Document DDmgbXYo8enojYpyYqX337Gko
friday March 23, 1984
\
P a r t 111
Environmental Protection Agency
40 CFR Part 761 Polychlorinated Biphenyls (PCBs); Manufacture, Processing, Distribution In Commerce and Use Prohibitions; Use In Electrical Transformers; Advanced Notice of Proposed Rulemaking
NEV 0 3 6 9 3 2
11070
Federal Register / Vol. 40, No. 58 / Friday, March 23,1904 / Proposed Rules
ENVIRONMENTAL PROTECTION AGENCY
40 CPR Part 761 IOPTS 62036;TSH-fRL 2626- 7]
Polyehlorlnated Biphenyls (PCBs);
Manufacture, Processing! Distribution
In Commeroe and Use Prohibitions;
Use In Electrical Transformers
/
AGENCY: Environmental Protection Agency (EPA).
ACTION: Advance notice of proposed rulemaking. *______________________
SUMMARY: EPA Issued a final rule which was published In the Federal Register of
August 25,1982 (47 FR 37342) that,
among other provisions, authorised the Indefinite use of certain electrical transformers containing polychlorinated biphenyls (PCBs) (PCB Electrical Use Rule). Although EPA had knowledge
prior (o August 25,1982 of a major fire* related Incident In Binghamton, New York Involving e PCB-Transformer, EPA believed that fires involving this equipment were rare, Isolated incidents. Thus, EPA did not consider the risks *
posed from fires when EPA made Its determination that the continued use of electrical transformers containing PCBs
did not pose unreasonable risks to public health or the environment. ,
Recent information from a May 1983 fire-related Incident In San Francisco, California Involving a PCB-Transformer and a September 1963 fire-related event In Chicago, Illinois Involving a PCBTransformer has brought into question
EPA'a earlier assumption that firerelated events Involving PCB*
Transformers bra rare and Isolated occurrences.
The purposes of issuing this Advance Notice of Proposed Rulemaking (ANPR)
are to solicit data specific to the risks posed by fires involving electrical
transformers that contain PCBs and to solicit dale on mechanisms for mitigating or eliminating these risks. Depending upon the results of EPA'a analysts of these data, EPA may propose
further control measures on the use of (his equipment by October 1984.
d a t e s : Comments on the Issues raised In this Notice must be submitted by May 22,1984.
addresses: Comments should be submitted In triplicate to: TSCA Public Information Office (TS--793), Office of Toxic Substances, Environmental Protection Agency, Rm. E-108, 01M St.. SW., Washington, D.C. 20460.
Comments should Include the docket number OPTS-Q2035. Comments received in connection with this Notice
will be available for reviewing an d , court Invalidated this portion of Ihe rule,
copying from 6:00 a.m. to 4:00 p.m., ' - as well is a number of other provisions,
Monday through Friday, excluding
and remanded the rule to EPA for
holidays, In Rm. B-107, Environmental further action.
Protection Agency, 401M Street BW., ' A sa consequence of the October 1980
Washington, D.C.
decision, EPA undertook a number of
FOR FURTHER INFORMATION CONTACT ' rulemaking actions. The action relevant
Jack P. McCarthy, Director. TSCA
to Ihe rule which Is the subject of
Assistance Office (TS-799). Office of
today's ANPR was published In the
Toxic Substances, Environmental -
Federal Register or August 25,1982 (47
Protection Agency, Rm. E-543,~401 M St., TR 37342) (hereafter, PCB Electrical Use
SW., Washington, D.C. 20480, Toll free: ~Rule).Thlsxuleemendedthe.May31, '
(800-424-9065), In Washington, D.C.: ' 1879 rule. The August 1982 amendment,
(554-1404), Outside the USA: (Operator- among other provisions, authorized the
202-354-1404).
. . , continued use of PCB-Transformers
O U F g m m jT A R Y INFORMATION:
(electrical transformers containing
I. Backjround l
* greater than 500 parts per million (ppm PCBs) In facilities Involved In the
'^ f f f l o ^ i e j o f the Toxic Substances . . handling of food or feed Items until
Control Act (TSCA) generally prohibits October 1,1985, and, allowed the use of
the use of PCBs after January 1,2978.
all other categories of non-railroad
The etatute does, however, set forth two electrical transformers containing or
exceptions under which EPA mey, by contaminated with PCBs for the
rule, allow a particular use pf PCBs to remainder of their useful lives. In Its
continue. Under section 8(e)(2) of TSCA, . August 25,1982 decision, EPA made a
EPA may allow PCBs to be used In a
determination that authorizing the use of
"totally enclosed manner." A "totally Ihase transformers for the remainder of
enclosed manner" Is defined by TSCA . " their useful lives did nol present an
to be "eny manner which will ensure
unreasonable risk to public health or Ihe
that any exposure of human beings or ' environment for the following reasons:
the environment to a polychlorinated. ' 1. EPA determined that If It did not
biphenyl will be Insignificant, as
authorize the use of PCBs in
determined by the Administrator by
transformen, the costs to the public and
rule," TSCA also allows EPA to
. United Btates Industry would be billions
authorize the us of PCBs In a manner of dollars, primarily as a result of the
other than a totally enoloaed manner if disruption of electrical service. EPA
die Agency finds that the use "will not determined that the resulting reduction
resent an unreasonable risk of Injury to In risk would not outweigh these
ealth or Ihe environment "
substantial costs.
EPA promulgated a rule, which was
2. EPA determined that the Inspection
published In the Federal Register of May and maintenance programs required
31,1979 (44 FR 31514) to Implement
under the rule reasonably reduced the
sections 6(e) (2) end (31 of TSCA. Thle exposure risks associated with the use
rule Is listed In the Code of Federal - : of PCBs In PCB Transformers, and the
Rgulalions under 40 CFR Part 761. The servicing conditions prevented further*
rule; among other provisions, designated PCB contamination of transformers.
all Intact, nonleaking capacitors, .
3. EPA determined that releases of
electromagnets, and transformera, other PCBs to the environment end exposure
fiian railroad transformers, as "totally to humans and biological organisms
enclosed," thus permitting their use
from mineral oil transformers are
without specific authorizations or
minimal. EPA estimated that these
conditions. The Environmental Defense transformers contain less than 0.15
Fund (EDF) petitioned the U.S. Court of percent of all the PCBs used In
Appeals for the District of Columbia . transformers end release less than one-
Circuit to review a number of provisions half of a percent of these PCBs on an
of the rule, including the portlonof the annual basis.
rule that designated all fnlact and
4. EPA determined that Ihe costs
nonleaking capacitors, electromagnets, - associated with other risk reduction
and transformers as "totally enclosed." measures such as accelerated phase-out,
[Environmenial Defense Fund, nc. v. . reducing the PCB concentration In the
Environmental Protection Agency. 636 . dielectric fluid, or providing
F.2d 1287).
containment for transformers were not
On October 30,19B0, the court, among reasonable when compered to the
other things, decided that there was
potential reduction In release.of PCBs
Insufficient evidence In the record to
achieved.
support the Agency's classification of . In evaluating the risks posed by the
transformers, capacitors, and
continued use of electrical transformers
electromagnets as totally enclosed, The containing PCBs, EPA had considered .
NEV 0 3 6 9 3 3
Federal Register / Vol.'dQ, No. fifl / Friday March 23, 1664 / Proposed Rules
11071
the exposure resulting from leaks and polychlorinated dlbenzofurans in the | IL Transformer Fire Risks /
pills of PCB-containing dielectric fluid ductwork of the building.
as constituting the principal route of release of PCBs to the environment for this equipment.
There was however, on Indication that fires Involving transformers Ido
could be responsible for the release of PCBs. For example, on February & 1081, In the Binghamton Slate Offioe Building In Binghamton, New York, a PCS*
Transformer wet Involved In a (ire In
the basement of the building. Monitoring, completed after the fire,
Indicated the distribution of PCBs, polychlorinated dlbenzofurans, and polychlorinated dlbenzodioxlns throughout the interior of the building* The distribution of PCBs (and suapecled oxidation products) throughout the 18*
The Sen Francisco. Incident and en
even more recent incident in the First
A primary .source of Information on
National Bank Building In Chicago, Illinois in September 1063, have prompted EPA to consider reassessing Its earlier position on the'expected frequency of fire-elated Incidents
Involving transformer that contain PCBs.
This Advance Notice of Proposed Rulemaking (ANPR) Is the Agency's first
the causes of end circumstances surrounding fires Involving transformers containing PCB are data compiled from
three PCB-Transformer fires in Binghamton, New York; Son Frmnclao, California; and Chicago, Illinois. In order to understand better the risks posed by
the.use of this equipment In the event of
a fire. EPA has evaluated each of these incidents, and compared the
step In formally assessing the public
circumstances surrounding each fire In
health and environmental risks posed by order to determine what factors
fires Involving electrical transformers * Increased (be risks posed from the fire,
containing PCBs. If SPA determines that and what factor, If any, reduced the
the risks posed by fires Involving
risks presented by the fire.
transformers that contain PCBs gre-
EPA assumes that (he risks posed by a
story building occurred via two vertical sufficlently luge, when weighed against fire involving a PCB-Transformer are
ventilation shafts that ran the length of the benefits of this equipment and the related to the degree of dispersion of
the building and opened Into the
costs of control measures, then EPA will- - toxlo chemicals from the transformer
transformer vault In the basement At propose measures by October 1684 to Into areas where people may be present.
the time, however, EPA believed that
reduce or eliminate these risks.
Thus, EPA expects that PCB-
fires Involving transformers that contain The purpose of this ANPR, then, is to
PCBs wera rare, Isolated events. Thus, present certain available information on
although EPA made determinations that *-'.-the risks posed try fires Involving
the use of electrical transformers
.'-.Vansformers that contain PCBs, and, to
containing PCBs did not pose
unreasonable risks to public health or
the environment EPA did not directly consider the public health and environmental risks posed from fire* related events. EPA also did not
evaluate the cost of Implementing risk reduction measures to mitigate the risks posed by fires Involving this equipment or factor.Into Its economic assessment
solicit dste In five major areas: (l) The risks posed to human health and the environment In the event of a firerelated accident Involving anelectrical transformer containing PCBs: (2) the
probability of fire-related events occurring that involve electrical
transformers that contain PCBs, and factors that may Increase this
cerleto now-identified costs associated probability; (3) the reactions and ,
with the continued use of these
mechanisms of reactions involved In the
Transformer Dies in buildings or near buildings may pose greater risks than PCB-Transformer fires in locations such as outdoor electrical substations. The Agency further assumes that the greater the dispersion of contaminants within a
building, the greater the potential for exposure of humans to these contaminants, and therefore, the higher the risks. EPA has reached certain conclusions about the risks posed by transformer fires, based on these three
case studies.
