Document 4vv5X5v0vZL4D7VvbMdj3EVqN

\ t 25-12 electrical WORLD E.O.W. 34.500 Manufacturers______ Electrical industry self-polices PCB use The furor in (he local press all over the country about (lie inuoductioii of poly chlorinated biphenyls (PCBs) into the environment (primarily river* and lakes) by manufacturers of electrical equipment creates the impression (hat industry has callously disregarded (he environmental effects of PCBs. Further, ihe implication is ihut suppliers are blindly lighting to retain PCBs. Westinghnusc Electric Corp, in a presenta tion to stale and local officials at its Distribution Appuruius Div. in Bloomington. Ind. has effectively dis pelled thus aura of industrial arrogance. Reference to or assessment of `'PCBs" is an oversimplification. B.A. Kerns. Westinghouse manager of envi ronmental control, pointed out that there are actually 209 possible homo logs of PCBs-lhat is. 209 permutations of the number and placement of chlo rine atoms in ihe biphenyl molecule, of which three are shown in Fig I. PCBs used by the elecirical-distribuiion- cquipmeni industry since ihe iniroduclion of PCBs in 1929 are few. and have included Arocior 1260. 1254, 1242. and 1016. all made hu Mfinfl"1" -------The bask difference* in PCBs is the degree of chlorination, or the number of chlorine utoms m the molecule. For example: Arocior 1254 contains 54% of chlo rine by weight, and 77% of its poly chlorinated biphenyls have flve or more chlorine atoms. Arocior 1242 has 42% chlorine, but only 9% of iu molecules have five or more chlorine atoms. This is ihe fluid used in Westinghouse transformers. Arocior 1016 contains 41% chlo rine. and only l% of iu molecules of five or more chlorine atoms. This is the fluid used in Westinghouse capacitors. The level of chlorination apparently is the most significant factor in the rela tive biodegradability of PCBs-the rale of biodegradability decreasing as the number of chlorine atoms per biphenyl molecule increases. Analysis of PCBs that have been passed through activated sludge-such as found in sewage plants--hat shown that 15% of Arocior 1054 degrades in a 48-hr cycle with a semiconiinunus treatment method. 2S% of Arocior 1242 degrades in 48 hr. and 33% of Arocior 1016 degrades in the same period. Results of additional tests with Arocior 1016 showed that treat ment for 14 days reduces the various A PCB la a linhad pair of banzena mofacutas (Fig 1), in which two or mort hydrogen atoms have baan raplacad by chlorine atoms mixtures in 1016 by as much as 98%plus. These tests have led Westinghouse to the conclusion that Arocior 1016 is sufficiently biodegradable to remain in controlled usage. Kern said. Chromatographically derived data on degradation, plus the extreme difficulty experienced in developing analytical tools to correctly identify and quantify the mixtures of PCBs used within Westinghouse's own plants, led West inghouse to conclude that many of the agencies supervising PCB analyses are arriving at erroneous results. Kern de clared. For example, analytical data pro vided to Westinghouse by agencies in Indiana show amounts of Arocior 1016 in waters and in fish that, because of iu degradation, could not possibly be there. In addition, the analysis for PCBs in fish used the whole Ash. when only the edible portions are commonly analyzed. This, in itself, allows a correc tion factor of about 4:1 in the state's re sults. Fish found to contain (he highest lev els of PCBs were the bottom-dwelling scavengers, such as catfish, carp, and eel: game fish showed much lower lev els. Factually, in surveys carried out in Lake Michigan, ihe number of Ash lhat are found to contain PCBs actually de creased between 1973 and 1975. It la Ineongruoum, Kern feels, lhat PCB standards are being imposed on the basis supporting data that are de rived from an analytical technique that stretches technology to the limit, and arc subject to errors runging up to 50%. Fat thaw* raatdaa levelflow 29 ppm laM level tor rata passage of tana attar aapoaura In November 1975. at an Eimronmental Protection Administration con ference on PCBs in Chicago, manv pa pers were presented oa research studies made under EPA supervision and sup port. to determine the effixu of PCB* on fish and animals. Ii was unfortunate that pruetically ail experiments, ut that lime, were conducted using Arocior 1254. a material which has not been used-at least in Westinghouse trans formers--since 1968. btcamt of Hi non biodegradability and its possible de trimental effects on (he environment: and which has never been used m Westinghouse's Bloomington (Ind) capacitor plant. While a few screening studies were carried out by EPA on Arocior 1242. no studies on (he use of Arocior 1016 had been planned at (hat lime Most of the data reported at this meeting indicated that massive doses of PCBi-a type not even available for ihe last few yean was used in (he lest-had detrimental effects when given to rats and monkeys However, little work was carried out using realistic concentra tions as actually found in the environ ment. Overlooked too often, according to Kern, is the fact that residual PCB levels in the fat tissues of animals de crease rapidly following the cessation of exposure to PCBs (Fig 2). EPA is now carrying out studies on the effects of Arocior 1(1)6 and 1242. and data should be available within 12 18 months. Kern feels that these studies will show a dramatically reduced envi ronmental effect from these lower homolojts effects that will allow a M0NS 037283 timely and orderly conversion to other dielectric fluids and that will not cause severe penalties in safety and in energy use. By 1971, accumulated proof showed (hat uncontrolled industrial applications of PCBs were contaminating the envi. ronment. Consequently, according to R.E. Wills Jr. a Weitinghouse attorney, in the absence of federal and state ac tion. industry itself began to impose ap propriate restraints. Monsanto, for in stance, the single domestic supplier of