Document VGqvB393eaKy425v89Yqr4D74

ASKAR EL: REQUIEM FOR AN CLD RELIALE David C. Morris Weyerhaeuser Co. Tacoma, Washington For several decades, askarel containing poly chlorinated biphenyls (PC3's) was .considered an excellent Insulating fluid. In che span of a few short years. It has come under attack as a pernicious and ubiquitous envlronsental contaminant. Regulations concerning this material are evolving rapidly, and a total ban Is ultimately expected. Spill prevention, control and disposal are required to preclude high economic loss as well as adverse publicity. Alter nates to che use of askarel include new fluids chat must also be reviewed for environmental acceptability. Introduction Until rather recently, our society used many chemicals with seemingly few environmental problems. In a short span of time, several factors contributed to a substantial change In che environment. A rapidly expanding population, enjoying che fruits of che most advanced technology and greatest affluence in the history of mankind, created a demand for more goods, often based on a host of new chemicals and materials. Consequently, genuine and serious environmental problems were becoming common. In che latter part of the 1960's, there was a new mood of social awareness and activism. Con currently, che raold advances in technology also Included significant improvements In the means of detecting and measuring concamlnar.es at remarkably low levels. The stage was sec for che suttden change in the status of askarel, an old reliable. PC3'a - The Problem Polychlorinated biphenyls are produced by substituting one to ten chlorine atoms for hydrogen atoms on che biphenyl structure shown In Figure 1. There are 209 possible combinations or isomers; for example, there are cvency-four different possible arrangements for the molecule containing three rhlorine atoms. One of these trlchloroblphenyls is illustrated by Figure 2. manufacturing process results in a loosely 'or.mlled mixture of various amounts of maov of *ne i.-oners: neaca che characteristics of a urt1c-iiir bacch is 'he sum of che several individual .-rmucnancs. lone general conclusions aboue chase ..as.eoiir.cn are: 1. Thsy cause abnormalities in cells, organs and gland - .i aar.v animals. This occurs at rather low levels .f the chemical. i 2. The material Is eulte stable and b^raiv reacts, iegrade*. >r Jecoaooses under normal seances; It la quite insoluble in water. % # * 1*4 1. (t Is heavier than water and Is ingested by tor rcn-reec 1113 snlral*. Animal, tend to bioacturulatc the chua.leal, i.e.. It la absorbed readily end excreted slowly, with a resultant high level becoming scored .n tissues. A. Traces of two very slallar chemicals (see Figure 3), polychlorinated dlber.zoiuran and polychlorinated dibenzodior.ln, have been found la the tissues of animals which have absorbed PCB's. The materials nay be present In the original PCS or may be cetabolized from PC3 by the an Inal. These coapounds are known to be highly toxic. 3. PCB's are ubiquitous and are apparently mobile In the atmosphere. They have even been found la snow at che Antarctic. 6. They are being found at significant levels in human tissues and in mother's milk. About ten years ago, PCB's were first isolated and Identified as a possible contaminant contributing to problems in animals. At that time, this chemical was in wide use. About half was utilized as the pri mary constituent of askarel is electrical equipment (askarel also conealns crlchlorobenzer.e as a solvent) . The remainder of the PCS was used In plaselcs, paints, carbonless paper, and many ocher products and processes. Since few problems had ever been noted with che material, any scrap or waste was indiscrimi nately severed or placed in dumps, as most chemicals had been handled for quite soae time. One of che characteristics that made P CB's or askaral attractive was Its stability; but this very permanency also meant that the material remained virtually intact for decades. It Is general./ conceded today chat this residual of PCB's will be present as a contaminant for decades, regardless of a complete elimination from che market place. Initial Conerol Efforts PCB's because of their excellent stability and thermal properties, have been used as a heat-transfer fluid in several industries. In Japan during 1968, a food product was contaminated with PCB's from a heat-exchange operation and more chan 1200 peopla wera afflicted, some rather severely, with what was called ~Tusho" disease. This outbreak, plus ocher incidents, and a rapidly expanding research effort identifying PCB's as a potential aecriment, led the sole U.S. producer (Monsanto Industrial Chemicals Coonany) to voluntarily restrict sales to closed electrical systems. This step removed about half che PCB's from che market, and began the