The three incidents discussed below
are the three most well-characterized and well-researched Incident that EPA
transformers, principally, the high costs formation of PCDFs and polychlorinated is aware oL EPA Is soliciting similar of clean-up following these Incidents. . dlbenzodioxlns (PCDDs) in flre-rslated Information on other fire-related
These costs reduce the benefits
Incidents Involving electrical
Incidents Involving transformers
associated with the continued use of
transformers containing PCBs: (4) the ' containing PCBs. A partial list of other
these transformers.
costs and nature of the oost Incurred by less wpll-known and leas well-
After promulgation of the 1082 rule, the owner of a transformer involved in a researched incidents that EPA Is aware
additional Information came to EPA's attention that Indicated that PCBTransformer fires may occur more
fire-related event; end (5) the
of appears in Unit 1U.B. EPA Is soliciting
Identification of available options for
additional information on these
mitigating or eliminating the risks posed Incidents, as well as Information on
frequently then previously expected,
end that PCB-Transformer fire hazards
aro not restricted solely to transformers
located Inside buildings. On May 15, 19B3, In the One Market Plaza complex In San Francisco, California, a PCB*
Transformer was Involved In a smoky Iranaformer vault fire. Monitoring
completed after the fire Indicated the presence of PCBs and polychlorinated
dlbenzofurans IPCDFs] In soot from this fire, Although the vault housing the transformer was located exterior to the
building Itself, unsealed conduits from the vault to the baiBment and outside
air Intake venls drew the contaminated smoke Into the budding end allowed for
by fires Involving electrical transformer other Incidents not Included on this list
containing PCBs as well as the costs end l. Binghamton, New York. At 5:30 a.m.
benefits associated with those options. on February 5.1681, a fire occurred in
If EPA Is not provided with adequate
' data, especially In the areas of the risks posed In the event of a fire, the
probability of these fires occurring, and the costs associated with clean-up following these Incidents, EPA will make Its regulatory Judgments based upon the data set forth In this document
the switchgear adjacent to a PCBTransformer in the basement mechanical room of the Binghamton
State Office Building. This building is an 18-story office tower that was completed in 1673. Power to the building was supplied by two transformers which
contained a coolant fluid consisting o f 65 percent PCB (trade name Arod or
These data indicate that PCB-
1254) and 35 percent mixed tri- and
Transformer fires pose relatively high tetrachlorlnated benzenes.
risks, occur with unknown frequency
Although the city fire departments
and cen resultJn relatively high clean responded within minutes, they did not
up costs.
enter the mechanical room until the
the distribution of the PCBs end
power was disconnected to the
1 NV 0 3 6 9 3 ^
11072
Federal Register / Vol. 49, No. 58 / Friday, March 23, 1964 / Proposed Rules
transformeri approximately 60 minutes found 697 ppm total tetra-chlorfnated
mall cracks In the concrete block vault
after the fire started, During this period, dlbenzofuran, 48 ppm 2,3,7,6-TCDF, 1.8 `walls"). Some of the heavy emoke Issuing
there wee repeated electrical arcing and ppm total tetra chlorinated
from the sidewalk grating was
reports of loud explosions occurring In dibeneodloxlni, and 1.2 ppm 2,3,7,8-
apparently pulled Into the building
the mechanical room. Smoke generated TCDD. Congener specific analysis of a through street level air makeup louvers
by the fire was distributed by
different Binghamton soot sample found and into the ventilating fans that supply
convection throughout the building
2,3,7,8 substituted constituents to be the air through the sub-basement, basement,
through an open vertical shaft that
most predominant congeners within
plaza level, and floors 2 through 6 of the
started in the mechanical room and ran each of the levels of chlorination of both Steuart Street office tower. Tests later
to the penthouse. Thla concrete block
PCDFs and PCDDs. Additional f ampllng Indicated that the contamination was
shaft contained the sheet metal duct for data on PCB, PCDF and PCDD levels
limited to thebesement, the air handling
the exhaust air from the men's
found following the Binghamton fire, as system through floor 6; and the exterior
restrooms on all the floor*. The shaft
well as additional Information on the
of the building. The upper floors of the
was not air tight and allowed imoka to circumstances surrounding this Incident 8leuart Street Tower receive air from
escape the space between the structural are presented In tha Verier report,
ventilating fans mounted In a penthouse
celling and the suspended celling on
"Exposure Assessment; Fires Involving above the 26th floor.
etch floor of the building. A* a result the entire inside of the building wea coated with black soot.
PCB Transformers" (Ref. 1).
Air samples taken in the vault starling
The Binghamton State Office Building a week after the fire measured 320 to
remains closed to normal use. The
1500 micrograms per cubic meter PCBs,
The probable source of the soot was building has been extensively cleaned depending on the rale of ventilation
combustion of the materials in the
by vacuuming and washing to remove through the vault. (Ambient levels of
switch gear. The heat of the Are
the coot. Analysis of air samples, wipe PCBs In the atmosphere have been
apparently ceused a ceramic bushing to samples from vinyl walls, and Bulk
measured and range from about 0.1 to 9
crack on one of the transformers,
aamplea of sprayed-on calling Insulation ninogram* per cubic meter.) The switch
allowing approximately 160 gallons of have demonstrated that the ratio of the Sear room adjacent to the vault had air
Insulating liquid to drain onto the floor various toxic constituents Is not
concentration as high as 88 mtcrograms
In the vicinity of the fire. Photograph* constant from one matrix to another,
per cubic meter before ventilation was
taken shortly after the Are was '
and that the vaporization and
started. The 8en Francisco Department
extinguished showed that the switch ** ndeposltlon processes are causing a ofPublic Health restricted access to any
gear was completely destroyed, but
gradual redistribution of the material
area having a level of PCBs in the air In
there was little damage to the
within tha building. Estimates of clean excess of i microgram per cubic meter,
transformera?The mechanlcalroom was up costs to date are between $16 end
or surface contamination in excess of 1
heavily coated with soot and puddles of $20 million.
microgram PCBs psr 100 square
liquid remained on the floor. The heat
2. San Francisco,.California. Shortly centimeters when sampled by wiping
from the fire wee sufficient to damage after li:Ao a.m. on May 16,1883, a fire with a cloth wetted with octane.
slightly a structural steel beam that was started in the tub-basement transformer Although no samples collected In the
directly over the switch gear. However, vault of the One Market Plaza office
offices on floors 2 through 6 were
the fire apparently did not spread to any building complex et the comer o f .
contaminated above these levels, the
material other then the switch gear
Steuart and Mission 8treels in 8an
city requested that the ventilation
Itself.
Francisco, The vault contained three
system not be operated because of the
Elevated leveli of PCDFs In the t o o t ' transformer that were filled with
possibility of spreading contamination,
ware reported within a week after the Aroclor 1242 coolant liquid. Heavy black to these dean areas. Without
fire. Comprehensive analyses of tha soot emoke Issued from the sidewalk grating ventilation, these floors could not be
were performed by Dr. David Stalling of adjacent to tha building for about three ' occupied.
the'U.S. Fish and Wildlife Service,
hours until the high voltage power to the Analysis of the soot collected in the
Columbia, Missouri, by Dr. Christopher transformer was interrupted by the
transformer vault and in the sub-
Rappe of the University of Umea In
utility. During thle three-hour period,
basement adjacent to the wall of the
Sweden, and by Dr, Pat O'Keefe of the there was considerable vibration and
transformer vault showed the presence
New York State Department of Health loud noises accurrlng In the vault that of PCBs, TCDFs, and TCDDs. A loot
Laboratories. These analyses reported were described by reporters at the soene ample token adjacent to the vault
the presence of PCDDs, PCDFs and
as "explosions" No Information Is
showed the preaence of 88,000 ppm
polychlorinated blphenylenes (PCBPs). available an the size of the
PCBs, 26.0 ppm total TCDFs (6,3 ppm 2,
although the amount! found varied frofti transformers, but it was reported that 3 ,7 ,8-TCDF), and 0.324 ppm TODD
sample to sample. Initial analyses of
only one transformer leaked, and th at' (0.059 ppm 2,3,7,8-TCDD). Additional
two soot samples by Smith et o l (Ref. 1) after the fire there were 60 to 60 gallone sampling date on PCB. PCDF, and PCDD
reported the preaence of 2.6 and 2.8 ppm of liquid In the vault, with the floor and levels found as a result of the San
2.3.7.6- letracfilorodlbenzo-p'dIpxln
walls of the vault caked with black soot Francisco tire ere presented tn the
(2,3,7,8-TCDD] and 124 ana 279 ppm
and liquids dripping from the vault
Versar report (Ref. 1).
2.3.7.6- telrachiorodlbenzofuren (2.3,7,6- celling. The liquid remaining In tha -
The available reports on the
TCDFJ. A more detailed analysis of a
transformer contained 0.127 ppm
analytical results from One Market
homogenized mixture of soot taken from tetrachlorodtbenzofuren (TCDF) and no Plaza do not specify the analytical
throughout the building and used.ln
detectable lelrachlorodlbenzo-p-dloxln procedures nor, tn most cates, the
animal feeding studies contained 7,200 (TCDD).
*.
detection limits of the procedures used.
ppm PCBs and the following
Smoke and soot from the transformer However, from a comparison of
concentrations of various homologs of vault contaminated the adjacent switch available information on the conlents of
PCDF; tetra-16 ppm, penta*21 ppm, hex- gear room (through the bus duct) and
the transformer and the amount of fluid
2 ppm, hepta-3.5 ppm, and ocla-0.74
small areas of the adjacent parking '
pilled, and the levels of contaminants
ppm. Analysis of a single soot sample garage end workshop areas (through
measured, It Is apparent that the
NEW 0 3 6 9 3 5
"V s*-
Federal Register / Vol. 49, No. SB / Friday, March 23, 1984 / Proposed Rules
11073
conversion of PCBs to PCDFs occurred exhaust system, and the exterior of the. * Dawley rats; (2) the Van Millar et a i. -
with about the same efficiency in both mall building next to the vault
(1977) atiidy In male Sprague Dawley
-Binghamton end San Francisco. Estimate or dean>up oosts to date
B , Conclusions Based on Case Studies
rats; (3) the Toth et a i (1979J study in Swiss mice; (4) the National Cancer
(provided by the Pacific Gas and
Bated upon EPA'e valuation of the . Institute (1980 a, b) studies (n rats and
Electric Company}ere between tlB and circumstance* turro onding the
mice: (5) the Pjtot et a i (1980) promotion
$20 million. .
Binghamton, New York; 8an Francisco. study In rats; and (8) the Kouri et a i
3. Chicago, Illinois. On September 28, California; and Chicago, Alile Area,
(1978) cocarcinogenlclty.study in mice
less, a fire occurred In a bus bar
EPA believes that Are Involving PCB* - (ReF.J).
..
between a PCB-Trsnsformer and the
Transformer preee&t certain rlaks o f.
Inaummaty, oocordlng to the
twitch gear In a transformer vault under exposure of humans and the
September I960 CAGriek assessment
the plaza on the tame block a i the Flret environment to toxic contaminants such * (Ref. 3), carcinogenic responses have
NfeUonal Bank Building in Chicago,
as volatilized PCBe and certain
Illinois. Although power to the
oxidation products of PCBs. including
transformer was cut after about 10
PCDF.
minutes, smoke continued to Issue from . 1. Toxicity o fPCBs and oxidation
the sidewalk grating for about 4S
products found in soot In earlier
minutes. Inspection of the transfoitnen rulemakings, EPA h t i already
after the Bra wae extinguished indicated concluded diet, based upon available
that one of the four transformer* In the information, persons exposed to PCBs
vault bad leaked approximately IB
can develop chloncne;.*nd, that bated
gallons of coolant consisting of 85
on animal data, there Is a potential for
percent Aroclor and 35 percent .
reproductive effects and developmental
chlorinated benzenes, The source of the toxicity ae well as oncogenicity in
leak was a small hole (n the transformer humane exposed to PCBs. Although the
casing that was possibly caused by effects of cnloracne are reversible, EPA
electrical arcing.
does not consider this effect of exposure
Significant PCB contamination w*{ - to PCB to be Insignificant (Ref. 2).
limited to the vault, the exhaust air , According to the September 12,1880
ducts from the vault, and to the exterior Carcinogenic Aeseeament Group's
surfaces of e small building adjacent to (CAG's) Risk Assessment on 2,3,7,8-
the transformer vent. The highest
TCDD (Ref. B], guaged by results of
readings outside the vault and its
toxicity testing in animis for a variety
exhaust system were on a window near of effects, 2.3,7.8-TCDD is one of the
the vault (437 mlcrograme per 100 square most toxic chemicals known. Hits
centimeters) end on an Intake air well substance was found in soot samples
grille (752 mlcroerams per 100 square
taken following the Binghamton enditan
centimeters) ana window (308
Francisco transformer Ares. LD* values
micrograms per 100 square centimeters). of 2.3,7,8-TCDD range from 0.0
The transformer vault was adjacent to mlcrograme per kilogram orally lor the
an underground perking garage and
male guinea pig to 27&mlcrograme per
shared a ventilating avstem with the
kilogram dermally for the rabbit, which
garage and a small adjacent building;
would classify this compound as
been induced In mice and rale at very low dosea of 2&7.8-7CDD. (n addition, 2,R7<0*TCDDhas been ihown to be a very potent cancer promoter. These results, together with suggestive evidence In epidemiologic studies, constitute substantial evidence that 2,3,/,8-TCDD le likely to be a human carcinogen. In addition, on the basis of s Dow Chemical Company study on 2.3.7.8- TCDD, it appears that 2,3.7,8-
TCDD Is a more potent carcinogen than afl&toxbi Bi. which le one of the moet
potent carcinogens known (Ref. 3).
