Document 2Rd43EdX7ggg4ENbo21Nz3D2a

DRAFT "T his R eport Is Not Meant To Be An Exhaustive Study. It Was P repared In Response To A Specific Inquiry For Rapid R etrieval And Assembly Of Information" MARKET INPUT/OUTPUT PROFILE, PROCESS TECHNOLOGY ASSESSMENT AND ENTRY INTO THE ENVIRONMENT OF POLYCHLORINATED BIPHENYLS (PCBs) TASK ORDER NUMBER 1 PREPARED BY FOSTER D . SNELL . INC . FOR UNITED STATES ENVIRONMENTAL PROTECTION AGENCY UNDER CONTRACT NUMBER 6B-01-210G DECEMBER 1973 NV 036323 TABLE OF CONTENTS SECTION I FINDINGS AND CONCLUSIONS SECTION II SECTION III RECOMMENDATIONS INTRODUCTION SECTION IV PRODUCTION QUANTITIES EXHIBIT I Composition of Different Liquid PCB Products EXHIBIT II PCB M anufacture and Sales Monsanto Industrial Chemicals Co. EXHIBIT III End-Used of A roclors SECTION V MANUFACTURING PROCESSES EXHIBIT IV Patent Digest EXHIBIT V Process Flow and Environmental Controls at Monsanto's Sauget Plant EXHIBIT VI Shipping of Aroclor Plasticizers EXHIBIT VII Example of C urrent Aroclor Labeling Practice EXHIBIT VIII Excerpts From NEMA's Proposed Environmental Controls EXHIBIT IX . Disposai Services Listcd in Section 4 of NEMA's Official Standards Proposai Page 1-1 II-l in -i IV -l IV-11 V -l V-6 NEV 036324 TABLE OF CONTENTS (continued) SECTION VI MANUFACTURING PROCESSES IN WHICH PCBs ARE USED EXHIBIT X H istorical D istribution of PCB Types and End-Use EXHIBIT XI PCB Use in the Electrical In d u stry EXHIBIT XII T ransform er T rends (1967-1974) EXHIBIT XIII Fluorescent Lamp Ballast Shipments (1963-1972) EXHIBIT XIV PCB Losses in Capacitor M anufacture EXHIBIT XV Transform er Imports EXHIBIT XVI E xcerpts From B roadhurst On PCB Technology in Open Systems and Heat Transfer EXHIBIT XVII PCB Levels Associated With Various Pr odue ts/P r ocess es SECTION VII THE ENTRY OF PCBs INTO THE ENVIRONMENT AND MANAGEMENT STEPS EXHIBIT XVIII PCB Service Life Functions EXHIBIT XIX Example of the Use of PCB Service Life Functions: Estimate of Capacitor PCBs In-Service EXHIBIT XX H istorical Pattern of PCB Channels To The Environment SECTION VIII BIBLIOGRAPHY Page VI-1 VI-17 VH-1 VII- 12 VIII- 1 NEV 036325 ABSTRACT The Office of Toxic Substances of the United States Environmental Protection Agency issued a task o rd er to Foster D. Snell, Inc. under Contract No. 68-01-2106 to p re p a re a broad re p o rt on a rap id response basis on the ''Market Input/O utput Profile, Process Technology A ssessm ent And Entry Into The Environment Of Polychlorinated B iphenyls (PC B s)". The study scope included literature review , patent analysis and strategic interview s. The Monsanto Industrial Chemicals Company is the sole use producer of PCBs under the "Aroclor" tradem ark. Production capacity is about 48 million l b s . a n n u ally . Imports appear to constitute 2%o r less of domestic usage. In recent y ears the use of PCBs has been voluntarily confined by Monsanto, essentially completely to transform er and capacitor applications. Roughly 500 million lb s . of PCBs are c u rren tly in -sc rv ic e , over 95% in transformers and capacitors. Recommendations include in-depth study of the m arket, technical and environmental aspects of PCB use in transform ers and capacitors. PCB management steps recommended for further evaluation are: banning use of the commodity in non-electrical applications and the granting of exemptions case-by-case: formal sanctioning of the National Standard Guidelines For Handling and Disposal of Capacitor - And Transform er - Grade Askarels Containing Polychlorinated Biphenyls: establishment of an enforcement mechanism that also applies to import controls. NEV 036326 SECTION I NEV 036327 SECTION I FINDINGS AND CONCLUSIONS This section serves as an executive summary of principal findings and conclusions related to PCB m arket tre n d s , technology and environ mental control patterns and information gaps. 1. PCB PRODUCTS ARE MIXTURES OF VARIOUS HOMOLOGS OF CHLORINATED BIPHENYL 11) Contaminants And Im purities In The Product Are Determined By The Quality Of The Starting M aterials And Process Conditions (2) The Unique Physical And Chemical P roperties Of PCBs Have Made These Substances Technically Attractive In A Variety Of End Uses (3) PCBs Have Been In Commercial Use In The U .S . Since The 1920s (4) The Tetrachloro And Lower C hlorobiphenyls A ppear Less Persistent In The Environment Than The Higher Chlorobiphenyls 2. THE MONSANTO INDUSTRIAL CHEMICALS COMPANY IS THE SOLE U .S. PRODUCER OF PCBs 3. MONSANTO'S CURRENT APPROXIMATE NAMEPLATE PRODUCTION CAPACITY IS 4B MILLION LBS. PCBs PER YEAR (36) 4. ANNUAL STATISTICS FOR U .S. PRODUCTION AND SALES OF AROCLORS SHOW MARKED DECREASE CAUSED BY RESTRICTION OF USE TO ELECTRICAL APPLICATIONS SINCE 1971 (1) Monsanto No Longer Sells PCBs For End-Uses Other Than Capacitor And Transformer Insulating Liquids (2) Domestic Sales Of A roclors Are Expected To Increase At An Average Annual Rate Of 7.4% Over The Next Five Years NEV 036328 1-1 5. THE PATTERN OF WORLD COMMERCE IN PCBs INDICATES LOWER FUTURE PRODUCTION AND RESTRICTED USAGE (1) Import Statistics Indicate That Only About 2% Of PCBs Sold In The U .S . Were Imported In 1971 And About 1.4% In 1972 (2) Imports of PCBs Are Expected To Be Less Than 2% Of Total U .S . Sales D uring The Next Five Y ears (3) D uring The Period From 1963 Through 1972 Exports Of Aroclors Were 78.7 Million Lbs. (4) Exports of Aroclors Are Expected To Maintain The Same Ratio To U .S. Sales As In The F ast Several Years [36). Or 10-15% (5) Known Foreign Producers of PCBs Include Czechoslovakia France. Germany, Italy, Japan. Spain, and the U .S.S.R . (6) World Commerce In PCBs Is Expected To Decrease By About The Same Amount Or More Than In The U .S. Since 1970, And To Be Essentially Confined To Capacitor And Transform er Applications 6. THE MANUFACTURE OF PCBs' IS NOT A COMPLEX PROCESS (1) C urrently There Is Only One Known Commercial Scale FCB Production Installation In The U .S .. Operated By Monsanto (2) Monsanto Has Reported Significant Environmental Controls At This Plant 7. HISTORICALLY, AROCLORS HAVE BEEN SHIPPED IN A FASHION SIMILAR TO ANY OTHER COMMODITY Both Monsanto and the National Electrical M anufacturers Association (NEMA) have taken special steps toward environmental controls in future tran sp o rt of PCBs. NEV 0363 29 1-2 B. THERE IS EVIDENCE OF RESEARCH AND DEVELOPMENT ACTIVITY TO CONTROL SPENT PCBs Envirotech Corporation reported an energy saving method of combusting waste PCBs. In Japan chemical destruction methods have been studied. 9. DURING THE PERIOD FROM 1957 THROUGH 1973 (PROJECTED) , ACCUMULATED U .S . CONSUMPTION OF PCBs WAS ABOUT 775 MILLION L B s., INCLUDING IMPORTS (1) P u rin a The Period From 1957 T hrough 1973 Approximately 234 Million L bs. Of PCBs Were Used In "Open" Systems And Approximately 541 Million Were Used In "Long Lived Contained" Systems (2) During The Period From 1957 T hrough 1971, Approximately 46% Of A roclors Sold In The U .S , Were The Least P ersisten t T richloro Or Lower C hlorobiphenyls (12) (3) An Estimate Of The Total A roclor Used In The U .S . In Electrical Systems Since 1934 Is 752 Million L bs. (4) An Estimate Of The Total A roclor Used In The U .S . In N on-Electrical Systems Since 1934 Is 367 Million Lbs. (5) An Estimate Of The Reasonable U pper Limit On Total PCB Consumption In The U .S . Since 1934 Is 1,175 Million L b s ., Assuming A 5%C onservative M argin For Imports And Statistical Uncertainty (6) Before 1971 T here Were 10 to 15,000 Direct P u rch asers Of A roclors. While C urrently There Are 25-30 . These p u rc h a se rs ordered A roclors directly from Monsanto Papageorge (36) reported that the o rd er of'm agnitude of p u rc h a se rs of Aroclor in 1971 or before in each end-use category is as follows: - Heat T ransfer - Hydraulics - Lubricants - Misc. Industrial : ; : - Transformers and Capacitors : - Plasticizer Applications : 1-3 2,000 3,000 "few" "several thousand" 40-50 2,000 NEV 036330 Many of these purchasers were distributors further disbu rsin g PCBs to countless small accounts (36) Since Monsanto's voluntary restriction of sales and other control actions, th ere are c u rren tly 25-30 d irect customers, all in transformer and capacitor applications. These customers use PCBs askarels in the finished products (capacitors and transform ers) or* in the course of servicing. 10. 1973 USE OF PCBs BY THE U .S. ELECTRICAL INDUSTRY IS ESTIMATED AT 36 MILLION POUNDS AND IS EXPECTED TO INCREASE TO ABOUT 51 MILLION FOUNDS BY 1978 (1) The Average Annual Growth Rate For PCB Use By The Electrical Industry D uring The 1963-1973 Period Is 4.6% And This Is Expected To Increase To About 7.4% Through 1978 (2) P resen t Production And Handling Procedures Adopted By Major Transform er And Capacitor M anufacturers (16) Minimize Environmental Contamination (50) (3) The Capacitor And T ransform er M anufacturing In d u stry Is A Highly Concentrated Industry A ccording to the National Electrical M anufacturers Association (16), its member companies have the major share of this m arket to the utility in d u stry . 22 transform er p ro d u cers 6 capacitor producers According to the Certified B allasts M anufacturers Association (53) th ere are only 10 m anufacturers of fluorescent lamp ballasts. (4) The Consumer Sector (Principally Electric Utilities) Is Becoming Increasingly Conscious Of The Need To Reduce Environmental Contamination (5) The Value Of Imported T ransform ers In 1973 Is Estimated At 50 Million And Is A Small Portion Of Total T ransform er Sales . Probably only few im ported transform ers contain insulating oils due to sh ip p in g , handling and economic considerations. 1-4 NEV 036331 . There is indication that probably relatively insignificant num bers of askarel type tra n s formers are imported. (B) Near Term Replacement Of PCBs In Most A skarel E lectrical Applications Is Technically Not Feasible 11. OPEN SYSTEMS END-USES HAVE ENCOMPASSED A BROAD RANGE OF APPLICATIONS IN WIDELY DISTRIBUTED PRODUCTS AND PROCESSES (1) The Applicability Of PCBs In Open Systems Is W ide-Ranging (2) In Most Open Systems Situations The Concentrations Of PCBs Associated With The P roduct/P rocess Have Probably Been Low Percentages (3) During The Next Five Y ears. Imports A re Expected To Be Essentially The Sole Source Of F resh PCBs In Open System End-U ses With Investm ent Casting Accounting For A Major Portion 12. BASED ON A SNELL LIFE CYCLE MODEL. ABOUT 500 MILLION LBS. OF PCBs ARE IN-SERVICE, ESSENTIALLY ALL IN ELECTRICAL APPLICATIONS (1) Nelson (38) Estimated That The Equivalent of 60% Of The Annual PCB Usage Was Scrapped In 1970 (2) A Life Cycle Model Developed From F u rth e r Evaluation Of N elson's (38) Assumptions Regarding The Scrappage Rates Of PCBs, Indicates That The Equivalent Of Only About 26% Of The Annual PCB Usage Was Scrapped In 1970 The total amount of PCBs in -serv ice through the end of 1973 was estimated using the model. The table below presents in -service estimates by end-use category. End-Uso PCB Quantity In-S ervice Through 1973 (million lb s .) Transform ers Capacitors Heat exchangers Plasticizer applications Hydraulic fluids and lubricants Miscellaneous industrial applications 205 270 11 negligible 9 negligible Total 495 1-5 NEV 036332 At the end of the next five y e ars only a negligible amount of PCBs will still be in non-electrical service. 13. SIGNIFICANT STEPS HAVE ALREADY BEEN TAKEN TO ENVIRONMENTALLY MANAGE PCBs IN PRODUCTION, CONSUMPTION AND COMMERCE Cl) The Monsanto Company, The Sole U .S. P ro d u cer, Has Led Environmental Control Of PCBs (2) The Market Statistics Suggest That The G reat Majority Of Open System U sers Of PCB Have Found A lternatives To This Commodity, But T here Has Not Been A Sense of Urgency To Eliminate PCBs Already In Service (3) The C urrent B uyers Of PCBs For Capacitor And Transform er Insulation Have Taken Formal Steps Toward Environmental Control (4) The Control Of PCBs Already In The Environment Is Not Feasible, Except In Highly Localized Situations (5) Regulatory Action Can A ssure Enforcement Of Controlled Use Of PCBs In The Future 1-6 NEV 036333 SECTION II NEV 03633^ SECTION II RECOMMENDATIONS In this section recommendations are presented related to further work to define the movement of PCBs through the commercial and wastage cycle. Other recommendations ad d ress PCB management stra teg ies. I . IN-DEPTH SURVEY OF THE ELECTRICAL INDUSTRY IS RECOMMENDED The purpose of the proposed su rv ey is to obtain detailed information of PCB use practices in the electrical in d u s try , which now accounts for essentially all the PCBs consumed in the U ,S . T here is strong evidence that in the near-term replacem ent of PCBs in the c u rre n t electrical uses would pose serious technological as well as institutional problem s. The scope of the proposed su rv ey is to define in-depth . shipping and handling of PCBs for electrical end-uses . transformer and capacitor manufacture and use technology environmental protection practice technical adm in istrativ e market configurations production and distribution of askarel capacitors and transformers use of these forecasts of production, d is tri bution and use . research and development status replacement of PCBs environmental controls NEV 03335 t economic impact of limiting PCB use in the electrical industry with respect to specific management strategies ; The proposed survey methods include literature review and telephone and visit survey of individual firms through the coordination of Industry associations. i ** Without economic impact assessm ent, the estimated level of effort required is B-10 man-months over a four month perform ance p erio d . . i* i i i II I i fi i' [ I I ri NV 036336 11-2 i 2. EVALUATION OF SELECTED FCB MANAGEMENT OPTIONS IS RECOMMENDED Study of the following PCB management concepts is recommended: . Formal banning of the sale or purchase of FCBs for non-electrical u se s, and the grant ing of exemptions on a case-by-case basis Formal sanctioning of the National Standard Guidelines For Handling and Disposal of Capacitor - And Transform er - Grade Askarels Containing Polychlorinated Biphenyls . Establishing an enforcement mechanism that also applies to Importing of PCBs NEV 036337 11-3 SECTION III I i I NEV 036338 SECTION III INTRODUCTION In conjunction with its hazardous m aterials control activities, the Office of Toxic Substances of the United States Environm ental Protection Agency (EPA) has issued the second task o rd er to F oster D. Snell, Inc. (Snell) un d er C ontract No. 68-01-2106 to p rep are a re p o rt on the "M arket Input/O utput Profile, P rocess Technology A ssessm ent, And Entry Into The Environment Of Polychlorinated Biphenyls (PCBsl" . The report summarizes the findings developed during the six w eek, rapid response effort to assemble this information from lite ra tu re re v ie w , market re se a rc h , technology assessment and selective interview ing of industry sources. 1. PURPOSE There is need for improved definition of the movement of PCBs through the various production/consum ption/was tags steps of our complex economy, both in terms of the respective PCB quantities and processes involved. The purpose of this study is to assimilate existing scattered information pertaining to this for an integrated definition, and to identify fu rth er information n eed s. The study outputs are designed to aid EPA in understanding the historical and c u rre n t commercial status of PCBs and to provide technical su p p o rt to decision making regarding the control of these su b sta n c es. 2. APPROACH AND SCOPE The rapid response effort to this task order is based upon literature search and review , selective interview s with industry so u rces, patent summarization and technology assessm ent, and market research. To obtain p e rtin e n t references on polychlorinated b ip h e n y ls, in addition to the S n elfan d EPA (Washington) lib ra rie s , the following places w ere visited: The Chem ist's Club (N.Y.) , Commerce Department Library (N.Y.) , Custom's Bureau (N.Y .) , the Tariff Commission (N .Y .), and the Engineering Society Library (N.Y.) . The card catalogs of the lib raries w ere review ed and the following indices w ere perused: Business Periodicals . Engineering NEV 036339 111-1 . Applied Science and Technology . Funk and Scott . Predicaste . Chemical Marketing A bstracts . Chemical Engineering Government Reports . Search The useful citations obtained are contained within the bibliography accompanying the report. In addition, personal communication was established with the following sources: . Monsanto Industrial Chemicals Corporation . National Electric M anufacturers Association (NEMA) . Edison Electric Institute (EE1) Selected transform er and capacitor manufacturers Other industry sources The cooperation of the Monsanto Industrial Chemicals Company, the sole U .S. producer of PCBs, is acknowledged. NEV 036340 Ill-2 SECTION IV NEV 036341 SECTION IV PRODUCTION QUANTITIES In this section market statistics are presented regarding the sources of polychlorinated biphenyl (PCB) p ro d u cts. 1. PCB PRODUCTS ARE MIXTURES OF VARIOUS HOMOLOGS OF CHLORINATED BIPHENYL Whenever aromatic hydrocarbons such as biphenyls are chlorinated, the product is a mixture of compounds, including isom ers. The In ter departmental Task Force on PCBs (1) summarized the composition of the different liquid chlorinated biphenyl products used predominantly in the U .S ., as shown in the first page of Exhibit I. The second page of the exhibit shows typical percent composition of the materials currently m arketed. (1) Contaminants And Im purities In The Product Are Determined By The Quality Of The Starting M aterials And P rocess Conditions Fractionation of samples of some PCBs of foreign manufacture indicated the presence of tetra and pentachlorodibenzofurans and hexa-and heptachloronaphthalenes ( l, 20) Papageorge (36) indicated th at, within the lim its of detectability, PCBs produced by the Monsanto Industrial Chemicals Company have not been found to contain these im purities. Monsanto uses biphenyl feedstock of high purity Monsanto neutralizes the reaction mass with lime rather than caustic soda (used in Europe) NEV 0363^2 IV-1 (2) The Unique Physical And Chemical P roperties Of PCBs Have Made These Substances Technically A ttractive In A Variety Of End Uses The most important physical properties of PCBs are low vapor p re ssu re s (high boiling p o in ts), low water solubility, and high dielectric constants. They are miscible with most organic solvents and compatible with many types of polym ers. Although some individual PCB compounds are cry stallin e, commercial m ixtures have been either liquids or resins. The chemical properties that make PCBs desirable in dustrial materials are: excellent thermal stability, strong resistan ce to both acidic and basic h y d ro ly sis, general in e rtn e ss and resistan ce to oxidation. . Specific data on these properties are summarized in the Encyclopedia of Chemical Technology (11). (3) PCBs Have Been In Commercial Use In The U .S . Since The 1920s T his re p re se n ts over 40 y ears of in d u stria l application. Early applications of PCBs w ere prim arily as insulating fluid in the electrical industry and as heat transfer fluid (14). In the early 1960s several new applications were promoted (14). (4) The Tetrachloro And Lower Chlorobiphenyls Appear Less Persistent In The Environment Than The Higher Chlorobiphenyls . Nelson (38) summarizing the findings of several w orkers found evidence supporting this conclusion. . T ucker of Monsanto (12) also concluded this and made the following correlation based on the homolog distribution of PCBs sold by the company from 1957 to 1971. NEV 036343 IV-2 PCB Chlorine Homolog 0 1 2 3 4 5 6 7 8 Percent Homolog in Monsanto U .S. Sales 1957-1971 0.1 1.3 14.8 29.9 21.9 16.1 10.5 4.2 1.1 Percent Homolog in Laboratory Aged Aroclor 1254, (Similar to PCBs Found in Environmental Samples) .1 .1 .5 1 21 48 23 6 Not Detectable NEV 036344 " 2. THE MONSANTO INDUSTRIAL CHEMICALS COMPANY IS THE SOLE U .S . PRODUCER OF PCBs There is no evidence in the literature that other companies have produced PCBs domestically in appreciable commercial quantities. There is evidence, however, that PCBs have been imported. The tradename used by Monsanto for these products is A roclor. Some principal industrial p u rch asers of Aroclors use the product u nder th eir own trad e names. IV-4 NEV 036345 3. MONSANTO'S CURRENT APPROXIMATE NAMEPLATE PRODUCTION CAPACITY IS 48 MILLION LBS. PCSs PER YEAR (36) Until 1971 these m aterials w ere produced at two locations. Plant Location A nniston, Alabama Sauget, Illinois (Win. G. Krummrich Plant) Capacity (Million lb s .) 