Document YjMKEYGGqBEVz12Mxbx8n5vq0

.KCK3ICU 2ES0U*CIS f t ^sisciaic \ RAO. scKtKSCUor, n. t.'1:303 & y, t..* >*V > CV O *f D3 rT-f.* liter 1 *235-2261 TATUS RE?CRT TO CUSTOMERS CM ?CB ` aly 24, 1972 . . COPIES: J. F. Toung J. F. KcAllister J. S. Anderson C. K, Rescue J. V. Blake D. F. Cross L. L. Dengler E. L. Dobbins J. A. Donna1ley R. V. Frahm D. A. Franke . V. . Gaither : deposition j ?r exhibit 1A/t'iSo'O j C. H. Love V. P. Hamby V. T. Kinsey H. D. Lsube 0. H. LeBlanc V. F. Karx * V. F. Powell A. Fozefsky E. L. Raab J. F. Repko V. K. Rodgers E. R. Bute m a n E. L. Simons H. B. Williams ssrs. K. H. Christiansen - Agency & Distributor Sales Div. V. L. Clarke - Apparatus Sales & Service Dept. - Canadian CE S. V. Corbin - Industrial Sales Div. . ___ J. J. Farrell - Power Trans forcer Products Dept. *-.' ' * G. H. Hupman - International Bus. Support Operations L. P. Hart, Jr. - Industrial & Fever Capacitor Products Dept. R. T. Harris - Medium Transformer Products Dept. I. J. Petersen. - Distribution Transformer Products Dept. D. F. Rank ine - Fover Transmission & Distribution Dept. -.Canadian CE V. R. TSckaberry - Fover Transmission & Distribution Seles Div. C. C, Thomas - Installation & Service Engrg. BusinessDept. P. C. .Van Dyck - Apparatus Services Business Div. ieral Electric customers vere informed in 1970 of the environmental concern leh had arisen over polychlorinated biphenyl materials (?C5*s) through the wideread distribution of the **Cpen Letter to Industrial Customers" and "Open Letter Electric Utility Customers'* and by other means. Since that time a great deal has :n accomplished to bring this situation under control. In particular, the responses cognizant agencies of the federal government have assiaed a greater degree of .dictability. Now that the Interdepartmental Task Force repoTt has been published, can give customers additional assurance that there will be a continued source of iply of Pyranol capacitors and transformers and that their application is consonant * :h ehe public interest. The accompanying statement has been prepared as a basis ' such customer communication, and has been approved by legal counsel of the nsforoer and Distribution Equipment Division and the Electronic Components Division. Kelson, Consultant Envircimaental Compatibility :cv aehment fr 775095 | A > GENP 003507 ADVICE TO GENERAL ELECTRIC CUSTOMERS CONCERNING PC3 (PYEAKOL) fR) 1. . FEDERAL GOVERNMENT REPORT SANCTIONS CONTINUED USE OF PCS IK TRANSFORMERS AND CAPACITORS 1! ' General Elec crie customers cay continue Co purchase* and apply General Electric Fyranol transformer* and capacitors, secure in the knowledge Chat all cognizant US government agencies are'parties to a report sanctioning Che continued use of polychlorinated biphenyls (PCS) in such apparatus- The following paragraph is quoted iron one of the findings in which the goverrznent's Task Force concurred: "6. The use of PCB's should not be banned entirely. Their continued use for transformers and capacitors in the near future is considered necessary because of Che significantly increased risk of fire end explosion and the disruption of electrical service which would result from a ban on PCS use. Also, continued use of PCZ's in transformers end capacitors pesents a minimal risk of environmental contamination. Th Monsanto Company, the sole domestic producer, has reported voluntarily * eliminating its distribution of PGo's to all except manufacturers of electrical transformers and capacitors." -- PC S 1 end the Environment, Sby the Interdepartmental Task Force on PCD's sponsored by the Departments, of Agriculture; Commerce; Health, Education, end V-lfcre; and Interior. ^ Also sponsored by the Environmental Protection Agency, plus other partici pe tin g agencies. Published Hay, 1972, distributed by KTIS, Springfield, Virginia 22151, under access m m b e r CC3-72-10&19. The report cay be ordered for $.00. 