Document 82YoJoNEmNZ7ed21Jyx2ZmVja

t POLICY FOP, THE USK AM) HAKS1I?:C OT IKEPTEEL' i NPC00026264 753601 1 . 7n t I Q-'..ic r i o n Page J II. Gcn'-v.il Safety Precautions--------- ----- ---- *--"" ------pagc 1 -/.. - Vapors......... ............. -..................-..... rnc 1 & 2 r. riuid....-......................... -............... rage 2 C. Eye Protection------ -------- ----------------- "------- Engc 2 6 3 D. Ingestion of IKERTELN---- -- -------------------------- Page 3 XII. Receiving And Storsge Of IKERTEEN*---- ------ ------ -------- Page 3 A. Tank Car....... -......... -- ----- ------ ----- -....... rage 3 B. Steel Drums and Cans---------------------------------- Page 3 -C,- Storage Tanks--- -------------------------------------- Page 3 6 A .... --- IV _PL*;tit-Manufacturltu? Arca-.---.r-." *-r " -_n_r-r-rr-inn- --rTage. A----------- A. INERTEEN Filling Area----............... -............. Page A B. Special Containers for ScrcpMaterial-------------------- Page 5 V. Conditjoninp of INERTRFM---------- ------ ------------------Page 5 A. IKERTEEN' Conditioning Equipment------------------- Page 5. B. Fullers1 Earth------- ----------------- Page 5 6 6 VI. Tcer-Pou-n Of IN'ERTEEN Units For Ronatr Or Scrap---- --- ---- Page 6 A. Tcnr-Down Procedure----------------- ------------------- Page 6 I VII. DnndHnr Of Emory Containers Contmiyioted U'lth TKnRTE?7------Png.c 6 A. Tank Cars------------------- ----- ----- --- ---------- Page 6 B. Drums-------------------------- -- ---- ---- ----- ---- Page 6 6 7 C. 5-GalIon Drums------------------------- ----- -- -------- Page 7 I D. Sample Bottles------ Page 7 VIII. Purrh.isrs cf TKERTEEN hv District Offices 6 Ronnir Shoos---- Page 7 A. District Offices--------------------------------------- Page7 6 8 B. Repair Shops........................................... Page*8 HPC00026265 753602 T O M C Y FOR THE USK AHT? liA'inij;::; OF IKKETEFtf I . Introduction IKEItTEEH is s synthetic transformer dielectric fluid made by the chlorination of a chemical, biphenyl, to give it non-fleasable ^properties. Since this process stabilises the fluid for transformer use, it also makes it difficult to destroy when it gets into the environment. Tests have been made throughout the world that show the undesirable nature of this type of fluid and its effect on some species of fish and birds. It has been shown that if IIISRTEEII is to continue to be used in transformers and capacitors, a positive effort must be made to control and prevent pollution by this product. IHEHTEEH can pet into the environment during the manufacture, delivery, improper use, maintenance, repair and disposal of trans formers and capacitors. Experience has shown that it is necessary to control all aspects of the manufacturing and fluid handling process with emphasis on the possibilities of leakages and spillages to prevent any HffiRTBEK from getting into the environment. Close attention to good plant housekeeping is the main key to pollution control. Care, must also be exercised to ensure that all test samples and IiJERfEEi; contaminated solvents are collected for disposal in an acceptable manner. Chemicals, such as IKERTEEii, are IIOT PERMITTED in any effluent from manufacturing plants. This is prohibited by the clean, stream . ' lavs. HJERTEEfl and IKERTEEU contaminated wastes have been shown not to be acceptable in sanitary land-fills. This then requires that these/'LL t& i>m wastes must be destroyed by incineration in a high temperature incinera tor ( F) equipped with a scrubber. >`* This problem is extremely serious as evidenced by the proposed federal legislation attempting to ban its use. By following acceptable procedures the problems of any pollution of the environment by IJJL'RTESII fror: our plunts can be controlled. IT. Genera] Kqfety Precautions 1NEUTEETJ vapor is non-toxic to humans^ except if taken internally', but care must be taken to avoid unnecessary contact with the licuid or vapors. * A. Vap1.or--s :v The odor o f IHERTEr: is n o tic e a b le v e i l below the maxi a cce p ta b le r. : r c o n c c n tru fic n ::. The ra x iru :- a t t io n lim it (cj hours) rec'-roanied i s one rr.ili i r:r:c, of I l*or cubic n o le r o f :*3r. f-J NPC00026266 753603 High concentrations of IIIERTEEK such a;; found inside r. trans former tank or tlie vapors from hot IliERI'EL must he avoided. The hit'll concentrations of vapors can cause irritation of the eyes, nose, throat and upper respiratory tract* If contact with high concentrations of INERTEE;; is necessary an approved gas mask or self-contained breathing apparatus must be vorn*. The vapors produced when ITiEPTEEK is decomposed by very high temperatures or from an, electric arc will consist mainly of hydrogen chloride. This vapor is very unpleasant and irritating, thus' giving ample warning of its presence. Under emergency conditions an approved gas mask or self-contained breathing: apparatus must be worn in order to enter a space containing, vapors of decomposed IKERTEEH. If irritating odors are detected with the breathing apparatus in use, the person should go immed iately into fresh air. All gas masks, respirators, replacement cartridges, and selfcontained breathing equipment must be Bureau of Mines approved and be maintained on a regular schedule, in accordance with the manufacturers recommendation. B. Fluid Unlike oil, INEKTEEN has virtually no fire hazard. However* IKERTEEN can be irritating to the skin. Some people are quite allergic to the solvent action of- INEKTEEIi on the skin. Both the liquid and vapor are irritating to the eyes. To prevent direct contact with the fluids approved aprons end. gloves should be worn, however, the regular use of gloves is net recccrccnded .since the gloves are easily contaminated on the inside with IKEHTESK from the hands. After handling INERTEEK the hands should be washed thoroughly with vara soapy water. In the case of splllege onto clothing, the clothing should be removed as soon as practical and laundered or discarded in containers designated as "Scrap Burnable IKERTEEH Waste". C. Pye Protection / IKZR1T.EK and its vapor are irritating to the eyes. Eye protection such as safety glasses with side shields or face shields must be vorn at all times when handling IKERTEEH. The use of medicinal washes or detergents on the skin followed by an application of skin crcnm vill eliminate any irritations resulting from INSRTEEii coming in contact with an open, cut or abrasion. Eye 0 7 *0:1 arc to liquid TKHKTHEK should be irrigated immediately with large quantities of v.vter from an approved eye .-'Vn- NPC00026267 753604 c .tin, ji-j;>un:> ... . -** .... . *"' XIXI'.TELK should bu o.av.incd by the company physician. D. Invest Ion cif 'TNT'RTnk*.1 IHF.RTEEM is redderntcly toxic if taken internally. Swallow!ng an ounce or more will cause irritation of the digestive tract and internal rracLicm, In r.uch eases the person should go to * the company physician inmed; nl cly. Any condition that might result in a possible Ingestion of lilEitTEEN should be avoided. III. R-eceivinr*1. And StoraMge1 Of I11K"i-mED"T". : I! IHEilTKEM is shipped from the manufacturer in tank cars, tan'; trucks, 55 gallon steel drums and in 5 gallon metal drums. All containers must be labeled as to contents and carry a precaution ary label in reference to ft.s.environmental hazard. Every container should be inspected for this labeling and leaks when received. . . Tank Car Receiving r . i^ u .*-'^A yrl \ \ A special receiving area nust be allocated to IUEETEEM tank cars. This area shall have provision for collecting reasonable amounts of 1NERTEE." i f tlie car is found to be leaking when re ceived. Any leek should be reported immediately to the Super intendent of Maintenance *for appropriate action. , .* . v. ; U;.- '*-,.# ., . Drain pans must be provided to prevent spillage from unloading hoses and connections. IKSF.TEEK tank cars do not have bottom unloading valve and must be pulped from the top n3n-hole opening. iI Benzene or other approved cleaning fluids used for cleaning the 4 sampling devices must be collected in a "Scrap INERTEEN" drum for 4 i disposition. After use the sampling device-shall be cleaned, . dried and stored in a suitable location. i I B. "Steel Drums and Cans ' I,.J. i. t... ' -- - * .r] ;f i. - On receipt all IXERTEEK drums and cans must'bc carefully inspected for leaks. The containers should be stored indoors in an area , .A.. especially selected for the purpose. A cement curb should en- *;*../ close the area to provide a basin fu;r containing the IMERTEEX ... from at least two drums should they be damaged. The area must not have a drain which is corniceted to a sanitary or storm .sewer. C. Storage Tanks -; M l 1KEKTCCN storage tanks should'be* erected on a cement base CO Hint inspection cun be made for leaks. A vail of cement must be erected around the tat:!: to provide c holding basin to cent ain all the jx::i;T;:::r: in ttie s m rage tank in the event of lank * Ini lure. The base and w.:i be ecu:.:ru__i^L_iii_i! i -3 .