Document NNaDake0b2Eaqvpx3M8KyGjrV

A r ' iJtON *v ' '* CHARLES H. MoCREA-, SR., NIK SKRINJARxC, ESQ. ESQ. j o n ^ s , :: ,,NESjf i CLo s r . v br own, c h a r t e r e d 3 GO'S l u t h Fo|lth : r ^ t c #00' ' [910.1 -6026 nC-7^2) 385 -4202 y - *\ y**' S I ' T rb ?* * % v - ; * || i '* % ' . * COURTE V * - ` DISTRICT OF NEVADA 'l NEVADA POWER COMPANY, a N e v a d a c o rp o ra tio n , P lain tiff, vs. MONSANTO COMPANY, a f o r e i g n c o r p o r a t i o n ? GENERAL ELECTRIC COMPANY, a f o r e i g n c o r p o r a t i o n ; WESTINGHOUSE ELECTRIC CORPORATION, a foreign c o r p o r a t i o n ; a n d DOES I t h r o u g h XXV, i n c l u s i v e , . D efendants. iffy CV-S-89-555-LDG-LRL OPPOSITION TO DEFENDAIT.*S JOINT MOTION__FOR SUMMARY J U lX-.MKNr ju d g m e n t on t h e f l e a ^ nc " REQUEST FOR ORAL ARGUMENT EXHIBIT 11 U.. - i F A P . T '.i.\'7 r L A 2 C R 0 ;c -jp iio .u J Sdf t zy nd h,ia ... c.Thniitmion l f l\ f > i : S / > ; Y ' J } i , i -* >! ; : 1 ._ k( fc- \ Aw- W* w t I i -*n U I lt>* 4 k k <*>( Im t Require! jncw r U SO L S i i r i y and H eiltb Re^ula^ons to * Snip flcpiiring, S?otyjiUjino. nd Shipprcikir^ (29 C ? R 1S15, 1916, 1S 17) * 7 ----------- -- SECTION 1 * L m anuracturcri name . . .J CMCAGENCY TLPHONt NO. General E l e c t r i c Cotrosny y o o s liiifftumcr. Strctt, Clrj, Su it, md If Cod*) Rome, ^Gt. 404-234-021 1 .. r i t t i i i-t-t-o-;--Mtti--4 13 404-1 100 Noodlavn Aye. `P ! t t f i ei a vu-- n i'o n r * HtvT.AU NAV.i a/s'o synonyms TRAD UAMt ANO SYNONYMS C h lo r in a t e d B ip n e n y l/ C h io rin a te d Bemen# B lend Pyranol, Aroclor ' CnUiC/l r auiuV AskareT/Chlorinated Aromatics * * *. S E C T IO N II - H A Z A R D O U S IN G R E D IE N T S PAIWTX, PRESERVATIVES, k SOLVENTI X TLV (Uniti) ALLOYS AMO METALLIC COATINGS PIGMENTS AAAI UETAL - catalyit ALLOTS ' VEHICLE SOLVENTS AOOiTIVES OTHERS x* - ' MCTALUC COATINOS FILLER METAL 1** PLUS COATINO OR CORE PL/X/ * OTHERS * -*: . . .. . . . HAZARDOUS MIXTURES OP OTHER LIQUIDS. SOLIDS, OR OASES TL (Un N . ; j y P - SECTIO N III * P H Y SIC A U -O A T A oiling point (V.) VAROR RRCSSURE (mm M.> VAROR OANSITV (AIR-1) soLuaiLrrv in water 410 -7R0*R A p p ro x .w 1 1l . . 104*F Approximate! 6.5 N il SR-CCIRIC ORAVITV (H,0-1) i PEYRVCOELNUTM. VEO(XLIATILE EVAAt)RATION RATE ( 11 . Rome, Ga. 4 P1r <f i e 1A 6 Hrs. 8 2 f aupcawancc ooow C l e a r L i q u i d with Y e l l o v T i n t , S l i g h t a c r i d odor SECTION IV - FIRE AND EXPLOSION HAZARD DATA ! r _a s -< c Iis t | y / i r . o 4 a ) C l e v e l a n d O o e n C u p _____________________ Nona to H n t H n r P a in t___________ I IXT.NSuilniNCi MEOlA None Required l A W W A SL LIMITS None- i iPtC.AL ClAt PlGHTINQ PROCEDURES liafjy<aT I t n n a f h s a n S U AD* 002 15T - j UNUSUAL RiA t ASO txPLOSlON h AZ>OS p - r \ A n r * A h y g _ A 1 / r T r -i r a 1 n ft r n n r a i n h i g h p x r r x n r . i g n f I IT. 1 ; . r h e _ u n p 1 r n * a n t n e . S S . 'and i r r i t a t i o n caused by MCI give amnle warning o f i t s - o r e s e n c e . PAGE ( 1) (C ontinued on rov tid) Form CSHA-2C 1 Hi*. u*r Ta Exh i b i. "F - 1 V'-i i .. 'J2.;.iI . \* ;V fV. W1%' i' a n V\> V* i^.*| I* V # \- P' -S "v , $ T } .vc} ; ssa I m 11( : .y.r I %) .4 \ !) !\ i i 'It V j SECTION V HEALTH HAZARD DATA i i ivi. : ..*' T v * ' j t ,, " .,,, Vapor 0.5 - 1.0 ngm/cu. n e t e r / S J H r . Day . ,.v> z-.'zp 'ItNil^TjjT * * "' t-- Dermatitus; P o s s i b l e Cloracne - Eye I r r i t a t i o n See ANSI C107.1 - 1974 c-M tnG CffcvAN o fir st a io p r o c e d u r e s * *V l*4 , ; 2. Kash sVin; i r r i g a t e eyes. * . \ t , ** * * JLl Consult physiciail. v STAAIUTV ' Lr:UNSTABLE SECTION VI - REACTIVITY DATA " CCNOITIONS TO AVOID * . STAILE INCOMPATABiLlTY (A/aunaiitoevotd) X . 1 % mA 2 A R OOU S DECOMPOSITION PROOUCTS HC1 when arced e l e c t r i c a l l y - HAZAPOOUJ POLYMERIZATION MAY OCCUR W ILL NOT OCCUR CONDITIONS TO AVOID x` -111 ---- * SECTION VII - SPILL OR LEAK PROCEDURES STEPS TO 8 T A K E N IN C A S S M A T E R I A L IS RELE-ASEO O R SP1LLEO U s e F u l l e r 1 *? e a T f h - _ t . r L _ A v n i d s p r e a d n f _ l i q u i d _____T m e d i a t i _ * w e e n i r . g . n f r h e r e q u i r e d with disp o sa l, i n t o dnra container designated fo r Pyranol contaraL F u l l e r ' s e a r t h - see ANSI C-107.1-1974. w a s : OISPOSAL MET HO o ----------- In rl a^r.ar Inn, -See ANSI C1Q7,1-1974 "G uidel ines f o r- h a n d lin g and d i s p o s a l . o f C3?ati transformer-grade askarels containing* polychlorinated biphenyls". -rr-- SECTION VIII - SPECIAL^PROTECTION INFORMATION "r e s p i r a t o r y p r o t e c t i o n ( S p \ f y typaj L a j B a s i c o t o r g a n i c c a n m s t e r t y p e o r si meai-hing apnnr^rn^r^n ^ e ^ s e d VENTILATION *n *g^ r 5i*-n r/ ^F. jTp-:s m s p hi ec ni ^ahl rtC?r r a -i m e c h a n i c a l (Generai) o th er p r o t e c t i v e g l o v e s use. gloves ot neoprene, EYE PROTECTION no! verhvlene n r VIfon_________________ S a f e ty g la s s e s o r eye shield: othX r Protective eq u ipm en t ______ Use aprons o f neoprene^. polyethylene .or... Viton'., SECTION IX - SPECIAL PRECAUTIONS pr eca ution s to ee t a k en in h a n o l .nq ano storing ,, Avoid open exposure o f hot as kar el s f> 130 FI. Be a l e r t for nos sib le a l l e r g i c . a c t i o n s . Normally shipped in necal c o n t a i n e r s . A f t e r handling, wash hands with ^ T^ r ^ c T U ^ n < ^ ua?~be f oTe ear ing --dr i nking, smoking o r m a c uf t oi l et I j l . i i t i c a r4 ** .1 '\v , <. ? A G c (2) C C > U . | R 2 ADM 002 158 V. Form OSHA-2C Her. May 72 Exhibit F-2 0 9 -~"l M QO*QTtvJ No. 44. I u ; I" * aju> TJ K Ju 30 i U. S. OEPARTr.' EIl JF LA30R ^9w(?r k p l a c e S T A N D A R D S A D M IN IS T R A T IO N B u r e a u o( Labo r S t a n d a r d s ? MATERIAL SAFETY DATA SHEET SECTION I U A N U A C T u a i a S N A | MONSANTO COMPANY A p * i s s r . v . f , t i n , C i i * . ) . . oOO N o r t h L i n d b e r g h C h ( wiC*C n a m | ano NONt u j Mixture z/^ C oJt} Boulevard, C H (u ic n f Awar Chlorinated arotratlc i Yl-?<Y*TlutrnoNc ncT (31*0 :Q^- 1000 St. Louis, Missouri 6Rl6o -- T a 0 n Z m| ano SN C N*Js Pyranol Al?3?B-2 0 a* * j l a -Mixture SECTION II PAINTS, t te J VaTIVIS. ASOLVNTI * t iGumrS CATALST HAZARDOUS INGREDIENTS TLV (U..M) ALLOTS ANO *TALLIC COaTINCS IASI U(TAL allots VIHICLI SOLVINTJ AOOlttVt J OTHtM MITALUC COATINGS riLLULSiacouaTtainlg 0 coaf LUX OTHjas 4 MAZAAOOUl kl XTURCS 0T OHCt LIQUIDS, SOLIOS. 0 CASCS n( * L- i ,,SECTION III PHYSICAL DATA "OILINGaoiNT (V.) 7 o 0 mm r2\>1 ) - ^ 0 0 ^saccinc cavitt ih2o=\y>Q ^ VAaoa aaosuai i>rw*#.j : Ava 11 a1t*CVO(NlUTUvfolIaMtili VAo* OtNSiTY lAia=1 Vao*arion am No : Ava \ 1 1 ='' SOLUeiLITT INWAT|a2_0_ 0 C_ n e g -l i. g i. b. .l e AF9(A*ANCt ano CO0 a Colorless oil aromatic odor ^ Burn 11,1 UTlNGUIjMING UfOlA SECTION IV FIRE AND EXPLOSION HAZARD DATA ... None to B o l l i n g $ L A LLM A L L I MI T S Self Lai '"Slav :: S M C i a l n ( i G h Ti n g r O C O u S _R e s p i r a t o r y p r o t e c t i o n when f i g h t i n g f i r e s where e x p o s u r e .to. vapora or gases is possible UNUSUAL #IAa ANO U r L O S lO N HAYAAOS Highly can be evolved. toxic gases (hydrogen chloride) ACM 002 l r SECTION V HEALTH HAZARD DATA _Th_a_I_S m_C_K_O__V.1_W_1T_V>ACO! H r t a v a i.l ,a b l e (MICTS 0# OVIMWOSVJM SVln I r r i t a t i o n I n t h e .form r.C r . h n - . q -r p , I n t o x i c a t i o n le a d s to n a u s e a , v o m i t i n g , l o s s o f w e ig h t. edema and a [ul*C4NCt\ nOMUST AlO '*OC[OU*(J Remove from exposure. Resnv cnntaml ra r.erf r.Tnthlr? dominai pal Wash c o n t a c t e d a r e a w ith l a r g e amounts of w a te r and soap. Lt T Refer to physician. r i jtajilitt UNTAILI staili r INCOu^aTAULTT (Umtin.-ait urn mvm*4) SECTION VI REACTIVITY DATA . CCSOITIONS ro av010 X M A X A A O O u S O I C C W ^ O S I T l O N N O O u C TS ------------------ ---- .------------ -- t r - 1 1 MAJA c o o l i ^OLrUCAUATlON kAAT O C C U * WILL NOT OCCUA CONDI TI ONS TO AVOI O X ! [ i______ __ . - - . . . . .. ...................................... - i1 t. SECTION VII SPILL OR LEAK PROCEDURES ST|P"S TO 1C TAI(N IN C a SC u a TCAia l *S * ( U ~ S i O CA Absorb on c la v , sawdust o r o th e r a b so rb an t m a te r ia l. Place In C 1 r drum s. Bury In a p p ro v e d c h e m i c a l l a n d f i l l in a c c o rd a n c e w ith 1; and s ta te reg u latio n s. a s t i 013p c sa l uiTHOo Burn In approved Incinerator in accordance with and s ta te reg u latio n s. j SECTION Vili SPEC1AL*PR0TECTION INFORMATION MS^iaatoat otiction (ip*ih it**/ Bureau of Mines ;. VINTIULTION local ia*lYauesst - f o r v a p o r s . UICHANICAL, (C4**rml) approved resp irato r SHOAL OT^I* fo. o n e r i v i c lo v is rubber OTHCA 0 fcc TIVI IQUIAWINT CV| OTCCTION c h e m i c a l g o g g l e s SECTION IX SFEC1AL PRECAUTIONS ( C a u t i o n s TO u t a m n i n h a n o l i n C a n o STOAj n c I ! Avoid skin and eye c o n ta c t, avoid in h a la tio n of vapors. ; OTHiA m(cau tiqni It 1iTfiC -- 'W* ^ t ^mi ml<~ +m -*---4^*-- While the inform ation and recommendations set fo rth herein are believed t o b e a c c u r a t e a s o f t h e d a t e h e r e o f , MONSANTO COMPANY MAKES NO WARRANT WITH RESPECT THERETO AND DISCLAIMS ALL L I A B I L I T Y 7 3 r " ELIAN CD T W ^ - ^ - 4 ADM 0 0 2 1 c o r C A p p r o v e d OHB Ho. AA-R1337 *hp r o va 1 Expires*. < J u l y 3 0 , 1 9 7 2 U.S. CE?AuIL':E!!T r LAC02 Form No. 0 Hay, 1571 u r RIAL SAFETY DATA SHEET' SECTION I W I, . I * C 1 N A w f __M__O__N__S_A__N_T__O___C_Oj_M__P__A__N_Y__________________ (u ia iliC ) ' xO. ( +\ L ) p e a _ i m o >: : m i l i m i k i t f . 1 i * m m > 2 < ^ C i i . oOU N o n l i L i n c b e r p h p o u l e v a r d , St. L o u i s , M is a ou r i 6 316 6 . L"C h l o r i n a t e d arom atic ' lOl x*" t O ISO rul Pvt*aro1 &1 r?^p O w w4 Mixture C ! S E C T I O N II H . ' 7 / p 0 0 U S I h T ^ - O l - > * T S iiM ti, m * C M| X I J C 4t AkTfl : i n ' i v i i , a i o l t I mts * i *LV , | A L L O T S AMO m C T a l L I C C O a Im CS All UlfAL A llo ri I v fiC U SO.v i s t i 400'* 'Vi i O '- 1 i 1 w it* m c coating M ill MITAI >iui co atim g o c o * i not O lM |tf H t U I O O u l i H T u M l O ' O T n H L I QUl OS . SOLI DS, 3 Oliti r iu. SECTION I I I PHYSICAL DATA i n; c>.i 7 6 0 v**0 M llu il -I v * *C Cl I A>a 1 nn H 2 liO-fa 0C Not! A v a i l i.'od A v a n C I>MC" ' C c " v' " '"i~ " ( 1 5 . 5 / 1 5 inc.rvoi.mi ~ -~ I V O : vji*t . . . I y.. ! 2 0 o n e r i i c i b i l ________ I ' u u s c i Axo 003* colories: oil aromatic ocor ~t m 'i n rw T n < rT H : SECTION IY FIRE AMO EXPLOSION HAZARD DATA 'ui-< O'M L l i I Ix c u I V Ix c, u|Q{ 4 None vai--**lit iiMiTi j-i. i " C - -x o OC l 3 w l r - : s : l r a t o r v p r o t e c t i o n when H - h M r r to vapors or gases is p o s s ib le . ! *\-nV *V c ?.1 vS*i1 5i/*T4 h 1or id c s and chlorine) can De evolved in fire s of th is product. iCM 0021^9 r C ' 7v rano 1 A 13 3 SECTION V H E A L T H HA RD OAT A (V R . )" . w i hot available. L'f-.in i r r i t a t i o n i n t h e f o r r , o f c h l o r a c n e , s y s t e m a t i c l e a d s t o n a u s e a ^ v o m i t i n g , i c s s oi w e i g h t , c e r . l _ a7ri Intoxication a t t e r . i r . S i ------ v c n'j i*si aio i o r e m o v e f r om e / . p o s u r e . ^ --1 ri> Pemove c o n t a m i n a t e d c l o t h i n g . Wash c o n t a c t e d a r e a ' w i t h l a r g e a m o u n t s o r w a t e r and s o a p . R e r e r to" pnysician SECTION VI PEACTIVITY DATA UHJT 4 |l( * Z 2 V * * I A llAtll It / " Mll ! * < . w Nv .i.v Nt 10 AvO'U X - * ; a.30oi oico-^osiT.ON oowct^Q ^ CC2, s m o k e , s o o t , c h l o r i d e s a n d c h l o r i n e - A.**OOut " . w| 11/ At tON WAT O C C u * * U l **OT O C C O c o w o m o N i to a v Oio X C( c Ur, ile the i n f o r m a t i o n and r e c o m m e n d a t i o n s s e t f o r t h h e r e i n a r e b e l i e v e be a c c u r a t e a s o f t h e d a t e h e r e o f , MONSANTO COMPANY MAKES NO WAR PAN U 1 1 H RESPECT THEPETO ANO DI SCLAI MS ALL LI ABI LI TY FROM cJ AC : HCH : JTG :V/EP f AN CE THEREON 1/ 26/72 /-- For m A p p r o v e d 0M3 Ilo. 4 4 - P. 1 3 3 7 Approval Expires: J u l y 30, 1972 0 L W f c l H II I k , . | , I n^ r 1 n p .'in U . \ O JPI F o m No . G3 rHay, 1971 2 1 IO 4 M AMU 0 AC T v * " * * * "* 1 MONSANTO COMPANY 1 QC* C11 l i f o t t C ( I f . J l t i a , a/ n* 1 P C 4 *J 5 800 North Lindbergh Boulevard, J C C mi CM. > . ( i h 3 I t h O m t u * i M i x t u r e ______________ \ c n T o r i n a V e d a r o m a t i c SECTION I N-- .-A. -- ( u ( N S I n ( T T I H mO N ( k o . ( M ^ \ 604-OOO St. L o u i s, M i s s o u r i 63166 NIT X O C M ( AMO I t n O n t u I n r_ A r n r J 1 > An * O AUU L. A Mixture { SECTION II '----------------------------- -- -- : ' a - i n -- r -- n * - r ----- r - ---- _-- 3 T paimts, r t iie t v A t iv t v . a so lv in ts * iC mj h r j HA7Ap.o o y $ jN n :* sm sr-J! IUtl1v11 rs --------------------------- A L L O T S AMO M f T A L L l C COa T IAS( METAL cat A i t n AUOTJ VfHlCll SOLVlNTS Aooi f v i s Ml TA LUC COATI NGS *n1u11l(1COUtaTTAiLnC0 COM LUI OtHlAI 0T-lS H A Z A O O u S m * X T U M OF O T m I I LIQUIDS, SOLIDS. 0 9 CASES SECTION I I I PHYSICAL DATA J] ion-. *INC rOiNI (~.*1 -7, or 0-, mm, m - .i ir.i'.-u *' - a r s r r j T r t 8R8 ~ b 2 ( r j c 4 s*4ciic c*a.virr in^or- u. ^ 5 / 2 5 'C ) 1 VAAO* " issum 1-- ""`l q 5 _ 2 4 5 0 C R r*_m M*VCOttNOTWVIOL1AT1ILI * VA*0* OlNStTr iaiI 11 ot Avail 1VA0**TlON *AT| i R n L n ----- =u l SOlUIILIt INWAll*- - 0 _ S 20C p Ai F7V t7A I A N C l ANO 0 0 0 n e R l i f c i b l e <0.03* yellow soft resin tsalu;i g h t 11 a r-oremn a-|--t 7i c a r r odo xrj* rF- i , SECTION IY FI RE AND EXPLOSION HAZARD DATA I iIluAlXM0>0'NT iMtlAl U T i N G u i J*iNG w t O i A None U A k M A K i LIMITI SMCial `Al UChTihGFCOCIOUAIS Peaplratorv nrotertlnn whp- r' vapors or eaae3 is possible.* n5_f-ac SAPPSLITS- o------ :j ?| u,'^*hV"gx'l.'c'gsy4(chlorides and chlorine) can be evolved In f i r e s of th is product. 1li 40H CC219 7 C ( c r o c l o r 1260 S E C T I OM Y H E A L T H HA tD DATA [MUtS'-OlO uwit VALUE Not a v a il. j*Sk I n i r r i!t a W o n i n t h e f or m o f c h l o r a c n e , s y s t e m a t i c i n t o x i c a t i o n l e a d s t o n a u s e a , v o m i t i n g , l o s s 01 w e i g n t , edema .and aocldjlllnal p i l n ( y t * C l N C T AND H * S I Aio N AOCtOuafS Remove from e x p o s u r e . _ Remove c o n t a m i n a t e d c l o t h i n g . c o n t a c t e d a r e a w i t n l a r g e amounts 01 W a t e r ana soap"! R e f e r t o p h y s i c i a n . Wash SECTION VI REACTIVITY DATA l i t A111Tv UNS7 AIK Ii nO AvOiO STAILI inCOxaaTability (Hiff 1*1 io oji41 X 0 0 HAiAAOOuS OIC OwaOJITiON OOuCTS HAjAHOOuS ' O lyui*u a i i o *< WAT OCCU WIU not OCCU* C0 2 , smoke, s o o t c h l o r i d e s & c h l o r i n e . CONDITIONS TO AVOID X SECTION YI I SPILL OR LEAK PROCEDURES Xfe5 r , on"fr*s'aiViSk,* S f c& R i a b s o r b a n t m a t e r i a l . P l a c e i n J | w i t h l o c a l and s t a t e r e g u l a t i o n s . I nasti OUKISal uUmOO Burn in approved in c in e r a to r in accordance w ith lo ca l i and s t a t e r e g u l a t i o n s . I1 SECTION V I I I SPECIAL PROTECTION INFORMATION B tS*l*AjO* ^OTtCTIOT (Sptci/y iyptf _______b u r e a u o f M in es *>c ' " 7 d ' r ; " ~7 n ' \ - - - -r - m VI NriLATION local hhauji Yes - f o r v a p o r s SHCIal v a" p o r s . M UICHANICAL OTm| n I NAOTicTivi Clovis rubber g OTMIN OTICTIVI iOUINUINT I Tl fAOTICTION c h e m i c a l g o g g le s M V . SECTION IX SPECIAL 0*"*LCAVJfJCNJ IO tJ. T*l| NIN MANQllhC ANO SfO*`NG fl A v o l a s k i n c o n t a c t and eve c o n t a c t . Avoid in h a la tio n of vapors. jOlM|A amcauhonj PRECAUTIONS 1 1------------------ -- . T Wh i l e t he i n f o r m a t i o n and r ecommendat i ons s e t f o r t h h e r e i n ar e b e l i e v e . t o be a c c u r a t e as o f t he d a t e h e r e o f , MONSANTO COMPANY MAKES NO WARRAM WI TH RESPECT THERETO AND DI SCLAI MS ALL L I A B I L I T Y FROM RELI ANCE THEREON J A G :H O H :J T G :WBP " ADM 0 0 2 1 3 0 1/25/72 8 c o r p A pp r o v e d OHB i,o. 4 4 - R U 8 7 Approvil Expires: Q Ju ly 30, 1972 u.i. OP/iiiiQiiirri<: L A S G R FT.T. N o . Hay, 197 MAiTP'tfi cr-trm p m Qf'P iT i i l l i I L U i I i u <jit; 1.1 t , [;*i l i-i U w L L S f, SECTION 1 1 AlMl ((A;m(t ULINnQHl MO. L?i/*ONi\'SANTO-COMPANY*4fiy C*i*. aO Noria Linceercn i3ouicvard* St. Louie, 'Misouri- Y?lM 63166 fnO/l _in n o a-CH{1. <M( Am tlSOntUl 1 1tAlOl MAWCAaOIlNONtu| Mixture 1 A r c e l o r 1?^ "h' r i n a t e t i a r o m a t i c T" f i x t u r e AIMli.f *J Jt # 'Minis SECTION U HiTA-rnOtiS yrana * SOLVI KM * I Ttv ALLOTS AUD uI T A LL I O COlTlMCJ IXSI u(TAL I( ; iai'ST vtHicii UtVlMl *:onivii II AUOtS UtTAVUC COATINGS f u l( a iu ti ai. H u l C;Oa Ti G O C O * f U U f OTHttS 'MI o MAZAIOOUS Hl XTUt CS Of O T * t LIQUIDS, SOLIDS. 0 8 G I U S AOH 0 0 2i-5v5-_ i^ tis c fO'Nf r.i rm oaBta3PiSEMC__*T_B__t_<O_ mNtiwmimaw 7 6 0 no 3 6 MOOc| P H YI S I CAL DATA ,nviaiauMA t " v"* m! ? ' - E P S / P V ' irL ------ 1Q0-??0C W O 0 ( * * S l l (AIA * 1 1 f^ttO lU H ll ll IN n c r l i r l M o | N | A , t i , ( | A.O O OO M w n w a a a u w u o a B ti 3 rrn <0.01 IVI l a r m i v o t A i i i t t * i r aiion K i t . -" arnrr.iT-t: 1c oi t nr . iw r.r.1Ia--wJ-i /n*' c':,,m'-' SECTION IV F I R E ANO EXPLOSI ON II AZAPO DATA ' . a| h PO'M tNt None rc7*=yrarjtrrv3.Nz z n H 4 M 4 A H I WlUlIt C 1 (IIISCwilt^'NGWlOlA 1.1*10*1. 1'<>1.1,0 'iOCl3y.nl I ir Q p.'.esoiraccrv oro* c e t i on vhor J - o v a p o r s or. c a s e s i s p o s s i b l e . r 1r*-------v--*-<-*-*:-- r--*v1^ ^ ?yr. i ! V*V i r. ^ 5.- ` h 1o r 1dc s and ehlo-r|lnc) can be e v o lv e d In1 fires r th is product. 0 o m r./r.u o f a i r m i r t i O v i ( i M " v i | _ ; S 'rCin I r r i t t , n In t h e Torn o f c h l c r a c n e , s y s t e m a t i c i n t o x l c a t i c J l e a o t t o nauscT"| v o . i i i i n ^ , I o t a o f v.e 1 n s , cue.:.a a na a t c i o m i n a i ; ^tul*Ct*C liWil aio rOCCO**(S ( Henove from e x p o s u r e . Remove c o n t a m i n a t o r i c l n t M r r co n tacted area v/lth la r^ c amounts of v/ater-anc soap. v,v-tc^ Refer to phy si c l a n . p o t s . c= - 2 lcg: SECTION Y I P E A C H Y ITY DATA 1 1 Z 3 i *- : ur>aid W W AVwU S IA IU X I Ma ; A A O O u i 0 ( C C w r o i i T lOH O O u C M MA7 AD OU % * O L U | * ' 7 A l lO *i u a t o c Cum h i wot o ccu C O H O i 1 i O * i TO V O I D X --- r i trf L _ _ SECTION Y II SPILL OP. LEAK. PROCEDURES 'i ' 1 l Ii >I 'tS Ca. xI =r ar:rTJj*- e,. . / x,r. rI *r *rcU _k*c = rc r - m= 3 3 c c r ______a f * :~ g a n a g g n a a e B ie .-- Absorb on clav , sawdust or o c r e r absorb ant r a t i n a i . Place In drums. Bury In asp rovec cremi c a l l a n d f i l l in accordance with O I lo c a l and s t a t e re g u la tio n s . C Ail f e i r nw \ n a n a o o r o v e d i n c i n e r a t o r i n a c c o r d a n c e w i t h l o c a l and s t a t e r e g u l a t i o n s . 3=0 SECT OH VIII SPECIAL PROTECT IOif INFORMATION r^ ij i/ K n o i OUC fIwH E u r e a u o f V. I n n s r . p n r o v e d rc,:, n *. r a t n r I'm* o r m o n i vi m u a i io LOCAL(IAAUI Yes -- f o r v a p o r s vmcal vapoj'j 01HIA Oil C'Ivi i.iOwli n u b b er niiiu foiiciivi lOui^tNt I| rAui | c1m>** elicmi c a l I'.orr.ifs u o a c tA ^ x c jiu rL c a x n c a c & ix fn D k l SECTION IX SPECIAL PRECAUTIONS rccrrrrc-ic jI_* *_l_C_A UA' IvUo' . lS a *s rJ'.. i/ r, anoo j eve A coSn .tact, avoid inr.alalien of vanors 0 |A #(C A uliO N l ACM 0 0 2 1 5 6 . While the information and recommendations set forth herein arc belicy to be accurate as of the date hereof, MONSANTO COMPANY MAKES NO WARRA. WITH RESPECT THEPETO AND DISCLAIMS ALL LIABILITY FROM RELIANCE THEREO J A G : HOH: J T C : WDP . . 1/25/72 10 Form p r o v e d OHt Ho. 4 - R 1 3 8 7 pprovi E xpires: U.S. BEPSEIUEilT U B O July 30, 1972 HATEHAL SAFETY BATA SHEET 1i K 'j j cai i gg, . au>LEWt i t to ts rt-._ - 1.g.-r?n r?Try7a g r.-i'c-r- 41. `" f ;M:OC1N1 S.AN.rNq.iT,OlimCi,OCiM( f.PIAi*Na.YA4 IP Ci i 0 N orm L inooeran B oulevard, - . ' 4 , Sai( I S I ' . O . IUI M i x t u r e ^ ________ " vfhirina ted aromatic SECTION I iMiatiNCt TClI^monc no. St.. L o u is, fo . /f l, l , M,t cQ-inoo M is s o u r i 63166 T.NiOc N4U( AnOIVnOntm, g p r o c l o r lg?H fix tu re 3 .SiCTI ON II Jj.lZA.';P0IIS IHGrc.D*r,l,T5 ri;r*v*'iv*ti, * lOLvtim MISI <1 IUt-l.vnl ALLOT! AMD METALLICOOaTIHCi i ASI MITAI. C414Lrr vi--ICLi SOl VIM' S *?3it'viS 1i ALLOTS ! ITalUC COATlMC TlUUltiCOVAITIAiLNC 0 C0*1 1lUt o?M|ik i'- m i MAZaIOOUI mIITUICS OC 0Tk(* UQUIOI. VQUDl. 01 CUCI %( \ SECTION III PHYSICAL DATA 1 .O...SC .O ... fi., 7 g 0 mm 3i 5 -i 0 0 c s*tc<*e c * 4 v l , r , M i 0 " , ^ 5 ^ / 2 5 0 C ) 1 ------------------------------------ . . . i 8 o _ 2 2 0 C 1 V4 * 0 OIMSITt i aia - i i 1 m.n t *CI v i VOLATILI ' 1 VIUVI 1*1 | V 4 Q 4 a TiON AAT| i BuA- ;n I SOLVULIT I K A i U I _ . ,, , [ 0*0 n e n lifrib le < 0 .0 X 1 4**f44Nci *no ooo Y ellow v isc o u s o i l a r o Tmrfl.TaftTiTcJCoWdLolCrMluma SECTION IV FIRE AND EXPLOSION HAZARD DATA 9 I.A S m A Q .M IU I*M . il Ii tINU`1">**GMIQtA Nov i ' n--e .IMC'Al n:liic IOCIOLIIS 'eso ira tory protection when f*rhtlnp -o vaporo or pasea is p ossib le. llA U M A Ill limits riT- v)h pi*n rrp-- *?]?< T^^lir^.i^^^^hloridez 1res of th is p ro d u ct. K U W f v> m rm and chlorine) can be evolved in 11 ADH 0021^7  Arcelor 125^ SECTION' V HEALTH HA' '0 OATA .^*1 V*.-; o.5'~?/-J of air i fi Skin Irritation In the form of cr.lcracr.e , systematic intoxi,cari` leads to nausea, vomiting, loss of weignt, ece.r.a"ar.c ato or.ir.a"/ LifciCt*<C **0 *'0 MOCtOvMi p Remove from exposure. Remove contaminated clothlnr. W arh ' f | ' contacted area with large amounts-of water and soap. Refer to 4'X physician. .tIn.1* ofc.tr* II SECTION VI REACTIVITY DATA w w ,' v w '. . v -fcv 0 * tJ ' TIIK ifcCOunililail la.J H*ifc*0Oui OtCOU'OSTiON MQOUCTS m a t 0CCu* wm. .or occun COHOiliOWS TO avoid . X ( ___________________________________________ SECTION V I I SPILL OR LEAK PROCEDURES > I 'i A b rl s 1^* i orb . f c o C n * .cl lmav, > * u l x O C* ! * > . . ( w sawdust or o t h e r ahsorbant material. Place In drums. Bury In approved chemical lancfill In accordance with local and 3tate regulations. 5;fcS'ub:u*rn->*%ipw.t-aono approved. ,inci, nerat_or I. n accord, ance wi. t. .h -local, and state regulations. J SECTION VIII SPECIAL PROTECTION INFORMATION OftCTCs I.'ptrtn ""'Bureau of Klr.es approved respirator for organic VNilULTlON lOCAi liMAusr Yes -- for vapors vapors .']J UlCMAfclCfcl OTHI i1*OT(CMvl C.OVii Rubber 1CI*(*fcOflCUvt IQw**fc*|N j IM **OTfCTIOH Chemical goggles 1II 1--- - SECTION IX SPECIAL PRECAUTIONS J'*tC*v,-V'old' sk^n* `a n y ^ v e ^ c V n V a c t , avoid uwjnu< inhalation of varors While the information and recornendations set forth herein are believed to be accurate as of the date hereof. MONSANTO COMPANY MAKES NO WARRANTY WITH RESPECT THERETO ANO DISCLAIMS ALL LIABILITY FROM Rr' TANCE THEREON. J AG: HQH: J T G : VS P - 12 1 / 2 5 / 7 2 Form Approved OHE No. 44-P.1387 Approval Expires: July 30, 1972 U.S. ( EP.EICEWt . ISCSI Form No'. '0 Hay, 197-J# MATERIAL SAFETY BATA SliEEI: SECTON I I **MW**Ci ** (KINBImCT Tfkl^*OM( MO. M O N SA N T O COM TA NY M lM So-inno * o r * i *i c tir. m n r c . 800 North Lindbergh B oulevard, St. L o u n , M i s s o u r i 631po M * AMO * N O M * M l THAUC MAUt AMO ATMOMTU .M ixture. Arn f l o r ??. c"ccK ori na tod Aromatic ^OAktUkA Mixturel faemii, AtCUiMfS Ca i AivfT V1MICU tOLvIHTS AOO'flVlt O*"Ml SECTION II IIA7;V1'.0miS ii n i -- n i i irm i n i r i i n i li r i i S t f i i . iolimm tu <U*utl ALLOY! AMD WfTALL1C CO TIKC u u u(ru ALLOTS MtTAUlC c o m i c i VnIuLLtIclomatnalic e* c o t nu OTKIAS MAlAtOOUl IZTUIC1 OF OTXCK LtQUlOl, SOLIO!, OR C i U ) ,TLi (U*m r^^J -X *i SECTIH III PHYSICAL DATA oivac o**! r.i 760 mm 3^ 5-360C MCCU.CtAA*M_.-J0--.^ ^ / y (. 0^ ':" ' T-.R-flo' V*OA'MSRI i--*".( 155-195C ) 3 mm *iKVOiilLrfMvoul ri tiLr . '. " ; N'A V**0* OEMifl lAKlIt J | >t A v a il - fi^VB'uOAAcM-O---*---5A1T1I SOlurAtLir*m AVI A0, . .C- n e g l i g i b l_e <0-Qlt ' ,. :1 f ( i- ' < `. h p .; f H U i i ie i aio oooi colorless oil slight aromatic odor! SECTION IV FIRE AHD EXPLOSION HAZARD'DATA C.O.C.U * |M F O l h l l >M MM . M l 180C f L A M A A A L L lA ll I Ll I ITItCUI |MfM U|0<A Vater, foam, COg or dry chomlcal Mt Cl AL l t a | fl&MtlMC M CI OUA t . R e s p i r a t o r y p r o t e c t i o n . whn f f Fh M n g f i r e s jw h e ,re _ e x p o s u re -_to vapors or gases is possible; ual >i 'A' ^HVefiy* {oVrcQraVos*^chlorides and chlorine) can be evolved In fires of this product. 13 AON 0 0 2 v 5 ^3 /rocior 1242 SECTION V HEALTH HAZ D DATA '-""`"" """v*''** i.Q m ,r/m j of air. !n 'Trw UflCSJk^Oi*nOwlilrlrtAiUtV1a1*tion in the form of chloracne, systematic intox cation leads to nausea, vomiting, |Ulr.l>CT AMO M*SI Aio f*OCIOU4l loss of weight, edema and < abdonmailnna.l Remove from exposure. Remove contaminated clothing. Wash contacted area with large amounts of water and soap. Refer to physician. 1 ____ . '________ UNSIAttf SECTION VI REACTIVITY DATA 1__ _____________ stash iMCOw^ATAiLItv t*4t0r**ta im J" haJaJOOu SOfCOMPOSITION NIOOUCTI _________ _ _CQ. COp . smoke soot, chlorides and PMOALJTAHAfOilOfUASIION mat oceu W*U NOT OCCU CONDITIONSTO AVOID * X chlorine________!__ 1* SECTION VII SPILL OR LEAK PROCEDURES |l|l U II (Al* iMCAVI MATtAIAl I&UlUO O* ^llUU Ab s o r b n n . c l a v t s a w d u s t n r o t h e r a h a a r h a n t - P l a c e. I n , d r u m ------- and bury in approved chemical landfill in accordance with, local and state regulations AIM Jt>>0<urn 'fn an approved incinerator In accordance with local and state laws. mti SECTION VIII SPECIAL PROTECTION INFORMATION |*fIAiaaIO* OTICIIONSntitr VINTlUlTiON LOCAI ((MAUSI Yea for vapors wiCmaniCaa /Ci m n U P*OTfCTIvf ClOVll Rubber OtM(A OtfCTlVf tauiNifNT . i*i paouction SPICIal OIK* 1 Chemical goggles 1 I SECTION IX SPECIAL PRECAUTIONS ********* ------ A Y Q ld akin .and eve contact_ avoid Inhalat Ion,of _y_a_po_r_3_,_ OlMta AaiCAutiO AO M * 002 15** While the Information and recommendations set forth herein are believed to be accurate as of the date hereof, MONSANTO COMPANY HAKES NO WARRANTY* WITH RESPECT THERETO AND OJSCLAIHS ALL LIA8ILITY FROM RELIANCE THEREON. JA G :H O H :JT G :V B P 1 /2 4 /7 2 14 TABLE 2 COMPOSITION OF COMMONLY USED | GENERAL ELECTRIC FYRANOL TRANSFORMER DIELECTRIC FLUIDS* FYRANOL' SPEC. NO. 1467 1470 1488 1497 o r A13B3B A13B3B2 A13B3B3 50P524 A50F559 50F570 COMPOSITION 6CK PCS ( A r o c l o r 1260) 4 OX t r l c h l o r o b e n z e n e 0.1252 t i n tetrap h en y l | 451 PCS ( A r o c l o r 1 2 6 0 ) 4GX t r i c h l o r o b e n z e n e 15X t e t r a c h l o r o b e n z e n e 0.1251 t i n tetrap h en y l 1 ! 6CX PCB ( A r o c l o r 1 2 6 0 ) ! 402 trlc h lo r o b e n z e n e \ 452 PCB ( A r o c l o r 1 2 6 0 ) 4CS t r i c h l o r o b e n z e n e 15X t e t r a c h l o r o b e n z e n e 0.125X dlepoxlde 45X PCB ( A r o c l o r 1 2 5 4 ) ; 40X t r i c h l o r o b e n z e h e y 15X t e t r a c h l o r o b e n z e n e 0.125X dlepoxlde - 60X PCB ( A r o c l o r 1254)-' . 4QX t r i c h l o r o b e n z e n e ^ 0.1252 dlepoxlde | BOX PCB ( A r o c l o r 1242),:. j . ' 13X t r l c h l o r o b e n z e n e ' ' ' 7X t e t r a c h l o r o b e n z e n e \ 0.125X dlepoxlde 65X PCB ( A r o c l o r 1 2 5 4 ) 23X t r i c h l o r o b e n z e n e 12X t e t r a c h l o r o b e n z e n e 0.125X dlepoxlde 4 GS PCB ( A r o c l o r 12 5 4 ) 6QX t r l c h l o r o b e n z e n e 0.125X dlepoxlde 1 f 4H0TE: The uae of Pyranol vaa d isco n tin u ed In 1977. 6 200638 t C PCB - AROCLOR-PYRANOL COMPOSITIONS 0012S G.E. CAPACITOR. MONSANTO i- PYRANOL PERCENT CHEMICAL AROCLOR G E - M A T 'L GE-MAT'L D E S I G N 'N C O M P 'N A B B R E V 'N D E S I G N 'N SPEC. NO. CODE - 4 1499 100 PCB 1242/1016 ! A15E1C 1 AAWH ( 1492 ' 67 PCB 1260 i 1 A13B1E 7?? 33 ------ 5460 7 7 7 ??? 1481 t A13B29 AAWN 75 PCB 1254 A13B1 AAWF 25 TCB -- D 5 B 7 6 ,0R D50PC36 DAFA/DAFC c 1478 100 TCB D5B76 OR D50PC36 DAFA/DAFC 1476 100 PCB 1254 A13B1 AAWF . V 1436 - 75 PCB 1254 A13B2A A13B1 AAWM AAWF 25 TCB "11 D5B76 OR D50PC36 DAFA/DAFC 1 BCA -- D5J16 DAHA PC43 OR DC OIL 1 A50PC43 ACAV \ 75 PCB 1242/1016 A13B1C AAWH 25 PCB 1221 A50PC42. ACAU 1 BCA -- D5J16 DAHA c 200634 i 16 c c PCB - AROCLOR-PYRANOL COMPOSITIONS G. E> CAPACITOR PYRANOL D E S I G N 'N PERCENT C O M P 'N CHEMICAL A B B R E V 'N MONSANTO AROCLOR D E S I G N 'N ! ! * G E - M A T 'L SPEC. NO. i i G E - M A T 'L 'C O D E P-II OR P Y R A N O L II : P-II OR P Y R A N O L II ( 100 0.35 99 0.7 PCB 4206 1242/1016 -- PCB 4221 1242/1016 A50PCSA A13B1C D5D71A A50PCSA A13B1C D5D70A -A D A A AAWH DAGS ADAA AAWH DAGW P-II OR P Y R A N O L II (V 99 1.0 A30PCSD PCB 1242/1016 A13B1C 330 D50PC26(A) ADAD AAWH ,D B S L P-I OR PYRANOL I i 100 PCB 1242/1016 , A13B1C (AAWH MONSANTO AROCLOR 1254 - PENTACHLOROBIPHENYL MIXTURE . 1 MONSANTO AROGLOR 1242 - TRICHLOROBIPHENYL MIXTURE MONSANTO AROCLOR 1016 - TRICHLOROBIPHENYL MIXTURE REDISTILLED TO REDUCE PENTA- AND HIGHER CHLOROBIPHENYLS MONSANTO AROCLOR 1221 - MAINLY MONOCHLOROBIPHENYL MIXTURE MONSANTO AROCLOR 5460 - CHLORINATED TERPHENYL MIXTURE TCB - TRICHLOROBENZENE BCA -- BETA-CHLOROANTHRAQUINONE c UNION CARBIDE 4206 EPOXIDE - 4--VINYLCYCLOHEXENE DIEPOXIDE i i ! 1 UNION CARBIDE 4221 EPOXIDE - 3,4-EFOXYCYCLOHEXYLMETHYL- 3, 4 - E F O X Y C Y C L Q H E X A N E CARBOXYLATE OR DICYCLO--DIEPOXY CARBOXYLATE D O W 'S D E R 3 3 0 - D I G L Y C I D Y L ETHER O F B I S F H E N O L -- A 200635 17 16 TADLE 2 - 2 . A v a i l a b l e D a t a o n U s a g e o f P C B - B a s e d D i e l e c t r i c F l u i d s i n , Hudson F a l l s (HF) a n d F t . E d w ard (FE) P l a n t s a n d T e m p e r a tu r e s o f E x p o s u re to P la n t E nvironm ent. * Year P lan t P y ran o l G rade % of P roduction C o m p o sitio n (se e Xey) 4 1946 FE 1476 95 100% 1254 1436 4 75% 1 2 5 4 , 25% TCB, 1% BCA 1481 1 75% 1 2 5 4 , 25% TCB 1950 ' fe 1499 80 100% 1 242 1 1 4 7 6 15 100% 1254 .1 t 1952 HF 1436 1481 1476 4 1 95 75% 1 2 5 4 , 75% 1 2 5 4 , 100% 1254 25% 25% TCB, TCB 1% BCjii A 1436 4 75% 1 2 5 4 , 25% TCB, 1% BCA 1481 1 75% 1 2 5 4 , 25% TCB 1953 HF 1499 ^25 100% 1 242 1476 V70 100% 1 2 5 4 L 1436 4 75% 1 2 5 4 , e t c . i 14 81 1 75% 1 2 5 4 , e t c . 1955 HF ,FE 1499 95 100% 1 242 1436 5 75% 1 2 5 4 , e t c . r 1956-59 - U n co n firm ed r e p o r t o f s w itc h b ack to 1254 > 1 ' ir 1964 HF ,F E P II 99 100% 1 2 4 2 , 0.35% 4206 1965 HF ,FE 1436 P II 1 75% 1 2 5 4 , e t c . 99 99% 1 2 4 2 , 0 .7 % 4 2 2 1 . 1436 1 75% 1 2 5 4 , e t c . 1971 h f,fe P II 99 99% 1 0 1 6 1 4 3.6 1 75% 1 2 5 4 , e t c . 1975 - R e p o r t o f r i n t r o d u c t i o n o f 0.7% 4221 i 1976 - D i s p l a c e m e n t o f 1 0 1 6 b y DEHP c o m m e n c e d V. 1 - 1977 'i w * - ' .> *-=H'* F j "F E' a i - J u n e 3T - P II *X I ^ lF C T 'u s a g e 25% .. . 99% 'S S V & fttrfttifedF"*'"1 1016, 0.7% 4221 T e m p e ra tu re s a t W hich W et U n its E xposed to A ir A ro clo r A ro clo r " 1 2 5 4 -b ased f l u i d s , FE, 90-95*C HF, 45-60*C 1242 o r 1016 f l u i d s , FE, 65-70*C " " * H F, 4 5 - 6 0 *C 1 '1i f Xey: 1254, M onsanto A ro c lo r 1254, p e n ta c h lo ro b ip h e n y l m ix tu re . 1242, M o n san to A r o c lo r 124 2 , t r i e h l o r o b i p h e n y l m ix t u r e . 1016., M onsanto i A ro c lo r 1016, tr ie h lo r o b ip h e n y l m ix tu re r e d i s t i l l e d to rem ove p e n ta - ! a n d h i g h e r c h l o r o b i p h e n y I s . TCB, t r i c h l o r o b e n z e n e m i x t u r e . BCA, ! b e ta c h lo r o a n th r a q u in o n e . 4206, U nion C a rb id e ep o x id e 4206, 4 - v in y l- c y c lo h e x e n e d ie p o x id e . 4221, Union C a rb id e ep o x id e 4221, 3 ,4 -ep o x y -6 -m eth y lcy clo h ex y lm eth y l 3,4-epoxy-6-m ethylcyclohexane c a r b o x y l a t e . DEHP, d i ( 2 - e th y lh e x y l) p h t h a l a t e . Data courtesy of Earl Dunham, GE Capacitor Products Dept. rOy 003C 13 i c INSTRUCTIONS GEH-1093B i * i C PYRANOL TRANSFORMERS AND PYRANOL IMMERSED CURRENT-LIMITING REACTORS I I "i- -* i rrfi * * V-Tt , ":1. 7 c c h o (no TRANSFORMER &ALUED PRODUCT DIVISIONS GENERAL^ ELECTRIC PITTSFIELD, MASS. i CEH-IO]A Lun m .I' '* 00 .19 1 CONTENTS INTRODUCTION......................... Type M-13 Indicator...................... 15 Pyrano Immersed Current-limiting Type A-10 Indicator...................... 15 Reactors............................................ 3 RECEIVING.................................................. 3 PRESSURE-RELIEF DIAPHRAGMS____ 15 Eight-inch Pressure Relief................ 16 ( HANDLING................................................... 3 Receiving............................. 16 STORAGE..................................................... 3 Description. ................... ..............'. 16 INSTALLATION.......................................... 3 Installation. . ................................. 17 Inspection.............................................. 3 Renewal of Diaphrag m*. . . . . f. 17 Foundation 4 Pressure-relief Alarm. . . . . . . . . IS Connections......................................... 4 Ten-inch Pressure Relief.............. IS Pressure T e s t .................. ................. 3 ' Receiving........... '........................... IS Cooling Coils on Vater-cooled Description........................ . * . . IS Transformers. 3 Installation. 19 GASKETS...................................................... 3 Nitrile-rubber Gaskets. ................. 5 VENT PIPES AND GAS ABSORBERS.. . 19 Vent Pipes........................................... 19 ( Storage. ............................................ 3 Gas Absorbers..................... 20 Application of Gasket . 3 Application.......................................... 20 Preparation of Scarfed Joints . 6 SAMPLING VALVE. . . ...........................L j21 Composition-cork Gaskets.................. 6 TAP CHANGERS FOR DE-ENERGIZED * Application of Gasket..................... 6 OPERATION............................................. 22 Preparation of Scarfed Joints. . 7 Drum Type. . ....................................... 22 PIPE FITTINGS.................................... MAINTENANCE........................................... Handling Pyranol................................ .Filling Transformers............................ Periodic Inspection............................. Vater-cooled Transformers................. 7 7 7 8 8 8 Plunger Type. ...........................'* Crab T y p e ................................ Vedge Type............... ^ Folding-handle Operating Mech anism......................................... Cap-type Operating Mechanism.. 22 23 24 2 23 Operation without Cooling Medium. . 9 Sampling and Testing Pyranol........... 9 Operation of Vedge-type Tap Changers from Floor Level. 25 Sampling from Transformers . 9 Installation of Floor-level Drive 25 Sampling from Drums....................... Testing for Dielectric Strength.. PYRANOL TESTING SERVICE............... DRYING AND FILTERING PYRANOL. . Drying the P a p e r . ................................ tyj rtg -FUlJcxlA^lith. &s . Charging the Filter.............................. Operation.............. ................ ............... Cleaning the F i l t e r . ........................... Pump....................................................... Motor....................................................... Strainer............ ...................................... Electric Drying Oven . . . . . . . . . . DRYING PYRANOL TRANSFORMERS. . SPAKE TRANSFORMERS......................... LOCAL CONDITIONS AFFECTING THE OPERATION AND LIFE OF TRANSFORMERS............................ 9 10 10 10 11 11 Tr 12 12 12 13 13 13 13 13 13 Test of Tap Changers........................ 25 BUSHINGS................... ............................. 25 Installation............................................. 25 Line Connections. .................................. 25 Connectors........................................... 26 $HIL^TYJ>E, CURRENT. TRAN 5- . FORMERS................................ . 2" Installation..................................... . 26 Connections and Polarity. . . . . . . . 26 PYRANOL IMMERSED, AIR-PRESSURE- COOLED TRANSFORMERS............J FORCED PYRANOL COOLED TRANS FORMERS. IF TRANSFORMER DOES NOT OP ERATE.................................................. Transformers Immersed in No. 1488 Pyranol............................................. 27 27 28 28 C Impure A i r . .................................... .. 13 Transformers Immersed in No. 1467 Altitude.................................................. 14 Pyranol................... 1 ....................... 28 c Transformer Housing...................... 14 General Procedure (with' either No. LIQUID-TEMPERATURE INDICATOR, 1467 or No. 1488 Pyranol)............ 28 TYPES P-2, M-13, A-10....................... 14 JUNCTION BOXES.................................... 28 Description. ......................................... 14 TRUCKS...................................................... 29 General............................................. 14 LOAD-RATIO CONTROL. ........... .*. . . 29 Type P-2 Indicator......................... 15 REN E W A L PARTS...................................... 29 / Vj T t). dm ^ * M W W f dmtmtlm M f L I w . i . * * -- pmmmdt f a r i w . -- m U a n a l l i t i a i | tm h * * 1 l a a a ^ i a a -- ` -- i mrnu mmmmt. / W W ! / . . . > la mmtmt\dd mm a ^ ^ r f w .t.a Ja a ^mammmmm a>iM wfca.A mmt aw tt mtmd a . / a . I . w l . / a * w m u . lm t d m ^ d l a i ^ n W M # Cmimi mi Cimatmtm 00' 20 PYRANOL TRANSFORMERS AND PYRANOL IMMERSED CURRENT-LIMITING REACTORS INTRODUCTION Pyranol* s a cooling and insulating liquid which is ooninflammable, chemically stable, and nonsludging. Pyranol supplied for use in transformers is straw-yellow in color and has a Saybolc viscostry of about 54 seconds at 37.8 C (100 F). Mineral oil is completely miscible in trans former Pyranol and affects its noninflammable characteristics. Since it is practically impossible to separate the two liquids after they have been mixed, it is important that contamination with any petroleum oils be avoided. H erials which are not soluble in Pyranol have been selected for use in constructing Pyranol transformers. No materials should be used in contact with transformer Pyranol except those approved by the General Elec tric Company. PYRANOL IMMERSED A Pyranol immersed current-limiting reac tor differs from a Pyranol immersed trans former in that it usually has no core, gener ally consisting of one winding immersed in Pyranol in a standard transformer tank. The following instructions, given for transfor mers, apply to these reactors. R E C E IV IN G Pyranol transformers are pressure-tight, and are normally shipped completely assem bled in their tanks, ready to be installed. Upon receipt of the transformer, examine the equipment for any damage that might have been sustained in transit. If injury or rough handling is evident, a damage claim should be filed immediately with the transportation company, and the nearest General Electric Apparatus Sales Office should be notified promptly. ____ RtgLsiervfJ for G-E aakarcl H A N D L IN G Lugs or eye nuts are provided for lifting the complete transformer and, when neces sary, additional lugs and eye nuts are sup plied for lifting the various parts. Then lift ing the complete transformer, use proper spreaders to obtain a vertical lift. Securely fasten the cover of the transformer in place to prevent buckling of the tank wall. Vhea necessary, transformers are provided with means of lifting with jacks, either by means of special jack bosses welded to rhe transformer tank, or by an extension of the base of the transformer. In no case should the transformer be moved or lifted by placing a jack or cackle under the drain valves, radi- acor connections, or other attachments. STORAGE Before storing a transformer, check it to see that the Pyranol is at the proper level. Renewal coils and insulation should also be ,, zderJ5w &I5.5 ** _ be sealed from the air. The storage room . should be clean and dry, and, hen possible, free of extreme temperature changes* Before a transformer is placed in service from storage, make sure ebar the Pyranol and interior of the transformer are dry. IN S T A L L A T IO N INSPECTION Prior to installation, carefully inspect the external parts of the transformer for damage which might have been sustained in transit. Tighten any parts that may have become loose, such as nuts and leads. Inspect the lead seals which are used to seal the valves at the base of the tank. They should be un broken when the transformer is received. Pyranol used for filling transformers should have dielectric strength of 30 kv or hirher. t r o r - r u r "3,ic^eciric,'strengrn Tt Pyranol in transformers in service reaches 25 kv or 0 0 ( 21 G cH -tO Q 3 B Pyrtnai Transformers and Pyrenoi Immersed CurrenlJimUing R etc tors lower, filter c la accordance with the sec tion on DRYING AND FILTERING PYRANOL. If the dielectric strength is low, or if there is other evidence of free water, dry the core and coils in accordance with instructions on DRYING PYRANOL TRANSFORMERS. Under certain temperature conditions the Pyranol aay condense into drops oq the underside of the pressure-relief diaphragm. These drops should not be mistaken for free water* Methods of sampling and testing Pyranol are covered in the section entitled SAMP LING AND TESTING PYRANOL. If the transformer is to operate at a high altitude (3000 feet or more above sea level), open a fitting above the liquid level, either the top sampling valve on the side of the tank or the filling plug in the cover, to equal ize the inrernal and external pressures at approximarely 23 G before the transforma is placed in operationJ If this is not practic able, the transformer should be vented and resealed a ta pressure according to the Table under PRESSURE TEST. If a transformer must be opened for inspec tion outdoors, on a damp or stormy day, take proper precautions to prevent the entrance of moisture. FOUNDATION --tv.Th e^o^y^fA^adicio li vnjrcgssary_for che installacion of a Pyranol transformer Ts a lev e l' floor strong enough to support the weight. If the transformer is. equipped with a dia phragm mounted in the side of the tank, place the transformer so chat the diaphragm is not facing an aisle or passageway. CONNECTIONS Donot change connections on a transformer that is under excitation, or make any connec tions except those authorized by the diagram or nameplate accompanying the transformer. Tap leads on some transformers are con nected to a tap changer, the handle of which may extend through the cover of the trans former or through the side of the tank--or it may be under the cover. Then the tap-changer handle is brought out through the main cover or the side of the tank, the exposed mech anism is proteCte^-by" a cover. If this cover is removed to operate the tap changer, it must be reptac ed to avoid the entrance of moisture. 4 Leads not in use must be insulated from ground and from all other leads. Regardless of the floor or foundation on which the transformer is placed, ground the tank permanently and effectively by connect ing to the grounding lug at'the bottom of the tank. A good, permanent, low-resistance ground -is essential for adequate protection. A poor ground may be worse chan no ground at all, since it gives a false feeling of safety to those working around the equipment, and may result in loss of life or damage to the apparatus. Then a transformer or autotransformer is specially designed for use on a system hav ing a solidly grounded neutral, be sure that the neutral lead, as indicated on the nameplace, is permanently and solidly grounded without resistance. In transformers specially designed for this service, the neutral lead is usually brought out through a bushing of a lower voltage rating than the line bushings. If the neutral is not solidly grounded^ suffi cient voltage, may appear from neutral to ground to cause arc-over of the neutral bush ing. A transformer or an autotransformer is oc casionally grounded through a low impedance or a tuned impedance of a higher value. In auch instances, the neutral bushing is of sufficient insulation strength to meet the conditions. Special Instructions acc oriipan/ 'unuir*ie'sTghed ' f o r c h-'xppii ti0R 5. A single-phase transformer suitable for Y operation-on either the high-or the low-volt age side may be so connected on either side, but not simultaneously on both sides unless precautions are taken to suppress third-har monic voltages. Two transformers of. identical voltage rac ing may be operated in multiple safely hen they have the same polarity, ratio,phase rota tion, and angular displacement, and approxi- ; mately the same percent impedance. Then desiring to operate, in multi pi e, tran s- formers that are not of identical design, com municate with rhe nearest Apparatus Sales Office of the General Electric Company for information. Be sure to state the serial num bers of the transformers that are to be operat ed in multiple. _, Every transformer shou'd be protected from lightning disturbances by some form o' 0 0 ( 22 P y n n o l T n n th rm tn i nd P ynrtot /mmerstd Currmni-ttmiti/tg R ttc io n G E H - I0 Q 3 B stroke protection. An approved lightning ar rester installed as near as possible to the transformer to be protected, is recommended. Provide the arrester with an efficient ground. Vhenever disconnecting switches, with or without arcing horns, arc mounted on top of structures, erect grounded protective masts to give a-45 degree-angle shield over the cop of the horns or open switch. A protecting screen is even siore efficient than masts only. PRESSURE TEST Pleasure test all Pyranol transformers be fore placing them in service. Subject the tanks to an internal pressure of five pounds per square inch when the installation is com pleted, using dry compressed air or dry nit rogen introduced through the filling hole in the cover. Then this pressure has beien at tained, shut off the supply and alio! the transformer to stand for 12 hours. Observe the pressure reading during this period, and examine the tank and fittings for leaks. If the pressure holds constant, the joints are satisfactory. Leaks above the Pyranol level may be lo cated by applying a solution of soap and water to all gasketed joints, pipe fittings, and cable connections. .Following the pressure test, and any time that it is necessary to break the transformer -Sjeair ^re*cal ^1SeTjraPiSfojn\e.r,jLC7, tb . pressure, in accordance with Table 1. TABLE 1 Pyranol Temperature Approximate Pressure Degrees C Lb Per 2 25 0.0 30 0.5 35 1.0 40 1.5 Use dry air or nitrogen if the pressure must be increased to an amount greater than at mospheric pressure (zero lb per sq in. gage pressure). If the seal is broken when the Pyranol temperature is lower than 25 C, reseal the Transformer ac atmospheric pressure; then vent the seal to atmospheric pressure when the Pyranol temperature reaches 25 C, to pre vent excessive pressure when the Pyranol temperature exceeds 25 C. COOUNG COILS ON WATER-COOLED TRANSFORMERS Cooling coils are thoroughly dried before shipment, and all traces of moisture are re moved by means of a bot-a(/ blast. Do not remove the caps from the terminals of a coil until ready to install or te'sc the coil. Never circulate water through a coil unless the tank is filled with Pyranol, as moisture might con dense on the coil and later be absorbed by the Pyranol. After the tank is filled with Pyranol, make s final pressure test on the cooling coil ac about 150 lb per sq In. The best method is to.use dry air pressure so that any leaks may be located by observing bubbles in the- Py ranol. If air is not available, fill the coil with Pyranol and apply pressure. After ob taining pressure, disconnect the supply, and after a half hour determine whether any fall in pressure is due to a leak in the coil or in the fittings at the ends of the coil. :t GASKETS The standard material for gaskets used in making liquid-tight joints on transformers and regulators is nitrile* rubber. However, some applications of composition-cork gaske.s re main. These instructions explain the proce dure for making a liquid-eight seal with both nitrile-rubber and enmposicion-cork gaskets. NITRILE-RUBBER GASKETS WiwHfvrub-bS'r req-iirre'-rKr to mike a liquid-tight seal, although adhesive A50P68 may be applied as a chin film in a few places, when required to hold the gas kets on a verrical surface. A small amount of adhesive is required to make scarfed joints in a gasket. The resilience of nitrile rubber makes pos sible the reuse of these gaskets in forming a seal if the gasket has not been damaged. Storage Score spare nitrile-rubber gaskets in a dark room, away from places o f high temperature, such as steam radiators. Application of Gaskat Clean the gasket, and the surfaces to which it is to be applied, of all rust, water, grease, insulating liquid, loose paint, scale, or any *A synthetic rubber compounded toG^E specifications 0 0 ( 23 1 IO Q 3 8 P y n n e l Tram formars and PyranoJ tm m antd CunvnhlimHing Raaciort ocher foreign material except thoroughly dried not distort the shape of the gasket excessive oilproof paint. Denatured alcohol is recom* ly. Joints can be cured immediately, or at Beaded for use in cleaning the surfaces. any time within a week. Place the gasket in the proper location, if To cure the joint, place the gasket in a this is a vertical surface, a chin film of ad heated press or vulcaoizer and.elamp together. hesive A50P68 oay be applied in a few places Apply only enough pressure* to insure a joint to secure it. As grooves or metal-to-metal of uniform contact. Avoid excessive distor stops are used on most gasketed joints, it is tion of the gasket. Cure the joint in the press essential that gaskets of proper width and for 33 minutes at 130 C, or 20 minutes at thickness be used so chat correct bolt spac 130 C. Do not heat over 160 C. Remove the ing and pressure can be maintained. (To be gasket at the end of the curing cycle and dip assured of obtaining gaskets with the correct in cold water until cool. dimensions and quality, order replacements A properly prepared joint is sufficiently from the General Electric Company.) strong to withstand sharp bending, twisting, Tighten the bolts, drawing each down in * and.elongation of 100 percent. There should small increments. Proceed around the bolt be,no gaps at either end of the scarf, and the , circle several times until the.metal stops are adhesion should be uniformly good. reached, or, if no. stops are provided, until the gtskVc is compressed, to 2/3 of the .origi nal thickness. Do not compress the gasket 1 beyond this point. No subsequent tightening of the bolts is necessary,' COMPOSITION-CORK GASKETS Composition-cork gaskets *11 not hold liquid unless treated or coated; that is, the liquid will seep very slowly through the cork aod will flow along the joint. For this- rea Preparation of je a r fid Joints * son, a suitable compound is essential with Place the gasket in the scarfing fixture-and cut to" the proper angle. The correct lengths of scarf for various thicknesses of gasket are given in TABLE 11. _- composition-cork gaskets. (Exceptions: Use no compound or sticker on the small gaskets in a bushing terminal cap, or on gaskets around a movable shaft.) TABLE 2 Application of Gaskot Thickness of Gasket ' - Length of Scarf hes)~--r- The following procedure applies particular ly, to the joint between the cover and tank, ' S u W h o u 1<TI* YsVcTas V gifheraKflinfe ^ tT ^ 3/8 11/2 the formation . of other liquid-seal joints. . . . 1/4 . 1 Clean the metal surfaces of black scale, 3/16: 3/4 oil, grease, water, rust, or any foreign ma Sand the surface until it is perfectly flat, drawing the sanding block toward the thin edge only, Pipe the scarfed area with a clean cloth dampened in acetone, alcohol, de-greaser solvent, or solvacohe. . Leave nothing on the acarf to interfere, with'the bond. Even a small terial other than thoroughly dried oilproof paint, preferably with denatured alcohol. Cut and scarf the gaskets to fit the tank -flange. If the gaskets are to be mounted in a groove, place them in the center ofthe groove. Make sharp corners, such as in junction box es, with angle pieces of cork.. amount of oil, such as might be'left from rub- . Remove the gaskets from the flange and birig with the fingers, will interfere with the thoroughly coat them with G-E compound 880 quality of adhesion. of fairly heavy consistency; then suspend the To the clean, scarfed surface, apply an gaskets in the air to drain until they are per even coat of.A30P68 adhesive, arid allow the fectly dry for handling. Such drying usually surfaces to air-dry until a "tackiness'* de requires less than four hours. (If necessary, velops'tot the.point that the adhesive-will not a small amount of talc may be sprinkled over transfer ro the fingers (usually from 5 to 15 the dried compound as an added precaution minutes). Then bring the scarfed surfaces against sticking when handling.) together and press ^the joint firmly by hand Apply one fairly heavy coat of compound to oocwith enough pressure to displace all air. Do the flange and underside of the cover, and 24 P yn n oJ Transformers and Pyrmnet /mmcfied Currwni-limiling R tte fo rt G H - tO R 2 5 allow to dry. TABLE 3 Before assembly, apply a light coat of com* pound SSO co the tank flange and underside of the gasket. After the compound has .dried sufficiently so that it will not adhere co the fingers (about IS minutes), assemble the gas* kets on the tank flange. Place the gasket between the bolt holes and inner edge of the flange. When full width gaskets are osed, make sure'they are assembled with at least 3/4 in. of gasket width inside the bolt boles. Locate scarfed joints between bolt holes. York each gasket section back and forth a few tines over the compounded metal surface. Make the scarfed joints as explained in a subsequent section. Weight or clamp^the gasket at frequent in* tervals to obtain the best possible adhesion to the metal surface. Use extra pressure at the scarfed joints and at curves. Leave the clamps or weights for at least 30 minutes. After this period, the compound should be quite "gummy" but not hard. If full-width gaskets are used, ream open* ings through che gasket for the bolts, and cover all exposed gasket surface at che holes with compound 880. This should be done with the clamps in position. Apply a light coat of compound to all ex posed surfaces of the gasket and to the un"derside oVcKif'"coVerr"* FBen^fhiTcorfip6ti&3TS *' tacky, as previously explained, aoune the cover. Thickness of Gasket (Inches) Length of Scarf (Inches) 3/8 2 1/4 * 1 1/4 3/16 1 Sand or file the surface until it is smooch, dra wing the sanding block or file toward the .chin`edge only. Apply a thin coat of G-E compound 880 to both scarfed surfaces and allow to dry until tacky. If the gasket is not to be used for several hours, clamp che scarfed joint together firmly and allow the clamps to remain for at least 30 minutes. Vafvs-stsm Packing! Packings for radiator and conservator valve seems sre made of rings of composition cork, 3/8 in. chick and 1/8 in. wide. They are in serted edgewise into the stuffing box, in which they fit snugly. Use no compound in applying these gaskets. The method of in sertion is ss follows: Remove che handle and gland, and clean all surfaces. Place the eork rings around the stem and force them into the stuffing box with a piece of standard 3/8 in. pipe. Repeat until the stuffing box Is full; then screw the gland down hard. Remove the gland and add n "corfcV. pf<fssin^''fir"`doVn^Vard 'fcTFfi 'tVe" gland. Assemble the handle and adjust the gland until the' valve stem turns quite hard. Tighten the bolts, drawing down all bolts in small increments. Proceed around tbe bolt circle several times until tbe gasket is com pressed to approximately ode-half its original thickness. Allow several hours (2 to 6) to elapse, then retighcen the bolts until the gas ket is compressed to about one-third its origi nal thickness. A third tightening, a few hours later, is also recommended- Keep the in sulating liquid away from the joint until the final tightening. Preparation of Scarfed Joints Place the gasket in a suitable fixture and cut to the proper angle. The correct lengrhs of scarf for various thicknesses of gasket are given in TABLE III. P IPE FITTINGS Then assembling pipe fittings, clean the threads thoroughly to remove all oil, grease, Pyranol, old compound, and din. Apply a coating of G-E compound 880 to the threads and screw the mating parts tightly in place. M A IN T EN A N C E In general, from the standpoint of mainten ance, operation, overvoltage protection, and overcurrent protection, Pyranol transformers should be treated the same as oil-filled trans formers. Specific instructions on items pecu liar to Pyranol transformers are given in the sections which follow. HANDLING PYRANOL Transformer Pyranol may be handled in the ooc 25 (rW- IOR3B PynnoLTt^ntf^rmmn f>d Pynnol Im m trtiJ Curnnl.RmMng R**etors same manner as mineral oil. However, con strength. Refer (o the section SAMPLING tinued exposure to liquid Pyranol nay pro AND TESTING PYRANOL. duce local skin irritations. Cleanliness among Pyranol samples may be drawn and tested workmen handling Pyranol constitutes an semiannually or annually, except in water- adequate safeguard against such effects. Or cooled transformers, where eests every four dinary medicinal washes will remove any months are recommended. Accurate records irritation caused by Pyranol coning ia con of these tests should be kept. If, at any time, tact with an open cut or skin abrasion. A the Pyranol tests below 23 kv at room temp drop of castor oil will neutralize any irrita erature, a filter press may be used to restore tion caused by eootact of liquid transformer the dielectric length to 30 kv or more. Pyranol with the eyes. As with nost volatile Maintain the level of the Pyranol in the materials, exposure to concentrated Pyranol transformer up to, or above, the mark on the vapors in unventilated rooms should be avoid Pyranol gage, or up to, or above, the lower ed. sampling valve. Pyranol must be handled in containers, Note that with a low operaring temperature pipes, all-metal hose, etc. which are free one of the constituents of No. 1467 Pyranol from oil, grease, pitch, or other foreign ma has a tendency to separate and appear on the terials, since they contaminate the liquid and ' surface as a light deposit. Then the operat decrease its noninflammable properties. It ing temperature returns to normal, this com is desirable that all sueb apparatus used in pound recombines with the Pyranol. storing or transporting Pyranol be maintained Examine the condition of the external trans for exclusive use with Pyranol, as it is ex former surfaces at regular intervals. If it is tremely difficult to remove all traces of oil, . found that weathering is taking place, clean or ocher Pyranol contaminants, from equip the surfaces thoroughly and repaint with a ment of this type. good grade of durable paint recommended by All-maal hose, instead of rubber-lined the General Electric Company. hose, must be used in handling Pyranol, since It is recommended that a pressure test be rubber is affected by Pyranol. made once a year, or more often for severe FILLING TRANSFORMERS Although all PyTanol transformers are ship-ped-afil led*wjrh, oj^ it j bejnec es sary. to refill a transformer. If so, proceed as' lows: Before filling the transformer, make sure chat the joints are tight and open all air vents. In order to prevent neration of the Pyranol, it is preferable to fill the transformer through the drain valve, with a filter press. operating conditions, to make sure that a complete seal is maintained. See instruc tions under heading PRESSURE TEST. -.