Document EdEOYJz8zjeYngXYMbpY2r4gN

criteria for a recommended standard.... OCCUPATIONAL EXPOSURE TO POLYCHLORINATED BIPHENYLS (PCBs) U.S. DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE Public Health Service Center for Disease Control National Institute for Occupational Safety and Health SEPTEM BER 1977 Am m u r <*tv**rum Om m m T Ui, O PtMM( (MfUa. H iIini. D.C. 2*4*3 000002 07925 DHEW(NIOSH) Publication No. 77-225 A000003 PREFACE The Occupational Safety and Health Act of 1970 emphasize* the need for standards to protect the health and safety of workers exposed to an ever-increasing number of potential hazards at their workplace. The National Institute for Occupational Safety and Health has projected a formal system of research, with' priorities determined on the basis of specified indices, to provide relevant data from which valid criteria for effective standards can be derived. Recommended standards for occupational exposure, which are the result of this work, are based on the health effects of exposure. The Secretary of Labor will weigh these recommen dations along with other considerations such as feasibility and means of implementation in developing regulatory standards. It is Intended to present succeseive reports as research and epide miologic studies are completed and as sampling and analytical methods are developed. Criteria and standards will be reviewed periodically to ensure continuing protection of the worker. I am pleased to acknowledge the contributions to this report on polychlorinated biphenyls by members of the NIOSH etaff and the valuable, constructive comments by the Review Consultants on polychlorinated biphenyls, by the ad hoc committees of the Society for Occupational and Environmental Health and the American Occupational Medical Aseoclatlon, and AOOOOfM ill N 07926 by Robert B. O'Connor, M.D., NIOSH consultant in occupational medicine. The NIOSH recommendations for- standards are not necessarily a consensus i of all the consultants and professional societies that reviewed this criteria document on polychlorinated biphenyls. A list of Review Consultants appears on page vi. inkles M.D. Dimeter, National Institute for Occupational Safety and Health ( I iv N 07927 The Division of Crlcerle Documentation end Stenderda Development (DCDSD), National Imtltute for Occupetlonel Sefety end Heelth, hed primary responsibility for the development of the crlterle end recommended atenderd for polychlorlneted blphenyle. From DCDSD, John M. Fejen aerved ee crlterle meneger end developed the basic Information with the eaeiatence of John A. Veaa, Ph.D. Personnel from other NIOSH Divisions that assisted In the development of this document vere Robert H. Hill Jr., Ph.D., Alan K. Gudemen, end Dennis M. O'Brien (Division of Physical Sciences end Engineering); Mark V, Jones (Division of Surveillance, Hazard Evaluations and Field Studies); and Trent R. Levis, Ph.D. (Division of Biomedical and Behavioral Science). The DCDSD review of this document vas provided by Richard A. Rhoden, Ph.D,, Chairman; J. Henry Wills, Ph.D.; and Howard L. MeMartln, M.D., with A. Blair Smith, M.D. (Division of Surveillance, Hazard Evaluations and Field Studies), and James H. Sterner, M.D. The views expressed In this document, the conclusions reached, and the recommendations for a standard are those of NIOSH after review of the evidence and consideration of the comments of reviewers. These views and conclusions are not necessarily those of the consultants, other federal agencies, and professional societies that reviewed the document. \ N 37528 NIOSH REVIEW CONSULTANTS ON POLYCHLORINATED BIPHENYLS Mary Bell, Ph.D. Department of Environmental Health University of Cincinnati Cincinnati, Ohio 45267 Eula Bingham, Ph.D. Department of Environmental Health University of Cincinnati Cincinnati, Ohio 45267 Rudolph J. Jaeger, Ph.D. Department of Physiology School of Public Health Harvard University Boston, Massachusetts 02115 Carl C. Smith, Ph.D. Department of Environmental Health University of Cincinnati Cincinnati, Ohio 45267 James R. Allen, DVM, Ph.D. Department of Pathology University of Wisconsin Medical School Madison, Wisconsin 53706 Paul E. Brubaker, Ph.D. Mobil Oil Corporation Paulsboro, New Jersey 08066 Renata D. Kimbrough, M.D. Bureau of Laboratories Center for Disease Control Atlanta, Georgia 30333 David Eotelchuck, Ph.D. United Electrical, Radio, and Machine Workers of America New York, New York 10007 * Charles E. Lawrence, Ph.D. New York State Department of Health Albany, New York 12237 William B. Papageorge Monsanto Industrial Chemicals Company CRITERIA DOCUMENT: RECOMMENDATIONS FOR AN OCCUPATIONAL EXPOSURE STANDARD FOR POLYCHLORINATED BIPHENYLS Tabla of Contants PREFACE NIOSH REVIEW CONSULTANTS I. RECOMMENDATIONS FOR A POLYCHLORINATED'BIPHENYLS (PCBa) STANDARD Section 1 - Environmental (Workplace Air) Section 2 - Medical Section 3 - Labeling and Posting Section 4 - Personal Protective Equipment and Clothing Section 5 - Informing Employees of Hazards from PCBs Section 6 - Work Practices and Engineering Controls Section 7 - Sanitation Practices Section 8 - Monitoring and Recordkeeping Requirements II. INTRODUCTION III. BIOLOGIC EFFECTS OF EXPOSURE Extent of Exposure Metabolism and Mechanism of Action Historical Reports Effects on Huaans Epidemiologic Studies Animal Toxicity Correlation of Exposure and Effect Carcinogenicity Mutagenicity Teratogenicity, and Effects on Reproduction IV. ENVIRONMENTAL DATA AND BIOLOGIC EVALUATION Samizoamaneal Concentrations Ceetrol of Exposure Environmental Scaling end Analytical Methods Biologic Evaluation V. WORK PRACTICES 111 vl 1 3 3 5 6 8 10 14 15 19 21 21 27 31 33 54 66 105 116 126 126 132 133 144 145 vii .K 07930 Tabla of Conciata (Contlnuad) 71. DE7E10PMENT OF STANDARD B u i a for Pravloua Standard! Baaa for tha RtcomtadadStandard VII. RESEARCH NEEDS Vili. REFBRENCES IX. APPENDI! X - Saapllng Froeadura for Collaction of Polychlorlnatad Blphanyla X. APPENDI* Il - Analytlcal Kaehod for Folychlorlnatad Blphanyla XX. APPENDI! Ili - Matarlai Safaty Data Shaat XXX. TABLXS 148 148 152 164 166 191 196 208 218 K'00009 vili N 07931 I. RECOMMENDATIONS FOR A POLYCHLORINATED BIPHENYLS (PCBa) STANDARD The National Institute for Occupational Safety and Health (NIOSH) recommenda that employee exposure to polychlorinated biphenyls (PCBa) In the workplace be controlled by adherence to the following sections. The standard la designed to protect the health and provide for the safety of employees for up to a 10-hour workday, AO-hour workweek, over a normal working lifetime. The standard is measurable by techniques that are*valid, reproducible, andavailable to Industry and governmental agencies. Compliance with the standard should substantially reduce any risk of reproductive or tusorlgenic effects of PCBs and prevent other adverse effects of exposure In the workplace. Employees should regard the recommended workplace environmental limit as the upper boundary for exposure and make every effort to keep exposure aa low as possible. Evidence indicates adverse reproductive and tumorigenlc effects In experimental animalsexposed to certain ccmserclal PCB preparations. Currently available Information Is not adequate to demonstrate that other commercial PCB preparations do not have these effects. Should sufficient information became available to indicate that the standard offers greater or lesser protection from some chloroblphenyl Isomers or cosmerclal preparations than Is needed, It will be consldared for revision. The Toxic Substances Control Act of 1976 (Public Law 94-469) required the US Environmental Protection Agency (EPA) to prescribe marking and disposal regulations for PCBs by July 1, 1977 (Federal Register 42:2656377, May 24, 1977). By this Act, the manufacture, processing, distribution i Aonooio ; K 07932 in commerce, or use of PCBs In any but totally enclosed systems la to be banned, effective 1 year after the date of Its enactment, October 11, 1976. Two years after the enactment date PCS manufacture la to be banned, and processing and distribution In commerce are to be banned 2.5 years from that date. However, the Act allows the Administrator of EPA to rule otherwise If he finds that manufacture, processing, distribution In commerce, or use in other than totally enclosed systems will not present an unreasonable risk of injury to health or to the environment. The Act does not affect use of equipment already containing PCBe In totally enclosed systems, so that a potential for occupational exposure to PCSs will continue to exist for many years as a consequence of their transportation, installation, use, and disposal. The part of the Act specific for PCSs la presented In Figure 1-1. "PCBs" are defined for this recommended standard as commercial preparations of chlorinated biphenyl compounds, Including those preparations which may be described as single isomers or classes of Isomers, such as Decachlorodiphenyl. Biphenyl and its moaoehlorlnated derivatives occurring in commercial preparations of PCBs shall be measured along with the polychlorinated derivatives, and shall be treated in this standard as the polychlorinated components of the preparations. "Occupational exposure to PCBs," Is defined as working with PCBs or with equipment containing PCBs that can become airborne or that can spill or splash on the akin or Into the eyes, or the handling of any solid products that may result in exposure to PCBe by skin contact or by Inhalation. The term "PCB work area" is defined as an area where there is occupational exposure to PCBs. In areas where no occupational exposure to PCBs occurs, AMOOU ; , .N 07933 but where PCBa are present In equipment in the workplace, adherence la required only to Section 8(a). Section 1 - Environmental (Workplace Air) (a) Concentration Occupational exposure to polychlorinated biphenyls (PCBs) shall be controlled so that no worker is exposed to PCBa at a concentration greater than 1.0 microgram total PCBa per cubic meter of air (1.0 ig/cu m ) , determined aa a time-weighted average (TWA) concentration, for up to a 10hour workday, AO-hour workweek. (b) Sampling and Analysis The recom&ended TWA occupational exposure limit for PCBs has been determined to be the lowest reliably detectable limit by the sampling and analytical methods recommended in this document. Environmental samples shall be collected and analyzed aa described In Appendices I and II, or by any methods shown to be at least equivalent In accuracy, precision, and sensitivity to the methods specified. Section 2 - Medical Medical surveillance shall be made available to all employees subject to occupational exposure to PCBs. (a) include: Preplacement or Initial medical examinations for workers shall (1) Comprehensive madleal and work histories with special emphasis on hepatic function, skin condition, and reproductive history. 3 A000012 t: 079 3V4 (2) 'Comprehensive * physical examination with particular attention to the skin and to hepatic function including determinations,, of. . I serum glutamic-oxaloacetic transaminase (SGOT) and serum glutamic-pyruvic i_ transaminase (SG?T) activities. The responsible physician may also wish to II obtain measurements of serum triglyceride concentrations or ofiother '! j indices of fat metabolism. 1 (3) A Judgment of the employee's ability to use positive j pressure respirators. 1 (b) During examinations applicants or employees having medical conditions that could be directly or Indirectly aggravated by exposure to I polychlorinated biphenyls or formulations, containing polychlorinated biphenyls shall be counseled on the increased risk of Impairment of heir i health that might result from working with these substances. (c) Women in the work force who are of child-bearing age shall be i* advised of the potential adverse effects of PCBs on the unborn child. Those who bear children while working with PCBs shall be counseled concerning the advisability of nursing their babies. (d) Initial medical examinations shall be made available to all workers as soon as practicable after promulgation of a standard based on these recommendations. (e) Periodic examinations shell be made available at least annually and Include: (1) interim medical and work histories, and (2) l physical examinations as outlined In paragraphs (a)(1) and (a)(2) of this section. i 1 i I (f) If evidence of adverse effects of exposure to PCBs jls . N II suspected or confirmed, appropriate medical care shall be made available jto the affected worker(s). 1 A o n o o is N 07935 (g) Pertinent medical records shall be maintained for all employees exposed to PCBs in the workplace. Such medical records shall be maintained for the period of employment plus 30 years. These records shall be made available to the designated medical representatives of the Secretary of Health, Education, and Welfare, of the Secretary of Labor, of the employer, and of the employee or former employee. Section 3 - Labeling and Posting All labels and warning signs shall be printed both in English and in the 'predominant language . of non-English-reading workers. Illiterate workers and workers reading languages other than those used on labels and posted signs Ishall be otherwise informed regarding hazardous areas and shall be Informed of the instructions printed on labels and signs. (a) Labeling The following warning label shall be affixed in a readily visible location on PCB-proceseing or other equipment, and on PCB-storage tanks or containers: POLYCHLORINATED BIPHENYLS (PCBs) DANGER! CONTAINS POLYCHLORINATED BIPHENYLS CANCER SUSPECT AGENT Use only with adequate ventilation. Do not gee in eyes, or on skin or clothing. first Aid; In case of skin or eye contact, flush with running water. A000014 N 07.936 (b) Potting Warning placards shall be affixed in readily visible locations in or near PCI work areas The information contained thereon shall be arranged 9' as in the following example, POLYCHLORINATED BIPHENYLS (PCBs) danger: i CANCER SUSPECT AGENT AUTHORIZED PERSONNEL ONLY > Do not enter unless area is adequately ventilated. Do not get in eyes, or on skin or clothing, Piret Aid; In case of skin or eye contact, flush with running water. Section 4 - Personal Protective Equipment and Clothing (a) Protective Clothing la any operation whera workers may coma Into direct contact with PCBs| protective clothing impervious to PCBs shall be worn. Gloves, boots, overshoes, and bib-type aprons that eover boot tops shall be provided when necessary. Protective apparel shall be made of materials which 1most effectively prevent skin contact with PCBs where it Is most likely to occur. Employers shall ensure that all personal protective clothing is inspected regularly for defects and that It la la a d e a n and satisfactory Cfe) Bye Protection Chemical safety goggles, face shields (8-lnch minimum) with goggles, or safety glasses with side shields shall be provided by employers land shall be worn during any operation la which PCBs are present. If liquid or A 00015 6 N 07937 solid PCBs contact the eyes, the eyes hall be Irrigated immediately with large quantities of water and then examined by a physician or other reaponalble medical personnel. (A drop of vegetable oil on the eye haa been found to reduce the resultant Irritation.) Eye protection ahall be In accordance with 29 CFR 1910.133 and ANSI Z 87.1-1968. (c) Respiratory Protection (1) Engineering controls shall be used when needed to keep concentrations of airborne PCBs at or below the recommended TVA occupational exposure limit. The only conditions under which compliance with the permissible exposure limit may be achieved by the use of rsspirators are: (A) During the time necessary to Install or test the required engineering controls. (B) For nonroutine maintenance or repair activities. (C) During emergencies when concentrations of airborne PCBe may exceed the permissible limit. (2) When the use of rsspirators is permitted by paragraph c(l) of this section, respirators shall be selected and used in Accordance with the following rsqulroenta: (A) The employer shall establish and enforce a respiratory protection program meeting the requlroents of 29 CFR 1910.134. (B) The employer shall provide respirators In accordance with Table 1-1 and shall ensure that aployaos properly use the respirators provided. The respirators shall be those approved by NIOSH or the Mining Enforcement and Safety Administration. The standard for approval is specified in 30 CFR 11. The employer ahall ensure that 7 Aftflflote N 07938 respirators are properly cleaned, maintained, and stored when not In use. TABLE 1-1 RESPIRATOR SELECTION GUIDE Concentration of PCBs Greater than 1.0 ig/eu a or Emergency (entry into area of unknown concentra tion) Respirator Type Approved under Provisions of 30 CFR 11 1 (1) .Self-contained breathing apparatus ! with full facepiece operated In pressure-demand or other positive pressure mode (2) Combination Type C suppliad-alr respirator with full facepiece operated In pressure-demand or other positive pressure mode and an auxiliary self-contained breathing i apparatus operated in pressure demand or other positive preseure mode Section 5 - Informing Employees of Hasards from PCBs (a) All new and present employees in any area in which PCBs are used shall be Informed of the hasards, relevant symptoms, and effects of overexposure to PCBs, and the precautions to be observed for safe use and handling of these materials. (by All tployees involved with the manufacture, use, transport,, or storage of PCBs shall be Informed that PCBs have been found to induce I tumors In experlasntal animals after repeated oral Ingestion and that because of these findings It Is concluded that PCBs are potential human i carcinogens; employees shall also be Informed.that adverse reproductive .i " . 8 A000017 N 07939 effects may result from occupational exposure to PCBs. (c) The employer shall Institute a continuing education program, conducted by instructors qualified by experience or training, to ensure that all employees occupationally exposed to FCSs have current knowledge of Job hasards, proper maintenance and cleanup methods, and proper use of protective clothing and equipment, Including respirators. The instructions shall include a general description of the medical surveillance program and of the advantages to the employee of participation. Special attention shall be given to women in the workplace. They shall be made aware of the potential adverse effects of PCBs on the unborn child, and of the known transport of PCBs to breast milk. Elements of the program shall alto Include: Emergency proceduree and drills; Instruction In handling epllla and laaks; Decontamination procedural; Firefighting equipment location and use; Firat-ald procedures, equipment location, and uaa; Rescue procedures; Confined space entry procedures; Low Warning (odor) properties of PCBs. (d) The information explaining the hazards of working with PCBs shall be kept on file and be readily accessible to workers at all places of employment where PCBs ere manufactured, used, stored, or transported. Required Information shall be recorded on the "Material Safety Data Sheet" shown la Appendix H I , or slallar form approved by the Occupational Safety and Health Administration, US Department of Labor. A000018 9 K 07940 Section 6 - Work Practices and Engineering Controls (a) Regulated Areas Access to PCB vork arias shall be regulated and limited to authorized persons* A dally roster shall be kept of persons entering such areas. i (b) Handling of PCBa and General Work Practices *l (1) Operating instructions shall be formulated and, posted where FCBs are handled or used* (2) Transportation and use of FCBs shall comply with all applicable local, state, and federal regulations* (3) FCBs shall be stored in tightly closed containers in vs11-vent11ated areas* 1' (4) When FCB storage containers are being moved, or when they are not In use and are disconnected, valve protection covers shall be in place. Containers shall be moved only with the proper equipment and shall be secured to prevent dropping or lots of control during transport. (5) Storage facilities shall be designed to contain spills completely within surrounding dikes and to prevent contamination of workroom air. (6) Ventilation switches and emergency respiratory equipment ahall bs located outside storsgs areas In readily accessible j locations which will rsmsln minimally contaminated with PCBa in an urgency. (7) Process vslvss end pumps ahall bs readily accessible and shall not ba located In pita or congested areas. (8) Containers and systems shall bs handled end opened with cere. Approved protective clothing ee specified In Section 4 ahall be worn 000019 N 07941 by employe engaged In opening, connecting, and dlaconnectlng FCB containers and systems. Adequate ventilation shall be provided to minimize exposures of such employees to airborne PCSs. (9) FCB-operating and storage equipment and systems sheli be inspected dally for signs of leaks. All equipment, Including valves, fittings, and connections shall be checked for leaks Immediately after FCBa are introduced therein. (10) When a leak is found, it shall be repaired or otherwise corrected immediately. Work shall resume normally only after necessary repair or replacement has been completed, the area has been ventilated, and the concentration of FCBs has been determined by monitoring to be at or below the recommended TWA concentration limit. (c) Control of Airborne PCBs (1) Suitable engineering controls, designed to maintai exposure to airborne FCBs et or below the limit prescribed in Section 1(a), shall be used. Complete enclosure of processes is the recommended method for control of FCB exposure. Local exhaust ventilation may also ba effactiva, used alone or in combination with process enclosure. When a local exhaust ventilation system is used, It shall be so designed and operated aa to prevent accumulation or recirculation of airborne FCBs in the workplace environment end to effectively remove FCBa from the breathing zones ofLjvployees. Exhaust ventilation a y s t m u discharging to outside air must conform to applicable local, state, and federal regulations and must sot constitute e hasard to employees or to the general population. Before maintenance work on control equipment begins, the generation of airborne PCBs shell be eliminated to the extent feasible. 11 N. 07942 Enclosures, exhaust hoods, and ductvork shall be kept in good repa^_. so that designed airflows are maintained. Airflow at eaeh hood shall be measured at least semiannually and preferably monthly, Continuous airflow indicators are recommended, such as water or oil manometers properly mounted at the juncture of fume hood and duct throat (marked to indicate acceptable airflow), A log shall be kept showing,design airflow and the results of semiannual airflow measurements. (2) Forced-draft ventilation systems shall be equipped wit remote manual controls and shall be designed to shut off automatically in the event of a fire in the FCB work area. (d) Special Work Areas (1) FCB Hazard Areas A hazard area shall be considered as any space having physical I characteristics and containing sources of PCBs, such as transformers, that could result in PCS concentrations in excess of the recoumtendad airborne PCS exposure limit. Exits shall be plainly marked, conveniently located, ' 1 and open outwardly into areas which will remain minimally contaminated* in an emergency. ^ (2) Confined or Enclosed Specee Entry Into confined or e n d o e e d specee, such ts tanka, pits, procaaa vessels, and tank ears whsrs there la limited agrsaa, shall be 1 controlled by a permit system. Permits shall be signed by en authorized representative of the eaploysr end ehell certify that appropriate measures have been taken to prevent adverse effects on the worker's health aa a rasuit of his or bar entry into such spaea. ^000021 12 N 07943 Confined or enclosed spaces which have contained PCBs shall be thoroughly ventilated to assure an adequate supply of oxygen, tested for PCBa and other contaminants, and inspected for compliance with these requirements prior to each entry* Adequate ventilation shall be maintained while workers are in such spaces. Leakage of PCBs into such confined or enclosed spaces while work is in progress shall be prevented by disconnecting and blanking the PCS supply lines. Each individual entering such confined or enclosed space shall be furnished with appropriate personal protective .equipment and clothing and be connected by a lifeline harness to a standby worker stationed outside of the space. The standby worker shall also be equipped for entry with approved personal protective equipment and clothing and have contact with a third person. The standby person shall maintain communication (visual, voice, signal line, telephone, radio, or other suitable means) with the employee inside the confined or enclosed space, (e) Emergency Procedures For all PCB work.areas where there Is e potential for the occurrence of emergencies, employers shell take ell necessary steps to ensure that employees are Instructed In, end follow, the procedures specified below is well es any others appropriate to the specific operation or process. (1) If PCBs leek or ere spilled, the following steps shall be taksn: (A) All noseaasntlal personnel shell be evacuated from the leek or spill area. (B) The area of the leek of spill shell be adequately ventilated to prevent the accumulation of vapors. 13 A008022 (C) If the PCBs ere in liquid font, they collected for reclamation or sorbed in vermiculite, dry sand, earth, or similar nonreactive material. (2) Personnel entering the spill or leak area shall be furnished with appropriate personal protective equipment and clothing. All other personnel shall be prohibited from entering the area* ' (3) Only personnel trained in the emergency procedures and I protected against the attendant hazards shall shut off sources of PCBs, clean up spills, control and repair leaks, and fight fires, in areas where PCBs are used. * (4) I All wastes and residues containing PCBs shall be collected in PCS-reslstant containers and appropriately disposed of (Federal Register 42:26563-77. May 24, 1977). (5) Safety showers, eyewash fountains, and washroom facilities shall be provided, maintained in working condition, and located so as to be readily accessible to workers la all areas where the occurrence of akin or eye contact with PCBs is likely. If liquid or solid PCBs are i splashed or spilled on an employee, contaminated clothing shall be removed promptly and the skin washed thoroughly with soap and wapar for at least 15 minutes. Eyes shall be irrigated Immediately with copious quantities of running water for at least 15 minutes If liquid dr solid PCBs get into them. A drop of vegetable oil may be applied to the eye to relieve tde irritating effeet of PCBs. Section 7 - Sanitation Practices (a) Employees occupationally exposed to PCBs shall be provided ACWWW23i i* N 07945 vith separate lockers or dther scorage facilities for street clothes and for work clothes. (b) Employees occupationally exposed to FCBs shall not veer work clothing away from their place of employment. (c) Employees occupationally exposed to PCBs shall be provided clean vork clothing daily, and cleaning^establishments shall be Informed as to the hazards of handling PCBs and proper disposal procedures for PCB contaminated waste water. (d) Facilities for shower baths shall be provided for employees occupationally exposed to FCBs. Workers should shower before changing Into street clothes. (e) Employees exposed to FCBs shall be advised to wash their hands and exposed skin before eating, drinking, smoking or using toilet facilities during the vork shift. (f) Food, drink, or smoking materials shall not be permitted In areas where FCBs are handled, processed, or stored. Section 8 - Monitoring and Recordkeeping Requirements (a) Monitoring (1) As soon as practicable after the promulgation of a standard'based on these recommendations, each employer who manufactures, processes, handles, stores or otherwise uses FCBs shall determine by an Industrial hygiene survey whether occupational exposure to FCBs may occur. Surveys shall be repeated at least once every year and within 30 days of any process change likely to result in occupational exposure to FCBs. Records of these surveys, including the basis for any conclusion thae there 1S AfihW024 K 07946 may be no occupational exposure to PCBa, shall be retained until the next survey has been completed* (2) If occupational exposure to FCBs Is determined ,to be possible, a program of personal monitoring shall be Instituted to measure or permit calculation of the exposures of all employees. (A) In all personal monitoring, samples representative of the employees' breathing zones shall be collected. (B) For each TWA concentration determination, a sufficient number of samples shall be taken to characterize each employee's i exposure during each work shift. Variations In work and production i schedules and In employees' locations and job functions shall be considered In choosing sampling times, locations, and frequencies. (C) Each operation in each work area shall be sampled at least once every 3 months. (3) If an employee Is found to be exposed to FCBs In excess of the recommended TWA concentrationlimit, control measures shall be initiated, the employee shall be notified of the exposure and of:the I; control measures being Implemented to correct the situation, and the employee shall be monitored every 30 days. Such monitoring shall continue until two such consecutive determinations Indicate chat - the employee's exposure no longer exceeds the recoesendsd TWA concentration limit. Routine monitoring may than ba raaumad. (b) Racordkaeplng Environmental monitoring recorde shall be maintained for at least; 30 years after the employee's last occupational exposure to FCBa. These records shell Include the datae and times of measurements, job function end \0 0 0 0 2 5 16 I>; 07947 % location of employee! within the worksite, methods of sampling and analysis used, types of respiratory protection In use at the time of sampling, TWA concentrations found, and identification of exposed employees. Each employee shall be able to obtain information on his or her own environmental exposures. Daily rosters of authorized persona who enter regulated areas shall be retained for 30 years. Environmental monitoring records and entry rosters shall be made available to designated representatives of the Secretary of Labor and of the Secretary of Health, Education, and Welfare. Pertinent medical records for each employee shall be retained for 30 years after the employee's last occupational exposure to FCBa. Records of environmental exposures applicable to an employee should be Included in that employee's medical records. These medical records shall be made available to the designated medical representatives of the Secretary of Labor, of the Secretary of Health, Education, and Welfare, of the employer, and of the employee or former employee. 17 * =- PUBLIC L A W 94-469-- OCT. 11, 1976 90 STAT. 2025 (e) PotiTCHLoiiiKATED B iphenyls.-- (1) Within six months after Rule*, the effective date of this Act the Administrator shall promulgate rules to-- (A) prescribe methods for the disposal of polychlorinated biphenyls, and (B) require polychlorinated biphenyls to be marked with dear and adequate warnings, and instructions with respect to their processing, distribution in commerce, use, or disposal or with respecttoany combination ofsuch activities. Requirements prescribed by rules under this paragraph shall be con sistent with the requirements of paragraphs (2) and (3). (2) (A) Except as provided under subparagraph (B), effective one year after the effective date of this Act no person may manufacture, process,or distributeincommerce or use any polychlorinated biphenyl inany manner otherthan ina totallyenclosed manner. (B) Tlie Administrator may by rule authorize the manufacture, processing, distribution in commerce or use (or any combination of such activities) of any polychlorinated biphenylina manner otherthan ina totallyenclosedmanner iftheAdministrator findsthatsuch manu facture, processing, distribution in commerce, or use (or combination of such activities) will not present an unreasonable nsk of injury to health or the environment. (C) For the purposes of this paragraph, the term "totally enclosed "Totdljnndmcd manner"*means any manner which will ensure that any exposure of nuaacr." human beings or the environment to a polychlorinated Diphenyl will be insignificant as determined by the Administrator by rule. (3) (A) Exoept at provided in subparagraphs (B) and (C)-- (i) no person may manufacture any polychlorinated biphenyl aftertwo yearsaftertheeffectivedateofthisAct, and () no person may process or distributein commerce any poly chlorinated biphenyl aftertwo and one-half yean aftersuch date. (B) Any person may petition the Administrator for an exemption Petitfeafor from the reouirementa of subparagraph (A), and the Administrator may grant uy rula such an exemption if the Administrator finds that-- (i) an unreasonable risk of injury to health or environment would not result,and (ii) good faith efforts have been made to develop a chemical substance which does not present an unreasonable nsk of injury to health or the environment and which may be substituted for such polychlorinatedbiphenyL A n exemption granted under this subparagraph shall be subject to ud such terms and conditions as the Administrator may prescribe end shall be m effect for such period (but not more than one year from the date it is granted) as the Administrator may prescribe. (C) Snbpaisgranh (A) shall not apply to the distribution in com merce ef any polychlorinated biphenyl if such polychlorinated biphenyl was tela for purposes other than resale before two end one halfyean afterthedateofenactment ofthisAct. (4) Any rale under paragraph (1), (2)(B), or (3HB) shall be promulgated in accordance with paragraphs (2), (3), ana <4) of sub section (c). .. (3) This subsection does not limit the authority of the Adminis trator,under any otherprovision of thisAct or any otherFederal law, to take action respecting any polychlorinated biphenyl. FIGURE 1-1. SECTION 6(e) OF THE TOXIC SUBSTANCES CONTROL ACT A000027. N 07949 VJ II. INTRODUCTION This report presents the criteria and the recommended standard based thereon which were prepared to meet the need for preventing occupational disease and Injury arising from workplace exposure to PCBs. The criteria document fulfills the responsibility of the Secretary of Health, Education, and Welfare, under Section 20(a)(3) of the Occupational Safety and Health Act of 1970, to develop criteria dealing with toxic materials and harmful physical agents and substances which will describe...exposure levels at which no employee will suffer Impaired health or functional capacities or diminished life expectancy as a result of his work experience.M The National Institute for Occupational Safety and Health (NIOSH), after a review of data and consultations with others, formalized a system for the .development of criteria upon which standards can be established to protect the health and to provide for the safety of employees exposed to hazardous chemical and physical agents. Criteria and recommended'standards should enable management and labor to develop batter engineering controls resulting in more healthful work environments Mere compliance with the recommended standard should not be used as a final goal. The## criteria for a standard for PCBs are part of a continuing aeries of criteria developed by NIOSH. The reeosnended standard applies to the processing, manufacture, and handling of PCBs as applicable under the Occupational Safety and Health Act of 1970. The standard was not designed for the population-at-large, and any application to situations other than Occupational exposures is not .warranted. It la intended to (1) protect A0flft028 . K 0795 against -acute and chronic PCB poisoning, (2) be measurable by techniques that are available to Industry and official agencies, and (3) be attainable with existing technology. i ' The standard la designed to substantially reduce the risk-; of I development of carcinogenic, adverse reproductive, hepatotoxlc, and dermatologic effects, Since 1970, PCBa have been' one of. the more ii thoroughly investigated environmental and occupational hazards. Nevertheless, there are important gaps in the knowledge of chronic exposure effects In man at low concentrations of ?C3s. Important research needs include studies on the reproductive histories of women who have been i exposed to PCBs, and quantitation of the dermal and respiratory absorption I I of different mixtures of PCBs. A better understanding is needed of the I ! i contaminants in commercial PCB preparations, particularly studies to determine the extent to whleh any chlorinated dlbenzofurans In tissues of PCB-exposed American workers result from direct absorption or are darlved from PCBs In the body. Another need is for an assessment of the hazards associated with the mobilization, during fasting or In other abnormal physiologic states, of PCBs stored in the body. ^00029 N 07951 U- 20 III. BOLOGIC EFFECTS OF EXPOSURE Extent of Exposure Biphenyl (C 12H 10), diagrammed In Figure III-l, can be chlorinated by replacing any or all of Its hydrogen atoms with chlorine [1]. Figure III-l. BIPHENYL MOLECULE AND RING NUMBERING SYSTEM Specific chloroblphenyl molecule are designated by reference to the positions of the chlorine atoms according to the numbering scheme depicted In Figure III-l. The lowest possible numbers are assigned, and the phenyl moiety with tha fewest chlorine atoms Is assigned prime numbers [1,2]. Examples of the nomenclature used here are shown In Figure III-2. C1 C1 Cl C1 a 3-Hjfclorobiphenyl 'a* 2,2*,3,4', 5-pentaehlorobiphenyl Figure III-2. EXAMPLES OF NOMENCLATURE SYSTEM OF CHLOROBIFHENYL COMPOUNDS There ere three monochlorobiphenyl compounds, 2-, 3-, and 4chlorobipheny1. The 5- and 6-monochiorobiphenyIs are identical to 3- and 2-oonochloroblpheayl, respectively. There are 18 dlchloroblphenyl 2i AOOOftoO .K 07952 r compounds, The number of possible chlorobiphenyl Isomers and the corresponding weight-percents of chlorine are presented in Tabl III-l, TABLE III-l NUMBER OE ISOMERS AND PERCENT CHLORINE FOR THE 10 CHLOROBIPHENYL (PCB) CLASSES Chlorobiphenyl Empirical Formula No. of Isomers Weight Z Cl mono di tri tetra penta hexa hepta octa none deca C 12H9C1 C 12H8C1 2 C 12H7C1 3 C 12H6C1 4 C 12H5C1 5 C 12H4C1 6 C 12H3C1 7 C 12H2C1 8 C 12BC1 9 C 10C1 10 Adapted from reference 1 3 12 24 42 46 42 24 12 . 3 1 18.79 31.77 41.30 48.56 54,30 58.93 62.77 65.98 68.73 71.18 1 In the commercial synthesis of chloroblphenyls 9 biphenyl is catalytically chlorinated with anhydrous chlorine; either iron filings or ferric chloride may be used as the catalyst [1]. The cosmerelal preparations, commonly referred to as "PCBs," are Isomeric mixtures. The weight-percent chlorine In commercial mixtures has generally varied between i 21 and 662 sad has been used to designate grades of commercial products. Commercial PCB products manufactured in the U S t Great Britain, and Japan i have been marketed under the trade name " A r e d o r " [1*3]. Several grades of Aroelor have been designated by numbers such as 1221y 1242, 1254, and 1260 i where the last two digits represent the percent by weight of chlorine in A000031 N 07953 the mixtures. Another grade of Aroclor, 1016, made primarily of tri- and tstrachlorobiphenyl compounds and containing 41Z chlorine by weight, was introduced In 1971 to replace Aroclor 1242 [2,4,5]. Other FCB products manufactured in Japan were marketed as "Santotherm" [1], and "Kanechlors" 300, 400, 500, and 600, containing approximately 42Z, 48Z, 54Z, and 60Z chlorine, respectively [6]. In Germany, products marketed- as "Clophens" A50 and A60 contained 54 and 60Z chlorine, respectively [7]* In France, PCBs were marketed as "Phenoclors" and "Pyralenes;" P h e n o d o r DP6 contains 60Z chlorine [8]. Other countries reported to have produced PCBs are Italy, Spain, Czechoslovakia, Poland* Argentina, Brazil, the USSR, and India [1,9,10]. The chloroblphenyl constituents of several commercial PCB products have been studied [6-8,11-16], Some data, both qualitative and quantitative, are presented in Table XII-2. About half the 209 possible chloxobiphenyls do not occur in any of the commercial preparations. Among those compounds which do not occur, or which occur in trace smounts only, are 3-chloroblphenyl, all of the tri- to pentachloro compounds that are chlorinated in only one ring, the pence-, hexa-, and heptachloro compounds that are completely chlorinated in one ring, and the pence- and hexachloro compounds that are chlorinated in four positions in one ring. Hi-- inisi PCBs are insoluble in water, but are soluble in oil and many organ!! solvents. Sosa other physical and chaolcal properties of certain Aroclor products are presented in Table XII-1 [1]. In addition to chlorinated biphenyls, the conerelal mixtures with 20-40Z chlorine contained biphenyl from about 11Z to traces, respectively, by weight. Kany commercial PCB products a l s o . contain chlorinated r:23 000032 07954 dibenzofurans [17-23] k and naphthalenes [18,19], Concentrations of t chlorinated dibenzofurans in various commercial PCB products are presented j in Table III-2, TABLE III-2 CHLORODIBENZOFURAN TYPES AND CONCENTRATIONS Qig/g) IN COMMERICAL PCB PREPARATIONS Mixture* di tri Chlorodlbanzofurans tetra pence hexa hepta Total i Ref. j (1) 1016 (1) 1016 (1) 1248 (1) 1254 (1) 1254 (1) 1260 (1) 1260 (2) A-60 (3) DP-6 (4) K300 (4) K400 (4) K500 (4) K600 0,5 (c)*** (e) <0,001 0.5 0.1 0.2 0.1 0.2 1.4 0.7 (a) (a) (a) <0,001 1.2 0.2 0.4 0.4 0.3 5.0 10.0 (a) <e> (a) (a) <0,001 0.3 1.4 0.9 0.5 0.3 2.2 2.9 (c) (a) <b) (b) 0.5 2.0 1.7 1,5 1.0 0.8 8.4 13.6 1-1.5 17-18 2.5-4 3-5 ** 21 21 21 21 21 21 21 21 20 20 20 20 { 14 V *. r ^ I '' **(I Pomarantz, written communication, January 1977) 's *** (a), (b), (c), (d), (a) represent relative amounts la increasing order Sene cooMrcial preparations that were marketed under the trade nsae Aroclor contained chlorinated terphenyls la addition to chlorinated biphenyls. Areclors 2565 and 4465 contained 75Z and 60Z chlorinated biphenyl compounds aad 25Z and 40X chlorinated terphenyl compounds, respectively. Both mixtures contained 65Z chlorine [1]. A broad class of nonfleasable synthetic chlorinated hydrocarbon Insulating liquids used In electrical capacitors, transformers, nuclear 40000.13 24 N 07955 reactors, and accessory equipment Is designated by the generic term "askarel" [4,5,24,25]. FCBs Have been major components of most askarels used In the US since 1932. Tvo general classes of FCB-contalnlng askarels are "capacitor"-grade and "transformer"-grade [4,5]. Aroclor 1242 was the major capacitor impregnant In the US before 1971; subsequently, Aroclor 1016 has been used mainly for this purpose [4]. Transformer?grade askarels manufactured In the US Include those marketed under trade names Including "Ashestol," "Chlorextol," "Inerteen," "No-Flamol," "Pyranol," and "Saf-TKuhl" [4]. Transformer-grade askarels are usually mixtures of trichlorobenzene and more highly chlorinated (42-602) biphenyls [5,24]. Some typical compositions are: 100Z Aroclor 1242; 70Z Aroclor 1254 and 30Z trichlorobenzene; 60Z hexachloroblphenyl and 40Z trichlorobenzene; 45Z hexachloroblphenyl and 55Z trichlorobenzene; and 70Z pentachiorobiphenyl and 30Z trichlorobenzene. Another type of transformer-grade askarel contains 45Z polychlorinated biphenyl (54Z chlorine) and 55Z of a mixture of trl- and tetrachlorobenzanes. Transformer-grade askarels also contain stabilizers such as g l y d d y l phenyl ether and 3,4-epoxycyclohexylmethyl-3, 4-epoxycyclohexane carboxylste [24]. Exposure to conserelal preparations of FCBs In the work environment may Involve many different chlorinated biphenyl compounds, and also substantial amounts of biphenyl, trl- and tetrachlorobenzenes, and small amounts of many different chlorinated dlbenzofurans, chlorinated naphthalenes and In special uses, chlorinated terphenyls. Commercial production of FCBa In the US began in 1929 and reached 85 million pounds In 1970 when the major producer began selling FCBs only for use in " d o s e d " systems. Since 1972, only those Aroclors designated 1016, 23 N 07956 - '"*353 1221, 1242, and 1254 have been produced in the US, and total annual production haa been around 40 million pounds [26], < i Imported PCBa amounted to about a half-alllion pounds In 1972 and * Ii 1973 [26,27], A decachloroblphenyl produced In Italy and Imported by one company for use In investment casting vexes accounted for 8Q-90Z ofithe total PCB Imports [26]. The other 10-201 was Imported from France for use In semldosed heat transfer applications [27], Occupational exposure to decachloroblphenyl could occur in the manufacture of the Investment castling vexes ea veli as in the preparation of the investment casting molds in the 25 US foundries vhlch use the decachloroblphenyl vax [26], Most of the PCBs produced in the US since 1971 have been usedjin i electrical capacitors (70S) and transformers (30Z) About 95Z of the 100 million capacitors produced annually in the US contain PCBs [27], There is potential occupational exposure to PCBs in the plants of the 17 reported companies that manufacture capacitors la the US, Capacitors are generally i classified into tvo categories for disposal purposes. "Small" capacitors I contain less than 2 pounds of PCBs; these incorporated into electrical equipment such as television sets hose air conditioners, and light fixtures contain 2-340 si of PCBs and have service lives of ae least 10 years [26,28]. "Large" capacitors may contain about 25 liters of PCBs [26] and have a service life of 15-20 years [26,27]. Potential occupational exposures exist la the servicing of appliances and la the disposal of used capacitors or equipment. ! Transformers that contain PCBs are used mainly in or near inhabited buildings vhera fire hasards from cheaper oil-filled transformers are greatest. The estimated 135,000 PCB-containlng transformers represent i, Af-P(MW5 . 26 .N 07957 ^ about 52 of all transformers in the US [27]. Occupational exposure to various aalearels used for transformers may occur in their manufacture, servicing, and transportation, or as a result of leaks [29]. Other potential occupational exposures to FCBs exist through losses in storage [30], shipment [29], manufacture and use of heat exchange units [27.31] , and in use of previously manufactured items which contain FCBs, such as hydraulic systems, vacuum pumps, and gas transmission turbines [30.31]. The past use of FCBs in carbonless copying papers may result in exposure of workers currently engaged in paper reclamation '[30]. Workers in plants that previously used PCBa may have current exposure in their working environments because FCBs have been shown to remain in the workplace air and on surfaces for years after FCB uaa has been discontinued [32,33]. Several occupations that may have Involved exposure to PCBs were tabulated in a 1966 publication [34]. NIOSH estimates that 12,000 workers have potential occupational exposure aa a result of current uses of FCBs in their working environments [33]. - In addition to their occupational exposures, FCB workers may be exposed to PCBs carried into their homes from the workplace [36], from 1i general contamination of the ambient air [26,37,38] and water [26,37], and to PCBa and their metabolites in their diets [39-46]. Metaboliam and Mechanism of Action A study of the metabolism of 4-chlorobiphanyl was reported In 1959 by Block and Cornish [47]. In this experiment, 1 gram of 4-chloroblphanyl was fad to rabbits In a single dose and 4*-chloro-4-blphenylol and its 27 li A0079im58i6 glucuroniside were recbvered from the urine in amounts that accounted for 24 and 502 respectively of the administered do9e. Subsequently, a substantial number of metabolic studies of individual | chloroblphenyl compounds [41-43,48-64], mixtures [85,86], and metabolites I [48,49,87] were reported, and a comprehensive review was published in 1976 [ [88]. These reports collectively demonstrate through many study methods 1 that some aspects of metabolism are of special significance to the toxicity i of FCBs and that some Isomers are more toxic, or have different effects, than others [89-94]. Chlorinated biphenyl digestive tract, regardless substitution [50,51,95,96]. j i compounds are readily absorbed from ttie i of the degree or pattern of chlorine ! It seems likely that similar absorptive characteristics apply to the respiratory system since chloroblphenyl mixtures in air are rapidly absorbed [97], as is decachloroblphenyl [98,99]. Varying amounts of chlorobiphenyls, depending on degree anti I pattern of chlorination, are excreted in the feces [42,50,53-56,100], milk i [41-44,51,101], and hair [102] of animals, but no more than trace amounts are excreted in the urine [42,51-55,57-62,103-105]. 1 i Metabolites of chloroblphenyl compounds have been found in the urine of mammals Including mice [52], rata [48,53-56,58-60,63,64,66,71,85]j t rabbita [63,47-69], monkeya [51,61,74,75], swine [72], goats [73], and cows i [41,73], a well as in feces [48.50-54,56,58-65,76-80], and milk [41]. The metabolites excreted in urine [53,54,58,59,61,63,64,66,67], bile! [50,51,53,81], feees [52-54,58,63,76], and milk [41] are, to varyingj agrees, conjugated with glucuronic or sulfuric acids. Differences iaj metabolism of FCBs among the aforementioned species are more quantitative A000Q3# 28 N 07959 i than qualitative [51,73]; hovever, metabolism In birds and fish may differ qualitatively from that In mammals [55,77]. Among mammals there are also quantitative differences in PC3 metabolism and In effects related to age and sex [50,93,106], Metabolites identified In mammals include mono- to polyhydroxylated derivatives [41,48,49,51-56,58-81,85], and methoxy [59,60], hydroxymethoxy [64,65,68,70,76,87], _ dihydrodihydroxy [51,53,54,69,74,75,81], hydroxydihydrodihydroxy [51,74], and dechlorinated derivatives [48,65,70,77]. The lover-chlorinated biphenyl compounds are more readily metabolized than are the more highly chlorinated ones [41,50,51,55,61-64,66,82- 84,96,107-109], with no metabolism having been demonstrated for decachloroblphenyl [66]. As a consequence, some of the more highly chlorinated compounds persist in the tissues for years after Intake has been discontinued [51,83,103,110]. The presence of at least tvo adjacent, unsubatltuted hydrogen atoms, particularly In positions 3, 4, and 5, or 3', 4', and 5 f, is required for rapid metabolism of chloroblphenyls [79,83,84]. All mono- dl-, and trlchloroblphenyls, and all tetrachloroblphenyla except 3,3',5,5'- tetrachlorobiphenyl meet this requirement. The latter compound, 3,3',5,5'- tetrachloroblphenyl, vas found to be particularly toxic to monkeys, and it was suggested that the chlorinated dlbenzofuran derivative may have been Involved [94]. While dlbenzofuran derivatives have not been demonstrated to exist as m f si fsit metabolites, they may have been identified as PCB metabolites In chickens [111] and Curley et si [22] reported the excretion of dlbenzofurans in urine of rats. In the latter case, hovever, dibenzofurans were also identified In the administered PCB [22]. 29 Dibenzofurana are of concern because they may be many times more toxic1than i PCBs [19,1121. i i Metabolites found in urine [48,51,53,56,60,61,64,66-74,85], bile [81], faces [51-53,56,58,60,61,64,66,76,79,80,113], and Bilk [41] include 1 hydroxy derivatives. Such compounds have been demonstrated to be more ,,i toxic than their respective parent chlorobiphenyl [41,114] and their presence in milk [41] is of special concern. Hydroxylation may be direct through hydroxylating enzyme systemsj or through formation of arene oxide Intermediates [48,51,53,68,75,81,87,115]. This latter process is of particular concern because of potential i carcinogenesis and mutagenesis as a result of covalent binding of arene oxides to nuclear components of the cell [51,68,74,82,86,116]. Such binding has been demonstrated both in vivo [51,86] and in vitro [51,82,86,116,117]. Additional evidence of hydroxylation through arne oxide intermediates included findings of metabolites in which chlorine, dueterium, or tritium were at different molecular locations than in the administered compound [68,115,116,118], and tranadihydrodiola as mammalian metabolites [51,69,74,75,81]. i Although adjacent unaubstltuted hydrogen atome are necessary for rapid metabolism of chlorinated biphenyls, it has been demonstrated that 2,2*,4,4f,5,5'-hexachlorobiphenyl, which does not have this characteristic, can be hydroxylsted [70,79], and oxidatively dechlorlnated [65,70]. It has t been proposed that the metabolism of this compound may also Involve arene oxide formation [65], and chronic exposure to potential carcinogenic activity of resulting arene oxides [86] may result from the metabolism of 3 this and similar compounds [75]. A0000.^9 30 tf 0 7 9 6 1 ; Historical Reports Smyth [119], In a paper read October 28, 1930, presented the results of'his studies with biphenyl, 2- and 4-chlorobiphenyl, and two unidentified polychlorobiphenyl mixtures. He reported the oral minimum lethal doses for rabbits and guinea pigs as 4+, 2.5, 3.5, 4+, and 4+ g/kg, respectively. Health problems associated with the manufacture of PCBs were the subject of a report by Jones and Alden [120] In 1936. The case history was presented of a man whose employment, from April 1930 to the end of 1933, involved the distillation of chlorobiphenyl. In May 1933 he developed chloracne, a specific type of acne known to be caused ,by some chlorinated hydrocarbon compounds [121,122]. Jones and Alden [120] stated that the manufacturing process was not enclosed, that a different source of benzene (a starting ingredient) had been used from the. summer of 1932 through October 1933, and that from March to October 1933, the dielectric qualities of the PCBs produced had been substandard. Of 24 men working in the manufacturing process during the period beginning In the summer of 1932, 23 developed chloracne. The first Indication of chloracne in the workers 'v appeared in January 1933. Following another change in the source of benzene, enclosure of the distillation apparatus and Installation of ventilation fans, a gradual improvement In the acnelform eruptions was noted. In 1936, Schwartz [123] reported digestive disturbances, burning of the eyas, and Impotence in men working with chloroblphenyls. He also noted that nonachloroblphenyl was used as an Insulator for automobile electric vires. In capacitors, and as a delusterer of rayon* A000040 31 N 07962 An early use of PCBs was for incorporation along w it chloronaphthalenes into synthetic waxes [124-128], These vexes contained J 10-20Z PCBs [124-126] and were used to insulate electrical wire and'cable. There were several reports that chloracne [125-128] developed in workers Involved in the manufacture and use of these waxes which were associated vI with at least one fatality in 1936 [125,127]. . 1 The fatal case was described by Drinker et al [125] in 1937 The patient, who had been exposed to low concentrations of tetra-f and pentachloronaphthalenes (902) and chlorinated biphenyls (102) developed I chloracne, .followed by jaundice. He vas hospitalized with abdominal , pain and distention. At autopsy, cirrhosis of the liver with superimposed acute yellow atrophy was found. Two other fatal cases were described where; the exposures had been to mixtures of penta- and hexachloronaphthalenes [125], I According to the authors, no similar cases had been reported in the literature. As a result of these fatalities, estimates of the airborne concentrations of chlorinated hydrocarbons in 30 different factories |vere made and animal experiments were performed to study the affects of exposure at such concentrations. i Rats, were exposed 16 hours/day, 6 days/week to trlchloronaphthalenes at 1.31 mg/cu m, to a mixture of penta- and hexachloronaphthalenes at 1.16 mg/cu , to a mixture of penta- and hexachloronaphthalenes (90Z) and J chlorinated biphenyls (10Z) at 1.37 mg/cu m, and to a chlorinated biphenyl mixture containing 64Z chlorine at 0.57 mg/cu m. The authors [125] stated i that higher concentrations had frequently been found In the factories, and that except for trlchloronaphthalenes, they did not consider that it would 1 be safe to expose workers to any of the mixtures at the concentrations i A000041 32 i\ N 07963 During July 1972 through June 1974, 2,324 fat samples were analyzed by the Human Monitoring Survey, 1,277 in the first year and 1,047 in the second [136], In the 2 years, respectively, FCBs were not detected in 24,5 and 9.12, were present at <1 ppm in 40.2 and 50.62, were present at >2 ppm in 5.5 and 4.92, and were present at 1-2 ppm in the remainder of the samples. Fence-, hexa-, and heptachloroblphenyl were 'the PCBs most frequently present. A complete analysis of FOB compounds in a composite sample of adipose tissues from patients at the University Hospital in Lund, Sweden, was reported by Jensen and Sundstrom [7] in 1974 Forty-five compounds, accounting for the total PCS content of the adipose tissues, were found and identified by comparison with known FCB isomers The biphenyl compounds included three tetrachloro Isomers, many penta-, hexa-, hepta-, octa-, and nonachloro Isomers, and decachlorobipheayl By comparison with Clophens A50 and A60, which had compositions similar to Areclors 1254 and 1260, respectively, the authors [7] found the relative concentration of several compounds with chlorine substitution in the 4,4' positions of the biphenyl ring to have occurred, as did many compounds without vicinal, unsubstituted positions. Most of the compounds whleh underwent, relative dilution to the greatest extent had either vicinal, unsubetltuted. 3,4-positions or two pairs of vieixal, unsubetltuted positions. Blood sera of 616 residents of urban and rural areas of South Carolina were analysed for PCBe and the results were presented by Flnklea at el [137] In 1972. Analysis was accomplished by GLC with a Nl-63 electron capture detector after basic dahydrochlorlnatlon. The amounts of PCBs present were estimated by Integration of five peak areas associated 3S I! 07967 water [26,37], and In many foods [39,45,46], A common dietary intake f 10-20 Mg/day has been estimated for teenage males in the US [46]. PCBs frequently have been found in various tissues and body fluids of the S population, eg, at ppm concentrations in adipose tissue [7,36,134-136], ppb concentrations in blood [137,138,140,141], and In milk [143,144] at ppm or ppb concentrations in the milk fat or whole milk, respectively. The Environmental Protection Agency's Human Monitoring Survey has analyzed human adipose tissue samples collected since late 1968 for PCB content [134]. According to this 1972 report, 637 samples had been analyzed, and 198 of these contained more than 1 ppm of PCBs* Positive findings were made In tissues from each of the 18 participating states. A detailed analysis of two samples collected In the Human Monitoring Survey was made by gas-llquld chromatography (GLC) and mesa spectrometry (MS) and reported by Biros et al [135] In 1970. The samples contained ait least 14 Isomers ranging from penta- to decachloroblphenyls. Price and Welch [36] stated that of more than 4,000 human adipose tissue samples examined by the Michigan State Department of Health Peetleldes, none had chromatograms that exactly matched those of standard Aroclor solutions. \Their data show relative accumulation In adipose tissue of the more highly chlorinated compounds, and relative dilution or absence of the less highly chlorinated compounds originally present la Aroclors 1254 and 1260. They [36] described the analyses of tissue samples at autopsy of a 77-year-old man In which PCB concentrations of 100-250 ppm (fat basis) were found. Th highest PCB concentration was in the liver. The authors [36] found about 55Z of adipose tissue samples in the general population contained PCBe at <1.0 ppm, about 36X at 1-2 ppm, and the remainder at more than 2 ppm. A000043 34 ' N 07966 and 600, The data suggested nohselective in utero transfer of PCB compounds from mother to fetus. Concentrations of PCBa in human embryonic and fetal tissues were reported by Shiota et al [139] in 1973 to not exceed those found in postnatal individuals who died accidentally. The concentrations, found in 19 embryos 5*8 weeks old, were reported as <2 ppb. The concentrations found in 5 second trimester and 2 .third trimester fetuses are presented in Table III-4, expressed on the bases of both whole tissue and on the fat content of the tissue. TABLE III-4 CONCENTRATIONS (ppb) OF FCBs IN TISSUES OF HUMAN FETUSES Age of Placental Basis Contents Cerebrum Tissue Analyzed Liver Kidney Skin 2nd trimester 3rd trimester One sample Whole Fat Whole Fat Adapted from reference 139 2-23 150-60 2* 270* 2-33 230-800 6-20 17-83 60-1,900 550-1,300 25-90 6-10 1,000-1,300 420-470 48-769 880-1,400 PCB cpscentratlons In the venous blood of nine patients hospitalized with severe wasting diseases were reported by HSsselberg and Scharr [140] in 1974, The investigators were concerned with the release of stored organo-halide pesticides and PCBa during mobilization of body fat* they were unable to detect any PCBs In the blood of 15 apparently healthy 37 N Q7969' A000044 with Aroclors 1254 and 1260, PCBa were not present in samples from all individuals in quantities measurable by the technique used (Table III-3). Analysis of the data indicated that measurable serum PCB concentrations were not related to tha age (<5 to >60 years) or sex (305 females, 311 males) of the donor, but that the concentrations associated with race and i residence (Table III-3) were statistically different. ' 1 TABLE III-3 PCB CONCENTRATIONS IN BLOOD SERUM BY RACE AND RESIDENCE i Race and Residence No. in Sample PCBa Measureable In o. Z PCB Concentrations Ave* Max ppb ppb Rural black Urban black Rural white Urban white 107 151 192 166 5 4.67 57 ` 37.75 119 61.98 89 53.61 9.45 5.22 5.12 4.38 20.6 29.0 16.6 22.0 Average of measureable concentrations Adapted from reference 137 , ,\ Maternal and cord bleed samples collected In Tokyo, Japan from ; December 1973 through February 1974 were reported in 1975 by Akiyama et el . [138] to contain PCBa at mean concentrations of 2.8 and 1.1 ppb, , respectively (on a whole blood basis) The maximum concentrations found 1 vers 7.6 ppb in maternal blood and 3.3 ppb In cord blood. Quantitatively, 1 significant correlations of FCB concentrations in 21 pairs of maternal and j cord blood samples, vers not found. Qualitatively, pairs of maternal and i i cord bloods had identical PCB patterns resembling chose of Kanechlors 500 ] A000045 36 H 07968 There were differences In chromatographic patterns between individuals! but for each individual the chromatographic patterns for the adipose tissue and the milk vert qualitatively the same. PCBs in all samples contained principally 4-8 chlorine substitutions* Although the basis (fat or whole milk) for expressing the concentration of PCBs in the milk was not stated, comparisons with PCB concentrations found in adipose tissue and milk by other investigators indicate that the whole milk basis was used [136,144] (EP Savage, written communication, February 1977). Concentration data are summarized in Table IZI-5* TABLE III-5 PCBS IN MILK AND ADIPOSE TISSUE OF FOUR WOMEN Subject PCB Concentrations, ppm Adipose Tissue Milk a b c d Adapted from reference 143 0.62 0.75 1.6 3.1 0.008 0.015 0.032 0.036 Concentrations of PCBs measured in milk samples from 39 women living in two small eitiee in Colorado were presented by Savage et al [144] in 1973* Two samples contained PCBs at concentrations of 0*03 and 0.1 ppm. Six other samples contained PCBs at 0.04 ppm, the lover limit of detection for the analytical method, or less. The time postpartum at which the samples were collected and the basis (fat or whole milk) for expressing the concentrations were not mentioned. (Comparison with data in the following 39 A 0 0 0 0 5 6 ,N 07971 control subjecta. PC? concentrationa found In the patients1 blood (uncorrected for efficiency of recovery) ranged from 10 to 100 ppb. Information vas not presented on the patients' occupations etc prior to their having become ill. FCB concentrations in blood plasma and in adipose tissue samples obtained from 23 people during routine abdominal sections.had a correlation coefficient of 0.74 according to Inoue et al [141]. The average concentration of PCBs was 6,113.52 ppb in blood plasma, and in the adipose j tissue (fat basis) it vas 2.611.9 ppm. These Investigators [141] also evaluated the effect of emaciation on FCB concentrations in blood plasma of these and other patients; they found an average of 8,414.26 ppb in 19 emaciated patients and 4,712.17 ppb in 30 uncmaclated patients. Hair samples collected from a college barber shop were reported by i Matthews et al [102] in 1976 to contain PCBs at 0.34-0.76 ppm. The samples were composites from five or mors individuals collected on tvo occasions, 4 1 months apart. Hair vaa collected from the barber shop aprons, and care vas taken to avoid possible contamination. Five commercial preparations of hair sprays, shampoos, and hair clipper lubricating oil were * PCBs. Blood samples vera not collected for comparison. negative for PCBs vera reported in 1966 to have been found in hair samples from three members of a Swedish family [142], but no concentration data ware given. Ic was speculated that one of the'family members, a 5-year-old girl, had acquired PCBs from her mother's milk. A correlation vas found betveen the quantities and compositions of PCBs In samples of adipose tissue collected from four women during Caesarean deliveries and in milk samples collected 3-5 days later [143]. A"00047 33 M 07970 (approximately 50 each) "were registered in Fukuoka and Nagasaki prefectures as of September 1973 (161]. In the prefectures of Hiroshima, Kochi, and Yaaaguchi, there were 60, 45, and 40 cases, respectively, at that time. In each of the other 17 prefectures there were 1-25 registered cases. The total number of cases registered by March 1970 was 1,015; by September 1973, the number had Increased to 1,200, and by May_1975 to 1,291 [161.162] . The disease became known as "Yusho," or rice oil disease [145.163] . The outstanding signs of the poisoning were acnelform eruptions and eye discharges (a. peculiar secretion from the meibomian glands) [146]. Chloracne was suspected [164]. Hyperpigmentation of the skin, nails, and mucous membranes, swelling of the upper eyelids, and hyperemia of the conjunctlvae were other common signs [146,165], Studies of the rice oils consumed by the patients Indicated that the oil associated with Yusho was produced mainly during February 1968 [147,148]. The source of the contamination was determined to be a heat exchange unit containing PCBe.that leaked through tiny holes when rice bran oil was heated at low pressure to remove odorous constituents [163,165]. By intensive chemical analyses, including Infrared spectrophotometry and GLC, the major contaminant in the rice bran oil was found to be Kanechlor 400 [147]. FOB concentrations in the oil varied, depending on the data of production or shipment. The highest concentration of PCBs, based on the chlorine content of the oil, wee about 3,000 ppm which was found in canned oil shipped on February 5. GLC data were not quantitated. In oils shipped thereafter, FOB concentrations decreased rapidly, and only traces were found In oils produced after February 19, 1968 [147,148], Minor contaminants in the rice oil Included polychlorinated dlbenrofurans at A000058 41 N 07973' paragraph suggests that'the whole milk basis was used.) Results of analyses of 334 human milk samples from 40 states for FCBs were presented in a written communication by EP Savage in February 1977. All positive samples that contained FCBs at less than 50 ppb on a whole i' milk basis were recorded as a "trace." Semples with 50 ppb or more of FCBs were reported as ppm In milk fat on the basis of 2.8% milk fat. Only five samples were not positive for FCBs, and 112 samples from 27 states I^ contained measurable amounts (up to 12.6 ppm on a fat basis). Of the total number of samples, 141 were analyzed during December 1976 and January 1977. The-time, postpartum when the samples were collected was not stated. While no adverse effects have been associated with FCBs at the concentrations found in adipose tissue, blood, or milk of Individuals whose only known exposures were 1from general environmental contamination [7,36,102,136-144], knowledge of these concentrations is Important to the evaluation of reports on occupational exposures. That Is, the data provide a basis for evaluating body burdens of PCBe added by occupational exposure and Indicate that workers may have substantial body burdens before the added Insult of occupational exposure. (b) Effects from Consuming PCI Contaminated Rice Iran Oil \ An episode of , poisoning associated with FOB Ingestion occurred in Japan in 1968, and was the subject of a special Issue of the journal1 i Fukuoka Aeta Medlca In June 1969 [145-159]. These reports dealt primarily with the situation In Fukuoka prefecture where 325 poisoning cases had been *( [l identified through January 20, 1969. The episode resulted from consumption^ of a particular brand of rice bran oil [160] and ultimately involved ! I. persons In 22 prefectures [161]. About equal numbers of cases i. A' 0 0 0 4 9 0 .N 07972 about 1/200 of the* PCB concentration [20,160], traces of chlorinated naphthalenes, and bromine at about 2% of the chlorine content [147], Recent analyses of some of the oil samples Indicate that there may have been other chlorinated organic contaminants (F Cordle, written communication, November 1976). In one study [148] , the contaminated rice bran oil was found to have been used largely for frying food (which may have altered the constituents). The oil vaa consumed for various periods during the spring through October 1968 [148]; the first reported clinical examination of a Yusho patient had occurred on June 7, 1968 [163]. Studies through January 1969 of patients in Fukuoka prefecture indicated that onsets of Yusho began as early as February and as late as December 1968, and first Involved the eyes [146]. Onset occurred In most patients in June, July, and August [146]. Some attempts vers made to estimate the amounts of rice oil and FCBa consumed by the patients [166,167]. Maximum consumption of oil was estimated at 4.4 liters [166]. Isono and Fujlvara [167] estimated that two Yusho cases may have resulted from the ingestion of FCBs at a dally rate of 67 ;ig/kg body weight for 3 months. For 146 Yusho patients who lived in homes known to have used oil shipped on February 5-6, the estimated average total oil consumption was 800 ml, a volume that contained an estimated 2 g of FCBa [166]. It was estimated that the maximum volume of oil consumed by e an Individual was 2.7 liters. Of 21 patients who had consumed more than 1,400 ml (3-4 g of PCBs), 18 were considered to have had major signs of Yusho. Among 80 patients estimated to have consumed less than 720 ml of the oil, 31 were thought to have had major signs of'Yusho. From the same 42 A000050 N 07974- ; data, the minimum PCB ingestion among the 146 patients was estimated at 0.5 g [165], Estimates of the amount of contaminated oil consumed by 13 pregnant women during the ingestion period ranged from 300 to 2,600 mg [167], but estimates of their PCB consumption were not made. Of the 13 babies born to these women, 8 had jaundice, 3 had marked dermal chromopexy, and 9 had excess secretion of tears [167], Several studies of PCBs in the tissues snd body fluids of Yusho pstients were made at various intervals after ingestion of the contaminated oil [146,147]. The samples taken closest to the time of ingestion were collected in October and November 1968 [146,147], Samples from discharges of the acnelform eruptions of two patients contained PCBs at 32 and 45 ppm, .and samples of subcutaneous fat from the face and abdomen of an 18-year-old man contained PCBs at about 75 and 13 ppm, respectively. PCBs with GLC patterns similar to those of the contaminated oil were found in these samples as well as in placental and fetal tlseuee [147], Preserved tissues from a baby that had been stillborn in October 1968 were later analyzed and PCB concentrations of 1.8, 1.2, and 0,1 ppm in fat were found in the liver, skin, and fat, respectively [168], The baby's mother had been classified as a severe case of Yusho with onset about mid-June, but the amount of oil consumed, the period of pregnancy during which it was consumed, and the body burden of the mother were not. reported [149], PCBs *rere found in all sputum samples from 13 patients collected between December * 1969 and May e 1970 [169,170]. PCB concentrations were highest In December and detection wee lees cosnon by Kay. Other data on concentrations of PCBs were obtained from body fat and other tissues taken from five Yusho patients at autopsy [168,171]. The A0 0 0 05 1 43 N 07975 dates of death were between July 1969 and Kay 1972, Cause of death was heart failure in four cases and a ruptured liver in another case [171], Estimates of contaminated oil consumed by two of the dead patients were about 0,3 g and 1.6 g, respectively [171], One PCB, probably a hexa- or heptachloroblphenyl from the contaminated oil, was especially concentrated in the tissues* The peaks associated with tetrachloroblphenyls were very low by comparison, suggesting that total PCBs in the body had been substantially decreased within a year after the end of exposure. The mesenteric fat contained FCBs at 0.9-15.1 ppm, and the liver contained 1.310,4 ppm in its fat. PCB concentrations in fatty tissues obtained during 11 control autopsies averaged 2,6 ppm. Of the organa examined (liver, heart, kidney, brain, and skin), the liver and heart usually contained the highest concentrations of PCBs [168,171], In an additional case, the subcutaneous fat obtained on autopsy of a woman who died in September 1972 (about 2 years after consuming contaminated oil) contained FCBs at 2.9 ppm [168], Polychlorinated dlbenzofurana (PCDFs), mainly penta- and hexachloro compounds, were found in tissues obtained on autopsy of two Tusho patients who died in 1969 and of one who died in,,1972 [160] , No chlorinated dlbenzofurana were found In tissues obtained on autopsy of two controls, although PCB concentrations of about 1-1.5 ppm were found in adipose tissue and liver fat. The findings from the Yueho patients are summarized in Table III-. f i N 07976 TABLE III-6 PCBs AND PCDFs (ppm) IN FAT FROM THREE YUSHO PATIENTS AT AUTOPSY Year of Death PCBs Adipose Liver PCDFs Adipose Liver 1969 3,4 1969 8.5 1972 2.1 Adapted from reference 160 4.7 5.6 3.5 0.03 0.04 0.01 2.3 1.1 0.3 The ratio of PCBa to FCDFe In the rice bran oil was about 200, aa In the adlpoae tissues obtained at autopsy* Hbvaver, In the liver, ratios of i 2, 5, and 12 Indicate that considerable concentration of PCDFa had occurred. Information on PCBa [146,147,168,171] and PCDFa [160] In tissues j 1 Indicates some shifts In concentrations during the 3 years after Ingestion of the contaminated oil was discontinued. Kasuda at al [168] reported that i a