** r. i* ` C-* * NPC00026268 a 753605 real:: Hint expansion jnliis it' previni, n m >- .... A sump drain with pu::.p :.uuid be providr*', It* ietni''ve *iny u:::iu- lotion of surface water but muse not be lI'*1* ini*5 * coni tory or storm sower. The pu:np will'be manualJy activated when rcepiir cd. The sump pump ir.uct nlr.t* he of sufficient rapacity to pump the IlEUTEE from l)ic storage tank bac in into containers for sal vaging Lhe material or for scrapping in ease of n spill. All tanl; piping must be exposed to permit inspection for leaks. t i /.* Plant -Manufacturhr, Aren T'or F i l H m y Units With IWERTESK , , ;1 r j Z " : zrr~ ... , i t' 1-^ It is quite "probable that in filling equipment with IIJERTEEN and further handling o f tliic equipment that an JMERTEEN spill will occur. * Therefore it Is necessary to provide facilities and a pro- cedurc for clean-up to prevent contamination, i- . A ' * ^ A. TNETITEF.N F i D i n r Area >- T`; V 'il . t, < i. The location of the ZKHRTEEK filling area should be adjacent to the test area and final chipping area to minimize the danger of damage of units during handling. The manufacturing area provided for filling equipment with / f ^ INERTEEN shall have a cement floor with adequate cement ctirb^'/ l*"'_ around the entire area Lo act as a basin for containing the 1 volumu of IKEF.TEEN from the largest production unit. Floor drains must not be connected to a sanitary or storm sewer but to a sump provided with a manually activated pump, capable of pumping spilled 1XERTSEK or other liquids into "Scrap IKERTEES" drums. Adequate ventilation of the area shall be provided to maintain an atmospheric 1NEUTELN fume level below one milligram of lNERTUEN per cubic meter of air. The exhaust from vacuum pump and ventilation of the area shall be directed thru filters capable of removing 1NTKTEK valors. *. Drip pans shall be provided feir hose connections and filling valves. 1KERTEEK resistant aprons and gloves shall be available for, special operations in.which the personnel must come in contact with the INERTEEW Respirators, self-contained breathing apparatus, or gas-rr.ar*kn of a type approved by the bureau of Kincs*must be available for use by personnel in high air concentrations of ll.'ERTEEK, All manufacturing procedures loss ii l.'.'.'kTEI.W' te the cuvi rt be directed toward preventing mer.t. In nf_ ;.> I 7!M v' - A- i- fi* t NPC00026269 753606 1rrH.'tiioU'iy tu (.ai i}1 un. i.ii. j - i j. ^kii>'>` "i -- B. Snccinl ConNlntTs For .r.cr.in_M.itPi-l ais 1. Drums 1nhclcd "Scrap IJERTtEU" must be available for handling all spills and waste INERTES^ Iron the sump, failed units, drip pans, sample Jars etc, 2. Open-head drums with approved closure or other suitable con tainers labeled "Scrap Burnable Ik'ERTEEN Materials" must be available for handling scrap cellulose insulation, rags, paper pressboard, wood, sawdust, etc. 3. Separate containers for handling steel, copper, end aluminum, each adequately marked, shall be provided for the components of contaminated core and coil assemblies when tear downs are necessary, 4. Containers for supplies of saw-dust for absorbing small INERTEEN spills or clean-up must be provided. Speedy-dri or other clay absorbing materials arc not reconcnendsd. `i Conditioning INERTEEN* A. IKERTEEN Conditioning Equipment ; The conditioning equipment and intermediate storage tank should be located in the bulk storage area which is provided with an adequate curb to contain the INERTEEN held in the intermediate storage tank. Two alternate procedures are satisfactory. The conditioning equipment'and intermediate storage tank may be located in the manufacturing filling area since a curb is provided for con taining a spill. If the conditioning equipment and storage tank is located in other areas it must be placed on a cement floor with an adequate curb surrounding the equipment end tank to provide a holding basin for ail the INERTEEN in the intermedite storage tank in the event of a tank failure. A sump, not connect ed to a storm or sanltnry sewer', may be provided to clean the holding basin In case of a spill. An alternate would be separ te pumping equipment to pump the IKERTEEN spill into "Scrap IKERTEEN" drums for disposal. * . B. Fullers* Earth Conditioning of INERTEEN requires fullers' earth treatment. The spent fullers' earth in cartridges or bags when replaced shall be allowed to thoroughly drain over drip pans ro remove as much liquid IKERTEEN as possible. The cartridge units of steel mush \- 5 * i*.1V NPC00026270 753607 cr.t.nict.icin co n tain in n f u i ] f:r:; ' eurlh sha] 3 b'T' ii.*ri-T*jK*ti an the container:* .market!, '`Itec.l Co:!l.*.-"u.riatntJ v/jth IKEiTKKi- , l 'or tii:;p o s it io n . C lo th bar.r. f ille - .! v?ith spent f u i 1er." ' earth s h a ll be disposed o f in the co n ta in e rs marked "Gerap Burnable 1EREE V.:!ictc". Tiie fullers' earth in the condition inf, equipment shall be changed when necessary to r.uintain the IliEETEEIi within acceptable operating limits. VI. Tear-Down of IHERTEEn Units for Repair or Scrap A. Tcar-Dovn Procedure 1. Drain all the IKERTEEN fran the transformer or capacitor into the conditioning tank or into drums labeled "Scrap IERTEE;" depending upon the laboratory reports of the. condi tion of the IMERTSEK. Allow sufficient time for all the INERTEEE to drain from cores and coils (at least twelve hours) and again drain the IliERTEEN from the tank. 2. Remove the cores and/or coil assemblies from the tank and place them on a steel tear-dovm table having a raised edge to contain any run-off IHERTEEW from the assembly. A center or other properly located drain shall be provided in the steel table to collect the run-off IEERTEE. 3. The personnel that dismantle the unit must wear approved gloves, apron and eye protection. *\ (. Place all materials in the appropriate salvage containers during the tear-down for later disposition. 5- The tear-down table shall be cleaned with kerosene or other approved solvents after the dismantling operation. The used fluids shall he placed in the "Scrap IliERTZEIC'1 drums for dis position. VII. Handling of Empty Containers Contaninsfted with IKSRTSS3 A. Tank Cars *. When tank cars have been unloaded they will be rc-senled end returned to the manufacturers without further cleaning. These tank care arc used only for IKSRTSEIf shipments and the cleaning will be done by tbe supplier.. B. Drums Dnana which contained new i ;;kt.7 ;;j can be used f o r v a s te f l u i d s * V ." JT NPC00026271 753608 marked "Scrap i n e r t e .*:n.. . Drums /hicti must bo retired from use shall be washed twice with one gallon portions of kerosene, benzine, or other approved solvent before crushing, delivery to scrap dealers or used for other disposal. The wash fluid shall be disposed of in drums marked "Scrap INERTEEir1. C. 5-GalIon Drums 5-Gallon drums which contained new INEKTEEN when empty sl^all be washed twice with kerosene, benzine or other approved -Solvent before scrapping or re-using, The wash solvent shall be .placed in a "Scrap 1NERTEEN" drum. D. Sample Bottles Sample bottles and other small containers used for obtaining samples of -INEKTEEN for test from any source such as trans formers, storage tanks, filling lines etc. must, be rinsed at least twice with benzine or kerosene before re-use or scrapping. The rinse solvent shall be placed in a "Scrap INEKTEEN" drum. '. , V7TI. Purchases Of INEKTEEN By Manufacturing Divisions, 1I& R Plants And E & S Groups * '. No direct sales of any quantity of IKERTEER will be made to any customers nor will authorizations be issued to the Monsanto Company to ship IKERTEEN except to these locations manufacturing INEKTEEN equipment or M & R Plants and E G S Groups having repair or service orders for the direct use of .IKZRTEEK under th super vision of Kcstinghouse personnel. This is to eliminate, any possible chance, for INEKTEEN to be obtained for uses of any kind except in transformers or capacitors. * A. Manufacturing Plants *' * INERTEEN for use in manufactaring and filling new equipment will be ordered from the Monsanto Company as a stock material. Orders for INEKTEEN