-.--I 'a n sjo rn yrrj^ qujpp ed wicha pres sure-vacuum gage, observe tie "gage''rea'dingf" periodically. If it continues to read approxi mately zero lb per sq is. with varying Pyraool temperatures, a leak in the seal is indicated, and a pressure test should be made. Fill to the 23 C mark on the gage, or up to WATER-COOLED TRANSFORMERS the lower sampling valve if no gage is pro vided. Baked-on Glyptal* paint is resistant to the action of Pyranol. Air-cured Glyptal paint sed for touch-up work in the factory and for repainting ia the field, however, requires a rather long curing period. Therefore, care should be taken to remove all traces of Py ranol that are spilled or dripped oa the out side of the transformer. The ingoing cooling water should have a temperature of approximately 23 C. Supply enough water so that the difference in temp eratures between the ingoing and the out going is not more than 10 C. It is recom mended that thermometers be permanently installed in the ingoing and outgoing water connections so that the difference in temp eratures may be readily* observed. *here multiple cooling coils are employed, see that PERIODIC INSPECTION . the flow through each secrion is such as to After the first few days of operation, test the top and produce the same temperature rise in each. To prevent condensation, never allow water ( c -< T T m dM irt Re*. U.S. PmL Off. that has been exposed by loweri**- '*** Pv- 0 0 26 Pynnot Tttnsformmn tt Pynnol mmtrtrd Ci/nwni^timiiing Rttcion (BEH.tOQlB ranol level of che transformer. cator is available) and on the Pyranol temp Nearly all cooling water will, in time, fora rature. scale or sediment in the cooling coil, which materially decreases the efficiency of the coil. This is indicated by a high Pyranol temperature and a decreased flow of water, load conditions and water pressure remaining SAMPLING AND TESTING PYRANOL Follow the procedure outlined herewith to obtain consistent results from simples taken for either field or laboratory tests. the same. Sam pling from Transformers Seale and sediment can be removed from a cooling coil without removing the eoil'from the tank. Disconnect* both inlet and outlet pipes from the water system and temporarily pipe the coil to a point several feet away from the transformer, where the coil can be filled and emptied safely. Take special care to prevent any acid, dirt, or water from enter ing the transformer. 1. Take samples preferably when the temp- perature of the transformer is near 25 C. Take samples from outdoor apparatus on a clear day only and guard against contamination by wind-blown dust, etc. 2. Use glass bottles as sample containers. A .one-quart bottle will bold sufficient Pynaol for complete tests. 3. To clean the bottles, rinse with non? Blow or siphon all the water from the cool leaded, oil-free gasoline; then wash with ing coil, and pump it full of a solution of strong soapsuds, rinse thoroughly with water, hydrochloric (muriatic) acid, specific gravity . and dry`in aft oven at 105 C to 110 C for at 1.10. (Equal parts of commsrially pure, con centrated hydrochloric acid and water will give this specific gravity.) A peteock locat least eight hours. After drying the bottles, seal tightly with a glass stopper or a clean cork. Protect the cork by wrapping with clean, ed on the elbow at the upper end of the coil metal foil. must be used to vent a coil in a closed sys 4. Impurities tending to affect the dielec tem when siphoning the water. The chemical tric strength of Pyranol will, in general, be action which takes place when the acid en- at the top of the liquid. Therefore, take the ters the coil may be very violent and often sample from the top through the small valve forces aeid, sediment, etc. from both ends of or plug, and .allow enough Pyranol to run out the coil. Therefore, it is advisable to leave so that any moisture or foreign material which one end partially open to prevent abnormal may have collected in the drain pipe, valve, pressure. or plug will be removed. After the solution has stood in the eoil 3. Draw a sample into the bottle, leaving about an hour, flush it thoroughly with clean sufficient air space to allow for possible ex water. If all the scale ia not removed the pansion of the Pyranol. Carefully seal the first time, repeat che operation until the coil container to prevent any exposure of the Py- is clean, using a new solution each time. The ranol to the atmosphere, using the stopper number of times it is necessary to repeat che removed from the bottle. process will depend on the condition of the 6. After taking che sample, reseal the ap-. coil, although ordinarily one or two fillings pararus as described in PRESSURE TEST. will be sufficient. If the ssmple is taken when the tempera If a wster-cooled transformer is to be re ture is lower chan 25 C, reseal the apparatus moved from service, it is recommended that at atmospheric pressure. However, when the the cooling coil he drained thoroughly, dried temperature reaches 25 C, vent the apparatus by hot air, filled with Pyranol, and sealed. to atmospher;c pressure to avoid excessive OPERATION WITHOUT COOLING internal pressure at higher temperatures. MEDIUM Do not run an artificially cooled transfor Sam pling from Drums mer continuously, even at no load, without Take samples from drums after the Pyranol the cooling medium. If the circulation of the has remained undisturbed for at least eight cooling medium is unavoidably stopped, im hours, and when the Pyranol is at least as mediately reduce the load as much as pos warm as the surrounding air. If the drums are sible and keep a close watch on the winding outdoors, take samples on a clear day only temperature (if a winding-temperature indi- ` and guard against wind-blown dust, etc. Take 00( 21 G E H * tO Q 3B PyrtneJ-Trensformers ttu f P y rtn a l tmmeneel C v rrtn tJ im iim g actors s sample from the top of the drum by means of a chemically clean chief. Observe the sampling precautions outlined before. Clean the glass thieves, used for taking the samples, in the same (Banner as the bot tles, and dry, preferably at a temperature not l e s s than 37.8 C(100 F). To stin t for Dielectric S tren tth For testing the dielectric strength of Pyrasol, the technique as specified by the Ameri can Society for Testing Materials in the test method entitled, "The Standard Method of Testing Electrical Insulating Oils" shall be followed. The following precautions and mod ifications should be observed: 1. Set the spacing of the two 1-incb disk electrodes at 0.100 inch. 2. Yipe the test cup and electrodes elean *ith dry, calendered tissues, or clean, dry chamois and rinse thoroughly with clean, nonleaded, oil-free gasoline. 3. Fill the cup with dry gasoline and make a breakdown test under standard conditions of voltage application (3 kv per second rise). If the dielectric strength is not less than 23 kv, the cup is considered suitable for testing purposes. The usual precautions in handling gasoline should be observed. 4. Immediately after the final rinsing with gasoline, rinse the test cup with the Pyranol under investigation and proceed with the test at once. 3. The temperature of the Pyranol, when tested, should be the same as that of the room, which should be between 20 C and 30 C (68 F and 86 F). 6. After filling the rest cup, allow the Pyra nol to stand for three minutes before testing, to allow entrained air babbles to escape. 7. Test, only once per filling. Fill at least five times and average the results. Pyranol testing lower than 23 kv should be filtered or replaced. PYRANO L TESTING SERVICE For convenience in sampling and testing Pyranol, the General Electric Company will, upon receipt of order at an Apparatus bales Office, furnish one-quart containers filled with clean, dry Pyranol. After emptying the container into the apparatus, immediately re fill with the liquid to be tested. This ob viates Step 3 under SAMPLING FROM AP PARATUS, but the subsequent steps should 10 be followed to insure obtaining a sample re presentative of the original Pyranol. Send the samples to the Field Engineer, Power Transformer Engineering Division, Pittsfield, Massachusetts, for testing. Re commendations for continued use or treatment 1 will be furnished, in addition to a complete report covering the following tests: 2 Dielectric strength 3*Acidity 2. Color 4. Condition To assist in furnishing the most useful comments on the results of the tests, request for this information should: 1. State why the tests are considered de sirable. 2. Give the aerial number and rating of the . apparatus. 3* State whether or not the sample repre sents the Pyranol originally furnished with the apparatus. If not, when was the Pyranol replaced. 4. Scare the temperature and weather con ditions at the time the sample was taken. 3 Give any other information that might have a bearing on the condition of the Pyra nol. 6. State to whom the report should be sent. FILTERING A N D DRYING PYRANOL Transformer Pyranol will seldom require filtration because the tank of a Pyranol trans former is sealed. Extensive filtering with ful ler's earth will remove a portion of one of the constituents of Pyranol. Should much filter ing be done it is recommended that a one-quart sample of the Pyranol be sent to the Field -Engineer, General Electric Company, Pitts field, Massachusetts, for test and recommen dations for treatment of the Pyranol. j - Then it is necessary to filter Pyranol to re move moisture or foreign material, the follow ing is the recommended procedure: Use a Py ranol purifier consisting of a specially pro portioned filter press, a positive-volume gear pump, driving motor, combined drip pan and mixing tank, and the necessary piping, valves, strainer, gages and drying^ ovens. Thoroughly clean the equipment to remove foreign ma terial, including oil. Avoid oil contamination because oil is completely miscible in Pyra nol and cannot be separated by any practical method. It is recommended that, wherever possible, separate equipment be reserved for the exclusive use of Pyranol. 0 0 ' 28 PyranoJ Transforman and Pyranof im m anad CvrrantJim Uing R factors G R U . in tgr7<? .. TO REMOVE MOISTURE FROM PYRANOL OR ANY OTHER INSULATING LIQ UID A THOROUGHLY DRY FILTERING MEDIUM. IS ESSENTIAL. Filter ptper and fuller's earth are need for this purpose on the Pyranol purifier, and the effectiveness of the filtering process is proportional to the care and thoroughness with which these materials are dried initially. ; DRYING THE PAPER The individual sheets of filter* paper should be separated 1/8 inch or more when hung on the rods in the oven, to permit free circulation of air and to insure rapid drying. Dry the pa per from six to twelve hours (depending upon the condition of the paper and the separation of the sheets) at a temperature of 95 C to 105 C. After drying the paper, take it from the oven directly to the filter, or, if this is not convenient, store it under moisture-free Pyranol (in a sealed container) for future use. Then transferring the paper, take care to han dle it as little as possible to avoid the ab sorption of moisture from the hands and to min imize the time that the paper is exposed to the air. Then the filter paper has been dried, do not permit it to cool to room temperature until ac tually clamped in the filter press or otherwise shielded from contact with the air, because a thoroughly dried sheet of paper will, when cooled, take up an appreciable amount of mois ture from the air in a matter of seconds. In many cases, it is considered preferable to provide special containers holding one or more complete charges of predried paper, the paper in this case being dried at a central point where it can be done effectively and economically* After drying, the paper is placed in the container while still hoc, covered with moisture-free Pyranol* and the container sealed. Thus, a stock of moisture-free paper is always available for immediate use. DRYING FULLER'S EARTH Fuller's earth, a clay-like material with tiny pores having the ability to take up mois ture and other impurities, should be thorough ly dried before being used in the filter, be cause pores already partially filled with mois ture have only a limited capacity for taking up additional impurities. Unlike filter paper and similar cellulose material, fuller's earth can withstand tem peratures far in excess of the boiling point of water. Therefore, by hearing the earth to 200 C or 300 C (400 C is about the top limit), the moisture can be changed to steam and ef fectively driven from the'microscopic-pores. The length of time required to do this depends apon the depth of earth in the container and - the temperature. For example, two-hours at 250 C will be satisfactory if the earth is-in shallow pans not more chan two inches deep. Dry fuller's earth, like dry filter paper, should not be permitted to cool to room tem*` perature before ic is actually mixed with-the Pyranol. This avoids reabsorbing moisture ~ from the air. The importance of this precau tion ean be most readily appreciated by con* - sidering the fact that Pyranol-is dried during . the few seconds it takes for the Pyranol-to* pass through a layer of properly prepared ful- . ler's earth and. filter paper. Then a high-cemperarure oven is not availr -* able at, or near, the filtering Job, the earth can be dried simply and effectively by using" the familiar plumber's furnaee and a-shallow, clean pan. A four-inch section cut from-the* bottom of a 14- or 16-inch distribution-trans former tank makes a satisfactory pan, or a pan may be fabricated with a heavy base-sec tion that will distribute the heat uniformly over the entire bottom surface. A single charge of earth (six pounds) for the Pyranol filter will be about 1-3/4 inches deep in a pan with a diameter of 16 inches. Regulate the furnace to about the point, where the bottom of the pan begins to take on a blue color (this valuis not critical) and Stir the earth slowly with paddle to main tain a uniform temperature throughout. A charge of earth can be dried on the job just prior to being transferred into the filter, so that, being hot, it will not reabsorb moisture from the air during the charging operation. CHARGING THE FILTER The frames and plates -should be placed alternately and so positioned that, when facing the pump or head end of the equipment, the small projections, on their top edges are at the right-hand side. Place three sheets of,dry filter paper be tween each plate and adjacent frame, taking care that the holes in the paper co#-------* to not 29 / 0 9 3 8 P y n n o i Trgnsfotmen and P y n n o l tmmwneJ Currwni-timtiin^ f tiitta n those a the plates. As soon as they are po tank. Therefore, allow sufficient time (two sitioned, posh the plates and frames together hours or store) for this air to escape before the to prevent free circulation of air past the pa transformer is re-energized. If these instruc- per while the remaining sheets are being in serted. Then all the sheets are la position, clamp the press securely by mesas of the com pression screws at che back of the assembly. tioasare followed, there should beno difficul ty in obtaining a dielectric strength of 30 kv or higher, as measured with one-inch disks set 0.1 inch apart. - The charge for the filter should consist of six pounds, of 80/300 mesh fuller's earth (the equivalent ia volume to a little more than oae galloa ia liquid measure). Mix about a third of this charge with five or six gallons of clean Pyraaol in the mixing tank. Then the charge is thoroughly mixed, open the valve leadiag from the mixing tank to the pump, and the valve between the press outlet and the drip pan, and make sure the ocher valves are closed. Then start the motor to circulate the Pyranoi and fuller's earth mixture through the press so as to deposit a layer of fuller's earth on the surface of che filter paper. After the pump has been running about five minutes, the remainder of the six-pound charge of earth may be added gradually to the mixing tank. Ac the same time, stir the mixture thoroughly to prevent any dry lumps of earth being drawn into the pump. The addieioh of the remainder of the earth will take from 10 to 13 minutes. It is recommended that che purifier be run at least five minutes after the last of che earth is added to make sure that all earth is de posited in the press and chat the cake is of proper depth. The purifier is then ready for use. OPERATION The most effective procedure for filtering is to pump the Pyraaol through the filter and CLEANING THE FILTER Compressed air passed through the press will release a considerable amount of Pyranoi that would otherwise be retained in the earth sod filter paper. To do this, first close all valves except the one leading from the filter-press outlet to che drip pan. Then connect a supply of dry, oil-free compressed air to the connec tion at the press inlet and pass the airthrough the press until no further Pyranoi 5 dis charged into the drip pan. Air pressures as high as 100 pounds can be used; the higher the pressure, the more rapidly the Pyranoi is foreed out. Ia addition to saving Pyranoi, this opera tion simplifies the subsequent removal of che earth and filter paper. After blowing out the press, the individual frames, with che filter paper held ia position o,n each side, ean be lifted from the press intact, and the earth and paper discarded with minimum effort. PUMP The purifier is equipped with a constant-; volume gear pump having a built-in relief valve adjusted to limit the output pressure to 100 pounds per square inch. The higher spe cific gravity of Pyraaol does not permit long or high ' 'auction" lifts; hence h is desirable to so locate che filtering apparatus that the inlet connections will be as short as possi- into a clean tank. Then this is not practica ble, the circulation method may he used, whereby the impure fluid is pumped directly from the transformer tank through the filter sod hack to the same tank. In such cases, it is recommended that che transformer be de energised. Since moat of the free water and sediment are asually found near the top surface of che Pyraool, the inlet to the filter should be con n e c t e d to the top of the transformer tank and the return fluid delivered into the bottom. Dur ing the filtering operation,'any air which has been drawn into the filter press will be dis charged into the bottom of the transformer . hie. The Pyranoi should preferably flow into the pump by gravity. There long runs cannot be avoided, the use of large hose will give best results. Tbere it is accessary to filter Pyranoi in transformers located in subway manholes or street vaults, space limitations usually make it impractical to lower the purifier into che vault. To maintain full-capacity operation under these conditions, it is recommended that a portable auxiliary motor and pump unit be installed in che vault to pump che Pyranoi up to the filter. After the equivalent cf several months of continuous service, che lbrasive action of It 0 0 30 Pynnol Tramformon and Pyranol ImmanaJ Currtnt.limiiing Ratetori GEW- tO?28 the fuller's earth passing through the pump gears map cause considerable.ear, particu larly if the Pyranol and fuller's earth are aoc well mixed. The filter is designed for con* venienc pump replacement, and hen this e ar has advanced to the extent that the out* put of the apparatus is appreciably below normal, install a new pump. While individual repair parts can be obtained for these pumps, the ear 11 be found to be so generally dis* tribated over the whole pump that a complete replacement is advisable. MOTOR The 1.5-horsepower motor is geared direct* ly to the pump. Ordinarily, a single-phase, 110/220-voIt, 60-cycle induction motor is supplied, but motors for other voltages and frequencies, or for direct current may be ob tained. STRAINER The strainer is provided to prevent any thing of appreciable size from entering and injuring the pump. It is easily accessible and should be thoroughly cleaned at regular in tervals. ELECTRIC DRYING OVEN The oven for this purifier requires approx imately MOO wmtts and is designed to oper ate from either 100-vole or 220-volt, single phase alternating current. The oven is pro vided with ao automatic heat control to avoid overheating the paper and earth, and is di vided into four compartments, each: with rods for suspending the filter paper for drying. DRYING PYRANOL TRANSFO RM ERS Dry Pyranol transformers by the shortcircuit method. Before applying voltage, blanket the transformer, beginning at the bot tom of the corrugations, cubes, or radiators and wrapping the tank with heavy paper, cloth, or building felt until sufficient surface has been covered (judged by trial). To pre vent condensation, thoroughly lag the cover. Ventilate the cover by raising the manhole covers, etc. and protect the openings if the transformer is out-of-doors. If the drying is carried on indoors, good ventilation or other meins should be provided to exhaust the vapors from the room. For two-winding transformers, short-circuit -one winding and apply voltage to the other winding to give the percent of full-load cur rent for maximum allowable top-PyranoI temp eratures in accordance with Table IV. Lower top-Pymnol temperatures may be used, but the length of the drying run .ill be increased. Table IV gives the values which apply to the SELF-COOLED rating, of type OA (self- cooled) as well as VC (water-cooled with internal cooling coil) transformers. The lat ter may not need blanketing of the tank, al though the cover should be lagged. Before drying three-winding transformers, or any of the forced-liquid-cooled types, ob tain advice from the nearest Apparatus Sales Office of the General Electric Company. TABLE 4 Maxsaun^allowmble Short- Kaxunany-allowahle Circuit Amperes in Per- To^Fynnol cent of Fall Load, Bued oo Self-Cooled Hating (aee preceding Tempo'iture paragraphs.) 50 100C 75 90C Do not alio the to^PyranoI temperature to exceed the specified value for the given pffcenr load, because* the windings are at a higher temperature than :he Pyranol, and damage to the insulation may result. Continue the drying until seven consecu-' five tests of samples of cop Pyranol taken every four hours show a dielectric strength of 30 kv or higher. Allow the Pyranol'sam ples to cool to room temperature (not higher than 40 C) before testing. SPARE TRANSFORMERS Time and expense will be saved If spare nits ire kept in readiness for instant use. Inspect the following tems during periods of Idleness: Pyranol level, Pyranol dielec tric strength, relief diaphragms, fan control and conduit, mercury seals, and load-ratio control. Also make periodic pressure tests. LOCAL CONDITIONS AFFECTING THE OPERATION AND LIFE OF TRANSFORMERS IMPURE AIR Ualess special care is taken, trouble may be experienced with transformers that are in stalled where abnormal conditions prevail. Bushings must be kept clean, since: the 00C 31 > /. / 0 9 J 8 P y n n o i Trtn sform in * n j Pyrs/tof m m ened Cumni-timiUtyQ e*cfon form at ion of conducting deposits may cause bushing arc-overs. Transformers near the seacoast should be kept well painted to prevent the corroding of any metal parts by the damp salt air. Conduit piping leading from the station to the terminal box at the transformer should be sealed to prevent warm air flowing to the box and condensing.. ALTITUDE If a transformer is moved to a location of a higher altitude, the effects due to the de creased air density are to increase its temp erature, rise (ifi self-cooled) and its pressure, and to lower the sparkover voltage of the bushings. These effects must be considered if a transformer is operated at a higher alti tude than that for which it was designed. After moving the transformer, seal it at 25 C with zero lb per sq in. pressure. Standard bushings may be used at any alti tude up to 3300 feet. If transformers are to be moved to an elevation higher than 3300 feet, first communicate with the aearesr Ap paratus Sales Office of the General Electric Company relative to suitability of tbe bush ings. TRANSFORMEiR HOUSING . Vhen large,j self-cooled Pyrmnol trans forme's are installed in vaults or compart ments, it is necessary to thoroughly ventilate tbe compartment. Provide cool-air inlets in, or near, tbe floor and outlets in, or near, the roof. Have the latter six feet or more above the top of the transformer. The num ber and size of the air outlets required will depend on their distance above the trans former, and on the efficiency and load cycle of the apparatus. In general, provide about 20 square feet each of inlet and outlet for each 1000 kva of transformer capacity. If the transformer will be required to operate for considerable periods at continuous full load, the areas of openings should be in creased to about 40 square feet per 1000 kva of transformer capacity. Arrange the air inlets and outlets so that they are permanently open. Do not use as ventilators, windows or doors which can be opened and closed by attendants, because of (he danger oi are inadvertently left closed during periods 14 of heavy load or high temperature. If forced ventilation is used, supply about 5000 cubic feet of air per minute for each 1000 kva of transformer capacity, aod conduct tbe incoming air directly to-jhe transformers so that it will flow up through and around the radiating members of the tank. If this cannot be done, and the air is merely moved through the room, provide abour 10,000 cubic feet per minute for each 1000 kva. Do not let the temperature of tbe room in which the transformer is installed exceed the temperature of the air entering the room by more than 5 C. Tbe entering air should come from a source not much warmer than the out side air. U Q U ID -TEM PER A TU R E INDICATOR TYPES P-2 M -1 3 ,A -1 0 The liquid^temperature indicator provides a means of reading the top-liquid temperature of a transformer. Such readings, if taken fre quently, will indicate abnormal conditions affecting the transformer. However, the read ings must not be relied upon as an indication of permissible load. DESCRIPTION Gsnwral The scale of the P-2 indicator reads 0 C120 C; while the scales of the M-13 and A-10 indicators read 20 C-100 C. Each indicator has an indicating needle (white) and maxi mum-reading needle (red), a Bourdon tube, and a length of capillary tubing that extends from tbe Bourdon tube to a bulb. The capil lary systems of the P-2 and M-13 indicators are of the liquid-filled type; whereas the system of the A-10 indicator is of the vaporpressure type. In either system, a change in cop-liquid temperature causes a change in pressure which actuates the Bourdon rube, thereby rotating the indicating needle. The bulb of each type of indicator is mount ed in a liquid-tight well in the top liquid of the transformer. Thus, an indicator can be removed without lowering the insulating liq uid in the transformer. ' A stop on the indicating needle moves the maximum-reading needle up scale so as to indicate the highest top-liquid temperature T 'lg U .1 --1 mum-reading needle can be reset by turning 0 0 C 32 Pyrtnol Tr*ntfofm *n s n J Pyrnot Im m + n tJ Cvrrtni-lim tting #teton G EH * 10*939 the knurled knob on the front of the P-2 sod M-13 indicators, or the reset lever extending below the case of the A-10 indicator. Each indicator contains a small snapaction switch with normally open contacts that can be used in an alarm or signal circuit. These contacts are adjusted at the factory to close at 73 C on water-cooled and forced Pyranol cooled transformers, and at 60 C on other types. Typo P-2 Indicator The P-2 indicator is furnished on trans formers, regardless of rating, where the mounting height is 120 inches, or less, above the floor level. The bulb is mounted in a well located in the tank wall, or in a tube header. To connect the alarm leads of this indi cator into an alarm circuit, remove the cap shown in Fig. 1. Uncoil the leads in the housing and remove the threaded bushing and housing. To the threaded bushing, solder a 12-inch maximum length of flexible conduit; then reassemble the threaded bushing and conduit over the leads and into the indicator case. TVPC 2 Fig. L Liqai-temperatune indicator, Type P-2, lead proteetioo mod connection Typo M -13 Indicator The type M-13 indicator is furnished on transformers 3001 kvs to 7300 kva when a local-type winding-temperature indicator is not furnished. It is also furnished on trans formers 301 kva to 7300 kva when the mount ing height does not permit the use of the P-2 indicator (i.e. mounting heights over 120 inches). The indicator dial is mounted at eye level above the base of the transformer. The alarm leads of the M-13 indicator are brought out of the case through flexible leadcovered cable. Typw A-IO Indicator This indicator is furnished on all trans formers rated above 7300 kva and on trans formc s 3001 kva to 7300 kva when a localtype winding-temperature indicator is also furnished. The indicator dial is mounted at eye level above the base of the transformer. Connections to the alarm-switch leads are made in a similar manner to those on the Pr2 indicator, as previously described. PR E5SU R E-R EL1EF DIAPHRAGMS A pressure-relief diaphragm is standard equipment on all Pyranol transformers above 23 kva. This diaphragm is made of frangible marerial and is held in place by flanges. A diaphragm breaker is normally used on transformers under 200 kva to rupture the dia phragm when the maximum safe pressure in the transformer tank is exceeded. The break er consists of a spring-operated plunger which is set by hand and is released by a bellows that operates the release pin when the pressure in the tank exceeds the pressure setting of the device. (See Fig. 2.) Older types of diaphragms do not have the breaker mechanism. In one type, the dia phragm is held between two flanges with cushioning gaskets, all assembled as a unit in a press so that uniform pressure is applied to the circumference of the diaphragm. The assembly is held together with flat-head crews, and the complete unit is bolted to a flange on the transformer. In bolting this as sembly to the tank, a gasket is placed on the tank flange. The older-type gasket is cork composit:on. It requires a covering of G-E compound 880 on both sides; whereas the 00 33 '6 G N*/093& P y r v td T rtn tform tn t n J P yrtn oi immen+d Curr*ni-tImUii*g ff**eton Tbe diaphragms are usually protected by a spua-metai cover snapped in place over the diaphragm flange EIGHT-INCH PRESSURE RELIEF RtcflMng Then tbe eight-inch pressure relief is ship ped assembled in place on the transformer, 'one temporary wooden block under the free cap and another between the free cap and re tained hood firmly support all pans. These temporary blocks are wired together at one end and marked with redj paint. Remove the blocks before potting tbe transformer into operation. 1 For separate shipment of the pressure-re lief device, s temporary cover is placed over the opening. The removable spider is left in place in the cover opening, and the diaphragm is packed separately. The cop flange, free cap, and retained hood are shipped assem bled. DoocHption Fig. 3 shows the parts of this device with a place which represents the tank cover. Tbe nitrile-rubber gasket requires no compound co aake * gas-and liquid-tight joint. The dia phragm assembly is bolted to the tank flange with cap screws fitted with lock washers, as bsc described. In another type, the diaphragm is held be tween one flange welded to the transformer mod a separate flange held by cap screws. The diaphragm is protected on both sides of the cushioning gaskets. The technique em ployed in bolting down this type of diaphragm and making the seal is of prime importance, since the rupture strength of the frangible material depends materially on the care with which this operation is performed. Vh.en replacing diaphragms of the latter type, clean the gasket surface of the tank flange thoroughly. If the inner gasket is cork, coat both sides with G-E compound B80. Lay the gasket on the rank flange and place the diaphragm over the gasket, being careful co center it properly. Lay the cushion gasket over thediaphragm and assemble the clamp ing ring over the cushioo, holding it in place with cap screws. 34 i Pyranol Trantformtrt nd'Pyrano! tmmint Cunw-A'miim$ Raactort GeW./OJB relief diaphragm is a thin disk of molded ma terial (G-E compound 20295) firmly held be tween clamping rings with a asleeted joint. These clamping tings are the bottom flange on the main cover and the top flange. Lo cated in the cover opening-directly below the diaphragm is a removable spider which sup ports the diaphragm in case of vacuum in the tank. In the cop flange is a crossbar rigidly held in place by a setscrew at each end. The lower side of the erossbar holds a blade with a knife edge a short distaoce above the dia phragm. A grid, which is restricted in its vertical movement by two screws, is fastened to the crossbar by.a relief pin, so that the edges of the grid are located j u s above the diaphragm. A metal cap (free cap) fits down over the top flange and is held in place by two spring clips, thus providing weatherproof prorecrion for the diaphragm. If the device is provided with an alarm switch, two sup porting clips are mounted on the top flange to prevent the free cap iron tilting. For a complete description of the alarm seethe sub sequent chapter on PRESSURE RELIEF ALARM. Assembled over the free cap is s retained hood with six feet bolted to the edge of the top flange. Then required, a special shield is mounted on one side of the pressurerelief device to deflect any oil chat may be e jected when the device operates. This shield is held in place by three long bolts and three spacers bolted to three of the holes in the edge of the cop flange. Should a sudden pressure oceur within the transformer tank, the relief diaphragm will be forced up against (he bottom edges of the grid, breaking the relief pin and allowing the grid to rise to the top of the screws. This permits the diaphragm to contact the knife edge, which immediately ruptures the dia phragm. The escaping gas raises the free cap and relieves the internal pressure, after which the free cap drops back in place to elose the diaphragm opening, reducing the possibility of moisture entering the trans-' former tank. The number " 1 0 " scamped on the head of the relief pin indicates a diaphragm rupturing pressure of 10 pounds per square inch; the number "IV* signifies a diaphragm rupturing pressure of 13 pounds per square inch. Installation If the pressure-relief device was shipped on the transformer, it is only necessary to re move the temporary wooden blocks and make certain the diaphragm is intact to prepare the device for operation. To inspect the dia phragm, remove the retained hood and the free cap, then replace these parts. If the pressure-relief device was shipped separately, remove the temporary shipping plate over the opening. Make certain the gas ket is in place in the bottom flange, then place the diaphragm over the gasket. Assem ble the cop flange over the diaphragm, bolting it-firmly in place; Fit the free cap firmly in place on top of the flange. If the device is equipped with an alarm switch, make sure the two supporting clips rest firmly against the free cap. Install the retained hood over the free cap by holding it to the edge of the top flange with six. hex head screws. If a shield is provided, assemble it in the desired lotarion, using the long bolts and . spacers. On S sa lsd Transform ers Install the pressure-relief device on sealed ; transforms* when the liquid temperature is between 23 C and 40 C. The pressure at which the transformer is sealed is dependent on the temperature of the liquid* and should be in accordance with instructions under PRESSURE TEST. Vh en this pressure-relief device is used on a sealed transformer to be installed in doors, a gas absorber or a vent pipe to the outside atmosphere can be installed directly over tbe relief diaphragm, if required. If this installation is to be made, it is necessary to remove the retained hood and the free cap from over tbe relief diaphragm. Six tapped boles (1/2 inch- 12) are provided in the top flange, to which the flange of the gas absorb er or the vent pipe can be bolted. The outer end of a vent pipe should be protected from the weather. ' Ronowal of D iiph ngm To renew the relief diaphragm after if has been ruptured, it is necessary to remove the retiined hood by taking* ouTThe six hex-head, screws around the rim of the top flange. If a shield is provided on one side of the pres sure-relief device, note its positii , 35 JQ Q 3B Pyranoi Transforman and Pyranol tmmanad Currant-limiUng R aacton it can be replaced in the same location. Re move the retained hood and lift off the free cap. Take our the six hex-head screws hold* in ; the top flange and remove the top flange together with the restricted grid. Remove the broken diaphragm. Note that a removable spider is located in the opening below the diaphragm. This spider oust be left in place. However, it can be removed if it is necessary to ase the opening as a handhole for any p a r pose. Then replacing the spider, be sure the aotched ends are down. Make certain the gasket is in place in the groove in the top flange, then place a new diaphragm overthe gasket.'Remove the broken port of the relief pin from the crossbarin the cop flange. (The bottom part of the relief pin is slotted to facilitate removal.) Remove the broken part of the relief pin from the top bar of the restricted grid by removing the small brass locking screw and washer* The new relief pin must have the same number (10 or 13) scamped on the head as the one being re* placed. Install the new relief pin by insert* ing it through the central hole in the top bar of the restricted grid and carefully screwing it into place, using a very light twisting ef* fort on the screw. For this reason, the relief - pin is designed to be screwed in with the fingers. Replace the washer and small brass **-S'ertpw- tcp^ock-^b-w^EeUef bjeg^lve.. top flange over the diaphragm, bolting it firm ly in place. Fit the free cap firmly in place on the top flange. On devices provided with an alarm switch, make sure the two support ing clips rest firmly against the free cap to prevent it from tilting. Install the retained hood over the free cap by bolting it to the edge of tbe top flange with the six hex-head screws. If a shield is provided on the pres sure-relief device, assemble ir in the proper place, using the long bolts and spacers. Pressura-raliaf Alarm A pressure-relief alarm switch can be mounted on the transformer cover adjacent to the pressure-relief device. The switch is as sembled inside a weatherproof housing and has a shaft protruding and bent at a right angle. A coil spring on the shaft exerts con siderable twisting effort, and a cam mounted near one end of the shaft acts as a stop, allowing the shaft about 90 degrees rotation. At one end of its travel the cam comes against the actuating member of the small snap-action switch mounted inside the hous ing, closing the switch. The switch housing, fitted with a weatherproof cover, has provi sion for conduit connection. The switch is rated 5 amperes at 230 volts s-c, or 10 amperes at 123 volts a-c. The d-c racing is approximately 0.03 ampere at 230 volts maximum. There is also a visible alarm mounted on tbe shaft. This indicator (painted red) turns Bp to the vertical position when the shaft rotates. To set the switch in the normal open posi tion it is necessary to lift up the free cap on the pressure-relief device. Then use the re set pin to turn the shaft so as to bring the bent end to a vertical position. The free cap should then be pressed down in place with the vertical end of the shaft engaging in the hole in the angle bracket attached to the free cap. .In (his way, the switch is held in the open position. TEN-INCH PRESSURE RELIEF Rac Bivins For shipping purposes, the relief pin is removed and shipped separately with an extra relief pin, gasket, and diaphragm. Also, the relief cover is securely wired in place. When installing the transformer, remove the ship- pf jf*w]re" frffnr:t freirccrver - tiird* :*th .-~.- relief pin as described under INSTALLA TION. Dascriptfon Fig. 4 shows tire outline of the 10-inch pressure relief and the internal construction in two sectional views. The diaphragm is a thin disk of G-E compound No. 2029B firmly held between a recessed gasket in the pipe flange and clamping flange. The grid in the pipe flange enables the diaphragm to with stand full vacuum in the tank, and a gasketed, metal cover, closed firmly .over the diaphragm by spring tension, protects it from the weather and mechanical injury. The relief pin ex tends through the edge of the cover opposite the hinge, and is screwed into the diaphragm clamping ring to hold the cover closed. The treated aluminum composition of this pin pre cludes corrosion. One of two numbers ill be found stamped on the head of the relief pin. The number "10" i n d i c a t e i,- P yn tto ! Transformers * n j Pyranot Im m tneti CurronbttmMng P ta cto n G t r l- 1 0 9 3 3 rapturing pressure of 10 pounds per square inch; the number **13** signifies a diaphragm rupturing pressure of 13 pounds per square inch. A sudden pressure within the transformer tank will force the diaphragm out against the cover, exerting tension on the relief pin, which is designed to break when the tension reaches the predetermined value. As soon as the relief pin breaks, the diaphragm is re leased against a knife edge centrally located over the front of the diaphragm. The knife edge cuts through the diaphragm, which breaks open to relieve the pressure. Immediately after relief of the pressure, the cover is clos ed by spring action, shutting firmly against a gasket to reduce the possibility of moisture entering the transformer. Installation When, installing the transformer, remove the shipping wire from the relief cover. Insert the aluminum relief pin through the steel pin in the edge of the cover, and screw it into the steel clamping ring. Use a nail in the hole just above the threads of the relief pin to screw it into place, and tighten the relief pin only until the head touches the steel pin in the cover without straining the relief pin. Do not turn the relief pin by its top end. After -xjK^re`lief,pi*'i'isr-e*wed -aeo`-`*pkaci to prevent tampering by using a piece of cop per wire through the hole io the head of the pin and passing the wire around the steel pin as shown in section A-A of Fig. 4. VENT PIPES AND GAS ABSORBERS Pyranol transformers raced 1 3 ,0 0 0 volts or less can be installed in a-building without a fireproof vault in accordance with the require m e n t s ^ the 1 9 4 7 National Electric Code*, since in sizes above 23 kva they are equipped with pressure-relief diaphragms or vents. This diaphragm meets the code requirements for transformers installed in well-ventilated areas. The upper steel clamping ring which fastens the diaphragm to the transformer is provided `Fig. 4. Pressure relief with 104och diaphragm with tapped holes, arranged to permit the easy attachment of a vent pipe that can be carried to the outside air, to a chimney, or to some other ventilating flue. VENT PIPES Then a vent pipe is provided for carrying gases <away from a poorly ventilated area, it VM-"KMWifWMM "4522* "A skarel-lnsuJatrd Transformers Installed Indoors. Askarvl-Lnsuiated transformers rated In excess of 25 kva shaj] be fumisned with" a pressure-relief vent. If Installed In a poorly ventilated place they snail be furnished with a means for absorbing any cases ceneraLed by arcing inside the ease, or the pressure-relief vent snail be connected to a chimney or flue m en will carry sues c&ses outside the guiding. A ikarel-lnsulsted transformers rated more than 15,000 volts snail be installed in a vault'*. Fig. 5. Vcnt-pipe-ilsngo outlines and Jim ensi G E fd - 1 0930 P yn n o J Transformer! and P y n n e t Immersed Current-limiting Rettio n Is recommended that its diameter be no smaller than the clear diameter of the frangible dia phragm to which it is attached; chat is, either six or eight inches, as shown in the outline (Fig. 5). It is also recommended that the met al of which the irenc pipe is made shall not be lighter than No. Id gage and that it shall be installed with the minimum of bends in order to provide a free passage of gas. It is farther recommended that provision be made for in specting the diaphragm and for removing any moisture that may accumulate on it. It is pre ferable that the pipe be so arranged that mois ture cannot collect on the diaphragm. GAS ABSORBERS There the installation of a vent pipe is not practicable, a gas absorber can be installed on the flange over the frangible diaphragm, as shown in Figs. 6 and 7. An absorber is de signed to absorb the gases produced by arc disintegration of part of the Pyranol in the transformer,~cwo percent of the Pyranol in distribution and power transformers, and five percent for a-c network transformers. This absorber has a steel tank with a mounting flange at the bottom for attachment to the relief vent of the transformer tank. At the top is a diaphragm with protecting cover. --Inni dc -fhe^baatihffif 4*$ k >^e:vs^ raIjra^S j r one above the other, each of which has a per forated steel bottom. The trays are fastened together by a center bolt to facilitate assem bly, and the entire group is secured to the ab sorber tank by two scuds. The bottom tray is filled with chipped marble; the upper trays contain G-E Compound A50P9. For transform ers rated over 300 kva, all trays contain the compound. Then an arc in the transformer generates gas and raises the pressure sufficient to break the diaphragm on the transformer, the gas passes into the absorber and is absorbed by the compound. Liquid carried along with the gas is stopped by the chipped marble and drains back into the transformer. If the gas exceeds the capacity of the absorber, the top diaphragm breaks. APPLICATION Under the provisions of the National Elec* trie Code, it~is*the responsioimy 01 tne *ocai code .authority to determine wh ether rent pipes Fig. 6. Pyranol tranaformer with gee abaorber or absorbers are required for a given installa tion. Important factors to be considered are: the energy available in the circuit to which the transformers are connected, the tvoe of protective equipment, the area and volume of 1k r0 m 1 which the transformers are instaTTea; tne "ir'enu 1aTTon Tact lines in tne room, the number of people employed in th- -*- 000 38 Pyrwot Transforman and Pyranol tmmonod Currank-tlmitir*? Raacton GW- 0 9 2 3 and the proximity of the employees to the transformers. If absorbers are osed, it is recommended that one absorber be used with each transform er. If one absorber is connected to two or more transformers by means of a header pipe, there is the possibility chat if one transform er fails and sufficient jas is generated to break the glass diaphragm in that transformer, the pressure in the header pipe may also be sufficient to break the diaphragms in the ocher transformers. Furthermore, if more than one transformer were simultaneously involved in trouble, sufficient gas might be produced, to exceed the capacity of one absorber. The absorber should be inspected ar in tervals to make certain that the diaphragms are intact and that the compound in the ab sorber trays has not become damp or caked. h en a gas absorber is supplied, a separate instruction book, which describes the installa tion, operation and care of the device, accom panies the apparatus. Fig. 7. Cm absorber SAMPLING VALVE Some transformers are provided with a sam pling valve by means of which the heigh: of the intake can be varied to coincide with the rise and fall of the Pyranol level, correspond ing to temperature changes. This type of valve makes itpossible to obtain a sample at the surface of the Pyranol at any time. The valve is placed is the tank wall ar a point about one inch below the 22 C Pyranol level. The intake pipe is a tube inside the tank and located parallel to the tank wall, the end of which may be raised or lowered by ro tating the outside part of the valve by moving the handle which extends below it. Note that when the handle points straight down, the in take pipe points straight up and is in position for maximum. Pyranol level. The valve is fitted with a knurled nut which can.be opened by hand, or by the use of a coin or screw driver. To take a sample, set the operating haodle pointing down, open the valve, and rotate the operating handle slowly until the liquid beginsto flow, at which point the rotation should be stopped to assure getting a sample of the surface liquid. Some transformers do not use the rotating feature, in which ease the sample is taken by Ugr. chfc'.ialv^.. -a.U.ojviatg.th*,.^-.. liquid to flow out. Pyranol transformers are sealed, and no breatbing takes place with the rise and fall of the Pyranol level. Thus, when the Pyranol is at a temperature other than 22 C, there is either a pressure or a vacuum within the tank, depending upon whether the temperature is above or below 22 C. For this reason, it is advisable to take a sample only when the Pyranol level gage is resting on, or slightly above, the 22 C mark. If tbe valve has been opened at any other time, and the vacuum or the pressure has been relieved, the valve should again be opened when the Pyranol seat reaches the 22 C level so that no abncrmal pressure or vacuum will be developed during subsequent changes in temperature. If the transformer is resealed while the Py ranol is at a temperature chat is above 25 C, tbe pressure in the air space can be restored to the proper value by dry compressed air or onnnitrogen. The proper sealing press 39 G S H - I0 2 B Pyrnnof Trmmformen in ti PynnoJ /mmvrit^ Currrni-dmiltng P **ctan various temperatures are listed in a Table ander Pressure Test. TAP CHANGERS FOR DE-ENERGIZED OPERATION There are several types of tap changers (ratio adjusters).knowu as "drum*1, "plunger", "crab", sad "wedge". All tap changers have indicating marks on stationary and rotating parts which oust be' in alignment when the tap changers are oa position No. 1. NOTE: DO NOT ATTEMPT TO CHANGE CONNECTIONS BY MEANS OF THE TAP CHANGER WHILE A TRANSFORMER IS EXCITED. A DRUM TYPE \ A change in voltage ratio with a drum-type tap changer is made by a partial turn of the handle. Remove the two bolts that hold the handle in place, or the cover over the handle, and turn until the index line points directly to the desired figure on the dial. After the handle is in the proper position, lock secure ly by replacing the two bolts or the cover. Before removing a power-transformer cover, take out the bolts that actaeh the tap changer to the cover flange, then lift the handle and shaft out of the cover. Do not replace a cov er "on' a *tVni 'Vi t f i b i r ' 1sp^Ciran-ger -op-ora rods in place. First, assemble the cover and lower the rods through their respective open ings, noting that they engage properly with the tap changers, and finally add the cover operating mechanism. When more than one operating rod is fur bished, the rods are numbered in accordance with the nameplate, mad are not interchange able. Match marks on the operating rods and the internal core-and-coil structure indicate the proper assembly of the operating rods and tap changers. The slot and pin joining the rod to the operating cap are larger on one side" of the rod than on the other to aid in mak ing correct assembly. A vernier coupling is used between the rod and the operating cap to assure that the indicator points directly to the dial number when the mechaoism is in a correct operating position. Sometimes, in re assembling, it may be necessary to change the vernier coupling in order to obtaio proper alignment of the shafts. Be sure that the sa operating cap does not force the. rod down on the mechanism. It should be possible to move the rod slightly up and down and rotate it an equal distance to either side after the assem bly is completed; otherwise,* the mechanism might be damaged. If this vertical play is noe obtained, remove the metal sleeve from one end of the rod, cut a small amount from the rod, and replace the sleeve. PLUNGER TYPE The plunger-type tap changer provides sol id insulation between tbe tap connections. This insulation must be lifted over the con tact members each time the taps are changed. To change taps, remove the two hex-head bolts in the cap and lift off the cap. Pull up thehandle as far as it will come (about seven inches). Rotate the handle until the pointer end is over the desired tap position, and then push down into the original position. Tighten the gland and bolt down the cap. Tbe contactor is of the scraping type and is self-cleaning. If it is considered desirable to make an inspection, proceed as follows: Remove the cap, lift up the handle as in changing taps, and turn the contactor ro a po sition between taps. It will stand in this po sition. Then remove the three studs and take off the clamping ring. Lift straight up on the handle. This will remove the small cover fthfpjfcgh*JiiclL ^*Jui^usxe 4 jrisp the operating shaft and contactor. "" ^ " When it is desired to remove the transformer cover, the tap-changer contactor should first be removed from the transformer. CRAB TYPE This type of tap changer is so named be cause of tbe nnique action by which the ec centric drive shaft and the contact arm, which it actuates, rotate in opposite directions. The construction consists essentially of a number of round contact rods with studs, to which the tap leads are connected. These contact rods are mounted between insulating heads of molded compound with Herkolic.e*tube inserts. A centrally mounted crankshaftthat actuates the movable-contact arm is op erated through a Herkolite insulating cou pling. The contact arm has fingers which eontact the individual coacaet rods at the outer end, and, at the inner end;--cylindrical copper collector which is placed over the R e t. U .S. P u . O ff. 00 40 Pyn n oJ Trtntform*rs and PyrtnoJ Im m tn td Cun*nt*limi<*9 /?