48 48 The Alabama plant was dismantled in A p ril, 1971. Nameplate production capacity of the two facilities was approximately 96 million lb s. (36). The 1973 projected production at the Illinois plant is approximately 43 million lb s. (37) . This re p re se n ts about 90% utilization of capacity. NEV 0363^6 IV -5 4. ANNUAL STATISTICS FOR U ,S . PRODUCTION AND SALES OF AROCLORS SHOW MARKED DECREASE IN USAGE CAUSED BY RESTRICTION TO ELECTRICAL APPLICATIONS SINCE 1971 These data, appearing in Exhibit II, specify Arcelor as well as end-use categories. Export data are also presented. (1) Monsanto No Longer Sells PCBs For End-U ses O ther Than Capacitor And Transform er Insulating Liquids . This voluntary restriction by the essentially sole source of PCBs for U .S. consumption was motivated by appreci ation of the difficulties Involved in imposing workable environmental controls in the other end-use categories (12, 36, 37) . Sales for heat tran sfer w ere phased out in 1972 while sales for other non-electric uses were discontinued in 1971. (2) Specific E nd-U ses, Including Those For Which Sales Were Phased Out By Monsanto A re C orrelated With Aroclor Type In Exhibit III (3) Domestic Sales Of A roclors A re Expected To Increase At An A verage Annual Rate Of 7.4% O ver The Next Five Y ears Papageorge (36) indicated that for planning purposes Monsanto prelim inarily expects a 6% annual growth rate in sales, all for capacitor and transform er applications. . Growth in Aroclor sales will depend on the outlook for ask arel (PCB) type capacitors and transform ers (36). . Selective interview s with industry sources and correlations with P red icast projections (42) indicate the following annual growth projections through 1978 - ask arel use in capacitors: - askarel use in transformers: - PCBs: 6 6 10 % 7.4 % See Section VI for in -d ep th discu ssio n . NEV 036347 IV-6 5. THE PATTERN OF WORLD COMMERCE IN PCBs INDICATES LOWER FUTURE PRODUCTION AND RESTRICTED USAGE (1] Import Statistics Indicate That Only About 2% of PCBs Sold In The U.S . Were Imported In 1971 And About \A% In 1972 A ccording to U .S . Tariff Commission reco rd s 354, 593 lb s. PCBs were im ported in 1972, and 640, 610 lb s . in 1971 (39). Before 1971 th is information was lumped in a general chlorinated hydrocarbons category in these records. P ursuan t to Customs Bureau D irective CIE 36-72, July 14, 1972 the field offices of the Customs Bureau have been specifically monitoring the inflow of PCBs. and th is information is forw arded to EPA (40). The information is not public. It should be noted that the quality of import statistics as well as the effectiveness of m onitoring PCB inflow can be influenced by how the imported chemicals are labeled and represented whether or not PCBs are a principal component or lesser ingredient of imported chemicals whether or not PCBs are an integral part of transform ers and capacitors or products with these as components, or in ru b b ers, plastics and adhesives. These are the principal pro ducts with which imported PCBs are thought to be associated (38). - the extent to which the above information is available during the importation cycle. IV-7 NEV 0 3 6 3 ^ 8 (2) Imports of PCBs Are Expected To Be Less Than 2% of Total U .S. Sales During The Next Five Years . T his is the same o rd er of magnitude as the 1971 and 1972 im ports. . The decline in world commerce is expected to be reflected also in imports. (3) During The Period From 1963 Through 1972 Exports of Aroclors Were 78.7 Million Lbs, T his re p re se n ts 15% of U .S . sales of A roclors over this period, which were 522.4 million lb s, Exports of A roclors to Canada are estim ated to have been about 7% of U .S . sales, o r about one-half the total exports [38). (4) Exports of A roclors Are Expected to Maintain The Same Ratio To U .S. Sales As In The Fast Several Years (36). Or 10-15% (5) Known Foreign Producers of PCBs Include Czechoslovakia France, Germany, Italy, Japan, Spain, and The U .S .S .R . . Several tradenam es have been reported (11,38) France: Pyralene and Phenoclor (Prodelec) Germany: Clophen (Farbenfabriken Bayer) Japan: Kannechlor (Kanegafuchi Chemical); Santotherm (Mitsubishi-Monsanto) Italy: Fcnclor (Caffaro) Spain: (Electro-Quimica de Flex) U .S .S .R .: Sovol IV-8 NEV 036349 Producers in France, Germany, Japan, Italy and Spain are the most likely sources of imported m aterials. Possible new producers may be located in Argentina, B razil, East Germany and India (1). > Historical use and loss patterns of PCBs are expected to be broadly sim ilar in all in d u stralized countries (38). Total production of PCBs outside the U .S. have been roughly estim ated to equal the U .S . production (1), corresponding to an annual rate of up to 80 million lb s . The combined PCB output of the W estern European producers, Prodelec, B ayer, Caffaro and ElectroQuimica de Flex, was 75 million lb s . in 1971. In 1970 it was reported that Japan was producing PCBs at an annual rate of 26 million l b s , (38). - capacitors: - transformers: - heat transfer: - plastics: - carbonless paper: - export: 40-50% 15% 10-15% 5% 35% 5-10% The use and production of PCBs was recently banned in Japan, but manufacture of PCB h earin g products (such as air conditioners with askarel capacitors) by Japanese in terests for export may be taking place in Taiwan (36). There is evidence of exemptions to the ban (36). World-wide, the non-U .S. production of PCBs has also probably decreased . due to the Japanese action noted above due to the recent agreem ent of the Organization for Economic Cooperation and Development (OECD) to limit sales principally to use in transform ers and capacitors and some minor essential heavy industrial applications (31). IV-9 NEV 036350 Farbenfabriken Bayer stopped marketing PCBs for p lasticizer uses before the OECD agreem ent (41). (6) World Commerce In PCBs Is Expected To D ecrease By About The Same Amount Or More Than In The U .S , Since 1970, And To Be Essentially Confined To'Capacitor And Transformer Applications . Japan will not produce PCBs The 1970 Aroclor production was 85 million lb s. Estimated 1973 production is 43 million l b s . , accounting for a 50% reduction . Western Europe will produce 30-40 million lb s. annually In the long run the remaining world producers will also show a pattern of reduced PCB production in the wake of developments in the U.S ., Western Europe and Japan. IV-10 NEV 036351 \ Components Given as % Chlorine* Biphenyl Mono-chlorobiphenyl Di-chlorobiphenyl Tri-chlorobiphenyl Tetra-chlorobiphenyl Penta-chlorobiphenyl Hexa-chlorobiphenyl 1221 1232 21 32 14.8 56.5 26.9 1.42 .06 EXHIBIT I (1) EPA COMPOSITION OF DIFFERENT LIQUID PCB PRODUCTS Monsanto A roclors (1) MCS MCS 1043 1242 1016 1248 1254 1260 32 42 42 48 54 60 .04 .02 .02 22.2 .72 .93 74.4 15.6 19.4 3.3 54.5 64.5 22.5 15.0 ^ 5 5 6.7** .16** 60 70 The last two digits of each Aroclor type indicate the percent chlorine content, except for MCS 1016 and 1043. Includes higher than penta-chlorinated isom ers. Homolog No. of Cl/Biphenyl 0 1 2 3. 4 5 6 7 6 N EXHIBIT I (2) EPA COMPOSITION OF DIFFERENT LIQUID PCB PRODUCTS (continued) Homolog D istribution of Aroclors; C urrently Marketed (12) Percent Composition* 1221 1016 1242 1254 11 51 32 4 2 <0.5 ND** ND ND <0.1 1 20 57 21 1 <0.1 ND ND <0.1 1 16 49 25 8 1 <0.1 ND <0.1 <0.1 <0.5 1 21 48 23 6 ND * Percent (w/w) by GC/Mass using area correction factors None detected, <0.01% = ND NEV 036353 1957 th ru 1964 EXHIBIT H (1) EPA PCB MANUFACTURE AND SALES MONSANTO INDUSTRIAL CHEMICALS CO. [Thousands of Pounds) 1957 1958 1959 1960 1961 1962 1963 1964 U .S. PRODUCTION DOMESTIC SALES U .S. EXPORT SALES (1) 32299 (2) (1) 26061 (2) (1) 31310 (2) 37919 35214 (2) 36515 37538 (2) 36353 38043 (2) 44734 38132 3647 50833 44869 4096 DOMESTIC SALES BY CATEGORY Heat Transfer Hydraulics/Lubricants Mise.- Industrial Transformer Capacitor Plasticizer Appi. Petroleum Additives 1612 704 12955 17028 U) - 1549 755 5719 14099 3939 - . 2685 1569 5984 .16499 4573 - . 2523 1559 7921 16967 6244 - . 4110 2114 6281 15935 9098 - 157 3915 1681 7984 15382 8924 - 582 3945 1528 7290 15606 9181 - 929 4374 1692 7997 19540 10337 - DOMESTIC SALES BY PCB GRADE NHV 036354 Aroclor 1221 Aroclor 1232 Aroclor 1242 Aroclor 1248 Aroclor 1254 Aroclor 1260 Aroclor 1262 Aroclor 1268 Aroclor 1016 23 196 18222 1779 4461 7587 31 - - 16 113 10444 2559 6691 5982 184 72 - 254 240 13598 3384 6754 6619 359 102 - 103 155 18196 2827 6088 7330 326 189 -- 94 241 19827 4023 6294 6540 361 158 - 140 224 20654 3463 6325 6595 432 210 - , 361 13 18510 5013 5911 7626 414 284 (1) Production figures and Plasticizer Applications fig u res unavailable during year indicated. (2) U .S. Export Sales fig u re s . unavailable during y e ar in d icated . (3) Sources: References 1, 36, 37. 596 13 23571 5236 6280 8535 446 190 \ 1965 th ru 1972 (Thousands of Pounds) 1965 1966 1967 1968 U .S. PRODUCTION DOMESTIC SALES U .S. EXPORT SALES 60480 51796 4234 65849 59078 6852 75309 62466 8124 82854 65116 11231 DOMESTIC SALES BY CATEGORY Heat Transfer H ydraulics/L ubricants Mise. Industrial Transformer Capacitor Plasticizer Appi. Petroleum Additives 1237 4616 1841 8657 23749 1169G - 1766 4258 1779 8910 28884 13481 - 2262 4643 1426 11071 29703 13361 - 2529 5765 1283 11585 29550 14404 - DOMESTIC SALES BY PCB GRADE Aroclor 1221 Aroclor 1232 Aroclor 1242 Aroclor 1248 Aroclor 1254 Aroclor 1260 Aroclor 1262 Aroclor 126B Aroclor 1016 369 7 31533 5565 7737 5831 558 196 - 528 16 39557 5015 7035 5875 768 284 - 442 25 43055 4704 6696 6417 840 287 - 136 90 44853 4894 8891 5252 720 280 - NEV 036355 EXHIBIT II (2) EPA PCB MANUFACTURE AND SALES MONSANTO INDUSTRIAL CHEMICALS CO. 1969 76389 67194 10624 1970 85054 73061 13651 1971 34994 34301 9876 1972 38600 26408 6388 Est. 1973 43000 36000 5400 3050 8039 1079 12105 25022 16460 1439 3958 7403 1627 13828 26708 19537 3060 1552 1155 11134 14141 3259 752 - - (25676 ( - 36000 - 507 273 45491 5650 9822 4439 712 300 1476 260 48588 4073 12421 4890 1023 330 - 2215 171 21981 213 4661 1725 1 3334 176 728 807 3495 , 305 - 20902 100 1100 - 6000 - - - 29000 \ End-Use I 1. 1016 1221 1232 Sales Existing Capacitors XX X Transform ers Sales Phased-Out Heat transfer H y d rau lics/ lubricants . hydraulic fluids . vacuum pumps . gas-transmission turbines Plasticizers . rubbers . synthetic resins . carbonless paper x X xX NEV 036356 EXHIBIT III (1) EPA END-USES OF AROCLORS 1242 1248 1254 1260 1262 1268 XX X past X XX X past X X XXX XX X X XX X X XX X X X EXHIBIT VIII (17) EPA EXCERPTS FROM NEMA'S PROPOSED ENVIRONMENTAL CONTROLS (continued) (3) Nonreclaimable contaminated transform er askarels, arced askarels, aekarels from manufacturing spills, and sump accumulation, e tc ., rich in PCBs and ask arels from holding basins, drip and drain pans, washings, sample jars and containers, etc. b . B urnable Solid Waste Material Containing PCBs. These m aterials can be disposed of by h ightemperature incineration and consist of celluloslc materials, rags, pressboard, wood, sawdust, fuller's earth in bulk or in cloth bags, blotter papers, nitrile or cork gaskets, etc. c. N onburnable Solid Waste M aterials Containing or Contaminated With PCBs. These m aterials may consist of coil stru ctu res, steel, copper, aluminum filter units of the steel mesh construction type, askarel drums, cans, etc. M aterials of this nature should be allowed to drain with the liquid collected in drip pans, etc. Further removal of adhering PCBs can be accomplished by washing or solvent extraction with kerosene or other approved washing liquids such as perchloroethylene or trichloroethylene. Accumulated liquids can be disposed of as indicated in p a r. F .2 .a . Solid materials may be handled as normal scrap. 3. Shipment of Scrap Liquids for Disposal All liquid scrap m aterial should be placed in appropriate metal transport drum s, properly labeled, for shipment to a company offering an acceptable disposal service. 4. Shipment of B urnable Solid Waste Material Containing PCBs for Disposable Material of th is type should be placed in open head drums with suitable closures and with the drum properly labeled for shipm ent to a company offering an acceptable disposal service. NV 036357 EXHIBIT VIII (IB) EPA EXCERPTS FROM NEMA'S PROPOSED ENVIRONMENTAL CONTROLS (continued) 5. Liquid and Solid Waste Disposal Service Organizations * a . General. Disposal of askarels and askarel-soaked m aterials should be accomplished by means in which there is no significant release of askarel to the en vironment. At presen t, disposal is accomplished by carefully-controlled incineration of liquids and soaked software, and by controlled landfill burial of apparatus and other hardw are from which askarel has been previously drained and washed. Present knowledge indicates that proper incineration must involve a suitable balance between dwell time and temperature in the incinerator plus oxygen availability and, finally, suitable scrubbers to remove the HC1 which will be formed; e . g . , (1) 2-second dwell time at 2000F and 3 percent excess oxygen in stack gas; (2) 2 1/2-second dwell time at 2700F and 2 percent excess oxygen in stack gas. These facilities should meet the applicable req u ire ments of the State in which they are located and should control effluents within the limits set forth in this document. Controlled landfill or deep-well disposal can be used where permitted by Federal, State and local regula tions . b . Costs. In addition to the normal costs of collecting scrap liquids and solids for disposal, additional costs borne by the owner of such scrap include shipping containers, cost of tran sp o rt to the disposal service organization, and a disposal fee usually based upon a per gallon or per pound charge. c. Disposal Services. Organizations offering disposal services are listed in Section 4, including their loca tion, facilities available, types of material handled, and disposal procedures used. Specific shipping directions, disposal procedures and costs should be obtained from the organization. NEV 036358 EXHIBIT VIII (19) EPA EXCERPTS FROM NEMA'S PROPOSED ENVIRONMENTAL CONTROLS (continued) II. SPECIFIC GUIDELINES A. Transform er M anufacturers, Service Shops. - Housekeeping It is necessary to assume that in filling equipment with askarel and during further handling of this equipment an askarel spill may occur. Therefore, it is necessary to provide facilities and a procedure for clean-up to p rev en t contamination. 1. Askarel Filling Area a. The location of the askarel filling area should be adjacent to the test area and final shipping area to minimi2e the danger of damage of units during handling. b . The main manufacturing area for filling equipment with askarel should be provided with impervious surface floors or suitable basins so constructed that any inadvertent leakage or spills are prevented from reaching stream s, san itary , o r storm sew ers. All askarel handling equipment such as pum ps, hoses, etc. shall be of the askarel resistant type. c. Drip pans shall be provided for hose connections and filling valves. 2. Special Containers for Scrap Materials a. . Drums labeled "SCRAP ASKAREL" should be avail able for handling all spilled and w aste askarel from sum ps, failed u n its, drip pans, sample ja rs , etc. b . Open-head drums with suitable closures and labeled "SCRAP BURNABLE ASKAREL WASTE" should be available for handling contaminated cellulose insul ation, rags, paper pressboard, wood, gaskets, saw dust, etc. NEV 036359 EXHIBIT VIII (20) EPA EXCERPTS FROM NEMA'S PROPOSED ENVIRONMENTAL CONTROLS (continued) c. Separate containers for handling steel, copper, and aluminum, each adequately m arked, shall be provided for the components of contaminated core and coil assem blies. These containers are . required for the various materials when repairing or scrapping assemblies. d. Containers for supplies of material for absorbing small askarel spills or clean-up of larger spills should be provided. 3. Conditioning of Askarels a. Askarel Conditioning Equipment. The conditioning unit should be located either in the storage tank area or the main transform er manufacturing area for filling with askarel. b . Fuller's Earth. Conditioning of new askarel or recycled askarel requires fuller's earth treatment. The spent fu ller's earth in cartridges or bags, when replaced should be allowed to thoroughly drain over drip pans to remove as much liquid askarel as possible. . The cartridge units of steel mesh construction should be placed in the "STEEL CONTAMINATED WITH ASKAREL" container for disposition. Cloth bags filled with fuller's earth should be placed in the "SCRAP BURNABLE ASKAREL WASTE" container lo r disposition. 