for make-up cr other purposes will be re ferred to the nearest M * P Plant or E & S Group depending on the need for the INERTEEN. B . District Offices Orders for INERTEEN will be referred to the nearest M G R Plant or E & S Group depending upon the need for the INEKTEEN and will be made a part o a service contract cm specific equipment. C. H l< r. F l a m s Orders for JKETJ.T.K for use in repairing equipment-ul-ll-- hc-iesuod NPC00026272 753609 on*j i.uij.l u.; u.mju t'n <-**; orders. All n p r . s h o p s prrlnr.ning service work on Ib'EK'J LEI.' irausforir'jrr, sM. ii.is.iiddeu mi are*! in Lhc repair shop Lo IKindle all lUiiRTEEN service work. This shop area must be filtered to provide the same safeguards ns established in the manuiactuviny locations including curbing around the area to contain an accidental spill, containers for holding material, contaminated with ll-iEKTEC!!, containers* for scrap IKEIITIXM and safety equipment for employees. All scrap materials must be disposed of at authorized locations that have incinerators capable of safely destroying the lKEKTEEN. Only the INERTl-EN contained in the equipment will be returned to the cus tomer. D. E & S Groups Service orders to maintain Ih'E&TEEt! equipment will be accepted and the necessary lEERTEEK will be ordered by the E & S group from Monsanto Co, for shipment to the E & S facilities. The required INEUTEEN will be taken to the customers premises and additions of make-up as other requirements supervised. An excess IttERTEEK will be returned to the E & 5 storage area APPROVED: APPROVED: March 16, 1972 ATPROVED: APPROVED: -li- Hi NPC00026273 753610 i l t t t n till! iM-.mn::: ninniilac luring :ccljou um. marked "Scrap 1i-EivTl.l.b1 lirlim;i wlijcl) mur.r be retired from use shall be washed twice wilh one gallon portions of kri u m m i c , be*n".pnaa ur other approved solvent .heroin crush fng, delivery to scrap <1o.ilers or used for oilier dis posal. The wash fluid s h a l l be disposed of in drum*! mar lied "Scrap IKEKTKKrr'. C. '.5-Gnllon Drums 5-Gnllon drums vhich contained new IKERTEEiC when empty shall be washed twice with kerosene,.benzene or other approved solvent before scrapping or re-usihg. The wash solvent shall be placed in a "Scrap IKERTEEN"* drum. . 1). Sample bottles - Sample bottles and other small containers used for obtaining samples of INERTEEK for test from any source such as trans formers, storage tanks, filling lines etc. must be rinsed*at leas*.* twice with benzene .or kerosene before re-use or scrapping. The rinse solvent shall be placed in a " Scrap. IKERTEEK" drum. VIII, Purchases of IXERTEEIT Bv District Offices and Repair Shoes It is necessary to police the sales of IXERTEEH to all users in oi-dcr to prevent the misuse of 1NERTEEN by those requiring this mater ial for equipment or applications* vhich are not closed systems thus : permitting environmental contamination with the XXSRTEEK. A. District Offices ,, All orders for IKSKTEEX must Be carefully surveyed in order to , establish the application for which material will be used. It Is . desirable, if at all possible, to obtain a service contract to handle the repair or maintenance of the customers1 transformer rather than supply the IKF.RTEEN. This insures direct control to prevent the pollution of the environment. For those customers willing to provide a service contract, it is important that the work is performed by personnel knowledgeable in the proper handling of INEKTEEU under the newly established guidelines. Orders for INEUTKI.K for Lhe service contracts shall be placed with Monsanto for delivery to the servicing group and not to the customer. In those eases in which Customers insist on performing their own . maintenance and repair work and in locations where service con- .^tracts ate impractical, orders for IKERTEEN will be accepted only `after the customer has established the need for .the .1NERTEEN and will provide signed doct.T!*.*nts indicating they.are fully aware of .the polychlorinated biph-. nyl problem, that they have established 7- * NPC00026274 753611 In no w t y will lml tl Li*c* Went inr,Htuac ElcctrLc Covpovai (on rer.pom.iltlc for liability rpMulLing from their use of the IKEKTECN. Orders then will be sent to.Monsanto for delivery to these customers. B. Repair Shons Ko order for IKERTEEM for delivery to any customers vIII be ac- * cepted by the repair shops. ... .. - r* *' . '.* a ; j -- -- `S-.. - `i * , , Orders for INERTEEN For service work performed in the repair shops or at customers'1 location vi.ll be directed to Monsanto for shipment of IKEKTEEK to the repair shop location only. All repair shops parforwing service work on INERTEEN trans formers must set aside an area in the repair shop to handle all INERTEEN service work. This shop area must be altered to pro vide the same safeguards as established in the manufacturing lo cations Including curbing around the area to contain an accidental spill, containers for holding materials contaminated'with INERTIEN, containers lor scrap XKERTEEN nnd safety equipment for employees. All scrap materials must be disposed of at authorized'locations that have incinerators capable of safely destroying the IKERTEEN. f * I_* A P P R O V E D _______________._________ APPROVED? APPROVED.* Ap p r o v e d ; ______ February A, 1972 0 - B' * ** 'A, * w m\* NPC00026275 753612 POLICY FOR THE USE AND HANDLING OF INERTEEN vwJ' Uk-*.x^ } "* /k (/^* \ A / W J ^.v - Jz-y.er-J /v U. ^ ..h POOR QUALITY ORIGINAL NPC00026276 753613 - CONTENTS - I. Introduction--- -- -- z z . Cenerai Safety Precautions- -Ar~Vapors-- TM -Page 1 -Page 1 -Page 1 -fit 2--- -- B. Fluid-- -- -- C, Eye Prdtection- -Page 2 I -Page 2 & 3 D. Ingestion of XNERTEEN- -Page 3 I H . "Receiving And Storage Of INERTEEN-- -Page 3 " A, Tank Car----- ----------- ..... -Page 3 B. Steel Drums and Cans--- -- -- - ------ C 5-- Storoge~Ttmlt6-- -- -- -- -- -- -- -Page 3 -Page-3 4 ---- t v , niant ^ianufnrttnrlnjy Ar "Page-4_____ ___ A. INERTEEN tilling Area--- -------------------------- -Page 4 B. Special Containers for Scrap Material-- --- --- -- -Page 5' V. Conditioning of INERTEEN------------- -- ----------- --- -Page 5 A. INERTEEN Conditioning Equipment-- -- -- -- --- -- B. Fullers* Earth--- -- *0 --- -- -- --- -- ---- --. VI. Tear-Down Of INERTEEN Units For Repair Or Scrap-- -- ** A. Tear-Down Procedure-- VII. Handling Of'Empty Containers Contaminated VIth INERTEEN. A. Tank Cars-- -- B. Druns-- -- -- C* 5-Gallon Drums-' -Page 5. -Page 5 & 6 -Page 6 -Page 6 * -Page 6 -Page 6 Page 6 & 7 Page 7 D. Samf la Bottles-* Page 7 Purchasa a(Jjf_INE^TEENJ>2_DlHStr^ct_iOffici6iS>>AJegairShogs-----Poge 7 A* Diet riet Offices* -Page 7 & 8 B. Repitr Shops* Page 8 NPC00026277 753614 POLICY FOR THE USE AND HANDLING OF TNERTEEN t " ' ~* I- Introduction INERTEEN is g synthetic transformer dielectric fluid made h y the chlorination of a chemical, biphenyl, to give it non-flammable .properties Since this process'stabilizes the fluid for transformer use, it also* makes it difficult to destroy when it gets into the environment. Tests have been made throughout the world that show the undesirable nature of this type of fluid and its effect on some species of fish and birds. It has been shown that if INERTEEN is to continue! to be used in transformers and capacitors, a positive effort must be made to control and prevent pollution by this product. INERTEEN can get into the environment during the manufacture, .delivery, improper use, maintenance, repair and disposal of trans formers and capacitors. Experience has shown that it is necessary to. control all aspects of the manufacturing and fluid handling process with emphasis on the possibilities of leakages end spillages to prevent any INERTEEN from getting Into the environment Close attention to good plant housekeeping is the main key to pollution control. Care must also he exercised to ensure that all test samples and INERTEEN contaminated solvents are collected for disposal in an acceptable manner. Chemicals, such as INERTEEN, are NOT PERMITTED in any effluent from manufacturing plants. This is prohibited by the clean stream qj laws. INERTEEN and INERTEEN contaminated wastes have been shown not to he acceptable in sanitary land-fills. This then requires that t h e s e ^ |i'^*i wastes must be destroyed by incineration in a high temperature incinera tor ( F) equipped with a scrubber. This problem Is extremely serious as evidenced b y the proposed federal legislation attempting to ban its use. By following acceptable procedures the problems of any pollution of the environment by INERTEEN from