#tvn G E rl- /0 -3 C c 1. FoldInc b ud r Sturt 3. C u k it 4. Nut 3. rollover L CtskeU 7. Tank of transformer I . Vernier coupline t. Iftdei m et* 10. Iasulatlnc abaft II. Ibdez line 12. Tap<tmnfcr upline 13. Half cylinder 14. Index paint mart 15. Casket 10. Numbered disk 17. Disk U . Cam Fig. 3. Operating mechanism for wedge-type tap changer drive shaft. Extending from this collector is a copper arm which connects to a separate stud similar to the contact rods. Th'is stud forms a common terminal completing the eir* cuit through (he tap changer from any of the contact rods. WEDGE TYPE F olding-hsndl Op rating M echanism The operating mechanism for the wedgetype cap changer has a folding handle. (See Fig. 8.) To change taps, take out the two holts in the mechanism cover and remove the cap. This completely uncovers the folding crank, which can be unfolded by grasping the nearest section and lifting out. Then the crank s unfolded, the position number is ex posed. Turn tbe cap change? by means of the crank to the desired position, fold the crank to the "locked** position, and replace the cap. When the cap is bolted over the mechanism, a metal pointerwill be in alignment with a num ber on the rim. of the cap to indicate the tap position on which the tap changer stands. One 00 41 s S E H - lO iB P yn n o Trantforman and Pyrtnol Immanad CurranidimiUng Raacion of the bolts in the cover has a hole into which a padlock can be inserted to lock the operating mechanism in position. If the operating mechanism and insulating rod are shipped separate from the transformer, they must be carefully assembled to assnre satisfactory operation. Operating mechanisms and rods are identified by the tap-changer number aod the last three numbers of the serial number of the transformer, as shown on the nameplate. Operating mechanisms with insulating rods attached must be assembled to the tap chang ers when both are on position 1. On this po sition the contact wedge of the tap changeras always between~tbe-two contact rods that are . connected to the leads tagged A and B. Check to aee that the tap changer is on position 1. On this position only, the large end of the deirog pin lines up with the line on the cyl inder or clamp. Next, check the connection of the vernier coupling at the cop of the insulat ing rod. The marks on the two coupling halves should line up. -Insert the insulating rod through the opening in the tank or cover onto the driving pin on the tap-changer shaft. If the tap changer aod insulating rod are in the cor rect position, the mark on the insulating rod will be in an exact line with the mark on the top core clamp of the transformer. The op- 'erxH |-rad -*h jcpii t sended f^omr the operating mechanism; none of its weight should be carried by the tap changer. The bolt boles in the mechanism gland should line up with those on the tank or cover flange. Then bolting the mechanism to the flange on the cover, the pointer for the po sition indicator must be assembled under the flange bolt or bolts which are located next to the tank wall. There the operating mechanism ts mounted on the side of the tank, the po sition-indicator pointer should be assembled under the bolt or bolts on the lower side of the tank flange. Start one or two bolts by hand to prevent the gland from ruming, then tighten the others. After completing assembly, check to see that the wedges make the best contact in each position by observing the torque as the tap changer is operated in both directions into a tap position. Starting from an operating po sition, the contact pressure is reduced to zero du riog the first 30-degree movement of the shaft. To shift the wedge to a point entering the next operating position requires about 2/3 of a revolution. As there is little or no fric tion to overcome, the torque will be notice ably small. A 30-degree movement is then re quired to drive the wedge home and to build ap the coatact pressure. The degree of contact of the wedge can als'o be determined by using a 115-volc lamp in aeries with the winding containing the tap changer. (Shorr-circuic the opposite winding or the lamp will not light.) The best position la midway in the band in which the lamp shows light. The design is such that a few degrees either side of the dial marking is per missible. If it is necessary to move the wedge con tact slightly, this is done by means of the vernier coupling. After making the adjust ment, put the bolts through the holes that line up aod recheck positioning as described above. After setting the tap changer, lock in position by mounting the cap and bolts before energizing the transformer. The east-iron cap and folding erank are sometimes removed for shipment. Then this is done, a temporary metal cover painted red Is used over the end of the operating shaft. This cap locks the cap changer on position 1, and it should not be removed until the folding crank can be installed. Do not turn the shaft until the crank is installed. To assemble the c"fa n i t ' i t 1s Vec' e~SsVry- o'sly- fb ` remov e' rhe*T screw through the shaft and replace the screw through the crank hub and shaft. These parts can be assembled only one way.* Fold over cbe crank and bolt on (he permanent cast-iron cap. The temporary cap and three screws can be discarded. Then the tap changer is mounted in a verti cal position, and the operating mechanism is mounted in a horizontal position, a position indicator is provided on the bracket for the bevel gears inside the transformer tank. Then it is necessary to reconnect the drive shaft inside the tank to the operating mechanism, (his internal position indicator must be ob served and set on the same position number as the.operating mechanism. Cap-type Operating Mechanism Older designs of the operating mechanism for a wedge-type tap changer have a cap in stead of a folding handle. To operate the tap changer, remove the two bolts which ' 00 42 Pynnoi Trntformmn *n Pyrno ImmwnmJ CurrtniJimtiing Reteton GeH- 103B cap, remove the cap, and invert it. Fit the inverted cap to the end of the operating shaft and use it as a handwheel to set the tap changer. To lock the tap changer in positioa after setting, replace the cap and bolts. ling between the stub shaft of the liquid seal and the transformer-shaft assembly. Two dif ferent-size slots in the metal coupling permit assembly in only one position. The shafts are also marked to indicate.proper alignment. Operation of W edge-typ Tap Changer* from Floor Laval After completing the assembly, check the contact of the wedges as described in * EDGE- Floor-level operation is accomplished on TYPE TAP CHANGER. large transformers by extending the shaft through a liquid seal on the tank wall to a pair of bevel gears, from which the shaft de scends to a handwheel located at a convenient height above the floor. 1 This seal affords a continuously high de gree of protection against leakage, with the minimum amount of attention and maintenance. A powerful spring exerts a continuous, heavy TEST OF TAP CHANGERS It is good policy to test each tap changer to make sure that the positions are correct and that the voltage steps are progressive. This can be done by applying a low voltage to one winding and measuring the voltage across the other winding for each position of the tap changer. pressure upon the packing material so that no . BUSHINGS periodic tightening is required. The shafts are supported in the housing,by self-Iubricar- ng bearings. The handwheel is equipped with a position indicator and a locking pin which engages only on operating positions, and which can be Replacement bushings for Pyranol trans formers should be ordered especially for use in Pyranol. Since instruction books are ship ped with bushings, only brief, general instruc tions are given here. padlocked. The handwheel ean be provided INSTALLATION ~ with a key-interlock, if desired. See that bushings are clean and dry when Installation of Floor-levol Drive installed. To expose the insulating material The tap changer with cperacing mechanism other than the porcelain to dirt or moisture is to invite deterioration and possible failure in a-St 4taqr J*_vl -tU-Mtf ^ 4.P. the transformer and set on position I. If the operating mechanism and insularing shaft are shipped separately, they must be assembled in the correct position to assure proper operation. Operating mechanisms and rods are identified by the tap-changer number and the last three figures of the transformer serial aumber as shown on the tap-changer nameplate. Some parts are not interchange able between tap changers. Before attempting to assemble the mech -SW iTSC e*--?.*.- ,, v , > a--. . :, v - - - ~ t v -^ _-.-r - Do not attempt to install a bushing in the transformer during damp or stormy weather without providing adequate means for exclud ing moisture. A bushing not having a detachable conduc tor should be install ed in the cover of a rran s- former by first mounting the bushing upon the cover and subsequently connecting the ter minal at the lower end of the cable conductor to the proper lead from the transformer wind- ing. anism and rod, see that the dial indicator on The gasket beneath the terminal cap should top of the bevel-gear drive inside the tank, be in perfect condition and should be made and the position indicator for the handwheel, are on position I. absolutely tight. A defective gasket or leak from any source at this point wi l l a l l o w water Refer to the Outline drawing furnished with the transformer, and bolt the liquid seal and long shaft to the flange on the outside of the to enter the central tube from where it can run down into the transformer. tank. Insert the steel shaft of the handwheel LINE CONNECTIONS drive mechanism into the lower end of the long Vhen connecting bushings to the line or coupling, and mount the mechanism in place external circuit, inspect the terminals or coup on the tank. lings after the connections are made to make Inside the tank, install the short-shaft coup- sure that they are tight. The line cc on. 43 GEW 10 3B P y n n o l Tr*nitarm *n r\d P yrtnot CurrtniJimUin R ttcto n b q s not bring any strain on the terminals which ill cause the joints or contacts to be come loose. Sufficient flexibility in the con necting leads must be provided to avoid mech anical strains due to expansion or contraction which may break the porcelain. The bushings will support a reasonable weight of connect ing conductor, but long spans of unsupported conductor,. especially if out-of-doors, should be avoided. Bushings should be inspected at regular in tervals and kept reasonably free from dust and dirt. In locations where abnormal conditions prevail, such as salt deposits, cement dust, acid fumes, etc., it should be recognized that a special hazard exists, and the bushings should be cleaned regularly to avoid accumu lations on the external surface which may re sult in flash over* wp* riaact M UJOTN* ftfM MIN4KZ A 1i Ti fra* wr I1RIUNDTM ^61- .* 0 CONNECTORS A standard line of terminal connectors for use with both solid and liquid-filled bushings has been developed and these parts may be ordered as accessories to the bushings. These OQRfliUTSiCaMVi-iMOMN*tCMiITLLODTC"rtl X**9"T1MJNCUSD Fig. 9. Carent-Wansformer import connectors provide for attaching cables, rods, tubes, and bars to the various standard bush coil Is right-side up, ms indicated by the word ( ings. "TOP** or the letter "Hj** painted thereon. BU SH IN G -TY PE CURRENT Handle the coil carefully so that the conduc tor insulation will not be injured. ' *. --`.'7 TRANSFO RM ERS -transformers-, ate-Lxhose uc m Connect the leads to the inside terminals '-'of'tire oetl-eT blue kf^nrabi rvg tk at the secondary coil and core surround a bush ters on the inside and outside leads corres ing, the conductor of which forms the primary. pond. This secondary coil and core are located To assemble the current transformer into either in an adapter on the main transformer cover or in a cradle suspended from rhe inside of the cover. These current transformers may be used to actuate either relays or ammeters. See the nameplate on the secondary outlet for turn ratios. the bushing adapter, remove the top of the adapter, fit the transformer into place, and replace the adapter top. Bolt the top down squarely to compress the gasket evenly. On double-section tanks it is sometimes necessary to remove this type of current trans INSTALLATION former from the underside of the cover for ( c Bushing current transformers are usually shipped completely assembled in the power transformer, or ar least in place in the highvoltage bushing adapters. It is then only nec essary to inspect them to see that they are dry. If evidence of moisture is found, the cur rent transformers must be removed and dried by hot air, not exceeding a temperature of shipment. In such cases, reassemble with the end marked " TOP*' or " H j " uppermost in ac cordance with Fig. 9* The insulating rube can be pushed up while tightening the jam nut. New place washers are furnished and should be bent to lock in place, as indicated. Main tain rhe 3/S-inch overhang of the current transformer inside the supporting place open 90 C. If the bushing ru t-- nf^ff^e ing. nil-- CONNECTIONS AND POLARITY J L_ _ _ _ ed separately, assemble it in place with in Insulate all leads not in use from ail ocher sulation as shown in Fig. 9* Be sure that the leads and ground. Do not allow the 1 00 44 1 P y n n o i T t t n t f o r m t n a h J P yra n o l I m m o n o J C u m n t- lim ii m g fta a e io rt GcW- /0<?J circuit of a current transformer to remain open. NOTE:- The Pyranol must be circulated and It must be closed through a burden or by the cooled at all times on an excited transformer short-circuiting links provided for the pur regardless of whether or not the transformer pose. is carrying load. The relative instantaneous directions of A special Pyranol c o o l e r s generally fur primary and secondary currents are shown in nished as well as a pump- and motor. The Fig. 10. cooler is designed for outdoor installation, PYRANOL IM M ERSED, and can be installed in either the vertical or horizontal position. A IR -P R E SSU R E -C O O L E D The piping connection should be such chat TRANSFO RM ERS These Pyranol immersed transformers are cooled by a free-air discharge applied ta the cooling surface* Air for cooling the trans former is supplied by a unit blower and motor or by small, weatherproof, outdoor fans which may be provided with hand or automatic con trol. All equipment is designed for outdoor ser vice. The fan motors require the care usually given such apparatus. If thermal devices are furnished for fao control, they are adjusted at the factory and should not be disturbed. If changes need to be made, recommendations should be obtaioed from the nearest Apparatus Sales Office of the General Electric Company. Then fans are not in use, they should be operated periodically to make sure they are in satisfactory condition. the water pssses through the cubes in the op posite direction to the Pyranol flow. This is essential in order to obtain maximum effi ciency of heat transfer. It is also essential that the water pressure be kept below the Pyranol pressure to prevent any water enter ing the Pyranol should a leak develop In the cooler. The coolers in most cases are de signed so that this difference will always exist when rated Pyranol flow and water flow are maintained. One end of the cooler is provided with a floating head, and sufficient space should be allowed in the piping for the removal of this bead. Then forced-air coolers are used instead of water coolers, special instructions will be furnished. The qaantity of Pyranol circulated has a direct bearing upon the heating and tempera ture rise of the transformer. It is very de sirable, therefore, that the inlee and outlet FORCED PYRANOL COOLED temperatures of the Pyranol be measured and TRANSFO RM ERS In forced Pyranol cooled transformers, the Pyranol is cooled by forced circulation through an external cooler. recorded to check the quantity of Pyranol flowing. The top Pyranol s cooled about 15 C during passage through the cooler and the water temperature increased about 5 C. Usually the water flow is 50 percent greater than the Py ranol f l o w . The cubes in the cooler should be kepc clean. To clean them, remove the cover plates from each end of the cooler and clean the in side surface with a wire brush. The external surface of the tube bundle may be cleaned by flushing out with a vola tile cleansing fluid. The tibes must then be dried by passage of hoc air through this se c tion of the cooler. Coolers may be tested at a pressure of 100 lb per square inch to determine whether there F ig . 10. Schematic diagram of bushing transformer, showing method of marking leads and tapping secondary wiodtng is any leakage. It is possible to cool the Pyranol from a bank of transformers by using one 00- 45 t GEW- IO Q3B PyranoLT/Bntformwn and P y n n o l Ctfrrvn^/imihn^ /?efors one Pyrmaol pump, bat this practice is Qot GENERAL PROCEDURE (With ither favored. In sach installations, equalizers N o. 1 4 6 7 or No. 1 4 8 8 Pyranol) ust be used to obtain proper Pyranol distri bution, which is difficult to obtain and as certain. Also, in case of trouble in one unit, damaged Pyranol would be* pumped directly into the good transformers. A separate cooler aod Pyranol pump for each transformer are Tecomreesded. The following instructions concerning re pairs presuppose chat a transformer contain ing No. 1488 Pyranol has.been prepared for antankiog in accordance with recommenda tions obtained from the General Electric Company. 1. Filter the Pyranol and store in thorough IF TRANSFORMER D0E5 NOT OPERATE The procedure to be followed if a trans ly dry, elean, and oil-free containers. Ail pumps, filters, and piping used in this pro cess must also be thoroughly clean, dry, and oil-free. See previous instructions covering former fails to operate depends on which of filtering. two Pyrasols, No. 1488 or No. 1467, is used 2. As soon after the filtering as possible, in the transformer. Transformers shipped prior send a one-quart sample of the purified Pyra- to November 20, 1944 were filled with No. 1488 ool, together with the serial number and rating Pyranol. Transformers shipped after this date of the transformer, and the results from the were filled with No. 1467 PyranoL Trans-* examination of the original Pyranol sample formers containing No. 1488 Pyranol require (if Pyranol is No. 1488) to the Field Engi different handling from those containing No. neer, General Electric Company, 100 Vood- 1467 Pyranol. lawn Ave., Pittsfield, Mass., so that analysis To determine which Pyranol the transformer contains, refer to the transformer nameplate. Nameplates of transformers containing No. 1467 Pyranol bear this number preceding the quantity of Pyranol shown in the tabulation of weights. No Pyranol number is given on the nameplates of the transformers containing and recommendation for repairs can be made. 3 Thoroughly clean the top yoke and top core laminations to prevent tackiness which would binder reassembly. No. 1478 Pyraool is the most satisfactory cleaning agent. Naph tha may be used, but presents a fire hazard. 4* Until repair materials are available, store No, 1488 Pyranol. Should there be any doubt cbe core and coils in a clean, dry room. Pyra as to the Pyranol contained in the transformer, nol film becomes acky, making dust or dirt handle it as if it were No. 1488. difficult to remove. If the core and coils have TRANSFORMERS IMMERSED . IN NO. 1 4 8 8 PYRANOL * If a transformer filled with No. 1488 Pyranol fails to operate, it is recommended chat the unit be sealed immediately from the at mosphere and the nearest General Electric Apparatus Sales Office notified. Take a sample of Pyranol from the top of the transformer and inspect it for discolora not been disassembled, resubmersioo in the filtered Pyranol is recommended, provided an adequate container is available. 5. Then reassembled, Pyranol transformers can be dried by the short-circuit method. (See DRYING PYRANOL TRANSFORMERS.) Dur ing drying, the top Pyranol temperature should be from 90 C to 100 C. JUNCTION BOXES tion aod the presence of water. A transformer is sometimes equipped with a Keep the transformer sealed; do not remove junction box, a metal housing that completely the interior for examination until recommen encloses the connection between the trans dations are received from the General Elec former bushing and the cable. A junction box tric Company. should be kept filled to the-proper level with TRANSFORMERS IMMERSED IN NO. 1 4 6 7 PYRANOL the insulating medium specified: Pyranol, oil, or petrolatum. For the lower Voltages, air is sometimes used. If the transformer coo tains No. 1467 Pyra The junction box can usually be removed nol, it may be handled in the same manner as from those transformers so equipped, to facili a transformer containing 10-C oil with excep tate lowering the transformer tank into the tions as noted below. vault. I t 00 46 P yrtn o l T n n ifa rm m *rtd P yrtnol tm m on oj C um nl-lim tlinf P#cton G EH * tQ $ 2 3 Before making the connections refer to the special instructions furnished with the cable end or cable terminal TRUCKS Bearings, whether bushed or of the roller bearing type, have a 1/8-ineh pipe plug pro vided in the end of the journal. To lubricate the bearing, remove the plug and insert an Alemite fitting. Trucks are shipped with the bearings filled with grease, but the bearings should be inspected and refilled from time-totime to prevent corrosion. LOAD-RATIO CONTROL Transformers which are equipped with loadratio control, that is, those arranged, to permit a change of taps without disconnecting the load, require the addition of a number of mech anical parts, and call for special electrical connections. Their installation, therefore, needs special attention. For this reason, all such transformers are covered by a special instruction book which should be thoroughly read before any attempt is made to assemble or operate such transformers. RENEWAL PARTS Then ordering renewal parts or Pyranol, or when requesting information regarding a par ticular transformer, always state the serial number of the transformer. This number will be found on the nameplate of the transformer. On large transformers, it will also be found stamped on the cop core frame; the top band of (he tank, and on the cover directly above the number on the tank band. A sketch show ing the exact location of coils, insulation or other pans required will greatly facilitate the filling of the order. This sketch must always state which side of the transformer is shown. Any additional information as to the elec trical or mechanical construction, operation, or installation of a particular transformer may be obtained by application to the nearest 'aids office of the General Electric Company* men tioning the serial number and the rating^ 00 47 .S -- 48 ac= GENERAL ELECTR Pyranol*, the cooling and insulat ing liquid of General Electric Pyranol transformers, isnonmflammable ON THE FIOOR in a motor room, Pyranol trans formers bring primary power right to the load. From this one fact spring many benefits to users , o f these transformers--direct benefits, including substantial savings realized not only during installa tion but, in most cases, throughout subsequent operation as well. On these benefits is based the industry' wide aeceptance of G-E Pyranol transformers, an acceptance which is best indicated by the fact that more than 7500 units, ranging in size from to 12,000 leva, and totalling more than 2,000,000 kva, have been installed. This bulletin outlines the principal advantages o f General Electric Pyranol transformers and shows typical installations, selected from the wide 'range of price to which these transforme: s are applied. *Xagiatmrod trad*m ark for G-E aakmral. UNDERGROUND-- with no costly enclosing vault re quired-- Pyranol ' transformers eliminate long runs of secondary copper. OVERHEAD and out of the way, at the center of the lighting load --in a modern industrial i plant. - - 0 - 0 9 CYRAN OL TRANSFORMERS / For Convenient, Economical Installations Indoors or Outdoors r r CC Pyranol transformers are ideally adapted for indoor installations in apartment, office, hospital, hotel, school, and theater buildings, where the noninflammable characteristics of Pyranol con* tribute to increased safety for occupants. In addition, contractors and builders find that Pyranol transformers make possible many direct savings in time, materials, and expense in such installations. Contractors can install Pyranol transformers with only a simple protective metal fence or grille, and yet meet the full requirements of the National Electrical Code, whereas the use of oil*immersed equipment usually requires the construction of fireproof enclosing vaults, together with sills for these vaults sufficient to confine all of the liquid contained in the largest transformer in the vault. In addition, doors or ventilating ducts leading from the vault into the building may re* quire special safety construction. Obviously. P y ranol transformers make possible a great saving in initial installation cost in such eases. Because of this freedom from installation re strictions, Pyranol transformers can often be in* stalled in out-of-the-way locations, usually close to the cm 1er of the electrical load. By eliminating long--and expensive-- runs of secondary copper, they not only effect important savings in this criti cal material, but also pay daily dividends in the form of improved voltage conditions for lighting, appliances, and similar equipment. These same factors also make Pyranol trans formers a money-saving selection for many outof-door installations. The degree o f safety these units provide makes it possible to save valuable outdoor space by placing them in spaces formerly unused because they are not suitable for oilimmersed units--on roofs, for example. In like manner, pole-type substations can frequently be eliminated from urban areas by installing Pyranol units in out-of-sight locations suitable for only these noninfiammable units. ! i \ ( C l Ic F19 1 . Sin g l*.p K ot* Pyran o l lronifo"ner ih o --tg lo-olioge ro o t. a ll bwthmgt R ar ing 25 Ua, 240 0 4160 Y (0 120 2 4 0 *otft Fig 2 . Sin g l*.p hate Pyranol tron*fom** h diaphragm on co*** (homing h.n- vol rage ron^-woll buihingi Raring SO W*a. 2 4 0 0 4160 Y to 1 2 0 . 240 *oiri - 00 50 2 INDUSTRIAL PLANTS SA' formers can be installed dose to the load, elim inat ing the cost of long heavy-copper secondary runs. These transformers require a relatively small floor space. In m any cases, they can be located in convenient out-of-the-way places which do not provide adequate space for installing oil-immersed units in vaults. M any users plaee them on overhead beams when floor space is at a premium. These combined savings in installation cost alone often mak them a money-saving choice for indoor installations. PY R A N O L TRA N SFO RM ERS were selected by a Cal* ifom ia industrial plant because the use of oil-filled units would have required the digging and lining c f an underground vault in the production area of the plant. Furthermore, there were savings in in* stallation time and costs. An increasing number of industrial-plant man agers and electrical superintendents are taking ad vantage of these distinctive economic benefits that Pyranol transformers offer for many types of duty: INSTALLED QU1CXLY AND INEXPENSIVELY Because Pyranol transformers can be quickly and safely installed indoors without a fireproof enclosing vault, an open pipe railing often con stitutes the only protection required. The trans POW ER WHERE IT IS NEEDED Because Pyranol transformers can be installed where they are most needed--at load-center points-- they make possible the most economical distri bution of power to lamps, motors, and other factory loads. Plant engineers call this "load-center distri bution"; they know that by bringing primary power to the center of the electric load they gain savings in reduced secondary losses. They also gain by improved voltage conditions, which enable electric equipment to operate at higher efficiency. IDEAL FOR P IA N M X P A ^ S IO N PROG RA M S The distinct advantages of Pyranol transformers make these units valuable to plant superintendents who are faced with a pressing need for increased power capacity. New installations can be madt quiekiy at plant load centers. Their flexibility o application also permits locating them where the) will facilitate the flow of materials. In addition, the load on esscing circuits cat sometimes be greatly increased by installing Pyranol transformers at load-center points tha are not suited for oil-immersed equipment. Ii some cases the capacity of factory lighting am power circuits has been doubled, and even treble? by dividing them into sections and supplying eac section from its load center with a Pyranol tram former. 00 51 4 O lT H PYRANOL TRANSFORMERS Fig. 3- 5 n gle-ph a**, 150-heo Pyronol iron* formar with eo^eMype high-rolfoge bwihingi and diaphragm on tank w ail I Fig . 5. * 71ire**pho*e, 1 30*h*o Pyranol trant/omier, with high**oltogt terminal Compartment arranged for conduit connection Fig 4 Single-oha* 750-k*a Pyionol tion\. forme*, ihowing to w *o lto g e C0"**M"C bulhing Fig 6 Smgl*-ohoe, 333-k*0 Pyranol tionyforme* 00 52 5 FOR CONFINED LOCATIONS THE EXTRA DEGREE OF SAFETY' PROVIDED BY PYRANOL TRANSFORMERS IS ESPECIALLY VALUABLE NETWORK V W i n -- SIDEWUK AND STREET The duty imposed upon a network transformer m ay be severe, because the inherent operating char* acteristics of low-voltage a*c network systems usually require secondary short circuits to burn themselyes dear. Furthermore, because there is no means of automatically removing an individual network transformer from the power supply, the unit may be subject to high overloads and high temperatures. Because of these' conditions, and because underground installation reduces the accessibility of these units, the extra safety offered by the noninflammable characteristics of Pyranol transformers is especially desirable for this type of service. MINES AND TUNNE15 For meeting the strict safety requirements for mines and tunnels, Pyranol transformers are often a wise choice, because neither Pyranol nor its gases can be ignited by an internal arc or an external fire. Although these safety features alone often result in the choice of Pyranol transformers, users also find that the savings which attend installing' them in above-ground substations can also be obtained by using them for underground service. Placed at the load center in underground areas, they save costly vault construction and shorten runs of secondary copper. This means reduced i copper losses and better voltage regulation. Because the Pyranol transformer is completely sealed against the entrance of dust and moisture, it is ideal for underground service. The ease with which Pyranol transformers can be installed and removed makes them especially valuable to mine operators when changing loads make it necessary to move transformers to new locations. RAHW AY CAR5, IOCOMOT1VE5, DOCKS, SHIPS The same considerations that affect the install; tion of transformers in mines, tunnels, and sub ways naturally apply to installations on railroad cars, locomotives, docks, and ships, where the advantages of Pyranol transformers are similarly important. Since 1933, Pyranol transformers have beer, used, with a remarkable service record, for heatinc and lighting railway cars. fig 7 P yiano i ftanifotme's .n underground nine >oul' (cenfe) *n o-c net~0'* Owl*, (tight) being in u o llcd in ia if* a y lacomot>*e UU 53 b c V EXTERIOR CONSTRUCTION IS BASED ON PROYED GENERAL ELECTRIC DESIGN FEATURES RELIEF D IAPH RA G M (under protecting cover) provides an opening foe release o f g u c s vgenerated ia event of aa jotera el e re GASKETS of rcsilienr com p o sition-cork arc clam ped be* r e to sm ooth, w ide, flat gasket surfaces. TANK AND COOLING .TUBES are made o f corrosion* resisting, copper-bearing steel,j ,- ^ ..- j, , ' -'5 *V'*-rr-T HANDHOLE COVER caa be removed to p r o i. vide easy access to internal connections. , CLOSELY SPACED HINGETYPE COVER C1AMPS, or cover bolts, hold the cover firmly ia position, compressing the cover gaskets evenly to form ^a liquid-tight and airtight joint. SAMPLING DEVICES provide for ready sampling of Pyranol. LOV-VOLTAGE CONCEN TRIC BUSHING. Two bladeterminals enter the tank through a single bushing- This m esas small gasket area and reduces the possibility of leakage. Fur therm ore. because they arc concentrically positioned, the magnetic fields of both te r minals areneutndued.This pre vent! tank losses, yet perm its a simple, dependable conscrucu p n , The neutral rrud (a shown at the left of the Idw -vdltagF' bushing. 8 ' a l l o u t s i d e s u r f a c e s o f t a n k a n d '* COVER are prepared for painting bjr sand- o r sbot-blastiag. A prim ing coat of Glyptal' basic lead chrom ate is first baked oo the tank, L follow ed by a baked-oa finish coat of bluegray Glyptal paint. This provides a tough and abrasion-resistant finish. r DRAlN PLUG 1 *C- rrgiittrti/ trttJtm^rk Fig. Sinn Ie-P h ate 75-lcva Pyranol frnhiiomief --no 54 DESIGN FEATURES < - * -Fva.v9.--'?Camel*fe .-of-jJahyg, 240P_',._.- . *_. - voli fpn/orm*f having Sotroko* ' comvrwcTia n ' * `~~ ' * Fig. 10. A u flib l*d Cor*-9nd*<oiU of linglphoM , 333-livo pTranol rrantiorvnr, thawing ' `'`'SpnairBiV'OorrtxruiTin-ict-banji in - , Operating experience since 1932 has proved the dependability of Pyranol transformers under widely varyir.; conditions of service. They have all the features that have made liquid-filled transformers the most nearl; trouble-free electric apparatus in service today. For example: A. They have high dielectric strength at both normal and impulse frequencies--important as a safeguart against damage to transformer from voltage surges caused by switching operations or by lightning. B. The heat-storage capacity inherent in liquid-filled transformers makes Pyranol units ideal for sus tained emergency overloads. C. Their pressure-tight tanks protect vital parts of the transformer against moisture, dust, dirt, an sabotage. D . Immersion of the transformer interior in the liquid Pyranol prevents drying and cracking of the wine ing insulation, and retains the high dielectric strength originally built into the transformer. CORE AND COILS The internal construction follows closely that of corresponding oil-immersed G-E transformers de scribed in Bulletin GEA-2600. This means that the benefits of Spirakore con struction. using cold-rolled high-permeability silicon steel core^, are likewise being made .available for single phase Pyranol transformers as large as 500kva. Figures 9 and 10 illustrate typical construe tions for small and large kva ratings, respectively. *C- trd*'rtmrk TANK All Pyranol transformers are completely seale to prevent evaporation of the Pyranol. A frang-.h diaphragm, described! on the succeeding page protects the transformer by relieving overpress-: in event of an internal arc. Sampling valves permit ready sampling of l Pyranol. Because the high specific gravity < Pyranol causes most contaminants ;o float, the: sampling valves are located near ' ' ' level 00 55 tRANOL TRANSFORMERS Fig. 11. Co*f-and-coil am m b ly for tkreo-phoie Pyrgnol tron> PYRANOL Pyranol is noninflammable, chemically stable, and inert. Tests and field experience prove that it shows no development of corrosive acidity or sludge even after long periods at high tempera* ture*. Pyranol and its vapors have no effect on the metals and other materials used in Pyranol equip ment. The life of these materials, when immersed in Pyranol, is approximately the same as that when they are immersed in oil. The dielectric strength of Pyranol is of a high order. Standard commercial-test values higher than 30 kv are customarily obtained. Like insulating oil. however. Pyranol follows the usual gas-solu bility laws. Exposed to wet air. it will absorb some water and. for this reason, every care is taken to assure the airtightness of the tank. Liquid Pyranol can be handled at room tem perature without fear of toxic effects. During the twelve years' experience of the General Electric Company in manufacturing Pyranol, there is no record of any workman's requiring first aid or medical assistance because of Pyranol vapors. Because of the nonoxidizing characteristics of Pyranol, filtration of the liquid will in general be required less often than is required with insulating oil. If it should become necessary to filter the Pyranol used m transformers, it can be done in a manner similar to that used in filtering insulating oil: that is, by the use of either a filter press or a specially arranged centrifuge. BUSHINGS The bushings furnished on Pyrano I transform er are pressure-tight and are located in the cover or in the tank wall. The standard arrangement for any particular rating is shown in the tabulation at the bottom of each data page '12 to 1 00 56 VENT PIPES AND CAS ABSORBE* Pyranol transformers under normal operation produce no ( u n . Under abnormal conditions, in the event of an arc inside the tank, fases will be generated by disintegration of Pyranol. Because these fases are noninflammable, it ia practical to provide a relief vent in the form of a frangible diaphragm. This diaphragm, regularly furnished on Pyranol transformers above 25 kva, ia designed to burst at- an internal pressure of 12 pounds per square inch, and meets the National Electrical Code's requirements for transformers installed in well-ventilated areas. Y IN T PIPES . The upper steel clamping ring, which fastens the diaphragm to the transformer, is provided with tapped holes to permit the easy attachment of a vent pipe for discharging gases into the outside air, into a chimney, or into other ventilating flues, (See Fig. 13.) In some cases the Code requires that a vent pipe be connected to such a ventilating flue for units above 25 kva installed in poorly ventilated places. It ia recommended that the diameter of the vent pipe be no smaller than the dear diameter o f the frangible diaphragm from which it ia es* ] tended; that is, either 6 or 8 inches, as shown in (Fig. 12). It should be made of material not lighter than No. 16 gage, and there should be as few bends as possible so that gases can flow freely through it. Provision should be made for inspecting the diaphragm and for removing any moisture that may accumulate on it; proper arrangement o f the pipe will generally prevent such accumulation of moisture. _ -- ox h o le s / c r ^ o - U ^ - '3 p I 9/16" drill ______ J i * Vg -13 ~ hex ho b o lts ~" CiornpTh<j m ,Flant]e F o r - i n c h O i o p K r o ^ m -v S ix holes 20*r ' ,/2"-3 ta p 3x_ h o l e s 20* P */i d r i l l Fig. 13. Clot we o pKragm a iw m b lr as S ix V 'g-13 h e x ho bolts Clornpinq Binq V ent-pipe flonqe F o r Q -in ch DinpHroqm Fig. 12. Derail of flange for *#nt diaphragm and *nt pt'o 00 57 C D R PYRANOL TRANSFORMERS GAS A B SO R B : * m Where it is not economical to install a vent pipe, a ( U absorber can be installed on the ftanfe over the frangible diaphragm, as shown in Fig. 14 and 15. It is designed to absorb the gases produced by arc disintegration o f part of the Fyranol in the transformer; 2 per cent of the Pyranol in distribu tion and power transformers, and 5 per cent for a-c network transformers. The absorber has s steel tank with a mounting flange at the bottom for attachm ent to the relief vent of the transformer tank, and, at the top, a separate diaphragm with a protecting cover. This tank contains several perforated-bottom steel trays, fastened together, one above the other, by a center bolt to facilitate assembly. The bottom tray is filled with chipped marble, and the upper trays contain soda lime. Should an internal arc generate sufficient (as to break the diaphragm on the transformer, the gas will pass up into the tank and be absorbed by the soda lime. Any liquid C carried by the gas will be stopped by the chipped marble and will drain back into the transformer. If the quantity of gas exceeds the absorber capaaty, the top diaphragm will break to relieve the pressure. PPU CATION Under the provisions of the 1940 National Elec trical Code, either vent pipes or absorbers may be r^ uired* for I"given 4nstaUatian:Ifi&uepjdgJfC*v tors are: the energy available in the circuit to which the transformers are connected; the type of pro* teccive equipment; the area, volume, and ventila tion facilities of the room in which the transformers are installed; the number and proximity of em ployees in the area. ? When absorbers are used, it is recommended that one be used with each transformer! If a single absorber is connected to two or more transformers by means of a common header, it is possible that if more than one transformer should experience trouble simultaneously, the gas produced might ex e ceed the capacity of the one absorber. The absorber should be inspected at Intervals to see that the diaphragms are intact and that the compound in the absorber has not become damp or caked. i1 Fig 15 Thr**-ohat 50-t-o Pvarol iic n if o r m c f w i t h got o o t o t b c i _____________________ 58 _ 000093 Monsanto 9+GakiCCmtmZAiS Otvtsipm M enunto Company BOON LmPafr. BOwlavtrd S t. lo v u . U n to u fi 63)66 3 u ; Oxford 4 -1 0 0 0 %*i M arch 3, 1969 i M r. Edward L-. Raab General E lectric Company 100 Woodlawn Pittsfield M assachusetts 01201 Dear M r. Raab: On F e b ru a ry 24, the San F ran cisco Chronicle carried a m ajor feature about "a menancing new pollutant" found in the San F ra n cisc o Bay a re a . The article was based on m arine life r e se arch c a rrie d out by Dr. Robert Risebrough of the U niversity of C alifornia. It stated that residues of polychlorinated biphenyl (PCB} w ere .killing certain m arine birds and posed a long-term th rea t to humans. This sto ry has caused considerable comment on the West Coast ` X r--V-.. Monsanto m anufactures polychlorinated biphenyl and m arkets it under our A roclor trade nam e. We, therefore,'w ould like to present some additional facts. The work done by Dr. Risebrough dates back to e a rlie r research by other scien tists to analyze the amount of pesticides in wildlife, soil and water.. The initial pesticide research was extrem ely difficult since any search to detect m aterials in the p a rts-p e rbillion range also brings out other "interferring" substances. 20 59 -2 - Several years ago, two Swedish scientists a; Stockholm U niversity's Institution of Analytical Chem istry, Professor Gunnar Widmark and Soren Jensen, reported they.had identified the other substances which w ere appearing during analysis of chlorinated pesticide r e s i dues. They said some of the m aterials were polychlorinated biphenyls *o r PCB. The amount reported was in the p arts-p er-b illio n range, or le ss. Since PC B 's are not "broadcast" or spread around the land as a re p esticid es, the scien tists theorized that the source m ust be the in d u strial w astes of PCB u sers. Dr. R isebrough's m ore recent work reports the identification of PCB, along with DDT and DDE pesticides, in the tissues of birds and fish on the West Coast. The conclusionsof these scientists are puzzling from several aspects. Polychlorinated biphenyls are stable chemical compounds which are essen tially insoluble in w ater. Their use does not make them easily released into the natural environment. A principal m arket for PCB is in electrical applications where they are used as insulating fluids for tran sfo rm ers and cap acito rs. In th is use, the chem ical is com pletely sealed in m etal containers. Another m arket is for heat tran sfer applications where the PCB fluid functions in a closed system* P C B 's are also used in. sev eral "plastic, type" applications. Here the chem ical is incorporated into the polym er as an intg ral p a r t of the solid m a te ria l. This applies w hether the polymer is used as an adhesive, an elasto m er or a surface coating. The Swedish and Am erican scientists also imply that polychlorinated biphenyls are "highly toxic" chem icals. This is simply not true. The toxicity of any m a terial, w hether it be chem icals, drugs, natural p lan ts o r even foods, is relativ e. Compared to the thousands of industrial chem icals and home products, PCB's are not toxic unless they are m ishandled or m isused. During mote than thirty years of U. 5. production and use, cases of any toxic effect have been extrem ely r a r e - - and then only where the sim ple precautions recom mended for uSe were not followed. 20 -3 - To our knowledge, polychlorinated biphenyls are not sprayed or dusted on crops, woodlands or any other areas, as are pesticides. It is, therefore, not only puzzling, but extrem ely difficult to con ceive how com m ercially produced PCB can show up in wildlife as DDT and other pesticides appear to be. This raises the question w hether the substance identified in the Swedish work, and now in C alifornia, is actually PCB -- or whether they are m a terials which, due to the m etabolism of other m a terials in the m arine environment, ap p ears to be PCB. Unfortunately, even though techniques for analyzing tissue samples have become quite p recise, the ability to analyze the possible im p act of naturally occurring substances in the food cycle of living organism s has not made comparable advances. M onsanto has a re se a rc h program to confirm the identity of the compounds reported to be PCB by the Swedish and California sc ie n tists. We also cooperate, on a regular basis, with federal, state and university lab o rato ries in their analysis of chlorinated hydrocarbon residues. Additionally, Monsanto w ill continue to exercise the highest degree of control in its m anufacturing, shipping and storage of PCB -- as we do with all products. In the functional fluids m ark et, we have c a rrie d out a program for sev eral years for the reclam ation of used P C B 's to avoid disposal of these valuable m a te ria ls. The source of the m arine life residue identified as PCB is not yet known. It will take extensive research , on a worldwide b asis, to confirm o r deny the initial scientific conclusions. We will keep you advised of our own re se a rc h and are available to answ er questions as they m ay arise. Very truly yours, ua.\ Elm er P. W heeler Manager Environmental Health /ecd 20 UU095 COMPANY NI LA P At K, CLI VI LAND, OHI O 4 4 1 1 2 . . A n* CM* 21* , 2 p - 3 3 7 c . . . LAMP DIVISION R E C E IV E D M arch 17, 1969 D r. E. K. K lin e NEW YORK OFFICE Dear Ed: MAR 19 1969 EDWARD U. KUNE M. D I have b e e n i n te le p h o n e c o n v e r s a tio n v i t h D r. Emmet K e lly an d Ed V h eeler, M edical D ire c to r and In d u s tria l H y g ien ist re s p e c tiv e ly o f M onsanto C hem ical Co. i n S t . L o u is . They a re -c b n c e m e d o v e r some rec e n t te c h n ic a l and newspaper a rtic le s re la tin g to th e presence of p o ly ch io ro b ip h en y l p ro d u cts in w idely dispersed f is h and y i l d l i f e . The in c r e a s in g i n t e r e s t i n t h e e f f e c t s o f p e s t i c i d e s , 4e s p e c i a l l y c h lo rin a te d ones, on th e ecosystem has raised th e q u estio n o f what adverse e ffe c ts , even th e p ico -g ran q u an tities of th e p o ly ch lo ro b ip henyl compounds found i n b i r d s ' liv e r s and eggs and in f is h l i v e r s , can have on th e norm al developm ent o f th e se s p e c ie s . A t p r e s e n t, th e r e i s l i t t l e t o i n d ic a te w h eth er th e s e compounds have been d i s p e rse d a tm o s p h e ric a lly o r have beer, w aterborne. The G en erel E le c tr ic Co. p u rch ases i t s c h lo rin a te d p o ly p h en y ls from M onsanto Co . , m o d ifie s i t , end u se s i t under th e name o f P y ra n o l. I b e lie v e th e m ajo r a p p li c a t i o n f o r t h i s m a te ria l in o u r Company i s as a d ie le c tric fo r c e rta in types of transform ers and c a p a c ito rs. D r. K e lly was n o t so u n d in g a to c s i n , b u t th o u g h t t h a t th e p ro p e r .p eo p le in our o rg a n iz a tio n should be a le rte d to th e p o s s ib ility th a t *qiie s a T p * o f '-' t 'P i/e-m a f want* 'Some ^atv em p t- t o d e te rm in e t o what, d e g re e th e Components u s in g t h i s m a te r ia l d i s charge i t as e ith e r liq u id o r so lid w aste, or as an a i r contam inant. I am a t t a c h i n g s e v e r a l a r t i c l e s on t h i s s u b j e c t w h ic h y o u may w i s h 1t o p a s s on t o t h e p r o p e r p e r s o n o r p e r s o n s . One i n d i v i d u a l who i s h i g h l y know ledgeable a b o u t th e u se s o f P ym nol is A. Baab a t th e L a b o rato ry i n P i t t s f i e l d , M a s s a c h u s e t t s . D r . Baab may b e a good p e r s o n t o co n tact f ir s t. Best personal regards A ttachm ents c c : JV L oney, K.D. I . M atelsky In d u stria l H ygienist #116. 20, 2 0 62 0 mC v O L . 2 1 6 . O C T O B C R 2 1 . I C S 7 ^ irrm in * ^ and the eom plrtal chain relra-wl attached by the phrnylalanyl (RXA amply by starving ribosonjo-niHNA complex to vhicli it is bound for threonine. With (his ho has been able to define the (RXA moleeulc carrying the List amino-aciil condition nrrereary for termination; incubating the * Thcrtt mu*t be a nscehar.iijr. for reading complex under suitable conditions with or without icrminaliiig codon (three oodons UAA, UAG, threonine or supernatant enzymes showed that to get * ('(A can code for chain termination) and rlcaving release it is nrreeary buL not sufficient to oomplcte the **u-i prpiidyl-fRNA bond. In iozJtm. Itioplys. peptide by incorporating threonine and that release m (a* at., 8. 773 (10G7) he de&cribr* an experimental is not solely dependent oo the transfer enzymes * md^vtaed to give a rapid assay for chain tormina* required to move the ribosome from the threony! oodon in Proc. US A\K. Acad. ci\, 53, 1144.(10G7) to the UAG terminating eodon. Release docs, however, , ttfurt* the discovery of an enzyme required for depend upon the presence of a supernatant factor. This ,.w**riiiv factor, with a molecular weight of between 40,000 and ' for termination employs the RXA from 50,000, sediments between 3*55 and 4*55. Because iu ,ilrr mutant of the coat protein gene of the RXA releasing activity is not affected by RXase, it cannot * irfophagc 17. This mutant has an amber codon, be an RXA-protein complex. Apparently the substrate * (; t ( (he position of the sixth amino-acid, a glut*. of the release enzyme is the riboaomo-mRXA-peptidyl .w residue, in the 17 coat protein molecule, in a (RXA complex so that it must act directly at the ribo (nr system the mutant RXA directs the synthesis some and not cleave the (RXA from peptidyURXA , , jiull X-terminal peptide of the coat protein with already released into the supernatant, which was the v n|iirnce X-formylmct-ala-scr-aspn-phc-llir; the other possibility. it amino-acid in the opat protein is glutamine, but Capcechi does not yet know whether the release a the mutant RXA the amber codon causes pre* enzyme works alone or in conjunction with other factors, .urn* termination of synthesis and the release of the in particular a hypothetical chain termination (RXA -lap-jttide. The great virtue of this system is that which reads the termination eodon but docs not carry >nt<*rminsted peptide still attaebed to the pcplidy.'