Document X5QEXGNka2K19nY98okMybeB

December 3, 1973 Chairman of the Board of Standards Review American National Standards Institute 1430 Broadway New York, N. Y. 10018 Dear Sir: The National Electrical Manufacturers Association (IfEMA), wliicn serves as Administrative Secretariat for the American Na tional Standards Committee, C107, on Use and Disposal of Askarel and Askarel-Soaked Materials, is pleased to submit, on bahalf of the k Comrittee, the following proposal for approval and publication L> as ap America.- Matiohal'Standaf3T~ Proposed American National Standard Guidelines for Handling and Disposal of Capacitor- and Transformer-Grade Askarel* Containing Polychlorinated Biphenyls, C107.1- ( ) (NEMA Publication Numbers CP-P1-1973 and TP-P6-1973). Copies of the proposal were submitted for concurrent review comments on the same date of issuance of the Committee letter ballot, namely, July 18, 1973. The scope of the proposal includes recommendations for han dling and disposal of askarel and askarel-soaked materials, sum mary of disposals services and analytical procedures. The Droposals for these recommendations were developed within the Committee, based on experience qained by manufacturers and users of transformers and capacitors and information developed bv Monsanto, ASTM and IEEE. A summary of accummulated recommenda tions for the first revision of the standard is attached as EX HIBIT "A". r The letter ballot indicated that the Committee will begi immediately with the first revision, a process that will take some time to complete. We believe that the C107 Committee has complied with all of the requirements of the Board of Standards Peview, as listed in BSP 4.1.1. To the best of its abilitv, the C107 Committee has also complied with the ANSI procedures, under the Standards Committee method. Cont'd- - - NPC00016280 207966 t The results of balloting are, as follows: Members elidible to vote Affirmative votes Negative votes Affirmative votes with comments Negative votes with comments No reply after followup Not voting 22 19 0 1 0 0 2 The roster of membership of C107 is attached. Sincerely yours, .tuyA-^r'"' AJ M. Salazar, Secretary A.MS :dk Att : CC: All members of Cl07 Comm. C.K. Poarch EEI Staff S. Sherr, IEEE Staff Tvler Nourse, Electronics Inds. Assoc. Managinq Director, Certified Ballast Mfrs. Assoc. J.J. Kark, NEMA Staff 2- - N P C 00l-62d T: V 207967 SUMMARY o r PKCOMMUNDATIONS FOP THE r i P S T REVTfiTON OF ANSI C 1 Q 7 . 1 - ( NOTE All recommendations were listed in the coverinq letter for the letter ballot except (C), which was submitted with an affirmative vote. Proposed by Mr. C. C. Travis "While it may not be practical at present to exercise meaninoful control over the disposition of devices and equipment in which small capacitor units arc used (see paragraph A2, page 8), we cannot conclude thajt meaningful control will not be practical in the future. Accordingly, in view of such a possibility, the devices and/or equipment should be labeled to the extent of showing that some components contain PCB's. A label will facilitate control over disposal at a later date if determined to be practical." Proposed by Mr. w, B, Papageorge "A recent incident in which askarel fluid in a transformer on its way to the customer was Dermitted to drain onto farm land dramatically hiqhlights the need for specific instruc tions that can be made available to private and oublie car riers to instruct them in the prooer handling of askarels during emergency conditions." Proposed by L. E. Wagner "Total disposal pan be accomplished at 3000F with only half second retention time. In actual operations we have proven that the factors involved in proper disposal of askarel are: 1. Retention time 2. Temperature 3. Concentration In other words, we can and have, in fact, accomplished the oroper destruction of askarels by limiting the concentration of askarels to 5% in the totel liquid stream to be destroyed. We feel that this should be considered in the next revision." Proposal'Submjtted by Mr. P. L. Derby (ATTACHED)__ 1 EXHIBIT "A" NPC00016282 y 207968 PROPOSAL A system for handling, shipping and disposing of transformer grade, sample service askarel wastes to provide environmental safe ty. Servicing of aakarel-containing transformers requires the drawing of repre sentative samples of the fluid. Generally, two to four quarts are obtained from the main drain valve and an additional quart from the sample bottle rinse. The procedure la repeated for a transformer top sample. The waste quantity will vary fro one to two gallons per transformer, depending on service company procedure. Integrity of containers presents a problem, as does the possibility of accidental spills during handling. Such spills could result in sever or ground contamination. In addition, prolonged storage and deterioration of the filled containers could cause leakage and further con tamination. Another potential source of contamination is damage during ship ping. Lack of a simple, efficient disposal- system may be the reason for unauthorized disposal of the ask-arel wastes into rivets and streams. Standardized /ontai:u*j and coll. . proceuutc, a of aulldlfying the aakarel wastes, and authorized disposal should help eliminate the environ mental threat. The system we propose is as follows: Providing a fiberboard carton containing four one-gallon plastic cube containara with appropriate closures and a four-pack fiberboard pre addressed package. Each cube container will be loaded with a pre-detarmlned quantity of Dow Imbiber Beads, a product that will solidify the waste aekarels within minutes. The outer package is pre-addressed for delivery to an authorized solid waste incinerator or aupervlsed dry land fill site for disposal. The advantages of the system we propose are: .. A standard container for disposal. .. A method for solidifying the askarel wastes to prevent leaks or other accidental contaminating spills. .. A method of environmentally sound containment when disposed of in dry land fill and assurance that such disposal will be accomplished by authorized personnel and procedures. .. A product and container that meets the requirements for environmentally aound high temperature Incinerator disposal. -- 2 .vV EXHIBIT "A" NPC00016283 207969