Document 97DRwe17RNLapQBzExE5d7Dq
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THE PCB-POLLUTION PROBLEM January 21 and 22, 1970
St. Louis Meeting With General Electric Co.
GENERAL ELECTRIC REPRESENTATIVES:
Mr. Edward L. Raab, GE Pittsfield, Mass., representing all GE locations
Mr. H. Gerade, GE toxicological consultant
Dr. K. Murphy, GE Schenectady, New York, Environmental
Pollution Control
J
MONSANTO REPRESENTATIVES:
H. S. Bergen, D. A. Olson, E. P. Wheeler, Dr. W. R. Richard, Dr. R. H. Munch, Dr. R. Keller, Dr. S. Tucker, W. B. Papageorge, J. G. Bryant, P. G. Benignus
A. Presentation and Discussion of Published Articles About Chlorinated
Aromatic Hydrocarbon insecticides, (DDT 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.
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He mentioned that manufacturers of DDT and chlorinated aromatic hydrocarbon insecticides will tend to emphasize the finding and interference of PCBs as the Government hearings limiting or banning use of the insecticides are held.
This lead GE 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 GLC - Mass
Spectrometric analytical capability and apparatus, as portrayed
in Table 1. The sophistication of our analytical capability was
emphasized to assure that our approach 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.
.
General Electric were impressed and completely satisfied with the scope of our analytical capability and work.
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C. Blodegradeablllty of PCBs
Mr. Wheeler related that while Aroclor 1254 and 1260 are being found, especially in aquatic environment, the lower chlorinated biphenyls are not being observed. It is anticipated that the lower chlorinated members may be largely biodegradeable.
Drs. Richard, Keller and Tucker discussed biodegradeability 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 GE to draw conclusions.
Since the literature indicates that trichlorobenzene and tritetrachlorobenzene are not susceptible to biodegradation, GE are Intrigued with the absence of reports about finding these materials in the environment. The obvious implication is that since these materials are used with the higher chlorinated PCBs found -- the source of the latter is not from dielectric fluids. However, it was reasoned that chlorobenzenes 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 spectrum.
D. Status of Aroclor Studies At Industrial Bio-Test. Table 2.
In essence results reported by Mr. Wheeler on chronic animal
toxicity tests and animal reproducibility studies underway are
not as favorable as we had hoped or anticipated. Particularly
alarming is evidence of effect on hatchability and production
of thin egg shells regards white leghorn chickens. The studies
Involved Aroclor 1242, 1254 and 1260. Some of the studies will
be repeated to arrive at better conclusions.
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E. The Location of Askarel Transformers. Table 3
Messrs. Raab and Benignus formulated Table 3 to portray the use and locations of askarel transformers throughout industry and our commercial and residential areas.
On discussing these askarel transformer applications Mr. Raab was * most impelling and forceful about the non-replaceability of
transformer askarel fluid and the critical or essential use and ^ need for askarel transformers, which have safety from fire as
' their outstanding virtue. Without dwelling on details and instead carried to the ultimate, the concensus is that without availability of askarel transformers large cities like New York would be shut down with no power. Certain industries that rely mainly on askarel transformers wo&ld go down with no power. Without Aroclor capacitors most of the lights across our country would go put and motors In air conditioners and many industrial applications would not run.
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Frankly, no one could think of a suitable replacement for transformer askarel fluid. Fortunately, Aroclor 1242 with promise about biodegradeability is used in most all of the Aroclor type capacitors. Moreover, possible favorable isomer rearrangements are foreseen in the case of Aroclor 1242.
Need to control, accumulate and properly dispose of scrap askarels is unquestionable in light of the PCB pollution problem, and essential toward maintaining the use of askarel dielectrics. At GE alone apparatus in which askarel fluid is used represents 100 million dollars annually. About 60# is in the capacitor area and 40$ represents transformers.
GE requested and we were pleased to give Dr. Murphy their Environmental Control man, a list of all GE and other locations receiving Pyranol shipments in 1969. This amounts to about 16 million pounds of askarel fluids with economic worth of near 2.5 million dollars. This listing included 244 different locations of which 115 were GE plants and service shops scattered throughout our country.