PCBs, restricted sales to uses only in "closed-system" electrical applications such as capacitors. This voluntary effort in itself removed about 40% of the PCBs used in the US. Manufacturers also initiated specific controls. And, to strengthen and supple ment these, the electrical industry, through the National Electrical Manu facturers Assn (NEMA). began devel oping standards and guides to prevent the inadvertent introduction of PCBs into the environment. NEMA appro priately included all stages, from initial manufacture of PCBs to ultimate dis posal. This word resulted in an industry Of ficial Standard Proposal document, which was published Jan 25, 1973. Guidelines for plant housekeeping, bulk-fluid shipment, receiving and transfer, employee safety, control of wa ter effluent, labeling, and scrap-disposal procedures are covered by this proposal. The guide alio listed known facilities with the capability of safely incinerating PCBs, or of maintaining a regulated chemical and scientific landfill area. Further, the proposal recommended that only Aroclor 1016. a PCB with a low concentration of the higher chlori nated homologs, be used in capacitors. These guidelines were formally adopted in January 1974 by the Ameri can National Standards Institute (ANSI). On April 1, 1976, EPA pub lished a notice of recommended dis posal procedures that are substantially in accordance with the ANSI guidelines. EPA Nan atoo ettosuptud to develop regulations that would control the dis charge* of PCBs under the provision of Section 307(a) of the 1972 amendments to the Federal Water Pollution Control Act. Wills sees this method of control as proper because the forthcoming regu lations will then be based on complete scientific information, and will not sub ject industry to inconsistent or unrealis tic requirements. Thus, on Dec 27, 1973, EPA proposed effluent limitations for the control of PCBs. A major problem developed, however, during the course of the hearings on these proposals. Section 307(a) of the FWPCA re quired EPA to establish a scientific basis to justify the limits set In addition, ERA was constrained to consider the toxicity, the persistence, the biodegradabttity, the importance of affective organisms, and the effect of the pollutant on the or ganisms. Unfortunately, Wills explained. EPA failed lo recognize the eeeentiel differ ences in the various PCBs, and used data associated with the higher-chlori nated PCBs-and even some mixtures the electrical industry had not used for 10 yean. In fact. Wills declared. EPA said it did not have an adequate basis upon which to promulgate justifiable standards to carry out the purposes of Section 307(a). There wu almost no information submitted in the "Basis and Purpose" document that related lo Aroclor 1016, for instance, even though manufac turers of electrical capacitors had used this improved material for more than two yean. Thus, st the end of the hear ing and after expert witnesses from both sides had been examined, the proposed limitations were withdrawn. Later, dur ing subsequent litigation, officials of EPA stated that the record of the pro ceeding would not support their pro posed limitations. Thu Food A Drug AduriuMrattmi also took action in 1972 to limit the amount HONS 037284 of PCBs that may be. lawfully present in food, resulting from unintentional eon* taminaiton. The tolerances were estab lished in July 1973. This provided that the edible portion of Ash was limited to ' a concentration of S ppm. Based upon ! recent information, FDA is reviewing this tolerance limit; it published this de* ; cision on Feb 26, 1976. i However, FDA also stated, "Surveil! lance data gathered by FDA and the US I Dept of Agriculture subsequent to the ( effective dale of the temporary tolerf ances. . . have shown that, with the ex ception of certain freshwater fish, the | presence of PCBs in those foods subject ' to the tolerances continues to be spo- 'i radic, and that there has been an overall and substantial decline in frequency ! and levels. These data further show that | the average daily dietary intake of PCBs I is quite low and well within the margin ' of safely.'* j Michigan and Indiana have also taken ' action to eliminate PCBs from items, products, or materials used in these states. These laws will effectively limit PCB content over the next three yean through a sliding scale of prohibition. Nevertheless, both laws recognize that use of PCBs In the electrical equip* ment industry continues to be indispen* sable. Accordingly, an exemption was provided for their use in a closed sys tem, such as the dielectric fluid for an electrical transformer or capacitor. This exemption is to continue until it is documented that substitutes are avail able to meet performance standards and . environmental acceptance. Monsanto | meanwhile has publicly stated that they ! will cease the manufacture of PCBs as t' soon as there are adequate substitutes. Several alternative fluids have been > ; proposed by Monsanto, Dow Chemical, ^ | Genera) Electric, Sun Oil, Shizuki in Jaj pan, and others (EW, Jan 1, 1976, p 36). [ But the one key drawback is that not [ one of them is as nonflammable as i PCBs. | J.B. Brittain, manager of engineering f of Westinghouse's Distribution Appa: rittni ntw AllllinMl bam** nf th* <IIA. . ` .develop an alternative fluid, according to Brittain, which it decided to use if , PCBs were eliminated. But. after a full development program had been com: pleted and units had been actually built for customer Acid testing, Westinghouse j decided that, because of its high 1 flammability, workers should not be ex- posed to it At this point, $230,000 had > been invested in this veoture. I Another fluid, safer to handle but still with inferior flammability character* 1 istics to PCBs, is now being tested. Westinghouse is constructing capacitors using this fluid for field tests, as the cul mination of a $300,000 development pnrogeraem. I ^ | I ; j { i IWartt, imm IS MIS HONS Q17pun