantling and crushing of cars, the discharge of gasoline to the ground, the handling <br />and storage of uncleaned motor blocks and the handling of porcelain coated tubs, sinks and <br />appliances (containing capacitors) together with the processing of other painted scrap metal, <br />contributed significantly to the lead and PCB contamination at the site. <br />