Of course in addition to dielectric use in hermetically sealed capacitors and transformers major amounts of PCBs are used as Plasticizers, Industrial Hydraulic Fluids and Heat-Transfer media.
F. Environmental Sources of PCBs From Dielectric Applications
1. Spills
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2. Disposal of waste
3. Ultimate disposal of product -- 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"
G. Considerations of Degradation Disposals
1. PCBs up to and including 3 chlorine atoms appear biodegradeable in preliminary laboratory work.
2. Thus far there is n>o evidence that higher chlorinated biphenyls will biodegrade.
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3. According to the literature TCB and TTCB biodegrade at a very slow rate.
4. Chemical, catalytic breakdown would probably require high temperatures.
5. Incineration will require 800C. and 5 second sojourn time. - HC1 scrubbing would be required.
H. Estimated Annual Amounts of Contaminated and Scrap PCBs Prom
The Erectrlcal Industry
'
1. Prom The Transformer Industry:
a) In plant and field spills are small and controllable with adsorbents, which should be incinerated.
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 occasion they may fill new transformers sent into the field without fluid. As these service shops are devoted primarily to repairing faulty transformers, we can assume that as much as 1.0 million pounds annually of "scrap" is generated. Most of this has been dumped or disposed of in streams.
c) We estimate that probably 150,000 pounds of this is arced beyond reworking and needs to be incinerated. The remainder may be reworkable by distillation.
2. From The Capacitor Industry:
.
a) Collectable waste from normal capacitor impregnation operations amounts to about 850,000 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 incinerated, along with the 150,000 pounds of scrap from transformers.
c) Power capacitors are designed to last over 30 years. Modern motor runs may last 10 years and the small lighting ballast usually last not over 10 years.
Eventually andvpumulatively there is a large potential of field-failedt capacitors. Fortunately Aroclor 1242 has been used almost exclusively since about 1950.
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The failed units are disposed of in industrial dumps. In case of ballasts the Aroclor capacitor along with the transformer imbedded in asphalt or encapsulated in epoxy resin, all encased in a metal box are discarded as a unit. This is emphasized to indicate that incineration of such apparatus is not applicable.
3. From Containers:
Most askarel moves in bulk, tank cars or tank wagons, which do not present a problem.
y 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. GE asked what is Monsanto's plan about reclamation of scrap ' PCB from GE plants, service shops, utilities, industrial users,
commercial users, etc.?
2. What is our view about a "Buy-Back" arrangement?
3. What arrangements will Monsanto make for incineration? Disposal
in suitable land-fills? Reclamation by distillation at
Monsanto?
;
4. To date Monsanto's posture is:
a) We have taken "good quality" scrap from GE's capacitor plant at Hudson Falls and had it reworked by simple filtration at Findett. This Findett arrangement is not practical nor economical. We paid GE 1 $(/lb. for this "quite good" Aroclor, plus 1.9 $/lb. freight. Findett charged 2.1 ^ to filter this material, making our cost
5 ?5/lb.
.
b) 130,000 pounds of somewhat lower quality scrap from Westinghouse capacitor plant has accumulated at Findett
for lack of distillation equipment.
c) Scrap from GE's Ft. Edward plant appears to need reprocessing by distillation.
d) About \ million pounds of "bad scrap" from GE Hudson Falls, has been disposed to a land-fill in New Jersey. Monsanto paid half of the freight cost.
e) A car load of s6rap transformer askarel from Westinghouse, South Boston, Virginia is being sent to W. G. Krummrich for reprocessing.
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f) We advised Westinghouse, 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-back" arrangements have been made on an individual and experimental basis. We have no fixed "buy back" arrangement, regards answering GE's question.
6. We have no established process for reclaiming either capacitor or transformer scrap.
7. We have no incinerator 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 desireable, it is better than indiscriminate dumping.
J. Transformer Askarel Blends Discussed With GE. Table 4.
Table 4 lists the transformer askarel blends reviewed with GE.
1. GE Rome has discontinued use of Blend A due to combustibility of arc formed gas. For this same reason, as dictated by their legal people they will not use Blend B.