Toxicological testing of
polychlorinated dibenzofurans (PCDFs) has been more Untied than testing of 2.3.7.9- TCDD. However, In a study designed to evaluate the comparative toxicity of PCBs and PCDFs, in rets, PCDFs were found t be more toxic than
PCBs [Ref. 5). In particular, the results of title study Indicate that PCDFs produced severe toxic effecte on hematologic and thymic function!, to rats fed diets containing polychlorinated dibenzofurani, severe reduction In erythrocyte counts, hematocrit, and hemoglobin concentration occurred, and blood imears Indicated hemolytic
however, none of these areas was heavily contaminated.
supertoxic (Ref. 4). (The scale of acute anemia. toxicity ranges from practically nontoxic Following the Binghamton fire, several
The First National Bank Building,
to supertoxic.) Deaths typically occur
researcher completed toxicological
about one-half block from the vault, was about one week or more offer treatment. testing of soot samples to guinea pigs,
not contaminated. Although one
In chronic and acute oral 2,3,7,8-TCDD Based on these studies using
fiberglass Alter on en air intake vent on toxicity studies on several animal
Binghamton State Office Building
the fourth floor of the Flret National
species, the liver, thymus, and spleen
(BSOB) soot. EPA has concluded that .
Bank Building was found to contain
have consistently been the target
multiple exposures to soot from PCB-
about 80 ppm PCBe, nearby Alters did organs. Liver damage, including necrotic Transformer Ares have the potential to
not show high levels. The building was end degenerative changes, lipid
product toxicity In the thymus, the
evacuated when emoke was seen
accumulation, and Increased liver
hematopoietic system, the salivary
coming from a window vent; however the smoke wee later IdentlAed ae the
Bweight have been observed In mice, rats, land duct epithelial and, possibly, the
and guinea pigs following 2,3.7,8-TCDD ver (Ref. 8k
exhaust from an auxiliary diesel
treatment. Atrophy of the thymus and
It Is worth noting that thymic atrophy,
generator that started when power was pleen has also consistently been found bone marrow depletion, and diminished
shut off to the transformers.
In laboratory animals. Other effects of body weight gato, all effects of the
No analyses were reported for PCDFs 2,3,7,8-TCDD Ingestion Include
eubchronlc administration of the BSOB
or PCDDa In the soot. A number of wipe suppression of reproductive function In soot have been routinely demonstrated
samples were collected in the First
rate and disturbances of the
to acute studies to guinea pigs using
National Bank Building and from the air hematopoietic system with occasional PCDFs end PCDDs (Ref. 8). In addition,
supply Intake near the transformer, but hemorrhaging in monkeys, rats, and
the group of guinea pigs dosed with
no PCDFs or PCDDs were found.
mice (Ref. 3).
231.1 ppm BSOB soot In he subchronic
The First National Bank Building wae . There are several cancer bloassay
study exhibited symptoms characteristic
evacuated at the time of the Are, but
studies of 2,3,7,8-TCDD: (1) A Dow
of ecute exposure to 2,9,7.8-TCDD and
reoccupted the following day. Cleaning Chemical Company sludy[Koclba et a h 2,3,7,8-TCDF which Include skeletal
was limited to the transformer vault. Its' 3978) in male and female Sprague
muscle degeneration, fatty changes In
NEV 0 3 6 9 3 6
11074
Federal Register / Vol. 49, No. 59 / Friday, March 23, 1984 / Proposed Rules
hepalocytes, end degeneration of
temperature. That Is, the fact that less from the oxidation of chlorobenzenes.
gastrointestinal tract epithelium (Ref. 61. PCB Is present means only that less total The low level PCDDs found following
One paper Hated that the oral U)Mof PCDF will be formed since low
the San Francisco fire could have been
the BSOB soot In guinea pigi Is 410
concentrations alone are not expected to associated wllh the possible presence of
milligram per kilogram body weight
have any effect on ihe reaction rate,
low concentrations o chlorobenzenes In
(Ref. 6), which would classify this
mechanism of reaction, or product yield. the fluid, from past servicing operations.
compound as vey toxtc (Ref. 4),
There also appear to ba few factors
Information Is not eveilqble on the
2. Discussion o fformation o f
present In an uncontrolled fire situation products'resulting from pyrotyztng
oxidation products from PCBs. There Is which would cause the total destruction chlorobenzene In commercial uses of
direct evidence of the fomiatlon of PCDF* and PCDDs from heating and '
of PCBs and PCDFs or which would present other competing reactions to
PCBs,'al different temperatures. In the .range expected to be formed In
burning commercial mixtures ol PCBs and diluents. The direct evidence 1 from: 11) Laboratory experiments
fmbllihed in chemical and other
Iteralure, and (2] chemical analyses of
materials at the sites where fires were known to Involve transformers that contained PCBs. PCBs, PCDFs, and . PCDDs were all-found In some soot
specimens from both the Binghamton and San Francisco fires. (PCDFs and
PCDDs were not analysed for in the tool from the Chicago fire.)
Laboratory studies provide the best available Information on the conversion of pare PCBs to PCDF*. In these studies, a number of different PCD congnere ;
and mixtures of congeners have been -, heated and the resulting materials analysed for all PCDFs and PCDDs.
Since a specific PCB compound reacts to form a limited number of PCDFs, the
formation of PCDFe Involve Intramolecular elimination of three
kinds of diatomic molecules, wllh or without some rearrangement of chlorine. atoms on the remaining phenyl rings. From the producti obtained In the PCB
reactions, the diatomic molecules, hvdrogen, hydrogen chloride, and
chlorine, are formed from one hydrogen and/or chlorine atom In ortho positions
on each of the two phenyl rings. The optimum temperature range for the published laboratory experiments was
600*C. Yields of PCDFs are In the percent range from 550*C to 600'C, but
drop off to tenths of a percent at 500*C andOWC. `
The description and characterization of the chemical reactions occurring In a
reduce the yield of PCDFs. An uncontrolled Are of sufficient
temperature (about 600*C) to bum materials containing PCBs can result In the formation of PCDFs as large as a ^ percentage of the level ot PCBs originally present In the material.
Concentrations would vary with the volume of contained combustion gases
or constituents of material containing articulate combustion solids. Although
igh temperature Incineration (i used to dispose of PCBs In oil, PCDFs and
PCDDs have also been delected following the lnctneratlon of PCBs In oil.
Incineration of PCBs requires at IZOO'C temperature, a two-second residence time, and sufficient oxygen, As explained above, however, laboratory
experiments Indicate that the reaction
temperature for the formation of PCDFs Is optimized at around 600*C.
Commercial mixtures of PCBs frequently contain mixtures of chlorobenzenes as well as PCBs. Even "pure" PCB mBy have low concentrations of chlorobenzenes
resent as contaminants. Experiments ave shown the formation of PCDFs and PCDDs from pyrolysis of mixtures of
chlorobenzenes In air. Other chlorinated compounds Including chlorophenols were also formed. Amounts of PCDFs ranged as high as tenths of a percent for
mixtures of trichlorobenzenss. Tetra* and pentachloro-benzene mixture* ' formed amounts of PCDFs and PCDDs which were two orders of magnitude smaller then the amounts of these compounds formed by trichlorobenzene. PCDF* and PCDDs may also be formed
uncontrolled burning.- ** *'
With respect to possible burning or
heating of commercial PCB mixtures at low concentrations In mineral oil, the
flash point and fire point of the oil might Increase Ihe chances o having a fire start, and, once an Oil Are starts, It Is not unexpected that such a fire would provide suitable reaction conditions for producing PCDFs and PCDDs (if chlorobenzenes arepresent) from 1 commercial PCBs. The flash points and
fire points of both mineral oil and silicone oil could permit the heating of dlssolved.or dispersed PCBs to
temperatures comparable to the temperatures used In published studies
of these reactions. Thus, EPA expects that mineral oil equipment and other types of equipment contaminated with PCBs may etso pose certain risks In the event of a fire from the perspective of the formation of toxic pyrolysis producti.
Compared to mineral oil, the lower flesh point and fire point of silicone oile (a potential substitua fluid for
retrofllltng PCB Transformers) might reduce the chances of hsvlng a fire start. But, once a silicone oil fire Harts, It li not unexpected that such a fire would' also provide suitable reaction conditions for producing PCDFs and PCDDs (when chlorobenzenes are present) from commercial mixtures of PCBs present In the transformers at low concentrations.
EPA Is soliciting Information concerning the Identification and
quantitation of residual chlorinated aromatic hydrocarbons, resulting from
fire In which aroclors (or any other commercial mixtures qf many PCB
from the chlorinated phenols observed exposure to open flame burning of In the pyrolysis of chlorinated benzenes. commercial formulations of transformer
compounds) are burned Is far more complex than the laboratory experiments. However, the same reactions observed In the laboratory
The reactions to form PCDFe and
PCDDs are blmolecular and the experimental concentrations of
chlorobenzenes were high. The reduced
fluids containing PCBs and other
chlorinated aromalie hydrocarbons. EPA 1b also soliciting Information on conditions actually present In
should also occur In fire situations
concentration of chlorobenzene as a
transformer locations, other than open
where the reactants and reaction
contaminant In commercial uses of PCBs flames, that can lead to the formation of
conditions are similar to laboratory
would probably not lead a substantial residual chlorinated aromatic
reaction conditions. Since the laboratory Increases In the amounts of PCDFs and hydrocarbons. EPA Is aleo soliciting
reaction that results In the formation of PCDDs formed from burning or heating Information on substitute fluids and the
PCDFs from PCBs Is Intramolecular end the PCBs. The notable exceptions are
chemical residues present following
an elimination, the effect of lower
commercial materials using
burning of.these materials.
concentrations of PCBs (such as those chlorobenzenes as a solvent for
3. Populations at risk from PCB-
present In mineral oil transformers)
concentrated PCBs, f.e., askarels. EPA Transformerfires. From Its analysis of
should have a minimal effect on the
. believes that the PCDD levels found In the three fires In Binghamton, Stn
reaction rate or product yield at a given ' the Binghamton soot samples resulted Francisco, and Chicago, EPA has
NEV 0 3 6 9 3 7
Federal Register / Vol. 49, No. 58 / Friday, March 23.1984 / Proposed Rules
11075
identified lix populations that may be at buildings that when they occur in
types of buildings. Fires involving PCB*
risk in the jevent of a fire Involving PCB- ' outdoor locations such as electrical
Transformers at Industrial facilities may
Transformers. The first group'are
substations. From this preliminary
pose lesser risks, because fewer persona
persons present In a building or possibly analysis. H also appears that he of the are generally present, and EPA expects
In an adjacent building at the time of a primary factors that contribute to the
that these transformers are often in
fire. The second group are firemen end risks posed by fires Involving'
places that are more open, where any
other emergency response personnel
transformers that contain PCBs In
malfunctions would be rapidly
responding to the fire. The third group buildings In the presence of ventilation Identified. EPA solicits comments on the
are onlookers present during the
ahafts or ductwork In the vicinity of a
relative risks posed by transformers
extinguishing of the fire, and the fourth transformer that is Involved in a fire. In located in office buildings, shopping
group are persons Involved In the clean' both Binghamton and Ban Francisco,
malls, hotels and motels versus
up following the fire. The final two
ventilation equipment or ductwork in
transformers located In Industrial
B i are persons returning to the ng following clean-up, and,
persons exposed to equipment, automobiles, eto. that may have been
the vicinity of the transformers significantly contributed to the
dispersion of PCBs and oertaln oxidation products, Including PCDD and
facilities or electrical substations.