- an amino-acid. Many people, including Capcechi, have t V\ ran be distinguished from the terminated peptide searched is vain for such a (RXA species, and although id from the (RXA and the amounts of each negative results ran never exclude the possibility that Mured Furthermore, starving the system for any one such (RXA ezists it is reasonable to think about i the air amino-acids in the peptide arrests the trails- alternative models in w*hich the terminating eodon machinery before it reaches the UAG oodon so arc read either by the ribosome or the release enzyme mirution ean be controlled. or in which nonsense oodons function simply because Kijiloiting this procedure, Capecchi isolated a they cannot be read at all. Further characterization pin of ribosome, mRXA and pentapcptkle of the release enzyme oould veil decide the issue. -*. --* - -fv "At. rinated Hydrocarbons In i I' 0 C HOLMES 1 H. SIMMONS Folychlorobi phenyl compounds have been detected In British wildlife. In birds* livers and eggs they are often In greater quantities than organochlorine pesticide residues. Polychloro- biphenyls are known to be toxic, and their detection in wildlife 1 0 'C. Ta t t o n raises the question of the adverse effect they may have. iI `n**i *( Government O emfct. mrs wild birds' ogg or tho livers of British wiMIifo an '.Z * fas-liquid chromatography (GLC) using *-^nt,i-enpuirs doLection, poaks oarverponding to such 'VuMc-lJuring pesticides as BMC, dirldrin and DDT, and nmuibolitos and breakdown products, oftrn apponi * resultant chromatograms. Thono pnaks sometime* I#|^-,it amounts wliich are significant from a toxienlo- * of view, but tin* sensitivity of morforu instni- T*1*slo onablea oomplntrly insignificant amounts to b* t<il. Anslyau ooi.eemed with tho determination ol i**S'"*;i,lof,in# posticidos in wildlife, hnwrvrr. Iinvc long i"'1 that it is not unusual for an additional m*iu "" ny os ton ponks'. anrraapandiiig tn uuidriiL ilicd also to appnor on throe chmmnlncram***. ' * known of tho structure and o rig in of tliisw* rum* u" * hut Roburn1 isubtilnd Iksl thoy are orgiutn* chlorino in nature, with a substantial ehlorins content, and consequently poMrsi electron-capturing proportos. On silicone or 'Apwinn' GLC eolurans. tbs sanos of peaks fur ihreo enmpuunds normally begins at the pnim at whirh pp`*TD and pp'.DDT art emerging from ilio columns and orlond. in terms of retention tiroes, to four or fivu times Uuit of pp'-DDT, which is the last of the commonly occurring puiiicidrs to suurge. Before examination by GLC, rereptes havs normnlly boon subjected to a fairly rigorous loan*up jwwrdure. such a* that of do Funbort Maunder tf ol.1, whirh inrlude a dimethyl formamidr-hex ano partition and ptreog>- through a colmni) of prepared alumina. Reesw* (lie-' unknown eumpeiindB are similar Ln nature and prepari ire to the argunwhlnrine pnalieidre, they also pass through thi* anil similar rlrun-up prea^Jumi; eonsrquently, they 20 2 B NA7UF OL 216. O C T o e t* 21 often interioro soriously with determinations 1 of pp'*TD and pp'-D U T in wildlife boc'.m of overlapping of the chromatographic peaks. uiLabio procduros have boon devisad to ovoreomo this difficulty of interfering peaks. One m ethod it to oftcct a bolw-r n-sokuion of ihoso particular peak* by ehoicc of * su;tb!o stntionA iy phuso for GLC*. Another m ethod, which also dem onstrates the proscneo of the** oompoundi in the sample, it the uro of e prelim inary thin-layer chromaiographic treatm ent*. T h e eleenod-up u rmete are exam ined on ailica gel chromatoplaice usieg a 1 por o*nt eolation o f ftootone in he u n o ea I mobile phase*. Spots corresponding to tho com pound* can th e n bo found ft! H r valuer between (hfi ftnd 1*0. whoroca tho com monly occurring organochlormo pesticides end their metabolite* produeo pota of lower J if valu*. A sim ilar separation can alto bo ehown with reverto phoao paper chromato graphy* whereby the unknown compounds move only a very short datenos from the base line com pared w ith th e po*;icides and their metabolites. Cos-liquid chromatography using dual ohannel detection synom s with separate aloe iron-capturo and flomo-ionixation detec te n has also been used to domonitrato the pretence of large am ounts of weakly electron- capturing material, in addition to known pesticide residuo*, in tho eggs of oyster catchers (Hiumaicpu* otiraUfui)*. s peri once in this laboratory has shown th a t thoae compounds occur most frequently an d in th e largest proportions in the livers, fat and eggs of birds, particularly torrestnsi predators such as sparrowhewki (Aecipca* flin u ] and kesLrols {Folu> iinnvrru.'us) u d m arine feoders such as guillemots (Urio aal?e) an d kittiw akec (> aso iridoctyla); they also eommor.ty occur in freshwater fish. We have dotocted small amounts in hum an and animal fa t sim ples, b u t lees irequently and in much smaller proportions than in avion samples. A sim ilar aeries of chromatographic pocks has boon properties. In tho preerribed extraction and ChC r'" o b se rv e d b> \Jialdon,.VfU'ehc. tgaLa, jUons^th^sc^n)>turr?,J>rofjLucc a jerie of chromsteri i a n d fish taken in Soottish wstors. H e found th a t the peaks peak* of tito typo iri qi*ubn. ^" " ^ v` given by th e ex tracts of fresh and sea-w ater fish reproaon- T he compounds occurring in British wildlife n*n*i>a t rted fairly low concentrations, but ihoao given by extracts to tliu more highly chlorinated biphenyl compound o f sosJ blubber corresponded to m uch larger proportions, th a n the more lightly chlorinated types. T br-` o f tha ordor found by th is laboratory in buds* eggs. chlorinated biphenyls also occur to soma e*W*i>* * ' D espite considerable curiosity about th e identity of these analogous polycldoroterphcnyl preparations 1**1' * com pounds, liu la progress has boon mad# in identifying them , b u t thoro has long been a general supposition th at they were either further breakdown or condensation prod uoto o f th e organochlorios pesticides or possibly commercial usos I t is possibio th a similar to thoae of pnlj-ehlonil-i*^ t some of tho compounds with J' .1 - m unition times occurring in British wikflifo sir l< i chlorinated polyclilorotcrphenyl com pound. ^i loose oom poundi of these with natural products sueh as protein m atter. fig . xtrnct Jo allows tho from a koatrrl gas-liquid liver. The ch rom etop1 peaks ** * f, I Jenson, howevor, sueoeeded in identifying a aeries of pp'-D D K (0-43 ne). IwU-DHC (0-13 ng) aad pm a* \ such peaks os oo(responding to polyelilnrobi phenyl com (0*03 ng) aro labelled. T1m> othor poaks Ton" JJ, pounds, in S00 pike token in difleaent ports of Sweden, mforrod to above and until now would hav an d in an eagle1*. W a have now boon able to show th a t sim ply as " unknown orgtuiochlnriuo eomi,,H*1' ^ th e long retention tim o oompoundi occurring iu B ritish oorn-ponding in nny known postiddo or its mrtsl* ^ c wildlife are also polyohlorobiphony!compounds. Fig. 16 allows tlm analogous chrom atogn f Polychlorinated biphonyl hss boon in common oommor- eial polychlnrobiplw yl rosin. So far asrcteM*"* ,i. caal use for some timo as a pleAieixor in paints, resins and aro cunoomcd and ap art from the putliewh* p * ^ "* phkStios. I t also has eloctrieal iiiMiUtiug proportion and is i*xart m atching for all b u t ft fow peaks *& 1 can bo u*od for a num ber wf othor protocuvo purpose. chromatograms. CommoreiuJ preparations of this mo is rial am usually Tho chromntngmms aliown wore obtained b>* ^ . grodod according to. tho degree of chlorination, b u t all of ilin-no gum {Gb'-SK 2) oulumn. b ut this ^ tnom aro sub urn (Jolly complex n u rtu re s o f pnlychloro- spoil donen botwoun tho retontiun timm e f d** ^ |>- . biphony! compounds th a t could be oxpoctud to rreoaibln th e unknown compounds end thoso from the tho organochlorino pnslioidre in Uwir chemical and physical hipltonyl m in has also bora dnm onstm lrd on n |* 20 64 '-f V0U 2l6' OCTOECfv . 1 9 6 7 / > uuT rrt rrxrrto* n i u es m : t onrctLTt oic o u n n ; fr** L (tifJfc lm L s ,'or 4*0 im K i rt) m o r * j r & ^usa 1 1C (ZKcICris* 100t "pirioc L' eJaKS XLS ren CyiB*"ifOM OF.-XU SOU ik^e X1E, IHiHn>*ll: tH- I SSI l> ITO S-Sl 5*39 l-CT S'CT sei s o t ACS A<C I ft k tl SAT OSS i :: 1-:, ;r> t c: t-e: SCO 4s 4-M Il^Ct nlnlU71v1uutncl; 4-C3 A ll rCS.fretrcJUoroblfrtMnrlmt. 1-21 131 : it j -m t 91 SCO 4-C3 . A 11 j ryauosilieono columns. Tho aem at reunlion lin o s for iho p o sts on these three typoe of eolumn ar m.T*blo 1. * jypriirr confirmation ss to th a id en tity of these com* Its* been obtained by * s tu d y of th eir bohsviour rm ilniflaycr chro m ate plates, alum ina sn d silica (el option columns sn d reverse phese paper ehromato* In addition, these compounds h*vs been shown h. P*mblo th e polyshlorobiphenyl compounds in their inertness. Thus they are not easily modified by .fi|4o chemical reactions to produce readily identifiable m u in their retention tim es on GLC as car. bo done, for Muuee, to p^'-D D T b y h ydrolysing it to yy'-DDE or to ,,Inti by oxidizing it to dicldrin. A number of livers and eggs taken from birds in the *.ih Isles or their coastal watere have boon exam ined ilii* laboratory w ith results sim ilar to those obtainod t i!m>kestrel liver referred to earlier. W hile th e identifies* . > yf iltese compounds in B ritish wildhfo m ay solve the .aii-ry of theao peaks on GLC chrom atogram s, it raises, t.aevrr. many other questions. Why. for axamplo, do compounds seom to be accum ulated, m ost frequently .I in the largest proportions, in certain types of wild* it >urli as birds, seals and fish, an d only, a t th e most in <rysmall proportions in matt or his domestic animals such m niwr or sheep 1 l a this respect they seem to differ Markedly from tho ergs nochlorine pesticides which aoem u t*v* invaded nearly all aspects o f our environm ent and to which they bear a strong roescnblaneo chemically end physically. Some o f t he sample of birds examined in this laboratory havo scorned to contain higher proportions of polychlorobiphenyl compounds than organoehJormo pesticides. F or example. tli* peaks on the chromatogram for tho kaatrcl liver shown in Fig. 1 are eatimatod to bo equivolonl to about 15 xig of pohxhlorobiphenyl oorspounds. This m ust U* contrasted against the orgnnnchJonno postieide residues listed above. These total only about (KB ng of which 0 33 ng is beta*BHC, an isomer of BHC which is generally regarded as soc-toxic to wildlife. Great concern has often been expressed by conservation ists about the affects of pesticide oo wildlife, particularly birds. The identification of these other orgsoochlonno compounds in wiklhfo prompts enquiries as to the possible toxic effects they may be having. That these compounds aro toxic is generally a g r e e d t h e polyrhlorobiphenyls are in feet regarded as an industrisJ hazard and threshold limits for them in air have been advised1*. We thank the Nature Conservancy for sample of wildlife and Monsanto Chemicals Ltd. for ample of po!ychlorobiph*n\i trains. - larvtnd OctoWr S, 1M7. *XaUrt. II. ST(IfrUl. *Kanuax.X. fi.. J. Sti. Tmd, J r v .17.10 0). Cww mmf t C lM id,T I(m Suuerurr Oficv. IosSod, I *TtVlrr. t*. X.. Rsnllus. 6. A.. s4 Xtrrlsaa. )L 1., J. Sri. Fmd i r . , is. ia *4 T*ubrn Usosdrr. U J., t p i . B.. Oodlr X- V.. lU n assS , X. Xcburx. i,, aid TXocsms. i . i u / f . SI. 14 llMJl. "Stance. J. Il.,u d Ttnoa. J. O'C, J. CS>* SU C.MTl. *Abbott, D. t . Lcss.B..aae Tbonsss, J. CSrMotw.,11.4*! (1M*). *E n u , K.. Jos's*!. 17. MS 11HI). *Ar?e" / IA# Gmrrfmmtri Cs#o*J. US (EX IIUlMUT 0 9 o . InsdM, IS M ). Ro4tn. A. Md Kindi*. X.. J. 7W . I n . 3m . AW -. St Ml. **Koldta. A. V,, J. JrJ M ..l.iF S >..an M S l. " Jiiw i. AW An.. 8 . 12 (1MS). *h i , s . lrnr. OMr)M f n s nm rf /V u n i l MSiwJi. MT (XaisSole fttWaiunt (.oreontas. AW fork. IMS}. **Brews, X . C M J - iW K .ttU (l*IT ). " /W v f U of rtm U d t a i l Trim, <1 (Cm o Ium a TWakdd Unit Valor*. ISM,. F. BROWNE l \J*'****ricj of Manchester Institute ml ent snd Technology By considering the opseity of a'surface layer of star, the author concludes that quisi>stellar sources, Supernovae and novae may be different manifestations of the nine mechanism. * usually considered th a t the outbursts of norae and *rvnovso aro fundam entally different proormet; b ut I ^11 here propose a m echanism which eon account for J*4**pltcnomciis. an d whieh a t the sam e tim e can account * **hrr problems concerned w ith quasi-stellar aouroe rMMira), In p articular, I suggest th a t theso outbursts *** liM y to be anisotropic (as mdeod th e y aro observed *" fur novae). Bocausoth energy ralcascd during a Mwn*t(va o u tb u rst i oomparable w*ith tlio stellar rest ***"**>* an anisotropic o u tb u rst could moo a th a t tbo star J ^ L r s ie d to rolatix'istie \Tloeity in order to oonservo thus affording a Doppler explanation of the l>rd -shifu o f tho quasi stellar source. m ""`'diir th e opacity of a layer. L . a t ih o surface o f a hff be th e thteknroa and 1 th e radius o f L, and . / ' plasma at temporaturo, T . with electron l***itiva ion densities N* and .V* rwapeetivrly. L will *u"*'*,*,M' 10 radiation of wavelength /. provided' th a t T ia L ^ht-ft. r ia tlie optieat d ep th uf A. A m ajor eon- *"*vi in t ^ T//> (he optical lIurknrM duo in fmo-fror abeorptioiu. I t i* known th a t T/rX,r - 4"> `tA*)AJl (ref. 1), where induced emissions ar included. Suppose, now , th a t 1 is compressed or dilated without changing th e total num bers of ions; th at ia, Aff is varied under conditions whieli maintain constant 4niTl AJl.Vf, so th a t Aff.V** constant. Evidently v// a.VM|AR xhr**a ]/!/?. Thus oomprrasion of L tnavaaea its opacity, while dilation reduce* the opacity. Of course, tho total num ber o f tons wilt not remain constant in practice, because tho recombination rate is proportional to .V*A*i. I f the percentage of atonu ionised is lnrgr, iho density of unionized atoms. N. will therefore be proportional to A'*N*. T hu means that the coniribu* lion to the opacity mad* by bound-bound end bound-frro transitions within unionixnl atom is also proportional to. This effect, recognized to 'b o im portant for stellar puliation'-*, furl lier increases the opacity of L on eompraosion. Some eensequeneee o f this variable surfaee opacity "ill now 1 examined. ITnder equilibrium eondilion I 7 4 NATURE. V ' 7 1 0 . DEC EM BER io . 1967 Fraction and M olUplea fraction ra symbol 10-* 10-* 10-* io-* 10-* JO-*' 10- X0-U daci osti mii m re anno p ia lemto otto d c n p n ? a multiple prefix symbol 10 d e ls 10* h o to 10* 10* D C ^ 10* 10 coa *T be m ulcted a* mmA ae pauiU. da* h* k 11 O X Compound prefixes should not bo used. Thus 10~* moire is represented by 1 nm, not 1 rrijin. Too attaching of a prefix to a unit in affect constitutes a now unit, so that 1 km' 1 (Ion)1 lO'm1 not 1 it(m*) m 10*=!'. W here poaaiblo any numerical prefix should appear in the num erato r o f an sx p rrre ion- phyital' quantity length volut density fc Example of Units C ontrary to SI, with their Equivalents unit angstrom inch foot yard nule neuuca! mils square inch square foot square yard square mile cubic inch cubic foot U-X. |*11< pound lug pound/cubie inch pou&d/cubic foot dyns q poundal w pound fore* Lilogr&Jiuns*fa atmosphere torr pound (f)/sq.ia. oqu Ivalent 10-' m 0-0241 m 3044 m kill m 1- 6&34 km I *43 II km < 411 mm* 33 003 m* 0*134 12? m* 1459 03 km* 1434 71 lu . 0028 31 S it.*] 0-004 540 ov: 0-143 492 27 U 14-303 0 kf 1*747 90x 10* 16-0144 k(f 10-* X I 0*134 343 K 4*4t 23 X 0-604 44 X 101*334 K it-* 133 133 X n r' 6194-74 K m * Organochlorine Pesticides in Seals and Porpoises A. V. HOLDEN K. MARSDEN Freshwtttr Fisheries Laboratory. Pitlochry, Perthshire Sesls and porpoises in Scotland and Canada, far from the sun application of pesticides, can accumulate high concentration *J residues in their blubber. These chemicals are spreading thr>j* the long food chain which ends with seals and porpoises and obviin**;* cannot be confined to their place of discharge. T a x presence of organochlorine residue in m arine lifo in m any areas of the world, including the Antarctic, hsa been harp soils {Phocc, yrotnlandico) on th e Canidisn heve also been examined and twhaev results Aufll*iuni-- - rep o rted recentlyl*'. In British water the aocumulstion analyses are reported here. Exam ination of sanlJ|* 1 o f residue in th e e c g i o f ao* birds1 and the process of aqal .bJubbor.frani.-Othor^arees. is continuing in.H* ' eoofclTmiioB` of~pi^icld^USjwgV'dferl^iY^ibdci"Salfis ' sobs'the' Variation b^w rcndlflorcot regions fYw in the m arine environment* have been studied. Analyse environment. o f various speoies o f m arine fish and mam m als from All tissue sample from Scottish waters were (* Scottish w aters during th e p ast 5 yean*** bavo shown 6 t --14"C until required for analyais. T3w t 'w ^ i-- th a t organochlorine re s id u a are now a normal occur* aasp lca were preserved in 10 p er e sn t formalin. ranoe, th e highest concentrations being found in organa showed no evidence o f any infiuonos on tho ai*l* * * o r tissue w ith she highest lipid content. Thus th e muscle prooedure, and in this and other cases involvin'* <"' ' * tissue of salm on ids, th e liv e n of ood and th e blubber of has not affected the efficiency o f recovery of )*" * * seals act as storags sites for those residues. residues. Aliquots of the sample (5 g) were gn*Kl * * j T he aq u atic m am m als, such as whales, seals and p o r powder w ith anhydrous crystalline m dium vIH* '* * * | poises, have a relatively high proportion of th e body weight grade) and axtrarted m a Soxhlel apparolu* * * ^ * lq th e form o f subcutaneous fa t (blubber), finals food distilled AR grada a-hxane (previously tested '"* j ehiafiy on gadoids and aalmonids. and porpoises chiefly on to be free of eloetron*eapturipg m aterials by f*1 , sm all gadoids and elupaoida. T he process o f eonoeotretion tography). The hexane extracta were tnedo up **1 ,. | o f pesticides through their food chain m ight be expected and 24 ml. aliquots ware subjected to ct<Tn.M|^ > to resu lt in high pesticide levels in the fa t e f these m ammals, tb s hoxano-dimcthylformamido p artitio n w*41** ,, an d sample analysed a t this laboratory confirm this Fwubcrt M aunder t si.*, followed by oolunv* ^ . expectatio n . In reoect y a r n , specimens o f th e grey eeal using alum ina containing A p er oc&t water* y** ^ ( C*'alichocrw p-ypw ). awmMw seal (Pioca sutdina) and peaticido residuos (rom fat extracta so treaty* -rpoisa {Pkoeaima pAocoeno) bavo bees sampled from 20 por cent, but, as is custom ary in o a ts o f Scotland. S a sp te s of blubber wore available do correction has been modo for s u d i lorec* **( * * all the specimens examined, and in a few eaaas other p m e n trd hero. j |>t r* organs were also available. As well as reoog&izcd peaticido The eluanetl*up hex ant* oxt recta were j j,ii residues, o th er alee iron c a p tu rin g subcLanoce havo been liquid chrom atography on a V aran 'Aeree*) 1 * | , detected by gas-liquid chrom atography and, in order to instrum ent employing two glass columns 4 ft- establish wboth or ruch suboanoes ore as widely d istributed outor diam eter. Ono column was packed Wl t-- *--' as tb s p est icides, blubber samples Cross grt y seals and aarb W A W /D .VCS 00-100' mesh sooted with J 66 20 0*E, VOL. 21 6. DECEM BER 3 0 . i- o 7 1275 * 1^0 silicone oil, and tho othor m-iih th e u n i t support re lj4i with per cont DC-2uO + 7-5 p e r cent ( \l ii!irone. Tho oven te m p e m u r o w u 200* C, the vn gna flow 60 m l./m in a n d Lho colum n rcoh:tion ,,0jl'ldnn equivalent to 1,000 th eo retical pLdoc- There ( significant degradation o f D D T on tho eoiumr.i. eompl etc aepuration o f th o com m on pcs: iciJu f(,r* is po n ib lo on ono or okhor of these column*, ' krone by polychlorinated biphenyl (TUli) residues*** ,^,p**TDE and p .p '-D D T pc.-.--s noccasitatcd a fun,her stage. Aliquot (5 m i.) o f somo o f th e extracts , evaporated to dryness in a tlro a ra of cold Altered air, ilw> residues refluxed w ith 2 m l. o f 2*6 per cent ^Jio potassium hydroxido fo r 16 m in on a warm .bath. A fter oooling. 6 mJ. o f n-hexono was added, coniti:ire! very Uiw Irv rh of both riieldrin and the DDT group, wltil,* M'uli (ruin the <*aLut Strait* (Gulf of St. lav:n.T.n j contained little dicldrin but higher DDT group rr-Miluc-*, imilnr to those of Scottish seals. Of the few porpoise* cxiuiiinr d. th at from Orkney w u the Iras: eor.:.m ;i:n .j. Lot tl.i< three taken on the cast coast of Scc'dcr.u l.td markedly highrr contents of all the m i d t r i rcri.'.urvd. 0 :n sp cu n itn cni.taihrd a total residue eon* crc;r^tior. (diridrm and DDT group) of 73-3 p.p.m. Analyses of a few tissues o th rr than the hlubber have baenm adr. lait concentrations in the blubber have always been found to be the highest (Tablo 2). Concentrations in othertiesues HTm likely to bo consistent with their lowrr lipid oontents. , mixing, followed by <0 raJL of 2 per oent sodium Mte solution. T h e eupem sL ant hexano layer was c Analysed by gas-liquid chrom ato g rap h y . By this wique. q u a n tita tiv e conversion of p,p'*D DT to p,p'* , and of p,p**TDE to p ,p '*2IDE ( - D D l i U ) . is ob,d. and th e conversion p rod uok confirm th e id e n tity of rginsl residues. The residual pooka in the p.p'*DD7 T5^ S . C fT T i^ : Ore. C iv..- Crz71.* ^ C n / .* .) T C IU SBC O O ^C U T U T IO SS X iU rT Lm X n is 11 t: Its < M 11 n o -:t : ct 0 11 ou se Mt ON M7 OC.T MR IX V S S M B S M C X S lu u r -- f M W S t t a c U re. u i s re-s o s ^4 10 u j.p'-TDE positions, where present, eon be subtracted _ the values o f tho p esticidoj originally determ ined hr? positions. H ydrolysis also destroys a and *r*BHC, present, b u t polychlorinated biphony Is a re un* xied. A eyanosilioone (A'ff-GO) column** has also rt used to separate p,p'*D D T and p tp `*T D E from PCB ^rftmnoe, eonfLrmir.g th e la tte r. Tbc principal pesticido rosidoes found in all aam plrs rained were those o f the D D T group, with dielarin ouch sm aller quantities. C anadian seals contained n eonoentrations o f dicldrin th a n S cottish sor.ls, while uh porpoises contained rem arkably high concentre* of all posticide residues (sec T ab le 1). Interference on r C-200 silicone eolumr. in th o p ,p '* T D E position caused C aon-hydrolyiobJe residue was responsible for about I per eent of th e to ta l estim ated p,p**TDE in tho -L^diar. and Soottish samples exam ined. In tho p.p'* r-T position, the non*hydrolycabIo residue constituted a. t* : 10 per cent in th e C anadian aam plrs and about x *per esn t in th e Scottish cam ples exam ined for this urferenoe, tho to ta l am o u n t of noa*hydrolyxable ^nal being sm aller in th e Canadian som plrs. The in T able 1 have n o t boen corrected for this inter* ~ee. for only a proportion o f th e sam ples were hydro* The pru;<cetinn of blubber extractable by hexane was d atcn ain ic for seme samples. Values ranged from 72 to 66 per oent (mean 60 per cont) for tho Canadian scaIs, and from 66 to S$ por cent (moon 93 per cant) for Scottish tools samples on the breeding grounds off the west coast. (VHuei for other sea! samples were not estimated.) Con centrations of pesticides in terms of extractable fist for these samp'.ra would thus be up to 60 per oent greater th an the vl!ucs in Table ), but the genera) comparison is n ot tigniflconl!}* affreted. The lower extractable fst values for the Canadian samples may possibly bo a m u lt of bring prrtrrved in formalin. Concentrations of pesticide residues in the extractable fat of various organs and tissues of one porpoise ahow an im portant relationship (Table 3). While the eoaoentra* tionc of the DDT group in the original tissues vary widely, th o u expressed in terras of extractable fat are in much, closer agreement, with the sole exception of the brain. A similar anomaly for tissue* of trout was described by H older.'1. Jt seems likely th a t a large proportion of the Jipid fraction of the brain may not contain pesticides, and the brain lipid composition is known to differ considerably from that of depot fat. *4 R'Ceulutafrogt.^be .yaxa.Qu^fgseciax, o / wosl* ^ re _ rip ^ ably difforent in a given area, an d M i T b u n ' `TiSfftr*Vacrri'kTftiii"ertn&`fcvf&9^w-fB*cXs cs^msretm* >- sUnad in T able 1. TUsutsrw^a SluUtf Kiweis Ltret Ip S n x u m 7 Xisia CDOOtnUStlOnis IlMUS 1 s CM U U -W 0-02 L b c u t s * t io v safoxs of eeeixocxtesiTB si >m a m ptranu.^ cstnet* SM (41 er axioi sse rosrocrai (p .;s.) C n u B im in is 7*0 S I H t Ul < 1 la HH IS tr ain^uak IbI 'rwAm(wt iipl iU asVmsp. Itst DUMrts p>*DDX p^'*TSX y*DDT *^*4. bSuIi IS 0-lt-ll s1w180BcSeCiU)sI s SO(DM-Wl VKmwStiersioestoeuMjosS,S) I oo((MOsteoS>) '*Ws*T`]inUh*rdtw*UJt>ma iu,, t o(sc-o-aoj* ** c s to ts trs ju . os-m o " bmS bSmU (>07) l*1M Cl1t<<<0J*r1-I-11<1*->))S10 o-i(ri--stoi li-o -u flt((*0o*0-4m1M o(s-Um)s Ma-*lT-l SIM l (M SI I-S-S3 S 1O-Mi-lT l(Ot1-a!i)l 7 UCM-OS>U S '1-1 I S (-St J'^*9**orO9.foakdmaurirlit.m7J 1 S (I H I , 1SS7J su ct-#i>so i*i H * lll OtSj 6u SC-M14)S I ISat*Dtl 7 Tbe unidentified peaks on the chromatograms seem to be similar to th o u produced by polychlorinated bi* phenyls and. to enable comparison to be made, the ratios (Ax) of the retention times of ail regularly occurring peaks (relative to dieltlrmw 100) have been calculated for th e operating column tem perature of 200* C, there values being tem perature-dependent. The Ax values of FCB compounds from comrnrrrial PCD formulations were also determined for both types of column (Tablo 4). At least even PCB-lype peaks wrre found, including those which interfere with p.p'*TDE and p^p'*DDT. Hcpiachlor epoxide and p,p'*MDE eould not be eon firmed on both lam ination by pesticides is g reater in th e seals on -4*t coast o f Scotland (ts k r n in an a r m roughly from *wdeon to th e T ay estu ary ) th a n in specim ens from th e "** and n o rth ' o o asu , ineludiog th e O rkney Islands. > Pups from tho O rkney and H arris (west coast) breed* * (rounds contained only slightly lower residues than '**11 from tho same areas. B y eom parishn. th e Canadian ^P*ra from lh r Magdalen Talands (Gulf of St. Lawrence) columns and aro not therefore recorded. The m s t significant aspect of tho raruha is th a t, although seah and porpoises inliabit an environment far removed from the sito of application or discharge of preticidre, they con. oonfsin much greater eonersifations of dieldnti and DDT group reoidi*cs than thore recorded for moat other speeks, including man. Robinson and H u n te r'1 futinil it mean concentration of dwldnn of 0 1 2 p.p.m. (range 0-10-0-73 p p m .) and a moan total eon* 67 90 1276 NATURE. VOL 2 16. DECEMBER 3 q. '*t an ti ration of D D T of 4-0 p.p.m . (retire 1*0 M l p.p.it,.) in arnnplr of huiiuitt depot fa: ; England il. IR-i. Nv evidence o f any significant chanci* a it* found duruiL* (2-05. TaWr *. s t u m s i n n u i r u m tlu , tr s t u n s* tomi*.*. > tu W 0 ooluan K llrilW Atxipl# Uiitit k i fr..-. * k a rlr pen - as a j*.y' UOR ih t.Arm i'1 -1 0 0 PCS - 1:1 --118 K-o - u a W iUOT -IT O -n t PCX - s u i PC Ik -3a2 PCS - s u e ,J Li ICO Ili la i lw m i?i su a*7 tu PCL C-S p j '-d l : - at TO . ti t.*.i.*3 - lU j Uh p'-7*> - 12'. 12*. r . 3 -123 li pea - it :a . p r'- D D i- it: ? ii vv aa -m t - la : H The veal* a n d pnrpoica from th e eat cookt of Scotland \%aro iikuoiiy more w rio u Jy co:Amj;ir.ti than tho>r from th e n o rth and went coasts. This, u , least in respect o f seal, m ay be breaukc. a* is believed, the population, in th e t o areas come from different breeding sue*. Tne oaU m tJi o f Aberdeen breed principally on the Fan,* aland*, off th rj orth-easi coat: of England, while the cals of no rth and west Scotland are primarily from the breeding grounds o f the O rkney Islands in the north* and other islands off the west oout of Scotland. The v * off eastern Scotland it also likely to receive more con tam in atio n from1'estuarine discharges than that a ? north an d west Scotland. Similarly, the two separate ceil population sampled off the c u t eoaat of Canada may inhabit areas with different levels of contamination. Pups contain pesticide residues in concentrations only slightly lower th a n in the parent population. Common seal* in H olland have bee found with Ctiiiarutratious of rrvidue imilcr to th o u of aoals on the Scottish oast coast**. While th e m udue concentration* .in suheutaneou fat are lugh. those of other tissues and orgon arc found to lie m uch lower. Thi* suggests th at there is no risk of physiological effect*, unless the m ctaboli^n of much of th e fat in times of a im s loads to a considerable increase in the concentration of the residue in circulating lipid, an d thus in residue concentrations in other organs or tissues. (S.vy mmU mi Ihu cua-! o f th e Srutti>h maihh,,(lj ^ pr;i.,.;:i:y on o ilm en {Suhriu tnlar) and e*xl (r ,* r.;err/..i .*. Thu higtn-t rtmccnlrstion* of pawtH'il ' M.l::^>it.d> in th r mnruu* environment 'have w> fnf ^ * f*i<.:.t; it, 'll triiiil (,V iruiffl) fin Ihe cast cooat with * U-i' p.p.i:. .di'-ldrm + total DDT) in mu*elo tw iiu '' ^ ' w ! t h e aanic ari*o would probably lia\e co..:**;.:. Cod exam ined from th e east const t*;*.ed up :n G-3S j*.p.m. (divldnn * toial DDT) in n(l *' tituc (iian.n 0 1 2 p.p.in.) and from the weat tom*i 0*50 p.p.m. (moan 0 22 p.p.m ). while cod liven en n u i.., up to i Cp p.m . and 12 p.p.m .. roepretndy. Crvv an* e>timr.:cd in ru t about 15Jb. of food daily, aiwt * dull seal could coiiKume its own weight in fond in \ days. Assuming a high proportion of the pestiekh- .i,, to be stored in body fat rath er than to be raen-u.i mt".ii:*lucd. an ncreaer of two orders of magnumt, , pa-iiridt concentration f.um food to body fat wit),,.. , few yca:v is feasible. This degreo of accumulat***, . rrsic.u- :n a:, environm ent not deliberately contantiih,i..i and ir. aperies ecologically far distant from th>* u , (- organisms of persistent pesticide, underline th,. M. puo-ibihty of confining such chemicals to th r an-.. . application. V\Y thsuk D r B. B- Rae for obtaining the samples, and D r C. J . Krm will for the Canadian aam(<i-. BwrhcC D*vber It . 1M7. *tf? !'***&!' Sri. Ad'. C* ( f t C*>*l, f i li d il OAa, W*--*., ISdi. 'T w :.i ,J. O'C.. snC Xuncl. 7. It. A.. .V w .w .B l. Ml (1MD K fvw.y. W., ar.d Tatton, 3. 0*G.. S*>mf*.tV7. C dM lI. * J,, Rii-K*rJ*--.P A.. frbu. A. K,, Cm Vo. 3. C. *M iw*, i. h . . * . lAwtllKTi. ivtirm*t: Aerimii un and Kuhtr* for Oreifead, r o n w M*. hi..; lu(-ori for lact *t^ 7-rm*.u tf Atrlcultun ad >*itsrka far SooiUad. rOArrW W u^. Lryirt for 1B6C * IV 1-*.ieri U. J.. Slvsa. M.. fkeil R. T .. J.'^mrr.. J.. nil Thomion. J.. Am.'. II. IS UMl). I.. * itnarn. 5.. .Vnr .tr^ iiiii. S3 SIS H M i. * Kew , D. i',. N;nviiit. J. II.. n>l Tin.J. O'O. I'S w .lM J " M La iia o i. J . H.. *nJ TU0u. J. UT... J.Vkt*m*y*^Ti.SSI (IM Il *IlilJfi.A. W.Amm. A p^ ^ ..1 0 . 1ST "Lil-.u'.t, 3.. i U Uunirr. C. I*., A *A. A'w*i. Kalll II Me tiwr " 3. It., and t Gendrrtt. H . J. Appt. CrW.. I (W^A1*, ' * b. h . AT*. JO* . So t. SB (IBM). U~UI.. A V.. J. Appl. AW . I (Sur> ). O {IMS). V- i k is. The North ^Pacific: an Example of Tectonics on a Sphere *>r \ d . p. mckenzie R. L. PARKER, >i \ Institute of C eophjnia tnd Ptuicary Physics, University of California at San E^ego Individual aseiimic areas move as rigid plates on the lurBee ** iphere. Appfiation of the Mercator projection to slip vrctori that the paving stone theory of world tectonics is correct *' to about a quarter of the Earth's surface. a T k * linear m agnetic anoraaliec'*' which parallel all aelivo ridgea con only be produced by reversals of the Earth' m agnetic field1 if th oooanic eruoi is formed doae to the r>dg axis*. Models* have shown th a t the anomnlir c a n n o t bo obaorved in th e N orth A tlantic unless most dyko intrusion, and honco crustal production, occurs w ithin 6 km of th s hdgo axis. The spreading ea floor* th e n earrios those anomalies for great horisonLal distances w ith little if an y doformation. The epicem r* f earth quake also accurately follow the u u w id n tr tdbwi with i t by transform fault** *. The atntcture of LukI ores * 1m clour, tho u g h tho narrow band of tJvdlow oa/thi|uakr* uggeats th a t crust im oonsutned along a linear fruture. The-w ohaervationt arr ex p la in e d if lha e ) ^ ^ aa a rigi*l p U te . a n d im en a cts w itK 'o tivr . m ieolly c1i^T regiuns h ie h also show irw i'i ^ , a ctiv ity . >'nr t >*o p tv p o a es o f th is or* iele. r* ** ^ _. tnm ehe arr r e p o rliv ely d efined as line "h*' t# cnit u prndueed tuul d ctrn yed . Tley iw"** ^ lopitgraphie fvetun*. TVai*form fauh* im - and are lm**v o f p u re slip . T h e y are a!way |wn* , fore, to the rrla tiv o v e lo c ity vector between t** 1*^ ^ . . . munt u w fu l p ro p erty . W e h a v e ireted *ha P*' . theon* of world tectonics in the North r*olw'-__ _ work well, fa-w d etailed studies o f o t l ^ r f r aoppurt the tlicory. 20 68 the s a (d) scggeiu a link with the s'a zl dispersion of pesticides. A^.loJgh talc is perhaps diagnostic of the presence of insecticides, its use 6 i r/aastitstive lrarer is no: fully war- 1 6 ^ : it is gradually being displaced . c pesticides by water or light petroleum h u Furthermore, some insecticides era dispersed is Fuller's earth, a mix- d : of minenb not readily analyzed by Pcs:urines: Tmnscllir.fic Motcecs s-rcy diffraction. b (be N o r t i r : : T e d : : Large-scale tropospheric transport from continents to oceans can best be Abstract. C oncentrations o f chlori approached by investigation of the three n a te d hydrocarbons ir. airborne d u st cein zones of movement of air masses: ca rried by the trade winds fro m the tie equatorial easterlies, the temperate E uropean*/.frican land areas to Bar woterlies, and the polar easterlies. b ados range fro m test than I to 164 Cram quantities of airborne particulate p a rts p er billion.' T l* low er lim it o f the Better carried by the equatorial easter- a verage co ntent o f 2 cubic m eter o f air E s, the trade winds, over 6000 km is 7 .S X 70" ,i gram . The contributions from Europe and Africa across the Al- o f fiv e r-h o m e a n d atm ospherically hatic to Barbados were collected (7 ). tra n sp o rted pesticides to ports o f th e Pronounced seasonal variations in the m a rin e en viro n m en t are calculated Bagnetic and biological fractions cor a p p ro xim a tely a n d com pered. T h e related with wind patterns- off (he Afri a m o u n ts o f pesticides contributed to the can coast. Mineralogical and biological tro p ica l A tla n tic b y the trade w inds observations pointed to a continental a p p ea r to be com parable to those car origin of the solids, with Europe and rie d to the sea b y m s or river system s. Africa as the most likely sources. Each Bmple comprised a large fraction of The transport and distribution of the particulate material in several mil- pesticides through the world ecosystem Eon cubic meters of air. An input rate have been attributed to a combination of solid phases to the tropical Atlantic of atmospheric and hydrospheric (oce sediments of 0.6 X 10~4 cm/year was anic and fluvial) currents (7), yet their siggested <d). Knowledge of the pesti relative contribution! remain unclear. cide levels ia such materials would per Tns high concentration! of residues of mit similar calculations of their inputs, pesticides found in shearwaters Puffinus for which purpose the Barbados tarn- : tenuirostris and P. griseus from the pies have been analyzed. 7 " L'Prciftr Oceanian3~s6a?fCd7fdiracfa" *x TKe^thnectirg-scTrrirt " (frft"*fatosg^-4- t i u a from Antarctica suggest that the wind, were made of O.S-mm-diam- ' coastal areas are not the sites of in cter monofilament nylon woven to five ;i. gestion (7). about 50 percent voids; they were Various lines of evidenee indicate air coated with a 50-pcrctm water solution transport: (i) the codistillation of of glycerin for our work; collection chlorinated hydrocarbons with water efficiency was about 50 percent for 1 2 ) . and (ii) their detection in air and particles larger than 1 p . Rigorous rainwater (J) and in atmospheric dust standards of cleanliness minimized con originating in Texas and subsequently deposited in Ohio ( 4 ). These observa tions, however, are not sufficient to support the hypothesis that much of the pesticides present in marine organisms was atmospherically transported to the oceans from the continents. Complementing such work is the o^> tamination by local dusts, which has always proved to be trivial. For blank runs for the pesticide analyses, acetonewashed dust was applied to screens, with subsequent treatment as for the real samples. Less than 100 pg of any of the DOT compoiAds (1 or other pesticides per gram of sample was aervation that the mineral talc that a found. used as a carrier and diluent for pesti The dust samples were Soxhlci-cxcides occurs in the solid-mineral phases tracicd for 6 hours with a 2:1 mixture of rains, glaciers, and riven and in dusts of bexanc and aertooc. Blank runs, recovered from the atmosphere in corn u ing the same solvent volume*, extrac cent ration! much higher than expected tion times, and glassware, wore made from natural occurrences (5); its exist before and several times curing the | ence in airborne particulate matter over course of the analyses; leu than 250 j HOVA-H N0.I4 8ULK CT aw-T Fit- 1- X-ray diffractocram (Cu raiu^an) of Atmospheric due: collected over the Coral Sea. with talc predocunauag, / * p i of toy pesticide per gram of sample tracts and occasionally interfered with was present to the conlrok. determination of p,p'-DD and o,p'~ The extracts'were concentrated tod DDT. analyzed with a Micro Tck-220 Extracts of samples between January chromatograph equipped with Ni-fiJ and September were pooled and placed and H*3 electrono p t ure detector*. Two on a thin-layer plate covered with silica columns, a 5-percent QF*1 and a 10- gel G that had been washed until chro- percent DC-200, both oa hexamethyi matognphically dean. A small fraction disilau ae-trrated Chromosorb W, 0- of the sample extract, mixed with stand C 100-mesh, were used simultaneously, ards. was applied to another area of differences in retention lime between the plate. After development with 10 the polar and nonpolar columns, com percent ethyl ether in hexane, the plate bined with occasional spiking of ex was divided into two sets of 13 l<m tracts with standards, initially confirmed strips which were scraped off and the identities of several of the peaks washed with petroleum ether, A con observed. Peaks of unknown com centrate of the petroleum ether w u pound* fluctuating In intensity over lie then injected into both columns of the year were present in all BArbadOS CX- ' i -- ~ .-r . v i ' -" S ' ' --- Diddrifl, p.p'-DDT, and p.p'-DDD were quantitatively rccovcjnJ from the corresponding areas of the plate occu pied by the standards. In' several ex tracts the interfering peaks made mea surements of p f .DDE and 'of o^'-DDT impossible; the thin-layer tjecovcrics of these compounds were 130 percent. A trace amount of a compound having the retention times of oy-DDE was also recovered, but a smalt peak provision ally attributed to heptachlof epoxide in one extract was not confirmed by thinlayer techniques. None of lihe uniden tified peaks had retention tunes equiv alent to those of the polychlorinated biphenyls (PCBJ, industrial pollutants widely dispersed in marine |ecosystems (9). No attempt was made to isolate chemically pure pesticides from the thin-layer extracts in order to obtain fared spectra; instead, several of the thin-layer extracts were treated with alcoholic KOK under conditions such that p.p'-DDT. o.p'-DDT, and p.pv DDD are convened to their dehydrochlorinated derivatives, which have characteristic retention times on QF-l and DC-200 columns.. The thin-layer extracts containing moss of the p.p'-DDT, p.p'-DDD, o.p'DDT, and dieldrio peaks were evapo rated almost to dryness in s graduated test tube to which 1 ml of 10 percent KOH in ethyl alcohol was added. After heating for S minutes in a steam bath, water and hexane were added and the solution was swirled. Analysis of the hexane layer showed that the p.p'-DDT, Table I. Pntieido fa airborne particle owe Barbados. Coneeatrafioas la air an baaed on 30-pcrocai tfficiraey ot the caflartiB net; ND act circled. D ata (1965-64) AAi*r volum e (X IP ) M aterial dry vt (s) T o o l Aaalyxvd p^-D D T p j-D D E Pesticide cfloesntrauoca la aamplci (ppb) j-D D T DDD Daeldrie Tout T en t ta tir (s X 10*M/m*) 4 -4 Oct. , 2 s-:i Oct. 7-21 Nov. 1-15 Dec. 25-25 Doc. 26-21 J u . / 15-17 Feb. f VIS Feb. 27 M ar. 14 A pr. 14-16 M ar n - n Jum 21-25 July 10-12 Ana15-13 Sept. 23 032 52 12 U S 7J 7.70 < 1 3 ND IU 13 237 71 19 143 12 232 10 ND 2J . u 133 It 49 23 13 037 30 ND 12 IS 332 II 13 . 13; 132 <7 ND 23 IS 134 14 2.1 11 . 4.7 3.10 11 ND 1J 3 333 2.7 ND 11 23 239 7 3 ND IS 11 239 53 33 I S 3 439 4 3 3.1 1.7 7 3 4.15 S3 13 *T*] * 7 *rl(M w w m w i tXwv m u wtlrctr mm IS pfrrloMt I m . PT&. / 11 / 13 7 3 3 ND ND ND ND ND ND ND ND ND 13 C 4 ND 1 0 .7 . it 4 ND ND 17 ND 4 3 ND 13 2.1 ND ND ND ND ND 13 ND ND XI 0J 1.1 1 3 3 1.4 13 1.1 13 13 S life m iM M Umm W 20 17 . <13 90 40 144 49 37 94 25 11 44 10.7 1X1 10.4 13.4 150-3 < 11 9 13 242 42 77 fU 27 17 41 21 1 110 10 120 Mr m e am m l . ' 70. SCILNCT. VOL. im paired, but peats having tfc. -e*t b ^ a lime* of p y -D D E, p.p'-DDNCU. and o.p'-DDE had appeared in (he re- f **tecu've extracts. The recoveries of az dehydrochbrinzted derivatives were equivalent to those obtained in the saponification of chromatographically pure standards. No other breakdown products producing peaks in the eicctroo-eapturc detector were identified. Tbe dicldrin peak was not fleeted by the alkaline-alcohol treatment but could * not be found after concentrated sulfuric acid was added to the evaporated ex tract. All extracts were analyzed with bo:h DC-200 and QF-1 columns, and each value presented (Table 1) is the aver age from two or more injections of a sample. The total concentrations of the chlorinated hydrocarbons in the dust were higher during the winter r.izths, but the total pcstieide content cf the air displayed no evident seasonal changes during I year. A relatively high ( content of magnetic dust had been re ported (6) for September, October, sr.d April when the wind circulations suggest that tbe dust originates in Morocco; on tl* other hand, the content was less be en October and March, when the probably comes from tropical Africa south of the Sahara. Most of the biological material was present in the winter samples; fungal hyphae abounded, and bacteria, fragments of vascular plants, and marine and fresh water diatoms were observed. Among ' tbe last were Melostra granulate, which > - & *<3Hsr* vrfi^iiburi6h?ifi<r^nV' ficida elegant, which is found io the running waters of cold mountainous legions. There was no correlation be tween tbe pesticide content of the air and either the magnetic content or the number of /ungal hyphae reported (d). Tbe pesticide concentration io air averages 7.1 X 10" M g /m \ or 41 ppb (parts per billion) by weight in the dust. Utilizing the sedimentation calculations on this dust (d ), we can calculate the introduction of pesticides to the equa- rial Atlantic by atmospheric transport the following way. We assume that t irea involved in dissemination by tbe trade winds lies between the equator ,and 30"N Latitude, covering 1.94 X IOtT cm!. Tbe reported (6) rate of sedimen tation for this area is 0.06 c m /1000 yean, equivalent to an annual input of dust solids of 9.70 X 101S g (demity of dust, 2-5 g/cm*; water content of the aediincr.ii. 50 percent). The value of u ujkini im 41 ppb of inscciiaU.-: -a i>.a dun yields 600 kg/year. The input of pactic.'drs into San Francisco Bay, r.c^urcd by the aver age total cocw.v.ra:::;. in \U San Joa quin River t: A r.:i;:k ('$) (0.1 liter) -and the miar. caJibw of 18.9 x 101J liter/ycir, amounts to 1900 kg/ycar. A simibr calculation for the Mississippi yields an brut into the Gulf of Mexico of 10* kg/ycar (77). These rates cf input indicate tbe rela tive significance of wiad and river trans port to the mzrir.e environment. The atmospheric rate is clearly an underes timate inasmuch as the method of col lection of the dusts fractionates against materials carried or. particles of leu than several microns or as vapors. We must conclude that, tka atmosphere can transport significant quantities of pesti cides to the open-occar. ceoiystem; where ocean currents and river drain ages cannot explain th: presence of residues, wind systems may provide conveyance from continents. Similarly we have examined ample* of airborne particulate matter from the central Pacific collected on glycerincoated nylon nets mounted on the mast of R.V. Argo (72) at 12 stations be tween 17*N and 18*S near 180* longi tude during the summer of 1967. No sample carried a detectable pesticide residue, but the weight of each sample did not exeeed 1 or 2 mg. and less than I pan per million or 1 ng of a pesti cide would have been undetectable. However, the presence of talc, the most mlrtrat,^ugjfnttd the presence of pestieidcs (Fig. 1). Dun collected from an ocean pier at La Jolla, California, between June and October 1967 yielded total pesticide contents in air ranging from 6 to 270 X 10" 1- g/m* and averaging 7.0 X 10"11 g/m 3; the prevailing winds are landward, with an unknown admixture of air from neighboring agricultural areas. This average value is 1000 times greater than its Barbadian counterpan. Such is the difference in pesticide load between marine air adjacent to agricul tural areas in which pestieides are used intensively and marine air remote from aites of application. Extracts of the Li Jolla dust samples were pooled, concentrated to a volume of about 1 ml, and refluxed for 10 min utes in 100 ml of 5 percent KOH in ethyl alcohol before 100 ml of hexane and 300 ml of concentrated aqueous solution of NaCI were added. The hex ane layer, a f t e r concentration to a small relume, was Cm analyzed for PCB. Sksh u ra tes: of extracts of marine fish from et= al waters in California reveals the ctracteristic profile, oo g u chromatogrars, of the PCB peaks (9); PCB arc prasal m higher concentra tions io crabs birds, and the profile of the varies peaks a usually evideot in unsapocilbd extracts. No PCB, how ever, w u cubic in the La Jolla uu sample if PCB was present, its maximum civeraunion in the airborne panieulato was 5 ppb--10,000 times lower than t&at of tout pesticides. The PCB are I c r compounds widely used in industry b the manufacture of plas tics. pains, and many other products, and are components of industrial air. Unlike the chlorinated-hydrocarbon pes ticides. wkrh they rocmblc somewhat in chemical structure, they apparently persist to a greater extent in the vapor phase. Tbs csoeentration ratios of total PCB to Icra] DDT io many seabirds, including two species of Pacific shearw ilen ltd nest in Alaska, and in petrels and resident peregrine falcons from Femes areas of Baja California are of the same order of magnitude (9); this fad suggests that PCB and pesticides are similarly dispersed. With other poUtfUMs, including products of atomie explosions (7J), they are prob ably univsszCy present in air; thus their distrikrioa in marine and terres trial ceosjsnss remote from sites of application can be expected to depend on the prrvaSog patterns of wind cireuUtioa and tbe rates of fallout. _ . k w . R is e s x o u c h Institute of Marine Resourcer, Department of Nutritional Science* University of California, Berkeley X. L H uocrrr, J. J. GiurriN E D. Goldiexo Scripps Imsanrion of Oceanography, Universify of California at Son Diego, la JoBa 92037 L 1 . 0 *0 . T o m n U X. K A . ftu d tkt. M v . a.M V 111. MS (l*C 7 ): L W. S M kiW fK . DM tM L. D. I . U t M J r . H . S Ou<t. Odd. U S. 9 w . I . L . SlaW n. C . It. Hi m . V. L. SKUt a u sis. cm (]K 4> : J. L C M K m * O: t H . F m v , 1. Aped U t SmppL a IS (!**> . g u c fi - ~~i_ F . A m , J r . C . S toi. K . l o w . XrW wr MS. M U F. A rm , Sr. St Ic n a , M . C. * * * . t. A r F W Ckvm. I J . U S tl > ; M C . rvu. F. A m . S r. C K . nemt*. s. i m a 1011 M. C. X W L F . U s u A M iii. tAU. 14. te n (m u g p. a w i m u . u Cam L XfcMate. <*- *m*w IM . MM C IV ); D . C . AW>u. i . a . K v r lm X O 'C T m S. T w w * ., Wv- jm m . isn nwti; mu. sii. li* Cwt.AUSw w(Mo>ir>t . M S S. A . J ty lTyf *7' * f 4 J. H. ClhCK C. Haliftoa, h fl/r-- fttiit iJri tm ti* i.miir--mtrnt (AawtKja Secnr, IMA), p. II). S. 11. WimJnm, t. J. CU1ia. . I). M * , c f.mitfM. Set. TVr*-/. . RI (I9C7). A. C. Delinr ri /.. Crackim, Cmimmrkim. Att* 21. US (I*?). j, llf m** ( (he Settore Kncwli Coma* rii. U.K. W* ihank A- C. DrUny tur them. B. ArwJ'Vi ol DOT ineluilc tu ( pomeri f^ '-DtlT and a^'-DDT aJ ihr mmbol>e Oru-aii*n ot pX-HOT: pp'-ODE. py- ODO. inJ >/-l)OMU. p* '-DOT, 1.1.1- liichiMO-2J-hu(p<hlorofh(i(rl)riKwir; DOT. l.l.l-ttieMro.i-(*-tMo*oplwtMl)*Mp- ttltfrnrtmfDnbaar: pp'ODE. IJ ^ irtlo w U-bhtp-chtomphforDcihjlr; pa'-DDD (ilw kPo*A a TDE), l.ldifKlirplJitK^ lUfiro<V*-*7l)rihane; p.p'*DOMU, Khtei U-h(/-<hi>i*rhrorl>rt*rt*u. | 9. . C. Ilolmr*. J. ll. 5irr.mnnt, J. O'C. Tal- ten. p/mturt Ili, 327 (l*,,7j; G. WaJmiU. /. ftmiurr Off,e. Air. Chrm. 9t, IBM(|H7|; A. V. Meiden ami K. Hmtmtr SIA 137 (lC7); n. W. Rixtrw-.li. M. N. K<r- tra, S G. Unman, r. L Amo. ut frp4/- lien; i. W. KitctifM.ih, in prrparaiam. 10. T. E. RaiUr ami J- K. I(fintini, J. m ,{. ECIaMrATID.i. Am . S*e. Lmtn. I), 27 11. A. W. Breidentarh, C, G. Cunnciu*. F. K. Kivihin, i, J. .Llurnuii.', K 5 Crrm, FmbUt Utmiih Kept. 12. 11 (IK7); II. p. NeioliM, Setrmrr 1SB, *7! (1947). 12. Scnppi louituikm & O rranorraphr. 12. G. M. Wood-tll, Set. Amtr. Iti. 2 (19C7). W. Swnwied 9f NSr (j/am GP U) ad ONE 7 FcW uiy IMI showing the micros! rueturc Of undis turbed marine days; he concluded that the micrusmiciurc of such clays "cor responds to the ardhouNC structure sug gested by Goldschmidt and later by Lambe, and iti faet exactly corresponds lo Ihe imaginative drawing of Tan.** Use of Ihc same technique for studying illiiic Pleistocene clays led to a similar conclusion (7). Whereas the electron mieroscopc of fers the best means available for study of sediment microstructure in detail, the replication technique does not pro vide easily ;interpretable results. My purpose is to illustrate Ihe microsiruc- Microsrucure of Sediments: ;* 9 ture in samples of sediment from the Gulf of Mexico as revealed by ultra- Investigation with Ultrathin Sections * thin sections ^of the sediment, and to point out that this technique provides Abstract. Eiflinination of ultrathin iscclions of "undisturbed" murine sediments more easily interpretable results. from the Gulf of Mexico indicates tfot they are characterized by a loose, open, The samples (Table 1) came from ranndotm arrangement of particles. The microstruciares do not appear to conform cores taken by R.V. Alaminos ( ). punlitriree!l'y to either cardhouse or honeycomb structures. Only cores were selected that had. been property scaled and stored to preserve yhc xnicrostruciure ("fabric") I f ^cll of the structure consists of many ns well ns possible the natural state of marine sediments has received liule ni- adhering particles (Fig. ]A ). Later was the sediment. From each core n cubic teniiqn from geological occanographcti. suggested (2, 3) a somewhat different sample of 2 to 5 cm was carefully cut Two popular theories prevail as to the structure in whieh the clay-mineral ag with a thin-bladcd knife or spatula. A nature'yaf ihc panicle arrangement in gregate, having a platy morphology, larger portion was cut initially in order sediments. Tcrzaghi ( / ) suggested were arranged generally in an edge-to- to retain an undisturbed portion in the a "honcy^nib" structure, with adhesive faec fashion forming a "cardhouse" center of the sample; likewise, the sam forces causing the panieles of clay miii structure (Fig. IB). Tan (4) presented ple itself vas taken front the center of crai to stick together on contact; each a three-dimensional idealization of each core. From each sample, smaller cardhouse stfueturc (Fig. 1C). samples (1 to 2 cm by 2 to 3 mm5) While some orientation studies, using were cut with a taut, very thin wire; polarized light and x-ray diffraction ihc outer, disturbed portion of each K-'fti- techniques (5 ), can reveal gross trends large sample was first trimmed with the toward preferred or random orientation wire to expose the inner, undisturbed foCB T T * ! bf' "Vip^& iTiPttuin^^iaWpTCT'wir'e'ftte-v of the microstruciurv. Most informa dried; this technique is recommended Fie. I. (A) Honeycomb structure (after Terzachi (/)]. (B) 'Cardhouse itraf- tion has come from the electron mi (tf. 9) because it entails leu panicle croscope. Roscnquist (6) used the elec disturbance due to effects of surface ture (after Lambe (J)JV tron microscope and the replication tension than do standard oven- or air- bouse structure (after Tea technique to obtain siercomicrographi drying techniques. Fig. 2. U lm thin acciium showing the micruuruclurcs of undisturbed rdimena from an abyssal pi ami a continental shelf (C ). * 72 mnenla! slope (B ). PC3: AN INDUSTRY FR03Ii>r7 000055 P olina 1. Origin of Currant Concern - Ecological Effects 2. Tbxidty, Fire and Other Health Hazards 3. General Electric Usage U* Disposal Practices 5. Qiestions to be Answered 6. A Proposed Progran 4 s "v-- v . .. -j.+ k -- - - v v . - J. S. Nelson Corporate Ihgineering October 30# 19u9 2 ( 73 P C B : AN INDUSTRY PROBLEM? 1 Origin of Current Concern - Ecological Effects Late in February, 1969, * West Coast newspaper carried a major feature about a menacing new pollutant" found in the San Francisco Bay area. The article was based oh marine life research carried out by Dr. Robert Risehrough of- the University of California. The article stated that residues of pesticides (DDT end DDE) and* polychlorinated biphenyl (PCB) were threatening the welfare of certain birds and posed long-term threat to humans.1 The following is Nature's synopsis of Dr. Rlsebrough'e paper:^ Polychlorinated biphenyls are widely dispersed in the global eeosystaa, and are powerful Inducers of hepatic enzymes which degrade estradiol. Tbgether with other chlorinated biocides, such as DDT, they could account for a large part of the aberration in calcium metabolism which has been observed in many species of birds since the Second World War These excerpts are representative of press coverage :3 PCB!s are produced under the trade name Aroclor by Monsanto Chemical Cornany, St. Louis. They were first identified in European birds by Swedish scientists. They apparently are released into the atmosphere and waterways by vaporizing, from factory smokestacks, by discharge into rivers and oceans...* A team of University of California and Oomell University scientists has determined that PCB's are five times more power ful than DDT in hormone-destroying activity, like DDT, they are .found throughout the environment and their quantities are increasing .japidly.-^Tlwy* ha*_be.^ibund*div-^h.jdlk jof-narfiingrinQiher.s Colorado and in marine life off California, as well as in European birds,..* What effects PCB's will have on man is not known, although in vapor form these chemicals are highly toric....the federal govern ment has not eet tolerance limits....tonsanto Company spokesmen say only that their scientists end sales executives are studying the problem.... 2. Tbod.city. Fire and Other Health Hazards Gorpany literature has long contained cautionary notes on the handling of Pyranpl (the C. K. registered trademark for chlorinated diphenyls). For example: 4 FVoa & Statement by the Monsanto Cbrpany, St. Louis, Mo., 3"3"69 2. Polychlorinated Biphenyls in the Global Ecosystem", by Risebrough, Rieche, Peakall, Herman, end Kirven, Nature. Vol. 220, Dec. 11, 1968. 3. Gainesville, Florida, Sun, April 25, 1969 1. Instructions GET-65080~(Il-4 1M): Pyranol Insulating Liquid and TTa D ry in g . o / *J A PCS: An Industry Probien? 1 ft'ansformer Pyranol can be handled in the Banner as mineral oil. Although continued eaqposure to liquid Pyranol nay produce local skin irritation, cleanliness among workmen constitutes an . adequate safeguard against such effects.... As with rest volatile materials, exposure to concentrated Pyranol vapors in unventilated zooms should be avoided. ** CAUTION-- Hydrogen chloride gas is formed when pyranol is decomposed by an electrical arc.... Early this year, an inquiry was received by Hr. John J. Perry, Specialist-Environmental Health Fhgineerlng, Schenectady from an Industrial hygienist at Fbrd Motor Company, as to the toxicity and fire hazard of transformer askarel. The following is extracted from the Hedlum Transformer Department's reply to the Ford question naire: 5 Material: #Pyranol A5QP524 Cbnponents: trlchloroblphenyl 60$ tri chlorobenzene 11.5? tetrachlorobenzene 5*5? diepoxide scavenger 0.125? Tbxidty: * ingestion -- highly toxic inhalation -- moderate respiratory tract -- moderate Skin Sensitizer: No. _ ....... Is material flancable? No. What products might be formed in the event of fire or abnormal temperature? In an incinerator burner designed for the disposal of chlorinated solvents, the products of combustion will be HCL end 002* In considering the question of flamiability, it should be kept in mind that askarels are chosen for Insulation applications partly because they are, "by definition", non-flamable liquids which, whan decomposed by electric arc, evolve only non-esplosiye gaseous mixtures. Recently discovered exceptions have been reported, and Medium Transformer Department has at least temporarily abandoned the use of A50P524, based on Arodor 1242, In favor of the "classical" Aroclor 1254 (*IS A1333B). Some people have sensitivity to Pyranol such that their skin erupts In a rash upon exposure. When discovered in the factory, they are transferred to 5* Transmitted with letter from F. J. McCann. Medium Eransforaer Department to R. G. Anderson, Fbrd Motor Company, 2-5-69. See letters from C. C. Fouls en, Hgr.-Ihgrg. # HDT to Classanoo Haywood, PozefsJy, and Deck, under dates of J-27-69 and ft-5-69 O 75 c PCB: An In d u s try Problem? -3 other* lines of wark and their symptoms disappear. The broad class of materials we are dealing with here, polycyclic aromatics, contains known or suspected carcinogens. This aspect has been considered in the industrial hygiene or medical review of operations in at least one plant. 