elimination of the most concon uses whereby PCB's were being introduced to the environment, such as through carbonless office papers. Of course, outdated capacitors and the like continued to be thrown on che Junk pile. In'lace 1975, the D.S. Environmental Protection Agency sponsored e ?C3 conference wnich was botn technical and political. The technical program was enlightening; there was little doubt that hard scientific evidence identifying CB's es a major concern was developing quickly. The political aspect of cha conference came from two sources. First, the 78408536 1 I A * 7 7 A .VI M I I A I G E N P 0 1 1274 public sector was allowed to sake presentations, the majority of vhlch predictably were emotional and often based on misinformation. The second political aspect arose as representatives from various govern mental agencies - FDA, Interior, NIOSH, Commerce, etc. - made statements to explain past indifference and to scourge the plague of the 70's, PCS's. There was little doubt ehat the bureaucracy felt safe in taking a stand, and that regulation or restriction was l=inent. There is strong public support for control since the saas of the populace is technically naive and thoroughly frightened by the constant dis closure chat everything from licorice to marachlno cherries nay be eutagenic, teratogenic, or carcinogcnlc. In this context, and knowing chat there were some substitute materials forthcoming, the equipment manufacturers began phasing out of askaral and into new fluids. Naturally, the fluid supplier (Monsanto) recognized that the market was disappearing and made the decision to terminate all production of the chemical later this year. Thus today, there are three questions to be answered: 1. What should be expected concerning the askarelfHied equipment now in service? 2. Exactly what is available in the future? 3. Vhac assurance is there Chat the course taken nev is correct; ean this happen again with a substitute material? Anticipated Pressure lr these times of OSHA. 1*5 , FDA, r?A> Protection Agencies ana the like, ic is apparent that users of equipment containing askarel can expect the following: 1. Specific regulations will be published for askarel handling, protection, disposal, ate. Tor example, one state Is In the process of promulgating a regulation that includes mandatory labeling of equipment containing more than two pounds of PCS. 2. Users will be asked to inventory askarel on the plant premises and to indicate the location of equipment in reference to vatervayi. 3. Monitoring of fluents will be required; this is already being specified In JfPDES permits in some locales. A. Protective measures, such ae dlkej, will be made sancator7. 3. ft may be required to include askarel in the spill olar.s which most plants already have. n. Any accidental m i l l vlJl have to be reported, even if it was apparently completely controlled on cne plant sice. If the pill should Involve eore than a certain qu-otity, a regulatory agency may visit the sice. 7. If a spill should escape to a waterway, recovery of the lost askarel will be requirad. There have been some specific (and very expensive) instances where this has been done In the past. 9. There will be e ben on nev installations of askarel-filled equipment, which will be rather meaningless since industry is already voluntarily abandoning tha market. Sue there will ultimately also be a ban forbidding the continued use of existing equipment. This coo may prove to be meaningless because the unavailability of askarel for copping out or rctrofilling transformers may result in early retirement of most askarel-filled equipment. There are substitutes available for copping out, but there is a H a l t to their use. Loss Prevention and Control Until quite recently, askarel spills were virtually Ignored. As attention focused on the problem, many incidents came to light. Spills or losses are known to have occurred under these circumstances: 1. Ae a consequence of moving or handling. 2. Overloaded or faulty capacitor. 3. Overloaded and overheated transformer which loses fluid through cr.u relief valve. A. Changing out carbonized askarel from a shorted transformer. 3. Leaks from valves on the transformer casing. 6. Loss when sampled for dielectric or moisture case. 7. Improper disposal of sample. 8. Misuse - mistaken for another chemical. This has occurred when wests askarel was placed in a used drum without relabeling. 9. Damage to drums or equipment by other equipment such as forklifts. 