Document 3N6N8r2BmxoQ1YNNr5pNo5mzE

{ j PCB PRESENCE IN TRANSFORMER OIL & INDUSTRY SERVICES DIVISIONS POLICY ............... TAB 1 \ POLICY PERTAINING TO ASKAREL FILLED APPARATUS..................... 2 i j STORAGE FACILITIES - PROCEDURES FOR REMOVING OR REDUCING PCB CONTENT IN OIL STORAGE FACILITIES................... 3 . PRECAUTIONS TO PREVENT CONTAMINATION OF CLEAN OIL HANDLING & STORAGE FACILITIES .................................... 4 REPAIR PROCEDURES FOR OIL-FILLED APPARATUS ....................... 5 NPC00026310 753647 PCB PRESENCE IN TRANSFORMER OIL & INDUSTRY SERVICES DIVISIONS POLICY Information available at this time Indicates there Is an Industry concern that transformer oil may contain minute quantities of PCB. The sampling to date Indicates various levels of PCB content 1n some oil storage facilities, handling equipment, 1n oil supplied by the oil industry, and in some transformers now 1n service. Not all locations or transformers 1n service show PCB content, but sufficient numbers are known, and therefore, warrant limedlate revision of procedures. PCB's In transformer oil 1s not confined to Uestlnghouse. Evidence Indicates It Is spread throughout the Industry and Involves some customer oil Inventories as well as some of our own. No one knows how long it has existed. A logical guess would be for several years. The Industry Services Divisions are taking Inrnediate action to properly dispose of Its oil containing PCB and to restore our storage and handling equipment to levels as nearly undetectable as practicable. No single law, state or federal, covers the whole subject, and It 1s therefore necessary to look at the situation not only in light of current statutes, but of pending and anticipated legislation. At present, there are no nationally establlshec standards for allowable levels of PCB's 1n oil for closed electrical systems. Specifically, four states have current laws covering specific use of PCB and materials containing PCB. These are Indiana, Michigan, Minnesota, and Connecticut. A review of these State Laws 1s attached. Nearly all states have laws relating to disposition of "hazardous materials'1 and these have been Interpreted PCB by some states. Of particular Importance are the laws relating to contamination NPC00026311 753648 2 of natural waterways by PCB. These are especially stringent. Materials known to contain any. PCB must not be permitted to enter any public sewer, drains, streams, lakes, or otherwise contaminate any water system. Industry Services Divisions feel that it 1s our obligation to make these facts known to our customers. Our policy Is to reduce our own oil systems and Inventories to the lowest practical level of PCB and observe all precautions to maintain that condition. It Is a customer decision as to what 1s done with his equipment when the presence of PCB 1s detected 1n his equipment. It 1s our Intention to use a 10 ppm break point which does not discount the possibility that at some future time, such contamination may come under regulations governing handling and disposal as askarel. We should make no warranty or Implication, written or oral, that assumes any liability 1n this event,and specific disclaimers are advisable 1f customers' written orders or other conmunlcations seek such warranty. Reference to State and Federal Laws, as contained herein, 1s for our use and direction. Our customers have the responsibility to determine for themselves what laws and regulations apply. UPC00026312 753649 POLICY PERTAINING TO ASKAREL FILLED APPARATUS I. The purpose of the following policy 1s to establish a good faith effort to conform to present and anticipated future laws and regulations - and to continue to render service on askarel-filled apparatus. If you are contacted by customers or sales and 1t appears that the service required 1s contrary to this policy, contact the Divisions Marketing Manager or Engineering Manager at Greentree for a review of the services requested and recommendations on procedures to be followed. A. Do not accept orders for handling askarel In the field. This Includes additions or extractions of the fluid, Including sampling. Customers should be requested to take their own samples. B. Askarel-filled equipment will only be accepted for 1n-p1ant repairs at the following eight (8).plants: Philadelphia Birmingham Houston Chicago Phoenix Emeryville Glassport Portland C. Stock Askarel -- Only the eight (8) plants listed above are authorized to hold askarel on their premises. Storage facilities at these plants are to be 1n specially selected facilities with sealed floors. Curbing Is to surround the storage area. Records are to be kept of Incoming and outgoing shipments and scrap disposal. II. Instructions on disposition and control of askarel have been 1n effect for several years. Specific Information 1s contained 1n (W) "Instructions for Handling Inerteen Insulating Fluid P.D.S. 54201 CM and Installation and Maintenance of Inerteen Transformers" issued 1n 1971 and revised June, 1976. A copy is enclosed following this page. NPC00026313 753650 - STORAGE FACILITIES PROCEDURES FOR REMOVING OR