Document 4aOx0YJJNjvz12Q0oKvmYykQa

'I! THE PCB-POLLUTION PROBLEM January 21 and 22, 1970 St, Loula Meeting With Oeneral Eleotrlo Co. GENERAL ELECTRIC REPRESENTATIVES: Mr. Edward L. Raab, OE Pittsfield, Maes,, representing all OB locations Mr. H. Oerade, OE toxlcologloal consultant Dr. K. Murphy, OB Seheneotady, New York, Environmental Pollution Control brt-lh fop J". _ rhQ. MONSANTO REPRESENTATIVES: H. S. Bergen, D. A. Olson, B. P. Wheeler, Dr. W. R. Richard, Dr. R. H. Munch, Dr. R. Keller, Dr. S. Tucker, W. B. Papageorge, J, 0. Bryant, P. 0. Benlgnus 1 A. Presentation and Dlsousalon of Published Articles About Chlorinated | Aromatio Hydrooaroon insecticides, (Dpi? etc,) and pCBs ' '. ! Mr. Wheeler presented to Mr. Raab a booklet containing most of the pertinent publications, to date, and Indicated that additional articles will appear shortly. ; He mentioned that manufacturers of DDT and chlorinated aromatic i hydrocarbon insecticides will tend to emphasize the finding and l Interference of PCBb as the Oovernment hearings limiting or : banning use of the insecticides are held. This lead QE to seek understanding of the scope, reproducibility, | reliability and validity of the analytical procedures used by ; various Investigators who reported finding PCB in concentrations ' as low as parts per billion. B. The Analytical Procedures Drs. Keller and Tucker presented details of Monsanto's OLC - Mass Speotrometrlc analytical capability and apparatus, as portrayed In Table 1, The sophistication of our analytical capability was emphasized to assure that our approaoh Is the ultimate and Is not surpassed. On this basis our views of the validity of results given In various publications are Indicated In the attachments to Table 1. Oeneral Eleotrlo were Impressed and completely satisfied with the Boope of our analytical capability and work. MQNS 031407 -2- C. Blodegradeablllty of PCBs Mr, Wheeler related that while Aroolor 1254 and 1260 are being found, especially In aquatlo environment, the lower ohlorlnated biphenyls are not being observed. It Is anticipated that the lower ohlorlnated members may be largely blodegradeable. Drs. Richard, Keller and Tuoker discussed blodegradeablllty studies by Monsanto at Ruabon and elsewhere. These studies appear preliminary and not conclusive. Much more needs to be done In this area to allow CE to draw oonoluslons. Since the literature Indicates that trichlorobenzene and trltetrachlorobenzene are not susoeptlble to biodegradation, OS are Intrigued with the absence of reports about finding these materials In the environment,. The obvious Implication Is that slnoe these materials are used with the higher ohlorlnated PCBs found -r the souroe of the latter Is not from dieleetrio fluids. However, It was reasoned that ohlorobenzenes may not remain due to their relatively higher vapor pressure or may not be found to date because they have not yet been zeroed In to the analytical speotrum. D. Status of Aroolor Studies At Industrial Bio-Test. Table 2. In essenoe results reported by Mr. Wheeler on ohronlo animal toxlolty tests and animal reproduolblllty studies underway are not as favorable as we had hoped or anticipated. Particularly alarming is evidence of effect on hatehability and production of thin egg Bhells regards white leghorn ohlokens. The studies involved Aroolor 1242, 1254 and 1260. Some of the studies will be repeated to arrive at better conclusions. B. The location of Askarel Transformers. Table 3. Messrs. Raab and Benlgnus formulated Table 3 to portray the use and locations of askarel transformers throughout Industry and our commercial and residential areas. On dlsousslng these askarel transformer applications Mr. Raab was most Impelling and forceful about the non-replaoeablllty of transformer askarel fluid and the orltioal or essential use and need for askarel transformers, whloh have safety from fire as their outstanding virtue. Without dwelling on details and Instead oarrled to the ultimate, the concensus is that without availability of askarel transformers large oltles like New York would be shut down with no power. Certain industries that rely mainly on askarel transformers would go down with no power. Without Aroolor oapaoltors most of the lightB aoross our oountry would go out and motors In air conditioners and many Industrial applications would not run. HONS 031408 -3 Frankly, no one oould think of a suitable replacement for transformer askarel fluid. Fortunately, Aroolor 1242 with promise about blodegradeablllty Is used In most all of the . Aroolor type oapaoltors. Moreover, possible favorable Isomer rearrangements