year after ingestion stopped, the concentrations of tetrachloroblphenyl components had decreased and vara naar those found In persons who had not Ingested the contaminated oil. The more highly chlorinated PCB compounds were still retained in the fatty tissue 4 years after Ingestion had stopped [168]. Blood from Tueho patients was first examined for PCBs 5 years aftar ingestion of the contaminated oil ceased. Three distinct GLC patterns were found among blood samples from 49 patients [172-175]. Two patterns (A and B) were peculiar to the Yusho patients, and the third pattern (C) was y k or>f>oro 45 N Q7977 similar to that of controls. Patterns A and B were characterized by peaks corresponding to those of certain penta- and hexachlorobiphenyl compounds that were present in the contaminated rice bran oil.. Patterns A and B differed, however, aa to the relative amounts of these compounds [172,173]. These patterns became diagnostic for Yusho [161]. The average concentrations of PCBs in the blood serum were 9, 4, and 2 ppb for patients with patterns A, B, and C, respectively, and 3 ppb for 27 control subjects [173]. The maximum blood serum FCB concentration found among 72 Yusho patients examined between April 1973 and March 1974 was. 26 ppb [174]. Of these patients, 43 had pattern A, 26 had pattern B, and 3 had pattern C. Similar ,patterns were reported in 1975 by Abe et al [176] in a 1974 study of 18 female Yusho patients and their 30 children, Concentrations of PCBs in blood samples from mothers ranged from 3 to 33 ppb during 1974; PCBs in samples from their children ranged from 1 to 20 ppb, and in samples from 14,control children, from 1 to 8 ppb. PCB concentrations tended to be higher in the blood samples from children nursed by Yusho mothers * A sample jof milk from a Yusho mother was reported in 1974 to contain PCBs with a GLC pattern similar to those In samples of fatty tissue from ocher Yusho patients [168]. Concentrations- of PCBs in the mother's milk were 0.06 ppm on postpartum days 0-2, 0.04 ppm on days 3 and 4, and 0.03 ppm on day 5. The respective concentrations in the milk fat were 4.5, 3.0, and 2.6 ppm. In addition to the skin and eye conditions manifested by most people who consumed the contaminated rice bran oil [146,151-153,162], there was pigmentation of the nails [146] and of the oral mucosa [154]. A substantial array of clinical and laboratory findings were published on 46 N 07978 ^considered indicative of microornai enzyme etiaulatlon [156], symptomatic <' functional changes indicative of neuropathy [150,177], respiratory : Involvement [170,178], a decreased concentration of bilirubin in the serum , 179], and, in many patients, an elevation of the concentration of triglycerides in the serum [155,157,158,175,179-181]. Babies born to women with Yuaho, both during and after the period of ingestion of the contaminated rice bran oil, were the subject of several investigations [149,159,176,182,183]. Babies^ of mothers who had ingested 'the contaminated oil became known- as "black" or "cla" babies because of rthe abnormal skin pigmentation that tended to persist for several months lifter their birth [176,182,183]. Infants born up to 5 years after their 'aethers' last ingestion of contaminated rice oil were still affected to some extent [182], In one study of four babies, other clinical and anatomical abnormalities (retarded intrauterine growth in three, edematous face and exophthalmic eyes la three, dentition in two, calcification on skull and vide, open sagltal suture of skull in three) were seen at birth [183]. These were not permanent, and postnatal body and mental development appeared notati in these and other Yuaho children [160,176,183]. In at least one casa an Investigator concluded that a baby had developed Yusho from nursing [182]. The period of ingestion of contaminated rice bran oil was only a few months, but the effects have persisted for several years [160,161,174,175,179,180,184,185]. The skin lesions and hypersecretion 47 H 0 7 9 7 9 from meibomian glands remained unchanged for long periods In many patients [174,184,185]; their magnitudes in 1974 appeared to be related to blood PCS concentrations [174]. In addition, complaints of generalized fatigue, and symptoms referable to the peripheral nervous system and to the respiratory system became more prominent. In 1974 these complaints and symptoms were established as part of the diagnostic criteria for Yusho [161]. These additional symptoms vere not related to the PCB concentrations in the blood [174], Elevated serum triglyceride concentrations vere found to be related to the concentration of FCBs in the blood serum [175], and Inversely related to the bilirubin concentrations In the serum [179]. The average serum triglyceride concentrations measured annually in 14 Yusho males from 1969 through 1974 ranged from 159 mg/100 ml In 1969, to 174 mg/100 ml In 1972, to 160 mg/100 ml In 1974 vlthout any significant changes from year to year. In 29 Yusho females, the concentrations Initially (1964) averaged 153*161 mg/100 ml, but decreased in 1973 and 1974 to 129 and 111 mg/100 ml, respectively [180]. The Yusho population of about 1,300 persons has been followed closely and records indicate that as of Kay 1975, 29 of them had died [162]. Deaths have been due to a variety of causes such as accidents, suicides, cardiac problems, and cancers. Malignant neoplasms vere found in at least nine cases [161], from which Kuratsune et al [160] concluded that there was s suggestion of excess deaths but chat no more could be aeld because information essential for analysis was not available. The relevance of the Yusho episode to occupational PCB exposure is compromised because: (1) the oil was Ingested; end (2) It contained large 48 \000056 N 07980 concentration* of dibenzofurans compared with those In the PCBs to which worker* generally have been exposed in their occupations. Its relevance is i further compromised because the effects observed from dally ingestion of 1- 15 mg of PCBa [165,167] were peculiar and excessive compared to those observed in workers exposed by inhalation to PCBa at 1-5 mg/cu m [120,125], i notwithstanding that the amounts absorbed may have been similar. I Nevertheless, information obtained from the Yusho episode is relevant to the study of PCB toxicology and occupational exposure. The information establishes that PCBs can be transmitted from mother to fetus, and, in the milk, from mother to child. It also establishes chat some PCB compounds are eliminated from the body relatively rapidly, and that others may require years for elimination. (c) Occupational Exposures Chloracne was among the earliest reported effects associated with . worker exposure to PCBs [125*128], It was not clear in some early reports that PCBs were contributing to the chloracne because PCBs usually constituted 10-202 of mixtures containing 80-902 chloronaphthslenes, a i previously known cause of chloracne [121,122], An early report that associated chloracne with PCBs in the absence of chloronaphthslenes was 1 that of Jones and Alden [120] in 1936 the manufacturing process was; i largely an open one and the workers were also exposed to benzene, biphenyl,, and other conpounds incidental to PCB manufacture. Over the years, cases, of chloracne associated with occupational exposure to PCBs have continued i to appear [186-196], Other effects associated with PCBs in early reports Included digestive disturbancesi eye irritation, liver injury* and Impotence | N 07981 f i t 49 [123,125], Elkins [130] reported in 1950 that the average concentration of FCBa in the workroom air of several plants In Massachusetts ranged frpa 0,1 to 5.8 ag/cu m. Maximum concentrations ranged from 0.2 to 10.5 mg/cu o. No evidence of immediate toxic effects was observed except at FOB concentrations approaching 10 mg/cu m, which the workers, found to be unbearably irritating. Three cases of severe chloracne were described by Pucclnelll [186] in 1954. The affected employees worked in a factory that produced capacitors Impregnated with Aroclor 1254. The workroom was 24 x 9 x 5 meters. Capacitors were heated to about 100 C In a 3-cu m autoclave to remove moisture, and then Impregnated with the Aroelor while in the autoclave. The temperature In the autoclave was reduced about 12 hours later. When the autoclave was opened, the temperature of the Aroclor vae 70-80 C. The capacitors were removed and carried to another location for finishing. Originally, one autoclave was used, but eventually eight were in operation, and FCB emissions to the workroom air occurred almost continuously. Concentrations of FCBs In 500-liter samples of air were found to vary from 5.2 mg/cu m in the center of the room, to 64 mg/cu m around the finishing operation, to 6.8 mg/cu m near the autoclave during removal of the capacitors. The three chloracne cases were in men, 18-24 yesra of age. They had worked in the factory for 2-4 years, and developed the first signs of ehloracs* 4-8 months after their exposures began. Other than chloracne, the men appeared healthy, and all findings, including liver function tests were reported as normal. Eight Other cases of chloracne associated with PCB exposure during the manufacture of radio capacitors were described by Hofmann and Meneghini N 07982 [187] in 1962. In the process, PCB vapors were generated by heat. The cases included one man and seven women, 20-37 years of age, who were exposed to PCBs 2.5-4 months before onset of signs of chloracne. The face was involved in six cases; ocher Involved areas varied, but included the i arms,' neck, upper torso, pubes, buttocks, and thighs. The case of a 21- yeer-old woman was described in detail. The first signs of chloracne appeared on her face 4 months after she began work, and aha was observed by the authors [187] 4 months later. On the face, a dirty brown coloring appeared. A hyperpigmented spot with shaded areas was present on the forehead. Subsequently, her buttocks and pubes became Involved. Exposure concentrations were not mentioned. Severe chloracne was described by Birmingham [188] in 1964 in 13 of 15 workers exposed to an Aroclor which was a mixture of bi- and terphenyls (65Z chlorine content). An enamel containing the Aroclor was painted onto glass and then baked in an oven. Faulty ventilation caused contamination by chlorinated hydrocarbon vapors. exposure were not given. Exposure concentrations and duration of \ An additional case history published in 1969 Involved a 43-year-old man exposed to PCBs in an electrical component factory [189]. He developed chloracne on the forehead, face, arms, and thighs within 3 months after! beginning work handling racks of electrical parts that had been dipped in hot PCBs. Exposure concentrations and actual durations' of exposure were 1 not stated, but it was reported that the man had put his hands in the ` mixture without skin protection for a long time, and that his clothes often became Impregnated with the PCBs. On examination 8 months after transfer to another job in the same room, papules, comedones, and pustules were 000059 si N 07983 found on his forehead, scalp, face, and arms. Although the man had been removed from direct exposure to PCBs, their odor was present In the men's new work area. It was reported that this was the first case of chloracne In the plant, where more than 100 workers had been engaged In the process for more than 20 years. A company that used PCBs at two manufacturing facilities provided testimony on employee health in 1975 (In the Matter of General Electric Company, File No. 2833, New York State Department of Environmental Conservation). Examination of records submitted as testimony Indicated that exposures were to an askarel [25] containing, by weight, about 60% of Aroclor 1254, 40% trichlorobenzene, and 0.0115-0.135% diepoxide scavengers. From the records submitted, It was not possible to determine the precise numbers of male and female workers. The exact occupations of the workers could not be determined either but a substantial number of "crimpers" was Indicated. The records shoved that employees had reported to the dispensary complaining of skin rashes and dermatitis on 49 occasions during the previous 15 years. Only the fingers and hands were Involved In 21 complaints, only the arms and hands in 5, and only the face and legs in 1 In 7 other complaints the face, neck, and legs were mentioned In 4, 2, and 1 casesrespectively, In addition to the upper extremities. Associated with the complaints of skin rashes end dermatitis were some complaints of itching of the face (2), neck (1), eyes (1), arms (2), and hands (1). A generalized skin rash was the basis of 14 additional cosq>lalnts. One worker developed the generalized rash on exposed parts of his body after only 2 days of working with the askarel. 52 AO<W$60 N' " '` studied [125], Further details of the animal experiment were reported by Bennett et el [129] in 1938. These investigators [129] found morphologic changes in the livers of tvo groups of rats exposed at the 0,57-mg/cu m concentration and also at 0*93 mg/cu m for 8 hour a/day. These animal; I experiments reported by Drinker et al [125] and by Bennett et al [129] have1 continued to be erroneously cited [130,131] even though' Drinker [132] 1 reported in 1939 that the "chlorinated biphenyl" vaa actually a mixture of chlorinated biphenyls and chlorinated terphenyls. Drinker [132] stated i that a followup inhalation experiment with chlorinated biphenyls containing 68Z chlorine shoved them to be of low toxicity and he recommended < i permissible limits for workroom air of 0.5 mg/cu m for mixtures of , i chlorinated biphenyls and biphenyls. terphenyls and 10 mg/cu m for chlorinated 1 *i The first Indication in the literature that PCBs might be embryotoxlc i or have teratogenic effects was the report by McLaughlin et al [133] In . 1963, 5 years prior to the rscognitlon of FCBs as an environmental pollutant. The authors evaluated the toxicity of Aroclor 1242 by Injecting j It Into the yolk sac of fertilized eggs prior to incubation, and then observing the effects on embryonic development. None of the egga hatched after Injection with 25 ag of PCBs/egg; with Injection of 10 mg/egg, one chick hatchet oat of 20 injected eggs, but It died 2 days later. Some of the embryos esaalaed shoved beek deformities edema, end retarded growth. Effects on Humane (e) Effects from General Environmental Contamination ^Inithe United States, FCBs art present in ambient air [26,37,38], Annoo6 i K 07964 The company physicians attributed the rashes to allergic or contact dermatitis caused by exposure to the askarel. Treatment included the use of creams, and temporary or permanent removal from exposure. Of the 49 complaints, 22 were second episodes, and in these cases the workers were removed permanently from exposure to askarels. One female employee who had dermatitis of the fingers was removed from exposure for 12 days. Within 2 days of reexposure she again reacted to the askarel and was permanently removed from such work. Over the same 15 years, other kinds of complaints were made by the workers on 16 occasions. These complaints -included burning sensations of the eyes (7), nose (1), and face (1); dry throat (1); asthmatic bronchitis (3); nausea (1); dizziness (1); and aggravation of acne (1). In moat of these cases, the company physicians recommended permanent removal from exposure. The health status of eight laboratory workers who routinely analyzed dielectric fluids containing PCBa was reported by Levy et al [197] in 1977. The men were 25-49 years of age and had been employed 2.5-18 years. Breathing zona, point source, and general work area air sample* ware collected on magnesium silicate at 50 ml/minuta over the workday on three occasions. The breathing zone samples contained FCBe et 0.014-0.073 mg/cu m. Sample# taken near an oven contained 0.042-0.264 mg/cu m, and general room area p l e a contained PCB* at 0.013-0.15 mg/cu m. The blood FCB concentrations In the worker* were 36-286 ppb.- The most common complaint of the vorkera (6 of 8) was dry or ore throat. Other complaint* were skin rash (3 of 8), gastrointestinal disturbances (3 of 8), eye irritation and headache (each, 2 of 8) Findings on examination of the eight workers were y N 07984 A000062 I akin rath (1), natal Irritation (2) rales (1), and elevated blood pressure (4), No liver, apleen or neurologic abnormalities were found by physical examination. There vere no caaea o*f chloracne. rSerum alkaliine phoaphataae, SCOT, SGPT, and total bilirubin, measured In seven subjects, vara all within normal limits. In addition, medical records of AO other i exposed employees ware examined, revealing two cases of slightly Increased SGOT, two elevated serum triglycerides, and one case each of increased serum alkaline phosphatase (SA?) activity, total serum bilirubin, and serum uric acid Epidemiologic Studies I An outbreak of dermatitis among workers in a Connneetlcut chemical j plant was described In 195A by Meigs et al [190], FCBs had been | substituted for molten salt In a heat exchange unit without modification of !' the syetem. There were alight, hue obvloua, vapor leaks under certain conditions, and tha concentration of PCBa In the.workers' breathing 2 ones was determined to be 0.1 mg/cu m. No employee worked regularly ,et points ' "V of leakage, end tha oparaelons, as described, continued for 19 months. Mild to moderate chloracne on the face, forehead, and eare developed In 7 of IA expoeed workers; the meetold region of one worker eleo was affected. The duration of expoeure before the initial eigne occurred, ranged upward from 5 months end averaged 1A months The average length of 1 \ expoeure wee 11 months for those who did not develop chloracne, with one worker shoving no eigne after 19 months. Liver function teste vere performed on the seven workers who. had developed chloracne. Clinical teste Included direct end total serum bilirubins, 24- end 48-hour cephalln A000063 1 54 N 07985 flocculations, thymol turbidity, and SAP activity. Findings were normal in six workers, and borderline increases in cephalin flocculation and thymol turbidity were found in the seventh worker with chloracne. Thirteen months later, the thymol turbidity test had Improved, but cephalin flocculation had not changed. All cases of chloracne were stated to have cleared up after an unspecified treatment. Control of vapor emissions by welding all joints in the heat exchange unit prevented recurrence [190]. Exposures of workers to PCBs in six industrial plants were discussed by Hasegawa et al [191] in 1972, The concentrations of PCBs found are summarised in Table III-7. TABLE III-7 RANGE OF FCB CONCENTRATIONS (jig/cu m) IN WORKROOM AIR Factory, Function No. Samples A PCB manufacture 6 B Capacitor manufacture 3 C Biphenyl recovery 2 D Capacitor manufacture 2 E ii 3 *1 sample **6,270 .due to spillage Adapted from reference 191 PCB Concentrations Vapors Particulates 26-163 120-350 13-15 350-540 95-965 19-37 20-125 4* 48-6,270** 73-650 ss 000064 N 079B6 PCBs were manufactured in one plane and used in manufacturing capacitors in four planes (one had discontinued use of PCBa 1 month *i \ earlier). Biphenyl, not chlorobiphenyls, was present in the sixth plant [191]. Air samples were collected in tvo fractions. A fraction associated vlth particles >0.1ji vaa collected on filter paper, and a fraction i containing vapors and particles <0,1jj In diameter was collected in two *i serially-connected midget implngers containing n-hexane. Samples were i collected only from places where high concentrations of PCBs were expected and not from the factory where FCB use had been discontinued. The vapor concentration exceeded the particulate concentration In all) except the sample taken after spillage. Particulate matter wasj { characterized by GLC as containing the same chloroblphenyl composition as 1 the*PCB product used In the plant, whereas the vaporized material contained' i one less chlorine atom/molecule than the FCB used In the plant. j FCBs were measured In the blood of the employees of six plants, including 99 exposed workers and 32 controls U91], Concentrations of PCBs | in the blood sera of exposed workers averaged 370 ppb, whereas controls averaged 20 ppb. The workers exposed to FCBs In the those of the plant that i' i i ; I had discontinued PCI use had serum PCS concentrations of 90 to 730 ppb j i (average 460 ppb). Based on data from three of the plants, no relationship * was found between duration of exposure (from <1 to 20 years) and c o n c e n t r e d of PCBs la the blood [191]. Complaints of dermal ailments seemed to be unrelated to the blood PCB concentrations and were considered to be due more to direct contact of the skin with PCBs than to generalized intoxication. The principal dermal findings Included brown ehromoderaatosis of the dorsal Joints of the hands i i 000065 56 N 07987 and fingers and of the nail bed, and acneiform exanthema* The latter also involved the jaw, back, and theighs in several cases. The investigators [191] considered that there was a definite effect of PCBs on fat metabolism as shown by decreases in the concentrations of total, free, and esterifled cholesterols in the blood, and by trends in the same direction for neutral fats, total glycerides, phospholipids, and beta-lipoprotein in the blood. There was evidence of mild disturbances of liver function manifested by increased SGOT, SGPT, and SAP activities and decreased activity of serum cholinesterase. These enzyme activity changes were not considered to be clinically significant. Studies of 38 current and 80 former employees of a capacitor factory in which Kanechlor 500 had been used from 1954 to about 1960 and Kanechlor 300 had been used from about 1960 to 1972, with PC3 use having been discontinued in April 1972, were reported by Rara et al In 1973 [192] and again in 1974 [193]. (Presumably, this factory was the one stated by Haeegawa et al [191] to have discontinued use of PCBs.) Current, workers included 17 who were engaged in the capacitor immersion process; the remaining 21 workers were engaged in finishing and assembling operations. The study concentrated on the 17 i s e r s l o n process workers. During exposure to PCBs In March 1972, the concentrations of PCBs In the whole blood of the immersion workers ranged from about 7 to 300 ppb, and were closely related to years of exposure. One year later, blood PCB concentrations had all decreased, but by varying amounts. For example, one of two workers who initially had PCB concentrations in their blood of about 180 ppb had a concentration of <10 ppb 1 year later, while the other one had a concentration >100 ppb. The average PCB blood concentration for the 57 A00006B 17 workers decreased to about 75Z of the original value. Based o n 1;blood samples collected about 6 and 12 months after use of FCBs was discontinued, i l the blood PCB half-lives for the Immersion workers vers calculated. It was found that the greater the duration of exposure, the greater the PCB half- life (1 year of exposure, 3 months half-life; 10-15 years of exposure, 30 months half-life). This indicated to the Investigators.that blood served as a PCB carrier, whereas fat served as a depot tissue [192], i While working with PCBs, many of the total group of employees* had dermal complaints (blaekheads, 45Z; aenelform eruptions, 37Z; skin i irritations, 13Z) [192], A year after discontinuance of exposure to PCBs, these conditions had Improved noticeably and only one or two blackheads remained. No correlation was apparent when concentrations of PCBs and i triglycerides in the sera of a large number of workers were compared graphically. The workers were also studied about 18, 24, and 36 months after use of PCBs had been discontinued [193]. During this period, blood PCB concentrations decreased to about 10-20 ppb in all but two workers who i had been exposed to PCBs for 9 and 15 years. The skin disturbances were reduced to vestigial markings on a few individuals. Ceeiparlsons with the concentrations of triglycerides and PCBs in the sera of these workers i indicated that the proportion of workers with significant Increases in triglyceride concentrations increased as the concentrations of PCBs increased Of nine workers with blood PCB concentrations >30 ppb, five had elevated triglyceride concentrations. Examinations of 13 workers from an electrical capacitor manufacturing *i plant for clinical manifestations of PCB toxicity were reported by Kitamura at el [194] In 1973. Examinations vers performed when the company Aonoo$?, - if i 58 N 07989 v'S discontinued the use of PtBs In June 1972, and were performed twice subsequently at 3-month Intervals. The average length of worker exposure to FCBs had been about 2.5 years. Innnediately after discontinuance of PCB use, the average PCB concentration in the blood of workers was 820 ppb, ranging from 320 to 2,100 ppb [194]. The mean concentration fell to 310 ppb after 3 months, and to 200 ppb after 6 months. From these observations, Kltamura et al [194] estimated the biological half-life of the PCBs in the blood immediately following the cessation of exposure to be about 90 days. No consistent correlation could be found between the concentration of PCBs in the blood and the duration of exposure to PCBs. Nail, hair, and gum color and color of the mucous membranes of the oral cavity all were normal. Ten of the workers had varying degrees of skin disorders on different parts of their bodies. The skin disorders included seborrhea adiposa, acne vulgaris, and follicular papulae on parts of the body where direct contact with the PCBs normally did not occur. The authors [194] concluded that PCBs probably had been an Important factor in the etiology of the skin disorders and that results of blood tests, hepatic function tests, and urinalyses were normal. Serum triglycerides were not determined. A study by Inoue et al [195] of the health of workers in family-owned silk-thread glossing factories in which PCBs were used was published in 1975. The study was initiated because PCB concentrations exceeding 100 ppb had been found in the blood of a 73-year-old man who had undergone surgery. His family operated a household thread-glossing factory. The family members and the hired helper were studied. Serum concentrations of PCBs resembling Kanechlor 500 ranged from 130 to 520 ppb. There was a close 59 5 , correlation between the PCB concentration in the blood and the degree.of 1I involvement in the glossing work. The head of the household had skin lesions and comedones on the face, back, and ears and had blood IjCB concentrations of 190-210 ppb. The rest of the people had practically no skin abnormalities, and other findings (not described) were, in general, considered of minor significance. A study of FOB contamination of the premises and the air of the same factory was reported by Fujiwara et al [33]. At the time the samples were taken, use of FCBs had been 1 discontinued. However, FCBs ware found in sir at 0.25 mg/cu m, in floor 1 boards at 80-130 ppm, in the dirt under the machinery at 10-900 ppm, and In the dust on steel frame beams at 110-180 ppm. The FCBs were similar to those in Kanechlor 500. 1 i Subsequent to the above study. Inoue et al [195] reported on the PCB rl concentrations in samples of blood obtained from 54 other similarly *- " employed people. PCB concentrations of over 100 ppb, 50-99 ppb, 10-50 ppb,, ! and 0-9 ppb were found in 2, 5, 19, and 28 persons, respectively.! i Correlative comparisons with the various functions performed in the! i factories shoved thee those workers who had direct contact with the, * ii glossing machines, those who maintained and repaired the machines, and , i those who had over 20 years of work experience had the highest ; concentrations of PCBs in their blood. i Skin abnormalities and other i findings la these 54 persons were described as relatively mild. One of the ' persons studied* a "woman in her 10th month of pregnancy, had a serum PCB | concentration of 24 ppb. Following birth, the mother and daughter were , described as healthy with no evidence of abnormalities. The concentration i of FCBs In the mothers's milk was found to be 0.25 ppm, and after 60 07991 N consultacin, sha stopped nursing her baby [195]. In 1974, Sato and Hasegawa [32] discussed their findings on PCB residues in the workers and in the air of pressure-sensitive (''carbonless") copying paper manufsecuring plants 2 years after PCB use had been 1 discontinued. A PCB product comparable to Kanechlor 300 was still detected in the workroom air of four of five factories at concentrations ranging from 0.13 to 4.A fig/cu m; in one factory PCBs comparable to a mixture of Kanechlors 300, 400, and 500 were found at concentrations ranging from 0.15 to 1.2 fig/cu n. Concentrations of PCBs in the blood sera of these workers, as measured by GLC, ranged up to 73 ppb, compared to a maximum of about 20 ppb in controls. The authors [32] concluded that the blood PCB concentrations in the workers were still elevated. `PCB concentrations in the blood of three groups of employees with different PCB exposure histories were presented in 1972 by Karppanen and Kolho [198]. The first group of four men and five women had no known occupational exposure to PCBs. The six women of the second group had been exposed while handling PCBs in an analytical laboratory. The third group ~v of eight men and four woman had worked, since 1968, in a plant where Aroelor 1242 was impregnated into capacitors. The authors [198] stated chat the workroom air of the capacitor factory met internationally accepted limits (p^astaably <1 mg/cu m), and that protection of the skin had been given special; attention. PCB measurements were made by GLC, using electron capture detection. The unexposed group had blood PCB concentrations of^ 5.6-12 ppb, the analytical laboratory workers had concentrations of 36-63 ppb, and ths capacitor plant workars had concentration? of 74-1,900 ppb. Subcutaneous adipose tissue samples from two of the unexposed workers 61 HHWU 7992 r contained- PCBs at 1.5 and 2.3 ppm; PCBs In-their blood expressed as i concentrations in fat of the blood were 6,6 and 9.9 ppm, respectively. ( In i three capacitor plant workers, adipose tissue samples contained PCBs at 160, 285, and 635 ppm; PCBs in their blood, expressed as concentrations, in their blood fat, were 400, 305, and 700 ppm, respectively. All persons examined were in good health. The capacitor plant workers had been under I special medical observation but the investigators were unable to detect any I biologic effect from the PCBs. > An epidemiologic Investigation of 37 refuse workers who were f potentially exposed to PCBs emitted from incinerated waste was described!by i Bumgarner et al [199] in 1973, The control group consisted of 36 workers from a lumber yard. Faired samples of scalp hair and blood were collected. ! PCS residues In the hair and blood plasma were extracted and analyzed by I- GLC with electron capture (EC) detection; rough quantitation was by evaluation of five peaks associated with Aroclors 1254 and 1260, The lover i limit of detection was 1 ppb. Hematocrit, blood cholesterol, and blood i pressure also were determined. PCB residues In the blood plasmas of the controls were detected in four workers and the maximum concentration was 4.2 ppb. Measurable concentrations of PCBs were found in the blood samples of 32 of the 37 refuse workers; the average and maximum concentrations were about 4 and 14 ppb, respectively. The concentrations of PCBs in plasma were not related to duration of exposure, age, or race, PCBs were not i: detected In hair samples (limit of detection, 1 ppb). Hematocrit, blood cholesterol, and blood pressure values did not change at different PCB i concentrations, i N 079931, A0o0r0 071 62 1 / A survey of the health of 34 workers exposed to Aroclor 1242 during manufacture of capacitors was discussed by Ouv et al [196] In 1976. The Aroclor was an electrical-grade material that contained "no Impurities." Breathing zone samples were collected In Implngers containing Isopropanol. It Is not clear If all samples were collected from the breathing zones. Nineteen workers were assigned to fill capacitors with Aroclor 1242 heated to 70 C. These workers were exposed to FCBs at 1.08-1.44 mg/cu m. The other 15 workers, located In a different room, were assigned to assemble Aroclor-dipped capacitor components. These workers were exposed to FCBs at 0.32 mg/cu m. None of the 34 workers used protective clothing. PCBs In the blood were separated by GLC and Identified by their retention times relative to aldrln. PCBs were not detected In the blood of 30 control subjects. For the two groups of PCB-exposad workers, averages of measurable blood FCB concentrations are presented In. Table III-8. TABLE III-8 AVERAGE OF DETECTABLE BLOOD FCB CONCENTRATIONS (ppb) OF TWO GROUPS OF WORKERS Exposure Group No. Workers FCB Retention Time Relative to Aldrln 0.69 1.31 1.47 1.96 Fillers 19 602(19)* 314(17) 391(13) 475(4) Assemb1ers 15 140(14) 100(14) 899(5) J (0) Numbers In parentheses are the numbers of workers In whom more than a trace of the FCB peak was detected. Adapted from reference 196 63 A000072 'N' 0799.4 J Distribution of PCBa in the blood of workers exposed while filling \ the capacitors differed from that of workers who assembled the components. i The higher boiling components were present more frequently and to a greater extent In the fillers. Twelve of the workers (5 of < i 19, and 7 of 15) complained of mild a burning and irritation of the face, eyes, and akin, and 3 of these had eczematous rashes on the hands and legs* ' One filler had chloracne1. i Although individual abnormalities were found in SGPT, SAP, and blllrubinj the average values for the exposed workers were within normal limits. *i Bromsulphothaleln retention testa were found to be elevated in four of the seven fillers whose blood PCB concentrations were >500 ppb. The; 1 investigators [196] reported no evidence of significant adverse responses! ! to PCB exposure in the workers with blood PCB concentrations below 200 ppb.1 Subsequently, "more efficient" exhaust ventilation was Installed and 1 the workers were advised to wear "suitable Impervious gloves" [196], Air i measurements, made after the ventilation change, indicated that the fillers < ( were being exposed to PCBs at 0.18-0.75 mg/cu m and the assemblers at 0.08 | mg/cu m. These were substantial reductions. However, blood PCB ; i concentrations that were found In 15 workers reexamined 2 months after the j i ventilation change did not show any substantial reductions. The , investigators [196] speculated that this might have been because the 1 workers did not strictly follow the reeoanendatlou to wear protective j \ clothing. | Based on a search of chart rscorda, Baha (HA Sinclairs, written ! communication, June 1976) reported a preliminary study of the Incidence of , 4 canger in s group of 51 research and development employees end 61 refinery */'ron73 64 n 07996 ; " i plant employees at a New Jersey petrochemical facility who were considered likely to have been exposed to Aroclor 1254 for various periods between 1949 and 1957. The eight cancers observed in the study population through December 31, 1975 were not significantly more chan would be expected (5.7) in a similar sample of the US population [200]. However of the eight cancers, the three melanomas and the two cancers of the 'pancreas were significantly different from calculated expectations. Some findings of this preliminary investigation were described in a letter from Bahn et al [201] to the editor of the New England Journal of Medicine. In this preliminary study, FCB exposure histories were based oh recollections of two company employees. Exposures to other chemicals could not be ascertained. The expected cancer rates were based on US population data rather than on a rate for the locality of the petrochemical facility. To correct these deficiencies in the preliminary study, a more intensive investigation is being conducted (BN Kightlinger, written communication, November 1976). A substantial change has occurred in the cohort since release of the preliminary report by Bahn and her coworkers, and it seems likely that the findings on this new cohort will differ significantly from those of the preliminary study. The final report is not yet available. In a study of current end former employees engaged in the manufacture of PCBs, no eases of malignant melanoma or pancreatic cancer were found from a review of the case histories of more than 300 employees (G Roush, written communication, September 1976). Seven cases of lung cancer were found from the death certificates of 50 former employees compered to an expected number of 2.7. The data are preliminary and were not corrected for age or smoking habits. The final report is not yet available. J\ 65 N 07996 Animal Toxic1tv i 1 Although there have been a few reports of dermal and Inhalation experiments with animals, most of the information on animal toxicity has Involved ingestion of FCBs In the diet or by intubation* Several animal experiments have Involved oral administration of FCBs for the lifetime of the animal. These studies have demonstrated chronic changes In the r microscopic anatomy of the liver and other organs, effects on reproduction, embryonic and fetal toxicity, effects on offspring from nursing, and carcinogenic and teratogenic responses* (a) Inhalation and Dermal Application Studies of PCS Mixtures i Absorption and distribution of inhaled FCBs were studied by Benthe et al [97] in 1972. Groups of 4-6 male Vistar rats were exposed to aerosols of a conmerelal PCB mixture containing 42Z chlorine, Fydraul A 200, coomonly used In hydraulic fluids* Absorption and distribution of the FCBs were studied through the measurement of PCB concentrations in liver, brain, and adipose tissue. The aerosols were produced In an aerosol generator at 180 C. The aerosols vers cooled, the larger particles were separated out^ and the airborne PCBs were introduced into a chamber at a concentration of i 30*4 t 3.4 g/cu m. Groups of the rats wereexposed for varying periods up to 2 hours. It was found that 15 minutes of exposure was sufficient to attain m than 50X of the PCB concentration of 69.7 jtg/g liver vet weight that could be attained with 2 hours of exposure. Consequently, the investigators used an exposure time of 30 minutes to study distribution of PCBs to the tissues. Immediately after 30 minutes of exposure, PCB concentrations were maximal, at about 52 jig/g liver tissue, whereas they were at low A"'0075 66 M 0 7 9 9 7 -V /-- \ concentrations In Che other tissues at 14 jig/g in adipose tissue, and 9 ig/g in brain tissue. After 24 hours the PCB level in the brain attained a maximum value of about 18 u % I% and within 36 hours the PCB concentration in the adipose tissue attained a maximum of about 250 ;ig/g, By 48 hours the concentrations of PCBs in the liver were reduced to about 3 ig/g and in the brain to about 5 jig/g, whereas the adipose tissue concentrations remained above 200 jig/g Experiments were reported by Rozanova [202] in 1943 in which rats were exposed to a technical mixture of "tetrachlorodiphenyl" and "pentachlorodiphenyl." The mixture, known as Solvol, was a transparent, colorless, oily, very viscous liquid used for filling capacitors. The "tetrachlorodlphenyl" component of the mixture had a distillation range of 220 to 245 C and the "pentachlorodlphenyl" component had a distillation range of 242 to 260 C. The animals were exposed in a 22-liter chamber through which air was drawn continually at a rata of 1-1.5 liters/minute, after first passing through a glass gooseneck containing the liquid PCBe. Air samples were taken from the chamber from time to time to determine the PCB concentrations. The analytical method was not reported. . Four rats exposed for 3 hours at about 10 mg/llter became uncoordinated and comatose and died within a day [202]. Autopsy findings Included liver necrosis and fatty degeneration, cloudy swelling of the epithelial calls of the renal tubules, congestion In the heart and spleen, and necrotic signs in the spleen. Three rats were exposed rspeatsdly to vapors of Solvol at 0.5 mg/llter. One rat died after sight exposures, and the other two were killed after 11 exposures. Five other rats were repeatedly exposed at 0.25 mg/llter; one was killed after 16 exposures, and 67 ; N 079.98 000076 the others, which appeared to be In satisfactory condition, were killed after 69 exposures. In these chronically exposed rats, gross and microscopic findings were similar to, but less marked than, those found In the acutely exposed animals. In addition, hyperplasia of the Kupffer cells was found in the liver. Treon et al [203] exposed groups of animals each comprised of 10 rats, 10 mice, 6 guinea pigs, 4 rabbits, and a cat to Aroclor 1242 or Aroclor 1254 vapors 7 hours/day, 5 days/week for up to 31 weeks, Aroclor 1242 exposures at concentrations of 8.6 jg/llter (0,83 ppm) for 3 weeks, 6,83 yg/liter (0.66 ppm) for 17 weeks, or 1.9 ^g/liter (0,18 ppm) for 31 weeks. Exposures to Aroclor 1254 were at 1.5 /g/liter (0,11 ppm) for 31 weeks or at 5.40 jjg/lltar (0.41 ppm) for 17 weeks. No consistent changes in mortality, growth, pathology, organ size, liver function, or hematologic parameters were found in animals exposed to Aroclor 1242. The animals exposed to Aroclor-1254 vapors shoved no changes in growth or mortality but microscopic evidence of apparently reversible hepatic cellular injury was found in all species except the cat at both exposure levels. Enlarged livers were found in the animals exposed at 5.40 m s /liter. An appreciable Incidence of pneumonia was found among the exposed and control animals, a fact which could have confounded soma of the results, but it is Important to note that liver changes, including fatty degeneration, were found in exposed animals that were free of pneumonia. Inhalation experiments with the commercial PCB product ''Decachlorodiphenyl" were reported by Berezy et al [98,99] in 1974. The oral toxicity of this FCB product wee investigated by Hunter et al [204], who administered it la the diet to Sprague-Davley AOOO0I7I7\* i i 68 rata at 1,000, 2,000^ 07999 5,0001 and 10,000 ppnf for 4 weeks. All animals fed Decachlorodiphenyl gained more weight than the controls and had greater liver to body weight ratios. Other effects observed at 10,000 ppm Included increased spleen, thyroid, and kidney weights relative to body weights, reduced hemoglobin, concentrations, and in males reduced rbc counts and hematocrits. In one Inhalation experiment [98], five male end five female rats were exposed for 6 hours to particles of the PCB product at an average concentration of 2,54 mg/llter. Seventy-eight percent of the particles were In the range of 1-5 m in diameter, 17X in the range of 5-15 m % and the remaining 5X were >15 jjm. During exposure there were repeated episodes % of blinking and sneezing. Signs of irritation disappeared after cessation of exposure. During the subsequent. 14-day observation period, food and water consumption and growth of the rats were considered by the authors to have been similar to those of the controls. No gross pathological changes were seen when the rats were killed 14 days after removal from exposure [98]. Subsequently [99], three troupe of rats, each consisting of 8 males and 8 females, wars sxposed 6 hours/day, 5 days/waek for 4 vesks at average concentrations of 4, 80, and 777 ;jg/llter. A similar group of Tata was ussd as a control. In this experiment, where 85-901 of the particles were in the. 1-3 m rent end 1-3X were >15 fa, no signs of irritation were seen during thgr exposures at the lover concentrations and growth rates were normal compared to controls. At the highest concentrations, frequent blinking and sneezing were noted during the exposures, end the growth rate of the melee wee slightly retarded (final body weights of 395 g vs 435 g for controls). The liver weights, relative to body weight, vers Increased 69 M Ofcooo 1p In males exposed 'at the highest concentration, and In females exposed at' the medium and high concentrations. Microscopic findings in the livers of i the rats exposed at the high concentration included occasional focal j aggregations of mononuclear cells with either parenchymal or periportal distribution, and minimal degrees of periportal hepatocytic vacuolatlon, and decreased centrilobular or periportal glycogen These findings! vere j not considered by the authors [99],to be of toxicologic significance. A i statistically significant decrease in packed cell and mean cell volumes vas found in male rats exposed at the high concentration. vas also a low white cell count due to a decrease In this group there ! in the number of lymphocytes, and increased thrombocyte activity. Blood glucose, SGOT, and serum sodium concentrations vere decreased. Von Wadal et al [205] described in 1942 the results of an experiment performed to determine the systemic effects of exposure of mice, guinea pigs, and rabbits, by inhalation, lngeation, and dermal application to an unspecified Aroclor. Concentrations and durations of exposure vere not < specified for the inhalation and lngeation experiments. However, 0.5, 1.0, or 1.5 ml of solutions containing 0.5 g Aroclor/ml vere used for the dermal applications. Within 5 days after the dermal applications, small papules 3 and blisters formed on the exposed akin areas and the external epidermal layers became desquamated. In addition, subacute yellow atrophy of the liver with some fatty infiltration was observed. Similar liver lesions vere produced in the inhalation experiment* In 1944, Miller [206] administered Aroclor 1242 to rata, rabbits, and guinea pigs by subcutaneous (sc) injection, by oral intubation, and by dermal and corneal application* The PCS doses ranged from single doses of A"00079 .N 08001 i f-a-m' i J 69 ng .to small drops (approximately 17 mg) applied daily to the cornea of rats for 25 days, to 1,380 mg Injected dally into rabbits for 10 days, Fatty degeneration and atrophy of the centrllobular cells of the liver were the characteristic signs of toxicity, The greatest amounts of liver damage were seen in guinea pigs, less vas seen In rabbits, and the least amount in rats, regardless of the dose, duration of exposure, or route of administration. Necrotic lesions were also seen in the skin of animals that received sc injections; signs of dermal irritation were seen after applications to the skin. The conjunctival tissue presented no gross changes when examined under magnification in the living animals. .Since the y pathologic changes in internal organs were similar regardless of method of administration, this experiment indirectly demonstrated that PCBa could be absorbed through the skin and the eye. The effects of Solvol applied to the ears of rabbits were reported by Farlbok [207] in 1954, Solvol was applied for 6 hours daily in doses of 0,7 to 3.76 g. A single application caused e d o a and inflammation of the ear, and one rabbit died 7 days after the application. With multiple doses, the animals died after 6*17 days. The dead animals, including the one that died after the single application, had fatty degeneration of the livers. Tog and Beams [208] reported in 1971 on the dermal toxicity of PCBs in adult fflsale New Zealand rabbits. Three coonerclal preparations of ?CBs were used: Clophen A60, Phenoclor DF6, and Aroclor 1260. Twenty-seven l-ol (118 mg) applications of eaeh of these products (la lsoprepanol), 5 tlmes/veek over 38 days, to the clipped and shaved backs of the rabbits resulted in various manifestations of toxicity. 71 ' A000080 In general, the toxic signs were most pronounced In the Clophen- treated animals and least pronounced with Aroclor 1260, Dermal findings Included thickening of the skin due to hyperplasia and hyperkeratosis of the epidermal epithelium, and dilation and plugging of hair follicles with keratinous material. .1 Microscopic study of liver sections showed! a i considerable diversity of lesions, Including centrllobular degeneration, 1 focal hydropic degeneration, focal necrosis, atrophy of centrllobular I parenchymal cells, cytoplasmic hyaline degeneration, pigmentation 'of Kupffer cells, and, to a lesser extent, pigmentation of parenchymal cells. Renal damage was found in all PCB-treated animals. i The most conaon i findings were hydropic degeneration of the convoluted tubules, with nuclear 1 pyknosls, and bursting and lysis of the tubular epithelial cells [208], i Dilation of the renal tubules, filled with casts of necrotic epithelial 1 cells, was found in half the rabbits. These findings indicate that the _) dermal application of ?C8 mixtures causes systemic lesions of the liver and kidneys besides the direct effect on the skin. However, In other studied 1 [19,21,23], it wee determined that Clophen A60, Phenoclor DF6, and Aroelors 1248 and 1254 were contaminated, to varying degrees [21], with highly toxic tetra- and peatachlorodlbensofureas. j (b) General Effects of Oral Administration of PCB Mixtures Single-dose oral LD50's of several PCBs reported In rats (JW Cook,1 i written c u n i i f i.stlon, June 1970) generally Indicated that as the degree of chlorination Increased, the acute toxicity decreased. The more highly chlorinated products (Aroelors 1248-1268) were of approximately equal toxicity (LDSO'e of about 10 g/kg), whereas the LD50's of the less highly j i chlorinated products (Aroelors 1221-1242) ranged from about 4 to 9 g/kg. < - * ; \ i 72 V 08003 t I I The minimum lethal doses of these PCSs applied to the skin of rabbits were generally In the range of 1-2 g except for 1221 which was in the range of 2-3 g and 1268 which was >2.5 g. The itmrunosuppressive activity of Aroclor 1260 was described in 1972 by Vos and de Roij [209] who fed three groups of 12 4-week-old female albino guinea pigs the FCB at 0, 10, or 50 ppm in their diets for 8 weeks. Aroclor 1260 was analyzed and found to be free of contamination with chlorinated dlbenzofurans, although it appeared to contain a minor acnegenlc Impurity. In each group, six animals received sc injections of aluminum phosphate-adsorbed tetanus toxoid to stimulate the lymphoid system (antitoxin production). The other six animals in each group served as positive or negative controls. Celluloseacetate electrophoresis was used to determine serum proteins, including gamma-globulins. The gamma globulin-containing cells in the popliteal lymph nodes were significantly reduced in the stimulated animals fed PCBs. Seras gamma-globulin levels were significantly decreased in the guinea pigs stimulated with tetanus toxoid and fed 10 ppm of Aroclor 1260 intheir diet. Increased serum alpha-8lobulin levels were found in the stimulated guinea pigs fed either 10 or 50 ppm of the PCB, and significantly Increased concentrations of albumin were found in the sera of both the stimulated and th unstimulated guinea plga fed the PCB at 10 ppm. Also, both the absolute and relative weights of the cervical lymph nodes in the unstimulated group fed 10 ppm of Aroclor 1260 were significantly reduced whereee those of the mesenteric lymph nodes in the stimuleted guinea pigs fed 10 end 50 ppm of PCB were significantly increased. These findings indicate that some Immunosuppressive effect was produced by the feeding of FCBe. However, the 73 N 08004 decreases of the gamma-globulin levels vere not found to be dose-related. i No evidence of any PCB-induced change was observed in microscopically i examined stained sections of liver, kidneys, adrenals, and skin. J i Vos and Van Driel-Crootenhuis [210] reported their studies of the effects of PCBs on the humoral and cell-mediated Immunities of guinea pigs I In 1972. Three experiments vere performed vith different protocols*; In i the first experiment, the authors investigated the humoral Immune response of guinea pigs fed 0, 10, 50, or 250 ppm of Clophen A60 in their diets and stimulated with a single sc injection of tetanus toxoid 3 weeks after Ithe feeding regimen began* Suppression of humoral immunity was observed at the I 50-ppm level. Microscopic examination of the livers revealed centrilobular i. degeneration, cellular atrophy, cellular necrosis, and nuclear enlargement. 1 At the 250-ppm level, no antitoxin production was observed. 'I The diets of guinea pigs in a second experiment [210] contained 0, 10, or 50 ppm of Clophen A60 or 50 ppm of Aroclor 1260. Primary and I secondary antigenic stimulations with tetanus toxoid vere given after 3 iand 5 weeks. The experiment lasted 6 weeks. Suppression of the humoral Immune response was observed In groups fed 50 ppm of either PCB produet. Decreases in the weights of the thymuses and increases in liver weights vere observed et the 50-ppm Clophen A60 level and . t o a lesser degree,!at i the 50-fpi Aroclor 1260 level. The residual liver concentrations of PCBs increased as the dose level and the duration of exposure increased. In their third experiment, Vos and Van Drlel-Grooeenhuie [210] fad ,30 guinea pigs diets containing Clophen A60 et 0, 50, or 250 ppm. After | 3 I weeks, . the animals vers challenged with 0.05- ml of Freund's complete adjuvant followed in 47 days by an injection of 0.1 ml of avian tuberculin 74 i- N 08005 antigen. The animals were killed 2 days later. All animals of the 250-ppm group died during the experiment, exhibiting retarded growth, atrophy and depletion of the lymphoid system, and liver damage. Significantly decreased thymus weights and increased liver weights also were observed, and total white blood cell counts were reduced significantly Bruckner et al [211] administered Aroclor 1242 * to rata by oral intubation to determine its acute and subacute effects. Two groups of six rats each were given single doses of either 2.5 or 6.0 g/kg of Aroclor 1242. The initial effects observed at both dosages were the same for the first 4 hours, ie, diarrhea, decreased spontaneous activity and muscle tone, decreased response to pain stimuli and mild chromodacryorrhea. However, during the next 24 hours the group receiving 6.0 g/kg had profuse diarrhea, adlpsia, oliguria, anorexia, erythema of the limbs, lack of response to pain stimuli, and general weakness. Eventually, ataxia, coma, and death followed. The condition of the rats receiving the lower dosage gradually Improved after the first 24 hours and was normal at the end of 72 hours. Another group of rate [211] that received single oral doses of 4 g Aroclor 1242/kg showed weight loss, elevated packed red cell volumes, increased serum polymorphonuclear leukocytes, crenatsd red blood cells, and Increased SCOT activities. All organs appeared normal except the livers and kidneys. The livers exhibited foci of sudanophlllc vacuolatlon. The kidneys shewed widely scattered foci of vacuolated tubular epithelial cells. In the subacute studies conducted by Bruckner et al [211], six rats were given 100 mg of Aroclor 1242/kg orally every other day for 3 weeks; 75 , -5 N 030 cm7 A000fl84 three control rata received 100 mg/kg of peanut oil on the aame schedule^. 1 Changes observed in the treated rats Included Increased liver weights!, decreased packed red blood cell volumes, Increased SCOT activities and HI marked Increases in liver microsomal hydroxylatlng and N-demethylating enzyme activities. Microscopic examinations of the livers and kidneys revealed greater Increases In generalized lipid vacuoles- than had been found with the acute doses. When single ip doses of 100 mg A r o d o r 1242/kg were given to rats, Increased N-demethylase and aniline hydroxylase i activities were observed after only 24 hours [211]. ! The effects of lover dietary levels of A r o d o r 1242 on rats varej reported by Bruckner et al [2121, who fed It to groups of six male Sprague-! Davley rats at concentrations of 0, 5, or 25 ppm for 2, 4, or 6 months.! Small reductions In hematocrit and hemoglobin levels similar to those found , l in other studies by Bruckner et al [211,213] vere seen. Urinary excretion | of coproporphyrln ves significantly Increased and dosa-dependent increases In liver microsomal hydroxylase activity vere meesured et the time of each ^ sampling. Similar dose-dspendsnt relationships vere found in other ; experiments [213,214] Proliferation of the hepatic endoplasmic reticulum i vas seen after 2 monthe of lngeetlng e diet containing 25 ppm of Aroclor , 1242; after 4-6 monthe of such Ingestion, lipid vacuolization of the liver | l vea evident 1974In , Bruckner et el [213] reported reduced velght gain, hepatic and renal damage, and an Increase In urinary coproporphyrln excretion In rets lnjectad lp with e total of 1.6 g/kg of Aroclor 1242 during e 10-vsek period. The hydroxylatlng and H-demethyletlng activities of the liver vere significantly elevated 24 hours after e single lp Injection of 100 mg/kg of A000085 i ./> i- - i N 08007 Aroclor 1242, with hydroxylating activity shoving the greater Increase. Cytochromes P-450 and b5 and NADPH-cytochrome reductase activities of the j liver all vere significantly Increased 3 days after dosing* A single dose of 50 mg/kg gave similar but less marked effects, whereas 25 mg/kg produced significant Increases in only hydroxylating and N-demethylating activities, Kimbrough et al [215] described in 1972 some effects of chlorobiphenyl mixtures on the livers of rats. Groups of 3- to 4-veek-old male and female Sherman strain rata vere given A r o d o r s 1254 and 1260 at 0 f 20, 100, 500, and 1,000 ppm in their diets. Each group consisted of 10 males and 10 females. Food consumption was measured periodically. The animals vere fed the PCBs for 8 months. One female fed 100 ppm of Aroclor 1260 died after 6 months and two females fed 500 ppm died after 1 and 2 months. Eight females fed the 1,000 ppm diet died in 2-6 months. The rats fed 500 and 1,000 ppm gained less weight than did the controls. At autopsy, livers of the male rats fed Aroclor 1260 weighed significantly more than did livers of control male rats. Livers of the females vere larger than normal but the velght differences vere not statistically significant, although at 500 ppm the fractions of body weight represented by the livers Increased significantly as a result of the reduced body velght gain. Microscopic findings in the livers included hepatocytlc hypertrophy, inclusions in the cytoplasm, brown pigment in the Kupffer cells, lipid accumulations, and, at the higher dietary levels, adenofibrosis The nodular greyish-white areas that represented extensive foci of adenofibrosie consisted of fibroblasts and collagen that surrounded rosettes of epithelial-cells [215]. ... 77 N Aroclor 1254 produced similar results [215]. One female and tvo male rats died at 500 ppm, but none died at the lover dietary levels, and ! the rats fed 500 ppm gained less velght than did controls* Ultrastructural changes In the livers of exposed animals consisted of proliferation of the smooth endoplasmic reticulum (SER) and atypical mitrochondrla. Similar changes have been observed in other experiments with FCBs [131,212,216- 218]. A major difference between the effects of the two products was the much higher Incidence of hepatic adenoflbrosla at a lover dietary level ,of Aroclor 1254 (100 ppm). In general, the effects of Aroclor 1254 on the liver were more pronounced than those of Aroclor 1260. 1 la 1973, Kimbrough et al [219] reported the resulcs of a study i conducted to determine whether morphologic changes produced In the liver vould regress after Ingestion of FCBs was stopped. Fifty male SFF Sherman strain rats were given Aroclor 1254 at 500 ppm In their diets for 6 month's, and then were returned to normal diets. Groups of five rats were killed 0, i 1, 2, 3, 4, 6, 8, and 10 months after Ingestion of FCBs had been discontinued. The livers and adipose tissues of the lOnnonth group were analyzed for PCBs. Control animals vers used la all evaluations and were fed only laboratory chow. The livers of exposed animals killed when exposure to Aroclor 1254 was discontinued were enlarged and most of the 40 livers studied microscopically shewed enlarged hepatoeytes, Increased lipid contents, and i adenoflbrosla. A brown pigment was seen In the Kupffer cells and la other i macrophages of 15 livers.Small adenoflbrotlc lesions consisting of glandular epithelial cells that formed duets surrounded by slight amounts of flbrotlc tissue were seen; larger lesions had more extensive fibrosis 78 N 03009 and contained collagen. Similar findings had been reported earlier by Kimbrough et al [215] and both in the areas of adenofibroeia and in othevise normal hepatic tissue, Kimbrough [220] later reported finding small clusters of glandular type cells, resembling those of pancreatic tissue in general appearance and staining characteristics, in 15 of 36 rat livers with adenofibrosls. The cells -stained red vith the stain used for esterase, and developed a blue granular appearance with the stain used for protein bound tryptophan. These staining reactions were suggestive of those of salivary gland tissue to the author. The cells may have been derived from either ductal or vascular epithelium, but there is no evidence to substantiate either suggestion [220], Signs of regression of the adenoflbrotlc lesions were not noted except for the disappearances of epithelial cells from the centers of the lesions [219]. Liver weights did regress to normal after 10 months without FCB exposure, but the lipid accumulation and the hypertrophy of the hepatic cells remained unchanged. Analysis of adipose tissues from the final group of rats killed showed that the FCB levels ranged from 924 to 1668 ppm (mean, 1192 ppm), Liver FCB levels ranged from 17.3 ppm to 26.2 ppnT'fmean, 22.7 ppm). The FCB concentrations in the adipose tissue and livers of the control animals were less than 1.0 ppm The authors [219] were unable to decide whether contamination of A r o d o r 1254 with dlbenzofuran was responsible for the observed liver lesions [219], Kimbrough and Linder [221] reported in 1974 the results of a FCBfceding experiment which they undertook to lnduee adenoflbrotlc lesions in the livers of BALB/cJ Inbred male miee, is, lesions similar to those previously observed in rats fed Aroclors 1254 and 1260. Two hundred mice,. N 08010 1I 5-6 weeks old, were distributed randomly into 4 groups of 50 each. ITwo I groups were fed a ground diet containing 300 ppm of Aroclor 1254. At ,the i i end of 6 months, one of these exposed groups was placed on a FCB-free diet while the other exposed group continued on the test diet for another! 5 months. The other two groups served as controls and were fed the plain ground laboratory diet for the entire 11 months. The average FCB Intake i was 49.8 ag/kg/day in the mice fed the FCB diet for the entire 11-month period. | I Livers of 45 of the 58 surviving control mice were found to be I normal. The other 13 had focal round-cell Infiltrates and sometimes small 'I ' areas of necrosis and fibrosis. Skin abscesses, usually near the groin, i were identified la all 13 control mice with hepatic round-cell Infiltrates. i These skin lesions were thought to be abscesses of the preputial glands. i i In comparison, 10 hepatomas were identified In 9 of the 22 survivors in the I group fed the FCB diet for 11 months. These tumors consisted of welli differentiated hepatocytss, relatively uniform in size but usually smaller I than the surrounding liver cells. They were well circumscribed an<i I surrounded by compressed hepatic parenchymal cells or strands of fibrous tissue. In the larger tumors, there vers areas In which the sinuses were i dilated and filled with a pink-staining amorphous material. No metastases I were seen on gross inspection of the organs, although no detailed screening, such, as serial sectioning of the lungs, was undertaken. Onlyj i one small hepatoma, composed of wall-differentiated hepatocytss, was! identified among the 24 survivors fed the FCB diet for only 6 months. The! i authors [221] noted that the mouse strain used in this study rarsly* develops hepatomas spontansously. A O O O ^ Vl' 80 K 08011 Adenofibrosis was Identified In the livers of the nice subjected to the 11-month PCB diet. .These lesions, according to the authors [221], may or may not be precursors of malignant lesions. They were seen in several areas of each liver as fibrosis and as glandular formations of proliferated epithelial cells replacing parenchymal cells. They formed ducts which produced mucus and vhich were surrounded by connective tissue of varying abundance. Allen and Abrahamson [216] reported on morphologic and biochemical changes, in the livers of rats given Aroclors 1246, 1254, and 1260 at 1,000 ppm in their diets for 6 weeks. A control group vaa fed unsupplemented chow. Each group contained 24 rats. Tour rats were killed after 1,3,7,14,21, 28, and 42 days of exposure. White blood cells, hemoglobin (Hb), hematocrit (Hct), differential white cell count, total serum proteins, and blood urea nitrogen (BUN) were measured at each Interval. Selected tissues were prepared for microscopic examination and the livers were homogenized and analyzed for cytoplasmic protein, DNA, and RNA. Liver microaomea were examined for aryl hydrocarbon hydroxylase, nitroreductase, M-demethylase, and nltrophenylacetate hydroxylase activities, and for cholesterol content. All of the PCB-dosed rats failed to gain weight. The moat severe effects vara noted with Aroclor 1248, followed by Aroclors 1254 and 1262. All blood samples showed increases in Hb and Hct, with no changes in the white blood call counts. Neutrophils ware Increased in the sera of all treatment groups. There were no changes in BUN or in total serum protein levels. Organ weights in all of the experimental rats constituted higher percentages of total body weights than in controls; the livers showed four- 81 ro- fold Increases in weight in all FCB-dosed groups. The increased liver weights were discernible after only 1 day of exposure. Liver hypertrophy I was attributed to proliferation of SER, development of large concentric i arrays of membranes, and Increases in lipid droplets within the cytoplasms of the affected cells. Arcelor 1248 was the moat, and 1262 the least, toxic FCB product as Judged by changes in liver histology* Liver j homogenates contained increased concentrations of protein and RNA, and decreased concentrations of DNA. These changes were seen within 2 weeks after initiation of feeding Aroclors 1248 and 1254; the protein and nucleic acid concentrations than either leveled off or decreased after 4-6 weeks.i Aroclor 1262, however, did not Induce these effects until 4 weeks after the beginning of feeding; the initial changes were followed by reversals [216]', ' Liver microsomal fractions had increased protein and phospholipid concentrations* These changes occurred earlier in the rats fed Aroclor 1248 and 1254 than in the Aroclor 1262-fed animals. Microsomal nitroreductase activity, expressed on the basis of microsomal protein, was l variable in the animals fed Aroclors 1248 and 1254; however, all animals .fed Aroclor 1262 had progressive Increases in nitroreductase activity. N-, dmethylate activity Increased early in the experimental period and! Increased progressively in all treatment groups as the exposures continued.: Aryl hydrocarbon hydroxylase, glucese-6-phosphatase, and other esterase i activities increased Initially, followed by continuous declines In activity la the groups fed Aroclors 1248 and 1254. The rats fed Aroclor 1262 had similar, but less marked, changes. Vhen enzyme activities were expressed as activity per total liver, all showed marked Increases. After 6 weeks, other degenerative changes in the liver occurred, such as dissolution of 1 A000091 82 , j f, Che concentric arrays of membranes* vealculatlon of Che endoplasmic reticulum, and accumulation within the cytoplasm of lipid droplets that had developed during the hypertrophic phase of the Intoxication [216]. Allen et al [222] administered PCBs (Aroclor 1248) and polychlorinated terphenyla (Aroclor 5460) to rhesus monkeys.. Sixteen male monkeys were distributed Into three groups. Group 1 consisted of six animals and was fed a basal diet supplemented with 300 ppm of Aroclor 1248. Group 2 consisted of six animals fed a basal diet containing 5,000 ppm of Aroclor 5460, The remaining four monkeys constituted the control group and were fed the standard colony diet. Each animal had access to 400 g of diet dally, The physical status of the animals was evaluated dally .and "complete" blood studies were performed biweekly. Approximately 10 g of liver tissue were removed from each animal during the 6th week (via laparotomy) and during the 12th week (at necropsy) for biochemical and microscopic evaluation. Animals fed Aroclor 1248 lost an average of 26t of .body weight; those receiving Aroclor 5460 lost an average of 19Z of body weight. Gross changes seen In the animals fed Aroclor 1248 included loss of hair from head, neck, and back, puffy faces, edematous lips, and swollen eyelids with purulent exudates around the eyes. These changes were seen within 1 month; similar, bug lees marked changes ware saen In the animals fed Aroclor 5460 [ 222] . Hematologic ehangea developed gradually. After 3 months, hsswglobins had decreased by about 2 g/100 ml, and hsmatocrlta had diminished from about 40Z to 33Z. Total white blood cell counts did not ehange; however, A000092 83 there was a shift to the left la the differential count. Total serum i proteins decreased by about 1.5-2 g/100 m l , and there was a gradual shift! in the albuain/globulln ratio of the serum protein. No changes were seen j In SGOT or SUN. Both experimental groups had similar patterns of changes; [222]. I At necropsy, both groups of animals shoved extensive alopecia, acnelform lesions of the skin, subcutaneous edema, liver hypertrophy with i fatty Infiltration, and gastric mucosal hypertrophy and hyperplasia. Liver i , i hypertrophy was attributed mainly to proliferation of the hepatocytlc SER. ' Gastric hypertrophy was characterized by thickened gastric mucosa, numerous i large cystic areas filled with mucin, and hyperplasia. Ulceration was seen, as vas Invasion of the underlying mucosa by glandular-type epithelial ; cells [222]. The authors [222] noted that, biochemically, the decreases observed In the DKA concentrations of the livers of both experimental groups reflected the hypertrophic cells observed microscopically, and the increases' in protein and RKA were said to be compatible with the proliferated SEE. Levels of microsomal protein per gram of protein vere not markedly altered, but decreases in the specific activities of esterase, aniline hydmxyleaa, nitroreductase, antT glucose-6-phosphatase became apparent within 6 weeks, and persisted. N-damechylase activity was increased at each examination. The results of a toxicity study conducted on four young male rhesus Bonkeyo fed Aroclor 1242 at concentrations of 3, 10, 30, or 1G0 ppm vere reported by Bell [223], McNulty [94], and in a communication written in A00093 84 N 08015 March 1977 by WP McNulty. All four monkeys on these diets died within 9 months. The monkeys had facial swelling red and swollen eyelids, conversion of all secretory-type cells of the stomach to mucous cells, growth of mucous glands into the muscular walls of the stomach, multiple ulcers in the stomach, atrophy of the thymus gland, and either disappearance of sebaceous glands or conversion of these glands to keratin cysts, particularly in the eyelids. Allen et al [104] and Allen and Norback [224] found gastric hypertrophy and hyperplasia and focal ulceration of the stomach lining in adult male rhesus monkeys fed single doses of 1.5 or 3.0 g of Aroclor 1248. (c) Studies Involving Individual PCB Isomers In 1972, Vos and Notenboom-Ram [225] discussed the comparative toxicities of dermally applied 120-og doses of 2,2,, 4 , 4 \ 5 (5 >hexachloroblphenyl and Aroclor 1260. The FCBs, dissolved in isopropanol, were applied 20 times to the clipped and shaved backs of three groups of four rabbits each, 5 times/week for 4 weeks. The control group received only Isopropanol. The Aroclor .1260 sample was found to be "free" of chlorinated dibenzofurans (limit of detection, 1 ppm), and because of the nature of the chemical reactions utilized in the synthesis of 2,2',4,4*,5,5*-hexachlorobiphenyl. Dermal applications o these FCBs resulted in early macroscopic skin lesions and morbid liver changes similar to* Chose found by Vos and Beams [208]. These liver lesions Included centrllobular degeneration and liver call atrophy, focal cytoplasmic hyaline degeneration of the hepatocytes, enlarged nuclei, loss of glycogen and proliferation of SE&. The authors [225] concluded that, although the 85 major acnegenic action'of crude FCB mixtures results from the presence of chlorinated dibenofurans, PCBs have acnegenic actions of their own. Hanaell and Ecobichon [217] described the effects of a aeries of chemically pure chlorobiphenyls on rat liver morphology 'l Biphenyl and !a series of iaomerically 'pure mono-, di-, tetra-, hexa-, and octachlorobiphenyls of known composition were administered . intraperitoneal (ip) injections in daily doses of 50 mg/kg to groups of seven young male Woodlyn strain Wistar rats for 3 consecutive days* the rats were killed k days after the final Injections had been made and sleeping times after II phnobarbital administration had been determined. The major microscopic alterations observed were proliferation of the hepatocytlc SEE, changes in the rough endoplasmic reticulum, and Increased numbers of lipid droplets and microbodies. However, in the rats administered isomerlcally pure hexa-j and octachlorobiphenyls, there were additional changes in hepatic! 1 morphology, including large numbers of hepatocytes with cytoplasmic vacuoles and small foci of necrosis involving five or slic cells. Biphenyl and 2 ,2'-dichlorobiphenyl appeared not to Induce extensive proliferation of the SER, but with the other compounds the SER proliferation appeared to be related to the degree of chlorination, especially to the presence of a chlorine in the 4 and/or 4* positions. The. laweetlgators [217] also Injected groups of seven rats lp with dally doses tf 100 mg/kg of either 4-mono-, 4,4*-di-( or 2,5,2*,5'- tetrachloroblphenyl for 7 days; ell rats from each group were killed 24 hours after the last injections. This regimen caused *- re pronounced alterations in hepatocytlc ultrastruceure than those obsc d after the 3- day experiments. Harked proliferation of SER end increased numbers of 86 0 ^ 5 N 03017 microbodies and lipid ^droplets were noted, as vers a large number or necrotic foci, centrllobular necrosis, and proliferation of biliary ductules. The most severe lesions were seen in the group receiving 4,4'dichloroblphenyl. There was not the Increase in hepatic weight and cell size noted by ocher authors [219,226], Hansell and Ecoblchon [217] observed that this apparent anomaly may have been due to the duration of PC3 administration, only 3-7 days, and to the relatively low dosages. Allen et al [226], in a series of experiments, studied the toxicity' of 2,2* ,5,5'-tetrachlorobiphenyl in rats and rhesus monkeys. In the first experiment, 5-week-old rats were separated Into five groups consisting of five males and five females each. After being fasted overnight, each of these groups was administered by gavage a single dose of one of the following amounts of the compound dissolved In corn oil: 0, 0.5, 1.0, 1.5, or 2.0 g/kg. Each dose had a total volume of 1 ml. After the dose had been given, blood was taken for complete blood counts. Eighteen of the 40 FCB-dosed rats died within 3 days. The dead animals Included all those given 2.0 g/kg, 7 rats from the group given 1.5 g/kg, and 1 rat from the 1.0 g/kg group. The rats were observed for 21 days after which complete blood counts were performed and the surviving animals were killed and necropsled. The major pathologic changee observed la the animals that died were marked regressions of lymphocytes In the spleen and lymph nodes and of cortical thymocytes. With the exception of hemorrhage and atrophy of the thymus, which were related to the decrease la the cortical thymocytes, and enlargement of the liver and kidneys, all tissue samples were normal when compared with those from the nonexposed group. 