4. Teardown of Units for Repair or Scrap a. Drain all askarel from the unit cither into a holding tank for reuse or into the drum labeled "SCRAP ASKAREL" for disposition, and then allow sufficient time for all of the askarel to drain from the core and coils. NEV 036360 EXHIBIT VIII (21) EPA EXCERPTS FROM NEMA'S PROPOSED ENVIRONMENTAL CONTROLS (continued) b . Remove the core and coil assem bly from the transform er. Sufficient absorbent material should be placed on the floor to absorb any askarel fluid that still drips from the tran s former . c. Place all materials in the appropriate salvage containers during the dismantling for later disposition. d. All used m aterials, including ra g s , saw dust, tap e, etc., regardless of quantity, shall be put into the appropriate containers for disposition. B. Transformer Labeling 1. New T ransform ers All new transform ers that contain PCBs shall have a label of adequate durability permanently and prominently attached to the tank by the m anufacturer, giving adequate warning and instructions. 2, In-service Transform ers The transform er manufacturer should make available suitable labels with a similar warning as shown in p ar. B.l for use on existing transform ers. C.~ T ransform er U sers - Shipping, Installation, Maintenance. Sampling, Apparatus Disposal 1, General A skarel-filled transform ers are delivered to custom ers as sealed units from which th ere is no escape of askarel under normal operation. While certain types of equipment failures can perm it loss of some ask arel to the environm ent, such cases are extremely rare. NEV 036361 EXHIBIT VIII (22) EPA EXCERPTS FROM NEMA'S PROPOSED ENVIRONMENTAL CONTROLS (continued) 2. Transportation and Receiving Immediately upon receipt of the equipment and following any transportation or handling accident which could affect the integrity of the tank, bushings or radiatorst the transportation vehicle, tank and fittings should be examined for any leakage or spillage that may have o ccurred in sh ip p in g . If leakage is evident, the cause should be corrected and the spillage soaked up with absorbent materials such as saw dust, followed by a clean-up of the affected area with rags soaked with kerosene or other approved solvent such as perchloroethylene or tri chloroethylene. All m aterials used should be collected for proper disposition as described in Section 3 Part 1, p a r . F, "Disposal Procedures and Services." 3. Installation and Periodic Inspection Following installation, the unit should again be inspected for any damage or leakage. It is recommended that periodic in-service Inspections be made for any leaks. 4. Filling, Filtering, or D rying Askarel Most askarel units are shipped with the p ro p er amount of askarel but if it becomes necessary to top off a un it, the m anufacturer's instructions should be followed. If it is necessary to dry or fu ller's-earth treat an askarel unit, the m anufacturer's instructions should be followed. When filtering or conditioning ask arel, all of the precautions previously described for drip pans, proper disposal of filter media, e tc., apply. G. Sampling It is common practice to sample ask arel from a transform er for periodic maintenance testing. As previously described, such samples should be taken in a manner to avoid any contamination of the environment. Washings should be collected for proper disposal. Field and laboratory test samples, washings, etc. should also be collected for proper disposal. NEV 036362 EXHIBIT VIII (23) EPA EXCERPTS FROM NEMA'S PROPOSED ENVIRONMENTAL CONTROLS (continued) 6. Transform er Disposal The ultimate disposal of an ask arel-filled transform er may be accomplished in either of two ways: a. Complete drainage and dismantling with the proper disposal of the askarel and askarel-soaked com ponents as described earlier in Section 3, Part I, p ar. F, "Disposal Procedures and Services." b . Disposition of askarel transform ers by means of junk or scrap dealers should be avoided unless a transform er is first drained, followed by soaking the interior with a suitable solvent. Accumulated liquids and w ashings are to be disposed of as described earlier. NEV 036363 EXHIBIT IX (1) EPA * DISPOSAL SERVICES' LISTED IN SECTION 4 OF NEMA'S OFFICIAL STANDARDS PROPOSAL (16) SECTION 4 DISPOSAL SERVICES Chem-Trol Pollution Services, Inc, 4816 Lake Avenue B lasdell, New York 14219 Phone 716-826-5850 This organization has facilities and services capable of handling: 1. Liquids Askarels alone or mixed with solvents or oils. Disposal by high tem perature incineration. 2. Solids (Software) Askarel-soaked compounds, rags canons, absorbing earths, etc. Disposal by incineration or scientific landfill. 3. Solids (Hardware) Capacitors, transform er tanks, cores, askarel-soaked metals. Disposal by scientific landfill. Has solvent extraction capability. * Disposal Services Listed in Section 4 Of The National Electrical M anufacturers Association ( NEMA) Official Standards Proposal (16) For Handling And Disposal Of Capacitor - And T ransform er - Grade A skarels Containing PCBs. NEV 036364 EXHIBIT IX (2) EPA DISPOSAL SERVICES LISTED IN SECTION 4 OF NEMA'S OFFICIAL STANDARDS PROPOSAI (16) (continued) Monsanto Company 800 No. L indbergh Boulevard St. Louis, M issouri 63166 Phone 314-694-3352 This organization has facilities and services capable of handling askarel liquids alone or mixed with other oils or solvents by hightemperature incineration. Liquid is pumped through a gun with atomizing steam into incinerator. Tem peratures are maintained at 2000-2500F with auxiliary natural gas. Exit gases are quenched to 180F by contact with w ater. Gas is then passed through a h ig h -en erg y v en tu ri scru b b er for removal of particulates. Before exhausting to air (110F), gases are passed through a packed column scru b b er to remove HC1. Nuclear Engineering Company Eastern Division P.O . Box 146 Morehead, Kentucky 40351 Phone 606-784-6611 Disposal Division Sheffield, Illinois Phone 815-454-2624 This organization provides containerization, transportation and disposal services of all liquids and solids (including h a rd w are). Disposal is in controlled chemical and scientific landfill a re a. AEC licensed for radioactive waste d isposal. Has two West Coast locations in slates of W ashington-and California in addition to above. NBV 036365 EXHIBIT IX (3) EPA DISPOSAL SERVICES LISTED IN SECTION 4 OF NEMA'S OFFICIAL STANDARDS PROPOSAL (16) (continued) Rollins-Purle, Inc. Box 3349 Wilmington, Delaware Phone 302-478-5150 19899 This organization- has facilities and services capable of handling: 1. Liquids Askarel alone or mixed with solvents or oils. Disposal is by high temperature incineration. 2. Solids (Software) Askarel-soaked compounds, rags, cartons, absorbing earths, etc. Disposal is by incineration at combustion tem peratures up to 2500F. Incineration gases are scrubbed, and entrained solids re moved before exhausting to a ir. Disposal facilities are available at the following locations: Logan: Rollins-Purle, Inc. Route 322 Logan Township B ridgeport. New Jerse y 08014 Baton Rouge: Rollins-Purle, Inc. Scenic Highway fi W. Cheatham Lane Scotlandville East Baton Rouge Parish Louisiana 70807 Houston: Rollins-Purle, Inc. Tidal Road 6 Highway 134 Deer P ark , Texas 77536 NEV 036366 SECTION Vi NEW 0 3 6 3 6 ? SECTION VI MANUFACTURING PROCESSES IN WHICH PCBs ARE USED In this section the end-uses of PCBs are discussed both in m arketing and technical term s to define the principal channels of movement of these substances through our economy. Emphasis is placed upon the capacitor and transformer applications because currently essentially all PCBs are sold in the U .S. for these uses, and because of the reported technical problems involved in finding replacement m aterials. Other end-uses for which the sole U .S. supplier has discontinued sales, are discussed in broader term s. Rased on this information, a crude accounting of PCBs1 entry into the environment is developed. 1. DURING THE PERIOD FROM 1957 THROUGH 1973 (PROJECTED) , ACCUMULATED U .S . CONSUMPTION OF PCBs WAS ABOUT 775 MILLION LBS ., INCLUDING IMPORTS This is based on sales of Aroclors during the same period in the U .S. and the conservative assum ption that Imports accounted for 2% of total domestic consum ption. Exhibit X summarizes the distribution of U .S. production during this period to the Aroclor types and principal end-uses. (1) D uring The Period From 1957 Through 1973 Approximately 234 Million Lbs. Of PCBs Were Used In "Open11 Systems And Approximately 541 Million Were Used In "Long Lived Contained" Systems . "Open" systems include the following end-use categories: hydraulics/lubricants, where losses can be relatively continuous due to leak s, maintenance problems and where make-up is required plasticizer applications, where PCBs can gradually evaporate from large surface areas miscellaneous industrial applications where PCBs occur often at low levels in widely distributed products and processes. VI-1 NEV 036366 Of the roughly 2% of U .S. consumption that is im ported only a fraction is likely to be imported in the form of or destined for open systems. "Long Lived Contained11 system s include the following end-use categories: electrical systems, capacitors and transformers which are sealed, have long service life and low failu re rate heat transfer equipment, where exchangers are also sealed and have relatively long life and low failure rate C urrently essentially all PCBs sold in the U .S. are for long lived, contained electrical system s due to the voluntary restriction on sales by Monsanto. (2) During The Period From 1957 Through 1971, Approximately 46% Of A roclors Sold In The U .S. Were The T richloro Or Lower C hlorobiphenyls (12) The trichloro and lower chlorobiphenyls are markedly less persistent in the environment than the higher homologs. See page IV-3. . The pattern of h istorical e n d -u ses in Exhibit III suggests that much of the less p ersistent PCBs were consumed in open systems. C urrently the relatively low to moderately persistent Aroclor 1016 is the p rin cip al product consumed (capacitors); the m oderately p e rsiste n t Aroclor 1254 is purchased in appreciably lesser amounts (transform ers). Small quantities of Aroclor 1221 and Aroclor 1242 are also used. (3) An Estim ate'O f The Total Aroclor Used In The U .S. In Electrical Systems Since 1934 Is 752 Million Lbs. T his is based on B oquist's (44) estimate of 690 million lb s. through 1971, adjusted for 1972 and projected 1973 consumption. VI - 2 NEV 036369 Assume conservatively that p rio r to 1960 the ratio was 70:30 of electrical system usage to other usage (44). This is reasonable since many of the open system applications of FCBs were promoted in the early 1960's. From 1960 through 1973 approxim ately 438 million lbs. Aroclors were consumed in electrical system s. Then, about 314 million lb s . A roclors w ere used in electrical system s from 1934 to 1960. Based on the above reasoning, about 135 million lb s. Aroclors were used in applications other than electrical from 1934 to 1960. (4) An Estimate Of The Total Aroclor Used In The U .S . In Non-Electrical Systems Since 1934 Is 367 Million Lbs. . T his is based on the 135 million lb s. estimate for the 1934 to 1960 p erio d , and sales figures of approximately 232 million lb s. since 1960. . Open system usage and heat-transfer applications are accounted fo r. (5) An Estimate Of The Reasonable Upper Limit On Total PCB Consumption In The U .S. Since 1934 Is 1,175 Million Lbs. This rep resen ts 587,000 tons. The figure is based on the above Aroclor consumption estim ates, adjusted upw ard by 5% for possible im ports, and statistical uncertainty p rio r to 1957. (6) Before 1971 There Were 10 To 15,000 Direct P u rch asers of A ro clo rs, While C urrently There Are 25-30 These p u rc h a se rs ordered Aroclors directly from Monsanto VI - 3 NEV 036370 Papageorge (36) rep o rted that the o rd er of magnitude of p u rc h a se rs of Aroclor in 1971 o r before in each end-use category is as follows: Heat Transfer H y draulics Lubricants Mise. Industrial Transformers and Capacitors : Plasticizer Applications : 2 1000 3,000 "few " "several thousand" 40 - 50 2,000 Many of these p u rch asers were distrib u to rs further disbu rsin g PCBs to countless small accounts (36) Since Monsanto's voluntary restriction of sales and other control actio n s, th ere are cu rren tly 25-30 direct custom ers, all in transform er and capacitor applications. These customers use PCBs as askarels in the finished products (capacitors and transform ers) or in the course of servicing. VI - 4 NfcV 036371 2. 1973 USE OF PCBs BY THE U .S . ELECTRICAL INDUSTRY IS ESTIMATED AT 36 MILLION LBS. AND IS EXPECTED TO INCREASE TO ABOUT 51 MILLION LBS. BY 1978 PCBs alone or as mixtures with chlorinated benzenes are used as dielectric liquids known as A skarels, in transform ers and capacitors. Besides their electrical functions, these impregnating liquids serve cooling and arc quenching functions. Transform ers are devices for converting electrical power from one voltage and c u rre n t level to another, and the conducting p a rts of these devices must be separated from each other by a suitable insulating medium such as oils, PCBs or others. Capacitors are devices for storing electrical energy through the physical separation of charged metal surfaces by an insulating medium. Because of the nonflammability of PCBs, their v ap o rs, and their arc-formed gaseous products, transform ers filled with PCBs are relatively free of fire and explosion hazards and may be used in locations where failures of oil-insulated transform ers would p resen t a potential danger to life and/or property. In addition to improving the safety aspect of capacitors, PCBs also have the advantage of reliab ility , long life and small size. Exhibit XI summarizes U.S.. PCB sales to the electrical in d u stry for the 1963-1973 period and estimates of 1978 sales. (1) The A verage Annual Growth Rate For PCB Use By The Electrical Industry During The 1963-1973 Period Ib 4,6% And This Is Expected To Increase At About 7.4% Per Year Through 1978 PCB use in transform ers has grown at the rate of 5.1% p er year for the 1963-1973 period equalling the rate of growth of the value of transform er shipments shown in Exhibit XII for the same p erio d . Industry sources (51) indicate that future PCB use will increase at a rate of about 10% per year and could account for about 19 million pounds per y ear of PCBs sold for transform er use by 1978. VI - 5 036372 There will be an increased demand for power and distribution transform ers emanating from expansions and maintenance of the electrical utilities in d u stry . Demand for specialty transform ers with FCB is basically derived from industrial and commercial construction .. Transform ers are located inside public, commercial or Industrial buildings, on the roof tops of such buildings or in close proximity to such buildings. .. Because PCBs are used, they req u ire no special enclosures other than that necessary to prevent accidental hazardous, mechanical or electrical contact with the equipment. Generation and use of electrical energy will probably be at a higher rate in the future in spite of general fuel shortages. PC B -insulated transform ers share only about 5% of the total m arket. About 125,000 such transform ers have been p u t into service in the United States since 1932 and c u rre n t production is at the rate of about 5,000 units per year (45). .. The amount of Askarel used in various types of transform ers ran g es from 40 to 500 gallons (516 to 6,450 lb s .) with an average of about 235 gallons (3,032 l b s . ) . The principle PCBs used are those designated as Aroclor 1254 and 1242 (54% and 42% chlorine respectively). PCB use in capacitors has grown at a slow er ra te than its use in transform ers and over the 1963-1973 period averaged 4.4% p e r y ear. Industry sources (50) indicate growth will be somewhat h ig h er over the next five y ears amounting to about 6% annually and account for 32 million lb s. p er year sold for capacitor use by 1978. Reasons given w ere: VI - 6 NEV 0 3 ^ 3 7 3 Greater emphasis by lighting manufacturers to provide more controlled lighting distribution sp u rre d on by OSHA enforcement as it p ertain s to illumination standards for better working con ditions . Strong demand by new construction of industrial and commercial building. Greater public awareness of safety and security requirem ents giving impetus to more emergency lighting system s and a tre n d to relam p s tr e e ts . Increased requirem ents for new motor and generator production fox a ir conditioners, pum ps, com pressors and other general industrial and consumer equipment and appliances. O verall, kvar production will in c re ase , but the total unit capacitor growth will not be equal because of improvements in capacitor design (use of polypropylenecellulose combinations). Present Production And Handling Procedures Adopted By Major Transform er And Capacitor M anufacturers (16) Can Minimize Environmental Contamination (50). Specific control m easures instituted by major manufacturers p reven ts the inadvertent loss of PCBs to the environment at all stages from initial receip t of ask arel through ultimate disposal of rejected u n its. All shipm ents of ask arel are made in closed containers such as rail tank car, truck tanks, marine or barge tanks or sealed drums. T ransfer from shipping containers to processing .system s are via closed piping, with appropriate valves, pumps, e tc ., provision is made for trapping and dis posing of fluid lost by leakage or sp ills from the transfer system and from storage containers. VI - 7 NEV 03637** . Capacitor manufacturing involves several additional product handling steps generating waste fluid which must be incinerated and about 5% scrap reject units which are disposed in dry-land fill sites (50). - Metal-cellulose or metal-cellulose/poiypropylene laminates are sealed in metal containers which have a weep hole at the top. The containers are placed In an impregnation-chamber heated under vacuum and dipped into a vat containing PCB and the PCB is sucked into the container through the weep hole. The capacitors are then raised and excess PCB is allowed to run off by gravity, and the weep holes are sealed by applying solder. - The outside of the capacitors are degreased with a suitable solvent which is then disposed of by incineration. . Exhibit XIV illustrates magnitudes of losses of PCB and disposal practices in one capacitor plant before and after controls (38). The exhibit also presents evidence that air pollution from capacitor manufacture is probably not signi ficant (50), (3) The Capacitor And Transform er Manufacturing Industry Is A Highly Concentrated Industry According to the National Electrical Manufacturers Association (16), its member companies have the major share of this market to the utility industry. - 22 transform er producers 6 capacitor producers According to the Certified Ballasts Manufacturers Association (53) there are only 10 manufacturers of fluorescent lamp ballasts. VI - 9 NEV 036375 Manufacturing equipment and operating procedures safeguard against loss of askarel to the environment. Enclosure systems of sealed piping, properly gasketed joints, valves, containers and pro cessing chambers should be used where askarel tem perature may exceed 