3. General Electric Usage EHPIS speciCications list aervea different formulations of Pyranol. The basic material is chlorinated diphenyl purchased from Monsanto under the desig nation Aroclor 1254, Aroclor 1242, and Aroclor 1260. These are blended with other chlorinated aromatics, Inhibitors, and scavengers to produce other askarels with different characteristics, all designated by the GE registered trademark, Pyranol. Product responsibility is assigned to the Medium Transformer Department, Rome, Georgia, presumably because HID sells Pyranol to customers who fill their transformers or other equipment in their own hops. The following is a list of departments assumed to be using Pyranol in the dielectric systems of products manufactured in-house: C Industrial and Power Capacitor Department Specialty Transformer Department? Wire and Cable Department? Commercial Distribution Transformer Department Lighting Systems Department? Medium Transformer Department <V Power Transformer Department Canadian General Electric Company 'S e rv ic e 'Shop's - - vr . v,- Ibtal usage has not been ascertained. The Transformer Departments have in recent years cut their relative use of Pyranol, limiting it to cases where the non.^mmrcability property is very important, such as indoor applications. (They axe using -aliphati e.hydro carbons, especially one known as ^lG-C*.) As a result of this trendy the Power Transformer Department at Pittsfield uses Pyranol in only about of its units, and Residential Distribution Transformer Department, at Hickory, uses none. lo search has been made for non-dielectric applications of Pyranol. Such may conceivably include use as a hydraulic fluid (e.g. in airo*aft or materials- handling systems); heat transfer applications; and as a plasticizer in the production of polymers used as adhesives, elastomers, or surface coatings. The largest user is the Industrial and Power Capacitor Department, Hudson Kalis, N. Y., which uses 10 million pounds per year -- probably more than the rest of the Company, combined. 2 1 76 | PCB: An In d u s try Problem? f L L D isposal P ra c tic e s The I n d u s t r i a l and row er Capacitor Department purchases approxim ately 10 m illio n pounds p e r y e a r, o f which 9 m illio n pounds are accounted f o r in term s o f p ro d u cts shipped. Waste i s handled in the follow ing manner: Re claim able m a te ria l re tu rn e d to rbnaanto 200,000 lh ./y r . Badly contam inated m a te ria l hauled away by a New J e rs e y acavenger (recomended by lb ns anto ) 000,000 Contained in scrapped sm all in d u stria l u n i t s d isposed in town dump, where d a ily b u ria l i s thought to be the practice T otal w aste and scrap , approx. 60,000 TJb60,000 lb ./y r., r At v ario u s tim es in the p a s t, o th er d isp o sa l methods have been used, in clu d in g sa le to a m anufacturer o f in se c tic id e ; in th e recent p a st, a t le a s t one re p re s e n ta tiv e o f th e Ibnsanto Company was re coranending i t s u se , alone o r in combination with m ineral o ils , as a road spray to a lla y d u st.7 At P i t t s f i e l d , th e r e has been some experim entation w ith a decom position chamber which f i r e s a t JOOO P ., but th e bulk o f contaminated m a te ria l i s s o ld ; a t Dome, w aste i s b u ried on th e Cocpany s i t e . Although nearby neighbors have shallow w e lls , no com plaints have been r e g is te r e d .^ 5. Q -iestlons to be Answered I t i s apparent from th e above d iscu ssio n th a t our knowledge of c h lo rin a te d d ip h e ry l fo r n ila tio n s and p o ssib le d e le te rio u s e ffe c ts i s not as complete as i s d e s ir a b le in today* clim ate o f concern f o r m aintaining and improving th e q u a li t y o f l i f e in i t s environmental aspects, w ith regard to worker protection, and in terms of product sa fety . N evertheless, i t is not responsive to suggest th a t "o th e r m a te ria ls be s u b s titu te d " u n t i l a l l doubts a re reso lv ed . I t must be-* remembered t h a t v i r t u a l l y *1*1 a p p lic a tio n s o f P yranol a re th e end product o f in te n siv e research d irec te d toward finding the b est m aterial for the ap p licatio n ; th a t s u b s titu tio n would involve tra d e -o ffs , not only w ith performance fa c to rs and economic fa c to r s , but w ith product sa fe ty considerations themselves -- i . e . , f l a m a b i l i t 7 and explosion p o s s ib ilitie s . While i t is d e sira b le to a tta in a b e tte r q u a n titativ e expression o f th e to x i e f f e c t o f PCB and i t s v a rio u s a d d itiv e s , and a b e tt e r understanding o f th e fla rm a b ility o f degradation products, the most im portant question, long ran g e, appears to b o , "does i n d u s t r i a l use o f PCB re p re s e n t a c re d ib le eco lo g ical th r e a t? 78 7 . L e tte r from T. W. Oneaon, Ksnsanto S a le s R e p re se n ta tiv e , to V. R. Mulhal l , Canadian General E le c tric Co., L td ., Peterborough, 11-12-68. 8. L e tte r , Dr. J . S. Anderson (RECO) to Mr. 7 . R. M ilh a ll, CGE, 12-20--68. 2l 77 PCS: An Industry Problem? One circumstance which makes it difficult to answer the question of ecological effects is that PC3 has not been found alone in any of the reported observations of nature, tout always accompanied by larger quantities of DDT or nng1 In the work previously cited, Dr. Risebrough has shown, by direct intra-mscular injection, that PCS has "the capacity to produce sublethal-physiological effects in birds" -- but this ie not the same thing as eaying that it does, in fact, do so outside of the laboratory. Scientific emaainatioa of this question degenerated, at the Wisconsin hearings on DDT, into a shouting contest between partisans of conservation (who seem willing to ban az^ chemical, regardless of lta otherwise beneficent results, if it ie suspected of harm); the makers of insecticides (e.g., Shell Gocpany); and the producer of PCS (Monsanto). The same witnesses have been quoted on both sides of the question. The reader may choose between the following statements, each attributed by the press to Dr. Eisebrough: (a) (PCS is) apparently playing s role in the decline of the peregrine falcon and it may have abetted the disappearance from the Gulf Coast of the bxcwn pelican. (San Fraacisoo . Examiner, Fbbi 25, 1969). (b) Tests with eggs..showed mathematically by oorrelatlon with eggshell thiclciess that DDE and not PCB's were to blame. (Milwaukee Sentinel, May 13, 1969).?? Ironically, the second statement was made when Dr. Risebrough was called to the stand by the attorney defending the insecticide interests* Should it be established that PCB is to blase for ecological damage, it remains to trace the transport mechanism and determine at least plausible sources ' and sets of conditions for propagation into the environment. Estimating from GS ^cipacftor tS5^ge^'total^dnduat^Jusago.,mig]\tJj?J2Q.Jto.{# million pounds, most of which ends up in closed systems from which dispersion ia^etf*a Veiy=16v/vt%te>'tThir' contrasts xlth such larger usage of DDT -- 160 million pounds in 1963, 103 million pounds in 1967 -- * most of which is broadcast on the landin the atmosphere. Monsanto has a research program to identify the compounds reported to be PCB by the Swedish and California scientists. This involves preciss analysis of environmental samples of -*' water, air, eoil and wildlife, including metabolic studies. Also under way are studies to determine the biological effects of deliberate dosage of PCB's on fish, birds, and mammalian animals. Special emphasis ie being paid to endocrinological effects, mineral metabolism and reproduction piy^iol^gy! As we become more pollution conscious, we wish to know what volume of unused Aokarel ie being burled, eewered or incinerated on the North American continent, particularly, and what hazards does it present. What degree of responsibility should Ibnsanto shoulder in this affair? Will it be necessary to diligently collect unusable Askarel, including Ask&rel-satursted fuller's earth, and develop techniques to destroy it? Should we return it to our factories for chemical decomposition? We mist answer these questions soon. 7 PCS: An Industry rrab lea? 6 Ihe above quotations Indicate Monsanto's concern >dth the ecological effects and state some of the questions to be answered, lionsante is the only U. S. supplierj hit additional information may be ought from European end Japanese, suppliers. Prodelec, in loanee, 1 the principal continental source of PCB, and rain tains a large toxicological laboratory. About three months ago, Kr. K. E. Sooville, Product ^fety Kepresmtative of .the Industrial and Fower Capacitor Department, wrote to Kr. Pierre Jay, Manager-Dielectric fluids Developaent for Prodelec, calling attention to the Risebrough research and asking for cem en ts and further information. Ho reply has been received as yet. 6. A Proposed Program * The Coroany1 stance on the PG3 situation mist take Into consideration not only the need for technical assessment of hazards, but the need to guard against veU-cotlv&ted hit possibly needless or precipitate legislative action, e.g., to tack a PC3 rider onto an antl-DDT bill. As a first step, it la suggested that an outside consultant, with more freedom to operate than our own people, be engaged to sort through the conflicting evidence, touch base with the people doing the research at Monsanto, and give us his views as to whether the Company needs to da anything further at this time. Ihis consultant would combine, ideally, the disciplines of analytical chemistry, ecology and toricology. He vould be asked to spend not more than two weeks on this initial survey, and report informally to Interested departments and Corporate functional components. Depmding upon his findings, a possible second step vould be to sigage appropriate industry technical body (e.g., the dlelectric'Cocrnltte~e Vf'flEBfJJ' The above reooranandatlon is the outcome of discussions between Drs. Anderson end Hirpiy of REQ3. (enviromental pollution); Mr. E. K. Deck (Safety and Plant Protection); end Messrs. Marquis and Nelson (Product Safety). It has b e d reviewed at length with Dr. Pozefsly, Dr. George, Mr. Scoville and others at Hudson Falls, and briefly with Mr. Alimansky and Dr. Osthoff at Pittsfield, all of'whoa have eooressed general agreement. Kr, Deck has suggested that we oonsider Dr. Horace W. Gerard, a toricologist at Fhirleigh Dickinson University for the assignment as our liaison scientist. Dr. Gerard is a hydrocarbon ecpperl who does much work fbr the Mobil Company and has carried out assignments for GE in the past. J. S. Nelson October 30> 1969 2 ( 79 THE USE AND DISPOSAL 0? ELECTRICAL INSULATING LIQUIDS Prepared by Corporate S ta f f G eneral E le c tr ic Company .December 21, 1970 t : *k'3r, * ADM 007720 1 the use and disposal of electrical insulating liq u id s c A bstract E le c tr ic a l in su la tin g liq u id s (EIL), th e ir a p p lic a tio n and d isp o sal a re studied ag ain st a background of s im ila r inform ation re la tin g to -petroleum products in to ta l. L ubricating o ils arc selected for p a rtic u la r a tte n tio n because of th e ir chemical and physical sim i l a r i ty to petroleum in su latin g liq u id s . N aphthenic m ineral o i l s are found to com prise over SO p e rc e n t by volume of the to ta l usage of EIL. Polybutenes are second, a t alm ost 10 p e rc e n t. Thus, 90 p ercent o f EIL a r e petroleum -based. Being , r e l a t i v e l y nontoxic and biodegradable, they re p re s e n t no environ m ental th r e a t when su b jected to co n v en tio n al secondary waste tre a tn e n t. The th ir d largest-volum e EIL group i s the a s k a r c ls , o r p olychlorob ip h e r y ls . This group has some to > le p r o p e r tie s and c o n ta in s members which have re c e n tly become s u s p e c t e c o lo g ic a lly . Accord in g ly , the rep o rt contains reeoamendations regarding the control and disposition of ssk arels. % i -- '-r. t I*,*, - V. -i X -H, - v.-.'-L V , j ADM 0 0 7 7 2 3 . 81 IKTRCSKICTIOX This study o f Che use and d isp o sa l o f e l e c t r i c a l in s u la tin g liq u id s has been undertaken in support of the objectives of the E le c tric and Nuclear Sub-Council of the N ational In d u stria l Pollution Control Council. I ts purpose is to examine e l e c t r i c a l in s u la tin g liq u id s (EIL) f o r t h e i r p o s s ib le to x ic o lo g ic a l o r e c o lo g ic a l im pact and, as a p p ro p ria te , to providn info rm atio n which may lead to ad v ice concerning government programs which would f a c i l i t a t e p riv a te s e c to r e f f o r t s d ir e c te d a t environm ental improvement, o r v o lu n ta ry a c tio n s by in d u stry S p e c ific a re a s o f i n t e r e s t Include p o llu tio n which may occur from the p la n ts where EIL a re used in m anufacture of e l e c t r i c a l a p p a ra tu s, and th a t which may occur during use or disposal. A v a rie ty of in su la tin g liq u id s is used In e le c tr ic a l apparatus such as trsn sfo rm ers, c i r c u i t breakers, c a p a c ito rs, and nigh -v o ltag e cable in order to o p tim ize, f o r each a p p lic a tio n , a range of design param eters ty p ifie d by d ie le c tr ic stre n g th , lo sses, d issip a tio n fac to r, arc and flame suppression, h e a t tr a n s f e r c o e ff ic ie n t, and product l i f e expectancy. Requirements and conditions to be met w ill, ln rt given instance, quickly narrow the p ra c tic a l o p tio n s a v a ila b le to the d e sig n e r down to a very few o r even to a s in g le f l u i d . F o r t h is reason I t should be borne In mind t h a t , even though a p a r t i c u l a r e l e c t r i c e l In s u la tin g liq u id may be c h a ra c te riz e d as co n ta in in g the p o te n tia l of contributing to the p o llu tio n uf th environment, the e o c la lly - d c s ir a b lc and econom ically c o rre c t a c tio n may l i e in the adoption o f precautions and control measures rath e r than in the s u b s titu tio n of a m ate ria l which would not perform the required fu n ctio n as w ell. R e p re se n ta tiv e s o f many o rg a n iz a tio n s, both in in d u s try and in government (se e , SOURCES OF INFORMATION), have c o n trib u te d in fo rm a tio n and su g g e stio n s; th e ir cooperation and helpfulness are acknowledged w ith thanks. * ADM 0 0 7 7 2 2 i 3 * c % w c * -a. - u s 1.0 T o ta l Flow ..of Petroleum products Because a high percentage of the to ta l volume o f e le c tr ic a l in s u la tin g liq u id s i s petroleum based,, the use and d is p o s itio n of EIL can b est be understood g a in s t a background o f Che q u a n titie s of petroleum products used throughout the economy, and Iiou they a re disposed o f . a* Table Ho. 1 d is p la y s the q u a n titie s and uses o f petroleum products in th e U .S. f o r 1963 (th e most recent year fo r which r e l a t i v e l y complete d a ta could be searched o u t) . The q u an tity on th is ta b le o f g r e a te s t i n t e r e s t is item 3,12, E l e c t r i c a l In s u la tin g O il. Hie q u a n tity shown, 1 .4 m illio n b a r r e ls , i s the t o t a l o f naphthenic end polybuccne EIL, and corresponds to 0.04% o f " a l l o i l s . " --1*1 L u b ric a tin g O il -- ------- ,a L u b ric a tin g o i l (Table 1, Item 3.7) was chosen fo r a com parative s tu d / because of i t s sim ila rity to e le c tric a l in su latin g grades of petroleum o il, and because d a ta r r c a v a ila b le from which a reasonable e stim a te can be formed o f vhat happens tt lu b ric an ts throughout th e ir l if e h isto ry . L u b ric a n ts may be c la s s if ie d conveniently in two groups: autom otive a:id i n d u s t r i a l . Table No. 2 Is an estim ate o f the usage, w aste g e n e ra tio n , end ' d is p o s itio n o f autom otive lu b ric a n ts throughout the country, and Table No. 3 p re s e n ts s im ila r d a ta fo r in d u s tr ia l lu b ric a tin g o i l s . A larg e p o rtio n of *:he w aste generated i s c o lle c te d by scavenging firm s, and the r a te of th is p o rtio n i s in d ic a te d in Table No. 4 . Table No. 3 suniuirlzes the r e s u lts of the " in v e s t i g a t i o n of lu b r ic a tin g o i l waste p r a e tic c s . I t w i l l be noted th a t a l i t t l e over h a lf of a l l lu b ricatin g o il ends as w aste, and of th is h a lf, ' more than h a lf i s sim ply dumped on th ground in one way o r an o th er - a s l o c a lly disposed w aste, as road o i l , in town dumps, e t c . 2 .0 Q u an titie s and Usage of E le c tric a l In su la tin g L iq u id s- . . * y *. * 4" Table No. 6 c o n ta in s a breakdown o f the p r in c ip a l uses o f naphthenic - m in e ral o i l a s an in s u la tin g liq u id . The Inform ation on transform er and cable o i l s was d eriv ed from the market estim ates o f s e v e ra l o i l producers ( R e f e r e n c e : OFLXNFOSFtftTTONj-te&^^F.^Sufctfrhfcea-frK-e urQ-breakc-rJr.duca -* c a p a e ito r d a ta were estim ated from General E le c tr ic usage and assumed m arket p o s it i o n . The second column o f data, th a t on f ie ld use, i s a measure of the g e n e ra tio n o f w aste o i l during the use o f the a p p a ra tu s . The t o t a l , 8 1/2 m illio n g a llo n ! , la e q u iv a le n t to 0 . 8% o f the w aste lu b ric a n t o i l shown on th e prev io u s Table (Ho. 3 ) . * t | ( i ( \ c ADN 00T J23 83 /i Tabic No. 7 i* s im ila rly derived and p re se n ts an a n a ly s is of the to ta l q u a n tity o f 1L according to the apparatus in which- i t is used. The f i r s t two e n t r i c i , naphthenic o i l and polybutenc liq u id , were added to g eth er to produce the t o t a l recorded as Item 3.12 in Table No. 1 ( i . c . , 57.26 m illio n g a llo n s i s e q u al to 1.36 n i l l i o n petroleum b a r r e ls ) . This s u b to ta l i s 912 of the t o t a l e stim a te d annual usage o f IL . The .to ta l is 63 B illio n g a llo n s , o r 1.5 m illio n b a rre ls . , * The c h lo rin a te d benzenes shown'are not used a lo n e , but as d ilu e n ts fo r th e s h a r d s , in some a p p lic a tio n s . The categ o ry , "other*1, in clu d es r e l a t i v e l y small q u a n titie s of such m aterials as dibutyl scbacate and silic o n e o i l, used in s p e c ia liz e d a p p aratu s o f low production q u a n ti ti e s . S p c c if ie a tic n s and g en eral c h a ra c te riz a tio n o f the p r in c ip a l XL a re shown in Table No. 8 * 3.0 Toxicology M ineral o i l s and polybutenes a re e s s e n tia lly n o n to x ic. The only re p o rte d danger i s from in h a la tio n o f vapor or m is ts, in which the maximum allow able concentration is 5 parts per m illion. The e s k a r c ls a re regarded as somewhat to x ic w ith regard to In g e s tio n , sk in a b s o rp tio n , and I n h a la tio n . The maximum allow able c o n c e n tra tio n fo r in h a la tio n i s 0 .5 p a r ts p e r m illio n . Because of the low v o l a t i l i t y , th ere i s l i t t l e chance of harmful atm ospheric concentration being developed a t ordinary tem peratures. Aakarels My produce local shin ir r ita tio n s in su scep tib le Individuals, but ordinary cleanliness co n stitu tes an adequate safeguard ag ain st such e f f e c t s . A drop o f c a s to r o i l w ill n e u tr a liz e any i r r i t a e i o n caused by c o n ta c t w ith th e eyes. The response to excessive in g e s tio n i s to induce vom iting and see a physician. 4 .0 Ecology Mr. Claude . ZoBcll has w ritte n , "M ineral o ils are susceptible to m icrobial o xidation, and c e rta in fra c tio n s undergo a u to x id a e io n . This seems to be N a tu re 's way of remedying o i l p o llu tio n In s o i l as v e i l as in sea w a te r ... Zn c o n tro lle d lab o ra to ry e x p e ri- .jacj)tiji. avert ann>orc^e- 0-40: -pa^emvt o f the carbon content of hydrocarbons into b a c te ria l c e ll substance or proto plasm ." (Caf. b-12). . M ineral o i l a and polybutenes a re not known to have a long tim e e f f e c t - upon the e c o lo g y . In the s h o rt te rn , the e ffe c e o f la rg e s c a le dumping o f hydrocarbons has been w ell a d v e rtise d in Che p r e s s . Small amounts have no d e trim e n ta l e f f e c t s . The m a te ria ls , in s h o rt, a re bio d eg rad ab le, e x is t n a tu ra lly in the ecology, and are not thought to be a problem In the context o f th is study. - 007724 84 I . % i. s 5 . The a s k e r c is , p a r tic u la r ly those w ith more than 502 c h lo rin a tio n , h.-.ve rec e n tly been id e n tifie d as a po ssib le ecological th re a t to marine and b ird l i f e . The a t t e n ti o n o f the lu d u stry was c a lle d to th is su b je c t in a w idely d is tr ib u te d l e t t e r from the Monsanto Chemical Company (sole U.S. p ro d u ce r), under the d a te c< February 1C, 1970. AsUarels introduced in to the ecology a rc b e lie v ed to a c t In a manner somewhat analogous to the p e r s is te n t p c s i i cid cs, being eoi.centratcd in successive links o f the food chain. j j j / I For th e sh e rt^ te rm , e f f e c ts of a s k a rc ls may be k ep t from the environm ent by a p p lic a tio n cniy In closed systems (of which transform ers and c a p a c ito rs a re exam ples) and by the e x e rc is e o f s u ita b le p rec a u tio n s in the d is p o s itio n o f w aste, as o u tlin ed below. For the longer term, the m anufacturer is working to develop m odified c h lo rin a te d friphcnyls which w ill be biodegradab le . This means t h a t even i f m inute q u a n titie s a re re Teased to the environment by a c c i d e n ta l s p i l l s , i t w i l l be p o ssib le to remove them from waste w ater stream s in conventional secondary treatm ent f a c ilitie s . (Reference b-15, quoting a l e t t e r from Monsanto to Congressman Ryan, June 30, 1970.) 5*0 Recommendations In view o f the suspected' e c o lo g ic a l hazard presented by polychlorina'.ed b ip h e n y ls, i t Is reconmended th a t the e l e c t r i c a l in d u stry employ the follow ing guidelines In th eir use: 1 . P ro v isio n Is to be made fo r q u a lifie d d e s tr u c tio n of FCB w aste m t c r i a l : such t h a t th ere w i l l be no re le a s e o f m a te ria ls to the atm osphere or to ground o r su rface w ater s ig n if ic a n t from the stan d p o in t of to x ic ity o r adverse eco lo g ical im pact. I n i t i a l l y , the only process which appear? fo meet these requirem ents is in c in e ra tio n under c a re fu lly co n tro lle d con d itio n s . V ith proper adjustm ent of tem perature,' residence time in the I n c in e r a to r , and o th e r param eters, products o f combustion w i l l be lim ite d to 1IC1, C02j and H20 (In the form of steam ). The h y d ro ch lo ric a c id ra y be absorbed in a scrubber and the re s u lta n t so lu tio n n eu tralized with lime to form calcium chloride so lu tio n , Ca&2 In the process d escrib ed , the only e f f lu e n ts to the environm enc^vlll be a plume of steam, carbon dioxide, and b rin e . '/ 2 . A ll liq u id waste is to be held In Impervious containers pending disposal. . j 3 . S o lid s contam inated by PCB's a re to be held in impervious c o n ta in e rs * * * jQ*wpur-6i_n&.-vPut.sing.5jay. bq^.caignplisheiL byvc leaning. w ith p ro p e r f lu i d s . The r e s u ltin g contam inated liq u id s cay be in c in e ra te d f aa above. `. 1 As. a r e s u l t o f the Monsanto l e t t e r to the in d u stry c lta d above, th e In d u stry l e i b e lie v ed to have progressed a long way toward the im plem entation o f th ese ( recooxDcndaeioas > t ADM 0 0 7 7 2 5 85 GENERAL E L E C T R I C CO MP A N Y JOt min. HUDSON PAUS, Hiw TOtJCmat . . . AUACOM Iti. TfllTHONI 747*3141 INDUSTRIAL AND POWER CAPACITOR DEPARTMENT */ A p r i l 1 2 , 1972 . I - Mr. P . C. B enignus, M onsanto Coopany Mr* N. R. C lark ., U n i v e r s a l M a n u fa c tu rin g Company M r. A. S . D oty, P . R. M allory C o., In c . / M r. E. G. Hammer, M cG rv-E dlson Power System s D iv is io n M r. J . F . K u z e la , Sangano E l e c t r i c Company H r. F . R. L e n g e fe ld , U nion E l e c t r i c Company Mr. R. D. M cC lain, W estinghouse E le c tr ic Corp. D r. E . M. M oore, E l e c t r i c U t i l i t i e s ' Company M r. V. P . Papa g e o rg e , M onsanto Company Mr. R. L. R o llin s , J a r d , In c , L M r. E. L. R aab, G e n e ra l E l e c t r i c Company H r. A. K. S a l a z a r , NEMA Mr. John S o d a la k l, E le c tro n ic In d u a trle a Aaaoc. c Enclosed is v h at I hope w ill be th e f in a l rev ised G uideline fo r th e C ap acito r Group on A sk arel D lap o aal. The P re fa c e haa been tak en from the T ransform er G u id elin e. :- . T here a re a re a s where both the Transform er and C ap acito r G uidelines read e s s e n t i a l l y th e sam e. H ow ever, I a n t i c i p a t e t h a t b o th G u id e lin e s w i l l be '* is s u e d and used s e p a r a te l y i n many e a s e s , so t h a t t h e r e sh o u ld be no p ro b lem In redundancy. ^ %...-a,raw . * w ^ if * ; - j, ` ' l r*-- i. *'*- -* r_- v I h a v e d l a c u i a e d w i t h A1 S a l a z a r t h e p o s s i b i l i t y o f u s in g th e G u id e lin e on an i n t e r i m b a s i s u n d e r NBiA a n d /o r EIA s p o n s o r s h ip u n t i l s u c h tim e a s th e G u id e - * l i n e i s is s u e d o f f i c i a l l y by ANSI. Ve sh o u ld a tte m p t to re a c h a d e c is io n .o n th is a t the next m eeting. Z e x p e c t t h a t tha* f u l l ANSI Com m ittac sh o u ld b e m e e tin g w ith in a b o u t a m onth to f i n a l l y approva th a g u ld e lin ts f o r rev iew by zoverum en t and o th e r members o f th e eom alttea. ^-- -- 1 j j J 1 A. P e t ti sky M anager-E ngineering Pt Enc. ADM 0 0 7 2 1 0 0 86 bcc: J. P. S tapleton y 8 , 1973 /' Or. A. P e s t f ik j C acarti X lootrio Coopta? Indtrial A Footr Capacitar Frodueta Dapartnant John Atra at ludaon I n Torte 18839 Rr. I . t . X ub Central X Itc tr io Coapaa? Tranforcar DIvi io n Boildiac 11-883 100 Voodlavn Atomi# f i t t a f i a l d , Bassachuaatts 01801 tCtlaMCS A racant ln c ld e a t in hlafc a ta ra i f l u i i la a fermaafoni od it a v7 to th oustcnar maa parai Ita <3 teo Arala onfeo faraland d r a g a tic e li? biffai lfh ta th naad fa r a p a clfla laaferuotloas thafe ama be aada avallatola to privata and p u b lic ca rriera to Ina trae t febea l a tfc propar bandi ine f aakarala durine entra ano? o a od ltlon a. '^ r o 3 o b i ^ t f c i i a t " ^ u r ''atiio ^ ^ v appropriata falda lina that aoold appi? to tbla t?pt o f alfeaafeloa and ahlab aoald bo in a i adi i l a tho AMI Coaltfeaa C-107 aakiral fu id e lin a * . V B. V ip a ta o ift AB8Z C om lttoa 0-lflT W /b t aat Br. ? . B. l>n1fT>aa S tearin e C oM lttoa Chal ABBI Coonlttoa C-1C7 Br. A. H Salaaar- Secretar? TPanafomar Settima and M I C-10f ADM 0 0 7 7 1 1 6ei:eral@ elecjic CENERAI. ELECTRIC COMPANY. ONE RIVER ROAO. ECHENECTAOY, NEW YORK 12345 PhOM (111) 274*2211 MAL 1 8TAT E ANO CO N 8TRUC OPERATION November 21t 1973 * Dr. C. Hugh Thompson, Chairman Hazardous and Toxic Substance Regulation Task Force Office of Water Program Operations Environmental Protection Agency Washington, D.C. 20460 Dear Dr. Thompson: SUBJECT: CCWENTS ON TOXIC POLLUTANT EFFLUENT STANDARDS (38 FR 21342, Sept. 7, 1973) In the above Federal Register announcement, the Environmental Protection Agency Invited comments that might assist 1t 1n setting effluent standards for the pollutants on EPA's f ir s t 11st of toxic pollutants. On behalf of the General Electric Comoany, I am pleased to submit for your consideration the following corrcents that we believe are relevant to the establishment of effluent standards for polychlorinated biphenyls (PC3s). The General Electric Company 1s a major manufacturer of sealed capacitors and transformers that Incorporate PCBs as Insulating liquids. .. COMMENTS *i In promulgating Its 11st of toxic pollutants; EPA stated that "Polychlorinated biphenyls are on the 11st because of th eir hich order of to x icity to ran and aquatic organisms, and because' of th e irfiio accumulative potential. The data are adequate, and the point source discharges require prompt co n tro l." (unaerlinings added! \ In an e a rlie r section of th is same promulgation (I, 3), which , explains the c rite ria of to x ic ity , appears the statement that "substances j which have an oral LD50 of 50 mg/kg of body weight or less . . . are defined t es highly toxic to ma^als This definition would seem to exclude i PCBs, because the LC50*s of all commercial preparations are many times ^ greater, th a t of a typical material (Aroclor 1242) being 8650 mg/kg ' 1*. l^PCBs and the Environnent, Interdepartmental Task Force on PCBs, May 1972, p. 131.------------------------ SP.Y1MG POGUSS ADM C072o0 88 6ENIRAI ELECTRIC I Dr. C. Hugh Thompson * -2- November 21, 1973 The low order of toxicity to man 1s supported by several decades of experience 1n the U.S. electrical Industry. In addition, the foregoing statements about PCBs quoted from the promulgation receive l i t t l e support from EPA's subsequent publication In October of Its "Proposed C riteria for Hater Quality - Vol. I . "(2j These c rite ria "are defined as the acceptable lim its of constituents 1n receiving waters based upon an evaluation of the la te st sc ien tific Information by the Environmental Protection Agency" (p. 12) and "are based upon current knowledge of the effects on health and welfare of the presence of various pollutants 1n receiving waters" (p. 18). C riteria fo r PC8s are discussed under four categories of water use (pages 121, 180, 224, and 320) along with the rationale for the' recorrcnended lim its. None of these discussions suggests biological effects th a t could be described as a "high order of toxicity to man and aquatic organisms"; most of the rationales represent fa r from "adequate" data; and none of them leads to the conclusion that "point source discharges require prompt control." , The only numerical value suggested 1s a maximum acceptable concentration of PCBs 1n fresh water of 0.002 /f g/1 (0.002 ppb) (p. 121). The rationale given for th is level Is based upon an exceedingly tenuous chain of reasoning beginning with a PCB residue level that has been suggested (not demonstrated; as the threshold for salmon egg mortality and continuing through several other vaguely defined m ultiplicative factors. Further, this number has no operational significance because no analytical techniques are available for the reliable determination of so low a concentration of PCBs 1n water. Section 304 (a) (1) of The Federal Hater Pollution Control Act Amendments of 1972 requires that c rite ria for water quality should accurately reflect^the la te s t scien tific knowledge "on the kind and W eifv o f - Vhfc h ^ r sr Tbe expected from the presence of pollutants 1n any body of water . . . u. He submit that none of the water quality c rite ria proposed for PCBs, which presumably reflec t the la test sc ien tific knowledge, provides an adequate basis for establishing effluent standards for PCBs. Other bases than water quality should be used and are discussed la ter on In L th is le tte r . In our opinion, however, the recommendation that "the body burdens of PCB's 1n birds and maronals. should not be Increased over present levels 1n order to maintain acceptable levels" does represent a reasonable goal for any PCB control program (Ref. 2, p. 180). The Proposed Criteria for Hater Quality acknowledge (Ref. 2, pp 17-18] th a t other considerations are important 1n "establishing particular standards and control measures" for pollutants th at "may be listed as toxic pollutants under subsection 307 (a)." ^ Proposed C riteria for Hater Quality. Vol. I , U.S. Environmental Protection Agency, Gctoocr 1973. AOH 0 0 7 2 6 1 89 C E I l E m O ElECTHIC Or. C. Hugh Thompson -3 - November 21, 1973 "Scoe of the more Important considerations are: (1) The nature of the environmental effect of the presence of pollutants In water (e .g ., long or short term, temporary or permanent, localized or widespread, etc.)* (2) The economic and social Impact of the standards and control. measures and the Impact of the environmental damage to be alleviated. . (3) The p racticality and enforceability of the standards and control measures, Including the av ailab ility of techniques and instrumentation for determining whether particular standards are being met." Regarding the third consideration, we have already Indicated th a t there Is no practical method of enforcing a standard based upon the recommended maximum concentration of 0.002 ppb of PCBs for fresh water. The following additional points, which we believe should be considered 1n establishing effluent standards for PCBs, are germane to the other two considerations. (1) In 1971 the Monsanto Company (the sole U.S. producer of PCBs) began a program that has led to a total ban on sales of PCBs for all uses except the manufacture of sealed electrical equipment (capacitors and transformers). As a result there has been a large decrease In the number of point source discharges of PCBs. .Since .thWLAre. prpfea.b]y^not.jno^tJun ^S^maioc~u$e-rs*.o- .throughout-,^..,, w the country, current production-type discharges of PCBs are no longer as ubiquitous as when PCBs were a component of paints. Inks, p la stic s, adhesives, te x tile coatings, hydraulic and heat transfer flu id s, etc. Indeed, "production and sales figures for PCBs 1n 1971 were roughly half of those for 1970, when these volumes were at th e ir peak ...(an d ) projections for 1972 Indicate an even lower volume " (Ref. 1, pp. 5-10). Thus, even apart from the Introduction of improved control measures by present PCS^users, there has been a major decrease 1n the amount of PCBs to which the environment can possibly be exposed. Although current PCS discharges can and should be more, carefully controlled, the situation 1s one whose magnitude is decreasing. There 1s, therefore, no need for emergency-type controls, which might be reflected in technically Infeasible standards and compliance schedules. AQH 0 0 7 2 6 2 90 GENERAL 3* ELECTRIC Or. C. Hugh Thompson -4 - November 21, 1973 (2) PCBs ere not a unique chemical species. More than,100 Isomers are possible, and major commercial products may contain as any as 18 d istin ct compounds. As pointed out by the Interdepartmental Task Force on PCSs: Full evaluation of actual or potential effects in the environment 1s hampered by the complex nature of the Ixtures th at compose PCBs, and by the Inclusion of ' , contaminants 1n these mixtures. As experimental studies have been conducted with the unaltered products, as sold, the results may not properly reflec t the effects of the components as they exist 1n the environment.* (Ref. 1, p. 19). Furthermore, I t was reported to the Interdepartmental 'Task Force " . . . th at a ll PCB products cannot be lumped together in terms of either th e ir environmental Impact or persistence." Other points Bade 1n this report to the Task Force are: (1) As the degree of chlorination (of PCBs) decreases, the bacterial degradation rate Increases. (Ref. 3, p. 4). (2) The residue storage levels (1n albino rats) decrease exponentially as the weight percent chlorine decreases. (Ref. 3. p. 6) * . (3) PCB residues found 1n wild lif e are dominantly penta-, hexa-, hepta-, and octa- chloro biphenyls. (Ref. 3, Chart 4). i / In recent years the Monsanto Company has developed a special -^product* Aroclor. grade ^ofr-Aroclernow--used-in---- capacitor manufacture. Although Its gross chlorine,,content 1s almost the same as that of Aroclor 1242 (1.e. about 425 of Cl), Aroclor 1016 has been specially d istille d to remove most of the higher boiling homologs, which are found in wild life residues. Indeed, more than 991 of Aroclor 1016 comprises homologs with 4 or less chlorine atoms per biphenyl (Ref. 3, Chart 1); and these homologs have not been found In wild lif e residues. ;! \ \ \ ( , In lig h t of the foregoing we recommend th at.th e specific commercial! preparation, Aroclor 1016, not be considered as. a toxic pollutant. We are encouraged to see that 1n promulgating Its 11st of toxic pollutants, * EPA has recognized that not all compounds of cadmium and cyanide are toxic and has stated that distinctions will be made when the final **oi Tucker, E.S., "Assessment of the Biological Persistence of Polychlorina 81phenyls," from Presentation to the Interdepartmental Task Force on PC by Monsanto Company, r.ay 15, 1972, p. 2. ADM 007203 91 CEU ERAL ELECTRIC Or. C. Hugh Thompson S* November 21, 1973 effluent standards are published. We recommend that similar distinctions be made 1n writing effluent standards for PCBs. (3) The "economic and social Impact" (consideration number 2) o uniform effluent standard would be much more severe upon an existing plant than upon a new plant. Host of the existing plants that manufacture sealed electrical equipment containing PCBs were 1n operation for many years before there was any recognition of the possible environmental hazards of PCBs, and during these years no special precautions were taken concerning the handling and disposal of these liquids. Thus, accuimjlatlons of PCBs over the years in and around the drainage systems of these plants could resu lt In continued discharge of PCBs even 1f the plants were to eliminate PCBs from th e ir current operations. Elimination of such reservoirs of PCBs might well require a major and prohibitively expensive renovation of plant and s ite . However, with the Institution of Internal control measures such as described 1n proposed American National Standard Guidelines older plants are preventing further build-up of such reservoirs. WHAT EFFLUENT STANDARDS ARE FEASIBLE FOR THE ELECTRICAL MANUFACTURING IHDUSTi We have already noted that the Monsanto Company now sells PCBs only to manufacturers of sealed electrical equipment, such as capacitors and transformers. The soundness of this decision 1s supported by the findings of the Interdepartmental Task Force on PCBs (Ref. 1, p. 4) and the regulator promulgated by the Food and Drug Administration (38 FR 18096, July 6, 1973). These documents recognize the unique combination of fire safety and design efficiency that the use of PCBs Imparts to capacitors and transformers and the minimal risk of environmental contamination associated with such use. / 1 He believe th at the special conditions pertaining to the past and AV present use of PCBs In the electrical Industry warrant recognition 1n the " setting of effluent discharge'standards. These should not necessarily be The manufacture of transformers and capacitors Involves a m ultiplicity of operations Including vacuum Imoregnatlon, heat treatment, fillin g , j sealing, washing operations and the like. Provision must be made for the \ handling of large apparatus containing up to 1500 gallons/un1t (1n the ca se ;' of transformers) and for the fillin g and sealing of millions of small units per year (1n the case of capacitors). Control of PCS discharges 1n such electrical manufacturing plants t requires a combination of process design and good housekeeping. For example, waste lines and operating procedures may be designed to eliminate contact between PCBs and water not directly used 1n the PCB operations themselves (e.g. cooling water). No effective end-of-Hne treatment has been demonstrated on a plant scale. Off icial Standards Proposal. Proposed American National Standard Guide!ii for Handling and Disposal of Capacitor- and Transformer-Grade Askarels Containing Polychlorinated Biphenyls, Cl07.1 - ( ), National Elctrica Manufacturers Association Pub. No. CP-P1-1973 and Pub. No. TR-PG-1973, January 25, 1973. AOM 0 0 7 6 * GENERAL ^ ELECTRIC Dr* C. Hugh Thompson - Kovember 21, 1973 Segregation of operations and waste lines is feasible in the design and construction of a new plant but would be prohibitively expensive for an old plant. I f such controls are Incorporated Into a new transformer or capacitor plant on a new s ite , 1t should be possible to lim it the discharge of PCBs to less than 5 pounds per day depending upon the volume and complexity of the production processes. The attainable discharge from an existing plant that had already been 1n production before the mid-60's may be as much as 15 pounds higher as the background level, depending on the size of the plant. Its age, and the nature of Its ea rlier operations, a ll of which would have . affected the location and extent of Its reservoirs of PCSs. Such a plant could In stall the control measures mentioned above and s t i l l be unable to reach the discharge levels for a new plant at a new s ite . We believe that the foregoing numbers can provide the basis for r e a lis tic effluent standards because they re fle c t the actual technology of the capacitor and transformer industry. As we have mentioned e a rlie r, the recommended water quality standards provide no practical basis for effluent standards.| SUMMARY | In the foregoing comments we have raised the following points: 1) Available data do not support categorizing PCBs as a "highly toxic" m aterial, nor setting standards on the basis of this a rb itra rily assigned hazard rating. 2) The maxinajm recommended concentration of 0.002 ppb of PCBs in fresh water is an operationally meaningless number that Is unsupported ; by convincing ecological data. Any effluent standards based upon such a water quality standard could not be attained in existing plants and . could lead to shut-down of capacitor and transformer operations. 3) Actions already taken by Monsanto and POB users 1n the electrical industry have substantially reduced the exposure of the environment to 1 \ PCBs and should result In a decreasing Impact of PCBs in the environment. \ 4) Existing data suggest that Aroclor 1016 should not be considered^ a toxic pollutant. * 5) Older plant sites will continue to have significant background ` levels of PCBs in th e ir discharges because of accumulated reservoirs from \ years of operation before anyone recognized the possible environmental \ hazards of PCBs. These background levels should be considered apart from c those levels contributed by current operating procedures. ADM 0072&5 93 CEMERAL ELECTtltC X Dr, C. Hugh Thompson - 7 - November 21* 1973 Ve a p p re c ia te th e o p p o rtu n ity to subm it th e s e comments and hope t h a t th e y w ill be o f a s s is ta n c e to EPA 1n s e t t i n g e f f lu e n t s ta n d a rd s f o r PCOs. c Very tr u ly y o u rs, __ / X ELS: 1 D r, E. L. Simons, Manager Environmental P rotection Operation -j II * c OM 0 0 7 2 B 94 GENERAL*. ) ELECTRIC vw > / GENERAL ELECTRIC COMPANY, 1 RJVER ROAD. SCHENECTADY. NEW YORK 12345 Ptmne (ftis) 374-2211 S u b je c t: E fflu e n t L im itatio n s fo r Item s on T oxic S u b stan ces L is t: Economic Im p act o f a Ban on ?C3 PRODUCT QUALITY STAFF November 21, 1973 D r, M artha Sager Chairm an, E fflu e n t Standards and V ater Q uality Inform ation A dvisory Committee E nvironm ental P ro te c tio n Agency Boom 8 2 1 , C r y s t a l H a l l , B ld g , #2 W ashington, D. C. 20460 Dear Dr. S ager: W ith re fe re n c e to your forthcom ing m eetin g (38FR30577) and p u rsu a n t to o u r u n d e rsta n d in g t h a t the Conaaittee has e x p re sse d en i n t e r e s t In knowing th e econom ic im pact o f e p o ssib le ben o f p o ly c h lo rin s te d biphenyls (o r s r e s tr ic tio r tan tam o u n t to a b a n ), ve have th e fo llo w in g comments to o f f e r : The v a l u e o f . th e a n n u e l p r o d u c t i o n o f PCB t r a n s f o r m e r s I n th e U .S. I s approxim ately $45 m illio n end th a t o f c a p a c ito rs ./ $140 m illio n . N eith er o f th ese fig u re s forms an a p p ro p riate ( base fo r a sse ssin g the soeio-econom ic e ff e c t o f re g u la tio n s ;J riS.. :pn^yrhe.E produccienv^Should^'Sueh-- ^ a bah occur in the near fu tu re ( l . e . , w ith in fiv e -y e a rs) the l im p a c t o f PCB tr a n s f o r m e r u n a v a i l a b i l i t y w ould be f e l t p r i m a r i l y -\ In term s o f d isru p tio n o f b u ild in g c o n stru c tio n , e le c tr ic d i s t r i - \ b u tto n , and r a ilro a d equipm ent p r o je c ts ; and in te rru p tio n o f the \ s u p p ly o f PCB c a p a c i t o r s w ould im p a c t m o st h e a v i l y on t h e e l e c t r i c a l supply s itu a tio n , exacerbating the "energy c r i s i s ." > i M oat PCB tr a n s f o r m e r s a r e I n s t a l l e d I n I n d u s t r i a l , e o n s n e r c ie l, ; and r e s i d e n ti a l s u b s ta tio n a p p lic a tio n s , A c o n sid e ra b le number a rc \ I n s t a l l e d on e l e c t r i c railw ay p a sse n g e r commuter e a rs s e rv in g m ajor \ m etro p o litan areas. In a ll a p p lic atio n s, these trsnfonocrs d istrib u te a le c tr i c power r e lia b ly w ith o u t-ris k o f f i r e and ex p lo sio n , and In com pliance w ith s p e c ific law s, codes, end Insurance r e s tric tio n s m andating non-flasm ablc liq u id c o n te n t. There la no re a d ily a v a ila b le a l t e r n a t i v e f o r many a p p l i c a t i o n s w here c o n s tr u c ti o n i s u n d e r way o i p l a n s . a r e c o m p le te . As much e s $1 b i l l i o n o f c o n s t r u c t i o n p r o j e c t s could be se rio u sly delayed, involving sch o o ls, fa c to rie s , o ffic e b u ild in g s , apartm ent houses, and co sn u ter tr a in s . ADM 0072*v 95 SEVERAL ELECTRIC D r. K m b i Sager 2- Th PCB c a p a c i t o r s p ro d u c e d i n th e U .S . a n n u a ll y h av e a m a jo r a f f e c t l a red u cin g the e le c tr i c c u rre n t v h leh would o th erw ise have to be g e n e ra te d to se rv e in d u s tr ia l and p u b lic n e e d s. The saving may be approxim ated by su n aln g up th e in c re m e n ta l c o s t o f o v e rs iz e g e n e ra to rs and th a t p o rtio n o f tra n sm issio n end d is tr ib u tio n system equipm ent which is th erm ally lim ite d . Equipment in th e se c la sse s c o rre sp o n d in g to th e 44 m illio n k llo v a r s o f new c a p a c ito r s i n s t a l l e d a n n u a lly , h a s a v a lu e o f a p p ro x im a te ly $1 b i l l i o n . A fo rc e d c o n v e rs io n to a non-PCB c a p a c ito r would be ham pered by sh o rta g e s o f b a s ic c a p a c i to r m a te ria ls and fa c to ry p roduction c a p a b ility , th u s p lac in g in Jeopardy ab out h a lf o f th is annual sa v in g . A d d itio n a lly , th e re would be s e rio u s d islo c a tio n s in the lig h tin g and a ir-c o n d itio n in g in d u strie s due to sh o rta g e s and m ism atches o f c a p a c ito rs re q u ire d in th o se sy stem s. The enclosed p ap er, T h e Sole o f P o ly c h lo rin a te d B iphenyls in E le c tr ic a l Equipm ent", F ebruary 4 , 1972, w as.prepared o r ig in a lly fo r the O ffice o f S cience and Technology and la included here fo r fu rth e r in fo rm a tio n on th e econom ic v a lu e o f t h e s e d e v i c e s . In a d d i t i o n , we h a v e u p d a te d t h e in f o r m a tio n a b o u t c a p a c ito rs and addressed ourselves s p e c ific a lly to the consequences of u n a v a i l a b i l i t y o f PCB c a p a c i t o r s i n t h e e n c l o s e d new s tu d y e n t i t l e d , "The Im p a c t o f a 'B a n ' on t h a Use o f PCB i n C a p a c i t o r s , " November 1 9 , 1973. Im p o rtan t as a re economic c o n s id e ra tio n s , ve f e e l th a t th e c a te fo r c o n tin u e d u se o f PCB's in c a p a c ito r s and tra n s fo rm e rs r e s t s l e s s on th e s e j fa c to rs thsn upon the lack o f su b sta n tia te d need fo r any tig h te r c o n stra in ts ; on th e h a n d li n g o f t h e s e m a t e r i a l s ^ t h a n th o s e a l j j e a ^ . i n ^ _use.^orv.f 1-g o a l'r tfid v-Ie tf-tric lr^ x ifd u sn'Ty ^ ' T t f e s e 'a s p s c t s a r e ^ d i s c u a s e d i n th e e n c lo s e d l e t t e r from D r. Simons o f G eneral E l e c t r i c to D r. Thompson o f E .P .A ., c o n s e n tin g upon t o x i c p o l l u t a n t a f f l u e n t s ta n d a r d s ( r e f e r e n c e , 38FR21342). \ Ve hope t h i s d isc u ssio n w ill be o f use to your com m ittee. , Very tru ly y o u rs, JSN :ev E nclosures c e : D r. C. Hugh Thompson C hairm an-H azardous and Toxle Substance R egulation Task Force O ffic e o f W ater Program O p eratio n s * E nvironm ental P ro te c tio n Agency W a sh in g to n , D. C. 2066C 007250 THE IMPACT OP A "BAN" CN THE _ USE OF PCB IN CAPACITORS StJMMAKT Tha P C B -ia p re g n a te d c a p a c i t o r s p ro d u c e d 1b Che U .S . a n n u a l l y hove a m a jo r e f f e c t I n r e d u c in g Che e l e c t r i c c u r r e n t w hich s u e t be gene raced to ee'rve Indue t r i a l and p u b lic need* fo r power. The annual sav in g aay be view ed as e q u iv a len t to 44 larg e e le c tr ic g e n e ra to rs, each o f th e 1000 m egawatt s i r e , which do n o t need to be i n s t a l l e d an a g g reg atio n com parable to the n a tio n 's annual grow th requirem ent. The f o l l o v l n g co n aeq u en ce* v i l l r e s u i t f r o a a PCB e f f l u e n t s t a n d a r d so s t r i c t as to hve the e ffe e t of a bsn: I f th e in d u s tr y i s fo rc e d to c o n v e rt to a non-PCB la p re g n a n t, low d ie le c tr le - c o n s ta n t liq u id s , a u e h a s m in eral o i l , o f f e r th e b e st i n i t i a l fallb ack position^ - M in eral o i l would roughly double th e pounds o f c a p ac ieo r . g rade d i e l e c t r i c p ap er and aluminum f o i l needed to produce p rese n t c a p a c ito r requirem ents. C urrent w orld-w ide sh o rtag es o f e o p a e ito r p ap er and f o i l would n o t su p p o rt, t h i s . - M a te ria l* a v a il a b i l it y would su p p o rt about 501 o f th e c u rre n t c a p a c ito r requirem ents using m ineral o i l. - I f a d e q u a te m a te r ia ls s u p p lie s were somehow s t t a l n e d , c u r r e n t cap acieo r m anufacturing f a c i li ti e s could produce a t b e st o n ly 50X o f c a p a c ito r u n i t re q u ire m e n ts . ! j , A s - - n o t v - P C S k w q u l d -xg s u i t - l a - c a p a c i t o r - a h o r t a g e s -<'- w * and m ajor production cutbacks in the lig h tin g , * lr c o n d itio n e r, and power supply in d u s tr ie s , and in t h e i r custom er o p e ra tio n s. A A D oubling th e s iz e o f c a p a c ito rs would p r e s e n t s e rio u s rep la ce m e n t p ro b le m s w here PCB c a p a c i t o r s had been u s e d . '\ - B a lla s t and a i r c o n d itio n e r m an u factu rers would have to re d e sig n c e rta in products to accept the larg e r c a p ac ito rs. Power sy stem s t a b i l i t y would be a d v e rse ly e ff e c te d by a s h o rta g e o f c a p a c ito rs , and b lac k -o u ts could be expected. * - New n o n -P C B 'a , su c h s s G . E . 's E e S n o l, c o u ld s u b t a n t i a l l y r e d u c e th e m agnitude o f th e m a te ria ls problem . However, Ectmol s t i l l ' r e p r e s e n ts an unknown r is k in r e l i a b i l i t y .a n d s a fe ty in th e m ajor consum er a p p lic a tio n a re a s . A mass co n v ersio n is not J u s t i f i e d a t th is tim e. AOH 0 0 7 2 5 97 I INTRODUCTION T b l l a a f o r a c a s t o f t h t c o n sq u e n c e # o a, PCB a f f l u e n t s t a n d a r d v h ieh ean n o t ba m et by e a p a e lto r m an u factu rera* aad co n sq u en tly becornes an a f f e c t i v e ban* I t l a a u b a itte d by th e G eneral- E l e c t r i c Company to a a a is f ln ehe dterm ination o f ap p ro p riera a fflu a n t atandarda re la tiv e t o e a p a e i t o r g r a d e PCB. Z I . BACKGROUND In th e U .S ., an im pregnated e a p a e ito r can be very sim ply d e scrib ed a; - Aluminum f o i l (aro u n d 0 ,2 2 m il t h ic k ) w hich a e rv e a aa th e eleefcroder. Sheet* o f d ie le c tr ic c o n sistin g o f e a p a c lto r grade. . paper o r com binations o f th is paper w ith p la s tic film . The d i e l e c t r i c i s p o s itio n e d betw een th e aluminum e le c tr o d e s as i t i s wound in to r o l l s , An a p p r o p r i a t e l i q u i d im p re g n a n t. - A sealed co n tain er fo r the c a p ac ito r r o ll and lm pregnant, r ' -sa.. - L-s--S- The ch o ice o f d ie le c tr ic m a te ria ls , th e number o f s h e e ts , and t h e i r th ic k n e s s e s a r e a l l th e r e s u l t o f many y e a r s o f r e s e a rc h and t e s t i n g f o r r e l i a b i l i t y and consieaer use s a fe ty . About 90-951 o f liq u id im pregnated r e a p e d tQ*~tConJt*ln^C&v^&d'.-axe i-H erl-^ ^ p c rtffc h 't-s ' t d - t he ' f 1ua r t& ~` and m ercury v ap o r l i g h t i n g , th e e l e c t r i c m otor and^ a i r c o n d itio n in g \ in d u s t r ie s , and power tra n sm issio n by e l e c t r i c u t i l i t i e s . The d i e l e c t r i c p a p e r a n d p l a s t i c f ilm s ( p r i m a r i l y p o l y p r o p y l e n e ) , alum inum f o i l , and PCBy have a l l been s p e c ia lly developed and c o n tro lle d fo r c a p a c ito r use and a re v produced as " sp e c ia lty " m a te ria ls. .t < C a p a c i t o r g ra d e PCB I s A r o c lo r 1016, m a n u fa c tu re d o n ly by M onsanto.' I t i s p r i m a r i l y t r l c h l o r o b i p h e n y l . I t d i f f e r s from a l l p r e v i o u s ly u s e d .] fo rm u latio n s in th a t p ra c tic a lly a l l o f th e h ig h er b o ilin g hom ologs-- \ w h ich h a v e g iv e n r i s e to r e p o r t s o f PCB i n w i l d - l i f e r e s l d u e s - - h a v e b e e n rem oved. - I n tr o d u c e d i n 1971, i t i s now th e o n ly PCB u sed by th e U .5 . e a p a e ito r in d u s tr y . Compared to o ch er fo rm u la tio o a , - i t has a higher degree of b io d eg rad ab ility ; - i t has a lower d eg ree,o f p e rsiste n c e in the environm ent. ADM 0 0 7 2 5 2 98 3 I I I . CONSEQUEKCES OF A "BAH** TO THE CAPACITOR INDUSTRY This ev alu atio n addresses i t s e l f to the s itu a tio n v h trc ln th i c i p t c i t o r I n d u s t r y I s e f f e c t i v e l y b in n e d from u s in g PCBf a . A. A lte rn a tiv e Im prgnants A lte r n a tiv e Im prgnants e re unproved in th e US. c ip a c it o r I n d u s tr y . M in e ril o i l v is th e m ajor Im prgnant b e fo re PC B 's, and i t ap p ears to re p re s e n t th e b e st im m ediate fa llb a c k p o s itio n . Even though m ineral o i l technology would p u t th e In d u stry baek 30-40 y e a rs in p ro g re s s , i t t i l l r e p r e s e n ts th e b e s t com b in atio n o f known te c h n o lo g y , m a te r ia ls a v a ila b ility , and r e lia b ility . For these reaso n s, m ineral o il im prgnant b a s been s e le c te d a t t h i s tim e a s th e b a s is o f com parison w ith PC B 's. T here have been a number o f v e ry a c tiv e program s to d ev elo p non-PCB im p rg n an ts, e s p e c ia lly a f te r th e environm ental problem v ia rec o g n ised . These programs a r t co n tin u in g in the in d u stry , and i t i s expected th a t an im provem ent w i l l be found w hich would be more a c c e p ta b le th an m in e ra l o i l . As an ex am p le, G e ie r a l E l e c t r i c l a u s in g * p h t h a l a t e e s t e r a s th e b ase f o r i t s non-PCB Ectm ol im prgnant. EeSnol c a p a c ito r s a re b eing old e o r a e r c ia lly where s p e c ia l s itu a tio n s re q u ire a non-PCB. T his i s th e case w here U .S. e l e c t r i c a l equipm ent, such es com puters, i s to be shipped to Japan where ?CBfs are banned. EcSiol has a higher d ie le c tric constant (see next Section B fo r d isc u ssio n o f th is p ro p erty ) than m ineral o i l , and consequently w ill re q u ire le s s a d d itio n a l m a te ria ls and m anufacturing c a p a c ity . However, , lim ite d a v e l l a b l l l t y o f th e p h th a la te e s e e r , la c k o f a p p ro p ria te manu- -m. *v "* *- f s e c u r i n g f a e i 11 t i e a L n e d ^ f p.r de^ ejlo p in g ,,new js f f l u e n t . aA ufA c,turiag-. .