87 The 9econd experiment vas conducted to determine the effects of l hepatic microsomal enzyme activity on the responses of male Sprague-Davley rats to 2,2' . S ^ '-tetrachlorobiphenyl [226]* The rats vere separated into i 6 groups of 10 animals each. Group 1 vas a positive control given four ip i injections of 75 mg/kg of the microsomal enzyme Inhibitor, SKF 525a , at18- hour intervals. Group 2 vas given four daily sc injections of 75 mg/kg lof phnobarbital. Group 3 vas the general control. Groups 4, 5, and, 6 received 1.25 g/kg of the chlorobiphenyl in 1 ml of corn oil by gastric i- intubation; group 5 vas dosed with the chlorobiphenyl 24 hours after 4 days vith dally sc doses of 75 mg/kg of phnobarbital. Group 6 received 75 i - mg/kg of SKF 525A ip 2 hours prior to administration of 2,2*, 5,5 V tetrachlorobiphenyl, and every 8 hours thereafter for 24 hours. Within 4 days, all the rats in group 5 and 50% in group 4 had died whereas none had died in group 5, which was pretreated vith phnobarbital. The findings that pretreatment vith phnobarbital allowed complete survival of rats after an LD5Q dose of the PCB, whereas pretreatment vith SKF 525A caused* 1Q0Z mortality, indicated to the investigators that metabolici transformation by endoplasmle reticulum enzymes resulted in deterlflcatlon ' [226]. The third experiment was performed to compare the differences between the responses of rats to 2,2*,5t5'~t*trachloroblphenyl and Aroclor 1248 [226]. Twelve mala rata vere placed la three groups of four animals each; group 1 was fed 100 ppm of Aroclor 1248 in its diet, group 2 was given 100 ppm of the 2,2',5,5* isomer in its diet, and group 3 (control) vae fed the staple ground meal diet. After 4 weeks of these feeding regimens, the rats vere fasted for 24 hours, killed, and necropalad; blood was also collected 88 N 08019 ac this time. There vere no detectable differences In general appearance, food consumption, activity, growth rate, or blood chemistries between the two experimental groups and the control group. The only significant difference at autopsy was an increase in liver weight as a percentage of body weight of the animals fed Aroclor 1248: 4.46 0.1IX, compared with 3.38 0.13Z for those fed 2,2*,5,5f-tetrachlorobiphenyl and 3.0 0.12Z for the controls. Proliferation of the endoplasmic reticulum within the hepatic cells was observed In the Aroclor 1248-fed animals. The Ndemethylase activity and the cytochrome P-450 content of the microsomal fraction of homogenized liver from th Aroclor 1248-fed rats were increased whereas Che activity of aniline hydroxylase and glucose-6-phosphatase in this fraction had decreased. There were increases in the concentrations of protein and RNA and a decrease in the DNA content of the liver homogenates from the Aroclor-fed animals. The livers of rats fed the isomer had similar but less marked changes in concentrations of protein, RNA, and DNA. The mean concentration of microsomal protein In liver was Identical with that of the controls but was more variable. A significant increase In the mean activity of N-demathylase was found. The fourth experiment [226] was performed to determine the effects of 2,2',5,51-tetrachlorobiphenyl on non-human primates Seven adult male. rhesus monkeys were given 18 mg/kg of the PCB Isomer dissolved In 2.5 ml of corn oil and-three controls vere given 2.5 ml of corn oil, all by gavage after a 24-hour fast. Complete blood counts had been dene on each animal prior to intubation. Isnedlately after treatment, the animals were placed in metabolism cages and their urine and feces analysed for 2,2',5,5'- 89 tetrachloroblphenyl by GLC. On the 14th day of the experiment the animals were faated for 24 houra, killed, and necropaied. Tlsauea were taken for light and electron microscopy and GLC. No overt clinical effects were seen in the treated monkeys. Over 122 of the PCS was recovered unmodified jin \ the feces but only minute amounts were present in the urine. Only the adipose tissue and adrenals had high PCB assays, and microscopically, i except for a moderate proliferation of hapatocytlc SER, all tissues were normal. DNA was slightly decreased in liver homogenates of exposed animals and hepatic microsomal cytochrome P-450 was increased. i Torok [227], In 1976, reported a study of pregnancy in NMRI mice I treated with 2,2'-dichlorobiphenyl. The mice were separated into three groups, with group 1 (37 mice) serving as the control; group 2 (18 mice) received the PCB la oral doses of 375 mg/kg/day on days 1-3 of gestation, and group 3 (37 mice) received 750 mg/kg/day on the same schedule. Administration of the PCB at either level resulted in longer Intervals frok i breeding to parturition: 18.2 days for controls, 19.4 days for mice treated with the PCB at 375 mg/kg/day, and 21.8 days in mica created at 750 mg/kg/day. There also were reductions in the numbers of dams with litters and in the mean litter else. Reductions were greatest in group 3. The authors [227] concluded that the effects were due to delayed Implantation, (d) Reproductive and Teratogenic Effects of PCB Mixtures Curley et al [101] studied the transplacental movement of PCSs in rata. Three groups of 90-day-old female rats were paired with male rats of the same age. All were fed standard laboratory chov by the authors, who designated the day of Insemination as day 0. Aroclor 1254 was given InV Amtree N 08021 90 doses of 0, 10, and 50 mg/kg in peanut oil (presumably by oral Intubation) once a day on days 7 through 15 of pregnancy to groups 1, 2, and 3, respectively. On the 20th day after insemination, fetuses were taken by Caesarean section from three rats of each PCB-exposed group and from two control rats. The fetuses from each experimental group were divided Into two lots and analyzed as duplicate samples for FCBs. Ten rats from each of the three experimental groups were allowed to deliver spontaneously. When the offspring were 5 days old, six mothers from each exposed group and two from the control group were separated from their litters for several hours and then returned for 1 hour of nursing. The contents (milk) of the pups' stomachs were analyzed for PCBs* Litters from three rats In each experimental group were allowed to survive until weaning at 21 days of age. These baby rats then were killed and their tissues analyzed for FCBs by GLC with EC detection [101]. The rats subjected to Caesarean section had normal fetal complements, in both size and number, end in the rats allovad to deliver spontaneously there were no significant differences In average litter size andweight among the three groups. However, the three groups, with 0, 10, or 50-mg/kg doses of Aroclor 1234, had 0, 1, and 4 stillbirths on the average, respectively [101]. Analyses of the tissues of ths Caesarean-delivered pups showed measurable level# of PCB-derlvcd components In the expoeed groups only, The mean PCB concentration# were <0.12, 0.63 1 0.06, end 1;38 0.06 g/g, respectively, for groups 1, 2, end 3. Although the PCB dote for group 3 wee five times that of group 2 (50 vs 10 mg/kg Aroclor 1254), the average 91 N 08022 t .1 amount of PCB-derived' components measured in the fetuses from these two i groups differed by only two-fold* .The authors suggested that the PCB distribution between the mothers and their fetuses may not have been uniform and that a partial (unspecified) barrier may have existed [101], Livers were increased in size and had enlarged hepatocytes in 15 lof i 21, and 15 of 20 weanling rats from groups 2 and 3, respectively. Some rats from group 3 showed vacuolization of the hepatocytlc cytoplasm (10 of 20), and 5 of 20 exhibited bile duct proliferation* Morphologic changes in 1j the liver were more pronounced at the higher dose [101], PCB-derived components were detected in litter-pooled milk at mean 1 concentrations of <0.75, 20.60 t 1.59, and 66,34 t 8*36 #g/g in groups 1, i 2, and 3, respectively* The authors [101] concluded that the morphologic changes identified in the livers of exposed weanling rats were probably caused by FCBs transmitted to the pups in the milk from the dams [101], i Reproductive effects of feeding A r o d o r s 1254 and 1260 to Sherman strain rats for two generations were reported by Linder et al [228] in 1974. In preliminary experiments, the two mixtures were fed to groups of' 10 females at 100 and 500 ppm in the diet Two similar groups served as ( controls. The diets, fed for 67 days before the first mating, were; continued through gestation and lactation. After weeningu of the first i litters, . the parents continued to be fed the diets* After being fed PCBs , for a total of 186 days, they were again mated and the diets fed through ' the second gestation and lactation. Feeding A r o d o r 1254 at 500 ppm | resulted in only 4 first litters being bora (2 alive), with no survivors to weaning. Consequently, feeding A r o d o r 1254 et 500 ppm was discontinued* Vlth A r o d o r 1254 at 100 ppm, there was little Indication from either the , i' I Anooioi i 92 N 08023 V. first or second mating of -reduced fertility, or Increased death In utero or during the nursing period. Aroclor 1260 fed at 100 ppm for 67 days had no apparent effect on reproduction, litter size, or survival of the first litters; however after being fed for 166 days, only 5 second litters were b o m from 9 mated females, compared to 9 out of 10 In the controls. At 500 ppm, Aroclor 1260 resulted in more pups dead at birth In -first litters, reduced second litter size, and fever litters being weaned (3 of 8 first litters; 2 of 6 second litters). Subsequently, Linder et al [228] fed groups of 20 female Sherman rats Aroclor 1254 at 1, 5, 20, and 100 ppm and Aroclor 1260 at 5, 20, and 100 ppm. Appropriate control groups with similar numbers of rats were used. The experimental plan was similar to that described above except that the FI generation pups continued to be fed the F2 generation diet until they reproduced the F2 generation. The first matings of the FI generation were after they were exposed to PCBs In utero, In milk, and in the diet' for 125129 days. The FI generation rate fed Aroclor 1254 et 20 and 100 ppm were mated a second time after a total of 274 days of PCB exposure. Rats exposed to Aroclor 1254 at dietary levels of 20 ppm or more had fever pups In their litters than the controls [228]. There vere also fever F2 generation pupa then controls. Second litters bora from rets fed 100 ppm of Aroeler 1254 had Increased mortality and markedly decreased mating performance Dietary levels of 5 ppm Aroclor 1254 and 100 ppm Aroclor 1260 had no effect on reproduction in rats exposed through two generations. Liver weights vere Increased In 21-day-old FI male weanlings at 1 ppm of Aroclor 1254 and In either sex of FI and F2 weanlings at 5 ppm or higher of both A r o d o r s 1254 and 1260. 93 N '08024 Annoi02 Villeneuve et el [229],, in 1971, wrote about fetotoxic effects of A r o d o r s 1221 and 1254 in rabbits. Twenty-four mature female rabbits were divided into six groups each comprised of two control and four experimental does. Experimental animals were given the Aroclors orally at 1.0 and 10 og/kg/day beginning after mating and continuing through gestation. z They ware killed 28 days after mating. Neither Aroclor had a. fetotoxic effect at either dose level. Liver weights expressed as percentages of body weight were significantly heavier in the does fed 10 mg/kg Aroclor 1254 than in controls (4.29 vs 2.79%). Liver weights of the other experimental does and of all fetuses were not significantly different from controls. In another experiment reported by Villeneuve et al [230], 16 mature female rabbits were separated into four groups and, after mating, were dosed orally with 0, 12.5, 25, or 50 mg/kg of Aroclor 1254 dally for the first 28 days of gestation. The 50-mg/kg group had three pregnancies.z One pregnant female died on the 11th day and contained nine fetuses. A second one died on the 17th day and contained six resorption sites. The third female aborted three deed fetuses on the 28th day. Two rabbits in the 25mg/kg group had normal fetuses. A third rabbit aborted her litter on the 28th day and died. The four animals in this group showed an average weight loss of 26 g and liver weights found at autopsy 29 days after mating averaged 5.11Z of their body weights. Autopsies were performed on the fetuses the two rabbits which had conceived in the 12.5-ag/kg group; the first rabbit had two normal fetusest with six resorption sites, while the second aborted two fetuses on the 27th day and was found on autopsy to contain one partially resorbed and two dead fetuses. The two dead fetuses obtained on autopsy shoved subcutaneous cephalic hemorrhages and had Aonnma H 08025 asymmetric skulls. Average weight gain of the females during pregnancy vaa 265 g, and their liver weights averaged 6.03Z of their body weights. Controls gained 654 g during pregnancy, and their livers averaged 2.66Z of their body weights. In their third experiment, Vllleneuve et al [230] gave each animal in three groups of six female rabbits 25 mg/kg Aroclor 1254 in corn oil (orally). Controls received c o m oil .alone. A control group and one exposure group were dosed from day 1 through day 28, and another control and an exposure group were dosed from day 7 through day 28. Administration of Aroclor 1254 at 25 mg/kg/day from day 1 through day 28 resulted in abortions in two of four rabbits. Their average weight gain vaa 245 g and liver weights averaged 6.032 of their body weights (controls, 531 g weight gain; liver weights, 2.65Z of body weight). In the second group administered PCBs, one of four rabbits aborted. Average weight gain was 156 g and the liver weights averaged 4.82Z of the body weights. PCB concentrations la various tissues of six rabbits and their fetuses, chosen at random from the above groups, were determined by Grant et al [231]. Concentrations of PCBs were higher in the livers of the fetuses than in their mothers: 5.4 vs 2.1 ppm at a dose of 1 mg/kg; 78.1 vs 69.5 ppm at 12.5 mg/kg; and 375.3 vs 124.2 at 25 mg/kg. In other tissues, PCB concentrations were generally less in the fetuses than la the dams. Allen ee al [232] in 1974 presented evidence of possible fetotoxicity In a short term PCB feeding experiment with 12 adult female rhesus monkeys. The monkeys ranged in age from 7 to 10 years and had an average weight of 5.6 kg. Each previously had delivered at least one Infant sad the menstrual cycle of each had been recordad for at least 2 years. Six of the 95 Anomo4 monkeys were fed en unspecified diec containing 25 ppm of Aroclor 1248 for 2 months. The other six monkeys were controls. After 2 months, the PC3exposed animals were pieced on PCB-free diets of commercial monkey chow. The monkey which had consumed the largest amount of PCBs died on the 128th day of the experiment (232]. At the beginning of the 5th month, ie, 3 months after the test animals had been removed from the PCB-containing diet, the remaining five test monkeys and the six controls were maced again. Three FCB-exposed monkeys were thought to have conceived since each showed the characteristic post-conceptual bleeding, lack of the subsequent menstrual period, and an enlarged uterus. Two either aborted or reabsorbed their fetuses during the 2nd month of pregnancy and the third monkey delivered a well-developed but smaller-then-normal (375 g t 1 g vs 544 g t 101 g) infant. High concentrations of PCBs were found in the adipose tissues and adrenals of this infant with means of 27.7 and 24.4 jg/g, respectively, ae compared to a range from 0.01 to 0.98 tg/g in the other infant tissues analysed. The FCB levels in the placenta averaged 0.9 pg/g, and 50 jtg/g in the mother's adipose tissue. Two additional attempts were made to breed the nonpregnant females during the next 5 months.v Only the controls became pregnant end ell delivered normal infants. Six of the monkeys ware fed en unspecified diet containing 25 ppm of Aroclor1248 for 2 montha. The other six monkeys wsrs ussd ss controls. Aftsr 2 months, ths PCS-apesed sxtlaals were plaeed on PCB-free diets of commsrclsl monkey chow. In 1976, Barsotti at el (233] end Allen end Bersottl (234] reported their findings on reproductive dysfunction in female end male adult rhesus monkeys fed Aroclor 1248 in their diets. One test group of female monkeys Krnm 05 96 .N 08027 <Lf> received 2,5 ppm and the other group received 5.0 ppm of Aroclor 1248 in a commercial diet. The control group, containing 12 females and 6 males, was fed the commercial diet alone. Females received 200 g, and the males received 300 g of their respective diets dally. Food left in the feeding cups at the end of the day was removed and veighed to determine the daily intake. After the end of the first 6 months, the average'PCB Intakes were ISO and 364 mg for females fed the 2.5- and 5.0-ppm diets, respectively [233]. Some of the exposed females began to exhibit the characteristic skin and blood chemistry 9lgns of FCB intoxication within 2 months. At 6 months, all exhibited these signs in varying degrees. Menstrual cycles were irregular and menstrual bleeding was excessive and prolonged [233], The conception rates for the control females and for those fed the 2,5-ppm Aroclor diet were 12 of 12 and 8 of 8, respectively, whereas 6 of 8 females fed the 5.0-ppm Aroclor diet conceived [233]. All 12 of the control group pregnancies resulted in normal births, compared to 5 and 1, respectively, for the exposed females fed the 2.5- and 5.0-ppm diets. Three of the eight fetuses of monkeys fed the 2.5-ppm Aroelor diet were resorbed shortly* after conception. Profuse uterine hemorrhaging was observed rather than the Implantation bleading which usually occurred 17 days after conception, according to the authors [233]. The two females from the group fed the 5.0-ppm diet who did not conceive initially ware bred five t i n e without success. Of the six females of this group that did become pregnant, three aborted at 46, 67, and 107 days of gestation; one fetus was resorbed, one was stillborn, and one delivered normally. The six live infanta b o m to PCB-fed mothers had body weights that were less than = 97 N 08028^h < Anonm6 normal for Che colony by one co cvo standard deviations. These Infants began shoving signs of FCB toxicity (acne, swollen eye lids, Increased skin pigmentation) after nursing their mothers for less than 2 months [234], In samples obtained from three of their mothers after the Infants developed the poisoning signs, the milk contained FCBs at 0.134-0.397 ppm, and the milk fat from a fourth mother contained 16.44 ppm. Three' of the infants died 44-112 days after birth. The effects of Aroclor 1234 on reproductive performance and fetal Integrity were evaluated In beagle dogs and Hormel miniature swine by FL Earl et al (written communication, 1976). Aroclor 1234 was administered orally In capsules as a solution In corn oil to 46 purebred beagle bitches once dally after the 1st day of gestation. Ten bitches were given 0.23 mg/kg/day, 16 were given 1 mg/kg/day, and 20 were given 5 mg/kg/day. Sixteen untreated bitches served as controls. The data presented show that Aroclor 1234 at 3 mg/kg/day significantly interfered with reproductive performance and was teratogenic in the beagle. When Aroclor 1234 was administered at 0.23 and 1.0 mg/kg/day, no effects on reproduction were observed but the Incidence of patent fontaaellcs In the offspring of the l.O-mg/kg/day group was increased sharply. Dosage at 5.0 mg/kg/day resulted In 43.52 resorptions (4-fold Increase over the control rate) and an average of only two live pups per litter. Patent fantaaelles were present In 50% of the offspring. Earl and his eoeorkers fed Aroclor 1254 to Hormel miniature swine in doses of 1.0 (4 sows), 10.0 (6 sows), and 30.0 (7 sows) mg/kg/day for 21 days before breeding and throughout gestation. Five sows served as controls. The 1-mg/kg/day dose produced a statistically significant 000107 N 08029 percentage of fetal reaorptions (231). Increasing the dose to 10 ag/kg/day lowered the fertility rate to 50% (80% in controls) and increasing the dose to 30 mg/kg/day lowered the fertility rate to 43%. Cleft palate and syndactyly in three feet were observed in on# fetus from the group fed 10 ng/kg/day. At this dose level, there was also a significant decrease in survivability with only 71% of the offspring alive after 5 days. At the 30-mg/kg/day dose, 14 of the 15 Implantations were resorbed and teratogenic abnormalities were present in 100% of the observed fetuses. Cleft palates, syndactyly, and patent fontanelle# were the teratogenic effects observed. The fact that pigs are normally born with closed fontanelles increases the slgnflcance of the teratogenic findings. (e) Studies on Mutagenicity and Cytotoxicity To evaluate the effects of PCBs on the testes of rats, Dlkshlth et al [235] administered, by oral intubation, 50 mg/kg/day of Aroclor 1254 dissolved In corn oil to a group of 18 adult male Sprague-Davley rats for 7 consecutive days. A control group of 18 rata received corn oil without PCBs. Three rats from each group vara killed 1, 7, 15, and 30 days after the last PCB administration. The testae and epididymlses were separated and weighed, as were the livers. Microscopic, hlstochemical (acid phosphatase), and cytogenetic examinations were performed. Rats used for cytogenetic examination were injected lp with colchicine 2 hours before being killed and the chromosomes In teatlcular tissues were examined. No affeeta on weight or gross appearance of either the teetea or epididymis were noted, nor was there evidence of atrophy or hypertrophy of the testes. The only structural changes noted In the testae of the exposed group was a proliferation of Interstitial tissue cells. These cells showed 99 N 08031) 4 i AOrtl08 an Increase in acid phosphatase activity, which, according to the authors [235], denoted a change from particulate enzyme localization in testicular interstitial cells of the controls to s disseminated, diffuse localization in the testes of the exposed group. Cytogenetic analyses shoved similar chromosomal configurations in both the control and the exposed groups. In the PCB-treated rats, some apparently sporadic abnormal chromosomes were seen in a few of the metaphase figures; chromosomal abnormalities also included breaks, exchange figures, chromatin bridges at anaphase, and chromosome fragments* The significance of these findings was unclear to the authors [235]. Green et al [236] looked for mutagenic effects in the bone marrow and spermatogonlal cells of male Oaborne-Mendal rats fed various doses of PCBs. Rats were given Aroclor 1242 either in single oral doses of 1,250, 2,500, or 5,000 mg/kg or in multiple oral doses of 500 mg/kg/day for 4 days* Aroclor 1254 was administered orally in daily doses of 75, 150, or 300 mg/kg for 5 days. The Aroclors were mixed with corn oil, except the 5,000- mg/kg dose of Aroclor 1242, which was given undiluted. Controls were fed uncontamlnated corn oil. The animals were given Colecimld (a colechlclne derivative) at 4 mg/kg 24 hours after PCB dosing vaa completed and they were killed 3 hours later. Aroclor 1242 produced no statistically demonstrable evidence of chromosomal damage in bone marrow eells at doses of 1,250 or 2,500 mg/kg, or at the 500-mg/kg dose level [236]. At 5,000 mg/kg, there appeared to be an Increase in the number of chromosomal abnormalities. However, since most of the changes occurred In one animal, the findings were not considered to be significant. Aroclor 1254 did not produce statistically 000109 100 V 33C31 significant numbers of chromosomal abnormalities In bone marrov cells at any dose level tested. A statistically significant number of .chromosomal abnormalities vas not identified in spermatogonlal cells from rata fed Aroclor 1242. Spermatogonlal cells from rats given Aroclor 1254 vere not examined since the results with the mors acutely toxic Aroclor 1242 vere negative. All observed chromosomal lesions vere single chromatids. The authors [236] did not exclude the possibility of point mutations since the procedures used in this experiment vould not have detected such damage. Green et al [237] also Investigated the possible Induction of dominant lethality In rats given Aroclor 1242 or Aroclor 1254 by oral Intubation. Except for the positive controls, results shoved nonrepToducible positive effects that vere not related to dose or stage sensitivity. The authors concluded that the two Aroclors did not appear to be mutagenic. Wyndham et al [116] performed the "Ames" bacterial test for mutagenicity on a variety of FCBe, using Salmonella trphlmurlum mutant strain TA1538. A comparison vas made of the mutagenic potentials of Aroclor 1254, 2,2'^S'-tetrtchlbrobiphenyl, Aroclor 1268, Aroclor 1221, and 4-chlorobiphanyl. The results shoved cleerly that as the degree of chlorination decreased, the mutagenic potential Increased. A concentration of 100 jig of 4-chloroblphenyl In the test medium gave over 2,000 revertant colonies/plage The more highly chlorinated biphenyls shoved very little activity as mutagens. HoopIngarner et el [238] studied the toadcitlee of various Aroclors at 50 ppm In the culture medium of Chinese hamster cells, sad. found Increasing toxicity (measured by cell population survival) vlth decreasing 101 .N 08032 chlorination. Aroelor' 1016 appeared to be disproportionately cytotoxic, on the basis of its chlorine content, suggesting to the authors that this product contained certain toxle components in higher proportions than either Aroclor 1232 or A r o d o r 1242, which it resembled chrcaatographically, Aroclor 1254 at 100 ppm shoved no apparent effect on the chromosomal integrity of humen lymphocytes in vitro. - Popper et al [239] studied the effect of hepetlc microsomal biocraneformation systems from control mice end from mice treated vith PCBa on the mutagenic potentials of the primary carcinogen N-methyl-N'-nitro-N- nltrosoguanldlne (MNNG), and the secondary carcinogen dlmethylnltrosamine (DMN), Hepatic mlcrosomes were Isolated from male Svlas-Webster mice that had been given 500 mg/leg of Aroclor 1254 4 days earlier, and from untreated control mice* The mutagenlcltlea of MNNG and DMN were assayed by a bacterial auxotroph reversion test using Bacillus subtilla. Mlcrosomes prepered from Che livers of the PCB-treated mice had 2-3 times as much cytochrome P-450 activity as the controls [239]. DMN added directly to the cultures vss not mutagenic et concentrations ee high as 300 mM. However DMN was converted to e mutagen when exposed to such mlcrosomes In the presence of an NADPH-genarating system. When MNNG wee Incubated with Isolated mlcrosomes, its mutagenic activity wee reduced. The authors concluded that isolated hepatic microtomes can modify the biologic activities, of mutagens end that the hepetlc microsomal biotransformation system could play a key role in chemical mutagenesis. (f) Studies on Ttaorlgenasls Kimbrough et el [218] distributed 400, 21- to 26-day-old weanling, Sherman strain, "COBS1* f w a l e rata randomly into two equal-tire groups. V 102 N 08033 Half of th rata were fed a plain ccramercial laboratory chow, The other 200 were fed laboratory chow containing 100 ppm of Aroclor 1260. The dosed group of rate was fed the FCB diet until 6 weeks before they were killed at the age of 23 months. Autopsies were performed on these rats .as well as those- that died before the exposures ended. Microscopic examination was completed on 184 dosed animals and 173 controls. From a few to multiple elevated tan nodules were found on the liver surfaces of 170 PCB-fed rats. The nodules varied from 0.1 to several cm in diameter. Only one such abnormality was found in the controls. Of the tumors, 26 of those -In exposed animals and the 1 from the control animal were hepaeoearclnpmic ; the other 144 experimental animals had hepatocellular nodules that were described as characteristic of neoplastic nodules or synomously, hyperplastic nodules. The authors [218] said "neoplastic nodules are part of the spectrum of response to hepatocardnogens and must be Included in the evaluation of tumorigenesis." Tumors identified and analyzed from other organs had no unusual features; no apparent differences in Incidence.were observed between the experimental and control groups [218]. s Evidence of PCB-lnduced hepatocarcinemas was reported by a group of Japanese investigators in 1972 [240] and in 1973 [241]. Mine groups of 12 male dd alee were fed a commercial stock diet supplemented with 100, 250, or 500 pga of Xanechlors 300, 400, or 500. A control group of eight mice was fed the stock diet. All mice were given water ad libitum. After 32 veeka, the animals were starved for 18 hours, killed, and examined macroscopically for tumors. .Seven of the 12 mice fed Kaneehlor 500 at 500 ppm developed hyperplastic liver nodules and five had well-developed 103 K 0A80it3n4rtiia hepatocellular carcinomas* None of the mice fed Kanechlor 500 at lover concentrations or Kanechlor 400 or 300 at any concentration developed hepatocarcinemas. In 1973, Klsura and Baba i242] described neoplastic changes in the livers of rats exposed to Kanechlor 400, Thirty 10-veek-old rata were separated Into an experimental group of 10 males and 10 females and a control group of 5 males and 5 females* The experimental group vas fed a diet supplemented vlth olive oil containing various concentrations of Kanechlor 400. The control group received an olive oil-supplemented diet. The diet of the experimental group of rats contained 385 ppm of Kanechlor 400 for the first 4 weeks, followed by 77 ppm for 8 weeks, 154 ppm for 3 weeks, 308 ppm for 3 weeks, and 616 ppm for 8 weeks. Body weights were checked weekly and shoved rapid decreases during the 616-ppm1 feeding period; for this reason the Kanechlor 400 content of the diet was reduced to 462 ppm for the next 32 weeks* The total feeding period for the experimental and control animals was about 58 weeks (400 days)* All rats that ingested total doses of more than 700 mg of Kanechlor 400 developed hypertrophy of the liver [242], Pale brown nodules were present on the parietal and cut surfaces of the livers of female rata that had ingested more than 1,200 mg of PCBe* However, none of the male rata had such hepatic nodules, despite having Ingested equal or greater amounts of Kanechlor 400* On microscopic examination, the livers of female rats were observed to have fatty degeneration and multiple adenomatous nodules that appeared to be benign neoplastic lesions. Males did not develop such neoplastic lesions; however, their livers did exhibit fatty degeneration. Lung abscesses, pneumonia, splenic atrophy, and Intracranial abscesses were Aitfwn'3 10* N 08035 found frequently In the experimental group. The authors [242] thought that resistance to infection vas lowered In the rats fed Kanechlor 400, * A formal rulemaking hearing vas convened August 20,' 1976 by the US Environmental Protection Agency on its proposed toxic pollutant vater effluent standards for PCBs (Federal Register 42:6532-55, February 2, 1977). Part of the testimony concerned comparative studies in vhlch groups of 100 male and female Charles River rats vere fed 1, 10, and 100 ppm of Aroclors 1242, 1254, or 1260 for 24 months, The survival of the rats vas poor and the experiment vas said to have been inconsistently reported. A rvaluation of the pathology slides revealed the occurrence of liver tumors (hepatomas and cholangiohepatcmas ) in the rats fed any one of the three Aroclor products. The incidence of liver tumors in the rats dosed at 100 ppm vas 3/20 for Aroclor 1242, 6/27 for Aroclor 1254, and 7/27 for Aroclor 1260, compared with 0/20 for the controls In addition to the tumors there vas a high frequency of nodular hyperplasia. The Incidence of nodular hyperplasia at 100 ppm was 8/20 for Aroclor 1242, 13/27 for Aroclor 1254, and 7/27 for Aroclor 1260, comparedwith 1/23 for the controls. Nodular hyperplasia in the rats dosed at 10 ppm occurred in 2/10 for Aroclor 1242, 3/26 for Aroclor 1254, and 9/23 for Aroclor 1260, and 1/23 for the controls. The incidence of tumors of the pituitary gland also vas elevated la each treated group. Correlation of Exposure and Effect (a) Absorption, Metabolism, Excretion, and Body Burdens It has been demonstrated in experimental animals that PCBs can be absorbed into the blood from inhaled air [97] and from the digestive tract 105 Annoii4 N 08036 [50,51,95,96]. Qualitatively, the effects in experimental animals from absorption by either route were similar [98,99,202*206]. When PCBs were applied to Che skin, certain effects, such as those on the liver, were similar to those obtained vhen PCBs were ingested or inhaled [205-208]. Thus, it appears that PCBs were also absorbed by this route. In experimental animals, most PCB Isomers were metabolized in varying degrees to more polar compounds such as hydroxylated derivatives [41,48,49,51-56*58-81,85,87]. The more highly chlorinated isomers were metabolized slowly and accumulate in the tissues [41,50,51,55,61-64,66,8284,96,103,107-110]. The hydroxylated derivatives were excreted in the bile, urine, and milk [41,48,50-56,58-61,63-66,69,71-80,85]. Unmetabolized compounds were excreted in feces, milk, end hair [41-44,50,51,53-56,100102], and traces ware found in urine [42,51-55,57-62,103-105]. In man, the metabolism of PCBs has not been studied. However, finding that PCB isomers that are difficult to metabolize become concentrated in residual PCBs of tissues from the general population, from persona who have ingested PCBs, end from those with occupational exposure suggests that men metabolizes, eliminates, and storts the compounds in ways similar to those of enlmsle [7,36,136,168,171-175]. Determination! of PCBs or their metabolite! In urine or fecee of humans have not been reported. PCBs have been found In human hair [102,142]. Excretion in human milk of PCBs with composition! similar to those In blood, has been reported in association with general environmental exposure! end following Ingestion tnd occupational exposures [143,144,166,192]. These findings of PCBs in human hair and milk also suggest metabolism and excretion similar to those of animals. in o m 1 5 N 08037 106 Because PCBa are *widespread In the environment, detectable concentrations have been found In tissues and body fluids of a substantial portion of the US population [36,102,134,135,137,140,144]. Detectable concentrations have been found in up to 62Z of blood serum samples, with concentrations ranging up to 30 ppb [137]. In emaciated patients, blood FCB concentrations as high as 100 ppb have been found- [140]. FCB concentrations In about three-fourths of adipose tissue samples from the general population were <1 ppm, and the remainder were mostly In the range of 1-2 ppm [36,136]. Usually the FCB Isomers found In blood and adipose tissue have been penta-, hexa-, and heptachloroblphenyls [7,135,136], and a high correlation was found between the concentrations in these two tissues [141]t PCB Isomers In cord blood were qualitatively Identical to those In maternal blood [138]. FCB Isomers excreted In human milk were similar or Identical to those In blood [168], and the concentrations in milk were positively correlated with adipose tissue concentrations [143]. In human milk samples from the general US population, FCB concentrations up to 13 ppm (fat basis) have been reported (EP Savage, written cosmunlcatlon, February 1977). i These concentrations of FCBs In blood, adipose tissue, and milk of the general US population arise from dietary Intakes estimated to be of the order o f . 10-20 Mg/day [46] and from Inhalation of air that may contain up to 100 ng/cm a [26,38]. (b) Irritation Effects and Chloracna The first reports of adverse effects of FCBs on workers included chloracne [120,123,130], digestive disturbances [123], Irritation of mucous membranes [120,123,130], and Impotence [123], The exposures associated v p Ts( V ^ 6 107 N 08038- vy with the effect 'were not well-defined either qualitatively or quantitatively. When FC2e were first being manufactured, (in mostly open systems) the exposures were to benzene and unidentified intermediates in addition to FCBs [120]. Jones and Alden [120] .and Schwartz [123] did not report exposure concentrations in their studies. However, Drinker et al [125] indicated that average concentrations of FCBe ranged from about 0.5 to 1.5 mg/cu o in 30 factories, which may have included the factories studied by Schwartz [123]. On the basis of these reports [120,123,125], it would appear that chloracne and some other systemic effects occurred with early FOB preparations when their average concentrations in workroom air were below 1.5 mg/cu m. Elkina [130] found that airborne FOB concentrations approaching 10 mg/cu m in capacitor-impregnating operations in Massachusetts were "unbearably" irritating to the workers, but there were no apparent toxic effects with concentrations that averaged up to 5*8 mg/cu m. Elkins [130] did not describe the processes or the PCBs used. Fuccinelll [186] found that when capacitors were filled with Aroclor 1254 heated to 70*80 C, PCB concentrations of about 5-7 mg/cu m resulted. The workers studied by Puccinelll [186] developed chloracne after 4-8 months of exposure. In studying similar processes, Hofmann and Maneghini [187] found that chloracne developed after 2.5-4 months of exposure. These Investigators [187] also described the development of areas of brown skin on the foreheads of workers. They did not describe the PCBs used or the exposure concentrations. Reports of the development of chloracne in Americana, who worked in operations which used heated PCBs, appeared in 1964 and 1969 [188,189]. In one of the processes [188], an Aroclor with a chlorine content of 65Z and containing both PCBs and polychlorinated N 03039 108 terphenyls was used; the PCB used in the other process [189] was not described, but extensive skin exposure from wearing PCB-soiled clothing and from lameraion of unprotected hands into the PCB mixture was described. A case of chloracne that developed in an Australian worker after exposure to A r o d o r 1242 at concentrations of 1-2 mg/cu m was reported by Ouw et al [196]. The PCB preparation was heated during a capacitor-filling process. Complaints of process workers Included irritation of the face, eyes, and skin. Eczematous rashes were also found on their hands and legs. In the reports of chloracne development in occupations involving PCBs (where environmental concentrations of PCBs were measured) [125,130,186189,196], the sampling and analytical methods did not distinguish between vapor and particulate forms of the PCBs. However, a common factor in many of these reports [186-189,196] was the use of heat in the process which would tend to generate PCB vapors. In their study of capacitor and PCB manufacturing plants in Japan, Hasegawa et al [191] found that concentrations of PCB vapors (or particles <0.1 on in diameter) exceeded the concentrations of PCBs in particles >0.1 m in diameter. The compositions of PCBs in the particulate were similar to those in the PCB preparations in use, but the less highly chlorinated compounds were concentrated In the vapors. In this study, where PCB vapors ranged from 0.026 to 0.965 mg/cu m and PCBs in the larger airborne particulate ranged from 0.19 to 0.650 mg/cu m (maximum total PCBs of 1.6 mg/cu m), dermal ailments Included a brown chromodermatosis of the hands and chloracne. The workers had been exposed to PCBs from <1 to 20 years. Meigs et al [190] described a process in which chloracne developed where the exposures had to have been to PCB vapors. The PCB which was used 109 Anomic N 08040 aa a heat-exchange medium was noc described, but PC5 concentrations were reported to be about 0.1 mg/cu a In the workroom elr where the workers were exposed. Under theae conditions, chloracne developed after a minimum of 5 months of exposure. Chloracne has also been studied in connection with determinations of tT PCB concentrations In blood. Hara et al [192,193] found -whole blood PCB concentrations of 7 to 300 ppb In Japanese workers engaged In capacitor filling. About 40% of theae workers had chloracna and 13% had irritation of the skin. Kltaaura et al [194] found PCBs at 320-820 ppb in blood samples from Japanese workers engaged In capacitor manufacture. Skin ailments, including chloracne, were found In 10 of 13 workers studied. Inque et al [195] found chloracne In a man exposad to PCBa in a silkgloaalng factory who had a concentration of about 200 ppb of PCBs In his blood, but they [195] found what vara described as relatively mild skin abnormalities In 28 other workers engaged In similar processes who had blood PCB concentrations mostly under 100 ppb (2 had concentrations >100 ppb). Ouv et al [196] concluded from their study of capacitor workers that no adverse effects were found In workers with blood PCB concentrations <200 ppb. Studies of ?CB-exposed workers where chloracne has not been found Include these of Levy et al [197], Karppanen and Kolho [198] , and B u m g s m e r et el [ 1 M]. la the study by Karppanan and Kolho [198], workers who had been exposed to PCBe for 4 years la e capacitor-impregnating operation had PCB coneantratlone of 74-1,000 ppb In samples of their blood. The environmental exposure concentrations of PCBs were reported to meet "internationally accepted standards." Other factors of the work situation, V * 110 M such as the skin protection, used, were not reported. In the study by Levy et al [197], workers who had been exposed to FCBa for 2.5-18 years had concentrations of PCBs In samples of their blood ranging from 36 to 286 * ppb. PCB exposure concentrations at the time of the study were 0,013-0.264 mg/cu m. Although some of the workers complained of throat or eye irritation, and some' skin rashes were found, no cases of'chloracne were seen. From the description of the work situation, It Is unlikely that skin exposure to liquid or solid PCBs was an Important factor in the total exposure of these workers. In their study of refuse workers, Bumgarner et al [199] found blood PCB concentrations to be 4-14 ppb. One possible source of exposure of these workers was airborne incinerator effluents, and It Is unlikely that additional exposure from skin contact occurred. Although skin exposure was unlikely In these two reports [197,199] where chloracne was not found, skin exposure is not necessary for chloracne to develop. Chloracne has been observed in Japanese people estimated to have Ingested total PCB doses of 0.3-4 g [146,164-167], and chloracne-llke lesions have been produced In experimental rhesus monkeys fed PCBs at 3 ppm In their diets [222]. Thus, although eliminating exposure of the skin through engineering controls and using appropriate protective clothing and work practices will reduce the total absorption of PCBs, these practices will not necessarily eliminate cfiigoracno. The data indicate that chloracne may occur with exposures to PCB vapor concentrations as low as 0,1 mg/cu m for several months, and with PCB concentrations In the blood of about 200 ppb. N` 08042 Annitt2tf (c) Effects Referable to the Liver Some clinical and autopsy findings in , Yusho, the disease that occurred after ingestion of PCB-contaminated rice oil by humans, were indicative of liver Injury [155-158,179*181]. These findings Included changes in liver cell anatomy considered consistent with microsomal enzyme stimulation and increased SAP activity. Effects that persisted for several years included decreased concentrations of iron and bilirubin in the serum [155,179] and Increased serum concentrations of triglycerides. The latter were found to Increase with residual concentrations of PCBs in the serum [180]. The maximum amounts of PCBs consumed by. Individuals manifesting these effects were estimated to have been of the order of 3-4 g total Intake oyer several months [165]. For two Yusho patients a daily PCB consumption of 67 Mg/kg for 3 months was estimated [167]. The maximum Intake would have been of the order of 50 ppm in the diet or 0.5-1 mg/kg/day. For comparative purposes, absorption of PCBs from inhalation during maximum occupational exposures that have been reported (10 mg/cu m) probably did not exceed 0.15 og/kg/day. The extent to which PCB consumption was responsible for the effects on the liver is not known since the contaminated oil also contained PCDFs [20,160] la quantities that could have resulted In a maximum PCDF consumption of 20-50 mg* Autopsy findings 1-3 years after the poisonings Indicated unusually high concentrations of PCDFs (0.3-2.5 Mg/g) relative to PCBs (3.5-5.6 jig/g) in liver fat [160], Although most animal feeding experiments have been conducted with dietary levels of PCBs that are much higher than those ingested by Yusho 112 patients, others have been conducted with dietary PCB levels that seen to confirm the Yuaho findings. Experiments have been reported with various commercial FCB mixtures (Aroclors 1242, 1254, 1260, and Clophen A60) added to the diet at 1*10 ppm [101,209*212,215,228,233] These experiments % demonstrated increased liver veights at all concentrations, dose dependent stimulation of microsomal enzyme activities, detectable > proliferation of the SER at concentrations of 10*100 ppm, and other microscopic changes including enlarged hepatocytes, hepatocytlc vacuolization, and, with prolonged exposures, development of adenoflbrosis. At high PCB concentrations (>1*5 mg/cu m), inhalation experiments with animals have demonstrated increased liver veights [98,99,202,203], Microscopic changes similar to those seen from FCB ingestion were found in livers of rats after inhalation of Aroclor 1254 at 1.5 mg/cu m or more [203], and from other commercial preparations (Decachlorodiphenyl and Solvol) at much higher concentrations (>4 mg/cu m) [99,202]. These data from the Yusho poisonings and from animal experiments indicate that hepatic effects seen in human are similar to those seen In animals. They also indicate chat some commercial preparations may be less severe liver poisons than others, but the data are not definitive in this regard. The ingestion experiments demonstrated Increased liver veights from feeding K B s at 1 ppm, and increasing evidence of liver Injury as -% dietary levels vers increased. A dietary level of 1 ppm may be considered roughly equivalent to e daily Intake of the order of 0.01-0.02 mg/kg, which would be somsevhat similar to the intake from Inhaling PCBa at 1 mg/cu a. Several reports of occupational exposures to FCBa have Involved the liver in various ways [123,125,127,186,190,191,197,198,200], In the earliest reports of FCB toxicity [123,135,127], the PCBs were mixed vlth chlorinated naphthalenes. The mixtures caused many cases of chloracne and, in some cases, jaundice* Liver cirrhosis vlth superimposed yellow atrophy was found in at least one fatality [125] I Similar findings have not been reported where exposures were to only PCBs in the absence of chlorinated naphthalenes. Mention of nausea and digestive disturbances in some reports [123,197] may have indicated liver injury. In the study by Schwartz [123], neither liver function test findings nor exposure concentrations were reported. In the Levy et al report [197], liver function tests (SAP, SCOT, SGPT, total bilirubin) performed at the time of the study did not Indicate current liver Injury. The workers had been exposed to unidentified PCBs at 0.013-0.264 tng/cu m, and blood PCB concentrations were 36-286 ppb. Even though there were no findings of current liver injury, these investigators' [197] examination of past medical records shoved occasional findings indicative of slight liver Injury (elevated serum enzymes, triglycerides, and uric aeld). A report of a worker who was removed from further exposure after experiencing nausea on exposure to an askarel containing Aroclor 1254 was nog accompanied by liver function teat results or exposure concentration data (In the Matter of General Electric Company, Fila No. 2633, New York State Department of Environmental Conaervatlon, 1975). Mora condualve studies of liver function were reported by Meigs et el [190], Haaegava et el [191], Hare et el [192,193], end Ouv et el [196]. t *>* -*1 Of the workers exposed to vepors of an undefined PCB et 0.1 mg/cu m in the 4nrovi 0 3 114 ,K 08045 5.' 2* 3? s ir; r. Vs. 4* rf i; I. study by Meigs et al [190],. liver function teats vere performed on seven, Findings in six of the workers ver normal and, In the other one, cephalin flocculation and thymol turbidity tests vere on the borderline of abnormality. Hasegava et al [191] found some changes in liver function teats (increased SGOT, SGPT, and SAP, and decreased serum cholinesterase and lipids) of 99 workers exposed to Kanechlors but the Investigators considered that only the decreased serum lipids were significant PCB i exposure concentrations at the time of the study vere 0.045-1.6 mg/cu m. The workers had exposure histories of <1 to 20 years. FCB concentrations in blood samples of the workers averaged 370 ppb, Hara et al [192] did not find evidence of a correlation of serum triglyceride concentrations with blood PCB concentrations during the first year after the work with PCBs was discontinued. However, when the same workers vere studied 2 years after stopping work with PCBs, the proportion of workers with elevated serum triglycerides increased as residual blood PCB levels increased [193]. The effect was particularly prominent In workers with residual blood PCB concentrations >50 ppb. In a study of 34 workers exposed to Aroclor 1242 in capacitor manufacture, Ouv et al [196] found individual' abnormalities in SGPT, SAP, and serum bilirubin, but average values for the group vere normal. Bremsulphaleln retention tests were elevated in four workers. Ouv et al [196] considered that there were no adverse jgneponses in workers with blood FCB concentrations below 200 ppb. The PCB exposure concentrations were 0.32-1.44 mg/cu a. No evidence of Impaired liver function was found In other studies [186,194,195,198] where PCB exposures vere reported as: Aroclor 1254 at 5-7 mg/cu m for 2-4 years [186]; Kanechlors at >0,25 mg/cu m [195]; and IIS SWWW*?* K,0.8046 unidentified PCBa at <1 mg/cu m for 4 years [198], Evidence relating to impaired liver function from occupational exposures to PCBs is generally consistent with findings in Yusho patients and in animal studies that indicated some effects could be expected from PCB Intakes equivalent to PCB inhalation at about 1 rag/cu m. The occupational exposure studies shov occasional evidence of liver Injury in workers exposed at concentrations of 0.013-0.264 mg/cu m [197], 0.1 ag/cu m [190], 0.045-1.6 mg/cu a [191], and 0.32-1.44 mg/eu m [196], Whether the observed effects occurred with exposures at the lover end of all these ranges is not known. The occupational exposure studies also shoved delayed recovery of normal serum triglycerides after exposures to PCBa stopped [193]. The elevated serum triglycerides were related to the higher residual blood PCB concentrations, and these in turn were related to the years of exposure. Residual PCBa have repeatedly been shown to be the more highly chlorinated Isomers and those metabolized with greater difficulty [7,36,51,83,103,110,135,136]. Summaries of effects of PCBs on humans and animals are presented in Tables III-9 and III-10, respectively. Carcinoxancltv. Mutagenicity. Teratogenicity, and Effects on Reproduction Ca) Carcinogenicity There la extensive evidence for formation of arena oxide intermediates during the metabolism of PCBs by several species Including rhesus monkeys [51,68,69,74,75,81,115,116,118]. Arene oxide formation was also proposed as a plausible Intermediate In the metabolism of the slowly 4 n r\ n m 116 N 08047 /' \ metabolized 2,2* ,4,4',5,5'-hexachlorobiphenyl [70,79], Binding PCB metabolites to nuclear components of liver cells has been demonstrated on administration of PCBs to monkeys [51], and to rats [81], and by in vitro experiments [51,82,86,116,117]. This information is sufficient to arouse suspicions that PCBs could have carcinogenic potential in humans. Hepatomas vere produced In 170 of 184 examined female rats fed Aroclor 1260 at 100 ppm from 3-4 to 23 months of age [218], and in .9 of 22 BALB/cj male mice fed Aroclor 1254 at 300 ppm for 11 months [221]. The tumors found in the rats Included 26 hepatocarclnomas and 144 neoplastic nodules, Only one liver tumor, a heps tocarcinema, was found in 173 control rats. In another report (Federal Register 42;6532-55. February 2, 1977), dose-related incidences of liver tumors vere reported in rats fed A r o d o r s 1242, 1254, or 1260 at 1, 10, and 100 ppm in the diet for 24 months. No liver tumors vere reported in rats fed the diets containing PCBs at 1 ppm. Only one tumor, a hyperplastic nodule (neoplastic nodule), was found in 23 controls. Neoplastic nodules vers found in the livers of rats fed the diet containing 10 ppm of PCBs (2/10, 3/26, and 9/23 for Aroclor 1242, 1254, and 1260, respectively). Higher tumor Incidences were found when diets containing PCBs at 100 ppm vere fed (11/20, 19/27, and 14/27 for Aroclors 1242, 1254, and 1260, respectively) and the tumors Included hepatomas and cholanglohefgtSBSS (3, 6, and 7 for Aroclors 1242, 1254 and 1260, respectively). In this experiment the incidence of pituitary tumors vas high In PCB-fed rats. In a study sponsored by the National Caneer Institute, Aroclor 1254 vas fed to groups of 24 rats at 25, 50, and 100 ppm In the diet. No liver inn/vio*; 117 ;M 08048 tumors were found In the controls, in the experimental females at any dose level, or In experimental males fed PCBs at 25 ppm. However, hepatocellular carcinomas were found In a male rat fed Aroclor 1254 at 50 ppm and In two males fed the PC3 at 100 ppm. The data also Indicated that the incidence of leukemias In males was dose-related (3/24 in controls; 8/24 In rate fed 100 ppm), Kanechlors have also been found to produce liver tumors when fed to mice and rats [240,241,242], Of 12 mice fed Kanechlor 500 at 500 ppm for 32 weeks, 7 developed neoplastic liver nodules and 5 had wall-developed hepatocellular carcinomas [240,241], In this experiment which had only 12 miee/group and continued for only 32 weeks, liver tumors were not found with Kanechlors 300 and 400 or with lover doea lavala of Kanechlor 500, However In another experiment [242], Kanechlor 400 fed to 10 male and 10 female rata for 58 weeks did produce liver tumors In the females. In this experiment the amounts fed (38-616 ppm) varied from time to time, but were in the 308-616 ppm range for the last 43 weeks Theta findings from animal studies indicated to NI0SH that PCBs have potential carcinogenic activity In humeae. They Indicate, but. do not conclusively demonstrate, with the dlettry levels used, thee the less highly chlorinated mixtures (Aroclor 1242 end Keaechlors 300 end 400) hive less carcinogenic potential than the store highly chlorinated mixtures (Aroclors 1254 and 1260 and Kanechlor 500), However, all FOB mixtures adequately tasted In rets end mlee have shown carcinogenic activity. The Intakes of PCBs at the lowest dietary level that has produced tumors In rsts (10 ppm) would be somewhat comparable to Intakes from occupational exposures at 5-10 mg/cu a* However PCBs ere slowly eliminated .from the 118 .N 08049 body and the higher chlorinated compounds may accumulate in the body for years. Thus animal experiments that are limited to 2 years by the life span of the animals may not be informative relative to workers exposed for up to 45 years. In humans, there are no adequate studies to confirm or deny carcinogenicity although preliminary data suggest that among Yusho patients, deaths due to cancers exceed expectations [160,1611 and preliminary studies of two occupationally exposed groups in the US indicate that the occurrence of certain cancers may be excessive (HA Slndalre, written communication, June 1976; G Roush, written communication, September 1976). However, the two reports are not consistent as to the types of cancers found to occur more frequently than expected. (b) Mutagenicity Several PCBs and ?CB mixtures. Ineluding the 4- and the 2,2',5,5 laomers and Aroclora 1221, 1254, and 1260, were subjected to the "Ames" test for mutagenicity [116]. Although 4*chloroblphenyl had mutagenic activity in this teat, the more highly chlorinated FCBe shoved very little activity. Aroclor 1254 did not cause significant chromosomal changes In the testes of rats after it was administered for 7 days at 50 mg/kg/day [235]. In another experiment [236], neither Aroclor 1254 administered at 300 mg/kg/day for 5 days nor Aroclor 1242 administered at 500 mg/kg/day for 4 days produced chromosomal aberrations in spermatagonlal or bene marrow cells of rets. These mixtures also did not produce any evidence of dominant lethal mutations in rats [237]. Although FCBe have little mutagenic potential, they may alter the mutagenicity and carcinogenicity of other compounds by stimulating microsomal ensyme activities [239]. 119 (c) Teratogenicity PCBs have been found In embryonic and fetal tissues of humans [139,168] and experimental animals [101] after introduction of PCBs into the maternal body, demonstrating that the potential for direct teratogenic effects exists. Several experiments have been conducted vlth rats [101,228], rabbits [229], monkeys [232], and dogs and pigs' (PL Earl et al, written cowaunication, 1976) that are reinvent to a discussion of PCB teratogenicity. In some of these experiments, the PCBs were administered by gavage and doses were reported in mg/kg; In other experiments, the ' PCBs were reported as ppm fed in the diet. For purposes of relative comparison, 50 ppm in the diet can be equated to 1 mg/kg/day. This is the order of magnitude of the maximum rate of PCB intake by Yusho patients. Animal experiments have used PCBs In dietary-equivalent amounts of 1-2,500 ppm. In most experiments with PCBs administered in amounts equivalent to dietary levels of 100 ppm or more, fetotoxlclty (resorptions, absortlons) has been such that teratogenic effects may have been masked [101,228,229]. In the two-generation feeding study of rats by Linder et al [228], no terata were reported. This study covered Aroclor 125A in the concentration range of 1100 ppm and Aroclor 1260 in the range of 5-100 ppm. Although terete were not reported, Aroclor 1254 concentrations of 20-100 ppm resulted in reduced litter sices In rhesus monkeys [232], feeding Aroclor 1248 at 2.5 and 5 ppm caused abortions la some cases and lover than normal birth weights, but no terete were reported. In dogs, terete were not found in pups born from dams fed the equivalent of 12 ppm In the diet, but were present when 48- or 200-ppm equivalents were fed. Sove fed the equivalent of 50 ppm la the same experiment had high rates of resorptions and, at 10-30 times this Annni29 120 n oaosi level, terata were definitely present In the piglets (Ft, Earl et al, written communication, 1976). Although there were retarded Intrauterine growth and signs of PCB toxicity in Yusho babies at birth, no terata were reported [149,159,176,182,183], A normal baby was born to a woman exposed to PCSs iln her work. The PCB exposure concentrations were not reported but the PCB concentration in her blood was 25 ppb at the time the baby was b o m . These studies indicate that PCBa have teratogenic potential for humans. However, the terata observed In animals occurred at levels at or above doses equivalent to the maximum doses of the Yusho patients and at intake rates 3-4 times greater than intakes expected from inhalation at max imum reported occupational exposures* (d) Other Effects on Reproduction Feeding rats Aroelor 1254 at 5 ppm or A r o d o r 1260 at 100 ppm had no effects on reproduction over two generations [228]. At higher dietary levels, reproductive effects Included poor mating performances, fewer litters, reduced litter size, and high postnatal death rates In the litters. In rabbits, A r o d o r s 1221 and 1254 were not fetotoxlc when administered only during gestation In amounts equivalent to dietary levels of about 50-500 ppm [229], However, when administered during gestation at higher levels (600-2,500 ppm dietary equivalent), Aroelor 1254 caused resorptions, abortions, maternal death, and. In two fetuses, aeynnnatric skulls [230], Delaying administration of PCBa until after the first week of pregnancy did not eliminate the effects. Feeding rhesus monkeys Aroelor 1248 at 25 ppm for 2 months resulted In a high degree of Infertility that persisted for at least 8 months after 121 N t the last ingestion^ of PCBs [232]. In another experiment, rhesus monkeys fed Aroclor 1248 at 2.5 and 5 ppm for 6 months had irregular menstrual cyeles with excessive and prolonged bleeding [233]. Even though these monkeys conceived veil on mating resorptions and abortions were frequent, and infertility vas common in subsequent matings [233]. Nursing infants developed ehloracne-like signs vithin 2 months and Infants frequently died during the nursing period. The milk contained PCBs at 0.154-0,397 ppm [234]. There are no reports of infertility or abortions attributed to huaai FCB consumption or exposure. There are reports of undesirable effects in children born to mothers exposed to PCBs in the diet and of undesirable effects developing from nursing such mothers. Babies born from mothers with Yusho were often dark colored a~; developed signs of Yusho after nursing [176,182,183]. In at least one case, Yusho developed In a baby vho vas only exposed to PCBs by nursing [182]. Concentrations of PCBs In milk vers not determined at the time of the Yusho poisoning. A milk sample obtained after birth of a normal baby from a woman exposed to PCBs at work contained PCBs at 0.25 ppm, and nursing vas discontinued [195]. The woman's exposure history and time of last exposure vere not given, but PCBs vers present In her blood at 24 ppb. Based on the findings In monkeys [234] the decision to not nurse the baby seems endrely justified. N 0 3 0 5 3 122 TABLE III-9 EFFECTS OF PCBa ON HUMANS ?CB Intake Source Duration Exposure Index Environmental, Blood Amount/kind (ppb) Effects Ref. Ingestion Up to 8 non 0.3-4 g Kanechlor 400 >50 Yus ho 145185 Occupational Tt it It h it M II 11 Not known 10 ng/cu m - Unbearable irritation 4-8 non 5-7 mg/cu m Aroclor 1254 -- Chloracne, no liver injury 2,5-4 non Not reported Chloracne, hyperpig mentation <1-20 yr 0.2-1.6 mg/cu m Kanechlors 370, ave. Chloracne, hyperpig mentation, liver injury 2,5 yr ave. Not reported Kanechlore 820, ave. Chloracne, no liver injury Not reported >0.25 mg/cu m Not reported 130-520 Chloracne, liver injury 2.5-18 yr 0.013-0.27 mg/cu m Not reported 36-286 Irritation, liver injury 14 aon ave. t 0.1 mg/cu m Not reported - Not reported <1-14 refuse vorkere Chloracne, liver injury No effects 130 186 187 191 194 195 197 190 199 123 .ir * -p ' H 08054 TABLE III-9 (CONTINUED) EFFECTS OF PCBs ON HUMANS FCB Intake Source Duration Exposure Index Environmental , Blood Amount/kind (ppb) Effects Ref. Occupational it it 2-23 yr 1-23 yr Up to 15 yr 0.32-1.44 mg/cu m Aroclor 1242 0.32-1.44 mg/cu m Aroclor 1242 Not reported Kanechlora it Not reported Not reported Kanechlors tt Central environment A years Continuous (>1 mg/cu m) Aroclor 1242 Air, 1-100 Food, 10-20 JJg/d >200 <200 Chloracne, liver injury 196 No effects 196 7-300 \ Chloracne, elevated triglycerides 192, 193 24 10-100 Normal baby Mild chlor acne 195 74-1,900 No effects 198 >1-30 No effects 137141 4 124 N 0 8 0 3 5 TABLE III-10. EFFECTS OF PCB INHALATION ON ANIMALS Expoaure Conditions Material mg/cu a Duration Species Effects Ref, Pydraul A 200 30,000 Solvol 10,000 it 250-500 Decachlorodiphenyl it 2,500 800 it 4 and 80 Aroclor 1262 8.6 If 6.8 h 1.9 Aroclor 1254 5.4 h 1.5 2 hr 3 hr Rats tt 8-69 3-hr exposures 6 hr it it 6 hr/d, 5 d/vk, 4 vk It PCB In liver, 70 ppm 97 1001 mortality, liver necrosis 202 Liver necrosis, hyper 202 plasia of Kupffer cells Irritation, no gross effects 98 Irritation, Increased liver velghts, micro scopic liver changes blood cell changes 99 No Irritation, Increased liver velghts In females 99 7 hr/d, 5 d/vk, 3 vk 7 hr/d, 5 d/vk, 17 vk 7 hr/d, 5 d/vk, 31 vk 7 hr/d, 5 d/vk, 17 vk 7 hr/d, 5 d/vk, 31 vk Mouse, None rat, cat 1 pguisi*nea rabble hh it h it Microscopic liver changes 1* Microscopic liver changes; reversible 203 203 203 203 203 125 AHW134 y O''05'6 I IV, ENVIRONMENTAL DATA AND BIOLOGIC EVALUATION Environmental Concentrations Tvo reporta of workroom air concentrations of PCBs appeared in 1956 [186,190], Pucclnelll [186] studied the concentrations in air of a capacitor factory in Italy, using the methods of Elkins.[130], and found concentrations in 500-liter air samples of 5.2-6.4 mg/cu m. Miegs et al [190] did not report on the analytical methods they used to determine concentrations of FCBs In the breathing zones of workers exposed when a heat exchange unit in a Connecticut factory leaked. From the description I of the factory, it Is likely that the exposures were largely to vapors; the I concentration found was 0,1 mg/cu m. In 1959, Elkins [130] reported that over a number of years, FCBs in some Massachusetts plants ranged up to 10.5 mg/cu m of air (Table IV-1). TABLE IV-1 FCB CONCENTRATIONS MEASURED IN MASSACHUSETTS FACTORIES Process Capacitor Impregnating tv Capacitor soldering Oil mixing Regulator filling Adapted from reference 130 ^000135. -.. ; U 1/ .: - -- PCB Concentrations (mg/cu m) Maximum Average 10.5 5.5 0.3 0.9 1.1 0.2 5.8 4.5 0.2 0.8 0.6 0.1 126 N 08057 I Of 21 air samples,, collected In capacitor Impregnating operations, Elkins considered that hazardous concentrations (>1 ppm for Aroclor 1242; >0.5 ppm for Aroclor 1254) existed in 15, While the sampling and analytical methods used were not documented, Elkins [130] recommended sampling with either a fritted bubbler or two lmplngers In series, both Si containing amyl acetate, and analyzing by the sulfur lamp method. / Occupational environmental studies vere conducted In five Japanese Tv plants by Hasegava et al [191]. Kanechlors 200 (predominantly dichlorobiphenyla), 300 (mostly trichlorobiphenyls), and 400 (mostly tetrachlorobiphenyls) vere used or manufactured In the planti. Air samples vere dravn through filter paper to collect particulate matter and normal hexane to collect vapors and analyzed by GLC, The data are summarized In Table III-7. In the paired samples, the vapor concentrations exceeded the particulate concentrations. One of the plants vas a biphenyl recovery plant vhere PCBa vere not uaed. In this plant, PCB concentrations vere <0.02 mg/cu m. In the PCB manufacturing plant, PCB vapor concentrations vere 0.026-0.163 mg/cu m, and particulate PCB concentrations vere 0.019- 0,037 mg/cu m. Higher PCB concentrations vere found In the capacitor plants: 0,095-0.965 mg/cu m of vapors, and 0.20-0.65 mg/cu m of particulates. In one particulate sample collected In a capacitor plant after a spill, the PCB concentration vas 6.2 mg/cu m. Stalff et al [243] In a 1974 report vere concerned about emissions from burned-out PCB-contalnlng ballasts in fluorescent fixtures In their laboratory. The Investigators collected samplis in two midget lmplngers, containing ethylene glycol and connected In series. The samples vere analyzed by GLC. PCB concentrations In the air ranged from 0.012 to 0.166 127 N 0 S 0 S ' 8 " i`! A ., v mg/cu a when the ballasts burned out and were 0.002 mg/cu a 3 days later. In a 1976 report of a survey of Australian workers exposed to Aroclor 1242, Ouv et al [196] listed breathing zone concentrations ranging from 0.32 to 2.22 mg/cu m before corrective measures were taken, and from 0.08 to 0.75 mg/cu a after Installing Improved ventilation. Breathing zone samples were collected at 30 liters/mlnute using Greenburg-Smith Impingera containing 75 ml of Isopropanol. The concentrations found are shown In Table IV-2. TABLE IV-2 PCB CONCENTRATIONS IN THE AIR INSIDE A CAPACITOR PLANT BEFORE AND AFTER IMPROVEMENT OF EXHAUST VENTILATION SYSTEM Areas in the Impregnation Room PCB Concentrations mg/cu m Before After Area ln the unloading tank In front of exhaust register from operator's breathing zone Area ln the unloading tank not ln front of exhaust register General.atmosphere near tank Solderlnf|atta Adapted Ir a m reference 196 1.44 2.22 1.08 0.32 0.75 0.7 0.18 0.08 Exposures of electrice! and meterais technlclane durlng 1976 to PCBs contalned ln meterais they testad vare evaluated by Levy et al [197]. Air acoples vare collected on magnasium slllcate 'Tlorisil" at 50 ml/mlnute for .>c ;: \' 128 N 08059 n 4-8 hours and analyzed by GLC utilizing electron capture detection. Breaching zone samples were collected on a single day from nine employees for 8 hours. The concentrations in the nine breathing zone samples, which would represent TWA exposure concentrations for the day, ranged from 0.014 to 0.073 mg/cu m. Concentrations of PCBs in nine point source samples collected over 4-8 hours on each of 3 days ranged from 0,013 to 0.264 mg/cu m, and in 19 room air samples collected over 4 hours on each of 3 days, from 0.08 to 0.16 mg/cu m. A plant manufacturing PCBs in ths US was surveyed for worker exposure in July 1976 [244], Three A r o d o r s (1016, 1242, and 1254) were made in the FCB production area. To begin ths process, biphenyl and chlorine vere piped into a chlorinator with a catalyst and allowed to react. Two separate groups of chlorlnators vere used for Aroclors 1242 and 1254. The product resulting from the reaction passed through a purifying operation, or to a distillation column as In ths case of converting Aroclor 1242 to Aroclor 1016, and then on to the storage tanks. Mixing tanks vere used to give the desired properties to the final product. 'v Although the operation was outdoors and theoretically a closed system, potential for employee exposure existed when samples vere drawn or leaks occurred. Local exhaust ventilation was used In two operations: (1) while filling 55-gallon drums, hoses vere placed near the openings, and (2) when employees tested samples dravn from the chlorlnators, their work station was equipped with an exhaust fan and hood. Eleven personal and seven arse air samples vere taken In the FCB production area for 6-8 hours at a flow rate of 200 cc/mlnute [244], PCBs vere collected on Florlsll, desorbed with hexane, and analyzed by GLC with 129 EC detection. Aroclor 1.016 was the PCB produced on the sampling dates, and J it was used as the standard for quantitating airborne PCBa. Personal air sample concentrations of PCBa reported as Aroclor 1016 ranged from 20 to 86. iig/cu m, while PCBa in area samples ranged from 16 to 55 tg/cu m. The data are presented in Table XV-3, TABLE 17-3 PCB CONCENTRATIONS FOUND IN A PLANT MANUFACTURING PCBa ON 2 CONSECUTIVE DAYS Gig/cu m)* Personal Air Samoles Job Title Premium operator Second operator Column operator Still operator Standard operator Distribution operator 7/21/76 47 46 64 40 54 7/22/76 20 43 51 86 61 36 Area Air Semole Location 7/21/76 2/22/76 Drumming 43 5 Temperature tasting 25 52 Chlorlnaeors 55 36 Incinerator burner 16 Total sampling time varied from 49 to 455 minutes and aaople volumes varied fron 67,6 to 201,6 liter Adapted from reference 244 130 N 03061 Sato and Hasegava [32] studied concentrations of PCBa In factories that had discontinued their use in production of pressure-sensitive copying paper 2 years earlier. PCB concentrations In the factories had not been determined when FCBs were being used, but were considered [3] to have been similar to those found by Hasagava et al [196] la capacitor manufacturing plants. The concentrations found by Sato and Rasvgava [32] at the time of sampling ranged from 0,13 to 4.4 pg/cu m. Th FCB concentrations In the outdoor air around the factories were 0,043-0,09 Mg/cu m [3], Another study of contamination In factories after PCB use had been discontinued was reported by Fujiwara et al [33], These investigators found 0,25 mg/cu m In air of a factory that had previously used FCBs In silk glossing. In addition to air contamination, FCBs were found In the dust around machinery and In the floor boards, FCB concentrations found In the air of some other factories and their surrounding environments In Japan vere summarised in 1976 by Tataukava [245], Concentrations found before 1957 In e factory producing transformers and capacitors ranged from 0,39 to 4,5 mg/cu m* The factory was said to have been old-fashioned with bad ventilation [245 ]. Concentrations found In varehouses for carbonless copying paper in 1972 ranged from 2 to 70 gg/eu a. In the same year, concentrations of 0.04-0.05 Mg/cu a vere found In a university laboratory where FCBs vere used, and concentrations of 0,006-0,12 Mg/cu m vers found in areas of mills that recycled paper. Background concentrations found in urban areas of Tokyo, Osaka, and Matsuyama City vere <0,002-0.04 Mg/cu a. Background concentrations of FCBs in ambient air over the US have been reported in ng/eu m quantities [26,38], Average concentrations of 131 'IptUMv.