our plants can be controlled. II. General Safety Precautions INERTEEN vapor Is non-toxic to humans', except If taken Internally, but care must be taken to avoid unnecessary contact with the liquid or vapor c A. Vapo s The >dor of INERTEEN is noticeable well below the maximum safe acceptable air concentrations. The maximum atmospheric concentra tion limit (8 hours) reconxnended is one milligram of INERTEEN per pubic meter of air. NPC00026278 753615 High concentrations of INERTEEN such as found inside a trans former tank or the vapors from hot INERTEEN must be avoided. The .high concentrations of vapors can cause irritation of the eyed, nose, throat and upper respiratory tract. If contact with high concentrations of INERTEEN is necessary an approved gas [maaisk or self-contained breathing apparatus must be worn. The f^vvaaipors produced when INERTEEN is decomposed by very high temperatures or from an electric arc will consist mainly of hydrogen chloride. This vapor is very unpleasant and irritating, thud giving ample warning of its presence. Under emergency conditions an approved gas mask or self-contained breathing apparatus must be worn in order to enter a space containing vapors of decomposed INERTEEN. If irritating odors are detected with the breathing apparatus in use, the person should, go irasedlately into fresh air. All gas masks, respirators, replacement cartridges, and selfcontained breathing equipment must be Bureau of Mines approved and be maintained on a regular schedule in accordance with the manufacturers recommendation. B. Fluid Unlike oil, INERTEEN has virtually no fire hazard. However, INERTEEN can be irritating to the skin. Some people are quite allergic to the solvent action of INERTEEN on the skin. Both the liquid and vapor are irritating to the eyes. To prevent direct contact with the fluids approved aprons and gloves should be worn, however, the regular use of gloves is not recosnended jsince the gloves are easily contaminated on the inside with INERTEEN from the hands. After handling INERTEEN the hands should be washed thoroughly with warm soapy water. In the case of spillage onto clothing, the clothing should be removed as soon as practical and laundered or discarded in containers designated as "Scrap Burnable TMMtfffim Waste11. C. Eye Protection / INERTEEN and its vapor are irritating ,to the eyes. Eye protection such as safety glasses with side shields or'face shields must be worn at all times when handling INERTEEN. The use of medicinal washes or detergents on the skin followed by an application of skin cream will eliminate any irrigations resulting from INERTEEN coming in contact with an open cut or abrasion. Eye exposure to liquid INERTEEN should be irrigated innediately with large quantities of water from an approved eye 2- - - NPC00026279 753616 wash for fifteen minutes mid then examined by the company physi cian,. Fersons developing n skin irritation due to contact with INERTEEN should be examined by the company physician. D, Inrcstlon of ISERTREH INERTEEN ic moderately toxic if taken internally. Swallowing an ounce or more will cause irritation of the digestive tract and internal reaction. In such cases the person should go to * the company physician immediately. Any condition that might result in a possible ingestion of INERTEEN should be avoided. H I , Receiving And Storage. Of INERTEEN i0 T; . M .j^ A INERTEEN is shipped from the manufacturer in tank cars, tank trucks, 55 gallon steel drums and in 5 gallon metal drums. All containers must be labeled as to contents and carry a precaution ary label in reference to Its .environmental hazard. Every container should be Inspected for this labeling and leaks when received* \ A, Tank Car Receiving --- ** (K-j*-- 5 `V-m --- u-*l hw-*-- -w- ,' i: A special receiving area mist be allocated to INERTEEN tank cars. This area shall have provision for collecting reasonable ^ amounts of INERTEEN if the car is found to be leaking when rej.* eelved. Any leak should be reported immediately to the Super intendent of Maintenance -for appropriate action. / /- .. ^ (l t--'*'TV *'X -j-* *-- *--- .<~4*Ur v'A-j<-J' t " i^*** (t*' .i. rain pans 'must be provided to prevent .spillage from unloading hoses and connections. INERTEEN tank cars do not have a bottom .unloading valve and must be pumped from the top man-hole opening, 'Benzene or other approved cleaning fluids used for cleaning the campling devices must be collected in a "Scrap INERTEEN" drum for disposition. After use Lhc sampling device >shall be cleaned, dried and stored in a> suitable location. .B. Steel Drums and Cans ^- .i'i .1v. On receipt all INERTEEN drums pnd cans must-be'carefully inspected * for leaks. The containers should be stored indoors in an area - , ^ , rL j. especially selected for the purpose. A cement curb should en- 4 close the area to provide a basin for containing the INERTEEN `r(ci^a w 6 from at least two drums, should they be damaged. The area must not have a drain which is connected to a sanitary or storm sewer, C* Stohnr.e Tanks - -. : * * ; A11'INERTEEN storage tanks should be" erected on a cement base Lo lfint:inspection can be m.i^o for leaks. A wall of cement must' be erected around ihc.ltahk' to provide a holding basin to contain . . all the INERTEEN in the storage tank In the cvcm. o ;. tank * '' failure. The base and wall must be constructed with INERTEEN . * -3 - . NPC00026280 753617 resistant expansion Joint 1.0 prevent crnc.klng of the cement. . A sump drain with pump ::linnId be provided in remove any accumu lation of surface water but must not be Lied Into a sanitary or Btdrm sewer. The pump w i l l `be manually activated when required. The sump pump must also be of sufficient rapacity to pump the . ; INERTEEN from the storage tank basin Into containers for sal vaging the material or for scrapping in ease of a spill. All tank piping must be exposed to permit inspection for leaks. IV.. Plant Manufacturing Area For Filling Units With INERTEEN / J V;i+JtnM-b, y-*/*- Jh'P- * yk t-u,.iX - V ^ {- f It la quite ^probable that in 11 ling equipment with INERTEEN and further handling of this equipment that an INERTEEN spill will occur. Therefore it is nccescary to provide facilities and. a pro cedure-for derni-up to prevesnntt econttnaimniinnaatfiionn. .x-.J ,Ritit J/ A. INERTEEN Fi U l n e Area U --- Tlte location of the INERTEEN filling area should be adjacent to the test area and final shipping area to minimize the danger of damage of units during handling. . The manufacturing area provided for f i P i n g equipment with ./y - i f INERTEEN shall have a cement floor with adequate, cement_curb#f L~<'. around the entire area to act as a basin for containing the volumu of INERTEEN from the largest production unit. Floor drains mu'st not be connected to a sanitary or storm sewer but to a sump provided with a manually activated pump capable of pumping spilled INERTEEN or other liquids into "Scrap INERTEEN" drums. Adequate ventilation of the area shall be'provided to maintain4 an atmospheric INERTEEN fume level b d o w one milligram of INERTEEN per cubic meter of air. The exhaust from vacuum pump and ventilation of the area shall be directed thru filters capable of removing INERTEEN valors. *. Drip pans shall be provided for hose connections and filling valves. IN1KTEEK resistant aprons and gloves shall be available for ap<clal operations in which the personnel must come in contact vlqh the INERTEEN. Reiplrators, self-contained breathing apparatus, or gas-masks of a type approved by the Bureau of Mines'must be available for usq by personnel in high air concentrations of INERTEEN. All manufacturing procedures must be directed toward preventing loss of INERTEEN to Lite environment. In cane of an INERTEEN A- NPC00026281 753618 spill the Superintendent of Maintenance should be contacted lnvncdiatcly to carry out the prescribed clcon-up procedure. B, Specini Containera For Scrap Materials 1. Drums labeled "Scrap INERTEEN" must be available for handling all spills,and waste INERTEEN from the sump, failed units, drip . pans, sample Jars etc. 2. {Open-head drums with approved closure or other suitable con tainers labeled "Scrap Burnable INERTEEN Materials" must be 'available for handling scrap cellulose insulation, rags, paper predsboard, wood, sawdust, etc. 3. Separate containers for handling steel, copper, and aluminum, each adequately marked, shall be provided for the components of contaminated core and coil assemblies when tear downs are necessary. 