55C. All wiper ra g s, clothing, waste fluids are collected and properly disposed. Scrap capacitors generated either during manufacture or failure in the field should be disposed of in super vised dry land-fill sites which meet State requirements Askarel or askarel containing fluids can be incinerated at designated facilities. See Exhibit IX. The flow of askarel through a typical transform er manu facturing plant is essentially a closed system (50). Bulk askarel, on receipt, is pumped to a storage tank. Askarel is transferred to the transform er filling operation (transformers can be filled directly or under vacuum) and any overflow is drained off and sent to a separate storage tank. The drained askarel is filtered through filter clay and reused. Transformers are then sealed, wiped clean, and shipped to customer. Transform ers that fail in the field are returned to the manu facturer or authorized repair stations (50). The askarel or other insulating fluid is drained and sent to approved incinerators. The transformer is repaired, filled with new askarel or other insulating oil under strict supervision and returned to service. VI - 8 NV 036376 (4) The Consumer Sector (Primarily Electric Utilities) Is Becoming Increasingly Conscious Of The Need To Reduce Environmental Contamination . Industry contacts (54) indicate that steps are being taken to eliminate transform er fluids from entering plant effluent streams by building confining walls around transformer stations. While certain types of equipment failures can permit loss of some askarel to the environment, such cases are extremely ra re and are limited to approximately 0.02V of the units in service per year (1.16). . Utilities are beginning to retu rn failed capacitors to the manufacturers, (54). Capacitor life expectancy for lighting applications is more than 10 years and more than 20 years in electrical utility applications so that losses due to in-service failure are limited to approximately 0.02% of the askarel put into service per year (1,16). (5) The Value Of Imported Transform ers In 1973 Is Estimated At 50 Million And Is A Small Portion Of Total Transformer Sales The annual average rate of growth of imports (current dollars) for the period 1967 - 1973 is 12.2% but comprises only 3.4% of 1973 U .S. value of shipments. See Exhibit XV. Sweden is the prim ary supplying nation to the U .S. although other supplying nations and major companies include the following: VI - 10 NEV 036377 Major Foreign Companies Exporting Transform ers To The U .S. (461 Country Firm Britain Ferranti-Packard Hawker-Siddely France Cognel Italy Legnano Japan Fuji Hitachi Mitsubishi Sumitomo Toshiba Sweden ASEA Switzerland Brown-Boveri Probably only few imported transform ers contain insulating oils due to shipping, handling and cost considerations, and the number of askarel type transformers imported is probably relatively insignificant. VI - 11 I 0363 (6) Near Term Replacement Of PCBs In Most Askarel Electrical Applications Is Technically Not Feasible . Although significant research effort has been, and continues to be spent, in finding replacement liquids for PCB, no substitutes have been found which provide the safety, reliability and economics of PCB. Mineral oil-insulated transformers can be substituted for PCB Insulated transform ers on a technical basis but other considerations must be taken into account (1). .. Safety building codes specify nonflammable oils which eliminates use of mineral oil. .. Serious economic constraints would occur by using insulated buses (with transformers located out doors) and protective vaults costing $5,000 to $50,000 more per transform er if space is avail able (1). Dry-type transformers cannot be directly substituted for PCB-insulated transformers (1). Reliability of dry-types is much less showing a 7% per year failure rate compared to 0.2% for liquid-insulated units. (1). PCB-insulated transform ers have a much greater overload capability and many can sustain a 100% overload for 8 hours and a 200% overload for 2 hours thus maintaining continuity of electric service during periods of temporary malfunction of related equipment (1). .. Some dry types are la rg e r by 10 to 30%, putting space constraints on their use (1). .. Dry types are noisier by 5-10 db (1). Open dry types cannot bo used in certain corrosive or hazardous atmospheres (1). V I - 12 NEV 036379 Replacement of PCB use in capacitors with other liquids would have serious consequences in terms of size, reliability, failure rate and safety. Reverting to an oil-paper dielectric system would Increase the average capacitor volume by approximately 600%, the weight by 500% and cost by 400% (44). The chem ical, thermal and oxidative stability of PCBs in the presence of capacitor tissues and plastic films and the favorable stress distribution between solid and liquid have made it possible to design low-cost capacitors of more than 10 years life in lighting applications and more than 20 years in electric utility applications (1). F irst-y ear failure rates have been reduced to less than 0.2% (1). The relative nonflammability of PCBs significantly re duces the fire hazard that might otherwise accompany those failures that resu lt in the ru pture of the case. VI - 13 NEV 036380 3. OPEN SYSTEMS END-USES HAVE ENCOMPASSED A BROAD RANGE OF APPLICATIONS IN WIDELY DISTRIBUTED PRODUCTS AND PROCESSES With Monsanto's voluntary restriction of sales to capacitor and tra n s former applications and considering the low volume of imported PCBs, the use of these commodities in open systems has necessarily dramatically de clined. Some PCB use probably still exists in these applications from past stockpiles, recycling and, in low quantities from imports, while the input of PCBs to open systems have been severely restricted suddenly, the scrapping of these materials from these sources is likely to be more gradual due to dwindling inventories and the natural decontamination of facilities. (1) The Applicability Of PCBs In Open Systems Is Wide-Ranging . The technology of use of PCBs in open systems and also in heat transfer is summarized in Exhibit XVI. In terms of PCB quantities consumed, before 1971 the decreasing o rd er of importance of these applications was as follows: plasticizers hydraulics/lubricants heat transfer miscellaneous industrial Petroleum additives and pesticide extenders were expert mental or short lived applications (36). (2) In Most Open Systems Situations The Concentrations Of PCBs Associated With The Product/Process Have Probably Been Low Percentages Exhibit XVII presents Snell's judgments regarding PCB levels associated with various reported end-uses. In heat transfer and vacuum pumps pure PCBs have been used. The likelihood of direct contact by the general population has been significant in the carbonless paper application. VI - 14 NEV 036381 PCB levels may have been 3 to 5% in this product (5). Gradually declining use of PCB bearing paper can be expected as Inventories are depleted and no more PCBs are used (36). Evidence of this is that in 1972, 95% of recycled paperboard samples examined contained less than 5 ppm PCBs. Data on the same type of material manufactured in 1970 and 1971 show that only 1B% of the samples contained less than 5 ppm (3). (3) During The Next Five Y ears, Imports Are Expected To Be Essentially The Sole Source Of Fresh PCBs In Open System . End-Uses With Investment Casting Accounting For A Major Portion In these applications the use of PCBs are projected to be minimal compared to 1970 levels. Imported PCBs in finished products are expected to decline as the use and production of PCBs is reduced or eliminated in Japan and Western Europe, There is evidence that the Yates Manufacturing Company, Chicago, Illinois, is the principal open system importer of PCBs (55). the material is "Deka", decachlorobiphenyl manufactured by Caffaro (Italy) 500,000 lb s. may be imported annually about 30% Deka is used in formulating wax for investment casting Yates distributes to 25 customers an environmental control program is ready to be initiated. VI - 15 o3b38z .. Yates will accept spent wax from casters freight free, potentially representing about 98% of the quantities sold by Yates .. Yates will pretreat the recovered melt .. Caffaro will reprocess the recovered material The 1 1/2 to 2% wax retained in the mold can be destroyed by the castors under an oxidizing atmosphere at 1600 to 1800F for 1 1/2 to 2 hours Yates is currently conducting long range toxicity studies Deka can be replaced by some benzene derivatives. VI - 16 NEV 036383 Arocor 1221 1232 1242 1248 1254 1260 1262 1268 1016 Total End-Use Category Heat Transfer Hydxaulics/Lubricants Miscellaneous Industrial Transformer Capacitor Plasticizer Applications Petroleum Additives Total t890 A3N EXHIBIT X EPA HISTORICAL DISTRIBUTION OF PCB TYPES AND END-USE U .S . Consumption of Aroclors 1957 Through 1973 (Projected) (000) L bs. Percent of Total 7,530 2,040 419,810 59,210 115,560 91,550 7,220 2,680 53,240 759,000 ' 1.0 0.3 55.3 7.8 15.2 12.1 1.0 0.4 7.0 20,280 60,990 21.790 509,910 144,490 1,440 759,000 2.7 8.0 2.9 67.2 19.0 0.2 EXHIBIT XI EPA PCB USE IN THE ELECTRICAL INDUSTRY U .S. Produced PCB Use In Transform ers and Capacitors (1863"197Best.) (Thousand Pounds) Year1 Transform er Use Capacitor Use Total 1963 1964 1965 1966 1967 1968 1969 1970 1971 1972 1973(est.) 1978(est.)2 7,290 7,997 8,657 8,910 11,071 . 11,585 12,105 13,828 11,134 11,310 (12,000) (19,320)2 15,606 19,540 23,749 2B.884 29,703 29,550 25,022 26,708 14,141 14,366 (24.000) (32,120)2 22.896 27,537 32,408 37,794 40.774 41,135 37,127 40,536 25,275 25.676 (36.000) (51,440)2 PCB Manufacture and Sales; Monsanto Company Foster D. Snell, Inc. and Industry Estimates NEV 036385 I EXHIBIT XII EPA TRANSFORMER TRENDS (1967-1974) (52) (Million Dollars) Year Total Value of Specialty Shipments Transformers Power and Distribution T ransform ers Power Transformers Regulators n .s .k . 1967 1968 1969 1970 1971 1972 1973 1974(est.) 1.134 1.253 1,296 1,389 1,344 1,397 1,480 1,550 208 228 271 287 270 279 295 310 790 857 886 902 903 950 1.010 1,050 121 15 154 14 128 11 115 25 146 26 154 14 160 15 170 20 NEV 036366 Year 1963 1964 1965 1966 1967 1968 1969 1970 1971 1972 Total Shipped (1.000 units) 36,091 40,841 48,217 51 ,B17 45,206 51,102 53,117 50,917 45,522 54,980 EXHIBIT XIII EPA FLUORESCENT LAMP BALLAST SHIPMENTS (1863-1972). (53) Value ($1,000) 91,699 96.364 106,593 130,149 117,024 133.027 152,713 163,711 144.529 160,740 036387 NE* EXHIBIT XIV EPA PCB LOSSES IN CAPACITOR MANUFACTURE A. MATERIAL BALANCE (38) I. PRODUCTS Capacitors are produced ranging in size from fluorescent lamp ballasts to 100 KVA units, with motor start units for air conditioners as the main product. II. PCB LOSSES BEFORE CONTROLS During 1969 the purchases of Aroclor 1242 were 3.7 x 105k g , 3.2 x IQ4 kg was lost in manufacture. Approximately 8.6% of Aroclor 1242 was lost. During 1969 the purchases of Aroclor 1254 were 1.5 x 104 k g , 2.3 x 103kg was lost in manufacture. Approximately 15.3% of Aroclor 1254 was lost. The losses w ere approximately evenly distributed between scrap from units that failed and loss in purification and degreasing operations. Some of the scrap was used as an antidusting agent in a parking lot and some mixed with a residual fuel oil and b u rn e d . No special precautions were practiced during disposal. III. PCB LOSSES AFTER CONTROLS 5 During 1971 the purchases of Aroclor 1242 were 4.2 x 10 k g , and no Aroclor 1254 was purchased. Losses were reduced to 1.9 x 104 k g , or approximately 4.5%, mostly due to failures of u n its. All scrap fluids were disposed of by burial in sealed containers. B. AIR EMISSIONS (50) Sampling of ventilation stacks in one capacitor plant where Aroclor 1016 had been used for about a year showed PCB levels of about 0,03 to 0.09 ppm by volume. Five stacks w ere sampled, using a 10-min sampling time per hour for a 25-hr p erio d . A detailed description of the total ventilation system was not reported. Samples of air taken 2-3 miles from the plant showed no detectable PCB levels. Sampling was done by methods suggested in the NEMA proposal (16) . 036388 YEAR 1967 1968 1969 1970 1971 1972 1973 1974 lest.) EXHIBIT XV EPA TRANSFORMER IMPORTS VALUE OF IMPORTS (Million Dollars) 25 38 40 40 36 48 50 52 NEV 036389 EXHIBIT XVI (1) EPA EXCERPTS FROM BROADHURST (19) ON PCB TECHNOLOGY IN OPEN SYSTEMS AND HEAT TRANSFER ' I, HYDRAULIC APPLICATIONS Hydraulic fluids are liquids used as force transm itters. Since most commercial hydraulic fluid mixtures are proprietary, it is difficult to obtain Information with respect to their composition. PCBs are useful in hydraulic fluids as lubricating additives in extreme pressure applications and as pour point depressants. Although it is true that the pour point of oils may be lowered by extensive'dew axing, the use of additives is much cheaper. There are other inexpensive additives which are often used for these applications and which.appear to be adequate. For example, TCP (tricresyl phosphate) is chemically stable as an additive in lubricants, and, although quite toxic, it is more biodegradable than the PCBs. An important requirem ent for many applications of hydraulic fluids is good heat and fire resistance. PCBs have excellent fire resistance characteristics. Aircraft hydraulic fluids are an example of an application where excellent heat and fire resistance are necessary in view of moderately high operating tempera tures and frequent accidents involving ruptured hydraulic components in the proxim ity of hot metallic surfaces. Also the Fiberglas acoustic blankets in the je t engines become soaked with leaking hydraulic fluid within as little as one year of use. Fire resistance in phosphate ester type hydraulic fluids has been related to PCB content. Phosphate ester hydraulic fluids have been used extensively for. commercial aircraft. PCBs have been assumed to be useful as "snuffers" in that they tend to extinguish a fire supported by other constituents. The market value of used phosphate ester type hydraulic fluids is sufficiently high that they are being recycled. 19. B roadhurst, Martin G ., Use and Replaceability of Polychlorinated Biphenyls. Environmental Health Perspectives: Bl-102, October 1972. NEV 036390 EXHIBIT XVI (2) EPA EXCERPTS FROM BROADHURST (19) ON PCB TECHNOLOGY IN OPEN SYSTEMS AND HEAT TRANSFER (continued) Considerable research is being done in connection with fire resistant hydraulic fluids for military aircraft Some of the hydraulic fluids being tested do not con tain PCB additives, b u t do contain TCP. It is possible that under appropriate process ing, PCBs may be replaced by TCP and perhaps certain other additives to obtain satisfactory lubrication. It is possible that PCBs are also used in phosphate ester and other halogenated hydraulic fluids for Industrial applications at high temperatures. II. VACUUM PUMP APPLICATIONS PCBs are used in pure form as a diffusion pump oil in commercial applications. They are useful as booster pump fluids. Except for certain applications w here alternative liquids may be Incompatible with the vapors being pumped, the advantage of using PCBs in diffusion pump oils appears to be mostly an economic o n e. TCP is used as a commercial diffusion pump fluid and is also inexpensive. Its vapor p re ssu re is lower than that of the PCBs making it less desirable In booster pum ps, but in many applications TCP may be a suitable replacement. PCB diffusion pump oils can be decomposed after use by incin eration . III. HEAT TRANSFER APPLICATIONS The main advantage of the PCBs as heat transfer fluids is their fire resistance. The other advantages of PCBs are low pour points and viscosities and good thermal stability up to 600F. Increased risk from fire and explosion is a major disadvantage with most PCB replacement fluids. Other non-flammable fluids are: 1. fluorocarbons, which have low toxicity, high thermal stability, and in spite of high cost are used as con vective or evaporative coolants, 2. w ater, which is quite corrosive, has a high temperature limit of 374C and requires extremely expensive high p ressu re systems for its use above the atmospheric boiling tem peratures and 3. molten salts and metals which, because of their resistance to radiation damage, are useful in reactor applica tions . NEV 036391 EXHIBIT XVI (3) EPA EXCERPTS FROM BROADHURST (19) ON PCB TECHNOLOGY IN OPEN SYSTEMS AND HEAT TRANSFER (continued) Several liquide are more stable at high temperatures than the PCBs. Few of these liquids are non-flammable. The phosphate esters, silanes, and aromatic ethers have high fire points (around 600F), but they are flammable and it is not clear how high the fire point must be for a fluid to be safe in a high temperature system, especially in the event of leakage into a furnace. The details of specific heat transfer applications are necessary to evaluate the suitability of PCB replacement flu id s. IV. PLASTICIZER APPLICATIONS PCBs are attractive as plasticizers because of their high compatabllity factor. The PCBs are permanently therm oplastic, chemically stable, non-oxidizing, noncorrosive, have excellent solvating powers, and are fire resistant. They are not normally attacked by acids, alkalies, or water. They are insoluble in w ater, glycerol, and glycols, and are soluble in organic solvents. V. ADHESIVES APPLICATIONS The more resinous chlorinated polyphenyls can be included in this category. Hot melt adhesive compositions based on phenolic resins are used in brake linings, clutch faces, and grinding w heels. Chlorinated polyphenyls and aryl phosphates (non-reactive plasticizers) also improve flow properties of phenolic resins p rio r to curing as well as imparting some flame proofing characteristics to the composition. PCBs have also been used in laminating adhesive formulations involving polyurethanes and polycarbonates to prep are safety and acoustical g lasses, Polyarylene sulfides, treated with chlorinated biphenyls, are employed to laminate ceramics and metals. An ethylene-propylene copolymer blended with PCB has been used in a hot melt adhesive having Improved toughness and resistance to oxidative and thermal degradation. It has excellent adhesion to polyethylene films. Similar adhesives, used to bond polyethylene to itself or other plastics, were prepared from sty ren e, alpha-m ethylstyrene or methylmethacrylate. Washable wall coverings and upholstering m aterials, made from films of polyvinyl chloride, are claimed to be improved by the addition of PCB to the adhesive formula tion . PCBs can also be applied in the preparation of polyvinyl alcohol adhesive compositions which are used to manufacture envelopes, in self-adhering films and in preparation of coatings of pressu re-ru p tu rab le capsules for adhesive tape. NEV 036392 EXHIBIT XVI (4) EPA EXCERPTS FROM BROADHURST (19) ON PCB TECHNOLOGY IN OPEN SYSTEMS AND HEAT TRANSFER (continued) VI. TEXTILE