- about 100 ng/cu o were found In Florid and Colorado In 1975 [38]. Control of Exposure The present primary use of FCBe la as dielectric or Insulating fluids for electrical capacitors and transformers* Potential hazards of PCBs in these Industries result from Inhalation and dermal exposures. It Is here that engineering controls, such as local exhaust systems, are necessary, Local exhaust systems should be designed and operated In conformance with American National Standard Z9.2-1971 Fundamentals Governing the Design and Operation of Local Exhaust Systems [246]. Guidelines for handling capacitor and transformer askarels Include the following recommendations from the American National Standards Institute (ANSI) [A]: (1) Enclosed systems of sealed piping, properly gasketed joints, valves, containers, and processing chambers should be used for any portion of the operation where askarel temperatures may exceed 55 C; (2) Enclosure should preferably extend to all other portions of the system Insofar as practicable; (3) Operations utilizing PCBs should be isolated from other manufacturing areas to avoid cross contamination; (A) Provision should be made for adequate ventilation and regulation of manufacturing operations to avoid open exposure to askarels; (5) When askarels are used at elevated temperatures (especially 33 C or higher), engineering controls oust be applied, either by the us* of closed systems or by effective local exhaust ventilation with general workroom exhaust* Durfee et el [247] cited the following potential sources of air emissions of PCBs In transformer and capacitor manufacturing operations: (1) vapor exhaust from scream jet ejectors; (2) evaporation from accidental Aonni4l 132 -M 08063 aptlls (3), evaporation from hot surfaces as part of flood-filling, inspection, w or holding operations; (A) vacuum pump exhausts; (5) evaporation from plant waste water. There are currently no commercially available fluids which can be considered as totally acceptable substitutes for FCBs in the broad range of AC capacitors, nor are there substitute dielectric systems which would satisfy reliability and safety requirements in most applications [28]. Transformers containing FCBs represent only about 5 Z of the US transformer market, and are used only where safety and reliability are of prime importance. For new installations, building and installation design provisions could be made to accommodate the use of filled, open dry-type, or sealed dry-type transformers. Major construction changes would be required to compensate for the fire resistance of askarel-fllled units if existing askarel-fllled transformers are to be replaced with oil-filled units of equivalent electrical ratings [A], Environmental Sampling and Analytical Methods (a) Air Sampling Before discussing the various methods available for sampling airborne PCSe, it is pertinent to discuss the criteria for an Ideal sampling device. NIOSR evaluated an Industrial worker's exposure and found that sampling in the breathing ions gives a truer picture of actual exposure than does area sampling. The first criterion for an Ideal air sampling device then Is that it be amenable to personal sampling. In addition it should be light, compact, and small enough so that workers can pursue their, dally activities without being aware of Its presence. The second criterion is that the 133 sampling device have a" sufficient capacity for PCBa to enable the collection of an air sample representative of a typical workday. Thirdly, recovery of PCBs from the sampling device should be quantitative or, at the least, reproducible. Finally, the sample must be stable in or on the sampling device between the time of sampling and the time of analysis. This latter criterion is hardly of concern here due to the general stability of PCBs. An air sampling procedure using fritted bubblers or implngers filled with toluene was published by ANSI in 1974 [4]. Neither the sampler capacity nor the sampling efficiency had been experimentally evaluated. Where high sampling flow rates or high capacities were required, additional bubblers or Implngers in series were recommended. Bldleman and Olney [248] used porous polyurethane foam for collecting samples of atmospheric PCBs. They found that the polyurethane foam shoved excellent collection efficiency (99Z or better) for tri-, tetra-, and pentachloroblphenyls. The authors [248] did not address the matter of sample recovery from the sorbent. In an environment where carbonless copy paper was being used, Nlahiyama et al [249] collected PCBs by drawing the air through a cooled column filled with Shiaalitt, a gas chromatographic solid support similar to Chromoeorb V. The collection efficiency of the device was 95Z and the PCBs were elated from the column with hexane. Other investigators used 5Z glycerol-coated Florisil for collecting organochlorine pesticides and PCBs from air [250]. Collection efficiencies were 90-100Z for PCBs. Harvey and Steinhauer [251] collected ambient air samples of PCBs using 0.25Z OV-17 silicone oil coated on ceramic saddles (distillation 134 N 08065 column packing), The collection efficiency of thie device vaa 70Z. More recently, Glam et al [252] found that sorbent tubes packed vith deactivated Florlsll could be used for collecting FCBs and phthalates from air[252], These compounds were found to be effectively retained by Florlsll. The authors did not discuss efficiency of recovery* In 1976, Laveskog and Llndskog [253] described a stack sampling device for chlorinated hydrocarbons which they used for FCB collection. This device utilized glass wool for the collection of particulates followed by a sorbent, 25-40Z Aplezon M on Chromosorb W, to collect vapors. The collection efficiency of the column was 99%, and desorptionefficiency vith absolute ethanol was 87Z. The authors investigated charcoal as a sorbent, but found it unsuitable for their purposes since the PCBe could only be recovered by extraction in a soxhlet apparatus with chloroform which in .turn could not be used with electron capture detection. Occupational Safety and Health Administration (OSHA) workers have used charcoal tubes for personal air sampling for FCBs (RG Kupel, written communication, 1976). Vhlle the sampling device would be expected to have good capacity for PCBs, recovery from charcoal is not quantitative*. vLlttie other information Is known about this method. A NTOSH Standards Completion Program Report [254] indicated that FCBs with 54%.chlorine content were effectively trapped on a fibrous glass filter. However, the presence of PCB vapor either apparently was not addressed or was assumed to be negligible* This may not be a valid assumption, particularly since another report from the same program [255] shoved that PCBs with 42% chlorine content have appreciable vapor pressure. Annoi44 135 NIOSH has also investigated the method of Glam et al [252], using Florisil as a sampling medium, In industrial environments. Florlsll (30/48 mesh) was placed in a tube similar to that used In the charcoal tube method for solvents, 100 mg in the front section and 50 mg in the back. The retention capacity of this sampling device for PCBa was evaluated under laboratory and field conditions, using various vapor genera'tlon techniques. In laboratory experiments, FCBs at 10 jjg/llter and 75Z relative humidity were sampled through a 100-mg Florlsll bed at 0.2 liter/minute vith no evidence of breakthrough after 4 hours (48 liters). Of 21 samples collected on Florlsll In a capacitor plant, only 6 had FCBs on the backup section and all 6 backup sections contained 1Z or less of the total FCBs In the tube. The volumes of air sampled ranged up to 61 liters, and FCB concentrations In air as high as 1.5 jig/llter vara measured. Other laboratory experiments shoved that PCBs could be desorbed quantitatively from Florlsll with hexane. Results from Florlsll tube and lmplnger samples taken side by side In the capacitor plant and analyzed vith a single commercial PCB product as a standard vara statistically similar Implngers are not suitable for personal sampling and are Inconvenient to use because they must be recharged vith the sampling solvent frequently and must be used in series The handling of absorber solutions Is difficult.because of the potential for spillage and leakage of the solvent and sample*, during transport to and from the sampling site. Solid sorbent sampling devices are veil suited for personal sampling since they are relatively small, and personnel veering the devices quickly become unavare of their presence, enabling more representative sampling. Shipment of these devices Is relatively simple. A0H0145 136 K 08067 Of the . solid sorbent sampling devices discussed, Florisil-ftiled' Cubes are deemed che most advantageous because Florlsll has a high capacity for FCBs and can be quantitatively desorbed; field evaluations have ahovn that Florisil-filled tubes are easier to handle and more convenient than impingers. Therefore, the Florlsll-fllled tube method la recommended for collection of PCBs from air, as detailed In Appendix I* (b) Analytical The cheniatry of PCBs was extensively reviewed by Hutzlnger et al [1] , and FCB analytical chemistry has been reviewed by several authors [256-264] but only references pertinent to selection of an analytical method for determination of PCBs In Industrial air samples will be discussed here. Of the analytical techniques available, the one most widely used for determining PCBs Is GLC with EC detection. This technique is rapid, precise, and very sensitive. The far greater sensitivity of EC detection compared with that of the flame Ionization detector (FID) la demonstrated by comparison of their relative responses to various PCB Isomers, shown In Table IV-4 [1], 40001^6 - * ii*.*-' * 08068 ' TABLE IV-A RELATIVE MOLAR RESPONSES OF ELECTRON-CAPTURE AND FLAME-IONIZATION DETECTORS TO SOKE PCS Relative Molar Resoons PCB Electron Capture Flame Ionization 2-chloro 3-chloro 4-chloro 2,2*-dichloro 2,4-dichloro 2,6-dichloro 3,3*-dichloro 3,4-dichloro 4 ,4'-dichloro 2,4,4'-trichloro 2,2'4,41- tetrachloro 2,2'6,61- tetrachloro 3 , 3 14 , 4 1- tetrachloro 3,35,5 *-tetrachloro 2,3,4,5-tetrachloro 2,3,5,6-tetrachloro 2 , 2 ,4,4'6,6'-hexachloro 3,3'4,4'5,51-hexachloro 2 , 2 13,415,5'6,61-octachloro 2,2'3,3,5,5*6,6>-octachloro decachloro Adaptad from reference 1 1.00 0.20 1.10 5.16 17.7 32.0 6.10 15.2 5.97 135 106 20.6 396 320 367 259 347 726 1,180 1,150 1,410 1.00 0.92 0.87 0.99 0.86 0.91 0.94 0.86 0.81 0.78 0.87 0.90 0,87 0.85 0.87 0.71 During the GLC-EC dettetion analysis of PCBs, multicomponent mixtures of various PCS# art almost always encountered. The eeaplee analyzed may or may sot resemble a ccsetercial PCB mixture. If so, the appropriate PCBccanareial mixture cau be used aa a standard for quantitation; if, not, a commercial mixture should not be used. Quantitation"cannot be accurate since it la based on Incomplete resolution of PCB isomers Even if complete resolution vera possible, all PCB isomers are not available for standards and the specific EC detection response of each Isomer would need t i *. t n o !U AWVYTO ' us N 03069 to be knovn. Many different methods have been used to "quantitate'' or estimate PCBs. Heights or areas of one [263], two [264], three [265], or' more [266,267], or of all chromatographic peaks [268-270] of a given sample have been used for comparison with standard commercial PCB mixtures. The chief disadvantage of such methods is that when the chromatogram of the sample does not closely resemble that of the standard the estimates are neither precise nor accurate* An Improvement upon these methods is the use of mixed PCB standards, as described by Beezhold and Stout [271]. This procedure Involves mixing various proportions of different PCB commercial mixtures, such as A r o d o r 1242 and Aroclor 1254, and obtaining sets of chromatograms. The chromatogram most closely resembling the sample is selected and the corresponding mixture is used as the standard. Savyer [269], in a collaborative study, evaluated the quantitation of PCBs in chicken fat. He found that the use of the total peak area or the sum total of all peak heights gave better results than did the use of selected peaks. The use of mixed standards gave good results vhen the composition which beet duplicated the response pattern of the sample was used. This was adopted as an official method by the Association of Official Analytical Chemists [272]. Using a different approach to standardisation, Rote and Murphy [273] produced a standard responaa curve using A r o d o r s 1232, 1242, 1248, 1254, 1260, and 1262. This plot was of the total area responses on the GLC trace divided by the weights of the A r o d o r s injected versus the average number of chlorine atoms in the molecule. The peaks in each chromatogram were identified as to chlorine content per chloroblphenyl molecule, and 139 *000148 =; ` . N 00070" '' each sample could Chen be quantitated using the response curve. The accuracy of this method is not greater than that of the methods previously mentioned, since it has been shown chat the response of EC detection varies greatly with the degree of chlorine substitution and also with the relative position of the chlorine substitution [11* Riaebrough et al [274] and Collins et al [268] used, dichlorodiphenyl- dlchloroethylane (p,pf-DDE) as a standard and assumed that the response of each chloroblphenyl Isomer was equal to that of p , p f-DDE, This method can only be grossly approximate, since the response of EC detection to individual FCB isomers varies greatly [1]. Rlsebrough et al [274] also reported the use of microcoulometric detection to determine total chlorine content, using a commercial PCS mixture as a standard* Sawyer [269] compared the EC detection with the mlcrocoulmatrlc and electrolytic conductivity detectors and found that the latter two deteetors are subject to more operational problems than is the EC detection* An analytical method utilizing a computer for the quantitation of PCBs wee described by Zobel [275]. This method would not be of value for routine sample analysis in industrial hygiene laboratories because of the expense or unavailability of a computer* The m ethod of Webb and McCall [276] Involves standardization of an A r o d o r m l N m hose peak-by-peak composition has been determined as weight percentages of the total. Since the response-to^relght factor la known for eaeh peak, the actual weight equivalent of each peak in the sample can be calculated despite vast differences of overall GLC patterns. To utilize this method as a standard procedure, it is necessary that some h f f!-ii\ I V 08071A000149 140 agency serve as a central repository for distribution of the reference materials. Presently, standards for Aroclora 1242, 1254, and 1260 as dilute solutions in iso-octane are available from Webb and McCall [276]. However, a fully characterized standard for the widely used Aroclor 1016 is not available. Potential future sources for these types of standards may be either the Association of Official Analytical Chemists or the US Food and Drug Administration. These organizations currently are Interested in this method [277] and are planning to test it collaboratively. The US Environmental Protection Agency has adopted the method of Webb and McCall [276] as a recommended procedure for quantitation of PCBs in industrial effluents [278]. Other Investigators have also concluded that this method is the best available method of quantitation [279]. Berg et al [280] investigated the quantitation of PCBs In terms of derivatives. PCBs could be quantitatively converted by catalytic dechlorination to bicyclohexyl. However the authors [280] found that the relatively low level of sensitivity, because blcyclohexyl had to be determined by GLC with FID, was a marked disadvantage. They [280] found that treatment of PCBs with anltmony pentachloride under elevated temperatures and anhydrous conditions gave good yields (85Z) of decachloroblphenyl which could be determined by GLC with EC detection. Armour [281] evaluated the perehlorlnatlon procedure of Berg et al [280] to determine its utility as a routine method for the confirmatory quantitation of PCBs. It was found necessary to modify that procedure because of observed inconsistencies in the efficiency of conversion of Aroclors 1254 (90-100Z) and 1242 (30-70Z) to decaehloroblphenyl. Armour [281] attributed this to volatilization of the lower molecular weight PCS 141 / i components during solvent evaporation, before their reaction vlth antimony jpentachlorlde. The remedy selected was to end evaporation while a small amount (0.1 ml) of solvent still remained, but this rendered the choice of solvents a more critical matter because of possible Interferences during the perchlorination step. Chloroform vas the solvent chosen because It minimized volatility and reacted favorably at the selected conditions. The increased pressure produced as a result of this substitution of chloroform required discontinuing use of flame-sealed Carlus tubes as recommended by Berg et al [280] for containing the elevated temperature-pressure perchlorination reaction. The recommended substitute vas a vacuum hydrolysis tube having the same volume specifications (10 mm O.D. X 150 mm), a tight Teflon sealing valve, and a side venting arm [281]. Other modifications devised by Armour [281] included the addition of methanol to tha reaction mixture's sxtrsct to produce an azeotrope with the residual chloroform which could then be evsporsted to e small volume before dilution, preparatory to determination of decachloroblphanyl. To determine the feasibility of e shortened reaction time, Armour et al tested iron es a catalyst, but decided that although a reaction time of 6 hours with iron catslyst rtsulted in quantitative (99Z average conversion for six Aroclors) and producible (83-110Z) conversions, the catalytic modification offered little advantage ever the overnight procedure. Perthlerlnetion has been used for the qusntitetion of PCBs by oehers [282,283]. Vhlle the sole perchlorination produet wee usually decachloroblphanyl, there have been reports of undesired byproducts resulting from contamination of the antimony pentachlorlde with bromide ions [284,285]. Results of NIOSH investigations indicate ehae this A00M51 142 N 03073 At- w: X 1 I I i contamination problem can be eliminated by vacuum distillation of the antimony pentachlbride. Factors for converting decachlorobiphenyl to A r o d o r a are presented in Table IV-5. TABLE IV-5 FACTORS TO CONVERT DECACHLOROBIPHENYL TO AN EQUIVALENT AMOUNT OF AROCLOR Aroclor Average Molecular Weight Q* 1221 188.5 0.38 1232 223 0.45 1242 257.5 0.52 1016 257.5 0.52 1248 292 0.59 1254 326.4 0.65 1260 361 0.72 1262 395.3 0.79 ^Calculated by dividing the average molecular weight by 499, the molecular weight of decachlorobiphenyl Adapted from reference 281 From a review of the literature, NIOSH conclude that the simplest method of PCB quantitation Involves standardization of samples with single comnarclal mixtures of PCBa. Should the composition of a sample not closely resemble that of a single commercial PCB mixture, the most accurate and precise method of quantitation available would be that of Afl0fl1S2 143 N 0 8 0 f % ^ vk perchlorination, w h i c h v seems to offer the best approach for determining total PCB content In samples when the initial concentrations of individual PCBs are of little or no concern* NIOSH recommends desorption of PCBs from Floriail with hexane, analysis by GLC, and quantitation of the sample by comparison with a standard PCB mixture of similar composition (Appendix II). If a PCB mixture with a composition similar to that of the sample la not available as a standard, NIOSH recommends converting the sample PCBs to decachlorobiphenyl for quantitation The methodology presented in Appendices I and II has been tested with Aroclor 1016 In the laboratory and In practice. Operating parameters found by NIOSH are presented In the Appendices. Biologic Evaluation While there la presently no adequate method for biologically monitoring Industrial workers for exposure to PCBs, additional research may make feasible the routine measurement of residues of these compounds In blood or other body fluids. K Q807b 144 V. WORK PRACTICES The employment of 'good work practices la required If hazardous occupational exposures to PCBs are to he prevented. The carcinogenic, teratogenic, dermatologic, and fetotoxic effects of PCBs largely determine the nature of necessary work practices. (a) All locations where occupational exposure to PCBs occurs should be established as regulated areas and posted with signs warning persons of the procedures necessary upon entering or leaving. When an otherwise closed PCB system Is opened, eg, during -the loading and unloading of storage tanks, the following work practices are desirable: (1) Only authorized personnel should be permitted In the area; (2) Adequate ventilation should be provided and the exhaust air should not be discharged Into any environment until It has been adequately decontaminated; (3) To prevent skin contact with PCBs, workers should be required to wear and use PCB-reaistant protective clothing and equipment, Including respirators. (4) Upon leaving regulated areas, workers should be required to remove such protective clothing and equipment and place It In impervious containers pending either decontamination or disposal; (5) Altar removing such protective clothing and equipment, workers should be required to wash their hands, forearms, and faces, and to shower after the laet exposure of the day. 145 . f f\ \ Whenever a worker must come into direct contact with PCBs, eg, during cleanup of spills or maintenance of vessels, PCB-reslstant protective clothing and an appropriate respirator must be worn. (b) Leakage and Spill Procedures PCB spills are to be cleaned up promptly, either by the use of sorbent materials, such as sawdust, or by trapping and* removal through pumping or other suitable means. In case of at * of PCBs on clothing, the contaminated clothing should be removed as sc 'actlcal, the skin should be thoroughly washed, and the clothing d be laundered or disposed of properly. Facilities and procedures for suc.i cleanup must be provided at manufacturing facilities producing capacitors and transformers, because spills of PCBs are quite likely to occur during the filling and handling of such devices. Users of PCB-fillsd transformers should Inspect them periodically for leakage. If leakage is found, the cause should be corrected and the spillage should be soaked up with sawdust or other absorbent material, Tha laak area should be cleaned finally with rags soaked with an appropriate safe solvent * Leaky transformer gaskets can bs staled temporarily by painting over the leaky area with epoxy cement. Refer to Transformer Aakarel Inspection and Maintenance Guide [25], and Guidelines for Handling end Disposal of Capacitor end Traneformer Grade Askartls Containing Polychlorinated Biphenyls [4] for further maintenance procedures. (c) Emergencies In emergencies, i n e d l a t s measures must be taken to eliminate hazardous conditions. Non-essential workers must be 'scuated until tha emergency no longer exists. Any worker haying visible contamination of the 146 V 08077 akin with FCBs mut showerkimmediately unless other action la warranted. (d) Respiratory Protection To ensure against Inadvertent exposure to PCBs, workers1 respirators oust be properly selected, fitted, and maintained. A guide to Industrial respiratory protection [286] has been developed which contains sufficient information to enable the establishment and maintenance of a respirator program that meets the requirements outlined in 29 CFR 1910.134. The guide [286] includes Information on respirator selection, use, maintenance, and Inspection, as well as a complete description of various types of respirators and their advantages and limitations, respirator fitting procedures, wearer training instructions, and physiologic and psychologic constraints on respirator use. Several NIOSH studies [287-289] have shown that respiratory protection may be Inadequate In many occupational situations, eg, abrasive blasting, coal mining, and paint spraying. For this reason, respirators are generally regarded by NIOSH as a type of control to be used only where engineering controls cannot be used, made adequate, or provided. 147 H ' VI. DEVELOPMENT OF STANDARD Baaia for Previous Standards In 1942, the Subcommittee on Threshold Limits of the National Conference of Governmental Industrial Hygienists compiled a list of maximum permissible concentrations of atmospheric contaminants recommended by various state Industrial hygiene units [290]. The eight states that made recommendations for FCBs (chlorodiphenyls) were unanimous In recommending 1 mg/cu m. No basis for the recommendations was given. Cook [291], In his 1945 listing of Maximum Allowable Concentrations of Industrial Atmospheric Contaminants, cited PCB standards for California and Utah of 1 mg/cu m and Oregon of 0.3 mg/cu m. He [291] also cited unofficial guidelines for Massachusetts of 5 mg/cu m and for New York of 1 mg/cu m and he recosnended 1 mg/cu m, based on the report of Drinker [132]. The American Conference of Governmental Industrial Hygienists (ACGIH) began listing PCBs (chloro di phenyl) with "toxic dusts, fumes and mists" In Its recommendations of maximum allowable concentrations of air contaminants for 1946 [292]. It compiled its 1946 list from Its 1942 list [290] and from Cook's [291] list, and continued to recommend 1 mg/cu m for PCBs. The ACGIH continued to recommend 1 mg/cu m for PCBs (chlorodlphenyl) until 1951 when It specified 1 mg/cu m as the limit for PCBs with 422s chlorine and proposed a limit of 0.5 mg/cu m for PCBs with 542 chlorine [293]. Each recommendation was clearly defined as a threshold limit value (TLV) for an 8-hour TWA concentration to which It was "felt" workers could be repeatedly exposed without adverse effect on their health.I I or*/** ^ 148 N 08079 Ia 1961, the ACGIH 'added the notation "skin" to the TLV of those substances, Including PCBs, which in liquid form can penetrate the skin to cause systemic effects [294,295]. In 1962, the ACGIH published documentation of its TLV recommendations [296]. Baaed on information in the reports of Schwartz [123], Drinker et al [125], Meigs et al [190], and Trton et al [203], the ACGIH [296] concluded that for PCBs chlorinated to 422, 1 mg/cu m would seem to offer reasonably good protection against severe systemle toxicity but may not guarantee complete freedom from chloracne. They also cited the information [207] that PCBs could be absorbed through the skin, causing fatty degeneration of the liver. In documenting its recommendation for PCBs containing 54Z chlorine, the ACGIH [296] cited Drinker et al [125], Drinker [132], and Treon et al [203], and on the basis of these reports it [296] considered that 0.5 mg/cu m appeared to be reasonable for repeated occupational exposures. The American Industrial Hygiene Association's Hygienic Guide "Chlorodlphenyls (containing 42Z and 54Z chlorine)" [297], published In 1965, adopted the ACGIH recommendations for time-weighted average exposures and suggested a short-exposure tolerance for PCBa of 10 mg/cu m to prevent unbearable Irritation, based on the report of Elkins [130]. The Hygienic Guide [297] provided Information that minimum lethal doses applied to the skin of rabbits for 24 hours were 1 g/kg for PCBs containing 42Z and 1.5 g/kg for PCBa containing 56Z chlorine. It also recommended avoiding prolonged or repeated skin contact, and It recoounded laundering of contaminated clothing before reuse, protecting the eyes from liquid splashes, treatment of the ayes If PCBa were splashed into them, and i i-* 149 periodic examinations to detect early evidence of skin irritation or liver damage. In 1970, the International Labour Office published permissible levels of toxic substances for several nations [298]. The PCB standards for six nations art given in Table VI-1. TABLE VI-1 PERMISSIBLE LEVELS OF FCBs FOR SIX NATIONS Country Standard (mg/cu a) Type of Standard Czechoslovakia 422 Chlorine 542 Chlorine Finland 422 Chlorine 542 Chlorine Poland Romania 422 Chlorine 542 Chlorine USSR Yugoslavia 422 Chlorine 542 Chlorine Adapted from reference 298 1.0 0*5 1.0 0.5 0.1 1.0 0.5 1.0 0.5 0.5 MAC it MAC 8-hour h MAC it it it t h la 1973, Viaall [299] compiled a lit of international occupational hyglsnla ataodards for chemicals, including "chlorodiphenyl." She listed values for Sweden of 0.5 ag/cu a and for the German Democratic Republic of 1.0 mg/cu a. In both countries the standards vers the same for PCBs containing 421 and 542 chlorine* The standards listed for the Federal Republic of Germany vers 1.0 mg/cu m for PCBs containing 422 chlorine end \00<VV59 ISO N 08031 0,5 mg/cu m for those with 542 chlorine, respectively. The TLV documentations for FCBs published by the ACGIH In 1976 [300] did not differ significantly from the original documentations [296]. However, the ACGIH [300] recalled, citing von Wedel et al [205], that several deaths due to liver atrophy occurred among workers exposed to fumes of chloroblphenyls and chloronaphthalenes, but pointed out that relatively few, If any reports had appeared of sytemic poisoning of workers exposed only to fumes of PCBs. The ACGIH has retained a TWA of 1 mg/cu m as the TLV for PCBs with 422 chlorine content and a TWA of 0,5 mg/cu m as the TLV for those with 542 chlorine content (through 1976) [301], However, a tentative short-term exposure limit (TLV-STEL) was added to the recommendations In 1976, STEL Is defined by ACGIH [299] as the maximum concentration to which workers can be exposed for up to 15 minutes continuously without suffering from Irritation, chronic or Irreversible tissue change, or narcosis of sufficient degree to Increase accident proneness, Impair self-rescue, or materially reduce work efficiency. According to the ACGIH [301], the STEL Is to be considered a mjT'fTTmrn allowable concentration, or absolute ceiling not to be exceeded at any time during the 15-minute excursion period; such excursions are not to occur more than 4 times a day and there must be at least 60 mliwtee between them. The STEL recommended for FCBs was 1 mg/cu m regardless of.the degree of chlorination. This reconaandatlon was made on the basis that the TLV documentation for PCBs [300] suggested that the values should be callings never to be exceeded, rather than TWA values for 8 hours of exposure [301], i5i A0P0160 * i* ` The 1968 ACG1K recommendations [302], adopted as the federal standards for PCBs (29 CPR 1910.1000, Table G-l) are TWA 8-hour exposure concentrations of 1,0 mg/cu m for mixtures containing 422 chlorine and 0,5 mg/cu m for mixtures containing 542 chlorine Basis for the Recommended Standard (a) Permissible Environmental Limit The major effects that have been found in workers exposed to PCBs are chloracne [186-191,195,1961, liver injury [190-193,196], and Irritation of skin and mucous membranes [192,196,197]* Exposures at peak PCB concentrations of 5-10 mg/cu m have been reported as "unbearably" irritating [130], Chloracne has been reported after occupational exposure to Aroclors 1242 [196] end 1254 [186], and to various Kanechlors [191,192,194,195], as well as after ingestion of Kanechlor 400 [146,153], Chloracne has frequently been associated with processes where the PCBs were heated [186189,196], The methodology In most of the exposure studies did not differentiate between vapor and particulate forma of the PCBs [186,190,196], In one study of Kanechlors in capacitor manufacturing plants where chloracne was coomon, vapor (or small particulate) concentrations (0,095-0,95 mg/cu m) exceeded particulate concentrations (0,02-0.65 mg/cu ) [191], In anothsr capacitor plant where heated Aroclor 1254 was used, exposure concentrations were 5-7 mg/cu m, but the vapor components were not aeperataly determined [186], In this plant, chloracne developed am. vorkars after 4-8 months of exposure, A study of workers, in a plant wher. he work situation lndlcatsd the exposures were to PCB 152 vapors, showed that chloraene developed after a minimum of 5 months and an average of 14 months of exposure [190]. In this study, exposure concentrations of an undefined FCB were reported as 0.1 mg/cu m. In other studies where PCB concentrations were not measured, chloraene developed after 3-8 months of exposure [187,139]. These data show that chloraene can develop after prolonged exposures to FCBs in concentrations as low as 0.1 mg/cu a, and that as the FCB exposure concentrations increase, the duration of exposure required for the development of chloraene decreases. The data also Indicate that FCBs In the vapor phase may contribute substantially to development of chloraene. However, they do not prove that only FCB vapors cause chloraene. Particulate PCBs have been shown to be absorbed from Inhaled air by experimental animals [97], and Ingested PCBs have caused chloraene [146,153]. Occupational exposure to a variety pf FCB mixtures (Aroclors 1242, and 1254,' various Kanechlors, and others) has caused chloraene, and no commercial PCB mixture has been shown to have more or less ;V chloracnegenlc properties than others. There are some studies of FCB workers In which chloraene was not found [197-199]. In one of these studies, the Aroclor 1242 concentrations were Imprecisely reported [198] and in the others the PCB.,mlxtures were undefined 1199] The report by Levy et al [197] gave possible PCB exposure concentrating of 0.013-0,264 mg/cu m and breathing zone concentrations of 0.014-0.073 mg/cu a. Thus the data indicate that chloraene may be prevented by keeping PCB exposures below 0.1 mg/cu m (100 *ig/cu m). In some of the studies where chloraene developed, signs of liver Injury were not found [186,194,195], but in the majority of studies where N 08084. chloracne was found", there were aleo indications of liver injury [190- 193,196].' Evidence of impaired liver function was found by other investigators [197] in a study where workers had not developed chloracne. Meigs et al [190] found evidence of alight liver injury in workers exposed to PCBa at 0.1 mg/cu m, and Levy et al [197] found historical evidence of liver Injury in the medical records of workers in the. plant where they found exposures ware <0.25 mg/cu m. Among the findings in these medical records were elevated serum triglycerides [197]. Abnormal serum triglycerides have been found in exposed workers by others [191-193], and in the Japanese people who accidentally consumed PCBa [155,157,158,175,179- 181]. The effect on serum triglycerides in workers was related to duration of exposure [193] and, in the workers and la the Yueho patients, to residual PCBa in the blood [175,180,193], In the Japanese workers who were removed from exposure, the effect remained for at least 2 years [193], Other indications of liver injury in exposed workers Included occasional findings of elevated serum enzyme activities, and abnormalities in various other liver function tests [190,191,196,197]. A level of exposure at which liver Injury will not occur la not indicated by the occupational exposure studies, since evidence of liver Injury has been found in the occupational studies with the lowest PCB concentrations. It is not possible to determine whether liver Injury occurred with exposures at the lamer levels of all the occupational exposure ranges reported, but to protect workers from any liver injury it seems that exposures should be maintained below 0,01 mg/cu m (10 jtg/eu m). Animal experiments do not demonstrate a safa exposure level either. Although Treon et al [203] found no evidence of liver Injury in 154 N 08035 J 1\ v' A t r experimental animals (rabbits, guinea pigs, cats, rats, and mice) exposed to A r o d o r 1242 at concentrations of 1.9-8,6 mg/cu a for up to 31 weeks, Ouv et al [196] found evidence of liver Injury in workers exposed to Aroclor 1242 at 0.32-1.44 mg/cu m. In their experiments with A r o d o r 1254, Treon et al [203] found microscopic evidence of liver Injury in animals exposed at 1.5 mg/cu for 31 weeks. Linder et al [228] found Increased liver weights In rats fed Aroclor 1254 at 1 ppa for two generations. The Intake of PCBs at this dietary level can be compared to the Intake from inhalation exposure at about 0.1-0.2 mg/cu a; thus, the animal experiments appear to confirm Indications of liver Injury in workers exposed to FCBs in this range. The combined studies of Levy et al [197], Melge et al [190], Hasegawa et al [191], and Ouv et al [196], and the animal studies [203,228], provide further support to the conclusion that PCB exposures must be maintained at lover levels to prevent liver Injury than to prevent chloracne. Since Indications of liver injury can be found In reports of both occupational studies [190,191,196] and animal experiments [203,228] with the lowest FOB exposure, there is no proof of an exposure level that is adequately low to prevent liver injury The prevention of liver injury is of particular concern because there is substantial evidence that arene oxides are formed during the metabolism of PCBs by animals [51,68,69,74,75,81,115,116,118], and the data offer no reason to suspect that humans metabolite PCBs differently from animals. PCB metabolites have been dnonstrated to bind to nuelear components of hepatic cells of rhesus monkeys [51] and rats [81] and this la sufficient evidence to arouse suspicions that PCBs could be potential carcinogens in fv 98086 Che workplace. Commercial FCB preparations chat have been adequately tested In rats [213,242] (Federal Register 42:6532-55, February 2, 1977) and mice [221,240,241] have been demonstrated to cause liver tumors. No liver tumors were found In rats fed Aroclors 1242, 1254, and 1260 at 1 ppm In the diet, but each of these mixtures produced tumors at 10 ppm (Federal Register 42;6532-55. February 2, 1977). In this same experiment a high Incidence of pituitary tumors was found in PCB-fed rats. In Tusho patients [160,161], and in American workers (written communications, HA Slnclalre, June 1976; G Rouach, September 1976), preliminary studies only indicate that the occurrence of certain cancers may be excessive. However, the findings In rats and mice demonstrate reproducible production of liver tumors after ingestion of various FCB mixtures, and NIOSH concludes that PCBs in workplace air are potential carcinogens. Additional concerns for the health of workers and their families are adverse reproductive effects [228,230,232,233], Including terete in animals fed various FCSs (FL Earl at al, written communication, 1976), and adverse effects in human and animal Infants nursed by PCB-exposed mothers [101,182,233].' PCBs resembling those in maternal blood both qualitatively and quantitatively have been found In human cord blood and in tissues of newborn humans and animals [101,138,139,166]. Fetal resorptions were common, sod dose related Incidences of terete were found in pups and piglets fan bitches and sows were fed A r o d o r 1254 at 1 mg/kg/day or more. Terete were not found In babies of Tusho patients (maximum consumption of PCBs of about 0.15 mg/kg/day); however, many undesirable effects including low birth weights and chloracne-like lesions at birth and after nursing were found [176,182,183]. 65 156 n 08087 Baaed on the findings of adverse reproductive effects, on its conclusion that PCBa are potential carcinogens in huaans and on its conclusion that occupational and animal studies have not demonstrated a level of exposure that will not subject the worker to possible liver injury, NIOSH recommends that the TWA concentrations of PCBs in the breathing zone of vorkera be maintained at or below- the minimally detectable TWA concentration for up to a 10-hour workday, 40-hour workweek. NIOSH considers the minimally detectable concentration of PCBs for the monitoring of occupational exposures to be 1 ^g/cu m, based on its review of the literature and the methodology presented In Appendices Z and II. Maintenance of exposures to PCBs at or below this concentration should reduce riake of reproductive and carcinogenic effects, and protect the employees from metabolic dysfunction, hepatic injury, and dermal effects due to FCB exposures during their working lifetimes. It la recognized that employees handling PCBa may have skin contact with these substances, potentially resulting in dermatologic and systemic effects. Consequently, appropriate work practices, training programs, and other measures should be required, regardless of the concentrations of airborne PCBs. Therefore, occupational exposure to PCBs has been defined as working with PCBa or with equipment containing PCBs that can become airborne or. that can spill or splash on the skin or into the eyes, or the handling o f ^ u y solid products that may result in exposure to PCBs by skin contact or by Inhalation. (b) Sampling and Analysis Based on an evaluation of the literature and on'its own studies, NIOSH recommends sampling and analysis for PCBs as detailed In Appendices I 157 Anflftl66 and II. Florisil ha bean elected as the eolid sorbent for PCBs because it will collect vapors as veil aa particulates and PCBs can be quantitatively recovered from it. The recommended Florisil sampling tubes have been shown to have an adequate sorption capacity (at least 100 jig) for monitoring occupational exposures at the recommended limit for up to a 10hour workday. NIOSH has used the sampling method for . monitoring TWA occupational exposures at 10-250 jig/cu m [197,244] by sampling at about 200 ml/mlnute for the entire workday* Total sample vo; tats of up to 100 liters were collected. At 1 pg/cu m, 100 liters of air ould contain 100 ng of PCBs. The lover limit of PCB detection by GLC with EC detection was found to be 32 pg/4-Ml injection. Since the contents of the Florisil tubes are dissolved In 5 ml of solvent, this represents a total of 40 ng of adsorbed .PCBs. Although NIOSH recommends sampling at 200 ml/mlnute, it may be feasible to use pumps that sample at faster rates If there are analytical difficulties with samples of about 100 liters due to low concentrations of PCBs. (e) Medical Surveillance Occupational exposure to PCBs has been shown to cause signs of liver injury and impaired liver function. Outr et al [196], Hasegawa et al [191], and Levy et al [197] all found occasional Incidents of elevated serum ensymes; exposure conditions under which these will not occur are not known. tWvefore, NIOSH recommends determination of SCOT and SGPT initially and at annual intervals. The responsible physician may also wish to determine serum triglyceride concentrations since these have been found to be abnormal In some workers chronically exposed to PCBs [191-193,197]. Especially, elevated serum triglyceride concentrations have been found to 138 N 08089 be related to duration of exposure and to the concentration of residual PCBs In the blood [193], Although the data Indicate that the recommended standard will prevent chloracne, it la not known that It will prevent other akin alimenta. NIOSH recommend# that In comprehensive physical examinations, special emphasis be given to the condition of the skin. PCBs fed to bitches and sows have been found to be teratogenic (FL Earl et al, written communication, 1976). Although terata have not been observed In human babies whose mothers had been exposed to PCBs [176,182,1831, PCBs have been found In human embryos and fetuses [138,139,168], and undesirable effects (abnormal skin color and low birth weights) have been observed In neonates [176,182,183] born after their mothers had ingested PCBs. A woman who was occupationally exposed to PCBs had a blood PCB concentration of 25 ppb when her normal baby was born [195]. NIOSH considers that its recomendad standard will protect unborn babies but recommends that women exposed to PCBs at work be advised of the potential hazards of PCB exposure to unborn children. PCBs have been found in milk of women who have been exposed 'b* PCBs [168,195] and babies have been adversely effected after being nursed by PCB-exposed mothers [182]. A safe level of PCBs In the milk of mothers occupationally exposed to PCBs la not known. Human milk samples In the general US ppfoletlon usually contain detectable amounts of PCBs, and about / one-third of the whole milk samples have been found to contain >50 ppb and up to about 350 ppb (EP Savage, written cosnunleatlon, February 1977). It la not known If all the mothers from whom these samples vers taken nursed their babies without effect. Infant monkeys who vara nursed by mothers 159 in their milk at 150-350 ppb became sick and developed chloracne [234]. Afcer consultation! the woman who was occupationally exposed to PCBs and who had PCBs in her milk at about 250 ppb, stopped nursing her baby out of concern for its health [195]. Based on these considerations, NIOSH recommends that women working with PCBs be counseled concerning the advisability of nursing their babies. (d) Personal Protective Equipment and Clothing PCBs applied to the skin or cornea of experimental animals have been shown to cause local lesions and liver and kidney injuries [205-208,225], One worker who developed chloracne after 3 months of exposure to PCBs was described as having frequently Immersed his hands in the FCB mixture and his clothes were described ae often being Impregnated with PCBs [189], Employees working with an askarel containing 60Z Aroclor 1254 frequently developed skin rashes which were considered by the company physician to be allergic or'contact dermatitis from the askarel (In the Matter of General Electric Company, File Ho. 2833, Hew York State Department of Environmental Conservation, 1975). Other complaints of these workers that were ascribed to the askarel Included irritation of the eyee, nose and throat. Levy et el [197] and Ouv et al [196] found that employees exposed to PCBs at 0.0130,264 mg/cu m and 0.32-1.44 mg/cu a, respectively, complained of similar lrrltatles* and, on examination, there were findings of skin rashes and nasal Irritation. Ouv et al [196] considered that one reason the blood PCB concentrations In workers they studied did not decline (after Improvements in the ventilation system had reduced the environmental concentrations of PCBs) was because the workers did not comply with the recommendations ` for projecting their skin from PCB contact. 160 * Baaed on theae reports [189,196,197,205-208,225], NIOSH recommends that employees working in situations where skin contact may occur be provided with clothing that la Impervious to PCBs and that will cover all body surfaces where contact may occur. To prevent splashing PCBs into the eyes, NIOSH recommends that employees wear appropriate goggles or safety glasses in accordance with 29 CFR 1910.133 and ANSI Z8?.1-1968, Since NIOSH has found PCBs to be potential carcinogens and recommends that exposures be maintained at or below 1 yg/cu m, it considers that only a self-contained breathing apparatus with a full facepiece operated in the positive-pressure mode will provide adequate protection when workers are in areas where higher concentrations exist. Based oh NIOSH etudlee [287-289], other respiratory protective devices ere not considered adequate to provide the needed protection. (e) Other Considerations Engineering .controls are recommended to maintain PCBs In closed systems to reduce exposures to the extent feasible. Such a recommendation la consistent with the Toxic Substances Control Act (Public Lav 94-469) and with the need to protect employees from exposure to PCBs. However, there are situations, such as la accidental leakage from d o s e d systems and in repair of equipment, when PCBs may not be confined. The reconsended standard prescribes general work practices for PCBa as well as emergency work practices. Employees should be Informed of the hazards of working with PCBs, end trained in the recomendad general work practices end the procedures to follow In emergencies. The advantages to their health of complying with the work practices and medical monitoring requirements of the recommended standard should be explained to the employees. As Ouv at 161 A n o tfijQ al [196] pointed out, improving air quality does not go far In alleviating the workers' body burdens of FCBa without their cooperation In Implementing the recommendations for protecting their skin from FCB contact, NTOSH also recosmenda certain sanitation practices to minimize Intake of FCBs by employees. Among these practices Is the requirement that employees be provided with d e a n work clothing daily and that they change clothing before leaving vork. The importance of this measure to the employee and the employee's family Is exemplified In finding up to 180 ppm of FCBs in the dust of PCB-workera* homes [36], FCBs may remain in contaminated premises for years [33], Partly for the same reason, and because FCBs In contact with the skin can be Irritating [196,197] and also because they have caused systemic effects In experimental animals [205208,225], NTOSH reeoomends that workers shower before leaving work. Toxic effects from ingestion of PCBs have been well documented In humans [145-185] and experimental animals [101,209-224,226-237,240-248], Workers may have an Intake of FCBs from their normal diet of 10-20 pg/day [46], and the maximum additional Intake expected from NIOSH's recommended allowable work exposures might be of the order of 10 jig, NTOSH recommends that workers wash their hands before eating and that food, drinks, and smoking materials not be permitted In FCB work areas. The Importance of *this recoMendaclon may be evaluated by considering that one drop of FCBs spilled on food, la drinks, or otherwise conveyed Into the mouth may contain about 50 jig of PCBs, compared to a total Intake of 20-30 jig from other sources, including allowable occupational exposures. Because the consequences of working with FCBs may be substantial, NTOSH recaeaends that entry Into FCB work areas be restricted to authorized konftV?! / 162 K'. employe whose entry Is logged daily, and whose exposures are monitored at least annually to ensure that airborne exposures are at or below the recommended TWA limit. 163 Mrt0l72 N ' 08094 VII. RESEARCH NEEDS There Is a clear need for Information in the following areas: (a) The effects of chronic exposure of animals and humans to PCBs at low concentrations require investigation. Epidemiologic studies of occupational groups and Information on -concentrations of PCBs in workroom air and any related clinical findings would be useful. (b) Chronic exposures of animals to PCBs at concentrations in the range of the recommended environmental limit. (c) Studies of the reproductive histories of women who have been exposed to PCBs In their occupational environments, Including studies of status and development of Infants born to these women. (d) The absorption efficiencies of various PCB mixtures by the dermal and respiratory routes, (e) The method of transport of PCBs in the blood and tha partition between blood on the one hand, and fat scores and milk on the other. (f) A problem that confounds our understanding of the toxicity of PCBs is that of tha toxic activity of contaminants associated with PCBs* The contaminan ts found in commercially Important PCB products should be identified, prepared In pure form and studied toxicologlcally both as individual substances and as mixtures with other, related compounds. (g) Studies regarding methods of removing PCBs from the akin (cleansing), (h) Studies on the use of various barrier creams as a means of minimizing dermal exposure to PCBs. AOiinift 164 (1) There la uncertainty regarding baseline values for FCBs in the blood of humans; research should be conducted to determine baseline values for the general population and for non-exposed industrial populations. 165 !v '* 08096 VIII. REFERENCES 1. Hutzlnger 0, Safe S, Zitko V: The Chemistry of FCBs. Cleveland, The Chemical Rubber Co Frees, 1974, pp 3,4,7-9,22,23,197-220.243-48 2 . Mleure JP, Hicks 0, Kaley RG, Saegar VW: Characterization of Polychlorinated Biphenyls, in Proceedings of the National Conference on Polychlorinated Biphenyls, November 19-21, 1975, Chicago, EPA560/6-75-004, US Environmental Protection Agency, * Office of Toxic Substances, 1976, pp 84-93 3. Kuratsune M (ed): Environmental Health Criteria for Polychlorinated Bi- and Terphenyl *-- WHO Environmental Health Criteria Programme (Japanese document to World Health Organisation}. Fukuoka, Japan, Public Health Association, Japan Environmental Agency, 1974, 159 pp 4. 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Durfee RL: Production and Usage of PCBs in the United States, in Proceedings of the National Conference on Polychlorinated Biphenyls, November 19-21, 1975, Chicago, EPA-560/6-75-004, US Environmental Protection Agency, Office oz Toxic Substances, 1976, pp 103-07 28. Rollins RL: PCBs In Capacitor Applications, in Proceedings of the National Conference on Polychlorinated Biphenyls, November 19-21, 1975, Chicago, EFA-560/6-75-004. US Environmental Protection Agency, Office of Toxic Substances, 1976, pp 306-08 29. Kopp TE: PCB Disposal, Reclaiming, and Treatment, in Proceedings of the National Conference on Polychlorinated Biphenyls, November 19-21, 1975, Chicago, EPA-560/6-75-004. US Environmental Protection Agency, Office of Toxic Substances, 1976, pp 108-23 t 30. 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Shlgematsu N, Ishlmaru S, Hlrose T, Ikeda T, Emori K, Miyazaki N: [Clinical and experimental studies on respiratory involvement in PCB poisoning-- II.] Fukuoka Acta Med 65:88-95, 1974 (Jap) 179. Hirayama C, Okumura M, Nagal J, Masuda 7: Hypoblllrubln in patients with polychlorinated biphenyls poisoning. Clin Chlm Acta 55:97-100, 1974 180. Okumura M, Yamanaka M, Nakamuta S, Uzava R: [Consecutive six year follov-up study on serum triglyceride levels in patients with PCB poisoning.] Fukuoka Acta Med 66:620-23, 1975 (Jap) 181. Uzava H, Ito 7, Notoml A, Rorl S, Ikeura 7, Katsukl S: [Clinical and experimental studies on the hyperglycerldemia Induced by oral ingestion of chlorinated biphenyls.] Fukuoka Acta Med 62:66-73, 1971 (Jap) 182 Yoshimura T: [Epidemiological study on Yusho babies born to mothers who had consumed oil contaminated by PCB.] Fukuoka Acta Med 65:7480, 1974 (Jap) 183. Funatsu I, Tamashita F, Ito 7, Tsugawa S, Funatsu T, Yoshlkane T, Hayashl M, Kato T, Yakushljl M, Okamoto G, Yamasaki S, Ariaa T, Kuno T, Ida H, Ida I: Polychlorblphenyls (PCB) induced fetopathy-- I. Clinical Observation. Kuruma Med J 19:43-51, 1972 184. Ohnishi T, Ikai R, Kurlmoto S, Kavashlma K: (Further ophthalmic studies on patients of chronic chlorobiphenyls poisoning ("Tusho").] Fukaeka Acta Med 66:640-41, 1975 185. Fnhdg H, Asahi 8, Toshltani S: [Dermatological findings of the patients with Tusho (PCB poisoning) In general examination in 1972.] Fukuoka Acta MSd 65:81-83, 1974 (Jap) 186. F u c d n s l l l V: [On chloraene]. Med d Lavoro 45:131-45, 1954 (Ita) 187. Hofmann MF, Meneghinl CL: [Concerning follleulosls caused by chlorosubstltuted hydrocarbons.] 6 Ital Dermatol Slfllol 103:42750, 1962 (Ita) 180 K 0 8 1 ^ 1 188. Birmingham DJ: 3:38-42, 1964 Occupational dermatology-- Current problems. Skin 189. Oliver NE: Chloracne. Arch Dermatol 99:127-28, 1969 190. 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Solne, Sweden, National Swedish Environment Protaction Board/Fubllcations 1973:4E, pp 124-28 199. Buagarnar JE, Banner DI, Colucel AV, Cra eon JP, Flnklea JF: Polychlorinated biphenyl reslduaa in refuse workers* Research Triangle Perk, NC, US Dept Health, Education, and Waifare, Public Heelth Service, National Institute of Environmental Heelth Sciences, June 1973, 10 pp 181 N 084/1,2,. , A0 0 0 1 9 0 200. Cutler SJ, Young JL Jr? Third National Cancer Survey-- Incidence Data, Monograph Al. US Dept Health, Education, Welfare, Public Haalth Service, National Institutes of Health, National Cancer Institute, March 1975, pp 10-24 201. Bahn AK, Roeenvaike I, Herrmann N, Grover F, Stellmau J, O'Leary K? Melanoma after exposure to PCBe. N Engl J Med 295:450, 1976 202. Rozanova LF: [Toxicity of some chlorinated aromatic hydrocarbons.] Faraakol Tokeikol 6(6):48-53, 1943 (Rus) 203. Treon JF, Cleveland FF, Ceppai JW, Atchlay RW: The toxicity of th* vapors of A r o d o r 1242 and A r o d o r 1254. Am Ind Hyg Q 17:204-13, 1956 204. Hunter B, Be them P, Haywood R, Str AE, Cherry CP: Decachlorodlphenyl toxicity to rats-- Dietary ministration for 4 veeks. Huntingdon, England, Huntingdon Research Centre, May 1974, 53 PP 205. Von Wedel Holla HA, Denton J: Observations on the toxic effects resulting from exposures to chlorinated naphthalene and chlorinated phenyls vith suggestions for prevention* Rubber Age 54:419-26, 1943 206. Miller JW: Pathologic changes in animals exposed to a commercial chlorinated diphenyl. Public Health Rep 59:1085-93, 1944 207. Parlbok VP: [Effects of chlorinated diphenyl (sovol) on the akin and Its resorption.] Farmakol Tokslkol 17:51-54, 1954 (Rus) 208. Vos JG, Beams RB: Dermal toxlelty studies of technical polychlorinated biphenyls and fractions thereof In rabbits* Toxicol Appi Pharmacol 19:617-33, 1971 209. Vos JG, De Rolj T: Immunosuppressive activity of a polychlorinated biphenyl preparation on the humoral lamina response la guinea pigs. Toxicol Appi Pharmacol 21:549-55, 1972 210. Vos JG,. Van Drlel-Grooteahula L: PCB-lodueed suppression of the humoral and *cell-mediated Immunity in guinea pigs* Sci Total Environ 1x289-302, 1972 211. Brmgkmer JV, Xhaana XL, Cornlah HH: Biological raaponass of tha rat to polychlorlaatad biphenyls. Toxicol Appi Fhaxmaeol 24:434-48, 1973 212. Brueknar JV, Khatma XL, Cornlah HH: Effset of prolonged ingeetion of polychlorinated biphenyls on the rat* 7d Cosmet Toxicol 12:323-30, 1974 213. Brueknar JV, Khanna XL, Cornish HH: Polychlorinated blphenyl-lnduced alteration of biologic parameters in the rat* Toxicol Appi Pharmacol 28:189-99, 1974 A.C0M 91 f * i* ' 182 N 0 3 1 ^ 214. Litterst CL, Farber TM, Baker AM, Van Loon EJ: Effect of polychlorinated biphenyl* on hepatic microsomal enzymes In the rat, Toxicol Appl Pharmacol 23:112-22, 1972 215. Kimbrough RD, Linder RE, Gaines TB: Morphological changes in livers of rats fed polychlorinated biphenyls. Arch Environ Health 25:35464, 1972 216. Allen JR, Abrahamson LJ: Morphological and biochemical changes In the liver of rats fed polychlorinated biphenyls. Arch Environ Contaa Toxicol 1:265-80, 1973 217. Hansell MM, Ecobichon DJ: Effects of chemically pure chlorobiphenyls on the morphology of rat liver. Toxicol Appl Pharmacol 28:416-27, 1974 218. Kimbrough RD, Squire RA, Linder RE, Strandbcrg JD, Mon tail! RJ, Burse VW: Induction of liver tumors In Sherman strain female rats by polychlorinated biphenyl A r o d o r 1260. J Natl Cancer Inst 55:145359, 1975 219. Kimbrough RD, Linder RE, Burse VW, Jennings RW: Adenofibrosis In the rat liver-- With persistence of polychlorinated biphenyls In adipose tissue. Arch Environ Health 27:390-95, 1973 220. Kimbrough RD: Brief communication: Fancreatlc-type tissue In livers of rata fed polychlorinated biphenyls. J Natl Cancer Inst 51:679-81, 1973 221. Kimbrough RD, Linder RE: Induction of adenofibrosis and hepatomas of the liver in BALB/cJ mice by polychlorinated biphenyls (Aroclor 1254). J Natl Cancer Inst 53:547-52, 1974 222. Allen JR, Abrahamson LJ, Norback DH: polychlorinated biphenyls and triphenyl* on Environ Res 6:344-54, 1973 Biological effects of the subhuman, -^primate. 223. Bell M: Ultra*truetural Features of Gastric Mucosa and Sebaceous Glands Aftar Ingestion of Aroclor 1242 by Rhesus Monkeys, in Proceedings of the National Conferenea on Polychlorlnatad Biphenyls, November 19-21, 1975, Chicago, EPA 560/6-75-004. US Environmental Protection Agency, Office of Toxic Substances, 1976, pp 350-58 224. Allte JR, Norbeck DH: Polychlorinated blphenyl-and triphenylInduced gastric mucosal hyperplasia In primates. Science 179:498-99, 1973 225. Vos JG, Noteaboom-Ram E: Comparative toxicity study of 2,4,5,2',4*,5'-hexachloroblphenyl and a polychlorlnatad biphenyl mixture in rabbits. Toxicol Appl Pharmacol 23:563-78, 1972 tfinniQ2 N 03114 226. Allen JR, Cartens LA, Abrahamscn LJ, Marlar RJ: Responses of rats and nonhuaan primates to 2,5,2T,5T-tetrachlorobiphenyl. Environ Res 9:265-73, 1975 227. Torok P: Delayed pregnancy in NMRI mice treated with PCB-- 2,2'dichlorobiphenyl. Bull Environ Contam Toxicol 16:33-36, 1976 228. Linder RE, Gaines TB, Kimbrough RD: The effect of polychlorinated biphenyls on rat reproduction, Fd Cosmet Toxicol 12:63-77, 1974 229. Villeneuve DC, Grant DL, Phillips VEJ, Clark ML, Clegg DJ: of FCB administration on microsomal ensyme activity In rabbits. Bull Environ Contam Toxicol 6:120-28, 1971 Effects pregnant 230. Villeneuve DC, Grant DL, Khera K, Clegg DJ, Baer H, Phillips VEJ: The fetotoxldty of a polychlorinated biphenyl mixture (Aroclor 1254) in the rabbit and in the rat, Environ Phys 1:67-71, 1971 231. Grant DL, Villeneuve DC, MeCully KA, Phillips transfer of polychlorinated biphenyls in the rabbit. 1:61-66, 1971 WEJ: Placental Environ Physiol 232. Allen JR, Carstens LA, Barsottl DA: Residual effects of short-term, low-level exposure of nonhuman primates to polychlorinated biphenyls, Toxicol Appl Pharmacol 30:440-51, 1974 233. Barsottl DA, Marlar RJ, Allen JR: Reproductive dysfunction in Rhesus monkeys exposed to low levels of polychlorinated biphenyls (Aroclor 1248). Fd Cosmet Toxicol 14:99-103, 1976 234. Allen JR, Barsottl DA: The effects of transplacental and mammary movement of PCBs on infant rhesus monkeys. Toxicology 6:331-40, 1976 235. Dikshith TSS, Roekvocd V, Abraham, R, Coulston F: Effects of a polychlorinated biphenyl (Aroclor 1254) on rat testis. Exp Mol Pathol 22:376-85, 1975 236. 237. Green S, Carr JV, Palmer KA, Oswald EJ: Lack of cytogenatlc effects la bone marrow and spermatagonlal calls in rata treated vieh polychlorinated biphenyls (Aroclor 1242 and 1254). Bull Environ Conte* Toxicol 13:14-22, 1975 S,Green Saaro FM, Friedman L: Lack of dominant lethality in rats treated with polychlorinated biphenyls (Aroclors 1242 and 1254). Fd Cosmet Toxicol 13:507-10, 1975 238. Hooplngarner R, Samuel A, Krause D: Polychlorinated biphenyl Interactions with tissue culture cells. Environ Health Perspect, Experimental Issue No. 1, April 1972, pp 155-58 N 08^5 184 if' * *-v \ V 239. Popper H, Czygan P, Greim H, Schaffner'F, Garro AJ: Mutagenicity of primary and secondary carcinogens altered by normal and induced hepatic microcodes (37103). Proc Soc Exp Biol Med 142:727*29 1973 240. Nagasaki H, Tomii S, Mega T, Marugaml M, Ito N; Hepatocarcinogenlclty of polychlorinated biphenyls in mice. Gann 63:805, 1972 241. Ito N, Nagasaki H, Aral M, Maklura S, Suglhara S, Hlrao K: Histopathologic studies on liver tumorigenesis Induced in mice by technical polychlorinated biphenyls and its promoting .effect on liver tumors Induced by benzene hexachlorlde* J Natl Cancer Inst 51:1637* 46, 1973 242. Kisura NT, Baba T: Neoplastic changes in the rat liver Induced by polychlorinated biphenyl. Gann 64:105*08, 1973 243. Staiff DC, Quinby GE, Spencer DL, Starr HG Jr: Polychlorinated biphenyl emission from fluorescent lamp ballasts. Bull Environ Contain and Toxicol 12:455*63, 1974 244. Jones M, Backer J: Industrial Hygiene Survey of the Polychlorinated Biphenyl Production Operation, Monsanto Industrial Chemicals Company, Sauget, Illinois* Cincinnati, Dept of Health, Education, and Welfare, Public Health Service, Center for Disease Control, National Institute for Occupational Safety and Health, May 1977, 10 pp 245. Tataukava R: FCB pollution of the Japanese environment, in Hlguehl K (ed): PCB Poisoning and Pollution. Ner York Academic Press, 1976, pp 147-79 246. American National Standard: Fundamentals Governing the Design and Operation of Local Exhaust Systems, ANSI Z9*2-1971. Nev York, American National Standards Institute, 1972, 63 pp 247. Durfse RL, Contoa G, Whitmore PC, Barden JD, Hackman EE III, Weetin RA: FCBa in the United States-- Industrial Use and Environmental Distribution, EPA 560/6-76-005. US Environmental Protection Agency, Office of Toxic Substances (FB-252 012) 1976, pp 10,15,16,18,19, 74,75,88,147 248. Bldljnaa TP, Olney CE: High-volume collection of atmospheric polychlorinated biphenyls. Bull Environ Contes Toxicol 11:442*50, 1974 249. Nlahlyasa K, Yano H, Kavano M: [Determination of polychloroblphenyl in air and Its vaporisation from noncarbon copy paper.] Shikoku Acta Med 29:305-10, 1974 (Jap) (Abet.) 185 N 08116 1 2 S eclrjC rV i*t 250. Wakimoto T, Tataukava R, Ogava T, Watanabe I: Determination of organochlorine pesticide and FCB (polychlorinated biphenyl) in air by the dry column collection method. Bunseki Kagaku 23: 790-93, 1974 (Abac.) 251. Harvey GR, Stainhauer WG: Atmoapherlc tranaport of polychloroblphenyla to the North Atlantic. Atmoe Environ 8:777-82, 1974 252. Glam CS, Chan HS, Neff GS: Rapid and inexpensive method for detection of polychlorinated biphenyls and phthalatea In air. Anal Chem 47:2319-20, 1975 253. Laveskog A, Llndakog A: Chlorinated hydrocarbons In the atmosphere. Chem Ing Tech 48:65, 1976 (Synopsis) 254. NIOSH Standards Completion Program: Chlorodlphenyl (54% Chlorine), Method No. SI21. Cincinnati, US Dept Health, Education, and Welfare, Public Health Service, Center for Disease Control, National Institute .for Occupational Safety and Health, 1976, 15 pp 255. NIOSH Standards Completion Program: Chlorodlphenyl (42% Chlorine), Method No. S120, Failure Report. Cincinnati, US Dept Health, Education, and Welfare, Public Health Service, Center for Disease Control, National Institute for Occupational Safety and Health, 1976, 7 pp 256. Flshbeln L: Chromatographic and biological aspects of polychlorinated biphenyls. J Chreoatogr 68:345-426, 1972 257. Flshbeln L: Chromatography of Environmental Hazards, Vol II. Nev York, Elsevier Scientific Publishing Co, pp 529-77, 1973 258. Interdepartmental Task Force on PCBa: Polychlorinated Biphenyls and the Environment, Report No. ITF-PCB-72-1. Springfield, Va, US Dept of Commerce, National Technical Information Service, C0M-72-10419, 1972, pp 23-40 259. Oswald EO| Albro PW, McKinney JD: Utilization of gas-liquid chromatography coupled with chemical loulzatron and electron Impact eaegr spectrometry for the Investigation of potentially hazardous a n r v o M a u l a l agents and their metabolites. J Chromatogr 98:363-448, 1974T 260. Cook JWi Some chemical aspects of polyeUorlnated biphenyls (FCBs). Environ Health Perepecc, Experimental Issue No. 1, April 1972, pp 3- 261. Saroflm AF: PCBa-- Environmental Impact-- Analytical Methods. Environ Res 5:338-62, 1972 186 N 08117 f fV. 262. Sherma J: Gas-chromatography analysis of polychlorinated biphenyls and other nonpesticide organic pollutants, Adv Chromatogr 12:141-76. 1975 263. Koeman JH, Ten Noever De Brauw MC, De Vos RR: Chlorinated biphenyls in fish, mussels and birds from the river Rhine and the Netherlands coastal area. Nature 221:1126-28, 1969 264. Skrentuy RF, Hamken RV, Dorough HW: Silo sealants as a source of polychlorobiphenyl (FCB) contamination of animal feed. Bull Environ Contaa Toxicol 6:409-16, 1971 265. Zitko V: Polychlorinated biphenyls and organochiorine pesticides in some freshwater and marine fishes. Bull Environ Contest Toxicol 6:464-70, 1971 266. Kail JE, Frlester LE, Sandlfer SH: Polychlorinated biphenyl (Aroclor 1242)-- Effect of uptake on growth, nucleic a d d s , and chlorophyll of a marine diatom. Bull Environ Contaa Toxicol 6:156-59, 1971 267. Hansen DJ, Parrish PR, Love JI, Wilson AJ Jr, Wilson PD: Chronic toxicity, uptake, and retention of Aroclor 1254 In two estuarine fishes. Bull Environ Contaa Toxicol 6:113-19, 1971 268. Collins GB, Holmes DC, Jackson FJ: The estimation of polychlorohiphenyls. J Chromatogr 71:443-49, 1972 269. Sawyer LD: Collaborative study of the recovery and gas chromatographic quantitation of biphenyl-DDT combinations in fish. J Assoc Off Anal Chem 56:1015-23, 1973 270. Flnstervalder CE: Collaborative study of the determination of polychlorinated biphenyls In paperboard. J Assoc Off Anal Chem 57:518-21, 1974 271. Beezhold FL, Stout VF: The use and effect of mixed standards on the quantitation of polychlorinated biphenyls. Bull Environ Contain Toxicol 10:10-15, 1973 272. Pesticide Residues, Is Horvltz W, Seazel A, Reynolds H, Park DL (eds): Official Methods of Analysis of the Association of Analytical Chemists, ed 12. Association of Official Analytical Chemists, 1975, pp 518-28 273. Rote JW, Murphy PC: A method for the quantitation of polychlorinated biphenyl (PCB) Isomers. Bull Environ Contam Toxicol 6:377-84, 1971 274. Rlsebreugh RW, Relche P, Olcott HS: Current progress In the determination of polychlorinated biphenyls. Bull Environ Contam Toxicol 4:192-201, 1969 187 N 08118 A 275. Zobal MGR: Quantitative biphenyl*-- A computer approach. 1974 determination of J Assoc Off Anal polychlorinated Chea 57:791-95. 276. Webb RG, McCall AC: Quantitative PCB standard* for electron capture ga* chromatography. J Chromatogr Sci 11:366-73, 1973 277. Burke JA: Report on chlorinated peeticldes. J Assoc Off Anal Chea 59:338-40, 1976 278. Method for Polychlorinated Biphenyl* (PCB*) In Industrial Effluents, Cincinnati, Environmental Protection Agancy, Environmental Monitoring Support Laboratory, 1976, 40 pp 279. Chau AST, Sampson RCJ: Electron capture chromatographic methodology for the quantitation of polychlorinated biphenyls-- Survey and compromise Environ Lett 8:89-101, 1975 280. Berg OW, Dlesady PL, Rees GAV: Column chromatographic separation of polychlorinated biphenyl* from chlorinated hydrocarbon pesticides, and their subsequent ga* chromatographic quantitation in terms of derivative* Bull Environ Contam Toxicol 7:338-47, 1972 281. Armour JA: Quantitative perchlorlnatlon of polychlorinated biphenyl* a* a method for confirmatory residue measurement and identification. J Aaeoc Off Anal Cham 56:987-93, 1973 282. Hutzlnger 0, Safe S, Zitko V: Analysis of chlorinated aromatic hydrocarbon* by exhaustive chlorination-- Qualitative and structural aspects of the perchloro-derlvatlves of biphenyl, naphthalene, terphenyl, dlbenxofuran, dlbenzodioxln and DDE. Int J Environ Anal Chem 2:95-106, 1972 283. Mlzutanl T, Matsumoto M: Determination of polychlorinated biphenyls by an exhaustive ehlorlnatlon method Shokuhln Elselgsku Zasshi 13:398-404, 1972 (Abet.) 284. Huekina JH, Svanson JE, Stalling DL: Perchlorlnatlon of polychlorinated biphenyls. J Assoc Off Anal Chem 57: 416-17, 1974 285. Trotter TO, Young SJV: Limitation on the use of antimony psifchloride for perchlorlnatlon of polychlorinated biphenyls. J AsetC Off Anal C h m 58:466-68, 1975 286. Pritchard JA: A Guide to Industrial Respiratory Protection, No. NI0SH 76-189. Cincinnati, US Dept Health, Education, and Velfara, Public Haalth Service, Center for Dlaeeae Control, National Institute for * Occupational Safety and Haalth, 1976, 150 pp V* -- 188 N 03119 3. ( ".-H4 287. Blair A: Abrasive^ Blasting Respiratory Protective Practices, No. NIOSH 74-104, Cincinnati, US Dept Health, Education, and Welfare, Public Health Service, Center for Disease Control, National Institute for Occupational Safety and Health, 1974, 116 pp 288. 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American Conference of Governmental Industrial Hygienists: Threshold Limit Values for 1968-- Recommended and Intended Values, Adopted at the 30th Annual Meeting, ACGIH, St. Louis, May 13, 1968, pp 1,3,5,7 Anom.qg N 0 3 1 2 1 190 IX. APPENDIX I SAMPLING PROCEDURE FOR COLLECTION OF POLYCHLORINATED BIPHENYLS General Requirement (a) Air sample representative of the breathing zone of workers must be collected to determine the exposure from each job or from the specific operation In each work area. (b) Suggested records: (1) Date and time of sample collection; (2) Pump model and serial number; (3) Sample tube type and number; (A) . Sampling duration; (5) Total sample volume; (6) Location of sampling; (7) Temperature, pressure, and relative humidity at time of sampling; (8) Other pertinent Information. Calibration Since the accuracy of environmental sampling can be no greeter than the accuracy of the air veliffe measurement, the accurate calibration of the sampling pump is essential to the correct estimation of the volume of the sample that Is collected. The required frequency of calibration Is dependant on the use, cere, end handling to which the pump Is subjected. Pumps should be calibrated initially and recalibrated If misused or 191 A0 0 0 2 0 0 N 08122 repaired. If pumps receive hard usage, more frequent calibration may be necessary. Regardless of use, maintenance and calibration should be performed on a regular schedule and records of these should be kept. The accuracy of calibration depends on the type of instrument used as a reference. The choice of calibration instrument will depend largely upon where the calibration is to be performed. Ordinarily,'pumps should be calibrated in the laboratory. For laboratory testing, primary standards, such as a spirometer.or a soapbubble meter, are recommended, although other standard calibration Instruments, such as a vet-test meter or dry gas meter, can be used. The calibration setups will be similar for all Instruments. Instructions for calibration with the soapbubble meter follow. If enother calibration device is selected, equivalent procedures should be used. Since thezflowrate of .a pump dependa on the preaeure drop acrosa the sampling device, in this ceae a "Florisil" tube, the pump ouat be calibrated while operating with e representative tube in line. The celibretlon system should be asses&led in earlee following this order: soapbubble meter, water manometer, Florleil tube, end pump. (a) Check the voltage of the pump battery with e voltmeter to ensure adequate voltage for celibretlon, end change or charge the battery if necessary. (b) T e n on the pump end moisten the inside of the soapbubble meter by lamerelag the buret in the eoep solution end drawing bubbles up the inside until they travel the entire buret length without bursting. (c) Adjust the pump rotameter to provide the desired flowrate. N- 08123 192 (d) Check the water manometer to ensure that the pressure drop across the sampling train does not exceed. 2,5 Inches of water at 0.2 liter/minute. (e) Start a aoapbubble up the buret and measure with a stopwatch the time required for it to move between calibration marks. (f) Repeat procedure (e) at least twice, average the results, and calculate the flowrate from the volume between the preselected marks divided by the time required for the aoapbubble to traverse the distance. (8) Record the volume measured, elapsed time, pressure drop, air temperature, atmospheric pressure, serial number of pump, date, time, and name of person performing the calibration. (h) The rotameter reading should be corrected for temperature and pressure, if necessary. Sampling (a) Samples should be collected as near as practicable to the faces of workers without interfering with freedom of movement. (b) Samples should, be collected to permit determination of TWA exposures for every job Involving exposure to PCBs and In sufficient numbere to express the verlablliey of the exposures In the work situation. (c) Apparatus for Breathing Zone Sampling (1) Pump, battery-operated, with clip for attachment to the worker's clothing. Airflow through the pump should be controlled within 5Z of the desired rate during the entire sampling period. (2) Sorbent Tubes Glass tubes at least 7 cm long with 4 cm I.D. and containing 193 * ( ' * ' ` . . . '` / - I N 08124 two sections of 30/48 mesh deactivated Florlsll. (Florisil, 30/60 mesh, is sieved to the proper mesh size.) The front section, preceded by a glass vool plug, contains 100 mg adsorbent, and the backup section contains 50 mg. A urethane foam plug is placed between these sections and also behind the backup section. The ends of the tuba are flame-sealed to prevent contamination before use. Deactivate the Florlsll before packing the tubes by drying a weighed amount at 105 C for 45 minutes. After cooling to room temperature, add the Florisil to a round bottom flask which can be attached to a rotary evaporator. Add water at 3 m l / 100 g of Florlsll (le, 3Z W/W water) and turn the mixture in the rotary evaporator for 1 hour or until it Is uniformly mixed (free-flowing). (d) Collection and Shipping of Samples (1) Immediately before sampling, break each end of the sorbent tube to provide an opening at least one-half the Internal diameter of the tube (2 mm). (2) The smaller, or backup, section of Florlsll should be positioned nearest the sampling pump. (3) The sorbent tube must be vertical during sampling. Tubes should not be placed la a horizontal position since this may lead to "channeling" of the sorbent bed. 4( ) Do not pass air being sampled through any hoae or tubing before It enters the tube. (5) Collect the air sample at a flow rate of 200 cc/minute or lesa to obtain the total sample volume required. The recommended maximum sampling volume for this method la 50 liters. 