are foreseen In the ease of Aroolor 1242. Need to oontrol, aooumulate and properly dispose of scrap askarels Is unquestionable in light of the PCB pollution problem, and essential toward maintaining the use of askarel dleleotrlos. At OS alone apparatus In which askarel fluid Is used represents 100 million dollars annually. About 60# Is In the oapaoltor area and 40# represents transformers. OB requested and we were pleased to give Dr. Murphy their. Environmental Control man, a list of all OE and other looatlons receiving Pyranol shipments In 1969. This amounts to about 16 million pounds of askarel fluids with eoonomlc worth of near 2.5 million dollars. This listing lnoluded 244 different looatlons of which 115 were OE plants and servloe shops scattered throughout our oountry. Of oourse In addition to dlelectrio use In hermetically sealed oapaoltors and transformers major amounts of PCBs are used as Plasticizers, Industrial Hydraulio Fluids and Heat-Transfer media. F. Environmental Souroes of PCBs From Dlelectrio Applications 1. Spills 2. Disposal of waste 3. Ultimate disposal of produot -- for failed apparatus 4. Ventilation of operation for employe protection 5. Waste from containers 6. Field on service failures 7. Repair and return apparatus "service shops" 0. Considerations of Degradation Disposals 1. PCBs up to and Including 3 ohlorlne atoms appear blodegradeable In preliminary laboratory work. 2. Thus far there is no evldenoe that higher chlorinated biphenyls will biodegrade. MONS 031409 3. According to the literature TCB and TTCB biodegrade at a very alow rate. 4. Chemical, catalytic breakdown would probably require high temperatures. 5. Incineration will require 800#C. and 5 second sojourn time. HC1 scrubbing would be required. Estimated Annual Amounts of Contaminated and Scrap PCBs Prom The gleccnoal Industry c" 1, Prom The Transformer Industry: a) In plant and field spills are small and controllable with adsorbents, which should be inoinerated. b) Near 2 million pounds a year of transformer askarels are sold to service and repair shops. These people do not manufacture new transformers, although on oooaslon they may fill new transformers sent Into the field without fluid. As these service shops are devoted primarily to repairing faulty transformers, we oan assume that as muoh as 1.0 million pounds annually of "sorapn Is generated. Most of this has been dumped or disposed of in streams. o) We estimate that probably 130,000 pounds of this Is arced beyond reworking and needs to be Incinerated. The remainder may be reworkable by distillation. 2. Prom The Capaoltor Industry; a) Collectable waste from normal oapaoltor impregnation operations amounts to about 830,000 pounds annually. Most of this should be reworkable via simple take-over distillation. b) Scrap, badly contaminated with polypropylene, epoxides, solvents, oil, grease and "Junk" Is generated at not over 50,000 pounds a year. This material should be Inoinerated, along with the 150,000 pounds of sorap from transformers. o) Power capacitors are designed to last over 30 yeara. Modern motor runs may last 10 years and the small lighting ballast usually last not over 10 years. Eventually and cumulatively there Is a large potential of field-failed oapaoltors. Portunately Aroolor 1242 has been used almost exclusively since about 1950. HONS 031410 -5- The failed units are disposed of In Industrial dumps. In oase of ballasts the Aroolor oapaoltor along with the transformer imbedded In asphalt or encapsulated In epoxy resin, all encased In a metal box are dlsoarded as a unit. This Is emphasized to Indicate that lnolneratlon of such apparatus Is not applicable. 3. From Containers! Most askarel moves In bulk, tank oars or tank wagons, which do not present a problem. > It Is questionable that drum shipments may present a problem. The drums can be used for returning scrap. I. Monsanto's Program To Handle Scrap 1. OK asked what is Monsanto's plan about reclamation of sorap PCB from OB plants, service shops, utilities. Industrial users, oontmeroial users, etc.? 2. What Is our view about a "Buy-Back" arrangement? 3. What arrangements will Monsanto make for lnolneratlon? Disposal In suitable land-fills? Reclamation by distillation at Monsanto? ^ M. To date Monsanto's posture Is: a) We have taken "good quality" sorap from OS's oapaoltor plant at Hudson Falls and had It reworked by simple filtration at Findett. This Flndett arrangement Is not praotloal nor eoonomloal. We paid OE 1 4/lb. for this "quite good" Aroolor, plus 1.9 4/lb. freight. Flndett oharged 2.1 4 to filter this material, making our cost 5 4/ib. b) 130,000 pounds of somewhat lower quality sorap from Vestlnghouse oapaoltor plant has accumulated at Flndett for laok of distillation equipment. 