-t ^ p r b ^ c V s h s ^ 'a h d ^ p a ^ I u l a r l th e unknown f a c t o r s of>, r e l i a b i l i t y and s a f e t y ! In the broad consumer use c re ss such as lig h tin g snd a ir co n d itio n ers a re \ some o f th e problem s t h a t p re v e n t a n e a r - tarm s u b s ti tu t io n . \ \ U nless c o n sid e ra b le tim e fo r th e developm ent and e v a lu a tio n o f a l t e r n a t ! liq u id a i s p e rm itte d , th e m ost s u ita b le im m ediate stratag em appears to be the use o f m ineral o il. The v i r t u e s o f PCB im p r g n a n t and th e d is a d v a n ta g e s o f m in e r a l o i l h a v e b een d is c u s s e d i n d e t a i l i n a number o f r e c e n t d o c u m e n ta. Among t h e s e docum ents a r e th e r e p o r t o f th e X ncerdepar m e n t a l Task F orce on PCB's (COM*7 2 -1 0 4 1 9 ), a p a p e r t i t l e d , '*The Role o f P o l y c h lo r in a t e d B ip h e n y ls i n E l e c t r i c a l Equipm ent" p re se n te d by G eneral E le c tr ic on F ebruary 4 , 1972, an d NEMA's O f f i c i a l S ta n d a r d s P ro p o s a l C P -P 1-1973/T R -P 6-1973, d a te d January 23, 1973. A ll o f th ese documents have poin ted out th a t ?C3-lm pregnaccd c a p a c ito r s a re s i g n i f i c a n t l y s m a lle r , more r e l i a b l e and s a f e r th an m in e ra l o i l im pregnated c a p a c ito r s and chat use o f m in eral o i l would r e tu rn ADM 007253 99 C *>* ''-i- 4 c a p a c ito r technology to i t pra-1932 le v e l. The e u b a titu tio n o f m in e ra l o i l f o r PCS lm p re g n s n ts w ould n e c e s s i t i e s r e d e s ig n o f end tq u lp m e n t to o tilie e the la rg e r cap ac ito r , larg e increaaea in c a p ac ito r m anufacturing f e c i l i t i e a (b o th p l a n t end equipm ent) end would r e a u l t in io c re a a e d u ce oi b e a le m a te ria l which e re p re s e n tly in a h o rt au p p ly . The fo llo w in g l a an a tte m p t to q u a n tify tome o f th e consequence r e la te d to th e uae o f m in eral o i l aa an a lte rn a tiv e iap reg n an t. 1 C a p a c ito r M a n u fa c tu rin g C a p a c ity M in e r a l o i l im p re g n a te d c a p a c i t o r s i z e s r e l a t i v e t o PCS c a p a c i t o r a a re shown i n T a b le 1 T able 1 - R e la tiv e Size Comparisons Types* AR0CL0R 1016 M ineral O il Shall In d u stria l 1 ,0 2 -2 .5 Power 1.0 2 .5 0 .2 Sm all I n d u s tr ia l - Used in lig h tin g , a i r c o n d itio n in g ) m otors end .e le c tro n ic s. Power - Large c a p a c ito ra used by e le c tr i c u t i l i t i e s and by In d u stry fo r in d u ctio n fu rn aces end power f a c to r c o rre c tio n . The d i e l e c t r i c c o n s ta n t o f a c a p a c i t o r 1 d i e l e c t r i c sy s te m l a th e { r a tio o f le a a b ility to sto re e le c tr o s ta tic energy r e la tiv e to a i r . The * ^ i l e ^thetr^f.minerei * i s 2 .2 5 . Use o f th e low er d i e l e c t r i c c o n s ta n t m in e ra l o i l in a p ap er I d i e l e c t r ic system , e s a ia ln g no change in th e th ic k n e ss o f the paper \ d i e l e c t r i c , w ould r e s u l t i n a c a p a c i t o r w h ich i s 60Z l a r g e r th a n th e PCb \ im pregnated d esig n . A d d itio n a lly , however, use o f m ineral o il re q u ire s th a t the thickness o f the paper d ie le c tr ic be in creased to reduce the o p e ra tin g s tr e s s on the system i f equal I l f s and r e l i a b i l i t y ere to be i a tta in e d . In the case o f lower v oltage In d u s tria l type c a p a c ito rs, such ) as those uted In flu o re sc e n t b a lla s t end a ir co n d itio n in g a p p lic a tio n s , the d i e l e c t r i c th ic k n e s s m ust be in c re a se d 10 to 25Z. In power c a p a c ito rs ; o p e ra tin g At h ig h e r v o lta g e s , th e d i e l e c t r ic th ic k n e s s m ust be in c re a s e d \ 25 to 40Z. The la r g e r in c re a se in the h igh v o lta g e u n its is re la te d to th e f a c t th a t corona i n i t i a t i o n and e x tin c tio n v o lta g e s o f m ineral o il im pregna d i e l e c t r i c s y ste m s a r e lo w e r th a n Chose o f FC2 im p re g n a te d s y s te m s . The approxim ate doubling o f p h y sic a l e ls e r e s u lts in about h a lf th e th ro u g h p u t o f c a p a c ito rs in e x is tin g m an u factu rin g equipm ent. The e a p a c ito i in d u stry c u rre n tly has l i t t l e i f any excess ca p ac ity to handle t h is , even i: adequate c a p a c ito r m a te ria ls su p p lie s a re assumed to be a v a ila b le . ADH 0 0 7 2 5 V 100 5 CONSEQUENCE - THE CAPACITY AND 0UTO7T OP THE CAPACITOR INDUSTRY WILL BE CUT APPROXIMATELY IN HALF. 0 C a p a c it o r M a te r ia l A v a i l a b i l i t y Th following T a b le 2 estimates t h e capacitor industry r e q u ir e m e n ts f o r p a p e r , foil, and im p r e g n a based on th e currently used AROCLOR 1016 ad for Binerai oil. T able 2 - 1974 C a p a c ito r M a te ria ls R equirem ents f ib s , In m il li o n s ^ Paper Al F oil lm pregnant AROCLOR 1016 26 18 26 M ineral O il 52-65 52-36 55-42 X Chante 100-1501 80-1001 35-601 There Is a worldw ide sh o rtag e o f c a p a c ito r grade paper and alum !nun f o i l . The c a p a c ito r p ap er sup p ly la e x p e c te d to c o n tin u e a t i t s p rese n t le v e l o f a v a ila b ility . M ineral o il im pregnation w ill req u ire a t l e a s t tw ice th e amount o f m a te r ia ls to p roduce th e same c a p a c ita n c e / ' a s w ith PC B's. U sing th e m ost o p tim is tic o f th e above num bers, th e t o t a l c a p a c ito r in d u stry 's requirem ents of K raft paper d ie le c tr ic , a l l of i t u sin g im ported pulp fo r i t s p ro d u c tio n , would In c re a se by 2 to 2 .5 tin e s and i t s req u irem e n ts f o r aluminum e le c tro d e f o i l would in c re a s e by 1 .8 0 j ' to 2 tim es. T o t a l I n d u s t r y r e q u ir e m e n ts i n 1974 f o r p e p e r d i e l e c t r i c i n PCB T im pregnated e x p e rie n c e , cap acito rs is estim ated th is requirem ent is the a t 26 lim it m illio n pounds. Based that au p p lltrs of th is on r e c e n*t type o f p ap er can produce w ith e x is tin g equipm ent. Adding f a c i l i t i e s i t o m ore th a n d o u b le th e p r e s e n t d o m e s tic o u t p u t o f p i p e r i s a t a s k t h a t ; could n o t ba com pleted in le s s th in 4 to 5 y e ars and the to ta l Investm ent, re q u ire d by th e paper m an u factu rers I s e stim a te d to exceed $200 m illio n . Z t la q u e s tio n a b le t h a t th e paper In d u stry would make t h i s in v estm en t, fa c lr th e p r o b a b ility t h a t f u tu r e lm pregnant and d e sig n developm ents would n e g a te i ts need. A lu a ln isa f o i l i s a l s o i n s h o r t s u p p ly . Some in v e s tm e n t i n f o i l - r o l l i n g equipm ent I s a lr e a d y u n d er wey a t G en eral E l e c t r i c to a l l e v i a t e th e s h o rta g e b u t an ad eq u ate c o n tin u in g su p p ly o f r e r o l l aluminum sto c k from which th e th gauges o f aluminum e le c tr o d e m a t e r i a l a r a made c a n n o t p r e s e n tly be a s s u r e d . The s u p p ly o f d i e l e c t r i c - g r a d e m in e r a l o i l r e q u i r e d to r e p l a c e PCB im p rg n an ts i s a ls o u n a ssu re d . D oubling th e s i t e o f c s p a c lto r s would ADM 007255 101 t ap proxim ately double the volw w o f im pregnant re q u ire d . Ths e o le m anufact o f d ie le c tr ic - g ra d e m in eral o i l hea re c e n tly Announced chat i t* a a n u fa c tu r i e b ein g d ia c o n tln u e d . The f e a e lb ilic y o f ap p ly in g th e e a p a e lto r in d u s tr on a tim e ly b a a ia w ith 35 m illio n pound a n n u a lly , a ta r tln g from a p ro d u c t r a t e o f a e r o , 1 d o u b tf u l t o sa y th e l e a s t CONSEQUENCE - THE CAPACITOR INDUSTRY WOULD BE ABIE TO SUPPLY ONLY ABOUT 5 0 1 OP THE CURRENT CAPACITOR DEMAND BECAUSE OP MATERIAL SHORTAGE; D. C oita U .S . im pregnated e a p a e lto r a le a f o r 1974 a re ahown in T able 3 . T able 3 * E stim ated 1974 T otal Im pregnated C ap acito r Sale m ilio n i b all In d u strial 100 Fever 55 A bout 90-95X o f t h e s e a r e PCB im p re g n a te d c a p a c i t o r s . I t l a e s ti m a t e d t h a t th e c o s t o f c a p a c ito r s would In c re a s e by a t l e a s t 100Z in going to m in e ral o i l . I t i s lik e ly th a t th e re would be an added I n fla tio n a ry fo rc e d w ith demand f a r exceeding su p p ly . CONSEQUENCE - COST OF CAPACITORS WOULD AT LEAST DOUBLE. AT CURRENT ' . PCS CAPACITOKJALES J g V Z J g v S WOULD APP > B 145-_MIILION-Itf-...,TM r^ ,, " CApXQilOR "COSTS ' t o 'EQUIPMENT MANUFACTURERS. TO this' WOULD BE ADDED AT LEAST ANOTHER $200 KILUON IN COSTS AT THE END-CONSUMER LEVEL. \ \ S . R e l ia b i li ty and W arranty Tha U f a e x p e c ta n c y o f c a p a c i t o r s a x c a e d s X0 y e a r s f o r l i g h t i n g a p p lic a tio n s and more th an 20 y e a rs in e l e c t r i c u t i l i t y power tra n s m is s io n a p p lic a tio n s . Although c a p a c ito rs are co n sid ered lo n g -liv e d p ro d u cts, t h e r e l a a h e v e r p r e s e n t d a n g e r o f s h o r t l i f e and a a r l y f a i l u r e . T h is can^ be caused by a number o f fa c to rs such as poor p ro cess c o n tro l, m a te ria ls q u a l i t y , m il- a p p lic a tio n , and new p ro d u ct in tr o d u c tio n w ith In ad eq u ate knowledge and ex p arlen ce o f r e l i a b i l i t y . The G e n e ra l E l e c t r i c Company w a r r a n ts I t s c a p a c i t o r s f o r one y e s r , and has extended th is w arranty where e a p a e lto r f a ilu r e s have been e x c e s s iv e and due to sh o rtco m in g s In c a p a c ito r q u a l i t y . The m ajor r e l i a b i l i t y and w arranty problem s l ie In the sm all In d u s tria l type c a p a c ito r ADM 0072 5t> 102 7 uch as used fo r lig h tin g b o to r s , end power s u p p lie s. The c a p a c ito r I n d u s t r y p ro d u c e s In Che o r d e r o f 100 B i l l i o n c s p s c l e o r s p e r j e e r . The m a jo rity o f th e se u n its s e l l In th e p ric e rang* o f 50$ to $4. The s e rv lc i c o s t f o r re p la c in g s f e lle d e a p s d to r I s $20 to $25. The in -w a rra n ty . fa ilu re ra te o f G eneral E le c tric cap aelto rs during the f i r s t year Is w ell u n d e r 0 . 5 1 . Ve b e l i e v e t h a t t h i s r e l i a b i l i t y I s t y p i c a l o f th e c a p a c i t o r I n d u s tr y In g e n e r a l. T h is perform ance has been a tt a in e d e f t e r many y e a r s o f d e v e lo p in g th e PCB c a p a c i t o r , and e s t a b l i s h i n g e x p e c te d norms f o r f a i l i ra te s and serv ice lif e . The c a p a c ito r In d u stry h is to ric a lly Is very e a re fu l in Intro d u cin g pro d u ct and process changes because s s a ll changes in f a ilu re r a te , w hich a re extrem ely d if f ic u lt to determ ine w ithout y ears o f se rv ic e ex p erien ce and s t a t i s t i c s , could r t s u l t In excessive com plaint and replacem ent c o s ts . For exam ple, T able 4 shows th e rep lacem en t c o a t I f th e f a i l u r e r a t a d u rin g tb s w arran ty p e rio d In c re a se d by d if f e r e n t le v e ls . T able 4 - Replacem ent C osts fo r E arly F a ilu re s X o f A nnually I n s ta lle d C apacitors F illin g , over E x istin g R ite Increase in ' F ercentaee Points M illions Re D isced Coat a t $25/Servlce C all 1 .0 1 .0 $25 m illio n 2 .0 2 .0 50 " 3 .0 3 .0 $75 -o. - u ..'ji, - rH e r-t^ 'm v o id -T h e '-'e a n sq w n s" f - s u e h ^ v a tr a n ty c o s t * - tf c e - c e p `-rci-t< I n d u s tr y w ould d e sig n any new noa-PCB p ro d u c ts on Che c o n s e rv a tiv e s i d e l However, th e re would s t i l l be a s u b s ta n tia l r is k a s so c ia te d w ith a m ass^ c h a n g e o v e r to a new im p rtg n a n t, e s p e c i a l l y In th e end-consum er p ro d u c t a re . w ith e s s e n tia lly no experience on r e l i a b i li t y and s a fe ty . ]\ CONSEQUENCE - I F THE FAILURE RATE OF THE 100 MILLION CAPACITORS ! - PRODUCED IN ONE YEAR WERE TO INCREASE BY 1 TO 3 PERCENTAGE POINTS, ' THE REPLACEMENT COSTS AT $25 PER SERVICE CALL WOULD RUN FROM $25 t o \ $75 MILLION. THIS IS THE MAGNITUDE OF THE CAPACITOR INDUSTRY'S ) EXPOSURE IN GOING TO A. NEW, UNTRIED IMFRECNANT ON A MASS BASIS, IV . CONSEQUENCES OF A "BAN" TO CAPACITOR USERS T h ia s e e t l o n e s t i m a t e s t h e e f f e c t o f a PCB ban on c u a to o e r a and u s e r s of cap acito rs. A0M CQ7 2b 7 103 8 r CRITICAL COMPORT AVAILABILITY C ap acito rs s rs s c r i t ic a l sad necessary component la end-user equipm ent, p a r tic u la r ly la sm all in d u s tr ia l a p p lic a tio n s* W ithout the c a p a c i t o r , th e ta d p ro d u c t v o u ld n o t o p e ra te a s d e s ig n e d . The c a p a c ito r s h o r t a g e r e s u l t i n g from a " b a n " on PCB c a p a c i t o r s w ould f o r c e a r e d u c t i o n by a t le a s t h a lf from the normal p roduction r a ts in th e p la n ts o f c a p a c ito r users* CONSEQUENCE - INCREASED LAYOFF AND UNEMPLOYMENT AS MANUFACTURERS ADJUST TO THE SHORTAGE* ELECTRIC POWER SYSTEM SAVINGS The m agnitude o f th e energy le v e ls tinder d isc u s s io n can be a sse sse d from the fo llo w in g : The U.S* c a p a c ito r I n d u s tr y p ro d u c e s th e e q u iv a le n t o f 55 m illio n k ilo v a r p er year* - A k llo v ar is equivalent to a t le a s t 1 k ilow att of generating c a p a c ity (some e s tim a te s p la c e t h is r a t i o o f k i lo v a tt / k ll o v a r a t up to 1*4). A bout 20X o f th e c a p a c ito r s a r e f o r re p la c e m e n t p u rp o s e s , and th e rem ain in g 80Z a re fo r nej/ s e rv ic e . Thus, 44 m illio n k ilo v a rs a re i n s t a ll e d on new sy stem s. W ithout th e se c a p a c ito r s , th e steam tu rb in e s and f u e l req u irem e n ts vould be r e la tiv e ly u n a ffe c te d , b u t g e n e ra to rs vould be la r g e r to h an d le more c u rr e n t, and c e r ta in com ponents o f tra n sm issio n and / d is tr ib u tio n system s (e.g.*, step-dow n tra n sfo rm e rs) vould have to be la r g e r to p re v e n t b u rn -o u t. The a d d itio n a l g e n e ra tin g c a p a c ity fb r 44 m illio n * k ilo v o lt-a m p e re , p ric e d in cre m e n tally , vould amount to about $300 m illio n ; *J th e ^ a d d it io n a 1 tr jn s a is a ^ o g _ a n d _ d y I h g U ^ o n .a q u ^ a jjn t v q u .ld _ a m o y ,_ tp . 'abouri^CXJ'm nilonr CONSEQUENCE - REDUCED AVAILABILITY OF CAPACITORS WOULD ADD FURTHER SUBSTANTIAL BURDEN TO THE ENERGY SUPPLY SITUATION* *V POWER SYSTEM STABILITY Tha preced in g d isc u ssio n in d ic a te s t h i t e le c tr i c s l energy requirem ents c o u ld t h e o r e t i c a l l y be met by u sin g fe v e r c s p s c l to r s and b u ild in g o v e rs iz e g e n e r s tlo n , tra n sm issio n and d is tr ib u tio n com ponents ( s t a sev ere economic p e n a lty ). Such a system vould be o p e ra tin g s t lo v pover fa c to r - - o r , in o th e r w ords, the system vould be c a rry in g s la rg e component of u s e le s s r e a c t i v e v o lt- a m p e r e s i n a d d i t i o n t o Che in - p h a s e com ponent t h a t r e p r e s e n t s ADM 00725 104 n e rg y d e liv e r y . S y ste m s tu d ie s have shown ( te e Economics o f JU lo v ar S upply by C am pbell, Ros, end T ic e , C e n e re i E l e c t r i c Company, Ju n e 2 0, 197 t h a t low power f a c to r se v e re ly H a l t s th e c a p s b illty of a power pool to la p o r t power from I ts neighbors d u rin g a lo sa -o f-g e n e ra tio n eaerg en cy . CONSEQUENCE - CAPACITOR SHORTAGES WOULD MAKE LARGE POWER SYSTEMS SUBJECT TO CASCADING OUTAGES, OR "BLACK-OUTS." SIZE AND REPLACEMENT As p o in te d o u t e a r l i e r , th e e ls e and e o e t o f a ln e r a l o i l im p reg n ated e a p a c l t o r s w ould be a t l e a s t tw ic e t h a t o f PCS c a p a c i t o r s . The l i g h t i n g I n d u s t r y h a s d e s ig n e d t h e i r b a l l a s t s f o r t h e s m a ll s i z e PCB c a p a c i t o r s . A p p ro x im a tely 20X o f b a l l a s t e a p a c lto r s a re u se d in th e rep la ce m e n t m ark e t Many room a i r c o n d itio n e r s have no ap ace f o r a l a r g e r c a p a e lto r i f a re p la c e m e n t l a r e q u ir e d . The c a p e e ito r I n d u s tr y h as c o n tin u a lly moved to reduce th e s iz e o f c a p a c ito rs . Equipment m an u factu rers have tak en edvaneag o f th e s e s iz e r e d u c tio n s , and have no room f o r e lz e in c r e a s e s . In c e r t a i n e s s e s , e lz e lim ita tio n s in th e replacem ent m ark et would fo rc e th e scrap p in g o f good lig h t fix tu re s and a ir c o n d itio n e rs. CONSEQUENCE - UNAVAILABILITY OT SMALL SIZE CAPACITORS WOULD FORCE THE EARLY OBSOLESCENCE OF GOOD, FUNCTIONAL EQUIPMENT. C e n e ra i E l e c t r i c Company November 19, 1973 9 t AOM 0 0 7 2 5 9 105 John F . Welch V ice-P resid en t, General E lectric Company January 14, 1976 General E lectric w elcom es the opportunity to participate in today's p roceed in gs and w ish es to com plim ent Mr. Train and the EPA for the constructive manner, in which they have approached this very com plex PCB issu e. A cooperative effort between gov ernm ent and industry can avoid the delays brought about by adver sa r y p roceed in gs and should truly benefit the public at la rg e. A s the leading industrial u ser of PC B's in the manufacture of capacitor and transform er products, we have pursued a parallel course both to reduce the PCB discharges from our manufacturing plants and to find an acceptable substitute for their u se in e lectrica l apparatus. The public record shows that we have made excellent progress in lowering PCB discharge lev els at all related manufacturing site s. Our technological developments have positioned these fa cili tie s to a ch ieve d isch arge le v e ls in the ou n ces-p er-d ay range. How ever, p rogress has been m ore difficult in the search for a PCB substitute. G eneral E lectric for the past 30 y e a r s has attempted to find a suitable su b stitu te. In the early y e a r s, th is effort was directed to im proving the econom y and perform ance of its e le ctr ic a l apparatus, but in the past several yea rs, the em phasis has been to provide a m o re environm entally acceptable substitute. We have tested over a hundred fluids representing the full spectrum of chemical sub stan ces, and although'there are prom ising leads, they all require additional lo n g -term testing for reliab ility, safety and environmental com p atability. F o r exam ple, in capacitors, all known potential substitutes, unlike P C B 's, are flammable. This characteristic presents a sig nificant problem to the u sers of capacitors: the appliance, lighting and se v e r a l other con su m er-related in d u stries. * Consum er product safety is just one of the many complex is s u e s which have to be resolved in evaluating a PCB substitute. E nvironm entally, as a m inim um , we m ust be satisfied that any subsubstitute considered is a significant im provem ent' over PCB's. As we stated at the outset. General Electric is m ost willing and indeed anxious to cooperate with EPA in their goal of finding a satisfactory substitute for PCB's in electrical apparatus. How e v er , we urge that the com plexity of this issu e and the potential con seq u en ces of precipitous action be thoroughly and thoughtfully 9- 10 3 gg.ag*T co n sid ered . Industry and government have the opportunity to dem onstrate, on this highly visible PCB issu e , that they can work together in solving environmental questions in the best interest of the public,. -10-' '107 HAL yi ELECTRIC GENERAL ELECTRIC COMPANY, 1 RIVER ROAD, SCHENECTAOY. NEW YORK 1234S ' (Alt) 974-2211 ' CORPORATE FACI LI TI ES SERVICES I C r January. 15, 1974 Hearing Clerk U. S. Environmental Protection Agency Washington, D. C. 20460 Be: 40 CFR 129 (Subpart I) G entlem en: On December 27 (38 FH 35388), EPA proposed an effluent standard for polychlorinated biphenyls, and made the proposal applicable to capacitor and (we infer) transformer manufacturers. Persons adversely affected by the proposal were Instructed to file objections by January 18, la accordance with 40 CFR 104 (39 FR 1027). . The General Electric Company (G.E.) Is engaged in the manufacture of Industrial and power capacitors, as well as power and distribution transformers. PCBs are widely used as insulating liquids in both categories; hence, our operations will be vitally affected by the final regulations. The degree of our reliance upon PCBs, their essentiality, and the economic . . Impact of an effective ban on their usage have been'addressed in our recent letters to Dr. Martha Sager (Chairwoman, Effluent Standards and Water Quality Information Advisory Committee) and Dr. C. Hugh Thompson (Chairman, Hazardous and Toxic Substance Rgulation Task Force), Copies of both letters are attached hereto. f; The proposed standard was apparently based solely on tordcologlcal data that \ V appear In EPA's Proposed Criteria for Water Quality (38 FR 29646). If so, we are * concerned about the paucity of data upon which the standard was based, the relevance of existing data to the creation of a toxic pollutant standard, and indeed - the validity of EPA's extrapolations from such data. More specifically, we And (1) an unnecessarily ; stringent standard, (2) a failure to distinguish among different PCB compounds, and (3) a failure to consider the exemption of residual PCBs from the standard. .. ADM 0 0 7 3 0 3 EX H IB IT - C* 108 6ENERU3 ECTHI6 U. 8. Environment*! Protection Agency - 2- . January IS, 1974 Nonethelea8, we cannot render responsible comments or objections a* required by 40 CFR 104. 6(d) in the absence of EPA's "statement of basis and purpose." A capsule summary of the statement was presented in 38 FR 35383, alone with an acknowledgment "that there may In some cases be inadequacies in the underlying data base." However, the complete text was not publicly available, as of January 11. Federal Regulations (40 CFR 104.4) would seem to have required availability by December 27. EPA states that "the attached standards are not based upon economic considerations," although its own criteria document acknowledges that such con siderations are important in "establishing particular standards and control measures" for pollutants that "may be listed as toxic pollutants under subsection 307(a)." See Proposed Criteria for Water Quality, Vol. I, U.S.E.P.A., October 1973. EPA then ckdms that "the Impact of the standards upon the economy has been examined and does not appear to be great." We disagree. In our judgment EPA's proposed standards would have a major economic impact. Presumably the rationale of EPA's examination also appears in the "statement of basis and purpose." Our . analysis of such examination must await our receipt and review of that document. For the sake of continuity, we plan to make an economic and feasibility presentation in conjunction with our (oncological comments. At that time, we will address the question of relevance, as required by 40 CFR 104.6(d). In view of the unavailability of essential data it is unreasonable to require G.E. to formulate detailed objections at this time. Therefore, on behalf of G. E ., I hereby file a general objection to'40 CFR 129 (Subpart I) and request that the Presiding Officer: , r^pdruint'td''40"CFR"ItW7 ) , '"findreai^nablV cause"existed for. our failure to submit specific objections to 40 CFR 129 (Subpart I) by January 18; (2) pursuant to 40 CFR 104.6(a), authorize eur subsequent submission of specific objections to 40 CFR 129 (Subpart 1), said authorization to terminate no sooner than one month after the aforementioned "statement of basis and purpose" is made available to G. E .; and (3) pursuant to 40 CFR 104.8(a), designate G.E. as a party in the subject proceec&ng. '! ij AOM 0 0 7 3 0 4 EX H IB IT "C" ' CENERAI.^- iliC TR IC t ;U. S. Environmental Protection Agency -3- * January 15, 1974 Please contact me (AC 518/374*2211, ext, 5-9056) If the Presiding Officer rules adversely on any or all of the above requests. Regardless, you may expect my attendance at the January 25 hearing. I will be ready at that time to assist in laying the groundwork for the future conduct of this proceeding. *c Sincerely yours, SUR:a Enclosures i Stuart U. Riehe1 Attorney-Environmental Protection l >.L' i - ^ 1 r \ i.: \ { VI * AOM 0 0 7 3 0 5 ex h ibit *cc 110 GENERAL ELECTRIC COMPANY 877TH MEETING OF THE BOARD OF DIRECTORS NEW YORK, NEW YORK - SEPTEMBER 12, 197S A meeting of the Board of Directors of General Electric Company * was held, pursuant to due notice, at the offices of the Company, 570 Lexington Avenue, New York, New York, on Friday, September 12, 1975, at 10:55 A. M ., Eastern Daylight Savings Time. ' There were present: M essrs. Reginald H. Jones, Chairman John E. Lawrence J. Paul Austin Ralph Lazarus James G. Boswell, II Edmund W. Littlefield Silas S. Cathcart Jack S. Parker Walter D. Dance Samuel R. Pierce, Jr. Charles D. Dickey, Jr.- Gilbert H. Scribner, Jr. Henry H. Henley, Jr. Herman L. Weiss Henry L. Hillman Walter B. Wriston ( Frederick L. Hovde Gilbert W. Humphrey Robert M. Estes Secretary Mr. Thomas S. Gates did not d the meeting. 9018 APPROVAL OF. THE MINJJJSS -OF; THE30ARD^CbF'-D:I^ECTORS- ^ "** . u _ AUGUST 1,1975 \( 1'' The minutes of the meeting of the Board of Directors held on August 1, 1975, copies of which were distributed, were reviewed and approved. September 12, 1975 V. Ill will be known as "GE Supply Company of Saudi Arabia. * Vice Chairman Weiss reported that for the first eight months, sales of the Components and Materials Group were 16 per cent under 1974 and earnings were 40 per cent -- or $35 million -- below 1974. Inventories were $76 million lower than the first of the year and cash generated after dividends for eight months totalled $73 million, an improvement of $154 million over 1974. Order rates for most of the Group's short cycle businesses continued to strengthen In August. Mr. Weiss also reviewed the Impact of recently announced raises In prices of steel and aluminum. Vice Chairman Weiss noted that Industrial Research Magazine has selected the 100 most significant new technical products each year since 1963. General Electric led the field In 1975; and Its total since the inception of the awards is more than twice as high as the next highest company. Vice Chairman Weiss referred particularly to the development ?>'r of a "super-microbe" which may be useful in the safe and rapid disposal of oil spills. He stated that Dr. Ananda Chakrabarty of the R&D Center is had been selected by Industrial Research Magazine as scientist of the year. Vice Chairman Weiss reviewed In detail the background of recent \' v- / charges against the Company relating to discharges of PCB from its plants at Hudson Falls and Ft. Edward, N.Y. Mr. Weiss explained the reasons I for use of PCB in transformers and capacitors, steps taken by the Company September 12, 1975 6 112 (including capital expenditures) to reduce discharges since PCB was first associated "with effects on health, the compliance with requirements of the Federal Environmental Protection Agency and the progress to further reduce discharges. He stated that the N. Y. State Commissioner of Environmental Conservation had insisted on a Company commitment to a zero discharge, a commitment the Company could not make in good faith because we know of no feasible way to achieve such a discharge. Mr. Weiss stated that the Department of Environmental Conservation had served a formal complaint demanding a zero discharge and outlined the further steps expected in the proceeding. 9022 REPORT ON MANAGEMENT DEVELOPMENT AND COMPENSATION COMMITTEE MEETING The Chairman of the Management Development and Compensation Committee reported on the highlights of its meeting held earlier this day. A summary of the proceedings is contained in the minutes of that meeting. 9023 REPORT ON AUDIT AND FINANCE COMMITTEE MEETING The Chairman of the Audit and Finance Committee reported on the highlights of Its meeting held earlier this day. A summary of the proceeding is contained in the minutes of that meeting. September 12, 1975 7 4-76 A D M IN IS T R A T IV E P RO CEED !* '" S 6 E LR 3000' IN RE GENERAL ELECTRIC COMPANY. File No. 2833 (N.Y. Dep(. of Enir. Conservation Feb. 9, 1976) In this interim opinion, the hearing officer holds that General Electric Company's (G E) discharges of PCB's fpolychlorinated biphenyls) into the upper Hudson River violate the New York En vironmental Conservation Law fE C L ) . The record over whelmingly establishes violations of E C L provisions prohibiting discharges into state waters which cause violation of applicable water quality standards, these include a proscription on waters con taining "toxic wastes and deleterious substances . in amounts that will be injurious to wildlife or whicn m any manner shall adversely affect tne flavor, color or odor thereof, or impair the waters for any best usage" assigned, including fishing G E 's PCB discharges are toxic substances, capable of causing skin lesions, destroying body cells, adversely affecting reproduction, and inducing cancer and death. The Department of Environmental Protection, which must establish violations by a preponderance of the evidence, has shown beyond a reasonable doubt the G E is responsible for the heavy con centration of PCB 's in the upper Hudson which violate water quality standards by injuring fish and making them dangerous to consume, thus destroying fishing. G E responsibility is shown by the size of its discharges as compared with others in the same area, and by the fact that PCB concentrations downstream of the G E plants are far higher than upstream As an affirmative defense. G E asserts tnat us conduct is immunized from state law penalties by virtue of its being specifically authorized in a senes of permits granted under the Federal Water Pollution Control Act. This defence must fail, for all G E permits have contained language spe cifically prohibiting violation of state water quality standards The hearing officer also rejects G E 's claims that its current, reduced levels . : PCB discharges are too small to violate the E CL . and that no injunction will he respecting the high emission levels which G E has a,reads voluntarily abandoned The claim that G E violated a crimma. water pollution provision of the E C L . however, is dis missed. for it wj* not intended to cover a continuous course of con duct like respondent's Further hearings will be held to determine what level of PCB discharge G E may be ordered to achieve, to wh3t , extent G E should be required to rectify the damage caused by us past discharges, the availability of PCB substitutes and their ade quacy anc environmental acceptability and whether G E should be required to post a S2 million performance bond Counsel for Dept of Envir Conservation Robert M Hallman. Dep C o n iji r and General Counsel Philip Gulen * Philip V*ardwell N Y State Dept of Envir Conservation 50 Wolf Road Albanv NY 12233 (5I8> 474-212! Counsel for Respondent G E D Earle Evans. Jr Anthony R Pittarelli Bond. Scnoeneck &. King One Lincoln Center Syracuse N Y 13202 (315) 422-012! Counsel for Intervenor N Y. State Dept of Commerce ' J Bruce McDonald. Counsel N Y State Dept of Commerce 9d Washington Ave Albanv \> 2225 (5!?- 474-2121 Counsel for Intervenor Natural Resources Defense Council . Saran C . Rosemarv Nichois Naiura: R^.'urces Defense Council 15 V* est -um Street New York NY ICC36 (212) So9-0;50 Sofaer. Hearing Officer Tins proceeding w-as ucMiuucuwed on September 3. 1975 by the Department of Environmental Conservation ("Department'') to enforce against the General Electric Com pany("GE'') ]7-0501. 17-0511' and 11-0503' of the Environmental Conservation Law of the State of New York (" ECL") and of water quality and purity standards promulgated pursuant to E CL 17-0301. The complaint alleges that G E is polluting the waters of the Hudson River by directly and indirectly discharging a toxic substance, polychlori nated biphenyls ("PCB 's"). into the river from the Company's facilities at Hudson Falls and Fort Edward (ECL 17-0501. 17-0511) and that the discharged PCB's are injurious to fish life of the Hud son River (E CL 11-0503 1) The Department seeks far-reaching relief, including an order that G E cease ns discharge of PCB's from all point and non-point sources.4 that G E restore the health of the Hudson River and other natural resources to the extent its PCB dis charges have despoiled them. 3nd that these objectives be attained through a procedure under Department's supervision, including a requirement that G E file a surety bond of S2.000.000 to guarantee its compliance G E answers that its discharges do not violate the ECL and raises as an affirmative defense compliance wuh its permit under the National Pollutant Discharge Elimination System (NPDES). now a State Pollutant Discharge Elimination Permit (SPDES). issued originally by the L' S Environmental Protection Agency (EPA). G E argues that no basis exists for the imposition of any remedy At the same time, the Company represents that " it is going forward voluntarily with a program to achieve maximum treatment and containment " Reply Brief, p I (Jan 12.1976) At the hearing, ns manager of Engineering and Product Development. Dr. Michael Modan. testified that G E was in the process of reducing its dis charge of PCB's from a claimed daily average of about two pounds, to a maximum daily amount of one hundred grams by the end of 1976 Tr 1322 These amounts are m sharp contrast to the com bined daily discharge level of 30 pounds from the plants at Fort Ed ward and Hudson Falls described in G E 's SPDES permit. The hearing commenced on October 6. 1975. when petitions to intervene were made by the New York State Department of Com merce ("Commerce ') and the Natural Resources Defense Council ("N R D C ") in behalf of itself and others' After oral and written argument, the pennons to intervene were granted on certain condi tions. as outlined in an opinion fled on November 19. 1975 * The parties engaged m extensive discovery after which nine additional days of hearing were held All witnesses were available for crossexamination. and the parties offered direct as well as rebuttal testimony A substantial record has been compliled. consisting of several thousands of pages of transcript, prefled testimony, reports, studies, articles and miscellaneous other exhibits12*456 1 E C L I *-0501 p'<yyit>'hon jta m u poilunon Ii shall be unlaw ful for an person d ire c ts or indirectly, to throw d rain, run or otherwise discharge m o Such waters organic or inorganic m ailer that shall cause or contribute to a condition in conira*ennon of ;ne stan dards adopted b me department pursuant io secnon 17-0301 2 E C L I '-0 5 11 R r \ i f Ki,.ir\.in ./<*, oi w Ki 'iju u r a i *u>ieumih, r owes The use of existing or - .r * /uiiets or oomi sources which discharge sewage industrial w<>ie or o n e - w jsie s mio waiers of this slate is prohibited unless such use is in compliance wuh ail xiandards criteria, lim itations, rules and regulanons promulgated or applied b> the department pursu ant to this article J E C L 11 -0503 Polltiimt iirom i prohibited No d vesiu ffs. coal tar -efuse from a gas house cheese factory, cream ery, condensary or canning factor. sawdust shapings, lan barx. lime acid, oil or other de'ete-'Ous or poisonous suDsiance shall be ih ro n or al lowed 10 run mm an waters eiiher private or public, in quantities in jurious io fish life protected wildlife or n e rfo w i inhabiting those * a ters or m/urious to the propagation of fs h proiecied wildlife or waierfowl iherem 4 E C L I *-0105416* "Pom t Aource'' means an discernible, confined and discrete con veyance, including but not limned io an pipe ditch, channel tunnel, co n d u it-w e ll, discrete fssu re . comaine- 'O'lmg stock, concemrated animal feeding operation o- vessel or other floating sioca from which pollutants a rt or may be discharged 5 The others are the Hudson R is e r Fisherm en's Association Inc . the Hudson R iv e r Sloop Restoration. Inc and the Federated Conservationists of Westchester Co unty. Inc In addition a statement bv the L nited Electrical W orkers w u made without objection from me parties 6 16 E L R 30001 For moving papers, see E L R 65296 - i i | The opinion and other papers and d o cu m e n t in this litigation ire on file wuh the Ne Yore Slate Department oi En viron m en tal C o n se f vaiion. O ffice of the G eneral Counsel. 50 W olf Road. A lb an *. N e Yore 114 6 LR 30008 ENVIRONMENTAL LAW reporte *-76 The filing of this enforcement action necessitated findings and conclusions on whether GE has violated any or all the statutes in* voked, On the other hand, it became dear to all those involved that a hearing and judgment concerning the remedies that should be im posed would become necessary only if G E was found to have acted unlawfully. The parties therefore agreed to defer the complicated remedial issues in this case until violations of law were found/ In summary, the record in this case overwhelmingly demon strates violations of ECL 17-0501 and 17-0511. within the applicable statutory period. PCB's are toxic substances, capable in sufficient quantities of causing skin lesions, destroying cells in vital body organs, adversely affecting reproduction, and inducing cancer and death. G E has discharged PCB's in quantities that have breached applicable standards of water quality, the PCB's have injured fish, and have destroyed the viability of recreational fishing in various parts of the Hudson River by rendering its fish dangerous to con sume. Fish analyses in evidence present a grim picture in which PCB contamination reaches over 100 times the temporary tolerance level established by the U.S. Food and Drug Administration (" FD A ") in 1971. These unlawful consequences are the product of both corpor ate abuse and regulatory failure: corporate abuse in that G E caused the PCB's to be discharged without exercising sufficient precaution and concern; regulatory failure in that G E informed the responsible federal and state agencies of its activities, and they too exercised in sufficient caution and concern until this action was instituted by New York's present Commissioner of Environmental Conserva tion. G E is responsible for its conduct and must be compelled to abide by the law It will at a minimum be ordered drastically to limit its discharges, as it claims itself willing and able to do; to consider and use substitute products wherever feasible; to take other steps that may be appropriate to prevent intentional and non-intentional future discharges; and to rectify the effects or its prior violations where lawfully proper, and economically and environmentally practicable. The public must not be made to pay a continuing price for past bureaucratic insufficiency. But neither should the legislature and public be deceived by this focus on GE's activities into assuming that government has otherwise dealt in a meaningful, institutional fashion with PCB's. or with other hazard ous substances being discharged into our environment.' Effective regulatory surveillance would have prevented much of the harm that G E has inflicted. The remedial order ultimately imposed in this case will therefore be constructed wuh a full and fair apprecia tion of the fact that, while the damage must cease and be rectified. G E has operated openly and negligently rather than in secret or in disregard of PCB discharge limits set in ns permits, For this reason, among others, the charge under ECL 11-0503 is dismissed /. P C B ' s a n d th e H u d s o n R iv e r A C om position an d Properties o f P C B 's PCB is the abbreviation, for a group of chemicals known as polychlorinated biphenyls. Their composition is based on the "biphenyl. " a substance made by healing benzene under appropriate conditions. The biphenyl consists of two phenyl molecules, each having six carbon atoms attached in a chain with its two ends hooked together to form a ring, and each' with six hydrogen atoms attached to its six carbon atoms.* A biphenyl nng is formed by*89 7. The Department objected when the Hearing Officer noted that any opinion and findings filed' prior to a determination of the.relief lo be afforded would be tentative and interim Tr 1944-1950 The objection was overruled since final and appealable findings and conclusions ill and should be filed with the Com missioner only after the proceeding ts complete. 8 New York enacted in 1973 a toxic substances control bjll which'gjves the Department authority lo promulgate within "not less" than one *car rules and regulations in control the discharge and storage of subsiances determined to be hazardous to the environment. L 1973, C -WO. E C L 37-0101 et je<j No official Department .icuon has yet been taken. EP A . pursuant to the IV1! Xmcndments of ihe FW'PCA. is responsible for setting effluent standards tor toaic pollutants FW PCA 307(at(l). 33 U S C . i I3l 7fai \n initial list of pollutants, proposed in 1973. includru PCB's 38 FR '80*4 i July 6, 197)) The Aci mandates that (he Adminstralo' focus on these " most enous hazards to man and oiher organisms inhabiting or consuming water" NRDC.sued EP a in- I47J to require it to promlgale I3u7fal standards E P A then proposed standards and hearing were held in 1974 See Tr 1145 No effluent standards have as yet been promulgated. 9 Each carbon atom, has the ability lo form four links, or bonds, with other aform. Crie w.iy m which si* carbon atom* cmnbine is for each to have one breaking the links between one carbon and hydrogen atom on each of two phenyl molecules and making instead a new carbon-to-carbon bond The result is a compound empirically described as CuHiu, or by the following structural diagram; H HH H h--c 'C""*Sc-- c /C X - h H HH H To chlorinate a biphenyl one must replace ns hydrogen atoms with chlorine. When only one chlorine atom is added in place of a hydrogen atom, the resulting compound is called a monochlorbiphenyl. When more than one chlorine atom is added, a polychlorinated biphenyl is formed. Since each biphenyl has ten hydrogen atoms. K B 's may have any number of chlorine atoms up to ten, and PCB's wiih anywhere from one to ten chlorine atoms are called homalop of each other. In manufacturing PCB's. it ts generally not possible exclusively tocreate molecules with a specific number of chlorine atoms. Instead, when chlorine gas and biphenyls are mixed, many homologs of PCB's are formed, and the average number of chlorine atoms with each biphenyl varies with the temperature. PCB mixtures not only contain different homolo^, they also consist of different "isomers." Each biphenyl has several possible sites for chlorine atoms, and the different arrangements of atoms are called isomers of each other. For example, dichlorobiphenyl (two chlorine atoms added) has 12 possible isomers, each with the chlorine atoms at different places on the two phenyl rings. The em pirical formula CnHiCti would apply to all these isomers, but structurally they would bedifferent. Chemists express these differ ences either diagramatically or more succinctly by describing the location of the chlorine atoms in accordance with the following position numbering system: 3=2 W Thus, for example, if the chlorine atoms in a tetrachlorobiphenyl (4C1-PCB) were located at the " 2" and "5" positions of each phenyl molecule the resulting compound could be described as 2. 5. 2`. 5` tetrachlorobiphenyl. The sole manufacturer of PCB's in the United States is the Monsanto Chemical Company. Domestic sales of all PCB's by Monsanto have ranged from 26.061.000 pounds in 1958 to 73,061.000 pounds in 1970; in 1974, sales totalled 34.406.000 pounds G E Exhibit 19. Until 1971, PCB's were sold for numerous commercial purposes. Monsanto limned PCB sales in 1972. however, to socalled closed applications. The sole application for which PCB's have been used in recent years, according to Monsanto data, are transformers and capacitors. The G E plants at Hudson Falls and Fort Edward manufacture transformers and capacitors. <md use PCB's in their preparation. Since 1966, GE has purchased 82,213.000 pounds of PCB's of all types from Monsanto for use in its pro ducts. Dep't Exhibit 6. PCB's, especially mixtures with relatively high percentages of chlorine, have useful physical properties. They are essentially non flammable. Tr. 1136-37 fDr. Simons). They are extremely stable; for example, a mixture with an average of five chlorines released only traces of degradation when treated with concentrated sulfuric acid for 2S5 hours or boiling 10 percent sulfuric acid for i50 hours. bond with ihe carbo(ion one side of it. *nd a double bond nn me r<ron on its other side Thu Cunfiguranon leaves eaen carbon with one unused 'm*. which in ihe phenyl rftulecule n occupied by a hsd.oeen atom The results <.an be described as C.H t 5r by the following sirmaural diagram MH See Dept Exhibit 15. p. 1 The description oi PCS'* is drw-i * testimony of Dr. Gilman D. \'e*lh. Dep't Exhibit 14 md Dr. E Tr. 1118-26 115 4-76 ADMINISTRATIVE p r o c eed 5 E L R 30009 Dep't Exhibit 14. p 7 (Dr Venh) Finally, electric current can pass through PCB's without alTecting or being affecied bv them. These properties have made PCB's desirable for use in capaci tors and transformers Transformers are used to change one type of current into another, and consequently dispense with the need to create generating and transmission capacity in all useful forms of current Capacitors also save considerable electrical energy Many motors and other electrical devices have parts that must be mag netized to operate, when such a motor draws current, only part of the current is used m rotating the shaft, the rest is required simply to maintain the magnetic Hied Without a capacitor, electricity would flow back and forth from the generating station and the motor, as it does in other applications With a capacitor hooked jeross a motors terminals, however, the magnetizing current is captured, rjther than sent back to the generating source, and returned to the motor during the next electrical cycle The net sav ing of power by using capacitors was estimated without rebuttal as 30 percent, or. to run three air conditioners with capacitors would require the same electrical power required to run two such air con ditioners without capacitors Tr. 1127-35 (Dr Simons). Monsanto has sold, and G E has used. PCB's with a variety of chlorine percentages These mixtures have been merchandized under the trade name " Aroclor." followed by a numerical designa tion such as Aroclor 1254 The "12" represents the 12 carbon atoms in the biphenyl ring, and the last two digits. " 54" for example, indi cate the average percent chlorine of the particular mixture Aroclor 1254 ("A 5 4 '). therefore, would have an average of five chlorine atoms for each biphenyl ring, though the mixture will contain PCB's with anywhere from 3 to 7 chlorines Dep't Exhibit No. 14, p 6 (Dr Venh) Until 1971. Monsanto sold large quantities of various Aroclors. especially 1242. 1254 and 1260 In 1971. the com pany introduced a new mixture, which u designated Aroclor 1016 (" A-1016") Since then. A -1016 has accounted for an increasing proportion of PCB sales, until in 1975. A-1016 sales are running at a greater rate than the sales of all other Aroclors combined G E E x hibit 19. p 3 G E purchases of PCB's from 1965 to 1975 indicate an almost total shift from A -1242 and 1254 to A -1016. and to a minor extent A -1221 Dept Exhibit 6 Aroclor "1016" is a deceptive numerical designation for that compound The chemical has 12 carbons, not 10. and contains over 41 percent chlorine, not 16 Monsanto's Manager of Product Accep tability testified that there was no scientific reason for the designa tion "1016." and conceded that "following the old nomenclature it should be called Aroclor 1241 plus'" Tr 1232-33 There is a differ ence between A -1016 and 1242. but it is not in the percent of chlorine Rather, it is in their homolog composition. Monsanto spe cifications show a maximum of 4 percent of homoiogs with five or more chlorines in A -1016. whereas the t>pical A-1242 mixture con tains o to ' percent of such homologs Dep t Exhibit 19(2) (Letter of W B Papageorge. Monsanto to Dr David L Stalling. U S Dep t o f Interior. Oct 17.1973) The extent to which this difference has any bearing on toxicity is discussed below B Presence o f P C B 's m the H udson R iv e r The Hudson River is some 305 miles long, from ns source at Lake Tear of the Clouds to the George Washington Bridge at New York City This case deals primarily with that part of the river near and downstream of the G E plants at Hudson Falls and Fort Ed ward The plants are only about one mile apart To determine the amount and type of PCB's in a body of water, or in any other matter, is no easy task. All the evidence pro duced at this hearing was derived through gas chromatography, the science of separating chemicals by heating them to the points that they become vapors." The parties recognize that this method is not perfect. Furthermore, the fact that analyzed material is found to contain a particular PCB configuration, for example A-1242, does 10 C h em ical* introduced in a gas chrom atograpn ill move n different rates depending on their respective boiling pom is. and w ill separate from the chrom atograph at d ifferen t times Each separation i$ recorded by a detector, w h ich then draws a pea on a chart paper recorder resulting eventually m a "g*s chrom atogram " The intensity of peaks on the chan recorder is propor tio n a l to the q u a n tity of the p a rticu la r ch e m ical escap in g from the chrom atograph By com panng a chrom atogram of an unknown m ixture with those o f m atu res whose contents were know n, an analyst is able to identify the types ar.d amounts o f chem icals in the unknow n m atu re with those o f m ixlures hose contents ere known Sec generally Dep 1E xh ib it 14. pp 4--13 ( Dr Venh) noi necessarily mean that thr material originally discharged was A-1242, since PCB homologs have different rates of btoaccumuialion and degradation. Further, chromatograms of mixtures wuh similar chlorine content tend strongly to resemble each other, a cir cumstance particularly true of A-1242 and 1016 But none of the parties objects to chromatography as a scientifically adequate way of measuring for PCB's. The record contains substantial evidence of PCB's m the water, sediment, organisms and fish of the Hudson River During August 1974, emplovees of the U S Environmental Protection Agency ("EPA T conducted an investigation of PCB contamination in the Hudson They found a concentration in water at the outfall from GE's Fort Edward facility of 2800 ppb (parts per billion or ug/1) A -1016 Sediment at the same sampling station yielded 6700 ppm (parts per million or rngAg) A-1016. indicating the absorptive capacity and constant exposure of the sediments nearest the outfall. At another station, one-half mile downstream, sediments contained 2980 ppm A-1016. or an accumulation 10* times greater than the recorded outfall concentration Dep't Exhibit 28. R J Nadeau k R P Davis. In vestig a tio n o f P o lx rh lo rm a te d B ip h e n y ls m the H u d so n R iv e r, p 9. Composites of snails found below the G E discharges were found to contain up to 45 ppm of a PCB analyzed as either A-1242 or 1016 G. D Venh to R J. Nadeau. Oct. 23. 1974. m Dep t Exhibit 28. appendix Shiner minnows had 78 ppm. and a rock bass set what was then regarded as "a new record for PCB contamina tion of fresh water fish." with 350 ppm. Id. 14, 18 The Department has for several years been aware of the pre sence of PCB's in New York's waters, including the Hudson. An analysis of fish in 1972 indicated a concentration of PCB's in largemouth bass of 0 66 to 14 62 ppm. in white perch of 0 38 to 15 8! ppm. and in stnped bass of 3.70 to 49 63 ppm Data compiled in 1973 on striped bass indicated that most fish tested contained more than 10 ppm PCB's. ranging up to 49 63 ppm in one sample Fish from other waters also had high concentrations G E Exhibit 11. appendices Beginning on December 4. 1974, the Department's Division of Pure Waters initialed, in conjunction wuh EPA, a more systematic monitoring program of PCB's m the Upper Hudson River Basin, an area including GE's plants W'ater and sediment samples were taken from several sampling stations Special precau tions were taken to assure quality analysis, including a series of interlaboraiorv comparison studies A-1016 was found in water below the G E plants at a rate of 3 ppb during mid-wmier 1974-75. indicat ing a river load of that PCB of about 94-97 lbs per day 11 Bv late August 19?5. when the studv terminated, sampling at the same sta tion reflected 0 06 ppb A-1016 in the river indicating a river load of less than 14 lbs per day Sediment and core samples" below the G E plants showed concentrations of A-1016 ranging as high as 100 ppm. 201 ppm and 1850 ppm as well as high concentrations of A -1221 and 1254 Dep't Exhibit 9 pp 6 -7 (R Mt Pleasant) This water and sediment monitoring studv included no collection and analysis of fish and other organisms On the basis of the water con centrations observed (not including the effects of sediment, runoff or other sources of PCB's). however, the report predicted that fish flesh concentrations of 3 ppm to 150 ppm of A-1016 would result Dep't Exhibit 5. pp 25-26 The Department's contemporaneous study of Hudson River fish overwhelmingly confirmed this antici pated result The Department initiated a statewide Hsh sampling program in August 1975 to ascertain the extent of PCB concentration. Numerous samples were taken from the Hudson River, prepared and analyzed, once again, precautions were taken for quality assurance Fish captured at stations below the G E plants contained higher amounts of PCB's than previously found Concentrations of12 11 The nver load of PCB s s the total mount of P C B * from 11 discharge points that enter th$ river daily This figure is derived b r-e isu rin g the total P C B s suspended in ihe waier column from dail* samplings - n u iiip iy rg ihis total by the daily volume of river flow which is expressed in cubic feei/second. and ihen multiplying b> 86.400. the number of seconds m dv 12 Sediment samples re obtim ed from ihe top level of ihe n ver sediment The Department sei this depih ( five centim eiers for iheir program The sed.ment is scooped up. with suitable equipment, libeled and later analysed for PC B co n tent Dep i Exh ibit 5. p 3 Core samples are taken wiih equipment which can penetrate ihe surface of river sediment or land formation Those core samples taken by ihe Department ranged from three to eleven inches m depth P ie core samples were analysed for PC B content in one inch sub-sample-* < r , h * o n u n a lly extracted core Id App C . figure 6. 