194 K 38125 (6) Cap the sorbent tubes with Inert plastic caps immediately after sampling. Under no circumstances are rubber caps to be used. Label tubes and note precise location assignments* (7) Handle one additional tube in the same manner as the sample tubes except that no air Is to be drawn through it. Label this tube as a blank. (8) If the tubes are to be shipped, pack them tightly to minimize breakage In transit. (9) Do not subject the tubes to extremes of temperatures or to low pressures. (10) Provide bulk samples of the PCS preparation whose presence in the environment Is suspected to the analytical laboratory. Do not transport these bulk materials In the same container as the samples or blank tubes. If possible, also provide a bulk air sample to use for qualitative Identification* 195 N m iZ 6  - - X. APPENDIX II ANALYTICAL METHOD FOR POLYCHLORINATED BIPHENYLS Principle of the Method A known volume of air Is drawn through a tuba containing Floris11 to adsorb the PCBs present In the air sample. The collected FCBs are desorbed with hexane, and the resulting solutions are analyzed using gas-liquid chromatography with electron capture detection. The concentration of PCBs relative to a standard PCB preparation Is read from a standard curve. If the air sample Is found to differ significantly In composition from available PCS standards, then use the alternate procedure of perchlorlnatlon described In paragraph (b)7 of Procedure. Range and Sensitivity of the Standard Analysis NIOSH has found with Aroclor 1016, that the minimum detectable amount of PCB Is 32 pg/4 ill, With a total desorption volume were 5 ml, this would represent a total sample of 40 n* of Aroclor 1016. Thus the method is capable of detecting a concentration of 40 ng in a 1 cu m air sample, or a concentrating of about 1 jtg/cu a In an air sample of 50 liters. The upper range of thff analytical method is apparently llmltlees depending only . upon the degree of dilution needed to maintain the concentration of the sample within the linear range of the electron capture detector (32 pg to 3 ng/Injection). In practice, concentrations la workplace air have been f o u M ' t o be as high as 1.5 mg/cu m. :N 03127 196 nwns Interferences (a) Strict measures to avoid contamination are required when using the electron capture detector. Foremost, the syringe oust be thoroughly cleaned after each injection. Hexane to be used in the analytical procedure should be periodically analyzed by GLC for purity. It should show no chromatographic peaks later than 45 seconds, if less than 5 #1 have been Injected. (b) Any compound which has nearly the same retention time on the GLC column as one of the FCBs la an interfrent. This type of Interference can often be overcome by changing the GLC operating conditions or by selecting another column. Retention time data on a single column, or even on a number of columns, cannot be considered as proof of chemical identity. It is important, therefore, that a sample of the bulk mixture of FCBs be analyzed at the same time as the contents of the sample tubes so that chemical identification of possible interferences can be made. (c) The Interferences which have been reported In the literature in the GLC analysis of FCBs are not expected to be Important for this method. Chlorinated pesticides, such as DDT, DDE, etc, have been reported aa Interferences due to coextraetlon with FCBs during workup of samples such as water, tissue, soil, or biologic fluids. In the case of personal air sampling In an Industrial environment, these Interferences would not be present in amounts that would significantly Interfere unless they were manufactured in the same area. Thus, unless these chlorinated pesticides are specifically known as potential interfrants, extra- cleanup or separation steps for these materials are net necessary. 197 *00(120? :N 08.128 11 (d) Sulfur-containing compounds in pecroleum products have been reported as interferences. (e) If present. In the PCB mixture, biphenyl will be an interference when staple* ere analyzed by perehlorination; however, PC3* for the purpose of this recommended standard Include biphenyl. (f) Brominated impurities in antimony pentachlorlde have also been found to lead to Interferences in perehlorination procedures. Results from NIOSH laboratories Indicate, however, that these brominated impurities may be removed byzvacuum distillation of the antimony pentachlorlde. Precision and Accuracy The performance characteristics of the method as found by NIOSH are presented below. (a) The volume of air sampled can be measured to H Z if a pump with a calibrated volume indicator la used. Volumes calculated from initial flow rate settings may be less accurate (51) because of changes In flow rate during sampling. (b) At airborne PCB concentrations of up to 10 mg/cu m, the front section of the Florlsll tube has a 1001 collection efficiency for 50-liter air samples. (c) Recovery of known amounts of PCBa adsorbed on Plorlsll la quantitative (1001). (d) Sealed tubes or desorbed sample solutions can be stored for 2 months without PCB loss. (e) The precision of the analysis is dependent upon the precision and sensitivity of the technique used to quantitate the GLC peaks of the 198 n 03129 ; 4 i 1 samplea and standards. The precision of che standard analytical procedure has a relative standard deviation of 4.4Z, (f) The average conversion of PCBa to decachlorobiphenyl Is about 100Z with a relative standard deviation of about 2Z. (g) Recovery of decachlorobiphenyl decachlorlnatlon procedure Is >99Z with a relative subjected to the o fstandard deviation 1.8Z. (h) The accuracy of these procedures is not knovn; accuracy depends on the ability to separate and Identify each compound In the PCS mixture and to compare each with a knovn standard. Many of the Isomers In commercial PCB mixtures have not been separated or Identified, and standarde for many of the Isomers are not available. Advantages of the Sampling and Analytical Methods (a) The sampling device Is small, portable, and Involves no liquids (b) The capacity of the solid sorbent sampling device for PCBs Is large and recovery of PCBe from the sorbent Is quantitative. (c) The contents of the sample collection tubes are analyzed by means of a rapid lnstrtffisntal method. (d) Interferences are minimal, and most of those which do occur can be eliminated by altering chromatographic conditions. (e) The perchlorlnatlou procedure provides qualitative confirmation and quantitative measure of PCBs, since it is based on measurement of the single GLC-EC detection response of decachlorobiphenyl. , N 0.8130 A0iJO2O8 Disadvantages of the Sampling and Analytical Methods (a) Tha precision of the sampling method Is limited by the reproducibility of the pressure drop across .the tubes. Pressure drop changes will result in variability in the flow rate and cause the sampling volume to be Imprecisely known because the pump is usually calibrated for only one tube. (b) A substantial difference between the composition of PCBs in the air sample and that of the commercial ?CB mixture being used as a standard will result In a large error in accuracy when the standard analytical procedure is used since estimation of the FCB content of the sample is based on comparison with such a PCB mixture. Apparatus Ca) Gas liquid chromatograph equipped with an electron capture detector capable of maintaining a detector temperature of 350 C. Cb) Glass column (6 feet x 2 mm I.O.) packed with 1.5* 0V-17/1.95* QF-1 on 80/100 mash Supelcoport. (c) Vials (20-ml), with aluminum-lined cape. (d) Mlcrollter syringe (10-jtl)* <) Volumetrie flasks (10-ml for Standards) with glass stoppers. (f) Ksthod for determining peak araae. <*> Culture tubes, 13 x 100 m , with unllned screw top cepe. (h) Oven, capable of maintaining 160 C 5 C. (i) Send bath. <j > Vortex mixer. '* N 08131 AOOA209 Reagents (a) (b) (c) (d) (e) (f) Cg) Hexane, pesticide-grade quality. Nitrogen carrier gas, prepurified. FCB mixture under study. Antimony.pentaehloride, distilled under vacuum. Decachloroblphenyl. Sodium sulfate, anhydrous. Hydrochloric a d d , 20Z aqueous. Calibration and Standards (a) Standardization Procedure Usa the particular PCS mixture as the standard that vas being used in the work area in which air samples were taken. Prepare standards in hexane at concentrations ranging from 8 to 500 ng/ml. Calibration curves should be established dally since the electron capture detector response may vary from day to day. Plot the standard curve In terms of concentration (ng/ml) versus area. Since the injection volumes of the standard and the sample are identical, the concentration of the sample can be read directly from the standard curve. (b) Alternate Standardization Procedure (Perchlorination) The product of the perchlorinatlon of the PCB mixture with antimony pentaehlorlda is decachloroblphenyl. Standards of decachloroblphenyl are prepared in hexane at concentrations ranging from 70 to 440 ng/jil. Calibration curves are established dally since the electron capture detector response may vary from day to day. The standard curve Is plotted In terms of concentration (ng/ml) versus peak area. Since the Injection 201 Annft2 io volume of the standard and the *ample are Identical, the concentration of the sample can be read directly from thla curve. Procedure (a) Cleaning of Equipment All glaaavare used for the laboratory analytic ahould be washed with a detergent, throughly rinsed with tap water, distilled water, pesticide- grade acetone, and finally pesticide-grade hexane end then dried. (b) Analysis of Samples (1) Preparation of Samples Seore.each tube with a file and plaee the glees wool and front section la a clean, dry vial. Piece theseparating urethane foam plug, the *t back section of the sorbent, and the retaining urethane foam plug in a second d e a n , dry vial. The front and back sections ere analyzed separately. (2) Desorption of Samples Prior to analysis, pipat 5.0 ml of hexane into .each vial. Florlsil particles should not be allowed to cling to the glees above the solvent. A minimal desorption time of 10 minutes la required before analysis, (3) Gas-liquid chromatographic determina tion by this procedure ere: conditions for PCB (A) Nitrogen carrier gas flow rate, 60 ml /minute. (B) Injector temperature, 300 C. (C) Interface end detector temperatures, both 325 C. 000211 . CD) Column temperature, 180 C. 202 t: 08133 (A) Sample Injection The solvent-flush technique Is recommended for Injection of materials Into the GLC apparatus. With this method, the following procedure would be used to Inject 4 pi of sample. Three microliters of hexane would be drawn into the syringe, followed by 1 pi of air, followed by A pi of sample solution. After the needle la removed from the sample solution, 1 additional pi of air Is drawn Into the syringe to minimize evaporation at the tip of the needle. The plunger now rests at the 9-pl mark. Inject at least 7 pi of the syringe contents Into the gas chromatogram. Not less than 1 pi of flush-solvent should be used. Larger volumes of flush may give a solvent' peak which Interferes with sample component peaks. The syringe must be cleaned with hexane after each injection. (5) Preliminary Analysis Using the solvent-flush method of subsection b(4), Inject 1 pi of sample and 1 pi of flush-solvent at the conditions specified under subsection b(3). If the sample la too concentrated, further dilutions will be necessary to bring the concentration of the sample solution Into the linear range of the electron eapeure detector. Once the concentration of the sample Is appropriately adjusted, Its chromatogram should be compared to that of a standard to determine If the air sample Is qualitatively different la composition from the standard. If there la little difference between tha two chromatograms, then proceed with the standard analysis using the PCS mixture for standardization, subsection b(6), On the other hand, should there be a significant difference between the two chromatograms (such that comparison with the FCB mixture eould result In 203 'H grot error), then use the alternate procedure for standardization, tubtection b(7). (6) Standard Analysis Select at least five proolnent peaks In the aample chromatogram and compare their heights or areas with those of the standard. Calculate the concentration of PCBs by comparing the heights or areas of the selected peaks in the sample chromatogram of those in the standard chromatograms of known amounts of material. (7) Alternate Standardization Procedure A 200-jjI aliquot of the sample is placsd In a 13-tan x 100-mm culture tube and the hexane is slowly evaporated with dry nitrogen until 10 pi or lass remain. Do not allow hexane to climb the tube during evaporation and do not allow the sample to evaporate to dryness. Iasadlately add 0.2-0,5 ml of distilled antimony pentachlprida with a disposable plpet as rapidly as possible (antimony pentachlorlda decomposes rapidly in air) and cap the tube. The sample should remain light yellow after this addltlont but If the sample turns dark brown or black, it must be discarded and another aliquot of that sample must be used. All samples are placed together In a sand bath. There should be no liner la the eap of the tube, since most liners are attacked by antimony pentachlorlda. A sample of daeachloroblplMayl is treated In a manner similar to the samples. The sand bath contalniaf all of the treated samples la placed In a preheated oven at 160 C for at least 3 hours Samples may also be treated overnight. After perchlorlnatlon, the sand bath Is removed from the oven and the samples are removed from the sand and allowed to cool to room temperature. To each sample la added dropwlse 0.3 ml of 20Z hydrochloric a d d . This mixture Is ;i 204 'H 08135 i\r002!3 I then extracted four times with 1-2 ml of hexane each time. Each extract is passed through a funnel containing approximately 0,5 g of anhydrous sodium sulfate (retained by a glass wool plug) into a 10-ml volumetric flask. The volume of the sample is brought to 10 ml by rinsing the pipet, sodium sulfate, and funnel tip with hexane. The funnel should not rest on thezllp of the flask during filtration. The glass wool plug and sodium sulfate In the funnel are replaced after each sample. An aliquot of the sample solution is Injected under the GLC conditions described above. The solvents flush technique is recommended using 2 pi of solvent back flush and 6 n l of standard or sample solution. The syringe must be cleaned vith hexane after each injection. The height or area of the decachlorobiphenyl peak is compared to that of the decachlorobiphenyl standard and the weight of decachlorobiphenyl present is calculated. (8) Gas-liquid chromatographic conditions for decachlorobiphenyl determination: (A) Nitrogen carrier gas flow race, 90 ml/minute. (B) Injector temperature, 300 C. (C) Interface and detector temperature, 325 C. (D) Column temperature, 220 C. (c) Determination of Desorption Efficiency NXOSH has found average desorption efficiency is >99.31, thus, results of sample analyses need not be corrected for desorption efficiency. Calculations (a) Standard Analytical Procedure The following are the steps in the calculation of concentrations of 205 Anno2i4 FCBs la air when determined with a PCB mixture aa the standard. (1) Add the heights or areas of several selected prominent peaks (at least five) In the chromatogram, compare with the total heights or areas of those same peaks In the standard, and read the concentration of the sample solution (ng/ml) from the standard curve. (2) Multiply the concentration, in ng/ml, of the sample solution by the total volume, In ml, of the sample solution and calculate the weight of FCBs In the sample. Make corrections for the blanks If necessary. (3) Add the weights found on the front and the back sections of the tube to find the total weight of PCBs In the air sample. (4) Divide the total weight of the FCBs In the air sample by the volume, in liters, of air sampled and report'the FOB concentration In ng/llcer or Its equivalent In jtg/cu m. (b) Alternate Standardization Procedure The following are the steps In the calculation of concentrations of PCBs In air using the perehlorlnatlon method. (1) Theheight or area of the decachloroblphenyl peak in the chromatogram of the sample aliquot la compared to the height or area of the decachloroblphenyl peak In the chromatograms of the standard. The concentration of decachloroblphenyl in the sample aliquot la read from the standard c m me. (2) The concentration of decachloroblphenyl In this aliquot (ng/ml) is multiplied by the total volume (ml) of the sample solution to give the total weight of PCBs In the sample aa decachloroblphenyl. ir * Hii n . a A 206 U 03137 (3) The weights of PCBe, as decachlorobiphenyl, found on ~ the front and back sections of the tube are summed, corrections for blanks are made, and the total weight of PCB, as decachlorobiphenyl, In the air sample la calculated. (4) The total weight of PCB is divided by the volume of air sampled and the air concentration Is reported in ng/liter or Its equivalent in pg/cu m. 207 08138 u XI. APPENDIX III MATERIAL SAFETY DATA SHEET General intruetion for preparing a Material Safety Data Sheet (MSDS) are presented in this chapter. The examples used in the text are for illustrative purposes and are not Intended to apply to any specific compound or product. Applicable information about a specific product or material shall be supplied in the appropriate block of the MSDS. The product designation is inserted in the block In the upper left corner of the first page to facilitate filing and retrieval. Print in upper case letters as large as possible. It should be printed to reed upright with the sheet turned sldevays. The product designation is that name or code designation vhlch appears on the label, or by vhlch the product is sold or known by employees. The relative numerical hazard ratings and key statements are those determined by the guidelines in Chapter V, Part B, of the NIOSH publication, An Identification Syseem for Occupationally Hazardous Materials. The company Identification may be printed in the upper right corner if desired. (a) Section I. Product Identification The manufacturer's name, address, and regular and emergency telephone numbers (Including area code) are Inserted in the appropriate blocks of Section I. The company listed should be a source of detailed backup Information on the hazards of the material(s) covered by the MSDS. The listing of suppliers or wholesale distributors la discouraged. The trade name should be the product designation or cosnon name associated with the material. The synonyms are those cosnonly used for the product, especially fcOA0217 208 N 08139 formal chemical nomenclature. Every known chemical designation or competitor's trade name need not be listed. (b) Section II. Hazardous Ingredients The "materials" listed In Section II shall be those substances which are part of the hazardous product covered by the MSDS and Individually meet any of the criteria defining a hazardous material. Thus, one component of a multicomponent product might be listed because of its toxicity, another component because of Its flammability, while a third component could be Included both for Its toxicity and Its reactivity. Note that a MSDS for a single component product must have the name of the material repeated In this section to avoid giving the Impression that there are no hazardous Ingredients. Chemical substances should be listed according to their complete name derived from a recognized system of nomenclature. Where possible, avoid using con&on names and general class names such as "aromatic amine," "safety solvent," or "aliphatic hydrocarbon" when the specific name Is known. The "2" may be the approximate percentage by weight or volume (indicate basis) which each hazardous Ingredient of the mixture bears to the whole mixture. This may be Indicated as a range or maximum amount, is, "10-401 vol" or "102 max vt" to avoid disclosure of trade secrets. Toxic hasard data Shall be etated In terms of concentration, mode of exposure or test, and animal used, eg, "100 ppm LC50-rat," "25 mg/kg LD50skin-rabbit," "75 ppm LC man," ox "permissible exposure from 29 CFR 1910.1000," or, If not available, from other sources of publications such as the American Conference of Governmental Industrial Hygienists or the 209 ,.;N -o8-1,40 A00021& American National Standards Institute Inc* Flashpoint, shock sensitivity or similar descriptive data may be used to Indicate flammability, reactivity, or similar hazardous properties of the material. Cc) Section III. Physical Data The data la Section III should be for the total mixture and should Include the boiling point and melting point la degrees Fahrenheit (Celsius In parentheses); vapor pressure, la conventional millimeters of mercury (am Hg); vapor density of gas or vapor (air * 1); solubility In water, In parts/hundred parts of water by weight; specific gravity (water 1); percent volatiles (indicate if by weight or volume) at 70 degrees Fahrenheit (21.1 degrees Celsius); evaporetlon rate for liquids or sublimable solids, relative to butyl acetate; aad appearance and odor. These data are useful for the control of toxic substances. Boiling point, vapor' density, percent volatiles, vapor pressure, and evaporation are useful for designing proper ventilation equipment. This Information Is also useful for design and deployment of adequate fire and spill containment equipment. The appearance and odor may facilitate identification, of substances stored la Improperly marked containers, or when spilled. (d) Section IV. Fire aad Explosion Data , Section IV should contain c o l l a t e fire and explosion data for the product. Unlading flashpoint aad autolgnltlon temperature in degrees Fahrenheit (Celsius la parentheses); floanable limits, in percent by volume in air; suitable extinguishing media or materials; special firefighting procedures; and, unusual fire and explosion hasard information. If the product presents no fire hasard, insert "RO F H E HAZARD" on the line 210 1; K 08141 labeled "Extinguishing Media." (e) Section V. Health Hazard Information The '"Health Hazard Data" should be a combined eatmate of the hazard of the total product. This can be expressed as a TWA concentration, as a permissible exposure, or by some other indication of an acceptable limit. Other data are acceptable, such as lowest LD50, if multiple components are Involved. Under "Routes of Exposurecosstents in each category should reflect the potential hazard from absorption by the route in question. Comments should indicate the severity of the effect and the basis for the statement, if possible. The basis might be animal studies, analogy with similar products, or human experiences. Comments such as "yes" or "possible" are not helpful. Typical comments might be: Skin Contact-- single short contact, no adverse effects likely; prolonged or repeated contact, irritation, and cracking. Readily absorbed through the skin with severe systemic effects. Eye Contact-- some pain and mild transient irritation; no corneal scarring. ' v. "Emergency and First Aid Procedures" should be written in lay language and should primarily represent first-aid treatment that could be provided by paramedical personnel or individuals trained in first aid. Information In the "Notes to Physician" section should Include any special medleal information which would be of aaalatance to an attending physician including required or recomendad preplaeement and periodic medical examinations, diagnostic procedures, and medleal management of overexposed workers 211 ^ N. 08142 not (f) Section VI. Reactivity Data The comment in Section VI relate to safe storage and handling of hazardoust unstable substances. It is particularly Important to highlight instability or incompatibility -to common substances or circumstances such as vater, direct sunlight, steel or copper piping, acids, alkalies, etc. '"Hazardous Decomposition Products" shall Include those products released under fire conditions. It must also Include dangerous products produced by Aging, such as peroxides in the case of some ethers. Where applicable, shelf life should also be indicated. (g) Section VII. Spill or Leak Procedure Detailed procedures for cleanup and disposal should be listed with emphasis on precautions to be taken to protect vorkers assigned to cleanup detail.' Specific neutralizing chemicals or procedures should be described in detail. Disposal methods should be explicit Including proper labeling of containers holding residues and ultimate disposal methods such as "sanitary landfill," or "incineration" Warnings' such as "comply vith local, state, and federal antipollution ordinances" are proper but hot sufficient. Specific procedures should be identified. (h) Section VIII, Special Protection Information Section VIII requires specific information. Statements such as "Tee," "No-t" or "If Necessary" are not informative. Ventilation requirements should be specific as to type and preferred methods. Specify respirators as to type and NIOSH or US Bureau of Mines approval class, la, "Supplied air," "Organic vapor canister," "Suitable for dusts not more toxic than lead," ate. Protective equipment must be specified as to type and materials of construction. 212 K 03143 (I) Section IX* Special Precautions "Precautionary Statements" shall consist of the label statements selected for use on the container or placard. Additional Information on any aspect of safety or health not covered in other sections should be Inserted In Section IX* The lover block can contain references to published guides or In-house procedures for handling and storage. Department of Transportation markings and classifications and other freight, handling, or storage requirements and environmental controls can be noted. (J) Signature and Filing Finally, the name and address of the responsible person vho completed the MSDS and the date of completion are entered. This will facilitate correction of errors and Identify a source of additional Information. The MSDS shall be filed In a location readily accessible to workers potentially exposed to the hazardous material* The MSDS can be used as a training aid and basis for discussion during safety meetings and training of new employees* It should assist management by directing attention to the need for specific control engineering, work practices, and protective measures to ensure safe handling and use of the material. It will aid the safety and health staff In planning a safe and healthful work environment and In suggesting appropriate emergency procedures and sources of help In the event of harmful exposure of employees* A000992 213 ' *k ' 08 T 44 MATERIAL SAFETY DATA SHEET M ANUFACTURER'S NAME AOORES TRADE NAME SYNONYMS 1PRODUCT IDENTIFICATION R E G U LA R TELEPHONE NO. EM ERGEN CY TELEPHONE NO: li HAZARDOUS INGREDIENTS m a t e r ia l o r com ponent % MA1ARO OATA O ILIN G POINT. T O -- MO SPECIFIC GRAVITY IM jO -tt ' VAPOR DENSITY IA lR * tl % VOLATILES V VOL. APPEARANCE ANO OOOR A000223 III PHYSICAL DATA M ELTING POINT VAPOR PRESSURE SOttM M .IT Y (N MjO. % IY W T EVAPO RATIO N NATE (UTYL A C ETA TS*II zi* N 08145 215 t. OS 46 __________________ VI REACTIVITY DATA CONOITIONS CONTRIBUTING TO INSTABILITY INCOMBAI iSILITY HAZARDOUS DECOMPOSITION BRQQUCTS CONDITIONS CONTRIBUTING TO HAZARDOUS POLYMERIZATION ______________ VII SPILL OR LEAK PROCEDURES STEPS TO BE T A K E N IE M A T E R IA L IS R E L I AS EO OR SPILLED Y NEUTRALIZING CHEMICALS \f WASTE DISPOSAL MSTHOO ___________ Vili SPECIAL PROTECTION INFORMATION VENTILATION RSOUIREMBNTS specific p e r s o n a l p r o t e c t iv e co m ph ew t RESPIRATORY M E T M O STAIU EVE GLOVES OTHER CLOTMINO AN O EQUIEMENT *<- - n n i w flWl225 216 yV. N 08147 V-- IX SPECIAL PRECAUTIONS TRICAVTlO N AftV STATEMENTS OTHSft HANOCINC ANO STO N A C I ft EQUIN IM tN T S / .1 1\w"' Miwioav ao o n u s. 0 * T f. 217 MQ0226 l<: 8 4 y TABLE XII-l Lzzw m CHEMICAL AND PHYSICAL PROPERTIES OP SOME AROCLORS DlatIllation Density Flash Fire- Aroclor Chlorine, Range C g/nl point* Point* X v/tf (corrected) 25 C F F Appearance i 1221 20.5-215 275-320 1.18 286-302 349 Clear, mobile oil 1232 31.4-32.5 290-325 1.26 305-310 460 ii 1242 42 325-366 1.38 384-356 none** ii 1248 48 340-375 1.44 379-384 ti ii 1254 54 365-390 1.54 none** ii Llght-yellov vinous liquid 1260 60 385-420 1.62 ii ii Light-yellow soft, sticky resin 1262 62 390-425 1.64 u ii LlghC sticky, viscous resin 1268 68 435-450 1.82 ii ii White to off-white powder *Claveland Open Cup O **None to boiling point CO Adapted fro reference 1 VO t 4 TABLE XII-3 QUALITATIVE AND PERCENT CHLOROBIPHENYL AND BIPHENYL COMPOSITIONS OP COMMERCIAL PCB PREPARATIONS (Q ulltativaly Major pilit M, minor peaka m, amblfuoua Identltlee ?; quantitatively, percentage rounded) CL>8ubilltute<3 Poaltlona Commercial Preparation Dealfnation* (trade name* omitted) *h-i ro po qd Itti 1221 1221 1221 1232 1414 1242 1242 1242 1241 124 1254 1254 1254 AM 1214 IIH 1244 Ml M l DM 13 14 f 21 32 14 Hi 05 35 1 a 04 R m m am 1 3 3 4 14 m 20 2 mm n 04 >.4 4 i,s 2,4 tr 1 43l2 4.3 5m t2r 0.4 4m I <0.1 <01 tr 1 HI m HI HI <1.0 M R Rm m HI tj 3 m 2.4' 14 10 m 2m 11 m 1* 11 HI M <5 M ma 0.5 ft' m HI HI 3.4 1 3.5 tr in t ir ve 4,r 4 2.3,4 4m 1 4 2 R 1 <3 <3 RI m 2.3,S 2.3.4 2,2\3 lit 2.3.4* 81 m 5 HI bk MI ft mi 2.4.5 2.4.4 2.T.4 2.T.4 UC 2.r.4 43 m 42 4 m HI m 0.4 m 4 4 4 12 HHHHIIIi 11 M <15 M 7 M? 2M a R R R 4 <13 3 0.1 2.Y.5 2.4.5 2.2.4 42 02 9 m m 10 1 H I R MR- R R <13 RR 2.2.1 0.3 M? n R m m R IQ a m m 2.4.4 3.4.5 2.3.4 3.2.4 01 2 li n M. 16 M ft 21 m m 0.3 m m m 3.4.4' 2 M N 08.750 i i 0n02?9 220 N 0 8 1 5 1 TABLE XIM (Continued) QUALITATIVE AND PERCENT CHLOROBIPHENYL AND BIPHENYL COMPOSITIONS OF COMMERICAL PCB PREPARATIONS (Qualitatively ma|or pooka M, minor peaks - m, ambiguous identities T;quantitatively, percenlagea rounded) C|f8ubetltitled Poaltlouo Commercial Preparation Designations (trade names omitted) rxi in irj Uil mi UM irx* nr.i *.ur I.MS un ur,i *.rjM n.r.i uri tut IUI uri i.r.4.1 ir.u uri r,ui i.r.t.5 un rr.i.T irir i.r.iy i.r.ir iam uar.r i.r,(,r tr.r uir wir u,w irx v i.r.vv atti 1221 1221 12 M U 1242 - 1242 1242 1241 1241 1254 1254 1254 154 11(4 1244 12(0 t4 AU DM b b 3 4 M HT 42 <2 HT b HT nI 2 07 I <2 HT fe UT 414 b 1 I 1n 3m 0U.1 M 2 n 4 U 2 <04 4a 12 HT lfi m 1 mn HT U Hf m8M S 1 N h) O oc Cn Nd .O O 2.r.5' 1221 1221 1221 1221 1232 1HC 1242 1242 1242 1241 1241 12S4 1254 12S4 4M 1144 1240 1240 440 440 DK 2 j.r.ir 3 1 !>.* ir.u ' rjiur irr mu rus uns 2.ur.s 2.r . 1.4.1 uMn44i.4 22..3r..3T.S.S.4.4 2ni2U.r...Trrrl....3.34si..J,44u4lA..-rr 1.3. T.4.5* 2.r.3.r.5 122M..M.3\S4V\S r.M.s r.3S4 mu 12., rr.S.4m i.r.s.vi 12..3.3\4\4 r.iu uu2irr....m4rm.si.v.is- r.4.r.s 1.1 Ur2r...rr2'.,.4\443.s\444.5-.445- n 0.5 s H 24 U 4 <04 m 1 <16 IR 7 23J H IB m 1 m U 4 <4 S U2 RI 1 RI M m RI m .m m l U 3 03 n 14 y 4 2 y m RI m y a RI 3 3 m yim RI RI 2 RI H 2m M 1 mmy 7 y 1i 6 m 1 m 14 M S <16 m ? tr 8 H? I j TABLE XII-J (Continued) QUALITATIVE AND PERCENT CHLOROBIPHENYL AND BIPHENYL COMPOSITIONS OP COMMERCIAL PCB PREPARATIONS (Qualitatively major pooka M, minor pooka - -m. omblyuoua identltlaa - ?; quantUatively, percentayea rounded) 5. j . CL>8ubotltutad Poaltlono Commercial Preparation Dealynatlona (trade namea omitted) i I tti 21 1221 1221 1212 IIM 1242 1242 1242 1241 1211 12*4 12*4 12*4 Itt 1211 12M 11U U l 1122T...2XrU..4Vu.Mr 2XTXJS i.rx t.v 1r..2r.,2ys- i.r.t.r* 2UiT2.MU.U.SW.I M DK K M it2.tnM..i4it.*M.** 22222i....3,.3rrrr....3.,3)3i"..,..4r444..5..4,ri.Y,.rii Jr.4.4\S oo c cn LrJ 21222ii212..,.r....r3r333.,....i33iT."3Mr.r.4,.444-.v,4..55S,M'p..i.44rrrP.5.j.3.u.5.5M.u5iMpr t212t...3rX..33T\.44A..4r.\Ji**t"r .wm .i .r 2, r.3.4.4*.P m 0.1 <8 m 2 n ? HI l 12 M <*1 M2 M Mm U 2 2 11 m 3 m \ ) KJ K> o to; 1221 1221 1221 1221 1232 IMS 1242 1242 1242 1241 1241 12S4 12S4 1254 151 1240 1240 1240 460 440 ora inryy 3 M27222ji2r,.X.XrTrXr....X4.3J44443....r4X1.rr4M4'....v..tSS151.Vv.V?441ffV io m m <01 09 <16 .7 1 <15 4 m 4 M 4 <4 M m 13 m m 0.4 m OS 1 222rr.rr3...4r3r.r.rr...sv44t.rr4r 2XT.4.Sf 2r.jr.454 m OS 4 H RI 1 m ni in U2 Hn 1 mm irurn 22..3MX.444.V.5.l4f 1222m,M.Mrr..ixX.Tj444o...r4rS..vSs.sS.rvI.f*s.J.T.4.4.S 7izr..rJxu..risr.x4.x.r44\st5.i.uVsf in ir .i.t 1. r.u.r.ttr 00I.32 <<40 <1270 M U 0(i1 m m 0441.9 0t>.4 m mm m mIO 01 02 <20 0.4 7 ulTu.JrX.ry.S..i4 22rX.3jrX.Msv1f 22i22r...222.Mrr.2...j.*3jJ.r..J.4.Jr..rr.4J..4r444.44....V'.54v..Ss5.`V.sl.45s.i4.44r.ri44``.j.r.vs\i 0tf3 014 2 OIS 3 Odi 54 TABLE Xll-2(Continued) QUALITATIVE AND PERCENT CHLOROBIPHENYL AND BIPHENYL COMPOSITIONS OP COMMERCIAL PCB PREPARATIONS (Qualitatively major peaka M. minor peaka m, amhlifuoua identltiea T;quantitatively, percentage rounded) CL'Hiibatltuted Poalllone Commercial Preparation lleaignalionti (trade namea omitted) 1221 1221 1221 1221 1222 l i l t 1242 1242 1242 124 124 1254 12S4 1254 *5 I2M 12tl 12tO MO MO Oft M.r.t.r.irj irxr.ifxr 2.r.).r.4.rir tt.rrx.tMAAfX.vusr irir.4,s.tr irxrxrjur i.r.lU0ir t.ur.iUM.f MM,r.i.4\i5\t 2.r.3,r,4.r.s.JM.r Rrflftat Rt: 17 It * It * It 14 It 16 * 04 0tI(.rtt1 2. 5 i0mn1 a 04 m a0aUm1it 07 07 li 14 7 * 14 S 7 16 * fW lik t, attllN ttwamltaliM. Mmtrtii l7t K M P* 1 I I i Oi 4 030 *4 -- * 3*0 ccnn rn 7 LIVE WIRE Company Adopts PCS Policy The U. S. Environmental Protection Agency has notified the E 1ue.tric Utility Industry that a group of chemicals known as ?>1/chlorinated biphenyls (PCB's) represents a potential hazard to the environment.and to human health. The Toxic Substance control act required the promulgation of rules prescribing marking and disposal requirements for PCB's. ike rules were promulgated with~3TV effective dace of April 18, 1973. The intent of the regulations are to protect the environment roni further contamination by PCB's resulting from improper nn d l i n g and disposal. >!c Ryan has stated that, "Nevada Power Company is committed to :i bilance of conservation and utilization of our natural re sources and to ensure an adequate energy supply to the customers within our service area. Our environmental policies recognize m a : cc achieve this goal 9Jjr facilities and operations must o? conducted and operated within environmental requirements". PCB's^are sometimes found as an additive in insulating fluids, fouadgin some capacitors and indoor transformers. During manuracture PCB's are intentionally added to transformers.and ca pacitors because PCB's can reduce the likelihood of fire in MSSJ N .0 661 3 000233 L Iva w Ire Na vuir.ber L9 / " r ij 2 . ' * The: regulations prescribe the approved methods of disposal when PCB's .-re taken from .service and requirements for facilities used for the storage of P C 3 's prior to their disposal. In addition to PC3-containing transformers and capacitors the law also applies to PCB articles, article containers, chemical substances, containers, equipment, and mixtures, all of which arc defined in the regulation. The regulation does not require that PCB's be removed from ser vice earlier than would normally occur, but their eventual dis posal must be in accordance with the requirements of the law. Currently, all company nonliquid waste is disposed of at a chem ical landfill near Beacty, Nevada. PCB's are among the most stable compounds known. Their chemical stability, low volatility, high dielectric constant, and com patibility with other hydrocarbons have contributed to their extensive use as dielectric and'heat transfer fluids, as in cap- A acitors and transformers. ^ . The threat of PCB's to the environment was only recently acknowledgeft. the danger arises from their chronic toxicity, their per vnsililfisess and persistance in the environment, and their-tendency :o accumulate in food chains. PCB's have been found in signifi cant concentrations in. waterways and sediments throughout the world, and have recently been found in the milk of nursing mother in majiy areas of ttfe United States. 1! 0681 4 Anonzfti Live Wire November, 1979 Page 3 In view of Che potencial health effects of exposure to employees and che public, the Safety Department has been charged with the .responsibility of developing, handling, and disposal procedures; also, employee and public education programs. In addition to employee training programs for affected depart ments such as Lines, Substation, and Warehouse personnel, much interest has been shown by certain .segments of the public and agencies. The Safety Department has developed a public presenta tion and information service for these groups. Special slide presentations have been made to the Public Service Commission and area fine departments. Within the company a Control and Handling Procedures manual has been prepared and distributed to .ill affected departments. Because the PCB liquids are found in Line, Substation capacitors, and indoor transformers the Line and Substation Departments are the most affected. f r-. r' A continuing education program has' been implemented to ensure hn:: all employees occupationally exposed to PCB's have current knowledge o f job hazards, proper maintenance and cleanup me- .nods, and proper use of protective clothing and equipment, Including respirators. N. 0681 5 40fl02r?5 U MEMORANDUM TO; FROM: DJSDCBDahiaahaclenvalvklerbeJlCyCiaOreBmrodVauteSe.trm'ltaisnlle,lewib&aLyrrhi.tns- 'es Dept. DATE: A)/-' f-fr j ; r, A F E T 'f Rickie Slate u r<L SUBJECT: ^. May 29, 19 78 MMewa rkPiCn gB RDeicsupiorseaml eanntds wbOtAiDmvpFrnheeioenhitgaacgvtsdetreuaeuiP,nkePcsndlaariihCadn"oPagnteoeBTngldieCdfro,shtBRnod7aaeisn1'sEin(ekssspd5lgeePvpado7inaAoodslrrilytosi,ieneeaescanfgtfprhlatRuftroaelnheleeeoscsreacmgearacEttiicrliofFonoPlotrurviineaoAonsdoeetdfmsaenrIdaeXtdnandrrtdCc,pfadohabeerlplaniloycnrPnpiswdmoRonoChfenvtiweeoetBceagshnorrBedteimueyi,rscrtnqllnhtmevodsgueEierni)narics.snltrtnglaeeoheesniaernAernanermsr,icenedrleentws,adgmigDolourrldeoenlrieeyiarlefivqqnaesftgaabuuceitpctuoleelciitotulprdntaosaoeidtmscrevthfme.eh,ideeedoqPe!enlnudECocintismifasntBp,imssfmtmca.'eoudosie.erssincdcnsftoTceitrpspHaehombotyrtceaemoseneotswaloinedneylnfesdtit.gvesamthiernuer,s t ttCvcsc1oheaea9oerhp7pbnv8iaaecFci.ccecelilireedtatnsAoobeiPrrlercnlssaClag,elirBadnrtraRyh-entbesierdynegarlrgineanJvsqabsetiPwnfeuecColurieirrBeanemsqrtg'dtrysueaaoitrtnpa1foes,srm-s,eefb,eqo1eanu"9rrntAeiml7dpaq9lwebmlu.nrie^ietcsolrhne,oetdt-ndsiitmcnbnato-oy-iansnslebtJleeaurerrivPlsvnyliCiiacocnBbe1fege, PlcllPea1CaadCr9rpBg7gBabe8ecsel.ii,ghhqtiioiunAgPgrinhhsaldilgsnvva,etgoorrlealn7tOtna1oacrg5stget-1peeoiqonbuor-efit r r e 1, d oaPMnflrdet.ahcseEoelmelxsepttrluey'ndstywltietoththetwethrrh.eiecgshueIlftahrtteehi ogernureeslgautacilrooaenntcisaoe.nnrynsIinpawgrpoiplblllaylwbeetmroliistnNe, gPtpCoalneEdaasPsdeAi"sucpaarnoglldse.adil"n fcioanrrme futlhleym RS/mh Ri/c/k^i.ec Salat e ..C- r A00TCK16 ** DEFENDANT? EXHIBIT U-U-a Xa x . \t\u\Vi j v r Survey shows blacks' PCBs(J13-- l,iis Review ~J<n 1-- Monday May 7. 1979 double those of wi * Newsdav WASHINGTON -- A naiiona) health survey shows that black Americans have twice as m u c h of the dangerous chemical com p o u n d s called P C B s in their bodies as whites. T h e survey, conducted by the Environmental Pro tection A g e n c y , is not yet published. But Dr. Freder ick W . K u tz , w h o is in charge of the EPA's nation al monitoring p r og r a m for pesticide residues in h u m a n beings, told N e w s d a y that the results are "absolutely a representative sample" of the U.S. population as a whole. " W e don't know why," K u t z of the finding. " W e just k n o w it's o c c u r ring." T h e survey results, based on a weighted population sample of 10,000 persons by * census tract across the country, show that blacks have an average of about four parts per million of PCBs, or polychlorinated biphenyls, stored in their, bodies, c o mp a r e d to tvro parts per million in whitie& Although those s e e m like small amounts, the c o m pounds aTe considered bo dangerous in both shorta n d long-term effects on h u m a n beings -- concentra tions as low as 10 parts per million can have harmful effects -- that the E P A' s findings have caused a ^ strong rent lion a m o n g b l a c k p o l i t i c a l l e a d e r s a n d m e m b e r s o f 11 it h e a l t h c o m munity. 'These were some i m m e diate reactions to a request from N e w s d a y for c o m m e n t on the findings: -- The Congressional Black Caucus designated Hep. -Barren J. Mitchell, D Md., to press the environ mental agency for answers on what should be done "to reduce high levels in blacks and the poor and to deter mine what long-range m e a s u r e s o u g h t to b e initi ated to prevent overexpo sure of poor, blacks and m i norities" to PCBs. -- N e w York State Health Commissioner D a vid Axelrod said his office will test milk samples ready collected from nurs-** ing m o t h e r s to d e t e r m i n e if there is a racial stratifica tion in P C B levels. Axelrod also called on the E P A to perform or fund studies to determine the cause of high levels of the chemical in blacks. H e expressed a "concern with infants par ticularly (because) an in fant can get a very strong dose of this c o m p o u n d from his mother." -- Medical leaders in both the National Association for the A d va n c e me n t of Colored People a n d the all black National Medical A s sociation expressed con cern. "1 a m going to present this to our health c o m m i t tee," said Dr. Sylvester D a vis, c h a i r m a n o f N A A C P 's medical arm. " W e will look into the situation and m a k e any directed action which seems warranted." N M A President Jesse Barber, a neurosurgeon at H o w a r d University Hospital, said his organization would in vestigate the EPA's find ings to "see if there is a n y thing we can do both from a scientific a n d a political point of view." While the scientists as yet have no explanation for the difference between P C B levels in blacks and whites, they speculate that differ ences in diet, genetics or life-style, a m o n g other fac tors, might be responsible. A n earlier study showing greater concentrations of the pesticide D D T in blacks than in whites w a s later at tributed to a difference in e x p o s u r e arising f r o m life style factor. T h t pi vi ie l evel at which P C B concentrations are hazardous to h u m a n b e i n g s is unknown, b u t a c cording to a -Justice D e p a r t ment complaint m a recent case . " I T K - .tic i'i.ur, c a rc i n o g e n i c and t h e e b i o a c c u mulate. At concentrations between 10 parts per mil lion and SG0 p a n s per mil lion, they cause .various harmful reactions in labora tory animals, including skin lesions, liver d a mage, kid ney m a l f u n c t i o n , u l c e r a t i o n of the stomach and repro ductive failure; at levels greater than 80u parts per million death occurs in lab oratory animals " Because of the serious health hazards posed by PCBs, the Food and Drug Administration has estab lished very low tolerances for P C B s in food items. A n y items that exceed these to lerances are removed from the market. A m o n g the items for which levels were established are eggs (0.5 part per million); dairy products (2.5 parts per mil lion) a n d animal feed (0.2 part per million). Because P C B s are stored.in fatty tis sue, only fish a n d poultry, w h i c h h a v e v e r y little fat, are permitted higher con centrations; they m a y con tain up to five parts per mil lion. Efforts b y black political fire a n d it w o u l d n ' t d e grade," even in acid, accord leaders in the health area have focused on problems such as providing minority health care and service, but the P C B study drew i m m e diate reactions: "This area has been neglected and not concentrated on by the black community/' said Rep. Louis Stokes, D-Ohio, chairman of the Black Cau cus brain trust on health af fairs. A n o t h e r m e m b e r , D r . , N a t h a n i e l Revis, said h e .: would recommend "that E P A or F D A further those studies b y determining the effects of these high concern ^trations on disease process es -- ifthere is a h i gh e r inci- denee of birth defects, tumors an d liver disorders/' Harold Snyder, P C B re gulation team leader at the environmental agency, said, ' `T h e h u m a n h e a l t h h a z ards are obvious, P C B s are very persistent materials. T h e y are a suspected carci nogen. W e k now they are associated with certain liver disorders." B u t h u m a n evid e n c e is slight a n d deals primarily w i t h J a p a n , w h e r e 1,857, P C B poisoning cases havebeen recorded since 1968/: f r o m rice oil containing 80fll t o 1 , 0 0 0 p a r t s p e r m i l l i o n of PCBs. Victims exhibited nervous disorders, hearing T h e evidence of the ef fects of P C B s on other f o r m s o f life, h o w e v e r , h a s been documented over a broad range of species. Al t h o u g h it is n o t k n o w n w h a t the potential effects of four parts per million will be in blac k citizens, it is k n o w n it takes only 8.5 part per bil lion of P C B to k W salmon eggs. Pinfish, spot and other p a n - s N c d r; a r e killed a t I f i v e p?,: *js '.ci billion. \i only 10 parts per bil lion or less, P C B s cause high mortality rates in A t lantic blue crabs, pink s h r i m p a n d oysters. T h e list goes on to include reproduc tive defects and other a b normalities in rats, chick ens, and similar higher animal forms. A s a result of those findings, Congress, in the Toxic Substances C o n trol Ac t of 1976, ordered an end to the manufacture er sale of P C Bs , effective this summer. I But that does not m e a n the p r ob l e m will go away. ' The man-made compound it s o s t a b l e t h a t it i s a l m o s t indestructible. It w a s devel opedf o r h e a t c o n t r o l w i t h i n electrical systems. "It w a s super f o r t h i s p u r p o s e b e cause it w o u l d n ' t b u r n b y ing to E P A' s Snyder. A n d for that very reason, he said, " W e are looking at the fact that n o w they are going to be around for 100 years or more" in the environ ment. T h e E P A estimates the total load of PCB.* already dispersed in the U.S. envi r o nm e n t at 150 million p o u n d s ; a n a d d i t i o n a l 2 U0 million p o u n d s is buried in municipal landfills a nd 758 million more are currently in commercial use in power transformers and other electrical equipment such as air conditioners, micro- wave ovens and T V > Al t h o u g h E P A h U* l i o n s t o r o n t r u ! i l i s p w t,| ,>l m o s t ot the P C B s ijfw in c o m n u - u i u l n.-e. it l i i i m - a control disposal of snnllei i t e m s s u c h a s T V set.- S n v dersaid. T h e result is that s o m e thing o n the order of JVh> muli->i> I'l'inal- **} p i ' h . , o 4 p w :<-.l t o r e m a i n : ;'ir **U\ U Y .m u i M U ioi v V n t u M . A n ) the --.np o u n d , a* .* t!'- j i e i .1 in w a t e r ; . n n . cl. l e n d - u, m o v e high., | o p the lnu({ <h a m m human loss, visual impairment, birth defects and severe T h e E P A r u n o t u h ha.no plan.- to allocate hinds skin problems. i-;i ^ u . i v i m : t h e P C B p h o iw:r.riii'ii. tXf'-;; a c o o p erative elioir with the P u b lic H e a l t h Seiv t v e in looking im*> muntiuiuti clfccr.s o n a b r o a d range of di seases, which might discov er a link b e tw e e n liver d a m a g e and P C B levels w*ithin the 7.00'J people in volved in that study."_ _ _ ' A000238 \ 'Sr N 03190 oEPA iojcic buDffnr-a TS-7^9 WnnjTc C 20*60 ju n * 1979 Toxic Subitanan EPA's Final PCB Ban Rule: : Over 100 Questions 8* Answers , To Help You Meet These Requirements INTRODUCTION On May 31, 1979 in the Federal Register (44 FR 31514) the U.S. Environmental Protection Agency published the Final Rule for Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution in Commerce, and U s e .Prohibitions. This Booklet* in a non-technical manner, deals with the Rule's coverage and requirements. Its question-and-answer format is categorized into the following 18 areas. Q&A Category Questions I Introductory I n f o r m a t i o n ........ .. ^ . 1-8 General Ruie Provisions............... . 9-21 Import/Expiort ......... ................. i Transformers ................. . . . . . 22-23 24-40 Railroad Transformers .................. 41-49 Capacitors ................. 50-54 Mining Equipment . . 55-60 Hydraulic Systems . . . . . . . . . . . 61-65 Heat Transfer Systems .................. 66-67 Other PCB U s e s ............ 68-75 Labeling . . . . . . . ................. 76-83 Testing ................................. 84-86 Storage . . . . . . .................... 87-95 S p i l l s .................................. 96-99 Recordkeeping . . . .................... 100-104 Disposal ...................... 105-119 . PCBs in the W o r k p l a c e .....................120-125 Contacts for Information . ............. 126-127 ^Thls Booklet has been prepared by the Industry Assistance Office within EPA's Office of Toxic Substances. It is an informal document^ and persons are directed to the PCB Final Rule for specific legal requirements. -1 - N id"I 7 o inks, iubrica .5, carbonless copy paper, and sealants, coatings, and dust control agents. Most of the PCBs marketed in the United States are still in service, primarily" in electrical equipment. (6) WHY ARE PCBs HARMFUL TO HUMAN HEALTH AND THE ENVIRONMENT? PCBs are harmful because once released into the environment they do not break apart into new chemical arrangements, instead they bioaccumulate in organisms throughout the environment. In addition, PCBs biomagnify in the food chain -- that is, they ac cumulate in the tissues of living organisms and .as they move up the food chain towards man their concentration increases. These facts are significant because PCBs have been shown to cause chronic (long-term) toxic effects in many species even when the exposured to very low concentrations. (7) WHAT ARE THE KNOWN HEALTH EFFECTS OF PCBs? There are well documented tests which show PCBs cause, among other things, reproductive failures, gastric disorders, skin lesions, and tumors in laboratory animals. Studies of workers exposed to PCBs have shown a number of symptoms and adverse effects including, but not limited to, chloracne and other epidermal disorders, digestive disturbances, jaundice, impotence, throat and respiratory irritations, and severe headaches. (8) WHAT ACTION HAS EPA TAKEN AGAINST PCBs? In 1976, Congress enacted the Toxic Substances Control Act (TSCA). Section 6(e) of this law requires EPA to establish rules to: (1) govern the disposal and marking of PCBs; and (2) pro hibit, with certain exceptions, the manufacture, processing, distribution in commerce, and non-totally_enclosed use of PCBs. 7 Final Marking and Disposal Rules appeared in the Federal Register on February 17, 1978 (clarifying amendments to this Rule appeared in the August 2, 1978 Federal Register). On June 7, 1978, the Proposed PCB Ban Rule was published in the Federal Register. The Final PCB Ban Rule appeared in the Federal Register on May 31, 1979; this Rule supersedes the February 17, 1978 PCB regulation and takes effect on July 2, 1979. A000241 N 2 i l 'y 6 o one million ;-jitional pounds of existing -PCBs will be con trolled, as well as 100,000 to 500,000 pounds per year of new PCBs, (11) IS THERE ANYTHING WHICH CONTAINS LESS THAN 50 PPM PCBs WHICH IS BANNED FROM BEING USED UNDER THIS RULE? Yes, waste oil containing any detectable concentration of PCBs is forbidden from being used as a sealant, coating, or dust control agent. To permit the use of waste oil with any PCBcontamination to be used in road oiling, pipe coating, or vege tation spraying would cause PCBs to directly enter the air and waterways, which could introduce' them into the food chain. (12) WHAT IS THE DIFFERENCE BETWEEN "MANUFACTURING OF PCBs" A N D "PROCESSING OF PCBs"? The actual creation of the chemical substance PCB, or a substance contaminated with PCBs (e.g., PCBs as an impurity), is the "manufacturing of PCBs". The production of PCB Articles and PCB Equipment is con sidered "processing of PCBs", and involves the use of existing PCBs. Processing PCBs includes such activities as placing man ufactured PCBs into capacitors or transformers. (13) WHAT IS CONSIDERED A PCB ARTICLE? PCB EQUIPMENT? PCB ITEM? An article whose surface is directly contacted by PCBs is considered a "PCB Article". Examples include capacitors, trans formers, electric motors, pumps, and pipes. Equipment whose surface is not directly contacted by PCBs, but contains a PCB article, is considered "PCB Equipment". Ex amples include televisions, air conditioners, microwave ovens, electronic equipment, and fluorescent light ballasts and fix tures. "PCB Item" is a collective term used throughout the Rule to refer to PCB Equipment/Articles/Containers/Article Containers. (14) WHAT EFFECT DOES THE PCB BAN RULE HAVE ON PCB ARTICLES? PCB EQUIPMENT? After July 2, 1979, PCB Articles can no longer be produced because the production is not totally enclosed. However, since -5- A001242 Nil 2960 p i *< ( 1 7 ) THE BAN RULE PROHIBITS THE USE OF PCBs EXCEPT IN A "TOTALL ENCLOSED MANNER". WHAT IS MEANT BY "TOTALLY ENCLOSED M A N N "Totally enclosed manner" is a term which Congress wrote into TSCA's Section 6(e) and refers to PCBs contained in a way that does not permit any detectable exposure to PCBs. Examples of totally enclosed PCB uses, allowed to continue after July 2, 1979, are found in television sets, air condi tioners, and microwave ovens. These items contain PCB components (such as PCB capacitors) but their normal continued use will not result in any exposure to human beings or their surroundings. (18) THE B A N RULE SAYS THAT EPA CAN GRANT EXCEPTIONS, KNOWN AS AUTHORIZATIONS, TO ENABLE THE CONTINUED MANUFACTURING, PROCESSING, DISTRIBUTION IN COMMERCE, OR USE OF PCBs IN A NON-TOTALLY ENCLOSED MANNER AFTER JULY 2, 1979. HOW C A N I GET AN AUTHORIZATION? HAS EPA ALREADY GRANTED SOME? EPA may propose and grant an authorization without a spe cific requestfrom those who will benefit from.the authori zation. Also, the authorization can be valid for any time period that EPA finds appropriate. The following non-totally enclosed PCB activities have al ready been authorized by EPA (beside each is the Rule section to refer to for details): o servicing PCB Transformers and PCB-Contaminated Transformers (Sec. 761.31(a)); o use in and servicing of Railroad Transformers (Sec. 761.31(b)); o use in and servicing of Mining Equipment (Sec. 761.31(c)); o use in Heat Transfer Systems (Sec. 761.31(d)); o use in Hydraulic Systems (Sec. 761.31(e)); o use in Carbonless Copy Paper (Sec. 761.31(f)); 1 us ojPigments (Sec. 761.31(g)); o servicing Electromagnets (Sec. 761.31(h)); o use in Natural Gas Pipeline Compressors (Sec. 761.31 (i)); - 7 - A000243 N 12 9 7u IMPORT/SXPORT (22) CAN PCBs (THE CHEMICAL ITSELF) BE IMPORTED. OR EXPORTED AFTER THE BAN RULE'S JULY 2, 1979 EFFECTIVE DATE? WHAT ABOUT PCB EQUIPMENT (TELEVISION SETS, MICROWAVE OVENS, ETC.) WHICH CAN CONTINUE TO BE DOMESTICALLY PRODUCED UNTIL JULY 1, 1979, HOW LONG CAN THEY CONTINUE TO BE IMPORTED AND EXPORTED? Because TSCA considers the term "import" to be synonomous with "manufacture", no PCBs (except waste) can be imported or exported after July 2, 1979, unless an exemption is obtained from EPA. Furthermore, it was the intent of Congress to have this Rule treat domestic and foreign PCB production equally. Therefore, PCB Equipment can be imported and exported until July 1, 1979. After July 1, 1979, an exemption must be obtained from EPA in order to continue this activity. (23) EPA HAS DECIDED TO ADOPT AN OPEN BORDER POLICY WITH RESPECT TO THE DISPOSAL OF PCBs. WHAT DOES THAT MEAN? The PCB Ban Rule allows for PCB wastes to be either imported or exported for disposal for one year -- until May 1, 1980. All imported PCB wastes must be disposed of in accordance with Sub part B of the Final Rule. Persons exporting PCB wastes for dis posal are to notify EPA at least 30 days before the first export shipment; quarterly reports of actual shipments are also required. EPA believes that the adoption of this open border policy for PCB waste disposal will be advantageous to both the U.S. and foreign countries, especially Canada. Generators of PCB wastes will be able to select the PCB disposal site that offers the most reasonable transportation and disposal costs. The open border policy will be in effect for almost one year, at which time EPA will examine the progress made by other nations in establishing and operating safe PCB disposal sites. The Agency will also at this time determine if extension of the open border policy is appropriate. -9- Nd i2 9 7 2 .requirements separately; the other 3 categories are discussed simultaneously.)' (27) HOW DO I DETERMINE WHICH OF THE FOUR TRANSFORMER CATEGORIES I HAVE? A transformer must be assumed to be a PCB Transformer if: (1) the nameplate indicates that the transformer contains PCB dielectric fluid; (2) the owner or operator has any reason to believe that the transformer contains PCB dielectric fluid; or (3) the transformer's dielectric fluid has .been tested and found to contain 500 ppm or greater PCB. If a transformer does not have a nameplate or there isn't any information to indicate the type of dielectric fluid in it, the transformer must be assumed to be a PCB Transformer. If a transformer is tested and found to contain less than 500 ppm PCB, it will then fall into one of the other appropriate categories. A transformer can be reclassified as a Non-PCB Transformer if its dielectric fluid has been tested or otherwise verified to contain less than 50 ppm PCB. Testing Transformers in order to classify them as Non-PCB Transformers does not significantly Change the actions required by the Rule. If your transformers are proven Non-PCB Transformers you should take precautions to see that they aren't later contaminated during servicing with PCB fluid over 50 ppm. (28) WHY SHOULD I ASSUME THAT MY MINERAL OIL TRANSFORMER IS A PCB-CONTAMINATED TRANSFORMER? IF I GO TO THE EXTRA TROUBLE AND EXPENSE TO TEST MY TRANSFORMER IN ORDER TO CLASSIFY IT AS A NON-PCB TRANSFORMER, WHY WON'T MY REQUIREMENTS UNDER THE RULE BECOME SIGNIFICANTLY SIMPLER? Current data shows that 25-40% of the existing mineral oil transformers are contaminated with 50 ppm or more of PCBs. No clear pattern exists to explain why one transformer is contaminated and another one is significantly less contami nated. This means that testing all transformers would be necessary in order to be certain about the appropriate cate gory. This would be extremely expensive. Therefore, the requirements in the Rule for servicing, disposal, labeling, and use have been designed to make this testing step largely unnec essary. The only servicing restriction on PCB-Contaminated Trans formers is that companies servicing transformers owned by others and who sell PCB-contaminated mineral oil to their customers must \ A000245 Ni- 1 1 l 2974 use of most 'xisting transformers throughout their lifetime. -PA has decided that this' activity doesn't present an unreasonable risk to human health and the environment. However, any servicing (including rebuilding) of pcb Trans formers that involves removing the coils from the casing is prohibited by the Ban Rule. Removing the coils substantially increases PCB exposure, therefore, EPA concludes this servicing to be an unreasonable risk, EPA believes the cost of this pro hibition (about $14 million the first year and steadily less each year after) is justified by the increased risks which would other wise occur to human health and the environment. (32) CAN X REBUILD MY TRANSFORMERS? Rebuilding a transformer would involve one or more of the following: draining the transformer, removing and disassembling the core, reworking the coil or rewinding a new coil, reassem bling the core, and refilling the. transformer with new fluid. EPA permits .the rebuilding only of PCB-Contaminated Trans formers (containing between'50 ppm and 500 ppm PCB), and, of course, Non-PCB Transformers. If your transformer is classified as a PCB Transformer (containing 500 ppm or greater PCB), it cannot be rebuilt unless it is first reclassified to a PCBContaminated Transformer. EPA decided to permit rebuilding of PCB-Contaminated Trans formers, because the exposure to PCB is relatively low and the economic impact of not permitting this activity would be very high. (33) CAN I SERVICE MY OWN TRANSFORMERS? EPA has decided to authorize this activity, which is con sidered, use, for persons who service their own transformers until July 1, 1984. (34) CAN I HAVE A SERVICE SHOP WORK ON MY TRANSFORMER? Yes, you can have work done on your transformer without receiving an exemption from EPA provided the shop does not add any PCB fluid. If PCB fluid (50 ppm PCB or greater) needs to be added, the shop can add your fluid without obtaining an exemp tion. However, if the service shop adds their PCB fluid to your transformer, they must get an exemption to do so after July 1,' 1979. A000246 MH r 2 s; 7 6 able to use a Railroad Transformer containing greater than 1,000 ppm PCB after July 1, 1984. (45) DO I HAVE TO TEST MY RAILROAD TRANSFORMER? You will have to test your Railroad Transformers immediately after any PCB concentration reduction related servicing^*,e (46) HOW OFTEN DO I HAVE TO TEST MY RAILROAD TRANSFORMER? It is necessary to test your Railroad Transformer immed iately after it has been serviced to reduce the PCB concentra tions in order to verify the new PCB concentration. In addition, between 12 and 24 months after such servicing the transformer is to be tested again to gauge the PCB concentration level. (47) ARE THERE RESTRICTIONS ON WHAT I PUT IN MY RAILROAD TRANSFORMER? Yes, there are restrictions. If you rebuild (remove the coil) the Transformer after January 1, 1982 it cannot be refilled1 with dielectric fluid containing a PCB concentration greater than 50 ppm. After January 1, 1982, Railroad Transformers may only be serviced with dielectric fluid containing less than 60,000 ppm PCB. Finally, after January 1, 1984, Railroad Transformers may only be serviced with dielectric fluid containing less than 1000 ppm. (48) WHAT KIND OF SERVICING CAN BE DONE ON RAILROAD TRANSFORMERS? Any kind of servicing can be done on Railroad Transformers until January 1, 1982. After that time, the transformer can be rebuilt only if it is to be refilled with dielectric fluid containing less than 50 ppm PCB. Starting on January 1, 1982 transformers may only be serviced with dielectric fluid contain ing less than 60,000 ppm PCB (except when it has been rebuilt). After January 1, 1984, Railroad Transformers may only be serviced with dielectric fluid containing less than 1000 ppm PCB (except when it has been rebuilt). After July 1, 1979, processing and distribution in commerce of PC3s in order to service Railroad Transformers can be con ducted only by those persons granted an exemption. - 16- Hi12979 A0 0 0 2 4 7 (49) CAN I REBUILD MY RAILROAD TRANSFORMER? Before January 1, 1982 you can rebuild your Railroad Transformer with PCB dielectric fluid. After January 1, 1982, any rebuilt Railroad Transformers must not contain dielectric* fluid with a PCB concentration greater than 50 ppm. CAPACITORS (50) HOW DO THESE RULES AFFECT CAPACITORS? CAN I CONTINUE TO USE MY PCB CAPACITORS? Yes, you can continue to use your PCB capacitors for their useful life. The primary effect of the new prohibition rules is to terminate the manufacture of any new PCB capacitors. (51) WHAT ABOUT THE DISPOSAL OF PCB CAPACITORS? These rules continue the provisions of the PCB Disposal and Marking Rule published in the February 17, 1978 Federal Register. Large PCB capacitors must be disposed of in an EPA approved chem ical waste landfill or incinerator. After January 1, 1980 all large PCB capacitors will have to be incinerated in special EPA approved incinerators. Special disposal is not required for small capacitors -except those waste capacitors owned by PCB capacitor or PCB equipment producers. (52) WHAT IS THE DIFFERENCE BETWEEN LARGE AND SMALL CAPACITORS? Small capacitors have less than 3 pounds of contained d ielectric fluid; large capacitors have 3 pounds or more of dielectr ic fluid. (53) I HAVE PCB CAPACITORS THAT ARE TEMPORARILY OUT OF SERVICE; CAN THEY BE PUT BACK INTO SERVICE? Yes, but they- will be subject to disposal requirements at a later date. A000248 !^ -17- Mpid1 'iI '< C y uA T.1 T -W ; (59) CAN I SCRAP THESE MACHINES? Yes, but first the PCB motors must be removed and properly disposed. PCB motors can either be incinerated or, after drain ing the PCBs, placed in a chemical waste landfill. (60) HOW LONG CAN I USE THESE MACHINES? PCBs cannot be used in mining equipment after January I, 1982. HYDRAULIC SYSTEMS (61) DO ALL HYDRAULIC SYSTEMS HAVE PCBs IN THEM? Probably not. PCB hydraulic fluid was developed for use in machines that were subject to high temperatures, such as aluminum die casting machines and hydraulic machines in steel mills. Be cause of their low flammability, PCBs provide an extra measure of fire protection. The use of these high concentration fluids was discontinued several years ago by most users, because of serious water pollution problems. However, residues of the original fluid remain in sufficient quantities to be of continuing envi ronmental concern. In addition, it is possible that hydraulic systems on other machines that did not pose any special fire risk also had these* PCB fluids added to them. These may be sufficiently contaminated to require action under these regulations. (62) CAN THESE PCB CONTAMINATED HYDRAULIC SYSTEMS CONTINUE TO BE USED? IS ANY CORRECTIVE ACTION NECESSARY? These PCB contaminated systems can be used until July 1, 1984, provided that a corrective program of testing, draining, refilling, and/or topping-off is undertaken. (63) HOW OFTEN MUST I TEST MY HYDRAULIC SYSTEM? Any hydraulic system that ever contained PCB hydraulic fluid must be tested by November 1, 1979, and, at least annually there after, until the system reaches 50 ppm PCB. A000249 (69) CAN PC NTINCJE TO BE USED IN SMALL QUANTITIES FOR RESEARC.-: v-iND DEVELOPMENT? Yes, until July 1, 1984. As with microscopic slides, EPA will decide later whether to extend the authorized time for use. (70) IN THE EARLY 1970's CARBONLESS COPY PAPER WAS MADE WITH INK CONTAINING PCBs. WHAT PROVISIONS DOES THE PCB BAN RULE MAKE FOR THIS PAPER? Although carbonless copy paper is no longer made with PCBs, supplies of this paperstock still exists; most are in files. Because the amount of PCB on each sheet is extreme'ly small and no inexpensive method of separating PCB from non-PCB carbonless pa per has been developed, EPA has authorized the use of existing PCB carbonless copy paper indefinitely. (71) SOME PIGMENTS CONTAIN PCBs, CAN THEY CONTINUE TO BE USED? EPA's PCB Ban Rule authorizes the use of diarylide and pthalocyanine pigments, containing PCBs as an impurity in con centrations ranging from several thousand parts per million to 50 .ppm, until January 1, 1982, However, after July 2, 1979, these pigments, containing greater than 50 ppm PCB, cannot be manufactured, and they cannot be processed or distributed in commerce after July 1, 1979, unless EPA grants exemptions for these activities. (72) OTHER CHEMICALS ALSO CONTAIN PCBs IN LOW CONCENTRATIONS, CAN THEY CONTINUE TO BE USED? At this time, EPA's B a n `Rule does not authorize the use of any other chemicals containing PCBs. Several manufacturers have requested exemptions to manufacture chemicals with low concen trations of PCBs, and, if these exemptions are granted, EPA will consider appropriate authorizations to permit the use of the chemicals. (73) IF SOMEONE MANUFACTURERS PCB CONTAMINATED CHEMICALS BUT DID NOT APPLY TO EPA FOR AN EXEMPTION CAN THEY STILL REQUEST ONE? Anyone in that situation should apply to EPA for an exemption using the procedures EPA published in the Federal Register on November 1, 1978. (See the "Contacts for Infor- A000250 -21 N S 1 2 9 2 *1 extremely (approximately $10 for eacn of the 35 million trans formers). An unmarked transformer is automatically assumed to be a PCB-Contaminated Transformer. However, if a transformer has no nameplate information but there is a reasonable suspicion that PCBs may be present above 500 ppm --- the transformer should be labeled as a PCB Transformer until the PCB content can be verified. (78) WHERE DO I HAVE TO PUT THE LABELS? All labels (or marks) are to be put on the exterior of PC3 Items and transport vehicles in a place that they can be easily seen and read by anyone inspecting or servicing them. (79) THERE ARE A LOT OF PCB CAPACITORS AND EQUIPMENT CONTAINING THESE CAPACITORS IN USE. DO THEY ALL HAVE TO BE LABELED? The requirements for labeling capacitors are primarily related to disposal; the labels serve as a positive reminder regarding disposal. All large, high voltage PCB capacitors have to be labeled, including those in service. Large, low voltage capacitors have to be labeled when they are taken out of service for disposal Small capacitors do not have to be labeled. Equipment con taining PCB capacitors does not have to be labeled unless the capacitor is a large, high voltage type or if the equipment was produced after January 1, 1979 and contains a small PCB capacitor. (80) DO I HAVE TO LABEL A PCB CAPACITOR THAT IS ON A POLE OR IN A SIMILAR INACCESSIBLE LOCATION? If a PCB capacitor is installed in a "protected" area (e.g., on a power pole, or structure, or behind a fence) the pole, structure, or fence is to be labeled in a place easily seen by interested persons, such as servicemen. (81) I SUBMITTED A PETITION TO EPA TO BE GRANTED AN EXEMPTION FROM THE JULY 2, 1979 MANUFACTURING BAN. IF I AM GRANTED AN EXEMPTION, WHAT WILL THE LABELING REQUIREMENTS BE FOR THE PCBS I MANUFACTURE? Any labeling requirements for chemical substances or mix tures containing 50 to 500 ppm PCBs manufactured after July 2, An00251 -2 3 - (85) WHAT EQUIPMENT IS AVAILABLE TO DETECT PCBs? There is no simple field test for detecting PCBs. It is usually done using gas chromatography/electron capture. The best solution would be 'to contact an experienced chemical laboratory in your area that could perform such tests. (86) ARE THERE EPA APPROVED LABS TO ANALYZED SAMPLES OF PCBs? No, EPA does not have a program for recommending or approving analytical laboratories. STORAGE (87) WHAT KINDS OF CONTAINERS ARE APPROPRIATE FOR STORAGE? The May 31, 1979 Final Rule permits 5 container types (5, 5B, 6D, 17C and 17E ) which comply with Department of Trans portation (DOT) specifications set out in 49 CFR 173.346, to be used to store liquid PCBs. Most of industry already is using these containers for PCB storage and handling. (88) CAN LARGE CONTAINERS, SUCH AS STORAGE TANKS, BE USED FOR THE STORAGE OF PCB LIQUIDS? EPA decided in the Final Rule to permit large containers, such as storage tanks, to be used to store bulk PCB liquids. This is to allow safe transfer and storage of large PCB liquid quantities; in addition, reduce storage costs. In other words, the transfer of stored bulk PCBs from tanks to other tanks or tank trucks will lessen the spill risks as opposed to having to transfer these large.quantities from a number of smaller storage drums into transfer tanks. These storage tanks must meet design and construction standards adopted by OSHA (29 CFR 1910.106). Also the storage facilities must have a spill prevention control and counter measure plan similar to the plans required for oil spill prevention. Owners and operators of bulk storage facilities will have to keep records of the amounts added to and removed from bulk containers. These records will be important in tracing waste shipments and enforcing the disposal and storage requirements. A0 0 fl2 5 2 -25- When itaiTier develops-a leak, t. contents should immediately ce transferred to another, non-leaking container or to special "overpack" containers, such as those used in the" chemical industry for leaking containers. (94 ) MUST THE EPA INSPECT A -PCB STORAGE AREA ONCE IT IS BUILT BEFORE IT CAN BE USED? No, it is the responsibility of the organization storing the PCBs to insure that the storage area meets the specifications. (95) DO PCB STORAGE AREAS HAVE TO BE PERIODICALLY CHECKED FOR LEAKS OR OTHER PROBLEMS? WHAT ABOUT PCB ARTICLES, SUCH AS TRANSFORMERS, THAT ARE IN SERVICE? PCB storage areas must be checked by the owner or operators at least every 30 days. Articles in service are not required to be checked by the regulations, but periodic checks would be a wise practice. SPILLS (96) DO PCB SPILLS HAVE TO BE REPORTED Under the authority of TSCA, PCB spills have to be reported whenever the incident poses a substantial risk to human health or the environment.- Since "substantial risk" cannot be precisely defined, however, any spill should be reported when people come into direct and' uncontrolled contact with PCBs, o r .the extent'of the spill is large enough to expose significant numbers of ani mals . * In addition, a spill should also be reported when the volume or the extent of the spill is unknown -- such as spills that enter drainage systems. PCB spills into water, onto shorelines, or those that threaten water-courses- should always be immediately reported. EPA is currently completing regulations under the Clean Air Act that will require reporting for water-related hazardous chemical spills (including -(PCBs). These regulations will have criminal penalties for failing to report such spills. As a general rule, spills involving a single capacitor do not have to be reported unless PCBs threaten or enter a water course. Because of the greater threat to health and the envi ronment, transformer spills should be reported -- ,unless only - 2 7 - A000253 disposition specifically, this applies *_o facilities using or storing at least 99.4 pounds (45 kilograms) of PCBs in PC3 Container(s ); one or more PCB Transformers; or 50 or more PCB High or Low Voltage Large Capacitors. These records shall be maintained for at least 5 years after the facility ceases using or storing PCBs or PCB Items in prescribed quantities. (101) DO PCB INCINERATOR FACILTIES HAVE TO KEEP RECORDS? CHEMICAL WASTE LANDFILL FACILITIES? HIGH EFFICIENCY BOILER FACILITIES? IF SO, FOR HOW LONG? Owners or operators of all three types of PCB Disposal Facilities have to keep records. Incinerator and high efficiency boiler facilities must keep their records for 5 years; chemical waste landfill facilities must keep their records for at least 20 years after PCBs have stopped being disposed there. (102) WHEN MUST I BEGIN KEEPING RECORDS OF MY PCB FACILITIES? PCB recordkeeping, if applicable, was to have begun on July 2, 1978. These records form the basis of an annual document prepared for each facility by July 1; the first annual reports should be compiled by July 2, 1979, (103) MUST COMPANIES SEND THEIR ANNUAL REPORTS CONCERNING PCBs TO EPA OR KEEP THEM FOR THEIR OWN RECORDS? Companies should keep their PCB records and annual reports at their facility for inspection by EPA personnel. Do not send the records or reports to EPA unless it is specifically requested by the Agency. (104.) I HAVE PCB FACILITIES IN SEVERAL LOCATIONS. DO RECORDS HAVE TO BE KEPT AT EACH SITE? Owners or operators of more than one facility having PCBs may choose to keep all of the records at a single facility, but the identify of that single facility must be available at each location. The record location must be manned at least 8 hours a day.