Finally, EPA believes thal there Is one other factor that may increase the risks posed by PCB-Transformer fires. This
contaminated during the fire.
PCDF into the building.
In addition to thase Incidents posing
A second factor that appears to
eertsln risks to persons present In or
increase the risks posed by fires
around buildings Involved In these fires, Involving PCB'Transformers is the
EPA believes that these Incidents may failure of protective devices such os
also pose risks to other populations and circuit breakers to interrupt the flow of
to the environment. Specifically,
electricity into a transformer. In both
depending upon the location end
Binghamton and Ban Francisco, there is
frequency of these Incidents, EPA
evidence that suggests that power
believes that the discharge of
continued to be provided to these
contaminated water [used to contain
transformers for some time after the
these fires) containing PCBs, PGOFs, and Initial malfunction. There Is speculation
PCDDi Into the water system could pcfiq; that this factor contributed to the
certain risks to other population groups formation of additional toxic pyrolysis ^
as well. EPA Is specifically soliciting
products, by creating excess neat and
data on the risks posed to humans and other conditions conducive to the
the environment from the discharge of formation of these oxidation products.
water used to contain these fires. EPA
A third factor that appears to Increase
solicits Information on other potential the risks posed by fires Involving PCB*
populations that may be at risk In the Transformers if firemen being unaware
event of a fire Involving a transformer thal they are responding to t fire'
that contains PCBs.
involving a PCB-Transformer. In both '
f Potentialfor exposure to PCBs and Binghamton and San Francisco, there li
oxidation products from fire,
evidence to suggest that the firemen
Monitoring for PCBs, PCDFs and/or
who Initially responded to the fires were
PCDDs was completed after the
not aware met PCB-Transformer were
February S. 1901 Binghamton fire, the
Involved. Thus, these firemen may not
May IS, 1933 San Francisco fire, and the have followed certain precautions that
September 29,1883 Chicago fire. PCB
might be considered to be appropriate
contamination was found In all three
given the potential risks posed in.the
incidents, and PCDFs end PCDDs were course of extinguishing such a fire. For
Identified In soot samples from both the example, filmed accounts of the Ban
Binghamton and San Francisco fires [see Francisco fire indicate that heavy black
Unit II.A. for summary of sampling
smoke poured out of the underground
data).
sidewalk vault bousing the PCB*
Sampling data accumulated following Transformers. These same filmed
the Binghamton fire clearly indicates the accounts Indicate that respiratory
potential for exposure to PCBs, PCDFs, protection was not used by firemen
end PCDDs by firemen, building
present above the transformer vault
occupants, and others In the vicinity of a during their response to the fire. Further,
PCB-Transformer fire. Sampling from the * these filmed accounts also indicate the
San Francisco fire also supports a.
presence of several similarly '
determination that PCB-Tranaformer
unprotected civilian onlookers In the
fires pose certain risks of exposure to ' area during the extinguishing of the fire.
PCUtr, PCDFs. and PCDDs. '
A related factor that may be relevant
EPA solicits additional data on PCB, to the degree of risk posed by fires
factor Is the lack of knowledge on the part of many persons. Including firemen and other emergency response personnel, State and local authorities, and parsons occupying these buildings about ihe potential risks posed in the event of a fire involving transformers that contain PCBs. In BlnghamtonVSan Francisco, and Chicago, tittle structural damage occurred to the buildings as a result of these fires. For the most part,'
damage was limited to smoke damage. In these cases, a conscious decision wes made by authorities at the scene to analyze for the presence of PCBs and
certain oxidation products before allowing re-oocupency. Without this decision on the pari of authorities present at the scene of other similar fires, It is possible that these other .buildings may have been prematurely re-opened for occupancy.
Part of the reason for this general lack
of knowledge about the risks posed In
fte event ofPCB'Transformer fires may be the lack of coordinated effort to
accumulate Information on similar fires when they occur. Currently, there Is no EPA requirement that fires Involving PCB-Transformer be reported to the
Agency. EPA solicits comments on the. benefits of maintaining an EPA PCB* Transformer Fire Reporting system as well as comments on other mechanisms
for Informing people of Ihe hazards posed by these Incidents.
EPA plso solicits Information horn knowledgeable parties on Its analysis of what factors Increase the risks posed by fires Involving PCB-Transformers as well'as comments on other factors present during the Binghamton, Ban Francisco, and Chicago fires (or other fires] that may have Increased Ihe risks posed by these fires. -
PCDF, and PCDD levels measured
Involving PCB-Transformer is the type
0. Factors that appear to have
following PCB-Tranformer fires.
of building In which the transformer Is decreased the risks posed by fire, EPA
8. Factors that appear to increase
located. EPA believes that PCB*
believes that other factors may exist
risks posed by fires. From EPA*s
Transformer fires In office buildings and that, in contrast to the factors listed
preliminary analysts, It appears that
shopping malts may pose greater risk* to above, limit the risks posed by PCB-
PCB'Transformer fires may pose high the public, because of the concentration Transformer fires. That Is, although the
risks when they occur near or Inside
of people normally present in these
`Binghamton and Sen Francisco firtfk are
\_
NEV 036938
11078________ Federal Register / Vol. 49. No. 56 / Friday, March 23. 1984 / Proposed Rules
considered to pose certeln risks, both of III. Procbability of Fires Occurring these Incidents had the potential to pose | Involvilni g Tnnefoimen That Contain
5much greater risks. For example, one jjPCBt--
these sites are office buildings, 13 ere hopping malls, 5 are Industrial
facilities, and 3 are hotels or motels.
factor that limited the risks associated 1 with the fires In Binghamton and San Francisco was the time of the Bros. Both fires occurred during periods when these buildings were, for the most part, unoccupied. In contrast, the Chicago fire, in September 1983 occurred In the First
National Bank-Building during a period
of high occupancy. However, In this Incident, power'to the transformer was
A. The Number and Location o f Transformers Containing PCB's
1. Data'contained in (he August 25, 1982 rulemaking record. Transformers . re used extensively by electric utilities and other Industries to transmit and distribute electric power efficiently. * Some transformers designed for use with PCBs contain between 60 and 70 percent PCBs; others, designed to
cul after about ten minutes. In
contain mineral oil dielectric fluid are
Binghamton and San Francisco, the
contaminated with PCBs from past ~
transformers remained energized for 50 servicing and manufacturing activities.
minutes and three hours, respectively.
An estimate of the number of utility
EPA Is solictlng informotionon other factors that may have mitigated the risks posed by Ares Involving PCB-,.. . Transformers.
C. Cieon-Up Costs Following PCB
. owned PCB-Transformers was -previously provided to EPA via an
Edison Electric Institute and Utilities and Solid Waste Advisory Group (EEl/.
USWAG) survey of the utility industry. These data were presented in tabular
Transformer Fires
form in the Proposed PCB Electrical Use
Given the well-established toxicity of
PCBs, and the presence of materials that are more toxic than PCBs In the soot'*.'/ from a fire Involving a PCB-Tranaformeif, owner of PCB-Transformers Involved In PCB-Transformer fires have Invested up
Rule, published In the Federal Register of April 22,1982 (47 FR17426). In tho : August 25,1682, PCB Electrical Use
Rule, EPA used these data, in combination with existing data from an earlier rulemaking to estimate the total number of PCB-Transformers In service
Over 00 percent of the PCBTransformers listed In this limited survey are owned by utilities (Ref. 6).
EPA believes that the estimates of the number of in-service PCB-Transformers used in the August 25,1982 rule ere still valid today. However, In order to
evaluate fully )he hazards posed by fires
*involving transformers containing PCBs,' EPA needs more detailed Information on PCB-Transformers. The data needed Include data on: II) The types.of buildingsIn which PCB-Transformers are used, (2) the number of PCB* "Transformers used in each building, (3) the ages of the transformers, (4) the ages of the buildings, (5) the location of the PCB-Transformers serving the buildings, nd (6) the ownership of the PCBTransformers. EPA solicits Information from other building owners similar to that provided by Equitable Life Assurance, as well as from Slate and local 'municipalities.
EPA alto solicits Information on the costs of requiring PCB-IVansformer
owners to report to EPA the number and locations of PCB-TYsnsformers.
to S20 million each to ensure the safety of persons returning to occupy these buildings. For a full analysts of .
measures taken aa part of the clean-up of the Binghamton fire, see 'The Binghamton State Office Building Clean up: a Progress Report Update, 1983" (Ref. 7), end "Investigation of the Contamination Remaining In the
Binghamton State Office Building Following Completion of Preliminary
Clean-up, October 20,1982" (Ref. 8).. These costs, for the clean-up and removal of contaminated material containing PCBs, PCDFs, and PCDDs
found after these Incidents can be factored Into the economic analysis of the benefits of the continued use of PCB* Transformers. Earlier analyses of the
and to estimate the distribution of these transformers among utility and non-. utility owners.
In the August 25,1982 PCB Electrical Usa Rule, EPA estimated that the utility
Industry owned approximately 89,000 Inservice PCB-Transformen. EPA estimated that 22,469 of these transformers are located In non- ' substation locations, such as In and around buildings and Industrial facilities. The 39,000 transformer represent about one-third of all PCB-
Transformera In service. EPA estimated that about 90,000 PCB-Transformets are
non-utility owned transformers. EPA also estimated that there are over 20 million mineral oil transformers In the electrical utility industry and about five million in all other applications. These
B. ResultsFrom a Survey o f BPA Regional Office*
In October 1963, EPA conducted a telephone survey of Us regional offices across the United States In an attempt to obtain additional Information on the frequency of fire-related events involving transformers that contain PCBs (Ref. 10). Fh>m this Informal survey, EPA learned that In the period from February 1981 through September ' 1983, there were at least 15 fire-related Incidents Involving transformers that contained PCBs (this includes the Binghamton fire, the San Francisoo fire, and the Chicago fire).
EPA uses the term "fire-related Incident or event" because In many cases It Is not clear whether an actual
benefits or the continued use of these
mineral oil transformers may contain
fire occurred In the vicinity of the
transformers, completed In support of relatively low level PCBs (less than 500 transformer. However, there eppeara to
ithe August 25,1882 PCB Electrical Use >pmPCBs) as a result of contamination be a full spectrum of fire-related events
Rule, did not take Into consideration the rom past servicing activities.
that can occur In the vicinity of a
costs of clean-up In the event of a PCB-
2. New information on PCB-
transformer. EPA believes that minor
Transformer fire1.