116 6 E L R 30010 EN VIRO N M EN TAL LAW R EP RTE' *'6 over 20 ppm A-l 242/1016 were found common. A composite of ten Yellow Perch had 236.42 ppm A-1242/1016, as well as 62.88 A-l254, a total of 299.30 ppm PCB's. An American eel, captured at Still water, was found to contain 403.38 ppm A -l 242/1016 and 155.87 ppm A-1254. totaling 559.25 ppm PCB's. Dep't Exhibit 13, Monitoring o f PCB's in Fish Taken from the Hudson River (Oct. 1975). This figure is over 100 times greater than the temporary tolerance limit set by the FDA in 1971 for PCB's in the edible portion of fish. GE does not challenge these data. During the hearing, the Company sought to introduce evidence gathered by Ecological Analysts. Inc., a firm that engages for profit in preparing testimony for corporations in environmental litigation. Tr. 1426-1427. The evidence gathered was analyzed by the Woodson-Tenent Laborato ries of Memphis. Tennessee, and some initial results were placed in the record through the testimony of Dr. Gerald J. Lauer, Vice Presi dent of Ecological Analysis. Inc. These results showed in 13 fish samples, several of which were taken below the GE plants, not a single sample with over 5 ppm PCB's in the edible flesh. After cross-examination, it became apparent that these data were unrelia ble. G E ultimately terminated its effort to introduce the material and agreed to request the laboratory involved to prepare a complete analysis of all its Hudson River samples.1* The new finding, based in part upon reanalysis of the same samples earlier analyzed, are consistent with the Department's conclusions. Several fish had con centrations of A-1016/1242 over 100 ppm in their edible flesh. Con centrations in what GE termed "non-edible" tissue ranged as high as 1178 ppm. NRDC Exhibit 1. C. GE's Responsibilityfo r PCB's m the Upper Hudson G E "has not contested that it has been a source of certain PCB's in the Upper Hudson River in the vicinity of its discharges." G E Reply Brief, p. 1L But it claims that "tjie evidence does not per mit. . . . by the legal standards which exclude conjecture as a basis for penalties, a finding that the high levels of PCB's reported in these fish are attnbuiable to Respondent's discharges." In particu lar. the company asserts ihere is "no evidence" excluding other PCB sources earlier than September 1975. "no evidence" relating downstream fish concentrations to Respondent's discharges, and "no evidence" as to when the accumulations occurred. Id. The Department has the burden of proof in this proceeding. ECL 17-0905(6). The burden involved is that normally applied in civil and administrative proceedings to prove the alleged violations by a preponderence of the evidence.** It may be that, in order to ob tain some especially onerou> and punitive remedy, the Department would be required to meet a higher standard of proof.1* But G E 's argument that, merely because this is an enforcement proceeding,*lo ..DaEW.ng Vro*yriagii.rujuan,^JJ.r_Lj t results of the sampling program cor Jutted Sv Ecological AnaUsisTlnc 'This in- ` eluded data from the Upper Hudson. Lower Hudson. Long Island Sound and Chesapeake Bj > G E ob.eeled on various grounds Initially its abjection was lhai the requesi was for the "furnishing of additional substantive evidence" and iherefore noi proper wuhm the scope of proceedings here the government has (he burden of proof Tr 1583 More particularly G E argued it had presented no evidence with respect to whole fish in the Upper Hudson nor any evidence "whatsoever wun respect to any type of investigation concerning PCB* in fish elsewhere " Tr 1593 G E also claimed ihe maienil was privileged, even though ii had originally sought to introduce the results of the investigation The Hearing Officer ruied that the material requested for Chesapeake Bay and Long Island Sound samples w*j outside the scope of the issues raised by the complaint, bui direeled G E to produce alt evidence relating to fish in the Hudson River Tr 16*0-61 Respondent requested a 48-hour stay of the order lo allow "a determination as io whether a review of what amounts to a sub poena order should be taken ai this time " A stay was granted. Tr. 1664, but on the followingda> G E withdrew its objections 14. McCormick. Evidence $1339, 355 f|973) The authorities cited by G E for a more exacting burden ace inapposite For example. Becketl v, Pfaeffle. 157 N Y S 247 (1st Dep t 1916. indicates that statutes "penal m nature " require Stricter proof, but it dealt iih a statute that punished its violation with fines and imprisonment Professor Jaffa's article likewise discusses cases where serious, personal consequences are imposed, such as deportation of long-nme resident aliens L. Jaffa. Adminiuratrre La* Burden of Proof and Scope of Review. 79 Harv L Rev 914. 919 (1966). 15. The lest for a penal suiuie in New York is whether the remedy chosen is "impressed for punishment or for redress of injury " Sicolo v Prudential Savings Bank of Bkly n. 5 S Y 2d 254, 358. 184 N Y S 2d 100. 103 (1959) Even a recovery that exceeds actual loss may noi amount to a penal sanction. But the couru have held lhai an arbitrary exaction, unrelated io actual loss, is a penal sanction E g , Verona Central Cheese Co v Munaugh, 50 N Y 314 (1873) These standards make clear that the remedies sought against G E are non-penil. The only violation charged that could justify any sanction that could be charac leriied as penal is E C L U-0503. discussed below. *hich has been dismissed. the Depariment has to prove is case on the merits by dear and convincing evidence, is untenable. | . . In any event, the Department has in fact carried its burden on this issue beyond any reasonable doubt. The evidence that GE is responsible for the high concentrations of PCB's in the Upper Hud son's water, sediment, organisms and fish is overwhelming. To begin wuh, GE has until recently been discharging very large amounts of PCB's into the Upper Hudson. GE applied for a dis charge permit on December 18. 1972, stating that it was directly dis charging an average of 30 pounds per day of "chlorinated hydrocar-' bons" (measured using the test for PCB's). and a maximum of 4 :6 pounds per day from its two plants. Dep't Exhibit 4. p. 3 GE's Manager of Environmental Operations, Dr. Simons, testified that these figures represented what he believed to have been the actual discharge from the plants. Tr. 1166. At the time, GE was purchas ing about 7,900,000 pounds of PCB's each year from Monsanto Dep't Exhibit 6. Purchases of even greater quantities had occurred at least as far back as 1966. Since the record indicates that G E's dis charges have decreased rather than increased m recent years, it is reasonable to assume that it discharged PCB's in 30 lb. per day quantities throughout the 1966-1972 period.'* In any event, GE ob tained the permit it sought, and makes no contention that it signifi cantly altered its discharge levels until early 1975." In March 1975, Clark. Dietz Associates, an engineering firm re tained by G E, performed a wastewater monitoring program at G E 's plants, and reported total average daily discharge levels of be tween 5.06 and 7.81 lbs. of PCB's. Dep't Exhibit 8. During late August 1975, both GE and the Department (with EPA) measured the discharge levels, and found a further reduction: GE's data indi cate an average discharge from the two most important discharge sources of 5.54 lbs., a figure that includes days in which excep tionally high discharges were recorded; the Department's data are roughly equivalent. Dep't Exhibit 7B(15); Dep't Exhibits 4. 29. 31 and 32. These findings show substantial reductions in PCB dis- a charges as compared to earlier periods. Yet. the amounts are still I significant especially when considered as supplementing the large " quantities already released, and the totals probably understate total discharges because some sources were not measured, and dis charges caused by run-off and percolation were not measured.11 After this action was commenced. GE made further measure ments of its discharges. These indicate a combined average of 3.46 lbs. per day directly discharged from its two plants, through the two main discharges (discounting an unusually high discharge of 116 j lbs. on September 13-14; Tr. 1245-48). In addition, however, data J collected by G E indicate average discharges of 1.42 pounds PCB's per day into the Hudson Falls Village Sewage Treatment Plant, .yvhich m turn^discharges into, the, Hudson. The total daily_discharee 'ifrfn'gTfe TeaniTgTrfthi^caserrhe' s 7oGghry'881bsTr' Not only has GE been shown to have discharged large quan tities of PCB's into the Hudson over long periods of time, the Department has established that other sources contribute negligible amounts of PCB's to the river. During September 1975. as part of its water and sediment study, the Department tested effluent from 28 municipal and industrial discharges in the Upper Hudson. The , Hudson Falls Village Treatment Plant showed a discharge of 2.45 ( lbs. PCB's per day, which has been shown to be attributable to GE. } Four other sources had amounts of 0.005. 0001. 0 22 and 0 095 lbs. per day (of which the 0.22 figure may be overstated, see Tr. t 355-56). All the remaining sources indicate no recordable amounts of PCB's. In striking contrast is the study's finding that GE effluent for a virtually contemporaneous period averages a gross discharge 16 30 lbs. per day would s u n over 84.000 lbs. between 1966 and to?J 17. On February 7, 1974. a G E engineer estimated ihen current avenge PCB discharges it 31 4 tbs per day. and maximum discharge at o* lbs per day Dep t Exhibit 16. A. Porqfsky io Dr Simons On May 8. 1971. Dr 5imorts iesu` ed under oath at EPA heannp on Proposed Standards (or To re Substances that G E as discharging 25-30 lbs. per day PCB's (rom us two piants Tr 1165-66 Monsanto sampled the two largest of several discharges n G E's.planu on December 13. 1974, and reported a combined lotal of 18 2 lbs per day `Dep't Exhibit 7(b)( 12), 18. See Dep't Exhibit 4. p, 8. Dep't Exmbii 7a and ''B. Tr 1379-83. a G E wit ness testified that run-off discharge through sources other than thoM monitored was unlikely, bui this was based on a cursory visual examination, and was noi at all addressed to possible discharge by percolation. See Tr. 1J42. Compare Tr 334-35; 1310-11, 1316-17, and the strong evidence ih (he soil around G E's plants find their way into (he river during h e g . Dep't Exhibit 5. Table 6 117 4-76 ADMINISTRATIVE PROCEF" \ gs 6 ELR 3001E of 2.12 11. per day of a -1016. G E protests that this study shows only that it was the major source of PCB's during August and Sep tember 1975. But it makes no effort to prove that other sources of PCB's esist than those studied by the Department, or that those compant s that use PCB's used them in greater quantities in past years. The strongest evidence orGE's responsibility for existing PCB levels is n the contrasting results obtained, in all the studies in evi dence. ol PCB concentrations upstream as opposed to downstream of GE plims. Thus, in the EPA study during August 1974, a read ing of 28X) ppb PCB's m water was taken at the junction of GE's Fort Edvard Plant's discharge and the Hudson River. The con centration at a station one-half mile above Bakers Falls, upstream of the G i plants, was less than 1 ppb. The concentrations at sta tions located .25, .5 and .75 miles downstream of the Fort Edward discharge were 2.2. 3 and less than 1ppb respectively. Dep't Exhibit 28, p. 17. The Department's water and sediment monitoring pro ject, fron December 1974 to August 1975. developed similar results. Water concentrations of PCB's upstream of the GE plants were uniformly (with one anomalous exception, see Dep't Exhibit 5, pp 17-18) less than 0.1 ppb; below the plants, concentrations declined f'om 3 ppb to 1.5 ppb, but were much higher throughout than upstream concentrations. id. Appendix C. Table I. Sediment samples taken above the G E plants also had con centrations of PCB's that were much lower than those below the plants. At the nine upstream stations. PCB's were found in quan tities below 3 ppm with one exception at the Glens Falls landfill, where 14.9 ppm A-1221 was recorded Sediment taken 1500 feet above GE Hudson Falls plant contained 0.6. 2.0 and 2.2 ppm A-1016. 1221 and 1254 respectively. Some of these upstream con centrations cannot be regarded as insignificant, in that they should cause concern for fish and other living things in the river. But the five downstream stations revealed PCB's in much higher quan tities, that render the upstream concentrations insignificant by comparison. A sample taken in the vicinity of the Fort Edward dis charge contained 100, 6 and 8 ppm A-1016, 1221 and 1254 respec tively; a sample from near the Thompson Island Dam, about 13 miles downstream of the Fort Edward discharge, revealed 1850. 1720 and 137 2 ppm of the same Aroclors. Dep't Exhibit 9. pp. 5-8 (R. Mi. Pleasanti; Dep't Exhibit 5, Appendix C. Figure 6. Plentiful evidence gathered concerning PCB concentrations in fish also shows that GE's plants are the only important sources of PCB contamination in that area. The August 19*J4 EPA study showed PCB concentration above the G E plants (but below the Hudson Falls sewage treatment plant) of 17,0. 7.0 and 1.9 ppm PCB's fA-1016/1242-. 1248 and 1254) in samples of Yellow Perch. Shiner Minnows and snails respectively. Sjanons below the G E_ "^ pftms*tir ned^u'p'ih'e^oCt las? TeffrfiSTTcrwfl h''fttT'fo'rh A-1242/1016. as well as Shiner Minnow and two snail samples of 78.45 and 27 ppm respectively. Dep't Exhibit 28. p. 18. The Depart ment's study during 1975 revealed that, in 29 samples taken from upstream stations (above the Hudson Falls sewage plant), all con tained less than 1 ppm PCB's. In contrast, the average concentra tion for the numerous fish sampled at Fort Edward was 176.83 ppm PCB's for the whole fish, and other, very high concentrations were found at most downstream stations. Dep't Exhibit 12. appen dix B-l. An experiment was conducted during October 1975 by the Department in which fish in "live care" were placed upstream and downstream of the GE plants. After 14 days of exposure, the fish upstream accumulated at most only trace amounts of A-1016 (less than 0.1 ppm) while those downstream accumulated from 1.66 to 3 76 ppm A-1016. Dep't Exhibit 12 (J. Spagnoli). GE's data are no less supportive in proving its responsibility. All fish taken at upstream stations contained less than 5 ppm in both their edible flesh and "non-edible" parts; fish taken below the GE plants had an average PCB content in their edible flesh of 94.66 ppm. with much higher amounts in their " non-edible" portions (ranging to 658 ppm in one Common Sucker sample). See NRDC Exhibit 1 and Dep't Exhibit 52. By any reasonable standard, then, G E has been shown to be responsible for the PCB contamination of the Upper Hudson. If others have contributed to that contamination, their contributions are inconsequential by comparison, and they in any case might also be held legally answerable for their actions. The Department can* not be required to prove that specific PCB molecules, discharged by G E, reached specific fish or parts of the river. Comoare GE Reoly Brief, p. 12. Given the natural flow of rivers, and the nature of the issues, the evidence of GE's responsibility is more than sufficient. //. Legal Consequences o f GE's PC8 Discharges A. The Violations Charged The Slate of New York, and our federal government, have drastically revised common law doctrine that allowed pollution of rivers subject only to the rights of other users and the limned no tion of public nuisance. As early as 1881. New York prohibited the discharge of any "noxious, offensive or poisonous substance into any public waters....'' Penal Code. 390 U881). In 1892, the prohibition was expanded to private waters, but limited to "quan tities destructive of the life of. or disturbing the habits of fish in habiting the same." Laws of 1892, c. 488. 5100. The "habits" ap parently in mind during that more decorous time became clear in 1912, when the phrase was changed to "propagation of fish." L 1912, c. 318. 247. In addition, a 1903 statute prohibited discharges injurious to human health, aiming particularly at sewage control. Public Health Law, 76 (McKinney 1943). Major reform was initialed when the legislature in 1946, by concurrent resolution, established a Special Committee of Pollution Abatement. That well-rounded and distinguished group" under took field work and conferences throughout the state, and issued an interim report noting that Americans have been "fouling their own nests," and that public health is the state's "greatest asset" which the legislature should not permit to be endangered or jeopardized. Leg. Doc. No. 59, pp. 22. 25 (1947). The committee considered ex isting laws inadequate. The provision aimed at protecting fish, by (hen 213 of the Conservation Law. was too limited, since it re quired proof that certain specific substances, discharged by a spe cific person, actually injured fish life. The sewagecontrol siajute was found inadequate because actual injury to health had to be proved, and industrial wastes seldom directly injured public health. The committee also reminded the legislature that proposed federal legislation would preempt state control unless New York assumed its own pollution abatement responsibilities. Id, 78. After further study, and with recommendations from the State Conservation and Health Departments, the committee filed a sec ond report containing a proposed Water Pollution Control Act. The bill had a statement of overall public policy calling for use of the < state's water resources in'"the best interests of the people." and a water classification system for determining the best public usage. Industrial wastes were "incMtable." the commitiee concluded, but (hey must be conditioned to avoid deterioration of public waters "for the other purposes for which thev are utilized___ '' Leg. Doc. No. 50. p. 17 (1948). < Hearings followed. Industry spokesmen expressed a k 7^tefefetierfoe.(iKriiiigs*?Tth:Yte-auThriitsTSrheRhTrfedralMtff-'i" ' they wanted the legislature todetermine the specifics of water clas sification rather than an administrator An engineering consultant to the committee, Morris M Cohn, defended the proposed system as realistic and flexible. Pure surface waters is only an ideal, he wrote, which if achieved might result in "no industries or munici- palities around to enjoy the beauties of such streams." He therefore/ saw "pollution" in relative terms, as a "condition which con-' travenes reasonable standards of quality which have been set up' with full consideration of the many (appropriate) factors___ "*V Resume of Hearing on Proposed Pollution Abatement Legislation.^ -- ----------------- ---- . ^ 19. Membera Assemblyman Harold C Ostenag Chairman. Committee on 1nlerstaie Cooperation. Senator Chauncey 8 Hammond. Chairman. Senator Floyd E. Anderson. Vice Chairman. Assemblyman wheeler Milmoe. Seere- -, tary.Senator Walter J Mahoney. AssernbKman Elisha T Barrett, Assembly man George W. Foy; Assemblyman John S Thompson. Attorney Genera) Nittumat L Goldstein; C. Chester Diamond. Commissioner of Ainculture and Markets; Algtfr B Chapman. Commissioner of Taiation and Finance In addi tion. there ere several advisory members from a variety of public and private organizations ^ee Leg. Doc. No. St. p. II U9-(g) 20. He explained further; "Pollution" is no( a hard and fail characteristic It is not like black and white A sensible definition of pollution tabes into consideration what is being polluted. It recognizes that hat is pollution at one point of a stream may not be pollution at another point, or certamlv not on another stream. Is it not sensible to define "pollution" as a condition which con travenes reasonable standards of quality which have been set up with full consideration of the many factors described above?.,. If the standards are sensibly established, the -mena of pollution are ser tamly as two plus two makn four 118 O hLK environmental law reporter 4-76 pp. 13-15 (Albany, N.Y. Aug. 11, 1948) (Legislative Reference of the New York Slate Library, Albany. New York). The legislation was adopted. It established a pattern that is with os still: a system with the avowed purpose of protecting the environment, but through a methodology that explicitly accepts various degrees of contamination. The act was consolidated with others in 1960, and entitled the Environmental Law. L 1970, c. 140. In its present form, the ECL's declaration of policy is "to con serve. improve and protect" New York's natural resources and en vironment, and to "control" water and other pollution "to enhance the health, safety and welfare of the people of the state and their overall economic and social well being." ECL 1-0101(1). Coordina tion and cooperation .at all levels of government are called for, and the state is to foster and maintain conditions under which men can thrive in harmony and achieve "social, economic and technological progress" by assuring healthful and pleasing surroundings: guaran teeing the "widest range of beneficial uses of the environment. . . without risk to health or safety, unnecessary degradation or other undesirable or unintended consequences:" and "promoting pat terns of development and technology which minimize adverse im pact on the environment.. ; ECL 1-010I2) 4 13). The message conveyed is hardly one-sided. It is basically an expression of con cern for the environment, but mixed with strong concern for economic well being and maximum utilization. At the heart of the ECL's provisions relating to water pollution is the water classification system adopted in 1949, and revised in various respects from lime to time. The ECL recognizes, as the en gineer Cohen and his committee would have had it recognize, "that due to variable factors, no single standard of quality and purity of the waters is applicable to all waters of the state or to different seg ments of the same waters." ECL 17-0301U). To obtain the law's objectives, therefore, the Department is instructed to group desig nated waters into classes, after nonce and hearing. ECL 17-030K2). Then, after proper study and further hearing, the Department is to "adopt and assign (necessary) standards of quality and purity for each such classification___ " ECL 17-0301(4). Acting pursuant to this mandate, the Department classified the waters at and im mediately below Fort Edward and Hudson Falls as "Class D " wa ters further downstream are classified "A" and "B". Class D waters must be "suitable for fish survival," though they need not "support the propagation of fish:" among their best usages is "secondary con tact recreation," which is defined to include fishing, but only minimal contact and "improbable" ingestion, 6 NYCRR 701. Since 1966, the "best usage" of Class A and B waters also includes fishing. Finally, an overall standard, applicable to waters classified A through D, is that they shall not contain "toxic wastes and deleterious substances . . . in amounts that will be injurious to fishlife or whichjn any manner sh^aji advert c&)orOr*i5tidr HhVfeof? oP'Tmpair^the waters lor any best usage" assigned. 6 NYCRR 701.5. Compliance wuh these standards is mandated by ECL 170501. which G E has been charged with violating. That section makes it unlawful to discharge, "directly or indirectly." any matter ihat shall "cause or contribute'' to a condition in contravention of the water quality standards established pursuant to ECL 17-0301. The issues posed by this provision, therefore, are whether PCB's in the quantities discharged by GE have "caused or contributed" to a breach of standards that (1) prohibit the discharge of "toxic wastes'* or "deleterious substances" in amounts "injurious to fish life" or (2) "impair the waters for any best usage," in particular fishing. The federal government long ago moved to regulate water pollution through effluent limitations, rather than merely the set ting of stream standards.'1 In 1972, the Federal Water Pollution Control Act (FWPCA) was amended to give the states primary responsibility for pollution abatement, but only if they adopted a program based both on stream standards and effluent limitations. 33 U.S.C. 1251 erseq. New York adopted a Stale Pollution Dis charge Elimination System (SPDES), essentially to avoid a federal akeover. See memo to Governor from Law Department, Senate 6394-A (June 21. 1973); id. (May 31. 1973) (H. L Diamond). Resume of Hearing on Proposed Pollution Abatement Legislation it 14-15 ( A u i 11. 19*8). 2! For a history or federal witcr pollution regulation see l F Grad, Trromt on &>vtronmmat La (JO J (1975). The resulting legal structure requires any would-be discharger of pollutants to seek a certification from the state in which the watere are involved are located. 33 U.S.C. 1341. After state approval, the applicant must obtain a federal discharge permit for the ac tivities permuted by ihe state. Discharging without a state permit violates ECL 17-0505: and increasing or altering a permitted dis charge violates ECL 17-0507. In addition, ECL 17-0511, the second statute under which GE has been charged, prohibits any industrial discharge from outlets or point sources "unless such use Is in com pliance with all standards, crtterta, limitations, rules and regulations promulgated or applied by the department pursuant to this article." The article involved, 17 ECL. includes provisions that make unlawful violations of both the permit and water- classification systems. B. Effect o f SPD ES and SP D E S Permit GE applied for a federal permit to discharge into the Hudson River from its plants at Hudson Falls and Fort Edward as early as November 22, 1971. See Refuse Act. 13. 33 U.S.C. 407. After the FWPCA amendments of 1972, GE submitted a revised application to EPA on January 18, 1973. On August 23.1973. the Department received GE's application under its new SPDES system. The ap plication indicated that a daily average of 30 pounds of "chlorinated hydrocarbons" were being discharged, and in a footnote explained ihat the "test for the determination of the pounds or concentration from which the pounds were derived, was determined by analysis for PCB'sTTr. 401. This was an unecessarily obtuse way of indicat ing its PCB discharges, since GE had been told by Monsanto on July 1, 1970, that "polychlorinated biphenyls . . . may be an en vironmental contaminant," and advised to use its best efforts to prevent them from entering the environment, Tr. 1171 (Dr. E. L. Simons). Nevertheless, the Department does not explicitly contend that it was misled. Department personnel appear to have been well aware by August 1973 of GE's KTB discharges, having already con ducted studies of their effects. See GE Exhibit 11. The Department acted quickly on G E's application. On Sep tember 11, 1973. the Department's Acting Assistant Director. Bureau of Industrial Wastes, wrote to an official in the Regional Office of EPA staling that the Department had reviewed GE's per mit application, and that "certification will be recommended since the present discharge complies with water quality standards." The letter goes on to specify areas tn which the application should be tightened, but does not mention PCB's or "chlorinated hydrocar bons." GE Exhibit 2. On November 13. 1973, the Department cer tified that no federal effluent limtations or standards under 301(6), 302, 306 and 307 of the FWPCA were applicable to G E's proposed discharges. It stated, however, that "the classification and r^5JUr\U toing^lhp-.qua)ityrfmdupunly-c f-wateFS^-Nevv;sf b f ir StateTMare applicable, and set forth certain specific and some general limitation to assure compliance. Among the specifics, for example, was a limit of 75 lbs. per day of Kjeldahl nitrogen, nothing was said specifically concerning PCB's. A general qualification, however, is clearly pertinent. The certification limited effluent of "toxic wastes" or "deleterious substances" in the following manner: "None alone or in combination wuh other substances or wastes in sufficient amounts or at such temperatures as to prevent fish survival or im pair the waters for agricultural purposes or any other best usage as determined for the specific waters which are assigned to this class." The certification then went on to limit discharges "at all times so as to be in full compliance with all applicable requirements of sections 701, 702 and 704 of title 6." NYCRR. the regulations establishing the classification and standards governing New York waters. Dep t Exhibit 2. The EPA regional office issued a draft NPDE5 permit to G E on March 22, 1974*, and invited comment. The draft proposed authorizing a daily average discharge of "chlorinated hydrocar bons" from the Hudjpn Falls plant (Discharge 002) of 10 pounds, and from the Fort Edward Plant (Discharge 004) of 20 pounds. It also proposed that chlorinated hydrocarbon discharge be reduced to zero within 21 months of the permit's issuance. GE Exhibit 3. pp. 4-7. The Department filed its comments on April 5, 1974, and as G E asserts did not mention the "chlorinated hydrocarbon" dis charges. On the other hand, the Department specifically requested inclusion of the general condition it had placed in its certification re quiring compliance with water quality standards. GE Ex'"1*1* * ~ 3. 119 4-76 ADM INISTRATIVE PROCEED!? 6 E L R 50013 EPA issued an NPDES permit to GE on December 20. 1974. intended to allow states to include their other prohibitions in the Though it contained no provision specifically requiring compliance general, undefined way that New York did so in this case. The with state water quality standards, it did comply in substance (as Senate Report explains: did the temporary permit) with the requirement that conditions of state certification must appear in the federal permit. FWPCA. 401 (d). 33 U.S.C. 1341 (d). In paragraph 6. it warns that its is suance does not "authorize. . . any infringement of Federal. State or local laws or regulations... " And before detailing the applicable limitations in paragraph 9, it recites: " Nothing in this permit shall be deemed to preclude the institution of any legal action nor relieve the permittee from any responsibilities, liabilities or penalties to The provision (401) makes clear that any water quality re quirements established under State law. more stringent than those established under this Act. also shall through certifica tion become conditions on any Federal license or permit. The purpose of the certification mechanism provided in this law is to assure that Federal licensing or permuting agencies cannot override State water quality requirements. .. * which the permittee is or may be subject . . . under any other Federal or state law or regulations." The permit authorized "chlori Senate Rep. No. 92-414. 92d Cong., 1st Sess. 69 (1971). This provi sion. moreover, was only part of an overall philosophy favoring a nated hydrocarbon" discharges of 10 and 20 lbs. from outfall num bers 002 and 004 respectively At the same time it ordered that dis local option to go beyond the federal program's limitations, as 510. 33 Li S C. 1370, makes abundantly clear: charges from the same points of "Polychlorinated Biphenyls" be limiied to 4 54 and 95.3 grams per day (or 3.52 oz.) by May 31, 1977. G E has appealed this limitation, though it represented at the hearing in (his case that it intends to withdraw ns appeal and will meet this standard by December 31, 1976. G E claims that it has complied wiih its state certification and federal permit. Consequently, it asserts, it cannot be found to have violated any statute for its discharges until the permit is duly modified in accordance with the applicable regulations. " If the SPDES permit program is to be meaningful and effective,. . . it can not. by its very nature as a permit system, allow the imposition of penalties for permitted discharges. It is axiomatic that penalties may not be imposed by a governmental agency for acts permuted by law." GE Brief, p 21 G E notes that the Department was fully Except as expressly provided in this chapter, nothing in this chapter shall (1) preclude or deny ihe right of any stale . . . to adopt or enforce (a) any standard or limitation respecting discharges or pollutants, or (b) any requirement respecting control or abatement of pollution: except that if an effluent limitation, or other limitation . . . or standard of perfor mance is in effect under this chapter, such Slate. . . may not adopt or enforce any effluent limitation, or other limitation . . . which is less stringent than the effluent limitation or other limitation . . . under this chapter: or (2) be construed as impairing or in any manner affecting any right or jurisdic tion of the Stales with respect to the waters (including boun dary waters) of such States. aware of GE's PCB discharges, and thus suggests that it implicitly The only New York case on this question clearly supports the found them lawful view that a permit may be conditioned in the manner that GE's is GE's argument has more than superficial appeal The effluent conditioned, and that these conditions become part of the permit limitation system is intended and well designed to serve as a sup tee's obligations despite the permit's other terms In B w a n e v. Cuv plement to the water classification system. Both the state and o f Lackawanna. 80 Misc.2d 816. 365 N.YS.2d 107 (Sup. Cl. 1974). federal governments are presented, when a discharge application is att'd iurhotu opnuon.___N.Y S.2d____ (4th Dep t I9' 5i. the com filed, with an opportunity to regulate so as to insure that water missioner of Environmental Conservation sought an injunction and quality objectives are attained. Thus, when GE filed its application penalties for defendant's discharging sanitary sewage into a water the Department should have been made aware that GE proposed way without giving it "effective secondary treatment" as required to continue discharging PCB's at an average rate of 30 lbs. daily. A by ECL 17-0509. The defendant City moved to dismiss the com relatively simple calculation at that point would have indicated that plaint. asserting that it had. and was complying with, an NPDES such a discharge rate was destined to cause the present situation. permit (which, of course, was issued only after state certification). Had this anticipated result been unacceptable, the Department The permit, however, contained the following language, identical in could then have denied or conditioned its certification. From the all material respects to paragraph 9 of GE's NPDES permit. viewpoint of the regulated, as well as of the public, a system that mandated such inquiry--and. incidentally, provided the resources to fulfill the mandate --would make much more sense than one r- w-_-rtiar4feaves -33mmtstratcrrt^wiih*dFScreWiv^o-'VppiOv^-^rtc-h^T^tS^? certain to undermine legislative objectives. The first answer to G E 's contention, however, is that neither Nothing in this permit shall be construed to preclude the in stitution of any legal action nor relieve the permittee from ~5rr,4ni ressonsij?iljt(es. o r e ru.hi .e^tabJ15 yr s .u - ,, "aril to any"applicable"State law'or regulation under authority preserved by Section 510 of the Act. the federal nor the state government has established such a system. The court rejected the City's argument. "The requirements of Administrators are accorded power to include in the very certifica obtaining a (NPDES-SPDES) permit (Environmental Conserva tions they issue conditions that might in effect preclude the ac tion Law Sections 17-0701 and 17-0803)." said the court, " and the ' tivities apparently permitted. This is not because the legislature in prohibition against discharging sewage which has not been given tended to allow administrators to avoid making difficult decisions, effective secondary treatment (Environmental Conservation Law / though that may sometimes be a consequence. Flexibility is Section 17-0509) are separate and distinct." Indeed, even had the * preserved because of the numerous ways in which administrators permit contained no language generally incorporating other state may be unable, despite the best intentions, to regulate effectively prohibitions, the court suggests it would have reached the same through the effluent limitations system. Inadequate information, result: "regardless of whether it has a permit it cannot discharge expertise, personnel or knowledge about the particular discharge, sewage which had not been given 'effective secondary treatment,' " are only some of the reasons a permit might be issued authorizing The same reasoning applies to G E's obligations under ECL 17- activity that would contravene some other part of the state or 050U 17-05U and federal government's regulatory scheme. The system seems clearly to place on the wouid-be discharger, whose influence with the agen cy might itself cause or contribute to regulatory insufficiency, the burden of insuring that the discharge violates no other federal, state or local prohibitions It would defeat the legislature's objectives to impose the costs of such failures on the public rather than upon the J^Klischarging party. The FWPCA informs us explicitly of another reason why GE cannot treat its NPDES or SPDES as part of a grant of immunity from other proscriptions. The act places great pressure on the states C. The Toxicity o j P i.B s A question fundamental to GE's liability under all the viola tions charged is. whether PCB's are "toxic" or "deleterious" sub stances. The lawidoes not permit this question to be asked m the abstract. The fact, for example, that humans have been severely harmed by certain quantities of particular PCB's proves u is toxic in the ordinary sense of the word, but not necessarily toxic m the sense used by the legislature. A person violates the law only by dis charging PCB's in quantities sufficient to cause the proscribed to adopt an effluent limitation system, but at the same time it guaranteed that the states would be free to impose additional limita tions, including those implicit in a water classification approach. Section 401 of the federal act requires that a state's conditions to its 22. In light of (his conclusion, there n no need to consider whether G E violated iu NPDES permti by exceeding its limits for PCB discharges, t discharging PCB's from outlets other than those specified in ihe permit, or manner See Dep'l Reply Brief, pp 5. 9 If such violations to own permit become a part of the federal permit because Congress mighi in ihemseivQ constitute a violation of E C L I'-O ill 120 * c 6 ELR 300U e n v ir o n m e n t a l la w r ep o r t l 4.76 effects --in ihis case, injury to fish or an adverse effect upon the protected usage of fishing. The potential toxicity of substances is ascertained in terms of standards accepted in both the scientific and legal worlds. The legislature provides the following definition, which is essentially in distinguishable from the FDA standard, and from the standard propounded by GE's witness. Dr. Golberg: " [TJoxic pollutant'' means those pollutants, or combination of pollutants, including disease-causing agents, which after discharge and upon exposure, ingestion, inhalation or assimilation into any organism, either directly from the en vironment or indirectly through food chains, will, on the basis of information available to the Department, cause death, disease, behavioral abnormalities, cancer, genetic mutations, physical malfunctions, including malfunctions in reproduction, or physical deformations, in such organisms or iheir offspring.11 If consumed in sufficient quantities by fish, animals or men, there is no doubt that PCB's can have the efTects described in the EC L as "toxic." Accord. G E Reply Brief 16. Just as PCB's have qualities that make them useful in industry, they have qualities that make them hazardous in the environment. That they are non* biodegradable, for example, may be useful in capacitors, but it also makes them persistent. They are virtually indissolvable in water, and their effects in the Hudson are fell long after their discharge into the river. PCB's also bioaccumulate. They are highly soluble in lipids ffats and oils), and therefore are in effect attracted to organisms relatively high in lipid content. They tend to remain sus pended in water, attached to plankton and other organisms, or they fall into the river sediment. In either case, they pass into snails and other aquatic organisms, including fish, and become stored in their bodies, particularly in areas with high lipid content. The signifi cance of bioaccumulation s that the PCB's are accumulated in fish and other high lipid organisms to points far higher than the PCB concentrations to which the organisms are exposed. Experimental results introduced at the hearing showed, for example, that Fathead Minnows accumulate A-1254 to a point 200.000 times greater than the concentrations in which they are placed Dep't Exhibit 36, pp. 8-9. Dr Veuh estimated that the bioaccumulation factor for A-1016 and 1242 m small fish would be about 50,000. This means that, in water containing 1 ppb PCB 1016/1242. such a fish could be ex pected to accumulate PCB 1016/1242 to a level of about 50 ppm. Ac cumulation can also occur from PCB's m sediment. Dr. Veuh showed that Fathead Minnows placed in a tank with PCB-free waier, but with Hudson River sediment containing 166 ppm A-1016. accumulated aconcentration of 109 ppm after 6days. Dep t Exhibit 14. pp. 18-19. Aquatic organisms accumulate PCB's from sediments in direct proportion to the PCB concentrations. Dep't Exhibit 26(1). p 9 (Hansen). Bioaccumulation occurs rapidly in fish, and then levels off. The evidence shows that when fish are exposed to a constant con centration of PCB's. they accumulate the chemical for about 20 to 30 days, and then concentration reaches a "steady state." The steady-state concentration is directly proportional to the water con centration: if the concentration is increased, accumulation resumes. See Tr. 599. The evidence indicates that the lesser chlorinated PCB homologs bioconccntrate to a lower degree than the higher chlori nated homolo^. This would mean, for example, that A-1254 would accumulate to a higher point than A-1016. making the former more toxic in general. The difference in steady-state levels among the Aroclors. however, is insignificant relative to the high levels of ac cumulation in them all. Dep't Exhibit 14, p. 16. Also, lower chlori nated homologs tend to accumulate faster than higher ones, be cause of their relatively greater solubility. Here again, however, the differences are relatively insignificant (they all accumulate quickly) and would matter only in special circumstances.* 23 17-OtOit 19) "PolluLim" is defined to include any "chemical" or "industrial' waste. E C L 17-010SC1' > Dr Kotbye testified ihai he could perceive no difference between ihe E C L definition and that applied to the FD A Tr. 1030. Dr. Golberg said (Tr 17611V We generally consider the loxicity to be a manifestation of the injurious efTeci of a chemical or physical agent on a living organism as manifested in variety of possible ways, such as structurally, functionally or tn retard ro ihe response of (he organs, for instance, behavior Fish also accumulate PCB's through the food chain, by means of biomagnificauon. At each level of the food chain, organisms ab sorb the collected accumulations of PCB's in the lower-level organ isms, Fish are relatively high on the chain. Humans are higher. Consequently, PCB levels in fish predicted on the basis of con centration in waier alone will [end to understate the actual level of PCB's because of accumulation from sediment and by biomag nification from the food chain. Little wonder that fish were described by ihe Chief of the Department's Bureau of Environ mental Protection as a "sink" for PCB's. Tr. 579 (J. Spagnoli). Due to these characteristics, PCB's have been observed to cause toxic effects in fish food, a variety of estuarine organisms, fresh water fish, birds, rats, mink, monkeys and humans. In one series of tests, for example, population growth of aciliate protozoan was reduced significantly by exposure to 1 ppb A-1254, growth in oysters was significantly reduced after 25 weeks of exposure to 5 ppb; various estuarine shrimp were killed by exposure to 0.9, 1.4 and 4.0 ppb; a dose of 1.0 ppb was lethal after two weeks to Longnose Killifish and 5.0 ppb was lethal to Pinfish and Spot Re searchers observed structural changes in tissues of the oysters, fish and shrimp exposed to A-1254, including abnormal invasion of Leukocytes (white blood cells), atrophy, abnormal cel) distribution, and the formation of crystalloids in the nuclei of shrimp digestive glands.1* PCB's were found in other experiments to be lethal in low concentrations to the water flea, scud and midge, all important fish foods, as well as to the Fathead Minnow and Flagfish; fish fry and eggs were found particularly susceptible." Time of exposure is an especially important factor in ascertain ing the effects of PCB's. The LC-50 value for A-1242 (the con centration that will kill 50 percent of the test organisms) was calcul ated to be 15 ppb for newly hatched minnows in a 96-hour test, bui after eight months all the fish were killed at this level. Dep't Exhibit 37(2). p. 566. Rainbow trout showed adecline in LC-50 values from 156 ppb A-1254 at 5 days, to 8 ppb at 10 days. Dep't Exhibit 19(S>. ^ p. 162, table 4 In an acute (short-term) test. A-1254 was shown to \ be one-tenth as toxic as DDT to shrimp, in that 100 ppb Aroclor 1 1254 was necessary to achieve the same lethal effect (100 percent) as 10 ppb DDT. But in a chronic (longer-term), flowing water test, only 0.94 ppb A-1254 was necessary to kill 51 percent of all juvenile / shrimp within 15 days, and 3.5 ppb A-1254 killed 50 percent adult shrimp m the same period. Dep't Exhibit 24(5). A-1254 registered ' an LC-50 on Rainbow Trout of 156 ppb in 5days; in just five more / days, the LC-50 was 8 ppb." Stress is another important variable The toxic effects of PCB's seem consistently greater when the con- ; laminated organism is under some form of stress, such as a change , in water temperature or in the process of reproducing." 1 Studies of the effects of PCB's on rats indicate that, at various levels, they affect reproduction, cause enlargement of the liver, in terfere with normal metabolism, create growths, some malignant, and can be lethal." Mink are especially sensitive animals, and ex- 24, D R. Nirnmo 1t at.. "Toxicity of Aroclor 1254 and us Physiological Activity , in Several Estuarine Organisms." 3 Archives of Env Contamination and Tox- / urology ` 22 (1975), Depl Exhibit 24(2) The authors speculate that the j crystalloid inclusions were possibly produced by a mrustbecause of PCB stress, t and refer to another study indicating that "PCB enhanced ihe pathogenic i effects of hepatitis virus in ducks." Id. 39. see M Friend A D O Trainer. < Polychlorinated b'phtnxt- Interaction m h duck hepatitis iron, 17 Science 1314 ' ' (1970) A table of the effects of PCB's on various salt water organisms, as reflected in the literature, prepared by Dr. David J. Hansen, is m Dep't Exhibit 26(1). 25. A V Nebeker A F A Pufles. Effect of Polychlonnated 8>phen\ls tPCS*to* Survival and Reproduction of Daphmo Cammarut. and Tanytarsus, 103 Transac tions of ihe Am. Fisheria Soc. 722 (1974): A. V Nebeker et at. Effect o f Polychlorinated Riphcnvl Campounds on Survival and Reproduction of the Fathead .Vfinno and flatfish, |Q3 Transactions of the Am Fisheries Soc 562 <I914l Dep l Exhibit 37.. \ 26. D L Stalling JP F L Mayer. J r . Toxtctnes of PCSi to fnh an,i Environmental Residues, Environmental Health Perspectives, p 162(\pr 19721. Dep't Exhibit 37(8). The authors found bioconcentrauon factors in fish of over 40.000 times exposure levels, and said that adverse effects on reproduction may occur at 5 ppb or less id 163. 27, Dep't Exhibit 377(2). p. 567 (flagfish exposed 40 days io PCB's died when water lemperature dropped 4*C ). Dep't Exhibit 37(9). p 13 (low dietary con centrations of PCB's afreet thyroid activity); Dep l Exhibit 23. p 5 and Exhibit 26(141. p 428 (shnmp exposed to sub-lethal quanniies of PCS'i died when water salinity gradually decreased over 9 hour penod). Dep't Exhibit^, p. 19* (iuvemle shrimp exoosed to PCB'S died after molting). 28 Dr Renale Kimbrough, who has conducted or participated in m irK o> 4-76 ADM INISTRATIVE PROCEED' "S 6 E L R KO 15 perimenu demonstrate that a diet of a 30 ppm proportional mix ture of A-l 241, 1248 and 1254 is lethal, and levels of 3.57 ppm and 0.164 ppm A-i 254 fed in the meat of cows placed on PCB diets were determined respectively to be lethal and embrvoioxic at the 100 percent level.11 The most dramatic--and tragic--known evidence of PCB tox icity is the so-called Yusho ("oil disease") incident. In 1968. an epidemic of a skin disease was reported in parts of Japan. Investiga tion proved it related to the consumption of cooking oil contami nated with Kanechlor 400 (equivalent to Aroclor 1248). A total of 1.291 reporied cases have been counted as of April 1975. The affected individuals consumed an average of 2 grams of the PCB, with the minimum dose estimated as 0.5 grams. The victims had a variety of symptoms, especially acne-like eruptions, pigmentation of skin, increased eye discharge, swelling of upper eyelids and weakness. Nine of ten babies delivered by pregnant victims had unusually grayish, dark-brown stained skin; most had increased eye discharge and less-than-average weight, indicating placental transport. Many of the symptoms have continued to the present in many victims, indicating the persistence of PCB's in the human body. A report of 22 deaths of victims as of September 13, 1973 in dicates that 9 "were caused by malignant neoplasms, suggesting a possible excess of deaths from cancer," though more information is needed to test that hypothesis.1* The Yusho incident triggered further investigations of PCB's. including some involving Rhesus monkeys. An initial study, in which monkeys were fed 300 ppm A-l 248, led within three to four weeks to their exhibiting symptoms similar to those of Yusho vic tims- severe acne, swelling of eyelids and loss of hair. Many devel oped ulcers, and all died within three months. The same results oc curred when monkeys were fed 100 ppm A further study tested the effects of a diet of 25 ppm. and wuhm one month the primates exhibited the symptoms of PCB intoxication. After two months they were removed from the diet to avoid unnecessary death, one of six died of PCB poisoning two months later, and the infants of those who survived were less-than-average in weight and h3d detec table levels of PCB's in their tissue at birth, which increased follow ing nursing on their mothers' contaminated milk. Two years later, the animals continued to exhibit some of their original symptoms, and had detectable levels of PCB's in their tissues. A third study was initiated, involving a much lower dosage--5.0 and 2.5 ppm existing research on this subiect. testified ai the hearing 4 dose of 20 ppm V I 25J enlarged the livers of rats. affecting the cytoplasm of liver celts and in ducing dangerous metabolic activity Deo : Exhibit *5. pp 3-4 An ejrlv siudv showed a urnor m :he bladder of one rat. cjusmg an intensive folio*.up in * hich 200 Sherman Strain rats were fed 100 ppm A-I26Q for almost 21 months Oi IS-* experimental rats |*fi had abnormal or autonomous growths on iheir livers. 2h *ere bepai-xeUuJar carcinomas imalignani lesion) Vine jf :hc I".' .vntrol rj;s had such growths Dr Kimbrough concluded thai ihe PCB had elicited a spectrum of response similar io established carcinogens R D Kimbrousn * at " Induction of Liver Tumors in Sherman Siram female Ratt b> PcUv chlorinated Biphenyl Aroclor 1260." in Dep't Exhibn 45(8) (un published paper, discussed m Aleefng Rerort. Report n/ a WoAj/irv on C/asutu jr.im v t Srr.::tt Hcpotoititular Lcnom m Rats. 35 Cancer Research 32U >\'ov ]9' j) 2^ Dr Robert K Ringer. who conducted and participated in most existing re search done regarding PCB's and mink. testified that Ihe experiments yielded similar symptoms impaired reproduction, internal bleeding, loss of appetite. Jegenerjuon of ihe liver and others See R T Aulench. R K Ringer A S Iwamoto Reproduction Failure and Mortality <n Mini. Fed on G'eat L a id Fnh 14 J Reprod Fert Suppl 365 M9"}). a study caused by Ihe threat ihai coho salmon diets posed for the mink r*n.hing industry. The study relating to cow meal is N S Platonow A L. H Karstad. Dietary Effects >/ PoluhlormateJ R ptiini/t Mmk. 3* Can J Camp Med 391 I I973i, Dcp t Exhibit 1 30 M Kuratsune ft a t, Epidemiologic study on Yusho. a Poisoning Caused bv In* teMton of Rice Oil Contaminated <//) a Commercial Stand of Polychlorinated B.phenyls Environmental Health Perspectives 119 (Apr. 1972). Dep't Exhibit 42(5); M Kuratsune rr of. "Some of the Recent Finding Concerning Yusho." paper presented ai Natl Conf on PCB's. Chicago, III. Nov 19-21. 1975 I C E Exhibit J I ) The investigators also resorted on a chick edema disease in western Japan, caused by ihe same nee oil, in which over 400.000 chickens were reportedly a.lied Their livers were yellowish and mottled C E presented testimony concerning the recent discovery that the Kanechlor involved in the Yusho incident contained polychlorinated dtbenzofurani fPC D F'sl. a highly toxic chemical Tr |77jO r Golberg) This information is discussed by Dr Kuratsune, et at m their (9*5 paper above. They find the evi dence interesting and worth following up. but provide no support fo r G E 's use of the d m io undermine the fact ihat PCB's were the principal causitive agent m Yusho They note, for eiample. that evidence of the expected effects of PCD F*i on the liven of deceased victims is licking, and they also speculate that the P C D P i. if indeed present, may have been produced from the PCB'! them vdyest *hen used as a heat transfer agent or m cooking. G E Exhibit Jt. A-l 248 io two sets of animals. Within two monihs, alter consuming from 35 to 50 mg PCB, some of the female monkeys began to ex hibit the typical symptoms of PCB intoxication; at six months all the females were so raffected. Their menstrual cycles were "decidedly altered" after consuming 60 to 120 mg PCB. and their reproductive capabilities were drastically lessened: only 5 of 8 on the 2.5 ppm diet and I of 8 on the 5 ppm diet had normal binhs. whereas 12 of 12 control animals had normal births. The infants were smaller than average, and contained PCB's; they accumulated more PCB's from their mothers' milk and, within four months. 3 of the 6 died of PCB poisoning. One female adult on each diet also died, and the tissue and organs of both were substantially altered, including widespread necrosis in the liver. Males also exhibited symptoms, but less severe ones, perhaps because their greater bodyweight provided more fatly tissue to store PCB's.1* GE contends that, whatever the toxicity of PCB's in general, A-1016 is far less toxic than the mixtures used in most experiments of PCB effects. A-l016 is said to be less toxic, not because it con tains a lower percentage of chlorine than other PCB's, but because it contains a relatively low proportion of PCB homologs with 4 or more chlorine atoms. For example, A-1016 contains only 1percent homologs with 5 or more chlorines whereas A-I242 contains 9 per cent of such homologs. A-1248 contains 40 percent and A-l 254 con tains 77 percent. Dep't Exhibit 39. p. 7; GE Exhibit 13. The evi dence in general establishes that the higher homologs are less biodegradable, that they bioaccumulate to higher levels, and in par ticular that a PCB isomer with 4 chlorines (2. 5. 2'. 5' tetrachlorobiphenyl) may be metabolized into highly toxic hydroxylaied PCB's. Tr. 1782-1783 (Dr. Golberg). Dr. Kimbrough also testified that, whereas homologs with 5or more chlorines were carcinogenetic to rat livers, it was not yet known whether those with four or less chlorines caused such tumors. See Dep't Exhibits 45(6) and 46(8). p. 14. The evidence shows, however, that the relative toxicity of PCB mixtures varies depending upon the organisms affected. The lower homolo^ are more soluble than higher ones, and are therefore more available to. and more rapidly absorbed by. fish swimming :n the water. Dep't Exhibit 15(9); Tr. 936-37. Furthermore. A-1016 has been observed to cause effects similar to those caused by other mixtures in many contexts. After a series of experiments designed specifically to test the toxicity of A-1016. because of its increased use. Dr. D. J. Hansen and his coauthors concluded that "Aroclor 1016 is similar to other PCB's in its toxicity to. and uptake and re-, tention by estuarine animals." In a chronic exposure <2 days), for example. Pinfish accumulated 5 I ppm A-1016 in edible flesh and 11 0 ppm in their whole bodies Most of those that died exhibited symptoms of poisoning, including changed appearance and behavior. "Acute toxicmes of Aroclor 1016 to oysters, brownshrimp. and pinfish," the researchers concluded, "were similar to that of Aroclor 12J2 and Aroclor 1254 "n The Department introduced, through Dr Alan V. Nebeker. data showing the effects on the water flea of PCB homoloes with 3. 