$< A hc A000254 -2 9 - (108) ARE Th-xE SPECIAL DISPOSAL REQUIREMENTS FOR SMALL PCB CAPACITORS CONTAINED PRIMARILY IN SMALL APPLIANCES AND FLUORESCENT LIGHT BALLASTS? No, small capacitors can be disposed of as municipal waste. EPA has determined that the random disposal of small capacitors in municipal solid waste sites by householders and other infrequent disposers does not present an environmental hazard. However, the disposal of large quantities of small PCB , capacitors by commercial and industrial activities poses a larger environmental risk. Therefore, EPA encourages these persons to establish voluntarily a collection and disposal.program that would result in the waste capacitors going to chemical waste landfills or high temperature incinerators. (109) HOW ARE HYDRAULIC MACHINES CONTAMINATED WITH PCBs TO BE DISPOSED? In general, only a relatively small portion of these ma chines are contaminated with PCBs, in particular those used in die-casting and forging operations. Therefore, instead of re quiring disposal in a chemical waste landfill, the final rule permits disposal of hydraulic systems as municipal solid waste and salvaging of these machines after draining. First, the ma chines must be drained of all free-flowing liquid. If the fluid contains more than 1000 ppm PCBs, the machine must be flushed with a solvent and thoroughly drained before disposal. The liquid must be disposed of by high temperature incinerators or, if the PCB concentration is 50 to 500 ppm, by high efficiency boilers or in chemical waste landfills. (110) HOW CAN I DISPOSE OF THE DIELECTRIC FLUID IN MY TRANSFORMER? Fluids from PCB Transformers (concentrations of 500 ppm greater) must be disposed of only by high temperature incin eration. Fluids from PCB-Contaminated Transformers (with 50 ppm to 500 ppm PCBs) must be disposed of in high efficiency boilers, in approved chemical waste landfills, or in high temperature incinerators. Fluids from Non-PCB Transformers (with less than 50 ppm PCBs) have one disposal restriction: they cannot be used as a sealant, coating, or dust control agent if they contain any detectable PCB. A000255 31- N 1 2 S' 9 4 (117) HAVE DISPOSAL SITES BEEN APPROVEJ FOR PCBs? WHERE ARE THEY? A*J0 O* ui* m c w i A A i Yes, W Ljkfc chemical waste landfill sites^have been ap proved. No incinerator sites have yet been approved, but three sites are currently being considered. The landfill locations are as follows: 1. Facility: General Electric Co., Silicone Products Division. Facility "Address: 260 Hudson River Rd., Waterford, New York 12189. Facility Telephone Number (518) 237-3330. Type of Facility Approved: Incinerator. Type of PCB Waste Handled: Approval allows G.E. to incinerate only those PCB wastes which are generated on site, i.e., G. E. can not accept PCBs for incineration from any other company or any other G.E. facility. Expiration Date of Approval: September 1, 1981. EPA Regional Office Contact: Wayne Pierre. EPA Telephone Number: (212) 264-- 0505. 2. Facility: Newco Chemical Waste Systems, Inc. Facility Address: 4526 Royal Avenue, Niagara Falls, New York 14330. Facility Telephone Number: (716) 285-6944. Type of Facility Approved: Chemical Waste Landfill. Type of PCB Waste Handled: Capacitors (small and large); Properly drained transformers: Contaminated soil, dirt, rags, and other debris; Dredge spoils; Municipal sludges; and Properly drained'containers (drums). Expirationd Date of Approval: August 18, 1981. EPA Regional Office Contact: Wayne Pierre. EPA Telephone Number: (212) 2640 505. 3. Facility: SCA Chemical Services, Inc. Facility Address: 1550 Balmer Rd., Model City, New York 14107. Facility Telephone Number: (716) 754-8231. Type of Facility Approved: Chemical Waste Landfill. Type of PCB Waste Handled: Capacitors (small and large); Properly drained transformers; Contaminated soil, dirt, rags, and other debris; Dredge spoils; Municipal sludges-; and Properly drained containers (drums). Expiration Date of Approval: October 2,,1981. 4. Facility: Waste Management of Alabama, Inc. Facility Address: P.O. Box 1200 Livingston,.Alabama 35470. Facility Telephone Number: (205) 652-9529. Type of Facility Approved: Chemical Waste Landfill. Type of PCB Waste Handled: Capacitors (small and large): Properly drained transformers; Contaminated soils, dirt, rags, and other debris; Dredge spoils; Municipal sludgip; and Properly drained containers (drums). Expiration D a t e A p p r o v a l : Open-ended. EPA Regional Office Contact: Mr. I n s Scarbrough. EPA Telephone Number (404) 881-3016. 5. Facility: Casmalia Disposal. Facility Address: 539 Ysidro Rd., P.O. Box 5275, Santa Barbara, California 93108-main office (site located near Casmalia in Santa Barbara County). Facility Telephone Number: (805) 969-4703. Type of Facility Approved: A0002S6 N812996 (119) CAN PCBs OR PCB ITEMS BE EXPORTED FOR DISPOSAL? B E ' IMPORTED FOR DISPOSAL? Yes, refer to Question #23 in the "Import/Export" section of this Booklet. PCBs IN THE WORKPLACE (120) ARE THERE ANY OSHA RULES GOVERNING PCBs IN THE WORKPLACE? i ~"* i 1~h-- r i-m-nr rfj c r however, in 1977 the National Institute of Occupational Safety and Health (NIOSH) -- the HEW organization responsible for researching workplace safety -- published "Criteria for a Recommended Standard ... Occupational Exposure to Polychlorinated Biphenyls (PCBs)". OSHA, associated with the Department of Labor, will use this document to develop mTa* ndatory standardWs . TreMg4aMrdUing PCBs. m **T*Nv4*aIS act (121) WHAT IS A RECOMMENDED STANDARD FOR OCCUPATIONAL EXPOSURE? WHAT IS THE STANDARD RECOMMENDED BY NIOSH FOR OCCUPATIONAL EXPOSURE TO PCBs? A recommended standard is a determination of the level of exposure that will substantially reduce any risks of reproductive or tumorigenic effects of PCBs and prevent other adverse effects of exposure in the workplace. It is based on a 10-hour workday, 40-hour workweek, over a normal working lifetime. NIOSH has recommended in their Criteria Document -for PCBs that occupational exposure to PCBs be controlled so that no worker is exposed at a concentration greater than 1.0 microgram total PCBs per cubic meter of air (1.0 Mg/cu m ) , determination'as time-weighted average (TWA) concentration, for up to a 10-hour workday, 40 hour workweek. This is only a recommended standard'and it has not been adopted to date, by either OSHA or EPA. At the present time, however, OSHA is reviewing this recommended standard. (122)' DID NIOSH RECOMMEND ANYTHING ELSE TO REDUCE EXPOSURE TO PCBS IN THE WORKPLACE? Yes, NIOSH made recommendations about work practices, perr sonal protective equipment and clothing, medical surveillance, personal clean up and sanitation practices, and employee information programs. A0 0 0 257 -3 5 - N12S38 I L. ji > (125 IF I GE -3 LIQUID ON MY- SKIN, HOW C. I REMOVE IT? If liquid or solid PCBs are splashed or spilled on an employee, contaminated clothing should be removed promptly and the skin washed thoroughly with soap and water for at least 15 minutes. -' Eyes should be irrigated for at least 15 minutes if liquid or solid PCBs get into them. A drop of vegetable oil may be put into the eye to relieve the irritating effect of PCBs. CONTACTS FOR INFORMATION . (126) IF I HAVE OTHER QUESTIONS ABOUT THE PCB BAN RULE'S . PROVISIONS, IS THERE SOMEONE I CAN CONTACT? If you have more questions call the Industry Assistance Office on their nationwide toll free number: 800-424-9065; persons in the Washington, D.C. area can reach this Office by calling 554-1404. (127) HOW DO I GET A COPY OF THE RULE? SUPPORT DOCUMENT/ VOLUNTARY ENVIRONMENTAL IMPACT STATEMENT (REFERRED TO IN THE RULES AS THE VERSAR REPORT)? Copies of .both can be obtained by calling the phone numbers mentioned in the answer to Question 126, or by writing to: John B. Ritch, Jr., Director industry Assistance Office Office of Toxic Substances (TS-799) U.S.^Environmental Protection Agency . 401 "M" Street, S.W. Washington, D.C. 20460 U.I.GOvtlNtofNTHINTINGOMiCt-.IW*O-- t 37- A000258 N i3fiU:} ^iau^'-iC U ijLt'r~* - > `.i.'.'JjA';-.-^1'^'^'.'.~i"*-----' t'iiSj-~?r>._-k.**&*._..-w-iilii. ' .'^ -;7` !. v' v ^Sunday, September 18;'1879--lift Vega Review-Journal--15A i ., , ,1 -,',a ,, ..-u S . s v i i i i i ; * - ~ * - - ` ~ v a s..-^.,;-i..\ v. ^yrX`^--t^'---.--,-v-y.,^r.t..^, ..-- ..... ,,. ...SALT- LAKE CTTY (APX -- Blood'testedand possibly *` Dr. Edward Gallagher) state health officerfor the Idaho*; breast mflk aampl&wiU b&t^n.-this weekby scientists Department of Health, said Saturday blood tests and pos `seekingto detorminehowwidelythe toxic substance PCB siblybreastmilksampleswould!be takenthisweekin east hasspreadthroughWestemstatea,officialsSaidSaturday.' ernIdaho'sFranklinCounty. | ^ ; Researchers from thonational Center for Disease CohV - GallagheF said researchers would be looking for ther trol are expected'to>amvein eastern Idaho early in the ' amountoPCB individualsmayhaveingested. He saidthe= weekto help state-officialswith'the tests for PCB, anoufc- teata would determine' whether further health studies^ lawedchenucaVwhichso-farhasbeenfoundinfoodorfeed, wouldbeneeded.; | '.j inninestates.. V ', .' / > ; , Vl * . -- Contamination.was recently noticed at.Ritewood Egg^ Health officials have^ founds PCB contamination in . Co. inFranklin, Idaho, amajoreggsuppliervoluntarilyde- 'chickens, egga; processed foods,and:feeds inIdaho, Utah, Montana, Washington^'.Oregon,. Iowa,'-North Dakota*. .straying millions chickens. of eggs, and jhundreds of thousands - of -;i .South Dakota and Minnesota; said Leroy.Gomez, district So far, no illness in humans or animals has been traced.! .directorfortheFoodandDrugAdministration,inDenver. , to PCB contamination, Gallagher said. He said because1 calculatedlevels-oftheche&icaiineontamSnetedeggswas butbannedfiveyearago. - >. . . . - - - , solow, a personwouldhaveto eat "a tremendous number Still not known-is how the chemical may have gotten ofeggs" toshowanyilleffects. into the meaL j Contact with large amountaof PCB -^polychlorinated Chickens from Ritewood were shipped to Utah for biphenyl -- has caused tumors in- laboratory animals, : slaughter, thentoClinton, Iowa, wheretheyweretobeput killedcattleinKansasandcausedskindiseasesamonghu- in Swift & Co. meat pies,.until contamination was discov mane, scientistssay. : v. -!' :! ';U . = GomezsaidFDA andEnvironmentalProtectionAgency ered. .... >.> \Yr '[ ? ' . : Contaminated chickensfromMontana were sent to But ; . investigators were samplingmeal at Pierce Packing Co.';- terfield, Minn., tobeputinto Campbell'schickensoup, but plant inBillings, Mont, thought to bea source of the con the.contamination waa found before the soup was pack- tamination. - -A Gomezsaidmealmadefromhogbyproductsshippedby; ' Eggs'froih-chickensfed bone andmeat meal containing Pierce beginning in early June contained the synthetic PCB went' into 76,000 Pepperidge Farms frozen cakes, chemical, one used asacoolantin electrical equipment whichhavebeenquarantined. | .; ' Fannersin Utah and Idaho have voluntarily destroyed ,360,000chickensinUtahandIdaho, GomagsiucL AD0fl259 'OUR P.O. B O X STREET 2 3 0 * LAS AND STEKAR AV-NUE VEGAS. N E V A D A . 89151 September 26, 1979 Chief Dale Scar City of Henderson Fire Dept. 134 Atlantic 'Street Henderson, NV 89015 Subject: Polychlorinated Biphenyls Dear Chief Scar: The U.S. Environmental Protection Agency has notified the Electric Utility Industry that a group of chemicals known as polychlorinated biphenyls (PCB's) represents a potential hazard to the environment and to human health. Nevada Power Company is committed to maintain environment policies which recognize that our facilities and operations must be conducted and operated within environmental requirements. The Toxic Substance Control Act is one of such federal regulations which prescribes Che requirements for the collecting, handling, transport ation, and disposal of Polychlorinated Biphenyls or PCB's. PCB's are used as an additive in insulating fluids and are found in some capacitors and indoor transformers. Until recently PCB's were added to certain transformers and capacitors because PCB's can reduce the likelihood of fire in electric equipment. In compliance with current regulations all of our indoor and outdoor electrical equipment (transformers and pole mounted capacitors) containing PCB fluid have been identified and have appropriate labeling. Occasionally our pie mounted capacitors will fail and rupture releasing approximately 1-2 gallons of the fluid, and pole top fires can result. If such an event occurs and your engine Companies respond, we would appreciate your cooperation and mutual assistance in the following: (1) Immediately notify the Power Company at 385-5691. (2) Under no circumstances is water to be used in washing down, ^ t is essential that the cleanup be conducted at the site in a manner least likely to spread the contamination. (3) Exception In the event of a pole top fire in order - to protect life, fire control, or protecting exposures, water may be used to that pro tection r w v n i > P.O. B O X LAS VEGAS, NEVA *89151 September 26, 1979 Chief Sam Cooper City of Las Vegas Fire Departments F. 0. Box 510 Las Vegas, NV 89101 1' DEFEEXNHDIBAITNT'S \ ttf- h ~ p r Subject: Polychlorinated Biphenyls Dear Chief Cooper: The U.S. Environmental Protection Agency has notified the Electric Utility Industry-that a group of chemicals known as polychlorinated biphenyls (FCB's) represents a potential hazard to the environment and to human health. Nevada Power Company is committed to maintain environment policies which recognize that our facilities and operations must be conducted and operated within environmental requirements. The Toxic Substance Control. Act is one of such federal regulations which prescribes the requirements for the collecting, handling, transport ation, and disposal of Polychlorinated Biphenyls or PCB's. PCB's are used as an additive in insulating fluids and are found in some capacitors and indoor transformers. Until recently PCB's were added to certain transformers and capacitors because PCB's can reduce the likelihood of fire in electric equipment. In compliance with current regulations all of our indoor and outdoor electrical equipment (transformers and pole mounted capacitors),-containing PCB fluid have been identified and have appropriate labeling. Occasionally our pole mounted capacitors will fail and rupture releasing approximately 1-2 gallons of the fluid, and pole top fires can result. If such an event occurs .and your engine Compa ties respond, we would appreciate your cooperation and mutual assistance in the following: (1) Immediately notify the Power Company at 385-5691. (2) Under no circumstances is water to be used in washing down. It is essential that the cleanup be conducted at the site in a manner least likely to spread the contamination. (3) Exception - In the event of a pole top fire in order to protect' life, fire control, or protecting exposures, water may be used to the extent to provide that pro tection. .N ,,-0591 7 ... ........... .... A000261 (4) Avoid -.r.lamination of Fire servit equipment or personnel. Avoid walking, dragging hoses, or con tacting any surfaces contaminated by the PCB fluid. The Company will respond on notice or discovery and will undertake cleanup and decontamination. Company representatives will' also contact the affected public and advise them of the incident and what steps are being taken to insure their'* safety and health. Should you have any questions concerning this request, I may be reached at 385-5627. As in the past, the Company appreciates the Fire D e p a rtment's continuing cooperation and mutual assistance. Please continue to promptly notify the Power Company in all electrical emergencies involving our facilities. Sincerely, Donald G. Fabbi Safety Director DGF/jg N .0591 8 A000262 PCBs Polychlorinated Biphenyl* CONTROL & HANDLING PROCEDURES SUBJECT: Labeling - High Voltage Capacitor Pole Locations a\ f l L.._ i ^ 1 i / *\ 'u ! / CAUTION l P C B s/ CONTAINS (WfCiarizjted UJ. * CTlJ*l,--haOtUaX U X < f ULiZum Cj > r. - / -- i m iiiti-witwtt_i__t_t_M_n_r_r cm u te onw extent: IMIITCI: OATl 6-/ _______________u__ic__i_iM____ia_*_____________ i1lTi s'_t ':s x a iu size PCS LABELING NCVALOitA UfOUWX .tXXtCUOVMA PANY OESCllMIC* i11/ * 3 UTISIOM SUPCIStOtO IT SHEET NO. af SH73 0RAWING NO. CHANGE Originated Sy: D. Fabbi 0r 3/15/79 Approved By: J . M cCarthy 0 *tr____________7 / 1 0 / 7 9 Pag# 9 N -0591 9 -000263 rvun P.O. B O aiKttr 30 * LAS ANQ STEWAP- AVENUE VEGAS, NEV JA 8 9 I5 I September 26, 1979 >- Chief Kimball.. City of North Las Vegas Fire Department 2626 E. Carey Avenue North Las Vegas, Nevada 89030 Subject: Polychlorinated Biphenyls Dear Chief Kimball: The U.S. Environmental Protection Agency has notified the Electric Utility Industry that a group of chemicals known as polychlorinated biphenyls (PCB's) represents a potential hazard to the environment and to human health. Nevada power Company is committed to maintain environment policies which recognize that our facilities and operations must be conducted and operated within environmental requirements. The Toxic Substance Control Act is one of such federal regulations which prescribes the requirements for the collecting, handling, transport ation, and disposal of Polychlorinated Biphenyls or PCB's. P C B 's are used as an additive in insulating fluids and are found in some capacitors and indoor transformers. Until recently PCB's were added to certain transformers and capacitors because PCB's can reduce the likelihood of fire in electric equipment. In compliance with current regulations all of our indoor and outdoor electrical equipment (transformers and pole mounted capacitors) containing PCB fluid have been identified and have appropriate labeling. Occasionally our pole mounted capacitors will fail and rupture releasing approximately 1-2 gallons of the fluid, and pole cop fires can result. If such an event occurs and your engine Companies respond, we would appreciate your cooperation and mutual assistance in the following: (1) Immediately notify the Power Company at 385-5691. (2) Under no circumstances is water to be used in washing down. "Tt is essential that the cleanup be conducted at the site in a manner least likely to spread the contamination. (3) Exception - In the event of a pole top fire in order to protect life, fire control, or protecting exposures, water may be used to the extent to provide that.pro- CecCion. . v| 06780 A000264 K (4) Avo~. -ontamination of Fire serv--e equipment or personnel. Avoid walking, dragging hoses, or con tacting any surfaces contaminated by the PCB fluid.\ The Company will respond on notice or discovery and will undertake cleanup and decontamination. Company representatives .-will also contact the affected public and advise them of the incident and what steps are being taken to insure their safety and health. As in the past, the Company appreciates the Fire Department's continuing cooperation and mutual assistance. Please continue to promptly notify the Power Company in all electrical emergencies involving our facilities. Sincerely, Donald G. Fabbi Safety Director DGF/jg HI '. i-VJLJ .-- 1*1 *~* A000265 N 067 81 <. ] N V FOUR' p.o. a o x ?A PO STREET 230 la s W K IK C O M F A N Y AND ST AR AVt.NuE VEGAS. NEVADA. 8915! September 26, 1979 Chief Roy L. Parrish Clark County Fire Depc. 707 I . Deser: Inn Road Las Vegas, NV 89L09 Subject: Polychlorinated Biphenyls Dear Chief Parrish: The U.S. Environmental Protection Agency has notified the Electric Utility Industry that a group of chemicals known as polychlorinated biphenyls (PCB's) represents a potential hazard to the environment and to human health. Nevada Power Company is committed to maintain environment policies which recognize that our facilities and operations must be conducted and operated within environmental requirements. The Toxic Substance Control Act is one of such federal regulations which prescribes the requirements for the collecting, handling, transport ation, and disposal of Polychlorinated Biphenyls or PCB's. PCB's are used as an additive in insulating fluids and are found in some capacitors and indoor transformers. Until recently P C B 's were added to certain transformers and capacitors because PCB's can reduce the likelihood of fire in electric equipment. In compliance with current regulations all of our indoor and outdoor electrical equipment (transformers and pole mounted capacitors) containing PCB fluid have been identified and have appropriate labeling. Occasionally our pole mounted capacitors will fail and rupture releasing approximately 1-2 gallons of the fluid, .and pole top fires can result. If such an event occurs and your engine Companies respond, we would appreciate .your cooperation and mutual assistance in the following: (1) Immediately notify the Power .Company at 385-5691. (2) Under n circumstances is water to be used in washing down. It is essential chat the cleanup be conducted ' at the site in a manner least likely to spread the contamination. (3) Exception In the event of a pole top fire in order * to protect life, fire control, or protecting exposures, water may be used to the extent to provide that pro- teccion- A000266 N 06778 (4) Avoid .laminacin of Fire servio equipment or personnel. Avoid walking, dragging hoses, or con tacting any surfaces contaminated by the PCB fluid. The Companykwill respond on notice or discovery and will undertake cleanup and decontamination. Company representatives will" also contact the affected public and advise them of the incident and what steps are being taken to insure their* safety and health. Should you have any questions concerning this request, I may be reached at 385-5627. As in the past, the Company appreciates the Fire Department's continuing cooperation and mutual assistance. Please continue to promptly notify the Power Company in all electrical emergencies involving our facilities. Sincerely, t - JU U Donald G. Fabbi Safety Director DGF/j g A000267 mayor sill b r u s i Mg(, J C-*'STENJCS {Iti *TTO*(T HICMAJtO C UAJtll CiT* CI* CMJSSC^L DO*H C I T Y of L A S V E G A S October 5, 1979 Mr. Donald G. Fabbi, Safety Director Nevada Power Company Fourth Street and Stewart Avenue Las Vegas, Nevada Dear Mr. Fabbi: Thank you for your informative letter on polychlorinated biphenyls. We have sent a copy of your letter and diagrams out to all pur firefighters. They will familiarize themselves with this information and take appropriate action in any situation involving this substance. Sincerely, Las Vegas Fire Department SC :rh CUV-11 A000968 > >1 400 E. S T E W A R T A V E N U E L A S V E G A S . N E V A D A 101 {702(.J0*0! if 1.41V!1 ,kJV f C O i l t a l l l a i^lOil s* ) F n da y , October 12, 1979-- L a s V e g a s R e v i e w - J o u r n a l -- 5 C woes grow The Los Angeles Times WASHINGTON -- Ha rr i s D w i g h t L a d l e is a n anguished man. S o m e days as m a n y as 15 of the m i nk on his Provo, U t ah, f a r m die, the victims of a Montana-generated contamination of the chemical P C B that federal agents are investigating from California to N e w Jersey. T h e government already has taken some of the blame for the troubles that have befallen Ladle and others like him. And, tsced with reports of contamina tion f r om 17 states, federal authorities readily admit the seriousness of the situ ation. "T h i s is o n e of the larg est chemical contamina tion incidents ever reported.to us," said A n thony Celeste, an associate director of the Food and Drug Administration and head of the federal investi gation. "In terms of the n u m b e r o f states affected it is the m o s t widespread." It all started in a smalt w a y last J u ne -- with th# s P in C gl B e -- l eak pol o y f c 200 hlor g i a n l a l t o e n d s bcii phenyl -- from a spare, un us e d electrical trans former at the Pierce Pack ing Co., a hog slaughtering a n d feed plant in Billings, Mont. ( P C B s belong to a family of organic chemicals kn ow n as polychlorinated hycrocarbons. T h e y are virtually indestructible a n d a l m o s t all those in e x istence have been m a n u factured by man. P C B s ac cumulate in b ody tissue and are poisonous for m a n and other animals.) A s a result of the Billings leak, highly contaminated feed from Pierce has been eaten by m a n y chickens and hogs in the West. Contaminated chickens, eggs and hogs have been found in a n u m b e r of states, particularly in the R o c k y M o un t a i n area. Furthermore, millions of p ounds of grease for use in the manufacture of soap and cosmetics, have been shipped from the Billings plant to California and Washington State and as far a w ay as C ana d a and Ja pan. T h e latest incident, one of a series of P C B contami nations in this decade, rais es bothersome questions about the ubiquitous quali ty of toxic chemicals like P C B , about the ability of federal officials to m o v e quickly to deal with the problem, and about the willingness of federal agen cies to alert consumers. Gov. John V. Evans of Idaho, a state where more than 400,000 chickens and millions of eggs have been destroyed because of P C B contamination, denounces "inexcusable delays" by the Department of Agricul ture and the Food and D r u g Administration in re porting the discovery of such contaminations. E v --j.' '* a n s is especially critical of a n u n n a m e d F D A official w h o m he quoted as saying: " W e d i d n 't w a n t t o c r e a t e a panic." This attitude also touch es a raw nerve in Ladle, the Utah mink farmer. "They w o n ' t tell the s h e e p b e cause they might run," he said, "but the wolfs al r e ad y in a m o n g t h e m kill ing the flock." 1 It w a s only a few w e e k s ago that Ladle lekmed that feed contaminated by P C B 'w a s responsible for killing more than a quarter of his 1,500 mink. H e had been giving his mi nk feed mixed with visc era from PCB-contaminated chickens. L a d l e is upset at w h a t h e sees as the government's delay in finding and report ing the contamination. H a d the contamination b e en discovered earlier, h e feels, h e could h a v e stopped using the' tainted viscera -- and he could h a ve Baved himself a lot of worry and m o n e y trying to find out w h a t w a s killing his mink. In a statement before a House commerce subcom mittee o n Sept. 26, Carol Tucker Foreman, assistant secretary of agriculture for food and consumer services acknowledged that there h a d b e e n " s o m e initial d e lays" in reporting the con tamination. As pieced together by federal agents, PCB-contaminated feed m o ve d from the Billings plant to the Ritewood Farms in Franklin, Idaho, on June 25. A n Agriculture Depart m e n t inspector, performing a routine chore, then took a tissue sample from a Rite-' wood Farms chicken that w a s processed at the Jolley Wholesale Poultry proc essing plant at Provo, U t a h , o n J u l y 6: Because of a mix-up at tributed to employee vaca tions, the sample w*as notsent by mail from the Pro vo plant to the Agriculture Department's San Francis co laboratory until July 16. O n Aug. 3,.the Depart m e n t 's r e g i o n a l m e a t a n d poultry inspection office \ recived test results indicat'ing that the chicken had 'P C B r e s i d u e s o f 1 5 . 6 5 p a r t s *jier million, m o r e than five times greater than the three parts per million al lowed. T h e regional office of the D e p a r t m e n t 's F o o d S a f e t y and Quality Service was notified five days later, a n d on Aug. 10 the department identified Ritewood F a rm s as the source of the con taminated chicken. A t this point, responsi bility for the investigation passed from the Agricul ture Department to the Food and Drug Adminis tration. T h e Agriculture Department notifed the F D A o n Aug. 15, according to a n official F D A chronol ogy qf events. O n Aug. 20, th e F D A b e g a n its investi gation at Ritewood Farms. A0002G9------- N 03187 CONTINUED A t this point, eggs and chickens from the massive farm, one of the West's leading egg producers, w e r e still e n te r i n g t h e m a r ket place. After m a n y days of in vestigation, Ritewood Farms owner Marlow Woodward remembered that h e still h a d o n h a n d two sacks of meal from the Pierce P a c k i n g firm of Bill- mgs. Samples of the meal were sent on Sept. 5 to the F D A laboratory in Seattle, but did not arrive until Sept. 11 because of a H u g h e s Air W e s t strike. O n e of the samples finally tested on Sept. 12 was found to contain levels of P C B too high to measure -- more than 1,000 parts per million, according to the FDA. Three days later, the source of the PCBs was found to be the leaking transformer at Pierce Packing. Shortly afterward, the chairman of Pierce Packing made a statement alerting the public to the danger of PCB contamination in its meat and bone meal andbegan to recall theproduct, according to federal inves tigators. So, the first public announcement of the prob lem was made more than 'five weeks after the Agri culture Department had located PCB-contaminated chickens at Ritewood Farms. By this time, the contaminated feed and chickenshad movedwidely across the country. Animal feed had been sent to six northwesternstates. The Campbell Soup Co. in Worthington. Minn., had already reported re ceiving PCB-conuaminated chicken. Contaminated chickens h a d also been sent to Swift & Co., in Clin ton. Iowa. M o r e than 12,000 cases of Pepperidge Farms frozen strawberry cakes made with PCB-con- taiminated eggs, were re ported in Utah. T h es e products have either been destroyed or are awaiting destruction. In early July, Ladle, the Pr ov o m i n k raiser, h a d bought chicken viscera from Jolley Poultry to use in his m i n k feed. T h e chickens had come from Ritewood Farms. His mink started dying in late July. Dr. J. Alan Thomas, head of the Utah State University animal diagnos tic laboratory in Provo, says that the overwhelm ing majority of the dead mink he tested from La dle's farmdied fromthe ef fects of PCB. The rest died of natural causes. FDA officials believe they have caught the cur rent PCB contamination in time to avoid great harm to humans. They are grateful that Ritewood Farms was selling old hens, sold for products that take longer to make, like soup, rather than fryers which would have been eaten by hu mans m u c h sooner. "It is o u r best j u d g m e n t that the short-term nature of this incident and the lev els of contamination found so far pose no immediate .threat to the health of con s u m e r s in the United States," Acting F D A C o m missioner Sherwin Gard ner told a H o us e C o m merce subcommittee on Sept. 28. T h e F D A s a ys it believes that its investigators h a v e traced most of the chickens and egg products that went into interstate commerce. T h e Agriculture Depart ment says about 400,000 pounds of poultry, 16,000 pounds of fresh pork, and more than 50,000 pounds of egg products, such as fro zen eggs, have been identi fied as contaminated and are being destroyed. TTie government regards P C B a as such a toxic and persistent c h e m i c a l that it has established rigid stand ards for disposal of them. High temperature inciner ation is r e c o m m e n d e d for material highly contami nated with PCBs, but the Environmental Protection Agency has yet to approve a n y P C B incinerator sites. Only eight chemical waste sites h a ve been approved for P C B disposal. P C B iB the only c h e m i cal wh os e manufacture has been banned by Congress. In 1976, Congress passed legislation forbidding m a nufacture or importation of PCBs, regulations that w e n t into effect last June. However, these regulations do not ban use of those c h e m i c a l s still o n h a n d . Therefore, the E P A has allowed the m o r e tljan 700 million pounds that remain to b e u sed in oils that serve as coolants and lubricants in electric transformers, capacitators and hydraulic systems, among other things. B y one E P A esti mate, there are more than 30 million transformers containing P C B s o n utility poles in every part of the country. " P C B contamination in t h e W e s t e r n states is n o t the first s u ch incident," the F D A ' s G a r d n e r said. " U n fortunately, it will p r o b a bly not be the last." A0 0 0 2 7 0 N 0313 8 NEVADA POWER COMPANY MEMO TO: Distribucin. Listed FROM: Donald Fabbi , 10/22/79 SUBJECT: PCS Control and Handling Procedures Attached herewith are copy(s) of our FC3 control and handling procedures for your use and or distribution to affected employees. The policies and implementing procedures' contained therein are manditory for use by all affected personnel in order to achieve environmental requirements. At this time most of the affected departments recordskeeping as specified in the procedures is presently being done*by the Safety Department. In the near future, you will receive additional re visions that will reflect recent changes in Company policy and regulatory requirements. Should you have any questions or need to request additional copies for personnel, let the Safety Department know. A. E. Pearson c c : C. L. Ryan J. McCarthy Dis tribution List R. Atkins - 5 R. Brown - 3 S. Burns - 2 R. Calle - 5 S. Claeys - 3 D. Crotta J. Crum - 3 V. Daniels - 5 D. Dawson - 3 J. Diehl J. Driscoll - 5 L. Dungy R. Genseal K. Grant - 2 F. Hall R. H a l l - 3 T. Harkenrider W. Henson - 3 A. Hofmeister W. James Contractors Commonwealth Elect. Davey Tree Surgery A.. Arebaio W.. Jones - 2 C.. Kaiser - 2 E.. Kulick - 5 R.. Langford T.. Leavitt - 3 J. Middleton W.. Neville D. Odell - 3 C. O'Neill JT. Freenon R. Slate C. Stewart J. Strobel H. Thompson - 2 C . Vaughn J. Webb - 5 R. Whatley S. Williams 2 DE! N.-0681 5.eryice Commission Soutnt*n Ntvidi i Ority Hgni frtwd Duty t o t w Late Sporta VOL. 30 SO. 115 US VEGAS. NEVADA. THURSDAY. OCTOBER 25. 1375 20c 80 PAGES Dangerous Leak Cleaned Up A potentially cancer-causirtf chemical cancer-causing substance -- had leaked to the l e a k e d d o w n a N e v a d a P o w e r C9- p o l e n e a r g r o u n d . Nellis Boulevard and Carey WedrtfWiay after a minor explosion and fire ruptured a tank in a - capacitator bank. Stroble said a Nevada Power crew, accom panied by safety-ijispectors, dressed in protec tive clothing-cleaned up the P C B from the ground and pole and also "z f e w drops" which Jan Stroble, director of community informa* _tion at Nevada Power, explained that a citizen "reported the incident after 10:30 a.m. to the spilt on a nearby bous e . . T h e p o w e r pole is located o n Nellis; Clark County Fire Department, Boulevard, 100 feet east of Glendale. Fire fighters alerted Nevada F p w e r that a capacitator b a n k atop a p o le in 43 ^ f o o t :w i d e .easement of desert had ruptured and approx Dr. John Santolucito of the federal Environ mental Protection Agency (EPA) in Las Vegas, explained, exposure to P C B causes skin irita- i m a t e l y o n e gallon o f toxi c PCB (poly tions a n d p r o l o n g e d e x p o s u r e c a n c a u s e liver chlorinated biphenyle) -- believed to be a and nerve system damage. A0 0 0 2 7 2 Y r The VaUey Tim es i * *. * r '.Stand with anybody that stands right. Stand with him while he is right, and part with him whenhq goes wrong." TM Abraham Lincoln * ' . .1/-ij!' mV "V Phone: Circulation 642-1231 All other (7021649-8700 North Las Vegas, Nevada 89030 15 Cents Per Copy Thursday, October 25, 1979 Nevada Pow er Cleans Highly Toxic Sp ill . MoTreBimytAahsaNnSNtaKtwllOoWFbrOiatLrerrels of twrearshe, csooinltaamndinarteefdusewwithhicha highly toxic electrical in samuWdeNdNWfuolpiieeereslleANalvclpeaedaolttacceiatdnwrnisctdvtndioenociRacfagnrsrhaadeodp,gdiellaslaairiduaPqnddeyrctuogpP.cahaeaiwalto,dnepyeorwtedaaeaworncedfGsieaturthtrlDiopfeChleoeurCmnoeor,crndo.sreroad.aheearlirowFsesesteonvuoapqaaAfeplfuowbitelnvisbeaptaooaedgyin-asf.lf., dbruuitoeipullitetsucyertdreipcooffltleuw,iado.r'ceAosnbugtoalatuliilntnogaenrgs aintlhlooanaft of the insulating liquid leaked to the ground beneath the poCle,ohmepsraiisdi.ng about ^*8.0-!1 ipsercethnte of stuhbe sltiqaunicde, hePsCaiDd,, polychlorinated biphenyl,1 a toxic chemical regulated by ctdAthhaiagneeFnecagEnebecnrrbpy-veicuidarbsuolaainscaniimdnsd,gewcnahltgareoaesaewlnnpPetuuv.rnpteoeortdte,c-*clr.yttehie1woannast oscfrcaopnetdamabinoauttedonseo-ihl,alafnbdartwreol. cboanrtraeilnsedof rwefiuthsien anad. w6-efeodost sarivtttha^irrad"eTdiacciTohuotBsehelsncyseeohtnaaslfe'tciumtqtdtoyhbcuuninersilttdteeaaouad,atmx"tnitioieFclilcnonieatar.aswy"bntwbdpaeydiisqestsglpeaeuao.irssddseeeau,fsula"mrossapeoert site, Fabbi said. CoM r'O o D e b a te co n tin u e s in8 E -- L a s V e g a s R e v i e w -urnal-- Friday, October 26, 1979 PCS egg scare [ BOISE, Idaho (UPI) -- W h e n a truck b u m p e d an electrical transformer at a Montana meat-packing plant s o me t i m e last June, t h e d r i v e r p r o b a b l y d i d n 't ' t h i n k m u c h o f it. B u t the incident h a d farr e a c h i n g effectsa s 2 0 0 g a l lons of a cancer-causing chemical, P C B, leaked out of the transformer and into animal feed, eventually -contaminating several hundred thousand pounds of eggs, chickens, pork, beef a nd processed foods in at least 17 states, f rom the W e s t Coast to N e w Jersey. A m o n g the businesses most directly affected w a s . the Ritewood E g g Co., the only major industry in tiny Franklin, Idaho, which was ordered by the federal gov e r n m e n t to destroy its e n tire inventory of hund r e d s of thousands of chickens and millions of eggs. A n d one-third of Frank lin's 4 0 0 residents u n d e r w e n t .tests to d e te r m i ne whether the P C B level in their bodies.was above fed eral standards. Fortunate ly, it w a s n 't. The contamination did not c o m e to public light until Sept., 11,.m o r e than/ two m o nt h s after a sample ~ of contaminated chicken from Ritewood was taken and three m o n t h s after the original P C B spill. PCB, or polychlorinated biphenyl, is u s e d as-a c o o lant for electrical equip ment. It has been linked to akin disease, liver cancer, ^miscarriages and birth de fects in tests o n laboratory animals. The Environmental Pro tection Agency outlawed the production of P C B in 1976, b u t t h e c h e m i c a l still is f o u n d in millions of elec trical transformers. P C B accumulates in ani m a l a n d h u m a n tissue, but s c i e n t i s t s d o n 't k n o w h o w m u ch P C B must be be ing ested to affect a person. I d a h o 's c h i e f h e a l t h o ffi cer, E d Gallagher of Boise, said a person would "have to eat three or four dozen of the Ritewood eggs for 45 days before the P C B would h a v e a n y affect. ' "I think (the incident) was extremely over played," said Louis. M e n doza, of Franklin, y h o said he continued to.eat eggs from Ritewood Egg Co. even after they heard the e g g s c o n t a i n e d P C B . (( "I just n e ve r felt overly a l a r m e d a b o u t itv" . M e n d o z a s aid. ' T d i d n 't t h i n k t o d m a n y people around; here did." . \ V A f t e r t h e f r i n i k ^ . b a c k e d ,`; into the Uansform^r at the P i e r c e P a c k i n g C o ; ,it> Bill i n g s , M o n t : , .' t h f ? 1; J P C B . l e a k e d i n t o ^ h e ; p l a n t 's waste water system. Fierce d r e d g e s - the*, w a s t e ' `. w a t e r for byproducts for use in meat mealran animat feed ingredient. F a r m s all over, the W e s t and Midwest bought the PCB-tainted Pierce feed. R i t e w o o d rece i v e d its batch J u n e 25. A routine tissue sample other food distribution from a R itewood chicken outlets. was taken at a U.S. D e T h e Idaho Health and partment of Agriculture Welfare D e p a r t m e n t laboratory at Provo, Utah, learned of the P C B inci o n J u l y 6. B y t he t i me the d e n t Sept. 4. T h e public tests c o n f i r m e d t h e P C B f o u n d o u t a b o u t it a w e e k c o ntamination a n d the later through the press af U S D A ha d notified the ter Ritewood began bury E P A a n d the U.S. F o o d ing its c o n d e m n e d chick a n d D r u g Administration ens at the c o u n t y landfill. of the c o n t a m i n a t e d s a m A n F D A official in Se at ple, it w a s A u g . 15. tle said the contamination T h e owners of the Rite was not announced i m m e w o o d farm were asked to diately because the F D A h a l t s a l e o f t h e i r c h i c k e n s " d i d n 't w a n t t o c a u s e a . a n d eggs o n Aug. 16 until panic." the initial indication of B l o o d a n d breast milk P C B contamination could tests on about one-third of bBsmltpihaeeohameBrnconmyopwfyonelifeSfedlaldiseePisrorpcCman6tocBel7.ndh,l3.tii,pamcfaifokniurrtetersndeothxfp2ec3e0terriepttsdoemasisruinattlesgss Franklin's 400 residents s h o w e d levels of P C B be l o w the federal limit. T h e y were tested because they used Ritewood products exclusively, and therefore they w e re m o r e likely than anyone to have ingested . E g g samples also showed the chemical. excessive levels, so- the Paul W o o d w a r d , part- F D A c o n d e m n e d all o w n e r of the Ritewood 550,000 chickens and mil- farm, blamed the federal > lions of eggs at the farm. agencies involved for "ov- ' I t w a s e s t i m a t e d t h a t 1 8 e r r e a c t i o n a n d s l o w n e s s . " million PCB-tainted eggs H e said the chickens and already h a d been sold in eggs which were destroyed I d a h o a n d o t h e r w e s t e r n c o u l d h a v e b e e n s a v e d if states. ` the U S D A had detected T h e F D A linked the the P C B soon after t h e . R i t e w o o d feed w i th the first tissue s a m p l e w a a .tak B i l l i n g s p a c k i n g p l a n t o n e n . . A. *' S e p t 14. T h e n shipments A n d , noting that h e and of P C B - c a r r y i n g m e a t his partners, were thinking were traced to a Campbell of suing the*government, S o u p Co. facility in W o r t h W o o d w a r d 'also said_ the ington, Minn.; Swift & Co.' federal restrictions.were in Clinton, Iowa, and m a n y too stringent. CONTINUED ON NEXT PAGE A0 0 0 2 7 4 N 03185 UEBAlb CUriTlNUES IN EG6 SCARE (continued) " I c a n 't b e l i e v e t h e y a n t s e c r e t a r y o f a g ri c u l e v e n t h o u g h their p r o d u c t s thought this w a s so bad," ture, h a d another view. were not found to be c o n W o o d w a r d s a i d , " I d o n 't " I n l i g h t o f t h i s i n c i d e n t , t a m i n a t e d b y P C B . s e e t h e m g e tt i n g all t h at it is clear t h at t h e d e p a r t N e a l A m b r o s e , o w n e r of excited about cancercaus-* m e n t must give special at A m b r o s e F a r m s of W e n ing cigarettes." tention to e n vi r o n me n t a l dell, Idaho, said h e h a d T h e federal g o v e r n contaminants in the food "hundreds" of hogs no one ment's handling of the inci supply," she said, adding w o u l d b u y because tests dent brought criticism of that the detection of P C B for P C B poisoning at his 1 'two kinds from Idaho poli at the Idaho farm w a s a farm were publicized. I ticians. chance occurrence. Gov. J o h n V. Evans, a " W e should have far D e m o c r a t , blasted the m o r e sensitivity to the p o U S D A and F D A for not tential gravity of this type i m m e d i a t e l y notifying of situation," she said. state officials a b o u t the D a v i d Fors, m a n a g e r of Franklin contamination. Fors Farms, Pullayup, H e said it w a s " absolutely W a s h . , called himself " a n inexcusable." innocent victim." H e said Idaho Senate President the destruction of his : P r o T e m R e e d B u d g e , " a " ^ c h i c k e n s " a m o u n t e d t o a " Republican w h o s e district loss of around $500,000. includes Franklin and w h o T h e owners of the Rile- said he w a s sure he h a d ea w o o d farm estimated their ten several dozen of the loss w a s m o r e than $1 mil c o n t a m i n a t e d R i t e w o o d lion. eggs, said the United Other food producers ; S t at e s is b e c o m i n g " t o o so- ' a n d retailers fared little phisticated. better, s o m e losing m o n e y " W e might be nearing a s t e r i l e s o c i e t y . W e 'r e j u s t getting regulations to the p o i n t w h e r e it'B b e c o m i n g counterproductive to soci ety. This whole P C B thing u s been far overplayed." . Carol F o re m a n , assist- A0 0 0 2 7 5 N 03186 ^to*U. U * MX 4 .- /^-i .CT2'i'v c- \rm j % UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX " 215 Fremont Street --:0 !T!V:: 0 r San Francisco, Ca. 94105 ' CERTIFIED MAIL NO. 552453 RETURN RECEIPT REQUESTED Mr. Arthur E. Pearson Nevada Power Company P.0. Box 230 Las Vegas NV 89151 In Reply E-3-3 Refer to: - TSCA-IX-002C QT 2 4 1373 Subject: In re Nevada Power Company Complaint and Notice of Opportunity for Hearing Docket No. TSCA-IX-002C Dear Mr. Pearson: Enclosed please find a Complaint and Notice of Opportunity for Hearing concerning violations of the Toxic Substances Control Act (TSCA), 15 USC 2601 et seq. The Complaint and the Rules of Practice, 40 CFR Part 22, set forth the alternatives available to you in responding to the alleged facts, violations, proposed penalty, and opportunity for a hearing. It should be emphasized that if you wish to request a hearing and avoid being found in default, you must file a written Answer within fifteen (15) days of your receipt of the Complaint, Whether or not you choose to request a hearing, you are encouraged to explore the possibility of- settlement by con tacting Keith Takata, U.S. Environmental Protection Agency, Region IX, Enforcement Division, 215 Fremont Street, San Francisco, California 94105, telephone (415)556-8008. Sincerely, Enclosures cc: EPA Environmental Monitoring and Support Laboratory Clark County Health District N Q7065 4000276 3-1730 RULES AMD REGULAI .5 U iiO -CI] Tills40-- Profacllcn 0 /Environmcri CHAPTER I:-- ci!VlROiIMENTAL PROTECTION AGENCY buf1oo5nAsr(dtaache):c.roobnartedhnlAoietniwugagIlsiuyus,tshehtfoet4fhrre.eiect1bty9iyv7n0eoea,wfddoT-n-iPdirCa>tnAo-t 4Is02ne2tcCetriFsiomeRnt S ( .CCCB*9eevnyirltfrray(lr-HAB---jcotlSliuuApiorlf'Le-f'..,i-V-i..'.,nnri,so Jt,h, ,30p v iB) To-.;e o) S 22.23 Suppkrr.eataJ j of * trRj.oiwj PART 22-- CONSOLIDATED RULES CP TACTICS GOVERNING THr *iJMiNiSTRATIVH ASSESSMENT CF CIViL PENALTIES OR THE REVOCA TION OR SUSPENSION OP PIR.V.I.'S Interim Rulei of Prasiico AAsCe-rl.ocryeY(Z:?AE)n. tire omental Protection ACTION: Interim rules of practice. Am5smaSp1eo5eUacaC:tturt_Miytacl-fiJ(cc-ueobT\ltsaUoreeStfVhdcCpliF:tinrA;htpIe-i1YneJrp)3so.:e2liTacntnTpcuTectteehuldnehynueu;reaticrosmrlerauetSasidugeluntsousmtetbeoslnrdusir?ctohtusaateeenuancesttncoifriovodaeebfiltrtse-lliheorvpiCnawnesTr-toncla..y-S-ncctdnpfwChta:i..;:cl:*.o:ny:i:e-/l./ D13f7'TST. IC: Effective date: AufUit h cCenivnxadmecrn.taorobneftohree rOucletosbsehro3u.l1d27t2o. re* AreDct3e~d.C;oS:?.: Coctr.tc.'its should be di sWajDttr.ai'.avnivi*cs*aTieioro;nj.xp.Bnicor^E.npPSJ.Atruc_nbD-iT.hCC4a0H.uoiIeT2sM-Csx3-i1jE6ySi0.n,ttrPcec2reec0stet2in-caS7r*iuc3f/bne3/*.:-t.' ror. rTT.TKEP. INFORMATION COSNteTvAeClTe :Lier. 202-73.>-9404. Ts7S;aC^scp:twiLurp"ohcpaVaoohhin-;b-i.ll'lne.*s-rT:-r.sre:.av.:tcate(..:te1as..vi:.:-.dt-?--c.;ru'.,reh`:..;'n.::--.rond.cTtrraa1asrop'aurcM.tueniiIclrseaoctitel*epefioitsswr1rtrn.E.;b:.h'r"-eu.e;uss:t.a.'o.rs'retdix-'no-*).uhtljeiewrplcleasC`lnseteiToo.icbetIdiihntSft.A-trpyfaheh0houep;*oa'*eitPca;a.e'Vrthi:-.oIodrdc;rr..ted*':TevCc:tr!nae.P"hryeufvao.iTArocTprCohEtelinsubnibrh.upnco.svsoolgapilerpircxeooren*pTroeurvOsil,opsceneci.fhop*:dtRsrdiptoaiejanroooeavSieleoMtioafdttcorxunudiemlnorseetitAndecsvhpsneds[uL:pstteerT.csrruaRlt-tadiasf,gr.mIvthlrutcruOatcpn:.ailhttirtrfearnhNre'uet.cecro?eidddeeussfrrf:, oANfuOTnl:-:.-;:n',V-i1.;r2!!c^d.<.c4---p4.-iDt.e--hs?aaArat.rcr*hamueuccomund.'c.:eu:.*:rnr,damanetrirrF..EtrlduuxcertrcchnpuatrutievetnehrIirrOsar.!.Cs'Laarcre.*rt Dated: July 2G. 1973. D ouglas M. Costls, Administrator, PoATL'ocT.yrtussrorc.-ri tPjAc?exiscrtTjtsocMtxCiGc.TovScocrar-'sctCn.uc:ivcm:zis PACtxouavnict.tyr:roxsls- tub pert A -- Gtnaral COS2CC"5C2C2I20CeC0a-...e..CCC-.:C0*:J.5fsCSxot5l34Li:otrrce.r.d?i.iTErSLFCDPnri.dd.cx-'Poteii:ieteiooeow.rirreicpcn.crn-j7*poeiaixuu?.;si:rffU.urmiots'ucio.ttacisreecianleaanraeuarm.nts:dtndlaJ.m:.shtdloc-us.Adeiban.crscJiCeeis;ue0ui.rerq.wa1ThinruaaiiCueiddenoanrel:c.ilddneLacicftso.siuovfn.tfcocnof.miaerrttttc.phrmr.etiu.u.lore*ae:loln.c^urotAc.r.nrfj.,utdspcicdsmaiilu.ineerlc-t.noaiJiiqrmircJ.sdpiteretro,erarf*ss-- Svbp^rl &-- Perries end A poeorancei H2~TL1A1021 AICrc.rtpieueruia'ieniinui.ii'lUccenox.a and severance. t u t port C-- ?r*iSocr!ng PrnevJi; m m iic1l-JACIniicitu.'aj-mivecrer.eitaaonftdhcecamcmcprmlra.ptlllra.ti.irnut:. cf the corn- 12.2M2.J13m7^ m.Dlo;.efVaof*nan*.uda0lAte3 r.lodrecdree.trt.lcser.:: consent eree* Cldj AuselerLied decuicn: blimLval. Subp-srt 0 -- H te rirg Preerdvrs m i Sehe-lullnc the hcirm;. :i:i :rjboufr.den cf 1113 7.V-.Z the fvinreript. usiena, in i uboorl C--Iniiinl w'sciiicn ntnl Moilcn To tsopen mHejn-ig H;uI:Ti MI.-.ciiuiarlndteosi:seleonp.cr. a hearing. i-.bpsrt ?--Appo2oslvstcwad Ai.r.inlitrjiivo 2,1CtoryAAoppprpdeeeaarllsffcrrorommrUcmerrcrsir-.evvteiwewofofuiIinimtelrldo*c:du* lien. Sub-ert C--fine! Order sn Apseol :,2:..31Cl afxtuac'enortiioorrcocnona.p'.puelcr.!a. final order. AppepCerenorndn.atitnxlrtof.ielidsArncu:arn.!c*i.'.:*.-.vt,uive* .T. vonr Ns' -'~l.t tU-*neesK"CentWrie.!<*.A ctI*I5m*;:.mr*..C1I.1;^Iij^ Subpcrt A--General J 22.01 Seope of thi:e r.-'se. cAda2ctatiprptpCrlhov'cornirtirta'ioCceviloirnerrv(rybioe-nit.ynasstce,Lh')o.s.'sst)olr-carsserpdpeeiQa:;IUdvLdSrcrr;dStidoo-.u'fhne*iTj(iicctropanalvresCn.eeep.p)srsce*:jeseterterAt:r.shdldahaesnn'iccA.e:c!iset(aa.ni:oniishtasi:daolipj*tge:foo.lc-hu7narys.toae-oerhr7or'o,retarao_ice;-iows:ii*-lfs:oserrurCe.usiuinoh.srsotsvsT;:;pa.hdi.:cesr.jr:r:cs~eeu.;r::a.hxr:arrc;Israssr.a.,pwt.thfs.oodez*sa^o~s_.aaiad;vra:e-or:aion:slN;'tG*:lo;tyhui:_h]:aaeaf::assu]po*;bs:,-,: pnw5plee2oAun2err.std3aiv2esleurrsInnUaeaodnli,stedhoaoIesnfiwrtSn.ht'co-helr:reruar*.cd?h:.ob?ea;sreLr:raahaan!so:-d->**th**yrfaeee.arcT:sdr:.^mi.e.'ahurno..;.:;. 22.33 Cefinhicn*. ecptmc2shavxuueiC(i7'Satcnaneo1o'cJr.i)'_aetir3e:imsTu.t"Jdtret_A:h"eaa*'esr-Aen:i-e-'e:i;;l:'cris-t?..2med).0d.re1m1Ca-r,.Luo*--r5`"n.7rAittsU;r.a:c:oru-.nt'laf"l.:t'C:..mvA-.re1ecim3cn:l*'M.2a2rrw^-:(57~1Tt3h-(h*ls-: cAupvdJraflcIwJceoouoiueenicole<((c-remdmrt:da:edh-lfshcci;a)aet)aiacopmooic:trli:n"eTfrCr.oia"uta"eC:n.un.aAtmumCrInlUe:.iocseln-atyooslauendjIed-unfpnuat0fc:enRjnteatliI.ochdirrncca.rtro.aloty:sluoa-Si.au.vtti"a-eijr:iey.'.enal...Ai:7rcpv*olr1::a1c-ryi.b::aaitr"..turlo;:;1-:e.or-.-rp"ceo-J..arr-aca.rm:_:::rtayyt;0t::aoac:rny:.;.*a..0oajv>atu:-:fnh;necaaa.ccc-i:no.`u::tt.v32r-*hem...a...a..ve.-1y.a':cU:ee.e-.p..air::r;rehi;A.ayos1arlairver:::.;,.;:: m ir i FERMAI CUT;'. V O L 43, 40. 151-- FKiPAY, ACUST 4, 173 N 0706g A0 0 (1277 Kuits a ; id r egulatio n s 34731 tpIpdsbsaiacoptpItdtvnhirosiiifonnaaiuaeeoe.oorsg<c(((((ers'msrrrtcinJCtsnumaknnlhnis.s>ttte),taaue)i)itsea)lCroedm)rcleAcodlersc"n.dne*tI"'i.s"n"ucooIyocdg`spaudsCH'aTnbFoItnf"ruspei&topadiofkyiJrturlenifdcenooairtoteinedeun,ircae.eicofanfcdnni_n'irsataedSanays.c:in1cUehy<adpew?.lrcnuil.rifienlr?.tpcee"onr..!nti:hhbSpWndf2?r.ninenio:ta;woatiy..etrnc.hAn"Cmtocrda'tacClr,oai:eeEashsr4bedrtdirsenhctlosdtvi.'semnlin.oeetmhaah*iebtioeiir1.rcntrrvrtnnlc)-eece.fbogk"votiiursinsuafaca.hnn*ytdrvrt"uviinor"rmonld.ogeitceplie'aimdase-msesnneenctr.rmtotnsrehe*cbspienrsieremgveesny;orsf'ayeousdaeda.'cirae.:inteobatnv5fa'tndDnoh'bpnnsAnhle5sb1msia-oripe.etsnm;eyc-Cdsarotrcwa-cet:gda.waslf.-hmcr'tosoaapntn/Toihhrme'mnhernms.rPi'cintiiecoipoeTnesdnchco-erppuHfnoocJhsio)eenfdllectsesc.raiaetOhc.ettstdeicobeiijhrhnaolec.adnneeuenacuergnide*-tr--r pgaleamoemtsvcnihdnirgv-hafehealnf$iy(daiiecoie(ieeidtrefsreerceceoocieeanqgppervlumaentogsannlgnracarl])n)isi)ieC1u)lnp.itrtr.raanotctnscso.a.c:aee"od,A"ynsl"nhtan"dacsslynlPgrrnon"ePuRoldoPpysiarii;asddeaRiearomvtc."fArlfauSe.mAhttylecemepPlfccetcinihcelcttoie:rdopvtdlrpcyspre.rpaigpfsAeH.hetioeefuuofimeamAicerenhtTeaif,rdilscefasaenrdsoerrrrtkiedrinei.ndicinttccs.lteusas"imdnjldtnnrmeadceaoraarumAeytocghr.ofeia.l'lrsiemvylid--oniion;inie.esrleoagnsnntsi,fs;iauisbrgthgHnonAotettofgalcininrlyForlendsatnAaciabftiaJlyroaaeyowrdstaut.rfeseecieuetteCoicralifta!gesmoediyicsAoacdharfaraaJagiltoridijreraifeitwgeinel-ovroeguauugp.icnfn*iooscrtern-rnyefvdftfnddetepoihe,g"rnuurnWhfhichniender'gaiaierceihs,l.nncc,eeaadoscmcrtanonentcCasrLhd,ieniisGreterreuyunyryvdae;autncrtadieseeysrra,,n.yorglzleioayopisrtSaihrwre(xilacnoeilgrteeevtonrpnaobeic.oo-o)nofudccrpdsnmedtfssdytlre,Jsnr"mE"ftforreoasrOegtdiuihaf.gaiCep"vtnhmvrntbirrcitarecdtmhoomugeelCf2npcvaehmieoeevynontfgvd.trdeeitesrt.eossrCeoeiiheohiyitie,euenr,rchstsz.roaPa-rtetrntaeoornaetieabhrheninhrnno.ru(oeatdaanroellsrtdetby*do*eesres,,,,s-rll"l---f-) (Ccc.l*ued)fei)nn-:c-Tiddcneoerdint.nRhrsucaeifstgphtdasaeonecindsntfe.teisnrt.!icvwIduniimtLctnlnse; aetohntcfheaoepmamrcpamtytc;aateimpnacedcntr.isnnaogprncst 5 22.iM Po*vr* m d du:i^ of ih* Irulor, rf/MiruJ u-lminislratnr, j'jJictnl offircr. rcupm.il juUici.il officer, ,md ossAscmeacinrmptomocotdgogrgtjttdatgtagoppgptsa*ttsourotmsnaohehyiuohuh.hoilhieioinercnferiirnearihairaeoirrfaorusglfanr((aym.rva(oefopcm(olneodaea.rrerafc1re(iof(qretr(efsyd2etawbd3eteadalecyiayd3Aei-.d2ieidnaaneo5nel1tnleictipipu)lsneb))ioacsp)nneap)roalilcnnsisg))eer)ae)idsalfa)rvaptratrmshecdropaalereegtrtncrettdifroiuslycprlrndlrellscCioaotrn.ioRnaeJcivhAedanrooprsdrEnClayrspgFreeseleeao:poegAffaumrerotulfcojermtoidtjoaollaaneiicir.gen.cruilrumxpetotjoyssovhuy.lrttfptioaUnddenbec.crtem:vsoiaeruuwtpdehdiefitohtnelf,hgviaoanrdsnoinedetneT:ivesocoetoegdieJnne.VcnidlemnrdcofmeetnAeicaciemciwesdibni.frrileraucmecnnanehpfatteedoolnhoiaixggtdsocrrifaiel.ydTld,eamehiudufattcsdaeshctit::eirrbaleaibiolnlitrcetiwoarr/lee'uie?nhktiocticioieapnntosaoahdetanrov.ne,yerolralditrcFanroldrlcctnebiaitsilet.rat'otlsgtst;uoeuirmawhircdehreaeaduaTdtlilisfItuidgnbohsmhepeunet}idojoedraiio(nfaoetnnollytctgeoadoe.aoauh'ti,chrod1nahhe!eeg,,oiweodelalett.mbfryjiind.n*p:;poacfcfom:caard.e'ih)odsuge.oo*efd.mrenfe'rtt,.mrr.e-ffa*v.a/ldaeisejfysdwfur,m-hiiraTiiradseniiimaioo.umt.luanfTh,c.iosetfousereraaOdo-nacatncorotr;efrcrinciryTiocdhidsoidfssiaof*vetaotheums:ieeylcecahaws.neiiecttcatorouuufitetttpraulirjeessnjafhiigheirtoevdsj.mdoifsarhhlpicuupd.oordoe.frta'hsattAi?uao,srtrisoraciciaibjctoeiarlmmiesuihrreraiseeidsdcne.plinosplt.rrfetdebecOgarirernjea:ostan.eunrnstsdttcabrniust.riunsfrchejlrfiJueeeicidscAjtyrcaof:fycogtpcapAneta,iTuc,ubtyerdeatunraoudrdarenfttdaofeihaihoot,fahoeisdiioiioednsileOyhilsaiaatlrdih^iiitrreclfcdtrarbrcejefol:ifcctraiimecuesnoftrovsoienelietirumdAi'tsynenieelenemgpehaecrcfocfomettstiqcccwndarsenridedigup:ifhoar/rpermidideaxerrgeoaidneheugnccmt.aaaaiiwiiratpnlaronafiwarettrprthetnmnifilc7egnmaadeeltooltiihhfstamneilvherenonofsraourrorcaolhhohi.rdaoetilgscnihiihyaicse1uecfeeeecarecelirdefinnnnsnvtooorotctyoiinoeiatircoeineaneenatiisgfeleccselnoia.mtonofisceshfflfsroftregirtdnlmdrifrde,fisldifrhulidcffsfrefhnffyrdetruloiidrucesfawinpsois,siiauxiopiunfiba,ttmenactiieeotcoocgnitanfcatcarindocjhrhrcnhracnererhaabbnleernocbofocgscleoeconepnreeoreedoateoaue'eUereesiuaaeirregordyedeaegsedeos*rryrr*rrsrdlfrfl*,r-r, salt.ahhgw((eoa76-r.w,i)cJen.nnoAsHe.tfdeet,.ahnwraidattrinotaodhrpwraoalerufxtatyaclr;llagiudngudvogemeordeetshvneietdcecopunni^crnooeffd;eaurcecbtnise'c.;c.eo-rs'r. nfbetittmshihanyaos((iee(ecnu98rn1ate,c)e)0hapsseso)ceurRfIotasfr:asDooeeenctsraqserrhdoiurnseueueticddihnnelrriiielgeeenmosslscsguc.suppeisob:neesaa:pttssrrhsto,apttrleiiere.roeadryonmrlscaaeeftstfchooenaotdredtsraaijuneotutahtttgxrdenhhespinmdoecedragedmiltofziT;acfptveaiik.o'acodeineninirnfenf'..cnebrtecc.sartUydf:-, smcmprcmtsTwfoopngertdtevqtrtctt(stlpilamciaatatnttherirhhhioi.ehaahie-edtii*riffhilrrrijhoatdevdhc.eoaaaahzicgoeeil((ffeae'aaea.t!iaeriaiesleda<ewttfmurla2clhmtitiaeaipnintdinsrishttthetp1trctc.aooaclciio)lianttotoidea)iiafealoiplodicrrehlie)daeehdeioorrnsntmoraoytnTwrlinrtrplelnaIrDrrreor,n,diomhririnfrhaogbaarpfrs,aucitiomlrnrfiufsrsitjsiCmmjsuaeifaseti.elvlrriigawmfjiaoutfihguwbeignugJxheidst.ctetuchcdnronrtnit;iA'rurrdhrlriredeiiMiai.ogao-geisosfneedtjmrfhnmrna-agetacninndii'rehyiuisda.enuruswrmhisarntiascbgaeittncloOoaii.go*,chid,tdctdgtiiiylllmdicscieTlrthiilsmtrtrhfvrvsncdfindabaohieihaeoiiim.ptieiraofaeiranorvsoht'coifarpephbeleayieeolsmfmpiipnedoarctlgqgutianrilh/crtneesilessriai*wcafnraoarahinmroinoulttlvneem.ipetfimpoMaceracoatthcorfloles(amhciaoftsiparrco?ecyteflcrcasweitcnaoosiwtftfreo.diviyd.iwAeluriaiitc*iefrhtiiarfdetcca)iaoosgfiidltastmjoacrcliarmrti.fetlooiasrmohetif.aijtnisuldnjqmecfinsiauihitetvcortndpuhti.uhwrvcsofryneneeriidreyp-unohcfitrw.msaearniegnicrdiieaatdeidnimdcnogr,cssiclasrnee;drre.rswcdyvgeyvit,ecalmUghjeahrianeJ.righgssyhrmrursmjeistAoiceedcmpuqioelra^u)iatifmu-ooia.raaadpgec.tteerhd.irfzitorrrirulawhirnadilnlinnf-rtlexsrarfehsosTolalefeT!cfi:aelnnvcdof.hecyiatqignrihtyattqrad/nvcganmicccntnhoaeerhoiwhsrcbtaiebufcagcvcacoiini.my'ieshivadntlstpoepcr'amesre?dotgo.oeoaarraleftrray.teT.ie.iclprdraa*rcerriill'inoincocijttrrdrimoiacnca;ardhdaLirhurdrhrihn&haw.anef.ryli;r.drasnsftu'eonhrtuirditicwfd`y'fs-ietleaeleayasaacuorahnuargir;.smigcmfhnafamwcroag.fwtqqaic.cumcpjcftseicqronirali.crgatiehtlree:djmie*nc,uru:jimuimdpa.ipil.j-auchrrcaors.iomnirfnentviaec:e.prijurerrrlrm(n:niibahnh'aaa.acszcini:oua.oieen1sssmelea"rrivns:cdgyy*yyyau:igne-er-t--l.,t-t.)f-tfv- k i ,CCCISTE?., V O L , HO. 151-- fCIDAY, AUGUST 4, 1971 . N 07067 A000278 'J 22 AND a=CL'lATONS (il) The chief r.rimir.islratlVw Jud ;c. at any ma-ic in the prococ--. .. m r.y reva-ian the crvc'io an adminis trative law judue other than the on*: orii.:r.r.lly assigned in the event of tin unavailability of the admintatrati*."! law judge or where reassignment will result in efficiency In the scheduling of hearings. I22.03 Filing. lerrirr. and form of plcad- inji2nd (io^uhipni (a) o f p.'ecdi.ncs e n d d e c : - TT.cr.fi, (1) The c::e:::iJ and two ccair; cf the complaint. cf me answer. and cf all subccciuer.t cocuner.ts served in the proceeding shall he filed with liti regioni 1 hearing cleri:. The regional hearim cleri: snail open and mainha:a the official file of the proceeding u p m receipt of the camp*.air.:. The region:l hearing clerk snail forward a copy <-f the compia^:: to the presidmg cific-'-r upon his Assignment :o the proceed ing. (2) A certificate of service shall ac company each document filed cr served. S.tccp; as otherwise provided, a party filing documents with the re gional hearing clerk, after the filini;zi the complaint, shall serve copies thereof upon all other parties and the presiding officer at the same time. (25 h'otwiths:wilding $22.0;nKl), che presidir.s officer correspcr.is d::::;:' with the parties, the or.Tin*4 or i.p.o carreapcacor.ee sh.aU be sent to the regional hearing Claris. a copy rhnii ee maintained by the presiding ci^nr ir.m e dur^rnta file,and a copy aha:! he s:n: to ail parties. Parties whs correspond directly with the presiding officer snail in udaicicn to scr.aag ail ether parties send a cop/ of all such corrL-ipor.der.ce to the regional hear ing clerk. A certificate c: service shall accompany each document served under ttiiscufcscciicn. ;b) Service of pioadir.ps and docu- r-.cn.'a-- (1) Ferrice of compicmi (i) Service of the complaint, together with =.capy cf these rules of practice, may Le made personally cr by ccrtuicii mail, return rec-:;a: requested, on the !-- r\nd^n:(or his raprcs.-r.ia;h;ej. (ii) Service upea a eomestic or for ci;m ccrporiiiicii or upon a ;artmerc b cr ether unincorporated rnsociAU.^n which is :ub;cc: to suit \and,-ra Cu i'.Lion name shall be made by pvr- seal service cr certified mail. AS preSi'l::h<*d by subpaia.-rush (11(1) of tni' paraurach. directed :o an off.csr. part ner. a nan asmg or general agent, cr to any other person authorised by ap pointment or by Tedcrai or State Ja*.v le recen e serr.ee of piOccss. (l Sorvice Hcon an officer or agney o the L'::V.tCil States shall be made by dtiiverm ; a copy ci the ccnplaint to ::he c:l:v:r icr agency, or in Any mann er prec: d for service by applicable rcgulations.,If the agency-is a corporation, the complaint shall be served as proC'cnbcd in subparagraph (licit) oi ^\;s p.vagrapn. (Iv) Service upon a State or local unit of CQYemnvjnc. or a State cr local oUiccr. c.cr.cV, department, corpora* tiCj' 0t'^cr Instrumentality shall be made ihe compiami In the manner described by the law of the State for \hc sendee of process on any such p e r ^ to n (A; If ^hen a State cr local unit cf B0vcrm3^it<0P - state or local depart- mer.t. asc^hey, corporation. or other mstrumerttr^jty, by delivering a copy of the com.fci*^ to the chief executive officer thereof; (3) If:vy-ou a State or local officer by deliver? ^ copy t0 5UCu officer. (v) Prp^f 0fservice of the complaint shall tj$. tr.acie by affidavit of the persen i.^iicing peraanal ver,ice. or by pr-'pt-rly return receipt. Such proof of ^^.-.-{cc shall be filed with the compia:?^ Laimemately upon compieLien of s^N-.-^-e, (2) Sendee o f documenti ofAer t h a n c o m p t a i ^ All documents other than the c o m ^ ir4tniay be served personal ly or by ^^rdL:ied or first class mail. A certifica^ f serr.ee shall accompany each cccun^*>it served. <c) T r - ^ C f p l e a d i n g s and dccu- nrr.tr. xcspt as provided herein, cr by crd'.y- ei tine presiding officer or cd.Tnnvitra-p0l-imere are no specific re cur:...eiV5 rcenas. to the form of docu- (2 Th$ first page o' every pleading. eUf, pe-sculler document shall contain a captif identifying the respondent *aad ih.&tSocset number which isexhib ited on tt* complaint. (31 onginsl of any pleading. 1</-.t5r 0f`dther document (other than exhibit^)libali te signcc by the pany lf." o-'fcy bii counsel or other repre sentative -yhe signature constitutes a representation by the signer that he has ^wc -fading, letter or other dJCumAg-t, that to m e test of h^s t.cTvlej&g.%t information, and belief. Lu* rT-.ada Uiervir. axe true, aad t h ^ r.Ci.ir.terpcscn for delay. (l Th.^-initial daau.-r.cn: filed by any persarv %fhail cor.tam his name, ad dress. a&d telephone number. Any changes lTi information shall bu esmmu^^^-d p.-cmptly to the region al hc.vs^; die.presiding officer, and all oar^;;fs to cr. proceedinj. A party who finifcj to fumuih such Information shall hV deemed to have waived his neh: t$; notice m o service under these rules. (5) Tlhe administrator, presiding offi cer. hc^rn.jdori, or regional hearing clr*.9Khy refuse to file any document ah:c!>cP0.;s j.Qtcomply v.ith this para* written noiic-* of such refusal shail- [.-rompe!/ givrn to the persen the document. -30 Filing and lerrie- cf rulinr*. ordiTi. and decisioni. .AJI niMnps. orders, decision-,, and other dccumer.ts i^Liied by ibc rc-.cnai administrator, regional Jud;c:arc?:V rcr. or the presiding officer. ac'a'ppVopriori*, shall be filed with the rcg'icr.ai hearing clerk. All such tlocumens issued by the administrator or juu-'cill officer shail be filed with the in.-mi; clerk. Copies of such rulings, crec.-s decisicns. or ether documents shall be served directly upon all parties by the administrator. reg:on?.l adminstralo.-. Judicial officer, regional judicial c:.'S csr, or presiding officer, as appropri ate. 3 22.07 QoraputJtnn in i er.eniion of tme. (a) C o m p u t a t i o n . In computing any p.uicd of tune previribed ur aliewed m these roles of practice, except ?_> c:herwiae provided, the day of the event from which the designated period begins to run shall not be included. Saturdays. Sundays, and Federal legal holidays shall be ir.ciudsd in comput ing tne time allowed for such filing. However, if the period of time pre scribed isfive (3) days or less, interme diate Saturdays, Sundays, ar.d legal holidays shall be excluded frem the computation. When a stated time expires on a Saturday. Sunday or ieral holiday, the statah time per.cd tr.ail te extended to include the next busi ness day.- (b) Zziznzior.; of Lirr.t. The presiding officer may grant an extension of tune for the filing of any pleaca-.g, docu ment. or motion (1) upon t::::?:y motion of a party to the prccccuj-.g only for good cause shown and after consideration of prejudice to cider parties, or (2) upon his own motion. Such a motion by a party mav only be made after notice to ail ocher parties, unless the movant can sho": g:ci cause why serving notice isimpractica ble. The motion shah be filed in ad vance of the date cr. which the pisaair.c. Cacument or motion is due ;o be filed, uniers the failure of a party :o r.ahc timely rneuon for extension o time was the result cf ancuastie ne glect. (c> 5?n;;ce by met?. Service is com plete upon mriiing. However, -.v!:;-? -t pleading or document is served o:-' mall, five (5) days shall be aidid the time Allowed by these rules let ---' iihng of a responsive pleadmg. 22-Ci Us parte diseuicioa of procffci-'i At no time after the lasuar.ee cf :-"-f complaint shall tiic admuiistraicr. r.cnul administrator, judicial ci.'.vvremonal judicial officer, prca:cu<g c:-'^ cvr. or any other pcrcon uiu - advise thca* officials tn the decis '-*) the case, discuss ex parte the m;:.:-* :; the fprocecduic with any iniL:1"--1"- FC2AL V0 U , NO. Idi--fSIOAY, AUGUST 4, 1975 07C6S Anno279 RULES M'O PECULATIONS 31733 .j:setsdslciT'iosputUruecenlnTohrrpgzcnrcef.neshp.lhaouy.utcoo.ieeth'.rmytomtfoh3',cirroeoptursr1e-cbimooar.nroinr'neipc.fonlf./oni'Ahti:oiumricy':rs.dV..etm:ne,eyehmrne'o(eJeir(p.reomrhArr.tdta-aiieTon(pivtdirniuripmihns;nrarcet:.y;nr;rvo''y^ror";;eoyi<::;utr-c'picc.;hi.roApns;oamtlnc'..reh..y*oat''r'u!:.,eiirieae.dn.to'dp!e*'-thmm:sacdanoni:oirnae-rduorej.of!.oreuasrrtsvs!.ruc'uvsidpepa.dclsccilani.:bnruaeh-tcwcnryl.trrdtdi,eniio'adJ.e.u_uaauceecntd0i'liolm!-arr'eeervg.omrrrccnraoiepdp.lfva"ttitnfra.rohecic.efn-coro;ot!trd*nne^*ony*--.r.f1 3 Eiamiiv.uion uf documents filed. .nitjscdczebSpyTld:obrteefruiiuichryinnalb.aprmueetnagijtirtdmnacedaholg.cdcceceittnelocneheioseptnAetrsaa:odpief.cpvnoiyrnoaysotrpohgnoimfualreep.nabnayrbdlytohSlpiliuceecoerubpdmeeanculbover.hidsiiydiccinnisnuiasaiggntctodemnhiigsnonysecscescgosoinucruhpputhemrriierfgoeslifreloi,suisolnlcaorebna0uotswndess-1-f, art D--rcriies and Appaeraneci *uer..t1pfirirnpvosAphScesaahrempetolr.fiaa!repntptaoryrcde0syouaaas1ursmrn.sbctaadtaeoancpcfytocaapoohtcunnnireeao.ndefarproosrppeefrtrmhofletecihreacp,cnairercrttcerisoiooebsnmenrutethen.harphqtetyaeesaurPlrtfaiseiosrrpvoretfesoapendponf.terhnadoaoA*eaa-rrf Int;rvmion. Viitmt>id:f:hiy;rnjrTfrteeavotioe.oioaefethne)pcinahnniofm.garr.egtnofriogcsg.errenli.ramtcitnfel.irnrrfdctecrcssoailh-panettdelscoeaenwuikeeriap;acrotfmrfdinAdcib.iav.eeoonnlpdco.etrifele.snrard(ghotoarsfr.rr1pynATh.uorlhscce'ot-0tetesashefi.rcrrtohrocuvtpoa-emisr.5arpeteiveicievtpeer.1oed.opei?tyotdceothntir:nohaortm.uhsrthisnhety.fittretcoeteeto.boidno!ecnsro(oeycnrtnuec.eecfothvaaistipfi)eannralnhrceetobafemerfsctdshonmtoneiorstdufu.:eemneefeeeprfaeepicrumnrotpronnyrvitochelstecrhrccggreteiswuhr-etocnnie:ai:.euen:fesogtceshvcpidhrsnteonetoonlAoceeeastherer.e.dfiisfeidrd*nenendrar?oeeetittiinyy**eoooa*gc***a*-aftr- bmmtsmbsbwctmdfmt(rafostpiaptdccasmstiftcutash7oiohooiihinihooehreateheferrgreeln.ngfoo.oioo(oie(ni)eurieteaeeaitsinmta.saymirnbdegnacetvhuinneltt.svsisdljdiletslinutjiifeg)i.lriuiirieltleirg.mtflmtaitaeoeioogohnsaidsdetsovrtnoldwrdnp.enmbeanhijnbntiaehrDovnioietgetbrbermirsavbnstpanrxtsohlshlhseitcetrn.lasne.eirelinseiseghe,dhgfytlodtnyteeAedseaewtspturnfoeri.rdueeahopetpfypecipaataaemQrgt^smimlteteIqmthtarirpwgrsra.lsaonteruorouhfnfherlpd,eeueJotu,etadotnrirdipdsaaonucrmeseiivelshl.rcesseaapfratbidtttltdecnnhtppdorehuhtfisihihscaenanteiaisioseiooittpinitcouaaoeiaccsrteatreodtntr.ecrididibrniusnsoreicerlerhnelanonfn.lttaoneddrayoeyiiaraletisceirexddndpliaanirinr.ceronptldglndirpfeut-vat.doyyh.tgsrpif.fthoooecerigreufcpaseshofoirjbLenariae.onunrstreefutefhtn-gr!iaoaefo(rorcopgpmeihypegnsodliat1mraaiAtrmlrliydfdapaeopeehreetlea.n)oamltl;mfaw-yhvaeatnclslfouavxrelatebtnitnchydstawohraestcivehdo.nrlaiithPit(ouotAg.tnc,esssetfymaiteeAhpeueettatthtoumiueeivtiimncinrsn)sddntrrememaaoooeopfcirnaotatomeimitu?cwt,srmgfwnstaorhrniionnnaioeodpuopeeeecu.tnoiaryseftataind/arorhistlicutiIsnetstnifhetcTtoiynnnonentnheintot2htmsboot.dertarsohccbehcchoindmghbr.thtebcmrnxfrsrfhwreceydebeecefueeitwr.iitiyeeoetn.ieosrerr,ossrsourislrrasssnvvt.wrefvosiedtbhTa.hvtrdtrtirnTpeiA,taauAftefnaaJssmettihteyitniiatahiufhhaihrahnlnAouaeveonnhhosnaiosnls'deniuoinei*peneeesoadeecegsaereyi-sefne,eaetnlyrt;a 522.12 Consolidation atnd levennec. (a) Consolidation. The p r e s i d i n g o f ficer may. by motion or sua spunte. consolidate a n y or all matters at isau* in two cr m e r e proceedings darket-td under theae rules cf practice where there exist c o m m o n parties of c o m m o n questions of fact or law. and where ccrtsoiid.Mion would expccite or simplify consideration of the issues. Consolidation shall no: affect the right of any party tc raise 'sues that r popmtuflrauateiclanstaitaccteicuvp.rnitrldouecpnreedetnhdearienlttgayhcetfboayarncdtti.hssthehueeians.mgetsair:yasu.l*Iecmnsoscmctnift 922.c14ompCloainntte.nt and amendment of the parcisashwslp'eoporiuelraloh<o(q((c(tc((anpavb453i152naipu:pinot1r1e1ca1)i))naooeornchsoiitAvsTspnSieCAsnfisetisit(rphesocodeo5thciAwfaeedhatlnsrfo)oapiacphteetctnhlrrtietoaeailyieoeofhcencnaftanimnd*pisieaechcelstn;tatlorotmoetshaeccholi0rsfrstnugeltaoef/eeeesyuegninmfdtsnro.ndmac*eatdepeft^egcooprttsnoe:eoectmnlptimntnanmfhmnahonbpidtaceruneenetneilrneehtatii^dlnnyh;aamnvceinetttmonisrimomrno'estrtceeitico.lctnics.f:raa'zea;\iuvs,Edittati*scat2ihnienhccoarnrnrt--gehecntegipi.g:ho--gaho;getfnelphfhenacrtdnfacottotnafrhlthvmtpcct.iuesysooei-t TTtcsetcmpbtbcpufaacfpIAaaihhrnheodioommeellnmcolhhov(oaaret(etarfmfmcsddccyeei.bmeciototioeileoo)aJn.ienhp)inopprrcudomccprteterdmocllathn.DnTcoyeiaAahcepotmWapfnoatsmttpiihhidteesamwehmhnvnivrogepoleeidndnntpiaeeafe:trarfloihpdleiyhaaaiarnltnannwtanleahnaipsaddnimfattchagcnlteditihnocoenrttyeuicnyefaat.emeaanosenutslmoti,sncacold*evwutwwoaatrfeaetnhtoaeif.pnfflterwlenaeftiytnbuhgirptorrcicrys0rltlpeyluutiteiraene/oretnl(eoeiw.mhlisrhrmia1mspdeo0gpn>fjv.tmhcha5tui/rhsaeyrfifaooisptia1recdoyinlohesaolimullloij?etipgnegtdalftnutatyc_nafihehpdoiphyrdewdoobmennteaeeat.rpslstdainfe,soenatiewnecrnTiwtoansciatdethsdcgoincdhtfiictrcecaefdehdoovnopstitecirtonr*attwr'hminelavlmitvu..een.enasyc.nhmhn:a*aeebrrciwdpAwegpe*eypettmlmdilua..elhla!ir:eu.acaycsdbvsdooteTiprpopiaihoihianuaefnpmnanehosmnrmjanbfeye.natdeetyontieneyolueedyds..:crl 9'.'2.15 Answer to the complaint. c o u l d h a v e b e e n raised if co ns o l i da t i o n smhctieaaea(vusdbyes),cernerboSdtysnishswosmoecuirwcoetauhstnnir.o,errneezo.dso.prTfceehcsruteataopsnrpeayosnriyudpicron.crgcfoeaoelrlfcpftpinocaogerdsr Subpart C--Prehearing Procedural 27.13 Issuance of complaint. lpierIovfveitshtiehonactoomfa tphpleaeirnasocatnn torhhaarsesgrvueilaoastlioaotnend*topabrnoey- scspAmipatttnechhholtsn;erg(uana-:.vay:.selJtti)ciltneudoccltsetdesfrobGhrtiuiwgmsfle(noeeccem3fiaphnt)fwathaentliehhlacnmyireweiotettadnhhonnmrlticceaiustnwtoeowsantVirnmemtsitfeeet/dnaihrghprfpsotitieallaafeomaattrstnlehonichienUsannaefoawtttaltr.t;tta(cereeh1hietshsrr5e(encp2e)uatttio)0o-prondrrnnusooaracatdvanpmhyleelerltapesnnyynwwcrtth'tacoe.i,lhiptesuaniplit.m(rarecho*-rTosrd.hiesr-:., FE0E2AL CEOISUS. VOL *3, HO. IJ1--OAT, AUGUST , 1773 N 07C69 A000280 :-.* 3 a R'J'-'S AND REGUlTICNS sadttuptaihupnnelJcae(aosmnsubiwlnwtln)naadaeetl.rehlrrllCredawof.sgase:ochiacsnnatahhtthytatilueaiaolnoanslonyrllnarteslsnyasetkoos.lxccalnoloprcdseokdfclntaewnaaaierioxttttllnmiheoewymodeeeln(gcedwaledJa)ar-h,gnnrdiiteedncehWonhefsoithoehftdcredrhesle.iar.rertesccarpTTpueot/o.emahrthma'nserceev-, pIsssrlwutiufaacpldtacilttnerhhnneiupehehodlollpepi*o?gh(tliaqfaeettaoremeinnoo.dechnceeuiiaeesunys)gnn.n))no.dfpfncdcrp;tdtetsd,iaho.et.d:culdiirlspi.Ratcemtest,setrissogmetpttifeuioea(pdtnctahmrosnra2hi.onrhnttootpi:ecctn?te)o/idc:a:ctbdtvis,nefiloso1*ntsspi.oeyanuhtrdxitrcnwch,r..nIohhhonaadrsreeapsgocma:aee:itnieesm.s?-ninpilnstntlasfutasoohhlalepnier*t/pcwuaetoV.Ifaffetyaeooanr.r!ssasucfofipcdpiria.sesirrAtecaintnaouca.usamantrr7treatnreyruenmrhdneesrtrrichn.iyiaderst*dcity.isees/naetyi.gcesniehmspinhcwstgcerirnptoiaripweoutte.edrrhoemdhihlbiasdarnq.ttlnsmlthqIeine,ehrmhapi^cdiusattiurtorngr'epasbhrhrcyohteebciidenue.oeeyeruhtstfneetythecsxteyqrhuitmhehrtogtnipe,tAebuhnaetatecatheyndrartguaehtheefsdnlnoahieo,rs.onapsl.eershsmniaaevdhotrdfn^nnotwraneneattoa.ohfod*pogenepnddssahciuresoletfcdl.wwidd.Taem,hthrrap-ortueagridfe(cairaheheo2m0niocttan3annreaerlrtrn??nee!77-lrlr-),tt...t" tdcrcr:iwsmm5siwccospshiCpprh2ceachanure.hru:ca2ri2ee(;igpel(anma.raarrota;oirv2eb.sm:.y.sihten1`j:ihpe)iii.trre.p;ljuelcCcf;S:\:.t::Vf(a:;?rapiZdRfibe.ipocno2rmnon'r.rCifewe.nleaisojmdartitdIevwiieustehereoavAfisahip.tatdnvccooc.ihrsiirdoicdcvedodetr1armhtfeerfefchimeuaidene.iornsisAadlibeptmoodltes.eneeonmrcemrmhayavercddsertire,o;d'r.1cr;,b:r0mvzoia:fiad.tateos~rysfu,tataitais:hrmorlhrautAyuoo:.i,cnrrenicnirsoyln.penius:dtlralyeicstu(hri.iyoesgiltcerh:co1s.-.imueodienchtocdtr0,aoago3osinar.i,ntms)eaTahbencfp)b.:sfocoxgyatumtrfoj.dronoe*tc.rceicaxe(ptTusnahrdtTdh1rruenpbsnseiaroyrheanol).rei.pe.hrdacintndoscdativronyentmheyhss...ctnidAic*vnsaoyfn(atede,eaa:4iof,daIpnolgrdtucvstsf)mfercryihrteeiwmmftnteehmcesgoroorihdrobosmooedxesrp.nfa.mreeitotwsicrfeoacdediaahemttiootatvnrerrttiftmcreaa*.hriebhfelnorpoitisoetet*pertlsydtney*odegees--a*rt-*r-r--. .siwospmmtihfroioaffenlanclitdsleic).oliecebdneereia.rxan*Dufoscp.gtlaereeeercporOrytimtfhsurtfioeahaipoicxrlteonteAedn.prMadedrsrsomagihiTvwnlrualiiaehhldnmbleeeiomlsedrrefteoun.ratiltaAinetnothodnoo?eirm.nnn?2ic2pitano.rimfl7aieinls2llsoset.oiritddddTitaoehiethncnoeorgeissrrr 22.3T Default order. scnsasfacIrsbcasdadupattpou'bpynfmavtlthrliwochtih5upoauiellnposielrrz:aeprfaoeolirrstail_ugol(ig0asioeniCceiaocxfdabeoeaamaapnofpysbetlattdensf)ihoshnsledoac.ixiulntiheha-irent)i)cn'ulaenz,::poprunmndulircrrteaeopcdmrap(wiaha.satderfslecDscnii1crtP.iacCbrihcccaeearen:it::t,aoadcnrddiaeAoui3ceonnoorrisecssecn.yutotdttdcsneoeu?tu)tipfpgahnrntnohfottssidfiedmnieteutofrc.aecsrpphodostoifptdoisehae'df:suaireffuenilestheazelrouoritnsennpifueruaeaa'aieurartneindvdolsrsafieebnaelag.dyattv.lllruutle(faftcltgoiLuipcandleaeauitepe2bha,stidtenlnlrlp.farcsr,iocoenitfAtii)teerlddeDehgnuecnea.pimnntaeiisrfdoahfio'attinnrrueessru.se:sgrf?Dniredeieslohefeeee.ppichalpifogt:aupna)oifdadhfawpfucmt?sfehaerptstea:hlin:fipuoi.orrraahetatuiosnracuhamsp.otefropisd.,rieaionpaatfueeurcerlteeerahtrlndmi.eliarrisfalao,efiynto-soslietscirlsru;tiawiyguettfrnir-arctootnfipafnptlnnpetn(llhti.ofaonyliptaneamgnnlns2trayrfgnarcfnrahogmnbeadiicr.oosdaiob-iopl)dl.gdutltfmeeanacailnilht.amcrruysiupoTacobseom,olejyotNraeddhdsneaaosoictuerhr.yfpptipapatrhfmlnh;fseeleusphotfionhhsradadcebarloarobyaeaawddrta-iddetetlgoeebopeieueeeerrroyirfrlnifilasfcedtteeistaleseotrnlwatrncdcalrbolihissiecyryiyrhdfpnnrtrpci.nceiregiefhdwpeio.avbrcil.asde.eidoadlrmostr,sasonuaieieaeeiuuwmfvteipIWreicni.ivnelrfposlsgrosnmntsnsossestflculegfTisfdehipsppisynAcTieaplaghahdttshoiurapouaxaheosotihtlaeerfnusluaaoinmheeoaohenwhoneoiduttcnsoutaannictnfttllfllldyyndoddn*enyonsseee*oefaas*tlfll-ttrf,t j22.atbm eIenmfornrmi aanl d orsdeetrt.lement: consent scmqaeeoutliiionnutbn?vc(emircelde2cnn*inscseg.)ptstrriuras.?Tcl:Sr;tawf3iiahiiwaout2tgnhtieniUh2miarleth:ee.nthrieehmestnstAaoe.eeeteirrphctftincto:neioatfctnrgienhirrlpd.inecapecredeconeScnrnlsvotateniae:icttpitsmtytnhticpl.trolgeelaileenmimymscTarspaeecethepoblhsaoneynprlnnenteototdficAneceariesscorncdngeeinbtseewrdctfwjunnitcecirnilctntrecaee'hgy*s--r- cpmhacapttlstacsasowpttatiiaehhhotonhhginoralegrrramrtilihe(eoeincdyrnasrmadcneermbtsueieprelslese)gdin)ltnlpe(eseeorsttdRipapj3gaoometclnCmnusftIrrraC)ds0cvoinoteottoasroioategome:eocdrnicu'tacaxcnn.nnttwtwhro-.etotectgihsoaisltsah:tevneetre-hragrswineiiesmiedtsced-recrl(ashn.Ted.emieeaa2seittonchiilnalonnrhtOnenmh)eoonalgagagutotadPmeDeinlfrtyAsart,oreantlaitm.lessgd.em,drneqedUiurtuieeedranrnonmceatmeeuiermnn.ecnesneifnstnni,oqcoetdioriontrdcpecetittrh,uonmipenyrelnnsodaneNsueianrrtosoi.s.otnsrthnehojldoesrtr.et-w-adnashepdre:rnt.ratxp:l:.heptATeoeershtspc:ltsTenicee:lrhsd:haeeptcaTr.cstetttsmnafercpietidoeerdsachfaeulytog.anur:.mieocrmre;uicir..r-mtc?:rrt.ivcsp.ceIa_rhrs.n*ftnecsr.na-r-bcecctVaa;:.::.rmosddi.ren-e:3:r.c1f:ratri"esm4pf.a.ttpt.ctVc--Ateoucut.cfrahrraireirodcouaooamqt...niree.