2. Today both GE, Pittsfield, Mass, and Rome, Ga. use Blend C (Pyranol A13B3B), which they mix themselves.
3. Blend D optimizes the Aroclor concentration in conformance
with GE's requirements for non-combustibility of the
arc formed gas and with the pour point requirements.
The price is in direct conformance with our previous
.
quotation for Aroclor 1242, when GE was using this at
a concentration of Q0% by weight.
y
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Accordingly Blend D meets GE'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 E (inerteen 70-30) is identical properties with Blend D, which latter GE, Rome, Ga. proposes to use. In the interest of standardization, we seek to have GE, at Pittsfield and Rome, Ga. use Blend E, which is used by Westinghouse for low temperature applications and is used by many other askarel transformer manufacturers for generaVapplication.
5. Although Westinghouse USA uses Blend F (100$ Aroclor 1242) for all applications, except for low-temperature application,
GE does not accept this use of 100$ Aroclor 1242 in transformers.
GE'wlll not accept Aroclor 1242 or any other blend with less than a 1 to 1 ratio of chlorine to Hydrogen atoms. A ratio significantly lower than 1 to 1 tends to yield combustible arc-formed gasses. GE 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 contrast 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 ca^e of electrical 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 eco 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 polychlorinated hydrocarbon insecticides.
4. Research data being,developed seems to confirm incrimination of PCBs subject to^rechecking.
5. Public, political and government pressures stopping some uses of chlorinated hydrocarbon insecticides (PCHI).
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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 except that Dutch researchers found PCBs in roaches.
12. There is no evidence of natural sources of PCBs nor any source other than industrially produced and used.
13. PCBs in a single dose have a low order of acute toxicity and are no significant problem to rats, dogs, chickens, 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 affect rat reproduction, (10 ppm. apparent no effect levels).
16. Some PCBs affect leghorn chicken 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 effect. What is significant? Since 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 since 1940-45. Proper precautions were not always followed.
20. GE Company's use of PCBs as dielectric fluids, has been extremely favorable without illness throughout 40 years.
21. Monsanto Company is* convinced that analytical techniques and data from some laboratories investigating PCBs are reliable and that conclusions being formulated are valid.
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22. Monsanto Company has not run duplicate analysis on samples reported in the literature.
L. What GE Desires
1. GE seeks that Monsanto take no precipitous reaction to the PCB problem that would result in withdrawing supply of Aroclor 1254 or 1260 to GE.
2. The consensus is that no Suitable replacement for transformer askarel fluid is foreseen1.
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 could be adopted.
4. In reply to Monsanto's legal question whether with continued use of Aroclor 1254 and 1260 GE would assume sole and complete liability -- Mr. Raab answered. No.' To substantiate his reply, Mr. Raab cited case examples involving GE where damages were sought and collected, even though GE was only the third party. He further stated that any arrangement seeking to delegate and confine liability to GE relative to the PCB problem would be worthless.
5. GE seeks to know the magnitude and time of Aroclor price increase that would result if Monsanto discontinues sale of Aroclor for non-electrical uses, or if pollution control expenses warrant a price increase (as anticipated).
. * *c
6. GE seeks to send a letter to their plants and service shops and major users of transformer askarel, such as the utilities giving notice of the PCB problem and guidance about the most suitable controls,
7. In the case of GE service shops scattered throughout our country it is unrealistic that these people would assume any expense to return scrap to Monsanto.
The minimum we can expect is that Monsanto pay the freight charges, 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 can expect from service shops and many other users is to continue to dump in a land-fill andystop discarding into the sewers.
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II
8. GE realizes that Monsanto is caught between the explosiveness of arc-formed gasses problem and on the other hand the PCB pollution problem. Realizing possible unfavorable outcome of the arc-formed gas problem, GE desires to withhold the PCB problem from involvement at NEMA, ASTM, IEEE, EEI and ASIA at this time, (making it an industry-wide problem) pending better in-depth understanding of the PCB problem.
9. GE strongly seeks to continue manufacture of askarel type
transformers, because in many applications this apparatus
cannot be replaced with mineral oil nor open dry, nor seal
gas dry type units.
S
.
Mineral oil burns. Open dry accumulates dust, lint, moisture and can then fall with explosion and burning. Sealed gas dry types are very expensive, space consuming and very difficult to maintain sealed.