4. Containers for supplies of aaw-dust for absorbing small INERTEEN spills or clean-up must be provided. Speedy-dri. or other clay absorbing materlala are not recommended. `/L V. Conditioning INERTEEN A. INERTEEN Conditioning Ecuinment i t The conditioning equipment and Intermediate storage tank should be located in the bulk storage area which Is provided with an adequate curb to contain the INERTEEN held .in the intermediate storage tank. Two alternate procedures are satisfactory. The conditioning equipment* and Intermediate storage tank may be located In the manufacturing filling area since a curb is provided for con taining a spill* If the conditioning equipment and storage ~ tank is located In other areas it must be placed on a cement , floor with an adequate curb surrounding the equipment and tank to provide a holding basin for al the INERTEEN in the intermediate atorage tank in the event of a tank failure. A sump, not connect ed to a storm or sanitary sewer', may be provided to clean the holding basin in case of a spill. An alternate would be separ- '* etc pumping equipment to pump the INERTEEN spill Into "Scrap INERlTEEN" drums for disposal. * B. Fullers1 Earth Conditioning of INERTEEN requires fullers' earth treatment. The spent fullers* earth In cartridges or bags when replaced shall be allowed to thoroughly drain over drip pans to remove as much, liquid INERTEEN as possible. The cartridge units of steel mesh *a- ___ i* I NPC00026282 753619  'J construction containing fullers* earth shall be scrapped in the containers marked, "Steel Contaminated with INKITEElr1, for dis position. Cloth bags filled with spent fullers' earth shall be disposed of in the containers marked "Scrap Burnable INERTEEN Waste". The fullers1 earth in the conditioning equipment shall be changed when necessary to maintain the INERTEEN within acceptable operating limits. . VI. .Tear-Down of INERTEEN Units for Repair or Scrap A. Tear-Down Procedure 1. Drain all the INERTEEN from the transformer or capacitor into the conditioning tank or into drums labeled "Scrap INERTEEN" depending upon the laboratory reports of the condi tion of the INERTEEN. Allow sufficient time for all the INERTEEN to drain freon cores and coils (at least twelve hours) and again drain the INERTEEN from the tank. ! 2. Remove the cores and/or coil assemblies from the tank and place them on a steel tear-down table having a raised edge to contain any run-off INERTEEN from the assembly. A center or other properly located drain shall be provided in the steel table to collect the run-off INERTEEN. ' 3- The personnel that dismantle the unit must wear approved i gloves, apron and eye protection. \ - U. Place all materials In the appropriate salvage containers I during the tear-down for later disposition. i 5. The tear-down table shall be cleaned with kerosene or other I approved solvents after the dismantling operation. The used fluids shall be placed ,in the "Scrap INERTEEN" drums for dis position. : VII. Handling of Empty Containers Contaminated with INERTEEN A. Tank Cars / When tank cars have been unloaded they will be re-sealed and returned to the manufacturers without further cleaning. These tank cars ore used only for INERTEEN shipments and the cleaning will be done by the supplier. * B. Drums v Drums which contained new INERTEEN can be used for waste fluids HPC00026283 753620 rom the INERTEEN manufacturing section and should be plainly, * marked "Scrap INERTEEN". Drums which must be retired from use shall be washed twice with one gallon portions of kerosene, benzine, or other approved solvent before crushing, delivery to scrap dealers or used for other disposal* The wash fluid shall be disposed of In drums marked "Scrap INERTEEN". C. 5-Gallon Drums 5-Gallon drums which contained new INERTEEN when empty shall be washed twice with kerosene, benzine or other approved solvent before scrapping or re-using, The wash solvent shall be placed in a "Scrap INERTEEN" drum. D. Sample Bottles Sample bottles and other small containers used for obtaining samples of INERTEEN for test from any source such as trans formers, storage tanks, filling lines etc. must be rinsed at least twice with .benzine or kerosene before re-use or scrapping. The rinse solvent shall be placed in a "Scrap INERTEEN" drum. VIII. Purchases Of INERTEEN By Manufacturing Divisions. M & R Plants And E ft S Groups No direct sales of any quantity of INERTEEN will be made to any customers nor will authorizations be issued to the Monsanto Company to ship INERTEEN except to those locations manufacturing INERTEEN equipment or M & R Plants and E & S Groups having repair or service orders for the direct use of INERTEEN under th super vision of Westlnghouse personnel. This is to eliminate any possible chance for INERTEEN to be obtained for uses-of any kind except in transformers or capacitors. A. Manufacturing Plants INERTEEN for use in manufacturing and filling new equipment will be ordered from the Monsanto Company as a stock material. Orders for INERTEEN for make-up or other purposes vili be re ferred to the nearest M & P Plant or E & 5 Group depending on the need for the INERTEEN. B. District Offices 7 Orders for INERTEEN will be referred to the nearest M & R Plant or E & S Group depending upon the need for the INERTEEN and will be made a part of a service contract on specific equipment. C. M & R Plants Orders for INERTEEN for use in repairing equipment will be issued -7 - 753621 by tlic M & R Plants to Monsanto for shipment to the repair plant' only and must be used on customers orders. All repair shops performing service work on INERTEEN transformers must set aside an area in the repair shop to handle all INERTEEN service work. This shop area must be altered to provide the same safeguards as established in the manufacturing locations Including curbing around the area to contain an accidental spill, containers for bolding materials contaminated with XNERTEEN, containers for scrap XNERTEEN and safety equipment for employees. All scrap materials roust be disposed of at authorized locations that have incinerators capable of safely destroying the XNERTEEN. Only the XNERTEEN contained in the equipment will be returned to the xus.tomer. D. E & S Groups Service orders to maintain INERTEEN equipment will be accepted and the necessary XNERTEEN will be ordered by the E & S group from Monsanto Co. for shipment to the E & S facilities. The required XNERTEEN will be taken to the customers premises and additions of make-up as other requirements supervised. An excess XNERTEEN will be returned to the E & S storage area. APPROVED: APPROVED: March 16, 1972 APPROVED: APPROVED: NFC00026285 753622 rom the XNKUTEEN ni.iiiuCacluring suction and should be plainly marked "Scrap 1HERTKEN". Drums which must be retired Crow nee shall be washed twice viLh one gallon porLionn of kerosene, benzene, or other approved solvent before crushing delivery to scrap dealers or used for other dis- 1 ponul. The wnr.h fluid shall be disposed of In drums marked "Scrap I N E K T L W . C. '.5-Railon Drums * 5-GnJlon drums which contained new INERTEEN when empty shall be washed twice with kerosene, benzene or other approved solvent before scrapping or re-using. The wash solvent shall be placed In a "Scrap 1NERTEEN" drum. D. Sample Bottles * * Sample bottles and other small containers used for obtaining samples of INERTEEN for test from any source such as trans formers, storage tanks, filling linos etc. must be rinsed'at least twice with benzene *or kerosene before re-use or scrapping. The rinse solvent shall be placed in a "Scrap. INERTEEN" drum. VIII. Purchases of IKEDTEEN by District Office3 and Repair Shoos It."Is necessary to police the sales of INERTEEN to all users in order to prevent the misuse of INERTEEN by those requiring this mater ial for equipment or applications which are not closed systems thus permitting-environmental contamination with the INERXEEK. A. District Offices . . /** ,' All orders for IKERTEEN must be carefully surveyed In order to establish the application for which material will be used. It Is desirable, if at all possible, to "obtain a service contract to handle the repair or maintenance of the customers1 .transformer rather than supply the 1KEKTEN. This Insures direct, control to prevent the pollution of ,,the environment. For those customers willing to provide service contract, it is Important that the j work is performed by personnel knowledgeable in the proper handling of INERTEEN under the newly established guidelines. Orders for INERTEEN for the 'Service contracts shall be placed with Monsanto for delivery to the servicing group and not to the customer. In those cases in which customers Insist on performing their own . maintenance and repair work and in lohatio'ns where service con t r a c t s arc impractical, orders for XKEftEEN will be accepted nly 'after the customer has established' the heed for the INEKTEEN and `will provide signed documents indicating they ore fully aware of .the polychlorinated biphenyl problem, that they have established 753623 procedures for the proper handling of INERTEEN and that they In no way will hoLd cite Wfntlnijhousc Electric Corporation re* sponsible for liability renvilting from tlie.ir use of the INERTEEN. Orders then will be sent to Monsanto far delivery to these customers.' B* Repair Shoos * ' v No order for INERTEEN for delivery to any customers will be ec- . cep ted by .the repair shops. J*ex r * - -S 1 ^ 11 >n ], rr i _% jLjtCiv *-- *t <~ v-c 1 ^is.tr-v-. j*.