*;sat-ff!tll-J` 5 23.13 Prehtojir.? conference. ssnsnaepdicdaa5irpnampUefetpmiobt0nhniheohtanvavhoxnmoue7eterereoig((n(((((C(ceopb(atreereeedorsarncdpccbpf1573324nce.a.y.nlnoeesstrrontiieecti1filu)e)le))))nsi))hdlieeleite,dn.titpeprrmo:aeasdrhelcsd.csTAfd-eeTrSdPr,RaTTatotsnbfcTc.NiubeemesdechnmrhhhtonatlurhbeaeohtnhnnphriHntioietoteaugfeyoocte.r.y.heoborieetnercoseerf.a;tzcetpaooafeytdsmiennectwer.otnporoiocasornso.\irltoc.r-nerrttsjiiracpettoiirfntdtiaadsg.tohohvaoanshvmmixethfirheats--hunhetomnrUein:reirf-e,tgsxecshpaneLsekr;cutelfoidlcajeonisaigs:ohvonaahm;pkeefarpdtrueeicicdafnda;raarstraclptfomileplardtiettiwtlrarim'erbcylepsctioinnsstnlprnsrnotiytxuiftmshonolst*usi.e'heoepiigogeigredsntsatdtpwhtftuebnccsfs.noesseayptanneieo-tsCouaaiaooeiaemofotnhdpttirriebddroleptorlcuctetrrc*oionfLwoemsoaoplceicintohitrmsaff:rraeononsmnztnnf:fetfgichifserhselrtpe:prscecrficgnogglnduaafoahiahi,ce.;r:anr,.sfterptenuefncsdwrrndcriaures.hah:mdeenmon:exeryyshet-.eoypecnoopnhee.e,gxtd:,:f:sha',s;farlht:"-?o,,sffairjqVcui0riatpr:ia.scifcpctfecsasen.brOrof.scemcwuiihlotaorahp4lor-earsccuHeinetr*lcys.aaaanhustinPth.aemnpruj*me-fcils;:i#ilm-uhaet.tnifr:ee:l.:r1tfen,ri:e-e'ecencnai`.Vs:ooiybrr.*ra.e-.:nrrsoc.dd:r:eap<tce::sucr.Jeyreir;yce.We.ynrnrciT.at,etcp.w'rcnriwarurit?cthccfe.eerco.rnoheehc<inar*eciceuataeox.ixudctentrcdnegeyeloeehsdsfr----.:-ff-lsr.t FEDIRAI HGISra, V O L <3, HO. tit-- FRIDAY, AUGUST 4, 1973 N 0707U \000?81 -sstcbwtpcitpATvAnurbIshhhppntucerrnyathgcr(eree(eeociilnladeinae:e.eevosrhntf>tt)sent.p.itoepapmedttedescracebsrjalaTnicyouoLdr,Vltjnnntsreoefehv(mthotgmo.i?i1pc'rseeeie:IccaiEdtd1)nttmh.n.eRsaih';isiat:eeur.i:orvsp.yoe;ett.or.ata\inhetijrfgaosrh;hoSurc.dfers;reen'ityeii.iyn`oihoihl,vcmcdc:easorr;neee.oriecejeic.ata;rrrpooasonti;cai,.wtlrth,l:eLnriifot"rytpil:seiaij.nisoTtu`yoo.lsihhnrldOggiar:n.ennbumfneteo:ocri.ir2f!ikraf0nrcoti.f:np)m.lhpon/rrwimodgi;n.cimatrrc:mnahaee.Auo.oscoctic:goi!drictpraitrfc't:Li..-icprfhupl:cohan:cpiiiePrccrossisoncsnoegrrrsaenrrhredric.tentboea<ehvdrosthfglltittcec.eemneeoeaaoeeerircdoc,rorrcnptacs.eyuet.rhrna:strpih;tAnnes/i.ootttiecarrohheuntlcnolnrotooaeelrddno*egaeeyrlif.l. } 22.20 Accelerated decision: dirr.-.isjaL uscpmfwmaapfoecsscswhcpsdheaIutpousierpdhsxlplratoinxreeepoh(ao((ai((oasl(ylryedoiarerand?i31talbcn2oetnuiisitnvrtsshe.olih1ncm)ch)nrsho))r).tnyetltiteptdtvishaiteeidpsaliiecwSnNtsri/oaZsIlatiGhFwitnya,tawraerfdogmuanprnuolherfs.eiriatitidlimetnenfmeciacsrganldtanetsyhaitoilnwetclhsngd*olhccsltarrnajeisatetulcscu,duaerf;teieLoiieyra.cryoelhoeoeenortnlpfeammmslfgaaravuhutferetenansdur.h;flcc(zhpiritcencrdeai.np.r1cipdit.oc^e-nsf.ra.ceaelntj*thp1ciaiiatceroecaeuthsnhefeon-lrtcoe:rcoaTsernorrlidiicuauderlonIfitienimname:ocr,eh.rf^yrrrnicccbtreriyshwe.tfcsenrpo:eiseast!ieeers*aapas,tasneodeinras'totriedlahn:usatnctuon,srfea.,n.sitwatditvoteiilacuepufednnynrmualdenluireatneelairltrhpnce.dpcoaagneonidverlinsceiot;dnrgwhsre.ont;fMtgscesodmsacdpt.s-enht,ancitilhhcr.reiceudamdeectasisrceeautidaliltrrrcrvisd.scuiaoldceeunah3etsilatnaseagiwlsos,.cfaoldryihpi-domaer,atsrg,omsahrnnreneakhpinoetaostintytmf'aytrbithat.oriiriduwneeriolroicsiooledleadeedaooniCsihcoairftd?amsrarlaftvoflh;unfiicvhfiidafuilfnercsirlrfpacelaoiaasiiotedttdtteralieouacmcehnomrtnuehhhcecsugoocacenencbertdynednadyieees-srrt,.ttrr Subport 0 --naorhg Procedure sA5atgppihsirv2ad(osea2reaimnsl2tclliia1lnediaWlrnsiwenihlfShsogueijctefmuarrhnoahdtestitiideihaensieuliesfcwealiaonrposrs^mgLriropscaeptchnhrat:lveekeannaesliioniJldnewdtueinthitrnadn;hiegr.gsgle!rinenfttrMoioa.lfewndiftd:iomhhnc,teioeiiltfnrhyC.icsesThhitetriarhhreealkeefl RULES AND REGULATIONS cwfqmh(acmciocnahthds1ioeancoueroeeeaesi(5a(<rrrtitdnraaseauntdcliyio)bi.rrsorfmjee):dcu)niiefitssddnebnnnenoePerrpLhhtNaetgegegrdhf.rocaaoyio.oionq.ooneeasgllsfs."ccfrctuvgllrntcmoiaoopehniearcdopotdt5npra.bueocseoishdnrdeofnoetc2arentiTpfeseeiinooot2srrceecnlrerhvitfr.arnfareemeanep1dhodeeeocuond5ghtoeranfeeosohtct(.enanipecfnhceeebuftaarefceTr)xtLiheayspiorhe,eemuncirhheiosrtedofnitenietlgoiiuennsahwhfcdpgsdhwtnrtgcedehait.iuehisehtn.ntnanteh.rtaherep1pigo:t.hguenraloael/rrtloiedphlfrciteenol2cnatih.hossespafhng2efieaieniasrclp..gbestTdot1itereisea.itfi.mhhThJranhnmefnrr-feeNoenetghMgaardegiaiaoasrfsleoeter)tlpwhtrmooppps.teaiitiooenfrorilsrahneneaof'eee.rnedgnrnreldgyia--t, ssTslccpacodc5oIcmnstadpootwwIpisittistspBSataiiisrthunonheohohnoeloraeifiererrhrt2aooihndraruib(i(ie*e(tcgneaecrsonmmmednansnsoe2eattusnadbtcmaelndfilnc'.lnehssthvlctcees2edlol)lus)oinbs)l;re'lmiheslpeeoluiteeiresmis2:mo.icunautdyrpytadhdsuenvtres.rsfthyoeoopoadcogeedVtrlaGduaieefesaeccrateeTw:apoosrfdensprriiuerreadurpteloncnEtpinncndcvadhe.rdrleevmofochnhtflrthlcarwdytfvtoaertintfineieashem.mfiis.dfhras,iaeeeeirsditvocrf,ufdbtpiuyrtleisdahcoeoheeliscssfieteitnlenesrela*iercrehdnisofcipahdtitmautmyannrvegmad.rtahdnhadnht.spmbraabsetlreinpmatssintaaouercleeiavsetltreaedrbaIimcletaiddnterlehsdastesasrcyeeas"neaitreeyeaoasrespe.weegsdniislvlwhiipeaTaivtcrnumdtedoeunpcecgcchpcifrgfeetmixiiaetotaiecvdcvmU.vchiiinhddnooaaornhaeeomsndatnssvepehieiiirnaseeerteinl:eirantfiomd'?wptdndimn,agyhtltna.etsinyrodofsdsearf.,nsietreehoaalg0.ttirlhtesitsectcoinirurtnue.iocsn.b.no/cnidtrlhdnpreuioeaacaetrendoue,eroteoobnetcccfTmreefor:emn,dltlixcioaeti,osfnr?etudeenoleaeltndonesscrrhei,ursssc.ftJhifis,ins,lutpecceigossnnfss.otnhnneeehufaiewiodetinnccrtr-eelo.ssfsidinosaptachdidebieeterTrnaaweorxsxeewtfhcmladhihToellfttusteadxji-bscdcnicfcnacl.aimbhieeiiersfieeinsloplirehadtoolrsfecauge.dmtotlsracuyleextehessranrptrynaehsneeenipiasirttsopti.emwaoenhtmisnyeeo,shnursvywltPtsonrpprmorwareet.esaerguIstwsowitneeiaautoifaeoeaosrironmflaisamdimqtupaoeitactteaeyntfrwdp,Wharhdortrnnmihuiorivipitptpguaslheeoitdnetotneeuiticiifeeeiereneeiirhilkuccevvhcceifntnioeatnntoteuandsrnoeetisrsrrtyhdghooiieiieeassoneeasr.flr,ttt,-r.t, 34 7c 3 soInurnba:jefofcnitrmutopoathnpeptrhsoetpacrtioeamnteteennorttsalatnhcdcrrc-ii.h--.r:f.-.'.v; rt,?. mnokAttgtcfosotnaotihhuhoinherftcrdefgvaIheit(arireotaefsfmeefygedainiet)dlwscnn)cnofn)ilhieri.enocebeslrtyses/edyahrrObedFj-Iaaudjdl.eweiife-rdfcntgmntaidmfihhxahhaenu-teinefaOoiacenkhoqirigillyatisdeitui.peoa.ufbhar,finedaapiaelsnroiev,otcnotcuee,aweinontdwoasdpnsvmFfeiuicWreooanit0doehntnhaangiathcd/paehclyniirocaanecxbeppeyegpsn/rttplrboap.hloay/edeaeemarraolieett:rfd.drtyhoOvriafsapoctcreif.peuriTvtrdoofnec.ctUarbbf;uhaneeAoscaitece.srvcaere~"epus'cttaicioiysiipotatjchcdctterusu,.ltuaruh-c.moscdn-cbteiea?lV.fce-it^rynlx;-.dcrsridieaiii.o.ri?crva.o,ca._itov.;.n::;ifb.l:z.'n-cc.-cl-o:c;-~.'r.y.?ecyc,ret:-~-;\'' scsccsdppcWmsbmtacbtepnmoausdteopr5ohoihhceuhtllholaenxteyeffreapruarero2uuuae((aaraloeedccaednrnoahcrra2ornabiittddd.yytpnshohtlttaeipbllhcesueo2rei)n)ylihneueeuliacrridiferir2ascemfantosbnddd.ugndoceerfhritcnetoegbe.OgiuetlOgihpbaadeeoasveindfxafj'rtppaOnIotjaonn.nfoIniboerdfhgeitfnThpnefnrdotfyteecgebbtohdcfsjtoerceioAeehsyxldeenhovhurjyiotnreictttsfetscteiicnticipohemaedtonhiuAohcnehdhtoilatcheidfteenstmfuipvtmenogstepeenenoieeexodeirnihlocoadurinaornnfndfdyeicnitdmeoeonefnetetetrcrcniohfgatl.usvihenmendoniAjdotsuefhphrnvisiehnaunhicretiefssedondotrdpioaesddieu,ggoodctetAerfcsoursinoneerorfrepbrpmes.rerrraisoorwefcdadwenrnosorcdotnthrvtrrluior.fsticeetxTrcyfplimeifiec.au.tdeiohooliynaeraigafexecidsepieedwhnsan.fAtnfirvlfotsxiioilherdrchufayr,ivoedasduWotoewfchmnrrenepiihrhotpeTelrssdi.dbnambnoilnsreicgxrnann.eruptphnietlagjhnishieeetrdashetghaosetndhdlaoeetg.exoacsTbtvryhyiocfteortefirnmteebacbelhcfhyotidnathotrdhfcl;edeampntcoieiyhefredleaoheofxeetevrspeoliyatptrish?ryffhofvcvfetnehceinsveme:prat.o<rioteurc.Vetinldeibrcr/mfnotiarerrfumoa?rrrsruaorsu.t.eeoscl.tokf,cfi-t.rthdnurcnouht.irir:raamp:h'iiet:ttu.nn-oieocte.re.nannhhiathikrr/hva-roeo:otrexnsca:onx.i.d.rgl.gyneiceegeciaeesrlc-f.--;llt $gtinh2oTa2in2httpgh1eetehrscefuBoocavurmoswirimodopaelnplarna.dltiainooinfanwntpiotrtacehhrsc.eaudnasrtnraettdthhdioaenaot:sfbbusikourptdrerdoeieovnnp:i:;nc"tog-f.f V VCL -S3, NO. -.Sl-FaiPAT, AUCUST A, 1973 N 07071 000282 J-73S BUIES AND REGULATIONS -aEduhgpppalepaocaorltveonircspenuegehntnrzdieamona.ttfmnhiqiaooFnp.elravnorewaiteslldlbtsalpaeoucsporrwtriedbehnedtyinedoenwaffenegolciratttarachysohtt.neoeh.fhv.cnearpetneinprrneryvoeareoseosvysfttdspcaheeetaiobrnedbhistnlteieieyiiocndr.sn.noheesgls,manevmhitoapaadtenfallensf.lad.nhititccnahbeooelteefrf,l.- 22-23 Filing the transcript. TpsbattuiaaotfApcottsirrhorcloafanfrehaalgaTcrpeeruytmslnetnieotiesnahrhpmhmpnisspispew.rnmetrdedecccasytn.ae.eiiyyurrrnghgntntr:ltiiAa,olhhPe:aiyppiiegtyftenoepairoattpcasttenorortbreoeoa.hor!aimfdaoatuceernfrdhelcncfovttfra.ppgftihueaidh"dpihrfhctotcle.cetyirelsdeseeerctpcatyncosahrntrisaaornorseho.raatecoetenfopsisirsfaanleonrcemh'clcmyls.ts.esgmllaoarhfotcltoheeivelcocrtef;opanoldch.fe.wafocnpluntwyi.seiteAtftnnylileyrrrrtruragtnahanirar.rarhcptbvgnnceyineoehasesomiiopsssfpscclahancppihtcmotertaattrhrrieoratyryiraeipehT.irtntsldebtpstnheslahehigureooltrseyteeatctncdcafcnohcmlfutcasotirlrepiclhllcvtinteoattetilioipaaohahhhnveerofnnnsicrtlnedyreeegectt,l.t 12Z.2arS.d oPrrdoepro.sed findings. conclusions, sppolfpbcbpirsronaueeurofoearrVengccpiebbrsnestogstlem.mst,fiyi'tiroedaeideshddtiirrfisihcsitenvfnnbisotairnen'tcaigr,nnufiod'iermocadtlenesrretorlcfusewuausafoesnpnsfpuefqthisciopshoafc:onmiharitsconjeepncitlasrfyrurlesalt.itmoselrpeacnsp,rtdl(ttoatoedlbr.2hiyn'ftoeeer0becpesaprs)erfaoi,fnlbaoeidaenrreryostdwoertsthteufeiarulo.wed.elfaynnwbegistspcrenTdma,ierfiaeoae.ntithvrsinodiaarnhbd.netatntndfyteyngiet.dirbltoep,nadaowyfrgrb.sssewmhsiphhuslttttiAiiraahhhhciacttoodllhhyeylheeeflll Etvbpari 1c--Initial Decision and Motion To Reopen a Hearing irs3pscsirpsf(nesiieiwiohe2e2oosngog(arn1a2nuannhaniis2lc.)oooeailo2l7lcsldnfs5uoinoFthfhsayrssiroiaclifIdlhffoonleasitioelahnnlnaorrirtrwlswepcc?soac.isaclaronr7ahuTloei.eerar'riadips.xhinddlrinaloceimoerpeedlmsgrs.rgcsiug.ir.iereassiectpdecdaihsrraooldmr^.ahunerena'n.o.etiedrorc.nsfeprkneetTacgacaliifnfic-ycinohnahni.icialndmoeuasiiebsd,tanhlbilmlftii-ae,Tneiinla.inl'lrenaoegehaainrirafststeptidwdismefindaraeteodwgoilpeealrdtiupcr)rehtceniddeodlfcsllasareedtesteiihiihnvcocceceradateiiilddneisrl,lt pdsmaaecutTtdactagsdctthoihihholnerifimrrneuoaehaedvio(t.ric(emaedclnildalclcetbeiiceiodllreln)urtsirp)laeseuesspirigddsrirsmpeanEp,oiAlbnoer:eeiaidsrtwenrgfotescn(tccusemefsioi1na.ucopniieeLnsosisctp)ssmoatarcccsietottgirleiihdr.dlmhtieuo:roaerstooolosireynnncn,ccneppofpulauweocticogfoufnnam.aotifttnrroirIscobpahnptiortntsefonochlt/thepmt.dieeufidhb(iscoesfiasfn2,tbhefneeihiaIfuihsc)tivoyncrattloeenrecfoiafeldtdaopltoLttlschrtbhboahlrdrhhrsrfpppeen7toedeeeemeeoyuerteryvcdsacahearn-nanasAieanefdfsseheraedyajecicctsiceewipveddldeldeiteioecAptrtvavaemryirsiiyonrrinmnnirrtisc.dollenm.hitw(igegcfmfnycnT4litedrTrpanmhieg5tpiteohtitehshoeehte)htnaeiiimeoetnodenfnneesnirnfdasieiagIaipnadAtaatlttttIctietilhtrhhnrhhgnnceoyatedoyrateeyefidyesoeeisrlir-r, scEssncsrdpgnhpis5adbocihgtttnnoeephooeheonroeueioofeaea2rg(gooe(eeomueanondca2ratctb.anrcnpdatnl.iedgcgrdrth)2)etilaadicncaiiheoidehoher3fucqnnnpdirlycniaf.eFZbsuu.etcrsciguagdpfg-m,nieerurhmtfi.s(.iculMaa.cs*n':aia3ricejuifisgocen(cgeccaumesos.)rhapo2srerpflraoooonshdlt.strvteoc)tWad;aiabhsurifnervyieairsoomuathsynfnlaaecbeakiiennaiencsnnoisvsfgonteercronotwtyotttwadniweifcheotasiftandatnoiosaec.mhecieariihnetlnpitolfgndeadilcytrrerhtehdreaalcnibuaeetehaoaoorarendooibttonntplsnwokaecbhslaofnedfewsypmusdyonuennetprreefeehdmlniieaievocrboarfndttcetnatescv(drtihtseihh(uyahrtof1lulhigdef4ouieiattlweeillneiaot0tniyeco.e.)yfcnmdteixcnh)ennhhghor.t(hoptAoeevhye1ciofnsedhwttfnrTactntiiew)aoheeesotauhoednrhmiihthrfvteiiyvtthoreeaisaneatst;oheirsttnigoenosltinrndglqrrsehhfcalertrcuees.ediuoofptrnieh.eatgoebeitllonhoeoeerporoninearniceloapcnteeersosemtltttTtshpdewfpfsrtohiuei.enttnaintroihehrhaewvnearooaeadodtegInryineeeeiaossarftlssrr. SAudbmcairniisFt--raAtivpeeoRoelvi ieawnd 22.u29toryApoprdeaelrsfronrmruollracrei.view of interloc Epapcdhrusieoeexs(clasaiaciaioelnr-)esdiungpnmEotstgdori/a..tegassttsfryntAhuaeeeaeepupnrsidrplldfAotoeefvfludaorioielenmrdrrsdddieiogeemfdnrnahrri,olfistiyetmnaterron2faritnoefht2aloacty.ic2thnrsuhe0fefsresoetrirhbe-ovramcKypomiltdrrlialedcoe)to.sacnenpbidrpt,doispteaiaradrncroiooengyi*ar cspblc(ldbTmbitoftatbmmosdatcWcpamnaIdpsatvisatoampdty.onoc3oiuhueoyilneeeireifn.heencehrfpuohooepafrpiaogi0cfenr-rarsamein(anoato(errattddhlmetalnpytlyeyspaprnnc)unimedsyaibedyt:ttvtdeiijvd?tpn)uelos)tgnseiiseetueouc.cortrorter)pteerl/eidhfiifaipaona.gts.siaanmryaeiarbdpsuncmdrannsfluiyaSqcglayeuosirdotaerlracllbfptAmeiitDyonpergarbruofyr...ynlrdilihfecttxcneriywaaeu.pAoar,weondunoloczhaelnapscvadd.adoe/hrenct.tixoTilu"teigecyun'a,enth::!reoes:nivredewcdifemnaiotecrrocy:oparrteinshconitvhae.asdse(eertdpipoycohreoldhferl,inaosomah2mngnpitdieuieoevaoixipetetrpfeuemrinntieoWpo)nbnl,ehfdrosdnctidcfeoncrrtrtgebcwatsunpreeifrtprhy(oaiipdn,nihieiovawmeenpsaieryot1cfbwstpnthdonopeleimseratiayiearpatryhhlrtrtnet)irtnhnheisoienirraatdgsb.ridothsadhryhotenontolrteeefneooahtsreleegnttnaafprtiehaesIwiicctieaswnehrafirttctPhtfivebnnoieolfprdctropfeoedetlfooieeydnfnyeeoa.betowtyoareoogrdrrbrprepAerfeeffibrmcrhryeetuoiouptaAyrlfrnoentcsd,rrSceattthihsyeomder(tihrcdsllcmtdorpemhhoiprgurqoitalc5hhdi<uuidiexnsotuciineoci.see(eirfneercfostlutte)nuimmvtuiaealco3umfgrrtrieludf)gerirorisarohhgirfedtrifRguesciolne.cb0htrdtuudsnsmcoelhnraemfaceloeostAAileiia,l.he)ndiA.waloyilairffeagrfinytfneifgrotedtsrinteieshmnnyoiobiucisrqIddsdsnr.tii:gc;ipArTiots,octtngcdcc:h*spgesrttnm?rarntuoiohdiaguhmmeo.ota-ihrnaserdteinhrecacprrotfnagoierecireeadarLydtocs.oiatramneiamoinserhiaupcirdsafnccernatiuteoi!nsfniptAct-roiumntrf.iocttaifstlteasetmtsyefpZprorme)filoio;pita.lnchiepmrswu-rassidcfsa-ishi.,msiTVotb*aifo1l.reenncryrirrce*,lo.ilti2ebtthtiAye.amvpe.iteafefrn-errriJargosresue-LacCdrc"rmfir:saveiia.wtia*vacavn/tle*rwscvn1Svrtttei.riOcgeAhs,'rciitmt.trrtierAnc:1ta-.-"st.a--ictfe_uadrce'ohii.oour^:rnteae"o:hyddidicrtrierrrilel.sitjj-ed-tyc--in--ol:ll,.r-lenys.nrory-ttnee)V.ir---l-, 22.30 Appeal from or review of initial soawbmonofteiopyforroi(arddrpttannyttihleee)dchh.aairrlewenetlAciToaaavio'tp:hstohlteooefitwpefoetergihaeanccreberaep.neodnnritlpnaihnitopesyeotgcetrcfiaailfrevrculcn(wseeea2slyitaewid0piiontor)fiophiknndintafnehsgd.doadtaahvafilonraynpeeren:tsgerp:h(gadst1lsheeacceea)aeercvfacaliaotAarfvicrrmunnsiyupnrtntunfrpliycaigaiaranipcichitnrp-gstrlee.'c,cye.a-'f**.-./:eres-*:-.a:rrc-i-"*:'**<J--a;r=- FEDERAI RrCISTIS, V O L , NO. 1ST-- FRIDAY, AUGUST 4, W78 \\ 0707? .AOOOWJ i \k v u k M i ;ViN 5 34737 cnccs to the record and the ' c- olasiinont. The- nnu-iic.v.s siv.cm cnt of ttie tr:v( . ir-ucs _ 7t- ed for review, a siaicificnt of the nature of the cane and the facts rcle* vant to the issues presented for review, arr.umcnt on the Issues pre sented. ar.d a short conclusion statin? the precise relief sought. together with appropriate references to the record. The hearing clerk shall serve the notice of appeal and the appel lant's brief upon all othrfr parties and amicus curtac. rrtbsrfruahaaieeernnfiifpri(eeysdse2veleef)reyira.ceedernaetnWcRddhpbbcodoeeyraeirsiftipdrrseehtal,tirfriyhpogvtnieoeannrenbraraiefttrttapwliysihiepahfepaisetlpftooerhs(egncrecraludnefstlKxha:mhl.era.n-aeUlorv.ep)tl/?,lnac5phount)ectfnsotstaaro.oudntlhptcrar,.aui.ofya,snhr7rhsritdogsaeicpeowuoerlcobnfmeetwrsmsriviiektoeinehantonfrghyeasft,, TasadopitasiennfefaahI(rtdtdrrlbveeeitas)erirfdsetmainoSuelsnroireucineo.tntsiaigicstemwcWiietcsoesoioieepnptfhshos,tuebbsohinnanecrftaoUiehhslofvsbleep'ufesrrdootie.icruehrnhrvh.lftcaetiteyeeehladu-iwernfitdfiiontonvbeeAbirgyetrnyieadatvtitmtclhohiH\sleeeneetiwdnIar)Aektipsoescaednatminrsrsrmdvahitetaioiitahincyenonnleeissrtl.- lapmatbpstieiupreemao(rigcplrncmnluaitheleatireeiaoesngnddSdlsftuete,caheosttourdehdofapentre.eteahmtqlthIsehaasu;oisoedehtnasnf(daataahieiiltnasdbttleihsipoiadloutepegrnAiinega*tiivsadloutoAweolJmmnrddnaiacepiseoimtnlocssenr-uiieueritissdmens.nnitrssoriesuisahnvetstentlyirhoespoasowrfttrhtsoihuoe.dcahrlepreloedTlattuadrehhbbloaperdeeeef iqtgteieiumnrvied.ciesn)eTtgaAohonfrfedcgtaohuApnepmidseaierpcdrneateiytrirftnaoiboietrstrisf:oc.orsnarurtazaelrttsoahpmreegatnAunytmde.em.euzicnprioto.iininsagvtfrnetraene*ar Subpart G-- final Order on Appeal ppirwsosfamcsofgfttrawarcmia}chrheieishehornlasriefonannio-lohect(isese(osaaiyVnd-n.rbcdnamnaaneepei-llnaataiadcSael)ilsllisitaihodbntrlsspphpersuIswloatoeenCabehPlttgettpteypcaeirgaehrsrrecoddashfvoetzdaeaddsorieFirlevaaeesntlteoemet.plerfasiioolnavoiliradeetdpnnnarrhosnanetratarvsrdeaassttnhamtihinedldew,eilcceetshnselimenahttehrstslhooseIbgiwsoireltpscesetbcarcay.auffhbaeurodocieyrri.oalUtoconssdyb"eidnieknlnef,cnreelu.octfstereanscrIeathltffiaprueilic.hlheliarsolfisotnlanderuetnnailksyhenieseroTsyesxyacwneotpicidfrhirpnahhottaaafiiooordootaypiavnantatceehaSsnmtrenbkheprirtcsitsoaefslrtd(hiceettreseaosamAdiarocilsaieeienenmaserup0nteinc.nltssodefhefasl.sneh)tgogosssoiuotncr.lsmfionnle.ehefndeicraluredrrdstaadldereeotraiPrso.nei-oTaeln'lnfgtrefysntsdtatatpirviii.lAhiruyhodstlmntdmyAseiooohieWe.cmeeendeteontbmnfartnehrmowo,dmrgredhTaaefhettAcAuettiteeltheernihhhcienbentonoaneiddtnrdrretykneneoeegrr,st-rft,,* 22.22 Motion to reconsider u final order. sasdteetehuhreffrMrftecacsoeehilcdAlrorcstetiml.dsidvaboemSieeonnmanutsidnineceofedtsidhioneslsettntrrdohomoaeoffetcutohwotitsrhanohntiveaentsphetsirudiefofsniberithvnnereiaaafdelttlocllneehfrsnoeontehrtroordfhdtr(tiehee1ontrsher0na.tar)elaeuwlEyolonemdivurlsgtadeesehaeyresl.dtyyessr SuAPUAbrpcnsatasdeerehtsr'scmotHhee--GnTtoSvouexpriopcnfliSenmugbCesniAtvtaiadlnlmceiRnsPiuesCnlteroasanltttiirveooesfl 5 22.cs3Cti3vaonivlecSreunpspienCnppaloelanmtditeremosnlitnaAuilnsctdtr.earrtuiintheasssTfeosxsmpicreancSttuicobef rsSWcwacdsw(tpssi(pwadtpcmgtorrchei1yaeu4huuuointurfroteroyicif(qi(50m(reaelaelehrbaptdctntca23wnes,betnhdustcnwntnetep)push))aeUess)cehfihetaeherd.tre:edemlliseioeasentesesr.Woetc.SSnxna.eiShrfsfnylsrtacnSeusmegneeinsoeuaTeyaR.edeFseesTigCnbceifvd.sbrsootsch'tenroeooswtpnsoa,cPpheiol-es'neqfiphriniitwbTeetnxiovoie2tanonsqsadh,tuhaeutasissne(icnrain3lehdfnuiraamcenieshtdletlsaaytfsl)t1aaleueetwttehdhseianotsh.eebe5snssrccsctoStcnh2laa.dsleddutnshees(geoclt2iffcsuuleapmeedilss)sroeen(lsefadpse)prbn(f.drehbtu1cavoe)siuiohpesaebpcsytlgtip.)maotseosrmaslhes)ishrepeetttulolrerssurWdlhaliicTharedlmeeotonliamohdnsuaortmnrpgahesdeahuhb.dtynifaidqheovblcaefwessroaebnrsyncelueloneuieeeienstfuntliegndddibcerrpnhrstclett2tbtapmep.ceepatessdnbhhsfsrwdeibs2putnpasrreueuoeeoCaeotceaaayor.eiicpptrsrespnrmf0fcnetblctnochuvdoneisflspnhapdrtcdtt3feydipleenuauaaii.hlgdaaceroulf*acie.jo(cdasttcepea.ueornnsueearicunfpereimpnUuetmn:,ojnrrdrnloygr-rei,p(cuacipee.pioccitelcdninrtcc-eeecac,iey)hspaeon'nemoi::ccan.tt;r.ttt.:aire.cAofi:.atcch.rhea.:asttbv;c:afrsaocaccosaduyad-:dcceen.i;avyee.a-.f-il/if-lit' RRRRRrRPRR..eeeeeeeeeMCctcSi1SC*rnagggsgggggiaCr.dFtesiI.igoiiiiiigiir0clo0loRooooooooe..OoGoo0tnnnnnnnnnne.B6.7.DlaCt4..I6Cs.IoIXVIoI1VVU0VIm.V.sCX3caI2.tII.PC..SI.hSJoII262.1.2SIh7.o1.inC6S022..2406iht..5010lu3rF51MF-0na5M10e2.7niSe4d2Ce13rtdl.a60oeFsFt57s0os.0eAtltu6r.5suphrBeD8t.B.ranhKhLmIul0aAtaFinmilead7llonaDPitvlnt.2dleaonncilee0nemisaProdtnnd2.eanzalugo.dnraSSaT.8eb.r,ytt-tee.1oir3rSN:o.9eetr'S-F.t.Inne7eherCeKew78eattaCd.S5ae:latX.e2nTttnS3i.lr1Tdsr:seBaa40.a.-.nD5l..uWJs:siWAe.a3.lFzndmClNCularlviraiani)she.tY'nshngvyri*l.:.... PirtiAl CUTE*, VOL <3, NO. 151--M1DAT, AUGUST 4, )?7b A_ M- 07076 Minors 1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 2 REGION IX 3 In re 4 NEVADA POWER CON.?ANY , 5 6 Respondent, Docket. No. TSCA-IX-072E COX?LAINT niiD NOTICE 0? OPPORTUNITY FCk HEARING 7 8 9 complaint 10 This is a civil administrative action instituted pursuant t; 11 Section 1*6(a) of the Toxic Substances Control Act (7SCA) , 15 CSC 12 2615(a). The Complainant is the Director, Enforcement Civisict, 13 United States Environmental Protection Agency (E?A), Region IX. 14 The Respondent is Nevada Power Company and has a place cf busies: 15 jin Las Vegas, Nevada. 16 This Complaint serves as notice that the Complainant has 17 reason to believe that Respondent has violated Section 15 cf IS TSCA, 15 USC 2614, as follows: 19 Count I 20 ^1.. 40 CI*E 761.10(b) states that ar.v PCB mixture shall be ' 21 disposed of ir. an incinerator (40 CFR 761.40 of Annex I). 22 2. 40 CEP. 761.10(e) (1) states that spills and other 23 uncontrolled discharges of PCB mixtures constitute the disposal 24 (4C CFR 761.2(c)) of PCB mixtures. 25 2. Cn or about February 19, 1979, Respondent operated a 26 capacitatcr (40 CFR 761,2(c)), which contained a PCB mixture (41 27 CFF: 761.2 (v)), at or near 5316 Iris Avenue, .as Vegas, Nevada. S !. Or. or about February 19, 1979 , the capacitor cuoratol 5 29 'Lj Ea soruder: apillad or discharged the PCB mixture in viclattcr. 30 jar < i CIR 701.10 (b) and 15 CSC 2416 (1)(C). 31 32 ij,5,(9, IIJT-MMU - 1 - I! 0 7 0 7 4 A000285 1 Count II 2 } 1. 40 era 76].lQ(b)(5), 761.10(c)(4), and 761.10(c)(2' 3 {state that when storage is desired prior to disposal, ?CF's s 4 be stored in a facility which complies with Annex III. 5 2. 40 C.rR 761.42 (b) (1) (:) of Annex-III states that fa-, 6 used for the storage of PCL's, which are designated for cijtc 7 shall have an adequate roof and walls to prevent rain water f 8 |jreaching the stored FC3's. i 9 I 3. On or about March 1, 1979, p.esooncer.t operated a zc 10 i - - used fer the storage of TCS's (40 CFR 761.2(c)), which were 11 |designated for disposal, at or near 2515.Industrial Read, Las 12 jVegas, ;:evada. 13 j 4. On or about March 1, 1979, the PCS storage facility 14 operated by Respondent did not have a roof or walls in viciat 15* of 40 CFR 761.42 it) (1) (i) of Annex III and 15 USC 2614 (1)(C). 16 j Count III 17 1. 40 c m 761.42 (b)'(li (ii) of Annex III states that 18 facilities U5 2 c for the storage of FC2'r(which are designated 19 disposal, shall have an adequate floor which has continuous 20 curbing with a rinimur. six inch high curb. 21 2. Cn o: about March 1, 1979, ths TC3 storage facility 22 operated by respondent did not have a floor or curbing m vie 23 of 40 CIR 701.42 (b) (1) (ii) of Annex III end IS CSC 2614(1)(C) I24 25 1. Count IV 40 c m '61.42(c) (7) of Annex III states that PCS ar 126 (40 CFP. 761.2 (r11 and FCD container's (40 CFP. 761.2 (u)) shell 27 dated when they are placed in storage. 2S 3 29 2. on or about .March 1, 1973, PCS articles and PCS ccr. tainers, which respondent had placed in its FC3 sternge fr.c.l .30 were not dated in violation of.40 CFF. 761.42 (c) (7). of Annex : 31 ...and 15 USC 2614(1)(C). 32 I N 07075 A0ni!?R6 1 Count V 2 1. 40 CFR 761.42(c)(8) of Annex III states that owners cr 3 operators of PC3 storage facilities shall establish and maintain 4 records as provided in Annex VI. 5 2. 40 CFR 761.45 (a)(1) of Annex VI: states that each owner 6 or operator of a facility, which contains at least 45 kilcgrar.s 7 of PCS mixtures or one or more PCS transformers or 50 or more PCS 8 large high or low voltage capacitors, shall develop and maintain 9 records of the dates when PCB's are placed into storage for 10 disposal. 11 3. On or about March 1, 1973, the facility operated by 12 Respondent contained at least 45 kilograms of PCB mixtures or one 13 or more PC3 transformers or 50 or more PCS large high or low 14 voltage capacitors. 15 4. On cr about March 1, 1979, Respondent had not developed 16 and maintained records of the dates when PCB's were placed into 17 storage for disposal in violation of 40 CFR 761.45 (al_(l) c: Annex 18 VI and 15 USC 2614(1) (C) and 2614 (31 ( M . 19 II 20 PROPOSED CIVIL PENALTY 21 Section 16(a) of TSCA, 15 USC 2615(a), authorires a civil 22 penalty of up to $25,000 per day for each violation of Section 15 23 of TSCA, 15 USC 2614. Based on the facts and the nature, cir 24 cumstances, extent, and gravity of the violations, as well as 25 Respondent's ability to pay, ability to continue to do business, 26 history of prior violations, and degree of culpability, E?A 27 proposes to assess the following civil penalty: 28 29 30 31 32 *v.r.** un-iu- - 3 - N 07076 A0 0 0 2 8 7 1 Count I 2 IS USC 2614(1) (C) 3 40 CFR 761.10(b) 4 Spill or discharge of PCB mixture............ ....... $ 5,coo 5 Count II 6 15 USC 2614 Cl) tC) 7 40 CFR 761.42(b)(1)(i) of Annex III 8 PCB storage facility with no roof or walls............ S -c- 9 Count III 10 15 USC 2614(1) (C) 11 40 era 761.42 (b) (1) (ii) of Annex III 12 PCB storage facility with no floor or curbing......... $ -013 *Count IV 14 15 USC 2614(1) (C) 15 40 CFR 761.42(c)(7) of Annex III 16 PCB articles and PCB containers not dated....... ..... $ - 0 - 17 Count V 18 15 USC 2614(1)(C) and 2614(3)(A) 19 40 CFR 761.45(a)(1) of Annex VI 20 No records of PCB's in storage........................ S - 0 21 Total Proposed Civil Penalty.......................... 6 5,000 22 III. 23 NOTICE OF OPPORTUNITY FOR HEARING 24 You have the right to request a hearing on any material fa 25 contained in the Complaint or the amount of the proposed per.ilt; 26 If you wish to request a hearing and avoid being found in defat 27. you must file a written Answer to the Complaint with the Region 28 Hearing Cleric, EPA Region IX, 215 Fremont Street, San Francisco 29 California 94105, within fifteen (15) days of your receipt cf tl 30 Complaint. The Answer must clearly and directly admit, deny, c: 31 explain each of the factual allegations contained in the Ccnpla 32 with regard to which you have any knowledge. A failure to edr.i1 -4- u. (Os 1111-MI* 111 n V /U / / *000288 1 deny, or explain any material fact allegation will constitute ar. 2 admission of the allegation. The Answer must also state (1) the 3 circumstances or arguments .which constitute the grounds of defense, 4 (2) the facts which you intend to place at issue, and f3) whether 5 a hearing is requested. 6 If you fail to file a written Answer within fifteen [15) I7 days of your receipt of the Complaint, you may be found in default. 8 Your default will constitute an admission of all facts alleged in 9 the Complaint and a waiver of your right to a hearing. The 10 penalty proposed in the Complaint will be imposed without further 11 proceedings. 12 Any hearing that you request will be held in the EPA Region IX 13 offices in San Francisco, California, unless there is good cause %14 to hold it at another location. The hearing will be conducted in 15 accordance with ,the provisions of the Administrative Procedure 16 Act, 5 CSC S52 et seq., and the Rules of-Practice, 40 CFR Part 22 17 (43 FR 34730), a copy of which accompanies the Complaint. 18 IV 19 SETTLEMENT CONFERENCE 20 Whether or not you request a hearing, you may confer infor 21 mally with EPA to discuss the alleged facts, violations, or 22 amount of the proposed penalty. An informal conference dees net, 23 however, affect your obligation to file a written Answer within 24 fifteen (15) days of your receipt of the Complaint. 25 Any settlement reached as a result of an informal conference 26 will be embodied in a written Consent`Agreement and Final Crder. 27 The issuance of the Consent Agreement and Final Order will consti 28 tute a waiver of your right to a hearing on any matter to which 29 you stipulated. 30 31 32 v, r. CT O: I t n - M l - W J -5- N.07078 1 If a settlement cannot be reached through an informal con 2 ference, the filing of a written Answer within fifteen (15) d a y s 3 of your receipt of the Complaint will preserve your right to a 4 hearing. 5 E?A encourages all parties against whom a penalty is proposed 6 to explore the possibility of settlement. To request an info-- al 7 conference, you should contact Keith Takata,'EPA Region IX, 8 Enforcement Division, 215 Fremont Street, San Francisco, California 9 94105, telephone number (415)556-8008. 10 11 Dated: 0.8 SEP 1975 12 Director Enforcement Division 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 - 6- W.ft*.f*Oi ii)- >L Sa f e t y d e p a r t m e n t NEVADA POWER COMPANY jn. Distribution Listed Belov DATE:____ 11/23/79 FROM SAFETY DIRECTOR, ft . F a b b i gnaiprr- PC31s - Questions & 'Answers/Regulations Attached is information regarding current EPA regulations rel ative to PCB's. The information is presented in a quescion/answer format. This may be useful in a number of ways, such as, dealing with the public or media, interpreting the standards,' or developing further methods of control or disposal programs, e t c ... J. McCarthy R. Brown D. Crotta S . Claeys K. Grant R. Hall W. Henson C. Kaiser W. McGarry R. Slate J. Strobel R. Whatley J. Z o m e s HO JOB IS SO URGENT - OR HO SERVICE SO IMPORTANT - THAT IT PR E V E N T S US FROM T AKING THE TINE TO 00 OUR WORK Sr H r h Jg b k : yoirtNOANrs exhibit 'k F H R P M k R tS lN T IF F 'S \ E X H I B nf-AvY-W1' .N. 09905 NEVADA POWER COMPANY Po 1ych 1or i na-t-ed Biphenyls PCB's Questi ons & Answers November 23, 1979 A00292 INTRODUCTION tino On May 31, 1979 in Che Federal Register (44 FR 31514) the U.'S Environmental Protection Agency published the Final Rule for' Polychlorinated Biphenyls (PCBs) Manufacturing, Processin Distribution in Commerce, and Use Prohibitions. This inf tion is presented in a non-technical manner, deals with the Rule's coverage and requirements. Its question-and-ansver format is categorized into the following areas. Q & A Category --' Pages Introductory Information ............. 2-3 General Rule Provisions .............. 4-5 Capacitors'............................ 6 Transformers ........................ 7-11 Labeling ........................\ ... 12-13 Testing ..... ...................... 13-14 Storage .............................. 14-16 Spills ............................... 16-17 Recordkeeping'........................ 17-18 Disposal .................... y PCBs in the Workplace ............... 23-24 Nevada Power Specifics and Program . 25-26 19-23 -1- il 0 9 9 0 7 I N T HQDUCTO RY I N FO RMAT 1 C1) WHAT ARE PCBs? The term PCBs Ts short for polychlorinated biphenyls. PCBs belong to a broad family of organic chemicals known as chlorinated hydrocarbons. PCBs are produced by attaching chlorine molecules to a biphenyl molecule. Although PC3s may be produced naturally .in the environment, almost a'll PCBs in existence today have been synthetically manufactured. (2) WHO MANUFACTURED PCBs? Monsanto Corporation was the principal manufacturer of PCBs in the United States. They began production of PCBs in 1929; in 1977 they voluntarily terminated^ product ion because of the wide spread environmental concerns about PCBs. (3) WHAT TRADE NAMES WERE PCBs SOLD UNDER? The tradename Monsanto Corporation sold PCBs under was "Askarel". However, companies who used PCBs in the manufacture of' transformers and capacitors, and for other uses, often used other tradenames. The following list is representative of PCE Tradenames: Aroclor, Pyaraul, Therminol, Pyroclor, Santotherm, Pvralene, Pyranol, Inerteen, Asbestol, Chlorextol, Diachlor, Dykanol, Elemex, Hyvol, No-Flamol, Saf-T-Kuhl, Aroclor B, Clorinol, Clorphen, Eucarel. (4) WHAT ARE THE PHYSICAL AND CHEMICAL PRQPERTIES Or PC3s? PCBs have a heavy liquid, oil-like consistency, and weigh 10-12 pounds per gallon. The properties which made them com mercially attractive include: ' a high degree of chemical stability, low solubility in water, low vapor pressure, low flammability, high heat capacity, low electrical conductivity, and a favorable dielectric constant. (5) HOW ARE PCBs USED? The primary use of PCBs has been in "closed" or "semiclosed" systems in electrical transformers, capacitors, heat transfer systems,.and hydraulic systems. PCBs have also been used in paints, adhesives, caulking compounds, plasticizers, \ -2- . N 0 9 9 0S A0Mt94 inks, lubric. ., carbonless copy paper, t sealants coati ncs, and dust control agents. Most of the PCBs marketed in the United States are still in service, primarily in electrical equipment. (6 ) WHY ARE PCBs HARMFUL TO HUMAN HEALTH AND THE ENVIRONMENT? PCBs are harmful because once released into the environment they do not break apart into new chemical arrangements, instead they bioaccumulate in organisms throughout the environment. In addition, PCBs biomagnify in the food chain -- that is, they ac cumulate in the tissues of living organisms and .as they move up the food chain towards man their concentration increases. These facts are significant because PCBs have been shown to cause chronic (long-term) toxic effects in many species even when the exposured to very low concentrations. (7) WHAT ARE THE KNOWN HEALTH EFFECTS OF PCBs? There are well documented tests which show PCBs cause, among other things, reproductive failures, gastric disorders, skin lesions,.and tumors in laboratory animals. Studies of workers, exposed to PCBs have shown a number of symptoms and adverse effects including, but not limited to, cnloracne and other epidermal disorders, digestive disturbances, jaundice, impotence, throat and respiratory irritations, and severe headaches. (8 ) WHAT ACTION HAS EPA TAKEN AGAINST PCBs? In 1976, Congress enacted the Toxic Substances Control Act (TSCA). Section 6 (e) of this_law requires EPA to establish rules to: (1) govern the disposal and marking, of PCBs; and (2) pro- . hibit, with certain exceptions, the manufacture, processing, distribution in commerce, and non-totally enclosed use of PCBs. Final Marking and Disposal Rules appeared in the Federal Register on February 17, 1978 (clarifying amendments to this Rule appeared in the August 2, 1978 Federal Register). On June 7, 1978, the Proposed PCB Ban Rule was published in the Federal Register. The Final PCB Ban Rule appeared in the Federal Register on May 31, 1979; this Rule supersedes the February 17, 1978 PCB regulation and takes effect on July 2, 1979 . . N( 0 9 9 0 9 A0ftn?95 G EN Z ?.AL ?.U Lc PROV 1ST S (9) WHAT DOES THE MAY 31, 1979 PCB BAN RULE DO? Speciically,,,the rule: (1 ) prohibits the manufacturing, processing, distribution in commerce,- and the use of PCBs .except in a totally enclosed manner after July 2, 1979; (2 ) provides authorizations for certain processing, dis tribution in commerce, and use of PCBs in a non-totallv enclosed manner; (3) prohibits, unless exempted by EPA, a1.1. manufacturing of PCBs after July 2, 1979; t4) prohibits, unless exempted by EPA, all processing anc distribution in commsjrce of PCBs after July 1 , 1979. Also, the February 17, 1978 PCB Disposal and Marking Rule requirements are. integrated into this PCB Ban Rule. Therefore, with the total scope of the PCB regulation -- from labeling to production ban to disposal -- now appearing in the May 31, 1979 Federal Register, this publication supersedes all earlier PCB regulations upon its July 2, 1979 effective, date. EPA has also published in the May 31, 1979 Federal Register a notice which explains how to file for an exemption from the July 1979 bans on processing and distribution in commerce of PCBs. Petitions for exemptions must be filed by July 1, 1979. EPA'earlier published procedures for filing petitions for exemp tion from the January 1, 1979 prohibition on manufacturing of PCBs. These procedures can be found in the November 1, 1978' Federal Register (43 FR 50905).* (10) DOES THIS RULE APPLY TO ALL PCBs OR IS THERE A CUT-OFF POINT BASED ON THE CONCENTRATION OF PCBs? In order to practically implement this rule (i.e., except tions, disposal and marking requirements), EPA had to adopt a PCB concentration cut-off point for regulation. Therefore, the final rule applies to any substance, mixture, or item with 50 ppm or greater PCB; wherever the term "PCB" or "PCBs" is used in the rule, it means PCBs at a concentration of 50 ppm or greater, unless otherwise specified. This 50 ppm is a change from the February 17, 1978 Disposal and Marking Rule which set a 500 p p m .cut-off. By lowering the PCB cut-off point from 500 ppm to 50 ppm, it will substantially increase health and environmental p r o t e c t i o n---approximately, 4 :N, 0991 0 A000296 croiled, a: ?CBs . . as 100,000 co 500,000 "p is per year c : raw (11) IS THERE ANYTHING WHICH CONTAINS LESS THAN 50 PPM PCBs WHICH IS BANNED FROM BEING USED UNDER THIS RULE? Yes, waste oil containing any detectable concentration of PCBs is forbidden from being used as a sealant, coating, or dust control agent. To permit the use of waste oil with any PC3contamination to be used in road oiling, pipe coating, or vege tation spraying would cause PCBs to directly enter the air and waterways, which could Introduce them into the food chain. (12) WHAT IS THE DIFFERENCE BETWEEN "MANUFACTURING OF PCBs" AND "PROCESSING OF PCBs"? The actual creation of the chemical substance PCB, or a substance contaminated with PGB^..(e.g ., PCBs as an impurity),, is the "manufacturing of PCBs". The production of PCB Articles and PCB Equipment is con sidered "processing of PCBs", and involves the use of existing PCBs. Processing PCBs includes such activities as placing man ufactured PCBs into capacitors or transformers. (13) WHAT IS CONSIDERED A PCB ARTICLE? PCB EQUIPMENT? PCB ITEM? An article whose surface is directly contacted by PC3s is considered a "PCB Article". Examples include capacitors, trans formers, electric motors, pumps, and pipes. Equipment whose surface is not directly contacted by PCBs, but contains a PCB article, is considered "PCB Equipment". Ex amples include televisions, air conditioners, microwave ovens, electronic equipment,*and fluorescent light ballasts and fix tures . "PCB Item" is a collective term used throughout the Rule to refer to PCB Equipment/Articles/Containers/Article Containers. (14) WHAT EFFECT DOES THE PCB BAN RULE HAVE ON PCB ARTICLES? PCB EQUIPMENT? After July 2, 1979, PCB Articles can no longer be produced because the production is not totally enclosed. However, since the production of PCB Equipment is considered totally enclosed processing, this can continue until July 1, 1979 under the Rule; in order co continue PCB Equipment production after that dace, an exemption must be obtained from EFA. -5- .N. 0 9 91 1 A0 0 0 2 9 7 c ?ac TORS (15) HOW DO THESE RULES AFFECT CAPACITORS ? CAN I CONTINU- t q USE HY PCB CAPACITORS? Yes, you can continue to use your PCB capacitors for cnei useful life. The primary effect of the new prohibition rules is to terminate the manufacture of any new PCB capacitors. (16) WHAT ABOUT THE DISPOSAL OF FC3 CAPACITORS? These rules continue the provisions of the PCB Disposal and Marking Rule published in the February 17, 1978 Federal Register. Large PCB capacitors must be disposed of in an EPA approved chem ical waste landfill or incinerator. After January 1, 1980 all large PCB capacitors will have^to be incinerated in special EPA approved incinerators. -- .Special disposal is not required for small capacitors -except those waste capacitors owned by PCB capacitor or PCB equipment producers. (17) WHAT IS THE DIFFERENCE BETWEEN LARGE AND SMALL CAPACITORS? Small capacitors have less than 3 pounds of contained dielectric fluid; large capacitors have 3 pounds or more of dielectric fluid. (18) I HAVE PCB CAPACITORS THAT ARE TEMPORARILY OUT OF SERVICE; CAN THEY BE PUT BACK INTO SERVICE? Yes, but they will be subject to disposal requirements at a later date. (19) I NEED SPECIAL PCB CAPACITORS TO SERVICE MY PCB EQUIP MENT. WILL I BE ABLE TO BUY REPLACEMENT PCB CAPACITORS? If suppliers receive an exemption from EPA, they can sell existing stocks of PCB capacitors to service existing PCB equipment. r a - v . i t i r i . j .1 6ita tie ii ir i---------- t -- -- . N. 0 9 9 1 2 A00025*8 TRANSFORMERS (20) UNDER THE FINAL BAN RULE, THE USE OF PCBs IN T R A N S F O R M S IS CONSIDERED USE IN A TOTALLY ENCLOSED MANNER. DOES IK'S KEAN I CAN GONTINUE TO USE HY TRANSFORMERS CONTAINING PCBs? IF SO, FOR HOW LONG? Transformers containing PCBs can be used as long as they perform their intended function and do not leak PCBs into the environment. (21) IN ORDER TO GET THE FULL USEFUL LIFE OUT OF LIQUID FILLED TRANSFORMERS, THEY MUST BE SERVICED OR REPAIRED PERIOD ICALLY. ARE THESE ACTIVITIES PERMITTED UNDER THE RULE? ARE THERE ANY RESTRICTIONS? Servicing of these transformers is authorized until July 1, 1984. EPA will consider the necessity of extending the author ized period prior to the 1984 termination date. Sepcial re strictions are dependent upon the concentration of PC3s in che transformer, and whether PCBs are sold during the servicing activities. There are four categories of transformers considered in this regulation and the restrictions and special conditions are easier to understand in the context of these categories. (22) WHAT ARE THE 4 TRANSFORMER CATEGORIES? WHAT IS THE SIGNIFICANCE OF EACH? The four categories of transformers established by the PCS Rule are: (1) PCB Transformers containing PCBs at a concentration of 500 PPM or greater; (2) FCB-Contaminated Transformers containing between 50 PPM and 500 PPM PCB; (3) Non-PCB Transformers containing less than 50 PPM PCS; (4) Railroad Transformers used in electric railroad lo comotives and self-powered cars that contain PC3 fluid. The transformer categories are significant, because under the Rule each is subject to different disposal, servicing (in cluding rebuilding), and storage requirements. -7 N. 0991 1 Aftnn?99 requirements _ .'ateiy; the other 3 categc as are ciszussed s imultaneous1v ., (23) HOW DO I DETERMINE WHICH OF THE FOUR TRANSFORMER CATEGORIES I HAVE? A transformer must be assumed to be a PCB Transformer if: (1) the nameplate indicates that the transformer contains PCB dielectric fluid; (2 ) the owner or operator has any reason to believe that the transformer contains PCB dielectric fluid; or (3) the transformer's dielectric fluid has been tested and found to contain 500 ppm or greater PCB. If a transformer does not have a nameplate or there isn't any information o indicate the type of dielectric fluid in it, the transformer must be assumed to be a PCB Trans forme r . If a transformer is tested-aad found to contain less than 500 ppm PCB, it will then fall into one of the other appropriate categories. A transformer can .be reclassified as a Nqn-PCB Transformer if its dielectric fluid has been tested or otherwise verified to contain less than 50 ppm PCB. Testing Transformers in order to classify them as Non-PCB Transformers does not significantly change the actions required by the Rule. If your transformers are proven Non-PCB Transformers you should take precautions to see that they aren't later contaminated during servicing with PCB fluid over 50 ppm. (24) WHY SHOULD I ASSUME THAT MY MINERAL OIL TRANSFORMER IS A PCB-CONTAMINATED TRANSFORMER? IF I GO TO THE EXTRA TROUBLE AND EXPENSE TO TEST MY TRANSFORMER IN ORDER TO CLASSIFY IT AS A NON-PCB TRANSFORMER, WHY WON'T MY REQUIREMENTS UNDER THE RULE BECOME SIGNIFICANTLY SIMPLER? Current data shows that 25-40% of the existing mineral oil transformers are contaminated with 50 ppm or more of PCBs. No clear pattern exists to explain why one transformer is contaminated and another one is significantly less contami nated. This means that testing all transformers would be neces.sary in order, to be certain about the appropriate cate gory. This would be extremely expensive. Therefore, the requirements in the Rule for servicing, disposal, labeling, and use have been designed to make this testing step largely unnecesseiry. The only servicing restriction on PCB-Contaminated Transformers is th at companies servicing trans formers owned by others and who sell PCB-contam in<ited minera,1 oil to the:Lr customers must: -S- ; N. 0 9 9 1 4 AOTOI300 receive an exemption from EPA. If they sold only ur.cont amine tec mineral oil (less than 50 ppm P C Bs), then no exemption would be needed. The disposal requirements for PCB-contaminated fluids are specific (high efficiency boilers, incineration or chemical waste landfills). However, the disposal options for fluids from Non-?C3 Transformers are not much greater, because of the broad prohibition on using waste containing PCBs for dust control, sealant or coating purposes. There are no labeling requirements for either transformer categories (PCB-Contaminated or Non-PCB Transformers), and no use restriction differences. '(25) HOW WOULD TRANSFORMERS WHICH USE PCB-FREE MINERAL OIL DIELECTRIC FLUID BE CATEGORIZED? Because of the widespread contamination of mineral oil dielectric fluid transformers, they must be assumed to be PC3- Contaminated Transformers. Even-if PCB-free dielectric fluid was added to an existing transformer, you couldn't be certain that PCB contamination in the transformer would not contaminate the new fluid to a level above 50 ppm PCB. - You, of course, have the option of testing the new aggregate dielectric fluid in the transformer to determine if the PC3 con centration is below 50 ppm, in which case it could be considered a Non-PCB Transformer. (26) CAN I RECLASSIFY MY PCB TRANSFORMER IF I REDUCE ITS PC3 CONCENTRATION? PCB Transformers can be reclassified to PCB-Contaminated Transformers by draining and refilling them with non-PCS di electric fluid. Before they can be reclassified the transformers must be tested and found to contain less than 500 ppm PCB after at least 3 months of in-service use. If the PCB concentration was successfully reduced below 50 ppm, then the transformer can be reclassified to a Non-PCB Transformer. (27) W H A T TYPE OF SERVICING CAN I DO ON MY TRANSFORMER? Routine servicing of transformers (i.e., testing the di electric fluid, filtering the fluid, removal of some fluid and then returning or replacing it, replacing gaskets.) in any of the categories will result in minimal exposures to PCBs and allow the -9 - lN 09915 A000301 use of mo si. .inc trans fo rm5 rs throuchc their' Lifetime. ---i has decided t . this activity d o e s n 't pres.nt an unreasonable risk to human nealth and the envi ronment. However, any servicing (including rebuilding) of PC3 Trans formers that involves removing the coils from the casing is prohibited by the Ban Rule. Removing the coils substantially increases PCB exposure, .,therefore, EPA concludes this servicing to be an unreasonable`'risk. EPA believes the cost of this pro hibition (about $14 "million the first year and steadily less each year after) is justified by the increased risks which would other wise occur to human health and the envi ronme nt. (28) CAN I REBUILD.MY TRANSFORMERS? Rebuilding a transformer would involve one or more of the following: draining the transformer, removing and disassembling the core, reworking the coil or-^rgwinding a new coil, reassem bling the core, and refilling the transformer with new fluid. EPA permits the rebuilding only of PCB-Contaminated Trans formers (containing between 50 ppm and 500 ppm PCB), and, of course, Non-PCB Transformers. If your transformer is classified as a PCB Transformer (containing 500 ppm or greater PCB), it cannot be rebuilt unless it is first reclassified to a PCBCon tamina ted Transformer. EPA decided to permit rebuilding of PCB-Contaminated Trans formers, because the exposure to PCB is relatively low and the economic impact of not permitting this activity would be very high. (29) CAN I SERVICE MY OWN TRANSFORMERS? EPA has decided to authorize this activity, which is con sidered use, for persons who service their own transformers until July 1, 1984. (30) CAN I HAVE A SERVICE SHOP WORK ON MY TRANSFORMER? Yes, you can have work done on your transformer without receiving an exemption from EPA provided the shop does not adc any PCB fluid. If PCB fluid (50 ppm PCB or greater) needs to be added, the shop can add your fluid without obtaining an exemp tion. However, if the service shop adds their PCB fluid to your transformer, they must get an exemption to do so after July 1, 1979. -10- .N 0 9 916 A000302 l a .n ; - iE MY DIELECTRIC FLUID? Dielecc-_c fluid can be reused as -long as ic is used in either the cransformer that ic came from or in a transformer which had a higher concentration of PCBs than the replacement fluid. (32) WHAT FLUIDS CAN"I USE WHEN I RETROFILL MY TRANSFORMER? Dielectric fluids containing less than 500 ppm FC3s can be used to refill transformers. However, dielectric fluids con taining less than 500 ppm PCB under no circumstances can be . mixed with fluids containing 500 ppm or greater P C B s . In other words, the deliberate dilution of PCB Transformers is prohi bited. A PCB Transformer must be drained, refilled, and tested after it was retrofilled before it can be reclassified as a PCB-Contaminated Transformer. It should be noted that PC3 Trans formers are usually retrofilled with fluids that have fire re sistant properties similar to PCBs. (33) ARE THERE ANY RESTRICTIONS ON WHO CAN SELL ME DIELECTRIC FLUID? After July 1, 1979, only those persons who have obtained exemptions from EPA can distribute (and sell) PCB dielectric fluid. ` - (34) CAN I SELL MY DIELECTRIC FLUID TO A WASTE 'OIL DEALER? Dielectric fluid containing greater than 50 ppm PCB cannot be sold to a waste oil dealer unless the. dealer is to dispose of it in accordance .with the regulation. Dielectric fluid with concentrations of less than 50 ppm can be sold to a waste oil dealer as long as it will not be used as a sealant, coating, or dust control agent. (35) CAN I SCRAP MY TRANSFORMER OR SELL IT TO SOMEONE TO SCRAP? If your transformer is a PCB Transformer, you cannot scrap or sell your transformer to someone else to scrap. You must dispose of it in an approved chemical waste landfill. On the other hand, if the transformer is a PCB-Contaminated or Non-?C3 Transformer, once the fluid is drained, the transformer can be scrapped or sold for scrap. (36) CAN USEABLE TRANSFORMERS BE SOLD BY PRESENT OWNERS? Yes, provided the seller had originally obtained the trans former for use and not resale -- and the buyer does not pur chase the useable PCB transformers for resale, but rather uses them himself. No exemption from EPA is required for such sales. -11- : N 09917 Anon.t o LABELING (37) WKAT NEEDS A LABEL? Most PCB Items (including PCB Containers, PCB Article Containers, PCB Articles, PCB Equipment, and PCB Transport Ve( h i d e s ) that contain 50 ppm or greater PCBs must be labeled. This labeling requirement is a modification from the February 17, 1978 Disposal and-Marking Regulation which applied to PCB Items that contain 500 ppm or greater PCBs. To provide sufficient time to identify and mark these additional items containing between 50 and 500 ppm PCB, the final May 1979 Rule allows until October 1, 1979 for labeling requirements to be met. (38) DO ALL TRANSFORMERS CONTAINING PC3s HAVE TO BE LABELED? PCB Transformers, containing 500 ppm or greater PCB, are required to be labeled. PCB-Contaminated Transformers, con taining between 50 and 500 ppnrP'CB, are not required to be la beled. The cost of marking a very large number of PCB-Contaminated Transformers while they are in service would be ex tremely high (approximately $10 for each of the 35 million transformers). An unmarked transformer is automatically assumed to be a _ PCB-Contaminated Transformer. However, if a transformer has no nameplate information but there is a reasonable suspicion that PCBs may be present above 500 ppm -- the transformer should be labeled as' a PCB Transformer until the PCB content can be ver ified. (39) WHERE DO I HAVE TO PUT THE LABELS? All labels (or marks) are to be put on the exterior of PCB Items and transport vehicles in a place that they can be easily seen and read by anyone inspecting or servicing them. (40) THERE ARE A LOT OF PCB^ CAPACITORS AND EQUIPMENT CONTAINING THESE CAPACITORS IN USE. DO THEY ALL HAVE TO BE LABELED? The requirements for labeling capacitors are primarily re lated to disposal; the labels serve as a positive reminder re garding disposal. All large, high voltage PCB capacitors have to.be labeled, including those in service. Large, low voltage capacitors have to be labeled when they are taken out of ser vice for disposal. Small capacitors do not have to be labeled. Equipment con taining PCB capacitors does not have, to be labeled unless the capacitor is a large, high voltage type or if the equipment was produced after January 1, 1979 and contains a small FC3 capacitor. -12- ; N 09918 (1) DO I . . T O LABEL A PC 3 CAPACITOR ...AT IS ON A POLE 0 = IN A SIMILAR INACCESSIBLE LOCATION? If a PCB capacitor is installed in a "protected" area (e.g., on a power pole, or structure, or behind a fence) the pole, structure, or fence is to be labeled in a place easily seen by interested persons, such as servicemen. (42) DOES E?A SUPPLY LA3ELS FOR PCB CONTAINERS OR PC3 ARTICLES AND EQUIPMENT? DOES EPA PROVIDE NAMES OF SOURCES FOR SUCH PCB LABELS? EPA does not supply any PCB labels. However, the Agency knows of two sources from which you can obtain the required labels: LABELMASTER, 7525 North Wolcott A v e ., Chicago, Illinois 60626, phone: 312-973-5100 -- to place only orders call toll free 800-621-5808 (except in Tilinois); W.H. BRADY CO., Faci lities, Identification, Products Division, 727 W. Glendale Ave., Milwaukee, Wisconsin, phone: 414-332-8100 (X624). Printing shops who produce labels would also be potential sources for these labels. The label format and sizes are in cluded in the regulation. TESTING (43) IS THERE AN EPA APPROVED TESTING AND SAMPLING PROCEDURE FOR PCB DETECTION? A variety of procedures exist for determining PCB con centrations in various media such as water, air, soil, mineral oil, pigments, etc. EPA has already made available through its Regional Offices copies of test procedures for PCBs in air, soil, water, and sediments. EPA is also preparing additional infor mation on test procedures for PCBs in oils; this information will also be available from EPA Regional Offices. In addition, copies of these procedures can be obtained from EPA's Office of Industry Assistance. (See the "Contacts for Information" Section of this Booklet on how to obtain this information.) -13 - ;AN0000939015V (44) N'T 15 AVAILA3LE TO DETEC There is _ simple field test for detecting PCBs. it is usually done using gas chromatography/electron capture. The best solution would be to contact an experienced chemical laboratory in your area that could perform such tests. (45) ARE THERE EPA-APPROVED LABS TO ANALYZED SAMPLES OF PCBs? No, EPA does not have a program for recommending or approving analytical laboratories. STORAGE (46) WHAT KINDS OF CONTAINERS ARE APPROPRIATE FOR STORAGE? The May 31, 1979 Final Rule permits 5 container types (5, 5B, 6D , 17C and 17E) which comply with Department of Trans portation (DOT) specifications set out in 49 CFR 173.346, to.be used to store liquid PCBs. Most of industry already is using these containers for PCB storage and handling. (47) CAN LARGE CONTAINERS, SUCH AS STORAGE TANKS, BE USED FOR THE STORAGE OF PCB LIQUIDS? EPA decided in the Final Rule to permit large containers, such as storage tanks, to be used to store bulk PCB liquids. This is-to allow safe transfer and storage of large PC3 liquid quantities; in addition, reduce storage costs. In other words, the transfer of stored bulk PCBs from tanks to other tanks or tank trucks will lessen the spill risks as opposed to having to transfer these large quantities from a number of smaller storage drums into transfer tanks. These storage tanks must'meet design and construction standards adopted by OSHA (29 CFR 1910.106). Also the storage facilities must have a spill prevention control and counter measure plan similar to the plans required for oil spill prevention. Owners and operators of bulk storage facilities will have to keep records of the amounts added to and removed from bulk containers. These records will be important in tracing waste shipments and enforcing the disposal and storage requirements. -14 - : n 09920 A000306 STC Yes, : -liquid PCB wastes, such 'as contaminated soil be temporarily stored for up to 30 days. (49) CAN PCB LIQUIDS OF LOW CONCENTRATION BE TEMPORARILY STORED? OF HIGH CONCENTRATION? Low concentration PCB liquids (50 to 500 ppm) can be temporarily stored for up to 30 days. All temporary storag.e areas must have a spill prevention control and counter measure plan. However, the final rule does not allow temporary storage for high concentration PCB liquids (above 500 ppm) because of the potential harm from a spill. (50) I HAVE A SMALL QUANTITY OF PCBs (I.E., A FEW SOAKED RAGS AND 1 GALLON OF PCBs IN APPROVED CONTAINER), AND I DON'T WANT TO SEND THEM A LONG DISTANCE FOR DISPOSAL. CAN I STORE THEM UNTIL A PCB DISPOSAL SITE CLOSE TO ME IS APPROVED? The mentioned- items may be stored until the last cav of 1983 . Uo (51) ONCE PCB ARTICLES ARE TAKEN OUT OF SERVICE, HOW LONG THEY BE KEPT BEFORE BEING PLACED IN AN APPROPRIATE ST AREA? WHAT ABOUT PCB EQUIPMENT -CONTAINING LEAKING PC ARTICLES? Non-leaking PCB articles and PCB containers containing leaking articles can be temporarily stored for up to 30 days,. (52) WHEN PCB CAPACITORS OR CONTAINERS ARE STORED IN AN APPROPRIATE STORAGE AREA, WHAT HAPPENS WHEN ONE OF THESE ITEMS STARTS TO LEAK? A leaking PCB capacitor should be immediately placed in a non-leaking Department of Transportation approved drum and any spillage cleaned up using sorbent or suitable solvents. It is a good practice to add sorbent material, such as saw dust, to the container to soak up any liquid that continues to leak out of the caDacitor. -15 - When a 'iner develops a leak, th jntents should immed ia te ly c ransferred to another, no; asiting container or to special "overpack" containers, such as those used in the chemical industry for leaking containers. (53) MUST THE EPA INSPECT A PCB STORAGE AREA ONCE IT IS BUILT BEFORE IT CAN BE USED? No, it is the responsibility of the organization storing the PCBs to insure that the storage area meets the specifications. (54) DO PCB STORAGE AREAS HAVE TO BE PERIODICALLY CHECKED FOR LEAKS OR OTHER PROBLEMS? WHAT ABOUT PCB ARTICLES, SUCH AS TRANSFORMERS, THAT ARE IN SERVICE? PCB storage areas must be -checked by the owner or operators at least every 30 days. Articles in service are not required to be checked by the regulations, but periodic checks would be a wise practice. SPILLS (55) DO PCB SPILLS HAVE TO BE REPORTED Under the authority of TSCA, PCB spills have to be reported whenever the incident poses a substantial risk to human health c: the environment. Since "substantial risk" cannot be precisely defined, however, any spill should be reported when people come into direct and uncontrolled contact with PCBs, or the extent of the spill is large enough to expose significant numbers of ani mals . In addition, a spill should also be reported when the volume or the extent of the spill is unknown -- such as spills that enter drainage systems. PCB spills into water, onto shorelines, or those that threaten water-courses should always be immediately reported. EPA is currently completing regulations under the Clean Air Act that will require reporting for water-related hazardous chemical spills (including (PCBs). These regulations will have criminal penalties for failing to report such spills. As a general rule, spills involving a single capacitor co not have to be reported unless PCBs threaten or enter a water course. Because of the greater threat to health and the envi ronment, transformer spills should be reported -- unless only . -16- IN 09922 Anonans leaks king s h as b!*sr *r\r' leaks, are -i .ved . Ar.v so i11 s-l be s topped and repaired - soon as possible.* (56) HOW DO I R E P O R T P C B S P I L L S ? PCB spills can be-.reported to the National Response Center operated by the U. S . :-Coast Guard at 800-424-8802 (in the District of Columbia, call 426-2675). (57) WHAT HAPPENS WHEN I REPORT A PCB SPILL? CAN I GET INFORMATION OR ADVICE ON WHAT TO DO ABOUT THE SPILL? The National Response Center will direct the report to the appropriate EPA environmental emergency office, based on the location of the spill. Experts from these offices (or related state and local experts) will con.tact persons responsible for the spills, in order to evaluate the potential environmental threat and to determine the appropriate spill control and cleanup measures. (58) IF I HAVE A SPILL, WHAT SHOULD I DO TO CONTROL OR CLEAN Up THE SPILL? : The first priority is to control the spread of the spill by damming or diking the leak. Also, any threats to water should be given top priority. Once a spill is contained clean up measures can begin. Clean up can be simply the removal of contaminated soil or debris. In some cases, more complex techniques may be required, such as special PCB sorbents or special filtration/carbon absorption removal of PCBs from water. Large and complicated spills should be cleaned u? by trained and experienced personnel. Organizations, who frequently handle ?C3s, should develop contingency plans and conduct training for dealing with spills. Commerical firms are also available on a contract basis to clean up spills. Government spill experts can provide information on such firms. REC O RD KEEPIN G (59) MUST COMPANIES KEEP RECORDS OF THE DISPOSITON OF PCBs IN SERVICE? IN STORAGE? IF SO, FOR HOW LONG? If you own or operate a facility which uses PCBs or PC3 Items, or have either stored, you are to keep records of their -1 7 - .N 09923 A000909 disposition. specifically, chis applies co facilities using c: storing at least 99.4 pounds (45 kilograms) of PC3s in PCS Con taineres); one or more PCB Transformers; or 50 or more PC3 Kish or Low Voltage Large Capacitors. These records shall be maintained for at least 5 years after the facility ceases using or storing PCBs or PCB Items in pre scribed quantities. (60) DO PC3 INCINERATOR FACILITIES HAVE TO KEEP RECORDS? CHEMICAL WASTE LANDFILL FACILITIES? HIGH EFFICIENCY BOILER FACILITIES? IF SO, FOR HOW LONG? Owners or operators of all three types of'PCB Disposal Facilities have to keep records. Incinerator and high efficiency boiler facilities must keep their records for 5 years; chemical waste landfill facilities must keep their records for at least 20 years after PCBs have stopped-being disposed there. (61) WHEN MUST I BEGIN KEEPING RECORDS OF MY PCB FACILITIES? PCB recordkeeping, if applicable, was to have begun on July 2, 1978. These records form the basis of an annual document prepared for each facility by July 1; the first annual reports; should be compiled by July 2, 1979. (62) MUST COMPANIES SEND THEIR ANNUAL REPORTS CONCERNING PCBs TO EPA OR KEEP THEM FOR THEIR OWN RECORDS? Companies should keep their PCB records and annual reports at their facility for inspection by EPA personnel. Do not send the records or reports to EPA unless it is specifically requested by the Agency. (63) I HAVE PCB FACILITIES IN SEVERAL LOCATIONS. DO RECORDS HAVE TO BE KEPT AT EACH SITE? Owners or operators of more than one facility having PCBs may choose to keep all of the records at a single facility, but the identify of that single facility must be available at each location. The record location must be manned at least 8 hours a day for a normal 40 hour week. -18- AOOifafcf 924 DISPOSAL (64) HOW DO I DISPOSE OF TRANSFORMERS CONTAINING PCBs? There are two ways to dispose of a PCB Transformer, which contains PCB concentrations in excess of 500 ppm. The trans former and the dielectric fluid can be burned together in a high temperature incinerator approved by EPA, or the liquid can be drained out of the transformer first. If the liquid is drained, the transformer must be flushed with solvent for 18 hours; the solvent and the dielectric fluid must then be disposed of in an EPA approved high temperature incinerator. The drained trans former after it is resealed must be disposed of in a chemical landfill which has been approved by EPA. If the transformer is a PCB-Contaminated Transformer, containing more than 50 ppm PCB and less than 500 ppm PCB, the transformer and the liquid can also be incinerated or the di electric liquid can first be d-rdned. If the liquid is drained it can be disposed of in a high temperature incinerator, a chem ical landfill which has been approved by EPA, or in a high effi ciency boiler. The drained transformer can be disposed of as scrap or in a disposal facility equivalent to good municipal solid waste disposal practices. " (65) HOW DO I DISPOSE OF LARGE PCB CAPACITORS? Until January 1, 1980, large PCB capacitors can be disposed of in EPA approved chemical waste landfills or high temperature incinerators. After January 1, 1980, they must be disposed of by high temperature incinerators. It is expected that hammermilltype crushers will be used at the incinerators to imprqve the de struction efficiency. These large capacitors account for approx imately one-third of the PCBs currently in service. (66) WHERE CAN PCB ARTICLES. (OTHER THAN PCB TRANSFORMERS AND CAPACITORS) BE DISPOSED? PCB articles can be disposed of in a chemical wa ste lanc- fill, as well as, in high temperature ine inerators r P roviced they are EPA approved, arti d e s , whi ch account for less than 1% of t! use in the U .S. , are pipes, hoses, parts of hi r el ectromagn ets , and electric motors. When these of in chemical waste landfills, they must be drained of free flowing liquid, and therefore, will contain only small amounts of PCBs. -19 - ,, N. 0 9 9 2 5 AoonRii (67) ARE THERE SPECIAL DISPOSAL REQUIREMENTS FOR SMALL PCS CAPACITORS CONTAINED PRIMARILY IN SMALL APPLIANCES AND FLUORESCENT LIGHT BALLASTS? No, small capacitors can be disposed of as municipal waste. EPA has determined that the random disposal of small capacitors in municipal solid waste sites by householders and other infrequent disposers does not present an environmental hazard. However, the disposal of large quantities of small PCB capacitors by commercial and industrial activities poses a larger environmental risk. Therefore, EPA encourages these persons to establish voluntarily a collection and disposal program that would result in the waste capacitors going to chemical waste landfills or high temperature incinerators. (68) HOW CAN I DISPOSE OF THEr.DIELECTRIC FLUID IN MY TRANS FORMER? Fluids from PCB Transformers (concentrations of 500 ppm greater) must be disposed of only by high temperature incin eration. Fluids from PCB-Contaminated Trans formers (with 50 ppm to 500 ppm PCBs) must be disposed of in high efficiency boilers, in approved chemical waste landfills, or in high tern-: perature incinerators. Fluids from Non-PCB Transformers (with" less than 50 ppm PCBs) have one disposal restriction: they canr.o be used as a sealant, coating, or dust control agent if they contain any detectable PCB. (69) WHERE CAN OTHER LIQUID WASTES WITH OVER 500 PPM PCB BE DISPOSED? BETWEEN 50 AND 500 PPM PCBs? LESS THAN 50 PPM PCBs? The same disposal options apply as for transformer dielec tric fluid. (70) WHERE CAN NON-LIQUID PCBs BE DISPOSED? Non-liquid PCBs at any concentration (e.g., contaminated rags and absorbent materials, and contaminated soils and ocher solids recovered from spills or removed from old disposal sites) can*be disposed in approved chemical waste landfills. (71) CAN DECONTAMINATED PCB CONTAINERS BE DISPOSED OF IN AN ORDINARY LANDFIL SITE? Yes, decontaminated PCB containers may be disposed of in ordinary landfill sices, rather chan in EPA approved chemical waste landfills. -20- Annnai2 .N 09926 (72) CAN DECONTAMINATED PC3 CONTAINERS. BE REUSED? Containers decontaminated in accordance with regulations can be reused for .general use. (73) HOW CAN PCB CONTAINERS USED ONLY TO HOLD LOW PC3 CONCEN TRATIONS BE DISPOSED? PCB Containers used only to contain materials or fluids, with PCB concentrations between 50 and 500 ppm can be disposed of as municipal waste. (74) WHAT ARE THE REQUIREMENTS FOR DISPOSAL SITES? Incinerators used to dispose PCBs must be approved by the appropriate EPA Regional Administrator. The approved inciner ators must meet the requirements" set out in Annex I of the Mav 31, 1979 Rule. Likewise, the chemical waste landfills used for the dis posal of PCBs and PCB Items must be approved by the appropriate EPA Regional Administrator, which must meet the requirements established in Annex II of the Final Rule. "High efficiency boilers used for the disposal of PC3Contaminated non-mineral oil fluids must also be- approved by the appropriate EPA Regional Administrator using the procedures established in paragraph 761.10 (a)(3)(iii)(B) of the Final Rule. High efficiency Boilers used for the disposal of PC3contaminated mineral oil fluids do not need to be approved, however, persons are required to notify the appropriate Region al Administrator using the procedures established in paragraph 761.10 (a)(2) (iii)(B) before commencing such burning." (75) HAVE ANY DISPOSAL SITES BEEN APPROVED FOR PCBs? WHERE ARE THEY? Yes, seven chemical waste landfill sites, and one limited use incinerator, have been approved. No incinerator sites have .yet been approved, but three sites are currently being considera The landfill locations are as follows: 1. Facility: General Electric Co . , Silicone Products Divi sion,^ F a c i l i t y Address: 260 Hudson River Rd. , Waterford, New York 12189. Facility Telephone Number (518) 237-3330. Type of Facility Approved: Incinerator. Type of PCB Waste Handled: Approval allows G.E. to incinerate only those PCB wastes which are generated on site, i.e., G.E. cannot accept PCBs for incin eration from any other company or any other G.E. facility. 21- - .N 09927 A000313 2. Facility,' Newco Chemical Waste Systems, I n c . Facility Address: 452~6 Royal Avenue, Niagara Falls , New York 14330". Facility Telephone Number: (716) 285-6944. Type of Facility Approved: Chemical Waste Landfill. Type of PCB Waste Handled: Capacitors (Small "and large); Properly drained transformers: Contaminated soil, dirt, rags, and other debris; Dredge spoils; Municipal sludges; and Properly drained containers (drums'). 3. Facility: SCA Chemical Services, Inc. Facility Address: 1550 Balmer Rd., Model City, New York 14107. Facility Telephone Number: (716) 754-8231. Type of Facility Approved: Chemical Waste Landfill. Type of PCB Waste Handled: Capacitors (small and large); Properly drained transformers; Contaminated soil, dirt, rags, and other debris; Dredge spoils; Municipal sludges; and Properly drained containers (drums). 4. Facility: Waste Management of Alabama, Inc. Facility Address: P . 0. Box 1200 Livingston, Alabama 35470. Facility Telephone Number: (205) 652-932-9. Type of Facility Approved: Chemical Waste Landfill. Type of PCB Waste Handled: Capacitors (small and large): Properly drained transformers; Contaminated soils, dirt, rags, and other debris; Dredge spoils; Municipal sludges; and Properly drained containers (drums). 5. Facility: Casmalia Disposal. Facility Address: 539 Ysidro Rd. , F7 (T Box 52)5 , Santa Barbara, California 93108 7 - main office (site located near Casmalia in Santa Barbara County). Facility Telephone Number: (805) 969-4703. Type of Facility Approved: Chemical Waste Landfill. Type of PCB Waste Handled: Capacitors (small and large): Properly drained transformers; Contaminated soil, dirt, rags, and other debris; Dredge spoils; Municipal sludges; and Properly drained containers (drums). 6. Facility: Nuclear Engineering Co., Inc. Facility Address: 9200 Shelbyville Rd . , Suite 526, P7 0. Box 7246, Louisville, Kentucky 40207', main office (site located near Beatty, NV in Nye County). Facility Telephone Number: (502) 426-7160. Type of Facility Approved: Chemical Waste Landfill. Type of PC3 Waste Handled: Capacitors (small and large); Properly drained transformers; Contaminated soil, dirt, rags, and other debris; Dredge spoils; Municipal sludges; and Properly drained containers (drums). 7. Facility: Chem-Nuclear Systems, Inc. Facility Address: P. 0. ox 1269, Portland, Oregon 97205 Main Office (Site located in Arlington, Oregon). Facility Telephone Number: (503) 2231912. Type of facility Approved: Chemical Waste Landfill. Tyre of PCB Waste Handled: Capacitors (small and large): Properly drained transformers; Contaminated soil, dirt, rags, asphalt, and other debris; and Properly drained containers (drums). 8. Facility: W e s - C o n I n c . Facility Address: P. 0. Box 564. Twin Falls, Idaho 83301". Main Office (Site located in Grand View, Idaho). Facility Telephone Number: (208) 734-77L1. Type of Facility Approved: Disposal in Missile Silos. Type of PCB Waste Handled: Capacitors (small and large); Properly drained transformers; Contaminated soil, dirt, rags, asphalt, and ocher debris; and Properly drained containers (drums): . N 09928 '22` Aooir*i4 (76) CAN A COMMON CARRIER (E.G., TRUCK LINE) TRANSPORT PCBs' FOR A COMPANY TO A DISPOSAL FACILITY 'IF THE TRANSPORT IS NOT WITHIN THE INDUSTRY? If the common carrier complies with the Hazardous Materials requirements set by the Department of Transportation, and the vehicle is properly/and visibly labeled on its exterior with a PCB label it can be used to transport PCBs to a disposal site. PCBs IN THE WORKPLACE (77) ARE THERE ANY OSRA RULES GOVERNING PCBs 'IN THE WORKPLACE? Yes, there are OSHA regulations governing PCBs in the work place. In 1977 the National Institute of Occupational Safety and Health (NIOSH) -- the HEW-^organization responsible for reserching workplace safety -- published "Criteria for a Recommence Standard .,. Occupational Exposure to Polychlorinated Biphenyls (PCBs)", OSHA, associated with the Department of Labor, will use this document to develope mandatory standards-regarding PCBs. However, OSHA Act requires .employers to provide employees with a place of employment that is free from recognized hazards. (78) WHAT IS A RECOMMENDED STANDARD FOR OCCUPATIONAL EXPOSURE? WHAT IS THE STANDARD. RECOMMENDED BY NIOSH FOR OCCUPATIONAL EXPOSURE TO PCBs?