Transformer design and application is governed by National
Electric Code, by local building codes. Fire Underwriters, NEMA, IEEE, ASTM, IEC, ASA, Insurance companies and others. Because of the diversity of organizations involved a directive to discontinue askarel transformer manufacture would assume highly complex proportions.
P. G. Benignus January 26, 1970
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INFORMATION SOURCE
TYPE & LEVEL PCB REPORTED
ANALYTICAL TECH . NIQUES REPORTED
MATRIX-OF SPECIES ANAL. & LOCATION
.
O rganochlorine R esi
dues, O.E.C.D.
.
P re lim in a ry Study
1966-1967, Sweden,
G. W idm ark, U n iv .
o f Stockholm .
R( Ce
ported
l4 -C 18
)
as PCB
ppm
ch ro m a to g ra m s
s im ila r to A roclors
1254-1260.
EC/GC on QF-1 & SF-96 ' Sea E a g le , Salmon columns chem ical con & P ike . Sweden.
firm a tio n ; N itra tio n (m ild) & S u lfu ric a c id . e x t r a c t io n . Some GC/Mass c o n fir m a tio n .
(ju v .)
C hlorinated Hydro
carbons in B ritis h W ild life Nature 216,
227 (1 0 /2 1 /6 7 ), D.C.
Holmes, J .H . Simmons,
& J . 0 1G. T a tto n .
R e p o rte d as PCB
re s in s . Eludes to h ig h ly ch lo rin a te d
bl iigphh et lnyy lsc halnodr in
ated terphenyls
PPb.
EC/GC on S E-52, Apiezon S parrow haw ks, k e s t r e ls ,
L, & XE-60. Some T .L .C . g iu lle m o ts . A ls o
Sample c le a n up DMF/HEX d e te c te d s m a ll amounts
p a r t i t i o n fo llo w e d by in human & anim al f a t s .
L.C.C. (A lum ina).
U .K .
|i
O rganochlorine P e s ti cides in Seals &
P orpoises, Nature 216, 1274 (1 2 /3 0 /6 7 ), A.V.
H olden & K. M arsdea.
R e p o rte d as a p p a r
e n t PCB. No le v e l s ta te d ; chrom ato
grams s im ila r to
A roclors 1254
1260.
EC/GC on X E -6 0 , DC-
2 0 0 , & QF-1 . Samp!e
ct ilteiaonn
up DMF/HEX p a r sa p o n ifica
tio n .
- Seal & P orpoise F a t. B ri-tish coastal
.
w aters. 1 v
j
C h lo rin a te d Biphenyls
in F ish , M ussels, &
B ird s from the. Rhine
& the N etherlands
Coastal Area. Nature
.221, 1126 ( 3 /2 2 /6 9 ) ,
J .H . Koeman, M C. 1
TenN oluer DeBrauw, &
R.H. DeVos.
I.
I
i
.
R e p o rte d as PCB
EC/GC on DC-200. Samp
. . (to A ro c lo r 1260,
P h e n c h lo r DP6 &
Chlophen A60, ppfa-
plea
rctliet iaonn
up DMF/HEX
fo llo w e d by
L C.C F Iu o ris i1).
ppm. A lso r e
ported the pres
(C o n firm e d by GC/Mass CH4).
ence o f te tr a - &
p e n ta -c h l orobenzen.e
& of tric h lo ro -
biphenyl in a '
roach & e id e r .
sam ple, m ostly
c l4 ,5 -c l8*
.
Roach, g ro u n d lin g ,
m ussel, sand e e l, sandwich te rn , e id e r.
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I DSW 347912
STLCOPCB4085161
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TYPE & LEVEL
NFORMATION SOURCE " PCB REPORTED
ANALYTICAL TECHL NIOUES REPORTED
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chem ical tre a tm e n t;,
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STLCOPCB4085162
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TABLE 2
January 15, 1970
STATUS OF AROCLOR STUDIES
AT INDUSTRIAL BIO-TEST
Aroclor 1242* 2 * * * * * * * 10
2 year rat at 1, 10 and 10Q ppm:
At 90 days--possible liver enlargement. Males at 100 ppm. Histology O.K. Others O.K. Blood, urine.