0) Sorap from OK's Ft. Edward plant appears to need reprooesslng by distillation. d) About i million pounds of "bad scrap" from OB Hudson Falls, has been disposed to a land-fill In New Jersey. Monsanto paid half of the freight oost. e) A car load of sorap transformer askarel from Westlnghouse, South Boston, Virginia Is being sent to W. 0. Krummrloh for reprooesslng. MONS 031411 -6 - f) We advised Westlnghouse, Sharon to incinerate 12,000 gallons of oil contaminated askarel. g) We talked with Sangamo, Picken, S. C. and strongly urged them to discontinue present disposal, 5. The above "take-baok" arrangements have been made on an individual and experimental basis. We have no fixed "buy back" arrangement, regards answering OK's question, 6, We have no established prooess for reclaiming either oapaoitor or transformer scrap, 7. We have no inoinerator for disposal of totally unreclaimable material, 8, To date and for the foreseeable future our only effective disposal is to a land-fill. While this Is not deslreable, . it is better than indiscriminate dumping. 3, Transformer Askarel Blends Discussed With QB, Table 4, Table 4 lists the transformer askarel blends reviewed with OS, 1. OS Rome has discontinued use of Blend A due to combustibility of aro formed gas, For this same reason, as diotated by their legal people they will not use Blend B. 2. Today both OB, Pittsfield, Mass, and Rome, Oa. use Blend C (Pyranol A13B3B), which they mix themselves. 3. Blend D optimizes the Aroelor concentration in oonformanoe with OS's requirements for non-combustibility of the arc formed gas and with the pour point requirements. The price is in dlreot conformance with our previous quotation for Aroolor 1242, when as was using this at a concentration of 80 by weight. HONS 031412 -7 - Accordingly Blend D meets OE's requirements, although containing 71.6# of the higher chlorinated Aroclor it does not conform with Monsanto's concern with the PCB pollution problem, 4. For all practical purposes Blend B (Inerteen 70-30) is identical properties with Blend D, which latter OK, Rome, Oa. proposes to use. In the interest of standardization, we seek to have OE, at Pittsfield and Rome, oa. use Blend E, which Is used by Westinghouse for low temperature applications and is used by many other askarel transformer manufacturers for general application, 5, Although Westinghouse USA uses Blend F (100# Aroolor 1242) for all applications, except for low-temperature application, OE does not aooept this use of 100# Aroclor 1242 in transformers, . OE'will not aocept Aroclor 1242 or any other blend with less than a 1 to 1 ratio of chlorine to Hydrogen atoms, A ratio signifioantly lower than 1 to 1 tends to yield combustible aro-formed gasses. OE feels strongly that this does not conform with the original definition of an askarel. Accordingly their legal people stress that this presents potential liability in case of an accident for which various precedents have already been set in court actions. Mr. Raab points out that this precedent for liability regards combustibility is already set, in oontrast with the PCB pollution situation which thus far is void of legal actions. He reiterated that the pollution problem thus far is a source of technical publications and warnings and emphasized that in the case of eleotrlcal applications which involve only hermetically sealed apparatus, adequate control should be possible. K. Facts As Agreed By Those In Attendance 1. CI5 - C6-8 Biphenyls -- found in aquatic eoo system in populated and industrial areas. 2. DDT + Cl hydrocarbon insecticides have effect on fish-eating birds (reproduction) leading to possible extinction of some species, 3. PCBs (some) are definitely suspected along with polyohlorinated hydrocarbon lnseotlcldes. 4. Research data being developed seems to oonflrm incrimination of PCBs subject to rechecking. 5. Public, political and government pressures stopping some uses of chlorinated hydrocarbon insecticides (PCHI). HONS 031413 - 8- 6. PCBs have been brought into hearings proposing restrictions or elimination of DDT, PCHI. 7. As manufacturer of PCHI's fight for their life, attention will be directed to PCBs. 8. To our knowledge PCBs are not being found In terrestrial birds or animals, but DDT and PCHI's are found, 9. PCBs are not being found In the eco system without the presence of DDT or PCHI's, 10. PCHI's residue are found without PCBs, 11. We have no evidence that anyone has found lower PCBs exoept that Dutch researchers found PCBs In roaches, IP. There Is no evidence of natural sources of PCBs nor any source other than Industrially produced and used. 13. PCBb in a single dose have a low order of acute toxicity and are no significant problem to rats, dogs, chlokens, fish And humans. 