>-- Orders for INERTE-E-N---for servi-c-e--w-o-r-k--p--e-r-f-o-r-m-e-d--I-n--t-h repai`r <> T shops or at customers1 location will be directed to Monsanto for shipment of INERTEEN to the repair shop location only. All repair shops performing service work on INERTEEN trans formers must set aside an ares in the repair shop to handle all INERTEEN service work. This shop area must be altered to pro vide the same safeguards as established in the manufacturing lo cations Including curbing around the area to contain an accidental aplll, containers for holding materials contaminated with INERTEEN containers for scrap INERTEEN and safety equipment for employees. All scrap materials must be disposed of at authorised locations that have incinerators capable of safely destroying the INERTEEN. APPROVED; APPROVED; _ _________ ,* _______ - /| t i ` APPROVED; * APPROVED;_____________________ February 4 1972 //l .J -**^-** `-U* iVvi I , .w .t h fXi-'-A r * ^ ( "V /; 8 NPC00026287 753624 August 12, 1576 J Protective equipment is provided by Westinahouse for employes working d ire c tly 'with Aroclor. The items provided are: A. Rubber Boots B. Rubber Gloves C. Bib Overalls D. P la s tic Aprons . Safety Glasses and Goggles F. Face Shields G. P la s tic Sleeve Protectors H. Respirators The employes are reouired by Westinghouse to wear the rubber gloves when working on tasks which may bring them in to d ire c t contact with A roclor. I t is the resp o n sib ility o f the Foreman to enforce th is requirement. Safety glasses/goggles are required fo r the f i l l plug spidering operation because o f- , the so ld erin g, not because of the Aroclor present. The balance o f the equipment lis te d 1s provided by Westinghouse and is available to employes working on jobs which bring them into d ire ct contact with Aroclor. The use o f protective equipment other than the rubber gloves 1s optional and is not required by Westinghouse. The contaminated Items are disposed o f by placing them In the contaminated waste barrels which are sent to the s c ie n t if ic la n d f ill fo r b u r ia l. The bib overalls are worn fo r approximately two weeks. They are run through the vapor degreaser on the can lin e to clean them up. They ar aood fo r another two weeks and then are thrown in to the contaminated waste b a rre ls. It is the resp o n sib ility o f the f i r s t lin e Supervisor to monitor the use o f the required equipment and to provide necessary information as to hazards and operating procedures. .i -.-tv. NPC00026288 753625 y POLICY FOR THE USE AND HANDLING OF INERTEEN V?7,vvv: NPC00026289 753626 CONTENTS - I. Introduction---------------- ----------- --------- ----- ------- Page 1 11 General Safety Precautions--------- ---------- ---------- Page 1 A. Vapors------------------------------ - ------ --Page1 & 2 B. Fluid.... -............................................... Page 2 C. Eye Protection----- ----- ----------- -- Page 2 & 3 D. Ingestion of INERTCEN------ ------------ ------- -- ....... Page 3 III. Receiving And Storage Of INERTEEN--- --------page 3 A. Tank Cor----------------------------- ------------ -------- Page 3 B. Steel Drums and Cans-------------------------- -- --- ------ Page 3 C. Storage Tanks------- --- ----------------- -------- ------ Page 3 4 4 IV. Plant Manufacturing Area------------------- -- --- ----- Page 4 A. INERTEEN Filling A r e a - - - .................... ..... .......Page 4 B . Special Containers for Scrap Material-------- - - - - - - - - - - P a g e 5 V. Conditioning of 1NERTEEN-............... ............... -.....Page 5 A. INERTEEN Conditioning Equipment--- ---------page 5 B. Fullers' Earth------------- Page 5 4 6 VI. Tear-Down Of 1NERTEF,N Units For Repair Or Scrap---- -- -- --- -Page 6 A. Tear-Down Procedure------- ---- - - - - - - - -- -- -- -- -- -- -- Page 6 i VII. Handling Of Empty Container* Contaminated With INERTEEN --Page 6 A. Tank Cars---------------------------- --- --------- Page 6 B. Drums-------- Page 6 4 7 C. 5-Gallon Drums---------------------- Page 7 D. Sample Bottles------ ------------------ ------ ------------ Page 7 VIII. Purchases of INERTEEN by District Offices 4 Repair Shoos Page 7 A. District Offices---- ---- -------- -----------------------Page 7 4 8 B. Repair Shops-------------------- ------------ ..._________Page 8 NPC00026290 753627 POLICY FOR THE USE AND HANDLING OF INEHTEEN Introduction INERTEEN is s synthetic transformer dielectric flulIrraa made by the chlorination of a chemical, biphenyl, to give it non-flammable properties Since this process stabilizes the fluid for transformer use, it also makes it difficult to destroy when it gets into the environment. Tests have been made throughout the world that show the undesirable nature of this type of fluid and its effect on some species of fish and birds. It has been shown that if INERTEEN is to continue to be used in transformers and capacitors, a positive effort must be made to control and prevent pollution by this product. INERTEEN can get into the environment during the manufacture, delivery, improper use, maintenance, repair and disposal of trans formers and capacitors. Experience has shown that it is necessary to control all aspects of the manufacturing and fluid handling process with emphasis on the possibilities of leakages and spillages to prevent any INERTEEN from getting into the environment. Close attention to good plant housekeeping is the main key to pollution control. Care must also be exercised to ensure that all test samples and IRlKtfi'EKN contaminated solvents are collected for disposal in an acceptable manner. Chemicals, such as INERTEEN, are NOT PERMITTED in any effluent om manufacturing plants. This is prohibited by the clean stream lavs. INERTEEN and INERTEEN contaminated wastes have been shown not to be acceptable in sanitary land-fills. This then requires that these waste^must be destroyed by incineration in a high temperature Incinera tor ( 9 F) equipped with a scrubber. This problem is extremely serious as evidenced by the proposed federal legislation attempting to ban its use. By following acceptable procedures the problems of any pollution of the environment by INERTEEN from our plants can be controlled. General Safety Precautions INERTEEN vapor is non-toxic to humans, except if taken internally, but care must be taken to avoid unnecessary contact with the liquid or vapors. A. Vapors The odor of INERTEEN is noticeable well below the safe acceptable air concentrations. The atmospheric concentra tion limit (9 hours) reconroended is one milligram of INERTEEN per cubic meter of air. NPC00026291 753628 V.' *-4 High concentrations of INERTEEN such as found Inside a trans former tank or. the vapors from hot INERTEEN must be avoided. The high concentrations of vapors can cause irritation of the eyes, nose, throat and upper respiratory tract. If contact with high concentrations of INERTEEN is necessary an approved gas mask or self-contained breathing apparatus must he worn. The vapors produced when HJEHTEEN is decomposed by very high temperatures or from an electric arc will consist mainly of hydrogen chloride. This vapor is very unpleasant and irritating, thus giving ample warning of its presence. Under emergency conditions an approved gas mask or self-contained breathing apparatus must be worn in order to enter a space containing vapors of decomposed INERTEEN. If irritating odors are detected with the breathing apparatus in use, the person should go immed iately into fresh air. All gas masks, respirators, replacement cartridges, and selfcontained breathing equipment must be Bureau of Mines approved and be maintained on a regular schedule in accordance with the manufacturers recamnendation. Fluid Unlike oil, INERTEEN has virtually no fire hazard. However, INERTEEN can he irritating to the skin. Same people are quite allergic to the solvent action of INERTEEN on the skin. Both the liquid and vapor are irritating to the eyes. To prevent direct contact with the fluids approved aprons and gloves should he worn, however, the regular use of gloves is not recommended since the gloves are easily contaminated on the Inside with INERTEEN from the hands. After handling INERTEEN the hands should be washed thoroughly with warm soapy water. In the case of spillage onto clothing, the clothing should be removed as soon as practical and laundered or discarded In containers designated as "Scrap Burnable INERTEEN Waste". Eye Protection INERTEEN and its vapor are irritating to the 'eyes. Eye protection such as safety glasses with side shields or'face shields must be worn at all times when handling INERTEEN. j ' The use of medicinal washes or detergents on the skin followed by an application of skin cream will eliminate any irritations resulting frem INERTEEN coming in contact with an open cut or abrasion. Eye exposure to liquid INERTEEN should be irrigated immediately with large quantities of water from an approved eye 2 .r..