COATINGS APPLICATIONS A textile coating for ironing board covers can be formed from a mixture of chlorinated biphenyl, cellulose acetobutyrate, and aluminum metal particles. PCBs also can be used as a de-lustering agent for ray o n s. Poly**alpha-olefins, (i. e . , polypropylene) films, when coated with a mixture of PCBs, UV light absorbers, and antioxidants show increased stabilization to oxidative degradation on exposure to sunlight and w eathering. Polyamide (nylon-type) yarns w ere found to be flame proofed when treated with PCB. Chlorinated biphenyls can also be used as ingredients in some sealing formulations employed to waterproof canvas. VII. SURFACE COATINGS APPLICATIONS In paints and v arn ish es, the h ard resinous PCBs im part increased hardness to film s, and the softer resins give flexibility. In nitrocellulose lacquers, PCBs either alone or in combination with other plasticizers and resins impart increased weatherability, luster, adhesion, and decreased burning rates. PCB and other plasticizers can be used in combination with poly (organosiloxanes) to prepare film casting solutions. These polymeric films could be employed in electrical coatings, insulating tapes, and protective lacquers. Plastic vessels, 1. e. bottles, manufactured from polyethylene, polyvinyl chloride, polyvinylidene chloride or similar resins coated with an epoxy lacquer (which contains PCB) make the vessels pliant, impervious, and resistant to aromas, acids, and alkalis. Paints at atomic energy installations are needed for (a) contaminated area (b) tolerance to high energy radiation, and (c) to meet clean condition standards. Paints for (a) should be glossy and smooth and should not transm it contaminants. For this purpose, the vinyl polymers are preferred over epoxy lacquers. The best plasticizers for use in this area are claimed to be the PCBs. The extent, if a n y , of their use in this application is unknown. The PCBs are usually compatible with epoxy re s in s , and they give good final hardness and impact resistance equal to the unmodified re sin . They also aid in the acceptance by the resin of la rg e r amounts of fillers. Epoxy resins in combina tion with PCB can be used as protective coatings for metals, i. e , , encapsulating electrical capacitors, for ferrite magnet cores, for corrosion resistant resistors, for pigmented metal coatings for winter camouflage coatings, and for pipes and blocks. NEV 036393 EXHIBIT XVI (5) EPA EXCERPTS FROM BROADHURST (19) ON PCB TECHNOLOGY IN OPEN SYSTEMS AND HEAT TRANSFER (continued) VIII. SEALANTS APPLICATIONS PCBs can be used as plasticizers in the formulation of putties from copolymers or ethylene-vinyl acetate or styrene. The products are non-hardening. and resistant to moisture and frost and show good w aatherability. A non-sticky, non hardening putty was also prepared from polysulfide mixtures which employs PCB as the plasticizer. This putty gave good bonding to building materials and had good extrudabillty and shape retention. Elastic pavement or concrete sealing compo sitions. used for traffic m arkings, were prepared from coal-tar-polysulfide mixtures which are plasticized with PCB. A sealant, effective for concrete and asphalt applications, can be formulated from a mixture of polysulfide, chlorinated ru b b e r, and polyisocyanate, and plasticized with PCB. IX. PRINTING APPLICATIONS Chlorinated biphenyls have been employed as p art of the formulations used to prepare pressure-sen sitiv e record and colored copying p ap ers. They have been used to coat papers used in thermographic duplicating processes as well as in xerographic transfer processes. Solvent-free printing on polyolefin plastics can be accomplished by heating a mixture.of low molecular weight material, chlorinated biphenyl or terpene re sin , and suitable pigments and dyes. Printing plates can be prepared from compositions containing a liquid resin such as epoxy, polyester, urethane, acrylic or vinyl with an excess of curing agent and PCB as the plasticizer. The extent, if an y , of cu rren t uses of PCBs in printing application is unknown. X. FIRE RETARDANT AND FLAME-PROOFING APPLICATIONS For increased effectiveness in flame retardant applications, the PCBs can be admixed with various metal oxides. Some flame retardant compositions based upon these mixtures are used in: polyolefin yarns; organopolysiloxane sealants; thermoplastic poly; fireproof panels made from starch which can be used for doors, floors, ceilings, and partitions; polyamides; and in fireproof fiberboards. XI. MISCELLANEOUS APPLICATIONS Catalyst carrie r for polymerization of olefins. NEV 03639A EXHIBIT XVI (6) EPA EXCERPTS FROM BROADHURST (19) ON PCB TECHNOLOGY IN OPEN SYSTEMS AND HEAT TRANSFER (continued) Conversion of water-permeable soil to a non'-permeable state. Soil is made non-permeable by applying to the soil a composition consisting of an ethoxylene-based resin polyamide, camphor, and PCB as p lasticizer. The compo sition has a density greater than w ater, and it hardens under w a ter. It can be applied to riv e r b a n k s, where It flows down the bank, and after hardening, prevents penetration of water (soil erosion-retardant). Combined insecticide and bactericide formulations. The composition contains aldrln or dleldrin, naphthalene hydrocarbons, malathion, methoxychlor, lindane, chlordane, terpineol, and chlorinated biphenyl as active agents. Inhibitors of microbial growth in enamel clay formulations. Plastic sound insulating materials for railway c a rs. Plastic (PVC) decorative articles which give the impression of internal scintillation. Increasing the density of carbon plates by impregnation with PCB. Graphite electrodes with low thermal expansion coefficients and high banding strengths. Increasing the coke yield from coal p itch . The coke Is very h ard , dark, and brilliant. As a metal quencher ox tempering agent for steel, alloys, -and glass. As an aid to fusion cutting of stacked metallic plates without adherence, The cutting is done with an electric arc or oxy-gas torch. NEV 036395 \ Reported Applications . Hydraulic . Vacuum pumps . Heat transfer . Plasticizers . Adhesives . Textile coatings . Surface coatings . Sealants . Printing . Fire retardants and flame proofing . * . Carbonless copy paper m Trace 036396 EXHIBIT XVII EPA PCB LEVELS ASSOCIATED WITH VARIOUS PRODUCTS/PROCESSES PCB Levels. Percent Ranges Low Medium High Pure Form X X X X X X X X X Likelihood of Direct Contact by the General Population Low Low Low Medium Medium Medium Medium Medium Low Medium High SECTION v n NEV 036397 SECTION VII THE ENTRY OF FCBs INTO THE ENVIRONMENT AND MANAGEMENT STEPS In this section the input/output dynamics of FOB consumption in the major end-use categories are examined. Patterns of entry into the environment are defined. Environmental control actions are summarized, and criteria for further management steps are developed. 1. ABOUT 500 MILLION LBS. OF PCBs ABE IN-SERVICE, BASED ON A SNELL LIFE CYCLE MODEL Rough models of the entry of FCBs into the environment from both open and long-lived contained systems have been developed, notably by Nisbet and Sarofim (13). Continuation of this work has been published by Nelson (38). (1) Nelson (38) Estimated That The Equivalent of 80% of The Annual Aroclor Sales Was Scrapped In 1970 . During 1970 about 58 million lb s. of PCBs became scrap (80% of 73 million l b s . , the 1970 domestic sales of A roclors). . Nelson (38) distributed this scrappage to principal routes of environmental entry as follows: 2 to 4 million lb s. lost to the atmosphere through evaporation from plasticizer applications - 8 to 10 million lbs. attributed to leaks and disposal of hydraulic. heat ex change and transformer fluids, mostly entering coastal and fresh waters NEV 036398 VII-1 about 44 million lb s . attributed to disposal in dumps and landfills in capacitors, plastics and miscellaneous products; Nelson (38) further dis tributed this solid waste portion as follows: .. 10-20% b u rn e d , at various efficiencies and possibly in conjunction with the produc tion of highly toxic by-products such as dichlorobiphenyl furanes and dioxanes .. about 2%vaporized .. long-term environmental storage of the remaining 34 to 39 million lb s . of FCBs in solid wastes in dumps and landfills Based on correlation of Aroclor type with principal end-us8 as well as pattern of scrappage, Nelson (38) postulated that p rio r to Monsanto's elimination of sales for open system applications PCBs entering the environment through the air route have been most likely Aroclors 1248 through 1260 from plastics and Aroclor 1242 from burning of refuse containing capacitors. FCBs entering the environment through the water route have been most likely Aroclors 1242 through 1260 from hydraulic,lubricant and transformer applications. - PCBs stored in the environment in dumps and landfills have been most likely Aroclor 1242 from capacitors. VII-2 NEV 036399 (2) A Life Cycle Model. Developed From F urther Evaluation Of Nelson's (38) Assumptions Regarding The Scrappage Rates Of FCBs. Indicates That The Equivalent Of Only About 26% Of The Annual Aroclor Sales Was Scrapped In 1970 . The FOB service life functions in Exhibit XVIII are the basis of the Snell model. ' These functions disaggregate annual usage. Each major end-use category is characterized in terms of FOB scrappage as percent of annual sales corresponding approximate in-rservice life of PCB . Assuming that in-service lives of PCBs In the major end-uses have been and will be reasonably constant* the following information can be generated estimates of the total amount of PCBs in-service, based on annual sales figures estimates of the amount of PCBs scrapped as a function of time and through the principal channels of entry into the environment, especially w here a channel is characteristic of an end-use category projection of the disappearance of the c u rre n t open-system inventory of PCBs in-service testing the consequences of various PCB control scenarios after further refinement of the model VII-3 NEV 0 3 6 4 0 0 . During 1970 about 19 million lb s. of PCBs became scrap using the Snell m odel, corresponding to about 26% of the annual Aroclor sa le s. (Nelson (38) estimated that these figures were 58 million ib s. and 80%, resp ectiv ely ). Entry into the environ ment probably followed the pattern defined by Nelson (38), presented in summary form under 1, (1) above. 2 to 4 million lb s. to air about 3 million lbs. to water 12 to 14 million lb s . to land roughly 20%burned .. roughly 80% In long term environmental storage in dumps and landfills The total amount of PCBs in-service through the end of 1973 was estimated using the procedure exemplified in Exhibit XIX. The table below p re sents in-service estimates by end-use category. End-Use PCB Quantity In-Service Through 1973 (million lb s.) Transformers Capacitors Heat exchangers Plasticizer applications Hydraulic fluids and lubricants Miscellaneous industrial applications 205 270 11 insignificant 9 insignificant Total 495 Assuming continuation of the current pattern of Aroclor sales through 1978, at the end of the next five years essentially no PCBs will be in non-electrical service Minimizing environmental burden from the roughly 20 million lb s. of PCBs still in non-electrical service is probably unfeasible logistically Exhibit XX summarizes the historical pattern of PCB channels to the environment. 036401 VII-4 2. SIGNIFICANT STEPS HAVE ALREADY BEEN TAKEN TO ENVIRONMENTALLY MANAGE PCBs IN PRODUCTION, CNSUMPTION AND COMMERCE Major control actions and strategy considerations are summarized below. (1) The Monsanto Company, The Sola U .S. Producer. Has Led Environmental Control of PCBs These steps fall into the general categories of process control, product improvement, sales restrictions, establishment of a waste disposal service, and "good w ill". Principal reported environmental controls at the existing production facility are summarized in Section V , and in Exhibit V . Product improvement is represented by Aroclor 1016. a variant of Aroclor 1242 and its replace ment in new capacitors. The 1016 material con tains a typical concentration of 0.4% by weight of the higher boiling (more persistent) chlorobiphenyl homologs, whereas the 1242 product contained about 7%of these (26), R6D efforts to find or develop equivalent, but readily biodegradable replacements for Aroclors in electrical service have not been successful (36). Sales restrictions include: discontinuation of sales to end-uses other than capacitors and transformers (long lived closed systems) restriction on sales to non-electrlcal manufacturers (36) requirem ent of a letter of intent by p u r chasers to follow good manufacturing practices (36). VII-5 N6V 3 6 4 0 2 . The waste disposal service includes destruction of waste PCB liquids in the incinerator described in Section V and the acceptance of used containers for controlled recycle. The following are key features of the container recycling service acceptance by Monsanto decontamination by an affiliated contractor firing of containers refurbishing for resale for non-food uses incineration by Monsanto of the decontamination solvents "Good will" includes general cooperativeness and an organizational aw areness of product acceptability and stewardship. As a service to open system customers, the firm has p rep ared a list of possible replace ments for PCBs in adhesives and coatings (14) . The company has set up an educational pro gram for custom ers, showing means for avoiding losses during the handling and use of PCBs (14) . (2) The Market Statistics Suggest That The Great Majority Of Open System Users Of PCBs Have Found Alternatives To This Commodity, But T here Has Not Been A Sense Of Urgency To Eliminate PCBs Already In Service Countless PCB bearing "open" processes and products currently in use, pre-date the voluntary elimination of sales to open system customers by Monsanto. With time, PCBs from these sources will disappear from active usage. This will lead to a corresponding gradual lessening in environmental burden VII - 6 NEV 03o*03 - There may be appreciable quantities of carbonless copy paper with FCBs in widely distributed* albeit gradually declining inventories (36) - The literature and limited interviews indicate that there has not been a sense of urgency on the part of users for the controlled replacement of PCB fluids in non-food processing . The same sources also indicate that PCBs were not handled with greater care in processing than other plasticizers, or analogous materials in the various end-uses - open system formulation and processing facilities may be still contaminated with PCBs from past practice a limited number of facilities may still be processing PCBs from past inventories or Imports - it is reasonable to assume that the general environment of industrial areas will be burdened with a gradually declining Input of PCBs from discontinued past practices The C urrent Buyers Of PCBs For Capacitor And Transform er Insulation Have Taken Formal Steps Toward Environmental Control A number of purchasers have discontinued the use of these materials (51), including Allis Chalmers - Wagner Electric Esco Manufacturing Others VII-7 NEV 036404 Manufacturers through their industry association, the National Association of Electrical M anufacturers (NEMA), have developed the "Proposed American National Standard Guidelines For Handling and Disposal Of Capacitor - And Transformer-Grade Askarels Containing Polychlorinated Biphenyls, C107.1 - ( ) (16) . See Exhibits VIII and IX for excerpts of the principal proposed technical procedures The prime users of askarel capacitors and transformers were represented by an indus try delegation, coordinated by the Edison Electric Institute (43) Nelson (3B) reported a case study of environmental losses at a capacitor manufacturing facility before and after controls were instituted. See Exhibit XIV. The major sources of PCB losses were Aroclor handling and filtration capacitor degreasing capacitor rejection Although askarel capacitors are long-lived closed system s, in use these are universally distributed. - the feasibility of PCB control in capacitor manufacture can depend on whether or not best available environmental controls for organic chemicals of the same general class are sufficient PCB control at the point of capacitor use could represent complex logistics. but the require ment of "turning in" faulty or useless capacitors for central disposal (as in exchange for replace ment capacitors) could be workable the feasibility of PCB control in the capacitor disposal phase can depend on whether or not conventional (landfill or other) solid waste disposal practices are suitable NEV 036405 VII-8 .. the extent to which improper disposal practices, such as poorly controlled burning of capacitors, are significant and can be controlled . The environmental control of askarel transform ers is less complex than that of capacitors the number of transformers manufactured annually and already installed Is signifi cantly less than the number of capacitors PCB control during transform er manufacture is less complex than that during capacitor manufacture because the former is a simpler process PCB control during transform er use is expected to be practicable because users are overwhelm ingly industrial, concentrated in the electrical industry and in numbers that can be " traced11 PCB control in the transform er or waste askarel disposal phase is expected to be feasible for the same reasons . It has been estimated that the future environmental losses of PCBs from electrical applications can be held below 0.03% of the PCBs in-service 144) with proper control of scrap s. small losses from product failure in-service would occur with time, an increasing portion of askarels will be Aroclor 1016 . This will minimize the entry into the environment of the more p e r sistent homologs of PCB, (4) The Control Of PCBs Already In The Environment Is Not Feasible, Except In Highly Localized Situations PCBs are universally distributed in the environment, with reported higher concentrations near industrial areas (28) . NEV 036406 VII-9 . Highly localized situations may include landfills and open dumps some contaminated production facilities (discontinued or on-*going production) spill sites some sludges . While appreciable decontamination activities in the general environment are not feasible, monitoring can indicate hazard as well as record dissipation of PCBs to acceptable levels. (5) Regulatory Action Can A ssure Highly Controlled Use Of PCBs In The Future - One alternative is to simply ban the production and remaining uses of PCBs in the U .S . , as in Japan, where need for exemptions has arisen . The economic impact of such action should be thoroughly investi gated , considering the technological and institutional dependence in the U .S. on askarel type capacitors and tran sfo rm ers . Another alternative is to establish specific controls such as the Food and Drug Administration's actions to prevent PCBs contamination of animal feed, foods, and food packaging materials the Environmental Protection Agency's actions to include PCBs on the Toxic Substances List and to promulgate Toxic Effluent Guidelines the actions of the U .S. Customs Bureau to monitor PCB imports the actions of the Occupational Safety and Health Administration to limit worker ex posures to PCBs VII-10 NEV 0 3 6 ^ 0 7 the actions of the Organization for Economic Cooperation and Development to limit inter national use of FCBs through exchange of statistical data .. through controls on production; distribution, imports/exports through controls on end-uses, such as limitation to electrical and other systems where non flammability is essential A logical regulatory extension of the pattern of recent voluntary controls is formal banning of the sale or purchase of FCBs for non-electrical u ses, and the granting of exemptions on a case-by-case basis formal sanctioning of the National Standard Guidelines For Handling and Disposal of Capacitor - And Transformer - Grade Askarels Containing Polychlorinated Biphenyls establishing an enforcement mechanism that also applies to importing of PCBs V II-11 NEV 036408 Historical PCB End-Use Category * Transformers . Capacitors Annual Sales Outlook 10% growth 6% g ro w th Historical PCB Scrappage As Percent of Annual Sales 3-4% 8% . Heat exchangers . Plasticizer applications , Hydraulic fluids and lubricants Miscellaneous industrial applications No sales No sales No sales No sales 20% 60% 25% 90% NEV 036409 EXHIBIT XVni EPA PCB SERVICE LIFE FUNCTIONS Corresponding In-Service Life of PCBs, Years Remarks 30 Askarel transformers have 30 year or longer lifetime (45, 54) 12 Capacitors life in electric utility service is about 20 years (45). This is about 10 years in lighting use (45). Capacitors are sometimes scrapped as part of the parent product, such as lamp ballasts. 