4 and 5chlorines, tested separately. He found "noi much difference in toxicity between trichlorobiphenyl and tetrachlorobiphenyl 31 Dr J R Allen. who conducted or participated in these experiments, testified at ihe hearing that Ihe levels chosen for ihe most recent expenmem were designed io iesi those set by the FD A as tolerable limits for certain foods Dep t Exhibit 41 He cunciuded l/J fr-7> Our studies have demonstraied a striking similarity between the signs and lesions produced by PCB's in man and m nonhuman primates .As is the case with man. we have found that the PCB's are extremely toxic to nonhuman primates over i wide range of dosages Even at levels ac cepted m certain foods detuned for Human consumption. PCB's are capable of producing obvious skin changes within two monins. and reproductive abnormalities wiihm four 10 sn monihs In addition, it has been shown that PCB's transfer through the placenta and are deposited m ihe feiia. Infants born to exposed mothers arc smaller than average jnd show increasing tissue levels of PCB's following birth due io the con sumption of mothers' milk that contains relatively high levels of the compounds Sufficient PCB's were consumed vn their mothers muk to cause morbidity and mortality in infants. 32 D J Hansen. P R Parrish A J Forester. Aroclor Iftli iaticity to ana Lp` take by Estuarine Animals. " Env Research J63 1197*1 Dep't Exhibit 26tSl The authors refer to comparative studies of the other Aroclors A subsequent siudv showied thu A-1016 was muen less toxic to Sheepshead Mmnos ihan A-I2J-*. but the former * as nevertheless lethal to adults at 32 ppb Dep't Exhibit ibt 211 Furthermore, an experiment conducted it the National Water Qu*' Laboratory m Duluth, Minnesota, shows a strong similarity m <he lethal ef of A-1016 and A-l242 on Faihead Minnows Fry Dep't Exhibit J^bl .1 6 E L R 3001o ENVIRONMENTAL Law REPORTE' 76 homologs which suggests that mixtures such as Aroclor 1016 and Aroclor 1242 would be similar in toxicity." Dep t Exhibit 36. p 6 Further tests of the relative toxicity of A -1242 and A -1016 on Rain bow Trout and Bluegills made it "apparent" that their toxicity is " similar "15 Other reliable and unchallenged data show that the tox icity of PCB's to some species (including Catfish and Bluegills) can vary inversely with the percent of chlorines or high homologs u Finally, the evidence that tetrachlorobiphcnyl may be metabolized into an hydroxylated derivative is inconclusive. A -1016 contains 21 percent tetrachlorobiphenyl. much of which has the isomers that are suspected of being particularly toxic A* Even if A -1016 is less toxic to some fish than other Aroclors. that fact fails to help G E in this case The sediment, water and fish of the Hudson downstream of G E 's plants are contaminated with substantial quantities of A -1242 and 1254. which have a continuing effect on living organisms in the river Dep't Exhibit 5. p 1920 (sediment heavily contaminated) The evidence shows that G E has in prior years purchased and used large quantities of higher chlori nated AroclorsJ* Dr Simons testified that he began planning PCB abatement steps in 1972. There is every reason to believe, therefore, that G E discharged higher chlorinated PCB wastes into the Hudson throughout the time the company was using those products. Assuming that substantial quantities of the higher chlorinated PCB's were discharged by persons or companies other than G E (of which there is no proof). G E 's discharges of A -1016 are added to the PCB's already present and therefore have a greater toxic effect than they other*-sc would have For the same reason, it mailers not at all that some of the PCB's were discharged more than three years before the complaint in this case, when G E claims the statute of limitations began to run." or before March 24. 1974. when the 33 IJ D e n i t h i C i - ? r i 5> C o m p arative loxictiv of Arcvtor 17*2 and 1016. based on data from the F ish -P e siiv d e Lab Colum bia. M o . in .onimuous-flow exposures Tex: Organism \2 i 2 1ug/l 1 $6 nr LC50 LC 50 \Hues salues after- 10161ugM 96 hr LC 50 LC 50 values v after- Rambo Troui 81uc gi 11 6 ' 10 da>s 39 100 isac fry 1 17 days - *9 109 **0 '2 5 23 days - I I 125 15 dass - 5* *6 1 8 < 35 davs - *3 15* *20 '0 9 gi 22 days 1* J In ic r m .lic n i rto bioasvax oi A-I2*2 12*'i j n J 2 { * -ixiiiiled m 1'da> L C -59 va.uc* .0 9 :-e g ''! of 5* ' 6 and 20* p ro rtfne*tivetv. and m Channel C j i f - n u i 10' 1 2 ' j n J '*1 n rb fevrecnvei D L S:.i:lng i F L Maser )r r \ \ PCS > F<t* a r j E m .ranm em j: R ?s JuCi -n Env Health Perspec t iv e s n r >5* 'f*2 x r r l ' 2 ' . Den i Eh m i The - . m e inverse correia- t u r n 4 ' o b s e r v e d O' Dr Fin g e r m co n n evt.o r *>th single Joses given io mink See D er ' E x h ib it *3 p * . T r I 0 79 35 Dr C *'th .'rc te :'le d tor CC that ie `.'j h io ro 6 ip h e n v l isom ers * iih hliirm e jin r r s in the * position had special properties apparently meaning hex were p oten iu llx more toxic than oihers Tr 1805-06 Dr Stalling testified that lour of si of the mosi abundant isom ers m P C B s contain chlorines in the J position An jn u le vO-authored bx Dr Golberg notes that "low er Chlorinated biphenyl are of special m ieresi because their biological degradability might le id to m etabolites o f increased lo x ic m w G re b a at In Suro Metabolism o f P 1 1 neffi/ 8 `r h*n>/J 13 Bull of E nv C o n u m in ju o n k Toxicologv *2* <W < >. Den i E x h ib it 61 See also Dep t E xh ib its oO k 62 Dr A llen identified 2. 5 2 5 le irjk h io ro h ip h e n v i as capanie of altering D N A and R N A . and n e re fore as linked w ith m utagenic, carcinogenic and necrogemc effects D ept E x hibit *1. p 6. T r 10*7 36 D e p t E x h ib n 6 reflects G E 's purchases from M onsanto since 19*6 Lbs m thousands ________________A r o c lo r ________________ Y e ars______________ TO TA L 1016 1242 1221 1254 1975 (Ja n -S e p ii 74 73 72 71 70 69 68 67 66 *162 8' 29 9653 7901 5561 9682 8323 9939 9*96 8767 *1*6 16 sow 30 923* 38* 35 *881 20 132* *223 14 9589 93 8219 104 9839 100 9395 101 8667 to o 37 N R D C argues ihat ihe applicable statute of lim itations is C P L R 213(5). hich allows ihe stale to sue for m isappropriation of public property either ' thin i n years from ihe lim e the cause ol action accrues or w iih m two y e jrs of definition of Class D waters was amended to include fishing as a best usage The higher PCB's continue to have an effect-continue to contaminate and pollute-and the toxicity of the more -cent discharges must be judged along with the PCB's already present, es pecially since G E is responsible for their presence Counting m the effects of all existing PCB mixtures in judging GE's liability is espe cially necessary, since the record indicates that mixtures of A-1016 and higher chlorinated Aroclors are more toxic than the comomed measures of their individual toxicmes See Dep t Exhibit 43. p 5. Dep t Exhibit 37(|). pp 723-24. 726 Finally, it is entirely possible that A -1254 has been discharged by G E in the very recent pa*i. be cause of accumulations in pipes, some of which have been moved in G E 's abatement efforts See Tr 1279 D . Violations o f E C L /"-O.'OI an d I '-0 < l I G E has violated ECL 17-0501 and 17-0511. as charged, by causing or contributing to a condition in comrjvennon of the *aier quality standards adopted pursuant to ECL 17-0301 Two separate standards have been violated G E has discharged wastes in>jrious to fish, and the company's conduct has caused and contributed to the impairment of a protected usage of the waters --fishing. /. In ju ry to fish G E argues that the toxic wastes discharged have not been shown to injure fish in that the evidence relied upon is largely based on laboratory tests concerning organisms other than species of fish found in the Hudson, no fish have been shown to have been directly affected, and G E in any event has brought its discharges to the point where no violation is continuing, making inappropriate the imposition of any penalty, including an injunction. The argument against laboratory testing is inconsistent wuh the best scientific practice Dr. Donald 1. Mount. Director of the En vironmental Protection Agency's National Water Quality Laborato ry in Duluth. Minnesota, commented generally th3t the results of laboratory toxicitv work wuh fish or other organisms correlated within a factor of two to conditions actually found m the field Tr. 964-66 Dr Lauer testified for G E that the most accurate way of determining toxicity to fish was through controlled experiments, rather than by examining individual Hudson River fish Tr 1635. Dr Golberg's observation that care must be exercised in tests be cause fish foods often contain contaminants is a well taken gener ality. but the evidence clearly shows that the scientists who testified, and whose findings were introduced, exercised adequate care in this regard G E has voiced no challenge against any laboratory test in evidence on this or any other s u b s ta n tiv e ground Reliance by the Depariment on evidence concerning organ isms and animals other than species of Hudson River fish is also proper See. e g S y n th e tic O rg a n u C h en i M a n u fa c tu re rs 4 s s n \ B ren n a n 503 F 2d il55. 1160-61 (3d Cir ]9" 4i (upholding use of tests show mg carcinogenic effects of ethy leneimme in rats and mice to show potential effects on men). E n u m n m cn tu l D e fe n se F u n d . E P .4 . 489 F 2d 1247. 1253-54. [4 ELR 200311 ( D C Cir 1973) (reliance on general data, laboratory experiments on animals, etc. sufficient basis to prohibit uses of DDT concerning which no spe cific evidence was presented) Manv experiments involved fish, some that are found in the Hudson Others involved creatures Simi lar to those found in the Hudson and others used animals or o-gjnisms available in sufficient numbers and conventionally used to test for toxic effects The range of PCB effects *as such, testified Dr Mount, that tests involving a vanetv of organism* was appropriate, and values concerning salt water species, for example, would be predictive of effects in fresh waier species Tr 963-69 To the ex tent some creatures were especially sensitive, as mink are. or par ticularly resistent. as rats may be. the evidence of their reactions may be given lessor more weight but is admissible and probative See generally Judge Leventhal's instructive discussion upholding an extrapolation of tht effects of aldrin/dieldrm "from rrvee to men." E n v iro n m e n ta l D e fe n se F u n d v E P 4 . 510 F 2d 12^2. 1298-99. (5 ELR 202431 ( D C Cir 1975). The record contains ample evidence from which an inference may be drawn that G E has discharged PCB's in quantities injurious to fish The nature of this case makes it unnecessary that the Department prove that specific fish were directly affected or. as G E puts it. what "actually" took place not what "could" or "might" i 4 the State s discover* of the facts h ivh e ve r is later G E 's discharges duntvg ilv Iasi three ears violate E C L t '-*''0 1. so no need auses io deede ih o o u o u o n 123, 4-76 ADM INISTRATE E PROCEEOINGS eLR v ; have taken place. GE Brief 29 ECL 17-0301 sets a water quality God, only to GE. and He has provided heavy rams ji suffic e.ntlv r standard, and Is part of a plan adopted in part to avoid the rigidities of the law aimed at punishing for harm done to identifiable fish. See discussion supra. pp. 30011-12. The experimental results in evi dence show that fish, among other living things, have suffered toxic regular intervals to have made predictable those that drained PCB's from the land around G E's plants GF.'s abatement activities are commendable, but GE made them necessary and is responsible for consequences-that could be expected to occur. There is no reason, effects from PCB exposures equal to or lower than those to which moreover, to consider only GE's discharge rate after this suit was fish taken from the Hudson were subjected 11 brought. GE is responsible for all its discharges for at least the three In this regard, no weight need be given to tne FDA tolerance years preceding the complaint, ihe period covered by ihe statute of limit of 5 ppm for the edible portion of fish. That standard is limitations the company contends is applicable CPLR 2U O designed to protect consumers of fish, not the fish themselves. It The theory on which GE argues in effect that its unlawful con would appear, on the one hand, that PCB levels of 5 ppm in fish duct should go unremedied is that no injunction may be issued :o i may not be harmful to the fish themselves. Important variables require a level of discharge that has already been achieved This is would have to be weighed, including at what places in the fish the simply incorrect. The Department is not required to accept GE's PCB's are located, and how sensitive is the particular species On the other hand, when injury* to fish is the relevant inquiry, the edi representations --mainly unsupported and equivocal*0--as a substitute for an order requiring discharges at a lawful level ble portions are far less significant than other areas and organs, such as the liver. The record shows that concentrations in the non Furthermore, whtle G E's promised discharge rate of 100grams per day may be lawful if the use of PCB's is commercially necessary, edible portions of fish are consistently higher than in the edible por the Department is entitled to attempt to show that adequaie i tions. and* that the non-edible paris include vital organs. See Tr. 1625-29 An ample basis is therefore present in the record to sub substitutes are available. Nor is the Department precluded b> any equitable principle from attempting to require GE to take steps to stantiate the unrebutted testimony of Dr. David L. Stalling that, rectify its prior violations. However negligent the Department rruv "from what we know about the response to levels, certainly the have been in granting GE a permit to discharge those large concentrations in the fish exceeding the 100 micrograms per gram amounts, the permit and the ECL required GE to conform as [parts per million] would have a very marked decreased chance for effluent to stream classification standards. This proceeding is survival if mortality had not already occurred." Tr. 673. Applying designed to protect public resources, and cannot be made into a GE's proposed test for proof by circumstantial evidence (even forum for determining the relative fault ofGE and the Department though in this context the evidence is scientific rather than based on unvenfiable observation or speculation!. the circumstances are indeed such "as to lead fairly and reasonably to the conclusion sought to be established and to exclude any other hypothesis fairly and reasonably " Ruppen v. Brooklyn Heights R R. Co.. 154 NY. 90. 93 (1897). The hypothesis of non-injury has been fairly and reasonably excluded GE would have this charge dismissed on the ground that it is now complying with the law Its argument .$ both factually and legally unsound The Department and NR DC demonstrate in their briefs that, even at present discharge levels, some fish win bioconcentrate PCB's to a level in excess of 5 ppm from the water alone. GES compulations completely exclude, furthermore, the very sub stantial PCB contamination of sediment, which the evidence shows leads to fish contamination swiftly and to very high 'evels.1* GE also characterizes as "anomolous" some substantial discharges that have occurred since September I9'5 because of heavy rain or be cause of work associated wuh abatement efforts, such as moving contaminated pipes The ECL may allow- or even require the Department io disregard discharges caused by an "act of God'* or other uncontrollable factors in considering G E 's activities, but the relevant section does not exempt GE from us own negligence or wilfullness See ECL 7M935. The PCB's cannot be attributed to 2. im pairm ent o f best u sage--recreational fishing The ECL and its regulations are also violated by discharges that cause or contribute to an impairment of recreational fishing. A violation of water standards sufficient to injure fish would or dinarily seem to impair fishing. This is true here, since GE's dis charges are at least "contributing" to acondition in which fishing is impaired. The proscriptions do not entirely overlap, however, since fishing may be impaired even though fish have not been injured m the sense legally required. Recreational fishing is impaired when fish, though healthy enough to survive, are dangerous to use as food. GE argued at the hearing that recreational fishing does not require fish that are edi ble. Tr. 986-93. This may be true as a matter of abstract theory, but m reality recreational fishermen frequently consume the fish they catch, as the testimony shows. Tr 1875. 1880-81 IJ. Pickett). Tr 1885 (E. Nash) Fishing in the Hudson has in fact been greatly reduced since Commissioner Ogden Reid informed the public of PCB contamination. Tr. 1870-73, 1879. 1886. which demonstrates that the activity is undertaken by some only if the fish they hope to catch can safely be eaten The regulations themselves contemplate fish consumption by prohibiting the discharge of substances that adversely affect the "flavor, color and odor" of fish 6 NYCRR 701.5. The regulations were therefore intended to protect the fish 38 See ih? sources cued in footnotes 2-1-32. tup'a particularly the low -dosage ing activities of fish-eating anglers as well as those who cjtch'fish Rhouv (n.*"VL-y experiment Dr x*ebev.cr tesiil'ed that concentranons as low purely for sport. a* I 5 ppb PCB's kill or reurd ihe growtn jnd reproduction of Minnows. Flagfish .md mosquno larvae- Dep t Exhibit 36. p 9 Dr Nimmo and omen found v i ; 1! toxic to shrimp m me I ppb ranee Dep'i Exhibit 2*15). p 197 Waier concentration near ihe G E plants ranged from 1 3 to JO ppt) A-1016 between December I9"J jnd August 19*5 Dr Stalling referred in 19*2 10 ihe fact that Hudson River fish have been rendered inedible by G E 's RGB discharges. The Department properly relies in proving this fact fin part upon the FDA's temporary tolerance limit of 5 ppm for the edible portion of fish Dr Kolbye testified that the FDA denveduis residues of 50O-NY1 ppm were assocuied with fish mortality in chrome con present standard to a large extent from the Yusho incidental n tinuous How exposures Dep t Exhibit 19(5). p 163 Hudson River fish ere found with levels this high, and n is safe io assume thai even higher levels have been reached in fivh (hat were killed, and that some fish with tower concentra which the victims "received an exposure of approximately 'two; grams of PCB's. which is translated to 2.000 milligrams of PCB^" ; tions were injured 39 Dep'i Exhibit 15(28) contains the experiment run by Dr Venn on the effect of Hudson River sediments on fish in a lank with the sediment, as well as in a tank with just the water overflow from the first line. Cnncemranon of PCB's m Fathead Minnows After 6 Divs >n Lake Superior Water and Hudson River Sediments Sample Number of PCB's <ug/gmt Fish___________ as Aroclor 1016 6 Days in Tank Containing Hudson River Sediment* 8 109 6 Days in Tank Receiving Over flow from Sedimcm Tank 6 36 4 Conirol Fish ' Lake Superior W jicril b Not deieciable a Sediment *. jmimed lift ug/gm (dt> CieM .1 Aroclnr lOIr h Estimate. K'D's m tank B >- .r* wav 0 a? -..1 (as Arodcr 1016) 40 When G E received us \P O ES permit on December 31. 1974. the m in m u n r daily discharge of PCB's as >et at 100 grams to be achieved b Ma 31. 19*' G E filed wuh EP A a request for an adjudicatory hearing on this effluent imita tion--m effect staving ns applicability until the qua non was hiigaied G E F t- hibn 17 Since filing ihe requat. on the basis of "new experimental data. * G E contends that an abatement svstem can be designed ihat will keep the PCB daily discharge below the !00 gram level Tr 11J4 In addition G E contends 'hat. bui for the uncertainly presented by the PCB limn that ma be imrosed m this proceedag. '.hex are now prepared io withdraw iheif hearing -equest D- Modan, responsible for `coping she ireaimem usiem saiificd in n *j*fd*''* his engineering judgment, the bench scale studies of he wstem indicate that the ICO gram daily maximum is achievable Tr 1305 These studies and other mater.a! Jeve'oped in connec^on * t h this system have noi ei been seen the Hc-anny U 'fcer -if :nc one- panics. j-ihOun iheir production was pr ,-n- ived Tr 1321-*2 Ve-.ner had u E withdrawn us requesi for a i:e.r.ng EPA an the .00 yrar level av c :'3.*':.e'v ;v*n ;'ectrolux Corp v V.-, *..r;'i Inc b N Y Id :5r v* Y S 24 v*-' . cr. ' other similar cases are J.si tiuisna- hie. given e c i.-cts j : t >E v cu..*'jng discnargcx and tne continuing effect' -- i . . v .1 !.*.*..-ci 124 *u . ... Ho said the FDA employed a safety factor of 10. and therefore esti mated that human beings could tolerate "without adverse effects on health . . . roughly 200 milligrams spread out over 1.000 days.. . Tr. 993. In adopting this standard during September 1971, the FDA contemplated that consumption of PCB's would taper off and cease after 1000days, as PCB discharges were reduced or elimi nated. It recognized that exposures over a longer period would enhance the possibility of toxic effects Dep't Exhibit 39. p. 4. The standard promulgated by FDA concerning fish was unchallenged by any party when issued, and was not meaningfully attacked by G E in this proceeding. Dr. Kolbye said the standard is under review in light of new evidence of PCB's carcinogenic effects and of its continued persistence in the environment at high levels. Tr. 1023-24. His conclusion regarding Hudson River fish was unam biguous. "The FDA is extremely concerned about the problem of PCB's in Hudson River fish." he testified, "since the regular inges tion of fish containing PCB's above 5 ppm represents a potential public health problem with unknown long range consequences " Evhibn 39. p 10 A single 200 gram meal of fish containing 100 ppm PCB's. according to his estimates, would result in the ingestion of 20 mg. PCB's. or 10 percent of the total 1000 day exposure deemed tolerable for adults, and 40 percent of the total allowable exposure 150 mg) for children. See id. 9 Significantly, the average PCB content of fish sampled by GE downstream of its plants was 94 bo ppm in their edible flesh', which excluded the PCB's in their skin A smele. 200 gram meat of the eel captured by the Depart* mem jt Stillwater and found to contain 559 25 ppm PCB's in its edi ble parts would comjrv.injte an adult with over 50 percent of the FDA estimated lifetime limit, and a child with 200 percent of ns al lowable lifetime exposure. Any doubts raised by the evidence in this record concerning the FD.A standard indicate that it is dangerously low rather than high The FD.A relied on an estimate of PCB consumption by Yusho victims of 2 grams. The published analysis of the incident by members of the study group that examined its consequences reports, however, that 2 grams was the average consumption. The came report esiimates-that the minimum consumed by a "patient" wds 5 grams, or 500 milligrams PCB's Moreover, ihe average con sumption of oil by Yusho victims was 800 ml., but the researchers founo that "the attack rate" for consumers of less than 720 ml of oi.' was 88 percent, for those who consumed over 720 ml. oil. that attjcic rate was 100 percent Finally, while the Yusho results find a strong correlation between amount of PCB's consumed and clinical Severny, u t<important to note that 38 " percent of those who con>umed less than "20 ml oil contracted "severe" as opposed to "iigh:" cases of poisomng.'M Kuratsune a a!., mpra, pp 123-25 It .s clear, therefore, that the ten-fold margin of safety adopted by FDA is based on a statistical average, and affords much less than x tenj'ol^.p;o^^n^o.yys.t,a^qiy,.luifhi^q^tial,,yj^i^rruny-jiU^; whom are iTkely to suffer severe attacks And the ten-fold safety .factor appears itselT to be far lower than safeiy factors adopted m other, similar contexts " G E s argument that it is now m compliance with the ECL has at SvSoaei> ot Plavucx Ind v OSH.V 50? F 2d 1301. 1JOS. ELR :Ol51lt2iJ C i: 14'? n iiiim o n j bx Of Kray bill of the V m'I Cancer Institute (hit a id-fold sijndjrd j * insufficient for the highU tone carcinogen vinyl chloride, since a 'XI-1oid margin is used for non-carcinogens) The history of vinyl chloride regulation is generally instructive Evidence of tone effects ted Do Chemical Company to recommend a maximum et- to -jrkers of .<0 ppm The industry refused to give up us 500 ppm stan- o.i-J then, and even as further evidence of carcinogenicity accumulaied. partly .v. the ground that extrapolations ftom experiments involving rats as im- n-oper Bv |9'2 hen ihe mdusirv agreed to finance a study, the first deaths of \ner:can o-kers due to V C Y exposure ere recorded. Bv |9?4 ihineer. orxers had been killed No sooner had the federa. government been led io a.lori the 50 ppm siandard thin evidence established u was too high After a tearing before an administrative judge, a standard of 1ppm as proposed, uh some va-tince allowed Industrv protested the standard as unnecessary and measibie The D C Circuit upheld me standard. njever. noting thji no t.-'e leveis had been established, that human lives ere at stake, and that ex perience tad sho n that the industrv had greatiy underestimated us technologi cal capacuv to reduce exposure levels itW F 2d at J0S-10 r r.c present case atvo involves acarcinogen of unknon potential effects, and i.nj.1 hljl: i - a: stake GF, has to reju*: i s.hartc- f*am a d.i-;* jve-.-.c -i to j pr.siiciid dj --.vir-tum -*t It/ j.-jrr.s. _r,.c its resources we'.- turned : .opine ith the problem Some 44 GE enp.ovcc- *'ei*- en IdeO afrno1m!fWl_Ti 9ecrtei'djca:gnAonxeodthaes- *uune devr1 ch! it jenf o* 'b terjtt.-d r..-..s;.: diccm-csv dem'Jt'tis reactions ind cv< and nasa. .r- niatiottx Der't E*hibit ai FoI.j - p -tud-es ommousIx c.-'JcJ for a beenfdealt wuh above The contention is particularly inappropriate in connection with the impairment of fishing Fishing has been a protected use in Class D waters s.ncs March 24.19?4 Furthermore, fishing was a protected use in Class A and B waters long before then, and the waters into which GE has discharged PCB's flow into Class A and B waters.4* The act requires that GE be found lia ble for impairing that protected use. and ordered tocease contribut ing to the condition it has caused. . Alleged Violation o f ECL Jl-f>;0* The Department claims GE has violated ECL 11-0503M) hy discharging a poisonous or deleterious substance into a public wjter in quanimes "injurious" to fish or wildlife, or to the propagation of fish or protected wildlife. The evidence that proves a violation of ECL 17-0501 and 1*7-0511. the Department contends, likewise proves a violation of ECL 11-0:03(1). Further, it offers proof that mink reside m the Hudson River basin, and that they are wtioiife that would be injured and whose propagation would be adversely affected if they consumed fish wuh the quantities of PCB's shown to exist m the river. ECL 11-0503(1) is. however, very different in background and purpose than ECL 17-0501 and 1"-0511. The former has nineteenth century roots, and is an isolated provision aimed specifically at pro tecting fish and wildlife. The latter are relatively modern parts of an overall sysiem of water classification. As we have seen, the wjter classification program was adopted pursuant toacommittee recom mendation based in part on the narrow scope of ECL 11-0503* I ). The committee's perception of the statute, as requiring proof of in jury by a specific substance on a particular occasion, is hardly en titled to binding weight But a relatively narrow purpose for the pro vision is also strongly suggested by ECL 714)925(5), which slates that "any act" in violation of ECL 11-0503* 11may bepunished by a fine of from S500 to Sl.000 "for each offense and an additional pen alty of ten dollars for each fish killed in violation thereof___ " The statute seems aimed at specific, identifiable "acts" and "offenses" that injure or kill fish A further characteristic of ECL 11-0505(1) is that its violation is punishable land apparently in the case of wildlife must be punished) as a misdemeanor. ECL 71-0919 incorporates by refer ence this penal remedy in ECL 71-0921(d). and the punishment for each offense is up to a S50Q fine and 1year imprisonment. ECL 710921131(a). Thus. ECL 11-0503* I > seems aimed, not only at episodes of toxtc discharge, but also wilful or grossly negligent, episodes, where severe penalties are appropriate The potential un fairness is compounded by the fact that ECL 114)503(1) makes it unlawful adversely to affect the reproduction of fish or wildlife, i whereas the wjter classification regulations specifically provide that \ Class D waters need not be suitable for reproduction 6 NYCRR 701 4 ~- ** "El- ftSia uci'is Tn6r5iftif'sbrTigainst whTcTvE l` Tl -05(iX was written. The company engaged in a continuing practice, in which discharges at any particular lime or day have not been shown in themselves to be injurious to fish or wildlife Unlike ECL 174)501. moreover, under ECL 114)503 GE`s insistence that injury to spe cific fish be shown has considerable mem. GE's activities were in addition revealed to the relevant state and federal agencies The company may be have acted at us own risk, but its conduct could hardly be characterized as wilful in the criminal sense Circum stances may arise where ECL 114)503 should be applied although no specific fish can be identified as injured, and even in conjunc tion wuh ECL 174)501. out the present case does not fit the antici pated pattern. Cf. People v. Conio>*Jaied Ed. C o . 34 N Y 2d 6-tp, 3S5 N. Y.S.2d 379 (19741 The Department has shown injury to fish, but not in a context to which ECL 11-0503 should be applied. As to the proof concern ing wildlife, the Department's case, as GE properly notes, is based entirely upon hearsay evidence -k Department witness tcMifiad that he had read books sunne mat mink existed in the Hudson River basin, and that unidentified citizens of unascertained exper tise had reported sighting mm.-. Tms is noi only hearsay, but hear say of unproven reliability. Eve- if believed, it would prove only 42 Si'* h M'CRR ( ` 01 4 TV H-Cio- fi-'e: fronv Bouen k<l .o loex J u Cii>in:ieJ Gas B. f-ont Loc* 2 to the Confluer-ce c^ihe MaAi-k c d ais- njted Class A The Loer H-.-ilsa-. *--Coxt.*;'*ie to Chelsea >s f*um CheSei sc^t*. to .. p .w Ij .-j County n Gai B r - r r i Ex hibit ! I 125 6--6 ADM INISTRATIVE PROCEEDINGS 6 'E L R 30019 (hat mink existed, in unknown quantities, in a very large area en compassing many thousands of potential food sources other than the Hudson River. An inference of injury cannot as readily be drawn in this context as in the case of fish, essentially trapped in the PCB contaminated waters, and actually shown to have ab sorbed PCBs in quantities demonstrably high enough to be in jurious to themselves and potentially to their consumers The allegation must be dismissed as inappropriate and unproven. HI Outstanding Remedial Issues The Department has proven violations of ECL P-0501 and P-0511. It has also shown itself entitled at the very least to an order requiring GE to reduce its PCB discharges to a lawful level. Whether the levels GE represents it has and can attain are lawful is only the first of several issues to be examined when this proceeding reconvenes. Other issues include: 1. The extent to which GE should be ordered to rectify the effects of ns prior discharges, including whether any prac ticable and environmentally safe method exists or can be devised to remove PCB`s from the river bottom, and the ex pected duration and extent of PCB contamination if no remedial steps are taken; 2. The extent to which GE should be required to remove PCB-comammated earth and equipment from around its plants and the manner in which this operation should be conducted. 3. The existence of substitutes for PCB'i. including their adequacy and environmental acceptability. 4. Whether GE is presently utilizing proper care in its manu facturing and sales processes to avoid PCB contamination, including what controls GE has in effect if any to insure that PCB-impregnated equipment is not being permitted to become a hazard to the environment after use; and 5. Whether the system of supervision proposed by the Department would be lawful and adequate, particularly the legality and necessity for a bond as requested. An aspect of all these questions is the cost involved in proceed ing in one way or another. The Department of Commerce will hpefullv provide assistance in this regard, by analyzing the costs of alternatives. The Department of Commerce should, in Ihis connec tion. note that the extreme prospect of closing down G E's plants has not been suggested by any party as warranted or necessary, the Department and NRDC have heretofore relied in advocating a zero PCB discharge on their claims that adequate alternatives exist. These are complicated matters that will require technical proof. The Department will have to go forward on these issues. GE is hereby ordered, however, to provide the parties and the Hearing Officer, within two weeks of the date of this opinion, with as com prehensive as possible a description of its present abatement plans. The hearing should proceed with a full appreciation for what G E is prepared to accomplish without compulsion. The Department should inform the parties as soon as possible when it will be pre pared to present its proof. After the forthcoming hearing, a pro posed order will be prepared and submitted to the Commissioner, containing all the findings made and conclusions drawn at both parts of this proceeding Meanwhile, this opinion shall constitute the interim findings and conclusions on GE's liability. -Z t , -IJS- v. i 126 c Spirometrie Findings in Capacitor Workers Occupationally Exposed to Polychlorinated Biphenyls (PCBs) Richard W. Lawton, MD; Marie R. Ross, RN; and Joseph Feingold, MD 1 S p irom etric finding? (forced vital capacity [FVCJ, forced reported by them as equivalent to that of asbestos ' f expiratory volume at one second [FEVJ, F E V J FVC) in a workers (12.1%). Of those showing- FVC reductions, population o f capacitor workers with occupational exposure to 80% showed a restrictive pattern (FEV,/FVC > 0.70) polychlorinated biphenyls (PCBs) are described during active without radiologic changes. PCBs were not reported as PCB use (1976) and following the PCB ban (1979 and 1983). acute direct pulmonary irritants, although eight-hour CThe initial fin d in g -o f restrictive im pairm ent (16% ) In 1976 was not supported by chest roentgenogram findings, nor con firm ed in 1979 and 1983, and was interpreted as artifactual `o test operator inexperience and inadequate expiratory time-weighted average air levels in the workplace areas of PCB use varied from 0.6 to 11.0 mg/mV The present paper reports a spirometry study of s. O bstructive im pairm ent was consistently found in 15% capacitor workers, drawn from the same plant popula o f the total population in 1976 and 1979. A history o f respi tion as that of Warshaw et al, but involving only workers ra to ry illness a n d/or sym ptom atology and reduced F E V J FVC with current occupational PCB exposure in 1976. Spi was correlated with PCB exposure and serum PCB levels rometry was repeated in 1979, 1981, and 1983 and (lower homologs) in females in 1976. but pot in males. Sm oking provided longitudinal data on a selected population. was correlated with reduced FEV%values. S o correlation o f { spirom etric variables with pest exposure or serum PCB levels was found for either sex in 1979. Methods and Materials In spirometric studies of &group of capacitor workers (N --243), some of whom had high direct occupa tional exposure to PCBs, Warshaw et al1 found a sub stantial prevalence of reduced vital capacity (FVC < 79.5% of predicted value). The prevalence (14%) was From the Biological Science* Branch, Corpo.**u Research end ^ D evelopm ent, G eneral E lectric Company, Schenectady, NY (D r Law- ton. RAD *t*fT); C apacitor Producta D epartm ent. General E lectric Company. Hudson Fall*. NY (M i Roe*. O ccupational H ealth Nur: Dr Feingold. P lant Physician, Dr Feingold la re tired and currently In the - practice of in te rn al medicine a t 31 E aal St. F o rt Edw ard, NY 12828). Presented at the American Occupational H ealth Conference, KanCity, MO. April 17. 1983. ddresa correspondence to: G eneral E lectric Company. Corporate rch and Development Center, PO Box 8. Bldg K -l. Room 3B12. .ecUdy NY 12301 (D r Law ton). 0J98.1736,'S6/8S06-433S3 00/0 Copyright C by William* a Wilkin* The study population consisted' brail'capacitor work ers with direct work-related PCB exposure in two plants in upper New York state. This population, when selected in 1976, consisted of 194 workers (152 males, 42 fe males) representing approximately 10% of the work force. Ages extended from 22 to 66 years and service times from 1 to 35 yean. The cohort was examined in 1976, 1979, 1981, and 1983. Exposure was defined in three categories: (1) high exposure: jobs requiring der mal contact in high air level zones (handling and sealing wet capacitors, capacitor salvage and repair); (2) me dium exposure: jobs requiring brief high exposure and contact such as maintenance men; and (3) low exposure: jobs not Involving dermal contact but in or at the periphery of the high-exposure zone. The initial examination consisted of a medical history, physical examination, chest roentgenograms, ECG, se quential multichannel autoanalyzer (SMA-26) blood analysis, hematology, urinalysis, and spirometry. Body weight was obtained in light indoor clothing and height Journal of Occupational Medicine/Volume 28 No. 6/June 1986 127 \ } } was determined without shoes, subsequent examina tions consisted of blood workup, changes in body weight and blood pressure, and spirometry. Chest roentgeno grams. ECG. and physical examination were repeated in 1983. Smoking classification (smokers, ex-smokers ind nonsmokers) was obtained in 1976. Detailed smok ing histories (cigarettes per day, years smoked, etc) were not obtained until 1979 (N -- 165). These were generally confirmed in 1983 and the 1979 data were used throughout the analysis with no account taken of the few reports of change in habit over the period. Chest roentgenograms were classified according to the Inter national Labor Organization classification of radi ographs (form OMB No. 63-5 1322). With two excep tions all roentgenograms with positive findings were classified in section 4. Serum PCB levels were obtained in 1976 and 1979 (analysed by Hazleton Laboratories America. Inc, Mad ison. WI) using methods previously described.3 Pulmo nary function was evaluated in 1976 using a Vanguard spirometer with a disposable filter paper flow sensor (Life Support Engineering Corp, Woburn, MA). In 1979 an updated version (Vanguard DS502) with a prepro grammed computer printout was used. Measurements were made in the standing position and the nose closed with the fingers. The calibrating source was a VS3Q0 31 syriDge and calibration conducted at various volumes and rates as recommended.4 For each worker the max imum expiratory volume-time curve was recorded and examined for freedom from test artifacts.* At least three trials were performed by each worker and reproducibil ity of the expiratory effort was accepted at the 10% vel. Measurements were made of forced vital capacity (FVC), the forced expiratory volume at one second (FEV,) and the ratio (FEV,/FVC) using the highest test of the three trials. The data were evaluated as the percent of predicted values using the tabulated predic tions of Knudson et al.*,r The apirometric patterns were classified as restrictive (FVC < 80% of predicted, FEV,/ FVC > 70%); obstructive (FVC S 80% of .predicted,, "F E V f/F V S ^ 70^o)';`or rnixeJ'^'FVC < '00%' o f p'rdieted, F EV,/FVC < 70%). Initially (1976) the nurse conducting the test had had little spirometric training and only subsequently was certified (1978) for pulmonary screening. Retro spective review of the 1976 expiratory spirograms in dicated 15 tests (7.7%) to be unacceptable due to tech nical error. Subsequently, only two workers' test results were unacceptable: one due to thoracic arthritis and another due to poorly fitting dentures. Nine workers' test results were unacceptable in 1976 but were accept able in 1979. Statistical analysis was performed on a Honeywell Series 600/6000 computer using available time-sharing applications programs.* Regression analyses were con- C'ucted using STATPAC, a versatile statistical package* r distribution plotting and the derivation of coeffiits and correlations by multiple stepwise regression. j \ n incremental F-ratio of 3.9 was used for entering and removing variables so that variables significant at the 5% level were included. Only one marginal association was found and this was treated as significant. PCB exposure was described in terms of the exposure cate gory, treated as a dummy variable, or the serum PCB level, either as reported, or as the concentration in total serum lipids.3 As a consequence of dropouts due to retirement or employee separation, rejected tests, refusal of the pro cedure, or death, the number and composition of the participating population changed during the three ex amination periods. For these reasons, and because of incompleteness of detailed smoking data, the analysis focused on 136 workers for whom complete data were available for the 1976, 1979, and 1983 time periods. In addition, 93 workers were examined at some point in 1981 so that a total of 80 workers had four sets of measurements. These subgroups provided a longitudinal assessment of the spirometry changes with time and of the reliability of the procedure. The entire available population was used to assess abnormal spirometric findings and for the relations with serum PCB levels. Results Workers in the study population were overweight (50% of the workers had body weights above the normal "desirable" range for large-framed individuals10) and heavy smokers. Those who smoked or had smoked (71 .4% of males, 54.2% of females) averaged a pack a day for 18 to 20 years. In 1976 there were seven cases of clinically recognized emphysema and 12 workers were told by their physi cians they had chronic bronchitis, although only two complained of current shortness of breath, cough, or sputum production. Past histories of significant pulmo nary infections were reported in 16 cases. Chronic upper respiratory tract infections and allergies were preva lent. Four workers (heavy smokers) reproted leuko plakia and/or laryngeal polyps. 0i chest roentgenogram examination emphysema was suspected in six cases. The i u^utQndiag^ was_s&yid.eqse-vfor--pastrpulmon a ry infection (granulomata, calcifications, scarring), A coin lesion (malignant) was discovered in one worker. Evi dence for fibrosis was found in only two workers. One worker (with carcinoma of the lung) showed bilateral circumscribed pleural thickening; another worker showed old healed pleural thickening at the left base. Mean 1979 serum PCB levels were elevated 35 to 40 times the normal background community levels in hu mans. The levels for PCBs were higher in the female subgroup. The Figure shows spirometry data converted to per cent of predicted value for 80 workers who had meas urements made at four periods during this study. The plotted points are means the 95% confidence limits for the population average. For the males, (N = 75) the mean FVC value rose between 1976 and 1979 (4.53 L to 4.90 L) and then declined (4.70 L in 1983). With the smaller accompanying change in FEV,, the FEV,/FVC ratio fell in 1979 and then returned to its 1976 value. However, as indicated in the Figure, only the FEV, population average appeared to be significantly less 4 5 4 PCB Exposure/Law t 128 T y -r. 100'c of the predicted value i ?76. These data ..-.dicated a continuing im provem ent ... the reliability of the m easurem ents with experience of both the operator and the workers. Using the predictions of Knudson et al.' workers were ifed in restrictive (FVC < 80%; FEV,/FVC > 70% ) a.. obstructive (FEV, < 80%; FEV,/FVC < 70%) cat- 1976 1979 1931 1980 Figure. FVC. FEV ,. and FEV,/FVC as percent of predicted value* for portion of study population with four spirometry tests (N - 80). Means and 95% confidence limits. egones (Taoie). In i for the total population (N = 179) we found th a t 6.2% of the population showed restrictive impairment. In 1979 the percent of the pop ulation showing this finding declined to 2.9%. In con trast. the obstructive category was relatively constant (15.6% and 15.3%) with 2.2% to 3.4% of the population showing a mixed result (FVC and FEV, both < 80% and FEV,/FVC < 70%). Obstructive defects were more prev alent in smokers and ex-smokers. Of those with FE V ,/ FVC < 70% about 70% had values between 65% and 70% and the ventilatory Impairment was considered mild. Four of the 25 workers not re tu rn in g for the test In 1979 were known to have clinical chronic obstructive lung disease. Because the study dropouts in 1983 made up such a large percentage of the population (21%), scoring for these data provided a lower estimate of the obstructive category. Using multiple stepwise regression we examined the significant partial correlations of the measured spirometric parameters with the conventionally used varia bles (sex, age. body height), as well as those of interest in this study (smoking, r e s p ira to ry history, and PCB exposure). Although the number of workers with satis factory spirograms and complete data varied for the three examinations, we found strong and complete regressions for FVC and FEV,, but incomplete and weaker equations for FEV,/FVC. Spirometric variables were inversely associated with smoking in all cases except FEV,/FVC in 1976. Body weight was inversely associated with FVC in 1979 and 1983. This la tte r relation was characteristic of the male subpopulation. The presence of a history of respiratory infection and/ or symptomatology was significantly associated with a decreased FEV, and FEV,/FVC in 1979 and 1983. High exposure to PCBs in the workplace, as measured either by the exposure category or the serum PCB level, was significantly associated with a decreased FEV,/FVC in 1976. a period of active PCB use. However, this associ ation of exposure and FEV,/FVC was found only for the female subpopulation. There were no significant associ ations for the serum PCB level and the spirometric p aram eters in 1979 for either sex. The Pearson product-movement correlation coeffi- TABLE R estrictive obstructive ana m ixed soeam etnc findings n total poo>ation n 1976 and 1979 using predictions of Knudson et a i' 1976 1979 Male Fem ale Total Male Fem ale Toiai Sm ok.ers _E s-smanodk. e rs Norl sm okers _Ex-samnodk. ers a mNoo.kne- rs wNo. % E_ Sma0nid, r , x-sm okers Nonsm okers E_ xS-msam0n*od'k.'e9rs s mNoo.kne- r s N,, o. "A N Restrictive 103 39 22 15 179 100.0 94 38 22 16 170 100 0 19 6 2 2 29 16 2 2 0 1 2 5 29 (FVC < 80%;; a 70-/.) FVC Obstructive 14 3 9 2 28 15 6 14 2 9 1 26 15 3 / TV C > 80% ; SFV*C. T 0 k | f 40 1 1 6 34 2 0 2 0 4 24 FVC < 80%. 2* FVC s 70%) Journal of Occupational Medicine/Volume 28 No. 6/June 1986 129 1 cients for the constant populate (N = 136) in 1976 and 1979 indicated an association of exposure with respiratory history and symptomatology in females, al though the relation was marginally significant (F = ".12%). In males we found the respiratory history to be .gnificantly associated with smoking. Smoking was also associated with a reduced FEVl( in males in 1976 and 1979 but only for females in 1979. Discussion Medical surveillance of a group of capacitor workers directly exposed to' PCBs was undertaken in 1976 to assess the workers' general health. The medical exami nation included spirometry, which was repeated in 1979 and 1983, and on a part of the group in 1981. We found pulmonary-function testing to be one of the most difficult procedures to perform well in the industrial medical setting. The procedure requires a trained and certified nurse or technician, functional and properly calibrated equipment, and motivated and cooperative workers If adequate data are to be obtained. These conditions were not fulfilled at the inception of this study: the nurse had little spirometrie training and testing experience and worked in cramped quarters with new equipment. The test was new for the workers whose motivation was uncertain, given the intense media coverage of PCBs at the time. As a consequence only 179 out of 194 workers tested (92%) had apparently satisfactory forced expir atory volume-time curves on retrospective review. Fol lowing nurse certification and repeated worker experi ence with the procedure, unsatisfactory data were ob- \ined in 1% or less of tested cases in 1979, 1961. and 983. Because of the technical deficiencies in the spirometry procedures and the uncertainties associated with the serum PCB meausrements in 1976,* we were inclined to reject the data. However, these observations were ob tained during the period of active PCB use and were characterized by high serum PCS levels in the workers. In addition, the observations coincided in time with those ofWarshaw et al.' In their studies (1976), as well as in ours, reduced FVCs were observed. FVCs < 80% of predicted with normal FEV^FVC (>70%) were found in 14% of the population studied by Warshaw et al and in 16./2% of our study population. In both studies there were no radiologic evidences of pulmonary fibrosis to account for the restrictive impairment observed. In our study, based on longitudinal observations, we believe the finding to be artifactual. FVC values as percent of predicted for the population in 1976 were normally distributed over the range, indicating a sys tematic decrease, which could have resulted from gen erally poor coaching and inadequate expiratory effort. In addition, regression studies indicated substantial di vergence of the prediction coefficients and a higher degree of variability of the 1976 data compared with that found on subsequent testing. We know of no rersible restrictive pulmonary pathology that could acwount for these findings. The principal and consistent respiratory finding In this work force exposed to PCBs was obstructive im pairment which wus found in approximately 15% cf the 456 population. In th-s lemale subgroup we found a signifi cant relation between exposure in the workplace and respiratory history and symptomatology in 1976. The serum PCB levels in females were 11% higher than in the males in. 1976 and 50% higher in 1979. These elevated levels were related initially to the women's employment as capacitor sealers (solderers) and in salvage and repair, jobs with relatively high exposure levels, and subseqeuently perhaps to a diminished PCB metabolism compared with that of males. The associa tion of serum PCB level and/or exposure and reduced FEVi/FVC in females in 1976 appeared as an isolated finding, and no other correlation with spirometry in males or females was found. - The present study provided no compelling evidence that PCB exposure, as measured by exposure category or serum PCB levels, was correlated with the occurrence of persistent spirometric abnormalities. The restrictiveimpairments observed In 1976 were transient and were interpreted In terms of inadequate expiratory effort rather than pulmonary fibrosis. The past histories of respiratory Illness and symptomatology, and the ob served obstructive Impairment by spirometry appear most likely to be coupled with heavy smoking, a complex of industrial exposures both prior to and during em ployment,11 and rural upstate New York demorgraphic factors.1"*13 Our 1976 data, however, are suspect and this study serves to emphasize the importance of nurse/ technician training in the conduct of spirometry. References 1. W arshaw R. Fiichbein A, T hornton J , el 1: Decrease in vital capacity in PCB-exposed worker* in a capacitor m anufacturing facil ity. A n n N Y A c a d S c i 1979:320:277-283. 2. Fiichbem A. WolfT MS. Lilts R. e t at: Clinical Findings Among PCB-Exposed Capacitor M anufacturing W orkers. A n n N Y A ca d S c i 1979;320:703-715. 3. Lawton RW, Brown J F J r. Ross MR, et at: Comparability and precision of serum PCB m easurem ent?. A r c h Environ H e a lth 1983:40:29-37. 4. Snowbird Workshop on standardization of spirom etry. A m . Rev. R e tp ir D it 1979:119:831-838. 5. Lewis BM: Pitfalls of spirom etry. J O ccu p M e d 1981;23:35-38 6. Knudson R J, Slatio RC, Lebowitz MD. et al: The maximum ex p irato ry flow volume curve: Norm al standards, variability, and (Teels of age. A m R e v R ea p Dia 1976;113:587-800. 7. Cotton Dust Staadard. F e d e ra l R egister 1978:43 (July 23):27414-27417. 8. Honeywell Series 800/6000 T im e sh a rin g A p p fic a tic n a L ib r a r y Guide, vol 2; SutijC ies. Honeywell Inform ation Systems, Inc. (DA 44), 1973. 9. Nelson W 8. M organ CB. Caporal P: 1979 STATPAC Simplified: A sh o rt introduction to how to run STATPAC. a general statistical package for data analysis. G eneral E lectric Co, CRD TIS Report 78CRD276. December 1978. 10. New weight stan d ard s for men and women S t a t B u ll M e tr o p Life Round 1959;40:1-4. 11. Brown DP. Jones M: M ortality and industrial hygiene study of workers exposed to polychlorinated biphenyls. Arch Environ H e a lth 1981:36:120-129. 12. Rubin BB: M ortality from lung cancer, emphysema and bro n chitis for counties in New York S tate, excluding New York City, 19CO1975. Albany, New York S tate D epartm ent of Health m onograph No. 16, 1880. 13. Nosca PC. B urnett WS. Greenwold P, et al: Populo*ion density as In indicator of urban*rurel differences In cancer incidence, upstate Now York. 1968-1972. A m J E p id e m io l 1980.112:332-373. PCB Exposure/Lawtc . 130 M - 2- 1 Tl.ME FICUM ] CXCMTTjgty 5* O O O LO I W M U5I* m aim e ca/ tvm Drrtcrct. A partial list of laboratories available for PCB analysis is provided in Table IV-1. C. Handling PCB Materials Detailed information on the handling and the exposure to PCBs should be obtained from the GE-Pittsfield Medical Center (Building 11). General handling information is as follows: Always wear rubber or vinyl gloves. Wear a face shield or safety glasses as appropriate when handling hazardous material or drilling. Wear disposable shoe covers and coveralls when handling large quantities of PCB-containing material. Wear an approved respirator as specified by the Medical Director. Do not touch or contaminate anything to be eaten. If skin is contacted with PCBs, clean off with paste-type waterless hand cleaner and wipe off with paper towels. Dispose of towels as a PCB solid waste (refer to Section VI of this manual). If PCBs get in the eyes, flush with water. Report any exposure or contact with PCBs to the Medical Ce.iter. GENERAL ELECTRIC L P ITTSFIELD , MASS. PCB INFORMATION AND COMPLIANCE MANUAL ISSUED: August 1982 BY: JM Rhodes REVISED: A p r il 1983 131 * PCS YEARLY SALES TOTALS r GENERAL ELECTRIC - ALL LOCATIONS ALL PCB PRODUCTS 1954 - 1977 1954 9,799,459 lbs 1955 10,779,019 lbs 1956 13,711,535 lbs 1957 10,375,310 lbs 1958 c 8,813,870 lbs 1959 9,639,679 lbs 1960 9,849,831 lbs 1961 8,929,560 lbs 1962 7,743,100 lbs 1963 8,267,202 lbs 4 Cm 0C896S 132 1964 \ 10, o y , 525 lbs A2 14,4*22,371 lbs 1966 \ 16,658,107 lbs 1067 15,258,874 lbs 1968 15,243,031 lbs 1969 11,472,988 lbs 1970 13,384,352 lbs 1971 9,349,428 lbs 1972 .11,841,805 lbs ... m 'h : .J > * * * * f - - - 1973 13,688,365 lbs 1974 12,905,681 lbs 1975 12,888,722 lbs 1976 8,858,605 lbs 2 1 AOH 008970 133 r 'y