REDUCING PCB CONTENT IN OIL STORAGE FACILITIES Purpose To reduce the PCB level in all new and used oil handling facilities to an acceptable level. At this time, the objective 1s a level no greater than 10 ppm with the ultimate goal being "undetectable" PCB content. Scope The work includes the removal and disposition of oil presently stored or Its dilution with new "clean" oil, whichever Is necessary to achieve a PC8 content no greater than 10 ppm. Procedures Due to the nature and physical location of many storage tanks and their Individual PCB content, no one procedure 1s suited to all of them. In some Instances, It will be necessary to dispose of large volumes of oil and may require the contracting for outside services for cleanup. Others with relatively low PCB content and small volumes may be diluted with an abundance of new, clean oil to levels lower than 10 ppm. 1. (a) Pump out and dispose of all oil containing PCB where - (1) ppm level and total volume of new oil prevents reduction to below 10 ppm by dilution with new, clean oil; (2) used oil, not included asastock material, exceeds 10 ppm (1t's not wise to Invest 1n new 611 to dilute used oil); (3) scrap oil exceeds 10 ppm. NPC00026314 753651 m 2 For identification purposes, we identify new oil tanks as "A" tanks; used, clean, reusable oil tanks as "BH ; scrap oil tanks as "C"; fuel oil tanks as "D". Other tanks can be designated as "E". (b) Each plant facility will be reviewed separately. Based on the PCB content, decisions should be made on the desirability of reducing the ppm of PCB by dilution before resorting to disposing of the liquid by scrapping. This means that no oil will be placed 1n a "Cn tank for scrap until other, more economically acceptable means of sale or disposition have been Investigated. 2. Tanks having had high PCB levels and with manholes. (a) Gain access to tanks when possible. Wipe out any remaining oil. (b) Wash down walls of tanks with spray nozzles and squeeges using new oil or mineral spirits as a cleaner. Operators must wear protective clothing and use approved air line breathing apparatus. (c) Depending on complexity of piping to each tank, It may be necessary to pressurize with air to remove all oil. The piping 1s disconnected from the tank and a circulating loop formed by connecting hoses 1n and out from the tanker. The lines are filled with oil and flushed by circulation. This procedure Is repeated with new oil several times. Each cycle should last about 10 minutes or more. 011 from each cycle 1s scrapped with contaminated waste oil. NPC00026315 753652 3 (d) When tanks and lines have been cleaned and emptied of oil, new oil is. pumped through the lines in the same manner as the flushing oil. This oil is also scrapped as 1t will have picked up residual oil. (e) Filters, check.valve clappers, and other Items should be removed from the system prior to flushing. These Items should be cleaned 1n new oil several times, dried, and reinstalled. New filters are Installed and the piping reconnected. (f) Future quantities of assumed clean oil and/or scrap oil 1s pumped Into the respective tanks only after 1t 1s determined to be free of PCB. Tanks having had high PCB levels but without manholes and/or burled underground. (a) Services of outside contractors should be sought to determine feasibility of cleaning with a spray nozzle probe or lance that could be Introduced through a vent or filled pipe opening. Spraying new, clean oil under high pressure will suffice to flush the walls of the tank. The accumulation of material at the bottom 1s pumped out and scrapped. Repeating the procedure several times may.be sufficient to reduce the PCB to a very low level. The lower the residual volume in the tank after pumping ceases, the more satisfactory the PCB level will be once the tank 1s refilled with clean, new oil. i NPC00026316 753653 4 (b) The piping and valves associated with burled tanks are cleaned and flushed as 1n the applicable paragraphs under 2 above. 4. All apparatus such as pumps, hoses, filters, filter presses, pans, drums, etc., known to be contaminated (by reason of their use with material in contaminated tanks), 1s either (a) disposed of as contaminated solid waste, or (b) thoroughly cleaned 1n an approved manner. NPC00026317 753654 PRECAUTIONS TO PREVENT CONTAMINATION OF CLEAN OIL HANDLING & STORAGE FACILITIES I. Oil or Askarel Handling Equipment 1. All pumps, filters, and hoses used for askarel are to be clearly marked and only used for askarel (for the eight designated askarel plants). 2. All oil handling equipment 1s to be checked for contamination. If contamination 1s found, it will be cleaned and flushed according to recomnended procedures. II. Storage Tanks & Piping Systems 1. All new and used oil tanks {"A" & "B") containing oil above 10 ppm will be considered as containing unsatisfactory material. It shall be disposed of as scrap material or diluted according to existing procedures and regulations to achieve a maximum level of 10 ppm. This level Is subject to constant review and may be.lowered 1n the future. 