5 1.7 Roughly 15% vaporization is considered during service life (48). Plastics have a short useful life. 4 In 1968 about 30%of the annual usage of indus trial lubricating oils and about 20%of the annual usage of hydraulic fluids w ere waste (49) 1.1 \ EXHIBIT XIX EPA EXAMPLE OF THE USE OF PCB SERVICE LIFE FUNCTIONS: ESTIMATE OF CAPACITOR PCBs IN-SERVICE The in-service life of PCBs in capacitors is estimated to be about 12 years ( o v erall. See Exhibit XVIII. The table below presents Aroclor sales during the last 12 years for capacitor applications. Year Sales of Capacitor A roclors, Million Lbs, 1973 1972 1971 1970 1969 1968 1967 1966 1965 1964 1963 1962 ' 24.0 17.1 14.1 26.7 25.0 29.6 29.7 28.9 23.7 19.5 15.6 15.4 270 Roughly 270 million lb s. of PCBs are in capacitor service through the end of 1973. Refined estimates could be obtained through consideration of the typical life cycles of the different types of askarel capacitors with corresponding disaggregation of Aroclor sales data. NEV 036410 \ Historical PCB End-Use Category . Transformers . Capacitors . Heat exchangers . Plasticizer applications . Hydraulic fluids and lubricants . Miscellaneous industrial applications . All categories: ratio of importance based on Nisbet and Sarofim's work (9) EXHIBIT XX EPA HISTORICAL PATTERN OF PCB CHANNELS TO THE ENVIRONMENT Interface With The Environment Of Scrap PCBs Air Water Land (dumps, landfills, etc.) X XX XX X XXX X XXX X XX XXX X XX XX X XXX 1 2 10 NEV 036411 Note: XXX = Principal channel; XX = secondary channel; X = non-negligible channel SECTION VIII NEV 0 3 6 *1 2 SECTION VIII BIBLIOGRAPHY Interdepartmental Task Force on PCBs Report ITF-PCB-72-1: Polychlorinated Biphenyls and the Environment. May 1972. 1 8 9 p p . (COM-72-10419). Quinby, Griffith E.: Polychlorobiphenyls (PCBs) and Related Chlorophenyls: Effects on Health and Environment. I. Bibliography -- 1881-1971. Oak Ridge, Tennessee; Oak Ridge National Laboratory (Report ORNL-EIS-72-20), Toxicology Infor mation Response Center Report TIRC-1; 1972. 140 p p . PB-209, 944. Department of A griculture Ad Hoc Group on PCBs: A griculture's Responsibility Concerning Polychlorinated Biphenyls (PCBs). Washington, Department of A griculture, 1972. 39 p p . Crump-Wiesner, Hans J. et al.: Distribution of Polychlorinated Biphenyls in the Aquatic Environment. Washington, United States Geological Survey, 1972. 24 p p . Fine, Sam D.: Final Environmental Impact Statement Rule Making on Polychlorinated Biphenyls. Washington, Department of Health, Education, and Welfare, Food and Drug Administration, 1972. 29 p p . Criteria Document For PCBs. Unpublished. Environmental Pro tection Agency, 1973. Council on Environmental Quality: Toxic Substances. Washington, Government Printing Office, 1971. 25 pp. Jay, Pierre: PCB - Uses in Askarel For Electrical Industry. Solna, Sweden; National Swedish Environment Protection Board; 1970. 25 pp. National Environmental Research Center: Position Paper on Poly chlorinated Biphenyls (PCBs). Washington, .Environmental Protection Agency, 1973. 170 pp. Unpublished. V III-l NEV 036413 10. Risebrough, Robert: More Letters in the Wind. Environment 12:16-26, Janu ary -F eb ru ary , 1970. 11. Hubbard, H .L.: Chlorinated Biphenyl and Related Compounds. IN: Kirk-Othmer Encyclopedia of Chemical Technology. Second Edition. Volume 5. New York, Interscience Publications, 1964. pp. 289-97. 12. Monsanto Company: Status Report to the Interdepartmental Task Force on PCBs. Presented May 15, 1972, Washington. ca. 100 pp. 13. Nisbet, I.C .T . and Sarofim, A .F .: Rates and Routes of Transport of PCBs in the Environment. Presented at International Scientific Meeting on PCBs, Quail Roost Conference Center, Rougemont, North Carolina. December 20-21. 1971. 14. Anon.: Pollution Cop's Lot Not 'A ppy.' Chemical Week 106: 19-20, April 21, 1971; 15. Weiss, Hans K. (Foster D. Snell, Inc.}: Market Study of Chlor inated Diphenyls. Confidential Report, 1966. 16. National Electrical Manufacturers Association: Proposed American National Standard Guidelines for Handling and Disposal of Capacitorand Transformer - Grade Askarels Containing Polychlorinated Biphenyls, C 107.7-( ) . NEMA Official Standards Proposal. Pub. Nos. CP-P1-1973 and TR-P6-1973, January 25, 1973. 23 pp. 17. Department of the Interior, Water Resources Scientific Information Center WRSIC 73-201; PCB in Water, a Bibliography. (96 references with ab stracts). January 1972. 144 p p . 18. Koppers C o., In c ., Tar Products Division: Halowax Chlorinated Naphthalenes. No date. ) 19. Broadhurst, Martin G.: Use and Replaceability of Polychlorinated Biphenyls. Environmental Health Perspectives 61-102, October 1972. National Bureau of Standards Report COM-72-51054.. 20. Vos, J . G. et a l.: Identification and Toxicological Evaluation of Chlorinated Dibenzofuran and Chlorinated Naphthalene in Two Commercial Polychlorinated Biphenyls. Food and Cosmetics Toxicology 8:625-33, 1970. VIII-2 NEV 0 3 6 4 1 ^ 21. Zitko, V. (Fisheries Research Board of Canada): Absence of Chlorinated Dibenzodioxlns and Dibenzofurans from Aquatic Animals. Bulletin of Environmental Contamination and Toxicology 7:105-10, 1972. 22. Anon.: Who Have Been the Users (Industrial) of Dangerous Poly chlorinated Biphenyls? Chemical Engineering 79: 37, January ID, 1972. 23. Anon.: Multiple Hearth Incineration. Water 6 Wastes Engineering 9: 46, December 1972. 24. Anon.: Monsanto Will Take Steps to Prevent Environmental Buildup of PCBs. Chemical a Engineering News 4B;11, July 20, 1970. 25. Anon.: Environmentally Hazardous Polychlorinated Biphenyls Are Even More W idespread.. . . Chemical Engineering 79:18, October 2, 1972. 26. Anon.: Monsanto Releases PCB Data. Chemical a Engineering News 49: 15, December 6, 1971. 27. Edwards, R.: The Polychlorobiphenyls, their Occurrence and Significance. A Review. Chemistry and Industry 47: 1340, 1971. 28. Anon.: Chemical Pollution. Polychlorinated B iphenyls. Science 175: 155, 1972. 29. Anon.: Research Heightens Concern Over PCBs. Chemical 6 Engineering News 50: 27-B, April 17, 1972. 30. Anon.: Prevalence, Impact of PCBs Probed. Chemical a Engineering News 50: 28-30, September 11, 1972. 31. Anon.: An International Agreement Limits PCB Use. Chemical a Engineering News 51: 2-3, F ebruary 26, 1973. 32. C arnes, R.A. et a l.: Polychlorinated Biphenyls in Solid Waste and Solid-Waste Related M aterials. Archives of Environmental Contamination Toxicology 1: 27-36, 1973. 33. T as, Albert C. and de Vol, R. H .: Characterization of Four Major Components in a Technical Polychlorinated Biphenyl M ixture. Environmental Science a Technology 5: 1216-10, 1971. VIII-3 NfcV 0 3 b 1*15 34. Gustafson, Carl G.: PCBs - Prevalent and Persistent. Environmental Science & Technology 4: 814-19, 1970. 35. Polychlorinated Biphenyls - Contamination of Animal Feeds, Foods, and Food Packaging M aterials. Federal Register 38: 18096-104, July 6, 1973. 36. Papageorge, W.P. {Monsanto Industrial Chemicals Company): Personal Communication. December 7, 1973. 37. Papageorge, W.P. (Monsanto Industrial Chemicals Company): Polychlorinated Biphenyl (PCB). A Presentation to the Effluent Standards and Water Quality Information Advisory Committee, November 29, 1973. 7 pp. 38. Nelson, N.: PCBs - Environmental Impact. A Review by the Panel on Hazardous Toxic Substances. Environmental Research 5: 249362, September 1972. 39. United States Tariff Commission, TC Publication 601: Imports of Benzenoid Chemicals and Products. United States General Imports of Intermediates Dyes, Medicinis, Flavor and Perfume Materials, and other Finished Products Entered in 1972 under Schedule 4, Part 1, of the Tariff Schedules of the United States. Washington, U .S .T .C ., 1973. 98 pp. 40. Customs Bureau Personnel in New York and Washington: Personal Communications, December 1973. 41. Tse, F. Y. et a l.: Review of Dielectric Media - Liquid Insulation. Insula on/Circuits, January 1971. 42. Industry Statistics on Electric Power Equipment. Predicasts, Quarterly Issues 47-54, 1972 and 1973. 43. Cawley, J . (Edison Electric Institute, New York): Personal Commun ication, November 26, 1973. 44. Boquist, E .R . (Westinghouse): The Need for Continued Use of Polychlorinated Biphenyls as Electrical Insulating Liquids. Pre sented to the National Industrial Pollution Control Meeting, Jan u ary 10, 1972. 15 p p . VIII-4 NEV 036416 45. McAllister, John F. et al. (General Electric C o.): Benefits of PCB Use. Private Communication to Dr. Edward J . B urger, J r . , Executive Office of the President, Office of Science and Technology December 30, 1971. 36 pp. 46. Anon.: Foreign Companies Exporting Transform ers to the United States. Electrical World, June 29, 1970, p . 59. 47. Monsanto Chemical Co. , Organic Chemicals Division Technical Bulletin O/PL-306A: Aroclor Plasticizers. No date. 48. Anon.: Japanese Develop Method to Decompose PCB. Chemical Marketing Reporter 203:27, April 9, 1973. 49. National Industrial Pollution Control Council, Electric and Nuclear Sub-Council: The Use and Disposal of Electrical Insulating Liquids, Sub-Council Report. Washington, N .I.P .C .C ., 1971. 22 pp. 50. Livltz, N. et a l.: Control Technology for Polychlorinated Biphenyls (PCBs). Argonne National Laboratory, report to Control Systems Laboratory, EPA, (April 1973). 51. Electrical Industry, Selected Sources: Confidential Communications, December 1973. 52. Department of Commerce: U .S. Industrial Outlook 1974 with Projections to 1980. Washington, Department of Commerce, 1973. p . 349. 53. Current Industrial Reports: Fluorescent Lamp B allasts, Second Quarter 1973. Department of Commerce SerieB MQ-36C (73)-2, August 1973. 54. Onishl, H arry (Commonwealth Edison Company, Maywood, Illinois): Personal Communication, December 19, 1973. 55. Salomon, Paul (Yates Manufacturing, Chicago): Personal Commun ication, December 19, 1973. VIII-5 NEV 036^17 EXHIBIT VIII (4) EPA EXCERPTS FROM NEMA'S PROPOSED ENVIRONMENTAL CONTROLS (continued) 2. Liquid Operating procedures should he such as to minimize or eliminate contact with askarels. Use of eye protection is recommended. The use of porous gloves which can absorb and retain askarels is to be avoided. B arrier creams or re sistant gloves should be used if contact is unavoidable. Use of enclosed transfer and handling equipment, processing equip ment, and mechanical washers reduces direct contact. Safety glasses with side shields or a face Bhield should be worn when handling askarels. D. Manufacturing Housekeeping Manufacturing equipment and operating procedures should safe guard against loss of askarels to the environment through proper containment and disposal procedures. Enclosed systems of sealed piping, properly gasketed Joints, valves, containers, and processing chambers should be used for any portion of the operation where askarel tem peratures may exceed 55C. Enclosure should preferably extend to all other portions of the system insofar as practicable. Containment provisions should be established around all aBkarel processing areas to ensure against inadvertent loss to sewer systems by spillage, leakage, or other uncontrolled conditions or events. Spills of askarel should be removed promptly by means of absorptive material, such as sawdust, or trapped and removed by pumping or other suitable means. Waste fluids containing askarel not suitable for reconditioning or reuse should be collected (by means of trap s, drip pans, tray s, etc.) from the various parts of the manufacturing and processing area (including washers or other cleaning devices). Disposal should be made in accordance with Part V of this section. Wiper ra g s, clothing and other extraneous m aterials saturated with askarels should be collected within the containment area for properly controlled laundering or disposal (see Part V of this section). NEV 0364L6 EXHIBIT VIII (5) EPA EXCERPTS FROM NEMA'S PROPOSED ENVIRONMENTAL CONTROLS (continued) E. Disposal of Askarel Wastes Methods for disposal of liquids and saturated solids generated by the manufacturing operation should be in accordance with those outlined In Part V of this section and should include (but not be limited to) the following wastes: 1. Contaminated liquid askarel which is unsuitable for reclaiming as a dielectric fluid. 2. Liquid askarel from solvent operations or w ater/ detergent type washers. 3. Saturated earth or other absorbent media from filtering operations. 4. Saturated sawdust or other absorptive materials from spills. 5, Saturated filters from vapor control devices and other filters. 6. Saturated wastes (paper, ra g s, e tc .) . 7. Saturated, spent gasket materials. 8. Askarel-contaminated vacuum pump oils. 9. Askarel~contaminated steam je t vacuum system condensates. F. Miscellaneous Procedures 1. Spills by leakage from finished capacitors should be cleaned up promptly by means of absorbent media which should then be moved to containers provided for that purpose within the containment area and later disposed of properly. NEV 036419 EXHIBIT VIU(6) EPA EXCERPTS FROM NEMA'S PROPOSED ENVIRONMENTAL CONTROLS (continued) 2. Askarel wastes should never be disposed *of down effluent drains or sew ers. The utmost care muBt be . exercised to prevent accidental loss by these avenues to the environment. 3. Capacitors failing tests or otherwise designated for disposal must be controlled and handled in accordance with the Intent of the procedures above, finally being disposed of by one of the means outlined in Part V of this section. NEV 036420 EXHIBIT v m (7 ) EPA " EXCERPTS FROM NEMA'S PROPOSED ENVIRONMENTAL CONTROLS (continued) IV. CONTROL OF WATER EFFLUENTS .. .Existing drain systems in capacitor manufacturing plants are probably contaminated as a result of past practices, and askarel traces may continue to show up In effluent streams for some tim e. However, the level should continue to decrease with the proper containment of askarel wastes and no further discharges Into drain systems. Other sections of this report provide that no askarel wastes of any kind be disposed of in any water effluent streams and that accidental 9pills ba prevented from getting into such stream s. A. Concentration Limits The 1972 EPA proposals are to keep PCB levels in riv e rs and lakes below 0.01 parts per billion. Plant effluent streams should be managed and controlled in a manner consistent with this goal. B. Monitoring Streams On a reg u lar basis consistent with plant situations, all effluent streams should be analyzed. The procedures for per forming the necessary analyses are contained in Section 5, Analysis of Water and Sediment for Polychlorinated Biphenyls. This procedure or its equivalent should be used. C. Methods For Minimizing Effluent Stream Contamination The ideal approach is to totally isolate all effluent streams that could be contaminated with askarels during manufacturing processes and prevent them from being discharged from the plant. Carbon adsorption, limestone beds, and solvent extraction are techniques which can be applied to reduce the aekarel content of effluent stream s. These techniques may be most useful in cleaning up water used In plant processing and to permit re cycling . NEV 036421 EXHIBIT VIII (B) EPA EXCERPTS FROM NEMA'S PROPOSED ENVIRONMENTAL CONTROLS (continued) V. SCRAP DISPOSAL PROCEDURES * The manufacture and use of capacitors involve processes which produce askarel-saturated solids and liquids containing or composed entirely of askarel, which should be disposed of as w astes. Specific sources of these materials appear throughout this document but may be placed into three categories; 1. Capacitor units impregnated with ask arel. production and field rejects. 2. Manufacturing process liquid wastes containing askarel. 3. Solid waste purposely or accidently saturated with askarel. Disposal should be done in a manner which is consistent with proper concern for the environment and which minimizes any release of askarels to the environment. A. Disposal of Capacitor Units Scrap capacitor units can be generated during manufacturing processes or during field service. Production rejects are those capacitors which are rejected after the impregnation process in the course of production by the capacitor manufacturer. They may be rejected for mechanical or electrical reasons, or because of obsolescence. Field rejects are those units which are rejected or which, for other reasons, are to be scrapped after shipment from the plant where they were manufactured. NEV 036422 EXHIBIT VIA (9) EPA EXCERPTS FROM NEMA'S PROPOSED ENVIRONMENTAL CONTROLS (continued) 1. Production Rejects Rejected capacitors in capacitor manufacturing plants rep resen t a concentration of aekarel. It is Important that their disposition be made in a manner consistent with proper concern for the environment. Therefore, capacitors should be disposed of only in supervised dry landfill sites which meet all applicable State requirem ents. Care should be exercised to insure that no loss of liquid will occur during transportation to the disposal site. Incineration of scrap capacitors in facilities designed to accept such solids should provide an alternate means of disposal as such services become available in the future. 