***: iW NPC00026292 753629 wash for fifteen minutes nnd then examined by the company physi Ian. Persons developing n skin irritation due. to contact with INERTEEN should be examined by the company physician. D. Ingestion of INERTEEN INERTEEN is moderately toxic if taken internally. Swallowing an ounce or more will cause irritation of the digestive tract and internal reaction. In such cases the person should go to the company physician immediately, Any condition that might result in a possible ingestion of INERTEEN should be avoided. I III. Receiving And Storage Of INERTEEN INERTEEN is shipped from the manufacturer in tank cars, tank trucks, 55 gallon steel drums and in 5 gallon metal drums. All containers must be labeled as to contents and carry a prccaution" ary label in reference to JJ s .environmental hazard. Every container should be inspected for this labeling and leaks when received* A. Tank Car Receiving A special receiving area must be allocated to IUERTEEN tank cars. This area shall have provision for collecting reasonable amounts of INERTEEN if the car is found to be leaking when re ceived. Any leak should be reported immediately to the Super intendent of Maintenance -for appropriate action. Drain pans must be provided to prevent spillage from unloading hoses and connections. INERTEEN tank cars do not have a bottom unloading valve and must be pumped from the top man-hole opening* iBenzene or other approved cleaning fluids used for cleaning the sampling devices must be collected in a "Scrap INERTEEN" drum for disposition. After use the sampling device shall be cleaned, dried and stored in a suitable location. Steel Drums and Cans 3 On receipt all INERTEEN drums and cans must be carefully inspected for leaks. The containers should be stored indoors in an area especially sclocLed for the purpose. A cement curb should en close the area to provide a basin fur containing the INERTEEN from at least two drums should they be damaged. The area milse not have a drain which is connected to a sanitary or storm sewer. C. Storage. Tanks sZ u f All INERTEEN storage tanks should be erected on a cement base so %iac:inspection can be made for leaks. A wall of cement must \ be erected around the tank to provide a holding basin to contain J all the INEKTEEN in Lhc storage tank in the event of tank failure. The base aud wall-must be constructed with INERTEEN - a - \ 1 j IP C 0 0 0 2 6 2 9 3 753630 reals ton t expansion Joint: to prevent cracking of the cement; A aump drain with pump alioulri be provided It* removu any accumu lation of surface water but must not be tied Into a sanitary or storm sewer. The pump will be manually activated when required. The sump pump must also be of sufficient capcity to pump the j INERTEEN from the storage tank basin into containers for sal vaging the material or for scrapping in cm:e of a spill. All tank piping must be exposed to permit Inspection for leaks. IV Plant Manufacturing Area For Filling Units With INERTEEN It is* quite probable that in filling equipment with INERTEEN and further handling of this equipment that an INERTEEN spill will occur. Therefore it is necessary to provide facilities and a pro cedure for clean-up to prevent contamination. A. INERTEEN Filling Area The location of the INEKTEEN filling area should be adjacent to the test area and* final shipping area to minimize the denger of damage of units during handling. Q {, /\ T The manufacturing area provided for filling equipment with INERTEEN shall have a cement floor with adequate cement curb around the entire area to act as a basin for containing the volumu of INERTEEN from the largest production unit. Floor drains must not be connected to a sanitary or storm sewer but to a sump provided with a manually activated pump capable of pumping spilled INERTEEN or othor liquids into "Scrap INERTEEN1' drums. Adequate ventilation of the area shall be provided to maintain an atmospheric INERTEEN fume level below one milligram of INERTEEN per cubic meter o air. The exhaust from vacuum pump and ventilation of the area shall be directed thru filters capable of removing INERTEEN vapors. * Drip pans shall be provided for hose connections and filling valves. INERTEEN resistant aprons and gloves shall be available for1 special operations in which the personnel must come in contact with the INERTEEN. Respirators, self-contained breathing apparatus, or gas-masks of 8 type approved by the Bureau of Mines must be available for use by personnel in high air concentrations of INERTEEN. All manufacturing procedures must be directed toward preventing loss of INERTEEN to the environment. In case of an INERTEEN - A- NPC00026294 753631 ftplll the Superintendent of Maintenance should be contacted invncdiatcly to carry out the prescribed clean-up procedure. B. Special Containers Tor Scrap Materials 1. Drums labeled "Scrap INERTEEN" must be available for handling 11 spills and waste INERTEEN from the sump, failed units, drip pans, sample jars etc. 2. Open-head drums with approved closure or other suitable con tainers labeled "Scrap Burnable INERTEEN Materials" must be available for handling scrap cellulose insulation, rags, paper pressboard, wood, sawdust, etc. 3. Separate containers for handling steel, copper, and aluminum, each adequately marked, shall be provided for the components of contaminated core and coil assemblies when tear downs are necessary. 4. Containers for supplies of saw-dust for absorbing small INERTEEN spills or clean-up must be provided. Speedy-dri or other clay absorbing materials are not recommended. Conditioning INERTEEN A. INERTEEN Conditioning Equipment The conditioning equipment and intermediate storage tank should be located in the bulk storage area which is provided with an adequate curb to contain the INERTEEN held in the intermediate storage tank. Two alternate procedures are satisfactory. The conditioning equipment' and intermediate storage tank may be located in the manufacturing filling area since a curb is provided for con taining a spill. If the conditioning equipment and storage tank is located in other areas It must be placed on a cement , floor with an adequate curb surrounding the equipment and tank to provide a holding basin for all the INERTEEN in the intermediate storage tank in the event of a tank failure. A sump, not connect ed to a storm or sanitary sewer, may be provided to clean the holding basin in case of a spill. An alternate would be separ ate pumping equipment to pump the INERTEEN spill into "Scrap INERTEEN" drums for disposal. B. Fullers* Earth Conditioning of INERTEEN requires fullers' earth treatment. The spent fullers' earth in cartridges or bags when replaced shall be allowed to thoroughly drain over drip pans to remove as much liquid INERTEEN as possible. The cartridge units of steel mesh if.5%^..^, NPC00026295 753632 construction containing f u l l e r s ' earth s h a ll be scrapped in the containers marked, " S te e l Contaminated with INERTEEN , fo r d is p o s itio n . C loth bags f i l l e d with spent f u l l e r s ' earth s h a ll be disposed o f in the con tain ers marked "Scrap Burnable INERTEEN Waste". The f u l l e r s ' earth in the co n d itio n in g equipment s h a ll be changed when necessary to m aintain the INERTEEN w ithin accep tab le operating lim its. 71. Tear-Down o f INEKTEEN U nits fo r Repair or Scrap A. Tear-Down Procedure 1 . Drain a l l th e INERTEEN from the transform er or ca p a cito r in to the co n d itio n in g tank or in to drums la b e le d "Scrap INERTEEN" depending upon the la b o ra to ry rep orts o f th e con d i tio n o f th e INERTEEN. Allow s u f f i c i e n t time fo r a l l the INERTEEN to drain from cores and c o ils (a t le a s t tw elve hours) and again drain the INERTEEN from the ta n k . 