Transformers, In late September 19B3, a arcing with no apparent volatilization of
In Unit V of this Notice, EPA hae presented preliminary estimates of the costs of clean-up In combination with estimates of the probability of such an occurrence, and preliminary estimates of the costs of various control measures designed to mitigate or eliminate the risks posed by PCB-Transformer fires.
major building owner In the United t States..the Equitable Life Assurance Society of the United States (Equitable Life Assurance), approsched EPA with Information on PCB-Transformen
present In its buildings. The survey conducted by Equitable Life Assurance Indicates that of the over 500 buildings owned by this corporate building owner,
PCBs or formation of oxidation products ( at one end of tho spectrum and a Binghamton-like event Is at the other
end of the spectrum. It Is not clear whether conditions short of a
Binghamton or San Francisco situation
can also lead to the volatilization of
PCBs snd the formation and/or distribution of toxic oxidation products
I approximately 36 sites are serviced by of PCBs. EPA solicits data on what other
about 277 PCB-Transformers. Fifteen of ' fire-related conditions, short of the
NEV 0 3 6 9 3 9
i I
Tederal Register / Voi. 49, No. 56 / Friday March 23, 19M / Proposed Rules________ 11077
condition present during fires like
estimates: 3-4 fire-related Incidents per
Other preliminary estimates Include:
Binghamton or San Francisco, can also 1.000 PCB-Transformers per year and 2- 560 incldents'per yeeHasiumes 4 fire-
lead to the volatilization of PCBs end
3 fire-related incidents Involving PCB- related incidents per year per 1,000 PCB-
the formation and distribution of PCDFs, TYansformers per fire department per
Transformers), 1,120 incidents per year
PCDOs, and other toxic oxidation
year.
(assumes probability of a fire In the
products.
*
If one enum ei that there are 140,000 United States Is equal to the probability
According to the resulte'of this
PCB-Tranefotmert In tervice (as
of e fire In Finland), and 1,405 Incidents
telephone survey, there were two fire* estimated by EPA In the August 23,1982 per year (assumes all transformer fires
related incidents In region I (both tn
PCB Electrical Use Role), then, 3 4 fire- reported to the NFIRS are PCB-
Boston, Massachusetts), three incidents tn Region 11(In New Jersey, Albany, New York, and Binghamton, New York),. two incidents In Region IV (in Clearwater and Miami, Florida), one
Incident In Region V (In Chicago, Illinois), one Incident In Region VI (in
Corpus Chrfstl, Texas), one Incident in
related Incidents per year per 1,000 transformers would yield an estimate of
between 420 end 560 fire-releted Incidents per year. If one assumes that all non-substation PCB-Trmnsformert (114.469) ere located In or around
buildings, then, 3-4 fire-related Incidents per year per ijOOOnon-substation
Transformer fires)..
EPA solicits date on the validity of the estimate provided above, a t well as data to support other estimates of the frequency of fire-related Incidents Involving electrical transformers that contain PCBs.
Region VII (In Kansas City, Kansas), two transformers would yield an estimate of UBenefits of PCB Transformen and
Incidents In region VIII (In Denver,
between 342 and 450 PCB-Transformer tbs Availability of Substitutes
Colorado), ana four Incidents In Region fire-related incidents per year In,
IX (in California) (Ref. 10).
buildings.
1ST
Thus, in a two-year period, without
If one assumes that there Is an
PCBs were orglnally used as dielectric
any formal EPA mechanism that
average of 10 major fire deportment
1 fluid tn electrical transformen primarily
required the reporting of fires Involving jurisdictions per State, and a total o! at because of their fire-resistant properties.
transformers containing PCBs, flfteon least 510 jurisdictions in the United
Traditionally, PCB-Transformers were
Incidents were reported to EPA regional States, then, a 2 or 3 fire-related
placed In locations where concerns for
offices. Detailed Information on all of transformer incidents per fire
fire safety were paramount. Even today,
these Incidents.Is not readily available. ,, # department yields an estimate of
PCB-Ttantfonneri that are In storage for
In many cases, monitoring for ths
'b e tw een 1,020 and 1,530 fire-releted
re-use are placed In or around buildings
presence and dietribution of PCBs end `PCB-Traniformer Incidents per year.
where fire safety Is a concern. Other
pyrolysis products does not seem to In addition, from dele collected In - dielectric fluids, such as mineral oil,
have been undertaken.
Finland on PCB-Transformer fires, the . - have superior electrical properties to
The causes of these IS fire-related
Director General of the Finnish Institute PCBs, but their fire resistant properties
Incidents are also not always known. - of Occupational Health (FIOH)
are not as good as PCBS.
When causes ware mentioned by survey
respondents, they Included: (1) Shortages tn bus-bars, (2) switchgear . malfunction, (3) electrical shorts or arcing of the transformer, and (4) high voltage cable burning. One of the more disturbing Incidents described by one of
the regions wet a case In which refuse present In the vicinity of a transformer
estimated that there mey be as many ae
1.120 such Incidents In the United States each year. This Is based on the assumption that the frequency of firerelated events in the United States would be the same as that In Finland. * EPA his contacted the Director General
of FIOH to obtain additional data on the basis of his estimates.
Thus, any consideration of phasing * out PCB-Transformers mutt be *.
accompanied by an analysis of the fireresistant properties and potential toxicity or combustion products of substitute fluids. In addition. EPA must evaluate the adequacy of the electrical
properties of these substitutes.
caught fire as a result of sparks from an Information compiled from the
B, Substitute. Transformen
arcing transformer. The fire Itself began In the refuse beneath the transformer, and. It eventually caused ths rupture of the transformer eating.
EPA solicits additional data from knowledgeable parties on the circumstance* surrounding the firerelated incidents described above. EPA also solicits information on the circumstances surrounding otherincidents that EPA may not be aware of, especially Information on the causes of the fires end the Information and distribution of contaminants.
C. Other Estimate o f Fire Frequency
National Fire Incident Reporting System (NF1RS), a computerized data base managed by the National Fire Administration, indicates that there were 1,405 transformer fires tn calendar year 1082. These data are not, however, specific to PCB-Transformers, EPA Is In' tne process of obtaining access to this data base for purposes of determining the percentage oi these fires that * Involved PCB-Transformers.
D. Range o f Estimates o f the Frequency o f PCB-Transformer Fires
EPA has developed a range o f . preliminary estimates on the frequency
In Hi August 1982 PCB Electrical Use Rule, EPA concluded that adequate substitutes exist for PCBs in Indoor transformer locations. The following units summarize available Information
on the Are safety and electrical efficacy of substitute transformers, and discusses available Information on the toxicity of substitute dielectric fluids In combustion situations.
There are six general types of substitutes for PCBs In transformers: Silicones, high-temperature hydrocarbons (KTH), chlorinated hydrocarbons, non-PCB askerela,
Informal dtscusstone between EPA
of fire-related Incidents Involving PCB- fluorocarbons, and mineral oil. The
representatives and representative# of Trantformers. The lowest estimate is
following summarizes data available to
the General Services Administration
eight per year based on reports to EPA. EPA on the fire safety, toxicity in the
(GSA), regional fire departments, end The highest preliminary estimate. 1,530 event of e fire, and electrical efficacy of
the National Fire Administration have fire-related incidents per year, is arrived each type of substitute fluid.
yielded some preliminary estimates of at by assuming that fire departments
There are several physlcat/chemlcul
the frequency of fire-related Incidents throughout the United States responds properties of substitute dielectric fluids
Involving PCB-Transformers. EPA has an average of 3 PCB-Transformer fire- that are used as a guide tn determining
obtained the following Informal
related incidents each, per year.
fire safety. These properties are the
NEV 0369*0
11078
Federal Roaster / Vol. 49, No. 58 / Friday, March 23, 1984 / Proposed Rules .
eulolgnitlon temperature, the flash point, In the absence of oxygen ere silicone
and the fire point. The minimum
dioxide, hydrogen, and hydrocarbons.
temperature at which a fuel buret Into Water, carbon dioxide, end carbon
flame when the atlmulu 1 thermal is monoxide are also produced In the
referred to a the autolgnltion
presence of oxygen. Silicone fluids are
temperature. The temperature at which self-extinguishing when burned In a
flret flame appear from i free radical pool, since a crust la formed which
eource euch at an ere, epark, or flame it smothers the flames.
referred to a t the flash point. The Are
Silicone transformer fluids olao have
point,is a lightly higher temperature at some disadvantages. They absorb
which flame ere iutalned. Currently, moisture from the air very rapidly and
the National Electrical Code require a extreme care must be taken to transfer
minimum fire point of 300'C for
the fluid without contact with the
unvaulted electrical transformera.
atmosphere In order to maintain proper
The property of having a fire point
electrical properties. Rrpduct literature
higher than 300'C allows classlucatlon from one silicone fluid manufacturer
of fluids at "la flammable transformer roughly estimates that at 100'C, silicone
fluid*' by Factory Mutual Research
fluids will circulate 5 or Btimes more
Corporation '(FMRC). During the past
lowly than askarel or mineral oil. Tbit
few year. FMRC, with the assistance of slower rate of circulation may have
Industry and government, has developed implications on the ability of the fluid to
a philosophy for hazard reduction, performed experimental and theoretical
dlBBlpate heat. 2. High-temperature hydrocarbon
research, and has lnoed a test sequence for recognition of less flammable transformer fluids.
The first requirement of the FMRC it
that the fluid nave a fire point of at least 300'C. This temperature is sufficiently high to afford resistance to small
Ignition sources, such as matches, but I t . til) low enough to be met by several classes of commercial fluids, including silicone oil.
The next requirement is that the transformer be located within a dam
that Is at least four times the area of the transformer tank and is deep enough to
contain all the fluid in the event of a spill.'Should the fluid become Ignited, and it It assumed that It will be, and
becomB fully Involved in flames, this
insures that the flames will not spread along the floor.
The final requirement Is a maximum
(HTH). EPA usee the term HTH to refer to mineral oili with a fire point higher than 300* C. This category of fluids
Includes high temperature eaten that are primarily used In railroad transformers. The primary advantages of H lH s tre
high fire point low toxicityt blodegradebiltty, and the long usage
history compared with other transformer oils. The higher Are point `of HTH fluids mitigates somewbat the fire hazard
normally associated with the use of mineral oil In Indoor locations.
HTH are refined from paraffinic-type base oil. Breakdown products from
complete combustion during arcing in (he absence or oxygen are hydrogen,
carbon, and hydrocarbons. Products produced In the presence of oxygen -
include water, carbon dioxide, and hydrocarbons. Data are not available on
allowable rate of convective beat release. In a nonflammable building
,
the products of Incomplete combustion ofHTHi.
with nonflammable contents, Ihe risk of Ester HTH are used primarily In *
extensive Are lost it mainly to Ihe
railroad transformers or where
structure Itself. If the celling ovet the fire transformers must elart up under very
Is overheated, collapse of the roof could cold conditions. Because there cost It
occur. Heat release rates have been
higher than other HTH and they ofler
measured by FMRC for several fluidf. no real advantages in indoor locations.
1. Silicones. Silicones refer to familyHis likely that the paraffinic HTH will
of relatively inert liquid organoslloxane be the materials of choice for these usee.
polymers used as electrical Insulation.