2. Field Rejects Small capacitors (defined as containing less than 2 pounds of askarel) are practically always used as components in other electrical or electromechanical equipment. Typical examples of large quantity usage of such capacitors are in fluorescent lamp ballasts and residential air conditioning equip ment. Failure of such capacitors may resu lt in scrapping of the device of which it is a p art (as in a fluorescent ballast) or re placement and scrapping of the individual capacitor (as in a room air conditioner). However, the majority of such capacitors do not fail in service, but are scrapped as a result of wearing out or obsolescence of the devices in which the capacitors are used as components. T h u s. the matter of disposal is characterized by a low concentration of small quantities of askarel throughout the country and, indeed, throughout the world. Fortunately, the nature of the devices and equipment in which such capacitors are used is such that they are normally disposed of in dry land fills as a matter of convenience. Since it is impractical at present to exercise any meaningful control over the disposition of the bulk of such devices and equipment. It is imperative that askarel used for impregnating small capacitors be limited to the recently intro duced type which contains a typical concentration of 0.4 percent of the higher boiling homologs.* Monsanto Method T-02302 NEV 036423 EXHIBIT VIII (10) EPA EXCERPTS FROM NEMA'S PROPOSED ENVIRONMENTAL CONTROLS (continued) Large capacitors (those incorporating more than 2 poundB of askarel) should be disposed of according to the procedure for production rejects. See p ar. A .l. B. Disposal of Liquid Wastes All waste askarel or liquid wastes containing askarel should be disposed of in accordance with one of the following procedures: 1. Incineration Present knowledge indicates that proper incineration must involve a suitable balance between dwell time and temperature in the incinerator plus oxygen availability and. finally, suitable scrubbers to remove the HC1 which will be formed; e . g . , (1) 2-second dwell time at 2000F and 3 percent excess oxygen in stack gas; (2) 1 1/2-second dwell time at 2700F and 2 percent excess oxygen in stack gas. These facilities should meet the applicable requirements of the State in which they are located and should control effluents within the limits set forth in this document. 2. Toxic and Hazardous Waste Disposal Sites Certain landfill sites have been classified by State and Federal Governments as suitable for the disposal of toxic and hazardous liquids. Where such approved sites exist, they may be used for the disposal of liquid wastes described in this doc ument. (See Section 4). 3. Packaging and Shipment a. Transportation to the disposal facility should be in containers which will prevent leakage and accidental loss of askarel to the environment. b. Containers should be labeled as to contents and precautions relative to loss to the environment. NEV 036424 EXHIBIT v m d i ) EPA EXCERPTS FROM NEMA'S PROPOSED ENVIRONMENTAL CONTROLS (continued) c . Containers used for this purpose should not be used for any other materials or retired from service until they are completely cleaned. Any solvents used in cleaning these containers will be contaminated with askarel and should be disposed of according to the same procedures herein described. C , Disposal of Solid Wastes All solid wastes which have been saturated with askarel should be disposed of by the following procedure: 1. The saturated wastes should be placed Into leakproof containers and transported to a supervised dry landfill site meeting State requirem ents. Alter natively , they can be disposed of by incineration in Staterapproved facilities. 2. Solid absorbents used for spills can be disposed of uncontained in the supervised dry landfill site; transport to the site should be in closed containers. Alternatively, incineration can be used in accordance with p a r . B (See Section 4 for facilities). NEV 036425 EXHIBIT Vin (12) EPA EXCERPTS FROM NEMA'S PROPOSED ENVIRONMENTAL CONTROLS (continued) VI. LABELING Capacitor units vary greatly in size and in end use or application. Small capacitor units are frequently applied as a component of another piece of equipment such as a fluorescent lighting ballast, a roadway or area lighting luminaire; a motor, etc. In such applications a label on the capacitor unit referencing approved disposal procedure would not normally be visible when the piece of equipment is disposed of. For the foregoing reasons the method of providing disposal instruc tions for small capacitors and large capacitors is treated separately. 1. Small Units (incorporating Less Than 2 Pounds of Askarel) Small capacitors are defined as those which contain askarel in quantities up to about two (2) pounds each and in which the free liquid does not exceed 0.4 pounds. They are hermetically sealed in metallic cases. Such capacitors are applied as a com ponent of a larger piece of equipment. Attaching a label to such equipment referencing this Guideline or describing disposal pro cedures would be of limited practical value. 2. Large Capacitor Units (Incorporating More Than 2 Founds of Askarel) The capacitor manufacturer should affix a label in a conspicuous place, referencing this document or describing disposal procedures consistent with it. NEV 036426 EXHIBIT y in (13) EPA EXCERPTS FROM NEMA'S PROPOSED ENVIRONMENTAL CONTROLS (continued) SECTION 3 TRANSFORMER GUIDELINES GENERAL GUIDELINES A. Definitions - Types of Transform er Askarels The term askarel generally describee a broad claBs of non flammable synthetic chlorinated hydrocarbon insulating liquids widely used in transform ers, reactors, and accessory equipment operated at power frequencies. Askarels of various compositional types are in use (for the general properties and types, see ASTM Specification for Chlorinated Aromatic Hydrocarbons (Askarels) for Transform ers, D 2283). The following trademarks are used by electrical manufacturers to designate the askarels used in their products: . Asbestol . Chlorextol . Inert een . No-Flamol Pyranol Saf-T-Kuhl B. Safety Precautions 1, Vapors Breathing vapor or fumes from heated askarels should be avoided. Provisions shall be made for adequate ventilation and regulation of manufacturing operations to avoid open ex posure of hot askarels (55C or h ig h e r). The gases produced when askarel is decomposed by very high temperatures (such as that of an electric arc) in the presence of air or organic NEV . 03642? EXHIBIT VIII (14) EPA EXCERPTS FROM NEMA'S PROPOSED ENVIRONMENTAL CONTROLS (continued) insulating materials contain a high percentage of hydrogen chloride, and small percentages of other g a se s.' If exposure to high concentrations of askarels or its arced products is necessary under emergency conditions, an approved gas mask of the organic canister-type or self-contained breathing apparatus must be worn. Such exposure should be under the surveillance of other personnel capable of rescue in cbbo of accident. If the odor of askarel or Its arced products is detected by the person wearing protective equipment, he should immediately go into fresh air. 2. Liquid Operating procedures should require avoidance of contact with any askarels. The use of porous gloves which can absorb and retain askarels is to be avolced. Resistant gloves and aprons of the neoprene, polyethylene, viton type should be used if con tact is unavoidable. In case of spillage on the clothing, the clothing should be removed as soon as practical, the skin washed and the clothing laundered. Safety glasses with side shields or a face shield should be worn when handling askarels. Hands should be washed with warm water and soap before eating, drinking, smoking or using toilet facilities. C. Transport Container Marking Any container such as tank cars, tank trucks, drums, cans, e tc., used to transport transformer askarels, new or used, should be labeled . . . D. Receiving, Handling and Storage of Askarels Askarels are shipped in tank cars, tank trucks, steel drums, metal cans and test sample containers. When received, all containers should be inspected for leaks. NEV 036^28 EXHIBIT VIII (15) EPA EXCERPTS FROM NEMA'S PROPOSED ENVIRONMENTAL CONTROLS (continued) 1. Storage Tanks Storage tanks should be erected so that inspection can be made for leaks or sp ills. Construction should be Buch that inadvertent leakage or spills are prevented from reaching streams and sanitary or storm sewers. 2. Tank Cars and Tank Trucks All bulk shipment equipment should be inspected for leaks Immediately upon receipt. Drain pans must be provided to p re vent spillage from unloading hoses and connections. Askarel liquid collected in drain pans should be placed in "SCRAP ASKAREL11 drums for disposition. 3. Steel Drums, Cans, and Test Sample Containers On delivery, all such shipments should be carefully in spected for leaks. The containers should be stored indoors in an area especially selected for this purpose. A curb should enclose the area to provide a basin for containing the askarel from one or more containers should the containers be damaged. The area must not have a drain which Is connected to a sanitary or storm sewer. If an indoor storage area is not possible, the containers should be stored under a lean-to. E. Water Effluents - Sampling, Concentration Limits and Analytical Procedures ...E x istin g drain systems from manufacturing plants, rep air shops and installation sites may be contaminated as a result of past practics. 1. Concentration Limits The 1972 EPA proposals are to keep PCB levels in riv ers and lakes below 0.01 parts per billion. Plant effluent streams should be managed and controlled in a manner consistent with this goal. NEV 036429 ( EXHIBIT VIII (16) EPA EXCERPTS FROM NEMA'S PROPOSED ENVIRONMENTAL CONTROLS (continued) 2. Monitoring Streams All plant effluent streams should be monitored on a regular basis, consistent with plant situations. The pro cedures for performing the necessary analyses are contained In Section 5, "Analysis of Water and Sediment for Polychlorinated Biphenyls." This procedure or Its equivalent shall be used. 3. Methods for Minimizing Effluent Stream Contamination The ideal approach is to totally isolate all effluent streams that could be contaminated with askarels during manufacturing processes and prevent them from being discharged from the plant. F. Disposal Procedures and Services 1. Sources of Materials Requiring Special Handling and Disposal Procedures Liquids containing PCBs and solids containing or con taminated with PCBs may be obtained from any of the following sources: transport containers, transformer manufacturing pro cesses, in-test failures, liquids contaminated beyond reclamation, in-service transformer leaks and failures, askarel-filled trans formers scrapped for any reason, etc. 2. Classification for Disposal of Materials Containing PCBs In general, there are three types of materials requiring disposal: liquids, burnable solid materials containing PCBs and nonburhable solid materials contaminated with PCBs. a. Liquids. Liquids containing PCBs requiring dis posal by high-tem perature incineration may consist of the following: (1) PCBs contaminated with mineral oil. (2) Mineral oil contaminated with PCBs. NEV 036430 EXHIBIT in (2) EPA END-USES OF AROCLORS (continued) End-Use 1016 1221 1232 1242 1248 1254 1260 1262 1268 M iscellaneous Industrial . ashesives . wax extenders . dedusting agents . inks . cutting oils . pesticide extenders X XXX X X X XX X X X X Note: Source: X denotes use of a given Aroclor in a specific end-use, while XX denotes principal use References 16. 36, 37, 38 SECTION V NEV 036432 SECTION V MANUFACTURING PROCESSES The basic United States patents for the manufacture of chlorobiphenyls are . U .S . 1,892,387 and 1,892,398 (December 27, 1932), R. L. Jenkins (to Swann R esearch, Inc.; reassigned to Monsanto Chemical C o .). . U .S. 3,029,295 (April 10, 1982), Robert Thermet and Ludovic Parvi (to Socit d' Electro-Chimie D'Electrometallurgie et des Aciries Electriques d l Ugine). . U .S. 1,892,400 (December 27, 1932), R. L. Jenkins and J . A . Sikarskl (to Swann R esearch, In c . ; reassigned to Monsanto Chemical C o .). F o ra digest of selected process patents Including recent developments see Exhibit IV. 1. THE MANUFACTURE OF PCBs IS NOT A COMPLEX PROCESS PCBs can be prepared by chlorinating biphenyl with anhydrous chlorine in the presence of iron filings or ferric chloride as catalyst (11, 34). . The product is a mixture of several PCBs and can be purified and fractionated by distillation . The by-product is hydrogen chloride, which is neutralized before distillation . The degree of chlorination is principally determined by the time of contact of biphenyl with anhydrous chlorine; 12 to 36 hours usually . Reaction temperature is about 150C. and pressure is near atmospheric V -l NEV 0364-33 . The degree of chlorination is measured by - the specific gravity of the m ixture, or the ball and ring softening point when the product is more viscous . Overall, a batch or semi-continuous cascade process can be used. . These processing fundamentals are featured both in U ,S . and Western European installations. Cl) C urrently There Is Only One Known Commercial Scale' FCB Production Installation In The U .S, This facility is the William G . Krummrich plant of the Monsanto Industrial Chemicals Co. at Sauget, Illinois. The facility is specifically designed for chlorobiphenyls- production The technology is not complex and other chemical firms and laboratories in the U .S . have the technical potential to produce PCBs Process flow in the Krummrich plant is summarized in Exhibit V. reported yields are h ig h , 97% or better (36) there are 6 reactors. 3 batch and 3 cascade batch size is about 2,500 gallons a new distillation column was installed in 1971 at an estimated cost of almost one million dollars (37) .. the gas fired unit enables production of Aroclors with minimized fractions of the highly chlorinated, persistent material NEV 03643<r V-2 . the heel cut residues, representing about 2%of throughput, are drummed, diluted and incinerated - transform er Aroclors can be diluted to 60-70% PCB with chlorobenzenes before shipping - overall, the process has been simplified (except for environmental controls), since fewer Aroclors are manufactured including elimination of flaked product (2) Monsanto Has Reported Significant Environmental Controls At The Krummrich Plant In Exhibit V a summary is provided of these controls The in-house goal has been reduction of PCBs in water discharges to less than one pound p er day (36). The goal for air emissions is also less than one pound per day (36). An incinerator was erected at Sauget to process both Monsanto's own wastes and as a service to in d u stry . - the unit, costing $1,500,000, is sized to process about 10 million lb s. p er year (14). controlled destruction takes place @2400F. @2%excess 0 over 1.5 sec. under an oper ating perm it from the Illinois EFA (36). exhausts are passed through a high-energy venturi scrubber, then a packed column with weak muriatic acid; exhausts are monitored as well as discharges of neutralized scrubber liquor (36). the service charge is 3 per lb. (14, 36). there is a cu rren t backlog of roughly 250,000 lb s. of material to incinerate and about 20 million lb s. have been destroyed to date (36). the company no longer reprocesses contaminated materials V-3 0 3 6 4 3 5 2. HISTORICALLY. AROCLORS HAVE BEEN SHIPPED IN A FASHION SIMILAR TO ANY OTHER COMMODITY The liquid chlorinated biphenyls have been packed and shipped in galvanized-Bteel drums or in tank cars constructed of nonrusting metals such as aluminum or tin-coated metal. The resinous products have been packed and shipped in open-top galvanized-steel drums, and the high-melting solid products are packed and shipped in bags. The railroad shipping classification is Resin Synthetic NOIBN. Exhibit VI summarizes the historical shipping practices based on the description in Monsanto's technical bulletin on plasticizers (47). It is reasonable to assume that the containers associated in the paBt with the distribution of Aroclors to Monsanto's open system customers have been a significant, but now declining, solid waste source of the environmental burden of PCBs. C urrently, Monsanto emphasizes the use of consigned tank cars for distribution to its 25-30 remaining custom ers, capacitor and transform er manu facturers (36). Shipping in 55 gallon steel drums still takes place for "topping" p u rp o ses. Exhibit VII is a sample of the type of label used for currently marketed Aroclors, providing explicit instructions for safeguards and uses. The National Electrical M anufacturers Association (NEMA) has developed standard guidelines for shipping and handling of A roclors. See Exhibits VIII and IX. NEV 03*436 V-4 3. THERE IS EVIDENCE OF RESEARCH AND DEVELOPMENT ACTIVITY TO CONTROL SPENT PCBs The Monsanto incinerator 1b evidence of th is, featuring a proprietary John Zink burner design (36). Envirotech Corporation (23) reported that FCBs can be almost totally decomposed in multiple hearth incineration. . A recent research project showed that PCB (Therminol FR-1) in waste sludges can be over 99.9%decomposed in a BSP multiple hearth furnace when operated at an exhaust gaB temperature of 1100F. . The study shows that multiple hearth inciner ation can achieve more efficient PCB destruction in combination with sewage sludge than other types of incineration methods. . A BSP furnace operating in the normal 1500-1700F. range but with an exhaust gas temperature of only 1100F. can decompose 99.9% of PCB in waste sludges 500F. or more lower than previous norms. . The majority of the heat required in a BSP furnace is normally supplied by the organic content of the waste sludges and the considerably lower exhaust tem perature in the BSP furnace allows fuel savings of 60% in removing PCBs from the environment. A Koochl U niversity team in Japan has developed a caustic soda solution to completely decompose polychlorinated biphenyl (48). . High p re ssu re is said to tu rn the chlorine Into sodium chloride within a short time. . A pilot plant capable of decomposing 30 lite r s /h r . of PCB will be completed in 1973 atKoochi University and the group will continue experiments. also using alcohol and other solvents. NEV 03643? V-5 EXHIBIT IV (1) EPA PATENT DIGEST PROCESSES FOR THE PREPARATION OF PCBs 3,717,685 February 20, 1973 Russell G. H ay, Vincent A . Notaro, Charles M. Selwitz Gulf Research 8 Development Company PROCESS FOR PREPARING CHLORINATED AROMATICS A process for preparing a chloroaromaUc compound which Involves heating an aromatic compound In the presence of a nitrate ion, a n itrite ion. NO or N02> HCl, w ater, oxygen, a strong acid and a paraffin or a cycloalkane. 