2. Remove the cores and/or c o i l assem blies from the tan k and place them on a s t e e l tear-down ta b le having a ra ise d edge to con tain any r u n -o ff INERTEEN from the assem bly. A cen te r or other properly lo cate d drain s h a ll be provided in the s t e e l ta b le to c o lle c t the r u n -o ff INERTEEN. 3. The personnel th a t dism antle the u n it must wear approved g lo v e s , apron and eye p r o te c tio n . U. Place a l l m aterials in the appropriate salvage containers during the tear-down fo r la te r d isp o sitio n . . The tear-down ta b le s h a ll be cleaned w ith kerosene or other approved so lven ts a ft e r the dism antling o p e ratio n . The used fL u id s s h a ll be placed in the "Scrap INERTEEN" drums fo r d is p o s itio n . V I I . Handling ol' Empty Containers Contaminated with INERTEEN A. Tank Cars When tank cars have been unloaded they w i l l be r e -s e a le d and returned to the manufacturers without fu rth er c le w in g . These * tank cars are used on ly fo r INERTEEN shipments and the c le w in g w ill be done by the s u p p lie r . D. Drums Drums which contained new INERTEEN can be used fo r waste f lu id s ri Y N P C 0 0 0 2 6 2 9 6 753633 from the INERTEEN manufncturing section and should be plainly marked "Scrap IMERTKEN". Drums which must be retired from use shall be washed twice with one gallon portions of kei usouc, benzene, or oilier approved solvent bcfoic crushing, delivery to scrap dealers or used for other dis posal. The wash fluid shall be disposed of in drums marked "Scrap INERTEEN". C. '5-0allon Drums 5-Ga]Ion drums which contained new INERTEEN when empty shall be washed twice with kerosene, benzene or other approved solvent before scrapping or re-using. The wash solvent shall be placed in a "Scrap INERTEEN" drum. D. Sample Bottles Sample bottles nnd other small containers used for obtaining samples of INERTEEN for test from any source such as trans formers, storage tanks, filling lines etc. must be rinsed at least twice with benzene or kerosene before re-use or scrapping. The rinse solvent shall be placed in a "Scrap. INERTEEN" drum. VIII. Purchases of INERTEEN by District Offices and Repair Shoos It is necessary to police the sales of INERTEEN to all users in order to prevent the misuse of INERTEEN by those requiring this mater ial for equipment or applications which are not closed systems thus permitting environmental contamination with the INERTEEN. A. District Office.*? . : All orders for INERTEEN must be carefully surveyed in order to establish the application for which material will be used. It is desirable, if at all possible, to obtain a service contract to handle the repair or maintenance of the customers' transformer rather than supply the INERTEEN. This insures direct control to prevent the pollution of the environment. For those customers willing to provide a service contract, it is important that the work is performed by personnel knowledgeable in the proper handling of INERTEEN under the newly established guidelines. Orders for INERTEEN for the service contracts shall be placed with Monsanto for delivery to the servicing group and not to the customer. In those cases in which customers Insist on performing their own maintenance and repair work and in locations where service con tracts ore impractical, orders for INERTEEN will be accepted only after the customer has established the need for the INERTEEN and will provide signed documents indicating they are fully awarc'of .the polychlorinated biphenyl problem, that they have established -1 - NPC00026297 753634 't v .- / * * procedures for the proper handling of INERTEEN and that they in no wny will hold the Ucntlnghouso Electric Corporation re sponsible for liability resulting from their use of the INERTEEN. Orders then will be sent to Monsanto for delivery to these customers. B. Repair Shops No order for INERTEEN for delivery to any customers will be ac cepted by the repair shops. Orders for INERTEEN for service work performed in the repair shops or at customers' location will be directed to Monsanto for shipment of INERTEEN to the repair shop location only. All repair shops performing service work on INERTEEN trans formers must set aside an area in the repair shop to handle all INERTEEN service work. Thi6 shop area must be altered to pro vide the same safeguards as established in the manufacturing lo cations Including curbing around the area to contain an accidental spill, containers for holding materials contaminated with INERTEEN, containers for scrap INERTEEN and safety equipment for employees. All scrap materials must be disposed of at authorized locations that have incinerators capable of safely destroying the INERTEEN. APPROVED:_______________ /_________ APPROVED: APPROVED:_________________________ APPROVED: February 4, 1972 8 *>: NPC00026298 753635 ^ ..... -.`- y ----- from the INERTEEN manufacturing section and should be plainly . marked "Scrap iNERTEEhf1. Drums which must be retired from use shall be washed twice with one gallon portions of kerosene, benzine, or other approved solvent before crushing, delivery to scrap dealers or used for other disposal. The wash fluid shall be disposed of in drums marked "Scrap INERTEEN". C . 5-Gallon Drums 5-Gallon drums which contained new INERTEEN when empty shall be washed twice with kerosene, benzine or other approved solvent before scrapping or re-using. The wash solvent shall be placed in a "Scrap INERTEEN" drum. D. Sample Bottles Sample bottles and other small containers used for obtaining samples of INERTEEN for test from any source such as trans formers, storage tanks, filling lines etc. must be rinsed at least twice with benzine or kerosene before re-use or scrapping. The rinse solvent shall be placed in a "Scrap INERTEEN" drum. VIII. Purchases Of INERTEEN By Manufacturing Divisions. M & R Plants And E & S Groups No direct sales of any quantity of INERTEEN will be made to any customers nor will authorizations be issued to the Monsanto Company Lo ship INERTEEN except to those locations manufacturing INERTEEN equipment or M & R Plants and E & S Groups having repair or service orders for the direct use of INERTEEN under th super vision of Westinghouse personnel. This is to eliminate any possible chance for INERTEEN to be obtained for uses of any kind except in transformers or capacitors. A. Manufacturing Plants INERTEEN for use in manufacturing and filling new equipment will be ordered from the Monsanto Company as a stock material. Orders for INERTEEN for make-up or other purposes will be re ferred to the nearest M & P Plant or E & S Group depending on the need for the INERTEEN. B. District Offices Orders for INERTEEN will be referred to the nearest M & R Plant or E & S Group depending upon the need for the INERTEEN and will be made a part of a service contract on specific equipment. C. M & R PlanLs Orders for INERTEEN for use in repairing equipment will be issued 7 NPC00026299 753636 r** by the M & R Plants to Monsanto for shipment to the repair plant'only and must be used on customers orders. All repair shops performing service work on INERTEEN transformers must set aside an area in the repair Bhop to handle all 1NERTEEN service work. This shop area must be altered to provide the same safeguards as established in the manufacturing locations including curbing around the area to contain an accidental spill, containers for holding materials contaminated with INERTEEN, containers for scrap 1NERTEEN and safety equipment for employees. All scrap materials must be disposed of at authorized locations that have incinerators capable of safely destroying the INERTEEN. Only the INERTEEN contained in the equipment will be returned to the jcustoraer. D. E & S Croups Service orders to maintain INERTEEN equipment will be accepted and the necessary INERTEEN will be ordered by the E & S group from Monsanto Co. for shipment to the E & S facilities. The required INERTEEN will be taken to the customers premises and additions of make-up as other requirements supervised. An excess INERTEEN will be returned to the E & S storage area. APPROVED: APPROVED: March 16, 1972 APPROVED: APPROVED: NPC00026300 753637