The viscosity of at least some HTHs
Although silicone'filled transformers decreases more rapidly than other
have been used since 1972, In the last
transformer fluids under the action of
five years, their use has Increased significantly. They are superior to
Increased temperatures associated with overloading. This property allows
mineral oil and non-PCB askarels In * greater cooling during overload
thermal stability and, unlike mineral oil, conditions.
will not degrade to form sludge. They
The primary disadvantage associated
also have fire point! above 300'C. with the use of HTHs Is that they have s
Combustion of silicones, whether by higher heat release rate than other.
arc-induced explosion or pray mtsl
substitutes. This mean that the HTHs
Ignition, produces fluocculant silicone wlirbum at over twice the temperature
dioxide particles and globules of silica- of silicone fluids, thus, potentially
gels. Breakdown products during arcing causing more damage In an indoor fire.
Another disadvantage of HTHs is the . Increased viscosity compared with that
of mineral oils. This higher viscosity at normal operating loads causes slightly higher operating temperatures ana could possibly shorten the life of the transformer.
3. Chlorinated hydrocarbons.
Chlorinated hydrocarbons refer to a group oi chlorinated aliphatic hydrocarbons. Ih e primary chlorinated hydrocarbon being considered for use as a electrical insulating fluid is perchloroetiwlene. The primary advantage of perchloroethylene Is Its nonflammability. \
Breakdown products from complete
combustion during arcing Include hydrogen, chloride, carbon, carbon
monoxide, carbon dioxide, and water. Data are not available on the products of Incomplete combustion of chlorinated aliphatic hydrocarbons.
4. Non-PCB askare/s. Non-PCB Askarel 4s a generic term for a group of
synthetic, flre-restitent, chlorinated aromatic hydrocarbons
(chlorobenzenes) used as electrical Insulating fluid. The primary advantages of the noD'PCfi askarels are their nonflammability and lower costs compared to HTHs end silicones. These fluids are treated the same a t PCBaskarels in the National Electrical Code.
As mentioned In Unit ILB.2. of this Notice, however, experiments have shown the formation of PCDFe and PCDDt from the Incomplete pyrolysis of mixtures of chlorobenzenes In air. Amounts of PCDFi ranged as high as
tenths of a percent for mixtures of trichlorobenzenes.
5. Fluorocarbons. Fluorocarbons (specifically Freon 113) ere being tested
for use as a transformer fluid. EPA 1 soliciting Information on the Are safety,
electrical efficacy, and toxicity of freon fluids in fire situation.
(5. Mineral o il Mineral oil is a refined mineral Insulating oil to which additives such as oxidation-inhibitor have been added. It Is used In the vest majority of outdoor transformer*...
If fire safety were not a consideration, mineral oil-filled transformers would probably be used In all applications. Mineral oils costs less than PCBs, htvs better heal transfer properties, ore considerably lighter In weight, and form noncorroaive products under conditions of electrical arcing*
The major disadvantage of mineral oil is Its flammability due to a low flash point. If arcing occurs, the complete combustion breakdown products are
hydrogen, methane, other hydrocarbons, carbon monoxide, end water. Data are
not available on the products of
NEV 036941
Perforai Register / Vol. 40, No. W / Friday, Match 8, 1984 / Fropoaed Auks
11079
incomplete combustion of mineral oil,
The National Fire Cade requires, with eome exception*, that efl-far*rietI
Experience with retrofllling PCB* Transformers since (he issuance of the Bisks August Z5,1682 PCB Eleotrical Use Rule
7toiy Options fee Reducing
transformen fantailed indoors bo pkoed In vaults, Because of On cost of lnstslHng tranfonuws fat vaults, fhte ta disadvantage of mineral ofl transformers.
A* concluded b iB W s Augast 28, *. 1962 PCB ELectrical Use Role, GPA believes that adrnate substitutes mdst for PCBs in indoor transformer location from the perspective of fire tafety and electrical efficacy. EPA is soliciting information, however, on the toxicity of aubitltute transformer fluids fai combutlon sttoetlons. Specifically, EPA I soliciting data on the product* of incomplete combustion of substitute dielectric fluid.
C. Retroftiling PCB Transformer
Indicates (hat retrofining with itiicone* to reclassify transformers as mw-PCB Is not practical at this timo, k alLonly one transformer rotrofiOarf with sflioono
fluid has been able is reach and maintain levels mutar (Oppa. ~
Companies oontooted dudnglta poet few month* have all agreed that
rotrafililog to roach and maintain leee `than SOppm PCBa la aotoost-cflsctiva. However, Trvo*t thought that rotrofififaig to maIntrisi kvoU nudar 00 ppm ssanhl be cost-sffectiv* in awny oases.
9. HTHb. Thera me atx HTH Holds
told be five comparita that may b* need a transformer dldaotric Brida. Utero
era also two products told by two attar companies that when mixed with other
Jm fysh ofAlternative Regahrtory Options for PCB-Trm&formers
1. Cleanup costs. Thera ore two
categories of clean-up cost* that EPA
considered In evaluating the cost*
affvcttvsw** ef variera options for PCS*
Transformer phase-rat. The first
category is the cteenrop of tpflls from
transformer*. In Its August 28.1982 PCB
Electrical Use Rule, fiPA atsamed that
O i perant of PCB Transformers failed
eodt year, and that 47.7 percent of these
tenures resulted In spills: EPA assumed
that an average of $0440 was spent per
pear per spill.
: The econd category of dean-up costs
Is the costs associated with the clean-up of catastrophic failures. For purposes of
1. Introduction. Two general type of products may bo u tad e* HTH *
the following analysis.EPA assume* a
ubititute* for PCB* In tronvfornwrs
transformer fluids. Three of the six
catastrophic failure rate of OjOI percent
ttand out a t the beet retrofill
fluids are parafflnlo-bosed ofl* and three per year, and that clean-up costa are $20
candidates, Theea fluids are silicone*.*;- are estero. As mentioned earlier, the
millionpar Incident These costs were
and high temperature hydrocarbon ' t`\ throe esters i n more specialised h r ose not factored Into the Agency's economic
(HTH). The principal question* to bo
In railroad transformers.
analysis completed for the August 25,
considered are the cost of retroflll
versus the value of the remalnthg Hfe of (he transformer and the ouaUficalton of ' the fluid a "le u flammable" for insurance purposes. Other fluids, inch ' as chlorineteo hydrocarbons, fluorocsrbon, and mineral oil, maybe used In new transformers but are inappropriate for retrofllling because the design of the PCB-Tronsformers doss not fit the properties of the fluids.
2, Silicone. There a rt six silicone fluida sold by a(x different companies
for use as dielectric fluid. Four of the tlx fluids have been approved by Factory Mutual a t "less flammable" fluida. Silicones have a higher viscosity than
The other throe fluids ora more viscous than die silicone* at lower temperetufes. but thin mre rapidly at
higher temperatures. According to an HTH manufacturer; thle property allows the transformers to be retrofilled with,
HTH without any derating. At lower normal load temperatures, however, (he
transformers do run hotter. These fluids ere completely compatible with the materials (hat make up PCB* Transformer*, and they are soluble In
PCBs. Two `Of these fluids ere approved by Factory Mutual a i "lea* flammable transformer fluidi," and the fire point of the third is over 300* C.
1982 PCB Electrical Us Rule. EPA presents a rariga'ofestimates of the
probability of catastrophic EbDums In Unit I1I.C. That* probabilities conge
from 0.0066 percent per year (about 8 Incidents per year) through 1.34 perant per year (about 1,630 incidents per year).
Additional table* (that Incorporate
ower probabilities of catastrophic fires) are presented In the preliminary cost* effectiveness analysis completed for this ANPR [Ref. 11).)
EPA'e estimate of dean-up ooste ' associated with catastrophic avants was derived from estimates provided from the Binghamton and San Francisco Incidents. Further, In the analysis
PCBi and are therefore not quite
As with silicones. It does not seem
ireeenled below, EPA assumes that -
comparable as a coolant For this
practical to relrofUl to maintain PCS
6ttlle cost Is normally associated with
reason, It Is possible that transformers concentrations under SOppm. However, clean-up following non-PCB transformer
retrofitted with silicons would have to It Is possible and cost-effective in many fires In cases where little structural
bs derated. According to one silicon
cases to maintain concentrations under damage occurs to the building Involved
fluid manufacturer, if the transformer
BOOppm. The cost variables are about In the fire. EPA 1*soliciting data on the
were fully loaded, a deraling not
exceeding five percent coula bs necessary.
It has been mentioned In the literature that a leaking problem could be created because silicone fluids are not compatible with silicone rubber gaskets and the coefficient of expansion of silicone fluida la 80 percent greater then that of PCBs. In actual practice, however, the silicone gaskets are replaced during retrofflllng. Further, even though the coefficient of expansion
the same ns for silicone fluids, except,
HTH fluids require annuel testing end *
possible filtering to remove moisture or
particulates.
*.
Because the paraffinic HTH* have
high convective and radiant heat release
rales, the owner's Insurance company
may recommend more stringent ,
Installation requirements.
EPA Is soliciting comments on the
Information provided above pertaining
to utilities* experience with retrofllling,
costs associated with clean-up following fires In transformers that do not contain PCB*.
2. Comparison o fclean-up costs .
versus phase-out ooste. The following. table uses a population of 114,489 unite (EPA's estimate of the number of nonsubstation PCB-Transformor*) and an
estimate of equipment life of 30 years, and compares phase-out cost* to clean up costs avoided If phase-out wae
Implemented over a 5-year period, over a 10-yeer period, and over a 15-year
Is greater than that for PCBs, the greater and the ability practically lo reduce PCB period. EPA did not consider Immediate
solubility of the filler gas (nitrogen) In concentrations to below B ppm by
phase-out because several persons
silicone eliminates that expected.
retrofllUng.
Indicated that manufacturing capacity
Increase In pressure.
was Insufficient to allow for this option.
NEV 0 3 6 9 ^ 2
For a full description of the assumptions 4. F in hazard inspection. Following range from $2,000 to $5,000 per
used In the following analysis, and for a the transformer fire In San Francisco,
transformer location (Ref. 11). '
more detailed analysis of phase-out
the owner of the transformer involved In In addition to closing off transformer
costs versus dean-up costs avoided, see the fire (Pacific Gas and Electric
locations through the use of sealants.
"Preliminary Study and Cost-
Company (PG&E)) instituted a fire
EPA believes that the use of smoke
Effectiveness Analyses of Alternative 'hazard elated Inspection program for detectors and other tensors in
Regulations for Indoor PCB
PCB-Transformers, Hits program
transformer locations to create an early
Transformers. February 1864" (Ref. 11). consisted of Inspecting all network PCB- warning System may be beneficial In
Ta b u l--PncuMiNARY Oqst-Efficttvsnesi
of Alternate PCB Requiahons son Phase-Out of Uthjiy-Owned Askarcl Transformers
Transformer* on a regular and frequent mitigating the risks from fires Involving
basis, using new techniques such as
transformers. Further, the use of a heat-,
Infrared sensors to detect potential
' sensitive or moke-sensitive baffling
defects ("hot spots") In the transformer ystem In ventilation ducts exiting the
and electrical equipment In the area of transformer location could reduce the
fttgudlonoption
Com*
MOeMUoItMHtaO*
WsNejeMt oyn3i)
the transformers, In addition, for Increased fire protection, PG&E Installed secondary diaconneot switches at PCB-
spread of contaminants via this route. For additional Information on the
economics of Implementing these types
U til 41.1
S4t7009..11
t,040.1 1.0O.S
S5tM5.4O0O0
Transformer locations. EPA believes that completing
rcojoo transformer fire hazard Inspections of
*h m*on*c*doflr*.