2. APPLICATIONS IN THE FOOD INDUSTHT The FDA has Issued a proposed rule making concerning the application 6f PCS's in human foods, animal feeds, and food-packaging material (Federal Register, 37-54-5705, March 18, 1972). From our reading of the proposed rule, it does not eppear to be the intent to outlav either capacitors or transformers when applied in accordar.ee with the manufacturer's ratings and installed separately from that equipcenc which is in direct contact with the food, feed, or food-packaging material being processed. Ve have written to the Hearing Clerk of the Department of Health, Education, and Welfare with the suggestion that the exemption of capacitors and transformers so applied be made explicit in the final version of the proposed rules. Ve anticipate concurrence by Che Department of KZV, In view of the following paragraph contained in their Draft Environmental Itpact Statement of May S, 1972, regarding the Notice of Proposed Rule Making, Polychlorinated Biphenyls: o<S\ m rr- "3. An exception to the proposed special provisions eliminating certain industrial uses of PCB'a will per*it the continued use of T h iselectrical power equipment containing PCS'* in regulated establishments. us'r of FC3*a la considered essential and presents only a minimal risk of accidental contamination of fowl and the cnvlrermcnt." '-- - GENP 003508 * -2- anticipates legislation It will be noted that progress in controlling possible adverse environ- . oentzl effects from PCE's has come about largely as the result of private industry ; initiatives in Halting applications to situations which are controllable, l.e., Che use o PCS'* in sealed transformers and capacitors. As noted in the Task Force report cited above: * "The government has no power to restrict Imports of FCB's by foreign manufacturers and if it disagreed with Monsanto's judgment on allowable uses it could not impose Dor stringent limitations on Monsanto or on any other potential manufacturer. a "This regulatory gap would be filled by the Administration's proposed Toxic Substances Control Act...." We see no reason to anticipate that the passage of the Toxic Substances Control CZAct- will affect the continued availability of Fyranol transformers and capacitors. While sore restrictive legislation was at one time proposed (by Congressman Ryan of New York), it was prepared before the findings of the Task Force were available, and has never come out of cositcee. * APPARATUS rCR EXPORT Those intending to export PCS-centaicing apparatus to certain foreign countries are advised to check for possible import restrictions. Japan and Sweden, for example, are known to have enacted restrictive legislation and/or license requirements. 5. DISPOSAL The electrical industry, having recognized that continuation of the public benefits resulting from the use of PC3as rests in part upon industry cooperation and success In keeping this material out of the country's water system, has formed Committee C107 of the American National Standards Institute to erect guidelines for the proper handling of FCS's in manufacture and upon ultimate disposal. General Electric intends to promote full compliance with these guide lines, thus helping to implement an additional recommendation contained in the Interdeparmcantal Task Foree Report, nscely, "an educational campaign aimed at users to assure proper disposal." The ANSI guidelines are expected to provide for high-temperature incineration of surplus PCS liquids (e.g., fluid discarded from a transformer) and disposal in properly-managed land-fill operations of solid material which has been in cot act with FCB's (e.g., discarded capacitors). Three pertinent statements froa the Task Force report may be noted in connection with these proposed procedures: CCP"t iiOsn r- GENP 003509 (X) "Incineration at 2000 F or above for two seconds will destroy FC3's...." (2) "PCI containing material burled In'soil is not expected to migrate but should remain in place." -- / r t 3 (3) "PCB's are being designated as hazardous substances under Section 12 (of the Federal Water Pollution Control Act), and the authority contained in the section could be used if an accidental spill of PCB'a into water should occur." (The referenced authority concerns notification and clean-up responsibilities, etc.) . Fending proaulgation of the ANSI guidelines, those With a disposal problea are requested to contact the appropriate General Electric field sales office. GENP 003510 775098