2. AIT new and used oil tanks ("An & "B") containing oil less than 10 ppm may be used, but It Is recoimtended that "An .tanks not be filled with new oil until bare minimum levels are reached. Eventually the oil in Inventory should be clean or at very low ppm levels. Used oil should not be put Into "B" tanks when higher than 10 ppm of PCB. 3. All tanks and piping under Items 1 and 2 above will be flushed and cleaned following recomnended procedures. At the end of the cleaning, a sample a shall be checked for verification of cleanliness. NPC00026318 753655 2 4. All scrap oil tanks ("C") must be repeatedly tested and those containing material above 10 ppm will be considered unusable and shall be disposed of according to existing procedures and regulations. If less than 10 ppm, it may be disposed of in normal manner. i 5. Based on the number of tanks at any location, various means for storage separation may be used. It is our objective to eventually reach and maintain i a condition where all oil stored for use is "clean" oil. ] 6. A sample will be taken from each compartment of the tanker on incoming i I shipments of new bulk oil. The sample should be analyzed for PCB content. ji If possible, the incoming oil should be stored 1n a separate tank until ! the analysis is determined to be free of PCB. : -5 i 4 NPC00026319 753656 REPAIR PROCEDURES FOR OIL-FILLED APPARATUS Samples of oil will be taken from all units received. Samples are to be taken from T. C. compartments as well as main tanks. When a unit is received, less oil) obtain samples from residual material available at bottom. Minimum amount for a test 1s 4 ounces. This requirement applies to oil-filled breakers or other devices containing transformer oil as well. It 1s our policy that no work be done on any unit until test results are known. If possible to obtain samples 1n advance, waiting time could be reduced. In emergency situations work may be started by considering the o1T contains PCB. Any oil removed under these conditions should not be placed In plant storage tanks. All solid materials removed from the unit must be handled as outlined under contaminated transformer repair procedures until test results are known. Procedures when 011 Tests show PCB Content above 10 ppm The customer will be advised of the test results and of our policy to consider oil over 10 ppm as normally unacceptable. He should be advised that we have the following to offer: 1. We proceed to repair the transformer as required and return as a unit containing some PCB 1n oil. Under such conditions, we will advise the customer of our final test showing ppm for PCB content. NPC00026320 753657 2 2. If the unit is to be completely rewound, our opinion at this time Indicates we may be able to sufficiently clean the reusable parts, and by refilling with clean oil, reduce the PCB content to approximately 10 ppm. At this time, we can give no assurance that this result will be obtained or that the customer's unit will not be considered a PCB ii product. Until we have proven techniques, this can be offered only on a best effort basis -- no warrantee to eliminate PCB 1s implied There are currently no restrictions on owning or operating a transformer, considered a closed system, containing PCB or oil containing PCB. The only requirement 1$ that the maintenance or ultimate disposition of the unit must be 1n accordance with regulations for handling and disposal of PCB. In addition, several jurisdictions may require labeling, record keeping* and reports. There are economic considerations to be evaluated concerning these procedures: 1. Repair procedures must be monitored and controlled to avoid contaminating any "clean** units being repaired. All rags, sawdust, and waste material must be scrapped and become part of the total PCB containing material disposition. 2. 011 used for processing or for final test must now be considered as containing PCB. It would obviously be desirable to use customer's oil or leave the oil used for test 1n the unit. 1 3. The expense to restore the facility to a "clean" status, if necessary i j to do so, should be evaluated. This would Include the dry out equipment, ] pumps, hoses, tanks, vacuum system, and oil handling equipment. I i -1 i NPC00026321 753658 EXHIBIT "fl1 Review of State Laws INDIANA Section 3 (a) A person shall not sell or manufacture for sale In Indiana the compound PCB. (b) Effective July 1, 1977 - A person may not sell a product 1f 1t contains concentrations of PCB's greater than 250.000 ppm. <c) Effective January 1, 1978 - A person may not'sell a product 1f It contains concentrations of PCB's of 1.000 ppm or more. (d) Effective January 1, 1979 - A person may not sell a product If it contains concentrations of 100 ppm or more of PCB's except: (1) The Board may determine a lower concentration for a particular product or, (2) If a Federal concentration 1s lower than Federal concentration will control. (e) Notwithstanding Paragraphs a - d, a person may sell PCB's or a product which contains PCB's If it 1s to be used 1n a closed system as a dielectric pursuant to rules promulgated by the Board to Insure the public health, safety; and welfare. (f) An