3,717,684 February 20, 1973 Vincent A. Notaro, Charles M. Selwitz Gulf Research 6 Development Company PROCESS FOR PREPARING CHLORINATED AROMATICS A process for preparing a nuclear polychloro alkyl aromatic compound which involves heating an alkyl aromatic in the presence of a nitrate io n , a nitrite io n , NO or N O j, HCl, w ater, oxygen and a strong a cid , wherein the molar ratio of HCl to aromatic compound is initially at a level of about 4:1 to about 10:1 and such ratio is maintained at approximately such level during the course of the reaction. 3,655,523 April 11, 1972 Harold O. Seeburger, Lee H. Horsley The Dow Chemical Company METHOD FOR SEPARATING A 2- AND 4-CHLOROBIFHENYL FROM THE CORRESPONDING HYDROXY BIPHENYL COMPOUNDS 2-Chlorobiphenyl, 4-chlorobiphenyl or mixtures thereof may be separated from a mixture with the corresponding hydroxybiphenyl compound by adding to the mixture of such compounds an azeotropic agent which is a glycol, glycol monoalkyl or phenyl ether, glycerol, glycerol alkyl ether, alkanolamine or dialkylenetriamine having a boiling point within about 45C. of the halobiphenyl compound at atmos pheric pressure, and then fractionally distilling the mixture thus formed at a p ressu re of up to about 200 mm. Hg. absolute. NEV 036438 EXHIBIT IV (2) EPA PATENT DIGEST (continued) 3,547,790 December 15, 1970 Bobby F . Dannels and Alvin F . Shepard Hooker Chemical Corporation AROMATIC CONDENSATION PRODUCTS A proceBB for producing aromatic condensation products comprises passing an electric current between a cathode and an anode in contact with liquid phase hydrogen fluoride, wherein the hydrogen fluoride is also in contact with an aromatic compound having a hydrogen atom substituted in at least one position of the aromatic rin g . The polymer products.have excellent heat resistance and electrical insulation properties and can be coated on other types of polymers to modify the surface characteristics thereof. The polymers can be converted to sulfonated polymer products. 3.539,622 November 10, 1970 Richard F . Heck Hercules Incorporated PROCESS FOR PRODUCING DIARYL COMPOUNDS A process for producing a diaryl compound which comprises an aryl mercuric salt in which the aryl group contains a benzene ring to which the mercury is directly attached with a palladous salt at a tem perature in the range of 20 to 150C. 3,145,237 August IB, 1964 Robert van Holden, Govert V erberg, and Bob Balder Shell Oil Company POLYNUCLEAR AROMATIC COMPOUNDS The process for the lnterroolecular condensation of aromatic compounds, which comprises contacting an aromatic compound having a labile hydrogen atom attached to an aromatic nucleus, in liquid phase, with a salt selected from the group consisting of the salts of the palladium and platinum group metals with an acid selected from the group consisting of mineral acids, aliphatic monocarboxyllc acids and sulfonic acids, under substantially anhydrous conditions, at a tem perature of from about 40 to 200C., in the presence of a member of the group consisting of the oxides and salts of the alkali metals and alkaline earth m etals. NEV 036^39 EXHIBIT IV (3) EPA PATENT DIGEST (continued) 3*072,728 January B* 1963 Milton Kosmln and Richard L. Wasson Monsanto Chemical Company METHOD OF PREPARING HALOGENATED DIPHENYL COMPOUNDS A process for the preparation of individual* preselected halogenated diphenyls or diphenyl ethers which calls for the reaction of o-chlorophenol, l-chloro-2-nitrobenzene and potassium hydroxide to form 2-chlorophenyl 2-nitrophenyl e th er. This product Is then reduced to 2-chlorophenyl 2-aminophenyl ether. The latter ether must be diazotized, after which the diazonium salt Is finally converted to the desired bis (2-chlorophenyl) ether. 3*068,297 December 11, 1962 Harold 1. Weingarten Monsanto Chemical Company ISOMERIZATION OF HALOBIPHENYLS The Invention relates to an improved process for effecting the conversion of by-product halogenated biphenyls to more useful liquid dielectric compositions having an Improved dielectric constant. The by-product dlhalogenated biphenyl compositions, particularly those rich In 2, 2'-dlhalobiphenyl can be lsomerized in the presence of aluminum chloride and anhydrous hydrogen chloride at temper atures from about 50C ., to about 250C. and more preferable still from about 70C. for a time of from about 15 minutes to about 10 hours or more and preferable from about 1 hour to about 5 h o u rs . 3,029.295 A pril 10. 1962 Robert Thermet and Ludovic Parvi Socit d'Electro-Chlmie d'Electro-Mtallurgic et des Aciries Electriques d'Ugine PREPARATION OF POLYCHLORINATED DIPHENYL DERIVATIVES A method of preparation * in a single stage of chlorinated diphenyl derivatives having a degree of chlorination up to 100% by passing a gaseous stream containing a chlorine gas ingredient and a diphenyl ingredient as essential ingredients through a fluidizable bed of divided m aterial, maintaining the temperature in the bed at a value of at least as high as the boiling point of a desired diphenyl derivative, and regulating the rate of throughflow' of said gaseous stream so as to maintain said bed In a state of stationary dense fluidization. This Invention relates to a method of producing poly chlorinated diphenyl derivatives. and more specifically the higher chlorinated derivatives Df diphenyl, such as decachlorodiphenyl and products of approaching composition. NEV 0 3 6 **0 EXHIBIT IV (4) EPA PATENT DIGEST (continued) 3,007.975 November 7, 1961 John T . MasBongale and Theodore H . Fairbanks American Viscose Corporation 4,4' BIS- (CHLOROMETHYL) -BIPHENYL A process of preparing 4,4'-bis-(chlorom ethyl)-biphenyl which comprises reacting biphenyl, formaldehyde and hydrogen chloride In the presence of a catalyst system comprising zinc chloride and water in a weight ratio at the start of the reaction of about 1.5 to 4 p arts of zinc chloride to 1 p a rt of water and wherein said zinc chloride is presen t In a ratio of 1.2 to 2.55 moles of zinc chloride p er mole of biphenyl present at the sta rt of the reaction. 1,892,400 December 27, 1932 Russell L. Jenkins and Joseph A . Slkarskl Swann Research, Inc. DIPHENYL RESIN AND METHOD OF PRODUCING THE SAME T his Invention related to diphenyl re s in s , and in particular to a process by which resins having predeterm ined properties may be produced, This process for the production of diphenyl by thermal synthesis, preheated benzol vapors are pumped through a bath of a molten salt or molten metal, such as lead, said bath being main tained at the diphenyl forming temperature of about 850C. 1,892,398 December 27, 1932 Russell L. Jenkins Swann Research, Inc. NONCRYSTALLINE HIGHLY CHLORINATED DIARYL RESIN The invention relates to the production of non-crystalline highly chlorinated diary! resins Wherein various percentages of complex high boiling compounds which are formed as a by-product in the thermal synthesis method of producing diphenyl are mixed with the diphenyl before chlorination. The diphenyl is separated from the product of the diphenyl reaction by distillation. 036^ EXHIBIT IV (5) EPA PATENT DIGEST (continued) 1,802,397 December 27, 1932 Russell L. Jenkins Swann Research. In c. PROCESS FOR THE PRODUCTION OF CHLORINATED DIARYLS ' This invention relates to a method for the production of chlorinated diary Is and has for its object the provision of means whereby varying amounts of chlorine may be substituted in diphenyl, o r other diaryls or substituted d la ry ls, to produce compounds having physical properties ranging all the way from light oils to solids or semi-solids at ordinary tem peratures. In the process for the catalytic production of chlorinated diphenyl, inducing and maintaining a thermosyphonic {low of the reacting mass through the catalyst by means of the action of the presence of the catalyst. NEV 036442 \ EXHIBIT V (1) EPA PROCESS FLOW AND ENVIRONMENTAL CONTROLS AT MONSANTO'S SAUGET PLANT 1. Process Flow* DISTILLED BIPHENYL-* REACTORS-frHOLDING AND AND ANHYDROUS NEUTRALIZATION CHLORINE TANKS > DISTILLATION-^ HOLDING--> BLENDING AND UNIT TANKS SHIPPING . Biphenyl purity is controlled . Batch or . Flexible, closed cascade tankage . Gas fired . Product . Dilution with storage chlorobenzenes . Scrap iron catalyst . Lime neutralization . First cut is recycled to reactor . Flexible . Drumming or closed tank car Riling tankage . Heart cut Is product . Heel cut is drummed, diluted and incinerated * * Source: References 11. 36 ,v?eo *3N \ \ EXHIBIT V (2) EPA PROCESS FLOW AND ENVIRONMENTAL CONTROLS AT MONSANTO'S SAUGET PLANT (continued) 2. Environmental Controls** Drainage is directed to trenches and piping, and then to one of two 3,000-gallon settling b asin s. Pads a re curbed. This insures PCB containment in case of accidental spill or equipment failure. When small quantities of PCB's are collected into the settling basins in the manufacturing area they are later pumped into drum s, and eventually incinerated. In the incinerator area itself, drainage is directed to trenches and piping which flow into a 10.000-gallon basin. Recovered PCB's are periodically pumped to storage, or incinerated. In the manufacturing area, rupture disc lines and atmospheric vents have been rerouted through catch tan k s, or redirected to settling basins. This insures that if a rupture does occur, PCB's will be contained in a controlled area. Nitrogen blanketing on storage tanks has been provided to eliminate , any "breathing" of the tanks and resultant PCB escape. Mist eliminators have been installed in vapor lin es. ** Source: References 14, 3B, 37 ***9 E 0 A9N EXHtBITV (3) EPA PROCESS FLOW AND ENVIRONMENTAL CONTROLS AT MONSANTO'S SAUGET PLANT (continued) Underground sewers have been replaced with aboveground sew ers, and others repaired or combined, to enable monitoring of the effluent from the department. In addition, this prevents any unknown buildup of PCB's in the sewer systems or any contamination of PCB's into other sew ers. Among the housekeeping responsibilities operators have assumed are these: All pumps are checked for leakage on every shift. Drip pans that collect leaks are emptied into scrap PCB drums. All leaks are reported and documented so that corrections can be made and settling basins observed. - "Floor Dry" is used to absorb any liquid PCB's that have spilled or leaked. If it becomes necessary to flush PCB's to the settling b a sin , a minimum amount of water is u se d . Sampling drums and scrap-PCB drums are quickly palletized, lab eled , and transferred to the incineration a re a . EXHIBIT V (4) EPA PROCESS FLOW AND ENVIRONMENTAL CONTROLS AT MONSANTO'S SAUGET PLANT (continued) Systems to monitor effluent have been developed * PCB content in the p arts-p er-b illio n range can be determined. The minimum detection level in wastewater is 100 ppb + 25%. Monitoring is continuous. Loading and shipping safeguards have been established to minimize accidental PCB loss during transportation. Specific written instruc tions are on every container shipped. 7 $O' Freight Classification Aroclor 1221 1232, 1242, 1248, 1254, 1260, 1262 Ball Classification Aroclor 1268, 4465, 5442, 5460 Truck Classification Aroclor 1268 Aroclor 4465, 5442, 5460 Standard Containers Aroclor 1221 Aroclor 1232 Aroclor 1242,1248, 1254, 1260, 1262 Aroclor 1268 Aroclor 4465 Aroclor 5442 Aroclor 5460 (flaked) EXHIBIT VI EPA SHIPPING OF AROCLOR FLASTICIZERi (47) Synthetic Resin, ^Liquid, NOIBN Synthetic Resin, Other Than Liquid, NOIBN Synthetic R esin, Powder, NOI Synthetic Resin, LumpB or Solid Mass, NOI Tank car, 520 lb . steel drum, 50 lb . can Tank .car, 550 lb . steel drum , 50 lb . can Tank car, 600 lb . steel drum , 50 lb . can 200 lb . fiber drum, 25 lb. fiber drum 500 lb. steel drum, 50 lb. can 450 lb. steel drum, 50 lb . can 50 lb . bag NEV 03 DIELECTRIC R U ID BY EXHIBIT VH (1) EPA EXAMPLE OF CURRENT AROCLOR LABELING PRACTICE <X > S stev cn m em SeK .f^it:r!:chidkfte Surfit itd fsi te s m net* < /\> CAUTION! CONTAINS CHLORINATED HYDROCARBONS Read and follow all IMPORTANT safeguard instructions shown on this container. WASTE DISPOSAL WnpaaititdehdfopbrriipophrroeMpneyolrnfisnluacinidntsoermantoaioytinfibcaeattri3oe*ntupruneseredpdofrupenoigdly.hcthplorrei Ship to: Supervisor Dept 831 MONSANTO COMPANY SAUGET, ILLINOIS 62201 MONSANTOCOMPANY, ST. LOUIS, MISSOURI 63166, U.SA 811.03-280.19/53 9*r*790 A3N EXHIBIT v n (2) EFA EXAMPLE OF CURRENT AROCLOR LABELING PRACTICE EN G LISH IM PO RTAN T C H LO RO D IPH EN YLS(42/.-54V ) (o r6 0 % )(P C B ) This product contains PO LY C H LO R IN A T ED B IP H E N Y L S (P C B 's) which som e studies have shown may be persistent, an environmental contaminant and, possibly. Injurious to certain forms of bird, aquatic and animal life. PREVEN T ANY ENTRY INTO THE EN V IR O N M EN T THRO UG H SP ILLS, LEAKAG E, D ISP O SA L, VAPO U RISATIO N . R E -U SE OF C O N T A IN E R S O R O TH ERW ISE. SPILLS, L EA K A G E S A N D W ASTE PR O D U C T M U ST B E CO LLECTED . Use of this product must be restricted to applications which can be controlled so that entry into the environment does not occur and to applications in which it cannot come into contact with food, animal feedsiuffs or pharmaceuticals. HARMFUL S U B S T A N C E IF TAKEN IN TERN A LLY O R IF IN P R O LO N G E D CO N T A C T W ITH TH E SK IN . C A U SE S IRRITATIO N O F SK IN AN D EYES. DU RIN G SH IP M E N T A V O ID S P IL L S A N D LEA K A G E INTO INLAN D W ATERW A YS A N D THE SEA . Store away from food, animal feedstuffs and pharmaceuticals. Keep container tightly closed. Do not eat or sm oke when using. Avoid breathing vapours, mist or fumes. D o not wear contaminated clothing. W ash product from skin with soap and water. W ash eyes by flushing with water. THIS COPY, THIS S IZ E , IN' SEVEN LANGUAGES IS PAINTED ON 30 AND 55 GALLON DRUMS USED FOR PCB SHIPMENTS. 6 ^ 9 0 A3N EXHIBIT VHI (1) EPA EXCERPTS FROM NEMA'S PROPOSED ENVIRONMENTAL CONTROLS SECTION 2 CAPACITOR GUIDELINES I. INTRODUCTION There are two general classes of askarelB used by the electrical industry. The higher chlorinated grades are the more persistent in nature. Because of their high degree of nonflammability, they are used In transformers where personnel safety Is of paramount importance. Capacitor-grade askarel has a lower degree of chlorination (com posed prim arily of the 3-chlorine isomers of biphenyl) and a higher degree of biodegradabllity. It is used in capacitors where the extreme degree of nonflammability required in transform ers is of Isbs Importance. II. CAPACITOR-GRADE ASKAREL In September of 1971, a new grade of capacitor im prgnant, Aroclor 1016, was made available to the Industry. This new grade contains a typical concentration of 0.4 percent by weight of the higher boilings homologs of the chlorinated biphenyls. Aroclor 1016 replaces Aroclor 1242 which previously was the major capacitor imprgnant and contained around 7 percent of the higher boiling homologs (the more persistent in nature). This 0.4 percent level of the higher boiling homologB should be the maximum concentration acceptable In any cap acitor imprgnant. Aroclor 1242 and 1254, previously used as im prgnants, do not meet this requirem ent and should no longer be used in capacitors designed and manufactured for alternating-current applic ations , Aroclor 1016 has the same UL nonflammability rating as Aroclor 1242. Excerpts From The National Electrical Manufacturers Association (NEMA) Official Standards Proposal (16) For Handling And Disposal Of Capacitor And Transformer-Grade Askarels Containing PCBs. NEV 036450 EXHIBIT VIA (2) EPA EXCERPTS FROM NEMA'S PROPOSED ENVIRONMENTAL CONTROLS (continued) IR. PLANT HOUSEKEEPING AND EMPLOYEE SAFETY A. Material Askarel for use In capacltorB should consist of homologs and isomers of chlorinated biphenyl with the concentration of the higher boiling homologs at about 0.4 percent.* Aroclor 1016 is considered to be the standard imprgnant meeting these require ments . Commonly used solvents Include benzene, kerosene, acetone, trlchloroethane, trichloroethylene and perchloroethylene. Typical vapor p ressu re data for Aroclor 1016 are: oc 25C 150C 200C = Q.001 mm = 0.006 mm = 4.3 mm 26.0 mm At 25C and 760 mm Hg p re ssu re , saturated air contains approximately 0.09 m g/liter. 1 mg/liter * 90.0 ppm (v/v) 1 ppm (v/v) = 0.011 m g/liter B. Bulk Fluid Shipment. Receiving, and Transfer Shipment of askarel from point of manufacture to point of receiving should be done in closed containers such as rail, tank c ars, truck tanks, marine or bargo tanks, or sealed drum s. Con tainers should be labeled as to contents and carry a label cautioning against loss of fluid to the open environment. Containers used to transport askarel should not be used for storage or to tran sp o rt other material without being completely cleaned of all traces of askarel. * Monsanto Method T-02302 NEW 036451 EXHIBIT VIII (3) EPA EXCERPTS FROM NEMA'S PROPOSED ENVIRONMENTAL CONTROLS (continued) (Cleaning procedures must take cognizance of precautions against excessive exposure and of the need for proper disposal of contaminated cleansing solvents and m aterials). T ransfer from shipping containers to processing systems should he through closed piping or tubing with appropriate valves, pumps, etc. Provision should be made for trapping and disposing of fluid lost by leakage or spills from the transfer system and from the storage containers. Drums to be retired from use should be cleaned before crushing, delivery to scrap dealers, or other disposal. Contaminated cleaning fluids and materials should be disposed of as Indicated in Part V. C. General Safety Precautions 1. Vapors Breathing vapor or fumes from heated askarel should be avoided. Provisions should be made for adequate ventilation and regulation of manufacturing operations to avoid open ex posure to askarel (especially at 55C or h ig h e r). The gases produced when askarel is decomposed by very high temperatures (such as that of an electric arc) in the presence of a ir or organic insulating materials contain a high percentage of hydrogen chloride, and small percentages of carbon dioxide, carbon monoxide and oxygen. Minute concentrations of this combination of gases are very unpleasant and irritatin g , thus giving ample warning of their presence. If exposure to high concentrations of askarel is necessary under emergency conditions, an approved gas mask or self-contained breathing apparatus should be worn. Such exposure should be under the surveillance of other personnel capable of rescue in case of an accident. If the odor of askarel is detected by the person wearing protective equipment, he should immediately go into fresh a ir. All gas masks, resp irato rs and re placement p arts should have Bureau of Mines approval and be maintained on a reg u lar schedule in accordance with the manu facturer's recommendation. 036A52