14. Based on six months of chronic studies in rats and dogs some PCBs are "moderately" toxic and more so than DDT, but less toxic than some of the other chlorinated hydrocarbon insecticides, 15. Some PCBs affeot rat reproduction, (10 ppm. apparent no effect levels), 16. Some PCBs affeot leghorn ohloken reproduction (100 ppm.). PCBs have no affect level for chickens, estimated 10 ppm. 17. Some environmentalists are claiming that the PCBs pose a threat to humans, are so "philosophizing" In publications. 18. One published page Indicates that PCBs are as bad (or worse) than DDT in microsomal enzyme effeot. What is significant? Sinoe many chemical compounds react similarly.' 19. Human experience In production of PCBs and their use has been favorable. Less than 20 Instances of Illness known to Monsanto Company sinoe 1940-45, Proper precautions were not always followed. 20. OE Company's use of PCBs as dlelectrlo fluids, has been extremely favorable without illness throughout 40 years. 21. Monsanto Company Is convinced that analytical teohnlqueB and data from Borne laboratories investigating PCBs are reliable and that conclusions being formulated are valid. MQNS 031414 -9 - 22. Monsanto Company has not run duplleate analysis on samplas reported In the literature. L. What QB Desires 1. OK seeks that Monsanto take no preoipitous reaotlon to the PCB problem that would result In withdrawing supply of Aroolor 1254 or 1260 to OB. 2. The oonsensus Is that no suitable replacement for transformer askarel fluid Is foreseen. 3. In event of development of a suitable fire-resistant fluid replacement for askarel, Mr. Raab emphasized that a minimum of 2 years testing work would be required before commercial use oould be adopted. ' 4. In reply to Monsanto's legal question whether with continued use of Aroclor 1254 and 1260 OB would assume sole and complete liability -- Mr. Raab answered, NoJ To substantiate his reply, Mr. Raab cited case examples Involving OB where damages were sought and collected, even though OB was only the third party. He further stated that any arrangement seeking to delegate and oonflne liability to OS relative to the PCB problem would be worthless. 5. OB seeks to know the magnitude and time of Aroolor prloe Increase that would result if Monsanto discontinues sale of Aroolor for non-electrloal uses, or If pollution oontrol expenses warrant a price increase (as anticipated). 6. CB seeks to send a letter to their plants and service shops and major users of transformer askarel, suoh as the utilities giving notice of the PCB problem and guidance about the most suitable controls. 7. In the case of OB servloe shops scattered throughout our country it Is unrealistic that these people would assume any expense to return scrap to Monsanto. The minimum we oan expeot Is that Monsanto pay the freight oharges, and reimburse for a suitable container to avoid additional and excessive contamination. This emphasizes need for Monsanto to have an effective reclaiming process. Otherwise, the best we oan expeot from service shops and many other users is to oontlnue to dump In a land-fill and stop discarding Into the sewers. MQNS 031*15 10 8. OE realizes that Monsanto is oaught between the explosiveness of arc-formed gasses problem and on the other hand the PCB pollution problem. Realizing possible unfavorable outoome of the arc-formed gas problem, OE desires to withhold the PCB problem from involvement at NEMA, ASTM, IEEE, EBI and ASIA at this time, (making It an Industry-wide problem) pending better ln-depth understanding of the PCB problem. 9. OE strongly seeks to continue manufacture of askarel type transformers, beoause In many applications this apparatus cannot be replaoed with mineral oil nor open dry, nor seal gas dry type units. Mineral oil burns. Open dry accumulates dust, lint, moisture and oan then fall with explosion and burning. Sealed gas dry types are very expensive, space consuming and very difficult to maintain sealed. Transformer deBlgn and application is governed by National Rlectrlo code, by looal building oodes. Fire Underwriters, NEMA, IEEE, ASTM, IEC, ASA, Insurance companies and others, Beoause of the diversity of organizations Involved a directive to discontinue askarel transformer manufacture would assume highly complex proportions. P. 0. Benlgnus January 86, 1970 HONS 031<>lb