exemption may be obtained notwithstanding Paragraphs a - d 1n accordance with the provisions of Section 4. Section 5 Effective July 1, 1977 - A person shall not use an Item, product, or material In the state which contains a concentration of 100 ppm or more of PCB's unless: (1) He files a written notice of Intention to use and, (2) He files an annual report detailing the total amount of PCB used. ** Covers only newly enacted State legislation specifically on PCB's. NOTE: General legislation covering disposition of "hazardous" mat e w B exists in almost every .state and has been Interpreted to aoTy to PCB's by some states. NPC00026322 753659 Section 6 Section 7 Effective July 1 1977 - Products which contain concentrations of 100 ppm or more of PCB's must be labeled. Effective July 1, 1977 - A person shall not dispose of PCB's or products which contain PCB's 1n concentrations of 100 ppm or more except in conformance with rules to be established by the Board. MICHIGAN Section 3 (a) A person may not sell or manufacture for sale 1n Michigan the compound PCS. (b) Effective July 1, 1976 - A person may not sell a product If It contains concentrations of PCB's greater than 250,000 ppm. (c) Effective January 1, 1977 - A person may not sell a product if It contains concentrations of PCB's of. 1,000 ppm or more. (d) Effective January 1, 1978 - A person may not sell a product If It contains concentrations of 100 ppm or more of PCB's except: (1) The Board may determine a lower concentration for a particular product or, (2} If a Federal concentration 1s lower,then Federal concentration will control (e) Notwithstanding Paragraphs 1 - 4, a person may sell PCB's or a product which contains PCB's If 1t is to be used In a closed system as a dielectric pursuant to rules promulgated by the Board to Insure the public health, safety, and welfare. (f) An exemption may be obtained notwithstanding Section 1 - 4 in accordance with the provisions of Section 4. Section 5 The Board after hearing may provide for coverage of additional similar compounds. Section 6 Effective July 1, 1976 - A person nwy not use an Item or product with a concentration of PCB's of 100 ppm or more unless: (a) He files a notice of Intent to use and, (b) He files an annual report of PCB used. In accordance with the Constitution of Michigan, an act does not become effective until ninety (90) days after the end of the Legislative Session unless the Legis lature specifically provides that the Act Is of Insediate Importance. Since this provision was not complied with In the Michigan PCB legislation, this legislation doesjnot become effective until April 1, 1977; Af PC00026323 753660 Section 7 Section 8 Effective July 1. 1976 - A person may not manufacture or sell a product which contains a concentration of 100 ppm or more PCB's unless the product 1s labeled as containing PCB's with such other Information as may be required by rule of the Board. In addition, the manufacturer must file a notice of Intent to sell and file an annual report. Effective July 1, 1976 - A person shall not dispose of solid or liquid waste from the use of PCB or a product or material which contains or has contained a concentration of 100 ppm or more of PCB except 1n conformance with rules promulgated by the Board. MINNESOTA Section 2 (a) Effective January l v 1978 - No person shall use sell, purchase, or manufacture PCB or products containing PCB without an exenptlon certificate. If there 1s no reasonable alternative or substitute for the PCB that Is reasonably available, the director may grant the certificate of exemption. Cb) Effective January 1, 1977 - No person shall add to a product or material the compound PCB unless the product 1s consplcuousl labeled as containing PCB. (c) Rules for exemptions are to be promulgated for July 1, 1977. CONNECTICUT Section 2 (a) Effective July 1, 1976 - No person shall manufacture the compound PC8 and no person shall sell the compound PCB without registration with the director. (b) Effective July 1, 1977 - No person shall use the compound PCB In the manufacture of a product or offer for sale a product with the compound PCB except 1n accordance with Section 3. Section 3 (a) A product or material containing the compound PCB may be manufactured for sale, sold for use, or used If the compound PCB 1s In a closed system and labeled 1n accordance with the American National Standards Institute standards. (b) A product may be sold 1n the state If the concentrations of PCB's 1n It are only Incidental amounts and 1f they were not the result of exposure to the compound PCB without taking reasonable measures to prevent contamination -- NPC00026324 753661 -4- (c) Additional exemptions for other products may be granted in accordance with Section 4. Section 5 No person or municipality shall dispose of the compound PCB or any item, product, or material containing PCB unless such disposal is in accordance with a properly issued permit. In addition to the above enacted laws, the states of Illinois and New York have pending Bills which would limit or control the use of PCB's in those states. NPC00026325 753662