The Environmental Protection Agency, citing nearly 40 examples, told the Smithsonian Institution yesterday that it is "in violation of the disposal, use, storage, marking and record keeping requirements of the PCB regulations" and set a 30-day deadline for compliance.
In a letter yesterday to Robert McC. Adams, Smithsonian secretary, the EPA said it found leaks in 12 of 25 PCB transformers checked during an emergency inspection last week and that the Smithsonian does not have any of the annual PCB reports that have been required since 1978.
Recent records supplied by the Smithsonian to The Washington Post did not include information that the EPA said is necessary, and sources said that detailed documentation does not exist.
Smithsonian spokesman Alvin Rosenfeld said yesterday that the institution has kept its own data, but not in the form of annual reports. He said he would not answer questions about specific violations until the Smithsonian has received a copy of the EPA's full inspection report.
James M. Seif, EPA's regional administrator, said there is "no immediate danger of contact" with the polychlorinated biphenyls (PCBs) by the 30 million people who visit the Smithsonian museums annually.
After the EPA's inspection, work crews spent last Saturday cleaning up PCBs in the Museum of Natural History, the Museum of American History and the National Portrait Gallery/Museum of American Art.
Early this week, an electrical testing and engineering firm began repairing leaking transformers under an $80,000 contract.
The hazardous materials unit of the D.C. Fire Department discovered the leaks on a June 27 visit to the Museum of American History, during which unit members were ordered from the building by Smithsonian officials who said they had not cleared the visit in advance.
When asked yesterday about the ejection of the firefighters, Fire Chief Theodore Coleman said, "We have rules we have to comply with." He refused to answer additional questions about the Smithsonian and abruptly ended his regular monthly news conference.
Because PCBs produce other more toxic chemicals, including deadly dioxin 2,3,7,8-TCDD, when they are burned, the EPA considers the possibility of fire the greatest danger of continued use of electrical PCB transformers.
Fire Department spokesman Ray Alfred has said that the dangers to firefighters -- including possible liver damage, sterility, birth defects and cancer -- mean that they would enter a building where PCBs are burning only to make rescues.
A PCB fire at a Smithsonian museum could force the closure of the building for years and contaminate priceless national heirlooms, such as the Star-Spangled Banner. Experts say the cost of cleaning up such treasures is incalculable.
Smithsonian officials said that their fire protection measures make such a fire improbable, but an electrical contractor earlier this year found numerous defects in the equipment that is supposed to safeguard their electrical system, especially in the Museum of American History.
The contractor, Substation Test Co. of Forestville, recommended replacement of 35 low-voltage circuit breakers in the Museum of American History, the Smithsonian Castle and the Arts and Industries Building after 10 failed a recent inspection.
The Smithsonian said last week that Substation would also make repairs to some defective electrical equipment. But a spokesman for the firm said this week that the institution has not asked for any electrical repairs.
A number of other circuit breakers were cited as defective in a 1984 Substation report, including what a source familiar with the institution's electrical system said were 15 pieces of electrical equipment in "critical" need of repair. He said only one had been repaired.
The EPA does not have jurisdiction over the Smithsonian's general electrical system and neither does the D.C. government nor the General Services Administration.
The Occupational Health and Safety Administration is the only governmental body with authority to force repairs in the Smithsonian's electrical system, but the agency has never made an inspection there, according to OSHA.
If a private building in the District had the electrical problems detailed by Substation, immediate repairs would be required or the structure would be closed, a D.C. government building inspector said last week.
In its letter to Adams, the EPA said that seven leaking PCB transformers were found in the Museum of American History, three leaking PCB transformers were discovered in the National Portrait Gallery/Museum of American Art, and two in the Museum of Natural History.
It said at least one transformer in each building "displayed evidence of having leaked for more than 48 hours without the initiation of cleanup, containment, or repair" in violation of federal regulations.
Concerning the Smithsonian's storage of PCB fluids and wastes, the EPA said that containers were not properly marked, that they were not stored in an area with required six-inch curbing and that the institution had no records of when waste fluids were put into the storage barrels.
The EPA also said that at least 12 of the transformers did not have the proper PCB warning stickers affixed to them.
Among the records the Smithsonian was lacking were the annual reports for 1978 through 1984 and more detailed logs giving "the location of any leaks, an estimate of the amount of released PCB fluid, the date and description of cleanup, containment, and repair procedures for the leaks, and documentation of daily inspections of active leaks," the letter said.
Bill Wells, of the Smithsonian's Office of Plant Services, said in an interview this week that he noted much of the required information in his personal files, but not in the form that the EPA requires.
Wells said the Smithsonian had not developed its own reporting forms, but the night before the EPA inspection, borrowed forms prepared by the District's Blue Plains sewage treatment plant and copied them onto Smithsonian letterheads.
Wells said that in 1981, 1982, 1984 and this year, the Smithsonian paid contractors to inspect electrical equipment, including transformers, and perform preventive maintenance such as calibration and lubrication.
Copies of contracts shown to reporters by Smithsonian officials indicate that the institution has spent about $7,500 on repairs to PCB transformers since 1981. This does not include replacement of three PCB transformers -- two in the National Portrait Gallery/Museum of American Art, and one in the Museum of American History.