PCB-Trantformer locations may be the
initial step In a program to reduce the .
S. Retrofitting. EPA has completed a likelihood of future fires Involving this
preliminary analysis of the costs of
equipment and to mitigate risks
retrofitting PCB-Transformers to reduce associated with these fires should they
PCB concentrations to below 500 ppm. occur. Other factors considered In a
EPA estimates that retroflll costa will. , transformer fire hazard inspection might
range from $20,736 to $32,034 per
: Include a consideration of: The age o f
transformer, depending upon the site oP the transformer and the maintenance
the transformer. These estimates do
history, the location of the transformer,
Include the costs of disposal of PCB
the location of ventilation equipment or
fluid, but do not Include any
ductwork In the vicinity or the
consideration of a loss of efficiency or transformer, and the presence of
derating as a result of the retroflll.
combustibles in a transformer vault or
An estimate of the total costs of requiring the retrofllllng of all PCBTransformers (114,469 in service nonsubs 1st)on transformers) to below 500 ppm Is about $1.6 billion. This can be compared to an estimate of clean-up costs avoided of about $1.7 billion. This
estimate of clean-up costs avoided assumes that retroftlled transformers
that contain less than 500 pm PCBs that are Involved In flre-related Incidents
would not result In the formation of PCDFs or PCDDs In sufficient quantities
to trigger ma[or clean-up efforts. EPA does not know whether this Is a valid
assumption. EPA Is soliciting data on the potential for (he former of PCDFe and PCDDs In PCB-Contamlnaled transformer*.
near a transformer location.
EPA is soliciting data on the effectiveness end costs of using infrared sensors to Identify potentially faulty equipment. EPA 1s also soliciting data . on the effectiveness and costs of other Imtlar technologies, and Information on the effectiveness and costs of Installing and using secondary disconnect switches exterior to transformer locations. EPA Is soliciting comments on Its list of factors to be considered bn fire hazard inspections, end comments on the ability to reduce the potential for fires by completing fire hazard Inspections and Instituting appropriate corrective measures. EPA Is soliciting Information on other factors that should
EPA also completed a preliminary analysts of the costs of retrofllllng of PCB-Transformere to reduce the
be Included In a PCB-Transformer fire hazard inspection, and Information on the costs of conducting such Inspections,
concentration of PCBs to.6 percent. An
5. Fire/smoke control technologic*
of risk reduction measures, see "Preliminary Study and CostEffectiveness Analyses of Alternative Regulations for Indoor PCB
Transformers, February 1964" (Ref. ll).
EPA It soliciting information on
available amok and fire control technologies, their application to PCBTransformer fire situations, their ability to reduce the risks associated with these fires, and the costs associated with installing these eystems.
6. Reporting o fPCB-Tronformerfin e to BPA. EPA it soliciting comments on the benefits of Instituting a PCBTransformer fire reporting system within the EPA. EPA believes that specifically requiring the reporting of these Incidents would Increase the general level of
knowledge about how these Incidents occur, the circumstances surrounding
these Incidents, and the nature and level of rieka posed by these Incidents. EPA ts soliciting comments on the costa
associated with requiring such reporting,
and the benefits to public health from such a system. EPA solicits comments
on the mechanics of such a system. Including comments on considerations
such as: (I) Who would ba responsible for reporting the fire, (2) when the report
must be filed, and (3) what typee of
Information must be reported. 7, Registration o fPCB-Transformert
with f in deportment* PG&E. in a
telephone conversation with EPA* Indicated that it routinely Informs fire departments of the location of PCBTransformers In the utility system. Representatives of the International
estimate of the total costs of requiring PG&E, in addition to completing fire
Firefighters Association and
retrofllllng of all non-substation PCB- . hazard Inspections, has committed to
representatives of fire departments have
Transformers to 6 percent PCBs Is about sealing off all openings through Its
informally indicated to EPA their desire
$1.3 billion. EPA Is also soliciting data network vaults. Presumably, this is
to see this practice Instituted
on the formation of PCDFs and PCDDs being done to reduce the spread of -
nationwide. EPA believes that the risks
In (his category of transformers. For
smoke to areas adjacenl to the
posed to firemen end bystanders during
additional Informatlon.on the costs of transformer location In the event of a
PCB-Transformer fires could be
requiring relrofillng, see "Preliminary
fire. EPA has obtained a preliminary
significantly reduced if the initial
Study end Cost-Effectiveness Analyses . range of estimates of the costs .
response team Is aware that the fire
of Alternative Regulations for Indoor
associated with sealing off transformer Involves a PCB-Transformer, and that
PCB Transformers, February 1664" (Ret locations to reduce the spread of
there ere certain risks associated with
11).-
contaminated smoke. These estimates extinguishing such a fire.
NEV 0 3 6 9 4 3
Federal Register / Vol, <9, Mo. SB / M d a y , M arch 3, W84 / Proposed Kiries
11081
EPA li lotfcitlng comment* On
which PCft-TraM feom are red, the other oxidation and p jn d jris products .
effectiveness of supplying this
tsm b e t of K B - lta n f e r e m used tn
measured In the buHdfftg following the
Information to tiro departments from the each building, the ape of the brildiagu, fire; foe nature of any clean-up
perspective of reducing the dike posed the age of the transformers, the location undertaken fofhnring the Incident; end, .
from these Incident to firem n end of the PCB-TTansfonnsrs serving i n
the oeeti of dean-up following the
bystanders. EPA ts alee toUottlag data buildings, end the arwiKeiMp ef th e '
Incident. `
'on the costs of providing these date to fire department fariedtettooe.
B. Utilities That Have Made Decision Voluntarily to Phase Out PCB Transformers
1. PG&E, PGftE hoi decided to replace Its B39PCB*Trenfonners tn the Ban Francisco area on a priority basis by December of a987. According to PG4E, 40 PCB-Transformer* Id vault locations are to be replsosd by une W, 1084, end t 45 PCB-Transformer* In 12 high-rise buildings are to be placed by june id, 19M. T at remaining PCB-Trusiormers are to be removed by the December 1687
te n s fanners. EPA Is also sohctttng
Information on the location ef PCBTramfonner* other tima these present
la or directly servicing bottdbtgs, 2. Populations exposed, types o f
chemicals, and iavek o fesposanxFPA Is toll citing InfbmuUosoapainiatiaae potentially exposed to PCB* and PCB* oxidation products lo lha vast of a fire, and the levels of chemicals to which lha populations are potentially exposed
3. Bootes o fexposureSoPCBs and oxidationproducts, EPA is salid ting
J. Factors that m ay Increase/decroase the risks posed by PCB-Transformers in the event of a fire-related incident. EPA
Is soliciting information on factors, such as the failure of protection devices, the location of ventilation equipment, the type of building In which a fire occurs, etc, that may Increase the risks posed to humans and the environment from fires -feivutvtng PCB-Tranformere. In addition, EPA Is soliciting information
on factors thatauy decrease these risks.
information on the potential routes of
6. Exposures and risks resulting from
exposure to PCBa and thair oxidation contaminated water at fin e. EPA Is
products la lha avast of a Ike Involving, soilciting comments on exposure* and
data. In the Interim, PG&E Is completing
this equipment EPA Is solid ting Information on the role of ventuattoa
risks that may remit from water contaminated at fires. Contaminated
PCB-Transformer fire hazard
equipment and ductwork lo the
water may result from the application of
Inspections, sealing opaalngs In vaults, dispersion of PCBs and oxidation
water during firefighting, the rupturing
. ana pledng secondary disconnect
products from PCB-Transfonnea
of pipes ander high temperatures, and
witches at PCB-Transformer locations^ . involved In fires.
J2. Florida Power and Light Florida * 4. Representativeness o fBinghamton
iotslbly other sources Including water rom cleni-up operations following the
Power and light Company (FPLC) has * and San Francisco data. PA D also committed to placing fie 458 PCS* soliciting comments on Its analysis of. Transformer. In September 1683, FPLC the Binghamton and San Francisco fires
fire. Contaminated watermsy enter sewer systems (both sanitary and storm sewer systems) and mey run off directly
announced Its plans to spend more than and on the representativeness of these to surface water. Contamination of
, $15 million in south Florida over a five- . fires horn the perspective of evaluating sewers, treatment works, sludges and
Star period to replace this equipment, lelilli on the priority system for the
removal of these transformers was not
available to EPA, but, EPA Is interested
In obtaining this type ei Information.
9. Boston Edison. According to a letter
dated August 5,1683 from Boston Edison
Company (BEC) lo a properly
management firm, BEC Is In the prooets
of developing programs for the orderly
elimination of PCB aqnipment from their
system. DEC Indicates that they have
already begun the examination of
transformer vaults In buildings for
imposes of determining what work will required and when It may b t
scheduled. EPA has no further details on
BECs decision or on Its priority system
for the removal of this equipment. BpA
Is soliciting additional information.
EPA is soliciting Information from
other utilities or building owners that
have made the decision to remove PCB-
Transformers from their present
focotloni, and data on the basis for
making the decisions lo phase out this
equipment,
___ .
the nature of the risks posed when a
PCB-Transformer U'lnvolved In a firerelated Incident
5. Information an the risks posed by
the fire in Chicago. EPA le soliciting
additional data on the causes of and circumstances surrounding the
September 1983 Chicago fire, trw efl as information on the risks posed from this
Incident. 9. Information on otherfire-related
incidents involving PCB-Tmnsfornen. EPA Is soliciting data on other PCBTransformer fire-related Incidents tn addition to data on Binghamton, Sen Francisco, and Chicago. EPA Is soliciting data on the time, dote, end location Of the Incident; tha cause of the Incident; the extent end avenue of smoke travel;
the location of ventilation equipment relative to the location of the fire; tha
type of equipment involved In the Incident; the age of the equipment; the type of building In which the Incident occurred; tha number of people present In the building et tha time of the Incident; the time elapsed between (he
beginning of the fire and tha response of
surfaoa water may result. EPA solicits Information and data on the distribution* of PCBs and other toxic chemicals . through such routes, Including the mode of distribution and environmental fate; actual or anticipated concentration levels In water, sludge, treatment systems and biota; adverse effects on ond continuing risk to humans through drinking water or Ingestion of contaminated food; risk to othsr organisms; threat lo the operation of sewago treatment systems: and the costs of clean-up.
B. Frequency o fFire-Related incidents
EPA Is soliciting comments from building owners, lire departments, utilities, and other parties on tha accuracy of EPA*s nationwide estimates of the frequency of fire-related Incidents . Involving PCB-Transformera. EPA Is also interested In data on the frequency of these firea versus the age of tha transformers Involved
C. Formation o fReaction Products
LVI. Summery of Data Needs for | P ro g o s e d R w t^ ^ J
the fire department; the time required to 1. The reaction products found
de-energlze the transformer, the
following PCB-Transformerfires. EPA la
effectiveness of the circuit breaker os a soliciting information on the types and
A, Bisks Posed by Fires
protection device in the incident; the
levels ofoxidation/pyrblysl/
1. Number, location, and ownership o f potential for the formation of oxidation Incomplete combustion products that
PCB-Transform ers. EPA Is soliciting
products such as PCDF end PCDD;
are found following fire-related
Information on the .types of buildings Is levels of PCBs, PCDFe, PCDDs, end
Incidents Involving PCB-Trenifonneri.