10. Freak Incidents, such as an icicle piercing a " transformer cooling fin, or a capacitor skewered by the errow of a frustrated bow hunter. Two actions should be takes Immediately to pre clude such occurrences. A rather detailed Inventory should be taken of every askarel cranaformer and capacitor aa shown is Figura 4. While most plants have some fora of inventory for electrical purposes, they do not includa information which will allow an evaluation of the environmental risk. It la suggested that oil transformers be Included in the inventory since even these present potential environmental costs. Inactive units or stored fluids should also be noted The second most immediate action ia to inform or educate the plant staff. There are two objective (1) to prevent or control spills, and (2) to ensure that personnel are not confused or frightened by Inadequate knowledge of s potential problem. % It la suggested chat an appropriate label - large and bright - be placed on askarel equipment. It la also necesscry to ensure chat contract personnel are informed to look for these labels, and it may be advisable to specify in writing the responsibility for spills caused by a contractor. 784086 C I 7 \ M\ A M2LO r After caking an inventory of askarel equipment, t decisions must be cad* whether to invest in pro je c t i o n or spill control for a particular lean. This cotter is arbitrary, but it is suggested that the items be rated by vulnerability to damage, quantity of askarel, and proximity to a waterway. Thus the larger transformer located by a road with an adjacent running ditch going toward the river waters, the bocrao is dredged. The macerial first passes through a settling chamber, then through a sand filter, and finally through an activated carbon column. All of the wet solids require disposal. Obviously, every effort should be made to avoid a spill of this nature; the cost is horrendous. The final bill for cleaning che spill of 265 gallons into che Duwaaish Waterway was 5500,000.' unrrancs more consideration than the smaller unit inside a building away from any traffic. Proper disposal of waste askarel, scrap equip ment, or solids wastes is rather well defined. The potential for a costly spill can be reduced by preventive measures. For example, place fences or posts around exposed equipaent; a light roof say be added to prevent dasage froa ice or dropped tools. Relocation of the equipment is an alternate. A plug should be threaded into the drain valve of a trans former. Finally, aany spills could be prevented by operating equipcent at the design rating Instead of 110Z plus. Askarel nay be transported as a liquid or gelled with molecular sieves. About twenty facilities are available for burning or landfill. Burning requires quite high temperatures to ensure complete destruction, and the exhaust gases must be scrubbed with caustic to remove the hydrochloric acid chat is emitted. Landfill can only be in certain approved sites. Transportation of PCB's to a disposal sice requires special preparation and handling. In one incident involving a spill from a 1500 kVA trans Inevitably, equipment will fall or freak acci dents will occur; several steps cay be taken to con former, transportation and incineration cost $2,100. In another incident involving che rupture of a pole- tain spilled askarel. Dikes can be installed around mounted capacitor, transportation and burial cost equipaent preferably with a capacity slightly greater S150. than the largest volume of askarel in one unit. If the location is outdoors in a wet cllcata, a device Environmental Acceptability of Alternate Compounds known as an imbiber valve, which contains molecular sieves that pass water but retain PCS's, can be in Several alternate fluids are now available la stalled when the dike is constructed. Plastic shields new transformers and capacitors. can be placed around pole-mounted capacitors to restrict a spill to a lesser area. Silicone-based fluids are offered for liquid- filled transformers. All evidence thus far indicates All drain holes in vaults should be plugged, Chat the material is quite Innocuous. It should be and romped sills placed at doors. All joints should noted that unlike askarel, che silicone fluid has a be scaled with a silicone putty, and concrete block specific gravity less chan one, and any spill would vails should be sealed with silicone paint or an have to be created as an ordinary oil spill. equivalent coating. Obtaining detailed environmental information from Should askarel be spilled, the precise amount of the vendors on their new capacitor fluids has been cleanup or reclamation is arbitrary - there are no difficult, and much of it is not comparable. For standards yet. At Che time of the spill in the example, one vendor will report on the toxic effects IXivamish Waterway (Seattle) in 197A, the F?A termi on a certain fish species on che basis of a 16 day nated the operation when the PCI content was reduced test, while another uses a 96 hour test. All che to 77 percs per trillion; this should indleacc chat new materials offer definite improvements over PCB's a thorough collection is expected. however. On