2 year dog at 1, 10 and 100 ppm:
At 6 months--0.K. body weight, food consumption, reactions, mortality, hematology, blood chemistry and urine.
3 generation rat reproduction at 1, 10 and 100 ppm:
100 ppm--effect on survival-difficult to obtain pups for maturing and mating, egg production.
Chickens--egg production, hatchability, survival, etc.at 1, 10 and 100 ppm:
10 and 100 ppm levels effect hatchability. 1 ppm O.K.
Aroclor 1254
2 year rat at 1, 10 and 100 ppm:
At 90 days possible liver enlargement in males at 100 ppm. Histology O.K. Other levels O.K.
2 year dog at 1, 10 and 100 ppm:
I
At six months body weight effected at 100 ppm. Possibly less food consumption? Other levels O.K. Same parameters as 1242.
V DSW 347914
STLCOPCB4085163
-2-
Aroclor 1254 (Continued)
3 generation rat study at 1, 10 and 100 ppm:
100 ppm--effect on survival same as 1242.
Chlcken--egg production, hatchabllity, survival,
etc, at 1, 10 and 100 ppm:
.
10 ppm O.K. but 100 effects hatchability.
Aroclor 1260
J
2 year rat at 1, 10 and 100 ppm:
At 90 days--possible liver enlargement in males and females at 100 ppm. Other levels O.K.
2 year dogs at 1, 10 and 100 ppm:
At six months, body weight effect at 100 ppm, possibly at 10 ppm. One male and one female died--refused to eat. No other obvious reason for fatalities by gross examination.
3 generation rat study at 1, 10 and 100 ppm:
No adverse effects.
Chicken--egg production, hatchability, survival,
etc, at 1, 10 and 100 ppm:
.
No effect.
y
5^ 347915
STLCOPCB4085164
2-year rat chronic At 1, 10, 100 ppm Statua 90 days
2-year dog chronic Status--6 months
3 generation rat reproduction
Chicken--Egg Production, Hatchability, Survival, etc.
1242
12^4
1260
100 ppm Liver enl.
Males 10 ppm '
O.K. "
100 ppm Liver enl.
Males 10 ppm
O.K.
100 ppm Liver enl.
M&F 10 ppm
O.K.
100 ppm O.K.
100 ppm affects
survival 10 ppm
O.K. 10 ppm affects hatch. 1 ppm
O.K.
100 ppm Body wt. dec. 10 ppm
O.K.
100 ppm affects survival 10 ppm
O.K.
100 ppm affects hatch. 10 ppm
O.K.
100 ppm 1M-1F
died refused food- no other gross atm. 10 ppm Possible body wt. effect
100 ppm O.K.
100 ppm O.K.
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STLCOPCB4085165
TABLE 3
LOCATION OP ASKAREL TRANSFORMERS
(ESTIMATES BY E. L. RAAB (GE) AND P. G. BENIGNUS)
_.
TYPE INSTALLATIONS
INSTALLED 1969 ~ PERCENT POUNDS ASKAREL OP TOTAL
.
CinO
1) Industrial Load centers, mainly indoor, including welding transformers
11,800,000
2) Utility substations
1,200,000
3) Utility Net Works
a) Below streets and side-walks,
in vaults
2,000,000
6$ 10f
b) Basements of buildings .
600,000
3$
*0 Shopping centers, schools, hospitals, office buildings, ship
docks, warehouses, airports,
high-rise, pad mounts
2,000,000
10f
5) Atomic power, space centers, radar power supplies, etc.
800,000
kf
6) Subway systems 7) Railroad Transformers 8) Electric Furnace Transformers 9) Instrument and measuring
Transformers 10) Rectifier Transformers
200,000 200,000 200,000
'200,000 400,000
1io
'&
1$
1$ 2f
ll) Mine, under and above ground units
200,000
If
12) Precipitation transformers
400,000 20,000,000 .
1 '--0
O
2f
General BreakDown
Indus trial Applications = `fr8f Utility and Commercial = 32$
.
DSW 347917
STLCOPCB4085166
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DSW 347918 STLCOPCB4085167