- ' A recommended standard is a determination of the level of exposure that will substantially reduce any risks of reproduc tive or tumorigenic*effects of PCBs and prevent other adverse effects of exposure in the workplace. It is based on a 10-hcur workday, 40-hour workweek, over a normal working lifetime. NIOSH has recommended in their Criteria Document for PCBs that occupational exposure to PCBs be controlled so chat no worker is exposed at a concentration greater than 1.0 micrograr. total PCBs per cubic meter of air (1.0 Mg/cu m) , determination as time-weighted average (TWA) concentration, for up to a 10hour workday, 40-hour workweek. This is only a recommended standard and it has not been adopted to date, by either OSHA or EPA. At the present time, however, OSHA is reviewing this recommended standard. (79) D I D NIOSH RECOMMEND ANYTHING ELSE TO REDUCE EXPOSURE TO PCBs IN THE WORKPLACE? Yes, NIOSH made recommendations about work practices, per sonal protective equipment and clothing, medical surveillance, personal clean up and sanitation practices, and employee infor mation programs. - 2 3 - A000315 .N 09929 (80) HOW DO OSHA STANDARDS AND NIOSH RECOMMENDATIONS R I L A " TO EPA's PCB REGULATIONS ? E P A 1s PCB Rules do noe directly regulate workers, but the Rules do restrict "or prohibit certain PCB activities which re duce the number of workers exposed. The EPA. Rules prohibit PCB transformer and capacitor manufacture, as well as PCB transformer rebuilding (except for railroad transformers); these activities were the major long-term occupational exposures to high concen tration PCBs. Worker exposure can also occur as a result of PCB spills and authorized servicing operations for PCB transformers. (81) WHAT KIND OF PROTECTIVE CLOTHING SHOULD BE WORN WHEN WORKING WITH PCBs? The type of protective clothing which should be worn when working with PCBs is dependent on the individual circumstances. Worker protective clothing and equipment is intended to prevent skin and eye contact, and control respiratory exposure. Respiratory exposure control (whether individual protection or workplace control) is most releyent for long-term production operations or major spills. PCB Transformer spills pose respir-; atory problems because of solvents, such as trichlorobenzene, that are mixed with the PCBs. Small spills, such as capacitor failures, seldom pose respiratory problems, but protection should be provided for incidents in confined areas. Skin protection can usually be achieved by wearing nonporous gloves and boots and heavy overalls. For major spill clean up activities," a full suit of non-porous clothing may be appropriate. Also, non-porous aprons can be effective in re ducing contamination of worker clothing. Non-porous protective gear can usually be laundered and reused, unless the garment is heavily contaminated, It is wise to launder work clothes separ ately from other garments. ** Eye protection should be worn when it is possible for PC3s to be splashed in the eyes. Removing contaminated soil does not usually pose such a threat. (8a)* IF I GET PCB LIQUID ON MY SKIN, HOW CAN I REMOVE IT? I liquid or solid PCBs are splashed or spilled on an employee, contaminated clothing should be removed promptly and the skin washed thoroughly with soap and water for at least 15 minutes. Eyes should be irrigated for at least 15 minutes if liquid or solid PCBs get into them. A drop of vegetable oil may be put into the eye to relieve the irritating effect of PCBs. 00316A' . N 09930 r Nevada Power Specifics and. Program (83) WHERE DOES NEVADA POWER DISPOSE OF ITS PCB WASTES? Nevada Power .Company's PCB waste is disposed or at an ap proved chemical waste"landfill near Beatty, Nevada (N.E.C.C.Q.) (84) HOW MANY PCB CAPACITOR BANKS DOES NEVADA POWER HAVE? Nevada Power has 611 PCB capacitor banks located on poles, and in Substations. (85) HOW MANY TRANSFORMERS CONTAINING PCB FLUIDS ARE ON YOUR SYSTEM? We have seven indoor transformers, containing PCB fluid, located at various hotels, shopping centers, and government buildings. We also have fifteen indoor transformers located at our power generating stations. (86) HOW MUCH PCB FLUID IS CONTAINED IN EACH CAPACITOR UNIT? Depending on the size, approximately 1 to 2 gallons of PCS fluid is contained in each capacitor unit. (87) WHAT IS NEVADA POWER COMPANY'S PCB POLICY? Nevada Power Company is committed to a balance of conserva tion and .utilization of our natural resources and to ensure an adequate energy supply to the customers within our service area. Our environmental policies recognize that to achieve this goal our facilities and operations must be conducted and operated within environmental requirements. The Toxic Substance Control Act is one of such federal regulations which prescribes the re quirements for the collecting, handling, transportation, and cis posal of Polychlorinated Biphenyls or PCB's. The policies and implementing procedures of this program are manditory for use by all affected Nevada Power Company per sonnel. (88) -HOW MUCH OF A PROBLEM IS EXPOSURE OF PCBs TO THE PUBLIC, AND WHAT ARE YOU DOING TO INFORM OR EDUCATE? 1. We have 629 pole, substation, and customer vault locations containing PCB fluid. All locations have been identified by a 6" required label'as per the EPA regulations. At pole locations the label (sign) is located approximately 8' from the ground. 2. Several months before the regulations went into effect, we started purchasing and installing non-FCB capacitor banks. We have eight such locations. h'evad Power Specifics and Program 3. We have conducted Graining programs with fi^e depart - 1 ments and with all of our affected personell in control and S handling procedures. -This program is also offered to interested groups or organizations. Exposure to the public 4. We have undertaken a program to reduce the exposure to the public from coming in contact with unintentional spills by re locating several of our outdoor pole capacitor locations to areas of less pedestrian access away from bus stops, swimming pools, playgounds, and school yards. 5. In our UGR vault locations with sump pumps that have trans formers containing PCB fluids we have installed PCB absorptive pillows and bales in the pump pits to collect any spill chat may occur. Other indoor transformer locations have dikes or metal trays.under them. 6. A large number of our capacitor banks are located remote from general public access such as in locked substations, in the desert and rural areas. 7. A number of capacitor banks are out of service (45) due to maintenance that has to be performed, also the use of the capacitors is mostly seasonal and conservatively 25% may be out of service at any given time. (89) WHAT DO I DO IF A SPILL OCCURS ON MY PROPERTY AND HOW DO I HANDLE IT? 1. If a spill occurs on your property call Nevada Power Company on the emergency phone number. If there should be a fire at or near the top of the pole, call the Fire Department also. 2. Stay well away from the spill area. Do not walk on the spilled liquid, or get any of the fluid (it is oily) on your body cr clothing, and keep pets away also, until our crews undertake the cleanup operation. .N 09932 *000318 (/) -J M3 VO li > I 06*687 oEPA Aflancy Toxic Subitancai '____________ Polychlorinated. Biphenyls: An Alert for Food and Feed Facilities wmt l<r *< P I VV Q I P I Q i >J |J I V i i w i 1 /' ` 4 I 2 DEFENDANT'S {.EXHIBIT ll- z f- i& P M i r.a **.;v.i ..i.*:v ***awr^-rta-*-tmr^;;iv`--*;/* ,4----- . ::*?:59EyL^ Im portant Notice: PCB Incinerators At the time this booklet w ent to press, there were still no approved PCB incinerators or alternative disposal methods available for commercial use in the United States. Until incinerators or alternative disposal methods are available. It is not advisable to remove PCB fluids or intact PCB-containing equipment unless safe storage facilities are available off the site. EPA permits disposal of large PCB capacitors in approved chemical waste landfills until M arch 1, 190 1. EPA requires all PCB capacitors to be containerized and packod w ith absorbent material prior to their disposal in chemical waste landfills. Several food contamination incidents have been caused by PCBs in storage. These incidents indicate that removing PCB equipment or draining fluid from a PCB transformer and storing the equipment or fluid may result in an increased risk of contam ina tion. Therefore, instead of removing this equipment from service at this time, carefully exam ine the risk of leaks or spillage and monitor continued opera tions closely. (See suggestions in paragraph C of checklist.) If there is potential for leaks or spills, corrective measures must be taken, including removal of equipment and fluid to a safe storage area away from the promises. If you have any questions, consult with your regional EPA or FDA office or local USDA nspoctor. At the present time, w e anticipate' that the first incinerator will be available in late 1980. EPA w ill publicize information on commercial PCB incinera tors as soon as they are approvod. In addition, you may check on the availability of.incinerators or alternative disposal methods by oilhor calling EPA'b O ffico of Industry Assislanco toll-froo (800) 4249 0 6 6 or calling your regional EPA or FDA contact or local USDA inspector. (See list of names and numbers in the booklet.) December 1979 06688 ' fc&gyw ' Y ittsz sm n z F . r FOREWORD . U NITED ST A TES EN VIRO N M EN TAL PROTECTION AGENCY WASHINGTON O C 10460 December 1979 o rfict or ionic iu h ia m c ii The food end feed Industries are particularly vulnerable to contamination 1roa polychlorinated biphenyls (PCB). PCBs are ubiquitous, perslatent Industrial chealca1a 'that are known to cause serious health and environmental effects. The Environmental Protection Agency has responaibi1Ity for regulatory control of PCBs and other toxic substances under the Toxic Substances Control Act of 1976. Me are working cooperatively with the Pood and Drug Admin iatrat ion, which regulates chemical substances In food and their use in food and animal feed plants, and the Department of Agriculture, which has reaponaibi11ty for aaauring the safety of meat and poultry, to protect our food aupply from PCB contamination. Thia booklet has been prepared tot Alert you to the serious potential problems aaaociatod with the use of PCB-containing equipment In the food and feed industry* Provide Information that will help you establish s program for contamination prevention in these facilities, and Provide information on current PCB government regulations and a reference of sources of additional Informat ion. PCB contamination has already caused costly destruction of large quantities of food and uncountable damage to our environment. W* urge you to alert your managers and employees to the problem of PCB contamination and to institute a program for preventatlva action without delay. Thia brochura will assist you In your efforts. W hy the concern? In recent years, tlfere have been a number of incidents where food has been contaminated with polychlorinated biphenyls (PCBs) and other toxic chemicals. This contamination has resulted from accidental spills, improper disposal,land unintentional misuse of PCB-ontainbig materials and equipment. PCBs are now known to have extremely hazardous health and environmental efforts, oven at low levels of concentra tion in the food chain, PCB-containing equipment, such as electrical transformers, has been extensively used in food and feed processing facilities. W e are especially concerned that future accidental contamination be prevented. This booklet has been prepared to help you identify potential problme and prevent costly future incidents that could have advorse alfocta on hoalth and the environment. 68 99ON TSL'UUV W h a ta ia PCD -- wlty, Itow, oiul whore re they uied? PC fis are a class of chem icals called chlorinated hydro carbons. PC Bs runge in consistency liom lioavy oily liquids to w axy solids. Their most important properties are chem ical stability, low flam mability, high boiling points, and low elocirical conductivity. Sin ce thoir development in 1929, PCDs have boon used in a variety of industrial applications. Hundreds ol W h y ore PCD hazardous? 3 PCBs have also boen used as plasticizers in paints, adhesives, and caulking compounds; fillers for invest ment casting waxes; and dye carriers In carbonless copy papor. Concern over PCBs' toxicity and' persistence in the environment led Congress to prohibit their manufacture, processing, or distribution in commerce. Although PCBs have not been manufactured in the United Slates since 1977, the chemical has been permitted to remain In older eloctrical transformers and other, industrial machinery. Knowledge of PCB toxicity in humans Is based pri marily on an incident which occurrod In Yusho, Japan in 19GH when PCBs leaked from a heat exchanger and contaminated rice oil. Among the many symptoms observed were chloracne (skin rash), discoloration of the gums and nailbeds, swelling of joints, waxy secre tions of glands in the eye lids, as wall as more general effects such as lethargy and joint pain. Thera ara also well documented tests on laboratory animals that show PCBs causa reproductive failures, gastric disorders, skin lesions, tumors, and other effects of concern. 4 W hy should food and food related industries be especially concerned about PCBs? The Vusho Incident illustrates the serious human health * and economic consequences of PCB contamination in food or feed related industries. Several other incidents underline the noed for special attention to prevent similar cotlj^ opnttmlnation in the future. These include: Discovery of PCBs In fishmeal used as a feed Ingredient in North Carolina as a result of a leaking heat exchanger, Contamination of fishmeal In Puerto Rico resulting from a fira Involving stored electrical transformers In the same warehouse, Death and sevore illness of foodlol cattle In Kansas caused by inadvertent use of PCU-containinaled oil as a carrier for insecticide, Contamination of animal feed ingredients with PCBs leaking from a transformer in storage at a packing company In Billings, Montana. These incidents have resulted in the destruction of large quantities of food, lead, and farm animals, and major disruption of the companies involved. O ON ON VO CD t PCDs In the enviro n m en t 6 Unlike most organic chemicals which break down fairl rapidly in the environment, PCBs are extremely stable The potential for biomagnification in the food drain is of special concern. Biomagnification is the piocesa through which small amounts of toxic substances rear higher levels of concentration at each stage of the foe chain. Microorganisms and plants take in traces of PCBs fror the environment. Thesa microorganisms and plants provide tha food for small fish and other anima' hk are in turn eaton by higher forms of animal life .... ea stop of the sequence, the PC^ content increases until human food supplios may be contaminated above the levola considered to be safe for consumption. (' y llHUHM lk tu 6 W hare mfoht PCBa bo found In food industry facilities? The following types of equipment may contain PCB fluids or other liquids such as mineral oil that are contaminated with PCBs: Transformer* Large cajfgC & en (over 3 tbs. o f fluid) Electromagnet* Heat transfer end hydraulic systems Small capacitors Equipment containing small capacitors including: electrical switch gear, fractional HP motors, and ballasted lighting fixtures. Transformers, largo capacitors, electromagnets, end heat transfer and hydraulic systems ore of primary importance because they contain tree flowing liquid. Small capacitors are of lass concern because the PCBs are usually in a non/iquid, nonmobile state. O ON c a p a c i t o r s 0 \ Capacitors hava been manufactured in a wide V O range of sires for various industrialuses. Capaci tors m a y contain P C B dielectric fluids. 7 TRANSFORMERS M a n y transformers have used P C B liquids to dissipato the heat generated by transmission. HEAT TRANSFER SYSTEM Heat transfer systems containing P CB s have been used in food processing equipment. C Existing federal regulations concerning PCBs and food i i. V \ Concern about highly toxic PCBs contaminating ' lan food has led to a number of regulatory actions b> .ie Food and Drug Administration (FDA), the U.S. Departmonl of Agriculture (USDA), and the Environmental Protection Agency (EPA). Under FDA regulations foods and foods are considered to be contaminated and may not be sold in interstate commerce if they contain 1PCBs in excess of certain prescribed concentrations. (Soo Table .) The uso of PCBs in food and animal feed processing facilities, oxcepl onclosod use in , transformers and capacitors, is prohibited by FDA regulation (21 Cf:n 110.40, 500.45).* * EPA has issued rules governing the use of PCBs. fn V general, PCB mixtures with concentrations less than 60 * parts per million (ppm) or 0.005 percent are not regu- latod. The uso of intact, non-leaking transformers, -------- n n a i-lln r c nnH np n a r itO r - C O n ta in in Q jjl i a The EPA rule permits the continued use ol PCBs in servicing of electromagnets and transformers and in heat transfer and hydraulic systems until July 1, 1984. As of November 1; 1979, PCBs may no longer be used in heat transfer systems In plants manufacturing or processing food, dnigs, and cosmetics. EPA rules Include provisions for marking, disposal, storage, and recordkeeping, portions of which are discussed later in this booklet. The polenliel for furiher regulatory action exists. On M ay 9 ,1 9 8 0 , EPA, FDA, and U SD A proposed to prohibit the use of PCB transformers, capacitors, and other eloctrical equipment in food, food, and agricultural chemical related facilities. For copies of the proposal, contact the Industry Assistance Office. The following checklist for Action has been prepared to assist you in conducting a full safety check of your facility. W e urge you to use this checklist to im plem ent a program for safety and contamination prevention In all your food and feed related facilities. ..06692 9 Checklist for Action W hat can I do? VV Determ ine If you have PCB e qu ip m e n t. 1. Locate any p o te n tial PCB source. You should inventory your plant for transformers, capacitors, heal transfer systems, hydraulic systems, end fluid stored for use in this equipment. After you have located these item s,. . . 2. Examine the equipm ent for caution labels. 9A caution label specifically identifying the equipment a containing PCBs may be present. If * , skip to Section D of this chocklist. If n o t,. . . B. Consider replacing PCB-contalnlng equipment w ith non-PCB equipm ent 3. Transformers and largo copacllors may bear n am ep la te s. If your transformer or capacitor has a manufacturer's nameplate with a trade name, refer to Table 2 at the end of this booklet. If the trade name does not appear there, tho equipment may still contain PCBs. Contact tho manufacturer, referencing the serial number to determine if the equipment contains PCBs. If there is no nameplate, or if this approach is unsuccessful. . . 4. Seek assistance from a servicing export. Call on your local transformer servicing company o' **ie engineering service department of your utility com, /. They can assist you to obtain a sample of your trans former fluid for analysis. You may also want to sample your heat transfer systems, hydraulic systems, or other' suspect oil. (Do not attempt to sample fluids in capaci tors.! T h e n . . . 6. Have the samples analyzed. This is tho only way to be certain whether or not your equipment conluins PCBs. If you determino that you have PCB equipment,. . . EPA, FDA, and U SD A have proposed to prohibit the use of PCBs in electrical equipment in food, feed, .and agricultural chem ical relatod industries. Although tho prohibition on PCB-containing equipmenl is not yet in effect, we urge voluntary removal f Take special precautions for continued use. O o\ 0\ VO OJ 10 Ae an alternative in transformers, you may want to consider replacing the PCB fluid with non-PCB fluid. You should be aware that the transformers will contain residual PCB concentrations after replacement and, therefore, may be subject to future federal regulation. EPA disposal rafufaftfens require incineration of all PCB liquids w llh concentrations of 6 0 0 ppm (0.06% ) or greater. The first approved incinerators will be available sometime in late 1980. Until incinerator methods are available, PCBa removed from service must be stored for leter dispoal. If It Is not possible for you to replace yoiir PCB-contain ing equipment, you will want t o . . . The risk ol PCB contamination can Ire miniml/od hy analyzing lha risk of spillage associated with each individual PCB unit and by taking steps to contain the potential uncontrolled toss of PCBs from the unit. You should consider the following questions: 1. Is there any evidence of an active leak from the PCB unit? If so, take whatever steps are necossary to protect your product or usable byproduct. Of course, leaking equipment should be repaired immediately. If your product is boing contaminated, contact the appro priate agency to determine the best way to destroy it. 2. Is the PCB unit located in an area whore there is a way that leaking fluid from the unit could find its way into your process? If so, these units should be given priority in the development of spill prevention meas ures. Special consideration should be given to potential leaks resulting from accidents as discussed in the following. 3. Is any liquid ever pumped from the vicinity of the PCB unit to the process area? If so, curt the PCD unit ho isolatod from the pump? 4 . If the PC B unit is pad mounted, are (Imre curbs or pans to serve us a barricade against loss of fluid? 6. If the PC B unit is located in on urea surrounded hy porous cinderhlock walls, have they been sealod with moiotiul w hich w ill not 'dissolve in solvents such as PCQ and trichloroberm me? Is the wull/floor intorfaco ti 6 . Is (he floor in the vicinity of a PCB unit free from cracks? Cracks that look like they would not prevent the loss of fluid should be grouted and painted whh solvent resistant materials, or government approved materials if required. 7. Is the PCB unit in e location where vehicular traffic might be a hazard? If so,.a vehicle barrier mloht ba useful. 8 . Is the PCB unit located near machinery which might throw projectiles with sufficient energy to damage the unit? If so, a shield, such as a fence, may provide the necessary protection. 8 . Is the PCB unit mounted on a surface which might be difficult to soul, such as unwelded steel plates or in a mobile machine? If so, e catchbosin might be installed under the unit. 10. Are (here floor drains in the vicinity of a PCB unit? If so, can they be sealed or otherwise isolated from the unit?1 O. Ba familiar w ith mandatory labeling and storage re q uirem en ts. 11. If you have PCB equipment or drums of PCB fluid in storage for future use, can they be removed from the process area? Are they marked or labeled to warn of PCB presence? If you have PCB equipment, you may be subject to mandatory labeling and storage requirements. 1. Labeling requirements. The EPA label for PCBs looks like this. i-- TM " ' ! EQUIPMENT CAUTION (UHTJUKlPCBs"j CONTAINS 8 S CAPACITOR(S) .06694 I E, Obtain further Information. to cr> 12 You must label the (ollowinn items: transformers containing liquids with more than 500 ppm of PCBs, 2,000PCB capacitors with 3 (three) or more pounds of fluid operating at volts or more, containers such as bags, barrels; or drums used to hold PCBs, electric motors utkjf) coolant with 50 ppm or more of PCBs, hydrauio systems or heat transfer systems containing 50 ppm or more of PCBs, and the storage areas described In the foliowing. In addition, labels must be placed on the following items when they are removed from service: PCB 2.000capacitors containing more than 3 pounds of fluid operating at less than volts and equipment containing a PCB transformer or largo high voltage capacitor. 2. Storage requirements. PCBs and PCB items which you remove from service for disposal must be stored in a location meeting EPA criteria to insure that they are proporly contained. This location should not be near your process area. It should be isolated so that it is not vulnerable to damage and puncture from vehicular, forklift, and other moving equipment. For assistance with the storage design criteria, contact the EPA regional office for your state. 0A list of EPA regional offices appears at the back of Jhis booklet. (See Appendix .) If you do not yet have the EPA regulations on PCBs, you can obtain a free ccpy from EPA by calling toll free (BOO) 424 9065 (in Washington, DC, 554-1404) and asking for a reprint of the PCB Ban Regulation, Federal Register. May 31. 1979, and for a list of the approvod PCB Disposal Facilities. If you want more background information on tho regulation, usk lor a free copy of the EPA Support ` Document to the PCB Ban Regulation at the same phono number. Tho mailing address is: Industry Assist ance Office IT S-799), Office of Toxic Substances, U.S. Environmental Protection Agency, 401 M Street, S.W., Washington, DC 20460. You may also contact tho noarest EPA Regional Officu. (Sue Appendix B.) OInthAenrnufisnoHfiuvl bAackground information on PCBs is lisiod Table 1. f \ y ijsff.rrvoT?;1xxm 13 FDA Limits on PCB C o ncentration In Food Food Milk and manufactured dairy products Concentration (parts per million) 1.6 ppm (fat basis) Poultry 3 ppm (fat basis) Red meat 3 ppm (action level) (fat basis) Eflfls 0.3 ppm Fish and shellfish 6 ppm )4(edible portion Feed for food producing animals 0.2 ppm (except concentrates, supplements, and pramL* Infant and junior foods 0.2 ppm 2.0Animal feed components ppm of animal origin Paper food packaging in direct contact with food 10 ppm (action level) Source: Title 21, Code of Federal Regulations, Section 109 federal Register, Voi. 44, No, 121. June 29. 1979, pp. 33330-33340. mA regulation establishing a n e w level of 2 p p m was p r o m gated but was stayed on October 5, 1979 until further notice. } h( r i -- \ - - * - ' -- "' < 14 15 Tabla 2. PCB Manufacturara and Trado Nomea PCBs have been marketed and various trade names. This list la have gone out ol business and M an u fa c tu re r by manufacturers in their products under complete since many companies la no longer available. Country Trade Nam e Aerovox Allis-Chalmers American Corp. Axel Electronics CBaayttearto Cattato Cattaro Capacitor Specialista Chemko Cornell Dubiller Dings Co. Electrical Utilities Corp. Electro Engineering Works Electromagnetic Filter Co. Envirotech Buell Etiez Magnets ESCO Mfg. Co. Ferranti-Packard Ltd. General Electric Geneva Industries H. K. Porter Helena Corp. Hevi-Duty Electric ITE Circuit Breaker Jard Corp. Kanegafuchi Kuhlman Electric McGraw Edison Malonoy Electric Monsanto Monsanto Monsanto US US US -- Germany Italy Italy Italy US Czechoslovakia US US US US US US US US US US US US US -- US US Japan US US US UK and US UK and Japan UK and Europe Hyvol Chlorextof Asbestol Clophon ` Dk Fonclor Inclor Dykanol. * Eucarel ' Pyranol Ask arel* Askarel* Pyranol Askarel* Non-Flammable Liquid Clorphen Kennechlor Saf-T-Kuhl Elemex Aroclor Santothorm FR Pyroclor `N 06695 M anufacturer Monsanto Monsanto Monsanto Niagara Transformer Corp. P. R. Mallory Er Co. * Power Zona Transformer Prodoloc Prodelec R. C. Uptegratt R. F. Interonics Reliance Electric Co. RosearchCottroll Songamo Electric Sovol Sprague Electric Co. . Standard Transformer Corp. Stens Magnetics Tobe Deutschmann Labs. Universal M fg. Corp. Van Tran Electric Wagner Electric Westinghouse Electric ; York Electronics --, --; i-- * ; Country US US US US US US France France US US US US US USSR US US US US US US US US US US _ _ Trade Name Therminol* * Pydraul* * * Santovac 1 and 2 sk aro l\ EEC-18 Aroclor B EEC-18 Phenodor Phyralene . Askarel* Diaclor Chlorinoi Askarel* No-Flamoi Inerteen Nepolin Apirolio . Kaneclor i Askarel is the generic nam e used tor nonflammable insulating Squid in transforrr\it an capacitors. j Various products used os heat transfer fkrids* such as Therminot FRO, were m e n u feo tured under this name. 1 I 1 0. mmmVarious products used as hydraulic fkrid. such as PydraufA-200. under this name. * t V ,.\k A000327 8SLUU0Y | Appendix A i j , 16 Other Available Inform ation on PCBs This booklet does not go into detail about the health and environmental effects of PCBs or the chomicals now M lf e u ia d ea substitutes for PCBs. The following reporipSptyf&M M echnical areas. The NIOSH Criteria Docuniaht lfe particularly recommended for its discus* lion of health issues for servicing PCB equipment or cleaning up PCB spills. "Criteria for a Recommended Standard . . . Occupa tional Exposure to Polychlorinatod Biphenyls (PCBs)." DHEW (NIOSH) Publication No. 77-225, September 1977. Order from Superintendent of Documents, U.S. Government Printing Offjco, Washington, D.C. 20402. Price $4.00 plus postago. "Assessment of the Use of Selected Replacement Fluids for PCBs in Electrical Equipment." Report No. EPA 560/6-77-008, March 1979. Order from National * Technical Information Service, Springfield, Virginia 22161. Report No. NTIS PB-296 377. "Polychlorinated Biphenyls and the Environment." 1972. Order from National Technical Information Service, Springfield, Virginia 22161. Report No. NTIS COM-72-10419. This is a thorough discussion of the properties and uses ol PCBs. "PCBs in the United States: Industrial Use and Envi ronment Distribution." 1976. Order from National Technical Information Service, Springfield, Virginia 22161. Report No. NTIS PC 252-012. 17 Appendix B W here Can I Seek Assistance? Assistance from EPA or FDA may be obtained by contacting your nearest regi office. Plants regulated by the Food Quality Service of liS D A may obtain help their local inspector. The following table lists by the state the ten Federal regk offices for FDA and EPA. REGION I: Connecticut Maine, Massachusetts, N e w Hampshire, Rhodt Island, Vermont EPA Mr. Robert Dangel Toxic Substances Coordinator John F. Kennedy Federal Building Boston, M A 02203 FDA Mr. A. J. Beebe Regional Director 585 Commercial Street Boston, M A 02109 16171 223-0585 (617) 223-1278 REGION II: N ew Jersey, N ew York, Virgin Islands, Puerto Rico EPA Mr. Ralph Larsen PCB Coordinator 26 Federal Plaza New York, NY 10007 (212)264-1925 FDA Mr. Caesar A. Roy Regional Director 830 3rd Avenue Brooklyn, NY 11232 (2121 965-5416 REGION III: Delaware, Maryland, Pennsylvania, Virginia, W est Virginia, District of Columbia \ EPA Mr. Charles Sapp ; Toxic Substances Coordinator 6! Curtis Building ( 3 A H 2 0 ) th r Walnut Street : Philadelphia, PA 19106 ' (2151 597-4058 FDA Mr. R. J. Davis Regional Director 2nd and Chestnut ea Room 900 Philadelphia, PA 19106 (215) 597-4390 REGION IV: Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, Tennassee EPA . Mr. Ralph Jennings ; Toxic Substances Coordinator - 345 Courtland Street, NE : Atlanta, GA 30300 (404)881-3864 FDA Mr. M. O. Kinslow Regional Director. 880 W . Poachtroe Streei Atlanta. GA 30309 (404) 881-4266 REGION V: Indiana, Illinois, Michigan, M innesota. Ohio, Wisconsin EPA ; Ml; Karl Bremer FDA Mr, L. fl. Claiborne I \ Toxic Substances Coordinator 230 South D m /1min Sirn/iiR/uun 1 1 CC Regional Director || n c m i i* D A iJa ik a IEGION VI: Arkansas, Louisiana. N ew Mexico. Oklahoma. Texas EPA Mr. John West PCB Coordinator First International Building 1201 Elm Street Dallas, TX 75270 FDA Mr. P. B. White Regional Director 3032 Bryan Street Dallas, T X 75204 (2141 749 2735 (214) 767-2734 IEGION VII: Iowa, Kansas, Missouri, Nebraska EPA Mr. Wolloano Brandnar Toxic Substances Coordinator 324 East 11 Street ' Kansas City, MO 64106 (8161 374 6538 FDA Mr. Clifford G. Shane 109 Cherry Stroot Kansas City, M O 64106 (8161 374-5646 IEGION VIII: Colorado, Montana, North Dakota, South Dakota, Utah, Wyoming EPA FDA Mr. Dean Giltam Mr. F. L. Lofsvold Toxic (Substances Coordinator Regional Diroctor 1860 Lincoln Street 721 19th Street Denver, CO 80295 US Customhouse Room 500 (303) 637-3926 Denver, CO 80202 (303) 837-4915 IEGION IX: Arizona, California, Hawaii, Nevada, American Samoa, Guam, Trust Territories of the Pacific, W ake Island EPA FOA Mr. Gerald Gavin PCB Coordinator Mr. I. B. Berch Regional Director 215 Fremont Street UN Plaza San Francisco, CA 94105 Federal Office Bldg. (415) 556-4606 Room 526 San Francisco, CA 94102 (415) 556-2062 REGION X: Alaska, Idaho, Oregon. Washington EPA ^ Dr. Jim Everts Toxic Substances Coordinate 1200 6th Avenue Seattle, W A 981 Ql amwT 0 6 6 9 7 FDA Mr. J. W . Swanson Regional Diiuctnr 909 1st Avenue Room 6003 Seattle, W A pBI 74 . CHEMICAL FWOARSTPECSLADNISDPFOILSLASLAPPROVED . ( 9 t u 7 .? , . o iIV l tV sen t to Cy.y1.i9* ,-- 1 *-. -J** -3f * ".. -Jf 7 yi. S T . I.O l'lS iA 111-- About 4.`i thmi tn.-ifp of Valen tine':- 1)ay candy in h**;m-shaped hnxes will go on the market although some of the boxes contain the toxic chemical PCB at in times the level allowed by federal guidelines. the St,.- Louis Post-Dispatch reported in Sunday editions. In a copyright story, the newspaper said polychlori nated biphenyl was found in boxes containing candy manufactured by E .J. Hrach and Sons Inc. of Chicago. Tests in Boston also showed PCB levels in 1,400 Schrafft's Candy Co. boxes exceeded guidelines for food packaging, the newspaper said. ^ P C B . a toxic chemical, was banned bv Congress for most purposes effective last -January. The Chicago branch of the federal Food and Drug Administration had recommended its Bureau of Foods seize the Brash's candy boxes. But the bureau refused, saying Valentine candy is a seasonal product with limited consumption, the Post-Dispatch repurt- ed. "To this day. I do not understand why the decision was made." Chicago FD A Director William R. Clark was quoted as saying. " I've spent a couple of sleepless * nights since that decision was made." The Post-Dispatch quoted documents and inspec tion reports on tests by Chicago inspectors in -July and ocAo.catlPreieoafffonucatnTTmTBBseegtcdsthhlrsumhrr-iy.oeaaoaeDs.ectcnmftanFihnhhbstleADadeh'r'possweseax,atApaldbtsetaaHudcpsobsnfubyhaoxsaetnlsphaueignsahdcseoanaeycae.irwndyeoidsrnBqxu;e.afsg'bucedpunoeeodltmtePeeihtelnaendFCerecvwdaiDoBnesPlcymNcAgsagCelthneupeirBbegvddiolyddaaeffylieuoMftlen1siillricvo0ieeniwnientddSaetclqiliscoshtesmufhh.feaoiesirnetlrrnsaalhls,titifs_eifehdfthto_ehtrhecin'd_tpetdeshehc,fmwprefliaastisirretmlaleydplvnigs-aibedntbtiu,&cosdeoikarev1txdrehr0neoeeedde0sfrt- dBBirraMaarccrihhhtce'shhaaVedallansldipesneiqtnniudntoieagtbceeohdsutoibtocyoSnlItaa5htf0eet,es0,rP0t0eohasfettoi-nrnDegtewisssppetsaavtpoecrnehartlshaapseiidesb.caoeyxsienosg.f | crIcteneoerccdmOie.aufnpolrfstfaiecnscNiinoayaeld'nrwssuetaopsYlmftrereotayihsrndiketiadr,ntebawegnoddetxteo,rbemjJyaoeuaPusmnnsrCaneuavBrafaSkal,iceatlathdJasumberrsleeeaearndry,ft,uiioAnccwrglt.eacioKsnosnemalqewioduminf.otebteaneosndttx.dpTimCnrhooaea. lioTnhien FfoDoAd pgaucidkealgiinnego._n__P_C_B__a_ll_o_w_s_1_0__p_a_rt_s_p__er_mil-j review -journal N E V A D A 'S LARGEST A N D M O S T COMPLETE N E W S P A ttjU p g g |i^ LAS VEGAS, NEVADA, SUNDAY, DECEMBER 30. 1979 I M B tiA lNTIFF-Sl ^nEXHiBtiy A000330 N 03184 1Ttarseonrss.utecdkefeorwPatCeBr | dteiiro,CntuhA,naaRdnpSeprtOahriNenenvaCtemlsIyTtoiugYusanett(diAoamnPll)aofc--wohreidAnpionbjsegystiobaeilnle1gw0ciin-htyeheempaaraiPocrlatCdslBffPierlCdemveBerialnplhoVlilagelwuhr, stsfMsuVPsaeyist3owtuwhGaiomesahtnCen0irEiiewaeMtanktaTattdlat0eGgsGteeBBdsssertlsiatarrhyennnfaaDnersbrTbsleouiVeieegirleltrmdtne5afohteiauetvreeggiifovfae0chusgvfksarstiamioomRGilpntnkgcoeoacisfcstpera"rnihrolise,ikeuryiadyapcntbcoobglTewGndeeierecliepomoaynmnegsscatddiehetrrnlyapaa,ehedodesboeietetlItitano.wtnairasrhdasiegaadeevnvhvymamstidaineerSrmloaciiadiines,iRyliVddndsdud.rtiiiiydtgociiFentTbeeyeoerg,ionn.uwihVrknedrelnSrbnlwhrosnoae,sraiiicaueeotaiiweedteanattnotakeeltdcexPii-fihalgwmfdirair"nbsedkhetCPnyotinkerEs..qMetvcahh.oewae.efg,ao"BudiPse2epueandctdfeeee0rPohtDtiettrtRoeehtcdhfis0ofesasatfldiktpotfieeihmcichSlivippntclsnltroc--iieTeyaiueootacfhntisneainrAaaresrrepcRrat.igctlhultsmtpsmhroeastsbtioieacaoldhbacektrliannovipkeEseeesnalePesnnetsoeeecl"latsnaaNatiypre-fimitbIamcvTdrSipaicionormlrnfeiRoienraueypfmflcirvpgenRdlienniisdoea.ucevlolMcuasirlnTiomoateticrPtkmMldptiomosntprtthehooosaeb..ndiefonieniteywrasnen.kiIWhnndmnehnnrapdeFeeecalatuoirsoiatdiadraueydtycottpttRnts.tlsCdetvaheao--tdadmeeHPdttiieorbnoisenVderprrrnmaeedosofasidgowiigfpnudtlo,ntunkiptsrknppcejflitsitaaoreetautenihpcaaeihuoinf2nawrigdls-ire-l-t,0,esyrgdytts | j' a n' 1 PCB discovered.^ , in Truckee fish R E N O (AP) -- A U .S. Fish and Wildlifi/ spokesman says .traces of the chemical P C B have been found in fish from-the Truckee River in this area sime lijfj'j. Dave Lenhart also said Monday that his agency has .not determined me P C B levels to be dangerous to hu mans. But he pointed out the tests are not conclusive. In related anion. Mike Reed of Sierra Pacific Power Co., which gels most of its Reno drinking water supply from the Truckee, said he wanteds to stress that the wa ter in the SP system is safe to drink as Jong as customers use tap water. Sierra Pacific has urged its customers to cut back on water consumption by 10 percent as long as the utility is forced to rely on wells for its water supply. Sierra Pacific has been using well water instead of Truckee water since the first indications that the river might be contaminated. P C B , or polychlorinated biphenyls, can be toxic to hu mans. But a UN-Reno.biochemist said the trace levels in dicated from preliminary Truckee tests should pose no himgwtptd3nere0eauaairtDM0Ptarlmhc.nlt"lrifeesrtstiopee.ih-sltclneelbfGoiekiptdomuror,lhfrmfderroiiaabnonnPlrbdvuemweaCMldestaearsheBymctt,iidihVhlttc"liseteeiihoie.tiksntsrhTnseiuptnatarteststrgthunhyroecermiapdbMfekanealeTetrPseebhdeaeraCtloae.uayhstfBhlceellocikdeeu-ashfvlernlaPetgoeec'hdmCtliovscengnecBiancoearoclairaensontelIirrhcsigntnleuea.caitrnab.obTnwtVoeo.iwhc"ouecueeaaneatrruskudoodts"eiseienmrienijenapedohwnkotprasyienedanehodragnodntbgwnjoewepuiinenepetaso'nde-rtt MsetorfeorPCTBructeksetes 'RcwsbCshViooaRnhehysi{fonmahigodCipeN"TkWtAsllvawhhtwTsmiiaoioAhhmeefttneenuerhmoairveiegRUrendcsentasimiaaeegstcanneSMst.UdemrSsWloiidtOotP,rtaalis..oenoi.hPgstSnmC.mNetpc"fbCeaCls.aFssyBoePraoelotoRBGidCnrlsmensrCtumne--rtetdhretIsarraspBpgsnoTseaeagetc,olaiolriawe"taYielrhoedlrictnvnsalodgaWhaauadahodlrvni(wlamnotcttfsAe$esii^tIfdawaoeWo'snioSPsoalbircentnsocdsue)fe'eienaiop.nalnrarPew--c"adTpltevgratnfPCoanlselaeiaiuitktuacsCdfBifroeMeht1eenerCoed;iB&sna,9xn|untlr$daoag6tisspanygfhhdar9Bjtiwepeetdsnueee.dyr.dpotctVagsyeaesiuTkotsptnsldueenewi"bhuajd.dbnrfPselueirloidosmtnctesttcssRutsiiwhhkcaaat--aaleionkoenudnnlfsdsuefercssoehataoweareatehtbRupaarmr.deseeavgorpiitdcetafcsvaeiuathtkinmehattetrse,sihgcseberoetaof"enwflDNotnTtienrrtedtlooalerrdielsserlioeumvoutnemdtswawctaucrceukaiotdttiretfslhlehncecooeuarttdgeeeeesessrr-t EPA is accused in PCB leaks -.--bcttcion1ornhuy9itixnhaesW7cwigieRe6lcntedrAhre.tlpa-aa.hipT--pScronwe.hrHlhvsoyJmfibuaIbocooNarrlahhrlseenamnGldnmntoukiaeTirosDfnnyir,aOnnos^gic.oanwpNotmtfgToufenesfrhd--otalsethelsoii,bebltaiTcilcDnnuplyhaahgdsh-auweMeiertmssng.noe"iEceoycolpDbnhfluswsriv.tdPi,ro--naiuitCrtnwhsgseoBgeechmnkdls"stonlmeacoowftwdasheefwnaeaanceticnssthtdbseapea",serluEii,fmkn-hmbPoPweeilirrpgiAyxsehoclhcceyt'saalseuanpyrcasgrHorastiptaeniahbocioePgsnleuornoeCesyssr,rstidBeA,sioelntsssgeifnetnuta--eonttiknbhelletlscecrebnfcyroriofhtla,oromhaefbwtmrwhmehlmcaesiiisefbngciaoaltEhgaetsiti AOOimi ' 0 3 1 8 3 Draft of July 28. 0 NEVADA POWER COMPANY : DEFENDANT'S EXHIBIT ll TO THE CUSTOMER: _' There has been an e le c tric a l failu re to Nevada Power Company's equip ment located on, or adjacent to , your premises. This failu re released a small quantity of liquid polychlorinated b i phenyls (PCBs). This liquid is considered a toxic environmental con taminant. The accidental release of this material requires special handling, clean-up, and disposal by our personnel in accordance with U. S. En vironmental Protection Agency regulations. The special clean-up procedures, and repair of this equipment, began and will continue until a ll contaminated material has been removed and your property restored to environmentally-safe lim its. To insure safe lim its, vegetation and soil sampling will be conducted. Upon in itia tin g clean-up by our persr"onnel, i t may be necessary to remove vegetation or other landscaping. The company w ill replace a ll material removed; questions of this nature may be referred to our Claims Depart ment. . Upon contact with this m aterial, potential health hazards are associated. For your health and safety, and other persons or animals, avoid walking on, or contacting this material until our clean-up has been completed. Watering of vegetation or so il w ill complicate the clean-up; please do 000332 N 06798 -2nojt water until clean-uq has been completed. For further safety and health information see the reverse side of this notice, or call Nevada Power Company at 385-5627. NEVADA POWER COMPANY ' A''0 0 3 3 3 N 06799 NEVADA POWER COMPANY HUMAN HEALTH AND THE ENVIRONMENT PCBs re harmful because once released into the environment they do not break apart into new chemical arrangements, instead they bioaccumulate in organisms throughout the environment. In addition, PCBs biomagnify in the food chain--that i s , they accumulate in the tissues of living organisms and as they move up the food chain towards man th eir concen tration increases. These facts are sig n ifica n t because PCBs have been shown to cause chronic (long-term) toxic e ffe cts in many species (not necessarily human) even when the exposure is very low concentrations. KNOWN HEALTH EFFECTS OF PCBs There are well documented tests which show PCBs cause, among other things, reproductive fa ilu r e s , gastric disorders, skin lesion s, and tumors in laboratory animals. Studies of workers exposed to PCBs have shown a number of symptoms and adverse effects including, but not limited to , chloracne and other epi dermal disorders, digestive disturbances, throat and respiratory i r rita tio n s, and severe headaches. SAFETY PRECAUTIONS AND FIRST AID The release of a small quantity of PC8s is not hazardous, provided that simple precautions are taken. Exposure can, and should be avoided until our clean-up is complete. The breathing of vapor or fumes should be avoided. Minute concentrations of this contamination may be unpleasant or ir r ita tin g , thus giving ample warning of their presence. nwAA p f4 N. 06800 -c- Like poison ivy, some pe%ople may be a lle rg ic and develop a rash, while others do not. I f there is unavoidable contact with the skin alcohol, solvents, or waterless hand cleaner may be used to cleanse the skin prior to washing with ordinary soap and water*, following the cleansing process, the application of cold cream w ill reduce the irrita tio n that may result from contact. I f the liquid contacts the eyes, they may be irrigated with water, and then examined by a physician (a drop o f ifastor o il has been found to re duce ir r ita tio n ) . Ingestion of the material is generally not considered a problem. Should accidental ingestion occur, a physician should be consulted. Hands should be washed in warm water and soap before eating, drinking, smoking, or using to ile t f a c il it i e s . A000335 'C V N..0 6 8 0 1 nt V defendant1 EXHIBIT ! ftAA n - ^ ^ v P/tfftJ r.zc:.; .vt..!.JULl' . t . . I. ,, r zc io :; d ; ii **7 w rx.j`r*..-,` *V".V K>.*.VV'hS'*'/^*'.j\1i , ..-j ; *: .r.::r*;'Vj} v V*T;i i :> f;;c*; .v; N 1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 2 REGION IX 3 In re 4 NEVADA POWER COMPANY, 5 Respondent. 6 Docket No. TSCA-IX-002; CONSENT AGREEMENT AND ORDER 7 CONSENT AGREEMENT 8I 9 This civil administrative action was instituted pursuant to 10 Section 16(a) of the Toxic Substances Control Act (TSCA), 11 15 U . S . C . 2615(a). The action was initiated by 2 Complaint and 12 Notice of Opportunity for Hearing issued on October 24, IP79 13 charging violations of Section 15(1)(C) of TSCA, 15 U.S.C. 14 2614(1)(C). The Complainant is the Director, Enforcement 15 Division, United States Environmental Protection Agency (EPA), 16 Region IX. The Respondent is Nevada Power Company, Las Vegas, 17 Nevada. 18 II 19 Respondent admits the jurisdictional allegations of the 20 r Complaint and Notice of Opportunity for Hearing. 21 r~ III 22 Respondent neither admits nor denies the specific factual 23 allegations contained in the Complaint and Notice of Opportunity 24 for Hearing. 25 IV 26 1. This compromise is in part in recognition that Respondent 27 has devised and implemented a plan for the cleanup of spills and 28 other uncontrolled discharges of PC3s (PCB soill plan). The PCQ 29 spi IT* plan is contained in Respondent1s appropr ia re opera u c n 30 manuals, orders, or other procedures. 31 A0 0 0 3 3 6 32 t, f*O I1-I' T y r r r r r 1infuni,..l* T ..%*i- .*'? j>V`* ** * * :'V'* t`* . * RICTI:.'.!.j j cl-j: . *i '* : i i . j rrrf^j* r* - '* .*/**i(' *1 ; '', j':;; *V!. w*.:;4 * ;. -.."- f * * ':v.:-*i-.V.-v'", ', \*m '- *`rj -;v*."v-V;'*O i.j* /.} i i* I.".**v\V 'V* * .r'*;\NVl"-\7*':; * ****V .r*,1'v ,V' V**' *>* ,,-J *' ,+'**.*>*\>v :*- * t^ '` ; ' '* V ' `*" v^'vvVvV *V **Vp.1 '?'.I**-: * ` ,, [,** ' ' ** I **''*' .'*'*'*1 r ..#***V"/-"j' *****.*A-**'t** 1 2. In addition to the requirements of C.F.R. Part 761, the 2 PC3 spill plan shall, by October 1, 1S30, contain provisions 3 which provide for the following: 4 a. The cleanup of spills and other uncontrolled discharges 5 of PC3s to less than 50_ ppm PCSs shall commence immediately upon 6 Respondent's knowledge of the spill or discharge. 7 b. After the cleanup of a spill or other uncontrolled 8 discharge of PCBs, samples shall be collected and analyzed to 9 ensure that the spill or discharge was cleaned up to less than 10 50 ppm PCBs. 11 c. For a spill or other uncontrolled discharce of PCBs 12 onto property not owned or operated by Respondent, the owner or 13 j operator shall be notified immediately upon Respondent's learning 14 of the spill or discharge, the owner or operator shall be 15 informed of the health effects of exposure to PCBs, Respondent's 16 PCS spill plan, and that no cleanup should be undertaken by the 17 owner or operator. 13 V 19 Respondent waives the right to a hearing on any issue t 20 contained in this Consent Agreement and Order. 21 22 Respondent consents to the issuance of this Consent 23 Agreement and Order. 24 NEVADA POWER COMPANY 25 26 Da 27 - 2-r tffd 28 29 3c/-- JS / ? & Date 30 31 Respondent, Vice President and Chief Counsel C T.yaa<cvy 33,. Eller Director Enforcement Division 32 A000337 *u. *.ivo. iin-MJ- >3 1S3H23 / y : J^*tf?*-^'s*T+' '." **.^ !', *p**,.*'/*'".*!'10 CLUi . ,\ ! i li*. J ^.' ri 1 ORDER 2 It is hereby ordered that Respondent shall, within sixty 3 (60) days or receipt of this Consent Agreement and Order, pay by 4 cashier's or certified check, payable to the United States of 5 America, a civil penalty in the amount of one thousand two 6 hundred fifty dollars ($1,250.00). This order shall become 7 effective immediately. 8 9 ToiiolCO 10 /\krf\A Sheila H. *i^>rnino iville Acting Regional Administrator 11 12 13 14 15 16 17 18 19 20 21 r 22 23 24 25 26 27 28 29 30 31 32 A000338 i"T *."''T '^ `V.'***;' Ogt t, 1^0:  lr*" DEFENDANT'S e x h ib it AAA -- - i . . I__. 1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 2 REGION IX 3 In re 4 NEVADA FONER COMPANY, 5 ResDondent. 6 Docket No. TSCA-IX-GG2C CONSENT AGREEMENT AND ORDER 7 -- CONSENT AGREEMENT 8I 9 This civ il administrative action was ins ti tuted pursuant to 10 Section 16(a) of the Toxic Substances Control Act (TSCA), 11 IS U.S.C, 2615(a). The action was initiated by a Complaint and 12 Notice of Opportunity for Hearing issued on October 2-, 1979 13 charging violations of Section 15(1)(C) of TSCA, 15 U.S.C. 14 261-1(1) (C). The Complainant is the Director, Enforcement 15 Division, United States Environmental Protection Agency (E?AJ, 16 Region IX. The Respondent is Nevada Power Company, Las Vegas, 17 Nevada. 18 II 19 Respondent admits the jurisdictional allegations of the f 20 Complaint and Notice of Opportunity for Hearing. 21 r III 22 Respondent neither admits nor denies the specific factual 23 allegations contained in the Complaint and Notice of Opportunity 24 for Hearing. 25 IV 26 1. This compromise is in part in recognition that Respondent 27 has devised and implemented a plan for the cleanup of spills and 28 other uncontrolled discharges of PC3s (PCB spill plan). The PCD 29 spill'-plan is contained in Respondent's appropriate operation 30 manuals, orders, or ocher procedures. 31 32 A000339 #u, *; f O; 1IINI17- I U -- *V"1 . -i . . . ; zi . . v.\-v". ':*'*,?.i * '*. V- *' r; ?- ` i-* 1 2. In addition to the requirements of 40 c.F.R. Part 751, t-e 2 PCB spill plan shall, by October 1, 1S80, contain provisions 3 which provide for the following: 4 a. The cleanup of spills and other uncontrolled cischarres 5 of PC5s to less than 50 ppm PC3s shall commence immediately upon 6 Respondent's knowledge of the spill or discharge. 7 b. After the cleanup of a spill or other uncontrolled 8 discharge of PC3s, samples shall be collected and analyzed to 9 ensure that the spill or discharge was cleaned up to less than 10 50 ppm PCSs. 11 c. For a spill or other uncontrolled discharge of PCBs 12 onto property not owned or operated by Respondent, the owner cr 13 operator shall be notified immediately upon Respondent's learning 14 of the spill or discharge. The owner or operator shall be 15 informed of the health effects of exposure to PC3s, Respondent's 16 PC3 spill plan, and that no cleanup should be undertaken by the 17 owner or operator. 18 V 2019 Respondent waives the right to a hearing on any issue f contained in this Consent Agreement and Order. ^21 . 22 Respondent consents to the issuance of this Consent 23 Agreement and Order. 24 NEVADA POWER COMPANY 25 26 Da 27 - 2.C 'f f -------------- r -------- :-- Respendent, Vice President and Chief Counsel 28 29 _D a_t _ rJh JU t * 30 .31 .yoc/a. Eller Di rector Enforcement Division 32 A000340 V. rO: i11 -J- a / / / .:*_ y **. - . *v *. ,v":.vr, i.'i; - v . v-^- ,r vv.:Vv: C.'-UTM .t: i i*,,.j j'-icic: 1 ORDER 2 It is hereby ordered that Respondent shall, within sixty 3 (60) cays of receipt of this Consent Agreement and Order, pay by 4 cashier's cr certified check, payable to"the United States of 5 America, a civil penalty in the amount of one thousand two 6 hundred fifty collars ($1,250.00). This order shall become 7 effective irrcied iately. 8 9 loftolga 10 \ ______ Sheila M. `Prindiville Acting Regional Administrator 11 12 13 14 15 16 17 18 19 T 20 21 /" 22 23 24 25 26 27 28 29 30 31 32 A000341 Ou. .1*0: IIM -m -W )  ".v^ 6t, Section A THE VALLEY TIMES Tuesday, November 4, J980 . f ja ze Fo rc e s Es c a p e O f D a n g ero u s C h e m ica lF*i-reAmNenFRhAacNkCedISCaOwa<yA-P*J*'--- `--seuqbusiptamnecnet.u--wsehdichin-healesc*trbieceanl sttafchomonhgaOdea-trmwlfeltfgaririacacucimahpiglalUpeg.l-uesadedn.r-tfacasa^i.Ma-t.uq-yiprd'ttp-aaaaiwreldaerePanK(MnC^pgatBo..eab.gn,r.t*l.deoiaopuaznyasef -wmthineiegkrheeindt ^thcetoaonvnsjecceeiilrnhl'nheeeeaardlt,e/davfnitiprhdoeefnoifgfzufheimcdtieearsilns.s 'insTidhee eclheecmtriiccaall wtraasncsfoonrtmaineresd, who.sqe',. g:'*a>sket opened in the fire. -- A000342 N 03171 NEVADA POWER COMPANY December 1 1 9 8 0 TO: Kei th Grant FROM: Donald Fabbi . SUBJECT: System-Wide PCB Transformers/Testing and Reclamation 3 DEFENDANT'S EXHIBIT Sunohio has announced the first commercial portable PCB destruction pro cess for transformer and capacitor fluids. This new process, called "PCBX", could represent a significant break through in our PCB disposal problem. The process is basically a chemical disposal method that breaks apart the very stable PCB molecule and rear ranges it to form other chemical compounds reported to be harmless and environmentally safe. This process could have important advantages over our present inerting (RTE, R-Temp) process. It is a totally enclosed process that filters and restores the oil for reuse, free from PCB's. Perhaps the most important feature is, this method does not require trans portation, storage, disposal, or further handling of PCB's. The process is portable and self-contained on a tractor-trailer that can be moved to the transformer containing PCB fluids. In my view, we should seriously consider this process as a better alter native to the present RTE, R-Temp inerting. In addition, we should delay any further inerting of the transformers on our system (such as at the Hilton and Horseshoe vaults) unless we are presented with an unusual pro blem such as a "leaker" (Clark Station, Unit #2). Labor, replacement oil, and disposal costs of the PCB oil from the present R-Temp arrangement is significant. Another consideration is, even though our employees work in a controlled safe environment while replacing the PCB oil with the R-Temp fluid, they share a real anxiety about an accidental release or possible health exposure. Presently, we are faced with the ultimate disposal of 14,807 gallons of PCB liquid in transformers located in our customer vaults and at our power plant locations. Currently we are faced with an enormous problem of pro per disposal in order to comply with the regulations currently in effect. I believe the Sunohio process is a better alternative and we should study it, pending their imminent EPA approval. DF/re Enclosures cc: J . McCarthy \0 0 0 3 4 3 [: 12 407 r F'iLD SERVICES FCR ELECTR'C POWER -'SUMS I j Tra^t'O^Sf F'U'O 'es!;ng ana 'eciamotion PC3X' S'jCs'aiiort *eDoifs o-C M a '"-ie.nance S^iichgeat Testing eng Cal'CratiOn TrcnsfOfnne' Eiect'.catlesiing Tfcnstormef ir.iici'ation gng Vacuum Filling preventive' .Vg.r.lencnce Orcgfgms Novemb-er 24, 1980 Mr. Do'nald G. Fabbi Safety Director Navada Power Company Fourth Street & Stewart Ave. P.0. Box 230 Las Vegas , Nevada 89151 Dear Sir: At your request we are forwarding a copy of our recent Press Release on PCBX. We are excited about this new process, however, are faced with the reality of waiting for EPA approval before it becomes commercially viable. In this regard, we are practicing patience. We also want you to know that Sunohio provides comprehensive field services for high voltage substations. We specialize in the following areas: TRANSFORMER OIL/PCB TESTING AND RECLAMATION PCB PROCESSING AND DISPOSAL TRANSFORMER ELECTRICAL TESTING SWITCHGEAR TESTING AND CALIBRATION SUBSTATION REPAIRS AND MAINTENANCE Of special interest is our capability in repairing PCB transformers so that leaks are corrected and prevented from contaminating the environment. We thank you for your interest in Sunohio and look forward to communicating with you in the future. Very truly yours, SUNOHIO T. F. Savastano General Manager TFS/cg Enel l\ l `f ^ ' *000344 NEWS RELEASE \ .. 1700 G A TEW A Y BLVD, S .E ./ CANTON, OHIO 44707 C3*:s * SCaviCi mask Or SU^O^iO FOR RELEASE: Thursday, September 11, 1980 FOR FU RTH ER INFORM ATION: Dave Gibson 216/453-4785 SIGNIFICANCE: PCBX*-- FIRST COMMERCIAL PCB DESTRUCTION PROCESS READY FOR EPA OPERATING APPRQVAL-IS SAID TO BE LESS COMPLEX, FASTER AND MORE DESIRABLE THAN OTHER PROCESSES. EPA TO WITNESS DEMONSTRATION OCTOBER 2, 1980. SUNOHIO ANNOUNCES PCBX CANTON, OHIO--A ready-to-go portable process to destroy highly toxic PCBs (polychlorinated biphenyls) contained in electrical transformer and capacitor fluids has been announced by Sunohio, Canton, Ohio. Announcement was made by Norman E. Jackson, Sunohio's Chairman. "The first commercial-scale PCBX unit has now been completed and tested. This is the prototype for a proposed fleet of similar vehicles to clean up PCBs nationwide. It will be used Thursday, October 2 for a field demonstration at Massillon, Ohio. This demonstration will be witnessed by a team of some 18 EPA (Environmental Protection Agency) officials. In addition to headquarters representatives, EPA personnel will be present from each of the ten regional EPA offices," Jackson said. . *PCBX is a service mark of Sunohio. K 12 40 Continued on Page 2. * IQTNERS"'* 04 S'.'N C C V A K V 0*0 TfUNSFGRM tft CCOPOaATiOS SuSS-CiAe.es - ' ' it * Similar presentations of the apparatus at work in actual field application wfl 1 be given in subsequent weeks for the media and industrial representatives. The new process, called "PCBX," has previously been fully disclosed to the EPA in Washington, D.C. On June 5, 1980, a team of seven representatives of Sunohio presented the new process in full detail to 14 EPA officials, as well as to Congressional representation. As a result of this presentation, Steven D. Jellinek, Assistant Administrator of EPA, expressed the belief that the PCBX process represented a potentially significant breakthrough to the vexing PCB-disposal problem. He requested a full fiel-d demonstration by Sunohio and appointed an EPA task force, headed by William Gunter, to expedite evaluation and approval. While the EPA has been asked to treat as confidential certain proprietary aspects of the process, PCBX is basically a chemical disposal method that breaks apart the very stable and toxic PCS molecule, rearranging it to form other chemical compounds that are either known or believed to be harmless and environ mentally safe. According to Jackson, the PCBX process has important advantages over other known alternate methods of disposal. "Compared to incineration, PCBX is safer environmentally, since it is performed in a totally enclosed liquid system at Continued on Page 3. N 1 2 4! A000346 race j . very low temperature and pressure. Also, valuable transformer oils, contaminated with PCBs, are not burned up and wasted, but rather are cleaned up and restored to new condition for reuse, completely free of PCBs. "Compared to another recently announced chemical method, PCBX is less complex, works faster and more completely, and will be more practical, convenient and economical in actual applications. PCB chemistry was disclosed by the Japanese in a technical journal in 1978, but we rejected this approach as being too complex for practical and economic application," Jackson said. Perhaps.the most important feature of the new technique is that it is the only method that does not require transportation or further unnecessary handling of dangerous PCBs. The entire process from the start was designed to be portable. It is fully self-contained and mounted on a standard 40-foot tractor-trailer that can be moved directly to contaminated transformers, capacitors, PCB storage areas, or anywhere PCBs are already located. The process can handle both highly concentrated as well as very dilute amounts of PCBs. Tests of the concentration of PCBs in processed fluids are done by sensitive gas .chromatography scans and show that there are very low to no detectable PCBs Continued on Page 4. V. 12 4 1 I A000347 whatsoever in fluids treated by the PCBX process. These results have been repeated on all kinds of PCB-contaminated oils as typically encountered in the field. Jackson further stated that Sunohio's policy has been to withhold public announcement until EPA approval seemed imminent. "No real purpose would be served by announcing a solution to an important problem if we couldnlt offer it to our customers for awhile. It is timely to announce our discovery and accomplishments at this time, not only because other process announcements have been made recently, but also because our demonstration for EPA is now imminent and, hopefully, their approval will be forthcoming in the very near future." Sunohio serves the industrial and utility industries by performing specialized maintenance and repairs on electrical substations and reclaiming electrical fluids on site for reuse. Sunohio is a partnership jointly owned by subsidiaries of Ohio Transformer Corporation, Louisville, Ohio, and Sun Company, Radnor, Pennsylvania. The PCBX process was researched by Dr. Oscar L. Norman of Sun, developed to a fully portable, commercial-scale operation by Ohio Transformer under the direction of Mr. Otis D. Jordan, and will be operated and licensed commercially by Sunohio. -0 O0 - N 12 4 1 2 A000348 ( rV. V . . With Amii-iu .1 s-j tlepenilrni fn i !ec!rn iInd-t'i.TfNrupriiuiojnny* utinilintiesc.vuimscluMhir'iCoi!vvpl.!n.iv -i ITmunlsn. r Iiih.ntn^;]miA<.'\.p.t-hi,imi-,MkdI1 Dllu'r'insiLlulifjns ine placing nu <in pn.;ii-r miiiMt'nrmcy <f i-leclnc pinecr S U N O H IO provide:- a et iir] -.i !L-ii! i i . j l n i t y fur servicing electric power equipment. T R A N S P O R T E R OIL/PCB TESTING & RECLAMATION I (I 10 7. Z 2 (t aeaFtatawUwoohrqnciinruiasllireltudndlinloilniodissewurcpgbnifregocnihpo'otsmlhmghereoaetmtsarfdfoEopvi,ftfnviemtlaeaichecmoeerrdcitotesdeeuhowvrn.tllubeahoytohtimw,lheCslveerasea1haerlenteen8ciscrecdiahde0clndho(ancaodfil,msFlmmoarutoitieidihedbrlmomam).eereydntyseerroooedtTserrvuorsosoathnfwprehiinrledasuethdsruhemifepeesheeqcoortrapiieurecotlrtirmhercisordmipmadeuoniuermsnnflrnrecoautsamtehteilfwtitrishconroeoetoiocterudtnnttev,omhuunr.deengratehSndrtnhGrpataaoeUdonmnrfdsaetoNrasedntsoifcnhsbnOoteome.kogeelarrsHva.daTmnstestttIetohhheoneosOdpeeesrr,tf TINRSATNASLFLOARTMIOENR CONNECTIONS Primary and Secondary ACCEPTANCE TESTING FefhtalmtharornyoansearVddrnm.kirnsAmhaaeftmCoitpargoehriraUhnddimiixsogeeeUireohsdtmrihrtMn.l'vtuesowTpanmhoshFchiosoguiifIsslliihpLuiellidlbaemLetvslndfhIieisoenlNeuillwtssitdrrnGuhaeiaagitlgiesth.pagieltohpediThcnoltrvirtehnyeraaai.edinccntoseutiftodltvuoorawmardmtltnihuhtesi*ehees S U N O H IO fi' I'i k*t mu liin-t u ill iT'imr t*j your plfiill unit dr.iw s<imp!ei from your oil or P C B lilk-H electrical equipment with POW EFi ON Tin- following comprehen sive A S T M screen tests for transformer fluids are then performed in our labora tory. 1 . A .S .T .M . D I5 0 0 - C o lo r This is a test in which a sample amount of oil is compared to a graduated color standard, thereby enabling our technician to classify the sample under a standard A S T .M . color. 2. A .S .T .M . D 1 5 2 4 V isu a l-S lu d g e This is a visual test to determine the pres ence of carbon, free water, insulating material, or insoluable sludges caused by deterioration of oil or P C B fluid. 3 * A .S .T.M . D877 -- D ielectric V o lta g e B re ak d o w n This test is per formed to determine the electrical insulat ing "strength" of oil or P C B fluid. 4. A .S .T .M . D 1 5 3 4 -- N e u tra liz a tio n N um b er (A c id ) This test deter mines the neutralization number or acid content in transformer oil or P C B fluid 5. A .S .T .M . D 971 - In te rfa c ia l T e n sio n ll F T ) testing performed to determine the amount of polar and non polar compounds in transformer oil, z: o 3.0 co cs < CU 3.5 ! os: o C O o>J u o PS u s cooPS u. 2 < 6 . A .S .T.M . D1298 - S p ecific H G ravity -- D 1S10 for P C B flu id s This test is useful to the field technicians for dctermm.rg the uc.uh.t of oil or P C B fluid to accurately compute the neutral num ber in me KO H g li ha* no direct indica tion to the quoine o! oil or P C B fluid, hut is useful for -dent:fy:ng P C B 's and oil con taminated with PCB's. z< K 12 413 A000349 1 IT.ll UIAIIsrUKMUl irVLUTOHY - CIJSTOMCR VAULTS LocJ tiun lour Queens Motel Trans former Manufac Lurer Pennsy Ivditia Ui 1ton Motel Tljin Trdnsformer Vault McCarran Field Underground Vault Westinghouse 1 McGraw Edison Horseshoe Club Underground Vault Westinghouse Spare Transformer at Pole Yard Sparc Transformer at Pole Yard boulevard Mall *(1) Underground Vault Western 4Motel * North Las Vegas City Hall Westinghouse Qcar State Westinghouse Westinghouse Allis Chalmers (1) 8cplaced PCD Fluid November 5, 1900 Cumpany Trans former Number 5700 5701 570Z F476 F477 H327 H32B 8094 8095 8096 7938 6618 E666 E667 G600 E317 E31B E319 Size KVA 500 500 500 2500 2500 2500 2500 833 833 833 833 500 2000 2000 750 167 167 167 GalIu m s of PCD Fluid Aruclur 711 711 711 Inerteen 615 615 E 1emex 615 61S Inerteen 395 395 395 Inerteen 395 Aroclor 237 Inerteen 425 425 Inerteen 355" 1nlorexlol ~ 27-- 237 237 8326 TotrTGal. To Lai lbs. F PCD Fluid at Location Approximately 24300 14059 14059 13545 4515 2709 9716 4058 6127 9516B Total l&s. lutdl Kilograms PCD Fluid at Location Approximately 11002 6390 Vault Contains Sump Pump Floor Drain Metal Tray X p H in $- X 6390 6157 2052 1231 4416 X X N/A N/A N/A N/A X i N/A N/A 1044 3694 X X 43256 Total kg 1 J 'niiirise 5 U t i o n u jut) L . Veyas Va 1ley c I.irk Station Coi*. C'l'cra Id 4 Uni t Stephanie St. .*1 Clark Station Cop*. Emerald 4 Unit Stephanie St. -2 Cljrk Station Cut*. En;erald 4 Unit Stephanie St. 3 Clark Station Cor. Emer Stephanie ald St. 4 02Un it fteid Gardner Moapa, Nevada Aux. Floor Uni t #1 lleid Gardner Moapa, Nevada Aux. Floor Uni t 02 Reid Gardner Mojpa, Nevada Aux. Floor Uni t if3 lleid Gardner^ Loal Yard ConLi*o 1 Room tieiil Gardner Cn.il Yard Control Room I 1 West M'jhoU'jL' 4.16U V PCD TRANSFORMER INVEII 10RY - CCMC RAT ING STAT IQHS SERIAL 1 7376501 1500 Inerleen " ' 595 6001 Genera 1 Electric 4.160 V 0173841 1000 Pyranol 425 4850 3091 2208 General Electric 4.160 V C500157 3750 Pyranul 10 13577 6172 Allis Chalmers 4. 160 V i 3298203 General Electric 4.160 V C501946 Chlorextol 1500 467----- 1500 Pyranol 520 " 5224 5944 2374 2702 Westinghouse 4.160 V 7023522 1000 Inerteen -- 335" 3840 1746 General Electric 4,160 y F959057A 1000 Pyranol 330 3772 1715 Westinghouse 4,160 V PBV7213Q2 1000 Inerteen -- 575" 6607 3003 Westinghouse 4.160 V PBV72141 750 Inerteen 250 2972 1351 Westinghouse 4.160 V 70233844 Inerteen 750 240 4929 TotaT~1. 2743 56338 Total lbs. 1247 kg.25609 Total I'dye . N/A Not in Immediate Area Not in Immediate Area Not In Immediate Area Not In limed tate Area Not (n Immediate Area Not In Immediate Area Not In limed late Area Mi ---- -------- cv if c` e - tJ f kc id Cjrdncr Sid lion ;iod|)d, Nevada Unit r1 - Westside ' He id Gardner Station Moji)j / Nevada Unit =2 - Westside Reid Gardner Station 2Moapa, Nevada Unit - Westside He id Gardner Station loapa, Nevada Unit 3 - Westside Reid Gardner Station loapa, Nevada Ash Pump House General Electric 13. KV H E Corporation ITE Corporation 1 West imjhouse 4,160 V West in gh ouse 4,160 V PCB TRANSFOUMEU INVENTORY - GENERATING STATIONS F260506 Pyranol 305 350 4001 1616 21503R01 1000 341 3098 1772 21503001 1000 341 3698 1772 PBV721501 PBV721601 1000 Incrteen -- nr" Inerteen 750 -- 265" 1552 Total G a l . 2915 3029 17741 Total lbs. 1325 1377 8064 Total kg. Figures Based on 11.43 Ibs/gal. and rounded off to nearest whole 1b. I 14607 Grant) Total Gallons PCB Fluid in all Trans formers 169247 Grand total lhs PCB Fluid In all Transformers 76929 Grand Total kgs PCB Fluii in all Transformers 11- 20-UU Not in lunediate Area Not in Immediate Area Not In Immediate Area Not In lunediate Area Not in limedlate Area N v-- icl.l-- P 3 ---- 41? (V MTjj rCOoMwtPAnI ; .j NEVADA POWER COMPANY December 9, 1980 ^ T S fendant^ { EXHIBIT I I YXxvr I i 12A l W I Notice of Results: PC8 Personnel Sampling Employee: Luis Pineiro____________ Survey # ______ 034_______ Sample Date: 11-03-80 & 11-04-80 Date of Results: 11-26-80 Attached is a copy of your results on personnel sampling for occupation al exposure to polychlorinated biphenyls, which was conducted on the *above date. This letter notifies you that your results reveal an exposure of less than allowable limits. Current limit for exposure to this chemical rests at .5 mg per cubic meter for eight hours. Since your exposure is within the allowable limits, you should not be unnecessarily concerned. Nevada Powe-- Company is interested in your good health; therefore, be sure you use all protective equipment provided and folio;, the established safety, procedures. If you should have any questions concerning this letter, please contact your supervisor or the Safety Department. Sincerely, NEVADA POWER COMPANY DGF/re Enclosure cc: Employees personnel file Supervisor Donald G. Fabbi Safety Director Aonn.'ifvi customer services, inc. 333J C a lifo rn ia tra e I $*n F f net*co, California 9 4 1 19 TttapTiona (415)939-3352 LABORATORY RESULTS - GAS CHROMATOGRAPHY T O : MARK REDOAWAY PURCHASE ORDER (CONTRACT) NO: ACCOUNT: rzvAOA pacu cn. LOCATION: las vigas, f.V JB N O : 1230-b0 DATE RECEIVED: DATE REPORTED: ltvl-;y oja u ], n. no (j0 ASSAY: FLO'*SIL TLE3ES, PCG'S LAB. SAMPLE NO. NO. COMPOUND 12333 12336 12337 1233b 12339 12343 12341 110067 per?- 110333 FCr' 110039 pen 11 *1090 1 li091 rep PC?1 18092 Per'. 034 PCP AIR COICENTRATION VOLUM E SAMPUNG BACK-UP T O T A L SAMPLED SECTION SECTION liten : : /: "j ; SflV * w v . PPffx 77.111 C O'rs O . Oui f* r i . ' j j U.U04 <' :.o u . UU4 7 7 . 0 0 n .o oc O.'.'>oi 0 . J06 1b . 4 <0.JOl 0.1*01 <0.901 1J 'J.OJ'J <0.0':l 0.0 JO 1 ^ .04 <*'.001 _ <0,OU1 <0.901 NOTES: Lu is Pineiro / >' -1 V ' >\ 7 f'/T : j:L-J- . \\ >>N_n t c n ~ i^s- /* SAMPLES HAVE BEEN CORRECTED FOR BLANK RESULTS. /. 630000-4-76 A00(1^55 RlaisrknseodftdouomlaptiengIOC-- Las Vegas Kevicw-tJournai-^-1 ftursaay, uecemoer o, icwo By Tom Tlede SMITHFIELD, N.C. (NEA) ^The whole sad thing began for Vicky Jor dan in the summer of 1978.*She was a newly wed housewife then, and well along in her first pregnancy. She was healthy, happy and excited with her prospects, and the pediatrician was confident that everything was pro gressing normally. Then a quiet disaster struck. Three truckdrivers who were haul ing polychlorinated biphenyls to a waste facility in Pennsylvania decid ed to "dump them instead in North Carolina. PCB's are used to fashion electric components, but are also known to be carcinogenic; the drivers spilled 30,000 gallons of the poison over-200 miles of roads. One of the roads, state highway 210,'funs in front of Jordan's Smithfield`.Home. At the time the PCB's were;dumped she was in the habit of walking along the road for daily exer cise. She continued to do this for J.hfetT\veek.s after, the spilling, until ilhorities told her of the risks.. By then, she says now, it was too late.*A short while later Jordan gave birth-t<o a son who was three months prfcinature. She remembers that the bsfcy cried a little, and breathed for a whil>but that was all it knew of life; shrsays it just wasn't strong enough, ni{d died in a few minutes. Jordan and her husband, an Air Force mechanic, were naturally devnstatvd. T hey were also puzzled. `1here was no hi.-uny oj bnlh pinhicin'- hi ciijirr ni their burnite*, and until tin* PGR'.- were dumped the pregnant y was quite routine.-They, dpeidd then that the ehemirnls were responsible. Vet* having made the connection, llicre was imibing they could do alfoul'it. The pediatrician agreed that 1'fill's could have been involved, but government health ofbeevs refused to confirm it. Jordan says the govern ment* was of very little help: "The oijly'thing they said was to wash all im vegetables." Mehmiuu- the load menace coniitt- vuid.^tate authorities promised to dig l lie contaminaiion up, if necessary, to pio ff cl the well-being of afleeted people, hut ihe early rhetoric soon fnjderl into legal and financial com plexities. Eventually it became clear ri*ti \u> one really knew wind to do aliourlhe l 'C'H's.' JsiJne-'people who lived along the prjis6'jU'd.*Voads talked briefly about s mt>vj$g. Bui -that reaction was con-1 siietvd to he impractical. Jordan says^the property values had fallen, foj' oiie thing, at a time when morigf^e-'lnlerest rates were high, thus UKistt'Jieople found they were more or Jordan says the second !<>>.- wa; even wot se than the first. Site stil keep.- the baby's picture in a locket around her neck. "1 think it's tiki murder," she say*. "Tlmse men who dumped the chemicals knew they were doing wrong.. It's like they just took n gun c a knife and did what they did." The men who flumped rite J 't'H's ate Robert Hums and two sons. They told a North Carolina jury last yeai that they could not take the chemi cals to % safe storage hi-caiiM* they ran out of tknnspurtation containers. They plOadcd |iuHty, hut have not heeii punished; there has been a de lay in. sent engltig. ;*?hefe has also U*en further delay fti the. disposal of the toxins. The state lifts spread charcoal oyer' the eoyUanimated roads, but a permanent ` \;.-cwIrelaaujnfrs\ui^pitthsseethyheaemvwse-eRrnbGeoeBwedn'uhsmeirilpeemedidn.ajMismni.gothhrepetx: amtShceaatvltn*y- f^o'l^ar^go/^. r - '* "1S.j Jo f Vicky^JoJlan, she ia.preg- i nant again, seven months, and is a patient, at. Duke University's high risk clinic. She says she is nervous Rnd worried, but wants a child v e r y much. i . ____ as stuck in place: So, angry but powerless, the Joruu decided to try for another baby, he freight pregnant for the second mefcaOttober of that year, and ahe lyt'tbr took, every precaution. She ratched ^rhai-jhe ate, she increased er viaiU to the pediatrician, and Bhe3 In May of 1979.Jordan gave birth -again. This time the baby was two months .early, and was burdened with physical defects. It had congenital heart disease (two valves instead of four), and a bilateral cleft (no upper lip. or palate). The baby also had a detached esophagus, and a collapsed ried to stay^away from-state. high way 210. ` yy She couldn't avoid the road alto* ;ether, .however. In dry weither its lust would rise and roll over her property, and during rains there were runoffs into the yard. Each time an automobile crept into the. Jordan's driveway, in fact, it may have diaphragm. i T h e child lived for eight month*. The Jordans named her Patricia Dale. Surgery waa ]>erformed to cor rect..some of the abnormalities, and hope was kindled for a brief lime, but in the end it was not enough. The tiny girl went into a coma In her crib, - and 'died in `the ` hospital (of heart v. dragged some of the polychlorinated *7100356 biphenyls along. N 03172 LAS VEGAS. NEVADA. THlPSInY. FEBRUARY M , ; Beating I Deadline ! Is Goal b mary manning SIN Staff Wntrr j; I;| j AnwahaclBpnft1ioaontaqoeageifectmdlncrueaaendilTTttlddnitlpiehdcFitrhtelcnbddayeuwyerreyyrgnci.acheodtiykolbshnUmapaBlasftdezerEfysSbenaitepflcooaEhnsrouirtaoi1nuuhtfdeoacavdcktMtseomodaylilae1psLiurnlisnsnc2.eosSema.sgs0ecdIxneasoowe-0yt-autfmybfeuv-m.fna-0.RdVeoottus0htreTfwrVte?s0oanrwjetfaghLoxalttniaetedgidorasioscWsdufatuss,dltlnlabm3i*ulsPe0yoSoei.lmvpsPssCcaigUisc.ibtlrpeoh9TBNeltoema0nnihhapu,tseueMarcmeoKsmcreotdfusaotesypdiiurnttnteelohhaceebtxtrlAnhoysyesse-- See Related . ,, S t o r y , P a g e 75. ...._______ i !1! ttciteccpporfiwrnePilionvaoonniaanwt.Cnig0evfmolrnclBeylGgm0lsBaCii.srprt0AdMunpaaoBaoesbaucadtvottpmrornednaeoyooslsiralmraoeiesnnsrltiiacecettdgekt.dioettsihes"crod:rytw'inPnnaoconestsstfCtleaotaeraoaeBlutatsiprsoAoBfiosdclpreedetmpaehAreeaCdisdkrqttoedot3crJseeeoamuaet'xipeepiuyrmisLnnmepunlaaraarnseitnrcsplndepnetniupaetytegroooiyespsiwndtrlrsa*wlrn.aePGeaigtli'aaqntagydxueCW1oovjiaudruecurA,rBPci_fcJeli:edaiir--Ca?hi<itlSlbdssptrtll:seetBue.eais*pjPe-mroctnfnhrai-rrbCesonerufnotisitxMaidtgrFsBch,rvleecmhla.raeeieLaegsaluengdttmdreob.inrfostescnqdiiasfuhucnmhlleeupinciimibilcnxcnotiipsasagleyyldgtr-.-rl * aoooot N 03167 \ , ~X i FirmTBoexatiincg DWeaadlisnete Due Here i;.,j|:!_.JTlcTgctctslLipeddtBcplsLbpttTociamowm1_isaaoonaahorapCenaoaeara9faooonahnaaeihnrbuiinnifoloeo8geptnpmxrdsldkanhusysvDlsi]e"hdTCceoUuPnt0Anok'aitcyiace.ate_eer1-pnannt.ktemfraaUnftitdCh.heVcuglte9rsdfoeciiaadG--fhhyelsiitCavrots*llie7dnseeroaair,inBnn,lclte.foe.eymsen9hneatfdsraseein4iaooekrr.,egtrodr.,n.es"raruytu7sdrdoeytauBiMaedsP,uunorssddehh.csMse1stTl,l1fdnbfnsesaeotrScorh.rauoeo9ia<i.lehsJradns3owlwSd-sai8acoyluuifr.boowl9nePtea4nao91ordrihpssnrwllth6eartuwcc.,.dnrdi,ditdcCripFyfdtstbrdqnlua7ali8tknhOeiwoaiedgiehuiillwfIrB3reSnduqbrneldadntaadlta'feoctbdo6ie9lngpfesig1Suool,eisthneglvhcettdcbaneelu,tddm,lhlhnirEdalcdifteortU,adetsmrobgfgih,'Pootcrmaandcasop'tabrotooiotiaaLrerae'CsbcnoftoclcsapoblnuinsalldeiPogapehilytclhllBmuscotocr4ogymmtoho(oi-mesoaBeoeautse-(htni6auGcfh-egatrrtnnrremalmregrfdme0pceeehpgptoitdveuddplsfcsaPeainnoaeiSUttauafagtipCcoiuanls5nvciCcocttemeaneareclngkeuae0tnnabtitaotmaosaswiineddilngBydhoyro-d0yssnn-1,-l-t.ll)'GesaGmspoalafrcPng1olOeatpfS(sliteeaouqt*uitcnlGhed.ouxtinhCoiaefteal0oiafiszcnjcnhu\sraudlopl'edvduefra0vvarFeskliiBioTApcPeIcAtaiimneeettoor0n.s,!isvdif*up"eeredCnta-niteChdsrrcrdebCidTni3Bnisrddhdm1iiornnnotJoetdBcsil0SoasB0ashoyieutsmeum'nsnonafean0eui0t''itti'idtaleouttsanxsnnpnrpslioflaonosgotkhiyhirmarre.lbpcttytsnarboimtafstaeeehhoediateedtlmorhytdnit1ttwcGfinaoavdfh'nhaoovu.irtiolorcxsi.ao.eastlti(lendse4t.sh1ptesaroeosreilnihahrsvhtkpuaecpi9roevd,TtmGnenrdeeh'oleceeee,f2ddocabni,i7i"odtio1enhtemWnda9hghomssabdieSea.f9.o',ivolopenbeltucainfnexeu52llgt0~7awdhrsrnite*hnpwxsioGsmemonpn0vh0tneo8s'e,uceafuaoeoue0mn.vinocnata-.encsatdarilonymiutna'yatoismctsvihs,1eenropfhnanidewieu,ilao0iacdrirtnpnmtrniondecngdUacsiinGooptnilhray.isno_mcalnleasrsu'oitueobmnllleesswtludbasnlo,_ladtri-iufclfiraleuohdainvovoononalieytinnaataeeotudnniieudeoeeiherunrlstdsrrdnnidnscgngesrset.ddy-nr.sd',,aaete*tss-.e*,",th,^.t man beings aren' t im mediate. according lo Dean Gillam. chief of the hazard assessment section of the E n viron m e n tal Protection /tgvmy in Ln-mrr. Co fo aIn htviriuory a n n u ls the cherr.tcal ;s suspected carcinogen, has changed chromosomes and fcius relb. GiUam said But then long-term atent effects f rhrunJc exposure io PC l; In human* r* 'i' .-auv sk:n lesions, tumors on u* ver ana scxuai liyMjficV. Gillam said We don l know ifj.it > changes human g<<n\ Giltam vsaid . S lM t ^ -, W Annoa58 031 68-