NEW 0 3 6 9 4 9
11082
Federal Register / Vol. 40, No. 58 / Friday, March 23, 1984 / Proposed Rules
2. The reaction and mechanism o f Transformers would pose higher risks in VII. References
reactions involved in the formation of reaction product. EPA If soliciting
information on the reactions and mechaniama of reaction involved in the
formation of oxldation/pyrrolyaia/ incomplete combuation products from
the event of PCB-Transformers that may be considered to be high risk transformers.
5. PCB-Transformerphase-out costs.
EPA is soliciting Information on the costs to transformer owners of requiring
(1) USEPA OPTS. EED, Versar. Inc.. "Exposure Assessment: First Involving
PCB-Transformers" (January 1964). (2) USEPA OPTS, HERD, "Response to
Commenta On Health Effect# of PCB# submitted by tha Chemical Manufacturer#
PCB-Trsnaformer fires.
the phaee-out of all PCB-Trsnsformere
Aaeoclatlon and tha Edison Electric
3. The potential for the formation of over 6-, 10-, or 16-year periods. EPA is
Institute" (August 10.1982).
reaction productfollowing fires
also soliciting comments on the Putman (3) USEPA, Carcinogenic Assessment Croup.
involving PCB-Contaminoled
Haves and Bartlett Preliminary Study
"The Carcinogenic Assessment Croup's
Transformers. EPA Is soliciting data on and Cost-Effectiveness Analyses of
Risk Assessment on (2.4.6-
the potential for the formation of toxic reaction products from fires Involving
PCB-Contaminated Transformers.
Alternative Regulations for Indoor PCB- . Transformer (Ref. 11).
6. Phase-out costs of high risk PCB-
TrichlorOphanoxy) Acetic A dd (2.4.B.-T) (2,4.5.-Tricholorophenoxy) Propionic Acid (Sltvex) 2.3.7,6-TetrachlorodJbenzo-pdloxln (TCDD)" (September 12, I960).
D. Cost and Nature o f Cost Associated Transformers. EPA it soliciting
(4) Cesarett end DoulL (1075) "Toxicology the
With Clean-Up
information on lha costs to transformer
Basic Science of Poisons." MacMillan
EPA is soliciting information on the coats incurred by owners of PCBTransformers Involved in fire-related incidents. These coats include the coats of analysis, the costs of clean-up and removal of contaminated materials, the costs of lawsuits filed bv damaged parties, and the costa of replacing the damaged vault and/or transformers) following the incident. EPA is also. soliciting data on the site of the are* cleaned, the levels remaining after * clean-up, and other explanatory information on how clean-up money was spent, and why clean-up required the amount of money used.
B. Costs and Benefits o f Regulatory Options
1. Benefits o f PCBs. EPA Is soliciting
owners of requiring the phase-out of
. Publishing Co., Inc., pp. 23-28.
PCB-Transformera that tall within the
(5) Otahl, S. Morita. M.. Fukuda. H.. (107)
high risk categorization.
"Comparative Toxidty of Polychlorinated
7. Fire hazard inspection programs. EPA it soliciting Information on what .
factors should bs included in a PCBTransformer flra hazard Inspection, and
on the effectiveness of inspections and subsequent corrective measures In
reducing the probability of fires and mitigating the risks posed when Area do
Biphenyls and Dibenzofurans in Rats." Toxicology and Applied Pharmacology,
43.13-22.
(6) USEPA OPTS. HERD. "Tha Toxicity of *
Boot From PCB Transformer Fires" (Deoember 20.1003). (7) OCS, (1063) Tha Binghamton State Office Building Clean-up: A Progress Report Update." Albany, NY: New York Stat#
occur. EPA it also soliciting information - Office of General Services (January 1063).
on the costs associated with completing (8) Varaar, "Investigation of the
these inspections and the costs associated with implementing corrective
measures following inspection.
8. Availability and effectiveness of early detection devices and smoke control technologies. EPA ie soliciting information on the effectiveness of early
Contamination Remaining in the Binghamton State Offtoe Building
Following Completion of Preliminary
Clean-up" (October 20.1062). (0) The Equitable Life Assurance 8oclety of
the United Stelae. Letter to David Dull. EPA "Equitable Ufa Assurance Survey" (October 4.1063).
specific information concerning whether detection devices in reducing the risks (10) USEPA OPTS, EED. "Summary of
transformer fire incidents have been
ssocistsd with PCB-Transformer fire-
Regional Data on PCB-Trensformar Fires"
reduced over the past 40 years due to
related incidents. EPA it also soliciting
(October 10.1063).
PCB usage, whether this usage hes mads a significant impact on reducing the
dollar costs from building fires, and
whether such usage has resulted in any appreciable saving of human life.
2. Substitute transformers. EPA Is soliciting Information on the toxicity of
information on the availability of smoke (11) USEPA OPTS, ETD. PHB, "Preliminary
control technologies to reducs tha
Study and Coet-EfTecUvenese Analysts of
spread of the contaminated smoke from Alternative Regulations for Indoor PCB
fires involving PCB Transformers. EPA Is soliciting data on the effectiveness of
these technologies in the event of an electrical power failure, which often
Transformers" (February 1064). (12) USEPA OPTS. ETD. PEDCo
Environmental Inc* "Substitutes for PCBs
for Use in Indoor Electrical Transformers"
(January 1064).
substitute dielectric fluids in the event accompanies PCB-Transformer firs*
(13) Milrt Corporation, "Environmental
of a fire.
related incident.
Assessment of PCBi in the Atmosphere."
3. Retrofilling. EPA is soliciting
9. Effectiveness and costs o f PCB-
Tablet 6-11 and B-13 (April 1076).
information on the flra safety, electrical efficacy and toxicity (in the event of a
fire-related incident) of PCB* Transformers that have been retrofitted with non-PCB fluid. EPA Is also soliciting comments on the PEDCo Environmental Inc. study of substitute transformers and dielectric fluids. -
Transformerfire reporting svstem. EPA
ie soliciting information on the costs and benefits ofinstituting an EPA PCBTransformer fire reporting system.
10. Registration of PCB-Transformer* with fire department jurisdictions or with EPA. EPA ie soliciting data on the costs and benefits of registering PCB-
(14) Buaer, Hana Rudolf, "Formation of Polychlorinated Dibenzofurena (PCDFe)
and Dibanzo-p-Dioxins (PCDDsj from tha Pyrolysle of Chlorobenzene" (1070). (15) Buter, Hans Rudolf, "Formation of Polychlorinated Dibenzofurans (PCDFs) from the Pyrolysis of PCBs" (1978). (16) Buser, Hans Rudolf, "Formation of Polychlorinated Dibenzofurans (PCDFs)
4. Identifying high risk transformers. Transformer fires with local flra
from the Pyrolysis of Individual PCB
EPA is soliciting information on what
departments or with regional offices of
Iiaffiera" jiarv)
constitutes a high risk PCB-Transformer the EPA.
from the perspective of hasards posed in 11. Utilities that ore phasing out PCB-
the event of a fire-related incident, and Transformers. EPA it soliciting
^ ePA li issuing the following list of
methods for identifying such a
information from all utilities that have documents which constitute the record
transformer. EPA is soliciting
made the decision to phase out PCB-
for this rulemsking, and request
information on the costs associated with Traneformera. EPA is Interested In
commenta on any other documente that
inspecting all PCB-Transformer
obtaining information on the rationale should be included. Document* will
locations to determine which PCB-
for instituting these phase-out programs. continue to be added to the tecord as
NEV 036945
Federal Register / Vol. 49, No. 58 / Friday, March 23. 1984 / Proposed Rule*
11083
appropriate, Including information
the National Fire Incident Reporting
"Incidence of PCB-Traneformer Fires"
submitted In response to this rule.
System for 1902" (November 10,1983). (November 23.1063).
A. Previous Rulemaking Record$
(3) USEPA, OPTS. EED. Telephone Communications between Denise
(1) Official rulemaking record from
Keehner, EPA, and Cary Girod. Ventura
"Polychlorinated Biphenyls (PCBs)
County Fire Protection District,
Manufacturing. Processing, Distribution "Frequency of PCB-Transformer Fires"
in Commerce and Use Prohibition Rule" (August 22,1983).
published In the Federal Register of May 31.1070 (44 FR 315141.
(2) Official rulemaking record from
"Polychlorinated Biphenyls (PCBs); Disposal and Marking Final Regulation"
(4) USEPA, OPTS. EED, Telephone Communications between Denise
Keehner, EPA, and Meg Pietrasz, Pacific Gas and Electric, "Information on PCBTransformer Fire in San Francisco"
ubllshed In the Federal Register of ebmanr 17,187 (43 FR 7150). (3) Official rulemaking record from Polychlorinated Biphenyls (PCBs); Manufacture, Processing, Distribution, and Use in Closed and Controlled Waste Manufacturing Processes" published in the Federal Register of October 21,1982 (47 FR 46960). (4) Official rulemaking record from Polychlorinated Biphenyls (PCBs): Manufacturing, Processing, Distribution
in Commerce and Use Prohibitions; Use in Electrical Equipment" published in the Federal Register of August 25,11)62
(December 1,1903).
(3) United Statee Department of Energy. Center for Fire Research, "Development of Flammability Criteria for Traneformer Dielectric Fluids" (March I960).
(0) Pacific GaS and Electric Company, Letter to Mr. Harry Seraydarian, USEPA Region IX, "PCB Transformer Fire in Sen Francieco" (June 20.1963).
(7) Pacific Gas and Electric Company. Letter to Mayor Dianne Felnsteln, "Plan to Remove PCB-Traneformers" (June lft, 1983).
(47 FR 37342).
(0) USEPA, OPTS. EED. Record of . <. Meeting between EPA and Dow
(11) USEPA, OPTS, EED, Record of Meeting between Bob Westin of Versar and Denise Keehner, EPA, "PCBTransformer Fires Issue" (week of September 20,1883).
(12) USEPA. OPTS. EED. Telephone ' Communication between Leo Kokoszka, EPA and Steve Farrow. USEPA Region VIII, "PCB-Transformer Fire and Related Incidents" (October 18,1983).
(13) Buser, H. R. (1878), "Formation of Polychlorinated Dibenzofurens (PCDFs) and Dibenzo-p-dioxins (PCDDi) from the Pyrolysis of Cholorobenzenee," Chemoephere No. 6, 415-424.
(14) The New York Times, "Florida Utility Will Replace Traneformers Made With Toxic PCB a" (Thursday, September 6,1882).
(18) USEPA, Office of Water Regulations and Standards, Criteria and Standards Division, "Ambient Water Quality Criteria for 2,3.7.6Tetracholordibenxo-p-dloxln" (February 1884).
list of Subjects In 0 CFR Part 761
B, Support Documents
(1) USEPA. OPTS. EED, Telephone Communications between Denise Keehner, EPA, and Peter Cilleon, GSA, "Frequency and Nature of PCB Transformer Fires" (October 3,1983).
(2) USEPA, OPTS. EED, Telephone Communications between Denise
` Coming, "Retrofllllng and PCBTransformer Fires" (September 20,1983).
(6) Chemical Regulation Reporter, . Article on PCB-Transformer Fire*. Can Expect 1,120 Transformer Fire
Hazardous materials. Labeling, Polychlorinated biphenyls, Reporting ana recordkeeping requirements,
Environmental protection.
Each Year. Finnish Scientist Tells
Dated: March IS. 1004.
N1EHS" (September 23.1983).
William D. Ruckebbsua,
(10) |orms Rantsnen, Director
Admln/ttrvtor.
Keehner, EPA, and David Endicott,
General, Institute of Occupational '
(mDoc.s*-minu r-a-umin]
National Fire Administration. "Data in Health. Letter to Don Clay. EPA.
MUJMO coot in s St
>
NEV 036946