che bails of all che daca-coxicicy, biodagradabillcy, solubility, etc. - which this Collection of visible or standing askarel can be writer has been able to obtain, che three available initiated with an absorbent compound. Rags with sol fluids should ba environmentally ranked: vent such as trlchlorobenxene should be used to wipe down equipment, poles, ete. Soil should be removed Host acceptable - Isopropyl biphenyl to a depth exceeding the obvious level to which the fluid soaked, and radially beyond the last visible Second - butylated chlorodiphenyl signs of fluid, boards or the like should be re oxide placed. All solid wastes - rsgs, gloves, soil, shovels, see. ss well es liquids should be set aside Third - di - 2 - echylhaxylphchalaca for proper disposal. (a phehalaca aster) Should a pill enter an Ineernal sever, the water flow should be terminated and askarel collected from che low spots. If che sever discharges into a sewage plant, most of ehe PCS chat is carried in the water will attach to suspended matter in the treatment plant and settla. Of course, these settled materials usually end up In a landfill eventually, but at least most of che PCS apparently remains immobilised. The worst situacin, of course, is if a spill caters a waterway intact. Noon has an answer for the situation where che eoncamlnaac enters fast scream and disperses widely. For lakes or rather title One suggested alternative to che replacement of askarel transformers has been to recroflll wich che slllcone-based fluids. This procedure involves draining out all possible askarel, followed by flush ing with trlehlorobenzene. A certain amount of askaral will be retained in pockets, insulation, etc.; Che residual PCS concent is estimated to be 1-3Z, and will be very dependent upon the aoounc of care taken and number of flushings performed. 1c should be noted chat all flushing fluids will require dljposal by methods approved for PCS'. t q$ c iv t>/- 'V V ---4; > Y 1<* Lj 38 1 784087 Q&& t Ccnclusicns and aecorrcrdations In this ego of environmental awareness and social activism, cany chemical substances will be scruti nized Intently. Regardless of Its relative impact, PCS is currently being cited as the leading hazardous chcaical which warrants control. Industry faces a new round of regulations^, reports, and costs. Aa with any such issue, the cost can be best controlled by gathering information, making unemotional judg ments, and planning to taka the appropriate action before the cltaticns are issued. Specifically, these steps are recommended: 1. Define the problem in the plant. Locate each item and assess the probability of damage or loss, estimate the ccsc of equipment protection and spill control. 2. Cat information from the vendors on their new equipment, including very specific data to back any claims of environmental properties. figure 2 fq u ri 2 - l '2 \ 2 ` TncMcrco-Q'ei'r1 3. For transformers, determine the efficacy of retrofllling and the probable availability of topping fluid. A. Proceed with protection, retrofilling, or replacement on a scheduled basis. In many instances, che choice will not be obvious, and it is suggested that it is better to err on the side of greater environmental protection. 3. In sooe instances where only a few pieces of equipment are involved, consider that total elimi nation of askarel may cost less than the hidden costs of continually reporting. Inspecting, etc. Tttracfiloro 8'&>**/* $^ Noone can be completely sure that Che steps taken will preclude a costly spill of this hazardous chemi cal. Should one occur, however, che plant Chat has evinced awareness end effort will fare better with the regulatory agencies and the public chan a plant which Ignored che problem of PCB's. fig u re J - Pmsi& e P C S **eioOo*'e% T riitfin a n l a . U x n taa 1 t il l SUa rir. n aet 2 ii a (li J k 5 V ttlM SW | ttc . Iff. Veat C asM icr kra IV Waa> 2 SO a a . laaalK IM nu C al. le e fta e a 1(2 o n 300 It Ik l l F a te x tla l Caatata a f S f l l l S ik h . C ut14* k l 4 ( . . M till frtv * 2 lU aa. fa rk ll/l a n a taw . O aciU a b i l l . . {m e * 4 , n a t r a f f i c cx 1000 rytumml 210 * 4 1 1 1 . U a fk i r a a . C n ira i* i fak rlca tle a . Sta* Slav ita a V trM af C av lraen eetal S K lU Iv lIT **v4 t u e . C a e c r r t a p e l . a a c v r k , ICO f t . f r e e < raia* ie -H ln e . C aeerate sa4. n a c u r , SO f t . f r e e fralaa a W ith. 20 f t . f r e e f r i i n a t i f le c k , *e F lat fare V bd l4U| ?ekeieclt (Ilk af )( ( U l O a tr a a af C a a l r i 5a- -fr. Ho 14-Ail. Om t i i f < 1 1 11 fta a a lt !!* l - c c :<B nrC rm - Cf 1t a x is L-- . tMUf Cnifii 2 -2 S L tl T* f< KOO ( l i t 200) Vjt. fa11- m i H Lm Tralflc. 11(11 1 t k . C w r u t r a v e l U tr M .it. 7 )' fra H*T. ftf. r l r a r i * . U i t t r i >< f w u i i a n i l t t r i 784088